Frequently Asked Questions

Information About The Settlement

1. What is this Action about?

Plaintiff alleges that Defendant misclassified as exempt its part-time adjunct faculty who were paid on a per-course basis, and, as a result, failed to pay them separately from the course-rate for non-productive time, and failed to pay them all wages due upon discharge from employment. Plaintiff also alleges that Defendant required and/or expected employees to work remotely from home but failed to reimburse them for their home office expenses incurred in order to carry out their job duties for Biola. Defendant strongly denies each of these allegations and contends that Plaintiff’s claims have no merit.

2. What does it mean that the Action has settled?

Defendant and Plaintiff negotiated an end to the case by agreement (i.e., settled the case) rather than continuing the expensive and time-consuming process of litigation. The Court has made no determination whether Defendant or Plaintiff is correct on the merits. There has been no trial in this case. By agreeing to settle, Biola does not admit any violations or concedes the merit of any claims.

Plaintiff and Class Counsel believe that this Settlement is fair and reasonable and is in the best interests of all Class Members. Plaintiff and Class Counsel strongly believe the Settlement is a good deal for you because they believe that: (1) Biola has agreed to pay a fair, reasonable and adequate amount considering the strength of the claims and the risks and uncertainties of continued litigation; (2) the Settlement is in the best interests of the Adjunct Class Members, Reimbursement Class Members, and Full-time Faculty Reimbursement Class Members, and (3) Biola has revised its reimbursement policy for remote technology and mobile phone expenses to provide reimbursement for home internet and mobile phone expenses to qualifying employees. The Court granted preliminary approval of the proposed Settlement as fair, reasonable and adequate, authorized notice, and scheduled a hearing to determine Final Approval.

3. What Are the terms of the Settlement?

1. Gross Settlement Amount: The Parties have agreed to settle the Action for a “Gross Settlement Amount” of One Hundred Ninety Thousand Dollars ($190,000.00) on a non-reversionary basis. This means that the entire Gross Settlement Amount will be paid by Defendant and paid out to Adjunct Class Members, Reimbursement Class Members, and Full-time Faculty Reimbursement Class Members, subject to various Court-approved deductions.

2. Court Approved Deductions from Gross Settlement: At the Final Approval Hearing, Plaintiff and Class Counsel will ask the Court to approve the following deductions from the Gross Settlement, the amounts of which will be decided by the Court at the Final Approval Hearing:

1. attorneys’ fees not to exceed 1/3 ($63,333.33) of the Gross Settlement and actual, reasonably incurred costs of Class Counsel not exceeding $10,000.00;

2. payment to the Class Representative not to exceed $5,000.00 in the aggregate for filing the Action, working with Class Counsel and representing the Class; and

3. all costs of third-party administration estimated at approximately $15,000.00.

Participating Class Members have the right to object to the amounts of the deductions in items 2(a)-(b) above. The Court will consider the objections.

3. Net Settlement Distributed to Class Members. What remains after these payments are made is called the “Net Settlement Amount,” which is estimated to be in the amount of approximately $96,666.67 depending on the final Court-approved deductions as discussed above. Sixty Percent (60%) of the Net Settlement Amount shall be allocated pro rata to each Adjunct Class Member based on the number of pay periods worked during the Adjunct Class Period, and the remaining forty percent (40%) of the Net Settlement Amount shall be allocated pro rata to each Reimbursement Class Member and each Full-time Faculty Reimbursement Class Member based on the number of pay periods worked during the Reimbursement Class Period, according to the methodology described in the next section.

4. How much will I get from the settlement and how will it be taxed?

1. Individual Settlement Payments. The Administrator will calculate Individual Settlement Payments as follows: For Adjunct Class Members the Administrator will (a) divide sixty percent (60%) of the Net Settlement Amount by the total number of pay periods worked by all Participating Adjunct Class Members, and (b) multiply the result by the number of pay periods worked by each individual Participating Adjunct Class Member. For Reimbursement Class Members and Full-time Faculty Reimbursement Class Members the Administrator will (a) divide forty percent (40%) of the Net Settlement Amount by the total number of pay periods worked by all Participating Reimbursement Class Members and Full-time Faculty Reimbursement Class Members (with any pay period during which an individual received remote technology reimbursement weighted as 0.5), and (b) multiply the result by the number of pay periods worked by each individual Participating Reimbursement Class Member.

