NOTICE OF CLASS ACTION SETTLEMENT

This Notice may affect your rights.  Please read it carefully.

Jackson et al. v. Ampac Paper, LLC,

U.S. District Court, Southern District of New York Case no. 22-CV-3120

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

You are receiving this Notice because you are eligible to receive a settlement payment from a lawsuit pending in the Southern District of New York, titled Jackson et al. v. Ampac Paper, LLC, No. 22-CV-3120 (the “Lawsuit”). This Notice explains your rights to participate in or exclude yourself from the settlement.

The Lawsuit was brought by Noemy Jackson, Roberto Perez and Raymundo Gallardo (“Plaintiffs”). Plaintiffs sued Ampac Paper, LLC (“Defendant”) on behalf of themselves and certain others who were employed by Defendant and worked at Defendant’s facility in Walden, New York during the applicable time period. Plaintiffs alleged that Defendant did not pay them and other employees for all their work hours. Defendant denies any wrongdoing. The Court has not decided who is right and who is wrong.

Plaintiffs and Defendant have agreed to settle the Lawsuit, subject to Court approval. Defendant has agreed to a total settlement fund of $1,200,000.00 to resolve all wage claims, including attorneys’ fees and costs.

The settlement covers individuals who were employed by Defendant in non-supervisory positions and worked in the converting department at Defendant’s Walden, New York facility at any time from April 15, 2016 through July 31, 2024 (“New York Class Members”).

Your legal rights may be affected by this settlement, and you have a choice to make now. Your options are explained in this Notice.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:

RECEIVE PAYMENT

To receive a payment, you must fill out and return the enclosed Claim Form and send it by mail, email, or fax to the Settlement Administrator no later than October 24, 2025.

The Settlement Administrator’s contact information is:
ProAmpac Settlement
c/o Optime Administration, LLC
PO Box 3206, Brockton, MA 02304
Phone: 844-625-7313
Email: PROAMPAC@OPTIMEADMIN.COM
Fax: 781-287-0381

EXCLUDE YOURSELF

If you wish to exclude yourself from the settlement, you must submit a written request for exclusion. The exclusion request must be sent by October 9, 2025 by regular mail, e-mail or fax to the Settlement Administrator at the above address.

Class Members who submit a valid and timely request for exclusion will not be entitled to receive a payment or object to the settlement but will retain the right to bring any claims they may have against Defendants. Any Class Member who does not exclude himself or herself from the settlement will upon final approval of the settlement be bound by the release of claims against Defendants and lose

the right to sue Defendants for any of the claims asserted against Defendants in this lawsuit.

OBJECT

As long as you do not exclude yourself from the settlement, you have the right to object to the settlement. The objection must be in writing and must be sent by October 9, 2025, by regular mail, fax, or email to the Settlement Administrator at the following address:

The Settlement Administrator’s contact information is:
ProAmpac Settlement
c/o Optime Administration, LLC
PO Box 3206, Brockton, MA 02304
Phone: 844-625-7313
Email: PROAMPAC@OPTIMEADMIN.COM
Fax: 781-287-0381

The Court will rule on your objection at the Final Class Settlement Approval Hearing discussed below.

These rights and options – and the deadlines to exercise them – are explained in this Notice.

BASIC INFORMATION

1. WHY DID I RECEIVE THIS NOTICE?

You have received this notice because you were employed by Defendant and worked in Defendant’s Walden, New York facility in the converting department in a non-supervisory position at any time from April 15, 2016 and July 31, 2024 (the “Class Period”), and Defendant has agreed to settle your claims.

On August 13, 2025, the United States District Court, Southern District of New York (the “Court”) preliminarily approved a settlement of the Lawsuit. According to Defendant’s records, you are a Class Member.

2. WHAT IS A CLASS ACTION?

A class action is a lawsuit where one or more people bring claims on behalf of themselves and other people who have similar claims. These other people are known as “Class Members.” In a class action, one court resolves the issues for all Class Members.

3. WHY IS THERE A SETTLEMENT?

Class Counsel, identified in paragraph 11 below, have litigated this case for over three years. Plaintiffs filed this case in the United States District Court for the Southern District of New York on April 15, 2022. The parties engaged in discovery by exchanging and analyzing documents and data and taking testimony of witnesses including the Plaintiffs and other former employees of the Defendant and representatives of the Defendant corporation. The parties twice engaged in mediation. After protracted negotiations, the parties agreed to settle the Lawsuit.

Plaintiffs and Class Counsel are satisfied that the terms and conditions of the settlement are fair, reasonable, and adequate and are in the best interest of the Plaintiffs, the Plaintiffs who opted into this case to bring Fair Labor Standards Act claims (“Opt-In Plaintiffs), and the New York Class Members.

