EXHIBIT 1

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

THOMAS DAY, :

:

Plaintiff, :

:

v. : Civil Action File No.: 

:

TCA FUND MANAGEMENT :

GROUP, CORP.; TCA GLOBAL : JURY TRIAL DEMANDED

CREDIT FUND, LTD.; :

ROBERT PRESS; :

ALYCE SCHREIBER; and :

WILLIAM FICKLING, :

:

Defendants. :

COMPLAINT

Plaintiff, through undersigned counsel, hereby files his Complaint against 

Defendants, showing the Court as follows:

Parties

1. Plaintiff Thomas Day (“Day”), at all times relevant to this case, was a 

resident of Georgia.

2. Defendant TCA Fund Management Group, Corp. (“TCA”), at all times 

relevant to this case, was the acting investment manager (“IM”) of the TCA Global 

Credit Master Fund (“GCMF” or “the Fund”), which is an alternative investment 

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fund with United States offices in Aventura, Florida and New York, New York and 

foreign offices in London, England and Sydney, Australia.

3. Defendant Robert Press (“Press”), at all times relevant to this case, was the

General Partner, Founder and President of TCA and handled the flow of cash 

between the Fund and TCA and personnel decisions. He is a resident of Florida.

4. Defendant Alyce Schreiber (“Schreiber”), at all times relevant to this case, 

was the acting CEO of TCA and, along with Press, handled the flow of cash 

between the Fund and TCA and personnel decisions. She is a resident of Florida.

5. Defendant William Fickling (“Fickling”) was TCA’s former head of 

corporate restructuring and, at all times relevant to this case, was TCA’s acting 

Chief Operating Officer (COO), and along with Press and Schreiber, handled the

flow of cash between the Fund and TCA and personnel decisions. He is a resident 

of Georgia.

Jurisdiction and Venue

6. This Court has federal question jurisdiction pursuant to 28 U.S.C. § 1331

over Count I of this Complaint, which arises out of the Dodd-Frank Act, 15 U.S.C. 

§ 78u-6(h).

7. This Court has supplemental jurisdiction pursuant to 28 U.S.C. § 1367 

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o ver Count II which arises under state law.

8. Venue is proper in this Court under 28 U.S.C. § 1391(b) because the

employment practices described herein occurred within the Miami Division of the

S o u t h e r n District of Florida.

Statement of Facts

TCA’s Fund Structure

9. TCA earns income through several revenue streams including incentive, 

commitment, execution, interest accruals, service, closing, management, 

performance, and other fees associated with its various funds (“the Funds”).

10. Upon information and belief, the Funds include: TCA Global Credit Fund 

GP, Ltd. (the general partner fund); TCA Global Credit Fund, LP (an onshore 

feeder fund); TCA Global Credit Fund, Ltd. (an offshore feeder fund, “GCF”);

TCA Global Lending, Corp. (a US tax blocking entity); and TCA Global Credit 

Master Fund, LP (the main fund, or “GCMF”); the Special Situations Credit 

Strategies ICAV (a fund registered in Ireland, or the “ICAV”); the TCA 

Opportunities Fund I, LP (“OPPS”); and the TCA Tamwheel UK LP (“TMWL”).

11. The GCMF is a direct lending fund in the alternative asset space that 

identified and made direct, asset-based loans ranging from approximately one to 

five million dollars in small and medium-size enterprises (“SMEs”).

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12. GCMF was TCA’s largest fund and the one where Plaintiffs principally 

worked. 

13. GCMF was managed by TCA and its administrator was Circle Partners.

14. TCA Global Credit Fund, LP and TCA Global Credit Fund Ltd (“GCF”)

were “feeder” funds that were invested in GCMF.

15. Plaintiffs and individual Defendants also worked with the ICAV Fund, 

which was formerly known as TCA Special Situations Credit Strategies and TCA 

Credit Strategies, is a Central Bank of Ireland chartered Irish Collective Asset 

Vehicle that is owned and operated by TCA and administered by APEX. 

16. The OPPS and TMWL funds are also, upon information and belief, operated 

by TCA.

17. Upon information and belief, the ultimate owner of the bank accounts for 

these Funds is a trust for the benefit of Press’ minor children and in which Press 

serves as the trustee.

Thomas Day’s Employment

18. Day was hired as TCA’s Chief Credit Officer (“CCO”) in January 2018 and 

assigned to new loan underwriting and possible investments within the GCMF.

