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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

KEY WEST DIVISION

CASE NO.:

Gannon Davis,

Dawna Godwin,

and other similarly situated individuals,

Plaintiffs,

v.

Tropic Water Sports LLC,

Florida Jet Ski Rentals, LLC

a/k/a Wolfeboro Jet Ski Rentals,

and Victor N. Drouin, individually,

Defendants,

_____________________________________/ 

COLLECTIVE ACTION COMPLAINT

(OPT-IN PURSUANT TO 29 USC § 216(b))

Comes now the Plaintiffs Gannon Davis, Dawna Godwin, and other similarly situated

individuals, by and through the undersigned counsel, and hereby sue Defendants Tropic Water 

Sports LLC, Florida Jet Ski Rentals, LLC, a/k/a Wolfeboro Jet Ski Rentals, and Victor N. Drouin, 

individually and allege:

Jurisdiction Venues and Parties

1. This is an action to recover money damages for unpaid regular and overtime wages under 

United States laws. Accordingly, this Court has jurisdiction pursuant to the Fair Labor 

Standards Act, 29 USC § 201-219 (Section 216 for jurisdictional placement) ("the Act"). 

2. Plaintiffs Gannon Davis and Dawna Godwin are residents of Monroe County, Florida,

within this Honorable Court jurisdiction and are otherwise sui juris Plaintiffs are covered 

employees for purposes of the Act.

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3. Defendants Tropic Water Sports LLC, Florida Jet Ski Rentals, LLC, a/k/a Wolfeboro Jet 

Ski Rentals, are Florida Limited Liability Companies performing business in Monroe

County, Florida.

4. The individual Defendant Victor N. Godwin is the owner/partner/and manager of 

Defendant Corporations Tropic Water Sports LLC, Florida Jet Ski Rentals, LLC, a/k/a 

Wolfeboro Jet Ski Rentals. This individual Defendant is the Employer of Plaintiffs and 

others similarly situated within the meaning of Section 3(d) of the "Fair Labor Standards 

Act" [29 U.S.C. § 203(d)].

5. Pursuant to 29 U.S.C. § 203 (r)(1) and pursuant to 29 C.F.R. §791.2, Defendants Tropic 

Water Sports LLC, Florida Jet Ski Rentals, LLC, a/k/a Wolfeboro Jet Ski Rentals, are a 

joint enterprise, and joint employers of Plaintiff. 

6. All the actions raised in this complaint occurred in Monroe County, Florida, within this 

Court's jurisdiction.

General Allegations

7. This cause of action is brought by Plaintiffs Gannon Davis and Dawna Godwin as a 

collective action to recover from the Defendants' regular and overtime wages, liquidated 

damages, costs, and reasonable attorney's fees under the provisions of the Fair Labor 

Standards Act, as amended, 29 USC § 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") and who worked more than forty (40) hours during one or more weeks on 

or after August 2021, (the "material time") without being adequately compensated. 

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8. Defendant Florida Jet Ski Rentals is a jet ski rental company doing business at 139 Seaside 

Avenue, Key Largo, Fl 33037, and 2146 Overseas Hwy, Marathon, FL, 33050, where both 

Plaintiffs worked.

9. Pursuant to 29 U.S.C. § 203 (r)(1), Defendants Tropic Water Sports LLC, Florida Jet Ski 

Rentals, LLC, a/k/a Wolfeboro Jet Ski Rentals are a joint enterprise because: 1) both 

companies have the same business activities; 2) both companies shared centralized 

management, equipment, and supplies; 3) Defendant operated as a single unit for a 

common business purpose; 4) between Defendants existed unified operation and common 

control, and they operated as a single unit; 5) Defendants shared a common business 

purpose, the profitable operation of both businesses; 6) Defendants had an interdependent 

financial interest; 7) and existed common ownership and management.

