UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

GAINESVILLE DIVISION

SANDRACHRISTINE LEPTICH,

 Plaintiff,

vs.

MERRITT HOSPITALITY, LLC 

d/b/a HEI HOTELS & RESORTS,

a Foreign Limited Liability 

Company,

 Defendants. 

______________________________/ 

 Case No.: 

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff, SANDRACHRISTINE LEPTICH (“Leptich” or “Plaintiff”), brings this 

action against Defendant, MERRITT HOSPITALITY, LLC d/b/a HEI HOTELS & 

RESORTS (“HEI”) for damages and all available relief under Title VII of the Civil Rights 

Act of 1964, 42 U.S.C. § 2000e, as amended by the Civil Rights Act of 1991, 42 U.S.C. 

§1981a (collectively “Title VII”).

SUMMARY OF THE ACTION

This case involves the discriminatory acts performed by HEI based on race, 

religion, and retaliation for engagement in protected activity. Leptich performed her job 

at a high level at HEI prior to being fired. However, at various times during her 

employment, Leptich was subjected to discriminatory comments against African American 

individuals. After complaining, Leptich was terminated. Title VII protects individuals 

from this specific type of disparate treatment and retaliation. HEI violated Title VII. As a 
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result, the harms and losses suffered by Leptich entitle her to money damages and other 

available relief. For her Complaint, Plaintiff respectfully states: 

PARTIES

1. Plaintiff, Leptich, is a citizen and resident of Alachua County, Florida. She 

is a former employee of Defendant.

2. Defendant, HEI, is a business entity with its principle place of business in 

Norwalk, Connecticut.

3. Defendant, HEI, conducts business across multiple states, including central 

and northern Florida.

JURISDICTION AND VENUE

4. Plaintiff brings this action for damages and all available relief under Title 

VII.

5. This Court has jurisdiction under 28 U.S.C. §§ 1331. Venue is proper under 

28 U.S.C. § 1391. These claims arise under the laws of the United States. The events 

giving rise to this action occurred within this District. 

6. Plaintiff has satisfied all administrative prerequisites to perfect her claim. 

Plaintiff filed a Charge of Discrimination with the Equal Employment Opportunity 

Commission (“EEOC”), incorporated herein, attached hereto and marked as Exhibit A, 

and the EEOC issued a notice of right to sue attached hereto and marked as Exhibit B.

Plaintiff brings this suit within ninety (90) days of receipt of her notice of right to sue. 

FACTS

7. Plaintiff started working for Defendant in approximately September 2017. 
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8. Plaintiff’s position was Director of Sales and Marketing.

9. Plaintiff is African-American.

10. Plaintiff is of Egyptian ethnicity and ancestry.

11. Plaintiff physically worked at the Hilton University of Florida Conference 

Center Gainesville (“Hotel”) in Gainesville, Florida that HEI was operating during the time 

period at-issue.

12. Plaintiff performed her job satisfactorily during her employment. 

13. At various times during her employment with HEI, Plaintiff was subjected 

to discriminatory comments about African-American individuals.

14. For example, in December 2017, General Manager, Cathy Zucker stated 

that African American employees sounded like a “hippo” and a “gorilla.” 

15. In approximately December 2017, an African American job candidate, Eric 

Brice, was being interviewed for a position, and Ms. Zucker questioned whether Ms.

Leptich and Merritt were going to hire “one of them” again.

16. Ms. Zucker’s comment referred directly to Mr. Brice’s race.

17. In January 2018, Catherine Salerno, VP Regional Sales/Marketing, openly 

considered race when assigning tasks to employees and when evaluating job candidates.

18. Specifically, Ms. Salerno stated that an African American employee, 

Georgette Lake, would be a “great fit” for the “SMERF” market of sales.

19. The “SMERF” market was knowingly of predominately African American 

clients. 
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20. Ms. Salerno also stated that she wanted to place Ms. Lake with African 

American clients because Ms. Lake could talk like “them” which, again, referred to 

African-American clientele.

21. In the same conversation, Ms. Salerno also stated that a white employee, 

Kari Wells, would be perfect for “corporate clients.” 

22. “Corporate clients” were knowingly of predominantly Caucasian clientele.

23. In the spring of 2018, Ms. Zucker told Plaintiff, “my black Lab bitch ebony 

is the meanest of all my dogs and I have to keep her separated from all my white and gold 

Labs.”

