LAW OFFICE OF LOWELL J. KUVIN

17 EAST FLAGLER STREET ∙ SUITE 223 ∙ MIAMI, FLORIDA 33131 ∙ TEL.: 305.358.6800 ∙ FAX: 305.358.6808

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No.: 1:20-cv-21773-FAM

PLAINTIFF’S STATEMENT OF CLAIM

COMES NOW Plaintiff GUSTAVO PEREZ (“Plaintiff”) and file his Statement of Claim 

of unpaid overtime wages pursuant to the Court’s Order [D.E. 7].

The relevant time period is April 28, 2017 to April 28, 2020 (“Relevant Time Period”).

During Plaintiff’s time of employment by Defendants, Plaintiff was instructed to not use

the time clock used by employees to record the number of hours they worked each work week. 

Therefore, Plaintiff files his Statement of Claim and estimates1 the amount(s) of overtime pay 

due based upon is “salary” and a forty hour work week (“hourly”) for overtime of: Five Hours 

(5), Ten Hours (10), Fifteen Hours (15), Twenty Hours (20), and Twenty-Five Hours (25) for the 

years (weeks) for the Relevant Time Period.

1 The estimates herein are based upon the information available to Plaintiff at the time of this 

filing. Plaintiff reserves the right to amend Plaintiff’s Statement of Claim as new information

becomes available.

GUSTAVO PEREZ, 

Plaintiff,

vs.

FLORIDA BEAUTY FLORA, INC., a Florida for 

Profit corporation, RONEN KOUBI, an individual, 

and RALPH MILMAN, an individual,

Defendants.

________________________________________/

Case 1:20-cv-21773-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 1 of 6
LAW OFFICE OF LOWELL J. KUVIN

17 EAST FLAGLER STREET ∙ SUITE 223 ∙ MIAMI, FLORIDA 33131 ∙ TEL.: 305.358.6800 ∙ FAX: 305.358.6808

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For Plaintiff GUSTAVO PEREZ

• 2017

Period Claimed: April 28, 2017 through December 31, 2017.

Weeks: 35, approximately.

Hours Worked: Plaintiff worked between five and twenty-five overtime hours each week as 

a non-exempt hourly employee. 

Applicable Wage: Plaintiff was paid an alleged “salary” of $110,000 for 2017. His; monthly 

“salary” $9,166.67, weekly “salary” $2,097.64, hourly wage rate $52.44. Plaintiff’s Overtime 

rate was $78.66.

WAGES OWED: 

Overtime Wages:

Weekly Amount Owed Dependent on X Number of Overtime Hours Worked

Year Salary 5 10 15 20 25

2017 $110,000 $393.31 $786.81 $1,179.92 $1,573.23 $1,966.53

Thirty-Five Weeks: Amount Owed Dependent on X Number of Overtime Hours Worked

Year Salary 5 10 15 20 25

2017 $110,000 $13,765.73 $27,531.47 $41,297.20 $55,062.94 $68,828.67

Total Overtime Wages Owed 2017: $13,765.73 to $68,828.67

• 2018

Period Claimed: January 1, 2018 through December 31, 2018.

Weeks: 52, approximately.

Case 1:20-cv-21773-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 2 of 6
LAW OFFICE OF LOWELL J. KUVIN

17 EAST FLAGLER STREET ∙ SUITE 223 ∙ MIAMI, FLORIDA 33131 ∙ TEL.: 305.358.6800 ∙ FAX: 305.358.6808

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Hours Worked: Plaintiff worked between five and twenty-five overtime hours each week as 

a non-exempt hourly employee. 

Applicable Wage: Plaintiff was paid an alleged “salary” of $121,583.47 for 2018. His;

monthly “salary” $10,128.21, weekly “salary” $2,317.67, hourly wage rate $57.94. Plaintiff’s

Overtime rate was $86.91.

WAGES OWED: 

Overtime Wages:

Weekly Amount Owed Dependent on X Number of Overtime Hours Worked

Year Salary 5 10 15 20 25

2018 $121,583.47 $434.56 $869.13 $1,303.69 $1,738.25 $2,172.81

Fifty-Two Weeks: Amount Owed Dependent on X Number of Overtime Hours Worked

Year Salary 5 10 15 20 25

2018 $121,583.47 $22,597.26 $45,194.51 $67,791.77 $90,389.02 $112,986.28

Total Overtime Wages Owed 2017: $22,597.26 to $112,986.28

• 2019

Period Claimed: January 1, 2019 through December 31, 2019.

Weeks: 52, approximately.

