Frequently Asked Questions

1. What is this website about?

This website is about a lawsuit that was filed against Hi-Tech Paintless Dent Repair and Mark Tsurkis and was recently certified as a collective action and as a class action.

2. What is this lawsuit about?

The lawsuit is about whether paintless dent repair (“PDR”) technicians who worked for Hi-Tech Paintless Dent Repair are owed unpaid overtime wages and were subject to unlawful deductions from their pay. Taras Dobrov, who previously worked as PDR technician, filed this lawsuit and claims that Hi-Tech Paintless Dent Repair and Mark Tsurkis (“Hi-Tech”) 1) misclassified Plaintiff and other PDR Technicians as independent contractors, as opposed to employees under statutory law, and failed to pay them an overtime rate for time worked in excess of 40 hours in given workweeks, as an employee would receive, in violation of the Fair Labor Standards Act (“FLSA”) and the Illinois Minimum Wage Law (“IMWL”); and 2) made unlawful deductions of “administrative surcharges” from their wages in violation of the Illinois Wage Payment and Collection Act (“IWPCA”). Dobrov is the Plaintiff. Hi-Tech is the Defendant.

Plaintiff seeks to be declared an employee under the FLSA, IMWL, and IWPCA and recover overtime wages for time he and other PDR technicians worked over 40 hours in given workweeks and reimbursement of unlawful deductions made from their pay. Plaintiff also seeks liquidated damages under the FLSA, treble damages under the IMWL, and statutory interest under the IMWL and IWPCA, plus attorneys’ fees and costs. The IMWL and IWPCA claims in this lawsuit have been certified by the court overseeing this action as a “Class Action.” The FLSA claims in this lawsuit have been certified by the court overseeing this action as a “Collective Action.”

Hi-Tech denies any wrongdoing and disputes all of the claims asserted in this lawsuit. Hi-Tech asserts that at all times PDR technicians were properly classified as independent contractors, and therefore Hi-Tech’s pay practices complied with federal and state wage and hour law and Hi-Tech’s PDR technicians were paid proper commissions for the work they performed.

The Court has not yet decided whether Plaintiff’s or Hi-Tech’s position is correct.

3. Why did I receive the Notice?

You received the Notice because you worked as a PDR technician for Hi-Tech at some time between April 20, 2015 and the present.

You are a member of the IMWL class if you worked for Hi-Tech between January 15, 2017, and the present and worked at least one full-time 40-hour week in Illinois during that period. If the Court later determines that Plaintiff’s position is correct, you may recover wages and other penalties under the IMWL for workweeks in which you worked more than 40 hours.

You are a member of the IWPCA class if you worked for Hi-Tech in Illinois between April 20, 2015, and the present and were subject to deductions of “administrative surcharges” from your wages.

You are eligible to participate in the FLSA collective action if you worked for Hi-Tech in the last three years and worked at least one full-time 40-hour week during that period. The Court may later determine that the appropriate period for recovery is two years. If the Court later determines that Plaintiff’s position is correct, you may recover wages and other penalties under the FLSA for workweeks in which you worked more than 40 hours.

4. What is the difference between the Collective Action and the Class Action?

A “Collective Action” is a lawsuit where one or more people bring claims on their own behalf, and other people can choose to join the lawsuit. You are not included in the “collective action” unless you request to join in writing.

A “Class Action” is a lawsuit where one or more people represent a large group, or “Class” of people. If you meet the requirements of the IMWL and/or IWPCA classes, you are automatically included in the class action unless you request to be excluded in writing.

5. How do I join the lawsuit?

How do I join the FLSA Collective Action?

If you meet the eligibility requirements to participate in the FLSA Collective Action and want to join, you must sign and timely complete a Consent Form. You can fill out the Consent Form electronically here or you can return the blue Consent Form in the prepaid, pre-addressed envelope, both enclosed with the Notice. You must postmark or submit the completed Consent Form by January 30, 2026.

Important: If you do nothing, you will not be able to participate in the FLSA portion of this lawsuit and will not be able to pursue your claim unless you file your own lawsuit within the required time period.

How Do I Join The IMWL and the IWPCA Class Action?

If you meet the eligibility requirements and want to be included in the IMWL and the IWPCA Class Action, do nothing. You are automatically included in the IMWL and IWPCA class action if you are eligible.

6. How do I exclude myself from the IMWL and the IWPCA Class Action?

If you want to be excluded from the IMWL and IWPCA class action, you must complete and sign the Exclusion Form. You can fill out the Exclusion Form electronically here or you can mail, email, or fax it to the following:

Lawsuit Against Hi-Tech
Stephan Zouras, LLC
222 W. Adams Street, Suite 2020
Chicago, IL 60606
lawyers@StephanZouras.com

Your Exclusion Form must be submitted, postmarked, emailed, or faxed to Stephan Zouras, LLC by January 30, 2026. You may not exclude yourself by telephone. If you properly request to be excluded before the deadline, you will not be bound by the result of this lawsuit.

7. How will this lawsuit affect me?

If you join the FLSA claims in the lawsuit and the PDR technicians win or settle the lawsuit, you may receive part of any money obtained. If you join the FLSA claims in the lawsuit and the PDR technicians lose, you will be bound by the outcome on the FLSA claims, will not be able to bring a separate lawsuit. If you join the FLSA claims in the lawsuit, you may be required to provide information or documents, appear for a deposition, testify at trial, or otherwise participate in this action. The lawyers representing the plaintiffs in this lawsuit will help you with those requirements. If you do not join the FLSA claims in the lawsuit, you will not receive any money obtained if the PDR technicians win or settle and will not be bound by the outcome of those claims if the PDR technicians lose.

If you do not exclude yourself from the IMWL and IWPCA class action claims in the lawsuit and the PDR technicians win or settle the lawsuit, you may receive part of any money obtained. If you do not exclude yourself from the IMWL and IWPCA class action claims in the lawsuit and the PDR technicians lose, you will be bound by the outcome of the IMWL and IWPCA claims and will not be able to bring a separate lawsuit. If you exclude yourself from the IMWL and IWPCA claims, you will not receive any money obtained if the PDR technicians win or settle and will not be bound by the outcome of those claims if the PDR technicians lose.

8. Who are the lawyers representing the PDR technicians and how will they be paid?

If you join the lawsuit, you will be represented by James B. Zouras, Ryan F. Stephan, Teresa M. Becvar, and members of their law firm, Stephan Zouras, LLC. If you have questions about this website or the lawsuit, please write, call, text, or email the firm as listed below.

Stephan Zouras, LLC
222 W. Adams Street, Suite 2020
Chicago, IL 60606
Email: lawyers@StephanZouras.com
Phone: (312) 233-1550
Text Message: (312) 854-8463
www.StephanZouras.com

If the PDR technicians are successful in this lawsuit, the attorneys for the PDR technicians may receive part of any money recovered and/or receive payment of attorneys’ fees and costs from Hi-Tech. If the PDR technicians lose this lawsuit, you will not have to pay any attorneys’ fees.

You also have the right to hire your own attorney to represent you in this action at your own expense.

9. Can employers retaliate against employees for joining a class and/or collective action lawsuit?

No. Federal and state laws prohibit an employer from discharging employees from employment or taking any other adverse employment action against employees because they have exercised their legal right to join a Class or Collective Action lawsuit, like this one, or because they have otherwise exercised their rights under the FLSA, IMWL or IWPCA.

This website has been authorized by the United States district Court for the Northern District of Illinois. The Court has taken no position on the merits of the lawsuit.

Do not call or write the Judge in this matter. The Judge cannot answer questions about this lawsuit or this website.