EXHIBIT A

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 1 of 13
9t17t2020 Madlson county OCRS

Billy \vashinglon, Clerk 0f the Circuit C0urt aild Compttollet n

N6w Seerch Expand All

c$6 Number Flld Datc ca8e Type stotu3 Jury T.lal

402020cA000029oMXMX

l62mmFc$MXl 05t1il2020 cficual Civil 3-D OPEN NO YES

Flllng oate De.crlptlon I

Acllve Conte.led Judgmenl D.tG

05t11no20 OTHER.DISCRIMINATION

EMPLOYIVENT/OTHER

YES NO

Pedy Type Bar lD P.fry Name

JUDGE

PLAINTIFF

DEFENDANT

MATTOX, MARIE A 739685

HEALTH PROFESSIONALS LLC

Sea&LI$s-Par!v

MHiil

OLIN, MELISSA GATES

BRocK, MICHELLE Searoh Thls PadY

lm{o Doc # Adlon Date t€scrlptlon Paga

I

I

05t1212020

o5t122020

o5t12t2020

o5t122020

o5t11t2020

05t11t2020

05t11D020

05t1lno20

o5t11n020

Active Proc€ss SUMIVONS

Judge: OLIN , MELlssA G Assignod

Payment receivod: $410.00 Recsipt Number MX 2020004571

Ass€ssmenl 1 Total Ass€ss€d S410.00 BElsnc6 Remaining S0 00

ISSUED SUMMONS

COMPUINT FOR DISCRIMINATION ACTION

CIVIL COVER SHEET

Ass€ssm€nl 1 asssss€d at sum $410,00

Case 402020cA000029cAAXlt4X Fil6d wilh Clerkon 5/112020

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J(dge A!slgnment Hl6tory IJ

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Flnanclal summary |J

Rep€n Hlltory

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Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 2 of 13
Filing # rcnn290 E-Filed 0511112020 09:45:45 PM

FORM 1-997. CIVIL COVER SHEET

The civit cover sheet and the information contained in it neither replace nor supplement the filing and service of

pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the

^Ctert 

oiCourt for the purpose of reporting data pursuant to section 25.075, Florida Statutes. (See instructions

for completion.)

CASE STYLE

IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT,

IN AND FOR MADISON COUNTY, FLORIDA

Case No.:_

Judge

MICHELLE BROCK

Plaintiff

vs.

TH PROFES MHM

Defendant

il AMOUNT OF CLAIM

Please indicate the estimated amount of the claim rounded to the nearest dollar $75.000

TypE OF CASE (lf the case fits more than one type of case, select the most definitive category.) lf the

most descriptive label is a subcategory (is indented under a broader category), place an x on both the main

category and subcategory lines.

ilt

f Condominium

n Contracts and indebtedness

fl Eminent domain

n Auto negligence

n Negligence - other

n Business governance

n Business torts

n Environmental/Toxictort

tl Third party indemnification

I Construction defect

n Mass tort

n Negligent securitY

! Nursing home negligence

n Premises liabilitY - commercial

n Premises liability - residential

n Products liability

n Real Property/Mortgage foreclosure

n Commercialforeclosure

n Homesteadresidentialforeclosure

n Non-homesteadresidentialforeclosure

I Other real property actions

[] Professional malpractice

n Malpractice - business

n Malpractice - medical

n Malpractice - other professional

X Other

! AntitrusVTradeRegulation

! Business Transaction

n Circuit Civil - Not ApPlicable

I Constitutionalchallenge-statuteorordinance

n Constitutionalchallenge-proposed amendment

n Corporate Trusts

X Discrimination-employmentorother

n lnsurance claims

n lntellectualproperty

n Libel/Slander

I Shareholder derivative action

tr Securitieslitigation

n Trade secrets

n Trust litigation

n County Civil

Small Claims up to $8,000

Civil

Replevins

Evictions

Other civil (non-monetary)

T

n

n

n

tr

Electronically Filed Madison Case # 2O200OOA29CAAXMX 0511112020 09:45:45 PM

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 3 of 13
COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the

Administrative Order. Yes X No X

REMEDIES SOUGHT (check allthat apply):

X Monetary;

X Non-monetary declaratory or injunctive relief;

X Punitive

NUMBER OF CAUSES OF AGTION:

(Specify)

I

IS THIS CASE A CLASS ACTION LAWSUIT?

tr Yes

XNo

VII. HAS NOTICE OF ANY KNOWN RELATED

XNo

n Yes - lf "yes" list all related

VIII. IS JURY TRIAL

X Yes

n

I CERTIFY that the information I h cover sheet is accurate to the best of my knowledge and belief, and

that I have read and will irements of Florida Rule of Judicial Administralion 2.425.

