EXHIBIT A 

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FORM 1.997. CIVIL COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of

pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the

Clerk of Court for the purpose of reporting data pursuant to section 25.075, Florida Statutes. (See instructions

for completion.)

I. CASE STYLE

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Case No.: _________________

Judge: ____________________

XIOMARA DEL CARMEN RIOS CHAVARRIA

Plaintiff

 vs.

YAMBO, INC., ARMANDO PEREZ Sr

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount of the claim rounded to the nearest dollar $18,866

III. TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the

most descriptive label is a subcategory (is indented under a broader category), place an x on both the main

category and subcategory lines.

☐ Condominium

☐ Contracts and indebtedness

☐ Eminent domain

☐ Auto negligence

☐ Negligence – other

 ☐ Business governance

 ☐ Business torts

 ☐ Environmental/Toxic tort

 ☐ Third party indemnification

 ☐ Construction defect

 ☐ Mass tort

 ☐ Negligent security

 ☐ Nursing home negligence

 ☐ Premises liability – commercial

 ☐ Premises liability – residential

☐ Products liability

☐ Real Property/Mortgage foreclosure

 ☐ Commercial foreclosure

 ☐ Homestead residential foreclosure

 ☐ Non-homestead residential foreclosure

 ☐ Other real property actions

 ☐ Professional malpractice

 ☐ Malpractice – business

 ☐ Malpractice – medical

 ☐ Malpractice – other professional

 ☐ Other

 ☐ Antitrust/Trade Regulation

 ☐ Business Transaction

 ☐ Circuit Civil - Not Applicable

 ☐ Constitutional challenge-statute or ordinance

 ☐ Constitutional challenge-proposed amendment

 ☐ Corporate Trusts

 ☐ Discrimination-employment or other

 ☐ Insurance claims

 ☐ Intellectual property

 ☐ Libel/Slander

 ☐ Shareholder derivative action

 ☐ Securities litigation

 ☐ Trade secrets

 ☐ Trust litigation

 ☒ County Civil

 ☐ Small Claims up to $8,000 

 ☒ Civil 

 ☐ Replevins

 ☐ Evictions

 ☐ Other civil (non-monetary)

 

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COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the

Administrative Order. Yes ☐ No ☒

IV. REMEDIES SOUGHT (check all that apply):

☒ Monetary;

☐ Non-monetary declaratory or injunctive relief;

☐ Punitive

V. NUMBER OF CAUSES OF ACTION: 

(Specify)

2

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

☐ Yes

☒ No

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

☒ No

☐ Yes – If “yes” list all related cases by name, case number and court:

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

 ☒ Yes

 ☐ No

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and

that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425.

Signature: s/ Jamie H. Zidell 

Attorney or party

FL Bar No.: 10121 

(Bar number, if attorney)

 Jamie H. Zidell

 (Type or print name)

 Date: 06/05/2020

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IN THE COUNTY COURT OF THE 11th JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CIVIL DIVISION 

XIOMARA DEL CARMEN RIOS 

CHAVARRIA and all others similarly situated 

under 29 U.S.C. § 216(b),

 Plaintiff, 

vs.

YAMBO INC. , a Florida Corporation, and 

ARMANDO PEREZ SR., an individual,

 Defendants.

_____________________________________

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COMPLAINT UNDER 29 U.S.C. §§ 201- 216 OVERTIME

AND MINIMUM WAGE VIOLATIONS

Plaintiff, XIOMARA DEL CARMEN RIOS CHAVARRIA, on behalf of herself and all 

others similarly situated under 29 U.S.C. § 216(b), through undersigned counsel, and hereby files

this Complaint against Defendants, YAMBO INC., and ARMANDO PEREZ SR, and alleges: 

1. This is an action arising under the Fair Labor Standards Act 29 U.S.C. §§ 201-216. 

2. This case involves damages in excess of $8,000.00 but less than $30,000.00 exclusive of 

attorney’s fees and costs.

