Gabroy Law Offices has filed a class-action lawsuit against Defendant Station Casinos LLC d/b/a and a/k/a KAOS Dayclub And Nightclub and Defendant Red Rock Resorts, Inc. d/b/a and a/k/a KAOS Dayclub And Nightclub (collectively “Defendants”) on behalf of Alyssa Faulstick. Garoy Law Offices has filed this lawsuit under the Worker Adjustment and Retraining Notification Act, 29 U.S.C. § 2101 et seq. (“WARN Act”).
This lawsuit alleges that the Defendants’ failed to pay her, and other similarly situated persons and failed to give her, and other similarly situated persons the required 60-day notice under the WARN Act. The true names and capacities, whether individual, corporate or other business entity, of Defendants DOES 1-10 and ROE corporation 11-20 are unknown to Plaintiff. These DOE/ROE defendants may be parent companies, subsidiary companies, owners, predecessor or successor entities, or business advisors, de facto partners, Plaintiff’s employer, those holding control over Plaintiff’s employment, those allegedly responsible for the allegations contained herein, or joint venturers of any Defendant. Plaintiff is informed and believes and therefore alleges that the Defendants designated herein DOES 1-10 and ROE corporations 11-20 were responsible in some manner for the events and happenings herein referred to and damages thereby to the Plaintiff as alleged herein and were ”Employer(s)” of Plaintiff as that term is defined in the WARN Act. The plaintiff will petition this Court to amend this Complaint to insert the true names of each party designated as Doe and/or Roe Defendant when said parties are ascertained. Plaintiff is informed and believes that each Defendant sued herein as DOE is responsible in some manner for the acts, omissions, or representations alleged herein and any reference to “Defendant” or “Defendants” herein shall mean “Defendants and each of them.”
On or about November 5, 2019, Plaintiff and members of the Class were given notice for the very first time that the “KAOS Dayclub and Nightclub” would be closing and that therefore “all KAOS positions would be eliminated within the next 60 days.” In such November 5, 2019 letter, Defendants offered Plaintiff and those similarly situated a “choice” to either “not continue employment [and] elect to have their position eliminated as of Friday, November 8, 2019” or to “continue to work on an on-call basis.” At no time were Plaintiff and members of her class given lawful notice of the closing of the KAOS Dayclub and Nightclub and/or termination of their employment. Plaintiff is informed and believes that, at a minimum, at least 100 other employees who worked at Defendants’ KAOS Dayclub and Nightclub also failed to receive sufficient notice before the respective location was closed and they were laid off/terminated. Combined, these terminated employees comprise the Class.