Case 2:21-cv-02214-MCA-MAH Document 1 Filed 02/10/21 Page 1 of 14 PageID: 1
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`
`
`Charles J. Messia, Esq.
`Lauren W. Gershuny, Esq.
`GENOVA BURNS LLC
`494 Broad Street
`Newark, New Jersey 07102
`Tel: (973) 533-0777
`Fax: (973) 533-1112
`cmessina@genovaburns.com
`lgershuny@genovaburns.com
`Attorneys for Plaintiff,
`FMLASource, Inc.
`
`
`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`
`
`FMLASOURCE, INC.,
`
`Plaintiff,
`
`v.
`
`RWJBARNABAS HEALTH INC.,
`
` Defendant.
`
`
`
`
`
` Civil Action No.:
`
`
`
`COMPLAINT AND
`DEMAND FOR JURY TRIAL
`
`
`
`Plaintiff, FMLASource, Inc. (“Plaintiff” or “FMLASource”), by way of Complaint
`
`against defendant RWJBarnabas, Inc. (“RWJB” or “Defendant”), alleges as follows:
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`INTRODUCTION
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`1.
`
`This action stems from RWJB’s unjustified breach of an agreement between it
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`and FMLASource, pursuant to which FMLASource provided RWJB with FMLA and ADA
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`leave administration services (the “Agreement”).
`
`2.
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`The Agreement, which commenced on October 20, 2019, stipulated an initial
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`three-year term that was not to expire until October 19, 2022. Yet, despite this required term
`
`
`
`
`
`
`
`Charles J. Messia, Esq.
`Lauren W. Gershuny, Esq.
`GENOVA BURNS LLC
`494 Broad Street
`Newark, New Jersey 07102
`Tel: (973) 533-0777
`Fax: (973) 533-1112
`cmessina@genovaburns.com
`lgershuny@genovaburns.com
`Attorneys for Plaintiff,
`FMLASource, Inc.
`
`
`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`
`
`FMLASOURCE, INC.,
`
`Plaintiff,
`
`v.
`
`RWJBARNABAS HEALTH INC.,
`
` Defendant.
`
`
`
`
`
` Civil Action No.:
`
`
`
`COMPLAINT AND
`DEMAND FOR JURY TRIAL
`
`
`
`Plaintiff, FMLASource, Inc. (“Plaintiff” or “FMLASource”), by way of Complaint
`
`against defendant RWJBarnabas, Inc. (“RWJB” or “Defendant”), alleges as follows:
`
`INTRODUCTION
`
`1.
`
`This action stems from RWJB’s unjustified breach of an agreement between it
`
`and FMLASource, pursuant to which FMLASource provided RWJB with FMLA and ADA
`
`leave administration services (the “Agreement”).
`
`2.
`
`The Agreement, which commenced on October 20, 2019, stipulated an initial
`
`three-year term that was not to expire until October 19, 2022. Yet, despite this required term
`
`
`
`
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`Case 2:21-cv-02214-MCA-MAH Document 1 Filed 02/10/21 Page 2 of 14 PageID: 2
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`of the contract, RWJB wrongfully, and without justification, terminated the Agreement as of
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`December 15, 2020.
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`3.
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`After the decision makers at RWJB made up their mind that they wanted to end
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`the Agreement with FMLASource, but without justification to do so, they proceeded to engage
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`in a plan to conjure up criticisms about FMLASource’s services. This was done in an attempt
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`to prematurely exit the Agreement under the auspices of a material breach without having to
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`pay FMLASource for the remainder of the contract term, through October 19, 2022.
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`4.
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`RWJB’s conduct of engaging in a pattern of drumming up manufactured and
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`pretextual complaints about FMLASource’s services over the last several months, in order to
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`make it appear that RWJB could terminate the contract without being responsible to pay
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`FMLASource for the remaining term, demonstrates RWJB’s bad faith in its performance of the
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`Agreement.
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`5.
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`As a direct result of RWJB’s breaches of the Agreement and the implied
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`covenant of good faith and fair dealing, Plaintiff has and will continue to suffer damages in
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`excess of $1 million that it would have otherwise received as a benefit from the contract.
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`PARTIES
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`6.
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`FMLASource, Inc. is a corporation incorporated in Illinois, with its principal
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`place of business located in Chicago, Illinois.
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`7.
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`Upon information and belief, RWJB is a corporation incorporated in New
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`Jersey, with its principal place of business located at 94 Old Short Hills Road, Livingston,
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`New Jersey.
