UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI-DADE DIVISION

CRYSTAL HARRIS, CASE NO.: 1:20 CV 22890 

Plaintiff, COMPLAINT

 Plaintiff Demands a Trial by Jury

v.

CELLCO PARTNERSHIP D/B/A 

VERIZON WIRELESS, 

Defendant. 

__________________________________/

 Plaintiff, CRYSTAL HARRIS, through her counsel, hereby complains of the Defendant 

CELLCO PARTNERSHIP D/B/A VERIZON WIRELESS, and alleges as follows:

NATURE OF CASE

1. Plaintiff complains pursuant to 42 U.S.C. § 1981 (“§ 1981”), Title VII of the Civil Rights 

Act of 1964, as codified, 42 U.S.C. §§ 2000e to 2000e-17 (amended in 1972, 1978 and by 

the Civil Rights Act of 1991, Pub. L. No. 102-166 (“Title VII”); and the Florida Civil Rights

Act of 1992, Section 760.10 et seq. (“FCRA”) and seeks damages to redress the injuries 

Plaintiff suffered as a result of being exposed to race discrimination, color discrimination, 

sex/gender discrimination, sexual orientation discrimination, hostile work environment, 

retaliation, intentional infliction of emotional distress, and negligent retention.

2. This action is to redress Defendant’s unlawful employment practices against Plaintiff, 

including Defendant’s unlawful discrimination and harassment against Plaintiff because of 

her race, color, sex/gender and sexual orientation, Defendants’ retaliation against Plaintiff 

because of her persistent complaints of discrimination, and Plaintiff’s unlawful termination.

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JURISDICTION AND VENUE

3. This is an action for monetary damages relief pursuant to § 1981, Title VII, and FCRA § 

760.10. 

4. This Court has jurisdiction of the claims herein pursuant to 28 U.S.C. §§ 1331 and 1343, as 

this action involves federal questions regarding deprivation of Plaintiff’s civil rights under § 

1981 and Title VII.

5. This Court has supplemental jurisdiction over Plaintiff’s related claims arising under state 

law pursuant to 28 U.S.C. §1367(a). 

6. Venue is proper in this district pursuant to 28 U.S.C. §1391(b) because Defendants were 

located in this judicial district, and a substantial part of the events or omissions giving rise to 

this action, including the unlawful employment practices alleged herein occurred in this 

district.

PROCEDURAL REQUIREMENTS

7. Plaintiff has complied with all statutory prerequisites to file this action.

8. On or around June 6, 2019, Plaintiff dual filed her charge with the Equal Employment 

Opportunity Commission (“EEOC”), Case number 10186854 and EEOC Charge Number: 

510-2019-02255

9. An EEOC filing automatically operates as a dual FCHR filing.

10. On or around March 14, 2020, Plaintiff received the EEOC’s Right to Sue Letter in reference 

to her EEOC charge. 

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11. Due to COVID-19 and other circumstances, an agreement was made between Plaintiff and 

Defendant to toll the deadline to file this complaint. Thereafter, Plaintiff timely filed this 

complaint. 

PARTIES

12. At all material times, Plaintiff CRYSTAL HARRIS, (hereinafter referred to as “Plaintiff” or 

“FLORENCE”) is an individual African American and black woman who is currently a 

resident of the State of Florida.

13. At all material times, Plaintiff identifies as a Lesbian.

14. At the time of the facts giving rise to this complaint, Plaintiff, FLORENCE lived in MiamiDade, Florida.

15. At all material times, Defendant CELLCO PARTNERSHIP D/B/A VERIZON WIRELESS 

(hereinafter referred to as “Defendant” or “VERIZON”) is a foreign profit corporation duly 

existing by the virtues and laws of the State of Florida that does business in the State of 

Florida.

16. At all material times, Defendant VERIZON is a corporation duly existing by the virtues and 

laws of the State of New Jersey and does business in the State of Florida.

17. At all material times, VERIZON employed the Plaintiff, FLORENCE and in the state of 

Florida and while living in Miami-Dade County.

18. At all material times, CHASE CHIAMARDAS and BRANDON POE were VERIZON 

Managers, and was Plaintiff’s Supervisors.

STATEMENT OF FACTS

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19. At all material times, VERIZON is an American telecommunications company which offers 

wireless products and services. 

20. In or around June 2014, VERIZON hired Plaintiff and she began working for VERIZON in 

Alabama. 

