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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF FLORIDA

PENSACOLA DIVISION

DELORES A. CAMPBELL

PLAINTIFF,

v. CIVIL ACTION NO.: 

FL HUD BAYBREEZE LLC.

DEFENDANT.

__________________________/

COMPLAINT

Plaintiff, DELORES A. CAMPBELL, (hereinafter referred to as the 

“Plaintiff” or “Campbell”), by and through her undersigned attorney, sues the 

defendant, FL HUD BAYBREEZE. (hereinafter referred to as the “Defendant” or 

“Baybreeze”), alleges as follows:

JURISDICTION AND VENUE

1. This is an action to remedy discrimination on the basis of disability, 

age, and retaliation in the terms, conditions, and privileges of Plaintiff’s 

employment in violation of the Americans with Disabilities Act, (ADA), 42 U.S.C. 

§§ 12111-12117, 12203; the Americans with Disabilities Act Amendments of 2008 

(ADAA), the Florida Civil Rights Act of 1992, as amended, Chapter 760 et seq., 

Florida Statutes; Age Discrimination in Employment Act of 1967 (ADEA), 29 

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U.S.C. § 262 et seq.; and Florida's Workers' Compensation Retaliation Law § 

440.205, Florida Statutes. 

2. Jurisdiction is invoked pursuant to 28 U.S.C. § 1331 and 42 U.S.C. 

§2000e-5(f).

3. Declaratory, injunctive, and equitable relief is sought pursuant to 28 

U. S. C. §§ 2201, 2202 and 42 U.S.C. § 2000e-5(g). 

4. Costs and attorney’s fees are sought pursuant to 42 U.S.C. §2000e5(k), Fed. R. Civ. P. 54 and other Florida Statutes as set forth herein.

5. This action lies in the Northern District of Florida, Pensacola 

Division, pursuant to 29 U.S.C. § 1391(b), because the action arose in this judicial 

district, and pursuant to 42 U.S.C. § 2000e-5(f)(3), because the unlawful 

employment practices were committed in this judicial district. 

6. Plaintiff has complied with all conditions precedent and 

administrative remedies have been exhausted and jurisdiction is invoked pursuant 

to 28 U.S.C. § 1331 and 42 U.S.C. § 2000e-5(f) and the Florida Civil Rights Act of 

1992, as amended, Chapter 760 et seq., Florida Statutes. Plaintiff dual filed a 

Charge of Discrimination with the Florida Commission on Human Relations 

(“FCHR” No.: 202021842) and the United States Equal Employment Opportunity 

Commission (“EEOC” No.: 15D202000208) on October 3, 2019. On April 23, 

2020, more than 180 days since Plaintiff’s charge was filed, the FCHR had not 

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concluded its investigation or made a determination pursuant to Fla. Stat. § 

760.11(3). Plaintiff thereafter requested her 90 day Notice of Right to Sue letter 

from the EEOC which was received on August 21, 2020. 

PARTIES

7. Plaintiff is a Caucasian female and a citizen of the State of Florida, 

Santa Rosa County and who resides in Gulf Breeze, Florida. She was employed by

Defendant from October 1992, until September 6, 2019. 

8. Defendant, FL HUD Baybreeze, LLC. (“Baybreeze”), is an assisted 

living and adult day care facility located in Gulf Breeze, Florida. 

9. Defendant is an employer within the meaning of the ADA, ADAA, 

ADEA, and the Florida Civil Rights Act as it employs in excess of twenty (20) 

employees. 

FACTS

10. Plaintiff is a sixty-five (65) year old Caucasian female.

11. Plaintiff was employed by Defendant, FL HUD Baybreeze, LLC.

(“Baybreeze”), at its’ assisted living and adult day care facility located in Gulf 

Breeze, Florida.

12. Defendant is an employer within the meaning of the ADA, ADAA, 

ADEA, and the Florida Civil Rights Act as it employs in excess of twenty (20) 

employees.

