NOTICE OF SETTLEMENT OF CLASS ACTION LAWSUIT
Cardenas, et. al. v. Denver Metro Maids, Inc., et. al.,
Case No. 2024CV32587
Your Legal Rights and Options in This Lawsuit:
Do Nothing
Be eligible to receive the payment in the amounts stated below.
Exclude Yourself
Get no payment in this settlement. This is the only option that allows you to be part of any other lawsuit against Denver Metro Maids, Inc., 5280 House Cleaning, Inc., Christopher Lude, Hannah Loberg, and related others named in Section 6 below as “Releasees” concerning alleged unpaid wages or lack of rest breaks when you worked for them. Complete and return the attached one-page opt- out form.
Object
Write to the Court about why you do not like the proposed settlement.
Go to a Hearing
Ask to speak in Court about the fairness of the proposed settlement.
These rights and the deadlines to exercise them are explained in this notice.
TO: All Eligible Class Members
You may be entitled to money from a class action settlement concerning your work for Denver Metro Maids, Inc. and/or 5280 House Cleaning, Inc. and the former individual owners of those businesses. Under the terms of the proposed settlement, you are currently eligible to receive a payment, subject to applicable withholdings.
PLEASE READ THIS DOCUMENT CAREFULLY. THIS SETTLEMENT AFFECTS YOUR LEGAL RIGHTS.
1. Why am I receiving this Notice?
A proposed settlement (“Settlement”) has been reached in the above-referenced class action lawsuit currently pending in the District Court for the City and County of Denver, Colorado. This letter serves as an official Court notice of the terms of the proposed Settlement and your rights in connection with it.
Because your rights will be affected by the Settlement, it is extremely important that you read this notice carefully. As explained in more detail below, you will be included in the Settlement unless you affirmatively request to be excluded from it by submitting the attached Opt-Out Form to the Settlement Administrator by February 3, 2026. Opt-Out Forms sent by mail must be post marked no later than February 3, 2026.
2. What is a class action lawsuit?
A “class action” lawsuit is one in which a person, called the Class Representative, sues on behalf of people who have similar claims. Together, these people form a Class. Each person in the Class is a Class Member. As explained in more detail below, you have been identified as a Class Member in the above-referenced lawsuit.
3. What is this lawsuit about?
On August 26, 2024, Maria Cardenas and Nallely Escarcega, the Class Representatives, filed a class action lawsuit seeking to recover damages for alleged violations of the labor rights of employees working at Denver Metro Maids, Inc. and 5280 House Cleaning, Inc. The Class Representatives allege that Denver Metro Maids, Inc., 5280 House Cleaning, Inc., and Defendants Christopher Lude and Hannah Loberg (collectively “Defendants”) owe money to them and the other cleaners employed at those businesses at any time between August 26, 2022 and August 26, 2024. Specifically, the lawsuit claims that Defendants failed to provide paid rest breaks required by Colorado law. It also claims that Defendants failed to pay the cleaners for tasks they performed before and after the compensated workday. The lawsuit claims that Defendants’ actions violated the Colorado Overtime and Minimum Pay Standards Order, 7 CCR 1103-1. Defendants deny these claims.
4. Am I a member of the Class?
Yes. According to Defendants’ employment records, you worked at Denver Metro Maids, Inc. and/or 5280 House Cleaning, Inc. at times between August 26, 2022 and August 26, 2024 and you are not currently a member of the Cooperative Colorado Unida, LLC, which has now purchased the above businesses. This qualifies you as a Class Member. As a Class Member, you are entitled to a share of the settlement money.
5. What does the Settlement provide?
Defendants will pay $285,000.00 to settle the class claims against them in this matter. $193,750.00 of this money will be paid to workers. $71,250.00 will be paid to the attorneys for the cleaners. Each Class Representative will receive a $10,000.00 incentive payment. Each Class Member will receive a share of the remaining funds based on Defendants’ payroll data showing the number of weeks they worked during this time period.
6. What are my rights as a Class Member?
Option A. Participate in the Settlement and receive a payment.
Upon approval by the Court, you will receive money from the Settlement, unless you request to be excluded. You do not have to take any affirmative steps to choose this option. If you do nothing, you will receive a settlement payment.
Upon approval of the Settlement by the Court, and that approval becoming final, you will receive a settlement payment and will be deemed to have released Denver Metro Maids, Inc., 5280 House Cleaning, Inc., and Defendants Christopher Lude and Hannah Loberg from all claims of every kind related to payment or rest breaks. Specifically, you will release and fully discharge Christopher Lude, Hannah Loberg, Denver Metro Maids, Inc., 5280 House Cleaning, Inc., and their present and former officers, directors, shareholders, agents employees, representatives, attorneys, parent companies, subsidiaries, divisions, affiliates, related companies, successors and assigns (the “Releasees”) from any and all wage and hour claims, debts, complaints, damages, penalties, costs, demands, suits, actions, and causes of action under Colorado law that were brought or could have been brought in this Action based on the facts alleged in the operative complaint. The facts alleged involved the failure to pay all time worked and the failure to provide paid rest breaks to the cleaners.
If you participate in this settlement you agree not to make claims against the Releasees for those things.
Option B. Exclude yourself from the Settlement.
If you do not wish to be a part of the Settlement, you must exclude yourself by filling out the attached Opt-Out Form and sending it to the Claims Administrator by mail, FAX or email to:
Denver Metro Maids Lawsuit
c/o Optime Administration, LLC
PO Box 3206
Brockton, MA 02304
Fax: 781-287-0381
Email: DenverMetroMaidsLawsuit@optimeadmin.com
If you exclude yourself from the Settlement, you will not receive a settlement payment and you will not be bound by the settlement.
