Jade Brooks vs. Bad Bakers Inc

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

Tentative Ruling

Plaintiff Jade Brooks’s (“Plaintiff”) motion for preliminary approval of the Parties’ class action and Private Attorneys General Act (“PAGA”) settlement is UNOPPOSED and tentatively GRANTED, subject to the revised Notice requested below.

Moving counsel’s Notice of Motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06. Moving counsel is directed to contact opposing counsel and advise them of Local Rule 1.06, the Court’s tentative ruling procedure, and the manner to request a hearing.

Status Conference (Compliance Hearing) is scheduled for 08/07/2026 at 10:30 AM in Department 8B at Tani G. Cantil-Sakauye Courthouse.

Hearing on Motion for Final Approval of Settlement is scheduled for 12/18/2026 at 9:00 AM in Department 8B at Tani G. Cantil-Sakauye Courthouse.

The Court has provided specific direction on the information and argument the Court requires to grant approval of a class action settlement. The Parties shall carefully review the Checklist for Approval of Class Action Settlements and fully comply with each applicable item to ensure a prompt ruling from the Court.

Background

On December 29, 2022, Plaintiff filed a putative wage and hour class action complaint against Defendant Bad Bakers, Inc. (“Defendant”) for: (1) failure to pay minimum and straight time wages (Labor Code §§ 204, 1194, 1194.2, and 1197); (2) failure to pay overtime wages (Labor Code §§ 1194 and 1198); (3) failure to provide meal periods (Labor Code §§ 226.7 and 512); (4) failure to authorize and permit rest periods (Labor Code § 226.7); (5) failure to timely pay final wages at termination (Labor Code §§ 201-203); (6) failure to provide accurate itemized wage statements (Labor Code § 226); (7) failure to indemnify employees for expenditures (Labor Code § 2802); and (8) unfair business practices (Business and Professions Code §§ 17200, et seq.). (Nguyen Decl., ¶ 4.)

Plaintiff sent a notice to Defendant and the California Labor & Workforce Development Agency (“LWDA”) alleging similar wage and hour violations pursuant to the PAGA on January 13, 2023. (Id., ¶¶ 4, 9, Exh. 2.) On November 12, 2025, Plaintiff filed a PAGA representative action complaint against Defendant for civil penalties under PAGA. (Id., ¶ 4.)

Plaintiff now seeks preliminary approval of the Parties’ Class Action and PAGA Settlement

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

Agreement and Class Notice (“Agreement”). (Nguyen Decl., ¶ 8, Exh. 1 (“SA”).) Counsel submitted the settlement to the LWDA. (Id., ¶ 9, Exh. 2.)

Legal Standard

The law favors the settlement of lawsuits, particularly in class actions and other complex cases where substantial resources can be conserved by avoiding the time, expense, and rigors of formal litigation. (See Neary v. Regents of Univ. of Cal (1992) 3 Cal.4th 273, 277-281; Lealao v. Beneficial California, Inc. (2000) 82 Cal.App.4th 19, 52.) However, a class action may not be dismissed, compromised, or settled without approval of the court, and the decision to approve or reject a proposed settlement is committed to the court’s sound discretion. (See Cal. Rules of Court, Rule 3.769; Wershba v. Apple Computer, Inc. (2001) 91 Cal.App.4th 224, 234-35 (Wershba).)

In determining whether to approve a class settlement, the court’s responsibility is to “prevent fraud, collusion or unfairness to the class” through settlement because the rights of the class members, including the named plaintiffs, “may not have been given due regard by the negotiating parties.” (Consumer Advocacy Group, Inc. v. Kintetsu Enters. of Am. (2006) 141 Cal.App.4th 46, 60.) The court must independently determine “whether the settlement is in the best interests of those whose claims will be extinguished” and “make an independent assessment of the reasonableness of the terms to which the parties have agreed.” (Kullar v.

