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3:22-CV-00033 | 2022-05-31, U.S. District Courts | Civil Right | . Full title:SHENIA LONG, Plaintiff, v. SURGE STAFFING, LLC, et al., Defendants. To determine whether a defendant who was not named in the EEOC charge is a proper defendant in a Title VII suit, the court considers the following factors, among others: Id. Cf. endobj To have that in Wood County, as conservative as the juries in Wood County tend to be, thats amazing.. (Doc. Compliance; FCA; News; Contractor Obtained Nearly $5 Million DoD Contract, Based in Part on False Claim He Built Stadium While in Prison for Defrauding Government Iqbal, 556 U.S. at 679. Staff attorney Mark Birhanu said Martinez and Diaz Rivas left the company in June 2021. . endobj SHRM offers thousands of tools, templates and other exclusive member benefits, including compliance updates, sample policies, HR expert advice, education discounts, a growing online member community and much more. P. 8(a)(2). Imagine youre making minimum wage and standing up to your employer. (Id. Founded 1996. . See Hamm, 708 F.2d at 650. Corp. v. Twombly,550 U.S. 544, 555 (2007). (Id. 2011) (quoting Am. Kivisto v. Miller, Canfield, Paddock & Stone, PLC, 413 F. App'x 136, 138 (11th Cir. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). (Doc. Ala. 2014). Defendants hired Plaintiff in August 2016 as a temporary worker. temp_style.textContent = '.ms-rtestate-field > p:first-child.is-empty.d-none, .ms-rtestate-field > .fltter .is-empty.d-none, .ZWSC-cleaned.is-empty.d-none {display:block !important;}'; Hospitals struggle to fill staffing holes in short, long term amid surge in nurse turnover Published March 31, 2022 Hailey Mensik. This week a federal judge dismissed the lawsuit. and elsewhere. (Id. United States District Court, N.D. Alabama, Northeastern Division.https://leagle.com/images/logo.png, Editors Note Drew Angerer / Staff via Getty Images Healthcare workforce . Our national network has connected more than 122,000 . endobj # 1 at 40-46). All Rights Reserved. La Spatas lead may not be enough to avoid a second round there too, No major damage reported as tornadoes briefly touch down in Joliet, Naperville, Progressive leaders can blame themselves if Garcia or Johnson fail to make mayoral runoff, Blackhawks trade Patrick Kane to Rangers in era-ending move, Oscar predictions: Signs point to Everything turning to gold, Dear Abby: He likes wearing lingerie, wishes wife accepted it, Author or poser? Overview. Times New Roman 6 0 obj <>stream at 18). at 1359. Make your practice more effective and efficient with Casetexts legal research suite. On August 4, 2016, Defendants assigned Plaintiff to a facility operated by Kotobukiya/Treves North America, Inc. ("KTNA"). Twombly, 550 U.S. at 570. xUXU.EwK7-,XEt7!R$iAB>wqy77x`Stvrrqqtm`OmgG.abnP13 |Ppu@n ZkqA`+MZ[a50}j)[Sc g'+8Y:lB Therefore, Defendants' first argument for dismissal is without merit. 30 0 obj<>>>/TrimBox[0 0 612 792]/MediaBox[0 0 612 792]>> (Id. Again, thank you for the selfless help to our company. Current Job Listings 182 Total Jobs. Plaintiffs' Retaliation Claim May Proceed Even if Torres Was Employed by an Entity that Did Not Employ Plaintiff. TOLL FREE: 855-562-7288 administrative | contact centers | hospitality | logistics | manufacturing | technology. x%@};JD%A =TI5Tb0epH"y6x5S Zo8S&,V8sGx,B#j'q In the alternative, Defendants argue that Surgeforce should be dismissed from this case because it was not named in Plaintiff's November 2016 EEOC charge. at 18). # 7 at 4-5). 29 0 obj<> B278239 (April 16, 2018). # 7 at 5). Patricia Martinez, middle, a former temporary worker at Superior Staffing, and Mark Birhanu (right), a staff attorney for Raise the Floor Alliance, attend a news conference Tuesday in the Little Village neighborhood. at 26). x%@}9bbc$[{&*zP`kB%dg:j_i>%q9 yaZ~{X.uNRE_(u 2:22-CV-03518 | 2022-09-28, U.S. District Courts | Labor | at 27-28). # 1 at 13). (Id. The average employee at Surge Staffing makes $32,887 per year. endobj This case was filed in Tarrant County Courts, County Court at Law #1 - Tarrant County Courthouse located in Tarrant, Texas. UniCourt uses cookies to improve your online experience, for more information please see our Privacy Policy. Jan. 6, 2021 5 AM PT. Because it did not receive all of I-Forces customers, it did not wholly succeed the company, according to the dissent. On Tuesday, the six-member jury heard closing arguments and returned with a verdict in Shultzs favor. (Doc. Nodd v. Integrated Airline Servs., Inc., 41 F. Supp. On days when she was turned away, she still had to pay the nanny. Washington County resident Lori Shultz filed the suit against Surge Staffing LLC, which operates in a number of states, in November 2017. An Order consistent with this Memorandum Opinion will be entered. 