UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF INDIANAINDIANAPOLIS DIVISIONANDREW SHEPHERD on behalf of)himself and all others similarly situated,))Plaintiffs,))CAUSE NO: 1:12-cv-167-vs-))ASI, LIMITED,))Defendant.)
CLASS ACTION COMPLAINTAND JURY DEMAND
Andrew Shepherd (“Plaintiff”) on behalf of himself and a class of those similarlysituated, by way of Complaint against ASI, Limited, (hereinafter referred to as“Defendant”) by and through his counsel alleges as follows:
NATURE OF THE ACTION
1. This is a civil action for collection of unpaid wages and benefits for sixty(60) calendar days pursuant to the Worker Adjustment and Retraining Notification Act of 1988, 29 U.S.C. §§ 2101-2109
, (the “WARN Act”). The Plaintiff was anemployee of the Defendant until he was terminated as part of, or as a result of a plantclosing ordered by the Defendant. As such, the Defendant is liable under the WARN Actfor the failure to provide the Plaintiff and the other similarly situated former employees atleast 60 days’ advance written notice of termination, as required by the WARN Act.
Case 1:12-cv-00167-SEB-DML Document 1 Filed 02/06/12 Page 1 of 8 PageID #: 1