UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES

AND DEMAND FOR JURY TRIAL

Plaintiff Brightstar Corp. (“Brightstar” or the “Company”) files this Complaint for 

Injunctive Relief and Damages against Defendant David Mayland (“Mayland”) through 

undersigned counsel, and respectfully alleges as follows:

I. INTRODUCTION AND NATURE OF THE ACTION

1. Brightstar brings federal claims for violations of the Defend Trade Secrets Act, 18 

U.S.C. § 1831, et seq. (“DTSA”). Brightstar also brings state claims for breach of contract, and for

actual and threatened misappropriation of Trade Secrets in violation of the Florida Uniform Trade 

Secrets Act, Fla. Stat. § 688.001, et seq. (“FUTSA”) against Mayland. Brightstar has suffered and 

will continue to suffer substantial and irreparable harm unless Mayland is enjoined.

II. PARTIES

2. Brightstar distributes wireless communications devices and provides associated 

services domestically and globally. 

3. Brightstar is a Delaware corporation with its principal place of business in Miami, 

Florida. 

BRIGHTSTAR CORP., 

Plaintiff,

v.

DAVID MAYLAND,

Defendant.

 /

Case No. 

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4. Mayland was an employee of Brightstar from August 6, 2013 to July 1, 2020. 

5. In or around May 2016, Mayland was appointed to the position of Senior Director 

of Corporate Development.

6. In or around November 2019, Mayland was appointed Vice President of Corporate 

Development of Brightstar.

7. During his employment with Brightstar, Mayland was based in Miami, Florida.

8. Upon information and belief, Mayland is a resident of Florida.

III. JURISDICTION AND VENUE

9. This Court has personal jurisdiction over the parties under Florida’s long-arm 

statute, Fla. Stat. § 48.193(1)(a), because Mayland has conducted business and substantial 

activities in Miami, Florida, and Brightstar’s primary place of business is in Miami, Florida.

10. This Court also has personal jurisdiction over all parties to this controversy because 

the parties executed a “Employee Confidentiality, Non-Disclosure, Non-Solicitation, and NonCompete Agreement” dated August, 6, 2013 (the “RCA”) that states: “The Employee hereby 

consents to personal jurisdiction...in the United States District Court for the Southern District of 

Florida, Miami Division, if such Court can exercise jurisdiction over the matter for any action 

brought by the Company or the Employee arising out of or in connection with this Agreement or 

the Employee's employment with the Company.” A true and correct copy of the RCA is attached 

as Exhibit 1.

11. This Court has subject matter jurisdiction under 28 U.S.C. § 1331 and 18 U.S.C. §

1836(c) because Brightstar asserts claims under the Federal Defend Trade Secrets Act, 18 U.S.C. 

§ 1836. 

12. This Court has supplemental jurisdiction over Brightstar’s state-law claims under 

28 U.S.C. § 1367.

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13. Venue is proper in this District because Mayland resides in this District, and 

because “a substantial part of the events or omissions giving rise to the claim occurred” in this 

District. 28 U.S.C. §§ 1391(b)(1) and (2).

14. Additionally, venue is proper in this District because the RCA states, “The 

Employee hereby consents to...exclusive venue in the United States District Court for the Southern 

District of Florida, Miami Division, if such Court can exercise jurisdiction over the matter for any 

action brought by the Company or the Employee arising out of or in connection with this 

Agreement or the Employee's employment with the Company.” Ex. 1 at 9-10.

IV. FACTS

A. Brightstar’s Business

15. Brightstar is a global provider of communications devices and netbook computers, 

providing various services in the wireless industry including logistics, strategic sourcing, 

management, and supply chain optimization.

16. Brightstar’s employees facilitate the delivery of these products and services through 

sales, distribution, assembly, manufacturing, and marketing operations.

17. The methods, techniques, processes, and proprietary financial information used to 

evaluate Company performance and to derive and prepare internal and external valuations of the 

Company, are Trade Secrets of the Company under the relevant contracts, DTSA, and FUTSA. 18 

U.S.C. §1839(3); Fla. Stat. § 688.002 (hereinafter referred to as “Trade Secrets”).

18. In order to attract and retain qualified employees, the Company offered a LongTerm Incentive Plan (the “LTIP”) to a portion of its employees in 2016. A true and correct copy 

of the LTIP is attached as Exhibit 2.

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B. The RCA

19. On August 6, 2013, Brightstar hired Mayland as a Director of Corporate 

Development responsible for global acquisitions, joint ventures, and other business development 

projects.

