1 of 14

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.:

JOSE PUERTO, VERONICA LUNA, 

HAZELL MEJIA, IRIS CALIX, and all 

others similarly situated under 29 U.S.C. § 

216(b),

Plaintiffs,

vs.

RINCONCITO SUPERLATINO 4, LLC.

Defendant.

_____________________________________/

COMPLAINT UNDER 29 U.S.C. §§ 201-16 OVERTIME WAGE VIOLATIONS, 

MINIMUM WAGE VIOLATIONS AND CONVERSION

Plaintiffs, JOSE PUERTO, VERONICA LUNA, HAZELL MEJIA, and IRIS CALIX

(hereinafter “Plaintiffs”), on behalf of themselves and all others similarly situated under 29 

U.S.C. § 216(b), through undersigned counsel, file this Complaint against Defendant

RINCONCITO SUPERLATINO 4, LLC. (hereinafter “Defendant”), and allege:

JURISDICTION AND VENUE

1. This is an action arising under the Fair Labor Standards Act 29 U.S.C. §§ 201-216. This 

Court has jurisdiction under 29 U.S.C. § 216(B).

2. The Plaintiffs JOSE PUERTO, VERONICA LUNA, HAZELL MEJIA, AND IRIS 

CALIX were each residents of Miami-Dade County, Florida at the time the dispute arose and 

each is sui juris.

3. The Defendant RINCONCITO SUPERLATINO 4, LLC regularly transacts business in 

Miami-Dade County. The Defendant Corporation was the Plaintiffs’ FLSA employer during 

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 1 of 14
2 of 14

Plaintiffs’ relevant period of employment (“the relevant time period”).

4. Venue is proper in this Court because Plaintiffs were residents of Miami-Dade County, 

Florida, at the time the dispute arose, the Defendant does business in Miami-Dade, Florida, and 

the events giving rise to these claims occurred within Miami-Dade County, Florida.

5. Plaintiffs’ worked for Defendant RINCONCITO SUPERLATINO 4, LLC in their 

restaurants.

6. Plaintiff JOSE PUERTO (hereinafter “PUERTO”), worked for Defendant as a sandwich 

maker and lunch preparer from on or about February 10, 2011 through on or about October 4, 

2019.

7. Plaintiff VERONICA LUNA (hereinafter “LUNA”), worked for Defendant as a food 

server from on or about September 17, 2012 through on or about October 7, 2019.

8. Plaintiff HAZELL MEJIA (hereinafter “MEJIA”), worked for Defendant as a food server 

from on or about September 20, 2012 through on or about October 3, 2019.

9. Plaintiff IRIS CALIX (hereinafter “CALIX”), worked for Defendant as a food server from 

on or about October 20, 2013 through on or about October 4, 2019.

10. The acts and/or omissions giving rise to this Complaint arose in Miami-Dade County.

COUNT I. - FEDERAL OVERTIME WAGE VIOLATION AS TO PLAINTIFFS’ 

PUERTO, LUNA AND CALIX

11. Plaintiffs re-allege the factual and jurisdictional statements in paragraphs 1 through 10 as 

though fully set forth herein.

12. This action arises under the laws of the United States.

13. This case is brought as a collective action under 29 U.S.C. § 216(b). It is believed that

the Defendant has employed several other similarly situated employees like Plaintiffs who have 

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 2 of 14
3 of 14

not been paid overtime wages for work performed in excess of 40 hours weekly from the filing 

of this Complaint back three years.

14. This Court has jurisdiction pursuant to 28 U.S.C. § 1331 as this case is brought pursuant 

to The Fair Labor Standards Act, 29 U.S.C. §§ 201-219 (section 216 for jurisdictional 

placement).

15. 29 U.S.C. § 207 (a) (1) states, "Except as otherwise provided in this section, no employer 

shall employ any of his employees who in any workweek is engaged in commerce or in the 

production of goods for commerce, or is employed in an enterprise engaged in commerce or in 

the production of goods for commerce, for a workweek longer than forty hours unless such 

employee receives compensation for his employment in excess of the hours above specified at a 

rate not less than one and one-half times the regular rate at which he is employed.”

