Preview
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg1of50 Trans ID: LCV20241514152
Ty Hyderally, Esq. (ID# 023231993)
HYDERALLY & ASSOCIATES, P.C.
33 PLYMOUTH STREET, STE. 202
MONTCLAIR, NEW JERSEY 07042
TELEPHONE (973) 509-8500
FACSIMILE (973) 509-8501
Attorneys for Plaintiff: Jevon Evans
JEVON EVANS, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: ESSEX COUNTY
PLAINTIFF, DOCKET NO.:
VS. CIVIL ACTION
BIG EASY CAMERA, LLC, JOHN DOES
1-10, AND XYZ CORP. 1-10, COMPLAINT AND JURY DEMAND
DEFENDANTS.
Plaintiff, Jevon Evans (“Evans” or “Plaintiff’), residing at 515 Elizabeth Ave., Newark, NJ
07112, Essex County by way of his Complaint against Defendant, Big Easy Camera, LLC (“Big
Easy’), John Does 1-10, and XYZ Corp. 1-10 (hereinafter collectively the “Defendants”) hereby
says:
I. Nature of Action, Jurisdiction, and Venue
This is an action seeking equitable and legal relief for: (1) a violation of the Conscientious
Employee Protection Act, N.J.S.A. 34:19-1, et seg. (“CEPA”); (2) a violation of the New
Jersey Wage and Hour Law, N.J.S.A. 34:11-56a et seq. (“NJWHL”); (3) a violation of the
New Jersey Wage Payment Act, N.J.S.A. 34:11-4.1, et seg. (‘NJWPA”); (4) breach of
express contract; and (5) breach of the implied covenant of good faith and fair dealing.
This court has jurisdiction due to the nature of the action and the amount in controversy.
Additionally, Plaintiff
has satisfied all prerequisites to bringing these claims.
Venue is appropriate in this court since Plaintiff resided in Essex County, New Jersey
during the relevant time period, the Defendants do business in Essex County, New Jersey,
and some or all of the causes of action accrued in Essex County, New Jersey.
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Il. Parties
During the relevant time period, Mr. Evans was an employee of Big Easy and worked in
the State of New Jersey.
Big Easy is a camera and photographic supply store with a business address at 40-50
Montgomery St., Hillside, NJ 07205.
Big Easy does business throughout New Jersey.
During the relevant time period, Eddie (last name unknown) was a manager at Big Easy.
Thus, during the relevant time period, Eddie was a member of management who controlled
Plaintiff's workplace, supervised Plaintiff, and (1) aided the employer in performing a
wrongful act that caused an injury; (2) was generally aware of his role as part of an illegal
or tortious activity at the time she provided assistance; and (3) knowingly and substantially
assisted the employer in the principal violation of the statutes referenced herein.
At all times referred to in this complaint, employees of the corporate defendant who are
referred to herein, were acting within the scope of their employment at the workplace
during working hours, or the corporate defendant ratified, embraced, and added to their
conduct to the extent that their actions exceeded the scope of their employment.
10. During the relevant time period, JOHN DOES 1-10 are currently unknown employees who
were either senior management level employees who controlled Plaintiff's workplace, and
supervised Plaintiff and aided and/or abetted in the commission of conduct complained of
herein and/or who either acted within the scope of their employment at the workplace
during working hours, or, to the extent they went beyond the scope of their employment,
defendants ratified, embraced and added to this conduct. As the parties engage in
discovery, Plaintiff retains the right to amend the Complaint to add these individual
employees by name.
11 During the relevant time period, XYZ Corp. 1-10 are unknown affiliated corporations or
entities or other corporations who have liability for the claims set forth herein. As the
parties engage in discovery, Plaintiff retains the right to amend the Complaint to add these
individual entities by name.
12. Thus, all the defendants are subject to suit under the statutes alleged above.
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Til. Factual Allegation:
13 On or about July 2019, Mr. Evans was hired by Big Easy.
14 Mr. Evans was hired to work in their warehouse, where he was responsible for loading and
unloading delivery trucks, shipping, and other warehouse job-related duties.
15 Mr. Evans was hired with a starting salary of $12.00/$13.00 per hour working an average
of 40 hours per week with overtime as needed.
16. Mr. Evans performed his duties in an exemplary fashion and consistently met or exceeded
all of Defendants’ legitimate expectations.
17. Due to his stellar performance at Big Easy, Mr. Evans received several raises.
18 On or about October 2022, Mr. Evans was given a raise to $16.00 an hour.
19. In approximately July 2023, Defendants started to pay Mr. Evans a weekly bonus of
$50.00, due to his exemplary performance. (Exhibit “1”).
20. In January 2023, Mr. Evans noticed the company was hiring illegal workers in the
warehouse.
21 Mr. Evans complained to management, including his supervisor Eddie, the Owner, Luis,
and the Operation Manager, Sam, and advised that it was wrong and illegal to hire illegal
immigrants.
22. Defendants got increasingly irritated with Mr. Evans’ complaints and told him to mind his
own business and just focus on work.
23 Defendants retaliated against Mr. Evans by cutting his hours from 40 hours to 37 hours.
(Exhibit “2”).
24 Mr. Evans protested the retaliatory action and the fact that hiring undocumented workers
violated the law; however, Defendants refused to take curative action.
25 Because the situation was not remediated, Mr. Evans reiterated his complaints from May
to July 2023 about Defendants’ illegal action.
26. Thus, during the time period of July 2023 to September 2023, Mr. Evans contacted U.S.
Immigration and Customs Enforcement (“ICE”) to report the immigration violations.
27. However, no changes occurred at the workplace, even as late as September 2023.
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28, Thus, in late September 2023, Mr. Evans had a conversation with Sam and told him that it
was not only illegal but also unfair what the Big Easy was doing.
29, Sam once again got angry at Mr. Evans for raising the issue again and advised that the
company could do whatever it wanted and hire whomever it wanted.
30. Mr. Evans responded that he doubted ICE would agree with him and shared that he had
already contacted ICE and informed them of the company’s illegal actions.
31 Sam terminated the conversation and stormed away.
32. Mr. Evans subsequently informed Eddie that he was concerned about his job as he had
admitted to Sam that he contacted ICE and informed them of the company’s illegal actions
and that Sam was very angry at Mr. Evans.
33 Eddie was furious with Mr. Evans for doing this, and informed him he would be talking to
Luis, the owner.
34, On Tuesday October 3, 2023, around 9am, Eddie approached Mr. Evans and demanded
that he took over an undocumented worker, Yamira’s workload, while he continued to do
his own workload.
35 Mr. Evans asked for the reason why he was told to Yamari’s work as well as his own.
36. Eddie replied with words to the effect of this is what you get when you complain about
undocumented workers.
37. When Mr. Evans took issue with the retaliatory act, Eddie demanded that he punch out and
go home.
38, Mr. Evans asked for documentation as to why he was being sent home.
39, Eddie then spoke to Sam who approached Mr. Evans with a typed-out statement that
referred to Sam as Human Resources.
40. Sami demanded that Mr. Evans sign the statement that read, “The Reason Why He Let Him
Go Because He Told Him to do The work And he Told Him This Not My Job. (Exhibit
“3”,
41 Mr. Evans advised this was untrue and went through the details of his interaction with
Eddie.
42. Sam reiterated that this is the statement Eddie wanted Mr. Evans to sign.
43 Sam then edited the note to read that Mr. Evans was asked to do someone else’s work.
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44 Because the statement did not reflect what occurred and because Sam refused to make the
statement a truthful and comprehensive statement, Mr. Evans refused to sign the statement.
45 Mr. Evans then did as directed, punched out, and went home.
46 Mr. Evans then texted the Owner, Luis, at 9:22am on October 3, 2023, and asked to meet
as Eddie sent him home. (See Exhibit “4”).
47 Luis responded at 9:40am that he would make time for him the following week. (See
Exhibit “5”).
48, At 9:43am on October 3, 2023, Mr. Evans then texted the Owner, Luis, and informed him
that the workers wanted to meet with Eddie to resolve a BIG issue that they were having
at work, and Eddie refused. (See Exhibit “6”).
49 Luis responded that he would meet him the following Tuesday, October 10, 2023. (See
Exhibit “7”).
50. At 6:35pm on October 3, 2023, Eddie texted Mr. Evans to advise that he should take the
rest of the week off and call him on Monday before he returned to work. (See Exhibit “8”).
51 Mr. Evans asked for paperwork and Eddie replied there was no need. (See Exhibit “9”).
52. At 6:40pm on October 3, 2023, Mr. Evans texted Luis and advised that he received a text
from Eddie telling him to take the rest of the week of and call him before he returned to
work. (See Exhibit “10”).
