UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

LATOYA FREEMAN, as guardian of

ALEXANDER FREEMAN,

Plaintiff,

v.

AMERISURE MUTUAL INSURANCE 

COMPANY, a foreign corporation, 

Defendant.

 

______________________________________/

CASE NO: 1:20-CV-23562-UU

AMENDED COMPLAINT

Plaintiff LATOYA FREEMAN, as guardian of ALEXANDER FREEMAN, 

by and through undersigned counsel, sues Defendant AMERISURE MUTUAL 

INSURANCE COMPANY, and states as follows:

PARTIES, JURISDICTION, AND VENUE

1. This is an action for damages that exceed $75,000, exclusive of interest 

and costs, and is otherwise within the jurisdictional limits of this Honorable Court.

2. At all times material hereto, Alexander Freeman was a citizen of Palm 

Beach County, Florida, over the age of eighteen years.

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3. Plaintiff Latoya Freeman, also a citizen of Florida and over the age of 

eighteen years, has been duly appointed as Alexander Freeman’s guardian and legal 

representative. 

4. At all times material hereto, Defendant Amerisure Mutual Insurance 

Company was incorporated in, and organized under the laws of the State of 

Michigan, with its principal place of business in Michigan, and doing business 

throughout Florida, including Miami-Dade County. 

5. Amerisure is engaged in substantial, continuous, systematic and nonisolated business activity within the state of Florida. Amerisure is subject to personal

jurisdiction in Florida because it regularly conducts business in Florida and it 

committed the tortious actions outlined in this complaint in the state of Florida. 

6. All conditions precedent to this action have been fully performed or 

waived.

7. Plaintiff originally filed this action in the Circuit Court of Florida’s 

Eleventh Judicial Circuit. Defendant Amerisure removed Plaintiff’s action to this 

Court due to diversity of citizenship. (D.E. 1 ¶ 1). 

8. Plaintiff files this Amended Complaint pursuant to Federal Rule of 

Civil Procedure 15(a)(1)(B), which permits a party to amend its pleading once as a 

matter of course within 21 days after service of a motion under Rule 12(b). 

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GENERAL ALLEGATIONS

9. At all times material hereto, Alexander Freeman was employed as an 

electrical worker by Bonded Lighting Protection Systems, Inc. (“Bonded”). 

10. On February 14, 2019, Alexander was working for Bonded on a 

construction site in Aventura, Florida. At approximately 1:15 p.m., during the course 

and scope of his employment, Alexander fell approximately 20 feet, resulting in 

catastrophic injuries, including a traumatic brain injury, that caused his physical and 

mental incapacitation.

11. Alexander’s workplace injury was covered under a workers’

compensation insurance policy issued to his employer by Defendant Amerisure. 

12. Defendant Amerisure, by and through its employees and agents, 

exercised the exclusive ability to authorize or deny coverage for, and otherwise 

control access to, medical treatment needed by Alexander as a result of his 

workplace injury. 

13. Alexander was legally entitled to receive the “quick and efficient 

delivery of disability and medical benefits” and the “prompt delivery of benefits”

pursuant to section 440.015, Florida Statutes. 

14. Alexander was taken by ambulance to the Aventura Hospital & Medical 

Center, where he was admitted in critical condition and in a comatose state. 

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15. Bonded promptly reported the incident to its workers’ compensation 

carrier, Defendant Amerisure.

16. Within an hour after the accident, Amerisure adjuster Angel Goldstein 

retained the services of an outside limited liability company, ALCC, to dispatch a 

mobile drug testing unit to the Aventura Medical Center to collect and test 

Alexander’s urine for illicit drugs.

17. At all times relevant hereto, ALCC, and its agents and employees, were

acting as agents of Defendant Amerisure, and acting within the course and scope of 

that agency relationship, making Defendant Amerisure vicariously liable for the 

conduct of ALCC, its agents, and its employees.

