`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
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`ORIGINAL COMPLAINT—COLLECTIVE ACTION
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`COMES NOW Plaintiff Michael Hoefer and Corey Wortman (collectively
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`“Plaintiffs"), each individually and on behalf of all others similarly situated, by and through
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`their attorney Josh Sanford of Sanford Law Firm, PLLC, and fortheir Original Complaint-—
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`Collective Action against Defendants CF Industries Holdings, Inc., and CF Industries
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`Employee Services, LLC (collectively “Defendant” or "Defendants"), and in support
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`thereof they do hereby state and allege as follows:
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`I.
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`PRELIMINARY STATEMENTS
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`1.
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`This is a collective action brought by Plaintiffs, each individually and on
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`behalf of all other hourly bonus plan participants employed by Defendant at any time
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`within a three-year period preceding the filing of this Complaint.
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`2.
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`Plaintiffs bring this action under the Fair Labor Standards Act, 29 U.S.C. §
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`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
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`damages,
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`liquidated damages, prejudgment interest, and costs,
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`including reasonable
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`Page 1 of 13
`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
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`plan participants lawful overtime compensation for hours worked in excess of forty (40)
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`hours per week.
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`3.
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`Upon information and belief, for at least three (3) years prior to the filing of
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`this Complaint, Defendant has willfully and intentionally committed violations of the FLSA
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`and IMWL as described. infra.
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`II.
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`JURISDICTION AND VENUE
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`4.
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`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
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`this suit raises federal questions under the FLSA.
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`5.
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`Plaintiffs’ claims under the IMWL form part of the same case or controversy
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`and arise out of the same facts as the FLSA claims alleged herein; accordingly, this Court
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`has supplemental jurisdiction over the IMWL claims pursuant to 28 U.S.C. § 1367(a).
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`6.
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`Defendant is headquartered within the Eastern Division of the Northern
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`District of Illinois and, upon information and belief, the records and other documents
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`related to the payroll practices that Plaintiffs challenge are located in this District.
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`Therefore, venue is proper within this District pursuant to 28 U.S.C. § 1391.
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`III.
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`THE PARTIES
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`7
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`Plaintiff Michael Hoefer (“Hoefer") is an individual and resident of Monona
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`County, Iowa.
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`8.
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`Plaintiff Corey Wortman ("Wortman")
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`is an individual and resident of
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`Woodbury County, Iowa.
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`Page 2 of 13
`Michael Hoefer, et al. v. CF Industries Holdings, Inc., et al
`U.S.D.C. (N.D. Ill.) No. 1:20-cv-4971
`Original Complaint—Collective Action
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`
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`Case: 1:20-cv-04971 Document #: 1 Filed: 08/24/20 Page 3 of 13 PageID #:3
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`9.
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`Defendant CF Industries Holdings,
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`Inc. ("CF Holdings"},
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`is a foreign
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`corporation, registered to do business in Illinois.
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`10.
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`CF Holdings's registered agent for service is Illinois Corporation Service
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`Company, 801 Adlai Stevenson Drive, Springfield, Illinois 62703.
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`11.
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`Defendant CF
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`Industries Employee Services, LLC
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`("CF Employee
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`Services"}, is a foreign limited liability company registered to do business in Illinois.
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`12.
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`CF Employee Services' registered agent for service is Illinois Corporation
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`Service Company, 801 Adlai Stevenson Drive, Springfield, Illinois 62703.
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`13.
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`Defendant maintains a website at https://www.cfindustries.com/
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`IV.
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`FACTUAL ALLEGATIONS
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`14.
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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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`15.
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`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.
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`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.
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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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`Page 3 of 13
`Michael Hoefer, et al. v. CF Industries Holdings, Inc., et al
`U.S.D.C. (N.D. Ill.) No.1:20-cv-4971
`Original Complaint-Collective Action
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`18.
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`Defendants are an “employer” within the meanings set forth in the FLSA and
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`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.
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`19.
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`Defendants manufacture and sell nitrogen products for agricultural and
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`industrial uses.
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`20.
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`Defendant operates in several states, including Illinois.
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`21.
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`Defendant has employees engaged in commerce and has employees
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`handling or otherwise working on goods or materials that have been moved in or produced
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`for commerce by others.
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`22.
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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) for each of the three years preceding the filing of this Complaint.
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`23.
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`During the period relevant to this lawsuit, Plaintiffs worked at Defendant’s
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`facility in Sergeant Bluff, Iowa.
