UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

CASE NO:

ALEXANDER WILLIAMS, on behalf

of himself and all others similarly situated,

Plaintiff(s),

v.

EXPRESS DRAIN & SEWER

CLEANING, LLC f/k/a EM GROUP

VENTURES, LLC,

Defendant.

/

COLLECTIVE COMPLAINT FOR DAMAGES 

AND DEMAND FOR JURY TRIAL

Plaintiff, ALEXANDER WILLIAMS (“Plaintiff” or “Williams”), on behalf of himself and 

all others similarly situated, pursuant to 29 U.S.C. § 216(b), files the following Collective Action 

Complaint for Damages and Demand for Jury Trial against Defendant, EXPRESS DRAIN & 

SEWER CLEANING, LLC f/k/a EM GROUP VENTURES, LLC (“Defendant”)1and alleges as 

follows:

INTRODUCTION

1. This is a Collective Action arising under the Fair Labor Standards Act (“FLSA”), 

pursuant to 29 U.S.C. §§ 201–216, to seek redress of Defendant’s class-wide violations of the 

FLSA. During the relevant time period, Defendant misclassified Plaintiff and all other similarly 

1 On or about October 20, 2021, Defendant’s registered agent and managing member filed its 

Article of Amendment to Articles of Organization with the Florida Secretary of State to change its 

name from EM Group Ventures, LLC to Express Drain & Sewer Cleaning, LLC.

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situated employees as exempt and failed to pay a plethora of plumbers and laborers overtime 

compensation for their work in excess of forty (40) hours per a week. 

PARTIES

2. During all times material hereto, Plaintiff was and remains a resident of Broward 

County, Florida, over the age of 18 years, and otherwise sui juris. 

3. During all times material hereto, Defendant was a Florida Limited Liability 

Company licensed to transact business in Florida within the jurisdiction of this Honorable Court, 

and maintained a principal place of business at 5801 Mayo St., Hollywood, FL 33023.

4. During all times material hereto, Defendant possessed authority to hire, fire, and 

discipline Plaintiff.

5. During all times material hereto, Defendant created and administered the payroll 

practices applicable to Plaintiff, including the issuance of paychecks to Plaintiff. 

6. During all times material hereto, Plaintiff was dependent upon Defendant for his 

employment, as Defendant supervised, directed, and controlled Plaintiff’s day-to-day 

responsibilities, and used Plaintiff’s work in furtherance of its business objectives.

7. Defendant was Plaintiff’s employer, as defined by 29 U.S.C. § 203(d), during all 

times pertinent to the allegations herein. 

JURISDICTION AND VENUE

8. All acts and omissions giving rise to this dispute took place within Broward 

County, Florida, within the jurisdiction of this Honorable Court.

9. Defendant regularly transacts business in Broward County, Florida, and jurisdiction 

is therefore proper within the Southern District of Florida pursuant to 29 U.S.C. § 216(b) and 28 

U.S.C. §§ 1331 and 1337. 

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10. Venue is also proper within the Southern District of Florida pursuant to 29 U.S.C. 

§ 216(b) and 28 U.S.C. § 1391(b). 

GENERAL ALLEGATIONS

11. Defendant provides drain cleaning and plumbing services to residential and 

commercial clients, including services such as, but not limited to, sewer draining and cleaning, 

high pressure jetting, storm drain cleaning, plumbing maintenance and repair, and grease trap 

cleaning.2

12. Defendant hired Plaintiff to work for it as a plumber in or around August 2017. 

13. Plaintiff’s primary job duties during his employment period included, but were not 

limited to: repairing pipes, fixing leaks, performing maintenance work on toilets and faucets, labor,

handling service calls, drain cleaning, installment work, etc. 

14. Defendant has employed dozens of similarly situated plumbers who held the same 

or substantially similar duties as Plaintiff during the course of the previous three (3) years. 

15. Plaintiff did not have a fixed work schedule but typically worked approximately 

40-55 hours per week. 

16. Defendant paid Plaintiff a salary of $600 per week, plus non-discretionary bonuses 

and commissions. 

17. However, Defendant failed to pay Plaintiff overtime wages in one or more 

workweeks for the work he performed in excess of forty (40) hours. 

2 See “Services,” available at https://expressdrainplumbing.com/all-services/ (last visited on 

September 8, 2022).

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18. Defendant deliberately avoided its obligation to compensate Plaintiff at the lawful 

time-and-a-half rate for some or all of the hours that Plaintiff worked in excess of forty (40) per 

week despite being expressly or constructively aware of Plaintiff’s work. 

19. Defendant regularly manipulated the time records for Plaintiff during the relevant 

time period in an attempt to avoid its federal overtime wage obligations. 

