Complaint

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UNITED STATES DISTRICT COURT

Southern District of Florida

Broward Division

CASE NO.: 20-CV-61047-RAR

PAUL RITCHIE,

an individual,

Plaintiff,

v.

MATTHEW A. DOLMAN, P.A.,

d/b/a DOLMAN LAW GROUP, and

d/b/a DOLMAN LAW GROUP

ACCIDENT INJURY LAWYERS PA,

a Florida for-profit corporation;

SIBLEY DOLMAN 

PERSONAL INJURY LAWYERS, LLP,

a Florida limited partnership;

SIBLEY DOLMAN 

PERSONAL INJURY LAWYERS,

a Florida general partnership;

SIBLEY LAW, P.A.,

a Florida for-profit corporation, and;

SIBLEY DOLMAN

PERSONAL INJURY LAWYERS, P.A.,

a Florida for-profit corporation

administratively dissolved,

Defendants.

___________________________________/

VERIFIED SECOND AMENDED COMPLAINT FOR

DAMAGES, DECLARATORY AND INJUNCTIVE RELIEF

AND DEMAND FOR JURY TRIAL

Plaintiff, PAUL RITCHIE, through his undersigned counsel, sues the above-named 

Defendants and submits a Second Amended Complaint as follows:

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JURISDICTION AND VENUE

1. This is an action for: Age Discrimination in Employment (29 U.S.C. §§ 621 to 634);

Violation of the Florida Civil Rights Act of 1992 (FCRA) prohibiting age discrimination in the 

workplace (Fla. Stat.§760.10(1)(a)); Unlawful Retaliation Fla. Stat. §448.102; Breach of 

employment contracts; Misclassification of Employee as an independent contractor under Florida 

Common Law and the Fair Labor Standards Act (29 U.S.C. 201, et seq.); Statutory 

Misappropriation of Image (Fla. Stat. §540.08); Florida Common Law - Unauthorized Use of 

Likeness, and; Florida Common Law - Restitution (Quantum Meruit/Unjust Enrichment).

2. This Court has subject matter jurisdiction under 28 U.S.C. § 1331 (Federal Question) 

and supplemental jurisdiction under 28 U.S.C. §1367 to hear additional Florida State claims 

substantially related to the original claim(s).

3. Venue is proper pursuant to 28 U.S.C. §1391 because a substantial part of the events or 

omissions giving rise to the claim(s) occurred in Broward County, Florida and the Defendants are 

Florida entities with sufficient contacts subjecting them to personal jurisdiction in this District.

EXHAUSTION OF ADMINISTRATIVE REMEDIES

4. On or about Feb 7, 2020 Plaintiff Paul Ritchie filed a charge with the Equal Employment 

Opportunity Commission regarding the defendants’ alleged discriminatory conduct.

5. The Equal Employment Opportunity Commission issued a Notice of Right to Sue letter, 

attached as Exhibit A, mailed via Certified U.S. Postal Service by the EEOC. The tracking number 

is 70192280000047003298. It was received at Plaintiff Paul Ritchie’s mail drop (PakMail) and 

signed for by an employee at that business. Therefore, Paul Ritchie cannot presently specify the 

exact date of receipt. Additionally, the USPS tracking report does not indicate the date of delivery.

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6. The USPS tracking report indicates that it was mailed on February 26, 2020, was in 

transit to another USPS facility on February 27, 2020 and still in transit to yet another USPS facility 

on March 2, 2020. See attached Exhibit B, USPS Tracking Report. According to the United 

States Postal Service tracking report, it would have been impossible for Paul Ritchie to have 

received the “Right to Sue” letter prior to March 2, 2020. The ninety-day deadline counting from 

March 2, 2020 is May 31, 2020. The Complaint was filed on May 28, 2020. The filing of the 

Complaint is timely because it was filed within 90 days of receipt of the Notice of Right to Sue.

PARTIES

7. Plaintiff PAUL RITCHIE is 69 years of age, a resident of the State of Florida and 

otherwise sui juris.

8. Defendant MATTHEW A. DOLMAN, P.A., d/b/a DOLMAN LAW GROUP, and d/b/a 

DOLMAN LAW GROUP ACCIDENT INJURY LAWYERS PA, is a Florida for-profit 

corporation with its principal office located at 800 N. Belcher Road Clearwater, FL 33765 whose 

Registered Agent is Rebecca Dolman located at the same address. 

9. Defendant SIBLEY DOLMAN PERSONAL INJURY LAWYERS, LLP is a Florida

limited partnership filed on 10/29/2018 whose Registered Agent is Brent Sibley at 20807 Biscayne 

Blvd Suite 100 Aventura, FL 33180.

10. Defendant SIBLEY DOLMAN PERSONAL INJURY LAWYERS is a Florida general 

partnership filed on 10/29/2018 whose Registered Agent is Brent Sibley at 20807 Biscayne Blvd 

Suite 100 Aventura, FL 33180.

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11. Defendant SIBLEY LAW, P.A., is a Florida for-profit corporation with its principal 

office located at 20807 Biscayne Blvd Suite 100 Aventura, FL 33180 with Brent Sibley as its 

Registered Agent.

12. Defendant SIBLEY DOLMAN PERSONAL INJURY LAWYERS, P.A., is a Florida 

for-profit corporation formed on April 11, 2018 and administratively dissolved on September 29,

2019. Registered agent is Brent Sibley at 20807 Biscayne Blvd Suite 100 Aventura, FL 33180.

13. All above named Defendants are related and intertwined through consolidation, merger 

and/or common ownership and control and have otherwise abrogated their separate identities

and/or acted in concert and/or are successors in interest.

14. All Defendants named herein are highly integrated with respect to ownership and 

operations and constitute a single employer or integrated enterprise. All Defendants are therefore 

referred to collectively as “Sibley Dolman” herein.

15. Sibley Dolman, as referenced herein, employs 20 or more employees.

FACTS

16. Paul Ritchie graduated law school in 1987 and the next year opened a solo personal 

injury practice in Washington State. In 1994 he stipulated to disbarment after diverting client 

settlement funds to aid a military colleague. Paul was convicted of felony theft. After completing 

a prison sentence and statutory release of all legal financial obligations, Paul Ritchie exclusively 

serves licensed attorneys an experienced paralegal.

17. Beginning in June 2016, Florida attorney Brent Sibley (Sibley Law, P.A.) engaged 

Paul Ritchie for assistance with various cases. Paul Ritchie promptly and fully disclosed his 

background to Brent Sibley.