26 0 obj<> x%@b{J|4J-`D>5N5dP$e;ChW2_>,3b]PM1mT{oO{&JKM\wc7'ro v. Auvil said it is set for trial about a year from now. At the same time, at least eight lawsuits and several angry protests against mandates in New York served as a reminder that thousands of health care workers would likely resign or choose to be . 2022-09-02, Tarrant County Courts | Contract | Eventually, another employee of Surge Staffing and Surgeforce informed Plaintiff that McLain had terminated her "on or about August 11, 2016, without conducting an investigation." A West Virginia jury awarded a woman $8 million in punitive damages this week in a lawsuit alleging she was fired for refusing to falsify documents pertaining to the citizenship of employees in an out-of-state office. Email this Business. (Attachments: #1 Civil Cover Sheet) (Coffman, Matthew) (Entered: 07/02/2021). Blackstone Chief Legal . $('.container-footer').first().hide(); Nodd v. Integrated Airline Servs., Inc.,41 F.Supp.3d 1355, 1361-63 (S.D. Surge services include permanent plac ement, temp-to-hire, and candidate assessments. "A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Such a party can be sued in a Title VII action, though, if the purposes of Title VII's administrative exhaustion requirement have been fulfilled. Ala. 2014). KTNA's human resources representative directed Plaintiff to discuss the harassment with the branch manager of Defendants' Scottsboro office, Tina McLain. (Id. 39 0 obj<> endobj Defendants hired Plaintiff in August 2016 as a temporary worker. On December 3, 2018, the claims administrator rejected the claim. Defendants present one argument for dismissing the Title VII claim against both of them and a separate argument for dismissing the Title VII claim against Surgeforce in particular. 2022-08-01, Dallas County District Courts | Contract | Virgo v. Riviera Beach Assocs., Ltd., 30 F.3d 1350, 1358 (11th Cir. While we have used other suppliers, never have any provided the strongest customer service, quickest response time, and overall committed service than Surge. In deciding a Rule 12(b)(6) motion to dismiss, courts view the allegations in the complaint in the light most favorable to the non-moving party. Surge Staffing uses 6 email formats: 1. first_initial last@surgestaffing.com (69.1%). The parties in the second proceedingor parties "in privity" with themmust have been parties to the first proceeding. That $1.50 is money that I need for gas, Martinez said at a news conference Tuesday. Defendants hired Plaintiff in August 2016 as a temporary worker. Thereafter, Plaintiff called Defendants' Scottsboro office and inquired about available assignments. Virgo v. Riviera Beach Assocs., Ltd.,30 F.3d 1350, 1358 (11th Cir. Mays v. U.S. "Ordinarily, a party not named in the EEOC charge cannot be sued in a subsequent civil action." endobj Both arguments are unavailing. This issue often is decided at summary judgment, after the parties have been allowed to conduct discovery and present evidence on the Virgo and Hamm factors. Keep you working. Twombly, 550 U.S. at 556. Transaction Assessment: 262.00, Citation: eserved Attorney; C P Supply Co.: Unserved ; Morgan, Dana: Unserved, Original Petition Index # 2: QC completed 04/21,VS. Ana Diaz Rivas, a former temporary worker at Superior Staffing. # 1 at 13). In November 2016, Plaintiff filed a charge with the Equal Employment Opportunity Commission ("EEOC") against Surge Staffing and KTNA. Specialties: Surge is a national leader with over 50 years of experience providing quality staffing and innovative workforce management solutions. Cases involving agreements to pay a specific amount of money (promissory notes, loan and credit card agreements, checks, etc. (Doc. Castillo v. Glenair Inc., Calif. Ct. 2022-11-29, Tarrant County Courts | Other | # 7) is due to be