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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NUMBER: ____________________

YU LI,

Plaintiff,

vs.

JONATHAN’S LANDING GOLF CLUB, INC.,

Defendant.

______________________________________/

COMPLAINT

COMES NOW, Plaintiff, YU LI, by and through her undersigned counsel, and sues the 

Defendant, JONATHAN’S LANDING GOLF CLUB, INC., and alleges as follows:

INTRODUCTION

1. This is a proceeding for damages to redress the deprivation of rights secured to 

the Plaintiff by the Family and Medical Leave Act, 29 U.S.C. 2601-2654 (“FMLA”).

JURISDICTION AND VENUE

2. The Court has jurisdiction over their controversy based upon the FMLA, and 

venue is proper as all acts described herein occurred within this judicial district. 

PARTIES

3. At all times material hereto, the Plaintiff was/is a citizen of the United States, sui 

juris, and an employee of the Defendant.

4. At all times material hereto, the Plaintiff was an employee and member of a 

protected class within the meaning of the FMLA.

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5. At all times material hereto, Defendant was a Florida Corporation doing business 

and services in this judicial district, was the employer or former employer of the Plaintiff, and is 

an employer as defined by the FMLA.

EXHAUSTION OF ADMINISTRATIVE REMEDIES

6. The Plaintiff has exhausted and fulfilled all conditions precedent to the institution 

of this action.

STATEMENT OF FACTS

7. The Plaintiff was an employee for the Defendant since October 5, 2010 and began 

her employment as a server. 

8. Over the years, due to outstanding performance, Plaintiff was promoted to dining 

room supervisor and eventually restaurant manager. 

9. Unfortunately, due to fatigue, back pain, and anxiety due to an incident that 

occurred at work in mid-February of 2020, Plaintiff was placed on FMLA leave from February 

29, 2020 to March 9, 2020, and was to take reduced/intermittent leave thereafter for up to three 

months. 

10. However, on March 22, 2020, while Plaintiff was still working with the 

restrictions of reduced hours, she was furloughed, and on May 6, 2020, she was terminated. 

11. Yet, Plaintiff had her position filled by another employee with much less 

experience who had not taken FMLA leave.

COUNT I

FMLA INTERFERENCE

12. The Plaintiff incorporates by reference paragraphs 1-11 herein.

13. At all times material to this lawsuit, the Plaintiff was entitled to leave under the 

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FMLA.

14. The Defendant unlawfully interfered with the Plaintiff’s exercise of her FMLA 

rights by failing to maintain her employment during her FMLA leave. 

15. As a direct and proximate result of the Defendant’s unlawful treatment, the 

Plaintiff has suffered damages and will continue to suffer irreparable injury and damages in the 

future, under the FMLA.

16. The Plaintiff is entitled to an award of reasonable attorney's fees, expert fees, 

costs and expenses related to this litigation under the FMLA.

WHEREFORE, the Plaintiff, YU LI, requests that judgment be entered against the 

Defendant, JONATHAN’S LANDING GOLF CLUB, INC., for all damages recoverable under 

the FMLA, in addition to all litigation expenses and costs, including attorneys’ fees and any 

other lawful and equitable relief this Court deems to be just and proper.

COUNT II

FMLA RETALIATION

17. The Plaintiff incorporates by reference paragraphs 1-11 herein.

18. At all times material to this lawsuit, the Plaintiff was entitled to leave under the 

FMLA.

19. As a result of this exercise of the FMLA, the Defendant intentionally, willfully 

and unlawfully retaliated against the Plaintiff, in violation of the FMLA.

20. That the Defendant’s decision to adversely affect the Plaintiff was both connected 

to, and in response to the Plaintiff’s FMLA coverage.

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21. As a direct and proximate result of the Defendant’s unlawful treatment, the 

Plaintiff has suffered damages and will continue to suffer irreparable injury and damages in the 

future, under the FMLA.

22. The Plaintiff is entitled to an award of reasonable attorney's fees, expert fees, 

costs and expenses related to this litigation under the FMLA.

WHEREFORE, the Plaintiff, YU LI, requests that judgment be entered against the 

Defendant, JONATHAN’S LANDING GOLF CLUB, INC., for all damages recoverable under 

the FMLA, in addition to all litigation expenses and costs, including attorneys’ fees and any 

other lawful and equitable relief this Court deems to be just and proper.

DEMAND FOR JURY TRIAL

The Plaintiff demands a jury trial.

Dated: August 11, 2020. Respectfully submitted,

Law Offices of Levy & Levy, P.A.

1000 Sawgrass Corporate Parkway, Suite 588

Sunrise, Florida 33323

Telephone: (954) 763-5722

Facsimile: (954) 763-5723

Counsel for Plaintiff

/s/ Chad Levy

CHAD E. LEVY, ESQ.

chad@levylevylaw.com

Secondary: assistant@levylevylaw.com

F.B.N.: 0851701

DAVID M. COZAD, ESQ.

david@levylevylaw.com

F.B.N.: 333933

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