Complaint Against FIG

Case 1:11-cv-01178-PAB Document 1 Filed 05/03/11 USDC Colorado Page 1 of 14

IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADO

Civil Action No.

SEAN NALETTE, individually,JAMES CURRAN, individually,and on behalf of others similarlysituated,

Plaintiffs,

vs.

INTRAWEST ULC, a LimitedLiability Company, FORTRESSINVESTMENT GROUP, a limited

Liability Company.

Defendants.

COMPLAINT

Plaintiffs, SEAN NALETTE and JAMES CURRAN, individually and on behalf of all

others similarly situated (hereinafter referred to as "Plaintiff(s)"), hereby sue Defendants,

INTRAWEST ULC and FORTRESS INVESTMENT GROUP (hereinafter referred to as

“Defendants”), and for their complaint allege, upon information and belief, except for the

allegationsconcerning Plaintiffs' own actions, asfollows:

NATURE OF THE ACTION

1. Plaintiffs bring this action, on behalf of themselves and other current and

former employees, or others similarly situated, who elect to opt into this action pursuant

to Section 16(b) of the Fair Labor Standards Act ("FLSA"), 29 U.S.C. §216(b), alleging

that Defendants have violated the FLSA, by actions, including but not limited to, failing


to pay Plaintiffs minimum wage, which wage specifically failed to include “Engaged to

Wait” pay and overtime premium pay calculated at one and one-half-times their regular

rate of pay for all hours worked over forty (40) during the workweek and failing to

maintain the proper documentation as an employer.

2. As a result of Defendants' multipleviolations of the FLSA, Plaintiffs and others similarly

situated are entitled to substantial damages, including, inter alia, unpaid wages,

liquidated damages, pre-judgment interest, attorney's fees, and litigation costs and

expenses.

JURISDICTION AND VENUE

3. This Court has jurisdiction over Plaintiffs' FLSA claims pursuant to 29 U.S.C. 216(b)

and 28 U.S.C. 1331.

4. Defendants are subject to personal jurisdiction in this Court by conducting business in

this Honorable Court’s judicial district.

5. Venue is proper in this District and in this Division pursuant to 28 U.S.C. 1391(a) and

(c) inasmuch as a substantial part of the events or omissions giving rise to the claims

occurred in this District and in this Division.

6. This Court is empowered to issue a declaratory judgment pursuant to 28 U.S.C. 2201

and 2202.

7. AllactsoromissionsgivingrisetothisdisputetookplaceintheDistrictofColorado.

THE PARTIES

8. Plaintiff, SEAN NALETTE, was, at all relevant times, an adult individual residing in the

District of Colorado.

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9. Plaintiff, SEAN NALETTE, was employed by Defendants from on or about 12/1/07

through 4/10/11 on a seasonal basis with each season starting on or about December 1st

and ending on or about the 2nd Sunday in April, as a ski instructor.

10. Plaintiff, SEAN NALETTE, failed to be properly compensated for, among other things,

on call time and worked in excess of forty (40) hours per workweek, without receiving

wages overtime compensation as required by the FLSA. Plaintiff s consent has been

obtained.

11. Plaintiff, JAMES CURRAN, was, at all relevant times, an adult individual residing in the

District of Colorado.

12. Plaintiff, JAMES CURRAN, was employed by Defendants within the last three (3) years

from the filing of this Complaint on a seasonal basis with each season starting on or about

December 1 st and ending on or about the 2nd Sunday in April, as a ski instructor.

13. Plaintiff, JAMES CURRAN, failed to be properly compensated for, among other things,

on call time and worked in excess of forty (40) hours per workweek, without receiving

wages overtime compensation as required by the FLSA. Plaintiff s consent has been

obtained.

14. Defendants, INTRAWEST ULC and FORTRESS INVESTMENT GROUP, are

corporations that regularly transact business within the District of Colorado, including but

not limited to, offering the services of a resort hotel.

15. Upon information and belief, Defendants are the employer of Plaintiffs and all others

similarly situated.

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16. Defendants have maintained a uniform common policy and practice of, inter alia, and as

set forth in greater detail below of willfully and knowingly not paying compensation for

work performed to employeessimilarly situated.

17. Plaintiffs were at all times relevant to the Complaint a nonexempt employee under the

Federal FLSA (29 U.S.C. §201 et. seq.)

18. The Defendants failed to keep true records of the hours worked by the Plaintiffs.

19. The Defendantsfailed to pay each Plaintiff for all hoursworked.

20. The Defendants acted with knowledge of facts or a reckless disregard for the facts

concerning the working conditions of their employees or with knowledge of or a reckless

disregard for the requirements of the Federal FLSA.

21. The Defendants' failureto pay Plaintiffsthe required minimum wage is in violation of the

Federal FLSA, 29 U.S.C. 206.