53 Luis responded at 8:33pm on October 3, 2023, “had no idea let me talk to him mad circle
back on Tuesday when we are scheduled to talk. (See Exhibit “11”’).
54, At 8:50pm on October 3, 2023, Mr. Evans acknowledged Luis’ phone call. (See Exhibit
“12").
55 On Sunday, October 8, 2023, at 10:03pm, Eddie texted Mr. Evans and advised that they
did not need him the next day. (See Exhibit “13”).
56. Mr. Evans responded at 10:04pm and asked for the reason or for any paperwork. (See
Exhibit “14”).
57. He received crickets from Eddie.
58 Further, Mr. Evans received no further text messages from Luis.
59, Instead, Defendants engaged in the ultimate act of retaliation.
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60. On Monday October 9, 2023, at 10:14am, Sam H. a/k/a Sam a/k/a Sami, sent an email, that
referred to himself as the Operation Manager, to Mr. Evans. (See Exhibit “15”).
61 The email had a termination letter, dated Friday October 6, 2023, attached to the October
9, 2023, letter. (See Exhibit “16”).
62. The letter had numerous falsehoods and was clearly retaliatory for Mr. Evans engaging in
whistleblowing actions.
63 The letter noted that Mr. Evans would continue to be employed for two weeks from the
date of the letter which meant October 20, 2023.
64. The letter further stated that his last paycheck would be on October 3, 2023.
65 The letter further thanked Mr. Evans for the time he spent at Big Easy Camera LLC.
66. Defendants then violated their contractual obligation and did not pay Mr. Evans beyond
67. Further Defendants’ failure to pay Mr. Evans violated the New Jersey Wage and Hour
laws.
68. Defendants’ own paystubs reflects their violation of law.
69. Defendants sent Mr. Evans his last 3 paychecks which reflected a pay period of September
17, 2023, until September 23, 2023, pay period of September 24, 2023, until September
30, 2023, and October 1, 2023, until October 7, 2023. (See Composite Exhibit “17”).
70. The last paycheck that Mr. Evans received had a pay date of October 10, 2023, and
reflected a year-to-date salary of $23,959.44. (See Exhibit “18”).
71 Interestingly and tellingly, Defendants paid Mr. Evans his work performance bonus in the
last three paychecks they issued.
72. Despite the fact that the termination letter referenced performance issues, there is not one
document Mr. Evans ever received that criticized his performance over the 4 % years of
his employment.
73 During the 4 % years of his employment, Mr. Evans received salary increases and then a
weekly performance bonus starting in approximately July 2023 until October 7, 2023.
74, During the 4 % years of his employment, Mr. Evans was never reprimanded.
75 During the 4 % years of his employment, Mr. Evans was never disciplined.
76. During the 4 % years of his employment, Mr. Evans was never written up.
77. During the 4 % years of his employment, Mr. Evans was never suspended.
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78. During the 4 % years of his employment, Mr. Evans was never demoted.
79. During the 4 % years of his employment, Mr. Evans was never put on a performance
improvement plan.
80. The above facts reflect that rather than take curative action, Defendants retaliated against
Mr. Evans for objecting to Defendants’ illegal practices and terminating Mr. Evans’
employment on October 2023.
81 This retaliatory act by Defendants creates and satisfies the specific factual predicate for the
CEPA violation alleged herein.
82. At the time of his termination on October 3, 2023, Mr. Evans was receiving compensation
that exceeded $35,000 per year if Defendants had not engaged in the retaliatory act of
cutting his hours from 40 hours per week to 37 hours per week.
83 Further, Defendants provided Mr. Evans paid time off and other benefits of employment.
Count I
(CEPA)
84. Mr. Evans realleges and incorporates herein the paragraphs set forth in this Complaint,
unless noted below.
85 Mr. Evans reasonably believed that Defendants were violating either a law, regulation, or
a clear mandate of public policy by the hiring of illegal workers in contravention of State
and Federal law.
86. Thus, Plaintiff reasonably believed that the employer's conduct was violating either a law,
government regulation, or a clear mandate of public policy.
87 Second, Plaintiff refused to participate or objected to this unlawful conduct, and advocated
compliance with not violating the law to the employer. Plaintiff did so by either (a)
pursuing and exhausting all internal means of securing compliance; or (b) refusing to
participate in the objectionable conduct.
88 Third, Plaintiff suffered an adverse employment action.
89 Fourth, Defendants retaliated against Plaintiff because Plaintiff did one or more of the
following:
(a) disclosed or threatened to disclose to a supervisor or a public body an activity, policy
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or practice of the employer or another employer, with whom there is a business
relationship, that the Plaintiff reasonably believed is in violation of a law, or a rule or
regulation promulgated pursuant to law;
(b) Provided information to, or testified before, any public body conducting an
investigation, hearing or inquiry into any violation of law, or a rule or regulation
promulgated pursuant to law by the employer or another employer, with whom there is
a business relationship; or
(c) Objected to, or refused to participate in an activity, policy or practice which Plaintiff
reasonably believed:
i) is in violation of a law, or a rule or regulation promulgated pursuant to law or
ii) is fraudulent or criminal; or
ili) is incompatible with a clear mandate of a public policy concerning the health,
safety, or welfare or protection of the environment.
90. The above actions of Defendants demonstrate that they are in violation of CEPA.
91 The facts supporting the CEPA violation do not touch upon the other claims pled in this
complaint.
92 Additionally, the facts supporting the CEPA violation are separate and distinct from the
facts supporting the other counts set forth below.
93 As a direct and proximate result of the actions of Defendants, Plaintiff
has suffered mental
anguish, physical discomfort, pain and suffering, shame and embarrassment, emotional
distress injuries, the physical manifestation of emotional distress injuries and/or physical
injury. Furthermore, Plaintiff has suffered lost wages, a diminished ability to earn a living,
and a diminished capacity to enjoy Plaintiff's life. Moreover, Plaintiff
has and/or may have
to incur expenses for medical, psychiatric, and/or psychological counseling and care.
Plaintiff's damages have been experienced in the past, and they will continue into the
future.
94. Further, Plaintiff has been required to retain an attorney to assist Plaintiff in asserting
Plaintiff's claims and protecting Plaintiff's rights.
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Count I
(New Jersey Wage and Hour Law, N.J.S.A. 34:11-56a et seq.)
95 Plaintiff realleges and incorporates herein the paragraphs set forth in this Complaint.
96. The actions of Defendants give rise to violations of the New Jersey Wage and Hour Law.
97. Additionally, Defendants failed to make, keep or preserve any records as required under
this statute.
98, Further, Defendants failed to pay defendant his lawful wages.
99, Defendants’ actions to violate the law were done intentionally and with malice.
100. Further, Plaintiff has been required to retain counsel to assist Plaintiff in asserting
Plaintiff's claims and protecting Plaintiff's rights.
Count Hl
(New Jersey Wage Payment Act, N.J.S.A. 34:11-4.1, et seq.)
101 Plaintiff realleges and incorporates herein the paragraphs set forth in this Complaint.
102 The actions of Defendants give rise to a violation of the New Jersey Wage Payment Act.
103 Under N.J.S.A. 34:11-4.2, every employer shall pay the full amount of wages due to his
employees at least twice during each calendar month, on regular pay days designated in
advance by the employer, in lawful money of the United States or with checks on banks
where suitable arrangements are made for the cashing of such checks by employees without
difficulty and for the full amount for which they are drawn.
104, Defendants failed to pay Plaintiff
his full amount of wages when lawfully due.
105. Further, Plaintiff has been required to retain an attorney to assist Plaintiff in asserting
Plaintiff's claims and protecting Plaintiff's rights.
Count IV
(Breach of Express Contract)
106. Plaintiff realleges and incorporates herein the paragraphs set forth in this Complaint.
107 Defendants had contractual obligations to Plaintiff that were set forth in their termination
letter.
108 Defendants’ actions breached the contractual obligations set forth in this document.
109 Defendants’ actions give rise to the claim of breach of express contract.
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110. As a direct and proximate result of the actions of Defendants, Plaintiff has been damaged.
Count V
(Breach of the Implied Covenant of Good Faith and Fair Dealing)
111. Plaintiff realleges and incorporates herein the paragraphs set forth in this
Complaint.
112 Defendants had contractual obligations to Plaintiff as reflected above.
113 Defendants have breached these obligations.
114, Defendants’ actions give rise to the claim of breach of the implied covenant of good faith
and fair dealing.