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`24.
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`25.
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`Defendants also have facilities in Louisiana, Mississippi and Oklahoma.
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`Plaintiffs were employed by Defendant within the three (3) years preceding
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`the filing of this Original Complaint.
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`26.
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`Hoefer worked for Defendants as an hourly-paid maintenance technician
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`from June of 2015 to July of 2020.
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`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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`Page 4 of 13
`Michael Hoefer, et al. v. CF Industries Holdings, Inc., et al
`u.s.o.c. (N.D. III.) No. 1:20-cv-4971
`Original Complaint—Collective Action
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`28.
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`Defendants also employed other hourly employees to accomplish its
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`business purposes, such as other technicians, warehouse employees and Operation
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`employees (collectively “Hourly Employees”).
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`29.
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`At all material times, Plaintiffs and other Hourly Employees have been
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`entitled to the rights, protection and benefits provided under the FLSA and IMWL.
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`30.
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`In addition to their hourly pay, Plaintiffs and other Hourly Employees were
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`eligible for annual quarterly, non-discretionary bonuses.
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`31.
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`These bonuses were based on objective criteria such as whether or not a
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`certain production rate was met and if employees had met safety goals.
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`32.
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`Plaintiffs’ annual bonus was calculated by incorporating the performance
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`from all of Defendants’ facilities, notjust the facility where Plaintiffs worked.
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`33.
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`Other Hourly Employees annual bonus was calculated in the same way.
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`34.
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`Each Plaintiff regularly worked in excess of forty (40) hours per week
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`throughout his tenure with Defendant.
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`35.
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`Upon information and belief, other Hourly Employees
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`regularly or
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`occasionally worked in excess of forty (40) hours per week.
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`36.
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`Defendant paid Plaintiffs and other Hourly Employees one-and-one-half
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`(1.5) times their base hourly rate for each hour they worked over forty (40) in a workweek.
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`37.
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`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.
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`38.
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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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`Page 5 of 13
`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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`39.
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`Defendant violated the FLSA and IMWL by not including all forms of
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`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.
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`40.
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`Defendant’s pay practices were the same for all Hourly Employees who
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`received bonuses.
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`41.
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`Upon information and belief, the pay practices that violate the FLSA alleged
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`herein were the same at all of Defendant’s facilities because the policy was a centralized
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`human resources policy implemented uniformly from the corporate headquarters.
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`42.
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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 IMWL.
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`V.
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`REPRESENTATIVE ACTION ALLEGATIONS
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`43.
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`Plaintiffs repeat and re—allege all the preceding paragraphs ofthis Complaint
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`as if fully set forth in this section.
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`44.
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`Plaintiffs bring this claim for relief for violation of the FLSA as a collective
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`action pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b).
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`45.
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`Plaintiffs bring their FLSA claims on behalf of all Hourly Employees who
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`were eligible for bonuses, who were employed by Defendant at any time within the
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`applicable statute of limitations period, who were classified by Defendant as non-exempt
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`from the overtime requirements of the FLSA and who are entitled to payment of the
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`following types of damages:
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`A.
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`Payment for all hours worked,
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`including payment of a lawful overtime
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`premium for all hours worked for Defendant in excess of forty (40) hours in a workweek;
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`B.
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`Liquidated damages; and
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`Page 6 of 13
`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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`C.
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`Attorneys’ fees and costs.
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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 and continues fonrvard through
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`the date ofjudgment pursuant to 29 U.S.C. § 255(a).
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`47.
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`The members of the proposed FLSA Collective are similarly situated in that
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`they share these traits:
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`A.
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`They were classified by Defendant as non-exempt from the overtime
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`requirements of the FLSA;
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`B.
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`C.
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`D.
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`They were paid hourly rates;
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`They received non-discretionary bonuses; and
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`They were subject to Defendant’s common policy of improperly calculating
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`overtime pay for hours worked over forty (40) per work week.
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`48.
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`Each Plaintiff has filed or will soon file a written Consent to Join this lawsuit.
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`49.
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`Plaintiffs are unable to state the exact number of the potential members of
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`the FLSA Collective but believe that the group exceeds fifty (50) persons.
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`50.
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`Defendant can readily identify the members of the Section 16(b) Collective.
