throbber
Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 1 of 14
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF NEW YORK
`
`ORPHEUS GRANT, individually and on behalf of all
`other persons similarly situated who were employed
`by AM COMMUNCATIONS LTD, AM
`COMMUNCATIONS LLC.; AM
`COMMUNICATIONS OF OHIO LLC; and/or any
`other entities affiliated with or controlled by AM
`COMMUNICATIONS, LTD.; AM
`COMMUNCATIONS LLC; and AM
`COMMUNICATIUONS OF OHIO LLC;
`
`COMPLAINT
`
`COLLECTIVE ACTION and CLASS
`ACTION
`
`JURY TRIAL
`
`Docket No.:
`
`3:20-CV-1526 (DNH/ML)
`
`Plaintiffs,
`
`-against-
`
`AM COMMUNICATIONS, LTD.; AM
`COMMUNCATIONS LLC; AM
`COMMUNICATIONS OF OHIO LLC; and any
`related entities,
`
`Defendants.
`
`Plaintiff Orpheus Grant (the “Named Plaintiff”), by his attorneys Gattuso & Ciotoli, PLLC;
`
`and Virginia & Ambinder, LLP, allege upon knowledge to themselves and upon information and
`
`belief as to all other matters as follows:
`
`PRELIMINARY STATEMENT
`
`1. This action is brought pursuant to the Fair Labor Standards Act (hereinafter referred to as
`
`"FLSA"), 29 U.S.C. §§ 206, 207, and 216(b); New York Labor Law § 190 et seq., New York
`
`Labor Law §§ 650 et seq. and 663; 12 New York Codes, Rules and Regulations (hereinafter
`
`referred to as "NYCRR") §§ 137-1.2 and 137-1.3 to recover unpaid minimum wages, overtime
`
`compensation, and related damages owed to the Named Plaintiff and all similarly situated persons
`
`(collectively “Plaintiffs”) who are presently or were
`
`formerly employed by AM
`
`COMMUNICATIONS, LTD.; and/or AM COMMUNCATIONS LLC; and/or AM
`1
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 2 of 14
`
`COMMUNICATIONS OF OHIO LLC; and/or any other entities affiliated with or controlled by
`
`AM COMMUNICATIONS, LTD.; AM COMMUNCATIONS LLC;
`
`and/or AM
`
`COMMUNICATIONS OF OHIO LLC; (hereinafter “AM” or “Defendants”) in trades and
`
`occupations entitled to receive overtime compensation.
`
`2. Beginning in 2014 and continuing through the present, Defendants have engaged in a
`
`policy and practice of depriving its employees of the applicable straight time wages and overtime
`
`wages for work they performed as mandated by federal and state law.
`
`3. Beginning in 2014 and continuing through the present, Defendants have engaged in a
`
`policy and practice of requiring its employees to regularly work in excess of forty (40) hours per
`
`week, without providing overtime compensation as required by the applicable federal and state
`
`laws.
`
`4. Defendants failed to provide proper wage notices to Plaintiffs in violation of state law.
`
`5. Defendants have applied the same employment policies, practices and procedures to all
`
`Plaintiffs that worked for Defendants at all of Defendants’ locations throughout the United States.
`
`6. Named Plaintiff has initiated this action seeking for himself, and on behalf of all similarly
`
`situated employees, all compensation, including straight time wages, minimum wages, and
`
`overtime compensation of which they were deprived, plus interest, damages, and attorneys' fees
`
`and costs.
`
`JURISDICTION
`
`7. Jurisdiction of this Court is invoked pursuant to FLSA, 29 U.S.C. § 216(b), and 28 U.S.C.
`
`§§ 1331 and 1337. This Court also has supplemental jurisdiction under 28 U.S.C. § 1367 of the
`
`claims brought under New York Labor Law.
`
`
`
`2
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 3 of 14
`
`8. The statute of limitations under FLSA, 29 U.S.C. § 255(a), for willful violations is three
`
`(3) years.
`
`9. The statute of limitations under New York Labor Law § 198(3) is six (6) years.
`
`VENUE
`
`10. Venue for this action in the Northern District of New York under 28 U.S.C. § 1391(b) is
`
`appropriate because a substantial part of the events or omissions giving rise to the claims occurred
`
`in the Northern District of New York.
`
`CLASS ALLEGATIONS
`
`11. Named Plaintiff realleges and incorporates by reference all the allegations set forth above.
`
`12. This action is properly maintainable as a collective action pursuant to the FLSA, 29 U.S.C.
