Preview
FILED: NASSAU COUNTY CLERK 10/31/2023 11:15 PM INDEX NO. 617754/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/31/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
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ZORYHA NORFLEET, LISA ABBAS and VALERIE : Index. No. 2023/__________
JANOWSKI on behalf of themselves and all others similarly :
situated, : Date Filed:
:
Plaintiffs, : SUMMONS
- against - :
: Plaintiffs designate
REVCORE RECOVERY CENTER MANHATTAN LLC, : Nassau County as Place of Trial
REVCORE RECOVERY CENTER OF QUEENS LLC, :
REVCORE NYCATS LLC, and REVCORE HOLDINGS :
LLC, :
Defendants. :
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TO THE ABOVE-NAMED DEFENDANTS:
You are hereby summoned and required to serve upon Plaintiffs’ attorneys an answer to
the complaint in this action within 20 days after the service of this summons, exclusive of the day
of service, or within 30 days after service is complete if this summons is not personally delivered
to you within the State of New York. In case of your failure to answer, judgment will be taken
against you by default for the relief demanded in the complaint.
The basis of venue designated is pursuant to CPLR § 501.
Dated: Melville, New York
October 31, 2023
Respectfully submitted,
By: /s/ Troy L. Kessler
Troy L. Kessler
KESSLER MATURA PC
Troy L. Kessler
Tana Forrester
Garrett Kaske
534 Broadhollow Road, Suite 275
Melville, New York 11747
Telephone: (631) 499-9100
Attorneys for Plaintiffs and the Putative FLSA
Collective and Putative Class
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To: RevCore Recovery Center Manhattan LLC
RevCore Recovery Center of Queens LLC
RevCore NYCATS LLC
d
c/o Garfunkel Wild, P.C., 111 Great Neck Rd., Ste. 600, Great Neck, NY 11021
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SUPREME COURT OF NEW YORK
COUNTY OF NASSAU
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ZORYHA NORFLEET LISA ABBAS and VALERIE :
JANOWSKI on behalf of themselves and all others similarly :
situated, :
: Index. No. 2023/__________
Plaintiffs, :
- against - : CLASS ACTION
: COMPLAINT
REVCORE RECOVERY CENTER MANHATTAN LLC, ::
REVCORE RECOVERY CENTER OF QUEENS LLC, :
REVCORE NYCATS LLC, and REVCORE HOLDINGS :
LLC, :
:
Defendants. :
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Plaintiffs Zoryha Norfleet, Lisa Abbas and Valerie Janowski on behalf of themselves and
all others similarly situated, by and through their attorneys Kessler Matura P.C., complaining of
the Defendants RevCore Recovery Center Manhattan LLC, RevCore Recovery Center of Queens
LLC, RevCore NYCATS LLC, and RevCore Holdings LLC (“Defendants” or “RevCore”), allege
as follows as for their Complaint:
PRELIMINARY STATEMENT
1. Plaintiffs bring this lawsuit to recover unpaid overtime and other damages on behalf
of all of RevCore’s as Group Facilitators, Substance Abuse Counselors or Peer Advocates
(“Counselors”) at any time between August 15, 2016, and August 15, 2022 (the “Class Period”),
based on Defendants’ violation of the Fair Labor Standards Act (“FLSA”) and the New York Labor
Law (“NYLL”) and appropriate rules and regulations.
2. RevCore failed to pay their Counselors for all hours worked.
3. While employed by RevCore, Plaintiffs and other similarly situated Counselors
worked over 40 hours per week without receiving overtime pay for all the hours they worked.
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4. Norfleet, Janowski, and Abbas (the “Class Representatives”) bring this action on
behalf of themselves and all similarly situated Counselors who worked during the Class Period,
pursuant to Article 9 of the New York Civil Practice Law and Rules to remedy violations of the
NYLL, Article 19, §§ 650 et seq., and Article 6, §§ 195 and 198, and the supporting New York
State Department of Labor regulations.
5. Norfleet and Abbas (the “FLSA Class Representatives”) bring this action on behalf
of themselves and all similarly situated Counselors pursuant to the FLSA who worked from August
15, 2019, to August 15, 2022 (the “FLSA Period”).
