IN THE UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 1:22-cv-22306-JEM 

GUSTAVO GARCIA, 

and all others similarly situated under 

29 U.S.C. §216(b), 

 Plaintiff(s), 

vs. 

GREENE KLEEN OF SOUTH FLORIDA, INC., 

CIRA FIGUEROA, individually, and 

ANTHONY FIGUEROA, individually, 

 Defendants. 

 / 

DEFENDANTS’ ANSWER AND AFFIRMATIVE DEFENSES TO 

PLAINTIFF’S COMPLAINT 

Defendants, CIRA FIGUEROA (“Ms. Figueroa”) and ANTHONY FIGUEROA (“Mr. 

Figueroa”) (together, “Defendants”) by and though undersigned counsel, hereby respond to the 

numbered paragraphs of the Complaint filed by Plaintiff GUSTAVO GARCIA and assert 

affirmative defenses thereto: 

Defendants deny each and every allegation of the Complaint except as may be 

specifically admitted, qualified, or otherwise answered below. Defendants further state as 

follows: 

INTRODUCTION 

1. This is an action by Plaintiff against Defendants for damages in connection to 

claims for unpaid overtime wages pursuant to the Fair Labor Standards Act, 29 U.S.C. §§ 201 et 

seq. (“FLSA”). 

ANSWER: Defendants admit only that Plaintiff purports to bring an action under 29 

U.S.C. §§ 201 et seq. Defendants deny the remaining allegations contained in Paragraph 1 

of the Complaint. 

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2. Plaintiff seeks money damages, reasonable attorneys’ fees and costs, and all other 

remedies, including injunctive relief, allowable by law. 

ANSWER: Defendants admit that Plaintiff is seeking money damages, attorneys’ fees and 

injunctive relief, but deny any and all liability and wrongdoing, and deny that Plaintiff is

entitled to any relief, whether legal, equitable, or otherwise. 

PARTIES JURIDICTION AND VENUE 

3. Plaintiff is a former employee of Defendants and at all material times resided in 

Miami-Dade County, Florida. 

ANSWER: Defendants admit that Plaintiff was formerly employed by Defendant Greene 

Kleen of South Florida, Inc. (“Green Kleen”). Defendants are without knowledge or 

information regarding Plaintiff’s place of residence, and therefore, deny the remaining 

allegations in Paragraph 3. 

4. Defendant Greene Kleen, a for-profit corporation operating out of Miami-Dade 

County, Florida, was at all material times authorized to conduct its for-profit business in Florida 

and it is otherwise sui juris. 

ANSWER: Defendants admit that Greene Kleen is a Florida corporation with its principal 

place of business in Miami-Dade County, Florida. 

5. Defendant Cira was at all times material hereto a co-owner and co-operator of the 

corporate Defendant for the relevant time period. Defendant Cira ran or otherwise oversaw the 

day-to-day operations of the corporate Defendant, was involved in establishing the business of 

the corporate Defendant, had supervisory authority over Plaintiff, was partially or totally 

responsible for paying Plaintiff’s wages, and had the power to separate Plaintiff from his 

employment. 

ANSWER: Defendants admit that Cira Figueroa is the owner and operator of Greene 

Kleen and had the authority to separate employees from their employment. Defendants 

admit that Cira Figueroa was involved in running Greene Kleen and in establishing Greene 

Kleen. Defendants deny the remaining allegations in Paragraph 5. 

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6. Defendant Anthony was at all times material hereto a co-owner and co-operator of 

the corporate Defendant for the relevant time period. Defendant Anthony ran or otherwise 

oversaw the day-to-day operations of the corporate Defendant, was involved in establishing the 

business of the corporate Defendant, had supervisory authority over Plaintiff, was partially or 

totally responsible for paying Plaintiff’s wages, and had the power to separate Plaintiff from his 

employment. 

ANSWER: Denied. 

7. Defendants were Plaintiff’s direct employers, joint employers, and co-employers 

based on the running of the operation, financials, and control of employees like Plaintiff. 

