Plaintiff vs. Platt’s Inc. - Unpaid Wages.

Plaintiff vs. Platt’s Air Conditioning & Heating, Inc. - Unpaid Wages.

IN THE COUNTY COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND
FOR BREVARD COUNTY, FLORIDA




ANTHONY NACHREINER,
Case No.
Plaintiff,

v.


PLATT’S AIR CONDITIONING & HEATING, INC.,

Defendant. ________________________________________/


COMPLAINT

Plaintiff, ANTHONY NACHREINER, by and through his undersigned attorney, sues Defendant, PLATT’S AIR CONDITIONING & HEATING, INC., and alleges as follows:
COUNT I - UNPAID WAGES
1. This is an action for unpaid wages that exceed $5,000.00.
2. Plaintiff, ANTHONY NACHREINER, (hereinafter “NACHREINER”) is a resident of Brevard County.
3. Defendant, PLATT’S AIR CONDITIONING & HEATING, INC., (hereinafter “PLATT’S”) is a Florida Corporation with an office in Palm Bay, Florida.
4. Plaintiff, NACHREINER, was most recently employed by Defendant, PLATT’S, from March 2001 to December 6, 2001.
5. Plaintiff’s hourly wage from March to December 2001 was $13.46 per hour.
6. Plaintiff, NACHREINER, was not paid his full hourly wage for his last seven (7) days or 56 hours of work for Defendant, PLATT’S.
7. Plaintiff was also paid a commission of 5% for the sales he made to certain clients including Brevard Builders Group, Prestige Homes and Totty Construction, in addition to his hourly wage.
8. Plaintiff has not received his 5% commission for the sales he made in October, November and December 2001.
9. Plaintiff was also paid a commission of 5% for the upgrades he sold to certain clients including Belmont Homes, Tiffany Homes and Tricon Development, in addition to his hourly wage.
10. Plaintiff has not received his 5% commission for the upgrades he sold in October, November and December 2001.
11. Plaintiff has complied with all conditions precedent prior to bringing this action.
12. Plaintiff has retained the undersigned attorneys and has agreed to pay them a reasonable fee.
13. This is an action for unpaid wages and Plaintiff is entitled to his attorney fees pursuant to Section 448.08, Florida Statutes, 2001.


14. WHEREFORE, Plaintiff, NACHREINER, demands judgment against Defendant, PLATT’S, for his damages for unpaid wages and commissions, attorney fees and costs of this action, pursuant to Section 448.08, Florida Statutes, 2001 and such other damages as this Court deems just and proper.

DATED this _____day of February, 2002.



______________________
Wayne L. Allen, Esquire
Florida Bar No. 110025
Adrienne E. Trent, Esquire
Florida Bar No. 0060119
W. John Gadd, Esquire
Florida Bar No. 0463061
WAYNE L. ALLEN & ASSOCIATES, P.A.
Attorneys for Plaintiff
700 N. Wickham Road, Suite 107
Melbourne, Florida 32935
Phone: (321) 254-7550
Fax: (321) 242-1681

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.