EXHIBIT 1

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IN THE CIRCUIT COURT OF THE 

11TH JUDICIAL CIRCUIT IN AND FOR 

MIAMI DADE COUNTY, FLORIDA 

ROBIN VELEZ 

 Plaintiff, 

vs. Case No. 

NEOCIS, INC., a Foreign Corporation 

 Defendant. 

________________________________________/ 

COMPLAINT 

 Plaintiff ROBIN VELEZ, (hereinafter “Plaintiff” or “VELEZ”) by and through her 

undersigned attorney hereby sues defendant NEOCIS, INC, a Foreign Corporation (hereinafter, 

"Defendant"), a corporation, and says: 

JURISDICTION AND VENUE 

1. This is an action for damages exceeding $30,000 excluding attorneys’ fees or costs and other 

relief based on unlawful employment practices committed by Defendant and jurisdiction of 

this Court is invoked pursuant to the provisions of Title VII of the Civil Rights Act of 1964, § 

706(f) (42 U.S.C. § 2000e-5(f)), the Americans with Disabilities Act (ADA), the Americans 

with Disabilities Act Amendments Act (ADAAA) 42 U.S.C. §§ 12101 et seq., the Florida Civil 

Rights Act (“FCRA”), §§ 760.01-760.11 and the Family and Medical Leave Act of 1993, 

(“FMLA”) 29 U.S.C. §§ 2601, et. seq.

2. This Court has jurisdiction of the claims herein pursuant to the FCRA, 29 U.S.C. § 2617, and 

28 U.S.C. § 1331. 

3. The claims asserted in this Complaint arose in Miami Dade County, Florida during the course 

of Plaintiff’s employment with Defendant.

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4. Venue is proper in this Court since Plaintiff was employed by Defendant in Miami-Dade, 

Florida. 

PARTIES 

5. Plaintiff is a resident of Miami-Dade County Florida and over the age of eighteen and 

otherwise sui juris. 

6. Plaintiff is a female individual with a disability or perceived disability. She is therefore a 

member of a class protected under Title VII, the ADA, the ADAA, and the FCRA because the 

terms, conditions, and privileges of her employment were altered because of her gender and/or 

her request for reasonable accommodation. 

7. Further, Plaintiff was retaliated against for her complaints of discriminatory conduct on behalf 

of Defendant and/or because of her requests for reasonable accommodation which places her 

within a class protected under Title VII, the ADA, the ADAA and the FCRA. 

8. Defendant is a foreign corporation with its principal place of business in Miami and authorized 

to do business in Florida. 

9. Defendant has, at all times material, employed 15 or more employees for each working day in 

each of twenty or more calendar weeks in the current or preceding year in accordance with 

Title VII, the ADA, the ADAA and the FCRA (42 U.S.C. §2000e(b); Fla. Stat. §760.02(7)). 

10. Plaintiff has exhausted her administrative remedies by filing a timely charge of discrimination 

("Charge") against the Defendant with the Equal Employment Opportunity Commission which 

was dually filed with the Florida Commission on Human Relations. 

11. Plaintiff’s Charge was filed on or about August 2, 2019. The actions complained of herein 

occurred within 300 days thereof and/or continued from that date stemming from the same 

actions set forth in the Charge. 

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12. Plaintiff was constructively terminated from her position on or about July 8, 2019. Her Charge 

was therefore timely filed. 

13. Plaintiff was issued a Notice of Right to Sue on June 11, 2020. This suit is filed in accordance 

with that Notice and within the applicable 90-day time limitation. 

14. The Florida Commission on Human Relations did not issue a finding on Plaintiff’s charge 

within 180 days of the filing of said charges. 

15. All other conditions precedent to this action have been performed or have been waived. 

GENERAL ALLEGATIONS 

16. Plaintiff was hired by Defendant in June 2017, as a purchasing agent. Plaintiff was the only 

female agent in the purchasing department. 

17. At the beginning of Plaintiff’s employment, Ms. Jessica Sonnenfeld (“Sonnenfeld”) was the 

supply chain manager and Plaintiff’s direct supervisor. 

18. Based on Plaintiff’s tenure with the company, positive performance and positive work history 

through her employment, Plaintiff was fully qualified for her position at the time all 

discriminatory events complained herein occurred. 

19. While Defendant allowed a male dominated culture to permeate the workplace throughout 

Plaintiff’s employment, the disparate treatment began on or about February 2019, when Ms. 

Sonnenfeld left. Mr. Juan Salcedo began the disparate treatment towards meand then Mr. Jon 

Anderson (“Anderson”) became the new supply chain director and Plaintiff’s direct supervisor. 

20. From the outset, Anderson treated her differently than her male counterparts in virtually all 

respects of the work environment. Plaintiff was excluded from communications, ridiculed and 

ignored during meetings and denied any help or support by Anderson. 

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21. Anderson further participated in misogynistic behavior within the workplace environment 

where everyone at Plaintiff’s level or above was male, other than Plaintiff. 

22. Starting on or about February 22 2019, Plaintiff complained to Human Resources, specifically 

Mr. Erik Beuckelaers (Beuckelaers), HR director, about the disparate treatment she was being 

subjected to. Specifically, Plaintiff complained that Anderson did not provide the requisite job 

support incumbent of him as her supervisor, ignored her suggestions and took her off of

projects without reason and gave those projects to her male counterparts. 

23. Anderson then retaliated against Plaintiff for her complaints to human resources by bullying 

Plaintiff, removing flexible work hours and denying Plaintiff the ability to work from home. 

Anderson also refused to give Plaintiff an explanation of what was expected of her and singled 

Plaintiff out by asking her to move desks. 