Foot Locker Retail, Inc. (2008) 168 Cal.App.4th 116, 130, 133.) The burden of establishing the fairness and reasonableness of the settlement is on the proponent. (Wershba, supra, 91 Cal.App.4th at p. 245; see also 7-Eleven Owners for Fair Franchising v. Southland Corp. (2000) 85 Cal.App.4th 1135 1165-66.)

The Court does not rubber stamp these motions, but rather serves as a guardian of absent class members’ rights to ensure the settlement is fair. (Luckey v. Superior Court (2014) 228 Cal.App.4th 81, 95.) “Ultimately, the [trial] court’s determination is nothing more than ‘an amalgam of delicate balancing, gross approximations and rough justice.” (7-Eleven, supra, 85 Cal.App.4th at p. 1145.) “A settlement need not obtain 100 percent of the damages sought in order to be fair and reasonable. Compromise is inherent and necessary in the settlement process.

Thus, even if ‘the relief afforded by the proposed settlement is substantially narrower than it would be if the suits were to be successfully litigated,’ this is no bar to a class settlement because ‘the public interest may indeed be served by a voluntary settlement in which each side gives ground in the interest of avoiding litigation.’” (Wershba, supra, 91 Cal.App.4th at p. 250, citations omitted.) The court’s primary objective for preliminary approval is to establish whether to direct notice of the proposed settlement to the class, invite the class’s reaction, and schedule a final fairness hearing. (Rubenstein et al., Newberg on Class Actions (6th ed. 2025) § 13:10.)

Provisional Class Certification

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

If the class has not yet been certified, part of the motion for preliminary approval will include a request for provisional certification for purposes of settlement only. (See Cal. Rule of Court, Rule 3.769.) Although the provisional process is less demanding than a traditional motion for class certification, a trial court reviewing an application for preliminary approval of a settlement must still find that the normal class prerequisites have been met. (See Amchem Products, Inc. v. Windsor, 521 U.S. 591, 625-627 (1997); in accord, Carter v. City of Los Angeles (2014) 224 Cal.App.4th 808, 826.)

Here, Plaintiff seeks provisional certification of the following class: “all current and former hourly, non-exempt employees employed by Defendant in the State of California during the Class Period.” (SA, ¶ 1.5.) The Class Period means the period from December 29, 2018 through October 10, 2024. (Id., ¶ 1.13.)

Plaintiff argues that provisional certification is appropriate because (1) the Class is ascertainable because the definition is objective and sufficiently clear; (2) the Class of approximately 394 individuals is sufficiently numerous; (3) common issues of law and fact predominate because Plaintiff challenges Defendant’s employment policies and practices; (4) Plaintiff’s claims are typical of the Class because Plaintiff is a former employee and was subject to the same policies and practices; (5) Plaintiff is an adequate representative because Plaintiff retained qualified Counsel, has no conflicts, and has diligently litigated this action on behalf of the Class; and (6) a class action is superior to a multiplicity of litigation (Mot., pp. 17:15-22:6.) The Court finds Plaintiff’s arguments persuasive and provisionally certifies the Class for settlement purposes for the reasons specified in Plaintiff’s moving papers.

Class Representative and Class Counsel

Plaintiff is preliminarily appointed Class Representative. (SA, ¶ 1.14.) Tyler J. Woods of Wilshire Law Firm, PLC is preliminarily appointed as Class Counsel. (Id., ¶ 1.6.)

Fair, Adequate, and Reasonable Settlement

Before approving a class action settlement, the Court must find that the settlement is “fair, adequate, and reasonable.” (Dunk v. Ford Motor Co. (1996) 48 Cal.App.4th 1794, 1801.) The Court considers such factors as “the strength of plaintiffs’ case, the risk, expense, complexity and likely duration of further litigation, the risk of maintaining class action status through trial, the amount offered in settlement, the extent of discovery completed and the stage of the proceedings, the experience and views of counsel, the presence of a governmental participant, and the reaction of class members to the proposed settlement.” (Ibid.) “[A] presumption of fairness exists where: (1) the settlement is reached through arm’s-length bargaining; (2) investigation and discovery are sufficient to allow counsel and the court to act intelligently; (3) counsel is experienced in similar

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

litigation; and (4) the percentage of objectors is small.” (Id., at p. 1802.)

