center business.
The complaint filed in federal court yesterday stated that the plaintiff signed a one-year contract with the defendant for $3.05 per hour and $3.55 per hour.
The complaint stated that the plaintiff continues to be employed by the defendant at the time of filing this complaint.
The plaintiff’s complaint stated that the defendant failed and refused to pay the compensation indicated in the employment contract, which is a breach of contract.
The defendant said her employer failed to pay her for the overtime hours she worked in excess of 40 hours a week.
According to the complaint, the defendant violated the provisions of Fair Labor Standards Act by failing to pay the plaintiff’s overtime compensation in the amount of one and one-half times regular pay rate for all of the hours worked by plaintiff in excess of 40 hours in each work week.
The complaint stated that due to the defendant’s breach of contract, the plaintiff was damaged and continues to be damaged in an amount to be proven at trial.
The complaint stated that the defendant’s promises and statements contained in the contracts were false and untrue. The defendant did not intent to honor his commitments but merely intended to induce plaintiff to accept the position and work for his company, the complaint stated.
As a result of the defendant’s fraud and deceit, the plaintiff was suffered lost of pay and benefits, the complaint added.
The plaintiff is seeking for a judgment of an award for appropriate back pay including but not limited to overtime wages, with pre-judgment interest in an amounts to be determined at trial; award for compensation for past and future pecuniary losses resulting from unlawful employment practices; for punitive damages for malicious and reckless conduct; for reasonable attorneys fees; for cost of suit; for liquidated damages; for temporary work authorization during the pendency of this matter; and for transfer relief and for such other relief that the court deem proper.


