UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

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JULIE FERRO, 

 Plaintiff, 

 v. 

DOCTORS HEALTHCARE PLANS, INC., and 

RAFAEL PEREZ, in his individual and professional 

capacities, 

 Defendants. 

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Civil Action No.: 

COMPLAINT 

Jury Trial Demanded

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Plaintiff Julie Ferro hereby alleges as follows: 

PRELIMINARY STATEMENT 

1. Founded in 2017, Defendant Doctors HealthCare Plans, Inc. (“Doctors 

HealthCare” or the “Company”) is a local health insurance plan offering Medicare coverage in 

Miami-Dade County. 

2. Despite Doctors HealthCare claiming in its logo, “Your Health, Our 

Commitment,” the Company and its founder and Chief Executive Officer, Defendant Rafael 

Perez, callously terminated Ms. Ferro, the former Vice President of Provider Relations, due to 

her underlying immunocompromised medical condition and because she needed related 

accommodations and leave. 

3. Ms. Ferro is an accomplished healthcare executive with over 30 years of 

experience managing Medicare and Medicaid insurance programs in the state of Florida who 

joined Doctors HealthCare as only its third employee. 

4. Over the last few years, Ms. Ferro helped grow the Company to over 100 

employees, more than 2,500 providers, and close to 10,000 members. 

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5. Unfortunately, Ms. Ferro’s tireless work did not matter after she began dealing 

with several medical issues starting in late 2019 related to her chronic inflammatory disorder and 

autoimmune compromised condition. 

6. The COVID-19 pandemic further brought to the forefront Ms. Ferro’s medical 

issues given the CDC’s warnings to “people of any age with serious underlying medical 

conditions” to stay home to avoid contracting the deadly virus. 

7. While Ms. Ferro understandably became concerned about what would happen if 

she contracted COVID-19, Mr. Perez stated at a staff meeting that he believed the virus was 

being made more of an issue because it is an election year and expressed in various ways his 

reluctance to have employees work remotely. 

8. Ultimately, Ms. Ferro was permitted to work from home, after being required to 

provide a doctor’s letter, but told that she had to have one of her staff members physically at the 

office. 

9. After a couple of months working from home, Mr. Perez pressured Ms. Ferro to 

return to the office with the rest of the employees on May 26, 2020. 

10. When Ms. Ferro returned to the office, she was shocked that most employees 

were not wearing masks or observing social distancing. 

11. She also noticed that the office lacked paper towels and sanitary products in the 

kitchen and bathrooms. 

12. On one occasion, Ms. Ferro texted Mr. Perez to tell him that she was going to 

work from home and her subordinate, who lived with her elderly mother, would work in her 

office since there was “no adequate distancing” where she worked. 

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13. Mr. Perez responded that Ms. Ferro was “the one with the office and not them,” 

which caused Ms. Ferro to return to the office. 

14. In late May and early June, and the number of COVID-19 cases quickly began to 

rise as businesses and public gathering places in Florida reopened quickly, and seemingly 

prematurely. 

15. On June 4, 2020, Florida broke its record for a single-day high of newly reported 

cases of COVID-19, with 1,419 new cases, and the state continued to report near record highs 

over the next few days. 

16. Mr. Perez unquestionably appeared concern that he would have to further 

accommodate Ms. Ferro’s medical condition due to the spike in COVID-19 cases, and he knew 

that, given Ms. Ferro’s past medical issues, she would need to take leave to get treatment for 

them. 

17. As a result, on Monday, June 8, 2020, Mr. Perez abruptly called Ms. Ferro into 

his office and told her that she was being let go because “things were not working out.” 

18. Ms. Ferro was shocked by this, given that she had been a loyal and dedicated 

employee, and because she had recently, at the end of 2019, received an excellent performance 

review and a $25,000 raise. 

19. Ms. Ferro questioned Mr. Perez about her termination, but he would give her only 

vague or transparently false reasons to try to justify her termination, and later even tried to get 

Ms. Ferro to agree to resign. 

20. Ms. Ferro brings this action pursuant to the Family Medical Leave Act, 29 U.S.C. 

§§ 2601 et seq. (“FMLA”) to redress her unlawful discriminatory and retaliatory discharge and 

interference with her rights under the FMLA. 

