Aleksandar Zunzurovski v. Michael Wright

This is an action for monetary and declaratory relief to redress the Defendants' violation of the

Plaintiffs' rights. The plaintiff seeks relief for Unjust Enrichment.

At all times relevant to this Complaint, the Defendant was an employee of Sapphire.

Upon information and belief, Wright worked as a "Host" or manager of the dancers and junior staff

during their employment with Sapphire.

On or about April 5, 2019, Maria Vasquez (“Vasquez”), a former dancer and employee of Sapphire,

sat for a deposition (“Vasquez Depo”) in a lawsuit she filed against Sapphire, James Mark Talla,

Jeffrey Wasserman, and Glen Peter Bernardi. This matter was held before Arbitrator Martin F.

Scheinman.

During the Vasquez Depo, Plaintiff and Wright were named as “Hosts” who allegedly sexually

harassed and or assaulted Vasquez.

On or about April 12, 2019, Natalia Titova (“Titova”), a former dancer and employee of Sapphire,

sat for a deposition (“Titova Depo”) in a lawsuit she filed against Sapphire, James Mark Talla,

Jeffrey Wasserman, and Glen Peter Bernardi. This matter was held before Arbitrator Martin F.

Scheinman.

During the Titova Depo, Plaintiff and Wright were named as “Hosts” who allegedly sexually

harassed and or assaulted Titova.

At the end of their arbitrations, Vasquez and Titova were awarded a total of $1,375,000.00.

On or about December 2016, Plaintiff filed a lawsuit against Sapphire (“P. Sapphire lawsuit”) and

David Michael Talla for FLSA and the regulations thereto; and according to the NYLL (§ 650 et

seq.) and the New York Commissioner of Labor’s Wage Order (the “Wage Orders,”) codified at 12

N.Y.C.R.R. 146 et seq., based upon the following acts and/or omissions which Defendants

committed: i. Defendants' failure to compensate Plaintiff for all hours worked at the statutory

minimum wage as required by federal and state law and regulations; ii. Defendant's failure to

provide Plaintiff with spread-of-hours payments under 12 NYCRR 146-1.6 and 137-1.7; iii.

Causes of Action

1. UNJUST ENRICHMENT