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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

CASE NO.:

Lori Weise,

and other similarly situated individuals,

Plaintiff (s),

v.

Blue Line Law Firm PLLC,

and Kevin J. Drummond, individually

Defendants,

___________________________________/ 

COLLECTIVE ACTION COMPLAINT

(OPT-IN PURSUANT TO 29 USC § 216(b))

Comes now the Plaintiff Lori Weise and other similarly situated individuals, by and 

through the undersigned counsel, and hereby sues Defendants Blue Line Law Firm PLLC, and 

Kevin J. Drummond, individually, and alleges:

Jurisdiction Venues and Parties

1. This is an action to recover money damage for unpaid regular wages and retaliation under 

United States laws. Accordingly, this Court has jurisdiction pursuant to the Fair Labor 

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

2. Plaintiff Lori Weise is a resident of Brevard County, Florida. Plaintiff is a covered employee

for purposes of the Act.

3. Defendant Blue Line Law Firm PLLC (from now on, Blue Line Law Firm, or Defendant) is a 

Florida corporation having a place of business in Palm Beach County, Florida.

4. Individual Defendant Kevin J. Drummond is the owner and manager of Blue Line Law Firm.

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5. Defendants Blue Line Law Firm and Kevin J. Drummond 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)].

6. All the actions raised in this complaint occurred in Palm Beach County, Florida, within this 

Court's jurisdiction. 

General Allegations

7. This cause of action is brought by Plaintiff Lori Weise as a collective action to recover from 

the Defendants minimum wages, retaliatory damages, liquidated damages, costs, and 

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

29 USC § 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 for 

Defendants during one or more weeks on or after April 2022, (the "material time") without 

being adequately compensated. 

8. Defendant Blue Line Law Firm is a law office located at 1645 Palm Beach Lakes Blvd., Suite 

1200, West Palm Beach, FL 33401. 

9. Defendants Blue Line Law Firm and Kevin J. Drummond employed Plaintiff Lori Weise as a 

non-exempted full-time, hourly employee, from April 25, 2022, to May 27, 2022, or 4 weeks. 

10. Plaintiff was hired to work remotely from home as a paralegal. Plaintiff had paralegal duties. 

At the time of her hiring, Plaintiff's wage rate was set at $21.00 an hour. 

11. During her time of employment with Defendant, Plaintiff had a regular schedule of 5 days per 

week. Plaintiff worked from Monday to Friday, from 9:00 AM to 5:00 PM (8 hours daily), or 

a total of 40 hours every week, but Defendants deducted one hour daily or five hours weekly 

as lunchtime.

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12. Plaintiff was required to clock out for one hour of lunchtime daily. However, at least two days 

per week, she was not able to take her lunchtime.

13. Furthermore, Plaintiff was required to work at least one off-the-clock hour every week (after 

hours). This hour constitutes one unpaid regular hour per week.

14. Plaintiff claims 3 regular unpaid hours per week (2 hours of lunchtime, plus 1 off-the-clock 

hour).

15. Plaintiff clocked in and out, and Defendant could track the number of hours worked by Plaintiff 

and other similarly situated individuals.

16. 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).

17. During her time of employment with Defendants, Plaintiff was not paid her wages, regularly 

on payment day,

18. Plaintiff complained multiple times about the lack of payment for regular hours to her manager,

Kevin J. Drummond.

19. As a direct result of Plaintiff's complaints, on or about May 22, 2022, Defendants lowered 

Plaintiff's working hours from 40 to 20 hours weekly, from 10:00 AM to 2:00 PM. However, 

Kevin J. Drummond called Plaintiff to request case status before 10:00 AM.

20. On or about May 27, 2022, Plaintiff did not receive her payment again. Thus, Plaintiff could 

not stand the payment issues and mistreatment received, and she was forced to resign from her 

employment with Defendants. 

21. On or about May 27, 2022, Plaintiff was constructively discharged for two reasons. One reason 

was the late payment issues, and the second reason was a discriminatory reason. Plaintiff is in 

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the process of filing her Charge of Discrimination with the U.S. Equal Employment 

Opportunity Commission (EEOC).

