LASC CIV 296 Rev. 04/26
Class Action and PAGA Settlement Agreement
For wage and hour settlements resolving class claims and PAGA civil penalties in a single agreement. The court-approved class notice is attached as Exhibit A.
Tools Court Model Documents
LASC Model Settlement Agreements in Word Format
The Los Angeles Superior Court publishes its model class action and PAGA settlement agreements only as PDFs. I have rebuilt all three as clean, carefully formatted Microsoft Word documents, so you can draft from the model (and produce the redline the court asks for) without retyping the court’s text.
Unofficial Convenience Copies. I prepared these Word versions independently; the court publishes only the PDFs, and those control if any discrepancy exists. Nothing on this page is legal advice.
01 The Documents
Download the Word Versions
Pick the model that matches your case. Each card also links the official PDF so you can verify against the court’s file.
LASC CIV 297 Rev. 04/26
Class Action Settlement Agreement
For class-only wage and hour settlements with no PAGA component. Includes the court-approved class notice as Exhibit A.
LASC CIV 298 Rev. 04/26
PAGA Settlement Agreement
For settlements of PAGA-only actions with no class claims. No class notice is required, so none is attached; approval proceeds by a single motion.
Faithful to the April 2026 Revisions. Each file follows the court’s current PDF word for word, with footnotes, paragraph numbering, and the notice exhibits rebuilt as native Word structures. Check the court’s website for any later revision before filing.
02 Background
Why These Word Versions Exist
The court plainly wants parties to use these models: each one opens with an instruction that counsel using it are to attach a redlined version to the motion for approval, showing exactly how the parties modified the model. The court distributes the models only as PDFs, and you cannot run a meaningful redline against a PDF.
Converting a PDF yourself rarely goes well. Automated conversion tends to scramble the paragraph numbering, drop footnotes into the body text, and shatter the class notice tables; cleaning that up can take longer than the drafting itself.
So I did the cleanup once. Each agreement was transcribed into Word with real heading styles, working tables, and the exhibits intact. Start from the model, keep an unmodified copy, and your redline becomes a two-click Compare.
The models themselves carry real weight. They are based on versions approved by the court and its complex litigation judges, developed with a 2022 ad hoc wage and hour committee co-chaired by Judge David Cunningham and Judge Amy Hogue (Ret.) and sixteen attorneys who regularly represent plaintiffs and defendants in wage and hour cases.
03 Choosing
Which Model Do I Need?
The three models track the three shapes a wage and hour settlement can take.
| Form | Use It For | Class Notice | Court Approval |
|---|---|---|---|
| LASC CIV 296 | Class claims and PAGA penalties settled together | Included as Exhibit A | Preliminary and final approval |
| LASC CIV 297 | Class claims only, with no PAGA component | Included as Exhibit A | Preliminary and final approval |
| LASC CIV 298 | PAGA claims only, with no class claims | Not required | Single approval motion |
Two drafting notes apply across the set. Each model is written for a single plaintiff suing a single employer; the court expects the parties to revise the form for multiple plaintiffs or multiple defendants.
And for PAGA notices sent to the LWDA after June 19, 2024, the models flag the amended penalty allocation of Labor Code section 2699, subdivision (m): 65% to the LWDA and 35% to aggrieved employees. Conform the bracketed splits to whichever allocation governs your notice date.
04 Workflow
How to Use the Models
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Start from the Model
Download the Word version and save two copies: one to draft in, one to leave untouched. The pristine copy is the baseline for the redline you will file.
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Tailor the Bracketed Terms
Work through the placeholders and bracketed options: the parties, the class and PAGA periods, the gross settlement amount, tax allocations, and the releases. In CIV 296 and 297, the release in the class notice must match the release in the agreement verbatim.
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Prepare the Required Redline
Run Word’s Compare feature against your untouched copy. Every model instructs counsel to attach that redline to the motion for approval so the court can see each modification at a glance, although this is really only required in Los Angeles County Superior Court.
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Verify and File
Check your draft against the official PDF (currently Rev. 04/26) and confirm the court has not posted a later revision. Then file the executed agreement, the redline, and the supporting declarations with your approval motion.
05 Questions
Frequently Asked Questions
Are these official court documents?
No. The official versions are the PDFs the court publishes, and those control if any discrepancy exists. I prepared the Word files independently as a drafting convenience, and each download is paired with a link to its official counterpart so you can verify. Nothing on this page is legal advice.
Do I have to use the models?
The court labels them “For Optional Use.” As a practical matter, the complex courts wrote them, and starting from one tends to shorten the path to approval. If you do use one, the instruction at the top of every model directs counsel to attach a redline showing the parties’ modifications to the approval motion.
Where do the models come from?
They are based on versions approved by the court and its complex litigation judges, developed with a 2022 ad hoc wage and hour committee co-chaired by Judge David Cunningham and Judge Amy Hogue (Ret.) and sixteen attorneys who regularly represent plaintiffs and defendants in wage and hour cases. The court revises them periodically; the current revision is April 2026.
Do the models reflect the 2024 PAGA amendments?
The April 2026 revisions include drafting notes for PAGA notices sent to the LWDA after June 19, 2024: penalty allocations move to 65% for the LWDA and 35% for aggrieved employees under Labor Code section 2699(m), per S.B. 92 and A.B. 2288. Confirm the split that governs your notice date before finalizing the bracketed percentages.
What changed in the Word versions?
Nothing substantive. The text follows the PDFs; what changed is the plumbing. Real heading styles, native footnotes, working tables, and exhibits that stay attached mean redlines, cross-references, and pagination behave the way Word documents should.
Can I use these outside Los Angeles County?
The models are drafted for the Los Angeles Superior Court, and other courts have their own checklists and preferences. The structure travels well as a starting point, but confirm the assigned department’s requirements before relying on any form.
Scheduling
Most of These Settlements Begin in Mediation
The models assume it: the recitals describe an all-day mediation that produced the agreement. I mediate California employment class and PAGA actions statewide by Zoom. Choose an available date, confirm, and you’re on the calendar.