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SETTLEMENT AGREEMENT AND RELEASE

This Settlement Agreement and Release (“Agreement”) is entered into between Plaintiff, 

Annie Raines, on behalf of herself and others similarly situated, and Salo, Inc., d/b/a, Interim 

Healthcare and its related and affiliated entities, namely Salo, Inc., an Ohio corporation; Interim 

Healthcare of Akron/Canton, Inc., an Ohio corporation; Interim Healthcare of Cambridge, Inc., an 

Ohio corporation; Interim Healthcare of Cincinnati, Inc., an Ohio corporation; Interim Home 

Styles of Greater Cincinnati, Inc., an Ohio corporation; Interim Healthcare of SE Indiana, Inc., an 

Indiana corporation; Interim Healthcare of Columbus, Inc., an Ohio corporation; Interim 

Healthcare of Dayton, Inc., an Ohio corporation; Interim Healthcare of Northwestern, Ohio, Inc., 

an Ohio corporation; Interim Healthcare of Pittsburgh, Inc., a Pennsylvania corporation; Interim 

Healthcare of Ohio, Inc., an Ohio corporation; Interim Healthcare Hospice of Western 

Pennsylvania, Inc., a Pennsylvania corporation; Interim Healthcare Hospice of Ohio, Inc., an Ohio 

corporation; Indianapolis Home Care, Inc., an Indiana corporation; Interim Healthcare of SE 

Ohio, Inc., an Ohio corporation; Interim Healthcare of Marietta, Inc., an Ohio corporation; and 

Happy Paws Home Care, Inc., an Ohio corporation, (“Salo”) to settle all state and federal wage 

and hour claims as further described herein.

Salo and Plaintiff (together, the “Settling Parties”) agree to do all things and take all steps 

reasonably necessary and appropriate to obtain approval of this Agreement in consideration for: 

(a) payment by Salo of the consideration expressed in this Agreement subject to the terms, 

conditions and limitations of this Agreement; (b) the release and dismissal with prejudice of all 

claims, as set forth in this Agreement; and, (c) other valuable monetary and non-monetary 

consideration, as set forth in this Agreement. This Agreement is contingent upon approval by the 

supervising Court and is entered into voluntarily by the Settling Parties for settlement purposes 

only.

I. CONSENT TO COURT-FACILITATED NOTICE

A. For settlement purposes only, the Settling Parties agree that Plaintiff and the 

“Potential Opt-In Plaintiffs” (as defined below) are similarly situated for purposes of 29 U.S.C. § 

216(b) of the Fair Labor Standards Act (“FLSA”) and consent to Court-facilitated notice of 

pendency of this action and proposed settlement thereof to the Potential Opt-in Plaintiffs. Potential 

Opt-in Plaintiffs shall include 2,500 Salo non-exempt employees including, but not limited to, 

home health aides during the period beginning March 2014 and ending December 31, 2017, who 

were denied overtime payments due to Salo’s failure to include as hours worked the time the 

Potential Opt-Ins plaintiffs spent traveling to and from jobsites in excess of 40 hours in a 

workweek. Within fifteen (15) days1of the supervising Court’s approval of this settlement, Salo 

shall provide the Settlement Claims Administrator with the corresponding names of each Potential 

Opt-In Plaintiff as well as each such individual’s last known mailing address.

B. The Settling Parties shall cooperate and present to the supervising Court for its 

consideration in connection with the approval of the Agreement and Court-facilitated notice such 

information as may be reasonably requested by the Court for approving an FLSA settlement and 

facilitated notice.

 

1 All time periods provided by this Agreement are in calendar days, not business days, unless otherwise stated.

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II. SETTLEMENT APPROVAL PROCEDURE

Within ten (10) days of the execution of this Agreement, the Settling Parties shall file a 

Joint Motion for Order Approving Settlement of Collective Action and Authorizing Notice of 

Settlement and Opportunity to File Claim Form and Release (“Consent Motion”) with the 

Settlement Agreement, agreed-to (proposed) Order on Consent Motion (“Approval Order”), and 

the Notice of Settlement, Claim Form and Release (including a postage-paid return envelope) 

(collectively, the “Notice Packet”), which is attached to this Agreement as Exhibit A, advising 

the Potential Opt-In Plaintiffs of the material terms and provisions of this settlement, including 

their estimated settlement share, the procedure for consenting to participate in this settlement by 

submitting a Claim Form and Release, and their rights with respect to this settlement. The Notice 

Packet must be sent out substantially in the form attached hereto as Exhibit A, subject to Court 

approval.

III. MODE, CALCULATION AND TIMING OF PAYMENT OF CLAIMS

A. Notice of Claims

1. As set forth above, within fifteen (15) days of the supervising Court’s 

approval of this settlement, Salo shall provide the Settlement Claims Administrator with the 

corresponding names of each Potential Opt-In Plaintiff as well as each such individual’s 

employee identification number, if any, last known mailing address, Social Security number, 

dates of employment, and state(s) of employment during the period covered by the settlement. 

All information provided regarding the Potential Opt-in Plaintiffs will be treated by Plaintiff’s 

Counsel and by the Settlement Claims Administrator as confidential, and the Claims 

Administrator will not communicate to Plaintiff’s Counsel any personally identifying 

information (such as names or addresses) regarding any Potential Opt-In Plaintiff who has not 

yet opted into the settlement. Prior to the mailing of the Notice Packet to the Potential Opt-In 

Plaintiffs, the Settlement Claims Administrator shall make commercially reasonable efforts to 

find accurate addresses through the United States Post Office’s National Change of Address 

database and shall mail the Notice Packet to any updated address obtained therefrom.

