UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

NOUREDDIN MAHMOUD ABDULAAL, 

Plaintiff,

v.

BEAUTY DISCOUNT ZONE INC, A&A HAIR &

BEAUTY INC D/B/A DISCOUNT BEAUTY SUPPLY,

DALIA BEAUTY SUPPLY, INC. D/B/A BEAUTY

DISCOUNT, WIGS N BUNDLES INC, MUNZER M.

ALATTAR A/K/A MOUNZER ALATTAR, OMAR ALATTAR,

Defendants.

___________________________________________________/

COMPLAINT

{Jury Trial Demanded}

Plaintiff, NOUREDDIN MAHMOUD ABDULAAL, brings this action against

Defendants, BEAUTY DISCOUNT ZONE INC, A&A HAIR & BEAUTY INC D/B/A 

DISCOUNT BEAUTY SUPPLY, DALIA BEAUTY SUPPLY, INC. D/B/A BEAUTY 

DISCOUNT, WIGS N BUNDLES INC, MUNZER M. ALATTAR A/K/A MOUNZER 

ALATTAR, and OMAR ALATTAR, pursuant to the Fair Labor Standards Act (“FLSA”), 29 U.S.C 

§ 201 et seq., and alleges as follows:

1. Jurisdiction is conferred on this Court by 28 U.S.C. § 1331 and 29 U.S.C. § 216(b).

2. At all times material hereto, Plaintiff NOUREDDIN MAHMOUD ABDULAAL was a

resident of the State of Florida and an “employee” of Defendants as defined by the FLSA.

3. At all times material hereto, Plaintiff engaged in interstate commerce on a regular and 

recurring basis within the meaning of the FLSA including but not limited to interstate 

communication with vendors in New York and California.

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4. At all times material hereto, Defendant, BEAUTY DISCOUNT ZONE INC, was a Florida 

corporation with its principal place of business in South Florida, engaged in commerce in the field 

of retail beauty supplies, at all times material hereto was the “employer” of Plaintiff as that term 

is defined under statutes referenced herein, engaged along with its employees in interstate 

commerce, and has annualized gross sales and/or business volume of $500,000 or more.

5. At all times material hereto, Defendant, A&A HAIR & BEAUTY INC D/B/A DISCOUNT 

BEAUTY SUPPLY, was a Florida corporation with its principal place of business in South Florida, 

engaged in commerce in the field of retail beauty supplies, at all times material hereto was the 

“employer” of Plaintiff as that term is defined under statutes referenced herein, engaged along with 

its employees in interstate commerce, and has annual gross sales and/or business volume of 

$500,000 or more.

6. At all times material hereto, Defendant, DALIA BEAUTY SUPPLY, INC. D/B/A 

BEAUTY DISCOUNT, was a Florida corporation with its principal place of business in South 

Florida, engaged in commerce in the field of retail beauty supplies, at all times material hereto was 

the “employer” of Plaintiff as that term is defined under statutes referenced herein, engaged along 

with its employees in interstate commerce, and has annual gross sales and/or business volume of 

$500,000 or more.

7. At all times material hereto, Defendant, WIGS N BUNDLES INC, was a Florida 

corporation with its principal place of business in South Florida, engaged in commerce in the field 

of retail beauty supplies, at all times material hereto was the “employer” of Plaintiff as that term 

is defined under statutes referenced herein, engaged along with its employees in interstate 

commerce, and has annual gross sales and/or business volume of $500,000 or more.

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8. Defendants, BEAUTY DISCOUNT ZONE INC, A&A HAIR & BEAUTY INC D/B/A 

DISCOUNT BEAUTY SUPPLY, DALIA BEAUTY SUPPLY, INC. D/B/A BEAUTY 

DISCOUNT, and WIGS N BUNDLES INC, are a single enterprise under the Fair Labor Standards 

Act, performed related activities through unified operation and common control for a common 

business purpose, engaged along with their employees in interstate commerce, and have an annual 

gross sales and/or business volume of $500,000 or more.

