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Contract analysis / email-crawford-to-bowman-epl-tender.eml
email-crawford-to-bowman-epl-tender.eml
High · 2
Medium · 1
Standard · 0
1. Failure to pay overtime compensation at one-and-one-half times the regular rate of pay
1. Failure to pay overtime compensation at one-and-one-half times the regular rate of pay for hours worked in excess of 40 per workweek;
2. Illegal automatic meal-break deductions of 30 minutes per shift despite employees alleg
2. Illegal automatic meal-break deductions of 30 minutes per shift despite employees allegedly being required to remain on-call during those periods;
3. Failure to compensate employees for pre-shift and post-shift work, including donning an
3. Failure to compensate employees for pre-shift and post-shift work, including donning and doffing uniforms, booting up point-of-sale and reservation systems, and attending shift-handover briefings, estimated at approximately 15 to 25 minutes per shift;
4. Failure to pay the applicable Florida minimum wage for tipped employees in certain fron
4. Failure to pay the applicable Florida minimum wage for tipped employees in certain front-desk and concierge roles participating in tip pools; and
5. Alleged misclassification of certain "lead" and "senior" hourly roles as exempt under t
High
⚑ Penalty / liquidated damages
5. Alleged misclassification of certain "lead" and "senior" hourly roles as exempt under the FLSA administrative exemption. The putative class and collective is described in the demand letter as encompassing all current and former hourly, non-exempt employees at Verimark-branded properties in Florida from January 2023 to the present, with an estimated class size of 4,100 to 5,900 individuals. The demand letter seeks
1. That Pinnacle acknowledge receipt of this notice and the attached tender letter at your
1. That Pinnacle acknowledge receipt of this notice and the attached tender letter at your earliest convenience;
2. That Pinnacle assign a claim number to this matter and identify a coverage counsel cont
2. That Pinnacle assign a claim number to this matter and identify a coverage counsel contact, if applicable;
3. That Pinnacle provide its initial coverage position, including any reservation of right
3. That Pinnacle provide its initial coverage position, including any reservation of rights, within a reasonable period; and
4. We remain available to provide any additional information or documentation that Pinnacl
4. We remain available to provide any additional information or documentation that Pinnacle may require to evaluate this claim. **Contact Information** Please direct all correspondence regarding this matter to the undersigned at: Calderwood & Harkness LLP 100 Southeast Second Street, Suite 3400 Miami, Florida 33131 Telephone: (305) 814-7200 Email: bcrawford@calderwoodharkness.com VHG's General Counsel, Devin K. Arroy
1. Notice of Claim / Tender Letter, dated February 7, 2026 (executed)
Medium
⚑ Notice / time limit to track
1. Notice of Claim / Tender Letter, dated February 7, 2026 (executed)
2. Demand Letter from Garza, Linden & Okafor LLP, dated January 14, 2026
High
⚑ Non-compete / exclusivity restraint
2. Demand Letter from Garza, Linden & Okafor LLP, dated January 14, 2026 --- CONFIDENTIALITY NOTICE: This email message, including any attachments, is sent by Calderwood & Harkness LLP and may contain information that is privileged, confidential, and/or protected by the attorney-client privilege or the attorney work-product doctrine. It is intended exclusively for the use of the individual(s) or entity named above. I