UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OFFLORIDA 

MIAMI DIVISION

CASE NUMBER:

REINALDO VELAZQUEZ,

Plaintiff,

vs.

MIAMI-DADE COUNTY, a political 

Subdivision of the State of Florida,

Defendant.

VERIFIED COMPLAINT 

AND

DEMAND FOR JURY TRIAL

Plaintiff REINALDO VELAZQUEZ ("VELAZQUEZ") files this Verified 

Complaint and sues the Defendant, MIAMI-DADE COUNTY ("COUNTY"), for 

violations of Title VII of the Civil Rights Act of 1964, Title 42 of the United States Code, 

Section 2000e et seq, and the Age Discrimination Employment Act (ADEA), based upon 

discrimination based upon age, race, ethnicity, and retaliation, and states as follows:

JURISDICTION

1. This Court has jurisdiction over the subject matter of this lawsuit under 28

U.S.C. § 1337 and Title VII of the Civil Rights Act of 1964, Title 42, United 

States Code, Section 2000e-16 and the Age Discrimination in Employment Act 

of1967;

CONDITIONS PRECEDENT

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2. All conditions precedent have been met, waived, or otherwise excused.

VELAZQUEZ filed a timely Complaint with the EEOC and received a Right to 

Sue Letter, followed by the timely initiation of this lawsuit;

VENUE

3. Venue is proper in the United States District Court for the Southern District of 

Florida in that the Plaintiff was employed by COUNTY;

PARTIES

4. VELAZQUZ, the Plaintiff, was an employee ofMIAM-DADE COUNTY 

as bus operator working for the Miami-Dade Transit Authority until 

January, 2020;

5. Miami-Dade County is a Political Sub-Division of the State of Florida;

6. At all times material, COUNTY was the employer ofthePlaintiff within the 

meaning of Title VII of the Civil Rights Act of 1964 and the Age 

Discrimination in Employment Act of 1967;

I. INTRODUCTION

7. VELAZQUZ was discriminated and retaliated against based on age, race, 

and ethnicity in violation of Title VII of the 1964 Civil Rights Act, as 

amended, and based on age in violation of the Age Discrimination in 

Employment Act of 1967, as amended.

II. THE FACTS OF THE CASE

1. VELAZQUEZ was employed as a bus operator with COUNTY's

Department of Transportation & Public Works;

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2. VELAZQUEZ is an Hispanic male;

3. VELAZQUEZ is over the age of 60 years;

4. VELAZQUEZ had an excellent work record for over 15 years and there was 

never a legitimate, non-discriminatory reason to terminate his employment;

5. VELAZQUEZ was supervised by African-American Supervisors who spoke 

to him in a derogatory manner and treated him less favorably than they treated 

African-American employees;

6. VELAZQUEZ's treatment was based on a deliberate motive to discriminate 

against him based on his race and ethnicity and the County Transportation 

Department was aware or should have been of this discrimination and yet 

condoned and permitted it;

7. VELAZQUEZ was qualified to work as a busdriver;

8. VELAZQUEZ was also terminated based upon his age and COUNTY's

desire to employ younger drivers;

9. Although VELAZQUEZ was terminated, COUNTY's Transportation & 

Public Works Department hired drivers under the age of 40 who were not as 

qualified as VELAZQUEZ;

10. All of the alleged reasons resulting in the discrimination of VELAZQUEZ 

constituted a pretext as there were valid no non-discriminatory reasons upon 

which to base the severe remedy of termination;

11. The termination of VELAZQUEZ and the decision to sustain his termination 

occurred in retaliation for his filing of an EEOC Complaint and of grievances, 

all of which were related to his complaints about discrimination that wasillegal

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under Title VII and the ADEA; thus, the County retaliated against the Plaintiff 

because of his Complaints about race, ethnic, and age discrimination;

12. VELAZQUEZ was allegedly terminated for having a verbal 

disagreement with an African-American supervisor. This action was taken

without any of the required steps set forth in COUNTY's Rules of 

Progressive Discipline, and there was no "just cause;"

13. African-American employees under similar or identical circumstances either

received no discipline, progressive discipline and /or were not terminated;

14. The Plaintiffs African-American supervisors discriminated against the 

Plaintiff because of his race and ethnicity and provided more favorable 

treatment for bus operators and other transit employees who were not 

Hispanic white males;

