simmons et al v. oklahoma heart hospital llc et al - 5:17 ... · case 5:17-cv-00607-m document 1...

Case 5:17-cv-00607-M Document 1 Filed 05/31/17 of 22

IN THE UNITED STATES DISTRICT COURT FORTHE WESTERN DISTRICT OF OKLAHOMA

(1) BRENDA SIMMONS,

(2) TUESDAE BOWLING,

(3) KIMBERLY MCKINZIE,

(4) REBECCA PARKER,on behalf of themselves andall others similarly situated,

Plaintiffs,

V.Case No. CIV-17-607-M

(1) OKLAHOMA HEART

HOSPITAL, LLC, D/B/AOKLAHOMA HEART JURY TRIAL DEMANDED ONHOSPITAL ALL CLAIMSPHYSICIANS GROUP,

(2) OHH PHYSICIANS,LLC,

Defendants.

VERIFIED COMPLAINT

Plaintiffs Brenda Simmons ("Simmons"), Tuesdae Bowling

("Bowling"), Kimberly McKinzie ("McKinzie"), and Rebecca Parker

("Parker") (collectively, "Plaintiffs"), on behalf of themselves and all others

similarly situated, bring this cause of action against Oklahoma Heart

Hospital, LLC d/b/a Oklahoma Heart Hospital Physicians ("OHH") and

OHH Physicians LLC ("OHHP") (collectively, "DEFENDANTS") and

state as follows:

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Parties

1. Defendants Oklahoma Heart Hospital, LLC ("OHH") is an Oklahoma

limited liability company doing business as Oklahoma Heart

Hospital Physicians with its primary place of business in Oklahoma

City, Oklahoma.

2. Defendants OHH Physicians LLC ("OHHP") is an Oklahoma limited

liability company entity related to OHH with its primary place of

business in Oklahoma City, Oklahoma.

3. OHH and OHHP, collectively, Defendants, style themselves and

other related entities operate collectively as a physician-owned

hospital system, designed by cardiologists to empower cardiovascular

specialists to bring world-class medical expertise and compassion to

the care of every patient.

4. Plaintiff Brenda Simmons is a citizen of the United States and

resides in Oklahoma City, Oklahoma. She was a Medical

Transcriptionist for Defendants from 2015 to 2017.

5. Plaintiff Tuesdae Bowling is a citizen of the United States and

resides in Oklahoma City, Oklahoma. She was a Medical

Transcriptionist for Defendants from 2015 to 2016.

6. Plaintiff Kimberly McKinzie is a citizen of the United States and

resides in Broken Arrow, Oklahoma. She has been a Medical

Transcriptionist for Defendants since 2010.

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7. Plaintiff Rebecca Parker is a citizen of the United States and resides

in Tulsa, Oklahoma. She has been a Medical Transcriptionist for

Defendants since 2010.

8. Plaintiffs consented in writing to be a part of this FLSA collective

action pursuant to 29 U.S.C. §216(b). Plaintiffs' signed consent forms

are attached as Exhibit 1 to this Complaint.

9. Plaintiffs bring this case individually and as an "opt-in" collective

action under 29 U.S.C. 216(b) on behalf of all those who file a

consent to join form with the Court.

10. Defendants employ many individual employees as Medical

Transcriptionists at any given period of time.

11. The number and identities of potential opt-in Plaintiffs may be easily

determined from Defendants' records.

Jurisdiction and Venue

12. The FLSA authorizes court actions by private parties to recover

damages for violation of the wage and hour provisions contained

within the FLSA. Jurisdiction over Plaintiffs' FLSA claims is based

upon 29 U.S.C. 216(b) and 28 U.S.C. 1331.

13. At all times material to this action, Defendants are and/or have been

the "employer" of Plaintiffs and those similarly situated within the

meaning of 29 U.S.C. 203(d).

