UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 9:22-cv-81684-JIC

IONA LEWIS and JACLYN HEERY,

individually and on behalf of all others

similarly situated,

Plaintiffs,

vs.

HOMESPIRE MORTGAGE 

CORPORATION, a Maryland corporation,

Defendant.

 /

PLAINTIFFS’ SUPPLEMENTAL STATEMENT OF CLAIM

Plaintiffs, by and through undersigned counsel, hereby file their Statement of Claim, as 

follows:1

All Plaintiffs seek the statutory minimum wages due them, “free and clear,” along with 

liquidated damages, reasonable attorneys' fees, and costs of suit, and for all other relief the Court 

deems just and proper, including a declaration Defendant’s Pay Policy violates the FLSA and 

injunctive relief prohibiting Defendant from maintaining the Pay Policy going forward. The 

statutory minimum wages due Plaintiffs is based on a minimum of forty (40) hours worked by 

Plaintiffs, per workweek, during the first three (3) months of their respective employment.

All Plaintiffs also seek overtime compensation.

Plaintiff, Lewis, also seeks additional unpaid minimum wages for the last pay period of her 

employment ($522.00), liquidated damages in that same amount ($522.00), along with unpaid 

1 Plaintiffs will file amended statements of claim at appropriate intervals based on the timing of 

any consents to join filed by additional similarly situated individuals, or as this Court orders otherwise.

Case 9:22-cv-81684-JIC Document 49 Entered on FLSD Docket 02/13/2023 Page 1 of 3
commissions for her entire tenure. Lewis will amend this statement once Homespire produces 

relevant documentation relating to the commissions owed. Otherwise, the following table 

summarizes the estimated/approximated claims of all Plaintiffs thus far:

Name Dates of Weekly Hourly Minimum OT

Employment Hours Rate of Wages Comp

 Worked Pay Owed Owed

 At Federal

 Rate

Iona Lewis2 4/18/22 – 8/25/22 45 $15.00 $3,480.00 $2,025.00

Jaclyn Heery3 3/7/22 – 10/14/22 50 $15.00 $3,480.00 $6,975.00

Brian Smith4 3/2022 – 10/2022 50 $15.00 $3,480.00 $6,975.00

Michele Garcia5 1/28/22 – 10/12/22 60 $15.00 $3,480.00 $18,000.00

Chris Ivester6 3/22/22 – 10/14/22 47.5 $15.00 $3,480.00 $5,231.25

Anthony 

Hernandez7

1/3/22 – 8/25/22 57.5 $15.00 $3,480.00 $14,568.75

William Bulloch8 2/28/22 – 10/14/22 60 $15.00 $3,480.00 $14,400.00

Savannah Pringle9 4/22 – 8/22 47.5 $15.00 $3,480.00 $3,037.50

Elizabeth Oviedo10 7/15/22 – 11/15/22 45 $15.00 $3,480.00 $1,912.50

Terry O’Neill11 5/2/22 – 10/15/22 42.5 $15.00 $3,480.00 $1,293.75

Tiffany Hightower12 2/22 – 7/22 60 $15.00 $3,480.00 $9,675.00

2 Homespire located Lewis in one its Boca Raton, Florida branch.

3 Homespire located Heery in its Roswell, Georgia branch.

4 Homespire located Smith in its Roswell, Georgia branch.

5 Homespire located Garcia in its Orlando, Florida branch.

6 Homespire located Ivester in its Roswell, Georgia branch.

7 Homespire located Hernandez in its Miami, Florida branch.

8 Homespire located Bulloch in its Roswell, Georgia branch.

9 Homespire located Pringle in its Roswell, Georgia branch.

10 Homespire located Oviedo in its Providence, Rhode Island branch.

11 Homespire located O’Neill in its Kansas City, Missouri branch.

12 Homespire located Hightower in its Oklahoma City, Oklahoma branch.

Case 9:22-cv-81684-JIC Document 49 Entered on FLSD Docket 02/13/2023 Page 2 of 3
Name Total Wages Liquidated Damages Total Damages

Owed

Iona Lewis $5,505.00 $5,505.00 $11,010.00

Jaclyn Heery $10,455.00 $10,455.00 $20,910.00

Brian Smith $10,455.00 $10,455.00 $20,910.00

Michele Garcia $21,480.00 $21,480.00 $42,960.00

Chris Ivester $8,711.25 $8,711.25 $17,422.50

Anthony Hernandez $18,048.75 $18,048.75 $36,097.50

William Bulloch $17,880.00 $17,880.00 $35,760.00

Savannah Pringle $6,517.50 $6,517.50 $13,035.00

Elizabeth Oviedo $5,392.50 $5,392.50 $10,784.00

Terry O’Neill $4,773.75 $4,773.75 $9,547.50

Tiffany Hightower $13,155.00 $13,155.00 $26,310.00

* All dates and hours are estimated/approximated, subject to amendment based on production of 

Defendant’s wage and hour records.

+ Overtime calculations subject to amendment based on production of Defendant’s commission 

payment records.

Dated: February 10, 2023

Boca Raton, FL

Daniel R. Levine 

Daniel R. Levine, Esq.

Fla. Bar No. 0057861

E-Mail: drl@pbl-law.com

PADULA BENNARDO LEVINE LLP

3837 NW Boca Raton Blvd., Suite 200

Boca Raton, FL 33431

Attorneys for Plaintiffs

Case 9:22-cv-81684-JIC Document 49 Entered on FLSD Docket 02/13/2023 Page 3 of 3