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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

CASE NO.: 

TED MENDEZ

and other similarly situated individuals,

Plaintiff (s), 

v. 

WASH PLUS, LLC,

and MICHAEL D. KELCH, individually, 

Defendants,

__________________________________/ 

COMPLAINT

(OPT-IN PURSUANT TO 29 U.S.C § 216(b)) 

COMES NOW the Plaintiff, TED MENDEZ, and other similarly situated individuals, by 

and through the undersigned counsel, and hereby sues Defendants WASH PLUS, LLC, and

MICHAEL D. KELCH, individually, and alleges: 

JURISDICTION VENUES AND PARTIES

1. This is an action to recover money damages for unpaid overtime wages under the laws of the 

United States. This Court has jurisdiction pursuant to Title 28 U.S.C. § 1337 and by Title 29 

U.S.C. § 201-219, § 216(b), the Fair Labor Standards Act, "the Act," (Section 216 for 

jurisdictional placement). 

2. Plaintiff TED MENDEZ is a resident of Florida, within the jurisdiction of this Honorable 

Court. Plaintiff is a covered employee for purposes of the Act. 

3. Defendant WASH PLUS, LLC (hereinafter, WASH PLUS, or Defendant) is a Florida 

corporation with its place of business in Pompano Beach, Broward County, within the 

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jurisdiction of this Court. At all times material, Defendant was and is engaged in interstate 

commerce. 

4. The individual Defendant MICHAEL D. KELCH was and is now the owner/partner and 

manager of Defendant Corporation WASH PLUS. This individual Defendant was the 

Employer of Plaintiff and others similarly situated within the meaning of Section 3(d) of the 

"Fair Labor Standards Act" [29 U.S.C. § 203(d)]. 

5. All the actions raised in this Complaint took place in Broward County, Florida, within the 

jurisdiction of this Court. 

GENERAL ALLEGATIONS

6. This cause of action is brought by Plaintiff TED MENDEZas a collective action to recover 

from Defendants overtime compensation, liquidated damages, costs, and reasonable attorney's 

fees under the provisions of Fair Labor Standards Act, as amended, 29 U.S.C. § 201 et seq (the 

"FLA or the "ACT") on behalf of Plaintiff, and all other current and former employees similarly 

situated to Plaintiff ("the asserted class") who worked over forty (40) hours during one or more 

weeks on or after February 2021, (the "material time") without being compensated overtime 

wages pursuant to the FLSA.

7. Corporate Defendant WASH PLUS is a seller of car wash systems. Defendant provides 

installation, maintenance, and repair services for these machines. Defendant also sells car wash 

chemicals and supplies for these machines. Defendant has facilities located at 22100 NW 22 

Street, Pompano Beach, Florida 330069, where Plaintiff picked up his work orders, the 

company truck, equipment, and supplies to perform his work. 

8. Defendants also operate from an office in Davenport and a storage locker near Orlando 

International Airport. 

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9. Defendants WASH PLUS and MICHAEL D. KELCH employed Plaintiff TED MENDEZ as 

a non-exempted, full-time, hourly employee from approximately February 05, 2021, to May 

26, 2022, or 68 weeks. 

10. Plaintiff had duties as a car wash machine technician. Plaintiff installed, gave maintenance, 

and repaired car wash systems. Plaintiff was a non-exempted full-time hourly employee, and 

he had a wage rate of $25.00 an hour. Plaintiff's overtime rate should be $37.50 an hour. 

11. During his employment with Defendants, Plaintiff worked regularly and consistently more 

than 40 hours weekly. However, Plaintiff was not paid for all his hours worked, nor overtime 

hours. 

12. Plaintiff had a regular schedule, and he worked 6 days per week. From Monday to Friday, 

Plaintiff worked from 7:00 AM to 6:00 PM (11 hours). On Saturdays, Plaintiff worked from 

8:00 AM to 1:00 PM (5 Hours). Every week, Plaintiff completed between 55 and 60 working 

hours, or an average of 57.5 hours weekly. Plaintiff was unable to take bonafide lunchtime. 

