Replies to post #78005 on Hiru Corporation (HIRU)

[satter]

Personally, I see red flags. In their April 29th/2025 OTC Disclosure and news service press release Hiru included this:-

https://www.otcmarkets.com/stock/HIRU/news/HIRU-Corporation-Provides-Update-on-Late-Filing-Corporate-Transformation-and-Strategic-Outlook?id=475225

Additionally, a dedicated legal team has been engaged to protect the company's interests and reputation, including addressing actions stemming from the prior ownership and management.

We know that, so far they have not responded to a plaintiff's motion for summary judgment seeking millions in damages. In that case Hiru's lawyer withdrew and no new lawyer has been assigned to the case, or if so, they have not notified the court. Some say its frivolous and related to prior management. Well, the above states they engaged a new legal team to address exactly that.

However, I found another case where past employees sued claiming they were not paid overtime pay. In that case Hiru a defendant, did not respond, and a default judgment was issued on June 11th, 2025. Granted it was a very small amount $117,623 but it just does not add up to me. They say it themselves to defend their reputation, that they have a new dedicated legal team for it. And with all this sheik Arab money, what's the problem? why no operational websites? I don't know what's going on, just think there are reasons to be concerned.


Complaint.

Isaac P. Hernandez, Esq. (SBN 025537)
Thunderbird Law Group
361 E. Coronado Rd., Ste. 201
Phoenix, Arizona 85004
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiffs
IN THE SUPERIOR COURT OF THE STATE OF ARIZONA
IN AND FOR THE COUNTY OF MARICOPA
Mirna Bernal Ayon, Arnulfo Bernal
Ayon and Elvira Carolina Ayon
Pedroza,
Plaintiffs,
vs.
Hiru Corporation, a Georgia
corporation, AZ Custom Bottled
Water, LLC, a Nevada corporation,
Salome Water and Ice, LLC, a
Nevada corporation, Joel Natario, an
individual and Kathryn Gavin, an
individual,
Defendants.
Case No. CV2023-020218
FIRST AMENDED COMPLAINT

Plaintiffs Mirna Bernal Ayon, Arnulfo Bernal Ayon and Elvira Carolina
Ayon Pedroza (“Plaintiffs”), hereby allege in support of their Complaint against
Defendants Hiru Corporation, AZ Custom Bottled Water, LLC, Salome Water and
Ice, LLC, Joel Natario, and Kathryn Gavin (“Defendants”), as follows:

NATURE OF THE ACTION
1. Plaintiffs bring this action pursuant to the Fair Labor Standards Act
(“FLSA”), 29 U.S.C. §201, et seq., and the Arizona Minimum Wage Act
(“AMWA”), A.R.S. §23-362, et seq.

2. Plaintiffs contend that Defendants failed to compensate Plaintiffs for
all hours of work and failed to compensate Plaintiff the overtime rate for certain
time periods in which they worked more than forty hours in a workweek, thereby
depriving Plaintiffs of compensation to which they are entitled.

3. Plaintiffs seek backpay for nonpayment and underpayment of wages
and overtime, liquidated damages, attorney’s fees and costs, and other relief
available under the FLSA, AMWA, and any other applicable law.

PARTIES
4. Plaintiff Mirna Bernal Ayon (“Plaintiff Mirna”) was at all times
relevant to this matter a resident of Maricopa County, Arizona.
5. Plaintiff Elvira Carolina Ayon Pedroza (“Plaintiff Elvira”) was at all
times relevant to this matter a resident of Maricopa County, Arizona.
6. Plaintiff Arnulfo Bernal Ayon (“Plaintiff Arnulfo”) was at all times
relevant to this matter a resident of Maricopa County, Arizona.
7. Defendant Hiru Corporation, (“HIRU) is a Georgia corporation
conducting business in Maricopa County, Arizona and throughout the State of
Arizona.
8. Defendant AZ Custom Bottled Water, LLC, (“AZCBW”) is a Nevada
corporation conducting business in Maricopa County, Arizona and throughout the
State of Arizona.
9. Defendant Salome Water and Ice, LLC, (“SWI”) is a Nevada
corporation conducting business in Maricopa County, Arizona and throughout the
State of Arizona.
10. Upon information and belief, Defendants HIRU, AZCBW and SWI
shared common ownership and management during the relevant time period.
11. Upon information and belief, Defendants HIRU, AZCBW and SWI
share common human resources personnel and functions.
12. Upon information and belief, Defendants HIRU, AZCBW and SWI
share legal counsel/
13. Upon information and belief, Defendants HIRU, AZCBW and SWI
share IT personnel and functions.
14. Upon information and belief, Defendants HIRU, AZCBW and SWI
share computer systems and networks.
15. Upon information and belief, employees transfer between Defendants
HIRU, AZCBW and SWI.
16. Defendants HIRU, AZCBW and SWI were part of a single integrated
enterprise during the relevant time period.
17. Defendants HIRU, AZCBW and SWI were joint employers during the
relevant time period.
18. Defendant Joel Natario was at all times relevant to this matter an
owner, manager, and/or agent of Defendants HIRU, AZCBW and SWI, and in that
capacity he exercised economic control and control over the nature and structure
over Plaintiffs’ employment by exercising his authority to hire and fire employees,
implementing employment policies and practices, and determining work
assignments, work schedules, and rates of pay.
19. Defendant Kathryn Gavin was at all times relevant to this matter an
owner, manager, and/or agent of Defendants HIRU, AZCBW and SWI and in that
capacity she exercised economic control and control over the nature and structure
over Plaintiffs’ employment by exercising her authority to hire and fire employees,
implementing employment policies and practices, and determining work
assignments, work schedules, and rates of pay.
20. At all relevant times Defendants, HIRU, AZCBW, SWI, Joel Natario
and Kathryn Gavin were employers as defined under §29 U.S.C. 203(d) and A.R.S.
§23-362(B).

