EXHIBIT A EXHIBIT A 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 1 of 29
Filing # 157962739 E-Filed 09/22/2022 02:42:57 PM 

FORM 1.997. CIVIL COVER SHEET 

The civil cover sheet and the information contained in it neither replace nor supplement the filing 

and service of pleadings or other documents as required by law. This form must be filed by the 

plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant 

to section 25.075, Florida Statutes. (See instructions for completion.) 

I. CASE STYLE 

IN THE CIRCUIT/COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT, 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

Maria Matos 

Plaintiff 

vs. 

Physicians Central Business Office LLC, Mark A. Cereceda 

Defendant 

Case # 

Judge 

II. AMOUNT OF CLAIM 

Please indicate the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of 

the claim is requested for data collection and clerical processing purposes only. The amount of the claim 

shall not be used for any other purpose. 

❑ $8,000 or less 

❑ $8,001 - $30,000 

$30,001- $50,000 

❑ $50,001- $75,000 

❑ $75,001 - $100,000 

❑ over $100,000.00 

III. TYPE OF CASE (If the case fits more than one type of case, select the most 

definitive category.) If the most descriptive label is a subcategory (is indented under a broader 

category), place an x on both the main category and subcategory lines. 

- 1 1 -

FORM 1.997. CIVIL COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing

and service of pleadings or other documents as required by law. This form must be filed by the

plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant

to section 25.075, Florida Statutes. (See instructions for completion.)

I. CASE STYLE

IN THE CIRCUIT/COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Maria Matos

Plaintiff Case #

Judge

vs.

Physicians Central Business Office LLC, Mark A. Cereceda

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of

the claim is requested for data collection and clerical processing purposes only. The amount of the claim

shall not be used for any other purpose. 

 ☐ $8,000 or less

☐ $8,001 - $30,000

☒ $30,001- $50,000

☐ $50,001- $75,000

☐ $75,001 - $100,000

☐ over $100,000.00

III. TYPE OF CASE (If the case fits more than one type of case, select the most

definitive category.) If the most descriptive label is a subcategory (is indented under a broader

category), place an x on both the main category and subcategory lines.

Filing # 157962739 E-Filed 09/22/2022 02:42:57 PM Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 2 of 29
CIRCUIT CIVIL 

❑ Condominium 

❑ Contracts and indebtedness 

❑ Eminent domain 

❑ Auto negligence 

❑ Negligence—other 

❑ Business governance 

❑ Business torts 

❑ Environmental/Toxic tort 

❑ Third party indemnification 

❑ Construction defect 

❑ Mass tort 

❑ Negligent security 

❑ Nursing home negligence 

❑ Premises liability—commercial 

❑ Premises liability—residential 

❑ Products liability 

❑ Real Property/Mortgage foreclosure 

❑ Commercial foreclosure 

❑ Homestead residential foreclosure 

❑ Non-homestead residential foreclosure 

❑ Other real property actions 

0 Professional malpractice 

❑ Malpractice—business 

❑ Malpractice—medical 

❑ Malpractice—other professional 

z Other 

❑ Antitrust/Trade regulation 

❑ Business transactions 

❑ Constitutional challenge—statute or ordinance 

❑ Constitutional challenge—proposed amendment 

❑ Corporate trusts 

❑ Discrimination—employment or other 

❑ Insurance claims 

❑ Intellectual property 

❑ Libel/Slander 

❑ Shareholder derivative action 

❑ Securities litigation 

❑ Trade secrets 

❑ Trust litigation 

COUNTY CIVIL 

❑ Small Claims up to $8,000 

❑ Civil 

❑ Real property/Mortgage foreclosure 

- 2 2 -

CIRCUIT CIVIL

☐ Condominium

☐ Contracts and indebtedness

☐ Eminent domain

☐ Auto negligence

☐ Negligence—other

☐ Business governance

☐ Business torts

☐ Environmental/Toxic tort

☐ Third party indemnification

☐ Construction defect

☐ Mass tort

☐ Negligent security

☐ Nursing home negligence

☐ Premises liability—commercial

☐ Premises liability—residential

☐ Products liability

 ☐ Real Property/Mortgage foreclosure

☐ Commercial foreclosure

☐ Homestead residential foreclosure

☐ Non-homestead residential foreclosure

☐ Other real property actions

☐Professional malpractice

☐ Malpractice—business

☐ Malpractice—medical

☐ Malpractice—other professional

☒ Other

☐ Antitrust/Trade regulation

☐ Business transactions

☐ Constitutional challenge—statute or ordinance

☐ Constitutional challenge—proposed amendment

☐ Corporate trusts

☐ Discrimination—employment or other

☐ Insurance claims

☐ Intellectual property

☐ Libel/Slander

☐ Shareholder derivative action

☐ Securities litigation

☐ Trade secrets

☐ Trust litigation

COUNTY CIVIL

☐ Small Claims up to $8,000

☐ Civil

☐ Real property/Mortgage foreclosure 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 3 of 29
❑ Replevins 

❑ Evictions 

❑ Residential Evictions 

❑ Non-residential Evictions 

❑ Other civil (non-monetary) 

COMPLEX BUSINESS COURT 

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the 

Administrative Order. Yes ❑ No IZI 

IV. REMEDIES SOUGHT (check all that apply): 

Monetary; 

Nonmonetary declaratory or injunctive relief; 

❑ Punitive 

V. NUMBER OF CAUSES OF ACTION: [ ] 

(Specify) 

2 

VI. IS THIS CASE A CLASS ACTION LAWSUIT? 

❑ yes 

no 

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED? 

no 

❑ yes If "yes," list all related cases by name, case number, and court. 

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT? 

yes 

❑ no 

IX. DOES THIS CASE INVOLVE ALLEGATIONS OF SEXUAL ABUSE? 

❑ yes 

no 

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of 

my knowledge and belief, and that I have read and will comply with the requirements of 

Florida Rule of Judicial Administration 2.425. 

Signature: s/ Jorge Freddy Perera Fla. Bar # 93625 

Attorney or party 

Jorge Freddy Perera 

(type or print name) 

09/22/2022 

Date 

(Bar # if attorney) 

- - 3 3 - -

☐ Replevins

☐ Evictions

☐ Residential Evictions

☐ Non-residential Evictions

☐ Other civil (non-monetary)

COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the

Administrative Order. Yes ☐ No ☒

IV. REMEDIES SOUGHT (check all that apply):

☒ Monetary;

☒ Nonmonetary declaratory or injunctive relief;

☐ Punitive

V. NUMBER OF CAUSES OF ACTION: [ ]

(Specify)

2

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

☐ yes

☒ no

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

☒ no

☐ yes If “yes,” list all related cases by name, case number, and court.

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

☒ yes

☐ no

IX. DOES THIS CASE INVOLVE ALLEGATIONS OF SEXUAL ABUSE?

☐ yes

☒ no

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of

my knowledge and belief, and that I have read and will comply with the requirements of

Florida Rule of Judicial Administration 2.425.

Signature: s/ Jorge Freddy Perera Fla. Bar # 93625

Attorney or party (Bar # if attorney)

Jorge Freddy Perera 09/22/2022

(type or print name) Date

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 4 of 29
Filing # 157962739 E-Filed 09/22/2022 02:42:57 PM 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

CASE NO.: 

MARIA MATOS, 

and all others similarly situated under 

29 U.S.C. §216(b), 

Plaintiff(s), 

vs. 

PHYSICIANS CENTRAL BUSINESS OFFICE, LLC, 

a Florida For-Profit Corporation, and 

MARK A. CERECEDA, individually, 

Defendants. 

/ 

COMPLAINT 

Collective Action Pursuant to 29 U.S.C. §216(b) 

MARIA MATOS ("Plaintiff'), by and through the undersigned counsel and 

on behalf of all similarly-situated individuals, hereby sues PHYSICIANS 

CENTRAL BUSINESS OFFICE, LLC ("Physicians Central"), a Florida For-Profit 

Corporation, and MARK A. CERECEDA ("Cereceda"), individually (collectively 

"Defendants") and alleges as follows: 

INTRODUCTION 

1. This is an action for unpaid overtime wages pursuant to the Fair 

Labor Standards Act, 29 U.S.C. §§ 201 et seq. ("FLSA"). 

2. Plaintiff seeks in excess of $30,000.00 in damages, exclusive of 

attorneys' fees and costs, as is within this Court's jurisdiction, reasonable 

1 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

1 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

CASE NO.: _________________ 

 

MARIA MATOS, 

and all others similarly situated under 

29 U.S.C. §216(b), 

 Plaintiff(s), 

vs. 