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18. On or about March 2017, Sibley provided a private office, computer and telephone for 

Paul Ritchie at the same office building where Sibley and his regular employees operated the firm 

of Sibley Law, P.A.. With Sibley’s knowledge and consent Paul Ritchie continued to work on 

matters for other attorneys and remained a free-lance paralegal in that respect. Although, Ritchie 

was now paid a regular flat monthly amount for all work required by Sibley.

19. At all material times hereto Sibley, as an owner and supervising attorney, exercised 

control over all aspects and details of Ritchie’s work and scheduled assignments. Ritchie’s work 

was part of the regular business of the employer.

20. On or about July 2017, Sibley offered, and Paul Ritchie accepted the role of Chief 

Operations Officer for the Sibley Law firm.

21. At that time Sibley and Paul Ritchie entered into an oral agreement whereby, Paul 

Ritchie would be allowed to temporarily continue his free-lance paralegal services for other 

attorneys until Sibley Law firm, and the envisioned “Sibley Law Group,” could support him 

exclusively. In consideration of Paul Ritchie eventually devoting all his time, management 

expertise and various creative talents, it was agreed between Paul Ritchie and Sibley that this 

position and arrangement would become exclusive, full-time and endure for as long as Paul Ritchie 

desired.

22. On or about September 2017, Sibley Law moved out of the office building in 

Hollywood, Florida. It was agreed that Ritchie also move and would lease his own office in a Fort 

Lauderdale building also occupied by a bankruptcy attorney for whom Paul Ritchie performed 

paralegal services.

23. Otherwise, the arrangement and plan for work and compensation between Sibley Law

and Paul Ritchie remained the same while utilizing internet communications and document 

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systems set up by Sibley. Sibley also provided computer monitors and telephone equipment to 

Paul Ritchie.

24. Paul Ritchie’s ongoing services to Sibley Law, P.A. included client intake interviews,

preparing demand presentations for complex and high value personal injury cases, and legal 

research and writing.

25. Paul Ritchie, in consideration of the promise of secure lifelong employment, provided 

expertise in numerous areas like operational and organizational management. Ritchie developed 

the litigation workflow and filing system. He assumed responsibility for organizing and 

conducting quarterly staff meetings, creating presentations and providing training of employees. 

Ritchie also assisted Sibley in conducting weekly staff meetings for the growing firm. And, Paul 

Ritchie commenced work on a new website including creating artwork, graphics and designing a 

website architecture.

26. On April 11, 2018 Brent Sibley merged his practice with that of Matthew Dolman and 

formed “Sibley Dolman Personal Injury Lawyers PA.”1

 The principals of that firm are believed 

to be Attorneys Mathew Dolman, and Brent Sibley, (age 42 and 38 respectively at that time).

27. Brent Sibley announced to Ritchie in the summer of 2018, a plan that Sibley Dolman 

would soon open an office at North Miami Beach.

28. Consistent with the earlier agreement between Paul Ritchie and Sibley, it was agreed 

that Paul Ritchie would begin to terminate his working relationships with other attorneys and 

devote all his time and talent exclusively to the Sibley Dolman firm.

1 Other entities were formed under the “Sibley Dolman” banner in October 2018 and are included as Defendants 

because their present legal status and relationship appear to be intertwined and not distinct. Upon information and 

belief, Matt Dolman and Brent Sibley are principals in all entities bearing the “Sibley” and/or “Dolman” names.

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29. In July 2018 pursuant to, and relying upon, the agreement between Paul Ritchie and 

Brent Sibley which included employment for as long as Ritchie desired, Paul Ritchie gave his 

landlord notice to terminate his Fort Lauderdale office lease effective September 1, 2018. And 

Paul Ritchie terminated ongoing work relationships with other attorneys, including a thriving 

bankruptcy attorney.

30. On or about September, 2018, Brent Sibley held a meeting with Paul Ritchie and his 

wife, Raquel Ritchie, at Turnberry Isle Country Club. Consistent with their agreement, Sibley at 

that time granted Paul Ritchie a raise in monthly pay based on his now exclusive relationship with

Sibley Dolman.

31. It was agreed that Paul Ritchie would work from his home office via Sibley Dolman’s 

internet communications, management systems, and equipment, except for in-person meetings as 

required.

32. During the period from September to November 2018, Paul Ritchie set up the Sibley 

Dolman office in North Miami Beach at the request of Brent Sibley which was beyond his expected 

job duties and entailed countless hours and talent.

33. Paul Ritchie created the office design including layout, furnishings, equipment and 

décor.

34. And, Paul Ritchie designed a new company logo for Sibley Dolman, which is still used 

by the firm in its public advertising.

35. Paul Ritchie supervised installations of signage, designed by Ritchie, as well as 

electronics and internet service.

36. Paul Ritchie shopped, selected, transported and assembled furniture, electronics and a 

beverage bar. Ritchie’s provided equipment including a refrigerator, coffee maker and microwave 

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oven at his own (unreimbursed) expense. Paul transported and disposed of unwanted furniture left 

by a previous tenant. He painted/wallpapered the entire office, conference and reception areas. 

These efforts were accomplished after normal hours and on weekends to make ready for the next 

quarterly employee meeting.

37. The effort and contributions of time, talent and material by Paul Ritchie were above 

and beyond the agreed job duties, performed on his own time and, were based on the secure longterm employment relationship promised by Brent Sibley to remain for as long as Paul Ritchie 

desired.

38. On or about December 10, 2018 Matthew Dolman hired Patrice Altine, age 37, into 

the Sibley Dolman firm.

39. On or about January 2019, Altine was given responsibility for certain operational 

duties previously performed by Paul Ritchie including client intake, demands to insurance 

companies and transfer of client files to the “ATO” operational system used by Dolman Law 

Group.

40. On or about January 2018 Ritchie was instructed by Brent Sibley to join in a video 

shoot with Matthew Dolman and Sibley. The purpose, as Sibley explained to Ritchie, was to create 

footage depicting the top three key people (Sibley, Dolman and Ritchie) of the Sibley Dolman firm 

engaged in active discussions.

