Haile et al v. Vivint, Inc. - 3:16-cv-00873-HTW-LRACase 3:16-cv-00873-HTW-LRA Document 1 Filed...

Case 3:16-cv-00873-HTW-LRA Document 1 Filed 11/07/16 Page 1 of 16

IN THE UNITED STATES DISTRICT COFOR THE SOUTHERN DISTRICT OF MISS grP D

JACKSON DIVISIONSON1 2411S

DeMarcus Haile and Shun Blackwell, A----7-1T—vcuRJowfsiue,

individually, and on behalf of all of thosesimilarly situated

Hu l'*•Plaintiffs, Civil Action No. 3: I 19 CA/ Sri 3

V.

Vivint, Inc.

Defendant.

COMPLAINT

COME NOW the Plaintiffs and prospective Class Representatives, under Federal

Rule of Civil Procedure 23, DeMarcus Haile and Shun Blackwell, on behalf of themselves

and all of those similarly situation, who files suit against the above-named Defendant, and

plead as follows:

JURY IRIA DI:::MANDED

PARTIES

1. The First-named Plaintiff, De-•arcus Haile ("Haile") is an adult resident of

Hinds County, Mississippi, and former employee of the Defendant, Vivint, Inc. Haile may

be senTed through his counsel in this matter.

2. The second-named Plaintiff, Shun Blackwell ("Blackwell") is an adult resident

of Lincoln County, Mississippi, and former employee of the Defendant, Vivint, Inc.

Blackwell may be served through his counsel in this matter.

COMPLAINT Page 1 of 16


3. The Defendant, Vivint, Inc. ("Vivint"), is a Utah-based corporation, registered

as a foreign company licensed to do business in the state of Mississippi, with its principal

place of business located in Provo, Utah. Vivint may be served with process through its

registered agent with the Mississippi Secretary of State's Office: CT Corporation System, 645

Lakeland East Drive, Suite 101, Flowood, Mississippi 39232.

JURISDICTION AND VENUE

4. This Court possesses subject matter jurisdiction over the claims made in this

Complaint based upon the complete diversity of state-citizenship of the parties to this

litigation. Complete diversity exists between the parties of this action, and the claims of the

Plthitiffs, not counting the potential claims of the proposed Rule 23 Class, exceed

$75,000.00.

5. Further, this Court possesses federal question subject-matter jurisdiction over

Plaintiffs' claims pursuant to 28 U.S.C. §1337 and the Fair Labor Standards Act. This Court

has the authority to grant declaratory relief pursuant to the FLSA and the federal Declaratory

Judgment Act, 28 U.S.C. 2201-02.

6. This Court possesses personal jurisdiction over each of the Defendants in this

action based upon their substantial and purposeful contacts with Mississippi, the forum

state.

7. Venue for this dispute, among other potentially-permissible venues, properly

lies with this Court, as this litigation involves substantial alleged acts or omissions which

occurred in the Jackson, Mississippi metropolitan area (among other locations, presumably),



located within judicial district of the United States District Court for the Southern District of

Mississippi.

REQUEST FOR CLASS CERTIFICATION UNDER FEDFERAL RULE OFCIVIL PROCEDURE 23

8. The Plaintiffs, on behalf of those similarly-situated, seek certification as the

class representatives for a class action lawsuit, under Rule 23 of the Federal Rules of Civil

Procedure.

9. The class sought to be certified under Rule 23 of the Federal Rules of Civil

Procedure, with the Plaintiffs as the class representatives, is all of those current and former

Vivint employees who have been victimized by the deceptive, intentional, fraudulent,

unconscionable, and dishonest (and/or grossly-negligent) practice of Vivint of being

promised a raise in hourly-pay (typically, $1 per hour) upon the completion of employee

"field training" and who, then, did not receive this pay-increase. Further, a second, separate

class sought to be certified under Rule 23 of the Federal Rules of Civil Procedure in this

litigation, with the Plaintiffs as the class representatives, is all of those former Vivint

employees who have been wrongly terminated (typically for fabricated, pretextual reasons)

by Vivint out of retaliation for seeking the back-pay owed by Vivint for the raises promised,

but never actually given.