2. Pay Period Challenges. The number of pay periods you worked during the Adjunct Class Period, Reimbursement Class Period, and Full-time Faculty Reimbursement Class Period as recorded in Biola’s records, are stated on the first page of the Notice you may have received. You have until November 24, 2025, to challenge the number of pay periods credited to you. You can submit your challenge by signing and sending a letter to the Administrator via mail, email or fax as found in FAQ 10. You should support your challenge by sending copies of pay stubs or other records. The Administrator will accept Biola’s calculation of pay periods as accurate unless you send copies of records that demonstrate that Biola’s calculation is inaccurate. You should send copies rather than originals because the documents will not be returned to you. The Administrator will resolve pay period challenges based on your submission and on input from Class Counsel (who will advocate on behalf of Participating Class Members) and Biola’s Counsel. The Administrator’s decision is final. You can’t appeal or otherwise challenge its final decision.

3. Taxes Owed on Payments to Class Members. Plaintiff and Biola are asking the Court to approve an allocation of 1/3 of each settlement payment made to an Adjunct Class Member to taxable wages (“Wage Portion”) and two-third to interest and penalties (“Non-Wage Portion”). The Wage Portion is subject to withholdings and will be reported on IRS W-2 Forms. Biola will separately pay employer payroll taxes it owes on the Wage Portion. Settlement payments made to each Reimbursement Class Member and Full-time

Faculty Reimbursement Class Member will be allocated entirely as Non-Wages and will be reported on IRS 1099 Forms.

Although Plaintiff and Biola have agreed to these allocations, neither side is giving you any advice on whether your settlement payments are taxable or how much you might owe in taxes. You are responsible for paying all taxes (including penalties and interest on back taxes) on any payments received from the proposed Settlement. You should consult a tax advisor if you have any questions about the tax consequences of the proposed Settlement.

5. When will I get my payment?

The Administrator will send, by U.S. mail, a check to each Participating Class Member (i.e., every Class Member who doesn’t opt-out from the Settlement).

Your check will be sent to the same address as the Notice was sent. If you change your address, be sure to notify the Administrator as soon as possible. FAQ 10 has the Administrator’s contact information.

Need to Promptly Cash Payment Checks. The front of every check will show the date when the check expires (the void date is 180 days after the date the check is issued). If you don’t cash your check by the void date, your check will be automatically cancelled, and the monies will be irrevocably lost to you because they will be paid to the non-profit organization or foundation (“Cy Pres”) Samaritan’s Purse.

6. What claims am I releasing?

After the Judgment is final and Biola has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Biola or related entities for wages based on the facts alleged in this case during the applicable time periods, as alleged in the Action and resolved by this Settlement.

The Participating Class Members will be bound by the following releases:

Adjunct Released Claims: Each member of the Adjunct Class who has not timely opted-out of the settlement shall fully release the Released Parties from all known and unknown claims arising under Labor Code §§ 201-203, 226.2, 515.7, 1194, 1194.2, the applicable IWC Wage Order, and Business and Professions Code §§ 17200 et seq. claims, that were alleged, or that could have been alleged, based on the facts included in the Complaint, and arising during the Adjunct Class Period. Upon the date of funding of the Gross Settlement Amount, and except as to the right to enforce the terms and conditions the settlement, all Adjunct Class Members who have not submitted a valid Request for Exclusion Form will fully release the Released Parties from the Adjunct Released Claims.

Reimbursement Released Claims: Each member of the Reimbursement Class and the Full-time Faculty Reimbursement Class who has not timely opted-out of the settlement releases the Released Parties from all claims under Labor Code § 2802 and Business and Professions Code §§ 17200 et seq., that were alleged, or that could have been alleged, based on the facts included in the Complaint and arising during the Reimbursement Class Period and the Full-time Faculty Reimbursement Period. Upon the date of funding of the Gross Settlement Amount, and except as to the right to enforce the terms and conditions the settlement, all Reimbursement Class Members and Full-time Faculty Reimbursement Class Members who have not submitted a valid Request for Exclusion Form will fully release the Released Parties from the Reimbursement Released Claims.

