1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ZOLDAN LAW GROUP, P

L

L

C

14500 N. Northsight Blvd. Suite 213 Scottsdale, Arizona 85260

Tel & Fax: 480.442.3410 – mzoldan@zoldangroup.com

Michael Zoldan; AZ Bar No. 028128

Jason Barrat; AZ Bar No. 029086

Jessica Miller; AZ Bar No. 031005

ZOLDAN LAW GROUP, PLLC

14500 N. Northsight Blvd., Suite 213

Scottsdale, AZ 85260

Tel & Fax: 480.442.3410

mzoldan@zoldangroup.com

jbarrat@zoldangroup.com

jmiller@zoldangroup.com

Attorneys for Plaintiff 

Dasha Ossiko

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Dasha Ossiko, an Arizona resident;

Plaintiff, 

v.

Amazing GLO, LLC d/b/a Adore Skin

& Body Sculpting, an Arizona limited 

liability company; Ondranique Walls, an 

Arizona resident; and Destiney Bell, an 

Arizona resident; 

Defendants.

Case No. 

VERIFIED COMPLAINT

(Jury Trial Requested)

Plaintiff Dasha Ossiko, for her Verified Complaint against Defendants, hereby 

alleges as follows:

NATURE OF THE CASE

1. Plaintiff brings this action against Defendants for their unlawful failure to 

pay minimum wage in violation of the Fair Labor Standards Act, 29 U.S.C. §§ 201-219

(hereinafter “FLSA”); A.R.S. §§ 23-362 - 23-364 (“Arizona Minimum Wage Statute”); 

and failure to make timely and reasonable payment of wages under the Arizona Wage 

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 1 of 10
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ZOLDAN LAW GROUP, P

L

L

C

14500 N. Northsight Blvd. Suite 213 Scottsdale, Arizona 85260

Tel & Fax: 480.442.3410 – mzoldan@zoldangroup.com

Statute, A.R.S. §§ 23-351, 23-353, and 23-355 (“Arizona Wage Statute”).

2. This action is also brought to recover minimum wage compensation, 

liquidated damages, and statutory penalties resulting from Defendants’ violations of the 

FLSA and Arizona Minimum Wage Statute.

3. This action is also brought to recover unpaid wages, treble damages, and 

statutory penalties resulting from Defendants’ violations of the Arizona Wage Statute.

JURISDICTION AND VENUE

4. This Court has jurisdiction over the subject matter and the parties hereto 

pursuant to 29 U.S.C. § 216(b) and 28 U.S.C. § 1331.

5. Plaintiff’s state law claims are sufficiently related to her federal claim that it 

forms the same case or controversy. This Court therefore has supplemental jurisdiction 

over Plaintiff’s claims under the Arizona Minimum Wage Statute and Arizona Wage 

Statute pursuant to 28 U.S.C. § 1367.

6. Venue is proper in this District under 28 U.S.C. §§ 1391(b) and (c) because 

all or a substantial part of the acts or omissions giving rise to the claims occurred in the 

state of Arizona. Plaintiff was employed by Defendants in this District.

PARTIES

7. At all relevant times to the matters alleged herein, Plaintiff Dasha Ossiko

resided in the District of Arizona. 

8. Plaintiff was a part-time, non-exempt employee of Defendants from on or 

about August 21, 2017 until on or about September 20, 2017.

9. At all relevant times, Plaintiff was an employee of the Defendants as defined 

in 29 U.S.C. § 203(e)(1), A.R.S. § 23-362, and A.R.S. § 23-350, and was a non-exempt 

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 2 of 10
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ZOLDAN LAW GROUP, P

L

L

C

14500 N. Northsight Blvd. Suite 213 Scottsdale, Arizona 85260

Tel & Fax: 480.442.3410 – mzoldan@zoldangroup.com

employee under 29 C.R.F. §213(a)(1).