10. The Plaintiffs, as the prospective class representatives, and the prospective

members of this/these class(es), under Federal Rule of Civil Procedure 23, have shared

similar injuries, and have suffered from similar forms of financial injury as a sole and

proximate result of the deceptive, intentional, fraudulent, unconscionable, and dishonest



(and/or grossly-negligent) practice of Vivint of being falsely-promised a raise in hourly-pay

(typically, $1 per hour) upon the completion of employee "field training.

11. Further, the Plaintiffs, as the prospective class representatives, and the

prospective members of this/these class(es), under Federal Rule of Civil Procedure 23, have

shared similar injuries, and have suffered from similar forms of financial injury as those

former Vivint employees who have, likewise, been wrongly-terminated (typically for

fabricated, pretextual reasons) by Vivint out of retaliation for seeking the back-pay owed by

Vivint for the raises promised, but never actually given.

12. Specifically, as relates to the appropriated of this proposed class certification

under Rule 23(b)(2) of the Federal Rules of Civil Procedure, the Defendants have acted

and/or refused to act on grounds generally applicable to the class, making appropriate

declaratory and injunctive reliefwith respect to the Plaintiffs, and the class(es) as a whole.

The proposed class members are entitled to injunctive relief to end the Defendants'

common, uniform, malicious, and deceptive employee-wage and retaliatory-discharge

practices.

13. Further, the proposed class is so numerous that joinder would be

impracticable. Although the precise number of members of the proposed class is currently

unknown, this number is far greater than can be feasibly addressed through joinder.

14. The class members of the proposed class also share common questions of fact

and law. Among these common questions of fact are law are: (1) whether the Defendants'

wage and hour policies or practices, as relate to the granting of promised raises for the

completion of "field training" by Vivint are deceptive, unlawful, unconscionable, dishonest,



and fraudulent; (2) whether Vivint has engaged in a pattern and practice of wrongly-

terminating its employees who raise questions regarding payment of "field training" wage-

increases based on a motive of malicious retaliation; and (3) whether monetary damages,

injunctive relief, and/or other equitable remedies for the class are warranted.

15. The Plaintiffs, the proposed class representatives, have suffered injuries, and

have claims, that are typical of all current and/or former employees (victims) of the

deceptive, dishonest, and retaliatory labor practices pleaded in this Complaint.

16. The Plaintiffs, as the proposed class representatives (the Class Plaintiffs), will

fairly and adequately represent and protect the interests of the members of the class(es).

FACTS

17. On or about October 2012, Plaintiff Haile began his employment with

Vivint's Jackson, Miss. location as a security-system-installer for that company.

18. According to the terms of his employment with Vivint, Plaintiff Haile would

start this employment at an hourly wage of $12.00/per hour.

19. Also, consistent with the nationwide company-policy ofVivint, the various

managers who supervised Plaintiff Haile on behalf ofVivint promised Plaintiff Haile (along

with every other employee of Vivint at the Jackson, Miss, location of the Defendant) that he

would receive a $1.00/per hour raise as soon as he completed his field training with that

company.

20. Plaintiff Haile did successfully complete his Vivint field training on or about

November 2012.



21. However, despite being owed, at a minimum, this $1.00/per hour raise from

Vivint since November 2012, Vivint did not begin paying Plaintiff Haile the extra $1.00/per

hour for his successful completion of Vivint's field training until 1.5 years later,

approximately in May 2013.

22. From the period of November 2012 when Plaintiff Haile first successfully

completed his Vivint field training until May 2013, Plaintiff Haile continuously asked

about, and otherwise demanded, payment of the $1.00/per hour raise that he had been

entitled to since November 2012.

23. Throughout the employment of Plaintiff Haile with Vivint, his managers and

supervisors were constantly changing. Plaintiff Haile asked, and otherwise demanded, the

$1.00/per hour raise to which he was entitled to each of his supervisors at Vivint.

24. Finally, in May of 2013, Plaintiff Haile had finally had enough and raised his

long-running concerns about the dishonest and deceptive wage-policies (broken promises) at

an Mississippi-Vivint meeting attended by all security-systems-installers for that region of

Vivint.

25. During this May 2013 company meeting attended in-person by: Plaintiff

Haile, PlaintiffBlackwell, Marcus (last name currently unknown), Dewain (last name

currently unknown), Leslie Nelson, Traumone Patton, three other security-system-installers

whose identities are not currently known, Shawn (last name unknown; was District Manager

for Vivint in May 2013), and Gary Maisenel Plaintiff Haile publicly raised the issue of the

$1.00/per hour raise that had been promised to all security-system-installers who have

successfully completed Vivint field training, but which no one had actually been paid.