Under the terms of the Agreement, Defendant denies liability, but agrees to pay a Gross Settlement Amount (“GSA”) of $125,000 to resolve Plaintiff’s claims. (SA, ¶¶ 1.23, 3.1, 11.1.) The GSA is non-reversionary and does not include employer payroll taxes owed on the wage portions of the Individual Class Payments, which Defendant will pay separately. (Id., ¶ 3.1.) The GSA will be paid as follows: $65,000 to be paid 30 days after the Court issues an order approving Plaintiff’s motion for final settlement approval; and $60,000 to be paid six months after the Court issues an order approving Plaintiff’s motion for final settlement approval. (Id., ¶¶ 3.1.1, 3.1.2, 4.3 [this paragraph indicates Defendant shall fund the GSA no later than 30 days and 6 months after the Effective Date[1]].)

The following amounts will be paid from the GSA: - $41,666.67 for Class Counsel’s attorneys’ fees and the reimbursement of Counsel’s litigation expenses not to exceed $20,000 (SA, ¶¶ 1.7, 1.8, 3.2.2); - $9,000.00 in administration costs (id., ¶ 3.2.3); - PAGA Penalties in the amount of $12,500 to be paid from the GSA, with 75% ($9,375) allocated to the LWDA PAGA Payment and 25% ($3,125) allocated to the Individual PAGA Payments (id., ¶ 3.25); and - $5,000.00 for the service award to Plaintiff for serving as the Class Representative (id., ¶ 3.2.1).

The remaining amount – the Net Settlement Amount (“NSA”) – is approximately $36,833.33 and will be distributed to the participating Class Members on a pro rata basis as Individual Class Payments. (SA, ¶¶ 1.24, 1.29.) An Individual Class Payment is calculated by (a) dividing the NSA by the total number of Workweeks worked by all Participating Class Members during the Class Period, and (b) multiplying the result by each individual Participating Class Member’s Workweeks. (Id., ¶ 3.2.4.) Similarly, the Aggrieved Employees’ portion of the PAGA Penalties will be allocated on a pro rata basis as Individual PAGA Payments, calculated by (a) dividing the amount of the Aggrieved Employees’ 25% share of PAGA Penalties ($3,125) by the total number of PAGA Period Pay Periods worked by all Aggrieved Employees during the PAGA Period, and (b) multiplying the result by each individual Aggrieved Employee’s PAGA Pay Periods. (Id., ¶¶ 1.25, 3.2.5.1.)

For tax purposes, 20% of each Individual Class Payment will be allocated to the settlement of wage claims and will be reported on an IRS W-2 Form. (Id., ¶ 3.2.4.1.) The remaining 80% will be allocated to the settlement of claims for interest and penalties and will be reported on IRS 1099 Forms. (Ibid.) The Administrator will report the Individual PAGA Payments on IRS 1099 Forms. (Id., ¶ 3.2.5.2.)

Not later than 15 days after the Court grants Preliminary Approval of the Settlement, Defendant will deliver the Class Data to the Administrator. (SA, ¶ 4.2.) Using best efforts to perform as soon as possible, and in no event later than 14 days after receiving the Class Data, the

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

Administrator will send to all Class Members identified in the Class Data, via first-class United States Postal Service (“USPS”) mail, the Class Notice with Spanish translation. (Id., ¶ 7.4.2.) Before mailing Class Notices, the Administrator shall update Class Member addresses using the National Change of Address database. (Ibid.) Not later than 5 calendar days after the Administrator’s receipt of any Class Notice returned by the USPS as undelivered, the Administrator shall re-mail the Class Notice using any forwarding address provided by the USPS. (Id., ¶ 7.4.3.)