19. In this role, Day was member of TCA’s executive leadership and 

management team responsible for a total credit portfolio of over $500 million with 

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expected annual originations of $180 million.

20. Day also formed TCA’s Credit and Investment Committees and served as its

Chairman.

21. In the scope of his professional duties, Day had access to information 

concerning TCA’s risk related policies and procedures, loan underwriting, 

portfolio administration, loan closings, cash disbursements, debt consolidation, 

working capital, loan portfolios, and ongoing transaction management. 

TCA Charged Borrowers Fees for Services Not Rendered

22. Upon information and belief, the Securities and Exchange Commission 

(“SEC”) conducted an examination covering the period 2014 through 2015 

resulting in a findings memo signed by SEC Assistant Regional Director Jeannie 

Cabot and issued to TCA on March 3, 2016 that uncovered, among other things, 

accounting irregularities composed primarily of recording deals prior to loan 

closing to inflate their assets under management (“AUM”).

23. Upon information and belief, beginning in 2017, Defendants attempted to 

circumvent SEC detection and continued to inflate their AUM and offset losses by 

devising a new fraudulent scheme using Investment Banking Services Agreements 

(IBSAs). 

24. In addition to being responsible for paying a commission if their loans were 

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funded, TCA’s potential borrowers were required to sign a “non-binding” term 

sheet that required the borrower to pay an execution fee, among other fees.

25. In almost every case until mid-2019, potential borrowers were 

simultaneously asked to sign a “binding” IBSA which was “considered due and 

payable upon execution.”

26. For example, a typical loan application for a borrower might include a 

potential loan of $2.5 million with an IBSA between $500,000 and two million, 

meaning that the loan’s interest rates, inclusive of the fee agreement(s), were 

effectively 40 to 50 percent, or higher.

27. Day repeatedly told Defendants Fickling and Press that TCA (which 

employed no investment banker and was not a registered broker-dealer) needed to 

hire an investment banker if IBSAs were going to be applied to potential 

transactions and even provided resumes for possible candidates.

28. No investment banker was ever hired, and, in early to mid-2019, TCA recharacterized the IBSAs as “Financial Consulting Fee Agreements.” 

29. After signing the term sheet and fee agreements, borrowers’ loans went to 

underwriting to determine if they were viable for funding.

30. The default rate on the IBSAs was over 95 percent because the majority of 

borrowers refused to pay for investment banking services they did not receive, or 

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investment banking services associated with a loan that was not closed. 

31. Defendants falsified records, such as invoices and scopes of work stating 

that TCA provided investment or consulting services to these borrowers.

32. For those loans that did close, Defendants “wrapped” the IBSA fees into the 

loans themselves, making it appear as though the borrowers paid the IBSA fees, 

regardless of whether or not they did, and charged borrowers interest on the 

wrapped fees thereby inflating accrual income.

TCA Reported Income from Borrower Fees It Did Not Receive

33. Although TCA did not actually render services for these fees, or receive 

payment for them, it continued to report a large and growing volume of IBSA “fee 

receivables” on its balance sheet.

34. For example, in 2017, TCA reported $59 million in IBSA deals, but only 

$30 million (or 50.8 percent) of these deals had an associated loan closing.

35. Nevertheless, in the same year (2017), the $29 million worth of the IBSA

deals that did not receive funding/loans remained on TCA’s balance sheet as IBSA

fee receivables (or “orphaned” fees unrelated to any underlying loans) resulting in 

an inflated AUM. 

36. The same pattern worsened in 2018, with TCA reporting $61 million in 

IBSA deals while only funding $6.4 million (or 10.5 percent) in loans and leaving 

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over $55 million in “orphaned” fees.

37. Once again, in 2019, TCA reported $39 million in IBSA deals while only 

$575 thousand (or 1.5 percent) in loans were funded, leaving $38.6 million in 

“orphaned” fees. 

38. Ultimately, TCA reported $178 million of IBSA income for the period of 

October 2016 through November 2019. 

TCA Falsely Reported Income to Inflate its Overall Income and Performance

39. Notably, for thirty-three of the thirty-eight months from October 2016 

through November 2019, IBSA reported income exceeded net income.

40. Indeed, during the tenure of Patrick Primavera—the managing director of 

TCA’s New York Office, which originated the IBSAs, and who ultimately 

resigned in August 2019—net income was higher than IBSA income only once

from October 2016 through July 2019. 