16. Plaintiff PUERTO worked for Defendant as a sandwich maker and lunch preparer at 

Defendant’s restaurant.

17. As a sandwich and lunch preparer, Plaintiff’s job duties required of him by Defendant, 

along with other employees, included preparing sandwiches and food obtained from local, 

national, and international sources, for customers who were local, national, and international 

residents.

18. Plaintiff LUNA and Plaintiff CALIX worked for Defendant as food servers at

Defendant’s restaurant.

19. As food servers, Plaintiffs’ job duties required of them by Defendant, along with other 

employees, included serving foods obtained from local, national, and international sources, to 

customers who were local, national, and international residents.

20. Defendant’s business activities involve those to which the Fair Labor Standards Act 

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 3 of 14
4 of 14

applies. Both the Defendant’s business and the Plaintiffs’ work for the Defendant affected 

interstate commerce for the relevant time period. Plaintiffs’ work for the Defendant affected 

interstate commerce for the relevant time period because the materials and goods Plaintiffs used 

on a constant and/or continual basis and/or that were supplied to Plaintiffs by the Defendant to 

use on the job moved through interstate commerce prior to and/or subsequent to Plaintiffs’ use of 

the same. The Plaintiffs’ work for the Defendant was actually in and/or so closely related to the 

movement of commerce while they worked for the Defendant that the Fair Labor Standards Act 

applies to Plaintiffs’ work for the Defendant.

21. Additionally, Defendant regularly employed two or more employees for the relevant time 

period who handled goods or materials that travelled through interstate commerce or used 

instrumentalities of interstate commerce as Plaintiffs did, thus making Defendant’s business an 

enterprise covered under the Fair Labor Standards Act.

22. Upon information and belief, the Defendant had gross sales or business done in excess of 

$500,000 annually for the years 2016, 2017, 2018 and 2019.

23. Between the period of on or about F e b r u a r y 1 0 , 2 0 1 1 through t o on or about

O c t o b e r 4 , 2 019 , Plaintiff PUERTO worked an average of 48 hours a week for

Defendant and was paid an average of $10.00 per hour for all hours worked per week but 

was not paid the extra half time rate for any hours worked over 40 hours in a week as required 

by the Fair Labor Standards Act. Plaintiff therefore claims the half time overtime rate for each 

hour worked above 40 in a week.

24. Between the period of on or about S e p t e m b e r 1 2 , 2 0 1 2 through t o on or

about D e c e m b e r 3 1 , 2 0 1 5 , Plaintiff LUNA worked an average of 56 hours a week for

Defendant, was paid $4.72 per hour for 40 hours of work per week and was paid nothing for 

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 4 of 14
5 of 14

all hours worked in excess of 40 hours per week as required by the Fair Labor

Standards Act. Plaintiff therefore claims the time and a half overtime rate at the applicable 

minimum wage rate for each hour worked in excess of 40 in a week.

25. Between the period of on or about J a n u a r y 1 , 2 0 1 6 through t o on or about

O c t o b e r 7 , 2 0 1 9 , P l a i n t i f f L U N A w o r k e d 4 8 h o u r s p e r w e e k f o r 2 

w e e k s p e r m o n t h for Defendant, was paid $5.23 per hour for 40 hours of work per week

was paid nothing for all hours worked in excess of 40 hours per week as required

by the Fair Labor Standards Act. Plaintiff therefore claims the time and a half overtime 

rate at the applicable minimum wage rate for each hour worked in excess of 40 in a week.

26. Between the period of on or about J a n u a r y 1 , 2 0 1 6 through t o on or about

O c t o b e r 7 , 2 0 1 9 , P l a i n t i f f C A L I X w o r k e d 4 4 h o u r s p e r w e e k f or

Defendant, was paid $5.25 per hour for 40 hours of work per week and was paid nothing for 

all hours worked in excess of 40 hours per week as required by the Fair Labor

Standards Act. Plaintiff therefore claims the time and a half overtime rate at the applicable 

minimum wage rate for each hour worked in excess of 40 in a week.