If the USPS does not provide a forwarding address, the Administrator shall conduct a Class Member Address Search, and re-mail the Class Notice to the most current address obtained. (Ibid.) Class Members will have 45 days after the Administrator mails Notice to request exclusion from the settlement, submit written objection, or challenge their workweeks. (Id., ¶¶ 1.44, 7.5.1, 7.6, 7.7.2.) The Response Deadline will be extended an additional 14 days beyond the 45 days otherwise provided in the Class Notice for all Class Members whose notice is re-mailed. (Id., ¶¶ 1.44, 7.4.4.)

The Administrator will inform the Class Member of the extended deadline with the re-mailed Class Notice. (Ibid.)

Within 7 days after Defendant fully funds the GSA, the Administrator will mail checks distributing the settlement. (SA, ¶ 4.4.) The Administrator will issue checks for the Individual Class Payments and/or Individual PAGA Payments and send them to the Class Members via First Class U.S. Mail. (Id., ¶ 4.4.1.) Before mailing any checks, the Settlement Administrator must update the recipients’ mailing addresses using the National Change of Address Database. (Ibid.) Within 7 days of receiving a returned check, the Administrator must re-mail checks to the USPS forwarding address provided or to an address ascertained through the Class Member Address Search. (Id., ¶ 4.4.2.)

The face of each check shall prominently state the date (180 days after the date of mailing) when the check will be voided. (Id., ¶ 4.4.1.) For any Class Member whose Individual Class Payment check or Individual PAGA Payment check is uncashed and canceled after the void date, the Administrator shall transmit the funds represented by such checks to the California Controller's Unclaimed Property Fund in the name of the Class Member. (Id., ¶ 4.4.3.)

“Effective on the date when Defendant fully funds the GSA and all employer-side payroll taxes owed on the Wage Portion of the Individual Class Payments, Plaintiff, Class Members, and Class Counsel will release claims against all Released Parties as follows:” - Plaintiff is subject to a general release. (SA, ¶¶ 5, 5.1.) - “All Participating Class Members will waive and release all claims asserted in the Operative Complaint filed in the Class Action or that could have been alleged based on the factual allegations asserted in the complaint filed in the Class Action during the Class Period, including claims for: (1) Failure to Pay Minimum and Straight Time Wages under California Labor Code §§ 204, 1194, 1194.2, and 1197 and the applicable Industrial Welfare Commission (‘IWC’) Wage Order; (2) Failure to Pay Overtime Wages under California Labor Code §§ 510, 1194 and 1198 and the applicable IWC Wage Order; (3) Failure to Provide Meal Periods under California Labor Code §§ 226.7 and 512 and the

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

applicable IWC Wage Order; (4) Failure to Authorize and Permit Rest Periods under California Labor Code § 226.7 and the applicable IWC Wage Order; (5) Failure to Timely Pay Wages at Termination under California Labor Code §§ 201-203 and the applicable IWC Wage Order and any other applicable statute; (6) Failure to provide Accurate Itemized Wage Statements under California Labor Code § 226 and any other applicable statute; (7) Failure to Indemnify Employees for Expenditures under California Labor Code § 2802 and any other applicable statute; and (8) Violation of Business & Professions Code § 17200 et seq.” (Id., ¶¶ 5, 5.2.) - “The claims released by Aggrieved Employees, including Non-Participating Class Members who are Aggrieved Employees, are all claims for civil penalties under PAGA arising during the PAGA Period that were alleged or could have been alleged based on the facts alleged in Plaintiff’s PAGA Notice to the LWDA and the complaint filed in the PAGA Action,[2] or that could have been based on the facts asserted in the PAGA Notice and the complaint filed in the PAGA Action against Released Parties, including but not limited to, include, but are not limited to, penalties under California Labor Code §§ 201, 202, 203, 204, 210, 226, 226.3, 226.7, 510, 512, 1174, 1174.5, 1194, 1194.2, 1197, 1197.1, 1198, 2802, 2699(f)(2) and applicable Industrial Wage Orders” (Id., ¶¶ 5, 5.3.)

