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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 22-81088-CV-MIDDLEBROOKS/MATTHEWMAN

Christine Ferrigan,

Plaintiff,

v.

City of Delray Beach, Florida, et al.,

 Defendants 

 

__________________________________/

PLAINTIFF’S RESPONSE TO DEFENDANTS’ 

CORRECTED STATEMENT OF MATERIAL FACTS

Plaintiff, Christine Ferrigan, by and through her undersigned counsel and under Federal 

Rules of Civil Procedure, Rule 56 and Local Rule 56.1, hereby submits her Response to 

Defendants’ Statement of Material Facts in support of her Opposition to Defendants’ Motion for 

Summary Judgment.

1. Disputed. "Pretreatment" means the reduction of the amount of pollutants, the 

elimination of pollutants, or the alteration of the nature of pollutant properties in wastewater 

prior to or in lieu of discharging or otherwise introducing such pollutants into a [wastewater 

facility] WWF. The reduction or alteration may be obtained by physical, chemical or biological 

processes, process changes or by other means, except as prohibited by subsection 62-625.410(5), 

F.A.C. Fla. Admin. Code § 62-625.200(17).

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2. Disputed. The IPP Inspector is involved in the inspection of hundreds of 

industrial and commercial users of the City’s sewer system. Ferrigan, ECF No. 56-1, 5:17-25 –

6:1-19.

3. Undisputed.

4. Disputed. “Reclaimed water” means water that has received at least secondary 

treatment and basic disinfection and is reused after flowing out of a domestic wastewater 

treatment facility. Fla. Admin. Code § 62-600.200(57); Delray Beach Ord. § 59.04.

5. Disputed. The purpose of a backflow and cross connection control program “is to 

protect the potable water supply of the City from the possibility of contamination or pollution by 

isolating within its customer's internal system or systems those contaminants or pollutants which 

could backflow or back-siphon into the public water supply system; to promote the elimination 

or control of existing cross connections, actual or potential, between the customer's potable water 

system or systems and nonpotable water systems, plumbing fixtures, and industrial piping 

systems; and provide for the maintenance of a continuing program of cross connection control 

which will systematically and effectively prevent the contamination or pollution of all potable 

water systems.” Delray Beach Ord. § 52.81. 

6. Disputed. See response to 5.

7. Undisputed.

8. Undisputed.

9. Undisputed.

10. Disputed. There are hundreds of industrial/commercial users of the City’s 

sanitary sewer system that require inspection in order to protect the system. Ferrigan, ECF No. 

56-1, 6:2-19, 7:2-18. After inquiring into whether the City had a reclaimed water program and 

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discovering that the regulatorily required program did not exist, Ms. Ferrigan was asked by 

Water and Sewer Manager Scott Solomon to develop the program. Ferrigan, ECF No. 56-1, 

19:17-24, 20:4-8, 22:8-18, 24:7-25 – 25:1-13.

11. Undisputed.

12. Disputed. It is unclear whether the contractor “breached several contractual 

requirements” or the City failed to perform its part of the work. Gelin, ECF No. 57-6, 33:16-25 

– 34: 1-5. 

13. Undisputed.

14. Undisputed.

15. Undisputed.

16. Undisputed.

17. Undisputed only during the times Mr. Lugo served as Ms. Ferrigan’s supervisor.

18. Undisputed.

19. Disputed. Assistant City Attorney William Bennett, Deputy Utilities Director 

Victor Majtenyi, Bryan Heller, and Ralph Lugo attended the February 3, 2020 meeting with 

DOH. Gelin, EF No. 57-6, 29:21-25 – 31:1-24, 45:3-10 (Heller and Majtenyi were upper 

management); Ferrigan, ECF No. 56-1, 96:9-11, 120:15-23.

20. Undisputed.

21. Undisputed.

22. Undisputed.

23. Undisputed.

24. Undisputed.

25. Undisputed.

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26. Undisputed.

