THE IN UNITED STATES DISTRICT COURT IN THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CRYSTAL HOWARD, PAUL GALLOWAY, ROBERT NEWSON, ALVAN YOUNG, and JOHN HUEBNER, Individually, and on Behalf of All Others Similarly Situated, Plaintiffs, v. SECURITAS SECURITY SERVICES, USA INC., Defendant. DECLARATION OF MICHAEL TURSKEY I, MICHAEL TURSKEY, hereby declare under penalty of perjury pursuant to 28 U.S.C. 1746 that the following is true and correct and based upon my personal knowledge, and if called to testify, would state: 1. For the period of approximately November 2002 to March 2007April 2008, I worked full-time as a Supervisor for Securitas for Security Services USA Inc. (Securitas). 2. At various times during my employment with Securitas, I worked as Security Guard, Branch Supervisor, and Shift Supervisor. and Assistant Manager 3. Securitas paid me hourly, and I earned approximately $1313.00 per hour in 2008. ) ) ) ) ) ) ) ) ) ) ) ) )
Hon. Joan B. Gottschall Magistrate Judge Maria Valdez Case No. 08 C 2746
43. During the period of September 2003 through March 2007, I was the Securitas Supervisor at the Champaign, Illinois office of Blue Cross Blue ShieldDuring approximately the last year of my employment with Securitas, I worked at the Motorola site in Arlington Heights, Illinois. 5. During approximately the last year of my employment with Securitas, I worked as a shift supervisor for the _ 3rd shift from 10 p.m. to 6 a.m.a.m. to ___ p.m. shif Yes I was 6. As part of my job duties with Securitas, I was expected and required to arrive on site prior to the start of my scheduled shift time. 7. As part of Securitas practice, I routinely arrived to work approximately 15_ minutes prior to the start of my scheduled shift in order to engage in work related activities.
8. During the time that I was on site prior to the start of my scheduled shift time, I engaged in work related activities as such receiving pass off information from the prior shift, retrieving and inspecting my security guard equipment, and performing head counts on the Motorola employees still on site. 9. At the Motorola site in Arlington Heights, Securitas did not provide the security guards with any timesheets or ways to punch in and out at the start and end of our shifts. 10. Instead, Securitas regularly paid myself and the other guards at the Motorola site based on the number of hours we were scheduled to work, and not the time we actually worked. 11. In fact, the Securitas Site Manager at the Motorola Arlington Heights branch would send the schedule to Securitass payroll department. The payroll department then issued my paycheck and the amount Securitas paid me was based on the hours I was scheduled to work and the amount did not include the time I routinely spent engaging in work activities prior to the start of my scheduled shift, as described above. 12. As part of Securitass practice, myself and other guards would routinely work approximately 10 - 15 minutes past the end of our scheduled shift, and this time was not recorded or tracked by Securitas and I was not paid for the nearly daily occurrence when I worked 10 15 minutes past the end of my scheduled shift time. true As a shift supervisor I managed officers weekly work schedule, but did not have control over any timesheets of any kind. yes many times but to the best of my knowledge I was paid for that time. 13. Under Securitass practice, I was also not allowed to leave the Motorola site during my meal breaks. In fact, I performed my security guard duties throughout my meal breaks and was required to continue to monitor the Motorola site throughout my meal break, which required me to, among other things, perform foot patrol throughout the building and site .true (paid lunch break) Dated: Sept. 25, 2009 Sign Name Print Name MICHAEL TURSKEY