Ramirez / Landscapes — filed stipulation and signed settlement order

1 Lilit Tunyan (SBN 329351) ltunyan@tunyanlaw.com 2 Artur Tunyan (SBN 349174) 3 atunyan@tunyanlaw.com TUNYAN LAW, APC Electronically Received 04/02/2025 03:45 PM 4 535 N Brand Blvd. Suite 285 Glendale, California 91203 5 Telephone: (323) 410-5050 6 Attorneys for Plaintiff RAUL LOPEZ RAMIREZ, 7 as an individual and on behalf of all employees similarly situated 8 Yvette Davis (SBN 165777) 9 ydavis@hbblaw.com Bianca Falcon (SBN 333278) 10 bfalcon@hbblaw.com edocs@hbblaw.com 11 HAIGHT BROWN & BONESTEEL LLP 2030 Main Street, Suite 1525 12 Irvine, CA 92614 Telephone: (714) 426-4600 13 Facsimile: (714) 754-0826 14 Attorneys for Defendant LANDSCAPES UNLIMITED, LLC 15 SUPERIOR COURT OF THE STATE OF CALIFORNIA 16 FOR THE COUNTY OF LOS ANGELES 17 RAUL LOPEZ RAMIREZ, individually, and on Case No.: 24STCV12695 18 behalf of all others similarly situated, [Assigned for all purposes to Hon. Doreen B. 19 Boxer, Dept. 19] Plaintiff, 20 PAGA REPRESENTATIVE ACTION 21 vs. JOINT STIPULATION FOR APPROVAL 22 OF SETTLEMENT OF CLAIMS 23 LANDSCAPES UNLIMITED, LLC, a Nebraska BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S Limited Liability Company; and DOES 1 through ACT OF 2004 24 10, inclusive, 25 Defendants Action Filed: May 21, 2024 Trial: Not yet set 26 27 28 JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S ACT OF 2004

1 JOINT STIPULATION 2 Plaintiff RAUL LOPEZ RAMIREZ (“Plaintiff”), individually and in his capacity as a 3 representative of the State of California on behalf of other allegedly aggrieved employees and 4 Defendant LANDSCAPES UNLIMITED, LLC (“Defendant”) (collectively, “the Parties”), by and 5 through their respective counsel, hereby stipulate and agree to the settlement of Plaintiff’s claim 6 for civil penalties under the California Labor Code Private Attorneys General Act, Labor Code § 7 2698, et seq. (“PAGA”), as follows: 8 1. Pursuant to PAGA, Plaintiff gave written notice to the Labor and Workforce 9 Development Agency (“LWDA”) and Defendant of various provisions of the California Labor 10 Code by letters dated March 16, 2024 that Defendant allegedly violated, including the facts and 11 theories to support the alleged violations. 12 2. The LWDA did not inform Plaintiff of any intent to investigate the claims noticed to 13 this day, has not communicated any intent to investigate the claims. Thus, Plaintiff has become 14 authorized under Labor Code § 2698 et seq. to act as private attorneys general for the alleged 15 PAGA claims. 16 3. On May 21, 2024, Plaintiff, a former employee of Defendant, filed this action as a 17 representative of the State of California on behalf of other allegedly aggrieved employees seeking 18 civil penalties under the Private Attorneys General Act of 2004, California Labor Code §§ 2698 et 19 seq. (“PAGA”) stemming from Plaintiff’s allegations that Defendant failed to pay all wages due 20 in violation of Labor Code Sections 204, 510 and 1194, including both regular and overtime wages; 21 failure to pay sick leave and provide employees with written notice of accrued sick leave in 22 violation of Labor Code Section 246; failure to pay for all unused vested vacation at termination 23 of employment in violation of Labor Code Section 227.3; failure to provide meal periods or 24 compensation in lieu thereof pursuant to Labor Code Sections 226.7 and 512, the applicable 25 Industrial Welfare Commission Wage Orders, and Code of Regulations, Title 8, Section 11000 et 26 seq.; failure to provide rest periods or compensation in lieu thereof pursuant to Labor Code 27 Sections 226.7 and 512, the applicable Industrial Welfare Commission Wage Orders, and Code of 28 Regulations, Title 8, Section 11000 et seq.; failure to provide accurate itemized wage statements 1 JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S ACT OF 2004

1 upon payment of wages pursuant to Labor Code Sections 226, subdivision (a), 1174, and 1175; 2 failure to reimburse for necessary expenditures pursuant to Labor Code Section 2802; failure to 3 pay wages of terminated or resigned employees pursuant to Labor Code Sections 201, 202, and 4 203 (“Action”). The complaint filed by Plaintiff on May 21, 2024 is the operative complaint in 5 this Action (“Operative Complaint”). Defendant denies, and continues to deny, all of the 6 allegations made by Plaintiff or that it is liable for any of the damages and/or civil penalties as 7 alleged in the Operative Complaint and LWDA Notice. 8 4. The Parties recognize that the issues presented in the Action are likely only to be 9 resolved with extensive and costly pretrial and trial proceedings, and that further litigation will 10 cause inconvenience, distraction, disruption, delay, and expense disproportionate to the 11 maximum potential benefits to the PAGA Settlement Members and Plaintiff from continued 12 litigation. 13 5. On February 24, 2025, the Parties participated in an all-day mediation presided over 14 by Hon. Carl West (Ret.), an experienced wage and hour mediator. Prior to participating in 15 mediation, the Parties engaged in extensive informal discovery, including production of 16 documents and information. Prior to mediation, Defendant also provided data to Plaintiff’s 17 counsel to evaluate the potential value of Plaintiff’s civil penalty claims. Thereafter, the Parties 18 engaged in extensive, arm’s length negotiations and reached a settlement of the Action that is 19 memorialized in the PAGA Settlement Agreement. During the mediation, the Parties agreed to 20 a settlement, which was negotiated in light of all known facts and circumstances, including the 21 difficulty of proving some of Plaintiff’s claims, potential defenses asserted by Defendant, the 22 uncertainty associated with litigation, the risks of significant delay, and numerous potential 23 appellate issues. Attached hereto as Exhibit 1 is the fully executed PAGA Settlement 24 Agreement (“Settlement,” “Settlement Agreement,” or “Agreement”) setting forth the terms of 25 the settlement. The Agreement is based upon the model agreement template made available by 26 the Los Angeles Superior Court. 27 6. The Settlement Agreement attached as Exhibit 1 to Joint Stipulation Approving 28 Settlement of Plaintiff’s Claims Brought Pursuant to the Private Attorney General’s Act of 2004 2 JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S ACT OF 2004

1 (“PAGA”) was submitted to the LWDA. A true and correct copy of the submission receipt is 2 attached to this stipulation as Exhibit 4. 3 7. The Parties conducted investigation of the facts and law. Counsel for the Parties 4 have further investigated the applicable law as applied to the facts discovered regarding 5 Plaintiff’s claims, the defenses thereto, and the Labor Code violations claimed by Plaintiff. 6 Based on their own independent investigations and evaluations, Plaintiff and his counsel are of 7 the opinion that the settlement for the consideration and on the terms set forth in the Settlement 8 Agreement is fair, reasonable, and adequate and is in the best interests of the Plaintiff and the 9 Aggrieved Employees in light of all known facts and circumstances and the risks inherent in 10 litigation, including the potential appellate issues. Further, Plaintiff’s counsel believes that the 11 settlement amount entered into is in the best interests of Plaintiff and the Aggrieved Employees 12 and that the settlement for each Aggrieved Employee is fair, reasonable, and adequate, given 13 the inherent risk of litigation. 14 8. The full terms of the settlement are in the Agreement. The key material terms are 15 as follows: 16 a. The Aggrieved Employees: The Aggrieved Employees (also known as the “PAGA 17 Settlement Members”) are: “All non-exempt or hourly employees of Defendant who 18 worked for Defendant within the State of California during the PAGA Period. 19 (Agreement, ¶¶ 1.4, 1.19.) 20 b. PAGA Period: PAGA Period means the period from March 16, 2023 through 21 February 24, 2025. (Agreement, ¶ 1.19) 22 c. No Reversion: The Settlement is non-reversionary. (Agreement, ¶ 3.1.) 23 d. Gross Settlement Amount: Defendant agrees to pay the maximum sum of 24 $150,000,000.00, subject to modification as provided in Paragraph 8 herein 25 (hereinafter referred to as the “Gross Settlement Amount” or “GSA”) for settlement 26 of the PAGA Penalties, which shall be inclusive of Plaintiff’s Counsel attorney’s 27 fees and costs and the settlement administrator’s fees and costs. (Agreement, ¶ 28 1.10.) 3 JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S ACT OF 2004

1 e. Net Settlement Amount: At least $83,600.82 will be available for distribution to the 2 Aggrieved Employees and the LWDA. Of this amount, the LWDA will receive at 3 least $62,700.61 under the Agreement, and Aggrieved Employees will receive at 4 least $20,900.21. (Agreement, ¶ 1.15.) 5 f. Attorney’s Fees: Plaintiff’s Counsel request an award of attorney’s fees in the 6 amount of $50,000.00, which is one third of the GSA. (Agreement, ¶ 3.2.1.) 7 g. Litigation Costs: Plaintiff’s Counsel’s litigation costs are capped to a maximum 8 amount of $20,000.00. Those actual costs are $11,399.18 including this stipulation 9 filing and future final report filing fee. Therefore, $11,399.18 is requested, by 10 Plaintiff. (Agreement, ¶ 3.2.1) 11 h. Settlement Administration: Payment to Aggrieved Employees and administration 12 will be accomplished through third-party settlement administrator Phoenix Class 13 Action Administration Solutions, which has agreed to perform Administrator duties 14 for a flat fee not to exceed $5,000.00, which is reasonable, based on all of the 15 services offered. Attached hereto as Exhibit 3 is the declaration from Administrator 16 regarding its qualifications, services and requested fee (Agreement, ¶ 3.2.2.) 17 i. General Release Payment: Upon approval of this PAGA settlement Plaintiff shall 18 receive a general release payment in the amount of $10,000 in lieu of arbitrating 19 Plaintiff’s individual claims and in consideration for representing Aggrieved 20 Employees and for a general release of all Plaintiff’s claims beyond the PAGA 21 claims released in this action in accordance with a separate individual Settlement 22 Agreement and Release entered into between the Parties. The General Release 23 Payment is not included in GSA (Agreement, ¶¶ 1.10, 5.1.) 24 j. Uncashed Checks: Funds represented by checks returned as undeliverable after a 25 re-mailing, and funds represented by checks remaining un-cashed for more than 180 26 days after issuance, will be tendered to the Unclaimed Property Fund or like fund. 27 (Agreement, ¶ 4.4.3.) 28 k. Release: In exchange for the above settlement consideration, Defendant shall be 4 JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S ACT OF 2004

1 entitled to a release from the LWDA and each and every Aggrieved Employee, 2 including Plaintiff. 1 (Agreement, ¶¶ 5.1-5.3.) 3 l. Notice to LWDA: Exhibit 4 confirms that notice was provided to the LWDA and 4 attaches the confirmatory submission documents. 5 9. The settlement in this action provides $83,600.82 to the allegedly Aggrieved 6 Employees and the LWDA in exchange for a release of claims under PAGA only. 2 The Settlement 7 Agreement and Release of PAGA Claims provides, in pertinent part: 8 Effective on the date when Defendant fully funds the entire Gross Settlement 9 Amount and Plaintiff’s general release payment pursuant to the separate agreement 10 entered into between the Parties, all Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, 11 agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for civil penalties under the California Private Attorneys General 12 Act, California Labor Code § 2698, et. seq. (“PAGA”) based on the PAGA Period facts stated in the Operative Complaint and the PAGA Notice filed with the LWDA 13 (“Released Claims”). 14 “PAGA Period” means the period from March 16, 2023 through February 24, 15 2025. 16 “Released Parties” means Defendant and each of its former and present directors, officers, shareholders, owners, members, attorneys, insurers, predecessors, 17 successors, assigns, subsidiaries, and affiliates. 18 “Aggrieved Employees” means all non-exempt or hourly employees of Defendant 19 who worked for Defendant within the State of California during the PAGA Period. 20 10. Based on its records, Defendant estimates that, there are approximately 200 Aggrieved 21 Employees who worked a total 2,650 of PAGA Pay Periods from March 16, 2023 through 22 February 24, 2025. If the number of actual PAGA Pay Periods during the PAGA Period exceeds 23 24 1 This comports with settled California Supreme Court authority. See Arias v. Superior Court, 46 Cal. 4th 969, 986 (2009) (concluding that “with respect to the recovery of civil 25 penalties, nonparty employees as well as the government are bound by the judgment in an action brought under the act….”). 26 2 $83,600.82 is the net amount available to the aggrieved employees and the LWDA from 27 the $150,000.00 total settlement amount following deduction for Plaintiff’s attorney’s fees of $50,000.00 (1/3 of the total settlement amount), Plaintiff’s counsel’s actual litigation costs of 28 $11,399.18 and third-party administration costs of $5,000.00. 5 JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S ACT OF 2004

