UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION

CASE NO.:

JOHN ADAMS, 

Plaintiff, 

v.

THERAPIES 4 KIDS, INC., 

a Florida Company, and 

EILEEN DE OLIVEIRA, 

individually.

Defendants. 

 / 

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

Plaintiff, JOHN ADAMS, sues Defendants, THERAPIES 4 KIDS, INC., a Florida 

Company, and EILEEN DE OLIVEIRA, an individual, and states as follows: 

INTRODUCTION 

1. This is an action by JOHN ADAMS against his former employer for minimum 

wages pursuant to the Fair Labor Standards Act.

2. Plaintiff seeks damages and a reasonable attorney’s fees. 

JURISDICTION, PARTIES, VENUE & GENERAL ALLEGATIONS

2. This action arises under the Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 206 

and is also for breach of contract. 

3. The Court has jurisdiction over the claims pursuant to 29 U.S.C. § 216(b). 

4. Plaintiff, JOHN ADAMS (hereinafter “ADAMS”) is a resident of Broward County, 

Florida and was at all times material, employed by Defendant, THERAPIES 4 KIDS, INC. 

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(hereinafter “T4k”) as a Customer Relations Representative and to assist with the company’s 

marketing.

5. ADAMS was an employee as defined by 29 U.S.C. § 203(e), and during his 

employment with Defendant, was engaged in commerce or in the production of goods for 

commerce. 

6. T4K is a Florida company with headquarters in Broward County, Florida, doing 

business in the Southern District of Florida, is an enterprise engaged in an industry affecting 

commerce, is an employer as defined by 29 U.S.C. § 203(d) and (s)(1), in that it has employees 

engaged in commerce or in the production of goods for commerce, or that has employees handling, 

selling, or otherwise working on goods or materials that have been moved in or produced for 

commerce by any person; and it is an enterprise whose annual gross volume of sales made or 

business done is not less than $500,000 (exclusive of excise taxes at the retail level that are 

separately stated) which has employees subject to the provisions of the FLSA, 29 U.S.C. § 206. 

7. Defendant, EILEEN DE OLIVEIRA (hereinafter “OLIVEIRA”), is a co-owner and

managing member of T4K, with operational control and direct control over the day to day 

operations, including compensation of employees and the setting of work schedules of persons 

working at T4K, and therefore is an employer under the FLSA. 

8. The claim arose within the Southern District of Florida, which is where venue is 

proper. 

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COUNT I – VIOLATION OF FLSA BY DEFENDANTS, T4K AND OLIVEIRA –

MINIMUM WAGE

9. Adams realleges the allegations of paragraphs 1 through 8 above as though fully 

set forth herein.

10. ADAMS worked for T4K for several hours during the last five (5) days of his

employment, March 30, 2020 through April 3, 2020, but received no compensation whatsoever 

for the work he performed. 

11. On or about April 3, 2020, OLIVEIRA sent a text message to ADAMS advising 

him that he would receive his last paycheck until his partner (Maria Santoro) returned two laptop 

computers OLIVEIRA previously gifted to Ms. Santoro. 

12. T4K’s failure to pay ADAMS his final paycheck violates 29 U.S.C. § 206(a)(1) by 

not paying him at least a minimum wage. 

13. ADAMS is entitled, pursuant to the FLSA to recover from T4K and OLIVIERA: 

a. The applicable minimum wage in effect at the times he worked without 

receiving compensation; 

b. As liquidated damages, an amount equal to the unpaid minimum wage he is 

owed; 

c. The costs of this action; and 

d. Reasonable attorney’s fees. 

WHEREFORE, Plaintiff, ADAMS prays that this Honorable Court: 

a. Enter judgment for ADAMS and against T4K and OLIVEIRA on the basis 

of their willful violations of the FLSA; 

b. Award ADAMS actual and compensatory damages in the amount shown to 

be due for unpaid minimum wages; 

c. Award ADAMS an equal amount in liquidated damages; 

d. Award ADAMS reasonable attorney’s fees and costs of suit; and 

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e. Other such relief as this Court deems just. 

Jury Demand

Plaintiff demands trial by jury. 

Dated: May 25, 2020

Respectfully submitted,

By: /s/ Laurence M. Krutchik, Esq.

LAW OFFICE OF LAURENCE M. 

KRUTCHIK, P.A.

Fla. Bar No. 0069449

Attorney for Adams and Cohen

7450 SW 172nd Street

Palmetto Bay, Florida 33157

Email: LMKAttorney@gmail.com

Telephone: (305) 537-6866

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