NOTICE FOR PRODCO, FTP, MARVEL, HOP SKIP & JUMP, ABC STUDIOS & FILM 49 PRODUCTIONS, INC. PARKING PRODUCTION ASSISTANT CLASS ACTION SETTLEMENT

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1 PRODCO, FTP, MARVEL, HOP SKIP & JUMP, ABC STUDIOS & FILM 49 PRODUCTIONS, INC. PARKING PRODUCTION ASSISTANT CLASS ACTION SETTLEMENT THIS NOTICE FORM AFFECTS YOUR LEGAL RIGHTS; PLEASE READ IT CAREFULLY United States District Court for the Southern District of New York Muhammed, et al. v. Prodco, Inc., et al., No. 16 Civ If you were a Parking Production Assistant ( PPA ) in New York between June 2, 2010 and December 31, 2016, please read this Notice Form. You may be able to participate in a Settlement of claims for back pay and other damages. Based on information in Prodco, Inc. s, FTP Productions, LLC s, Marvel Television, Inc. s, Hop Skip & Jump Productions, Inc. s, Touchstone Television Productions, LLC d/b/a ABC Studios and Film 49 s (collectively, ABC s ) records, you may be entitled to participate in the proposed Settlement of Muhammed, et al. v. Prodco, Inc., et al., No. 16 Civ (the Class and Collective Litigation ). PLEASE NOTE: YOU MAY RECEIVE OTHER NOTICES SIMILAR TO THIS ONE INVOLVING SETTLEMENTS WITH DIFFERENT DEFENDANTS IN THIS OR OTHER CASES. IF YOU DO, YOU MUST FILL OUT A DIFFERENT CLAIM FORM FOR EACH ONE IN ORDER TO PARTICIPATE IN EACH SETTLEMENT. THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK HAS PRELIMINARILY APPROVED THIS SETTLEMENT. You may indicate your desire to participate in the Settlement by submitting a fully completed Claim Form and Identification Document to the Claims Administrator by October 9, If the Settlement is finally approved by the Court, you will be mailed a Settlement Check for approximately $N/A. You can, if you wish, opt-out of the Settlement, but if you do so and you still wish to pursue claims against ABC, you will have to commence a new action and represent yourself in that case or obtain new lawyers to represent you. You can also object to the Settlement (but if you object, you cannot opt-out). More information about this case, the proposed Settlement, and your rights are set forth below in this Notice Form. POUNOT021

2 YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT: TO RECEIVE A SETTLEMENT PAYMENT Submit a timely Claim Form and/or cash your Settlement Check. You are eligible to receive money from the qualified settlement fund. You may indicate that you wish to participate in the Settlement by fully and timely completing, signing and mailing, ing or faxing the enclosed Claim Form and an Identification Document to the Claims Administrator. The Claim Form must be postmarked, ed or faxed to the Claims Administrator on or before October 9, 2017 See Section 8 for complete instructions. Whether you submit the Claim Form and Identification Document or not, a Settlement Check will be mailed to you at the last known postal address for you available to the Claims Administrator representing the payments you are entitled to under the Settlement. If you cash this check, you will release all of your claims under the Settlement. TO EXCLUDE YOURSELF FROM THE SETTLEMENT (i.e., OPT-OUT) Get out of this lawsuit (opt-out). Receive no money from the qualified settlement fund. Keep any rights you might have to pursue claims against ABC. If you do not wish to participate in the Settlement, you can exclude yourself ( opt-out ) from the Class and Collective Litigation and the Settlement by following the directions outlined in Section 10 below. If you exclude yourself, you will not receive a Settlement Payment and you cannot object to the Settlement, as you will no longer be a part of the Class and Collective Litigation. You will retain the right to bring your own action under federal and state law if you have any timely claims. If you wish to bring an action on your own, you will need to retain an attorney or represent yourself. Any potential Class Member who follows the opt-out procedure will be excluded from the Settlement Classes. TO OBJECT TO THE SETTLEMENT Write to the Court about why you think the settlement is unfair to the class. You will still be bound by the Settlement. You may write to the Court about why you believe the Settlement is unfair or unreasonable. If you object, you may ask to appear before the Court to express your concerns about the fairness of the Settlement. Procedures for objecting are described in Section 9 below. Whether or not the Court rejects your objection, you will still be bound by the terms of the Settlement. IF YOU DO NOTHING IN RESPONSE TO THIS NOTICE FORM AND YOU DO NOT CASH YOUR SETTLEMENT CHECK Receive no money from the Settlement Fund. Give up certain rights. If you do not submit a Claim Form and Identification Document or cash the Settlement Check you receive, but also do not opt-out, you: (1) will still be bound by the release of any state law claims as described in the enclosed Claim Form (which means you cannot sue ABC under any state law for overtime compensation or other damages related to wage matters); and (2) will not receive any money from the Settlement. However, you will retain your right to bring an action under the FLSA. If you wish to retain the ability to continue to sue under both federal and state law, you must opt-out of the Settlement. These rights and options and the deadlines to exercise them are explained in more detail below. For additional information, you may visit

