NOTICE OF SETTLEMENT OF UNPAID WAGE LAWSUIT INVOLVING TRULIEVE ASSISTANT GENERAL MANAGERS
A court authorized this Notice. This is not a solicitation from a lawyer.
- A settlement has been entered to resolve a lawsuit on behalf of current or former exempt-classified and salary-paid Assistant General Managers (referred to in this Notice as “AGMs”) at Trulieve.
- On November 7, 2024, Plaintiff filed a lawsuit seeking alleged unpaid wages for exempt-classified AGMs. The lawsuit claimed Trulieve should have paid AGMs on an hourly basis and paid them overtime wages. Trulieve denies the allegations in the lawsuit. Trulieve claims that the AGMs were properly classified and paid as salaried, exempt employees in accordance with the law, and that overtime wages are not owed.
- This Notice describes important terms of the Joint Stipulation of Collective Action Settlement and Release (“Agreement”). You are receiving this Notice because Trulieve’s records indicate you worked as an exempt-classified AGM for at least one week between February 13, 2022 and September 1, 2024 (the “Collective Period”), in the state of Arizona, Florida, Georgia, Maryland, Pennsylvania and/or West Virginia, and are not believed to have signed an arbitration agreement with a waiver to participate in a class/collective and/or judicial action.
- You may participate in the Settlement by submitting the enclosed Claim Form and Release by April 25, 2025.
- If you participate in the Settlement, you will receive a settlement payment of $________, which is based on the number of weeks you worked as a salaried, exempt AGM for Trulieve during the Collective Period. Half of your payment will be subject to deductions for payroll taxes and other legally required withholdings. The other half of your payment will be treated as non-wage income.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:
SEND IN THE ENCLOSED CLAIM FORM AND RELEASE
Receive a settlement payment. Give up certain overtime claims. By completing the enclosed Claim Form and Release and sending it to the proper address by April 25, 2025, you will be paid the amount described above and you will be bound by the Judgment entered by the Court. You will also give up the right to sue Trulieve for claims arising from the facts alleged in the Lawsuit.
DO NOTHING
You do not give up any rights; however, you will not receive any payment under the settlement.
What is this lawsuit and who is involved?
In this Lawsuit, former AGMs allege they worked more than 40 hours per week but were not paid overtime wages. Rather, they claim that they were only paid a salary and that they are owed overtime wages for the hours they worked above 40 in a workweek. Plaintiff brought the case as a collective action on behalf of all AGMs who worked for Trulieve within the Collective Period.
Trulieve denies these allegations and contends that all AGMs were properly compensated for all hours worked and were not eligible for overtime pay.
The Parties agreed to settle the disputed claims. The Court has not made any determination as to the merits of Plaintiff’s alleged claims or as to Trulieve’s defenses.
How do I receive a settlement payment?
You must complete and return the enclosed Claim Form and Release to the Claims Administrator. A pre-paid envelope is enclosed for you to use to submit the Claim Form and Release.
You may also send the completed Claim Form and Release by e-mail at info@TrulieveAGMSettlement.com or by fax to 516-842-5402.
You can also go to TrulieveAGMSettlement.com to submit your Claim Form and Release.
If you lose the pre-paid envelope, you may mail the completed Claim Form and Release to
Trulieve Cannabis Corp. Assistant General Manager Settlement
c/o Arden Claims Service LLC
PO Box 1015
Port Washington, NY 11050
Tel: 516-347-2030 | Fax: 516-842-5402
E-mail: info@TrulieveAGMSettlement.com
Website: TrulieveAGMSettlement.com
Your payment will be sent to you directly at the address to which this Notice was sent. If your address changes, please call 516-347-2030. It is your responsibility to keep an updated address on file with the Claims Administrator.
What am I giving up in exchange for a settlement payment?
Once you submit your Claim Form and are sent a payment, you cannot sue Trulieve or any of the Released Parties for claims asserted or which could have been asserted in the Lawsuit for unpaid wages that accrued during your employment as an exempt-classified AGM during the Collective Period, and relating back three years (September 1, 2021 through September 1, 2024). The release of claims also includes all state and federal claims for unpaid overtime wages, and related claims for penalties, interest, liquidated damages, attorneys’ fees, costs, and expenses.
You will be forever barred (individually, as a representative member of any class, and through any collective proceedings) from filing any civil action, lawsuit, grievance, demand for arbitration, charge, claim, and/or administrative complaint against Trulieve or any of the Released Parties, based upon or arising out of, or related to, any such claims.
Can I get more information about the Settlement?
If you would like more information about the Settlement, you may contact the Settlement Administrator, Arden Claims Service, at:
Trulieve Cannabis Corp. Assistant General Manager Settlement
c/o Arden Claims Service LLC
PO Box 1015
Port Washington, NY 11050
Tel: 516-347-2030 | Fax: 516-842-5402
E-mail: info@TrulieveAGMSettlement.com
Website: TrulieveAGMSettlement.com
Who are the attorneys who represent the Named Plaintiff?
The Shavitz Law Group, P.A. represents the Named Plaintiff and have negotiated the settlement terms. As part of the Settlement, the firm will be paid one-third of the Settlement to compensate them for their attorneys’ fees, plus their outof- pocket costs and expenses, for litigating and settling the Lawsuit. You will not have to pay the attorneys any of their fees, costs or expenses. You may contact the Shavitz Law Group, P.A. with any questions about this settlement at info@shavitzlaw.com or 800- 616-4000.
Mail:
Trulieve Cannabis Corp. Assistant General Manager Settlement
c/o Arden Claims Service LLC
PO Box 1015
Port Washington, NY 11050
Tel: 516-347-2030
Fax: 516-842-5402
E-mail: info@TrulieveAGMSettlement.com
Website: TrulieveAGMSettlement.com
Important Dates
Opt-in Deadline
Date: April 25, 2025