Automated Summary
Key Facts
Plaintiff Jerin Varghese filed suit against Defendants Plecosystems Inc. and Warren Casey alleging violations of the Fair Labor Standards Act and New York Labor Law for unpaid wages and overtime. Plaintiff was employed as a business analyst for approximately 15 months from January 2021 to March 25, 2022, earning between $110,000-$132,000 annually on a salary basis. Defendants failed to pay Plaintiff for the last several weeks of work during which he worked approximately 45 hours per week. The case was filed on May 8, 2023, with default certificates entered in November 2023. After a hearing on July 8, 2025, the Court granted default judgment on August 12, 2025, awarding Plaintiff $28,919.96 total, including $13,032.13 in unpaid wages, $13,032.13 in liquidated damages, $1,427.85 in unpaid overtime, and $1,427.85 in liquidated damages on overtime.
Issues
- The court evaluated whether Plaintiff sufficiently alleged all elements of his claims pursuant to the Fair Labor Standards Act and New York Labor Law, including employer status and coverage requirements. The court found Plaintiff adequately pled employer status and that Defendants failed to invoke any exemptions.
- The court determined whether it has subject matter jurisdiction over the action, noting that Plaintiff alleges violations of the Fair Labor Standards Act, a federal statute, and claims under the New York Labor Law arise from the same facts, thus establishing subject matter jurisdiction over all claims in this action.
- The court analyzed whether personal jurisdiction was proper over both Defendants. Plecosystems is a Delaware Corporation with principal place of business in New York, and Casey is a New York resident who signed a waiver of service. The court found it has personal jurisdiction over Defendants under New York law and federal rules.
- The court considered three factors for granting default judgment: whether the defendant's default was willful, whether defendant has a meritorious defense to plaintiff's claims, and the level of prejudice the non-defaulting party would suffer. The court found Defendants' default was willful, they failed to present any defense, and denying the motion would be prejudicial to Plaintiff.
- The court assessed the appropriate damages award, finding Plaintiff's evidence provided sufficient basis to evaluate the fairness of the requested damages. The court awarded $28,919.96 total, representing $13,032.13 in unpaid wages, $13,032.13 in liquidated damages, $1,427.85 in unpaid overtime, and $1,427.85 in liquidated damages on overtime.
Holdings
- The court granted Plaintiff's motion for default judgment against Defendants Plecosystems Inc. and Warren Casey, finding the default was willful, no meritorious defense was presented, and entry of judgment was appropriate under Rule 55 of the Federal Rules of Civil Procedure. The court awarded Plaintiff $28,919.96 in total damages, consisting of unpaid wages, liquidated damages, and unpaid overtime.
- The court awarded Plaintiff $28,919.96 in total damages, consisting of $13,032.13 in unpaid wages with liquidated damages, $1,427.85 in unpaid overtime with liquidated damages, and reasonable attorneys' fees and costs to be determined later. The Clerk of Court is requested to terminate the motion at docket entry 33.
- The court found it has personal jurisdiction over both Defendants - Plecosystems Inc. as a Delaware corporation with principal place of business in New York, and Warren Casey as a New York resident who signed a waiver of service. The court also found subject matter jurisdiction over all claims arising from the same facts under FLSA and NYLL.
- The court found Plaintiff sufficiently alleged liability under the Fair Labor Standards Act and New York Labor Law for minimum wage and overtime claims. Defendants failed to invoke any exemptions as the burden rests on the employer. Plaintiff worked approximately 15 months for Defendants and was owed unpaid wages for the last several weeks of employment.
Remedies
- The court awarded the plaintiff $1,427.85 in unpaid overtime compensation for hours worked in excess of 40 per week, plus liquidated damages equal to the same amount of $1,427.85, as required by both the Fair Labor Standards Act and New York Labor Law for uncompensated overtime hours.
- The court awarded the plaintiff $13,032.13 in unpaid wages for his last month of work, plus liquidated damages equal to the same amount of $13,032.13, representing compensation for the failure to pay minimum wage and overtime hours as required under the Fair Labor Standards Act and New York Labor Law.
- The court granted the plaintiff reasonable attorneys' fees and costs incurred in this action, with the specific amount to be determined later. The Court will refer Plaintiff's motion for attorneys' fees and costs to Magistrate Judge Netburn for an inquiry on reasonable attorneys' fees and costs.
Monetary Damages
28919.96
Legal Principles
Under Rule 55 of the Federal Rules of Civil Procedure, default judgment requires a two-step process: first entry of default, then entry of default judgment. Courts consider three factors: (1) whether the defendant's default was willful, (2) whether defendant has a meritorious defense, and (3) prejudice to the non-defaulting party. For FLSA exemptions, the burden rests on the employer to prove employees fall within exempted categories; willful default constitutes waiver of affirmative defenses. The FLSA requires employers to pay minimum wage and overtime for hours worked over 40 per week. Employer status is determined by examining the economic reality including power to hire/fire, control over work schedules, rate and method of payment, and maintenance of employment records.
Precedent Name
- City of New York v. Mickalis Pawn Shop, LLC
- Santana v. Latino ExpressRestaurants, Inc.
- Mt. Hawley Ins. Co. v. Pioneer Creek B LLC
- Irizarry v. Catsimatidis
- Transatlantic Marine Claims Agency, Inc. v. Ace Shipping Corp.
Cited Statute
- Fair Labor Standards Act
- New York Labor Law
Judge Name
Mary Kay Vyskocil, United States District Judge
Passage Text
- "The Court held a hearing on Plaintiff's motion for a default judgment in this matter on July 8, 2025. As explained at that hearing and as further detailed below, Plaintiff's motion for default as to Defendants Plecosystems Inc. and Warren Casey is GRANTED."
- "Judgment is hereby entered in favor of Plaintiff against Defendants in the amount of $28,919.96, representing $13,032.13 in unpaid wages for his last month of work; liquidated damages on the unpaid wages in the sum of $13,032.13; unpaid overtime in the amount of $1,427.85; liquidated damages on the unpaid overtime in the sum of $1,427.85; and reasonable attorneys' fees and costs incurred in this action in an amount to be determined later."
- "When determining whether to grant a motion for default judgment, courts in this district consider three factors: (1) whether the defendant's default was willful; (2) whether defendant has a meritorious defense to plaintiff's claims; and (3) the level of prejudice the non-defaulting party would suffer as a result of the denial of the motion for default judgment."