`FILED
`
`U.S. DISTRICT COURT
`EASTERN DISTRICT ARKANSAS
`IN THE UNITED STATES DISTRICT COURT
`MAY 1 8 2021
`EASTERN DISTRICT OF ARKANSAS
`CENTRAL DIVISION
`JAMES W. Mc-K, CLERK
`By:
`-
`
`LAEARTHA BANKS and ARIA
`LAMBERT, Each Individually and on
`Behalf of All Others Similarly Situated
`No. 4:21-cv- '/1q - JM
`
`vs.
`
`DEPCLERK
`PLAINTIFFS
`
`CENTENE MANAGEMENT COMPANY, LLC,
`DEFENDANTS
`and CENTENE CORPORATION This case assigned to District Judge Ma~
`and to Magistrate Judge __.Vi .... o .. LfC'pe.~,"-----(cid:173)
`ORIGINAL COMPLAINT-COLLECTIVE ACTION
`
`COME NOW Plaintiffs Laeartha Banks and Aria Lambert ("Plaintiffs"), each
`
`individually and on behalf of all others similarly situated, by and through their attorneys
`
`Daniel Ford and Josh Sanford of Sanford Law Firm, PLLC, and for their Original
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`Complaint-Collective Action ("Complaint") against Defendants Centene Management
`
`Company, LLC, and Centene Corporation ( collectively "Defendant" or "Defendants"), they
`
`state and allege as follows:
`
`I.
`
`PRELIMINARY STATEMENTS
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`1.
`
`This is a collective action brought by Plaintiffs, each individually and on
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`behalf of all others similarly situated, against Defendant for violations of the overtime
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`provisions of the Fair Labor Standards Act, 29 U.S.C. § 201, et seq. (the "FLSA"), and the
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`overtime provisions of the Arkansas Minimum Wage Act, Ark. Code Ann.§ 11-4-201, et
`
`seq. (the "AMWA").
`
`2.
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`Plaintiffs seek a declaratory judgment, monetary damages, liquidated
`
`damages, prejudgment interest, and a reasonable attorney's fee and costs as a result of
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`Page 1 of 12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complaint-Collective Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 2 of 14
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`Defendant's policy and practice of failing to pay proper overtime compensation under the
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`FLSA and the AMWA.
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`II.
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`JURISDICTION AND VENUE
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`3.
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`The United States District Court for the Eastern District of Arkansas has
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`subject matter jurisdiction over this suit under the provisions of 28 U.S.C. § 1331 because
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`this suit raises federal questions under the FLSA.
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`4.
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`This Complaint also alleges AMWA violations, which arise out of the same
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`set of operative facts as the federal cause of action; accordingly, this Court has
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`supplemental jurisdiction over Plaintiff's AMWA claims pursuant to 28 U.S.C. § 1367(a).
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`5.
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`Plaintiffs were employed by and performed work for Defendant in Little
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`Rock; therefore, venue is proper within the Central Division of the Eastern District of
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`Arkansas pursuant to 28 U.S.C. § 1391.
`
`Ill.
`
`THE PARTIES
`
`6.
`
`Plaintiff Laertha Banks ("Banks") is an individual and resident of Pulaski
`
`County.
`
`7.
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`Plaintiff Aria Lamber ("Lambert") is an individual and resident of Pulaski
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`County.
`
`8.
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`Separate Defendant Centene Management Company, LLC ("Centene
`
`Management"), is a foreign limited liability company.
`
`9.
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`Centene Management's registered agent for service of process is C T
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`Corporation System, at 120 South Central Avenue, Clayton, Missouri, 63105.
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`10.
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`Separate Defendant Centene Corporation ("Centene Corporation") is a
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`foreign, for-profit corporation.
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`Page 2 of 12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complaint-Collective Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 3 of 14
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`11 . Centene Corporation's registered agent for service of process is C T
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`Corporation System, at 120 South Central Avenue, Clayton, Missouri, 63105.
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`12. Defendants, in the course of their business, maintain a website at
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`https://www.centene.com/.
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`IV.
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`FACTUAL ALLEGATIONS
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`13.
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`Plaintiffs repeat and re-allege all the preceding paragraphs of this Complaint
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`as if fully set forth in this section.
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`14. Defendants provide healthcare plans and services to its customers.
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`15. Defendants have unified operational control and management, as well as
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`control over employees, including shared power to supervise, hire and fire, establish
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`wages and wage policies and set schedules for their employees through unified
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`management.
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`16. Upon information and belief, the revenue generated from Centene
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`Management and Centene Corporation was merged and managed in a unified manner.
