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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.

JACQUES CHARLES-PIERRE, on his own

behalf and on behalf of others similarly situated, 

Plaintiff, 

v. 

MILLENNIUM STEEL, INC., a Florida

corporation, and RICARDO WRIGHT, 

individually,

Defendants.

_____________________________________/

COMPLAINT

1. Plaintiff, JACQUES CHARLES-PIERRE, was employed by Defendants, 

MILLENNIUM STEEL, INC., a Florida corporation, and RICARDO WRIGHT, individually

(hereinafter “Defendants”), and brings this action on behalf of himself and other current and 

former employees of defendant similarly situated to him for overtime compensation and other 

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

Plaintiff performed work and related duties as an Iron Worker for Defendants in Broward 

County, Florida.

2. Defendant, MILLENNIUM STEEL, INC., is a corporation that owns and operates 

a business in Hollywood, Broward County, Florida, and is within the jurisdiction of this Court. 

3. Defendant, RICARDO WRIGHT, owns and/or operates MILLENNIUM STEEL, 

INC., and regularly exercises the authority to hire and fire employees, determine the work 

schedules of employees, set the rates of pay of employees, and control the finances and 

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operations of MILLENNIUM STEEL, INC. By virtue of such control and authority, RICARDO 

WRIGHT, is an employer as such term is defined by the FLSA, 29 U.S.C. 201 et seq.

4. Jurisdiction is conferred on this Court by 28 U.S.C. §1337 and by 29 U.S.C. 

§216(b). 

5. At all times pertinent to this Complaint, Defendant, MILLENNIUM STEEL, 

INC., was an enterprise engaged in interstate commerce or in the production of goods for 

commerce as defined in §§3(r) and 3(s) of the Act, 29 U.S.C. §§203(r) and 203(s). 

6. The annual gross sales volume of Defendant, MILLENNIUM STEEL, INC., was 

in excess of $500,000.00 per annum.

7. During Plaintiff’s employment with Defendants, he worked as an Iron Worker. 

8. In the course of employment with Defendants, Plaintiff and the other similarly 

situated employees were not paid time and one-half of their regular rate of pay for all hours 

worked in excess of forty (40) hours per work week during one or more work weeks.

9. Specifically, Plaintiff and other similarly situated employees regularly worked 

over 40 hours a week (overtime). However, instead paying them at time and a half their regular 

rates of pay for overtime, Defendants paid Plaintiff and similarly situated employees at their 

regular rates of pay (or “straight time”) for the overtime hours they worked. 

10. Further, Defendant required Plaintiff to travel to remote work sites in locations 

such as a Homestead and Port St. Lucie, Florida. Plaintiff was required to transport other 

employees to those locations. Despite having to travel as much as 2 hours each way to these 

locations, Defendants did not pay Plaintiff until he was at the work site. 

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11. The records, if any, concerning the number of hours actually worked by Plaintiff 

and all other similarly situated employees and the compensation actually paid to such employees 

are in the possession and custody of Defendants.

12. Plaintiff has retained the undersigned counsel to represent him in this action, and 

pursuant to 29 U.S.C. '216(b), Plaintiff is entitled to recover all reasonable attorney’s fees and 

costs incurred in this action.

COUNT I

RECOVERY OF OVERTIME COMPENSATION

13. Plaintiff adopts and realleges all allegations contained in Paragraphs 1 through 12

above.

14. In one or more work weeks, Plaintiff and those similarly situated to him worked 

overtime hours. However, Plaintiff and those similarly situated to him were not fully 

compensated for those overtime hours.

15. Plaintiff and similarly situated employees are entitled to time and one-half of their 

regular rates of pay for each hour worked in excess of forty (40) hours per work week. 

16. The additional persons who may become plaintiffs in this action are Defendants'

current and former hourly employees, including, but not limited to, Iron Workers, who worked in 

excess of forty (40) hours during one or more work weeks during or after June 25, 2017, but 

were not paid time and a half of their regular rate for all of their overtime hours worked because 

of Defendants’ practice of paying them straight time for overtime.

17. At all times pertinent to this Complaint, Defendants failed to comply with Title 29 

U.S.C. §201-209 in that the Plaintiffs and those similarly situated to him performed services for

Defendants, for which Defendants failed to properly pay for all hours worked in excess of forty 

(40) within a work week.

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18. By reason of the said intentional, willful and unlawful acts of Defendants,

Plaintiff and those similarly situated to him have suffered damages, plus incurred costs and 

reasonable attorney’s fees.

19. As a result of Defendants’ willful violation of the Act, the Plaintiff and those 

similarly situated to him are entitled to liquidated damages.

WHEREFORE, Plaintiff, JACQUES CHARLES-PIERRE, and those similarly situated to 

him who have or will opt into this action, demand judgment against Defendants, MILLENNIUM 

STEEL, INC. and RICARDO WRIGHT, jointly and severally, for the payment of all overtime 

hours at one and one-half times their regular rate of pay, liquidated damages and reasonable 

attorney’s fees and costs of suit, and such further relief that this Court deems just and 

appropriate.

Jury Trial Demand

Plaintiff demands a jury trial.

Dated: June 25, 2020

Boca Raton, Florida Respectfully Submitted, 

____________________________________

Gregg I. Shavitz 

Florida Bar No. 011398

E-mail: gshavitz@shavitzlaw.com 

Camar R. Jones

Florida Bar No. 720291

E-mail: cjones@shavitzlaw.com

SHAVITZ LAW GROUP, P.A.

951 Yamato Road, Suite 285

Boca Raton, Florida 33431

Telephone: 561-447-8888

Facsimile: 561-447-8831

Attorneys for Plaintiffs

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