13. Plaintiff regularly worked an average of 57.5 hours. However, Defendants paid Plaintiff for 

less than 40 hours weekly, but they did not compensate Plaintiff for overtime hours.

Defendants paid Plaintiff only for billable hours or the hours that Defendants billed its clients. 

14. Defendants requested Plaintiff and other similarly situated individuals to report only billable 

hours. They did not allow Plaintiff and other similarly situated individuals to document the 

actual number of hours worked, including travel time. 

15. Defendants failed to count as hours worked and part of his principal activity the time spent by 

Plaintiff traveling from job site to job site during the workday and the time spent traveling 

away to distant locations. The time spent traveling to the different worksites was part of 

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Plaintiff's principal activity. Consequently, this time was working time and must be counted as 

hours worked.

16. Due to Defendants' unlawful employment practices, Plaintiff estimates he was not paid for an 

average of 10 regular hours weekly. Plaintiff was not paid for a substantial number of hours at 

any rate, not even at the minimum wage rate, as established by federal and state law.

17. Therefore, Defendants willfully failed to pay Plaintiff minimum wages in violation of the Fair 

Labor Standards Act, 29 U.S.C. §206, et seq.

18. Every week, Plaintiff worked an average of 57.5 hours. However, he was not compensated for 

overtime hours as required by law.

19. Plaintiff did not clock in and out, but Defendants could track the number of hours worked by 

Plaintiff and other similarly situated individuals. Defendants knew that Plaintiff was working 

more than 40 hours weekly. 

20. Therefore, Defendants willfully failed to pay Plaintiff overtime wages, at the rate of time and 

a half his regular rate, for every hour that he worked in excess of forty (40), in violation of 

Section 7 (a) of the Fair Labor Standards Act of 1938 (29 U.S.C. 207(a)(1).

21. Plaintiff was paid bi-weekly with checks and paystubs that did not reflect the actual number of 

days and hours worked.

22. Plaintiff disagreed with the lack of payment for overtime hours, and he complained verbally to 

his supervisor and owner of the business, MICHAEL D. KELCH, many times. He was told 

that the company compensated only for billable hours, and they did not pay overtime hours. 

23. On or about May 26, 2022, Plaintiff was forced to leave his employment because, because he 

was working too many uncompensated hours. 

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24. The additional persons who may become Plaintiffs in this action are employees and/or former 

employees of Defendants who are and who were subject to the unlawful payroll practices and 

procedures of Defendants and were not paid minimum wages and overtime wages at the rate 

of time and one-half of their regular rate of pay for all overtime hours worked in excess of 

forty. 

COUNT I:

WAGE AND HOUR FEDERAL STATUTORY VIOLATION;

FAILURE TO PAY OVERTIME; AGAINST ALL DEFENDANTS

25. Plaintiff TED MENDEZ re-adopts every factual allegation stated in paragraphs 1-24 above as 

if set out in full herein. 

26. This action is brought by Plaintiff TED MENDEZ and those similarly situated to recover from 

the Employer unpaid overtime compensation, as well as an additional amount of 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. 29 U.S.C. § 207 (a)(1) states, "No 

employer shall employ any of his employees... for a workweek longer than 40 hours unless 

such employee receives compensation for his employment in excess of the hours above

specified at a rate, not less than one and a half times the regular rate at which he is employed." 

27. The employer WASH PLUS was engaged in interstate commerce as defined in §§ 3 (r) and 

3(s) of the Act, 29 U.S.C. § 203(r) and 203(s)(1)(A). Defendant is a distributor of car wash 

equipment and supplies and is also a seller of car wash chemicals. At all times pertinent to this 

Complaint, the Employer/Defendant operates as an organization that sells and/or markets its 

services to customers throughout the United States. Employer/Defendant obtains and solicits 

funds from non-Florida sources, accepts funds from non-Florida sources, uses telephonic 

transmissions going over state lines to do its business, and transmits funds outside of the State 

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of Florida. Upon information and belief, the annual gross revenue of the Employer/Defendant 

was always more than $500,000 per annum. Therefore, there is enterprise coverage.

