DELCARATION OF ELIZABETH DITIRRO IN SUPPORT OF MOTION FOR FINAL APPROVAL

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2 I, ELIZABETH DITIRRO, declare as follows: 1. I am a resident of the United States of America, and am over the age of 18. I am a Project Manager for ILYM Group, Inc., (herein after referred to as ILYM Group ) the professional settlement services provider that has been retained by the Parties to serve as the Claim Administrator for the above captioned action, Leslie Veurink v. Beverly Health and Rehabilitation Services, Inc., et al.. The facts set forth herein are based on my own personal knowledge. If called as a witness, I could and would competently testify thereto. 2. ILYM Group has extensive experience in administering class action settlements, including direct mail services, database management, claims processing, and settlement fund distribution services for class actions ranging in size from 26 to 4.5 million class members. 3. On February 11, 2016, the Court appointed ILYM Group as the Claims Administrator in the above referenced Action. In this capacity, ILYM Group was charged with (a) printing and mailing the Notice of Pendency of Class Action Settlement, Claim Form and Exclusion Form; (b) conducting address traces to locate Class Members as necessary; (c) responding to Class Member inquiries; (d) calculating and distributing the amounts due to Class Members pursuant to the Settlement; (e) tax reporting in connection with the Settlement; and (f) any other duties necessary for administration of the Settlement, as the Parties mutually agree to and/or the Court orders ILYM Group to perform. 4. On February 18, 2016, ILYM Group received the class data files from Defendant, which contained the Class Members names, last known addresses, social security numbers, and dates of employment. The data file was uploaded to our database and checked for duplicates and other possible discrepancies. The final mailing list contained two thousand three hundred seventeen (2,317) Class Members. 5. As part of the preparation for mailing, all two thousand three hundred seventeen (2,317) names and addresses were then processed against the National Change of Address ( NCOA ) database, maintained by the United States Postal Service ( USPS ), for purposes of updating and confirming the mailing addresses of the Class Members before mailing of the Notice Packet. To the extent an updated address for an individual identified as a Class Member was found DELCARATION OF ELIZABETH DITIRRO IN SUPPORT OF MOTION FOR FINAL APPROVAL

3 in the NCOA database, the updated address was used for mailing the Notice Packet. To the extent that no updated address was found in the NCOA database, the original address provided by Defendant was used for mailing the Notice Packet. 6. On March 17, 2016, the notice packet was mailed via U.S first class mail. A true and correct copy of the mailed notice packet is attached hereto as Exhibit A. 7. As of the date of this declaration, two hundred seventy five (275) notice packets have been returned to our office as undeliverable. Of the two hundred seventy five (275) notice packets that have been returned to our office as undeliverable, two (2) were returned with a forwarding address provided by the post office. ILYM Group performed a computerized skip trace on the two hundred seventy three (273) returned notice packets that did not have a forwarding address, in an effort to obtain an updated address for purposes of r ing the notice packet. Of the two hundred seventy three (273) notice packets that were skip traced, two hundred sixty (260) updated address was obtained and the notice packet was promptly r ed to the Class Members via first class mail. 8. As of the date of this declaration, there are thirteen (13) undeliverable notice packets, since an updated address could not be obtained. 9. As of the date of this declaration, ILYM Group has not received any objections to the Settlement. The deadline to Object to the settlement is May 2, The deadline to submit a Request for Exclusion (or Opt-Out) is May 2, As of the date of this declaration, ILYM Group has received nine (9) Requests for Exclusion. 11. As of the date of this declaration, ILYM group has received three hundred two (302) valid Claims which account for approximately 25.42% of the total workweeks. The deadline to submit a Claim is May 2, The Estimated Net Settlement Proceeds available to pay Class Members is $213, which was determined by subtracting the following from the $375,000 Maximum Settlement Amount: the requested Class Representative Enhancement Awards ($10,000.00), requested Class Counsel s fees ($112,500.00), requested Class Counsel s expenses ($19,832.81), and the Settlement Administration costs ($18,682.09). The highest Individual Settlement Payment DELCARATION OF ELIZABETH DITIRRO IN SUPPORT OF MOTION FOR FINAL APPROVAL

