1
NOTICE OF CLASS ACTION
TO ALL INDIVIDUALS WHO WORKED AS DANCERS AT THE GOLD CLUB,
LOCATED AT 650 HOWARD STREET IN SAN FRANCISCO, CALIFORNIA, FROM
MAY 24, 2000 UNTIL FEBRUARY 18, 2004.
YOU MAY BE A MEMBER OF A CLASS OF PERSONS WHO SUED THE
GOLD CLUB.
IF YOU ARE A MEMBER OF THE CLASS, WHICH IS DESCRIBED BELOW,
YOU SHOULD CAREFULLY READ THIS NOTICE BECAUSE IT WILL AFFECT
YOUR RIGHTS.
THIS COURT-ORDERED NOTICE IS NOT AN EXPRESSION OF ANY
OPINION BY THE COURT AS TO THE MERITS OF ANY OF THE CLAIMS OR
DEFENSES ASSERTED BY EITHER SIDE IN THIS LITIGATION. THE SOLE
PURPOSE OF THIS NOTICE IS TO INFORM YOU OF THE LAWSUIT SO THAT
YOU CAN MAKE AN INFORMED DECISION AS TO WHETHER YOU SHOULD
REMAIN IN OR OPT OUT OF THIS CLASS ACTION.
BACKGROUND OF CASE
The Plaintiffs in this lawsuit are three former dancers at the Gold Club, who performed
under the stage names “Grace,” “Kili” and “Debra.” The Plaintiffs sued Defendants SOLID
GOLD, INC., TOP SHELF ENTERTAINMENT, INC., and GOLD CLUB – SF, LLC. At the
Plaintiffs’ request, the Court authorized this lawsuit to proceed as a class action and appointed
the Plaintiffs to act as the Class Representatives on behalf of all dancers who worked at the Gold
Club from May 24, 2000 until February 18, 2004. This group of dancers is known as the Class
or the Class Plaintiffs. The Court also appointed the attorneys listed below as Class counsel to
provide legal representation to each Class member.
The Class alleges that Defendants violated California law by treating Class members as
independent contractors, when those persons were in fact employees of one or more of the
Defendants. Defendants deny the Class' allegations and assert that Class members were properly
treated as independent contractors, not employees. The Court has not yet ruled whether Class
2
members were independent contractors or employees.
If the Class is successful in this action, all of the persons who are members of the Class
may be entitled to receive a monetary recovery.
DEFINITION OF CLASS
On June 8, 2005, the Court entered an order certifying the Class, which is defined as
follows:
All entertainers who performed at the Gold Club at 650 Howard Street in San
Francisco from May 24, 2000 through February 18, 2004.
TRIAL DATE
This class action is currently set for trial on October 11, 2005 in the California Superior
Court for the County of San Francisco.
AUTOMATIC INCLUSION IN CLASS; RIGHT TO OPT-OUT OF CLASS
If you are a member of the class – that is, if you were a dancer at the Gold Club at any
time between May 4, 2000 and February 18, 2004 - you have the following options:
A. You will be automatically included in the Class unless you elect to exclude
yourself from the class by September 24, 2005.
B. You may exclude yourself from the Class by giving Class counsel notice as set
forth below.
You have the choice of remaining in the Class or being excluded from the Class. The
choice has certain legal consequences, and you are advised to discuss your decision with an
attorney. Class counsel will not contact you during the period that you may opt-out of the Class,
from August 25, 2005 until September 24, 2005, although you may contact Class counsel should
you wish. Defense counsel is not permitted to contact you during the opt-out period or at any
time if you remain in the Class, because the Class was certified.
IF YOU CURRENTLY DANCE AT THE GOLD CLUB, YOUR DECISION TO
BE INCLUDED IN THE CLASS WILL NOT AFFECT YOUR ABILITY TO CONTINUE
TO DANCE AT THE CLUB
3
If you elect to be included in the Class:
1. You will be represented by the existing Class Representatives, who are identified
as the named Plaintiffs above under their stage names, and by the attorneys appointed as counsel
for the Class, who are identified below. You will be entitled to contact Class counsel regarding
this litigation. After the opt-out period, Class counsel may also contact you to advise you
regarding this litigation. Defendants and their attorneys are not permitted to contact you about
this action.
