The Notice is to tell you about the Settlement of a class action lawsuit, Fredericks v. Ameriflight, brought on behalf of pilots who worked for Ameriflight under a training repayment agreement. You received the Notice because you may be entitled to money as part of the Settlement. The Notice tells you how to get more information about the Settlement and ensure that you receive all payments owed to you.
The Settlement is on behalf of the following classes/collectives:
a. Opt-in Plaintiffs: comprised of the individuals who consented to join the FLSA collective during the opt-in period (excluding individuals who are no longer represented by Plaintiff’s counsel). It does not include individuals who received an opportunity to opt in to the FLSA claims but did not do so.
b. Unlawful Penalty Class: the class certified by the Court on November 25, 2024, which is defined as: “Pilots with a Beechcraft 99 repayment agreement who left employment with Ameriflight before the term of the repayment plan was complete.” The Rule 23 class only includes pilots who completed training, and were under the Beechcraft 99 training repayment agreement between January 30, 2019, and February 28, 2025. Pilots who signed repayment agreements for aircraft other than the Beechcraft 99 are not included in the class.
c. Some individuals are both Opt-in Plaintiffs and members of the Unlawful Penalty Class
The total amount of the Settlement is $425,000 (“Settlement Fund”). This amount is non-reversionary, meaning that no part of the Settlement Fund will revert back to Ameriflight. The Settlement contemplates allocation of the Settlement Fund as follows:
• Attorneys’ fees in an amount not to exceed $170,000
• Reasonable litigation costs incurred by class counsel, in an amount not to exceed $45,000;
• Service award of $10,000 for the named plaintiff, Kathleen Fredericks;
• Costs of settlement administration in an amount not to exceed $10,000;
• Remainder of the Settlement Fund (“Net Settlement Fund”), an amount no less than $190,000, to be distributed to the 19 opt-in plaintiffs and one member of the unlawful penalty class who made post-employment payments to Ameriflight.
The attorneys will submit a detailed fee petition, justifying their request for attorneys’ fees, to the Court two weeks before the end of the objection period, on April 13, 2026, which will be made available here.
The monetary part of the Settlement has two parts: Reimbursement for training payments made after Opt-in Plaintiffs and Unlawful Penalty Class Members left Ameriflight; and Minimum wage damages.
Reimbursement for training payments: To the extent that any Opt-in Plaintiff or Unlawful Penalty Class Member made post-employment payments to Defendant pursuant to a training repayment agreement, they will receive an amount equal to the total amount that they paid to Ameriflight and/or any third-party debt collection company, including interest and collection costs. These amounts shall be paid as non-taxable reimbursements, subject to consultation with tax advisors.
Minimum wage damages: If the Court approves the Settlement, approximately two months after the Reimbursement for training payments, Opt-in Plaintiffs will receive a second payment, which represents compensation for the minimum wage violations alleged in this Lawsuit. This amount will be allocated to Opt-in Plaintiffs proportional to their total regular earnings while employed by Defendant (regular hours multiplied by wage rate). These amounts shall be paid 50% as wages and 50% as liquidated damages/1099 other income.
Your payment will be sent via paper check. If you would like to select an alternative payment option, you may do so here.
As part of the Settlement, Ameriflight has agreed to declare that its training repayment agreements entered into by the Opt-in Plaintiffs and members of the Unlawful Penalty Class are null and void. Ameriflight will release entitlement to and discontinue all collections efforts under the agreements, which amounts to approximately $852,128 in waived balances. Ameriflight will decline to enforce the non-competition provisions of the contracts that certain class members signed.
As part of the Settlement, Ameriflight has agreed to declare that its training repayment agreements entered into by the Opt-in Plaintiffs and members of the Unlawful Penalty Class are null and void. This means that you have no further obligations to Ameriflight under the agreement. You will release Ameriflight of and from all known and unknown claims for an unlawful kickback and/or failure to pay wages free and clear under the Fair Labor Standards Act, and any other claims that were asserted or that could have been asserted under state or federal wage and hour laws based on the facts alleged in the operative Complaint. You will also release Ameriflight of and from the unenforceable penalty claim that was asserted or could have been asserted based on the facts alleged in the operative Complaint.
The Opt-in Plaintiffs will release Ameriflight “of and from all known and unknown claims for an unlawful kickback and/or failure to pay wages free and clear under the Fair Labor Standards Act, and any other claims that were asserted or that could have been asserted under state or federal wage and hour laws based on the facts alleged in the operative complaint.”
The Unlawful Penalty Class members will release Ameriflight “of and from the unenforceable penalty claim that was asserted or could have been asserted based on the facts alleged in the operative complaint.”
Any member of the Unlawful Penalty Class who intends to object to the fairness of the Settlement must, no later than April 27, 2026, send their objection to the Settlement Administrator, Atticus Administration. Any objection to the Settlement must include: (i) the objector’s full name, address, email address, and telephone number; (ii) a written statement of all grounds for the objection; (iii) a statement whether the objector intends to appear at the Final Approval Hearing; and (iv) the objector’s signature.
You may submit a change of address via the website here. Alternatively, you may contact the Settlement Administrator via email at [email protected].