4 to be paid is approximately $1, with the average Individual Settlement Payment to be paid being approximately $710.91, without applicable taxes, and withholdings. The estimated Settlement Payments will likely change due to incoming Claim submissions. These amounts will be updated in our supplemental declaration that will be submitted after the May 2, 2016 Claim deadline. 13. ILYM Group will incur a total of $18, in costs, associated with the administration of this settlement. This will include all costs incurred to date, as well as estimated costs involved in completing the settlement administration. I declare under penalty of perjury that the foregoing is true and correct. Executed on this 25 th day of April, 2016 at Tustin, California. Elizabeth DiTirro DELCARATION OF ELIZABETH DITIRRO IN SUPPORT OF MOTION FOR FINAL APPROVAL

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6 SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF SONOMA LESLIE VEURINK. V. BEVERLY HEALTH AND REHABILITATION SERVICES, INC., ET AL. CASE NO. SCV NOTICE OF PROPOSED CLASS ACTION SETTLEMENT AND FINAL SETTLEMENT APPROVAL HEARING A court authorized this notice. This is not a solicitation from a lawyer. IF YOU WORKED FOR BEVERLY HEALTH AND REHABILITATION SERVICES, INC., GGNSC ADMINISTRATIVE SERVICES, LLC AND/OR HOSPICE PREFERRED CHOICE, INC. AS A CLINICAL EMPLOYEE IN THE STATE OF CALIFORNIA DURING ALL OR PART OF THE PERIOD FROM JUNE 8, 2008 THROUGH MAY 23, 2014, YOU COULD RECEIVE A PAYMENT FROM A PROPOSED CLASS ACTION SETTLEMENT. A proposed class action settlement ( the Settlement ) has been reached between plaintiffs Leslie Veurink and Andrew Carr ( Plaintiffs or Class Representatives ), on behalf of themselves and the below-defined Settlement Class, and defendants Beverly Health and Rehabilitation Services, Inc., GGNSC Administrative Services, LLC, and Hospice Preferred Choice, Inc. ( Golden Living or Defendants ). The Settlement resolves a class action lawsuit about claims that Golden Living violated various California and Federal wage and hour labor laws including, among other things, (1) allegedly failing to pay minimum wage and overtime compensation, (2) allegedly failing to provide California employees with meal and rest periods in compliance with California law, (3) allegedly failing to provide accurate written wage statements to California employees, and (4) allegedly failing to timely pay earned wages to California employees following the termination of their employment. Defendants deny all liability to Settlement Class members, assert that Golden Living has fully complied with all applicable wage and hour laws, and have entered into the Settlement solely for purposes of resolving this dispute. The Settlement provides for cash payments to participating Class Members (those who submit timely and valid Claim Forms) who worked in California during all or part of the period from June 8, 2008 through May 23, Settlement payments shall be allocated pro-rata among participating Class Members according to the number of pay periods they worked between the dates of June 8, 2008 and February 11, 2016 (the date of preliminary approval of the Settlement). The enclosed Claim Form lists your estimated gross individual settlement payment, the dates of your employment in California by Golden Living and the pay periods you worked during the Class Period. OVERVIEW OF YOUR LEGAL RIGHTS AND OPTIONS UNDER THE SETTLEMENT PARTICIPATE DO NOTHING EXCLUDE YOURSELF OBJECT To receive a cash payment from the Settlement, you must return the enclosed Claim Form by no later than May 2, If you do nothing, you will not receive any cash payment from the Settlement and, if you were employed by Golden Living in California, you will give up your rights to be part of any other lawsuit against Defendants involving claims arising under California law that are the same as or similar to the ones in this case. You will, however, retain your right to be part of another lawsuit against Defendants for the same or similar claims that arise under the federal Fair Labor Standards Act. The only way for you to be part of any other lawsuit against Defendants involving legal claims that arise under California law and are the same as or similar to the ones in this case is to submit a valid Request for Exclusion to the Claims Administrator postmarked no later than May 2, If you were employed by Golden Living in California and wish to object to the Settlement, you must not exclude yourself from the Settlement and you must submit a written objection and supporting papers, to the Claims Administrator that is postmarked, no later than May 2, These rights and options, and how to exercise them, are explained in more detail in this notice and on the enclosed Claim Form. The Court handling this case still has to decide whether to grant final approval to the Settlement. Cash payments will only be issued if the Court grants final approval to the Settlement. 1