24. Anderson’s conduct carried over to other male counterparts of Plaintiff’s and supervisors, who 

began subjecting Plaintiff to the same level of disparaging remarks and related inappropriate 

conduct. Anderson also refused to assist Plaintiff in her work projects in a manner consistent 

with how he treated her male counterparts. 

25. Anderson was quick to admonish Plaintiff if there was any delay in completion of her tasks 

but permitted male employees to be significantly behind in reporting. 

26. Plaintiff continued complaining about the harassment, continued disparate treatment and the 

intimidation/retaliation to Beuckelaers, Alon Mozes, and Ezell Raudez, between February 

through July 2019. 

27. As a result of the harassment, Plaintiff was diagnosed with anxiety. Anxiety is a disability 

under the ADA, the ADAAA, and the FCRA in that it substantially impairs Plaintiff’s major 

life activities as defined by the ADA and ADAAA. Specifically, it substantially impairs 

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Plaintiff’s ability to, at minimum, concentrate, evaluate, and communicate/interact with others. 

The ability to concentrate, evaluate, and communicate/interact with others are considered 

“major life activities” as defined by the ADA and ADAAA. 

28. The anxiety Plaintiff experienced was so acute, Plaintiff had stomach issues and migraines. 

29. Plaintiff made multiple requests to Beuckelaers and Mozes in human resources to be removed 

from the hostile work environment and requested time off while the situation was addressed as 

a reasonable accommodation all to no avail. 

30. Instead, Plaintiff was told by Beuckelaers and Mozes that she was too sentivie and perhaps 

purchasing was not for her. Beuckelaers suggested that Plaintiff should consider looking for a 

position as an office manager which would be more suitable. Upon information and belief, no

disciplinary action was taken against Anderson. 

31. Furthermore, on or about June 19, 2019, Plaintiff submitted a request for FMLA. 

32. However, Defendant failed to provide Plaintiff with the reasonable accommodation requested. 

33. Plaintiff’s request for FMLA was ignored. Plaintiff was required to provide additional 

paperwork to excuse absences and was not provided any reasonable accommodation. 

34. On or about July 9, 2019, Mozes advised Plaintiff that her claims were found to be baseless 

and she had to return to work by July 12, 2019. 

35. The work conditions created a hostile work environment which were an immediate threat to 

Plaintiff’s life. Therefore, Plaintiff had no other choice but to resign. 

36. Defendant acted with intentional disregard for Plaintiff’s rights under Title VII, ADA, ADAA 

and the FCRA. 

37. Defendant’s justification(s) for its treatment of Plaintiff, if any, are a mere pretext for unlawful 

discrimination and retaliation. 

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38. If, however, the reason(s) proffered by Defendant are found to be with merit, Plaintiff’s gender, 

complaints of discrimination, and/or request for leave were motivating factor(s) in the decision 

for the adverse employment action(s). 

39. Plaintiff has retained the undersigned firm to prosecute this action on her behalf and has agreed 

to pay it a reasonable fee for its services. 

40. Plaintiff is entitled to her reasonable attorneys’ fees and costs if she is the prevailing party in 

this action. 

COUNT I 

VIOLATION OF THE CIVIL RIGHTS ACT 

(DISCRIMINATION BASED ON SEX) 

41. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-39 of this 

complaint as if set out in full herein. 

42. Plaintiff brings this action under Title VII of the Civil Rights Act of 1964, §§706(a) and 

706(g) for damages caused by Defendant’s unlawful employment practices committed 

against Plaintiff. 

43. Plaintiff is a member of a protected class, to wit, female. 

44. Defendant, by and through its supervisors and HR representatives, did not treat Plaintiff the 

same as other male employees. 

45. Anderson acted on behalf of Defendant and acted within the scope of his duties. 

46. At all times material hereto, the Defendant failed to comply with the Civil Rights Act of 1964 

[42 U.S.C. 2000 e-2 (a)], which states, “It shall be an unlawful employment practice for an 

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

discriminate against any individual with respect to his compensation, terms, conditions, or 

privileges of employment, because of such individual's race, color, religion, sex, or 

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national origin; or (2) to limit, segregate, or classify his employees or applicants for 

employment in any way which would deprive or tend to deprive any individual of 

employment opportunities or otherwise adversely affect his status as an employee, 

because of such individual's race, color, religion, sex, or national origin.”

47. Defendant’s decision to discriminate against Plaintiff was because of Plaintiff’s gender. 

48. The Plaintiff was subjected to disparate treatment in the workplace, in that similarly situated, 

male employees were allowed better work opportunities by not being subjected to unfair 

treatment. 

49. At the time of this treatment from employment, the Plaintiff did perform and excel at the 

performance of the essential functions assigned to her by Defendant. 

50. The Plaintiff was qualified for the position apart from her apparent gender. 

51. The Defendant is a sophisticated employer who has actual knowledge of the requirements of 

Title VII of the Civil Rights Act of 1964, as amended. 

52. The failure of Defendant to adhere to the mandates of the Act was willful and its violations 

of the provisions of the Act were willful. 

53. Defendant, through its practices and policies as an employer, willfully, and with malicious or 

reckless disregard of Plaintiff’s federally protected rights, discriminated against Plaintiff on 

account of her gender in violation of Act with respect to its decision to treat Plaintiff different 

from other employees. 

54. Defendant’s disparate treatment of Plaintiff including but not limited to Plaintiff’s

termination from employment was directly and proximately caused by the Defendant’s 

unjustified discrimination against Plaintiff because of the fact that she was a female, in 

violation of the Act. 

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55. If, however, the reason(s) proffered by Defendant are found to be with merit, Plaintiff’s 

gender, was a motivating factor in the decision for the adverse employment action(s). 

