16. On or about April 22, 2010, upon information and belief, Defendant CAH purchased  the Hospital in order to operate as a critical access hospital in the County of Yadkin.    18. Defendant CAH did not close the Hospital or terminate all employees prior to April  30, 2015.    19. Upon information and belief, in April 2015, Defendant CAH negotiated a lease  extension with the County of Yadkin to operate the Hospital through July 31, 2015.   20. Upon information and belief, in May 2015, the County of Yadkin and Defendant  CAH were in negotiations for the leasing of the Hospital after July 31, 2015.  However, an additional lease was not completed.     21. On May 21, 2015, Defendants notified some of its employees that their final day of  employment would be May 23, 2015, the Mass Layoff Termination Date.  Additionally, those employees received a document detailing Human Resource related  matters from Defendant HMC, with the contact individual being from Defendant  25. Named Plaintiffs bring this Claim for Relief for violation of 29 U.S.C. § 2101 to  2109, on behalf of themselves and on behalf of all other similarly situated former  employees, pursuant to 29 U.S.C. § 2104(a)(5) and Fed. R. Civ. P. 23(a), who worked  at or reported to Defendants’ Hospital and were terminated without cause on or about  the Mass Layoff Termination Date, and within 30 days of that date, or were  terminated without cause as the reasonably foreseeable consequence of the mass  layoffs and/or Hospital closing ordered by Defendants on or about May 23, 2015, and  who are affected employees, within the meaning of 29 U.S.C. § 2101(a)(5)  (hereinafter collectively referred to as the “WARN Act Class,” and individually and  collectively referred to as the “WARN Act Class Members”).   27. Defendants as employers, did not give Named Plaintiffs or any of the WARN Act  Class Members the statutorily required 60 days' notice of the mass layoff or  termination in violation of the WARN Act.   28. Pursuant to 29 U.S.C. § 2104(a)(5), Named Plaintiffs maintain this claim on behalf of  themselves and each of the other similarly situated former employees who are  members of the WARN Act Class.   29. Each of the other similarly situated former employees are similarly situated to Named  Plaintiffs in respect to his or her rights under the Federal WARN Act, in at least the  following ways: Named Plaintiffs and the other similarly situated former employees  were discharged by Defendants without cause on their part; Named Plaintiffs and the  other similarly situated former employees are “affected employee(s)” within the  meaning of the Federal WARN Act (29 U.S.C. § 2101(a)(5)); Defendants were  required by the WARN Act to give Named Plaintiffs and other similarly situated  former employees at least 60 days' advance written notice of their respective layoff  and/or terminations; prior to their termination, neither Named Plaintiffs nor the other  similarly situated former employees received written notice that complied with the  requirements of the WARN Act; and Defendants failed to pay Named Plaintiffs and  the other similarly situated former employees their respective wages, salary, benefits,  and accrued severance pay for the 60 days' period following notice of their  terminations and after notice of their respective layoff and/or termination.   31. Upon information and belief, the identity of the members of the class and the recent  residential address of each of the WARN Act Class Member is contained in the books  and records of Defendants.   32. Upon information and belief, Defendants employed more than 130 employees at the  Hospital. Additionally, upon information and belief, the rate of pay and benefits that  were being paid by Defendants to each WARN Act Class Member at the time of  his/her termination is contained in the books and records of Defendants.   33. Common questions of law and fact exist as to members of the WARN Act Class,  including, but not limited to, the following: whether Defendants were employers  under the WARN Act; whether all WARN Act Class Members were protected under  the WARN Act; whether the members of the WARN Act Class were employees of  Defendants who worked at or reported to Defendants’ Hospital; whether Defendants  unlawfully terminated the employment of the WARN Act Class Members without  cause on their part and without giving them 60 days' advance written notice in  violation of the WARN Act; and whether Defendants unlawfully failed to pay the  WARN Act Class members 60 days' wages and benefits as required by the WARN  Act.   35. Class certification of these claims is appropriate under Fed. R. Civ. P. 23(b)(3)  because questions of law and fact common to the WARN Act Class predominate over  any questions affecting only individual members of the WARN Act Class, and  because a class action is superior to other available methods for the fair and efficient  adjudication of this litigation—particularly in the context of WARN Act litigation,  where individual plaintiffs may lack the financial resources to vigorously prosecute a  lawsuit in federal court against corporate defendants, and damages suffered by  individual WARN Act Class members are small compared to the expense and burden  of individual prosecution of this litigation.   36. Concentrating all the potential litigation concerning the WARN Act rights of the  members of the Class in this Court will obviate the need for unduly duplicative  litigation that might result in inconsistent judgments. It will also conserve the judicial  resources and the resources of the parties and is the most efficient means of resolving  the WARN Act rights of all the members of the Class.   37. Plaintiff intends to send notice to all members of the WARN Class to the extent  required by Rule 23.  Warn Act Class Allegations (29 U.S.C. § 2104; Fed. R. Civ. P. 23)  