7 Additional information regarding the Settlement is available through the Claims Administrator or Class Counsel, whose contact information is provided in this notice. Additionally, the full terms of the Settlement, as well as all relevant pleadings in this lawsuit can be found online at the following address: FREQUENTLY ASKED QUESTIONS BASIC INFORMATION 1. Why did I get this notice? Golden Living s records show that you are, or have been, employed as an hourly clinical employee in California during all or part of the period from June 8, 2008 through May 23, This notice explains the lawsuit, the Settlement, and your legal rights. The lawsuit in the Superior Court of the State of California, County of Sonoma, is known as Leslie Veurink, et al. v. Beverly Health and Rehabilitation Services, Inc. et al., Case No. SCV ( Action ). Leslie Veurink and Andrew Carr are called the Plaintiffs, and the companies they sued, Beverly Health and Rehabilitation Services, Inc., GGNSC Administrative Services LLC, and Hospice Preferred Choice, Inc. are called the Defendants. The judge assigned to oversee this class action is the Honorable Allan Hardcastle (the Court ). 2. What is the Action about? The Action generally involves claims under California and Federal wage and hour laws. Plaintiffs are former employees of Golden Living who worked as hourly clinical employees in the State of California. Plaintiffs allege, among other things, that Defendants allegedly failed to pay minimum wage and overtime compensation to California employees, allegedly failed to provide California employees with meal and rest periods in compliance with California law, allegedly failed to provide accurate written wage statements to California employees, and allegedly failed to timely pay earned wages to California employees following the termination of their employment. Defendants deny all liability and assert that they have fully complied with all applicable wage and hour laws, assert that the Action should not be a class action except for purposes of the Settlement and they have entered into the Settlement solely for purposes of resolving this dispute. 3. Why is this lawsuit a class action? In a class action, one or more individuals are called the class representative. In this case, Leslie Veurink and Andrew Carr are the class representatives who brought suit on behalf of other employees who have similar claims. All of these people are a class or class members. One court resolves the issues for all class members, except for those who exclude themselves from the class. On February 11, 2016 (date of preliminary approval), the Court issued an order conditionally certifying the Settlement Class defined in response to Question 4 below for purposes of settlement only. 4. Who is in the Settlement Class? The Settlement Class is defined as follows: All current and former clinical employees of Beverly Health and Rehabilitation Services, Inc., GGNSC Administrative Services, LLC and Hospice Preferred Choice, Inc., employed in California during the Class Period, i.e. from June 8, 2008 to May 23, The certified class specifically excludes: 1) any individual who is a Plaintiff in pending litigation against Golden Living in federal or state court involving claims under the FLSA or California Labor Code or who executed a court-approved waiver of claims in any such case, and 2) any individual who chose to opt-in and receive a settlement payment in the case of Jarrett v. GGNSC Holdings, LLC, 2:12-cv BP, pending in the United States District Court for the Western District of Missouri. 5. Why is there a settlement? After engaging in substantial discovery, including Defendants production of timecard data for randomly selected putative class members, both sides agreed to the Settlement to avoid the cost and risk of further litigation. The Settlement does not mean that any law was broken. Golden Living denies all of the legal claims in the case. The Class Representatives and their lawyers think the Settlement is in the best interests of all Settlement Class members. 2

