MARYELLEN O'SHAUGHNESSY 

CLERK OF THE FRANKLIN COUNTY COMMON PLEAS COURT, COLUMBUS, OHIO 43215 

CIVIL DIVISION 

ROBERT MURRAY, 

PLAINTIFF, 

vs. 

EASE LOGISTICS SERVICES LLC 

ET. AL., 

DEFENDANT. 

-

lBCV-03-2022 

CASE NUMBER 

- CLERK'S ORIGINAL CASE SCHEDULE 

CASE FILED 

INITIAL STATUS CONFERENCE 

INITIAL JOINT DISCLOSURE OF ALL WITNESSES 

SUPPLEMENTAL JOINT DISCLOSURE OF ALL WITNESSES 

DISPOSITIVE MOTIONS 

DISCOVERY CUT-OFF 

DECISIONS ON MOTIONS 

FINAL PRE-TRIAL CONFERENCE/ORDER (OR BOTH) 

TRIAL ASSIGNMENT 

NOTICE TO ALL PARTIES 

JUDGE J. LYNCH 

LATEST TIME 

OF OCCURRENCE 

03/07/18 

******** 

. 07/25/18 

09/19/18 

12/12/18 

12/26/18 

02/06/19 

02/20/19 0900AM 

03/13/19 0900AM 

ALL ATTORNEYS AND PARTIES SHOULD MAKE THEMSELVES FAMILIAR WITH THE 

COURT'S LOCAL RULES, INCLUDING THOSE REFERRED TO IN THIS CASE SCHEDULE. 

IN ORDER TO COMPLY WITH THE CLERK'S CASE SCHEDULE, IT WILL BE NECESSARY 

FOR ATTORNEYS AND PARTIES TO PURSUE THEIR CASES VIGOROUSLY FROM THE DAY 

THE CASES ARE FILED. DISCOVERY MUST BE UNDERTAKEN PROMPTLY IN ORDER TO 

COMPLY WITH THE 1.DATES LISTED IN THE RIGHT-HAND COLUMN. 

_/_/_ 

DATE 

BY ORDER OF THE COURT OF COMMON PLEAS, 

FRANKLIN COUNTY, OHIO 

MARYELLEN O'SHAUGHNESSY, CLERK 

(CIV363-Sl0) 

EXHIBIT A Case: 2:18-cv-00273-ALM-CMV Doc #: 1-3 Filed: 03/29/18 Page: 1 of 14 PAGEID #: 7
Case: 2:18-cv-00273-ALM-CMV Doc #: 1-3 Filed: 03/29/18 Page: 2 of 14 PAGEID #: 8
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Mar 07 4:39 PM-18CV002022 

OE048 - Yl 

MARYELLEN O'SHAUGHNESSY 

FRANKLIN COUNTY CLERK OF COURTS 

GENERAL DIVISION, COURT OF COMMON PLEAS 

CASE TITLE: ROBERT MURRAY -VS- EASE LOGISTICS SERVICES LLC CASE NUMBER: 18CV002022 

ETAL 

TO THE CLERK OF COURTS, YOU ARE INSTRUCTED TO MAKE: 

CERTIFIED MAIL 

DOCUMENTS TO BE SERVED: 

COMPLAINT 

CASE INFORMATION SHEET 

PROPOSED DOCUMENTS TO BE SERVED: 

UPON: 

PETER CORATOLA, JR 

6100 AVERY RD 

DUBLIN, OH 43016 

EASE LOGISTICS SERVICES LLC 

6100 AVERY RD 

DUBLIN, OH 43016 

JUVENILE CITATIONS ONLY: 

HEARING TYPE: 

Date already scheduled at Courtroom: 

Electronically Requested by: SHARON CASON-ADAMS 

Attorney for: 

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THIS PAGE INTENTIONALL V LEFT BLANK 

Case: 2:18-cv-00273-ALM-CMV Doc #: 1-3 Filed: 03/29/18 Page: 4 of 14 PAGEID #: 10
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Mar 07 4:39 PM-18CV002022 

OE048 - X87 

IN THE COURT OF COMMON PLEAS 

FRANKLIN COUNTY, OHIO 

Robert Murray 

8785 Hubbard Dr. North 

Galloway, Ohio 43119 

Plaintiff, 

V. 