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ADMINISTRATIVE PREREQUISITES

21. Concurrently with the filing of this Complaint, Plaintiff will file a Charge of 

Discrimination with the Equal Employment Opportunity Commission (“EEOC”), which will be 

cross-filed with the Florida Commission on Human Relations (“FCHR”), alleging unlawful 

discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.

(“Title VII”), the Americans with Disabilities Act of 1990, 42 U.S.C § 12101 et seq. (“ADA”) 

and the Florida Civil Rights Act of 1992, §§ 760 et seq. (“the FCRA”). 

22. Upon issuance of a Notice of Right to Sue from the EEOC, Plaintiff shall seek 

leave to amend this Complaint to include claims and factual allegations under Title VII and the 

FCRA, including with regard to gender-based discrimination and harassment. 

23. Pursuant to FCRA § 760.11(8), Plaintiff will seek leave to amend this Complaint 

to include claims and factual allegations under the FCRA after 180 days have passed without 

there being a determination by the FCHR on whether reasonable cause exists. 

24. Plaintiff has complied or will comply with any and all other prerequisites to filing 

this action. 

JURISDICTION AND VENUE 

25. The Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1331, as this 

action involves federal questions regarding the deprivation of Plaintiff’s rights under the FMLA. 

The Court has supplemental jurisdiction over Plaintiff’s related claims arising under state law 

pursuant to 28 U.S.C. § 1367(a). 

26. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) because a 

substantial part of the events or omissions giving rise to this action, including employment 

practices alleged herein, occurred in this district. 

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PARTIES 

27. Plaintiff Julie Ferro is a former Vice President of Provider Relations at Doctors 

HealthCare Plans, Inc. Ms. Ferro is a resident of the state of Florida and, at all relevant times 

herein, met the definition of an “employee” and/or “covered employee” under all relevant 

statutes. 

28. Defendant Doctors HealthCare Plans, Inc. is a Florida profit corporation 

registered at 2020 Ponce de Leon Boulevard, Suite PH 1, Coral Gables, FL 33134. In its filings 

with the Florida Division of Corporations, Doctors HealthCare lists Mr. Perez as its President 

and CEO. At all times relevant herein, Doctors HealthCare was and is an “employer” under all 

relevant statutes. 

29. Defendant Rafael Perez is a resident of the state of Florida, is the President and 

CEO of Doctors HealthCare, and supervised Plaintiff during her employment at the Company. 

At all relevant times, Defendant Perez met the definitions of “employer” and/or “covered 

employer” under all applicable statutes. 

FACTUAL ALLEGATIONS 

I. Ms. Ferro’s Professional Background and Work at Doctors HealthCare 

30. Ms. Ferro is an accomplished healthcare executive with over 30 years of 

experience managing Medicare and Medicaid insurance programs in the state of Florida. 

31. In the early 1980s, Ms. Ferro worked at Humana, where Ms. Ferro was 

responsible for managing the insurer’s provider relationships. 

32. Ms. Ferro also gained substantial experience working in a provider relationship 

and business development role for the healthcare providers Jackson Memorial Health Plans, 

Physician Healthcare Plans, Inc., and LogistiCare. 

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33. Around 2002, Mr. Perez contacted Ms. Ferro to recruit her to work at Mr. Perez’s 

healthcare insurance startup, Medica Health Care Plans, Inc. (“Medica”), given her knowledge 

and experience. 

34. Ms. Ferro was one of the very first employees at Medica, and served in the vital 

role of Director of Provider Relations. Ms. Ferro worked tirelessly for a decade to help Medica 

grow its providers and members. 

35. In February 2012, Medica was sold to UnitedHealth Group for $400 million. 

36. Ms. Ferro remained working at Medica under the UnitedHealth Group leadership. 

37. However, in August 2013, Ms. Ferro decided to stop working to focus on her 

escalating health issues that were later diagnosed as rheumatoid arthritis. 

38. In late 2008, Ms. Ferro developed a serious case of the shingles that required her 

to be hospitalized in intensive care for five days. In the months leading up to the sale of Medica 

in 2012, Ms. Ferro also shared with Mr. Perez that she was starting to feel fatigued, had pain in 

her joints, and that on multiple occasions her knees would start to buckle and she would almost 

fall. 

39. After about six months of not working at all and focusing on her health, in 2014, 

Ms. Ferro started working as an independent consultant for several management services 

organizations and other healthcare entities. This included work for Mr. Perez’s son, Gabriel 

Perez, who Ms. Ferro helped to secure a major account that was expected to generate about $1 

million a year in revenue. 

