Ali also submitted a copy of the training manual USA Cab provided its lessees. Before entering into a lease with USA Cab, Ali leased a taxi from Ivory Cab. Ali also testified he kept no financial records and could not ascertain how much he earned while driving the USA Cab taxi. In July, without leave of court, Ali filed declarations by Hristov and two additional drivers for USA Cab, which set forth individualized claims. After his relationship with USA Cab ended in 2007, Hristov worked for two other cab companies as an independent contractor and without any employee benefits.

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