21. In or around June 2018, VERIZON promoted Plaintiff and transferred her from a store in 

Huntsville, Alabama to Florida. This promotion was a part of the company’s Women of 

Wireless in Leadership Development Program. 

22. At all material times before this move, Plaintiff had an excellent employment record with no 

significant history of disciplinary, attendance or performance issues.

23. In June 2018, once Plaintiff transferred to her new Florida location, she worked as a 

Solutions Manager. 

24. At all material times, Plaintiff was the only black female and only black LGBTQ female in 

the new Florida location she worked from. Moreover, there were few females in leadership 

roles she worked along side. 

25. At all material times, CHASE CHIAMARDAS was one of Plaintiff’s Supervisor while 

working for VERIZON. He was a white male employee and understood to be heterosexual. 

26. At all material times, ANDREW SHEETS was one of Plaintiff’s Supervisor while working 

for VERIZON. He was a white male employee and understood to be heterosexual.

27. At all material times, VERNON EARLY was one of Plaintiff’s Supervisor while working for 

VERIZON. He was a white male employee and understood to be heterosexual.

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28. At all material times, LASAUN DAVIS was one of Plaintiff’s Supervisor while working for 

VERIZON. He was an African-American male employee and understood to be heterosexual.

29. At all material times, BRANDON POE was one of Plaintiff’s Supervisor while working for 

VERIZON. He was a white male employee and understood to be heterosexual.

30. At all material times, JORGE ZAPATA was one of Plaintiff’s Supervisor while working for 

VERIZON. He was a Hispanic male employee and understood to be heterosexual.

31. At all material times, KWAME TROTAN was one of Plaintiff’s Supervisor while working 

for VERIZON. He was an African-American male employee and understood to be 

heterosexual.

32. The above men, CHIAMARDAS, SHEETS, EARLY, DAVIS, POE, ZAPATA, and 

TROTAN are hereinafter referred to as the “comparators.”

33. Because of her race, color, sex, and sexual orientation, VERIZON routinely subjected 

Plaintiff to overly strict reprimands for failing to come into the store on time. In contrast, 

when other comparators—other men—would do the same, VERIZON would chose not to 

enforce company’s policy and they were not as unfavorably reprimanded. 

34. Plaintiff was not adequately trained in certain areas like her comparators which created 

staffing issues in maintaining adequate number of employees in the store, nor received the 

same benefits, resources or accommodations, such as use of a company vehicle for WOW 

events and often excluded out of company engagements. 

35. The VERIZON’s failure to (1) adequately train and support Plaintiff’s store with the 

resources, (2) to properly staff, and (3) schedule her stores constantly created violations in 

the security procedures beyond Plaintiff’s control, VERIZON which was well aware of.

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36. Intending to set Plaintiff up for termination, VERIZON placed Plaintiff on nine (9) months 

of probation unlike her male counterparts, many of those listed above who committed the 

same business practices yet where not placed on probation or retaliated against with 

probation. Nor were these comparators eventually terminated for such violations of 

company policy. 

37. Plaintiff made complaints to VERIZON personnel and her managers on or November 2018 

thru February 22, 2019.

38. Plaintiff alleges that throughout 2018- 2019, she was subjected to a denial of equitable 

treatment while employed and frequent hostile comments by VERIZON’s employees and 

supervisors on account of her race, color, sexual orientation and national origin such as: 

comments about complaints “always” coming from women and excluding her from 

company functions

39. VERIZON would routinely deviate from its own company policy when it came to 

comparators that were similarly situated, while ruling with an iron fist when it came towards 

Plaintiff, even if she was not at fault. By way of example, VERIZON’s failure to adequately 

train and support her store with the resources to properly staff and schedule her stores 

casually created violations in the security procedures while doing so for other stores in the 

area.

40. VERIZON failed to provide such Company resources and staffing to Plaintiff because she 

was the only African-American black female and only African-American black LGBTQ 

female. 

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41. When Plaintiff became aware of the bias treatment toward her, she made several attempts to 

resolve the issues internally at VERIZON by complaining of the above unlawful 

discrimination to General Manager DAVIS, District Manager POE, Director ZAPATA, and 

Regional HR Manager KEENAN. 