1 10% of the estimated PAGA Pay Periods (i.e., exceeds 2,915 pay periods), Defendant shall 2 increase the Gross Settlement Amount by a pro-rata dollar value equal to the number of pay 3 periods in excess of 2,915 pay periods. For example, if there is a 1% increase over 10% then the 4 Gross Settlement Amount increases by 1%. 5 11. The Parties request that the Court approve the arm’s length settlement reached between 6 the Parties pertaining to penalties under PAGA, and the release of PAGA claims. 7 NOW THEREFORE, in return for the mutual commitments and consideration detailed in 8 the PAGA Settlement Agreement attached hereto as Exhibit 1, the Parties stipulate as follows: 9 1. The Parties stipulate and jointly propose that the Court review and approve the terms 10 contained in the Parties’ Settlement Agreement, attached as Exhibit 1, in full. 11 2. The Settlement is fair, adequate, and reasonable, as it represents a reasoned 12 compromise reached through arm’s length negotiations and considers the risks, complexity, and 13 expense of further litigation. 14 3. The settlement terms reached through mediation provide for a gross payment by 15 Defendant of One Hundred Fifty Thousand Dollars and Zero Cents ($150,000.00; “Gross 16 Settlement Amount”). The Gross Settlement Amount, which shall cover distribution to the LWDA 17 and the allegedly aggrieved employees, Plaintiff’s counsel’s costs and fees, Plaintiff’s 18 enhancement award and costs of administration of the settlement, as follows: 19 20 Description Amount 21 Attorneys’ Fees (1/3 of total settlement) $50,000.00 $11,399.18 3 22 Plaintiff’s Counsel’s Costs (not to exceed amount $20,000) 23 Third-Party Administration Cost $5,000.00 24 25 26 3 The Settlement authorizes reimbursement of actual costs not to exceed $20,000, at this 27 time, actual out of pocket costs, including the cost of submitting this Stipulation and final report filing fee total $11,399.18. A true and correct copy of a ledger of Plaintiff’s counsel’s costs are 28 attached hereto as Exhibit 2. 6 JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S ACT OF 2004

1 4. Should the Court approve a lesser amount for attorneys’ fees, costs, or costs of third- 2 party administration, the difference shall be allocated as follows: 25% to the allegedly aggrieved 3 employees and 75% to the LWDA. 4 5. The Settlement Administrator shall establish a Qualified Settlement Fund pursuant to 5 Section 468B(g) of the Internal Revenue Code for purposes of administering the Settlement. The 6 Settlement Administrator shall furnish the Qualified Settlement Fund with its own Employer ID 7 Number and calculate all settlement checks and withholdings required under law based on 8 information that will be confidentially furnished by Defendant. There are no payroll deductions 9 to be calculated under this Settlement, since no part of the Settlement will be classified as wages. 10 6. “PAGA Settlement Members” (also referred to herein as the “Aggrieved 11 Employees”) means all non-exempt or hourly employees of Defendant who worked for 12 Defendant within the State of California during the PAGA Period. 13 7. Upon the date of entry of an order and judgment by the Court in this Action approving 14 this Settlement, and payment of all funds due under this Settlement, the LWDA and PAGA 15 Settlement Members, including Plaintiff, fully release and forever discharge the Released 16 Parties from any and all Released Claims as defined in Exhibit 1. The final order and judgment 17 entered pursuant to this Settlement will bind all those who would be bound by a judgment if the 18 action had been brought by the LWDA, including Plaintiff, the LWDA, and all PAGA 19 Settlement Members during PAGA period, whether requesting exclusion from the Settlement 20 or not, with respect to the recovery of civil penalties under the California Private Attorneys 21 General Act, California Labor Code § 2698, et. seq. only, against the Released Parties. See 22 Arias v. Superior Court (2009) 46 Cal.4th 986. 23 8. Under California law, no notice to the allegedly aggrieved employees is required for 24 the resolution of an action under PAGA. Arias v. Superior Court, (2009) 46 Cal.4th 969, 977. The 25 Parties have nevertheless agreed to provide an explanatory letter to the allegedly aggrieved 26 employees to accompany the PAGA penalty checks. Attached to the PAGA Settlement Agreement 27 (Exhibit A) attached hereto as Exhibit 1 is the proposed letter to the allegedly aggrieved employees 28 tat would accompany the checks. 7 JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S ACT OF 2004

1 9. The Parties further expressly agree that the Court will retain jurisdiction under Code of 2 Civil Procedure section 664.6 to resolve any disputes arising from the settlement of the above- 3 described action. 4 IT IS SO STIPULATED. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 8 JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEY GENERAL’S ACT OF 2004

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “1”

Lilit Tunyan (SBN 329351) 1 ltunyan@tunyanlaw.com Artur Tunyan (SBN 349174) 2 atunyan@tunyanlaw.com TUNYAN LAW, APC 3 535 N Brand Blvd. Suite 285 Glendale, California 91203 4 Telephone: (323) 410-5050 5 Attorneys for Plaintiff RAUL LOPEZ RAMIREZ, as an individual and on behalf of all employees 6 similarly situated 7 Yvette Davis (SBN 165777) 8 ydavis@hbblaw.com Bianca Falcon (SBN 333278) 9 bfalcon@hbblaw.com edocs@hbblaw.com 10 HAIGHT BROWN & BONESTEEL LLP 2030 Main Street, Suite 1525 11 Irvine, CA 92614 Telephone: (714) 426-4600 12 Facsimile: (714) 754-0826 13 Attorneys for Defendant LANDSCAPES UNLIMITED, LLC 14 15 SUPERIOR COURT OF THE STATE OF CALIFORNIA 16 FOR THE COUNTY OF LOS ANGELES 17 RAUL LOPEZ RAMIREZ, individually, and Case No. 24STCV12695 18 on behalf of all others similarly situated, [Assigned for all purposes to Hon. Stephanie 19 Plaintiff, M. Bowick, Dept. 19] 20 PAGA SETTLEMENT AGREEMENT vs. 21 22 LANDSCAPES UNLIMITED, LLC, a Complaint Filed: May 21, 2024 Nebraska Limited Liability Company; and Trial: None Yet Set 23 DOES 1 through 10, inclusive, 24 Defendants 25 26 27 28 1 PAGA SETTLEMENT AGREEMENT

1 PAGA SETTLEMENT AGREEMENT 2 This PAGA Settlement Agreement (“Agreement” or “Settlement”) is made by and 3 between Plaintiff RAUL LOPEZ RAMIREZ (“Plaintiff”) and Defendant LANDSCAPES 4 UNLIMITED, LLC (“Defendant”). The Agreement refers to Plaintiff and Defendant 5 collectively as “Parties,” or individually as “Party.” 6 1. DEFINITIONS. 7 1.1. “Action” means the Plaintiff’s PAGA lawsuit alleging wage and hour violations 8 against Defendant captioned Ramirez v. Landscapes Unlimited, LLC, Case N 24STCV12695, 9 initiated on May 21, 2024 and pending in Superior Court of the State of California, County of 10 Los Angeles. 11 1.2. “Administrator” means Phoenix Class Action Administration Solutions, the neutral 12 entity the Parties have agreed to appoint to administer the Settlement. 13 1.3. “Administration Expenses Payment” means the amount the Administrator will be 14 paid from the Gross Settlement Amount to reimburse its reasonable fees and expenses in 15 accordance with the Administrator’s “not to exceed” bid submitted to the Court in connection 16 with approval of this Settlement. 17 1.4. “Aggrieved Employee” means a non-exempt or hourly employee of Defendant who 18 worked for Defendant during the PAGA Period. 19 1.5. “Aggrieved Employee Data” means Aggrieved Employee identifying information in 20 Defendant’s possession including the Aggrieved Employee’s name, last-known mailing address, 21 Social Security number, and number of PAGA Pay Periods. 22 1.6. “Aggrieved Employee Address Search” means the Administrator’s investigation and 23 search for current Aggrieved Employee mailing addresses using all reasonably available sources, 24 methods and means including, but not limited to, the National Change of Address database, skip 25 traces, and direct contact by the Administrator with Aggrieved Employees. 26 1.7. “Court” means the Superior Court of California, County of Los Angeles. 27 1.8. “Defense Counsel” means HAIGHT BROWN & BONESTEEL LLP. 28 2 PAGA SETTLEMENT AGREEMENT

1 1.9. “Effective Date” means the date by when both of the following have occurred: (a) 2 the Court enters a Judgment on its Order Approving the PAGA Settlement and (b) the Judgment 3 is final. The Judgment is final as of the latest of the following occurrences: (a) the day the Court 4 enters Judgment if no objections are filed to this settlement or if all objections are withdrawn 5 prior to the Court ruling on them; or (b) sixty-one (61) days after the date of entry of the 6 Approval Order if objections are filed and overruled and no appeal is taken from the order 7 approving the settlement; or (c) if a timely appeal is made, ten (10) business days after the final 8 resolution of that appeal if the appeal is rejected, the settlement is upheld, and the settlement 9 approval order is no longer subject to further judicial review. 10 1.10. “Gross Settlement Amount” means $150,000.00 which is the total amount 11 Defendant agrees to pay under the Settlement except as provided in Paragraph 8 below. The 12 Gross Settlement Amount will be used to pay Individual PAGA Payments, the LWDA PAGA 13 Payment, PAGA Counsel Fees Payment, PAGA Counsel Litigation Expenses Payment, and the 14 Administrator’s Expenses Payment. In addition to Gross Settlement Amount Defendant will pay 15 $10,000.00 to Plaintiff in consideration for representing Aggrieved Employees and for a general 16 release of Plaintiff’s all claims beyond PAGA claims released in this action in accordance with a 17 separate individual settlement and mutual release agreement entered between the Parties. 18 1.11. “Individual PAGA Payment” means the Aggrieved Employee’s pro rata share of 19 25% of the PAGA Penalties calculated according to the number of pay periods the Aggrieved 20 Employee worked during the PAGA Period. 21 1.12. “Judgment” means the judgment entered by the Court based upon the approval. 22 1.13. “LWDA” means the California Labor and Workforce Development Agency, the 23 agency entitled, under Labor Code section 2699, subd. (i). 24 1.14. “LWDA PAGA Payment” means the 75% of the PAGA Penalties paid to the 25 LWDA under Labor Code section 2699, subd. (i). 26 1.15. “Net Settlement Amount” means the Gross Settlement Amount, less the following 27 payments in the amounts approved by the Court: Individual PAGA Payments, the LWDA PAGA 28 Payment, PAGA Counsel Fees Payment, PAGA Counsel Litigation Expenses Payment, and the 3 PAGA SETTLEMENT AGREEMENT

