UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

CIVIL COMPLAINT 

(Write the full name of each Plaintiff 

who is filing this complaint. If the 

names of all the plaintiffs cannot fit 

in the space above, please write 

"see attached" in the space and 

attach an additional page with the 

full list of names.) 

v. Case No.: I : Jo cJ 107 MW/ if{ 

(To be filled in by the Clerk's Office) 

(Write the full name of each Defendant 

who is being sued. If the names of all 

the Defendants cannot fit in the space 

above, please write "see attached" in 

the space and attach an additional 

page with the full list of names.) 

I --------------

NDFL Pro Se 1 (Rev. 12/16) Civil Complaint 

ClerkAdmin/Official/Forms 

Jury Trial Requested? 

YES ~ NO 

80:llWd Ol, 11 hlJW 

no GNl:I :)050 0371:I 

1 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 1 of 16
I. PARTIES TO THIS COMPLAINT 

A. Plaintiff( s) 

1. Plaintiff's Name: _m_\_C_~-~-\~_9-__ \_\)_t~\7~---

Address: l'.Yii Sh 1lll ~ / S-2--1-\,,_ ld{\f\,<l, 

City, State, and Zip Code: AJ ({(,'v'l>-Aftj FL- ~'LSTelephone: fi;0 -~3?4-6~ome)~(l) .. :a-~L.-\--3S~e) (Cell) 

_______ (Home) _______ (Cell) 

(Provide this information for any additional Plaintiffs in this case by 

attaching an additional page as needed.) 

B. Defendant(s) 

1. Defendant's Name: ---------------

Name of Employer (ifrelevant):~O Gffiut S&\~\.~&tvS 

Address:~ 1t.) l ~0~£\. \j'J\, V'\\~ (2=, \ vJ 

City, State, and Zip Code~;./\.,\~ 1 f L '2y 7-;,t) ~ ~ 

NDFL Pro Se I (Rev. 12/ 16) Civil Complaint 

ClerkAdmin/Official/Forms 2 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 2 of 16
2. Defendant's Name: --------------.,L-----

Name of Employer (if relevant): ______________ _ 

Address: -----------~- ----------

3. Defendant's Name: - - -----------------

Address: -----------------------

tate, and Zip Code: -----------------

rovide this information for any additional Defendants in this case by 

attaching additional pages as needed.) 

II. BASIS FOR JURISDICTION 

Federal courts have limited jurisdiction. Generally, only two types of cases 

may be heard in federal court: (1) a case involving a federal question or (2) 

case involving diversity of citizenship of the parties. A "federal question" 

case arises under the United States Constitution or federal laws or treaties. 28 

U.S.C. § 1331. A "diversity" case means a citizen of one State sues a citizen 

of another State or nation. No defendant may be a citizen of the same State as 

any Plaintiff in a diversity case, and the amount in controversy must be more 

NDFL Pro Se I (Rev. 12/ 16) Civil Complaint 

ClerkAdmin/OfficiaVForms 3 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 3 of 16
than $75,000. 28 U.S.C. § 1332. 

What is the basis for federal court jurisdiction? (check all that apply) 

,LP ederal Question □ Diversity of Citizenship 

Fill out the paragraphs in this section that apply to this case. 

A. If the Basis for Jurisdiction Is a Federal Question: 

List the specific federal statutes, federal treaties, and/or provisions of the 

United States Constitution that are at issue in this case: -------

B. If the Basis for Jurisdiction is Diversity of Citizenship: 

1. Plaintiff( s) 

a. Plaintiff is an individual and a citizen of: -----,.c--------

b. If any Plaintiff is a business or co ration, list the State where the 

te: Businesses/Corporations must be represented by counsel. 

NDFL Pro Se I (Rev. 12/16) Civil Complaint 

ClerkAdmin/OfficiaVForms 4 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 4 of 16
Attach additional page to provide this information for additional 

Plaintiffs.) 

2. Defendant(s) 

a. If the Defendant is an individual, identify their citizenship below. 

1. Defendant (name)-----------------,- --

3. 

b. If the Defendant is a corporation or business, list the state of 

incorporation or principal place of business below. 

1. Defendant (name) 3e..V\o ())~\U{ 

State of Incorporation is _£\ _,___-+---{:)"-C' ............. t &_______.~-------

or Principal Place of Business is'l_-+0.: ---"-"~-__,~1.- ,------

2. Defendant (name) _______________ _ 

or Principal Place of Business is --~----------

(Attach additional page if necessary to list all Defendants.) 

3. Have you previously been involved in litigation with one or more 

NDFL Pro Se I (Rev. 12/ 16) Civil Complaint 

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Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 5 of 16
of the named Defendants? 

