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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.:

Barbara A. Garcia, 

and other similarly situated individuals,

Plaintiff (s) 

v. 

 

Laundry Flagler LLC, 

a/k/a Soaphia Laundry Centers 

Tanguy Letalaer, 

and Phillippe Erb, individually, 

 Defendants, 

_________________________________/ 

COLLECTIVE ACTION COMPLAINT

(OPT-IN PURSUANT TO 29 USC § 216(b))

Comes now the Plaintiff Barbara A. Garcia and other similarly situated individuals, by and 

through the undersigned counsel, and hereby sues Laundry Flagler LLC, a/k/a Soaphia Laundry 

Center, Tanguy Letalaer, and Phillippe Erb, individually and alleges:

JURISDICTIONAL ALLEGATIONS

1. This is an action to recover money damages for regular and overtime unpaid wages under 

the United States laws. This Court has jurisdiction pursuant to the Fair Labor Standards 

Act, 29 USC § 201-219 (Section 216 for jurisdictional placement) ("the Act"). 

2. Plaintiff Barbara A. Garcia is a resident of Dade County, Florida. Plaintiff is a covered 

employee for purposes of the Act.

3. Defendant Laundry Flagler LLC, a/k/a Soaphia Laundry Center (from now on, Soaphia 

Laundry Center, or Defendant) is a Florida corporation having a business in Dade County, 

Florida. 

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4. Individual Defendants Tanguy Letalaer and Phillippe Erb are the owners/partners/and 

managers of Defendant Corporation Soaphia Laundry Center. These individual Defendants

are the Employers of Plaintiff and others similarly situated within the meaning of Section 

3(d) of the "Fair Labor Standards Act" [29 U.S.C. § 203(d)].

5. Defendant Soaphia Laundry Center is engaged in interstate commerce as defined in §§ 3 

(r) and 3(s) of the Act, 29 U.S.C. § 203(r) and 203(s)(1)(A). Defendant is a retail business 

operating as a laundry center. Defendant uses the instrumentalities of interstate commerce. 

Defendant has more than two employees recurrently engaged in commerce or the 

production of goods for commerce by regularly and recurrently using the instrumentalities 

of interstate commerce to accept and solicit funds from non-Florida sources. Upon 

information and belief, the annual gross revenue of the Employer/Defendant was always 

in excess of $500,000 per annum. By reason of the foregoing, Defendant's business 

activities involve those to which the Fair Labor Standards Act applies. Therefore, there is 

FLSA enterprise coverage.

6. Plaintiff was employed by an enterprise engaged in interstate commerce. Through her daily 

activities, Plaintiff and other employees similarly situated regularly and recurrently

participated in interstate commerce by handling and working on goods and materials and 

materials that were produced for commerce and moved across State lines at any time during 

the business. Therefore, there is individual coverage.

7. At times mentioned, individual Defendants Tanguy Letalaer and Phillippe Erb were the 

owners/partners, and they directed Soaphia Laundry Center's operations. Defendants 

Tanguy Letalaer and Phillippe Erb were the employers of Plaintiff and other similarly 

situated individuals within the meaning of Section 3(d) of the "Fair Labor Standards Act" 

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[29 U.S.C. § 203(d)]. In that, these individual Defendants acted directly in the interests of

Soaphia Laundry Center concerning its employees, including Plaintiff and others similarly 

situated. Defendants Tanguy Letalaer and Phillippe Erb had financial and operational 

control of the business and provided Plaintiff with her work schedule. They are jointly and 

severally liable for Plaintiff's damages. 

8. All the actions raised in this complaint occurred in Dade County, Florida, within this 

Court's jurisdiction. 

Collective Action Allegations

9. Plaintiff brings this action pursuant to the Fair Labor Standards Act, 29 USC §§201, et seq.

("the Act"). Section 216 (b) for jurisdictional placement).