20. On that date, Mayland entered into a RCA with Brightstar. Exhibit 1.

21. Mayland remained an employee of Brightstar for nearly seven years. During his 

tenure, Mayland held various positions of increasing seniority within the Company, most recently 

that of Vice President of Corporate Development.

22. In his capacity as Vice President of Corporate Development, Mayland prepared 

financial information relating to the Company and its operations, as described in Paragraph 15 of 

this Complaint.

23. As a result, Mayland was privy to highly sensitive financial information and Trade 

Secrets for at least the last several years of his employment at Brightstar. As such, the RCA

contained reasonable covenants to protect the Company’s interest in its valuable Confidential 

Information1and Trade Secrets (Confidential Information and Trade Secrets are collectively 

referred to hereinafter as “Protected Information”).

24. In the RCA, Mayland agreed that he would not, even after the termination of his 

employment, disclose or use for his own benefit or that of any other person or entity, any Protected

Information (as defined in Footnote 1, below) of the Company. The RCA provides:

(iv) Non-Disclosure of Confidential Information of the Company.

As a material inducement to the Company to allow the Employee to remain 

an employee of the Company, and as a material inducement to the Company 

to disclose or allow to be known to the Employee some or all of the 

Confidential... the Employee shall not, directly or indirectly, without the 

 

1 "Confidential Information" as used here and throughout this Complaint refers to that term as it 

is more fully described in Paragraph 2(b) of the attached RCA.

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prior written consent of the Board of Directors of the Company, or a 

person duly authorized thereby, other than to a person to whom 

disclosure is reasonably necessary or appropriate in connection with 

the performance by the Employee of the duties of the Employee as an 

employee of the Company, disclose or use for the benefit of 

himself/herself or any other person, corporation, partnership, joint 

venture, association, or other business organization, any of the trade 

secrets or Confidential Information of the Company.

Ex. 1 at 5 (emphasis added).

25. The RCA defines “Confidential Information” as including but not limited to Trade 

Secrets, future Company business plans, project files, sales information and sales volumes. Ex. 1 

at 3.

26. The RCA further defines Confidential Information as including that information 

considered to be Trade Secrets under FUTSA and DTSA, providing:

(ii) any information that is of value or significance to the Company that 

derives independent economic value, actual or potential, from not being 

generally known to, and not being readily ascertainable by proper means 

by, other persons who can obtain economic value from its disclosure or use, 

including information not generally known to the competitors of the 

Company nor intended by the Company for general dissemination. 

Ex. 1 at 2-3.

27. As Brightstar’s operations are dispersed domestically and globally, the Trade 

Secrets are used in interstate commerce, as required by the DTSA.

28. The RCA is reasonably tailored, limiting itself such that Confidential Information 

shall not include any:

(a) information known generally to the public (other than as a result of 

unauthorized disclosure by Employee),

(b) information that became available from a third party source and such 

source is not bound by a confidentiality agreement, or 

(c) any information not otherwise considered by the Board of Directors of 

Brightstar Corp. to be Confidential Information.

Ex. 1 at 3.

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29. The RCA provides that if duration, area, or scope of any restriction specified is 

“adjudged unreasonable in any proceeding, then [the restriction] shall be reduced so that the 

restrictions may be enforced as is adjudged to be reasonable.” Ex. 1 at 7.

30. Additionally, the RCA provides that “the invalidity or unenforceability of any 

provision of the [RCA] shall not affect the validity or enforceability of any other provision of the 

[RCA], which shall remain in full force and effect.” Ex. 1 at 10.

31. As Mayland acknowledge in the RCA, “in the event of a breach by the Employee 

of any restrictive covenant set forth in this Agreement, the Employee agrees that such a breach 

would cause irreparable injury to the Company.” Ex. 1 at 6-7.

32. Finally, the RCA provides, “in the event of a breach by the Employee of any 

restrictive covenant...the Company shall be entitled to seek all available civil 

remedies...including, without limitation, an injunction without posting a bond, monetary damages,

attorneys’ fees, and costs.” Ex. 1 at 7.

C. The LTIP

33. On April 2, 2016, the Company’s LTIP became effective. The LTIP provided 

employees with the opportunity to earn cash-based long-term incentive compensation contingent 

upon the Company’s performance over a specified time period, and the employee’s continued 

service with the Company.

