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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION 

CASE NO.: 

MARIO A. IZAGUIRRE

and other similarly situated individuals,

Plaintiff (s),

v.

PROJECT V INC.,

d/b/a BRAVO ELECTRONICS OUTLET

a/k/a BRAVO ELECTRONICS, INC.,

SHLOMO VAKNINE, and

PINI VAKNINE, individually

Defendants,

___________________________________/ 

COMPLAINT

(OPT-IN PURSUANT TO 29 U.S.C § 216(b)

COMES NOW the Plaintiff MARIO A. IZAGUIRRE by and through the undersigned 

counsel, and hereby sues Defendants PROJECT V INC., d/b/a BRAVO ELECTRONICS 

OUTLET, a/k/a BRAVO ELECTRONICS, INC., and SHLOMO VAKNINE, and PINI 

VAKNINE individually, and alleges: 

JURISDICTION VENUES AND PARTIES

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

for retaliation under the laws of the United States. This Court has jurisdiction pursuant to 

the Fair Labor Standards Act, 29 U.S.C. § 201-219 (Section 216 for jurisdictional 

placement) (“the Act”).

2. At all times material hereto Plaintiff MARIO A. IZAGUIRRE is a resident of Broward

County, Florida, within the jurisdiction of this Honorable Court. Plaintiff is a covered 

employee for purposes of the Act.

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3. Defendant PROJECT V INC., d/b/a BRAVO ELECTRONICS OUTLET, a/k/a BRAVO 

ELECTRONICS, INC. (hereinafter BRAVO ELECTRONICS) is a Florida corporation, 

having its main place of business in Broward County, Florida, where the Plaintiff worked.

The Defendants were and are engaged in interstate commerce. 

4. The individual Defendants SHLOMO VAKNINE and PINI VAKNINE are the 

owners/partners/officers and managers of BRAVO ELECTRONICS. The Defendants

SHLOMO VAKNINE and PINI VAKNINE had operational control of the business and

they are the employers of Plaintiff within the meaning of 29 U.S.C. § 203(d)].

5. All the actions raised in this complaint took place in Broward County Florida, within the 

jurisdiction of this Court.

ALLEGATIONS COMMON TO ALL COUNTS

6. Plaintiff MARIO A. IZAGUIRRE brings this collective action for overtime compensation 

and other relief under the Fair Labor Standards Act (FLSA), 29 U.S.C. §201 et seq., on 

behalf of himself and other similarly situated employees of Defendants.

7. This cause of action is brought by Plaintiff as a collective action to recover from the 

Defendants minimum wages, overtime compensation, liquidated damages, and the costs 

and reasonable attorney’s fees under the provisions of Fair Labor Standards Act, as 

amended, 29 U.S.C. § 201 et seq (the “FLA or the “ACT”) on behalf of Plaintiff, and all 

other current and former employees similarly situated to Plaintiff (“the asserted class”) and 

who worked in excess of forty (40) hours during one or more weeks on or after May 2017, 

(the “material time”) without being compensated overtime wages pursuant to the FLSA. 

8. Corporate Defendant BRAVO ELECTRONICS is a retail business selling computers, 

audio, visual, communication equipments, and electronic gadgets. The Defendant operates 

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a store at the Sawgrass Mills mall located at 12801 W Sunrise Blvd, Sunrise, Florida,

33323, where Plaintiff worked.

9. Defendants BRAVO ELECTRONICS, SHLOMO VAKNINE, and PINI VAKNINE

employed Plaintiff MARIO A. IZAGUIRRE from approximately January 2010, through 

March 18, 2020, or more than 10 years. However, for FLSA purposes, Plaintiff’s relevant 

period of employment is 115 weeks.

10. Plaintiff was hired as a full-time inside salesman working in the showroom of BRAVO 

ELECTRONICS located at the Sawgrass Mills mall. 