`
`§ 216(b), and as a Class Action under Rule 23 of the Federal Rules of Civil Procedure.
`
`13. This action is brought on behalf of Named Plaintiff and a class consisting of similarly
`
`situated employees who worked for Defendants as cable television and internet installation
`
`technicians throughout the United States.
`
`14. Named Plaintiff and potential plaintiffs who elect to opt-in as part of the collective action
`
`are all victims of Defendants’ common policy and/or plan to violate the FLSA by failing to pay
`
`for all hours worked and overtime compensation at one and one-half the regular hourly rate for
`
`hours in excess of 40 per week.
`
`15. The putative class is so numerous that joinder of all members is impracticable. The size of
`
`the putative class is believed to be in excess of 100 employees. In addition, the names of all
`
`potential members of the putative class are not known.
`
`16. The questions of law and fact common to the putative class predominate over any questions
`
`affecting only individual members. These questions of law and fact include, but are not limited
`
`
`
`3
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 4 of 14
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`to: (1) whether Defendants failed to pay wages owed for all hours worked; (2) whether Defendants
`
`properly accounted for and paid all hours worked; (3) whether Defendants paid overtime
`
`compensation when owed; and (4) whether Defendants failed to provide New York Plaintiffs with
`
`proper wage notices during the time of their employment.
`
`17. The claims of the Named Plaintiff are typical of the claims of the putative class members.
`
`Named Plaintiff and putative class members were all subject to Defendants’ policies and willful
`
`practice of failing to account for and pay all hours worked, including overtime compensation, and
`
`other wage violations.
`
`18. Named Plaintiff and his counsel will fairly and adequately protect the interests of the
`
`putative class. Named Plaintiff has retained counsel experienced in complex wage and hour
`
`collective and class-action litigation.
`
`19. A class action is superior to other available methods for the fair and efficient adjudication
`
`of this controversy. The individual Named Plaintiff and putative class action members lack the
`
`financial resources to adequately prosecute separate lawsuits against Defendants. A class action
`
`will also prevent unduly duplicative litigation resulting from inconsistent judgments pertaining to
`
`Defendants' policies.
`
`THE PARTIES
`
`20. Named Plaintiff Orpheus Grant is an individual who is currently a resident of Broome
`
`County, New York, and was employed by Defendant(s) out of Defendants’ Rochester, New York
`
`location as a technician from approximately December 2018 until September 2020.
`
`21. Upon information and belief, Defendant AM COMMUNICATIONS, LTD. is a foreign
`
`limited liability corporation authorized to do business within the State of New York, with a
`
`principal place of business at 5707 State Route 309, Galion, Ohio 44833.
`
`
`
`4
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 5 of 14
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`22. Upon information and belief, Defendant AM COMMUNCATIONS LLC is a domestic
`
`limited liability company organized and existing under the laws of the State of New York and
`
`authorized to do business in New York, with a principle place of business in Niagara County, New
`
`York.
`
`23. Upon information and belief, Defendant AM COMMUNICATIONS OF OHIO, LLC. is
`
`a foreign limited liability corporation authorized to do business within the State of New York, with
`
`a principal place of business at 5707 State Route 309, Galion, Ohio 44833.
`
`24. At all times relevant to this action, Defendants constituted Plaintiffs’ employers as defined
`
`by NYLL §§ 2(6), 190(3), and 651(6), and 29 U.S.C. § 203, et seq..
`
`25. Plaintiffs repeat and re-allege the foregoing allegations hereof.
`
`FACTS
`
`26. This action is properly maintainable as a collective action pursuant to the FLSA, 29 U.S.C.
`
`§ 216(b) and as a Class Action under Rule 23 of the Federal Rules of Civil Procedure.
`
`27. This action is brought on behalf of Plaintiff and a putative class and collective consisting
`
`of similarly situated employees who worked for Defendants as cable television and internet
`
`installation technicians, and other employees performing similar tasks in furtherance of
`
`Defendants’ operations.
`
`28. While working for Defendants, Plaintiff and other similarly situated employees were
`
`regularly required to perform work for Defendants without receiving pay for all hours worked
`
`including overtime compensation for hours in excess of 40 in a week, as required by applicable
`
`federal and state law.
`
`29. Named Plaintiff worked for Defendants from approximately December 2019 through
`
`October 9, 2020.
`
`
`
`5
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 6 of 14
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`30. Named Plaintiff was paid approximately $11.80 per hour.
`
`31. Named Plaintiff typically worked Monday through Saturday, from approximately 8:00 or
`
`8:30 a.m., to approximately 8:30 or 9:00 p.m.
