Exhibit 10

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 1 of 37
4/20/2021 Gmail - Fwd: Reminder - Training 

Gmail 

Fwd: Reminder -Training 

Labriola, John F. (Office of the Chair) <John.Labriola@miamidade.gov> 

To: "jflabriola@gmail.com" <jflabriola@gmail.com> 

From: Lopez, Isidoro (Office of the Chair) <lsidoro.Lopez@miamidade.gov> 

Sent: Monday, March 29, 2021 12:24 PM 

To: Labriola, John F. (Office of the Chair) <John.Labriola@miamidade.gov> 

John Labriola <jflabriola@gmail.com> 

Mon, Mar 29, 2021 at 12:54 PM 

Cc: Cuellar, Arleene (HR) <Arleene.Cuellar@miamidade.gov>; Vega, Olga R. (Office of the Chair) 

<Olga.Vega@miamidade.gov> 

Subject: RE: Reminder - Training 

Hi John, 

Your claim of distress is self-imposed. All you had to do last Friday March 26 was send an email to the HR Department 

with a proposed date and time of your choice for a virtual training session regarding County policy to be conducted while 

you are being paid. That was a simple task that you were ordered to perform and yet you still have not complied. The 

order did not mention or demand that you surrender your conscience or your beliefs as you mention in your email. 

The County's anti-discrimination policy in Implementing Order 7-45 was adopted unanimously by the Board of County 

Commissioners in 2019. That Board policy is the subject of the training you have been ordered to complete. The order 

for you to be trained while on duty being paid regarding the Board's anti-discrimination policy is not harassment or 

discrimination. It is the opposite of that. The purpose of the training is to prevent unlawful discrimination and unlawful 

harassment. Employers all over the Country train employees on such anti-discrimination policies. 

John, whether you disagree with the DAR is not the issue today. Right now, what needs to happen is you need to send 

an email by 4 pm today to schedule this training in the manner required in the March 25 email you received. If you do 

not, you may be dismissed from employment since this email is now your fourth chance in writing to comply with a simple 

direct order to send an email while on duty being paid. 

Once again, I encourage you to comply today. 

Kind Regards, 

I. Lopez 

Isidoro R. Lopez, Esq. 

Chief of Staff 

https://mail.google.com/mail/u/0?ik=1 b1 eae8ad5&view=pt&search=all&permmsgid=msg-f%3A 1695586061718856641 &simpl=msg-f%3A 16955860617... 1/3 

MDC_000001

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 2 of 37
Below you will find a list of all online classes. Please read the instructions carefully before starting

class.

Home (/global/home.page) > Human Resources (/global/humanresources/home.page) > e-Learning

e-Learning

Share:  

Disaster Assistance Employee (DAE)

Instructions

Ethics Training for Employees

Interviewing Made Easy

Management/Professional Performance Appraisal

Keys To Unlocking County Services

Know Your County Government

Diversity Matters

MDC_000002

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 3 of 37
Employee Protection Ordinance

Plan to Survive an Active Shooter Event

Resume Writing

Service Excellence

Stress Management

Time Management

Valuing Cultural Diversity

Violence in the Workplace





Implementing Order 7-45: Discrimination, Harassment and Retaliation

Implementing Order 7-45 was approved by the Board of County Commissioners in December 2019,

replacing previous anti-discrimination policies. This online video will ensure that all Miami-Dade

County employees understand the County's policy related to these topics, their protections and their

responsibilities.

Anti-Discrimination Policy (AO 7-45) (https://miamidade.granicus.com/MediaPlayer.php?

publish_id=92988709-b8ab-11eb-8549-0050569183fa)

Anti-Discrimination Policy Quiz

(https://hrprd.miamidade.gov/psp/HRPRD/EMPLOYEE/HRMS/c/MDC_CUSTOM_MENU.MDC_TRN_STU_TEST.GBL

&PAGE=MDC&)

MDC_000003

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 4 of 37










Interviewing Made Easy Course Material

(https://www.miamidade.gov/humanresources/library/elearning-interviewing.pdf)

