1 

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. ____________-CIV-___________/____________ 

 

PRISGAR DE SUZE, an individual, 

 

Plaintiff, 

 

vs. 

MARRINSON GROUP, INC., 

a Florida Corporation, d/b/a MANOR PINES,

 

Defendant. 

___________________________________________/ 

COMPLAINT

 1. Plaintiff, PRISGAR DE SUZE (hereinafter referred to as “Plaintiff” and “DE 

SUZE”), was an employee of Defendant, MARRINSON GROUP, INC., a Florida Corporation 

d/b/a MANOR PINES, and brings this action against Defendant for violations of the Americans 

with Disabilities Act of 1990, 42 U.S.C. §12101 et seq., as amended through the ADA 

Amendments Act of 2008, P.L. 110-325, § 2, 122 Stat. 3553 (the “ADAAA”). 

2. DE SUZE is an individual residing in Broward County, Florida, within the 

jurisdiction of this Court. 

3. Defendant, MARRINSON GROUP, INC. (hereinafter referred to as 

“MARRINSON GROUP” and “Defendant”), has at all times material to this Complaint owned 

and operated a skilled nursing facility and rehabilitation center doing business as MANOR PINES 

located at 1701 N.E. 26th Street, Fort Lauderdale, Florida 33305 in Broward County, Florida, 

within the jurisdiction of this Court. 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 1 of 35
2 

4. Jurisdiction is conferred on this Court by 28 U.S.C. §1332, §1337, and 29 U.S.C. 

§12101. 

5. Venue is proper in this Court pursuant to 28 U.S.C. §1391 because all of the events, 

or a substantial part of the events, giving rise to this action, occurred in Broward County, Florida, 

within the jurisdiction of the United States District Court for the Southern District of Florida, Fort 

Lauderdale Division. 

6. At all times material to this action, DE SUZE was an “employee” of MARRINSON 

GROUP within the meaning of the ADAAA, 42 U.S.C. §12111(4), 

7. At all times material to this action, MARRINSON GROUP was an “employer” of 

DE SUZE within the meaning of the ADAAA, 42 U.S.C. §12111(5), and the FCRA, F.S.

§760.02(7), because Defendant was a business engaged in interstate commerce and had Fifteen 

(15) or more employees in each of Twenty (20) or more calendar weeks in the current or preceding 

year.

8. In approximately 2011 or 2012, MARRINSON GROUP hired DE SUZE as a 

Porter-Custodian at the MANOR PINES skilled nursing facility and rehabilitation center located 

at 1701 N.E. 26th Street, Fort Lauderdale, Florida 33305. 

9. At all times material to this action, DE SUZE was an individual with one or more 

chronic medical conditions, including but not necessarily limited to multiple myeloma, a cancer 

of the blood cells,

1 which affects, inter alia, Plaintiff’s hemic, immune, and musculoskeletal

systems, and which caused medically related absences throughout the course of DE SUZE’s

employment with MARRINSON GROUP between approximately January 2019 and May 2019. 

1 DE SUZE was first diagnosed with multiple myeloma in approximately 2009 when he was FiftyNine (59) years of age and successfully worked for more than the next ten (10) years despite 

Plaintiff’s cancer. 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 2 of 35
3 

10. At all times material to this action, including but not necessarily limited to between 

approximately January 2019 and May 2019, DE SUZE’s primary duties for MARRINSON 

GROUP at the MANOR PINES skilled nursing facility and rehabilitation center consisted of

custodial work, namely: (a) emptying trash bins and taking out the trash; and (b) cleaning the 

floors of the facility.

11. Significantly, the performance of DE SUZE’s essential duties between 

approximately January 2019 and May 2019 as a Porter-Custodian for MARRINSON GROUP at 

MANOR PINES did not require Plaintiff to regularly lift more than ten (10) pounds, as DE SUZE 

instead regularly took out trash bags and worked with trash bins that were not heavy items and 

even the floor buffer that was used sometimes once or twice per week was equipment that Plaintiff 

was fully capable of pushing in the facility. 