26. During this same May 2013 meeting, several other security-system-installers

employed by Vivint stated that they suffered from the exact same broken promises regarding

wages by Vivint.

27. Shawn (last name unknown; the District Manager ofVivint's Jackson, Miss.

region in May 2013), during this meeting, stated that he would "look into the situation."

28. Next, three-to-four days following the above-described meeting, Shawn (the

then-District Manager) called Plaintiff Haile and told Plaintiff Haile that: (1) Plaintiff Haile

would begin receiving his now-overdue raise of $1.00/per hour beginning immediately; (2)

that all back-pay owed by Vivint to Plaintiff Halle for the 1.5 years that he worked without

receiving the raise to which he had been entitled this entire time would promptly be paid to

Plaintiff Haile; and (3) that all overtime payments made by Vivint to Haile would be re-

adjusted to reflect the $13.00/per hour (and not $12.00/per hour) base-rate of pay upon

which all overtime calculations were based.

29. Then, four weeks later (not immediately), Plaintiff Haile received his first

paycheck reflecting the new hourly-wage of $13.00/per hour that had been owed since

November 2012.

30. Exactly one-month after Plaintiff Haile finally began receiving the long-

overdue hourly base wage of $13.00/per hour, Haile reached out to his former District

Manager, Shawn, again to discuss these continuing payment problems with Vivint.

31. During this telephone conversation, when pressed on the back-pay and

overtime-adjustments owed to Plaintiff Haile, District Manager, Shawn, gave Haile the



runaround. Finally, District Manager, Shawn, admitted to Haile that Vivint was not willing to

pay any back-pay or overtime-adjustments.

32. Without providing any further explanation, (then) District Manager, Shawn,

simply stated "we (Vivint) can't do that (pay back-pay and the corrected overtime amounts,

as promised)."

33. For the next (approximately) year-and-a-half Plaintiff Haile continuously

raised these same complaints and demands with his constantly-changing supervisors at

Vivint.

34. For the next (approximately) year-and-a-half Plaintiff Haile continuously was

told by Vivint that the situation would be corrected and that Plaintiff Haile simply needed

to be patient and allow the situation to be fixed internally at Vivint.

35. The above representations about correcting Plaintiff Haile's, and the other

security-installers' back-pay and overtime wages, from Vivint and its management turned out

to be false, deceptive, and either grossly-negligent or malicious.

36. Finally, after continuing to raise his legal demands about these long-running

wage-deceptions with Vivint management, Plaintiff Haile, on or about May 6, 2015, received

a telephone call from his (then) Manager at Vivint (this person, whose identity is currently

unknown, was serving as the "Acting Manager" for the Jackson, Miss., region ofVivint in

May 2015, and he worked out of a Vivint office in Alabama). During this peculiar, surprise,

telephone call, the Acting District Manager for the Jackson, Miss., region ofVivint told

Plaintiff Haile that he needed to meet him early, that morning, at the Hilton hotel located on

County Line Road in Jackson, Miss.



37. During this peculiar, surprise, early-morning meeting, the Acting District

Manager ofVivint began by making small-talk. Then, moments later, and out of nowhere,

this Acting District Manager added: "By the way, we (Vivint) are letting you go."

38. When asked why he was being fired by Vivint, Plaintiff Haile was told by this

Acting District Manager the following lie: "Because we (Vivint) were following you, and you

didn't show up to your job."

39. The true motive for the (wrongful) termination of Plaintiff Haile was

malicious and unlawful retaliation for Haile continuing to push the issues of the owed pack-

pay and owed overtime adjustments that Vivint owed to Haile, and to the other security-

system-installers at the Jackson, Miss., region of Vivint, and perhaps nationwide.

40. The stated reason for Vivint's (wrongful) termination of Plaintiff constituted a

knowing lie on the part ofVivint.

41. Second-named Plaintiff, Blackwell, another former employee ofVivint,

suffered from a nearly, if not completely, identical set of facts as Plaintiff Haile at the hands

of Vivint.

