EXHIBIT “B”

Case 9:20-cv-80993-WPD Document 92-2 Entered on FLSD Docket 07/28/2021 Page 1 of 3
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Alicia Kendrick

From: Daniel R. Levine

Sent: Monday, October 12, 2020 5:09 PM

To: Chad Levy

Cc: Alex Ershock; Alicia Kendrick

Subject: RE: JTR adv. O'Bryan

Attachments: Tim O'Bryan 2020 records.pdf

Of course – I didn’t realize we had not provided copies – see attached

Daniel R. Levine, Esquire

*Board Certified in Labor & Employment Law – The Florida Bar

*Arbitrator & Mediator ‐ American Arbitration Association  

3837 NW Boca Raton Blvd., Suite 200 | Boca Raton, FL  33431

Main: 561.544.8900 | Facsimile: 561.544.8999

**For the latest legal news and topics, sign up for the PBL BLOG **

DRL@PBL‐Law.com |  www.PBL‐Law.com

This email is intended solely for the use of the individual to whom it is addressed and may contain information that is privileged, confidential or otherwise exempt from disclosure

under applicable law.  If the reader of this email is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient, you are

hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited.  If you have received this communication in error, please immediately

notify us by telephone and return the original message to us at the listed email address.  Thank You.  

From: Chad Levy <chad@levylevylaw.com>  

Sent: Monday, October 12, 2020 5:04 PM

To: Daniel R. Levine <DRL@pbl‐law.com>

Cc: Alex Ershock <ABE@pbl‐law.com>; Alicia Kendrick <ak@pbl‐law.com>

Subject: RE: JTR adv. O'Bryan

Dan‐this motion is the same you said before, with the exception of cc, which is the first time this has been mentioned

and has not been provided.  If you want to forward a copy of these notes I can review them.  But none of it changes the

undisputed fact that on or about 4/16 he was tested, and on 4/20 he was positive, only to be fired while he was waiting

for his COVID positive results.  

Two weeks (up to 80 hours) of paid sick leave at the employee’s regular rate of pay where the employee is unable to

work because the employee is quarantined (pursuant to Federal, State, or local government order or advice of a health

care provider), and/or experiencing COVID‐19 symptoms and seeking a medical diagnosis;  

Dr. Newcomer is, in essence, irrelevant, because he was experiencing symptoms and was seeking diagnosis by waiting

for his test results, in compliance with the statute.  But regardless I will see what you have if you want to send it over.

Chad E. Levy, Esq.

PADULA BENNARDO LEVINE 

COLL &ORAllVE LEGAL SOLUl,ONS FOR IODAY'S BUSINESS NEEDS 

Case 9:20-cv-80993-WPD Document 92-2 Entered on FLSD Docket 07/28/2021 Page 2 of 3
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www.levylevylaw.com

The Law Offices of Levy & Levy, P.A. 

1000 Sawgrass Corporate Parkway, Suite 588 

Sunrise, Florida 33323 

Telephone: (954) 763-5722 

Facsimile: (954) 763-5723 

Electronic: chad@levylevylaw.com 

From: Daniel R. Levine <DRL@pbl‐law.com>  

Sent: Monday, October 12, 2020 4:32 PM

To: 'Chad Levy' <chad@levylevylaw.com>

Cc: Alex Ershock <ABE@pbl‐law.com>; Alicia Kendrick <ak@pbl‐law.com>

Subject: JTR adv. O'Bryan

Chad –

As previously indicated, my client feels very strongly about this matter and has insisted upon placing you on notice of

defendants’ intent to seek sanctions under Rule 11 unless the complaint is withdrawn.

I do not relish serving this type of motion on you, but again, my client feels very strongly about it.

Please review and advise.

Daniel R. Levine, Esquire

*Board Certified in Labor & Employment Law – The Florida Bar

*Arbitrator & Mediator ‐ American Arbitration Association  

3837 NW Boca Raton Blvd., Suite 200 | Boca Raton, FL  33431

Main: 561.544.8900 | Facsimile: 561.544.8999

**For the latest legal news and topics, sign up for the PBL BLOG **

DRL@PBL‐Law.com |  www.PBL‐Law.com

This email is intended solely for the use of the individual to whom it is addressed and may contain information that is privileged, confidential or otherwise exempt from disclosure

under applicable law.  If the reader of this email is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient, you are

hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited.  If you have received this communication in error, please immediately

notify us by telephone and return the original message to us at the listed email address.  Thank You.  

T orT ~ .L..J'oA-D"' --... 

LEVY & LEVY. P.A. 

PA.DUL .A BENNA.R.DO LEVI " E 

S 0 ' US 5 E 

Case 9:20-cv-80993-WPD Document 92-2 Entered on FLSD Docket 07/28/2021 Page 3 of 3