On June 18, 2019 a
Motion-Secondary
was filed
involving a dispute between
Diego Delgado Luna,
Felix Ortega Pacheco,
Florencio Rivera Rodriguez,
Fotis Louzakos,
Gonzalo Martinez,
Jose Salazar Ortiz,
Juan Campos Trejo,
Plutarco Navarrete Cabanas,
and
Ainos Realty Corp.,
George Liberatos,
Helen Liberatos,
Karabinis Diner Corp.
Dba Oasis Diner,
Petros Liberatos,
for Other Matters - Contract - Other
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 02/07/2022 10:30 PM INDEX NO. 513496/2019
NYSCEF DOC. NO. 111 RECEIVED NYSCEF: 02/07/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------x
JOSE SALAZAR ORTIZ, FLORENCIO
RIVERA RODRIGUEZ, FELIX ORTEGA
PACHECO, GONZALO MARTINEZ, JUAN
CAMPOS TREJO, PLUTARCO NAVARRETE
CABAÑAS, and FOTIS LOUZAKOS, Individually
and on Behalf ofAll Putative Class Members,
Index No. 513496/2019
Plaintiff,
-against-
AFFIDAVIT OF LINDA
KORDELIS IN OPPOSITION TO
MOTION
KARABINIS DINER CORP. d/b/a OASIS DINER,
AINOS REALTY CORP., PETROS LIBERATOS,
HELEN LIBERATOS, and GEORGE LIBERATOS,
Jointly and Severally,
Defendants.
----------------- -------------------------------x
STATE OF NEW YORK )
)
COUNTY OF
LINDA KORDELIS, being duly sworn, deposes as follows:
1. I am a [former?] employee of Oasis Diner. I worked at Oasis Diner as a
2007
counter attendant and waitress from to2020
2. As an employee I was paid an hourly wage, and recorded my time on a
time card.
3. I observed that itwas Oasis Diner's regular practice to have employees
who were paid in cash to sign documents at the time of payment of their weekly salaries. I
observed that these documents had written entries for the time the employees worked and the
1 of 2
FILED: KINGS COUNTY CLERK 02/07/2022 10:30 PM INDEX NO. 513496/2019
NYSCEF DOC. NO. 111 RECEIVED NYSCEF: 02/07/2022
were being paid. I observed the employees sign the documents because they would do so around
the counter area on Sunday nights when they were paid by Helen or Petros Liberatos. I
specifically saw Florencio Rivera, Felix Ortega, and Juan Campos sign such documents on a
weekly basis.
Swprn Before Me this
fi ay of February 2022
N iry 1 uÉlic
Michael G. Fastala LINDA KORDELl'S
Notary Public, Stateof New York
No. 01FA6376198
Qualified in Queens County
- June 46
My Commissica Expires 2022
2
2 of 2
Document Filed Date
February 07, 2022
Case Filing Date
June 18, 2019
Category
Other Matters - Contract - Other
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Preview
FILED: KINGS COUNTY CLERK 02/07/2022 10:30 PM INDEX NO. 513496/2019 NYSCEF DOC. NO. 111 RECEIVED NYSCEF: 02/07/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------x JOSE SALAZAR ORTIZ, FLORENCIO RIVERA RODRIGUEZ, FELIX ORTEGA PACHECO, GONZALO MARTINEZ, JUAN CAMPOS TREJO, PLUTARCO NAVARRETE CABAÑAS, and FOTIS LOUZAKOS, Individually and on Behalf ofAll Putative Class Members, Index No. 513496/2019 Plaintiff, -against- AFFIDAVIT OF LINDA KORDELIS IN OPPOSITION TO MOTION KARABINIS DINER CORP. d/b/a OASIS DINER, AINOS REALTY CORP., PETROS LIBERATOS, HELEN LIBERATOS, and GEORGE LIBERATOS, Jointly and Severally, Defendants. ----------------- -------------------------------x STATE OF NEW YORK ) ) COUNTY OF LINDA KORDELIS, being duly sworn, deposes as follows: 1. I am a [former?] employee of Oasis Diner. I worked at Oasis Diner as a 2007 counter attendant and waitress from to2020 2. As an employee I was paid an hourly wage, and recorded my time on a time card. 3. I observed that itwas Oasis Diner's regular practice to have employees who were paid in cash to sign documents at the time of payment of their weekly salaries. I observed that these documents had written entries for the time the employees worked and the 1 of 2 FILED: KINGS COUNTY CLERK 02/07/2022 10:30 PM INDEX NO. 513496/2019 NYSCEF DOC. NO. 111 RECEIVED NYSCEF: 02/07/2022 were being paid. I observed the employees sign the documents because they would do so around the counter area on Sunday nights when they were paid by Helen or Petros Liberatos. I specifically saw Florencio Rivera, Felix Ortega, and Juan Campos sign such documents on a weekly basis. Swprn Before Me this fi ay of February 2022 N iry 1 uÉlic Michael G. Fastala LINDA KORDELl'S Notary Public, Stateof New York No. 01FA6376198 Qualified in Queens County - June 46 My Commissica Expires 2022 2 2 of 2