NOTICE OF CLASS ACTION SETTLEMENT

IF YOU ARE AFRICAN AMERICAN AND YOU HAD TO UNDERGO
AN ID PROCEDURE TO ENTER A CHECK INTO CASH STORE IN CALIFORNIA AT ANY TIME
FROM FEBRUARY 9, 2012 THROUGH NOVEMBER 23, 2021 (“CLASS PERIOD”), A PROPOSED CLASS ACTION SETTLEMENT HAS BEEN REACHED THAT MAY AFFECT YOUR RIGHTS

The Los Angeles Superior Court authorized this notice.
This is not a solicitation from an attorney.

What is this notice about?

On February 8, 2016, a group of six individuals (“Plaintiffs”) filed a lawsuit entitled Christina Harvey; Dyrius Groomes; Tyrie Dedrick; Armond Person; and Anthony Logan, on behalf of Themselves and the Class; Deron Hollins, Plaintiffs, vs. Check Into Cash, Inc., an entity of unknown form; Check Into Cash of California, Inc., an entity of unknown form; and Does 1 to 10, inclusive, Defendants, Los Angeles Superior Court Case Number BC609540, alleging that Check Into Cash required African Americans to show ID prior to entering into its California locked stores but did not require that process from non-African Americans (the “Action”). The parties have reached a proposed class action settlement (“Settlement”), which the Court preliminarily approved on November 23, 2021.

You are a member of the class if you are an African American who was asked to show ID before entering into any Check Into Cash locked store in California at any time from February 9, 2012 to November 23, 2021.

Check Into Cash disputes all of the claims asserted in the Action and enters into this Settlement for the sole purpose of avoiding the operational burden, expense, distraction, and uncertainty of continuing litigation. The Court has not decided any of the contentions of the parties. This notice is not to be understood as an expression of any opinion by the Court as to the merits of the claims asserted by Plaintiffs. Check Into Cash denies all liability, is confident that it has strong legal and factual defenses to Plaintiffs’ claims, and asserts that it has always properly complied with all applicable laws and regulations. Check Into Cash contends that its conduct is and has been lawful at all times relevant and that Plaintiffs’ claims do not have merit and do not meet the requirements for class certification.

This Settlement is a compromise reached after good-faith, arm’s length negotiations between the parties, through their attorneys and with the assistance of a third-party neutral, and is not an admission of liability on the part of Check Into Cash.

The purpose of this notice is to provide you with a brief description of the Action, to inform you of the Settlement terms, to describe your rights in connection with the Settlement, and to explain what steps you may take to participate in, object to, or exclude yourself from the Settlement. If you do not timely exclude yourself from the Settlement, and the Court finally approves the Settlement, you will be bound by the terms of the Settlement and any final judgment.

What are the Settlement terms?

Subject to final Court approval, Check Into Cash will pay: (1) each of the six named Plaintiffs $10,000, for a total of $60,000, to fully and finally resolve their individual claims against Check Into Cash; (2) a $10,000 enhancement payment to class representative Christina Harvey for representing the class’s interest; (3) a $4,500 enhancement payment to class representative Anthony Logan for representing the class’s interest; and (4) $142,500 in attorneys’ fees and costs to Plaintiffs’ counsel. Subject to final Court approval, Check Into Cash is also agreeing to implement a new policy at its California stores which are locked during normal business hours.

What will I receive under the Settlement?

The implementation of a new policy at Check into Cash’s California stores which are locked during normal business hours on how patrons are admitted.

Do I have a lawyer in this case?

Class Members are represented by the Law Office of Mark Mazda, Plaintiffs’ counsel, who is experienced in classaction litigation. If you want to be represented by your own attorney, you may hire one at your own expense and enter an appearance through your own counsel.

How will the lawyers be paid?

Subject to final Court approval, the Law Office of Mark Mazda will be paid by Check Into Cash in the amount of $142,500 for attorneys’ fees and costs. You are not responsible for paying this attorney anything.

What are my options?

1. Do nothing. If you do nothing, and if the Court finally approves the Settlement, you will be considered part of the Class and you will be bound by the Settlement and you will release Check Into Cash, its present and former parent companies, subsidiaries, related or affiliated companies, shareholders, officers, directors, employees, agents, attorneys, insurers, successors and assigns, and any individual or entity which could be jointly liable with Check Into Cash and its respective present and former parent companies, subsidiaries, related or affiliated companies, shareholders, officers, directors, employees, agents, attorneys, insurers, successors and assigns, from any and all claims and/or causes of action arising from or related to the Action under any federal, state or local law or administrative order that were pled or could have been pled in the instant action based on the facts alleged in the Action or which arise out of or directly or indirectly relate to such facts, whether known or unknown, including but not limited to violations of the Unruh Civil Rights Act, and any other claims whatsoever that were alleged in the Action or which arise out of or directly or indirectly relate to such facts, including without limitation all related and derivative claims for penalties, punitive damages, and restitution or other equitable relief under Business and Professions Code § 17200 et seq. for the Class Period (“Released Claims”). Upon the Court’s final approval of the Settlement, you will also waive and relinquish with respect to the Released Claims, any and all provisions, rights, and benefits of Section 1542 of the California Civil Code, and any and all similar provisions, rights, and benefits conferred by any law of any state or territory of the United States or principle of common law that is similar, comparable, or equivalent to Section 1542 of the California Civil Code, which provides: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR  SUSPECT  TO EXIST  IN HIS  OR  HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.” The full terms of the Released Claims are contained in the Stipulation of Settlement that is available in the public court records on file in this Action.