2. Fifteen (15) days after Court approval of this Agreement and the Notice 

process described herein, the Settlement Claims Administrator shall mail, in one mailing, by 

U.S. Mail all Notice Packets to the Potential Opt-In Plaintiffs. Potential Opt-In Plaintiffs must 

submit a completed Claim Form and Release, by mail or facsimile, to the Settlement Claims 

Administrator on or before ninety (90) days after Court approval of this Agreement (the “Claim 

Bar Date”). If any Notice Packet is returned as undeliverable for a Potential Opt-In Plaintiff, the 

Claims Administrator shall promptly attempt to locate such Potential Opt-In Plaintiff up to two 

times through an electronic search using the Social Security number and/or former address of 

that person and, if a new address is obtained through the skip trace, shall promptly mail an 

additional Notice Packet to such person. The Claim Bar Date for Potential Opt-In Plaintiffs 

receiving such Notice Packets shall be 30 days after re-mailing or the original Claim Bar Date, 

whichever is later.

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3. Thirty (30) days prior to the Claim Bar Date, the Settlement Claims 

Administrator will distribute a reminder postcard by First Class U.S. Mail to any Potential Opt-In 

Plaintiffs who have not returned a Claim Form and Release. 

4. In the event that Plaintiff’s Counsel or the Settlement Claims 

Administrator is contacted by a Potential Opt-In Plaintiff before the Claim Bar Date and the 

Potential Opt-In Plaintiff indicates that he or she did not receive the Notice Packet, the Settlement 

Claims Administrator shall mail an additional Notice Packet to the address provided by the 

Potential Opt-In Plaintiff. The Claim Bar Date for Potential Opt-In Plaintiffs receiving such 

Notice Packets shall be 30 days after mailing or the original Claim Bar Date, whichever is later.

5. In the event any Claim Form and Release is timely submitted but does not 

contain a signature or sufficient information to identify the Potential Opt-In Plaintiff, the 

Settlement Claims Administrator shall provide the Potential Opt-In Plaintiff with a letter 

requesting the information that was not provided (the “Cure Letter”) and giving the Potential OptIn Plaintiff the later of fifteen (15) calendar days or the applicable Claim Bar Date to respond. 

Any Potential Opt-In Plaintiff who fails to timely respond to a Cure Letter will not be considered 

a Qualified Claimant.

6. The Potential Opt-In Plaintiffs who timely return completed and executed 

Claim Form and Releases will be considered “Qualified Claimants” entitled to receive their share 

of the Revised Gross Fund (as defined in III. F(2) paragraph below).

7. In the event of any dispute over a Potential Opt-In Plaintiff’s dates of 

employment, unpaid overtime and/or the late submission of any claims, the Settling Parties will 

meet and confer in good faith in an effort to resolve the dispute, and if the Settling Parties are 

unable to reach an agreement, the Settlement Claims Administrator shall decide the dispute, and 

its decision will be final. 

8. Within ten (10) calendar days after the Claim Bar Date, the Settlement 

Claims Administrator shall provide to Salo’s Counsel and Plaintiff’s Counsel a list, including 

names, address(es) and telephone number(s) (including cell phone numbers) of Qualified 

Claimants and shall provide electronic copies of all timely received and completed Claim Form 

and Releases. In addition, redacted copies of all timely received and completed Claim Form and 

Releases suitable for filing with the Court—i.e., removing addresses and other personally 

identifying information—shall be provided to Counsel for Salo so that Salo’s Counsel may, at its 

option, file all Claim Form and Releases with the Court.

9. At the conclusion of the settlement administration process, the Settlement 

Claims Administrator shall maintain an electronic copy of all Claim Form and Releases received 

by the Potential Opt-In Plaintiffs and shall provide the original and electronic Claim Form and 

Releases to Counsel for Salo.

B. Salo’s Payment Obligations

1. Payments to Plaintiff and the Gross Fund. In consideration for the 

dismissal with prejudice of the lawsuit (the “Litigation”) as well as the release of claims effected 

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by this Agreement and other good and valuable consideration, Salo shall pay One Million Five 

Hundred Thousand Dollars and Zero Cents ($1,500,000.00) to settle the Litigation for the benefit 

of Plaintiff and all Potential Opt-In Plaintiffs (the “Gross Fund”). Subject to the terms of this 

Agreement, the Gross Fund is inclusive of payment for: (1) the Portion of the Revised Gross Fund 

(as defined below) for Plaintiff and all Potential Opt-In Plaintiffs who become Qualified 

Claimants, or their respective authorized legal representatives; (2) all service payments sought 

from and approved by the Court; (3) all attorneys’ fees, costs, and litigation expenses approved by 

the Court, including those in connection with securing Court approval of this Agreement, other 

than fees and costs awarded in connection with any successful proceeding to enforce the terms of 

this Agreement; (4) the employee’s and the employer’s share of applicable federal, state and local 

taxes required to be withheld by Salo; and (5) costs and fees in excess of Twenty Five Thousand 

Dollars and Zero Cents ($25,000.00) incurred by the Settlement Claims Administrator. Other than

Settlement Claim Administrator Fees not to exceed Twenty Five Thousand Dollars and Zero 

Cents ($25,000.00), the Gross Fund shall be all that Salo shall pay to Plaintiff and Potential Opt-In 

Plaintiffs to settle the Litigation and this figure assumes 100% of the Potential Opt-in Plaintiffs 

make valid and timely claims and become Qualified Claimants. The Gross Fund is exclusive of 

any and all interest or investment income accrued, which accrued interest/income and unclaimed 

funds after the payment of those amounts set forth above shall revert to Salo.

C. Timing of Payments by Salo

Within ten (10) days of Court approval of this Agreement, Salo agrees to deposit One 

Million Five Hundred Thousand Dollars and Zero Cents ($1,500,000.00) into the Qualified 

Settlement Fund described in paragraph III.E(1) below.

D. Settlement Claims Administration

1. Selection of Settlement Claims Administrator. Within five (5) days of 

the execution of this Agreement, Plaintiff’s Counsel shall select a firm to serve as Settlement 

Claims Administrator, subject to Salo’s written approval, which approval shall not be 

unreasonably withheld.

