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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 

AMILCAR AMBIELA,

 Plaintiff,

vs.

ROKO INVESTMENTS 2 LLC, a Florida

Limited Liability Corporation,

ROKO INVESTMENTS LLC, a Florida

Limited Liability Corporation d/b/a

OLENKA ARTISAN BAKERY,

OSCAR PRIETO, Individually, 

OLENKA RIGLOS, Individually

 Defendants.

________________________________________/

COMPLAINT

Plaintiff AMILCAR AMBIELA (hereinafter “Plaintiff”) by and through his undersigned 

attorney, hereby sues Defendants ROKO INVESTMENTS 2 LLC, a Florida Limited Liability 

Company (hereinafter "ROKO INVESTMENTS 2”) and ROKO INVESTMENTS LLC, a Florida 

Limited Liability Company d/b/a OLENKA ARTISAN BAKERY (hereinafter “OLENKA 

ARTISAN BAKERY”) OSCAR PRIETO, individually (hereinafter “PRIETO”) and OLENKA 

RIGLOS, individually (hereinafter “RIGLOS”) (collectively “Defendants”) and states as follows:

JURISDICTION AND VENUE

1. This is an action for damages and other relief for unpaid wages and unpaid overtime 

committed by Defendants pursuant to the Fair Labor Standards Act, 29 U.S.C. §§ 201, et seq. 

(hereinafter the “Fair Labor Standards Act”, the “FLSA” or the “Act”).

2. Jurisdiction is conferred upon this Court pursuant to 29 U.S.C. § 216(b), 28 U.S.C. § 1331, 

and 28 U.S.C. § 1367.

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3. Venue is proper for the United States Court for the Southern District of Florida because 

Plaintiff was employed in the Southern District of Florida by Defendants, which at all material 

times conducted, and continues to conduct, business in the Southern District of Florida, and 

because the acts that give rise to Plaintiff’s claims occurred within the Southern District of 

Florida and because Defendants are subject to personal jurisdiction there.

4. Plaintiff at all times pertinent to this complaint resided within the Southern District of Florida. 

Plaintiff is over the age of eighteen and otherwise sui juris. 

PARTIES

5. During all times relevant to this Complaint, Plaintiff was employed by Defendants. 

Specifically, Plaintiff performed work for Defendants from on or about January 1, 2022, until 

on or about June 29, 2022, as a cook. Plaintiff was therefore an employee as defined by 29 

U.S.C. § 203(e).

6. ROKO INVESTMENTS 2 is a Florida limited liability company organized and existing under 

and by virtue of the laws of Florida and was registered to do business within Florida. ROKO 

INVESTMENTS 2 has its principal place of business in Weston, Florida. ROKO 

INVESTMENTS 2 had, at all times material hereto, conducted substantial and continuous 

business within the Southern District of Florida, and is subject to the laws of the United States 

and the State of Florida.

7. ROKO INVESTMENTS 2 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.

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8. At all times material to this Complaint, ROKO INVESTMENTS 2 has had two (2) or more 

employees who have regularly sold, handled, or otherwise worked on goods and/or material 

that have been moved in or produced for commerce.

9. Specifically, ROKO INVESTMENTS 2 owns and operates the warehouse where some of the 

goods that are sold at OLENKA ARTISAN BAKERY are prepared. These goods are prepared 

using goods and materials that have been moved in or produced for commerce by any person. 

10. OLENKA ARTISAN BAKERY is a Florida Limited Liability Company organized and 

existing under and by virtue of the laws of Florida and was registered to do business within 

Florida. OLENKA ARTISAN BAKERY has its principal place of business in Weston, 

Florida. OLENKA ARTISAN BAKERY had, at all times material hereto, conducted 

substantial and continuous business within the Southern District of Florida, and is subject to 

the laws of the United States and the State of Florida.

11. OLENKA ARTISAN BAKERY 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.

12. Specifically, OLENKA ARTISAN BAKERY owns and operates a bakery located at 2246 

Weston Road, Weston FL 33326. OLENKA ARTISAN BAKERY which uses goods or 

materials that have been moved in or produced for commerce by any person to prepare its 

products. 