34. As this was an incentive program, which the Company freely offered to a select 

group of employees, continued eligibility was also contingent upon each employee’s performance

and compliance with the LTIP’s covenants.

35. Mayland was a participant in the LTIP.

36. On February 6, 2019, the LTIP was amended, lowering the threshold at which 

employees would be eligible for compensation under the Plan.

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37. Under the LTIP, if the Company met that lowered performance threshold based on 

a valuation of the Company as of December 31, 2019, LTIP participants would receive certain 

cash payments. 

38. The Company did not reach that threshold and accordingly, participants did not 

receive cash payments under the LTIP. 

39. Importantly, both the original LTIP, as well as its 2019 amended version, contained 

“Confidentiality Covenants.” Exhibit 2 at 4-5.

40. These Confidentiality Covenants provided, in relevant part:

during a Participant’s employment with Brightstar and at all times after the 

termination of the Participant’s employment with Brightstar for any reason, 

the Participant shall not, Directly or Indirectly, without the prior written 

consent of the Board, or a person duly authorized thereby, disclose or 

use for the benefit of the Participant or any other person...any 

Confidential Information, other than to a person employed by Brightstar 

or any Affiliates to whom disclosure is reasonably necessary or appropriate 

in connection with the performance of the Participant’s duties as an 

employee of Brightstar.

Ex. 2 at 4-5 (emphasis added).

41. While the LTIP does not explicitly define Confidential Information, as the RCA 

does, reasonable construction would implicate the same definitions for both, concordant with and

comprising the definition of Trade Secrets in the DTSA and FUTSA.

D. Mayland Uses or Discloses or Threatens to Use or Disclose 

Brightstar’s Protected Information for His Own Benefit

42. At all times during and following Mayland’s employment with Brightstar, Mayland 

was contractually bound to protect the Company’s Protected Information. 

43. In fact, in the RCA, Mayland acknowledged that the Non-Disclosure covenant was 

a material inducement that allowed Brightstar to share its Protected Information. 

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44. On or about March 30, 2020, Mayland was one of approximately 1,000 employees 

furloughed by Brightstar.

45. Prior to his furlough, Mayland was engaged in the preparation of confidential 

financial information relating to the Company.

46. Had Brightstar had any inkling of Mayland’s questionable ethics and frail loyalties, 

Brightstar would never have employed Mayland, let alone entrusted him with such sensitive 

financial information.

47. Upon information and belief, Mayland retained Protected Information related to 

that work, illegally taking it with him when he ceased to be an employee of the Company.

48. In order to conduct its business with its parent company (“SoftBank”), lenders, 

investors, and other essential business functions, Brightstar prepares annual financial information 

and conducts an annual valuation of the Company.

49. During the first quarter of 2020, Brightstar contracted an independent firm to 

conduct such a valuation of the Company (the “2020 Independent Valuation”).

50. The 2020 Independent Valuation contained Protected Information. As a result, it 

was made available only to LTIP participants, and only upon request.

51. Upon information and belief, in or around March 2020, Mayland, in his capacity as 

an LTIP participant, requested and received a copy of the 2020 Independent Valuation.

52. Upon information and belief, Mayland made this request not as an inquisitive LTIP 

participant, but with the intent of procuring the Protected Information to bolster his own position.

53. On July 1, 2020, Mayland was notified that he was part of a reduction in force.

54. Upon information and belief, Mayland retained legal counsel shortly prior to his 

termination, as he embarked on a plan to seek LTIP payment to which he was not entitled.

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55. Beginning in June 2020 and through the present, Mayland, directly and through his 

counsel, has made several threatening communications to Brightstar demanding LTIP payment.

56. Brightstar explained to Mayland that the relevant Company valuation did not meet 

the threshold set forth in the LTIP and as a result, he was not entitled to any payment under the 

LTIP.

57. Refusing to accept this, Mayland began to threaten Brightstar, indicating that he 

has reason to believe, based on Protected Information he accessed as an employee, that contrary 

to the 2020 Independent Valuation, the Company had met the threshold for a cash payout to LTIP

participants, in particular himself.

58. Mayland threatened to go public with spurious and baseless allegations. 

59. In making these threats, Mayland illegally used or disclosed or threatened to use or 

disclose the Protected Information he apparently had retained as leverage, thinking the Company 

would pay any price for the safety of its highly classified information.

60. In essence, Mayland attempted to sell the Company its own Protected Information.

61. In making these threats, Mayland held hostage the Company’s Protected 

Information, including the 2020 Independent Valuation and internal financial information he 

illegally retained, using them for his own benefit in his attempts to sell them to the highest bidder.