41. Publication plans for the video were not discussed or disclosed to Ritchie.

42. Paul Ritchie was never provided an opportunity to review or approve any use of video 

footage of his image prior to any publication. Nor did Paul Ritchie grant permission for 

publication. This contrasts with a previous video wherein employees of Sibley Law firm endorsed 

a product called Practice Panther. Paul Ritchie consented to video recording in that instance as 

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well. Before publication, Paul Ritchie was allowed to review the final promotional video and 

approve use of his image in publication. In that video, Paul Ritchie was properly identified, and 

his image was used in the context originally represented. That was not the case with the Sibley 

Dolman promotional video that is the subject of this action.

43. Paul Ritchie did not execute any release, oral or written, for publication of his image 

or likeness by Sibley Dolman.

44. On or about January 2019, Michaela J. Sprague, age 45 at that time, was hired at the 

Clearwater office of Sibley Dolman as a paralegal to assume duties over cases previously under 

the purview of Paul Ritchie.

45. Michaela J. Sprague had been convicted of theft and her sentence was determined in 

late 2018 after probation was revoked for violation. (Pinellas County case No. 18-00076-MM). 

Ms. Sprague had also been convicted of obtaining property in return for worthless check, again 

with probation violation. (Pinellas County case No. 0421797MMANO, 2004).

46. In March 2019, Ritchie requested a meeting with Sibley to discuss management issues, 

particularly the re-assignment of responsibilities that would have previously fallen to Ritchie. 

Ritchie expressed to Sibley that he was feeling like a “mushroom” (kept in the dark and fed B.S.)

since the hire of Patrice Altine and Michaela Sprague.

47. At Gulfstream Park on March 15, 2019 Brent Sibley told Paul Ritchie that Matthew

Dolman and his wife Rebecca Dolman (principals in Dolman Law Group and Sibley Dolman) had 

discussed Ritchie’s continued employment with Sibley. Sibley reassured Ritchie that his 

employment status remained secure and would continue for as long as Ritchie desired.

48. Plaintiff Paul Ritchie was consistently complimented, and paid bonuses based on his 

performance for Sibley Dolman.

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49. On March 26, 2019 Brent Sibley asked Paul Ritchie to come early to a staff meeting 

scheduled for that same day. Upon the Ritchie’s arrival, Sibley arranged to be alone with Paul 

Ritchie.

50. Sibley then notified Paul Ritchie that his employment was terminated upon order of 

Matthew Dolman. Sibley indicated that he had known of Dolman’s directive for several days.

51. Paul Ritchie continued to be paid thru the month of April 2019 and asked to remain 

available if called upon, but was essentially relieved of all duties.

53. All electronic and communications equipment belonging to Sibley was returned from 

Ritchie’s home office. And, the Ritchie signed out of all communications systems such as SibleyLaw.com email accounts, Slack, and Trello accounts as well as What’s App and the like.

54. Unbeknownst to Paul Ritchie, a promotional marketing video depicting the image and 

personality of Paul Ritchie had been published on the internet by Sibley Dolman just days before

Ritchie was terminated, but after Matthew Dolman purportedly made the decision to fire Paul 

Ritchie and communicated that to Brent Sibley.

55. Continuously since that date, and despite written objection by Paul Ritchie, that video 

and others containing Ritchie’s identifiable likeness have been promulgated by Sibley Dolman 

over the internet on various platforms in direct promotion of Sibley Dolman law firm for the 

commercial purpose of selling legal services to new clients.

56. By use of editing, some of the videos improperly suggest that Paul Ritchie is associated 

with insurers or insurance defense firms or adjusters. The audience could easily believe, as perhaps 

intended, that the image of Paul Ritchie is that of an adversary to the Sibley Dolman firm and its 

clients and is defamatory by implication, or presents Paul Ritchie in a false light. It does not depict 

Paul Ritchie in any manner to which he would have consented.

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57. The video published just after Matthew Dolman made the decision to discharge Paul 

Ritchie contained the following audible narrative boasting of a very young workforce as part of 

why potential clients should select the Sibley Dolman firm: “People want response times that are 

much quicker than they were before. And that's what we strive to provide our clients. We have a 

very young, modern workforce, we’re available, we’re connected, it’s all hands on deck when we 

go to trial.” (emphasis added) The promotional video appears on the internet at 

https://sibleydolman.com/ and at https://www.youtube.com/watch?v=gpmbNGbr7N8&t=76s 

(02:05 minutes into the video.) See Exhibit C attached hereto.

58. Indeed, Sibley Dolman makes good on their expressed intent to deliberately maintain 

a “very young workforce.” Information in the public domain reveals the average age of a Sibley 

Dolman employee, including lawyers, is 36.7 years. A list of Sibley Dolman staff is below:

Sibley Dolman Staff Age

Alex Knapp, Atty. 41

Alexandra Aimilia Veakis 24

Alicia M Winterkorn 29

Brent F. Sibley, Atty. 38

Brittany Rose Florio 32

David D. Neiser, Atty. 58

Dominic R. Scavo, Atty. 26

Erin Lee Cross 39

Izabela A. Dobson 35

Jennifer J. Mazzo 35

Julia N. Dolman, Atty. 34

Julia Nicole Mcgrath 34

Kay Nicole Viola 21

Kim Veneziano 54

Kyle Anthony James 36

Lauren La Primmer 27

Matthew A. Dolman, Atty. 43

Michaela J. Sprague 48

Patrice E. Altine 38

Rebecca Heist Dolman, Atty. 42

Sandy Kessler 33

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Sarah Marie Walters 27

Sherry Sweeney 49

Susan M Bartelloni 31

Zahira Kathleene Vinolo Cordero 35

Bryan C. Hannan, Atty. 42

AVERAGE AGE 36.57

59. To break it down further, the median age of paralegals & legal assistants in the United

States is 42.8. 2 The average age for non-lawyer legal staff at Sibley Dolman is 34.8 years.

60. The median age of a lawyer in the United States today is 49.

3

 The average age of 

attorneys at Sibley Dolman is 40.5 years.

Sibley Dolman Attorneys Age

Alex Knapp, Atty. 41

Brent F. Sibley, Atty. 38

David D. Neiser, Atty. 58

Dominic R. Scavo, Atty. 26

Julia N. Dolman, Atty. 34

Matthew A. Dolman, Atty. 43

Rebecca Heist Dolman, Atty. 42

Bryan C. Hannan, Atty. 42

2 Source: https://datausa.io/profile/soc/paralegals-legalassistants#:~:text=The%20median%20age%20of%20Paralegals,than%20than%20their%20Female%20counterparts.

