A former driver, Plaintiff Phillip Daniel, has sued Stericycle, Inc. and Shred-it USA, LLC, alleging that he and other
drivers/customer service representatives were subject to automatic lunch break deductions and not paid correctly for
all hours worked, including alleged unpaid overtime pay, in violation of the FLSA and NCWHA. Based on these
allegations, Plaintiff Daniel has sought to recover unpaid wages, liquidated damages, pre- and post-judgment
interest, and attorneys’ fees, costs, and expenses.
Defendants dispute these claims and have defended against the lawsuit. Defendants deny the allegations made by Plaintiff Daniel in the case, assert that drivers
and customer service representatives in North Carolina were paid for all hours worked, and deny that their pay practices violated the law in any way. Without
admitting any liability, the Defendants have agreed to settle these claims to avoid further litigation.
Certain individuals received Notice of this proposed settlement because records indicate they were employed in North Carolina by Stericycle,
Inc. and/or Shred-it USA, LLC as a driver or customer service representative between November 24, 2018,
and February 25, 2023, and are not subject to an arbitration agreement.
WHO IS INCLUDED IN THE PROPOSED SETTLEMENT?
The proposed Settlement includes two groups of individuals who will be able to receive payment from the
Settlement if they do not opt out of the settlement by requesting exclusion:
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FLSA Opt-In Plaintiffs: The FLSA Opt-In Plaintiffs are eleven (11) individuals, including Plaintiff
Daniel, who previously filed a consent form to join this case as party-plaintiffs prior to the execution of the
Parties’ Settlement Agreement.
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Putative Rule 23 Settlement Class Members: All non-exempt drivers or customer service representatives
who were employed by Defendants in North Carolina at any time from November 24, 2018, through
February 25, 2023, and who are not subject to an arbitration agreement.