42. Despite complaining of the above unlawful discrimination, VERIZON, General Manager 

DAVIS, District Manager POE, Director ZAPATA, and Regional HR Manager KEENAN 

did nothing to correct the situation or provide reasonable assurances to Plaintiff that 

VERIZON would address her complaints. 

43. Moreover, that Plaintiff’s complaints were ignored by VERIZON and that nothing was done 

about such complaints. 

44. During Plaintiff’s transfer and when she continued to exercise her complaint male 

colleagues and/or supervisors commented, “it’s always a woman,” who makes complaints. 

45. On once instance the VERIZON argue that Plaintiff was the only one working in the store at 

times, and was in violation of store security policy, but VERIZON fails to provide the 

alternative to what Plaintiff should have done if the stores were not receiving proper 

resources to staff more than just her. 

46. Despite fearing for her own safety, VERIZON offered no other alternatives to Plaintiff other 

than opening up her store alone if she was the only employee scheduled.

47. After Plaintiff continued complaints to VERIZON about this issue, instead of protecting her, 

she was wrongfully written up for violating the two-person policy amount other defendable 

allegations that one person can simply just not do. Her District supervisors failed to properly 

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and adequately train Plaintiff nor provide her with the proper support and resources other 

stores and comparators received.

48. Plaintiff received no response or conclusion from VERIZON about her initial discrimination 

complaints and was instead terminated on or about February 22, 2019.

49. Plaintiff was terminated in retaliation on or about February 22, 2019 for making her 

discrimination complaint as part of a protected activity in addition to questioning her write 

up on tardies when her comparators had not been written up the same and received more 

favorable treatment.

50. Plaintiff does not appear to have violated company policy nor does VERIZON present any 

evidence of such occurring or prior to her 2019 termination. More importantly her tardies do 

not serve as the basis for the Company’s termination, and are a delayed response to her 

discrimination complaint. 

51. During Plaintiff employment with VERIZON, she witnessed several occasions where 

employees of the Defendant VERIZON, discriminated African American VERIZON’s 

employees and made sexist comments to women. 

52. By way of example, Defendant VERIZON’s male employees and supervisors frequently 

discriminated against African American and black employees in the workplace by referring 

to them with emphithets and would say, “loud and ghetto”

53. Defendant VERIZON’ employees above comments shocked and greatly offended Plaintiff.

54. At all material times, Defendant VERIZON male employees did not made such comments to 

Verizon’s male employees.

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55. Due to the continuing sexual comments by DefendantVERIZON’s employees, it appeared to 

Plaintiff that Verizon had not taken adequate steps to prevent continued unlawful conduct by 

DefendantVERIZON. 

56. On or about February 22, 2019, VERIZON terminated Plaintiff instead of resolving the 

issues she complained of.

57. At all material times, VERIZON terminated Plaintiff in retaliation for having exercised a 

protected activity and complaining of her discrimination and harassment while employed. At 

all material times, Plaintiff complained about discrimination and harassment on the basis of 

her race (African-American), her sex(female), and sexual orientation (lesbian).

58. The above are just some of the examples of unlawful discrimination and retaliation to which 

the Respondent subjected Claimant following her race, color, national origin, sex, and 

because she opposed the unlawful discrimination of Respondents. Based on the 

circumstances described herein, Respondent unlawfully discriminated against Claimant on 

the basis of her sex/gender, race, color, and national origin. Based on the above, Claimant 

believes that she was discriminated against and terminated by Respondent due to her race, 

color, national origin, sex, and for her opposition to the unlawful conduct in violation of 

Title VII of the 1964 Civil Rights Act as amended, and applicable state and city laws.

59. The above are just some of the examples of unlawful and discriminatory conduct to which 

Defendants subjected Plaintiff. 

60. Through Defendants’ repeated continuous unlawful conduct, discrimination, retaliation, and 

sexual harassment, Defendants’ subjected Plaintiff to an ongoing hostile environment, which 

lead to her termination.

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61. At all material times, Defendant VERIZON knew or should have known of the company’s 

repeated continuous unlawful conduct, discrimination, and sexual harassment, as described 

above.

62. At all material times, Defendant VERIZON knew or should have known of the company’s 

retaliatory acts and that Plaintiff’s termination was a retaliatory act.

63. At all material times, Defendant VERIZON failed to adequately respond to the company’s 

unlawful conduct and failed to prevent the retaliatory acts and that Plaintiff’s termination.