 

PHYSICIANS CENTRAL BUSINESS OFFICE, LLC, 

a Florida For-Profit Corporation, and 

MARK A. CERECEDA, individually, 

 

Defendants. 

___________________________________________/ 

COMPLAINT 

Collective Action Pursuant to 29 U.S.C. §216(b) 

MARIA MATOS (“Plaintiff”), by and through the undersigned counsel and 

on behalf of all similarly-situated individuals, hereby sues PHYSICIANS 

CENTRAL BUSINESS OFFICE, LLC (“Physicians Central”), a Florida For-Profit 

Corporation, and MARK A. CERECEDA (“Cereceda”), individually (collectively 

“Defendants”) and alleges as follows: 

INTRODUCTION 

1. This is an action for unpaid overtime wages pursuant to the Fair 

Labor Standards Act, 29 U.S.C. §§ 201 et seq. (“FLSA”). 

2. Plaintiff seeks in excess of $30,000.00 in damages, exclusive of 

attorneys’ fees and costs, as is within this Court’s jurisdiction, reasonable 

Filing # 157962739 E-Filed 09/22/2022 02:42:57 PM Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 5 of 29
attorneys' fees, and costs pursuant to the FLSA, and all other remedies allowable 

by law. 

PARTIES, JURISDICTION, AND VENUE 

3. Plaintiff was formerly employed by Defendants and performed work 

for Defendants in Miami-Dade County, Florida. 

4. Physicians Central is, and was, a Florida For-Profit Corporation 

conducting business in Miami-Dade County. 

5. Cereceda is, and was, a corporate officer for/operator of Physicians 

Central during the relevant time period. Further, Cereceda controlled the 

business and Physicians Central's employees (including Plaintiff) in terms of 

hiring, firing, scheduling, duties, work hours, calculation of wages, paying of 

wages, and ensuring compliance with local, state, and federal laws, including, 

but not limited to, the FLSA. 

6. Physicians Central and Cereceda are employers, joint employer, or 

co-employer for purposes of the FLSA as the term is defined by 29 U.S.C. § 203. 

7. Venue is proper in this Court because Defendants transact business 

in this Circuit, Defendants maintain a principal place of business in this Circuit, 

Defendants employed Plaintiff in this Circuit, and the claims arose within the 

Circuit. 

2 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

2 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

attorneys’ fees, and costs pursuant to the FLSA, and all other remedies allowable 

by law.

PARTIES, JURISDICTION, AND VENUE

3. Plaintiff was formerly employed by Defendants and performed work 

for Defendants in Miami-Dade County, Florida.

4. Physicians Central is, and was, a Florida For-Profit Corporation 

conducting business in Miami-Dade County.

5. Cereceda is, and was, a corporate officer for/operator of Physicians 

Central during the relevant time period. Further, Cereceda controlled the 

business and Physicians Central’s employees (including Plaintiff) in terms of 

hiring, firing, scheduling, duties, work hours, calculation of wages, paying of 

wages, and ensuring compliance with local, state, and federal laws, including, 

but not limited to, the FLSA. 

6. Physicians Central and Cereceda are employers, joint employer, or 

co-employer for purposes of the FLSA as the term is defined by 29 U.S.C. § 203. 

7. Venue is proper in this Court because Defendants transact business 

in this Circuit, Defendants maintain a principal place of business in this Circuit, 

Defendants employed Plaintiff in this Circuit, and the claims arose within the 

Circuit. 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 6 of 29
GENERAL ALLEGATIONS 

A. Defendants' Business and Interstate Commerce 

8. The primary purpose of Physicians Central is to provide health 

services to its patients/clients in the specialized field of occupational medicine. 

9. Physicians Central operates four to five locations across Miami-Dade 

County, Florida. 

10. Under information and belief, Plaintiff alleges that Physicians 

Central's gross annual revenue exceeded $500,000.00 during 2019, 2020, 2021 

and is expected to exceed $500,000.00 during 2022. 

11. Physicians Central customarily and regularly sold goods and 

services across state lines. 

12. At all relevant times, Physicians Central employed two or more 

employees that customarily, continually, and regularly handled goods and 

materials that i) were purchased from a person or entity outside the state of 

Florida and/or ii) were purchased in Florida but had previously traveled through 

interstate commerce. 

13. Upon information and belief, Physicians Central obtained and 

solicited funds from non-Florida sources, accepted funds from non-Florida 

sources, used telephonic (or other electronic) transmissions going over state lines 

to do its business, transmitted funds outside the State of Florida, used electronic 

means to market and run their business in a way that was not limited to Florida, 

3 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

3 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

GENERAL ALLEGATIONS 

A. Defendants’ Business and Interstate Commerce 

8. The primary purpose of Physicians Central is to provide health 

services to its patients/clients in the specialized field of occupational medicine.

9. Physicians Central operates four to five locations across Miami-Dade 

County, Florida.

10. Under information and belief, Plaintiff alleges that Physicians 

Central’s gross annual revenue exceeded $500,000.00 during 2019, 2020, 2021 

and is expected to exceed $500,000.00 during 2022. 

11. Physicians Central customarily and regularly sold goods and 

services across state lines. 

12. At all relevant times, Physicians Central employed two or more 

employees that customarily, continually, and regularly handled goods and 

materials that i) were purchased from a person or entity outside the state of 

Florida and/or ii) were purchased in Florida but had previously traveled through 

interstate commerce. 

13. Upon information and belief, Physicians Central obtained and 

solicited funds from non-Florida sources, accepted funds from non-Florida 

sources, used telephonic (or other electronic) transmissions going over state lines 

to do its business, transmitted funds outside the State of Florida, used electronic 

means to market and run their business in a way that was not limited to Florida, 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 7 of 29
and otherwise regularly engaged in interstate commerce during the relevant 

period. 

14. Physicians Central, upon information and belief, accepts checks, 

wire transfers, and other forms of payments that are made or processed outside 

the state of Florida, and did so during the relevant period. 

15. Physicians Central is an employer engaged in interstate commerce 

and subject to the FLSA. 

B. Defendants' Employment and Failure to Properly Pay Plaintiff 

16. Plaintiffs employment with Defendants began during 2019. 

17. During her employment, Plaintiff worked as a non-exempt "New 

Patient Coordinator" earning an annual salary of $45,000.00. 

18. Plaintiff was required to answer calls from new patients seeking 

services from all of Defendants' locations. 

19. Throughout the relevant time period, Plaintiff regularly worked 

overtime hours where her work hours reached, at least, sixty (60) hours (some 

weeks it was decidedly more) per week without proper overtime wages as required 

by the FLSA. 

20. Defendants have knowledge of Plaintiffs work hours as she was 

required to clock in and out each day. 

21. Further, Defendants regularly required Plaintiff to work off the clock. 

22. During the relevant time period Plaintiff was required to answer new 

patient calls after work hours. This off-the-clock, on-call time was not captured 

4 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

4 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

and otherwise regularly engaged in interstate commerce during the relevant 

period.

14. Physicians Central, upon information and belief, accepts checks, 

wire transfers, and other forms of payments that are made or processed outside 

the state of Florida, and did so during the relevant period. 

15. Physicians Central is an employer engaged in interstate commerce 

and subject to the FLSA. 

B. Defendants’ Employment and Failure to Properly Pay Plaintiff 

16. Plaintiff’s employment with Defendants began during 2019. 

17. During her employment, Plaintiff worked as a non-exempt “New 

Patient Coordinator” earning an annual salary of $45,000.00.

18. Plaintiff was required to answer calls from new patients seeking 

services from all of Defendants’ locations.

19. Throughout the relevant time period, Plaintiff regularly worked 

overtime hours where her work hours reached, at least, sixty (60) hours (some 

weeks it was decidedly more) per week without proper overtime wages as required 

by the FLSA. 

20. Defendants have knowledge of Plaintiff’s work hours as she was 

required to clock in and out each day.

21. Further, Defendants regularly required Plaintiff to work off the clock. 

22. During the relevant time period Plaintiff was required to answer new 

patient calls after work hours. This off-the-clock, on-call time was not captured 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 8 of 29
by Defendants' timekeeping system but was nonetheless strictly required as part 

of Plaintiffs regular job duties. Such off-the-clock, on-call work would occur 

throughout the week, including weekends. 

23. Defendants intentionally refused to pay Plaintiff overtime wages she 

was owed under the FLSA. 

