IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

SHEKEARA ADMORE,

Plaintiff, CASE NO.:

v.

HOSPICE OF PALM BEACH COUNTY, 

INC. d/b/a TRUSTBRIDGE HOSPICE 

FOUNDATION, INC., 

Defendant.

_____________________________________/

COMPLAINT 

Plaintiff, SHEKEARA ADMORE, by and through her undersigned counsel, hereby sues 

Defendant, HOSPICE OF PALM BEACH COUNTY, INC. d/b/a TRUSTBRIDGE HOSPICE 

FOUNDATION, INC., and states as follows:

JURISDICTION AND VENUE

1. Jurisdiction of this Court is invoked pursuant to the Family and Medical Leave Act 

(FMLA), 29 U.S.C. §2601, et seq.

2. Venue lies within United States District Court for the Southern District of Florida, 

West Palm Beach Division because a substantial part of the events giving rise to this claim 

occurred in this Judicial District and is therefore proper pursuant to 28 U.S.C. 1391(b). 

PARTIES

3. Plaintiff, SHEKEARA ADMORE (hereinafter as “Admore” or “Plaintiff”), is a 

resident of West Palm Beach County, Florida, at all times material and was an employee of 

Defendant within the meaning of the Family and Medical Leave Act (FMLA).

4. Defendant, HOSPICE OF PALM BEACH COUNTY, INC. d/b/a 

TRUSTBRIDGE, INC., is a Florida corporation authorized and doing business in this Judicial 

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District. 

GENERAL ALLEGATIONS

5. At all times material, Defendant acted with malice and reckless disregard for 

Plaintiff’s federally protected rights.

6. At all times material, Plaintiff was qualified to perform her job duties within the 

legitimate expectations of her employer. 

7. Plaintiff has retained the undersigned counsel to represent her in this action and is 

obligated to pay them a reasonable fee for their services.

8. Plaintiff requests a jury trial for all issues so triable. 

FACTUAL ALLEGATIONS

9. Plaintiff began her employment with Defendant on or around February 27, 2017 as 

a RN Floating Manager.

10. In or around January 29, 2020, Plaintiff was approved for FMLA.

11. On April 24, 2020, Plaintiff returned to work but her job duties were significantly 

changed prior to taking FMLA. Plaintiff worked 5 days a week in the office but upon return to 

work, plaintiff’s job assignment location was changed to work 3 days a week (Monday, Wednesday, 

and Friday) in Jupiter Medical Center’s Inpatient Hospice Unit and 2 days a week (Tuesday and 

Thursday) at home.

12. On April 24, 2020, Plaintiff submitted a doctor’s note to Human Resource 

representative, Fazieh Formosa, which stated that Plaintiff needed to work from home due to her 

son’s underlying medical condition and covid-19.

13. On April 27, 2020, Plaintiff was told the organization could not support the Plaintiff 

working from home nor in the office setting 5 days per week, therefore, the Plaintiff’s workload 

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would be reduced from full time hours of pay, 40 hours per week, to part time 16 hours per week 

for 30 days to work at home on Tuesdays and Thursday of each week.

14. On May 13, 2020, an email was sent to all employees stating the organization would 

accommodate all full-time employees who were affected by COVID 19 to maintain their full-time 

status until June 30, 2020. Despite the said accommodation, Plaintiff continued to only be permitted 

to work part time, 16 hours per week (Tuesdays and Thursdays) until June 30, 2020.

15. On May 28, 2020, Plaintiff was granted an additional 30 days to work from home 2 

days a week with the stipulation that she had to return to work full duty by June 30, 2020.

16. On June 30, 2020, Plaintiff received a call from Area Director, Elaine Williams and 

Chief Nursing Officer, Jacqueline Lopez-Devine confirming her return to work on July 1, 2020. 

Plaintiff confirmed her return to work.

17. Shortly afterwards, Plaintiff received a second call from Ms. Williams and Ms. 

Lopez-Devine informing she was required to work in Jupiter Medical Center Hospital’s Inpatient 

Hospice unit 3 days a week and in the Area 4 office 2 days a week.

