IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF FLORIDA

PENSACOLA DIVISION

ZOE ROSE HAFT,

Plaintiff,

v. CASE NO.: ___________________

AKC3, LLC, d/b/a STAY THE SPA;

CAMERON SMITH; and 

JENNIFER WALDEN-SMITH,

Defendants.

__________________________________/

COMPLAINT

COMES NOW, the Plaintiff, ZOE ROSE HAFT (hereinafter referred to as 

“Plaintiff”), by and through the undersigned counsel, and sues AKC3, LLC d/b/a 

STAY THE SPA (“Stay the Spa”); CAMERON SMITH (“Mr. Smith”), and 

JENNIFER WALDON-SMITH (“Mrs. Smith”; hereinafter Stay the Spa, Mr. Smith 

and Mrs. Smith shall individually, interchangeably, and/or collectively be referred 

to as "Defendants"), and alleges:

JURISDICTION AND VENUE 

1. This Court has subject matter jurisdiction over this action pursuant to 

29 U.S.C. §§ 206, 207, and 216(b), which provides that suit under the Federal Labor 

Standards Act (hereinafter "FLSA") “may be maintained against any employer...in 

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any Federal or State court of competent jurisdiction.”

2. This Court has federal question jurisdiction over this action pursuant to

28 U.S.C. §1331.

3. Venue is proper in this District pursuant to 28 U.S.C. §1391(b) as the

Defendants are located and/or do business within this District. In addition, a 

substantial part of the events and omissions giving rise to the claims pleaded in this 

Complaint occurred within this District.

PARTIES 

4. Plaintiff is a resident of the State of Florida and was an employee of the 

Defendants from October 2018 through September 2020.

5. Plaintiff worked for the Defendants performing multiple duties 

assigned to her by the Defendants and required by the Defendants at their property 

located in the Pensacola, Florida, area.

6. At all times material herein, Plaintiff was an employee of the 

Defendants within the meaning of the Act, 29 U.S.C. § 203(e)(1).

7. Defendant, Stay the Spa, is a Florida limited liability company duly 

licensed and organized under the laws of the State of Florida and is engaged in the 

business of, but not limited to, operating a full-service day spa.

8. Defendant, Mr. Smith, is a resident of the State of Florida and is listed 

as a title manager of Defendant, Stay the Spa.

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9. Defendant, Mrs. Smith, is a resident of the State of Florida and is listed 

as a title manager of Defendant, Stay the Spa.

10. Defendants, at all times material, were an "employer" of the Plaintiff

within the meaning of the FLSA, 29 U.S.C. § 203(d).

FACTUAL ALLEGATIONS 

11. The Defendant, Stay the Spa, is an employer and enterprise engaged in 

interstate commerce.

12. The Defendant, Mr. Smith, is an employer and enterprise engaged in 

interstate commerce, because, without limitation, he exercises control over 

significant aspects of the Stay the Spa’s day-to-day functions, including without 

limitation, compensation of employees.

13. The Defendant, Mrs. Smith, is an employer and enterprise engaged in 

interstate commerce, because, she exercises control over significant aspects of the 

Stay the Spa’s day-to-day functions, including without limitation, compensation of 

employees.

14. The Defendant, Stay the Spa’s, principal place of business is 240 S. 

Jefferson Street, Pensacola, FL 32502.

15. The Defendants, as part of their business, would engage in interstate 

commerce by, but not limited to, processing credit cards which are instruments of 

interstate commerce, transacting business with foreign corporations which were part 

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of interstate commerce, purchasing products, furniture, equipment, materials, and 

supplies from dealers, wholesalers, suppliers, and retailers out of state which were 

part of interstate commerce, by advertising on the World Wide Web and other 

mediums to potential clients outside the State of Florida, and by transacting 

business across state lines, all of which are part of interstate commerce.

16. Furthermore, the Defendants obtain, exchange, and send/receive funds 

to and from outside of the State of Florida, sells goods and products outside the State 

of Florida, use telephonic transmissions going outside of the State of Florida to 

conduct business, and transmit electronic information through computers, the 

Internet, via email, and otherwise outside of the State of Florida.

17. The Defendant, Stay the Spa, has an annual revenue of at least five 

hundred thousand dollars ($500,000.00).

20. The Defendants' operations, practices, policies and procedures 

including those with respect to compensation, are highly integrated and 

interdependent such that the Defendants constitute a single and/or joint employer 

under the law.