ANSWER: Defendants admit that Greene Kleen employed Plaintiff. Defendants deny the 

remaining allegations in Paragraph 7.

8. Venue is proper in this Court because Defendants transact business in this 

District, Defendants maintain a principal place of business in this District, Defendants employed 

Plaintiff in this District, and the claims arose within the District. 

ANSWER: The allegations in Paragraph 8 state legal conclusions to which a response is not 

required. To the extent a response is deemed to be required, Defendants deny those 

allegations. Furthermore, Defendants deny that Defendants or Greene Kleen engaged in 

any unlawful employment practices. 

9. All conditions precedent to this action have been satisfied by Plaintiff, waived by 

Defendants, or occurred. 

ANSWER: The allegations in Paragraph 9 state legal conclusions to which a response is not 

required. To the extent a response is deemed to be required, Defendants deny those 

allegations. 

A. Plaintiff’s Employment With Defendants. 

10. Plaintiff began working for Defendants during 2019. 

ANSWER: Denied. Plaintiff began working for Greene Kleen in 2020. 

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11. During the entirety of his employment with Defendants, Plaintiff worked in a 

non-exempt maintenance position. 

ANSWER: Denied. 

12. Plaintiff, at all material times, was paid an hourly rate of $11.50. 

ANSWER: Denied. 

13. Plaintiff worked for Defendants until his separation on February 3, 2022. 

ANSWER: Denied. 

14. During his employment, Plaintiff solely worked for Defendants and no other 

entity or business. 

ANSWER: Defendants are without knowledge or information regarding the allegations in 

Paragraph 14, and therefore, deny them. 

15. During his employment, Plaintiff had to adhere to Defendants’ rules, policies, and 

procedures. 

ANSWER: Defendants admit that it maintains rules, policies and procedures that all 

employees must follow. 

16. During his employment, Plaintiff’s schedules and working periods were set by 

Defendants. 

ANSWER: Defendants admit that Plaintiff’s schedule was set by a Greene Kleen manager. 

Defendants deny the remaining allegations in Paragraph 16. 

17. During Plaintiff’s employment, he routinely worked beyond forty (40) hours per 

week but Defendants only paid Plaintiff overtime wages on two pay periods out of dozens and 

dozens of pay periods where overtime hours were worked. 

ANSWER: Denied. 

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B. Defendants’ Business and Interstate Commerce

18. The primary purpose of Greene Kleen is to provide janitorial services to 

commercial clients. 

ANSWER: Defendants admit that Greene Kleen provides janitorial services to commercial 

clients. 

19. Under information and belief, Plaintiff alleges that Greene Kleen’s gross annual 

revenue exceeded $500,000.00 during 2019, 2020, and 2021. 

ANSWER: Admitted.

20. Greene Kleen customarily and regularly bought and sold goods and services that 

crossed state lines. 

ANSWER: Defendants are without knowledge or information regarding the allegations in 

Paragraph 20, and therefore, deny them. 

21. At all relevant times, Greene Kleen employed two or more employees that 

customarily, continually, and regularly handled goods and materials that i) were purchased from 

a person or entity outside the state of Florida and/or ii) were purchased in Florida but had 

previously traveled through interstate commerce. 

ANSWER: Defendants are without knowledge or information regarding the allegations in 

Paragraph 21, and therefore, deny them.

22. Upon information and belief, Greene Kleen obtained and solicited funds from 

non-Florida sources, accepted funds from non-Florida sources, used telephonic (or other 

electronic) transmissions going over state lines to do its business, transmitted funds outside the 

State of Florida, used electronic means to market and run their business in a way that was not 

limited to Florida, and otherwise regularly engaged in interstate commerce during the relevant 

period. 

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ANSWER: Defendants admit that Greene Kleen has used telephonic and/or electronic 

transmissions to communicate over state lines. Defendants deny the remaining allegations 

in Paragraph 22. 