10. Pursuant 29 C.F.R. §791.2. Defendants Tropic Water Sports LLC, Florida Jet Ski Rentals, 

LLC, a/k/a Wolfeboro Jet Ski Rentals were joint employers because: 1) Defendants,

through their owner/manager, had equal and absolute control over the Plaintiff and other 

employees similarly situated; 2) Defendants through their management jointly and equally 

determined terms and employment conditions of Plaintiffs and other employees similarly 

situated; 3) Defendants operated the two facilities where Plaintiffs and the other similarly 

situated employees worked; 4) the work performed by Plaintiff and other similarly situated 

individuals was an integral part of the business operation of Tropic Water Sports LLC, 

Florida Jet Ski Rentals, LLC, a/k/a Wolfeboro Jet Ski Rentals; 5) both corporations had the 

power to hire and to fire employees. 

11. Therefore, because the work performed by Plaintiffs and other similarly-situated 

individuals simultaneously benefited all Defendants and directly or indirectly furthered 

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their joint interest, Defendants Tropic Water Sports LLC, Florida Jet Ski Rentals, LLC, 

a/k/a Wolfeboro Jet Ski Rentals are a joint enterprise as defined in 29 U.S.C. § 203 (r)(1), 

and they are also joint employers as defined in 29 C.F.R. §791.2. 

12. Defendants Tropic Water Sports LLC, Florida Jet Ski Rentals, LLC, a/k/a Wolfeboro Jet 

Ski Rentals, are the joint employers of Plaintiffs and other similarly situated employees 

under the FLSA's broad definition of "employer" (29 U.S.C. §203 (d)), and they are jointly 

liable for Plaintiff's damages. 

13. Defendants Tropic Water Sports LLC, Florida Jet Ski Rentals, LLC, a/k/a Wolfeboro Jet 

Ski Rentals, hereinafter will be called Florida Jet Ski Rentals collectively.

14. Defendants Florida Jet Ski Rentals and Victor N. Godwin employed Plaintiffs Gannon 

Davis and Dawna Godwin as non-exempted, full-time jet ski rental store attendants.

15. Defendants employed Plaintiff Gannon Davis from approximately August 23, 2021, to 

October 02, 2022, or 58 weeks. Plaintiff had a wage rate of $15.00 an hour. Plaintiff's 

overtime should be $22.50 an hour. At his hiring, Plaintiff was promised a basic hourly 

wage of $15.00 an hour plus 20% commissions of sales, but Defendants never fulfilled the 

agreement.

16. Defendants employed Plaintiff Dawna Godwin from approximately December 07, 2021, 

to October 02, 2022, or 43 weeks. Plaintiff had a wage rate of $16.00 an hour. Plaintiff's 

overtime should be $24.00 an hour. 

17. During their employment with Defendants, Plaintiffs Gannon Davis and Dawna Godwin 

had a regular schedule. Plaintiffs worked seven days per week, from Monday to Sunday, 

from 9:00 AM to 7:00 PM (10 hours daily), or a total of 70 hours weekly. Plaintiffs did not 

take bonafide lunchtime.

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18. While employed by Defendants, Plaintiffs were paid in a very irregular way. Plaintiffs 

always worked a minimum of 70 hours weekly, but they were paid 60 hours or less per 

week. Hours over 40 were paid at their regular rate. The remaining hours were not paid at 

any rate, not even at the minimum wage rate.

19. Furthermore, there were many weeks in which Plaintiffs' wages divided by the number of 

hours worked resulted in a wage rate lower than the minimum wage rate required by law.

20. Plaintiffs were paid a different amount every week at the convenience of the Employer. 

Plaintiffs complained to the owner of the business Victor N. Drouin many times, but the 

problem was never solved.

21. Plaintiffs did not clock in and out, but Defendants were in complete control of Plaintiffs'

activities, and they knew about the number of hours that Plaintiffs were working.

22. Therefore, Defendants willfully failed to pay Plaintiffs regular hours and overtime hours 

at the rate of time and one-half their regular rate for every hour they 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). and 29 U.S.C. § 201 et seq. 

23. Plaintiffs were paid weekly with checks without paystubs providing basic information 

about the number of days and hours worked, wage rate paid, employee taxes deducted, etc.

24. On or about October 02, 2022, the Plaintiffs left their employment because, at that time,

Defendants did not pay them wages for four consecutive weeks.

25. The plaintiffs are not in possession of time and payment records, but they will provide a 

preliminary estimate of their unpaid working hours. The Plaintiffs' calculations will be 

based on an average of 60 hours paid weekly.

