UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Transcription

1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION DE ANGELO BENTLEY, MARQUES ROBERTSON, IKEYMA MCKENTRY, individually, and on behalf of all similarly situated persons, CIVIL ACTION FILE NO. 1:13-cv RWS Plaintiffs, v. FLOOD BROTHERS, INC., Defendant. NOTICE OF LAWSUIT AGAINST FLOOD BROTHERS, INC. A Court has authorized this Notice. This is not an advertisement. Please review this Notice carefully, as it details certain legal rights that you may have. This Notice is to inform you of your right to join a lawsuit filed against Flood Brothers, Inc. ( Flood Brothers. The lawsuit seeks to recover unpaid overtime wages, liquidated damages, and attorneys fees and costs on behalf of all current and former Movers employed by Flood Brothers at any time beginning July 9, 2010 to present. The Court has not made any determination about the merits of Plaintiffs claims. Flood Brothers denies liability. If you wish to join this lawsuit, you must complete and return the attached Notice of Consent to the address indicated below by December 27, 2013.

2 What This Lawsuit Is About. This lawsuit seeks overtime pay for current and former Movers employed by Flood Brothers. The Plaintiffs in this lawsuit are current and former Movers employed by Flood Brothers at any time beginning July 9, Plaintiffs allege that they and other Movers worked more than forty hours per week, that they were legally entitled to be paid overtime compensation, and that Flood Brothers did not pay them overtime at a rate of 1 and ½ their regular rate. The Plaintiffs seek to recover unpaid overtime wages, liquidated damages equal to any unpaid overtime wages, and attorneys fees and costs. As a current or former Mover with Flood Brothers, you have been identified as an individual who may be entitled to damages. The proposed class in this action is defined as: All individuals who were, or are, employed by Flood Brothers, Inc. as Movers at any time beginning July 9, You have the right to opt in, or join, this lawsuit. To opt in, you must file a Consent To Join Form with the Court. A Consent to Join Form is attached to this Notice. Protection Against Retaliation. Federal law forbids Flood Brothers from retaliating or discriminating against you in any way if you decide to join this lawsuit.

3 How To Join This Lawsuit. Enclosed is a Consent Form and envelope addressed to one of the attorneys who represents the Plaintiffs. If you decide to join this lawsuit, you must complete and sign the enclosed Consent Form, postmarked on or before December 27, 2013, and mail it to: Steve E. Wolfe & Justin M. Scott Buckley & Klein, LLP 1230 Peachtree St., N.E, Suite 900 Atlanta, Georgia The Legal Effect of Joining This Lawsuit. If you decide to join this lawsuit, you will be bound by any judgment entered by the Court. While the lawsuit is proceeding, you may be required to participate in the discovery process, and there is also a possibility that if the case proceeds to trial, you will be called to testify. Specifically, you may be required to respond to written questions, testify under oath during depositions and in court, or any combination of those things. If you join the lawsuit, you will be represented by the Plaintiffs counsel. Plaintiffs counsel is being paid on a contingency fee basis, which means that if there is no recovery, you will not have to pay any attorneys fees. If there is a recovery, Plaintiffs counsel will receive a part of any settlement obtained or money judgment entered in favor of all members of the class. By joining the lawsuit, you designate the class representatives, DE ANGELO BENTLEY, MARQUES ROBERTSON, and IKEYMA MCKENTRY, as your agents to make decisions on your behalf concerning the litigation, the entering of an agreement with Plaintiffs counsel concerning attorneys fees and costs, and all other matters pertaining to this lawsuit. These decisions and agreements made and entered into by the class representative will be binding on you if you join this lawsuit.

4 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION DE ANGELO BENTLEY, MARQUES ROBERTSON, IKEYMA MCKENTRY, individually, and on behalf of all similarly situated persons, CIVIL ACTION FILE NO. 1:13-cv RWS Plaintiffs, v. FLOOD BROTHERS, INC., Defendant. CONSENT TO JOIN I,, consent to be a Plaintiff in the abovecaptioned case as a member of the Class. I am and/or have been employed as a Mover with Flood Brothers, Inc. ( Flood Brothers I began my employment with Flood Brothers on (please provide date, and: I am still employed (check if still employed with Flood Brothers; or My employment with Flood Brothers ended on (please provide date.

5 During my employment with Flood Brothers, I worked more than forty (40 hours per week but was not paid overtime compensation. I agree to be represented in this lawsuit by the named Plaintiffs and their attorneys: Buckley & Klein, LLP, 1230 Peachtree St., N.E., Suite 900, Atlanta, Georgia Name Address Phone Number Address Date