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13. Plaintiff began her employment with Defendant, on or about October 

15, 1992. 

14. Throughout the course of Plaintiff’s employment, she held positions 

of a Certified Nurse’s Assistant (“CNA”) and Restorative CNA.

15. During Plaintiff’s employment with Defendant, she performed the 

duties and responsibilities of her position in an exceptional manner and was not 

subject of any disciplinary issues prior to her termination. 

16. On March 1, 2019, during non-work hours, Plaintiff broke her arm 

and was went out on Family and Medical Leave Act (“FMLA”) leave. 

17. On June 5, 2019, Plaintiff returned to work. 

18. On June 7th, 2020, two days after returning from FMLA leave due to a 

broken arm, Plaintiff suffered an on the job injury to her back. 

19. Plaintiff notified Defendant of the workplace injury and indicated that 

she was in severe pain. 

20. Plaintiff sought medical treatment and was diagnosed with Lumbar 

Radiculopathy.

21. On July 18, 2019, Defendant’s workers compensation carrier denied 

Plaintiff’s workers’ compensation claim. 

22. On or about August 2, 2019, Plaintiff’s treating physician instructed 

that she could return to work with restrictions of light duty. 

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23. At the time of Plaintiff’s injury she was performing the duties of a 

Restorative CNA. 

24. Upon being notified of Plaintiff’s restrictions, Defendant denied 

Plaintiff the ability to return to work light or restricted duty. 

25. Prior to Plaintiff’s request for accommodation, Defendant 

accommodated younger employees with similar job duties and restrictions with 

light duty employment. 

26. Plaintiff had the ability to perform the essential functions of her position

with or without a reasonable accommodation.

27. Defendant had knowledge of Plaintiff’s physical disability, back injury 

when she informed Defendant of her disability on or before June 7, 2019.

A. Defendant was aware of Plaintiff’s disability.

B. Plaintiff is a qualified individual with a disability:

(i) she had a physical impairment that substantially limited

one or more major life activities: Plaintiff suffered from 

mobility, bending, lifting and fatigue;

(ii) Plaintiff was under the treatment of a doctor for the care 

and treatment of her physical disabilities. 

(iii) she has a record of such impairment; and,

(iv) she was regarded (perceived or otherwise) by Defendant 

as having such impairments.

28. Plaintiff’s disabilities substantially affected the major life activities of 

concentration, mobility, lifting and bending. 

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29. Plaintiff had the ability to perform the essential functions of her

position as a Restorative CNA and could have done so with or without an 

accommodation had Defendant allowed her to return to her position as a 

Restorative CNA. 

30. However, on September 6, 2019, Defendant terminated Plaintiff’s 

employment just a few weeks after it denied her workers’ compensation claim and 

after its refusal to reasonably accommodate Plaintiff with light duty as it has in 

similar instances with other employees.

FIRST CAUSE OF ACTION

(DISABILITY DISCRIMINATION - AMERICANS WITH DISABILITIES ACT, (ADA), AND 

AMERICANS WITH DISABILITIES ACT AMENDMENTS (ADAA))

31. Plaintiff repeats and re-alleges each and every allegation contained in 

paragraph 1 through 30 of this complaint with the same force and effect as if set 

forth herein.

32. This is an action to remedy discrimination on the basis of Plaintiff’s 

disability, perceived or otherwise, in the terms, conditions, and privileges of his 

employment with Defendant in violation of the Americans with Disabilities Act, 

(ADA), 42 U.S.C. §§ 12111-12117, 12203; the Americans with Disabilities Act 

Amendments of 2008.

33. At all times material hereto, Plaintiff was an employee of 

Defendant within the meaning of Americans with Disabilities Act, (ADA), 42 

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U.S.C. §§ 12111-12117, 12203; the Americans with Disabilities Act Amendments 

of 2008.

