Armani Raji et al. v. The Collier Companies Inc et al.

No. If you received a Notice it's because you are a member of a class action and your rights may be affected. You may also be entitled to certain benefits. Please read the notice for more information.

Plaintiffs Armani Raji and Kimberly L. Swygert (“Plaintiffs”) filed a putative class action for alleged violations of Florida Statute § 83.49, the Florida Residential Landlord Tenant Act (“FRTLA”) and Florida Consumer Collections Practices Act, Fla. Stat. §559.55 et seq. (“FCCPA”). Plaintiffs allege that the Defendants violated these statutes when they demanded accelerated rent and/or accelerated late fees. Defendant strongly disagrees that its practices failed to comply with FRTLA or the FCCPA, but have agreed to resolve this matter to avoid the time and expense of litigation. The Plaintiffs and Defendants agreed to settle these claims in a Class Action Settlement for the monetary and non-monetary benefits and releases set forth in the Settlement Agreement. All Class Members will release Defendants from all liability from the claims in the lawsuit. Defendants will refund partial amounts paid for accelerated rent and all amounts collected for accelerated late fees based on whether a notice of termination was provided if required by the lease (Explained in more detail below); will release the Class Members from damages or amounts refunded; request removal or deletion of all credit reporting for accelerated rent and/or accelerated late fees by all credit reporting organizations to whom it has reported the debts; and will refrain from attempting to collect amounts owed for accelerated rent and/or accelerated late fees. 

You are in the Settlement Class in the Action if you meet either of the following criteria:

Actual Damages Class:

All former tenants identified in a residential lease related to any Class Property, and their guarantor(s) (if any), who received a notice demanding payment of accelerated late fees and/or accelerated rent and who did make payment to Defendants following such notice within the Class Period (the “Actual Damages Settlement Class”).

Injunctive Relief Class:

All former tenants identified in a residential lease related to any Class Property, and their guarantor(s) (if any), who, within the Class Period, received a notice demanding payment of accelerated late fees and/or accelerated rent and who did not make payment to Defendants (the “Injunctive Relief Settlement Class”).

The Court has not decided in favor of either side in this case. The Defendants deny all allegations of wrongdoing, but are settling to avoid the expense and inconvenience of continuing to litigate the case.  The Plaintiffs and the lawyers representing them (“Plaintiffs’ Counsel”) believe that settlement is in the best interest of the class because it provides substantial benefits to the class members, which the class members would not receive if the Plaintiffs lost the lawsuit or were only partially successful.  In addition, the Settlement avoids the expense and delay of pursuing the case through trial and any appeals, which might otherwise continue for several more years.

If you are a Settlement Class Member, you have a right to stay in the case as a Settlement Class Member, or you can choose to be excluded from the case. You need to decide this question very soon.

Option 1.  Fill Out and Return the Claim Form no later than February 24, 2026. Your Claim will be Evaluated and You May Receive a Money Refund.

To claim rights to your refund as part of this case, you should fill out and return the claim form that was included with your notice no later than February 24, 2026. Your claim will then be evaluated as described in this notice and in the Settlement Agreement, and you may receive a money refund. Submitting the claim form will cost you nothing, but will identify you as a member of the Actual Damages class in this case, and will preclude you from seeking your own relief in any other separate lawsuit.

If you timely submit a valid claim form then, after the Settlement is finally approved, you will automatically receive a payment and/or balance relief in accordance with the settlement agreement. If you decide to stay in the case as a Settlement Class Member, you will be bound by all orders and judgments of the Court with regard to the Settlement Class. 

Option 2. Do Nothing. You will not receive any Monetary Compensation, but you will receive all of the benefits of the Injunctive Relief Class.

If you do nothing, you will gain the same relief as every member of the Injunctive Relief Class. If you decide to stay in the case as a Settlement Class Member, you will be bound by all orders and judgments of the Court with regard to the Settlement Class.

Option 3. Exclude yourself from the Action.

You have the right to not be part of this Action by excluding yourself or “opting out” of the Settlement Class. If you exclude yourself, you will not receive a payment and/or balance relief in accordance with the settlement agreement. However, you will maintain your legal right to sue Defendants in a separate lawsuit at your own expense. 

