Wage Payment and Collection Act Motions to Dismiss

Motion to Dismiss - Unpaid Wages, Commissions, and Bonuses; Hunt & Associates PC; 12.16.2014

Case Topics: Breach of Contract, Wage Payment and Collection Act, Illinois Sales Representative Act – Grounds for Moving: Illinois Sales Representative Act does not apply to employees but only sales representatives. Illinois Sales Representative and Illinois Wage Payment and Collection Acts do not entitle plaintiff to jury trial. Defendant was not plaintiff's employer.

Motion to Dismiss - Employer Withholding of Final Compensation - Reply; Winston & Strawn LLP; 05.19.2016

Case Topics: Wage Payment and Collection Act, Breach of Contract – Grounds for Moving: Wage Payment and Collections Act only reaches compensation owed upon the employee's exit date. No Illinois case has held shared profits actionable under Wage Payment and Collections Act. Defendants improperly named. Plaintiff failed to perform contractual prerequisites necessary to give rise to alleged profits interest.

Motion to Dismiss - Employer Withholding of Final Compensation - Response Memo; Novack & Macey LLP; 04.27.2016

Case Topics: Wage Payment and Collection Act, Breach of Contract – Grounds for Moving: Wage Payment and Collections Act only reaches compensation owed upon the employee's exit date. No Illinois case has held shared profits actionable under Wage Payment and Collections Act. Defendants improperly named. Plaintiff failed to perform contractual prerequisites necessary to give rise to alleged profits interest.

Motion to Dismiss - Employer Withholding of Final Compensation; Winston & Strawn LLP; 02.29.2016

Case Topics: Wage Payment and Collection Act, Breach of Contract – Grounds for Moving: Illinois Wage Payment and Collections Act only reaches compensation unequivocally owed upon the employee's exit date. No Illinois case has ever held shared profits actionable under Illinois Wage Payment and Collections Act. Defendants are improperly named. Plaintiff failed to perform certain fundamental contractual prerequisites necessary to give rise to alleged profits interest.

Motion to Dismiss - Unpaid Wages, Commissions, and Bonuses - Response; Hunt & Associates PC; 01.20.2015

Plaintiff's Response to Motion to Dismiss Employment Complaint – Case Topics: Breach of Contract, Wage Payment and Collection Act, Illinois Sales Representative Act – Grounds for Moving: Illinois Sales Representative Act does not apply to employees but only sales representatives. Illinois Sales Representative and Illinois Wage Payment and Collection Acts do not entitle plaintiff to jury trial. Defendant was not plaintiff's employer.

Motion to Dismiss - Unpaid Wages, Commissions, and Bonuses - Reply; Seyfarth Shaw LLP; 02.03.2015

Case Topics: Breach of Contract, Wage Payment and Collection Act, Illinois Sales Representative Act – Grounds for Moving: Illinois Sales Representative Act does not apply to employees but only sales representatives. Illinois Sales Representative and Illinois Wage Payment and Collection Acts do not entitle plaintiff to jury trial. Defendant was not plaintiff's employer.