3 Source: https://brandongaille.com/30-mind-boggling-lawyer-demographics/

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61. Sibley Dolman admittedly, and boastfully, intends to maintain a “very young 

workforce,” especially in comparison to national averages. And, they have accomplished exactly 

that. No wonder that Paul Ritchie, who was 67 at the time of his discharge, simply did not fit the 

law firm’s mold where only two people are over the age of 50, and none are over 60. Age 

discrimination (being the expressed preference for younger workers) is intentional and the 

pervasive practice at Sibley Dolman. And it is the “but for” reason Paul Ritchie was discharged. 

Other reasons offered by Sibley Dolman are mere pretext as discussed below.

62. Immediately after the sudden termination by Sibley Dolman and publication of the 

videos, Ritchies’ income for paralegal and administrative services dropped to zero. Paul Ritchie 

felt betrayed and depressed, adversely impacting his ability to seek new employment and his 

relationship with his wife and child.

63. On or about October 21, 2019, Plaintiff Paul Ritchie sent a letter to Sibley Dolman 

outlining a number of potential claims arising from his discharge from employment. Among those 

was a potential claim for age discrimination.

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64. On the same day Matthew Dolman responded via email stating, “Paul: You were not 

terminated due in any part to your age. Rather, when we merged firms there was no longer a need 

for your services as they are handled out of Clearwater by my staff. Further, I did not want to 

employ or be associated with an individual who has previously been disbarred from practicing law 

in another State and not eligible to practice law in Florida.” See Exhibit D attached hereto.

65. The statement is mere pretext. First, Patrice Altine who was assigned Paul Ritchie’s 

duties was, and currently is working, in the Miami area not Clearwater. Public records show is 

address to be 9018 Southwest 150th Avenue, Miami, FL 33196-1342. Patrice Altine, at age 37, 

was hired after Paul Ritchie, assumed duties previously assigned to Paul Ritchie, and was then 

retained through the merger and after discharge of Paul Ritchie.

66. Second, it is not credible that Paul Ritchie was discharged because he is a disbarred 

lawyer for three reasons: a) Matthew Dolman knew of Paul Ritchie’s background and disbarment 

early in 2018 and recommended an attorney to assist Paul Ritchie in pursuing reinstatement to 

practice law; b) in August 2018 Brent Sibley issued a check made payable to the Washington State 

Bar Association on behalf of Paul Ritchie in the amount of $25,869.13 for payment of restitution, 

even though the statute of limitations on collection had run; and; 3) the paralegal, Michaela 

Sprague, who was also hired after Paul Ritchie, assumed duties previously assigned to Paul Ritchie 

and was retained through the merger, has a criminal history as described above.

67. Regarding Paul Ritchie’s scope of duties, Sibley Dolman has expressed that, “Sibley 

Dolman would not allow him to communicate with clients.” First, that is not quite true. Paul 

Ritchie, at the direction and request of Brent Sibley, conducted initial screening interviews of 

potential clients and made investigations into facts to respond to discovery and support settlement 

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demands and litigation under a licensed attorney’s supervision and in accordance with applicable 

rules of that time. 4

68. Second, the Florida Supreme court on May 28, 2020 made changes to Rules Regulating 

The Florida Bar 3-6.1, which governs the employment in law offices of lawyers who have been 

disbarred by the Florida Supreme Court. As of July 27, 2020, Rule 3-6.1(d) now states, 

“Individuals subject to this rule must not have contact (including engaging in communication in 

any manner) with any client.”5

 A less restrictive, or explicit, version of the rule was in effect at 

the time Paul Ritchie was employed and discharged by Sibley Dolman. And, it is questionable 

whether it is applicable to Paul Ritchie as an “Individual subject to this rule” because such 

individuals are defined as “former lawyers who have been disbarred or whose disciplinary 

resignations or disciplinary revocations have been granted by the Florida Supreme Court.” Rule 3-

6.1(a) (emphasis added). Paul Ritchie was disbarred by the Washington State Supreme Court. 

Nonetheless, the new more restrictive rule in Florida was not in effect and could not have been a 

reason for discharge of Paul Ritchie in 2019. The statement by Sibley Dolman is a belated 

contrivance and pretextual.

69. On or about October 29, 2019, Matthew Dolman lodged a complaint with the Florida 

Bar against Paul Ritchie as retaliation against Paul Ritchie’s assertion of age discrimination and 

other claims of his wrongful termination. While the nature of the complaint may have been

confidential at that time, the fact that the complaint was filed is not confidential.

70. On or about December 19, 2019, Paul Ritchie made a formal response to that Bar 

complaint. The Florida Bar subsequently closed the complaint without comment on its merits or 

further action.

4 See, The Florida Bar v. Thomson, 310 So. 2d 300 (Fla. 1975) and Florida Bar Ethics Opinion 88-6, April 15, 1988. 5 Amendments to Rule Regulating The Florida Bar— Rule 3-6.1, Case No. SC19-1688

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71. Retaliatory acts against a previous employee are apparently nothing new for Matthew

Dolman. In a complaint filed in a case entitled Landau & Associates, P.A., v. Matthew A. Dolman, 

et al in the Sixth Judicial Circuit, Pinellas County (case no. 18-000441-CI), the plaintiff alleged 

that on November 2, 2017, Dolman threatened to sue a past employee for “unsolicited practice of 

law.” And apparently threatened criminal action to leverage a result in a civil matter stating; “UPL 

is a 3rd degree felony in this state. You would be wise to return to Ohio and drive trucks.”

72. Due to Dolman’s repeated negative contact with his former employee, the parties in 

the above case stipulated that during the pendency of the action:

. . . neither Mr. Dolman, nor Dolman, P.A., either directly or indirectly, shall contact 

[that employee] in any way, be it in person, via telephone or text, via email, or 

otherwise, other than through the parties’ respective undersigned counsel.

* * *

The Court shall enter an Order approving this Stipulation Regarding No Contact 

and directing Mr. Dolman and Dolman, PA. to comply with the terms hereof as if 

same were orders of the Court.

The Court so ordered on March 6, 2018.

73. That former employee also brought a separate action for injunctive relief against 

Dolman for stalking, Ludwig, Jacob George v. Dolman, Matthew A., case no. 18-001610-FD, 

Pinellas County.

74. Matthew Dolman has refrained from making additional acts of retaliation against Paul 

Ritchie. However, just eight days after Paul Ritchie raised the issue of age discrimination and 

other issues regarding his wrongful termination from employment, Matthew Dolman again 

demonstrated organizational retaliatory behavior by making a meritless complaint to the Florida 

Bar against Paul Ritchie. Due to its close proximity in time to Paul Ritchie raising the employment 

issues, it is clear that the action taken by Matthew Dolman was retaliatory and employment related.

