UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

ANTONIO RICARDO VILARINO, 

Plaintiff,

v.

THE EVENT GROUP ENTERPRISES, INC., 

JOEL CLENDENIN, 

ASHLEY CLENDENIN, 

JOSEPH J. DOHERTY, 

Defendants.

__________________________________/

COMPLAINT

{Jury Trial Demanded}

Plaintiff, ANTONIO RICARDO VILARINO, brings this action against Defendants, THE 

EVENT GROUP ENTERPRISES, INC., JOEL CLENDENIN, ASHLEY CLENDENIN, and

JOSEPH J. DOHERTY, pursuant to the Fair Labor Standards Act (“FLSA”), 29 U.S.C § 201 et 

seq., and alleges as follows:

1. Jurisdiction is conferred on this Court by 28 U.S.C. § 1331 and 29 U.S.C. § 216(b). 

2. At all times material hereto, Plaintiff ANTONIO RICARDO VILARINO was a resident of 

the State of Florida and an “employee” of Defendants as defined by the FLSA.

3. Defendants’ business is located in Broward County, Florida.

4. At all times material hereto, Defendant, THE EVENT GROUP ENTERPRISES, INC., was 

a Florida corporation with its principal place of business in South Florida, engaged in commerce 

in the field of producing events including designing and furnishing their décor, at all times material 

hereto was the “employer” of Plaintiff as that term is defined under statutes referenced herein, 

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engaged along with its employees in interstate commerce, and has annual gross sales and/or 

business volume of $500,000 or more.

5. Defendant, JOEL CLENDENIN, is a resident of Palm Beach County, Florida and was, and 

now is, a manager of Defendant, THE EVENT GROUP ENTERPRISES, INC., controlled 

Plaintiff’s duties, hours worked, and compensation, and managed the day-to-day operations of 

THE EVENT GROUP ENTERPRISES, INC. Accordingly, JOEL CLENDENIN was and is an 

“employer” of the Plaintiff within the meaning of 29 U.S.C. §203(d).

6. Defendant, ASHLEY CLENDENIN, is a resident of Palm Beach County, Florida and was, 

and now is, a manager of Defendant, THE EVENT GROUP ENTERPRISES, INC., controlled 

Plaintiff’s duties, hours worked, and compensation, and managed the day-to-day operations of 

THE EVENT GROUP ENTERPRISES, INC. Accordingly, ASHLEY CLENDENIN was and is an 

“employer” of the Plaintiff within the meaning of 29 U.S.C. §203(d).

7. Defendant, JOSEPH J. DOHERTY, is a resident of Palm Beach County, Florida and was, 

and now is, a manager of Defendant, THE EVENT GROUP ENTERPRISES, INC., controlled 

Plaintiff’s duties, hours worked, and compensation, and managed the day-to-day operations of 

THE EVENT GROUP ENTERPRISES, INC. Accordingly, JOSEPH J. DOHERTY was and is an 

“employer” of the Plaintiff within the meaning of 29 U.S.C. §203(d).

8. Two or more of Defendants’ employees handled tools, supplies, and equipment 

manufactured outside Florida in furtherance of their business, including but not limited to phones, 

computers, computer monitors, computer keyboards, computer mice, pens, and paper.

9. Plaintiff ANTONIO RICARDO VILARINO worked for Defendants as a general laborer.

10. Defendants failed to pay Plaintiff’s full and proper overtime wages of 1.5 times Plaintiff’s

regular hourly rate of $20 for hours worked over 40 each week.

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11. Attached as Exhibit A is a preliminary calculation of Plaintiff’s claims. These amounts may 

change as Plaintiff engages in the discovery process.

12. Defendants have knowingly and willfully refused to pay Plaintiff’s legally-entitled wages.

13. Plaintiff has complied with all conditions precedent to bringing this suit, or same have been 

waived or abandoned.

14. Plaintiff has retained the services of the undersigned and is obligated to pay for the legal 

services provided.

COUNT I

VIOLATION OF FAIR LABOR STANDARDS ACT (“FLSA”)

ALL DEFENDANTS

15. Plaintiff realleges and incorporates the allegations set forth in paragraphs 1-14 above as if

set forth herein in full.

16. Plaintiff alleges this action pursuant to the Fair Labor Standards Act, 29 U.S.C. §§ 216 (b), 

that Plaintiff is entitled to: (i) time-and-a-half overtime pay and (ii) liquidated damages pursuant 

to the Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq. 

17. Plaintiff seeks recovery of damages as referenced above and further seeks interest, costs, 

and attorneys’ fees pursuant to 29 U.S.C. § 216(b).

WHEREFORE, Plaintiff demands judgment against Defendants, jointly and severally, plus 

costs, reasonable attorneys’ fees, and such other remedy as the court deems just and appropriate.

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COUNT II

BREACH OF CONTRACT AND FAILURE TO PAY WAGES

DEFENDANT THE EVENT GROUP ENTERPRISES, INC.

18. Supplemental jurisdiction over the pendent state claim is conferred on this Court by 28 

U.S.C. 1367.

19. Plaintiff reallege and incorporates the allegations set forth in paragraphs 1-14 above as if 

set forth herein in full.

20. Plaintiff entered into an oral contract for wages at the rate of pay indicated in Plaintiff’s

Statement of Claim.

21. Plaintiff worked for Defendant and did not receive the compensation promised. Defendant, 

therefore, wrongfully deprived Plaintiff of wages that were due and owing and to which Plaintiff 

is lawfully entitled under an oral contract for wages with Defendant.

22. Plaintiff have been damaged as a result of Defendant’s failure to pay the agreed upon 

wages.

23. Pursuant to Section 448.08, Florida Statutes, Plaintiff is entitled to the costs of this action 

and reasonable attorneys’ fees.

WHEREFORE, Plaintiff demands judgment against Defendant for the unpaid wages that 

are due and owing, prejudgment interest, reasonable attorneys’ fees and costs incurred in this 

action, and any and all further relief this Court deems just and appropriate.

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Respectfully submitted,

Koz Law, P.A.

320 S.E. 9th Street

Fort Lauderdale, Florida 33316

Phone: (786) 924-9929

Fax: (786) 358-6071

Email: ekoz@kozlawfirm.com

Elliot Kozolchyk, Esq.

Bar No.: 74791

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