Case 20-10080-BLS
Doc 5
Filed 01/16/20
Page 3 of 15
PARTIES
4.
Upon information and belief, at all relevant times, Defendant USM was
incorporated in the state of Michigan with Facilities located at 7839 Costabella Avenue, Remus,
MI 49340 (the “Remus Facility”) and 2416 Watauga Rd, Johnson City, TN 37601 (the “Johnson
City Facility”).
5.
Upon information and belief, at all relevant times, Defendants TMA, Premier,
Granite and Solid were Delaware corporations with facilities at 4525 NW 41st ST. Riverside MO.
64150 (the “Riverside Facility”), Huntsville, AL, Pelham, AL, Chattanooga, TN and Alpharetta, GA,
as well as other facilities (collectively with the Remus Facility, Johnson City Facility, and Riverside
Facility, “the Facilities”).
6.
Upon information and belief, at all relevant times, Defendants Clio
Intermediate and Clio Holdings were Corporations with headquarters located at 4525 NW 41 st Street,
Ste. 400 Riverside, MO 64150.
7.
Upon information and belief, at all relevant times, Defendants, as a single
employer jointly maintained, owned, and operated the Facilities.
8.
On or about January 15, 2020 Defendants filed with this Court voluntary
petitions for relief under Chapter 7 of the United States Bankruptcy Code.
9.
Plaintiff Zachary Bentley was employed by Defendants, as a single employer,
at the Remus Facility until his layoff without cause on or about January 3, 2020.
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