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Filing # 124123096 E-Filed 03/31/2021 04:12:14 PM
IN THE CIRCUIT COURT OF THE
SEVENTH JUDICIAL CIRCUIT
IN AND FOR
FLAGLER COUNTY, FLORIDA
CASE NO.: 2017-CA-000537
IRENE MAYER, individually and on
behalf of others similarly situated,
Plaintiff,
Vv.
PERFECT PIZZA PIE, INC., a Florida
Corporation,
Defendant.
NOTICE OF FILING
Plaintiff, IRENE MAYER, hereby gives this Court notice of filing the
attached Exhibit referenced by Plaintiff's counsel at the March 31, 2021 hearing on
Plaintiff's Motion for Class Certification (Exhibit “A”).
DATED this 31st day of March, 2021.
/s/ C. RYAN MORGAN
C. Ryan Morgan, Esq.
FBN 0015527
Morgan & Morgan, P.A.
20 N. Orange Ave., 15th Floor
P.O. Box 4979
Orlando, FL 32802-4979
Telephone: (407) 420-1414
Facsimile: (407) 245-3401
Email: RMorgan@forthepeople.com
Attorneys for Plaintitf
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 04/01/2021 09:54 AM
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 31, 2021, a true and correct copy of the
foregoing has been filed with the Clerk of the Court using the E-Portal Filing System,
which will serve the following counsel of record via E-mail: Adam G. Prom, Esq.,
HALL BOOTH SMITH, P.C., BB&T Tower 200 W. Forsyth Street, Suite 400,
Jacksonville, FL 32202, E-mail: aprom@hallboothsmith.com, Attorney for Defendant.
/s/ C. RYAN MORGAN
C. Ryan Morgan, Esq.
EXHIBIT “A”
Aen RS SA RAS ASHER
From: orThePeople.com"
Date: Mon May 22 15:38:00 EDT 2017
RMorgan “orThePeople.com"
Cc
"Claudia a"
Subject: LEGAL ADVERTISEMENT: Pizza Delivery Driver Reimbursement Claims
RAFT LEGAL ADVERTE M Pak
Re Pizza Delivery Driver Reimbursement Claim:
Greetings
If you have already retained a lawyer for this matter, please disregard this letter.
You are Teceiving this letter because you are either a current or former client of Morgan and Morgan and
worked for a national pizza chain. My name is Ryan Morgan and | am an attorney with Morgan and Morgan
and am co-chair of the Employee Rights Group for the firm. I am writing to inform you of potential claims you
may have if you worked for a pizza chain as a delivery driver in the last few years. Our firm has investigated
and prosecuted several individual and class actions claims on behalf of delivery drivers against some of the
large, national pizza chains. as well as local, franchisee chains. Specifically, the claim is that some of the pizza
chains have failed to properly reimburse their drivers a sufficient amount to pay them the minimum wage. Our
investigation and research shows that in some situations, the drivers incurred more in automobile expenses
(such as gas, maintenance, insurance and depreciation) than they actually received by the pizza companie in
reimbursement pay. If true, such a practice often violates state and federal wage law. If successful. each driver
would be entitled to additional compensation to reimburse them for these expenses
As part of our investigation into these allegations,
your name has been identified from our database as
someone who worked for a national pizza chain. If you did and you worked as a del y driver, you may have
a viable claim for additional compensation from your employer as described above. To the extent that you have
any knowledge or information on these allegations in any way. or wish to bring your own claim, we are asking
that you contact us to discuss the same. You are under no obligation at all to respond to this letter or contact us
i
even if you have information. Regardless of your decision, you should know that federal and state law has strict
time limitations for any employee who wishes to pursue these types of claims for unpaid wages.
Thank you for taking the time to read this letter. If you would like to discuss a claim, have any
information you would like to share, or simply need additional information from us before disclosing any
information, please feel free to respond to this letter, Alternatively, you can contact me by telephone if you do
not wish to email by dialing, toll free, 800-454-6825, or my direct number 407-418-2069, or by email
rmorgan@forthepeople.com.
Morgan & Morgan has a team of lawyers dedicated to representing employees in wage and hour
actions. Morgan & Morgan has litigated hundreds of cases for unpaid wages per year involving thousands of
employees across the nation including collective actions similar to this case. The undersigned attorney, C Ryan
Morgan, has been practicing law since 2005 and has also been appointed class counsel in similar cl s and
collective actions. For more information on the firm, Mr. Morgan, current casi and past results, please visit
www. forthepeople.com.
Sincerely,
C. Ryan Morgan, Esq.
Morgan & Morgan, P.A.