42. Plaintiff Blackwell, whose exact dates of employment will be illuminated in the

discovery process of this litigation, identical to Plaintiff Haile: (1) is owed significant back-

pay for the $1.00/per hour raise he was never given for successfully completing Vivint field

training; (2) is owed significant overtime-adjustments related to the willful or grossly-

negligent failure of Vivint to pay the promised $1.00/per hour raise following Plaintiff

Blackwell's successful completion of Vivint field training; and (3) was maliciously and

unlawfully terminated, out of retaliation (identical to Plaintiff Haile), for fabricated reasons,



due to Plaintiff Blackwell's insistence that he receive the compensation that Vivint had

promised him, but had failed to pay.

43. The Plaintiffs have suffered severe fmancial damages that were solely and

proximately caused by grossly-negligent, dishonest, deceptive, malicious, and/or retaliatory

actions pleaded in this Complaint.

(THIS SPACE INTENTIONALLY LEFT BLANK)



COUNT ONE —VIOLATIONS OF THE FAIR LABOR STANDARDS ACT

44. The Plaintiffs incorporate by reference all allegations of all previous

paragraphs and further alleges as follows:

45. Vivint has committed systemic, continual, repeated, knowing, intentional, and

malicious violations of the FLSA, as amended. In particular, the Vivint has engaged in

knowing, and repeated, violations of the FLSA's requirement to pay overtime at 1.5 times

the true base hourly wage for all hours worked in excess of 40 per week.

46. Vivint's management even went so far as to acknowledge to the Plaintiffs that

such overtime-adjustments were legally owed to the Plaintiffs, along with all other security-

system-installers working in the Jackson, Miss., region of Vivint.

47. Nonetheless, Vivint knowingly failed to pay these overtime wages that it knew,

in fact, were owed to the Plaintiffs, along with many other security-system-installers

employed by Vivint.

48. The above wrongful acts have solely and proximately caused the Plaintiffs

severe financial damages.

49. BASED UPON THE ABOVE-PLEADED ALLEGATIONS, the Plaintiffs,

on behalf of themselves and all of those similarly situated, demand that they, as the Class

Representatives, be awarded damages in an amount that shall be proved to finder-of-fact at

trial. However, these pleaded-damages include, but are not limited to: actual damages,

compensatory damages, punitive damages (in an amount not less than $5,000,000.00), all

attorneys' fees, all costs of litigation, expenses, all legal pre and post-judgment interest, and



all other relief that is appropriate under the FLSA, or that the Court finds to be just and

equitable under the facts to be proven at trial.

COUNT TWO FRAUD




malicious misrepresentations of materials facts for the purpose of financial gain against its

own security-system-installer employees. In particular, Vivint has engaged in a pattern of

deceptive, fraudulent, and dishonest wage-practices related to its knowingly false-promises to

give pay-raises to its security-system-installation employees once they complete their field

training.

52. The above wrongful acts have solely and proximately caused the Plaintiffs

severe financial damages, and they have caused a financial windfall for Vivint.







all other relief that the Court finds to be just and equitable under the facts to be proven at

trial.



COUNT THREE BREACHES OF CONTRACT (EXPRESS WARRANTIES)




malicious misrepresentations of express promises of pay-increases and overtime-

adjustments, as pleaded in this Complaint, above. In particular, Vivint has engaged in a

pattern of deceptive, fraudulent, and dishonest wage-practices related to its false-promises to

give pay-raises to its security-system-installation employees once they complete their field

training, as pleaded in this Complaint.

56. The above violations of express contractual terms have solely and proximately

caused the Plaintiffs severe financial damages.








trial.

COUNT FOUR (GROSS) NEGLIGENCE





59. Vivint has, in a gross, wanton, reckless, and unconscionable manner, violated

the standard of care that they owed to the Plaintiffs, when they failed to pay its security-

system-instnller employees the $1.00/per hour raise that Vivint promised them as of the date

of their successful completion, respectively, of Vivint field training, as well as failing to make

the promised overtime-adjustments for these employees based upon the higher base-rate(s)

of hourly-wages that should have been used as the inputs by Vivint for these overtime-

calculations.

60. The above (gross and wanton) violations of the standard of care owed by

Vivint to the Plaintiffs have solely and proximately caused the Plaintiffs severe financial

damages.








COUNT FIVE WRONGFUL TERMINATION (RETALIATORY DISCHARGE).





63. Vivint unlawfully, maliciously, and out of vengeful retaliation for being

exposed for its unlawful wage-practices toward its security-system-installers, pleased above in

this Complaint, wrongly terminated the Plaintiffs.