14. At all times material to this action, Plaintiffs and those similarly

situated are and/or have been "employees" of Defendants as defined

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by 29 U.S.C. 203(e)(1), and worked for Defendants within the

territory of the United States within three (3) years preceding the

filing of this lawsuit.

15. Plaintiffs and those similarly situated are non-exempt employees

within the meaning of the FLSA.

16. At all times material to this action, Defendants have been an

enterprise engaged in commerce or in the production of goods for

commerce as defined by 29 U.S.C. 203(s)(1) of the FLSA, with

annual revenue in excess of 8500,000.00. At all times material to this

action, Defendants have been engaged in commerce or in the

production of goods for commerce. 29 U.S.C. 201(s)(1)(B).

17. Venue in this Court is proper under 28 U.S.C. 1391(b) because the

occurrences in question substantially occurred in the this District, at

least one of named Plaintiffs resides in this District, a significant

number of putative class members reside in this District, and

Defendants is located in this District.

Factual Allegations

General Work Duties

18. Plaintiffs are current or former employees of Defendants who

performed Medical Transcriptionist ("MT") related work duties.

19. These MTs served as "telecommuting" employees of Defendants, who

commonly performed transcription work from home.

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20. MTs transcribed doctor dictations for a variety of medical records

such as referring physician letters, clinic notes, clinic diagnostic

reports, patient histories, physical examinations, emergency room

visits, operations, chart reviews, and consultation and discharge

summaries.

21. MTs returned dictated reports in printed or electronic form for

physicians' review, corrections, and signature, and for inclusion in

patients' medical records.

22. Defendants' uniform job description and offer letter for MTs

specifically notes the position's "FLSA status" as "NON-EXEMPT,

thus requiring the payment of overtime and minimum wage for all

time worked and obligating Defendants to maintain accurate records

of hours worked and wages paid to MTs.

23. Defendants required MTs to: translate medical jargon and

abbreviations into their expanded forms to ensure the accuracy of

patient and health care facility records; know medical office

procedures; identify mistakes in reports and check with doctors to

correct information; recognize inconsistencies in medical terms;

review, edit and proofread reports or dictated material for spelling,

grammar, clarity, consistency, and proper medical terminology; have

working knowledge of and proficiency in their medical transcription

platform and related software; exhibit a "bring it on" work ethic by

being solution- and team-oriented, flexible, and positive; not take

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excessive or abusive breaks; and attend 90% of team and

departmental meetings.

24. To facilitate the work-at-home arrangement, Defendants provided

MTs with equipment and software necessary to perform

transcription and with access to Defendants' IT technical support.

Compensation

25. Defendants compensated MTs based on production (i.e., at a flat rate

per line of transcription produced), commonly at the rate of

approximately eleven (11) cents per line.

26. Defendants did not instruct MTs to record their hours worked per

workweek. Defendants did not seek to track or keep accurate records

of hours worked by MTs, nor record hours worked by MTs on their

paystubs.

27. Defendants removed MTs' access to information about the amount of

lines typed by the MTs on Defendants' medical transcription

platform accessible by Plaintiffs, and Defendants did not list line

counts on MTs' paystubs.

28. Defendants listed a pay rate of, for example, $16.00 per hour on MTs'

paystubs.

29. Defendants did not record or maintain accurate records of hours

worked by MTs for purposes of compensation. In failing to do so,

Defendants failed to satisfy their duties as an employer under the

FLSA.

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30. MTs' production pay did not include compensation for any other

activities beyond line production.

31. Defendants specifically and repeatedly informed MTs that they

received pay based only upon their actual production of lines.

32. Defendants told MTs they could not make a higher rate than their

production rate, commonly about eleven (11) cents per line.

33. Supervisors specifically informed MTs that they were not entitled to

additional compensation beyond their line rate (i.e., for any time

spent completing any other task beyond line production).

34. Defendants denied MTs further benefits or pay, including paid time

off, after MTs met their quotas for the amount of hours that they

worked based on lines produced.

