Customer Appreciation Events

During the COVID-19 pandemic, Do-Rite added a surcharge to guest checks. Under a proposed settlement concerning how that surcharge was disclosed, Do-Rite will host two Customer Appreciation Events at participating locations, subject to final court approval.

During each event, guests will receive 50% off eligible on-site food and beverage purchases, up to a maximum discount of $10 per guest per event. The discount will not apply to mobile, catering, or delivery orders.

Event dates, times, and participating locations will be announced once scheduled. Additional information regarding the settlement is below.

LEGAL NOTICE OF PROPOSED CLASS ACTION SETTLEMENT

Maher v. Do-Rite Tinley LLC, et al.,

Case No. 2022 CH 08000

(Circuit Court of Cook County, Illinois, County Department, Chancery Division)

A state court authorized this notice. You are not being sued. This is not a solicitation from a lawyer.

This notice is to inform you that a settlement has been reached in a class action lawsuit captioned Maher v. Do-Rite Tinley LLC, et al. Case No. 2022 CH 08000, Circuit Court of Cook County, Illinois, County Department, Chancery Division, brought on behalf of all persons in Illinois from whom Do-Rite collected a surcharge which Do-Rite did not disclose until, if ever, after the purchase during the period of August 16, 2017 through August 26, 2026. The lawsuit alleges claims for damages and injunctive relief as necessary under three Counts: (1) violations of the Illinois Consumer Fraud and Deceptive Practices Act (“ICFA”); (2) common law fraud; and (3) unjust enrichment. The defendants, Do-Rite Tinley LLC and Lettuce Entertain You, Inc. (“Defendants”), deny any wrongdoing and maintain that they have not violated any laws. The settlement does not establish who is correct but rather is a compromise to end the lawsuit and avoid the uncertainties and expenses associated with ongoing litigation.

• How do I know if I am a Class Member? The Settlement Class includes all persons in Illinois from whom Do-Rite collected a surcharge which Do-Rite did not disclose until, if ever, after the purchase during the period of August 16, 2017 and August 26, 2026.

• What Can I Get Out of the Settlement? If you’re eligible and the Court approves the settlement, Do-Rite will hold two (2) Customer Appreciation Events at the Do-Rite Tinley Park, Do-Rite Erie, Do-Rite Fulton Market, Do-Rite Addison, and Do-Rite Willis Tower locations (or such other location(s) as the Parties may agree in writing and subject to Court approval).  The first Customer Appreciation Event will occur within the first six months from the Effective Date of the Settlement Agreement, and the second will occur within the following six months from the first Customer Appreciation Event.  During each Customer Appreciation Event, Do Rite shall offer all customers a discount of fifty percent (50%) off the regular retail price of eligible food and beverage items, subject to the following limitation: the maximum discount available to any individual customer at each event shall be ten dollars ($10.00) in total and only includes food and beverage items (i.e., the discount does not apply to gift cards, retail merchandise, and similar items). The discount will be automatically applied at the point of sale for qualifying purchases made on site (i.e., will not apply to mobile orders, catering orders, or delivery orders) during the Customer Appreciation Event hours. The discount shall be available to all customers who make purchases on site at the applicable location during the hours designated for the Customer Appreciation Event, including but not limited to members of the Settlement Class. Do Rite shall provide at least seven (7) days advance notice of the dates, times, and location(s) of the Customer Appreciation Events by means reasonably calculated to reach Class Members and regular customers, which include, but are not limited to, in store signage, posting on Do-Rite’s website, and/or social media postings.

No minimum purchase is required to receive the discount, and the discount shall be applied at the point of sale. The Customer Appreciation Events and the associated discount are nontransferable and have no cash value. The discount cannot be redeemed for cash, credit, or any other consideration, and will not be issued as a gift card, coupon, or voucher. Class Members shall not be entitled to any additional or separate monetary or non-monetary consideration from Do Rite in lieu of or in addition to the Customer Appreciation Events described in this Section.

• How Do I Get My Settlement Relief? Attend the Customer Appreciation Events and make a qualifying purchase.

• Do I Have a Lawyer? Yes. The Court has appointed lawyers from the law firms Law Office of James X. Bormes, P.C., The Khowaja Law Firm, LLC, and Kerkonian Dajani, LLP as “Class Counsel.” They represent you and other Settlement Class Members. The lawyers will request to be paid two hundred thousand dollars ($200,000.00) as reasonable attorneys’ fees incurred in this class action lawsuit. You can hire your own lawyer, but you will need to pay that lawyer’s legal fees. The Court has also appointed Plaintiff James Maher—a class member like you—to represent the Settlement Class as a “Class Representative.”

