IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

Gerardo Mejias Cardosa, 

Plaintiff, Case No. ___________________ 

v. 

PLAINTIFF DEMANDS 

TRIAL BY JURY

Bureau Intelligence Investigator FL Inc and 

John L Rodriguez 

Defendants.

COMPLAINT

Plaintiff, Gerardo Mejias Cardosa (“Plaintiff”), by and through their attorney, Daniel I. 

Schlade, complain against Bureau Intelligence Investigator FL Inc (“Defendant” or “BIIFI”) 

and John L Rodriguez (“Defendant” or “Rodriguez”). BIIFI and Rodriguez may collectively be 

referred to as “Defendants”. In support of this Complaint, Plaintiff states:

Introduction

1. This action seeks redress for Defendants’ willful violations of the Fair Labor Standards

Act, 29 U.S.C. § 201 et seq. (“FLSA”), as well as any related state law claims, for Defendants’

failure to pay overtime wages owed. 

Parties

2. Plaintiff is a resident of Homestead, Florida; and he was employed by BIIFI and Rodriguez.

3. BIIFI is a business that is located, headquartered, and conducts business in Homestead,

Florida. 

4. Rodriguez is the owner and President of BIIFI, and they are in charge of its employees.

On information and belief, Rodriguez is a resident of Homestead, Florida. 

1:22-cv-23158

Case 1:22-cv-23158-XXXX Document 1 Entered on FLSD Docket 09/28/2022 Page 1 of 7
5. Defendants are “an enterprise engaged in commerce or in the production of goods for

commerce” under 29 USC § 203(s)(1)(A)(i) and (ii) because they have annual gross volume of 

sales made or business done of at least $500,000; and because they are engaged in interstate 

commerce or in the production of goods for interstate commerce. Additionally, they have more 

than three employees.

Jurisdiction And Venue

6. The Court possesses subject matter jurisdiction over the FLSA claim(s) pursuant to 29

U.S.C. § 216(b) and 28 U.S.C. § 1331 (federal question), and 28 U.S.C. §1337; and supplemental 

jurisdiction over any related state law claim(s) pursuant to 28 U.S.C. § 1367. 

7. Venue is proper in the SOUTHERN District of Florida because all underlying facts and

transactions occurred in or about Homestead, Florida. 

Facts Common To All Claims

8. BIIFI is an “employer” as that term is defined in Section 203 of the FLSA, because it is a

privately owned for-profit entity.

9. Rodriguez is an “employer” as that term is defined in Section 203 of the FLSA, because:

(1) they were Plaintiff’s head “boss” at BIIFI; (2) they had the power to hire and fire the employees,

including Plaintiff; (3) they supervised and controlled Plaintiff’s work schedules and conditions of 

employment; (4) they determined the rate and method of payment for employees; and (5) they 

maintained employment records.

COUNT I: VIOLATION OF THE FLSA

10. Plaintiff reincorporates by reference Paragraphs 1 through 9, as if set forth in full herein

for Paragraph 10. 

Case 1:22-cv-23158-XXXX Document 1 Entered on FLSD Docket 09/28/2022 Page 2 of 7
11. Plaintiff began working at BIIFI in or before March 20, 2020 until on or about July 16, 

2022.

12. At all times, Plaintiff held the same position at BIIFI, they were a security guard. Plaintiff 

was an “employee” of Defendants as that term is used in Section 203 of the FLSA because he was 

employed by Defendants to perform security services, and they do not fall into any of the 

exceptions or exemptions for workers under the FLSA.

13. Although schedules are subject to change, Plaintiff’s general schedule with Defendants 

required Plaintiff to work on average 54 hours per week.

14. Plaintiff was paid their wages on a(n) weekly basis.

15. Plaintiff’s wages were not based on the number of jobs performed or completed, nor was 

it based on the quality or efficiency of their performance.

16. Plaintiff’s rate of pay was $13 per hour.

17. Throughout the course of Plaintiff’s employment with Defendants, Defendants regularly 

scheduled and directed Plaintiff to work in excess of forty (40) hours per week.

18. Defendants did not pay Plaintiff not less than one and a half (1.5) times the regular rate at 

which he was employed during the hours worked in excess of forty (40) hours per week.

19. On information and belief, Defendants have failed to keep proper time records tracking 

Plaintiffs’ time worked; and Defendants’ failure and refusal to pay Plaintiff overtime wages for 

hours worked in excess of forty (40) hours per week was a willful violation of the FLSA.

20. Plaintiff is entitled to recover unpaid overtime wages and liquidated damages for up to 

three (3) years prior to the filing of this lawsuit. On information and belief, this amount includes: 

(i) $11,376.00 in unpaid overtime wages; (ii) liquidated damages of $11,376.00; and (iii) Plaintiff’s 

attorney’s fees and costs, to be determined. A calculation of Plaintiff’s damages are attached as 

Exhibit A.

