Barker v. ITL Foods, LP dba Pizza Hut

United States District Court, For The Southern District Of Texas

Case No: 4:22-cv-00342
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TO: All employees who worked as delivery drivers at any of the nineteen ITL Foods, LP’s Pizza Hut franchises in the Dallas Metroplex area at any time since February 2, 2019, and were paid a vehicle expense reimbursement for using their own vehicles for deliveries.

You received this Notice because the Court in charge of this lawsuit has ordered this Notice be sent to persons who are identified by ITL Foods, L.P.’s records as current or former delivery drivers at one of their nineteen Pizza Hut locations throughout the Dallas Metroplex since February 2, 2019.

The Court has allowed or conditionally “certified” a collective action lawsuit that may affect you.

WHAT IS THIS LAWSUIT ABOUT

A Pizza Hut delivery driver who worked for ITL Foods, L.P. at a location in the Dallas Metroplex, Adam Barker, filed this lawsuit on behalf of himself and other current and former delivery drivers, alleging that they were paid less than minimum wage under the FLSA in light of the costs and expenses incurred by using their personal vehicle for deliveries.

The delivery driver alleges he and other delivery drivers are entitled to recover lost wages from ITL Foods, L.P. because he alleges ITL Foods, L.P. failed to pay a mileage reimbursement rate that fully compensates delivery drivers for all of their vehicle related expenses, causing their wages to fall below the federal minimum wage during some or all workweeks. ITL Foods, L.P. vehemently denies the delivery driver’s allegations.

Please refer to the NOTICE TO CLASS MEMBERS to advise you of how your rights under the FLSA may be affected by this case and describe how to participate in this case if you want to.

Important Dates

• Initial Mailing, Emailing and Text Notice: October 31, 2023
• Consent To Join Deadline: December 30, 2023

YOU CAN GET MORE INFORMATION BY CALLING OR EMAILING THE DELIVERY DRIVER’S ATTORNEYS:

C. Ryan Morgan, Esq.
Email: RMorgan@forthepeople.com
Jolie N. Pavlos, Esq.
Email: JPavlos@forthepeople.com
MORGAN & MORGAN, P.A.
20 N. Orange Ave., 15th Floor
P.O. Box 4979
Orlando, FL 32802-4979
Telephone: (407) 418-2069 (C. Ryan Morgan)
Telephone: (407) 245-3517 (Jolie N. Pavlos)
Facsimile: (407) 245-3401