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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

Case No.: ______________

JAHEL GONZALEZ, and other similarly 

situated individuals,

Plaintiff(s),

v.

1350 S DIXIE LLC d/b/a THESIS HOTEL 

MIAMI; NRI REAL TOKEN TENANT, 

LLC d/b/a THESIS HOTEL MIAMI; 

BRENT REYNOLDS, individually; LINK 

SERVICES CC CORP; and NASSIM N. 

CHAURIYE, SR., individually,

Defendants.

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COMPLAINT

(OPT-IN PURSUANT TO 29 U.S.C § 216(B))

Plaintiffs, JAHEL GONZALEZ (“Plaintiff”) and other similarly situated individuals, sue 

the Defendants, 1350 S DIXIE LLC d/b/a THesis Hotel Miami; NRI REAL TOKEN TENANT, 

LLC d/b/a THesis Hotel Miami; BRENT REYNOLDS, individually; LINK SERVICES CC 

CORP; and NASSIM N. CHAURIYE, SR., individually (collectively the “Defendants”) and 

allege:

JURISDICTION

1. This is an action to recover money damages for unpaid overtime wages under the 

laws of the United States. This Court has jurisdiction pursuant to the Fair Labor Standards Act, 29 

U.S.C. § 201-219 (Section 216 for jurisdictional placement) (“the Act”).

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VENUE

2. Plaintiff is a resident of Miami-Dade County, Florida, within the jurisdiction of this 

Honorable Court. Plaintiff is a covered employee for purposes of the Act.

3. 1350 S DIXIE LLC d/b/a THesis Hotel Miami; NRI REAL TOKEN TENANT, 

LLC d/b/a THesis Hotel Miami; LINK SERVICES CC CORP (the “Corporate Defendants”); 

BRENT REYNOLDS; and NASSIM N. CHAURIYE, SR. (the “Individual Defendants”), have

their main place of business in Miami-Dade County, Florida, where Plaintiff worked for 

Defendants, and at all times material hereto were and are engaged in interstate commerce. The 

Individual Defendants, upon information and belief, reside in Miami-Dade County, Florida.

4. Defendants 1350 S DIXIE LLC and NRI REAL TOKEN TENANT, LLC (the 

“THesis Defendants” share common ownership, common management, centralized control of 

labor relations, and common offices and interrelated operations. Both companies have Defendant 

BRENT REYNOLDS as one of their principal managers/directors/supervisors who controls how 

the companies are run and how and when employees are paid. 

5. THesis Defendants own and/or operate a hotel called the THesis Hotel Miami in 

Coral Gables, Florida. In addition, THesis Defendants supervise and control the work and the hours 

worked by employees who physically work at the THesis Hotel Miami in Coral Gables. Defendant 

BRENT REYNOLDS uses different corporate structures to supervise and control the THesis 

Defendants, but ultimately, he is one of the main persons involved in the decision making when it 

comes to running the THesis Hotel Miami and paying the employees who work there. 

6. THesis Defendants are an integrated enterprise under the law. Alternatively, each 

company is an enterprise under the law and each company is an agent of each other.

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7. LINK SERVICES CC CORP (the “Staffing Agency”) is a dissolved staffing 

company owned and operated by Defendant NASSIM N. CHAURIYE, SR. Staffing Agency 

provides employees to THesis Defendants to clean and maintain the THesis Hotel Miami in Coral 

Gables. Plaintiff was initially hired to work at the THesis Hotel Miami through the Staffing 

Agency, but then was hired directly to work for the owners/managers of THesis Hotel Miami.

8. The Corporate Defendants (THesis Defendants and the Staffing Agency) share 

employees or interchange employees; work in the direct interest of one another; and their 

employees are in the common control of these three defendants. The Corporate Defendants are 

joint employers. Alternatively, each company is an enterprise under the law and each company is 

an agent of each other. 

9. Each Corporate Defendant is sued individually, as a joint enterprise, as joint 

employers, and as agent of each other.

COUNT I: WAGE AND HOUR VIOLATION BY

THE CORPORATE DEFENDANTS

10. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-9

above as if set out in full herein. 

11. This action is brought by Plaintiff and those similarly situated to recover from the 

Corporate Defendants unpaid overtime compensation, as well as an additional amount as 

liquidated damages, costs, and reasonable attorneys’ fees under the provisions of 29 U.S.C. § 201 

et seq., and specifically under the provisions of 29 U.S.C. § 207. 29 U.S.C. § 207 (a)(1) states, “No 

employer shall employ any of his employees . . . for a work week longer than 40 hours unless such 

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employee receives compensation for his employment in excess of the hours above-specified at a 

rate not less than one and a half times the regular rate at which he is employed.”

12. Jurisdiction is conferred on this Court by Title 28 U.S.C. § 1337 and by Title 29 

U.S.C. § 216(b). The Corporate Defendants are and, at all times pertinent to this Complaint, were

engaged in interstate commerce. At all times pertinent to this Complaint, the Corporate Defendants

operate as organizations which sell and/or market their services and/or goods to customers from 

throughout the United States and also provide their services for goods sold and transported from 

across state lines of other states, and the Corporate Defendants obtain and solicit funds from nonFlorida sources, accept funds from non-Florida sources, use telephonic transmissions going over 

state lines to do their business, transmit funds outside the State of Florida, and otherwise regularly 

engage in interstate commerce, particularly with respect to their employees. 

