Non-California Collective Notice
All persons who worked for LA Laser Center PC, Daniel Taheri M.D. Inc., or LA Business Management Services LLC as a physician assistant or nurse practitioner in Arizona or Nevada, but not in California, at any time from October 24, 2019, to April 29, 2026, were subject to a Training Repayment Agreement, and who timely and validly opt into the Settlement.
This is a court-authorized notice. This is not a solicitation from a lawyer. A court has authorized this notice because you may be a member of the Non-California Collective in this FLSA settlement.
Case Summary
Lakey and Cummings v. LA Laser Center, PC
County of Los Angeles
1What Is This Lawsuit About?
Plaintiffs Lakey and Cummings filed a lawsuit against LA Laser Center, PC alleging violations of the federal Fair Labor Standards Act (FLSA). The lawsuit alleges that LA Laser Center, PC subjected non-exempt employees who worked outside of California to unlawful Training Repayment Agreements and failed to properly pay wages owed under federal law.
LA Laser Center, PC denies all of the allegations in the lawsuit and denies any wrongdoing. The Court has not decided who is right. Instead, the parties have agreed to settle the lawsuit to avoid the costs and risks of further litigation.
2Who Is Included in the Non-California Collective?
Non-California Collective Definition:
All persons who worked for LA Laser Center PC, Daniel Taheri M.D. Inc., or LA Business Management Services LLC as a physician assistant or nurse practitioner in Arizona or Nevada, but not in California, at any time from October 24, 2019, to April 29, 2026, and were subject to a Training Repayment Agreement.
If you received this notice, the Settlement Administrator believes you may be a member of the Non-California Collective based on employment records provided by LA Laser Center, PC. If you have questions about whether you are included, please contact the Settlement Administrator.
3How Is This Different from the California Class?
| Feature | California Class | Non-CA Collective |
|---|---|---|
| Legal Basis | California State Law and Federal FLSA | Federal FLSA |
| To Participate | Automatic — do nothing | Wait for your check; endorse and deposit it |
| If You Do Nothing | Receive payment; release CA claims | Check is mailed to you; depositing it opts you in |
| To Exclude Yourself | Submit opt-out request | Do not endorse or deposit your check |
4What Does the Settlement Provide?
The parties have agreed to a settlement that will provide monetary relief to Non-California Collective members. A settlement check will be mailed directly to each Non-California Collective member at the address on file with the Settlement Administrator. The specific settlement amount and individual payment calculations are set forth in the Settlement Agreement, available on the Important Documents page.
Each Non-California Collective member's individual settlement payment will be calculated based on the number of workweeks they worked for LA Laser Center, PC outside of California during the collective period, relative to the total workweeks worked by all Non-California Collective members.
5What Are Your Options?
Participate — Endorse & Deposit Your Check
Wait for your settlement check to arrive in the mail. When you receive it, endorse the check (sign the back) and deposit it within 180 days of receipt.
Endorsing and depositing the check constitutes your opt-in to the FLSA collective action. By doing so, you will receive your settlement payment and release your federal FLSA claims against LA Laser Center, PC and the Released Parties.
Do Not Participate — Do Not Cash Your Check
If you do not wish to participate in the settlement, simply do not endorse or deposit your settlement check.
By not cashing your check, you will not release any FLSA claims and you retain the right to pursue your own FLSA claims against LA Laser Center, PC separately.
How opting in works: Under the Fair Labor Standards Act, you formally join (opt in to) this collective action by endorsing and depositing your settlement check. No separate form or submission is required — your check endorsement serves as your consent to join. If you wish to object to the settlement before checks are issued, you must include an "opt in" statement as part of your objection. This is discussed in the Notice of Fair Labor Standards Act Collective Settlement.
6Key Deadlines
| Event / Deadline | Date |
|---|---|
| Objection DeadlineDeadline(Note: You must affirmatively opt in to the settlement to submit an objection.) | August 11, 2026 |
| Final Approval Hearing | September 10, 2026 at 9:00 a.m. |
| Estimated Check Mailing Date | TBD |
| Check Endorsement Deadline (180 days from receipt)To Participate | 180 days from receipt |
Court dates will be updated when confirmed. Check the Important Dates page for the latest information.
7Keep Your Address Updated
Your settlement check will be mailed to the address on file with the Settlement Administrator. If your address has changed, please contact the Settlement Administrator as soon as possible to update your mailing address so you do not miss your check.
8The Attorneys
The Court has appointed Class Counsel to represent the Non-California Collective in this matter. Class Counsel's fees and costs will be paid from the settlement fund and will be subject to Court approval. You do not need to pay Class Counsel separately.
You have the right to hire your own attorney at your own expense to advise you about your rights in connection with this settlement.
9Final Approval Hearing
The Court will hold a Final Approval Hearing to decide whether to approve the settlement as fair, reasonable, and adequate. The hearing date is listed on the Important Dates page. You may, but are not required to, attend this hearing.
If the Court approves the settlement, checks will be mailed to Non-California Collective members after any appeals are resolved.
Need More Information?
The full Settlement Agreement and other important documents are available for download. If you have questions, please contact the Settlement Administrator.
Disclaimer: This website is for informational purposes only and does not constitute legal advice. This notice summarizes the proposed settlement. For the complete terms of the settlement, please review the full Settlement Agreement available on the Important Documents page. Collective members are encouraged to consult with their own legal counsel regarding their rights and options.