throbber
Case: 1:20-cv-04971 Document #: 1 Filed: 08/24/20 Page 1 of 13 PageID #:1
`Case: 1:20-cv-04971 Document #: 1 Filed: 08/24/20 Page 1 of 13 PagelD #:1
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`IN THE UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`
`EASTERN DIVISION
`
`MICHAEL HOEFER and COREY
`WORTMAN, Individually and on Behalf
`of All Others Similarly Situated
`
`PLAINTIFFS
`
`vs.
`
`No. 1:20-cv-4971
`
`CF INDUSTRIES HOLDINGS, INC., and
`CF INDUSTRIES EMPLOYEE SERVICES, LLC
`
`DEFENDANTS
`
`ORIGINAL COMPLAINT—COLLECTIVE ACTION
`
`COMES NOW Plaintiff Michael Hoefer and Corey Wortman (collectively
`
`“Plaintiffs"), each individually and on behalf of all others similarly situated, by and through
`
`their attorney Josh Sanford of Sanford Law Firm, PLLC, and fortheir Original Complaint-—
`
`Collective Action against Defendants CF Industries Holdings, Inc., and CF Industries
`
`Employee Services, LLC (collectively “Defendant” or "Defendants"), and in support
`
`thereof they do hereby state and allege as follows:
`
`I.
`
`PRELIMINARY STATEMENTS
`
`1.
`
`This is a collective action brought by Plaintiffs, each individually and on
`
`behalf of all other hourly bonus plan participants employed by Defendant at any time
`
`within a three-year period preceding the filing of this Complaint.
`
`2.
`
`Plaintiffs bring this action under the Fair Labor Standards Act, 29 U.S.C. §
`
`201, et seq. (“F LS "), the Illinois Minimum Wage Law, 820 ILCS 10511, et seq. (“IMWL”),
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`and applicable administrative rules and regulations for declaratory judgment, monetary
`
`damages,
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`liquidated damages, prejudgment interest, and costs,
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`including reasonable
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`Michael Hoefer, et al. v. CF Industries Holdings, Inc., et al
`U.S.D.C. (N.D. III.) No. 1 :20-cv-4971
`Original Complaint—Collective Action
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`

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`attorneys’ fees, as a result of Defendant’s failure to pay Plaintiff and other hourly bonus
`
`plan participants lawful overtime compensation for hours worked in excess of forty (40)
`
`hours per week.
`
`3.
`
`Upon information and belief, for at least three (3) years prior to the filing of
`
`this Complaint, Defendant has willfully and intentionally committed violations of the FLSA
`
`and IMWL as described. infra.
`
`II.
`
`JURISDICTION AND VENUE
`
`4.
`
`The United States District Court for the Northern District of Illinois has
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`subject matterjurisdiction over this suit under the provisions of 28 U.S.C. § 1331 because
`
`this suit raises federal questions under the FLSA.
`
`5.
`
`Plaintiffs’ claims under the IMWL form part of the same case or controversy
`
`and arise out of the same facts as the FLSA claims alleged herein; accordingly, this Court
`
`has supplemental jurisdiction over the IMWL claims pursuant to 28 U.S.C. § 1367(a).
`
`6.
`
`Defendant is headquartered within the Eastern Division of the Northern
`
`District of Illinois and, upon information and belief, the records and other documents
`
`related to the payroll practices that Plaintiffs challenge are located in this District.
`
`Therefore, venue is proper within this District pursuant to 28 U.S.C. § 1391.
`
`III.
`
`THE PARTIES
`
`7
`
`Plaintiff Michael Hoefer (“Hoefer") is an individual and resident of Monona
`
`County, Iowa.
`
`8.
`
`Plaintiff Corey Wortman ("Wortman")
`
`is an individual and resident of
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`Woodbury County, Iowa.
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`Original Complaint—Collective Action
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`

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`9.
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`Defendant CF Industries Holdings,
`
`Inc. ("CF Holdings"},
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`is a foreign
`
`corporation, registered to do business in Illinois.
`
`10.
`
`CF Holdings's registered agent for service is Illinois Corporation Service
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`Company, 801 Adlai Stevenson Drive, Springfield, Illinois 62703.
