In this wage and hour lawsuit Dr. Dwight Steward was retained to conduct a survey to determine the amount if any of off-the-clock work performed by class members prior to the start of shift during meal and rest breaks and after the start of shift on behalf of the defendants Wackenhut and Oracle. Dr. Steward reviewed the case documents including the plaintiff’s first amended complaint and the order granting class certification prior to designing his multi-question survey. The survey asked class members about the amount of time they worked before and after the scheduled shifts how often they received meal and rest breaks as well as how often their breaks were interrupted to perform work on behalf of the defendants. The survey was administered in three steps. First a postcard was sent to each class member informing them they would be receiving a survey in the mail. The survey was then sent to all class members. A follow-up postcard was sent to each class member who had not responded to the survey in a timely manner with a toll-free phone number that enabled the class member to complete the survey telephonically. Dr. Steward’s report included his findings for each of the subjects reviewed in the survey. His report also included statistical confidence intervals for each of the survey statistics.