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`The names, physical addresses, electronic mailing addresses and phone numbers of the
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`FLSA collective action plaintiffs are available from Defendant, and a Court-approved
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`Notice should be provided to the FLSA collective action plaintiffs via first class mail, email
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`and text message to their last known physical and electronic mailing addresses and cell
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`phone numbers as soon as possible, together with other documents and information
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`descriptive of Plaintiffs' FLSA claim.
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`Page 7 of 13
`Michael Hoefer, et al. v. CF Industries Holdings, Inc., et al
`U.S.D.c. (N.D. Ill.) No. 1:20-cv-4971
`Original Complaint—Collective Action
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`VI.
`FIRST CLAIM FOR RELIEF
`(Individual Claims for Violation of the FLSA)
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`51.
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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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`52.
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`29 U.S.C. § 207 requires employers to pay employees one and one-half
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`(1.5) times the employee's regular rate for all hours that the employee works in excess of
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`forty (40) per week.
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`53.
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`Defendant classified Plaintiffs as non-exempt from the requirements of the
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`FLSA.
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`54.
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`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
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`rates when calculating their overtime pay.
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`55.
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`Defendant failed to pay Plaintiffs an overtime rate of one and one-half times
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`their regular rate for all hours worked in excess of forty hours per week.
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`56.
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`Defendant’s conduct and practice, as described above, has been and is
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`willful, intentional, unreasonable, arbitrary and in bad faith.
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`57.
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`By reason of the unlawful acts alleged herein, Defendant
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`is liable to
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`Plaintiffs for monetary damages, liquidated damages and costs, including reasonable
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`attorney’s fees provided by the FLSA for all violations which occurred within the three (3)
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`years preceding the filing of Plaintiffs' initial complaint, plus periods of equitable tolling.
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`58.
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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
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`Page 8 of 13
`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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`the amount of unpaid minimum wage and unpaid overtime premium pay described above
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`pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b).
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`60.
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`Alternatively, should the Court find that Defendant acted in good faith in
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`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.
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`VII.
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`SECOND CLAIM FOR RELIEF
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`(Collective Action Claim for Violation of FLSA)
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`61
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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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`62.
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`Plaintiffs brings this collective action on behalf of all Hourly Employees
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`employed by Defendant to recover monetary damages owed by Defendant to Plaintiffs
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`and members of the putative collective for all the overtime compensation for all the hours
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`they worked in excess of forty (40) each week.
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`63.
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`Plaintiffs bring this action on behalf of themselves individually and on behalf
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`of all other similarly situated employees, former and present, who were and/or are
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`affected by Defendant's willful and intentional violation of the FLSA.
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`64.
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`29 U.S.C. § 207 requires employers to pay employees one and one-half
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`(1.5) times the employee's regular rate for all hours that the employee works in excess of
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`forty (40) per week.
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`65.
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`Defendant violated Section 778.208 of Title 29 of the Code of Federal
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`Regulations by not
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`including all forms of compensation, such as non-discretionary
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`bonuses paid to Plaintiffs and those similarly situated,
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`in their regular rate when
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`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.
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`In the past three years, Defendant has employed more than five hundred
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`(500) Hourly Employees.
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`67.
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`Like Plaintiffs, these Hourly Employees regularly or occasionally worked
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`more than forty (40) hours in a week.
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`68.
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`Defendant failed to pay these workers at the proper overtime rate.
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`69.
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`Because these employees are similarly situated to Plaintiff, and are owed
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`overtime for the same reasons, the opt-in class may be properly defined as:
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`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.
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`70.
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`Defendant's conduct and practice, as described above, has been and is
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`willful, intentional, unreasonable, arbitrary and in bad faith.
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`71.
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`By reason of the unlawful acts alleged in this Complaint, Defendant is liable
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`to Plaintiffs and all those similarly situated for, and Plaintiffs and all those similarly situated
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`seek, unpaid overtime wages,
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`liquidated damages, and costs,
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`including reasonable
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`attorney’s fees as provided by the FLSA.
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`72.
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`Alternatively, should the Court find that Defendant acted in good faith in
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`failing to pay Plaintiffs and all those similarly situated as provided by the FLSA, Plaintiffs
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`and all those similarly situated are entitled to an award of prejudgment interest at the
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`applicable legal rate.
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`VIII.
`THIRD CLAIM FOR RELIEF
`(Individual Claims for Violation of the IMWL)
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`73.
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`Plaintiffs repeat and re-allege all previous paragraphs of this Complaint as
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`though fully incorporated in this section.