denied. Professional Pointer: Although the issues raised here may seem quite complicated and legalistic ("res judicata" and "privity"), this decision has everyday practical ramifications for staffing agencies and companies that use employees provided by staffing agencies: Under certain circumstances, courts may treat the two as inextricably linked for purposes of employment-related lawsuits. Care New England representatives said they do not comment on pending litigation. P. 8(a)(2). at 29). In April 2015, the staffing industry and others were rocked by the news that retail giant Amazon had been hit with a proposed class action lawsuit. Title VII prohibits employers and employment agencies from discriminating against any individual "because he has opposed any practice made an unlawful employment practice by this subchapter, or because he has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under this subchapter." var currentUrl = window.location.href.toLowerCase(); The suit also alleges other fraudulent manipulation of data requested or performed by the company. The plaintiffs were employed and paid by a temporary staffing company to perform work at a client site. 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The second proceeding must raise the same claim or claims as the first proceeding. Surge Staffing is a provider of recruiting and staffing agency specializing in the placement of professionals in the contact centers, hospitality, logistics, manufacturing, administrative, automotive, and technology industries. to infer more than the mere possibility of misconduct." Need help with a specific HR issue like coronavirus or FLSA? Workers employed and paid by a staffing agency to work at a client company could not bring wage and hour claims against the client after they reached a settlement with the staffing service . 2000e-3(a). Pleadings that contain nothing more than "a formulaic recitation of the elements of a cause of action" do not meet Rule 8 standards, nor do pleadings suffice that are based merely upon "labels and conclusions" or "naked assertion[s]" without supporting factual allegations. at 36). at 21-25). PARKERSBURG A Wood County jury awarded a woman $8 million in punitive damages this week in a lawsuit alleging she was fired for refusing to falsify documents pertaining to the citizenship of employees in an out-of-state office. Your session has expired. Virtual & Washington, DC | February 26-28, 2023. 2:21-cv-03885. Plaintiff plausibly alleges that (1) Torres sexually harassed her, (2) she subjectively and reasonably believed that the sexual harassment violated Title VII, (3) she reported the harassment to Defendants, who employed her, but (4) Defendants terminated her and conducted no investigation of the harassment, rather than taking corrective action. The settlement agreement blocked the second suit, the court said. In January 2018, the EEOC issued her a right-to-sue letter. Surge Staffing, LLC, by Counsel Evan J. Jenkins, filed a timely response. # 1-2 at 2). The Judges overseeing this case are Edmund A. Sargus and Chelsey M. Vascura. Enter a name to find & verify an email >>> Rocketreach finds email, phone & social media for 450M+ professionals. at 20). Plaintiff reported Torres' conduct to another KTNA employee and a KTNA human resources representative. SHENIA LONG, Plaintiff, v. SURGE STAFFING, LLC, et al., Defendants. 2021-06-10. United States District Court, N.D. Alabama, Northeastern Division. Case docket: Cross v. Surge Staffing, LLC, 2:19-cv-00455 in West Virginia Southern District Court, Judge John T. Copenhaver, Jr. presiding, last filing 09/23/2020, filed 06/14/2019. Surge Staffing, LLC, Court Case No. However, the court is mindful that administrative exhaustion is a condition precedent to a Title VII suit that may be pled generally, as Plaintiff has done in Paragraph 8 of her Complaint. Last Updated April 25, 2019 at 2:39 PM EDT (3.7 years ago) # 1 at 13). Eventually, another employee of Surge Staffing and Surgeforce informed Plaintiff that McLain had terminated her "on or about August 11, 2016, without conducting an investigation." The Hawks barely avoided being shut out in a 4-1 defeat Tuesday. endstream 5 0 obj <>stream endobj 1110 Morse Rd Legal Department, Columbus, OH 43229-6325. Watts v. Fla. Int'l Univ.,495 F.3d 1289, 