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75. From April 2018 to March 2019, Matthew Dolman allowed Paul Ritchie to believe 

that expressed assurances of job security and longevity were being honored while in actuality, 

Dolman was waiting for the opportune time to terminate Paul Ritchie’s employment because Paul 

was just too old for the firm’s image.

76. Dolman’s perfidious nature was also alleged in the case of The Law Offices of Berman 

& Berman, P.A. v. Matthew A. Dolman, et al, case no. 2013CA007581, 15th Judicial Circuit, Palm 

Beach County. The Complaint in that case alleged that Dolman was a member of the Berman 

firm. And, in paragraphs 11 and 12 of the Complaint further alleged that:

Plaintiff discussed on numerous occasions its concerns with Matthew A. Dolman 

possible drug use, possible adultery and continuous white lies, however were 

falsely reassured each time he was 100% on board for the Plaintiff . . .

and that during the same time period, 

Dolman was diverting business of Plaintiff and conspiring to open his own 

competing firm utilizing Plaintiff’s business contacts.

77. Consistent with his past behavior, Matthew Dolman maintained a deception of job 

security and longevity for Paul Ritchie while it suited his purposes, then lashed out at Paul Ritchie 

in retaliation for raising issues of wrongful discharge by filing a meritless complaint with the 

Florida Bar in hope of chilling any further action by the Plaintiff.

78. Plaintiff has been required to engage legal counsel to pursue his rights due to 

Defendants’ acts and continue to incur legal fees and costs.

79. Plaintiff has suffered and continues to suffer monetary damages, emotional distress 

and pain and suffering (such as grief, fright, anxiety, humiliation, and depression) as a proximate 

result of Defendants acts alleged herein.

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FIRST CLAIM FOR RELIEF

AGE DISCRIMINATION

Wrongful Termination of Employment

29 U.S.C §623(a)(1)

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1 

through 79 above as if fully set forth below.

80. At all material times hereto Plaintiff Paul Ritchie was over the age of 40.

81. At all material times hereto, Plaintiff Paul Ritchie was performing his job duties 

satisfactorily or better, received performance-based bonuses and consistently good performance 

feedback from the employer.

82. Plaintiff Paul Ritchie was discharged.

83. Two younger comparators with inferior qualifications kept their jobs substantially 

replacing Plaintiff Paul Ritchie.

84. Defendants Sibley Dolman had a continuing need for the Plaintiff’s skills and services 

and his various duties were still being performed within the law firm after his discharge.

85. Defendants Sibley Dolman willfully and wrongfully terminated the employment of 

Plaintiff Paul Ritchie in violation of 29 U.S.C §623(a)(1).

WHEREFORE, having alleged a plausible prima facie case of age discrimination based on 

facts alleged herein, Plaintiff requests this Court grant to Plaintiff and against Defendants Sibley 

Dolman:

a) Back pay from the time of discharge to trial;

b) Front pay, to make up for the difference in pay that the employee would have 

earned in the future in amounts to be proven at trial;

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c) Compensatory damages, including but not limited to emotional distress and pain 

and suffering (such as grief, fright, anxiety, humiliation, and depression) in 

amounts to be proven at trial;

d) Liquidated and/or other punitive damages applicable under the law in amounts to 

be proven at trial;

e) Attorney’s fees as provided under applicable law, and;

f) Other and further relief as this Court may deem just and equitable.

SECOND CLAIM FOR RELIEF

AGE DISCRIMINATION

Unlawful Retaliation

29 U.S.C §623(d) and 42 U.S.C. 2000e-3(a)

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1 

through 79 above as if fully set forth below.

86. Plaintiff Paul Ritchie engaged in activity protected under 42 U.S.C. 2000e-3(a) when 

he sent a letter to Sibley Dolman on October 21, 2019 opposing unlawful employment practices, 

including age discrimination.

87. Defendants were aware of Plaintiff Paul Ritchie’s participation in the protected activity

as evidenced by their acknowledgement of the Plaintiff’s letter dated October 21, 2018 and 

forwarding that letter to the Florida Bar.

88. Defendants, by their principal Matthew Dolman, took adverse action against the 

Plaintiff by lodging a complaint with the Florida Bar.

89. A causal connection exists between the protected activity and the adverse action. On 

his own behalf, Plaintiff Paul Ritchie on October 2, 2019 complained to the employer of a practice 

that he reasonably believed violated the anti-discrimination laws. Eight days later, Matthew 

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Dolman lodged a meritless complaint with the Florida Bar in retaliation. That proximity in time 

indicates a causal connection between the allegation of wrongful termination and the complaint to 

the Florida Bar.

90. An inquiry by the Florida Bar was conducted and closed on April 13, 2020 without 

further action.

91. Matthew Dolman’s meritless Bar complaint was designed to deter Paul Ritchie from 

seeking legal redress and constitutes an impermissibly adverse retaliatory action precisely because 

of its “in terrorem effect” even though it does not arise strictly in an employment context.

92. Generally, individuals who lodge unsuccessful complaints against a lawyer are 

immune from any later action for defamation or abuse of process by the lawyer. No similar 

immunity is afforded a lawyer who makes an unsuccessful bar complaint against an individual

member of the general public.

6

WHEREFORE, Plaintiff requests this Court grant to Plaintiff and against Defendants 

Sibley Dolman:

a) Compensatory damages in amounts to be proven at trial;

b) Punitive damages applicable under the law in amounts to be proven at trial;

c) Attorney’s fees as provided under applicable law, and;

d) Other and further relief as this Court may deem just and equitable.

6 “Members of the legal profession are accorded rights and privileges not enjoyed by the public at large; the acceptance 

of these carries with it certain responsibilities and obligations to the general public. For the sake of maintaining the 

high standards of the profession and disciplining those who violate the Canons of Legal Ethics, one who elects to 

enjoy the status and benefits as a member of the legal profession must give up certain rights or causes of action which, 

in this instance, is the right to file an action against a complainant who lodges an unsuccessful complaint with the 

Grievance Committee of The Florida Bar.” David E. Stone et al., v. Lynne B. Rosen, 348 So.2d 387 (Fla. 3rd DCA)

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THIRD CLAIM FOR RELIEF

Supplemental State Claim - Unlawful Retaliation

Fla. Stat. §448.102

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1 

through 79 above as if fully set forth below.

