UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF TEXASHOUSTON DIVISIONHILDA L. SOLIS, Secretary of Labor, )United States Department of Labor, ))Plaintiff, ))v. ) Civil Action No.)KINDER MORGAN ENERGY PARTNERS LP )LP and KINDER MORGAN, INC. )Individually and Jointly, ))Defendants. )______________________________________ )COMPLAINT
Plaintiff, Hilda L. Solis, Secretary of Labor, United States Department of Labor, bringsthis action to enjoin the Defendants Kinder Morgan Energy Partners LP and Kinder Morgan, Inc.from violating the provisions of Sections 7 and 15(a)(2) of the Fair Labor Standards Act of 1938,as amended, 29 U.S.C. §§ 201,
, hereinafter referred to as the Act, and to restrainDefendants from withholding payment of overtime compensation found by the Court to be dueemployees under the Act,
and an equal amount as liquidated damages due to the employees who arenamed in the attached Exhibit A.
I.This Court has jurisdiction over this action and Defendants pursuant to Sections 16 and17 of the Act,
29 U.S.C. §216 and §217,
and 28 U.S.C. §§1331 and 1345.II.1. Defendant Kinder Morgan Energy Partners LP is now, and at all timeshereinafter mentioned was, a corporation with a place of business and doing business at 500
Case 4:11-cv-00454 Document 1 Filed in TXSD on 02/04/11 Page 1 of 4