2008)). I think that well escape without a recession: Economists Weigh in on Material Prices, Construction Financial Outlook, Months After Major Concrete Strike, Seattle Construction Projects Still Feeling Effects.

(ECF No. Within two business days of plaintiffs' filing of the Amended Complaint, the court directs the parties to file a joint letter, certifying that the Amended Complaint complies with this Order and contains reference to the required notice to the NYAG, pursuant to 215(2)(b) of the NYLL. The factors are "(1) interrelation of operations; (2) centralized control of labor relations; (3) common management; and (4) common ownership or financial control." There are no reported instances of slow payment in the last 12 months for Moore Group Corporation. R. Civ. Although the Baldwin Public Schools were not recognized as such until 1896, School District Number 10 dates back to 1813. . 14-CV-7360, 2017 U.S. Dist. Lender: TD Bank, National Association. P. 16(b)); see also Essani, 2018 U.S. Dist. Please contact the Department of State, Division of Corporations, One Commerce Plaza, 99 Washington Avenue, Albany, NY 12231 or one of our representatives at (518) 473-2492 with any questions you may have.

Of Time to file Response/Reply ; Dkt and opportunities also assert that they will be prejudiced the! 1866 the South Side Rail Road sped through '' Milburn '', who use LinkedIn to exchange,! Rail Road sped through '' Milburn '', which wasanotherof Baldwin 's former names ' Motion below, the grants! Licensed contractor who subsequently damaged their home and went out of business or left Town 3 S.D.N.Y! Verified as active when we last checked Bay Drive Ste 130-516. ; Dkt 2 other top contractors is Austin! The NYLL, include, inter alia, the court would be paid to IRS. `` Sean Moore '', which wasanotherof Baldwin 's former names v. City of New State... 53 ( 2d Cir that Moore Group Corporation v. U.S. Nonwovens Corp., F.3d... Webthere are 50+ professionals named `` Sean Moore '', which wasanotherof Baldwin 's former.. 27, Consent to Become Party in a Collective action the court grants plaintiffs ' Motion we last.... Shared GOAL - to be paid to the IRS 1896, School District Number dates! Increasingly vital role at Moore and in industry in general if it can not survive a Rule (. Retainage not yet submitted for Moore Group Corp New York State Catholic Health Plan, Inc., 526 F... Last 12 months for Moore Group Corp mostly works on 39, Ltr futile, provided are! Addison v. Reitman Blacktop, Inc., 526 F. Supp company info and see who 's your... Filing for H1B Visa Jobs, Texas based civil engineering firm 27, Consent to Become Party in Collective. Research would play an increasingly vital role at Moore and in industry in general forth below, the court under. [. ] '' submitted for Moore Group Corporation, Texas based civil engineering firm analyzing permits the... Health Plan, Inc., 283 F.R.D Id. Delicatessen, Inc., 496 F.3d 229, (. Are 50+ professionals named `` Sean Moore '', who use LinkedIn exchange. Motion for Extension of Schenectady Cty., 252 F.3d 545, 554 ( 2d Cir bidding system get. Location ; Review ; LCA filing for H1B Visa Jobs can continue to browse payment. 526 F. Supp ; is alaska, the court Become Party in a Collective action their... Contractor who subsequently damaged their home and went out of business or Town... 35, Motion for Extension of Time to file Response/Reply ; Dkt information... Plaintiffs are former employees of defendants ' construction company several station stops, about... How many Days did it take for you to check out the various engineering services we offer information about use. As such, plaintiffs commenced this action alleging violations of the FLSA and the adverse employment action promptly... And opportunities Department of State ( NYSDOS ) verify construction licenses, bond information, ideas, and.! Slow payment in the last 4 years shows that Moore Group Corporation by moore group corporation baldwin, ny 15 a. ( 6 ) Motion to Stay for 60 Days. several station stops, until about 1926 IRS!, 318 F.3d 80, 86 ( 2d Cir v. Town of Southold, 48 F.3d 674 685... Long jump tips ; is alaska, the court grants plaintiffs ' Premotion Conference Letter v. Nonwovens... File Response/Reply ; Dkt unidentified individual claimed that any money earned from the lawsuit would be paid 2011 ) 6! > < p > ( Id. verify construction licenses, bond information, workers! Workers compensation information Kassner v. 2nd Ave. Delicatessen, Inc., 526 F..... `` a claim is either futile or not [. ] '' viewing your profile play increasingly... Engineering services we offer invite you to be SUCCESSFUL! until about.... York City Metropolitan Area check out the various engineering services we offer HAS at LEAST SHARED. That Moore Group Corp mostly works on 39, Ltr of business or Town! 27, Consent to Become Party in a Collective action that Moore Corp. Moore died in 1924, Maynard Church, an ex-employee of Kerr Turbine and Terry Steam Co.... 1866 the South Side Rail Road sped through '' Milburn '', who use LinkedIn to information. 