10. Plaintiff contends that Defendants, in this case, violated the Fair Labor Standards Act by 

failing to pay Plaintiff and other similarly situated individuals the proper compensation for 

every regular hour worked and overtime hours worked at the rate of time and one-half their 

regular rate.

11. This action is intended to include every laundry center employee and any similarly situated 

individuals who worked for Defendant at any time during the past three (3) years. 

COUNT I:

WAGE AND HOUR FEDERAL STATUTORY VIOLATION;

FAILURE TO PAY OVERTIME; AGAINST ALL DEFENDANTS

12. Plaintiff Barbara A. Garcia re-adopts every factual allegation stated in paragraphs 1-11 

above as if set out in full herein. 

13. This cause of action is brought by Plaintiff Barbara A. Garcia as a collective action to 

recover from Defendant overtime wages, liquidated damages, costs, and reasonable 

attorney's fees under the provisions of the Fair Labor Standards Act, as amended, 29 USC 

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§ 201 et seq (the "FLA or the "ACT") on behalf of Plaintiff and all other current and former 

employees similarly situated to Plaintiff ("the asserted class") and who worked more than 

forty (40) hours during one or more weeks on or after April 2021, (the "material time") 

without being adequately compensated. 

14. Defendant Soaphia Laundry Center is a coin laundry operated by Laundry Flagler LLC. 

Defendant Laundry Flagler LL operates several coin laundry. Plaintiff worked at Soaphia 

Laundry Center located at 1050 West Flagler ST, Miami, Florida 33130. 

15. Defendants Soaphia Laundry Center, Tanguy Letalaer, and Phillippe Erb employed 

Plaintiff Barbara A. Garcia from approximately April 28, 2021, to August 08, 2022, or 67 

weeks. 

16. Plaintiff was hired as a non-exempted, full-time, hourly laundry attendant. Plaintiff was 

paid a wage rate of $10.00 an hour. Plaintiff's overtime should be $15.00 an hour. 

17. Plaintiff had duties as a laundry employee, including laundry sorting, washing, drying, 

ironing, repairing work, folding, packing, etc. 

18. During her time of employment with Defendants, Plaintiff had an irregular schedule. 

Plaintiff worked weeks of 5 days and weeks of 6 days. Plaintiff worked minimum from 

7:00 AM to 5:00 PM (10 hours daily). Sometimes, Plaintiff began to work earlier, and she 

stayed working late. Thus, in weeks of 5 days, Plaintiff worked a minimum of 50 hours 

weekly. In weeks of 6 days, Plaintiff worked a minimum of 60 hours weekly. Plaintiff was 

unable to take bonafide lunch periods.

19. Plaintiff estimates that during her employment with Defendants, she worked 33 weeks with 

a minimum of 50 hours and 34 weeks with a minimum of 60 hours weekly.

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20. Plaintiff worked a substantial amount of overtime hours every week. However, Plaintiff 

was paid for less than 40 regular hours with checks, and she was paid in cash for an average 

of 5 overtime hours, but at her regular rate. The remaining overtime hours were not paid to 

Plaintiff at any rate, not even at the minimum wage rate. Plaintiff was not paid for overtime 

hours as required by the FLSA. 

21. Plaintiff clocked in and out, and Defendants could track the hours worked by Plaintiff and 

other similarly situated employees.

22. Therefore, Defendants willfully failed to pay Plaintiff for overtime hours at the rate of time 

and a half her regular rate for every hour that he worked in excess of forty (40), in violation 

of Section 7 (a) of the Fair Labor Standards Act of 1938 (29 U.S.C. 207(a)(1).

23. Plaintiff was paid bi-weekly in with checks and cash. Defendants refused to provide 

Plaintiff with paystubs providing basic information such as the number of days and hours 

worked, wage rate paid, employee taxes withheld, etc.

24. Plaintiff complained numerous times about missing payment for overtime and regular 

hours. 