27. Defendant willfully and intentionally refused to pay Plaintiffs’ overtime wages as 

required by the Fair Labor Standards Act as Defendant knew of the overtime requirements of 

the Fair Labor Standards Act and recklessly failed to investigate whether Defendant’s payroll 

practices were in accordance with the Fair Labor Standards Act. Defendant remains owing 

Plaintiffs these wages since the commencement of each Plaintiffs’ employment with Defendant

through to each of the Plaintiff’s termination date respectively.

WHEREFORE, Plaintiffs PUERTO, LUNA and CALIX, request liquidated damages and 

reasonable attorney fees from Defendant under the Fair Labor Standards Act (FLSA), Fla. Const. 

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 5 of 14
6 of 14

art. X § 24, Fla. Stat. § 448.109, and any other applicable authority, to be proven at the time of 

trial for all overtime wages still owing from Plaintiffs’ entire employment period with Defendant

or as much as allowed by the Fair Labor Standards Act along with court costs, interest, and any 

other relief that this Court finds reasonable under the circumstances. The Plaintiffs request a 

trial by jury.

COUNT II. - FEDERAL MINIMUM WAGE VIOLATION AS TO PLAINTIFFS’ LUNA, 

MEJIA, AND CALIX

28. Plaintiffs re-allege the factual and jurisdictional statements in paragraphs 1 through 27 as 

though fully set forth herein.

29. This action arises under the laws of the United States.

30. This Court has jurisdiction pursuant to 28 U.S.C. § 1331 as this case is brought pursuant 

to the Fair Labor Standards Act, 29 U.S.C. §§ 201-219.

31. 29 U.S.C. § 206(a)(1) states “... an employer must pay a minimum wage of $5.15/hr to 

an employee who is engaged in commerce...” On July 24, 2009, Federal minimum wage was 

raised to $7.25/hr, where it has remained since that time.

32. Plaintiffs LUNA, MEJIA, and CALIX worked for Defendant as food servers. As food 

servers, Plaintiffs’ job duties required of them by Defendant, along with other employees, 

included serving foods obtained from local, national, and international sources, to customers who 

were local, national, and international residents.

33. Defendants’ business activities involve those to which the Fair Labor Standards Act 

applies. Both the Defendants’ business and the Plaintiffs’ work for the Defendant affected 

interstate commerce for the relevant time period. Plaintiffs’ work for the Defendant affected 

interstate commerce for the relevant time period because the materials and goods Plaintiffs used 

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 6 of 14
7 of 14

on a constant and/or continual basis and/or that were supplied to Plaintiffs by the Defendant to 

use on the job moved through interstate commerce prior to and/or subsequent to Plaintiffs’ use of 

the same. The Plaintiffs’ work for the Defendant was actually in and/or so closely related to the 

movement of commerce while they worked for the Defendant that the Fair Labor Standards Act 

applies to Plaintiffs’ work for the Defendant.

34. Additionally, Defendant regularly employed two or more employees for the relevant time 

period who handled goods or materials that travelled through interstate commerce, or used 

instrumentalities of interstate commerce as Plaintiffs did thus making Defendants’ business an 

enterprise covered under the Fair Labor Standards Act.

35. Upon information and belief, the Defendant had gross sales or business done in excess of 

$500,000 annually for the years 2016, 2017, 2018 and 2019.

36. Between the period of or about S e p t e m b e r 1 2 , 2 0 1 2 through t o on or about

D e c e m b e r 3 1 , 2 0 1 5 , Plaintiff LUNA was paid $4.72 per hour.

37. Between the period of or about J a n u a r y 1 , 2 0 1 6 through t o on or about

O c t o b e r 7 , 2 0 1 9 , P l a i n t i f f L U N A was paid $5.23 per hour.

38. Defendant never gave Plaintiff LUNA notice that tips would be applied to cover the 

minimum wage deficiency that is otherwise available for food servers.

39. Between the period of or about S e p t e m b e r 2 0 , 2 0 1 2 through t o on or about

O c t o b e r 3 , 2 0 1 9 , P l a i n t i f f M E J I A was paid $5.23 per hour.

