NOTICE OF PROPOSED CLASS ACTION ON BEHALF OF NON-EXEMPT (NON-MANAGEMENT) EMPLOYEES AGAINST TRANSDEV

Dear Former or Current Non-Exempt Transdev Employee:

You have received this letter because you are believed to be one of thousands of non-exempt (i.e. non-management) employees on whose behalf a proposed class action lawsuit has been filed against Transdev Services, Inc. (referred to collectively below as Transdev).

BACKGROUND OF LAWSUIT

On February 27, 2023, a proposed class action lawsuit was filed in the United States District Court, District of San Diego, by a former non-exempt employee (the “Class Representative”) employed by Transdev. The lawsuit is proposed as a class action on behalf all current and former non-exempt employees who worked for Transdev at any time during the period of February 27, 2019 to the final date of the disposition of the action, up to and including the present (the “Class Members”). (Lovejoy v.., U.S.D.C., S.D. Case No.: 3:23-cv-00380-AJB-MDD) (the "Lovejoy Action"). The lawsuit claims that Transdev systematically violated bus operators’ rights under the California Labor Code by failing to pay them for actual hours worked and instead paying them based on hours Transdev estimated its employees should work according to routes (i.e., paddles, manifests) assigned to the bus operators, resulting in bus operators consistently working off the clock before, during, and after shifts. Additionally, the lawsuit claims that Transdev did not build in the ability for bus operators to take legally adequate meal and rest breaks into the routes they assigned to Plaintiff and putative class members. You can obtain more detailed information regarding the evolution of the lawsuit at the website dedicated to the proposed class action: www.ushealthworkslawsuit.com.

In the proposed Class Action, the proposed Class Representative alleges that Transdev committed and continue to commit unlawful labor practices in the State of California by:

• Failing/failed to pay the non-exempt employees all of their earned minimum wages, regular rate wages, and overtime wages (by not recording all time worked, etc.);
• Failing/failed to provide the non-exempt employees accurate and lawful wage statements-pay stubs;
• Transdev failed/fails to timely pay all earned minimum wages, regular rate wages, and overtime wages when the employees' employment ended;
• Failing/failed to authorize and permit the non-exempt employees to take paid 10 consecutive minute, uninterrupted, rest periods, relieved of all job duties, for shifts worked in excess of 4 hours or a second rest period for shifts in excess of 6 hours;
• Failing/failed to provide the non-exempt employees the opportunity to take 30 consecutive minute, uninterrupted, meal periods, relieved of all job duties, for shifts worked in excess of 5 hours or a second meal period for shifts in excess of 10 hours;
• Engaging in unfair business practices; and
• As that a consequence of these alleged violations of the California Labor Code, civil penalties should be imposed upon Transdev pursuant to the Private Attorneys General Act (“PAGA”).

The lawsuit seeks to recover money from Transdev, including unpaid minimum wages, regular rate wages, overtime, premium compensation, liquidated damages, statutory and civil penalties, attorneys fees and costs, for all proposed Class Members at any time during the class period who experienced one or more of the Labor Code violations listed above, alleged to have been committed by Transdev. Moreover, through the lawsuit, the proposed Class Representative seeks an injunction to prevent Transdev from continuing to engage in unlawful and unfair business practices.

THE ATTORNEYS WHO SEEK TO REPRESENT THE PROPOSED CLASS ARE:

To assist in their investigation, the attorneys who represent the non-exempt (non-management) Transdev employees are trying to gather information regarding Transdev’s policies and practices concerning: documenting hours worked, calculating and paying all earned wages, including minimum wage, regular rate wages and overtime wages; the accuracy of pay stubs; and whether valid rest periods were permitted and valid meal periods provided.

The attorneys who represent Transdev’s former and current non-exempt (non-management) employees would like to speak with you to assist in their investigation in order to recover the money potentially due and owing you. Any and all information you provide will be kept confidential. After you have read this letter, please call the attorneys to discuss what money Transdev may owe you.

Transdev may not retaliate against you in any way for providing any information to the attorneys. You make schedule a convenient date and time to speak with the attorneys, at absolutely no cost to you, at the website dedicated to this lawsuit: www.transdevlawsuit.com.

We are in the process of seeking approval from the Court to approve this lawsuit to proceed as a class action on your behalf. In connection with this effort, we continue to obtain declarations from many of your fellow proposed class members/coworkers, specifying Transdev’s unlawful labor policies and practices. Your assistance is critical to our efforts to seek certification of this lawsuit to proceed as a class action on your behalf. Should the Court certify this action, on behalf of you, as well as your fellow proposed class members/coworkers, we will seek to recover from Transdev the unpaid minimum wages, regular rate wages, overtime, premium compensation, liquidated damages, statutory and civil penalties, to which you are entitled.

Lastly, we believe Transdev management personnel and/or their attorneys may try to speak with you regarding this proposed Class Action lawsuit. You are under no obligation to talk to them. Transdev management personnel and/or their attorneys represent Transdev’s interests only. They do not represent you or have your best interests in mind. The questions they ask, and the answers you give them, are not confidential and, if you do pursue any claims, either by yourself or as part of this proposed Class Action lawsuit, Transdev may use the information you provide the employer’s attorneys against you.

Your assistance in our investigation of the claims against Transdev is critical to our ability to recover the money Transdev may owe you. Please contact any of the attorneys who propose to represent the former and current Transdev non-exempt (non-management) employees as soon as possible.

Thank You -
Proposed Class Counsel