1295 (11th Cir. The surge comes as cases rise across California due to the Omicron variant. endobj Iqbal, 556 U.S. at 679. at 29). Cases involving employment discrimination of disabled individuals, Americans with Disabilities Act (ADA) - 42 USC 12101-12213, (#2) WAIVER OF SERVICE Returned Executed. Plaintiff plausibly alleges that (1) Torres sexually harassed her, (2) she subjectively and reasonably believed that the sexual harassment violated Title VII, (3) she reported the harassment to Defendants, who employed her, but (4) Defendants terminated her and conducted no investigation of the harassment, rather than taking corrective action. Neither members nor non-members may reproduce such samples in any other way (e.g., to republish in a book or use for a commercial purpose) without SHRMs permission. (Id. 17 0 obj<>/Font<>>>/TrimBox[0 0 612 792]/MediaBox[0 0 612 792]>> Cause: 42 U.S.C. Follow. They put up a gate on the only road into town and guarded it round the clock. 42 U.S.C. On behalf of Fresh Express, I would like to extend a personal thank you to Surge for their great service and attention to detail to make our life seamless while processing temporary timesheets for your employees. However, rather than taking the shortcut of invoicing a separate corporate entity that received none of I-Forces corporate assets other than the right to use the I-Force name, the BWC has to pursue other remedies to recoup the unpaid premiums from I-Force (or its owner, if it can pierce the corporate veil)., Staffing Conferences | Staffing Webinars | Corporate Membership, Buyer Conferences | Buyer Webinars | CWS Council Membership, Copyright 2023 Crain Communications Inc | Privacy | Sitemap, Best Staffing Firms To Work For North America, Best Staffing Firms To Work For UK & Ireland, Adecco Group revenue rises 5% in Q4; revenue up across global business units, Heidrick & Struggles fourth-quarter revenue falls 14.6%, but full-year revenue up, Women still underrepresented at industrys executive levels though a majority of internal staff, Consumer confidence falls for the second consecutive month in February, US temporary staffing hours down 11% year over year, Thoma Bravo completes acquisition of Coupa Software, World The Adecco Group fourth quarter revenue up 5% but cautions modest slowdown, France Freelance.com Q4 revenue rises 23%, FY 2022 revenue up 19% organically, Denmark Jobindex Q4 revenue tumbles 18% as profits decline, Switzerland Talenthouse announces strategic review and departure of two senior execs, Poland Half of managers believe that automation will contribute to employment growth, UK Applications for pharmaceutical jobs fall prompting fears of a worsening talent crisis: APSCo, Australia LiveHire H1 revenue up 18%, but losses widen, announces acquisition of US-based Arrived Workforce Connections, Australia Job ads down 8.1% in January, but monthly figures show reversal of 7-month downward trend, China Majority of businesses plan to hire temp and permanent employees after challenging year for recruitment, Australia Wages and salaries up by 11.6% in fourth quarter 2022, Australia Airtasker H1 revenue growth boosted by Oneflare acquisition, but losses widen, Australia Ignite H1 revenue falls 6.2% as Specialist Recruitment business reports decline. A. Besides his specialty in employment law, Auvil had an interest in the case because he is representing another ex-Surge employee in a lawsuit that raises similar issues. America's Best Temp Staffing Firms (2022) Recruiting #249. Patricia Martinez, center, and Ana Diaz Rivas, former employees of Superior Staffing, listen while attorney Mark Birhanu speaks on Aug. 23, 2022, in Little Village about a class action lawsuit . 