MARTINEZ RAMOS v. JUSTIN'S CAFE, LLC, 1:19-cv-00014

Plaintiff Santos Martinez Ramos worked at Justin's Café (2013–2018) as a dishwasher/food preparer; he alleges he worked roughly 45–56 hours/week but was not paid overtime.
He was paid hourly (started $11/hr; ended $16/hr) and alleges multiple bounced paychecks and no pay during the restaurant's final pay periods.
Plaintiff sued Jan. 3, 2019 under the FLSA, DCMWA, and DCWPCL; he voluntarily dismissed the corporate owner and another individual, leaving defendant Allison Kays (the general manager).
Kays was served Jan. 19, 2019, never appeared; the Clerk entered default March 27, 2019, and plaintiff moved for default judgment.
The court found Kays an "employer" with operational control, held the complaint's allegations well-pleaded, and awarded default judgment totaling $60,560.88 (unpaid overtime $6,249.84; unpaid wages $6,782.13; liquidated damages $39,095.91; attorney's fees $7,913; costs $520).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether default judgment is appropriate	Kays was properly served and failed to appear or defend	(No response; Kays did not contest)	Default properly entered and judgment appropriate where defendant unresponsive under Fed. R. Civ. P. 55 and precedent.
Liability under FLSA/DCMWA for unpaid overtime/wages	Ramos worked overtime and was paid straight time; Kays, as GM, exercised operational control and is an "employer" liable	(No response)	Well-pleaded allegations establish Kays is an employer and liable under FLSA and DCMWA.
Damages for unpaid wages/overtime — evidentiary sufficiency	Ramos submitted declaration, paystubs, bounced-check evidence, and detailed damage calculations to quantify unpaid wages/overtime	(No response)	Court independently calculated damages based on submitted records and awarded unpaid overtime $6,249.84 and unpaid wages $6,782.13.
Liquidated damages — FLSA vs. D.C. law	Plaintiff seeks liquidated damages; D.C. law allows treble damages under DCMWA/DCWPCL (more favorable)	(No response / no good-faith defense)	Apply D.C. law (employee entitled to higher recovery); treble damages awarded ($39,095.91) because defendant offered no good-faith defense.
Attorney's fees & costs — reasonableness	Counsel submitted contemporaneous time records and applied Laffey rates; seeks $7,913 in fees and $520 in costs	(No response)	Rates and hours found reasonable; fees $7,913 and costs $520 awarded.

H.F. Livermore Corp. v. Aktiengesellschaft Gebruder Loepfe, 432 F.2d 689 (D.C. Cir. 1970) (default judgment appropriate when adversary process halted by unresponsive party)
Fanning v. Wellman Dynamics Corp., 113 F. Supp. 3d 172 (D.D.C. 2015) (default establishes liability for well-pleaded allegations but court must determine damages)
Flynn v. Mastro Masonry Contractors, 237 F. Supp. 2d 66 (D.D.C. 2002) (damages may be based on affidavits and documentary evidence without a hearing)
Boland v. Elite Terrazzo Flooring, Inc., 763 F. Supp. 2d 64 (D.D.C. 2011) (definition of employer and effect of default on liability)
Guevara v. Ischia, Inc., 47 F. Supp. 3d 23 (D.D.C. 2014) (person with operational control over wages/hours qualifies as employer)
Ventura v. L.A. Howard Constr. Co., 134 F. Supp. 3d 99 (D.D.C. 2015) (court may award damages and need not hold hearing if record supports award)
Martinez v. Asian 328, LLC, 220 F. Supp. 3d 117 (D.D.C. 2016) (D.C. law allows treble damages for wage violations; apply the more generous remedy)
Hensley v. Eckerhart, 461 U.S. 424 (U.S. 1983) (lodestar method for attorney's fees)
Blum v. Stenson, 465 U.S. 886 (U.S. 1984) (reasonable hourly rate standard)
Covington v. District of Columbia, 57 F.3d 1101 (D.C. Cir. 1995) (use prevailing community rates; discussion of Laffey matrix)