24. Ms. Zucker’s comment was made at a meeting and was directed at Plaintiff 

because of her race.

25. On January 16, 2019, Corporate Director of Finance/Transition, Marc 

Setless, shockingly, told Ms. Leptich that the Martin Luther King, Jr., holiday was a 

“Monkey Holiday.”

26. Ms. Leptich was extremely offended by this awful and discriminatory 

comment. 

27. Ms. Leptich complained to Merritt’s human resources representative, Alana 

Rawls, (and copied Ms. Zucker) about Mr. Setless’ discriminatory comment both verbally 

and in writing on January 22, 2019. 

28. After no action was taken by Merritt’s human resources about the 

discriminatory behavior of its directors, Ms. Leptich met with Ms. Rawls and complained 

to her in person about all of the discriminatory behavior discussed supra. 
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29. During the meeting, which took place on February 25, 2019, Ms. Rawls 

became upset at Ms. Leptich for bringing up Ms. Salerno’s discriminatory comments 

“again.”

30. Shockingly, Ms. Rawls also told Ms. Leptich, “what do you care, you’re not 

even African American.” 

31. The next day, February 26, 2019 - Ms. Leptich was terminated.

32. Plaintiff was terminated by Ms. Zucker.

33. No valid reason existed to terminate Plaintiff.

34. No valid reason was given to Plaintiff regarding her termination.

35. Only days before Plaintiff’s termination, HEI informed her that she would 

be retained by the new hotel operator.

36. Defendant’s actions demonstrate a pattern and practice of discrimination

based on race.

37. Defendant claimed it reprimanded Mr. Setless due to his racist comment but 

it actually transferred him due to a business need.

38. Shortly after Plaintiff’s termination by HEI, its contract to operate the Hotel 

ended.

39. However, Plaintiff’s co-workers at HEI maintained their employment with 

the new hotel operator, Benchmark Hospitality (“Benchmark”). 

40. Indeed, Benchmark did not simply terminate all of HEI’s staff when the 

contract ended.
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41. In fact, Benchmark honored all previous HEI employees’ start dates, 

accrued time off, and all other benefits.

42. Due to her termination, Plaintiff was never given the opportunity to 

continue working with Benchmark like her coworkers.

43. Moreover, HEI had many other job opportunities that could have transferred 

Plaintiff to or placed her in, but it did not allow her to avail herself to those due to the 

illegal termination

COUNT I

RACE DISCRIMINATION IN VIOLATION OF TITLE VII

44. Plaintiff realleges and adopts allegations contained in paragraphs 1-43, as if 

fully set forth in this Count.

45. Plaintiff is a member of a protected class because she is African American.

46. At all material times, Plaintiff was qualified to perform her job duties.

47. The acts of Defendant, by and through its agents and employees, violated 

Plaintiff’s rights against discrimination under Title VII because it treated Plaintiff less 

favorably because of her race.

48. Defendant ridiculed Plaintiff and called her derogatory terms based on her 

race.

49. Specifically, Defendant told Plaintiff that her “black lab bitch” dog was her 

meanest and needed to be separated from “white” dogs.

50. The comment in Paragraph 48 was made specifically towards Plaintiff and 

in anger over a business dispute.
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51. Other discriminatory comments about African-Americans were also made 

in Plaintiff’s presence such as referring to African-Americans as “hippos,” “gorillas,” and 

“one of them.”

52. Defendant did not subject the non-African American employees to similar 

treatment.

53. Plaintiff suffered an adverse employment action when she was terminated 

before the transition to Benchmark took place.

54. The discrimination to which Plaintiff was subjected was based on her race. 

55. Defendant does not have a legitimate, non-discriminatory reason for its 

firing of Plaintiff.

56. The conduct of Defendant and its agents and employees, proximately, 

directly, and foreseeably injured Plaintiff, including, but not limited to, lost wages and 

benefits, future pecuniary losses, emotional pain and suffering, humiliation, inconvenience, 

mental anguish, loss of enjoyment of life, and other non-pecuniary losses.

57. The conduct of Defendant was so willful and wanton, and in such reckless 

disregard of the statutory rights of the Plaintiff, as to entitle her to an award of punitive 

damages against Defendant, to deter Defendant, and others, from such conduct in the 

future.

58. Plaintiff is entitled to recover reasonable attorneys’ fees and litigation 

expenses pursuant to Title VII.