21. The Defendants control the day to day operations of the day spa located 

at 240 S. Jefferson Street, Pensacola, FL 32502, and are actively involved in the day 

to day operations of same including matters concerning hiring, firing, payroll, setting 

policies, making procedures, setting goals and quotas, marketing, establishing 

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services to offer, setting product and services pricing, and other business operations.

22. The Defendants hired Plaintiff in or about October 2018 as an 

esthetician. The Plaintiff is no longer employed by the Defendants.

23. Along with working as an esthetician, the Plaintiff also worked in the 

Defendants’ full day service spa, boutique shop, worked on location for weddings, 

attended meetings, trained other employees, attended training of product 

representatives, and sold goods and products.

24. The Defendants facilities were open to the public.

25. At all times material herein, the Defendants, controlled the Plaintiff's 

day to day activities, supervised, and/or had operational control over the Plaintiff. 

The Defendants were responsible for hiring the Plaintiff, having the ability to 

terminate the Plaintiff, setting the Plaintiff's rate of pay, determining if minimum 

wage or overtime was to be paid, determining if commission(s) were to be paid, 

setting the Plaintiff's work schedule including the number of days and hours 

worked, determining and assigning the Plaintiff's work duties, and supervising 

the Plaintiff.

26. During her employment with the Defendants, the Defendants 

misclassified some of the Plaintiff's employment as an independent contractor. 

Specifically, some of her time was compensated as an employee and other parts of 

her time were classified incorrectly by the Defendants as an independent contractor.

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27. In particular, when the Defendants hired the Plaintiff or about October 

2018, the Defendants paid the Plaintiff as a non-exempt employee that received a 

W-2.

28. On or about July 16, 2019, the Defendants informed the Plaintiff that 

the Defendants wanted to provide her with a “special offer” that was only available 

to “select employees” so she could “get more money in her paycheck” that would 

allow the Plaintiff to be paid more than she was paid previously as a non-exempt 

employee that received a W-2.

29. Unbeknownst to the Plaintiff, the Defendants’ had an ulterior, sinister 

motive and the “special offer” was just to misclassify the Plaintiff as an independent 

contractor for the Defendants’ sole and exclusive benefit.

30. The Defendants desired to misclassify the Plaintiff as an independent 

contractor to purposefully escape payroll taxes and unemployment taxes such as 

FICA, SUTA, and other applicable payroll taxes.

31. Commencing on or about July 16, 2019, the Defendants began 

compensating the Plaintiff as an independent contractor.

32. Despite the Defendants changing the Plaintiff’s employment status 

from a non-exempt employee that received a W-2 to an independent contractor on 

or around July 16, 2019, the Plaintiff’s job duties, functions, and responsibilities 

remained the same. 

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33. At all times during the period the Plaintiff has worked for the 

Defendants, the Defendants have exercised control over her.

34. At all times during the period Plaintiff worked for the Defendants, the 

relationship with the parties were permanent in nature.

35. At all times during the period Plaintiff worked for the Defendants, the 

Plaintiff was economically dependent on the Defendants.

36. At all times during the period Plaintiff worked for the Defendants, the 

Plaintiff's job duties performed were an integral part of the Defendants' business.

37. The Plaintiff was a "non-exempt" employee of the Defendants.

38. The Plaintiff was not a salaried employee.

39. The Plaintiff worked the number of hours required of her by the 

Defendants, but was not properly paid for each and every hour worked during a work 

week.

40. The Defendants permitted the Plaintiff to work for them but did not 

properly pay her for all work that she performed for the Defendants.

41. The Plaintiff worked over forty (40) hours in a work week for the 

Defendants, but was not paid overtime compensation at the proper overtime rate by 

the Defendants for those hours worked over forty (40) in a work week.

42. The Plaintiff worked for the Defendants, but was not paid any wages as

compensation for Plaintiff completing mandatory training, meetings, training other 

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employees, trainings with product representatives, cleaning, sweeping, and 

sanitizing the Defendants’ premises, all as demanded by the Defendants. 

43. The Defendants were directly involved with paying the Plaintiff.

44. The records concerning the hours worked by the Plaintiff are in the 

exclusive possession and sole custody and control of the Defendants. Therefore, the 

Plaintiff is unable to determine and state the exact amount of damages due.

45. The Defendants' actions in failing and/or refusing to pay the Plaintiff 

the applicable minimum wage and/or overtime compensation, as required by the 

FLSA, were willful and not in good faith.