Case 1:22-cv-23158-XXXX Document 1 Entered on FLSD Docket 09/28/2022 Page 3 of 7
WHEREFORE, Plaintiff Gerardo Mejias Cardosa respectfully requests that the Court enter 

a judgment in their favor and against Defendants BIIFI and Rodriguez jointly and severally, for:

A. The amount of unpaid overtime wages for all time worked by Plaintiff in excess of forty

(40) hours in individual work weeks, totaling at least $11,376.00;

B. An award liquidated damages in an amount equal to at least $11,376.00;

C. A declaration that Defendants violated the FLSA;

D. An award reasonable attorneys’ fees and costs; and

E. Any such additional or alternative relief as this Court deems just and proper.

Gerardo Mejias Cardosa 

s/Daniel I. Schlade

Lead Attorney For Plaintiff 

Daniel I. Schlade (FL Bar No. 1034991) 

Attorney For Plaintiff

Justicia Laboral, LLC

6232 N. Pulaski, #300 

Chicago, IL 60646 

773-550-3775

Email: dschlade@justicialaboral.com

danschlade@gmail.com

PLAINTIFF DEMANDS TRIAL BY JURY

Case 1:22-cv-23158-XXXX Document 1 Entered on FLSD Docket 09/28/2022 Page 4 of 7
EXHIBIT A

Case 1:22-cv-23158-XXXX Document 1 Entered on FLSD Docket 09/28/2022 Page 5 of 7
Week Av. Hours/Wk. Hours Over 40 Hrly. Wage Unpaid OT FLSA Liquidated