Ease Logistics Services LLC 

6100 Avery Rd. 

Dublin, Ohio 43016 

And 

Peter Coratola, Jr. 

6100 Avery Rd. 

Dublin, Ohio 43016 

Defendant. 

Case No. 

Judge: 

Magistrate: 

COMPLAINT WITH JURY 

DEMAND ENDORSED HEREIN 

This is an action for damages for retaliation (wrongful discharge) in violation of the Fair 

Labor Standards Act 29 USCS §215(a) and for breach of contract arising under Ohio law. 

PARTIES: 

1. Plaintiff Robert Murray (hereinafter "Plaintiff') is an individual and a resident of 

Franklin County, Ohio. 

2. Defendant Ease Logistics Service LLC (hereinafter "Ease Logistics") is a domestic 

limited liability company with offices located in Franklin County, Ohio. 

3. Defendant Peter Coratola, Jr. (hereinafter "Coratola") is the owner and statutory agent of 

Defendant Ease Logistics. 

4. Plaintiff was an employee as that term is defined by the FLSA and Defendants are 

employers as that term is defined by the FLSA. 

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5. Defendants Ease Logistics and Coratola are an enterprise engaged in commerce as those 

terms are defined by 29 USCS §203. 

JURISDICTION AND VENUE 

6. This Court has jurisdiction over Plaintiffs' FLSA claims pursuant to 29 U. S.C. §216(b ). 

7. This Court has subject matter jurisdiction over Plaintiffs' state law claim. 

8. Venue is proper because the events giving rise to this Complaint occurred in Franklin 

County, Ohio. 

BACKGROUND FACTS. 

9. Plaintiff was hired by Defendant on January 4, 2016 to perform the duties of Logistics 

Coordinator. 

10. His duties included, but were not limited to, dispatching, tracking loads, and dealing with 

damaged loads. 

11. In or around June 2016 his duties were expanded to include delivering loads and 

maintaining the company straight truck. 

12. Plaintiff accepted these additional duties because Defendant promised that he would 

receive $15 .00 per hour for driving during regular business hours and $20.00 per hour 

when he was required to work after 6:00 p.m. 

13 . Plaintiff normally worked 8-15 hours per day and routinely worked more than forty (40) 

hours per week. 

14. He turned in his hours on a weekly basis. 

15. Defendants issued paychecks two times per month. 

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16. Unfortunately, Plaintiffs compensation was never changed to reflect the promised pay 

mcrease. 

17. On January 2, 2017 Plaintiff overslept. 

18. He was awakened by an angry telephone call made by Coratola. 

19. Coratola informed him to stay home for the day and that he was banned from overtime as 

punishment for oversleeping. 

20. Plaintiff returned to work the next day without incident and thereafter worked his normal 

schedule, including the overtime required to complete his duties. 

21. On January 12, 2017 he received his paycheck stub. 

22. His pay record indicated that he had only worked 80 hours and his pay reflected no 

overtime even though he had worked more than 80 hours. 

23 . He contacted Justin Young regarding this discrepancy. 

24. Mr. Young informed Plaintiff that Young was instructed not to pay him overtime and 

stated that he believed Plaintiff was informed of this matter. 

25. Plaintiff expressed surprise that he would not be compensated for his overtime. 

26. Soon after his communication with Mr. Young about the situation, Coratola called 

Plaintiff into his office and launched into a tirade. 

27. Coratola asked, "Where the fl'* * do you get off? I told you no overtime" and "Why 

would I reward you with overtime for being late? What's the f'l'**ing issue?" 

28. Plaintiff stated that he was not working for free . 

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29. He also defended himself by pointing out that he often reported to work early in the 

morning and stayed later than every other employee. 

30. Coratola fired Plaintiff on the spot. 

31 . After his termination, Plaintiff received a paycheck reflecting 3 hours of overtime (less 

than what he actually worked.) This was not the first time that Plaintiff was paid for less 

overtime than he actually worked. 

COUNTI 

RETALIATION IN VIOLATION 

OF THE FAIR LABOR STANDARDS ACT 29 uses §215(a)(3) 

32. Plaintiff restates and incorporates the allegations in the foregoing paragraphs as if fully 

rewritten herein. 

