EXHIBIT A

Case 1:20-cv-22242-KMW Document 1-2 Entered on FLSD Docket 05/29/2020 Page 1 of 21
MIAMI-DADE COUNTY CLERK OF THE 

COURTS

HARVEY RUVIN

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JORGE UGARTE VS WHOLE FOODS MARKET IP LP

Local Case Number: 2020-008685-CA-01 Filing Date: 04/20/2020

State Case Number: 132020CA008685000001 Judicial Section: CA02

Consolidated Case No.: N/A Case Type: Discrimination - Employment or Other

Case Status: OPEN

Ä Parties Total Of Parties: 2 +

å Hearing Details Total Of Hearings: 0 −

Hearing Date Hearing Time Hearing Code Description Hearing Location

± Dockets Total Of Dockets: 9 −

Number Date Book/Page Docket Entry

Event 

Type Comments

Ŗ 8 05/20/2020 Motion for 

Extension of 

Time

Event Parties: Whole Foods Market IP LP

Ŗ 7 05/06/2020 Service 

Returned

Event Parties: Whole Foods Market IP LP

6 04/23/2020 Receipt: Event RECEIPT#:2320139 AMT PAID:$10.00 NAME:SYGMAN, FORREST 

7300 N KENDALL DR STE 450 MIAMI FL 33155 COMMENT: 

ALLOCATION CODE QUANTITY UNIT AMOUNT 3139-SUMMONS 

ISSUE FEE 1 $10.00 $10.00 TENDER TYPE:E-FILING ACH TENDER 

AMT:$10.00 RECEIPT

04/22/2020 20 Day 

Summons 

Issued

Service

Ŗ 5 04/22/2020 ESummons 20 

Day Issued

Event Parties: Whole Foods Market IP LP

Ŗ 4 04/22/2020 (M) 20 Day (C) 

Summons (Sub) 

Received

Event

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Number Date Book/Page Docket Entry

Event 

Type Comments

3 04/21/2020 Receipt: Event RECEIPT#:2320176 AMT PAID:$401.00 NAME:SYGMAN, FORREST 

7300 N KENDALL DR STE 450 MIAMI FL 33155 COMMENT: 

ALLOCATION CODE QUANTITY UNIT AMOUNT 3100-CIRCUIT 

FILING FEE 1 $401.00 $401.00 TENDER TYPE:E-FILING ACH 

TENDER AMT:$401.00 RECE

Ŗ 2 04/20/2020 Complaint Event

Ŗ 1 04/20/2020 Civil Cover 

Sheet - Claim 

Amount

Event

General

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HARVEY RUVIN

Miami-Dade County 

Clerk of the Courts

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Miami, Florida 33130

305-275-1155

©2020 Clerk of the Courts. All rights reserved.

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Case 1:20-cv-22242-KMW Document 1-2 Entered on FLSD Docket 05/29/2020 Page 3 of 21
FORM 1.997. CIVIL COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of

pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the

Clerk of Court for the purpose of reporting data pursuant to section 25.075, Florida Statutes. (See instructions

for completion.)

I. CASE STYLE

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Case No.: _________________

Judge: ____________________

Jorge Ugarte

Plaintiff

 vs.

Whole Foods Market I.P.,L.P.,a Foreign Limited Par

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount of the claim rounded to the nearest dollar $30,001

III. TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the

most descriptive label is a subcategory (is indented under a broader category), place an x on both the main

category and subcategory lines.

☐ Condominium

☐ Contracts and indebtedness

☐ Eminent domain

☐ Auto negligence

☐ Negligence – other

 ☐ Business governance

 ☐ Business torts

 ☐ Environmental/Toxic tort

 ☐ Third party indemnification

 ☐ Construction defect

 ☐ Mass tort

 ☐ Negligent security

 ☐ Nursing home negligence

 ☐ Premises liability – commercial

 ☐ Premises liability – residential

☐ Products liability

☐ Real Property/Mortgage foreclosure

 ☐ Commercial foreclosure

 ☐ Homestead residential foreclosure

 ☐ Non-homestead residential foreclosure

 ☐ Other real property actions

 ☐ Professional malpractice

 ☐ Malpractice – business

 ☐ Malpractice – medical

 ☐ Malpractice – other professional

 ☒ Other

 ☐ Antitrust/Trade Regulation

 ☐ Business Transaction

 ☐ Circuit Civil - Not Applicable

 ☐ Constitutional challenge-statute or ordinance

 ☐ Constitutional challenge-proposed amendment

 ☐ Corporate Trusts

 ☒ Discrimination-employment or other

 ☐ Insurance claims

 ☐ Intellectual property

 ☐ Libel/Slander

 ☐ Shareholder derivative action

 ☐ Securities litigation

 ☐ Trade secrets

 ☐ Trust litigation

 ☐ County Civil

 ☐ Small Claims up to $8,000 

 ☐ Civil 

 ☐ Replevins

 ☐ Evictions

 ☐ Other civil (non-monetary)