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`2
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`JURISDICTION AND VENUE
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`8.
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`This Court has diversity jurisdiction over the subject matter of this action
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`pursuant to 28 U.S.C. § 1332(a). Federal subject matter jurisdiction is conferred over
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`Plaintiff’s state law claims based on diversity of citizenship and because the amount in
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`controversy exceeds the sum of Seventy-Five Thousand ($75,000.00) dollars, exclusive of
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`interest and costs.
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`9.
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`Venue is proper in this Court under 28 U.S.C. § 1391(b) because a substantial
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`part of the events or omissions giving rise to these claims occurred in the District of New
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`Jersey. Namely, RWJB has all of its locations – which FMLASource services – in New
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`Jersey.
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`FACTS
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`A. FMLASource’s History with Barnabas and Agreement with RWJB
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`10.
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`FMLASource, an industry-leading leave administrator that services thousands of
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`customers throughout the country, are experts in processing and monitoring its clients’
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`employees’ leaves of absence to which they are entitled under various federal and state laws,
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`including, most notably, the Family and Medical Leave Act (“FMLA”).
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`11.
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` On or about July 1, 2016, FMLASource and RWJB’s predecessor, Barnabas
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`Health, Inc. (“Barnabas”), entered into a contract for leave administration services.
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`12.
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`That same year, Barnabas announced that it had finalized a merger with Robert
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`Wood Johnson Health System, the resulting entity of which was RWJB.
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`13.
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`In recognition of the stellar job FMLASource did on behalf of the Barnabas
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`account, RWJB entered into a new contract – the Agreement – with FMLASource on or about
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`October 19, 2019, pursuant to which FMLASource would administer the leaves of all
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`3
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`
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`employees -- approximately 33,000 -- of the merged entity, RWJB. Attached as Exhibit A is a
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`true and correct copy of the Agreement.
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`14.
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`Pursuant to the terms of the Agreement, the services which FMLASource was
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`required to perform for RWJB (the “Services”) are encapsulated in Schedule I of the
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`Agreement. Schedule I describes the Services which are comprised of the standard package of
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`services offered to FMLASource’s customers, including a designated account management
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`contact; access to FMLASource’s call center and online tools; leave administration; and
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`reporting on program utilization, frequency of leaves, and absence history on a rolling 12-
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`month basis.
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`15.
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`The parties also agreed that fees were to be structured based on the number of
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`employees covered under the Agreement. Specifically, RWJB agreed to pay a fee of $1.43 per
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`employee per month for FMLASource’s services outlined in Section I of the Agreement.
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`16. Upon information and belief, as of the date of this Complaint RWJB has at least
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`32,999 employees covered under the Agreement, resulting in an annual revenue to
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`FMLASource of at least $566,262.84.
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`17. Upon information and belief, it is likely that the number of employees covered
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`under the Agreement will grow over the next two years, as RWJB has acquired or is in the
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`process of acquiring and integrating at least two additional facilities. If this expansion occurs
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`prior to October 2022, it will significantly increase RWBJ’s employee count, and
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`consequently, the fees due under the Agreement.
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`18.
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`Pursuant to the Agreement, RWJB and FMLASource agreed to a guaranteed
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`three-year initial term of the Agreement.
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`19. Under the terms of the Agreement, RWJB is only permitted to terminate the
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`Agreement if FMLASource “fails to perform any material service required to be performed” and
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`if such failure is not cured within 30 days.
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`FMLASource Onboards RWJB and Meets or Exceeds its Contractual Obligations
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`B.
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`20. After RWJB expressed its intention to move forward with FMLASource for its
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`entire employee population, FMLASource began the re-implementation process with RWJB in
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`May of 2019.
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`21. During this process, which took several months and for which FMLASource did
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`not charge RWJB, the relevant teams within RWJB and FMLASource met on a weekly basis to
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`discuss the Services and address any specific issues or concerns with leave administration.
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`22.
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`This process ran smoothly and, after several months, on October 20, 2019, the
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`Agreement “went live.”
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`23. During the initial months of the Agreement, RWJB and FMLASource held
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`weekly teleconferences to monitor the Services and address any specific concerns.
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`24. During this time, RWJB made a variety of customization requests—that is,
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`requests to modify the Services to fit RWJB’s specific needs, which were not requirements
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`under the Agreement. For instance, RWJB requested a specific format for a leave report that it
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`could use to process its payroll.
