Complaint Filed For Field Rep Unpaid Overtime Lawsuit

Our overtime pay attorneys are currently handling an unpaid overtime lawsuit against Reliable Reports, Inc., a Texas corporation that allegedly willingly violated the Fair Labor Standards Act (FLSA).  Our lawyers have filed the lawsuit on behalf of a Field Reporting Specialist (Field Rep) and other current and former employees working at Reliable Reports, Inc.  The lawsuit seeks payment for all unpaid overtime wages owed as well any liquidated fees and attorney fees.

A Field Rep is assigned 45 to 100 properties to inspect in a typical work week. Properties were often located 10 to 30 miles apart and were often in urban areas where traffic and other unexpected delays are prevalent.

Reliable Reports refused to pay its Field Rep’s for driving time, driving time that employees incurred at the beginning and end of each shift, traveling from their homes to first appointment and from their last appointment back to their homes.

In addition, the Field Reps put hundreds of miles on their own personal vehicles, completed multiple overnight trips per month, performed massive amounts of unpaid off-the-clock work and overtime, and paid the entire cost of a variety of mandatory-job related expenses, including a home office, cell phone, GPS unit and more. When these costs were deducted from the Field Reporting Specialists and also divided into the massive number of hours they actually worked each week, the employees did not earn the federally mandated minimum wage.

Below you will find the Complaint. The unpaid overtime lawsuit is currently pending in court.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA

FORT WAYNE DIVISION

MATTHEW HARRIS, individually and on behalf of all similarly situated individuals,

vs.

RELIABLE REPORTS, INC., a Texas Corporation,

Defendant.                                                                                                  

PLAINTIFF’S MOTION FOR CONDITIONAL CLASS CERTIFICATION,  COURT-SUPERVISED NOTICE TO POTENTIAL OPT-IN PLAINTIFFS

PURSUANT TO 29 U.S.C. §216(b). AND EXPEDITED DISCOVERY

Plaintiff,  Matthew Harris,  on  behalf of himself and  all  other  similarly  situated

individuals, respectfully moves, pursuant to Section 16(b) of the Fair Labor Standards Act

(“FLSA”), 29 U.S.C. § 216(b), for entry of an order:

(1)  conditionally certifying a collective FLSA class;

(2)  implementing a procedure whereby Court-Supervised Notice of Plaintiffs FLSA claim is sent (via US Mail and e-mail) to all current and former employees employed by Reliable Reports, Inc. (“Defendant”) during the past three years as Field Reporting Specialists (or “Field Reps” as they are also sometimes called);¹ and

(3)  requiring Defendant to identify all potential opt-in plaintiffs by promptly responding to “Plaintiffs First Interrogatories to Defendant” (attached as Exhibit B) within ten (10) days of the entry of the order.

¹ A proposed Notice is attached as Exhibit A.