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James X. Bormes (pro hac vice)

Catherine P. Sons (pro hac vice)

LAW OFFICE OF JAMES X. BORMES, P.C.

Illinois State Bar No. 620268

8 South Michigan Avenue

Suite 2600

Chicago, Illinois 60603

(312) 201-0575

jxbormes@bormeslaw.com

cpsons@bormeslaw.com

LEAD ATTORNEY IN CHARGE FOR 

PLAINTIFF AND CLASS MEMBERS

Thomas M. Ryan (pro hac vice)

LAW OFFICE OF THOMAS M. RYAN, P.C.

Illinois State Bar No. 6273422

35 East Wacker Drive

Suite 650

Chicago, Illinois 60601

(312) 726-3400

tom@tomryanlaw.com

Attorney for Plaintiff 

LOCAL COUNSEL:

Michelle R. Matheson #019568

MATHESON & MATHESON, P.L.C.

15300 North 90th Street

Suite 550

Scottsdale, Arizona 85260

(480) 889-8951

mmatheson@mathesonlegal.com

Attorney for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

WHITNEY WHITMORE, individually and

on behalf of all others similarly situated,

Plaintiff,

v.

REMEDY TEMPORARY SERVICES, INC.

and MCKESSON CORPORATION,

Defendants.

Case No.: 15 cv 2161 SRB

FIRST AMENDED COLLECTIVE 

ACTION COMPLAINT

(JURY TRIAL REQUESTED)

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Plaintiff, Whitney Whitmore, individually and on behalf of all other persons similarly 

situated, known and unknown, through her attorneys, for her First Amended Complaint against 

Defendants Remedy Temporary Services, Inc. and McKesson Corporation (collectively, 

“Defendants”), states as follows:

NATURE OF PLAINTIFF’S CLAIMS 

1. This lawsuit arises under the Fair Labor Standards Act, 29 U.S.C. § 201 et seq. 

(“FLSA”), for Defendants’ failure to pay Plaintiff and other similarly situated persons all overtime 

pay for all time worked in excess of forty (40) hours per week.

2. Defendants employ the telephone-based workers who are the putative class 

members in this lawsuit.

3. Defendants knowingly required and/or permitted Plaintiff, who worked as a 

telephone-dedicated employee in the position of Customer Service Representative and other 

similarly situated telephone-dedicated employees to perform unpaid work before and after the 

start and end times of their shifts, including but not limited to booting up computers, initializing 

several software programs, reading company issued emails and instructions, and completing 

customer service calls.

4. In addition, Defendants were aware that Plaintiff and those similarly situated to her 

also performed work for Defendants on their break periods, including meal breaks, for which they 

were not paid. The work that Plaintiff and similarly situated employees performed during break 

periods includes, but is not limited to, completing customer orders, finishing customer service 

calls, logging back into the phone system, re-booting their computers and initializing software 

programs. 

5. The amount of uncompensated time Plaintiff and those similarly situated to her 

spend or have spent on these required and unpaid work activities averages approximately fifteen 

to twenty minutes per day per person.

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6. Defendants’ conduct violates the FLSA, which requires non-exempt employees to 

be compensated for their overtime work at a rate of one and one-half times their regular rate of 

pay. See 29 U.S.C. § 207(a).

7. Plaintiff brings her FLSA overtime claims as a collective action pursuant to 29 U.S.C. 

§ 216(b) on behalf of telephone-dedicated employees who worked for Defendants throughout the 

country at call centers owned by McKesson Corporation (“McKesson”).

JURISDICTION AND VENUE

8. This Court has original jurisdiction over Plaintiff’s FLSA claims in this action 

under 29 U.S.C. § 1331 and 29 U.S.C. § 216(b).

9. Venue is proper in this Court as the illegal conduct alleged herein occurred in this 

district. 

THE PARTIES

10. Plaintiff Whitney Whitmore is an individual who Defendants employed from 

approximately April of 2015 to the present as an hourly, non-exempt Customer Service 

Representative who was placed to work in a call center operated by McKesson Corporation 

located at 4345 North Scottsdale Road in Scottsdale Arizona. Plaintiff Whitmore resides in and 

is domiciled within this judicial district.