115 As a direct and proximate result of the actions of Defendants, Plaintiff has been damaged.
WHEREFORE, as to each and every count, Plaintiff demands judgment on each and all of these
Counts against the Defendants jointly and severally, as follows:
A Compensatory damages of not less than $600,000;
B Damages for lost wages and benefits, back pay, front pay (or reinstatement);
Cc Damages for humiliation, mental and emotional distress;
Statutory damages, if applicable;
Punitive damages and or liquidated damages, where permitted by law;
Attorneys’ fees and costs of suit;
Lawful interest including pre-judgment interest on lost wages;
Lawful interest - including pre-judgment interest on any wages not paid in a timely
manner; and
Such other, further and different relief as the Court deems fitting, just and proper.
Plaintiff hereby reserves the right to amend this Complaint to supplement or modify the factual
obligations and claims contained herein, based upon information received from the defendants,
witnesses, experts, and others in the course of discovery in this matter.
DEMAND FOR TRIAL BY JURY
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Pursuant to Rule 4:35-1(a) and (b), Plaintiff respectfully demands a trial by jury on all
issues in the within action so triable.
DESIGNATION OF TRIAL COUNSEL
In accordance with Rule 4:25-4, TY HYDERALLY is hereby designated as trial counsel
on behalf of Plaintiff.
R. 4:5-1(b)(2) CERTIFICATION OF NO OTHIS ACTIONS OR PARTIES
Thereby certify that the matter in controversy is not the subject of any other action pending in any
court or of a pending arbitration proceeding, that no other action or arbitration proceeding is
contemplated, and that there are no other parties known to me at this time who should be joined as
parties to this action.
DEMAND FOR PRODUCTION OF INSURANCE AGREEMENTS
Pursuant to R. 4:10-2(b), demand is hereby made that you disclose to the undersigned
whether there are any insurance agreements or policies under which any person or firm carrying
on an insurance business may be liable to satisfy all or part of a judgment which may be entered
in the action or to indemnify or reimburse for payment made to satisfy the judgment.
If so, please attach a copy of each, or in the alternative state, under oath and certification:
(a) policy number; (b) name and address of insurer; (c) inception and expiration date; (d) names
and addresses of all persons insured thereunder; (e) personal injury limits; (f) property damage
limits; and (g) medical payment limits.
DATED: June 17, 2024 HYDERALLY & ASSOCIATES, P.C.
Attorneys for Plaintiff
By:
TY HYDERALLY, Esq.
For the Firm
‘\Evans Jevon\Pleadings\042424.COM.docx
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EXHIBIT 1
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7
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EXHIBIT 2
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7
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EXHIBIT 3
a
feet
ws
aT
Big Easy Camera
fo?
As Per Off Eddie Let Jevon Go Home 7
The Reason Why He Let Him Go Because He =
ise Weckdtack And ihe\tokd Him This Not My Job.
he Human Reso rc
sta
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg18o0f50 Trans ID: LCV20241514152
EXHIBIT 4
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg190f50 Trans ID: LCV20241514152
2:28 S&B 2946
Luis(Owner Of Job)
(917) 414-8330
Hee
Oct 3, 9:51AM
Ok let's meet Tuesday next week
Tue 6:40PM
ESYo)
gam (omel (idels om VColUM oO lm (UTS
cerca -Xem-Mt-bdm column =e (01 (1
Wa NAL elaR C1. Ua MC) eM)
WWictsl.@eni mere] MnatcMela mY Lelaterey
lo -a(o] come]0 kere) aa KOM Ve ae
Tue 8:33PM
had no idea let me talk to him
mad circle back on Tuesday
when we are scheduled to talk
Tue 8:50PM
+ Send message
©
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 200f50 Trans ID: LCV20241514152
EXHIBIT 5
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 210f50 Trans ID: LCV20241514152
4268808 77110 - 3d B
Luis(Owner Of Job)
(917) 414-8330 @
10/3/23, 9:40AM
Good morning Jevon, really sorry
to hear that | had no idea as you
know, | have little involvement in
the warehouse and | really do
not keep up with day to day nor
do | even work in the same
facility... i'll try and make time
next week to meet with you and
come in special Let me know
what day is good for you. Thank
you
10/3/23, 9:43AM
NACE AN 4a 1-4 Ol Com BAO) 7
Nols Coli mM 7-FoMalcoldual-teme)'Act- ln]
EVavoM ato(e(Wim Mat -MUVo) al ecm ia (comico)
Eq stelel(-miolae-M an--1tlnlem ce)
Ie-soxe) MMe Ws} [MSU Mtge] MMI
lacixeael ale atomcre](¢ Maem Mile]eM WVaNVAl
Tan merelanl (are m CoM (eLUR i leciml (o\-1-m
NicMer:lame (=) Maal lare ow iamenge(=1s
10/3/23, 9:51AM
Ok let's meet Tuesday next week
E>,
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EXHIBIT 6
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 23 0f50 Trans ID: LCV20241514152
4268808 77110 - 3d B
Luis(Owner Of Job)
(917) 414-8330 @
10/3/23, 9:40AM
Good morning Jevon, really sorry
to hear that | had no idea as you
know, | have little involvement in
the warehouse and | really do
not keep up with day to day nor
do | even work in the same
facility... i'll try and make time
next week to meet with you and
come in special Let me know
what day is good for you. Thank
you
10/3/23, 9:43AM
NACE AN 4a 1-4 Ol Com BAO) 7
Nols Coli mM 7-FoMalcoldual-teme)'Act- ln]
EVavoM ato(e(Wim Mat -MUVo) al ecm ia (comico)
Eq stelel(-miolae-M an--1tlnlem ce)
Ie-soxe) MMe Ws} [MSU Mtge] MMI
lacixeael ale atomcre](¢ Maem Mile]eM WVaNVAl
Tan merelanl (are m CoM (eLUR i leciml (o\-1-m
NicMer:lame (=) Maal lare ow iamenge(=1s
10/3/23, 9:51AM
Ok let's meet Tuesday next week
E>,
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EXHIBIT 7
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 250f50 Trans ID: LCV20241514152
4268808 77110 - 3d B
Luis(Owner Of Job)
(917) 414-8330 @
10/3/23, 9:40AM
Good morning Jevon, really sorry
to hear that | had no idea as you
know, | have little involvement in
the warehouse and | really do
not keep up with day to day nor
do | even work in the same
facility... i'll try and make time
next week to meet with you and
come in special Let me know
what day is good for you. Thank
you
10/3/23, 9:43AM
NACE AN 4a 1-4 Ol Com BAO) 7
Nols Coli mM 7-FoMalcoldual-teme)'Act- ln]
EVavoM ato(e(Wim Mat -MUVo) al ecm ia (comico)
Eq stelel(-miolae-M an--1tlnlem ce)
Ie-soxe) MMe Ws} [MSU Mtge] MMI
lacixeael ale atomcre](¢ Maem Mile]eM WVaNVAl
Tan merelanl (are m CoM (eLUR i leciml (o\-1-m
NicMer:lame (=) Maal lare ow iamenge(=1s
10/3/23, 9:51AM
Ok let's meet Tuesday next week
E>,
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EXHIBIT 3
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2:24 & 3940
Manager Eddie
(917) 717-1780
Tue 6:35PM
Hey Jevon take the rest of the
week off call me on Monday
before you come To work
Mal-x-XeR-Ye)an(my ox ROLMN ALA CUn
er olla fel.
No need
Tue 6:38PM
a
Sun 10:03PM
Hi Jevon we don't need you
tomorrow
thank you
Sun 10:04PM
+ Send nes
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EXHIBIT 9
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2:24 & 3940
Manager Eddie
(917) 717-1780
Tue 6:35PM
Hey Jevon take the rest of the
week off call me on Monday
before you come To work
Mal-x-XeR-Ye)an(my ox ROLMN ALA CUn
er olla fel.
