UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

 

GONZALO CRIVELLO, 

 Plaintiff, 

 

 vs. 

 

RANSOM-EVERGLADES SCHOOL, INC, 

is a Florida Corporation, 

 

Defendant. 

_______________________________________/ 

COMPLAINT 

 Plaintiff, GONZALO CRIVELLO (hereinafter “CRIVELLO” or “Plaintiff”), by 

and through the undersigned counsel, hereby sues RANSOM-EVERGLADES SCHOOL, 

INC. (hereinafter “RANSOM”), and states as follows: 

JURISDICTION AND VENUE 

1. This action is brought to remedy violations of law that occurred in 

violation of 42 U.S.C. § 1981. This Court has jurisdiction pursuant to 28 U.S.C. §§ 1331. 

This Court has jurisdiction to grant declaratory and further relief pursuant to 28 U.S.C. §§ 

2201 and 2202. 

2. RANSOM is a corporation engaged in the staffing business conducting 

business in Miami-Dade, Florida and is within the jurisdiction of this Court. 

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PARTIES 

3. CRIVELLO is a resident of Doral, Florida. 

4. RANSOM is located in Miami-Dade County, Florida. 

5. CRIVELLO was, at all times material to this Complaint, employed by 

RANSOM in Miami-Dade, Florida. 

6. CRIVELLO has retained the undersigned attorneys to address the 

violations contained in this Complaint. 

7. All conditions precedent to filing suit have been met or have been waived. 

FACTUAL ALLEGATIONS 

8. RANSOM is a school that educates children from grades six through 

twelve. 

9. CRIVELLO, who was born in Argentina, and is Hispanic, worked as a 

sailing coach and PE teacher. 

10. CRIVELLO started working in 2012 for Defendant and held the positions 

of head sailing coach, physical education teacher, and waterfront director. 

11. CRIVELLO was among RANSOM’s top coaches during the time of his 

employment at RANSOM. 

12. In or about July 2014 RANSOM hired a new head of school, Stephanie 

“Penny” G. Townsend. Townsend was the former head of the Pennington School, 

Princeton, New Jersey, which is one of the oldest boarding schools in the nation. 

Townsend set out to change the culture of RANSOM, which was already one of the most 

successful schools in the nation in terms of academics and college placements. Even 

though RANSOM has always been a nationally recognized school that did not house its 

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students, Townsend envisioned a school whose culture was closer to a boarding-school 

style of education more prevalent in some of the nation’s oldest schools located in the 

Northeast. 

13. Some Hispanic instructors did not fit within the vision of a boardingschool type of education. At some point, Townsend began to terminate numerous 

instructors and/or coaches. A pattern emerged in which it became apparent that 

Townsend was firing or forcing out a disproportionate number of Hispanic teachers and 

coaches, some of whom had always excelled in the jobs and were popular among 

students and parents. These teachers and coaches were replaced with non-Hispanic 

individuals. 

14. The Hispanic coaches who were terminated include Mauricio Diaz, 

Francisco Viacava, Lorenzo Diaz and Geronimo Fernandez. 

15. Townsend made comments that were derogatory of Hispanics in reference 

to Hispanic faculty members. Townsend complained that Hispanics are “too loud,” “talk 

too much,” and gossip too much or words to that effect. 

16. In or about January 2015, RANSOM took away many of CRIVELLO’s 

responsibilities pertaining to the management of the waterfront and gave them to the 

person who was to be his successor, a non-Hispanic person who did not have anywhere 

near the same experience as CRIVELLO with regard to boating, sailing, or marine 

activities. 

17. Soon after taking over CRIVELLO’s responsibilities as waterfront 

director, CRIVELLO’s replacement ran over an obstruction in the water causing severe 

damage to the boat he and students were riding in at the time. That same week, 

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CRIVELO’s replacement ran out of gas while boating with students. He was never 

disciplined for such incidents. 

18. CRIVELLO first learned in May 2016 that RANSOM would not renew 

his employment contract. 

19. RANSOM terminated CRIVELLO because of his national origin and 

ancestry (Hispanic/Argentinean). 

COUNT I 

VIOLATION OF 42 U.S.C. § 1981 

20. RANSOM terminated CRIVELLO because of his ancestry and those 

ethnic characteristics associated with those born in Argentina and/or who are Hispanic in 

violation of 42 U.S.C. § 1981. 

21. RANSOM terminated CRIVELLO because has born in Argentina and is 

Hispanic in violation of 42 U.S.C. § 1981. 

22. The actions of RANSOM were intentional or were with reckless disregard 

of CRIVELLO’s civil rights. 

23. The actions of RANSOM as alleged herein were taken with malice and 

with a reckless disregard of CRIVELLO’ civil rights. 

WHEREFORE, Plaintiff CRIVELLO asks this Court to grant the following relief: 

 a. Issue a declaratory judgment finding that Defendant’s conduct 

toward CRIVELLO violated 42 U.S.C. § 1981; 

 b. Enjoin and restrain Defendant and all other persons acting on 

behalf of, or in concert with them, from engaging in such unlawful practices; 

 c. Enter judgment in favor of Plaintiff CRIVELLO and against 

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RANSOM for backpay, reinstatement or front pay in lieu of reinstatement in the amount 

of wages and fringe benefits it is determined that Plaintiff CRIVELLO has lost as a result 

of RANSOM’s unlawful conduct, together with prejudgment interest from the date of the 

violations; 

 d. Enter judgment in favor of Plaintiff CRIVELLO and against 

RANSOM for compensatory and punitive damages pursuant to federal statutes, including 

42 U.S.C. § 1981a, together with pre-judgment interest; 

 e. Award Plaintiff CRIVELLO a reasonable attorney’s fee, pursuant 

to 42 U.C.S. § 1988, with the costs of this action; and 

 f. Award such other and further legal and equitable relief as may be 

appropriate to redress fully the deprivation of Plaintiff CRIVELLO’s rights, to prevent 

reoccurrence of similar acts in the future and to protect RANSOM’s other employees 

from such unlawful behavior. 

JURY DEMAND

 CRIVELLO demands trial by jury on all issues so triable. 

 Respectfully submitted, 

GARY A. COSTALES, P.A. 

1200 Brickell Avenue, Suite 1440 

Miami, Florida 33131 

(305) 375-9510 

(305) 375-9511 (facsimile) 

 /s Gary A. Costales 

Gary A. Costales, Esq. 

Florida Bar No. 0948829 

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