UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

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1 CASE 0:15-cv Document 1 Filed 01/13/15 Page 1 of 22 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Kurt Seipel, on behalf of himself and all others similarly situated and the proposed Minnesota Rule 23 Class, v. Plaintiff, Case No.: COLLECTIVE AND CLASS ACTION COMPLAINT Safety Signs Inc. and Safety Signs, LLC, Defendants. Kurt Seipel ( Plaintiff Seipel ), on behalf of himself and all others similarly situated, and on behalf of the members of the proposed Minnesota Rule 23 Class, by and through his attorneys, Nichols Kaster, PLLP, brings this action against Defendants Safety Signs Inc. and Safety Signs, LLC (collectively Defendant ) for damages and other relief relating to violations of the Fair Labor Standards Act and Minnesota law. PRELIMINARY STATEMENT 1. The state of Minnesota requires employees who work on projects, financed in whole or in part by state funds, to be paid at a prevailing wage rate. This case is about Defendant s systematic violation of federal and state law by (1) calculating overtime related to work on projects financed in whole or part by state funds at an hourly rate set by Defendant rather than the basic hourly rate set by state prevailing wage law, (2) applying the wrong labor code when calculating prevailing and overtime wages related to work on projects financed in whole or part by state funds, (3) failing to include

2 CASE 0:15-cv Document 1 Filed 01/13/15 Page 2 of 22 all time at the jobsite as hours worked when calculating prevailing and overtime wages, (4) failing to post the prevailing wage rate at its job sites, (5) failing to keep proper records; and (6) deducting administration fees related to fringe benefits. 2. Plaintiff Seipel brings this case on behalf of himself and Defendant s other traffic control and pavement marking employees (and those similarly situated) to recover for these violations. 3. This action is brought as a collective action under the Fair Labor Standards Act, 29 U.S.C. 201, et seq., ( FLSA ) for failure to pay federally mandated compensation. 4. This action is also brought as a class action pursuant to Rule 23 of the Federal Rules of Civil Procedure, to remedy violations of Minnesota law, under the Minnesota Fair Labor Standards Act, Minn. Stat , et seq. ( MFLSA ), the Minnesota Prevailing Wage Law, Minn. Stat , the Minnesota Wage Laws, Minn. Stat and , and breach of contract. 5. Defendant willfully engaged in a pattern, policy, and practice of unlawful conduct for the actions alleged in this Complaint, in violation of the federal and state rights of Plaintiff Seipel, others similarly situated, and members of the proposed Minnesota Rule 23 Class. JURISDICTION AND VENUE 6. This action arises under the FLSA, 29 U.S.C. 201 et seq. Therefore, the Court has original jurisdiction to hear this Complaint and to adjudicate the claims stated herein pursuant to 28 U.S.C

3 CASE 0:15-cv Document 1 Filed 01/13/15 Page 3 of This Court also has supplemental jurisdiction, pursuant to 28 U.S.C. 1367, over the state law claims, as the state and federal claims derive from a common nucleus of operative fact. 8. Venue is proper in the United States District Court, District of Minnesota, pursuant to 28 U.S.C. 1391, as Defendant resides in this District and because events giving rise to the claims occurred here. PARTIES Plaintiff Seipel 9. Plaintiff Seipel is an adult resident of the State of Wisconsin. Plaintiff Seipel works for Defendant in the pavement marking division at Defendant s Lakeville, Minnesota office and at various job sites in Minnesota. 10. Plaintiff Seipel has worked for Defendant from approximately June 2013 to the present. 11. Pursuant to 29 U.S.C. 216(b), Plaintiff Seipel has consented in writing to be a party to the FLSA claims asserted in this action. Plaintiff Seipel s signed consent form is attached as Exhibit A. 12. Plaintiff Seipel and others similarly situated are current and former employees of Defendant within the meaning of the FLSA, 29 U.S.C. 203(e)(1). 13. Plaintiff Seipel and the proposed Minnesota Rule 23 Class are current and former employees of Defendant within the meaning of Minn. Stat , Minn. Stat , and other applicable laws. 3

