Confidential

Facts

This is a class action suit brought by approximately 4,000 employees of two hospitals owned by the defendant.
The plaintiffs alleged that they were not paid properly. The plaintiffs contended that their overtime pay was not
calculated correctly, because the defendants paid overtime based on a "base rate" and failed to include shift
differentials, callback pay, supplemental shift pay and other forms of pay in their regular rate for the purposes
of calculating overtime.
The plaintiffs also contended that the defendants had improperly implemented 10 and 12 hour shifts, and that
the plaintiffs were entitled also to back pay for unpaid meal and break periods.
The defendants admitted that there were some underpayments, but that the violations
were de minimis. The defendants contended that proper secret ballot elections were held in all
units prior to the implementation of extended shifts, and that all other legal requirements were
met.