Frequently Asked Questions





YOU MUST RETURN A CLAIM FORM BY FEBRUARY 8, 2022 TO RECEIVE A PAYMENT FROM THE SETTLEMENT


This lawsuit is known as Alvarez et al. v. Chipotle Mexican Grill, Inc. et al., Case Number 2:17-cv-04095-KM-JBC. The Court in charge of this case is the U.S. District Court for the District of New Jersey. The lawsuit claims that Chipotle improperly classified Apprentices as exempt from federal and state overtime laws, which means it did not pay overtime wages when Apprentices worked more than 40 hours in a workweek. Chipotle denies that it did anything wrong and believes that Apprentices were properly paid as employees who are exempt from federal and state overtime requirements. The parties have agreed to settle the lawsuit, and no party has won.

Chipotle’s records state that you worked as an Apprentice in New Jersey between June 7, 2014, and July 15, 2019, or in any state other than New Jersey, California, New York, or Texas between June 18, 2017, and August 25, 2020 (the periods covered by the lawsuit).

The Court ordered that you be sent this notice to give you the chance to receive a share of the money being paid to settle this case. This notice explains the lawsuit, the settlement, and your legal rights.

Chipotle has agreed to pay a total of $15,000,000 to settle the lawsuit. If you return the Claim Form enclosed with this Notice on time, you will be paid a share of this settlement fund.

The Court has approved the following payments from the fund: (i) payment to you and to any of the rest of the approximately 4,838 Apprentices who worked at Chipotle during the time and in the states covered by this case; (ii) payment of additional amounts to compensate the people who led this case in recognition of the risks they took and their service to the case, in the amounts of up to: $30,000 for lead named plaintiff Carmen Alvarez, $10,000 for named Plaintiff Asher Guni, and $2,500 for Opt-In Plaintiff Joie Dickerson; (iii) the costs for the third-party vendor that is administering this settlement in an amount that will not exceed $52,000; (iv) Chipotle’s share of actual payroll taxes for the portion of settlement payments that are considered wages; and (v) payment of fees to the attorneys who litigated this case for several years not to exceed $5,000,000 plus reasonable out-of-pocket costs.

The full terms of the settlement can be found here

The amount of your portion of the settlement, based on a formula that has been approved by the Court, can be found on your Claim Form after logging into this website and in the Settlement Notice that was mailed and emailed to you. If you do not have the Notice and Claim Form, you can call the administrator at 877-888-9446 to request a re-mailing or ask about your estimated award.

Half of this payment is subject to deductions for taxes and other withholdings like any other paycheck, for which you will receive a W-2, and the other half will have no withholding and you will receive a tax form 1099.

The formula used for determining Apprentices’ settlement payments is based on the number of weeks you worked as an Apprentice during the periods and states covered by the settlement. The Settlement Agreement explains the exact allocation formula. You may obtain a copy of the Settlement Agreement by contacting the Settlement Claims Administrator at the address listed below or by clicking here.

Neither the lawyers for the Plaintiffs nor for Chipotle are giving you advice about what taxes may or may not be owed on the money you receive through the settlement. You should seek the advice of a tax professional.

In order to receive a payment through this settlement, you must sign and return the enclosed Claim Form to the Settlement Claims Administrator by February 8, 2022. There are four ways you can return your Claim Form:

  • Mail: If you mail your Claim Form, it must be postmarked no later than February 8, 2022

Chipotle Overtime Settlement
Claims Administrator
c/o A.B. Data, Ltd.
PO Box 170800
Milwaukee, WI 53217
Phone: 877-888-9446

  • Email: info@ApprenticeSettlement.com
  • Fax: 414-961-2742
  • Online Submission: You may submit your Claim Form through this website by logging in on the homepage of www.ApprenticeSettlement.com using your Notice ID and last four digits of your social security number, then filling out the Claim Form found on the landing page.
If you fax, email, or submit your Claim Form online, it must be received no later than February 8, 2022.

After you submit your Claim Form, you will be issued a check mailed to the address you provide on the Claim Form which will constitute your payment of the share of settlement proceeds.


If you wish to change the name or address listed on the envelope in which the Notice you received was sent, please inform the settlement administrator of your new address. By filling out the Claim Form found after logging in on www.ApprenticeSettlement.com and using your new address, it will automatically update. If your address changes after you fill out the Claim Form, if it is prior to February 8, 2022, you may fill out the form a second time online to update with your new address. You can also update your address by calling 877-888-9446, or by sending a letter to the address above.

Checks will be mailed to you at the address provided on your Claim Form on April 1, 2022. You will have 180 calendar days after the date your settlement check is issued to cash your settlement check.

If you return a properly completed Claim Form by the deadline, you will be giving up the right to sue Chipotle for all claims of unpaid overtime or other wages, arising from your employment as an Apprentice, including claims based on Chipotle’s classification of Apprentices and any other facts alleged in this lawsuit, and related claims for penalties, interest, liquidated damages, attorneys’ fees, costs, and expenses, as described below:
  • If you worked as an Apprentice in New Jersey, you will give up any claim for wages that accrued between June 7, 2014, and September 21, 2021.
  • If you worked as an Apprentice in a state other than New Jersey, California, New York, or Texas, you will give up any claim for wages that accrued between June 18, 2017, and September 21, 2021.
If you do not want to give up these claims, then you should not return the Claim Form.

If you are a participant in Maxcimo Scott, et al., v. Chipotle, No. 1:12-cv-8333-ALC-SN (S.D.N.Y 2012), any claims for weeks you worked covered by that case will not be released by this settlement.

It is against the law to retaliate or discriminate against an employee who decides to participate in this settlement agreement. Chipotle will not discriminate or retaliate against you because of your decision to participate or not in this settlement.

Three law firms, Outten & Golden LLP, Cohen Milstein Sellers & Toll PLLC, and Green Savits LLC, brought this lawsuit and serve as the lawyers for the Apprentices in this case. The lawyers are available to answer any questions. They can be reached at the telephone numbers and email addresses below. The lawyers are being paid for all their work in this case, including answering any questions you may have, from a share of the settlement fund, as explained in Section 3 above.

Justin M. Swartz
Melissa L. Stewart
Jennifer Davidson
OUTTEN & GOLDEN LLP
685 Third Avenue, 25th Floor
New York, NY 10017
Telephone: (212) 245-1000
Website: www.outtengolden.com
Email: ChipotleApprenticeSettlement@outtengolden.com
Joseph M. Sellers
Harini Srinivasan
COHEN MILSTEIN
SELLERS & TOLL PLLC
1100 New York Ave., N.W., Ste. 500
Washington, DC 20005
Telephone: (202) 408-4600
Website: www.cohenmilstein.com
Email: cscherman@cohenmilstein.com

This FAQ page summarizes the basic terms of the proposed settlement. If you have additional questions about the settlement or want more information, you can contact the Settlement Claims Administrator or Plaintiffs’ Counsel at the addresses and/or telephone numbers below.

Justin M. Swartz
Melissa L. Stewart
Jennifer Davidson
OUTTEN & GOLDEN LLP
685 Third Avenue, 25th Floor
New York, NY 10017
Telephone: (212) 245-1000
Website: www.outtengolden.com
Email: ChipotleApprenticeSettlement@outtengolden.com
Joseph M. Sellers
Harini Srinivasan
COHEN MILSTEIN
SELLERS & TOLL PLLC
1100 New York Ave., N.W., Ste. 500
Washington, DC 20005
Telephone: (202) 408-4600
Website: www.cohenmilstein.com
Email: cscherman@cohenmilstein.com