33 . The FLSA prohibits employers from discharging employees because the employee has 

made any complaint to the employer that the employee has not been paid wages (or 

overtime) in accordance with the law. 

34. Defendant was aware that Plaintiff routinely worked overtime in order to fulfill the duties 

of his position. 

35 . Plaintiff worked overtime during the pay period covered by the check he received on 

January 12, 201 7. 

36. Defendant knew Plaintiff was working overtime during this period and allowed him to do 

so. 

37. When Plaintiff complained about not receiving overtime pay for hour worked in excess of 

forty hours per week he was engaged in protected activity as contemplated by the FLSA. 

38. Defendants responded to Plaintiffs complaint by terminating him. 

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39. But for Plaintiffs complaint about not being paid for his overtime, he would not have been 

terminated. 

40. Terminating Plaintiff under these circumstances is a violation of the FLSA and Plaintiff 

has been damaged thereby. 

41. Plaintiff is entitled to damages including back pay, front pay, compensatory damages, 

liquidated damages, and attorney's fees. 

COUNT II 

BREACH OF CONTRACT 

42. Plaintiff restates and incorporates the allegations in the foregoing paragraphs as if fully 

rewritten herein. 

43 . In June 2016, Plaintiff agreed to accept additional duties in exchange for a pay increase. 

44. Defendants promised to pay Plaintiff $15 .00 per hour for driving during regular business 

hours and $20.00 per hour when he was required to work after 6:00 p.m. 

45 . After June 2016, Plaintiff frequently worked past 6:00 p.m. and delivered product after 

6:00 p.m. 

46. Plaintiff questioned Operations Manager Larry Basford about why he had not been paid 

according to this arrangement. 

4 7. Mr. Basford was aware of the agreement and was aware that Plaintiff often worked 

overtime. 

48. Mr. Basford stated that there would be no overtime if Plaintiff were paid $20/per hour. 

49. Plaintiff was never paid the agreed upon rate. 

50. Defendants breached their agreement with Plaintiff and he has been damaged thereby. 

WHEREFORE, Plaintiff respectfully prays that this Court grant him damages in excess of 

$25,000, including: 

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a. lost past and future wages and benefits; 

b. compensatory damages; 

c. liquidated damages pursuant to the FLSA; 

d. attorney fees and costs; 

e. prejudgment and post judgment interest; 

f. such other equitable and further relief as may be just and appropriate 

Respectfully Submitted, 

ls/Sharon Cason-Adams 

SHARON CASON-ADAMS (0067550) 

Adams & Liming, LLC 

1335 Dublin Rd. Suite 104D 

Columbus, Ohio 43215 

Telephone: 614-488-2559 

Fax No: 614-488-2069 

Attorney for Plaintiff 

JURY DEMAND 

Plaintiff hereby demands trial by jury on all issues triable before a jury. 

ls/Sharon Cason-Adams 

SHARON CASON-ADAMS (0067550) 

Case: 2:18-cv-00273-ALM-CMV Doc #: 1-3 Filed: 03/29/18 Page: 10 of 14 PAGEID #: 16
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Mar 07 4:39 PM-18CV002022 

OE048 - X93 

In the Court of Common Pleas, Franklin County, Ohio, General Division 

Robert Murray 

Plaintiff/ Appellant, 

vs. Case No. 

--- -----------

Ease Logistics Services LLC, et al 

Defendant/ Appel lee, 

Civil Case Filing Information Summary 

Type of Action/Case Classification: 

Professional Tort (Type A) 

($225.00 Security Deposit Required) 

Product Liability (Type B) 

($225.00 Security Deposit Required) 

Other Torts (Type C) 

($225.00 Security Deposit Required) 

Workers Compensation (Type D) 

($22S.00 Security Deposit Required) 

Foreclosure (Type E) 

($350.00 Security Deposit Required) 

Administrative Appeal (Type F) 

($ 100.00 Security Deposit Required) 

✓ All Other Civil Cases (Type H) 

($225.00 Security Deposit Required) 

Cognovit Confession of Judgment (H) 

($1 00.00 Security Deposit Required) 

JURY DEMAND? Yes Total Security Deposit$ ______ _ ($300.00 Additional Security Deposit Required ) (Yes or No) 

ls a TEMPORARY RESTRAINING ORDER being requested at this time? __ 

No 

Is this a case in which ALL the issues presented are a result of the 

defendant(s) having signed and defaulted on a COGNOVIT NOTE? 

ls th is a FORCIBLE ENTRY AND DETAINER case? 