`
`32. Throughout the entirety of his employment, Named Plaintiff and those similarly situated
`
`were required to attend a regularly scheduled Thursday morning meeting beginning at 7:00 a.m.
`
`and lasting to between 8:00 a.m. and 9:00 a.m.
`
`33. The meeting was attended by approximately 20 technicians and five supervisors.
`
`34. After the Thursday morning meetings, Named Plaintiff was required to travel between 30
`
`and 60 minutes to his first service job for the day. Named Plaintiff and those similarly situated
`
`were not allowed to clock-in to record his hours for pay until they arrived at the first service job
`
`for the day.
`
`35. This policy and practice by Defendants deprived Named Plaintiff and those similarly
`
`situated of pay for all hours worked. Much, if not all, of this unpaid time was unpaid overtime.
`
`36. Named Plaintiff and those similarly situated were required to use apps on a cell phone
`
`provided by Defendants to record hours worked for pay. The apps were from Tech Mobile and
`
`ADP.
`
`37. Named Plaintiff and those similarly situated were required to clock-in on the apps upon
`
`arrival at a customer’s residence and clock-out when leaving the customer’s residence, and not
`
`clock-in again until they arrived at the next customer’s residence.
`
`38. Named Plaintiff was instructed by a director from the Cleveland office named Jeff to clock
`
`in and out after each job throughout the day. This practice continued through at least late March
`
`or early April of 2020.
`
`
`
`6
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 7 of 14
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`39. This policy and practice deprived Named Plaintiff and those similarly situated of pay for
`
`travel time in between service jobs. Much, if not all, of this unpaid time was unpaid overtime.
`
`40. This policy and practice also deprived Named Plaintiff and those similarly situated of New
`
`York State minimum wages for all hours worked.
`
`41. As a result of this policy and practice, the paystubs that Named Plaintiff and those
`
`similarly situated received from Defendants did not accurately reflect all of the hours that they
`
`worked.
`
`
`
`FIRST CAUSE OF ACTION
`FLSA FAILURE TO PAY OVERTIME COMPENSATION
`
`42. Plaintiffs repeat and re-allege the allegations set forth above as if fully set forth herein.
`
`43. Pursuant to the Fair Labor Standards Act (“FLSA”), 29 U.S.C § 207, “no employer shall
`
`employ any of their employees who in any workweek is engaged in commerce or in the production
`
`of goods for commerce, or is employed in an enterprise engaged in commerce or in the production
`
`of goods for commerce, for a workweek longer than forty hours unless such employee receives
`
`compensation for their employment in excess of the hours above specified at a rate not less than
`
`one and one-half times the regular rate at which he is employed.”
`
`44. Time spent training for an employer is compensable time.
`
`45. Time spent traveling during normal business hours is compensable time.
`
`46. Further, pursuant to 29 U.S.C. § 203(d), an “employer” includes “any person acting directly
`
`or indirectly in the interest of an employer in relation to an employee and includes a public agency,
`
`but does not include any labor organization (other than when acting as an employer) or anyone
`
`acting in the capacity of officer or agent of such labor organization.”
`
`
`
`7
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 8 of 14
`
`47. Named Plaintiff and those similarly situated are employees within the meaning
`
`contemplated in Fair Labor Standards Act (“FLSA”), 29 U.S.C. §203(e).
`
`48. Defendants are “employer[s],” within the meaning contemplated in the FLSA, 29 U.S.C. §
`
`203(d), and, consequently, are liable for violations of FLSA.
`
`49. Defendants failed to pay Named Plaintiff, and similarly situated employees, wages owed
`
`for all hours worked including overtime wages at the rate of one and one-half times the regular
`
`rate of pay, for the time in which they worked after the first 40 hours in any given week.
`
`50. The failure of Defendants to pay Named Plaintiff and those similarly situated their
`
`rightfully owed wages and overtime compensation was willful.
`
`51. By the foregoing reasons, Defendant is liable to Plaintiffs in an amount to be determined
`
`at trial, plus interest, liquidated damages, attorneys’ fees, and costs.
`
`SECOND CAUSE OF ACTION
`NEW YORK FAILURE TO PAY MINIMUM WAGES
`
`
`
`52. Plaintiffs repeat and re-allege the allegations set forth above as if fully set forth herein.
`
`53. New York Labor Law (“NYLL”) § 652(1) and 12 NYCRR § 142-2.1 prescribe a minimum
`
`wage that employers must pay to their employees for each hour worked. Defendants are employers
`
`within the meaning of the NYLL and Plaintiffs are employees within the meaning of the NYLL.