24. Indeed, Defendants had complete knowledge of Plaintiffs overtime 

hours where the timekeeping system and on-call requirements revealed the 

same. Despite this knowledge, Defendants willfully and purposefully did not 

tender Plaintiff her full and proper overtime wages he was owed under the FLSA. 

25. Defendants were Plaintiffs employer, joint employer, or co-employer 

for purposes of the FLSA as the term employer is defined by 29 U.S.C. § 203 and, 

as such, jointly and severally owe Plaintiff unpaid overtime wages. 

C. Cereceda's Employment of, and Failure to Properly Pay, Plaintiff 

26. During the relevant period, Cereceda was Plaintiffs 

manager/supervisor as well as the general operator of the business. 

27. During Plaintiffs employment, Cereceda acted as Plaintiffs 

supervisor/manager, provided Plaintiff with her work duties, gave feedback on 

the work Plaintiff performed for Defendants, had the ability to discipline Plaintiff 

and other employees, and was responsible for recording, calculating, and paying 

Plaintiffs work hours. 

5 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

5 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

by Defendants’ timekeeping system but was nonetheless strictly required as part 

of Plaintiff’s regular job duties. Such off-the-clock, on-call work would occur 

throughout the week, including weekends.

23. Defendants intentionally refused to pay Plaintiff overtime wages she 

was owed under the FLSA. 

24. Indeed, Defendants had complete knowledge of Plaintiff’s overtime 

hours where the timekeeping system and on-call requirements revealed the 

same. Despite this knowledge, Defendants willfully and purposefully did not 

tender Plaintiff her full and proper overtime wages he was owed under the FLSA.

25. Defendants were Plaintiff’s employer, joint employer, or co-employer 

for purposes of the FLSA as the term employer is defined by 29 U.S.C. § 203 and, 

as such, jointly and severally owe Plaintiff unpaid overtime wages. 

C. Cereceda’s Employment of, and Failure to Properly Pay, Plaintiff

26. During the relevant period, Cereceda was Plaintiff’s 

manager/supervisor as well as the general operator of the business. 

27. During Plaintiff’s employment, Cereceda acted as Plaintiff’s 

supervisor/manager, provided Plaintiff with her work duties, gave feedback on 

the work Plaintiff performed for Defendants, had the ability to discipline Plaintiff

and other employees, and was responsible for recording, calculating, and paying 

Plaintiff’s work hours.

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 9 of 29
28. Cereceda, at all material times, was on notice of Plaintiffs work 

hours and off-the-clock, on-call work but purposefully did not investigate nor 

remedy the due and owing overtime wages. 

29. Cereceda intentionally refused to pay Plaintiff overtime wages she is 

owed under the FLSA. 

30. Cereceda is partially or totally responsible for paying Plaintiffs due 

and owing overtime wages. 

31. Cereceda must be considered Plaintiffs employers, joint employer, 

or co-employer for purposes of the FLSA as the term employer is defined by 29 

U.S.C. § 203. 

D. Defendants' Illegal Payment Practices Affected All Other Similarly 

Situated Employees. 

32. During the relevant time period, Defendants employ other 

individuals performing services similar to Plaintiff. 

33. These similarly-situated individuals were also required to work offthe-clock, on-call duties in answering/responding to new patient calls 

throughout the night and weekend. 

34. Through this misclassification, these other individuals were paid in 

a same or similar fashion (salary without any overtime pay) as Plaintiff that 

violates the FLSA. 

35. Defendants employ other individuals that customarily and regularly 

performed overtime work for which they were not compensated either fully 

and/or at the correct rate. 

6 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

6 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

28. Cereceda, at all material times, was on notice of Plaintiff’s work 

hours and off-the-clock, on-call work but purposefully did not investigate nor 

remedy the due and owing overtime wages.

29. Cereceda intentionally refused to pay Plaintiff overtime wages she is 

owed under the FLSA. 

30. Cereceda is partially or totally responsible for paying Plaintiff’s due 

and owing overtime wages. 

31. Cereceda must be considered Plaintiff’s employers, joint employer, 

or co-employer for purposes of the FLSA as the term employer is defined by 29 

U.S.C. § 203. 

D. Defendants' Illegal Payment Practices Affected All Other Similarly 

Situated Employees. 

32. During the relevant time period, Defendants employ other 

individuals performing services similar to Plaintiff. 

33. These similarly-situated individuals were also required to work offthe-clock, on-call duties in answering/responding to new patient calls 

throughout the night and weekend.

34. Through this misclassification, these other individuals were paid in 

a same or similar fashion (salary without any overtime pay) as Plaintiff that 

violates the FLSA.

35. Defendants employ other individuals that customarily and regularly 

performed overtime work for which they were not compensated either fully 

and/or at the correct rate. 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 10 of 29
36. The potential class of aggrieved individuals working for Defendants 

and subject to this misclassification have worked over forty (40) hours a week 

during the last three (3) years without being paid at a proper time-and-a-half 

their regular rate of pay for all overtime hours worked. 

COUNT I 

OVERTIME VIOLATION BY PHYSICIANS CENTRAL 

UNDER THE FAIR LABOR STANDARDS ACT 

37. Plaintiff, on behalf of herself and all others similarly situated, reallege and incorporate by reference the allegations in paragraphs 1 through 36 

above as if fully set forth herein. 

38. As part of its business, Physicians Central purchased goods and 

materials that traveled through interstate commerce. 

39. These goods and materials were customarily, continually, and 

regularly handled by two or more employees, including Plaintiff. 

40. Upon information and belief, Physicians Central obtained and 

solicited funds from non-Florida sources, accepted funds from non-Florida 

sources, used telephonic transmissions going over state lines to do its business, 

transmitted funds outside the State of Florida, used electronic means to market 

and run its business in a way that was not limited to Florida, and otherwise 

regularly engaged in interstate commerce during the relevant period. 

41. Physicians Central, upon information and belief, accepted credit 

card payments, wire transfers, and other forms of payments made or processed 

outside the state of Florida during the relevant time period. 

7 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

7 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

36. The potential class of aggrieved individuals working for Defendants 

and subject to this misclassification have worked over forty (40) hours a week 

during the last three (3) years without being paid at a proper time-and-a-half 

their regular rate of pay for all overtime hours worked. 

COUNT I 

OVERTIME VIOLATION BY PHYSICIANS CENTRAL 

UNDER THE FAIR LABOR STANDARDS ACT 

37. Plaintiff, on behalf of herself and all others similarly situated, reallege and incorporate by reference the allegations in paragraphs 1 through 36

above as if fully set forth herein. 

38. As part of its business, Physicians Central purchased goods and 

materials that traveled through interstate commerce. 

39. These goods and materials were customarily, continually, and 

regularly handled by two or more employees, including Plaintiff. 

40. Upon information and belief, Physicians Central obtained and 

solicited funds from non-Florida sources, accepted funds from non-Florida 

sources, used telephonic transmissions going over state lines to do its business, 

transmitted funds outside the State of Florida, used electronic means to market 

and run its business in a way that was not limited to Florida, and otherwise 

regularly engaged in interstate commerce during the relevant period. 

41. Physicians Central, upon information and belief, accepted credit 

card payments, wire transfers, and other forms of payments made or processed 

outside the state of Florida during the relevant time period.

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 11 of 29
42. During her employment with Physicians Central, Plaintiff worked 

overtime hours for which she was not compensated at a proper overtime rate as 

required by the FLSA. 

43. Physicians Central did not compensate Plaintiff for her overtime 

despite knowledge of the overtime hours Plaintiff worked. 

44. Plaintiff is owed unpaid overtime compensation pursuant to the 

FLSA. 

45. In addition, Physicians Central is liable for double the overtime 

amounts owed as liquidated damages under the FLSA as a result of its 

intentional and willful violations for up to the three-year statute of limitations 

afforded by the FLSA. 

WHEREFORE, Plaintiff respectfully requests that the Court: 

a. Enter judgment for Plaintiff and all others similarly situated against 

Physicians Central under the FLSA; 

b. Award Plaintiff and all others similarly situated actual damages for the 

unpaid overtime wages; 

c. Award Plaintiff and all others similarly situated liquidated damages; 

d. Award Plaintiff and all others similarly situated attorneys' fees and 

e. Award Plaintiff and all others similarly situated all recoverable interest; 

f. Award any other relief this Honorable Court deems just and proper. 