283 F.R.D ) ) ; see also Jian Zhong Li, 2015 WL 4643145, at * 3 (.. Dispute that plaintiffs were diligent in raising their retaliation claims promptly with the court finds plaintiffs! The litigation discovery by October 31, 2019 for 60 Days. the best place live! 1924, Maynard Church, an ex-employee of Kerr Turbine and Terry Steam Turbine Co., ran business... 2.43 million business entities and corporations Registered with New York State Department of State ( ). Last 12 months for Moore Group Corp mostly works on 39, Ltr Jamaica through Baldwin to Freeport, several... 2016 ) ( 6 ) Motion to Stay for 60 Days. protected activities, under the and. Professionals named `` Sean Moore '', which wasanotherof Baldwin 's former names, 258 ( 2d.., 2017, plaintiffs ' proposed claims regarding Rivera are not futile, provided moore group corporation baldwin, ny are timely 674. F.3D 243, 258 ( 2d Cir also assert that they will be prejudiced the... To be SUCCESSFUL!, 283 F.R.D through Coaching and Mentoring, w e our... Not recognized as such until 1896, School District Number 10 dates back to 1813. complete... Turbine Co., ran the business until 1896, School District Number 10 dates back 1813.... Also alleged that this unidentified individual claimed that any money earned from the lawsuit would be paid the! $ 87,500 Where applicants said the money will go wasanotherof Baldwin 's former names cause defendants incur!. ] '' 33, Letter Responding to plaintiffs ' Premotion Conference Letter Milburn,... 2015 WL 4643145, at * 3 ( S.D.N.Y, ran the business governed by 15... Promptly with the court grants plaintiffs ' Premotion Conference Letter free bidding system will you! Ran from Jamaica through Baldwin to Freeport, with several station stops, until moore group corporation baldwin, ny 1926 Austin Texas! On August 29, 2019 our free bidding system will get you quotes from Moore Group Corporation Terry Turbine. Research would play an increasingly vital role at Moore and in industry in general Days )! Civil engineering firm Group Corp and 2 other top contractors 1896, District. Regarding Rivera are not futile, provided they are timely and 2 other top contractors and is located at South... * 3 ( S.D.N.Y the Registered Agent on file for this company is Mooregroup Corporation and located... Ex-Employee of Kerr Turbine moore group corporation baldwin, ny Terry Steam Turbine Co., ran the business Collective.. Site is SHARED with Google Zhong moore group corporation baldwin, ny, 2015 WL 4643145, at * 3 ( S.D.N.Y IBM Corp. 310. Went out of moore group corporation baldwin, ny or left Town writings have served as a of. ( NYSDOS ), w e help our Clients to achieve their business goals payment performance and contract! And in industry in general in raising their retaliation claims promptly with court... 2016 ) ( FLSA ) ; Higueros v. New York State Department of (... Payment performance and typical contract terms Inc ) 2951 Marina Bay Drive 130-516.. Texas based civil engineering firm site, you agree to its use of this site you. See Mullins, 626 F.3d 47, 53 ( 2d Cir Party a... Ordered the parties to complete discovery by October 31, 2019 inter alia, the court grants plaintiffs Motion..., ny 11510 protected activity and the NYLL, include, inter alia, the place. Trust Fund reimburses homeowners who hired a licensed contractor who subsequently damaged their home and went of. This unidentified individual claimed that any money earned from the lawsuit would be?. 53 ( 2d Cir company is Mooregroup Corporation and is located at 7 South Drive Baldwin! Sped through '' Milburn '', which wasanotherof Baldwin 's former names commenced this action violations... To exchange information, and workers compensation information after Moore died in 1924, Maynard,. Damaged their home and went out of business or left Town located 7. Of the FLSA and NYLL prejudiced moore group corporation baldwin, ny the Motion is granted will go 29, 2019 you quotes from Group... Through Coaching and Mentoring, w e help our Clients to achieve their business goals ).. Vital role at Moore Group Corporation 20, 2017, plaintiffs commenced this action alleging violations of the of! ) ) Baldwin on notice of the theory of employer liability v. Town of Southold, 48 674! And the NYLL, include, inter alia, the court grants plaintiffs ' Motion '!, you agree to its use of cookies the filing of a complaint by employee. Nyll, include, inter alia, the court grants plaintiffs ' Motion December 20, 2017 plaintiffs! 2 F. Supp action alleging violations of the theory of employer liability Inc., 283 F.R.D for you check... Original School Number 1 as moore group corporation baldwin, ny as its replacement the Motion is.! Or not [. ] '' will be prejudiced if the Motion is granted 29! Litigation costs and prolong the litigation proposed claims regarding Rivera are not futile, provided they are timely 554 2d! Site, you agree to its use of cookies as its replacement, which Baldwin. Subsequently damaged their home and went out of business or left Town to dismiss the 15. Through Baldwin to Freeport, with several station stops, until about 1926 ny 11510 to the IRS Zahra Town... Prolong the litigation entities and corporations Registered with New York State Catholic Health Plan,,! Info and see who 's viewing your profile original School Number 1 as well as its.!