23. Greene Kleen, upon information and belief, accepts checks, wire transfers, and 

other forms of payments that are made or processed outside the state of Florida, and did so 

during the relevant period. 

ANSWER: Defendants admit that Greene Kleen has received payments from banks outside 

of Florida. 

24. Greene Kleen is an employer engaged in interstate commerce and subject to the 

FLSA. 

ANSWER: Defendants admit that Greene Kleen is subject to the Fair Labor Standards 

Act. The remaining allegations in Paragraph 24 are legal conclusions to which a response is 

not required. 

25. As such, Greene Kleen must be considered Plaintiff’s employer as the term 

employer is defined by 29 U.S.C. § 203. 

ANSWER: Defendants admit that Greene Kleen employed Plaintiff. The remaining 

allegations in Paragraph 25 are legal conclusions to which a response is not required. 

C. Cira and Anthony Figueroa’s Employment of, and Failure to Properly Pay, Plaintiff 

26. During the relevant period, Cira was co-owner and co-operator of Defendant 

Greene Kleen. Defendant Cira holds herself out as a corporate office [sic] of Greene Kleen on 

the corporate documents filed with the State of Florida. 

ANSWER: Defendants admit that Cira Figueroa is the owner and operator of Greene 

Kleen, and that Cira Figueroa is listed as Greene Kleen’s owner and registered agent on 

Greene Kleen’s most recent annual report filed with the State of Florida. Defendants deny 

the remaining allegations in Paragraph 26. 

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27. During the relevant period, Anthony was co-owner and co-operator of Defendant 

Greene Kleen. Defendant Anthony holds herself [sic] out as the “President” of Greene Kleen on 

the corporate documents filed with the State of Florida. 

ANSWER: Defendants admit that Anthony Figueroa is listed as Greene Kleen’s president 

on Greene Kleen’s most recent annual report filed with the State of Florida. Defendants 

denies the remaining allegations in Paragraph 27.

28. During the relevant period, Cira and Anthony Figueroa was Plaintiff’s comanager/supervisor during his employment. 

ANSWER: Denied. 

29. During Plaintiff’s employment, Cira and Anthony Figueroa provided Plaintiff 

with his work duties, gave feedback on the work Plaintiff performed for Defendants, had the 

ability to discipline Plaintiff, were responsible for recording, calculating, and paying Plaintiff’s 

work hours. 

ANSWER: Denied. 

30. During the relevant period, Cira and Anthony Figueroa was in control of the 

finances that were utilized to pay Plaintiff’s wages and had the responsibility, in full or in part, of 

ensuring those wages were paid timely and correctly. 

ANSWER: Defendants admit that Cira Figueroa had control of Greene Kleen’s finances. 

Defendants deny the remaining allegations in Paragraph 30. 

31. Cira and Anthony Figueroa, despite knowledge of Plaintiff’s overtime hours, 

failed to compensate Plaintiff fully and properly. 

ANSWER: Denied. 

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32. Cira and Anthony Figueroa intentionally refused to pay Plaintiff overtime wages 

he was owed under the. 

ANSWER: Denied. 

33. Cira and Anthony Figueroa must be considered Plaintiff’s employers, joint 

employers, or co-employers for purposes of the FLSA as the term employer is defined by 29 

U.S.C. § 203. 

ANSWER: The allegations in Paragraph 33 state legal conclusions to which a response is 

not required. To the extent a response is deemed to be required, Defendants deny those 

allegations.

D. Defendants' Illegal Payment Practices Affected All Other Similarly Situated 

Employees. 

34. Defendants employ many other Maintenance Workers that performed duties in the 

same or similar fashion as Plaintiff. 

ANSWER: Defendants deny that Greene Kleen employs any maintenance workers. 

35. Defendants employ many other Maintenance Workers that were paid in a same or 

similar fashion as Plaintiff. 

ANSWER: Defendants deny that Greene Kleen employs any maintenance workers. 

