UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

GAINESVILLE DIVISION

RYAN NORMAN, 

 

Plaintiff,

vs. CASE NO.: 

POWER PRODUCTION MANAGEMENT INC., 

POWER PRODUCTION MANAGEMENT HOLDINGS, INC.,

FRANKCRUM 5 INC, and

5Z005-FRANKCRUM 5 INC,

Defendants.

_______________________________________/

COMPLAINT

Plaintiff, RYAN NORMAN, by and through his undersigned counsel, sues the Defendants, 

FRANKCRUM 5 INC, 5Z005-FRANKCRUM 5 INC, POWER PRODUCTION MANAGEMENT 

INC., and POWER PRODUCTION MANAGEMENT HOLDINGS, INC., (collectively referred to 

as “Defendants”) and alleges as follows:

JURISDICTION AND VENUE

1. Jurisdiction of this Court is invoked pursuant to the Fair Labor Standards Act of 1938, 

as amended, 29 U.S.C. § 201, et seq.

2. Venue lies within United States District Court for the Middle District of Florida, Tampa 

Division because a substantial part of the events giving rise to this claim occurred in this Judicial 

District and is therefore proper pursuant to 28 U.S.C. 1391(b).

PARTIES

3. Plaintiff, RYAN NORMAN, is a resident of Kissimmee, Osceola County, Florida at 

all times material and worked for Defendant in this Juridical District during the applicable statute of 

limitations.

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4. Defendant, FRANKCRUM 5 INC, is a corporation, authorized and doing business in 

this Judicial District.

5. Defendant, 5Z005-FRANKCRUM 5 INC, is a corporation, authorized and doing 

business in this Judicial District.

6. Defendant, POWER PRODUCTION MANAGEMENT INC., is a Florida Profit 

Corporation, authorized and doing business in this Judicial District.

7. Defendant, POWER PRODUCTION MANAGEMENT HOLDINGS, INC., is a 

Florida Profit Corporation, authorized and doing business in this Judicial District.

8. Defendants are joint employers and/or an integrated enterprise/single employer.

9. Defendants are an enterprise engaged in commerce as defined by 29 U.S.C. §

203(s)(l)(A).

10. Plaintiff was an employee of Defendants pursuant to 29 U.S.C. § 203(e)(l), 

Defendants were Plaintiff's employer within the meaning of 29 U.S.C. § 203(d), and Defendants

employed Plaintiff within the meaning of 29 U.S.C. § 203(g).

FACTUAL ALLEGATIONS

11. Plaintiff, RYAN NORMAN, was employed with Defendants from approximately 

February 2012 to June 6, 2018 as a Lead Installer/Electrician and Quality Control earning 

approximately $25.00 per hour and working 60 + hours per week.

12. As Lead Installer/Electrician and Quality Control, Plaintiff worked in excess of 40 

hours per work week for which he was not compensated by Defendants at a rate of time and one half 

his regular hourly rate. 

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COUNT I

(Fair Labor Standard Act - Overtime)

13. Plaintiff realleges paragraphs 1 through 12 as though set forth fully herein.

14. The employment of Plaintiff provided for a forty (40) hour work week but throughout 

his respective employment Plaintiff was required to work and did work a substantial number of 

hours in excess of forty (40) hours per work week.

15. At all times material, Defendants failed to comply with 29 U.S.C. § 201 et seq., in

that Plaintiff worked for Defendants in excess of the maximum hours provided by law, but no 

provision was made by Defendants to compensate Plaintiff at the rate of time and one-half his 

regular rate of pay for the hours worked over forty (40) in a work week.

16. Defendants’ failure to pay Plaintiff the required overtime pay was intentional and

willful.

17. As a direct and legal consequence of Defendants’ unlawful acts, Plaintiff has suffered 

damages and has incurred, or will incur, costs and attorneys' fees in the prosecution of this matter.

WHEREFORE, Plaintiff, RYAN NORMAN, respectfully request all legal and equitable 

relief allowed by law including judgment against Defendants, FRANKCRUM 5 INC, 5Z005-

FRANKCRUM 5 INC, POWER PRODUCTION MANAGEMENT INC. and POWER 

PRODUCTION MANAGEMENT HOLDINGS, INC., for overtime compensation, liquidated 

damages, prejudgment interest; payment of reasonable attorneys' fees and costs incurred in the 

prosecution of this claim and equitable relief declaring and mandating the cessation of Defendants’

unlawful pay policy and such other relief as the court may deem just and proper.

DEMAND FOR JURY TRIAL

23. Plaintiff requests a jury trial on all issues so triable.

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Dated this 15th day of May, 2020.

FLORIN GRAY BOUZAS OWENS, LLC

/s/ Wolfgang M. Florin

WOLFGANG M. FLORIN, ESQUIRE

Florida Bar No.: 907804 

wolfgang@fgbolaw.com

gina@fgbolaw.com

16524 Pointe Village Drive, Suite 100

Lutz, FL 33558

Telephone (727) 254-5255

Facsimile (727) 483-7942 

Attorney for Plaintiff

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