Navigate
Fighting for Fair Pay

DMV Protection Notice of Class Action Lawsuit

Notice of Opportunity to Join Federal Unpaid Overtime Pay Lawsuit and Notice of Class Action Lawsuit

 If you have worked as a security guard at DMV Protection, LLC between August 4, 2022, and the present, please read this notice.

This Is a Court Authorized Notice.

Please read this notice to learn about the lawsuit, how your rights may be affected, and what your options are.

  • A lawsuit was brought by a former DMV Protection, LLC (DMV) security guard who claims that DMV Protection failed to pay security guards overtime for the hours they worked over 40 in a workweek as required by the federal Fair Labor Standards Act (FLSA).
  • The security guard also brings class action wage and hour claims under the laws of Maryland, Virginia, and Washington D.C.
  • This lawsuit is proceeding as a collective action under the FLSA and as a class action under the wage and hour laws of Maryland, Virginia, and Washington D.C. on behalf of individuals who worked for DMV Protection, were classified as independent contractors, at any time from August 4, 2022, to the present and who worked over 40 in at least one workweek.
  • The Court hasn’t determined if the Plaintiff’s position or the Defendant’s position is the correct one.

 

YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT
 

Ask to be included in the federal portion by completing the consent sue form

 If you choose to be included in the federal portion of the lawsuit under the Fair Labor Standards Act, you will share in any monetary recovery that might come from a trial or a settlement in this lawsuit. You give up any rights to separately sue DMV Protection about the same legal claims in this lawsuit. If you wish to be included, you must complete and submit the “Consent to Sue” form on or before (if by mail, postmarked on or before) June 13, 2026.
 

Do nothing

 By doing nothing, you will not be included in the FLSA portion of the lawsuit. This means that you give up the possibility of monetary recovery that may come from a trial or settlement under the FLSA, if those bringing the lawsuit are successful. But you will be part of the Maryland, Virginia and/or Washington D.C. class claims.

You keep any rights to sue DMV Protection separately about the same legal claims in this lawsuit, but the limitations period on your federal claim will continue to run.
Exclude yourself By excluding yourself, you give up any right to receive a payment if the Plaintiffs are successful. You won’t give up any legal rights.

 

 

  1. WHY DID I GET THIS NOTICE?

You are getting this notice because DMV Protection’s records show that you worked more than 40 hours in at least one workweek between August 4, 2022, and the present.

  1. WHAT IS THIS CASE ABOUT?

The lawsuit alleges that DMV Protection failed to pay security guards overtime under the federal Fair Labor Standards Act (“FLSA”) and Maryland, Virginia, and Washington D.C. laws for the hours they worked over 40 in a workweek, misclassified them under Virginia’s Misclassification law, and failed to pay security guards for all hours worked as required under Maryland, Virginia, and Washington D.C. laws. Specifically, Plaintiff alleges that security guards were unlawfully classified as independent contractors, that they routinely worked over 40 hours in a workweek, that DMV Protection subjected security guards to unlawful wage withholding policies, failed to pay for all hours worked, and that DMV Protection unlawfully failed to pay them overtime. DMV Protection denies these allegations and states that it has properly classified the workers as independent contractors. The Court has not yet decided who is correct.

The lawsuit is known as Rangel v. DMV Protection, LLC, et al., 1:25-cv-01288, and is pending before the Honorable Anthony J. Trenga, United States District Judge in the Eastern District of Virginia.

  1. HOW DO I JOIN THE FEDERAL PORTION OF THE LAWSUIT?

To join the federal portion of the lawsuit, you must return a completed Consent to Sue Form. By scanning the QR Code below you complete the form online. Or you may forward it to the attorneys designated in the Form by email to DMVOvertime@getmansweeney.com, by facsimile to 845-255-8649, or by U.S. mail, postmarked on or before, June 13, 2026.

  1. HOW DO I PARTICIPATE IN THE CLASS ACTION?

Each security guard who falls within the above class definition, which DMV’s records indicate includes you, are automatically a member of the Class and part of this lawsuit, unless you affirmatively ask to exclude yourself. If you choose not to exclude yourself from the lawsuit, you will be bound by the judgment of the court, regardless of whether that judgment is favorable or unfavorable to you. If the court determines that DMV is liable for damages or a settlement is reached in the lawsuit, you will share in any money received in the lawsuit. If the court determines that DMV is not liable for damages, you will not receive a recovery.

If you participate in this lawsuit, you will be represented by Class Counsel and Local Counsel listed below that the court has approved to represent the Plaintiffs and members of the Class. You may also contact them if you have any questions or concerns.

Matt Dunn
GETMAN, SWEENEY & DUNN, PLLC
260 Fair Street
Kingston, NY 12401
Phone: 845-255-9370
Fax: 845-255-8649
DMVOvertime@getmansweeney.com
www.GetmanSweeney.com
Class Counsel

Timothy Coffield (VSB No. 83430)
Coffield PLC
106-F Melbourne Park Circle
Charlottesville, VA 22901
Phone: 434-218-3133
Fax: 434-321-1636
tc@coffieldlaw.com
www.coffieldlaw.com/
Local Counsel

You do not have to pay any upfront fees for the services of Class Counsel or for any of the costs of bringing this lawsuit. The attorneys for the Class will be paid on a contingency fee basis if they are successful at trial or through settlement. The attorneys will be paid up to 1/3 of the fund generated by their work or their earned fees, whichever is greater. The court will determine the fairness of any fees to be awarded if it enters a judgment in Plaintiffs’ favor or a settlement is reached. If the court enters judgment in favor of DMV, you will owe Class Counsel nothing.

If you participate in the case, you may need to provide discovery, sit for deposition, and/or attend trial.

  1. CAN DMV PROTECTION FIRE OR RETALIATE AGAINST ME IF I JOIN THE LAWSUIT?

The law strictly prohibits any employer from retaliating against employees for exercising their rights under the FLSA. Therefore, you may not be terminated or subjected to discrimination in any manner for exercising your rights under the FLSA, including by joining this lawsuit.

  1. HOW TO EXCLUDE YOURSELF IF YOU DO NOT WANT TO BE PART OF THIS CASE.

The Court will exclude from this case any class member who requests to be excluded. To request to be excluded from this case, send a letter indicating your desire to not be part of the case, by mail or fax, to the Plaintiffs’ lawyers (contact information below) to be postmarked no later than June 13, 2026.

If you exclude yourself from this case, you will not participate in the result of this case whether favorable or unfavorable to the class. You will retain the right to start your own lawsuit against DMV if you want, however you will have to hire and pay your own lawyer for that lawsuit, and you will have to prove your claims. Any such claims may be subject to a statute of limitations.

THIS NOTICE HAS BEEN AUTHORIZED BY THE U.S. DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA. PLEASE DO NOT CONTACT THE COURT. ADDRESS ANY QUESTIONS OR INQUIRIES TO IDENTIFIED COUNSEL.