13. At all times material to this Complaint, OLENKA ARTISAN BAKERY has had two (2) or 

more employees who have regularly sold, handled, or otherwise worked on goods and/or 

material that have been moved in or produced for commerce. 

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14. At all material times hereto, Defendants ROKO INVESTMENTS 2 and OLENKA ARTISAN 

BAKERY were joint “employers” of Plaintiff as that term is defined under 29 U.S.C. § 203(d) 

in that

a. Both companies share the same principal place of business;

b. Both companies share the same mailing address;

c. Both companies share the same corporate officers; 

15. OLENKA ARTISAN BAKERY and ROKO INVESTMENTS 2 upon knowledge and belief, 

separately and/or in combination have had gross revenue which exceeds $500,000 for each of 

the past three (3) years and utilizes goods in the flow of commerce across state lines.

16. Defendant PRIETO is the owner and manager and exercised operational control over the 

activities of, corporate Defendants, ROKO INVESTMENTS 2 and OLENKA ARTISAN 

BAKERY.

17. Defendant PRIETO, acted directly in the interest of his companies, ROKO INVESTMENTS 

2 and OLENKA ARTISAN BAKERY. Upon all available information, PRIETO, controlled 

the manner in which Plaintiff performed his work, and the pay he was to receive. 

18. Defendant RIGLOS, is the owner and manager and exercised operational control over the 

activities of, corporate Defendants, ROKO INVESTMENTS 2 and OLENKA ARTISAN 

BAKERY.

19. Defendant RIGLOS, acted directly in the interest of her companies, ROKO INVESTMENTS 

2 and OLENKA ARTISAN BAKERY. Upon all available information, RIGLOS, controlled 

the manner in which Plaintiff performed his work, and the pay he was to receive. 

20. All Defendants were “employers” of Plaintiff as the term is defined under 29 U.S.C. § 203(d). 

21. All other conditions precedent to this action have been performed or have been waived. 

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GENERAL ALLEGATIONS COMMON TO ALL COUNTS

22. Plaintiff is a non-exempt employee of Defendants and is subject to the payroll practices and 

procedures set forth hereinafter, and who worked more than forty (40) hours during one of 

more workweeks within three (3) years of the filing of this complaint.

23. Plaintiff began working for Defendants on or about January 1, 2022, through June 29, 2022, 

as a cook. His primary duties were unloading merchandise when it arrived, cooking, baking, 

and cleaning dishes. Plaintiff did not have independent decision-making authority. 

24. During the course of his employment, Plaintiff regularly worked six (6) days a week for about 

seven (7) to ten (10) hours a day. Per the parties’ agreement, Plaintiff was paid a salary of 

$1,000 a week regardless of the hours worked.

25. The Defendants established a weekly pay period, such that the employees were supposed to 

get paid once a week for the seven (7) day period ending immediately preceding. However, the 

wages due on the regularly established pay day began to arrive late and were provided 

piecemeal, such that the amounts due would be paid only in part, late, or not at all.

26. As a result, Defendants failed to compensate Plaintiff at a rate higher or equal to Florida and 

federal minimum wage for some of the work performed by Plaintiff during the relevant period. 

27. Furthermore, at all times pertinent to this action, Defendants failed to comply with 29 U.S.C. 

§§ 201 – 219 in that Plaintiff performed services for Defendants for which no provision was 

made to properly pay for those hours worked over forty (40) in a given workweek.

28. Defendants and their representatives knew that Plaintiff was working overtime, and that federal 

law requires employees to be compensated at time and one-half per hour for overtime pay.

29. Defendants maintained complete control over the hours Plaintiff worked and the pay he was 

to receive. 

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30. Plaintiff has retained the undersigned firm to prosecute this action on his behalf and has agreed 

to pay it a reasonable fee for its services.

31. Plaintiff is entitled to his reasonable attorneys’ fees and costs if he is the prevailing party in 

this action.

