Long v. The UPS Store, Inc., et al.

Case No. 15-CI-000695

Jefferson Circuit Court, Division Ten

IF YOU PURCHASED NOTARY SERVICES FROM A THE UPS STORE® LOCATION IN KENTUCKY BETWEEN FEBRUARY 12, 2010 AND JULY 15, 2016, YOU MAY BE ELIGIBLE TO PARTICIPATE IN A CLASS ACTION SETTLEMENT AND RECEIVE A VOUCHER OF $10-$20 TO BE USED AT A UPS STORE IN KENTUCKY, WITH SOME LIMITED EXCEPTIONS.

Important Dates and Deadlines
Deadline to file a claim May 11, 2021
Deadline to opt-out May 11, 2021
Deadline to object May 11, 2021

WHAT IS THIS SETTLEMENT ABOUT?

Thirty-six (36) entities that operate The UPS Store® Franchises (the “Franchisees”) in the State of Kentucky, as well as The UPS Store, Inc. have agreed to fully settle and release claims of all who purchased notary services at the Franchisees between February 12, 2010, and July 15, 2016. The Franchisees have agreed to pay $250,000,to fund vouchers for eligible Class Members as described below (the “Class Vouchers”), and to pay an attorneys’ fee award to be determined by the Court, an incentive award to the Class Representative to be determined by the Court, and settlement costs. The UPS Store, Inc. has agreed to facilitate the administration of Class Vouchers for processing at the Franchisees’ store locations.

Each Class Voucher is redeemable for a total amount of $10.00 and for a one-time use, meaning that if it is redeemed for less than $10.00, the remaining amount of the $10.00 will not be available for future use or credit. Each eligible Class Member may claim up to two Class Vouchers, for a total value of $20.00. Class Vouchers are not redeemable for cash and will not be replaced if lost, stolen, or damaged, and copies will not be accepted. Each Class Voucher may be redeemed for any service or product offered at the Franchisees, except that (i) a Class Voucher may not be used for the purchase of United States Postal Service products or services, including but not limited to postage stamps and metered mail, and (ii) no more than $5.00 of each Class Voucher may be applied towards shipping or freight costs. Class Vouchers may not be aggregated or combined with any other promotional offers. Each Class Voucher, to be valid at the time of sale and application, must bear the name of the Class Member who applied for the Class Voucher on the Website.

To receive a Class Voucher, a Class Member must, (1) provide the Class Member’s name, address, e-mail address, and telephone number; (2) certify under penalty of perjury that he or she paid more than $0.50 for notary services at a The UPS Store operated by one of the Franchisee Defendants, JZJ, Inc. or Forty One Adventures, Inc. during the Class Period, and (3) state whether he or she paid more than $0.50 for notary services at a The UPS Store operated by one of the Franchisee Defendants, JZJ, Inc. or Forty One Adventures, Inc. during the Class Period on one, or more than one occasion. If a Class Member certifies he or she was charged more than $0.50 for notary services on more than one occasion during the Class Period, that Class Member may claim a maximum of two Class Vouchers. To participate in the proposed settlement, the Class Member must have purchased notary services at one of the qualifying The UPS Store locations. For a full list of qualifying locations, click here.

This Settlement resolves a lawsuit alleging that the Franchisees charged more for notary services than is permitted under Kentucky law and that The UPS Store, Inc. can be held liable for the Franchisees’ alleged actions. The Franchisees deny that they overcharged customers, and The UPS Store, Inc. denies that it can be held responsible for the actions of the Franchisees. By entering into the Settlement, the Franchisees and The UPS Store, Inc. have not conceded the truth or validity of any of the claims against them.

Your legal rights are affected whether you act, or do not act. Read the Notice carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT:

SUBMIT A CLAIM FORM

If you submit a valid Claim Form by May 11, 2021, you will receive a voucher(s) and will give up certain rights to sue.

Click here to submit a Claim Form online.

Click here to download a Claim Form.

Deadline:
May 11, 2021.

EXCLUDE YOURSELF

This is the only option that allows you to sue on your own regarding the legal claims in this case, but you will not receive a settlement benefit under the Settlement. The deadline for excluding yourself is May 11, 2021.

Deadline:
May 11, 2021.

OBJECT

Inform the Court about why you do not like the Settlement. The deadline for objecting is May 11, 2021.

Deadline:
May 11, 2021.

DO NOTHING

If you do nothing, you will receive no money from the Settlement, but you will still give up certain rights to sue.


HOW TO FILE A CLAIM

To be eligible to receive a Class Voucher, you must complete and submit a valid Claim Form. You may submit your Claim Form online or download a Claim Form. To be valid, a Claim Form must be completed fully and accurately, signed under penalty of perjury, and timely submitted.

If you file a Claim Form online, then you must do so by 11:59 p.m. PDT on May 11, 2021.
If you submit your Claim Form by mail, it must be postmarked by May 11, 2021 and mailed to:

The UPS Store Notary Settlement
c/o Claims Administrator
1650 Arch Street, Suite 2210
Philadelphia, PA 19103

Only one Claim Form may be submitted per Class Member.


HOW TO OPT-OUT

If you do not want benefits from the Settlement, and you want to keep the right to sue or continue to sue Defendants on your own about the legal issues in this case, then you must take steps to get out of the Settlement. This is called excluding yourself—or it is sometimes referred to as “opting out” of the Settlement Class.

You may submit your opt out request online. You must complete the online Claim Form and then check the box indicating that you wish to opt out of the settlement. The deadline to submit your opt out request online is 11:59 p.m. PDT on May 11, 2021.

You may also submit your opt out request by mail by completing the Claim Form and checking the box indicating that you wish to opt out of the settlement. Your opt out request must be mailed to the address below, so it is postmarked no later than May 11, 2021.

The UPS Store Notary Settlement
Attn: Exclusion Requests
P.O. Box 58220
Philadelphia, PA 19102

If you opt out of the Settlement and choose to retract your decision, you must contact the Claims Administrator via email at info@TheUPSStoreNotarySettlement.com by May 11, 2021.


HOW TO OBJECT

If you are a Class Member (and do not exclude yourself from the Settlement Class), you can object to any part of the Settlement. To object, you must submit your written objection to the Claims Administrator by mail to the address below, so it is received no later than May 11, 2021.

The UPS Store Notary Settlement
Attn: Objections
P.O. Box 58220
Philadelphia, PA 19102

The written statement of your objection(s) must include (i) a detailed statement of the Class Member’s objection(s), as well as the specific reasons, if any, for each objection, including any evidence and legal authority the Class Member wishes to bring to the Court’s attention and any evidence the Class Member wishes to introduce in support of his/her objection(s); (ii) the Class Member’s full name, address and telephone number; (iii) information demonstrating that the Class Member is entitled to be included as a member of the Class; and (iv) the objection must be personally signed.