8 6. What does the settlement provide? THE SETTLEMENT BENEFITS WHAT YOU GET Under the terms of the Settlement, Golden Living agrees to pay a Total Settlement Amount in the amount of $375,000. Deducted from the Gross Settlement Fund will be sums approved by the Court for attorneys fees (not to exceed $112,500, 30% of the Total Settlement Amount), attorneys actual costs as approved by the Court, enhancement awards to Plaintiffs for their services as the Class Representatives (not to exceed $5,000 each) as approved by the Court, and the fees and expenses of the Claims Administrator as approved by the Court. The total Court-awarded deductions from the Total Settlement Amount will result in a Net Settlement Amount which will be distributed to those Class Members who submit claims for payments. The Settlement Fund will be distributed to Participating Class Members according to the number of pay periods they worked between the date of June 8, 2008 and February 10, 2016 (preliminary approval of the settlement). Payments will be characterized as 50% wages and 50% interest and penalties. Each Participating Class Member s share of payroll and income taxes, all other applicable deductions or withholding required by law or expressly authorized by the Participating Class Member, including payments of any liens, garnishments or levies, shall be withheld from the Individual Settlement Payment. The attached Claim Form lists the estimated gross amount you would be entitled receive if you participate in the Settlement and submit a valid Claim Form. The Claim Form also lists the dates of your employment by Golden Living during the Class Period and the pay periods worked during the relevant time. If you believe the Claim Form is incorrect and you wish to challenge the payroll information used by the Claims Administrator to determine your approximate settlement payment (for example, the number of pay periods worked), please notify the Claims Administrator no later than May 2, 2016: ILYM Group, Inc. P.O. Box 130 Tustin, CA (888) You must submit written evidence to support your challenge to the payroll information with the enclosed Claim Form. The Claims Administrator will have full discretion as to whether to accept or deny your challenge. 7. What am I giving up in exchange for the settlement benefits? In exchange for the consideration provided, Plaintiffs and each member of the Class who does not submit a valid Request for Exclusion (defined in response to Question 10 below) will release the following claims: All Class Members who failed to submit a timely Exclusion Form release any and all claims, from June 8, 2008, through the date of the Preliminary Approval Order, against Released Parties that were raised or that could have been raised under California law based upon the facts set forth in the Complaints including, but not limited to, any known or unknown claims relating to allegations that Golden Living failed to pay all overtime due, that Golden Living failed to provide all required meal periods and/or rest breaks, that Golden Living failed to pay Class Members all wages upon termination from employment, that Golden Living did not include all required accurate information on employee wage statements, and that Golden Living owes associated compensation and/or penalties, as founded on state law (the Released Claims ). The Released Claims include all such claims for wages and for civil or statutory penalties, including but not limited to claims under California Labor Code sections 201, 202, 203, 226, 226.7, 510, 512, 1174, , 1194, , 1198, claims for penalties under the Private Attorneys General Act ( PAGA ) (Cal. Labor Code sec. 2699, et. seq.); claims of unfair competition under Cal. Business and Professions Code sec , et. seq.; and costs and attorneys fees and expenses relating to the Released Claims. The claims released by those Class Members who fail to timely submit an Exclusion Form include all such claims, whether known or unknown by the releasing party, that fall within the scope of the Released Claims. Thus, even if a Class Member discovers facts and/or claims in addition to or different from those that they now know or believe to be true with respect to the subject matter of the Released Claims, those claims will remain released and forever barred. Therefore, with respect to those Released Claims, Class Members expressly waive and relinquish the provisions, rights and benefits of section 1542 of the California Civil Code, which reads: A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing the release, which if known by him or her must have materially affected his or her settlement with the debtor. Note: To the extent you do nothing (i.e. you do not submit a valid Claim Form) you will not release your claims under the Fair 3