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`17.
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`As a result of this unified operation, control and management, through
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`shared employees and ownership with the authority to establish wages and wage policy,
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`Defendants operated as a single enterprise.
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`18. Within the three years preceding the filing of this Complaint, Defendant has
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`continuously employed at least four employees.
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`19. Defendant employs two or more individuals who engage in interstate
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`commerce or business transactions, or who produce goods to be transported or sold in
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`interstate commerce, or who handle, sell, or otherwise work with goods or materials that
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`have been moved in or produced for interstate commerce.
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`Page 3 of 12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Orlglnal Complaint-Collective Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 4 of 14
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`20.
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`Defendant's annual gross volume of sales made or business done is not
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`less than $500,000.00 (exclusive of excise taxes at the retail level that are separately
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`stated) in each of the three years preceding the filing of the Original Complaint.
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`21.
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`At all times material herein, Plaintiffs have been entitled to the rights,
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`protections, and benefits provided under the FLSA.
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`22.
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`Defendant employed Banks as a Utilization Manager from February of 2019
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`until March of 2021.
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`23. Defendant employed Lambert as a licensed practical nurse and concurrent
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`review nurse from July of 2019 until February of 2021.
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`24. Defendant classified Plaintiffs as non-exempt
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`from
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`the overtime
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`requirements of the FLSA and paid them an hourly wage.
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`25.
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`Plaintiffs worked at Defendant's location in Little Rock.
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`26. Defendant also employed other hourly-paid employees to perform the work
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`necessary to its business (hereinafter referred to as "hourly employees")
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`27.
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`In addition
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`to
`
`their hourly wage, Plaintiffs
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`regularly
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`received
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`nondiscretionary bonuses ("bonuses").
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`28.
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`Specifically, Plaintiffs received referral bonuses, as well as annual bonuses
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`based on employee performance and the company's profitability.
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`29.
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`The bonuses are nondiscretionary because they are based on objective and
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`measurable criteria, and because Plaintiffs expected to receive the bonuses and did in
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`fact receive the bonuses on a regular basis.
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`30. Upon information and belief, all or most hourly employees received
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`bonuses.
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`Page4of12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complalnt-Collectlve Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 5 of 14
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`31.
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`Defendant informs its hourly employees of the bonuses upon hiring because
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`the bonuses are part of Defendant's compensation package. Hourly employees expect to
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`receive the bonuses.
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`32.
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`Defendant directly hired Plaintiffs and other hourly employees, controlled
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`their work schedules, duties, protocols, applications, assignments and employment
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`conditions, and kept at least some records regarding their employment.
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`33.
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`Plaintiffs and other hourly employees regularly worked in excess of forty
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`hours per week throughout their tenure with Defendant.
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`34. Defendant paid Plaintiffs and other hourly employees 1.5x times their base
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`hourly rate for the hours they worked over 40 in a workweek.
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`35. However, Defendant did not include the bonuses that were paid to Plaintiffs
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`and other hourly employees in their regular rates when calculating their overtime pay even
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`though Plaintiffs and other hourly employees received bonuses in pay periods in which
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`they also worked in excess of forty hours per week.
`
`36.
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`Section 778.208 of Title 29 of the Code of Federal Regulations requires that
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`all forms of compensation, such as non-discretionary bonuses, "must be totaled in with
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`other earnings to determine the regular rate on which overtime pay must be based."
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`37.
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`Defendant violated the FLSA and AMWA by not including all forms of
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`compensation, such the nondiscretionary bonuses of Plaintiffs and other hourly
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`employees, in their regular rate when calculating their overtime pay.
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`38.
`
`Upon information and belief, Defendant's pay practices were the same for
`
`all hourly workers who received bonuses.
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`Page 5of12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complaint-Collective Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 6 of 14
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`39.
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`Upon information and belief, the pay practices that violate the FLSA and
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`AMWA alleged herein were the same at all of Defendant's facilities because the policy
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`was a centralized human resources policy implemented uniformly from the corporate
`
`headquarters.
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`40.
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`Because of the volume of work required to perform their jobs, Plaintiffs and
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`other hourly employees consistently worked in excess of forty hours per week.
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`41.
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`Defendant knew, or showed reckless disregard for whether, the way it paid
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`Plaintiffs and other hourly employees violated the FLSA and AMWA.
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`V.
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`REPRESENTATIVE ACTION ALLEGATIONS
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`42.
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`Plaintiffs repeat and re-allege all previous paragraphs of this Complaint as
`
`though fully incorporated in this section.
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`43.