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

estimate about her unpaid hours.

23. Plaintiff Lori Weise intends to recover her regular hours, liquidated damages, retaliatory 

damages, and any other relief as allowable by law. 

Collective Action Allegations

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

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

25. Plaintiff contends that Defendant, in this case, violated the Fair Labor Standards Act by failing 

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

worked as required by the FLSA.

26. This action is intended to include every paralegal and any similarly situated individuals who 

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

COUNT I:

FLSA WAGE AND HOUR FEDERAL STATUTORY VIOLATION: FAILURE TO 

PAY MINIMUM WAGE

27. Plaintiff Lori Weise re-adopts every factual allegation stated in paragraphs 1-26 of this 

complaint as if set out in full herein.

28. Plaintiff Lori Weise brings this action to recover from the Employer Blue Line Law Firm

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. 

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29. Defendant Blue Line Law Firm was and 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 provides legal services 

through its business activity, affecting interstate commerce. Defendant had 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. Defendant uses 

the instrumentalities of interstate commerce to accept and solicit funds from non-Florida 

sources by using electronic devices to authorize credit card transactions. Upon information and 

belief, the annual gross revenue of the Employer/Defendant was always more than $500,000 

per annum. Therefore, there is FLSA enterprise coverage.

30. Plaintiff and those similarly situated were employed by an enterprise engaged in interstate 

commerce. Plaintiff and those similarly situated through their daily activities regularly 

participated in interstate commerce. Plaintiff's work was directed to support the activities of a 

law firm providing legal services. Therefore, there is FLSA individual coverage.

31. Defendant Blue Line Law Firm was and is subjected to the minimum wage provisions of the 

Fair Labor Standards Act (FLSA).

32. 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

33. the production of goods for commerce, wages at the following rates: 

(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

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34. Defendants Blue Line Law Firm and Kevin J. Drummond employed Plaintiff Lori Weise as a 

non-exempted full-time, hourly employee, from April 25, 2022, to May 27, 2022, or 4 weeks. 

35. Plaintiff was hired to work remotely from home as a paralegal. Plaintiff had paralegal duties. 

At the time of her hiring, Plaintiff's wage rate was set at $21.00 an hour. 

36. During her time of employment with Defendant, Plaintiff had a regular schedule of 5 days per 

week. Plaintiff worked from Monday to Friday, from 9:00 AM to 5:00 PM (8 hours daily), or 

a total of 40 hours every week, but Defendants deducted one hour daily, or 5 hours of lunchtime 

weekly.

37. Plaintiff was required to clock out for one hour of lunchtime daily. However, at least two days 

per week, she was not able to take her lunchtime.

38. Furthermore, Plaintiff was required to work at least one off-the-clock hour every week (after 

the hour). This hour constitutes one unpaid hour per week. 

39. Plaintiff claims 3 regular unpaid hours per week (2 hours of lunchtime, plus 1 off-the-clock 

hour).

40. Plaintiff clocked in and out, and Defendant could track the number of hours worked by Plaintiff 

and other similarly situated individuals.

41. 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).

42. Plaintiff was paid by direct deposits and by Zelle.

43. 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 Defendant. However, upon information and belief, Defendant did not maintain accurate 

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time records of hours worked by Plaintiff and other employees. Defendant violated the recordkeeping requirements of FLSA, 29 CFR Part 516.

44. 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:

* Florida's minimum wage for 2022 is $10.00, which is higher than the Federal minimum wage. 

As per FLSA regulations, the higher minimum wage applies.

a. Total amount of alleged unpaid wages:

One Hundred Twenty Dollars and 00/100 ($120.00)

b. Calculation of such wages: 

Total weeks of employment: 4 weeks plus 

Total relevant weeks: 4 weeks

Total hours worked: 35 weekly average

Total number of unpaid hours: 3 hours weekly

Regular rate: $21.00

FL Minimum wage rate 2022: $10.00

$10.00 x 3 unpaid regular hours $30.00 weekly x 4 weeks=$120.00 weekly

c. Nature of wages:

This amount represents regular unpaid hours at the Florida minimum wage rate

45. Defendant unlawfully failed to pay Plaintiff Lori Weise minimum wages as required by law.

46. Defendant 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 remains owing 

Plaintiff and those similarly situated these minimum wages since the commencement of 

Plaintiff and those similarly situated employee's employment with Defendant as set forth 

above. Plaintiff and those similarly situated are entitled to recover double damages. 