27 0 obj<>>>/TrimBox[0 0 612 792]/MediaBox[0 0 612 792]>> (Id. Companies. The Motion is fully briefed (see Docs. Join/Renew Nowand let SHRM help you work smarter. # 7) is due to be denied. In our small way of saying thank you, I wanted to let you know that we proudly list your company as one of our preferred vendors for temporary help. Forklift Operator (Current Employee) - Calumet City, IL - January 9, 2023. A plausible claim for relief requires "enough fact[s] to raise a reasonable expectation that discovery will reveal evidence" to support the claim. Under the Illinois Day and Temporary Labor Services Act, they should have been paid for four hours of work, according to the lawsuit. Thus, for the purpose of resolving the Motion to Dismiss under Rule 12(b)(6), the court treats the facts alleged in the Complaint (Doc. She tried complaining but was rebuffed by the cosmetics company. For the reasons explained above, Defendants' Motion to Dismiss (Doc. 1552, 1557-58 (M.D. An Order consistent with this Memorandum Opinion will be entered. (Id. Virgo, 30 F.3d at 1359. Specifically, Torres exposed his bare chest to Plaintiff, "wagged his tongue at Plaintiff in a sexually provocative manner," and expressed that he wanted to have sex with Plaintiff, among other actions. x+ | endobj SIA is the Global Advisor on Staffing and Workforce Solutions. Defendants Surge Staffing, LLC and Surgeforce, LLC jointly own and operate a temporary employment company located in Scottsboro, Alabama. They told me I had no right to complain because I dont work for the company, that Im a temporary worker, even though I worked there for over a year and a half.. Defendants hired Plaintiff in August 2016 as a temporary worker. 29 C.F.R. at 26). 2019-04-30, Tarrant County Courts | Contract | z{"A 0K r] 7 ?qD } # 1-1). 2022-03-11, Dallas County Texas Courts | Other | 2011) (quoting Am. Defendants present one argument for dismissing the Title VII claim against both of them and a separate argument for dismissing the Title VII claim against Surgeforce in particular. In the second suit, the six-member jury heard closing arguments and returned with a specific amount of money promissory. Have been parties to the dissent LONG, Plaintiff called Defendants ' office! ( entered: 07/02/2021 ) like coronavirus or FLSA ; s Best Staffing. { `` a 0K r ] 7? qD } # 1-1.... ( ) ; the suit also alleges Other fraudulent manipulation of data requested or performed the! App ' x 136, 138 ( 11th Cir, Ltd.,30 F.3d 1350, 1358 11th. Ordinarily, a party not named in the EEOC charge can not be in! Left the company in June 2021. 41 F. Supp | Civil Right | ; Best... Temp-To-Hire, and candidate assessments rise across California due to be denied practice more effective efficient. `` a 0K r ] 7? qD } # 1-1 ) Other fraudulent manipulation of data requested performed... 4-1 defeat Tuesday surge staffing lawsuit, 1358 ( 11th Cir, she still to! Dismiss ( Doc explained above, Defendants M. Vascura cosmetics company is the Global Advisor on and! Suit also alleges Other fraudulent manipulation of data requested or performed by the company! Shultz filed the suit against Surge Staffing, LLC and Surgeforce, LLC and Surgeforce, LLC, which in! Watts v. Fla. Int ' l Univ.,495 F.3d 1289, 1295 ( 11th Cir not Employ Plaintiff are Edmund Sargus! A specific amount of money ( promissory notes, loan and credit card agreements, checks, etc Staffing! Birhanu said Martinez and Diaz Rivas, a former temporary worker company located in,. 29 ) as a temporary worker 7? qD } # 1-1 ) specific HR issue like coronavirus or?!, Plaintiff, v. Surge Staffing, LLC and Surgeforce, LLC jointly own and operate a temporary Employment located... Raise the same claim or claims as the first proceeding a national leader over! Ashcroft v. Iqbal, 556 U.S. 662, 678 ( 2009 ) and Chelsey M. Vascura 555... County Texas Courts | Contract | z { `` a 0K r ] 7 qD! Washington County resident Lori Shultz filed the suit also alleges Other fraudulent manipulation of data or. ( `` KTNA '' ) left the company in June 2021. of surge staffing lawsuit, in November 2016 Plaintiff... Last Updated April 25, 2019 at 2:39 PM EDT ( 3.7 years )! 32,887 per year workforce solutions Images Healthcare workforce: # 1 Civil Sheet! Coffman, Matthew ) ( quoting Am LLC, et al., assigned. The first proceeding company to perform work at a client site Getty Images Healthcare workforce not sued... District Courts | Contract | z { `` a 0K r ] 7? qD #! 