`
`11.
`
`Defendant CF
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`Industries Employee Services, LLC
`
`("CF Employee
`
`Services"}, is a foreign limited liability company registered to do business in Illinois.
`
`12.
`
`CF Employee Services' registered agent for service is Illinois Corporation
`
`Service Company, 801 Adlai Stevenson Drive, Springfield, Illinois 62703.
`
`13.
`
`Defendant maintains a website at https://www.cfindustries.com/
`
`IV.
`
`FACTUAL ALLEGATIONS
`
`14.
`
`Plaintiffs repeat and re-allege all the preceding paragraphs of this Complaint
`
`as if fully set forth in this section.
`
`15.
`
`Defendants have unified operational control and management, as well as
`
`control over employees, including shared power to supervise, hire and fire, establish
`
`wages and wage policies and set schedules for their employees through unified
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`management.
`
`16.
`
`Upon information and belief, the revenue generated from CF Holdings and
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`CF Employee Services was merged and managed in a unified manner.
`
`17.
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`As a result of this unified operation, control and management, through
`
`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.
`
`Defendants are an “employer” within the meanings set forth in the FLSA and
`
`IMWL, and were, at all times relevant to the allegations in this Complaint, Plaintiffs’
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`employer, as well as the employer of the members of the collective.
`
`19.
`
`Defendants manufacture and sell nitrogen products for agricultural and
`
`industrial uses.
`
`20.
`
`Defendant operates in several states, including Illinois.
`
`21.
`
`Defendant has employees engaged in commerce and has employees
`
`handling or otherwise working on goods or materials that have been moved in or produced
`
`for commerce by others.
`
`22.
`
`Defendant's annual gross volume of sales made or business done is not
`
`less than $500,000.00 (exclusive of excise taxes at the retail level that are separately
`
`stated) for each of the three years preceding the filing of this Complaint.
`
`23.
`
`During the period relevant to this lawsuit, Plaintiffs worked at Defendant’s
`
`facility in Sergeant Bluff, Iowa.
`
`24.
`
`25.
`
`Defendants also have facilities in Louisiana, Mississippi and Oklahoma.
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`Plaintiffs were employed by Defendant within the three (3) years preceding
`
`the filing of this Original Complaint.
`
`26.
`
`Hoefer worked for Defendants as an hourly-paid maintenance technician
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`from June of 2015 to July of 2020.
`
`27. Wortman worked for Defendants as an hourly-paid instrumentation
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`technician from February of 2016 to November of 201 9.
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`28.
`
`Defendants also employed other hourly employees to accomplish its
`
`business purposes, such as other technicians, warehouse employees and Operation
`
`employees (collectively “Hourly Employees”).
`
`29.
`
`At all material times, Plaintiffs and other Hourly Employees have been
`
`entitled to the rights, protection and benefits provided under the FLSA and IMWL.
`
`30.
`
`In addition to their hourly pay, Plaintiffs and other Hourly Employees were
`
`eligible for annual quarterly, non-discretionary bonuses.
`
`31.
`
`These bonuses were based on objective criteria such as whether or not a
`
`certain production rate was met and if employees had met safety goals.
`
`32.
`
`Plaintiffs’ annual bonus was calculated by incorporating the performance
`
`from all of Defendants’ facilities, notjust the facility where Plaintiffs worked.
`
`33.
`
`Other Hourly Employees annual bonus was calculated in the same way.
`
`34.
`
`Each Plaintiff regularly worked in excess of forty (40) hours per week
`
`throughout his tenure with Defendant.
`
`35.
`
`Upon information and belief, other Hourly Employees
`
`regularly or
`
`occasionally worked in excess of forty (40) hours per week.
`
`36.
`
`Defendant paid Plaintiffs and other Hourly Employees one-and-one-half
`
`(1.5) times their base hourly rate for each hour they worked over forty (40) in a workweek.
`
`37.
`
`However, Defendant did not include the bonuses that were paid to Plaintiffs
`
`and other Hourly Employees in their regular rates when calculating their overtime pay.
`
`38.