27. Undisputed.

28. Undisputed.

29. Undisputed.

30. Undisputed.

31. Undisputed.

32. Undisputed.

33. Disputed. For non-union employees the manager or supervisor can recommend 

that an employee be terminated. The City manager will more likely than not follow that 

recommendation. Gelin, ECF No. 57-6, 133:13-25-134:1-15. Defendant Hadjimiry (Utilities 

Director) made the determination that Ms. Ferrigan’s position should be eliminated and 

recommended to Defendant Moore (City Manager) that he eliminate the position. Ex. 1, Delray 

Beach (Oris), 29:8-23; Hadjimiry, ECF No. 57-2, 86:6-25, 87:25 – 88: 1-7.

34. Disputed. Mr. Hadjimiry was aware of Ms. Ferrigan’s communications with 

DOH and OIG when he started with the City. Ex. 1, Delray Beach (Oris), 115:22-25 – 116:1-16.

35. Disputed. See response to 34.

36. Disputed. Mr. Hadjimiry told Ms. Ferrigan “You're not giving them anymore 

information and you're not going to see them anymore and you're not coming in tomorrow on 

Saturday.” Ferrigan, ECF No. 57-1, 157:10-22.

37. Disputed. See response to 36.

38. Disputed. Ex.18, Second Declaration of Christine Ferrigan at ¶ 14.

39. Disputed. Ex. 18 at ¶¶ 14-15.

40. Disputed. Ex. 18 at ¶¶ 14-15; DeCarolis, ECF No. 57-5, 72:15-20.

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41. Disputed. IPP Administrator Paul DeCarolis was shocked that Ms. Ferrigan was 

terminated. He was not consulted. DeCarolis, ECF No. 57-5, 74:6-25 – 75:1-2. Before 

terminating Ms. Ferrigan, Mr. Hadjimiry and Mr. DeCarolis had discussions about going back to 

a more proactive pretreatment inspection program. DeCarolis, ECF No. 57-5, 68:14-25 – 69:1-

22. Mr. DeCarolis informed Mr. Hadjimiry that he could not do plan reviews and inspections. 

He could not do both jobs. DeCarolis, ECF No. 57-5, 72:15-20.

42. Disputed. See response to 41.

43. Undisputed.

44. Undisputed.

45. Undisputed.

46. Undisputed.

47. Undisputed.

48. Disputed. Mr. Moore became aware that Ms. Ferrigan had been involved with the 

DOH investigation when the recommendation to eliminate her position was raised. Ex. 1,Delray 

Beach (Oris), 115:22-25 – 116:1-10, 116:17-24. 

49. Undisputed.

50. Undisputed.

51. Disputed. Ferrigan, ECF 57-1, 176:5-25.

52. Undisputed.

53. Undisputed.

54. Undisputed.

55. Undisputed.

56. Undisputed.

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57. Disputed. The cited reference does not support the fact alleged.

58. Disputed. Defendant Moore’s decision to eliminate Ms. Ferrigan’s position was 

based on the recommendation of Defendant Hadjimiry. Moore, ECF No. 58-4, 79:6-23, 95:20-

23.

59. Undisputed.

60. Disputed. The investigation was limited to events that took place at Delray 

Summit and did not include Ms. Ferrigan’s other complaints about being harassed or retaliated 

against for raising concerns with DOH. Bast, ECF No. 55-6, 153:13-25-154:1-21. 

61. Disputed. See response to 60.

62. Undisputed.

63. Undisputed.

64. Undisputed.

65. Undisputed.

66. Disputed. Mr. Hadjimiry observed the interviews. Human Resources 

Representative Armando Figueroa also scored the interviews. ECF No. 58-5 at 1. 