8 I Page 

costs; 

and 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

8 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

42. During her employment with Physicians Central, Plaintiff worked 

overtime hours for which she was not compensated at a proper overtime rate as 

required by the FLSA.

43. Physicians Central did not compensate Plaintiff for her overtime 

despite knowledge of the overtime hours Plaintiff worked.

44. Plaintiff is owed unpaid overtime compensation pursuant to the 

FLSA. 

45. In addition, Physicians Central is liable for double the overtime

amounts owed as liquidated damages under the FLSA as a result of its 

intentional and willful violations for up to the three-year statute of limitations 

afforded by the FLSA. 

WHEREFORE, Plaintiff respectfully requests that the Court: 

a. Enter judgment for Plaintiff and all others similarly situated against 

Physicians Central under the FLSA;

b. Award Plaintiff and all others similarly situated actual damages for the 

unpaid overtime wages;

c. Award Plaintiff and all others similarly situated liquidated damages; 

d. Award Plaintiff and all others similarly situated attorneys’ fees and 

costs;

e. Award Plaintiff and all others similarly situated all recoverable interest; 

and

f. Award any other relief this Honorable Court deems just and proper. 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 12 of 29
COUNT II 

OVERTIME VIOLATIONS AGAINST MARK CERECEDA UNDER 

THE FAIR LABOR STANDARDS ACT 

46. Plaintiff, on behalf of herself and all others similarly situated, reallege and incorporate by reference the allegations in paragraphs 1 through 37 

above as if fully set forth herein. 

47. Cereceda operated the day-to-day activities of Defendants' business, 

had supervisory authority over Plaintiff, had control/access to Plaintiffs records 

for work hours, and was partially or totally responsible for paying Plaintiffs 

wages. 

48. Cereceda scrutinized Plaintiffs work and controlled how Plaintiff did 

her job. 

49. During Plaintiffs employment with Defendants, Plaintiff 

consistently worked for Defendants over 40 hours per week. 

50. Cereceda was fully aware that Plaintiff consistently worked for 

Defendants over 40 hours per week. 

51. Despite notice and knowledge, Cereceda failed to investigate or 

otherwise remedy the due and owing overtime wages earned by Plaintiff. 

52. During her employment with Physicians Central, Plaintiff worked 

overtime hours for which she was not compensated at a proper overtime rate as 

required by the FLSA. 

53. Plaintiff is owed unpaid overtime compensation pursuant to the 

FLSA. 

9 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

9 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

COUNT II 

OVERTIME VIOLATIONS AGAINST MARK CERECEDA UNDER 

THE FAIR LABOR STANDARDS ACT 

46. Plaintiff, on behalf of herself and all others similarly situated, reallege and incorporate by reference the allegations in paragraphs 1 through 37

above as if fully set forth herein. 

47. Cereceda operated the day-to-day activities of Defendants’ business, 

had supervisory authority over Plaintiff, had control/access to Plaintiff’s records 

for work hours, and was partially or totally responsible for paying Plaintiff’s 

wages. 

48. Cereceda scrutinized Plaintiff’s work and controlled how Plaintiff did 

her job.

49. During Plaintiff’s employment with Defendants, Plaintiff 

consistently worked for Defendants over 40 hours per week. 

50. Cereceda was fully aware that Plaintiff consistently worked for 

Defendants over 40 hours per week. 

51. Despite notice and knowledge, Cereceda failed to investigate or 

otherwise remedy the due and owing overtime wages earned by Plaintiff.

52. During her employment with Physicians Central, Plaintiff worked 

overtime hours for which she was not compensated at a proper overtime rate as 

required by the FLSA. 

53. Plaintiff is owed unpaid overtime compensation pursuant to the 

FLSA. 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 13 of 29
54. Cereceda did not compensate Plaintiff for her overtime despite her 

knowledge of the overtime hours Plaintiff worked. 

55. Cereceda is also jointly and severally liable for double the overtime 

amounts owed as liquidated damages under the FLSA as a result of her 

intentional and willful violation of the FLSA for up to the three-year statute of 

limitations afforded by the FLSA. 

WHEREFORE, Plaintiff respectfully requests that the Court: 

a. Enter judgment for Plaintiff and all others similarly situated against 

Cereceda under the FLSA; 

b. Award Plaintiff and all others similarly situated for actual damages for 

the unpaid overtime wages; 

c. Award Plaintiff and all others similarly situated liquidated damages; 

d. Award Plaintiff and all others similarly situated attorneys' fees and 

costs; 

e. Award Plaintiff and all others similarly situated all recoverable interest; 

and 

f. Award any other relief this Honorable Court deems just and proper. 

JURY TRIAL 

Plaintiff hereby requests a trial by jury with respect to all claims so triable. 

10 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

10 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

54. Cereceda did not compensate Plaintiff for her overtime despite her 

knowledge of the overtime hours Plaintiff worked.

55. Cereceda is also jointly and severally liable for double the overtime 

amounts owed as liquidated damages under the FLSA as a result of her 

intentional and willful violation of the FLSA for up to the three-year statute of 

limitations afforded by the FLSA. 

WHEREFORE, Plaintiff respectfully requests that the Court: 

a. Enter judgment for Plaintiff and all others similarly situated against 

Cereceda under the FLSA;

b. Award Plaintiff and all others similarly situated for actual damages for 

the unpaid overtime wages;

c. Award Plaintiff and all others similarly situated liquidated damages; 

d. Award Plaintiff and all others similarly situated attorneys’ fees and 

costs;

e. Award Plaintiff and all others similarly situated all recoverable interest; 

and

f. Award any other relief this Honorable Court deems just and proper. 

JURY TRIAL 

Plaintiff hereby requests a trial by jury with respect to all claims so triable. 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 14 of 29
Dated: September 22, 2022 

Respectfully submitted, 

By: /s/ J. Freddy Perera 

J. Freddy Perera, Esq. 

Florida Bar No. 93625 

freddy@pba-law.com 

Brody M. Shulman, Esq. 

Florida Bar No. 092044 

brody@pba-law.com 

PERERA ALEMAN, P.A. 

12505 Orange Drive, Suite 908 

Davie, Florida 33330 

Telephone: 786-485-5232 

Counsel for Plaintiff 

11 I Page 

PERERA ALEMAN 

12505 Orange Drive • Suite 908 • Davie, FL 33330 

2030 S Douglas Road • Suite 203 • Coral Gables, FL 33134 

(786) 485.5232 • www.PBA-Law.com 

11 | Page

PERERA ALEMÁN

12505 Orange Drive · Suite 908 · Davie, FL 33330 

2030 S Douglas Road · Suite 203 · Coral Gables, FL 33134 

(786) 485.5232 · www.PBA-Law.com

Dated: September 22, 2022

Respectfully submitted, 

By: /s/ J. Freddy Perera

J. Freddy Perera, Esq. 

Florida Bar No. 93625 

freddy@pba-law.com 

Brody M. Shulman, Esq. 

Florida Bar No. 092044 

brody@pba-law.com 

 

PERERA ALEMÁN, P.A. 

12505 Orange Drive, Suite 908 

Davie, Florida 33330 

Telephone: 786-485-5232 

 

Counsel for Plaintiff 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 15 of 29
Filing # 159033082 E-Filed 10/11/2022 08:00:38 PM 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL 

CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

CASE NO: 2022-018329-CA-01 

SECTION: CA21 

JUDGE: David C. Miller 

Maria Matos 

Plaintiff(s) 

vs. 

Physicians Central Business Office LLC et al 

Defendant(s) 

/ 

ORDER TO COMPLETE AND COMPLY WITH CASE SCHEDULING AND 

MANAGEMENT ORDER 

THIS CAUSE came before the Court to review and do case management. Based on the review 

of the file, and pursuant to Rule 2.545, Fla. R. Jud. Admin., the Parties, with the Court's 

assistance, if necessary, will establish a Completed Case Scheduling/Management Order. 

Therefore, it is; 

ORDERED and ADJUDGED as follows: 

1. The Parties shall determine and complete the CASE SCHEDULE below, to extent they can 

agree on one or all of the To-Dos in this matter and set the Deadlines for as many as can be 

agreed on. If there is/are any Deadlines for the Parties To-Dos that cannot be agreed on, the 

Plaintiff's Counsel shall set a hearing if necessary for the Court to decide the 

Deadlines. 