47. At times mentioned, individual Defendant Kevin J. Drummond was the owner and operator of 

Blue Line Law Firm. Defendant Kevin J. Drummond was the Employer of Plaintiff and others 

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similarly situated within the meaning of Section 3(d) of the "Fair Labor Standards Act" [29 

U.S.C. § 203(d)]. This individual Defendant acted directly in the interests of corporate 

Defendant in relation to its employees, including Plaintiff and others similarly situated. 

Defendant Kevin J. Drummond had financing and operational control of the corporation, he 

was responsible for Plaintiff and other similarly situated employees' working conditions, and 

he is jointly and severally liable for Plaintiff's damages. 

48. Defendant Blue Line Law Firm and Kevin J. Drummond willfully and intentionally refused to 

pay Plaintiff minimum wages as required by the Fair Labor Standards Act and remain owing 

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

Defendant. 

49. 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 Lori Weise and those similarly situated respectfully request that this 

Honorable Court: 

A. Enter judgment for Plaintiff Lori Weise and against Defendants Blue Line Law Firm and Kevin 

J. Drummond based on Defendants' willful violations of the Fair Labor Standards Act, 29 USC

§ 201 et seq. and other Federal Regulations; and

B. Award Plaintiff Lori Weise actual damages in the amount shown to be due for unpaid 

minimum wages, with interest; and

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

D. Award Plaintiff Lori Weise 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 

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pursuant to Federal Law. 

Demand for a Jury Trial

Plaintiff Lori Weise and those similarly situated demand trial by a jury of all issues triable as

a right by a jury.

COUNT II:

FEDERAL STATUTORY VIOLATION: RETALIATORY CONSTRUCTIVE 

DISCHARGE; PURSUANT TO 29 USC 215(a)(3

50. Plaintiff Lori Weise re-adopts every factual allegation stated in paragraphs 1-26 of this 

complaint as if set out in full herein.

51. Defendant Blue Line Law Firm was and is engaged in interstate commerce as defined in §§ 3 

(r) and 3(s) of the Act, 29 USC § 203(r) and 203(s)(1)(A). Defendant had more than two 

employees recurrently engaged in commerce or the production of goods for commerce. Upon 

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

material hereto more than $500,000 per annum. Therefore, there is FLSA enterprise coverage.

52. Plaintiff and those similarly situated were employed by an enterprise engaged in interstate 

commerce. Plaintiff and those similarly situated through their daily activities regularly 

participated in interstate commerce. Plaintiff's work was directed to support the activities of a 

law firm providing legal services. Therefore, there is FLSA individual coverage.

53. By reason of the foregoing, Defendant's business activities involve those to which the Fair 

Labor Standards Act applies. 

54. 29 USC § 206 (a) (1) states "....an Employer must pay a minimum wage of $5.15/hr. to an 

employee who is engaged in commerce...." [29 U.S.C. § 206 (a) (1)].

55. Likewise, 29 USC 215(a)(3) states... it shall be unlawful for any person— "to discharge or in 

any other manner discriminate against any employee because such employee has filed any 

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complaint or instituted or caused to be instituted any proceeding under or related to this chapter, 

or has testified or is about to testify in any such proceeding,......"

56. Defendants Blue Line Law Firm and Kevin J. Drummond employed Plaintiff Lori Weise as a 

non-exempted full-time, hourly employee, from April 25, 2022, to May 27, 2022, or 4 weeks. 

57. Plaintiff was hired to work remotely from home as a paralegal. Plaintiff had paralegal duties. 

At the time of her hiring, Plaintiff's wage rate was set at $21.00 an hour. 