2. Settlement Claims Administrator Responsibilities. The Settlement 

Claims Administrator shall be responsible for: (a) preparing (subject to the parties’ approval) the 

calculations of the individualized Settlement Payments (as defined below) and tax withholding 

amounts for Plaintiff and Potential Opt-In Plaintiffs, as applicable; (b) preparing, printing and 

disseminating to the Potential Opt-In Plaintiffs the Notice Packet and return envelope as well as 

the reminder postcard described in Paragraph III(A)(3) above; (c) copying counsel for all Settling 

Parties on material correspondence and promptly notifying all counsel for the Settling Parties of 

any material requests or communications made by any Settling Party or Potential Opt-In Plaintiff 

who receives Notice; (d) preparing, monitoring and maintaining a toll-free number with phone 

answerers until thirty (30) days after the mailing of checks to Qualified Claimants; (e) receiving 

and reviewing the Claim Form and Releases submitted by Potential Opt-In Plaintiffs to determine 

eligibility for payment; (f) calculating the final Settlement Payment for each Qualified Claimant in 

accordance with this Agreement (subject to the parties’ approval); (g) mailing the service 

payments and settlement checks to Qualified Claimants; (h) wiring Plaintiff’s Counsel’s 

attorneys’ fees, expenses, and costs in accordance with this Agreement and Order of the Court; (i) 

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paying all payroll tax obligations of Salo in accordance with this Agreement; (j) issuing W-2 and 

1099 Forms for all amounts paid to Qualified Claimants; (k) ascertaining current address and 

addressee information for each Notice Packet returned as undeliverable pursuant to Paragraph 

III(A)(2); (l) responding to inquiries of the Potential Opt-In Plaintiffs regarding the terms of 

settlement and procedures for returning Claim Form and Releases; (m) referring to Plaintiff’s 

Counsel all inquiries by the Potential Opt-In Plaintiffs about the amount of any Qualified 

Claimant’s individual estimated settlement payment, if the Settlement Claims Administrator is 

unable to answer such inquiries; (n) responding to inquiries of Plaintiff’s or Salo’s Counsel; (o) 

promptly apprising counsel for the Settling Parties of the activities of the Settlement Claims 

Administrator; (p) maintaining adequate records of its activities, including the date of the mailing 

of the Notice Packets and receipt of Claim Form and Releases, returned mail and other 

communications and attempted written or electronic communications with Plaintiff and Potential 

Opt-In Plaintiffs; (q) confirming in writing to Plaintiff’s Counsel and Salo’s Counsel and the 

Court its completion of the administration of the settlement and retaining copies of all endorsed 

settlement checks; (r) timely responding to communications from the Settling Parties or their 

counsel; (s) maintaining the confidentiality of the Class List and obtaining appropriate insurance 

against a breach of such confidentiality; and (t) such other tasks as the Settling Parties mutually 

agree.

3. Settlement Fund Fees and Expenses. All fees, expenses, and costs of the 

Settlement Claims Administrator related directly or indirectly to the Settlement Fund (as defined 

in paragraph III.(E)(1) below), including, but not limited to, all fees, expenses, and costs in 

connection with the Gross Fund and Settlement Fund (including, but not limited to, those related 

to notice, check cutting and mailing, claims processing, court filings, legal and accounting advice 

relating to the establishment of the Qualified Settlement Fund and tax treatment and tax reporting 

of awards to Qualified Claimants, preparation of tax returns (and the taxes associated with such 

tax returns as defined below)) up to, and not to exceed Twenty Five Thousand Dollars and Zero 

Cents ($25,000.00) shall be paid by Salo. If the fees, expenses, and costs of the Settlement 

Claims Administrator exceeds Twenty-Five Thousand Dollars and Zero Cents ($25,000.00), such 

costs shall be paid from the Gross Fund.

4. Reporting by Settlement Claims Administrator. Throughout the period 

of claims administration, the Settlement Claims Administrator will provide such reports to the 

Settling Parties upon request by either Settling Party, regarding the status of the mailing of the 

Notice Packets to the Potential Opt-In Plaintiffs, the claims administration process, the receipt of 

Claim Form and Releases, and distribution of the Settlement Checks or any other aspect of the 

claims administration process.

E. Creation and Implementation of a Qualified Settlement Fund

1. Establishing the Qualified Settlement Fund. Salo shall make the payment 

called for by Paragraph III(C) to an account titled Salo, Inc. Settlement Fund (the “Settlement 

Fund”), intended by the Settling Parties to be a “Qualified Settlement Fund” as described in 

Section 468B of the Internal Revenue Code of 1986, as amended, and Treas. Reg. Section 

1.468B-1, et seq. The Settlement Fund shall be established as a Qualified Settlement Fund within 

the meaning of Section 468B of the Internal Revenue Code of 1986, as amended, the Treas. Reg. 

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Section 1.468B-1, et seq., and shall be administered by the Settlement Claims Administrator, 

subject to the ultimate authority of the Court.

2. Administering the Settlement Fund. The Settlement Claims Administrator 

shall serve as Trustee of the Settlement Fund and shall act as a fiduciary with respect to the 

handling, management, and distribution of the Settlement Fund, including the handling of taxrelated issues and payments. The Settlement Claims Administrator shall act in a manner necessary 

to qualify the Settlement Fund as a Qualified Settlement Fund and to maintain that qualification. 

The Settling Parties shall cooperate to ensure such treatment and shall not take a position in any 

filing or before any tax authority inconsistent with such treatment. The Settling Parties agree to any 

relation-back election required to treat the Settlement Fund as a Qualified Settlement Fund from 

the earliest possible date.