3/1/2020 52 12 $12.00 $72.00 $72.00

3/8/2020 52 12 $12.00 $72.00 $72.00

3/15/2020 52 12 $12.00 $72.00 $72.00

3/22/2020 52 12 $12.00 $72.00 $72.00

3/29/2020 52 12 $12.00 $72.00 $72.00

4/5/2020 52 12 $12.00 $72.00 $72.00

4/12/2020 52 12 $12.00 $72.00 $72.00

4/19/2020 52 12 $12.00 $72.00 $72.00

4/26/2020 52 12 $12.00 $72.00 $72.00

5/3/2020 52 12 $12.00 $72.00 $72.00

5/10/2020 52 12 $12.00 $72.00 $72.00

5/17/2020 52 12 $12.00 $72.00 $72.00

5/24/2020 52 12 $12.00 $72.00 $72.00

5/31/2020 52 12 $12.00 $72.00 $72.00

6/7/2020 52 12 $12.00 $72.00 $72.00

6/14/2020 52 12 $12.00 $72.00 $72.00

6/21/2020 52 12 $12.00 $72.00 $72.00

6/28/2020 52 12 $12.00 $72.00 $72.00

7/5/2020 52 12 $12.00 $72.00 $72.00

7/12/2020 52 12 $12.00 $72.00 $72.00

7/19/2020 52 12 $12.00 $72.00 $72.00

7/26/2020 52 12 $12.00 $72.00 $72.00

8/2/2020 52 12 $12.00 $72.00 $72.00

8/9/2020 52 12 $12.00 $72.00 $72.00

8/16/2020 52 12 $12.00 $72.00 $72.00

8/23/2020 52 12 $12.00 $72.00 $72.00

8/30/2020 52 12 $12.00 $72.00 $72.00

9/6/2020 52 12 $12.00 $72.00 $72.00

9/13/2020 52 12 $12.00 $72.00 $72.00

9/20/2020 52 12 $12.00 $72.00 $72.00

9/27/2020 52 12 $12.00 $72.00 $72.00

10/4/2020 52 12 $12.00 $72.00 $72.00

10/11/2020 52 12 $12.00 $72.00 $72.00

10/18/2020 52 12 $12.00 $72.00 $72.00

10/25/2020 52 12 $12.00 $72.00 $72.00

11/1/2020 52 12 $12.00 $72.00 $72.00

11/8/2020 52 12 $12.00 $72.00 $72.00

11/15/2020 52 12 $12.00 $72.00 $72.00

11/22/2020 52 12 $12.00 $72.00 $72.00

11/29/2020 52 12 $12.00 $72.00 $72.00

12/6/2020 52 12 $12.00 $72.00 $72.00

12/13/2020 52 12 $12.00 $72.00 $72.00

12/20/2020 52 12 $12.00 $72.00 $72.00

12/27/2020 52 12 $12.00 $72.00 $72.00

1/3/2021 52 12 $12.00 $72.00 $72.00

1/10/2021 52 12 $12.00 $72.00 $72.00

1/17/2021 52 12 $12.00 $72.00 $72.00

1/24/2021 52 12 $12.00 $72.00 $72.00

1/31/2021 52 12 $12.00 $72.00 $72.00

2/7/2021 52 12 $12.00 $72.00 $72.00

2/14/2021 52 12 $12.00 $72.00 $72.00

2/21/2021 52 12 $12.00 $72.00 $72.00

2/28/2021 52 12 $12.00 $72.00 $72.00

3/7/2021 52 12 $12.00 $72.00 $72.00

3/14/2021 52 12 $12.00 $72.00 $72.00

3/21/2021 52 12 $12.00 $72.00 $72.00

3/28/2021 52 12 $12.00 $72.00 $72.00

4/4/2021 52 12 $12.00 $72.00 $72.00

4/11/2021 52 12 $12.00 $72.00 $72.00

4/18/2021 52 12 $12.00 $72.00 $72.00

4/25/2021 52 12 $12.00 $72.00 $72.00

5/2/2021 52 12 $12.00 $72.00 $72.00

5/9/2021 52 12 $12.00 $72.00 $72.00

5/16/2021 52 12 $12.00 $72.00 $72.00

5/23/2021 52 12 $12.00 $72.00 $72.00

5/30/2021 52 12 $12.00 $72.00 $72.00

6/6/2021 52 12 $12.00 $72.00 $72.00

6/13/2021 52 12 $12.00 $72.00 $72.00

6/20/2021 52 12 $12.00 $72.00 $72.00

Case 1:22-cv-23158-XXXX Document 1 Entered on FLSD Docket 09/28/2022 Page 6 of 7
6/27/2021 52 12 $12.00 $72.00 $72.00

7/4/2021 52 12 $12.00 $72.00 $72.00

7/11/2021 52 12 $12.00 $72.00 $72.00

7/18/2021 52 12 $12.00 $72.00 $72.00

7/25/2021 52 12 $12.00 $72.00 $72.00

8/1/2021 52 12 $12.00 $72.00 $72.00

8/8/2021 52 12 $12.00 $72.00 $72.00

8/15/2021 52 12 $12.00 $72.00 $72.00

8/22/2021 52 12 $12.00 $72.00 $72.00

8/29/2021 52 12 $12.00 $72.00 $72.00

9/5/2021 52 12 $12.00 $72.00 $72.00

9/12/2021 52 12 $12.00 $72.00 $72.00

9/19/2021 52 12 $12.00 $72.00 $72.00

9/26/2021 52 12 $12.00 $72.00 $72.00

10/3/2021 52 12 $12.00 $72.00 $72.00

10/10/2021 52 12 $12.00 $72.00 $72.00

10/17/2021 52 12 $12.00 $72.00 $72.00

10/24/2021 52 12 $12.00 $72.00 $72.00

10/31/2021 52 12 $12.00 $72.00 $72.00

11/7/2021 52 12 $12.00 $72.00 $72.00

11/14/2021 52 12 $12.00 $72.00 $72.00

11/21/2021 64 24 $12.00 $144.00 $144.00

11/28/2021 64 24 $12.00 $144.00 $144.00

12/5/2021 64 24 $12.00 $144.00 $144.00

12/12/2021 64 24 $12.00 $144.00 $144.00

12/19/2021 64 24 $12.00 $144.00 $144.00

12/26/2021 64 24 $12.00 $144.00 $144.00

1/2/2022 64 24 $12.00 $144.00 $144.00

1/9/2022 64 24 $12.00 $144.00 $144.00

1/16/2022 64 24 $12.00 $144.00 $144.00

1/23/2022 64 24 $12.00 $144.00 $144.00

1/30/2022 64 24 $12.00 $144.00 $144.00

2/6/2022 64 24 $12.00 $144.00 $144.00

2/13/2022 64 24 $12.00 $144.00 $144.00

2/20/2022 64 24 $12.00 $144.00 $144.00

2/27/2022 64 24 $12.00 $144.00 $144.00

3/6/2022 64 24 $12.00 $144.00 $144.00

3/13/2022 64 24 $12.00 $144.00 $144.00

3/20/2022 64 24 $12.00 $144.00 $144.00

3/27/2022 64 24 $12.00 $144.00 $144.00

4/3/2022 64 24 $12.00 $144.00 $144.00

4/10/2022 64 24 $12.00 $144.00 $144.00

4/17/2022 64 24 $12.00 $144.00 $144.00

4/24/2022 64 24 $12.00 $144.00 $144.00

5/1/2022 64 24 $12.00 $144.00 $144.00

5/8/2022 64 24 $12.00 $144.00 $144.00

5/15/2022 64 24 $12.00 $144.00 $144.00

5/22/2022 64 24 $12.00 $144.00 $144.00

5/29/2022 64 24 $12.00 $144.00 $144.00

6/5/2022 64 24 $12.00 $144.00 $144.00

6/12/2022 64 24 $12.00 $144.00 $144.00

6/19/2022 64 24 $12.00 $144.00 $144.00

6/26/2022 64 24 $12.00 $144.00 $144.00

7/3/2022 64 24 $12.00 $144.00 $144.00

7/10/2022 64 24 $12.00 $144.00 $144.00

TOTALS 1896 $11,376.00 $11,376.00

Case 1:22-cv-23158-XXXX Document 1 Entered on FLSD Docket 09/28/2022 Page 7 of 7