□ Yes ,t.No 

If yes, identify prior case#: _______ Date: ____ _ 

Court: ----------------------

Defendant: --------------------

Judge: _______________ _____ _ 

Result: ---------------------

III. STATEMENT OF CLAIM 

Write a short and plain statement of your claim. Do not make legal 

arguments or quote from cases. State the facts which show what happened, 

as well as where and when it happened. State how each Defendant was 

involved and explain what a Defendant did or did not do; identify how each 

Defendant caused you harm or violated federal law. Write each statement in 

numbered paragraphs, limited as far as practicable to a single event or 

incident. If more than one claim is asserted, number each claim, and ensure 

that a short and plain statement of facts supporting each claim is included in 

the facts alleged. Attach no more than two (2) additional pages to state your 

claim. 

NDFL Pro Se I (Rev. 12/16) Civil Complaint 

ClerkAdmin/Official/Fonns 6 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 6 of 16
IV. RELIEF REQUESTED 

State briefly and precisely what damages or other relief the plaintiff asks the 

court to order. Do not make legal arguments. Include any basis for claiming 

that the wrongs alleged are continuing at the present time. Include the 

amounts of any actual damages claimed for the acts alleged and the basis for 

these amounts. Include any punitive or exemplary damages claimed, the 

amounts, and the reasons you claim you are entitled to actual or punitive 

money damages. ---------------------

V. CERTIFICATION 

As required by Federal Rule of Civil Procedure 11 , I certify by signing below 

that to the best of my knowledge, information, and belief, this complaint: ( 1) 

is not being presented for an improper purpose, such as to harass, cause 

unnecessary delay, or needlessly increase the cost of litigation; (2) is 

supported by existing law or by a non-frivolous argument for extending, 

NDFL Pro Se I (Rev. 12/ 16) Civil Complaint 

ClerkAdmin/OfficiaVFonns 7 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 7 of 16
modifying, or reversmg existing law; (3) the factual contentions have 

evidentiary support or, will likely have evidentiary support after a reasonable 

opportunity for further investigation or discovery; and (4) the complaint 

otherwise complies with the requirements of Rule 11. 

I agree to timely notify the Clerk's Office if there is any change to my 

mailing address. I understand that my failure to keep a current address on file 

with the Clerk's Office may result in the dismissal of my case. 

Date: 4(i,{~ Plaintiffs Signature: 8 V 

Printed Name of Plaintiff: ~~~~.\ Q_,J{-IZ:, 

Address: LM\~. ~u} l ss~ l~ 

A.LC{!,Y\<AJ\, R ~ 3~~ l S 

E-Mail Address: W\~- ~\.J-tsz, ® ~"--\\. (($)\N\ 

Telephone Number: <c?£G -~ ~ L\ '- 3 S:!6 

(Additional signature pages must be attached if there is more than one 

Plaintiff.) 

NDFL Pro Se I (Rev. 12/ 16) Civil Complaint 

ClerkAdmin/OfficiaVFonns 8 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 8 of 16
Michael Rivers, 

v. 

Zeno Office Solutions 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRIC OF FLORIDA 

Plaintiff 

Case: --------

Defendant April 21 , 2020 

CIVIL COMPLAINT 

ATTACHMENT A 

1. The Plaintiff, Michael Rivers, currently resides in the City of Alachua, County of 

Alachua, and the State of Florida currently and all times relevant to this 

complaint. 

2. Zeno Office Solutions is a Corporation with an address of 8701 Florida Mining 

Boulevard in the City of Tampa, County of Hillsborough, and the State of Florida 

and has been Incorporated and at the same address all times relevant to this 

complaint. 

3. On December 10, 2018, the Plaintiff was employed by Zeno Office Solutions. 

4. Among other duties, the Plaintiff was servicing and installing Xerox brand copiers 

and printers during his employment. 

5. While employed with Zeno the Plaintiff was required to maintain inventory in his 

personal vehicle and home and was required to answer emails, telephone calls, 

and text messages prior to and after scheduled work hours, lunch breaks, and on 

non-workdays i.e. weekends. 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 9 of 16
6. On January 15, 2019, the Plaintiff resigned from Zeno Office Solutions. 

12. The Plaintiff regularly completed work at home without compensation as required 

to meet the requirements of the job and as directed by his manager David 

Rutherford. 

13. The Plaintiff was required to answer phone calls, emails, and text messages 

during his scheduled lunch hour and was required to update his company provided 

laptop computer data at home after work hours and on weekends. 

14. All parts required for service calls and re-stocking of parts inventory used were 

shipped to the Plaintiffs home address and he was required to open several boxes 

of parts both large and small after work hours and weekends. 