40. Defendant never gave Plaintiff MEJIA notice that tips would be applied to cover the 

minimum wage deficiency that is otherwise available for food servers.

41. Between the period of on or about J a n u a r y 1 , 2 0 1 6 through t o on or about

O c t o b e r 7 , 2 0 1 9 , P l a i n t i f f C A L I X was paid $5.25 per hour.

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 7 of 14
8 of 14

42. Defendant never gave Plaintiff CALIX notice that tips would be applied to cover the 

minimum wage deficiency that is otherwise available for food servers.

43. The payment to Plaintiffs LUNA, MEJIA and CALIX by Defendant did not meet the

applicable Federal Minimum Wage required for said period of time. Therefore, Plaintiffs claim 

the difference between the amounts paid the Plaintiffs and the applicable Federal Minimum 

Wage for all hours worked for the relevant time periods.

44. Defendant willfully and intentionally refused to pay Plaintiffs minimum wages as 

required by the Fair Labor Standards Act as Defendant knew of the Federal Minimum Wage 

requirements of the Fair Labor Standards Act and recklessly failed to investigate whether 

Defendants’ payroll practices were in accordance with the Fair Labor Standards Act. Defendant

remains owing Plaintiffs these wages since the commencement of Plaintiffs’ employment with 

Defendant through to each of the Plaintiff’s termination date respectively.

WHEREFORE, Plaintiffs LUNA, MEJIA, and CALIX request double damages and 

reasonable attorneys’ fees from the Defendant pursuant to the Fair Labor Standards Act and as 

cited above, to be proven at the time of trial for all minimum wages still owing from Plaintiffs’ 

entire employment period with Defendant or, as much as allowed by the Fair Labor Standards 

Act, whichever is greater, along with court costs, interest, and any other relief that his Court 

finds reasonable under the circumstances. The Plaintiffs request a trial by jury.

COUNT III . - FLORIDA MINIMUM WAGE VIOLATION AS TO PLAINTIFFS’ 

LUNA, MEJIA, AND CALIX1

45. Plaintiffs re-allege the factual and jurisdictional statements in paragraphs 1 through 44 as 

 

1 To the extent Plaintiffs’ claim for Florida Minimum Wage overlaps Plaintiffs’ claim for Federal 

Minimum Wage payments, Plaintiffs’ are claiming the higher of the two applicable rates.

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 8 of 14
9 of 14

though fully set forth herein.

46. Florida Statute § 448.110 (3) states “Effective May 2, 2005, employers shall pay 

employees a minimum wage at an hourly rate of $6.15 for all hours worked in Florida. Only 

those individuals entitled to receive the federal minimum wage under the federal Fair Labor 

Standards Act and its implementing regulations shall be eligible to receive the state minimum 

wage pursuant to s. 24, Art. X of the State Constitution and this section. The provisions of ss. 

213 and 214 of the federal Fair Labor Standards Act, as interpreted by applicable federal 

regulations and implemented by the Secretary of Labor, are incorporated herein.” [Fla. Stat. § 

448.110 (3)].

47. Florida Statute § 448.110 (4)(a) states “Beginning September 30, 2005, and annually on 

September 30 thereafter, the Agency for Workforce Innovation shall calculate an adjusted state 

minimum wage rate by increasing the state minimum wage by the rate of inflation for the 12 

months prior to September 1.”

48. As of January 1, 2017, Florida’s minimum wage was raised to $8.10/hr. Minimum wage 

claims are brought pursuant to the Florida Constitution and the Fair Labor Standards Act. On 

January 1, 2018, the Florida minimum wage was increased to $8.25/hr. Minimum wage claims 

are brought pursuant to the Florida Constitution and the Fair Labor Standards Act. On January 1, 

2019, the Florida minimum wage was increased to $8.46/hr. Minimum wage claims are brought 

pursuant to the Florida Constitution and the Fair Labor Standards Act. On January 1, 2020, the 

Florida minimum wage was increased to $8.56/hr. Minimum wage claims are brought pursuant 

to the Florida Constitution and the Fair Labor Standards Act.

49. All conditions precedent pursuant to §448.110 have been met by Plaintiff to claim 

minimum wages against the Defendant.