Signature: A

Attorney or party

FL Bar No,: 739685

(Bar number, if attorney)

Marie A Mattox

(Type or print name)

Date: 0511112020

IV

V.

vt.

number

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 4 of 13
]VflCHELLE BR0CK,

Plaintiff,

IN TIIE CIRCUIT COURT OT'TITE

THIRD JUDICI.AL CIRCTIIT, IN AND

FOR MADISON COUNTY, FLORIDA

CASE NO.: 20-CAFLA BAR NO.: 0739685

v

IVIIIM IIEALTTI PROFESSIONA,LS, LLC.

f/k/a MHIII HEALTH PROF'ESSIONALS: INC.,

I)efendant.

soMPL4lNr

Plaintiff, MICI'IELLE BROCK, hereby sues Defendant, TvfHM I{EALTH

PROFESSIONALS, LLC. tlW IMHM HEALTIi PROFESSIONALS, INC., and all eges:

NATIJRE OF LITE ACTION

l. This is an action brought uncler the Florida Civil Rights Act, cotlified at Chapter

760, Florida Statutes.

Z. This action involves claims which are, iudividually, in excess of Thirty Thousaurd

Dollars (S30,000.00), exclu$ive of costs and intercst.

TH.I.: PAR,TIES

3. At all times pertinent hercto, Plaintifl MICHELLE BROCK, has been a residcnt

of Ceorgia and employed by Defendant in Madison County, Florida, Plaintifl is a member of a

protscted class because of her race (African American) and because shc reported unlawful

employment practices and wa*c subject to retaliation thereafter.

4. Ar all tirnes perl,inent hereto, Defendant, MI{M ITEALTH PROFESSIONALS,

LLC. f/k/a MHM HEALTF{ PROFESSIONALS, INC., has been organized and existing unrler the

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 5 of 13
laws of Florida as a foreigr corporation conducting its regular businsss at various locations in

Florida inclucling irsplace of business in Madison Corurry where it employcd Plaintif.fl Atall times

pertinent to this acrion, f)efendant bas besn an "employef ' as that tcrm is used uuder the appl.icnble

larvs identified abuve. DeJ.Endant was PlaintifPs employer as it rclates to thcse olairns.

colfQlrtoNs PRECEqE$r

5. Plaintiffhas satisfied all conditions precedent to bringing this action in that

Plaintiff filed a charge of discrimination with the FLoridn Commission on tlurnan Relations and

Equal Employment Opportunity Commission. This action is tinrely tiled thercafter.

STaTEMENT pF THX ULTIMATE F$CTS

6. Plaintiff began her ernployment rvith Defendant on or about October 8, 2018, and

held the position of Mcntsl Health Professional at the time of her wrongful termination on April

12, 2019. Defendant is locared insi<le of the Madison Corectional Institution, and provides

mental health services to the all-male inmate population.

7. Plaintiff was subjected to frightening work condition.r. She repeatedly had to stop

mental health services anl have inrnates removed because they worild mastubate in front of her.

8. Despite her stellar rvork perfornrance drring her eml:loyment with Defendartt,

Plaintiffhas been subjected to disparate trsaEnent, different terms and conditjons of

ernployment, and was lrcld to a different standard because of her raco, and because she rcported

Deiendant's unlawful employmcnt activities aud was subjected to retaliation thereafter.

9, 1'be disparate treamenf and retaliation came at the hands of specifically but ttot

limited to I.T. Employee Paul Barrs and Regional Director Tamara Taylor.

z

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 6 of 13
I0. Jn t6e fall of 2018, Paul Bans, a white male employee of Defendant, pulled thc

Plainriffs name badge off olher chest, which was unwanted touching that made her

uncomfonable. However, becau$e she feured retatiation, she did not report the incident.

t l. On April 8, 2018, Barrs, who works in .Defendant's I.T. departmcnt, oame into thc

.plaintiffs offjce to inquire about a rnissing bluc computer cord. She did not knorv where the cord

was. and Bans became enraged, yelling and soreaming without cause, shocking Plaintiff'

12. Plaintiff irrsisred on being treated. respectfully likc the rcst of the employees.

Howevcr, Barrs stonne{ olf and threatened to take her computer while shorrting that he was

going to the Directcr.

13. Barr demanded tbat Regional Director Tamara Taylor lake some son of action

against plaintiff. Thereafter, Taylor approached Plaintiffand treated her as the instigator and did

not show any concern for her maltrestment by Bans.