67. Undisputed with the exception of the scores that are reported, which are incorrect. 

68. Disputed. The applicable regulations provide that a pressure vacuum breaker 

(PVB) is inappropriate to use when there is backpressure as there is in much of the City’s 

system. Without considering backpressure, the regulation notes that a dual check device 

provides the worst level of protection, not a double check valve which is incorrectly noted as the 

“target response.” The regulations state: “Means of backflow protection, listed in an increasing 

level of protection, include the following: a dual check device (DuC); a double check valve 

assembly (DC) or double check detector assembly (DCDA); a pressure vacuum breaker 

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assembly (PVB); a reduced-pressure principle assembly (RP) or reduced-pressure principle 

detector assembly (RPDA); and an air gap. A PVB may not be used if backpressure could 

develop in the downstream piping.” Fla. Admin. Code § 62-555.360, Table 62-555.360-2, n. 1. 

69. Undisputed.

70. Undisputed.

71. Disputed. Human Resources reviews applications submitted through NeoGov to 

determine if a candidate meets minimum qualifications. Ex. 1,Delray Beach (Oris), 16:11-25 –

17:1. Mr. Hadjimiry, who knew Ms. Ferrigan’s experience very well, told Mr. Oris that she did 

not have the minimum qualifications, and her application was not forwarded to him for 

consideration. Ex. 1, Delray Beach (Oris), 48:16-25.

72. Disputed. See response to 71.

73. Disputed. The cited references do not support the fact alleged.

74. Disputed. Applicants are not informed that they can appeal a rejection 

notification. Ex. 1, Delray Beach (Oris), 53:9-16. 

ADDITIONAL FACTS

75. In 2018, Ms. Ferrigan reported problems she observed with the reclaimed water 

program to her supervisors, Scott Solomon and Victor Majtenyi. Ferrigan, ECF No. 57-1, 52:9-

25 – 53:1-17; 54:22-25 – 55:1-7.

76. Later, in November 2018, Ms. Ferrigan began to receive reports of residents 

experiencing illnesses that they believed related to their drinking water. Ferrigan, ECF No. 57-1,

58 – 59:1-17; Ex. 2, Cross Connection Issue Facts at 1 – 3. 

77. On December 6, 2018, Ms. Ferrigan discovered a cross-connection which she 

immediately reported to Mr. Solomon and advised him that the discovery had to be reported to 

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Florida Department of Health (DOH) and Department of Environmental Protection (DEP). 

Ferrigan, ECF No. 57-1, 53:18-25 – 54:1-21. 

78. Sometime in early to mid-2019, Ms. Ferrigan also discovered additional cross 

connections and reported them to Mr. Solomon. Id. at 66:14-25 – 69:1-17; 73:8-10. 

79. On or about April 1, 2019, Ms. Ferrigan discovered that the written report 

submitted by the City to DOH on or about December 19, 2018 concerning the cross-connection 

that was discovered at 801 S. Ocean Blvd. failed to accurately report that residents had reported 

getting sick from their drinking water. The report had been submitted and signed by Utilities 

Director Marjorie Craig. Id. at 74:23-25, 77:12-19. 

80. On or about April 5, 2019, Ms. Ferrigan reported the inaccurate report that was 

submitted to DOH to the Assistant City Manager/Acting Utility Director Caryn Gardner-Young. 

Id. at 79:20-25 – 82:1-6. 

81. On or about May 17, 2019, Ms. Ferrigan hand-delivered a timeline of events 

entitled City of Delray Beach Utilities: Cross-Connection Issue Facts to Ms. Gardner-Young. 

The document provided a detailed description of events that occurred in late 2018 involving four 

homeowners that complained about the poor quality of their drinking water at the time. Ex. 2, 

Cross-Connection Issue Facts at 1 – 5. Ms. Ferrigan reported that at the time she was finding 

“major violations” with the reclaimed water program in area 12C. Id. at 6. 

82. Ms. Gardner-Young never responded to Ms. Ferrigan’s timeline. Ferrigan, ECF 

No. 57-1, 84:11-18.