Does this case include allegations of CONSUMER SALES PRACTICES 

ACT violations under Chapter 1345 or any other statutory consumer 

protection provision of the Ohio Revised Code? 

Refiling Information: 

(Yes or No) 

No 

(Yes or No) 

No 

(Yes or No). 

No 

(Yes or No) 

Jf this is a REFILING of a previously dismissed case, please complete the following : 

Original Judge ______ ____ _ 

0067550 

Attorney Ohio Sup. Ct. Registrati on No. 

Sharon Cason-Adams 614-488-2559 

Attorney/Party Name (Type or Print) Telephone Number 

l 335 Dublin Rd Ste l 04D 614-488-2069 

Mailing Address Facsimile Number 

Columbus OH 43215 

City State Zip Code 

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Case: 2:18-cv-00273-ALM-CMV Doc #: 1-3 Filed: 03/29/18 Page: 12 of 14 PAGEID #: 18
MARYELLEN O'SHAUGHNESSY 

CLERK OF THE FRANKLIN COUNTY COMMON PLEAS COURT, COLUMBUS, OHIO 43215 

CIVIL DIVISION 

- ROBERT MURRAY 

8785 HUBBARD DR NORTH 

GALLOWAY, OH 43119, 

PLAINTIFF, 

vs. 

EASE LOGISTICS SERVICES LLC 

6100 AVERY RD 

DUBLIN, OH 43016, 

DEFENDANT. 

-

18CV-03-2022 

CASE NUMBER 

 SUMMONS** ** 

TO THE FOLLOWING NAMED DEFENDANT: 

EASE LOGISTICS SERVICES LLC 

6100 AVERY RD 

DUBLIN, OH 43016 

03/07/18 

YOU HAVE BEEN NAMED DEFENDANT IN A COMPLAINT FILED IN FRANKLIN COUNTY 

COURT OF COMMON PLEAS, FRANKLIN COUNTY HALL OF JUSTICE, COLUMBUS, OHIO, 

BY: ROBERT MURRAY 

8785 HUBBARD DR NORTH 

GALLOWAY, OH 43119, 

PLAINTIFF (S). 

A COPY OF THE COMPLAINT IS ATTACHED HERETO. THE NAME AND ADDRESS OF 

THE PLAINTIFF'S ATTORNEY IS: 

SHARON CASON-ADAMS 

ADAMS & LIMING LLC 

SUITE 104D 

1335 DUBLIN ROAD 

COLUMBUS, OH 43215 

YOU ARE HEREBY SUMMONED AND REQUIRED TO SERVE UPON THE PLAINTIFF'S 

ATTORNEY, OR UPON THE PLAINTIFF, IF HE HAS NO ATTORNEY OF RECORD; A COPY 

OF AN ANSWER TO THE COMPLAINT WITHIN TWENTY-EIGHT DAYS AFTER THE SERVICE 

OF THIS SUMMONS ON YOU, EXCLUSIVE OF THE DAY OF SERVICE. YOUR ANSWER 

MUST .BE. FILED WITH THE COURT WITHIN THREE DAYS AFTER THE SERVICE OF A 

COPY OF THE ANSWER ON THE PLAINTIFF'S ATTORNEY. 

IF YOU FAIL TO APPEAR AND DEFEND, JUDGMENT BY DEFAULT WILL BE RENDERED 

AGAINST YOU FOR THE RELIEF DEMANDED IN THE COMPLAINT. 

MARYELLEN O'SHAUGHNESSY 

CLERK OF THE COMMON PLEAS 

FRANKLIN COUNTY, OHIO 

RV• Mll.RTll. ."T Rl<'T Zill' nl<'PTT'T'V rT .l<'Rll' 

(CIV370-S03) 

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