COUNT I

VIOLATION OF FLSA/MINIMUM WAGES against ROKO INVESTMENTS 2

32. Plaintiff re-alleges and reaffirms paragraphs 1 through 31 as fully set forth herein.

33. This action is brought by Plaintiff to recover from Defendant ROKO INVESTMENTS 2

unpaid minimum wage compensation, as well as an additional amount as liquidated damages, 

costs, and reasonable attorney’s fees under the provisions of 29 U.S.C. § 201 et seq., 29 U.S.C. 

§ 206.

34. At all times during his employment, the Plaintiff was an employee required to be paid a 

minimum hourly wage for every hour worked and entitled to receive those minimum hourly 

wages not later than the regularly established pay day. 

35. ROKO INVESTMENTS 2 has violated the provisions of the FLSA, 29 U.S.C. § 206 and § 

215(a)(2) by failing to timely pay the Plaintiff at least a minimum hourly wage on the regularly 

scheduled pay date when wages were due for some of the hours he worked as alleged above.

36. ROKO INVESTMENTS 2, knew or showed a reckless disregard for the provisions of the 

FLSA concerning the timely payment of wages for all hours worked in respective pay periods 

and accordingly remains owing the named Plaintiff, liquidated damages, based upon the unpaid 

minimum wages for the failure to pay even the required minimum hourly wage for every hour 

worked during each respective pay period during the three-year period preceding this lawsuit.

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37. The Plaintiff incurred expenses and endured considerable hardships and damages as a result of 

being deprived of a minimum hourly wage when due as alleged.

38. By reason of the said intentional, willful and unlawful acts of ROKO INVESTMENTS 2, 

Plaintiff has suffered damages plus incurring costs and reasonable attorneys' fees.

39. Plaintiff seeks to recover for unpaid wages accumulated from the date of hire.

40. ROKO INVESTMENTS 2 never posted any notice, as required by the Act and federal law, to 

inform employees of their federal rights to overtime and minimum wage payments.

41. As a result, ROKO INVESTMENTS 2’s willful violations of the Act, Plaintiff is entitled to 

liquidated damages.

42. Plaintiff has retained the undersigned counsel to represent him in this action, and pursuant to 

29 U.S.C. § 216(b), Plaintiff is entitled to recover all reasonable attorneys' fees and costs 

incurred in this action from ROKO INVESTMENTS 2.

WHEREFORE, Plaintiff respectfully prays for the following relief against ROKO 

INVESTMENTS 2:

A. Adjudge and decree that Defendant has violated the FLSA and has done so willfully, 

intentionally and with reckless disregard for Plaintiff’s rights;

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

wage, with interest; and

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

D. Award Plaintiff the costs of this action, together with a reasonable attorneys’ fees; and

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

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COUNT II

VIOLATION OF FLSA/OVERTIME against ROKO INVESTMENTS 2

43. Plaintiff, re-alleges and reaffirms paragraphs 1 through 31 as if fully set forth herein.

44. This action is brought by Plaintiff to recover from Defendant ROKO INVESTMENTS 2 

unpaid overtime compensation, as well as an additional amount as liquidated damages, costs, 

and reasonable attorney’s fees under the provisions of 29 U.S.C. § 201 et seq., 29 U.S.C. § 207 

(a)(1) states “[n]o employer shall employ any of his employees... for a work week longer than 

40 hours unless such 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.”

45. Since the commencement of Plaintiff’s employment, ROKO INVESTMENTS 2 has willfully 

violated the provisions of § 7 of the FLSA [29 U.S.C. § 207] by having employees working 

for longer than forty (40) hours without properly compensating them for all hours overtime

hours at a rate not less than one- and one-half times their regular rate.

46. Specifically, throughout his employment Plaintiff regularly worked over forty (40) hours 

during some of the workweeks in which he was employed. However, his pay was always the 

same regardless of the hours he worked. 

