UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

MARTIN J. WALSH, ) 

Secretary of Labor, ) FILE NO.

United States Department of Labor, ) 

) ___________________ 

Plaintiff, ) 

v. ) 

) 

SEATBELT SOLUTIONS, LLC and ) 

JEFFERY L. BIEGUN, an individual ) 

) 

) C O M P L A I N T

Defendants. ) (Injunctive Relief Sought)

Plaintiff brings this action pursuant to § 17 of the Act, 29 U.S.C. § 217, to have 

Seatbelt Solutions LLC and Jeffery L. Biegun enjoined from violating the provisions of §§ 6, 7, 

11(c), 15(a)(2) and 15(a)(5) of the Fair Labor Standards Act of 1938, as amended, 29 U.S.C. 

§ 201, et seq., hereinafter the Act; and, pursuant to § 16(c) of the Act, 29 U.S.C. § 216(c), to 

recover unpaid overtime wages, together with an equal amount as liquidated damages. 

I 

This Court has jurisdiction over this action pursuant to §§ 16(c) and 17 of the Act, 29 

U.S.C. § 217, to enjoin violations of the Act and to restrain the withholding of back wages due 

under the Act; and by 28 U.S.C. § 1345 to award additional amounts equal to back wages due as 

liquidated damages under § 16(c) of the Act, 29 U.S.C § 216(c). 

II

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A. Defendant, Seatbelt Solutions LLC (“Seatbelt Solutions”), at all times 

hereinafter mentioned, has been a corporation having a place of business and doing business in 

Palm Beach County, Florida.

B. Defendant, Jeff Biegun (“Biegun”) is Seatbelt Solution’s Owner, and at all 

times hereinafter mentioned, acted directly or indirectly in the interest of Defendant Seatbelt 

Solutions, in relation to their employees, and therefore is an employer within the meaning of § 

3(d) of the Act, 29 U.S.C. § 203(d). Biegun makes final decisions on the operation of the 

enterprise including but not limited to scheduling, staffing, and pay.

III

At all times hereinafter mentioned:

A. Defendants Seatbelt Solutions and Biegun (collectively “Defendants”),

engaged in related activities performed either through unified operation or common control for a 

common business purpose, constitutes an enterprise within the meaning of § 3(r) of the Act, 29 

U.S.C. § 203(r); and

B. Such enterprise, employing employees engaged in commerce or in the 

production of goods for commerce, or employees handling, selling or otherwise working on 

goods or materials that have been moved in or produced for commerce, such as manufacturing

seatbelts that are sold outside the state of Florida; and having an annual gross volume of sales 

made or business done of not less than $500,000 (exclusive of excise taxes at the retail level 

which are separately stated), constitutes an enterprise engaged in commerce or in the production 

of goods for commerce, within the meaning of § 3(s)(1)(A) of the Act, 29 U.S.C. § 203(s)(1)(A).

IV

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Since at least May 28, 2018, Defendant repeatedly violated the provisions of §§ 7 

and 15(a)(2) of the Act, 29 U.S.C. §§ 207 and 215(a)(2), by employing employees, including 

sales associates and machinists, in an enterprise engaged in commerce or in the production of 

goods for commerce, for workweeks longer than 40 hours without compensating such employees 

for their employment in excess of such hours at rates not less than one and one-half times the 

regular rates at which they were employed.

V

Since at least May 28, 2018, Defendants, an employer subject to the provisions of 

the Act, violated the provisions of §§ 11(c) and 15(a)(5) of the Act, 29 U.S.C. §§ 211(c) and 

215(a)(5), and Regulations found at 29 C.F.R. § 516 by failing to make, keep and preserve 

adequate and accurate records of the persons employed and of the wages, hours and other 

conditions and practices of employment maintained by them, as prescribed in the aforesaid 

Regulations.

VI

WHEREFORE, cause having been shown, Plaintiff prays for Judgment pursuant 

to § 17 of the Act, 29 U.S.C. § 217, permanently enjoining Defendants, their agents, servants, 

employees and all persons in active concert or participation with it from violating the provisions 

of §§ 6(a), 7(a), and 11(c) of the Act and pursuant to § 16(c) of the Act, 29 U.S.C. § 216(c), 

awarding back wages for a period of two (2) years prior to the commencement of this action, and 

an additional equal amount as liquidated damages to employees (as named in Appendix “A” 

attached hereto and made a part hereof and such other employees as hereafter may be identified 

and named prior to or at trial); and for such other and further relief as may be necessary and 

appropriate including costs of this action.

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Respectfully submitted,

ADDRESS: SEEMA NANDA 

Office of the Solicitor Solicitor of Labor 

U.S. Department of Labor 

61 Forsyth Street, S.W. TREMELLE I. HOWARD

Room 7T10 Regional Solicitor

Atlanta, GA 30303 

Telephone: 404.302.5445 

Facsimile: 404.302.5438 s/Daniel P. Miller

E-mail: fisher.jeremy.k@dol.gov DANIEL P. MILLER

 ATL.Fedcourt@dol.gov 

 miller.daniel.p@dol.gov 

 s/Jeremy K. Fisher 

 JEREMY K. FISHER 

 Counsel 

 

 Attorneys for Plaintiff, Martin J. Walsh, 

 Secretary of Labor, United States 

 Department of Labor 

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CERTIFICATE OF SERVICE

I hereby certify that on October 12, 2022, I electronically filed this Complaint 

with the Clerk of Court using the CM/ECF system and also served a copy of this 

Complaint via electronic mail on the following representative for Respondent: 

Adi Amit, 

101 Centre 

101 NE Third Avenue, Suite 300 

Ft. Lauderdale, FL 33301 

954-533-5922 

adi@defenderofbusiness.com

/s/ Daniel P. Miller

 DANIEL P. MILLER

Trial Attorney

Office of the Solicitor

U.S. Department of Labor 

61 Forsyth Street, S.W., Suite 7T10 

Atlanta, GA 30303 

(404) 302-5445 

(404) 302-5438 (FAX) 

miller.daniel.p@dol.gov 

Atlanta Docket

Atl.fedcourt@dol.gov

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