UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

CASE NO:

RICARDO RAMOS,

Plaintiff,

v.

KALI-AUTO DETAIL, L.L.C.,

a Florida limited liability company,

and LINO MORENO, individually,

Defendant.

/

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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

following Complaint for Damages and Demand for Jury Trial against Defendants, KALI-AUTO 

DETAIL, L.L.C. (“KALI”), and LINO MORENO (“MORENO”) (collectively “Defendants”), and 

alleges as follows:

INTRODUCTION

1. Defendants unlawfully deprived Plaintiff of full payment of federal overtime wages during 

the course of his employment. This action arises under the Fair Labor Standards Act 

(“FLSA”) pursuant to 29 U.S.C. §§ 201–216, to recover all federal wages that Defendants

refused to pay Plaintiff during his employment.

PARTIES

2. During all times material hereto, Plaintiff was a resident of Palm Beach County, Florida, 

over the age of 18 years, and otherwise sui juris. 

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3. During all times material hereto, Defendant, KALI, was a Florida limited liability company

located and transacting business within Boynton Beach, Florida, within the jurisdiction of 

this Honorable Court.

4. During all times material hereto, Defendant, KALI, was vested with the ultimate control 

and decision-making authority over the hiring, firing, day-to-day operations, and pay 

practices, particularly as they relate to Plaintiff, during the relevant time period.

5. Defendant, KALI, was Plaintiff’s employer, as defined by 29 U.S.C. § 203(d), during all 

times pertinent to the allegations herein. 

6. Defendant, MORENO, was a resident of the Southern District of Florida during the 

relevant time period. 

7. During all times material hereto, Defendant, MORENO, was vested with the ultimate 

control and decision-making authority over the hiring, firing, day-to-day operations, and 

pay practices, for KALI, particularly as they relate to Plaintiff.

8. Defendant, MORENO, was Plaintiff’s employer, as defined by 29 U.S.C. 203(d), during 

all times pertinent to the allegations herein.

JURISDICTION AND VENUE

9. All acts and omissions giving rise to this dispute took place within Palm Beach County, 

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

10. Defendant, KALI, is headquartered and regularly transacts business in Palm Beach 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. 

11. 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). 

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GENERAL ALLEGATIONS

12. Defendant, KALI, has operated in Florida since at least 2011.

13. KALI provides car detailing services throughout the Palm Beach County area and utilizes 

opportunities at local car dealerships to service automobiles within the surrounding area. 

FLSA COVERAGE

14. Defendant, KALI, is covered under the FLSA through enterprise coverage, as KALI was 

engaged in interstate commerce during Plaintiff’s employment period. More specifically, 

KALI’s business and Plaintiff’s work for KALI affected interstate commerce because the 

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

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

use of the same. Accordingly, Defendant, KALI, was engaged in interstate commerce 

pursuant to 29 U.S.C. § 203(s)(1)(B). 

15. During his employment with Defendants, Plaintiff and multiple other employees handled 

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

including, but not limited to: screwdrivers, cloths, cleaning detergent, windex, water hoses, 

pencils, pens, car keys, etc. 

16. Defendant, KALI, regularly employed two (2) or more employees for the relevant time 

period, and these employees handled goods or materials similar to those goods and 

materials handled by Plaintiff, thus making Defendant, KALI an enterprise covered by the 

FLSA. 

17. Upon information and belief, Defendant, KALI, grossed or did business in excess of 

$500,000.00 in 2017, 2018, 2019, and is expected to gross in excess of $500,000.00 in 

2020.

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18. During all material times hereto, Plaintiff was a non-exempt employee of Defendants,

KALI, and MORENO, within the meaning of the FLSA. 

PLAINTIFF’S WORK FOR DEFENDANTS

19. Plaintiff had two (2) periods of employment with Defendants during the relevant time 

period.

20. Plaintiff first began working for Defendants in July 2017 and continued to do so until the 

end of December 2018.

21. Plaintiff’s second period of employment lasted from on or about June 1, 2020 through June 

21, 2020. 

22. During all times periods pertinent to this Complaint and pertinent to both employment 

periods, Plaintiff performed non-exempt work for Defendants as a car detailer throughout 

Palm Beach County and the surrounding area. 

23. During all times material hereto, Plaintiff was a non-exempt hourly employee employed 

by Defendants. 