1 Administration Expenses Payment. The remainder is to be paid to Aggrieved Employees as 2 Individual PAGA Payments. 3 1.16. “PAGA Counsel” means TUNYAN LAW, APC. 4 1.17. “PAGA Counsel Fees Payment” and “PAGA Counsel Litigation Expenses 5 Payment” mean the amounts allocated to PAGA Counsel for reimbursement of reasonable 6 attorneys’ fees and expenses, respectively, incurred to prosecute the Action. 7 1.18. “PAGA Pay Period” means any Pay Period during which an Aggrieved Employee 8 worked for Defendant for at least one day during the PAGA Period. 9 1.19. “PAGA Period” means the period from March 16, 2023 through February 24, 10 2025. 11 1.20. “PAGA” means the Private Attorneys General Act (Labor Code §§ 2698. et seq.). 12 1.21. “PAGA Notice” means Plaintiff’s March 16, 2024 letter to Defendant and the 13 LWDA providing notice pursuant to Labor Code section 2699.3, subd.(a). attached to this 14 Agreement as Exhibit A. 15 1.22. “PAGA Penalties” means the total amount of PAGA civil penalties to be paid from 16 the Gross Settlement Amount, allocated 25% to the Aggrieved Employees and the 75% to 17 LWDA in settlement of PAGA claims. 18 1.23. “Plaintiff” means RAUL LOPEZ RAMIREZ, the named plaintiff in the Action. 19 1.24. “Approval Order” means the proposed Court Order Granting Approval of PAGA 20 Settlement. 21 1.25. “Released PAGA Claims” means the claims being released by the Plaintiff and 22 PAGA Counsel and as described in Paragraph 5 below. 23 1.26. “Released Parties” means: Defendant and each of its former and present directors, 24 officers, shareholders, owners, members, attorneys, insurers, predecessors, successors, assigns, 25 subsidiaries, and affiliates. 26 1.27. “Settlement” means the disposition of the Action effected by this Agreement and 27 the Judgment. 28 1.28. “Defendant” means named Defendant LANDSCAPES UNLIMITED, LLC. 4 PAGA SETTLEMENT AGREEMENT

1 2. RECITALS. 2 2.1. On May 21, 2024, Plaintiff brought this Action against Defendant for civil penalties 3 under the Private Attorneys General Act of 2004, California Labor Code §§ 2698 et seq. 4 (“PAGA”) stemming from Plaintiff’s allegations that Defendant failed to pay all wages due in 5 violation of Labor Code Sections 204, 510 and 1194, including both regular and overtime wages; 6 failure to pay sick leave and provide employees with written notice of accrued sick leave in 7 violation of Labor Code Section 246; failure to pay for all unused vested vacation at termination 8 of employment in violation of Labor Code Section 227.3; failure to provide meal periods or 9 compensation in lieu thereof pursuant to Labor Code Sections 226.7 and 512, the applicable 10 Industrial Welfare Commission Wage Orders, and Code of Regulations, Title 8, Section 11000 11 et seq.; failure to provide rest periods or compensation in lieu thereof pursuant to Labor Code 12 Sections 226.7 and 512, the applicable Industrial Welfare Commission Wage Orders, and Code 13 of Regulations, Title 8, Section 11000 et seq.; failure to provide accurate itemized wage 14 statements upon payment of wages pursuant to Labor Code Sections 226, subdivision (a), 1174, 15 and 1175; failure to reimburse for necessary expenditures pursuant to Labor Code Section 2802; 16 failure to pay wages of terminated or resigned employees pursuant to Labor Code Sections 201, 17 202, and 203 (the “Operative Complaint”). Defendant denies the allegations in the Operative 18 Complaint, denies any failure to comply with the laws identified in the Operative Complaint and 19 denies any and all liability for the causes of action alleged. 20 2.3. Pursuant to Labor Code section 2699.3, subd.(a), Plaintiff gave timely written 21 notice to Defendant and the LWDA by sending the PAGA Notice. 22 2.4. On February 24, 2025, the Parties participated in an all-day mediation presided over 23 by Hon. Carl West (Ret.), which led to this Agreement to settle the Action. 24 2.5. Prior to mediation, Plaintiff obtained, through informal discovery, employee and 25 payroll data, policy documents, and additional information regarding Defendant’s non-exempt, 26 hourly employees in California, which Plaintiff’s Counsel reviewed and analyzed. 27 28 5 PAGA SETTLEMENT AGREEMENT

1 2.6. The Parties, PAGA Counsel and Defense Counsel represent that they are not aware 2 of any other pending matter or action asserting claims that will be extinguished or affected by 3 the Settlement. 4 3. MONETARY TERMS. 5 3.1. Gross Settlement Amount. Except as otherwise provided by Paragraphs 1.10 and 8, 6 Defendant promises to pay One Hundred Fifty Thousand Dollars ($150,000.00) and no more as 7 the Gross Settlement Amount. Defendant has no obligation to pay the Gross Settlement 8 Amount prior to the deadline stated in Paragraph 4.3 of this Agreement. The Administrator will 9 disburse the entire Gross Settlement Amount without asking or requiring Aggrieved Employees 10 to submit any claim as a condition of payment. None of the Gross Settlement Amount will 11 revert to Defendant. 12 3.2. Payments from the Gross Settlement Amount. The Administrator will make and 13 deduct the following payments from the Gross Settlement Amount, in the amounts specified by 14 the Court in the Approval Order: 15 3.2.1. To PAGA Counsel: A PAGA Counsel Fees Payment of not more than 33 16 1/3% which is currently estimated to be $50,000.00 and PAGA Counsel Litigation Expenses 17 Payment of not more than $20,000. Defendant will not oppose requests for Court approval of 18 these payments provided that they do not exceed these amounts. Plaintiff and/or PAGA Counsel 19 will file a motion for PAGA Counsel Fees Payment and PAGA Litigation Expenses Payment 20 with the motion for approval of the Settlment. If the Court approves a PAGA Counsel Fees 21 Payment and/or a PAGA Counsel Litigation Expenses Payment less than the amounts requested, 22 the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties 23 shall have no liability to PAGA Counsel or any other Plaintiff’s Counsel arising from any claim 24 to any portion any PAGA Counsel Fee Payment and/or PAGA Counsel Litigation Expenses 25 Payment. The Administrator will pay the PAGA Counsel Fees Payment and PAGA Counsel 26 Expenses Payment using one or more IRS 1099 Forms. PAGA Counsel assumes full 27 responsibility and liability for taxes owed on the PAGA Counsel Fees Payment and the PAGA 28 Counsel Litigation Expenses Payment and holds Defendant harmless, and indemnifies 6 PAGA SETTLEMENT AGREEMENT

1 Defendant, from any dispute or controversy regarding any division or sharing of any of these 2 Payments. 3 3.2.2. To the Administrator: An Administrator Expenses Payment not to exceed 4 $12,000 except for showing of good cause and as approved by the Court. To the extent the 5 Administration Expenses are less or the Court approves payment less than $12,000, the 6 Administrator will retain the remainder in the Net Settlement Amount. Phoenix Class Action 7 Administration Solutions has been selected as the Administrator, based upon its “not to exceed” 8 bid of $5,000.00. 9 3.2.3. To the LWDA and Aggrieved Employees: PAGA Penalties shall be paid 10 from the Gross Settlement Amount, with 75% allocated to the LWDA PAGA Payment and 25% 11 allocated to the Individual PAGA Payments. 12 3.2.3.1. The Administrator will calculate each Individual PAGA Payment 13 by (a) dividing the amount of the Aggrieved Employees’ 25% share of PAGA Penalties by the 14 total number of PAGA Period Pay Periods worked by all Aggrieved Employees during the 15 PAGA Period and (b) multiplying the result by each Aggrieved Employee’s PAGA Period Pay 16 Periods. Aggrieved Employees assume full responsibility and liability for any taxes owed on 17 their Individual PAGA Payment. 18 3.2.3.2. If the Court approves PAGA Penalties of less than the amount 19 requested, the Administrator will allocate the remainder to the Net Settlement Amount. The 20 Administrator will report the Individual PAGA Payments on IRS 1099 Forms. 21 4. SETTLEMENT FUNDING AND PAYMENTS. 22 4.1. Aggrieved Employee Pay Periods. Based on a review of its records, Defendant 23 estimates there are appoximately 200 Aggrieved Employees who worked a total 2,650 of PAGA 24 Pay Periods from March 16, 2023 through February 24, 2025. 25 4.2. Aggrieved Employee Data. Within fourteen (14) business days after the Effective 26 Date, Defendant will deliver the Aggrieved Employee Data to the Administrator in the form of a 27 Microsoft Excel spreadsheet. To protect Aggrieved Employees’ privacy rights, the 28 Administrator must maintain the Aggrieved Employee Data in confidence, use the Aggrieved 7 PAGA SETTLEMENT AGREEMENT

1 Employee Data only for purposes of this Settlement and for no other purpose, and restrict access 2 to the Aggrieved Employee Data to Administrator employees who need access to the Aggrieved 3 Employee Data to effect and perform under this Agreement. Defendant has a continuing duty to 4 immediately notify PAGA Counsel if it discovers that the Aggrieved Employee Data omitted 5 employee identifying information and to provide corrected or updated Aggrieved Employee Data 6 as soon as reasonably feasible. The Parties and their counsel will expeditiously use best efforts, 7 in good faith, to reconstruct or otherwise resolve any issues related to missing or omitted 8 Aggrieved Employee Data. 9 4.3. Funding of Gross Settlement Amount. Defendant shall fully fund the Gross 10 Settlement Amount by transmitting the funds to the Administrator no later than sixty (60) 11 calendar days after the Effective Date. 12 4.4. Payments from the Gross Settlement Amount. Within fourteen (14) days after 13 Defendant funds the Gross Settlement Amount, the Administrator will mail checks for all 14 Individual PAGA Payments, the LWDA PAGA Payment, the Administration Expenses 15 Payment, the PAGA Counsel Fees Payment, the PAGA Counsel Expenses Payment. 16 Disbursement of the PAGA Counsel Litigation Expenses Payment shall not precede 17 disbursement of Individual PAGA Payments. 18 4.4.1. The Administrator will issue checks for the Individual PAGA Payments 19 and send them to the Aggrieved Employees via First Class U.S. Mail, postage prepaid along with 20 the Notice of PAGA Representative Action Settlement (attached hereto as Exhibit B). The face 21 of each check shall prominently state the date (180 days after the date of mailing) when the 22 check will be voided. The Administrator will cancel all checks not cashed by the void date. 23 Before mailing any checks, the Settlement Administrator must update the recipients’ mailing 24 addresses using the National Change of Address Database. 25 4.4.2. The Administrator must conduct an Aggrieved Employee Address Search 26 for all Aggrieved Employees whose checks are retuned undelivered without USPS forwarding 27 address. Within seven (7) calendar days of receiving a returned check the Administrator must 28 re-mail checks to the USPS forwarding address provided or to an address ascertained through the 8 PAGA SETTLEMENT AGREEMENT

1 Aggrieved Employee Address Search. The Administrator need not take further steps to deliver 2 checks to Aggrieved Employees whose re-mailed checks are returned as undelivered. The 3 Administrator shall promptly send a replacement check to any Aggrieved Employee whose 4 original check was lost or misplaced, requested by the Aggrieved Employee prior to the void 5 date. 6 4.4.3. For any Aggrieved Employee whose Individual PAGA Payment check is 7 uncashed and cancelled after the void date, the Administrator shall transmit the funds 8 represented by such checks to the California Controller's Unclaimed Property Fund in the name 9 of the Aggrieved Employee. 10 4.4.4. The payment of Individual PAGA Payments shall not obligate Defendant 11 to confer any additional benefits or make any additional payments to the Aggrieved Employees 12 (such as 401(k) contributions or bonuses) beyond those specified in this Agreement. 13 5. RELEASES OF CLAIMS. 14 Effective on the date when Defendant fully funds the entire Gross Settlement Amount 15 and Plaintiff’s general release payment pursuant to the separate individual settlement and release 16 agreement entered between the Parties, Plaintiff and PAGA Counsel will release claims against 17 all Released Parties as follows: 18 5.1 Plaintiff’s Release. 19 5.1.1 Scope of Plaintiff’s Release. Plaintiff and his respective former and present 20 spouses, representatives, agents, attorneys (including PAGA Counsel), heirs, 21 administrators, successors, and assigns generally, release and discharge Released 22 Parties from all claims, transactions, or occurrences that occurred during the 23 PAGA Period, including, but not limited to: (a) all claims that were, or reasonably 24 could have been, alleged, based on the facts contained in the Operative Complaint 25 and the PAGA Notice (“Plaintiff’s Release”). Pursuant to the individual 26 settlement and release agreement Plaintiff also provides a general release of all 27 claims as defined in a separate individual settlement and release agreement. 28 Plaintiff’s Release does not does apply to: (i) claims or actions to enforce PAGA 9 PAGA SETTLEMENT AGREEMENT