15. On one occasion, the Plaintiff went into Superintendent Wells' office, a 

black female and she became hostile and disparaged the plaintiff in a 

manner that she did not treat African American employees;

16. Dispatcher Supervisor St. Preux, of African-American decent, suspended 

VELAZQUEZ for no reason. He had arrived to perform his second piece of 

work and the dispatcher told him that the work had already been assigned to 

another operator. Mr. St. Preux took it upon himself to call the driver back 

and assign the work to VELAZQUEZ, who took the work. As he was 

performing his pre-trip, he noticed that the work was 15 minutes behind 

schedule. He did the route, even though he knew it was behind schedule; 

however, since it was a priority route, he wanted to write a report. When he 

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arrived at the end of the route, he asked Mr. St. Preux for his name to include 

in his report because at that time VELAZQUEZ did not know who Mr. St. 

Preux was. Mr. St. Pruex questioned whether VELAZQUEZ had his vest on, 

which was irrelevant because VELAZQUEZ was in the dispatch office and 

the vest was only required to be worn in the parking lot. There were many 

operators in the garage with jackets on because the office is cold; however, 

Mr. Pruex only asked VELAZQUEZ for his vest. He proceeded to suspend him 

and instructed Supervisor Wilson to remove VELAZQUEZ from duty for the 

next day. He then advised VELAZQUEZ to go see his superintendent the next 

day. Before leaving, VELAZQUEZ opened his jacket to show him that he was 

wearing his vest under his jacket. Mr. St. Preux did not have the authority to 

suspend him, and when he arrived the next day to speak with his superintendent, 

he was told that he was not suspended, that he would get paid for the day, and to 

report for duty as scheduled the following day;

17. VELAZQUEZ was verbally reprimanded because despite feeling ill he still

reported for work, but his supervisor attempted to write him up. When 

VELAZQUEZ pulled into an emergency bay at the end of my route because 

he felt so ill, an ambulance had to be called to the site. His vitals were taken 

and his blood pressure was high. He was advised to go see his doctor. A 

Supervisor drove him to the garage, but then he had to wait for an hour and a 

half to be driven to the doctor. After waiting for so long, he went home and 

went to the doctor on my own. After discussing the incident with his 

Supervisor upon his return to work, the write-up did not occur because there 

was video evidence reviewed by Shop Steward Kevin Craig and

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VELAZQUEZ showing that Supervisor Juan Diaz violated major rules 

while operating the bus, which included talking on the phone while operating 

the bus and backing up without assistance. Two days later, VELAZQUEZ 

spoke with Kevin Craig to follow up and was told that General 

Superintendent of Bus Operations Joel Perez reviewed the tape and said that 

I was being retaliated against by Supervisor Juan Diaz for his complaints.

18. These actions have no justification other than discrimination because of his 

Hispanic heritage and age. In all of the actions listed in above, supervisors 

have been trying to reprimand him without just cause;

19. VELAZQUEZ is in the possession of the disciplinary action reports of other

African-American employees that performed acts severely more egregious 

than those for which VELAZQUEZ was falsely accused, and the worst

discipline received by any of those African-American employees was a 30-

day suspension, along with a "Last Chance Agreement," and they were back 

on the job. None were ever terminated;

20. On January 6, 2020, VELAZQUEZ was terminated from his position as a 

bus operator by Defendant MIAMII-DADE COUNTY's Department of 

Transportation and Public Works (DTPW);

21, When the Plaintiff was stationed in the Coral Way Garage, which is a more 

diverse garage because of the demographics of the community, there were 

never any issues. Upon arriving at the Central Bus Garage, which is 

predominately an African-American majority demographic, VELAZQUEZ

began getting increased calls to see his Supervisor, who was African

American.

22. On April 5, 2019, VELAZQUEZ was performing his first piece of work when 

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he was delayed in traffic. He would normally need to be relieved at the end of 

the line, then catch the bus going back to the garage to begin his second piece 

of work. If he is even ten minutes late, he would miss the bus going back to the 

garage, so this was not a one-time occurrence. On one particular day, the bus he 

rode going back to the garage had an accident enroute, furthering thedelay 

through no fault of his own. When arriving at the garage, he was told to go see the 