62. Attempting to force Brightstar into making this payment, Mayland even threatened 

to bring suit against Brightstar premised on baseless claims, a “Trojan horse” through which he 

would disclose Protected Information.

63. These threats not only breach the RCA and LTIP (collectively, “the Agreements”), 

by Mayland using his possession of Protected Information for his own benefit, but also 

demonstrate the deepest disrespect for the judicial system.

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E. Mayland Uses or Discloses or Threatens to Use or Disclose

Brightstar’s Protected Information for the Benefit of a Third Party

64. Mayland’s communications to Brightstar further weaponized the Company’s 

Protected Information by reference to a pending shareholder action in Delaware (the “Delaware 

Action”).

65. In the Delaware Action, minority shareholders are exercising their rights under § 

262 of the General Corporation Law of the State of Delaware (“DGCL”) to demand an appraisal 

of the value of common shares of the Company in connection with a merger under § 267 of the 

DGCL. The Delaware Action is integrally related to the 2020 Independent Valuation.

66. Mayland represented to Brightstar that he has been in contact with the Delaware 

Action representatives, and that they invited him to serve as an expert witness in the Action.

67. Upon information and belief, Mayland used or disclosed or threatened to use or 

disclose the Protected Information which he illegally retained in his communications with 

participants in the Delaware Action. 

68. Importantly, no members of the Delaware Action have legal access to any of the 

relevant Protected Information that Mayland possesses.

69. In an effort to bridge that gap, Mayland has used or disclosed or threatened to use 

or disclose not only Protected Information, but also to use such Information to testify regarding

the proprietary process, formulas, and analysis behind confidential presentations he has retained, 

as well as the 2020 Independent Valuation, which he only accessed through his LTIP participation, 

and was subject to the confidentiality provision in the LTIP Plan.

70. Mayland has used or disclosed or threatened to imminently use or disclose the 

mechanics of Brightstar’s financial information, including future business plans, the projections 

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of which are reflected in confidential presentation materials, and sales information reflected in 

both the presentation materials and the 2020 Independent Valuation.

71. The aforementioned Protected Information used or disclosed or threatened to be 

used or disclosed are protected under the DTSA and FUTSA as financial information, 

compilations, and methods of valuation, from which Brightstar derives independent economic 

value, and takes reasonable efforts to guard. 18 U.S.C. § 1839; Fla. Stat. § 688.002.

72. In addition to the traditional methods a company may take in the course of business 

to protect sensitive financial information, Brightstar took the affirmative step of requiring Mayland 

to execute the RCA, which emphasizes that the Company continually expends significant time and 

expense to protect its Protected Information, as their exclusive control is essential to maintain their 

value. Ex. 1 at 1.

73. Mayland has used or disclosed or has threatened to use or disclose the methods and 

techniques by which Company financial statements are prepared, all of which are closely guarded 

Protected Information, and subject to the Agreements, thereby holding himself out to be a so-called 

“expert” for use in the Delaware Action.

74. Brightstar is validly concerned about protecting its Protected Information, as two 

of the minority shareholders in the Delaware Action are employed by direct competitors of 

Brightstar, and disclosure of this Protected Information to competitors or other third parties would 

do irreparable harm.

75. Brightstar has not and does not consent to any use or disclosure, direct or indirect, 

by Mayland of Company Protected Information.

76. Mayland knew, or should have known that using or disclosing or threatening to use 

or disclose Brightstar’s Protected Information would cause irreparable damage to Brightstar. 

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77. The very purpose of establishing confidentiality provisions in the Agreements was 

to prevent such irreparable harm. Mayland knew this, and was counting on that potential loss in 

making these threats. 

V. CAUSES OF ACTION

A. Count One—Violations of the Federal Defend Trade Secrets Act (“DTSA”)

78. Brightstar incorporates Paragraphs 1 through 77 of this Complaint as fully set forth 

herein.

79. Mayland has, without authorization, used or disclosed or threatened to use or 

disclose Brightstar’s Trade Secrets, as that term is defined in the DTSA, for his own benefit.

80. Mayland has done so, and continues to do so in full knowledge of the irreparable 

harm this is causing or will cause to Brightstar.

81. DTSA provides in pertinent part: “An owner of a trade secret that is 

misappropriated may bring a civil action under this subsection if the trade secret is related to a 

product or service used in, or intended for use in, interstate or foreign commerce.” 18 U.S.C. §

1836(b)(1).