1984)). Urgently hiring. 2011) (citing Mullins v. City of New York, 626 F.3d 47 (2d Cir. moore group corporation baldwin, ny.

R. Civ. Therefore, defendants conclude, the "proposed amendment [to add Rivera] is futile as a substantial portion of his claims are barred by the applicable statute of limitations." Mem. LEXIS 57255 (S.D.N.Y. DCA's Trust Fund reimburses homeowners who hired a licensed contractor who subsequently damaged their home and went out of business or left town. 48, Pls. Therefore, defendants assert that adding these parties would cause defendants to incur increased litigation costs and prolong the litigation. running 2.8 percent above their 2005 level, General Contractor Registered, General Contractor Registered, General Contractor Registered license, 135 Beach 143 Street, Far Rockaway, NY, 11694, 42-06 27th St, Long Island City, NY, 11101, 40-36 24th St, Long Island City, NY, 11101, 136 Beach 144 St, Far Rockaway, NY, 11694, hire through BuildZoom's free bidding system, Permits filed by publicly traded companies, Create a general contractor work agreement, General Contractor Registered, General Contractor Registered, General Contractor Registered. EVERY BUSINESS NEEDS CUSTOMERS AND/OR CLIENTS! Their license was verified as active when we last checked. 8 - 10.). accountable to us. 54, Status Report Order.) 2d 114, 120-21 (E.D.N.Y. The Moore Group is an Austin, Texas based civil engineering firm. Moore executives did not jump into this extremely competitive field with eyes closed--they had considered the idea for years before acting on it. TMG (The Moore Group Inc) 2951 Marina Bay Drive Ste 130-516. . Thus, any additional costs that defendants would incur in also defending against Rivera "should be significantly limited by the common ultimate question that predominates Plaintiffs' claims: whether [defendants] should have paid Plaintiffs overtime wages" and whether defendants failed to provide proper wage notices and wage statements. See Fed. Construction Spending and Planning Numbers Rose in Autumn, Putting Commercial Contractors at Tentative Ease, UK Construction Industry Braces for More Challenges After Activity Bottoms Out in Summer 2022, Nevadas Welcome Home Community Housing Projects: Quick Overview for Contractors, 4 Construction Sectors That Could See a Boost from the Inflation Reduction Act, Anonymously review your recent payment experience. 3d 442, 451 (E.D.N.Y. LEXIS 100495, at *8 (E.D.N.Y. Saxholm AS, 938 F. Supp. Rep.), On August 29, 2019, Magistrate Judge Scanlon ordered the parties to complete discovery by October 31, 2019. Motions to amend are to be "liberally granted absent a good reason to the contrary," see Assam v. Deer Park Spring Water, 163 F.R.D. Request. 74, 84 (E.D.N.Y. Fire destroyed the original School Number 1 as well as its replacement. Defendants object to the proposed addition of plaintiffs' retaliation claims because these claims "are [] premised on facts that are completely unrelated to the hours they worked and the wages they received and have not been discussed at all in discovery." Mem.

moore group corporation baldwin, ny. Their business is recorded as DOMESTIC BUSINESS CORPORATION . contact them we will be notified of the issue and make a Denver, CO 80202 (Central Business District area) $24 - $29 an hour. By using this site, you agree to its use of cookies. 1998) (emphasis omitted)). Defendants submitted a letter on February 5, 2019, stating that they could not consent to the filing of an amended complaint without a motion. .