18. Realizing Alexander was unable to consent to the collection and testing 

of his urine, ALCC owner, Renee Bryant, emailed Amerisure adjuster Goldstein: 

Do you by any chance have a signed drug testing 

authorization that the employee may have signed preemployment? Sometimes that helps in these cases where 

the Claimant is unconscious and unable to consent. 

Situations like this always make the hospital staff nervous 

and sometimes unwilling to allow us in to take a specimen 

from the bedside catheter bag, but a signed authorization 

always helps.

In the alternative, I recommend that if the accident 

happened today and it’s that critical, we allow the hospital 

to stabilize him and attend to him medically tonight and 

we can go out in the morning and try to secure a sample 

for you. We can sometimes get Risk Management at the 

hospital to pave the way for us, but it’s too late in the day 

to get them now. We can definitely go out in early in the 

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morning and see what we can do –again, if you have a 

signed authorization, it would certainly help...

19. Alexander’s employer provided an “Employee Acknowledgment 

Agreement” signed by Alexander six years earlier, on February 2, 2013, to adjuster 

Goldstein and ALCC owner Bryant, which stated:

I understand that if I am injured during the course and 

scope of my employment and I test positive for the 

presence of alcohol and/or drugs, I may forfeit my 

eligibility for medical and indemnity benefits under 

Florida’s workers’ compensation law (Florida Statutes 

440.101, 440.102). I also understand that a refusal to test 

under this circumstance will automatically result in 

forfeiture of my eligibility for medical and indemnity 

benefits and immediate termination from employment.

(Emphasis added).

20. Notably, in this Employee Acknowledgement Agreement, Alexander 

did not consent to the collection of his urine, or even consent to undergo drug and/or 

alcohol testing. While the underlined language in the Employee Acknowledgement 

Agreement purports to forfeit Alexander’s eligibility for workers’ compensation 

benefits if he refuses such testing, this provision is unconstitutional and invalid. See 

Recchi Am. Inc. v. Hall, 692 So. 2d 153, 154 (Fla. 1997) (holding irrebuttable 

presumption that workplace injury was caused primarily by the intoxication of the 

employee violates the constitutional right to due process). 

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21. The “Employee Acknowledgement Agreement” is also in violation of 

Florida Statute 440.21(2), which provides “An Agreement by an employee to waive 

her or his right to compensation as required by this chapter is invalid”.

22. ALCC then dispatched Jonathan Alvarez to collect Alexander’s urine. 

23. The very evening that Alexander was catastrophically injured and 

admitted to the hospital in critical condition, Jonathan Alvarez, without identifying 

himself or stating his purpose, interrupted a prayer group by Alexander’s family at 

the hospital to ask for a medical proxy, and took Alexander’s sister, Latoya Freeman,

aside. 

24. Alvarez told Latoya Freeman that he needed her to sign important 

paperwork for Alexander’s employer without disclosing that he was at the hospital 

to collect Alexander’s urine. 

25. Alvarez disclosed the reason for his presence at the hospital only after 

a nurse demanded to know why he was there. After the nurse left, Alvarez pressured

Latoya Freeman by telling her that she had no option but to sign the papers, and that 

it was important that she do so immediately. 

26. Latoya signed the document presented by Alvarez without knowing

what she was signing. 

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27. Shortly after giving Alvarez her signature, a nurse advised Latoya that 

Alvarez was from workers’ compensation and was not at the hospital to help 

Alexander. 

28. Latoya then quickly advised Alvarez that she withdrew any consent for 

sampling Alexander’s urine. 

29. Nevertheless, Alvarez snuck into Alexander’s hospital room to take 

urine from his Foley catheter bag, but his efforts were thwarted when he was caught 

by a nurse prior to obtaining a urine sample. 

30. The following day, February 15, 2019, Alvarez returned to Aventura 

Medical Center and contacted the Risk Management Department to request a sample 

of Alexander’s urine. Alvarez provided the Risk Management Department the 

invalid Employee Acknowledgment Agreement in an attempt to demonstrate no 

consent was needed for the collection of Alexander’s urine, but the Department

denied Alvarez’s request. 