Plaintiff’s moving papers demonstrate that the settlement was reached after sufficient investigation and arm’s length negotiations. Following the filing of the Action, the Parties exchanged documents and information before going to mediation. (Nguyen Decl., ¶ 5.) Defendant produced a sample of time and pay records for Class Members and provided documents of its wage and hour policies and practices during the Class Period, and information regarding the total number of current and former employees in its informal discovery responses. (Ibid.)

After reviewing documents regarding Defendant’s wage and hour policies and practices and analyzing Defendant’s timekeeping and payroll records, Class Counsel was able to evaluate the probability of class certification, success on the merits, and Defendant ’s maximum monetary exposure for all claims. (Id., ¶ 6.) On November 9, 2023, the Parties participated in a private, Zoom mediation with experienced class action mediator Hon. Raul A. Ramirez (Ret.). (Id., ¶ 7.) The settlement negotiations were at arm’s length and, although conducted in a professional manner, were adversarial. (Ibid.)

In evaluating the settlement, Counsel also considered information discussed during mediation regarding Defendant’s financial condition. (Ibid.) While Parties were unable to resolve this Action during the November 9, 2023, mediation with the help of Judge Ramirez, the Parties were subsequently able to reach an agreement on general settlement terms and executed a Memorandum of Understanding on July 7, 2025. (Ibid.)

Counsel evaluated Defendant’s maximum exposure as follows:

Claim Maximum Exposure Discount Realistic Exposure Unpaid Work Time $63,560.67 80% $4,234.75 Meal Period Claim $135,484.80 80% $27,096.96

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

Rest Period Claim $135,484.80 80% $27,096.96 Reimburse Necessary $25,660.00 80% $5,132.00 Business Expenses Waiting Time Penalties $329,793.75 80% $65,958.75 Inaccurate Wage $329,500.00 80% $65,900.00 Statements PAGA $340,000.00 80% $68,000.00 Total: $1,359,484.02 $263,419.42

(Nguyen Decl., ¶¶ 18-25.) Counsel provides sufficient description of Plaintiff’s claims, Defendant’s defenses, the exposure above, and the risks of continued litigation. (Id., ¶¶ 15-27.) The GSA represents approximately 9.19% of Defendant’s maximum exposure and 47.45% of Defendant’s realistic exposure.

Counsel attests to their extensive experience in similar cases. (Nguyen Decl., ¶¶ 39-68.) Counsel attests to their belief that the settlement is fair, reasonable, and adequate. (Id., ¶ 14.) Based on the foregoing, the Court preliminarily finds, subject to the final fairness hearing, that the Settlement is within the ballpark of reasonableness and that all relevant factors support preliminary approval.

PAGA Payment

The Agreement provides for PAGA Penalties in the amount of $12,500 to be paid from the GSA, with 75% ($9,375) allocated to the LWDA PAGA Payment and 25% ($3,125) allocated to the Aggrieved Employees as Individual PAGA Payments. (SA, ¶ 3.25.) The Aggrieved Employees are “all current and former hourly, non-exempt employees employed by Defendant in the State of California during the PAGA Period.” (Id., ¶ 1.4.) The PAGA Period means the period from January 13, 2022 through October 10, 2024. (Id., ¶ 1.33.) As discussed above, the Aggrieved Employees’ portion of the PAGA Penalties payment will be distributed on a pro rata basis and the Aggrieved Employees are subject to a separate release. (Id., ¶¶ 3.2.5.1, 5.3.) The Agreement makes clear that Aggrieved Employees cannot opt out of the PAGA portion of the settlement. (Id., ¶ 7.5.4.)

