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Plaintiff,
v.
Defendants.
_______________________________________/
COMPLAINT
Plaintiff, Marcus Abrego, on his own behalf and on behalf of all others similarly situated,
sues Defendants, Baker Landscape Corporation, a Florida corporation, and Mark Allen Baker
(collectively “Defendants” unless otherwise noted), for violating the Fair Labor Standards Act,
a non-exempt employee within the meaning of the FLSA and was entitled to minimum and
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SARELSON LAW FIRM, P.A., 1401 Brickell Avenue, Suite 510, Miami, Florida 33131, 305-379-0305, 800-421-9954 (fax)
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www.Sarelson.com
Case 9:10-cv-80944-JIC Document 1 Entered on FLSD Docket 08/10/2010 Page 2 of 3
4. Mark Allen Baker is the owner of the corporate defendant and is an employer of
the Plaintiff within the meaning of the FLSA. He is the individual responsible for Plaintiff’s
routinely worked in excess of 40 hours per week. He was paid $9.00 per hour and was only paid
6. Plaintiff’s counsel has reviewed Plaintiff’s time records but they do not accurately
9. Many of the Defendants’ employees are undocumented immigrants who are far
11. Venue is proper because all of the facts and allegations that form the basis of this
12. Upon information and belief, numerous employees of the Defendants were and
are being improperly denied wages in violation of the FLSA and Florida common law.
13. Plaintiff has retained counsel and is obligated to pay a fee for services rendered.
14. The parties engaged in presuit settlement discussions in a good faith effort to
resolve the matter without litigation, but the parties were unable to reach a solution.
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SARELSON LAW FIRM, P.A., 1401 Brickell Avenue, Suite 510, Miami, Florida 33131, 305-379-0305, 800-421-9954 (fax)
www.FloridaEmploymentLawyerBlog.com
www.Sarelson.com
Case 9:10-cv-80944-JIC Document 1 Entered on FLSD Docket 08/10/2010 Page 3 of 3
16. Plaintiff was a non-exempt employee within the meaning of the FLSA. He was
17. Defendants were and remain employers within the meaning of the FLSA.
Defendants paid the Plaintiff only straight time for all hours worked in excess of forty and also
failed to pay a minimum wage for uncompensated hours worked less than 40 per week.
20. Plaintiff is entitled to an award of back pay and liquidated damages equal to the
Plaintiff prays that this Court enter judgment in his favor against Defendants, Baker
Landscape Corporation, and Mark Allen Baker (jointly and severally) and award monetary
damages for back pay, liquidated damages, reasonable attorneys’ fees and costs and any other
Respectfully submitted,