COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in

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1 Weld County, Colorado, District Court, th Avenue Greeley, CO Plaintiff: vs. Defendants: JENNIFER BELL, individually and on behalf of all others similarly situated, BRADLEY PETROLEUM, INC., a Colorado Corporation, SAV-O- MAT, INC. a Colorado Corporation Lee E. Christian (18743) Lee E. Christian, P.C. 415 Mason Court, Building #2 Fort Collins, CO Phone Number: FAX Number: Case Number: Division COURT USE ONLY Courtroom COMPLAINT WITH JURY DEMAND follows: The Plaintiff, by and through her attorney, LEE E. CHRISTIAN, P.C., respectfully alleges as INTRODUCTION, CLASS ALLEGATIONS, PARTIES, JURISDICTION & VENUE 1. This is a class action for damages and declaratory relief against Bradley Petroleum, Inc., and Sav-O-Mat, Inc. (The Defendants) for nonpayment of wages after the filing of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in bad faith. Plaintiff was also not paid her final vacation pay. 2. Plaintiff Jennifer Bell is a resident of Weld County, State of Colorado.

2 3. Defendants Bradley Petroleum, Inc. and Sav-O-Mat, Inc. are Colorado corporations maintaining a principal place of business at 7268 S Tucson Way, Centennial, CO At all times relevant in this Complaint, the Defendants were the employer of Plaintiff and others similarly situated. The Defendants operate approximately 50 gas stations and convenience stores in Colorado, New Mexico and Wyoming.

3 4. At all times referenced herein, Plaintiff Jennifer Bell was employed at a Sav-O- Mat service station in Weld County, Colorado. 5. Jennifer Bell is a member of a class of persons who were terminated from the Defendants for alleged theft. These allegations of theft were made without probable cause. The allegations of theft were made so that the Defendants could illegally recover monies for an alleged shortage. The allegations were made so Defendants wouldn t have to pay the final paycheck of the Plaintiff and similarly situated persons at the time of termination. Agents and/or employees of the Defendants contacted the police. At times a criminal court case was brought against the class of persons. The criminal investigations and/or criminal cases ended in favor of the employees. No convictions were entered against the class of persons. Yet, the individual employees were not paid their final pay with interest and penalties after the criminal investigation or case ended. This was the policy and practice of the Defendants. The policy and practice was in bad faith. The class of persons was denied lawfully earned wages because of false accusations of theft. 6. Jennifer Bell is a member of a class so numerous that joinder of all members is impracticable. 7. There are questions of law or fact common to the class. 8. The claims or defenses of the representative parties are typical of the claims or defenses of Plaintiff s claim. 9. The representative party, Jennifer Bell, will fairly and adequately protect the interests of the class. 3

4 10. The prosecution of separate actions by or against individual members of the class would create a risk of inconsistent or varying adjudications with respect to individual members of the class which would establish incompatible standards of conduct for the party opposing the class. 11. Alternatively, the prosecution of separate actions by or against individuals members of the class would create a risk of adjudications with respect to individual members of the class which would as a practical matter be dispositive of the interests of the other members not parties to the adjudications or substantially impair or impede their ability to protect their interest. 12. The questions of law or fact common to the members of the class predominate over any questions affecting only individual members, and a class action is superior to the other available methods for the fair and efficient adjudication of the controversy. 13. Bradley Petroleum, Inc. and Sav-O-Mat, Inc. are owned and operated under similar ownership, policies and procedures. Any distinction between the two Defendants is minimal. FACTUAL BACKGROUND 14. Plaintiff was employed from January 24, 2008 to May 25, 2013 at Sav-O-Mat, a service station operated by Bradley Petroleum, in Greeley, Colorado. Ms. Bell was terminated for a shortage of cash at the store. The Greeley Police Department was contacted by an agent of the Defendants. Plaintiff was not charged. Plaintiff did not steal anything. Yet, Plaintiff was not paid her final paycheck. 4

5 15. It is common in the gas station industry and with the Defendants to have shortages in the cash register and shortage of products. The shortages can often be explained by reasons other than theft. Yet, the policy of the Defendants is to recover shortages from their employees. 16. The Defendants employees consistently reimbursed Defendants out of their pocket for shortages out of fear of losing their job or having the police contacted. This action occurred even though there was no theft. This reimbursement caused unjust enrichment to the Defendants. 17. Despite her demands for her wages, the Plaintiff s final paycheck was wrongfully withheld. Defendants alleged that the Plaintiff had stolen from them. No court case was filed against Plaintiff. 18. Upon information and belief, Plaintiff received a W-2 that included these wages despite never receiving them. No interest or penalties were paid to any individual who may have finally been paid after they complained to the Colorado Department of Labor and Employment. 19. Bradley Petroleum and Sav-O-Mat (hereafter Bradley) have made illegal deductions from employee wages for shortages for THIRTY FIVE YEARS despite repeated government interventions, lawsuits, settlement agreements, consent decrees and court orders designed to stop them. The United States and Colorado Departments of Labor instituted formal legal actions in 1981, 1990, 1996 and The Colorado Department of Labor has received hundreds of complaints from the Defendants employees regarding illegal deductions from pay for shortages over 35 years. 5