20. As a result of Defendant’s intentional manipulation of these time records, Plaintiff’s 

payroll records during the relevant time period do not accurately reflect the total amount of hours 

actually worked by Plaintiff. 

21. Plaintiff last day of work with Defendant was on or about August 15, 2022. 

FLSA COVERAGE

22. Defendant is covered under the FLSA through enterprise coverage, as Defendant 

was engaged in interstate commerce during all pertinent times in which Plaintiff was employed. 

More specifically, Defendant and Plaintiff’s work for the Defendant affected interstate commerce 

because the goods and materials Plaintiff and other employees used and/or handled on a constant 

and/or continuous basis moved through interstate commerce prior to or subsequent to Plaintiff’s 

use of the same. Accordingly, Defendant was engaged in interstate commerce pursuant to 29 

U.S.C. § 203(s)(1)(A). 

23. During his employment with Defendant, Plaintiff and multiple other employees, 

handled and worked with various good and/or materials that have moved through interstate 

commerce, including, but not limited to the following: hand-tools, service trucks, jackhammers, 

cameras, hydro-jetting equipment, work gloves, extension cords, installation equipment, pens, 

computers, cellular telephones, order forms, and other related items.

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24. Defendant regularly employed two (2) or more employees for the relevant time 

period, and these employees handled goods or materials similar to those goods and materials 

handled by Plaintiff, thus making Defendant’s businesses enterprises covered by the FLSA. 

25. Defendant grossed in excess of $500,000.00 in 2020 and 2021, and is expected to 

gross in excess of $500,000.00 in 2022.

COUNT I – FEDERAL OVERTIME WAGE VIOLATIONS - 29 U.S.C. § 207

26. Plaintiff hereby re-alleges and re-avers Paragraphs 1 through 25 as though set forth 

fully herein.

27. Plaintiff alleges this action pursuant to the Fair Labor Standards Act (“FLSA”), 29 

U.S.C. § 216(b).

28. During all times material hereto, Plaintiff was a non-exempt employee who was 

eligible for overtime wages when he worked in excess of forty (40) hours per week.

29. During the time period relevant to this lawsuit, Plaintiff regularly worked in excess 

of forty (40) hours per week. 

30. However, Defendant failed to properly compensate Plaintiff in one or more 

workweeks for some of the hours worked in excess of forty (40) at a the applicable overtime wage 

premium. 

31. Plaintiff is entitled to recover statutorily prescribed overtime wages at the 

applicable overtime wage rate for all hours worked in excess of forty (40) per week during the 

course of the previous three (3) years. 

32. Defendant intentionally and/or willfully violated the FLSA or were reckless and/or 

indifferent as to its compliance with federal overtime law. 

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33. Accordingly, the statute of limitations in this action should be three (3) years as 

opposed to two (2) years. 

34. Moreover, Defendant’s willful and/or intentional violations of federal wage law 

entitle Plaintiff to an additional amount of liquidated, or double damages.

35. As a direct and proximate result of Defendant’s conduct, Plaintiff has been 

damaged in an amount to be proven at trial, including, but not limited to, a sum equivalent to the 

unpaid overtime compensation as required by 29 U.S.C. § 216(b), plus liquidated damages, and 

any such further damages as may be shown at the time of trial.

WHEREFORE, Plaintiff, ALEXANDER WILLIAMS, respectfully requests that this 

Honorable Court enter judgment in his favor and against the Defendant, EXPRESS DRAIN & 

SEWER CLEANING, LLC f/k/a EM GROUP VENTURES, LLC, and award Plaintiff: (a) 

overtime wages; (b) liquidated damages; (c) all reasonable attorney’s fees and litigation costs as 

permitted under the FLSA; and any and all such further relief as this Court may deem just and 

equitable under the circumstances.

DEMAND FOR JURY TRIAL

Plaintiff, ALEXANDER WILLIAMS, hereby demands a trial by jury on all appropriate 

claims. 

Dated this 9th day of September 2022.

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Respectfully Submitted,

USA EMPLOYMENT LAWYERSJORDAN RICHARDS, PLLC 

1800 SE 10th Ave. Suite 205

Fort Lauderdale, Florida 33316

Ph: (954) 871-0050

Counsel for Plaintiff

By: /s/ Jordan Richards

JORDAN RICHARDS, ESQUIRE

Florida Bar No. 108372

JAKE BLUMSTEIN, ESQUIRE

Florida Bar No. 

Jordan@jordanrichardspllc.com

Jake@jordanrichardspllc.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that the foregoing document was filed via CM/ECF on September 

9, 2022. 

By: /s/ Jordan Richards

JORDAN RICHARDS, ESQUIRE

Florida Bar No. 108372

SERVICE LIST:

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