Benoit V HGS Consent to Join Form

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

COLE BENOIT,
individually and on behalf of all others similarly situated,
Plaintiffs,
v.
HINDUJA GLOBAL SOLUTIONS, LLC
and HGS (USA), LLC.
Defendants.

Case No: 1:24-cv-11627
Hon. Jeremy C. Daniel
Mag. Gabriel A. Fuentes

CONSENT TO JOIN

1. Pursuant to the Fair Labor Standards Act, 29 U.S.C. §216(b), I hereby consent to join and act as a plaintiff in the above-captioned lawsuit.

2. I worked for Hinduja Global Solutions, LLC and HGS (USA), LLC as a remote customer service representative and I agree to be bound by any adjudication or court rulings in this Lawsuit, whether favorable or unfavorable. I understand that reasonable costs expended by Plaintiff’s Counsel on my behalf will be deducted from any settlement or judgment amount on a pro-rata basis among all other plaintiffs. I understand that Plaintiff’s Counsel will petition the Court for an award of attorneys’ fees from any settlement or judgment.

3. I hereby designate the Sommers Schwartz, P.C. law firm to represent me in this Lawsuit.

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Additional Terms & Information

Section 216(b) of the Fair Labor Standards Act, 29 U.S.C. §216(b), encourages employees to band together to enforce their rights to minimum wages and overtime pay.

It is illegal for an employer to retaliate against an individual for exercising his or her rights (such as by participating in this lawsuit, or by submitting this document, or talking to attorneys about his or her rights to full compensation for work performed).

Unless you retain other legal counsel, at your own expense, you will be represented in this class / collective action lawsuit by Sommers Schwartz, P.C. (“class counsel”). No prepayment of legal fees or costs is required. If the class or collective action is later de-certified, class counsel will inform you of your options; and class counsel may ask you to enter into a separate written retainer agreement at that time.

By joining this Lawsuit, you agree to stay in contact with class counsel throughout the pendency of the Lawsuit and to provide timely assistance to the attorneys and their staff, including preserving and providing documents and discovery responses, returning phone calls and emails, and testifying at depositions and trial. Please advise class counsel immediately of any change of address or employment; any bankruptcy filing; or any criminal conviction.

Attorneys shall be entitled to no fee unless awarded/approved by the court. In addition, any costs advanced by class counsel may be deducted from any amount you receive on a pro rata basis with all other plaintiffs.

Whether you have a claim or are entitled to damages cannot be determined until we review your information and employment history. Class counsel makes no guarantees or representations about the probable outcome of this Lawsuit.

If you ever have questions or need to talk to Class Counsel, we can be contacted as follows:

Kevin J. Stoops, Esq.
One Towne Square, Floor 17
Southfield, Michigan 48076
(248) 355-0300
[email protected]

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