12. In or around approximately December 2018-January 2019, DE SUZE began 

experiencing physical symptoms because of Plaintiff’s multiple myeloma, including by way of 

example, back problems, in connection with which DE SUZE sought medical leave under the 

Family and Medical Leave Act (FMLA).

13. On or around January 30, 2019, MARRINSON GROUP notified DE SUZE in 

writing that he was eligible for medical leave from his employment under the FMLA.

14. On or around February 18, 2019, the “Certification of Healthcare Provider Form” 

provided to DE SUZE by MARRINSON GROUP in connection with Plaintiff’s FMLA leave was 

completed by Dr. Sondra Aiken, board certified Internal Medicine, see Exhibit A, in which 

Certification Dr. Aiken documented that, inter alia: (a) DE SUZE was experiencing possible bone 

deterioration from steroidal treatment for Plaintiff’s multiple myeloma leading to vertebrae 

fractures and back pain for which Plaintiff would be receiving an orthopedic evaluation and pain 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 3 of 35
4 

management; (b) the only job function DE SUZE was then unable to perform was “lifting”; and 

(c) FMLA leave through a reduced work schedule of four (4) hours per day four (4) days per week 

between approximately January 2019 and March 2019. 

15. In March 2019, DE SUZE was absent from his employment with MARRINSON 

GROUP on FMLA leave for approximately four (4) weeks while Plaintiff received in-patient 

treatment at Baptist Hospital as a result of Plaintiff’s multiple myeloma and associated back 

problems and medical condition. 

16. In early April 2019, DE SUZE began undergoing a course of chemotherapy for 

Plaintiff’s multiple myeloma. 

17. On or around April 4, 2019, MARRINSON GROUP notified DE SUZE that his 

twelve (12) weeks of eligible medical leave under the FMLA would purportedly be expiring on 

April 19, 2019 and Plaintiff needed to: (a) contact Defendant immediately about returning to work; 

(b) request an extended medical leave due to any inability to return to work because of his medical 

condition; or (c) resign due to his inability to return to work. 

18. On or around April 17, 2019, DE SUZE requested an accommodation from 

MARRINSON GROUP for his multiple myeloma and related medical conditions in the form of a 

brief extension of time off and/or accommodating Plaintiff’s work schedule, and on April 17 or 

18, 2019, another “Certification of Healthcare Provider Form” for DE SUZE was sent to 

MARRINSON GROUP from Plaintiff’s treating hematology-oncology provider at Baptist 

Hospital-Miami Cancer Institute, see Exhibit B, in which Certification Defendant was notified, 

inter alia, DE SUZE: (a) had previously been hospitalized from March 1-29, 2019; (b) was then 

capable of performing light duty work but should not “lift/pull” anything greater than ten (10) 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 4 of 35
5 

pounds; and (c) was undergoing chemotherapy treatments that could cause severe fatigue and 

cytotoxic side effects which include immunosuppression. 

19. On or around May 10, 2019, DE SUZE provided MARRINSON GROUP with a 

Return to Work letter dated May 10, 2019 from Dr. Claudia Paba Prada at Baptist Hospital-Miami 

Cancer Institute in which Defendant was notified, inter alia, that DE SUZE could return to work 

on May 13, 2019. See Exhibit C. 

20. More specifically, on or around May 10, 2019, DE SUZE went, in uniform, to the 

MANOR PINES facility and Plaintiff showed his supervisor, Steven Jones, MARRINSON 

GROUP’s Housekeeping Director at MANOR PINES, the May 10th Return to Work letter from 

Baptist Hospital-Miami Cancer Institute (Exhibit C), but Jones first directed DE SUZE to bring 

the Return to Work Letter to Bill Savage, Defendant’s Director at MANOR PINES, who made a 

copy of the Letter, and Jones subsequently refused to allow Plaintiff to work and instead told 

Plaintiff to call him in approximately one week. 

21. However, when DE SUZE called Jones approximately one week later by May 17, 

2019, Jones informed Plaintiff that MARRINSON GROUP had no place to put Plaintiff to work 

and DE SUZE’s employment with Defendant was terminated.

22. At all times material to this action, DE SUZE satisfactorily performed his essential

job duties as a Porter-Custodian for MARRINSON GROUP. 

