Notice of Class & Collective
Action Settlement

PLEASE READ THIS NOTICE CAREFULLY. You may be entitled to a cash payment from a class and collective action settlement if you worked as a restaurant Server at Mai Kai Restaurant and Polynesian Show in Fort Lauderdale, Florida, between November 15, 2024, and January 15, 2026.

On December 1, 2025, Plaintiff, Cannet, filed a putative class action against The Mad Room Hospitality, seeking damages under the Florida Minimum Wage Act ("FMWA"). Plaintiff also sought damages for alleged violations of the Fair Labor Standards Act ("FLSA"). The claims related to various wage violations allegedly committed at Mai Kai Restaurant and Polynesian Show ("Mai Kai") in Fort Lauderdale, Florida. The action was assigned case number 0:25-cv-62454 and assigned to Hon. Melissa Damian. The Parties have explored settlement and after a lengthy class mediation with experienced mediator Lori Adelson, agreed that a full and final class settlement, pursuant to Fed. R. Civ. P. 23, was in the best interests of the Parties.

The proposed Settlement is not an admission of wrongdoing by Defendant, and Defendant denies that it violated the law. The Court has not decided who is right or wrong. Rather, to avoid the time, expense, and uncertainty of litigation, the Parties have agreed to settle the lawsuit. The Settlement has been preliminarily approved by the Court.

The Settlement, if approved, provides monetary benefits to the Class and Collective. The Defendant has agreed to pay a maximum of $85,000.00, which will be distributed among Class and Collective Members based on the number of hours each member worked during the Class Period. Payments are estimated at approximately $2.27 per hour worked, but could be less after the deduction of attorneys' fees, costs, the Class Representative service award, and administration expenses approved by the Court.

To receive a Settlement Payment, you must submit a timely and valid Claim Form. By submitting a Claim Form, you also consent to opt in to the FLSA collective action component of this Settlement. If you do not submit a Claim Form, you will not receive a Settlement Payment, but you will still be bound by the terms of the Settlement unless you submit a valid request for exclusion.

If you worked as a restaurant Server at Mai Kai during the Class Period, you have the following options:

1. 1 Submit Your Claim. Submit a timely Claim Form to receive your Settlement Payment and opt in to the FLSA collective action. Your Claim Form must be submitted online or postmarked no later than August 7, 2026.
   
   You may submit your Claim Form by mail or online here or via the navigation menu above.
2. 2 Exclude Yourself (Opt Out). You can elect to get out of the Class and keep your right to sue Mai Kai Restaurant and Polynesian Show on your own regarding the claims in the lawsuit. To exclude yourself, you must submit a written, signed request for exclusion, postmarked no later than August 7, 2026.
3. 3 File an Objection. If you do not exclude yourself, you can remain a Class Member and write to the Court about why you disagree with the Settlement. Objections must be postmarked no later than August 7, 2026.
4. 4 Appear at the Hearing. You may appear at the Final Approval Hearing on September 16, 2026, at 11:00 A.M. at the United States Federal Courthouse in Fort Lauderdale, Florida. A Notice of Appearance must be postmarked on or before August 7, 2026.
5. 5 Do Nothing. You will be bound by the terms of the Settlement and give up your right to sue Mai Kai Restaurant and Polynesian Show on these claims, but you will receive no money.

For more information, visit the Important Documents tab for Court Documents or the Contact Us tab above to obtain information for the Settlement Administrator or Counsel for this matter. You may also review the operative complaint and other case filings at www.pacer.gov.