1 Settlement Agreement; (ii) claims premised upon vested rights Plaintiff may have 2 under Defendant’s ERISA-covered employee benefit plans; and (iii) claims that 3 controlling law clearly states may not be released by private settlement, such as 4 claims for unemployment benefits, state-sponsored disability benefits, social 5 security benefits, or workers’ compensation benefits. With the exception of 6 Plaintiff, who will execute an individual settlement agreement which includes a 7 general release of all claims, this settlement shall not impact Aggrieved 8 Employees’ ability to assert claims other than the PAGA claims being released by 9 this Settlement. 10 5.1.2 Plaintiff’s Waiver of Rights Under California Civil Code § 1542. For purposes of 11 Plaintiff’s Release, Plaintiff expressly waives and relinquishes the provisions, 12 rights, and benefits, if any, of Section 1542 of the California Civil Code, which 13 reads: A general release does not extend to claims that the creditor or 14 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 15 him or her would have materially affected his or her settlement with the debtor or Released Party. 16 17 5.2 Release by Aggrieved Employees: All Aggrieved Employees are deemed to release, 18 on behalf of themselves and their respective former and present representatives, agents, 19 attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for 20 civil penalties under the California Private Attorneys General Act, California Labor Code § 21 2698, et. seq. (“PAGA”) based on the PAGA Period facts stated in the Operative Complaint and 22 the PAGA Notice filed with the LWDA (“Released Claims”). 23 5.3 Release by PAGA Counsel: PAGA Counsel release on behalf of their present and 24 former attorneys, employees, agents, successors and assigns the Released Parties from all 25 claims for PAGA Counsel Fees incurred in connection with the Operative Complaint and the 26 PAGA Period facts stated in the Operative Complaint and the PAGA Notice. 27 6. MOTION OR STIPULATION FOR APPROVAL OF SETTLEMENT. 28 10 PAGA SETTLEMENT AGREEMENT

1 Plaintiff’s Counsel agrees to prepare and file a stipulation or motion for approval of this 2 Settlement. 3 6.1. Plaintiff’s Responsibilities. Plaintiff will prepare and deliver to Defense Counsel all 4 documents necessary for obtaining approval of this Settlement under Labor Code Section 2699, 5 subd. (f)(2)) including (i) a draft proposed Order Granting Approval of PAGA Settlement; (ii) a 6 signed declaration from the Administrator attaching its “not to exceed” bid for administering the 7 Settlement and attesting to its willingness to serve; competency; operative procedures for 8 protecting the security of Aggrieved Employee Data; amounts of insurance coverage for any data 9 breach, defalcation of funds or other misfeasance; all facts relevant to any actual or potential 10 conflicts of interest with Aggrieved Employees or the LWDA; and the nature and extent of any 11 financial relationship with Plaintiff, PAGA Counsel or Defense Counsel; (iii) a signed 12 declaration from PAGA Counsel firm attesting to its timely transmission to the LWDA of all 13 necessary PAGA documents (initial notice of violations (Labor Code section 2699.3, subd. (a)), 14 Operative Complaint (Labor Code section 2699, subd. (l)(1)), this Agreement (Labor Code 15 section 2699, subd. (l)(2)); and all facts relevant to any actual or potential conflict of interest 16 with Aggrieved Employees and/or the Administrator. In their Declarations, Plaintiff and PAGA 17 counsel shall aver that they are not aware of any other pending matter or action asserting claims 18 that will be extinguished or adversely affected by the Settlement. 19 6.2. Responsibilities of PAGA Counsel. PAGA Counsel and Defense Counsel are jointly 20 responsible for expeditiously finalizing and filing the stipulation or motion for approval of this 21 Settlement no later than thirty (30) calendar days after the full execution of this Agreement and, 22 if necessary, obtaining a prompt hearing date for the motion and appearing in Court to advocate 23 in favor of the motion. PAGA Counsel is responsible for delivering the Court’s Preliminary 24 Approval to the Administrator. 25 6.3. Duty to Cooperate. If the Parties disagree on any aspect of the proposed stipulation 26 or motion for approval of this Settlement and/or the supporting declarations and documents, 27 PAGA Counsel and Defense Counsel will expeditiously work together on behalf of the Parties 28 by meeting in person, via virtual means, i.e., zoom or Teams, or by telephone, and in good faith, 11 PAGA SETTLEMENT AGREEMENT

1 to resolve the disagreement. If the Court does not grant the motion for approval of this 2 Settlement or conditions its approval on any material change to this Agreement, PAGA Counsel 3 and Defense Counsel will expeditiously work together on behalf of the Parties by meeting in 4 person or by telephone, and in good faith, to modify the Agreement and otherwise satisfy the 5 Court’s concerns. 6 7. SETTLEMENT ADMINISTRATION. 7 7.1. Selection of Administrator. The Parties have jointly selected Phoenix Class Action 8 Administration Solutions to serve as the Administrator and verified that, as a condition of 9 appointment, Phoenix Class Action Administration Solutions agrees to be bound by this 10 Agreement and to perform, as a fiduciary, all duties specified in this Agreement in exchange for 11 payment of Administration Expenses. The Parties and their Counsel represent that they have no 12 interest or relationship, financial or otherwise, with the Administrator other than a professional 13 relationship arising out of prior experiences administering settlements. 14 7.2. Employer Identification Number. The Administrator shall have and use its own 15 Employer Identification Number for purposes of calculating payroll tax withholdings and 16 providing reports state and federal tax authorities. 17 7.3. Qualified Settlement Fund. The Administrator shall establish a settlement fund that 18 meets the requirements of a Qualified Settlement Fund (“QSF”) under US Treasury Regulation 19 section 468B-1. 20 7.4. Administrator Duties. The Administrator has a duty to perform or observe all tasks 21 to be performed or observed by the Administrator contained in this Agreement or otherwise. 22 8. AGGRIEVED EMPLOYEE SIZE ESTIMATES AND ESCALATOR CLAUSE 23 Based on its records, Defendant estimates that, there are 200 Aggrieved Employees who 24 worked 2,650 Pay Periods from March 16, 2023 through February 24, 2025. If the number of 25 actual PAGA Pay Periods during the PAGA Period exceeds 10% of the estimated PAGA Pay 26 Periods (i.e., exceeds 2,915 pay periods), Defendant shall increase the Gross Settlement Amount 27 by a pro-rata dollar value equal to the number of pay periods in excess of 2,915 pay periods. 28 12 PAGA SETTLEMENT AGREEMENT

1 For example, if there is a 1% increase over 10% then the Gross Settlement Amount increases by 2 1%. 3 9. CONTINUING JURISDICTION OF THE COURT. 4 The Parties agree that, after entry of Judgment, the Court will retain jurisdiction over the 5 Parties, Action, and the Settlement solely for purposes of (i) enforcing this Agreement and/or 6 Judgment, (ii) addressing settlement administration matters, and (iii) addressing such post- 7 Judgment matters as are permitted by law. 8 9.1. Waiver of Right to Appeal. Provided the Judgment is consistent with the terms and 9 conditions of this Agreement, specifically including the PAGA Counsel Fees Payment and 10 PAGA Counsel Litigation Expenses Payment, the Parties, their respective counsel waive all 11 rights to appeal from the Judgment, including all rights to post-judgment and appellate 12 proceedings, the right to file motions to vacate judgment, motions for new trial, extraordinary 13 writs, and appeals. The waiver of appeal does not include any waiver of the right to oppose such 14 motions, writs or appeals. If another party appeals the Judgment, the Parties’ obligations to 15 perform under this Agreement will be suspended until such time as the appeal is finally resolved 16 and the Judgment becomes final, except as to matters that do not affect the amount of the Net 17 Settlement Amount. 18 10. ADDITIONAL PROVISIONS. 19 10.1. No Admission of Liability or Representative Manageability for Other Purposes. 20 This Agreement represents a compromise and settlement of highly disputed claims. Nothing in 21 this Agreement is intended or should be construed as an admission by Defendant that any of the 22 allegations in the Operative Complaint have merit or that Defendant have any liability for any 23 claims asserted; nor should it be intended or construed as an admission by Plaintiff that 24 Defendant’ defenses in the Action have merit. The Parties agree that representative treatment is 25 for purposes of this Settlement only. If, for any reason the Court does not approve this 26 Settlement, Defendant reserves all available defenses to the claims in the Action, and Plaintiff 27 reserves the right to contest Defendant’s defenses. The Settlement, this Agreement and Parties’ 28 willingness to settle the Action will have no bearing on, and will not be admissible in connection 13 PAGA SETTLEMENT AGREEMENT

1 with, any litigation (except for proceedings to enforce or effectuate the Settlement and this 2 Agreement). 3 10.2. Integrated Agreement. Upon execution by all Parties and their counsel, this 4 Agreement together with its attached exhibits shall constitute the entire agreement between the 5 Parties relating to the Settlement, superseding any and all oral representations, warranties, 6 covenants, or inducements made to or by any Party. 7 10.3. Attorney Authorization. PAGA Counsel and Defense Counsel separately warrant 8 and represent that they are authorized by Plaintiff and Defendant, respectively, to take all 9 appropriate action required or permitted to be taken by such Parties pursuant to this Agreement 10 to effectuate its terms, and to execute any other documents reasonably required to effectuate the 11 terms of this Agreement including any amendments to this Agreement. 12 10.4. Cooperation. The Parties and their counsel will cooperate with each other and use 13 their best efforts, in good faith, to implement the Settlement by, among other things, modifying 14 the Settlement Agreement, submitting supplemental evidence and supplementing points and 15 authorities as requested by the Court. In the event the Parties are unable to agree upon the form 16 or content of any document necessary to implement the Settlement, or on any modification of the 17 Agreement that may become necessary to implement the Settlement, the Parties will seek the 18 assistance of a mediator and/or the Court for resolution. 19 10.5. No Prior Assignments. The Parties separately represent and warrant that they have 20 not directly or indirectly assigned, transferred, encumbered, or purported to assign, transfer, or 21 encumber to any person or entity and portion of any liability, claim, demand, action, cause of 22 action, or right released and discharged by the Party in this Settlement. 23 10.6. No Tax Advice. Neither Plaintiff, PAGA Counsel, Defendant nor Defense 24 Counsel are providing any advice regarding taxes or taxability, nor shall anything in this 25 Settlement be relied upon as such within the meaning of United States Treasury Department 26 Circular 230 (31 CFR Part 10, as amended) or otherwise. 27 28 14 PAGA SETTLEMENT AGREEMENT

1 10.7. Modification of Agreement. This Agreement, and all parts of it, may be amended, 2 modified, changed, or waived only by an express written instrument signed by all Parties or their 3 representatives, and approved by the Court. 4 10.8. Agreement Binding on Successors. This Agreement will be binding upon, and 5 inure to the benefit of, the successors of each of the Parties. 6 10.9. Applicable Law. All terms and conditions of this Agreement and its exhibits will 7 be governed by and interpreted according to the internal laws of the state of California, without 8 regard to conflict of law principles. 9 10.10. Cooperation in Drafting. The Parties have cooperated in the drafting and 10 preparation of this Agreement. This Agreement will not be construed against any Party on the 11 basis that the Party was the drafter or participated in the drafting. 12 10.11. Confidentiality. To the extent permitted by law, all agreements made, and orders 13 entered during Action and in this Agreement relating to the confidentiality of information shall 14 survive the execution of this Agreement. 15 10.12. Use and Return of Aggrieved Employee Data. Information provided to PAGA 16 Counsel pursuant to Cal. Evid. Code §1152, and all copies and summaries of the PAGA Data 17 provided to PAGA Counsel by Defendant in connection with the mediation, other settlement 18 negotiations, or in connection with the Settlement, may be used only with respect to this 19 Settlement, and no other purpose, and may not be used in any way that violates any existing 20 contractual agreement, statute, or rule of court. Not later than 90 calendar days after the 21 Administrator discharges its obligation to pay out of all Settlement funds, Plaintiff shall destroy 22 all paper and electronic versions of Aggrieved Employee Data received from Defendant unless, 23 prior to the Administrator’s payment of all Settlement Funds, Defendant make a written request 24 to PAGA Counsel for the return, rather than the destructions, of Aggrieved Employee Data. 25 10.13. Headings. The descriptive heading of any section or paragraph of this Agreement 26 is inserted for convenience of reference only and does not constitute a part of this Agreement. 27 10.14. Calendar Days. Unless otherwise noted, all reference to “days” in this Agreement 28 shall be to calendar days. In the event any date or deadline set forth in this Agreement falls on a 15 PAGA SETTLEMENT AGREEMENT

