Plaintiff alleges former employer Neuro Solutions failed to pay wages

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Katherine Frank-Klein has taken legal action against her former employers, alleging significant labor law violations. On February 4, 2025, Frank-Klein filed a complaint in the United States District Court for the Southern District of New York against Neuro Solutions 100, LLC and NeuroDynamics 100, Inc., along with their executives Michael Bingham and Mark Keck. The lawsuit claims that these entities failed to pay wages and overtime as required by both federal and New York state laws.

The case revolves around allegations that the defendants violated the Fair Labor Standards Act (FLSA) and New York Labor Law (NYLL) by not compensating employees properly. According to the complaint, Frank-Klein was employed as Chief Operations Officer under a contract that promised an annual salary of $225,000 with a performance-based raise. However, she claims that her salary payments were irregular and ceased almost entirely in early 2025. She alleges that despite working approximately 67 hours per week, she did not receive overtime pay or minimum wage compensation for her work beyond standard hours.

Frank-Klein’s complaint further accuses the defendants of retaliatory actions after she raised concerns about unpaid wages. Following a demand letter sent on January 13, 2026, she was allegedly excluded from critical meetings necessary for her role. This exclusion is claimed to be a direct response to her complaints about payment practices.

The plaintiff also asserts breach of contract due to the failure of NeuroSolutions to provide equity and bonuses as stipulated in her employment agreement. Additionally, she argues that defendants unjustly enriched themselves at her expense by withholding owed compensation.

In seeking redress from the court, Frank-Klein requests various forms of relief including designation of this case as a collective action under FLSA provisions and class action status under Rule 23 for NYLL claims. She seeks damages covering unpaid wages, overtime compensation, liquidated damages for willful violations of labor laws, punitive damages for breach of contract and misappropriation claims, as well as attorneys’ fees and costs associated with the litigation.

Representing Katherine Frank-Klein is attorney Brian L. Greben from his law office located in Great Neck, New York. The case has been assigned Case ID: 1:26-cv-00963 but no judge has been named yet.

Source: 126cv00963_Katherine_Frank_Klein_v_Neuro_Solitions_Complaint_Southern_District_of_New_York.pdf


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