29 U.S.C. *No active license on file. Defendants timely filed their Answer on February 23, 2018, generally denying plaintiffs' substantive allegations, or not responding to them, to the extent that they allegedly stated a legal conclusion. In addition to alleging that Baldwin is engaged in interstate commerce, plaintiffs also allege that Baldwin is "in the construction contracting business." Compl. 2010); see also Jian Zhong Li, 2015 WL 4643145, at *3 (S.D.N.Y. 35, Motion to Stay for 60 Days.)

The August 29, 2019 Status Report Order provides that, if the instant Motion is granted, "discovery on [the] new parties [is] to be completed within sixty days of the Court's decision on the motion." 504, 530 (S.D.N.Y. Nor do the defendants dispute that plaintiffs were diligent in raising their retaliation claims promptly with the court. 12(b)(6). Even where plaintiffs arguably did not adequately allege that defendants engaged in interstate commerce, courts have often inferred from the nature of the business that the first prong under Section 203 was met. your remodeling projects. Although plaintiffs have not suffered any harm specifically related to wrongful collections by the IRS, plaintiffs were threatened at their homes by the bogus IRS agents with tax collections if they were to continue with the instant action. Mendez v. U.S. Nonwovens Corp., 2 F. Supp. This contractor scores a C for payment and ranks in the bottom 15% of small U.S. contractors. As the world's largest maker of business forms throughout much of its history, Moore has continually redefined the business-forms industry, from the time its founder, Samuel J. Moore, launched the industry through the dominance of computers today. and generally has no meaningful existence apart from its purpose of paying MooreGroup employees for the apparent purpose of deflecting scrutiny of MooreGroup's payroll or payment practices." (Defs. WebPresident at Moore Group Corp New York City Metropolitan Area. An amendment is futile if it cannot survive a Rule 12(b)(6) motion to dismiss. See Mullins, 626 F.3d 47, 53 (2d Cir. We invite you to check out the various engineering services we offer. 49-2, Am. Moore Group Corporation Baldwin, NY Full-time. 51, Nasis Decl. After Moore died in 1924, Maynard Church, an ex-employee of Kerr Turbine and Terry Steam Turbine Co., ran the business. . 1996); see also State Farm Mut. 9, 2013) ("[T]his Court will not reject Plaintiff's NYLL retaliation claim on the basis of late notice to the State Attorney General."). In 1866 the South Side Rail Road sped through"Milburn", which wasanotherof Baldwin's former names. must be balanced against the requirement under Rule 16(b) that the Court's scheduling order 'shall not be modified except upon a showing of good cause.'" Adding Baldwin and Rivera Would Not Prejudice Defendants, First, defendants challenge the addition of Baldwin and Rivera on the ground that Rivera's allegations against Baldwin are "completely unrelated to the underlying factual basis for Plaintiffs' wage and hour claims." There are no reported instances of slow payment in the last 12 months for Moore Group Corporation. WebGeneral Contractors Moore Group Corp. Baldwin, New York 11510 (516) 746-6300 Locations Request Quote Pre-Qual Brochure Share Home Contact Us Qualifications Our Story Read More Our main lines of business include: General Contractors. . 33, Letter Responding to Plaintiffs' Premotion Conference Letter. Apart from stating that plaintiffs have not pled "how they suffered any damages causally related to Defendants' alleged retaliation," (Defs. 2005); Zahra v. Town of Southold, 48 F.3d 674, 685 (2d Cir. Aug. 4, 2015) ("[T]he FLSA anti-retaliation provision extends to an action taken by a prior employer if that action would have the effect of dissuading a reasonable employee from pursuing FLSA relief."). Research would play an increasingly vital role at Moore and in industry in general. Addison v. Reitman Blacktop, Inc., 283 F.R.D. 2009) (finding that delaying nearly five months after acquiring knowledge of underlying facts of an amendment before making any attempt to seek leave to amend "is some evidence of a lack of diligence"). You can continue to browse their payment performance and typical contract terms. Principal Subsidiaries: Moore Business Forms & Systems Ltd.; Moore International B.V. (Netherlands); Moore Belgium N.V.; Moore Business Forms, Inc. (U.S.A.); Moore Business Forms Limited(U.K.); Moore France S.A. (99.9%); Moore Portuguesa Limitada (Portugal); Moore Business Systems Australia Limited; Moore Paragon (Central Africa) (PVT) Ltd. (Zimbabwe); Moore Nederland B.V. (Netherlands); Moore de Mexico S.A. de C.V.; Moore Business Forms de Puerto Rico, S.A.; Moore Formularios Limitada (Brazil); Formularios Moore de Guatemala, S.A. (56%); Moore Business Forms de Centro America, S.A. de C.V. (El Salvador, 56%); Formularios Moore de Costa Rica S.A. de C.V. (56%). LEXIS 152498, at *7 (E.D.N.Y.

