EXHIBIT “A” 

Case 1:20-cv-21769-CMA Document 1-2 Entered on FLSD Docket 04/28/2020 Page 1 of 9
Filing # 103610261 E-Filed 02/20/2020 10:26:10 AM 

FORM 1.997. CIVIL COVER SHEET 

The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of 

pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the 

Clerk of Court for the purpose of reporting data pursuant to section 25.075, Florida Statutes. (Sec instructions 

for completion.) 

I. CASE STYLE 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

Case No.: 

Judge: 

Lazaro Jimenez 

Plaintiff 

vs. 

Rent-A-Center East, Inc. 

Defendant 

II. AMOUNT OF CLAIM 

Please indicate the estimated amount of the claim rounded to the nearest dollar $500,000 

III. TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the 

most descriptive label is a subcategory (is indented under a broader category), place an x on both the main 

category and subcategory lines. 

O Condominium 

❑ Contracts and indebtedness 

❑ Eminent domain 

O Auto negligence 

❑ Negligence — other 

0 

0 

0 

0 

0 

0 

0 

O Premises liability — residential 

❑ Products liability 

❑ Real Property/Mortgage foreclosure 

0 

❑ 

0 

0 

0 

Professional malpractice 

O Malpractice — business 

O Malpractice — medical 

Business governance 

Business torts 

Environmental/Toxic tort 

Third party indemnification 

Construction defect 

Mass tort 

Negligent security 

Nursing home negligence 

Premises liability — commercial 

Commercial foreclosure 

Homestead residential foreclosure 

Non-homestead residential foreclosure 

Other real property actions 

❑ Malpractice — other professional 

El Other 

O Antitrust/Trade Regulation 

❑ Business Transaction 

❑ Circuit Civil - Not Applicable 

❑ Constitutional challenge-statute or ordinance 

❑ Constitutional challenge-proposed amendment 

❑ Corporate Trusts 

• Discrimination-employment or other 

❑ Insurance claims 

❑ Intellectual property 

❑ Libel/Slander 

❑ Shareholder derivative action 

❑ Securities litigation 

❑ Trade secrets 

❑ Trust litigation 

❑ County Civil 

O Small Claims up to $8,000 

❑ Civil 

❑ Replevins 

❑ Evictions 

❑ Other civil (non-monetary) 

Page 1 of 2

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COMPLEX BUSINESS COURT 

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the 

Administrative Order. Yes ❑ No N 

IV. REMEDIES SOUGHT (check all that apply): 

N Monetary; 

IN Non-monetary declaratory or injunctive relief; 

M Punitive 

V. NUMBER OF CAUSES OF ACTION: 

(Specify) 

1 

VI. IS THIS CASE A CLASS ACTION LAWSUIT? 

❑ Yes 

IX No 

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED? 

M No 

❑ Yes — If "yes" list all related cases by name, case number and court: 

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT? 

M Yes 

❑ No 

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and 

that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425. 

Signature: s/ Anthony M Georges-Pierre 

Attorney or party 

FL Bar No.: 533637 

(Bar number, if attorney) 

Anthony M Georges-Pierre 

(Type or print name) 

Date: 02/20/2020 

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Case 1:20-cv-21769-CMA Document 1-2 Entered on FLSD Docket 04/28/2020 Page 3 of 9
Filing # 103610261 E-Filed 02/20/2020 10:26:10 AM 

IN THE CIRCUIT COURT OF THE 

11TH JUDICIAL CIRCUIT, IN AND 

FOR MIAMI-DADE COUNTY, FLORIDA 

LAZARO JIMENEZ, 

CASE NO.: 

Plaintiff, 

vs. 

RENT-A-CENTER EAST, INC., 

Defendant. 