3. Tax Withholding and Reporting.

a. Employment Taxes. The Settling Parties recognize that the 

settlement payments to Qualified Claimants will be subject to applicable tax withholding and 

reporting. The Settlement Claims Administrator shall be responsible for withholding and timely 

remitting and reporting to the appropriate taxing authorities the employee’s share of payroll taxes 

from the wage portion of each Qualified Claimant’s settlement payment. The applicable employer 

tax contributions associated with the wage portion of the settlement payments paid to Qualified 

Claimants, including, but not limited to, its own share, as the employer or former employer, of the 

FICA tax and any federal and state unemployment tax due, with respect to the amounts treated as 

wages pursuant to Section 3.5(A) will be paid out of the Gross Fund. Any such payroll taxes 

ordinarily borne by the employer shall be paid out of the Gross Fund. The amounts designated as 

liquidated damages shall be reported to the IRS on Form 1099 and not subject to withholding.

b. Fund Taxes. All taxes (including any estimated taxes, interest, or 

penalties) arising with respect to the income earned by the Settlement Fund, if any, including any 

taxes or tax detriments that may be imposed on Salo or the Settlement Fund with respect to 

income earned for any period during which the Settlement Fund does not qualify as a “Qualified 

Settlement Fund” for federal and state income tax purposes (hereinafter “Settlement Fund Taxes”) 

shall be paid out of the Settlement Fund. Further, Settlement Fund Taxes shall be treated as a cost 

of the administration of the Settlement Fund. The Settling Parties agree to cooperate with the 

Settlement Claims Administrator, each other, and their tax attorneys and accountants to the extent 

reasonably necessary to carry out the provisions set forth in this Section.

4. Other Payments and Indemnification. The Settlement Claims 

Administrator shall satisfy from the Settlement Fund: all federal, state, local, and other reporting 

requirements (including any applicable reporting with respect to attorneys’ fees and other costs 

subject to reporting) and any and all taxes, penalties and other obligations with respect to the 

payments or distributions not otherwise addressed in this Agreement. The Settlement Claims 

Administrator shall indemnify the Settling Parties for any penalty or interest arising out of an 

incorrect calculation or late deposit of the same.

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5. Communication with Counsel. Plaintiff’s Counsel and Salo’s Counsel are 

authorized to communicate directly with the Settlement Claims Administrator to expedite the 

settlement administration process. 

F. Allocation of the Settlement Fund

1. Revised Gross Fund. The amount approved by the Court for Plaintiffs’

Service Payments, attorneys’ fees, expenses, and costs; and the expenses of the Settlement Claims 

Administrator shall be deducted from the Gross Fund to obtain a “Revised Gross Fund.”

2. Allocation of Revised Gross Fund. Qualified Claimants shall be paid 

their portion of the Revised Gross Fund pursuant to the following allocation formula:

a. The Parties shall provide the Settlement Claims Administrator with 

a spreadsheet identifying each Potential Opt-in Plaintiff’s total unpaid overtime hours and final 

rate of pay within the period identified in Paragraph I(A). Each Potential Opt-in Plaintiff’s 

Maximum Potential Awards shall be calculated by determining their unpaid overtime (i.e., 

unpaid overtime hours x 1.5 final rate of pay);

b. The Settlement Claims Administrator shall divide the Revised 

Gross Fund by the sum of all Maximum Potential Awards for all Potential Opt-in Plaintiffs to 

obtain the “Settlement Quotient;”

c. Multiply each Potential Opt-in Plaintiff’s Maximum Potential 

Award by the Settlement Quotient to determine each Potential Claimant’s “Portion of the 

Revised Gross Fund;” 

d. Only Potential Opt-in Plaintiffs who become Qualified Claimants 

pursuant to Paragraph III(A)(6) shall be entitled to receive their Portion of the Revised Gross 

Fund. 

3. Service Payment. From the Gross Fund, Counsel for Plaintiff shall seek a 

Service Payment for Annie Raines of Ten Thousand Dollars and Zero Cents ($10,000.00) and a 

Service Payment for Rebecca Stevens for Five Thousand Dollars and Zero Cents ($5,000.00) for 

their involvement in commencing the claims represented in this litigation and in helping to bring 

about this collective outcome. The settlement is not conditioned upon the Court’s approval of the 

requested Service Payments and any amount that is not approved by the Court for these Service 

Payments shall revert back to the Gross Fund for distribution as provided herein.

4. Attorneys’ Fees and Costs Amounts. Plaintiff’s Counsel shall make an 

application to the Court for an award of Thirty-Three and One-Third Percent (33 1/3%) of the 

Gross Fund for attorneys’ fees. In addition, Plaintiff’s Counsel shall seek reimbursement of their 

reasonably incurred costs and expenses not to exceed $10,000 from the Gross Fund. Salo will not 

oppose the foregoing requests and application for attorneys’ fees and costs by Plaintiff’s Counsel. 

Payment of such attorneys’ fees, expenses, and costs to Plaintiff’s Counsel shall be made in 

accordance with this Agreement and shall constitute full satisfaction of any and all obligations by 

Salo to pay any person, attorney or law firm for attorneys’ fees, expenses or costs incurred on 

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behalf of Plaintiff and Potential Opt-in Plaintiffs for the claims released by this Settlement. The 

Settlement Claims Administrator shall report the payment of these fees, expenses and costs to 

Plaintiff’s Counsel on an IRS Form 1099. The settlement is not conditioned upon the Court’s 

approval of the requested attorneys’ fees and costs, and any amount that is not approved by the 

Court for these payments shall revert back to the Gross Fund for distribution as provided herein. 

There shall be no other payment to or liability for legal fees or other payments to any attorney or 

other person for the claims released by this Settlement other than as set forth herein.

5. Tax Treatment. The Settlement Claims Administrator shall allocate fifty 

percent (50%) of the total paid to each Qualified Claimant to wages (to be reported on an Internal 

Revenue Service (“IRS”) Form W-2) and fifty percent (50%) to non-wage compensation (to be 

reported on an IRS Form 1099). The Settlement Claims Administrator shall be responsible for 

withholding and timely remitting and reporting all taxes to the appropriate taxing authorities. 