64. Plaintiff claims a continuous practice of discrimination and claims a continuing violation 

and makes all claims herein under the continuing violations doctrine.

65. Defendant discriminated against and retaliated against Plaintiff because of her sex/gender, 

race, color, sexual orientation and because she complained or opposed the unlawful conduct 

of Defendants related to the above-protected classes.

66. At all material times, Defendant’s above unlawful conduct interfered and discouraged 

Plaintiff from continuing her employment with Defendant and from complaining.

67. At all material times, Plaintiff opposed and complained of Defendant’s ongoing 

discrimination, retaliation, and unlawful conduct. 

68. As a result of Defendant’s actions, Plaintiff felt extremely humiliated, degraded, victimized, 

embarrassed and severely emotionally distressed.

69. As a result of Defendant’s continued harassment of Plaintiff, she suffered numerous injuries 

including physical, economic, and emotional damages. 

70. As a result of the acts and conduct complained of herein, Plaintiff has suffered and will 

continue to suffer the loss of income, the loss of salary, bonuses, benefits and other 

compensation which such employment entails, and Plaintiff also suffered future pecuniary 

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losses, emotional pain, anxiety, depression, loss of sleep, humiliation, inconvenience, loss of 

enjoyment of life, and other non-pecuniary losses. 

71. Plaintiff further claims aggravation, activation, and/or exacerbation of any preexisting 

condition.

72. At all times material, Defendant and its supervisors acted with deliberate indifference to the 

discrimination and retaliation Plaintiff faced.

73. Plaintiff claims unlawful constructive and/or unlawful actual discharge and also seeks 

reinstatement

74. As Defendant’s conduct has been malicious, willful, outrageous, and conducted with full 

knowledge of the law, Plaintiff demands Punitive Damages against Defendant. 

COUNT I: DISCRIMINATION 

UNDER TITLE VII

[AGAINST DEFENDANT VERIZON]

75. Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in the 

previous paragraphs 1 to 74.

76. Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-2. [Section 703] 

states in relevant part as follows: 

(a) Employer Practices; it shall be an unlawful employment practice for an 

employer - (1) to fail or refuse to hire or to discharge any individual, or otherwise 

to discriminate against any individual with respect to her/his compensation, terms, 

conditions, or privileges of employment, because of such individual’s race, color, 

religion, sex, or national origin.

77. Throughout 2018, Defendant VERIZON allowed their managers to engage in discriminatory 

practices which resulted in Plaintiff being subjected to a discriminatory hostile work 

environment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. §2000e et 

seq., as amended. 

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78. Defendant’s harassment of Plaintiff was, in whole or in part because she was a woman, 

African American, black, and a lesbian.

79. Defendants engaged in unlawful employment practices prohibited by 42 U.S.C. §2000e et 

seq., by discriminating against Plaintiff because of her race, color, sexual orientation, and 

sex/gender.

COUNT II: RETALIATION

UNDER TITLE VII

[AGAINST DEFENDANT VERIZON]

80. Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in the 

previous paragraphs 1 to 74.

81. Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §2000e-3(a) provides that it 

shall be unlawful employment practice for an employer: 

“(1) to . . . discriminate against any of his employees . . . because [s]he has 

opposed any practice made an unlawful employment practice by this subchapter, 

or because [s]he has made a charge, testified, assisted or participated in any 

manner in an investigation, proceeding, or hearing under this subchapter.” 

82. Defendant subjected Plaintiff to unlawful discrimination at the workplace based on his 

conduct toward and comments about women and African Americans.

83. Plaintiff engaged in protected activity when she opposed Defendant’s unlawful acts and 

complained of his acts to VERIZON’s HR department and VERIZON’s upper management.

84. Because of Plaintiff’s complaints of unlawful discrimination, Defendant subjected Plaintiff 

to increased duties, increased scrutiny, and terminated her. 

85. The Defendant’s harassment of Plaintiff was, in whole or in part, in retaliation for her 

complaints of discrimination. 

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86. The Defendant VERIZON has discriminated against and harassed the Plaintiff in the terms 

and conditions of her employment in retaliation for her lawfully having engaged in 

statutorily protected activity and as a result of her complaints of discrimination.

87. At all material times, Defendant VERIZON knew of the hostile work environment and failed 

to take prompt remedial action or steps to reassure Plaintiff that complaints of discrimination 

would be quickly corrected.