If you have any questions regarding the lawsuit, you may contact Class Counsel via the following contact information, or via the mailing addresses listed below: James X. Bormes, (312) 201-0575, jxbormes@bormeslaw.com; Paul A. Castiglione, (312) 566-8070, pcastig@khowajalaw.com, or Elizabeth M. Al-Dajani, (312) 416-6180, ealdajani@kerkonialdajani.com.

• What Are My Rights and Options? You have three options. You can do nothing, exclude yourself (opt out) from the settlement, or comment on or object to any of the settlement terms.

• • Do Nothing: If you do nothing, you will not be able to sue the Defendants and certain related companies in a future lawsuit about the claims addressed in the settlement.

• • Exclude Yourself (Opt Out): If you exclude yourself, you will keep your right to sue the Defendants on the issues the settlement concerns. You must contact the Class Counsel by mail to exclude yourself. All Requests for Exclusion must be received by December 11, 2026.

• • • How to Exclude Yourself (Opt Out)- To exclude yourself (opt out), you must mail a written request for exclusion to the Class Counsel at:

Class Counsel:

James X. Bormes and Catherine P. Sons

Law Office of James X. Bormes

8 S. Michigan Ave., Suite 2600, Chicago, IL 60603

Paul A. Castiglione and Kasif Khowaja

The Khowaja Law Firm, LLC

8 S. Michigan Ave., 26^th Floor, Chicago, IL 60603

Elizabeth Al-Dajani and Karnig S. Kerkonian

Kerkonian Dajani, LLP

1555 Sherman Ave., Suite 344, Evanston, IL 60201

Your request must:

(a) state your full name, current mailing address, and telephone number;

(b) include a statement such as “I request to be excluded from the Maher v. Do-Rite Tinley LLC et al., Case No. 2022 CH 08000 settlement”;

(c) be personally signed and dated; and

(d) be postmarked no later than December 11, 2026, or received by email (if permitted) no later than December 11, 2026.

Requests that do not comply with these requirements may be deemed invalid. If you request exclusion, you will not be bound by the settlement or release.

• • Object: You can also object to the settlement if you disagree with any of its terms. You may also appear at the Final Approval Hearing, either by yourself or through an attorney you hire at your own expense. All Objections must be received by December 11, 2026.

• • • How to Object- If you do not exclude yourself, you may object to the settlement. To object, you must file or mail a written objection with the Court and mail copies to Class Counsel and Defense Counsel at the addresses below so that it is filed and postmarked by December 11, 2026.

Your objection must:

(a) state your full name, mailing address, telephone number, and, if available, email address;

(b) include a statement of the grounds for your objection and any supporting facts and legal arguments;

(c) identify any documents you want the Court to consider and attach copies if available;

(d) state whether you intend to appear at the Final Approval Hearing, and if you will appear through counsel, identify that counsel by name, firm, address, telephone number, and email;

(e) include your signature (or your counsel’s signature if represented).

Objecting does not prevent you from participating in the Settlement relief if the settlement is approved.

Court filing address:

Clerk of the Circuit Court of Cook County, Illinois,

County Department, Chancery Division

c/o Honorable Eve M. Reilly

50 W. Washington Street, Room 2405

Chicago, Illinois 60602

Re: Maher v. Do-Rite Tinley LLC and Lettuce Entertain You Enterprises, Inc., Case No. 2022 CH 08000

Class Counsel:

James X. Bormes and Catherine P. Sons

Law Office of James X. Bormes, P.C.

8 S. Michigan Ave., Suite 2600, Chicago, IL 60603

Paul A. Castiglione and Kasif Khowaja

The Khowaja Law Firm, LLC

8 S. Michigan Ave., 26^th Floor, Chicago, IL 60603

Elizabeth Al-Dajani and Karnig S. Kerkonian

Kerkonian Dajani, LLP

1555 Sherman Ave., Suite 344, Evanston, IL 60201

Counsel for Defendants:

Christopher Ward

Patrick McMahon

Foley & Lardner LLP

321 North Clark Street, Suite 2800, Chicago, Illinois 60654

• When will the Court Approve the Settlement? The Court will hold a final approval hearing on December 7, 2026 at 9:30 AM before the Honorable Eve M. Reilly in Room 2405 at the Richard J. Daley Center building, 50 W. Washington Street, Chicago, Illinois 60602 (subject to being changed to a later date). The Court will hear objections, determine if the settlement is fair, and consider Class Counsel’s request for fees and expenses and an incentive award of $5,000 to the Class Representative.  You may appear at the hearing, but you are not required to do so.

• What are the Important Deadlines?
  • Opt-Out (Exclusion) Deadline: December 11, 2026
  • Objection Deadline: December 11, 2026
  • Final Approval Hearing: December 7, 2026 (subject to being changed to a later date, and at such time this Notice will be updated)

PLEASE DO NOT CONTACT THE COURT WITH QUESTIONS ABOUT THIS SETTLEMENT