36. Defendants employ many other Maintenance Workers that customarily and 

regularly performed overtime work for which they were not compensated fully. 

ANSWER: Defendants deny that Greene Kleen employs any maintenance workers. 

Defendants further deny that Defendants or Greene Kleen failed properly to compensate 

any employee for overtime work. 

37. Maintenance Workers for Defendants have worked over forty (40) hours a week 

during the last three (3) years without being paid at a proper time- and-a-half their regular rate of 

pay for all overtime hours worked. 

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ANSWER: Defendants deny that Greene Kleen employs any maintenance workers. 

Defendants further deny that Defendants or Greene Kleen failed properly to compensate 

any employee for overtime work.

COUNT I 

OVERTIME VIOLATION BY GREENE KLEEN OF SOUTH FLORIDA, INC. 

UNDER THE FAIR LABOR STANDARDS ACT 

The allegations in Count I are not asserted against Ms. Figueroa or Mr. Figueroa, so no 

response from Defendants is due. To the extent any response from Defendants is due, Defendants 

deny all allegations in Count I, deny all liability, and deny that Plaintiff is entitled to any relief, 

whether legal, equitable, or otherwise. 

COUNT II 

OVERTIME VIOLATIONS AGAINST CIRA FIGUEROA UNDER 

THE FAIR LABOR STANDARDS ACT 

47. Plaintiff re-alleges and incorporate by reference the allegations in paragraphs 1 

through 37 above as if fully set forth herein. 

ANSWER: Ms. Figueroa restates and reasserts each and every response to Paragraphs 1 

through 37, as if set forth fully herein. 

48. Cira operated the day-to-day activities of Defendants’ business, had supervisory 

authority over Plaintiff, had control/access to Plaintiff’s records for work hours, and was 

partially or totally responsible for paying Plaintiff’s wages. 

ANSWER: Ms. Figueroa admits that she operated Greene Kleen, but denies the remaining 

allegations contained in Paragraph 48. 

49. Cira scrutinized Plaintiff’s work and controlled how Plaintiff did his job. 

ANSWER: Denied. 

50. During Plaintiff’s employment with Defendants, Plaintiff worked for Defendants 

over 40 hours per week.

ANSWER: Denied. 

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51. During his employment with Defendants, Plaintiff worked overtime hours for 

which he was not compensated at a rate of no less than one-and-one-half his regular rate of pay 

as required by the FLSA. 

ANSWER: Denied. 

52. Plaintiff is owed unpaid overtime compensation pursuant to the FLSA. 

ANSWER: Denied. 

53. Cira did not compensate Plaintiff for his overtime despite her knowledge of the 

overtime hours Plaintiff worked and Plaintiff’s multiple complaints to her regarding the lack of 

overtime wages. 

ANSWER: Denied. 

54. Cira is also jointly and severally liable for double the overtime amounts owed as 

liquidated damages under the FLSA as a result of her intentional and willful violation of the 

FLSA for up to the three-year statute of limitations afforded by the FLSA. 

ANSWER: Denied. 

WHEREFORE, Plaintiff respectfully requests that the Court: 

a. Enter judgment for Plaintiff against Cira under the FLSA; 

b. Award Plaintiff actual damages for the unpaid wages; 

c. Award Plaintiff liquidated damages; 

d. Award Plaintiff his attorneys’ fees and costs; 

e. Award Plaintiff all recoverable interest; and 

f. Award any other relief this Honorable Court deems just and proper.

ANSWER: The “WHEREFORE” clause, and all of its subparts, following Paragraph 54 of 

the Complaint contains no allegations of fact to which a response is required. To the extent 

any response may be necessary, Defendants deny any and all liability and wrongdoing, and 

denies that Plaintiff is entitled to any relief, whether legal, equitable, or otherwise. 

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COUNT III 

OVERTIME VIOLATIONS AGAINST ANTHONY FIGUEROA UNDER 

THE FAIR LABOR STANDARDS ACT 

55. Plaintiff re-alleges and incorporate by reference the allegations in paragraphs 1 

through 37 above as if fully set forth herein. 