Hours Worked: Plaintiff worked between five and twenty-five overtime hours each week as 

a non-exempt hourly employee. 

Applicable Wage: Plaintiff was paid an alleged “salary” of $125,175 for 2019. His; monthly 

“salary” $10,431.25, weekly “salary” $2,387.01, hourly wage rate $59.68. Plaintiff’s

Overtime rate was $89.51.

Case 1:20-cv-21773-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 3 of 6
LAW OFFICE OF LOWELL J. KUVIN

17 EAST FLAGLER STREET ∙ SUITE 223 ∙ MIAMI, FLORIDA 33131 ∙ TEL.: 305.358.6800 ∙ FAX: 305.358.6808

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WAGES OWED: 

Overtime Wages:

Weekly Amount Owed Dependent on X Number of Overtime Hours Worked

Year Salary 5 10 15 20 25

2019 $125,175 $447.57 $895.13 $1,342.70 $1,790.26 $2,237.83

Fifty-Two Weeks: Amount Owed Dependent on X Number of Overtime Hours Worked

Year Salary 5 10 15 20 25

2019 $125,175 $23,273.38 $46,546.77 $69,820.15 $93,093.54 $116,366.92

Total Overtime Wages Owed 2017: $23,273.38 to $116,366.92.

• 2020

Period Claimed: January 1, 2020 through February 14, 2020.

Weeks: 6, approximately.

Hours Worked: Plaintiff worked between five and twenty-five overtime hours each week as 

a non-exempt hourly employee. 

Applicable Wage: Plaintiff was paid an alleged “salary” of $125,175 for 2019. His; monthly 

“salary” $10,431.25, weekly “salary” $2,387.01, hourly wage rate $59.68. Plaintiff’s

Overtime rate was $89.51.

WAGES OWED: 

Overtime Wages:

Weekly Amount Owed Dependent on X Number of Overtime Hours Worked

Year Salary 5 10 15 20 25

2020 $125,175 $447.57 $895.13 $1,342.70 $1,573.23 $1,966.53

Case 1:20-cv-21773-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 4 of 6
LAW OFFICE OF LOWELL J. KUVIN

17 EAST FLAGLER STREET ∙ SUITE 223 ∙ MIAMI, FLORIDA 33131 ∙ TEL.: 305.358.6800 ∙ FAX: 305.358.6808

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Six Weeks: Amount Owed Dependent on X Number of Overtime Hours Worked

Year Salary 5 10 15 20 25

2020 $125,175 $2,685.39 $5,370.78 $8,056.17 $10,741.56 $13,426.95

Total Overtime Wages Owed 2020: $2,685.39 to $13,426.95

• Aggregate

The aggregate approximate amount/range for the three (3) years prior to the filing of the 

instant lawsuit and dependent on the number of overtime hours worked, is $62,321.76 to 

$311,608.82, not including an equal amount in liquidated damages.

• Attorney’s Fees and Costs:

Lowell J. Kuvin, Esq. 7.2 hours at $450/hr. or $3,240.00

Costs: $400 filing fee and $150.00 for service of two Summonses; $550.00.

Respectfully submitted May 13, 2020.

By: s/Lowell J. Kuvin

Lowell J. Kuvin, Esq.

Florida Bar No. 53072

lowell@kuvinlaw.com

legal@kuvinlaw.com

Law Office of Lowell J. Kuvin

17 East Flagler Street, Suite 223

Miami, Florida 33131

Tel.: 305.358.6800

Fax: 305.358.6808

Attorney for Plaintiff

Case 1:20-cv-21773-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 5 of 6
LAW OFFICE OF LOWELL J. KUVIN

17 EAST FLAGLER STREET ∙ SUITE 223 ∙ MIAMI, FLORIDA 33131 ∙ TEL.: 305.358.6800 ∙ FAX: 305.358.6808

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 13, 2020, I electronically filed the foregoing 

document via CM/ECF. I also certify that the foregoing document is being served this day on all 

counsel of record or pro se parties identified in the attached Service in the manner specified, 

either via transmission of Notices of Electronic Filing generated by CM/ECF, or in some other 

manner for those counsel or parties who are not authorized to receive electronic Notices of 

Electronic Filing. 

Service List

Ainsworth, Clancy, PLLC

801 Brickell Avenue

Miami, PL 33131

Telephone: (305) 600-3816

Facsimile: (305) 600-3817

Ryan Clancy, Esq.

Email: rvan@business-esq.com

Email: info@business-esq.com

Attorney for Defendants

Case 1:20-cv-21773-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 6 of 6