UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA

If you worked as an H-2A worker with Las Princesas Corporation in 2021, 2022, 2023, or 2024, you may be eligible for a payment.

A federal court authorized this notice. This is not a solicitation from a lawyer.

• The parties have reached proposed settlements with  Las Princesas Corporation, Martha Zeferino José, and The Tankard Nurseries (the “Defendants”)  to resolve claims of whether the Las Princesas H-2A workers who worked at Tankard between July 1, 2021, and June 30, 2022, were employees entitled to overtime; whether H-2A workers who worked for Las Princesas Corporation and/or Martha Zeferino José  between May 29, 2021 and September 9, 2024 are entitled to be reimbursed for the cost of their H-2A visas, transportation from Mexico to the United States, and related expenses; and whether the Las Princesas Corporation and/or Martha Zeferino José (the “Las Princesas Defendants”) violated anti-trafficking laws by holding the passports and identification documents of the employees, failed to pay workers the required wage rate, and failed to comply with the work contract.  The settlements will also resolve individual claims brought by the Class Representatives.
• Under the proposed settlements, class members will receive a payment to partly compensate them for their H-2A visas, transportation from Mexico, and related expenses, which will be a pro rata amount based on the number of seasons worked, which Defendant(s) they worked for, and whether the opted into this action. Employees will also receive $100 in compensation related to the confiscation of their documents.  Workers who worked at Tankard will be eligible to receive settlement payments to partly compensate them for their payment for allegedly inadequate meals, and to receive settlement payments in amounts that will vary based on whether the class member worked overtime hours for Tankard between July 1, 2021, and June 30, 2022, according to the available records.  There will also be payments to the Class Representatives for their service to the class in the amount of $2,500 each and for their individual trafficking claims in the amount of $1,000 each.  In addition, Tankard has agreed not to use a labor contractor to provide workers for the next three years, and the Las Princesas Defendants have agreed not to employ H-2 workers or domestic workers in agriculture for the next three years.  More details about the settlement are provided in this document and are available by contacting Class Counsel or visiting www.DemandaLasPrincesas.com.
• Your legal rights are affected whether you act or don’t act. Read this notice carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:

SUBMIT A CHANGE OF ADDRESS FORM

This will ensure you receive your payment, if you are entitled to one.

EXCLUDE YOURSELF

Get no payment. This is the only option that allows you to ever be part of any other lawsuit against The Tankard Nurseries Inc., Las Princesas Corporation, and/or Martha Zeferino José about the legal claims in this case.

OBJECT

Tell the Court why you don’t like the settlement.

• These rights and options—and the deadlines to exercise them—are explained in this notice.
• The Court in charge of this case still has to decide whether to approve the settlement. Payments will be made if the Court approves the settlement and, if there are any appeals, if the appeals are resolved in favor of the settlement. Please be patient.

Contáctenos para información en español:
Las Princesas Settlement
c/o Optime Administration, LLC
PO Box 3206
Brockton, MA 02304
Phone: 844-625-7313
Fax: 781-287-0381
Email: LASPRINCESAS@OPTIMEADMIN.COM

BASIC INFORMATION

1. Why did I get this notice package?

You received this notice because your name is included in payroll and/or timekeeping records maintained by The Tankard Nurseries and/or Las Princesas Corporation showing that you worked for Las Princesas Corporation as an H-2A worker between May 29, 2021 and September 9, 2024 or because you previously joined this case by submitting a form called Consent to Sue.

The Court authorized the Plaintiffs’ lawyers to send you this notice because you have a right to know about a proposed settlement of a class action lawsuit, and about all of your options, before the Court decides whether to approve the settlement. If the Court approves it, and after any objections or appeals are resolved, a settlement administrator appointed by the Court will make the payments that the settlement allows.

This package explains the lawsuit, the settlement, your legal rights, what benefits are available, who is eligible for them, and how to get them.

The Court in charge of the case is the United States District Court for the Eastern District of Virginia, and the case is known as Hernández Lara, et al. v. Las Princesas Corporation, et al., Case No. 2:24-cv-000346. The people who sued are called Plaintiffs. They are José Alberto Hernández Lara, Ismael Lorenzo Perez, Leonel Santiago Gómez, and Uriel Hernandez Espinoza.  The company and the people they sued, Las Princesas Corporation, Martha Zeferino José, and The Tankard Nurseries Inc., are called the Defendants.

2. What is this lawsuit about?

The lawsuit alleged that the Defendants failed to reimburse the workers for their visa, transportation, and other expenses related to their travel from Mexico to the United States; that workers paid for an unlawful mealplan, that Defendants did not pay overtime wages for work performed in Virginia between July 1, 2021 and June 30, 2022, that Las Princesa Corporation and Martha Zeferino José confiscated workers’ passports and engaged in other acts constituting human trafficking, and that they breached the terms of the H-2A contracts. The Defendants deny they did anything wrong, and Defendant Tankard denies it was the employer of the workers.