31. ALCC continued its efforts to get Alexander’s urine despite his 

inability to give consent. An ALCC supervisor called Aventura Medical Center’s 

Risk Management Department to again request access to take a sample of 

Alexander’s urine, but that request was also denied. 

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32. Alexander’s employer, Bonded, advised an Amerisure adjuster that 

Alexander’s accident should be covered by workers’ compensation even if his urine 

sample was positive for drugs.

33. In light of the difficulties the carrier was having obtaining Alexander’s 

urine, workers’ compensation counsel for Amerisure/Bonded filed a “Motion to 

Preserve Evidence” of blood, urine, and or other bodily fluids of Alexander Freeman

in the workers’ compensation court on February 15, 2019.

34. The motion was denied the same day it was filed. 

35. Upon information and belief, ALCC and Defendant Amerisure

continued to seek access to Alexander’s urine through the hospital’s Risk 

Management Department with collector Alvarez’ supervisor, Franklin Bryant, now 

pressuring the hospital’s Risk Management Department to allow collection of 

Alexander’s urine using the unconstitutional and invalid Employee 

Acknowledgment Agreement.

36. The Risk Management Department, at the direction of the hospital’s 

in-house counsel, made the decision to allow ALCC and Defendant Amerisure to 

collect a urine specimen from Alexander’s Foley catheter without consent. The Risk 

Management Department based its decision on the unconstitutional and invalid 

Employee Acknowledgment Agreement signed by Alexander in 2013. 

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37. Shortly thereafter, ALCC collector Alvarez collected Alexander’s 

urine sample, erroneously listing the date of collection as 14 February 2019 at 5:43

p.m. when the date of collection was February 15, 2019. ALCC sent the sample out 

for testing. 

38. That evening, ALCC owner Bryant emailed Amerisure adjuster 

Goldstein informing her that:

We got the urine collected for you. The in-house hospital 

legal department intervened and allowed us to collect it 

based on your signed pre-employment authorization. 

Those really help! The sister rescinded her consent 

because one of the nurses told her she should not agree to 

this. Again, the hospital’s in-house legal intervened and 

spoke with her and she agreed to allow the test. We 

collected it tonight from his bedside catheter bag with the 

assistance of his attending nurse and the consent of the 

family. I will let you know as soon as the results are back! 

39. Alexander’s urine tested positive for carboxy-THC and a cocaine 

metabolite. 

40. On February 20, 2019, shortly after receiving the results, ALCC owner 

Bryant sent Amerisure adjuster Goldstein a copy of the laboratory report. 

41. ALCC owner Bryant told Amerisure adjuster Goldstein that the testing 

of Alexander’s urine was not in compliance with Florida law or regulation, such that 

the test results could not be used as a basis to deny Alexander’s claim for workers’

compensation benefits. 

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42. Under Chapter 440, Florida Statutes, once the carrier was notified of 

Alexander’s workplace injury, Defendant Amerisure had three options: pay the 

claim; deny the claim within 14 days; or investigate the claim for up to 120 days in 

order to determine compensability while paying the claim during the period of 

investigation.

43. On February 27, 2019, Amerisure denied Alexander’s workers’

compensation claim in its entirety “based on a positive post-accident drug test 

resulting in the claimant’s violation of the Employer’s drug free workplace program 

and the presumption that the accidental injuries were occasioned primarily by the 

intoxication of the claimant and/or the influence of such drugs at the time of the 

accident.” Thus, it used the test on the wrongfully obtained urine sample to deny 

Alexander treatment for the catastrophic injuries he suffered in the workplace 

accident, despite Alexander’s employer telling Amerisure that a positive drug test 

should not be used to deny Alexander workers’ compensation benefits, and despite 

ALCC telling Amerisure that the drug testing was not conducted in compliance with 

Florida law and could not legally be used to deny Alexander workers’ compensation 

benefits. 