2. The Plaintiff's Counsel shall file the entire completed Scheduling/Management Order 

as a Completed Case Scheduling/Management Order through Court Map for execution 

and rendering by the Court within 60 days of the entry of the Order or the appearance of 

the first Defendant whichever occurs last. The Plaintiff's Counsel will bear the burden 

of ensuring this Order is complied with and the entire scheduling/management order with 

completed table of to dos and deadlines is filed, but that will not determine who may be 

ultimately responsible for any lack of compliance with this Order. 

3. The Parties shall strictly comply with the deadlines in the Schedule (which shall supersede 

any contrary or different Trial Order Deadline — not as to the trial date or date of the 

calendar call which are determined by the Trial Order) and should expect that the case 

will be tried during the anticipated trial period specified, without continuances. The parties 

cannot agree to extend the deadlines and cannot agree to waive any portion of the provisions 

of this Order. If your case does not go to Trial, it will most probably be sent to Non-Binding 

Case No: 2022-018329-CA-01 Page 1 of 6 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO: 2022-018329-CA-01

SECTION: CA21

JUDGE: David C. Miller

Maria Matos

Plaintiff(s)

vs.

Physicians Central Business Office LLC et al

Defendant(s)

____________________________/

ORDER TO COMPLETE AND COMPLY WITH CASE SCHEDULING AND

MANAGEMENT ORDER

 THIS CAUSE came before the Court to review and do case management. Based on the review

of the file, and pursuant to Rule 2.545, Fla. R. Jud. Admin., the Parties, with the Court’s

assistance, if necessary, will establish a Completed Case Scheduling/Management Order. 

Therefore, it is;

 ORDERED and ADJUDGED as follows:

The Parties shall determine and complete the CASE SCHEDULE below, to extent they can

agree on one or all of the To-Dos in this matter and set the Deadlines for as many as can be

agreed on. If there is/are any Deadlines for the Parties To-Dos that cannot be agreed on, the

Plaintiff’s Counsel shall set a hearing if necessary for the Court to decide the

Deadlines. 

1. 

The Plaintiff’s Counsel shall file the entire completed Scheduling/Management Order

as a Completed Case Scheduling/Management Order through Court Map for execution

and rendering by the Court within 60 days of the entry of the Order or the appearance of

the first Defendant whichever occurs last. The Plaintiff’s Counsel will bear the burden

of ensuring this Order is complied with and the entire scheduling/management order with

completed table of to dos and deadlines is filed, but that will not determine who may be

ultimately responsible for any lack of compliance with this Order.

2. 

The Parties shall strictly comply with the deadlines in the Schedule (which shall supersede

any contrary or different Trial Order Deadline – not as to the trial date or date of the

calendar call which are determined by the Trial Order) and should expect that the case

will be tried during the anticipated trial period specified, without continuances. The parties

cannot agree to extend the deadlines and cannot agree to waive any portion of the provisions

of this Order. If your case does not go to Trial, it will most probably be sent to Non-Binding

3. 

Case No: 2022-018329-CA-01 Page 1 of 6

Filing # 159033082 E-Filed 10/11/2022 08:00:38 PM Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 16 of 29
Arbitration. 

4. Procedural Requirements: In addition to strict adherence to the Florida Rules of Civil 

Procedure and the Administrative Orders of the Court, the parties will be required to strictly 

comply with the Completed Case Scheduling/Management Order. 

5. The parties may not agree to extend any of the deadlines contained in the Completed Case 

Scheduling/Management Order. Deadlines may only be altered by the Court where the 

interests of justice so require, upon prompt motion, notice and hearing. 

6. The following To-Dos and Deadlines are to be determined by Agreement of the 

Parties, filled in, and returned to the Court for execution and rendering OR the Court 

will determine and fill in such To-Dos and Deadlines: 

CASE SCHEDULE 

Case No: 2022-018329-CA-01 Page 2 of 6 

Arbitration.

Procedural Requirements: In addition to strict adherence to the Florida Rules of Civil

Procedure and the Administrative Orders of the Court, the parties will be required to strictly

comply with the Completed Case Scheduling/Management Order. 

4. 

The parties may not agree to extend any of the deadlines contained in the Completed Case

Scheduling/Management Order. Deadlines may only be altered by the Court where the

interests of justice so require, upon prompt motion, notice and hearing.

5. 

The following To-Dos and Deadlines are to be determined by Agreement of the

Parties, filled in, and returned to the Court for execution and rendering OR the Court

will determine and fill in such To-Dos and Deadlines:

6. 

CASE SCHEDULE

Case No: 2022-018329-CA-01 Page 2 of 6

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 17 of 29
CASE MANAGEMENT PROCEDURES 

7. Duty to Communicate: Prior to filing any Motion, counsel shall confer with each other 

directly in good faith, not through staff, to attempt to narrow or resolve issues. "In good 

faith" means you are professional and temperate in your communications, you return phone 

calls and emails in a timely manner, and you do not set unreasonable deadlines for responses. 

8. Scheduling of Hearings: Motions filed (other than dispositive motions or those requiring 

testimony) must be noticed for hearing on the first available motion calendar. The Court may 

rule upon the Motions on the papers filed for the Court's review. 

9. Compelling Discovery where there has been no response: The parties are to comply with 

Administrative Order 06-09 when moving to compel production of propounded discovery. 

These Motions shall be submitted via CourtMAP with supporting documents and shall not be 

placed on Motion Calendar. 

10. Motions for Protective Order: Motions for Protective Order must be filed as soon as the 

grounds are known. Counsel should be coordinating deposition dates for specific 

parties/witnesses and have a duty to confer regarding any issues that would be the subject 

of a motion for protective order prior to scheduling the deposition. The filing of the motion 

must not be delayed until immediately prior to the scheduled deposition. A motion for 

protective order does not automatically stay the deposition and the deposition shall proceed 

unless an order granting the motion is entered by the Court. 

11. Motions for Extension: All Motions for Extension of Time SHALL BE SET TO BE 

HEARD WITHIN 7 DAYS OF THE MOTION BEING FILED and the Motion must state 

with specificity the reason why Extension is needed, the anticipated deadline for completion, 

and any extraordinary or compelling reasons to grant relief. The Court may rule upon 

submission of the Motion without a hearing. All Motions for Extension of Time must be 

preceded by a meet and confer with opposing counsel and absent agreement, be set for 

hearing immediately upon filing. Counsel should be prepared to respond promptly if the 

Motion is Denied. The failure to timely set the Motion for Extension to be heard will be 

deemed a waiver of any attempt to get an Extension. 

12. Dispositive Motions: Motions which may dispose of specific issues, portions of the case or 

the entire case should be filed and set for hearing as soon as possible. Parties wishing to 

pursue a dispositive motion should target the essential discovery promptly. Parties should 

confer to assure necessary discovery is scheduled to be completed and will be completed 

prior to a special set hearing date. Last minute cancellations are NOT ALLOWED. 

Case No: 2022-018329-CA-01 Page 3 of 6 

CASE MANAGEMENT PROCEDURES

Duty to Communicate: Prior to filing any Motion, counsel shall confer with each other

directly in good faith, not through staff, to attempt to narrow or resolve issues. “In good

faith” means you are professional and temperate in your communications, you return phone

calls and emails in a timely manner, and you do not set unreasonable deadlines for responses.

7. 

Scheduling of Hearings: Motions filed (other than dispositive motions or those requiring

testimony) must be noticed for hearing on the first available motion calendar. The Court may

rule upon the Motions on the papers filed for the Court's review.

8. 

Compelling Discovery where there has been no response: The parties are to comply with

Administrative Order 06-09 when moving to compel production of propounded discovery. 

These Motions shall be submitted via CourtMAP with supporting documents and shall not be

placed on Motion Calendar.

9. 

Motions for Protective Order: Motions for Protective Order must be filed as soon as the

grounds are known. Counsel should be coordinating deposition dates for specific

parties/witnesses and have a duty to confer regarding any issues that would be the subject

of a motion for protective order prior to scheduling the deposition. The filing of the motion

must not be delayed until immediately prior to the scheduled deposition. A motion for

protective order does not automatically stay the deposition and the deposition shall proceed

unless an order granting the motion is entered by the Court.

10. 

Motions for Extension: All Motions for Extension of Time SHALL BE SET TO BE

HEARD WITHIN 7 DAYS OF THE MOTION BEING FILED and the Motion must state

with specificity the reason why Extension is needed, the anticipated deadline for completion,

and any extraordinary or compelling reasons to grant relief. The Court may rule upon

submission of the Motion without a hearing. All Motions for Extension of Time must be

preceded by a meet and confer with opposing counsel and absent agreement, be set for

hearing immediately upon filing. Counsel should be prepared to respond promptly if the

Motion is Denied. The failure to timely set the Motion for Extension to be heard will be

deemed a waiver of any attempt to get an Extension.