34. At all times material hereto, Defendant was an employer within the 

meaning of Americans with Disabilities Act, (ADA), 42 U.S.C. §§ 12111-12117, 

12203; the Americans with Disabilities Act Amendments of 2008, as the 

Defendant employed more than 15 employees. 

35. Any possible assertion that there was a viable business justification 

for the Plaintiff’s termination, is entirely pretextual for Defendant’s retaliation and 

discrimination against her for engaging in a protective activity and for any actual 

or perceived disability. 

36. The adverse personnel action, the termination of Plaintiff’s 

employment, clearly violated Plaintiff’s right under the Americans with 

Disabilities Act, (ADA), 42 U.S.C. §§ 12111-12117, 12203; the Americans with 

Disabilities Act Amendments of 2008, and such action clearly constituted a 

prohibited employment practice, contrary to the public policy of the ADAA.

37. As a result of the Defendant’s violations of the Americans with 

Disabilities Act and Amendments, the Plaintiff has been substantially damaged, in 

that she has lost wages, associated job benefits; and in addition, she has sustained 

compensatory damages, based upon emotional distress, associated with the 

wrongful, unlawful and retaliatory discharge from Defendant’s employment. 

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38. As a result of the wrongful and unlawful retaliatory actions that 

lead to her discharge from Defendant’s employment, Plaintiff has been 

experiencing anxiety and difficult economic circumstances, resulting from the 

unlawful discharge; and the Plaintiff has also sustained continued mental and 

psychological distress, due to the unlawful dismissal from employment.

39. Plaintiff has retained the undersigned attorney to assist her, in the 

prosecution of this action, and she is obligated to pay said attorney a reasonable fee 

for his professional services. 

40. Plaintiff is entitled to recovery of reasonable attorney’s fees and

costs pursuant to Americans with Disabilities Act, (ADA), 42 U.S.C. §§ 12111-

12117, 12203; the Americans with Disabilities Act Amendments of 2008.

SECOND CAUSE OF ACTION

(DISABILITY RETALIATION - AMERICANS WITH DISABILITIES ACT, (ADA), 42 U.S.C. §§

12111-12117, 12203; THE AMERICANS WITH DISABILITIES ACT AMENDMENTS OF 2008

(ADAA))

41. Plaintiff repeats and re-alleges each and every allegation contained 

in paragraph 1 through 30 of this complaint with the same force and effect as if set 

forth herein.

42. This is an action to remedy discrimination on the basis of Plaintiff’s 

disability, perceived or otherwise, in the terms, conditions, and privileges of her 

employment with Defendant in violation of the Americans with Disabilities Act, 

(ADA), 42 U.S.C. §§ 12111-12117, 12203; the Americans with Disabilities Act 

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Amendments of 2008.

43. At all times material hereto, Plaintiff was an employee of 

Defendant within the meaning of Americans with Disabilities Act, (ADA), 42 

U.S.C. §§ 12111-12117, 12203; the Americans with Disabilities Act Amendments 

of 2008.

44. At all times material hereto, Defendant was an employer within the 

meaning of Americans with Disabilities Act, (ADA), 42 U.S.C. §§ 12111-12117, 

12203; the Americans with Disabilities Act Amendments of 2008, as the 

Defendant employed more than 15 employees. 

45. Any possible assertion that there was a viable business justification 

for the Plaintiff’s termination, is entirely pretextual for Defendant’s retaliation and 

discrimination against her for engaging in a protective activity and for any actual 

or perceived disability. 

46. The adverse personnel action, the termination of Plaintiff’s 

employment, clearly violated Plaintiff’s right under the Americans with 

Disabilities Act, (ADA), 42 U.S.C. §§ 12111-12117, 12203; the Americans with 

Disabilities Act Amendments of 2008, and such action clearly constituted a 

prohibited employment practice, contrary to the public policy of the ADAA.