25. On or about August 08, 2022, Plaintiff was fired by a new administration.

26. The records, if any, concerning the number of hours worked by Plaintiff and the 

compensation paid to such employees should be in the possession and custody of 

Defendants. However, Defendants did not maintain accurate time records of hours worked 

by Plaintiff and other employees, upon information and belief. Therefore, the Defendants 

violated the record-keeping requirements of FLSA, 29 CFR Part 516.

27. Upon information and belief, Defendants never posted any notice, as required by the Fair 

Labor Standards Act and Federal Law, to inform employees of their Federal rights to 

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overtime and minimum wage payments. Accordingly, Defendants violated the Posting 

requirements of 29 USC § 516.4. 

28. Plaintiff is not in possession of time and payment records, but she will provide a good faith 

estimate about her unpaid overtime hours based on her best recollections. 

*Please note that this amount is based on a preliminary calculation, and these figures could 

be subject to modification as discovery could dictate. 

a. Total amount of alleged unpaid O/T wages: 

Eleven Thousand Eight Hundred Dollars and 00/100 ($11,800.00) 

b. Calculation of such wages: 

Total period of employment: 67 weeks 

Relevant weeks of employment: 67 weeks 

Regular rate: $10.00 x 1.5=$15.00 O/T

O/T rate: $15.00 

O/T rate: $15.00-$10.00 O/T rate=$5.00 Half-time

Half-time: $5.00

1.- Overtime for 33 weeks with 50 working hours

Relevant weeks: 33 weeks 

Total hours worked: 50 hours weekly 

i.- Half-time for 5 hours weekly 

$5.00 x 5 O/T hours= $25.00 weekly x 33 weeks =$825.00 

ii.- Full overtime for 5 hours weekly 

$15.00 x 5 O/T hours=$75.00 weekly x 33 weeks=$2,475.00 

2.- Overtime for 34 weeks with 60 working hours

Relevant weeks: 34 weeks 

Total hours worked: 60 hours weekly 

i.- Half-time for 5 hours weekly 

$5.00 x 5 O/T hours= $25.00 weekly x 34 weeks =$850.00 

ii.- Full overtime for 15 hours weekly 

$15.00 x 15 O/T hours=$225.00 weekly x 34 weeks=$7,650.00 

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Total #1 and #2: $11,800.00 

 Nature of wages (e.g., overtime or straight time):

 This amount represents unpaid overtime wages. 

29. At all times, the Employers/Defendants failed to comply with Title 29 USC §207 (a) (1). 

In that, Plaintiff performed services and worked more than the maximum hours provided 

by the Act. Still, Defendants made no provision to properly pay Plaintiff at the rate of time 

and one-half for all hours worked over forty hours (40) per workweek as provided in said 

Act. 

30. Defendants showed reckless disregard of the provisions of the Act concerning the payment 

of overtime wages as required by the Fair Labor Standards Act and remained owing 

Plaintiff these overtime wages since the commencement of Plaintiff's employment with 

Defendants, as set forth above, and Plaintiff is entitled to recover double damages. 

31. Defendants Soaphia Laundry Center, Tanguy Letalaer, and Phillippe Erb willfully and 

intentionally refused to pay Plaintiff overtime wages at the rate of time and one-half her 

regular rate, as required by the law of the United States, and remain owing Plaintiff these 

overtime wages since the commencement of Plaintiff's employment with Defendants. 

32. Plaintiff has retained the law offices of the undersigned attorney to represent her in this 

action and is obligated to pay reasonable attorney's fees. 

Prayer for Relief 

Wherefore, Plaintiff Barbara A. Garcia respectfully requests that this Honorable Court: 

A. Enter judgment for Plaintiff Barbara A. Garcia and against the Defendants Soaphia 

Laundry Center and Tanguy Letalaer and Phillippe Erb based on Defendants' willful 

violations of the Fair Labor Standards Act, 29 USC § 201 et seq.; and 

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B. Award Plaintiff Barbara A. Garcia, actual damages in the amount shown to be due for 

unpaid overtime compensation for hours worked in excess of forty weekly, with 

interest; and

C. Award Plaintiff an equal amount in double damages/liquidated damages; and 

D. Award Plaintiff reasonable attorney's fees and costs of suit; and 

E. Grant such other and further relief as this Court deems equitable and just and/or 

available pursuant to Federal Law. 

