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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

PETAGAY UYLETT, 

Plaintiff, CASE NO.: 

vs.

MANS INVESTMENT BROWARD 

COUNTY, LLC, a Florida limited liability

company, NISHI MALLICK, an 

individual, and SHREYA MALLICK, an 

individual, 

Defendants.

___________________________________/

COMPLAINT

COMES NOW, Plaintiff, PETAGAY UYLETT (the “Plaintiff” or “Plaintiff”), by and 

through her undersigned attorney, and sues Defendants, MANS INVESTMENTS BROWARD 

COUNTY, LLC (the “Employer”), NISHI MALLICK (“N. Mallick”) and SHREYA MALLICK 

(“S. Mallick”)(collectively the Defendants) and alleges: 

PARTIES, JURISDICTION, AND VENUE

1. This is an action to recover money damages for unpaid minimum and overtime wages, 

under the laws of the United States and the State of Florida. This court has jurisdiction pursuant to 

the Fair Labor Standards Act, 29 U.S.C. §§ 201 – 219 (§ 216 for jurisdictional placement) (“the 

FLSA”), and F.S.A. § 448.10, 29 U.S.C. § 207 (a)(2)(c), under 28 U.S.C. § 1343. 

2. The corporate Defendant, MANS INVESTMENTS BROWARD COUNTY, LLC is a 

Florida limited liability company, having its principal place of business in Broward County, 

Florida, where the Plaintiff was employed. 

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3. Defendant N. Mallick, is a member and manager of the Employer and a resident of the 

State of Florida. 

4. Defendant S. Mallick is a member and manager of the Employer and a resident of the State 

of Florida.

5. This action is brought by Plaintiff to recover from the Employer unpaid minimum and 

overtime compensation, as well as an additional amount as liquidated damages, costs, and 

reasonable attorney’s fees under the provisions of 29 U.S.C. §201 et.seq., and specifically under 

the provisions of 29 U.S.C. § 207. 

6. Jurisdiction is conferred on this Court by Title 28 U.S.C. § 1337 and by Title 29 §216 (b). 

The Employer is and, at all times pertinent to this Complaint, was engaged in interstate commerce. 

7. This is an action for unpaid overtime compensation, unpaid minimum wage, as well as an 

additional amount as liquidated damages, costs and reasonable attorney’s fees pursuant to the 

FLSA, § 207. 

GENERAL ALLEGATIONS

8. Defendants’ business activities involve those for which the Fair Labor Standards Act 

applies. Both the Defendants’ business and the Plaintiff’s work for the Defendants affected 

interstate commerce during the relevant time period. Plaintiff’s work for the Defendants affected 

interstate commerce during the relevant time period because the materials and goods included, but 

were not limited to cleaning chemicals and other housekeeping and maintenance equipment, and 

electronics, that Plaintiff used on a constant and/or continual basis and/or that were supplied to 

Plaintiff by the Defendants to use on the job moved through interstate commerce prior to and/or 

subsequent to Plaintiff’s use of the same. The Plaintiff’s work for the Defendants was actually in 

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and/or so closely related to the movement of commerce while Plaintiff worked for the Defendants 

that the Fair Labor Standards Act applies to Plaintiff’s work for the Defendants. 

9. It is the understanding of Plaintiff that the Employer has revenues in excess of five hundred 

thousand Dollars for the years 2019, 2020, 2021, and 2022. 

10. Employer had more than two employees. 

11. By reason of the foregoing, the Employer is and was, during all times hereafter mentioned, 

an enterprise engaged in commerce of goods for commerce as defined in 29 U.S.C. §§ 3(r) and 

3(s) of the FLSA. 

12. From the moment Plaintiff was employed by Employer, Plaintiff worked and lived on the 

premises of the motel, which was located at 4211 North Federal Highway, Pompano Beach, 

Florida 33064 (the “Premises”). Plaintiff resided in the Premises with her young school aged 

daughter. 

13. When Plaintiff began working for Employer, N. Mallick told Plaintiff that she would be 

working for minimum wage, and upon showing that Plaintiff could provide good work, that 

Plaintiff’s pay would be increased. 