3. The Plaintiff, XIOMARA DEL CARMEN RIOS CHAVARRIA was a resident of Dade 

County, Florida at the time that this dispute arose.

4. The corporate Defendant YAMBO INC., is a company that regularly transacts business 

within Miami-Dade County. Upon information and belief, the Defendant Corporation 

was the FLSA employer for Plaintiff’s respective period of employment (“the relevant 

time period”). 

5. The individual Defendant ARMANDO PEREZ SR is a corporate officer and/or owner 

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and/or manager of the Defendant Corporations who ran the day-to-day operations of the 

Corporate Defendants for the relevant time period and was responsible for paying 

Plaintiff’s wages for the relevant time period and controlled Plaintiff’s work and schedule 

and was therefore Plaintiff’s employer as defined by 29 U.S.C. § 203 (d).

6. All acts or omissions giving rise to this dispute took place in Miami-Dade County.

COUNT I. FEDERAL OVERTIME WAGE VIOLATION

7. This action arises under the laws of the United States. This case is brought as a collective 

action under 29 U.S.C. § 216(b). It is believed that the Defendants have employed 

several other similarly situated employees like Plaintiff who have not been paid overtime 

and/or minimum wages for work performed in excess of 40 hours weekly from the filing 

of this complaint back three years.

8. This Court has jurisdiction pursuant to 28 U.S.C. § 1331 as this case is brought pursuant 

to The Fair Labor Standards Act, 29 U.S.C. §§ 201-219 (section #216 for jurisdictional 

placement). This Court has concurrent jurisdiction with the Federal Courts under 29 

USC §216(B).

9. 29 U.S.C. § 207 (a) (1) states, "Except as otherwise provided in this section, no employer 

shall employ any of his employees who in any workweek is engaged in commerce or in 

the production of goods for commerce, or is employed in an enterprise engaged in 

commerce or in the production of goods for commerce, for a workweek longer than forty 

hours unless such employee receives compensation for his employment in excess of the 

hours above specified at a rate not less than one and one-half times the regular rate at 

which he is employed.”

10. Plaintiff XIOMARA DEL CARMEN RIOS CHAVARRIA worked for Defendants as a 

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kitchen helper/dishwasher/cleaner from on or about May 28, 2019 through on or about

March 21, 2020. 

11. Defendant's business activities involve those to which the Fair Labor Standards Act 

applies. Both the Defendant’s business and the Plaintiffs’ work for the Defendants 

affected interstate commerce for the relevant time period. Plaintiffs’ work for the 

Defendants affected interstate commerce for the relevant time period because the 

materials and goods that Plaintiffs used on a constant and/or continual basis and/or that 

were supplied to her by the Defendants, to use on the job moved through interstate 

commerce prior to and/or subsequent to Plaintiffs’ use of the same. The Plaintiffs’ work 

for the Defendants was actually in and/or so closely related to the movement of 

commerce while he worked for the Defendants that the Fair Labor Standards Act applies 

to Plaintiffs’ work for the Defendants. 

12. Additionally, Defendants regularly employed two or more employees for the relevant 

time period who handled goods or materials that travelled through interstate commerce, 

or used instrumentalities of interstate commerce, thus making Defendant’s business an 

enterprise covered under the Fair Labor Standards Act.

13. Upon information and belief, the Defendant Corporation had gross sales or business done 

in excess of $500,000 annually for the years 2019 and is expected to exceed $500,000 for 

the year 2020.

14. Individual Defendant, ARMANDO PEREZ SR., was Plaintiff’s individual employer 

pursuant to 29 U.S.C. § 203(d) as set forth above.

15. Between the period of on or about May 28, 2019 through on or about November 1, 2019, 

Plaintiff XIOMARA DEL CARMEN RIOS CHAVARRIA worked an average of 72

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hours a week for Defendants and was paid an average of $6.251per hour but was never 

paid the extra half time rate for any hours worked over 40 hours in a week as required by 

the Fair Labor Standards Act. Plaintiff therefore claims the half time overtime rate for 

each hour worked above 40 hours in a week based on the applicable Florida minimum 

wage for each year.