14. Plaintif.f was told to calm down while she was trying to explain the situation and

rvari suspended for three days. White employees, including without limitation Dr. Katie Daly,

receive much fairer heatment when exhibiting similar behavior to Plaintiff'

I5' Tuylor told Plaintiff she was being suspended hecause she would not calm down'

although r.r'itnesses can corroborate that the Plaintiffwas not being unreasonable' Although Bans

irritiated the attack and cxhibited unprofessionalism in the workplace, he was ncver told to calm

down and was allowed to leave the scene while supervisors questioned Plaintifft6. Barrs was not suspended or telmfulated and was only made to take online

performance training as a result of his attack.

3

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 7 of 13
l?. Plaintiffhas ncver received a writfcn waming or reprimand duling her time of

cmploynrent,and has never been fired from another job. White employees rvere lreated more

fbvorably and therefore it can be infened that the diffsrential teatmsnt u.as due to ber nace.

18. While on this unwarranted suspension, on or about April I l, 2019, Plaintiff

notified Defenda.ot via email that tlrerc war; a pervasive workplace bias against mirtorities and

that she felt targeted when the Detbndant refi,rsed to hear and accept her description of tlte

incidenq while inrnrediately accepting thc white male cmployee's version of thc incidsnt.

19. On Apr:il 12,2019, one day after rcporting Deflendant's disparate treatment of

ruinorifies, she was terminated rl-ith no written explanation. Defendant told Plaintiff she was

bcing terminated for unprofossionalism dcspite rvhitc employecs receiving progrossive discipline

for their similar or urorre unprofessional behavior.

20, One such former ernployee, Michetle Fortier, was acctrsed of unprofessionalism

several times but rvas given multiplc chrnces and *.arnings over her eight (8)-year ernployment.

Another wbite cmployee, Dr. Katic Daly, rvas absent eight (8) times in her first ni.neiy (90) days.

and screamed at a discharge re-entry manager right in front of supervisors. Daly was given

multiple warnings and chanccs for her unprof'e$sionalism, unlike the Plaintiff.

2L Plaintiffhas retained the undemignsd to reprcsent her interests i.n this cause and is

obU*qatod to pay a fee for these seruices. Defcndant should be made to pay said fee under the

laws referenced abovc.

COUNI'I

RqcE DISCRTMIiVATION

22. Paragraphs I through 2l are re-alleged and incorporated herein by reference.

23. This is iln action against Defendant for discrimination based upon mce brought

under Chapter 760, Florida Statutes.

4

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 8 of 13
24. Plaintiffhas been the victim of discrimination on the basis of P'laintiffs race in that

plaintiff was h.eated differently than similarly sinrated cmployees ol'Defendants who are white

and has been subject to disparate rcatment, at least in pan, of Plaintiflls race'

25. Dcfbndant is liable for tfic diflbrential teatrnent and hostility towards Plaintiff

because it controlled the actions arul inactious of the persons making decisions af.Tectilg Plaintiff

or it knew or slroutd have known of thcse actions and inactiotm and failed to take prompt ard

adequate romedial acti<ln or took no action at all to pt'event the abuses to Plaintiff' Fwthcnnorc,

Defen4ant lcrowingly condoned and ratilled the differential treatmcnt ol'Plaintitf as mort' fully set

fbrth above because it allowed the differential treatment and participatd in sa$e.

26. Defendant's known allowance and ratification of t}ese actions and inactions acl'ions

cre&ted, perpetuatcd and facilitated an abrsive and offensive work envirorunent within the meaning

ofthe statutes referenced above,

27, [n essence, the actions of agonts of Detbndant, which were each condoned and

ratified by Defendant, welr of a race-based nature and in violatiou of Lhe las's set forth herein.

28. The cliscrimination complained of herein alfected a teffn, condition, or privilege of

pla.intifTs continued ernploynrent with Defendant. The events sct fcrrth herein lead, at least in part,

to.Plaintiffs suspension and tennination on conbived allegations.

29. Defendaut's conduct and omissions consfihrtcs intentional discrim.ination and

unlarvful cmployment practices based upon race in violation of Chapter 760, Florida Statutes.

30. As a direct aad proximate result of Defendont's conduct described above, Plaintiff

has suftbred ernorional dishess, mental pain a.nd suffering, past and future pecuniary lo$ses,

inconvenicnce, bodily injury, nrental anguish,loss of enjoyment of life and other non-pecuniary

losses, along with lost back and front pay, interest on pay, bonusas, and other benefits. Tlrese

5

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 9 of 13
damages have occurred in thc past, are perrnanent and continuing. Plaintiff is cntitled to

injuncti ve/equi tab le relic I' and puni tivc d amages.

COUNT TI

RETALIATION :,Shauter 760

31. Paragraphs I through 2l are re-alleged and incorporatcd herein by refilrence.

32. Defendant is au employer as that tcrm is used under the ap,plicable statuEs

referenced above..