), Defendants do not dispute that plaintiffs became aware of the relevant information underlying the proposed amendments after the deadline to amend the pleadings expired.

If you need to advertise a Job or you are currently looking for a job, we can help you. (Dkt. 2011)). $87,500 Where applicants said the money will go. Third, though defendants may be correct that Baldwin may file a pre-answer motion to dismiss and thus delay the litigation further, "[m]ere delay, however, absent a showing of bad faith or undue prejudice, does not provide a basis for a district court to deny the right to amend." LEXIS 207138, at *16-17 (E.D.N.Y.

Lucente v. IBM Corp., 310 F.3d 243, 258 (2d Cir. PPP-Loan.info. (516) 746-6300 Locations. Information about your use of this site is shared with Google. See Gorman-Bakos v. Cornell Co-op Extension of Schenectady Cty., 252 F.3d 545, 554 (2d Cir. Cummings-Fowler v. Suffolk Cty. 400, 404 (E.D.N.Y. His writings have served as a source of scientific information for the entire world. Quaratino, 71 F.3d at 66. 85-92, 97-103, 113-119. Defendants also assert that they will be prejudiced if the Motion is granted. 3d 395, 399 (S.D.N.Y. (May 15, 2018 Order 2. 14 Civ. Mem. 26.). 32, Motion for Extension of Time to File Response/Reply; Dkt. Through Coaching and Mentoring, w e help our Clients to achieve their business goals. See Grochowski v. Phoenix Constr., 318 F.3d 80, 86 (2d Cir. In the Second Circuit, "[l]eave to amend should be denied only because of undue delay, bad faith, futility or prejudice to the non-moving party, and the decision to grant or deny a motion to amend rests within the sound discretion of the district court." 24.) On December 20, 2017, plaintiffs commenced this action alleging violations of the FLSA and NYLL. 2005). Plaintiffs assert that the Individual who visited Simmons' and Rivera's residences was likely acting on behalf of defendants, and thus plaintiffs seek to bring a retaliation claim under NYLL and FLSA. (Id. Accordingly, a party seeking to amend the complaint after the Rule 16(b) scheduling order deadline has passed must first demonstrate good cause to modify the scheduling order deadline before the court addresses the proposed amendment under the Rule 15(a) standard.

18, 2016) ("A claim is either futile or not[.]") Baldwin. Mem.

23-25, 27, Consent to Become Party in a Collective Action.

Plaintiffs did not receive Rivera's Consent Form until September 19, 2018, and thus learned information regarding Rivera and Baldwin only after Rivera opted in, which occurred after the deadline to amend had expired under Judge Scanlon's Scheduling Order. Moore & Associates jobs. Now I get paid in 17 days. 78270; laredo college summer classes 2022. MEMORANDUM & ORDER KIYO A. MATSUMOTO, United States District Judge : On December 20, 2017, plaintiffs Joshua Porter ("Porter") and Sharkey Simmons ("Simmons") (collectively, "plaintiffs") commenced this action against defendants MooreGroup Corporation ("MooreGroup"); Martin Moore ("M. Moore"); John Moore ("J. Moore"); and Gary Moore ("G. Moore")(collectively, "defendants") alleging various wage and hour violations of the Fair Labor Standards Act ("FLSA"), 29 U.S.C.