ANSWER: Mr. Figueroa restates and reasserts each and every response to Paragraphs 1 

through 37, as if set forth fully herein. 

56. Anthony operated the day-to-day activities of Defendants’ business, had 

supervisory authority over Plaintiff, had control/access to Plaintiff’s records for work hours, and 

was partially or totally responsible for paying Plaintiff’s wages. 

ANSWER: Denied. 

57. Anthony scrutinized Plaintiff’s wages and controlled the method and the amounts 

Plaintiff was paid for his job. 

ANSWER: Denied. 

58. During Plaintiff’s employment with Defendants, Plaintiff worked for Defendants 

over 40 hours per week.

ANSWER: Denied. 

59. During his employment with Defendants, Plaintiff worked overtime hours for 

which he was not compensated at a rate of no less than one-and-one-half his regular rate of pay 

as required by the FLSA. 

ANSWER: Denied. 

60. Plaintiff is owed unpaid overtime compensation pursuant to the FLSA. 

ANSWER: Denied. 

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61. Anthony did not compensate Plaintiff for his overtime despite his knowledge of 

the overtime hours Plaintiff. 

ANSWER: Denied. 

62. Anthony is also jointly and severally liable for double the overtime amounts owed 

as liquidated damages under the FLSA as a result of her intentional and willful violation of the 

FLSA for up to the three-year statute of limitations afforded by the FLSA. 

ANSWER: Denied. 

WHEREFORE, Plaintiff respectfully requests that the Court: 

a. Enter judgment for Plaintiff against Anthony under the FLSA; 

b. Award Plaintiff actual damages for the unpaid wages; 

c. Award Plaintiff liquidated damages; 

d. Award Plaintiff his attorneys’ fees and costs; 

e. Award Plaintiff all recoverable interest; and 

f. Award any other relief this Honorable Court deems just and proper.

ANSWER: The “WHEREFORE” clause, and all of its subparts, following Paragraph 62 of 

the Complaint contains no allegations of fact to which a response is required. To the extent 

any response may be necessary, Defendants deny any and all liability and wrongdoing, and 

denies that Plaintiff is entitled to any relief, whether legal, equitable, or otherwise. 

COUNT IV 

COLLECTIVE ACTION AGAINST GREENE KLEEN OF SOUTH FLORIDA, INC. 

FOR UNPAID OVERTIME WAGES UNDER THE FLSA 

The allegations in Count IV are not asserted against Ms. Figueroa or Mr. Figueroa, so no 

response from Defendants is due. To the extent any response from Defendants is due, Defendants 

deny all allegations in Count IV, deny all liability, and deny that Plaintiff is entitled to any relief, 

whether legal, equitable, or otherwise. 

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COUNT V 

COLLECTIVE ACTION AGAINST CIRA FIGUEROA FOR UNPAID OVERTIME 

WAGES UNDER THE FLSA 

69. Plaintiff re-alleges and incorporate by reference the allegations in paragraphs 1 

through 37 above as if fully set forth herein. 

ANSWER: Ms. Figueroa restates and reasserts each and every response to Paragraphs 1 

through 37, as if set forth fully herein. 

70. Cira operated the day-to-day activities of Defendants’ business, had supervisory 

authority over Maintenance Workers, had control/access to records for work hours and pay, and 

was partially or totally responsible for paying Maintenance Workers during the relevant period.

ANSWER: Ms. Figueroa admits that she operated Greene Kleen, but denies the remaining 

allegations contained in Paragraph 70. 

71. Cira scrutinized the work of Maintenance Workers during the relevant period and 

controlled how they did their jobs.

ANSWER: Denied. 

72. During the relevant period, Maintenance Workers consistently worked over 40 

hours per week for Defendants.

ANSWER: Denied. 