10. Defendant Amazing GLO, LLC d/b/a Adore Skin & Body Sculpting is a 

limited liability company, authorized to do business in Arizona, and was Plaintiff’s 

employer as defined by 29 U.S.C. § 203(e)(1), A.R.S. § 23-362, and A.R.S. § 23-350.

11. Defendant Ondranique Walls is an Arizona resident. She has directly caused 

events to take place giving rise to this action. Ondranique Walls was at all relevant times 

Plaintiff’s employer as defined by 29 U.S.C. § 203(e)(1), A.R.S. § 23-362, and A.R.S. § 

23-350.

12. Defendant Destiney Bell is an Arizona resident. She has directly caused 

events to take place giving rise to this action. Destiney Bell was at all relevant times 

Plaintiff’s employer as defined by 29 U.S.C. § 203(e)(1), A.R.S. § 23-362, and A.R.S. § 

23-350.

13. Under the FLSA, Defendants Ondranique Walls and Destiney Bell are

employers. The FLSA defines “employer” as any individual who acts directly or indirectly 

in the interest of an employer in relation to an employee. Defendants Ondranique Walls 

and Destiney Bell determined the method and rate of Plaintiff’s payment of wages. As 

persons who acted in the interest of the previously identified corporate entities in relation 

to the company’s employees, Ondranique Walls and Destiney Bell are subject to individual 

and personal liability under the FLSA.

14. Plaintiff is further informed, believes, and thereon alleges that each of the 

Defendants herein gave consent to, ratified, and authorized the acts of all other Defendants, 

as alleged herein.

15. Defendants, and each of them, are sued in both their individual and corporate

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 3 of 10
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ZOLDAN LAW GROUP, P

L

L

C

14500 N. Northsight Blvd. Suite 213 Scottsdale, Arizona 85260

Tel & Fax: 480.442.3410 – mzoldan@zoldangroup.com

capacities.

16. Defendants are jointly and severally liable for the injuries and damages 

sustained by Plaintiff.

17. At all relevant times, Defendants have been engaged in interstate commerce 

and have been an enterprise whose gross annual volume of sales made or business done is 

greater than $500,000. 

FACTUAL ALLEGATIONS

18. Defendants own and operate Adore Skin & Body Sculpting which is a body 

sculpting and skin rejuvenation treatment center.

19. On or about August 21, 2017, Plaintiff commenced employment with 

Defendants as an administrative assistant.

20. As an administrative assistant, Plaintiff’s primary job duties included 

greeting clientele, answering incoming calls, sales support, scheduling patient 

appointments, document filing, chart preparation, maintaining medical records, managing 

referrals, sorting of faxes/mail and data entry.

21. At the commencement of Plaintiff’s employment, she was a non-exempt 

employee and was paid $2.25 per hour as an administrative assistant.

22. Between August 21, 2017 and September 20, 2017 Plaintiff worked a total 

of 40 hours and was compensated a total of $90.00.

23. At all relevant times, Plaintiff’s job responsibilities differed to training she 

would be given in an educational environment.

24. At all relevant times, Defendants directly benefited from Plaintiff’s work 

product.

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 4 of 10
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ZOLDAN LAW GROUP, P

L

L

C

14500 N. Northsight Blvd. Suite 213 Scottsdale, Arizona 85260

Tel & Fax: 480.442.3410 – mzoldan@zoldangroup.com

25. Plaintiff routinely worked alone without any supervision of existing staff.

26. Defendant Ondranique Walls trained Plaintiff for approximately one day 

before releasing her to work under no supervision.

27. Defendants directly derived an immediate advantage from Plaintiff’s work 

product.

28. At no time throughout the tenure of Plaintiff’s employment were the 

operations of the defendants impeded.

29. After an initial 90 day period, Plaintiff was entitled to full time employment 

with compensation of $14.00 per hour.

30. Plaintiff and Defendants agreed to compensation in the amount of $60.00 per 

week. 

31. On or about September 20, 2017 Plaintiff was terminated for inquiring about 

her owed wages.