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26. Plaintiffs Gannon Davis and Dawna Godwin seek to recover regular wages, overtime 

wages, liquidated damages, and any other relief as allowable by law.

Collective Action Allegations

27. Plaintiffs bring this action pursuant to the Fair Labor Standards Act, 29 USC §§201, et seq.

("the Act"). Section 216 (b) for jurisdictional placement).

28. Plaintiffs contend that Defendants, in this case, violated the Fair Labor Standards Act by 

failing to pay Plaintiffs and other similarly situated individuals the proper compensation 

for every regular and overtime hour as required by the FLSA.

29. This action is intended to include every Jet-Ski rental store attendant and any similarly 

situated individuals who worked for Defendants at any time during the past three (3) years. 

COUNT I:

WAGE AND HOUR FEDERAL STATUTORY VIOLATION;

FAILURE TO PAY OVERTIME; AGAINST ALL DEFENDANTS

30. Plaintiffs Gannon Davis and Dawna Godwin re-adopt every factual allegation as stated in 

paragraphs 1-29 above as if set out in full herein. 

31. This action is brought by Plaintiffs Gannon Davis and Dawna Godwin and those similarly 

situated to recover from the Employers unpaid 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. 29 U.S.C. § 207 (a)(1) states, "No employer shall employ any of his employees... 

for a work week 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."

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32. Defendants Florida Jet Ski Rentals and Victor N. Godwin employed Plaintiffs Gannon 

Davis and Dawna Godwin as non-exempted, full-time jet ski rental store attendants.

33. Defendants employed Plaintiff Gannon Davis from approximately August 23, 2021, to 

October 02, 2022, or 58 weeks. Plaintiff had a wage rate of $15.00 an hour. Plaintiff's 

overtime should be $22.50 an hour. 

34. Defendants employed Plaintiff Dawna Godwin from approximately December 07, 2021, 

to October 02, 2022, or 43 weeks. Plaintiff had a wage rate of $16.00 an hour. Plaintiff's 

overtime should be $24.00 an hour. 

35. During their employment with Defendants, Plaintiffs Gannon Davis and Dawna Godwin 

had a regular schedule. Plaintiffs worked seven days per week, from Monday to Sunday, a 

total of 70 hours weekly. The Plaintiffs did not take bonafide lunchtime.

36. While employed by Defendants, Plaintiffs always worked a minimum of 70 hours weekly, 

but they were paid for 60 hours per week or less at their regular rate. The remaining hours 

were not paid to Plaintiffs at any rate, not even at the minimum wage rate.

37. Plaintiffs were paid a different amount every week at the convenience of the Employer. 

38. Plaintiffs worked more than 40 hours weekly, but they were not paid for overtime hours as 

required by law.

39. Plaintiffs did not clock in and out, but Defendants were in complete control of Plaintiffs'

activities, and they knew about the number of hours that Plaintiffs were working.

40. Therefore, Defendants willfully failed to pay Plaintiffs overtime hours at the rate of time 

and one-half their regular rate for every hour they 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).

and 29 U.S.C. § 201 et seq. 

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41. Plaintiffs were paid weekly with checks without paystubs providing basic information 

about the number of days and hours worked, wage rate paid, employee taxes deducted, etc.

42. On or about October 02, 2022, the Plaintiffs were forced to resign from their employment 

because Defendants did not pay them for four consecutive weeks.

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

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

custody of Defendants. However, Defendants did not maintain accurate and complete time 

records of hours worked by Plaintiffs and other employees in the asserted class, upon 

information and belief. Accordingly, Defendants violated the record-keeping requirements 

of FLSA, 29 CFR Part 516.

44. 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.

45. Plaintiffs are not in possession of time and payment records. Still, before the completion 

of Discovery, they will provide a good faith estimate of unpaid overtime wages based on 

their best knowledge. Plaintiffs will adjust their statement of claim according to Discovery. 