47. As a result of the Defendant’s violations of the Americans with 

Disabilities Act and Amendments, the Plaintiff has been substantially damaged, in 

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that she has lost wages, associated job benefits; and in addition, she has sustained 

compensatory damages, based upon emotional distress, associated with the 

wrongful, unlawful and retaliatory demotion that lead to her discharge from 

Defendant’s employment. 

48. As a result of the wrongful and unlawful retaliatory actions that 

lead to her discharge from Defendant’s employment, Plaintiff has been 

experiencing anxiety and difficult economic circumstances, resulting from the 

unlawful discharge; and the Plaintiff has also sustained continued mental and 

psychological distress, due to the unlawful dismissal from employment.

49. Plaintiff has retained the undersigned attorney to assist her, in the 

prosecution of this action, and she is obligated to pay said attorney a reasonable fee 

for his professional services. 

50. Plaintiff is entitled to recovery of reasonable attorney’s fees and

costs pursuant to Americans with Disabilities Act, (ADA), 42 U.S.C. §§ 12111-

12117, 12203; the Americans with Disabilities Act Amendments of 2008.

THIRD CAUSE OF ACTION

(DISABILITY DISCRIMINATION - FLORIDA CIVIL RIGHTS ACT OF 1992, AS AMENDED,

CHAPTER 760 ET SEQ., FLORIDA STATUTES)

51. Plaintiff repeats and re-alleges each and every allegation 

contained in paragraph 1 through 30 of this complaint with the same force and 

effect as if set forth herein.

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52. Defendant discriminated against Plaintiff on the basis of her

disability, perceived or otherwise, in the terms, conditions, and privileges of 

Plaintiff’s denied employment in violation of the Florida Civil Rights Act of 1992, 

as amended, Chapter 760 et seq., Florida Statutes. 

53. At all times material hereto, Plaintiff was an employee of 

Defendant within the meaning of Florida Civil Rights Act of 1992, as amended, 

Chapter 760 et seq., Florida Statutes.

54. At all times material hereto, Defendant was an employer within 

the meaning of Florida Civil Rights Act of 1992, as amended, Chapter 760 et seq., 

Florida Statutes, as the Defendant employed more than 15 employees. 

55. Any possible assertion that there was a viable business 

justification for the Plaintiff’s termination, is entirely pretextual for Defendant’s 

retaliation and discrimination against her for engaging in a protective activity and 

for any actual or perceived disability. 

56. The adverse personnel action, the termination of Plaintiff’s 

employment, clearly violated Plaintiff’s right under the Florida Civil Rights Act of 

1992, as amended, Chapter 760 et seq., Florida Statutes. 

57. As a result of the Defendant’s violations of the Americans with 

Disabilities Act and Amendments, the Plaintiff has been substantially damaged, in 

that she has lost wages, associated job benefits; and in addition, she has sustained 

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compensatory damages, based upon emotional distress, associated with the 

wrongful, unlawful and discriminatory termination that lead to her discharge from 

Defendant’s employment. 

58. As a result of Defendant’s wrongful and unlawful discriminatory 

acts against Plaintiff that lead to her discharge from Defendant’s employment, 

Plaintiff has been experiencing anxiety and difficult economic circumstances, 

resulting from the unlawful discharge; and the Plaintiff has also sustained 

continued mental and psychological distress, due to the unlawful dismissal from 

employment.

59. Plaintiff has retained the undersigned attorney to assist her, in the 

prosecution of this action, and she is obligated to pay said attorney a reasonable fee 

for his professional services. 

60. Plaintiff is entitled to recovery of reasonable attorney’s fees and

costs pursuant to Florida Civil Rights Act of 1992, as amended, Chapter 760 et 

seq., Florida Statutes.

FOURTH CAUSE OF ACTION

(DISABILITY RETALIATION - FLORIDA CIVIL RIGHTS ACT OF 1992, AS AMENDED,

CHAPTER 760 ET SEQ., FLORIDA STATUTES)

61. Plaintiff repeats and re-alleges each and every allegation 

contained in paragraph 1 through 30 of this complaint with the same force and 

effect as if set forth herein.