46. Plaintiff has retained the undersigned attorneys and is obligated to pay

them a reasonable fee for their services pursuant to the FLSA.

COUNT I — FAILURE TO PAY OVERTIME UNDER THE FLSA

47. Plaintiff re-alleges paragraphs 1 – 46 above as if fully set forth herein.

48. The Defendants hired Plaintiff in or about October 2018 to work for 

them at their location in the Pensacola, Florida area.

49. During her time as an employee of the Defendants, the Plaintiff 

worked as and performed the essential duties of her job including, but not limited 

to as an esthetician. She was also required to work at the full day service spa, 

boutique shop, worked on location for weddings, attended meetings, trained other 

employees, attended training of product representatives, and sold goods and products

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and other merchandise in the Defendants’ full day service spa and boutique shop.

50. On average, the Plaintiff worked over forty (40) hours in a work week 

for the Defendants performing all of the job duties of an esthetician, and her other 

job duties.

51. The Plaintiff estimates, that in many weeks during her employment 

with the Defendants, she worked well in excess of forty (40) hours per week.

52. Section 207(a)(1) of the FLSA prohibits an employer from employing 

its non-exempt employees for a work week longer than forty (40) hours, unless such 

employee receives compensation for all hours he or she is employed in excess of 

forty hours at a rate not less than one and one-half times the regular rate of pay.

53. The Plaintiff was not exempt from receiving overtime compensation 

under the FLSA.

54. As such, Plaintiff was entitled to be paid at a rate one and one-half (1 

1

/2) times her regular hourly rate for each hour worked in excess of forty (40) in a 

work week.

55. The Defendants employed Plaintiff in excess of forty (40) hours in at 

least one work week without paying her at a rate of one and one half (1 1/2) times her 

regular rate of pay for all hours worked in excess of forty (40) in the work week as 

required by the FLSA, and thus have violated the Plaintiffs rights under § 207 of the 

FLSA.

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56. As a consequence of the Defendants violation of the FLSA, the Plaintiff 

is entitled to one and one half (1 1/2) times her regular rate of pay for all hours she 

worked in excess of 40 hours for each week she was employed by the Defendants 

and for which she was not paid one and one half times (1 1/2) her regular rate.

57. Defendants knew and were aware at all times that Plaintiff worked more 

than forty (40) hours per week without receiving the appropriate overtime 

compensation.

58. Defendants failed and refused to properly compensate Plaintiff at the 

proper overtime rate for each hour worked in excess of forty (40) in a work week.

59. The Defendants knew, or showed reckless disregard for the fact, that 

their failure to pay the Plaintiff as alleged herein was in violation of the FLSA.

60. The actions of the Defendants complained of herein were willful within 

the meaning of 29 U.S.C. § 216(b).

61. Because of Defendants' actions, Plaintiff has had to retain counsel and 

is entitled to recover her attorneys' fees and costs connected with this suit.

62. As a result of the unlawful acts of the Defendants, Plaintiff has been 

deprived of overtime compensation in amounts to be determined at trial, and is 

entitled to recovery of such amounts, liquidated damages, attorneys' fees, costs 

and other compensation.

WHEREFORE, the Plaintiff prays that this Honorable Court:

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A. Enter judgment for the Plaintiff and against the Defendants on 

the basis of Defendants' willful violations of the overtime 

provisions of the Fair Labor Standards Act, 29 U.S.C. §207, as 

to the Plaintiff;

B. Award Plaintiff actual and compensatory damages in the amount 

shown to be due for unpaid overtime compensation;

C. Award Plaintiff an equal amount in liquidated damages;

D. Award Plaintiff reasonable attorney's fees and costs of suit;

E. Enter a declaration that the Plaintiff's employment as an 

esthetician is not exempt from receiving overtime compensation 

under the FLSA;

F. Enter a judgment according to the declaratory relief sought; and

G. Grant such other and further relief as this Court deems equitable

and just.

COUNT II — VIOLATION OF 26 U.S.C. § 7434

63. Plaintiff re-alleges paragraphs 1 – 46 above as if fully set forth herein.

64. The Defendants hired Plaintiff in or about October 2018 as an 

esthetician.

65. At all times herein, Plaintiff worked for the Defendants as an 

esthetician and in Defendants’ full-service day spa and boutique salon.