Demand for a Jury Trial

Plaintiff Barbara A. Garcia demands a trial by a jury of all issues triable as a right by a jury. 

COUNT II:

FLSA WAGE AND HOUR FEDERAL STATUTORY VIOLATION: FAILURE TO 

PAY MINIMUM WAGE; AGAINST ALL DEFENDANTS

33. Plaintiff Barbara A. Garcia re-adopts every factual allegation stated in paragraphs 1-11 of 

this complaint as if set out in full herein.

34. Plaintiff Barbara A. Garciabrings this action to recover from the Employer Soaphia 

Laundry Center unpaid minimum wages, as well as an additional amount as liquidated 

damages, costs, and reasonable attorney's fees under the provisions of 29 USC § 201 et 

seq., and specifically under the provisions of 29 USC §206. 

35. Defendant Soaphia Laundry Center was and is subjected to the minimum wage provisions 

of the Fair Labor Standards Act (FLSA). 

36. USC §206 states, "Every Employer shall pay to each of his employees who in any 

workweek is engaged in commerce or the production of goods for commerce or is 

employed in an enterprise engaged in commerce or the production of goods for commerce, 

wages at the following rates: 

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 (1) except as otherwise provided in this section, not less than— 

(A) $5.85 an hour, beginning on the 60th day after May 25, 2008; 

(B) $6.55 an hour, beginning 12 months after that 60th day; and 

 (C) $7.25 an hour, beginning 24 months after that 60th day 

37. Defendants Soaphia Laundry Center, Tanguy Letalaer, and Phillippe Erb employed 

Plaintiff Barbara A. Garcia from approximately April 28, 2021, to August 08, 2022, or 67 

weeks. 

38. Plaintiff was hired as a non-exempted, full-time, hourly laundry attendant. Plaintiff was 

paid a wage rate of $10.00 an hour. 

39. Plaintiff had duties as a laundry employee, including laundry sorting, washing, drying, 

ironing, repairing work, folding, packing, etc. 

40. During her time of employment with Defendants, Plaintiff had an irregular schedule. 

Plaintiff worked weeks of 5 days and weeks of 6 days. Plaintiff worked minimum from 

7:00 AM to 5:00 PM (10 hours daily). Sometimes, Plaintiff began to work earlier, and she 

stayed working late. Thus, in weeks of 5 days, Plaintiff worked a minimum of 50 hours 

weekly. In weeks of 6 days, Plaintiff worked a minimum of 60 hours weekly. Plaintiff was 

unable to take bonafide lunch periods.

41. Plaintiff estimates that during her employment with Defendants, she worked 33 weeks with 

a minimum of 50 hours and 34 weeks with a minimum of 60 hours.

42. Plaintiff consistently and regularly worked more than 40 hours weekly, and Defendants 

always paid her a fraction of her overtime hours. However, Defendants paid Plaintiff for 

less than 40 regular hours. 

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43. Plaintiff estimates that during her time of employment, Defendants failed to pay Plaintiff 

an average of 3 regular hours weekly. 

44. There is a substantial amount of regular hours every week that were not paid to Plaintiff 

at any rate, not even at the minimum wage rate as required by law.

45. Plaintiff clocked in and out, and Defendants could track the hours worked by Plaintiff and 

other similarly situated employees.

46. Therefore, Defendant willfully failed to pay Plaintiff regular hours in violation of Section 

206 (a) of the Fair Labor Standards Act of 1938 (29 USC 206(a)(1).

47. Plaintiff was paid bi-weekly in with checks and cash. Defendants refused to provide 

Plaintiff with paystubs providing basic information such as the number of days and hours 

worked, wage rate paid, employee taxes withheld, etc.

48. Plaintiff complained numerous times about missing payment for overtime and regular 

hours. 