JURISDICTION & VENUE
6. This Court has jurisdiction over this matter pursuant to N.Y. Lab. Law, Article 9,
§§ 190 et seq., and C.P.L.R. § 301.
7. This Court is the proper venue under C.P.L.R. § 501, due to a preexisting agreement
between Plaintiffs and Defendants.
THE PARTIES
Plaintiff Zoryha Norfleet
8. Norfleet is a resident of Bronx County, New York.
9. At all times relevant to this Class Action Complaint, Norfleet was an “employee”
within the meaning of Section 3(e) of the FLSA, 29 U.S.C. § 203(e), and N.Y. Lab. Law §§ 190(2),
651(5).
10. Norfleet was employed by Defendants as a Substance Abuse Counselor and Group
Facilitator from November 26, 2019, to March 13, 2020.
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11. As a Counselor, Norfleet was required to process clients’ answers to questionnaires,
take notes on their meetings, call any necessary supportive services, and facilitated group sessions
for clients.
12. Norfleet was typically only paid for 35 hours each week, regardless of how many
hours she worked.
13. Norfleet typically worked 45 or more hours per week.
14. Over the course of her employment, Norfleet was not fully relieved of duty for
purposes of taking a full-length meal break each shift.
15. Norfleet was not permitted to record the actual number of hours that she worked
and was instructed by Defendants that RevCore did not pay overtime.
16. Norfleet expressed her consent to make these claims against Defendants by signing
a written consent form, pursuant to 29 U.S.C. § 216(b). The consent form is attached, as Exhibit
A.
Plaintiff Lisa Abbas
17. Abbas is a resident of Kings County, New York.
18. At all times relevant to this Class Action Complaint, Norfleet was an “employee”
within the meaning of Section 3(e) of the FLSA, 29 U.S.C. § 203(e), and N.Y. Lab. Law §§ 190(2),
651(5).
19. Abbas was employed by Defendant as a Peer Advocate from approximately
November 20, 2021, to March 18, 2022.
20. As a Peer Advocate, Abbas was required to process clients’ answers to
questionnaires, take notes on their meetings, call any necessary supportive services, and
accompany clients to appointments.
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21. Abbas was typically only paid for the amount that she was scheduled each week,
regardless of how many hours she worked.
22. Over the course of her employment, Abbas was not fully relieved of duty for
purposes of taking a full-length meal break each shift.
23. Abbas regularly worked over 40 hours per week.
24. Abbas was not permitted to record the actual number of hours that she worked and
was instructed by Defendants that RevCore did not pay overtime.
25. Abbas was not permitted to record the overtime hours that she worked, nor was she
paid at the required overtime rate of time and one half for all hours worked over 40.
26. Abbas expressed her consent to make these claims against Defendants by signing a
written consent form, pursuant to 29 U.S.C. § 216(b). The consent form is attached with Abbas’s
form, as Exhibit A.
Plaintiff Valerie Janowski
27. Janowski is a resident of Queens County, New York.
28. At all times relevant to this Class Action Complaint, Janowski was an “employee”
within the meaning of N.Y. Lab. Law §§ 190(2), 651(5).
29. Janowski was employed by Defendants as a Substance Abuse Counselor and Group
Facilitator from approximately January 8, 2018, through November 6, 2018.
30. Janowski met with clients, took notes meetings, called any necessary supportive
services, and facilitated group sessions for clients.
31. Janowski was typically only paid for 35 hours each week, regardless of how many
hours she worked.
32. Janowski typically worked 45 or more hours per week.
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33. Over the course of her employment, Janowski was not fully relieved of duty for
purposes of taking a full-length meal break each shift.
34. Janowski was not permitted to record the actual number of hours that she worked
and was instructed by Defendants that RevCore did not pay overtime.
35. At all times relevant to this Class Action Complaint, Janowski was an “employee”
within the meaning of N.Y. Lab. Law § 190(2).
Defendants
36. At all times relevant, Defendants’ annual gross volume of sales made or business
done, collectively and independently, was not less than $500,000.
37. At all times relevant, RevCore applied the same employment policies, practices,
and procedures to all Counselors throughout the State of New York, including policies, practices,
and procedures with respect to recording time and payment of overtime compensation.