56. As a direct and proximate result of the Defendant’s intentional conduct, Plaintiff suffered 

serious economic losses as well as mental pain and suffering. 

57. Plaintiff is entitled to such affirmative relief as may be appropriate, including, but not limited 

to, lost wages, benefits, and compensation for emotional distress, pursuant to the provisions 

of Title VII of the Civil Rights Act of 1964, §706(g). 

58. Plaintiff, based on information and belief, alleges that Defendant’s actions were done with 

malice, and with intentional disregard for her protected rights under Title VII of the Civil 

Rights Act of 1964. Defendant, by and through their officers, and/or supervisors, authorized, 

condoned, and/or ratified the unlawful conduct of Anderson, and/or other employees. 

Therefore, Plaintiff is also entitled to punitive damages from Defendant in a sum according 

to proof at trial. 

WHEREFORE, Plaintiff respectfully requests that: 

A. The Court grant Plaintiff judgment award Plaintiff judgment against Defendant to 

compensate her for past and future pecuniary losses, including injury to her professional 

reputation, and emotional pain and suffering caused by Defendant’s discriminatory 

treatment in an amount to be determined at trial and in accordance with the Civil Rights 

Act of 1964, §706(g); 

B. The Court award punitive damages as permitted under the law; 

C. The Court award Plaintiff the costs of this action together with her reasonable attorney’s 

fees incurred herein, pursuant to contract and/or statute; and 

D. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the full 

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benefits Plaintiff would have had Plaintiff not been discriminated against by Defendant, 

or in lieu of reinstatement, award front pay; 

E. The Court award Plaintiff such other and further relief as the Court deems appropriate. 

COUNT II 

VIOLATION OF THE CIVIL RIGHTS ACT 

(RETALIATION) 

59. Plaintiff incorporates herein the allegations contained in paragraphs 1–39, inclusive, as though 

same were fully re-written, and says: 

60. Plaintiff is a member of a protected class under Title VII, to wit she complained of 

discriminatory treatment. 

61. Plaintiff complained to Defendant’s Human Resources department, as set forth above, about 

the harassment to which she was subjected, the preference Anderson had towards male 

employees in the department, and unfounded disciplinary actions. 

62. The conduct of Defendant, by and through the conduct of its agents, employees, and/or 

representatives, and the Defendant’s failure to make prompt remedial action to prevent 

continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights under 

federal law. 

63. Plaintiff, based on information and belief, alleges that Defendant’s actions were done with 

malice, and with disregard for her protected rights under the Title VII. Defendant, by and 

through its officers, and/or supervisors, authorized, condoned, and/or ratified the unlawful 

conduct of Anderson and/or other employees. Therefore, Plaintiff is also entitled to punitive 

damages from Defendant in a sum according to proof at trial. 

64. Defendant’s stated reason(s) for terminating Plaintiff is pretextual. 

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65. If, however, the reason(s) proffered by Defendant are found to be with merit, Plaintiff’s 

complaints of discrimination, were a motivating factor in the decision for the adverse 

employment action(s). 

WHEREFORE, Plaintiff respectfully requests that: 

A. The Court grant Plaintiff judgment award Plaintiff judgment against Defendant to 

compensate her for past and future pecuniary losses, including appropriate back pay, 

benefits' adjustment, injury to her professional reputation, and emotional pain and 

suffering caused by Defendant’s discriminatory treatment in an amount to be determined 

at trial and in accordance with the Civil Rights Act of 1964, §706(g); 

B. The Court award punitive damages as permitted under the law; 

C. The Court award Plaintiff the costs of this action together with her reasonable attorney’s 

fees incurred herein, pursuant to contract and/or statute; and 

D. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the full 

benefits Plaintiff would have had Plaintiff not been discriminated against by Defendant, 

or in lieu of reinstatement, award front pay; 

E. The Court award Plaintiff such other and further relief as the Court deems appropriate. 

COUNT III 

FAILURE TO ACCOMMODATE IN VIOLATION OF THE ADA AND ADAAA 

66. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-39 of this 

complaint as if set out in full herein. 

67. Plaintiff is disabled as she suffers from anxiety which is an impairment which substantially 

limits one or more major life activities. 

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68. Plaintiff is, and at all times was, qualified to perform the essential functions of her job with or 

without a proposed reasonable accommodation. Plaintiff is therefore a “qualified individual” 

as that term is defined in the Americans With Disabilities Act, as amended (“ADAAA”) § 

101(8) (42 U.S.C. § 12111(8)). 

69. Defendant failed to provide Plaintiff with a reasonable accommodation as that term is defined 

in the ADAAA, § 101(9). Plaintiff requested that she have extended time off from work as 

well as intervention to address the harassment she was being subjected to. These requests were 

reasonable and would not have caused Defendant undue hardship. 

70. As a result of Defendant’s actions, Plaintiff has suffered damages in an amount to be proven 

at the time of the trial of this cause. 

71. Plaintiff is informed, believes and alleges that pursuant to ADAAA § 107(a) (42 U.S.C. § 

12117(a)), Plaintiff is entitled to damages because of Defendant’s willful conduct in denying 

her request(s). 

WHEREFORE, Plaintiff requests judgment against Defendant as follows: 

A. Actual damages as a result of Defendant’s discriminatory actions;

B. Punitive damages due to Defendant’s willful behavior;

C. Compensatory damages; 

D. Injunctive relief where feasible; 

E. Attorney’s fees;

F. Costs of this action; and 

G. Any other relief this Court deems proper. 

COUNT IV 

VIOLATION OF THE ADA AND ADAAA (RETALIATION) 

72. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-39 of this 

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complaint as if set out in full herein. 