7. How can I opt out of this Settlement?

Submit a written and signed letter with your name, present address, telephone number, and a simple statement that you do not want to participate in the Settlement. The Administrator will exclude you based on any writing communicating your request be excluded. Be sure to personally sign your request, identify the Action as Patton v. Biola University, Los Angeles Superior Court Case No. 24STCV19764, and include your identifying information (full name, address, telephone number, approximate dates of employment, and the last four digits of your social security number for verification purposes). You must make the request yourself. If someone else makes the request for you, it will not be valid. The Administrator must be sent your request to be excluded by November 24, 2025, or it will be invalid. FAQ 10 has the Administrator’s contact information.

8. How do I tell the Court that I do not agree with the Settlement?

Only Participating Class Members have the right to object to the Settlement. Before deciding whether to object, you may wish to see what Plaintiff and Biola are asking the Court to approve. At least 16 days before the Final Approval Hearing, Class Counsel and/or Plaintiff will file in Court (1) a Motion for Final Approval that includes, among other things, the reasons why the proposed Settlement is fair, and (2) a Motion for Fees, Litigation Expenses and Service Award stating (i) the amount Class Counsel is requesting for attorneys’ fees and litigation expenses; and (ii) the amount Plaintiff is requesting as a Class Representative Service Award. Upon reasonable request, Class Counsel (whose contact information is in FAQ 10) will send you copies of these documents at no cost to you. You can also view them here or the Court’s website www.lacourt.org.

A Participating Class Member who disagrees with any aspect of the Agreement, the Motion for Final Approval and/or Motion for Fees, Litigation Expenses and Service Award may wish to object, for example, that the proposed Settlement is unfair, or that the amounts requested by Class Counsel or Plaintiff are too high or too low. The deadline for sending written objections to the Administrator is November 24, 2025. Be sure to tell the Administrator what you object to, why you object, and any facts that support your objection. Make sure you identify the ActionPatton v. Biola University, Los Angeles Superior, Court Case No. 24STCV19764, and include your full name, current address, telephone number, and approximate dates of employment for Biola and sign the objection. FAQ 10 has the Administrator’s contact information.

Alternatively, a Participating Class Member can object (or personally retain a lawyer to object at your own cost) by attending the Final Approval Hearing. You (or your attorney) should be ready to tell the Court what you object to, why you object, and any facts that support your objection. See FAQ 9 for specifics regarding the Final Approval Hearing.

9. Can I attend the Final Approval Hearing?

You can, but don’t have to, attend the Final Approval Hearing on February 18, 2026, at 10:00 a.m. in Department 9 of the Los Angeles Superior Court, located at 312 North Spring Street, Los Angeles, CA 90012. At the Hearing, the judge will decide whether to grant Final Approval of the Settlement and how much of the Gross Settlement will be paid to Class Counsel, Plaintiff, and the Administrator. The Court will invite comment from objectors, Class Counsel and Defense Counsel before making a decision. You can attend (or hire a lawyer to attend) either personally or virtually via LACourtConnect (www.lacourt.org/lacc). Check the Court’s website for the most current information.

It’s possible the Court will reschedule the Final Approval Hearing. You should check this website beforehand or contact Class Counsel to verify the date and time of the Final Approval Hearing.

10. Are there more details about the Settlement?

The Agreement sets forth everything Biola and Plaintiff have promised to do under the proposed Settlement. The easiest way to read the Agreement, the Judgment or any other Settlement documents is to visit the Important Documents page. You can also telephone or send an email to Class Counsel or the Administrator using the contact information listed below or consult the Superior Court website by going to (www.lacourt.org/casesummary/ui/index.aspx) and entering the Case Number for the Action, Case No. 24STCV19764. You can also make an appointment to personally review court documents in the Clerk’s Office at the Stanley Mosk Courthouse by calling (213) 830-0800.

11. What if I lose my check?

If you lose or misplace your settlement check before cashing it, the Administrator will replace it as long as you request a replacement before the void date on the face of the original check. If your check is already void you will have no way to recover the money.