47. ROKO INVESTMENTS 2 is and was, during all times hereafter mentioned, an enterprise 

engaged in commerce or in the production of goods for commerce as defined in §§ 3 (r) and 

3(s) of the FLSA, 29 U.S.C. § 203(r) and 203(s). ROKO INVESTMENTS 2’s business 

activities involve those to which the Fair Labor Standards Act applies. 

48. Specifically, ROKO INVESTMENTS 2 was, during all times hereafter mentioned, an 

enterprise engaged in commerce or in the production of goods for commerce as defined in §§ 

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3 (r) and 3(s) of the FLSA, 29 U.S.C. § 203(r) and 203(s). ROKO INVESTMENTS 2’s 

business activities involve those to which the Fair Labor Standards Act applies. 

49. Plaintiff was not exempted from the overtime provision of the Act pursuant to the provisions 

of the Act, 29 U.S.C. § 213(a), in that he was neither a bona fide executive, administrative, or 

professional employee. Plaintiff performed duties such as cooking food and pastries, unloading 

merchandise, washing the dishes, and did not have decision-making authority.

50. ROKO INVESTMENTS 2 has knowingly and willfully failed to pay Plaintiff at time and one 

half of his regular rate of pay for all hours worked in excess of forty (40) per week between 

the relevant time period.

51. By reason of the said intentional, willful, and unlawful acts of ROKO INVESTMENTS 2, 

Plaintiff has suffered damages plus incurring costs and reasonable attorneys' fees.

52. Plaintiff seeks to recover for unpaid wages accumulated within three (3) years of the filing of 

this complaint.

53. As a result of ROKO INVESTMENTS 2’s willful violations of the Act, Plaintiff is entitled to 

liquidated damages.

54. Plaintiff has retained the undersigned counsel to represent he in this action, and pursuant to 

29 U.S.C. § 216(b), Plaintiff is entitled to recover all reasonable attorneys' fees and costs 

incurred in this action from ROKO INVESTMENTS 2.

WHEREFORE, Plaintiff respectfully prays for the following relief against ROKO 

INVESTMENTS 2:

A. Adjudge and decree that Defendant has violated the FLSA and has done so willfully, 

intentionally and with reckless disregard for Plaintiff’s rights;

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B. Award Plaintiff actual damages in the amount shown to be due for overtime 

compensation for hours worked in excess of forty (40) weekly, with interest; and

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

D. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT III

VIOLATION OF FLSA/MINIMUM WAGES against OLENKA ARTISAN BAKERY

55. Plaintiff re-alleges and reaffirms paragraphs 1 through 31 as fully set forth herein.

56. This action is brought by Plaintiff to recover from Defendant OLENKA ARTISAN BAKERY 

unpaid minimum wage compensation, as well as an additional amount as liquidated damages, 

costs, and reasonable attorney’s fees under the provisions of 29 U.S.C. § 201 et seq., 29 U.S.C. 

§ 206.

57. At all times during his employment, the Plaintiff was an employee required to be paid a 

minimum hourly wage for every hour worked and entitled to receive those minimum hourly 

wages not later than the regularly established pay day. 

58. OLENKA ARTISAN BAKERY has violated the provisions of the FLSA, 29 U.S.C. § 206 and 

§ 215(a)(2) by failing to timely pay the Plaintiff at least a minimum hourly wage on the 

regularly scheduled pay date when wages were due.

59. OLENKA ARTISAN BAKERY knew or showed a reckless disregard for the provisions of the 

FLSA concerning the timely payment of wages for all hours worked in respective pay periods 

and accordingly remains owing the named Plaintiff, liquidated damages, based upon the unpaid 

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minimum wages for the failure to pay even the required minimum hourly wage for every hour 

worked during each respective pay period during the three-year period preceding this lawsuit.

60. The Plaintiff incurred expenses and endured considerable hardships and damages as a result of 

being deprived of a minimum hourly wage when due as alleged.

61. By reason of the said intentional, willful and unlawful acts of OLENKA ARTISAN BAKERY, 

Plaintiff has suffered damages plus incurring costs and reasonable attorneys' fees.