Superintendent to sign his green sheet (late payment form). This is part of the 

normal process when the second piece of work has already been assigned to a 

driver on the board. VELAZQUEZ's regular Supervisor, Mr. Orlando Aleman, 

was not present at the time and only Ms. Sandra Wells was at the office. As 

VELAZQUEZ approached, there was an African-American bus operator standing 

at the doorway to her office. He had a similar situation as VELAZQUEZ had 

experienced, and Ms. Wells signed that driver's sheet without incident. As 

VELAZQUEZ approached, Ms. Wells' demeanor changed immediately. Similar to 

the driver before him, he asked her to please sign his green sheet. Her response was 

abrasive, and she stated, "You know, if it was up to me, I would take away the 

second piece of work and send you back to the board." VELAZQUEZ asked her if 

she were treating him so poorly because he had brought up concerns about this 

incident. He asked her to check his video to see if he did anything wrong, but there 

was no reasoning with Ms. Wells. As the conversation escalated, VELAZQUEZ stated 

that this discriminatory treatment was unfair and that he was going to go talk with the 

Chief. At that time, Ms. Wells stated, "Are you trying to intimidate me?" 

VELAZQUEZ replied, "No. Are you try to intimidate me?" While walking out of 

Ms. Wells' office to go to Chief Achinah's office, she followed him and Supervisor 

Gilbert had to physically restrain Ms. Wells from attacking him. She de-escalated the 

situation and VELAZQUEZ was asked to go home. An hour later, VELAZQUEZ 

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was called and relieved of duty pending an investigation.

COUNT I.

RACE AND ETHNIC BASED DISCIMINAITON (TITLE VII)

23. Plaintiff re-alleges paragraphs 1 through 22 as if fully setforth herein;

24. Plaintiff was received adverse action and was terminated because of 

discrimination based on his race and ethnicity;

25. As a result, the Plaintiff has been damaged.

WHEREFORE, the Plaintiff demands an award of damages, including 

compensatory damages, attorneys’ fees and costs and any other relief under 

the law.

COUNT II. 

DISCRIMINATION BASED ON AGE IN 

VIOLATION OF AGE DISCRIMINATION

IN EMPLOYMENT ACT OF 1967

26. Plaintiff re-alleges paragraphs 1 through 25 as if fully setforth herein;

27. VELAQUEZ is a 60-year-old male, and the COUNTY willfully 

discriminated against him due to his age by intentionally firing him

because of his age and then retaining and/or hiring younger and less 

qualified individuals;

38. As a direct and proximate result of said discrimination by COUNTY,

Plaintiff has suffered damages.

WHEREFORE, Plaintiff demands judgment for damages against the COUNTY, 

including but not limited to compensatory damages, back pay and benefits, future pay and 

benefits, liquidated damages, punitive damages, prejudgment interest, and attorney's fees and 

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costs, and other available relief as the Court deems just and proper.

COUNT III. 

RETALIATION IN VIOLATION OF TITLE VII

29. Plaintiff re-alleges paragraphs 1 through 28 above as if fully set forth 

herein;

30. Plaintiff engaged in protected activities in the form of filing a 

Complaint;

31. As a direct and proximate result of his engaging in protected activities and

in direct retaliation for his engaging in his protected activities, the Plaintiff 

was subjected to adverse employment action in a tangible way, denial of 

employment opportunities, and deprivation of benefits and termination;

32. As a direct and proximate result, Plaintiff has suffered permanent 

damages.

WHEREFORE, Plaintiff demands judgment for damages against the COUNTY, including 

but not limited to compensatory damages, back pay and benefits, future pay and benefits, liquidated 

damages, punitive damages, prejudgment interest, and attorney's fees and costs, and other 

available relief as the Court deems just and proper.

DEMAND FOR JURY TRIAL

Plaintiff demands trial by jury of all issues triable as of right by jury.

VERIFICATION

I declare under penalty of perjury under the laws of the United States of America that I

have read the Complaint and the foregoing facts are true and correct.

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REINALDO VELAZQUEZ

Dated this 28th day of April, 2020, by Reinaldo Velazquez, Plaintiff

Respectfully submitted,

Michael A. Pizzi, Jr., Esq.

Florida Bar No. 079545

Attorney for Plaintiff

6625 Miami Lakes Drive - Suite 316 Miami 

Lakes, FL 33014

Telephone: (305) 986-2277

Fax: (305) 777-3802

E-Mail: mpizzi@pizzilaw.com

By: s/s Michael A. Pizzi, Jr. 

 Michael A. Pizzi, Jr., Esq.

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