Payments treated as W-2 wages shall be made net of all applicable employment taxes, including, 

without limitation, federal, state and local income tax withholding and the employee share of the 

FICA tax, and shall be reported to the Internal Revenue Service (“IRS”) and the payee under the 

payee’s name and social security number on an IRS Form W-2. Payments treated as liquidated 

damages, statutory penalties and interest shall be made without withholding and shall be reported 

to the IRS and the payee, to the extent required by law, under the payee’s name and social security 

number on an IRS Form 1099. Payments of attorneys’ fees and costs shall be made without 

withholding. Plaintiff’s Counsel will receive a Form 1099 for this payment. The tax treatment of 

and withholding from any Service Payments made pursuant to Paragraph III(F)(3) shall be 

determined by the Settlement Claims Administrator. 

G. Payments from the Qualified Settlement Fund 

1. Service Awards, Fees and Costs. Within fifteen (15) business days of the 

Court’s Order Approving this Agreement, the Settlement Claims Administrator shall pay, out of 

the Gross Fund, to (1) Plaintiffs such amount of service payments as have been approved and 

ordered by the Court, not to exceed a total of $15,000, and (2) Plaintiff’s Counsel such amount of 

attorneys’ fees and costs as has been approved and ordered by the Court.

2. Timing of Payments to Qualified Claimants. Within twenty-one (21) 

days after the deadline for Consents to be returned to the Settlement Claims Administrator, the 

Settlement Claims Administrator will transmit all payments to Qualified Claimants by first-class 

U.S. Mail to the last known address for each Qualified Claimant, or such other address provided 

by the Qualified Claimant to the Settlement Claims Administrator.

3. No Additional Benefits or Compensation. It is expressly understood and 

agreed that the receipt of any payment under this Agreement will not entitle any Qualified 

Claimant to any compensation or benefits under any of Salo’s or Released Parties’ bonus or other 

compensation or benefit plans or agreements. Nor will the receipt of such payments entitle any 

Qualified Claimant to any retirement, 401K benefits or matching benefits or deferred 

compensation benefits, or increases in any benefits or payments. The Qualified Claimants are not 

entitled to any new or additional compensation or benefits as a result of having received payments 

pursuant to this Agreement (notwithstanding any contrary language or agreement in any benefit or 

compensation plan document).

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4. Tax Advice. Plaintiff, on behalf of herself and Potential Opt-in Plaintiffs, 

acknowledges and agrees that she has not relied upon any advice from Salo as to the taxability of 

the payments received pursuant to this Agreement or in any other respect whatsoever.

5. Negotiation of Settlement Checks. Qualified Claimants will have ninety 

(90) days after the date on the settlement checks (the “Check Issuance Date”) in which to negotiate 

the checks. If any Qualified Claimant does not negotiate his or her settlement check within 90 

days after the Check Issuance Date, the check will be void, and no such void checks will be 

reissued. The Settlement Claims Administrator will advise Plaintiff’s Counsel of any uncashed 

checks fourteen (14) days prior to the 90 day deadline and will provide contact information for any 

Qualified Claimants who have not cashed their checks at that time. 

Any funds remaining in the Qualified Settlement Fund after payment to: (1) all Qualified 

Claimants who timely negotiate their settlement checks; (2) all service payments, attorneys’ fees, 

costs, and litigation expenses approved by the Court; (3) all costs incurred by the Settlement 

Claims Administrator and all costs in connection with the Settlement Fund including, but not 

limited to, those related to notice, check cutting and mailing, claims processing, court filings, legal 

and accounting advice relating to the establishment of the Qualified Settlement Fund and tax 

treatment and tax reporting of awards to Qualified Claimants, preparation of tax returns (and the 

taxes associated with such tax returns as defined below); and (4) applicable federal, state and local 

income taxes, and all federal and state unemployment taxes required to be withheld shall be 

returned to Salo. 

IV. RELEASE BY QUALIFIED CLAIMANTS 

A. Release. Conditioned upon the Court’s entry of the Approval Order, and in 

exchange for the monetary consideration recited in this Agreement, Plaintiff does hereby agree to 

dismiss the captioned case with prejudice and all Qualified Claimants, including Potential Opt-In 

Plaintiffs, who execute a Claim Form and Release shall release Salo and any of its subsidiaries, 

affiliates, business units, members, shareholders, and their predecessors and successors, officers, 

directors, agents, employees and assigns (collectively, the “Released Parties”) from any and all 

wage claims pled in the Complaint or that could have been pled under the facts alleged in the 

Complaint under the Fair Labor Standards Act, 29 U.S.C. § 201, et seq. (“FLSA”) and any state 

and/or local wage-and-hour laws through the date of full execution of this Agreement, as set forth 

in the Claim Form and Release. (The claims being released are referred to in this Agreement as 

“Released Claims.”).

V. NOTICES

All notices, requests, demands and other communications required or permitted to be given 

to either party pursuant to this Agreement shall be in writing and shall be delivered personally or 

mailed, postage prepaid, by first-class mail to the undersigned persons at their respective 

addresses as set forth herein:

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Counsel for Plaintiff:

Shannon M. Draher

Hans A. Nilges

Nilges Draher LLC

7266 Portage Street NW

Suite D

Massillon, OH 44646

Counsel for Defendant: Douglas M. Kennedy 

Paul L. Jackson

Roetzel & Andress, LPA

41 South High Street

Huntington Center, 21st Floor

Columbus, OH 43215

Defendant: Thomas J. DiMarco

President/CEO

Salo, Inc.

960 Checkrein Avenue

Columbus, OH 43229

VI. REPRESENTATION BY COUNSEL

All of the Settling Parties acknowledge that they have been represented by counsel 

throughout all negotiations that preceded the execution of this Agreement and that this 

Agreement has been executed with the advice of counsel.

VII. NO ADMISSION OF LIABILITY

Salo enters into this Agreement to avoid further expense and disruption to its business. The 

Settling Parties acknowledge and agree that liability for the actions that are the subject matter of 

this Agreement is disputed by Salo. This Agreement and the settlement are a compromise and 

shall not be construed as an admission of liability at any time or for any purpose, under any 

circumstances, by the Settling Parties to this Agreement. The Settling Parties further 

acknowledge and agree that this Agreement and the settlement shall not be used to suggest an 

admission of liability in any dispute the Settling Parties may have now or in the future with 

respect to any person or entity. Neither this Agreement nor anything herein, nor any part of the 

negotiations had in connection herewith, shall constitute evidence with respect to any issue or 

dispute other than for purposes of enforcing this Agreement.

