LAW OFFICES OF ANTHONY F. SANCHEZ, P.A. 

6701 SUNSET DRIVE, SUITE 101, MIAMI, FL, 33143 TELEPHONE (305) 665-9211

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No.: 20- -CIV-X/X

Valentina Teresa Reyes, and Yasmina Farah, 

individually, and on behalf of others similarly 

situated,

Plaintiffs,

vs.

Home KO, LLC, a Florida limited liability 

company; Courey International (U.S.A.)

Inc., a for profit Florida corporation, and; 

Alan Courey, individually, 

Defendants.

CLASS REPRESENTATION

FAIR LABOR STANDARDS ACT COMPLAINT

Plaintiffs Valentina Teresa Reyes, and Yasmina Farah, individually, and on behalf of others 

similarly situated, sue Defendants, Home KO, LLC; Courey International (U.S.A.) Inc., and; Alan 

Courey, individually, and allege: 

JURISDICTIONAL ALLEGATIONS

1. This lawsuit is an action to recover money damages for unpaid overtime wages, 

brought under the laws of the United States of America and under Florida common law and 

statutes, including §448, Florida Statutes. This Court enjoys jurisdiction pursuant to the Fair Labor 

Standards Act, 29 U.S.C., §§201-219 (“FLSA”), 28 U.S.C. §1367, §448, Florida Statutes, and § 

24, Art. X of the Florida Constitution. 

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2. Plaintiff Valentina Teresa Reyes (“Reyes”) worked as a sales representative for a 

home improvement company operating under the names Home KO, LLC and Courey International 

(U.S.A.) Inc. She was employed approximately ten (10) years ending January 2020.

3. Plaintiff Yasmina Farah (“Farah”) worked as a buyer representative for the same 

home improvement company operating under the names Home KO, LLC and Courey International 

(U.S.A.) Inc. She was employed approximately fifteen (15) years ending January 2020.

4. Plaintiffs Reyes and Farah, together with any other person who may hereafter 

consent to join in this lawsuit, are respectively “employees” within the meaning of 29 U.S.C. 

§203(e). 

5. Defendants Home KO, LLC (“Home KO”) and Courey International (U.S.A.) Inc. 

(“Courey International”) are a conglomerate of related entities and individuals, said entities being 

closely owned and/or controlled by individuals, including, inter alia, Defendant Alan Courey. 

Defendants may be jointly referred to as “Employer” or “Defendants”.

6. Defendant Home KO is a Florida limited liability company, and a “person” and 

“employer” within the meaning of the 29 U.S.C. §203 (a) and (d).

7. Defendant Courey International, is a Florida corporation and a “person” and 

“employer” within the meaning of the 29 U.S.C. §203 (a) and (d). Defendants, individually and as 

a group – together and with others through which it operates – are an “Employer” and an enterprise 

engaged in commerce within the meaning of 29 U.S.C. §203(s).

8. Jurisdiction is conferred upon this Court by 28 U.S.C. §§1331, 1337, 1367 and by 

29 U.S.C. §216(b). The Employer is, and at all times material to this action was, an organization 

which sells and/or markets and/or transports services and/or goods to customers in Florida and 

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across state lines. Upon information and belief, the annual gross revenue of the Employer was at 

all times material to this action in excess of $500,000.00 per annum. 

9. By reason of the foregoing, the Employer is, and at all times material to this action 

was, an enterprise engaged in commerce or in the production of goods for commerce as defined in 

Sections 3(r) and 3(s) of the FLSA, 29 U.S.C., §§ 203(r) and 203(s). Moreover, the named 

Plaintiffs, and others similarly situated, were individually engaged in commerce within the 

meaning of the FLSA by virtue of the nature of the work they performed. 

CLASS ALLEGATIONS UNDER THE FLSA 

10. The Plaintiffs are similarly situated to other persons employed by the Employer in 

that they were required to be paid for hours worked in excess of forty (40) in a workweek, at the 

statutory premium rate of 1.5 time regular hourly rate during any part of the preceding three-year 

period commencing upon the filing of this lawsuit. 

11. The Employer does not keep accurate time-keeping records for hours worked by 

the Plaintiffs or any other similarly situated, covered employees as a means to avoid the payment 

of overtime hours by capping the hours worked log at 40 hours per week even though employees 

routinely worked more than 40 hours per week. 

12. Plaintiffs and others similarly situated were required to work in excess of 40 hours 

per week without payment for those hours at the premium rate, or at all. 

ATTORNEY’S FEES

13. Plaintiffs have engaged the services of the undersigned attorneys and have agreed 

to pay reasonable attorney’s fees for their services. 

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ENTITLEMENT TO ATTORNEY’S FEES

14. Plaintiffs and others similarly situated are entitled to an award of prevailing party 

attorney’s fees and costs pursuant to the Fair Labor Standards Act, 29 U.S.C. §§ 201-219 and other 

related authority. Additionally, Plaintiffs are entitled to fees and costs pursuant to Florida Statute 

§448.08, and other related authority.