44. Prior to its denial of Alexander’s workers’ compensation claim, despite 

being advised by his employer, Bonded, that Alexander’s claim should be approved 

even if he tested positive for drugs, Defendant Amerisure did not confirm whether 

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Bonded had a valid Drug Free Workplace Program, as required by the Florida 

statutes in order to deny workers’ compensation coverage based on the defense that 

the workplace accident was primarily caused by the employee being under the 

influence of drugs. 

45. Prior to its denial of Alexander’s workers’ compensation claim, 

Defendant Amerisure did not investigate whether Alexander’s injuries were 

primarily caused by drug impairment. 

46. Prior to its denial of Alexander’s workers’ compensation claim, 

Defendant Amerisure knew or should have known that Bonded’s Drug Free 

Workplace Program policy was not legally sufficient. 

47. Thus, despite knowing it had no legal basis on which to deny 

Alexander’s workers’ compensation claim, Defendant Amerisure, through its agents 

and employees, did just that. 

48. Defendant Amerisure denied Alexander’s workers’ compensation 

claim from February 27, 2019 until on or about December 3, 2019. 

49. As a result of Defendant Amerisure’s wrongful denial of his workers’

compensation claim, Alexander was denied specialized medical care for his brain 

injury, which exacerbated his injury and led to Alexander suffering from a rare bone 

disorder. 

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50. As a result of Defendant Amerisure’s wrongful denial of his workers’

compensation claim, Alexander was forced to live with his sister upon his discharge 

from Aventura Medical Center, without any specialized medical care or treatment, 

from about June 7, 2019, until July 19, 2019. The lack of proper care during this 

time exacerbated Alexander’s brain injury. 

51. On or about July 19, 2019, Alexander Freeman was admitted to an acute 

care facility based upon a letter of protection signed by his workers’ compensation 

attorneys. 

52. On or about December 3, 2019, Amerisure/Bonded accepted 

Alexander’s workers’ compensation claim. 

53. Defendant Amerisure has not, however, paid the total bill for the 

medical care and treatment provided to Alexander by the acute care facility, leaving 

Alexander with a debt of approximately $100,000. Defendant Amerisure has refused 

to pay the amount of the bill that exceeds the amount allowed by the workers’ 

compensation fee schedule because it contends such benefits are not recoverable 

under the workers’ compensation system. 

54. By this action, Plaintiff seeks, inter alia, damages for personal injuries, 

severe emotional distress, medical expenses, and other harm caused by Defendant

Amerisure’s intentional acts committed during the course of Alexander’s workers’

compensation claim, subsequent to and distinct from his original workplace injury. 

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COUNT I

BREACH OF FIDUCIARY DUTY

55. Plaintiff realleges paragraphs 1-54 as if fully set forth herein.

56. Defendant Amerisure owed Alexander a fiduciary duty by virtue of its

exclusive ability to authorize or deny Alexander’s workers’ compensation claim and 

his receipt of medical care and treatment for the injuries he sustained in the 

workplace accident. This fiduciary duty required Defendant Amerisure to place the 

interests of Alexander above its own financial interests. 

57. This fiduciary duty required Defendant Amerisure to authorize 

coverage for Alexander in accordance with Florida’s workers’ compensation law 

and in order to protect his health and well-being. 

58. Defendant Amerisure breached its fiduciary duty by refusing to 

authorize Alexander’s receipt of urgent medical care and treatment, including 

treatment for the catastrophic brain injury he suffered as a result of the workplace 

accident. 

59. Defendant Amerisure also breached its fiduciary duty by obtaining 

Alexander’s urine without his consent, after strong-arming Alexander’s sister to give 

her consent based on an invalid document signed by Alexander years before at the 

time of his hire.

60. Defendant Amerisure also breached its fiduciary duty by denying 

Alexander’s receipt of urgent medical care and treatment, including treatment for 

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the catastrophic brain injury he suffered as a result of the workplace accident, based 

upon the results the testing of Alexander’s urine, despite being advised by both 

Alexander’s employer and ALCC that the test results could not be used to deny 

Alexander’s claim for workers’ compensation benefits. 

