Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / statute-of-limitations-memo.docx
statute-of-limitations-memo.docx
Parties
Harkness LLP
Verimark Hospitality Group Inc
Okafor LLP
M. Serrano
Luminos Payroll Solutions Inc
Palomar Realty Partners LLC
Hoffmann-La Roche Inc
Ridgepoint Advisory Group LLC
Dates
February 8, 2026
January 14, 2026
January 14, 2021
January 1, 2022
January 1, 2021
January 17, 2026
January 16, 2026
March 14, 2022
August 22, 2025
February 28, 2026
Amounts
$18.5
$14.00
$10.98
$3.02
$85,000
$120,000
$8.25
$16.50
$4,073,850
$8,147,700
Obligations
This creates a data-collection challenge, as records from VHG's prior payroll system for the period January 2021 through December 2021 must be located, preserved, and reviewed
The transition to Luminos TimeTrack is significant for this analysis because the five-year Florida lookback period extends into a period (January 2021 through December 2021) during which VHG utilized a different payroll processing system, the identity and record-retention practices of which must be verified
Using January 14, 2026 as the reference date for purposes of preliminary scoping, the relevant lookback dates under each potentially applicable limitations period are as follows: An important caveat must be noted regarding the use of the demand letter date as a reference point
The employer need not prove that it acted in good faith; rather, the plaintiff must affirmatively establish that the employer knew or recklessly disregarded the law's requirements
In a Rule 23 class action, class members are automatically included in the class and bound by the judgment unless they affirmatively opt out; in an FLSA collective action, individuals must affirmatively opt in
Each paycheck is a discrete event, and any claim based on that paycheck must be brought within the applicable limitations period measured from the date of that paycheck