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62. This is an action to remedy retaliation by the Defendant in 

violation of the Florida Civil Rights Act of 1992, as amended, Chapter 760 et seq., 

Florida Statutes.

63. At all times material hereto, Plaintiff was an employee of 

Defendant within the meaning of Florida Civil Rights Act of 1992, as amended, 

Chapter 760 et seq., Florida Statutes.

64. At all times material hereto, Defendant was an employer within 

the meaning of Florida Civil Rights Act of 1992, as amended, Chapter 760 et seq., 

Florida Statutes, as the Defendant employed more than 15 employees. 

65. Any possible assertion that there was a viable business justification 

for the Plaintiff’s termination, is entirely pretextual for Defendant’s retaliation 

against her for engaging in a protective activity and for any actual or perceived 

disability. 

66. The adverse personnel action, the termination of Plaintiff’s 

employment, clearly violated Plaintiff’s right under the Florida Civil Rights Act of 

1992, as amended, Chapter 760 et seq., Florida Statutes, and such action clearly 

constituted a prohibited employment practice, contrary to the public policy of the 

ADAA.

67. As a result of the Defendant’s violations of the Americans with 

Disabilities Act and Amendments, the Plaintiff has been substantially damaged, in 

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that she has lost wages, associated job benefits; and in addition, she has sustained 

compensatory damages, based upon emotional distress, associated with the 

wrongful, unlawful and retaliatory demotion that lead to her discharge from 

Defendant’s employment. 

68. As a result of the Defendant’s wrongful and unlawful retaliatory 

actions that lead to her discharge from Defendant’s employment, Plaintiff has been 

experiencing anxiety and difficult economic circumstances, resulting from the 

unlawful discharge; and the Plaintiff has also sustained continued mental and 

psychological distress, due to the unlawful dismissal from employment.

69. Plaintiff has retained the undersigned attorney to assist her, in the 

prosecution of this action, and she is obligated to pay said attorney a reasonable fee 

for his professional services. 

70. Plaintiff is entitled to recovery of reasonable attorney’s fees and

costs pursuant to Florida Civil Rights Act of 1992, as amended, Chapter 760 et 

seq., Florida Statutes.

FIFTH CAUSE OF ACTION

(FLORIDA'S WORKERS' COMPENSATION RETALIATION § 440.205)

71. Plaintiff repeats and re-alleges each and every allegation contained in 

paragraph 1 through 30 of this complaint with the same force and effect as if set 

forth herein.

72. Defendant’s conduct and commissions constitutes intentional 

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discrimination and unlawful employment practices based upon Workers’ 

Compensation Law. FLA. STAT. § 440.205. 

73. Defendant’s acts were with malice and with reckless disregard for 

Plaintiff’s statutorily protected rights.

74. This is an action to remedy discrimination and retaliation on the basis 

of Plaintiff’s engaging in protective activity of informing Defendant of a work 

related injury and seeking workers compensation benefits in the terms, conditions, 

and privileges of her employment with Defendant in violation of the Workers’ 

Compensation Law. FLA. STAT. § 440.205.

75. Any possible assertion that there was a viable business justification 

for the Plaintiff’s termination, is entirely pretextual for Defendant’s retaliation and 

discrimination against her for engaging in a protective activity. 

76. The adverse personnel action, Plaintiff’s termination, clearly violated 

Plaintiff’s right under the Workers’ Compensation Law. FLA. STAT. § 440.205

and such action clearly constituted a prohibited employment practice, contrary to 

the public policy of the State of Florida.

77. As a result of the Defendant’s violations of the Workers’ 

Compensation Law. FLA. STAT. § 440.205, the Plaintiff has been substantially 

damaged, in that she has lost wages, associated job benefits; and in addition, she 

has sustained compensatory damages, based upon emotional distress, associated 

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with the wrongful, unlawful and retaliatory demotion that lead to her discharge 

from Defendant’s employment. 

