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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.: 

JULIO LEE HERNANDEZ

and other similarly situated individuals,

Plaintiff(s),

v.

GALENOS MEDICAL CENTER CORP.

and MARIA C. ELOY, individually

Defendants,

__________________________________/

COMPLAINT

(OPT-IN PURSUANT TO 29 U.S.C § 216(b)

COMES NOW the Plaintiff JULIO LEE HERNANDEZ, and other similarly 

situated individuals, by and through the undersigned counsel, and hereby sues Defendants 

GALENOS MEDICAL CENTER CORP. and MARIA C. ELOY individually, and alleges: 

JURISDICTION VENUES AND PARTIES

1. This is an action to recover money damages for unpaid overtime wages 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. Plaintiff JULIO LEE HERNANDEZ is a resident of Miami-Dade County, Florida, 

within the jurisdiction of this Honorable Court. Plaintiff is a covered employee for 

purposes of the Act.

3. Corporate Defendant GALENOS MEDICAL CENTER CORP. (hereinafter 

GALENOS MEDICAL CENTER, or Defendant) is a Florida corporation having 

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its main place of business in Miami-Dade County, Florida, where the Plaintiff 

worked for Defendant. At all times material hereto, Defendant was engaged in 

interstate commerce. 

4. The individual Defendant MARIA C. ELOY was and is now the 

owner/partner/president, and she directed operations of GALENOS MEDICAL 

CENTER. Defendant MARIA C. ELOY is the employer 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)].

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

the jurisdiction of this Court.

GENERAL ALLEGATIONS

6. This cause of action is brought by Plaintiff JULIO LEE HERNANDEZ, and other 

similarly situated employees to recover from the Defendants 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”).

7. Corporate Defendant GALENOS MEDICAL CENTER is a medical center that 

provides a complete range of medical services including transportation services. 

8. Defendants GALENOS MEDICAL CENTER and MARIA C. ELOY employed 

Plaintiff JULIO LEE HERNANDEZ as a non-exempt local driver, approximately 

from November 14, 2018 to April 22, 2020 or 75 weeks. However, for FLSA 

purposes, Plaintiff’s relevant period of employment is 70 weeks, because Plaintiff 

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did not work overtime hours since approximately March 15, 2020, (the beginning 

of the Coronavirus quarantine in Dade County).

9. Within his time of employment, Plaintiff was paid at the wage rate of $11.00, 

$12.00, and $12.50 an hour. Plaintiff worked at the medical center located at 8504 

NW 103 ST. Hialeah Gardens, FL 33016. 

10. Plaintiff’s duties consisted of transporting patients from their homes to the medical 

center, taking them to specialists' medical appointments, and then returning patients 

back home.

11. During his employment with Defendants, Plaintiff had a regular schedule, he 

worked 5 days per week from Monday to Friday, within the timeframe from 5:30 

AM, to 3:00 PM, depending on the needs of the patients. Plaintiff completed a 

minimum of 45 hours every week. The Plaintiff was unable to take bonafide lunch 

breaks.

12. In addition, during the relevant period of employment, after completing his daily 

shifts, Plaintiff and other similarly situated drivers, worked at home in a clerical 

capacity. On Mondays, Tuesdays, Wednesdays, Thursdays, and Sundays, Plaintiff 

worked at home making telephone calls to confirm scheduled patients to be 

transported the following day. Plaintiff employed at least 2 hours every day to 

confirm the transportation of elderly patients. Thus, every week the Plaintiff spent 

an average of 10 additional uncompensated off-the-clock overtime hours.

13. Consequently, Plaintiff worked a total average of 55 hours, or 15 overtime hours 

weekly. However, he was paid for only 2.5 overtime hours. There is a substantial 

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number of overtime hours that were not paid to Plaintiff at any rate. Not even at the 

minimum wage rate.

14. Plaintiff was paid for 40 regular hours, plus 2.5 overtime hours at the correct 

overtime rate. Nevertheless, Plaintiff was not paid for all his overtime hours as 

required by the Fair Labor Standards Act.

15. During the relevant time of employment, Plaintiff did not clock in and out, but the 

Defendants were in complete control of Plaintiff’s working hours, and they were 

able to keep track of the hours worked by Plaintiff and other similarly situated 

individuals.

16. Therefore, Defendants willfully failed to pay Plaintiff 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). and 29 U.S.C. § 201 et seq.

17. Plaintiff was paid bi-weekly with checks and paystubs that did not show the real 

number of days and hours worked.

18. On or about December 2019, Plaintiff began complaining about his wages with his 

supervisor Arsenio LNU. Plaintiff also complained about the lack of overtime pay. 

Plaintiff complained about overtime pay for the last time on or about the first week 

of February. 