`
`Plaintiffs bring this claim for relief for violation of the FLSA as a collective
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`action pursuantto Section 16(b) of the FLSA, 29 U.S.C. § 216(b), on behalf of all persons
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`similarly situated as hourly employees who were, are, or will be employed by Defendant
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`within the applicable statute of limitations period, who are entitled to payment of the
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`following types of damages:
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`A.
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`Regular wages and overtime premiums for all hours worked over forty hours
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`in any week;
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`B.
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`C.
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`Liquidated damages; and
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`Attorney's fees and costs.
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`44.
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`Plaintiffs propose the following class under the FLSA:
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`All hourly employees who received a bonus in connection
`with work performed in at least one week in which
`they worked over forty hours within the past three years.
`
`Page 6of12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complalnt--Collectlve Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 7 of 14
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`45.
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`In conformity with the requirements of FLSA Section 16(b), Plaintiffs have
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`filed or will soon file a written Consent to Join this lawsuit.
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`46.
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`The relevant time period dates back three years from the date on which
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`Plaintiffs' Original Complaint-Collective Action was filed herein and continues forward
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`through the date of judgment pursuant to 29 U.S.C. § 255(a), except as set forth herein
`
`below.
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`4 7.
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`The members of the proposed FLSA collective are similarly situated in that
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`they share these traits:
`
`A.
`
`B.
`
`C.
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`They were paid hourly;
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`They were eligible for and received nondiscretionary bonuses;
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`They worked over forty hours in at least one week in which they performed
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`work related to a bonus; and
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`D.
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`They were subject to Defendant's common policy of failing to pay a proper
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`overtime rate for hours worked over forty in a week.
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`48.
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`Plaintiffs are unable to state the exact number of the collective but believe
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`that the class exceeds one hundred (100) persons.
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`49. Defendant can readily identify the members of the collective, who are a
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`certain portion of the current and former employees of Defendant.
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`50.
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`The names and physical and mailing addresses of the probable FLSA
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`collective action plaintiffs are available from Defendant.
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`51.
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`The email addresses of many of the probable FLSA collective action
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`plaintiffs are available from Defendant.
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`Page 7 of12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complaint-Collective Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 8 of 14
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`FIRST CLAIM FOR RELIEF
`VI.
`(Individual Claims for Violation of the FLSA)
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`52.
`
`Plaintiffs repeat and re-allege all previous paragraphs of this Complaint as
`
`though fully set forth herein.
`
`53.
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`Plaintiffs assert this claim for damages and declaratory relief pursuant to
`
`the FLSA, 29 U.S.C. § 201, et seq.
`
`54.
`
`At all relevant times, Defendant has been, and continues to be, an
`
`enterprise engaged in commerce within the meaning of the FLSA, 29 U.S.C. § 203.
`
`55.
`
`29 U.S.C. §§ 206 and 207 require any enterprise engaged in commerce to
`
`pay a minimum wage for all hours worked up to 40 each week and to pay 1.5x their regular
`
`wages for all hours worked over 40, unless an employee meets certain exemption
`
`requirements of 29 U.S.C. § 213 and all accompanying DOL regulations.
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`56.
`
`Defendant classified Plaintiffs as non-exempt from the requirements of the
`
`FLSA.
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`57. Despite Plaintiffs' entitlement to overtime payments under the FLSA,
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`Defendant failed to pay Plaintiffs 1.5x their regular rate for all hours worked in excess of
`
`40 per week.
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`58.
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`Defendant knew or should have known that its actions violated the FLSA.
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`59.
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`Defendant's conduct and practices, as described above, were willful.
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`60.
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`By reason of the unlawful acts alleged herein, Defendant is liable to
`
`Plaintiffs for monetary damages, liquidated damages and costs, including reasonable
`
`attorney's fees provided by the FLSA for all violations which occurred beginning at least
`
`three years preceding the filing of Plaintiffs' initial complaint, plus periods of equitable
`
`tolling.
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`Page 8 of 12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Orlglnal Complalnt--Collectlve Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 9 of 14
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`61.
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`Defendant has not acted in good faith nor with reasonable grounds to
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`believe its actions and omissions were not a violation of the FLSA, and, as a result thereof,
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`Plaintiffs are entitled to recover an award of liquidated damages in an amount equal to
`
`the amount of unpaid minimum wage and unpaid overtime premium pay described above
`
`pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b).
`
`62.
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`Alternatively, should the Court find that Defendant acted in good faith in
`
`failing to pay Plaintiffs as provided by the FLSA, Plaintiffs are entitled to an award of
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`prejudgment interest at the applicable legal rate.