4 CASE 0:15-cv Document 1 Filed 01/13/15 Page 4 of Plaintiff Seipel, others similarly situated, and members of the proposed Minnesota Rule 23 Class have been employed by Defendant within at three years prior to the filing of this lawsuit. Defendant 15. Upon information and belief, Defendant Safety Signs does business under two legal names, Safety Signs Inc. and Safety Signs, LLC. 16. Safety Signs Inc. is a domestic corporation, with its principal place of business in Lakeville, Minnesota. 17. Safety Signs, LLC is a domestic corporation, with its principal place of business in Lakeville, Minnesota. 18. At all relevant times, Defendant has employed individuals engaged in interstate commerce and/or the production of goods for commerce within the meaning of the FLSA, 29 U.S.C According to its website, Defendant provides traffic-control equipment and services to help keep roads, work zones, construction crews, and pedestrians safe when roads are under construction. Defendant s customers include state and munincipal highway departments throughout Minnesota as well as local contractors and privateproperty owners. 20. Upon information and belief, Defendant s gross annual sales made or business done has been $500,000 or greater at all relevant times. 4

5 CASE 0:15-cv Document 1 Filed 01/13/15 Page 5 of Defendant maintains its main office in Lakeville, Minnesota as well as three regional offices in Duluth, Mankato, and Rochester, Minnesota. Defendant employs traffic control and pavement marking employees throughout the state. 22. Defendant is an employer engaged in interstate commerce and/or the production of goods for commerce, within the meaning of the FLSA, 29 U.S.C. 203(d). 23. Defendant has been and continues to be an employer and employs employees including Plaintiff Seipel, others similarly situated, and the proposed Minnesota Rule 23 Class. See Minn. Stat , , subd. 7, , subd. 4. FACTUAL ALLEGATIONS FOR ALL CLAIMS 24. Plaintiff Seipel, others similarly situated, and members of the proposed Minnesota Rule 23 Class worked as laborers in traffic control or pavement marking (or in other similar positions) for Defendant. 25. Defendant provides traffic-control services as part of highway construction projects in the state of Minnesota. Plaintiff Seipel and the similarly situated employees job duties included, but were not limited to: setting up and taking down barriers and signs to close roads or divert drivers to different road lanes for construction; marking pavement with paint, epoxy, or tape of various colors; or grinding away or water blasting off old paint and tape on asphalt and/or concrete roads to divert traffic for construction. In performing these job duties, Plaintiff Seipel and the similarly situated operated heavy equipment at times. 26. Plaintiff Seipel and those similarly situated performed work on projects financed in whole or in part by state funds. 5

6 CASE 0:15-cv Document 1 Filed 01/13/15 Page 6 of Minnesota law requires employers to pay their employees who work on projects funded in whole or in part by state funds, wages comparable to similar work in the area where the project is located (the prevailing wage ). A purpose of this law is to prevent local wage standards from being undercut on construction projects by low bidders that try to import cheap labor as a cost-cutting technique. See Minn. Stat The prevailing wage consists of a basic hourly rate and a fringe benefit rate. The fringe benefit rate can include benefits such as health insurance, pension plans, and holiday, vacation, and sick plans. The combination of these two rates is the prevailing wage rate. 29. In instances where Plaintiff Seipel and the similarly situated worked on projects that were not financed in whole or in part by state funds, Defendant paid them an hourly rate of pay, which was set by Defendant. 30. When Plaintiff Seipel and the similarly situated worked on projects financed in whole or in part by state funds, Defendant was required to pay them the prevailing wage rate consisting of a basic hourly rate, which was set by law and higher than their hourly rate set by Defendant, plus a fringe benefit rate set by law. See Minn. Stat The prevailing hours of labor may not be more than eight hours per day or more than 40 hours per week. Minn. Stat , Subd. 4. For hours worked in excess of the prevailing hours of labor, employees must be compensated at a rate of at least one 6

7 CASE 0:15-cv Document 1 Filed 01/13/15 Page 7 of 22 and one-half (1-1/2) times the hourly basic rate of pay. Minn. Stat , Subd. 1, , Subd The applicable prevailing wage rate varies upon geographic area and the type of job performed (i.e., the labor code). See e.g., Minn. R et. seq. 33. Defendant failed to pay Plaintiff Seipel and the similarly situated, on projects, financed in whole or in part by state funds, at a rate of at least one and one-half (1-1/2) times the hourly basic rate of pay when they worked hours in excess of the prevailing hours of labor. Instead, Defendant paid them one and one-half (1-1/2) times their lesser hourly rate of pay for these hours worked. 34. Upon information and belief, Defendant also denied Plaintiff Seipel and the similarly situated compensation for time spent at the jobsites. This resulted in Plaintiffs and the similarly situated not being paid for all their hours worked. 35. Defendant also misclassified Plaintiff Seipel and those similarly situated by incorrectly classifying them under a labor code that resulted in a lower prevailing wage rate than what is required by law. 36. For example, in several instances, Defendant classified Plaintiff Seipel as a traffic control person, when he was performing the job duties of a pavement marking or marking removal equipment employee. The prevailing wage rate for a traffic control person is typically less than the prevailing wage rate for a pavement marking employee. 37. Defendant routinely suffered and permitted Plaintiff Seipel and others similarly situated to work more than eight (8) hours in a day and more than forty (40) and 7

