Sunday, May 25, 2025

Arbitration for Payroll Structuring and Wage Concealment

 Based on the sources provided, here is a summary of the document and a list of the names involved:

Summary of the Document

This document is an Amended Demand for Arbitration filed by Claimant Jorden Hollingsworth against multiple individuals and entities. The core of the case is alleged to be a deliberate, highly orchestrated corporate scheme designed to misclassify wages, obscure employer liability, and manipulate payroll obligations, while funneling profits through a complex network of successor entities and financial trusts. The scheme also involved a failure to pay final wages on time, as required by law.

The Respondents are accused of engineering a multi-layered payroll structuring operation spanning multiple states and involving at least 30 corporate entities. This operation allegedly functioned through a centralized financial hub at 411 E Bonneville Ave, Las Vegas, NV, which was listed on the Claimant's paystub. At the center of this scheme is "Direct Demo," described as a sales and marketing division for Qunol and Zena Nutrition products. Respondents allegedly structured this business to hire employees under different legal entities (including AMJ Services LLC, DRVM LLC, MK Marketing LLC, and DRC Demo LLC) while falsely presenting them as a single, unified employer. These separate entities were purportedly created solely to shift employer liability, reclassify wages, and conceal financial responsibility.

Claimant was terminated on December 12, 2024, triggering an immediate legal obligation under ORS 652.140 to issue final wages by December 13, 2024. Respondents allegedly failed to pay Claimant until December 27, 2024, which was 14 days late. Under ORS 652.150, failing to pay final wages on time triggers statutory penalty wages, requiring the employer to compensate the employee at their regular daily rate for up to 30 days. Respondents also allegedly failed to pay these penalty wages on time. The refusal to pay penalty wages is described as a deliberate and calculated effort to avoid accountability through the use of shell corporations and successor entities. These tactics allegedly involved systematically dissolving, transferring, and restructuring payroll obligations to obstruct employees from enforcing their wage rights. Employer identity allegedly changed multiple times, and payroll was issued under dissolved or successor entities, creating legal barriers for wage claims.

The document argues that successor entities operated at 411 E Bonneville, assuming payroll functions previously handled by entities like DRVM LLC after its dissolution, but without assuming the associated financial liabilities. This practice is argued to trigger successor liability principles under Oregon law (ORS 60.637, ORS 60.654), which hold that a business continuing the same operations, processing payroll, or financially benefiting from a dissolved entity’s workforce is responsible for outstanding obligations.

Public business registrations are cited as confirming that several payroll-processing and commission-structuring entities are linked to the Boutros Family Foundation. Payments were allegedly structured through multiple entities rather than being issued directly, creating layers of corporate separation.

The scheme is alleged to extend beyond businesses controlled solely by the Boutros family and Deepak Chopra. Sanofi, through its wholly owned subsidiaries, Chattem, Inc. and Quten Research Institute, is alleged to have played a direct financial role in payroll structuring and commission misclassification. Sanofi's subsidiaries allegedly financially controlled Qunol commissions misclassified as wages and had ties to payroll processing and employer identity manipulation through entities at 411 E Bonneville. Payroll funds and commissions allegedly moved through Sanofi-controlled entities, linking them to financial structuring that concealed employer responsibility.

Claimant's wages were manipulated through practices like falsely reflecting excessive work hours on paystubs to conceal misclassified commissions, processing payroll under dissolved entities, and repeatedly changing employer identity to obstruct legal claims. Commissions from Qunol and Zena Nutrition were allegedly reclassified as hourly wages, allowing the employer to manipulate tax obligations and avoid commission-based liability.

The document requests full discovery to clarify the flow of payroll and funds, commission structuring, the role of successor entities, and the relationship between entities. It argues that Respondents cannot obstruct payroll transparency to conceal wage violations and that failure to provide discovery should result in an adverse inference ruling.

Claimant requests that the arbitrator hold all named Respondents jointly and severally liable for unpaid wages, misclassified earnings, and financial mismanagement where successor liability applies. Full financial discovery is sought, along with statutory penalty wages under ORS 652.140 and ORS 652.150. The document argues for piercing the corporate veil to hold individual Respondents and corporate parents like Sanofi personally liable due to deliberate fraud, abuse of corporate formalities, inadequate capitalization, and the resulting injustice if they were allowed to escape liability.