`
`Section 778.208 of Title 29 of the Code of Federal Regulations requires that
`
`all forms of compensation, such as non-discretionary bonuses, “must be totaled in with
`
`other earnings to determine the regular rate on which overtime pay must be based."
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`39.
`
`Defendant violated the FLSA and IMWL by not including all forms of
`
`compensation, such the non-discretionary bonuses paid to Plaintiffs and other Hourly
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`Employees, in their regular rate when calculating their overtime pay.
`
`40.
`
`Defendant’s pay practices were the same for all Hourly Employees who
`
`received bonuses.
`
`41.
`
`Upon information and belief, the pay practices that violate the FLSA alleged
`
`herein were the same at all of Defendant’s facilities because the policy was a centralized
`
`human resources policy implemented uniformly from the corporate headquarters.
`
`42.
`
`Defendant knew, or showed reckless disregard for whether, the way it paid
`
`Plaintiffs and other Hourly Employees violated the FLSA and IMWL.
`
`V.
`
`REPRESENTATIVE ACTION ALLEGATIONS
`
`43.
`
`Plaintiffs repeat and re—allege all the preceding paragraphs ofthis Complaint
`
`as if fully set forth in this section.
`
`44.
`
`Plaintiffs bring this claim for relief for violation of the FLSA as a collective
`
`action pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b).
`
`45.
`
`Plaintiffs bring their FLSA claims on behalf of all Hourly Employees who
`
`were eligible for bonuses, who were employed by Defendant at any time within the
`
`applicable statute of limitations period, who were classified by Defendant as non-exempt
`
`from the overtime requirements of the FLSA and who are entitled to payment of the
`
`following types of damages:
`
`A.
`
`Payment for all hours worked,
`
`including payment of a lawful overtime
`
`premium for all hours worked for Defendant in excess of forty (40) hours in a workweek;
`
`B.
`
`Liquidated damages; and
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`C.
`
`Attorneys’ fees and costs.
`
`46.
`
`The relevant time period dates back three years from the date on which
`
`Plaintiffs' Original Complaint—Collective Action was filed and continues fonrvard through
`
`the date ofjudgment pursuant to 29 U.S.C. § 255(a).
`
`47.
`
`The members of the proposed FLSA Collective are similarly situated in that
`
`they share these traits:
`
`A.
`
`They were classified by Defendant as non-exempt from the overtime
`
`requirements of the FLSA;
`
`B.
`
`C.
`
`D.
`
`They were paid hourly rates;
`
`They received non-discretionary bonuses; and
`
`They were subject to Defendant’s common policy of improperly calculating
`
`overtime pay for hours worked over forty (40) per work week.
`
`48.
`
`Each Plaintiff has filed or will soon file a written Consent to Join this lawsuit.
`
`49.
`
`Plaintiffs are unable to state the exact number of the potential members of
`
`the FLSA Collective but believe that the group exceeds fifty (50) persons.
`
`50.
`
`Defendant can readily identify the members of the Section 16(b) Collective.
`
`The names, physical addresses, electronic mailing addresses and phone numbers of the
`
`FLSA collective action plaintiffs are available from Defendant, and a Court-approved
`
`Notice should be provided to the FLSA collective action plaintiffs via first class mail, email
`
`and text message to their last known physical and electronic mailing addresses and cell
`
`phone numbers as soon as possible, together with other documents and information
`
`descriptive of Plaintiffs' FLSA claim.
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`Original Complaint—Collective Action
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`VI.
`FIRST CLAIM FOR RELIEF
`(Individual Claims for Violation of the FLSA)
`
`51.
`
`Plaintiffs repeat and re—allege all the preceding paragraphs of this Complaint
`
`as if fully set forth in this section.
`
`52.
`
`29 U.S.C. § 207 requires employers to pay employees one and one-half
`
`(1.5) times the employee's regular rate for all hours that the employee works in excess of
`
`forty (40) per week.
`
`53.
`
`Defendant classified Plaintiffs as non-exempt from the requirements of the
`
`FLSA.
`
`54.