11. Defendant McKesson is the largest pharmaceutical distributor in North America. 

McKesson operates telephone call centers on North Scottsdale Road and on Raintree Road in

Scottsdale, Arizona and, upon information and belief, elsewhere, where telephone-dedicated 

hourly employees handle phone calls regarding medicines, medical supplies and health care 

information. McKesson directly employs some Customer Service Representatives at its call 

centers. This lawsuit does not involve those employees because, upon information and belief, 

McKesson’ properly records and pays for all time those employees work. This lawsuit involves 

Customer Services Representatives who are placed at McKesson’s call centers via Remedy and its 

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staffing services and are not direct employees of McKesson. McKesson may be served at 2338 

W. Royal Palm Road, Suite J, Phoenix, Arizona 85021, care of Corporation Service Company, 

McKesson’s registered agent in Arizona.

12. Defendant Remedy Temporary Services, Inc. (“Remedy”) is a for profit California 

corporation qualified to do business in Arizona as Remedy Temporary Services LLC. Remedy 

may be served at 8655 East Via De Ventura, #G200, Scottsdale, Arizona 85258, care of Corporate 

Creations Network, Inc., Remedy’s registered agent in Arizona.

13. Remedy works with companies, including McKesson, that require large volume 

work forces. Remedy has employees and managers who work onsite at these companies, including 

at McKesson’s work sites where Plaintiff and the putative class members worked. Remedy 

employees and managers assist and help manage a company’s telephone-dedicated staffing needs 

and who manage recruitment, selection, training, planning, retention and management reporting 

of those phone-based employees. 

14. During the class period, Remedy provided McKesson with staffing and in-house 

services related to the human resources processes, from worker recruitment and selection to 

introduction, planning and management of workers, including of the Plaintiff and similarly situated 

employees.

15. Remedy issued paychecks to Plaintiff and the similarly situated employees. 

16. Defendants employed Plaintiff and other similarly situated persons as “employees,” 

as that term is defined by Section 3(e) of the FLSA, 29 U.S.C. § 203(e).

17. At all material times, Defendants have been an enterprise in commerce or in the 

production of goods for commerce within the meaning of 3(s)(1) of the FLSA because it has had 

employees engaged in commerce. 29 U.S.C. § 203(s)(1).

18. Furthermore, Defendants have had, and continue to have, an annual gross business 

volume in excess of $500,000.

19. At all relevant times, Defendants were an “employer” of Plaintiff and other 

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similarly situated persons, as that term is defined by Section 203(d) of the FLSA, 29 U.S.C. § 

203(d).

20. At all material times, Plaintiff and FLSA Class Members were individual 

employees who engaged in commerce or in the production of goods for commerce as required by 

29 USC § 206-207.

21. Further, at all material times, Defendants have operated as a “single enterprise” 

within the meaning of 3(r)(1) of the FLSA. 29 U.S.C. § 203(r)(1). That is, Defendants perform 

related activities through unified operation and common control for a common business purpose. 

See Brennan v. Arnheim and Neely, Inc., 410 U.S. 512, 515 (1973); Chao v. A-One Med. Servs., 

Inc., 346 F.3d 908, 914–15 (9th Cir. 2003).

FACTUAL ALLEGATIONS

A. Defendants’ Practice of Requiring and/or Permitting Telephone-Based Hourly

Employees to Work Before the Start of Their Scheduled Shift Time

22. McKesson operates and has operated “call centers” in Arizona and across the nation 

where telephone-dedicated employees similar to Plaintiff handle phone calls regarding medicines, 

medical supplies and health care information technology solutions offered by McKesson to its 

customers. 

23. McKesson and Remedy have an agreement to share the services of Plaintiff and 

similarly situated telephone-based employees. 

24. McKesson and Remedy earn revenue and profits from the services of Plaintiff and 

other similarly situated telephone-dedicated employees.

25. Prior to starting work on the call center floor, Plaintiff and other similarly situated 

telephone-based employees were and are interviewed by employees and managers of McKesson 

and Remedy.

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26. Remedy and McKesson had the power to hire and fire Plaintiff and other persons 

similarly situated, with McKesson having ultimate approval as to whether a person works in its 

call centers.

27. For workers placed at McKesson’s call centers via Remedy, both McKesson and 

Remedy supervised and controlled the work schedule of Plaintiff and other similarly situated 

persons.

28. For workers placed at McKesson’s call centers via Remedy, McKesson and 

Remedy jointly determined the rate of pay for Plaintiff other similarly situated persons.