15. The Plaintiff was required to re-stock his personal vehicle with parts as required 

after work hours and weekends and was unable to use said vehicle for personal 

use due to "car stock" [parts needed] requirements and he was required to discard 

and/or recycle all shipping materials and parts after work hours and on weekends. 

11. The Plaintiff worked several hundred hours without properly being compensated. 

WHEREFORE, the Plaintiff claims: 

1. The Defendant breached its duty to act causing significant financial loss to the 

Plaintiff. 

2. The Plaintiff is owed 

The PLAINTIFF 

By,CID 

Michael Rivers 

2 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 10 of 16
Michael Rivers, 

v. 

Zeno Office Solutions 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRIC OF FLORIDA 

Plaintiff 

Case: --------

Defendant April 21, 2020 

CIVIL COMPLAINT 

ATTACHMENT B 

1. The Plaintiff, Michael Rivers, claims the Defendant failed to pay overtime at a 

rate of thirty-three (33) dollars per hour. 

2. The amount calculated is as follows: 

a. Employed from December of 2018 through July of 2019 or approximately 

twenty (28) weeks. 

b. Plaintiff approximate hours worked "off' the clock and uncompensated for 

approximately fifteen (15) hours per work. 

c. Total uncompensated hours of approximately three hundred sixty-four (364). 

d. The Plaintiff is owed approximately thirteen thousand eight hundred 

sixty (13,860) dollars. 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 11 of 16
3. The Plaintiff makes the claim for punitive damages as Zeno Office Solutions 

knew or should have known that its manager was requiring work "off' the clock. 

Second, Zeno Office Solutions knowingly shipped parts for service calls and 

"car" stock to the Plaintiffs home subsequently requiring working "off' the clock 

hours. 

a. The Plaintiff requests the Court order punitive damages in the amount of 

one hundred twenty-five thousand dollars (125,000). 

The PLAINTIFF 

2 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 12 of 16
UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF FLORIDA 

PENSACOLA DIVISION 

Michael Rivers 

Plaintiff, 

vs. Case No: ------------

Zeno Office Solutions 

Defendant(s). 

NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS 

(For Use by Prisoners and Pro Se Plaintiffs Proceeding In Forma Pauperis) 

To: Zeno Office Solutions 

(Name of the defendant or-if the defendant is a corporation, partnership, or association-an officer 

or agent authorized to receive service) 

Why are you getting this? 

A lawsuit has been filed against you, or the entity you represent, in this court under the 

number shown above. A copy of the complaint is attached. 

This is not a summons, or an official notice from the court. It is a request that, to avoid 

expenses, you waive formal service of a summons by signing and returning the enclosed waiver. 

To avoid these expenses, you must return the signed waiver within 60 days (give at least 30 

days, or at least 60 days if the defendant is outside any judicial district of the United States) from 

the date certified below by the United States Marshal Service as the date this notice was sent. Two 

copies of the waiver form are enclosed, along with a stamped, self-addressed envelope or other 

prepaid means for returning one copy. You may keep the other copy. 

What happens next? 

If you return the signed waiver, it will be filed with the court. The action will then proceed 

as if you had been served on the date the waiver is filed, but no summons will be served on you and 

you will have 60 days from the date this notice was sent (see the date certified below by the United 

States Marshal Service) to answer the complaint ( or 90 days if this notice is sent to you outside any 

judicial district of the United States). 

If you do not return the signed waiver within the time indicated, arrangements will be made 

to have the summons and complaint served on you, and you, or the entity you represent, may be 

required to pay the expenses of making service. 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 13 of 16
Date: 4/21/2020 

Signature of the attorney or unrepresented party 

Michael Rivers 

Printed name 

13912 NW 155th Lane 

Address 

Alachua, FL 32615 

Address 

Certification by United States Marshal Service of Date Notice was Sent 

I certify that this request was sent to the above-named defendant on the date below. 

Date: --------- Signature of USMS representative 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 14 of 16
Michael P. Rivers 

13912 NW 155th Lane• Alachua, FL 32615 • (860) 234-3580 • mike-rivers@hotmail.com 

United States District Court 

401 SE P1 Avenue, Suite 243 

Gainesville, FL 32601 

RE: Civil Complaint 

Dear Clerk: 

May 4, 2020 

Enclosed please find an Affidavit of Financial Status, Motion to Proceed In Forma Pauperis, and a 

Civil Complaint for filing. 

Should you have any questions or comment please contact me by email at mike-rivers@hotmail.com 

or at 860-234-3580. Thank you for your prompt attention. 

/f)e?.) 

~ vers 

Enclosures 

Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 15 of 16
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Case 1:20-cv-00107-MW-GRJ Document 1 Filed 05/11/20 Page 16 of 16