UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No.: ___________________________

MARILYN CASELLAS,

Plaintiff,

v.

LAWSON INDUSTRIES, INC, a Florida

Corporation, RONALD BAILEY, Individually, 

and HOWARD BAILEY, Individually,

Defendants.

_____________________________/ 

COMPLAINT AND DEMAND FOR JURY TRIAL

COMES NOW, Plaintiff, MARILYN CASELLAS, by and through undersigned counsel, 

and sues Defendants, LAWSON INDUSTRIES, INC., RONALD BAILEY, and HOWARD 

BAILEY, and alleges as follows: 

GENERAL ALLEGATIONS

1. Plaintiff, MARILYN CASELLAS, brings this action against Defendants to recover 

unpaid overtime wages owed by Defendants to Plaintiff pursuant to Plaintiff’s employment 

agreement with the Defendants. 

2. Jurisdiction is conferred on this Court by the Fair Labor Standards Act of 1938 

(“FLSA”), 29 U.S.C. § 206 and 207.

3. Venue is proper in the Southern District of Florida, pursuant to 28 U.S.C. §§

1391(b) and (c), because Plaintiff was employed by Defendants in this District; because 

Defendants, at all material times, conducted and continue to conduct business in the Southern 

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District of Florida; because the unlawful employment practices that give rise to Plaintiff’s claims 

happened within the Southern District of Florida; and because Defendants are subject to personal 

jurisdiction herein.

4. At all times material hereto, Plaintiff has been a citizen and resident of Broward 

County, Florida.

5. At all times material hereto, Defendant, LAWSON INDUSTRIES, INC.

(“Lawson”), was Plaintiff’s employer as defined by law and a corporation conducting business in 

this judicial district.

6. At all times material hereto, Lawson had employees engaged in commerce or in the 

production of goods for commerce, and/or had employees handling, selling, or otherwise working 

on goods or materials that were moved in or produced for commerce by a person. 29 U.S.C. §203.

7. At all times material hereto, Lawson, upon information and belief, had revenue in 

excess of $500,000.00 per annum.

8. Defendant, RONALD BAILEY (“RB”) is an officer and owner of Defendant 

Lawson, and RB commonly controlled the day-to-day operations of Lawson and shared an interest 

in making profits through the operation of this corporate entity. 

9. At all times material hereto, RB was Plaintiff’s employer as defined by law. 

10. Defendant, HAROLD BAILEY (“HB”) is an officer and owner of Defendant 

Lawson, and HB commonly controlled the day-to-day operations of Lawson and shared an interest 

in making profits through the operation of this corporate entity. 

11. At all times material hereto, HB was Plaintiff’s employer as defined by law.

12. At all times material hereto, Plaintiff was individually engaged in commerce while 

working for Defendants. 

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13. All conditions precedent have occurred or have been waived.

14. Plaintiff has engaged the undersigned attorney and is entitled to recover her 

attorneys’ fees from Defendants. 

COUNT 1: FLSA RECOVERY OF UNPAID OVERTIME WAGES

15. Plaintiff incorporates by reference the allegations contained in paragraphs 1 

through 14 above as if fully set forth herein. Plaintiff worked for Defendants from approximately

August 8, 2016 to November 2, 2018. The Plaintiff was originally hired through an agency and 

was hired directly by the Defendants in January 2017.

16. During the relevant time period, Plaintiff worked for Defendants in the accounts 

payable department. 

17. In accounts payable, Plaintiff’s primary duties and responsibilities included 

answering emails and phone calls, taking care of all payables, working directly with the controller, 

working with purchasing and receiving, working with high volume invoices, and processing and 

meeting daily deadlines. 

18. In January 2017, the Defendants agreed to pay the Plaintiff $19.00 per hour in 

exchange for her services. In April 2018, the Defendants increased the Plaintiff’s hourly rate to 

$20.00 per hour. 

19. The Plaintiff worked 45 hours per week from January 1, 2017 through April 1, 

2018. The Plaintiff also worked 45 hours per week from April 1, 2018 through November 2, 2018.1

20. During one or more work week, Defendants did not pay Plaintiff overtime wages

for all hours worked by Plaintiff, in violation of the FLSA, 29 U.S.C. § 206 and 207.

1 The parties entered into an agreement tolling the applicable statute of limitations.

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21. Plaintiff was unlawfully denied overtime wages in violation of the FLSA, 29 U.S.C. 

§ 206 and 207.

22. By reason of the intentional, willful and unlawful acts of the Defendants, Plaintiff 

has suffered damages.

23. Plaintiff is owed an additional amount equal to the amount of unpaid overtime 

wages as liquidated damages.

WHEREFORE, Plaintiff hereby demands judgment against Defendants for all unpaid 

overtime wages, liquidated damages, attorneys’ fees, costs, and such other and further relief as this 

Court deems just and appropriate.

Jury Trial Demand

Plaintiff demands a trial by jury on all issues so triable.

 Respectfully submitted this 24th day of July, 2020.

 By: s/Michelle Cohen Levy

 Michelle Cohen Levy, FBN 0068514

 The Law Office of Michelle Cohen Levy, P.A.

 4400 N. Federal Highway

 Lighthouse Point, Florida 33064

 P: (954) 651-9196

 Michelle@CohenLevyLegal.com

 Counsel for Plaintiff

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