The Class Representative filed this Action, on behalf of herself and purportedly on behalf of the putative Class Members, asserting that AMAZON violated wage and hour laws by allegedly (a) rounding employees’ starting and stopping times to the detriment of the employees, (b) failing to pay for clocked-out rest periods and meal periods shorter than 30 minutes, and (c) failing to promptly pay all wages due and owing on termination.

In general, Oregon law requires payment for rest periods and meal periods of less than 30 minutes, and requires employers to pay for all hours worked and to promptly pay all wages due and owing on termination.

AMAZON denies Class Representative’s allegations in their entirety.

The Class shall be granted a Gross Settlement Amount of $18,000,000 (the “Settlement Fund”). This is made up of Guaranteed Funds and Claimable Funds. Each Class Member will receive his/her/their portion of the Guaranteed Funds, and his/her/their portion of the Claimable Funds, if applicable. The Class Representative shall request a service award of $20,000 for her service in this matter in her capacity as such (the “Service Payment”). Class Counsel will request attorney fees, costs, and litigation expenses in the amount of one-third of the Gross Settlement Fund. Any un- awarded attorney fees/costs/litigation expenses and/or Service Payment will be redistributed to the Class. The Settlement shall not become effective if the Court does not approve it.

If you are a Class Member, you will receive your share of the Guaranteed Funds, whether or not you submit a Claim Form. To also receive your share of the Claimable Funds, if eligible, in addition to your share of the Guaranteed Funds, you will need to submit a Claim Form on or before January 13, 2023.

If eligible, you will receive your share of the Guaranteed Funds, whether or not you submit a Claim Form. To also receive your share of the Claimable Funds, if eligible, in addition to your share of the Guaranteed Funds, you will need to submit a Claim Form on or before January 13, 2023. You may do so by mailing, emailing, or faxing the Claim Form to the Settlement Administrator, or you may submit a Claim Form here.

By submitting a Claim Form, or negotiating any settlement check associated with this case, you are waiving any right to proceed in any fashion for the claims released in this case.

If you believe that the proposed Settlement is unfair or inadequate or are dissatisfied with the amounts approximated in your Notice or feel that Class Counsel’s request for attorney fees, costs, and litigation expenses and/or the Service Payment (which will be posted here no later than January 20, 2023) should not be approved, you may object to the Settlement and/or Class Counsel’s request for attorney fees, costs, and litigation expenses and/or the Service Payment by mailing by first-class mail, a detailed written statement bearing the caption of this action shown above on the first page stating your comment or objection, to (a) the Settlement Administrator at Amazon Swearingen Settlement, P.O. Box 2004, Chanhassen, MN 55317-2004, and (b) Mark O. Hatfield United States Courthouse, 1000 S.W. Third Ave., Portland, OR 97204. Objections must be mailed so as to be received no later than February 6, 2023, and must include the caption of the action and your name, address, and telephone number together with a detailed statement of the basis for your objection and whether you wish to be heard personally or by counsel at the final hearing at which the Parties will be requesting binding Court approval of the Settlement and the award of attorney fees, costs, and litigation expenses and the service payment, as described above. If you object to the settlement, you may not opt out of the settlement, and you will be bound by the Judge’s rulings and orders. You may also appear in person or by counsel at the final hearing described below.

If you choose not to be bound by this Settlement Agreement and do not wish to share in any of the benefits described herein, you may opt out of the Class by submitting a written, signed, and dated statement of your wish to opt out (including the date, your name, year of birth, last four digits of Social Security Number or Tax ID Number, and signature, as well as a statement stating “I wish to opt out of the Swearingen v. AMAZON settlement.”) by first-class mail, to the Settlement Administrator: Amazon Swearingen Settlement, P.O. Box 2004, Chanhassen, MN 55317-2004. The written, signed, and dated opt-out statement must be received no later than January 13, 2023 (the “Opt-Out Deadline”). All requests for exclusion received after the Opt-Out Deadline will not be effective, and such a person will be a member of the Class.

The hearing for final consideration and approval of the Settlement and the award of attorney fees, costs, and litigation expenses to Class Counsel and service payment to the Class Representative is scheduled to take place on March 1, 2023, at 1:30 p.m. at the Mark O. Hatfield United States Courthouse, 1000 S.W. Third Ave., Portland, OR 97204. The hearing may be changed, held remotely, or cancelled without further notice. If you wish to determine if the hearing is changed or cancelled, you may contact the Settlement Administrator at the address shown here.