40. Around January 2017, Mr. Perez approached Ms. Ferro about working for him to 

help launch another start-up health plan in Miami-Dade County specializing, like Medica, in 

Medicare coverage. 

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41. At the time Mr. Perez discussed this opportunity, Mr. Perez repeatedly asked Ms. 

Ferro how she was feeling and whether she would be able to commit to work on a full-time 

basis. 

42. Ms. Ferro, whose health issues were under control at the time, responded that she 

was doing well and was committed to working full-time. 

43. Ms. Ferro was only the third employee for the new business at the time, and 

worked tirelessly to launch Doctors HealthCare on January 1, 2019. 

44. The Company has been growing rapidly ever since, and now has over 100 

employees, more than 2,500 providers, and close to 10,000 members. 

II. Ms. Ferro’s Health Issues Return 

45. Ms. Ferro was able keep her health issues under control for the first couple of 

years at the Company. However, during a trip to see her daughter in Virginia for Thanksgiving 

last year, Ms. Ferro had to visit the emergency room because she developed a growth on the side 

of her mouth. Ms. Ferro was prescribed an antibiotic to treat the growth and was discharged. 

46. After returning to Florida, Ms. Ferro woke in the middle of the night on the 

Sunday after Thanksgiving to find that the left side of her face had hardened, and she decided to 

go to the emergency room. 

47. At the hospital, Ms. Ferro was given a different antibiotic that caused her immune 

system to go into shock, which resulted in her being intubated. 

48. Ms. Ferro was in the hospital for a week, and after she was discharged, she stayed 

home for two weeks to recover while she continued to do her work for the Company. 

49. During that time, Ms. Ferro regularly kept Mr. Perez updated on her medical 

issues and the progress of her recovery. 

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50. At no time during her employment was Ms. Ferro advised of her rights under the 

FMLA to take job-protected leave under the FMLA to treat her serious medical condition and 

health issues. 

51. Had she been advised of her rights under the FMLA, Ms. Ferro likely would have 

taken additional leave, or intermittent leave, and not been put through anxiety and worry about 

the impact that taking time off from work would have on her job and job security. 

52. On December 24, 2019, Ms. Ferro returned to work. 

53. However, for the next several weeks, she continued to experience health issues 

due to the medication, Enbrel, which she was taking to treat her rheumatoid arthritis. 

54. Ms. Ferro frequently became nauseous and would need to rush to the bathroom to 

throw up, including one time during a meeting where Mr. Perez were present. 

55. During one conversation, Ms. Ferro disclosed that she was taking Enbrel, and 

since Mr. Perez has a pharmacy background, Mr. Perez told her that the side effects are similar to 

a medication that Mr. Perez’s wife was taking for Crohn’s disease, and that she also was 

immunocompromised. 

56. During another conversation about Ms. Ferro’s ongoing medical issues, Mr. Perez 

told her that, “There is always something with you.” 

57. In addition to commenting upon her health issues and their impact on Mr. Perez’s 

impression of her, Mr. Perez also frequently made pointed disability-related and ageist remarks 

to Ms. Ferro, who turned 60 in March, including about how much they have both aged and are 

not as young and healthy as they used to be. 

58. In mid-February 2020, Ms. Ferro began to feel disoriented and fatigued, but 

continued to work through the symptoms until one day when the Company’s Medical Director, 

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Andres Prieto, M.D., noticed that Ms. Ferro was flushed around her neck and chest. 

59. Dr. Prieto checked Ms. Ferro’s blood pressure and told her that she should go and 

see her physician because the symptoms were abnormal. 

60. Ms. Ferro again worked from home for a couple of days until her blood pressure 

started to return to normal, but it still took a few weeks for Ms. Ferro to get her blood pressure 

fully under control. 

III. The COVID-19 Pandemic 

61. In March 2020, the COVID-19 pandemic began to sweep through the United 

States in earnest and became a public health crisis. 

62. Mr. Perez initially dismissed the virus as a simple case of the flu and claimed that 

the state of emergency was unnecessary. 

63. Incredibly, Mr. Perez told Ms. Ferro and other employees at a staff meeting that, 

essentially, the government warnings and state of emergency declarations were unwarranted, and 

that the virus was being made more of an issue because it is an election year. 