62. Plaintiff seeks to recover for unpaid wages accumulated from the date of hire.

63. OLENKA ARTISAN BAKERY never posted any notice, as required by the Fair Labor 

Standards Act and federal law, to inform employees of their federal rights to overtime and 

minimum wage payments.

64. As a result, OLENKA ARTISAN BAKERY willful violations of the Act, Plaintiff is entitled 

to liquidated damages.

65. Plaintiff has retained the undersigned counsel to represent him in this action, and pursuant to 

29 U.S.C. § 216(b), Plaintiff is entitled to recover all reasonable attorneys' fees and costs 

incurred in this action from OLENKA ARTISAN BAKERY.

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant:

A. Adjudge and decree that Defendant has violated the FLSA and has done so willfully, 

intentionally and with reckless disregard for Plaintiff’s rights;

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

wage, with interest; and

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

D. Award Plaintiff the costs of this action, together with a reasonable attorneys’ fees; and

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E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT IV

VIOLATION OF FLSA/OVERTIME against OLENKA ARTISAN BAKERY

66. Plaintiff, re-alleges and reaffirms paragraphs 1 through 31 as if fully set forth herein.

67. This action is brought by Plaintiff to recover from Defendant OLENKA ARTISAN BAKERY

unpaid overtime compensation, as well as an additional amount as liquidated damages, costs, 

and reasonable attorney’s fees under the provisions of 29 U.S.C. § 201 et seq., 29 U.S.C. § 207 

(a)(1) states “[n]o employer shall employ any of his employees... for a work week longer than 

40 hours unless such 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.”

68. Since the commencement of Plaintiff’s employment OLENKA ARTISAN BAKERY has 

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

working for longer than forty (40) hours without properly compensating them for all overtime 

hours at a rate not less than one- and one-half times their regular rate.

69. Specifically, throughout his employment Plaintiff regularly worked over forty (40) hours 

during some of the workweeks in which he was employed. However, the wages Plaintiff 

received was always the same regardless of the hours he worked. 

70. OLENKA ARTISAN BAKERY is and was, during all times hereafter mentioned, an enterprise 

engaged in commerce or in the production of goods for commerce as defined in §§ 3 (r) and 

3(s) of the FLSA, 29 U.S.C. § 203(r) and 203(s). OLENKA ARTISAN BAKERY’s business 

activities involve those to which the Fair Labor Standards Act applies. 

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71. Specifically, OLENKA ARTISAN BAKERY was, during all times hereafter mentioned, an 

enterprise engaged in commerce or in the production of goods for commerce as defined in §§ 

3 (r) and 3(s) of the FLSA, 29 U.S.C. § 203(r) and 203(s). OLENKA ARTISAN BAKERY’s 

business activities involve those to which the Fair Labor Standards Act applies. 

72. Plaintiff was not exempted from the overtime provision of the Act pursuant to the provisions 

of the Act, 29 U.S.C. § 213(a), in that he was neither a bona fide executive, administrative, or 

professional employee. Plaintiff performed duties such as cooking and washing the dishes and

did not have decision-making authority.

73. OLENKA ARTISAN BAKERY has knowingly and willfully failed to pay Plaintiff at time and 

one half of his regular rate of pay for all hours worked in excess of forty (40) per week between 

the relevant time period.

74. By reason of the said intentional, willful, and unlawful acts of OLENKA ARTISAN 

BAKERY, Plaintiff has suffered damages plus incurring costs and reasonable attorneys' fees.

75. Plaintiff seeks to recover for unpaid wages accumulated within three (3) years of the filing of 

this complaint.

76. As a result of OLENKA ARTISAN BAKERY’s willful violations of the Act, Plaintiff is 

entitled to liquidated damages.

77. Plaintiff has retained the undersigned counsel to represent he in this action, and pursuant to 

29 U.S.C. § 216(b), Plaintiff is entitled to recover all reasonable attorneys' fees and costs 

incurred in this action from OLENKA ARTISAN BAKERY.