14. However, Plaintiff was mercilessly under-paid. In the year 2019 and previously, Plaintiff 

was paid $50.00 per-week by the Employer. In the years 2020, 2021, and 2022, Plaintiff was paid 

$75.00 per-week, by the Employer. Such equates to $7.14 and $10.71 per day, respectively. 

15. Plaintiff resided on the Premises and was expected to be immediately on call three hundred 

sixty-five days a year, between the hours of 6:30 a.m. to 12:00 a.m. Plaintiff would routinely be 

subjected to duties at all hours during this time period. Such duties included housekeeping, 

maintenance, customer relations, and even gaining access to motel rooms with unresponsive 

guests. 

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16. On the exceptionally rare periods where Plaintiff was able to leave the Premises, Plaintiff 

was still expected to be on call. On multiple occasions when Plaintiff was off premises with her 

young daughter, N. Mallick would demand her return to the Premises. In so far that N. Mallick 

would drive to pick up Plaintiff herself upon such calls and require that Plaintiff stop everything 

she was doing to attend needs at the Premises. Both managers of the Employer would not even 

allow Plaintiff time away from work and the premises to schedule doctor appointments for her 

daughter. 

17. Given Defendants’ requirement that Plaintiff be immediately available and Defendants’

requirement that Plaintiff be on call and working 17.5 hours each day, three hundred sixty-five 

days a year, Plaintiff’s housing on the premises was for the pure benefit of the Employer. 

18. Plaintiff worked every single day of the calendar year in 2019, 2020, 2021 and 2022. 

19. N. Mallick and S. Mallick were both direct supervisors of Plaintiff. N. Mallick and S. 

Mallick would provide Plaintiff with all her assigned tasks, at all hours of the day and night, and 

require Plaintiff to immediately conduct her work. 

20. Defendants willfully and intentionally refused to pay Plaintiff’s minimum wage and 

overtime wages as required by the Fair Labor Standards Act. Defendants knew of the overtime 

requirements of the Fair Labor Standards Act and intentionally failed to conduct any payroll 

practices in accordance with the Fair Labor Standards Act. Defendants remain owing Plaintiff 

these wages since the commencement of Plaintiff’s employment with Defendants for the time 

period specified above. 

21. The Defendants sold the Premises in May 2022 and no longer operate or own the motel. 

Plaintiff’s employment with Defendants terminated upon such sale. 

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22. Plaintiff has retained the law of the undersigned attorney to represent her in this action and 

is obligated to pay a reasonable attorney’s fees. 

COUNT I 

UNPAID MINIMUM WAGE VIOLATION AGAINST MANS INVESTMENTS 

BROWARD COUNTY, LLC

23. Plaintiff re-alleges and incorporates paragraphs 1 through 22 as fully set forth herein.

24. Employer failed to comply with Title 29 U.S.C. §§ 201 – 219 and 29 C.F.R. § 516.2 and § 

516.4 et. seq. in that it failed to pay Plaintiff required minimum wages for a portion of the work 

that the Plaintiff worked under 40-hours per week.

25. During the period of employment, Plaintiff was not paid the minimum wage required by 

the FLSA. Specially, Plaintiff worked for from 122.50 hours a week under the minimum wage 

required under the FLSA. 

26. Plaintiff was paid in the year 2019 $50 per week. Which equals approximate hourly wage 

of 0.40 cents per hour. 

27. In the years 2020, 2021, and 2022 Plaintiff was paid approximately $75.00 per week. Such 

equals a hour wage of approximately 0.61 cents per hour. 

28. Employer knew Plaintiff suffered or was permitted to work for Employer defined in 29 

U.S.C. § 203 (g) for less than minimum wage. 

29. Employer failed and refused to compensate Plaintiff for such work at the required

minimum wage, contrary to the provisions of the FLSA. 

30. At all times material hereto, Employer knew that the herein described refusal and /or 

failures were prohibited by the FLSA and intentionally and willfully violated the FLSA as cited 

herein and showed reckless disregard for whether herein described refusal and failure were 

violations of the FLSA. 

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31. At all times material hereto, Employer failed to maintain proper time records as mandated 

by the FLSA regarding the hours worked by Plaintiff. 