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`25.
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`Though not included within the scheduled Services, and therefore, normally
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`subject to an additional fee, FMLASource created a custom report that met RWJB’s needs
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`beginning January 1, 2020, without charging any additional fee.
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`26. Another example, amongst others, of FMLASource customizing services for
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`RWJB at no cost in reliance on RWJB acting in good faith with respect to the Agreement – and
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`5
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`in spite of having no contractual obligation to do so– was in March of 2020 when RWJB
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`requested that FMLASource integrate with RWJB’s long-term disability carrier, Cigna.
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`27. Again, while not required under the Agreement and believing RWJB would
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`respect the Agreement and act in good faith, FMLASource developed an export file that would
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`facilitate information-sharing with Cigna to make claims administration simpler for RWJB
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`employees, without any additional fee.
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`28.
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`In addition to making these customization efforts and many more, which
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`FMLASource had no obligation under the Agreement to do, FMLASource’s performance under
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`the Agreement speaks for itself. Since the commencement of FMLASource’s relationship with
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`RWJB (and its predecessor, Barnabas), FMLASource has administered tens of thousands of
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`leaves with an accuracy rate of over 99%.
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`29.
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`Further, in a highly regulated space in which employee litigation and regulatory
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`scrutiny are common, there have been zero reported investigations or lawsuits in connection
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`with FMLASource’s services.
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`C. Once RWJB’s New Business Personnel Takes Over, RWJB Manufactures Nitpick
`Complaints to Try To Justify Its Termination of the Agreement
`
`
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`30. At or near the time of the Agreement’s commencement, FMLASource’s business
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`contacts at RWJB changed and, upon information and belief, they were thrust into an existing
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`vendor relationship that they did not necessarily want.
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`31.
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`These new business contacts at RWJB must have realized that FMLASource’s
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`track record was stellar and that they would not be able to get out of the Agreement unless they
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`began to manufacture dissatisfaction. So that is what they did.
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`32. At around this same time, RWJB’s leadership stopped attending the parties’
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`weekly teleconferences. Despite multiple follow-ups from FMLASource to continue these
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`6
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`weekly discussions to ensure there were no issues with the Services and/or to quickly and
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`efficiently address any issues should they occur, RWJB failed to respond. Notably, at that time,
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`FMLASource was not sure why RWJB stopped attending the parties’ weekly calls. But it soon
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`became clear that RWJB had one foot out the door and was focused on figuring out how to exit
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`the three-year-term Agreement – rather than complying with and, in good faith, working on its
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`relationship with FMLASource.
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`33.
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`In or about May 2020, RWJB’s team started complaining about FMLASource;
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`but, importantly, their complaints did not relate to the Services which FMLASource was required
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`to provide. Instead, RWJB’s complaints primarily related to preferences and requests for
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`customizations, which departed from the services for which RWJB and FMLASource had
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`contracted.
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`34.
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`These nitpick complaints did not relate to contractual breaches on the part of
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`FMLASource, much less “material” breaches; as a result, they did not permit RWJB to
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`terminate the Agreement.
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`35.
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`RWJB, committed
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`to
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`its plan
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`to somehow end
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`the Agreement with
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`FMLASource, continued in its pattern of manufacturing nitpick complaints, many of which did
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`not reflect reality. Specifically, RWJB sent a letter dated June 6, 2020, which contained
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`meritless complaints. Indeed, none of them rose to the level of a material breach of the
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`contract, yet the correspondence concluded with a request to terminate the Agreement. This
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`was despite the fact that FMLASource was not given a chance to cure any alleged issues. Such
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`failure to provide FMLASource the opportunity to cure any deficiencies – baseless or not --
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`was of course intentional, as RWJB did not want to see FMLASource succeed; rather, they
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`wanted FMLASource out.
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`7
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`36.
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`FMLASource took the issues raised in RWJB’s June 6, 2020 letter seriously,
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`however, and immediately investigated the claims with a designated team organized
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`specifically to service the RWJB account. After a thorough review, FMLASource determined
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`that most of RWJB’s complaints were without merit and did not accurately reflect the history
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`of events.
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`37. More so, RWJB’s alleged errors or mistakes largely consisted of stated
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`preferences for the Services – not material failures to provide the Services as listed in Schedule
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`I of the Agreement.
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`38. As a result, the June 6 letter reads as merely a “wish list” that FMLASource did
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`not 100% fulfill. Nowhere in the June 6 letter did RWJB provide a specific example of a
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`material Service that FMLASource failed to provide.