WHEREFORE, Plaintiff respectfully prays for the following relief against OLENKA ARTISAN 

BAKERY:

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A. Adjudge and decree that Defendant has violated the FLSA and has done so willfully, 

intentionally and with reckless disregard for Plaintiff’s rights;

B. Award Plaintiff actual damages in the amount shown to be due for overtime 

compensation for hours worked in excess of forty (40) weekly, with interest; and

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

D. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT V

VIOLATION OF FLSA/MIMIMUM WAGES against PRIETO

78. Plaintiff, re-alleges and reaffirms paragraphs 1 through 31 as if fully set forth herein.

79. At the times mentioned, Defendant PRIETO was, and is now, a corporate officer and manager 

of corporate Defendants ROKO INVESTMENTS 2 and OLENKA ARTISAN BAKERY. 

80. PRIETO was an employer of Plaintiff within the meaning of Section 3(d) of the “Fair Labor 

Standards Act” [29 U.S.C. § 203(d)], in that he acted directly in the interests of Defendants 

ROKO INVESTMENTS 2 and OLENKA ARTISAN BAKERY.

81. Specifically, PRIETO supervised Plaintiff, determined company payroll decisions, and 

maintained the right to hire and fire Plaintiff during all pertinent times hereto. 

82. Defendant PRIETO is the manager and owner, and exercised operational control over the 

activities of, corporate Defendants ROKO INVESTMENTS 2 and OLENKA ARTISAN 

BAKERY.

83. PRIETO had operational control of the businesses and is thus jointly liable for Plaintiff’s 

damages.

84. Defendant PRIETO willfully and intentionally refused to properly pay Plaintiff at least 

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minimum wages for each hour worked as required by the law of the United States as set forth 

above and remains owing Plaintiff these wages since the commencement of Plaintiff’s 

employment with Defendants as set forth above. 

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant PRIETO: 

A. Adjudge and decree that Defendant PRIETO has violated the FLSA and has done so 

willfully, intentionally and with reckless disregard for Plaintiff’s rights;

B. Award Plaintiff actual damages in the amount shown to be due for unpaid minimum wage, 

with interest; and

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

D. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT VI

VIOLATION OF FLSA/OVERTIME against PRIETO

85. Plaintiff, re-alleges and reaffirms paragraphs 1 through 31 as if fully set forth herein.

86. At the times mentioned, Defendant PRIETO was, and is now, a corporate officer and manager 

of corporate Defendants, ROKO INVESTMENTS 2 and OLENKA ARTISAN BAKERY.

87. PRIETO was an employer of Plaintiff within the meaning of Section 3(d) of the Fair Labor 

Standards Act [29 U.S.C. § 203(d)], in that PRIETO acted directly in the interests of

INVESTMENTS 2 and OLENKA ARTISAN BAKERY in relation to its employees including 

Plaintiff. 

88. Specifically, PRIETO is the owner of the corporations, and the individual who hired the 

Plaintiff. PRIETO supervised Plaintiff, determined company payroll decisions, and maintained 

the right to hire and fire Plaintiff during all pertinent times hereto. 

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89. PRIETO had operational control of the businesses and is thus jointly liable for Plaintiff’s 

damages.

90. Defendant PRIETO willfully and intentionally refused to properly pay Plaintiff overtime 

wages as required by the law of the United States as set forth above and remains owing Plaintiff 

these wages since the commencement of Plaintiff’s employment with Defendants as set forth 

above. 

91. By reason of the said intentional, willful and unlawful acts of PRIETO, Plaintiff has suffered 

damages plus incurring costs and reasonable attorneys' fees.

92. As a result of PRIETO’S willful violations of the Act, Plaintiff is entitled to liquidated 

damages.

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant PRIETO: 

A. Adjudge and decree that PRIETO has violated the FLSA and has done so willfully, 

intentionally and with reckless disregard for Plaintiff’s rights;

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

compensation for hours worked in excess of forty (40) weekly, with interest; and

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

D. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT VII

VIOLATION OF FLSA/MIMIMUM WAGES against RIGLOS

93. Plaintiff, re-alleges and reaffirms paragraphs 1 through 31 as if fully set forth herein.

94. At the times mentioned, Defendant RIGLOS was, and is now, a corporate officer and manager 

of corporate Defendants ROKO INVESTMENTS 2 and OLENKA ARTISAN BAKERY. 