83. On or around January 2, 2020, Ms. Ferrigan was contacted by DOH official Steve 

Garcia. Mr. Garcia called to inquire about a complaint DOH received from a resident who 

wanted to know what happened with the cross-connection issue discovered in late 2018. Ms. 

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Ferrigan confirmed that she was familiar with the issue. Ferrigan, ECF No. 57-1, 100:13-25 –

101:1-19; 109:23-25 – 110:1-22; DOH Reyes, ECF No. 57-8, 26:13 – 27:19. 

84. On January 3, 2020, Ms. Ferrigan emailed Interim City Manager and Fire Chief 

Neal de Jesus that members of the public had been exposed to reclaimed water through 

“illegal/improper cross connections.” She further informed him that the public was not notified 

and that a resident’s complaint to DOH had triggered an investigation. Ms. Ferrigan also stated 

that she was ordered in the past not to communicate with DOH. She concluded by asking Mr. de 

Jesus for protection under the Florida Whistle-Blower’s Act. Ex. 3, Jan. 3 email at 2. Ms. 

Ferrigan’s email was forwarded to City Attorney Lynn Gelin and new City Manager George 

Gretsas. Id. at 1.

85. On or about January 6, 2020, Ms. Ferrigan met at the request of officials from 

DOH for approximately six hours to discuss the problems she had encountered with the City’s 

reclaimed and drinking water systems. Ferrigan, ECF No. 57-1, 113:4-10; 114:11-19.

86. At the conclusion of the meeting with DOH, Ms. Ferrigan was asked to prepare a 

timeline of her experiences with the City’s reclaimed and drinking water systems. She provided 

that timeline around the January 15 – 19, 2020-time frame along with other documentation for 

DOH to review. Id. at 114:20-25 – 115:1-4. All the issues raised by Ms. Ferrigan were being 

discovered for the first time by DOH officials. DOH Reyes, ECF No. 57-8, 28:4-25 – 35:1-20. 

87. The timeline Ms. Ferrigan provided to DOH was twenty-nine pages. It covered 

issues that arose with the City’s reclaimed water program from 2018 through early 2020. Ex. 4, 

Christine Ferrigan Timeline.

88. In addition to raising concerns about the reclaimed water system and the 

contamination of drinking water, Ms. Ferrigan also worked with the public interest group Public 

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Employees for Environmental Responsibility (PEER) to reveal that the City’s water was 

contaminated with substances are sometimes collectively referred to as PFAS. Ms. Ferrigan 

assisted PEER in obtaining a samples that led to the disclosure in October 2020 that the City’s 

water was contaminated. Ferrigan, ECF No. 57-1, 133:23-25 – 139:1-9. 

89. On October 26, 2020, PEER publicly released the PFAS test results for the 

Delray Beach water system. See, Alarming PFAS Levels in Delray Beach Drinking Water

published at https://peer.org/alarming-pfas-delray-beach-drinking-water/. 

90. City Utilities Director Hassan Hadjimiry learned that Ms. Ferrigan obtained the 

sample that was used by PEER to report that the City’s water was contaminated. Hadjimiry, ECF 

No. 57-2, 166:18-25-167:1. 

91. The revelation of PFAS contamination led to the involvement of DOH and a 

recommendation that the City test quarterly to monitor PFAS contamination levels. Ex. 5, 

October 13, 2021 letter from DOH to Mr. Hadjimiry. 

92. At present, the PFAS levels in the City’s water system exceed the current EPA 

health advisory levels. DOH Reyes, ECF No. 57-8, 71:14-25 – 73:1-3. 

93. In February 2020, Ms. Ferrigan reached out to OIG because she was concerned 

that she would be fired because of her disclosures regarding the reclaimed water program. Ms. 

Ferrigan asked OIG to provide her with whistleblower status. Ferrigan, ECF No. 57-1, 149-150. 

