Dilnoza Khashimova, Individually And On Behalf Of All Other Persons Similarly Situated Who Were Employed By Smile Homecare Agency, Inc., Along With Other Entities Affiliated Or Controlled By Smile Homecare Agency, Inc. v. Smile Homecare Agency, Inc.…

individuals (collectively “Plaintiffs”) who are citizens of the State of New York and are presently

or were formerly employed by Smile Homecare Agency, Inc., along with other entities affiliated

or controlled by Smile Homecare Agency, Inc., (“Defendant”), to provide personal care,

assistance, health-related tasks and other home care services to Defendant’s clients within the State

of New York.

Plaintiffs seek to recover wages and benefits which Plaintiffs were statutorily and

contractually entitled to receive pursuant to New York Labor Law (hereinafter referred to as

“NYLL”) § 190 et seq., § 663, § 651 et seq., and § 650 et seq., 12 New York Codes, Rules, and

Regulations (hereinafter referred to as “NYCRR”) §§ 142-2.1, 142-2.2, 142-2.4, 142-2.10, and

New York Public Health Law § 3614-c, and Title 6, Section 6-109 of the New York City

Administrative Code (hereinafter referred to as “NYC Admin. Code § 6-109”).

Causes of Action

1. NEW YORK LABOR LAW MINIMUM WAGE

2. NEW YORK LABOR LAW OVERTIME

3. NEW YORK LABOR LAW “SPREAD OF HOURS”

4. FAILURE TO PAY WAGES

5. BREACH OF CONTRACT

6. BREACH OF CONTRACT