Notice of FLSA & State Wage
and Hour Class Settlement

This lawsuit seeks back overtime wages for people who worked for A-1 Quality Logistical Solutions, LLC and its related companies — including East Logistics LLC, Empire Labor Services LLC, Eastern Labor LLC, DC Labor, LLC, Western Logistics, LLC, Westside Labor, LLC, AtPac Services, LLC, Warehouse Cargo Services, EastCoast Services, LLC, WestCoast Services, Elite EC Logistics, LLC, Elite WC Logistics, LLC, Complete Quality Solutions, LLC, and Complete Quality Support, LLC — as well as William Foster, III, and Richard Mursinna (together, "Defendants"). The Named Plaintiffs allege that Defendants improperly classified them and other workers as independent contractors under the Fair Labor Standards Act ("FLSA") and applicable state wage and hour laws and failed to pay overtime premium wages for all hours worked over 40 in a workweek. Defendants dispute these claims and deny any wrongdoing.

The settlement covers people who worked for Defendants as independent contractors as order selectors or lumpers between February 24, 2020 (or earlier if you worked in a state with a longer statute of limitations) and the date the Settlement Agreement was executed. The Court has preliminarily approved the settlement as fair and reasonable. This settlement is related to and contingent upon a global settlement of this case and other arbitrations.

The settlement requires Defendants to create a Settlement Fund of $936,658.72. Because no money from the Settlement Fund will go back to Defendants, the entire fund will be allocated among the participating workers — so you are expected to recover more money than any estimated amount. From the Fund, approximately $45,107.40 will be requested for Class Counsel's attorneys' fees and litigation costs, approximately $31,890.93 for settlement administration, and a $15,000 Service Award to each of the two Named Plaintiffs, all subject to Court approval. These amounts are paid in addition to your settlement recovery.

You have the following options. Your rights depend on which notice you received: if you have already filed a Consent to Sue that remains pending in this case, you do not need to do anything to participate and receive a payment. If you have the right to join but have not yet joined, you must file a Claim Form to receive a payment.

1. 1 File a Claim Form to participate and receive a payment. If you wish to receive your share of the Settlement Fund, complete the Claim Form and Consent to Sue no later than sixty (60) days after this notice is issued. If you already filed a Consent to Sue that remains pending, you do not need to file a new Claim Form to participate.
   
   You may submit your Claim Form by mail or email to the Settlement Administrator, or online here or via the navigation menu above. In exchange for your payment, you agree to release your wage and hour claims against Defendants for the covered period.
2. 2 Exclude yourself (opt out). If you want to keep the right to sue Defendants on your own about the legal issues in this case, you must exclude yourself. Send the Settlement Administrator a written, signed statement including your name, address, telephone number, and last four digits of your Social Security number, stating that you opt out of the Johnson v. A-1 wage and hour settlement. Your opt-out statement must be dated no later than 60 days from the date of mailing. If you opt out, you will not receive a payment and cannot object.
3. 3 Object to the settlement. If you participate, you may object to the settlement terms if you believe they are unfair. Mail or email a written objection to the Settlement Administrator identifying all of your reasons, along with your name, address, telephone number, and last four digits of your Social Security number, no later than 60 days from the date of mailing. You may also ask to appear at the fairness hearing. If the Court overrules your objection, you will still be bound by the settlement.
4. 4 Do nothing. If you received the "Right to Join" notice and do nothing, you will not receive money from the settlement and you will give up any wage and hour claims against Defendants. If you already filed a Consent to Sue, doing nothing means you will participate and receive your settlement share.

No retaliation. Whether you choose to participate, object, or opt out, you are free to make your choice without fear of retaliation. Defendants will not retaliate against you based on your choice. Even if you signed an agreement that contains an arbitration clause, you have the right to participate in this settlement.

For more information, visit the Important Documents tab for Court Documents or the Contact Us tab above to reach the Settlement Administrator or Class Counsel for this matter.