`
`54. As a result of Defendants’ failure to pay Plaintiffs for all time worked, Defendants failed
`
`to pay Named Plaintiff, and similarly situated employees, wages owed for all hours worked
`
`including the minimum hourly rate required by the NYLL.
`
`55. The failure of Defendants to pay Named Plaintiff and those similarly situated their
`
`rightfully owed wages and overtime compensation was willful.
`
`
`
`8
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 9 of 14
`
`56. By the foregoing reasons, Defendants are liable to Plaintiffs in an amount to be determined
`
`at trial, plus interest, liquidated damages, attorneys’ fees, and costs.
`
`
`
`
`
`THIRD CAUSE OF ACTION
`NEW YORK FAILURE TO PAY OVERTIME WAGE COMPENSATION
`
`57. Plaintiffs repeat and re-allege the allegations set forth above as if fully set forth herein.
`
`58. Title 12 NYCRR § 142-2.2 requires that, “[a]n employer shall pay an employee for
`
`overtime at a wage rate of 1½ times the employee's regular rate for hours worked in excess of 40
`
`hours in one workweek.”
`
`59. New York Labor Law § 663, provides that “[i]f any employee is paid by his employer less
`
`than the wage to which he is entitled under the provisions of this article, he may recover in a civil
`
`action the amount of any such underpayments, together with costs and such reasonable attorneys’
`
`fees.”
`
`60. Time spent training for an employer is compensable time.
`
`61. Time spent traveling during normal business hours is compensable time.
`
`62. Upon information and belief, Named Plaintiff and those similarly situated regularly worked
`
`more than forty (40) hours a week while working for Defendants.
`
`63. Upon information and belief, Named Plaintiff and those similarly situated did not receive
`
`compensation for all hours worked and did not receive overtime compensation at one and one-half
`
`times their regular hourly rate for hours in excess of 40 in any given week.
`
`64. Consequently, by failing to pay to Named Plaintiff and those similarly situated for all hours
`
`worked and overtime compensation, Defendants violated New York Labor Law § 663 and 12
`
`NYCRR § 142-2.2.
`
`
`
`9
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 10 of 14
`
`65. Upon information and belief, Defendants’ failure to pay overtime compensation to Named
`
`Plaintiff and those similarly situated potential plaintiffs was willful.
`
`66. By the foregoing reasons, Defendants have violated New York Labor Law § 663 and 12
`
`NYCRR § 142-2.2, and are liable to Plaintiffs in an amount to be determined at trial, plus interest,
`
`damages, and attorneys' fees and costs.
`
`FOURTH CAUSE OF ACTION
`NEW YORK FAILURE TO PAY WAGES
`
`67. Plaintiffs reallege and incorporate by reference all the allegations set forth above.
`
`68. Pursuant to Article Six of the NYLL, workers, such as Named Plaintiffs and putative class
`
`members, are protected from wage underpayments and improper employment practices.
`
`69. Pursuant to Labor Law § 190, the term “employee” means “any person employed for hire
`
`by an employer in any employment.”
`
`70. As persons employed for hire by Defendants, Named Plaintiff and those similarly situated
`
`are “employees,” as understood in Labor Law § 190.
`
`71. Pursuant to Labor Law § 190, the term “employer” includes any “person, corporation,
`
`limited liability company, or association employing any individual in any occupation, industry,
`
`trade, business or service.”
`
`72. As an entity that hired Named Plaintiff and those similarly situated, Defendant is an
`
`“employer.”
`
`73. Named Plaintiff and those similarly situated wage rates were within the meaning of NYLL
`
`
`
`10
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 11 of 14
`
`§§ 190, 191.
`
`74. Pursuant to NYLL § 191 and cases interpreting same, workers, such as Named Plaintiffs
`
`and putative class members, are entitled to be paid all their weekly wages “not later than seven
`
`days after the end of the week in which the wages are earned.”
`
`75. Defendants failed to pay Named Plaintiff and members of the putative class their hourly
`
`wage for all hours worked.
`
`76. Unpaid time work includes, but is not limited to, time spent traveling between jobs and at
`
`morning meetings.
`
`77. In failing to pay Named Plaintiff and putative class members proper wages for all hours
`
`worked, and time and one-half for hours worked after forty hours in a week, Defendant violated
`
`New York Labor Law.
`
`78. Upon information and belief, Defendant’s failure to pay Named Plaintiff and those
`
`similarly situated full wages every week was willful.