9 Labor Standards Act. You will release, however, all other claims listed above. You can talk to one of the lawyers listed below for free or you can talk to your own lawyer if you have questions about the Class Released Claims and what they mean. 8. How do I get a cash payment? HOW TO GET A CASH PAYMENT To receive a cash payment, you must complete and submit the enclosed Claim Form. You may complete and submit the Claim Form sent to you with this Notice and mail it postmarked no later than May 2, 2016 to: ILYM Group, Inc. P.O. Box 130 Tustin, CA (888) Claim Forms that do not include all required information and/or that are not timely submitted will be deemed null, void, and ineffective. Settlement Class members who fail to submit a valid and timely Request for Exclusion on or before the above-specified deadline shall be bound by all terms of the Settlement and any final judgment entered in the Action if the Settlement is approved by the Court regardless of whether or not they have submitted valid Claim Forms. 9. When will I get my check? Checks will be mailed to Settlement Class members eligible to receive benefits under the Settlement, after the Court grants final approval of the Settlement. If the judge approves the settlement after a hearing on May 18, 2016 (see The Court s Fairness Hearing ), there may be appeals. If there are any appeals resolving them could take some time, so please be patient. Provided that the Court grants final approval of the Settlement, checks will be sent out shortly within approximately ninety days thereafter, assuming there are no appeals. To the extent you have questions regarding when checks will be mailed, please contact the Claims Administrator. EXCLUDING YOURSELF FROM THE SETTLEMENT 10. How do I ask the Court to exclude me from the Settlement Class? If you do not wish to participate in the Settlement, you may be excluded (i.e., opt out ) by completing and timely submitting the enclosed Request for Exclusion form ( Request for Exclusion ). The Request for Exclusion must be signed, dated and mailed by First Class U.S. Mail, or the equivalent, postmarked no later than May 2, 2016 to: ILYM Group, Inc. P.O. Box 130 Tustin, CA (888) Requests for Exclusion that are not properly completed and timely submitted will be deemed null, void, and ineffective. Any Settlement Class Member who fails to submit a valid and timely Request for Exclusion on or before the above-specified deadline shall be bound by all terms of the Settlement and any Judgment entered in the Action if the Settlement receives final approval from the Court. If a Settlement Class Member submits both a Claim Form and a Request for Exclusion, the Request for Exclusion will be disregarded and the Class Member shall remain bound by the terms of the Settlement and any Judgment entered in the Action. 11. If I exclude myself, can I get anything from the Settlement? No. By electing to be excluded from the Settlement Class, (1) you will not receive the check generated by the Settlement (if approved), even if you would otherwise be entitled to it; (2) you will not be bound by any further order or judgments entered for or against the Settlement Class; (3) you will have no right to object to the settlement or be heard at any hearing scheduled for the Court s consideration of the settlement; and (4) you may present any claims against Defendants that were asserted by Plaintiffs in this case by filing your own lawsuit at your own expense or by seeking to intervene in this lawsuit as an individual plaintiff at your own expense. 4

10 12. If I don t exclude myself, can I sue later? No. Unless you exclude yourself, you give up the right to sue Golden Living for any of the Released Claims described in response to Question 7 above. You must exclude yourself from the Settlement Class to start or continue your own lawsuit. 13. Do I have a lawyer in this case? THE LAWYERS REPRESENTING YOU The Court has appointed the following lawyers to serve as Class Counsel for the Settlement Class: Alan Harris Priya Mohan HARRIS & RUBLE 655 North Central Avenue, 17 th Fl. Glendale, CA Telephone: Facsimile: David S. Harris NORTH BAY LAW GROUP 116 E. Blithedale Ave., Suite 2 Mill Valley, California Telephone: Facsimile: How will the costs of the lawsuit and the settlement be paid? Subject to court approval, Class Counsel can petition the Court for up to $112,500 in attorneys fees (30% of the Total Settlement Amount) and actual costs incurred. The Court may award less than these amounts. If lesser amounts are awarded, the difference will be included in the net settlement fund and will be available for distribution to Settlement Class members who timely submit valid Claim Forms. In addition, and subject to Court approval, Plaintiffs Leslie Veurink and Andrew Carr will seek enhancement awards of up to $5,000 each for their participation in this lawsuit and for taking on the risk of litigation. Class Counsel has filed their Motion for Attorneys Fees, Costs and Enhancement Awards, which can be found online at: Furthermore, and subject to Court approval, the Settlement Administrator s costs and fees associated with administering the Settlement shall be paid from the Total Settlement Amount, which are estimated to be approximately $18, The Court may award less than these amounts. If lesser amounts are awarded, the difference will be included in the net settlement fund and will be available for distribution to Settlement Class members who timely submit valid Claim Forms. 