59. Plaintiff has no plain, adequate, or complete remedy at law for the actions 

of Defendant which have caused, and continue to cause, irreparable harm.
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REQUEST FOR RELIEF

60. WHEREFORE, Plaintiff, SANDRACHRISTINE LEPTICH, demands 

judgment against the Company and requests this Court award damages including:

61. Issue a declaratory judgment that the discrimination/harassment against 

Plaintiff by Defendant was a violation of Plaintiff’s rights under the Title VII;

62. Require that Defendant make Plaintiff whole for her losses suffered as a 

result of the discrimination through reinstatement, or, if that is not practical, through an 

award of front pay;

63. Grant Plaintiff a judgment against Defendant for damages, including 

punitive damages (when ultimately pled and approved by this Court);

64. Award Plaintiff her reasonable attorneys’ fees and litigation expenses 

against Defendant pursuant to Title VII; and

65. Provide any additional relief that this Court deems just.

COUNT II

RETALIATION IN VIOLATION OF TITLE VII

66. Plaintiff realleges and adopts allegations contained in paragraphs 1-43, as if 

fully set forth in this Count.

67. Plaintiff engaged in statutorily protected activity when she complained to 

Defendant that the racial slurs and derogatory terms and phrases being used at HEI were 

discriminatory.

68. Plaintiff’s most recent protected activity took place on January 22, 2019 and

then again on February 25, 2019.
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69. Plaintiff’s complaints were lodged to both HEI’s human resources 

department and to management.

70. Plaintiff’s protected activity was conducted both in writing and verbally.

71. HEI did not respond kindly to Plaintiff’s complaints about discrimination.

72. Specifically, HEI was mad that Plaintiff was complaining about 

discrimination “again.”

73. HEI also questioned why Plaintiff cared about discrimination.

74. The day after her final complaint about discrimination, February 26, 

2019 - Ms. Leptich was terminated.

75. Plaintiff suffered an adverse employment action when she was terminated.

76. A causal connection exists between the protected activity and the adverse 

actions against Plaintiff.

77. The acts of Defendant, by and through its agents and employees, violated 

Plaintiff’s rights against retaliation under Title VII because it treated Plaintiff less 

favorably because of her complaints of race discrimination.

78. Defendant does not have a legitimate, non-discriminatory reason for its 

firing of Plaintiff.

79. The conduct of Defendant and its agents and employees, proximately, 

directly, and foreseeably injured Plaintiff, including, but not limited to, lost wages and 

benefits, future pecuniary losses, emotional pain and suffering, humiliation, inconvenience, 

mental anguish, loss of enjoyment of life, and other non-pecuniary losses.
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80. The conduct of Defendant was so willful and wanton, and in such reckless 

disregard of the statutory rights of the Plaintiff, as to entitle her to an award of punitive 

damages against Defendant, to deter Defendant, and others, from such conduct in the 

future.

81. Plaintiff is entitled to recover reasonable attorneys’ fees and litigation 

expenses pursuant to Title VII.

82. Plaintiff has no plain, adequate, or complete remedy at law for the actions 

of Defendant which have caused, and continue to cause, irreparable harm.

REQUEST FOR RELIEF

WHEREFORE, Plaintiff, SANDRACHRISTINE LEPTICH, demands judgment 

against the Company and requests this Court award damages including:

83. Issue a declaratory judgment that the discrimination/harassment against 

Plaintiff by Defendant was a violation of Plaintiff’s rights under the “Title VII”;

84. Require that Defendant make Plaintiff whole for her losses suffered as a 

result of the discrimination through reinstatement, or, if that is not practical, through an 

award of front pay;

85. Grant Plaintiff a judgment against Defendant for damages, including 

punitive damages (when ultimately pled and approved by this Court);

86. Award Plaintiff her reasonable attorneys’ fees and litigation expenses 

against Defendant pursuant to “Title VII”; and 

87. Provide any additional relief that this Court deems just. 
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Dated this 18th day of February, 2020.

Respectfully submitted,

/s/ CARLOS LEACH

Carlos Leach, Esq.

FBN: 0540021

Trial Counsel for Plaintiff

The Leach Firm, P.A.

631 S. Orlando Ave., Suite 300

Winter Park, FL 32789

Telephone: (407) 574-4999

Facsimile: (833) 423-5864

Email: CLeach@theleachfirm.com