64. On March 16, 2020, the Centers for Disease Control and Prevention (“CDC”), 

issued an official warning that the elderly and “people of any age with serious underlying 

medical conditions” should stay home during the pandemic, as they are “particularly at risk for 

severe illness or death due to COVID-19.” 

65. Shortly after this warning was issued, Dr. Prieto advised Ms. Ferro to work from 

home. 

66. Ms. Ferro took the rest of the day off (in part because it was her birthday), but she 

returned to the office the next day because she felt uncomfortable being the only one working 

from home when the Company had not issued any instructions or guidance to employees on the 

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issue. 

67. It took over a week after this public health warning for Mr. Perez and the 

Company to begin identifying departments and employees that could work remotely. 

68. However, the message from Mr. Perez remained clear that there must still be 

physical coverage in the office for all areas of the Company. 

69. In late March 2020, Ms. Ferro spoke with Mr. Perez about her own 

immunocompromised condition, and identified other employees on her team who may be at risk 

of severe illness or death if they were exposed to the virus. 

70. Mr. Perez told Ms. Ferro that he would be letting her know what to do shortly. 

71. A couple of days after this conversation, Dr. Prieto told Ms. Ferro that she needed 

to work from home because of her immunocompromised condition. 

72. Another three members of Ms. Ferro’s staff also were permitted to work from 

home, but, as she had been instructed, Ms. Ferro made sure to have at least two of her other staff 

members physically stationed in the office, even though they easily could have worked remotely. 

73. Despite Mr. Perez’s intimate knowledge of Ms. Ferro’s history of medical issues, 

Mr. Perez requested that Ms. Ferro provide a letter from her physician substantiating her need to 

work from home. 

74. On March 30, 2020, Ms. Ferro provided Mr. Perez with a letter from her 

physician that said: 

This is a letter to confirm that Mrs. Ferro has rheumatoid arthritis. 

She is immunocompromised due to the medication she takes for 

her arthritis which is Enbrel. This places her at extremely high risk 

for having complications with the COVID-19 pandemic. I 

recommend that she continue to work from home and should self 

isolate as much as possible because of her increased risk. 

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75. Ms. Ferro is unaware of any other employees who were required to provide a 

similar physician letter in order to be permitted to work from home. 

76. Ms. Ferro managed all of her responsibilities while working remotely and 

checked in on the employees who were at the office. 

77. On May 15, 2020, Ms. Ferro received a “Performance Bonus payment” for her 

work during the past year, and which also provided additional support to employees during the 

pandemic. 

78. Ms. Ferro was given the lowest “Performance Bonus payment” among the 

employees at her level, and upon information and belief, the decision to do so was based on Ms. 

Ferro’s disability and having taken a medical leave in late 2019. 

79. On or around May 22, 2020, Mr. Perez announced at a telephonic staff meeting 

that employees would start returning to the office on May 26, 2020, after the Memorial Day 

holiday. 

80. Mr. Perez also explained that if there was any objection to returning to the office 

it should be raised directly with him, and reassured employees that it would be safe to return to 

the office. 

81. After the meeting, Mr. Perez spoke to Ms. Ferro and asked whether she planned 

to work in the office. 

82. Ms. Ferro responded that she would check with her physician, but based on the 

conversation, she felt pressured to request that her physician issue a letter clearing her to return 

even though Mr. Perez was aware that Ms. Ferro’s immunocompromised status put her at risk of 

serious complications and death if she was exposed to the novel coronavirus. 

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83. On May 26, 2020, Ms. Ferro returned to the office and saw that few employees 

were wearing masks or observing social distancing. 

84. As a result, Ms. Ferro stayed in her office with the door closed. One of the few 

times that she left her office, Mr. Perez confronted Ms. Ferro near the elevator and questioned 

Ms. Ferro about her immunocompromised condition and medication in front of Dr. Prieto. 

85. Ms. Ferro was brief in her responses, as she felt very uncomfortable being 

questioned about her medical issues when other employees were nearby and could overhear the 

discussion. 

86. Because of the lack of use of masks and social distancing, Ms. Ferro decided to 

alternate the use of her office with her Provider Relations Manager, Noelle Pagliery. 

87. Ms. Pagliery repeatedly expressed her concern about potential exposure to the 

virus because she lives with her elderly mother, who also has medical conditions and therefore is 

at high risk of dying if she were to contract the virus. 

