Complaint

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UNITED STATES DISTRICT COURT

Southern District of Florida

Broward Division

CASE NO.:

PAUL RITCHIE,

an individual, and;

RAQUEL RITCHIE,

an individual,

Plaintiffs,

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 COMPLAINT FOR 

DAMAGES, DECLARATORY AND INJUNCTIVE RELIEF

AND DEMAND FOR JURY TRIAL

Plaintiffs, PAUL RITCHIE, and RAQUEL RITCHIE through their undersigned counsel,

sue the above-named Defendants and allege:

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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); 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, 

which Plaintiff received on or about February 28, 2020.

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PARTIES

6. Plaintiff PAUL RITCHIE is over 40 years of age, a resident of the State of Florida and 

otherwise sui juris.

7. Plaintiff RAQUEL RITCHIE is 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.

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.

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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 more recently performed free-lance 

paralegal services exclusively for licensed attorneys.

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

Paul Ritchie for assistance with various cases.

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 schedule. 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 

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exclusively and for as long as Ritchie desired. It was agreed between Paul Ritchie and Sibley that 

this position and arrangement would become exclusive, full-time and endure indefinitely.

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 for work and compensation between Sibley Law and Paul 

Ritchie remained the same while utilizing internet communications and document systems set up 

by Sibley. Sibley also provided computer monitors and telephone equipment to Paul Ritchie.

24. In September 2017, Paul Ritchie’s wife, Raquel Ritchie, joined him as an 

administrative assistant in his new office to help with the growing number of cases assigned to 

Ritchie by various attorneys and increasing workload from Sibley.

25. Over previous months, Ritchie had helped grow one attorney’s bankruptcy practice 

significantly though effective marketing. Raquel Ritchie handled bankruptcy client intake and 

documentation as well as other administrative tasks.

26. 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 other 

paralegal duties.

27. Paul Ritchie was also a key person in operational and organizational management. 

Ritchie developed the litigation workflow and filing system. He had 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.

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28. 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).

29. As caseloads increased, Brent Sibley announced to Ritchie in the summer of 2018 a 

plan that Sibley Dolman would soon open an office at North Miami Beach.

30. Consistent with the earlier agreement between Paul Ritchie Sibley, it was agreed that 

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

all his time exclusively to Sibley Dolman.

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

Sibley, Paul Ritchie gave notice to terminate his Fort Lauderdale office lease effective September 

1, 2018.

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

Raquel Ritchie at Turnberry Isle Country Club. At that meeting Brent Sibley, on behalf of Sibley 

Dolman, offered full-time employment to Raquel Ritchie as a phone receptionist and 

administrative assistant with a promise of job security for as long as she wished. She accepted.

33. Consistent with their agreement, Sibley at that time on behalf of Sibley Dolman granted

Paul Ritchie a raise in monthly pay based on his exclusive employment relationship with Sibley 

Dolman.

34. It was agreed that Paul Ritchie and Raquel Ritchie would work from their home office 

via Sibley Dolman’s internet communications, management systems, and equipment, except for 

in-person meetings as required.

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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35. During the period from September to November 2018, Paul Ritchie and Raquel Ritchie

set up the Sibley Dolman office in North Miami Beach.

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

décor. 

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

the firm in its public advertising.

38. Raquel Ritchie obtained the necessary city business license for Sibley Dolman from

the City of North Miami Beach.

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

electronics and internet service.

40. Paul Ritchie and Raquel Ritchie shopped, selected, transported and assembled 

furniture, electronics and a beverage bar. Ritchie’s provided equipment including a refrigerator, 

coffee maker and microwave oven at his own (unreimbursed) expense. Paul and Raquel Ritchie 

transported and disposed of unwanted furniture left by a previous tenant. They

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 of Sibley Dolman.

41. The effort and contributions of time, talent and material by Paul Ritchie and Raquel 

Ritchie were above and beyond the agreed job duties, performed on their own time and, were based 

on the employment relationship promised by Brent Sibley as being secure.

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

the Sibley Dolman firm.

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43. 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 operational system used by Dolman Law Group.

44. 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.

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

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

footage of his image prior to any publication.

47. Paul Ritchie did not execute any release for publication of his image or likeness.

48. On or about January 2019, a younger paralegal, under the age of 40 and whose name 

is believed to be Michaela, was hired at the Clearwater office of Sibley Dolman to assume duties 

over cases previously under the purview of Paul Ritchie.

