UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

IVAN FEDERICO DOMINGUEZ, 

Plaintiff,

v.

METRO PREVENTIVE PLUMBING

MAINTENANCE INC., 

MICHAEL A CIOFFOLETTI, 

Defendants.

__________________________________/

COMPLAINT

{Jury Trial Demanded}

Plaintiff, IVAN FEDERICO DOMINGUEZ (“Dominguez”), brings this action against 

Defendants, METRO PREVENTIVE PLUMBING MAINTENANCE INC. (“Metro”) and 

MICHAEL A CIOFFOLETTI (“Cioffoletti”), and alleges as follows:

1. This is an action arising under the Fair Labor Standards Act 29 U.S.C. §§ 201-219 

(“FLSA”). Jurisdiction is conferred on this Court by 28 U.S.C. § 1331 and 29 U.S.C. § 216(b).

2. At all times material hereto, Dominguez was a resident of Florida and an “employee” of 

Defendants as defined by the FLSA.

3. At all times material hereto, Metro was a Florida corporation that regularly transacted 

business in South Florida.

4. Cioffoletti is an FLSA employer as defined in 29 U.S.C. § 203(d), is an owner and/or 

manager of Metro, ran the day-to-day operations and had operational control over Metro, and was 

directly involved in decisions affecting duties, employee compensation, and hours worked by 

employees, such as Dominguez.

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5. Metro’s business involves plumbing services.

6. Defendants have employees handling, selling, or otherwise working on goods or materials 

that have been moved in or produced for commerce including but not limited to computers, phones, 

pens, and paper.

7. Upon information and belief, Metro’s gross sales or business done was in excess of 

$500,000 per year at all times material hereto.

8. Metro was an enterprise engaged in commerce or the production of goods for commerce 

and is covered by the FLSA at all times material hereto.

9. Dominguez worked for Defendants as a plumber.

10. Defendants failed to pay Dominguez’s full and proper overtime wages.

11. Defendants knowingly and willfully refused to pay Dominguez’s legally-entitled wages.

12. Attached as Exhibit A is a preliminary calculation of Dominguez’s claims. These amounts 

may change as Dominguez engages in the discovery process.

13. Dominguez retained the services of the undersigned and is obligated to pay for the legal 

services provided.

COUNT I

VIOLATION OF THE FAIR LABOR STANDARDS ACT

AGAINST ALL DEFENDANTS

14. Plaintiff realleges and incorporates the allegations set forth in paragraphs 1-13 above as if

set forth herein in full.

15. Plaintiff alleges this action pursuant to the Fair Labor Standards Act, 29 U.S.C. §§ 216 

(b), that Plaintiff is entitled to: (i) time-and-a-half overtime pay and (ii) liquidated damages 

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

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16. Plaintiff seeks recovery of damages as referenced above and further seeks interest, costs, 

and attorneys’ fees pursuant to 29 U.S.C. § 216(b).

WHEREFORE, Plaintiff demands judgment against Defendants, jointly and severally, plus 

costs, reasonable attorneys’ fees, and such other remedy as the court deems just and appropriate.

Respectfully submitted,

Koz Law, P.A.

800 East Cypress Creek Road Suite 421

Fort Lauderdale, Florida 33334

Tel: (786) 924-9929

Fax: (786) 358-6071

Email: ekoz@kozlawfirm.com

Elliot Kozolchyk, Esq.

Bar No.: 74791

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