UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

CLAUDETE PELISSARO MARTELLO, 

Plaintiff,

v.

BRIDGE REAL ESTATE GROUP, LLC, 

Defendant.

__________________________________/

COMPLAINT

{Jury Trial Demanded}

Plaintiff, CLAUDETE PELISSARO MARTELLO (“Martello”), brings this action against 

Defendant, BRIDGE REAL ESTATE GROUP, LLC (“BREG”), 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, Martello was a resident of Florida and an “employee” of 

Defendant as defined by the FLSA.

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

business in Broward County, Florida.

4. BREG’s business involves apartment property management and rentals.

5. BREG has 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.

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

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

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7. BREG was an enterprise engaged in commerce or the production of goods for commerce 

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

8. At all times material hereto, Martello engaged in interstate communication on a regular 

and recurrent basis including but not limited to telephone and email with customers in Brazil, 

Massachusetts, Colombia, New York, and California.

9. Martello engaged in interstate commerce on a regular and recurring basis and is 

individually covered by the FLSA. 

10. Martello worked for BREG as a leasing consultant.

11. BREG failed to pay Martello’s full and proper overtime wages.

12. BREG knowingly and willfully refused to pay Martello’s legally-entitled wages.

13. Attached as Exhibit A is a preliminary calculation of Martello’s claims. These amounts 

may change as Martello engages in the discovery process.

14. Martello 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 DEFENDANT BREG

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

set forth herein in full.

16. 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.

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

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

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WHEREFORE, Plaintiff demands judgment against Defendant 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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