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66. The Plaintiff's job duties as an esthetician included, but were not limited 

to work for the Defendants in their full day service spa and boutique shop and 

providing clients with services typically provided by estheticians including without 

limitation, makeup, tanning, and waxing. 

67. The Plaintiff was also required to work on location for weddings, attend 

meetings, train other employees, attend training of product representatives, and sell 

goods and products.

68. Prior to July 16, 2019, the Plaintiff was paid via a W-2 for all work

performed as an esthetician, including working in their full day service spa and 

boutique shop and providing clients with services typically provided by 

estheticians, including without limitation, makeup, tanning, and waxing.

69. On or about July 16, 2019, the Defendants informed the Plaintiff that 

the Defendants wanted to provide her with a “special offer” that was only available 

to “select employees” so she could “get more money in her paycheck” that would 

allow the Plaintiff to be paid more than she was paid previously as a non-exempt 

employee that received a W-2.

70. Unbeknownst to the Plaintiff, the Defendants’ “special offer” was just 

to misclassify the Plaintiff as an independent contractor for the Defendants’ sole and 

exclusive benefit.

71. Commencing on or about July 16, 2019, the Defendants began 

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compensating the Plaintiff as an independent contractor.

72. Despite the Defendants changing the Plaintiff’s employment status 

from a non-exempt employee that received a W-2 to an independent contractor on 

or around July 16, 2019, the Plaintiff’s job duties, functions, and responsibilities 

remained the same. 

73. The Defendants issued the Plaintiff a 1099 for the Plaintiff’s income 

earned while employed as an esthetician by the Defendants for July 16, 2019 through 

December 31, 2019 and a W-2 for income earned while employed as an esthetician 

by the Defendants for 2018 and from January 2019 through July 15, 2019.

74. The Defendants continued to misclassify and improperly treat the 

Plaintiff as an independent contractor from July 16, 2019 until her employment with 

Defendants was terminated.

75. During Plaintiffs employment with the Defendants, she was always an 

employee of the Defendants:

a. At all times herein, the Plaintiffs tanning, waxing, and makeup 

appointments for Defendants’ customers were set/scheduled 

through Defendants’ online system and paid through the 

Defendants’ point of sale system.

b. At all times herein, the Plaintiff did not have her own private 

business.

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c. At all times herein, the Plaintiff was required to work in any and 

all clinics and events hosted by the Defendants or otherwise held 

on Defendants’ premises without additional pay.

d. At all times herein, the Plaintiff could not work for another 

facility and was unable to work for other employers/provide 

esthetician services at any facility other than the Defendants’ 

facility.

e. At all times herein, the Plaintiff was unable to personally set the 

rates of pay for her tanning, waxing, and makeup appointments

for Defendants’ customers.

f. At all times herein, the Plaintiff’s compensation for her tanning, 

waxing, and makeup appointments for Defendants’ customers

was provided by and set by the Defendants.

g. At all times herein, the Plaintiff was unable to provide any 

esthetician services including without limitation, tanning, 

waxing, and makeup appointments for customers other than for 

Defendants’ customers.

h. At all times herein, the Plaintiff was required to work in 

Defendants’ full day service spa and boutique shop and sell 

Defendants’ products and goods.

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i. At all times herein, the Plaintiff was required to attend company 

employee meetings, train other employees, and attend trainings 

by product representatives.

j. At all times herein, the Plaintiff was required to provide services 

on behalf of the Defendants on location at weddings. 

k. At all times herein, the Plaintiff's work in Defendants’ full day 

service spa and boutique shop facilitated and supported her work 

as an esthetician.

j. At all times herein, the Defendants exercised control over the 

Plaintiff's work activities, including Plaintiff's work providing 

esthetician services, requiring the Plaintiff to clean, sweep, and 

sanitize the Defendants’ facilities without compensation.

k. At all times herein, the Plaintiff was economically dependent on 

the Defendants.

1. At all times herein, the Plaintiff's job duties performed were an 

integral part of the Defendant's business.

76. Defendants had full knowledge that Plaintiff worked in excess of forty 

(40) hours per week during certain weeks in the years of 2018, 2019, and 2020. 

77. The Defendants had full knowledge that the Plaintiff was not an 

independent contractor and should have been provided a W-2 for her services 

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performed for the Defendants during the calendar years of 2019 and 2020.