82. Brightstar is a global corporation and the Trade Secrets misappropriated by 

Mayland are valuable and used in Brightstar’s products and services globally and domestically.

83. DTSA provides for injunctive relief “to prevent any actual or threatened 

misappropriation,” which is necessary and appropriate in order to prevent further irreparable harm 

to the Company. 18 U.S.C. § 1836(3)(A).

84. DTSA further provides for monetary damages and exemplary damages, both of 

which are appropriate here, because Brightstar has suffered actual loss and where Mayland’s 

misappropriation was done in a willful and malicious manner. 18 U.S.C. § 1836(3)(B).

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B. Count Two—Violations of the Florida Uniform Trade Secrets Act (“FUTSA”)

85. Brightstar incorporates Paragraphs 1 through 77 of this Complaint as fully set forth 

herein.

86. Mayland has, without authorization, used or disclosed or threatened to use or 

disclose Brightstar’s Trade Secrets, as defined in FUTSA, to his own benefit, misappropriating 

Trade Secrets within the meaning of Fla. Stat. § 688.002.

87. Mayland has done so, and continues to do so in full knowledge of the irreparable 

harm this is causing or will cause to Brightstar.

88. FUTSA provides in pertinent part: “Actual or threatened misappropriation may be 

enjoined.” Fla. Stat. § 688.003(1).

89. FUTSA further provides for monetary damages and exemplary damages, both of 

which are appropriate here. Brightstar has suffered actual loss and Mayland’s breach of his RCA 

and the LTIP and his misappropriation of Trade Secrets were done in a willful and malicious 

manner. Fla. Stat. §§ 688.004(1) and (2).

Count Three—Breach of the Restrictive Covenant Agreement

90. Brightstar incorporates Paragraphs 1 through 77 of this Complaint as fully set forth 

herein.

91. Brightstar and Mayland entered into the RCA, a valid contract. Exhibit 1.

92. In the RCA, Mayland agreed that he would not, directly or indirectly, disclose or 

use for his own benefit or for the benefit of others, any Protected Information. Ex. 1 at 5.

93. Mayland breached the RCA by using or disclosing, or by implication, threatening 

to use or disclose, for his own benefit, Brightstar’s Protected Information to threaten Brightstar, 

for his own financial gain. Fla. Stat. § 542.33.

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94. Mayland breached the RCA by using or disclosing or by implication, threatening 

to use or disclose Protected Information, including but not limited to serving as paid expert witness

in the Delaware Action, and through frivolous suits of his own design.

95. Mayland’s breaches of the RCA caused and continue to cause Brightstar to suffer 

irreparable harm in the insecurity of its Protected Information and its continued ability to compete 

in the marketplace. 

96. Mayland explicitly threatens breaches that would irreparably harm the Company in 

all aspects of its business operations.

97. Brightstar has no adequate remedy at law, and will suffer substantial and irreparable 

harm unless Mayland is preliminarily and permanently enjoined from the actions described herein. 

Ex. 1 at 6-7.

98. Mayland’s aforementioned threat to use or disclose Protected Information, 

including but not limited to serving as paid expert witness will cause irreparable harm to Brightstar, 

as two of the minority shareholders participating in the Delaware Action are direct competitors of 

Brightstar.

99. Breach of the restrictive covenants in the RCA subjects Mayland to liability for 

damages and preliminary and permanent injunctive relief, as well as attorneys’ fees and costs. Ex. 

1 at 6-7.

Count Four—Breach of the Long-Term Incentive Plan Confidentiality Covenants

100. Brightstar incorporates Paragraphs 1 through 77 of this Complaint as fully set forth 

herein.

101. Mayland freely entered into the LTIP, a valid contract. Exhibit 2.

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102. As an LTIP participant, Mayland agreed that he would not, directly or indirectly, 

disclose or use for his own benefit or for the benefit of others, any Protected Information. Ex. 1 at

5.

103. Mayland breached the LTIP by using or disclosing or by implication, threatening 

to use or disclose, for his own benefit, Protected Information to threaten Brightstar, for his own 

financial gain.

104. Mayland breached the LTIP by using or disclosing or by implication, threatening 

to use or disclose, for his own benefit, Protected Information in communications with 

representatives in the Delaware Action.