`
`Defendant violated Section 778.208 of Title 29 of the Code of Federal
`
`Regulations by not including non-discretionary bonuses paid to Plaintiffs in their regular
`
`rates when calculating their overtime pay.
`
`55.
`
`Defendant failed to pay Plaintiffs an overtime rate of one and one-half times
`
`their regular rate for all hours worked in excess of forty hours per week.
`
`56.
`
`Defendant’s conduct and practice, as described above, has been and is
`
`willful, intentional, unreasonable, arbitrary and in bad faith.
`
`57.
`
`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 within the three (3)
`
`years preceding the filing of Plaintiffs' initial complaint, plus periods of equitable tolling.
`
`58.
`
`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 are entitled to recover an award of liquidated damages in an amount equal to
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`Original Complaint—Collective Action
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`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).
`
`60.
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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
`
`prejudgment interest at the applicable legal rate.
`
`VII.
`
`SECOND CLAIM FOR RELIEF
`
`(Collective Action Claim for Violation of FLSA)
`
`61
`
`Plaintiffs repeat and re-allege all the preceding paragraphs of this Complaint
`
`as if fully set forth in this section.
`
`62.
`
`Plaintiffs brings this collective action on behalf of all Hourly Employees
`
`employed by Defendant to recover monetary damages owed by Defendant to Plaintiffs
`
`and members of the putative collective for all the overtime compensation for all the hours
`
`they worked in excess of forty (40) each week.
`
`63.
`
`Plaintiffs bring this action on behalf of themselves individually and on behalf
`
`of all other similarly situated employees, former and present, who were and/or are
`
`affected by Defendant's willful and intentional violation of the FLSA.
`
`64.
`
`29 U.S.C. § 207 requires employers to pay employees one and one-half
`
`(1.5) times the employee's regular rate for all hours that the employee works in excess of
`
`forty (40) per week.
`
`65.
`
`Defendant violated Section 778.208 of Title 29 of the Code of Federal
`
`Regulations by not
`
`including all forms of compensation, such as non-discretionary
`
`bonuses paid to Plaintiffs and those similarly situated,
`
`in their regular rate when
`
`calculating their overtime pay.
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`Page 9 of 13
`Michael Hoefer, et al. v. CF Industries Holdings, Inc., at al
`U.S.D.C. (N.D. Ill.) No. 1:20-cv-4971
`Original Complaint—Collective Action
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`66.
`
`In the past three years, Defendant has employed more than five hundred
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`(500) Hourly Employees.
`
`67.
`
`Like Plaintiffs, these Hourly Employees regularly or occasionally worked
`
`more than forty (40) hours in a week.
`
`68.
`
`Defendant failed to pay these workers at the proper overtime rate.
`
`69.
`
`Because these employees are similarly situated to Plaintiff, and are owed
`
`overtime for the same reasons, the opt-in class may be properly defined as:
`
`All hourly-paid bonus plan participants in the past three years
`who earned a bonus in connection with work performed
`in any week in which they worked over forty hours.
`
`70.
`
`Defendant's conduct and practice, as described above, has been and is
`
`willful, intentional, unreasonable, arbitrary and in bad faith.
`
`71.
`
`By reason of the unlawful acts alleged in this Complaint, Defendant is liable
`
`to Plaintiffs and all those similarly situated for, and Plaintiffs and all those similarly situated
`
`seek, unpaid overtime wages,
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`liquidated damages, and costs,
`
`including reasonable
`
`attorney’s fees as provided by the FLSA.
`
`72.
`
`Alternatively, should the Court find that Defendant acted in good faith in
`
`failing to pay Plaintiffs and all those similarly situated as provided by the FLSA, Plaintiffs
`
`and all those similarly situated are entitled to an award of prejudgment interest at the
`
`applicable legal rate.
`
`VIII.
`THIRD CLAIM FOR RELIEF
`(Individual Claims for Violation of the IMWL)
`
`73.
`
`Plaintiffs repeat and re-allege all previous paragraphs of this Complaint as
`
`though fully incorporated in this section.
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`74.
`
`Plaintiffs assert this claim for damages and declaratory relief pursuant to
`
`the IMWL, 820 ILCS 105/1 , et seq.
