COMPLAINT FOR VIOLATIONS OF THE FLSA Page 1 of 10

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JANET M. HEROLD

Regional Solicitor

DANIEL J. CHASEK

Associate Regional Solicitor

NANCY E. STEFFAN (CSBN 280958) Trial Attorney 

Office of the Solicitor

United States Department of Labor

350 S. Figueroa St., Suite 370

Los Angeles, California 90071-1202

Telephone: (213) 894-5366

Steffan.Nancy.E@dol.gov

Attorneys for Plaintiff Secretary of Labor

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Thomas E. Perez,

 Secretary of Labor,

 United States Department of Labor,

 Plaintiff,

 v.

Family Support Resources, Inc., an Arizona corporation; Larry Douglas, an individual; Alta Douglas, an individual.

 Defendants.

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Case No. _______________

COMPLAINT

Plaintiff, THOMAS E. PEREZ, Secretary of Labor, United States 

Department of Labor (“Plaintiff” or the “Secretary”), brings this action to 

enjoin defendants FAMILY SUPPORT RESOURCES, INC., LARRY 

DOUGLAS, and ALTA DOUGLAS from violating the provisions of Sections 6, 7, and 15 of the Fair Labor Standards Act of 1938, as amended (29 

U.S.C. §§ 201, et seq.) (hereinafter called “FLSA” or the “Act”), pursuant 

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COMPLAINT FOR VIOLATIONS OF THE FLSA Page 2 of 10

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to Section 17 of the Act; and to recover unpaid compensation owing to Defendants’ employees, pursuant to Section 16(c) of the Act.

I

Jurisdiction of this action is conferred upon the Court by Sections 

16(c) and 17 of the Act and 28 U.S.C. § 1345.

II

a. Defendant FAMILY SUPPORT RESOURCES, INC., a corporation 

(“Defendant Company”), is and at all times hereinafter mentioned 

was a corporation with an office and a place of business located at 

6019 W. Sunnyside Dr., Glendale, AZ 85304, within the jurisdiction 

of this Court, and is, and at all times hereinafter mentioned, was engaged in providing residential housing for children who are in the 

State of Arizona foster care system.

b. Defendant LARRY DOUGLAS, an individual, resides within the jurisdiction of this Court, and at all times hereinafter mentioned acted 

directly or indirectly in the interest of Defendant Company in relation 

to its employees.

c. Defendant ALTA DOUGLAS, an individual and spouse of Defendant LARRY DOUGLAS, resides within the jurisdiction of this Court, 

and at all times hereinafter mentioned acted directly or indirectly in 

the interest of Defendant Company in relation to its employees.

III

Defendant FAMILY SUPPORT RESOURCES, INC., is and at all 

times hereinafter mentioned was engaged in related activities performed 

through unified operation or common control for a common business purpose, and is and at all times hereinafter mentioned was an enterprise within 

the meaning of Section 3(r) of the Act.

IV

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Defendant FAMILY SUPPORT RESOURCES, INC., at all times 

hereinafter mentioned was an enterprise engaged in commerce or in the 

production of goods for commerce within the meaning of Sections 

3(s)(1)(A) the Act in that said enterprise at all times hereinafter mentioned 

had employees engaged in commerce or in the production of goods for 

commerce, or employees handling, selling, or otherwise working on goods 

or materials that have been moved in or produced for commerce by any person and in that said enterprise has and has had an annual gross volume of 

sales made or business done of not less than $500,000.00.

V

Defendants FAMILY SUPPORT RESOURCES, INC., LARRY 

DOUGLAS, and ALTA DOUGLAS violated the provisions of Sections 6 

and 15(a)(2) of the FLSA, 29 U.S.C. §§ 206 and 215(a)(2), respectively, by 

employing employees engaged in commerce or in the production of goods 

for commerce, or who were employed in an enterprise engaged in commerce or in the production of goods for commerce, within the meaning of 

the FLSA, at wage rates less than the applicable federal minimum wage, 

which was $7.25 an hour during the investigative period of January 18, 

2012 through and including January 17, 2014 (“Subject Period”).

VI

Defendants FAMILY SUPPORT RESOURCES, INC., LARRY 

DOUGLAS, and ALTA DOUGLAS violated the provisions of Sections 7 

and 15(a)(2) of the FLSA, 29 U.S.C. §§ 207 and 215(a)(2), respectively, by 

employing employees who in workweeks were engaged in commerce or in 

the production of goods for commerce, or who were employed in an enterprise engaged in commerce or in the production of goods for commerce, 

within the meaning of the FLSA, for workweeks longer than forty hours 

without compensating said employees for their employment in excess of 

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forty hours per week during such workweeks at rates not less than one and 

one-half times the regular rate at which they were employed.

VII

Defendants FAMILY SUPPORT RESOURCES, INC., LARRY 

DOUGLAS, and ALTA DOUGLAS violated the provisions of Sections 

11(c) and 15(a)(5) of the FLSA, 29 U.S.C. §§ 211(c) and 215(a)(5), by failing to maintain, keep, make available (to authorized agents of Plaintiff for 

inspection, transcription, and/or copying), and preserve records of employees and of the wages, hours, and other conditions and practices of employment maintained, as prescribed by the regulations promulgated by Plaintiff 

pursuant to the authority granted in the FLSA, published at 29 C.F.R. § 

516.1.