41. The four months following Primavera’s resignation, August 2019 through 

November 2019, fewer new IBSAs were reported, and, as a result, reported net 

income exceeded IBSA income for these four months.

42. Plaintiffs believe that, without the IBSA income (which is a component of 

net income), TCA’s aggregated net income during the entire period from October 

2016 through November 2019, would have been negative.

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43. Consequently, Plaintiffs believe that Defendants knew they could not collect 

income from the IBSAs but continued to use them, and report them as income, to 

manufacture sources of income that would circumvent SEC and auditor scrutiny 

under generally accepted accounting principles and international accounting 

standards. 

44. By using these methods to inflate TCA’s income, Defendants could then add 

the unrealized IBSA income to their monthly net asset value calculations (“NAV”)

and AUM and continue to report positive returns to investors, while masking the 

fact that: the majority of TCA’s borrowers were in default; TCA’s cash flow was 

low; and GCMF was experiencing negative months.

45. For example, TCA’s November 2019 NAV reflected AUM of $516 million, 

which equates to IBSA receivables comprising 34 percent.

46. However, these IBSA receivables do not reflect loans that actually closed 

and where the IBSA fees were “wrapped” into the principal loan balance and 

subsequently charged interest. 

47. Day estimates that “wrapped” fees at end of 2017 amounted to $57.9 

million, or 30 percent of then outstanding principal. 

48. As a result, Plaintiffs estimate that between 40 to 60 percent of AUM, or 

between $207.6 million to $309.6 million, was fraudulently misstated, between

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2017 and 2019 period as a direct result of fraudulent IBSA fee reporting and 

related accounting.

TCA’s Inflated Income Forms the Basis for Reporting Performance and 

Management Fees

49. In addition to IBSA fees, TCA reported incentive fees for performance and 

management, or additional fees received by TCA that are contingent on a positive 

overall performance.

50. Without the IBSA income, the net income would be negative, and no 

incentive fees would be available.

51. Nevertheless, because TCA continued to falsely report IBSA fee income that 

inflated their NAV and AUM, it misrepresented to investors and regulators that 

TCA was performing positively, and incentive fees were payable. 

52. From October 2016 through November 2019, TCA reported total 

performance fees of approximately $27.5 million and total management fees of 

approximately $28.5 million.

53. In the months during this period, where TCA reported IBSA fees exceeding 

net income, TCA reported $24 million in performance fees and $6.55 million in 

management fees.

54. Notably, these incentive fees were substantially lower between August and 

December 2019, when net income exceeded IBSA income and TCA reported 

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negligible management fees and $3.5 million in performances fees, of which IBSA

income accounted for approximately $1.66 million. 

55. Although TCA waived incentive fees totaling $11.4 million between

October 2016 and November 2019, approximately $9.16 million were waived 

during months where net income was lower than IBSA income.

Defendants Attempt to Evade Day’s Increased Underwriting Scrutiny

56. After Day was hired and introduced more robust underwriting standards—

requiring that borrowers must be able to service the loan debts and related fees—

virtually all new loan production ceased in 2018. 

57. Day estimates that, under his direct supervision, only six or seven loans 

closed in 2018 and the same number of loans closed in 2019.

58. This means that, between 2018 and 2019, less than ten percent of borrowers 

actually secured loans, and services (for which some proportion of the IBSA would 

be collectible) were only rendered to borrowers in four or five exceptional cases.

59. Once it became clear to Day that TCA was reporting fee receivables for 

loans that were not funded (and would not generate any fees or result in default), 

he refused to accept these fees as part of the underwriting procedures.

60. On numerous occasions, Day informed Fickling and Press that TCA could 

not report fees for these loans, but was falsely assured that they had corrected the 

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same. 

61. On one occasion, during a business dinner when Day asked Press for

clarification about TCA’s IBSA practices, Press accused Day of being an 

informant, seeking to “entrap” him and of wearing a wire before storming out.

62. Instead of addressing Day’s concerns, fees continued but omitted in new 

underwriting packages, resulting in more orphaned IBSAs.

63. Further, Press used the law firm Lucosky Brookman, in which Press’

brother-in-law, Seth Brookman is a named partner, to facilitate the closing of loans

and related fee agreements. 

64. In several of these closings, Brookman served as the closing counsel for

TCA Group while his partner, Joe Lucosky, served as counsel for the borrower.

65. None of these closings were presented to Day or TCA’s Credit and 

Investment Committee (TCIC).

