NICHOLSON & EASTIN, LLP

707 N.E. 3RD AVENUE, SUITE 301, FORT LAUDERDALE, FLORIDA 33304

1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No:

JOHN S. SOLTYS, )

)

Plaintiff, )

vs. )

)

PROSEGUR SECURITY USA, INC, a Delaware )

Corporation, and PROSEGUR GLOBAL RISK )

SERVICES, LLC a Delaware Corporation, )

)

Defendants. )

__________________________________________/

COMPLAINT

 Plaintiff, JOHN S. SOLTYS, by and through undersigned counsel, files this Complaint 

and sues the Defendants, PROSEGUR SECURITY USA, INC., and PROSEGUR GLOBAL RISK 

SERVICES, LLC (collectively, “PROSEGUR” or “Defendants”), and states as follows:

NATURE OF THE CASE

1. This Complaint seeks to recover damages resulting from the Defendants’ violation of 

the Florida Private Whistleblower Act, Florida Statutes §§448.101 - 448.105. Defendants violated 

the Florida Private Whistleblower Act by unlawfully terminating Plaintiff’s employment in 

retaliation for Plaintiff’s written and oral objections to Defendants’ actions which constituted 

violations of laws, rules or regulations. 

THE PARTIES

2. Plaintiff, JOHN S. SOLTYS, is a citizen of the state of Florida, and is sui juris. 

3. Defendant PROSEGUR SECURITY USA, INC., is a Delaware Corporation with a 

principal place of business in Herndon, Virginia. PROSEGUR SECURITY USA has been 

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operating in Florida without being registered with the Florida Secretary of State as a foreign 

corporation conducting business in Florida. PROSEGUR SECURITY USA withdrew its foreign 

corporation status in Florida as of January 10, 2021. See Exhibit 1. 

4. Defendant PROSEGUR GLOBAL RISK SERVICES, LLC is a Delaware Corporation

with a principal place of business of Herndon, Virginia. PROSEGUR GLOBAL RISK SERVICES

is a subsidiary of PROSEGUR SECURITY USA and maintains an office in Deerfield Beach, 

Florida. PROSEGUR GLOBAL RISK SERVICES has also been operating in Florida without 

being registered with the Florida Secretary of State as a foreign corporation conducting business 

in Florida. 

JURISDICTION AND VENUE

5. The amount in controversy in this action exceeds $75,000.00, excluding interest, costs 

and attorneys’ fees, and is between a citizen of the State of Florida, and citizens of another state. 

As such, this action is within the diversity jurisdiction of the court in accordance with the 

provisions of 28 U.S.C. § 1332(a).

6. Venue in the Southern District of Florida is proper in this action under 28 U.S.C. § 

1391(b)(2) because a substantial part of the events or omissions giving rise to this action occurred 

within the Southern District of Florida. 

FACTUAL BACKGROUND AND GENERAL ALLEGATIONS

7. Plaintiff was employed by the Defendants as the Vice President of Global Intelligence 

and Operations at PROSEGUR GLOBAL RISK SERVICES from October 2021 through the date

of his unlawful termination on August 10, 2022. Plaintiff has worked at the PROSEGUR 

GLOBAL RISK SERVICES offices in Broward County, Florida since January 2022. 

8. Plaintiff had extensive military, law enforcement and intelligence community

experience prior to accepting employment with PROSEGUR. Plaintiff is a retired Navy SEAL

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and a retired senior intelligence officer with the Central Intelligence Agency, who also formerly 

served as a Deputy United States Marshal, and a Special Agent with the United States Customs 

Service.

9. PROSEGUR GLOBAL RISK SERVICES was in the business of providing private 

investigative services in Florida and elsewhere, including the collection of evidence for use in civil 

and criminal cases, background investigations, criminal and non-criminal intelligence gathering, 

as well as executive protection services. PROSEGUR GLOBAL RISK SERVICES advertised 

these services on PROSEGUR SECURITY USA’s website. See Exhibit 2. 

10. Plaintiff reported to Robert L. Dodge, who was Chief Executive Officer for Global 

Risk Services at PROSEGUR. Mr. Dodge assumed the position of Chief Executive Officer for 

PROSEGUR GLOBAL RISK SERVICES in May 2021.