22. The Defendants’ failure to pay Plaintiffs the required overtime wages is in violation of

the Federal FLSA, 29 U.S.C. 207.

23. The Defendant’s failure to maintain proper employee records is in violation of the

Federal FLSA, 29 CFR Part 516.

24. At all relevant times, Plaintiffs, and those similarly situated, were employed as Ski

Instructors for Defendants.

STATEMENT OF FACTS

25. Plaintiffs were employees of Defendants as more fully alleged herein. Plaintiffs bring

this action on behalf of themselves and on behalf of other, current and former employees

of Defendants similarly situated for unpaid compensation and other relief under the Fair

Labor Standards Act, as amended, 29 U.S.C. §216(b) (the "FLSA" or the "Act").

4


26. From approximately 12/1/07 through 4/10/11, and for all other times within the prior

three (3) years to the filing of this complaint, on a seasonal basis, with each season

starting on or about December 1 st and ending on or about the 2nd Sunday in April,

Plaintiffs were employed by Defendants as a non-exempt hourly employee within the

personal jurisdiction and venue of this Court.

27. Plaintiffs were forced to work without pay and were not paid regular wage for the

services provided by Defendants.

28. Plaintiffs were forced to perform the work of a ski instructor and at a rate less than his

agreed upon rate for the benefit of Defendants.

29. Plaintiffs were forced to be on call without regular pay.

30. Plaintiffs were employees subject to the control of the Defendants, required to remain at

the place of employment or very close to the workplace in time and distance, with very

little freedom to use the time as his own, awaiting a decision on a job assignment without

compensation.

31. Pursuant to Defendants' uniform practice and corporate policy, although Defendants

regularly required Plaintiffs and those similarly situated to work more than 40 hours in a

workweek, Plaintiffs and those similarly situated were not paid for any hours they

worked beyond 40 hours in a workweek.

32. Pursuant to Defendants' uniform practice and corporate policy, although Defendants

regularly required Plaintiffs and those similarly situated to suffer at the on call will of the

Defendants, Plaintiffs and those similarly situated were not paid for any hours they

suffered while on call for the Defendants.

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33. During these uncompensated hours, Plaintiffs and those similarly situated performed

work for the benefit of the Defendants, in the normal course of the Defendants' business

and such work was integrated into the business of the Defendants.

34. Plaintiffs and those similarly situated often worked on call without pay and in excess of

40 hours a week, yet Defendants willfully failed to pay them overtime compensation of

one and one-half times their regular rate of pay, or at all for their on call time, in violation

of the FLSA.

35. Defendants knew that Plaintiffs and those similarly situated performed work that required

additional wages to be paid. Nonetheless, Defendants operated under a scheme, as

described above, to deprive Plaintiffs and those similarly situated of wages.

36. Defendants' conduct, as alleged herein, was willful and has caused significant damage to

Plaintiffs and those similarly situated.

37. Upon information and belief, throughout all relevant time periods, while Defendants

employed Plaintiffs and those similarly situated, Defendants failed to maintain accurate

and sufficient time records.

38. Throughout all relevant time periods, upon information and belief, and during the course

of Plaintiffs' own employments, while Defendants employed Plaintiffs and those

similarly situated, Defendants failed to post or, keep posted, a notice explaining the

minimum wage and overtime pay rights provided by the FLSA.

39. This cause of action is brought as a collective action to recover from Defendant, unpaid

compensation, a declaratory judgment, liquidated damages, and the costs and reasonable

attorney's fees under the provisions of Title 29 U.S.C. §216(b) on behalf of Plaintiff and

all other current and former employees similarly situated during the material time.

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40. The asserted class for this collective action includes all current and former employees

similarly situated to Plaintiffs, who were non-exempt hourly employees who worked for

Defendants during the time period from 3 years prior to the filing of this Complaint.

41. Subject matter jurisdiction is conferred on this Court by Title 28 U.S.C. §1337 and by

Title 29 U.S.C. §216(b). At all times pertinent to this Complaint, Defendants were an

enterprise engaged in interstate commerce or in the production of goods for commerce as

defined by §39(r) and 3(s) of the Act, 29 U.S.C. §203(r) and 203(s). The annual gross

sales volume of the Defendants was in excess of $500,000.00 per annum. Alternatively,

Plaintiff and those employees similarly situated worked in interstate commerce so as to

fall within the protection of the Act.

42. At all times pertinent to this Complaint, Defendant failed to comply with Title 29 U.S.C.

§§201-209 in that Plaintiffs and those employees similarly situated performed services

and labor for Defendants for which Defendants made no provision to pay Plaintiff and the

other employees in the asserted class full and proper, regular and overtime compensation

to which they were lawfully entitled for all of the hours worked in excess of forty (40)

within a workweek or to pay for any on call work.