13. Upon information and belief, the annual gross revenue of each one of the Corporate 

Defendants was at all times material hereto in excess of $500,000 per annum.

14. Alternatively, the combined annual gross revenue of all of the Corporate 

Defendants was at all times material hereto in excess of $500,000 per annum and/or Plaintiff and 

those similarly situated, by virtue of working in interstate commerce, otherwise satisfy the Act’s 

requirements. 

15. By reason of the foregoing, the Corporate Defendants are and were, during all times 

hereafter mentioned, enterprises engaged in commerce or in the production of goods for commerce 

as defined in §§ 3 (r) and 3(s) of the Act, 29 U.S.C. § 203(r) and 203(s) and/or Plaintiff and those 

similarly situated was and/or is engaged in interstate commerce for the Corporate Defendants. The 

Corporate Defendants’ business activities involve those to which the Act applies. The Corporate 

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Defendants are a hotel and their managing companies and a staffing company, respectively and, 

through their business activities, affect interstate commerce. 

16. The Plaintiff’s work for the Corporate Defendants likewise affects interstate 

commerce. Plaintiff was employed by the Corporate Defendants as a housekeeper for the 

Corporate Defendants’ business.

17. While employed by the Corporate Defendants, Plaintiff worked approximately an 

average of 72-84 hours per week without being compensated at the rate of not less than one- and 

one-half times the regular rate at which she was employed. Plaintiff was employed as a 

housekeeper performing the same or similar duties as that of those other similarly situated 

housekeepers whom Plaintiff observed working in excess of 40 hours per week without overtime 

compensation. 

18. Plaintiff worked for the Corporate Defendants from approximately January 2021 

through June 2021 and then from approximately December 2021 through March 22, 2022. In total, 

Plaintiff worked approximately 40 compensable weeks under the Act, or 40 compensable weeks 

if we count 3 years back from the filing of the instant action.

19. The Corporate Defendants paid Plaintiff on average approximately $13-$14 per 

hour. 

20. However, the Corporate Defendants did not properly compensate Plaintiff for hours 

that Plaintiff worked in excess of 40 per week.

21. Plaintiff seeks to recover unpaid overtime wages accumulated from the date of hire 

and/or from 3 (three) years back from the date of the filing of this Complaint.

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22. Prior to the completion of discovery and to the best of Plaintiff’s knowledge, at the 

time of the filing of this Complaint, Plaintiff’s good faith estimate of unpaid overtime wages is as 

follows:

a. Actual Damages: $22,400

b. Calculation: $14 (hourly pay) x .5 (overtime rate) x 80 (approximate number of 

overtime hours) x 40 (compensable weeks) = $22,400

c. Liquidated Damages: $22,400

d. Total Damages: $44,800 plus reasonable attorneys’ fees and costs of suit.

23. At all times material hereto, the Corporate Defendants failed to comply with Title 

29 U.S.C. §§ 201-219 and 29 C.F.R. § 516.2 and § 516.4 et seq. in that Plaintiff and those similarly

situated performed services and worked in excess of the maximum hours provided by the Act but 

no provision was made by the Corporate Defendants to properly pay them at the rate of time and 

one half for all hours worked in excess of forty hours (40) per workweek as provided in the Act. 

The additional persons who may become Plaintiffs in this action are weekly-paid employees and/or 

former employees of the Corporate Defendants who are and who were subject to the unlawful 

payroll practices and procedures of the Corporate Defendants and were not paid time and one half 

of their regular rate of pay for all overtime hours worked in excess of forty. 

24. The Corporate Defendants knew and/or showed reckless disregard of the provisions 

of the Act concerning the payment of overtime wages and remains owing Plaintiff and those 

similarly situated these overtime wages since the commencement of Plaintiff’s and those similarly

situated employees’ employment with the Corporate Defendants as set forth above, and Plaintiff

and those similarly situated are entitled to recover double damages. The Corporate Defendants

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never posted any notice, as required by Federal Law, to inform employees of their federal rights 

to overtime and minimum wage payments. 

25. The Corporate Defendants willfully and intentionally refused to pay Plaintiff 

overtime wages as required by the laws of the United States as set forth above and remains owing 

Plaintiff these overtime wages since the commencement of Plaintiff’s employment with the 

Corporate Defendants as set forth above.

