UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

DYLAN HALL, on behalf of himself and others similarly situated,

v.

J. CAIAZZO PLUMBING & HEATING CORP. and MICHAEL CAIAZZO, in his individual and professional capacities.

Case No.: 1:21-cv-05416-ENV-SJB

NOTICE OF LAWSUIT

To: All current and former Plumbing Mechanics and Plumbing Helpers employed by J. Caiazzo Plumbing & Heating Corp. and Michael Caiazzo from September 29, 2018 to present.
1. Why did I get this notice?

You received this notice because records show that you worked for Defendants as a Plumbing Employee at any time from September 29, 2018 to today.

2. What is this lawsuit about?

This is a collective action lawsuit about whether Defendants failed to pay overtime wages and other wages to their Plumbing Employees.

In a collective action lawsuit, one or more Plaintiffs bring a lawsuit on behalf of others who have similar claims. The corporate entities and individual that are being sued are called the Defendants. The court resolves the issues for everyone who decides to join the case.

3. How do I join this lawsuit?

If you would like to join this case, you must sign and return the attached “Consent to Join Form” before March 29, 2022.

A prepaid return envelope is enclosed for your convenience. If you lost the return envelope, you could send the Consent to Join Form by mail, email, or fax to the information below:

Innessa M. Huot, Esq.
FARUQI & FARUQI, LLP
685 Third Avenue, 26th Floor
New York, NY 10017
Telephone: 212-983-9330

You may also email the Join Form to: ihuot@faruqilaw.com

You may also fax the Consent to Join Lawsuit form to: 212-983-9331.

If you do not return the Consent to Join Form by March 29, 2022, you may not be able to participate in this lawsuit

4. What happens if I join the lawsuit?

If you choose to join the case, you will be bound by any ruling, settlement, or judgment whether favorable or unfavorable. If there is a favorable resolution, you may be entitled to some portion of money that is recovered. However, if the lawsuit is not successful, you will also be bound by that result, and you will not receive any money in this case.

While this lawsuit is pending, you may be asked to provide oral or written discovery and/or testify at a deposition and/or trial in this matter. To join this lawsuit, you must sign and return the enclosed Join Form by March 29, 2022.

5. What happens if I do nothing?

If you do nothing, you will not be included in this case and this lawsuit will not affect your rights in any way. That means you will not be affected by any ruling, judgment, or settlement in this lawsuit and you will not share in any amounts recovered by Plaintiff if he gets an award or settlement in this case.

You have the right to hire your own attorney to file an independent lawsuit for you. However, if you hire your own attorney, you may be responsible for paying that attorney. You should also be aware that your federal claims are limited by a three-year statute of limitations (at most). Any delay in joining this action or proceeding separately may result in some or all of your claims expiring.

6. Will I have a lawyer in this case?

If you choose to join this case, you will be represented by:

Innessa M. Huot, Esq.
FARUQI & FARUQI, LLP
685 Third Avenue, 26th Floor
New York, NY 10017
Telephone: 212-983-9330
ihuot@faruqilaw.com

If Plaintiff is successful in recovering money in this case, attorneys’ fees and costs may be: (i) part of a settlement or money judgment obtained; (ii) ordered by the Court to be paid by Defendants; or (iii) may be a combination of both options.

If Plaintiff does not recover anything in this lawsuit, you will not have to pay any attorneys’ fees and costs.

7. Can I get in trouble for joining this case?

It is a violation of Federal and New York State law for Defendants to fire, discipline, discriminate, or retaliate against you for joining this case. Also, immigration status does not affect your entitlement to recover back wages or participate in the lawsuit. You have the right to participate in the action even if you are an undocumented immigrant.

If you believe you have been penalized, discriminated against, or disciplined in any way for receiving this Notice or joining this case—you may contact the lawyers in this case or any other lawyers of your choosing to learn more about your rights and legal protections.

8. What if I still have questions?

If you have any questions about this case, or would like more information, please contact:

Innessa M. Huot at (212) 983-9330 or ihuot@faruqilaw.com

PLEASE DO NOT CONTACT THE CLERK OF THE COURT WITH QUESTIONS INVOLVING THIS LAWSUIT.

Dated: January 28, 2022

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

DYLAN HALL, on behalf of himself and others similarly situated,

Plaintiff,

v.

J. CAIAZZO PLUMBING & HEATING CORP. and MICHAEL CAIAZZO, in his individual and professional capacities,

Defendants.

Case No.: 1:21-cv-05416-ENV-SJB

CONSENT TO JOIN

I, , consent to join the above-captioned lawsuit. I understand this lawsuit is brought under the Fair Labor Standards Act, pursuant to 29 U.S.C. §§ 201, et seq. I hereby consent, agree, and opt in to become a plaintiff in this action and to be bound by any judgment of the Court, or settlement reached by the named Plaintiff and Defendants, concerning unpaid wages, liquidated damages, attorneys’ fees, costs, and other relief arising out of my employment with Defendants. I have been employed by Defendants within the last three years.

I hereby appoint Faruqi & Faruqi, LLP, located at 685 Third Avenue, 26th Fl., New York, NY 10017, telephone number (212) 983-9330, as my attorneys. I authorize Faruqi & Faruqi, LLP to represent me in this action and to litigate this matter on my behalf.

Date 05/24/2022
Clear

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