Central Ave. S.E., Albuquerque, New Mexico, which is within the city limits of theCity of Albuquerque.3. Defendants Eric Szeman
Diane Avila (“Avila’) are,
upon information and belief, the owners of the Malt Shop. Defendant AndrewSzeman is the general manager of Malt Shop.4. Plaintiff
Kevin O’Leary (“O’Leary”)
is a waiter formerly employed by Malt Shop.5. The action is brought for the refusal of Malt Shop, Avila and theSzemans
) to pay the minimum wage required by lawunder the Albuquerque Minimum Wage Ordinance
and for an award of punitive and compensatory damages for
against Defendants for retaliationafter
voted for an increase in the minimum wage and demanded paymentof the minimum wage. This Complaint also seeks injunctive relief to prohibitongoing harassment of
by Defendants, to stop Defendants fromattempting to enforce a coercive illegal contract and to require Defendants tofollow the law.6. MWO allows the City Attorney to bring an action to enforce its termsagainst an employer who refuses to pay an increase in the minimum wage.7.
O’Leary is the real party in interest in the captioned matter
who wasdeprived of a fair and legal wage by Defendants and victimized by Defendants.