UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

CASE NO:

TIMBREL NEWTON, and

VANESSA HITE,

Plaintiffs,

v.

GLOBAL ENTERPRISE SOUTH

FLORIDA, INC., a Florida corporation

and TIVADAR BODORLO, individually,

Defendants.

/

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

Plaintiffs, TIMBREL NEWTON (“Ms. Newton”) and VANESSA HITE, (“Ms. Hite”), 

(collectively, “Plaintiffs”), pursuant to 29 U.S.C. § 216(b), file the following Complaint for 

Damages and Demand for Jury Trial against Defendants, GLOBAL ENTERPRISE SOUTH 

FLORIDA, INC. (“GLOBAL ENTERPRISE”) and TIVADAR BODORLO (“TB”), individually

(collectively referred to hereinafter as “Defendants”), and allege as follows:

INTRODUCTION

1. Defendants have unlawfully deprived Plaintiffs of federal overtime compensation during 

the course of their employment. This is an action arising under the Fair Labor Standards 

Act (“FLSA”) pursuant to 29 U.S.C. §§ 201-216, to recover all wages owed to Plaintiffs 

during the course of their employment with Defendants. 

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PARTIES

2. During all times material hereto, Plaintiffs were residents of Broward County, Florida, over 

the age of 18 years, and otherwise sui juris. 

3. During all times material hereto, Defendant, GLOBAL ENTERPRISE, was a Florida for 

profit corporation located and transacting business within Pompano Beach, Florida, within 

the jurisdiction of this Honorable Court.

4. GLOBAL ENTERPRISE is headquartered and operates its principal location at 1043 NW 

31st Ave, Pompano Beach, Florida 33069. 

5. Defendant, GLOBAL ENTERPRISE, was Plaintiffs’ employer, as defined by 29 U.S.C. § 

203(d), during all times pertinent to the allegations herein. 

6. Upon information and belief, during all times material hereto, Defendant, TB, was a 

resident of the Southern District of Florida.

7. During all times material hereto, Defendant, TB was the president and owner of the 

corporate defendant within Pompano Beach, Florida. 

8. During all times material hereto, Defendant, TB, was over the age of 18 years, an officer 

and/or director of the corporate Defendant, and was vested with the ultimate control and 

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

for Defendant, GLOBAL ENTERPRISE, during the relevant time period.

9. During all times material hereto, Defendant, TB, was Plaintiff’s employer, as defined by 

29 U.S.C. § 203(d). 

JURISDICTION AND VENUE

10. All acts and omissions giving rise to this dispute took place within Broward County, 

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

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11. Defendant, GLOBAL ENTERPRISE, is headquartered and regularly transacts business in 

Broward 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. 

12. 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). 

GENERAL ALLEGATIONS

13. Defendant, GLOBAL ENTERPRISE, has been in operation in Florida since at least 2008.

14. GLOBAL ENTERPRISE provides disaster restoration services throughout the State of 

Florida. 

15. On its website, GLOBAL ENTERPRISE advertises that it operates locations in South 

Carolina, North Carolina, Virginia, Texas, California, Colorado, Arizona, New York, 

Connecticut, Massachusetts, Ohio, Chicago and Tennessee. See 

https://www.gedrusa.com/our-locations/ (last visited June 17, 2020).

FLSA COVERAGE

16. Defendant, GLOBAL ENTERPRISE, is covered under the FLSA through enterprise 

coverage, as GLOBAL ENTERPRISE was engaged in interstate commerce during 

Plaintiff’s employment period. More specifically, GLOBAL ENTERPRISE’s business 

and Plaintiff’s work for GLOBAL ENTERPRISE affected interstate commerce because 

the goods and materials Plaintiffs 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, GLOBAL ENTERPRISE, was 

engaged in interstate commerce pursuant to 29 U.S.C. § 203(s)(1)(B). 

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17. During their employment with Defendants, Plaintiffs and multiple other employees 

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

commerce, including, but not limited to: cell phones, computers, computer keyboards, 

telephones, headsets, pens, pencils, paper, staples, markers, folders, mailing equipment, 

envelopes, staplers, tape, post-it and sticky notes, labels, etc. 