20 North Orange Avenue, 14th Floor
P.O. Box 4979
Orlando, FL 32802-4979
Phone: (407) 420-1414
Direct Dial: (407) 418-2069
Fax: (407) 245-3404
fmorgan@forthepeople.com
Visit us online at http://www. forthepeopie.com
‘It MORGAN & MORGAN
Pair Ovi
Bisse anontbire [Cr oa
ATs CRORE
mic} TUSU RANA | YSTEA,
Ryan Morgan
Attorney
My Bio
: (407) 418-2069
F: (407) 245-3401
A: 20.N Orange Ave, Suite 1600, Orlando, FL 32801
MORGAN & MORGAN
HE PEOPLE,
pRachceaneas | rocations FORNEYS iL resucrs |
A referral is the best compliment. if you know anyone that needs our help, please have them call our office 24/7.
CONFIDENTIALITY NOTICE: This e-mail message including attachments, if any, is intended for the person or entity to
which it is addressed and may contain confidential and/or privileged material. Any unauthorized review, use. disclosure or
distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all
copies of the original message, Thank you.
From: Igiguru@aol.com [mailto:lgiquru@aol.com}
Sent: Tuesday, July 18, 2017 12:06 PM
To: Ryan Morgan x5028
Subject: Pizza Delivery Drivers Class Action
Hello Attorney Morgan,
Thank you for your letter inviting me to join the class action regarding pizza delivery drivers. | worked for Domino's
(Perfect Pizza Pie, Inc.) in Palm Coast, Florida from January of 2015 to July, 2016. | also worked for Papa John's (PJ
United, Inc.) from Nov 2016 to March 2017, in Palm Coast, resulting in extensive wear and tear on my vehicle, not to
mention the cost of tires, oil changes and any damages my car encountered from poorly maintained driveways and
careless drivers while being paid $1.20 or $1.40 per delivery, at $5.00 an hour.
One experience, in particular, from Domino's, Perfect Pizza Pie, Inc.was their decision to increase the delivery charge for
customers 10 cents, and neglecting to inform the drivers. Their lack of respect for us was disturbing, These business’
have no problem “giving the store away” to unhappy customers (Oh, not enough mushrooms on your pizza? That's oka’
here is a $10 credit for your next order.) off the backs of their bi jest assets, the delivery drivers.
Pizza delivery drivers are the driving force for the profits of these highly successful business’ and we are treated with
complete and utter disregard. They do not respect us. | believe it is time we are fairly compensated for the fiscal and
physical sacrifices we make for them.
Thank you very much. | look forward to working with you.
irene Mayer
CONFIDENTIALITY NOTICE: This e-mail message including attachments, if any, is intended for the person or entity to
which it is addressed and may contain confidential and/or privileged material. Any unauthorized review, use, disclosure or
distribution is prohibited. If you are not the intended recipient, please coritact the sender by reply e-mail and destroy all
copies of the original message. Thank you.
Preview
Filing # 124123096 E-Filed 03/31/2021 04:12:14 PM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.: 2017-CA-000537 IRENE MAYER, individually and on behalf of others similarly situated, Plaintiff, Vv. PERFECT PIZZA PIE, INC., a Florida Corporation, Defendant. NOTICE OF FILING Plaintiff, IRENE MAYER, hereby gives this Court notice of filing the attached Exhibit referenced by Plaintiff's counsel at the March 31, 2021 hearing on Plaintiff's Motion for Class Certification (Exhibit “A”). DATED this 31st day of March, 2021. /s/ C. RYAN MORGAN C. Ryan Morgan, Esq. FBN 0015527 Morgan & Morgan, P.A. 20 N. Orange Ave., 15th Floor P.O. Box 4979 Orlando, FL 32802-4979 Telephone: (407) 420-1414 Facsimile: (407) 245-3401 Email: RMorgan@forthepeople.com Attorneys for Plaintitf Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 04/01/2021 09:54 AM CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 31, 2021, a true and correct copy of the foregoing has been filed with the Clerk of the Court using the E-Portal Filing System, which will serve the following counsel of record via E-mail: Adam G. Prom, Esq., HALL BOOTH SMITH, P.C., BB&T Tower 200 W. Forsyth Street, Suite 400, Jacksonville, FL 32202, E-mail: aprom@hallboothsmith.com, Attorney for Defendant. /s/ C. RYAN MORGAN C. Ryan Morgan, Esq. EXHIBIT “A” Aen RS SA RAS ASHER From: orThePeople.com" Date: Mon May 22 15:38:00 EDT 2017 RMorgan “orThePeople.com" Cc "Claudia a" Subject: LEGAL ADVERTISEMENT: Pizza Delivery Driver Reimbursement Claims RAFT LEGAL ADVERTE M Pak Re Pizza Delivery Driver Reimbursement Claim: Greetings If you have already retained a lawyer for this matter, please disregard this letter. You are Teceiving this letter because you are either a current or former client of Morgan and Morgan and worked for a national pizza chain. My name is Ryan Morgan and | am an attorney with Morgan and Morgan and am co-chair of the Employee Rights Group for the firm. I am writing to inform you of potential claims you may have if you worked for a pizza chain as a delivery driver in the last few years. Our firm has investigated and prosecuted several individual and class actions claims on behalf of delivery drivers