 Plaintiffs have retained the services of the undersigned attorneys and are obligated  to pay the undersigned a reasonable fee for their services.    Plaintiffs demand a trial by jury on all claims alleged herein.   Plaintiffs sue under Rule 23(a) and (b) of the Federal Rules of Civil Procedure for  violations of the WARN Act, on behalf of themselves, and a class of employees who were laid off  by Defendants as part of a reasonably foreseeable result of shutdowns or mass layoffs (“Class”)  during the weeks of September 30, 2019, through October 14, 2019.    The persons in the Class (“Class Members”) are so numerous that joinder of all  members is impracticable as there are, upon information and belief, approximately one-hundred  or more (100) potential class members.    The claims of the representative Plaintiff are typical of the claims of the Class, as  she/they were laid off as part of the shutdown or mass layoff, and did not receive the requisite  notice.    The representative Plaintiff will fairly and adequately protect the interests of the  class.    The named Plaintiff retained counsel competent and experienced in complex class  action employment litigation.    A class action is superior to other available methods for the fair and efficient  adjudication of this controversy—particularly in the context of WARN Act and wage litigation –  where the individual Plaintiff and class members may lack the financial resources to vigorously  prosecute a lawsuit in federal court against corporate defendants and separate actions would create  a risk of inconsistent or varying adjudications with respect to individual class members and the  adjudications with respect to individual class members would be dispositive of the interests of  other members.    Defendants have acted on grounds that apply generally to the class.    Plaintiff and other similarly situated employees were laid off as part of plant  shutdowns or mass layoffs of a single site of employment as defined by the WARN Act, for which  they were entitled to receive 60 days advance written notice under the WARN Act.    At all relevant times, Defendants employed three hundred (300) or more  employees, exclusive of part-time employees, or employed 100 or more employees who in the  aggregate worked at least 4,000 hours per week exclusive of hours of overtime within the United  States as defined by the WARN Act.     At all relevant times, Defendants were “employers” as that term is defined by the  WARN Act.      During the weeks of September 30, 2019, through October 14, 2019, Defendants  ordered “shutdowns” or “mass layoffs” as that term is defined by the WARN Act.      Defendants’ actions resulted in an “employment loss” as that term is defined by the  WARN Act for at least 33% of its workforce, and at least 50 of its employees, excluding (a)  employees who worked less than six of the twelve months prior to the date WARN notice was  required to be given and (b) employees who worked an average of less than 20 hours per week  during the 90-day period prior to the date WARN notice was required to be given.    Defendants’ termination of the Class Members’ employment constituted plant  shutdowns or mass layoffs at a single site of employment as defined by the WARN Act.     The Plaintiff and each of the Class Members are “aggrieved employees” of  Defendants as that term is defined by the WARN Act.    Pursuant to the WARN Act, Defendants were required to provide at least 60 days  prior written notice of the layoff, or notice as soon as practicable, to the affected employees, or  their representative, explaining why the sixty (60) days prior notice was not given.     Defendants failed to give at least sixty (60) days prior notice of the layoff in  violation of the WARN Act.    Defendants failed to pay the Plaintiff and each of the Class Members their  respective wages, salary, commissions, bonuses, accrued holiday pay and accrued vacation for 60  working days following their respective layoffs, and failed to make the pension and 401(k)  contributions, provide other employee benefits under ERISA, and pay their medical expenses for  60 calendar days from and after the dates of their respective terminations.    As a result of Defendants’ failure to pay the wages, benefits and other monies as  asserted, the Plaintiff and Class Members were damaged in an amount equal to the sum of the  members’ unpaid wages, accrued holiday pay, accrued vacation pay, accrued sick leave pay and  benefits which would have been paid for a period of sixty (60) calendar days after the date of the  their terminations.    All administrative notice requirements and prerequisites have been satisfied.   Plaintiff hereby incorporates by reference the allegations contained in paragraphs 1  through 33 as if fully stated herein.    Plaintiffs were employed by Defendants.      During the weeks of October 7 and October 14, 2019, Defendants, without warning,  and despite having knowledge of their intention to conduct mass lay-offs, engaged in a mass lay  off without properly notifying Plaintiffs.    No prior written notice was provided to the Plaintiffs as required by the WARN act.   VIOLATIONS OF THE WARN ACT AGAINST DEFENDANT  