11. During his time of employment with Defendants, Plaintiff had a mandatory, regular 

schedule, Plaintiff worked 7 days per week, from Monday to Sunday. Plaintiff worked from 

Monday to Saturday from 9:30 AM to 6:00 PM (8.5 hours each day). On Sunday, Plaintiff 

worked from 10:00 AM to 4:00 PM (6 hours). The Plaintiff worked a minimum average of 

57 hours weekly. The Plaintiff did not take bonafide lunch periods.

12. The Plaintiff was paid on a “commissions only” payment plan, with an established 

commission settlement period of 1 week.

13. Defendants set a fixed commission of 30% over Plaintiff’s total sales. Plaintiff did not have 

other compensation besides his commissions. 

14. The Plaintiff worked a minimum of 57 hours weekly, he was paid entirely by commissions, 

and he was not paid for overtime hours.

15. However, during 2018, 2019, and 2020, Plaintiff’s total earned commissions attributed to 

the pay period (1 week) divided by the 57 hours worked, did not exceed one-half times the 

applicable minimum wage for every hour worked in a workweek. 

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16. As a result, the conditions of the exemption have not been met, and Section 7(i) exemption 

is not applicable. The Plaintiff must be paid an overtime premium for all hours worked 

over 40 in a workweek, at the overtime rate of time and one-half his regular rate of pay. 

Plaintiff is owed overtime wages for the years 2018, 2019, and 2020.

17. In addition, during 11 weeks of 2020, Plaintiff earned commissions for an average of 

$347.91 weekly, which divided by the 57 hours worked in every week resulted in a regular 

rate of $6.11, well below the required minimum wage rate for 2020.

18. Regardless of the Defendants’ payment plan arrangements, Plaintiff was a commissionbased inside salesperson, and he was entitled to be paid at least time and one-half the 

minimum wage rate for all hours worked in a week period, as required by the Fair Labor 

Standard Act.

19. Defendants did not maintain any time-keeping method, but they were able to monitor the 

hours worked by the Plaintiff and other similarly situated individuals. Defendants did not 

keep accurate records of hours worked each workday, hours worked each workweek, and

earnings and wages paid. 

20. Plaintiff was paid weekly with checks and paystubs that did not show the number of days 

and hours worked, the percentage of commissions paid, etc.

21. Therefore, Defendants willfully failed to pay Plaintiff for all his overtime hours at the rate 

of time and one-half his regular rate for every hour that he worked in excess of forty (40), 

in violation of Section 7 (a) of the Fair Labor Standards Act of 1938 (29 U.S.C. 207(a)(1).

Defendants also willfully failed to pay Plaintiff minimum wages in violation of the Fair 

Labor Standards Act, 29 U.S.C. §206, et seq.

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22. Plaintiff did not return to work after the quarantine period established by Broward County, 

(approximately March 18, 2020),

23. Plaintiff is not in possession of time and payment records. However, the Plaintiff will 

provide a preliminary Statement of Claim based on W-2 forms (Wage and Tax Statement") 

for 2018, and 2019, and also based on 1 paystub dated March 2020, showing Plaintiff’s

earnings accumulated for 2020. Plaintiff will amend his Statement of Claim, after proper 

discovery. 

24. Plaintiff MARIO A. IZAGUIRRE seeks to recover overtime and minimum wages for the 

relevant period, liquidated damages, and any other relief as allowable by law. 

25. The additional persons who may become Plaintiffs in this action are employees and/or 

former employees of Defendants who are and who were subject to the unlawful payroll 

practices and procedures of Defendants and were not paid minimum or overtime wages at 

the rate of time and one half of their regular rate of pay for all overtime hours worked in 

excess of forty. 

COUNT I:

WAGE AND HOUR FEDERAL STATUTORY VIOLATION; 

FAILURE TO PAY OVERTIME; AGAINST ALL DEFENDANTS

26. Plaintiff MARIO A. IZAGUIRRE re-adopts every factual allegation as stated in paragraphs 

1-25 above as if set out in full herein. 

