Plaintiffs Theresa Egan, Brian Barker, and Sabrina Budden-Wright worked as travel nurses for defendant Fastaff. They filed a lawsuit on behalf of themselves and other similarly situated employees against Fastaff alleging, among other things, that the company violated the FLSA by excluding the value of their housing stipends from their “regular rate” of pay, and thus miscalculating their mandated overtime rate of pay. This alleged miscalculation resulted in underpayment of overtime wages, which the Plaintiffs seek to recover, among other things, in this lawsuit.

The Plaintiffs sought to represent similarly situated employees at Fastaff and to give them an opportunity to participate in the lawsuit by filing a Consent to Join Form. The Court entered an Order dated October 19, 2023, which is why you are receiving this Notice and being given the opportunity to join this lawsuit. You may receive this Notice and information about this lawsuit via U.S. Mail and email. The Court has not decided which side is right.

By conditionally certifying this lawsuit as a collective action and issuing this notice, the Court is not suggesting that the Plaintiffs will win or lose the case.

Individuals are eligible to participate if they are a member of the following group of people that the Court authorized to receive Notice and be given an opportunity to participate in this lawsuit:

All travel healthcare professionals currently or formerly employed by Fastaff or U.S. Nursing Corporation who (1) worked more than 40 hours in a workweek from February 16, 2020 until the date of the Court’s conditional certification order and (2) who received a “Housing Stipend” (or its equivalent by any other name) that was not included in their regular rate of pay during a workweek where they worked more than 40 hours.

The Plaintiffs are asking the Court to award them and similarly situated employees any unpaid overtime wages during the relevant time period, along with an additional amount as liquidated damages, pre-judgment and post-judgment interest, reasonable attorneys’ fees, and the costs of this action.

If you opt to join the collective, you will be represented by Plaintiffs’ counsel, who will commonly represent the interests of Plaintiffs, and all similarly situated employees that join this lawsuit. You do not have to separately pay Plaintiffs’ counsel. If the lawsuit results in a money judgment or settlement, Plaintiffs’ Counsel, at their option and depending on the circumstances, will seek their attorneys’ fees and costs as a percentage of the overall recovery, or to be separately paid by Fastaff, all subject to Court approval. You may alternatively choose to retain your own counsel or represent yourself. Plaintiffs’ Counsel are:

George A. Hanson
Alexander T. Ricke
Crystal Cook Leftridge
STUEVE SIEGEL HANSON LLP
460 Nichols Road, Suite 200
Kansas City, MO 64112