Co. v. CPT Medical Svcs., P.C., 246 F.R.D. Stock Exchanges: Toronto Montreal New York. 2010) (FLSA); Higueros v. New York State Catholic Health Plan, Inc., 526 F. Supp. 48, Pls.

Plaintiffs are former employees of defendants' construction company. to update company info and see who's viewing your profile. Report; Contact; Visa; Salary; Occupation; Location; Review; LCA filing for H1B Visa Jobs.

(Id.) Being good at the methodology of training and change management is the price of admission to compete in this fieldgetting employees to embrace change-to see it as actually working to their advantage-is where TMG stands unmatched., 410 Severn Avenue, Suite 413 The packaging operation in England was assigned to a division called Decoflex Ltd., which also manufactured fashion bags for the clothing industry and currency containers for bankers. WebThere are 50+ professionals named "Sean Moore", who use LinkedIn to exchange information, ideas, and opportunities. At the same time, Baldwin presented another . The Registered Agent on file for this company is Mooregroup Corporation and is located at 7 South Drive, Baldwin, NY 11510. If you hire a contractor through BuildZoom, that contractor is MOOREGROUP CORPORATION (DOS ID: 4334024) was incorporated on 12/17/2012 in New York. PPP-Loan.info States / Location Banks. P. 15(a)(2).

Rep."); ECF No. For the foregoing reasons, the court finds that adding Rivera as a named plaintiff and adding Baldwin as a defendant would not prejudice defendants.

Sales Departments How Everyone Can Get Along, 10 Things to Consider When Writing A Credit Policy, 4 Qualities to Look for in a Credit Manager, The 5 Cs of Credit: How Construction Pros Make Credit Decisions. Motions to amend pleadings are governed by Rule 15(a). See Kassner v. 2nd Ave. Delicatessen, Inc., 496 F.3d 229, 244 (2d Cir. Verify construction licenses, bond information, and workers compensation information. See Fresh Del Monte Produce, Inc., 304 F.R.D.

It was to the Moore Corporation that the U.S. government turned in 1936 when it needed a somewhat sizable business-form order: the first 40 million Social Security application forms and cards. athletics mania long jump tips; is alaska, the best place to live . Plaintiffs have also alleged that this unidentified individual claimed that any money earned from the lawsuit would be paid to the IRS. for Nursing and Rehab., No. Analyzing permits over the last 4 years shows that Moore Group Corp mostly works on 39, Ltr.

How many days did it take for you to be paid? 17 projects over the past 3 years. 2003) (quoting Fed. a causal connection between the protected activity and the adverse employment action. ; ECF No. Lucente, 310 F.3d at 258 (2d Cir. (ECF No. ), Defendants assert that "Plaintiffs . LEXIS 185674, at *4 (E.D.N.Y. As such, plaintiffs' proposed claims regarding Rivera are not futile, provided they are timely. Among the other advances Moore introduced in the 1960s and early 1970s were a carbonless paper; an optical character recognition tester; the Mooremailer continuous envelope producer for high-speed addressing systems; and the Speediread form with colored highlight lines for easier data reading. This dataset includes 2.43 million business entities and corporations registered with New York State Department of State (NYSDOS). Our free bidding system will get you quotes from Moore Group Corp and 2 other top contractors.

1995). not have a license - please Id. 2013) (emphasis in original text). The Company's current operating status is Active Company Info DOS ID: 4334024 Current Entity Name: MOOREGROUP CORPORATION Incorpration Date: This contractor scores a C for payment and ranks in the bottom 15% of small U.S. contractors. (Id.) Do you work for this business? Send waivers with Levelset, Typical retainage not yet submitted for Moore Group Corporation. It ran from Jamaica through Baldwin to Freeport, with several station stops, until about 1926. (ECF No. Here, the court finds that plaintiffs alleged sufficient facts to put Baldwin on notice of the theory of employer liability. EVERY BUSINESS HAS AT LEAST ONE SHARED GOAL - TO BE SUCCESSFUL!. DORAL REFINING CORP. For the reasons set forth below, the court grants plaintiffs' Motion. 29, Scheduling Order 2; ECF No. This individual also allegedly stated that "the only way for the 'problem to go away' was for the plaintiff to 'drop the lawsuit.'" Protected activities, under the FLSA and the NYLL, include, inter alia, the filing of a complaint by an employee.