94. On September 25, 2020, OIG determined that Ms. Ferrigan was entitled to 

whistleblower status. Ex. 6, OIG Whistleblower Determination.

95. In a published report issued May 6, 2021, “OIG found evidence that certain City 

staff were aware of at least one report of sickness caused by the drinking water at the time the 

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City falsely reported to FDOH on December 19, 2018 that no reports of sickness or illness had 

been received.” Ex. 7, OIG Report at 2, 7.

96. The OIG Report states that a whistleblower complained “ that the 12C Project 

resulted in prohibited cross-connections and that City officials intentionally concealed from state 

officials that residents were sickened when reclaimed water contaminated the City’s drinking 

water system.” Ex. 7 at 1, 8. 

97. Ms. Ferrigan wrote a response to the findings in the OIG Report. They are 

attached to the Report. Ex. 7, Attachment B.

98. It was well known that Ms. Ferrigan was the person who blew the whistle to OIG. 

Gelin, ECF No. 57-6, 123:18-25 – 124; Ex. 1, Delray Beach (Oris), 38:4-7; Hadjimiry, ECF No. 

57-2, 113:4-25 – 114:1-15.

99. On July 1, 2020, DOH issued a warning letter to the City. Ex. 8, DOH Warning 

Letter. The letter outlined twelve regulatory violations. The letter was issued because “the 

department had already gathered sufficient evidence to document and substantiate that the City 

of Delray Beach was in violation of the Safe Drinking Water Act, specifically pertaining to 

backflow prevention and cross connection control.” Reyes, ECF No. 57-8,62:6-25 – 63:1-12.

100. On March 15, 2021, DOH submitted a Civil Penalty Authorization Memo to the 

Florida Department of Environmental Protection under the Drinking Water Program seeking 

almost $1.8 million in penalties and costs from the City due to its violation of drinking water 

standards. Ex. 9, Civil Penalty Memo. 

101. The memo explicitly refers to the City employee that was contacted by DOH on 

January 3, 2020 and references the timeline she provided. Ex. 9, at 2. The employee being 

referred to was Ms. Ferrigan. DOH Reyes, ECF No. 57-8, 88:6-14; 103:19-22. It was wellCase 9:22-cv-81088-DMM Document 66 Entered on FLSD Docket 02/24/2023 Page 11 of 17
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known that Ms. Ferrigan was the employee/whistleblower who cooperated with DOH’s 

investigation. See, e.g., Gelin, ECF No. 57-6, 96:15-25 – 97:1-16.

102. In discussing the Civil Penalty Authorization Memo, DOH Director of 

Environmental Public Health, Rafael Reyes, described the seriousness of the violations: “[t]he 

department has never seen a situation of this magnitude which actually reflects gross 

negligence.” DOH Reyes, ECF No. 57-8, 90:5-12. Mr. Reyes went on to testify about the 

significance of the violations and the fact that many presented a “major public health threat.” 

DOH Reyes, ECF No. 57-8, 96:19-25 – 99:1-22.

103. On November 12, 2021, DOH issued a Consent Order requiring the City of 

Delray Beach to pay a fine and costs totaling $1,021,193.90. Consent Order, ECF No. 58-3, ¶ 6. 

The Order finds the City violated at least nine (9) regulatory standards concerning its crossconnection program and lists the City’s violations, including that the City “submitted one or 

more false statements.” Consent Order, ECF No. 58-3, ¶ 4(a) – (i). The Consent Order mandates 

a timetable for corrective actions. Consent Order, ECF No. 58-3, ¶ 5.

104. On January 21, 2022, Ms. Ferrigan submitted a written complaint to the City’s 

Human Resources Department asserting that she was being harassed and bullied by Utilities 

Director Hassan Hadjimiry. The complaint raises a particular incident involving a water 

customer who spoke to Mr. Hadjimiry and was threatening to Ms. Ferrigan. Ex. 10, HR 

Complaint. But the complaint also alleges that Mr. Hadjimiry was harassing Ms. Ferrigan 

because of her communications with DOH.