18. Defendant, GLOBAL ENTERPRISE, 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, GLOBAL 

ENTERPRISE an enterprise covered by the FLSA. 

19. Upon information and belief, Defendant, GLOBAL ENTERPRISE, grossed or did 

business in excess of $500,000.00 during the years of 2017, 2018, 2019 and is expected to 

gross in excess of $500,000.00 in 2020.

20. During all material times hereto, Plaintiffs were non-exempt employees of Defendants, 

GLOBAL ENTERPRISE and TB, within the meaning of the FLSA. 

PLAINTIFF’S WORK FOR DEFENDANTS

21. Plaintiff, Ms. Newton began working for Defendants on February 7, 2020 and continues to 

be employed as of the date of filing this Complaint.

22. Plaintiff, Ms. Hite, began working for Defendants on April 27, 2020, and continues to be 

employed as of the date of filing this Complaint. 

23. During all times periods pertinent to this Complaint, Plaintiffs performed non-exempt work 

for Defendants as administrative assistants. 

24. During all times material hereto, Plaintiff, Ms. Newton, was treated as a non-exempt hourly 

employee and compensated at the rate of $17.00 per hour. 

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25. During all times material hereto, Plaintiff, Ms. Hite, was treated as a non-exempt hourly 

employee at compensated at the rate of about $12.85 per hour. 

INDIVIDUAL EMPLOYER LIABILITY

26. During all pertinent times to Plaintiffs’ employment, Defendant, TB, oversaw the day-today operations of GLOBAL ENTERPRISE and instructed Plaintiffs and other employees 

on their duties and responsibilities. Defendant, TB, also controlled the payroll practices 

and policies of the company.

27. Defendant, TB, maintained hiring and firing authority over company employees including 

Plaintiffs. TB also retained control and decision-making over promotions for employees. 

28. During all times material hereto, Defendants were expressly aware of the work performed 

by Plaintiffs, but nevertheless refused to pay Plaintiffs for any of the work they performed 

for Defendants. 

MS. NEWTON’S PRELIMINARY STATEMENT OF CLAIM

29. Plaintiff, Ms. Newton, worked for Defendants as a non-exempt employee for eighteen (18)

weeks between February 7, 2020, and the present.

30. During this time period, Plaintiff, Ms. Newton, worked at least nine (9) hours per day.

31. Thus, Plaintiff, Ms. Newton worked for Defendants for an average of at least forty-five 

(45) hours per week. 

32. Plaintiff, Ms. Newton, seeks unpaid overtime wages in the amount of $25.50 for at least

ninety (90) overtime hours she worked for Defendants without receiving any overtime 

compensation whatsoever. 

33. Therefore, Plaintiff, Ms. Newton, claims $25.50 per hour x 90 hours = $2,295.00 in 

unliquidated damages. 

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34. Because of Defendants’ willful and/or intentional violations of federal wage law, Plaintiff, 

Ms. Newton, seeks an additional amount of liquidated damages, in the amount of $2,295.00

for a total of $4,590.00, plus reasonable attorneys’ fees and costs. 

MS. HITE’S PRELIMINARY STATEMENT OF CLAIM

35. Plaintiff, Ms. Hite, worked for Defendants as a non-exempt employee for seven (7) weeks 

between April 27, 2020, and the present.

36. During this time period, Plaintiff, Ms. Hite, worked at least nine (9) hours per day.

37. Thus, Plaintiff, Ms. Hite worked for Defendants for an average of forty-five (45) hours per 

week. 

38. Plaintiff, Ms. Hite, seeks unpaid overtime wages in the amount of $19.27 for at least fortyfive (45) overtime hours she worked for Defendants without receiving any compensation 

whatsoever. 

39. Therefore, Plaintiff, Ms. Hite, claims $19.27 per hour x 45 hours = $867.15 in unliquidated 

damages. 

40. Because of Defendants’ willful and/or intentional violations of federal wage law, Plaintiff, 

Ms. Hite, seeks an additional amount of liquidated damages, in the amount of $867.15 for 

a total of $1,734.30, plus reasonable attorneys’ fees and costs. 