If you wish to be excluded from the Settlement Class, you must send a written Request for Exclusion to Raji v. The Collier Companies, Inc., c/o Settlement Administrator, PO Box 23678, Jacksonville, FL 32241 no later than January 25, 2026 stating your name, address, and email address, and the following statement: “I request exclusion from the Settlement Class in Raji v. The Collier Companies, Case No. 2021-CA-000002 without condition or caveat.”

You do not need to hire your own lawyer to request exclusion from the Settlement Class, however you are entitled to retain counsel, if you so choose. If you exclude yourself from the Settlement Class, you give up your right to receive money or other benefits awarded in this case, if any, and you will not be bound by any judgments or orders of the Court.

If the request for exclusion is submitted by someone other than the Settlement Class Member (i.e., a Legally Authorized Representative or attorney), then the third party signor (e.g., attorney, legal representative, or other third party) must include the following attestation on the exclusion request: “I certify and attest to the Court that the Settlement Class Member on whose behalf this exclusion request is submitted has been provided a copy of and an opportunity to read the Class Notice and thereafter specifically requested to be excluded from the Settlement Class.” Such third-party signor must include their full name, contact information, and the legal basis for that signor’s authority to act on behalf of the Settlement Class Member.

Written requests for exclusion must be delivered to the Claims Administrator no later than January 25, 2026.

If you do not comply with these procedures, including the deadline for submitting the written request for exclusion, you will lose any opportunity you have to be excluded from the Proposed Settlement.

If you take part in the settlement and do not object to it, you do NOT have to appear at the hearing.

A copy of your marriage license, divorce decree or court order is required for a name change.

You can submit the documentation via email at [email protected]. In your email, put ‘Name Change’ in the subject line. In the body of the email, provide the NoticeID, original name, and address of the Class Member on the Notice you received. Also provide the new name, address and phone number that you would like on future correspondence.

Alternatively, you can submit the required documents by mail to: Raji v The Collier Companies, c/o Settlement Administrator, PO Box 23678, Jacksonville, FL 32241.

Two documents are required for a name change for a deceased Class Member.

They are: 1) A Copy of the death certificate, and 2) Documentation providing evidence to show the new payee as legal beneficiary – this could be a will, estate documentation, etc. The documentation will be reviewed when received. We may reach out to you with additional questions, if necessary.

You can submit these documents via email at [email protected], put ‘Name Change’ in the subject line. In the body of the email, provide the Notice ID, original name and address of the Class Member on the Notice you received. Also provide the new name, address and phone number that you would like on future correspondence.

Alternatively, you can submit the required documents by mail to: Raji v The Collier Companies, c/o Settlement Administrator, PO Box 23678, Jacksonville, FL 32241.

You have the right to not be part of this Action by excluding yourself or “opting out” of the Settlement Class. If you exclude yourself, you will not receive a payment and/or balance relief in accordance with the settlement agreement. However, you will maintain your legal right to sue Defendants in a separate lawsuit at your own expense. 

If you wish to be excluded from the Settlement Class, you must send a written Request for Exclusion to Raji v. The Collier Companies, Inc., c/o Settlement Administrator, PO Box 23678, Jacksonville, FL 32241 no later than January 25, 2026 stating your name, address, and email address, and the following statement: “I request exclusion from the Settlement Class in Raji v. The Collier Companies, Case No. 2021-CA-000002 without condition or caveat.”

You do not need to hire your own lawyer to request exclusion from the Settlement Class, however you are entitled to retain counsel, if you so choose. If you exclude yourself from the Settlement Class, you give up your right to receive money or other benefits awarded in this case, if any, and you will not be bound by any judgments or orders of the Court.

If the request for exclusion is submitted by someone other than the Settlement Class Member (i.e., a Legally Authorized Representative or attorney), then the third party signor (e.g., attorney, legal representative, or other third party) must include the following attestation on the exclusion request: “I certify and attest to the Court that the Settlement Class Member on whose behalf this exclusion request is submitted has been provided a copy of and an opportunity to read the Class Notice and thereafter specifically requested to be excluded from the Settlement Class.” Such third-party signor must include their full name, contact information, and the legal basis for that signor’s authority to act on behalf of the Settlement Class Member.