– COUNT I –

VIOLATION OF THE FAIR LABOR STANDARDS ACT

(Failure to Pay Overtime Wages)

Plaintiffs, and others similarly situated, reallege ¶¶ 1-14 as though fully set forth here.

15. At all times during his employment, Plaintiffs, and those similarly situated, were 

protected employees required by law to be paid by at the rate of one-and-half times their regular 

hourly rate for all hours they worked in excess of forty during any given workweek. 

16. Plaintiffs routinely worked overtime hours every workweek, but their overtime 

hours were routinely and systematically not paid at the premium rate, and/or at all. 

17. Other current and former similarly situated employees of the Employer, were also 

not paid overtime wages as required by law.

18. At all times material to this action, the Employer failed to comply with 29 U.S.C. 

Sections 201-219; 29 C.F.R., Part 516 – Records to be Kept, and; 29 C.F.R. Part 778 – Overtime 

Compensation, as well as other applicable authority in that Plaintiffs and those similarly situated 

performed services and worked in excess of the maximum hours provided by the FLSA, but no 

adequate provision was made by the Employer to properly pay them at the premium rate, or at all, 

for hours worked in excess of forty (40) hours per workweek. 

19. The Employer failed to pay overtime compensation to Plaintiffs, and those similarly 

situated, based upon factors to include the following: (a) Plaintiffs were not paid for most of the 

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many hours worked in excess of forty at all during applicable workweeks; (b) the Employer failed 

to maintain the types of books and records and policies necessary and required to establish the 

commencement of the workweek for overtime wage calculation purposes; (c) the Employer has 

failed to timely disburse overtime compensation during the applicable pay period when the excess 

hours were worked, or ever.

20. The Employer knew and/or showed a reckless disregard for the provisions of the 

FLSA concerning the payment of overtime wages and remains owing Plaintiffs and other similarly

situated employees overtime wages due from the commencement of the statutory period beginning 

April 2017, and, as a result, they are entitled to recover liquidated damages equal to the amount of 

their unpaid overtime wages for that period.

WHEREFORE, Plaintiffs and others similarly situated request all unpaid overtime wages, 

liquidated damages and reasonable attorney’s fees and costs from Defendants, pursuant to the Fair 

Labor Standards Act. In the event that Plaintiffs and those similarly situated employees do not 

recover liquidated damages, then Plaintiffs and those similarly situated seek an award of 

prejudgment interest for the unpaid overtime compensation and any and all other relief which this 

Court may deem reasonable under the circumstances.

– COUNT II –

BREACH OF AGREEMENT TO PAY COMMISSIONS AND PTO BENEFITS

Plaintiff Valentina Teresa Reyes realleges ¶¶ 1-2, 5-8, and 13-14, as though fully set forth 

herein.

21. At all times during her employment, Plaintiff Reyes was employed by the Employer 

who promised to pay her commissions in addition to her regular hourly compensation as a material 

term of employment. Commissions were based upon gross revenues or sales generated by Plaintiff 

Reyes on a monthly basis.

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22. Additionally, Employer agreed to compensate Plaintiff Reyes for accrued paidtime-off (“PTO”) benefits as a material term of employment. 

23. The Employer breached the agreement by failing to pay commissions generated 

and due on a monthly basis and/or at the time employment terminated. 

24. The Employer breached the agreement by failing to pay accrued PTO benefits.

WHEREFORE, Plaintiff Reyes demands the following: payment of all accrued unpaid 

wages and commissions, including unpaid PTO benefits, in an amount to be proven at the time of 

trial; accrued interest on those sums at the applicable judgment rate of interest, and; an award of 

reasonable attorney’s fees and costs. 

– COUNT III –

BREACH OF AGREEMENT TO PAY PTO BENEFITS

Plaintiff Yasmina Farah realleges ¶¶ 1, 3, 5-8, and 13-14, as though fully set forth herein.

25. At all times during her employment, Plaintiff Farah was employed by the Employer 

who promised to pay her accrued paid-time-off benefits as a material term of employment.

26. The Employer breached the agreement by failing to pay Plaintiff Farah accrued 

PTO benefits.

WHEREFORE, Plaintiff Farah demands the following: payment of all accrued unpaid 

wages, including unpaid PTO benefits, in an amount to be proven at the time of trial; accrued 

interest on those sums at the applicable judgment rate of interest, and; an award of reasonable 

attorney’s fees and costs. 

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JURY DEMAND

27. Plaintiffs demand trial by jury of all issues, claims and defenses triable by jury as 

of right.

Dated: May 15, 2020

Anthony F. Sanchez, P.A. 

Attorneys for Plaintiffs

6701 Sunset Drive, Suite 101

Miami, Florida 33143

Tel.: 305-665-9211

Fax: 305-328-4842

Email: afs@laborlawfla.com

By: /s/ Anthony F. Sanchez

Anthony F. Sanchez

Florida Bar No.789925

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