66. Indeed, Primavera’s replacement, and the new Managing Director of TCA’s 

New York office, William Haemmerle, admitted to Day that he would not have 

approved these transactions but for Press’ insistence that they close before the end 

of 2019. 

TCA’s Audit Threatens to Reveal its Inflated Assets and Fraud 

67. Grant Thornton was retained for TCA’s fiscal year end audits from 2017 

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through 2019.

68. Like Plaintiffs, Thornton was highly skeptical of the 2018 results and sought 

to investigate the IBSAs.

69. To avoid this and cast its accounting irregularities as inadvertent, TCA 

admitted to an accounting error.

70. Nevertheless, in November 2019 auditors sought information on what 

portion of the outstanding 2018 IBSA balance has been collected throughout 2019. 

71. In fact, upon information and belief, Thornton had 42 open issues, 11 of 

which related to the IBSA fee fraud.

72. In preparing for the 2019 audit, Plaintiffs recognized that TCA had very few 

performing assets (approximately 30) despite reporting around $500 million in 

AUM. 

73. TCA’s published November 2019 NAV reported an AUM of $516 million. 

74. As of November 2019, Plaintiffs believed that IBSAs accounted for over 

$207 million of the AUM, of which $178 million is reported IBSA income and the 

remainder are loans with “wrapped” IBSA fees.

75. In addition to the IBSAs, Plaintiffs believe an additional 25 to 35 percent of 

TCA’s $516 million AUM is non-performing, meaning the true value of the AUM 

would be closer to $150 million.

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76. In early January 2020, Plaintiffs estimated that GCMF had around $60 

million in performing assets, yielding around 16 percent, or $9.6 million per 

annum (the “true yield”).

77. As a result, TCA’s gross return as a percentage of its AUM, without IBSAs, 

equates to 1.92 percent, before expenses.

78. Nevertheless, TCA consistently reported a yield of seven to eight percent in 

its monthly NAV and investor newsletters. 

79. The variance between TCA’s purported seven to eight percent net annual 

return and TCA’s actual 1.92 percent gross annual return is largely attributable to

the IBSAs reported as “income.”

80. On February 28, 2020, Defendants claimed they were winding down GCMF.

Defendants’ Attempt to Evade Detection and Investor Redemptions by 

Commingling Assets and Liabilities Between Separate Domestic and International 

Funds

81. Upon information and belief, beginning in 2018 and prior to the purported 

GCMF wind-down, Defendants used the commingled monies between the foreign

ICAV and domestic GCMF to effectuate fraudulent transactions between the two 

funds.

82. For example, TCA created invoices each month for monthly services fees 

but did not send them to the invoiced companies and, consequently, the companies 

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were unaware of did not pay for service fees.

83. Instead, TCA sent “copies” of these purported invoices—some of which

were part of the GCMF portfolio—to the ICAV Fund Administrator, APEX, as 

proof of revenue to be reported as “fee income receivable.”

84. To the extent that these invoices were paid at all, they were paid from 

GCMF’s IM bank account, pursuant to a supposed fraudulent “servicing 

agreement” between the ICAV and the GCMF. 

85. Defendants also commingled ICAV and GCMF investor funds. 

86. For example, in 2019, fees were reported to the GCMF, but the direct loan 

was never funded by the GCMF, it was funded by the ICAV. 

87. Plaintiff believes that Defendants commingled money between the ICAV 

and GCMF largely so that the GCMF could pay redemptions to investors when it 

lacked sufficient liquidity to do so from its own fund. 

88. Upon information and belief, Defendants sought to use the ICAV to avoid 

SEC detection, diverting the remaining assets of the GCMF, and it continues to 

operate; with TCA employees receiving bonuses and remaining employed even as 

the GCMF purportedly winds down.

Plaintiff’s Protected Activity

89. On December 24, 2019, Day submitted information on the SEC’s Tips, 

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Complaints, and Referrals (“the TCR”) system regarding conduct at TCA. 

90. On January 7, 2020, Day sent an email (“the Notification”) notifying TCA, 

its directors, officers and other upper management personnel that he had filed the 

TCR and which also stated, in pertinent part:

We have attempted to escalate our concerns, and seek 

remedial action, regarding the scale, scope and 

complexity of these matters by way of discussions with 

TCA Fund Management Group Corp Chairman and 

Founder Robert Press, Acting COO William Fickling, and 

Acting CEO Alyce Schreiber. No adequate action has 

been taken by notified personnel to address our collective, 

material, and on-going concerns. 

