UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-CV-22671-ALTONAGA/TORRES

DELIO BATISTA, 

CARLOS LOPEZ,

MARIANA LOPEZ and

RAFAELA VALIENTE,

Plaintiffs,

vs.

AVANT ASSURANCE INC., 

REINIER CORTES, AND 

ANDREA GONZALEZ QUINTERO,

Defendants.

______________________________/

Language proposed only by Plaintiffs is boldfaced and underlined. 

Language proposed only by Defendants is boldfaced and italicized.

SPECIAL INTERROGATORIES TO THE JURY

Do you find from a preponderance of the evidence:

Delio Batista

1. That Delio Batista was an employee covered under the FLSA as 

defined in 29 U.S.C. 203(e)(1), of:

(Please mark “YES” or “NO” for each you find was an employer):

Avant Assurance Inc. _____________

Reinier Cortes _____________

Case 1:22-cv-22671-CMA Document 76-2 Entered on FLSD Docket 06/12/2023 Page 1 of 6
Andrea Gonzalez Capote _____________

If you answered “YES” to one or more of the above, please answer 

Question 2. If you answered “NO” to all the above, please skip to 

Question 4.

2. That Delio Batista was exempt from the overtime pay provisions of the 

FLSA pursuant to the _____ exemption:

Answer “YES” or “NO” _____________

If you answered “NO” to Question 2, please answer Question 3. 

If you answered “YES” to Question 2, please skip to Question 4.

3. That Defendants failed to pay Delio Batista the overtime wages

required by law:

Answer “YES” or “NO” _____________

If “Yes”, in what amount _____________

Please answer Question 4.

4. That Defendants failed to pay Delio Batista bonuses and/or 

commissions under their breach of contract-related counts:

Answer “YES” or “NO” _____________

If “Yes”, in what amount _____________

Please answer Question 5.

Carlos Lopez

5. That Carlos Lopez was an employee covered under the FLSA as 

defined in 29 U.S.C. 203(e)(1), of:

Case 1:22-cv-22671-CMA Document 76-2 Entered on FLSD Docket 06/12/2023 Page 2 of 6
(Please mark “YES” or “NO” for each you find was an employer):

Avant Assurance Inc. _____________

Reinier Cortes _____________

Andrea Gonzalez Capote _____________

If you answered “YES” to one or more of the above, please answer 

Question 6. If you answered “NO” to all the above, please skip to 

Question 8.

6. That Carlos Lopez was exempt from the overtime pay provisions of the 

FLSA pursuant to the _____ exemption:

Answer “YES” or “NO” _____________

If you answered “NO” to Question 6, please answer Question 7. 

If you answered “YES” to Question 6, please skip to Question 8.

7. That Defendants failed to pay Carlos Lopez the overtime wages

required by law:

Answer “YES” or “NO” _____________

If “YES,” in what amount _____________

Please answer Question 8.

8. That Defendants failed to pay Carlos Lopez bonuses and/or 

commissions under their breach of contract-related counts:

Answer “YES” or “NO” _____________

If “YES,” in what amount _____________

Case 1:22-cv-22671-CMA Document 76-2 Entered on FLSD Docket 06/12/2023 Page 3 of 6
Please answer Question 9.

Mariana Lopez

9. That Mariana Lopez was an employee covered under the FLSA as 

defined in 29 U.S.C. 203(e)(1), of:

(Please mark “YES” or “NO” for each you find was an employer):

Avant Assurance Inc. _____________

Reinier Cortes _____________

Andrea Gonzalez Capote _____________

If you answered “YES” to one or more of the above, please answer 

Question 10. If you answered “NO” to all the above, please skip to 

Question 12.

10.That Mariana Lopez was exempt from the overtime pay provisions of 

the FLSA pursuant to the _____ exemption:

Answer “YES” or “NO” _____________

If you answered “NO” to Question 10, please answer Question 11. 

If you answered “YES” to Question 10, please skip to Question 13.

11.That Defendants failed to pay Mariana Lopez the overtime wages

required by law:

Answer “YES” or “NO” _____________

If “YES,” in what amount _____________

Please answer Question 12.

Case 1:22-cv-22671-CMA Document 76-2 Entered on FLSD Docket 06/12/2023 Page 4 of 6
12.That Defendants failed to pay Mariana Lopez bonuses and/or 

commissions under their breach of contract-related counts:

Answer “YES” or “NO” _____________

If “YES,” in what amount _____________

Please answer Question 13.

Rafaela Valiente

13.That Rafaela Valiente was an employee covered under the FLSA as 

defined in 29 U.S.C. 203(e)(1), of:

(Please mark “YES” or “NO” for each you find was an employer):

Avant Assurance Inc. _____________

Reinier Cortes _____________

Andrea Gonzalez Capote _____________

If you answered “YES” to one or more of the above, please answer 

Question 14. If you answered “NO” to all the above, please skip to 

Question 16.

14.That Rafaela Valiente was exempt from the overtime pay provisions of 

the FLSA pursuant to the _____ exemption:

Answer “YES” or “NO” _____________

If you answered “NO” to Question 14, please answer Question 15. 

If you answered “YES” to Question 14, please skip to Question 16.

15.That Defendants failed to pay Rafaela Valiente the overtime wages

required by law:

Case 1:22-cv-22671-CMA Document 76-2 Entered on FLSD Docket 06/12/2023 Page 5 of 6
Answer “YES” or “NO” _____________

If “YES,” in what amount _____________

Please answer Question 16.

16.That Defendants failed to pay Rafaela Valiente bonuses and/or 

commissions under their breach of contract-related counts:

Answer “YES” or “NO” _____________

If “YES,” in what amount _____________

SO SAY WE ALL.

___________________________

Foreperson’s Signature

DATE: ___________________

Case 1:22-cv-22671-CMA Document 76-2 Entered on FLSD Docket 06/12/2023 Page 6 of 6