8 CASE 0:15-cv Document 1 Filed 01/13/15 Page 8 of 22 forty eight (48) hours in a workweek without paying them the proper overtime compensation for all of their hours worked. 38. For instance, Plaintiff Seipel typically worked over eight (8) hours in a day and over fifty (50) hours per week, where a majority of the hours and overtime hours worked were on projects financed in whole or in part by state funds. Defendant is in possession of the records of these hours worked. 39. Defendant failed to consistently post at the jobsite in a conspicuous place the prevailing wage rates. See Minn. Stat , Subd. 4, , Subd Defendant also misrepresented to Plaintiff Seipel and those similarly situated that the projects on which they were working were not projects financed in whole or in part by state funds, and therefore not prevailing wage jobs, when in actuality they were. When Plaintiff Seipel asked Defendant if he was working on a prevailing wage job, Defendant told him to not worry about it. 41. Defendant routinely deducted a percentage of the fringe benefit received by Plaintiff Seipel and the proposed Minnesota Rule 23 Class as a purported administrative fee. 42. Defendant was aware, or should have been aware, that Plaintiff Seipel and those similarly situated should receive compensation calculated at the prevailing wage rate because, upon information and belief, the Minnesota Department of Transportation audited and ordered Defendant to pay back wages to its employees for certain jobs under its jurisdiction. 8

9 CASE 0:15-cv Document 1 Filed 01/13/15 Page 9 of Defendant received complaints about its failure to pay proper prevailing wages and overtime wages. When Plaintiff Seipel and his co-workers complained to their supervisors, the complaints were ignored. FLSA COLLECTIVE ACTION ALLEGATIONS 44. Plaintiff Seipel, on behalf of himself and others similarly situated, realleges and incorporates by reference the above paragraphs as if fully set forth herein. 45. Plaintiff Seipel brings this action on behalf of himself and all individuals similarly situated. The proposed Collective Class for the FLSA claims is defined as follows: All persons who worked as laborers and/or construction workers in traffic control and/or pavement marking (or in other similar positions) for Defendant any time from three years prior to the filing of this Complaint through the entry of judgment (the FLSA Collective ). 46. Plaintiff Seipel consented in writing to be a part of this action pursuant to 29 U.S.C. 216(b). As this case proceeds, it is likely that other individuals will sign consent forms and join as plaintiffs. 47. Plaintiff Seipel and the FLSA Collective are victims of Defendant s widespread, repeated, systematic and consistent illegal policies that have resulted in violations of their rights under the FLSA, 29 U.S.C. 201 et seq., and that have caused significant damage to Plaintiff Seipel and the FLSA Collective. 48. Defendant willfully engaged in a pattern of violating the FLSA, 29 U.S.C. 201 et seq., as described in this Complaint in ways including, but not limited to, failing to 9

10 CASE 0:15-cv Document 1 Filed 01/13/15 Page 10 of 22 pay employees proper overtime compensation based on the prevailing wage rate. See 29 U.S.C Defendant is liable under the FLSA for failing to properly compensate Plaintiff Seipel and the FLSA Collective, and, as such, notice should be sent to the FLSA Collective. There are numerous similarly situated current and former employees of Defendant who have suffered from the common policies and practices of Defendant, and who would benefit from the issuance of a Court-supervised notice of the present lawsuit and the opportunity to join. Those similarly situated employees are known to Defendant, and are readily identifiable through Defendant s records. MINNESOTA CLASS ACTION ALLEGATIONS 50. Plaintiff Seipel, on behalf of himself and all members of the proposed Minnesota Rule 23 Class, re-alleges and incorporates by reference the above paragraphs as if fully set forth herein. 51. Plaintiff Seipel brings a claim on behalf of himself and as a class action pursuant to Rule 23(a) and (b) of the Federal Rules of Civil Procedure. The proposed Minnesota Rule 23 Class is defined as: All persons who worked as laborers and/or construction workers in traffic control and/or pavement marking (or in other similar positions) for Defendant in Minnesota at any time three years prior to the filing of this Complaint through the entry of judgment (the Minnesota Rule 23 Class ). 52. Individuals in the Minnesota Rule 23 Class are so numerous that joinder of all members is impracticable. While the precise number of class members has not been determined at this time, upon information and belief, Defendant has employed in excess 10