18. Plaintiff made Ms. Williams aware and reminded Mrs. Lopez- Devine, Plaintiff 

could not work in the said capacity in the Inpatient Unit amongst positive COVID patients due to 

health reasons but could return to the office 5 days per week as assigned prior to FMLA.

19. Plaintiff was told that if she could not fulfill her job duties, she would need to resign.

20. Later in the day, Plaintiff received a call from Pauline Christian, Sr. Human 

Resource representative, along with ElvaLinda Gonzalez who told Plaintiff they were informed that 

she could not return to work due to her son’s medical condition and therefore needed to tender her 

resignation.

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21. Plaintiff explained to Ms. Christian that she was not resigning and wanted to return 

to her normal job duties she was performing prior to FMLA working in the office and not with 

patients due to her son’s medical condition.

22. Plaintiff was told they could not accommodate her request and was constructively 

discharged.

COUNT I

FAMILY MEDICAL LEAVE ACT – INTERFERENCE

23. Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in 

Paragraphs 1 through 22.

24. Plaintiff is an individual entitled to protection under the Family and Medical Leave 

Act (FMLA), 29 U.S.C. §2601, et seq.

25. Plaintiff is an eligible employee within the meaning of the FMLA because Plaintiff 

worked for Defendant for twelve (12) months and had at least 1,250 hours of service for the 

Defendant during twelve (12) months immediately preceding her FMLA leave. 

26. Plaintiff is a covered employee within the meaning of FMLA. 

27. Defendant’s actions interfered with Plaintiff’s lawful exercise of her FMLA rights. 

Specifically, Defendant interfered with Plaintiff’s lawful right to apply for and take FMLA leave 

and to be reinstated to the same or equivalent job position upon her return from her FLMA.

28. Defendant’s actions interfered with Plaintiff’s lawful exercise of her FMLA rights 

and constitute violations of the FMLA.

29. As a result of Defendant’s unlawful actions Plaintiff has suffered damages.

WHEREFORE, Plaintiff, SHEKEARA ADMORE, prays for judgment against the 

Defendant, HOSPICE OF PALM BEACH COUNTY, INC. d/b/a TRUSTBRIDGE HOSPICE 

FOUNDATION, INC., for the following damages:

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a. Back pay and benefits;

b. Prejudgment interest on back pay and benefits;

c. Front pay and benefits;

d. Liquidated damages;

e. Attorneys’ fees and costs;

f. Injunctive relief; and

g. For any other relief, this Court deems just and equitable.

COUNT II

(FAMILY AND MEDICAL LEAVE ACT -- RETALIATION)

30. Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in 

Paragraphs 1 through 22.

31. Defendant retaliated against Plaintiff in violation of the FMLA in that Plaintiff’s 

request for time off and utilization of qualified FMLA leave was a substantial or motivating factor 

that prompted Defendant to not reinstate Plaintiff to her same or similar job position.

32. Defendant’s actions constitute a violation of the FMLA.

33. As a result of Defendant’s actions Plaintiff has suffered damages.

WHEREFORE, Plaintiff, SHEKEARA ADMORE, prays for judgment against the 

Defendant, HOSPICE OF PALM BEACH COUNTY, INC. d/b/a TRUSTBRIDGE HOSPICE 

FOUNDATION, INC., for the following damages:

a. Back pay and benefits;

b. Prejudgment interest on back pay and benefits;

c. Front pay and benefits;

d. Liquidated damages;

e. Attorneys’ fees and costs;

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f. Injunctive relief; and

g. For any other relief, this Court deems just and equitable.

DEMAND FOR JURY TRIAL

34. Plaintiff, SHEKEARA ADMORE, requests a jury trial on all issues so triable.

Dated this 11th day of August 2020.

FLORIN GRAY BOUZAS OWENS, LLC

/s/Christopher D. Gray

CHRISTOPHER D. GRAY, ESQUIRE

Florida Bar No.: 902004

Primary: chris@fgbolaw.com

Secondary: debbie@fgbolaw.com

WOLFGANG M. FLORIN, ESQUIRE

Florida Bar No.: 907804

wolfgang@fgbolaw.com

16524 Pointe Village Drive, Suite 100

Lutz, FL 33558

Telephone (727) 254-5255

Facsimile (727) 483-7942

Attorneys for Plaintiff

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