29. For Plaintiff and certain of the workers placed at McKesson’s call centers via 

Remedy, Remedy issued paychecks unless and until the workers became direct employees of 

McKesson, and both Defendants were involved in determining the actual amount of compensation 

paid by the paycheck.

30. At the McKesson call center where Plaintiff Whitmore worked, Remedy and 

McKesson had managers on the floor of the call center during the workday, managing the work 

activities of the Plaintiff and other similarly situated persons.

31. McKesson and Remedy jointly and collectively monitored, controlled and directed 

the work activities of Plaintiff and other similarly situated persons, including the unpaid work at 

issue.

32. Defendants do not allow telephone-based employees to use McKesson’s phones 

and computers for any personal use. Additionally, Defendants generally prohibit and do not allow 

telephone-based employees to use their own personal cell phones on the call center floor. Under 

Defendants’ policies and practices, telephone-based employees are required to store their personal 

cell phones during the work day and can generally only use them on breaks and off the call center 

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floor. 

33. At the McKesson call center where Plaintiff worked, Remedy’s and McKesson’s 

managers on the call center floor could and did regularly see with their own eyes that Plaintiff and 

similarly situated telephone-based employees arrived at their work stations before the start of their 

scheduled shift time, logged into McKesson’s computers, and began working on their computers 

prior to the start of their scheduled shift time.

34. Despite seeing and knowing that Plaintiff and similarly situated telephone-based 

employees performed work at their work stations prior to their scheduled shift time start, 

Defendants and their managers on the floor of the call center did not make any effort to stop or 

otherwise disallow this pre-shift work and instead allowed and permitted it to happen.

35. Defendants possess, control and/or have access to information and electronic data 

that shows the times Plaintiff and similarly situated telephone-based employees logged into their 

computers each day and the time they logged into their telephone systems. 

36. By possessing, controlling and/or accessing this information, Defendants knew that 

Plaintiff and similarly situated telephone-based employees worked prior to the start of their 

scheduled shift time.

37. Despite having this information and knowing that Plaintiff and similarly situated 

telephone-based employees logged into their computers, initialized necessary software programs, 

and read company issued emails and instructions prior to the start of their scheduled shift time, 

Defendants did not make any effort to stop or otherwise disallow this pre-shift work and instead 

allowed and permitted it to happen. 

38. Defendants knowingly required and/or permitted Plaintiff and those similarly 

situated to her to perform unpaid work before and after the start and end times of their shifts, 

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including but not limited to booting up computers, initializing several software programs, and 

reading company issued emails and instructions prior to the start of their scheduled shift time, and 

completing customer service calls, closing down the software programs, and logging off the system 

after the end of their scheduled shift times.

39. In addition, by having managers on the call center floor and having access to the 

electronic data, among other things, Defendants were aware that Plaintiff and those similarly 

situated to her also performed work for Defendants on their break periods, for which they were not 

paid. The work that Plaintiff and similarly situated employees performed during break periods 

includes, but is not limited to, completing customer orders, finishing customer service calls, 

logging back into the phone system, re-booting their computers and initializing software programs.

40. The amount of uncompensated time Plaintiff and those similarly situated to her 

spend or have spent on these required and unpaid work activities averages approximately fifteen 

to twenty minutes per day per person.

41. Defendants monitored and directed the work activities of Plaintiff and other 

similarly situated persons, including the unpaid work at issue.

B. Defendants Knew of and Assented to the Pre-Shift Work

42. Defendants’ policy and practice permits and/or requires telephone-based 

employees to be logged into their phones by the employee’s scheduled start time. 

43. In order to be logged into McKesson’s telephone systems, Defendants required 

and/or permitted Plaintiff and similarly situated telephone-based employees to arrive at their work 

station prior to their scheduled shift time and boot up computers, initialize several software 

programs, and read company emails and instructions. 

44. Defendants’ policy and practice disciplines telephone-based employees if they are 

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not logged into their phones and ready to handle calls by the start of their scheduled shift time. 

45. This policy and practice of Defendants results in telephone-based employees, 

including the Plaintiff, to boot up their computers, initialize several software programs and/or read 

company emails and instructions prior to their start of their scheduled shift time. 

46. As set forth herein, via their policies and practices and through their own telephone 

and computer systems, Defendants knew and were aware that the telephone-based employees 

performed work prior to the start of their scheduled shift. 