73. Plaintiff requested reasonable accommodation(s) for her disability. This request was made to 

Buckelaers and Mozes who knew of Plaintiff’s disability. 

74. As a direct result of Plaintiff’s requests for a reasonable accommodation, Plaintiff was 

subjected to disparate treatment and harassment without valid reason. 

75. Plaintiff’s constructive termination constitutes an adverse employment action under the ADA 

and ADAAA. 

76. Plaintiff, based on information and belief, alleges that Defendant’s actions were done with 

malice, and with disregard for her protected rights under the ADA and ADAAA. Defendant, 

by and through its officers, and/or supervisors, authorized, condoned, and/or ratified the 

unlawful conduct of employees. Therefore, Plaintiff is also entitled to punitive damages from 

Defendant in a sum according to proof at trial. 

77. Defendant’s stated reason(s) for denying Plaintiff’s request for accommodation is pretextual. 

78. If, however, the reason(s) proffered by Defendant are found to be with merit, Plaintiff’s

complaints of discrimination and requests for reasonable accommodation, was a motivating 

factor in the decision for the adverse employment action(s). 

 WHEREFORE, Plaintiff requests that: 

A. The Court grant Plaintiff judgment award Plaintiff judgment against Defendant to 

compensate him for past and future pecuniary losses, including injury to his 

professional reputation, and emotional pain and suffering caused by Defendant’s 

discriminatory and retaliatory treatment in an amount to be determined at trial and in 

accordance with the ADA and ADAAA. 

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B. The Court award Plaintiff the costs of this action together with his reasonable 

attorney’s fees incurred herein, pursuant to contract and/or statute; and

C. The Court award Plaintiff such other and further relief as the Court deems appropriate. 

COUNT V 

HANDICAP/DISABILITY DISCRIMINATION UNDER THE FCRA 

79. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-39 of this 

complaint as if set out in full herein. 

80. Section 760.10 of the FCRA states in relevant part: 

(1) it is unlawful employment practice for an employer: 

(a) to discharge or to fail or refuse to hire any individual, or otherwise to discriminate 

against any individual with respect to compensation, terms, conditions, or privileges of 

employment, because of such individual's race, color, religion, sex, natural origin, age, 

handicap, or marital status. 

81. The FCRA accordingly prohibits employers from taking adverse employment action against 

an employee as a result of his actual handicap/disability, as a result of an employee's record of 

having such handicap/disability, and/or because the employer regards the employee as 

handicapped/disabled, and further requires employers to reasonably accommodate the actual 

handicaps/disabilities and/or records of such handicaps/disabilities of their employees. 

82. Specifically, Plaintiff alleges that Defendant wrongfully denied her reasonable requests for an 

accommodation to her disability. 

83. The adverse and disparate treatment to which Plaintiff was subjected by Defendant, including 

but not limited to, Plaintiff's constructive termination, as set forth above, was the direct and 

proximate result of Plaintiff's actual disability, which substantially limited her in one or more 

major life activities, and/or Plaintiff's record of having such disability. 

84. Defendant's alleged bases for its adverse treatment of Plaintiff, if any, are pretextual and 

asserted only to cover up the discriminatory nature of its conduct. 

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85. Even if Defendant could assert legitimate reasons for its adverse and disparate treatment of 

Plaintiff, which reasons it did not/does not have, Plaintiff's actual handicap(s)/disability and/or 

Plaintiff's record of having such a disability were also motivating factors for Defendant's 

adverse treatment of Plaintiff. 

86. As a result of the discriminatory conduct to which Plaintiff was subjected, 

Plaintiff has experienced, and will continue to experience, significant financial and economic 

loss in the form of lost wages. Plaintiff has also experienced, and will continue to experience, 

emotional anguish, pain and suffering and loss of dignity damages. Plaintiff accordingly 

demands lost economic damages, lost wages, back pay, interest, front pay, the value and/or 

economic impact of lost benefits, and compensatory damages. 

87. Based on information and belief, alleges that Defendant’s actions were done with malice, and 

with disregard for his protected rights under FCRA. Defendant, by and through its officers, 

and/or supervisors, authorized, condoned, and/or ratified the unlawful conduct of Defendant’s 

employees. Therefore, Plaintiff is also entitled to punitive damages from Defendant in a sum 

according to proof at trial. 

WHEREFORE, Plaintiff requests judgment against Defendant as follows: 

A. Adjudge and decree that Defendant has violated FCRA, and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights;

B. Enter a judgment requiring that Defendant pay Plaintiff appropriate back pay, benefits' 

adjustment, and prejudgment interest at amounts to be proved at trial for the unlawful 

employment practices described herein; 

C. Enter an award against Defendant and award Plaintiff compensatory damages for mental 

anguish, personal suffering, and loss of enjoyment of life; 

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D. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the full 

benefits Plaintiff would have had Plaintiff not been discriminated against by Defendant, or 

in lieu of reinstatement, award front pay; 

E. Award Plaintiff the costs of this action, together with a reasonable attorney fees; and

F. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances. 

COUNT VI 

VIOLATION OF THE FLORIDA CIVIL RIGHTS ACT 

(DISCRIMINATION BASED ON SEX) 

88. Plaintiff re-avers and re-states paragraphs 1–39 above, as though the same were fully re-written 

herein, and says: 

89. Plaintiff brings this action under the Florida Civil Rights Act (“FCRA”), §§ 760.01-760.11 for 

damages caused by Defendant’s unlawful employment practices committed against Plaintiff 

because Plaintiff was subjected to a hostile work environment on the basis of her gender, 

Female. 

