IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MALLORY GUILLAUME,

Plaintiff,

vs.

NEW HOPE MEDICAL GROUP LLC, 

a Florida Limited Liability Company, 

Defendant.

 /

COMPLAINT FOR DAMAGES

Plaintiff, MALLORY GUILLAUME, sues Defendant, NEW HOPE MEDICAL 

GROUP LLC, and shows:

Introduction

1. This is an action by MALLORY GUILLAUME against her former employer 

for unpaid overtime pursuant to the Fair Labor Standards Act. Plaintiff seeks damages and a 

reasonable attorney’s fee.

Jurisdiction

2. This action arises under the Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 

207. The Court has jurisdiction over the claims pursuant to 29 U.S.C. § 216(b).

3. The claim arose within the Southern District of Florida, which is where venue 

is proper.

Parties and General Allegations

4. Plaintiff, MALLORY GUILLAUME, (hereinafter “GUILLAUME”) a 

resident of Broward County, Florida, was at all times material, employed by NEW HOPE 

MEDICAL GROUP LLC as a medical assistant/front desk clerk for Defendant, was an 

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employee as defined by 29 U.S.C. § 203 (e), and during her employment with Defendant was 

engaged in commerce or in the production of goods for commerce within the meaning of 29 

U.S.C. § 207(a). To wit: GUILLAUME regularly and consistently used the phone and 

internet to communicate with out of state insurance companies, processed electronic 

transactions from patients for co-payments, and handled goods and materials that traveled in 

interstate commerce. 

5. Defendant, NEW HOPE MEDICAL GROUP LLC (hereinafter, “NEW 

HOPE”), is a Florida Limited Liability Company doing business in Broward County, Florida, 

and is an enterprise engaged in an industry affecting commerce, is an employer as defined by 

29 U.S.C. § 203(d) and (s)(1), in that it has employees engaged in commerce or in the 

production of goods for commerce, or that has employees handling, selling, or otherwise 

working on goods or materials that have been moved in or produced for commerce by any 

person; and it is an enterprise whose annual gross volume of sales made or business done is 

not less than $500,000 (exclusive of excise taxes at the retail level that are separately stated) 

which has employees subject to the provisions of the FLSA, 29 U.S.C. § 207, in the medical 

office where GUILLAUME was employed. At all times pertinent to this Complaint, NEW 

HOPE operates as an organization which sells and/or markets its services and/or goods to 

customers throughout the United States and also provides its services for goods sold and 

transported from across state lines of other states, and NEW HOPE obtains and solicits funds 

from non-Florida sources, accepts funds from non-Florida sources, uses telephonic 

transmissions going over state lines to do their business, transmit funds outside the State of 

Florida, and otherwise regularly engages in interstate commerce, particularly with respect to 

its employees.

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6. From February 14, 2022 through August 14, 2022, Defendant NEW HOPE has 

willfully violated the provisions of §7 of the Act [29 U.S.C. §207] by employing employees 

engaged in commerce for workweeks longer than 40 hours without compensating them for their 

employment in excess of 40 hours at rates not less than one and one-half times the regular rates 

at which they were employed: specifically GUILLAUME, since February 14, 2022, has worked 

in excess of 40 hours a week most weeks of her employment, and was not compensated for the 

work in excess of 40 hours at a rate not less than one and one-half times the regular rate at which 

she was employed.

7. The failure to pay overtime compensation to GUILLAUME is unlawful in that 

she was not exempted from the overtime provisions of the Act pursuant to the provisions of 29 

U.S.C. § 213(a), in that she neither was a bona fide executive, administrative or professional 

employee.

8. NEW HOPE’s actions were willful and purposeful as it was well aware of the 

Fair Labor Standards Act and GUILLAUME’ status as non-exempt, but chose not to pay her

in accordance with the Act.

9. GUILLAUME is entitled pursuant to 29 U.S.C. § 216(b), to recover from 

NEW HOPE:

a. All unpaid overtime that is due;

b. As liquidated damages, an amount equal to the unpaid overtime owed;

c. The costs of this action, and;

d. A reasonable attorney’s fee.

WHEREFORE, Plaintiff, MALLORY GUILLAUME, prays that this court will grant 

judgment against Defendant NEW HOPE MEDICAL GROUP LLC:

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a. awarding GUILLAUME payment of overtime compensation found by 

the court to be due to her under the Act; 

b. awarding GUILLAUME an additional equal amount as liquidated 

damages;

c. awarding GUILLAUME her costs, including a reasonable attorney’s fee; 

and

d. granting such other and further relief as is just.

Jury Demand

Plaintiff demands trial by jury.

Dated: September 13, 2022

Plantation, Florida

Respectfully submitted,

/s/Robert S. Norell

Robert S. Norell, Esq. (Fla. Bar No. 996777)

E-Mail: rob@floridawagelaw.com

ROBERT S. NORELL, P.A.

300 N.W. 70th Avenue

Suite 305

Plantation, Florida 33317

Telephone: (954) 617-6017

Facsimile: (954) 617-6018

Counsel for MALLORY GUILLAUME

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