UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION

CASE NO:

ROSSANNA JAIMES,

Plaintiff,

v.

JABA PRO STONE CORP.,

a Florida corporation,

Defendant.

/

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

Plaintiff, ROSSANA JAIMES (“Plaintiff”) pursuant to 29 U.S.C. § 216(b) files the 

following Complaint against Defendant, JABA PRO STONE CORP. (“Defendant”), and alleges 

as follows:

INTRODUCTION

1. Defendant unlawfully deprived Plaintiff of overtime compensation during the course of her 

employment. This action arises under the Fair Labor Standards Act (“FLSA”) pursuant to 

29 U.S.C. §§ 201-216, to recover all overtime wages that Defendant refused to pay Plaintiff 

during her employment.

PARTIES

2. During all times material hereto, Plaintiff was a resident of Broward County, Florida, over 

the age of 18 years, and otherwise sui juris.

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3. During all times material hereto, Defendant, JABA PRO STONE CORP., was a Florida 

for-profit corporation located and transacting business within Hollywood, Florida, within 

the jurisdiction of this Honorable Court. 

4. During all times material hereto, Plaintiff worked for Defendant, JABA PRO STONE 

CORP., at its principal location at 3129 N. 29th Ave., Hollywood, Florida 33020.

5. Defendant, JABA PRO STONE CORP., was Plaintiff’s employer, as defined by 29 U.S.C. 

§ 203(d), during all times pertinent to the allegations herein.

JURISDICTION AND VENUE

6. All acts and omissions giving rise to this dispute took place within Broward County, 

Florida, which falls within the jurisdiction of this Honorable Court.

7. Defendant, JABA PRO STONE CORP., regularly transacts business in Broward County, 

Florida, and jurisdiction is therefore proper within the Southern District of Florida pursuant 

to 29 U.S.C. § 216(b) and 28 U.S.C. §§ 1331 and 1337.

8. Venue is also proper within the Southern District of Florida pursuant to 29 U.S.C. § 216(b) 

and 28 U.S.C. § 1391(b).

GENERAL ALLEGATIONS

9. Defendant, JABA PRO STONE CORP., is a mass production counter tops creator and 

installer that services residential and commercial builders throughout South Florida. JABA 

PRO STONE CORP. has been operating since 2011. See https://jabapro.com/#!/about (last 

visited May 29, 2020).

FLSA COVERAGE

10. Defendant, JABA PRO STONE CORP., is covered under the FLSA through enterprise 

coverage, as JABA PRO STONE CORP. was engaged in interstate commerce during 

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Plaintiff’s employment period. More specifically, JABA PRO STONE CORP.’s business 

and Plaintiff’s work for JABA PRO STONE CORP. affected interstate commerce because 

the goods and materials Plaintiff and other employees used or handled on a constant and 

continuous basis moved through interstate commerce prior to or subsequent to Plaintiff’s 

use of the same goods and materials. Accordingly, Defendant, JABA PRO STONE CORP., 

was engaged in interstate commerce pursuant to 29 U.S.C. § 203(s)(1)(B).

11. During her employment with Defendant, Plaintiff and multiple other employees handled 

and worked with various goods or materials that moved through interstate commerce, 

including, but not limited to: cell phones, clothing, computers, computer keyboards, glass, 

telephones, marble, granite, quartz, corian, natural stone, saws, screw compressors, cranes, 

and belt drives, etc. 

12. Defendant, JABA PRO STONE CORP., regularly employed two (2) or more employees 

for the relevant time period, and these employees handled the same or similar goods or 

materials as Plaintiff, thus making Defendant, JABA PRO STONE CORP., an enterprise 

covered by the FLSA.

13. Upon information and belief, Defendant, JABA PRO STONE CORP., grossed or did 

business in excess of $500,000.00 during the years 2017, 2018, 2019, and is expected to 

gross in excess of $500,000.00 in 2020.

14. During all material times hereto, Plaintiff was a non-exempt employee of Defendant, JABA 

PRO STONE CORP., within the meaning of the FLSA.

PLAINTIFF’S WORK FOR DEFENDANTS

15. Plaintiff began working for Defendant on or about December 6, 2019 as a drafter.

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16. During all time periods pertinent to this Complaint, Defendant retained the power to hire, 

fire, discipline, and control company pay practices as they relate to Plaintiff and other 

company employees.

17. During all time periods pertinent to this Complaint, Plaintiff performed non-exempt work 

for Defendant performing computer drawings of countertops.

18. During all times material hereto, Plaintiff was an hourly employee. Her regular hourly rate 

was seventeen dollars ($17.00) per hour.

19. Plaintiff worked in excess of forty (40) hours per week in one or more of her workweeks 

when employed by Defendant.

20. Defendant failed to pay Plaintiff time-and-one-half her regular hourly rate when Plaintiff 

worked in excess of forty (40) hours in a workweek.

COUNT I – FEDERAL OVERTIME WAGE VIOLATIONS – 29 U.S.C. § 207

21. Plaintiff hereby re-alleges and re-avers Paragraphs 1 through 19 as though set forth fully 

herein.

22. Plaintiff alleges this action pursuant to the Fair Labor Standards Act (“FLSA”), 29 U.S.C. 

§ 216(b).

23. From on or about December 6, 2019, until about March 19, 2020, Defendant refused to 

compensate Plaintiff at the proper overtime rate of time-and-one-half required by the FLSA 

for hours worked in excess of forty (40).

24. Defendant willfully and intentionally refused to pay Plaintiff’s overtime wages as required 

by the FLSA, as Defendant knew of the overtime requirements of the FLSA.

25. Defendant recklessly failed to investigate whether Defendant’s payroll practices were in 

accordance with the FLSA during the relevant time period.

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26. Accordingly, the statute of limitations in this action should be three (3) years as opposed 

to two (2) years.

27. Defendant’s willful or intentional violations of federal wage law entitle Plaintiff to an 

additional amount of liquidated, or double, damages.

28. As a result of the violations alleged herein, Plaintiff was required to retain the undersigned 

counsel and is therefore entitled to recover reasonable attorney’s fees and costs.

WHEREFORE, Plaintiff, ROSSANNA JAIMES, respectfully requests that this Honorable

Court enter judgment in her favor and against Defendant, JABA PRO STONE CORP., and award 

Plaintiff: (a) unliquidated damages to be paid by Defendant; (b) liquidated damages to be paid by 

Defendant; (c) reasonable attorney’s fees and costs to be paid by Defendant; and any and all such 

further relief as may be deemed just and reasonable under the circumstances.

DEMAND FOR JURY TRIAL

Plaintiff, ROSSANNA JAIMES, requests and demands a trial by jury on all appropriate claims.

Dated this 29th day of May, 2020.

Respectfully Submitted,

USA EMPLOYMENT LAWYERSJORDAN RICHARDS, PLLC

805 E. Broward Blvd. Suite 301

Fort Lauderdale, Florida 33301

Ph: (954) 871-0050

 Counsel for Plaintiff, Rossanna Jaimes

By: /s/ Jordan Richards

 JORDAN RICHARDS, ESQUIRE

Florida Bar No. 108372

MELISSA SCOTT, ESQUIRE

 Florida Bar No. 1010123

JAKE BLUMSTEIN, ESQUIRE

 Florida Bar No. 1017746

Jordan@jordanrichardspllc.com

Melissa@jordanrichardspllc.com

Jake@jordanrichardspllc.com

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that the foregoing document was filed via CM/ECF on May 29, 

2020. 

By: /s/ Jordan Richards

JORDAN RICHARDS, ESQUIRE

Florida Bar No. 108372

SERVICE LIST:

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