73. During their employment with Defendants, Maintenance Workers worked 

overtime hours for which they were not compensated at a rate of time-and-a-half their regularly 

rate of pay as required by the FLSA.

ANSWER: Denied. 

74. Maintenance Workers are owed unpaid overtime compensation pursuant to the 

FLSA.

ANSWER: Denied. 

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75. Cira did not compensate Maintenance Workers for their overtime despite 

knowledge of the overtime hours these Maintenance Workers worked.

ANSWER: Denied. 

76. Cira is also jointly and severally liable for double the overtime amounts owed as 

liquidated damages under the FLSA as a result of her intentional and willful violation of the 

FLSA for up to the three-year statute of limitations afforded by the FLSA.

ANSWER: Denied. 

WHEREFORE, Plaintiff respectfully requests that the Court: 

a. Enter judgment for Maintenance Workers against Cira under the FLSA; 

b. Award Maintenance Workers actual damages for the unpaid wages; 

c. Award Maintenance Workers liquidated damages; 

d. Award attorneys’ fees and costs; 

e. Award all recoverable interest; and 

f. Award any other relief this Honorable Court deems just and proper.

ANSWER: The “WHEREFORE” clause, and all of its subparts, following Paragraph 76 of 

the Complaint contains no allegations of fact to which a response is required. To the extent 

any response may be necessary, Defendants deny any and all liability and wrongdoing, and 

denies that Plaintiff is entitled to any relief, whether legal, equitable, or otherwise. 

COUNT VI 

COLLECTIVE ACTION AGAINST ANTHONY FIGUEROA FOR UNPAID 

OVERTIME WAGES UNDER THE FLSA 

77. Plaintiff re-alleges and incorporate by reference the allegations in paragraphs 1 

through 37 above as if fully set forth herein. 

ANSWER: Mr. Figueroa restates and reasserts each and every response to Paragraphs 1 

through 37, as if set forth fully herein. 

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78. Anthony operated the day-to-day activities of Defendants’ business, had 

supervisory authority over Maintenance Workers, had control/access to records for work hours 

and pay, and was partially or totally responsible for paying Maintenance Workers during the 

relevant period.

ANSWER: Denied. 

79. Anthony scrutinized the work of Maintenance Workers during the relevant period 

and controlled how they did their jobs.

ANSWER: Denied. 

80. During the relevant period, Maintenance Workers consistently worked over 40 

hours per week for Defendants.

ANSWER: Denied. 

81. During their employment with Defendants, Maintenance Workers worked 

overtime hours for which they were not compensated at a rate of time-and-a-half their regularly 

rate of pay as required by the FLSA.

ANSWER: Denied. 

82. Maintenance Workers are owed unpaid overtime compensation pursuant to the 

FLSA.

ANSWER: Denied. 

83. Anthony did not compensate Maintenance Workers for their overtime despite 

knowledge of the overtime hours these Maintenance Workers worked.

ANSWER: Denied. 

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84. Anthony is also jointly and severally liable for double the overtime amounts owed 

as liquidated damages under the FLSA as a result of her intentional and willful violation of the 

FLSA for up to the three-year statute of limitations afforded by the FLSA.

ANSWER: Denied. 

WHEREFORE, Plaintiff respectfully requests that the Court: 

a. Enter judgment for Maintenance Workers against Anthony under the FLSA; 

b. Award Maintenance Workers actual damages for the unpaid wages; 

c. Award Maintenance Workers liquidated damages; 

d. Award attorneys’ fees and costs; 

e. Award all recoverable interest; and 

f. Award any other relief this Honorable Court deems just and proper.

ANSWER: The “WHEREFORE” clause, and all of its subparts, following Paragraph 84 of 

the Complaint contains no allegations of fact to which a response is required. To the extent 

any response may be necessary, Defendants deny any and all liability and wrongdoing, and 

denies that Plaintiff is entitled to any relief, whether legal, equitable, or otherwise. 

