Notice of Class & Collective Action
Settlement & Claims Process

A former employee (the "Plaintiff"), Richard Santana, has sued Another Broken Egg of America, LLC d/b/a Another Broken Egg ("Another Broken Egg" or the "Defendant"), alleging that he is entitled to damages for alleged wage and hour violations, including alleged improper notice of the use of the tip credit, violation of the side work regulations, and miscalculation of overtime. The Plaintiff filed the lawsuit including claims as a class action under the Florida Minimum Wage Act ("FMWA") and the Fair Labor Standards Act ("FLSA"). Another Broken Egg denies the Plaintiff's allegations and denies that anyone is entitled to any damages. To avoid the burden, expense, and uncertainty of continued litigation, the parties have agreed to a settlement, which has been preliminarily approved by the Court.

Under the Settlement, Another Broken Egg has agreed to pay up to a maximum settlement amount of $500,000.00 (the "Maximum Settlement Amount"), to be allocated among the Class and Collective Members, as well as to pay attorneys' fees, general release awards, litigation costs, employer-related taxes, and the expenses of administering the settlement. Under the allocation formula for the FMWA claim, you are estimated to receive a payment of $0.27 for every hour you worked at a tip-credit rate during the Relevant Period (March 26, 2019 to August 1, 2025). If you also opt into the Overtime Collective on your Claim Form, you may receive an estimated payment of $4.53 for every overtime hour worked during the Relevant Overtime Period (March 26, 2022 to August 1, 2025), based on the overtime hours Another Broken Egg's records verify. All settlement payments will be reported half on a W-2 and half on a 1099. To participate and receive a payment, you must return a properly completed Claim Form so that it is received or postmarked no later than August 14, 2026.

Your legal rights are affected, and you have a choice to make. Your options are explained below:

1. 1 Return the Claim Form and Receive a Payment. By timely returning a properly completed Claim Form, you will agree to participate in the FMWA settlement and receive your Florida class payment. Only if you also opt into the Overtime Collective on the Claim Form will you receive any overtime payment and release your federal FLSA claims. You may submit your Claim Form by U.S. Mail, in the enclosed pre-paid envelope, or online here or via the navigation menu above. Your Claim Form must be postmarked or otherwise received by August 14, 2026.
2. 2 Do Nothing. If you do not return the Claim Form but do not exclude yourself, you will remain part of the case but will receive no payment. Despite not receiving payment, you will still release your non-FLSA wage and hour claims against the Released Parties, as set forth in the Settlement Agreement.
3. 3 Exclude Yourself (Opt Out) by August 14, 2026. Submit a written request for exclusion to the Claims Administrator, postmarked or received no later than August 14, 2026. You will not receive a payment or recover anything under this settlement, but you will retain any rights you may have related to the claims in this case, subject to the applicable statute of limitations. If you exclude yourself, you may not object.
4. 4 Object by August 14, 2026. If you do not exclude yourself, you may write to the Court about why you do not like the settlement and ask to testify about its fairness. Your written objection must be submitted to the Claims Administrator and postmarked no later than August 14, 2026. The Court will hold a Final Approval Hearing on September 11, 2026 at 2:00 p.m. via Zoom (Meeting ID 160 0169 1761, Passcode 334775) to consider the settlement and any objections.

This notice summarizes the proposed settlement. For more information, visit the Important Documents tab for Court Documents or the Contact Us tab above to obtain information for the Claims Administrator or Class Counsel for this matter. If there is any discrepancy between this Notice and the Settlement Agreement, the Settlement Agreement will control.