No need
Tue 6:38PM
a
Sun 10:03PM
Hi Jevon we don't need you
tomorrow
thank you
Sun 10:04PM
+ Send nes
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 300f50 Trans ID: LCV20241514152
EXHIBIT 10
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 310f50 Trans ID: LCV20241514152
4277 88 Oe HHG-: $id B
Luis(Owner Of Job)
(917) 41 4-830 @
3
eeee
10/3/23, 9:51AM
Ok let's meet Tuesday next week
10/3/23, 6:40PM
ESTo)
gam (omel (idels om Vole MoU lm (UTS)
Ig-Xex-1hV-Xe Me cy am cola x0(0(=)
WN AL elaR 1. Cm aM) MOLL)
WWictel.@eni mete] Mant-Mela mY celaterey
lo -3(o]km 0]0 kere) gai KOM Vel ae
10/3/23, 8:33PM
had no idea let me talk to him
mad circle back on Tuesday
when we are scheduled to talk
10/3/23, 8:50PM
| + Send message
©
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 320f50 Trans ID: LCV20241514152
EXHIBIT 11
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 33 0f50 Trans ID: LCV20241514152
4277 88 Oe HHG-: $id B
Luis(Owner Of Job)
(917) 41 4-830 @
3
eeee
10/3/23, 9:51AM
Ok let's meet Tuesday next week
10/3/23, 6:40PM
ESTo)
gam (omel (idels om Vole MoU lm (UTS)
Ig-Xex-1hV-Xe Me cy am cola x0(0(=)
WN AL elaR 1. Cm aM) MOLL)
WWictel.@eni mete] Mant-Mela mY celaterey
lo -3(o]km 0]0 kere) gai KOM Vel ae
10/3/23, 8:33PM
had no idea let me talk to him
mad circle back on Tuesday
when we are scheduled to talk
10/3/23, 8:50PM
| + Send message
©
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 340f50 Trans ID: LCV20241514152
EXHIBIT 12
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 350f50 Trans ID: LCV20241514152
4277 88 Oe HHG-: $id B
Luis(Owner Of Job)
(917) 41 4-830 @
3
eeee
10/3/23, 9:51AM
Ok let's meet Tuesday next week
10/3/23, 6:40PM
ESTo)
gam (omel (idels om Vole MoU lm (UTS)
Ig-Xex-1hV-Xe Me cy am cola x0(0(=)
WN AL elaR 1. Cm aM) MOLL)
WWictel.@eni mete] Mant-Mela mY celaterey
lo -3(o]km 0]0 kere) gai KOM Vel ae
10/3/23, 8:33PM
had no idea let me talk to him
mad circle back on Tuesday
when we are scheduled to talk
10/3/23, 8:50PM
| + Send message
©
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 36 0f50 Trans ID: LCV20241514152
EXHIBIT 13
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 37 0f50 Trans ID: LCV20241514152
2:24 & 3940
Manager Eddie
(917) 717-1780
Tue 6:35PM
Hey Jevon take the rest of the
week off call me on Monday
before you come To work
Mal-x-XeR-Ye)an(my ox ROLMN ALA CUn
er olla fel.
No need
Tue 6:38PM
a
Sun 10:03PM
Hi Jevon we don't need you
tomorrow
thank you
Sun 10:04PM
+ Send nes
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 38 0f50 Trans ID: LCV20241514152
EXHIBIT 14
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 390f50 Trans ID: LCV20241514152
2:24 & 3940
Manager Eddie
(917) 717-1780
Tue 6:35PM
Hey Jevon take the rest of the
week off call me on Monday
before you come To work
Mal-x-XeR-Ye)an(my ox ROLMN ALA CUn
er olla fel.
No need
Tue 6:38PM
a
Sun 10:03PM
Hi Jevon we don't need you
tomorrow
thank you
Sun 10:04PM
+ Send nes
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 40 0f50 Trans ID: LCV20241514152
EXHIBIT 15
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 410f50 Trans ID: LCV20241514152
— Forwarded Message aoe
From: "Sam H"
To:
Ce:
'Jevon Evans" <_a >
Sent: Wed, Oct 11, 2023 at 1:21 PM
Subject: Re: terminate
here you go
On Tue, Oct 10, 2023 at 12:55 AM Jevon Evans Ei wrote:
Okay. | need my last 2 paystubs and my last paycheck
Sent from Yahoo Mail on Android
On Mon, Oct 9, 2023 at 10:14 AM, Sam H
wrote:
hello Jevon
terminate letter attached
-
Thanks & best regards,
SAM .H
Power Photo Corp
40-50 Montgomery St
Hillside, NJ 07205
Office: 718-502-6178
Cell: 917-442-9402
Email: samh@powerphotocorp.com
This email, together with any attachment, is for the exclusive and confidential use
of the addressee(s) and may contain legally privileged information. Any other distribution, use or
reproduction without the sender's prior consent is unauthorized and strictly prohibited If you have
received this message in error, please notify the sender by email immediately and delete the
message from your computer without making any copies
-
Thanks & best regards,
SAM .H
Power Photo Corp
40-50 Montgomery St
Hillside, NJ 07205
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 42 0f50 Trans ID: LCV20241514152
Office: 718-502-6178
Cell: 917-442-9402
Email: samh@powerphotocorp.com
This email, together with any attachment, is for the exclusive and confidential use
of the addressee(s) and may contain legally privileged information. Any other distribution, use or
reproduction without the sender's prior consent is unauthorized and strictly prohibited If you have
received this message in error, please notify the sender by email immediately and delete the
message from your computer without making any copies
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 43 0f50 Trans ID: LCV20241514152
EXHIBIT 16
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 440f50 Trans ID: LCV20241514152
Big Easy Camera LLC,
40-50 Montgomery St
Hillside NJ 07205
718-502-6178
Dear Jevon Evans
| hope this letter finds you well. | am writing to address a matter that has come to our attention
regarding your performance and job responsibilities here at Big Easy Camera LLC
It has come to our notice that you have consistently not been performing your job duties and
have been unwilling to fulfill the responsibilities that are expected as part of your role. At Big
Easy Camera LLC, we have a clear set of job expectations, and it is essential that every team
member contributes to the success of the organization by fulfilling their role.
Despite our previous discussions and attempts to address the issue, we have not seen the
improvement we expected. As a result, we have regrettably decided to terminate your
employment with Big Easy Camera LLC, effective last working day, typically two weeks from the
date of the letter.
During your notice period, you will be expected to mention any specific tasks or handovers. You
will receive your final paycheck on, date 10/3/2023.
Please arrange to return any company property, keys, documents, or any other items in your
possession by a specific date and instructions for returning company property.
Will Be available to assist you with any questions you may have regarding your final paycheck, or
any other related matters.
We understand that this news may be difficult, and we want to thank you for the time you have
spent at Big Easy Camera LLC. We wish you the best in your future endeavors.
Operation Manger
Sam H 10/6/2023
SH
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 45 o0f50 Trans ID: LCV20241514152
EXHIBIT 17
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 46 0f50 Trans ID: LCV20241514152
Aa?
Number P. e
RB Tot
G S487
24957717 0 4071949 1 of 1
Earnings Statement
Big Easy Cameras LLC
40-50 Montgomery St Period Starting: 09/17/2023
Hillside, NJ 07205-1131 Period Ending: 09/23/2023
Pay Date: 09/26/2023
‘Taxable Marital Status: Single
Exemptions/Allowances’ Tax Override: Jevon Evans
Federal: 2 Federal
State: 2 State:
Local
Social Security Number: HK IRI
Eamings rate hours/units this period year to date Other Benefits and
Regular 16.0000 38.33 613.28 21880.48 Information this period year to date
Overtime 0.00 78.48 Sick
Sick 0.00 384.00 ~ Carry Over 0.00
Personal 48.00 ~ Accrued Hours, 0.00 40.00
Bonus 0.00 50.00 500.00 + Taken Hours 0.00 24.00
= Balance 16.00
Gross Pay $663.28 $22,890.96 Total Hours Worked 38,33 1370.80
its
account number transiVABA amount.
Statutory Deductions this. to date XXXXXX9295 XXXXXKAXX, 335.35
Federal Income -43.40 341.61
Social Security “41.12 1419.24 Important Notes
Medicare -9.62 331.92 Basis of pay: Hourly
New Jersey State Income -10.57 353.71
New Jersey Stata Ul ~2.82 97.29
New Jersey State DI 0.00 0.00
New Jersey FLI 13.73
Voluntary Deductions this period year to date
Child support 1 -120.00 4000.00
Child support 2 -100.00 3000.00
Net Pay $335.35
Your federal taxable wages this period are $663.28
Big Easy Cameras LLC
40-50 Montgomery St Pay Date:
Hillside, NJ 07205-1134 09/26/2023
o
spe
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Deposited to the account yumi a Sass dl
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Checking DirectDeposit 5 + XXX, 195 XXAKKKAXK 335.35
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Jevon Evans
50 Blum
Newark, NJ 07103
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 47 o0f50 Trans ID: LCV20241514152
Germany Code
Ror
cote,
24957717
Big Easy Cameras LLC
40-50 Montgomery St
Loci
01/7 soa Tah Earnings Statement
Period Starting: 09/24/2023
AX?