11 CASE 0:15-cv Document 1 Filed 01/13/15 Page 11 of 22 of sixty (60) individuals in traffic control and pavement marking in Minnesota during the applicable limitations period. Plaintiff Seipel and the proposed Minnesota Rule 23 Class have been equally affected by Defendant s violations of law. 53. There are questions of law and fact common to the proposed Minnesota Rule 23 Class that predominate over any questions solely affecting individual members of the proposed Class, including but not limited to: a. Whether Defendant paid Plaintiff Seipel and the proposed Minnesota Rule 23 Class proper prevailing and overtime wages; b. Whether Defendant s charge to Plaintiff Seipel and the proposed Minnesota Rule 23 class for administration fees was unlawful; c. Whether Defendant maintained accurate records that are necessary and appropriate to enforce the state laws; d. Whether Defendant s conduct was willful; e. The proper measure of damages sustained by the proposed Minnesota Rule 23 Class; and f. Whether Defendant should be enjoined from such violations in the future. 54. Plaintiff Seipel s claims are typical of those of the members of the Minnesota Rule 23 Class. Plaintiff Seipel, like the other members of the proposed Minnesota Rule 23 Class, was subject to Defendant s policies and practices of willfully failing to pay the proper prevailing and overtime wages. Plaintiff Seipel and members of the proposed Minnesota Rule 23 Class have sustained similar injuries as a result of Defendant s actions they were all denied proper prevailing wage and overtime pay they should have received. 11

12 CASE 0:15-cv Document 1 Filed 01/13/15 Page 12 of Plaintiff Seipel will fairly and adequately protect the interests of the Minnesota Rule 23 Class, and has retained counsel experienced in complex wage and hour class and collective action litigation. 56. This action is properly maintainable as a class action under Fed. R. Civ. P. 23(b)(1), 23(b)(2), and 23(b)(3). 57. This action is properly maintainable as a class action under Fed. R. Civ. P. 23(b)(1) because prosecuting separate actions by individual class members would create a risk of inconsistent or varying adjudications with respect to individual class members that would establish incompatible standards of conduct for Defendant. 58. This action is properly maintainable as a class action under Fed. R. Civ. P. 23(b)(2) because Defendant has acted or refused to act on grounds generally applicable to the class, thereby making appropriate final injunctive relief or corresponding declaratory relief with respect to the class as a whole. 59. This action is properly maintainable as a class action under Fed. R. Civ. P. 23(b)(3) because questions of law or fact predominate over any questions affecting individual class members, and a class action is superior to other methods in order to ensure a fair and efficient adjudication of this controversy because, in the context of wage and hour litigation, individual plaintiffs lack the financial resources to vigorously prosecute separate lawsuits in federal court against large defendants. Class litigation is also superior because it will preclude the need for unduly duplicative litigation resulting in inconsistent judgments pertaining to Defendant s policies and practices. There do not appear to be any difficulties in managing this class action. 12

13 CASE 0:15-cv Document 1 Filed 01/13/15 Page 13 of Plaintiff Seipel intends to send notice to all members of the Minnesota Rule 23 Class to the extent required by Fed. R. Civ. P. 23. CAUSES OF ACTION COUNT ONE VIOLATION OF THE FLSA OVERTIME PROVISIONS On Behalf of Plaintiff Seipel and the FLSA Collective 61. Plaintiff Seipel, on behalf of himself and the FLSA Collective, re-alleges and incorporates by reference the above paragraphs as if fully set forth herein. 62. The FLSA, 29 U.S.C. 207, requires employers to pay their employees for hours worked in excess of forty (40) in a work week at a rate no less than one and onehalf times their regular hourly rate of pay. 63. Plaintiff Seipel and the FLSA Collective consistently worked more than forty (40) hours per week for Defendant. 64. Defendant did not pay Plaintiff Seipel and those similarly situated the overtime pay they were owed due to its policy and practice of (1) calculating overtime related to work on projects financed in whole or part by state funds at an hourly rate set by Defendant rather than the basic hourly rate set by state prevailing wage law or blended rate if applicable; (2) applying the wrong labor code when calculating their overtime wages related to work on projects financed in whole or part by state funds; (3) failing to include all time worked at the jobsite when calculating overtime wages; and (4) deducting administration fees related to fringe benefits. 13