11. 

Dispositive Motions: Motions which may dispose of specific issues, portions of the case or

the entire case should be filed and set for hearing as soon as possible. Parties wishing to

pursue a dispositive motion should target the essential discovery promptly. Parties should

confer to assure necessary discovery is scheduled to be completed and will be completed

prior to a special set hearing date. Last minute cancellations are NOT ALLOWED.

12. 

Case No: 2022-018329-CA-01 Page 3 of 6

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 18 of 29
13. Amendment of Pleadings: Motions to amend should be filed so as not to affect the date of 

trial. Although the Court recognizes the rule of liberality with regard to amendment of 

pleadings, liberality declines with an approaching trial date unless the amendment involves 

newly discovered information not previously available. Review your pleadings for necessary 

amendment(s) early, not as part of last-minute trial preparation. 

14. Objections: If objections to written discovery involve the phrasing of the request or time 

frame of any discovery request, these objections may not be extended even if the parties 

agree and are due at the time the initial response is due. Failure to timely file these 

objections shall be deemed an express waiver of the objection. Parties shall comply with 

the "Duty to Communicate" above, prior to setting timely made objections for hearing. 

15. Documents made available for inspection and copying: If discovery responses provide 

that the documents are available for inspection and copying at a mutually convenient time 

and place, the responding party shall immediately (within 48 hours) provide three alternative 

dates and times that the documents are available for inspection and copying. All of the dates 

shall be within ten (10) days. Failure to provide the dates and times shall constitute a failure 

to respond to discovery. Review shall occur within fifteen (15) days of the response, absent 

extraordinary circumstances. Examples of "extraordinary circumstances" include a sole 

practitioner in trial on another case, a medical emergency, prepaid vacation, and a death in 

the family. 

16. Privilege Logs: Privilege logs are due at the time of the response and may not be reserved to 

be provided later. Privilege logs must specifically identify the document in accordance with 

Rule 1.280(b)(6), Fla.R.Civ.P, AND The item must at least be described by Author, 

primarily Recipient and all those copied, date, nature of document, and the same 

information as to all attachments printed out or opened in records for view. 

17. The failure to timely provide the privilege log will result in the waiver of the privilege. 

This procedure requires preparation of a privilege log with respect to all documents, 

electronically stored information, things and oral communications withheld on the basis of a 

claim of privilege or work product except the following: written and oral communications 

between a party and their counsel after commencement of the action and work product 

material created after commencement of the action and solely kept between them and staff, 

experts, etc. 

Parties are instructed that where they believe that the divulgence of the logging information 

would necessarily cause disclosure of the allegedly privileged information, they must 

identify that the item exists and that in camera review by the court will be sought. 

However, if the Court determines that there is nothing inherent in the divulgence of the 

existence of the document or the logging information required that would violate privilege, 

the Court will impose sanctions for any in camera request determined to be frivolous. In 

camera requests by the party claiming the privilege must be signed by both the 

requesting attorney and the client, to assure that all are aware of the request and the 

consequences. 

Case No: 2022-018329-CA-01 Page 4 of 6 

Amendment of Pleadings: Motions to amend should be filed so as not to affect the date of

trial. Although the Court recognizes the rule of liberality with regard to amendment of

pleadings, liberality declines with an approaching trial date unless the amendment involves

newly discovered information not previously available. Review your pleadings for necessary

amendment(s) early, not as part of last-minute trial preparation.

13. 

Objections: If objections to written discovery involve the phrasing of the request or time

frame of any discovery request, these objections may not be extended even if the parties

agree and are due at the time the initial response is due. Failure to timely file these

objections shall be deemed an express waiver of the objection. Parties shall comply with

the “Duty to Communicate” above, prior to setting timely made objections for hearing.

14. 

Documents made available for inspection and copying: If discovery responses provide

that the documents are available for inspection and copying at a mutually convenient time

and place, the responding party shall immediately (within 48 hours) provide three alternative

dates and times that the documents are available for inspection and copying. All of the dates

shall be within ten (10) days. Failure to provide the dates and times shall constitute a failure

to respond to discovery. Review shall occur within fifteen (15) days of the response, absent

extraordinary circumstances. Examples of “extraordinary circumstances” include a sole

practitioner in trial on another case, a medical emergency, prepaid vacation, and a death in

the family.

15. 

Privilege Logs: Privilege logs are due at the time of the response and may not be reserved to

be provided later. Privilege logs must specifically identify the document in accordance with

Rule 1.280(b)(6), Fla.R.Civ.P, AND The item must at least be described by Author,

primarily Recipient and all those copied, date, nature of document, and the same

information as to all attachments printed out or opened in records for view.

16. 

The failure to timely provide the privilege log will result in the waiver of the privilege.

This procedure requires preparation of a privilege log with respect to all documents,

electronically stored information, things and oral communications withheld on the basis of a

claim of privilege or work product except the following: written and oral communications

between a party and their counsel after commencement of the action and work product

material created after commencement of the action and solely kept between them and staff,

experts, etc.

17. 

Parties are instructed that where they believe that the divulgence of the logging information

would necessarily cause disclosure of the allegedly privileged information, they must

identify that the item exists and that in camera review by the court will be sought. 

However, if the Court determines that there is nothing inherent in the divulgence of the

existence of the document or the logging information required that would violate privilege,

the Court will impose sanctions for any in camera request determined to be frivolous. In

camera requests by the party claiming the privilege must be signed by both the

requesting attorney and the client, to assure that all are aware of the request and the

consequences.

Case No: 2022-018329-CA-01 Page 4 of 6

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 19 of 29
18. Expert Disclosure: Parties should furnish opposing counsel with the names and addresses 

of all expert witness under Rule 1.390(a) to be called at trial and all information regarding 

expert testimony that is required by Rule 1.280(b)(5). Each party is limited to one expert per 

specialty. No other expert testimony should be permitted at trial. Information furnished 

pursuant to this paragraph should be timely filed. 

19. Depositions: The parties are ordered to block time now for necessary depositions to be set in 

this case Expert deposition time should be coordinated and blocked as soon as experts are 

known to ensure compliance with this schedule. Depositions may commence at any time. 

Refer to the above regarding motions for protective order. 

20. Witness and Exhibit Lists: The parties shall timely exchange their witness and exhibit 

lists. The lists shall include complete proper names and addresses. If counsel chooses to list 

their bar address as the witness' address, counsel is deemed to have agreed to produce the 

witness voluntarily as they have withheld the information necessary for a witness subpoena, 

and counsel will be responsible for assuring that witness' presence at trial. 

21. Mediation: Parties must mediate by the Court's deadline. The parties are responsible for 

assuring that they have all the necessary information to value their position prior to 

mediation. If the parties fail to mediate before the mediation deadline, sanctions will be 

imposed by the Court. Failure to Mediate will not constitute just cause for a Trial 

Continuance. 

22. "Frustrated Lawyer/Pro-Se Rule" 

Please see the 11th Judicial Circuit in and for Miami-Dade County Division 21 website 

— for assistance scheduling anything the other(s) in the file are making difficult. 

DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 11th day of October., 

2022. 

2022— '7 Pis., 

2022-018329-CA-01 10-11-2022 7:59 PM 

Hon. David C. Miller 

CIRCUIT COURT JUDGE 

Electronically Signed 

No Further Judicial Action Required on THIS MOTION 

CLERK TO RECLOSE CASE IF POST JUDGMENT 

Electronically Served: 

Jorge Freddy Perera, freddy@pba-law.com 

Case No: 2022-018329-CA-01 Page 5 of 6 

Expert Disclosure: Parties should furnish opposing counsel with the names and addresses

of all expert witness under Rule 1.390(a) to be called at trial and all information regarding

expert testimony that is required by Rule 1.280(b)(5). Each party is limited to one expert per

specialty. No other expert testimony should be permitted at trial. Information furnished

pursuant to this paragraph should be timely filed.

18. 

Depositions: The parties are ordered to block time now for necessary depositions to be set in

this case Expert deposition time should be coordinated and blocked as soon as experts are

known to ensure compliance with this schedule. Depositions may commence at any time. 

Refer to the above regarding motions for protective order.

19. 