90. Plaintiff is a member of a protected class, to wit, female. 

91. Defendant, by and through its supervisors, by the conduct describe above, Defendant has 

engaged in discrimination against Plaintiff because of Plaintiff’s gender and subjected the 

Plaintiff to animosity based on her gender. 

92. Anderson’s actions toward Plaintiff were constant and pervasive.

93. The harassment was sufficiently severe or pervasive to alter the conditions of Plaintiff’s 

employment, such that a reasonable person would find the environment hostile. Plaintiff was 

unable to perform her day-to-day duties in an effective manner due to the constant remarks 

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about her sex and exclusion from meetings/correspondence which were essential to perform 

her job. 

94. Despite complaints, Anderson’s behavior was not addressed or corrected by Defendant, and 

further, grew in intensity. Defendant, by its inactivity, condoned Anderson's actions. 

95. As a direct and proximate result of Defendant’s willful actions, Plaintiff has suffered 

emotional distress and other compensatory and actual damages, and has been compelled to 

retain the services of counsel to represent her on this matter. 

96. Plaintiff is entitled to such affirmative relief as may be appropriate, including, but not limited 

to, pain and suffering, pursuant to the provisions of the FCRA. 

97. Plaintiff, based on information and belief, alleges that Defendant’s actions were done with 

malice, and with disregard for her protected rights under the FCRA. Defendant, by and through 

its officers, and/or supervisors, authorized, condoned, and/or ratified the unlawful conduct of 

Peterson and its other employees. Therefore, Plaintiff is also entitled to punitive damages from 

Defendant in a sum according to proof at trial. 

WHEREFORE, Plaintiff requests that: 

A. The Court grant Plaintiff judgment award Plaintiff judgment against Defendant to 

compensate her for past and future pecuniary losses, including appropriate back pay, 

benefits' adjustment, injury to her professional reputation, and emotional pain and suffering 

caused by Defendant’s discriminatory treatment in an amount to be determined at trial and 

in accordance with the Florida Civil Rights Act, §§ 760.01-760.11. 

B. The Court award punitive damages as permitted under the law; 

C. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the full 

benefits Plaintiff would have had Plaintiff not been discriminated against by Defendant, or 

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in lieu of reinstatement, award front pay; 

D. The Court award Plaintiff the costs of this action together with her reasonable attorney’s 

fees incurred herein, pursuant to contract and/or statute; and 

The Court award Plaintiff such other and further relief as the Court deems appropriate. 

COUNT VII 

VIOLATION OF THE FLORIDA CIVIL RIGHTS ACT 

(RETALIATION) 

98. Plaintiff re-alleges and re-avers paragraphs 1-39 as though full set forth herein. 

99. Plaintiff brings this claim under the Florida Civil Rights Act, Florida Statutes § 760.01 et seq.

for Defendant’s retaliatory conduct. 

100. Plaintiff complained to Defendant’s Human Resources department, as set forth above, 

about the harassment to which she was subjected, the preference Anderson had towards male 

employees in the department, and unfounded disciplinary actions. 

101. As a direct result of Plaintiff’s complaints of actions Plaintiff objectively perceived to be 

discriminatory in nature, Plaintiff was summarily disciplined, treated in a progressively worse 

manner, and subjected to a hostile work environment by Defendant. 

102. By the conduct describe above, Defendant retaliated against Plaintiff for exercising rights 

protected under the FCRA. 

103. As a result of Defendant’s actions, as alleged herein, Plaintiff has been deprived of rights, 

has been exposed to ridicule and embarrassment, and has suffered emotional distress and 

damage. 

104. The conduct of Defendant, by and through the conduct of its agents, employees, and/or 

representatives, and the Defendant’s failure to make prompt remedial action to prevent 

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continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights under 

state law. 

105. Plaintiff, based on information and belief, alleges that Defendant’s actions were done with 

malice, and with disregard for her protected rights under FCRA. Defendant, by and through its 

officers, and/or supervisors, authorized, condoned, and/or ratified the unlawful conduct of 

Anderson and/or other employees. Therefore, Plaintiff is also entitled to punitive damages 

from Defendant in a sum according to proof at trial. 

106. Defendant’s alleged reason(s) terminating Plaintiff (if any) are pretextual as described 

above. 

107. If, however, the reason(s) proffered by Defendant are found to be with merit, Plaintiff’s 

complaint(s) of discrimination, were a motivating factor in the decision for the adverse 

employment action(s). 

108. Plaintiff further seeks her attorney's fees and costs as permitted by law. 

WHEREFORE, Plaintiff respectfully requests judgment against Defendant as follows: 

A. The Court grant Plaintiff judgment award Plaintiff judgment against Defendant to 

compensate her for past and future pecuniary losses, including appropriate back pay, 

benefits' adjustment, injury to her professional reputation, and emotional pain and suffering 

caused by Defendant’s discriminatory treatment in an amount to be determined at trial and 

in accordance with the Florida Civil Rights Act, §§ 760.01-760.11. 

B. The Court award punitive damages as permitted under the law; 

C. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the full 

benefits Plaintiff would have had Plaintiff not been discriminated against by Defendant, or 

in lieu of reinstatement, award front pay; 

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D. The Court award Plaintiff the costs of this action together with her reasonable attorney’s 

fees incurred herein, pursuant to contract and/or statute; and 

E. The Court award Plaintiff such other and further relief as the Court deems appropriate. 

COUNT VIII 

VIOLATION OF THE FMLA (RETALIATION) 

109. Plaintiff re-alleges and re-avers the allegations contained in paragraphs 1–39 above as 

though the same were fully set forth herein. 

110. This is an action under the Family and Medical Leave Act of 1993 [29 U.S.C. §§ 2601 et 

seq.] for retaliation in violation of 29 U.S.C. § 2615(a)(1). 