Hillside, NJ 07205-1131 Period Ending: 99/30/2023
Pay Date: 10/03/2023
‘Taxable Marital Status: Single
Exemptions/Allowances: Tax Override: Jevon Evans
Federal 2 Federal:
State: 2 State:
Social Seairiy Number: 10 RIOUX
Eamings rale hours/units this period year
to date Other Benefits and
Regular 16.0000
Preview
ESX-L-004123-24 06/17/2024 12:26:57 PM Pg1of50 Trans ID: LCV20241514152 Ty Hyderally, Esq. (ID# 023231993) HYDERALLY & ASSOCIATES, P.C. 33 PLYMOUTH STREET, STE. 202 MONTCLAIR, NEW JERSEY 07042 TELEPHONE (973) 509-8500 FACSIMILE (973) 509-8501 Attorneys for Plaintiff: Jevon Evans JEVON EVANS, SUPERIOR COURT OF NEW JERSEY LAW DIVISION: ESSEX COUNTY PLAINTIFF, DOCKET NO.: VS. CIVIL ACTION BIG EASY CAMERA, LLC, JOHN DOES 1-10, AND XYZ CORP. 1-10, COMPLAINT AND JURY DEMAND DEFENDANTS. Plaintiff, Jevon Evans (“Evans” or “Plaintiff’), residing at 515 Elizabeth Ave., Newark, NJ 07112, Essex County by way of his Complaint against Defendant, Big Easy Camera, LLC (“Big Easy’), John Does 1-10, and XYZ Corp. 1-10 (hereinafter collectively the “Defendants”) hereby says: I. Nature of Action, Jurisdiction, and Venue This is an action seeking equitable and legal relief for: (1) a violation of the Conscientious Employee Protection Act, N.J.S.A. 34:19-1, et seg. (“CEPA”); (2) a violation of the New Jersey Wage and Hour Law, N.J.S.A. 34:11-56a et seq. (“NJWHL”); (3) a violation of the New Jersey Wage Payment Act, N.J.S.A. 34:11-4.1, et seg. (‘NJWPA”); (4) breach of express contract; and (5) breach of the implied covenant of good faith and fair dealing. This court has jurisdiction due to the nature of the action and the amount in controversy. Additionally, Plaintiff has satisfied all prerequisites to bringing these claims. Venue is appropriate in this court since Plaintiff resided in Essex County, New Jersey during the relevant time period, the Defendants do business in Essex County, New Jersey, and some or all of the causes of action accrued in Essex County, New Jersey. ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 2of50 Trans ID: LCV20241514152 Il. Parties During the relevant time period, Mr. Evans was an employee of Big Easy and worked in the State of New Jersey. Big Easy is a camera and photographic supply store with a business address at 40-50 Montgomery St., Hillside, NJ 07205. Big Easy does business throughout New Jersey. During the relevant time period, Eddie (last name unknown) was a manager at Big Easy. Thus, during the relevant time period, Eddie was a member of management who controlled Plaintiff's workplace, supervised Plaintiff, and (1) aided the employer in performing a wrongful act that caused an injury; (2) was generally aware of his role as part of an illegal or tortious activity at the time she provided assistance; and (3) knowingly and substantially assisted the employer in the principal violation of the statutes referenced herein. At all times referred to in this complaint, employees of the corporate defendant who are referred to herein, were acting within the scope of their employment at the workplace during working hours, or the corporate defendant ratified, embraced, and added to their conduct to the extent that their actions exceeded the scope of their employment. 10. During the relevant time period, JOHN DOES 1-10 are currently unknown employees who were either senior management level employees who controlled Plaintiff's workplace, and supervised Plaintiff and aided and/or abetted in the commission of conduct complained of herein and/or who either acted within the scope of their employment at the workplace during working hours, or, to the extent they went beyond the scope of their employment, defendants ratified, embraced and added to this conduct. As the parties engage in discovery, Plaintiff retains the right to amend the Complaint to add these individual employees by name. 11 During the relevant time period, XYZ Corp. 1-10 are unknown affiliated corporations or entities or other corporations who have liability for the claims set forth herein. As the parties engage in discovery, Plaintiff retains the right to amend the Complaint to add these individual entities by name. 12. Thus, all the defendants are subject to suit under the statutes alleged above. 2 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 3of50 Trans ID: LCV20241514152 Til. Factual Allegation: 13 On or about July 2019, Mr. Evans was hired by Big Easy. 14 Mr. Evans was hired to work in their warehouse, where he was responsible for loading and unloading delivery trucks, shipping, and other warehouse job-related duties. 15 Mr. Evans was hired with a starting salary of $12.00/$13.00 per hour working an average of 40 hours per week with overtime as needed. 16. Mr. Evans performed his duties in an exemplary fashion and consistently met or exceeded all of Defendants’ legitimate expectations. 17. Due to his stellar performance at Big Easy, Mr. Evans received several raises. 18 On or about October 2022, Mr. Evans was given a raise to $16.00 an hour. 19. In approximately July 2023, Defendants started to pay Mr. Evans a weekly bonus of $50.00, due to his exemplary performance. (Exhibit “1”). 20. In January 2023, Mr. Evans noticed the company was hiring illegal workers in the warehouse. 21 Mr. Evans complained to management, including his supervisor Eddie, the Owner, Luis, and the Operation Manager, Sam, and advised that it was wrong and illegal to hire illegal immigrants. 22. Defendants got increasingly irritated with Mr. Evans’ complaints and told him to mind his own business and just focus on work. 23 Defendants retaliated against Mr. Evans by cutting his hours from 40 hours to 37 hours. (Exhibit “2”). 24 Mr. Evans protested the retaliatory action and the fact that hiring undocumented workers violated the law; however, Defendants refused to take curative action. 25 Because the situation was not remediated, Mr. Evans reiterated his complaints from May to July 2023 about Defendants’ illegal action. 26. Thus, during the time period of July 2023 to September 2023, Mr. Evans contacted U.S. Immigration and Customs Enforcement (“ICE”) to report the immigration violations. 27. However, no changes occurred at the workplace, even as late as September 2023. ESX-L-004123-24 06/17/2024 12:26:57 PM Pg4of50 Trans ID: LCV20241514152 28, Thus, in late September 2023, Mr. Evans had a conversation with Sam and told him that it was not only illegal but also unfair what the Big Easy was doing. 29, Sam once again got angry at Mr. Evans for raising the issue again and advised that the company could do whatever it wanted and hire whomever it wanted. 30. Mr. Evans responded that he doubted ICE would agree with him and shared that he had already contacted ICE and informed them of the company’s illegal actions. 31 Sam terminated the conversation and stormed away. 32. Mr. Evans subsequently informed Eddie that he was concerned about his job as he had admitted to Sam that he contacted ICE and informed them of the company’s illegal actions and that Sam was very angry at Mr. Evans. 33 Eddie was furious with Mr. Evans for doing this, and informed him he would be talking to Luis, the owner. 34, On Tuesday October 3, 2023, around 9am, Eddie approached Mr. Evans and demanded that he took over an undocumented worker, Yamira’s workload, while he continued to do his own workload. 35 Mr. Evans asked for the reason why he was told to Yamari’s work as well as his own. 36. Eddie replied with words to the effect of this is what you get when you complain about undocumented workers. 37. When Mr. Evans took issue with the retaliatory act, Eddie demanded that he punch out and go home. 38, Mr. Evans asked for documentation as to why he was being sent home. 39, Eddie then spoke to Sam who approached Mr. Evans with a typed-out statement that referred to Sam as Human Resources. 40. Sami demanded that Mr. Evans sign the statement that read, “The Reason Why He Let Him Go Because He Told Him to do The work And he Told Him This Not My Job. (Exhibit “3”, 41 Mr. Evans advised this was untrue and went through the details of his interaction with Eddie. 42. Sam reiterated that this is the statement Eddie wanted Mr. Evans to sign. 43 Sam then edited the note to read that Mr. Evans was asked to do someone else’s work. ESX-L-004123-24 06/17/2024 12:26:57 PM Pg5of50 Trans ID: LCV20241514152 44 Because the statement did not reflect what occurred and because Sam refused to make the statement a truthful and comprehensive statement, Mr. Evans refused to sign the statement. 45 Mr. Evans then did as directed, punched out, and went home. 46 Mr. Evans then texted the Owner, Luis, at 9:22am on October 3, 2023, and asked to meet as Eddie sent him home. (See Exhibit “4”). 47 Luis responded at 9:40am that he would make time for him the following week. (See Exhibit “5”). 