Case 20-10080-BLS
10.
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Filed 01/16/20
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Plaintiff Troy Ladehoff was employed by Defendants, as a single employer at
the Riverside Facility until his layoff without cause on or about January 3, 2020.
11.
Upon information and belief, at all relevant times, Defendants each jointly
maintained, owned and operated the Facilities.
12.
Plaintiffs and the Other Similarly Situated Employees were employed by
Defendants as a single employer at the Facilities until their termination without cause on or about
January 3, 2020 and thereafter at which time Defendants ordered a mass layoff and/or plant closing
of the Facilities.
13.
Upon information and belief, approximately 1100 persons were employed at
the Facilities by Defendants until their termination without cause on or about January 3, 2020 and
thereafter.
14.
The Plaintiffs bring this action on their own behalf and, pursuant to Rules
7023(a) and (b) of the Federal Rules of Bankruptcy, Rules 23(a) and (b)(3) of the Federal Rules of
Civil Procedure and the WARN Act, 29 U.S.C. § 2104(a)(5), on behalf of all other employees of the
Defendants who also worked at or reported to the Facilities, and who were terminated as part of or as
the foreseeable result of a mass layoff and/or plant Closing at the Facilities ordered by Defendants on
or about January 3, 2020 and thereafter (collectively, “the Class”).
15.
On or about January 3, 2020 and thereafter, Defendants, as a single employer,
ordered the termination of the Plaintiffs’ employment together with the termination of all other
employees who worked at or reported to the Facilities as part of a mass layoff and/or plant closing as
defined by the WARN Act for which they were entitled to receive 60 days advance written notice
under the WARN Act.
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