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`Page 10 of 13
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`U.S.D.C. (N.D. Ill.) No. 1:20-cv-4971
`Original Complaint—Collective Action
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`74.
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`Plaintiffs assert this claim for damages and declaratory relief pursuant to
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`the IMWL, 820 ILCS 105/1 , et seq.
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`75.
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`At all
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`relevant times, Defendant was Plaintiffs’ “employer" within the
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`meaning of the IMWL, 820 ILCS 10513.
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`76.
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`lMWL, 820 ILCS 105/4a(1) requires employers to pay all employees one
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`and one-half times regular wages for all hours worked over forty (40) hours in a week,
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`unless an employee meets the exemption requirements of 820 ILCS 104I4a(2).
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`77.
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`Defendant failed to pay Plaintiffs all overtime wages owed, as required
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`under the IMWL.
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`78.
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`Defendant's failure to include bonuses when calculating Plaintiffs’ overtime
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`pay resulted in a failure to pay Plaintiffs full and complete overtime during weeks in which
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`Plaintiffs worked more than forty (40) hours.
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`79.
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`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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`80.
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`By reason of the unlawful acts alleged in this Complaint, Defendant is liable
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`to Plaintiffs for monetary damages, liquidated damages, damages of 5% of the amount
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`of underpayment for each month following the date of payment during which such
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`underpayments remain unpaid, costs, and a reasonable attorney’s fee provided by the
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`IMWL for all violations which occurred within the three (3) years preceding the filing of
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`Plaintiffs' initial complaint, plus periods of equitable tolling. 820 ILCS 105112.
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`81.
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`Alternatively, should the Court find that Defendant acted in good faith in
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`failing to pay Plaintiffs as provided by the IMWL, Plaintiffs are entitled to an award of
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`prejudgment interest at the applicable legal rate.
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`Page 11 of 13
`Michael Hoefer, et al. v. CF Industries Holdings, Inc., et al
`U.S.D.c. (N.D. Ill.) No. 1:20-cv-4971
`Original Complaint—Collective Action
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`IX.
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`PRAYER FOR RELIEF
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`WHEREFORE, premises considered, Plaintiffs Michael Hoefer and Corey
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`Wortman, each individually and on behalf of all others similarly situated, respectfully pray
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`that each Defendant be summoned to appear and to answer herein as follows:
`
`A.
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`That Defendant be required to account to Plaintiffs, the collective members
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`and the Court for all of the hours worked by Plaintiffs and the collective members and all
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`monies paid to them;
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`B.
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`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.;
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`C.
`
`D.
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`A declaratory judgment that Defendant's practices violate the IMWL;
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`Certification of, and proper notice to,
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`together with an opportunity to
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`participate in the litigation, all qualifying current and former employees;
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`E.
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`Judgment for damages for all unpaid overtime compensation under the Fair
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`Labor Standards Act, 29 U.S.C. § 201, etseq., and attendant regulations at 29 C.F.R. §
`
`516, et seq;
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`F.
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`Judgment for damages for all unpaid overtime compensation under the
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`IMWL,
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`G.
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`Judgment for liquidated damages pursuant to the Fair Labor Standards Act,
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`29 US.C. § 201, et seq., and attendant regulations at 29 C.F.R. § 516, et seq., in an
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`amount equal to all unpaid overtime compensation owed to Plaintiffs and members of the
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`collective during the applicable statutory period;
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`H.
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`Judgment for liquidated damages pursuant to the IMWL,
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`Page 12 of 13
`Michael Hoefer, et a]. v. CF Industries Holdings, Inc., et al
`U.S.D.c. (N.D. lll.) No. 1:20-cv-4971
`Original Complaint—Collective Action
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`I.
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`An order directing Defendant to pay Plaintiffs and members of the collective
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`pre-judgment interest, reasonable attorney's fees and all costs connected with this action;
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`and
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`J.
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`Such other and further relief as this Court may deem just and proper.
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`Respectfully submitted,
`
`PLAINTIFFS MICHAEL HOEFER and
`COREY WORTMAN, Individually and on
`Behalf of All Others Similarly Situated
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`SANFORD LAW FIRM, PLLC
`One Financial Center
`
`650 South Shackleford, Suite 411
`Little Rock, Arkansas 72211
`Telephone: (501) 2
`-0088
`
`
`
`
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`Page 13 of 13
`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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`