9. Defendants, BEAUTY DISCOUNT ZONE INC, A&A HAIR & BEAUTY INC D/B/A 

DISCOUNT BEAUTY SUPPLY, DALIA BEAUTY SUPPLY, INC. D/B/A BEAUTY 

DISCOUNT, and WIGS N BUNDLES INC, were joint employers of Plaintiff under the Fair Labor 

Standards Act, shared Plaintiff’s services, had Plaintiff acting in the interest of each business, and 

shared common control of Plaintiff. 

10. Defendant, MUNZER M. ALATTAR A/K/A MOUNZER ALATTAR, is a resident of 

Broward County, Florida and was, and now is, a manager of Defendants, BEAUTY DISCOUNT 

ZONE INC, A&A HAIR & BEAUTY INC D/B/A DISCOUNT BEAUTY SUPPLY, DALIA 

BEAUTY SUPPLY, INC. D/B/A BEAUTY DISCOUNT, AND WIGS N BUNDLES INC, 

controlled Plaintiff’s duties, hours worked, and compensation, and managed the day-to-day 

operations of BEAUTY DISCOUNT ZONE INC, A&A HAIR & BEAUTY INC D/B/A 

DISCOUNT BEAUTY SUPPLY, DALIA BEAUTY SUPPLY, INC. D/B/A BEAUTY 

DISCOUNT, and WIGS N BUNDLES INC. Accordingly, MUNZER M. ALATTAR A/K/A 

MOUNZER ALATTAR was and is an “employer” of the Plaintiff within the meaning of 29 U.S.C. 

§203(d).

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11. Defendant, OMAR ALATTAR, is a resident of Broward County, Florida and was, and now 

is, a manager of Defendant, BEAUTY DISCOUNT ZONE INC, controlled Plaintiff’s duties, and 

managed the day-to-day operations of BEAUTY DISCOUNT ZONE INC. Accordingly, OMAR 

ALATTAR was and is an “employer” of the Plaintiff within the meaning of 29 U.S.C. §203(d).

12. Two or more of Defendants’ employees handled tools, supplies, and equipment 

manfuactured outside Florida in furthernace of their business including but not limited to phones, 

computers, computer monitors, computer keyboards, computer mice, pens, and paper.

13. Plaintiff NOUREDDIN MAHMOUD ABDULAAL worked for Defendants as a store 

manager.

14. Defendants failed to pay Plaintiff’s full and proper overtime wages of 1.5 times Plaintiff’s

regular hourly rate for hours worked over 40 each week.

15. Defendants failed to pay Plaintiff’s full and proper minimum wages for certain hours 

worked during Plaintiff’s employment.

16. Attached as Exhibit A is a preliminary calculation of Plaintiff’s claims. These amounts may 

change as Plaintiff engages in the discovery process.

17. Defendants have knowingly and willfully refused to pay Plaintiff’s legally-entitled wages.

18. Plaintiff has complied with all conditions precedent to bringing this suit, or same have been 

waived or abandoned.

19. Plaintiff has retained the services of the undersigned and is obligated to pay for the legal 

services provided.

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COUNT I

VIOLATION OF FAIR LABOR STANDARDS ACT (“FLSA”)

ALL DEFENDANTS

20. Plaintiff realleges and incorporates the allegations set forth in paragraphs 1-19 above as if

set forth herein in full.

21. Plaintiff alleges this action pursuant to the Fair Labor Standards Act, 29 U.S.C. §§ 216 (b), 

that Plaintiff is entitled to: (i) unpaid minimum wages, (ii) time-and-a-half overtime pay, and (iii) 

liquidated damages pursuant to the Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq. 

22. Plaintiff seeks recovery of damages as referenced above and further seeks interest, costs, 

and attorneys’ fees pursuant to 29 U.S.C. § 216(b).

WHEREFORE, Plaintiff demands judgment against Defendants, jointly and severally, plus 

costs, reasonable attorneys’ fees, and such other remedy as the court deems just and appropriate.

Respectfully submitted,

Koz Law, P.A.

320 S.E. 9th Street

Fort Lauderdale, Florida 33316

Phone: (786) 924-9929

Fax: (786) 358-6071

Email: ekoz@kozlawfirm.com

Elliot Kozolchyk, Esq.

Bar No.: 74791

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