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 9 of 14
10 of 14

50. On February 26, 2020, Plaintiff LUNA and Plaintiff MEJIA initially sent via FEDEX the 

required Florida Minimum Wage Notices to the Defendant pursuant to Florida Statute § 

448.110(6)(a). See attached hereto a copy of the notices and proof of service of same as Exhibit 

A.

51. Florida Statute §448.110(6)(b) provides that upon receipt of said Florida Minimum Wage 

Notice “The employer shall have 15 calendar days after receipt of the notice to pay the total 

amount of unpaid wages or otherwise resolve the claim to the satisfaction of the person 

aggrieved.” The 15 calendar days expired on March 20, 2020. However, as of the date of filing 

the instant Complaint, Plaintiff LUNA, Plaintiff MEJIA and the Defendant have been unable to 

resolve said Florida Minimum Wage violation.

52. On April 6, 2020, Plaintiff CALIX initially sent via USPS Certified Mail the required

Florida Minimum Wage Notices to the Defendant pursuant to Florida Statute § 448.110(6)(a). 

See attached hereto a copy of the notices and proof of service of same as Exhibit B.

53. Florida Statute §448.110(6)(b) provides that upon receipt of said Florida Minimum Wage 

Notice “The employer shall have 15 calendar days after receipt of the notice to pay the total 

amount of unpaid wages or otherwise resolve the claim to the satisfaction of the person 

aggrieved.” The 15 calendar days expired on April 29, 2020. However, as of the date of filing the 

instant Complaint, Plaintiff CALIX and the Defendant have been unable to resolve said Florida 

Minimum Wage violation.

54. Plaintiff LUNA worked for Defendant as a food server from on or about September 17, 

2012 through on or about October 7, 2019.

55. Plaintiff MEJIA worked for Defendant as a food server from on or about September 20, 

2012 through on or about October 3, 2019.

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 10 of 14
11 of 14

56. Plaintiff CALIX worked for Defendant as a food server from on or about October 20, 

2013 through on or about October 4, 2019.

57. Plaintiffs LUNA, MEJIA, and CALIX worked for Defendant as food servers. As food 

servers, Plaintiffs’ job duties required of them by Defendant, along with other employees, 

included serving foods obtained from local, national, and international sources, to customers who 

were local, national, and international residents

58. Additionally, Plaintiff’s work for the Defendant affected interstate commerce for the 

relevant time period because the materials and goods that Plaintiff handled and/or used on a 

constant and/or continual basis and/or that were supplied to Plaintiff by the Defendant to use on 

the job moved through interstate commerce prior to and/or subsequent to Plaintiff’s use of the 

same. Plaintiff’s work for the Defendant was actually in and/or so closely related to the 

movement of commerce while she worked for the Defendant that the Fair Labor Standards Act 

applies to Plaintiff’s work for the Defendant.

59. Between the period of or about S e p t e m b e r 1 2 , 2 0 1 2 through t o on or about

D e c e m b e r 3 1 , 2 0 1 5 , Plaintiff LUNA was paid $4.72 per hour for said work which did not 

meet the applicable Florida minimum wage for said time period as required by the Florida 

Constitution. Therefore, Plaintiff claims difference between Plaintiff’s average hourly rate of 

$4.72/hr and the applicable minimum wage rate for all hours worked.

60. Between the period of or about J a n u a r y 1 , 2 0 1 6 through t o on or about

O c t o b e r 7 , 2 0 1 9 , P l a i n t i f f L U N A was paid $5.23 per hour for said work which did 

not meet the applicable Florida minimum wage for said time period as required by the Florida 

Constitution. Therefore, Plaintiff claims difference between Plaintiff’s average hourly rate of 

$5.23/hr and the applicable minimum wage rate for all hours worked.

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 11 of 14
12 of 14

61. Defendant never gave Plaintiff LUNA notice that tips would be applied to cover the 

minimum wage deficiency that is otherwise available for food servers.