VIII. MODIFICATION OF AGREEMENT

This Agreement may not be modified or amended except in writing, signed by the affected 

Settling Parties or the respective counsel of record for the Settling Parties and as approved by the 

Court.

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IX. CONSTRUCTION AND INTERPRETATION

A. Entire Agreement. This Agreement constitutes the entire agreement between the 

Settling Parties with respect to the subject matter contained herein. This Agreement shall be 

construed as a whole according to its fair meaning and intent, and not strictly for or against any 

party, regardless of who drafted or who was principally responsible for drafting this Agreement or 

any specific term or condition thereof. Plaintiff and Salo participated in the negotiation and 

drafting of this Agreement and had available to them the advice and assistance of independent 

counsel. As such, neither Plaintiff nor Salo may claim that any ambiguity in this Agreement 

should be construed against the other.

B. No Reliance on Representations or Extrinsic Evidence. Except as expressly 

provided herein, this Agreement has not been executed in reliance upon any other oral or written 

representations or terms, and no such extrinsic oral or written representations or terms shall 

modify, vary or contradict its terms. In entering into this Agreement, the Settling Parties agree 

that this Agreement is to be construed according to its terms and may not be varied or 

contradicted by extrinsic evidence.

C. Controlling Law. This Agreement shall be subject to, governed by, construed, 

enforced and administered in accordance with the laws of the State of Ohio, and shall be subject to 

the continuing jurisdiction of the United States District Court for the Southern District of Ohio, 

Eastern Division.

D. No Assignment. Plaintiff’s Counsel and Plaintiff, on behalf of herself and 

Potential Opt-in Plaintiffs, represent and warrant that they have not assigned or transferred, or 

purported to assign or transfer, to any person or entity, any claim or any portion thereof or interest 

therein, including, but not limited to, any interest in the Litigation, or any related action.

E. Severability. If any provision of this Agreement is held by a court of competent 

jurisdiction to be void, voidable, unlawful or unenforceable, except the Release as set forth in 

Section IV and the Claim Form and Release, the remaining portions of this Agreement will remain 

in full force and effect to the extent that the effect of the Agreement remains materially the same 

and the obligations of the Settling Parties remain materially the same.

X. COUNTERPARTS

This Agreement, any amendments or modifications to it, and any other documents required 

or contemplated to be executed in order to consummate this Agreement, may be executed in one 

or more counterparts, each of which shall be deemed an original of this Agreement. All 

counterparts of any such document together shall constitute one and the same instrument. A 

photocopy, facsimile, or digital image of an executed counterpart shall be enforceable and 

admissible as an original.

XI. BINDING EFFECT

This Agreement is binding upon and shall inure to the benefit of the Settling Parties to this 

Agreement. Without limiting the foregoing, this Agreement specifically shall inure to the benefit 

of Salo as well as its present and former owners, stockholders, predecessors, successors, joint 

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ventures, assigns, agents, directors, officers, board members, employees, representatives, insurers, 

attorneys, parents, subsidiaries, benefit plans, plan fiduciaries, affiliates, affiliated divisions and 

entities, and all persons acting by, through, under or in concert with any of them. Also without 

limiting the foregoing, this Agreement shall be binding upon the spouses, children, heirs, assigns, 

administrators, executors, beneficiaries, conservators, successors and offspring of all Qualified 

Claimants.

XII. ATTORNEYS’ FEES, COSTS AND EXPENSES

Except as otherwise specifically provided herein, the Settling Parties and all Potential Optin Plaintiffs shall bear responsibility for their own attorneys’ fees, costs and expenses, taxable or 

otherwise, incurred by them or arising out of this litigation and shall not seek reimbursement 

thereof from any party to this Agreement. However, in the event of any dispute to enforce the 

terms of this Agreement, the prevailing party shall be entitled to an award of their reasonable 

attorneys’ fees and costs from the non-prevailing party.

XV. AUTHORITY OF COUNSEL

A. Facsimile and Email Signatures. Any Settling Party may execute this 

Agreement by signing or by causing its counsel to sign on the designated signature block below 

and transmitting that signature page via facsimile or email to counsel for the other Settling 

Party. Any signature made and transmitted by facsimile or email for the purpose of executing 

this Agreement shall be deemed an original signature for purposes of this Agreement and shall 

be binding upon the Settling Party whose counsel transmits the signature page by facsimile or 

email.

B. Voluntary Signature. All Settling Parties agree that they have signed this 

Agreement, or authorized their counsel to sign this Agreement on their behalf, knowingly, 

voluntarily, with full knowledge of its significance, and without coercion.

C. Warranty of Counsel. Plaintiff’s Counsel warrant and represent that they are 

expressly authorized by Plaintiff to take all appropriate action required or permitted to be taken 

pursuant to this Agreement in order to effectuate its terms. Counsel for Salo warrant and represent 

that they are authorized to take all appropriate action required or permitted to be taken by Salo

pursuant to this Agreement in order to effectuate its terms.

XVI. CONTINUING JURISDICTION

The Parties hereto agree to move for the United States District Court for the Southern 

District of Ohio, Eastern Division to retain continuing jurisdiction to construe, interpret and 

enforce the provisions of this Agreement; to supervise the administration and distribution of the 

resulting settlement funds; and to hear and adjudicate any dispute or litigation arising from or 

related to this Agreement or the issues of law and facts asserted in the collective action litigation.

The Settling Parties (a) acknowledge that it is their intent to consummate this Agreement; 

and (b) agree to cooperate to the extent reasonably necessary to effectuate and implement all terms 

and conditions of the Agreement and to exercise their best efforts to accomplish the foregoing 

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terms and conditions of the Agreement, as long as such cooperation does not delay the 

administration or approval of the Agreement.

