If you are a Filipino national who worked for Montana Mike’s Steakhouse, Holiday Inn Express or Water Zoo in Clinton, Oklahoma under an H-2B visa between January 1, 2008 and December 31, 2014, you may be a potential Class Member, and you have a right to know about this class action lawsuit.

Three former H-2B workers who worked in Clinton, Oklahoma for Steakmacher, LLC d/b/a Montana Mike’s Steakhouse (“Steakmacher”), Hotelmacher, LLC d/b/a Holiday Inn Express (“Hotelmacher”) and Schumacher Investments, LLC d/b/a the Water Zoo (“Water Zoo”) have sued these companies, their alleged owners Walter and Carolyn Schumacher (the “Schumachers”), and Apex USA, Inc. (“Apex”) (together, “Defendants”), alleging forced labor and breach of contract.

The Court has allowed this lawsuit to proceed as a class action on behalf of all H-2B workers from the Philippines who were sponsored by or worked for the Defendants under H-2B visas between 2008 and 2014.

For answers to frequently asked questions, read the Notice of Class Action.  Please contact Class Counsel at the email or phone numbers listed at the bottom of this page if you have any questions.

Important Information

Your legal rights may be affected, and you have a choice to make now:

Your Rights and Options in This Lawsuit
These rights and options – and the deadlines to exercise them – are explained further in the Notice of Class Action.

Do nothing You do not need to do anything to be included in the lawsuit.  By doing nothing, you may receive monetary damages or other relief that may come from a trial or settlement, but you give up any rights to sue the Defendants separately about the same legal claims in this lawsuit, regardless of whether the class action is successful or unsuccessful.
Ask to be Excluded (“Opt Out”) You may ask to be excluded from this lawsuit and pursue your own lawsuit.  If you ask to be excluded from this lawsuit, you will not share in any monetary settlement or damages awarded in this lawsuit, but you will keep any rights to sue Defendants separately about the same legal claims in this lawsuit.

If you wish to be excluded, you must act before April 7, 2022. More detailed instructions are included in the Notice of Class Action.

 Important Documents:

Order Granting Class Certification
Order Appointing Class Counsel
Notice of Class Action (in English), (in Tagalog).

Class Counsel

If you have any questions, you can contact Class Counsel at [email protected] or at the phone numbers below.

Meghan Lambert
P.O. Box 13327
Oklahoma City, OK 73113
Telephone:  (405) 525-3831
Christopher J. Willett
Caitlin Boehne
314 E. Highland Mall Blvd., Ste. 401
Austin, Texas 78752
Telephone:  (512) 474-0007
Eben Colby
Catherine Fisher
500 Boylston Street, 23rd Floor
Boston, MA 02116
Telephone:  (617) 573-4800
George A. Warner
180 Montgomery Street, Suite 600
San Francisco, CA 94104
Telephone:  (415) 864-8848
Alyssa Musante
300 South Grand Avenue
Los Angeles, CA 90071-3144
Telephone:  (213) 687-5223