23. At all times material to this action, DE SUZE suffered from one or more “physical 

impairments” within the meaning of the ADA, 29 C.F.R. §1630.2(h)(1), as a result of DE SUZE’s 

multiple myeloma, back condition, and resulting medical issues which were ongoing between 

approximately January 2019 and May 2019, including but not limited to Plaintiff suffering from a

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 5 of 35
6 

physiological disorder or condition affecting one or more of DE SUZE’s body systems including 

but not necessarily limited to DE SUZE’s hemic, immune, and musculoskeletal systems. 

24. MARRINSON GROUP failed to provide DE SUZE with a reasonable

accommodation for Plaintiff’s disability and medical conditions and Defendant instead subjected 

DE SUZE to discrimination, disparate treatment, and retaliation because of DE SUZE’s conditions 

by Defendant, inter alia: (a) denying DE SUZE’s request for a reasonable accommodation for 

Plaintiff’s disability; and (b) terminating DE SUZE’s employment in May 2019 based upon false 

and/or pretextual grounds because of Plaintiff’s disability and/or in retaliation for Plaintiff having 

sought an accommodation and/or otherwise exercised his rights under the ADA, all in violation of 

the ADA.

25. The reasons proffered by MARRINSON GROUP in May 2019 for terminating DE 

SUZE’s employment were false and known to be false by Defendant at the time of Plaintiff’s 

termination and instead were a pretext for disability discrimination and retaliation against DE 

SUZE in violation of the ADA. 

EXHAUSTION OF ADMINISTRATVIE REMEDIES

26. On January 29, 2020, DE SUZE filed a Charge of Discrimination with the United 

States Equal Employment Opportunity Commission (EEOC) and Florida Commission for Human 

Relations (FCHR) Charge No. 510-2020-02259 alleging that he had been subjected to disability

discrimination and retaliation in violation of the Americans with Disabilities Act and the Florida 

Civil Rights Act. A copy of DE SUZE’s Charge of Discrimination is attached hereto as Exhibit D. 

27. On or around May 8, 2020, the EEOC issued a Dismissal and Notice of Suit Rights 

to DE SUZE in connection with Charge No. 510-2020-02259. See Exhibit E. 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 6 of 35
7 

28. DE SUZE’s Complaint in this action is being filed with the Court on June 23, 2020 

within Fort-Five (45) days of DE SUZE’s receipt in May 2020 of the EEOC’s Dismissal and Notice 

of Suit Rights for Charge No. 510-2020-02259. 

COUNT I

DISABILITY DISCRIMINATION IN VIOLATION OF 

THE AMERICANS WITH DISABILITIES ACT

Plaintiff, PRISGAR DE SUZE, reasserts and reaffirms the allegations of Paragraphs 1 

through 28 as if fully set forth herein and further states that this is an action against MARRINSON 

GROUP, INC. for disparate treatment and disability discrimination in violation of the Americans 

with Disabilities Act of 1990, 42 U.S.C. §12101 et seq., as amended through the ADA 

Amendments Act of 2008, P.L. 110-325, § 2, 122 Stat. 3553. (“ADAAA”).

29. The Americans with Disabilities, the ADA and ADAAA, 42 U.S.C. §12112(a), 

prohibits discrimination “against a qualified individual on the basis of disability in regard to job 

application procedures, the hiring, advancement, or discharge of employees, employee 

compensation, job training, and other terms, conditions, and privileges of employment. 

30. At all times material to this action, DE SUZE suffered from multiple myeloma and

other medical conditions which affected Plaintiff’s hemic, immune, and musculoskeletal systems

and which manifested physical problems during DE SUZE’s employment with MARRINSON 

GROUP between approximately January 2019 and May 2019. 

31. At all times material to this action, DE SUZE suffered from one or more “physical 

impairments” within the meaning of the ADA and ADAAA, 29 C.F.R. §1630.2(h)(1), as a result 

of multiple myeloma or other physiological disorders or conditions which affected DE SUZE’s

hemic, immune, and musculoskeletal systems. 