15. How do I object to the Settlement? OBJECTING TO THE SETTLEMENT Any member of the Settlement Class may object to the proposed Settlement, or any portion thereof, by a written objection, and supporting papers, mailed to the Claims administrator no later than May 2, The Claims Administrator s address is the following: Claims Administrator: ILYM Group, Inc. P.O. Box 130 Tustin, CA A written objection must contain the objecting person s full name, current address, the last four digits of his or her Social Security Number, include all objections and the reasons therefore, and include any and all supporting papers (including, without limitation, all briefs, written evidence, and declarations). A member of the Settlement Class who desires to object but who fails to comply with the objection procedure set forth herein shall be deemed not to have objected. Any member of the Settlement Class who does not timely submit written objections shall not be permitted to present his, her, or its objections at the Court s Fairness Hearing. Any member of the Settlement Class who submits an objection remains eligible to receive monetary compensation from the Settlement if he or she submits a timely and valid Claim Form. Only members of the Settlement Class who do not file a Request for Exclusion may file objections. 5

11 16. What s the difference between objecting and asking to be excluded? Objecting is simply telling the Court you do not like something about the Settlement. You can object only if you stay in the Settlement Class. Excluding yourself is telling the Court that you do not want to be part of the Settlement Class. If you exclude yourself, you will have no basis to object because the Settlement will no longer affect you. THE COURT S FAIRNESS HEARING The Court will hold a hearing to decide whether to approve the Settlement. If you have filed a timely objection you may attend and you may ask to speak, but you don t have to. 17. When and where will the Court decide whether to approve the settlement? The Court will hold a Final Approval Hearing on May 18, 2016 at 3:00 p.m. in Courtroom 19 of the Sonoma County Superior Court, located at 3055 Cleveland Avenue, Santa Rosa, California The Hearing may be moved to a different date and/or time without additional notice. At this hearing, the Court will consider whether the settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them. The Court will only listen to people who have filed timely objections. The Court will also decide how much to pay Class Counsel for attorneys fees and costs and how much of an enhancement award to pay the Class Representatives. After the Hearing, the Court will decide whether to approve the Settlement. We do not know how long these decisions will take. 18. Do I have to come to the hearing? No. Class Counsel will answer any questions the judge may have. But, you are welcome to come at your own expense. If you send an objection, you don t have to come to Court to talk about it. As long as you mailed your written objection on time, the Court will consider it. You may also pay another lawyer to attend, but it is not required. 19. May I speak at the hearing? If a member of the Settlement Class wishes to appear at the Final Approval Hearing and orally present his or her objection to the Court, the objector must have mailed a timely objection as set forth in paragraph What happens if I do nothing at all? IF YOU DO NOTHING If you are a member of the Settlement Class and you do nothing, you will not receive a payment from this Settlement and you will not be able to start a lawsuit or continue a lawsuit against Defendants about the claims in this case described in response to Question 7 ever again with the sole exception that you will not be releasing your claims under the Fair Labor Standards Act. You will release, however, the other claims described in paragraph How do I get more information? GETTING MORE INFORMATION This notice summarizes the Settlement. More details are in the Settlement. You may contact Class Counsel or the Claims Administrator for more information. Additionally, copies of the settlement agreement, pleadings and other important filings in the Action can be found online at the following address: 6