 

Filing # 106452957 E-Filed 04/20/2020 02:06:33 PM Case 1:20-cv-22242-KMW Document 1-2 Entered on FLSD Docket 05/29/2020 Page 4 of 21
COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the

Administrative Order. Yes ☐ No ☒

IV. REMEDIES SOUGHT (check all that apply):

☒ Monetary;

☐ Non-monetary declaratory or injunctive relief;

☐ Punitive

V. NUMBER OF CAUSES OF ACTION: 

(Specify)

3

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

☐ Yes

☒ No

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

☒ No

☐ Yes – If “yes” list all related cases by name, case number and court:

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

 ☒ Yes

 ☐ No

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and

that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425.

Signature: s/ Forrest Sygman 

Attorney or party

FL Bar No.: 748020 

(Bar number, if attorney)

 Forrest Sygman

 (Type or print name)

 Date: 04/20/2020

Case 1:20-cv-22242-KMW Document 1-2 Entered on FLSD Docket 05/29/2020 Page 5 of 21








IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA.

 IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY,FLORIDA.

DIVISION

CIVIL  OTHER

 DISTRICTS

SUMMONS 20 DAY CORPORATE SERVICE

(a) GENERAL FORMS

CASE NUMBER

2020-008685-CA-01

PLAINTIFF(S)

JORGE UGARTE

VS. DEFENDANT(S)

WHOLE FOODS MARKET I.P., L.P.,

a Foreign Limited Partnership,

SERVICE

THE STATE OF FLORIDA:

To Each Sheriff of the State:

YOU ARE COMMANDED to serve this summons and copy of the complaint or petition in this action on 

defendant(s): WHOLE FOODS MARKET I.P., L.P., 

 By serving the Registered Agent CT Corporation System

 1200 S. Pine Island Road

 Plantation, Fl 33324

 

Each defendant is required to serve written defense to the complaint or petition on

Plaintiff’s Attorney: FORREST SYGMAN, PA

CLO

C

K IN

whose address is: 7300 NORTH KENDALL DRIVE, SUITE 450

 MIAMI, FL 33156 

within 20 days “ Except when suit is brought pursuant to s. 768.28, Florida Statutes, if the State of Florida, one of its agencies, or 

one of its officials or employees sued in his or her official capacity is a defendant, the time to respond shall be 40 days. When 

suit is brought pursuant to. 768.28, Florida Statutes, the time to respond shall be 30 days.” after service of this summons on that 

defendant , exclusive of the day of service, and to file the original of the defenses with the Clerk of this Clerk Court either before service 

on Plaintiff’s attorney or immediately thereafter. If a defendant fails to do so, a default will be entered against that defendant for the relief 

demanded in the complaint or petition.

HARVEY RUVIN

CLERK of COURTS

DEPUTY CLERK

DATE

AMERICANS WITH DISABILITIES ACT OF 1990 

ADA NOTICE

“If you are a person with a disability who needs any accommodation in order to participate 

in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. 

Please contact the Eleventh Judicial Circuit Court’s ADA Coordinator,Lawson

E. Thomas Courthouse Center, 175 NW 1st Ave., Suite 2702, Miami, FL 33128, Telephone 

(305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 at least 7 days before your 

scheduled court appearance, or immediately upon receiving this notification if the time 

before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, 

call 711.”

CLK/CT. 314 Rev. 02/16 Clerk’s web address: www.miami-dadeclerk.com

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Case 1:20-cv-22242-KMW Document 1-2 Entered on FLSD Docket 05/29/2020 Page 17 of 21
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

CASE NO. 2020-008685-CA-01 

JORGE UGARTE, 

Plaintiff, 

v. 

WHOLE FOODS MARKET I.P., L.P., 

Defendant. 

________________________________________/ 

DEFENDANT’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO 

RESPOND TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

Defendant, WHOLE FOODS MARKET I.P., L.P. (“Defendant”), respectfully requests the 

entry of an order extending the time, through and including June 5, 2020, in which to file a response 

to Plaintiff, JORGE UGARTE’s (“Plaintiff”) Complaint. In support of this Motion, Defendant 

states as follows: 

1. Plaintiff filed this action on April 20, 2020. Defendant was served with the 

Summons and Complaint on May 1, 2020. Accordingly, Defendant’s response to the Complaint 

is currently due on May 21, 2020. 