64. Further, to whitewash this tortious and wrongful termination, Vivint

fabricated knowingly false pretexts to fire the Plaintiffs, along with an unknown number of

other similarly-situated security-system-installer employees around the United States.

65. The true reason that the Plaintiffs were fired by Vivint is that they continued

to make demands for their legal rights to be paid lawfully under the FLSA, and as promised

by Vivint. Such demands bring these Plaintiffs under the Mc/Irn1 (and its progency)

exceptions to the at-will employment principles under Mississippi state law.



Representatives, be awarded damages in an amount that shall be proved to finder-of-Eact at


compensatory damages, punitive damages (in an amount not less than $5,000,000.00), 211



DeMARCUS HAILE andSHON BLACKWELL, on behalf ofthemselves and all of those similarlysituated

By:

Me.'1171 P. Allied-Bmce Tominex, Im, 626 So. 2c1 603 (Miss. 1993).



Macy D. Hanson

Attorney for the Plaintiffs

MACY 1D. HANSON MS BAR 104197

[email protected] LAW OFFICE OF MACY D. HANSON, PLLCTHE ECHELON CENTER4102 FIRST CHOICE DRIVE

MADISON, MISSISSIPPI 39110TELEPHONE: (601) 853-9521FACSIMILE: (601) 853-9327


FOR OFFICE USE ONLY

JS 44 (Rev. 0816) Case 3:16-cv-00873-Hydy+fiAcpmffsta_EIEfiled 9/fi6cAFtgEtil3f kno_ LARThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as

provided bylocal rules of court This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court l'or theipurpose of nitiating the civil docket sheet. (SEE INSTRUCTIONS ay NEXT PiGE OF THIS row)

I. (a) PLAINTIFFS DEFENDANTSDeMarcus Haile Vivint, Inc.Shon Blackwell

(b) County of Residence or First Listed Plaintiff Hinds (MS County of Residence of First Listed Defendant Utah County (UT)(ExcEPT IN US. MINTIEF C..

j(IN U.S. ELI/NT/FE CASES ONLY)

ST-NOM: IN LAND CONDEMNATION CASES. USE THE LOCATION OF

THE TRACT OF LAND INVOLVED.

The Law Office of Macy --7!5:::::1 rn1(01 Attorneys (Pim Name. AddIvss, and TeleptPLLCme Nnmb r) NOV -7 2016 Attoeys illKoromoD. Hanson,

102 First ChoiceDrive.Madison, MS 39110 601-853-9521 ARTHUR JO ON

DEPUTYEl'e ..........iiii^.,

II. BASIS OF JURISDICTION (Place an "X" in One Box Only) HI. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One BoxAt. PlanUBT(Ear Oivervity UtrAw WO and One BOXOr Iktinntant)

7 I U.S. Government 3 Federal Question 19'F DEE P.M DEE

Plaintiff (U.S. Government Not a Early) Citizen of This State IX 1 0 I Incorporated or Principal Place 71 4 1 4ofBusiness In This Slate

O 2 U.S. Government El 4 Diversity Cii inn of Another State CI 2 X 2 Incorporated and Principal Place (3 5 0 5Defendant (Indium. Cni.renship ofPar)in.; in Item 111) of Business In Another State

Citizen or Subject of a 1 3 1 3 Foreign Nation 2 6 0 6

Foreign Coniurv

IV. NATURE OF SUIT (Marc an -.'Cin One Box Onlv) Click here for \nnirc.,,I LH: i,KiL: 1)-,in, •!1.

1 CONTRACT TORTS EORFEFITRE/PENAL-ry BANKRUPTCY OTI I ER sTAILTE$ j1 HO Insurance PERSONAL INJURY PERSONAL INJURY 1 625 Drug Related Seizure 0 422 Appeal 281USC 158 1 375 False 'Jahns Act0 120 Marine 771 310 Airplane 7 365 Personal hijury of Property 21 USC 851 1 423 Withdrawal 0 376 Qui lam (31 USCO 130 Miller Act 0 315 Airplane Product Product Liability 73 600 Other 25 CSC 157 3729(a))1 140 Negotiable Instrument Liability- 1 367 Health Care 7 400 State ReapportionmentO 150 Recovery of Overpayment 1 320 Assault. Libel & Pharmaceutical PROPERTY RIGHTS 7 410 Antitrust