111. Plaintiff was an employee covered by the FMLA in that she was employed for at least 12 

months and at least 1,250 hours prior to her request for leave due to her own medical condition 

on June 19, 2019. Plaintiff is therefore an "employee" under 29 U.S.C. § 2611(2). 

112. At all times relevant hereto, Defendant was a covered employer under the FMLA, 29 

U.S.C. § 2611(4)(A)(iii) in that it employed over 50 employees in 20 or more workweeks in

the current or preceding calendar year. 

113. Plaintiff gave sufficient notice to her employer of her need for leave under the FMLA and 

provided all necessary paperwork. 

114. Such leave was then denied by Plaintiff. Plaintiff was required to return to work despite 

her own medical condition. 

115. The fact that Plaintiff requested leave was a “protected activity” under the FMLA. 

116. Plaintiff’s leave request was, at minimum, a motivating factor in Defendant’s decision to 

terminate Plaintiff’s employment. 

117. Defendant’s purported reason(s) for terminating Plaintiff are pretextual. 

Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 20 of 36
20 

118. Defendant, by and through their officers, and/or supervisors, authorized, condoned, and/or 

ratified the unlawful conduct of other employees. Therefore, the actions of Defendant’s 

employees should be imputed to Defendant. 

119. Plaintiff has retained the services of the undersigned counsel and is obligated to pay 

attorney’s fees should she recover damages from the Defendant.

WHEREFORE, Plaintiff requests: 

A. Wages, salary, lost benefits, and any other compensation denied or lost to Plaintiff 

by reason of Defendant’s violation of the FMLA, all as provided in 29 U.S.C. § 

2617; 

B. Interest on the amount found due; 

C. Liquidated damages pursuant to 29 U.S.C. § 2617(a)(1)(A)(iii); 

D. Plaintiff’s cost of suit herein together with reasonable attorney’s fees incurred in 

this action; and 

E. Such other relief as the Court deems just and proper. 

COUNT IX 

VIOLATION OF THE FMLA (INTERFERENCE) 

120. Plaintiff re-alleges and re-avers the allegations contained in paragraphs 1–39 above as 

though the same were fully set forth herein. 

121. Plaintiff was eligible for FMLA leave for her own medical condition pursuant to 29 U.S.C. 

§ 2612(a)(1)(C). She requested leave pursuant to the statute on or about June 19, 2019 and 

submitted all required paperwork. 

122. Under the FMLA, 29 USC § 2614(a), Plaintiff had the right to take leave under the Act. 

123. When Defendant denied Plaintiff’s leave, Defendant interfered with Plaintiff’s right and 

thus violated the FMLA. 

Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 21 of 36
21 

124. As a direct result, Plaintiff has suffered, and will continue to suffer, a loss of wages and 

benefits. 

125. Defendant’s conduct was not done in good faith and Plaintiff is therefore entitled to 

liquidated damages in an amount equal to her loss of wages/benefits pursuant to the FMLA, 

29 U.S.C. § 2617(a). 

126. Defendant, by and through its officers, and/or supervisors, authorized, condoned, and/or 

ratified the unlawful conduct of its employees. 

127. Plaintiff has retained the services of the undersigned counsel and is obligated to pay 

attorney’s fees should she recover damages from the Defendant. 

128. Should Plaintiff prevail, Plaintiff is entitled to be awarded reasonable attorney’s fees and 

the costs of this action pursuant to 29 U.S.C. § 2617(a)(3). 

WHEREFORE, Plaintiff requests judgment for: 

A.Wages, salary, lost benefits, and any other compensation denied or lost to Plaintiff by 

reason of Defendant’s violation of the FMLA, all as provided in 29 U.S.C. § 2617; 

B. Interest on the amount found due; 

C. Liquidated damages pursuant to 29 U.S.C. § 2617(a)(1)(A)(iii); 

D. Plaintiff’s cost of suit herein together with reasonable attorney’s fees incurred in 

this action; and 

E. Such other relief as the Court deems just and proper. 

Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 22 of 36
22 

DEMAND FOR JURY TRIAL 

 Plaintiff ROBIN VELEZ demands trial by jury on all issues and all counts of this 

Complaint so triable as a matter of right. 

Dated: June 25, 2020 

PEREGONZA LAW GROUP, PLLC 

1414 NW 107th Ave, 

Suite 302 

Doral, FL 33172 

Tel. (786) 650-0202 

Fax. (786) 650-0200 

By: /s/Nathaly Saavedra 

Nathaly Saavedra, Esq. 

Fla. Bar No. 118315 

Email: nathaly@peregonza.com 

By: /s/Juan J. Perez 

Juan J. Perez, Esq. 

Fla. Bar No. 115784 

Email: juan@peregonza.com

Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 23 of 36
FORM 1.997. CIVIL COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of

pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the

Clerk of Court for the purpose of reporting data pursuant to section 25.075, Florida Statutes. (See instructions

for completion.)

I. CASE STYLE

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Case No.: _________________

Judge: ____________________

Robin Velez

Plaintiff

 vs.

Neocis, Inc.

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount of the claim rounded to the nearest dollar $500,000

III. TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the

most descriptive label is a subcategory (is indented under a broader category), place an x on both the main

category and subcategory lines.