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

action and are obligated to pay a reasonable attorney’s fee.

WHEREFORE, Plaintiff requests compensatory and liquidated damages, prejudgment 

interest, and reasonable attorney’s fees from all Defendants, jointly and severally, pursuant to the 

Fair Labor Standards Act as cited above, to be proven at the time of trial for minimum wage owing 

from Plaintiffs’ entire employment period with Defendants, or as much as allowed by the Fair 

Labor Standards Act, whichever is greater, along with court costs. In the event that the Plaintiff 

does not recover liquidated damages, then Plaintiff seeks an award of prejudgment interest for 

unpaid minimum wage, and any and all other relief which this Court deems reasonable under the 

circumstances.

COUNT II

UNPAID MINIMUM WAGE VIOLATION AGAINST NISHI MALLICK

33. Plaintiff re-alleges and incorporates paragraphs 1 through 22 as fully set forth herein.

34. N. Mallick failed to comply with Title 29 U.S.C. §§ 201 – 219 and 29 C.F.R. § 516.2 and 

§ 516.4 et. seq. in that it failed to pay Plaintiff required minimum wages for a portion of the work 

that the Plaintiff worked under 40-hours per week.

35. During the period of employment, Plaintiff was not paid the minimum wage required by 

the FLSA. Specially, Plaintiff worked for from 122.50 hours a week under the minimum wage 

required under the FLSA. 

36. Defendant, N. Mallick, had day-to-day and operational control of Plaintiff and her 

compensation structure and is therefore an employer pursuant to 29 U.S.C. § 203(d)

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37. Plaintiff was paid in the year 2019 $50 per week. Which equals approximate hourly wage 

of 0.40 cents per hour. 

38. In the years 2020, 2021, and 2022 Plaintiff was paid approximately $75.00 per week. Such 

equals an per-hour wage of approximately 0.61 cents per hour. 

39. N. Mallick knew Plaintiff suffered or was permitted to work for Employer defined in 29 

U.S.C. § 203 (g) for less than minimum wage. 

40. N. Mallick failed and refused to compensate Plaintiff for such work at the required

minimum wage, contrary to the provisions of the FLSA. 

41. At all times material hereto, N. Mallick knew that the herein described refusal and /or 

failures were prohibited by the FLSA and intentionally and willfully violated the FLSA as cited 

herein and showed reckless disregard for whether herein described refusal and failure were 

violations of the FLSA. 

42. At all times material hereto, N. Mallick failed to maintain proper time records as mandated 

by the FLSA regarding the hours worked by Plaintiff. 

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

action and are obligated to pay a reasonable attorney’s fee.

WHEREFORE, Plaintiff requests compensatory and liquidated damages, prejudgment 

interest, and reasonable attorney’s fees from all Defendants, jointly and severally, pursuant to the 

Fair Labor Standards Act as cited above, to be proven at the time of trial for minimum wage owing 

from Plaintiffs’ entire employment period with Defendants, or as much as allowed by the Fair 

Labor Standards Act, whichever is greater, along with court costs. In the event that the Plaintiff 

does not recover liquidated damages, then Plaintiff seeks an award of prejudgment interest for 

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unpaid minimum wage, and any and all other relief which this Court deems reasonable under the 

circumstances

COUNT III

UNPAID MINIMUM WAGE VIOLATION AGAINST SHREYA MALLICK

44. Plaintiff re-alleges and incorporates paragraphs 1 through 22 as fully set forth herein.

45. S. Mallick failed to comply with Title 29 U.S.C. §§ 201 – 219 and 29 C.F.R. § 516.2 and 

§ 516.4 et. seq. in that it failed to pay Plaintiff required minimum wages for a portion of the work 

that the Plaintiff worked under 40-hours per week.

46. Defendant, S. Mallick, had day-to-day and operational control of Plaintiff and her 

compensation structure and is therefore an employer pursuant to 29 U.S.C. § 203(d)

47. During the period of employment, Plaintiff was not paid the minimum wage required by 

the FLSA. Specially, Plaintiff worked for from 122.50 hours a week under the minimum wage 

required under the FLSA.