JURISDICTION AND VENUE

21. Defendants caused events to occur in Arizona out of which this VENUE
Complaint arises.
22. Jurisdiction and Venue are proper in this Court because the acts,
events, or omissions giving rise to Plaintiffs’ claims occurred in whole, or in part,
in Maricopa County, Arizona

FACTUAL BACKGROUND

Plaintiff Mirna

23. Plaintiff Mirna was a full-time employee of Defendants from January
4, 2022 through August 26, 2022. Throughout her employment with Defendants
she performed work as a carboard box assembler.
24. When she began her employment with Defendants she was promised
a starting hourly rate of $14.50 and an increase to $15.00 per hour after three months
of employment.
25. During the first four to six weeks of her employment Plaintiff Mirna
worked between 40 to 45 hours per week, and received between $800 and $850
every two weeks.
26. From around mid-February 2022 through August 2022 when she left
her employment with Defendants, Plaintiff Mirna worked 50 to 60 hours per week,
and received payment of between $700 and $900 every two weeks.

Plaintiff Arnulfo

27. Plaintiff Arnulfo Bernal was a full-time employee of Defendants from
January 4, 2022 through August 26, 2022. Throughout his employment with
Defendants he performed work as a water box stacker and forklift driver.
28. When he began his employment with Defendants, he was promised a
starting hourly rate of $15.00.
29. During the first four to six weeks of his employment Plaintiff Arnulfo
worked between 40 to 45 hours per week and received between $800 and $850
every two weeks.
30. From around mid-February 2022 through August 2022 when the left
his employment with Defendants, Plaintiff Arnulfo worked 60 to 65 hours per week,
and received payment of between $700 and $900 every two weeks.

Plaintiff Elvira

31. Plaintiff Elvira was a full-time employee of Defendants from January
4, 2022, through August 26, 2022. Throughout her employment with Defendants
she performed work on a water-bottle assembly line.
32. When she began her employment with Defendants, she was promised
a starting hourly rate of $15.00.
33. During the first four to six weeks of her employment Plaintiff Elvira
worked between 40 to 45 hours per week and received between $800 and $850
every two weeks.
34. From around mid-February 2022 through August 2022 when she left
her employment with Defendants, Plaintiff Elvira worked 50 to 60 hours per week,
and received payment of between $700 and $900 every two weeks.
35. Upon information and belief, Defendants knew or should have known
that Plaintiffs did not receive any wages for certain work time.
36. Upon information and belief, Defendants knew that Plaintiffs and
other employees were not receiving the corresponding hourly rate and overtime
premium rate when they worked more than 40 hours in a work week.
37. Prior to and during the applicable statutory period Defendants
implemented policies and practices that Defendants knew or should have known
would violate Plaintiffs’ rights under the FLSA and AMWA.
38. Prior to and during the applicable statutory period Defendants
knowingly and intentionally failed to take any action to prohibit or monitor the
accrual of unpaid wages and overtime.

FIRST CAUSE OF ACTION
FLSA-Minimum Wages

39. Plaintiffs incorporate by reference the preceding paragraphs of this
Complaint as if specifically set forth herein.
40. By failing to pay Plaintiffs at all for certain hours of work, Defendants
violated their rights under the FLSA, including but not limited to, 29 U.S.C. §206.
41. Defendants’ failure to pay Plaintiffs for all hours of work was
knowing, willful, and in reckless disregard of their rights under the FLSA.

SECOND CAUSE OF ACTION
FLSA-Unpaid Overtime

42. Plaintiffs incorporate by reference the preceding paragraphs of this
Complaint as if specifically set forth herein.
43. By failing to pay Plaintiffs one-and-one-half times their regular hourly
rate for all hours worked in excess of 40 hours per work week, Defendants violated
their rights under the FLSA, including but not limited to 29 U.S.C. §207.
44. Defendants’ failure to pay Plaintiffs one-and-a-half times their regular
hourly rate for all hours worked in excess of 40 hours per work week was knowing,
willful, and in reckless disregard of their rights under the FLSA.

THIRD CAUSE OF ACTION
AMWA-Minimum Wages

45. Plaintiffs incorporate by reference the preceding paragraphs of this
Complaint as if specifically set forth herein.
46. By failing to pay Plaintiffs at all for certain hours of work, Defendants
violated their rights under the AMWA, including but not limited to, A.R.S. §23-
363.
47. Defendants’ failure to pay Plaintiffs for all hours of work was
knowing, willful, and in reckless disregard of their rights under the AMWA.
WHEREFORE, Plaintiffs prays for relief against Defendants as follows:
A. Award Plaintiffs backpay for nonpayment and underpayment of wages
and overtime;

B. Award Plaintiff double or liquidated damages under the AMWA and
FLSA in an amount equal to their unpaid wages and overtime;
C. Order Defendants to pay reasonable attorney’s fees and costs;
D. Order Defendants to pay pre-judgment interest on all amounts for
which pre-judgment interest is legally allowable, at the highest lawful
rate;
E. Order Defendants to pay post-judgment interest at the highest lawful
rate for all amounts, including attorney fees, awarded against
Defendant; and
F. Order all other relief, whether legal, equitable or injunctive, as may be
necessitated to effectuate full relief to Plaintiffs.

JURY DEMAND
Plaintiffs request a jury trial.
Respectfully submitted this 29th day of January 2024.
Thunderbird Law Group
By: /s/ Isaac P. Hernandez
Isaac P. Hernandez
Attorney for Plaintiff

Entry of Default Judgment June 11th, 2025

Could not copy & paste.

[rheddle]

They updated the Georgia Secretary of State filing on May 30. If they were going to walk away from this, why would they bother?