Case 9:12-cv-81185-RNS Document 8 Entered on FLSD Docket 11/16/2012 Page 1 of 2

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 12-cv-81185-SCOLA/HOPKINS ERICK LARA, on his own behalf and on behalf of others similarly situated, Plaintiff, v. QSGI GREEN, INC., a Delaware corporation, THE GASKET GUY, INC., a Florida corporation, and HANK LAWS, individually, Defendants. _______________________________________/ Plaintiff, ERICK LARA, by and through the undersigned counsel, hereby files his Statement of Claim, and states as follows: Plaintiff was employed by Defendants, between approximately June 2009 and September 2012. Within the 2 year statute of limitations1, which looks back October 2010, he was employed approximately 88 work weeks. During this time, Plaintiff worked approximately 8 hours of overtime on average each week. Plaintiff was paid on a piece rate basis, and earned an average of $600.00 in piece rate compensation each week. When Plaintiff worked overtime hours, he was not paid any additional compensation those hours. Based on the foregoing, Plaintiff is owed the following: $600.00/48 hours = $12.50 $12.50/2 = $6.25 $6.25 x 8 hours x 88 weeks = $4,400.00 To the extent discovery reveals that more hours were worked on average than are estimated herein, there may be an increase in the damages for this claim.
1

Plaintiff does not waive the argument that a 3 year statute of limitations applies in this case.

Case 9:12-cv-81185-RNS Document 8 Entered on FLSD Docket 11/16/2012 Page 2 of 2

The Statement of Claim is a preliminary estimate of the back wages owed to Plaintiff, and is based upon the limited information presently known to Plaintiff. Plaintiff reserves the right to amend his Statement of Claim based upon discovery and additional information. The above estimate is un-liquidated, and is exclusive of Plaintiffs attorneys fees and costs. Dated: November 16, 2012 Boca Raton, Florida Respectfully submitted, /S/ CAMAR R. JONES Camar R. Jones (Fla Bar No.: 720291) E-mail: cjones@shavitzlaw.com SHAVITZ LAW GROUP, P.A. 1515 S. Federal Highway, Suite 404 Boca Raton, Florida 33432 Telephone: 561-447-8888 Facsimile: 561-447-8831