16. Between the period of on or about November 1, 2019 through on or about November 30, 

2019, Plaintiff XIOMARA DEL CARMEN RIOS CHAVARRIA worked an average of 

72 hours a week for Defendants and was paid an average of $6.942per hour but was 

never paid the extra half time rate for any hours worked over 40 hours in a week as 

required by the Fair Labor Standards Act. Plaintiff therefore claims the half time 

overtime rate for each hour worked above 40 hours in a week based on the applicable 

Florida minimum wage for each year.

17. Between the period of on or about December 1, 2019 through on or about March 21, 

2020, Plaintiff XIOMARA DEL CARMEN RIOS CHAVARRIA worked an average of 

60 hours a week for Defendants and was paid an average of $8.333per hour but was 

never paid the extra half time rate for any hours worked over 40 hours in a week as 

required by the Fair Labor Standards Act. Plaintiff therefore claims the half time 

overtime rate for each hour worked above 40 hours in a week based on the applicable 

Florida minimum wage for each year.

18. Additionally, during the relevant time period, there were 3 weeks in which Plaintiff

worked 84 hours a week for Defendants and was paid an average of $6.434per hour but 

 

1

Plaintiff earned $450.00 per week for this time period.

2

Plaintiff earned $500.00 per week for this time period.

3

Plaintiff earned $500.00 per week for this time period.

4

Plaintiff earned $540.00 per week when she worked 7 days per week.

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was never paid the extra half time rate for any hours worked over 40 hours in a week as 

required by the Fair Labor Standards Act. Plaintiff therefore claims the half time 

overtime rate for each hour worked above 40 hours in a week based on the applicable 

Florida minimum wage for each year.

19. Defendants willfully and intentionally refused to pay Plaintiff’s overtime wages as 

required by the Fair Labor Standards Act as Defendants knew of the overtime 

requirements of the Fair Labor Standards Act and recklessly failed to investigate whether 

Defendants’ payroll practices were in accordance with the Fair Labor Standards Act. 

Defendants remain owing Plaintiff these wages since the commencement of Plaintiff’s

employment with Defendants for the time period specified above.

WHEREFORE, the Plaintiff requests double damages and reasonable attorney fees from 

Defendants, jointly and severally, pursuant to the Fair Labor Standards Act as cited above, to be 

proven at the time of trial for all overtime wages still owing from Plaintiff’s entire employment 

period with Defendants or as much as allowed by the Fair Labor Standards Act along with court 

costs, interest, and any other relief that this Court finds reasonable under the circumstances. The 

Plaintiff requests a trial by jury.

COUNT II. FLORIDA MINIMUM WAGE VIOLATIONS

COMES NOW PLAINTIFF, through Counsel, and re-adopt the factual and jurisdictional 

statements in paragraphs 1-19 above and further state:

20. Florida Statute § 448.110 (3) states “Effective May 2, 2005, employers shall pay 

employees a minimum wage at an hourly rate of $6.15 for all hours worked in Florida. 

Only those individuals entitled to receive the federal minimum wage under the federal 

Fair Labor Standards Act and its implementing regulations shall be eligible to receive the 

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state minimum wage pursuant to s. 24, Art. X of the State Constitution and this section. 

The provisions of ss. 213 and 214 of the federal Fair Labor Standards Act, as interpreted 

by applicable federal regulations and implemented by the Secretary of Labor, are 

incorporated herein.” [Fla. Stat. § 448.110 (3)]. 

21. Florida Statute § 448.110 (4)(a) states “Beginning September 30, 2005, and annually on 

September 30 thereafter, the Agency for Workforce Innovation shall calculate an adjusted 

state minimum wage rate by increasing the state minimum wage by the rate of inflation 

for the 12 months prior to September 1.”