28. Plaintiff was employed by an enterprise engaged in interstate commerce. Through his daily 

activities, Plaintiff and other employees similarly situated regularly and recurrently

participated in interstate commerce by handling and working on goods and materials and 

materials that were produced for commerce and moved across State lines at any time during 

the business. Therefore, there is individual coverage.

29. Defendants WASH PLUS and MICHAEL D. KELCH employed Plaintiff TED MENDEZ as 

a non-exempted, full-time, hourly employee from approximately February 05, 2021, to May 

26, 2022, or 68 weeks. 

30. Plaintiff had duties as a car wash machine technician. Plaintiff installed, gave maintenance, 

and repaired car wash systems. Plaintiff was a non-exempted full-time hourly employee, and 

he had a wage rate of $25.00 an hour. Plaintiff's overtime rate should be $37.50 an hour. 

31. During his employment with Defendants, Plaintiff worked regularly and consistently more 

than 40 hours weekly. However, Plaintiff was not paid for all his regular or overtime hours. 

32. Plaintiff had a regular schedule, and he worked 6 days per week, an average of 57.5 hours 

weekly. Plaintiff was unable to take bonafide lunchtime. 

33. Plaintiff regularly worked an average of 57.5 hours. However, Defendants paid Plaintiff for 

less than 40 hours weekly, and they did not compensate Plaintiff for overtime hours. 

Defendants paid Plaintiff only for billable hours or the hours that Defendants billed its clients. 

34. Defendants failed to count as hours worked and part of his principal activity the time spent by 

Plaintiff traveling from job site to job site during the workday and the time spent traveling 

away to distant locations. The time spent traveling to the different worksites was part of 

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Plaintiff's principal activity. Consequently, this travel time was working time and must be 

counted as hours worked. 

35. Defendants requested Plaintiff and other similarly situated individuals to report only billable 

hours. They did not allow Plaintiff and other similarly situated individuals to document the 

actual number of hours worked. 

36. Due to Defendants' unlawful employment practices, Plaintiff worked an average of 57.5 hours. 

However, he was not compensated for overtime hours as required by law.

37. Plaintiff did not clock in and out, but Defendants could track the number of hours worked by 

Plaintiff and other similarly situated individuals. Defendants knew that Plaintiff was working 

more than 40 hours weekly. 

38. Therefore, Defendants willfully failed to pay Plaintiff overtime wages, at the rate of time and 

a half his regular rate, for every hour that he worked in excess of forty (40), in violation of 

Section 7 (a) of the Fair Labor Standards Act of 1938 (29 U.S.C. 207(a)(1).

39. Plaintiff was paid bi-weekly with checks and paystubs that did not reflect the actual number of 

days and hours worked.

40. The records, if any, concerning the number of hours worked by Plaintiff and all other 

employees and the compensation paid to such employees should be in the possession and 

custody of Defendants. Nevertheless, upon information and belief, Defendants did not 

maintain accurate and complete time records of hours worked by Plaintiff and other employees 

in the asserted class. Defendants violated the record-keeping requirements of FLSA, 29 CFR 

Part 516.

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41. Defendant never posted any notice, as required by the Fair Labor Standards Act and Federal 

Law, to inform employees of their federal rights to overtime and minimum wage payments. 

Defendant violated the Posting requirements of 29 U.S.C. § 516.4.

42. Prior to the completion of discovery and to the best of Plaintiff's knowledge, at the time of the 

filing of this Complaint, Plaintiff's good faith estimate of unpaid overtime wages is as follows:

*Please note that this amount is based on a preliminary calculation and that these figures could be subject to 

modification as new evidence could dictate. After proper discovery, calculations will be adjusted. 

a. Total amount of alleged unpaid wages: 

Forty-Four Thousand Six Hundred Twenty-Five Dollars and /100 ($44,625.00) 

b. Calculation of such wages: 

 Total time of employment: 68 weeks

Total relevant weeks of employment: 68 weeks

Total hours worked: 57.5 average 

Regular rate: $25.00 an hour x 1.5=$37.50 O//T rate 

$37.50 x 17.5=$656.25 weekly x 68 weeks=$44,625.00

 

c. Nature of wages (e.g., overtime or straight time):

 This amount represents unpaid half-time overtime hours. 