38. At all relevant times, RevCore maintained control, oversight, and direction over
Plaintiffs and similarly situated employees, including timekeeping, payroll and other employment
practices that applied to them. RevCore has three locations in New York, where it employed
Plaintiffs and other Counselors.
39. At all times relevant, the activities of RevCore constituted an “enterprise” within
the meaning of Section 3(r) & (s) of the FLSA, 29 U.S.C. § 203(r) & (s).
40. At all times relevant, RevCore was an “employer” within the meaning of Section
3(d) of the FLSA, 29 U.S.C. § 203(d), and N.Y. Lab. Law §§ 190(3), 651(6).
Defendant RevCore Recovery Center Manhattan LLC
41. Upon information and belief, RevCore Recovery Center Manhattan LLC was a
domestic corporation, authorized to do business pursuant to the laws of the State of New York.
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42. RevCore Recovery Center Manhattan LLC was doing business as RevCore.
43. RevCore Recovery Center Manhattan LLC maintained its principal place of
business at 598 Broadway, 2nd Floor, New York, New York.
Defendant RevCore Recovery Center of Queens LLC
44. Upon information and belief, Defendant RevCore Recovery Center of Queens LLC
was a domestic corporation, authorized to do business pursuant to the laws of the State of New
York.
45. Defendant RevCore Recovery Center of Queens LLC was doing business as
RevCore.
46. RevCore Recovery Center of Queens LLC maintained its principal place of
business at 37-20 74th St., 3rd Floor, Jackson Heights, New York.
Defendant RevCore NYCATS LLC
47. Upon information and belief, Defendant RevCore NYCATS LLC was a domestic
corporation, authorized to do business pursuant to the laws of the State of New York.
48. Defendant RevCore NYCATS LLC was doing business as RevCore.
49. RevCore NYCATS LLC maintained its principal place of business at 598
Broadway, 2nd Floor, New York, New York.
Defendant RevCore Holdings LLC
50. Upon information and belief, Defendant RevCore Holdings LLC was a domestic
corporation, authorized to do business pursuant to the laws of the State of New York.
51. Defendant RevCore Holdings LLC was doing business as RevCore.
52. Defendant RevCore Holdings LLC maintained its principal place of business at
1415 59th Street, Brooklyn, New York.
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FLSA COLLECTIVE ACTION CLAIMS
53. Plaintiffs Norfleet and Abbas bring the Third Cause of Action, pursuant to the
FLSA, 29 U.S.C. § 216(b), on behalf of themselves and the “FLSA Collective,” defined as:
All individuals who worked for Defendants as Group
Facilitators, Substance Abuse Counselors or Peer Advocates
at any time during the FLSA Period.
54. Upon information and belief, there are approximately more than 30 Counselors that
are similarly situated to the FLSA Class Representatives who were denied overtime by Defendants.
55. The FLSA Class Representatives represent other Counselors and are acting on
behalf of Defendants’ Counselors interests as well as their own interests in bringing this action.
56. Defendants required the FLSA Class Representatives, and all individuals employed
as Counselors to work in excess of 40 hours per week without paying them overtime compensation
at a rate of at least one and one-half times their regular hourly rate.
57. Defendants were aware or should have been aware that the law required it to pay
non-exempt employees, including the FLSA Class Representatives and the FLSA Collective, an
overtime premium of one and one-half times their regular rate of pay for all work-hours Defendants
suffered or permitted them to work in excess of 40 per workweek.
58. The FLSA Collective is readily identifiable and locatable through the use of the
Defendants’ records. The FLSA Collective should be notified of and allowed to opt-in to this
action, pursuant to 29 U.S.C. § 216(b). Unless the Court promptly issues such a notice, the FLSA
Collective, who have been unlawfully deprived of overtime pay in violation of the FLSA, will be
unable to secure compensation to which they are entitled, and which has been unlawfully withheld
from them by Defendants.
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NEW YORK CLASS ACTION ALLEGATIONS
59. Plaintiffs Norfleet, Abbas and Janowski, The New York Class Representatives,
bring the First and Second Causes of Action on their own behalf and as a class action, pursuant to
Article 9 of the New York Civil Practice Law and Rules on behalf of the following class of persons:
All individuals who worked for Defendants as Group Facilitators,
Substance Abuse Counselors or Peer Advocates at any time during
the Class Period (the “Class”).