☐ Condominium

☐ Contracts and indebtedness

☐ Eminent domain

☐ Auto negligence

☐ Negligence – other

 ☐ Business governance

 ☐ Business torts

 ☐ Environmental/Toxic tort

 ☐ Third party indemnification

 ☐ Construction defect

 ☐ Mass tort

 ☐ Negligent security

 ☐ Nursing home negligence

 ☐ Premises liability – commercial

 ☐ Premises liability – residential

☐ Products liability

☐ Real Property/Mortgage foreclosure

 ☐ Commercial foreclosure

 ☐ Homestead residential foreclosure

 ☐ Non-homestead residential foreclosure

 ☐ Other real property actions

 ☐ Professional malpractice

 ☐ Malpractice – business

 ☐ Malpractice – medical

 ☐ Malpractice – other professional

 ☒ Other

 ☐ Antitrust/Trade Regulation

 ☐ Business Transaction

 ☐ Circuit Civil - Not Applicable

 ☐ Constitutional challenge-statute or ordinance

 ☐ Constitutional challenge-proposed amendment

 ☐ Corporate Trusts

 ☒ Discrimination-employment or other

 ☐ Insurance claims

 ☐ Intellectual property

 ☐ Libel/Slander

 ☐ Shareholder derivative action

 ☐ Securities litigation

 ☐ Trade secrets

 ☐ Trust litigation

 ☐ County Civil

 ☐ Small Claims up to $8,000 

 ☐ Civil 

 ☐ Replevins

 ☐ Evictions

 ☐ Other civil (non-monetary)

 

Filing # 109410730 E-Filed 06/25/2020 02:51:40 PM Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 24 of 36
COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the

Administrative Order. Yes ☐ No ☒

IV. REMEDIES SOUGHT (check all that apply):

☒ Monetary;

☒ Non-monetary declaratory or injunctive relief;

☒ Punitive

V. NUMBER OF CAUSES OF ACTION: 

(Specify)

9

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

☐ Yes

☒ No

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

☒ No

☐ Yes – If “yes” list all related cases by name, case number and court:

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

 ☒ Yes

 ☐ No

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and

that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425.

Signature: s/ Juan J. Perez 

Attorney or party

FL Bar No.: 115784 

(Bar number, if attorney)

 Juan J. Perez

 (Type or print name)

 Date: 06/25/2020

Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 25 of 36
IN THE CIRCUIT COURT OF THE

11TH JUDICIAL CIRCUIT IN AND FOR 

MIAMI DADE COUNTY, FLORIDA

ROBIN VELEZ

 Plaintiff,

vs. Case No. 2020-013499-CA-01

NEOCIS, INC., a Foreign Corporation

 Defendant.

________________________________________/

SUMMONS IN A CIVIL CASE

TO: NEOCIS INC, through its Registered Agent: 

MOZES, ALON

2800 Biscayne Blvd

Suite 600

Miami, FL 33137

YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF’S ATTORNEY

NATHALY SAAVEDRA, ESQ.

PEREGONZA LAW GROUP, PLLC.

1414 NW 107TH AVE

SUITE 302

DORAL, FL 33172

an answer to the complaint which is herewith served upon you, within 20 days after service of this 

summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will 

be taken against you for the relief demanded in the complaint. You must also file your answer 

with the Clerk of this Court within a reasonable period of time after service.

______________________ ____________________

CLERK DATE

_____________________________________ 

(BY) DEPUTY CLERK

Filing # 109470601 E-Filed 06/26/2020 02:19:51 PM Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 26 of 36
Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 27 of 36
Filing # 109682529 E-Filed 07/01/2020 03:24:46 PM Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 28 of 36
Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 29 of 36
LEÓN COSGROVE, LLP 

255 ALHAMBRA CIR. I 8TH FLOOR I MIAMI, FL 33134 I T 305.740.1975 I WWW.LEONCOSGROVE.COM 

IN THE CIRCUIT COURT OF THE 11TH 

JUDICIAL CIRCUIT IN AND FOR MIAMIDADE COUNTY, FLORIDA 

ROBIN VELEZ, 

Plaintiff, 

v. 

NEOCIS, INC., a Foreign 

Corporation, 

Defendant. 

_____________________________________/ 

CASE NO. 2020-013499-CA-01 

NOTICE OF APPEARANCE AND DESIGNATION OF E-MAIL ADDRESSES 

Please take notice that Tiffany L. Anderson of the law firm of León Cosgrove, LLP appears 

in this case as counsel for Defendant Neocis, Inc. All parties are requested to forward copies of all 

correspondence and pleadings to the undersigned counsel at the address listed below. In addition, 

all pleadings and papers in this action shall be served by e-mail under Fla. R. Jud. Admin. 2.516 

on the following: 

Primary e-mail address Secondary e-mail 

Tiffany L. Anderson tanderson@leoncosgrove.com cmanzano@leoncosgrove.com

Dated: July 20, 2020 

Respectfully submitted, 

/s/ Tiffany L. Anderson 

Tiffany L. Anderson 

Florida Bar No. 83995 

LEÓN COSGROVE, LLP 

255 Alhambra Circle, 8th Floor 

Miami, Florida 33134 

Tel: 305.740.1975 

Fax: 305.437.8158 

 Email: tanderson@leoncosgrove.com 

Email: cmanzano@leoncosgrove.com 

Counsel for Defendant

Filing # 110460190 E-Filed 07/20/2020 10:24:32 AM Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 30 of 36
2 

LEÓN COSGROVE, LLP 

255 ALHAMBRA CIR. I 8TH FLOOR I MIAMI, FL 33134 I T 305.740.1975 I WWW.LEONCOSGROVE.COM 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on July 20, 2020, a true and correct copy of the foregoing was 

electronically filed with the Clerk of the Court and served via eService from the Florida Courts E-Filing 

Portal on the following: 

Nathaly Saavedra, Esq. 

Juan J. Perez, Esq. 

