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 Guy D. Knoller - #002803 

Law Offices of Guy David Knoller, P.L.L.C. 

7321 N. 16th Street 

Phoenix, Arizona 85020 

(602) 254-6044 

E-Mail: guydknoller@gmail.com 

Attorney for Plaintiff 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA

 

JENNIFER SLOCUM, 

 Plaintiff, 

 vs. 

MARC TAYLOR; MARC TAYLOR, 

INC., 

 Defendants. 

No. 

COMPLAINT 

 Plaintiff alleges as follows: 

FIRST CLAIM FOR RELIEF

(Fair Labor Standards Act) 

 1. Plaintiff is a resident of Maricopa County, Arizona. 

 2. Defendant Marc Taylor, Inc. (hereinafter referred to as “MT”) is a 

corporation authorized to do business in Arizona. 

3. Jurisdiction is based upon 29 U.S.C. §216(b), the Fair Labor Standards 

Act (hereinafter referred to as “FLSA”). 

4. Plaintiff worked for Defendant for approximately 1 3/4 years ending 

January 2018. 

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 5. Defendant Marc Taylor is a resident of Maricopa County, and is 

personally liable as an "employer" within the meaning of 29 U.S.C. §203, as he: 

 a. acted directly for and on behalf of Defendant MT; 

 b. had the power and exercised the power to hire and fire; 

 c. supervised workers and controlled the conditions of employment; 

 d. maintained employment records; and, 

 e. is the President, director and owner of Defendant MT. 

6. Plaintiff was not paid overtime, at the rate of one and one-half her hourly 

rate of pay (minimum wage) for all hours worked in excess of 40 each week. 

7. Plaintiff worked approximately 1700 hours of overtime (and possibly 

more) (over 40 hours in one week) during her employment for which she was not paid 

at the rate of time and one-half. 

8. Defendant's conduct was willful: Defendants knew or should have known 

Plaintiff was misclassified and not exempt under the FLSA; and, Defendants failed to 

make adequate inquiry into compliance with the FLSA. 

9. Plaintiff is not exempt from coverage under the FLSA and is entitled to 

overtime at the rate of time and one-half for all hours worked in excess of 40 for each 

week. 

10. Plaintiff is entitled to liquidated damages: double the amount due pursuant 

to 29 U.S.C. §216(b). 

11. Plaintiff is entitled to attorneys’ fees and costs pursuant to 29 U.S.C. 

§216(b). 

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12. Defendant also violated the record keeping requirements of the FLSA. 

WHEREFORE Plaintiff requests judgment against Defendant for: 

1. Damages for overtime pay with interest; 

2. For liquidated damages; 

3. For reasonable attorneys fees, which are mandatory, and costs incurred 

herein; and, 

4. Such other relief that this Court deems appropriate. 

 SECOND CLAIM FOR RELIEF 

 (Discharge in Retaliation of Making a FLSA Demand) 

 

1. The preceding allegations of the Complaint are incorporated by reference 

herein. 

 2. Plaintiff demanded payment for overtime hours worked, but was not paid. 

 3. In retaliation Defendants terminated Plaintiff stating that she was not a 

good fit after giving her a raise and two bonuses during her employment. 

 4. Plaintiff has been damaged by Defendants’ retaliatory termination of her. 

 5. Defendants’ termination was in violation of the anti-retaliation provisions 

of the FLSA. 

WHEREFORE Plaintiff requests: 

1. Damages in an amount to be proven at trial, together with interest thereon 

for lost wages and benefits and future lost wages and benefits; 

2. For reasonable attorneys fees and costs; and, 

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3. For such other relief as this Court deems appropriate. 

 

 DATED this 2nd day of February 2018.

 /s/ Guy D. Knoller 

 Guy D. Knoller 

 Attorney for Plaintiff 

 I hereby certify that on February 2, 2018, I electronically transmitted the attached 

document to the Clerk's Office using the CM/ECF System for filing and transmittal of a 

Notice of Electronic Filing. 

 /s/ Debbie A. Wallen 

 Debbie A. Wallen 

 

 

 

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