32. At all times material to this action, DE SUZE was substantially limited in one or 

more “major life activities” within the meaning of the ADA and ADAAA, 29 C.F.R. §1630.2(i), 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 7 of 35
8 

including but not necessarily limited to lifting, as well as the operation of one or more of Plaintiff’s 

major bodily functions including but not necessarily limited to functions of DE SUZE’s hemic, 

immune, and musculoskeletal systems. 

33. At all times material to this action, DE SUZE was an individual with a “disability” 

as defined by the ADA and ADAAA, 42 U.S.C. § 12102(1), because Plaintiff (a) suffered physical 

impairments that substantially limited one or more major life activities; (b) had a record of such 

impairments; and/or (c) was regarded by MARRINSON GROUP as a person with such 

impairments.

34. At all times material to this action, DE SUZE had to endure substantial limitations 

as a result of multiple myeloma and Plaintiff’s related medical conditions within the meaning of 

the ADA and ADAAA, 29 C.F.R. §1630.2(j), because DE SUZE’s conditions substantially limited 

Plaintiff’s ability to perform one or more major life activities—including but not necessarily 

limited to lifting—as compared to most people in the general population. 

35. At all times material to this action, DE SUZE has been “disabled” within the 

meaning of the ADA and ADAAA, 42 U.S.C. §12102(1)(A), because DE SUZE’s chronic multiple 

myeloma and related medical conditions are actual physical impairments that substantially limit

one or more of DE SUZE’s major life activities.

36. In addition, at all times material to this action, DE SUZE has also been “disabled” 

within the meaning of the ADA and ADAAA, 42 U.S.C. §12102(1)(C), because DE SUZE was 

regarded by MARRINSON GROUP as having a physical impairment that substantially limited

one or more of his major life activities as a result of DE SUZE’s multiple myeloma and related 

medical conditions. 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 8 of 35
9 

37. At all times material to this action, DE SUZE was a “qualified individual” as that

term is defined by the ADA and ADAAA, 42 U.S.C. §12111(8), because Plaintiff was able to 

satisfactorily perform the essential functions of his job as a Porter-Custodian for MARRINSON 

GROUP between approximately January 2019 and May 2019 with or without reasonable 

accommodation by Defendant. 

38. At all times material to this action, DE SUZE was a “qualified individual with a 

disability” within the meaning of the ADA and ADAAA, 29 C.F.R. §1630.2(m) and 42 U.S.C. 

§12111(8), because DE SUZE possessed the requisite skill and experience to carry out his duties

for MARRINSON GROUP between approximately January 2019 and May 2019, and DE SUZE

likewise was capable of performing the essential functions of his job despite DE SUZE’s disability, 

with or without reasonable accommodation(s) by MARRINSON GROUP. 

39. Further, DE SUZE was also qualified for his job with MARRINSON GROUP

between approximately January 2019 and May 2019 within the meaning of the ADA and ADAAA, 

42 U.S.C. §12111(8) & (9), even in the face of the impact of DE SUZE’s multiple myeloma and 

chronic medical conditions because MARRINSON GROUP could have and should have provided 

DE SUZE with reasonable accommodation(s) including but not limited to time off, modified work 

schedule(s), and/or breaks from work because of Plaintiff’s medical conditions. 

40. On multiple occasions between approximately January 2019 and May 2019, 

MARRINSON GROUP subjected DE SUZE to disparate treatment and discrimination in violation 

of 42 U.S.C. §12112 which was motivated by DE SUZE’s disability and Defendant discriminated 

against DE SUZE because of his disability in violation of 42 U.S.C. §12112, including but by 

MARRINSON GROUP, inter alia: (a) denying DE SUZE’s request for a reasonable 

accommodation for Plaintiff’s disability; and (b) terminating DE SUZE’s employment in May 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 9 of 35
10 

2019 based upon false and/or pretextual grounds because of Plaintiff’s actual or perceived 

disability. 

41. MARRINSON GROUP terminated DE SUZE’s employment in May 2019 because 

of DE SUZE’s actual and/or perceived disability, in violation of 42 U.S.C. §12112(a). 

42. The reasons proffered by MARRINSON GROUP in May 2019 for terminating DE 

SUZE’s employment were false and a pretext for discrimination against DE SUZE because of his 

disability in violation of 42 U.S.C. §12112(a).