`
`75.
`
`At all
`
`relevant times, Defendant was Plaintiffs’ “employer" within the
`
`meaning of the IMWL, 820 ILCS 10513.
`
`76.
`
`lMWL, 820 ILCS 105/4a(1) requires employers to pay all employees one
`
`and one-half times regular wages for all hours worked over forty (40) hours in a week,
`
`unless an employee meets the exemption requirements of 820 ILCS 104I4a(2).
`
`77.
`
`Defendant failed to pay Plaintiffs all overtime wages owed, as required
`
`under the IMWL.
`
`78.
`
`Defendant's failure to include bonuses when calculating Plaintiffs’ overtime
`
`pay resulted in a failure to pay Plaintiffs full and complete overtime during weeks in which
`
`Plaintiffs worked more than forty (40) hours.
`
`79.
`
`Defendant’s conduct and practices, as described above, were willful,
`
`intentional, unreasonable, arbitrary and in bad faith.
`
`80.
`
`By reason of the unlawful acts alleged in this Complaint, Defendant is liable
`
`to Plaintiffs for monetary damages, liquidated damages, damages of 5% of the amount
`
`of underpayment for each month following the date of payment during which such
`
`underpayments remain unpaid, costs, and a reasonable attorney’s fee provided by the
`
`IMWL for all violations which occurred within the three (3) years preceding the filing of
`
`Plaintiffs' initial complaint, plus periods of equitable tolling. 820 ILCS 105112.
`
`81.
`
`Alternatively, should the Court find that Defendant acted in good faith in
`
`failing to pay Plaintiffs as provided by the IMWL, Plaintiffs are entitled to an award of
`
`prejudgment interest at the applicable legal rate.
`
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`Original Complaint—Collective Action
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`IX.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, premises considered, Plaintiffs Michael Hoefer and Corey
`
`Wortman, each individually and on behalf of all others similarly situated, respectfully pray
`
`that each Defendant be summoned to appear and to answer herein as follows:
`
`A.
`
`That Defendant be required to account to Plaintiffs, the collective members
`
`and the Court for all of the hours worked by Plaintiffs and the collective members and all
`
`monies paid to them;
`
`B.
`
`A declaratory judgment that Defendant's practices violate the Fair Labor
`
`Standards Act, 29 U.S.C. § 201, et seq., and attendant regulations at 29 C.F.R. § 516, et
`
`seq.;
`
`C.
`
`D.
`
`A declaratory judgment that Defendant's practices violate the IMWL;
`
`Certification of, and proper notice to,
`
`together with an opportunity to
`
`participate in the litigation, all qualifying current and former employees;
`
`E.
`
`Judgment for damages for all unpaid overtime compensation under the Fair
`
`Labor Standards Act, 29 U.S.C. § 201, etseq., and attendant regulations at 29 C.F.R. §
`
`516, et seq;
`
`F.
`
`Judgment for damages for all unpaid overtime compensation under the
`
`IMWL,
`
`G.
`
`Judgment for liquidated damages pursuant to the Fair Labor Standards Act,
`
`29 US.C. § 201, et seq., and attendant regulations at 29 C.F.R. § 516, et seq., in an
`
`amount equal to all unpaid overtime compensation owed to Plaintiffs and members of the
`
`collective during the applicable statutory period;
`
`H.
`
`Judgment for liquidated damages pursuant to the IMWL,
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`Original Complaint—Collective Action
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`I.
`
`An order directing Defendant to pay Plaintiffs and members of the collective
`
`pre-judgment interest, reasonable attorney's fees and all costs connected with this action;
`
`and
`
`J.
`
`Such other and further relief as this Court may deem just and proper.
`
`Respectfully submitted,
`
`PLAINTIFFS MICHAEL HOEFER and
`COREY WORTMAN, Individually and on
`Behalf of All Others Similarly Situated
`
`SANFORD LAW FIRM, PLLC
`One Financial Center
`
`650 South Shackleford, Suite 411
`Little Rock, Arkansas 72211
`Telephone: (501) 2
`-0088
`
`
`
`
`
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`Original Complaint—Collective Action
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