78. As a result of the wrongful and unlawful retaliatory actions that lead 

to her discharge from Defendant’s employment, Plaintiff has been experiencing 

anxiety and difficult economic circumstances, resulting from the unlawful 

discharge; and the Plaintiff has also sustained continued mental and psychological 

distress, due to the unlawful dismissal from employment.

SIXTH CAUSE OF ACTION

(AGE DISCRIMINATION – FCHR)

79. Plaintiff repeats and re-alleges each and every allegation contained in 

paragraph 1 through 30 of this complaint with the same force and effect as if set 

forth herein.

80. This is an action to remedy discrimination on the basis of Plaintiff’s 

age in the terms, conditions, and privileges of her employment with Defendant in 

violation of the Florida Civil Rights Act of 1992, as amended, Chapter 760 et seq., 

Florida Statutes.

81. At all times material hereto, Plaintiff was an employee of Defendant 

within the meaning of the Florida Civil Rights Act of 1992, as amended, Chapter 

760 et seq., Florida Statutes.

82. At all times material hereto, Defendant was an employer within the 

meaning of national origin in violation of the Florida Civil Rights Act of 1992, as 

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amended, Chapter 760 et seq., Florida Statutes, as the Defendant employed more 

than 20 employees.

83. Plaintiff is a 64 year old Caucasian female.

84. Plaintiff is a highly qualified CNA with more than 20+ years of 

experience.

85. While employed with Defendant, Plaintiff performed the duties and 

responsibilities of her position in a more than satisfactory manner. 

86. Any possible assertion that there was a viable business justification 

for the Plaintiff’s termination, is entirely pretextual for Defendant’s 

discrimination against her for engaging in a protective activity. 

87. The adverse personnel action, the termination of Plaintiff’s 

employment clearly violated Plaintiff’s right under the Florida Civil Rights Act 

of 1992, as amended, Chapter 760 et seq., Florida Statutes. 

88. As a result of the Defendant’s violations of the Florida Civil Rights 

Act of 1992, as amended, Chapter 760 et seq., Florida Statutes, the Plaintiff has 

been substantially damaged, in that he has lost wages, associated job benefits; 

and in addition, he has sustained compensatory damages, based upon emotional 

distress, associated with the wrongful, unlawful and discriminatory termination

that lead to his discharge from Defendant’s employment. 

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89. As a result of Defendant’s wrongful and unlawful discriminatory 

actions against Plaintiff that lead to her discharge from Defendant’s employment, 

Plaintiff has been experiencing anxiety and difficult economic circumstances, 

resulting from the unlawful discharge; and the Plaintiff has also sustained 

continued mental and psychological distress, due to the unlawful dismissal from 

employment.

90. Plaintiff has retained the undersigned attorney to assist her, in the 

prosecution of this action, and she is obligated to pay said attorney a reasonable 

fee for his professional services. 

91. Plaintiff is entitled to recovery of reasonable attorney’s fees and costs 

pursuant to the Florida Civil Rights Act of 1992, as amended, Chapter 760 et 

seq., Florida Statutes.

SEVENTH CAUSE OF ACTION

(AGE DISCRIMINATION - ADEAA)

92. Plaintiff repeats and re-alleges each and every allegation contained in 

paragraph 1 through 30 of this complaint with the same force and effect as if set 

forth herein.

93. This is an action to remedy retaliation by the Defendant in violation of 

the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. § 262 et

seq., and Amendments (ADEAA).

94. At all times material hereto, Plaintiff was an employee of Defendant 

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within the meaning of the Age Discrimination in Employment Act of 1967 

(ADEA), 29 U.S.C. § 262 et seq., and Amendments (ADEAA).

95. At all times material hereto, Defendant was an employer within the 

meaning of the Age Discrimination in Employment Act of 1967 (ADEA), 29 

U.S.C. § 262 et seq., and Amendments (ADEAA), as the Defendant employed 

more than 20 employees. 