3 1. What is this Litigation about? Several lawsuits were filed by current and former Parking Production Assistants ( PPAs ) alleging that PPAs are owed compensation for hours worked that they were not paid for, and related damages. Specifically, the PPAs allege, inter alia, that ABC violated the Fair Labor Standards Act ( FLSA ) and New York Labor Law by not paying PPAs correctly for all of the hours, including overtime hours, that they worked. ABC denies that it violated any law and maintains that it has consistently acted in accordance with all governing laws at all times, including by paying PPAs correctly. ABC specifically denies any wrongdoing or liability but agreed to settle the lawsuits to avoid continued litigation. To learn more about the claims in the Complaints and information about this settlement, you can go to the website: 2. Why did I receive this Notice Form? The Court in the relevant actions granted preliminary approval of a Settlement Stipulation and authorized the mailing of this Notice Form to you. This Notice describes the Settlement. You received this Notice Form because payroll records indicate that you provided services as a PPA on one or more productions produced by ABC between June 2, 2010 and December 31, Why is there a class settlement? A class action is a lawsuit where one or more persons, called class representatives, sue not only for themselves, but also on behalf of other individuals who have similar claims. These individuals are called Class Members. In a class action, one court resolves the issues for all Class Members who do not opt out of the case. 4. Why is there a Settlement? The attorneys representing the Class Members ( Class Counsel ) have analyzed and evaluated the merits of the claims made against ABC in the Class and Collective Litigations. Upon careful consideration of all of the facts and circumstances, Class Counsel believes that the Settlement negotiated with ABC is fair, reasonable and adequate and is in the best interest of the Class. The Court has preliminarily agreed with that assessment by permitting this Notice Form to be sent to you. 5. How much is the total settlement? Pursuant to the Settlement Stipulation, ABC has agreed to pay $1,750, to settle the Class and Collective Litigation. This amount shall be used for distribution to Participating Class members, minus any payment for Attorneys fees and costs, Claims Administrator fees and costs, Service Payments to Class Representatives (subject to the Court s approval), and Defendants share of payroll taxes. 6. How much is my Settlement Payment? If the Settlement is finally approved by the Court, you will receive a Settlement Check for approximately $N/A representing settlement amounts for the following claims: Back Pay: $N/A (this amount will be subject to standard payroll deductions and you will receive an IRS Form W2 and its state and local equivalents for this payment); Other Damages: $N/A (this amount will not be subject to standard payroll deductions but you may owe taxes on this amount and will receive an IRS Form 1099-MISC and its state and local equivalents for this payment). Your Participating Class Member Final Settlement Payment will be a proportionate share of the Net Settlement Amount, as determined by the Claims Administrator pursuant to a formula and based on a number of factors, including: (i) whether you were engaged as a PPA by ABC during the relevant time period, as reflected in the applicable payroll records; (ii) how many productions you worked on and for how long; and (iii) the number of PPAs who participate in the Settlement. ABC s records (and those of any applicable third-party payroll companies) are presumed to be correct, and in the absence of proof to the contrary will be used to calculate your Participating Class Member Final Settlement Payment

4 7. When will I get my Settlement Payment? The Court will hold a Fairness Hearing to determine whether to finally approve the Settlement, as described in more detail in Sections 16 and 17. If the Court finally approves the Settlement, and there are no appeals, payments will go out within 55 days after the Court issues its Final Approval Order. It there are any appeals, then the process will be delayed. You will need to deposit or cash your Settlement Check within one-hundred eighty (180) calendar days after it is dated. Any uncashed checks after that date will be void and will not be re-issued. 8. How can I participate in the Settlement? You may indicate that you wish to participate in the Settlement by completing, signing and mailing, ing or faxing the enclosed Claim Form and an Identification Document to the Claims Administrator. Your Claim Form and Identification Document must be postmarked, faxed or ed to the Clams Administrator on or before October9, The Claims Administrator s address is: PPA Overtime Litigation Settlement re ABC Claims Administrator P.O. Box , Louisville, KY info@abcppasettlement.com Tel: Fax: Muhammed, et al. v. Prodco, Inc., et al., No. 16 Civ By filling out and submitting your Claim Form and Identification Document, you are opting in to the FLSA portion of the action. To ensure that your Settlement Check is mailed to the proper address, you are strongly encouraged to fill out and timely submit a Claim Form and Identification Document; however, if you do not submit your Claim Form and Identification Document, you will still receive a Settlement Check if you are eligible to receive one. You will also opt in to the FLSA portion of the action if you cash your Settlement Check. The Claims Administrator will not make your payment until the Settlement is fully and finally approved by the Court. If you submit a Claim Form and Identification Document, you should contact the Claims Administrator before the claim filing deadline of October 9, 2017 to confirm your fully completed Claim Form was received. You should keep the Claims Administrator informed of any changes in your address until you have received your Settlement Check and tax reporting forms. 