 

43. At all times material hereto, the Employers/Defendants failed to comply with Title 29 U.S.C. 

§207 (a) (1). In that, Plaintiff and those similarly-situated performed services and worked in 

excess of the maximum hours provided by the Act, but no provision was made by the 

Defendants to properly pay Plaintiff and others similarly situated at the rate of time and one 

half for all hours worked in excess of forty hours (40) per workweek as provided in said Act. 

44. Defendants knew and/or showed reckless disregard of the provisions of the Act concerning the 

payment of overtime wages as required by the Fair Labor Standards Act and remain owing 

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

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Plaintiff and those similarly-situated employees' employment with Defendants as set forth 

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

45. At times mentioned, individual Defendant MICHAEL D. KELCH was and is now the 

owner/partner and manager of WASH PLUS. Defendants MICHAEL D. KELCH was the 

Employer of Plaintiff and others similarly situated within the meaning of Section 3(d) of the 

"Fair Labor Standards Act" [29 U.S.C. § 203(d)]. This individual Defendant acted directly in

WASH PLUS' interests concerning its employees, including Plaintiff and others similarly 

situated. Defendant MICHAEL D. KELCH had financial and operational control of the 

business, provided Plaintiff with his work schedule, and he is jointly and severally liable for 

Plaintiff's damages.

46. Defendants WASH PLUS and MICHAEL D. KELCH willfully and intentionally refused to 

pay Plaintiff overtime wages as required by the law of the United States and remain owing 

Plaintiff and other similarly situated overtime wages since the commencement of Plaintiff's 

employment with Defendants, as set forth above. 

47. Plaintiff TED MENDEZ has retained the law offices of the undersigned attorney to represent 

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

PRAYER FOR RELIEF

WHEREFORE, Plaintiff TED MENDEZ and those similarly situated respectfully requests that 

this Honorable Court: 

A. Enter judgment for Plaintiff TED MENDEZ and other similarly situated individuals and 

against the Defendants WASH PLUS and MICHAEL D. KELCH, based on Defendants' willful 

violations of the Fair Labor Standards Act, 29 U.S.C. § 201 et seq.; and 

B. Award Plaintiff TED MENDEZ actual damages in the amount shown to be due for unpaid 

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overtime compensation for hours worked in excess of forty weekly, with interest; and

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

D. Award Plaintiff reasonable attorneys' fees and costs of suit; and 

E. Grant such other and further relief as this Court deems equitable and just and/or available 

pursuant to Federal Law. 

JURY DEMAND

Plaintiff TED MENDEZ demands a trial by jury of all issues triable as of right by jury.

COUNT II: 

F.L.S.A. WAGE AND HOUR FEDERAL STATUTORY VIOLATION: FAILURE TO 

PAY MINIMUM WAGE; AGAINST ALL DEFENDANTS

48. Plaintiff re-adopts every factual allegation stated in paragraphs 1-24 of this Complaint as if set 

out in full herein.

49. The employer WASH PLUS was engaged in interstate commerce as defined in §§ 3 (r) and 

3(s) of the Act, 29 U.S.C. § 203(r) and 203(s)(1)(A). Defendant is a distributor of car wash 

equipment and supplies and is also a seller of car wash chemicals. At all times pertinent to this 

Complaint, the Employer/Defendant operates as an organization that sells and/or markets its 

services to customers throughout the United States. Employer/Defendant obtains and solicits 

funds from non-Florida sources, accepts funds from non-Florida sources, uses telephonic 

transmissions going over state lines to do its business, and transmits funds outside of the State 

of Florida. Upon information and belief, the annual gross revenue of the Employer/Defendant 

was always more than $500,000 per annum. Therefore, there is enterprise coverage.