49. On or about August 08, 2022, Plaintiff was fired by a new administration.

50. The records, if any, concerning the number of hours worked by Plaintiff and those similarly 

situated and the compensation paid to such employees should be in the possession and 

custody of Defendants. However, upon information and belief, Defendants did not 

maintain accurate time records of hours worked by Plaintiff and other employees. 

Defendants violated the record-keeping requirements of FLSA, 29 CFR Part 516.

51. Upon information and belief, Defendants never posted any notice, as required by the Fair 

Labor Standards Act and Federal Law, to inform employees of their Federal rights to 

overtime and minimum wage payments. Accordingly, Defendants violated the Posting 

requirements of 29 USC § 516.4.

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52. Before the completion of discovery, and to the best of Plaintiff's knowledge, at the time of 

the filing of this complaint, Plaintiff's reasonable faith estimate of unpaid wages is as 

follows:

a. Total amount of alleged unpaid wages: 

Two Thousand Ten Dollars and 00/100 ($2,010.00) 

b. Calculation of such wages: 

Total weeks of employment: 67 weeks

Total number of hours worked: 50 and 60 hours weekly

Total number of regular unpaid hours: 3 hours weekly 

Regular rate: $10.00 an hour

$10.00 x 3 unpaid regular hours=$30.00 weekly x 67 weeks=$2,010.00 

c. Nature of wages:

This amount represents unpaid minimum wages at the Florida minimum 

wage rate.

53. Defendants unlawfully failed to pay Plaintiff Barbara A. Garcia minimum wages, as 

provided by the Fair Labor Standards Act. 

54. Defendants knew and showed reckless disregard of the provisions of the Act concerning 

the payment of minimum wages as required by the Fair Labor Standards Act and remain

owing Plaintiff and those similarly situated these minimum wages since the 

commencement of Plaintiff and those similarly situated employee's employment with 

Defendants as set forth above. Plaintiff and those similarly situated are entitled to recover 

double damages. 

55. Defendants Soaphia Laundry Center, Tanguy Letalaer, and Phillippe Erb willfully and 

intentionally refused to pay Plaintiff minimum wages as required by the Fair Labor 

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Standards Act and remain owing Plaintiff these minimum wages since the commencement 

of Plaintiff's employment with Defendants. 

56. Plaintiff has retained the law offices of the undersigned attorney to represent her in this 

action and is obligated to pay reasonable attorney's fees. 

Prayer for Relief

Wherefore, Plaintiff Barbara A. Garcia and those similarly situated respectfully request that this 

Honorable Court: 

A. Enter judgment for Plaintiff Barbara A. Garcia, and against the Defendants Soaphia 

Laundry Center, Tanguy Letalaer, and Phillippe Erb based on Defendants' willful 

violations of the Fair Labor Standards Act, 29 USC § 201 et seq. and other Federal 

Regulations; and 

B. Award Plaintiff Barbara A. Garcia actual damages in the amount shown to be due for 

unpaid minimum wages, with interest; and 

C. Award Plaintiff Barbara A. Garcia an equal amount in double damages/liquidated 

damages; and

D. Award Plaintiff Barbara A. Garcia reasonable attorneys' fees and costs of suit; and 

E. Grant such other and further relief as this Court deems equitable and just and/or 

available pursuant to Federal Law. 

Demand for a Jury Trial

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Plaintiff Barbara A. Garcia and those similarly situated demands trial by a jury of all issues triable 

as a right by a jury. 

Date: October 6, 2022 

 Respectfully submitted, 

 By: _/s/ Zandro E. Palma____ 

 ZANDRO E. PALMA, P.A.

 Florida Bar No.: 0024031 

 9100 S. Dadeland Blvd. 

 Suite 1500 

 Miami, FL 33156 

 Telephone: (305) 446-1500 

 Facsimile: (305) 446-1502 

 zep@thepalmalawgroup.com 

 Attorney for Plaintiff

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