TO: All current and former Customer Service Representatives (“CSRs”) who performed customer service duties for Centene Corporation or Centene Management Company, LLC (“Centene”) as temps/contingent workers at their brick-and-mortar service center facilities or remotely, and used the Beeline system, at any time from February 1, 2019 to the present.
DATE: May 16, 2022
RE: Fair Labor Standards Act (“FLSA”) lawsuit against Centene seeking compensation for overtime for hours worked by Customer Service Representatives who were temps/contingent workers and used the Beeline System.
Oliver et al. v. Centene Corp., et al, Case No. 4:21-cv-00199-RLW, pending in the United States District Court for the Eastern District of Missouri.
The purpose of this Notice is to inform you of the existence of a collective action lawsuit against Centene. The Court has determined that you may be similarly situated to Denasha Oliver and Jacki Livingston, the Named Plaintiffs who brought this case. Therefore, the Court has ordered that this Notice may be sent to you and that the lawsuit be explained so that you can decide whether to opt in (join the lawsuit).
Please note that the Court has not ruled on the merits of the lawsuit. The Court has only ruled that you may be notified of the existence of the lawsuit so that you can determine whether you wish to join it.
Plaintiffs, Denasha Oliver and Jacki Livingston (“Plaintiffs”), brought this action under the Fair Labor Standards Act (“FLSA”) on behalf of themselves and all other past and current CSRs who performed customer service duties for Centene as temps/contingent workers, and used the Beeline system, at any time from February 1, 2019 to the present.
Plaintiffs contend that they and other CSRs are owed overtime pay under the FLSA. Specifically, Plaintiffs allege that Centene violated the FLSA by requiring CSRs to routinely perform certain pre-shift, meal-period, and post-shift activities off-the-clock without pay. These activities include starting up and shutting down their computers and logging into, loading, and closing various computer software programs and applications used throughout their shifts, as well as reading emails and logging calls off-the-clock. Plaintiffs contend that by prohibiting, encouraging, or pressuring CSRs from including these pre-, mid-, and post-shift activities in their compensable time by virtue of attendance adherence policies, Plaintiffs and other CSRs were forced to perform some or all the above referenced tasks off the clock. Plaintiffs allege that they and all employees similarly situated are entitled to recover unpaid overtime pay, liquidated damages (equal to the unpaid overtime pay) and interest, attorneys’ fees, and costs associated with bringing this lawsuit.
Centene denies all of Plaintiffs’ allegations and denies any wrongdoing whatsoever.