61. Defendant Amerisure acted in this manner although it knew of the

wrongfulness of its conduct and the high probability that Alexander would suffer 

severe emotional distress, that Alexander’s condition would deteriorate, that 

Alexander would suffer extreme pain and suffering, and Alexander would suffer 

permanent physical injuries subsequent to and distinct from the workplace injury, 

but Defendant Amerisure intentionally pursued that course of conduct anyway. 

62. Defendant Amerisure took such tortious actions without justification 

and for the sole purpose of increasing their profits or bottom line by avoiding 

expenditures for care undeniably due Alexander under workers’ compensation law.

63. Defendant Amerisure’s tortious actions constitute an actionable tort, 

separate and apart from the obligation of Defendant to provide and authorize medical 

benefits for Alexander under the Florida Workers’ Compensation Act. 

64. Defendant Amerisure’s tortious actions resulted in injuries to 

Alexander that are separate and distinct from the workplace injury he suffered on or 

about February 14, 2019. 

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65. As a direct and proximate cause of Defendant Amerisure’s breach of 

fiduciary duty, Alexander has sustained damages. Alexander was unable to timely 

receive the necessary care and treatment needed to treat his workplace injuries, has 

suffered deteriorated health, has suffered physical injuries subsequent to and distinct 

from his original workplace injury, has endured extreme pain and suffering, 

disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life,

medical expenses, and aggravation of a previously existing condition, if any. The 

losses are either permanent or continuing and Alexander will suffer the losses in the 

future. 

WHEREFORE, Plaintiff demands judgment against Defendant Amerisure for 

compensatory and punitive damages, costs, pre-judgment and post-judgment 

interest, and for such other and further relief that this Court deems just and proper. 

COUNT II

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

66. Plaintiff realleges paragraphs 1-54 as if fully set forth herein.

67. Under Chapter 440, Alexander was entitled to receive workers’

compensation benefits, including, but not limited to, the prompt receipt of 

healthcare.

68. Defendant Amerisure, which is vicariously liable for the actions of its 

agent ALCC, which was at all relevant times acting within the course and scope of 

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this employment/agency relationship, is liable for the intentional infliction of 

emotional distress to Alexander as a result of:

a. denying Alexander essential, urgent, and medically necessary 

treatment and care, knowingly without any legitimate factual or legal basis, 

and knowing that such conduct would result in Alexander suffering permanent 

injury; 

b. wrongfully obtaining a sample of Alexander’s urine while he was 

in a comatose state based on an agreement that it knew was legally invalid;

c. wrongfully denying Alexander’s receipt of urgent medical care 

and treatment, including treatment for the catastrophic brain injury he suffered 

as a result of the workplace accident, after being advised by ALCC that the 

testing was not in compliance with Florida law and could not be used to deny 

Alexander his workers’ compensation benefits;

d. wrongfully denying Alexander’s receipt of urgent medical care 

and treatment, including treatment for the catastrophic brain injury he suffered 

as a result of the workplace accident, after being advised by Bonded that a 

positive test result should not be used to deny Alexander’s workers’ 

compensation benefits; and

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e. failing to pay Alexander his disability/indemnity benefits 

despite knowing that Plaintiff was in dire financial condition and depended on 

such benefits to provide food and shelter for himself and his minor child.

69. Defendant Amerisure knew of the wrongfulness of its conduct and the 

high probability that Alexander would suffer severe emotional distress and injury as

a result of its conduct, but Amerisure intentionally pursued that course of conduct 

anyway. 

70. Defendant Amerisure took such tortious actions without justification 

and for the sole purpose of increasing its profits or bottom line by avoiding 

expenditures for care undeniably due Alexander under workers’ compensation law. 

71. Defendant Amerisure’s tortious actions were unwarranted, outrageous, 

and extremely dangerous to the health and life of Alexander. 

72. By virtue of its exclusive authority to authorize Alexander’s receipt of 

workers’ compensation benefits, Defendant Amerisure was in a position of power 

over Alexander, and asserted that power to Alexander’s detriment. 

