Complaint,Petition: PAIGE E. MORTON v. JAX CROWN TOWN GRILL, INC.

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                                45D02-2406-PL-000410                                Filed: 6/18/2024 9:49 AM
                                                                                                            Clerk
                                   Lake Superior Court, Civil Division 2                    Lake County, Indiana




STATE OF INDIANA                       )     IN THE LAKE SUPERIOR COURT
                                       ) SS:
COUNTY OF LAKE                         )     CONTINUOUS TERM 2024

PAIGE MORTON,                                   )
     Plaintiff,                                 )
                                                )
   vs.                                          )         CAUSE NO.:
                                                )
JAX CROWN TOWN GRILL, INC.,                     )
     Defendant.                                 )

                             COMPLAINT FOR UNPAID WAGES

         Comes now the Plaintiff, PAIGE MORTON, by and through counsel, ARMAN G.

SARKISIAN of SARKISIAN, SARKISIAN & ASSOCIATES, P.C., and for her cause of action

against the Defendant, JAX CROWN TOWN GRILL, INC., alleges and states as follows:

         1.    That the Defendant, JAX CROWN TOWN GRILL, INC., is a for-profit business

entity organized and/or licensed to operate in the State of Indiana.

         2.    That at all relevant times herein the Plaintiff, PAIGE MORTON, was an

employee of the Defendant.

         3.    That the employment relationship has ended.

         4.    That there are unpaid wages due and payable to Plaintiff by Defendant.

         5.    That Plaintiff has made demands for payment to Defendant, verbally and in

writing.

         6.    That Defendant did issue a check for a portion of the wages dated March 8, 2024,

however that check came back unpayable, thus damaging Plaintiff further.

         7.    That to date, the wages remain unpaid.

         8.    That Plaintiff brings this action by and through the applicable wage payment
statutes of Indiana, and seeks damages that shall include the unpaid wages, attorneys fees, costs

of this action, prejudgment interest, and liquidated damages on the unpaid wages.

       9.      That Defendant has a legal duty to pay Plaintiff her wages.

       10.     That Defendant has breached that duty and continues to.

       WHEREFORE, the Plaintiff, PAIGE MORTON, prays for judgment against the

Defendant, JAX CROWN TOWN GRILL, INC., in a just and proper sum, for the costs of this

action, and for all other just and proper relief in the premises.

                                               Respectfully submitted,



                                               /s/ Arman G. Sarkisian
                                               Arman G. Sarkisian (28767-64)
                                               SARKISIAN, SARKISIAN & ASSOC., P.C.
                                               Attorneys for Plaintiff
                                               3645 Willowcreek Road
                                               Portage, Indiana 46368
                                               219-762-7718
                                               Arman@Sarklawfirm.com