`
`79. By the foregoing reasons, Defendant has violated NYLL and is liable to Named Plaintiff
`
`and those similarly situated in an amount to be determined at trial, plus liquidated damages,
`
`interest, attorneys’ fees and costs.
`
`FIFTH CAUSE OF ACTION
`NEW YORK FAILURE TO PROVIDE ANNUAL WAGE NOTICES
`
`
`
`80. Plaintiffs repeat and re-allege the allegations set forth above as if fully set forth herein.
`
`81. Defendants have willfully failed to supply Plaintiffs with wage notices, as required by
`
`NYLL § 195(1), in English or in the language identified as their primary language, containing
`
`Plaintiffs rate or rates of pay and basis thereof, whether paid by the hour, shift, day, week, salary,
`
`piece, commission, or other; hourly rate or rates of pay and overtime rate or rates of pay if
`
`
`
`11
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 12 of 14
`
`applicable; the regular pay day designated by the employer in accordance with NYLL § 191; the
`
`name of the employer; any “doing business as” names use by the employer; the physical address
`
`of the employer’s main office or principal place of business and a mailing address if different; the
`
`telephone number of the employer; plus, such other information as the commissioner deems
`
`material and necessary.
`
`82. Plaintiffs did not receive all required wage notices during their employment with
`
`Defendants.
`
`83. Through their knowing or intentional failure to provide Plaintiffs with the wage notices
`
`required by the NYLL, Defendants have willfully violated NYLL §§ 190 et. seq., and the
`
`supporting New York State Department of Labor Regulations.
`
`84. According to NYLL § 198-1(b), Plaintiffs are entitled to $50 for every week in which they
`
`did not receive a wage notice and/or statement, or a total of $2500, together with costs and
`
`reasonable attorney’s fees..
`
`85. By the foregoing reasons, Defendants have violated NYLL §§ 195(1) and 198-1(b) and are
`
`liable to the Plaintiffs in an amount to be determined at trial, plus liquidated damages, interest,
`
`attorneys' fees and costs.
`
`WHEREFORE, Named Plaintiff, individually and on behalf of all other persons similarly
`
`situated who were employed by Defendants, demands judgment:
`
`
`
`(1) On the First Cause of Action against Defendants, all unpaid wages and unpaid
`
`overtime wages in an amount to be determined at trial, plus liquidated damages in the amount
`
`equal to the amount of unpaid wages, interest, attorneys’ fees and costs, pursuant to the FLSA
`
`
`
`12
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 13 of 14
`
`
`
`(2)
`
`On the Second Cause of Action against Defendants, all unpaid minimum wages in
`
`an amount to be determined at trial, plus liquidated damages in the amount equal to the amount of
`
`unpaid wages, interest, attorneys’ fees and costs pursuant to the New York Labor Law;
`
`
`
`(3) On the Third Cause of Action against Defendants, all unpaid overtime wages in an
`
`amount to be determined at trial, plus liquidated damages in the amount equal to the amount of
`
`unpaid wages, interest, attorneys’ fees and costs pursuant to the New York Labor Law;
`
`
`
`(4) On the Fourth Cause of Action against Defendants, all unpaid wages in an amount to
`
`be determined at trial, plus liquidated damages in the amount equal to the amount of unpaid wages,
`
`interest, attorneys’ fees and costs pursuant to the New York Labor Law;
`
`
`
`(5) On the Fifth Cause of Action, in an amount to be determined at trial, plus interest,
`
`attorneys’ fees, and costs, pursuant to the New York Labor Law;
`
`
`
`(3)
`
`Such other and further relief as this Court may deem just and proper.
`
`
`Dated: New York, New York
`
`December 10, 2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`
`
`/s/ James Emmet Murphy
`James Emmet Murphy, Esq.
`VIRGINIA & AMBINDER, LLP
`40 Broad Street, 7th Floor
`New York, New York 10004
`jmurphy@vandallp.com
`Tel:
`(212) 943-9080
`
` Fax:
`(212) 943-9082
`
`jmurphy@vandallp.com
`
`
`
`and
`
`Frank S. Gattuso, Esq.
`GATTUSO & CIOTOLI, PLLC
`The White House
`7030 E. Genesee Street
`Fayetteville, New York
`315-314-8000
`
`13
`
`

`

`Case 3:20-cv-01526-DNH-ML Document 1 Filed 12/10/20 Page 14 of 14
`
`315-446-7521 (fax)
`fgattuso@gclawoffice.com
`
`
`
`
`
` Attorneys for the Plaintiff and putative class
`
`
`
`
`
`14
`
`

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