2. You will receive notice of any proposed settlement or dismissal of Class claims,
or any judgment entered in this action.
3. You will waive any right you may have to separately sue SOLID GOLD, INC.,
TOP SHELF ENTERTAINMENT, INC., and/or GOLD CLUB – SF, LLC. on any of the claims
asserted in this class action and, instead, agree that your claims will proceed in the Superior
Court for the County San Francisco as part of this class action. You will be bound by any
judgment or other final disposition of the class lawsuit, whether favorable or unfavorable, subject
to any right of appeal. You will not have the right to bring an individual action at a later date.
4. You will participate, upon proof of membership in the class and the filing of a
proper claim form, in a distribution of funds, if any, recovered in the litigation.
5. Any records maintained by Defendants regarding your work at the Gold Club will
be produced to Class counsel for use only in this litigation and will be kept confidential by Class
counsel. Neither Defendants nor the Class Representatives, nor their counsel, shall disclose your
legal names or last known addresses to anyone, unless you consent to the disclosure or the
disclosure is ordered by the Court.
If you elect to be excluded from the class:
1. You will not be bound by any disposition of the class action and you will retain
any claims you may have against Defendants. You will have the right to appear in this action
through your own attorney.
2. You will not share in any recovery which might be paid to Class members if the
Class Representatives are successful in trial or as a result of any settlement.
4
COUNSEL FOR THE PLAINTIFF CLASS
James A. Quadra
Rebecca Bedwell-Coll
Robert D. Sanford
Moscone, Emblidge & Quadra LLP
180 Montgomery Street, Suite 1240
San Francisco, California 94104-4238
Telephone: (415) 362-3599
Facsimile: (415) 362-7332
CHANGE OF ADDRESS
If you move after receiving this notice and elect to remain in the Class, you should supply
your name and correct address to:
Counsel for the Plaintiff Class
James A. Quadra
Rebecca Bedwell-Coll
Robert D. Sanford
Moscone, Emblidge & Quadra LLP
180 Montgomery Street, Suite 1240
San Francisco, California 94104-4238
Telephone: (415) 362-3599
Facsimile: (415) 362-7332

WHAT TO DO
IF YOU WISH TO BE A MEMBER OF THE CLASS, YOU DO NOT NEED TO TAKE
ANY FURTHER ACTION, EXCEPT TO PROVIDE AN ACCURATE ADDRESS TO THE
CLASS ATTORNEYS, SHOULD YOU CHOOSE TO DO SO. YOU SHOULD RETAIN ALL
RECORDS AND DOCUMENTS PERTAINING TO YOUR WORK AT THE GOLD CLUB.
IF YOU WISH TO BE EXCLUDED FROM THE CLASS, YOU MUST NOTIFY
CLASS COUNSEL IN WRITING (SETTING FORTH YOUR NAME AND ADDRESS) AT
THE ADDRESS SET FORTH BELOW AND SUBMIT YOUR WRITTEN NOTICE IN AN
ENVELOPE POSTMARKED NO LATER THAN SEPTEMBER 24, 2005:
James A. Quadra
Rebecca Bedwell-Coll
Robert D. Sanford
Moscone, Emblidge & Quadra LLP
180 Montgomery Street, Suite 1240
San Francisco, California 94104-4238
Telephone: (415) 362-3599
Facsimile: (415) 362-7332
5
YOU BEAR THE RESPONSIBILITY FOR ENSURING THAT YOUR NOTICE IS
POSTMARKED BY THE DEADLINE.
DO NOT CALL OR WRITE TO THE COURT OR THE CLERK OF THE
COURT. ADDRESS ALL INQUIRIES IN WRITING TO THE ATTORNEYS FOR THE
CLASS SET FORTH ABOVE.
HON. JAMES L. WARREN
JUDGE OF THE SUPERIOR COURT