Production, Quality, and Timeliness Requirements

35. Defendants required MTs to meet minimum production, quality and

timeliness standards for their work.

36. Defendants did not guarantee any particular amount of work would

be available at any given time. Defendants specified, however, that

full-time MTs worked full-time schedules.

37. Defendants expected MTs to produce 150 lines per hour.

38. Defendants had a minimum production standard of 110 lines per

hour.

39. Defendants specifically identified 6000 lines per week (i.e., 150 lines

per hour) as 40 hours of production time.

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40. Defendants noted these production expectations and standards as

critical to their success.

41. Defendants required MTs to ensure that the transcribed and edited

lines of the medical records reflect rates of accuracy in excess of 99%.

42. With respect to timeliness, Defendants generally considered an

acceptable turnaround time to be 24-48 hours.

43. MTs were evaluated on, inter alia: their ability to maintain their

average lines while at the same time maintaining a high level of

accuracy; their knowledge of medical office procedures; their review,

editing and proofreading of reports and dictated materials; ability to

maintain a proper database of documentation for reports transcribed;

their turnaround times; and communication with physicians.

44. MTs unable to meet these production, quality, and timeliness

standards were subject to discipline and/or termination of

employment.

45. Discretionary bonuses to MTs were based upon annual evaluations

regarding successful performance of all of their duties and work

performed—not just line production.

Equating Line Counts to Hours Worked

46. Defendants developed internal calculations of production time based

on lines produced per week.

47. At around eleven (11) cents per line at a rate of 150 lines per hour,

MTs would earn about $16.00 per hour.

8


48. MTs commonly produced more than 4, 400 or 6, 000 lines per

workweek.

49. Based upon the lines typed exceeding what Defendants considered a

40 hour workweek, Defendants knew or should have known that MTs

were working in excess of 40 hours per workweek without overtime

compensation.

50. MTs were provided specific examples as to their hourly rate based

upon their lines produced per hour.

51. Defendants used this hourly rate conversion to calculate accrued paid

time off ("PTO") for MTs.

52. Defendants' own records demonstrate Defendants' production-based

understanding that MTs worked overtime without overtime pay.

53. For example, in one biweekly pay period (i.e., February 26, 2017 to

March 11, 2017), named Plaintiff Simmons earned $1926.29, typing

17, 511 lines at a rate of eleven (11) cents. According to Defendants'

understanding and expectations regarding line production per hour

(i.e., an average of 110 to 150 lines per hour), Simmons would have

worked between 117 to 160 hours during this biweekly pay period

without any compensation for overtime hours worked.

Unpaid Transcription-Related Duties

54. Beyond the production pay and production time worked, Defendants

did not track or compensate non-productive time worked by MTs.

9


55. MTs' production pay did not account for all of the non-productive

activities they performed.

56. Defendants specifically indicated to MTs that they are compensated

based on production of lines of transcription, subject to withholding

taxes, and would not be compensated for any other work-related

activity.

57. MTs performed various non-productive tasks which were essential to

the accurate editing and transcribing of medical reports, but did not

receive compensation therefor.

58. MTs' duties that were essential to the accurate editing and

transcription of medical reports included: retrieving the patient's

medical record number and name to verify the correct individual's

record is being consulted; ascertaining the patient's name, date of

birth, and date of visit to the physician and hospital are correct;

ensuring the dictator's name is entered correctly; making sure all

preliminary background information is entered correctly and, if the

dictator does not provide the date of the report, looking up the correct

information to determine the date; ensuring the attending

physician's name is entered and marked to receive a copy of the

patient report; communicating with other MTs as a team,

Defendants' management, and doctors via phone, e-mail and text

message; ensuring the accuracy of physician and patient personal

information to verify locations, addresses, and proper inputting of

10


medications; ensuring the proper medical term (in terms of spelling

and definition) is inserted into the medical record; communicating

with technical support in order to troubleshoot technical problems or

defects with Defendants' transcription/editing platform and/or voice-

recognition software; picking up medical records from medical offices

or facilities for transcription purposes; and notifying Defendants that

they would be away from the keyboard for certain periods of time.