COMPLAINT 

(OPT-IN PURSUANT TO 29 U.S.0 § 216(B)) 

1. Plaintiff Lazaro Jimenez, (hereinafter referred to as "Plaintiff'), was an employee of 

Defendant, Rent-A-Center East, Inc. (referred to as "Defendant"), and brings this action on 

behalf of himself and other current employees and former employees of Defendans similarly 

situated to him for overtime compensation and other relief under the Fair Labor Standards Act 

("FLSA"), as amended, 29 U.S.C. § 216 (b). Plaintiff performed non-exempt duties in 

connection with his employment for Defendant in Miami-Dade County, Florida. The factual 

contentions in this complaint have evidentiary support or will likely have evidentiary support 

after a reasonable opportunity for further investigation or discovery. Plaintiff alleges the 

following on information, belief, or by investigation of his counsel, formed after an inquiry 

reasonable under the circumstances, as set forth in the preceding paragraphs: 

2. Defendant, have at all times material hereto owned and/or operated a business within the 

jurisdiction of this Court, including. doing business in Miami-Dade County. 

Case 1:20-cv-21769-CMA Document 1-2 Entered on FLSD Docket 04/28/2020 Page 4 of 9
3. This action is brought to recover from Defendant overtime compensation, liquidated 

damages, and the costs and reasonable attorney's fees of this action under the provisions of the 

FLSA, 29 U.S.C. §216(b). 

4. Jurisdiction is conferred on this Court by 28 U.S.C. § 1337 and by 29 U.S.C. §216 (b). 

5. At all times material to this Complaint, Defendant has had two (2) or more employees 

who have regularly sold, handled, or otherwise worked on goods and/or materials that had been 

moved in or produced for commerce. 

6. Based upon information and belief, the annual gross sales volume of defendant entity was 

in excess of $500,000.00 per annum at all times material hereto. 

Based upon information and belief for the relevant time period as detailed herein Plaintiff 

was engaged in interstate commerce. 

8. Based upon information and belief for the relevant time period as detailed herein Plaintiff 

produced goods for interstate conunerce. 

9. Based upon information and belief for the relevant time period as detailed herein Plaintiff 

produced goods for interstate commerce. 

10. Based upon information and belief for the relevant time period as detailed herein Plaintiff 

handled goods and/or materials that have been moved in or produced for interstate commerce. 

11. Based upon information and belief for the relevant time period as detailed herein Plaintiff 

sold goods and/or materials that have been moved in or produced for interstate commerce. 

12. Based upon information and belief for the relevant time period as detailed herein Plaintiff 

worked on goods or materials that have been moved in or produced for interstate 

commerce. 

Case 1:20-cv-21769-CMA Document 1-2 Entered on FLSD Docket 04/28/2020 Page 5 of 9
13. Based upon information and belief during the relevant time period plaintiff was an 

employee employed by the defendant business. 

14. Based upon information and belief during the relevant time period defendant business 

had an annual gross volume of sales made or business done of at least $500,000. 

15. Based upon information and belief during the relevant time period defendant was 

engaged in interstate commerce or in the production of goods for commerce as defined by 

the FLSA, 29 U.S.C. §203(s). 

16. Based upon information and belief during the relevant time period defendant company 

regularly used the U.S. mail to send or receive letters to and from other states. 

17. Based upon information and belief during the relevant time period Plaintiff and/or 

Defendant's other personnel used company telephones or computers to place or accept 

interstate business calls or take orders. 

18. Based upon information and belief during the relevant time period defendant company's 

employees used materials (tools or other articles necessary for doing or making 

something) in conducting their employers' business which had shipped in interstate 

commerce. 

19. The additional persons who may become Plaintiffs in this action are Defendant's nonexempt employees who have worked in excess of forty (40) hours during one or more 

work weeks on or after January 2018 and did not receive time and a half of their regular 

rate of pay for all of the hours they worked over forty (40) in one or more work weeks. 

20. Plaintiff regularly worked in excess of forty (40) hours per week in one or more weeks 

during his employment with Defendant. 

Case 1:20-cv-21769-CMA Document 1-2 Entered on FLSD Docket 04/28/2020 Page 6 of 9
21. Likewise, the other employees similarly situated to Plaintiff regularly worked in excess 

of forty (40) hours in one or more work weeks during their employment with Defendant. 

