EXHIBIT “3” 

REDACTED

Case 1:20-cv-23151-BB Document 1-3 Entered on FLSD Docket 07/29/2020 Page 1 of 9
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: ____________________

Kareem Pickering, Aaron Muhammad

Plaintiff

 vs.

Akal Security, Inc.

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount of the claim rounded to the nearest dollar $35,000

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 # 109701403 E-Filed 07/01/2020 09:14:17 PM Case 1:20-cv-23151-BB Document 1-3 Entered on FLSD Docket 07/29/2020 Page 2 of 9
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)

2

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/ Chad E. Levy 

Attorney or party

FL Bar No.: 851701 

(Bar number, if attorney)

 Chad E. Levy

 (Type or print name)

 Date: 07/01/2020

Case 1:20-cv-23151-BB Document 1-3 Entered on FLSD Docket 07/29/2020 Page 3 of 9
` Filing # 109840081 E-Filed 07/06/2020 05:33:50 P1VI 

XX IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

CIVIL DIVISION SUMMONS CASE NUMBER 

2020-013938-CA-01 

PLAINTIFF(S): vs. DEFENDANT(S) CLOCK IN 

Kareem Pickering Akal Security, Inc., Served 

and Aaron Muhammad, ~ l ~ 

~~ ~$~~ `_~ ~ ~_~ ___.~ 

,uu , r7 

r ~~ ~~~. 2~ ~,

is a ~z;du ~W Peozos ;; e~e~ ~~ 

THE STATE OF FLORIDA C4reu6t aind Couilzty Ceur'ts 

To Each Sheriff of the State: Gn and f®ll° the Seccnd Jr_sdyc°af C9reuBt 

YOU ARE COMMANDED to serve this summons and a copy of the Complaint or Petition, in this action on Defendant(s): Akal 

Security, Inc., by serving Registered Agent: 

Akal Security, Inc. 

Attn: Corporation Service Company, Registered Agent 

1201 Hays Street 

Tallahassee, Florida 32301 

Each Defendant is required to serve written defenses to the Complaint or Petition on Plaintiffs Attorney: 

CHAD E. LEVY, ESO. 

LEVY & LEVY, P.A. 

Whose Address is: 1000 Sawgrass Corporate Parkway 

Suite 588 

Sunrise, Florida 33323 

Telephone: (954) 763-5722 

Facsimile: (954) 763-5723 

Within 20 days afier service of this summons on that defendant, exclusive of the day of service, and to file the original of the 

defenses with the Clerk of this Court either before service on Plaintiff's attorney or immediately thereafter. If a Defendant fails to do 

so, a default will be entered against that Defendant for the relief demanded in the Complaint or Petition. 

HARVEY RUVIN DATE 

Seal 

Clerk of Courts By: -o' 71e` 

Deputy Clerk 

Case 1:20-cv-23151-BB Document 1-3 Entered on FLSD Docket 07/29/2020 Page 4 of 9
` Filing # 109701403 E-Filed 07/01/2020 09:14:17 PM 

IN THE CIRCUIT COURT OF THE 11Tx 

JUDICIAL CIRCUIT IN AND FOR 

MIAMI-DADE COUNTY, FLORIDA 

KAREEM PICKERING CASE NO.: 

and AARON MUHAMMAD, 

Plaintiffs, 

M19 

AKAL SECURITY, INC., 

Defendant. 

COMPLAINT 

COMES NOW, Plaintiffs, KAREEM PICKERING and AARON MUHAMMAD (hereafter 

referred to collectively as "Plaintiffs"), by and through their undersigned counsel, and sue the 

Defendant, AKAL SECURITY, INC., and alleges as follows: 

INTItODUCTION 

1. This is a proceeding for compensatory damages, punitive damages, and costs and 

attorneys' fees to remedy racial and national origin discrimination, affecting the terms, conditions 

and privileges of employment, and to redress the deprivation of rights secured to the Plaintiffs under 

by the Florida Civil Rights Act of 1992, Florida Statutes §760, et seg. ("FCRA") 

JURISDICTION AND VENUE 

2. Jurisdiction is invoked pursuant to the FCRA. 

3. Venue is proper as all claims asserted herein arose in Miami-Dade County. 

4. At all times material hereto, the Plaintiffs was/is a citizen of the United States, a 

resident of Miami-Dade County, Florida, sui juris, and an employee or former employee of the 

Defendant. 

Case 1:20-cv-23151-BB Document 1-3 Entered on FLSD Docket 07/29/2020 Page 5 of 9
5. At all times material hereto, the Plaintiffs were and continue to be AfricanAmericans, and are members of a protected class within the meaning of the FCRA. 

6. At all times material hereto, the Plaintiffs were employees within the meaning of the 

FCRA. 