6 20. In 2003, Bradley entered a settlement agreement in the case Okamoto v. Bradley Petroleum, et.al., Denver County District Court Case No.2001 CV 5947 in which they clearly and explicitly agreed to cease making illegal deductions such as the one s involved in this case. The Complaint was originally filed by Amy Okamoto, individually and on behalf of all others similarly situated. The Complaint was amended numerous times to add additional plaintiffs. 21. Despite the settlement agreement, Bradley made 1,373 illegal deductions from wages totaling $52, in the years 2007 and 2008 alone. The Denver County District Court found these deductions illegal, ordered Bradley to repay the aggrieved employees, and ordered an audit of payroll records to unearth additional illegal deductions. This order was reversed on jurisdictional grounds by the Court of Appeals. Nevertheless, the lengthy litigation is illustrative of the ongoing practice and policy of the Defendants to make illegal deductions in the payment of wages. 22. The Defendants policy and practice regarding shortages is to terminate the employee for theft, refuse to pay the employee s final paycheck, call law enforcement, and to not fully pay the wages/interest/penalties when no conviction has entered. Although some employees who filed complaints with the Colorado Department of Labor were eventually paid their wages, the employees were not paid interest or penalties. 23. The Plaintiff was not paid her final vacation pay of one week upon termination. 6

7 FIRST CLAIM FOR RELIEF (WAGE ENTITLEMENT UNDER THE COLORADO WAGE ACT) 24. Plaintiff hereby incorporates paragraphs 1 through 22 of this Complaint as though fully realleged herein. 25. Plaintiff wasn t paid her final wages or vacation pay upon termination as required by the Colorado Wage Act, C.R.S (et.seq.). C.R.S reads as follows: (1) No employer shall make a deduction from the wages or compensation of an employee except as follows: (c) Any deduction necessary to cover the replacement cost of a shortage due to theft by an employee if a report has been filed with the proper law enforcement agency in connection with such theft pending a final adjudication by a court of competent jurisdiction; except that, if the accused employee is found not guilty in a court action or if criminal charges related to such theft are not filed against the accused employee within ninety days after the filing of the report with the proper law enforcement agency, or such charges are dismissed, the accused employee shall be entitled to recover any amount wrongfully withheld plus interest. In the event an employer acts without good faith, in addition to the amount wrongfully withheld and legally proven to be due, the accused employee may be awarded an amount not to exceed treble the amount wrongfully withheld. In any such action the prevailing party shall be entitled to reasonable costs related to the recovery of such amount including attorney fees and court costs. 26. The Defendants, without good faith legal justification refused to pay Ms. Bell her wages, contacted law enforcement in bad faith, and didn t pay wages, interest and penalties when Ms. Bell was not charged with theft. 27. There is a class of similarly situated employees who suffered the same treatment as the Plaintiff. 7

8 28. Ms. Bell and those similarly situated employees are entitled to wages, interest, treble damages, costs and attorneys fees. SECOND CLAIM FOR RELIEF (FAIR LABOR STANDARDS ACT) 29. Plaintiff hereby incorporates paragraphs 1 through 27 of this Complaint as through fully realleged herein. 30. At the times hereinafter mentioned, Defendants Bradley Petroleum, Inc. and Sav- O-Mat, Inc. were the employer of the Plaintiff within the meaning of 3 (d) of the Fair Labor Standards Act, 29 USC 201, et seq. Act. 31. Plaintiff was an employee of the Defendants within the meaning of 3 (e) of the 32. At all times herein Defendants and Plaintiff were engaged in commerce and Plaintiff was employed by an enterprise engaged in commerce throughout the period of her employment by Defendants. 33. Defendants employed Plaintiff without paying her a minimum wage contrary to the provisions of the Act. 34. Defendants Bradley Petroleum, Inc. and Sav-O-Mat, Inc. willfully violated the Act. Defendants refusal to pay a minimum wage was without good faith or reasonable ground to believe that the Defendants were in compliance with the Act, mandating an award of liquidated damages under the Act. 8

