UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

GARNETTE VASSOR, 

Plaintiff,

v.

HARKHAM SHIPPING LLC, 

GABRIEL HARKHAM, 

JOSEPH WOLANSKI, 

Defendants.

__________________________________/

COMPLAINT

{Jury Trial Demanded}

Plaintiff, GARNETTE VASSOR, brings this action against Defendants, HARKHAM 

SHIPPING LLC, GABRIEL HARKHAM, and JOSEPH WOLANSKI, 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 GARNETTE VASSOR was a resident of the State of 

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

3. At all times material hereto, Plaintiff engaged in interstate commerce on a regular and 

recurring basis within the meaning of the FLSA through, among other activity, her work as a guard 

at Defendants’ premises where goods moving in intersate or foreign commerce are kept pursuant 

to 29 CFR § 779.115.

4. At all times material hereto, Defendant, HARKHAM SHIPPING LLC, was a Florida 

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

of shipping, at all times material hereto was the “employer” of Plaintiff as that term is defined 

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under statutes referenced herein, engaged along with its employees in interstate commerce, and 

has annual gross sales and/or business volume of $500,000 or more.

5. Defendant, GABRIEL HARKHAM, is a resident of Broward County, Florida and was, and 

now is, a manager of Defendant, HARKHAM SHIPPING LLC, controlled Plaintiff’s duties, hours 

worked, and compensation, and managed the day-to-day operations of HARKHAM SHIPPING 

LLC. Accordingly, GABRIEL HARKHAM was and is an “employer” of the Plaintiff within the 

meaning of 29 U.S.C. §203(d).

6. Defendant, JOSEPH WOLANSKI, is a resident of Broward County, Florida and was, and 

now is, a manager of Defendant, HARKHAM SHIPPING LLC, controlled Plaintiff’s duties, hours 

worked, and compensation, and managed the day-to-day operations of HARKHAM SHIPPING 

LLC. Accordingly, JOSEPH WOLANSKI was and is an “employer” of the Plaintiff within the 

meaning of 29 U.S.C. §203(d).

7. 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.

8. Plaintiff GARNETTE VASSOR worked for Defendants as a security guard.

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

regular hourly rate for hours worked over 40 each week.

10. Defendants failed to pay Plaintiff’s full and proper minimum wages for certain hours 

worked during Plaintiff’s employment.

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.

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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) unpaid minimum wages; (ii) time-and-a-half overtime pay, and (iii) 

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.

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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