12 CLAIM FORM SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF SONOMA LESLIE VEURINK. V. BEVERLY HEALTH AND REHABILITATION SERVICES, INC., ET AL. CASE NO. SCV YOU MUST TIMELY COMPLETE, SIGN AND RETURN THIS FORM BY MAY 2, 2016 TO BE ELIGIBLE FOR A MONETARY RECOVERY. <<Name>> <<Address Line 1>> <<Address Line 2>> <<City, State>> <<Telephone Number>> If your name or address is different from those shown above, print the corrections on the lines to the right. If you move, please send us your new address. YOU MUST COMPLETE, SIGN AND MAIL THIS FORM BY FIRST CLASS U.S. MAIL OR EQUIVALENT, POSTAGE PAID, POSTMARKED ON OR BEFORE MAY 2, 2016 ADDRESSED AS FOLLOWS TO BE ELIGIBLE TO RECEIVE A RECOVERY. ILYM Group, Inc. P.O. Box 130 Tustin, CA Under the terms of this Settlement, you qualify to claim an estimated pre-tax payment of approximately $<<estimated award>>. This is the estimated gross amount that you will receive if you timely submit this claim form subject to the following. Your actual gross settlement payment may end up being higher than estimated, depending on the number of Class Members who actually file claims and whether the Court approves the costs of the lawsuit as described in the Notice of Proposed Class Action Settlement ( Class Notice ) you received with this Claim Form. In any event, your gross settlement payment will be subject to appropriate withholding for both the employee and employer portion of applicable payroll taxes relating to the wage portion of the settlement payment. Your gross settlement payment is based on your employment with Beverly Health and Rehabilitation Services, Inc., GGNSC Administrative Services, LLC, and/or Hospice Preferred Choice, Inc. ( Golden Living ) during all or some of the period from June 8, 2008 through May 23, 2014 (the Class Period ). As explained in detail in the enclosed Class Notice, Golden Living s payroll records indicate you are entitled to participate and receive a settlement payment as a member of the following Settlement Class: All current and former clinical employees of Beverly Health and Rehabilitation Services, Inc., GGNSC Administrative Services, LLC and Hospice Preferred Choice, Inc., ( Golden Living ) employed in California during the Class Period, i.e. from June 8, 2008 to May 23, The certified class specifically excludes: 1) any individual who is a Plaintiff in pending litigation against Golden Living in federal or state court involving claims under the FLSA or California Labor Code or who executed a court-approved waiver of claims in any such case, and 2) any individual who chose to opt-in and receive a settlement payment in the case of Jarrett v. GGNSC Holdings, LLC, 2:12-cv BP, pending in the United States District Court for the Western District of Missouri. As a member of this Settlement Class, Golden Living s payroll records indicate you worked [insert total pay periods] during the period of [insert dates of employment during class period]. Your approximate gross pre-tax payment as part of the Settlement Class is [insert approximate payment]. This payment will be characterized as 50% wages and 50% interest and penalties. Your share of payroll and income taxes, and all other applicable deductions or withholding required by law or expressly authorized by you, including payments of any liens, garnishments or levies, shall be withheld from the settlement payment. If you disagree with the number of periods and/or work days listed above, you may dispute these numbers by submitting satisfactory documentation to the Claims Administrator with this Claim Form showing that you worked a different number ILYM ID: <<Insert>>

13 of pay periods and/or work days during the applicable portion of the Class Period. The Claims Administrator will then make a determination on your dispute based on your employment records and any other documents you submit. In resolving a dispute, Golden Living s records shall be presumed to be accurate and correct unless the information you submit proves otherwise. RELEASE OF CLAIMS By signing this Claim Form and in exchange for the payment described above, you agree to the following release: I release any and all claims, from June 8, 2008, through the date of the Preliminary Approval Order, against Released Parties that were raised or that could have been raised under Federal or California law based upon the facts set forth in the Complaints including, but not limited to, any known or unknown claims relating to allegations that Golden Living failed to pay all overtime due, that Golden Living failed to provide all required meal periods and/or rest breaks, that Golden