Michael Groeneveld v. Verb Technology Company Inc.

I. BACKGROUND

This case involves unpaid wages. Plaintiff Groeneveld filed the Complaint in New Jersey Superior Court, Monmouth County, against Defendants Verb Technology, Cutaia, and Khan as well as several other unidentified individuals. (ECF No. 1-3.) Plaintiff (resident of New Jersey) was employed at Verb Technology (incorporated in Nevada) as the Senior Vice President of Global Sales from September 7, 2021, to November 8, 2022. Ud. J 1-2, 6.) Cutaia, Chief Executive Officer of Verb Technology, and Khan, Executive Vice President and then-interim Chief Financial Officer, were Plaintiff's superiors.' (Id. J 7-8.) Plaintiff alleges that his offer letter from Verb Technology promised annual performance bonuses ranging from $100,000.00 to $190,000.00, conditioned on Plaintiffs achievement of certain to-be-defined performance objectives. (Ud. □□ 9-15.) During Plaintiff's employment, Cutaia and Khan allegedly “agreed that [Plaintiff] was entitled to three quarters of a full year bonus, $142,500,” and Plaintiff then achieved objectives “entitling him to further compensation.” Ud. J] 21-24.) Despite Cutaia and Khan acknowledging that Plaintiff was owed…