3. Why is this a class action?

In this class action, one or more people called Class Representatives (in this case José Alberto Hernández Lara, Ismael Lorenzo Perez, Leonel Santiago Gómez, and Uriel Hernandez Espinoza), sued on behalf of people who have similar claims. All these people are Class Members. One court resolves the issues for all Class Members, except for those who exclude themselves from the Class. U.S. District Judge Jamar Walker is the federal judge presiding over this class action.

4. Why is there a settlement?

The Court did not decide in favor of Plaintiffs or Defendants. The Plaintiffs think they could have won all or most of their claims and recovered back wages and liquidated damages and other damages for the class members if they won at trial.  Defendants think the Plaintiffs would not have won anything from a trial because Tankard was not legally the employer of the Class Members and the Defendants believe they complied with the law. But there was no trial. Instead, Defendants and the Plaintiffs agreed to two settlements (which will be discussed below as “the settlement”). That way, they avoid the cost and risks of a trial, and the members of the proposed class will get compensation. The Class Representatives and the attorneys for both sides think the settlement is fair for all Class Members and for the Defendants.

WHO IS IN THE SETTLEMENT

5. How do I know if I am part of the settlement?

A list of everyone included in the Settlement Classes is attached at the end of this Notice. 

Judge Walker decided that everyone who fits any of these descriptions is a member of the Settlement Classes:

Las Princesas Settlement Class: All individuals who were brought to the U.S. by Las Princesas to perform agricultural work under H-2A contracts between May 29, 2021 and September 9, 2024.
Tankard Settlement Class:  All individuals who were brought to the U.S. as H-2A workers by the Las Princesas Corporation and/or Martha Zeferino José and who performed work for The Tankard Nurseries Inc. between May 29, 2021 and the present.
Tankard Subclass: All individuals who were brought to the U.S. as H-2A workers by the Las Princesas Corporation and/or Martha Zeferino José and who performed overtime work for The Tankard Nurseries Inc. between July 1, 2021 and June 30, 2022.

The people who previously filed a Consent to Sue (the “Opt-Ins”) are also included even if they don’t fit in the Settlement Class definition.

If you are still not sure whether you are included, you can ask for free help. You can call Optime Administration at 844-625-7313, or contact us through www.DemandaLasPrincesas.com or email LasPrincesas@optimeadmin.com for more information.

THE SETTLEMENT BENEFITS—WHAT YOU GET

6. What does the settlement provide?

Tankard and the Las Princesas Defendants have agreed to each pay $150,000 (for a total of $300,000) into a settlement fund to 1) be divided among the Class Members and Opt-ins, 2) provide service awards for the Class Representatives, 3) pay the Class Representatives for their individual claims, and 4) pay Class Counsels’ fees and costs.  

7. How much will my payment be?

Your share of the fund will depend on the dates you worked, your rate of pay, whether you worked for Tankard, and whether you are an Opt-in (meaning you submitted a Consent to Sue). 

Taxes will be withheld from the portion of your payment that is considered wage damages. 

If  after one year there is still money remaining in the Settlement Fund because some Class Members could not be located, the remaining money will be distributed to the Class Members and Opt-ins who received the first round payment.  Each person getting a second distribution will get the same percentage of the total amount Class Counsel believes they are owed based on the available records.  

To find out exactly how much your payment will be before taxes, contact Class Counsel at LASPRINCESAS@OPTIMEADMIN.COM, or through www.DemandaLasPrincesas.com.

HOW YOU GET A PAYMENT

8. How can I get a payment?

To receive your payment, you need to provide your current address.  A Change of Address form is attached to this Notice. You may also request a Change of Address form at www.DemandaLasPrincesas.com or by calling or sending a WhatsApp message to 434-242-1494. You can also contact the Settlement Administrator at LASPRINCESAS@OPTIMEADMIN.COM.

You can also make sure your coworkers get their payment by sharing this Notice with people you know whose name appears on the list of Settlement Class Members and encouraging them to contact Class Counsel.

9. When would I get my payment?

The Court will hold a hearing on December 4, 2025, to decide whether to approve the settlement. If Judge Walker approves the settlement and that decision is not overturned on appeal, the settlement administrator will begin sending people their payments as soon as possible after the approval. In order to make sure you receive your payment, contact Class Counsel with your current address.

10. What am I giving up to get a payment or stay in the Class?

Unless you exclude yourself, you are staying in the Class, and that means that you can’t sue, continue to sue, or be part of any other lawsuit against The Tankard Nurseries Inc., Las Princesas Corp., and/or Martha Zeferino José about the legal issues in this case or in any way related to the claims in this case. It also means that all of the Court’s orders will apply to you and legally bind you. If you do not exclude yourself, you will agree to a “Release of Claims,” described below, which describes exactly the legal claims that you give up if you stay in the Class.

EXCLUDING YOURSELF FROM THE SETTLEMENT

If you don’t want a payment from this settlement, but you want to keep the right to sue or continue to sue any of the Defendants about these same legal issues on your own, then you must take steps to get out of this case. This is called excluding yourself or opting out of the settlement Class.