19. As a result, on or about April 22, 2020, the Plaintiff was fired using pretextual 

reasons.

20. The Plaintiff is not in possession of time and payment records, and he does not 

remember the dates in which his wage-rates were raised. However, he will provide 

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a good faith estimate based only on his last wage-rate of $12.50 an hour. After 

proper discovery, the Plaintiff is going to amend his statement of claim.

21. Plaintiff JULIO LEE HERNANDEZ seeks to recover retaliatory damages, unpaid 

overtime hours, liquidated damages, and any other relief as allowable by law. 

22. 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 

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

23. Plaintiff JULIO LEE HERNANDEZ re-adopts every factual allegation as stated in 

paragraphs 1-22 above as if set out in full herein. 

24. This action is brought by Plaintiff JULIO LEE HERNANDEZ and those similarlysituated 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 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.”

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25. This cause of action is brought by Plaintiff JULIO LEE HERNANDEZ as a 

collective action to recover from the Defendants overtime compensation, liquidated 

damages, costs and reasonable attorney’s fees under the provisions of the 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 November 2018, (the “material time”) 

without being compensated “at a rate not less than one and a half times the regular 

rate at which he is employed.”

26. Defendant GALENOS MEDICAL CENTER was and is engaged in interstate 

commerce pursuant to 29 U.S. Code § 203 (r) (2) (C) and 203 (s) (1) (C). Defendant 

provides medical services and receives payments from Medicare and Medicaid. 

Defendant has more than two employees recurrently engaged in commerce or in 

the production of goods for commerce by regularly and recurrently using the 

instrumentalities of interstate commerce to accept and solicit funds from nonFlorida sources; by using electronic devices to authorize credit card transactions.

Upon information and belief, the annual gross revenue of the Employer/Defendant 

was always material hereto more than $500,000 per annum. By reason of the 

foregoing, Defendant’s business activities involved those to which the Fair Labor 

Standards Act applies. Therefore, there is FLSA enterprise coverage.

27. Plaintiff and those similarly situated were employed by an enterprise engaged in 

interstate commerce. Particularly, the Plaintiff was a driver, and through his daily 

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activities, used the channels of interstate commerce and transported patients 

recipients of Medicare and Medicaid. Therefore, there is individual coverage.

28. Defendants GALENOS MEDICAL CENTER and MARIA C. ELOY employed 

Plaintiff JULIO LEE HERNANDEZ as a non-exempt local driver, approximately 

from November 14, 2018, to April 22, 2020 or 75 weeks. However, for FLSA 

purposes, Plaintiff’s relevant period of employment is 70 weeks, because Plaintiff 

did not work overtime hours since the beginning of the Coronavirus quarantine in 

Dade County.

29. Within his period of employment, Plaintiff was paid at the wage rate of $11.00, 

$12.00, and $12.50 an hour. Plaintiff worked at the medical center located at 8504 

NW 103 ST. Hialeah Gardens, FL 33016. 

30. Plaintiff’s duties consisted of transporting patients from their homes to the medical 

center, taking them to specialists' medical appointments, and then returning patients 

back home. 

31. During his employment with Defendants, Plaintiff had a regular schedule, he 

worked 5 days per week from Monday to Friday, a minimum of 45 hours every 

week. The Plaintiff was unable to take bonafide lunch breaks. 

32. In addition, during the relevant period of employment, Plaintiff worked making 

telephone calls to confirm scheduled patients to be transported the following day, 

an average of 10 additional, uncompensated off-the-clock overtime hours.

33. Consequently, Plaintiff worked a total average of 55 hours, or 15 overtime hours 

weekly. However, he was paid for only 2.5 overtime hours. There is a substantial 

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number of overtime hours that were not paid to Plaintiff at any rate. Not even the 

minimum wage rate.

34. Plaintiff was paid for 40 regular hours, plus 2.5 overtime hours at the correct 

overtime rate. Nevertheless, Plaintiff was not paid for all his overtime hours as 

required by the Fair Labor Standards Act.

35. Plaintiff did not clock in and out, but the Defendants were in complete control of 

Plaintiff’s working hours, and they were able to keep track of the hours worked by 

Plaintiff and other similarly situated individuals. 

36. Therefore, Defendants willfully failed to pay Plaintiff 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). and 29 U.S.C. § 201 et seq.

37. Plaintiff was paid bi-weekly with checks and paystubs that did not show the real 

number of days and hours worked.

38. 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 the Defendants. However, upon information and 

belief, the Defendants did not maintain accurate and complete time records of hours 

worked by Plaintiff and other employees in the asserted class.

39. The Defendants violated the record-keeping requirements of FLSA, 29 CFR Part 

516.

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40. 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.