9 35. Plaintiff and those similarly situated are owed minimum wages in an amount to be established at trial. Plaintiff and those similarly situated are also entitled to recover an additional equal amount as liquidated damages under the Act, attorneys fees, interest, costs and such other relief as appropriate and allowed by law. THIRD CLAIM FOR RELIEF (MALICIOUS PROSECUTION) 36. Plaintiff hereby incorporates paragraphs 1 through 34 of this Complaint as through fully realleged herein. The Defendants called the police and attempted to, or had criminal charges brought. 37. A criminal case was brought against the Plaintiff. The criminal case was brought as a result of an oral or written statement made by the Defendants. cause. 38. The criminal case ended in favor of the Plaintiff. 39. The Defendants statements against the Plaintiff were made without probable 40. The Defendants statements against the Plaintiff were motivated by malice towards the Plaintiff. 41. As a result of the criminal case, the Plaintiff had damages. 42. Similarly situated employees have the same claim as the Plaintiff. 9

10 FOURTH CLAIM FOR RELIEF (ABUSE OF PROCESS) 43. Plaintiff hereby incorporates paragraphs 1 through 41 of this Complaint as through fully realleged herein. 44. The Defendants intentionally caused a criminal investigation of the Plaintiff and/or a criminal case to be filed against the Plaintiff. investigated. 45. The principal reason for Defendants action was other than to have a crime 46. This action of the Defendants caused the Plaintiff damages. 47. Similarly situated employees have the same claim as the Plaintiff FIFTH CLAIM FOR RELIEF (CIVIL CONSPIRACY) 48. Plaintiff hereby incorporates paragraphs 1 through 46 of this Complaint as through fully realleged herein. 49. Various members of the Defendants agreed, by words or conduct, to accomplish an unlawful goal or accomplish a goal through unlawful means. 50. One or more unlawful acts were performed to accomplish the goal or acts were performed to accomplish an unlawful goal. 51. The Plaintiff had damages from these acts. 52. The Plaintiff s damages were caused by the acts performed to accomplish the goal. 10

11 SIXTH CLAIM FOR RELIEF (OUTRAGEOUS CONDUCT) 53. Plaintiff hereby incorporates paragraphs 1 through 51 of this Complaint as though fully restated herein. 54. The Defendants engaged in extreme and outrageous conduct by attempting to have Plaintiff charged with a crime. 55. The Defendants engaged in the conduct recklessly or with the intent of causing the Plaintiff severe emotional distress. 56. The Plaintiff incurred severe emotional distress which was caused by the Defendants conduct. SEVENTH CLAIM FOR RELIEF (DEFAMATION) 57. Plaintiff hereby incorporates paragraphs 1 through 53 of this Complaint as though fully restated herein. 58. Defendants published or caused to be published a statement that the Plaintiff was terminated for theft from the Defendants. 59. The statement caused Plaintiff actual damages. 60. The substance or gist of the statement was false at the time it was published. 11

12 EIGHTH CLAIM FOR RELIEF (UNJUST ENRICHMENT) 61. Plaintiff hereby incorporates paragraphs 1 through 57 of this Complaint as though fully realleged herein. said services. 62. Defendants engaged the services of Plaintiff and Plaintiff diligently performed 63. Plaintiff rendered services with the reasonable expectation that she would be paid the reasonable value of such services by the Defendants. 64. Defendants were unjustly enriched in that they had the benefit of Plaintiff s work and reimbursements. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in her favor and against the Defendants, and grant: (a) (b) Declaratory and other injunctive and/or equitable relief; Compensatory damages on all claims allowed by law in an amount to be determined at trial; (c) Actual damages including wages, penalties and interest. 12

13 (d) Punitive damages on all claims allowed by law and in an amount to be determined at trial; (e) Damages for emotional distress, loss of reputation, humiliation, and other pain and suffering; (f) Attorneys fees and the costs of this action, including expert witness fees, on all claims allowed by law; (g) (h) (i) Pre- and post-judgment interest at the lawful rate; penalties and/or liquidated damages; Any further relief that this court deems just and proper, and any other relief as allowed by law. PLAINTIFF REQUESTS A JURY ON ALL MATTERS SO TRIABLE. DATED this 21st day of May, Respectfully submitted, LEE E. CHRISTIAN, P.C. /s/ Lee E. Christian Lee E. Christian, Reg. No Duly Signed Original on File at the Offices of Lee E. Christian, P.C. Plaintiff s Address: 2626 w 1 st St #183 Greeley, CO 80634

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