48. Plaintiff was paid in the year 2019 $50 per week. Which equals approximate hourly wage 

of 0.40 cents per hour. 

49. In the years 2020, 2021, and 2022 Plaintiff was paid approximately $75.00 per week. Such 

equals an per-hour wage of approximately 0.61 cents per hour. 

50. S. Mallick knew Plaintiff suffered or was permitted to work for Employer defined in 29 

U.S.C. § 203 (g) for less than minimum wage. 

51. S. Mallick failed and refused to compensate Plaintiff for such work at the required

minimum wage, contrary to the provisions of the FLSA. 

52. At all times material hereto, S. Mallick knew that the herein described refusal and /or 

failures were prohibited by the FLSA and intentionally and willfully violated the FLSA as cited 

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herein and showed reckless disregard for whether herein described refusal and failure were 

violations of the FLSA. 

53. At all times material hereto, S. Mallick failed to maintain proper time records as mandated 

by the FLSA regarding the hours worked by Plaintiff. 

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

action and are obligated to pay a reasonable attorney’s fee.

WHEREFORE, Plaintiff requests compensatory and liquidated damages, prejudgment 

interest, and reasonable attorney’s fees from all Defendants, jointly and severally, pursuant to the 

Fair Labor Standards Act as cited above, to be proven at the time of trial for minimum wage owing 

from Plaintiffs’ entire employment period with Defendants, or as much as allowed by the Fair 

Labor Standards Act, whichever is greater, along with court costs. In the event that the Plaintiff 

does not recover liquidated damages, then Plaintiff seeks an award of prejudgment interest for 

unpaid minimum wage, and any and all other relief which this Court deems reasonable under the 

circumstances

COUNT IV

UNPAID OVERTIME VIOLATION AGAINST MANS INVESTMENTS BROWARD 

COUNTY, LLC

55. Plaintiff re-alleges and incorporates paragraphs 1 through 22 as fully set forth herein.

56. At all times material hereto, the Employer failed to comply with Title 29 U.S.C. §§ 201 –

219 and 29 C.F.R. § 516.2 and § 516.4 et. seq. in that Plaintiff performed services and worked in 

excess of the maximum hours provided by the FLSA but no provision was made by the Employer 

to properly pay Plaintiff at the rate of time and one-half for all hours worked in excess of 40-hours 

per week as mandated in the FLSA.

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57. Plaintiff was a non-exempt employee, entitled to be paid at the rate of one and one-half for 

all hours worked in excess of forty (40) hours per week

58. During the period of employment, Plaintiff was not paid the overtime wages as required 

by the FLSA. Specially, Plaintiff worked for from 122.50 hours a week under the minimum wage 

required under the FLSA. 

59. Plaintiff was paid in the year 2019 $50 per week. Which equals approximate hourly wage 

of 0.40 cents per hour. 

60. In the years 2020, 2021, and 2022 Plaintiff was paid approximately $75.00 per week. Such 

equals an per-hour wage of approximately 0.61 cents per hour. 

61. Therefore, Plaintiff has unpaid overtime in the amount of 82.5 hours per-week. 

62. Employer failed to pay Plaintiff the required wages in violation of the overtime wage 

requirement established by the FLSA.

63. Employer failed to properly maintain records for additional hours worked by Plaintiff in 

excess of forty (40) hours per week.

64. Plaintiff worked on average 82.5 over time hours per week for which she was only 

compensated at a below minimum wage rate. 

65. Employer knew Plaintiff suffered or was permitted to work for Employer defined in 29 

U.S.C. § 203 (g) for less than required overtime pay. 

66. Employer failed and refused to compensate Plaintiff for such work at the required

minimum wage, contrary to the provisions of 29 U.S.C. § 207(a). 

67. At all times material hereto, Employer knew that the herein described refusal and /or 

failures were prohibited by the FLSA and intentionally and willfully violated the FLSA as cited 

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herein and showed reckless disregard for whether herein described refusal and failure were 

violations of the FLSA. 

68. At all times material hereto, Employer failed to maintain proper time records as mandated 

by the FLSA regarding the hours worked by Plaintiff. 

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

action and are obligated to pay a reasonable attorney’s fee.