27. This action is brought by Plaintiff MARIO A. IZAGUIRRE and those similarly-situated to 

recover from the Employer unpaid overtime compensation, as well as an additional amount 

as liquidated damages, costs, and reasonable attorney’s fees under the provisions of 29 

U.S.C. § 201 et seq., and specifically under the provisions of 29 U.S.C. § 207. 29 U.S.C. 

§ 207 (a)(1) states, “No employer shall employ any of his employees... for a workweek 

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longer than 40 hours unless such employee receives compensation for his employment in 

excess of the hours above specified at a rate not less than one and a half times the regular 

rate at which he is employed.”

28. The employer BRAVO ELECTRONICS was and is engaged in interstate commerce as 

defined in §§ 3 (r) and 3(s) of the Act, 29 U.S.C. § 203(r) and 203(s)(1)(A). The Defendant

is a retailer of electronic audio-visual, and communications equipment. Defendant has

more than two employees directly and recurrently engaged in interstate commerce. At all 

times pertinent to this Complaint, the Employer/Defendant operates as an organization that

sells and/or markets its services and/or goods to customers from throughout the United 

States and also provides its services for goods sold and transported from across state lines 

of other states. Employer/Defendant obtains and solicits funds from non-Florida sources, 

accepts funds from non-Florida sources, uses telephonic transmissions going over state 

lines to do its business, transmits funds outside the State of Florida. Upon information and 

belief, the annual gross revenue of the Employer/Defendant was always more than

$500,000 per annum. Defendant’s business activities involve those to which the Fair Labor 

Standards Act applies. Therefore, there is enterprise coverage

29. Plaintiff was employed by an enterprise engaged in interstate commerce and through his 

daily activities, Plaintiff and other employees similarly situated regularly and recurrently

participated directly in interstate business, by handling goods and materials that were 

moved across State lines at any time in the course of business, and by completing credit 

card transactions. Therefore, there is individual coverage.

30. Defendants BRAVO ELECTRONICS, SHLOMO VAKNINE, and PINI VAKNINE 

employed Plaintiff MARIO A. IZAGUIRRE from approximately January 2010, through 

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March 18, 2020, or more than 10 years. However, for FLSA purposes, Plaintiff’s relevant 

period of employment is 115 weeks. 

31. Plaintiff was hired as a full-time inside salesman working in the showroom of BRAVO 

ELECTRONICS located at the Sawgrass Mills mall. 

32. During his time of employment with Defendants, Plaintiff had a mandatory, regular 

schedule, Plaintiff worked 7 days per week a minimum average of 57 hours weekly. The 

Plaintiff did not take bonafide lunch periods.

33. The Plaintiff was paid on a “commissions only” payment plan, with an established 

commission settlement period of 1 week.

34. Defendants set a fixed commission of 30% over Plaintiff’s total sales. Plaintiff did not have 

other compensation besides his commissions. 

35. During 2018, 2019, and 2020, Plaintiff’s total earned commissions attributed to the pay 

period (1 week) divided by the 57 hours worked, did not exceed one-half times the 

applicable minimum wage for every hour worked in a workweek. 

36. As a result, the conditions of the exemption have not been met, and Section 7(i) exemption 

is not applicable. The Plaintiff must be paid an overtime premium for all hours worked 

over 40 in a workweek, at the overtime rate of time and one-half his regular rate of pay. 

Plaintiff is owed overtime wages for the years 2018, 2019, and 2020.

37. Defendants did not maintain any time-keeping method, but they were able to monitor the 

hours worked by the Plaintiff and other similarly situated individuals. Defendants did not 

keep accurate records of hours worked each workday, hours worked each workweek, and 

earnings and wages paid. 