14 CASE 0:15-cv Document 1 Filed 01/13/15 Page 14 of The forgoing conduct, as alleged, constitutes a willful violation of the FLSA within the meaning of 29 U.S.C Upon information and belief, Defendant also violated the FLSA by failing to accurately record, report, and/or preserve records of hours worked by Plaintiff Seipel and the FLSA Collective, thus failing to make, keep, and preserve records with respect to each of its employees sufficient to determine their wages, hours, and other conditions and practice of employment. 67. As the direct and proximate result of Defendant s unlawful conduct, Plaintiff Seipel and the FLSA Collective have suffered and will continue to suffer a loss of income and other damages. Plaintiff Seipel and the FLSA Collective are entitled to damages, liquidated damages, attorneys fees, and costs incurred in connection with this claim. COUNT TWO VIOLATION OF MFLSA OVERTIME PROVISIONS On Behalf of Plaintiff Seipel and the Proposed Minnesota Rule 23 Class 68. Plaintiff Seipel, on behalf of himself and the proposed Minnesota Rule 23 Class, re-alleges and incorporates by reference the above paragraphs as if fully set forth herein. 69. The MFLSA, specifically, Minn. Stat , requires employers to pay their employees for hours worked in excess of forty eight (48) in a work week at a rate no less than one and one-half (1-1/2) times their regular hourly rate of pay. 14

15 CASE 0:15-cv Document 1 Filed 01/13/15 Page 15 of The Minnesota Prevailing Wage Law, specifically, Minn. Stat , requires that laborers or mechanics of a prevailing wage job be paid one and one-half (1-1/2) times the hourly basic rate of pay for hours worked that exceed the prevailing hours. Prevailing hours are defined as hours worked up to eight (8) in one day or forty (40) in on one week. 71. Plaintiff Seipel and the Minnesota Rule 23 Class consistently worked more than eight (8) hours in one day and forty (40) hours in one week for Defendant on projects financed in whole or part by state funds. 72. Defendant did not pay Plaintiff Seipel and those similarly situated the overtime pay they were owed due to its policy and practice of (1) calculating overtime related to work on projects financed in whole or part by state funds at an hourly rate set by Defendant rather than the basic hourly rate set by state prevailing wage law or blended rate if applicable; (2) applying the wrong labor code when calculating their overtime wages related to work on projects financed in whole or part by state funds; (3) failing to include all time at the jobsite as hours worked when calculating overtime wages; and (4) deducting administration fees related to fringe benefits. 73. The forgoing conduct, as alleged, constitutes a willful violation of law within the meaning of Minn. Stat (5). 74. As the direct and proximate result of Defendant s unlawful conduct, Plaintiff Seipel and the proposed Minnesota Rule 23 Class have suffered and will continue to suffer a loss of income and other damages. Plaintiff Seipel and the Minnesota 15

16 CASE 0:15-cv Document 1 Filed 01/13/15 Page 16 of 22 Rule 23 Class are entitled to damages, liquidated damages, attorneys fees, and costs incurred in connection with this claim. COUNT THREE VIOLATION OF MINNESOTA S PREVAILING WAGE PROVISIONS On Behalf of Plaintiff Seipel and the Proposed Minnesota Rule 23 Class 75. Plaintiff Seipel, on behalf of himself and the proposed Minnesota Rule 23 Class, re-alleges and incorporates by reference the above paragraphs as if fully set forth herein. 76. Plaintiff Seipel brings this cause of action under the Minnesota Prevailing Wage Law, Minn. Stat , Subd. 8, for failure to pay the proper prevailing wage as set forth in Minn. Stat The Minnesota Prevailing Wage Law, specifically, Minn. Stat , requires that laborers or mechanics of a prevailing wage job be paid one and one-half (1-1/2) times the hourly basic rate of pay for hours worked that exceed the prevailing hours. Prevailing hours are defined as hours worked up to eight (8) in one day or forty (40) in on one week. Minn. Stat , Subd Plaintiff Seipel and the Minnesota Rule 23 Class consistently worked more than eight (8) hours in one day and forty (40) hours in one week for Defendant on projects financed in whole or in part by state funds. 79. Defendant did not pay Plaintiff Seipel and those similarly situated the prevailing wages they were owed due to its policy and practice of (1) calculating overtime related to work on projects financed in whole or part by state funds at an hourly 16