Living failed to pay me all wages upon termination from employment, that Golden Living did not include all required accurate information on my wage statements, and that Golden Living owes associated compensation and/or penalties, as founded on state law (the Released Claims ). The Released Claims include all such claims for wages and for civil or statutory penalties, including but not limited to claims under the Fair Labor Standards Act, California Labor Code sections 201, 202, 203, 226, 226.7, 510, 512, 1174, , 1194, , 1198, claims for penalties under the Private Attorneys General Act ( PAGA ) (Cal. Labor Code sec. 2699, et. seq.); claims of unfair competition under Cal. Business and Professions Code sec , et. seq.; and costs and attorneys fees and expenses relating to the Released Claims. I release all such claims, whether known or unknown by me, that fall within the scope of the Released Claims. Thus, even if I discover facts and/or claims in addition to or different from those that I now know or believe to be true with respect to the subject matter of the Released Claims, those claims will remain released and forever barred. Therefore, with respect to those Released Claims, I expressly waive and relinquish the provisions, rights and benefits of section 1542 of the California Civil Code, which reads: A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing the release, which if known by him or her must have materially affected his or her settlement with the debtor. SIGNATURE AND CERTIFICATION: 1. I have received and read the Notice of Proposed Class Action Settlement. I have had the opportunity to consult with the attorneys of my choosing to ask questions about this lawsuit. I understand that I am releasing any and all claims I might have against Golden Living that are alleged in or related to the Veurink action. Settlement. 2. I wish to receive my share of the proposed Settlement in accordance with the terms of the 3. The last four (4) digits of my Social Security Number (SSN) are:. I declare under penalty of perjury under the laws of the State of California and the United States that the foregoing three paragraphs are true and correct., Date Signature Typed or Printed Name ILYM ID: <<Insert>>

14 REQUEST FOR EXCLUSION SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF SONOMA LESLIE VEURINK. V. BEVERLY HEALTH AND REHABILITATION SERVICES, INC., ET AL. CASE NO. SCV DO NOT FILL OUT THIS FORM IF YOU WANT TO PARTICIPATE IN THE SETTLEMENT. YOU MUST FILL OUT A CLAIM FORM IF YOU WANT TO BE ELIGIBLE FOR MONETARY RECOVERY I declare, under penalty of perjury, as follows: I worked for Beverly Health and Rehabilitation Services, Inc., GGNSC Administrative Services, LLC, and/or Hospice Preferred Choice, Inc. at some time between June 8, 2008 to May 23, 2014 as a non-exempt, hourly-paid clinical employee in California. I wish to be excluded from the Settlement Class and not participate in the proposed settlement. By submitting this form, I understand that I will not be eligible to receive monetary recovery from the settlement fund. I also understand that any portion of the settlement fund to which I would have been entitled will not revert to Defendants, but will remain in the settlement fund to be distributed per the terms of the Settlement. Dated:, 20 (Signature) (Typed or Printed Name) (Address) (City, State, Zip Code) (Telephone Number, Including Area Code) YOU MUST COMPLETE, SIGN, DATE, AND MAIL THIS REQUEST FOR EXCLUSION BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED, OR EQUIVALENT, POSTAGE PAID, POSTMARKED ON OR BEFORE MAY 2, 2016, ADDRESSED AS FOLLOWS, IN ORDER FOR YOUR EXCLUSION TO BE VALID. MAIL TO: SETTLEMENT ADMINISTRATOR C/O ILYM GROUP, INC. P.O. BOX 130 TUSTIN, CA (888) ILYM ID: <<Insert ID>>

15 PROOF OF SERVICE I am attorney for the plaintiffs herein, over the age of eighteen y~ars, and not a party to the within action. My business address is Harris & Rubie, 655 North Central Avenue, Glendale, California On April26.;. 2016, I served the within documents: DECLARATION OF ELIZABETH D1TIRRO IN SUPPORT OF MOTION FOR FINAL APPROVAL OF CLASS-ACTION SETTLEMENT Hand Delivery: I caused such envelope to be delivered by hand in person to: NIA Facsimile: I caused such envelope to be delivered by or fax to: NIA. I am readily familiar with the Firm's practice of collection and processing correspondence for mailing. Under tliat practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course ofbusiness, addressed as follows: Sharon Bauman Manatt, Phelps & Phillips LLP 1 Embarcadero Ctr., Fl. 30 San Francisco, CA I declare under penalty of gerjury that the above is true and correct. Executed on April 26, 2016, at Los Angeles, California. ~~ Ala Harris