Witness and Exhibit Lists: The parties shall timely exchange their witness and exhibit

lists. The lists shall include complete proper names and addresses. If counsel chooses to list

their bar address as the witness’ address, counsel is deemed to have agreed to produce the

witness voluntarily as they have withheld the information necessary for a witness subpoena,

and counsel will be responsible for assuring that witness’ presence at trial.

20. 

Mediation: Parties must mediate by the Court’s deadline. The parties are responsible for

assuring that they have all the necessary information to value their position prior to

mediation. If the parties fail to mediate before the mediation deadline, sanctions will be

imposed by the Court. Failure to Mediate will not constitute just cause for a Trial

Continuance.

21. 

22. “Frustrated Lawyer/Pro-Se Rule”

Please see the 11th Judicial Circuit in and for Miami-Dade County Division 21 website

– for assistance scheduling anything the other(s) in the file are making difficult.

DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 11th day of October,

2022.

2022-018329-CA-01 10-11-2022 7:59 PM

Hon. David C. Miller

CIRCUIT COURT JUDGE

Electronically Signed

No Further Judicial Action Required on THIS MOTION

CLERK TO RECLOSE CASE IF POST JUDGMENT

Electronically Served:

Jorge Freddy Perera, freddy@pba-law.com

Case No: 2022-018329-CA-01 Page 5 of 6

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 20 of 29
Jorge Freddy Perera, admin@pba-law.com 

Jorge Freddy Perera, admin3@pba-law.com 

Physically Served: 

Case No: 2022-018329-CA-01 Page 6 of 6 

Jorge Freddy Perera, admin@pba-law.com

Jorge Freddy Perera, admin3@pba-law.com

Physically Served:

Case No: 2022-018329-CA-01 Page 6 of 6

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 21 of 29
Filing # 159108272 E-Filed 10/12/2022 04:14:13 PM 

RETURN OF SERVICE 

State of Florida 

Case Number: 2022-018329-CA-01 

Plaintiff: 

MARIA MATOS 

VS. 

County of Miami-Dade Circuit Court 

Defendant: 

PHYSICIANS CENTRAL BUSINESS OFFICE, LLC., ET AL 

For: 

BRODY M. SHULMAN 

PERERA ALEMAN PLLC 

12401 ORANGE DR 

SUITE 123 

DAVIE, FL 33330 

1111 111111111 

OJF2022022190 

III III 

Received by OJF SERVICES, INC. on the 10th day of October, 2022 at 1:23 pm to be served on PHYSICIANS CENTRAL 

BUSINESS OFFICE, LLC., 815 NW 57 AVE., STE. 405, MIAMI, FL 33126. 

I, GREG SCHULTE, do hereby affirm that on the 11th day of October, 2022 at 11:20 am, I: 

CORPORATE SERVED: by delivering a true copy of the SUMMONS AND COMPLAINT with the date and hour of service 

endorsed thereon by me, to: SHIRLEY VIERA EMPLOYEE OF MARK A. CERECEDA, registered agent for PHYSICIANS 

CENTRAL BUSINESS OFFICE, LLC., at the address of: 815 NW 57 AVE., STE. 405, MIAMI, FL 33126, and informed 

said person of the contents therein, in compliance with either federal or state statutes. 

I CERTIFY THAT I AM OVER THE AGE OF 18, HAVE NO INTEREST IN THE ABOVE ACTION, AND THAT I AM A 

CERTIFIED PROCESS SERVER, IN GOOD STANDING, IN THE JUDICIAL CIRCUIT IN WHICH THE PROCESS WAS 

SERVED. "UNDER PENALTY OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING (DOCUMENT) AND 

THAT THE FACTS STATED IN IT ARE TRUE, 92.525. ELECTRONIC SIGNATURES ARE NOW PERMITTED 

PURSUANT TO FLORIDA STATUTE 48.21. NOTARY ARE NOT REQUIRED PURSUANT TO F.S. 92.525(2). 

GREG SCHUL 

CPS #245 

OJF SERVICES, INC. 

13727 S.W. 152nd Street 

P.M.B. 354 

Miami, FL 33177 

(786) 293-5750 

Our Job Serial Number: OJF-2022022190 

Copyright © 1992-2022 DreamBuilt Software. Inc. - Process Server's Toolbox V8.2k 

Filing # 159108272 E-Filed 10/12/2022 04:14:13 PM Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 22 of 29
Filing # 158540996 E-Filed 10/04/2022 11:26:14 AM 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

CASE NO.: 2022-018329-CA-01 

MARIA MATOS, 

and all others similarly situated under 

29 U.S.C. §216(b), 

Plaintiff(s), 

VS. 

PHYSICIANS CENTRAL BUSINESS OFFICE, LLC, 

a Florida For-Profit Corporation, and 

MARK A. CERECEDA, individually, 

Defendants. 

SUMMONS 

THE STATE OF FLORIDA: 

To Each Sheriff of Said State: 

YOU ARE HEREBY COMMANDED to serve this Summons and a copy of Complaint 

to Defendant: 

PHYSICIANS CENTRAL BUSINESS OFFICE, LLC 

THROUGH ITS REGISTERED AGENT: 

Mark A. Cereceda 

815 NW 57th Avenue, Suite 405 

Miami, FL 33126 

Defendant is required to serve written defenses to the Complaint on Plaintiffs' counsel, 

whose name and address is: J. Freddy Perera, Esq. and Brody M. Shulman, Esq., Perera 

Aleman, P.A. 12505 Orange Drive, Suite 908 Davie, FL 33330 within 20 calendar days after 

service of this summons on that Defendant, exclusive of the day of service, and to file the original 

of the defenses with the Clerk of the Court either before service on Plaintiffs' attorney or 

immediately thereafter. If a Defendant fails to do so, a default will be entered against that 

Defendant for the relief demanded in the complaint or petition. 

'I' 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 23 of 29
DATED ON 10/7/2022 . 2021. 

SHARON R. BOCK 

By: 

Pp 

3DitiNN E

\ 

As Deputy Clerk 

SUMMONS: 

PERSONAL SERVICE OF A CORPORATION 

iMK / 

coon''. 

IMPORTANT 

A lawsuit has been filed against you. You have 20 calendar days after this summons is 

served upon you to file a written response to the attached Complaint in this Court. A phone call 

will not protect you. Your written response, including the above case number and named parties, 

must be filed if you want the Court to hear your case. If you do not file your response on time, 

you may lose the case, and your wages, money and property may thereafter be taken without 

further warning from the Court. There are other legal requirements. You may want to call an 

attorney right away. If you do not know an attorney, you may call an attorney referral service or 

a legal aid office (listed in the phone book). 

If you choose to file a written response yourself, at the same time you file your written 

response to the Court you must also mail or take a carbon copy or photocopy of your written 

response to the "Plaintiffs/Plaintiffs Attorney" named below. 

IMPORTANTE 

Usted ha sido demandado legalmente. Tiene veinte (20) dias, contados a partir del recibo 

de esta notificacion, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. 

Una Ilamada telefonica no lo protegera; si usted desea que el escrito, incluyendo el numero del 

caso y los nombres de las panes interesadas en dicho caso. Si usted no contesta la demanda a 

tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o priva de 

sus derechos, sin previo aviso del tribunal. Existen otros requisitos legates. Si lo desea puede 

usted consultar a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a una de 

las oficinas de asistencia legal que aparecen en la guia telefonica. 

Si desea responder a la demanda pro su cuenta, al mismoi tiempo en que presents su 

respuesta ante el tribunal, debera usted enviar por correo o entregar una copia du su respuesta a la 

persona denominada abajo como "Plaintiffs/Plaintiffs"s Attorney." (Demandante o Abogado de 

Demandante). 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 24 of 29
IMPORTANT 

Des poursuites judiciaries ont ele entreprises contre vous. Vous avez 20 jours consecutifs 

a partir de la date de l'assignation de cet'te citation pour deposser une response ecite a la plainte 

cijointe aupres de ce Tribunal. Un simple coup de telephone est insuffisant pour vous proteger; 

vous etes oblige de deposer votre reponse ecrite, ave mention du numero de dossier ci-dessus et 

du nom des parties nommees ici, si vous souhaitez que le Tribunal entende votre cause. Si cous 

ne deposez pas votre reponse ecrite dans le relai requis, vous resiquez de perdre la cause ainsi que 

votre salaire, votre argent, et vos biens peuvent tere saisis par la suite, sans aucun preavis ulterieur 

du Tribunal. II a d' autres obligations juridiques et vous pouvez requerir les services immediates 

dun avocat. Si vous ne connaissez pas d'avocats, you pourriez telephoner a un service de reference 

d'avocats ou a un brueau d'assistance juridique (figurant a I'annuaire de telephones). 