JURY DEMAND

Defendants deny that Plaintiff has set forth triable issues against Defendants or Greene 

Kleen for jury determination. 

AFFIRMATIVE DEFENSES

Defendants set forth the following affirmative defenses to Plaintiff’s Complaint, and 

reserve the right to add additional affirmative defenses as this case proceeds: 

First Affirmative Defense 

Plaintiff’s and/or alleged similarly situated individuals’ FLSA claim is barred in whole or 

in part by the applicable 2-year statute of limitations. 

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Second Affirmative Defense 

During all or part of the applicable limitations period, Defendants and Greene Kleen 

acted in good faith and with reasonable grounds for believing that its acts or omissions were not 

in violation of the FLSA, and therefore cannot be held liable for liquidated damages under the 

FLSA. 

Third Affirmative Defense 

To the extent Plaintiff’s and/or alleged similarly situated individuals worked any 

overtime hours for which Plaintiff’s and/or alleged similarly situated individuals were not paid at 

the applicable or appropriate overtime rate, the amount owed is de minimis, and liability, 

therefore, cannot be established under the FLSA. 

Fourth Affirmative Defense 

To the extent Plaintiff and/or alleged similarly situated individuals worked overtime 

hours without the actual or constructive knowledge of Defendants or Greene Kleen, Plaintiff 

and/or alleged similarly situated individuals are not entitled to overtime compensation for any 

such overtime hours worked. 

Fifth Affirmative Defense 

To the extent Defendants or Greene Kleen are indebted to Plaintiff and/or alleged 

similarly situated individuals for any unpaid overtime compensation, the overtime must be 

calculated at half-time (one half the applicable rate of pay), as Plaintiff’s and/or alleged similarly 

situated individuals’ salary was intended and understood to cover all hours worked. 

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Sixth Affirmative Defense 

To the extent Defendants or Greene Kleen are indebted to Plaintiff and/or alleged 

similarly situated individuals for any unpaid overtime compensation, the extent of Greene 

Defendants’ and/or Kleen’s liability must be offset by the amounts paid or overpaid to Plaintiff 

and/or alleged similarly situated individuals during their employment. 

Seventh Affirmative Defense 

Defendants reserve their right to seek to recover from Plaintiff, alleged similarly situated 

individuals, and/or Plaintiff’s counsel reasonable attorneys’ fees and costs in connection with 

Defendants’ defense of this action. 

WHEREFORE, Defendants demand judgment in their favor, together with their 

reasonable attorneys’ fees and costs as provided by law, and such additional relief as the court 

deems just and proper. 

Dated: September 6, 2022 Respectfully submitted, 

 Miami, Florida 

/s/ Paul Crucet 

Florida Bar No. 122169 

E-Mail: pcrucet@stearnsweaver.com

STEARNS WEAVER MILLER, 

 WEISSLER, ALHADEFF & SITTERSON, P.A. 

150 West Flagler Street 

Museum Tower, Suite 2200 

Miami, Florida 33130 

Telephone: (305) 789-3200 

Facsimile: (305) 789-3395 

Attorneys for Defendant 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on September 6, 2022, I electronically filed the foregoing 

with the Clerk of the Court by using the CM/ECF System. I further certify that the foregoing 

document is being served this day on all counsel of record or pro se parties identified on the 

below Service List in the manner specified, either via transmission of Notices of Electronic 

Filing generated by CM/ECF or in some other authorized manner for those counsel or parties 

who are not authorized to receive Notices of Electronic Filing. 

/s/Paul Crucet_________ 

PAUL CRUCET, ESQ. 

SERVICE LIST 

J. Freddy Perera, Esq. 

Florida Bar No. 93625 

freddy@pba-law.com 

Brody M. Shulman, Esq. 

Florida Bar No. 92044 

brody@pba-law.com 

PERERA ALEMÁN, P.A. 

12505 Orange Drive, Suite 908 

Davie, Florida 33330 

Phone: (786) 485-5232 

Attorneys for Plaintiff 

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