In light of these areas of misconduct, and consistent with 

professional standards, compliance rules, and other legal 

and ethical obligations, this letter is being sent to all 

Board members, the head of investor relations, the head 

of TCA compliance, Executives and Officers, and others 

as deemed appropriate by us and our counsel. 

Also, given involvement in certain investor and audit 

meetings, and reliance on assertions of Mr Press, we are 

concerned that there may have been representations made 

to investors and/or auditors that are erroneous, and, 

therefore, a need to inform them of our on-going material 

concerns. We are asking permission to inform them, so 

please advise. We believe we have a fiduciary duty to 

these current and prospective investors, as well as the 

current auditors.

91. The Notification included the contact information for the undersigned, as 

well as Plaintiffs’ SEC counsel.

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Defendants’ Retaliation

92. A few hours after Day sent Notification, Bruce Wookey, TCA’s Independent 

Lead Director of TCA’s Board, emailed Day demanding copies of the TCR and 

informing him that he would have his email and other connections to TCA disabled. 

93. In the same email, Wookey also made a reference to the health and welfare of 

Day’s daughter which Day found to be inappropriate, given the context of the 

emails, and a veiled threat.

94. When Day responded that Wookey should speak to the undersigned counsel, 

Wookey refused to do so until Day provided him with a certified copy of the TCR. 

Wookey informed him that the Notification was “grounds for dismissal & damages. 

Access to TCA resources can now, and will be withdrawn.”

95. Subsequently, Plaintiff’s email and network access were withdrawn.

96. Without system access, Plaintiff was locked out of work.

97. On January 16, 2020, counsel for TCA confirmed that Plaintiff “[is] on full 

paid leave pending our investigation into the allegations.” 

98. On February 5, 2020, counsel for Plaintiff informed TCA’s counsel that this 

action constituted retaliation under the Dodd-Frank Act, 15 U.S.C. § 78u-6(h).

99. On February 28, 2020, by a letter to Plaintiffs’ counsel, TCA terminated 

Plaintiff.

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Damages

100. Had Plaintiff been permitted to remain employed at TCA—with full access 

to the tools necessary to perform his job—he would not only have received his 

salary, but would also have been eligible for 2019 bonuses and benefits such as 

retirement contributions and employer-sponsored health insurance for himself and 

his family.

101. As a result of Defendants’ conduct, Plaintiff’s career has been derailed. He 

has and will continue to suffer lost wages and loss of other employment-benefits 

such as bonuses, health insurance, and retirement contributions.

102. The conduct of Defendants has caused Plaintiff extraordinary emotional 

distress, emotional pain and suffering, inconvenience, humiliation and 

embarrassment.

103. As a result of Defendants’ conduct, Plaintiff has incurred not only the 

aforementioned damages but other damages, such as pre-paid childcare expenses, 

job search expenses, attorneys’ fees and related expenses.

COUNT I: RETALIATION IN VIOLATION OF THE DODD-FRANK ACT

104. Plaintiff reasserts and incorporates the preceding Paragraphs of this

Complaint as if fully set forth herein.

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105. Under the Dodd-Frank Act, 15 U.S.C. § 78u-6(h), no employer may 

discharge, demote, suspend, threaten, harass, directly or indirectly, or in any other 

manner discriminate against, a whistleblower in the terms and conditions of 

employment because of any lawful act done in making disclosures that are 

protected under the Sarbanes-Oxley Act of 2002, 15 U.S.C. § 7201 et seq.

106. Defendants took adverse action against Plaintiff because of his reports of 

conduct that violates Section 17(a) of the Securities Act of 1933, 15 U.S.C. § 77q, 

Section 10(b) of Securities Exchange Act of 1934, 15 U.S.C. § 78j; and Rule 10b-5 

of the Securities Exchange Act, 17 C.F.R. § 240.10b-5; Sections 206(1-2) and (4) of 

the Investment Advisers Act of 1940, 15 U.S.C. §§ 80b-6(1-2) and (4), 80b-7, and 

Adviser’s Act Rules 206(4)-7-8, 17 C.F.R. §§ 275.206(4)-7-8.

107. Defendants retaliated against Plaintiff for the same by preventing him from 

accessing the tools necessary for him to perform his job, placing him on indefinite 

administrative leave, withholding compensation, and, ultimately, terminating him.

108. Defendants’ retaliatory conduct has adversely affected Plaintiff’s

employment.

109. Defendants’ retaliatory conduct might have dissuaded a reasonable person

from making or supporting a report. 