105. Mayland breached the LTIP by using or disclosing or by implication, threatening 

to use or disclose Protected Information for the benefit of a third party, including but not limited 

to serving as paid expert witness and through frivolous suits of his own design.

106. Mayland’s breaches of the LTIP caused and continue to cause Brightstar to suffer 

irreparable harm in the insecurity of its Protected Information.

107. Mayland threatens breaches that would irreparably harm the Company in all aspects 

of its business operations.

108. Brightstar has no adequate remedy at law, and will suffer substantial and irreparable 

harm unless Mayland is preliminarily and permanently enjoined from the actions described herein. 

Ex. 1 at 6-7.

109. Mayland’s aforementioned threat to use or disclose Protected Information, 

including but not limited to serving as paid expert witness will cause irreparable harm to Brightstar, 

as two of the minority shareholders participating in the Delaware Action are direct competitors of 

Brightstar.

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VI. STATEMENT OF IRREPARABLE INJURY TO BRIGHTSTAR

110. Brightstar has been, and continues to be subjected to irreparable injury for which 

no remedy at law exists.

111. The unlawful actions by Mayland, his agents, and those acting in concert with him

are causing and will continue to cause great and irreparable harm to Brightstar’s businesses, which 

cannot be remedied adequately by an award of monetary damages.

112. Without this Court’s intervention, there is a real, present, and continuing threat that 

Mayland will breach his agreement with Brightstar, wrongfully use or disclose, or continue to use 

or disclose, Brightstar’s Protected Information.

113. Mayland’s use or disclosure of Brightstar’s Protected Information, which would 

inevitably result from his serving as an expert witness in the Delaware Action, would cause 

Brightstar irreparable harm for which Brightstar has no remedy at law.

114. Unless preliminary and/or permanent injunctions are entered on the terms set forth 

below, greater injury will be inflicted upon Brightstar than could possibly result to Mayland by the 

granting of said relief. Mayland will be harmed by the granting of the prayed-for injunctive relief 

only to the extent that the order will compel Mayland to abide by his obligations imposed by law.

115. Brightstar has legitimate and protectable business interests in its Protected 

Information, including financial information and business operations.

VII. PRAYER FOR INJUNCTIVE RELIEF

116. WHEREFORE, Brightstar prays that:

a. judgment be entered in favor of Brightstar and against Mayland; and

b. the Court enjoin Mayland from the actions described herein, including by

ordering the following:

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(i) a preliminary and permanent injunction providing that Mayland 

shall not, directly or indirectly, use or disclose or threaten to use or 

disclose Brightstar’s Protected Information in any way whatsoever, 

including but not limited to attempting to bolster his own financial 

position and/or benefit or providing such information to thirdparties, including but not limited to serving as a paid expert witness 

in the Delaware Action; and

(ii) a preliminary and permanent injunction providing that Mayland 

shall not, directly or indirectly, use or disclose or threaten to use or 

disclose Brightstar’s Protected Information Brightstar’s Protected 

Information in any way whatsoever, including but not limited to 

using or disclosing such information to parties or counsel or any 

person associated with or affiliated in any way with the Delaware 

Action or any other legal action, unless compelled to do so by law.

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VIII. PRAYER FOR DAMAGES AND SUCH OTHER RELIEF

117. Brightstar further prays for:

a. all damages sustained by Brightstar as a result of the wrongful conduct 

described above, beginning with the earliest date of violation up until the date of the entry of the 

final judgment in this action, including actual and consequential damages;

b. pre- and post-judgment interest; 

c. attorneys’ fees and costs; and

d. such other and further relief as this Court may deem just and proper.

118. In addition, Mayland’s conduct was wanton, willful, and malicious, so as to justify 

the imposition of punitive damages. Brightstar intends to seek to amend this Complaint before 

trial to add a claim for punitive damages pursuant to the procedure set forth in Florida Statutes § 

768.72.

JURY DEMAND

Brightstar demands a jury trial for all issues/claims to which it is entitled to a jury trial.

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Dated this 10th day of August 2020.

Respectfully submitted,

/s/ Carol A. Field

Anne Marie Estevez

Florida Bar No. 991694

aestevez@morganlewis.com

Carol A. Field

 Florida Bar No.: 987166

 Email: carol.field@morganlewis.com

MORGAN, LEWIS & BOCKIUS LLP

200 South Biscayne Boulevard, Suite 5300

Miami, FL 33131

Phone: (305) 415-3409

Fax: (305) 415-3001

Counsel for Plaintiff Brightstar Corp.

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