32. Between August 21, 2017 and September 20, 2017, Defendants failed to 

properly compensate Plaintiff minimum wage under both the FLSA and the Arizona 

Minimum Wage Statute.

33. Between August 21, 2017 and September 20, 2017, Defendants paid Plaintiff 

$90.00 in exchange for the 40 hours of work she performed for the benefit of Defendants. 

34. Defendants refused and/or failed to properly disclose or apprise Plaintiff of 

her rights under the FLSA, Arizona Minimum Wage Statute, and Arizona Wage Statute.

35. Defendants willfully failed and/or refused to compensate Plaintiff at the rates 

and amounts required by the FLSA and the Arizona Minimum Wage Statute.

36. Defendants received the benefit of Plaintiff’s work without providing her any 

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 5 of 10
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ZOLDAN LAW GROUP, P

L

L

C

14500 N. Northsight Blvd. Suite 213 Scottsdale, Arizona 85260

Tel & Fax: 480.442.3410 – mzoldan@zoldangroup.com

compensation, much less reasonable compensation, for her efforts. 

37. Defendants’ failure and/or refusal to compensate Plaintiff at the rates and 

amounts required by the FLSA and Arizona Wage Statute were willful.

COUNT I

(FAILURE TO PAY MINIMUM WAGE – FLSA – 29 U.S.C. § 206)

38. Plaintiff incorporates by reference all of the above allegations as though fully 

set forth herein.

39. At all relevant times, Plaintiff was employed by Defendants within the 

meaning of the FLSA.

40. Plaintiff was an employee entitled to the statutorily mandated minimum 

wage.

41. Defendants have intentionally failed and/or refused to pay Plaintiff minimum 

wage according to the provisions of the FLSA.

42. As a direct result of Defendants’ violations of the FLSA, Plaintiff has 

suffered damages by not receiving any compensation in accordance with 29 U.S.C.§ 206.

43. In addition to the amount of unpaid minimum wage owed to Plaintiff, she is 

entitled to recover an additional equal amount as liquidated damages pursuant to 29 U.S.C.

§ 216(b).

44. Defendants’ actions in failing to compensate Plaintiff, in violation of the 

FLSA, were willful. Defendants knew Plaintiff was not being compensated properly for 

time worked and failed to pay proper minimum wages. Defendants knew their failure to

pay minimum wage was a violation of the FLSA.

45. Defendants have not made a good faith effort to comply with the FLSA.

46. Plaintiff is also entitled to an award of attorneys’ fees and other statutory 

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 6 of 10
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ZOLDAN LAW GROUP, P

L

L

C

14500 N. Northsight Blvd. Suite 213 Scottsdale, Arizona 85260

Tel & Fax: 480.442.3410 – mzoldan@zoldangroup.com

damages pursuant to 29 U.S.C. § 216(b). 

COUNT II

(FAILURE TO PAY MINIMUM WAGE – ARIZONA MINIMUM WAGE 

STATUTE)

47. Plaintiff incorporates by reference all of the above allegations as though fully 

set forth herein.

48. At all relevant times, Plaintiff was employed by Defendants within the 

meaning of the Arizona Minimum Wage Statute.

49. Defendants intentionally failed and/or refused to pay Plaintiff minimum 

wage according to the provisions of the Arizona Minimum Wage Statute.

50. In addition to the amount of unpaid minimum wage owed to Plaintiff, she is 

entitled to recover an additional amount equal to twice the underpaid wages and interest 

pursuant to A.R.S. § 23-364(g).

51. Plaintiff is also entitled to an award of attorneys’ fees and costs pursuant to

A.R.S. § 23-364(g).

COUNT III

(FAILURE TO TIMELY PAY WAGES DUE – ARIZONA WAGE STATUTE)

48. Plaintiff incorporates by reference all of the above allegations as though fully 

set forth herein.

49. At all relevant times, Plaintiff was employed by Defendants within the 

meaning of the Arizona Wage Statute.

50. Defendants were aware of their obligation to pay timely wages pursuant to 

A.R.S. § 23-351.

