NOTICE OF YOUR RIGHT TO JOIN A LAWSUIT FOR UNPAID WAGES AGAINST AJ, INC. d/b/a SUSHI O SUSHI, KI SOOK LEE AND KYUNG LEE
This is a Court-Authorized Notice, not a solicitation from a lawyer. The Court has taken no position on the claims in this lawsuit.
DATED: December 5, 2025
TO: All non-managerial employees paid a salary for work performed at Sushi O Sushi at any time between August 28, 2021 and the present
RE: Gaudreau v. AJ, Inc. d/b/a Sushi O Susho, et. al., 1:23-cv-02202-MDB (D. Colo.)
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INTRODUCTION
You are receiving this letter because you were a non-managerial employee paid a salary for work performed at Sushi O Sushi at some time between August 28, 2021 and the present.
If the above is accurate, you may be owed unpaid overtime wages. If you claim you are owed unpaid overtime wages, you may have the right to join a lawsuit against Sushi O Sushi and Ki Sook Lee and Kyung Lee (“Defendants” or “Sushi O Sushi”), in which you may be able to recover any unpaid wages. This letter will explain to you how to join the lawsuit and how your rights will be affected by your decision to join or not to join; please read it carefully.
If you claim to be owed wages by Sushi O Sushi and wish to joint this lawsuit, you must send the enclosed “Consent to Join Lawsuit” form to the law offices of Milstein Turner, PLLC by e-signature, e-mail, text message or U.S. postal mail, before February 3, 2025. If your consent form is not received or postmarked by this date, you will not be able to share in any federal overtime wages or liquidated damages that may be recovered in the lawsuit.
If you decide to join this lawsuit to recover such wages, you must complete, sign and date the consent form by February 3, 2025 to:
Andrew H. Turner
Milstein Turner, PLLC
1490 Lafayette Street, #304
Denver, CO 80218
Phone: 303-305-8230
[email protected]
DESCRIPTION OF THE LAWSUIT
Matthew B. Gaudreau (“the named representative Plaintiff”) – has sued Sushi O Sushi, Ki Sook Lee and Kyung Lee to recover overtime wages he claims he is owed. The named representative Plaintiff claims that Sushi O Sushi violated federal law when it failed to pay overtime wages to salaried workers. The Plaintiff claims that he is entitled to recover allegedly unpaid overtime wages, as well as liquidated damages. He also argues that, as provided under the law, he should be paid his “reasonable” attorneys’ fees and costs.
Sushi O Sushi denies that its workers were not properly compensated and otherwise denies Mr. Gaudreau’s complaints. This Notice is not an expression by the Court of any opinion as to the merits of any claims or defenses asserted by any party to this action. These claims are contested and have not yet been determined in favor of or against any party.
NO RETALIATION PERMITTED
Both state and federal law prohibit Sushi O Sushi, Ki Sook Lee, Kyung Lee and any other individuals or companies from retaliating against anyone who participates in this lawsuit. They cannot harass, intimidate, or otherwise threaten you for having joined the lawsuit. If you are currently employed by them, they cannot terminate your employment or otherwise take action or discriminate against you because of your decision to participate in this case. Defendants will not retaliate against any worker who chooses to participate in this case.
THE CLASS OF EMPLOYEES ELIGIBLE TO JOIN THIS SUIT
All non-managerial employees paid a salary for work performed at Sushi O Sushi at any time between August 28, 2021 and the present are eligible to join.
YOUR RIGHT TO JOIN THIS LAWSUIT
If you were paid a salary and you worked at Sushi O Sushi at any time between August 28, 2021 and the present, and you believe you are owed overtime wages, you have the right to file a claim for these unpaid wages by completing and returning the attached form to join, or “opt-in,” to this lawsuit (also known as becoming an “opt-in” Plaintiff).
Your decision to join or not to join this lawsuit is your own. You are not prohibited from filing your own lawsuit to recover unpaid wages if you choose not to join this lawsuit. You may hire an attorney to do so (or do so yourself, without an attorney). In addition, if you do choose to join, your continued right to participate in the lawsuit, and your right to recovery of monies, will depend on the Court’s determination as to whether you worked for Defendants and whether you were not properly compensated.
THE LEGAL EFFECT OF JOINING THIS LAWSUIT
You will not be charged any money if you join this case. If you choose to join this lawsuit, you will be bound by any judgment or settlement, whether it is favorable or unfavorable. While the suit is proceeding, you may be required to provide information about your employment, sit for a deposition, and/or testify in court.
THE LEGAL EFFECT OF NOT JOINING THIS LAWSUIT
If you choose not to join this lawsuit, you will not receive any federal overtime or liquidated damages payments if Plaintiff succeeds. But, you will also not be affected by any judgment or settlement, favorable or unfavorable, in this action. If you choose not to join this lawsuit, any relief you may be entitled to would only be recoverable by you through a lawsuit you separately file with your own attorney. The FLSA typically requires that any lawsuits must be filed within two years of the employer’s violation.
LEGAL REPRESENTATION
The Attorney for the named Plaintiff is Andrew H. Turner, MILSTEIN TURNER, PLLC, 1490 Lafayette St. #304, Denver, CO. 80218, Tel: (303) 305-8230, [email protected]. You have the right to retain different attorneys, at your own expense, if you so choose.
HOW THE ATTORNEYS ARE PAID
If you choose to join this action and to be represented by the attorney for the Plaintiffs listed above, you will not have to pay said attorneys directly – whether this case is settled, won or lost. Instead, if wages are awarded or the parties settle, the attorney will be paid by Defendants either their hourly fees plus litigation costs as awarded by the Court, or 33 1/3% of the total money recovered in the case, whichever is greater, or such other amount set by the Court. If wages are not awarded or the case is not settled or is lost, the attorney will not be paid.
HOW AND WHEN TO JOIN THIS LAWSUIT
If you wish to join this lawsuit, you must complete, date, sign, and e-sign, mail, email or text the enclosed form by February 3, 2025 to:
Andrew H. Turner
Milstein Turner, PLLC
1490 Lafayette St., #304
Denver, CO 80218
303-305-8230
[email protected]
If your consent form is not received or postmarked by this date, you will not be entitled to any portion of claimed federal overtime wages or liquidated damages that may be recovered from Defendants in this lawsuit.
ADDITIONAL INFORMATION
If you need further information regarding this case, please call or email the Plaintiffs’ lawyer, Andrew Turner, at (303)-305-8230 or [email protected]. Please do not call the Court Clerk.