Counsel estimated Defendant’s maximum PAGA penalty exposure is $340,000, based on a $100 penalty for all 3,400 pay periods. (Nguyen Decl., ¶ 24.) However, given Defendant’s defenses, the contested nature of the claims, and the discretionary nature of penalties, Counsel applied a discount of 80% for a realistic exposure of $68,000. (Ibid.) The PAGA allocation represents approximately 18.38% of Defendant’s realistic exposure and 3.68% of Defendant’s maximum exposure. The Court finds the PAGA allocation reasonable under the circumstances and is entitled to a presumption of fairness and it is preliminarily approved.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

Proposed Class Notice

The notice to Class Members must fairly apprise the prospective members of the terms of the settlement without expressing an opinion on the merits of the settlement. (7-Eleven Owners for Fair Franchising v. Southland Corp. (2000) 85 Cal.App.4th 1135, 1164; see also Cal. Rules of Court, Rule 3.769.) “Whether a claimant would want to accept or reject the proposed settlement is a decision to be made by him independently and without influence or pressure from those competing parties who either favor or oppose the settlement.” (Phila. Hous. Auth. v. Am. Radiator & Std. Sanitary Corp. (E.D. Pa. 1970) 323 F.Supp. 364, 378.)

The Notice fairly describes the settlement. (SA, Exh. A (“Notice”).) However, the following issues must be addressed: - The Notice includes the following language: “The Plaintiff, as well as Plaintiff’s lawyers (called ‘Class Counsel’), believe the Settlement is fair and reasonable and in the best interests of all Class Members.” (Notice, p. 3.) The Court finds this language is unnecessary and may improperly discourage class members from objecting to the settlement. Accordingly, it must be removed. - Effective April 13, 2026, the Court has moved to Department 8B in the new Tani G.

Cantil- Sakauye Courthouse located at 500 G St. Sacramento, California, 95814. Where an address and/or Department for the Court is inserted into the Notice, the Parties should use this new information. (Id., p. 8.) - The Notice should inform Participating Class Members that if they desire to appear remotely at the final approval hearing, they can join via the Department’s Zoom link or phone number and provide the following access information for the appropriate Department in the Notice: To join by Zoom link: https://saccourt-ca-gov.zoomgov.com/j/16184738886; To join by phone: (833) 568-8864 / ID: 16184738886. (Ibid.)

With these revisions, the Notice is approved.

Class Counsel Fees and Costs

The Agreement provides for a Class Counsel’s attorneys’ fees payment not to exceed $41,666.67 for and the reimbursement of Counsel’s litigation expenses not to exceed $20,000. (SA, ¶¶ 1.7, 1.8, 3.2.2.) Plaintiff argues that the requested fee award is reasonable as a percentage of the common fund and in line with typical cases. (Mot., pp. 12:6-14:2.) Plaintiff further argues that the fee award is appropriate because this matter involves a fee-shifting provision and is supported by the experience, reputation, and ability of Class Counsel. (Id., ¶ 14:3-15:2.)

The requested award is preliminarily approved. In moving for final approval, the Court expects Counsel to support their arguments with respect to this amount, including by providing information necessary to perform a lodestar analysis. (See In re Activision Sec. Litigation (N.D.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

Cal. 1989) 723 F.Supp. 1373, 1379; Consumer Privacy Cases (2009) 175 Cal.App.4th 545, 557- 58 & fn. 13.; Martin v. Ameripride Servs. (S.D. Cal. June 9, 2011), 2011 WL 2313604 at *22 (collecting cases); Vasquez v. Coast Valley Roofing, Inc. (E.D. Cal 2010) 266 F.R.D. 482, 491 (same); see also Chavez v. Netflix, Inc. (2008) 162 Cal.App.4th 43, 66 & n.11.)

The Court also preliminarily approves the Agreement’s cost allocation with the expectation that Counsel will provide a declaration, in moving for final approval, that shows actual costs.