2. Exclude yourself from the Settlement. If you do not wish to take part in the Settlement, you may exclude yourself by mailing or delivering to the parties’ counsel a written request for exclusion so that it is actually received no later than January 31, 2022. To be valid, the written request must include your full name, current address, telephone number, and signature. The Request for Exclusion from Settlement should state:

“I WISH TO BE EXCLUDED FROM THE CLASS IN THE HARVEY, et al. v. CHECK INTO CASH, INC., et al. CLASS ACTION LAWSUIT, LOS ANGELES SUPERIOR COURT CASE NO. BC609540.”

Send your request for exclusion to both of the following locations:

Mark Mazda Law Office of Mark Mazda 2601 Main Street, Suite 1200 Irvine, CA 92614

Michael A. Hood Kathy A. Le JACKSON LEWIS P.C. 200 Spectrum Center Drive, Ste. 500 Irvine, CA 92618

Any person who submits a valid and timely request for exclusion shall, upon receipt, no longer be a Class Member, shall be barred from objecting to or participating in any portion of the Settlement because the Settlement no longer affects him or her, and shall receive no benefits from the Settlement. Class Members who do not exclude themselves from the Settlement pursuant to the procedures set forth in this notice will be bound by the Settlement and will release their claims against Check Into Cash.

3. Object to the Settlement: If you do not exclude yourself from the Settlement, you have the right to object to the terms of the Settlement if you do not like any part of it. However, if the Court rejects your objection, you will still be bound by the Settlement terms. If you wish to object to the Settlement, or any portion of it, you must file with the Court and serve on the parties’ counsel your written objection so that your written objection is actually received by the Court and the parties’ counsel no later than January 31, 2022. The objection must be in writing, state the case name and case number, explain the basis of your objection, provide supporting authority (if available), provide your full name, current address, telephone number and signature, and state whether you are represented by your own counsel.

Send your objection to all three of the following locations:

Clerk of Court Superior Court of California County of Los Angeles 111 N. Hill Street Los Angeles, CA 90012

Mark Mazda Law Office of Mark Mazda 2601 Main Street, Suite 1200 Irvine, CA 92614

Michael A. Hood Kathy A. Le JACKSON LEWIS P.C. 200 Spectrum Center Drive Suite 500 Irvine, CA 92618

The Final Approval Hearing is scheduled for February 23, 2022, at 11:00 a.m. in Department 12 of the Superior Court of California, County of Los Angeles, Spring Street Courthouse, located at 312 North Spring Street, Los Angeles, CA 90012. The Final Approval Hearing may be postponed without further notice to the Class; however, if you have returned a written objection, the parties will notify you of changes in the hearing date. You have the right to appear either in person or through your own attorney (at your own expense) at this hearing. If you intend to appear at the Final Approval Hearing to discuss your objections, your written objection letter should include a Notice of Intention to Appear at the Final Approval Hearing. Any attorney who intends to represent an individual objecting to the Settlement must file a notice of appearance with the Court and serve counsel for all parties no later than February 18, 2022.

If you object to the Settlement, you will remain a member of the Class, and if the Court finally approves the Settlement, you will be bound by the terms of the Settlement, including the release of claims stated above, in the same way as Class Members who do not object.

When will the Court decide whether to finally approve the Settlement?

The Court will hold a Final Approval Hearing on February 23, 2022 at 11:00 a.m. at the Superior Court, County of Los Angeles, Spring Street Courthouse, Department 12, 312 North Spring Street, Los Angeles, CA 90012. At this hearing, the Court will consider whether the settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them at that time. At or after the hearing, the Court will decide whether to finally approve the Settlement.

Do I have to come to the Final Approval Hearing?

No. You are not required to attend the Final Approval Hearing, but you are welcome to attend the hearing at your own expense. You may also pay your own lawyer to attend the hearing, but it is not necessary.

May I speak at the Final Approval Hearing?

You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must file with the Court a “Notice of Intention to Appear.” Be sure to include your name, address, telephone number, and your signature. Your Notice of Intention to Appear must be filed with the Court no later than February 18, 2022, and must also be served on Class Counsel (Law Office of Mark Mazda) and Check Into Cash’s counsel (JACKSON LEWIS P.C.). The addresses for the Court, Class Counsel, and Check Into Cash’s counsel are listed above. You cannot speak at the hearing if you are not a Class Member or an attorney representing a Class Member.

How can I get more information?

This notice is only a summary of the Action and the Settlement. The Stipulation of Settlement and documents filed in connection therewith contain the complete terms of the Settlement. For more information, you can go to www.harveysettlement.com. You can also inspect the Stipulation of Settlement and the Court’s files in this Action at the Court Clerk’s office at 111 N. Hill Street, Los Angeles, CA 90012 during regular Court hours or via the Court’s website at lacourt.org.

PLEASE DO NOT CALL OR WRITE TO THE COURT FOR INFORMATION OR ADVICE
ABOUT THIS SETTLEMENT OR THE SETTLEMENT PROCESS

Dated: November 23, 2021

/s/ The Honorable Carolyn B. Kuhl Jude of the Superior Court County of Los Angeles