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`39. Despite the fact that RWJB’s complaints related to preferences outside the four
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`corners of the Agreement, FMLASource remained committed to working with RWJB to
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`improve the relationship.
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`40.
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`In furtherance of those efforts, FMLASource submitted a point-by-point
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`response to each specific concern RWJB had, and described an action plan to address each.
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`41.
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` On August 20, 2020, however, RWJB continued in its pattern of manufacturing
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`service failures in order to get out of the three-year-term of the contract, and sent
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`FMLASource another letter, which likewise made minor complaints related to RWJB’s
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`preferences, but once again failed to identify any material service failures.
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`42.
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`The fact that no material service failures were identified in the August 20 letter
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`is not surprising given that, as of the date of the letter, 96% of 277 surveyed RWJB employees
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`rated FMLASource’s customer experience as positive.
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`43. Despite the fact that RWJB employees almost universally felt that FMLASource
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`was doing a good job, it was unfortunately becoming obvious that RWJB had made up its mind
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`to terminate the Agreement and that it would not cooperate with FMLASource to improve the
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`relationship.
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`44. Nonetheless, FMLASource once again took the concerns identified in the August
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`20 letter seriously and conducted numerous internal meetings to investigate whether RWJB’s
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`claims had merit.
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`45.
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`The investigation, however, revealed that they did not.
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`46.
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`In light of this finding, it became abundantly clear to FMLASource that RWJB’s
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`alleged concerns were not a genuine contractual grievance, but a pretext to terminate the
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`Agreement prematurely.
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`47. As such, and in response to the August 20 Letter, FMLASource sent a detailed
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`response to RWJB on September 4, 2020, in which FMLASource re-asserted its commitment
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`to the relationship and the expectation that RWJB would honor the Agreement.
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`48. Despite all of FMLASource’s efforts, on October 19, 2020, RWJB sent a letter
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`purporting to terminate the Agreement effective December 15, 2020.
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`In Its Haste to Get FMLASource Out, RWJB Creates Confusion Among Its
`Employees
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`D.
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`
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`49. Although RWJB informed FMLASource that it would be terminating the
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`Agreement on December 15, 2020, prior to that date RWJB started telling its employees that as
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`of December 1, 2020, RWJB was transitioning their leave of absence vendor from
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`FMLASource to Reed Group (“Reed”), a competitor of FMLASource. This contradiction
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`between what RWJB told FMLASource and what it told its employees has caused much
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`confusion for RWJB’s employees and FMLASource.
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`FIRST CLAIM FOR RELIEF
`(BREACH OF CONTRACT)
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`50.
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`Plaintiff hereby incorporates by reference each of the preceding allegations as
`
`though each were specifically set forth at length herein.
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`51.
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`FMLASource and RWJB entered into the Agreement whereby Plaintiff was to
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`be paid per employee per month for the period of three years for FMLA and ADA leave
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`administration services.
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`52.
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` Pursuant to the Agreement, RWJB was to pay FMLASource a fee of $1.43 per
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`employee per month in exchange for all of the Services as set forth in Schedule I to the
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`Agreement.
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`53.
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`RWJB materially breached the Agreement by, among other actions and inactions
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`described above, terminating the Agreement prior to the end of the contract term without
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`justification for doing so under the terms of the Agreement.
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`54.
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`FMLASource has suffered damages as a direct and foreseeable result of RWJB’s
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`breaches because, among other damages, FMLASource has not received the benefit of its
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`bargain in the Agreement – its fee, through October 19, 2022.
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`55.
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`FMLASource has complied with all conditions precedent to the bringing of this
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`action or, in the alternative, RWJB has waived and/or is estopped from raising conditions
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`precedent as a defense.
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`WHEREFORE, Plaintiff demands judgment against RWJB for compensatory damages,
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`consequential damages, punitive damages, attorneys’ fees and costs of suit, prejudgment and
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`post-judgment interest, and such other and further relief as the Court may deem just and
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`equitable.
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`SECOND CLAIM FOR RELIEF
`(BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING)
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`56.
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`Plaintiff hereby incorporates by reference each of the preceding allegations as
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`though each were specifically set forth at length herein.
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`57.
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`Every contract made under New Jersey law incorporates an implied covenant of
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`good faith and fair dealing.
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`58.
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`FMLASource and RWBJ entered into the Agreement which is a valid and
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`enforceable contract between the parties.
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`59.
