UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

ANTHONY SANTIAGO, 

Plaintiff,

v.

PEACOCK’S 17, LLC, 

LEE J. GARIPOLI, 

Defendants.

__________________________________/

COMPLAINT

{Jury Trial Demanded}

Plaintiff, ANTHONY SANTIAGO (“Santiago”), brings this action against Defendants, 

PEACOCK’S 17, LLC (“Peacock”) and LEE J. GARIPOLI (“Garipoli”), 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, Santiago was a resident of Florida and an “employee” of 

Defendants as defined by the FLSA.

3. At all times material hereto, Peacock was a Florida corporation that regularly transacted 

business in Broward County, Florida.

4. Garipoli is an FLSA employer as defined in 29 U.S.C. § 203(d), is an owner and/or manager 

of Peacock, ran the day-to-day operations and had operational control over Peacock, and was 

directly involved in decisions affecting duties, employee compensation, and hours worked by 

employees, such as Santiago.

5. Peacock’s business involves hair salon operations.

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6. Defendants have employees handling, selling, or otherwise working on goods or materials 

that have been moved in or produced for commerce including but not limited to computers, phones, 

pens, and paper.

7. Upon information and belief, Peacock’s 17, LLC’s gross sales or business done was in 

excess of $500,000 per year at all times material hereto.

8. Peacock was an enterprise engaged in commerce or the production of goods for commerce 

and is covered by the FLSA at all times material hereto. 

9. At all times material hereto, Santiago engaged in interstate communication on a regular 

and recurrent basis including but not limited to phone and text messaging with customers in located 

outside Florida an average of once per week.

10. Santiago engaged in interstate commerce on a regular and recurring basis and is 

individually covered by the FLSA. 

11. Santiago operates two other hair salons, MANKIND, INC. and MANKIND CG LLC, and 

shares employees and supplies between Peacock, MANKIND, INC., and MANKIND CG LLC.

12. Peacock, MANKIND, INC., and MANKIND CG LLC are a single enterprise under the 

FLSA, performed related activites through unified operation and common control for a common 

business purpose, engaged along with their employees in interstate commerce, and upon 

information and belief have combined annual gross sales and/or business volume of $500,000 or 

more.

13. Santiago worked for Defendants as a barber.

14. Defendants failed to pay Santiago’s full and proper minimum wages.

15. Defendants failed to pay Santiago’s full and proper overtime wages.

16. Defendants regularly paid Santiago late.

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17. Defendants knowingly and willfully refused to pay Santiago’s legally-entitled wages.

18. Attached as Exhibit A is a preliminary calculation of Santiago’s claims. These amounts 

may change as Santiago engages in the discovery process.

19. Santiago retained the undersigned and is obligated to pay for the legal services provided.

COUNT I

VIOLATION OF THE FAIR LABOR STANDARDS ACT

AGAINST ALL DEFENDANTS

20. Plaintiff realleges and incorporates the allegations set forth in paragraphs 1-19 above as if

set forth herein in full.

21. 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 including but not limited to liquidated damages for wages paid late pursuant 

to the Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq.

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

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

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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