This Notice only summarizes the Lawsuit, the settlement, and other related matters. For more information, and to receive a copy of the Settlement Agreement, you may contact the Settlement Administrator at the address, toll-free number, and e-mail address listed throughout this Notice.

4. HOW WILL MY SHARE OF THE SETTLEMENT BE CALCULATED?

Under the Settlement preliminarily approved by the Court, Class Members will receive a payment representing a proportionate share of the total settlement fund allocated based on the number of minutes during which they were “punched in” to Defendant’s timekeeping system but not paid during the Class Period according to data provided to Plaintiffs’ Counsel by Defendant.

Class Counsel will ask the Court to approve a payment of not more than $393,333 for their attorneys’ fees, approximately $20,000 as reimbursement for costs, and approximately

$25,000 for distribution expenses from the total settlement fund. The fees would pay Class Counsel for their years of work litigating the case and negotiating and overseeing the settlement; the reimbursement of costs will cover costs associated with the Litigation; and the distribution expenses will cover the administration of the settlement.

In addition, the Named Plaintiff and Opt-In Plaintiffs who participated in discovery (“Service Award Recipients”) will apply to the Court for service awards of a total aggregate not to exceed $51,000 from the total settlement fund for their services in identifying and prosecuting the claims in this case, participating in discovery, and assisting in the settlement process.

After deduction of attorneys’ fees and costs and service awards, a Net Settlement Fund of approximately $710,667 will be allocated to Class Members, in amounts depending on the number of minutes during which they were “punched in” to Defendant’s timekeeping system but not paid during the Class Period according to data provided to Plaintiff’s Counsel by Defendant. Anyone whose payment amount is calculated to be less than $50.00 will receive a minimum payment of $50.00 plus any additional pro rata distribution to which they are entitled based upon Class Counsel’s calculations.

All settlement payments will be subject to taxes. Class Counsel and Defendant’s Counsel do not make any representations concerning the tax consequences of this settlement or your participation in it, and you are advised to seek your own personal tax advice.

5. HOW DO I PARTICIPATE IN THE SETTLEMENT?

In order to receive an Individual Settlement Award if the Settlement is finally approved by the Court:

You must fill out and send the Claim Form attached to this notice to the Settlement Administrator no later than October 24, 2025.

You can send the claim form by mail, fax, or email. If you choose to submit a claim form, it is extremely important that you keep the Settlement Administrator informed of any changes in your address so the Settlement Administrator can mail your check to you. Fill out and send in the enclosed Change of Information form if this notice was not mailed to your current address. The Settlement Administrator’s contact information is:

ProAmpac Settlement
c/o Optime Administration, LLC
PO Box 3206, Brockton, MA 02304
Phone: 844-625-7313
Email: PROAMPAC@OPTIMEADMIN.COM
Fax: 781-287-0381

6. WHEN WILL I GET MY PAYMENT?

The date you receive your settlement check will depend on the date that the Court gives a final approval of the settlement. We estimate that payments will be made approximately 60 days after the Court finally approves the settlement, if there are no appeals. You must deposit or cash your settlement check within 120 days after it is mailed to you. Checks not cashed within 120 days will become void.

7. WHAT AM I GIVING UP BY PARTICIPATING IN THE SETTLEMENT?

If you do not exclude yourself from the case, you will release the claims alleged in the Lawsuit even if you do not cash your check. That means you cannot sue, continue to sue, or be a party to any other lawsuit against Defendant for the wage and hour claims that were brought, or that could have been brought, in this Lawsuit from the beginning of time through entry of the Court’s Approval Order.

8. WHAT HAPPENS IF I DO NOT WANT TO PARTICIPATE IN THE SETTLEMENT?

If you do not want to participate in the settlement and receive a share of the settlement fund, then you may exclude yourself by opting out of the settlement class. You should be aware that the statute of limitations on these claims may affect your ability to bring them on your own should you not participate in the settlement.

If you want to keep the right to sue Defendant for the claims in this case, you must take steps to exclude yourself from the settlement. To do so, you must mail a written, signed statement to the Settlement Administrator stating: “I opt out of the Jackson v. Ampac Paper, LLC case.” You must include your name, address, and telephone number. To be effective, the opt-out statement must be mailed to the Settlement Administrator via First Class United States Mail, postage prepaid, and postmarked by October 9, 2025.

ProAmpac Settlement
c/o Optime Administration, LLC
PO Box 3206, Brockton, MA 02304
Phone: 844-625-7313
Email: PROAMPAC@OPTIMEADMIN.COM
Fax: 781-287-0381

If you exclude yourself as described above, you will NOT be allowed to object to the settlement as described in paragraph 12 below.

