10. This Court has jurisdiction pursuant to 28 U.S.C. § 1331 as this case is brought pursuant to  The Fair Labor Standards Act, 29 U.S.C. §§ 201-219 (section #216 for jurisdictional  placement).    12. Plaintiff worked for Defendant as pool installer and concrete worker from on or about  November 20, 2016 through to on or about March 27, 2020.    13. Defendant's business activities involve those to which the Fair Labor Standards Act applies.  Both the Defendant’s business and the Plaintiffs’ work for the Defendants affected interstate  commerce for the relevant time period. Plaintiffs’ work for the Defendants affected interstate  commerce for the relevant time period because the materials and goods that Plaintiffs used on  a constant and/or continual basis and/or that were supplied to him by the Defendants to use  on the job moved through interstate commerce prior to and/or subsequent to Plaintiffs’ use of  the same. The Plaintiffs’ work for the Defendants was actually in and/or so closely related to  the movement of commerce while he worked for the Defendants that the Fair Labor  Standards Act applies to Plaintiffs’ work for the Defendants.     14. Additionally, Defendants regularly employed two or more employees for the relevant time  period who regularly handled goods or materials that travelled through interstate commerce,  or used instrumentalities of interstate commerce, thus making Defendants’ business an  enterprise covered under the Fair Labor Standards Act.   15. Upon information and belief, the Defendant Corporation had gross sales or business done in  excess of $500,000 annually for the years 2016, 2017, 2018 and 2019.      16. Upon information and belief, the Defendant Corporation’s gross sales or business done has  exceeded $250,000 for the first six months of the year 2020 and is expected to exceed  $500,000 for the year 2020.   18. Between the period of on or about January 1, 2020 through to on or about March 27, 2020,  Plaintiff worked 7 days a week, worked an average of 90 hours a week for Defendant and  was paid nothing at all for the 50 hours worked in excess of 40 in a week as required by the  Fair Labor Standards Act. Plaintiff therefore claims the time and half time overtime rate of  $15.00 for each hour worked above 40 in a week.   20. This Court has jurisdiction for Plaintiff’s unpaid wage claim as this is a claim for unpaid  wages pursuant to Fla. Stat. § 448.08.   21. Plaintiff orally contracted for employment with Defendants and Defendants verbally  agreed to pay Plaintiff.   22. From on or about January 1, 2020 through to on or about March 27, 2020, of Plaintiff  employment with Defendants, Plaintiff worked 7 days each week for Defendants. During  this time Plaintiff worked approximately 90 hours per week for Defendants. However,  Defendants have not paid Plaintiff any wages for the 12 weeks that Plaintiff worked for  Defendants during this time at a rate of $10.00 per hour for 40 hours and $15.00 per hour  for the 50 overtime hours worked in each week from January 1, 2020 through to on or  about March 27, 2020.   23. As a direct proximate result of Defendants action, Plaintiff has suffered damages.   25. 29 U.S.C. § 206 (a) (1) states "Every employer shall pay to each of his employees who in any  workweek is engaged in commerce or in the production of goods for commerce, or is  employed in an enterprise engaged in commerce or in the production of goods for commerce,  wages at the following rates: except as otherwise provided in this section, not less than--  $5.85 an hour, beginning on the 60th day after May 25, 2007; $6.55 an hour, beginning 12  months after that 60th day; and $7.25 an hour, beginning 24 months after that 60th day…”  [29 U.S.C. § 206 (a) (1)]". On July 24, 2007 Federal minimum wage was raised to $5.85/hr.  On July 24, 2008, Federal minimum wage was raised to $6.55/hr. On July 24, 2009, Federal  minimum wage was raised to $7.25/hr.    26. Between the period of on or about January 1, 2020 through to on or about March 27, 2020,  Plaintiff worked an average of 90 hours a week for the Defendants. Plaintiff was paid  $0.00/hr for said work in violation of the Fair Labor Standards Act as said payment of  $0.00/hr did not meet the applicable Federal Minimum Wage required for said period of  time. Therefore, Plaintiff claims difference between his average hourly rate of $0.00/hr and  the applicable minimum wage rate of $7.25/hr for all hours worked.   8. This action arises under the laws of the United States.     9. This case is brought as a collective action under 29 USC 216(b). It is believed that the  Defendant has employed several other similarly situated employees like Plaintiff who have  not been paid overtime wages for work performed in excess of 40 hours weekly from the  filing of this complaint back three years.   COME NOW PLAINTIFF, through Counsel, and re-adopts the factual and  jurisdictional statements in paragraphs 1-19 above and further states:   JOINTLY AND SEVERALLY  COMES NOW PLAINTIFF, through Counsel, and re-adopts the factual and  jurisdictional statements in the paragraphs 1-7 as though fully set forth herein and further states:    JOINTLY AND SEVERALLY  COMES NOW PLAINTIFF, through Counsel, and re-adopts the factual and jurisdictional  statements in paragraphs 1-24 above and further states:  