17 CASE 0:15-cv Document 1 Filed 01/13/15 Page 17 of 22 rate set by Defendant rather than the basic hourly rate set by state prevailing wage law or blended rate if applicable; (2) applying the wrong labor code when calculating their prevailing and overtime wages related to work on projects financed in whole or part by state funds; (3) failing to include all time at the jobsite as hours worked when calculating prevailing and overtime wages related to work on projects financed in whole or part by state funds; (4) failing to post the prevailing wage rate at its job sites; and (5) deducting administration fees related to fringe benefits. 80. The forgoing conduct, as alleged, constitutes a willful violation of law within the meaning of Minn. Stat (5). 81. As a direct and proximate result of Defendant s unlawful conduct, Plaintiff Seipel and members of the proposed Minnesota Rule 23 Class have suffered and will continue to suffer a loss of income and other damages. Plaintiff Seipel and the Minnesota Rule 23 Class are entitled to damages, liquidated damages, attorneys fees, and costs incurred in connection with this claim. COUNT FOUR VIOLATIONS OF THE MFLSA RECORD KEEPING PROVISIONS On Behalf of Plaintiff Seipel and the Proposed Minnesota Rule 23 Class 82. Plaintiff Seipel, on behalf of himself and the proposed Minnesota Rule 23 Class, re-alleges and incorporates by reference the above paragraphs as if fully set forth herein. 83. Pursuant to Minn. Stat , employers are required to make and keep records regarding work hours and pay. 17

18 CASE 0:15-cv Document 1 Filed 01/13/15 Page 18 of Defendant unlawfully failed to maintain records as required by Minn. Stat Defendant s actions in violating the above named statute were willful and not the result of mistake or inadvertence. 86. As a direct result of Defendant s unlawful conduct, Plaintiff Seipel and members of the Minnesota Rule 23 Class have suffered damages in an amount to be determined at trial. COUNT FIVE VIOLATION OF MINN. STAT On Behalf of Plaintiff Seipel and the Proposed Minnesota Rule 23 Class 87. Plaintiff Seipel, on behalf of himself and the proposed Minnesota Rule 23 Class, re-alleges and incorporates by reference the above paragraphs as if fully set forth herein 88. Pursuant to Minn. Stat , an employer cannot take deductions from wages for loss, theft, damage or other indebtedness without the worker s written permission. 89. Defendant willfully violated Minn. Stat when it deducted administration fees, from Plaintiff Seipel and the proposed Minnesota Rule 23 Class fringe benefits. 90. As a direct and proximate result of Defendants unlawful conduct, Plaintiff Seipel and members of the proposed Minnesota Rule 23 Class have suffered and will continue to suffer a loss of income and other damages. Plaintiff Seipel and the Minnesota 18

19 CASE 0:15-cv Document 1 Filed 01/13/15 Page 19 of 22 Rule 23 Class are entitled to damages, liquidated damages, attorneys fees, and costs incurred in connection with this claim. COUNT SIX VIOLATION OF MINN. STAT On Behalf of Plaintiff Seipel and the Proposed Minnesota Rule 23 Class 91. Plaintiff Seipel, on behalf of himself and the proposed Minnesota Rule 23 Class, re-alleges and incorporates by reference the above paragraphs as if fully set forth herein. 92. Pursuant to Minn. Stat , employers must pay all wages earned by an employee at least once every 31 days on a regular pay day, designated in advance by the employer, regardless of whether the employee requests payment at longer intervals. 93. Defendant willfully violated Minn. Stat when it failed to pay prevailing wages and overtime compensation required by state law, and deducted administration fees, from Plaintiff Seipel and the proposed Minnesota Rule 23 Class fringe benefits. 94. As a direct and proximate result of Defendants unlawful conduct, Plaintiff Seipel and members of the proposed Minnesota Rule 23 Class have suffered and will continue to suffer a loss of income and other damages. Plaintiff Seipel and the Minnesota Rule 23 Class are entitled to damages, civil penalties, attorneys fees, and costs incurred in connection with this claim. 19