22. As of May 2, 2005, Florida’s minimum wage was raised to $6.15/hr. On January 1, 2006 

the Florida Minimum Wage was raised to $6.40/hr. On January 1, 2007 the Florida 

Minimum Wage was raised to $6.67/hr. On January 1, 2008 the Florida Minimum Wage 

was raised to $6.79/hr. On January 1, 2009 the Florida Minimum Wage was raised to 

$7.21/hr. On June 1, 2011, the Florida minimum wage was increased to $7.31/hr. On 

January 1, 2012, the Florida minimum wage was increased to $7.67/hr. On January 1, 

2013, the Florida minimum wage was increased to $7.79/hr. On January 1, 2014, the 

Florida minimum wage was increased to $7.93/hr. On January 1, 2015, the Florida 

minimum wage was increased to $8.05/hr. Minimum wage claims are brought pursuant to 

the Florida Constitution and the Fair Labor Standards Act. On January 1, 2017, the 

Florida minimum wage was increased to $8.10/hr. Minimum wage claims are brought 

pursuant to the Florida Constitution and the Fair Labor Standards Act. On January 1, 

2018, the Florida minimum wage was increased to $8.25/hr. Minimum wage claims are 

brought pursuant to the Florida Constitution and the Fair Labor Standards Act. On 

January 1, 2019, the Florida minimum wage was increased to $8.46/hr. Minimum wage 

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claims are brought pursuant to the Florida Constitution and the Fair Labor Standards Act.

On January 1, 2020, the Florida minimum wage was increased to $8.56/hr. Minimum 

wage claims are brought pursuant to the Florida Constitution and the Fair Labor 

Standards Act.

23. The Fair Labor Standards Act provides that if a state has a minimum wage that is higher 

than the Florida minimum wage, then an employee in that state has a Florida right under 

the FLSA to be paid that state’s minimum wage. 29 U.S.C. § 218(a); see also 29 C.F.R. 

§ 541.4; see also C.F.R. § 778.5. Thus, Plaintiff claims the Florida minimum wage for all 

hours worked pursuant to the hourly rates listed in the previous paragraph.

5

24. Between the period of on or about May 28, 2019 through on or about November 1, 

2019, Plaintiff XIOMARA DEL CARMEN RIOS CHAVARRIA worked an average of 

72 hours a week for Defendants and was paid an average of $6.256per hour which did 

not meet the applicable Florida Minimum Wage required for said period of time. 

Therefore, Plaintiff claims difference between Plaintiff’s average hourly rate of $6.25/hr 

and the applicable minimum wage rate for all hours worked.

25. Between the period of on or about November 1, 2019 through on or about November 30, 

2019, Plaintiff XIOMARA DEL CARMEN RIOS CHAVARRIA worked an average of 

72 hours a week for Defendants and was paid an average of $6.947per hour which did 

not meet the applicable Florida Minimum Wage required for said period of time. 

Therefore, Plaintiff claims difference between Plaintiff’s average hourly rate of $6.94/hr 

and the applicable minimum wage rate for all hours worked.

 

5

Plaintiff is not required to comply with the Florida statute’s pre-suit notice requirements when the minimum wage 

violations occur within 3 years prior to filing. See Touzout v. America Best Care Rental KF Corp., 2017 WL 

2541225 *1 (S.D. Fla. December 21, 2017).

6

Plaintiff earned $450.00 per week for this time period.

7

Plaintiff earned $500.00 per week for this time period.

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26. Between the period of on or about December 1, 2019 through on or about March 21, 

2020, Plaintiff XIOMARA DEL CARMEN RIOS CHAVARRIA worked an average of 

60 hours a week for Defendants and was paid an average of $8.338per hour which did 

not meet the applicable Florida Minimum Wage required for said period of time. 

Therefore, Plaintiff claims difference between Plaintiff’s average hourly rate of $8.33/hr 

and the applicable minimum wage rate for all hours worked.

