UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

DAWN MELETIA CAMPBELL JOHNSON, 

Plaintiff,

v.

MICHAEL GIORDANO, 

GREG GIORDANO, 

ELISA GIORDANO, 

Defendants.

__________________________________/

COMPLAINT

{Jury Trial Demanded}

Plaintiff, DAWN MELETIA CAMPBELL JOHNSON (“Johnson”), brings this action 

against Defendants, MICHAEL GIORDANO (“M. Giordano”), GREG GIORDANO (“G. 

Giordano”), and ELISA GIORDANO (“E. Giordano”), and alleges as follows:

1. This is an action arising under the Fair Labor Standards Act 29 U.S.C. §§ 201-219 

(“FLSA”). Jurisdiction is conferred on this Court by 28 U.S.C. § 1331 and 29 U.S.C. § 216(b).

2. At all times material hereto, Johnson was a resident of Florida and an “employee” of 

Defendants as defined by the FLSA.

3. M. Giordano is an FLSA employer as defined in 29 U.S.C. § 203(d), was directly involved 

in decisions affecting Johnson’s duties, compensation, and hours worked.

4. G. Giordano is an FLSA employer as defined in 29 U.S.C. § 203(d), was directly involved 

in decisions affecting Johnson’s duties, compensation, and hours worked.

5. E. Giordano is an FLSA employer as defined in 29 U.S.C. § 203(d), was directly involved 

in decisions affecting Johnson’s duties, compensation, and hours worked.

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6. At all times material hereto, Johnson was an employee in the domestic service of a home 

and performing a variety of domestic services as defined by 29 U.S.C. § 202, was engaged in 

commerce, and is individually covered under the FLSA.

7. M. Giordano and G. Giordano, and E. Giordano were joint employers of Johnson under the 

FLSA, shared control of Johnson’s services, had Johnson acting in their mutual interest, and shared 

common control of Johnson.

8. Johnson worked for Defendants as a home health aide.

9. Defendants failed to pay Johnson’s full and proper minimum wages.

10. Defendants failed to pay Johnson’s full and proper overtime wages.

11. Defendants knowingly and willfully refused to pay Johnson’s legally-entitled wages.

12. Attached as Exhibit A is a preliminary calculation of Johnson’s claims. These amounts 

may change as Johnson engages in the discovery process.

13. Johnson retained the services of the undersigned and is obligated to pay for the legal 

services provided.

COUNT I

VIOLATION OF THE FAIR LABOR STANDARDS ACT

AGAINST ALL DEFENDANTS

14. Plaintiff realleges and incorporates the allegations set forth in paragraphs 1-13 above as if

set forth herein in full.

15. Plaintiff alleges this action pursuant to the Fair Labor Standards Act, 29 U.S.C. §§ 216 

(b), that Plaintiff is entitled to: (i) unpaid minimum wages; (ii) time-and-a-half overtime pay, and 

(iii) liquidated damages pursuant to the Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq.

16. Plaintiff seeks recovery of damages as referenced above and further seeks interest, costs, 

and attorneys’ fees pursuant to 29 U.S.C. § 216(b).

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WHEREFORE, Plaintiff demands judgment against Defendants, jointly and severally, plus 

costs, reasonable attorneys’ fees, and such other remedy as the court deems just and appropriate.

Respectfully submitted,

Koz Law, P.A.

800 East Cypress Creek Road Suite 421

Fort Lauderdale, Florida 33334

Tel: (786) 924-9929

Fax: (786) 358-6071

Email: ekoz@kozlawfirm.com

Elliot Kozolchyk, Esq.

Bar No.: 74791

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