Written requests for exclusion must be delivered to the Claims Administrator no later than January 25, 2026.

If you do not comply with these procedures, including the deadline for submitting the written request for exclusion, you will lose any opportunity you have to be excluded from the Proposed Settlement.

Yes. If you are a Settlement Class Member, and if you think the Proposed Settlement is unfair, you have the right to object to the Settlement on your own or through counsel. To object, you must submit a writing containing the following: (1) a prominent identifying reference to the Action containing the title of the case, “Raji v. The Collier Companies, Case No. 2021-CA-000002”; (2) your full legal name (3) your current address and email; (4) a statement of each objection being made and the basis therefor; (5) a statement indicating whether you intend to appear at the Final Approval Hearing; (6) a list of witnesses whom you may call by live testimony; (7) if you are represented by legal counsel, the name, address, bar number, and telephone number of the counsel; (8) any legal authority upon which you intend to rely in support of the objection; and (9) copies of any documents or papers that you plan to submit or want the Court to consider.

Written objections must be filed with the Court and served upon all counsel in the Action by no later than February 9, 2026.

If you do not comply with these procedures, including the deadline for submitting written objections, you will lose any opportunity to have your objection considered by the Court or to otherwise contest the approval of the Proposed Settlement or to appeal from any orders or judgments entered by the Court in connection with the Proposed Settlement.

This notice is a summary of the Action and the Proposed Settlement. If you have any questions about this notice or the Proposed Settlement, you may contact Class Counsel at the email addresses and phone numbers listed above

Additional information about this case, the claims, and the Proposed Settlement is available on this Settlement Website or by contacting the Settlement Administrator via email at [email protected] or via USPS mail at: Raji v. The Collier Companies, Inc., c/o Settlement Administrator, PO Box 23678, Jacksonville, FL 32241.

If after reviewing the Settlement website you still have questions, you can contact Class Counsel (See “Who Represents the Settlement Class” above).

DO NOT CONTACT THE COURT OR DEFENDANTS OR DEFENDANTS’ COUNSEL FOR INFORMATION.

The Court has appointed the Plaintiffs as the representatives of the Settlement Class. The Court has also appointed the following lawyers as counsel for the Settlement Class (“Class Counsel”):

Robert G. Churchill

Churchill Law Group, PLLC

E-Mail: [email protected]

Post Office Box 5122

Tallahassee, Florida 32314

Telephone: (850) 668-6700

David H. Abrams

Law Office of David H. Abrams

E-Mail: [email protected]

Post Office Box 568587

Orlando, Florida 32856

Telephone: (850) 224-7653

Dean LeBoeuf

Brooks, LeBoeuf, Foster, Gwartney, & Hobbs P.A.

E-Mail: [email protected]

909 East Park Avenue

Tallahassee, Florida 32301

Telephone: (850) 222-2000

These lawyers represent your interest in the Action. You will not be charged for their services.

Pursuant to the settlement agreement, the Released Parties are defined as follows:

“Released Parties” shall include Plaintiffs, Defendants, class members, and all Related Parties.

Pursuant to the Settlement Agreement, the following claims are released:

“Released Claims” means all claims arising from or relating to Defendant’s charges for accelerated rent or accelerated late fees during the Class Period, arising from or relating to Defendant’s compliance with FRLTA, arising from or relating to Defendant’s compliance with FCCPA, or all claims which could have been asserted in this action, as defined in Paragraph 6(1) on page 23 of the Settlement Agreement. You are encouraged to review Section 6(1) of the Settlement Agreement for a full and complete understanding of the Released Claims.

Specifically, if the Settlement is finally approved, Plaintiffs and each Settlement Class Member (except Settlement Class Members who have excluded themselves from the Settlement Class) will release the Defendants and all Related Parties from all Released Claims that they have or could have asserted in this lawsuit.