27. Additionally, there were 3 weeks within the relevant time period in which Plaintiff

worked 84 hours a week for Defendants and was paid an average of $6.439per hour

which did not meet the applicable Florida Minimum Wage required for said period of 

time. Therefore, Plaintiff claims difference between Plaintiff’s average hourly rate of 

$6.43/hr and the applicable minimum wage rate for all hours worked.

28. Defendant's business activities involve those to which the Fair Labor Standards Act 

applies. Both the Defendant’s business and the Plaintiffs’ work for the Defendants 

affected interstate commerce for the relevant time period. Plaintiffs’ work for the 

Defendants affected interstate commerce for the relevant time period because the 

materials and goods that Plaintiffs used on a constant and/or continual basis and/or that 

were supplied to her by the Defendants, to use on the job moved through interstate 

commerce prior to and/or subsequent to Plaintiffs’ use of the same. The Plaintiffs’ work 

for the Defendants was actually in and/or so closely related to the movement of 

commerce while he worked for the Defendants that the Fair Labor Standards Act applies 

to Plaintiffs’ work for the Defendants. 

29. Additionally, Defendants regularly employed two or more employees for the relevant 

 

8

Plaintiff earned $500.00 per week for this time period.

9

Plaintiff earned $540.00 per week when she worked 7 days per week.

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time period who handled goods or materials that travelled through interstate commerce, 

or used instrumentalities of interstate commerce, thus making Defendant’s business an 

enterprise covered under the Fair Labor Standards Act.

30. Upon information and belief, the Defendant Corporation had gross sales or business done 

in excess of $500,000 annually for the years 2019 and is expected to exceed $500,000 for 

the year 2020.

31. Defendants willfully and intentionally refused to pay Plaintiff’s minimum wages as 

required by the Fair Labor Standards Act as Defendants knew of the Florida Minimum 

Wage requirements of the Fair Labor Standards Act and recklessly failed to investigate 

whether Defendants’ payroll practices were in accordance with the Fair Labor Standards 

Act. Defendants remain owing Plaintiff these wages since the commencement of 

Plaintiff’s employment with Defendants for the time period specified above.

WHEREFORE, Plaintiff request double damages and reasonable attorney fees from the 

Defendants, jointly and severally, pursuant to the Fair Labor Standards Act and pursuant to Fla. 

Stat. § 448.08, and as cited above, to be proven at the time of trial for all minimum wages still 

owing from Plaintiff’s entire employment period with Defendants or, as much as allowed by the 

Fair Labor Standards Act --whichever is greater along with court costs, interest, and any other 

relief that this Court finds reasonable under the circumstances. The Plaintiff requests a trial by 

jury.

[THIS SPACE INTENTIONALLY LEFT BLANK]

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Respectfully Submitted,

J.H. Zidell, Esq.

J.H. Zidell, P.A.

Attorney For Plaintiff

300 71st Street, Suite 605

Miami Beach, Florida 33141

Tel: (305) 865-6766

 Fax: (305) 865-7167

Email: ZABOGADO@AOL.COM

By:__/s/ J.H. Zidell__________

 J.H. Zidell, Esq.

Florida Bar Number: 0010121

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Page 1 of 2

IN THE COUNTY COURT IN AND FOR

MIAMI-DADE COUNTY, FLORIDA

CIVIL DIVISION

CASE NO.: 2020-001452-CC-24

XIOMARA DEL CARMEN RIOS

CHAVARRIA and all others similarly situated

under 29 U.S.C. § 216(b),

 Plaintiff,

vs.

YAMBO INC. , a Florida Corporation, and

ARMANDO PEREZ SR., an individual,

 Defendants.

_____________________________________

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NOTICE OF APPEARANCE OF COUNSEL

COME(S) NOW the undersigned counsel and notices the Court and all parties as

follows:

The undersigned hereby appears as an additional trial counsel of record on behalf of the

Plaintiff(s), and requests that all documents filed or served in this case be sent to the

undersigned.

NATALIE STAROSCHAK, ESQ.