88. Ms. Ferro informed Mr. Perez of the office arrangement by text message. 

89. On June 1, 2020, Ms. Ferro worked at the office again and continued to observe 

the lack of masks and social distancing, as well as the fact that the office lacked even basic 

supplies such as paper towels and sanitary products in the kitchen and bathrooms. 

90. On June 2, 2020, after working part of the day in the office, Ms. Ferro texted Mr. 

Perez that she was leaving to work from home and that Ms. Pagliery would work in her office for 

the rest of that day and on the next day. 

91. Mr. Perez responded abruptly, questioning her as to why this was. 

92. Ms. Ferro responded that there was “no adequate distancing” where Ms. Pagliery 

sat in the office. 

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93. Sensing that Mr. Perez was annoyed about her leaving, Ms. Ferro asked if Mr. 

Perez wanted her to go back to the office. 

94. After Mr. Perez responded that she was “the one with the office and not them,” 

Ms. Ferro returned to the office and allowed Ms. Pagliery to work from home. 

IV. As COVID-19 Cases Rise in Florida, Defendants Abruptly Terminate Ms. Ferro 

95. Businesses and public gathering places in Florida reopened (quickly and 

seemingly prematurely) in late May and early June, and the number of COVID-19 cases quickly 

began to rise. 

96. On June 4, 2020, the state broke its record for a single-day high of newly reported 

cases of COVID-19, with 1,419 new cases, and the state continued to report near-record highs 

over the next few days (a trend which, sadly, has continued well into August 2020). 

97. On Monday, June 8, 2020, Mr. Perez called Ms. Ferro into his office and told her 

that she was being let go because “things were not working out.” 

98. Ms. Ferro was shocked by the news, given that she had been a loyal and dedicated 

employee for the many years that she worked for Mr. Perez, and because she had recently, at the 

end of 2019, received an excellent performance review and a $25,000 raise. 

99. In addition, just two weeks before her termination, Ms. Ferro had received a 

$10,000 performance bonus that Mr. Perez wrote in a letter was a reflection of her “performance, 

the contributions [she] made, and the goals achieved on behalf of the company during the past 

year.” 

100. Ms. Ferro asked Mr. Perez why she was being terminated. Mr. Perez claimed that 

she had become “very forgetful” and used his hand to gesture a peak and valley – a 

representation of the ups and downs with her health issues. 

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101. Mr. Perez could tell that Ms. Ferro was not satisfied with his answer, and so Mr. 

Perez then claimed that she had been forgetful about some issues with providers and said, 

without any detail, that middle management executives had expressed concerns about her. 

102. Mr. Perez also falsely accused Ms. Ferro of proposing a final settlement to a 

provider without authority when Mr. Perez knew she had only asked whether the provider was 

interested in settling a claim dispute. 

103. Since Mr. Perez clearly knew what he was doing was wrong, Mr. Perez took care 

to assure Ms. Ferro that she would retain her stock in the company, said that Mr. Perez would 

pay her through August 2020, and offered to let her resign. 

104. Ms. Ferro told Mr. Perez that it was clear that Mr. Perez had made a final 

decision, but that she and Mr. Perez knew that she was not being let go for proper reasons. 

105. On June 23, 2020, Ms. Ferro received a text from Mr. Perez’s administrative 

assistant asking her for a resignation letter. 

106. Ms. Ferro responded that she did not resign from her job. 

107. After her termination, Ms. Ferro also received numerous messages from 

employees and service providers expressing their surprise that Ms. Ferro left Doctors HealthCare 

and telling her that she would be missed. 

108. Unfortunately, Mr. Perez and Doctors HealthCare’s disregard for employees’ 

health in the workplace amid the COVID-19 pandemic, as well as their unlawful termination of 

Ms. Ferro because of her medical issues and protected leave fit into a set of other unlawful 

and/or discriminatory conduct that Mr. Perez engaged in and/or allowed to occur in the 

workplace over the years of Ms. Ferro’s employment. Such further factual allegations will be 

added to this Complaint when it is amended in connection with Ms. Ferro’s discrimination and 

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hostile work environment claims, which must first go through an administrative filing and 

investigation process. 

FIRST CAUSE OF ACTION 

(Retaliation in Violation of the FMLA) 

Against Doctors HealthCare 

109. Plaintiff repeats, reiterates, and re-alleges each and every allegation in the 

preceding factual allegations, as though fully set forth herein. 