88. Defendant VERIZON engaged in unlawful employment practice prohibited by 42 U.S.C. 

§2000e et seq. by retaliating against Plaintiff with respect to the terms, conditions or 

privilege of employment because of her opposition to the unlawful employment practices of 

Defendant.

COUNT III: FCRA §760.10

DISCRIMINATION

[AGAINST DEFENDANT]

89. Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in the 

previous paragraphs 1 to 74.

90. At all times relevant to this action, Plaintiff was and is a woman, lesbian, African American, 

and black. 

91. Throughout 2018 and 2019, Defendant VERIZON allowed their manager to Defendant 

REINMUTH to engage in discriminatory practices which resulted in Plaintiff being 

subjected to a discriminatory hostile work environment in FCRA. 

92. Defendant’s harassment of Plaintiff was, in whole or in part because she was a woman, a 

lesbian, African American, and black.

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93. Defendants are prohibited under the FCRA from discriminating against Plaintiff because of 

her sex/gender, race, and color with regard to discharge, employee compensation, and other 

terms, conditions, and privileges of employment. 

94. Defendants violated the FCRA by unlawfully discriminating against Plaintiff based her sex/

gender, sexual orientation, race, and color.

95. Plaintiff has been damaged by the illegal conduct of Defendants. 

COUNT IV: FCRA

RETALIATION

[AGAINST DEFENDANT]

96. Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in the 

previous paragraphs previous paragraphs 1 to 74.

97. Defendant REINMUTH subjected Plaintiff to unlawful discrimination at the workplace 

based on his conduct toward and comments about women and African Americans.

98. Plaintiff engaged in protected activity when she opposed Defendant REINMUTH’s unlawful 

acts and complained of his acts to VERIZON’s HR department and VERIZON’s upper 

management.

99. Because of Plaintiff’s complaints of unlawful discrimination, Defendant REINMUTH 

subjected Plaintiff to increased duties, increased scrutiny, and terminated her. 

100.The Defendants’ harassment of Plaintiff was, in whole or in part, in retaliation for her 

complaints of discrimination. 

101.The Defendants has discriminated against and harassed the Plaintiff in the terms and 

conditions of her employment and has denied the Plaintiff continued employment in 

retaliation for her lawfully having engaged in statutorily protected activity and as a result of 

her complaints of discrimination. 

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102.At all material times, Defendants knew of the hostile work environment and failed to take 

prompt remedial action or steps to reassure Plaintiff that complaints of discrimination would 

be quickly corrected.

COUNT V: NEGLIGENT RETENTION DEFENDANT

[AGAINST DEFENDANT VERIZON]

103.Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in the 

previous paragraphs previous paragraphs 1 to 74.

104.Defendant VERIZON negligently retained Defendant VERIZON’s managers.

105.Defendant VERIZON knew or should have known that Defendant VERIZON’s managers 

were dangerous, incompetent, and a threat to do harm to employees under his supervision or 

working in their office. 

106.Defendant VERIZON negligently retained Defendant VERIZON’s supervisors and Human 

Resource employees based on their failure to respond to and address unlawful acts in their 

office.

107.Defendant VERIZON knew or should have known that VERIZON’s manager Defendant 

REINMUTH and Human Resource employees were dangerous, incompetent, and a threat to 

do harm to employees under their supervision or working in their office. 

108.As direct and proximate consequences of Defendant VERIZON's negligent retention of such 

managers and employees, Plaintiff has suffered serious physical, psychological, and 

emotional injuries that have required, or will require in the future, medical and 

psychological treatment

COUNT VI: DISCRIMINATION 

UNDER FEDERAL LAW 42 U.S.C. § 1981

[AGAINST DEFENDANT VERIZON]

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109.Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in the 

previous paragraphs 1 to 74.

110.42 USC § 1981 states in relevant part as follows:

(a) Statement of equal rights All persons within the jurisdiction of the United 

States shall have the same right in every State and Territory to make and enforce 

contracts, to sue, be parties, give evidence, and to the full and equal benefit of all 

laws and proceedings for the security of persons and property as is enjoyed by 

white citizens, and shall be subject to like punishment, pains, penalties, taxes, 

licenses, and exactions of every kind, and to no other. (b) “Make and enforce 

contracts” defined For purposes of this section, the term “make and enforce 

contracts” includes the making, performance, modification, and termination of 

contracts, and the enjoyment of all benefits, privileges, terms, and conditions of 

the contractual relationship. 42 U.S.C.A. § 1981.