43. Plaintiffs have retained the undersigned counsel to represent them each individually and

on behalf of the asserted class, Plaintiffs are entitled to the recovery of reasonable

attorney's fees and costs if they prevail in this action.

COUNT I–STATUTORY VIOLATION OF FAIR LABOR STANDARDS ACT(MINIMUM WAGE VIOLATION)

44. Plaintiffs, on behalf of themselves and those similarly situated, reallege and incorporate

by reference paragraphs 1 through 43 as if they were set forth again herein.

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45. At all relevant times, Defendants have been and continue to be employers engaged in

interstate commerce and/or the production of goods for commerce, within the meaning of

the FLSA, 29 U.S.C. 206(a) and 207(a).

46. At all relevant times, Defendants employed, and/or continue to employ, Plaintiffs and

those similarly situated within the meaning of the FLSA.

47. Upon information and belief, Defendants have had gross revenues in excess of

$500,000.00 for each relevant time period.

48. Defendants’ business activities involve those to which the FLSA applies, including that it

affects and utilizes interstate commerce.

49. Plaintiffs, and those similarly situated, were also engaged in utilizing instruments of

interstate commerce or produced goods to be used in such.

50. Plaintiffs consent in writing to be a party to this action, pursuant to 29 U.S.C. 216(b).

51. Plaintiffs and those similarly situated regularly were not paid for all time spent in

physical or mental exertion controlled or required by Defendant and pursued primarily

for the benefit of Defendants’ business.

52. Plaintiffs and those similarly situated regularly worked on call numerous hours each

week but were not paid for all hoursworked in violation of the FLSA.

53. Plaintiffs and those similarly situated were required to report to work at least 15 minutes

early on a daily basis to "assist guests" to be eligible to receive work for the day.

Pursuant to the Defendant's Policy of Mandatory Volunteer Work, employees who did

not provide free guest services 15 minutes before they were supposed to be at work were

denied work.

8


54. Plaintiffs and those similarly situated not receiving a morning ski lesson were and

are required to wait for the possibility of a lesson later in the morning or day. The time

for this was between 3.5 and 5 hours with no compensation. Plaintiffs and those

similarly situated engaged to wait by the Defendants were required to make themselves

available at a moment’s notice.

55. Plaintiffs and those similarly situated regularly were engaged to wait and required to

work “off the clock” or “on –call” each week but were not paid for all hours worked and

in violation of the FLSA. Pursuant to 29 CFR §785.15 and 785.17, if the employee is

unable to use the time effectively for his own purposes, the employee is engaged to wait

or if the employee is required to remain on the premises or so close thereto that he cannot

use the time effectively for his own purposes, the employee is working while “on call”.

56. Defendants violated the FLSA by requiring all employees to work without pay as

mandatory "volunteers" for 15 minutes or more every day prior to clocking in as

working.

57. Defendants violated the FLSA by requiring employees to report to work and wait for

extended periods of time for an assignment without pay. Plaintiffs were required to

spend time waiting to respond to the employer's needs or were "engaged to wait"

constituting compensable hours of work under the FLSA.

58. Defendants required and/or knew that off the clockwork was being performed.

59. Defendants caused thesimilarly situated employeesto believe that their present working

conditions or the continuance of employment would be adversely affected by non-

attendance at the mandatory daily"volunteer" work.

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60. As a result of Defendants' willful failureto compensate their employees, including

Plaintiffs and those similarly situated, at a rate not less than the regular rate of pay for

work performed, Defendants have violated and continue to violate the FLSA, 29 U.S.C.

201 et seq.

61. The foregoing conduct, as alleged, constitutes a willful violation of the FLSA within the

meaning of 29 U.S.C. 255(a).

62. Due to Defendants' FLSA violations, Plaintiffs, on behalf of themselves and those

similarly situated, areentitled to recover from Defendants, their regular compensation, an

additional, equal amount as liquidated damages for Defendants' willful violations of the

FLSA and for its unreasonably delayed payment of wages, reasonable attorneys' fees, and

costs and disbursements of this action, pursuant to 29 U.S.C. 216(b).

COUNT II–STATUTORY VIOLATION OF FAIR LABOR STANDARDS ACT(OVERTIME WAGE VIOLATION)










67. Defendants' business activities involve those to which the FLSA applies, including that it


10





70. Section 207(a) (1) of the FLSA states that an employee must be paid overtime equal to, at

least one and one-half times the employee's regular rate of pay for all hours worked in

excess of 40 hours per week. Pursuant to 29 C.F.R. 778.315, compensation for hours

worked in excess of 40 hours per week may not be considered paid to an employee unless

that employee is compensated for all non-overtime hours worked.

71. Plaintiffs and those similarly situated regularly were not paid for all time spent in

physical or mental exertion controlled or required by Defendant and pursued primarily

for the benefit of Defendants' business.