WHEREFORE, Plaintiff requests compensatory and liquidated damages, prejudgment 

interest, and reasonable attorney’s fees from all Defendants, jointly and severally, pursuant to the 

Fair Labor Standards Act as cited above, to be proven at the time of trial for overtime owing from 

Plaintiff’s entire employment period with Defendants, or as much as allowed by the Fair Labor 

Standards Act, whichever is greater, along with court costs. In the event that the Plaintiff does not 

recover liquidated damages, then Plaintiff seeks an award of prejudgment interest for unpaid 

overtime, and any and all other relief which this Court deems reasonable under the circumstances

COUNT V

UNPAID OVERTIME VIOLATION AGAINST NISHI MALLICK

70. Plaintiff re-alleges and incorporates paragraphs 1 through 22 as fully set forth herein.

71. At all times material hereto, the Employer failed to comply with Title 29 U.S.C. §§ 201 –

219 and 29 C.F.R. § 516.2 and § 516.4 et. seq. in that Plaintiff performed services and worked in 

excess of the maximum hours provided by the FLSA but no provision was made by the Employer 

to properly pay Plaintiff at the rate of time and one-half for all hours worked in excess of 40-hours 

per week as mandated in the FLSA.

72. Plaintiff was a non-exempt employee, entitled to be paid at the rate of one and one-half for 

all hours worked in excess of forty (40) hours per week. 

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73. Defendant, N. Mallick, had day-to-day and operational control of Plaintiff and her 

compensation structure and is therefore an employer pursuant to 29 U.S.C. § 203(d)

74. During the period of employment, Plaintiff was not paid the overtime wages as required 

by the FLSA. Specially, Plaintiff worked for from 122.50 hours a week under the minimum wage 

required under the FLSA. 

75. Plaintiff was paid in the year 2019 $50 per week. Which equals approximate hourly wage 

of 0.40 cents per hour. 

76. In the years 2020, 2021, and 2022 Plaintiff was paid approximately $75.00 per week. Such 

equals an per-hour wage of approximately 0.61 cents per hour. 

77. Therefore, Plaintiff has unpaid overtime in the amount of 82.5 hours per-week. 

78. N. Mallick failed to pay Plaintiff the required wages in violation of the overtime wage 

requirement established by the FLSA.

79. N. Mallick failed to properly maintain records for additional hours worked by Plaintiff in 

excess of forty (40) hours per week.

80. Plaintiff worked on average 82.5 over time hours per week for which she was only 

compensated at a below minimum wage rate. 

81. N. Mallick knew Plaintiff suffered or was permitted to work for Employer defined in 29 

U.S.C. § 203 (g) for less than required overtime pay. 

82. N. Mallick failed and refused to compensate Plaintiff for such work at the required

minimum wage, contrary to the provisions of 29 U.S.C. § 207(a). 

83. At all times material hereto, N. Mallick knew that the herein described refusal and /or 

failures were prohibited by the FLSA and intentionally and willfully violated the FLSA as cited 

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herein and showed reckless disregard for whether herein described refusal and failure were 

violations of the FLSA. 

84. At all times material hereto, N. Mallick failed to maintain proper time records as mandated 

by the FLSA regarding the hours worked by Plaintiff. 

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

action and are obligated to pay a reasonable attorney’s fees. 

WHEREFORE, Plaintiff requests compensatory and liquidated damages, prejudgment 

interest, and reasonable attorney’s fees from all Defendants, jointly and severally, pursuant to the 

Fair Labor Standards Act as cited above, to be proven at the time of trial for overtime owing from 

Plaintiff’s entire employment period with Defendants, or as much as allowed by the Fair Labor 

Standards Act, whichever is greater, along with court costs. In the event that the Plaintiff does not 

recover liquidated damages, then Plaintiff seeks an award of prejudgment interest for unpaid 

overtime, and any and all other relief which this Court deems reasonable under the circumstances.