24. During his relevant employment periods, Plaintiff was supervised by Defendant, 

MORENO, and was subject to MORENO’s control and direction. 

25. During the relevant employment periods, Defendant, MORENO, maintained control and 

direction over KALI’s pay policies and practices particularly as they relate to Plaintiff. 

26. Plaintiff worked in excess of forty (40) hours per week when he was employed by 

Defendants during both of the respective employment periods. 

27. On average, Plaintiff worked an average of forty-two (42) hours per week.

28. During the relevant employment periods, Plaintiff’s regularly hourly rate was $10.00 per 

hour and $10.50 per hour, respectively.

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29. On occasion, Defendants would compensate Plaintiff overtime wages when Plaintiff 

worked in excess of forty (40) hours per week.

30. However, during several workweeks, Defendants failed to pay Plaintiff 1.5 times his 

regular hourly rate free and clear of any unlawful deductions for hours worked in excess 

of forty (40) per week in a workweek.

31. On information and belief, there are several workweeks in which Defendants unlawfully 

deducted wages from Plaintiff in weeks in which Plaintiff worked in excess of 40 hours, 

thus depriving Plaintiff of the full overtime wages he was entitled to receive under federal 

law.1 

32. Plaintiff is therefore entitled to recover federal overtime wages arising from violations 

committed by Defendants during the course of Plaintiff’s employment.

33. Plaintiff objected to the withholding of his hard-earned wages. 

34. Plaintiff brings these claims arising under the Fair Labor Standards Act and is therefore 

entitled to recover his reasonable attorney’s fees and costs incurred as a result of 

Defendant’s unlawful conduct. 

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

35. Plaintiff hereby re-alleges and re-avers Paragraphs 1 through 34 as though set forth fully 

herein.

1 For example, on information and belief, during the 2-week pay period of June 11, 2018, through 

June 24, 2018, Plaintiff worked 10.37 hours of overtime. Defendants unlawfully deducted at least 

$20.00 from Plaintiff’s wages this pay period. Because this deduction drove Plaintiff’s 

compensation below the required overtime rates, Defendants are in violation of the FLSA. 

Furthermore, from June 8, 2020, through June 21, 2020, Plaintiff worked 2.8 hours of overtime. 

Defendants unlawfully deducted $80.00 from Plaintiff’s wages this pay period. Because this 

$80.00 deduction drove Plaintiff’s compensation below the required overtime rates, Defendants 

are in violation of the FLSA. 

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

§ 216(b).

37. Plaintiff claims the federal overtime wages free and clear of any unlawful deductions for 

all of the hours that he worked in excess of forty (40) per week during both of his 

employment periods with Defendants. 

38. Defendants willfully and intentionally refused to pay Plaintiff the applicable federal 

overtime wages free and clear of any unlawful deductions as required by the FLSA, as 

Defendants knew of the federal overtime wage requirements of the FLSA yet refused to 

pay Plaintiff same. 

39. Defendants intentionally pilfered these wages that were due and owing to Plaintiff. 

40. Defendants recklessly failed to investigate whether their payroll practices were in 

accordance with the FLSA during the relevant time period.

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

to two (2) years. 

42. Defendant’s willful and/or intentional violations of federal wage law entitles Plaintiff to an 

additional amount of liquidated, or double, damages.

43. 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, RICARDO RAMOS, respectfully requests that this Honorable 

Court enter judgment in his favor and against Defendants, KALI-AUTO DETAIL, L.L.C., and 

LINO MORENO, and award Plaintiff: (a) unliquidated damages to be paid by the Defendants 

jointly and severally; (b) liquidated damages to be paid by the Defendants jointly and severally; 

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(c) reasonable attorney’s fees and costs to be paid by the Defendants jointly and severally; and any 

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

DEMAND FOR JURY TRIAL

Plaintiff, RICARDO RAMOS, requests and demands a trial by jury on all appropriate claims. 

Dated this 12th day of July, 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

By: /s/ Jordan Richards

JORDAN RICHARDS, ESQUIRE

Florida Bar No. 108372

Jordan@jordanrichardspllc.com

Melissa@jordanrichardspllc.com

Jake@jordanrichardspllc.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that the foregoing document was filed via CM/ECF on July 12, 

2020. 

By: /s/ Jordan Richards

JORDAN RICHARDS, ESQUIRE

Florida Bar No. 108372

SERVICE LIST:

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