43. MARRINSON GROUP knowingly and willfully engaged in conduct prohibited by 

the ADA and ADAAA against DE SUZE because of his disability so as to discourage, dissuade 

and/or otherwise dishearten DE SUZE. 

44. DE SUZE’s actual and/or perceived disability was a motivating factor in 

MARRINSON GROUP’s decision to terminate DE SUZE’s employment in May 2019, in violation 

of 42 U.S.C. §12112. 

45. MARRINSON GROUP’s violations of the ADA and ADAAA were intentional and 

were done with malice or reckless indifference to DE SUZE’s rights guaranteed under the laws of 

the United States.

46. DE SUZE has suffered and continues to suffer loss of earnings, emotional distress, 

loss of self-esteem and other injuries as a direct result of MARRINSON GROUP’s violations of 

the ADA and ADAAA. 

47. DE SUZE has retained the undersigned counsel to represent him in this action and 

pursuant to 42 U.S.C. §12205, DE SUZE is entitled to recover all reasonable attorneys’ fees and 

costs from MARRINSON GROUP. 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 10 of 35
11 

WHEREFORE, Plaintiff, PRISGAR DE SUZE demands judgment against Defendant, 

MARRINSON GROUP, INC., for back pay, employment benefits, other compensation including 

bonuses, compensatory damages, punitive damages, equitable relief including but not limited to 

reinstatement and/or front pay, injunctive relief, interest, attorneys’ fees, costs, expert fees and 

such other and further relief as this Honorable Court deems proper.

COUNT II 

RETALIATION IN VIOLATION OF THE AMERICANS WITH DISABILITIES ACT

Plaintiff, PRISGAR DE SUZE, reasserts and reaffirms the allegations of Paragraphs 1 

through 28 as if fully set forth herein and further states that this is an action against MARRINSON 

GROUP, INC. for Retaliation in violation of the Americans with Disabilities Act, 42 U.S.C. 

§12203, as amended through the ADA Amendments Act of 2008, P.L. 110-325, § 2, 122 Stat. 

3553. 

48. The Americans with Disabilities, ADA and ADAAA, 42 U.S.C. §12203(a), 

provides that: “No person shall discriminate against any individual because such individual has 

opposed any act or practice made unlawful by this chapter or because such individual made a 

charge, testified, assisted or participated in any manner in an investigation, proceeding or hearing 

under this chapter.” 

49. Similarly, the ADA and ADAAA also provide, 42 U.S.C. §12203(b), that it shall 

“be unlawful to coerce, intimidate, threaten, or interfere with any individual in the exercise or 

enjoyment of, or an account of his or her having exercised or enjoyed, or on account of his or her 

having aided or encouraged any other individual in the exercise or enjoyment of, any right granted 

or protected by this chapter.” 

50. At all times material to this action, DE SUZE was an individual with a “disability” 

as defined by the ADA and ADAAA, 42 U.S.C. § 12102(1), because Plaintiff (a) suffered physical 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 11 of 35
12 

impairments that substantially limited one or more major life activities; (b) had a record of such 

impairments; and/or (c) was regarded by MARRINSON GROUP as a person with such 

impairments.

51. DE SUZE was at all times material to this action a “qualified individual” as that 

term is defined by the ADA and ADAAA, 42 U.S.C. §12111(8), because Plaintiff was able to 

satisfactorily perform the essential functions of his job as a Porter-Custodian for MARRINSON 

GROUP between approximately January 2019 and May 2019 with or without reasonable 

accommodation. 

52. DE SUZE engaged in statutorily protected activity under the ADA and ADAAA on 

multiple occasions between approximately January 2019 and May 2019 by, inter alia, DE SUZE

exercising or attempting to exercise or enjoy his rights under the ADA, including but not limited 

to: (a) requesting an accommodation for his disability; (b) submitting the April 2019 “Certification 

of Healthcare Provider Form” in connection with his disability; and (c) communicating to both 

Steven Jones and Bill Savage about DE SUZE’s repeated attempts to resume working in May 2019 

at MANOR PINES.