11. How do I get out of the settlement?

To exclude yourself from the settlement, you must send a letter saying that you want to be excluded from Hernández Lara, et al. v. Las Princesas Corporation, et al. Be sure to include your name, address, telephone number, and your signature. You must mail, e-mail or fax your exclusion request postmarked no later than November 18, 2025 to:

Las Princesas Settlement
c/o Optime Administration, LLC
PO Box 3206
Brockton, MA 02304
Phone: 844-625-7313
Fax: 781-287-0381
Email: LasPrincesas@optimeadmin.com

If you ask to be excluded, you will not get any settlement payment, and you cannot object to the settlement. You will not be legally bound by anything that happens in this lawsuit.

12. If I stay in the Class, how does that impact my legal rights?

Unless you exclude yourself, you give up any right to separately sue any of the Defendants for the claims that this settlement resolves.  This is called a “Release of Claims.” If you have a pending lawsuit speak to your lawyer in that case immediately. You must exclude yourself from this Class to continue your own lawsuit. Remember, the exclusion deadline is November 18, 2025.

13. If I exclude myself, can I get money from this settlement?

No. If you ask to be excluded, you will not get any settlement payment. You may be able to sue (or continue to sue) any of the Defendants in the future.  However, lawsuits are subject to being dismissed if claims are not filed within applicable time limits.  If you exclude yourself from this action, those time limits will start running again.

THE LAWYERS REPRESENTING YOU

14. Do I have a lawyer in this case?

The Court decided that Patricia Kakalec of Kakalec Law PLLC, Clermont Ripley and Carol Brooke of the North Carolina Justice Center, and Rachel McFarland, Marissa Baer, and Jason Yarashes of Legal Aid Justice Center are qualified to represent you and all Settlement Class Members.  These lawyers are called “Class Counsel” and you may contact them if you have questions about your rights in this case or about the lawsuit.  All of your counsel speak Spanish.  You can contact them at 434-242-1494 (phone or WhatsApp). You and the Settlement Class Members will not be charged for these lawyers. If you want to be represented by your own lawyer, you may hire one at your own expense.

15. How will the lawyers be paid?

Class counsel will ask the Court to approve payment of attorneys’ fees and their out-of-pocket expenses.  The fees would pay Class Counsel for investigating the facts, litigating the case, and negotiating the settlement. The Court may award less than these amounts.

OBJECTING TO THE SETTLEMENT

16. How do I tell the Court that I don’t like the settlement?

If you’re a Class Member, you can object to the settlement if you don’t like any part of it. You can give reasons why you think the Court should not approve it. The Court will consider your views.

You can ask the Court to deny approval by making an objection, but you can’t ask the Court to order a different settlement.  The Court can only approve or reject the proposed settlement. If the court denies approval, no settlement payments will be sent out and the lawsuit will continue.

To object, you must send a letter saying that you object to Hernández Lara, et al. v. Las Princesas Corporation, et al. Be sure to include your name, address, telephone number, your signature, and the reasons you object to the settlement. Mail or fax the objection to the address below postmarked no later than November 18, 2025:

Las Princesas Settlement
c/o Optime Administration, LLC
PO Box 3206
Brockton, MA 02304
Phone: 844-625-7313
Fax: 781-287-0381
Email: LasPrincesas@optimeadmin.com

You may also object by attending the Court’s fairness hearing described below.

17. What’s the difference between objecting and excluding?

Objecting is simply telling the Court that you don’t like something about the settlement. You can object only if you stay in the Class. Excluding yourself is telling the Court that you don’t want to be part of the Class. If you exclude yourself, you have no basis to object because the case no longer affects you.

THE COURT’S FAIRNESS HEARING

18. When and where will the Court decide whether to approve the settlement?

The Court will hold a Fairness Hearing at 2:30 pm  on December 4, 2025, at the United States District Court for the Eastern District of Virginia, Norfolk Division, 600 Granby St., Norfolk, VA  23510.  At this hearing the Court will consider whether the settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them. Judge Walker will listen to people who attend the hearing in order to object. After the hearing, the Court will decide whether to approve the settlement. We do not know how long these decisions will take.

19. Do I have to come to the hearing?

No. Class Counsel will represent the Class at the hearing and answer any questions Judge Walker 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 your own lawyer to attend, but it’s not necessary.

20. What happens if I do nothing at all?

If you do nothing, you will be included in the Settlement Class and you will agree to the Release of Claims, meaning you won’t be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendants about the legal issues in this case, ever again.  You will be eligible for a payment if the settlement is approved.

GETTING MORE INFORMATION

21. Are there more details about the settlement?

This notice summarizes the proposed settlement. You can get also get a copy of the Settlement Agreement or more information by contacting Class Counsel by calling 434-242-1494 (tel. or WhatsApp).

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The Honorable Jamar K. Walker
United States District Judge

DATE OF THIS NOTICE: September 19, 2025