Notice of Fair Labor Standards Act
Wage & Hour Settlement

You are receiving this notice because you have the right to join in a settlement for unpaid overtime wages for the time you 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, "Respondents") between February 24, 2020 and the date the Settlement Agreement was executed. This notice is only a summary.

The Named Claimant alleges that Respondents improperly classified him and other workers as independent contractors under the Fair Labor Standards Act ("FLSA") and failed to pay overtime premium wages for all hours worked over 40 in a workweek. Respondents dispute the claims, deny that anyone was misclassified, and deny that they violated the FLSA. The Arbitrator has preliminarily approved the settlement as fair and reasonable. This settlement is related to and contingent upon a global settlement of this arbitration and another arbitration and case. If the Arbitrator gives final approval and you file a Claim Form, you will be eligible to recover your settlement share.

The settlement requires Respondents to create a Settlement Fund of $113,341.28. Because no money from the Settlement Fund will go back to Respondents, the entire fund will be allocated among the Claimants who file a claim form — so you are expected to recover more money than any estimated amount. From the Fund, approximately $4,892.60 will be requested for Claimants' Counsel's attorneys' fees and costs, approximately $3,459.07 for settlement administration, and a $15,000 Service Award to the Named Claimant, all subject to the Arbitrator's approval. These amounts are paid in addition to your settlement recovery. Payment to participating Claimants is due by June 1, 2027 (or after any appeal period expires or is exhausted, whichever is later), and checks will be issued within 15 calendar days of that payment.

You can respond to this notice in one of two ways:

1. 1 File a Claim Form to participate and receive a payment. If you want to receive your share of the Settlement Fund, you must complete the Claim Form and Consent to Sue no later than sixty (60) days after this notice is issued. Any Claim Form emailed or postmarked after that deadline may be considered late and invalid. In exchange for your payment, you agree to release all wage and hour claims against Respondents arising during the covered period.
   
   You may submit your Claim Form by mail or email to the Settlement Administrator, or online here or via the navigation menu above. If you file a Claim Form, you designate Getman, Sweeney & Dunn, PLLC to represent you in this action.
2. 2 Do nothing. If you do not file a Claim Form, then you: (1) will not be covered by the settlement; (2) will not receive money from the settlement; and (3) will not give up any wage and hour claims against Respondents. You will keep any rights to sue Respondents about the same legal claims, provided you do so within the applicable statute of limitations.

No retaliation. Whether you decide to submit a Claim Form to participate or do nothing, you are free to make your choice without fear of retaliation. Respondents 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 or the Contact Us tab above to reach the Settlement Administrator or Claimants' Counsel for this matter.