Settlement Administrator

The Agreement designates Phoenix Class Action Administration Solutions (“Phoenix”) and provides for a settlement administration cost payment not to exceed $9,000, except for a showing of good cause and as approved by the Court. (SA, ¶¶ 1.2, 3.2.3, 7.1.) Counsel requested several bids from experienced settlement administrators and accepted the bid of Phoenix, which was the lowest out of the bids received. (Nguyen Decl., ¶ 10, Exh. 3.)

Phoenix is appointed as Settlement Administrator and the allocation is reasonable and preliminarily approved.

Class Representative Service Award

The Agreement provides for a $5,000 service award to Plaintiff for serving as the Class Representative. (SA, ¶ 3.2.1.) Plaintiff describes her efforts and estimates that she spent approximately 30 hours prosecuting this case. (Brooks Decl., ¶¶ 6-9.)

The requested service award is preliminarily approved.

Compliance Hearing

The Court sets a Compliance Hearing for August 7, 2026 at 10:30 a.m. No later than July 31, 2026, Plaintiff shall file a revised Notice and redline copy for the Court’s review.

If Plaintiff adequately addresses the Court’s concerns, the Court will sign the Proposed Order submitted with Plaintiff’s moving papers, and no appearance will be required.

Final Approval Hearing

The Court will again review and consider the terms of this settlement at the time of the final approval hearing. The Court sets a Final Approval Hearing for December 18, 2026 at 9:00 a.m. If either party is unavailable on that date, the parties shall meet and confer to identify three other Fridays at 9:00 a.m. that work for the parties to schedule the hearing. They shall then submit

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

those dates to the Court via email at Dept8B@saccourt.ca.gov, and the Court will reschedule the hearing accordingly.

The briefing shall be filed in conformity with Code of Civil Procedure section 1005.

[1] The “Effective Date” means “the date by which both of the following have occurred: (a) the

Court enters a Judgment on its Order Granting Final Approval of the Settlement; and (b) the Judgment is final. The Judgment is final as of the latest of the following occurrences: (a) if no Participating Class Member objects to the Settlement, the day the Court enters Judgment; (b) if one or more Participating Class Members objects to the Settlement, the day after the deadline for filing a notice of appeal from the Judgment; or (c) if a timely appeal from the Judgment is filed, the day after the appellate court affirms the Judgment and issues a remittitur.” (SA, ¶ 1.19.) [2] The Court assumes that the Agreement’s reference to the “PAGA Action” is erroneous since

the PAGA claims were raised via amendment to the class action complaint.

To request oral argument on this matter, you must call Department 8B at (916) 874-5762 by 4:00 p.m., the court day before this hearing and notification of oral argument must be made to the opposing party/counsel. If no call is made, the tentative ruling becomes the order of the court. (Local Rule 1.06.)

Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government Code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website. Parties may contact Court-Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore.

If you are not using a reporter from the Court’s Approved Official Reporter Pro Tempore list, a Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) must be signed by each party, the private court reporter, and the Judge. The signed form must be filed with the clerk prior to the hearing.

If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211). The form must be filed with the clerk at least 10 days prior to the hearing or at the time the hearing is scheduled if less than 10 days away. Once approved, the clerk will forward the form to the Court Reporter’s Office and an official reporter will be provided.

If oral argument is requested, the Parties are encouraged to appear via Zoom with the links

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00332118-CU-OE-GDS: Jade Brooks vs. Bad Bakers Inc 07/24/2026 Hearing on Motion for Preliminary Approval of Settlement Class Action and PAGA in Department 8B

below:

To join by Zoom link - https://saccourt-ca-gov.zoomgov.com/j/16184738886 To join by phone dial (833) 568-8864 ID 16184738886

Counsel for Plaintiff is directed to notice all parties of this order.

Please note that the Complex Civil Case Department now provides information to assist you in managing your complex case on the Court website at https://www.saccourt.ca.gov/divisions/civil/complex-civil-cases. The Court strongly encourages parties to review this website regularly to stay abreast of the most recent complex civil case procedures. Please refer to the website before directly contacting the Court Clerk for information.