8.:. Enforcement ofJudgment Slander Persona! Injury 7 620 Copyrights 1 430 Banks and BankingCI 151 Medicare Act 0 330 Federal Employers' Product Liability 7 530 Patent 0 450 CommerceO 152 Recovery of Defaulted Liability D 368 Asbestos Personal 0 840 Trademark 7 460 Deportation

Student Loans 0 340 Marine hijury Product 1 470 Racketeer Influenced and(Excludes Veterans) CI 345 Marine Product Liability I ABOR SOCIAL SECURITY Corrupt Organizations

7 153 Recovery of Overpayment Liability PERSONAL PROPERTY X 710 [awl abor Standards 71 861 IBA (1395111 1 480 Consamer Creditof Veteran's Benefits 1 350 Motor Vehicle CI 370 Other Fraud Act 1 862 Black Lung (923) CI 490 CabIc/Sat TV

O 160 Stockholders' Snits 1 355 Motor Vehicle CI 371 Truth in Lending CI 720 LaborManagetnent CI 863 DI WC DIWW (405(9)) CI 850 Securities:Commodities;O 190 Other Contract Product Liability CI 380 Other Personal Relations ii 864 SSID Title XVI ExchangeO 195 Contract l'roduet Liability 1 350 Other Personal Property Barnage Cl 740 Railway labor Ad El 865 RSI (405(g)) 1 890 Other Statutory ActionsCI 196 Franchise Injury CI 385 Property Damage CI 751 Family and Medical 71 891 Agricultural Acts

0 362 Pemonal Injury Product Liability Leave Act El 893 Environmental MattersMedical Malpractice El 790 Other Labor IMigation 1 1(95 Freedom of Information

1 REAL PROPERTY CIVIL RIGHTS PRISONER PETITIO'NS 7 791 Employee Retirement FEDERAL TAX SUITS Act3 210 Land Condemnation 2 440 Other Civil Rights Habeas Corpus: Income Security Act 1 870 'rases (U.S. Plaintiff 0 896 Arbitration3 220 Foreclosure 0 441 Voting 0 463 Alien Detainee or Defendant) 0 899 Administrative l'rocedure3 230 Rent Lease & Ejectment 71 442 Employment 0 510 Motions to Vacate n 871 IRS—Third Party Act Review or Appeal of1 240 Tons te Land 71 443 Housillg. Sentence 26 LiSC 7609 Agency Decision3 245 Tort Product Liability Accommodations 0 530 General 0 950 Constitutionality of7 290 All Other Real Property 7 445 Amer. w Disabilities 1 535 Death Penalty IMMIGRATION State Statutes

Employment Other: 01 462 Naturalization Application7 446 Amer. w Disabilities 1 540 Mandamus & Other 7 465 ()Thor Immigration

Other 7 550 Civil Rights Actions21 44S 1:ducation 0 555 Prison Condition

0 560 Cix il DetaineeConditions ofConfinement

V. ORIUIN (Place an "X'' in One &A Ws)X l Original --.1 7 Removed from 1 3 Remanded from 1 4 Reinstated or .–I 5 Transferred from :7 6 Multidistrict CI 8 Multidistrict

Proceeding State Court Appellate Court Reopened Another District Litigation LitigationOpecif,v) Transfer Direct File

Cite the U.S. Civil Statute under which you are tiling (no Hot rifejurixelectianal statutes unk.s.v diversity):Fair Labor Standards Act, as amended.

VI. CAUSE OF ACTION Brief description of cause:

Employment Wage and Retaliatory Discharge SuitVII. REQUESTED IN CR CHECK IF THIS IS A CLASS ACTION DEMAND CHECK YES only ildemanded in complaint:

COMPLAINT: UNDER RULE 23, F.R.Cv.P. 5, 000,000.00 JURY DEMAND: X Yes C) No

VIII. RELATED CASE(S)IF ANY fSet, instructions):

JUDGE DOCKET NUMBER

DATE SIGNATURE OF A HORNEY OE RECORD ------->2 —26/11/07/2016

RECEIPT AMOUNT APPLYING IFP JUDGE MAG. JUDGE

ClassAction.orgThis complaint is part of ClassAction.org's searchable class action lawsuit database and can be found in this post: Vivint Sued by Employees Over Rampant Wage Problems

https://www.classaction.org/news/vivint-sued-by-employees-over-rampant-wage-problems

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