62. Between the period of or about S e p t e m b e r 2 0 , 2 0 1 2 through t o on or about

O c t o b e r 3 , 2 0 1 9 , P l a i n t i f f M E J I A was paid $5.23 per hour for said work which did 

not meet the applicable Florida minimum wage for said time period as required by the Florida 

Constitution. Therefore, Plaintiff claims difference between Plaintiff’s average hourly rate of 

$5.23/hr and the applicable minimum wage rate for all hours worked.

63. Defendant never gave Plaintiff MEJIA notice that tips would be applied to cover the 

minimum wage deficiency that is otherwise available for food servers.

64. Between the period of on or about J a n u a r y 1 , 2 0 1 6 through t o on or about

O c t o b e r 7 , 2 0 1 9 , P l a i n t i f f C A L I X was paid $5.25 per hour for said work which did 

not meet the applicable Florida minimum wage for said time period as required by the Florida 

Constitution. Therefore, Plaintiff claims difference between Plaintiff’s average hourly rate of 

$5.25/hr and the applicable minimum wage rate for all hours worked.

65. Defendant never gave Plaintiff CALIX notice that tips would be applied to cover the 

minimum wage deficiency that is otherwise available for food servers.

66. The Defendant’s wage payment practices to Plaintiff for the above mentioned time 

periods, did not meet the Florida minimum wage law requirements as Plaintiff was not paid the 

required Florida minimum wage for all hours worked and is therefore claiming the difference 

between the amount paid to Plaintiff and the applicable Florida minimum wage for the time 

period specified above.

67. Defendant willfully and intentionally refused to pay Plaintiff’s minimum wages as 

required by the Fair Labor Standards Act as Defendant knew of the Florida Minimum Wage 

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 12 of 14
13 of 14

requirements of the Fair Labor Standards Act and recklessly failed to investigate whether 

Defendants’ payroll practices were in accordance with the Florida Constitution and the Fair

Labor Standards Act. Defendant remains owing Plaintiffs these wages since the commencement 

of Plaintiffs’ employment with Defendant through to each of the Plaintiffs’ termination date 

respectively.

WHEREFORE, the Plaintiffs requests double damages and reasonable attorney fees from 

the Defendant pursuant to the Florida Constitution as cited above, to be proven at the time of trial 

for all minimum wages still owing from Plaintiffs’ entire employment period with Defendant or, 

as much as allowed by the Florida Constitution, along with court costs, interest, and any other 

relief that this Court finds reasonable under the circumstances. The Plaintiffs requests a trial by 

jury.

COUNT IV. CONVERSION

68. Plaintiffs re-allege the factual and jurisdictional statements in paragraphs 1 through 67

as though fully set forth herein.

69. Defendant withheld money from all of Plaintiffs’ paychecks allegedly to pay to the 

United States government on Plaintiffs’ behalf for Plaintiffs’ federal income, social security, 

and medicare taxes.

70. Defendant never paid any taxes on behalf of Plaintiffs.

71. All of the money that Defendant withheld from Plaintiffs’ paychecks that was supposed 

to be paid to the United States government on Plaintiffs’ behalf, was converted by the 

Defendant for their own use.

72. Plaintiffs’ were damaged by Defendant’s conversion of the money that was withheld 

from Plaintiffs’ paychecks because Plaintiffs’ were entitled to either receive that money 

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 13 of 14
14 of 14

themselves or to have that money paid to the government on their behalf.

WHEREFORE, Plaintiffs request damages from the Defendant in the amount that was 

improperly withheld from their paychecks, the value of any and all benefits each Plaintiff lost 

due to Defendant’s non-payment of same to the United States Government, plus court costs and 

interests, and any other relief that this Court finds reasonable under the circumstances.

The Plaintiffs request a trial by jury.

Respectfully submitted,

J. H. ZIDELL, P.A.

ATTORNEYS FOR PLAINTIFF

300 71ST STREET, SUITE 605

MIAMI BEACH, FLORIDA 33141

T: 305-865-6766

F: 305-865-7167

By: __/s/ J.H. Zidell________

J.H. Zidell, Esq. 

Florida Bar No.: 0010121

Case 1:20-cv-21999-RNS Document 1 Entered on FLSD Docket 05/13/2020 Page 14 of 14