60. The people in the Class are so numerous that joinder of all members is
impracticable. Although, the precise number of people is unknown, and facts on which the
calculation of that number can be based are presently within the sole control of Defendants.
61. Upon information and belief, the size of the Class is over 80 individuals.
62. Common questions of law and fact exist as to the Class that predominate over any
questions only affecting them individually and include, but are not limited to:
a. Whether Defendants failed to pay proper overtime compensation for all
work-hours and violated the NYLL and the supporting New York State
Department of Labor regulations;
b. Whether Defendants failed to keep accurate time records for all hours
worked by the Class Representatives and the Class;
c. What proof of hours worked is sufficient where an employer fails in its duty
to maintain true and accurate time records;
d. Whether Defendants failed to furnish the Class Representatives and Class
with an accurate statement of, inter alia, wages, hours worked, and rates
paid as required by NYLL § 195;
e. The nature and extent of Class-wide injury and the appropriate measure of
damages sustained by the Class Representatives and the Class;
f. Whether Defendants failed to pay the Class Representatives and the Class
their overtime wages, but attempted to comply with the NYLL in reasonable
good faith ; and
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g. The nature and extent of class-wide injury and the measure of damages for
those injuries.
63. The Class Representatives fairly and adequately protect the interests of the Class
and have no interests antagonistic to the Class. The Class Representatives are represented by
attorneys who are experienced and competent in both class litigation and employment litigation.
64. A class is superior to other available methods for the fair and efficient adjudication
of the controversy, particularly in the context of wage-and-hour litigation where an individual
plaintiff lacks the financial resources to vigorously prosecute a lawsuit in federal court against the
corporate defendant. The damages sustained by individual class members are small, compared to
the expense and burden of individual prosecution of this litigation. Class action treatment will
obviate unduly duplicative litigation and the possibility of inconsistent judgments.
65. Further, the Class Representatives and the Class have been equally affected by
Defendants’ failure to pay proper wages and provide proper wage statements.
66. The Class Representatives’ claims are typical of those of the Class. The Class
Representatives and the other Class members were subjected to Defendants’ policies, practices,
programs, procedures, protocols and plans alleged herein concerning the failure to pay proper
wages and the failure to keep adequate records. Plaintiffs’ job duties are typical of those of the
class members.
67. A class action is superior to other available methods for the fair and efficient
adjudication of this litigation – particularly in the context of wage litigation like the present action,
where individual plaintiffs may lack the financial resources to vigorously prosecute a lawsuit in
federal court against a corporate defendant. The members of the Class have been damaged and
are entitled to recovery as a result of Defendants’ common and uniform policies, practices, and
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procedures. Although the relative damages suffered by individual members of the Class are not
de minimis, such damages are small compared to the expense and burden of individual prosecution
of this litigation. In addition, class treatment is superior because it will obviate the need for unduly
duplicative litigation that might result in inconsistent judgments about Defendants’ practices.
68. This action is properly maintainable as a class action under Article 9 of the New
York Civil Practice Law and Rules.
COMMON FACTUAL ALLEGATIONS
69. Plaintiffs and the members of the Class (collectively “Class Members”) are due
overtime premiums under the FLSA and NYLL and were not provided accurate wage statements
as a result.
70. Defendants’ conduct was widespread, repeated, and consistent.
71. Regardless of the location at which Plaintiffs and Class Members worked for
Defendants, Defendants policies and practices remained substantially the same.
Unpaid Overtime Wages
72. Upon information and belief, Defendant had a policy and pattern or practice to
require Plaintiffs and Class Members to work in excess of 40 hours per week.
73. Plaintiffs and Class Members were typically paid for 70 hours in a biweekly cycle
regardless of hours they worked in one workweek.
74. Defendant was aware or should have been aware of all the work that Counselors
performed.
75. During the Class Period, Defendants did not pay Plaintiffs and Class Members time
and one half for all hours worked over 40 in a workweek in violation of the FLSA and the NYLL.
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76. Defendant did not pay overtime wages during the Class Period, pursuant to a
company-wide policy.
Inaccurate Wage Statements
77. During the Class Period, Defendants did not provide Plaintiffs and Class Members
with an accurate wage statement each pay period.