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38. Therefore, Defendants willfully failed to pay Plaintiff for all his overtime hours at the rate 

of time and one-half his regular rate for every hour that he worked in excess of forty (40), 

in violation of Section 7 (a) of the Fair Labor Standards Act of 1938 (29 U.S.C. 207(a)(1).

39. Plaintiff was paid weekly with checks and paystubs that did not show the number of days 

and hours worked, the percentage of commissions paid, etc.

40. The records, if any, concerning the number of hours, worked by Plaintiff and all other 

employees, and the compensation actually paid to such employees should be in the 

possession and custody of Defendants. Nevertheless, upon information and belief, 

Defendants did not keep any time-keeping method and did not maintain accurate records.

41. Defendants violated the record-keeping requirements of FLSA, 29 CFR Part 516.

42. Upon information and belief, Defendants never posted any notice, as required by the Fair 

Labor Standards Act and Federal Law, to inform employees of their Federal rights to 

overtime and minimum wage payments.

43. Defendants violated the Posting requirements of 29 U.S.C. § 516.4.

44. Prior to the completion of discovery and to the best of Plaintiff’s knowledge, at the time of 

the filing of this complaint, the Plaintiff’s good faith estimate of unpaid wages are as 

follows:

 *Please note that these amounts are based on a preliminary calculation and that these 

 figures could be subject to modification as discovery could dictate. 

 *Florida's minimum wage is higher than the federal minimum wage. As per FLSA 

 regulations, the higher minimum wage applies.

a. Total amount of alleged unpaid wages:

Twenty-Nine Thousand Two Hundred Seventy-Four Dollars and 68/100 

($29,274.68)

b. Calculation of such wages:

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Total period of employment: More than 10 years

Total relevant weeks: 115

Total Number of hours worked: 57 hours weekly

Total number of unpaid O/T hours: 17 hours weekly.

1.- Unpaid Overtime 2018 = 52 weeks

Total relevant weeks of employment: 52 weeks 

Total hours worked: 57 hours weekly

Unpaid O/T hours: 17 hours weekly

W-2 form: 34,101.20:52 weeks= $655.80 weekly: 57 hours weekly=$11.51

Regular rate: $11.51 x 1.5=$17.27 O/T rate

O/T rate $17.27 x 17 hours=$293.59 weekly x 52 weeks=$15,266.68

2.- Unpaid Overtime 2019 = 52 weeks

Total relevant weeks of employment: 52 weeks 

Total hours worked: 57 hours weekly

Unpaid O/T hours: 17 hours weekly

W-2 form: 25,927.20:52 weeks= $498.60 weekly:57 hours weekly=$8.75

Regular rate: $8.75 x 1.5= $13.13 O/T rate

O/T rate $13.13 x 17 hours=$223.21 weekly x 52 weeks= $11,606.92

3.- Unpaid Overtime 2020 = 11 weeks

Total relevant weeks of employment: 11 weeks 

Total hours worked: 57 hours weekly

Unpaid O/T hours: 17 hours weekly

Earnings 2020: 3,827.00:11 weeks= $347.91 weekly:57 hours weekly=$6.11

FL Minimum wage 2020 $8.56 x 1.5=$12.84 O/T rate

O/T rate $12.84 x 17 hours=$218.28 weekly x 11 weeks=$2,401.08

Total #1, #2 and #3= $29,274.68

c. Nature of wages (e.g. overtime or straight time):

 This amount represents the unpaid overtime.

45. At all times material hereto, the Employers/Defendants failed to comply with Title 29 

U.S.C. §§ 201-219 and 29 C.F.R. § 516.2 and § 516.4 et seq. in that Plaintiff and those 

similarly-situated performed services and worked in excess of the maximum hours 

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provided by the Act but no provision was made by the Defendants to properly pay them at 

the rate of time and one half for all hours worked in excess of forty hours (40) per 

workweek as provided in said Act. 