[On] 9-15-20 I contacted DOH to report that in a meeting with Hadjimiry & Magloire (9-11-20) I 

was ordered not to report any history on a location. I explained to Hadjimiry that I was told by 

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DOH to include everything. He was not happy. See email 9-15-20. Hadjimiry has told several 

employees to stay away from me because I am trouble. [Ex. 10, at 1-2]1 

105. On January 26, 2022, Ms. Ferrigan was terminated with no warning or notice. 

Ex. 11, Letter from Terrence Moore to Christine Ferrigan. The letter described the following 

reasons for terminating Ms. Ferrigan, which are refuted by the evidence.

(a) “Due to the reorganization of the Department of Utilities of the City of Delray 

Beach, I have decided to eliminate the position of Utilities Industrial Pretreatment Program (IPP) 

Inspector effective today, January 26, 2022.” There is no evidence that the Pretreatment 

Program was reorganized other than to eliminate Ms. Ferrigan’s position as IPP Inspector. 

(b) “During the tenure of our current Utilities Director, the City has undertaken 

efforts to review and analyze various positions, such as the IPP Inspector, in order to determine 

their effectiveness and overall need. As such, it has been determined that the duties and 

responsibilities of your position can be accomplished by the IPP Administrator.” There is no 

evidence that other positions within the Utilities Department were analyzed and eliminated.2 

Rather, there were positions added. Concerning the assertion that the IPP Administrator can also 

handle the duties on the IPP Inspector, the evidence reveals that claim is false - pretextual.

(i) Paul DeCarolis has been the City’s IPP Administrator for many years. He 

testified that he spends 50-60% of his time doing plan review to determine impact fees. 

DeCarolis, ECF No. 57-5, 20:1-5, 20:22-24. The remaining 40% of his time is spent overseeing 

the tanks department, storage tanks, and the welfare protection program.” Id. at 20:25- 21:1-4. 

1

 See, also, Ferrigan, ECF No. 57-1, 175:13-25 – 179:1-18 (describing the events leading to the complaint and the 

complaint process).

2

 When asked what positions were analyzed, Assistant City Administrator admitted that no position other than Ms. 

Ferrigan’s was reviewed by the City. Oris 28:20-24. 

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(ii) Although Ms. Ferrigan’s position was eliminated, the Utilities Department hired a 

plan reviewer (Joe Ballardo), so that Mr. DeCarolis could go out in the field and do more 

Pretreatment Program inspections. Id. at 43:1-6, 65:21-25. Specifically, Mr. DeCarolis testified 

“we’re an extremely busy City and the director [Mr. Hadjimiry] wants me to concentrate more 

on pretreatment and get away from plan review.” Id. at 66:2-6, 20-25. He further testified that 

Mr. Hadjimiry “wants me to get away from plan review, so I can do what involves with 

pretreatment. That’s inspections, doing proactive and doing – concentrate on more inspections.” 

Id. at 67:10-13. Mr. DeCarolis also testified “I have to train someone then we’re going to start 

back at me doing more inspections.” Id. at 67:17-19. Even before terminating Ms. Ferrigan, Mr. 

Hadjimiry and Mr. DeCarolis had discussions about going back to a more proactive pretreatment 

inspection program. Id. at 68:14-25 – 69:1-22. In fact, before Ms. Ferrigan was terminated, Mr. 

DeCarolis informed Mr. Hadjimiry that he could not do plan reviews and inspections. He could 

not do both jobs. Id. at 72:15-20. Mr. DeCarolis was shocked that Ms. Ferrigan was suddenly 

terminated. He was not consulted about eliminating Ms. Ferrigan’s position. Id. at 74:6-25 –

75:1-2. 

(c) “[T]he COVID-19 pandemic has had a significant budgetary impact on the City 

and has prompted the need to make serious budgetary reductions and staffing changes within 

every department. The elimination of your position is a necessary result of these changes . . .” 