48, At 9:43am on October 3, 2023, Mr. Evans then texted the Owner, Luis, and informed him that the workers wanted to meet with Eddie to resolve a BIG issue that they were having at work, and Eddie refused. (See Exhibit “6”). 49 Luis responded that he would meet him the following Tuesday, October 10, 2023. (See Exhibit “7”). 50. At 6:35pm on October 3, 2023, Eddie texted Mr. Evans to advise that he should take the rest of the week off and call him on Monday before he returned to work. (See Exhibit “8”). 51 Mr. Evans asked for paperwork and Eddie replied there was no need. (See Exhibit “9”). 52. At 6:40pm on October 3, 2023, Mr. Evans texted Luis and advised that he received a text from Eddie telling him to take the rest of the week of and call him before he returned to work. (See Exhibit “10”). 53 Luis responded at 8:33pm on October 3, 2023, “had no idea let me talk to him mad circle back on Tuesday when we are scheduled to talk. (See Exhibit “11”’). 54, At 8:50pm on October 3, 2023, Mr. Evans acknowledged Luis’ phone call. (See Exhibit “12"). 55 On Sunday, October 8, 2023, at 10:03pm, Eddie texted Mr. Evans and advised that they did not need him the next day. (See Exhibit “13”). 56. Mr. Evans responded at 10:04pm and asked for the reason or for any paperwork. (See Exhibit “14”). 57. He received crickets from Eddie. 58 Further, Mr. Evans received no further text messages from Luis. 59, Instead, Defendants engaged in the ultimate act of retaliation. ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 6of50 Trans ID: LCV20241514152 60. On Monday October 9, 2023, at 10:14am, Sam H. a/k/a Sam a/k/a Sami, sent an email, that referred to himself as the Operation Manager, to Mr. Evans. (See Exhibit “15”). 61 The email had a termination letter, dated Friday October 6, 2023, attached to the October 9, 2023, letter. (See Exhibit “16”). 62. The letter had numerous falsehoods and was clearly retaliatory for Mr. Evans engaging in whistleblowing actions. 63 The letter noted that Mr. Evans would continue to be employed for two weeks from the date of the letter which meant October 20, 2023. 64. The letter further stated that his last paycheck would be on October 3, 2023. 65 The letter further thanked Mr. Evans for the time he spent at Big Easy Camera LLC. 66. Defendants then violated their contractual obligation and did not pay Mr. Evans beyond 67. Further Defendants’ failure to pay Mr. Evans violated the New Jersey Wage and Hour laws. 68. Defendants’ own paystubs reflects their violation of law. 69. Defendants sent Mr. Evans his last 3 paychecks which reflected a pay period of September 17, 2023, until September 23, 2023, pay period of September 24, 2023, until September 30, 2023, and October 1, 2023, until October 7, 2023. (See Composite Exhibit “17”). 70. The last paycheck that Mr. Evans received had a pay date of October 10, 2023, and reflected a year-to-date salary of $23,959.44. (See Exhibit “18”). 71 Interestingly and tellingly, Defendants paid Mr. Evans his work performance bonus in the last three paychecks they issued. 72. Despite the fact that the termination letter referenced performance issues, there is not one document Mr. Evans ever received that criticized his performance over the 4 % years of his employment. 73 During the 4 % years of his employment, Mr. Evans received salary increases and then a weekly performance bonus starting in approximately July 2023 until October 7, 2023. 74, During the 4 % years of his employment, Mr. Evans was never reprimanded. 75 During the 4 % years of his employment, Mr. Evans was never disciplined. 76. During the 4 % years of his employment, Mr. Evans was never written up. 77. During the 4 % years of his employment, Mr. Evans was never suspended. ESX-L-004123-24 06/17/2024 12:26:57 PM Pg7of50 Trans ID: LCV20241514152 78. During the 4 % years of his employment, Mr. Evans was never demoted. 79. During the 4 % years of his employment, Mr. Evans was never put on a performance improvement plan. 80. The above facts reflect that rather than take curative action, Defendants retaliated against Mr. Evans for objecting to Defendants’ illegal practices and terminating Mr. Evans’ employment on October 2023. 81 This retaliatory act by Defendants creates and satisfies the specific factual predicate for the CEPA violation alleged herein. 82. At the time of his termination on October 3, 2023, Mr. Evans was receiving compensation that exceeded $35,000 per year if Defendants had not engaged in the retaliatory act of cutting his hours from 40 hours per week to 37 hours per week. 83 Further, Defendants provided Mr. Evans paid time off and other benefits of employment. Count I (CEPA) 84. Mr. Evans realleges and incorporates herein the paragraphs set forth in this Complaint, unless noted below. 85 Mr. Evans reasonably believed that Defendants were violating either a law, regulation, or a clear mandate of public policy by the hiring of illegal workers in contravention of State and Federal law. 86. Thus, Plaintiff reasonably believed that the employer's conduct was violating either a law, government regulation, or a clear mandate of public policy. 87 Second, Plaintiff refused to participate or objected to this unlawful conduct, and advocated compliance with not violating the law to the employer. Plaintiff did so by either (a) pursuing and exhausting all internal means of securing compliance; or (b) refusing to participate in the objectionable conduct. 88 Third, Plaintiff suffered an adverse employment action. 89 Fourth, Defendants retaliated against Plaintiff because Plaintiff did one or more of the following: (a) disclosed or threatened to disclose to a supervisor or a public body an activity, policy 7 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 8of50 Trans ID: LCV20241514152 or practice of the employer or another employer, with whom there is a business relationship, that the Plaintiff reasonably believed is in violation of a law, or a rule or regulation promulgated pursuant to law; (b) Provided information to, or testified before, any public body conducting an investigation, hearing or inquiry into any violation of law, or a rule or regulation promulgated pursuant to law by the employer or another employer, with whom there is a business relationship; or (c) Objected to, or refused to participate in an activity, policy or practice which Plaintiff reasonably believed: i) is in violation of a law, or a rule or regulation promulgated pursuant to law or ii) is fraudulent or criminal; or ili) is incompatible with a clear mandate of a public policy concerning the health, safety, or welfare or protection of the environment. 90. The above actions of Defendants demonstrate that they are in violation of CEPA. 91 The facts supporting the CEPA violation do not touch upon the other claims pled in this complaint. 92 Additionally, the facts supporting the CEPA violation are separate and distinct from the facts supporting the other counts set forth below. 93 As a direct and proximate result of the actions of Defendants, Plaintiff has suffered mental anguish, physical discomfort, pain and suffering, shame and embarrassment, emotional distress injuries, the physical manifestation of emotional distress injuries and/or physical injury. Furthermore, Plaintiff has suffered lost wages, a diminished ability to earn a living, and a diminished capacity to enjoy Plaintiff's life. Moreover, Plaintiff has and/or may have to incur expenses for medical, psychiatric, and/or psychological counseling and care. Plaintiff's damages have been experienced in the past, and they will continue into the future. 94. Further, Plaintiff has been required to retain an attorney to assist Plaintiff in asserting Plaintiff's claims and protecting Plaintiff's rights. ESX-L-004123-24 06/17/2024 12:26:57 PM Pg9of50 Trans ID: LCV20241514152 Count I (New Jersey Wage and Hour Law, N.J.S.A. 34:11-56a et seq.) 95 Plaintiff realleges and incorporates herein the paragraphs set forth in this Complaint. 96. The actions of Defendants give rise to violations of the New Jersey Wage and Hour Law. 97. Additionally, Defendants failed to make, keep or preserve any records as required under this statute. 98, Further, Defendants failed to pay defendant his lawful wages. 99, Defendants’ actions to violate the law were done intentionally and with malice. 100. Further, Plaintiff has been required to retain counsel to assist Plaintiff in asserting Plaintiff's claims and protecting Plaintiff's rights. Count Hl (New Jersey Wage Payment Act, N.J.S.A. 34:11-4.1, et seq.) 101 Plaintiff realleges and incorporates herein the paragraphs set forth in this Complaint. 102 The actions of Defendants give rise to a violation of the New Jersey Wage Payment Act. 103 Under N.J.S.A. 34:11-4.2, every employer shall pay the full amount of wages due to his employees at least twice during each calendar month, on regular pay days designated in advance by the employer, in lawful money of the United States or with checks on banks where suitable arrangements are made for the cashing of such checks by employees without difficulty and for the full amount for which they are drawn. 