47. Defendants did not instruct Plaintiff and similarly situated telephone-based 

employees to not log into their computers or telephones, or to not read company emails prior to 

the start of their scheduled shift time. Rather, Defendants required, permitted and/or allowed 

Plaintiff and the putative class members to work prior to their scheduled shift time.

48. By knowing of, permitting and/or requiring Plaintiff and similarly situated 

telephone-based employees to log into their computers, initialize their various software programs 

and/or read company email and instructions prior to the start of their scheduled shift time, 

Defendants assented to them performing this work. 

C. Defendants’ Failure to Pay Overtime Wages to Their Telephone-Based Hourly 

Employees

49. Defendants determined the rate of pay for Plaintiff other similarly situated persons.

50. McKesson’s and Remedy’s managers reviewed daily work times prior to 

McKesson and Remedy approving paychecks before they were issued.

51. Defendants supervised and controlled the work schedule of Plaintiff and other 

similarly situated persons by setting the work schedules of those persons and requiring them to be 

at their work stations and ready to handle calls at the start of their scheduled shift time. 

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52. Both Defendants determined the actual amount of compensation paid by the 

paycheck.

53. Plaintiff and those employees similarly situated are individuals who were, or are, 

employed by Defendants in customer service, sales, and similar positions at McKesson’s call 

centers who were not paid for some or all of their work activities prior to the beginning of their 

shifts, during meal and rest breaks, or after the end of their shifts.

54. When Plaintiff and similarly situated telephone-dedicated employees are at work 

at McKesson’s call centers, there is no way to tell the difference between direct hires of 

McKesson and other telephone-dedicated workers who are placed at the call center through 

Remedy.

55. Plaintiff and the other employees are similarly situated to one another because 

their duties consisted primarily of providing services related to handling phone calls regarding 

medicines, medical supplies and health care information technology solutions offered by 

McKesson to its customers while working in McKesson’s call centers. Plaintiff and others similarly 

situated all shared similar policies, job titles, job descriptions, training, job duties and compensation, 

among other things.

56. Plaintiff and the other employees are also similar because Defendants did not pay

them for all time they actually worked. Defendants knowingly required Plaintiff and the similarly 

situated individuals to perform unpaid work before and after their scheduled shifts, including but 

not limited to booting-up computers, initializing several software programs, reading company emails 

and instructions, and completing customer service calls. Additionally, Defendants were aware that 

Plaintiff and those similarly situated to her also performed work for Defendants on their break 

periods, for which they were not paid.

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57. The net effect of Defendants’ policies and practices, instituted and approved by 

company managers, is that Defendants willfully failed to pay regular and overtime compensation 

to Plaintiff and others similarly situated, and willfully failed to keep accurate time records to save 

payroll costs. Defendants thus enjoyed ill-gained profits at the expense of their hourly employees.

58. Plaintiff and others similarly situated at times work or worked in excess of forty 

hours per week for Defendants in a given workweek.

59. Defendants’ policy and practice of requiring and/or permitting their employees, 

including Plaintiff and other non-exempt, hourly employees, to perform work without pay for such 

work performed, violates Section 6 of the FLSA, 29 U.S.C. § 206.

60. Defendants’ policy and practice of requiring their employees to perform work 

without pay in many instances has caused and continues to cause Plaintiff and certain other 

similarly situated hourly employees to work in excess of forty hours per week, without being 

properly compensated at a wage of 1.5 times their respective hourly rate for such work performed, 

as required by Section 7 of the FLSA, 29 U.S.C. § 207.

61. Defendants’ failure to compensate their non-exempt, hourly call center employees 

with the full amount of the applicable regular wage or overtime wage has caused Plaintiff and 

other similarly situated non-exempt call center employees to suffer harm.

62. Defendants’ non-exempt, call center hourly employees are entitled to compensation 

for all time they worked without pay in any given workweek.

COLLECTIVE ACTION ALLEGATIONS

63. Plaintiff brings Count I of this Complaint as a collective action on behalf of herself 

and all other current and former hourly employees of Defendants who Defendants required to 

perform the work described herein without pay at any time during the three years prior to the 

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commencement of the action to present at call centers owned by McKesson. 

64. Plaintiff has actual knowledge that FLSA Class Members have been denied 

overtime pay for hours worked over forty hours per workweek. That is, Plaintiff worked with 

other telephone dedicated employees who worked at the McKesson call center. As such, she has 

first-hand personal knowledge that the same pay violations occurred to other class members. 