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95. RIGLOS was an employer of Plaintiff within the meaning of Section 3(d) of the “Fair Labor 

Standards Act” [29 U.S.C. § 203(d)], in that he acted directly in the interests of Defendants 

ROKO INVESTMENTS 2 and OLENKA ARTISAN BAKERY.

96. Specifically, RIGLOS supervised Plaintiff, determined company payroll decisions, and 

maintained the right to hire and fire Plaintiff during all pertinent times hereto. 

97. Defendant RIGLOS is the manager and owner, and exercised operational control over the 

activities of, corporate Defendants ROKO INVESTMENTS 2 and OLENKA ARTISAN 

BAKERY.

98. RIGLOS had operational control of the businesses and is thus jointly liable for Plaintiff’s 

damages.

99. Defendant RIGLOS willfully and intentionally refused to properly pay Plaintiff at least 

minimum wages for each hour worked as required by the law of the United States as set forth 

above and remains owing Plaintiff these wages since the commencement of Plaintiff’s 

employment with Defendants as set forth above. 

COUNT VIII

VIOLATION OF FLSA/OVERTIME against RIGLOS

100. Plaintiff, re-alleges and reaffirms paragraphs 1 through 31 as if fully set forth herein.

101. At the times mentioned, Defendant RIGLOS was, and is now, a corporate officer and 

manager of corporate Defendants, ROKO INVESTMENTS 2 and OLENKA ARTISAN 

BAKERY.

102. RIGLOS was an employer of Plaintiff within the meaning of Section 3(d) of the Fair Labor 

Standards Act [29 U.S.C. § 203(d)], in that RIGLOS acted directly in the interests of 

INVESTMENTS 2 and OLENKA ARTISAN BAKERY in relation to its employees including 

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Plaintiff. 

103. Specifically, RIGLOS is the owner of the corporations, and the individual who hired the 

Plaintiff. RIGLOS supervised Plaintiff, determined company payroll decisions, and maintained 

the right to hire and fire Plaintiff during all pertinent times hereto.

104. RIGLOS had operational control of the businesses and is thus jointly liable for Plaintiff’s 

damages.

105. Defendant RIGLOS willfully and intentionally refused to properly pay Plaintiff overtime 

wages as required by the law of the United States as set forth above and remains owing Plaintiff 

these wages since the commencement of Plaintiff’s employment with Defendants as set forth 

above. 

106. By reason of the said intentional, willful and unlawful acts of RIGLOS, Plaintiff has 

suffered damages plus incurring costs and reasonable attorneys' fees.

107. As a result of RIGLOS willful violations of the Act, Plaintiff is entitled to liquidated 

damages.

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant RIGLOS: 

A. Adjudge and decree that RIGLOS has violated the FLSA and has done so willfully, 

intentionally and with reckless disregard for Plaintiff’s rights;

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

compensation for hours worked in excess of forty (40) weekly, with interest; and

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

D. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

Case 0:22-cv-61736-XXXX Document 1 Entered on FLSD Docket 09/15/2022 Page 18 of 19
Page 19

DEMAND FOR JURY TRIAL

Plaintiff, AMILCAR AMBIELA demands trial by jury on all issues and all counts of this 

Complaint so triable as a matter of right.

Dated: September 15, 2022

PEREGONZA THE ATTORNEYS, PLLC

5201 Blue Lagoon Drive, 

Suite 290

Miami, FL 33126

Tel. (786) 650-0202

Fax. (786) 650-0200

By: /s/

Nathaly Saavedra, Esq. 

Fla. Bar No. 118315

Email: nathaly@peregonza.com

By: /s/ 

Juan J. Perez, Esq. 

Fla. Bar No. 115784

Email: juan@peregonza.com

Case 0:22-cv-61736-XXXX Document 1 Entered on FLSD Docket 09/15/2022 Page 19 of 19