59. MTs performed additional, uncompensated work in the preparation

and finalization of hospital dictation records that were submitted.

This work included, inter alia, downloading files to be transcribed

and searching for emergency transcriptions ("STATs"). MTs' work

was also subject to physician review, requests for additional

transcription, and/or corrections prior to signature. Such changes

and adjustments in patient medical records were completed as part

of the reports upon which MTs were evaluated.

60. Defendants also required the typing of information and lines (which

were not tracked by the transcription platform) for which MTs were

not compensated, including appending metadata and other

information within the transcription platform during the production

flow processes.

Other Unpaid Time Worked

61. MTs had to "watch for work, which means monitoring the

transcription queue for dictations to become available.

11


62. MTs were on-call, including certain hours during the day during

which Defendants expected MTs to be ready and available to work.

MTs commonly received texts and phone calls from doctors or

hospital personnel to quickly complete STATs or begin working.

Defendants provided each MT with an OEM email address and

frequently sent emails and information regarding work-related

matters.

63. Initial training on, installation of, and configuration of Defendants'

transcription software platform was uncompensated.

64. Initial employee orientation was uncompensated.

65. MTs attended unpaid training sessions. Defendants' Transcription

Supervisor tracked training attendance for annual performance

evaluations.

66. Defendants further required MTs to go to meetings in the Oklahoma

City office, take yearly HIPAA computer courses and other trainingwithout compensation.

Defendants' Further Knowledge of Time Worked by MTs ThroughClose Supervision

67. Defendants' Transcription Supervisor closely monitored MTs and

their production quality, quantity, and other work performed.

68. Defendants' Transcription Supervisor monitored line counts on

Monday mornings, and would commonly send out emails during the

week to MTs regarding their line counts and the need for them to

12


meet line count expectations, as well as quality and timeliness

requirements.

69. Defendants did, or had the ability to, track MTs time worked using

their medical transcription platform technology, third-party Kronos

software, and other internal and third-party analytics software and

production tracking information available to Defendants.

70. Defendants' Transcription Supervisor was aware that MTs routinely

worked seven days a week to meet line and other production

expectations.

71. Defendants' Transcription Supervisor required MTs to notify

Defendants of any unavailability and to request approval for any

unavailability to ensure that STATs were directed to available MTs.

72. The records generated by the transcription/editing software,

including but not limited to Cerner, indicate MTs' log-in and -out

information. Records showing VPN log-in and -out information most

likely also reflect the same.

73. Based on information and belief, Defendants used KRONOS

timekeeping and attendance software to convert lines produced into

hours of production time worked.

74. Despite their knowledge that Plaintiffs were non-exempt employees

who performed additional work beyond line production, Defendants

ended their practice of tracking all time worked prior to the start of

the proposed Class Period.

13


75. Defendants made active efforts to misinform employees of their

rights and to conceal known violations, thereby justifying equitable

tolling of the statute of limitations.

Collective Action Allegations

76. Plaintiffs, individually and on behalf of other similarly situated MT

employees of Defendants, seek relief on a collective basis based on

Defendants' failure to provide premium pay for all hours worked in

excess of forty (40) per workweek during at least one (1) workweek

over the past three (3) years.

77. Defendants required MTs to perform the same job duties and tasks,

subject to the same production, quality, and timeliness standards

and expectations.

78. Defendants compensated MTs based on the same pay policies and

criteria (i.e., flat rate per line of transcription produced; no overtime

pay; no compensation for other job duties and tasks; equating lines

production with hours worked).

79. Defendants established a common plan or policy to not pay overtime

premiums to MTs, who Defendants knew to be non-exempt

employees.

