Former Party Clowns Sue to Challenge Misclassification, Recover Stolen Wages

“Worker misclassification is no laughing matter.”

PRESS RELEASE — Dec. 19, 2023

New York, NY – Plaintiffs Brayan Angulo, Cameron Pille, Janina Salorio, and Xander Black, former clowns and entertainers for, Inc., filed a lawsuit in federal court today alleging, Inc. and its owners Adolph Rodriguez and Erica Barbuto engaged in years of worker misclassification and violations of federal and state wage-and-hour law, failing to pay workers for many of the hours that they worked.

In their federal court complaint, Plaintiffs allege that Defendants, who are based in Elmont, Long Island and provide clowns and other children’s entertainers to appear at birthday parties and other events for children, recruited actors to work for them and promised them a $25 per hour wage, but then misclassified them all as independent contractors. Plaintiffs allege that Defendants relied on this misclassification to deny them the protection of federal and state wage protection laws, including the Fair Labor Standards Act and the New York Labor Law, not paying workers their required overtime wages or promised wages.

Plaintiffs seek to represent a proposed class of all clowns and children’s entertainers who worked for Defendants and were classified as independent contractors between May 5, 2017 and the present.

Plaintiffs allege, among other things, that Defendants failed to pay them the required overtime premium rate for all hours worked above 40 in a workweek, and failed to pay them the promised hourly wage for all hours they worked—specifically, for time they spent traveling to and between different parties—and instead only paid them for the scheduled time of the parties.

When Plaintiff Cameron Pille raised concerns about Defendants’ pay practices with another coworker, she was terminated within thirty minutes, in apparent retaliation for her comments to her coworker.

“For years, has treated clowns, who are largely young actors with no prior training in clowning who sign up for this job to make ends meet, as independent contractors,” said Cameron Pille, one of the lead Plaintiffs in the lawsuit. “I’m proud to join with my clown colleagues to stand up to their wage theft and misclassification.”

The lawsuit was filed in the U.S. District Court for the Southern District of New York. A copy of the lawsuit can be viewed here:

Plaintiffs are represented by Hugh Baran and Patricia Kakalec, with the New York City law firm Kakalec Law PLLC.

Kakalec Law PLLC is a New York based law firm which represents employees in wage and hour, discrimination, and other employment matters. For more information, visit: