Garcia v. Ray's Smoothies Inc.
- Lorna Schofield
- 1:24-cv-02234
- U.S. District Court · Southern District of New York
- 2
In Garcia v. Ray’s Smoothies Inc., Judge Aaron ordered damages materials and briefing after a default judgment on some wage claims.
Maria Garcia must provide the damages spreadsheet, billing records, and letter brief concerning her FLSA overtime claim. Ray’s Smoothies Inc. and the other defendants are affected because the filings concern the amount and terms of relief sought after default judgment on some claims.
What happened
In Garcia v. Ray’s Smoothies Inc., Maria Garcia sought a default judgment against Ray’s Smoothies Inc. and other defendants. A prior order granted default judgment on her overtime claim under the Fair Labor Standards Act and on New York wage-notice and wage-statement claims, but denied it on her minimum-wage claim.
This order requires Garcia to file a damages spreadsheet for the overtime claim, provide billing records showing hours and rates, and submit a letter addressing whether she seeks both extra damages and prejudgment interest. She must file these materials by February 14, 2025, and email a native version of the spreadsheet to chambers.
Judge Stewart D. Aaron issued the order and referred the case to a damages proceeding for the claims covered by the default judgment. The order did not decide whether Garcia may recover both types of monetary relief.
The detailed version
- Garcia v. Ray's Smoothies Inc. · No. 1:24-cv-02234
- Lorna Schofield
- Jan. 31, 2025
Background
Maria Garcia filed a motion for a default judgment on July 24, 2024. Her attorney’s filing referred to three exhibits, including a damages spreadsheet and billing records, but those exhibits were not filed on the court’s electronic docket.
A January 30, 2025, order granted default judgment on Garcia’s overtime claim under the Fair Labor Standards Act (FLSA) and on her New York Labor Law claims involving failure to provide a wage notice and accurate wage statements. That order denied the motion as to Garcia’s FLSA minimum-wage claim and referred the case for a damages inquest, meaning a proceeding to determine the amount of money owed, on the claims for which default judgment was granted.
This Order
The court ordered Garcia to do three things by February 14, 2025:
- File a damages spreadsheet calculating the amount she seeks for the FLSA overtime claim and email a native version of that spreadsheet to chambers.
- File contemporaneous billing records showing the time spent on the case and the hourly rate charged.
- File a letter brief addressing whether she contends that she may recover both liquidated damages and prejudgment interest on the FLSA overtime claim and, if so, identifying the legal basis for that position.
The order quoted precedent stating that prejudgment interest may not be awarded in addition to liquidated damages in an FLSA action. It did not resolve that issue in this order.
Disposition and Classification
Judge Stewart D. Aaron ordered the specified filings and continued the damages process. This is a procedural order concerning the calculation of damages and related submissions; it did not decide the unresolved question about combining liquidated damages with prejudgment interest.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.