53. MARRINSON GROUP subjected DE SUZE to adverse employment actions 

including but not necessarily limited to terminating DE SUZE’s employment in May 2019 based 

upon false and/or pretextual grounds because of Plaintiff’s good faith objection to discrimination 

because of an actual or perceived disability, all because DE SUZE engaged in statutorily protected 

activity under the ADA and ADAAA. 

54. MARRINSON GROUP’s retaliatory actions against DE SUZE constitute 

violations of the ADA and ADAAA, which prohibits employers from discriminating against an 

individual because he has opposed any act or practice made unlawful under the ADA/ADAAA, 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 12 of 35
13 

42 U.S.C. §12203(a), and also prohibits employers from coercing, intimidating, threatening, or 

interfering with any individual in the exercise or enjoyment of rights under the ADA/ADAAA on 

account of him having exercised or enjoyed or attempted to exercise or enjoy such rights, 42 U.S.C. 

§12203(b). 

55. MARRINSON GROUP’s termination of DE SUZE’s employment in May 2019

was unlawful retaliation in violation of 42 U.S.C. §12203 because of Plaintiff’s request for 

accommodations and Plaintiff’s good faith objections to and complaints about MARRINSON 

GROUP’s disparate treatment and disability discrimination, in violation of the ADA.

56. The fact that DE SUZE engaged in activity protected by the ADA was a motivating 

factor in MARRINSON GROUP’s termination of Plaintiff’s employment in May 2019, in 

violation of 42 U.S.C. §12203. 

57. The reasons proffered by MARRINSON GROUP in May 2019 for terminating DE 

SUZE’s employment were a pretext for unlawful retaliation against DE SUZE in violation of 42 

U.S.C. §12203. 

58. As a direct and proximate result of MARRINSON GROUP’s unlawful retaliation 

against DE SUZE in violation of the ADA, Plaintiff has suffered damages and has been deprived 

of job-related economic benefits, all in amounts to be established at trial.

59. MARRINSON GROUP’s actions have caused DE SUZE to suffer damages for 

emotional distress, mental anguish, loss of enjoyment of life, and other non-pecuniary losses. 

60. MARRINSON GROUP’s actions were undertaken intentionally, willfully, and 

maliciously with respect to, or with malice and/or reckless disregard for, DE SUZE’s federally 

protected rights under the ADA, as a result of which Plaintiff is entitled to punitive damages from 

Defendant. 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 13 of 35
14 

61. Pursuant to 42 U.S.C. §12205, DE SUZE is entitled to recover all reasonable 

attorneys’ fees and costs from Defendant’s as a result of MARRINSON GROUP’s violations of 

the ADA’s anti-retaliation provisions. 

WHEREFORE, Plaintiff, PRISGAR DE SUZE, demands judgment against Defendant, 

MARRINSON GROUP, INC., for back pay, employment benefits, other compensation including 

bonuses, compensatory damages, punitive damages, equitable relief including but not limited to 

reinstatement and/or front pay, injunctive relief, interest, attorneys’ fees, costs, expert fees and 

such other and further relief as this Honorable Court deems proper. 

JURY TRIAL DEMAND

PRISGAR DE SUZE demands trial by jury on all issues so triable. 

Dated: June 23, 2020 Respectfully submitted, 

 By: s/KEITH M. STERN 

 Keith M. Stern, Esquire 

 Florida Bar No. 321000 

 E-mail: employlaw@keithstern.com 

 LAW OFFICE OF KEITH M. STERN, P.A.

 80 S.W. 8th Street, Suite 2000 

 Miami, Florida 33132 

 Telephone: (305) 901-1379 

 Facsimile: (561) 288-9031 

Attorneys for Plaintiff 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 14 of 35
EXHIBIT A

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 15 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 16 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 17 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 18 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 19 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 20 of 35
EXHIBIT B 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 21 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 22 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 23 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 24 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 25 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 26 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 27 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 28 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 29 of 35
EXHIBIT C 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 30 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 31 of 35
EXHIBIT D 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 32 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 33 of 35
EXHIBIT E 

Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 34 of 35
Case 0:20-cv-61226-WPD Document 1 Entered on FLSD Docket 06/23/2020 Page 35 of 35