Respondents may attempt procedural defenses, but the document argues these fail because JAMS has jurisdiction, a motion to dismiss is improper, employer identity concealment does not shield liability, late payment does not cancel penalty wages, successor businesses cannot avoid wage liabilities, veil piercing is supported by precedent, and discovery is necessary.

Claimant seeks a total of $300,000 in damages, including unpaid wages, misclassified commissions, $10,050 in penalty wages, compensatory, general, and punitive damages, successor liability damages, personal liability, and legal fees/arbitration costs. The document asserts that Respondents acted in bad faith by deliberately withholding wages, concealing employer identity, misclassifying wages, and ignoring Claimant's hardship.

The document concludes that the case is a deliberate financial strategy to conceal employer identity, misclassify commissions, funnel profits, and use successor businesses to shield Respondents from financial responsibility. Arbitration must enforce full successor liability, mandate payroll transparency, impose maximum statutory penalties, and hold all Respondents, including Sanofi and its subsidiaries, personally liable.

Names Involved

Here is a list of all individuals, entities, brands, laws, rules, and case law mentioned in the document:

Individuals (Claimant and Respondents):

  • Jorden Hollingsworth
  • Ashraf “Peter” Boutros
  • Deepak Chopra
  • Maged “Mike” Boutros
  • Osama Boutros
  • Marie-Laurie Amiard-Boutros
  • Collins Coltharp

Corporate/Business Entities & Brands:

  • DRVM LLC
  • AMJ Services LLC
  • Ashraf “Peter” Boutros
  • Deepak Chopra
  • Maged “Mike” Boutros
  • Marie-Laurie Amiard-Boutros
  • Chattem, Inc.
  • Quten Research Institute LLC
  • Sanofi-Aventis U.S. LLC
  • Sanofi
  • Osama Boutros
  • MK Marketing LLC
  • DRC Demo LLC
  • "Direct Demo"
  • Qunol
  • Zena Nutrition
  • Boutros Family Foundation
  • Basil Management Trust
  • Rita GP Partners LLC
  • VitaMina Labs LLC
  • Zena Nutrition Inc.
  • FC – Nevada Inc.
  • Boutros Boys Inc.
  • TPD IP LLC
  • QIP Management Trust
  • MK Marketing LLC (Washington)
  • Pishoy Holdings LLC
  • QRIB Intermediate Holdings
  • MAK Nutrition LLC
  • MAK Media LLC
  • Mina Management
  • PB Management Trust
  • Mina GP Partners LLC
  • MAK Digital LLC
  • AMJ, LLC
  • ADP

Arbitration Forum & Rules:

  • JAMS
  • JAMS Rule 24(c)

Laws & Rules:

  • ORS 652.140
  • ORS 652.150
  • ORS 60.637
  • ORS 60.654
  • ORS 652.200
  • FRCP 8(a)

Case Law:

  • Schreiber v. Friedman (JAMS 2016)
  • Amfac Foods, Inc. v. Int’l Systems & Controls Corp. (1982)
  • Klokke Corp. v. Classic Exposition, Inc. (1996)
  • Pettit v. Price (2004)
  • State ex rel Neidig v. Superior National Insurance Co. (2007)
  • Russell v. U.S. Bank National Association (2012)
  • Wills v. Enloe (2005)
  • Sabin v. Willamette-Western Corp. (1976)
  • Doyle v. City of Medford (2014)
  • Wyatt v. Body Imaging (2011)
  • Wilson v. Smurfit Newsprint Corp. (2009)
  • Eclectic Investments, LLC v. Conner (2014)
  • Belknap v. U.S. Bank Nat’l Ass’n (2010)

Locations/Addresses:

  • 411 E Bonneville Ave, Las Vegas, NV
  • 15 Vela Way, Bridgewater, NJ
  • Sanofi U.S. Headquarters (address reference)

This list includes all unique names as requested by your query.

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