33. The foregoing allegations cstablish a oause of action for unlan'fi.il rctaliation afier

PlaintitT reported or opposed unlawi:ul employnrent practices adversely affecting her under

Chapter 760, Florida Statutes, and other statutory provisions cited hercin.

34. The foregoing unlawful actions by Defetrdant rvere purposeful.

35. Plaintiff r.oiced opposition to unlawlul employment practices during her

cmployment witb Defendant and lvas the victim of rctaliation thereafter, as rclate<l in part above.

36. Plaintiff is a member of a protected class because she reported rurlawful

employment practices and was the victim of retaliation thereaftsr. There is thus a causal

conncction bcnveen the reporting of the unlawful employment practiccs an<l the adverse

employment act i on taken thereafter.

37. As a direct and proximate re.sult of the foregoing unlawful ncts and omissions,

Plaiutiff has suffered meutal nnguish, emotiona.l distress, expen$e, Ioss of benetits, embarras$ment,

hurniliation, damage to rcputation, ilbess, lost wages, los.s of capacity for the enjoyruent of life,

and other tangible and intangible damages. These damages are continuing and are peffiianent.

Plaintiffis cntitled to ptrnitive damagcs and to injunctive relicf.

PRAYSIB 8pR Rpl,tqr

WHEREFORE, Plaintiff demands judgrnent against l)efendant for tbe following:

6

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 10 of 13
(a) that process issue and this Court take jurisdicfion ovet'this case;

(b) that rhis Court grunt equitable relief against Defendant under the appliOable

counts $et forth above, mandating Defbndant's obedience to the laws

cnpmerated herein and providing other equitable relief to Plaintiff;

(c) enter judgment against Defendant and for Plaintiff awarding all legallyavailable general and compensatory damages and econornic loss to Plaintiff

from Defendant lbr Defendant's violations of law enumerated hercin;

(d) enter judgment against Defendant and for Plaintiff permanently enjoining

Defbndant from future violations of law enumerated herein;

(e) cnrer judgmcnt against Defcndant and for Plaintifi' awarding Plaintiff

attonrey's fees and costs;

(0 arvard Plaintiffintercst where appropriate; and

(g) grant such other firrther relief as being just and proper under the

circumstances, including but not timited to reinstaternent.

DEMAND rE)R TRTAL. BY JURY

PlaintifThereby dernands a trial by.ir,ry on all issue.s herein lhat are so triableDATED this I l'h day of May 2020.

7

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 11 of 13
Respectfu[y subnrittod,

/s/ Mq4e A. Muttot

Marie.A. Mattox IFBN 0i39685]

MARTE A. MATTOX, P,A.

203 North Gadsden Sheet

Tallabassee, FL 32301

Telephone: (850) 3834800

Facsinaile: (850) 383-4801

lvta,rie@m altox lavi'.co m

Secondary emails:

mar I enp(F;nragpxl aw. qgm

rn i c hel le@mattoxlaw.com

ATTORN EYS FOR, PLAINTI FF

I

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 12 of 13
filine ll107333290 E-Filed 05/nn020 09:45:45 PM

MICHELIJ BROCI(,

Plafutiff,

v.

MHM HEALTE PROT'ESSIONALS, LLC.

f/k/a MHM f,EALTU PROX'ESSIONALS, INC.,

Defcndrnt

INTffi CIRCTJI]T COURT OF TEE

THIRD JTIDICIAL CXRCUIT, IN A]TD

FOR MADISoN COUNTY, tr'LORTIIA

CA,SE NO.: 20.CA - 2q

Ff"A BAR N0.: 0739685

SUMMONS

TTM STATE OF FLORIDA:

To Each Sheriffof the Sate:

YOU ARB COMMANDED to sorve this summons and a copy of the complaint or

petition in this aodon on Defendant:

TVffilT EEALTE PROFESSIONALS, LLC

C/O C T CORPORATION SYSTEM - REGISTEREI} AGENT

I2OO SOUTH PII\IE ISLAND ROAI)

PLAT{TATION, SI,33324

Each dcfendant is required to serve writbn defenses to thc complaint or petition on

lVlarie A, Mattox, P. A., PlaintifFs attomey, whose address is 203 North Gadsden Street,

Tallahassee, FL 32501, within 20 days after service of this sunmons on ftat defendarrt,

exclusive of the day of service, and to file the original ofthe defenses with the clerk of this court,

either before serrue on plaintiffs attomey or immediately thereafter. If a defcndant fails to do

so, a default wilt he entered against that defendant fbr the relief demanded in the complaint or

pctition.

DATED on 2020,

CLERK OF THE CIRCUIT COURT

t1- -1

By u +^J

Case 4:20-cv-00455-RH-MAF Document 1-1 Filed 09/17/20 Page 13 of 13