110. At all times relevant herein, Plaintiff was an “eligible employee” within the 

meaning of the FMLA. Plaintiff, a full-time employee of Doctors HealthCare, at all relevant 

times worked at least 1,250 hours in any 12-month period, and specifically did so during the 12-

month period preceding her termination. 

111. At all times relevant herein, Doctors HealthCare was a “covered employer” within 

the meaning of the FMLA. Doctors HealthCare employs 50 or more employees during at least 

20 calendar weeks over the covered period within a 75-mile radius of the Company. 

112. By the actions described above, among others, Defendants have retaliated against 

Ms. Ferro for taking FMLA leave, including by, inter alia, reducing her pay and terminating her 

employment. 

113. As a direct and proximate result of Defendants’ unlawful retaliatory conduct in 

violation of the FMLA, Plaintiff has suffered, and continues to suffer, monetary and/or other 

economic harm for which she is entitled to an award of monetary damages, liquidated damages, 

reasonable attorneys’ fees and expenses, and other relief. 

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SECOND CAUSE OF ACTION 

(Unlawful Interference in Violation of the FMLA) 

Against Doctors HealthCare 

114. Plaintiff repeats, reiterates, and re-alleges each and every allegation in the 

preceding factual allegations section, as though fully set forth herein. 

115. At all times relevant herein, Plaintiff was an “eligible employee” within the 

meaning of the FMLA, and Doctors HealthCare was a “covered employer” within the meaning 

of the FMLA. 

116. By the actions described above, among others, Defendants have unlawfully 

interfered with Ms. Ferro’s right to take FMLA leave by denying her notice required under the 

FMLA regulations. 

117. Defendants further unlawfully interfered with Ms. Ferro’s rights under the FMLA 

by terminating her employment because she suffered from a serious medical condition that had 

in the past, and likely would continue to in the future, require Ms. Ferro to take leave to treat her 

serious medical condition. 

118. As a direct and proximate result of Defendants’ unlawful conduct in violation of 

the FMLA, Plaintiff has suffered, and continues to suffer, monetary and/or other economic harm 

for which she is entitled to an award of monetary damages, liquidated damages, reasonable 

attorneys’ fees and expenses, and other relief. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against 

Defendants, containing the following relief: 

A. A declaratory judgment that the actions, conduct and practices of Defendants 

complained of herein violate the laws of the United States; 

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B. An injunction and order permanently restraining Defendants and their partners, 

officers, owners, agents, successors, employees and/or representatives, and any and all persons 

acting in concert with them, from engaging in any such further unlawful conduct, including the 

policies and practices complained of herein; 

C. An award of damages against Defendants, or any jointly or severally liable entity 

or person, in an amount to be determined at trial, plus prejudgment interest, to compensate 

Plaintiff for all monetary and/or economic damages, including, but not limited to, loss of past 

and future income, wages, including overtime wages, compensation, seniority, and other benefits 

of employment; 

D. An award of damages against Defendants, or any jointly or severally liable entity 

or person, in an amount to be determined at trial, plus prejudgment interest, to compensate 

Plaintiff for all non-monetary and/or compensatory damages, including, but not limited to, 

compensation for her emotional distress; 

E. An award of damages for any and all other monetary and/or non-monetary losses 

suffered by Plaintiff, including, but not limited to, loss of income, earned bonus pay, reputational 

harm, and harm to professional reputation, in an amount to be determined at trial, plus 

prejudgment interest; 

F. An award of punitive damages, and any applicable penalties and/or liquidated 

damages in an amount to be determined at trial; 

G. Prejudgment interest on all amounts due; 

H. An award of Plaintiff’s reasonable attorneys’ fees and costs; and, 

I. Such other and further relief as the Court may deem just and proper. 

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JURY DEMAND 

Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein. 

Dated: August 19, 2020 

New York, New York Respectfully submitted, 

WIGDOR LLP 

By: ____________________________

Bryan L. Arbeit 

(Bar No. 1010329) 

Lawrence M. Pearson 

(to be admitted pro hac vice) 

85 Fifth Avenue 

New York, NY 10003 

Telephone: (212) 257-6800 

Facsimile: (212) 257-6845 

barbeit@wigdorlaw.com 

lpearson@wigdorlaw.com 

Counsel for Plaintiff 

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