104, Defendants failed to pay Plaintiff his full amount of wages when lawfully due. 105. Further, Plaintiff has been required to retain an attorney to assist Plaintiff in asserting Plaintiff's claims and protecting Plaintiff's rights. Count IV (Breach of Express Contract) 106. Plaintiff realleges and incorporates herein the paragraphs set forth in this Complaint. 107 Defendants had contractual obligations to Plaintiff that were set forth in their termination letter. 108 Defendants’ actions breached the contractual obligations set forth in this document. 109 Defendants’ actions give rise to the claim of breach of express contract. 9 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg10o0f50 Trans ID: LCV20241514152 110. As a direct and proximate result of the actions of Defendants, Plaintiff has been damaged. Count V (Breach of the Implied Covenant of Good Faith and Fair Dealing) 111. Plaintiff realleges and incorporates herein the paragraphs set forth in this Complaint. 112 Defendants had contractual obligations to Plaintiff as reflected above. 113 Defendants have breached these obligations. 114, Defendants’ actions give rise to the claim of breach of the implied covenant of good faith and fair dealing. 115 As a direct and proximate result of the actions of Defendants, Plaintiff has been damaged. WHEREFORE, as to each and every count, Plaintiff demands judgment on each and all of these Counts against the Defendants jointly and severally, as follows: A Compensatory damages of not less than $600,000; B Damages for lost wages and benefits, back pay, front pay (or reinstatement); Cc Damages for humiliation, mental and emotional distress; Statutory damages, if applicable; Punitive damages and or liquidated damages, where permitted by law; Attorneys’ fees and costs of suit; Lawful interest including pre-judgment interest on lost wages; Lawful interest - including pre-judgment interest on any wages not paid in a timely manner; and Such other, further and different relief as the Court deems fitting, just and proper. Plaintiff hereby reserves the right to amend this Complaint to supplement or modify the factual obligations and claims contained herein, based upon information received from the defendants, witnesses, experts, and others in the course of discovery in this matter. DEMAND FOR TRIAL BY JURY 10 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg11o0f50 Trans ID: LCV20241514152 Pursuant to Rule 4:35-1(a) and (b), Plaintiff respectfully demands a trial by jury on all issues in the within action so triable. DESIGNATION OF TRIAL COUNSEL In accordance with Rule 4:25-4, TY HYDERALLY is hereby designated as trial counsel on behalf of Plaintiff. R. 4:5-1(b)(2) CERTIFICATION OF NO OTHIS ACTIONS OR PARTIES Thereby certify that the matter in controversy is not the subject of any other action pending in any court or of a pending arbitration proceeding, that no other action or arbitration proceeding is contemplated, and that there are no other parties known to me at this time who should be joined as parties to this action. DEMAND FOR PRODUCTION OF INSURANCE AGREEMENTS Pursuant to R. 4:10-2(b), demand is hereby made that you disclose to the undersigned whether there are any insurance agreements or policies under which any person or firm carrying on an insurance business may be liable to satisfy all or part of a judgment which may be entered in the action or to indemnify or reimburse for payment made to satisfy the judgment. If so, please attach a copy of each, or in the alternative state, under oath and certification: (a) policy number; (b) name and address of insurer; (c) inception and expiration date; (d) names and addresses of all persons insured thereunder; (e) personal injury limits; (f) property damage limits; and (g) medical payment limits. DATED: June 17, 2024 HYDERALLY & ASSOCIATES, P.C. Attorneys for Plaintiff By: TY HYDERALLY, Esq. For the Firm ‘\Evans Jevon\Pleadings\042424.COM.docx 11 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg12o0f50 Trans ID: LCV20241514152 EXHIBIT 1 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg13o0f50 Trans ID: LCV20241514152 7 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 140f50 Trans ID: LCV20241514152 EXHIBIT 2 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg15o0f50 Trans ID: LCV20241514152 7 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg16o0f50 Trans ID: LCV20241514152 EXHIBIT 3 a feet ws aT Big Easy Camera fo? As Per Off Eddie Let Jevon Go Home 7 The Reason Why He Let Him Go Because He = ise Weckdtack And ihe\tokd Him This Not My Job. he Human Reso rc sta ESX-L-004123-24 06/17/2024 12:26:57 PM Pg18o0f50 Trans ID: LCV20241514152 EXHIBIT 4 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg190f50 Trans ID: LCV20241514152 2:28 S&B 2946 Luis(Owner Of Job) (917) 414-8330 Hee Oct 3, 9:51AM Ok let's meet Tuesday next week Tue 6:40PM ESYo) gam (omel (idels om VColUM oO lm (UTS cerca -Xem-Mt-bdm column =e (01 (1 Wa NAL elaR C1. Ua MC) eM) WWictsl.@eni mere] MnatcMela mY Lelaterey lo -a(o] come]0 kere) aa KOM Ve ae Tue 8:33PM had no idea let me talk to him mad circle back on Tuesday when we are scheduled to talk Tue 8:50PM + Send message © ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 200f50 Trans ID: LCV20241514152 EXHIBIT 5 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 210f50 Trans ID: LCV20241514152 4268808 77110 - 3d B Luis(Owner Of Job) (917) 414-8330 @ 10/3/23, 9:40AM Good morning Jevon, really sorry to hear that | had no idea as you know, | have little involvement in the warehouse and | really do not keep up with day to day nor do | even work in the same facility... i'll try and make time next week to meet with you and come in special Let me know what day is good for you. Thank you 10/3/23, 9:43AM NACE AN 4a 1-4 Ol Com BAO) 7 Nols Coli mM 7-FoMalcoldual-teme)'Act- ln] EVavoM ato(e(Wim Mat -MUVo) al ecm ia (comico) Eq stelel(-miolae-M an--1tlnlem ce) Ie-soxe) MMe Ws} [MSU Mtge] MMI lacixeael ale atomcre](¢ Maem Mile]eM WVaNVAl Tan merelanl (are m CoM (eLUR i leciml (o\-1-m NicMer:lame (=) Maal lare ow iamenge(=1s 10/3/23, 9:51AM Ok let's meet Tuesday next week E>, ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 22 0f50 Trans ID: LCV20241514152 EXHIBIT 6 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 23 0f50 Trans ID: LCV20241514152 4268808 77110 - 3d B Luis(Owner Of Job) (917) 414-8330 @ 10/3/23, 9:40AM Good morning Jevon, really sorry to hear that | had no idea as you know, | have little involvement in the warehouse and | really do not keep up with day to day nor do | even work in the same facility... i'll try and make time next week to meet with you and come in special Let me know what day is good for you. Thank you 10/3/23, 9:43AM NACE AN 4a 1-4 Ol Com BAO) 7 Nols Coli mM 7-FoMalcoldual-teme)'Act- ln] EVavoM ato(e(Wim Mat -MUVo) al ecm ia (comico) Eq stelel(-miolae-M an--1tlnlem ce) Ie-soxe) MMe Ws} [MSU Mtge] MMI lacixeael ale atomcre](¢ Maem Mile]eM WVaNVAl Tan merelanl (are m CoM (eLUR i leciml (o\-1-m NicMer:lame (=) Maal lare ow iamenge(=1s 10/3/23, 9:51AM Ok let's meet Tuesday next week E>, ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 240f50 Trans ID: LCV20241514152 EXHIBIT 7 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 250f50 Trans ID: LCV20241514152 4268808 77110 - 3d B Luis(Owner Of Job) (917) 414-8330 @ 10/3/23, 9:40AM Good morning Jevon, really sorry to hear that | had no idea as you know, | have little involvement in the warehouse and | really do not keep up with day to day nor do | even work in the same facility... i'll try and make time next week to meet with you and come in special Let me know what day is good for you. Thank you 10/3/23, 9:43AM NACE AN 4a 1-4 Ol Com BAO) 7 Nols Coli mM 7-FoMalcoldual-teme)'Act- ln] EVavoM ato(e(Wim Mat -MUVo) al ecm ia (comico) Eq stelel(-miolae-M an--1tlnlem ce) Ie-soxe) MMe Ws} [MSU Mtge] MMI lacixeael ale atomcre](¢ Maem Mile]eM WVaNVAl Tan merelanl (are m CoM (eLUR i leciml (o\-1-m NicMer:lame (=) Maal lare ow iamenge(=1s 10/3/23, 9:51AM Ok let's meet Tuesday next week E>, ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 26 0f50 Trans ID: LCV20241514152 EXHIBIT 3 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 27 0f50 Trans ID: LCV20241514152 2:24 & 3940 Manager Eddie (917) 717-1780 Tue 6:35PM Hey Jevon take the rest of the week off call me on Monday before you come To work Mal-x-XeR-Ye)an(my ox ROLMN ALA CUn er olla fel. No need Tue 6:38PM a Sun 10:03PM Hi Jevon we don't need you tomorrow thank you Sun 10:04PM + Send nes ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 28 0f50 Trans ID: LCV20241514152 EXHIBIT 9 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 29 0f50 Trans ID: LCV20241514152 2:24 & 3940 Manager Eddie (917) 717-1780 Tue 6:35PM Hey Jevon take the rest of the week off call me on Monday before you come To work Mal-x-XeR-Ye)an(my ox ROLMN ALA CUn er olla fel. No need Tue 6:38PM a Sun 10:03PM Hi Jevon we don't need you tomorrow thank you Sun 10:04PM + Send nes ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 300f50 Trans ID: LCV20241514152 EXHIBIT 10 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 310f50 Trans ID: LCV20241514152 4277 88 Oe HHG-: $id B Luis(Owner Of Job) (917) 41 4-830 @ 3 eeee 10/3/23, 9:51AM Ok let's meet Tuesday next week 10/3/23, 6:40PM ESTo) gam (omel (idels om Vole MoU lm (UTS) Ig-Xex-1hV-Xe Me cy am cola x0(0(=) WN AL elaR 1. Cm aM) MOLL) WWictel.