Peregonza Law Group, PLLC 

1414 NW 107th Avenue, Suite 302 

Doral, Florida 33172 

Email: nathaly@peregonza.com 

Email: juan@peregonza.com 

s/ Tiffany L. Anderson 

 Tiffany L. Anderson 

Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 31 of 36
LEÓN COSGROVE, LLP 

255 ALHAMBRA CIR. I 8TH FLOOR I MIAMI, FL 33134 I T 305.740.1975 I WWW.LEONCOSGROVE.COM 

IN THE CIRCUIT COURT OF THE 11TH 

JUDICIAL CIRCUIT IN AND FOR MIAMIDADE COUNTY, FLORIDA 

ROBIN VELEZ, 

Plaintiff, 

v. 

NEOCIS, INC., a Foreign 

Corporation, 

Defendant. 

_____________________________________/ 

CASE NO. 2020-013499-CA-01 

AGREED MOTION FOR EXTENSION OF TIME 

TO FILE A RESPONSE TO PLAINTIFF’S COMPLAINT 

Pursuant to Florida Rule of Civil Procedure 1.090(b), Defendant Neocis, Inc. 

(“Defendant”) hereby moves for an enlargement of time to file a response to Plaintiff Robin 

Velez’s (“Plaintiff”) Complaint (“Complaint”), and in support states as follows: 

1. On June 25, 2020, Plaintiff filed the Complaint in this case. 

2. On July 1, 2020, the Complaint was served on Defendant. 

3. This law firm was recently retained to represent Defendant in this matter. 

4. Plaintiff’s nine-count Complaint contains numerous allegations necessitating 

additional investigation before Defendant can form an appropriate response. 

5. Accordingly, Defendant respectfully requests a two-week extension of time to file 

a response to Plaintiff’s Complaint, up to and including, August 4, 2020. 

6. Defendant’s counsel contacted Plaintiff’s counsel regarding the requested relief and 

Plaintiff’s counsel agreed to this extension of time. 

7. The granting of this motion will not prejudice any party and is being sought in good 

faith and not for the purpose of delay. 

Filing # 110460190 E-Filed 07/20/2020 10:24:32 AM Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 32 of 36
2 

LEÓN COSGROVE, LLP 

255 ALHAMBRA CIR. I 8TH FLOOR I MIAMI, FL 33134 I T 305.740.1975 I WWW.LEONCOSGROVE.COM 

WHEREFORE, Defendant respectfully requests that this Court enter an Agreed Order 

granting this motion and enlarging Defendant’s time to file a response to Plaintiff’s Complaint, up 

to and including, August 4, 2020. 

Dated: July 20, 2020 

Respectfully submitted, 

/s/ Tiffany L. Anderson 

Tiffany L. Anderson 

Florida Bar No. 83995 

LEÓN COSGROVE, LLP 

255 Alhambra Circle, 8th Floor 

Miami, Florida 33134 

Tel: 305.740.1975 

Fax: 305.437.8158 

 Email: tanderson@leoncosgrove.com 

Email: cmanzano@leoncosgrove.com 

Counsel for Defendant

Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 33 of 36
3 

LEÓN COSGROVE, LLP 

255 ALHAMBRA CIR. I 8TH FLOOR I MIAMI, FL 33134 I T 305.740.1975 I WWW.LEONCOSGROVE.COM 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on July 20, 2020, a true and correct copy of the foregoing was 

electronically filed with the Clerk of the Court and served via eService from the Florida Courts E-Filing 

Portal on the following: 

Nathaly Saavedra, Esq. 

Juan J. Perez, Esq. 

Peregonza Law Group, PLLC 

1414 NW 107th Avenue, Suite 302 

Doral, Florida 33172 

Email: nathaly@peregonza.com 

Email: juan@peregonza.com 

s/ Tiffany L. Anderson 

 Tiffany L. Anderson 

Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 34 of 36
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO: 2020-013499-CA-01

SECTION: CA13

JUDGE: Alexander Bokor

Robin Velez

Plaintiff(s)

vs.

Neocis Inc

Defendant(s)

____________________________/

ORDER GRANTING DEFENDANT'S AGREED MOTION FOR EXTENSION OF TIME

TO FILE A RESPONSE TO PLAINTIFF'S COMPLAINT

THIS CAUSE came before the Court on Defendant Neocis, Inc.’s (“Defendant”) Agreed

Motion for Extension of Time to File a Response to Plaintiff Robin Velez’s (“Plaintiff”)

Complaint (“Motion”). The Court, having considered the Motion and being otherwise advised

that the parties are in agreement as to the relief sought in the Motion, ORDERS AND

ADJUDGES that Defendant’s Motion is GRANTED. Defendant shall have through and

including August 4, 2020 to respond to Plaintiff’s Complaint.

DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 29th day of July,

2020.

2020-013499-CA-01 07-29-2020 4:06 PM

Hon. Alexander Bokor

CIRCUIT COURT JUDGE

Electronically Signed

Case No: 2020-013499-CA-01 Page 1 of 2

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No Further Judicial Action Required on THIS MOTION

CLERK TO RECLOSE CASE IF POST JUDGMENT

Electronically Served:

Cynthia Manzano, cmanzano@leoncosgrove.com

Juan J. Perez, juan@peregonza.com

Juan J. Perez, eservice@peregonza.com

Juan J. Perez, office@peregonza.com

Nathaly Saavedra, nathaly@peregonza.com

Nathaly Saavedra, office@peregonza.com

Tiffany L. Anderson, tanderson@leoncosgrove.com

Tiffany L. Anderson, cmanzano@leoncosgrove.com

Tiffany L. Anderson, dzulueta@leoncosgrove.com

Physically Served:

Case No: 2020-013499-CA-01 Page 2 of 2

Case 1:20-cv-23161-DPG Document 1-2 Entered on FLSD Docket 07/30/2020 Page 36 of 36