9. IF I DON’T EXCLUDE MYSELF AND I CASH MY SETTLEMENT CHECK, CAN I SUE DEFENDANT FOR THE SAME THING LATER?

No. If you do not exclude yourself from the settlement, you give up any rights to sue Defendant under any federal, state or local law for the wage and hour claims that were asserted or could have been asserted in the Lawsuit.

10. IF I DON’T EXCLUDE MYSELF AND I DO NOT SUBMIT A CLAIM FORM OR CASH MY SETTLEMENT CHECK, CAN I SUE DEFENDANT FOR THE SAME THING LATER?

No. If you do not exclude yourself from the settlement, you give up any rights to sue Defendant under any state or local law for the wage and hour claims that were asserted or could have been asserted in the Lawsuit, even if you do not submit a claim form or cash your settlement.

11. IF I EXCLUDE MYSELF, CAN I GET MONEY FROM THIS SETTLEMENT?

No. If you exclude yourself, you will not receive any money from this settlement.

12. HOW DO I TELL THE COURT THAT I DO NOT LIKE THE SETTLEMENT?

You can object to the settlement if you do not like any part of it. You can give reasons why you think the Court should not approve it. The Court will consider your views. If the Court rejects your objection, you will still be bound by the terms of the settlement of your claims.

To object, you must send a letter to the Settlement Administrator stating that you object to the settlement. Your statement must include the reasons why you object and any supporting documentation, and whether it applies only to the individual objector, to a specific subset of the class, or the entire class, as well as your name, address, email, and telephone number. If you wish to present your objection at the fairness hearing described below, you must state your intention to do so in your written objection. Mail the objection to the Settlement Administrator via First-Class United States Mail at the address below. Your objection may not be heard unless it is mailed to the Settlement Administrator via First Class United State Mail and postmarked by October 9, 2025.

ProAmpac Settlement
c/o Optime Administration, LLC
PO Box 3206, Brockton, MA 02304
Phone: 844-625-7313
Email: PROAMPAC@OPTIMEADMIN.COM
Fax: 781-287-0381

Your objection statement will be filed with the Court. If you want to be represented by your own lawyer regarding your objection, you must hire one at your own expense.

13. WHAT’S THE DIFFERENCE BETWEEN OBJECTING TO THE SETTLEMENT AND EXCLUDING MYSELF?

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

14. DO I HAVE A LAWYER IN THIS CASE?

The Court decided that the lawyers at the law firms of Kakalec Law PLLC and the Law Office of Robert D. McCreanor, P.L.L.C., are qualified to represent you and all the members of the New York Class. These lawyers have been designated as “Class Counsel” in this lawsuit. The lawyers’ contact information is:

15. HOW WILL THE LAWYERS BE PAID?

Class Counsel will ask the Court to approve a payment of approximately $393,333 as their attorneys’ fees and approximately $20,000 for their costs from the total settlement amount. The fees would pay Class Counsel for their years of work litigating the case and negotiating and overseeing the settlement and the reimbursement of costs will cover costs associated with the Litigation and the administration of the settlement.

16. WHEN AND WHERE WILL THE COURT DECIDE WHETHER TO APPROVE THE SETTLEMENT?

The Court will hold a Fairness Hearing to decide whether to approve the settlement on November 14, 2025 at 10:00 a.m. before the Honorable Judith C. McCarthy in Courtroom 421 at 300 Quarropas Street, White Plains, New York, 10601 at the United States District Court for the Southern District of New York.

At the hearing, the Court will consider whether the settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them. If you wish to bring anything to the Court’s attention about the settlement, you should provide it in writing to the Settlement Administrator according to paragraph 10 above. The Settlement Administrator will provide your letter to the Court before the fairness hearing. You may also attend the hearing and ask to speak at the hearing, but you don’t have to. The Court will listen to people who have asked to speak at the hearing. The Court may also decide how much to pay Class Counsel. After the hearing, the Court will decide whether to approve the settlement. We do not know how long these decisions will take.

17. HOW CAN I GET MORE INFORMATION ABOUT THE SETTLEMENT?

This Notice summarizes the settlement. More details are in the Settlement Agreement. You are encouraged to read it. To the extent there is any inconsistency between this Notice and the Settlement Agreement, the provisions of the Settlement Agreement control. You can obtain more information about the settlement or obtain a copy of the Settlement Agreement by contacting the Settlement Administrator at:

ProAmpac Settlement
c/o Optime Administration, LLC
PO Box 3206, Brockton, MA 02304
Phone: 844-625-7313
Email: PROAMPAC@OPTIMEADMIN.COM
Fax: 781-287-0381

PLEASE DO NOT CALL OR WRITE THE COURT ABOUT THIS NOTICE.