P. 1
2 Complaint

2 Complaint

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Published by Eugene D. Lee

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Categories:Types, Research, Law
Published by: Eugene D. Lee on Aug 13, 2009
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02/06/2013

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209. Pursuant to 20 C.F.R. § 541.118(6), where a deduction not permitted by these

interpretations is inadvertent, or is made for reasons other than lack of work, the exemption will

not be considered to have been lost if the employer reimburses the employee for such deductions

and promises to comply in the future.

. As a result of Defendants' wrongful conduct, Plaintiff has suffered harm to his

profession, reputation, and experienced feelings of shame, mortification, and hurt

. Defendants' wrongful conduct was a substantial factor in causing harm to

Plaintiff's profession and reputation.

05. At all material times, Defendants, and each of them, either knew that each

statement was false or had serious doubts about the truth of each statement, and that they acted

with malice, oppression, or fraud, entitling Plaintiff to an award of punitive damages against the

individual Defendants.

WHEREFORE Plaintiff prays for relief as stated in pertinent part hereinafter.

ELEVENTH CLAIM

(Violation of FLSA)
(Against Defendant County, and DOES 1 through 10 inclusive)

206. Plaintiff alleges this Eleventh and separate claim for reimbursement of deductions

from his salary made in violation of FLSA against Defendant County and DOES 1 through 10,

inclusive.

7. Plaintiff incorporates by reference herein the allegations contained in Paragraphs

1 through 136 above, inclusive.

208. Pursuant to 20 C.F.R. § 541.118(1), an employee will not be considered “on a

salary basis” if deductions from his predetermined compensation are made for absences

occasioned by the employer.

Case 1:07-cv-00026-OWW-TAG Document 2 Filed 01/06/2007 Page 44 of 47

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