1 weekend or federal legal holiday, such date or deadline shall be on the first business day 2 thereafter. 3 10.15. Notice. All notices, demands or other communications between the Parties in 4 connection with this Agreement will be in writing and deemed to have been duly given as of the 5 third business day after mailing by United States mail, or the day sent by email or messenger, 6 addressed as follows: 7 To Plaintiff: Lilit Tunyan 8 ltunyan@tunyanlaw.com 9 Artur Tunyan atunyan@tunyanlaw.com 10 TUNYAN LAW, APC 535 N Brand Blvd. Suite 285 11 Glendale, California 91203 Telephone: (323) 410-5050 12 13 To Defendant: Yvette Davis 14 ydavis@hbblaw.com Bianca Falcon 15 bfalcon@hbblaw.com edocs@hbblaw.com 16 HAIGHT BROWN & BONESTEEL LLP 17 2030 Main Street, Suite 1525 Irvine, CA 92614 18 Telephone: (714) 426-4600 Facsimile: (714) 754-0826 19 20 10.16. Execution in Counterparts. This Agreement may be executed in one or more 21 counterparts by facsimile, electronically (i.e. DocuSign), or email which for purposes of this 22 Agreement shall be accepted as an original. All executed counterparts and each of them will be 23 deemed to be one and the same instrument if counsel for the Parties will exchange between 24 themselves signed counterparts. Any executed counterpart will be admissible in evidence to 25 prove the existence and contents of this Agreement. 26 10.17. Stay of Litigation. The Parties agree that upon the execution of this Agreement 27 the litigation shall be stayed, except to effectuate the terms of this Agreement. The Parties 28 further agree that upon the signing of this Agreement that pursuant to CCP section 583.330 to 16 PAGA SETTLEMENT AGREEMENT

1 extend the date to bring a case to trial under CCP section 583.310 for the entire period of this 2 settlement process. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17 PAGA SETTLEMENT AGREEMENT

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “A”

1 2 3 MARCH 16, 2024 4 5 VIA ONLINE SUBMISSION Labor & Workforce Development Agency 6 Attn. PAGA Administrator 1515 Clay Street, Ste. 801 7 Oakland, CA 94612 8 PAGAfilings@dir.ca.gov 9 VIA CERTIFIED MAIL 10 Return Receipt Requested 11 Landscapes Unlimited, LLC 1201 Aries Dr. 12 Lincoln, NE 68512 VIA CERTIFIED MAIL 13 Return Receipt Requested 14 URS Agents Inc. Agent for Service of Process for 15 Landscapes Unlimited, LLC 7801 Folsom Blvd, #202 16 Sacramento, CA 95826 17 NOTICE OF LABOR CODE VIOLATIONS PURSUANT TO 18 LABOR CODE SECTION § 2698 ET SEQ. 19 Re: Raul Lopez Ramirez v. Landscapes Unlimited, LLC 20 21 To Whom It May Concern: 22 Please be advised that my office has been retained by Raul Lopez Ramirez (“Plaintiff”) to pursue a Labor Code Private Attorney General Act (PAGA) representative action (Cal. Lab. 23 Code §§ 2699, et seq.) against his former employer Landscapes Unlimited, LLC (“Defendant”). 24 The purpose of this letter is to comply with PAGA and set forth the facts and theories of California Labor Code violations which Plaintiff alleges Defendant engaged in with respect to 25 Plaintiff and all of Defendant’s aggrieved employees. 26 Plaintiff wishes to pursue a PAGA representative action on behalf of himself as an aggrieved 27 employee, on behalf of the State of California, and on behalf of all other current and former aggrieved employees who worked for Defendant in California as an hourly paid, non-exempt 28 1

employee at any time within the applicable statutory period (hereafter, the “Aggrieved 1 Employees”). 2 Plaintiff and the Aggrieved Employees of Defendant suffered the Labor Code violations described 3 below. 4 Factual Background Regarding Plaintiff's Employment with Defendant 5 Defendant owns and operates an industry, business, and establishment within the State of California. As such, Defendant is subject to the California Labor Code and the Wage Orders issued 6 by the Industrial Welfare Commission (“IWC”). 7 Plaintiff worked for Defendant as a machine operator from approximately 2010 to march 11, 2024. 8 Defendant classified Plaintiff as non-exempt from overtime. During the time period that Plaintiff was employed by Defendant, Plaintiff typically worked 6 days per week, and over 8 hours each 9 workday. 10 Throughout Plaintiff's employment, Defendant committed numerous labor code violations under state law. As discussed below, Plaintiff's experience working for Defendant was typical and 11 illustrative. 12 Failure to Pay for All Hours Worked, Including Overtime 13 Under California law, an employer must pay for all hours worked by an employee. “Hours worked” 14 is the time during which an employee is subject to the control of an employer and includes all the time the employee is suffered or permitted to work, whether or not required to do so. 15 In addition, Labor Code § 510 provides that employees in California shall not be employed more 16 than eight (8) hours in any workday or forty (40) hours in a workweek unless they receive additional compensation beyond their regular wages in amounts specified by law. 17 Labor Code §§ 1194 and 1198 also provide that employees in California shall not be employed 18 more than eight hours in any workday unless they receive additional compensation beyond their 19 regular wages in amounts specified by law. Additionally, Labor Code § 1198 states that the employment of an employee for longer hours than those fixed by the Industrial Welfare 20 Commission is unlawful. 21 Throughout the time period involved in this case, Defendant maintained a policy and practice of 22 failing to pay Plaintiff and the Aggrieved Employees for all hours worked. Defendant regularly used a system of time rounding in a manner that resulted, over a period of time, in failing to 23 compensate Plaintiff and the Aggrieved Employees properly for all the time they have actually worked, even though the realities of Defendant's operations are such that it is possible, practical, 24 and feasible to count and pay for work time to the minute. Accordingly, Defendant frequently paid 25 Plaintiff and the Aggrieved Employees less than all their work time. Some of this unpaid work also should have been paid at the overtime rate. Throughout the statutory period, Defendant failed to 26 maintain accurate time records and falsified Plaintiff’s and the Aggrieved Employees’ time records. Plaintiff and the Aggrieved employees were only required to sign under a blank timesheet at the 27 beginning of their shifts. Plaintiff’s and the Aggrieved Employees supervisors would later complete 28 the timesheets with the scheduled shift time worked by Plaintiff and the Aggrieved Employees as 2

opposed to Plaintiff and the Aggrieved Employees clocking in and out electronically or recording 1 their actual time on a handwritten timesheet. Plaintiff and the Aggrieved Employees were regularly 2 required to arrive at least 30 minutes earlier than their scheduled start time of the shift to be able to attend the team meetings prior to start of their shifts. Additionally, Plaintiff and the Aggrieved 3 Employees were also required to work beyond their scheduled shift hours at the end of the shift by walking to the Defendant’s shop to store the machine key and other tools prior to leaving 4 Defendant’s premises. Defendant refused to permit Plaintiff and the Aggrieved Employees to 5 personally record their actual time, and while recording Plaintiff’s and the Aggrieved Employees time instead of them, falsified the time records by inputting not more than scheduled 8 hours in a 6 single day, despite the fact that Plaintiff and the Aggrieved Employees regularly worked in excess of 8 hours per day, depriving Plaintiff and the Aggrieved Employees of wages, including overtime 7 wages. In doing so, Defendant also failed to maintain accurate records of the hours Plaintiff and the 8 Aggrieved Employees worked. 9 As a result, Defendant is liable to Plaintiff and the Aggrieved Employees for the civil penalties provided for in Labor Code §§ 210, 558, 1197.1, and 2699(f)(2) for failing to pay for all hours 10 worked, including overtime. 11 Failure to Provide Meal Periods 12 Under California law, employers have an affirmative obligation to relieve employees of all duty in 13 order to take their first 30-minute, duty-free meal periods no later than the start of sixth hour of work in a workday, and to allow employees to take their second 30-minute, duty-free meal period 14 no later than the start of the eleventh hour of work in the workday. Further, employees are entitled to be paid one hour of additional wages for each workday they were not provided with all required 15 meal period(s). 16 Despite these legal requirements, Defendant wrongfully failed to provide Plaintiff and the 17 Aggrieved Employees with legally compliant meal periods. Defendant regularly required Plaintiff and the Aggrieved Employees to work in excess of five consecutive hours a day without providing a 18 30-minute, continuous and uninterrupted, duty-free meal period for every five hours of work, or without compensating Plaintiff and the Aggrieved Employees for meal periods that were not 19 provided by the end of the fifth hour of work or tenth hour of work. Defendant did not instruct and 20 allow Plaintiff and the Aggrieved Employees to record their meal periods. Plaintiff is not aware whether his supervisor would fill in the meal period time in the blank timesheets he was required to 21 sign. As a result of the off-the clock work prior to the start of the shift, Plaintiff and the Aggrieved Employees would regularly take their first meal periods after the end of the fifth hour. Most 22 importantly, Defendant wrongfully required Plaintiff and the Aggrieved employees to combine their 23 30-minute first meal periods with their first rest periods and have one 45- minute combined meal and rest break instead of taking separate meal periods and separate rest periods. Accordingly, 24 Defendant’s policy and practice was to not provide meal periods to Plaintiff and the Aggrieved Employees in compliance with California law. 25 Plaintiff and the Aggrieved Employees are thus entitled to be paid one hour of additional wages for 26 each workday he or she was not provided with all required meal period(s). Defendant, however, 27 regularly failed to pay Plaintiff and the Aggrieved Employees the additional wages to which they were entitled for meal periods and that were not provided. 28 3

As a result, Defendant is liable to Plaintiff and the Aggrieved Employees for the civil penalties 1 provided for in Labor Code §§ 210, 558, and 2699(f)(2) for failing to provide meal periods and pay 2 meal period premium wages. 3 Failure to Authorize and Permit Rest Periods 4 Employers are required by California law to authorize and permit breaks of 10 uninterrupted minutes for each four hours of work or major fraction of four hours (i.e. more than two hours). 5 Thus, for example, if an employee’s work time is 6 hours and ten minutes, the employee is entitled to two rest breaks. Each failure to authorize rest breaks as so required is itself a violation of 6 California’s rest break laws. 7 Defendant, however, wrongfully failed to authorize and permit Plaintiff and the Aggrieved 8 Employees to take timely and duty-free rest periods. Defendant regularly required Plaintiff and the Aggrieved Employees to work in excess of four consecutive hours a day without Defendant 9 authorizing and permitting them to take a 10 minute, continuous and uninterrupted, rest period for every four hours of work (or major fraction of four hours), or without compensating Plaintiff and 10 the Aggrieved Employees for rest periods that were not authorized or permitted. Defendant did not 11 adequately inform Plaintiff and the Aggrieved Employees of their right to take a rest period. Moreover, Defendant did not have adequate policies or practices permitting or authorizing rest 12 periods for Plaintiff and the Aggrieved Employees, nor did Defendant have adequate policies or 13 practices regarding the timing of rest periods. Defendant did not schedule rest periods every 4 hours or a major fraction. Instead, Defendant wrongfully required Plaintiff and the Aggrieved employees 14 to combine their 30-minute first meal periods with their first rest periods and to take combined one 45-minute first meal and rest break instead of taking separate meal periods and separate rest 15 periods. Plaintiff and the Aggrieved Employees have never been authorized and taken their third 16 rest periods. Most importantly, Plaintiff and the Aggrieved Employees were not allowed to leave the work premises during rest periods. Accordingly, Defendant’s policy and practice was for Plaintiff 17 and the Aggrieved Employees to work through rest periods and to not authorize or permit them to take any rest periods. 18 Plaintiff and the Aggrieved Employees are thus entitled to be paid one hour of additional wages for 19 each workday he or she was not authorized and permitted to take all required rest period(s). 20 Defendant, however, regularly failed to pay Plaintiff and the Aggrieved Employees the additional wages to which they were entitled for rest periods and that they were not authorized and permitted 21 to take. 22 As a result, Defendant is liable to Plaintiff and the Aggrieved Employees for the civil penalties provided for in Labor Code §§ 210, 558, and 2699(f)(2) for failing to authorize and permit rest 23 periods and pay rest period premium wages. 24 Failure to Maintain Accurate Records of Hours Worked 25 Plaintiff seeks penalties under Labor Code § 1174(d). Pursuant to Labor Code § 1174.5, any 26 person, including any entity, employing labor who willfully fails to maintain accurate and complete records required by Labor Code § 1174 is subject to a penalty under § 1174.5. Pursuant to the 27 applicable IWC Order § 7(A)(3), every employer shall keep time records showing when the 28 employee begins and ends each work period. Meal periods and total hours worked daily shall also 4