COUNT VI

UNPAID OVERTIME VIOLATION AGAINST SHREYA MALLICK

86. Plaintiff re-alleges and incorporates paragraphs 1 through 22 as fully set forth herein.

87. At all times material hereto, the Employer failed to comply with Title 29 U.S.C. §§ 201 –

219 and 29 C.F.R. § 516.2 and § 516.4 et. seq. in that Plaintiff performed services and worked in 

excess of the maximum hours provided by the FLSA but no provision was made by the Employer 

to properly pay Plaintiff at the rate of time and one-half for all hours worked in excess of 40-hours 

per week as mandated in the FLSA.

88. Plaintiff was a non-exempt employee, entitled to be paid at the rate of one and one-half for 

all hours worked in excess of forty (40) hours per week. 

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89. Defendant, S. Mallick, had day-to-day and operational control of Plaintiff and her 

compensation structure and is therefore an employer pursuant to 29 U.S.C. § 203(d)

90. During the period of employment, Plaintiff was not paid the overtime wages as required 

by the FLSA. Specially, Plaintiff worked for from 122.50 hours a week under the minimum wage 

required under the FLSA. 

91. Plaintiff was paid in the year 2019 $50 per week. Which equals approximate hourly wage 

of 0.40 cents per hour. 

92. In the years 2020, 2021, and 2022 Plaintiff was paid approximately $75.00 per week. Such 

equals an per-hour wage of approximately 0.61 cents per hour. 

93. Therefore, Plaintiff has unpaid overtime in the amount of 82.5 hours per-week. 

94. S. Mallick failed to pay Plaintiff the required wages in violation of the overtime wage 

requirement established by the FLSA.

95. S. Mallick failed to properly maintain records for additional hours worked by Plaintiff in 

excess of forty (40) hours per week.

96. Plaintiff worked on average 82.5 over time hours per week for which she was only 

compensated at a below minimum wage rate. 

97. S. Mallick knew Plaintiff suffered or was permitted to work for Employer defined in 29 

U.S.C. § 203 (g) for less than required overtime pay. 

98. S. Mallick failed and refused to compensate Plaintiff for such work at the required

minimum wage, contrary to the provisions of 29 U.S.C. § 207(a). 

99. At all times material hereto, S. Mallick knew that the herein described refusal and /or 

failures were prohibited by the FLSA and intentionally and willfully violated the FLSA as cited 

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herein and showed reckless disregard for whether herein described refusal and failure were 

violations of the FLSA. 

100. At all times material hereto, S. Mallick failed to maintain proper time records as mandated 

by the FLSA regarding the hours worked by Plaintiff. 

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

action and are obligated to pay a reasonable attorney’s fees. 

WHEREFORE, Plaintiff requests compensatory and liquidated damages, prejudgment 

interest, and reasonable attorney’s fees from all Defendants, jointly and severally, pursuant to the 

Fair Labor Standards Act as cited above, to be proven at the time of trial for overtime owing from 

Plaintiff’s entire employment period with Defendants, or as much as allowed by the Fair Labor 

Standards Act, whichever is greater, along with court costs. In the event that the Plaintiff does not 

recover liquidated damages, then Plaintiff seeks an award of prejudgment interest for unpaid 

overtime, and any and all other relief which this Court deems reasonable under the circumstances.

Respectfully Submitted,

 VAZQUEZ & ASSOCIATES

 Attorneys for Plaintiff

By: /s/ STEVEN B. HERZBERG

Steven B. Herzberg, Esq.

Florida Bar No. 111541

E-mail: sh@gvazquez.com

By: /s/ GERARDO A. VAZQUEZ 

Gerardo A. Vazquez, Esq.

Florida Bar No. 006904

E-mail: gv@gvazquez.com

1111 Brickell Avenue, Suite 1550

Miami, Florida 33131

Phone: (305) 371-8064

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JURY DEMAND

Plaintiff demand trial by jury of all issues triable as of right by jury.

By: /s/ STEVEN B. HERZBERG

Steven B. Herzberg, Esq.

Florida Bar No. 111541

E-mail: sh@gvazquez.com

By: /s/ GERARDO A. VAZQUEZ 

Gerardo A. Vazquez, Esq.

Florida Bar No. 006904

E-mail: gv@gvazquez.com

1111 Brickell Avenue, Suite 1550

Miami, Florida 33131

Phone: (305) 371-8064

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