9. How do I tell the Court that I do not like the Settlement or object to it? If you do not opt-out of the Settlement, you can object to the Settlement if you do not like any part of it. You can give reasons why you think the Court should not approve it. If you object and the Settlement is approved, you will be barred from bringing your own individual lawsuit asserting claims related to the matters released through this Settlement, and you will be bound by the final judgment in the case with respect to all claims under state law (and, if you submit a Claim Form and Identification Document and/or cash your Settlement Check, with respect to all claims under the FLSA) and all Orders entered by the Court. To object, you must send a letter to the Claims Administrator saying that you object to the Settlement. The Claims Administrator will share your objection with Class Counsel and ABC s Counsel and your objection will be filed with the Court. You will be contacted by the Claims Administrator or Class Counsel with the date, time and location of any Court hearing. The Court will consider your objection, whether or not you attend the Fairness Hearing, described in Sections 16 and 17 below. However, if you wish to appear before the Court to be heard, you must specifically request to do so in your objection letter. Your statement must include all reasons for your objection and any supporting documentation in your possession. Your statement must also include your name, address, address, and telephone number, and a list of the productions upon which you worked. You must also include whether you are represented by counsel, and if you are, the name and address of your counsel. Your objection will not be heard unless it is postmarked and sent to the Claims Administrator on or before 30 days following the date that this Notice Form was postmarked. 10. How do I exclude myself (opt-out) of the Settlement? If you wish to exclude yourself from the Settlement, you must submit a written request. To do so, you must mail a written, signed statement to the Claims Administrator stating I opt out of the PPA Class Action Litigation against ABC or words to that effect which clearly express your desire to exclude yourself from this Settlement and the Class and - 4 -

5 Collective Litigation. You must include your name, address, and telephone number in the statement and you must sign the statement ( Request for Exclusion ). To be effective, the Request for Exclusion must be mailed, ed, or faxed to the Claims Administrator on or before 60 days following August 9, 2017; or, if your Notice Form was r ed, either the remainder of the sixty days following August 9, 2017 or twenty days after the r ing of such form, whichever is longer. It must be sent to the Claims Administrator at the mailing address, address, or fax number listed in Section 8. If you exclude yourself, you will NOT receive any monies from the Settlement. If you fail to include the required information or if your Request for Exclusion is not timely received by the Claims Administrator, your Request for Exclusion will be deemed null, void and ineffective. Failure to be excluded will result in your remaining a member of the Settlement Classes and you will be bound by any final judgment in the case with respect to all claims under state law. If you validly and timely request exclusion, you will not be bound by any final judgment, and you will maintain your right to pursue your individual claims against ABC. If you wish to bring an action on your own, you will need to retain an attorney or represent yourself. By opting-out you will automatically be excluded from the Settlement Classes there is no discretion that will be exercised by the Court or by counsel as to the exclusion of those who properly request it. (Fed R. Civ.P.23(c)(2)(B)(v).) 11. What s the difference between objecting and excluding yourself (opting-out)? Objecting is simply telling the Court that you do not like something about the Settlement. You can object only if you do not exclude yourself from the Settlement. In other words, if you object, you will still be part of the Settlement. Excluding yourself from the Settlement ( opting-out ) is telling the Court that you do not want to be part of the Settlement. If you exclude yourself, you have no basis to object because the case no longer affects you. 12. What happens if I do nothing? If you choose not to submit a Claim Form and Identification Document, or if you do not timely and properly return your Claim Form and Identification Document, a Settlement Check will be mailed to you at the last known postal address for you available to the Claims Administrator, and you will release your state law claims ( State Law Released Claims ), and will not be able to sue ABC for overtime compensation or other damages related to wage matters under state law. If you cash your Settlement Check, you will also release your claims under the FLSA ( FLSA Released Claims ). If you do not cash the Settlement Check, you will retain any claims you may have under the FLSA. Please review the enclosed Claim Form for a complete explanation of all Released State Law Claims and FLSA Released Claims. 