111.Plaintiff, an African American and black woman, was discriminated against by Defendants 

because of her race, ancestry and ethnicity as provided under 42 USC § 1981 and has 

suffered damages as set forth herein. 

112.Plaintiff claims that Defendants unlawfully discriminated against and terminated Plaintiff 

because of her race, ancestry and ethnicity.

113.At all material times, Plaintiff’s termination and increased duties by Defendants was a 

"significant change" in employment status.

114.Plaintiff was discriminated against by Defendants because of her race, ancestry and ethnicity 

as provided under 42 USC Section 1981 and has suffered damages as set forth herein. 

115.Defendants allowed the unlawful discrimination towards Plaintiff and employees of her 

same race, ancestry and ethnicity to continue.

COUNT VII: RETALIATION 

UNDER FEDERAL LAW 42 U.S.C. § 1981

[AGAINST DEFENDANT VERIZON]

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116. Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in the 

previous paragraphs 1 to 74.

117. 42 USC § 1981 states in relevant part as follows:

(a) Statement of equal rights All persons within the jurisdiction of the United 

States shall have the same right in every State and Territory to make and enforce 

contracts, to sue, be parties, give evidence, and to the full and equal benefit of all 

laws and proceedings for the security of persons and property as is enjoyed by 

white citizens, and shall be subject to like punishment, pains, penalties, taxes, 

licenses, and exactions of every kind, and to no other. (b) “Make and enforce 

contracts” defined For purposes of this section, the term “make and enforce 

contracts” includes the making, performance, modification, and termination of 

contracts, and the enjoyment of all benefits, privileges, terms, and conditions of 

the contractual relationship. 42 U.S.C.A. § 1981.

118. Plaintiff, an African American and black woman, was discriminated against by Defendants 

because of her race, ancestry and ethnicity as provided under 42 USC § 1981 and has 

suffered damages as set forth herein. 

119.Defendant subjected Plaintiff to unlawful discrimination at the workplace based on his 

conduct toward and comments about women and African Americans.

120.Plaintiff engaged in protected activity when she opposed Defendant’s unlawful acts and 

complained of his acts to VERIZON’s HR department and VERIZON’s upper management.

121.Because of Plaintiff’s complaints of unlawful discrimination, Defendant subjected Plaintiff 

to increased duties, increased scrutiny, and terminated her. 

122.The Defendant’s harassment of Plaintiff was, in whole or in part, in retaliation for her 

complaints of discrimination. 

123.The Defendant’s has discriminated against and harassed the Plaintiff in the terms and 

conditions of her employment and has denied the Plaintiff continued employment in 

retaliation for her lawfully having engaged in statutorily protected activity and as a result of 

her complaints of discrimination. 

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124.At all material times, Defendant’s knew of the hostile work environment and failed to take 

prompt remedial action or steps to reassure Plaintiff that complaints of discrimination would 

be quickly corrected.

125.Plaintiff claims unlawful retaliation under 42 U.S.C. 1981 for opposition to Defendant’s 

unlawful employment practices and has suffered damages as set forth herein.

WHEREFORE, the Plaintiff requests that judgment be entered against the Defendants 

VERIZON, for damages, including compensatory, consequential, punitive damages if 

subsequently permitted by this Court, and all equitable relief, in addition to all litigation 

expenses and costs, including attorneys' fees and any other lawful and equitable relief this Court 

deems to be just and proper.

JURY DEMAND

Plaintiff requests a jury trial on all issues to be tried. 

Dated: July 13, 2020

 Miami, Florida 

 Respectfully submitted,

 Ligon Law Group, LLC d/b/a PrettySMART Law 

 ___________________________

 Shannon A. Ligon, Esquire

 Fla Bar No.: 59191

 100 Biscayne Blvd. #1114 

 Miami, FL 33132 

 Phone: 888.779.7426

 Fax 305.675.6190

 Email: PrettySMARTLaw@gmail.com

 Attorneys for Plaintiff

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 13, 2020, I electronically filed the foregoing document 

with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is 

being served this day on all counsel of record or pro se parties identified on the attached 

Service List in the manner specified, either via transmission of the Notices of Electronic 

filing generated by CM/ECF or in some other authorized manner for those counsel or parties 

who are not authorized to receive electronically transmitted Notices of Electronic Filing.

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