Furthermore, other telephone dedicated employees at McKesson call centers have shared with her 

similar pay violation experiences as those described in this complaint.

65. Other employees similarly situated to Plaintiff work or have worked at McKesson 

call centers, but were not paid overtime at the rate of one and one-half their regular rate when those 

hours exceeded forty hours per workweek. 

66. Although Defendants permitted and/or required the FLSA Class Members to work 

in excess of forty hours per workweek, Defendants have denied them full compensation for their 

hours worked over forty. Defendants have also denied them full compensation at the federally 

mandated minimum wage rate.

67. FLSA Class Members perform or have performed the same or similar work as 

Plaintiff.

68. FLSA Class Members regularly work or have worked in excess of forty hours 

during a workweek.

69. FLSA Class Members are not exempt from receiving overtime pay at the federally 

mandated wage rate under the FLSA.

70. As such, FLSA Class Members are similar to Plaintiff in terms of job duties, pay 

structure, and the denial of overtime and wages.

71. Defendants’ failure to pay the overtime compensation wage rate required by the 

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FLSA results from generally applicable policies or practices, and does not depend on the personal 

circumstances of the FLSA Class Members.

72. The experiences of Plaintiff, with respect to her pay, are typical of the experiences 

of the FLSA Class Members.

73. The specific job titles or precise job responsibilities of each FLSA Class Member 

do not prevent collective treatment.

74. All FLSA Class Members, irrespective of their particular job requirements, are 

entitled to overtime compensation for hours worked in excess of forty during a workweek.

75. Although the exact amount of damages may vary among FLSA Class Members, 

the damages for the FLSA Class Members can be easily calculated by a simple formula. The claims 

of all FLSA Class Members arise from a common nucleus of facts. Liability is based on a 

systematic course of wrongful conduct by Defendants that caused harm to all FLSA Class 

Members.

76. As such, Plaintiff brings her FLSA overtime claim as a collective action on behalf 

of the class set forth in the following paragraph.

77. Plaintiff’s Counsel seek to send notice of this lawsuit to the following described 

persons:

All persons who worked for Defendants as telephone dedicated 

employees, however titled, except those persons who were direct 

employees of McKesson, who were compensated, in part or in full, 

on an hourly basis at McKesson call centers, at any time between

October 27, 2012 and the present and who did not receive the full 

amount of overtime wages earned and owed to them.

78. There are questions of law or fact common to the employees described in paragraph 

77.

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79. Plaintiff is similarly situated to the employees described in paragraph 77, as 

Plaintiff’s claims are typical of the claims of those persons.

80. Plaintiff’s claims or defenses are typical of the claims or defenses of the persons 

described in paragraph 77.

81. This is not a collusive or friendly action. Plaintiff has retained counsel experienced 

in complex employment litigation, and Plaintiff and her counsel will fairly and adequately protect 

the interests of the persons described in paragraph 77.

82. A collective action is the most appropriate method for the fair and efficient 

resolution of the matters alleged in Count I.

83. At all relevant times, Defendants employed Plaintiff and the persons described in 

paragraph 77.

84. At all relevant times, Defendants paid Plaintiff and the persons described in 

paragraph 77 to work.

85. At all relevant times, Defendants have been an “employer” of Plaintiff and the 

persons described in paragraph 77, as the term “employer” is defined by Section 3(d) of the FLSA, 

29 U.S.C. § 203(d). 

86. At all relevant times, Plaintiff and the persons described in paragraph 77 have been 

“employees” of Defendants as defined by Section 3(e) of the FLSA, 29 U.S.C. § 203(e).

COUNT I – FLSA

(Failure to Pay Overtime Wages)

87. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 86 as 

paragraph 87 of this Count I.

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88. Plaintiff, individually and on behalf and the members of the class described in 

paragraph 77, asserts claims for unpaid overtime pursuant to the FLSA.

89. At any and all times relevant hereto, Defendants were an “enterprise engaged in 

commerce” within the meaning of Section 3(s) of the FLSA, 29 U.S.C. § 203(s).

90. At any and all times relevant hereto, Defendants were an “employer” of the Plaintiff 

and the members of the class described in paragraph 77 within the meaning of Section 3(d) of the 

FLSA, 29 U.S.C. § 203(d). 

91. At any and all times relevant hereto, Plaintiff and the members of the class 

described in paragraph 77 were “employees” of Defendants as defined by Section 3(e) of the 

FLSA, 29 U.S.C. § 203(e).