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50. Plaintiff was employed by an enterprise engaged in interstate commerce. Through his daily 

activities, Plaintiff and other employees similarly situated regularly and recurrently

participated in interstate commerce by handling and working on goods and materials and 

materials that were produced for commerce and moved across State lines at any time during 

the business. Therefore, there is individual coverage.

51. This action is brought by Plaintiff to recover from the Employer unpaid minimum wages, 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. 

§206. U.S.C. §206 states, "Every Employer shall pay to each of his employees who in any 

workweek is engaged in commerce or in the production of goods for commerce, or is employed 

in an enterprise engaged in commerce or in the production of goods for commerce, wages at 

the following rates: 

 (1) except as otherwise provided in this section, not less than— 

(A) $5.85 an hour, beginning on the 60th day after May 25, 2008; 

(B) $6.55 an hour, beginning 12 months after that 60th day; and 

 (C) $7.25 an hour, beginning 24 months after that 60th day. 

52. Defendants WASH PLUS and MICHAEL D. KELCH employed Plaintiff TED MENDEZ as 

a non-exempted, full-time, hourly employee from approximately February 05, 2021, to May 

26, 2022, or 68 weeks. 

53. Plaintiff had duties as a car wash machine technician. Plaintiff installed, gave maintenance, 

and repaired car wash systems. Plaintiff was a non-exempted full-time hourly employee, and 

he had a wage rate of $25.00 an hour. Plaintiff's overtime rate should be $37.50 an hour. 

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54. During his employment with Defendants, Plaintiff worked regularly and consistently more 

than 40 hours weekly. However, Plaintiff was not paid for all his hours worked 

55. Plaintiff had a regular schedule, and he worked 6 days per week average of 57.5 hours weekly. 

Plaintiff was unable to take bonafide lunchtime. 

56. Plaintiff regularly worked an average of 57.5 hours. However, Defendants paid Plaintiff for 

less than 40 hours weekly. Defendants paid Plaintiff only for billable hours or the hours that 

Defendants billed its clients. 

57. Defendants requested Plaintiff and other similarly situated individuals to report only billable 

hours. They did not allow Plaintiff and other similarly situated individuals to document the 

actual number of hours worked. 

58. Defendants failed to count as hours worked and part of his principal activity the time spent by 

Plaintiff traveling from job site to job site during the workday and the time spent traveling 

away to distant locations. The time spent traveling to the different worksites was part of 

Plaintiff's principal activity. Consequently, this time was working time and must be counted as 

hours worked. 

59. Due to Defendants' unlawful employment practices, Plaintiff estimates that he was not paid 

wages for an average of 10 regular hours every week. Plaintiff was not paid for a substantial 

number of hours at any rate, not even at the minimum wage rate, as established by federal and 

state law.

60. Plaintiff did not clock in and out, but Defendants could track the number of hours worked by 

Plaintiff and other similarly situated individuals. Defendants knew that Plaintiff was working 

more than 40 hours weekly. 

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61. Therefore, Defendants willfully failed to pay Plaintiff minimum wages in violation of the Fair 

Labor Standards Act, 29 U.S.C. §206, et seq.

62. Plaintiff was paid bi-weekly with checks and paystubs that did not reflect the actual number of 

days and hours worked. 

63. On or about May 26, 2022, Plaintiff was forced to leave his employment because he was 

working too many uncompensated hours. 

64. The records, if any, concerning the number of hours worked by Plaintiff and all other 

employees and the compensation paid to such employees should be in the possession and 

custody of Defendants. However, upon information and belief, Defendants did not maintain 

accurate and complete time records of hours worked by Plaintiff and other similarly situated 

individuals. Defendants violated the record-keeping requirements of FLSA, 29 CFR Part 516.

