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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

CASE NO.: 1:20-cv-440

PAUL SLATTER,

Plaintiff,

vs.

CHESAPEAKE ENERGY CORPORATION,

CHESAPEAKE OPERATING, LLC.,

TRIPLE BS CONSULTING, LLC.,

AFS PETROLOGIX, LLC.

Defendants.

______________________________________________/

COMPLAINT

{Jury Trial Demanded}

Plaintiff, PAUL SLATTER (“PLAINTIFF”), through counsel, sues 

Defendants, CHESAPEAKE ENERGY CORPORATION, CHESAPEAKE 

OPERATING, LLC., TRIPLE BS CONSULTING, LLC., and AFS PETROLOGIX, 

LLC. (Collectively “DEFENDANTS”) and alleges the following:

1. This is an action for damages within the jurisdiction of this court

wherein Plaintiff alleges that Defendants violated the Fair Labor 

Standards Act (FLSA), which requires employers to compensate nonexempt employees for their overtime work. See, 29 U.S.C. § 207(a).

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2. At all times material hereto, Plaintiff was an FLSA non-exempt hourly 

worker (i.e. a “safety advisor”) who has been not paid and/or denied 

overtime pay required by law, for which he now seeks recovery.

3. Plaintiff resides in this court’s venue and is a past employee of 

Defendants.

4. At all times material hereto, Defendant, CHESAPEAKE ENERGY 

CORPORATION was a foreign (“Oklahoma”) corporation engaged in 

the business of discovering and developing of oil and natural gas assets

and in gas gathering and compression, waslicensed to transact business 

in the State of Texas, conducted business in this court’s venue, was an 

“employer” of the Plaintiff within the meaning of 29 U.S.C. §203(d)

and at all times material hereto, engaged along with its employees in 

interstate commerce, and had annual gross sales and/or business 

volume of $500,000 or more.

5. At all times material hereto, Defendant, CHESAPEAKE 

OPERATING, LLC. was a foreign (“Oklahoma”) limited liability 

company engaged in the business of discovering and developing of oil 

and natural gas assets and in gas gathering and compression, was 

licensed to transact business in the State of Texas, conducted business 

in this court’s venue, was an “employer” of the Plaintiff within the 

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meaning of 29 U.S.C. §203(d) and at all times material hereto, engaged 

along with its employees in interstate commerce, and had annual gross 

sales and/or business volume of $500,000 or more.

6. At all times material hereto, Defendant, TRIPLE BS CONSULTING, 

LLC., was a foreign (“Louisiana”) limited liability company engaged 

in the staffing of employees to the oil industry, conducted business in 

this court’s venue, was an “employer” of the Plaintiff within the 

meaning of 29 U.S.C. §203(d) and at all times material hereto, engaged 

along with its employees in interstate commerce, and had annual gross 

sales and/or business volume of $500,000 or more.

7. At all times material hereto, Defendant, AFS PETROLOGIX, LLC,

was a foreign (“Louisiana”) limited liability company engaged in the 

staffing of employees to the oil industry, conducted business in this 

court’s venue, was an “employer” of the Plaintiff within the meaning 

of 29 U.S.C. §203(d) and at all times material hereto, engaged along 

with its employees in interstate commerce, and had annual gross sales 

and/or business volume of $500,000 or more.

8. At all times material hereto, from about April 24, 2017 to November 3, 

2017) Defendant, TRIPLE BS CONSULTING, LLC. hired and placed 

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Plaintiff as a “Safety Consultant” with Defendants, CHESAPEAKE 

ENERGY CORPORATION and CHESAPEAKE OPERATING, LLC.

9. At all times material hereto, from about November 4, 2017 to April 16, 

2020) Defendant, TRIPLE BS CONSULTING, LLC. hired and placed

Plaintiff as a “Safety Consultant” with Defendants, CHESAPEAKE 

ENERGY CORPORATION and CHESAPEAKE OPERATING, LLC.

10. At all times material hereto, both Defendants CHESAPEAKE 

ENERGY CORPORATION and CHESAPEAKE OPERATING, LLC.

jointly controlled Plaintiff’s employment thereby qualifying them as 

joint employers as more fully defined by 29 C.F.R. 791.2(a).

11. In justifiable reliance upon Defendants’ collective representations and 

promises of payment, Plaintiff accepted employment and worked for 

Defendants.

12. During the subject time period, Defendants failed to pay Plaintiff the 

required overtime as mandated by the FLSA.

13. Plaintiff has complied with all conditions precedent to bringing this 

suit, or same have been waived or abandoned.

14. Plaintiff has retained the services of the undersigned and is obligated to 

pay for the legal services provided.

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COUNT I

VIOLATION OF FAIR LABOR STANDARDS ACT (“FLSA”)

(ALL DEFENDANTS)

15. Plaintiff reavers and realleges paragraphs 1-14 herein.

16. Plaintiff alleges this action pursuant to the Fair Labor Standards Act 

("FLSA"), 29 U.S.C. §§ 216 (b), that Plaintiff is entitled to: (i) time 

and-a-half overtime pay, and (ii) liquidated damages pursuant to the 

Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq. 

17. Plaintiff seeks recovery of damages as referenced above and further 

seeks costs, and attorney’s fees pursuant to 29 U.S.C. § 216(b).

WHEREFORE, Plaintiff demands judgment against the Defendants, jointly 

and severally, plus costs, reasonable attorney’s fees, and such other remedy as the 

court deems just and appropriate.

Respectfully submitted,

Law Offices of Goldberg & Loren, P.A.

1776 N. Pine Island Rd.

Suite 224

Plantation, FL 33322

Phone: (954) 585-4878

Facsimile: (954) 585-4886

E-Mail: JLoren@goldbergloren.com

________________________

James M Loren, Esquire

Fla Bar No.: 0055409

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