J.H. ZIDELL, P.A.

ATTORNEY FOR PLAINTIFF

300 71ST STREET, #605

MIAMI BEACH, FL 33141

PH: 305-865-6766

FAX: 305-865-7167

EMAIL: NSTAR.ZIDELLPA@GMAIL.COM

F.B.N. 116745

BY:___/s/___Natalie Staroschak______________

NATALIE STAROSCHAK, ESQ.

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT A TRUE AND CORRECT COPY OF THE

FOREGOING WAS SENT VIA CM/ECF FILING ON JUNE 30, 2020 TO:

ALL EFILING REGISTRANTS

BY:___/s/___Natalie Staroschak______________

NATALIE STAROSCHAK, ESQ.

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IN THE CIRCUIT COURT 

OF THE TWENTIETH JUDICIAL CIRCUIT IN 

AND FOR MIAMI DADE COUNTY, FLORIDA 

XIOMARA DEL CARMEN RIOS CASE NO.: 2020-001452-CC-24 

CHAVARRIA and all others similarly 

situated under 29 U.S.C. § 216(b), 

 

Plaintiff, 

v. 

YAMBO INC., a Florida Corporation, and 

ARMANDO PEREZ SR., an individual, 

Defendants. / 

DEFENDANTS’ YAMBO, INC. AND ARMANDO PEREZ, SR.’S 

JOINT MOTION FOR ENLARGEMENT OF TIME 

TO FILE A RESPONSE TO PLAINTIFF’S COMPLAINT 

COMES NOW, Defendants YAMBO, INC., a Florida Corporation (“Yambo”), and 

ARMANDO PEREZ SR. (“AP”), individually, by and through undersigned counsel, respectfully 

submit this unopposed motion for enlargement of time to respond to Plaintiff’s Complaint, and in 

support of states as follows: 

1. On June 5, 2020, Plaintiff filed her Complaint against Defendants Yambo and AP, 

under the Fair Labor Standards Act (“FLSA”). 

2. On or about July 2, 2020, Plaintiff served Yambo and AP. 

3. Defendants response to Plaintiff’s Complaint is due on July 22, 2020. 

4. Both Defendants are represented by undersigned counsel. 

5. Defendants respectfully request to jointly respond to the Complaint. 

6. The service of Plaintiff’s Complaint was the first notification to Defendants that 

Plaintiff believed that she any claims of any kind related to her employment with Defendants. 

7. Defendants recently retained the undersigned counsel. 

Case 1:20-cv-23101-BB Document 1-1 Entered on FLSD Docket 07/27/2020 Page 23 of 28
CASE NO.: 2020-001452-CC-24

-2-

8. Defendants respectfully request this Honorable Court a brief enlargement of time 

to jointly respond to Plaintiff’s Complaint. 

9. This motion is made in good faith and not for the purpose of delay and the Plaintiff 

will not be prejudiced by the requested enlargement of time. 

WHEREFORE, Defendants respectfully move this Court for an enlargement of time to 

respond to Plaintiff’s Complaint and for such further relief the Court deems just and proper. 

 Date: July 20, 2020 Respectfully submitted, 

 TARA E. FAENZA, PA 

Counsel for Defendants 

 66 West Flagler Street, Suite 900 

 Miami, Florida 33130 

 Telephone (786) 376-2272 

 tef@faenzalaw.com

 

 By: /s/ Tara E. Faenza 

 TARA E. FAENZA 

 Florida Bar No.: 106928 

 tef@faenzalaw.com 

 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via Eservice this 20th day of July, 2020 to: J.H. Zidell, Esq., J.H. Zidell, P.A., Counsel for Plaintiff, 

(Email: ZABOGADO@AOL.COM); David Nudel, Esq., J.H. Zidell, P.A., Counsel for Plaintiff, 

(Email: DNUDEL.JHZIDELLPA@GMAIL.COM). 

 By: /s/ Tara E. Faenza, 

 TARA E. FAENZA, ESQ. 