65. Upon information and belief, Defendants never posted any notice, as required by the Fair Labor 

Standards Act and Federal Law, to inform employees of their Federal rights to overtime and 

minimum wage payments. Defendants violated the Posting requirements of 29 U.S.C. § 516.4. 

66. Prior to the completion of discovery and to the best of Plaintiff's knowledge, at the time of the 

filing of this Complaint, Plaintiff's good faith estimate of unpaid wages is as follows: 

*Please note that this amount is based on a preliminary calculation and that these figures could 

be subject to modification as discovery could dictate. 

Florida's minimum wage is higher than the federal minimum wage. As per FLSA regulations, 

the higher minimum wage applies.

a. Total amount of alleged unpaid wages: 

Six Thousand Eight Hundred Dollars and 00/100 ($6,800.00) 

b. Calculation of such wages: 

Total period of employment: 68 weeks

Total relevant weeks: 68 weeks 

Total number of hours worked: 57.5 weekly average

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Total number of unpaid regular hours: 10 hours weekly 

Regular rate: $25.00 

Florida Minimum wage: $10.00 

Fl minimum wage rate $10.00 x 10 hours=$100.00 weekly x 68 weeks=$6,800.00 

c. Nature of wages: 

This amount represents unpaid minimum wages at the Florida minimum wage rate.

67. The Defendants unlawfully failed to pay minimum wages to Plaintiff. Plaintiff seeks to recover 

for minimum wage violations accumulated during his relevant time of employment. 

68. The Defendants knew and showed reckless disregard of the provisions of the Act concerning 

the payment of minimum wages as required by the Fair Labor Standards Act and remain owing 

Plaintiff these minimum wages. 

69. At times mentioned, individual Defendant MICHAEL D. KELCH was and is now the 

owner/partner and manager of WASH PLUS. Defendants MICHAEL D. KELCH was the 

Employer of Plaintiff and others similarly situated within the meaning of Section 3(d) of the 

"Fair Labor Standards Act" [29 U.S.C. § 203(d)]. This individual Defendant acted directly in

WASH PLUS' interests concerning its employees, including Plaintiff and others similarly 

situated. Defendant MICHAEL D. KELCH had financial and operational control of the 

business, provided Plaintiff with his work schedule, and he is jointly and severally liable for 

Plaintiff's damages.

70. Defendants WASH PLUS and MICHAEL D. KELCH willfully and intentionally refused to 

pay Plaintiff minimum wages as required by the law of the United States and remain owing 

Plaintiff these minimum wages as set forth above. 

71. Plaintiff has retained the law offices of the undersigned attorney to represent him individually 

and on behalf of the asserted class and incurred attorney's fees and costs in bringing this action. 

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Pursuant to 29 U.S.C § 216 (b), Plaintiff is entitled to recover reasonable attorney's fees and 

costs. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff TED MENDEZ respectfully requests that this Honorable Court: 

A. Enter judgment for Plaintiff TED MENDEZ and against the Defendants WASH PLUS and 

MICHAEL D. KELCH based on Defendants' willful violations of the Fair Labor Standards 

Act, 29 U.S.C. § 201 et seq. and other Federal Regulations; and 

B. Award Plaintiff actual damages in the amount shown to be due for unpaid minimum wages, 

with interest; and

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

D. Award Plaintiff reasonable attorney's fees and costs of suit; and 

E. Grant such other and further relief as this Court deems equitable and just and/or available 

pursuant to Federal Law. 

JURY DEMAND

 Plaintiff TED MENDEZ and those similarly situated demand trial by a jury of all issues 

triable as of right by a jury. 

DATED: November 14, 2022 

 Respectfully submitted, 

 By: _/s/ Zandro E. Palma____ 

 ZANDRO E. PALMA, P.A.

 Florida Bar No.: 0024031 

 9100 S. Dadeland Blvd. 

 Suite 1500 

 Miami, FL 33156 

 Telephone: (305) 446-1500 

 Facsimile: (305) 446-1502 

 zep@thepalmalawgroup.com 

 Attorney for Plaintiff 

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