96. Plaintiff is a 64 year old Caucasian female.

 97. Plaintiff is a highly CNA with more than 20+ years of experience.

 98. While employed with Defendant, Plaintiff performed the duties and 

responsibilities of her position in a more than satisfactory manner. 

99. Any possible assertion that there was a viable business justification 

for the Plaintiff’s termination is entirely pretextual for Defendant’s retaliation 

against her for engaging in a protective activity. 

100. The adverse personnel action, the termination of Plaintiff’s 

employment, clearly violated Plaintiff’s right under the Age Discrimination in 

Employment Act of 1967 (ADEA), 29 U.S.C. § 262 et seq., and Amendments 

(ADEAA), and such action clearly constituted a prohibited employment practice, 

contrary to the public policy of the FCRA.

101. As a result of the Defendant’s violations of the Age Discrimination in 

Employment Act of 1967 (ADEA), 29 U.S.C. § 262 et seq., and Amendments 

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(ADEAA), the Plaintiff has been substantially damaged, in that she has lost 

wages, associated job benefits; and in addition, she has sustained compensatory 

damages, based upon emotional distress, associated with the wrongful, unlawful 

and retaliatory demotion that lead to her discharge from Defendant’s 

employment. 

102. As a result of Defendant’s wrongful and unlawful retaliatory 

actions that lead to her discharge from Defendant’s employment, Plaintiff has 

been experiencing anxiety and difficult economic circumstances, resulting from 

the unlawful discharge; and the Plaintiff has also sustained continued mental and 

psychological distress, due to the unlawful dismissal from employment.

103. Plaintiff has retained the undersigned attorney to assist her, in the 

prosecution of this action, and she is obligated to pay said attorney a reasonable 

fee for his professional services. 

104. Plaintiff is entitled to recovery of reasonable attorney’s fees and costs 

pursuant to the Age Discrimination in Employment Act of 1967 (ADEA), 29 

U.S.C. § 262 et seq., and Amendments (ADEAA).

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests this Court to enter a 

judgment: 

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a. Declaring the acts and practices complained of herein are violation of 

the ADAA, Florida Civil Rights Act (FCRA), Florida’s Worker’s Compensation 

Retaliation § 440.205, Florida Statue, and the ADEA.

b. Enjoining and permanently restraining those violations of the ADAA, 

Florida Civil Rights Act (FCRA), the Florida’s Worker’s Compensation 

Retaliation § 440.205 Florida Statue, and the ADEA.

c. Directing the Defendant to take such affirmative action as is necessary 

to ensure that the effects of these unlawful employment practice are eliminated and 

do not continue to affect Plaintiff’s employment opportunities;

d. Directing Defendant to place Plaintiff in the position she would have 

occupied but for Defendant’s discriminatory treatment of her and make her whole 

for all earnings she would have received but for Defendant’s discriminatory 

treatment, including but not limited to, wages (past and future), pension, and other 

lost benefits.

i. Awarding Plaintiff Front Pay in lieu of reinstatement;

ii. Awarding Plaintiff compensatory damages;

iii. Awarding Plaintiff liquidated damages; 

iv. Awarding Plaintiff the costs of this action together with a 

reasonable attorney’s fees; and,

e. Granting such other and further relief as the Court deems just and 

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proper in the premises. 

DEMAND FOR JURY TRIAL

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, 

Plaintiff demands a trial by jury in this action. 

Respectfully submitted,

Dated: October 28, 2020. By: /s/ Clayton M. Connors 

CLAYTON M. CONNORS 

Florida Bar No.: 0095553

Email: cmc@westconlaw.com

WESTBERRY & CONNORS, LLC.

4400 Bayou Blvd., Suite 32A

Pensacola, Florida 32503

Tel: (850) 473-0401

Fax: (850) 473-1388

Attorney for the Plaintiff

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