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

42. 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 based on 

Plaintiff’s last wage-rate of $12.50, after proper discovery, Plaintiff will adjust his 

calculations.

a. Total amount of alleged half-time unpaid O/T wages:

Sixteen Thousand Four Hundred Six Dollars and 60/100 ($16,406.60)

b. Calculation of such wages:

Total weeks of employment: 75 weeks

Relevant weeks of employment: 70 weeks 

 Total number of hours worked: 55 average weekly.

 Total number of overtime hours: 15 hours weekly

 Total number of paid O/T hours: 2.5 O/T hours weekly 

 Total number of unpaid O/T hours: 12.5 hours weekly

 Regular rate: $12.50 an hour x 1.5 =$18.75 O/T rate

 

 O/T rate $18.75 x 12.5 O/T hours=$234.38 wkly x 70 weeks=$16,406.60

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

 This amount represents unpaid overtime wages.

43. 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 provided by the Act but no provision was made by the Defendants

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to properly pay him 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. 

44. 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 and those similarly-situated employee’s 

employment with Defendants as set forth above, and Plaintiff and those similarlysituated are entitled to recover double damages. 

45. At the times mentioned individual Defendant MARIA C. ELOY, was the 

owner/partner/and directed operations of GALENOS MEDICAL CENTER. 

Defendant MARIA C. ELOY was the employer 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)]. This individual Defendant acted directly in the interest of 

GALENOS MEDICAL CENTER in relation to its employees, including Plaintiff 

and others similarly situated. Defendant MARIA C. ELOY had operational and 

financial control of the business, determining terms, and working conditions of 

Plaintiff and other similarly situated employees, and she is jointly and severally 

liable for the Plaintiff’s damages. 

46. Defendants GALENOS MEDICAL CENTER and MARIA C. ELOY willfully and 

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

United States, and remains owing Plaintiff these overtime wages since the 

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

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47. 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 JULIO LEE HERNANDEZ and those similarly situated

respectfully requests that this Honorable Court: 

A. Enter judgment for Plaintiff and other similarly situated and against the 

Defendants GALENOS MEDICAL CENTER and MARIA C. ELOY 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 JULIO LEE HERNANDEZ and those similarly situated demand trial by jury of 

all issues triable as of right by jury.

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COUNT II:

FEDERAL STATUTORY VIOLATION PURSUANT TO 29 U.S.C. 215 (a)(3) 

RETALIATORY DISCHARGE; AGAINST ALL DEFENDANTS

48. Plaintiff JULIO LEE HERNANDEZ re-adopts every factual allegation as stated in 

paragraphs 1-22 of this complaint as if set out in full herein.

49. This Court has jurisdiction pursuant to The Fair Labor Standards Act, 29 U.S.C. §§ 

201-219 (section #216 for jurisdictional placement) as well as the Florida 

Constitution that vests this action within a court of competent jurisdiction.

50. Defendant GALENOS MEDICAL CENTER was and is engaged in interstate 

commerce pursuant to 29 U.S. Code § 203 (r) (2) (C) and 203 (s) (1) (C). Defendant 

provides medical services and receives payments from Medicare and Medicaid. 

Defendant has more than two employees recurrently engaged in commerce or in 

the production of goods for commerce by regularly and recurrently using the 

instrumentalities of interstate commerce to accept and solicit funds from nonFlorida sources; by using electronic devices to authorize credit card transactions.

Upon information and belief, the annual gross revenue of the Employer/Defendant 

was always more than $500,000 per annum. By reason of the foregoing, 

Defendant’s business activities involved those to which the Fair Labor Standards 

Act applies. Therefore, there is FLSA enterprise coverage.

51. Plaintiff and those similarly situated were employed by an enterprise engaged in 

interstate commerce. Particularly, the Plaintiff was a driver, and through his daily 

activities, used the channels of interstate commerce and transported patients 

recipients of Medicare and Medicaid. Therefore, there is individual coverage.

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52. By reason of the foregoing, Defendants’ business activities involve those to which 

the Fair Labor Standards Act applies.

53. 29 U.S.C. § 207 (a) (1) states, "if an employer employs an employee for more than 

forty hours in any workweek, the employer must compensate the employee for 

hours in excess of forty at the rate of at least one and one-half times the employee's 

regular rate...."

54. Likewise, 29 U.S.C. 215(a)(3) states... it shall be unlawful for any person— “to 

discharge or in any other manner discriminate against any employee because such 

employee has filed any complaint or instituted or caused to be instituted any 

proceeding under or related to this chapter, or has testified or is about to testify in 

any such proceeding,......”