@eni mete] Mant-Mela mY celaterey lo -3(o]km 0]0 kere) gai KOM Vel ae 10/3/23, 8:33PM had no idea let me talk to him mad circle back on Tuesday when we are scheduled to talk 10/3/23, 8:50PM | + Send message © ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 320f50 Trans ID: LCV20241514152 EXHIBIT 11 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 33 0f50 Trans ID: LCV20241514152 4277 88 Oe HHG-: $id B Luis(Owner Of Job) (917) 41 4-830 @ 3 eeee 10/3/23, 9:51AM Ok let's meet Tuesday next week 10/3/23, 6:40PM ESTo) gam (omel (idels om Vole MoU lm (UTS) Ig-Xex-1hV-Xe Me cy am cola x0(0(=) WN AL elaR 1. Cm aM) MOLL) WWictel.@eni mete] Mant-Mela mY celaterey lo -3(o]km 0]0 kere) gai KOM Vel ae 10/3/23, 8:33PM had no idea let me talk to him mad circle back on Tuesday when we are scheduled to talk 10/3/23, 8:50PM | + Send message © ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 340f50 Trans ID: LCV20241514152 EXHIBIT 12 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 350f50 Trans ID: LCV20241514152 4277 88 Oe HHG-: $id B Luis(Owner Of Job) (917) 41 4-830 @ 3 eeee 10/3/23, 9:51AM Ok let's meet Tuesday next week 10/3/23, 6:40PM ESTo) gam (omel (idels om Vole MoU lm (UTS) Ig-Xex-1hV-Xe Me cy am cola x0(0(=) WN AL elaR 1. Cm aM) MOLL) WWictel.@eni mete] Mant-Mela mY celaterey lo -3(o]km 0]0 kere) gai KOM Vel ae 10/3/23, 8:33PM had no idea let me talk to him mad circle back on Tuesday when we are scheduled to talk 10/3/23, 8:50PM | + Send message © ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 36 0f50 Trans ID: LCV20241514152 EXHIBIT 13 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 37 0f50 Trans ID: LCV20241514152 2:24 & 3940 Manager Eddie (917) 717-1780 Tue 6:35PM Hey Jevon take the rest of the week off call me on Monday before you come To work Mal-x-XeR-Ye)an(my ox ROLMN ALA CUn er olla fel. No need Tue 6:38PM a Sun 10:03PM Hi Jevon we don't need you tomorrow thank you Sun 10:04PM + Send nes ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 38 0f50 Trans ID: LCV20241514152 EXHIBIT 14 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 390f50 Trans ID: LCV20241514152 2:24 & 3940 Manager Eddie (917) 717-1780 Tue 6:35PM Hey Jevon take the rest of the week off call me on Monday before you come To work Mal-x-XeR-Ye)an(my ox ROLMN ALA CUn er olla fel. No need Tue 6:38PM a Sun 10:03PM Hi Jevon we don't need you tomorrow thank you Sun 10:04PM + Send nes ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 40 0f50 Trans ID: LCV20241514152 EXHIBIT 15 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 410f50 Trans ID: LCV20241514152 — Forwarded Message aoe From: "Sam H" To: Ce: 'Jevon Evans" <_a > Sent: Wed, Oct 11, 2023 at 1:21 PM Subject: Re: terminate here you go On Tue, Oct 10, 2023 at 12:55 AM Jevon Evans Ei wrote: Okay. | need my last 2 paystubs and my last paycheck Sent from Yahoo Mail on Android On Mon, Oct 9, 2023 at 10:14 AM, Sam H wrote: hello Jevon terminate letter attached - Thanks & best regards, SAM .H Power Photo Corp 40-50 Montgomery St Hillside, NJ 07205 Office: 718-502-6178 Cell: 917-442-9402 Email: samh@powerphotocorp.com This email, together with any attachment, is for the exclusive and confidential use of the addressee(s) and may contain legally privileged information. Any other distribution, use or reproduction without the sender's prior consent is unauthorized and strictly prohibited If you have received this message in error, please notify the sender by email immediately and delete the message from your computer without making any copies - Thanks & best regards, SAM .H Power Photo Corp 40-50 Montgomery St Hillside, NJ 07205 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 42 0f50 Trans ID: LCV20241514152 Office: 718-502-6178 Cell: 917-442-9402 Email: samh@powerphotocorp.com This email, together with any attachment, is for the exclusive and confidential use of the addressee(s) and may contain legally privileged information. Any other distribution, use or reproduction without the sender's prior consent is unauthorized and strictly prohibited If you have received this message in error, please notify the sender by email immediately and delete the message from your computer without making any copies ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 43 0f50 Trans ID: LCV20241514152 EXHIBIT 16 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 440f50 Trans ID: LCV20241514152 Big Easy Camera LLC, 40-50 Montgomery St Hillside NJ 07205 718-502-6178 Dear Jevon Evans | hope this letter finds you well. | am writing to address a matter that has come to our attention regarding your performance and job responsibilities here at Big Easy Camera LLC It has come to our notice that you have consistently not been performing your job duties and have been unwilling to fulfill the responsibilities that are expected as part of your role. At Big Easy Camera LLC, we have a clear set of job expectations, and it is essential that every team member contributes to the success of the organization by fulfilling their role. Despite our previous discussions and attempts to address the issue, we have not seen the improvement we expected. As a result, we have regrettably decided to terminate your employment with Big Easy Camera LLC, effective last working day, typically two weeks from the date of the letter. During your notice period, you will be expected to mention any specific tasks or handovers. You will receive your final paycheck on, date 10/3/2023. Please arrange to return any company property, keys, documents, or any other items in your possession by a specific date and instructions for returning company property. Will Be available to assist you with any questions you may have regarding your final paycheck, or any other related matters. We understand that this news may be difficult, and we want to thank you for the time you have spent at Big Easy Camera LLC. We wish you the best in your future endeavors. Operation Manger Sam H 10/6/2023 SH ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 45 o0f50 Trans ID: LCV20241514152 EXHIBIT 17 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 46 0f50 Trans ID: LCV20241514152 Aa? Number P. e RB Tot G S487 24957717 0 4071949 1 of 1 Earnings Statement Big Easy Cameras LLC 40-50 Montgomery St Period Starting: 09/17/2023 Hillside, NJ 07205-1131 Period Ending: 09/23/2023 Pay Date: 09/26/2023 ‘Taxable Marital Status: Single Exemptions/Allowances’ Tax Override: Jevon Evans Federal: 2 Federal State: 2 State: Local Social Security Number: HK IRI Eamings rate hours/units this period year to date Other Benefits and Regular 16.0000 38.33 613.28 21880.48 Information this period year to date Overtime 0.00 78.48 Sick Sick 0.00 384.00 ~ Carry Over 0.00 Personal 48.00 ~ Accrued Hours, 0.00 40.00 Bonus 0.00 50.00 500.00 + Taken Hours 0.00 24.00 = Balance 16.00 Gross Pay $663.28 $22,890.96 Total Hours Worked 38,33 1370.80 its account number transiVABA amount. Statutory Deductions this. to date XXXXXX9295 XXXXXKAXX, 335.35 Federal Income -43.40 341.61 Social Security “41.12 1419.24 Important Notes Medicare -9.62 331.92 Basis of pay: Hourly New Jersey State Income -10.57 353.71 New Jersey Stata Ul ~2.82 97.29 New Jersey State DI 0.00 0.00 New Jersey FLI 13.73 Voluntary Deductions this period year to date Child support 1 -120.00 4000.00 Child support 2 -100.00 3000.00 Net Pay $335.35 Your federal taxable wages this period are $663.28 Big Easy Cameras LLC 40-50 Montgomery St Pay Date: Hillside, NJ 07205-1134 09/26/2023 o spe B B fe Deposited to the account yumi a Sass dl TeeiiiGA amount Checking DirectDeposit 5 + XXX, 195 XXAKKKAXK 335.35 a ge a8 G me gE v% a uo Jevon Evans 50 Blum Newark, NJ 07103 ESX-L-004123-24 06/17/2024 12:26:57 PM Pg 47 o0f50 Trans ID: LCV20241514152 Germany Code Ror cote, 24957717 Big Easy Cameras LLC 40-50 Montgomery St Loci 01/7 soa Tah Earnings Statement Period Starting: 09/24/2023 AX? Hillside, NJ 07205-1131 Period Ending: 99/30/2023 Pay Date: 10/03/2023 ‘Taxable Marital Status: Single Exemptions/Allowances: Tax Override: Jevon Evans Federal 2 Federal: State: 2 State: Social Seairiy Number: 10 RIOUX Eamings rale hours/units this period year to date Other Benefits and Regular 16.0000