against some of the large, national pizza chains. as well as local, franchisee chains. Specifically, the claim is that some of the pizza chains have failed to properly reimburse their drivers a sufficient amount to pay them the minimum wage. Our investigation and research shows that in some situations, the drivers incurred more in automobile expenses (such as gas, maintenance, insurance and depreciation) than they actually received by the pizza companie in reimbursement pay. If true, such a practice often violates state and federal wage law. If successful. each driver would be entitled to additional compensation to reimburse them for these expenses As part of our investigation into these allegations, your name has been identified from our database as someone who worked for a national pizza chain. If you did and you worked as a del y driver, you may have a viable claim for additional compensation from your employer as described above. To the extent that you have any knowledge or information on these allegations in any way. or wish to bring your own claim, we are asking that you contact us to discuss the same. You are under no obligation at all to respond to this letter or contact us i even if you have information. Regardless of your decision, you should know that federal and state law has strict time limitations for any employee who wishes to pursue these types of claims for unpaid wages. Thank you for taking the time to read this letter. If you would like to discuss a claim, have any information you would like to share, or simply need additional information from us before disclosing any information, please feel free to respond to this letter, Alternatively, you can contact me by telephone if you do not wish to email by dialing, toll free, 800-454-6825, or my direct number 407-418-2069, or by email rmorgan@forthepeople.com. Morgan & Morgan has a team of lawyers dedicated to representing employees in wage and hour actions. Morgan & Morgan has litigated hundreds of cases for unpaid wages per year involving thousands of employees across the nation including collective actions similar to this case. The undersigned attorney, C Ryan Morgan, has been practicing law since 2005 and has also been appointed class counsel in similar cl s and collective actions. For more information on the firm, Mr. Morgan, current casi and past results, please visit www. forthepeople.com. Sincerely, C. Ryan Morgan, Esq. Morgan & Morgan, P.A. 20 North Orange Avenue, 14th Floor P.O. Box 4979 Orlando, FL 32802-4979 Phone: (407) 420-1414 Direct Dial: (407) 418-2069 Fax: (407) 245-3404 fmorgan@forthepeople.com Visit us online at http://www. forthepeopie.com ‘It MORGAN & MORGAN Pair Ovi Bisse anontbire [Cr oa ATs CRORE mic} TUSU RANA | YSTEA, Ryan Morgan Attorney My Bio : (407) 418-2069 F: (407) 245-3401 A: 20.N Orange Ave, Suite 1600, Orlando, FL 32801 MORGAN & MORGAN HE PEOPLE, pRachceaneas | rocations FORNEYS iL resucrs | A referral is the best compliment. if you know anyone that needs our help, please have them call our office 24/7. CONFIDENTIALITY NOTICE: This e-mail message including attachments, if any, is intended for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any unauthorized review, use. disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message, Thank you. From: Igiguru@aol.com [mailto:lgiquru@aol.com} Sent: Tuesday, July 18, 2017 12:06 PM To: Ryan Morgan x5028 Subject: Pizza Delivery Drivers Class Action Hello Attorney Morgan, Thank you for your letter inviting me to join the class action regarding pizza delivery drivers. | worked for Domino's (Perfect Pizza Pie, Inc.) in Palm Coast, Florida from January of 2015 to July, 2016. | also worked for Papa John's (PJ United, Inc.) from Nov 2016 to March 2017, in Palm Coast, resulting in extensive wear and tear on my vehicle, not to mention the cost of tires, oil changes and any damages my car encountered from poorly maintained driveways and careless drivers while being paid $1.20 or $1.40 per delivery, at $5.00 an hour. One experience, in particular, from Domino's, Perfect Pizza Pie, Inc.was their decision to increase the delivery charge for customers 10 cents, and neglecting to inform the drivers. Their lack of respect for us was disturbing, These business’ have no problem “giving the store away” to unhappy customers (Oh, not enough mushrooms on your pizza? That's oka’ here is a $10 credit for your next order.) off the backs of their bi jest assets, the delivery drivers. Pizza delivery drivers are the driving force for the profits of these highly successful business’ and we are treated with complete and utter disregard. They do not respect us. | believe it is time we are fairly compensated for the fiscal and physical sacrifices we make for them. Thank you very much. | look forward to working with you. irene Mayer CONFIDENTIALITY NOTICE: This e-mail message including attachments, if any, is intended for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please coritact the sender by reply e-mail and destroy all copies of the original message. Thank you.