46. A.- Overtime Claim of Plaintiff Gannon Davis

a. Total amount of alleged unpaid O/T wages:

Twenty-One Thousand Seven Hundred Fifty Dollars and 00/100 ($21,750.00)

b. Calculation of such wages: 

Total weeks of employment: 58 weeks

Total relevant number of weeks: 58 weeks

Total number of hours worked: 70 hours

Total number of unpaid O/T hours: 30 O/T hours

Total number of O/T hours paid at regular rate: 20 O/T hours

Total number of O/T hours paid at $0.00: 10 O/T hours

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 Rate Paid: $15.00 x 1.5= $22.50=O/T rate

 O/T rate: $22.50 - $15.00 paid=$7.50 

 Half-Time O/T: $7.50

i. Half-time Overtime for 20 hours paid at regular rate, $15.00

$7.50 x 20 O/T hours=$150.00 weekly x 58 weeks=$8,700.00

ii. Overtime for 10 hours paid at $0.00

 

 $22.50 x 10 O/T hours= $225.00 weekly x 58 weeks= $13,050.00

 Total # i and # ii: $21,750.00

47. B.- Overtime claim of Plaintiff Dawna Godwin

a. Total amount of alleged unpaid O/T wages:

Seventy Thousand Two Hundred Dollars and 00/100 ($17,200.00)

b. Calculation of such wages: 

Total weeks of employment: 43 weeks

Total relevant number of weeks: 43 weeks

Total number of hours worked: 70 hours

Total number of unpaid O/T hours: 30 O/T hours

Total number of O/T hours paid at regular rate: 20 O/T hours

Total number of O/T hours paid at $0.00: 10 O/T hours

 Rate Paid: $16.00 x 1.5= $24.00=O/T rate

 O/T rate: $24.00 - $16.00 paid=$8.00

 Half-Time O/T: $8.00

i. Half-time Overtime for 20 hours paid at regular rate, $16.00

$8.00 x 20 O/T hours=$160.00 weekly x 43 weeks=$6,880.00

ii. Overtime for 10 hours paid at $0.00

 

 $24.00 x 10 O/T hours= $240.00 weekly x 43 weeks= $10,320.00

 Total # i and # ii: $17,200.00 

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

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This amount represents unpaid overtime wages.1

48. At all times material hereto, the Employers/Defendants 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 Plaintiffs and those 

similarly situated performed services and worked more than the maximum hours provided 

by the Act. Still, the Defendants made no provisions to properly pay them 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. 

49. Defendants Florida Jet Ski Rentals and Victor N. Godwin knew and showed a reckless 

disregard for the Act's provisions concerning the payment of overtime wages as required 

by the Fair Labor Standards Act, and Plaintiffs and those similarly situated are entitled to 

recover double damages. 

50. At times mentioned, individual Defendant Victor N. Drouinwas, and is now, the 

owner/director and manager of Defendant Corporation Florida Jet Ski Rentals. Individual 

Defendant Victor N. Drouin had absolute operational control of Florida Jet Ski Rentals. 

Individual Defendant Victor N. Drouin was the Employer of Plaintiffs and others similarly 

situated within the meaning of Section 3(d) of the "Fair Labor Standards Act" [29 U.S.C. 

§ 203(d)]. In that, this individual Defendant acted directly in the interest of Florida Jet Ski 

Rentals concerning its employees, including Plaintiffs and others similarly situated, and he 

is jointly and severally liable for Plaintiffs' damages. 

51. Defendants Florida Jet Ski Rentals and Victor N. Godwin willfully and intentionally 

refused to pay Plaintiffs Gannon Davis and Dawna Godwin overtime wages as required by 

1 At this time, Plaintiffs have limited time and payment records. Accordingly, Plaintiffs estimate their

damages and reserve the right to amend the calculations.

- 

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the law of the United States and remain owing Plaintiffs these overtime wages since the 

commencement of Plaintiffs' employment with Defendants as set forth above. 

52. Plaintiffs seek to recover unpaid overtime wages accumulated from their date of hiring to 

their last day of employment.

53. Plaintiffs have retained the law offices of the undersigned attorney to represent them in this 

action and are obligated to pay reasonable attorneys' fees.

