IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION 

AARON B. LECHLER,

Plaintiff,

v. C.A. No.: 1:20-cv-141

WIREDRAWN POSTPRODUCTION, LLC, and,

JONATHAN NOWZARADAN,

Defendants.

__________________________________/

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff, AARON B. LECHLER (hereinafter sometimes referred to as 

“Plaintiff”), by and through his undersigned counsel, sues Defendants, 

WIREDRAWN POSTPRODUCTION, LLC, and JONATHAN NOWZARADAN

(hereinafter sometimes collectively referred to as “Defendants”), and in support 

thereof states as follows:

INTRODUCTION

1. This is an action by Plaintiff against his employers for unpaid wages 

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

Plaintiff seeks damages for unpaid overtime, liquidated damages, and a reasonable 

attorney’s fee and costs.

JURISDICTION

2. This claim is properly before this Court pursuant to 28 U.S.C. § 1331, 

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since this claim arises under federal law, and by the private right of action conferred 

in 29 U.S.C. § 216(b).

VENUE

3. Venue is proper in this district under 28 U.S.C. § 1391(b)(1) because 

Defendant, WIREDRAWN POSTPRODUCTION, LLC, has offices or conducts 

business in Travis County, Texas.

THE PARTIES

4. Plaintiff, AARON B. LECHLER, is an individual residing in Travis

County, Texas. 

5. Plaintiff, AARON B. LECHLER, was employed by Defendants from 

December of 2017, through January 10, 2019, as a “Story Editor,” whose duties were 

to create a story line via editing/producing the source footage, and was paid at the 

rate of $280.00 per ten (10) hour day.

6. Defendant, JONATHAN NOWZARADAN, is an individual residing 

in Travis County, Texas.

7. Defendant, WIREDRAWN POSTPRODUCTION, LLC, primarily 

operates a business that performs filmmaking, video production and photography 

services.

8. Defendant, WIREDRAWN POSTPRODUCTION, LLC, is a Limited 

Liability Company established under the laws of the State of Texas.

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9. Defendant, JONATHAN NOWZARADAN, at all times relevant to this 

matter acted directly or indirectly in the interest of Defendant, WIREDRAWN 

POSTPRODUCTION, LLC, in relationship to Plaintiff’s employment; therefore, is 

a joint employer as defined by 29 U.S.C. § 203(d).

10. Defendant, JONATHAN NOWZARADAN, (1) possessed the power to 

hire and fire the employees, (2) supervised and controlled employee conditions of 

employment, (3) determined the rate and method of payment for employees, and (4) 

maintained employment records. 

11. Defendant, WIREDRAWN POSTPRODUCTION, LLC, has 

employees subject to the provisions of 29 U.S.C. § 206 in the facility where Plaintiff

were employed. 

12. At all times material to this complaint, Defendant, WIREDRAWN 

POSTPRODUCTION, LLC, employed two or more employees and had an annual 

dollar volume of sales or business done of at least $500,000.00.

13. At all times material to this complaint, Defendant, WIREDRAWN 

POSTPRODUCTION, LLC, was an enterprise engaged in interstate commerce, 

operating a business engaged in commerce or in the production of goods for 

commerce as defined by § 3(r) and 3(s) of the Act, 29 U.S.C. §§ 203(r)-(s). 

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14. At all times material to this Complaint, Defendants were the employers

of the Plaintiff, and as a matter of economic reality, Plaintiff was dependent upon 

Defendants for his employment.

15. Plaintiff was individually engaged in commerce and produced goods 

for commerce and his work was directly and vitally related to the functioning of 

Defendants’ business activities. 

VIOLATION OF THE OVERTIME PROVISIONS OF

THE FAIR LABOR STANDARDS ACT

16. Plaintiff 1) occupied a position as a Story Editor; 2) did not hold a 

position considered as exempt from the overtime provisions of the FLSA; and, 3) 

was never paid any compensation for the work he provided in excess of 40 hours in 

a workweek.

17. Defendants’ management of Plaintiff required him to work in excess of 

40 hours in a workweek.

18. Plaintiff’s regular and recurring schedule varied as needed by the 

Defendants. Plaintiff typically averaged 50 hours of work in each workweek of his 

employment with the Defendants.

19. Plaintiff worked Plaintiff worked an average of 10 hours of overtime a 

workweek through his employment for which he was not compensated at one and 

one-half his regular rate.

20. Throughout the employment of Plaintiff, Defendants repeatedly and 

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willfully violated Sections 7 and 15 of the Fair Labor Standards Act by failing to 

compensate Plaintiff at a rate not less than one and one-half times his regular rate of 

pay for each hour worked in excess of 40 in a workweek. 

21. Defendants either knew about or showed reckless disregard for the 

matter of whether their conduct was prohibited by the FLSA and failed to act 

diligently with regard to their obligations as employers under the FLSA. 

22. Defendants failed to act reasonably to comply with the FLSA, and so

Plaintiff are entitled to an award of liquidated damages in an equal amount as the 

amount of unpaid overtime pay pursuant to 29 U.S.C. § 216(b).

23. The acts described in the above paragraphs violate the Fair Labor 

Standards Act, which prohibits the denial of overtime compensation for hours 

worked in excess of 40 per workweek. 

24. As a result of Defendants’ unlawful conduct, Plaintiff is entitled to 

actual and compensatory damages, including the amount of overtime which was not 

paid that should have been paid.

25. Plaintiff is entitled to an award of reasonable and necessary attorneys’

fees, costs, expert fees, mediator fees and out-of-pocket expenses incurred by 

bringing this action pursuant to 29 U.S.C. § 216(b) and Rule 54(d) of the Federal 

Rules of Civil Procedure. 

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WHEREFORE, Plaintiff, AARON B. LECHLER, demands Judgment against 

Defendants, jointly and severally, for the following:

a. Awarding Plaintiff his compensatory damages, attorneys’ fees and 

litigation expenses as provided by law;

b. Awarding Plaintiff his pre-judgment, moratory interest as provided by 

law, should liquidated damages not be awarded;

c. Awarding Plaintiff liquidated damages and/or statutory penalties as 

provided by law;

d. Awarding Plaintiff such other and further relief as the Court deems just 

and proper. 

JURY TRIAL DEMAND

Plaintiff, AARON B. LECHLER, demands a jury trial on all issues so triable.

Respectfully submitted this February 6, 2020.

ROSS • SCALISE LAW GROUP

1104 San Antonio Street

Austin, Texas 78701

(512) 474-7677 Telephone

(512) 474-5306 Facsimile

Charles@rosslawpc.com

_________________________________

CHARLES L. SCALISE

Texas Bar No. 24064621

DANIEL B. ROSS

Texas Bar No. 789810

ATTORNEYS FOR PLAINTIFF

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