Case 1:20-cv-23101-BB Document 1-1 Entered on FLSD Docket 07/27/2020 Page 24 of 28
IN THE COUNTY COURT IN AND FOR 

MIAMI-DADE COUNTY, FLORIDA

CIVIL DIVISION 

CASE NO.: 2020-001452-CC-24

XIOMARA DEL CARMEN RIOS 

CHAVARRIA and all others similarly situated 

under 29 U.S.C. § 216(b),

 Plaintiff, 

vs.

YAMBO INC. , a Florida Corporation, and 

ARMANDO PEREZ SR., an individual,

 Defendants.

_____________________________________

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NOTICE OF APPEARANCE OF COUNSEL

COME(S) NOW the undersigned counsel and notices the Court and all parties as 

follows:

The undersigned hereby appears as an additional trial counsel of record on behalf of the 

Plaintiff(s), and requests that all documents filed or served in this case be sent to the 

undersigned.

DAVID M. NUDEL, ESQ.

J.H. ZIDELL, P.A.

ATTORNEY FOR PLAINTIFF

300 71ST STREET, #605

MIAMI BEACH, FL 33141

PH: 305-865-6766

FAX: 305-865-7167

EMAIL: DNUDEL.JHZIDELLPA@GMAIL.COM

F.B.N. 1003678

BY:___/s/___David M. Nudel______________

DAVID M. NUDEL, ESQ.

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT A TRUE AND CORRECT COPY OF THE 

FOREGOING WAS SENT VIA CM/ECF FILING ON JULY 6, 2020 TO:

ALL EFILING REGISTRANTS

BY:___/s/___David M. Nudel______________

DAVID M. NUDEL, ESQ.

Page 2 of 2

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IN THE CIRCUIT COURT 

OF THE TWENTIETH JUDICIAL CIRCUIT IN 

AND FOR MIAMI DADE COUNTY, FLORIDA 

XIOMARA DEL CARMEN RIOS CASE NO.: 2020-001452-CC-24 

CHAVARRIA and all others similarly 

situated under 29 U.S.C. § 216(b), 

 

Plaintiff, 

v. 

YAMBO INC., a Florida Corporation, and 

ARMANDO PEREZ SR., an individual, 

Defendants. / 

NOTICE OF APPEARANCE 

COME(S) NOW the undersigned counsel and notices the Court and all parties as follows: 

The undersigned hereby appears as an additional trial counsel of record on behalf of the Plaintiff(s), 

and requests that all documents filed or served in this case be sent to the undersigned. 

Tara E. Faenza, Esq. 

Tara E. Faenza, PA 

66 West Flagler Street, Suite 900 

Miami, FL 33130 

Email: tef@faenzalaw.com

Telephone: 786-376-2272 

 Date: July 20, 2020 Respectfully submitted, 

 TARA E. FAENZA, PA 

Counsel for Defendants 

 66 West Flagler Street, Suite 900 

 Miami, Florida 33130 

 Telephone (786) 376-2272 

 tef@faenzalaw.com

 

 By: /s/ Tara E. Faenza 

 TARA E. FAENZA 

 Florida Bar No.: 106928 

 tef@faenzalaw.com 

 

Case 1:20-cv-23101-BB Document 1-1 Entered on FLSD Docket 07/27/2020 Page 27 of 28
CASE NO.: 2020-001452-CC-24

-2-

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-service 

this 20th day of July, 2020 to: J.H. Zidell, Esq., J.H. Zidell, P.A., Counsel for Plaintiff, (Email: 

ZABOGADO@AOL.COM); David Nudel, Esq., J.H. Zidell, P.A., Counsel for Plaintiff, (Email: 

DNUDEL.JHZIDELLPA@GMAIL.COM). 

 By: /s/ Tara E. Faenza, 

 TARA E. FAENZA, ESQ. 

Case 1:20-cv-23101-BB Document 1-1 Entered on FLSD Docket 07/27/2020 Page 28 of 28