Case 20-10080-BLS
16.
Doc 5
Filed 01/16/20
Page 5 of 15
Upon information and belief, Defendants constituted a “single employer” of
the Plaintiffs and the other Class members in that among other things:
Common Ownership
(a)
Upon information and belief, in or about March 2017, Clio Holdings
purchased a majority of the shares in USM through Clio Intermediate, it wholly owned
subsidiary.
(b)
Upon information and belief, in or about May 2017, Clio Holdings through
Clio Intermediate purchased a majority of the shares in TMA, Premier, Granite and Solid.
Common Directors and Officers
(c)
Upon information and belief, at all relevant times, USM, TMA, Premier,
Granite and Solid did not maintain its own Board of Directors.
(d)
Upon information and belief, all decisions at USM, TMA, Premier, Granite
and Solid were made by the Board of Directors of Clio Holdings and Clio Intermediate.
Dependency of Operations
(e)
Upon information and belief, at all relevant times, USM, TMA, Premier,
Granite and Solid were completely dependent on Clio Holdings through Clio
Intermediate for its daily operating funds which was provided either directly by Clio
Holdings through Clio Intermediate or through financing arranged by Clio Holdings
through Clio Intermediate.
Unity of Personnel Policies
(f) Upon information and belief, at all relevant times USM, TMA, Premier,
Granite and Solid and Clio Holdings through Clio Intermediate maintained common
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