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

particularly the assignment of responsibilities that would have normally 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.

50. 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 and 

Raquel’s, employment status remained secure and would continue for as long as they desired.

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

performance for Sibley Dolman.

52. 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.

53. Sibley then notified Paul Ritchie that his employment, and that of his wife Raquel, was 

terminated immediately upon order of Matthew Dolman. Sibley indicated that he had known of 

Dolman’s directive for several days. No explanation was given.

54. 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.

55. Raquel Ritchie was paid for the following two weeks after discharge.

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

Ritchie’s home office.

57. Unbeknownst to Paul Ritchie, a promotional 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 

Raquel Ritchie and communicated that to Brent Sibley.

58. 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.

59. 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 

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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.

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

videos, both Ritchie’s income for paralegal and administrative services dropped dramatically. 

Both Paul Ritchie and Raquel Ritchie felt betrayed and depressed, adversely impacting ability to 

seek new accounts.

61. 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.

62. On or about October 29, 2019, Mathew Dolman lodged a complaint with the Florida 

Bar that Paul Ritchie was engaging in the unauthorized practice of law.

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

complaint.

64. On or about April 13, 2020 the Florida Bar closed the complaint without further action.

65. Plaintiffs have been required to engage legal counsel to pursue their rights due to 

Defendants acts and continue to incur legal fees and costs.

66. Plaintiffs have suffered and continue 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

By Plaintiff Paul Ritchie

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 66 above as if fully set forth below.

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

68. 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.

69. Plaintiff Paul Ritchie was discharged.

70. Two younger comparators with inferior qualifications and not in the protected class 

kept their jobs substantially replacing Plaintiff Paul Ritchie.

71. 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.

72. 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

By Plaintiff Paul Ritchie

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 66 above as if fully set forth below.

73. 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 an unlawful employment practice, 

namely age discrimination.

74. 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.

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

Plaintiff by lodging a complaint with the Florida Bar.

76. 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 

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that he reasonably believed violated the anti-discrimination laws. In retaliation, Mathew Dolman 

submitted a complaint about Ritchie to the Florida Bar.

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

further action.

WHEREFORE, 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;

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

and suffering (such as grief, fright, anxiety, humiliation, anger, depression, 

embarrassment frustration as well as reputational harm, and other negative 

consequences experienced as a result of the retaliation) 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.

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THIRD CLAIM FOR RELIEF

By Plaintiff Paul Ritchie

BREACH OF EMPLOYMENT CONTRACT

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1 

through 66 above as if fully set forth below.

78. On behalf of Defendant Sibley Law, P.A., Brent Sibley entered into an employment 

contract with Paul Ritchie on or about March 2017 for an indefinite duration.

79. On or about September 2018 ratification of the employment contract was 

communicated to Ritchie by Brent Sibley on behalf of all Defendants named herein.

80. Plaintiff has performed all of the conditions, covenants and promises required in 

accordance with the terms and conditions of the contract.

81. By promising job security for as long as the employee desired and other assurances 

and representations, Defendants abrogated their at-will termination rights.

82. Defendants, and each of them, breached their employment agreement with Plaintiff 

Paul Ritchie by arbitrarily terminating his services.

83. As a result of the breach of the Defendants, and each of them, of the obligations 

pursuant to the employment contract, Plaintiff Paul Ritchie has suffered damages.

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

Defendants:

a) Back pay damages from the time of breach to trial;

b) Front pay (expectation damages), to make up for the difference in pay that the 

employee would have earned in the future 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.

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FOURTH CLAIM FOR RELIEF

By Plaintiff Raquel Ritchie

BREACH OF EMPLOYMENT CONTRACT

Plaintiff Raquel Ritchie realleges and incorporates allegations contained in paragraphs 1 

through 66 above as if fully set forth below.

84. On behalf of Defendants, Brent Sibley entered into an employment contract with 

Raquel Ritchie on or about September 2018 whereby Defendants promised job security 

indefinitely.

85. By promising job security for as long as the employee desired, Defendants abrogated 

their at-will termination rights.

86. Plaintiff Raquel Ritchie has performed all of the conditions, covenants and promises 

required in accordance with the terms and conditions of the contract.

87. Defendants, and each of them, breached their employment agreement with Plaintiff 

Raquel Ritchie by arbitrarily terminating her services.

88. As a result of the breach of the Defendants, and each of them, of the obligations 

pursuant to the employment contract, Plaintiff Raquel Ritchie has suffered damages.