72. Plaintiffs and those similarly situated regularly worked overtime each week but were not

paid for all hoursworked in violation of the FLSA.

73. As a result of Defendants' willful failureto compensate their employees, including

Plaintiffs and those similarly situated, at a rate not less than the regular rate of pay for

work performed, Defendants have violated and continue to violate the FLSA, 29 U.S.C.

201 et seq..




similarly situated, are entitled to recover from Defendants, their regular compensation, an


11


FLSA and for its unreasonably delayed payment of wages, reasonable attorneys' fees, and


COUNT III–STATUTORY VIOLATION OF FAIR LABOR STANDARDS ACT(EMPLOYEE TIME RECORDS VIOLATION)










80. Defendants’ business activities involve those to which the FLSA applies, including that it





83. Defendants failed to maintain proper records, including, but not limited to, timesheets,

time cards, or other documentation which logs the date, time, hours worked, overtime

hours worked and the name of the employee.

84. As a result of Defendants' failure to record, report, credit and/or compensate its

employees, including Plaintiffs and those similarly situated, Defendants have failed to

make, keep and preserve records with respect to each of their employees sufficient to

12


determine the wages, hours and other conditions and practices of employment in

violation of the FLSA, 29 U.S.C. 201, et seq., including 29 U.S.C. 211(c) and

215(a).




similarly situated, are entitled to recover from Defendants, their regular compensation, an


FLSA and for its unreasonably delayed payment ofwages, reasonable attorneys' fees, and


PRAYER FOR RELIEF

Wherefore, Plaintiffs on behalf of themselves and all others similarly situated,

respectfully request that this Court grant the following relief:

a. Prompt issuance of notice pursuant to 29 U.S.C. 216(b) to all similarly situated

members of an FLSA class, apprising them of the pendency of this action, permitting them to

assert timely FLSA claims in this action by filing individual Consents to Sue pursuant to 29

U.S.C. 216(b) and appointing Plaintiffs and their counsel to represent those similarly situated

to the Plaintiff and tolling of the statue of limitations;

b. A declaratory judgment that the practices complained of herein are unlawful

under the FLSA;

c. An award of unpaid wages for all hours worked as well as overtime compensation

due under the FLSA;

13


d. An award of liquidated and/or punitive damages as a result of the Defendants'

willful failure to pay for all hours worked as well as overtime compensation pursuant to 29

U.S.C. 216;

e. An award ofprejudgment and post-judgment interest;

f. An award of costs and expenses of this action together with reasonable attorneys'

and expert fees; and

g. Such other and further relief as this Court deems just and proper.

DEMAND FOR TRIAL BY JURY

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiffs demand a trial

by jury on all questions of fact raised by the Complaint and on all issues triable under such.

Dated this 3rd day of May, 2011.

/s/ Jennifer Robbins, Esq.JENNIFER ROBBINS, ESQ.The Robbins Law Firm LLCBar No.: 34393P.O. Box 7757671041 Lincoln AvenueSteamboat Springs, CO 80487Phone: 970-875-0999 Fax: 888-228-5873Email: [email protected] for Plaintiffs Local Counsel

Please also copy:

Vincent B. Lynch, Esq.Lynch & Robbins, P.A.

(Admissionpro hac vice to be filed)2639 Dr. MLK Street NorthSt. Petersburg, Florida 33704

(727) 822-8696

[email protected]

Attorney for Plaintiffs

14

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I. (a) PLAINTIFFS DEFENDANTS

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V. ORIGIN (Ph= gm 'IC in Om Box (ink I Apiccal to District

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VI. CAUSE OF ACTION Brierdescription of cause.Violation ot FLSA

VII. REQUESTED IN 3 t. lihtic. IF TlilS IS A CLASS AC110ti DEMANDS CHECK YES only it demanded in complaint

COMPLAINT: UNDER F R.C.P '3 .11.1t1 DEMAND: Of Yee 11 NO

VIII. RELATED CASE(S)Am.i

IF NYis ternuelionOn .111_, DGEI 1 DOCKET NUMBER

pan p I n SIOMTLIth

1<•:1"1-..!1. MAO JUDOS

Case 1:11-cv-01178-PAB Document 1-2 Filed-05/03/11 USDC Colorado Page 1 of 1

Court Name: U.S. District Court, Colorad

Division: 1Receipt Number: C0X837516Cashier ID: sqTransaction Date: 05/83/2011Payer Name: ROBBINS LAW FIRM

CIVIL FILING FEEFor: ROBBINS LAW FIRMAmount: $350.80

CREDIT CARDAmt Tendered: $350.80

Total Due: $350.08Total Tendered: $350.88Change Amt: $0.00

11-CV-1178

A fee of $45.00 will be assessed on

any returned check.

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Complaint Against FIG

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