73. To Defendant Amerisure’s knowledge, Alexander, as a result of his 

physical condition after the workplace accident, was peculiarly susceptible to 

emotional distress, but Amerisure proceeded in its intentional misconduct in the face 

of such knowledge. 

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74. Defendant Amerisure’s tortious actions constitute an actionable tort, 

separate and apart from the obligation of Amerisure to provide and authorize medical 

benefits for Alexander under the Florida Workers’ Compensation Act. 

75. Defendant Amerisure’s tortious actions resulted in injuries to 

Alexander that are separate and distinct from the workplace injury he suffered on or 

about February 14, 2019.

76. When Alexander regained consciousness, he became aware of 

Defendant Amerisure’s actions—that it wrongfully obtained his urine sample; 

wrongfully relied on the test results of that sample to deny his workers’ 

compensation claim; wrongfully prevented him from obtaining urgent medical care 

and treatment, including treatment for the catastrophic brain injury he suffered as a 

result of the workplace accident, resulting in the exacerbation of his workplace 

injuries; and wrongfully withheld his disability/indemnity benefits despite knowing 

that Plaintiff was in dire financial condition and depended on such benefits to 

provide food and shelter for himself and his minor child. As a result of Defendant 

Amerisure’s conduct, Plaintiff suffered severe emotional distress.

77. In conducting these tortious actions, Defendant Amerisure engaged in 

unlawful, fraudulent, and outrageous conduct that goes beyond all bounds of 

decency and is extreme, outrageous, shocking, atrocious and utterly intolerable in a 

civilized society. 

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78. As a direct and proximate result of Defendant Amerisure’s conduct, 

Alexander has suffered severe emotional distress, and substantial other damages 

including bodily injury, resulting pain and suffering, disability, disfigurement, 

mental anguish, loss of capacity for the enjoyment of life, lost wages, and 

aggravation of a previously existing condition, if any. The losses are either 

permanent or continuing and Alexander will suffer the losses in the future. 

WHEREFORE, Plaintiff demands judgment against Defendant Amerisure for 

compensatory and punitive damages, costs, pre-judgment and post-judgment 

interest, and for such other and further relief that this Court deems just and proper. 

DEMAND FOR JURY TRIAL

Plaintiff demands trial by jury in this action of all issues that are so triable.

DATED this 16th day of September 2020.

Respectfully submitted,

s/ Diana L. Martin

THEODORE J. LEOPOLD, ESQ.

Florida Bar No: 705608

tleopold@cohenmilstein.com 

DIANA L. MARTIN, ESQ.

Florida Bar No.: 624489

dmartin@cohenmilstein.com

Cohen Milstein Sellers & Toll PLLC

2925 PGA Boulevard, Suite 200 

Palm Beach Gardens, FL 33410

T: (561) 515-1400

F: (561) 515-1401

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was filed 

with the Clerk of Court using the CM/ECF system on September 16, 2020, and the 

foregoing document is being served this day on all counsel or parties of record on 

the Service List below, either via transmission of Notices of Electronic Filing 

generated by CM/ECF or in some other authorized manner for those counsel or 

parties who are not authorized to receive Notices of Electronic Filing.

s/ Diana L. Martin

DIANA L. MARTIN, ESQ.

Florida Bar No.: 624489

dmartin@cohenmilstein.com

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SERVICE LIST

Joseph T. Kissane, Esquire

Cole, Scott & Kissane, P.A. - Jacksonville

Via Email: joseph.kissane@csklegal.com

4686 Sunbeam Rd., Suite 102

Jacksonville, FL 32257

Telephone: (904) 672-4000

Facsimile: (904) 672-4050

Via CM/ECF

Jason R. Hull, Esquire

Jessica C. Fernandez, Esquire (1015540)

WICKER SMITH O’HARA, McCOY & FORD, P.A.

100 N. Tampa St., Suite 1800

Tampa, FL 33602

Telephone: (813) 222-3939

Facsimile: (813) 222-3938

Via CM/ECF

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