51. Defendants were aware that, under A.R.S. § 23-353, they were obligated to 

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 7 of 10
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ZOLDAN LAW GROUP, P

L

L

C

14500 N. Northsight Blvd. Suite 213 Scottsdale, Arizona 85260

Tel & Fax: 480.442.3410 – mzoldan@zoldangroup.com

pay all wages due to Plaintiff.

52. Defendants failed to timely pay Plaintiff her wages due without a good faith 

basis for withholding the wages.

53. Defendants have willfully failed and refused to timely pay wages due to 

Plaintiff. As a result of Defendants' unlawful acts, Plaintiff is entitled to the statutory 

remedies provided pursuant to A.R.S. § 23-355.

CONCLUSION AND PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays:

A. For the Court to declare and find that the Defendants committed the 

following acts:

i. violated minimum wage provisions of the FLSA, 29 U.S.C. § 206, 

by failing to pay minimum wages;

ii. willfully violated minimum wage provisions of the FLSA, 29 

U.S.C. § 206, by failing to pay minimum wages;

iii. violated minimum wage provisions of the Arizona Minimum 

Wage Statute, by failing to pay minimum wages;

iv. willfully violated minimum wage provisions of the Arizona 

Minimum Wage Statute, by failing to pay minimum wages;

v. willfully violated the Arizona Wage Statute by failing to pay all 

wages due to Plaintiff;

B. For the Court to award compensatory damages, including liquidated damages 

pursuant to 29 U.S.C. § 216(b) and/or treble damages pursuant to the Arizona 

Wage Statute, in an amount to be determined at trial;

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 8 of 10
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ZOLDAN LAW GROUP, P

L

L

C

14500 N. Northsight Blvd. Suite 213 Scottsdale, Arizona 85260

Tel & Fax: 480.442.3410 – mzoldan@zoldangroup.com

C. For the Court to award an additional amount equal to twice the underpaid 

minimum wages and interest pursuant to A.R.S. § 23-364(g), in an amount 

to be determined at trial.

D. For the Court to award interest on all wage compensation due accruing from 

the date such amounts were due under all causes of action set forth herein;

E. For the Court to award such other monetary, injunctive, equitable, and 

declaratory relief as the Court deems just and proper;

F. For the Court to award Plaintiff’s reasonable attorneys’ fees and costs 

pursuant to 29 U.S.C. § 216(b), A.R.S. § 23-364(g), and A.R.S. § 12-341.01

and all other causes of action set forth herein;

G. Any other remedies or judgments deemed just and equitable by this Court.

JURY DEMAND

Plaintiff hereby demands a trial by jury of all issues so triable.

RESPECTFULLY SUBMITTED December 12, 2017.

ZOLDAN LAW GROUP, PLLC

By: /s/ Jason Barrat 

14500 N. Northsight Blvd, Suite 213

Scottsdale, AZ 85260

Attorneys for Plaintiff Dasha Ossiko

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 9 of 10
1 VERIFICATION 

2 

Plaintiff Dasha Ossiko declares under penalty of perjury that she has read the 

3 

4 foregoing Verified Complaint and is familiar with the contents thereof The matters asserted 

5 therein are true and based on her personal knowledge, except as to those matters stated upon 

6 information and belief, and as to those matters, she believes them to be true. 

7 

8 

9 

10 

u 0 

"' ....:l N 

::::e 11 

....:l 0 

~~ 

0.. 0 c. N ~ 12 ~ ~ 

<co 0.. • c ua 

;:J -;~ 

"OC 

0 :!@ 13 0 c p::: u a "'-o 

d :!'0 

~ e 14 

~ .';;I 

~:= 

< ... "0 ~ 15 

....:l ~N ., .. -": 

z .c o 16 .. ~ 

< ~: ~ d 

Q ~u. 17 ....:l . o<j z_ 

0 o u 

N ~f-o 

18 

Dasha Ossiko 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Case 2:17-cv-04589-DJH Document 1 Filed 12/12/17 Page 10 of 10