be recorded. 1 Defendant, however, failed to maintain accurate records of hours worked and all meal periods taken 2 or missed by Plaintiff and the Aggrieved Employees. 3 Throughout the statutory period, Defendant failed to maintain accurate time records and falsified 4 Plaintiff’s and the Aggrieved Employees’ time records. Plaintiff and the Aggrieved employees were only required to sign under the blank timesheets at the beginning of their shifts. Plaintiff’s and the 5 Aggrieved Employees’ scheduled shift start and end time was filled in by their supervisors as opposed to Plaintiff and the Aggrieved Employees clocking in and out electronically or recording 6 their actual time on a handwritten timesheet. Defendant refused to permit Plaintiff and the 7 Aggrieved Employees to personally record their actual time, and while recording Plaintiff’s and the Aggrieved Employees time falsified the time records by inputting not more than scheduled 8 hours 8 in a single day, despite the fact that Plaintiff and the Aggrieved Employees regularly worked in excess of 8 hours per day, depriving Plaintiff and the Aggrieved Employees of wages, including 9 overtime wages. 10 Defendant’s failure to provide and maintain records required by the Labor Code IWC Wage Orders 11 deprived Plaintiff and the Aggrieved Employees the ability to know, understand and question the accuracy and frequency of meal periods, and the accuracy of their hours worked stated in 12 Defendant’ records. Therefore, Plaintiff and the Aggrieved Employees had no way to dispute the 13 resulting failure to pay wages, all of which resulted in an unjustified economic enrichment to Defendant. As a direct result, Plaintiff and the Aggrieved Employees have suffered and continue to 14 suffer, substantial losses related to the use and enjoyment of such wages, lost interest on such wages and expenses and attorney’s fees in seeking to compel Defendant to fully perform its obligation 15 under state law, all to their respective damage in amounts according to proof at trial. As a result of 16 Defendant’ knowing failure to comply with the Labor Code and applicable IWC Wage Orders, Plaintiff and the Aggrieved Employees have also suffered an injury in that they were prevented 17 from knowing, understanding, and disputing the wage payments paid to them. 18 As a result, Defendant is liable to Plaintiff and the Aggrieved Employees for the civil penalties provided for in Labor Code § 1174.5 for failing to maintain accurate records of hours worked and 19 meal periods. 20 Failure to Reimburse and Indemnify Expenses 21 California Labor Code § 2802 requires employers to reimburse employees for their necessary 22 expenditures and losses incurred in direct consequence of the discharge of their duties or of their obedience to directions of the employer. 23 Throughout the statutory period, Defendant wrongfully required Plaintiff and the Aggrieved 24 Employees to pay expenses that they incurred in direct discharge of their duties for Defendant without reimbursement. Defendant required Plaintiff and the Aggrieved Employees to purchase 25 additional safety gloves but failed to reimburse for those gloves. Plaintiff also failed to reimburse 26 Plaintiff and the Aggrieved Employees for personal cell phone usage as Plaintiff and the Aggrieved Employees were required to use their personal cell phones to call and receive work related calls and 27 text messages from their supervisors and to send pictures of work to report on the progress of work 28 or finished assignments. Plaintiff and the Aggrieved Employees incurred these substantial expenses 5

as a direct result of performing their job duties for Defendant, and Defendant have failed to 1 indemnify Plaintiff and the Aggrieved Employees for these employment-related expenses. 2 Failure to Timely Pay All Wages at Termination 3 Labor Code §§ 201 and 202 provide that if an employer discharges an employee, the wages earned 4 and unpaid at the time of discharge are due and payable immediately, and that if an employee voluntarily leaves his or her employment, his or her wages shall become due and payable not later 5 than seventy-two (72) hours thereafter, unless the employee has given seventy-two (72) hours previous notice of his or her intention to quit, in which case the employee is entitled to his or her 6 wages at the time of quitting. 7 Within the applicable statute of limitations, the employment of Plaintiff and many other Aggrieved 8 Employees ended, i.e. was terminated by quitting or discharge, and the employment of others will be. However, during the relevant time period, Defendant failed, and continues to fail to pay 9 Plaintiff and terminated Aggrieved Employees, without abatement, all wages required to be paid by Labor Code sections 201 and 202 either at the time of discharge, or within seventy-two (72) hours 10 of their leaving Defendant’ employ. These unpaid wages include wages for unpaid work time 11 (including minimum and straight time wages), missed meal periods, and missed rest periods. 12 Defendant’s conduct violates Labor Code §§ 201 and 202.Labor Code § 203 provides that if an employer willfully fails to pay wages owed, in accordance with sections 201 and 202, then the 13 wages of the employee shall continue as a penalty wage from the due date, and at the same rate until 14 paid or until an action is commenced; but the wages shall not continue for more than thirty (30) days. 15 Accordingly, Plaintiff and the Aggrieved Employees are entitled to recover from Defendant their 16 additionally accruing wages for each day they were not paid, at their regular hourly rate of pay, up to 30 days maximum pursuant to Labor Code § 203. 17 Moreover, Defendant is liable to Plaintiff and the Aggrieved Employees for the civil penalties 18 provided for in Labor Code § 2699(f)(2) for failing to timely pay all wages at termination. 19 Failure to Furnish Accurate Itemized Wage Statements 20 Labor Code § 226(a) provides that every employer shall furnish each of his or her employees an 21 accurate itemized wage statement in writing showing nine pieces of information, including: (1) gross wages earned, (2) total hours worked by the employee, (3) the number of piece-rate units 22 earned and any applicable piece rate if the employee is paid on a piece-rate basis, (4) all deductions, provided that all deductions made on written orders of the employee may be aggregated and shown 23 as one item, (5) net wages earned, (6) the inclusive dates of the period for which the employee is 24 paid, (7) the name of the employee and the last four digits of his or her social security number or an employee identification number other than a social security number, (8) the name and address of the 25 legal entity that is the employer, and (9) all applicable hourly rates in effect during the pay period 26 and the corresponding number of hours worked at each hourly rate by the employee. An employee is presumed to suffer an injury if this information is missing. Lab. Code § 226(e)(2)(B)(iii). 27 The statute further provides: “An employee suffering injury as a result of a knowing and intentional 28 failure by an employer to comply with subdivision (a) is entitled to recover the greater of all actual 6

damages or fifty dollars ($50) for the initial pay period in which a violation occurs and one hundred 1 dollars ($100) per employee for each violation in a subsequent pay period, not to exceed an 2 aggregate penalty of four thousand dollars ($4,000), and is entitled to an award of costs and reasonable attorney’s fees.” Lab. Code § 226(e)(1). 3 Defendant intentionally and willfully failed to provide employees with complete and accurate wage 4 statements. The deficiencies include, among other things, the failure to correctly identify hourly rates, the failure to correctly list gross wages earned, and the failure to list the true net wages 5 earned, including wages for meal periods that were not provided in accordance with California law, 6 wages for rest periods that were not authorized and permitted to take in accordance with California law, and correct wages earned for all hours worked. Moreover, during some pay periods Defendant 7 failed to state the hourly rate, the total hours worked, the pay period beginning and end date in the wage statements at all. 8 As a result of Defendant violating Labor Code § 226, Plaintiff and similarly Aggrieved Employees 9 suffered injury and damage to their statutorily protected rights. 10 Accordingly, Plaintiff and similarly Aggrieved Employees are entitled to recover from Defendant 11 the greater of their actual damages caused by Defendant’ failure to comply with Labor Code § 226(a), or an aggregate penalty not exceeding $4,000 dollars per employee. 12 Moreover, Defendant is liable to Plaintiff and the Aggrieved Employees for the civil penalties 13 provided for in Labor Code § 226.3 for failing to furnish accurate itemized wage statements. 14 Failure to Pay All Earned Wages Twice Per Month 15 Based on its failure to pay Plaintiff and the Aggrieved Employees for all wages as discussed above, 16 Defendants also violated Labor Code § 204. 17 Labor Code § 204 requires employers to pay employees all earned wages two times per month on days designated in advance by the employer as the regular paydays. Labor performed between the 18 1st and 15th days, inclusive, of any calendar month shall be paid for between the 16th and the 26th day of the month during which the labor was performed, and labor performed between the 16th and 19 the last day, inclusive, of any calendar month, shall be paid for between the 1st and 10th day of the 20 following month. Lab. Code § 204(a). The requirements of this section shall be deemed satisfied by the payment of wages for weekly, biweekly, or semimonthly payroll if the wages are paid not more 21 than seven calendar days following the close of the payroll period. Lab. Code § 204(d). 22 Throughout the statute of limitations period applicable to this cause of action, employees were also entitled to be paid twice a month at their regular rates, including all meal period premium wages 23 owed, rest period premium wages owed, and wages owed for hours worked. However, during all 24 such times, Defendant systematically failed and refused to pay the employees all wages due, and failed to pay those wages twice a month, in that employees were not paid all wages for all meal 25 periods not provided by Defendant, all wages for all rest periods not authorized and permitted by 26 Defendant, and all wages for all hours worked. As a result, Defendant owe employees the legally required wages for unpaid wages, and Plaintiff and the Aggrieved Employees suffered damages in 27 those amounts. 28 Moreover, Defendant is liable to Plaintiff and the Aggrieved Employees for the civil penalties 7

provided for in Labor Code § 210 for failing to pay all earned wages twice per month. 1 Failure to Provide Paid Sick Leave and Written Notice of Available Paid Sick Leave 2 Labor Code § 246 (a) an employee who, on or after July 1, 2015, works in California for the same 3 employer for 30 or more days within a year from the commencement of employment is entitled to 4 paid sick days. 5 Labor Code § 246 (i) requires employers to provide an employee with written notice that sets forth the amount of paid sick leave available. 6 During the statutory period, Defendant maintained a policy and practice of failing to provide 7 Plaintiff and the Aggrieved Employees with the paid sick leave as well as to provide a written notice of accrued paid sick leave. On information and belief, Defendants’ failure to provide an 8 employee with written notice that sets forth the amount of paid sick leave available was not a 9 single, isolated incident, but was instead part of Defendant’s policy and practice that applied to the Aggrieved Employees. 10 As a result, Defendant is liable to Plaintiff and the Aggrieved Employees for the civil penalties 11 provided for in Labor Code § 2699(f)(2) for failing to provide any information on accrued sick 12 leave. 13 Failure to Pay All Accrued Vacation Wages at Termination 14 Labor Code § 227.3 requires employers to pay employees for all unused vested vacation time at their final rate of pay upon termination of their employment. 15 During the statutory period, Defendant maintained a policy and practice of failing to pay Plaintiff 16 and the Aggrieved Employees the vacation pay and the correct amount of vacation pay owed at the termination of employment. For instance, when Plaintiff’s employment with Defendant terminated, 17 he was owed vacation wages which Defendant failed to pay. On information and belief, 18 Defendant’s failure to pay Plaintiff the accrued vacation pay was not a single, isolated incident, but was instead part of Defendant’s policy and practice that applied to the Aggrieved Employees. 19 As a result, Defendant is liable to Plaintiff and the Aggrieved Employees for the civil penalties 20 provided for in Labor Code § 2699(f)(2) for failing to pay all accrued vacation wages at termination. 21 Action for Civil Penalties Under PAGA 22 23 In light of the above, Plaintiff alleges that Defendant violated the following provisions of the Labor Code with respect to the Aggrieved Employees: 24 1. Labor Code § 204, 510, 1194, 1197, and 1198 by failing to pay for all hours worked, 25 including minimum wages, straight time wages and overtime wages; 26 2. Labor Code § 226.7, 512 and applicable Wage Orders by failing to provide meal periods; 27 28 8