26. Plaintiff has retained the law offices of the undersigned attorney to represent her in 

this action and is obligated to pay a reasonable attorneys’ fee.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff and those similarly situated request that this Honorable Court: 

A. Enter judgment for Plaintiff and others similarly situated and against the Corporate 

Defendant on the basis of the Corporate Defendant’s willful violations of the Fair Labor 

Standards Act, 29 U.S.C. § 201 et seq. and other Federal Regulations; and

B. Award Plaintiff actual damages in the amount shown to be due for unpaid wages and 

overtime compensation for hours worked in excess of forty weekly; and

C. Award Plaintiff an equal amount in double damages/liquidated damages; and

D. Award Plaintiff reasonable attorneys’ fees and costs of suit; and 

E. Grant such other and further relief as this Court deems equitable and just. 

COUNT II: WAGE AND HOUR VIOLATION BY

BRENT REYNOLDS (OVERTIME)

27. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-26

above as if set out in full herein.

28. At the times mentioned, Brent Reynolds (“Reynolds”) was, and is now, the owner 

and/or main officer of the THesis Defendants. Reynolds was an employer of Plaintiff and others 

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similarly situated within the meaning of Section 3(d) of the Act [29 U.S.C. § 203(d)], in that this 

defendant acted directly or indirectly in the interests of the THesis Defendants in relation to the 

employees of the THesis Defendants, including Plaintiff and others similarly situated. Reynolds

had operational control of the THesis Defendants, was involved in the day-to-day functions of the 

THesis Defendants, managed and supervised Plaintiff’s work schedule, and is jointly liable for

Plaintiff’s damages.

29. Reynolds is and was at all times relevant a person in control of THesis Defendants’ 

financial affairs and can cause the THesis Defendants to compensate (or not to compensate) their 

employees in accordance with the Act.

30. Reynolds willfully and intentionally caused Plaintiff not to receive overtime 

compensation as required by the laws of the United States as set forth above and remains owing 

Plaintiff these overtime wages since the commencement of Plaintiff’s employment with the THesis 

Defendants as set forth above. 

31. Plaintiff has retained the law offices of the undersigned attorney to represent her in 

this action and is obligated to pay a reasonable attorneys’ fee.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff and those similarly situated request that this Honorable Court: 

A. Enter judgment for Plaintiff and others similarly situated and against Reynolds on the 

basis of the Defendants’ willful violations of the Fair Labor Standards Act, 29 U.S.C. 

§ 201 et seq. and other Federal Regulations; and

B. Award Plaintiff actual damages in the amount shown to be due for unpaid wages and 

overtime compensation for hours worked in excess of forty weekly; and

C. Award Plaintiff an equal amount in double damages/liquidated damages; and

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D. Award Plaintiff reasonable attorneys’ fees and costs of suit; and 

E. Grant such other and further relief as this Court deems equitable and just. 

COUNT III: WAGE AND HOUR VIOLATION BY

NASSIM N. CHAURIYE, SR. (OVERTIME)

32. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-26 

above as if set out in full herein.

33. At the times mentioned, Nassim N. Chauriye, Sr. (“Chauriye”) was, and is now, the 

owner and/or main officer of the Staffing Agency. Chauriye was an employer of Plaintiff and 

others similarly situated within the meaning of Section 3(d) of the Act [29 U.S.C. § 203(d)], in 

that this defendant acted directly or indirectly in the interests of the Staffing Agency in relation to 

the employees of the Staffing Agency, including Plaintiff and others similarly situated. Chauriye

had operational control of the Staffing Agency, was involved in the day-to-day functions of the 

Staffing Agency, managed and supervised Plaintiff’s work schedule, and is jointly liable for 

Plaintiff’s damages.

34. Chauriye is and was at all times relevant a person in control of Staffing Agency’s 

financial affairs and can cause the Staffing Agency to compensate (or not to compensate) its 

employees in accordance with the Act.

35. Chauriye willfully and intentionally caused Plaintiff not to receive overtime 

compensation as required by the laws of the United States as set forth above and remains owing 

Plaintiff these overtime wages since the commencement of Plaintiff’s employment with the 

Staffing Agency as set forth above. 

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36. Plaintiff has retained the law offices of the undersigned attorney to represent her in 

this action and is obligated to pay a reasonable attorneys’ fee.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff and those similarly situated request that this Honorable Court: 

A. Enter judgment for Plaintiff and others similarly situated and against Chauriye on the 

basis of the Defendants’ willful violations of the Fair Labor Standards Act, 29 U.S.C. 

§ 201 et seq. and other Federal Regulations; and

B. Award Plaintiff actual damages in the amount shown to be due for unpaid wages and 

overtime compensation for hours worked in excess of forty weekly; and

C. Award Plaintiff an equal amount in double damages/liquidated damages; and

D. Award Plaintiff reasonable attorneys’ fees and costs of suit; and 

E. Grant such other and further relief as this Court deems equitable and just. 

Dated: August 26, 2022.

Respectfully submitted,

By:__/s/ Julisse Jimenez

Julisse Jimenez, Esquire

 Fla. Bar No.: 65387

 Email: julisse@saenzanderson.com

R. Martin Saenz, Esquire

Fla. Bar No.: 0640166

Email: msaenz@saenzanderson.com

SAENZ & ANDERSON, PLLC

20900 NE 30th Avenue, Ste. 800

Aventura, Florida 33180

Telephone: (305) 503-5131

Facsimile: (888) 270-5549

Counsel for Plaintiff

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