78. By failing and refusing to provide Plaintiff with a W-2 for all her 

services performed for the Defendants in 2019 and failing to accurately reflect 

overtime wages which Plaintiff should have received during the calendar year of 

2018 and 2019, the Defendants caused the Plaintiff to be issued an inaccurate and 

incorrect W-2 in 2018, and inaccurate and incorrect W-2 for January 1, 2019 through 

approximately July 15, 2019, and an inaccurate and incorrect 1099 for July 16, 2019

through December 2019.

79. Additionally, by failing and refusing to provide Plaintiff with a W-2 

for her services performed for the Defendants in 2019 and failing to accurately 

reflect overtime wages which Plaintiff should have received during the calendar 

years of 2018 and 2019, the Defendant failed to appropriate, pay, or otherwise 

provide the Florida Department of Revenue with the appropriate payroll taxes that 

needed to be paid, including federal and state employment taxes.

80. From on or about 2018 to the present, Defendants facilitated or caused 

incorrect W-2's and 1099’s to be filed, and incorrect state wage forms that were 

reported to the Florida Department of Revenue.

81. Defendants knew or should have known that the Plaintiff was not an 

independent contractor because of the treatment provided to her from the years prior 

to July 16, 2019, and because the Plaintiff was economically dependent on the 

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Defendants as noted above/would not qualify as an independent contractor under the 

law.

82. Defendants misclassified Plaintiff's income earned as an independent 

contractor and refused to provide Plaintiff with a W-2 for all work performed in 2019 

to purposefully escape payroll taxes and unemployment taxes such as FICA, SUTA, 

and other applicable payroll taxes.

83. Defendants never received nor sought any legal or professional advice 

before naming the Plaintiff a 1099 independent contractor in 2019.

84. Defendants had an obligation to provide correct information returns 

to the IRS, State of Florida, and the State of Florida Department of Revenue.

85. Section 7434 of 26 U.S.C. provides, in pertinent part, as follows:

(a) In general

If any person willfully files a fraudulent information return with 

respect to payments purported to be made to any other person, such 

other person may bring a civil action for damages against the person 

so filing such return.

86. Defendants provided paychecks to Plaintiff and were directly 

responsible for the issuance of paychecks to Plaintiff, calculation of 

withholdings from Plaintiff’s pay, the payment of taxes to the IRS, the 

preparation of their annual income tax returns, the preparation and filing of Form 

941's, and the filing of information returns on their own behalf as noted above.

87. Plaintiff's W-2s for the 2018 and 2019 calendar year misstated 

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the Plaintiff's income and misrepresented the amount of income earned by the 

Plaintiff during her work with Defendants.

88. Defendants were aware and/or knew or should have known that all 

of Plaintiff’s services for Defendants should have been included on a W-2; 

however, Defendants willfully provided Plaintiff with incorrect W-2s and 1099s

in order to avoid paying the required employment taxes on her behalf.

89. Defendants served/filed or caused to be served/filed a knowingly 

misleading false annual tax W-2 for the year of 2018 by failing to pay and report 

overtime wages and for the year of 2019 by misclassifying Plaintiff's work as an 

independent contractor rather than as an employee, and then failing to properly 

identify her as an employee and pay the required employment taxes on her behalf.

90. Defendants served/filed or caused to be served/filed knowingly false 

IRS Form 941 quarterly tax returns in or about 2019 and 2020 by failing to include 

Plaintiff's income as an employee.

91. Defendants acted willfully to issue or cause to be issued an incorrect 

and inappropriate IRS information return to Plaintiff so as to avoid paying the 

employer share of FICA and related employer tax withholdings.

92. Plaintiff suffered damages as a result of Defendants’ willful 

provision of false information returns, including the overpayment of taxes as an 

independent contractor, the failure to receive the required contribution to her 

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taxes by her employers, the lack of a contribution to social security, and the like, 

as a result of Defendants’ intentional and willful acts as described above.

WHEREFORE Plaintiff demands the entry of a judgment in her favor and 

against Defendants, jointly and severally, after trial by jury and as follows:

A. That Plaintiff recover the greater of $5,000 for each fraudulent 

information return filed by Defendants for each year during the 

past three (3) years or the damages proximately caused by 

Defendants' conduct for each year during the past three (3) 

years, including any and all damages following the filing of this 

Complaint;

B. That Plaintiff recover an award of reasonable attorney's fees, costs, 

and expenses pursuant to 26 U.S.C. §7434;

C. That Plaintiff recover all interest allowed by law; and

D. Grant such other and further relief as this Court deems equitable 

and just.