11. Prior to his employment with PROSEGUR, Mr. Dodge was employed for 7 years as 

a corporate executive at G4S. See Exhibit 3. G4S, which is now a subsidiary of Allied Universal,

also provided corporate investigation, risk consulting, intelligence and executive protection 

services, and is a global competitor to PROSEGUR. 

12. During the course of Plaintiff’s employment at PROSEGUR, he became aware that

PROSEGUR SECURITY USA and PROSEGUR GLOBAL RISK SERVICES were engaging in 

activities that constituted violations of laws, rules and regulations. Plaintiff objected – orally 

and/or in writing – to these violations. 

Unlicensed Private Investigations 

13. In order to offer, advertise and/or provide private investigative services in Florida, 

PROSEGUR GLOBAL RISK SERVICES was required by Florida statutes to be licensed as a 

private investigative agency with the Florida Department of Agriculture. 

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14. Pursuant to § 493.6120, Fla. Stat., it is a criminal violation to offer, advertise and/or 

provide private investigative services in Florida without having a valid private investigator license. 

15. From the time Plaintiff was hired, through the date of his unlawful termination of 

employment, PROSEGUR GLOBAL RISK SERVICES did not have a private investigative 

agency license in Florida. 

16. Plaintiff objected both orally and in writing to CEO Robert Dodge that PROSEGUR 

was unlawfully providing private investigative services without an appropriate license. 

False Representations Regarding Qualifications

17. Because of the very sensitive nature of the types of corporate investigations conducted 

by PROSEGUR, the qualifications and backgrounds of PROSEGUR corporate officers and 

employees were highly material to current and prospective clients. 

18. In making proposals to prospective clients, PROSEGUR would provide biographies 

on key personnel to the prospective clients touting the intelligence community and law 

enforcement experience of PROSEGUR GLOBAL RISK SERVICES’s key personnel. 

19. The biography provided by PROSEGUR to prospective clients regarding Robert 

Dodge’s experience falsely claimed that Dodge had been an Anti-Terrorism Weapons, Tactics and

training specialist in the United States Navy. See Exhibit 4. 

20. Plaintiff, who was in the United Stated Navy for over 20 years, confronted Robert 

Dodge with the fact that no such position existed in the Navy. Plaintiff learned that Robert Dodge 

had actually held the position of boatswains mate (a member of the deck crew) while in the Navy. 

21. Plaintiff objected to Robert Dodge regarding PROSEGUR’s use of Dodge’s false 

credentials. Dodge initially ignored Plaintiff’s objections, and stated to Plaintiff that current and 

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prospective clients wanted to see this type of experience. Eventually, Dodge removed the false 

information from his PROSEGUR biography. 

22. Because Robert Dodge’s false biography was sent through the mails and interstate 

wire communications to prospective clients for the purpose of misleading prospective clients 

regarding PROSEGUR GLOBAL RISK SERVICES’s experience and capabilities, the use of the 

false biographic information violated state and federal fraud statutes, including the federal Mail 

Fraud and Wire Fraud statutes.

Trade Secrets Act Violation 

23. Robert Dodge informed Plaintiff that upon Mr. Dodge’s departure from G4S he was

subject to a non-compete and confidentiality agreement for a period of 2 years. As part of the noncompete and confidentiality agreement, Dodge said he agreed that he could not solicit clients that 

were clients of G4S during his period of employment at G4S, nor could he use confidential 

information obtained during his employment with G4S.

24. In violation of Mr. Dodge’s non-compete and confidentiality agreement, PROSEGUR 

actively sought to obtain Caterpillar Inc., as a client using confidential information Dodge had 

taken from G4S. At the time PROSEGUR SECURITY USA and PROSEGUR GLOBAL RISK 

SERVICES were soliciting Caterpillar as a client, Caterpillar was still a client of G4S. 

25. In an effort to conceal Mr. Dodge’s prohibited involvement in the solicitation of 

Caterpillar, Mr. Dodge referred to the effort to acquire Caterpillar as a client by the code name 

“Project Panther” in his emails and other communications. 