3. Labor Code § 226.7 and applicable Wage Orders by failing to authorize and permit rest 1 periods; 2 4. Labor Code § 1174.5 and applicable Wage Orders by failing to maintain accurate 3 records of hours worked and meal periods taken or missed; 4 5. Labor Code § 2802 by failing to reimburse and indemnify employees for expenses and losses in the direct consequence and discharge of their duties; 5 6. Labor Code §§ 201 to 203 by willfully failing to pay all wages owed at termination; 6 7. Labor Code § 226 by failing to provide accurate itemized wage statements; 7 8. Labor Code § 204 by failing to pay all earned wages two times per month; 8 9. Labor Code § 246 by failing to provide paid sick leave and written notice of available paid sick leave; and 9 10 10. Labor Code § 227.3 by failing to pay accrued vacation pay at termination. Therefore, on behalf of all Aggrieved Employees, Plaintiff seeks applicable penalties related to the 11 violations alleged above pursuant to the PAGA. These include, but are not limited to, penalties 12 under Labor Code §§ 210, 226.3, 558, 1174.5, 1197.1, 2802, and 2699(f)(2). 13 Plaintiff has placed Defendant on notice by mailing a certified copy of this correspondence to its corporate address and address of the agent for service, as indicated on the first page. 14 The facts and claims contained herein are based on the information available at the time of this 15 writing. Therefore, if through discovery and/or expert review, Plaintiff becomes aware of additional compensation owed or losses incurred by Plaintiff or by any other aggrieved employee of Defendant 16 or any additional facts, Plaintiff expressly reserves the right to revise these facts and/or add any new 17 claims by amending the claim letter or by adding applicable causes of action to the complaint which will relate back to the date of this letter. 18 19 Thank you for your attention to this matter. If you have any questions, please do not hesitate 20 to contact me. 21 Sincerely, 22 23 24 Lilit Tunyan, Esq. 25 TUNYAN LAW, APC 26 27 28 9

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “B”

1 Mailing Date] 2 3 NOTICE OF SETTLEMENT 4 Name 5 Address 6 Ramirez v. Landscapes Unlimited, LLC 7 Los Angeles Superior Court, Case No. 24STCV12695 8 Dear NAME: 9 You are receiving the enclosed check in connection with the settlement of a lawsuit entitled Ramirez v. Landscapes Unlimited, LLC, Los Angeles Superior Court, Case No. 24STCV12695. 10 In that lawsuit, Plaintiff Raul Lopez Ramirez asserted various wage and hour claims against Defendant Landscapes Unlimited, LLC (“Defendant”) under Labor Code § 2699 et seq., the 11 California Private Attorney General Act (“PAGA”) on behalf of non-exempt hourly employees of 12 Defendant who worked for Defendant in California between March 16, 2023 through February 24, 2025 (“PAGA Settlement Members”), and on behalf of the State of California. 13 Defendant denied and continues to deny all of the allegations and liability for any claims in this 14 case. Defendant maintains that it was in compliance with the California Labor Code at all times and enters into this Settlement with no admission of liability and solely for the purposes of 15 compromising and settling the action to avoid the cost and operational burden of continued 16 litigation. 17 The Court has not made a determination about Plaintiff’s allegations. This Notice is not to be understood as an expression of any opinion by the Court as to the merits of the claim. 18 The enclosed check is your allocated share of the settlement which was calculated on a pro-rata 19 basis (i.e., proportional) based on the number of pay periods you worked for Defendant in the PAGA period divided by the total number of pay periods worked by all PAGA Settlement 20 Members. Your settlement amount represents civil penalties and may be subject to federal, state, 21 and local taxes and may be reported to the appropriate taxing authorities. Enclosed is an IRS Form 1099 for 100% of this payment. Please consult a tax advisor to determine your individual payment, 22 if any, and reporting obligations. The enclosed check will remain valid and negotiable for one hundred eighty (180) days from the date of the issuance, and shall thereafter automatically be void 23 if not cashed within that time. Funds attributable to any uncashed check will be sent to the California State Controller’s Unclaimed Property division, in your name. 24 25 The Court has approved the parties’ Settlement Agreement (“Settlement”). By operation of the Settlement’s terms, all PAGA Settlement Members are deemed to release, on behalf of themselves 26 and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, Defendant and each of its former and present directors, officers, 27 shareholders, owners, members, attorneys, insurers, predecessors, successors, assigns, subsidiaries, and affiliates from all claims for civil penalties under the California Private Attorneys 28 1

General Act, California Labor Code § 2698, et. seq. (“PAGA”) based on the PAGA Period facts 1 stated in the Operative Complaint and the PAGA Notice filed with the LWDA claims that arose 2 under PAGA based on the facts alleged in the lawsuit. The Settlement does not affect any other type of claim. There is no statutory right for PAGA Settlement Members to opt out or otherwise 3 exclude themselves from this Settlement. 4 Upon entry of the Order approving the Settlement, any PAGA Settlement Member covered by this Agreement will be barred from proceeding with any claim released by this Settlement. 5 You may call the Settlement Administrator, Phoenix Class Action Administration Solutions at--- 6 ----------with any questions. You must inform the Settlement Administrator of any change of 7 address to ensure receipt of your settlement payment. 8 9 PLEASE DO NOT CONTACT THE COURT OR THE CLERK’S OFFICE FOR INFORMATION REGARDING THIS SETTLEMENT. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “2”

1 Date Description Rate ($) 3/16/2024 PAGA Notice submission fee to LWDA 75 2 3/18/2024 PAGA mailing costs to Defendant 19.36 5/21/2024 Complaint court filing fee 454.22 3 5/23/2024 Complaint and Summons process service fee 87.51 5/29/2024 Proof of Service of Complaint court filing fee 7.26 4 10/29/2024 Case Management Statement Court filing fee 11.76 5 12/9/2024 Mediation fee to JAMS 9500 3/24/2025 Economic damages expert fee 1200 6 Joint stipulation for PAGA settlement approval court filing fee 32.31 Final accounting report court filing fee 11.76 7 8 Total costs 11399.18 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “3”

1 2 3 Lilit Tunyan (SBN 329351) ltunyan@tunyanlaw.com 4 Artur Tunyan (SBN 349174) atunyan@tunyanlaw.com 5 TUNYAN LAW, APC 535 N Brand Blvd. Suite 285 Glendale, California 91203 6 Telephone: (323) 410-5050 7 Attorneys for Plaintiff RAUL LOPEZ RAMIREZ, as an individual, and on behalf of all similarly 8 situated employees, 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 11 12 RAUL LOPEZ RAMIREZ, on behalf of Case No.: 24STCV12695 13 themself and all others similarly situated, [Assigned for all purposes to Hon. Doreen B. 14 Plaintiff, Boxer, Dept. 19] 15 v. DECLARATION OF MICHAEL MOORE OF 16 LANDSCAPES UNLIMITED, LLC, a BEHALF OF PHOENIX CLASS ACTION Nebraska Limited Liability Company; and SETTLEMENT ADMINISTRATION IN 17 DOES 1 through 50, inclusive, SUPPORT OF PAGA SETTLEMENT APPROVAL 18 Defendants. 19 Complaint Filed: May 21, 2024 Trial Date: None Set 20 21 22 23 24 25 26 27 28 QUALIFICATION DECLARATION OF MICHAEL MOORE

1 DECLARATION OF MICHAEL MOORE 2 I, Michael Moore, declare as follows: 3 1. I have personal knowledge of the facts set forth herein and if called upon to 4 testify, I could and would do so competently under oath. 2. I am employed by Phoenix Settlement Administrators (“PSA”), as President and 5 Managing Partner. 6 3. I personally have over 15 years of experience in claims management and 7 administration of class and collective action matters. 8 4. PSA has never had any financial interest in or affiliation with the parties or counsel 9 in this matter. 10 5. PSA has extensive experience administering class action matters. PSA has 11 administered complex wage and hour, labor and employment, consumer/ product liability, TCPA, 12 FLSA, FACTA, ERISA and PAGA class action matters, through final approval and distribution. 13 PSA has developed a system of quality assurance measures, to ensure the highest quality service 14 is provided in our cases and to class members. 15 6. PSA’s Claims Management Group has extensive experience in all aspects of 16 Notification and Identification of Class Members, Claims Processing, Formulation and 17 Calculation Methodologies, Award Distribution and Taxation, Accounting and Reconciliation. 18 7. PSA has extensive experience in and are experts at all aspects of administrating 19 complex class action matters including; (i) preparing, printing, mailing and tracking privacy 20 notices; (ii) operation of a 24/7/365 multi-lingual call center; (iii) establishing settlement websites; 21 (iv) claims management; (v) USPS processes and systems, third party tracing, including the use 22 of reverse telephone directory services; (vi) database management, programming and security protocols; (vii) calculating and issuing settlement payments; (viii) tax management, filings, and 23 account reconciliation; and (ix) final approval. 24 8. As part of Settlement Notice procedures, PSA will run the names of all Settlement 25 Aggrieved Employees through the National Change of Address (“NCOA”) database to determine 26 any updated addresses for Aggrieved Employees. If a PAGA Packet from the initial notice mailing 27 is returned as undeliverable, the Settlement Administrator will attempt to obtain a current address 28 QUALIFICATION DECLARATION OF MICHAEL MOORE

1 for the Aggrieved Employee to whom the returned PAGA Packet had been mailed by undertaking 2 skip tracing. If the Settlement Administrator is successful in obtaining a new address, it will 3 promptly re-mail the PAGA Packet to the Aggrieved Employee. Further, any PAGA Packets that 4 are returned to the Settlement Administrator with a forwarding address before the Response Deadline shall be promptly re-mailed to the forwarding address affixed thereto. 5 9. PSA has been appointed as a Settlement Administrator in both State and Federal 6 Courts. 7 Data Handling and Security Procedures 8 10. Phoenix Settlement Administrators has adequate procedures in place to safeguard 9 the data and funds to be entrusted to it. PSA’s Technology and Banking groups are directly 10 involved with Management on all issues of Information Security and Settlement Fund transfer, as 11 it pertains to the continuance of business processes, and all risk, vulnerability, security and 12 assessments as it pertains to information. The group, along with internal systems in place, monitor 13 and communicate with Management on a Preventative and comprehensive level, in order to 14 prevent potential Strategic or Compliance Risks. All processing of confidential and personal 15 information is handled and maintained within the organization and therefore all data received is 16 kept within a strict chain of custody internally. All informational assets are classified and assigned 17 based on initial case assessment, client and procedural requirements. The Technology Group 18 handles all higher-level ownership of information and physical peripherals, as well as ownership 19 of direct / indirect assets associated with technology and the continuance of business, Specific 20 Users, Groups or Entities are assigned Shared Ownership or Management Capability based on 21 procedural needs, and security level granted. 22 11. In addition to high levels of Data Center Policies/Procedures and Facility/Maintenance Security Protocols, PSA’s conducts semiannual training to maintain 23 additional safeguards such as: 24 a. Phoenix Settlement Administration Business Continuity Policy 25 b. Phoenix Settlement Administration Disaster Recovery Plan 26 c. Phoenix Settlement Administration Incident Response Plan 27 d. Phoenix Settlement Administration Personal Computer Security Policy 28 QUALIFICATION DECLARATION OF MICHAEL MOORE