41. Plaintiffs have retained the undersigned counsel to seek recovery of wages owed and 

entitled to recover reasonable attorney’s fees and costs. 

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

(Ms. Newton Against All Defendants)

42. Plaintiffs hereby re-allege and re-aver Paragraphs 1 through 41 as though set forth fully 

herein.

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43. Plaintiff, Ms. Newton alleges this action pursuant to the Fair Labor Standards Act 

(“FLSA”), 29 U.S.C. § 216(b).

44. Plaintiff, Ms. Newton claims federal overtime wages for all of the hours that she worked 

in excess of forty (40) per week between February 7, 2020, and the present, and April 27, 

and the present, respectively.

45. Defendants willfully and intentionally refused to pay Plaintiff, Ms. Newton, the applicable 

federal overtime wages as required by the FLSA, as Defendants knew or should have 

known of the overtime wage requirements of the FLSA. 

46. Defendants recklessly failed to investigate whether Defendants’ payroll practices were in 

accordance with the FLSA during the relevant time period.

47. On information and belief, Defendants failed to keep accurate time and payroll records 

during the relevant time period. 

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

to two (2) years. 

49. Defendants’ willful and/or intentional violations of federal wage law entitle Plaintiffs to an 

additional amount of liquidated, or double, damages.

50. As a result of the violations alleged herein, Plaintiff, Ms. Newton, was required to retain 

the undersigned counsel and are therefore entitled to recover reasonable attorney’s fees and 

costs. 

WHEREFORE, Plaintiff, TIMBREL NEWTON, respectfully requests that this Honorable 

Court enter judgment in her favor and against Defendants, GLOBAL ENTERPRISE SOUTH 

FLORIDA, INC., and TIVADAR BODORLO, and award Plaintiffs: (a) unliquidated damages to 

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

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Defendants jointly and severally; (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.

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

(Ms. Hite Against All Defendants)

51. Plaintiff, Ms. Hite, hereby re-alleges and re-avers Paragraphs 1 through 41 as though set 

forth fully herein.

52. Plaintiff, Ms. Hite alleges this action pursuant to the Fair Labor Standards Act (“FLSA”), 

29 U.S.C. § 216(b).

53. Plaintiff, Ms. Hite, claims federal overtime wages for all of the hours that she worked in 

excess of forty (40) per week between February 7, 2020, and the present, and April 27, and 

the present, respectively.

54. Defendants willfully and intentionally refused to pay Plaintiffs the applicable federal 

overtime wages as required by the FLSA, as Defendants knew or should have known of 

the overtime wage requirements of the FLSA.

55. Defendants recklessly failed to investigate whether Defendants’ payroll practices were in 

accordance with the FLSA during the relevant time period.

56. On information and belief, Defendants failed to keep accurate time and payroll records 

during the relevant time period. 

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

to two (2) years. 

58. Defendants’ willful and/or intentional violations of federal wage law entitle Plaintiffs to an 

additional amount of liquidated, or double, damages.

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59. As a result of the violations alleged herein, Plaintiffs were required to retain the 

undersigned counsel and are therefore entitled to recover reasonable attorney’s fees and 

costs. 

WHEREFORE, Plaintiff, VANESSA HITE, respectfully requests that this Honorable 

Court enter judgment in her favor and against Defendants, GLOBAL ENTERPRISE SOUTH 

FLORIDA, INC., and TIVADAR BODORLO, and award Plaintiffs: (a) unliquidated damages to 

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

Defendants jointly and severally; (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

Plaintiffs, TIMBREL NEWTON and VANESSA HITE, hereby request and demand a trial 

by jury on all appropriate claims. 

Dated this 17th day of June 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

MELISSA SCOTT, ESQUIRE

Florida Bar No. 1010123

JAKE BLUMSTEIN, ESQUIRE

Florida Bar No. 1017746

Jordan@jordanrichardspllc.com

Melissa@jordanrichardspllc.com

Jake@jordanrichardspllc.com

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that the foregoing document was filed via CM/ECF on this 17th

day of June, 2020. 

By: /s/ Jordan Richards

JORDAN RICHARDS, ESQUIRE

Florida Bar No. 108372

SERVICE LIST:

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