UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-CV-22787-SCOLA/GOODMAN

LIORA SAMANDAROVA,

Plaintiff,

vs.

HOOKAH EXOTIX LLC, 

JEAN-CHRISTOPHE PITTMAN, 

AND ALEXANDRE ARKHIPOV,

Defendants.

______________________________/

DECLARATION OF LIORA SAMANDAROVA

LIORA SAMANDAROVA states the following under oath:

1. My name is Liora Samandarova, and I have personal knowledge of the facts herein.

2. I am a resident of Florida, over 18 years old and am sui juris.

3. Defendants, Hookah Exotix LLC, Jean-Christophe Pittman and Alexandre Arkipov, lured 

me to the United States to do office work for their hookah lounge. 

4. Defendants promised that I would be paid $1,000.00 a month to do marketing and 

promoting. 

5. However, once I got the job, I was also required to sell hookahs to customers at the lounge; 

essentially, I was also required to work as a server. 

6. I worked for the Defendants from May 1, 2022 through June 30, 2022, which is eight-anda-half (8.5) weeks.

7. I never received the $1,000.00 a month in compensation, and instead ended up paying rent 

to the Defendants under false pretenses because they promised me a place to live, which turned 

out to be a lie as well. 

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8. I am owed $2,000.00 for the two months that I worked for the Defendants doing office 

work. 

9. I worked an average of 64 hours a week during those 8.5 weeks, but I was never paid any

minimum wages.

10. I should have earned $464.00 in minimum wages each week calculated as 64 hours a week

times $7.25 an hour as minimum wage (64 x $7.25). 

11. I am owed approximately $3,944.00 for the time I worked calculated as $464.00 times 8.5 

weeks ($464.00 x 8.5). 

12. Furthermore, I was never paid any overtime wages while working for the Defendants. 

13. I worked 24 hours a week in overtime each week.

14. I should have made $15.00 an hour in overtime based on Florida’s minimum wage of 

$10.00 an hour. 

15. Therefore, I should have made $360.00 a week in overtime (24 x $15.00).

16. I should have made $3,060.00 in overtime over the 8.5 weeks I was employed (8.5 x 

$360.00). 

17. Based on the contract I had with the Defendants, I am owed $2,000.00 for each month 

that I performed office work, $3,944.00 in unpaid minimum wages, plus $3,060.00 in overtime 

wages, for a total of $9,004.00.

18. The Defendants also owe me $7,004.00 in liquidated damages for the unpaid minimum 

and overtime wages. 

19. Overall, I am owed $16,008.00 in wages and liquidated damages, exclusive of attorneys’

fees and costs. 

20. I further hired FairLaw Firm to represent me in this matter, and I am obligated to pay 

them attorneys’ fees and costs for prosecuting this matter.

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21. I also seek recovery of my attorneys’ fees and costs from Defendants.

Under penalties of perjury, I declare that I have read the foregoing Declaration and the 

facts stated in it are true.

_____________________________

Liora Samandarova 

Dated_________________________

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