VERIZON CONNECT FLSA COLLECTIVE ACTION FOR ALL PRESENT AND FORMER BDR and CLOSERS

FELDMAN LEGAL GROUP Plaintiffs' attorneys for verizon connect flsa BDR AND

ABOUT THIS FLSA COLLECTIVE ACTION LAWSUIT FOR OVERTIME WAGES

LAUREN GARNICK, TSHACHA ROMEO and COREY HANVEY VS. VERIZON CONNECT FLEET USA LLC; MIDDLE DISTRICT OF FLORIDA, CASE NO: 8:20-cv-01474

Our firm represents Lauren Garnick, Tshacha Romeo, a current and formerly employed VERIZON CONNECT FLEET USA LLC, BUSINESS DEVELOPMENT REPRESENTATIVE (BDR), and COREY HANVEY, a former CLOSER, in a currently filed collective action lawsuit for overtime wages against Verizon under the Fair Labor Standards Act (FLSA) pending in the US District Court Middle District of Florida.

A copy of this lawsuit to be filed is viewable here with this link:

https://3im48bncp1h319qzs3fmpzu1-wpengine.netdna-ssl.com/wp-content/uploads/2020/07/Complaint-1st-Amd-Complaint-Garnick-v.-Verizon-FINAL-071320-.pdf

The lawsuit seeks to recover overtime wages for all present and former INSIDE SALES REPS, including but not limited to all BDR, CLOSERS or other job titles, for all hours worked over 40 in each and every workweek in the past 3 years at rates of time and one half the employee's regular rates of pay (which must include the value of all commissions/bonuses earned). The lawsuit also seeks to recover double the sum of the wages owed to all persons as liquidated damages, plus payment of all attorney's fees and costs and expenses.

The lawsuit alleges a plan and scheme by VERIZON CONNECT to evade and avoid paying required overtime wages to all inside sales reps, including BDR and CLOSERS working for the company in the preceding 3 years to the present. The lawsuit alleges that the Company had a De Facto policy against employees reporting all overtime hours, and a policy and practice of permitting employees to suffer to work off the clock for overtime hours, both of which would be unlawful. The lawsuit also alleges that employees routinely worked during the 1 hour provided lunch break which would cause each and every person to incur compensable, unpaid overtime wages, and that the company did not provide any REAL means to report and claim these overtime hours, up to 5 hours per week, and other compensable overtime time minutes and hours. Plaintiffs Garnick, Romeo and Hanvey also allege they incurred work hours unreported and unpaid coming in work early, staying late, and handling phone calls and emails outside of the office.

VERIZON CONNECT, as successor and purchaser of FLEETMATICS, has inherited a company with past similar unlawful pay practices against BDR by failing to pay overtime wages as seen in the case of Gillard, Stramiello and Pate v. Fleetmatics USA LLC, Case no. 8:16-cv-00081, settled for $2.1 million dollars in November 2016.

As part of our continuing investigation into the alleged FLSA wage violations by VERIZON CONNECT and in an effort to gather evidence in support of our position and corroborate facts about its pay practices, we are in need of speaking to as many present and former BDR and CLOSERS, and all other inside sales reps. We seek to determine if the positions and job duties/requirements are similar for all the various job titles used, as well to investigate and determine if the alleged unlawful pay practice at issue here is pervasive and long standing at VERIZON CONNECT.

You are someone who has valuable information as a witness to the alleged unlawful pay practices.Your contact information was obtained from a resume posted on the internet which indicates that you were at one time, or are now, either a member of the similarly situated class of persons who worked for VERIZON CONNECT FLEET USA LLC, and who may have personal knowledge of the important facts related to the claims in this lawsuit, and who may also have legal rights affected by the outcome of this pending lawsuit.

The law, and 1st AMENDMENT of the US Constitution permits attorneys in FLSA class/collective actions to communicate in this form with the class members (current and former employees) before certification. See Cooper v. E. Coast Assemblers, Inc., 21 Wage & Hour Cas. 2d (BNA) 152: January 2013.

To be clear, the purpose of this email is NOT to solicit you to opt into and join this collective action lawsuit, (which will seek a national class certification) and to claim your wages, or to advertise our firm. Rather, we are contacting you to determine what your experience has been and if similar to what our clients in this pending lawsuit have alleged, and to corroborate facts.

We are asking that you voluntarily contact us to discuss your employment experience with VERIZON CONNECT. You are under no obligation at all to respond to this email or contact us even if you have relevant information, and we will not intentionally email you again.

Thank you for taking the time to read this email. If you have any information you would like to share, or if we can discuss your work experience with VERIZON CONNECT, please email me or call me or my associate Jason Quintus at the office. I can additionally be reached after business hours and weekends at 813 906-8932. Let us know available days and times, nights or weekends to best call you, and the number to reach you at.

We Want to HEAR ABOUT YOUR EXPERIENCE

**The FLSA also makes it unlawful to retaliate or discriminate against any person or employee who makes a claim for overtime wages, including participating in any class or collective action to recover overtime wages.

Thank you for taking the time to read this letter, and please feel free to contact myself or one of our attorneys to discuss your work experience. We can be reached at mlf@feldmanlegal.us; jquintus@feldmanlegal.us, the main office or by cell phone 813 906 8932.