13. Who is Class Counsel? The Court appointed the following lawyers as Class Counsel to represent the Class: VALLI KANE & VAGNINI LLP Robert J. Valli, Jr. Sara Wyn Kane James A. Vagnini 600 Old Country Road, Suite 519 Garden City, New York (516) You may also retain counsel of your own choosing to represent you in this action. 14. Are attorney fees, costs, expenses and service payments being sought? Class Counsel has pursued the lawsuit on a contingent basis and has not received any payment of fees or any reimbursement of their out-of-pocket expenses related to the recovery on behalf of the Settlement Classes. As part of the Settlement, Class Counsel will ask the Court to approve a payment to them of one-third of the qualified settlement fund for their Attorneys Fees and Lawsuit Costs. Class Counsel seeks these Attorneys Fees and Lawsuit Costs to pay for investigating the facts of this case, litigating this case and negotiating the Settlement. In addition, the Class Representatives and those who expended significant time and effort in getting the claims settled will seek payments of $5,000 each for their role in the case. Service Payments and Attorneys Fees and Lawsuit Costs have already been deducted in calculating your Estimated Settlement Payment set out herein

6 15. What is the legal effect of the Settlement? If the Court grants final approval of the Settlement, Settlement Checks will be issued to all Class Members who have not opted out of the Settlement. Those Class Members who have either timely submitted a Claim Form and Identification Document or cashed their Settlement Check will have fully released and discharged ABC from federal and state law claims for wages, benefits, and other compensation arising out of or relating to the facts alleged in the Class and Collective Litigation. If you do not submit a Claim Form and Identification Document or cash your Settlement Check and did not opt-out, your claims under state law are released. These claims are described in the enclosed Claim Form. When claims are released, that means that a person covered by the release cannot sue ABC for any of the claims that are covered by the release. If you timely opted-out of the Settlement, you have not released any claims. 16. When will the Court decide whether to finally approve the Settlement and what if it is not approved? The Court will hold a Fairness Hearing on December 14, 2017 at the United States District Court for the Southern District of New York, at, 10:00 A.M. At this hearing the Court will finally consider whether the Settlement is fair, reasonable, and adequate and whether it should be approved and, if so, the Court will determine what amount of Attorneys Fees and Lawsuit Costs and Service Payments should be awarded. If there are objections, the Court will consider them. The Court will listen to individuals who have asked to speak at the hearing. At or after the Fairness Hearing, the Court will decide whether to grant the Settlement final approval. The Parties do not know how long it will take for the Court to issue its decision. The time and date of the hearing may be changed without further notice. If the Court does not approve the proposed Settlement, the case will proceed as if no settlement has been attempted and there can be no assurance that the class will recover more than is provided for in this Settlement, or indeed anything. 17. Do I have to attend the Fairness Hearing? No, you are not required to attend the Fairness Hearing, but are welcome to, at your own expense. Class Counsel will represent you at the hearing, unless you have opted-out of the action. 18. Are there more details about the Settlement? What if I have any questions? This Notice Form summarizes the terms of the proposed Settlement. You may also view a pdf of the relevant documents in the case (including the Complaint, Notice Form, and Claim Form) at If you have a procedural question such as how to complete the Claim Form, please contact the Claims Administrator. If you have a question that requires legal consultation, please contact Class Counsel Robert J. Valli, Jr., Sara Wyn Kane, or James A. Vagnini at Valli Kane & Vagnini LLP, 600 Old Country Road, Suite 519, Garden City, New York 11530, (516) , Your communications with Class Counsel will be strictly confidential and privileged. 19. What if my name or address changes? NO INQUIRIES SHOULD BE DIRECTED TO THE COURT. If your name, mailing address, address, and/or telephone number changes after you receive this Notice Form or submit your Claim Form and Identification Document, you must notify the Claims Administrator immediately. If you do not correct your address, a Settlement Check may be mailed to the address that is on file for you. Therefore, it is your duty to keep an updated address on file. The contact information for the Claims Administrator is listed in Section 8 above. 20. Will I be retaliated against? Whether you are a current or former PPA working on an ABC production, your decision as to whether or not to submit a Claim Form or cash your Settlement Check will in no way affect your current or future work with ABC productions. Consistent with its policies against retaliation, ABC is prohibited by law from taking any action against individuals who participate in the Settlement