The claim that eliminating Ms. Ferrigan’s position was part of an effort to “make serious 

budgetary reductions” was also false.

(i) The City provided Assistant City Manager Jeffrey Oris to testify on behalf of the City 

concerning the reasons for Ms. Ferrigan’s termination among other issues. Ex. 1, Delray Beach 

(Oris), 1:13-25.

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(ii) Financial documents for the fiscal year involving Ms. Ferrigan’s position 

elimination were reviewed with Mr. Oris. He acknowledged that the City financial report was 

favorable. Id. at 105:16-25 – 111:14. Mr. Oris admitted that the City had $342 million more in 

assets than liabilities. Id. at 111:1-14. Mr. Oris admitted that Ms. Ferrigan’s position was not 

eliminated to address a budget deficit. Id. at 113:1-17. He also admitted that Ms. Ferrigan’s 

position was approved in the budget for the fiscal year. Id. at 114:11-22. 

 106. On February 25, 2022, Complainant’s counsel informed City Attorney Lynn 

Gelin that she intended to contest her unlawful termination. The letter also put the City on notice 

that evidence that may be relevant to Ms. Ferrigan’s claims should be preserved. Ex. 12, email 

transmitting preservation letter ; Ex. 13, evidence preservation letter. 

 107. Six days later, on March 3, 2022, the City rejected Ms. Ferrigan’s application for 

the open Environmental Resources Compliance Manager position. Ex. 14, Email from Human 

Resources. The City failed to credit her extensive training and experience over twenty-eight 

years in environmental programs. The City intentionally ignored her experience in its 

assessment of her application, which is contrary to its policy of considering experience in lieu of 

education requirements. Ex. 1, Delray Beach (Oris), 47:8-25 – 48:1-3. Mr. Hadjimiry, who 

knew Ms. Ferrigan’s experience very well told Mr. Oris that she did not have the minimum 

qualifications and was not forwarded to him for consideration. Ex. 1, Delray Beach (Oris),

48:16-25. 

________/s/Rachael Flanagan________ 

Leslie M. Kroeger (Florida Bar: 989762) 

Rachael Flanagan (Florida Bar: 1018544) 

Cohen Milstein Sellers & Toll, PLLC 

11780 US Highway Suite 500 

Palm Beach Gardens, FL 33408 

Telephone: (877) 515 7955 

Fax: (561) 515 1401 

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Email: lkroeger@cohenmilstein.com 

rflanagan@cohenmilstein.com 

 Richard E. Condit (pro hac vice) 

Cleveland Lawrence III (pro hac vice) 

C. Ezra Bronstein (pro hac vice) 

Mehri & Skalet, PLLC

2000 K Street, NW, Suite 325 

Washington, DC 20006 

Tel.: (202) 822-5100/Fax: (202) 822-4997 

Email: rcondit@findjustice.com 

clawrence@findjustice.com 

ebronstein@findjustice.com 

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CERTIFICATE OF SERVICE

I, Rachael Flanagan, hereby certify that on February 23, 2023, I served the foregoing upon the 

below listed counsel for the Defendants via ECF: 

Daniel L. Abbott (Florida Bar: 767115) 

Brett J. Schneider (Florida Bar: 12443) 

Samantha Williams (Florida Bar: 107117) 

Weiss Serota Helfman Cole & Bierman 

200 East Broward Blvd., Suite 1900 

Ft. Lauderdale, FL 33301 

Telephone: (954) 763-4242 

Fax: (954) 764-7770 

Email: dabbott@wsh-law.com

bschneider@wsh-law.com 

ssoto@wsh-law.com

________/s/Rachael Flanagan________ 

Rachael Flanagan (Florida Bar: 1018544) 

Cohen Milstein Sellers & Toll, PLLC 

rflanagan@cohenmilstein.com 

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