`
`VII. SECOND CLAIM FOR RELIEF
`(Collective Action Claim for Violation of the FLSA)
`
`63.
`
`Plaintiffs repeat and re-allege all previous paragraphs of this Complaint as
`
`though fully set forth herein.
`
`64.
`
`Plaintiffs asserts this claim for damages and declaratory relief on behalf of
`
`all similarly situated employees pursuant to the FLSA, 29 U.S.C. § 201, et seq.
`
`65.
`
`At all relevant times, Defendant has been, and continues to be, an
`
`enterprise engaged in commerce within the meaning of the FLSA, 29 U.S.C. § 203.
`
`66.
`
`29 U.S.C. §§ 206 and 207 require any enterprise engaged in commerce to
`
`pay all employees a minimum wage for all hours worked up to 40 each week and to pay
`
`1.Sx their regular wages for all hours worked over 40 each week, unless an employee
`
`meets certain exemption requirements of 29 U.S.C. § 213 and all accompanying
`
`Department of Labor regulations.
`
`67.
`
`Defendant classified Plaintiffs and other similarly situated employees as
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`non-exempt from the overtime provisions of the FLSA.
`
`Page9 of 12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complaint-Collective Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 10 of 14
`
`68.
`
`Defendant failed to pay Plaintiffs and similarly situated employees 1.5x their
`
`regular rate for all hours worked in excess of 40 per week.
`
`69.
`
`Defendant deprived Plaintiffs and similarly situated employees of
`
`compensation for all of the hours worked over forty per week, in violation of the FLSA.
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`70.
`
`Defendant knew or should have known that its actions violated the FLSA.
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`71.
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`Defendant's conduct and practices, as described above, were willful.
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`72.
`
`By reason of the unlawful acts alleged herein, Defendant is liable to
`
`Plaintiffs and all similarly situated employees for monetary damages, liquidated damages
`
`and costs, including reasonable attorney's fees provided by the FLSA for all violations
`
`which occurred beginning at least three years preceding the filing of Plaintiffs' initial
`
`complaint, plus periods of equitable tolling.
`
`73.
`
`Defendant has not acted in good faith nor with reasonable grounds to
`
`believe its actions and omissions were not a violation of the FLSA, and, as a result thereof,
`
`Plaintiffs and similarly situated employees are entitled to recover an award of liquidated
`
`damages in an amount equal to the amount of unpaid overtime premium pay described
`
`above pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b).
`
`7 4.
`
`Alternatively, should the Court find that Defendant acted in good faith in
`
`failing to pay Plaintiffs and the collective members as provided by the FLSA, they are
`
`entitled to an award of prejudgment interest at the applicable legal rate.
`
`VIII. THIRD CLAIM FOR RELIEF
`(Individual Claims for Violation of the AMWA)
`
`75.
`
`Plaintiffs repeat and re-allege all previous paragraphs of this Complaint as
`
`though fully set forth herein.
`
`Page 10 of 12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complaint-Collective Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 11 of 14
`
`76.
`
`Plaintiffs assert this claim for damages and declaratory relief pursuant to
`
`the AMWA, Ark. Code Ann.§§ 11-4-201, et seq.
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`77.
`
`At all relevant times, Defendant was Plaintiffs' "employer" within the
`
`meaning of the AMWA, Ark. Code Ann. § 11-4-203( 4 ).
`
`78.
`
`Sections 210 and 211 of the AMWA require employers to pay all employees
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`a minimum wage for all hours worked, and to pay 1.5x regular wages for all hours worked
`
`over 40 each week, unless an employee meets the exemption requirements of 29 U.S.C.
`
`§ 213 and accompanying Department of Labor regulations.
`
`79.
`
`Defendant classified Plaintiffs as non-exempt from the requirements of
`
`AMWA.
`
`80.
`
`Defendant failed to pay Plaintiffs overtime wages as required under the
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`AMWA for all hours that Plaintiffs worked in excess of forty per week.
`
`81.
`
`Defendant knew or should have known that its practices violated the AMWA.
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`82.
`
`Defendant's conduct and practices, as described above, were willful,
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`intentional, unreasonable, arbitrary, and in bad faith.
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`83.
`
`By reason of the unlawful acts alleged herein, Defendant is liable to
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`Plaintiffs for, and Plaintiffs seek, monetary damages, liquidated damages, prejudgment
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`interest, and costs, including reasonable attorney's fees as provided by the AMWA.
