Jimenez v. Brownstone Property Group LLC, and Brownstone Management LLC, and Brownstone Works Well, LLC, and Alejandro Romero, individually; Index No.:24-cv-5108

New Action filed in the United States District Court Eastern District of New York

On July 23, 2024, Plaintiff Jimenez, on behalf of himself, individually, and on behalf of all others similarly-situated, (collectively as “FLSA Plaintiffs”), by and through his attorneys, BORRELLI & ASSOCIATES, P.L.L.C., as and for his Complaint against BROWNSTONE PROPERTY LLC (“Brownstone Property”), and BROWNSTONE MANAGEMENT LLC (“Brownstone Management”), and BROWNSTONE WORKS WELL, LLC (“Brownstone Works”), (all three, together, as “Eternity Defendants”), and ALEJANDRO ROMERO,  individually, (together, with Eternity Defendants, where appropriate, as “Defendants”), alleges upon knowledge as to himself and his own actions, and upon information and belief as to all other matter, as follows :

Plaintiff worked for Defendants – – three New York limited liability companies based in Kings County, one a holdings company and the other two its subsidiaries, which together operate as a single integrated enterprise to run a property management and property renovation/construction company, and the enterprise’s Chief of Construction who is its day-to-day overseer of construction and maintenance operations – – as a construction and maintenance worker at various buildings that Defendants managed throughout New York City, from in or around June 2019 through March 2023. As described below, on several weeks during his employment, Defendants willfully failed to pay Plaintiff the overtime wages lawfully due to him under the Fair Standards Labor Act (“FLSA”) and the New York Labor Law (“NYLL”).  Specifically, during those weeks, Defendants required to work Plaintiff to work, and Plaintiff did work, beyond forty hours, yet Defendants paid Plaintiff a flat daily rate that did not change based on how many Plaintiff worked in a day or in a week, and thus Defendants did not pay Plaintiff overtime pay at the rate of one and one-half times Plaintiff’s regular rate of pay for any hours that Plaintiff worked in excess of forty in a week. Additionally, from January 2020 through the end of his employment, Defendants violated the NYLL by failing to pay Plaintiff, a manual worker, on at least as frequently as a weekly basis, paying him on a bi-weekly instead. Defendants also violated the NYLL by failing to furnish with any wage statement on each payday for the period that Plaintiff worked in 2019, and from 2020 through the end of his employment, by providing him with an inaccurate wage statement on each payday, and by failing to provide Furthermore, throughout at least the Relevant Period, Defendants failed to provide him with any wage notice upon his hire. Defendants paid and treated all of their non-managerial construction and/or maintenance work in the same manner.

If any individual is or has previously been an employee of the Defendants named in the lawsuit and/or has information that may be relevant to this case, please contact Borrelli & Associates, P.L.L.C. as soon as possible through one of our websites, www.employmentlawyernewyork.com or www.516abogado.com, or any of our phone numbers: (516) 248–5550, (516) ABOGADO, or (212) 679–5000.