If you are a current or former exotic dancer at Crazy Horse III Gentleman’s Club in Las Vegas, you may be eligible to participate in a lawsuit asserting wage claims under the Fair Labor Standards Act (FLSA). NOTICE OF YOUR RIGHT TO “OPT-IN” TO CLAIMS
BROUGHT UNDER THE FLSA AGAINST Russell Road Food and Beverage, LLC dba Crazy Horse III Gentlemen’s ClubUnited States District Court for the District of Nevada
Desio v. Russell Road Food and Beverage, LLC d/b/a Crazy Horse III Gentlemen’s Club et al.
CIV. CASE NO. 2:2015-cv-01440-GMN-CWH August 7, 2018
Dear current or former exotic dancer of Crazy Horse III Gentlemen’s Club:
Enclosed is a consent form allowing you to “opt-in” to participate in a case that has been filed by Diane Desio, who performed as an exotic dancer for Russell Road Food and Beverage, LLC dba Crazy Horse III Gentlemen’s Club (“Crazy Horse III”) in Las Vegas and was classified as an independent contractor. This case has been brought on behalf of individuals who performed as exotic dancers for Crazy Horse III, were classified as independent contractors, and were not paid any wages, at any time since January 2014.
According to the Defendants’ records, you may be eligible to participate in this case because you have performed as an exotic dancer at Crazy Horse III at any time since January 2, 2014 and were classified as an independent contractor. In order to participate in the case, and obtain a portion of any judgment or settlement that may be entered in the exotic dancers’ favor, you must complete and return this consent form to the address below by no later than October 6, 2018.
In this lawsuit, the Plaintiff alleges that Crazy Horse III violated the federal Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 201 et seq., by improperly classifying its exotic dancers as independent contractors, and, as a result, has failed to pay them minimum wage compensation, and has unlawfully required them to “tip out” Crazy Horse III employees. The Defendant denies all of the allegations brought by Plaintiff, and contends that all exotic dancers were independent contractors
The case is at an early stage, and there has not been a decision by the court as to whether the Plaintiff’s position or Defendants’ position is the correct one. There has also not been any settlement reached. If you do not return the enclosed consent form by October 6, 2018, and if a settlement or judgment is obtained in the future, you will not be considered part of this case and will be unable to receive a share of any settlement or judgment that the plaintiffs may obtain. If you do participate in the case, you will be bound by any ruling entered by the court or settlement reached by the parties. Ms. Desio, who initiated this case, will work with plaintiff’s counsel to make decisions regarding the progress of this litigation, and we welcome your input as well into those decisions. You may also be asked to be a witness or to provide evidence in the case, although not all individuals who submit a consent form will be required to do so.
Again, to join this case, you must return the enclosed “opt-in” consent form by mail, e-mail or fax to the address below no later than October 6, 2018. In the meantime, if you have any questions, do not hesitate to contact Plaintiff’s counsel at the phone number or e-mails provided below:
Shannon Liss-Riordan
Harold Lichten
Matthew Thomson
LICHTEN & LISS-RIORDAN, P.C.
729 Boylston Street, Suite 2000
Boston, MA 02116
(617) 994-5800
[email protected]
[email protected]
www.llrlaw.com
Robert Starr
Adam Rose
LAW OFFICE OF ROBERT L. STARR
23901 Calabasas Road, #2072
Calabasas, CA 91302
(81 225-9040
[email protected]
Please do not contact the court; you may contact the counsel listed above with any question you have.
Yours truly,
Shannon Liss-Riordan
Robert Starr
You can also download a copy of the opt-in form by clicking here. |
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