In or around December 2008, Tallgrass employed Whitney as the
CFO. Whitney remained an employee of Tallgrass through 2011.10.
To date, there are significant amounts owed to Whitney for back wages andreimbursable expenses. Attempts by Whitney to collect on the amounts due from Tallgrass haveyielded no success.11.
In July 2009, the Bloom Agency presented to Kurtis, Whitney, and Dr. AllenWilliams (then acting CEO of Tallgrass) an initial marketing proposal for Tallgrass. As a resultof the presentation, Tallgrass engaged the Bloom Agency to develop and implement a thoroughmarketing plan for Tallgrass.12.
Pursuant to the agreement, the Bloom Agency completed a thorough marketing plan for Tallgrass. In addition, the Bloom Agency implemented the marketing plan by
completing various tasks, including, but not limited to, designing Tallgrass’ website, conductin
email campaigns on behalf of Tallgrass, and designing Tallgrass’ marketing collateral and
packaging materials. The Bloom Agency submitted invoices to Tallgrass for the services itrendered. Attempts by the Bloom Agency to collect on the amounts due from Tallgrass haveyielded no success.13.
820 ILCS 115/5 provides that every employer shall pay the final compensation of separated employees in full, no later than the next regularly scheduled payday for eachemployee. The monetary equivalent of all earned vacation pay shall be paid as part of theemployee's final compensation.
Final compensation is defined by the IWPCA as not only
including wages, earned bonuses, earned vacation and holidays, but also “any other
compensation owed the employee by the employer pursuant to an employment contract or
agreement between the two parties.”
820 ILCS 115/2.
Case: 1:13-cv-07322 Document #: 1 Filed: 10/11/13 Page 3 of 7 PageID #:3