80. Defendants established a common plan or policy of refusing to pay

MTs for job duties and tasks beyond line production.

81. Defendants established a common plan or policy of equating line

counts with hours worked.

14


82. Defendants established a common plan or policy to not track, or

maintain accurate records of, hours worked by MTs, who Defendants

knew to be non-exempt employees.

Count I

(Failure to Pay Overtime in Violation of the FLSA)

83. Plaintiffs hereby incorporate and re-allege, in full, all preceding

paragraphs of this Complaint.

84. At all times relevant herein, Plaintiffs and similarly situated

employees were entitled to the rights, protections, and benefits

provided under the FLSA.

85. The FLSA requires employers to pay non-exempt employees one and

one-half times the regular rate of pay at which they are employed for

hours worked in excess of forty (40) per workweek. 29 U.S.C. 207.

86. Defendants failed to pay Plaintiffs and those similarly situated

overtime compensation at the statutorily prescribed rate of one-and-

one-half times the regular rate of pay for all hours worked in excess

of forty (40) per work week.

87. Plaintiffs and those similarly situated are entitled to an award of

liquidated damages. Defendants will not be able to meet their

burden of proving that it acted in good faith and with objectivelyreasonable grounds for believing that their conduct was not in

violation of the FLSA.

15


88. Defendants' violations of the FLSA as stated herein are willful

violations resulting in a three (3) year statute of limitations as

Defendants knew, or showed reckless disregard for whether, their

conduct violated the FLSA specific to Plaintiffs and those similarly

situated.

89. Defendants violated the FLSA by failing to keep accurate records of

all time worked by, and wages and wage adjustments paid to,

Plaintiffs and those similarly situated.

90. Defendants failed to post notice of FLSA rights and misinformed

employees as to their rights justifying equitable tolling of the statute

of limitations.

91. Defendants are liable under the FLSA for unpaid overtime,

liquidated damages, pre- and post-judgment interest, reasonable

attorneys' fees, court costs and litigation costs.

WHEREFORE Plaintiffs seek relief and judgment against

Defendants, individually and as a collective action, as follows: notice of

this action be provided to all similarly situated persons as a collective

action under the FLSA; judgment against Defendants for violation of the

FLSA; an award of unpaid wages; incentive payment to the representative

Plaintiffs; determination that Defendants' FLSA violations were willful;

imposition of liquidated damages against Defendants; pre-judgment and

post-judgment interest as provided by law; an award of reasonable

16


attorneys' fees, litigation costs and court costs incurred; and for such other

and further relief as the Court deems just and proper.

Demand for Jury Trial

Plaintiffs and those similarly situated demand a jury trial on all

claims presented herein.

17


Respectfully submitted,

/s/ D. Colby AddisonD. Colby Addison, OBA #32718Chris Hammons, OBA #20233LAIRD HAMMONS LAIRD, PLLC1332 SW 89th StreetOklahoma City, OK 73159

Telephone: 405.703.4567Facsimile: 405.703.4067E-mail: [email protected]

Kevin J. Dolley, USDC No. 54132M0(Application for Pro Hac ViceAdmission Pending)LAW OFFICES OF KEVIN J. DOLLEY, LLC2726 S. Brentwood Blvd.St. Louis, MO 63144

Telephone: 314.645.4100Facsimile: 314.736.6216Email: kevin@dolle law.com

ATTORNEYS FOR PLAINTIFFS AND THOSESIMILARLY SITUATED

18


C7t77-- VERIFICATION

Pe Leccc.I, --Tuesd-atitrg, verify under penalty of perjury that the foregoing Verified

Complaint is true and correct to the best of my knowledge, information, and belief.

