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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:20-CV-22310

PATRICIA WOHLGEMUTH,

Plaintiff,

vs.

CHANDI GROUP, INC.,

TULSI CHANDIRAMANI, and

SHEILA CHANDIRAMANI,

Defendants.

______________________________/

COMPLAINT

Plaintiff, Patricia Wohlgemuth, sues Defendants, Chandi Group, Inc., Tulsi 

Chandiramani, and Sheila Chandiramani, as follows:

Parties, Jurisdiction, and Venue

1. Plaintiff, Patricia Wohlgemuth, was and is a resident of Miami-Dade 

County, Florida, at all times material, and he is sui juris. 

2. Plaintiff was an hourly employee of Defendants, as the term “employee” is defined 

by 29 U.S.C. §203(e).

3. Plaintiff was a non-exempt employee of Defendants.

4. Plaintiff consents to participate in this lawsuit.

5. Defendant, Chandi Group, Inc., is a Florida for-profit corporation that is 

authorized to conduct and that actually conducts its jewelry business in this District, with its

principal place of business within Miami-Dade County, Florida, and it is sui juris. 

6. Defendant, Tulsi Chandiramani, was at all material times a resident of this 

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District; he was and is a manager, owner, officer, director, and/or operator of the corporate 

Defendant for the relevant time period. He ran its day-to-day operations and was partially or 

totally responsible for paying Plaintiff’s wages. 

7. Defendant, Sheila Chandiramani, was at all material times a resident of this 

District; she was and is a manager, owner, officer, director, and/or operator of the corporate 

Defendant for the relevant time period. She also ran its day-to-day operations and was partially 

or totally responsible for paying Plaintiff’s wages. 

8. Venue is proper pursuant to 28 U.S.C. §1391(b)(ii) because Defendants transact 

business in this District, because Defendants, maintained their principal places of business in this 

District, because Plaintiff worked and was due to be paid in Miami-Dade County, and because 

most if not all of the operational decisions were made in this District.

9. This Court has original jurisdiction over Plaintiff’s federal question claims 

pursuant to 28 U.S.C. §1331 and 26 U.S.C. §201, et seq.

10. Any/all condition(s) precedent to filing this lawsuit occurred and/or was satisfied 

by Plaintiff.

11. Plaintiff retained the undersigned counsel and agreed to pay a reasonable fee for 

all services rendered.

Background Facts

12. Defendants were Plaintiff’s direct employers, joint employers and co-employers 

for purposes of the FLSA, as the term “employer” is defined by 29 U.S.C. §203(d). 

13. Defendants regularly employed two or more employees for the relevant time 

period that handled goods or materials that travelled through interstate commerce, or used 

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instrumentalities of interstate commerce, thus making Defendants’ business an enterprise covered 

by the Fair Labor Standards Act.

14. Defendants have been at all times material engaged in interstate commerce in the 

course of their marketing, sale, and transmission of jewelry, goods, materials, supplies, and 

equipment that have all moved through interstate commerce

15. In particular, Defendants own and operate a company , Chandi Group, Inc., that 

sells jewelry and precious materials that travel in interstate commerce.

16. The individual Defenants, Tulsi Chandiramani, and Sheila Chandiramani and 

also owned/operated a now dissolved company, Chandi Group Brickell, LLC, that also sold 

jewelry and precious metals that likewise traveled in interstate commerce. 

17. Defendants also engage in interstate commerce in the course of their submission 

of billings and receipt of payment involving out-of-state payors. 

18. Furthermore, Defendants obtain, solicit, exchange and send funds to and from 

outside of the State of Florida, regularly and recurrently use telephonic transmissions going 

outside of the State of Florida to conduct business, and transmit electronic information through 

computers, the internet, via email, and otherwise outside of the State of Florida in the course of 

their business.

19. Defendants’ annual gross revenues derived from this interstate commerce are 

believed to be in excess of $500,000.00 for the relevant time period and/or in excess of $125,000 

for each relevant fiscal quarter.