93. Florida Statute 448.102 prohibits an employer from taking any retaliatory personnel 

action against an employee because the employee has disclosed, or threatened to disclose, to any 

appropriate governmental agency, under oath, in writing, an activity, policy, or practice of the 

employer that is in violation of a law, rule, or regulation. 

94. Paul Ritchie objected to an activity, policy, or practice of the employer which is in 

violation of a law, rule, or regulation as described herein.

95. Plaintiff Paul Ritchie has, in writing, brought the activity, policy, or practice to the 

attention of a supervisor or the employer and has afforded the employer a reasonable opportunity 

to correct the activity, policy, or practice.

WHEREFORE, Plaintiff requests this Court grant to Plaintiff and against Defendants 

Sibley Dolman:

a) Compensatory damages in amounts to be proven at trial;

b) Punitive damages applicable under the law in amounts to be proven at trial;

c) Attorney’s fees as provided under applicable law, and;

d) Other and further relief as this Court may deem just and equitable.

FOURTH CLAIM FOR RELIEF

Supplemental State Claim

FRAUDULENT MISREPRESENTATION

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1 

through 79 above as if fully set forth below.

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96. About March 2017, on behalf of Defendant Sibley Law, P.A., Brent Sibley induced 

Paul Ritchie to make plans to eventually abandon all other employment by promising secure, lifelong, employment with Sibley Law, P.A.

97. About 2018 Sibley failed to inform that a “merger” with Dolman could result in 

termination of Ritchie by control of the firm transferring to Matthew Dolman.

98. About July through August 2018 Paul Ritchie, acting upon and in reliance on 

representations of employment security and longevity made by Brent Sibley on behalf of the Sibley 

Dolman firm, terminated his independent paralegal employment arrangements with other attorneys 

and gave up his business in order to be fully available to Sibley Dolman.

99. On or about September 2018 Sibley deceived Ritchie on behalf of all Defendants 

named herein by expressly affirming full-time employment security and longevity for Paul Ritchie, 

knowing that he had relinquished control over hiring and firing to Matthew Dolman.

100. Defendants, and each of them, committed fraudulent misrepresentation by inducing 

Ritchie to first accept the position and then by persuading him to continue in the position by 

assuring him of long term employment security while at the same time, hiring replacement 

employees with the intent to terminate employment of Ritchie as described in detail herein.

101. Defendants though their agents, Matthew Dolman and Brent Sibley made false 

statements concerning material facts of employment security and longevity promised to Plaintiff 

Paul Ritchie as specifically set forth herein.

102. Brent Sibley, acting on behalf of Defendants, deliberately and repeatedly, and in order 

to deceive Paul Ritchie, failed to inform Plaintiff that upon “merger” with Dolman’s firm, Dolman

would have hiring and firing authority and that Paul Ritchie could lose his job and that Matthew 

Dolman in fact intended to terminate Paul Ritchie’s employment.

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103. If Matthew Dolman had knowledge superior to that of Brent Sibley regarding 

intentions to terminate Paul Ritchie, Dolman had a duty to timely reveal those intentions.

104. Both Brent Sibley and Matthew Dolman, acting on behalf of Defendants, knew that

their representations made to Paul Ritchie of job security and longevity as specifically described 

herein were false.

105. Defendants intended that their representations of employment security and longevity 

would induce Paul Ritchie to act on those representations to forbear other employment and 

opportunities as specifically stated above.

106. By acting in justifiable reliance on those false representations of employment security 

and longevity, Paul Ritchie suffered damages.

WHEREFORE, Plaintiff requests this Court grant to Plaintiff and against Defendants 

Sibley Dolman:

a) Compensatory damages in amounts to be proven at trial;

b) Punitive damages applicable under the law in amounts to be proven at trial;

c) Attorney’s fees as provided under applicable law, and;

d) Other and further relief as this Court may deem just and equitable.

FIFTH CLAIM FOR RELIEF

Supplemental State Claim

Negligent Misrepresentation

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1 

through 79 above as if fully set forth below.

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107. About March 2017, on behalf of Defendant Sibley Law, P.A., Brent Sibley induced 

Paul Ritchie to make plans to eventually abandon all other employment by promising secure, lifelong, employment with Sibley Law, P.A.

108. About 2018 Sibley failed to inform that a “merger” with Dolman could result in 

termination of Ritchie by control of the firm transferring to Matthew Dolman.

109. About July through August 2018 Paul Ritchie, acting upon and in reliance on 

representations of employment security and longevity made by Brent Sibley on behalf of the Sibley 

Dolman firm, terminated his independent paralegal employment arrangements with other attorneys 

and gave up his business in order to be fully available to Sibley Dolman.

110. On or about September 2018 Sibley deceived Ritchie on behalf of all Defendants 

named herein by expressly affirming full-time employment security and longevity for Paul Ritchie, 

knowing that he had relinquished control over hiring and firing to Matthew Dolman.

111. Defendants, and each of them, committed fraudulent misrepresentation by inducing 

Ritchie to first accept the position and then by persuading him to continue in the position by 

assuring him of long term employment security while at the same time, hiring replacement 

employees with the intent to terminate employment of Ritchie as described in detail herein.

112. Defendants though their agents, Matthew Dolman and Brent Sibley made false 

statements concerning material facts of employment security and longevity promised to Plaintiff 

Paul Ritchie as specifically set forth herein.

113. Brent Sibley, acting on behalf of Defendants, deliberately and repeatedly, and in order 

to deceive Paul Ritchie, failed to inform Plaintiff that upon “merger” with Dolman’s firm, Dolman

would have hiring and firing authority and that Paul Ritchie could lose his job and that Matthew 

Dolman in fact intended to terminate Paul Ritchie’s employment.

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114. Both Brent Sibley and Matthew Dolman, acting on behalf of Defendants, knew that

their representations made to Paul Ritchie of job security and longevity as specifically described 

herein were false, or that the representation was made under circumstances in which the 

representor ought to have known of its falsity.

115. Defendants intended that their representations of employment security and longevity 

would induce Paul Ritchie to act on those representations to forbear other employment and 

opportunities as specifically stated above.

116. By acting in justifiable reliance on those false representations of employment security 

and longevity, Paul Ritchie suffered damages.