COUNT III — FAILURE TO PAY MINIMUM WAGE UNDER THE FLSA

93. Plaintiff re-alleges paragraphs 1 – 46 above as if fully set forth herein.

94. The Defendants hired Plaintiff in or about October 2018 to work for 

them at their location in the Pensacola, Florida area.

95. During her time as an employee of the Defendants, the Plaintiff 

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worked as and performed the essential duties of her job including, but not limited 

to as an esthetician. She was also required to sell items and other merchandise in 

the Defendants’ boutique salon.

96. The Plaintiff was also required to work on location for weddings, attend 

meetings, train other employees, attend training of product representatives, and sell 

goods and products.

97. Section 206 of the FLSA prohibits an employer from paying its 

employees less than $7.25 per hour. 

98. The Plaintiff was engaged in commerce or in the production of goods 

for commerce.

99. The Defendants required that the Plaintiff complete mandatory training 

to provide esthetician services at Defendants’ premises after Defendants employed 

the Plaintiff. The mandatory training included, but was not limited to company 

meetings and training by product representatives. 

100. The training occurred outside of the Plaintiff’s normal work hours.

101. The Plaintiff was unable to carry out productive work during this 

mandatory training.

102. The Plaintiff was not compensated for time spent completing the 

Defendants’ mandatory training. 

103. The Defendants also required that the Plaintiff clean, sweep, and/or 

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sanitize the Defendants’ premises during her employment with the Defendants. 

104. The Defendants did not compensate the Plaintiff for her time spent 

working for the Defendant by cleaning, sweeping, and/or sanitizing the Defendants’ 

premises during her employment with the Defendants. 

105. The Defendants were required to compensate the Plaintiff for her time 

spent performing the mandatory training and for the time spent working for the 

Defendant by cleaning, sweeping, and/or sanitizing the Defendants’ premises during 

her employment with the Defendants.

106. Defendants knew and were aware at all times that Plaintiff performed 

the mandatory training and cleaned, swept, and/or sanitized the Defendants’ 

premises during her employment with the Defendants without receiving the 

appropriate compensation.

107. Defendants failed and refused to properly compensate Plaintiff for each 

hour worked by the Plaintiff completing the mandatory training and cleaning, 

sweeping, and/or sanitizing the Defendants’ premises, and working weddings on 

location during her employment with the Defendants.

108. The Defendants knew, or showed reckless disregard for the fact, that 

their failure to pay the Plaintiff as alleged herein was in violation of the FLSA.

109. The actions of the Defendants complained of herein were willful within 

the meaning of 29 U.S.C. § 216(b).

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110. Because of Defendants' actions, Plaintiff has had to retain counsel and 

is entitled to recover her attorneys' fees and costs connected with this suit.

111. As a result of the unlawful acts of the Defendants, Plaintiff has been 

deprived of wages in amounts to be determined at trial, and is entitled to recovery 

of such amounts, liquidated damages, attorneys' fees, costs and other 

compensation.

WHEREFORE, the Plaintiff prays that this Honorable Court:

A. Enter judgment for the Plaintiff and against the Defendants on 

the basis of Defendants' willful violations of the minimum wage

provisions of the Fair Labor Standards Act, 29 U.S.C. §206, as 

to the Plaintiff;

B. Award Plaintiff actual and compensatory damages in the amount 

shown to be due for unpaid compensation;

C. Award Plaintiff an equal amount in liquidated damages;

D. Award Plaintiff reasonable attorney's fees and costs of suit;

E. Enter a declaration that the Plaintiff is entitled to be compensated 

minimum wage under the FLSA for all hours worked by the 

Plaintiff for the Defendants;

F. Enter a judgment according to the declaratory relief sought; and

G. Grant such other and further relief as this Court deems equitable 

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and just.

PLAINTIFF DEMANDS A TRIAL BY JURY

DATED this 11th day of September, 2020.

CARVER, DARDEN, KORETZKY, TESSIER, 

FINN, BLOSSMAN & AREAUX LLC

By:_/s/Robert S. Rushing_______ 

Robert S. Rushing, Esquire

Florida Bar No.: 0013946

Travis M. Morock, Esquire

Florida Bar No.: 118823

151 West Main Street, Suite 200

Pensacola, Florida 32502

Telephone: (850) 266-2300

rushing@carverdarden.com

morock@carverdarden.com

Attorney for Plaintiff, 

ZOE ROSE HAFT

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