2. Counsel for Defendant is currently in the process of investigating the allegations of 

the Complaint, and respectfully requests a brief extension, through and including June 5, 2020, to 

respond to the Complaint. The requested extension will permit counsel to investigate the matter in 

order to prepare an adequate response. 

3. In accordance with the Rules of this Court, on May 18, 2020, Defendant’s counsel, 

Alexandra Blanco Mangas, conferred with Plaintiff’s counsel, Forrest Sygman, Esq., who advised 

that Plaintiff has no objection to the requested enlargement of time. 

Filing # 107735997 E-Filed 05/20/2020 12:16:36 PM Case 1:20-cv-22242-KMW Document 1-2 Entered on FLSD Docket 05/29/2020 Page 18 of 21
2 

4. This motion is not made to unduly delay these proceedings, the requested extension 

will not prejudice either party, and it is in the interest of justice to grant the enlargement requested 

herein. 

WHEREFORE, Defendant respectfully requests that the Court enter an Order granting the 

instant Motion and permitting Defendant to respond to Plaintiff’s Complaint on or before June 5, 

2020. 

DATED: this 20th day of May 2020. Respectfully Submitted, 

By: /s/ Alexandra Blanco Mangas 

Patrick G. DeBlasio, III 

Florida Bar No. 871737 

E-mail: pdeblasio@littler.com 

Secondary: btapia@litter.com 

Alexandra Blanco Mangas 

Florida Bar No. 106874 

E-mail: alblanco@littler.com 

Secondary: kljackson@littler.com 

LITTLER MENDELSON, P.C. 

Wells Fargo Center 

333 S.E. 2nd Avenue, Suite 2700 

Miami, Florida 33131-1804 

Telephone: (305) 400-7500 

Facsimile: (305) 603-2552 

COUNSEL FOR DEFENDANT 

WHOLE FOODS MARKET I.P., L.P. 

 

Case 1:20-cv-22242-KMW Document 1-2 Entered on FLSD Docket 05/29/2020 Page 19 of 21
3 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on this 20th day of May 2020, a true and correct copy of the 

foregoing document was filed with the Clerk of Court by using the Florida Courts E-Filing Portal 

and served this day on all counsel of record identified on the attached Service List, either via 

transmission of Notices of Electronic filing generated by the Florida Courts E-Filing Portal or in 

some other authorized manner for those counsel or parties who are not authorized to receive 

electronically Notices of Electronic Filing. 

/s/ Alexandra Blanco Mangas 

Alexandra Blanco Mangas, Esq.

SERVICE LIST 

ATTORNEYS FOR PLAINTIFF 

Forrest Sygman, Esq. 

Florida Bar No. 748020 

E-mail: forrest@sygmanlaw.com 

Secondary: paralegal@sygmanlaw.com 

Marlene Collazo, Esq. 

Florida Bar No. 75330 

E-mail: associate@sygmanlaw.com 

FORREST SYGMAN, P.A. 

The Tate Building 

7300 N. Kendall Drive, Suite 450 

Miami, Florida 33156 

Telephone: (305) 661-8955 

ATTORNEYS FOR DEFENDANT 

Patrick G. DeBlasio, III 

Florida Bar No. 871737 

E-mail: pdeblasio@littler.com 

Secondary: btapia@litter.com 

Alexandra Blanco Mangas 

Florida Bar No. 106874 

E-mail: alblanco@littler.com 

Secondary: kljackson@littler.com 

LITTLER MENDELSON, P.C. 

Wells Fargo Center 

333 S.E. 2nd Avenue, Suite 2700 

Miami, Florida 33131-1804 

Telephone: (305) 400-7500 

Facsimile: (305) 603-2552 

4813-6689-6316.1 099817.1063 

Case 1:20-cv-22242-KMW Document 1-2 Entered on FLSD Docket 05/29/2020 Page 20 of 21
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

CASE NO. 2020-008685-CA-01 

JORGE UGARTE, 

Plaintiff, 

v. 

WHOLE FOODS MARKET I.P., L.P., 

Defendant. 

________________________________________/ 

AGREED ORDER 

THIS MATTER having come before the Court on Defendant Whole Foods Market I.P., 

L.P.’s Unopposed Motion for Enlargement of Time to Respond to Plaintiff’s Complaint, and the 

Court being otherwise duly advised, it is hereby: 

ORDERED AND ADJUDGED as follows: 

1. The Defendant’s Motion is GRANTED. 

2. Defendant shall have until June 5, 2020 to respond to the Complaint. 

DONE and ORDERED in Chambers at Miami, Florida on May ____, 2020. 

 

________________________________ 

ALAN FINE 

CIRCUIT COURT JUDGE 

Copies to: All Counsel of Record 

4850-7190-8540.1 099817.1063 

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