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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NUMBER: ____________________

CAMMIE HARDING,

Plaintiff,

vs.

J&T MANAGEMENT, INC. 

d/b/a MCDONALD’S,

Defendant.

______________________________________/

COMPLAINT

COMES NOW, Plaintiff, CAMMIE HARDING, by and through her undersigned 

counsel, and sues the Defendant, J&T MANAGEMENT, INC. d/b/a MCDONALD’S, and 

alleges as follows:

INTRODUCTION

1. This is a proceeding for damages to redress the deprivation of rights secured to 

the Plaintiff by the Family and Medical Leave Act, 29 U.S.C. 2601-2654 (“FMLA”), as 

temporarily modified pursuant to the Families First Coronavirus Response Act (“FFCRA”), 

Public Law 116-127..

JURISDICTION AND VENUE

2. The Court has jurisdiction over their controversy based upon the FMLA and 

FFCRA, and venue is proper as all acts described herein occurred within this judicial district. 

PARTIES

3. At all times material hereto, the Plaintiff was/is a citizen of the United States, sui 

juris, and an employee of the Defendant.

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4. At all times material hereto, the Plaintiff was an employee and member of a 

protected class within the meaning of the FMLA and the FFCRA.

5. At all times material hereto, Defendant was a Florida Corporation doing business 

and services in this judicial district, was the employer or former employer of the Plaintiff, and is 

an employer as defined by the FMLA and FFCRA.

EXHAUSTION OF ADMINISTRATIVE REMEDIES

6. The Plaintiff has exhausted and fulfilled all conditions precedent to the institution 

of this action.

STATEMENT OF FACTS

7. The Plaintiff was an employee for the Defendant since April of 2018. 

8. Plaintiff returned from a cruise on February 8, 2020, and two days later began to 

feel ill. 

9. Plaintiff notified management and was moved to drinks, but was still concerned, 

given the spreading of COVID-19. 

10. The next day, February 11, 2020, Plaintiff had a very high fever but still came to

work. 

11. The next day, feeling worse, Plaintiff asked to leave early, and was told not to 

come in the next day. 

12. On February 16, 2020, Plaintiff then went into work to see the schedule and 

noticed that she was off the schedule completely. 

13. When asking why, Plaintiff learned that she was terminated for job abandonment. 

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COUNT I

FFCRA INTERFERENCE

14. The Plaintiff incorporates by reference paragraphs 1-13 herein.

15. At all times material to this lawsuit, the Plaintiff was entitled to benefits afforded

under the FMLA as temporarily modified by the FFCRA.

16. The Defendant unlawfully interfered with the Plaintiff’s exercise of her FFCRA

rights by denying her benefits that she was afforded. 

17. As a direct and proximate result of the Defendant’s unlawful treatment, the 

Plaintiff has suffered damages and will continue to suffer irreparable injury and damages in the 

future, under the FMLA as temporarily modified by the FFCRA.

18. The Plaintiff is entitled to an award of reasonable attorney's fees, expert fees, 

costs and expenses related to this litigation under the FMLA as temporarily modified by the 

FFCRA.

WHEREFORE, the Plaintiff, CAMMIE HARDING, requests that judgment be entered 

against the Defendant for all damages recoverable under the FMLA as temporarily modified by 

the FFCRA, 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.

DEMAND FOR JURY TRIAL

The Plaintiff demands a jury trial.

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Dated: July 2, 2020. Respectfully submitted,

Law Offices of Levy & Levy, P.A.

1000 Sawgrass Corporate Parkway, Suite 588

Sunrise, Florida 33323

Telephone: (954) 763-5722

Facsimile: (954) 763-5723

Counsel for Plaintiff

/s/ Chad Levy

CHAD E. LEVY, ESQ.

chad@levylevylaw.com

Secondary: assistant@levylevylaw.com

F.B.N.: 0851701

DAVID M. COZAD, ESQ.

david@levylevylaw.com

F.B.N.: 333920

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