46. Defendants knew and/or showed reckless disregard of the provisions of the Act concerning 

the payment of overtime wages as required by the Fair Labor Standards Act and remain 

owing Plaintiff and those similarly-situated these overtime wages since the commencement 

of Plaintiff’s and those similarly-situated employee’s employment with Defendants as set 

forth above, and Plaintiff and those similarly-situated are entitled to recover double 

damages. 

47. At the times mentioned, individual Defendants SHLOMO VAKNINE and PINI 

VAKNINE were the owners/officers and managers of Defendant Corporation BRAVO 

ELECTRONICS. Individual Defendants SHLOMO VAKNINE and PINI VAKNINE

were the employers of Plaintiff and others similarly situated, within the meaning of Section 

3(d) of the “Fair Labor Standards Act” [29 U.S.C. § 203(d)]. In that, these individual 

Defendants acted directly in the interest of BRAVO ELECTRONICS in relation to its

employees including Plaintiff and others similarly situated. Individual Defendants

SHLOMO VAKNINE and PINI VAKNINE had total financial and operational control of 

the Corporation, determining Plaintiff’s employment terms and conditions of employment 

and they are jointly and severally liable for Plaintiff’s damages 

48. Defendants BRAVO ELECTRONICS, SHLOMO VAKNINE, and PINI VAKNINE

willfully and intentionally refused to pay Plaintiff overtime wages as required by the law 

of the United States and remain owing Plaintiff these overtime wages since the 

commencement of Plaintiff’s employment, as set forth above. 

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49. The Plaintiff has retained the law offices of the undersigned attorney to represent him in 

this action and is obligated to pay a reasonable attorneys’ fee. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff MARIO A. IZAGUIRRE and those similarly situated respectfully 

requests that this Honorable Court: 

A. Enter judgment for Plaintiff and others similarly situated and against the Defendants

BRAVO ELECTRONICS, SHLOMO VAKNINE, and PINI VAKNINE based on

Defendants’ willful violations of the Fair Labor Standards Act, 29 U.S.C. § 201 et seq.; 

and

B. Award Plaintiff actual damages in the amount shown to be due for unpaid overtime 

compensation for hours worked more than forty weekly, with interest; and

C. Award Plaintiff an equal amount in double damages/liquidated damages; and

D. Award Plaintiff reasonable attorneys' fees and costs of suit; and 

E. Grant such other and further relief as this Court deems equitable and just and/or 

available pursuant to Federal Law. 

JURY DEMAND

Plaintiff MARIO A. IZAGUIRRE and those similarly situated demand trial by a jury of all issues 

triable as of right by a jury.

COUNT II:

F.L.S.A. WAGE AND HOUR FEDERAL STATUTORY VIOLATION: FAILURE TO 

PAY MINIMUM WAGE; AGAINST ALL DEFENDANTSS

50. Plaintiff re-adopts every factual allegation as stated in paragraphs 1-25 of this complaint 

as if set out in full herein.

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51. The employer BRAVO ELECTRONICS was and is engaged in interstate commerce as 

defined in §§ 3 (r) and 3(s) of the Act, 29 U.S.C. § 203(r) and 203(s)(1)(A). The Defendant 

is a retailer of electronic audio-visual, and communications equipment. Defendant has 

more than two employees directly and recurrently engaged in interstate commerce. At all 

times pertinent to this Complaint, the Employer/Defendant operates as an organization that 

sells and/or markets its services and/or goods to customers from throughout the United 

States and also provides its services for goods sold and transported from across state lines 

of other states. Employer/Defendant obtains and solicits funds from non-Florida sources, 

accepts funds from non-Florida sources, uses telephonic transmissions going over state 

lines to do its business, transmits funds outside the State of Florida. Upon information and 

belief, the annual gross revenue of the Employer/Defendant was always more than

$500,000 per annum. Defendant’s business activities involve those to which the Fair Labor 

Standards Act applies. Therefore, there is enterprise coverage

52. Plaintiff was employed by an enterprise engaged in interstate commerce and through his 

daily activities, Plaintiff and other employees similarly situated regularly and recurrently

participated directly in interstate business, by handling goods and materials that were 

moved across State lines at any time in the course of business, and by completing credit 

card transactions. Therefore, there is individual coverage.