78. Defendants did not list accurate hours worked and overtime rates of pay on
Counselors’ pay stubs.
79. As a result, Defendants did not furnish Plaintiffs and Class Members with an
accurate statement of, inter alia, wages, hours worked, and rates paid as required by NYLL.
FIRST CAUSE OF ACTION
NYLL – Unpaid Overtime
(Brought on behalf of the Plaintiffs and the Class)
80. Plaintiffs reallege and incorporate by reference all allegations in all preceding
paragraphs.
81. At all times relevant, Plaintiffs and the Class were employees and Defendants were
their employer within the meaning of the NYLL.
82. Plaintiffs and the Class are covered by the NYLL.
83. Defendants did not keep, make, preserve, maintain and furnish accurate records of
time worked by Plaintiffs and Class Members.
84. Defendants did not pay Plaintiffs and the members of the Class overtime wages to
which they are entitled under the NYLL Article 19 §§ 650, et seq., and the supporting New York
State Department of Labor Regulations.
85. Defendants did not pay Plaintiffs and Class Members overtime at a wage rate of
one and one-half times their regular rate of pay.
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86. Defendants have a policy and practice of not paying overtime compensation for all
hours worked to Plaintiffs and the Class.
87. Defendants did not have a reasonable, good-faith belief that their overtime-payment
policies, as they relate to Plaintiffs and the Class, were in compliance with the NYLL.
88. As a consequence of the willful underpayment of wages, alleged above, Plaintiffs
have incurred damages thereby and Defendants are indebted to them in the amount of the unpaid
overtime compensation, liquidated damages, reasonable attorneys’ fees and costs of the action,
and pre-judgment and post-judgment interest.
SECOND CAUSE OF ACTION
NYLL – Notice and Record-Keeping Requirement Violation
(Brought on behalf of Plaintiffs and the Class)
89. Plaintiffs reallege and incorporate by reference all allegations in all preceding
paragraphs.
90. Defendants did not supply Plaintiffs and members of the Class with an accurate
statement of wages as required by N.Y. Lab. Law § 195, containing the dates of work covered by
that payment of wages; name of employee; name of employer; address and phone number of
employer; rate or rates of pay and basis thereof, whether paid by the hour, shift, day, week, salary,
piece, commission, or other; gross wages; hourly rate or rates of pay and overtime rate or rates of
pay if applicable; the number of hours worked, including overtime hours worked if applicable;
deductions; and net wages.
91. Due to Defendants’ violations of N.Y. Lab. Law § 195, for each workweek that
Defendants did not provide a proper wage statement from August 15, 2016 through August 15,
through the present, Plaintiffs and members of the Class are each entitled to damages of $250 per
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workday, or a total of $5,000 per class member, as provided for by N.Y. Lab. Law § 198, reasonable
attorneys’ fees, costs, and injunctive and declaratory relief.
THIRD CAUSE OF ACTION
FLSA – Overtime Wages
(Brought on behalf of FLSA Class Representatives and the FLSA Collective)
92. The FLSA Class Representatives reallege and incorporate by reference all
allegations in all preceding paragraphs.
93. The FLSA Class Representatives and members of the FLSA Collective are non-
exempt employees entitled to be paid overtime compensation for all overtime hours worked.
94. Defendants employed Plaintiffs and members of the FLSA Collective for
workweeks longer than 40 hours and willfully did not compensate Plaintiffs for all of the time
worked in excess of 40 hours per week, at a rate of at least one and one-half times their regular
hourly rate, in violation of the requirements of Section 7 of the FLSA, 29 U.S.C. § 207(a) (1).
95. Plaintiffs expressed their consent to make these claims against Defendants by filing
a written consent form, pursuant to 29 U.S.C. § 216(b).
96. Defendants did not make a good faith effort to comply with the FLSA with respect
to their compensation to Plaintiffs and the FLSA Collective.
97. Because Defendants’ violations of the FLSA were willful, a three-year statute of
limitations applies, pursuant to 29 U.S.C. § 255.
98. As a consequence of the underpayment of wages, alleged above, Plaintiffs have
incurred damages thereby and Defendants are indebted to them in the amount of the unpaid
overtime compensation, together with interest, liquidated damages, attorneys’ fees, and costs in an
amount to be determined at trial.
