Lee v. Direct Sales Advantage LLC et al
Plaintiff: Thomas Franklin Lee
Defendant: Direct Sales Advantage LLC, Chlomi Ohana, Hanan Bajayo and Family Moving Services, Inc doing business as Texas Movers Group
Case Number: 0:2026cv60249
Filed: January 29, 2026
Court: U.S. District Court for the Southern District of Florida
Presiding Judge: Melissa Damian
Nature of Suit: Labor: Fair Standards
Cause of Action: 29 U.S.C. ยง 0201 Fair Labor Standards Act
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on March 23, 2026. A more recent docket listing may be available from PACER.

Date Filed Document Text
March 23, 2026 Filing 9 NOTICE of Attorney Appearance by Nicholas Giovanni Battaglia on behalf of Family Moving Services, Inc, Chlomi Ohana. Attorney Nicholas Giovanni Battaglia added to party Family Moving Services, Inc(pty:dft), Attorney Nicholas Giovanni Battaglia added to party Chlomi Ohana(pty:dft). (Battaglia, Nicholas)
March 12, 2026 Filing 8 Defendant's MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM by Hanan Bajayo, Direct Sales Advantage LLC. Responses due by 3/26/2026. (Kassier, Andrew)
March 12, 2026 Filing 7 NOTICE of Attorney Appearance by Andrew Michael Kassier on behalf of Hanan Bajayo, Direct Sales Advantage LLC. Attorney Andrew Michael Kassier added to party Hanan Bajayo(pty:dft), Attorney Andrew Michael Kassier added to party Direct Sales Advantage LLC(pty:dft). (Kassier, Andrew)
March 8, 2026 Filing 6 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Thomas Franklin Lee. Hanan Bajayo served on 2/23/2026, response/answer due 3/16/2026. (Cuthbertson, Dillon)
March 8, 2026 Filing 5 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Thomas Franklin Lee. Direct Sales Advantage LLC served on 2/23/2026, response/answer due 3/16/2026. (Cuthbertson, Dillon)
January 30, 2026 Opinion or Order Filing 4 PAPERLESS ORDER ON COURT PRACTICE IN CASES WITH MULTIPLE DEFENDANTS THIS CAUSE is before the Court upon a sua sponte review of the record. To better manage the orderly progress of the case, it is hereby ORDERED as follows:1. Plaintiff shall file proof of service, as to each Defendant, within seven (7) days of perfecting service on each Defendant. 2. Defendants shall file their responses and motions jointly. a. If there are conflicts of position, the co-Defendants shall file a motion for leave to file separate responses or motions, in which they must describe what those conflicts are.b. If the co-Defendants need more than twenty (20) pages for their joint responses or motions, they shall file a motion for leave to file excess pages, which the Court will consider expeditiously. 3. The co-Defendants may file separate answers to the Complaint. Unless otherwise ordered by the Court, the time for responsive pleadings--for all Defendants--begins to run once all Defendants have either (1) been served or (2) waived service. If the Defendants face response periods of different lengths--say, because one Defendant has been personally served whereas another has waived service--all Defendants will be subject to the longest of those response periods. 4. Although all Defendants will be subject to the longest of all response periods, each served Defendant must still file a notice of appearance within twenty-one (21) days of being served with the Complaint (or sixty (60) days if service is waived).5. Failure to comply with these procedures may result in sanctions, including the striking of the motion(s) or response(s). Signed by Judge Melissa Damian on 1/30/2026. (mul)
January 30, 2026 Filing 3 Summons Issued as to Hanan Bajayo, Direct Sales Advantage LLC, Family Moving Services, Inc, Chlomi Ohana. (scn)
January 29, 2026 Filing 2 Clerks Notice of Judge Assignment to Judge Melissa Damian. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Alicia O. Valle is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. (scn)
January 29, 2026 Filing 1 COMPLAINT against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-19168612, filed by Thomas Franklin Lee. (Attachments: #1 Civil Cover Sheet, #2 Summon(s), #3 Exhibit A - Plaintiff's Statement of Claim)(Cuthbertson, Dillon)

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Plaintiff: Thomas Franklin Lee
Represented By: Dillon Scott Cuthbertson
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Defendant: Direct Sales Advantage LLC
Represented By: Andrew Michael Kassier
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Defendant: Chlomi Ohana
Represented By: Nicholas Giovanni Battaglia
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Defendant: Hanan Bajayo
Represented By: Andrew Michael Kassier
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Defendant: Family Moving Services, Inc doing business as Texas Movers Group
Represented By: Nicholas Giovanni Battaglia
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