Si vous choisissez de deposer vous-meme une reponse ecrite, II vous faudra egalement, en 

meme tempos que cette formalite, faire parvenir ou expedier une copie au carbone ou une 

photocopie de votre reponse ecrite au "Plaintiffs/Plaintiffs"s Attorney" (Plaignant ou a son 

avocate) nomme ci-dessous. 

Filed By: J. Freddy Perera, Esq. 

Fla. Bar No.: 93625 

Brody M. Shulman, Esq. 

Fla. Bar No.: 92044 

Address: Perera Aleman, P.A. 

12505 Orange Drive 

Suite 908 

Davie, FL 33330 

(786) 485-5232 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 25 of 29
Filing # 159108272 E-Filed 10/12/2022 04:14:13 PM 

RETURN OF SERVICE 

State of Florida 

Case Number: 2022-018329-CA-01 

Plaintiff: 

MARIA MATOS 

VS. 

County of Miami-Dade Circuit Court 

Defendant: 

PHYSICIANS CENTRAL BUSINESS OFFICE, LLC., ET AL 

For: 

BRODY M. SHULMAN 

PERERA ALEMAN PLLC 

12401 ORANGE DR 

SUITE 123 

DAVIE, FL 33330 

IIII!I2I01 121! 11111 I I 

Received by OJF SERVICES, INC. on the 10th day of October, 2022 at 1:23 pm to be served on MARK A. CERECEDA, 815 

NW 57 AVE., STE. 405, MIAMI, FL 33126. 

I, GREG SCHULTE, do hereby affirm that on the 11th day of October, 2022 at 11:20 am, I: 

AUTHORIZED: served by delivering a true copy of the SUMMONS AND COMPLAINT with the date and hour of service 

endorsed thereon by me, to: SHIRLEY VIERA as AUTHORIZED AGENT, who stated they are authorized to accept 

service for: MARK A. CERECEDA at the address of: 815 NW 57 AVE., STE. 405, MIAMI, FL 33126, and informed said 

person of the contents therein, in compliance with state statutes. 

Additional Information pertaining to this Service: 

THE ATTORNEY GAVE THE RECIPIENT AUTHORIZATION TO ACCEPT SERVICE 

I CERTIFY THAT I AM OVER THE AGE OF 18, HAVE NO INTEREST IN THE ABOVE ACTION, AND THAT I AM A 

CERTIFIED PROCESS SERVER, IN GOOD STANDING, IN THE JUDICIAL CIRCUIT IN WHICH THE PROCESS WAS 

SERVED. "UNDER PENALTY OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING (DOCUMENT) AND 

THAT THE FACTS STATED IN IT ARE TRUE, 92.525. ELECTRONIC SIGNATURES ARE NOW PERMITTED 

PURSUANT TO FLORIDA STATUTE 48.21. NOTARY ARE NOT REQUIRED PURSUANT TO F.S. 92.525(2). 

GREG SCHU E 

CPS #245 

OJF SERVICES, INC. 

13727 S.W. 152nd Street 

P.M.B. 354 

Miami, FL 33177 

(786) 293-5750 

Our Job Serial Number: OJF-2022022191 

Copyright © 1992-2022 DreamBuilt Software, Inc. - Process Servers Toolbox V8.2k 

Filing # 159108272 E-Filed 10/12/2022 04:14:13 PM Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 26 of 29
Filing # 158540996 E-Filed 10/04/2022 11:26:14 AM 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

CASE NO.: 2022-018329-CA-01 

MARIA MATOS, 

and all others similarly situated under 

29 U.S.C. §216(b), 

Plaintiff(s), 

VS. 

PHYSICIANS CENTRAL BUSINESS OFFICE, LLC, 

a Florida For-Profit Corporation, and 

MARK A. CERECEDA, individually, 

Defendants. 

SUMMONS 

THE STATE OF FLORIDA: 

To Each Sheriff of Said State: 

( 

YOU ARE HEREBY COMMANDED to serve this Summons and a copy of Complaint trik7 

to Defendant: 

1( ri)

Mark A. Cereceda 

815 NW 57 (it C61 I th Avenue, Suite 405 

Miami, FL 33126 

Defendant is required to serve written defenses to the Complaint on Plaintiffs' counsel, 

whose name and address is: J. Freddy Perera, Esq. and Brody M. Shulman, Esq., Perera 

Aleman, P.A. 12505 Orange Drive, Suite 908, Davie, FL 33330 within 20 calendar days after 

service of this summons on that Defendant, exclusive of the day of service, and to file the original 

of the defenses with the Clerk of the Court either before service on Plaintiffs' attorney or 

immediately thereafter. If a Defendant fails to do so, a default will be entered against that 

Defendant for the relief demanded in the complaint or petition. 

~Slc(I 7

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 27 of 29
10/7/2022 

DATED ON 2021. 

SHARON R. BOCK 

By: 

As Deputy Clerk 

SUMMONS: 

IMPORTANT 

A lawsuit has been filed against you. You have 20 calendar days after this summons is 

served upon you to file a written response to the attached Complaint in this Court. A phone call 

will not protect you. Your written response, including the above case number and named parties, 

must be filed if you want the Court to hear your case. If you do not file your response on time, 

you may lose the case, and your wages, money and property may thereafter be taken without 

further warning from the Court. There are other legal requirements. You may want to call an 

attorney right away. If you do not know an attorney, you may call an attorney referral service or 

a legal aid office (listed in the phone book). 

If you choose to file a written response yourself, at the same time you file your written 

response to the Court you must also mail or take a carbon copy or photocopy of your written 

response to the "Plaintiffs/Plaintiffs Attorney" named below. 

IMPORTANTE 

Usted ha lido demandado legalmente. Tiene veinte (20) dias, contados a partir del recibo 

de esta notificacion, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. 

Una llamada telefonica no lo protegera; si usted desea que el escrito, incluyendo el numero del 

caso y los nombres de las partes interesadas en dicho caso. Si usted no contesta la demanda a 

tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o priva de 

sus derechos, sin previo aviso del tribunal. Existen otros requisitos legales. Si lo desea puede 

usted consultar a un abogado inmediatamente. Si no conoce a un abogado, puede Hamar a una de 

las oficinas de asistencia legal que aparecen en la guia telefonica. 

Si desea responder a la demanda pro su cuenta, al mismoi tiempo en que presenta su 

respuesta ante el tribunal, debera usted enviar por correo o entregar una copia du su respuesta a la 

persona denominada abajo como "Plaintiffs/Plaintiffs"s Attorney." (Demandante o Abogado de 

Demandante). 

IMPORTANT 

Des poursuites judiciaries ont ele entreprises contre vous. Vous avez 20 jours consecutifs 

a partir de la date de l'assignation de cet'te citation pour deposser une response ecite a la plainte 

cijointe aupres de ce Tribunal. Un simple coup de telephone est insuffisant pour vous proteger; 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 28 of 29
vous etes oblige de deposer votre reponse ecrite, ave mention du numero de dossier ci-dessus et 

du nom des parties nommees ici, si vous souhaitez que le Tribunal entende votre cause. Si cous 

ne deposez pas votre reponse ecrite dans le relai requis, vous resiquez de perdre la cause ainsi que 

votre salaire, votre argent, et vos biens peuvent tere saisis par la suite, sans aucun preavis ulterieur 

du Tribunal. II a d' autres obligations juridiques et vous pouvez requerir les services immediates 

d'un avocat. Si vous ne connaissez pas d'avocats, you pourriez telephoner a un service de reference 

d'avocats ou a un brueau d'assistance juridique (figurant a l'annuaire de telephones). 

Si vous choisissez de deposer vous-meme une reponse ecrite, it vous faudra egalement, en 

meme tempos que cette formalite, faire parvenir ou expedier une copie au carbone ou une 

photocopie de votre reponse ecrite au "Plaintiffs/Plaintiffs"s Attorney" (Plaignant ou a son 

avocate) nomme ci-dessous. 

Filed By: J. Freddy Perera, Esq. 

Fla. Bar No.: 93625 

Brody M. Shulman, Esq. 

Fla. Bar No.: 92044 

Address: Perera Aleman, P.A. 

12505 Orange Drive 

Suite 908 

Davie, FL 33330 

(786) 485-5232 

Case 1:22-cv-23542-PAS Document 1-1 Entered on FLSD Docket 10/31/2022 Page 29 of 29