1 e. Phoenix Settlement Administration Phoenix Data Archiving and Retention Policy 2 f. Phoenix Settlement Administration Phoenix Personnel Security Policy 3 g. Phoenix Settlement Administration Risk Assessment 4 h. Phoenix Settlement Administration Service Provider Risk Assessment i. Phoenix Settlement Administrator Classification and Access Rights Policy 5 j. Phoenix Settlement Administrator Password Policy 6 k. Phoenix Settlement Administrators Certification of Destruction 7 l. Phoenix Settlement Administrators Security Awareness Training Program. 8 12. PSA currently maintains both an errors and omissions insurance policy and a 9 separate data breach insurance policy, with coverages of $2 million and $3 million, respectively, 10 and with each policy providing coverage on an occurrence basis. 11 13. PSA costs are reasonable and competitive when compared to the industry. 12 14. PSA only employs a certified and/or qualified translator to translate Court- 13 approved Notices for postings on PSA’s website for dissemination to the Class. 14 15. To complete the Settlement Administration for this case, the Settlement 15 Administration will include hard cost and hourly costs detailed below: 16 • Hard Cost: Postage, Printing Supplies, Toll Free Setup, QSF Bank Setup, NCOA, 17 Skip Tracing, Re-Mail and Translation costs. 18 • Hourly Cost: The hourly rates include Programming Database & Setup, Project 19 Management, Notice Packet Formatting, Programming Undeliverable, Programming Claims 20 Database, Programming Calculations, Disbursement Review, Printing of Notice & Checks, 21 Reconcile Uncashed Checks, Conclusion Reports, Potential Tax Filing and Case 22 Management/Maintenance. 16. Having factored in the hard and hourly cost, the settlement administration for this 23 project has a Will Not Exceed-Flat Fee Total of five thousand dollars and zero cents ($5,000.00). 24 17. PSA is willing to serve as the Administrator of the parties’ settlement in this action. 25 18. No party or law firm involved in this action has any ownership interest in PSA or other 26 relationship with PSA aside from that of clients selecting PSA to provide administration services. 27 28 QUALIFICATION DECLARATION OF MICHAEL MOORE

1 I declare under penalty of perjury under the laws of the United States and state of California 2 that the foregoing is true and correct. 3 Executed on April 2, 2024, at Orange, California. 4 5 ________________________________ 6 Michael E. Moore 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 QUALIFICATION DECLARATION OF MICHAEL MOORE

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “4”

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 Lilit Tunyan (SBN 329351) 2 ltunyan@tunyanlaw.com Artur Tunyan (SBN 349174) 3 atunyan@tunyanlaw.com TUNYAN LAW, APC 4 535 N Brand Blvd. Suite 285 Glendale, California 91203 5 Telephone: (323) 410-5050 6 Attorneys for Plaintiff RAUL LOPEZ RAMIREZ as an individual and on behalf of all 7 employees similarly situated 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF LOS ANGELES 11 RAUL LOPEZ RAMIREZ, individually, and Case No.: 24STCV12695 12 on behalf of all others similarly situated, [Assigned for all purposes to Hon. Doreen B. 13 Boxer, Dept. 19] Plaintiff, 14 [PROPOSED] ORDER GRANTING 15 vs. APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE 16 ATTORNEYS GENERAL ACT OF 2004 AND LANDSCAPES UNLIMITED, LLC, a JUDGMENT 17 Nebraska Limited Liability Company; and 18 DOES 1 through 10, inclusive, 19 Defendants Action Filed: May 21, 2024 20 Trial: Not yet set 21 22 23 24 25 26 27 28 Case No.: 24STCV12695 Ramirez v. Landscapes Unlimited, LLC [PROPOSED] ORDER GRANTING APPROVAL OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEYS GENERAL ACT OF 2004 AND JUDGMENT0

1 TO ALL PARTIES AND TO THEIR COUNSEL OF RECORD: 2 Plaintiff RAUL LOPEZ RAMIREZ (“Plaintiff”), individually and in his capacity as a 3 representative of the State of California on behalf of other allegedly aggrieved employees and Defendant 4 LANDSCAPES UNLIMITED, LLC (“Defendant”) (collectively, “the Parties”) have reached terms of 5 settlement of this action alleging a claim for relief pursuant to the Labor Code Private Attorneys General 6 Act of 2004, Labor Code § 2698, et seq. (“PAGA”). 7 The Parties filed a Joint Stipulation for Approval of Settlement of Claims Brought Pursuant to the 8 Private Attorneys General Act of 2004 (“PAGA”) (the “Joint Stipulation”) memorialized in the PAGA 9 SETTLEMENT AGREEMENT (the “Settlement” or “Settlement Agreement”). A true copy of the 10 Settlement Agreement is attached to the Joint Stipulation as Exhibit 1. The Court having considered all 11 the papers filed and otherwise being fully informed, and good cause appearing therefor enters into this 12 Order and Judgment which is intended to be a final disposition of the Action in its entirety. 13 IT IS HEREBY ORDERED and ADJUDGED that the Joint Stipulation for approval of 14 settlement of claims brought pursuant to PAGA is GRANTED subject to the following findings and 15 orders: 16 1. All terms used for purposes of this Order and Final Judgment, not otherwise defined, shall have 17 the same meaning as given in the PAGA Settlement Agreement (“Settlement” or “Settlement 18 Agreement”), attached as Exhibit 1 to the Joint Stipulation. The terms, provisions, and obligations set 19 forth in the Settlement Agreement attached as Exhibit 1 to the Joint Stipulation are deemed a part of this 20 Order and Judgment incorporated herein in their entirety. 21 2. Pursuant to PAGA, California Labor Code § 2699(l)(2), the Labor and Workforce 22 Development Agency (the “LWDA”) has been given timely notice of the Settlement Agreement. The 23 Court finds and determines that Plaintiff’s notice of the Settlement to the LWDA complied with the 24 statutory requirements of PAGA. 3. The Court has determined that the Settlement is, in all respects, fair, reasonable and accurate, 25 and meets the requirements for approval under PAGA. Accordingly, the Court approves the Settlement. 26 4. The Court finds that the Gross Settlement Amount, Net Settlement Amount, and the 27 28 1 Case No.: 24STCV12695 Ramirez v. Landscapes Unlimited, LLC [PROPOSED] ORDER GRANTING APPROVAL OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEYS GENERAL ACT OF 2004 AND JUDGMENT

1 methodology used to calculate and pay the LWDA Payment, and the PAGA Settlement payments to the 2 PAGA Settlement Members, in accordance with the Settlement, are fair and reasonable. 3 5. The Court confirms approval of the Settlement as to the following group of individuals, 4 collectively referred to as the “PAGA Settlement Members” (sometimes also referred to as “Aggrieved 5 Employees”): 6 All non-exempt or hourly employees of Defendant who worked for Defendant within the State of California from March 16, 2023 through February 24, 2025. 7 8 6. The Court approves the Notice to PAGA Settlement Members, attached as Exhibit A to the 9 Settlement Agreement. 10 7. PAGA claims are released as follows: 11 “Effective on the date when Defendant fully funds the entire Gross Settlement Amount and Plaintiff’s general release payment pursuant to the separate agreement entered into between the 12 Parties, All Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, 13 and assigns, the Released Parties from all claims for civil penalties under the California Private Attorneys General Act, California Labor Code § 2698, et. seq. (“PAGA”) based on the PAGA 14 Period facts stated in the Operative Complaint and the PAGA Notice filed with the LWDA (the “Released Claims”).” 15 Released Parties are as follows: 16 “Defendant and each of its former and present directors, officers, shareholders, 17 owners, members, attorneys, insurers, predecessors, successors, assigns, subsidiaries and affiliates. “ 18 19 8. The Court authorizes Phoenix Class Action Administration Solutions to act as the Settlement 20 Administrator. 21 9. The Court authorizes the Settlement Administrator to calculate and pay the Settlement 22 payments, in accordance with the terms of the Settlement. 23 10. Defendant is directed to deliver the Gross Settlement Amount to the Settlement Administrator within sixty (60) days after the Effective Date, as set forth in the Settlement Agreement. 24 11. The Court awards the Settlement Administrator in this Action its fees and costs of $5,000.00 25 in accordance with the terms of the Settlement Agreement. 26 27 28 2 Case No.: 24STCV12695 Ramirez v. Landscapes Unlimited, LLC [PROPOSED] ORDER GRANTING APPROVAL OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEYS GENERAL ACT OF 2004 AND JUDGMENT

1 12. The Court awards to Plaintiff’s Counsel in this Action its fees of $50,000.00 in accordance 2 with the terms of the Settlement Agreement. The Court awards to Plaintiff’s Counsel actual costs of 3 $11,399.18 as shown by the ledger of costs attached as Exhibit 2 to the Joint Stipulation. 4 13. The Court approves the allocations and gross settlement amount of $150,000.00 for the release 5 of claims brought under PAGA, to be paid in accordance with the terms of the Settlement. 6 14. Under the terms of the Settlement, the Net Settlement Amount is $83,600.82. Seventy-five 7 percent (75%) of the Net Settlement Amount will be paid to the State of California Labor and Workforce 8 Development Agency (“LWDA Payment”), and the remaining amount of the Net Settlement Amount shall 9 be distributed to the PAGA Settlement Members in accordance with the terms of the Settlement. 10 15. Checks for Settlement Shares sent to PAGA Settlement Members shall be valid for one 11 hundred eighty (180) days after issuance. Funds remaining from any checks for Settlement Shares 12 uncashed after one hundred eighty (180) days will be disbursed to the California Controller’s Unclaimed 13 Property Fund in the name of the PAGA Settlement Member. 14 16. Nothing in this Order and Judgment or the Settlement shall be construed as an admission or 15 concession by any party. The Settlement and this resulting Order and Judgment simply represent a 16 compromise of disputed allegations. 17 17. Plaintiff is directed to submit a copy of this Order and Judgment to the LWDA within ten (10) 18 days of the date of this Order and Judgment. 19 After entry of this Order and Judgment, pursuant to California Rules of Court, Rule 3.769(h) and 20 Civil Procedure Code § 664.6, the Court shall retain jurisdiction to construe, interpret, implement, and 21 enforce the Settlement Agreement and this Order and Judgment, to hear and resolve any contested 22 challenge to a claim for settlement benefits, and to supervise and adjudicate any dispute arising from or 23 in connection with the distribution of settlement benefits. 24 IT IS SO ORDERED, ADJUDGED AND DECREED. 25 04/29/2025 26 Dated: _______________________ ______________________________________________ Hon. Doreen B. Boxer 27 LOS ANGELES COUNTY SUPERIOR COURT JUDGE 28 3 Case No.: 24STCV12695 Ramirez v. Landscapes Unlimited, LLC [PROPOSED] ORDER GRANTING APPROVAL OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE ATTORNEYS GENERAL ACT OF 2004 AND JUDGMENT

1 PROOF OF SERVICE STATE OF CALIFORNIA ) 2 ) ss 3 COUNTY OF LOS ANGELES ) 4 I am employed in the county of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 535 N Brand Blvd. Suite 285 5 Glendale, CA 91203. 6 On the date indicated below, I served the document described as: JOINT STIPULATION FOR APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE 7 ATTORNEY GENERAL’S ACT OF 2004 AND [PROPOSED] ORDER GRANTING APPROVAL OF SETTLEMENT OF CLAIMS BROUGHT PURSUANT TO THE PRIVATE 8 ATTORNEYS GENERAL ACT OF 2004 AND JUDGMENT on the interested parties in this action by sending a true copy thereof to interested parties as follows and as stated on the attached 9 service list: 10 Yvette Davis ydavis@hbblaw.com 11 Bianca Falcon bfalcon@hbblaw.com 12 Hagle, Eric R. ehagle@hbblaw.com 13 Jacqueline Araujo jaraujo@hbblaw.com 14 Danny Thammavongsa dthammavongsa@hbblaw.com 15 edocs@hbblaw.com Haight Brown & Bonesteel LLP 16 2030 Main Street Suite 1525 17 Irvine, CA 92614 Telephone: 714.426.4600 18 Facsimile: 714.754.0826 19 Attorneys for Defendant LANDSCAPES UNLIMITED, LLC 20 [] BY E-MAIL: I hereby certify that this document was served from Glendale, 21 California, by e-mail delivery on the parties listed herein at their most recent known e-mail address or e-mail of record in this action. 22 [] BY ELECTRONIC SERVICE: Based on an agreement of the parties to accept electronic 23 service, I caused the documents to be sent to the persons at the electronic service addresses listed above via electronic mail. I did not receive an error message. 24 25 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on April 2, 2025 at Glendale, California. 26 27 Lilit Tunyan 28 Name Signature 1 PROOF OF SERVICE