58. During her time of employment with Defendant, Plaintiff had a regular schedule of 5 days per 

week. Plaintiff worked from Monday to Friday, from 9:00 AM to 5:00 PM (8 hours daily), or 

a total of 40 hours every week, but Defendants deducted one hour daily, or 5 hours of lunchtime 

weekly.

59. Plaintiff was required to clock out for one hour of lunchtime daily. However, at least two days 

per week, she was not able to take her lunchtime.

60. Furthermore, Plaintiff was required to work at least one off-the-clock hour every week. This 

hour constitutes one unpaid hour per week. 

61. Plaintiff claims 3 unpaid regular hours per week (2 hours of lunchtime, plus 1 off-the-clock 

hour).

62. Plaintiff clocked in and out, and Defendant could track the number of hours worked by Plaintiff 

and other similarly situated individuals.

63. 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).

64. During her time of employment with Defendants, Plaintiff was not paid her wages regularly 

on the payment day,

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65. Plaintiff complained multiple times about the lack of payment for regular hours to her manager, 

Kevin J. Drummond. 

66. These complaints constituted protected activity under the FLSA.

67. However, as s a direct result of Plaintiff's complaints, on or about May 22, 2022, Defendants 

lowered Plaintiff's working hours from 40 to 20 hours weekly, from 10:00 AM to 2:00 PM. 

Despite Plaintiff's reduced schedule, Kevin J. Drummond called her to request case status 

before 10:00 AM.

68. This reduction of working hours constituted an adverse retaliatory employment action

69. On or about May 27, 2022, Plaintiff did not receive her payment again. Thus, Plaintiff could 

not stand the payment issues, and she was forced to leave her employment with Defendants. 

70. Consequently, on or about May 27, 2022, Plaintiff was constructively discharged. The harsh 

and unfair working conditions forced Plaintiff to quit. No reasonable person could continue 

working under the unfair conditions established by Defendants. 

71. The motivating factor which caused Plaintiff's constructive discharge, as described above, was 

her complaints seeking regular wages from the Defendants. In other words, Plaintiff would not 

have been discharged but for her complaints about regular wages.

72. There is close proximity between Plaintiff's protected activity and her discharge.

73. At all times during her employment, Plaintiff performed her work satisfactorily. There was no 

reason other than unlawful employment practices or retaliation to constructively discharge 

Plaintiff.

74. The Defendants' termination or constructive discharge of Plaintiff was in direct violation of 29 

U.S.C. 215 (a) (3) and, as a direct result, Plaintiff has been damaged.

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75. At times mentioned, individual Defendant Kevin J. Drummond was the owner and operator of 

Blue Line Law Firm. Defendant Kevin J. Drummond was the Employer 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)]. This individual Defendant acted directly in the interests of corporate 

Defendant in relation to its employees, including Plaintiff and others similarly situated. 

Defendant Kevin J. Drummond had financing and operational control of the corporation, he 

was responsible for Plaintiff and other similarly situated employees' working conditions, and 

he is jointly and severally liable for Plaintiff's damages. 

76. Plaintiff Lori Weise has retained the law offices of the undersigned attorney to represent her

in this action and is obligated to pay reasonable attorneys' fees. 

Prayer For Relief

Wherefore, Plaintiff Lori Weise respectfully requests that this Honorable Court:

A. Issue a declaratory judgment that the Defendants' acts, policies, practices, and procedures 

complained of herein violated provisions of the Fair Labor Standards Act; 

B. Enter judgment against Defendants Blue Line Law Firm and Kevin J. Drummond that 

Plaintiff Lori Weise recovers compensatory damages and an equal amount of liquidated 

damages as provided under the law and in 29 USC § 216(b); 

C. That Plaintiff recovers an award of reasonable attorney fees, costs, and expenses. 

D. Order Defendants Blue Line Law Firm and Kevin J. Drummond to make whole Plaintiff

by providing appropriate back pay and other benefits wrongly denied in an amount to be 

shown at trial and other affirmative relief; 

E. Plaintiff Lori Weise further prays for such additional relief as the interests of justice 

may require.

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Demand for a Jury Trial

Plaintiff Lori Weise demands a trial by a jury of all issues triable as a right by a jury.

 Date: October 7, 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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