55. Defendants GALENOS MEDICAL CENTER and MARIA C. ELOY employed 

Plaintiff JULIO LEE HERNANDEZ as a non-exempt local driver, approximately 

from November 14, 2018, to April 22, 2020 or 75 weeks. However, for FLSA 

purposes, Plaintiff’s relevant period of employment is 70 weeks, because Plaintiff 

did not work overtime hours since the beginning of the Coronavirus quarantine in 

Dade County.

56. Within his period of employment, Plaintiff was paid at the wage rate of $11.00, 

$12.00, and $12.50 an hour. Plaintiff worked at the medical center located at 8504 

NW 103 ST. Hialeah Gardens, FL 33016. 

57. Plaintiff’s duties consisted of transporting patients from their homes to the medical 

center, taking them to specialists' medical appointments, and then returning patients 

back home. 

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58. During his employment with Defendants, Plaintiff had a regular schedule, he 

worked 5 days per week from Monday to Friday, a minimum of 45 hours every 

week. The Plaintiff was unable to take bonafide lunch breaks. 

59. In addition, during the relevant period of employment, Plaintiff worked making 

telephone calls to confirm scheduled patients to be transported the following day, 

an average of 10 additional, uncompensated off-the-clock overtime hours.

60. Consequently, Plaintiff worked a total average of 55 hours, or 15 overtime hours 

weekly. However, he was paid for only 2.5 overtime hours. There is a substantial 

number of overtime hours that were not paid to Plaintiff at any rate. Not even the 

minimum wage rate.

61. Plaintiff was paid for 40 regular hours, plus 2.5 overtime hours at the correct 

overtime rate. Nevertheless, Plaintiff was not paid for all his overtime hours as 

required by the Fair Labor Standards Act.

62. Plaintiff did not clock in and out, but the Defendants were in complete control of 

Plaintiff’s working hours, and they were able to keep track of the hours worked by 

Plaintiff and other similarly situated individuals. 

63. Therefore, Defendants willfully failed to pay Plaintiff 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). and 29 U.S.C. § 201 et seq.

64. Plaintiff was not in agreement with the number of hours paid and with the lack of 

pay for overtime hours, and he complained to his supervisor Arsenio LNU 

beginning December 2019.

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65. Plaintiff complained about his wages and overtime with his supervisor Arsenio 

LNU multiple times.

66. These complaints constituted protected activity under the Fair Labor Standards Act.

67. On or about the first week of February 2020, Plaintiff complained about the last 

time. Plaintiff complained about getting paid for his working hours less than newly 

hired employees. Plaintiff complained also about his unpaid hours. 

68. On or about April 22, 2020, the Plaintiff was fired using pretextual reasons.

69. At all times during his employment with Defendants, Plaintiff performed his duties 

satisfactorily. There was no reason other than a retaliatory action to terminate 

Plaintiff’s employment with Defendants.

70. There is proximity between Plaintiff’s protected activity and his termination.

71. The Defendants’ termination of the Plaintiff was in direct violation of 29 U.S.C. 

215 (a) (3) and, as a direct result, the Plaintiff has been damaged.

72. At the times mentioned individual Defendant MARIA C. ELOY, was the 

owner/partner/and directed operations of GALENOS MEDICAL CENTER. 

Defendant MARIA C. ELOY was the employer 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)]. This individual Defendant acted directly in the interest of 

GALENOS MEDICAL CENTER in relation to its employees, including Plaintiff 

and others similarly situated. Defendant MARIA C. ELOY had operational and 

financial control of the business, determining terms, and working conditions of 

Plaintiff and other similarly situated employees, and she is jointly and severally 

liable for the Plaintiff’s damages. 

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73. Plaintiff JULIO LEE HERNANDEZ seeks to recover overtime wages for every 

hour more than 40 that he worked, liquidated damages, retaliatory damages, and 

any other relief as allowable by law. 

74. 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 JULIO LEE HERNANDEZ respectfully requests that this 

Honorable Court:

A. Issue a declaratory judgment that Defendants’ acts, policies, practices, and 

procedures complained of herein violated provisions of the Fair Labor Standards 

Act; 

B. Enter judgment against the Defendants GALENOS MEDICAL CENTER and 

MARIA C. ELOY that Plaintiff recovers compensatory, damages, and an equal 

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

216(b); 

C. That Plaintiff recovers an award of reasonable attorney fees, costs, and expenses. 

D. Order the Defendants GALENOS MEDICAL CENTER and MARIA C. ELOY

to make whole the Plaintiff by providing appropriate back pay and other benefits 

wrongly denied in an amount to be shown at trial and other affirmative relief; 

E. Plaintiff JULIO LEE HERNANDEZ further prays for such additional relief as the 

interests of justice may require.

JURY DEMAND

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Plaintiff JULIO LEE HERNANDEZ demands trial by a jury of all issues triable as of right 

by a jury.

Dated: May 25, 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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