22. However, Defendant did not pay time and one-half wages for all of the overtime hours 

worked by Plaintiff and the other employees similarly situated to him. 

23. The records, if any, concerning the hours worked by Plaintiff, and compensation actually 

paid to Plaintiff and the other similarly situated employees to Plaintiff are in the 

possession and custody of Defendant. 

COUNT I 

RECOVERY OF WAGE AND HOUR FEDERAL STATUTORY VIOLATION AGAINST 

DEFENDANT 

24. Plaintiff readopts and re-alleges the allegations contained in Paragraphs 1 through 23 

above. 

25. Plaintiff is entitled to be paid time and one-half of his regular rate of pay for each hour 

worked in excess of forty (40) hours per work week. All similarly situated employees of 

Defendant are similarly owed their overtime rate for each overtime hour they worked and were 

not properly paid. 

26. Defendant knowingly and willfully failed to pay Plaintiff and the other employees 

similarly situated to him at time and one half of their regular rate of pay for all hours worked in 

excess of forty (40) per week. 

27. By reason of the said intentional, willful and unlawful acts of Defendant, all Plaintiffs 

(the named Plaintiff and those similarly situated to him) have suffered damages plus incurring 

costs and reasonable attorneys' fees. 

Case 1:20-cv-21769-CMA Document 1-2 Entered on FLSD Docket 04/28/2020 Page 7 of 9
28. As a result of Defendant's willful violations of the Act, all Plaintiffs (the named Plaintiff 

and those similarly situated to him) are entitled to liquidated damages. 

29. Plaintiff has retained the undersigned counsel to represent him in this action, and 

pursuant to 29 U.S.C. §216(b), Plaintiff is entitled to recover all reasonable attorneys' fees and 

costs incurred in tins action. 

30. Plaintiff demands a jury trial. 

WHEREFORE, Plaintiff, and those similarly situated to him who have or will opt into 

this action, demands judgment, against Defendant, for the payment of all overtime hours at one 

and one-half their regular rate of pay due them for the hours worked by them for which they have 

not been properly compensated, liquidated damages, reasonable attorneys' fees and costs of suit, 

and for all proper relief including prejudgment interest. 

Plaintiff demands a trial by jury as to each count of this complaint. 

Dated this 1-0 day of Rbruqc-ci , 2020 

Respectfully submitted, 

By: 

Antho y M. G orges-Pierre, Esq. 

Florida Bar Number: 0533637 

Max L. Horowitz, Esq. 

Florida Bar Number: 118269 

REMER & GEORGES-PIERRE, PLLC 

COURTHOUSE TOWER 

44 West Flagler Street, Suite 2200 

Miami, FL 33130 

Tel. (305) 416-5000 

Fax: (3n 416-5005 

E-Maillagkrgpatt 

1.1./o 

Case 1:20-cv-21769-CMA Document 1-2 Entered on FLSD Docket 04/28/2020 Page 8 of 9
IN THE CIRCUIT COURT OF THE 

11TH JUDICIAL CIRCUIT, IN AND 

FOR MIAMI-DADE COUNTY, FLORIDA 

LAZARO JIMENEZ, 

CASE NO.: 

Plaintiff, 

vs. 

RENT-A-CENTER EAST, INC., 

Defendant. 

SUMMONS IN A CIVIL CASE 

TO: CT CORPORATION SYSTEM 

Registered Agent for RENT-A-CENTER EAST, INC. 

1200 South Pine Island Road 

Plantation, FL 33324 

YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY 

Anthony M. Georges-Pierre, Esq. 

REMER & GEORGES-PIERRE, PLLC 

COURTHOUSE TOWER 

44 West Flagler Street, SUITE 2200 

MIAMI, FL 33130 

an answer to the complaint which is herewith served upon you, within 20 days after service of this summons upon 

you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief 

demanded in the complaint. You must also file your answer with the Clerk of this Court within a reasonable period 

of time after service. 

CLERK DATE 

(BY) DEPUTY CLERK 

Case 1:20-cv-21769-CMA Document 1-2 Entered on FLSD Docket 04/28/2020 Page 9 of 9