VII

During the Subject Period, Defendants FAMILY SUPPORT 

RESOURCES, INC., LARRY DOUGLAS, and ALTA DOUGLAS violated 

the above-described provisions of the FLSA.

Judgment permanently enjoining and restraining such violations of 

the FLSA is specifically authorized by Section 17 of the FLSA, 29 U.S.C. 

§ 217.

WHEREFORE, cause having been shown, the Secretary prays for a 

judgment against Defendants as follows:

a. For an Order pursuant to Section 17 of the Act, permanently enjoining and restraining Defendants FAMILY SUPPORT RESOURCES, 

INC., LARRY DOUGLAS, and ALTA DOUGLAS, their officers, 

agents, servants, employees, and those persons in active concert or 

participation with them from prospectively violating the aforementioned provisions of Section 15 of the Act; and 

b. For an Order:

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i. pursuant to Section 16(c) of the Act finding Defendants liable 

for unpaid minimum wage and overtime compensation due Defendants’ employees and for liquidated damages equal in 

amount to the unpaid compensation found due Defendants’ 

employees listed in the attached Exhibit A (additional back 

wages and liquidated damages may be owed to certain employees presently unknown to the Secretary for the period covered by this Complaint) and that such unpaid minimum wage 

and overtime compensation and liquidated damages be paid 

from: a) the assets of Defendant FAMILY SUPPORT 

RESOURCES, INC.; b) the separate property of Defendant

LARRY DOUGLAS; and/or c) the separate property of Defendant and ALTA DOUGLAS; or in the event liquidated 

damages are not awarded;

ii. pursuant to Section 17 of the Act enjoining and restraining Defendants, their officers, agents, servants, employees and those 

persons in active concert or participation with Defendants, 

from withholding payment of unpaid back wages found to be 

due Defendants’ employees and pre-judgment interest computed at the underpayment rate established by the Secretary of 

Treasury pursuant to 26 U.S.C. § 6621 and that such withholding of payments be enjoined and restrained from: a) the assets 

of Defendant FAMILY SUPPORT RESOURCES, INC.; b) the 

separate property of Defendant LARRY DOUGLAS; and/or c) 

the separate property of Defendant and ALTA DOUGLAS;

c. For an Order awarding the Secretary the costs of this action; and 

d. For an Order granting such other and further relief as the Court 

deems to be necessary or appropriate.

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Dated: September 24, 2015 M. PATRICIA SMITH

Solicitor of Labor

JANET M. HEROLD

Regional Solicitor

DANIEL J. CHASEK

Associate Regional Solicitor

/s/ Nancy E. Steffan .

NANCY E. STEFFAN

Trial Attorney

 UNITED STATES

DEPARTMENT OF LABOR

Attorneys for Plaintiff

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EXHIBIT A TO COMPLAINT

Employee Names

Thaddeus Allie

Reginals Armstead

Vanessa Armstrong

Rebecca Baer

Amy Barkhaus

AnnieBeld

Elvena Benford

Cholanda Black

Amanda Breen

Brandi Brisker

Tyra Brooks

Theda Brothers

Jeannie Burlingame

Melissa Carter

Andrea Cashion

Gail Casson

Desiree Chiarini

Nicole Clay

Wynette Cleaver

Steven Cooper

Grace Cota

Robert Culver

La Tonya Davis

Margarita De St Aubin

ShallaDeatherage

Timothy Dupree

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Varetta Ensley

Angela Figueroa

Regina Fletcher

Tammy Gant

Amber Hampson

Ebony Harris

Andrea Hughes

OliviaIbanez

Shahidah Jabaar

Samantha Jackson

Joan Jefferies

Ileen Jimenez

Auvea Jimison

Gail Johnson

Veronica Johnson

Leanna Jones

Sammie Jones

Brittany Lewis

Avis Lopez

DebraLopez

StevieLopez-Wilkirson

Sarahi Luna

Cynthia Magallanes

Cherrelle Malloy

Jeff Maloney

Monica Manjarrez

Michelle Mann

Marquita Marshall

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Raeneisha McAfee

Kimberly McCray

Angela Means

Charidy Miles

Nicole Miller

Frank Moore

Norlanda Mosley

Askia Muhammad

Breeanna Muhlenkamp

Caitlin Nagle

Nyisha Neal

Art Owens

Phoenix Pacheco

Guyton Penns

Latrice Perryman

Melissa Potter

Mandy Quesada

Patricia Redd

Tammy Reed

Kenya Reid

Juanita Reiland

ShallaRobinson

Jymie Rose

Erin Royal

Melissa Rydwell

Kristopher Seydel

Alyssa Shaffer

Robert Stanford

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Annalisa Stevens

OnekiThomas

Sharon Thompson

Sammie Trotter

Yvonne Voorhees

Georgia Walker

Wanda Watkins

Stephanie Watson

Samantha Webster

Christine Wessel

Margo Wilson

Fabian Wiltz

LaDarrell Wimbley

Amy Woods

Isabel Zamarripa

Mariela Zavala-Renteria

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