26. PROSEGUR SECURITY USA and PROSEGUR GLOBAL RISK SERVICES used 

confidential pricing and other confidential information obtained from G4S by Mr. Dodge in 

formulating its proposal to Caterpillar. 

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27. While employed with G4S, Mr. Dodge had sent confidential information and 

documents from his G4S email account to his personal email account. Plaintiff was provided with 

copies of some of this information that Mr. Dodge forwarded from his personal email account to 

Plaintiff and others as PROSEGUR. Attached as Exhibit 5 are sample documents. 

28. PROSEGUR’s use of confidential information obtained by Robert Dodge from G4S 

constituted a violation of multiple state and federal laws protecting trade secrets, including the 

federal Theft of Trade Secrets statute, 18 U.S.C. §1832.

29. Plaintiff objected to Robert Dodge and PROSEGUR regarding Mr. Dodge’s violation 

of the non-compete agreement, as well as PROSEGUR’s use of G4S confidential information 

provided to PROSEGUR by Mr. Dodge. Plaintiff’s objections were ignored. 

Unlawful Termination of Employment 

30. In retaliation for Plaintiff’s objections to PROSEGUR’s violations of laws, rules and 

regulations described above, PROSEGUR took negative personnel action against Plaintiff by

excluding Plaintiff from internal and external company meetings, and by limiting his duties,

responsibilities and authority within PROSEGUR GLOBAL RISK SERVICES.

31. The retaliation against Plaintiff escalated, and on August 10, 2022, Plaintiff’s 

employment with PROSEGUR was unlawfully terminated in retaliation for his objections to 

PROSEGUR’s violations of laws, rules and regulations. 

32. Plaintiff was told that his employment was being terminated as part of a companywide 

reduction in force. This was a lie as PROSEGUR GLOBAL RISK SERVICES had already hired 

Plaintiff’s functional replacement prior to Plaintiff’s termination of employment.

33. Prior to Plaintiff’s termination of employment, he had never received any formal or 

informal counseling regarding poor performance. To the contrary, Plaintiff had helped 

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PROSEGUR GLOBAL RISK SERVICES substantially exceed its targeted revenue and profit

goals. 

34. The negative personnel actions taken against Plaintiff by the Defendants constituted

violations of the Florida Private Whistleblower Act. 

35. All conditions precedent to the maintenance of this action have been fulfilled, have 

been waived, or have occurred. 

36. Plaintiff has retained the undersigned attorneys to prosecute this action and has agreed 

to pay a reasonable fee for their services.

COUNT I

VIOLATION OF FLORIDA PRIVATE WHISTLEBLOWER ACT 

(Against PROSEGUR SECURITY USA and PROSEGUR GLOBAL RISK SERVICES)

37. Plaintiff adopts and re-alleges the allegations set forth in paragraphs 1 through 36 as 

if fully stated fully herein.

38. This is a cause of action against Defendants PROSEGUR SECURITY USA, INC. and 

PROSEGUR GLOBAL RISK SERVICES. LLC for retaliatory personnel action in violation of the 

Florida Private Whistleblower Act in response to Plaintiff’s objections to one or more activities

and practices of his employer which constituted a violation of a law, rule or regulation. 

39. Pursuant to Florida Statutes §§448.101-448.105, Plaintiff is entitled to recover his lost 

wages, including interest and costs, as well as liquidated damages, as well as his expenses and 

attorneys’ fees in bringing this action. 

WHEREFORE, Plaintiff demands judgment for damages, together with interest, costs, 

and attorneys’ fees and costs, and for such other relief as this Court deems just and proper.

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DEMAND FOR JURY TRIAL

Plaintiff demands a trial of this action by jury for all issues triable as of right by jury.

RESPECTFULLY SUBMITTED this 26

th day of August, 2022.

/s Robert N. Nicholson 

Robert N. Nicholson, P.A.

Florida Bar No. 933996

Email: Robert@NicholsonEastin.com

Nicholson & Eastin, LLP

707 N.E. Third Ave., Suite 301

Fort Lauderdale, FL 33304

Telephone: (954) 634-4400

Attorneys for John S. Soltys

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