7. At all times material hereto, the Defendant, upon information and belief, was a 

Florida corporation doing business in Miami-Dade County, an employer or former employer of the 

Plaintiffs, and was, and is, an employer within the meaning of the FCRA. 

EXHAUSTION OF ADMIlNIST1tATIVE ItE1VIEDIES 

8. The Plaintiffs has fulfilled all conditions precedent to the institution of this action. 

STATEMENT OF FACTS 

9. Mr. Pickering and Mr. Muhammed, both African-American males, were qualified 

individuals who began working for the Defendant as Transportation Detention Officer for 

approximately ten years and nine years, respectively. 

10. However, on September 19, 2018, Plaintiffs were both terminated for the pretextual 

reason of improper weapons handling, despite other similarly situated Hispanic employees 

committing similar or worse violations, such as taking a loaded shotgun into a secure facility and 

leaving the shotgun inside their vehicle. 

11. These officers were only given a short suspension. 

12. Additionally, there were two other Hispanic Officers who were watching a Mental 

Health Detainee that had committed suicide due to their negligence. 

13. The officers involved in this incident were subjected to better treatment as one officer 

was allowed to resign, while the other is still employed. 

14. Yet, in the Plaintiffs' situation, there was no such leniency and a clearly disparate 

Case 1:20-cv-23151-BB Document 1-3 Entered on FLSD Docket 07/29/2020 Page 6 of 9
treatment towards them for no reason other than the fact they are black and not Hispanic. 

COUNTI 

FCI2A --- RACE DISCRIMINA'I'ION 

15. The Plaintiffs incorporates by reference paragraphs 1- 14 herein. 

16. The Defendant discriminated against the Plaintiffs in the terms and conditions oftheir 

employment, and otherwise denied the Plaintiffs job opportunities because of their race. 

17. The unlawful discriminatory actions by the Defendant and its agents and employees, 

as set forth herein, were and are intentional, willful, malicious and with gross disregard for the 

Plaintiffs' rights, and violate the FCRA. 

18. As a direct and proximate result of the Defendant's unlawful and discriminatory 

treatment, the Plaintiffs has suffered damages and will continue to suffer irreparable injury and 

damages in the future, including, but not limited to: 

a. Damage to reputation, confidence and self-esteem; 

b. Loss of past and future income; 

C. Loss of future earning capacity; 

d. Loss of other fringe benefits; 

C. Stress, anxiety and emotional distress; 

f. Significant past and future pain and suffering; and 

g. Other financial losses. 

19. The Plaintiffs is entitled to an award of reasonable attorney's fees, expert fees, costs 

and expenses related to this litigation. 

WHEREFORE, the Plaintiffs, KAREEM PICKERING and AARON MUHAMMAD, 

requests that judgment be entered against the Defendant THE DEFENDANT AMERICAS 

CORPORATION, for damages; including compensatory, consequential, and punitive, and all 

Case 1:20-cv-23151-BB Document 1-3 Entered on FLSD Docket 07/29/2020 Page 7 of 9
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. 

COUNT II 

FCRA -- NATIONAL ORIGIN DISCRIMINATION 

20. The Plaintiffs incorporates by reference paragraphs 1- 14 herein. 

21. The Defendant discriminated against the Plaintiffs in the terms and conditions of their 

employment, and otherwise denied the Plaintiffs job opportunities because of their national origin. 

22. The unlawful discriminatory actions by the Defendant and its agents and employees, 

as set forth herein, were and are intentional, willful, malicious and with gross disregard for the 

Plaintiffs' rights, and violate the FCRA. 

23. As a direct and proximate result of the Defendant's unlawful and discriminatory 

treatment, the Plaintiffs has suffered damages and will continue to suffer irreparable injury and 

damages in the future, including, but not limited to: 

a. Damage to reputation, confidence and self-esteem; 

b. Loss of past and future income; 

C. Loss of future earning capacity; 

d. Loss of other fringe benefits; 

e. Stress, anxiety and emotional distress; 

f. Significant past and future pain and suffering; and 

g. Other fmancial losses. 

24. The Plaintiffs is entitled to an award of reasonable attorney's fees, expert fees, costs 

and expenses related to this litigation. 

WHEREFORE, the Plaintiffs, KAREEM PICKERING and AARON MUHAMMAD, 

requests that judgment be entered against the Defendant, AKAL SECURITY, INC., for damages, 

L 

Case 1:20-cv-23151-BB Document 1-3 Entered on FLSD Docket 07/29/2020 Page 8 of 9
including compensatory, consequential, and punitive, 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. 

DElVIAND FOR JURY TRIAL 

The Plaintiffs demands trial by jury of all issues triable as of right by a jury. 

Dated: July 1, 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@lgyylMlaw.com 

Secondary: assistant ,levlevylaw.com 

F.B.N.: 0851701 

DAVID M. COZAD, ESQ. 

david ,levylevylaw.com 

F.B.N.: 333920 

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