UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 

FELICE FEIG, 

Plaintiff, 

vs. 

WELLS FARGO N.A. 

Defendant. 

_____________________/ 

COMPLAINT 

Plaintiff FELICE FEIG (“FEIG”), by counsel, sues the Defendant the WELLS FARGO 

N.A. (WELLS FARGO”) and for her Complaint says: 

JURISDICTION AND VENUE 

1. This is an action arising under the Americans With Disabilities Act and the 

Age Discrimination in Employment Act. 

2. The action is also cognizable under the Florida Civil Rights Act of 1992 

(“FCRA”) 

PARTIES

3. Plaintiff, FEIG, is a female and resident of Palm Beach County, Florida. At all 

time pertinent, FEIG was an “employee” as defined by the Americans with 

Disabilities Act and Florida Civil Rights Act of 1992, Fla. Stat. §760.01 et seq. 

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4. Defendant, WELLS FARGO, is an “employer” as defined by the Americans 

with Disabilities Act and the Florida Civil Rights Act of 1992, Fla. Stat. §760.01 et 

seq. 

CONDITIONS PRECEDENT 

5. Plaintiff filed a Charge of Discrimination asserting disability and age 

discrimination or about September 12, 2019, with the Equal Employment Opportunity 

Commission which was co-filed with the Florida Civil Rights Commission. 

6. The EEOC issued a Right to Sue on or about February 12, 2020 which was 

served by mail several days later. 

7. The FCHR did not issue a no-cause determination within 180 days of filing the 

charge. 

GENERAL ALLEGATIONS 

8. FEIG was born in 1962 and is over the age of forty. 

9. FEIG was first employed by employed by WELLS FARGO’s predecessor bank 

Wachovia in 1994. 

10. In 2011 Plaintiff was diagnosed with a major stress disorder, a disability which 

affected a major life activity -working. 

11. Plaintiff submitted documentation to her employer of her disability, and both 

requested and received an accommodation from WELLS FARGO.. 

12. This accommodation lasted from 2011 to 2017, although WELLS FARGO 

describes it as “temporary. 

13. The primary accommodation related to her being excused from servicing the 

automatic teller machine 

14. In 2017 Plaintiff’s branch was closed and she was assigned to a high volume 

branch. 

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15. There she was expected to service the automatic teller machines despite her 

disability. 

16. Plaintiff submitted additional medical documentation concerning her disability 

which was either ignored or denied by Defendant. 

17. The Defendant placed Plaintiff under increasing stress and wrote her up 

frequently for minor infractions which, when committed by younger and able bodied 

workers were ignored. 

18. Plaintiff was terminated in April 2019 by the Defendant on account of her age 

and disability. 

COUNT I - DISABILITY DISCRIMINATION 

(FLORIDA CIVIL RIGHTS ACT AN?D AMERICANS WIT?H DISABILITIES ACT) 

19. FEIG readopts and realleges paragraph 1 through 18 above as if fully set forth 

herein. 

20. The conduct of WELLS FARGO, by and through the conduct of its agents, 

subjected FEIG to unlawful discrimination on account of disability in violation of the 

Florida Civil Rights Act and the Americans with Disabilities Act. 

21. As a direct, natural, foreseeable and proximate result of the actions and inactions 

of WELLS FARGO, by and through the actions and inactions of its managerial 

personnel, FEIG has suffered injuries and losses including a violation of her statutory 

rights, economic loss, mental pain and suffering and extreme emotional stress, loss of 

ability to lead a normal life, all of which injuries and losses are continuing and 

permanent in nature. 

22. The Plaintiff is entitled to recover punitive damages under the Florida Civil 

Rights Act as a punishment to WELLS FARGO and to deter others. 

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WHEREFORE, FEIG prays for the following relief:

a. Entry of judgment for restitutionary, compensatory and punitive damages including, but 

not limited to, damages for emotional pain and suffering, anguish, injury of reputation, 

and loss of capacity to enjoy life. 

b. Award FEIG costs in this action, including reasonable attorneys’ fees and expert fees as 

provided by the Americans With Disabilities Act and the Civil Rights Act; and 

c. Any other equitable relief, including reinstatement or front pay in lieu thereof, deemed 

appropriate by this Court. 

COUNT I I- AGE DISCRIMINATION 

(FLORIDA CIVIL RIGHTS ACT) 

23. FEIG readopts and realleges paragraph 1 through 18 above as if fully set forth herein. 

24. The conduct of WELLS FARGO, by and through the conduct of its agents, subjected FEIG 

to unlawful discrimination on account of age in violation of the Florida Civil Rights Act. 

25. As a direct, natural, foreseeable and proximate result of the actions and inactions of 

WELLS FARGO, by and through the actions and inactions of its managerial personnel, 

FEIG has suffered injuries and losses including a violation of her statutory rights, 

economic loss, mental pain and suffering and extreme emotional stress, loss of ability to 

lead a normal life, all of which injuries and losses are continuing and permanent in nature. 

26. The Plaintiff is entitled to recover punitive damages under the Florida Civil Rights 

Act as a punishment to WELLS FARGO and to deter others. 

WHEREFORE, FEIG prays for the following relief: 

a. Entry of judgment for restitutionary, compensatory and punitive damages 

including, but not limited to, damages for emotional pain and suffering, anguish, 

injury of reputation, and loss of capacity to enjoy life. 

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b. Award FEIG costs in this action, including reasonable attorneys’ fees and expert fees as 

provided by the Florida Civil Rights Act; 

c. Any other equitable relief, including reinstatement or front pay in lieu thereof, 

deemed appropriate by this Court. 

COUNT I I- AGE DISCRIMINATION 

(ADEA) 

27. FEIG readopts and realleges paragraph 1 through 18 above as if fully set forth herein. 

28. The conduct of WELLS FARGO, by and through the conduct of its agents, subjected FEIG 

to unlawful discrimination on account of age in violation of the Agee Discrimination in 

Employment Act. 

29. The Defendant acted willfully to deprive Plaintiff of her rights under thee ADEA. 

30. As a direct, natural, foreseeable and proximate result of the actions and inactions of 

WELLS FARGO, by and through the actions and inactions of its managerial personnel, 

FEIG has suffered injuries and losses including a violation of her statutory rights, 

economic loss, 

31. The Plaintiff is entitled to a penalty for the willful violation of the ADEA through the 

time of trial 

WHEREFORE, FEIG prays for the following relief: 

a. Entry of judgment for comic and pecuniary including, a penalty for willfully 

violating the ADEA, 

b. Award costs in this action, including reasonable attorneys’ fees and expert fees as 

provided by the ADEA; 

c. Any other equitable relief, including reinstatement or front pay in lieu thereof, 

deemed appropriate by this Court. 

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DEMAND FOR JURY TRIAL 

Plaintiff demands trial by jury as to all issues so trial as a matter of right. 

CORNELL & ASSOCIATES, P.A. 

2645 EXECUTIVE PARK DRIVE 

WESTON, FLORIDA 33331 

OFFICE (954) 618-1041 

E-MAIL: WARE@WARECORNELL.COM

BY:__/G. WARE CORNELL, JR.__ G. 

WARE CORNEL, JR., ESQ. 

FLORIDA BAR NUMBER: 203920 

5 

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