Prayer For Relief

Wherefore, Plaintiffs Gannon Davis, Dawna Godwin, and those similarly situated respectfully 

request that this Honorable Court: 

A. Enter judgment for Plaintiffs Gannon Davis and Dawna Godwin, and other similarly 

situated and against the Defendants Florida Jet Ski Rentals and Victor N. Godwin, 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 Plaintiffs' actual damages in the amount shown to be due for unpaid wages and

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

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

D. Award Plaintiffs 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

Plaintiffs Gannon Davis, Dawna Godwin, and those similarly situated demand trial by a jury of all 

issues triable as a right by jury.

COUNT II:

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FLSA WAGE AND HOUR FEDERAL STATUTORY VIOLATION: FAILURE TO 

PAY MINIMUM WAGE; AGAINST ALL DEFENDANTS

54. Plaintiffs Gannon Davis and Dawna Godwin re-adopt every factual allegation stated in 

paragraphs 1-29 of this complaint as if set out in full herein.

55. Plaintiffs bring this action to recover from the Employer Florida Jet Ski Rentals unpaid

minimum wages, as well as an additional amount as liquidated damages, costs, and 

reasonable attorney's fees under the provisions of 29 USC § 201 et seq., and specifically 

under the provisions of 29 USC §206. 

56. Defendant Florida Jet Ski Rentals was and is subjected to the minimum wage provisions 

of the Fair Labor Standards Act (FLSA).

57. USC §206 states, "Every Employer shall pay to each of his employees who in any 

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

employed in an enterprise engaged in commerce or

58. 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

59. Defendants Florida Jet Ski Rentals and Victor N. Godwin employed Plaintiffs Gannon 

Davis and Dawna Godwin as non-exempted, full-time jet ski rental store attendants.

60. Defendants employed Plaintiff Gannon Davis from approximately August 23, 2021, to 

October 02, 2022, or 58 weeks. Plaintiff had a wage rate of $15.00 an hour. 

61. Defendants employed Plaintiff Dawna Godwin from approximately December 07, 2021, 

to October 02, 2022, or 43 weeks. Plaintiff had a wage rate of $16.00 an hour. 

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62. During their employment with Defendants, Plaintiffs Gannon Davis and Dawna Godwin 

had a regular schedule. Plaintiffs worked seven days per week, from Monday to Sunday, a 

total of 70 hours weekly. The Plaintiffs did not take bonafide lunchtime.

63. While employed by Defendants, Plaintiffs always worked a minimum of 70 hours weekly, 

but they were paid for 60 hours per week or less at their regular rate. The remaining hours 

were not paid at any rate, not even at the minimum wage rate.

64. Plaintiffs were paid a different amount every week at the convenience of the Employer. 

65. Furthermore, there were many weeks in which Plaintiffs' wages divided by the number of 

hours worked resulted in a wage rate lower than the minimum wage rate required by law.

66. On or about October 02, 2022, Plaintiffs Gannon Davis and Dawna Godwin were forced 

to resign from their position because Defendants did not pay them wages for four 

consecutive weeks.

67. There is a substantial number of hours that were not paid to Plaintiffs at any rate, not even 

at the minimum wage rate, as required by the FLSA.

68. Plaintiffs did not clock in and out, but Defendants were in complete control of Plaintiffs'

activities, and they knew about the number of hours that Plaintiffs were working.

69. Therefore, Defendant willfully failed to pay Plaintiff regular hours in violation of Section 

206 (a) of the Fair Labor Standards Act of 1938 (29 USC 206(a)(1).

70. Plaintiffs were paid weekly with checks without paystubs providing basic information 

about the number of days and hours worked, wage rate paid, employee taxes deducted, etc.

71. The records, if any, concerning the number of hours worked by Plaintiff and those 

similarly situated, and the compensation paid to such employees should be in the 

possession and custody of Defendants. However, upon information and belief, Defendants

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did not maintain accurate time records of hours worked by Plaintiff and other employees. 

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

72. 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. Accordingly, Defendants violated the Posting 

requirements of 29 USC § 516.4.

73. Before the completion of Discovery, and to the best of the Plaintiffs' knowledge, at the time 

of the filing of this complaint, Plaintiff's reasonable good faith estimate of unpaid wages is

as follows:

* Florida's minimum wage for 2022 is $10.00, which is higher than the Federal minimum 

wage. As per FLSA regulations, the higher minimum wage applies.