110. The unlawful employment practices complained of above were intentional 

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and were performed by Defendants with malice or reckless indifference to the 

Dodd-Frank Act. 

111. As a direct and proximate result of Defendants’ illegal conduct, Plaintiff has

suffered, and continues to suffer, emotional distress, humiliation, embarrassment, 

pain and suffering, loss of reputation, loss of enjoyment of life, lost wages and 

benefits, and has incurred attorneys’ fees and expenses and other serious damages. 

COUNT II: Retaliation in Violation of Florida Whistleblower Act

112. Plaintiff reasserts and incorporates paragraphs 1-103 of this Complaint as if

fully set forth herein.

113. By questioning, refusing to adhere to, and seeking to correct TCA’s 

accounting and underwriting practices, Plaintiff objected to or refused to participate 

in Defendants’ conduct which was in violation of, or which Plaintiff reasonably 

believed was in violation of laws, rules or regulations including but not limited to: 

Section 17(a) of the Securities Act of 1933, 15 U.S.C. § 77q, Section 10(b) of 

Securities Exchange Act of 1934, 15 U.S.C. § 78j; and Rule 10b-5 of the Securities 

Exchange Act, 17 C.F.R. § 240.10b-5; Sections 206(1-2) and (4) of the Investment 

Advisers Act of 1940, 15 U.S.C. §§ 80b-6(1-2) and (4), 80b-7, and Adviser’s Act 

Rules 206(4)-7-8, 17 C.F.R. §§ 275.206(4)-7-8.

114. By filing a TCR, Plaintiff disclosed to the SEC that he believed Defendants

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were in violation of multiple laws, rules, or regulations including but not limited to 

those identified in paragraph 118, above.

115. By continuing to provide the SEC with information related to the TCR, 

Plaintiff participated in a SEC investigation or inquiry into TCA which eventually 

became the basis for an enforcement action by the SEC. See SEC v. TCA Global 

Management Group Corp., et al., 1:20-cv-21964 (S.D.Fla. May, 11 2020).

116. When Plaintiff informed Defendants that they he filed the TCR, Defendants 

immediately subjected him to adverse employment actions by preventing him from 

accessing the tools necessary for him to perform his job, placing him on indefinite 

administrative leave, withholding compensation, and, ultimately, terminating him.

117. The actions of Defendants constitute unlawful retaliation in violation of the 

Florida Whistleblower Act (“FWA”), Fla. Stat. §§ 448.102(1-3).

118. As a result, of Defendants’ unlawful actions, Plaintiff has suffered emotional 

distress, inconvenience, humiliation, and other indignities.

119. As a result of Defendants’ violation of the FWA, Plaintiff is entitled to 

recover lost wages, benefits, compensatory damages, as well as equitable and 

injunctive relief, and reinstatement to the same position held before the retaliatory 

personnel action, or to an equivalent position and reinstatement of full fringe 

benefits and seniority rights.

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120. Plaintiff seeks an award of reasonable attorney's fees, court costs, and 

expenses pursuant to F.S. §448.104.

Prayer for Relief

WHEREFORE Plaintiff respectfully prays for relief as follows:

A. For a trial by jury;

B. For a finding that Defendants violated Plaintiff’s rights as set forth herein;

C. For a judgment in Plaintiff’s favor for full front and back pay; compensatory 

damages for emotional distress; compensatory damages for loss of reputation, 

wages, and benefits; consequential damages; punitive damages; attorney fees, and

litigation costs;

D. Any such other and further relief as the Court deems proper and just.

JURY DEMAND

Plaintiffs request a jury trial on all questions of fact raised by this

Complaint.

[SIGNATURE BLOCK ON NEXT PAGE]

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Respectfully submitted this 28th day of February, 2022.

BUCKLEY BEAL, LLP

 s/ Edward D. Buckley

 Edward D. Buckley

 Pro Hac Vice Pending

 Georgia Bar No. 092750

edbuckley@buckleybeal.com

600 Peachtree Street NE, Suite 3900

Atlanta, Georgia 30308

Telephone: (404) 781-1100 

Facsimile: (404) 781-1101

HESS LAW FIRM

s/ Ephraim R. Hess

Ephraim Roy Hess

Florida Bar No. 983100

erh@thehessfirm.com

erhpalaw@gmail.com

205 Davie Boulevard

Fort Lauderdale, Florida 33315

Telephone: (954) 585-8599

 Attorneys for Plaintiff

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