Dated:

Petft-Sign Name

19


VERIFICATION

I, Kimberly McKinzie, verify under penalty of perjury that the foregoing Verified


Dated: .5

441 Ze:Sign Name

19


VERIFICATION

I, Brenda Simmons, verify under penalty of perjury that the foregoing Verified


Dated: /3 1 oil

N'teAAL__ 5t-vvkSign Name

19


VERIFICATION

I, Thesdae Bowling, verify under penalty of perjury that the foregoing Verified


Dated: 3 20 17

7-COA wL1NC,Sign Name

19

JS 44 (Rev. 08/16) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except asprovided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for thepurpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff(For Diversity Cases Only) and One Box for Defendant)

’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEFPlaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4

of Business In This State

’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6 Foreign Country

IV. NATURE OF SUIT (Place an “X” in One Box Only) Clic ere for: Nature of Suit Code Descriptions.CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 376 Qui Tam (31 USC ’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 3729(a))’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 410 Antitrust

& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 840 Trademark ’ 460 Deportation

Student Loans ’ 340 Marine Injury Product ’ 470 Racketeer Influenced and (Excludes Veterans) ’ 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizations

’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 480 Consumer Credit of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud Act ’ 862 Black Lung (923) ’ 490 Cable/Sat TV

’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) ’ 850 Securities/Commodities/’ 190 Other Contract Product Liability ’ 380 Other Personal Relations ’ 864 SSID Title XVI Exchange’ 195 Contract Product Liability ’ 360 Other Personal Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 890 Other Statutory Actions’ 196 Franchise Injury ’ 385 Property Damage ’ 751 Family and Medical ’ 891 Agricultural Acts

’ 362 Personal Injury - Product Liability Leave Act ’ 893 Environmental Matters Medical Malpractice ’ 790 Other Labor Litigation ’ 895 Freedom of Information

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 791 Employee Retirement FEDERAL TAX SUITS Act’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: Income Security Act ’ 870 Taxes (U.S. Plaintiff ’ 896 Arbitration’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee or Defendant) ’ 899 Administrative Procedure’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party Act/Review or Appeal of’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 Agency Decision’ 245 Tort Product Liability Accommodations ’ 530 General ’ 950 Constitutionality of’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION State Statutes

Employment Other: ’ 462 Naturalization Application’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration

Other ’ 550 Civil Rights Actions’ 448 Education ’ 555 Prison Condition

’ 560 Civil Detainee - Conditions of Confinement

V. ORIGIN (Place an “X” in One Box Only)’ 1 Original

Proceeding’ 2 Removed from

State Court’ 3 Remanded from

Appellate Court’ 4 Reinstated or

Reopened’ 5 Transferred from

Another District(specify)

’ 6 MultidistrictLitigation -Transfer

’ 8 Multidistrict Litigation -

Direct File

VI. CAUSE OF ACTIONCite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:

VII. REQUESTED INCOMPLAINT:

’ CHECK IF THIS IS A CLASS ACTIONUNDER RULE 23, F.R.Cv.P.

DEMAND $ CHECK YES only if demanded in complaint:JURY DEMAND: ’ Yes ’ No

VIII. RELATED CASE(S)IF ANY (See instructions):

JUDGE DOCKET NUMBERDATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 5:17-cv-00607-M Document 1-1 Filed 05/31/17 Page 1 of 1

Simmons, Brenda; Bowling, Tuesdae; McKinzie, Kimberly; Parker, Rebecca

Cleveland

D. Colby Addison; Chris Hammons; Laird Hammons Laird, PLLC 1332 SW 89th Street, Oklahoma City, OK 73159 405.703.4567

Oklahoma Heart Hospital, LLC; OHH Physicians, LLC.

Oklahoma

Paul Ross; McAfee & Taft Tenth Floor, Two Leadership Square, 211 North Robinson Ave. Oklahoma City, OK 73102; 405.235.9621

29 U.S.C. § 201–216

Collective action wage claim

Excess of $75,000.00

05/08/2017 D. Colby Addison

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simmons et al v. oklahoma heart hospital llc et al - 5:17 ... · case 5:17-cv-00607-m document 1...

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