53. This action is brought by the Plaintiff to recover from the Employer unpaid minimum 

wages, as well as an additional amount as liquidated damages, costs, and reasonable 

attorney’s fees under the provisions of 29 U.S.C. § 201 et seq., and specifically under the 

provisions of 29 U.S.C. §206. U.S.C. §206 states “Every employer shall pay to each of his 

employees who in any workweek is engaged in commerce or in the production of goods 

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for commerce, or is employed in an enterprise engaged in commerce or in the production 

of goods for commerce, wages at the following rates: 

(1) except as otherwise provided in this section, not less than—

(A) $5.85 an hour, beginning on the 60th day after May 25, 2008; 

(B) $6.55 an hour, beginning 12 months after that 60th day; and 

 (C) $7.25 an hour, beginning 24 months after that 60th day.

54. Defendants BRAVO ELECTRONICS, SHLOMO VAKNINE, and PINI VAKNINE 

employed Plaintiff MARIO A. IZAGUIRRE from approximately January 2010, through 

March 18, 2020, or more than 10 years. However, for FLSA purposes, Plaintiff’s relevant 

period of employment is 115 weeks. 

55. Plaintiff was hired as a full-time inside salesman working in the showroom of BRAVO 

ELECTRONICS located at the Sawgrass Mills mall. 

56. During his time of employment with Defendants, Plaintiff had a mandatory, regular 

schedule, Plaintiff worked 7 days per week a minimum average of 57 hours weekly. The 

Plaintiff did not take bonafide lunch periods.

57. The Plaintiff was paid on a “commissions only” payment plan, with an established 

commission settlement period of 1 week.

58. Defendants set a fixed commission of 30% over Plaintiff’s total sales. Plaintiff did not have 

other compensation besides his commissions. 

59. However, during 11 weeks of 2020, Plaintiff earned a weekly average of $347.91 of 

commissions, which divided by the 57 hours worked in every week resulted in a regular 

rate of $6.11, well below the required minimum wage rate for 2020.

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60. There is a substantial number of hours that were not compensated at the minimum wage 

rate as established by the FLSA.

61. Regardless of the Defendants’ payment plan arrangements, Plaintiff was a commissionbased inside salesperson, and he was entitled to be paid at least the minimum wage rate for 

regular hours worked in a week period, as required by the Fair Labor Standard Act.

62. Defendants did not maintain any time-keeping method, but they were able to monitor the 

hours worked by the Plaintiff and other similarly situated individuals. Defendants did not 

keep accurate records of hours worked each workday, hours worked each workweek, and 

earnings and wages paid. 

63. Plaintiff was paid weekly with checks and paystubs that did not show the number of days 

and hours worked, the percentage of commissions paid, etc.

64. Therefore, Defendants willfully failed to pay Plaintiff minimum wages in violation of the 

Fair Labor Standards Act, 29 U.S.C. §206, et seq.

65. The records, if any, concerning the number of hours worked by Plaintiff and all other 

employees, and the compensation actually paid to such employees should be in the 

possession and custody of Defendants. However, upon information and belief, Defendants

did not maintain accurate and complete time records of hours worked by the Plaintiff and 

other similarly situated individuals 

66. Defendants violated the record-keeping requirements of FLSA, 29 CFR Part 516.

67. Upon information and belief, Defendants never posted any notice, as required by the Fair 

Labor Standards Act and Federal Law, to inform employees of their Federal rights to 

overtime and minimum wage payments.