WHEREFORE, Plaintiff requests this Court grant to Plaintiff and against Defendants 

Sibley Dolman:

a) Compensatory damages in amounts to be proven at trial;

b) Punitive damages applicable under the law in amounts to be proven at trial;

c) Attorney’s fees as provided under applicable law, and;

d) Other and further relief as this Court may deem just and equitable.

SIXTH CLAIM FOR RELIEF

Supplemental State Claim

Promissory Estoppel

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1 

through 79 above as if fully set forth below.

117. Defendants made promises (affirmative representations) of employment security and 

longevity which should reasonably expect to induce action or forbearance of a substantial character

by Paul Ritchie as specifically set forth above.

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118. Plaintiff Paul Ritchie did reasonably act and forbear to his detriment in justifiable 

reliance on those promises as described herein. 

119. Due to the Plaintiff’s detrimental reliance on the Defendants’ affirmative 

representations as described herein, enforcing the promises of employment security and longevity 

is necessary to avoid injustice to Plaintiff Paul Ritchie.

WHEREFORE, Plaintiff requests this Court grant to Plaintiff and against Defendants 

Sibley Dolman:

a) Reliance damages in amounts to be proven at trial;

b) Expectation damages applicable under the law in amounts to be proven at trial;

c) Attorney’s fees as provided under applicable law, and;

d) Other and further relief as this Court may deem just and equitable.

SEVENTH CLAIM FOR RELIEF

Supplemental State Claim

Statutory Misappropriation of Image – Fla. Stat. §540.08

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1

through 79 above as if fully set forth below.

120. While Paul Ritchie did consent to be filmed at the direction of his employer, there 

was no voluntary consent to the use (publication) of the likeness, where or where it would appear, 

or what it would be used for.

121. Any consent became invalid upon termination of employment.

122. Paul Ritchie was not allowed to view or approve the video before it was used.

123. The use of Paul Ritchie’s likeness was for Defendant's benefit and done to directly 

promote a product or service, not merely for expressive purposes. 

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124. The association of Paul Ritchie’s likeness is valuable and exploitive whether he is 

seen as representing an adversary (acting role to which he was an unwitting player) or as an integral 

part of the Sibley Dolman firm. In either event, the value to Sibley Dolman is apparent by the 

continuous running of Ritchie’s likeness for several months over the internet.

125. Among others, the first video containing Ritchie’s image also appeared on the 

Dolman Law Group “YouTube” channel on or about March 23, 2019 

(https://www.youtube.com/user/dolmanlawclearwater) indicating it received 635,000 views as of 

October 20, 2019. It is curious that more recently, that web page indicates the specific video had 

received only 380 views. According to YouTube.com, one such video featuring Paul Ritchie has 

received over 6,000 views (https://www.youtube.com/watch?v=SDyCt5Ybw7w). Another video featuring Paul 

Ritchie has received over 2,500 (https://www.youtube.com/watch?v=gpmbNGbr7N8). And yet another, also 

displaying Paul Ritchie, has received more than 2,500

(https://www.youtube.com/watch?v=_UJukXfWeAU). This list is not all inclusive – there are more 

promotional videos published by Defendants in which Paul Ritchie’s image appears on various 

websites without his consent.

126. The unauthorized use of his image has disrupted Plaintiff’s effort to control his public 

image for marketing purposes, and may have substantially altered that image after receiving 

hundreds of thousands of views on the internet.

WHEREFORE, under Florida’s right of publicity statute, the Plaintiff requests that this Court 

grant:

a) Injunctive relief barring further publication of Plaintiff’s image, likeness or name by 

or in association with Sibley Law, Sibley Dolman or Dolman Law Group;

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b) Plaintiff’s recovery of damages for loss or injury sustained by reasons and actions 

stated above, including an amount which would have been a reasonable royalty;

c) Prejudgment interest on the damages awarded, and;

d) Such further equitable relief the Court deems just and reasonable as provided by law.

EIGHTH CLAIM FOR RELIEF

Supplemental State Claim

Florida Common Law - Unauthorized Use of Likeness

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1

through 79 above as if fully set forth below.

127. The Florida common law right of publicity extends to any individual whose name or 

likeness has been exploited through unauthorized use during his or her lifetime.

128. The common law right is meant to protect the privacy and integrity of an individual's 

name and likeness, because “Nothing so exclusively belongs to a man or is so personal and 

valuable to him as his name, inasmuch as his reputation and the character he has built up are 

inseparably connected with it.” Battaglia v. Adams, 164 So. 2d 195 (Fla. 1964).

128. A violation of the common law right of publicity is found when an individual’s name 

or likeness is used without his or her consent for the benefit its value would confer on the

defendant.

130. Under the common law right of publicity, a plaintiff may be awarded nominal 

damages for the unauthorized use of his or her name without proving actual harm or damage.

131. The common law right to privacy in Florida traditionally includes; the right to prohibit 

publicity that unreasonably places one in a false light before the public, and; the right to prohibit 

the appropriation of one’s name and likeness.

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132. The unauthorized depiction of Paul Ritchie in the videos caused the plaintiff personal 

and professional humiliation, and it was severe enough to harm his career, and adversely impact

relationships with family.

WHEREFORE, Plaintiff Paul Ritchie requests this Court grant to Plaintiff and against 

Defendants:

a. Nominal damages for unauthorized use without further proof;

b. Damages for defamation (false light) in an amount to be proven at trial;

c. Damages for shame, humiliation, mental anguish, and hurt feelings experienced in the 

past or to be experienced in the future in amounts to be proven at trial, and;

d. Such further relief as deemed by this Court to be just and equitable under law.

NINETH CLAIM FOR RELIEF

Supplemental State Claim

Florida Common Law Restitution – Measured by Quantum Meruit and Unjust Enrichment

Plaintiff realleges and incorporates allegations contained in paragraphs 1 through 79 above 

as if fully set forth below.

133. Paul Ritchie performed substantial hours working to set up the North Miami Beach 

office of Sibley Dolman. 

134. Paul Ritchie relied on promises of long term job security reaffirmed on behalf of 

Sibley Dolman and then breached by order of Matt Dolman.

135. Plaintiff changed his position to his prejudice in reliance upon the agreement which 

he would not have done except for the agreement.

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136. An action founded on quantum meruit or unjust enrichment at the expense of another 

is a common law variety of restitution to enforce an implied promise, otherwise referred to as a 

quasi-contract or a contract implied in law.