To be valid, the exclusion request must be received by February 3, 2026. Opt-Out Forms sent by mail must be postmarked no later than February 3, 2026.
Importantly, if you ask to be excluded from the Settlement, you will not receive any settlement payment, and you cannot object to the Settlement. If you exclude yourself, you will not be legally bound by the Settlement or the release of legal claims against Defendants and the Releasees.
Option C. Participate in the Settlement but object to its terms.
If you choose to participate in the Settlement, you may object to its terms, and the Court will consider your objections in deciding whether to approve the Settlement. If you choose to exclude yourself from the Settlement altogether (see Option B above), you cannot object to its terms.
If you choose to object to the proposed Settlement, you may do so in writing sent to the Settlement Administrator by February 3, 2026. It is required that all written objections and supporting papers must include: (a) your full name, address and telephone number; and (b) an explanation of why you object to the proposed settlement agreement. All written objections must be sent to the Administrator by mail to:
Denver Metro Maids Lawsuit
c/o Optime Administration, LLC
PO Box 3206
Brockton, MA 02304
Fax: 781-287-0381
Email: DenverMetroMaidsLawsuit@optimeadmin.com
All written objections must be received by the Administrator no later than February 3, 2026. If you wish to object to the proposed settlement agreement in person by speaking in Court, you may do so by appearing at the Final Fairness Hearing to be held on March 10, 2026 at 12:00pm, at the District Court, City and County of Denver, Colorado, 1437 Bannock St. Denver, CO 80202 in Courtroom 203 on the Second floor.
7. What do I give up by receiving a settlement payment?
As explained in Section 6, you have the option to request exclusion from this Settlement. If you do not request exclusion from this Settlement by following the procedure described in Section 6, you will receive the settlement payment described above and be bound by the Settlement and the Release as set forth in the settlement agreement and Final Approval Orders.
If you currently have a pending legal claim or lawsuit against Defendants or another of the Releasees, or if you anticipate filing a future legal claim or lawsuit based on wage-related events that already have taken place, you should promptly consult with your attorney about this settlement and the impact of this release on your current or anticipated legal claims or lawsuits.
8. Can I Be Retaliated Against for Participating in This Settlement?
No. It is a violation of Colorado law for anyone to retaliate against you in any way for taking part in this settlement.
9. Do I have a lawyer in this case?
The Court has preliminarily approved the following lawyer to serve as “Class Counsel” and to represent the interests of Plaintiffs and the Class Members:
Andrew H. Turner
Milstein Turner PLLC
2400 Broadway – Unit B
Boulder, CO 80304
Tel: 303-305-8230
andrew@milsteinturner.com
The above lawyer represents your legal interests and will answer your questions in strict confidence without charge. If you call, please identify yourself as a “Class Member” in the “Denver Metro Maids” lawsuit and ask to speak the above attorney. If you would like to review a full copy of the entire Settlement Agreement he will provide it to you upon request.
Nothing prohibits you from speaking with other lawyers about the lawsuit or this Notice. You have the right to retain an attorney of your own choosing and at your own cost.
10. How do the Plaintiff’s attorneys get paid?
Class Counsel has asked the Court to enter an award of attorney’s fees and expenses to compensate Class Counsel for their work and money expended in this action of $71,250.00. Class Counsel has filed a petition for attorney’s fees and has provided documentation of their time expended and expenses; however, the actual amount awarded will be determined by the Court to ensure that the amount of attorney’s fees and costs is fair and reasonable. The Court will hold a hearing to consider this attorney’s fee request and the fairness of this settlement agreement as a whole on March 10, 2026 at 12:00pm, at the District Court, City and County of Denver, Colorado, 1437 Bannock St. Denver, CO 80202 in Courtroom 203 on the Second floor. You have the right to speak about or object to the proposed attorney’s fee.
You also have the right to retain an attorney of your own choosing and at your own cost.
11. Will the Class Representatives be rewarded for serving the Class? Representative?
Yes. Class Counsel will request that an incentive award be paid to the Class Representatives to compensate them for their time and effort expended in this action, and for their public service performed for the Class. The requested incentive award to each of the two Class Representatives is $10,000.00 and shall be in addition to any compensation they are entitled to receive as a member of the Class.
12. When and where will the Court decide whether to approve the Settlement?
The Court will hold a hearing to decide whether to approve the Settlement. You are not required or expected to attend that hearing. However, you are welcome to attend.
At the hearing, the Court will consider whether the Settlement (including the requested attorneys’ fees) is fair and reasonable. The Court will consider all written objections to the Settlement and will hear from any Class Members who have objections to the Settlement.
The Court will hold the hearing on March 10, 2026 at 12:00pm, at the District Court, City and County of Denver, Colorado, 1437 Bannock St. Denver, CO 80202 in Courtroom 203 on the Second floor. This date, however, shall be subject to adjournment by the Court without further notice other than that which may be posted by the Court. If you plan to attend, please confirm the date and time with Class Counsel listed in Section 9 above.
13. How do I obtain more information?
This Notice summarizes the most important aspects of the settlement. You can obtain a copy of the entire settlement agreement, as well as the underlying Court pleadings, by contacting the attorneys listed in Section 9 above or the Settlement Administrator identified below:
Denver Metro Maids Lawsuit
c/o Optime Administration, LLC
PO Box 3206
Brockton, MA 02304
Fax: 781-287-0381
Email: DenverMetroMaidsLawsuit@optimeadmin.com
DO NOT CONTACT THE COURT OR THE CLERK OF COURT.
14. What if my name or address changes?
It is your responsibility to inform the Settlement Administrator of your correct address. Please mail any change of address information to the Settlement Administrator (see Section 13, above).
DO NOT CALL THE COURT OR THE CLERK OF THE COURT.