IN THE COUNTY COURT FOR
BREVARD COUNTY, FLORIDA
SELECT SEAFOODS, INC.
Plaintiff, KENNETH HENLEY, by and through his undersigned attorney, sues Defendant, SELECT SEAFOODS, INC., and alleges as follows:
1. This is an action for unpaid wages that do not exceed $15,000.
2. Plaintiff, KENNETH HENLEY, (hereinafter “HENLEY”) is a resident of Brevard County, Florida.
3. Defendant, SELECT SEAFOODS, INC., (hereinafter “SELECT SEAFOODS”) is a Florida corporation doing business in the State of Florida.
4. Plaintiff was employed by the Defendant in the Defendant’s Rockledge Office in Brevard County, Florida.
5. On September 3, 1999, Plaintiff was hired as a truck driver by Defendant.
6. Plaintiff began the employment and continued to perform Plaintiff’s duties until November 26, 1999.
7. Defendant did not pay Plaintiff his weekly salary for the weeks of November 13, 1999 and November 20, 1999.
8. Despite demand being made upon Defendant, Defendant has refused to pay Plaintiff the wages that Plaintiff earned for the weeks of November 13, 1999 and November 20, 1999.
9. Defendant owes Plaintiff wages in the amount of $ 960.00 plus interest.
10. Defendant did not reimburse Plaintiff for phone expenses and monies advanced by Plaintiff for repairs on Defendant’s vehicle during the weeks of November 13, 1999 and November 20, 1999 in the amount of $588.76 plus interest.
11. Plaintiff is obligated to pay his attorneys a reasonable fee for their services.
12. This is an action for unpaid wages and Plaintiff is entitled to his attorney fees pursuant to Section 448.08, Florida Statutes, 1999.
13. Plaintiff has complied with all conditions precedent prior to bringing this action.
WHEREFORE, Plaintiff prays for judgment against Defendant for unpaid wages with interest and all other damages to which he may be entitled, together with his attorney fees and costs of this action.
DATED: This ____ day of June, 2000.
Wayne L. Allen, Esquire
Florida Bar No. 110025
Adrienne E. Trent
Florida Bar No. 0060119
Attorneys for Plaintiff
WAYNE L. ALLEN, P.A.
700 N. Wickham Road, Ste. 107
Melbourne, FL 32935
Attorney: Maurice Arcadier
Date Filed: 06/2000
Our Melbourne office is centrally located in Brevard County, enabling our lawyers to serve clients throughout “the Space Coast”, including Cocoa Beach, Palm Bay and Vero Beach.