20. Plaintiff worked for Defendants, Tulsi Chandiramani, and Sheila Chandiramani,

from February 1, 2005 to January 21, 2020. During part of this time Plaintiff also worked for 

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Chandi Group Brickell, LLC, and for the remainder of the time she worked for Chandi Group, 

LLC.

21. Defendants coordinated their merchandise, staffing, and efforts so as to operate as 

a single “enterprise” during Plaintiff’s employment with them.

22. Plaintiff’s work for Defendants was actually in or so closely related to the 

movement of commerce while she worked for Defendants that the Fair Labor Standards Act 

applies to Plaintiff’s work for Defendants. 

23. Plaintiff would regularly and routinely receive merchandise that arrived from 

outside of the State of Florida to be then (re)sold at Defendants’ store(s), she regularly and 

routinely utilized the internet in her work, she regularly and routinely conducted business on the 

telephone with persons located outside of the State of Florida, and she regularly and routinely 

sold merchandise that traveled outside of the State of Florida.

24. Plaintiff worked for Defendants in their two jewelry stores selling merchandise, 

cleaning, making repairs, and doing other functions for Defendants from February 1, 2005 to 

January 21, 2020.

25. These other functions would include conducting personal errands for the 

individual Defendants.

26. To the extent that records exist regarding the exact dates of Plaintiff’s 

employment, such records are believed to be in Defendants’ exclusive custody.

27. Defendants paid Plaintiff a salary of $31,000 per year.

28. Plaintiff would regularly and routinely work more than 40 hours in a workweek 

for Defendants.

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Liability

29. Defendants failed and refused to pay Plaintiff overtime wages calculated at time 

and one-half times her regular hourly rate(s) of pay for all of the hours that she worked over 40 

hours in a given workweek.

30. Defendants willfully and intentionally refused to pay Plaintiff wages at a rate of 

time and one-half times her regular rate of pay for each of the overtime hours she worked during 

the relevant time period by paying Plaintiff for up to 40 hours each week without paying her

overtime wages for any of the overtime hours she worked.

31. Defendants either recklessly failed to investigate whether their failure to pay 

Plaintiff an overtime wage for the hours beyond 40 in a workweek during the relevant time 

period violated the FLSA, they intentionally misled Plaintiff to believe that Defendants were not 

required to pay an overtime rate, and/or Defendants concocted a scheme pursuant to which the 

deprived Plaintiff of the overtime pay earned.

32. Plaintiff is entitled to a backpay award of overtime wages for all overtime hours 

she worked, plus an equal amount as a penalty, plus all attorneys’ fees and costs.

WHEREFORE Plaintiff, Patricia Wohlgemuth, demands the entry of a judgment in her

favor and against Defendants, Chandi Group, Inc., Tulsi Chandiramani, and Sheila 

Chandiramani, jointly and severally after trial by jury, and as follows:

a. That Plaintiff recover compensatory overtime wage damages and an equal 

amount of liquidated damages as provided under the law and in 29 U.S.C. 

§ 216(b);

b. That Plaintiff recover pre-judgment interest on all unpaid overtime wages 

if the Court does not award liquidated damages;

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c. That Plaintiff recover an award of reasonable attorneys’ fees, costs, and 

expenses pursuant to the FLSA;

d. That Plaintiff recover all interest allowed by law;

e. That Defendants be Ordered to make Plaintiff whole by providing 

appropriate overtime pay and other benefits wrongly denied in an amount 

to be shown at trial and other affirmative relief; 

f. That the Court declare Defendants to be in willful violation of the 

overtime provisions of the FLSA; and 

g. Such other and further relief as the Court deems just and proper.

DEMAND FOR JURY TRIAL

Plaintiff, Patricia Wohlgemuth, demands a trial by jury of all issues so triable.

Respectfully submitted this 3rd day of June 2020,

s/Brian H. Pollock, Esq.

Brian H. Pollock, Esq. (174742)

brian@fairlawattorney.com

FAIRLAW FIRM

7300 North Kendall Drive

Suite 450

Miami, FL 33156

Tel: 305.230.4884

Counsel for Plaintiff

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