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`RWBJ acted with bad motive and engaged in bad faith conduct, by, among other
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`things, terminating the Agreement prior to the contract term, without justification, with the
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`express purpose of depriving FMLASource of benefits under the Agreement.
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`60.
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`Further, RWJB breached the implied covenant of good faith and fair dealing by
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`ceasing to productively communicate with FMLASource and otherwise failing to cooperate
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`with FMLASource, while at the same time shifting its focus to manufacturing alleged service
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`defects so that it could prematurely and unlawfully exit the Agreement.
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`61.
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`RWJB further breached the implied covenant of good faith and fair dealing by
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`confusing both its own employees as well as FMLASource by informing FMLASource that it
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`would be terminated on December 15, 2020, but telling its own employees that Reed would be
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`taking over leave administration as of December 1, 2020.
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`62.
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`FMLASource has suffered damages as a direct and foreseeable result of RWBJ’s
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`breaches of the implied covenant of good faith and fair dealing.
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`WHEREFORE, Plaintiff demands judgment against RWJB for compensatory damages,
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`consequential damages, punitive damages, attorneys’ fees and costs of suit, prejudgment and
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`post-judgment interest, contribution, indemnification, and such other and further relief as the
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`Court may deem just and equitable.
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`THIRD CLAIM FOR RELIEF
`(UNJUST ENRICHMENT)
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`
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`63.
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`Plaintiff hereby incorporates by reference each of the preceding allegations as
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`though each were specifically set forth at length herein.
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`64.
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`RWJB has been unjustly enriched by accepting the services of FMLASource –
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`services that will, among other things, benefit RWJB through the end of the term of the
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`Agreement, while refusing to pay FMLASource for those services.
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`65.
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`The retention of this benefit without remuneration to Plaintiff would be unjust.
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`WHEREFORE, Plaintiff demands judgment against RWJB for compensatory damages,
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`consequential damages, punitive damages, attorneys’ fees and costs of suit, prejudgment and
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`post-judgment interest, and such other and further relief as the Court may deem just and
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`equitable.
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`FOURTH CLAIM FOR RELIEF
`(DECLARATORY JUDGMENT)
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`Plaintiff hereby incorporates by reference each of the preceding allegations as
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`66.
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`though each were specifically set forth at length herein.
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`67.
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`Plaintiff seeks relief under the New Jersey Declaratory Judgment Act, N.J.S.A.
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`2A:16-50 et seq., which allows parties to sue for a judicial declaration in order to declare and
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`settle the rights and obligations of the parties.
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`68.
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`FMLASource seeks a declaration that it is not in breach of the Agreement and
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`therefore, there is no justification for a termination of the Agreement.
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`WHEREFORE, Plaintiff respectfully requests that this Court enter an Order declaring
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`that FMLASource is not in breach of the Agreement, and therefore there is no justification for a
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`termination of the Agreement, together with such other and further relief as the Court deems just
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`and equitable.
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`Dated: February 9, 2021
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`Respectfully submitted,
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`By:
`
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`
`
`s/ Charles J. Messina
`Charles J. Messina, Esq.
`GENOVA BURNS LLC
`494 Broad Street
`Newark, New Jersey 07102
`Tel: (973) 533-0777
`Fax: (973) 533-1112
`cmessina@genovaburns.com
`Attorneys for Plaintiff,
`FMLASource, Inc.
`
`JURY DEMAND
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`Plaintiff demands a trial by jury as to all issues so triable.
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`LOCAL CIVIL RULE 11.2 CERTIFICATION
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`Pursuant to L. CIV. R. 11.2, the undersigned counsel for Plaintiff hereby certifies that
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`this matter in controversy is not the subject of any action pending in any court, or of any
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`pending arbitration or administrative proceeding.
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`LOCAL CIVIL RULE 201.1(d)(3) CERTIFICATION
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`Pursuant to L. CIV. R. 201(d)(3), the undersigned counsel for Plaintiff hereby certifies
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`that the amount in controversy exceeds $150,000.00.
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`By:
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`s/ Charles J. Messina
`Charles J. Messina, Esq.
`GENOVA BURNS LLC
`494 Broad Street
`Newark, New Jersey 07102
`Tel: (973) 533-0777
`Fax: (973) 533-1112
`cmessina@genovaburns.com
`Attorneys for Plaintiff,
`FMLASource, Inc.
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`Dated: February 9, 2021
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`15797081v1 (24536.001)
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`14
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