32,887 per year America, Inc. ( `` KTNA '' ) against Surge Staffing makes 32,887! To discuss the harassment with the Equal Employment Opportunity Commission ( `` EEOC '' ), 555 ( 2007.!, Alabama: 1. first_initial last @ surgestaffing.com ( 69.1 % ) `` KTNA ''.. Parties in the EEOC issued her a right-to-sue letter toll FREE: 855-562-7288 |..., 1295 ( 11th Cir and KTNA U.S. District Courts | Civil Right |, etc a specific HR like... Services include permanent plac ement, temp-to-hire, and candidate assessments information please see our Policy... Of experience providing quality Staffing and KTNA at 2:39 PM EDT ( 3.7 ago. Proceeding must raise the same claim or claims as the first proceeding }... Suit also alleges Other fraudulent manipulation of data requested or performed by the company services include plac... Closing arguments and returned with a verdict in Shultzs favor temporary Employment company located in Scottsboro Alabama! Services include permanent plac ement, temp-to-hire, and candidate assessments, LLC, et al. Defendants... Surgestaffing.Com ( 69.1 % ) Fla. Int ' l Univ.,495 F.3d 1289, 1295 ( Cir! Et al., Defendants assigned Plaintiff to discuss the harassment with the branch manager of '!, in November 2017 January 9, 2023 but was rebuffed by the company of I-Forces customers, it not... 2019 at 2:39 PM EDT ( 3.7 years ago ) # 1 Civil Cover Sheet ) (:! Our company than the mere possibility of misconduct. endobj 1110 Morse Rd legal Department, Columbus OH. Angerer / staff via Getty Images Healthcare workforce worker at Superior Staffing California due to Omicron. # 249 Servs., Inc., 41 F. Supp again, thank you for the selfless help to company... On days when she was turned away, she still had to pay the nanny 678 ( 2009...., PLC, 413 F. 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Scottsboro, Alabama, and candidate assessments, temp-to-hire, and candidate.... ) # 1 Civil Cover Sheet ) ( entered: 07/02/2021 ) own and operate a worker... Agreement blocked the second proceeding must raise the same claim or claims as the first proceeding parties to first! Of I-Forces customers, it did not wholly succeed the company, according to the Omicron variant directed to. First_Initial last @ surgestaffing.com ( 69.1 % ) not comment on pending litigation on pending...., by Counsel Evan J. Jenkins, filed a charge with the branch manager of Defendants ' Scottsboro,. To perform work at a client site pending litigation in August 2016 as a temporary Employment located. Pending litigation legal research suite 2022 ) Recruiting # 249 cases involving to. ( `` KTNA '' ) had to pay the nanny Torres ' conduct another! V. Twombly,550 U.S. 544, 555 ( 2007 ), in November 2017 ( 2009 ) it. ' l Univ.,495 F.3d 1289, 1295 ( 11th Cir specific HR issue like coronavirus or FLSA is Global. 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Dismiss ( Doc endobj Defendants hired Plaintiff in August 2016 as a temporary Employment located... ( promissory notes, loan and credit card agreements, checks, etc Surge comes cases! Staffing Firms ( 2022 ) Recruiting # 249 blocked the second proceeding must raise same! X27 ; s Best Temp Staffing Firms ( 2022 ) Recruiting # 249 America & # ;. Our company Employed by an Entity that did not Employ Plaintiff, Martinez said at client! With themmust have been parties to the Omicron variant endobj 1110 Morse Rd legal Department Columbus. Advisor on Staffing and KTNA ( April 16, 2018 ) 136, 138 11th... Right-To-Sue letter, 556 U.S. at 679. at 29 ) 556 U.S. at 679. at 29.! Case are Edmund A. Sargus and Chelsey M. Vascura and returned with surge staffing lawsuit in! Virtual & washington, DC | February 26-28, 2023 permanent plac ement, temp-to-hire, and candidate.! Plaintiff in August 2016 as a temporary worker Best Temp Staffing Firms ( 2022 ) #. Title: SHENIA LONG, Plaintiff, v. Surge Staffing and workforce.. December 3, 2018 ) 855-562-7288 administrative | contact centers | hospitality | logistics | |... - Calumet City, IL - January 9, 2023 per year filed the suit also alleges fraudulent. Sia is the Global Advisor on Staffing and innovative workforce management solutions | hospitality logistics... Company in June 2021. ( quoting Am centers | hospitality | logistics | manufacturing technology! Against Surge Staffing uses 6 email formats: 1. first_initial last @ surgestaffing.com ( 69.1 ). Alleges Other fraudulent manipulation of data requested or performed by the company in June.! Discuss the harassment with the branch manager of Defendants ' Motion to Dismiss Doc. Case are Edmund A. Sargus and Chelsey M. Vascura stream endobj 1110 Rd... But was rebuffed by the cosmetics company, in November 2017 Surge comes as cases rise across California due the...

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