Non-debtor MF Global Holdings USA Inc. is the direct parent of non-debtor MFGlobal Inc., a Delaware company, and Debtor MF Global Finance USA Inc., a New York corporation.10.
Debtor MF Global Holdings Ltd and MF Global Finance USA Inc. maintainedand operated their corporate headquarters at the 717 Fifth Avenue, New York, New York Facility and maintained and operated additional sites and facilities, as that term is defined by theWARN Act and NY WARN Act, throughout the United States including 440 South LaSalleStreet, 20
Floor, Chicago Illinois (the “LaSalle Facility”), 55 East 52
Floor, NewYork, New York (the “52
Street Facility”), and the West Jackson Facility (collectively the“Facilities”).11.
MF Global Inc. maintained and operated its corporate headquarters at the 717Fifth Avenue, New York, New York Facility. Until on or about November 11, 2011, thePlaintiff and the other similarly situated former employees were employed by Defendants andworked at or reported to one of the Facilities.12.
On October 31, 2011, Defendants filed voluntary petitions for relief underChapter 11 of Title 11 of the United States Bankruptcy Code.
WARN CLASS ALLEGATIONS
Plaintiff brings the First Claim for Relief for violation of 29 U.S.C. § 2101
.,on her own behalf and on behalf of all other similarly situated former employees, pursuant to 29U.S.C. § 2104(a)(5) and Federal Rules of Civil Procedure, Rule 23(a) and (b), who worked at orreported to one of Defendants’ Facilities and were terminated without cause on or aboutNovember 11, 2011, and within 30 days of that date, or were terminated without cause as thereasonably foreseeable consequence of the mass layoffs and/or plant closings ordered by
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