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99. Defendants were or should have been aware that the FLSA required them to pay
their Counselors premium overtime pay for all hours worked in excess of 40 per week.
100. Defendants did not pay Plaintiffs and Class Members overtime wages for their work
in excess of 40 hours per week and this was willful, intentional, and in bad faith
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs seek for the following relief:
A. That, at the earliest possible time, the Court certify this case as a class and collective
action pursuant to CPLR Article 9 and Section 216(b) of the FLSA, and authorize the issuance of
notice to the Class and the FLSA Collective;
B. Designation of Plaintiffs Zoryha Norfleet, Valerie Janowski and Lisa Abbas as the
Class Representatives, and counsel of record as Class Counsel;
C. Unpaid overtime pay permitted by law pursuant to the FLSA, NYLL, and
supporting regulations;
D. Statutory damages, as provided for by N.Y. Lab. Law §§ 195 and 198, for Defendants’
violations of the notice and recordkeeping requirements pursuant to N.Y. Lab. Law § 195;
E. Pre-judgment interest and post-judgment interest as provided by law;
F. Appropriate equitable remedy violations;
G. Attorneys’ fees and costs of the action;
H. Issuance of a declaratory judgment that the practices complained of in this action
are unlawful under N.Y. Lab. Law § 190 et seq.;
I. Such other injunctive and equitable relief as this Court shall deem just and proper;
J. Reasonable incentive awards for Plaintiffs to compensate them for the time they
spent attempting to recover wages for the Class and for the risks they took in doing so; and
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K. Such other relief as this Court shall deem just and proper.
Dated: Melville, New York
October 31, 2023
Respectfully submitted,
By: /s/ Troy L. Kessler
Troy L. Kessler
KESSLER MATURA P.C.
Troy L. Kessler
Tana Forrester
Garrett Kaske
534 Broadhollow Road, Suite 275
Melville, New York 11747
Telephone: (631) 499-9100
tkessler@kesslermatura.com
tforrester@kesslermatura.com
gkaske@kesslermatura.com
Attorneys for Plaintiffs and the Putative
FLSA Collective and Putative Class
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Exhibit A
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DocuSign Envelope ID: 6A1CFDE3-172A-4459-94AD-516DF17F03F1
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/31/2023
CONSENT TO BECOME A PARTY-PLAINTIFF
1. I consent to be a party plaintiff in a lawsuit against my current/former employer, RevCore
Recovery Center Manhattan LLC. (“RevCore”) and any related individuals and entities, for
alleged violations of the Fair Labor Standards Act, 29 U.S.C. § 201, et seq., and the New York
Labor Law.
2. During the past three years, there were occasions when I worked over 40 hours over the course of
the workweek and RevCore did not pay me overtime wages as required by the Fair Labor Standards
Act.
3. I designate Kessler Matura P.C. to represent me and make decisions on my behalf concerning the
litigation, including any settlement. I agree to be bound by any adjudication, whether it is favorable
or unfavorable.
4. I also consent to join any separate or subsequent action to assert my claims against RevCore and/or
any related entities potentially liable.
8/29/2023
Date: ______________ _________________________________
Signature
Lisa Abbas
_________________________________
Print Name
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CONSENT TO BECOME A PARTY-PLAINTIFF
1. I consent to be a party plaintiff in a lawsuit against my current/former employer, RevCore
Recovery Center Manhattan LLC. (“RevCore”) and any related individuals and entities, for
alleged violations of the Fair Labor Standards Act, 29 U.S.C. § 201, et seq., and the New York
Labor Law.
2. During the past three years, there were occasions when I worked over 40 hours over the course of
the workweek and RevCore did not pay me overtime wages as required by the Fair Labor Standards
Act.
3. I designate Kessler Matura P.C. to represent me and make decisions on my behalf concerning the
litigation, including any settlement. I agree to be bound by any adjudication, whether it is favorable
or unfavorable.
4. I also consent to join any separate or subsequent action to assert my claims against RevCore and/or
any related entities potentially liable.
8/25/2023
Date: ______________ _________________________________
Signature
Zoryha Norfleet
_________________________________
Print Name
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