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`IX.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, premises considered, Plaintiffs Laeartha Banks and Aria Lambert,
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`each individually and on behalf of all others similarly situated, respectfully pray that
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`Defendant be summoned to appear and to answer this Complaint and for declaratory
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`relief and damages as follows:
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`Page 11 of 12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complaint-Collective Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 12 of 14
`
`A.
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`Declaratory judgment that Defendant's practices alleged in this Complaint
`
`violate the FLSA, the AMWA, and their related regulations;
`
`B.
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`Certification of a collective under Section 216 of the FLSA of all individuals
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`similarly situated, as further defined in any motion for the same;
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`C.
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`Judgment for damages suffered by Plaintiffs and others similarly situated
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`for all unpaid overtime wages under the FLSA, the AMWA and their related regulations;
`
`D.
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`Judgment for liquidated damages owed to Plaintiffs and all others similarly
`
`situated pursuant to the FLSA, the AMWA, and their related regulations;
`
`E.
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`An order directing Defendant to pay Plaintiffs and all others similarly
`
`situated interest, a reasonable attorney's fee and all costs connected with this action; and
`
`F.
`
`Such other and further relief as this Court may deem just and proper.
`
`Respectfully submitted,
`
`LAERTHA BANKS and ARIA LAMBERT,
`Individually and on Behalf of All Others
`Similarly Situated, PLAINTIFFS
`
`SANFORD LAW FIRM, PLLC
`Kirkpatrick Plaza
`10800 Financial Centre Pkwy, Suite 510
`Little Rock, Arkansas 72211
`Telephone: (501) 221-0088
`FacsimiF-'(88 787-2040
`
`-t \o
`
`Daniel Ford
`Ark. Bar No. 2014162
`
`rd
`ar o. 2001037
`josh@sanfordlawfirm.com
`
`Page 12 of 12
`Laeartha Banks, et al. v. Centene Management Company, LLC
`U.S.D.C. (E.D. Ark.) No. 4:21-cv-_
`Original Complalnt--Collectlve Action
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 13 of 14
`
`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF ARKANSAS
`CENTRAL DIVISION
`
`LAEARTHA BANKS and ARIA
`LAMBERT, Each Individually and on
`Behalf of All Others Similarly Situated
`
`vs.
`
`No. 4:21-cv-_
`
`PLAINTIFFS
`
`CENTENE MANAGEMENT COMPANY, LLC,
`and CENTENE CORPORATION
`
`DEFENDANTS
`
`CONSENT TO JOIN COLLECTIVE ACTION
`
`I was employed as an hourly worker for Centene Management Company, LLC,
`and Centene Corporation within the past three years. I understand this lawsuit is being
`brought under the Fair Labor Standards Act for miscalculated overtime wages. I consent
`to becoming a party-plaintiff in this lawsuit, to be represented by Sanford Law Firm, PLLC,
`and to be bound by any settlement of this action or adjudication by the Court.
`
`c;(~ ga.J.J
`
`LAEARTHA BANKS
`May 18, 2021
`
`Josh Sanford, Esq.
`SANFORD LAW FIRM, PLLC
`Kirkpatrick Plaza
`10800 Financial Centre Parkway, Suite 510
`Little Rock, Arkansas 72211
`Telephone: (501) 221-0088
`Facsimile: (888) 787-2040
`josh@sanfordlawfirm.com
`
`
`
`Case 4:21-cv-00429-JM Document 1 Filed 05/18/21 Page 14 of 14
`
`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF ARKANSAS
`CENTRAL DIVISION
`
`LAEARTHA BANKS and ARIA
`LAMBERT, Each Individually and on
`Behalf of All Others Similarly Situated
`
`vs.
`
`No. 4:21-cv-_
`
`PLAINTIFFS
`
`CENTENE MANAGEMENT COMPANY, LLC,
`and CENTENE CORPORATION
`
`DEFENDANTS
`
`CONSENT TO JOIN COLLECTIVE ACTION
`
`I was employed as an hourly worker for Centene Management Company, LLC,
`and Centene Corporation within the past three years. I understand this lawsuit is being
`brought under the Fair Labor Standards Act for miscalculated overtime wages. I consent
`to becoming a party-plaintiff in this lawsuit, to be represented by Sanford Law Firm, PLLC,
`and to be bound by any settlement of this action or adjudication by the Court.
`
`ARIA LAMBERT
`May 18, 2021
`
`Josh Sanford, Esq.
`SANFORD LAW FIRM, PLLC
`Kirkpatrick Plaza
`10800 Financial Centre Parkway, Suite 510
`Little Rock, Arkansas 72211
`Telephone: (501) 221-0088
`Facsimile: (888) 787-2040
`josh@sanfordlawfirm.com
`
`