137. An action for restitution is not regarded as an action upon the contract within the 

meaning or purpose of the Statute of Frauds, and the remedy is not in general affected by the 

Statute of Frauds.

138. Thus, the Plaintiff uses quantum meruit and unjust enrichment to measure recovery 

(restitution) because the Plaintiff performed services for the benefit of Defendants who breached 

a promise upon which they intended Plaintiff to rely, and he did so rely.

WHEREFORE, Plaintiff requests this Court grant:

a. Restitution to Plaintiff for the value of improvements and equipment provided to the 

North Miami Beach Office by Plaintiff;

b. Restitution to Plaintiff Paul Ritchie for the value of the Sibley Dolman logo design, 

and;

c. Other and further equitable relief deemed just by this Court.

TENTH CLAIM FOR RELIEF

29 U.S.C. 201, et seq

And Supplemental State Claim - Florida Common Law

Misclassification of Employee

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1

through 79 above as if fully set forth below.

139. The legal character of the employment relationship actually changed in March 2017 

upon commencing monthly regular payments to Ritchie. At that point he became an employee, 

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although not an exclusive one. Paul Ritchie became exclusively employed by Sibley Dolman 

commencing September 1, 2018.

140. Under Florida law, independent contractor or employee status depends not on the 

statements of the parties but upon all the circumstances of their dealings with each other.

141. Florida law determines whether a worker is an independent contractor or employee 

based on a number of factors, the most important being the extent of control exercised by the 

employer over the worker.

142. Here, it is indisputable that subsequent to September 2018, Sibley Dolman exercised 

complete control dictating to Paul Ritchie the work to be performed, hours to be worked (full-time 

regardless of location) and provided the operational systems and equipment to perform the work. 

All work product was reviewed and supervised by attorney Brent Sibley who exercised the right 

to direct what shall be done and how and when it shall be done. And, after September 2018, Paul 

Ritchie worked exclusively for only one company – Sibley Dolman.

142. The federal government also uses a multi-factor test to determine if a worker has been 

properly classified as an independent contractor, including; whether the company exerts a high 

level of control and instruction over the work; the company provides the tools and materials needed 

to perform the job, and; whether the person works for only one company.

144. Method of payment is also a factor, whether by the time or by the job. Paul Ritchie 

was paid for his time on a regular basis for work that was a regular part of the firm.

145. Not every factor need be present to conclude that a worker is an employee rather than 

an independent contractor. But among the factors, the “extent of control” is recognized by Florida 

courts as the most important factor in determining whether a person is an employee or independent 

contractor.

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WHEREFORE, Plaintiff requests this Court enter judgment for Plaintiff and against 

Defendants:

a. Declaring that Paul Ritchie was an employee and not an independent contractor as of 

a date no later than September 2018 (and as early as March 2017) and continuing 

through the date of his termination from employment;

b. Awarding Plaintiff damages to include, but not limited to, overtime, break time, 

unpaid employer taxes in amounts to be proven at trial;

c. Ordering Sibley Dolman to pay 100% of FICA taxes that weren’t withheld originally 

and interest assessed daily thereon;

d. Awarding any unpaid wages when misclassifying Plaintiff as an independent 

contractor;

e. Granting other and further relief deemed just and equitable by this Court.

DEMAND FOR JURY TRIAL

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands trial by jury 

of any issue so triable.

Respectfully submitted this 4th day of September, 2020.

CERTIFICATION AND CLOSING

Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my 

knowledge, information, and belief that this Second Amended Complaint: (1) is not being 

presented for an improper purpose, such as to harass, cause unnecessary delay, or needlessly 

increase the cost of litigation; (2) is supported by existing law or by a nonfrivolous argument for 

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extending, modifying, or reversing existing law; (3) the factual contentions have evidentiary 

support or, if specifically so identified, will likely have evidentiary support after a reasonable 

opportunity for further investigation or discovery; and (4) the complaint otherwise complies with 

the requirements of Rule 11.

FRANK ANZALONE, ESQ.

By: Frank Anzalone___

Attorney for Plaintiff

Bar No. 0284350

4611 South University Drive, Suite 151

Davie, FL 33328

Ph: 954-274-5924

Fx: 954-680-7851

Email: frankanzalone@lawyer.com

 frankanzalonelaw@gmail.com

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VERIFICATION

of Paul Ritchie

I, Paul Ritchie, declare as follows:

1. I am the Plaintiff in the present case, a citizen of the United States of America, and a 

resident of the State of Florida.

2. I have personal knowledge of the Defendants, as well as Matthew Dolman and Brent 

Sibley, their activities, and their intentions, including those set out in the foregoing Verified 

Second Amended Complaint; and if called on to testify I would competently testify as to the 

matters stated herein.

3. I verify under penalty of perjury under the laws of the United States of America and the 

State of Florida that the factual statements in this Verified Second Amended Complaint concerning 

Paul Ritchie, my activities, and intentions are true and correct, as are the factual statements 

concerning the Defendants, as well as Matthew Dolman and Brent Sibley, their activities, and their 

intentions.

Executed this 3rd day of September, 2020 at Fort Lauderdale, Florida.

________________________

Paul Ritchie

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EXHIBIT C

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8/14/2020 Gmail - Claim

https://mail.google.com/mail/u/2?ik=1068a280cf&view=pt&search=all&permmsgid=msg-f%3A1648010975074994185&simpl=msg-f%3A16480109750... 1/1

Paul Ritchie <psrconsultingllc@gmail.com>

Claim

Matt Dolman <matt@dolmanlaw.com> Mon, Oct 21, 2019 at 9:49 AM

To: Paul Ritchie <paul@paulsritchie.com>, "BFS@sibley-law.com" <BFS@sibley-law.com>

Cc: Bobby Jones <bjones@bobbyjoneslaw.com>

Paul

You were not terminated due in any part to your age. Rather, when we merged firms there was no longer a need for your

services as they are handled out of Clearwater by my staff. Further, I did not want to employ or be associated with an

individual who ha previou ly been di barred from practicing law in another State and not eligible to practice law in

Florida. 

Your claims will be responded to by counsel. This will be my only communication with you. 

Sent from my Verizon, Samsung Galaxy smartphone

Get Outlook for Android

From: Paul Ritchie paul@paul ritchie com

Sent: Monday, October 21, 2019 9:30:00 AM

To: Ma Dolman matt@dolmanlaw com ; BFS@ ibley law com BFS@ ibley law com

Subject: Claim

[Quoted text hidden]

EXHIBIT D

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