68. Defendants violated the Posting requirements of 29 U.S.C. § 516.4.

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69. Prior to the completion of discovery and to the best of Plaintiff’s knowledge, at the time 

of the filing of this complaint, the Plaintiff’s good faith estimate of unpaid wages are as 

follows: 

*Please note that these amounts are based on a preliminary calculation and that these 

figures could be subject to modification as discovery could dictate. 

Florida's minimum wage in 2020 is $8.56, which is higher than the federal minimum wage. 

As per FLSA regulations, the higher minimum wage applies.

a. Total amount of alleged unpaid wages:

One Thousand Seventy-Eight Dollars and 00/100 ($1,078.00)

b. Calculation of such wages: 

Total relevant weeks: 11 weeks in 2020

Total hours worked: 57 hours per week

Wage rate paid: $6.11

Florida minimum wage 2020: $8.56 an hour-$6.11 rate paid=$2.45 difference

 Min. wage difference $2.45 x 40 hours= $98.00 weekly x 11 weeks=$1,078.00

 

c. Nature of wages:

This amount represents unpaid minimum wages at Florida rate.

70. The Defendants unlawfully failed to pay minimum wages to Plaintiff. Plaintiff seeks to 

recover for minimum wage violations accumulated during his relevant time of 

employment. 

71. The Defendants knew and/or showed reckless disregard of the provisions of the Act 

concerning the payment of minimum wages as required by the Fair Labor Standards Act 

and remain owing Plaintiff these minimum wages.

72. At the times mentioned, individual Defendants SHLOMO VAKNINE and PINI 

VAKNINE were the owners/officers and managers of Defendant Corporation BRAVO 

ELECTRONICS. Individual Defendants SHLOMO VAKNINE and PINI VAKNINE

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were the employers of Plaintiff and others similarly situated within the meaning of Section 

3(d) of the “Fair Labor Standards Act” [29 U.S.C. § 203(d)]. In that, these individual 

Defendants acted directly in the interest of BRAVO ELECTRONICS in relation to its

employees including Plaintiff and others similarly situated. Individual Defendants

SHLOMO VAKNINE and PINI VAKNINE had total financial and operational control of 

the Corporation, determining Plaintiff’s employment terms and conditions of employment 

and they are jointly and severally liable for Plaintiff’s damages 

73. Defendants BRAVO ELECTRONICS, SHLOMO VAKNINE, and PINI VAKNINE

willfully and intentionally refused to pay Plaintiff minimum wages as required by the law 

of the United States, and remain owing Plaintiff these minimum wages as set forth above. 

74. Plaintiff has retained the law offices of the undersigned attorney to represent him in this 

action and is obligated to pay a reasonable attorneys’ fee. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff MARIO A. IZAGUIRRE respectfully requests that this Honorable Court: 

A. Enter judgment for Plaintiff and against the Defendants BRAVO ELECTRONICS, 

SHLOMO VAKNINE, and PINI VAKNINE based on Defendants’ willful violations of 

the Fair Labor Standards Act, 29 U.S.C. § 201 et seq. and other Federal Regulations; 

and

B. Award Plaintiff actual damages in the amount shown to be due for unpaid minimum 

wages, with interest; and

C. Award Plaintiff an equal amount in double damages/liquidated damages; and

D. Award Plaintiff reasonable attorneys' fees and costs of suit; and 

E. Grant such other and further relief as this Court deems equitable and just and/or 

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available pursuant to Federal Law. 

JURY DEMAND

Plaintiff MARIO A. IZAGUIRRE and those similarly situated demand trial by a jury of all issues 

triable as of right by a jury.

DATED: June 19, 2020

 Respectfully submitted,

 By: _/s/ Zandro E. Palma____

 ZANDRO E. PALMA, P.A.

 Florida Bar No.: 0024031

 9100 S. Dadeland Blvd.

 Suite 1500

 Miami, FL 33156

 Telephone: (305) 446-1500

 Facsimile: (305) 446-1502

 zep@thepalmalawgroup.com

 Attorney for Plaintiff

 

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