20 CASE 0:15-cv Document 1 Filed 01/13/15 Page 20 of 22 COUNT SEVEN BREACH OF CONTRACT On Behalf of Plaintiff Seipel and the Minnesota Rule 23 Class 95. Plaintiff Seipel, on behalf of himself and the proposed Minnesota Rule 23 Class, re-alleges and incorporates by reference the above paragraphs as if fully set forth herein. 96. Defendant entered into many valid contracts with public contracting authorities within the state of Minnesota of which Plaintiff Seipel and the proposed Minnesota Rule 23 Class are third party beneficiaries. 97. These contracts provide that Defendant will pay Plaintiff Seipel at the prescribed prevailing wages for the prevailing hours worked as well as overtime premiums for hours worked in excess of the prevailing hours, in accordance with Minn. Stat Defendant failed to honor these contracts by not paying proper prevailing wages and overtime compensation to Plaintiff Seipel and those similarly situated. 99. As a direct and proximate result of Defendants unlawful conduct, Plaintiff Seipel and members of the proposed Minnesota Rule 23 Class have suffered and will continue to suffer a loss of income and other damages. Plaintiff Seipel and the Minnesota Rule 23 Class are entitled to damages, liquidated damages, and other costs incurred in connection with this claim. 20

21 CASE 0:15-cv Document 1 Filed 01/13/15 Page 21 of 22 PRAYER FOR RELIEF WHEREFORE, Plaintiff Seipel, on behalf of himself and the FLSA Collective, prays for relief as follows: a) Designation of this action as a collective action on behalf of the FLSA Collective and prompt issuance of notice pursuant to 29 U.S.C. 216(b) to those similarly situated apprising them of the pendency of this action, and permitting them to assert timely FLSA claims in this action by filing individual consent forms pursuant to 29 U.S.C. 216(b); b) Judgment against Defendant finding it failed to pay proper overtime for Plaintiff Seipel and the FLSA Collective; c) Judgment against Defendant for an amount equal to Plaintiff Seipel and the FLSA Collective s unpaid back wages at the applicable overtime rates; d) Judgment against Defendant for violating the FLSA by failing to maintain accurate time records of all the hours worked by Plaintiff Seipel and the FLSA Collective; e) A finding that Defendant s violations of the FLSA are willful; f) All costs and attorneys fees incurred prosecuting this claim; g) An award of prejudgment interest; h) An award of liquidated damages; i) Leave to add additional plaintiff by motion, the filing of written consent forms, or any other method approved by the Court; and j) All further relief as the Court deems just and equitable. WHEREFORE, Plaintiff Seipel as Class Representative, on behalf of himself and the proposed Minnesota Rule 23 Class, prays for relief as follows: a) Certification of this action as a class action pursuant to Fed. R. Civ. P. 23 on behalf of the Minnesota Class and the appointment of Plaintiff Seipel as Class Representative and his counsel as Class Counsel; 21

22 CASE 0:15-cv Document 1 Filed 01/13/15 Page 22 of 22 b) Judgment against Defendant finding it failed to pay Plaintiff Seipel and the proposed Minnesota Rule 23 Class proper compensation and overtime compensation; c) Judgment against Defendant for an amount equal to Plaintiff Seipel s and the proposed Minnesota Rule 23 Class unpaid back wages; d) Judgment against Defendant for an amount equal to the administration fees deducted from Plaintiff Seipel and the proposed Minnesota Rule 23 Class; e) All relief available on Plaintiff Seipel and the proposed Minnesota Rule 23 Class claim for breach of contract, including, without limitation, an award of all of unpaid prevailing and overtime wages; f) Judgment against Defendant for violating Minnesota law by failing to maintain accurate time records of all the hours worked by Plaintiff Seipel and the proposed Minnesota Rule 23 Class; g) All damages, liquidated damages, civil penalties, and prejudgment interest available; h) All costs and attorneys fees incurred prosecuting this claim; and i) All further relief as the Court deems just and equitable. Dated: January 13, 2015 NICHOLS KASTER, PLLP /s/ Michele R. Fisher Michele R. Fisher, MN Bar No Brittany Skemp, MN Bar. No IDS Center, 80 South 8th Street Minneapolis, MN Telephone (612) Fax (612) ATTORNEYS FOR PLAINTIFFS 22

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