A.- Minimum Wages Claim of Plaintiff Gannon Davis

a. Total amount of alleged unpaid wages:

One Thousand Six Hundred and 00/100 ($1,600.00)

b. Calculation of such wages: 

Total weeks of employment: 58 weeks

Total relevant week: 4 weeks

Total hours worked: 40 hours weekly

Total number of unpaid hours: 40 hours weekly

Regular rate: $15.00

FL Minimum wage rate 2022: $10.00

FL min. wage $10.00 x 40 unpaid regular hours=$400.00 weekly

 $400.00 weekly x 4 weeks=$1,600.00

c. Nature of wages:

This amount represents unpaid min. Wages at Florida minimum wage rate.

B.- Minimum Wages Claim of Plaintiff Dawna Godwin

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a. Total amount of alleged unpaid wages:

One Thousand Six Hundred Dollars and 00/100 ($1,600.00)

b. Calculation of such wages: 

Total weeks of employment: 43 weeks

Total relevant week: 4 weeks

Total hours worked: 40 hours weekly

Total number of unpaid hours: 40 hours weekly

Regular rate: $16.00

FL Minimum wage rate 2022: $10.00

FL min. wage $10.00 x 40 unpaid regular hours=$400.00 weekly

 $400.00 weekly x 4 weeks=$1,600.00

c. Nature of wages:

This amount represents the unpaid min. Wages at the Florida minimum wage rate.2

74. Defendants Florida Jet Ski Rentals and Victor N. Godwin unlawfully failed to pay 

Plaintiffs Gannon Davis and Dawna Godwin minimum wages. 

75. 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 Plaintiffs and those similarly situated these minimum wages since the 

commencement of Plaintiffs and those similarly situated employee's employment with 

Defendants as set forth above. Plaintiffs and those similarly situated are entitled to recover 

double damages. 

76. At times mentioned, individual Defendant Victor N. Drouinwas, and is now, the 

owner/director and manager of Defendant Corporation Florida Jet Ski Rentals. Individual 

Defendant Victor N. Drouin had absolute operational control of Florida Jet Ski Rentals. 

2 At this time, Plaintiffs have limited time and payment records. Accordingly, Plaintiffs estimate their 

damages and reserve the right to amend the calculations. In this Statement of Claim are not included 

minimum wages for weeks in which Plaintiffs were paid at rates below the min. wage required by law.

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Individual Defendant Victor N. Drouin was the Employer of Plaintiffs and others similarly 

situated within the meaning of Section 3(d) of the "Fair Labor Standards Act" [29 U.S.C. 

§ 203(d)]. In that, this individual Defendant acted directly in the interest of Florida Jet Ski 

Rentals concerning its employees, including Plaintiffs and others similarly situated, and he 

is jointly and severally liable for Plaintiffs' damages. 

77. Defendants Florida Jet Ski Rentals and Victor N. Godwin willfully and intentionally 

refused to pay Plaintiffs minimum wages as required by the Fair Labor Standards Act and 

remain owing Plaintiff these minimum wages.

78. The Plaintiffs have retained the law offices of the undersigned attorney to represent them 

in this action and are obligated to pay reasonable attorney's fees. 

Prayer for Relief

Wherefore, Plaintiffs Gannon Davis and Dawna Godwin and those similarly situated respectfully 

request that this Honorable Court: 

A. Enter judgment for Plaintiffs Gannon Davis and Dawna Godwin and against the 

Defendants Florida Jet Ski Rentals and Victor N. Godwin based on Defendants' willful 

violations of the Fair Labor Standards Act, 29 USC § 201 et seq. and other Federal 

Regulations; and

B. Award Plaintiffs Gannon Davis and Dawna Godwin actual damages in the amount 

shown to be due for unpaid minimum wages, with interest; and

C. Award Plaintiffs Gannon Davis and Dawna Godwin an equal amount in double 

damages/liquidated damages; and

D. Award Plaintiffs Gannon Davis and Dawna Godwin reasonable attorney's fees and costs 

of suit; and 

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

available pursuant to Federal Law. 

Demand for a Jury Trial

Plaintiffs Gannon Davis, Dawna Godwin, and those similarly situated demand trial by a 

jury of all issues triable as of right by a jury.

Dated: November 15, 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 Plaintiffs

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