92. Plaintiff and the members of the class described in paragraph 77 were not paid for 

all time worked in excess of 40 hours in a week during the applicable statutory time period, in 

violation of the maximum hours provisions of the FLSA, 29 U.S.C. § 207.

93. At all times relevant hereto, Defendants’ failure to pay Plaintiff and the members 

of the class described in paragraph 77 premium pay for all time worked over 40 hours in a week 

was willful in that, among other things:

a. Defendants knew that the FLSA required them to pay time and one-half for 

all time worked over 40 hours in a week;

b. Defendants failed to maintain true and accurate time records; and

c. Defendants encouraged Plaintiff and other similarly situated employees to 

not record all time worked.

94. As a direct and proximate result thereof, Plaintiff and the members of the class 

described in paragraph 77 are due unpaid back wages and liquidated damages, pursuant to 29 

U.S.C. § 216.

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DAMAGES SOUGHT

95. Plaintiff and the FLSA Class Members are entitled to recover compensation for the 

hours they worked for which they were not paid at the federally mandated overtime wage rate.

96. Plaintiff and the FLSA Class Members are also entitled to an amount equal to all 

of their unpaid wages as liquidated damages. 29 U.S.C. § 216(b).

97. Plaintiff and FLSA Class Members are entitled to recover their attorneys’ fees and 

costs as required by the FLSA. 29 U.S.C. § 216(b).

WHEREFORE, Plaintiff, individually and on behalf of all others similarly situated, by and 

through her attorneys, demands judgment against Defendants and in favor of Plaintiff and all others 

similarly situated, for a sum that will properly, adequately and completely compensate them for 

the nature, extent and duration of their damages, the costs of this action and as follows:

A. Conditionally certify the class described in paragraph 77, and grant Plaintiff’s counsel 

leave to send notice of this lawsuit to the members of the class and allow them the 

opportunity to opt-in as party plaintiffs pursuant to Section 16 of the FLSA, 29 U.S.C. § 

216;

B. Declare and find that the Defendants committed one or more of the following acts:

i. Violated provisions of the FLSA for Plaintiff and all persons who opt-in as party 

plaintiffs; and

ii. Willfully violated provisions of the FLSA for Plaintiff and all persons who opt-in 

as party plaintiffs.

C. Award compensatory damages, including all wages and overtime pay

owed, in an amount according to proof;

D. Award liquidated damages on all wages and overtime compensation due to Plaintiff and all 

persons who opt-in as party plaintiffs;

E. Award all costs and reasonable attorneys’ fees incurred prosecuting this claim;

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F. Grant leave to amend to add claims under applicable state and federal laws to conform with 

the proofs at trial;

G. Grant leave to add additional plaintiffs by motion or any other method approved by the 

Court to conform with the proofs at trial; and 

H. Grant such further relief as the Court deems just and equitable.

DATED this 22nd day of March 2016

LAW OFFICE OF JAMES X. BORMES, P.C.

s/ James X. Bormes

(pro hac vice)

James X. Bormes

LAW OFFICE OF JAMES X. BORMES, P.C.

Illinois State Bar No. 620268

8 South Michigan Avenue

Suite 2600

Chicago, Illinois 60603

(312) 201-0575

jxbormes@bormeslaw.com

Thomas M. Ryan

(pro hac vice)

LAW OFFICE OF THOMAS M. RYAN, P.C.

Illinois State Bar No. 6273422

35 East Wacker Drive

Suite 650

Chicago, Illinois 60601

(312) 726-3400

tom@tomryanlaw.com

LOCAL COUNSEL:

Michelle R. Matheson #019568

MATHESON & MATHESON, P.L.C.

15300 North 90th Street

Suite 550

Scottsdale, Arizona 85260

(480) 889-8951

mmatheson@mathesonlegal.com

Attorney for Plaintiff

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CERTIFICATE OF SERVICE

I hereby certify that on March 22, 2016, I electronically transmitted the attached 

document to the Clerk's Office using the CM/ECF System for filing and for service to the 

following CM/ECF registrants:

Gerald L. Maatman, Jr.

Christina M. Janice

Amelia Sanchez-Moran

Seyfarth Shaw LLP

131 South Dearborn, Suite 2400

Chicago, IL 60603

/s/ Dawanyia Slayton, Paralegal

Case 2:15-cv-02161-SRB Document 38 Filed 03/22/16 Page 18 of 18