Dated: February__, 2018 SALO, INC.

By: ___________________________

Its: ___________________________

Dated: February ___, 2018

_________________________________

ANNIE RAINES

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EXHIBIT A

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NOTICE OF SETTLEMENT OF COLLECTIVE ACTION LAWSUIT

You are receiving this notice because you are a member of a collective action and eligible to 

participate in a settlement. A court approved this notice. This is not a solicitation from a 

lawyer. 

If you work or worked for Salo, Inc., d/b/a Interim Healthcare as a non-exempt employee

and spent time traveling to and from jobsites during the workday, you may be entitled to a 

payment from a collective action settlement if you complete and return the enclosed form. 

A current home health aide of Salo, Inc. (“Salo”) has filed a lawsuit alleging that Salo failed to pay 

her and other non-exempt employees overtime associated with time spent traveling over 40 hours 

during a normal workweek. The Parties have entered into this settlement solely with the intention 

to avoid further disputes and litigation with the attendant inconvenience and expense. No Court 

has ruled on the merits of the Plaintiff’s claims, and no party has prevailed in this action. 

Under the allocation formula created by the settlement, you are estimated to receive approximately 

$__________, subject to deductions for applicable taxes. The final amount to which you may be 

entitled may be higher or lower than the estimated amount.

Your legal rights may be affected, and you have a choice to make now: 

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:

RETURN THE 

CONSENT 

FORM

By returning a properly completed Claim Form and Release you agree to 

participate in the settlement, receive a monetary settlement payment, and 

release your claims.

DO NOT 

RETURN THE 

CONSENT 

FORM

If you do not wish to participate in or be bound by the settlement, you should 

not return the Claim Form and Release. If you do not timely return a properly 

completed Claim Form and Release postmarked by [date], you will not 

receive a settlement payment, and you will not release any claims.

BASIC INFORMATION

1. Why did I get this notice?

You have received this notice because Salo’s records show that you currently work or previously 

worked as a non-exempt employee for Salo during the period of March 2014 to December 31, 

2017, the time period covered by the settlement, and that you are owed overtime for time spent 

traveling during a normal workday. 

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The Court ordered that you be sent this notice because you have a right to know about the 

settlement of this collective action lawsuit that affects your rights. This notice explains the 

lawsuit, the settlement, your legal rights, and what benefits are available.

The Court overseeing these lawsuit is the United States District Court for the Southern District of 

Ohio, Eastern Division. The lawsuit is known as Annie Raines v. Salo, Inc., d/b/a Interim 

Healthcare, Case No. 2:17-cv-00209 (S.D. Ohio). The person who filed the lawsuit is called the 

“Plaintiff.” Salo is referred to as the “Defendant.”

2. What is the lawsuit about?

This lawsuit is about whether Salo failed to pay overtime wages for time that its home health aides 

spent traveling to and from client residences during their normal workdays. The Court has not 

made any ruling on the merits of the claims.

3. What is a collective action?

In a “Collective Action,” one or more people called “Named Plaintiffs” sue on behalf of people 

who have similar claims. When other employees who have similar claims opt into the Collective 

Action, they become “Collective Members.” You may opt into the Collective Action and 

participate in the settlement of the lawsuit by signing and returning the enclosed Claim Form and 

Release. A settlement check will be mailed to you if and when all appeals have been exhausted.

4. Why is there a settlement?

The Court did not decide in favor of Plaintiff or Salo and neither side prevailed. The Parties 

agreed to this settlement with the intention to avoid further disputes and litigation with the 

attendant inconvenience and expense. That way, they avoid the cost of a trial, and the people 

affected will get compensation. 

WHO IS IN THE SETTLEMENT

5. How do I know if I will be included in the settlement?

You will receive a settlement check if you are or were a non-exempt employee who was not paid 

all of his/her overtime as a result of Salo’s travel time during the working day for the period of 

March 3, 2013 through December 31, 2017, and you properly complete, sign, and return the 

enclosed Claim Form and Release by [date 90 days from mailing of Notice].

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6. I’m not sure if I want to be included.

If you are still not sure whether you would like to be included, you can ask for free help. You can 

contact the attorneys for the Plaintiff as follows: 

Shannon Draher

Nilges Draher LLC

7266 Portage Street NW

Suite D

Massillon, OH 44646

(330) 470-4428

THE SETTLEMENT BENEFITS – WHAT YOU GET

7. What does the settlement provide?

Salo has agreed to pay $1,500,000 to be utilized to pay monies to current and former non-exempt 

employees who are covered by the settlement. The settlement amount will be used to pay 

settlement payments, Court-approved attorneys’ fees and costs, Court-approved service payments 

of a combined total of $15,000 ($10,000 to Annie Raines and $5,000 for Rebecca Stevens), and 

payroll and other applicable taxes. 

The settlement funds for Collective Members will be divided proportionately among current and 

former non-exempt employees who are covered by the settlement based on each employee’s 

unpaid overtime during the period covered by the settlement. Should such employees not 

participate, any remainder shall revert to Salo. Settlement checks that are not cashed within 90

days will be null and void.

8. How much will my payment be and how was it calculated?

Based on the formula that has been approved by the Court, you are estimated to receive 

approximately $_____, half of which is subject to deductions for applicable taxes and withholdings 

like any other paycheck, and for which you will receive a W-2; and half of which will be reported 

on an IRS Form 1099. The final amount to which you may be entitled may be higher or lower than 

the estimated amount. The allocation formula takes into account your unpaid overtime as a result 

of Salo’s failure to pay travel time during the period covered by the settlement. The Settlement 

Agreement contains the exact allocation formula. You may obtain a copy of the Settlement 

Agreement by following the instructions in Paragraph 14 below.

HOW YOU GET A PAYMENT

9. How can I get my payment?

To get your payment, you must fully complete the enclosed Claim Form and Release and mail it to 

the Claims Administrator in the enclosed envelope postmarked no later than [date]. You may also 

e-mail or fax the Claim Form and Release to the Settlement Claims Administrator, so that it is 

received no later than [date]. The Settlement Claims Administrator’s complete contact information 

is: 

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[Claims Administrator to insert] 

If you return a properly completed Claim Form and Release by the deadline, you will be sent a 

settlement check after all appeals have been exhausted.