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

Defendants:

a) Back pay damages from the time of breach to trial;

b) Front pay (expectation damages), to make up for the difference in pay that the 

employee would have earned in the future 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.

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FIFTH CLAIM FOR RELIEF

By Plaintiff Paul Ritchie

Supplemental State Claim

Statutory Misappropriation of Image – Fla. Stat. §540.08

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1

through 66 above as if fully set forth below.

89. While Paul Ritchie consented to be videoed at the direction of his employer, there was 

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

what it would be used for.

90. Any consent became invalid upon termination of employment.

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

92. 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.

93. 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.

94. 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

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(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.

95. 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;

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.

SIXTH CLAIM FOR RELIEF

By Plaintiff Paul Ritchie

Supplemental State Claim

Florida Common Law - Unauthorized Use of Likeness

Plaintiff Paul Ritchie realleges and incorporates allegations contained in paragraphs 1

through 66 above as if fully set forth below.

96. 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.

97. 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 

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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).

98. 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.

99. 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.

100. 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.

101. 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

his income and 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.

//

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SEVENTH CLAIM FOR RELIEF

By Plaintiffs Paul Ritchie and Raquel Ritchie

Supplemental State Claim

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

Plaintiffs reallege and incorporates allegations contained in paragraphs 1 through 66 above 

as if fully set forth below.

102. Paul Ritchie and Raquel Ritchie performed substantial hours working to make 

improvements and alterations to the North Miami Beach office of Sibley Dolman.

103. Paul Ritchie and Raquel Ritchie relied on promises of job security reaffirmed on 

behalf of Sibley Dolman and then breached by order of Matthew Dolman.

104. Plaintiffs changed their position to their prejudice in reliance upon the agreements

which they would not have done except for the agreements.

105. 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.

106. Thus, the Plaintiffs use quantum meruit and unjust enrichment to measure recovery 

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

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

WHEREFORE, Plaintiff requests this Court grant:

a. Restitution to Plaintiffs for the value of improvements, labor and equipment provided 

to the North Miami Beach Office by Plaintiffs;

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.

Case 0:20-cv-61047-RAR Document 1 Entered on FLSD Docket 05/28/2020 Page 19 of 24
Complaint

Page 20 of 24

EIGHTH CLAIM FOR RELIEF

By Plaintiff Paul Ritchie

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 66 above as if fully set forth below.

107. The legal character of Paul Ritchie’s employment relationship actually changed in 

March 2017 upon commencing monthly regular payments to Ritchie. At that point he became an 

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

Dolman commencing September 1, 2018.

108. 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.

109. 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.

110. Here, it is indisputable that Sibley Dolman exercised complete control dictating to 

Paul Ritchie the work to be performed, hours to be worked 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 would be done and how and when it would be 

done. And, after September 1, 2018, Paul Ritchie worked exclusively for only one company -

Sibley Dolman.

111. 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 

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Complaint

Page 21 of 24

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.

112. 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.

113. 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.

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 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.

//

//

//

Case 0:20-cv-61047-RAR Document 1 Entered on FLSD Docket 05/28/2020 Page 21 of 24
Complaint

Page 22 of 24

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 25th day of May, 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 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 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 Defendants

Bar No. 0284350

4611 South University Drive, Suite 151

Davie, FL 33328

Ph: 954-274-5924

Fx: 954-680-7851

Email: frankanzalone@lawyer.com

Case 0:20-cv-61047-RAR Document 1 Entered on FLSD Docket 05/28/2020 Page 22 of 24
Complaint

Page 23 of 24

VERIFICATION

of Paul Ritchie

I, Paul Ritchie, declare as follows:

1. I am a 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 

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 Complaint concerning Paul Ritchie and 

Raquel Ritchie, their activities, and their 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 25th day of May, 2020 at Fort Lauderdale, Florida.

________________________

Paul Ritchie

Case 0:20-cv-61047-RAR Document 1 Entered on FLSD Docket 05/28/2020 Page 23 of 24
Complaint

Page 24 of 24

VERIFICATION

of Raquel Ritchie

I, Raquel Ritchie, declare as follows:

1. I am a 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 

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 Complaint concerning Paul Ritchie and 

Raquel Ritchie, their activities, and their 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 25th day of May, 2020 at Fort Lauderdale, Florida.

________________________

Raquel Ritchie

Case 0:20-cv-61047-RAR Document 1 Entered on FLSD Docket 05/28/2020 Page 24 of 24