UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO.: 1:20-cv-23151-BLOOM/LOUIS 

KAREEM PICKERING and AARON ) 

MUHAMMED, ) 

) 

Plaintiffs, ) 

) 

v. ) 

) 

AKAL SECURITY, INC., ) 

) 

Defendant. ) 

__________________________________________) 

ANSWER TO COMPLAINT 

COMES NOW, Defendant Akal Security, Inc. ("Defendant” or “Akal Security”), by and 

through the undersigned counsel, and answers the Complaint of Plaintiffs Kareem Pickering and 

Aaron Muhammed ("Plaintiffs"), as follows: 

1. Answering paragraph 1 of the Complaint, Defendant admits only that Plaintiffs 

bring this action seeking damages for alleged race and national origin discrimination pursuant to 

the Florida Civil Rights Act of 1992 (“FCRA”), but denies any such claims have any merit or that 

Plaintiffs are entitled to any relief whatsoever. 

2. Defendant admits the allegations in paragraph 2 of the Complaint. 

3. Answering paragraph 3 of the Complaint, Defendant admits that venue is proper in 

this Court, but denies that any valid claims are asserted by Plaintiffs. 

4. Defendant admits the allegations in paragraph 4 of the Complaint. 

5. Defendant admits the allegations in paragraph 5 of the Complaint. 

6. Answering paragraph 6 of the Complaint, Defendant admits Plaintiffs were 

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employed by Defendant. Defendant denies the remaining allegations in paragraph 6 of the 

Complaint. 

7. Answering paragraph 7 of the Complaint, Defendant admits that it was an employer 

within the meaning of the FCRA and that it did business in Miami-Dade County. Defendant denies 

the remaining allegations in paragraph 7 of the Complaint. 

EXHAUSTION OF ADMINISTRATIVE REMEDIES 

8. Defendant denies the allegations in paragraph 8 of the Complaint. 

STATEMENT OF FACTS

9. Answering paragraph 9 of the Complaint, Defendant admits that Plaintiffs are AfricanAmerican males and worked for Defendant. Defendant denies the remaining allegations in 

paragraph 9 of the Complaint. 

10. Answering paragraph 10 of the Complaint, Defendant admits that Plaintiffs were both 

terminated on or about September 19, 2018. Defendant denies the remaining allegations in 

paragraph 9 of the Complaint. 

11. Answering paragraph 11 of the Complaint, Defendant admits that two armed 

detention officers who left a shotgun in a van were issued a suspension. Defendant denies the 

remaining allegations in paragraph 11 of the Complaint. 

12. Defendant denies the allegations in paragraph 12 of the Complaint. 

13. Defendant denies the allegations in paragraph 13 of the Complaint. 

14. Defendant denies the allegations in paragraph 14 of the Complaint. 

COUNT I 

FRCA – RACE DISCRIMINATION 

15. Defendant incorporates paragraphs 1-14 as if fully set forth herein. 

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16. Defendant denies the allegations in paragraph 16 of the Complaint. 

17. Defendant denies the allegations in paragraph 17 of the Complaint. 

18. Defendant denies the allegations in paragraph 18 of the Complaint. 

19. Defendant denies the allegations in paragraph 19 of the Complaint. 

COUNT II 

FRCA – NATIONAL ORIGIN DISCRIMINATION 

20. Defendant incorporates paragraphs 1-19 as if fully set forth herein. 

21. Defendant denies the allegations in paragraph 21 of the Complaint. 

22. Defendant denies the allegations in paragraph 22 of the Complaint. 

23. Defendant denies the allegations in paragraph 23 of the Complaint. 

24. Defendant denies the allegations in paragraph 24 of the Complaint. 

To the extent that Plaintiffs’ prayer for relief requires a response or any allegation remains 

unanswered, Defendant denies such allegations. 

AFFIRMATIVE AND OTHER DEFENSES

FIRST DEFENSE 

The Complaint should be dismissed, in whole or in part, because some or all of Plaintiffs’ 

allegations fail to state a claim upon which relief can be granted. 

SECOND DEFENSE 

All or part of Plaintiffs’ claims are barred by the applicable statutes of limitations. 

THIRD DEFENSE

Plaintiffs’ claims may be barred on doctrines of laches, unclean hands, and after acquired 

evidence. 

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FOURTH DEFENSE

The Complaint may be barred, in whole or in part, because Defendants at all times acted 

reasonably and in good faith towards Plaintiffs. 

FIFTH DEFENSE

The Complaint may be barred, in whole or in part, by Plaintiffs’ failure to mitigate their 

alleged damages. 

SIXTH DEFENSE

Any adverse employment actions taken against Plaintiffs were for business reasons 

unrelated to their race or national origin. 

SEVENTH DEFENSE

Any alleged damages claimed by Plaintiffs were not proximately cause by the actions of 

Defendant and/or were caused by Plaintiffs’ own actions.

EIGHTH DEFENSE

To the extent any adverse employment action was motivated in part by Plaintiffs’ race or 

national origin, the same action would have been taken by Defendant even in the absence of such 

motivation. 

NINTH DEFENSE 

Plaintiffs’ claims are barred in whole or part because they failed to timely exhaust their 

administrative remedies. 

Defendant reserves the right to amend its Answer, to add affirmative or other defenses, 

or to withdraw defenses as deemed appropriate after discovery. 

WHEREFORE, having fully answered the Complaint, Defendant Akal Security 

respectfully requests: 

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1. Judgment entered in favor of Defendant, this action dismissed with prejudice, and 

Plaintiffs have and recover nothing of Defendant by way of this action; 

2. Judgment be entered against Plaintiffs and in favor of Defendant for all costs and 

attorneys’ fees incurred in the defense of this action; and 

3. Defendant recover such other and further relief as this Court may deem just and 

proper. 

Date: August 3, 2020 

Respectfully submitted, 

s/ Neil D. Kodsi 

Neil D. Kodsi, Esq. 

Florida Bar No. 0011255 

E-mail: neil.kodsi@jacksonlewis.com

JACKSON LEWIS P.C. 

One Biscayne Tower, Suite 3500 

2 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: 305-577-7600 

Attorneys for Akal Security, Inc. 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on August 3, 2020, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day on all counsel of record or pro se parties identified on the attached Service 

List via transmission of Notices of Electronic Filing generated by CM/ECF. 

s/ Neil Kodsi 

Neil D. Kodsi, Esq. 

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SERVICE LIST 

Chad E. Levy, Esq. 

E-mail: chad@levylevylaw.com 

David M. Cozad, Esq. 

E-mail: david@levylevylaw.com 

LEVY & LEVY, P.A. 

1000 Sawgrass Corporate Parkway, Suite 588 

Sunrise, Florida 33323 

Telephone: 954-763-5722 

Counsel for Plaintiffs 

Neil D. Kodsi, Esq. 

E-mail: neil.kodsi@jacksonlewis.com 

JACKSON LEWIS P.C. 

One Biscayne Tower, Suite 3500 

2 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: 305-577-7600 

Counsel for Akal Security, Inc. 

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