10. When will I get my payment?

It is possible that there will be an appeal of the Court’s order approving the settlement. It is always 

uncertain whether any appeals can be resolved, and resolving them can take time, perhaps more 

than a year. 

Provided that there are no appeals, you will be sent a check within approximately two months of 

submitting your Claim Form and Release. Please be patient.

11. What am I giving up if I sign the Claim Form And Release to get a payment?

Once you agree to and return the Claim Form And Release, you cannot sue, continue to sue, or be 

a party in any other lawsuit against Salo relating to the claims at issue in this case during the time 

period covered by the Settlement. It also means that all of the Court’s orders will apply to you and 

legally bind you. If you do not agree to and return Claim Form and Release by the deadline, you 

will not participate in the settlement, you will not receive any payment the settlement, you will not 

release any claims, and you will not be bound by the Court’s orders.

THE LAWYERS REPRESENTING YOU

12. Do I have a lawyer in this case?

Upon signing and returning the Claim Form and Release, you will be consenting to join this case, 

you will designate the law firm of Nilges Draher LLC to represent you. These lawyers are called 

“Plaintiff’s Counsel.” You will not be charged for these lawyers. You can find more information 

about Plaintiff’s Counsel at http://ohlaborlaw.com/. 

You do not need to retain your own attorney in order to participate in the settlement. If you want 

to be represented by your own lawyer, you may hire one at your own expense.

13. How will the lawyers be paid?

The Court has approved payment of $_________ for attorneys’ fees, plus $___ in attorneys’ actual 

out-of-pocket costs. These fees will compensate Plaintiff’s Counsel for investigating the facts, 

litigating the case, negotiating the settlement, and Plaintiff’s Counsel’s out-of-pocket costs. 

GETTING MORE INFORMATION

14. How do I get more information?

If you have other questions about the settlement, you can contact Plaintiff’s Counsel at the address 

and/or telephone number below.

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Shannon M. Draher

Hans A. Nilges

Nilges Draher LLC

7266 Portage Street NW

Suite D

Massillon, OH 44646

(330) 470-4428

DATED: ________, 2018

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Raines v. Salo, Inc., d/b/a Interim Healthcare

2:17-cv-00209 (S.D. Ohio)

Claims Administrator

[NAME]

[ADDRESS]

[ADDRESS]

[PHONE NUMBER]

CLAIM FORM AND RELEASE

INSTRUCTIONS

In order to receive any portion of the settlement funds described in the Notice of Settlement 

(“Notice”), you must sign, date, and return this Claim Form and Release to the Settlement 

Claims Administrator postmarked by the _______________2018 Bar Date 

CHANGES OF ADDRESS

It is your responsibility to keep a current address on file with the Settlement Claims 

Administrator. Please make sure to notify the Settlement Claims Administrator of any change of 

address.

Annie Raines v. Salo, Inc., d/b/a Interim Healthcare

Settlement Claims Administrator

[Name]

[Address]

[Address]

[Phone]

[DATE].

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CLAIM FORM AND RELEASE

THIS FORM MUST BE POST-MARKED OR OTHERWISE SUBMITTED TO THE SETTLEMENT CLAIMS 

ADMINISTRATOR NO LATER THAN [DATE].

I. CONSENT TO JOIN 

I understand that this lawsuit is being brought under the Fair Labor Standards Act of 1938, as 

amended, 29 U.S.C. §§ 201, et seq. (“FLSA”) and related state laws. Pursuant to 29 U.S.C. § 

216(b), I hereby consent and agree to join the case of Annie Raines v. Salo, Inc., d/b/a Interim 

Healthcare, United States District Court for the Southern District of Ohio, Case No. 2:17-cv00209. I consent and agree to be bound by any action by the Court. I further agree that the 

Plaintiff in the Litigation shall act as my agent and make all decisions on my behalf concerning the 

Litigation, including the settlement thereof. 

I hereby designate the law firm of Nilges Draher LLC to represent me in this action.

II. RELEASE 

My signature below constitutes a full and complete release and discharge of Salo, Inc. 

____________________________________ (“Salo”) and its present and former owners, 

stockholders, predecessors, successors, assigns, agents, directors, officers, employees, 

representatives, insurers, attorneys, parents, subsidiaries, affiliates, benefit plans, plan fiduciaries, 

and all persons acting by, through, under or in concert with any of them (“Salo Releasees”) by me 

and by my respective heirs, beneficiaries, devisees, legatees, executors, administrators, trustees, 

conservators, guardians, personal representatives, successors-in-interest, and assigns, from any and 

all wage and hour claims, demands, rights, liabilities, expenses, and losses of any kind, that I have, 

had, or might have had against Salo based on any act or omission that occurred at any time up to 

and including [Date Agreement is Signed], related to any of the facts or claims alleged in this 

Litigation or that could have been alleged based on the facts at issue in the Litigation, even if 

presently unknown and/or un-asserted, including but not limited to: The Fair Labor Standards Act 

of 1938 (“FLSA”), 29 U.S.C. §§ 201, et. seq. and the wage and hour laws and regulations of any 

state in which (1) I worked for Salo or (2) resided in while employed by Salo any claims that could 

be asserted against the Salo Releasees under state, federal, local and/or common law, relating to 

the failure to pay wages, back wages, overtime, minimum wages, interest on such claims, and 

attorneys’ fees, expenses and costs related to such claims in exchange for my proportionate share of 

the settlement. 

Full Legal Name (print) Signature

Maiden or other names worked under* Street Address*

City, State and Zip Code*

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E-mail Address*

Cell phone* Home Telephone Number*

*This information will be redacted and will not be filed in the public record. This information will 

be used solely for Plaintiff’s Counsel to communicate with you.

12356418 _1 130680.0025

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