Management/Professional Performance Appraisal Course Material

(https://www.miamidade.gov/humanresources/library/elearning-performance-appraisal.pdf)

Know Your County Government Course Material

(https://www.miamidade.gov/humanresources/library/know-your-county-government.pdf)

Resume Writing Course Material

(https://www.miamidade.gov/humanresources/library/elearning-resume-writing.pdf)

Service Excellence Course Material

(https://www.miamidade.gov/humanresources/library/elearning-service-excellence.pdf)











Stress Management Course Material

(https://www.miamidade.gov/humanresources/library/elearning-stress-management.pdf)

Time Management Course Material

(https://www.miamidade.gov/humanresources/library/elearning-time-management.pdf)

Time Management Balance Wheel

(https://www.miamidade.gov/humanresources/library/elearning-time-management-balancewheel.pdf)

Time Management Self-Quiz (https://www.miamidade.gov/humanresources/library/elearningtime-management-self-quiz.pdf)

Valuing Cultural Diversity Training

(https://www.miamidade.gov/humanresources/library/elearning-cultural-diversity.pdf)

Related Documents

Was this page helpful? Yes No

Human Resources Training Staff

305-375-2473

PHONE NUMBER(S)

Arleene Cuellar, Director (/global/government/biographies/human-resources.page)

HUMAN RESOURCES (/GLOBAL/HUMANRESOURCES/HOME.PAGE)

MDC_000004

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 5 of 37
Stephen P. Clark Center

111 NW 1st Street,

21st Floor

Miami, FL 33128

305-375-1589 (tel:305-375-1589)

Contact Us (/global/humanresources/contact.page)

Request Public Records (/global/publicrecords/search.page)

 (https://www.facebook.com/MiamiDadeHumanResources/)

 (https://twitter.com/miamidadehr)  (https://www.instagram.com/miamidadehr)

 (https://www.linkedin.com/company/miami-dade-human-resources-department)

MDC_000005

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 6 of 37
Human Rights & 

Fair Employment Practices

Division

Overview of the County’s 

Anti-Discrimination Policy

1

February 2021

MDC_000006

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 7 of 37
Objective

2

February 2021

• To ensure all County employee’s understand 

and adhere to the County’s antidiscrimination policy and complaint reporting 

procedures.

MDC_000007

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 8 of 37
What HRFEP Does

3

February 2021

Intake and 

investigate 

internal & 

external 

discrimination 

complaints

Provide

Mediation 

services

Provide 

specialized 

training and 

participate in 

outreach 

activities

Diversity 

Management & 

PolicyDevelopment

MDC_000008

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FEPLs

4

February 2021

• Notifies HRFEP of the complaint

• Takes all complaints seriously

• Tries to resolve the issues internally

• HRFEP provides support to FEPLs

• FELP can forward a complaint to HRFEP for 

investigation

• HRFEP can refer complaints based on unfair 

practices to FEPLs for response

• List of FEPLs for each department is available at 

www.miamidade.gov/humanrights/library/depart

ment-liaisons-updated.pdf

Fair Employment Practices Liaisons:

MDC_000009

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Miami-Dade County Policy

5

February 2021

Implementing Order (IO) 7-45: Equal Employment 

Opportunity Policy Prohibiting Unlawful 

Discrimination, Harassment or Retaliation

http://www.miamidade.gov/aopdfdoc/aopdf/pdffiles/

IO7-45.pdf

The policy of Miami-Dade County is

to ensure that all employees are able

to enjoy a work environment free

from all forms of discrimination,

including harassment and retaliation

MDC_000010

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Protected Classes

6

February 2021

• race

• sex

• color 

• national origin

• religion

• retaliation

• age

• disability

• ancestry 

• marital status

• pregnancy

• sexual orientation, 

• gender identity or 

expression

• status as a victim of 

domestic violence, or 

• the exercise of their 

constitutional or 

statutory rights 

MDC_000011

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Negative Impact

7

February 2021

• We have a moral and legal duty to stop all 

forms of discrimination

• It is Bad for Business!

– Direct financial costs associated with 

defending EEOC charges and lawsuits

– Adverse impact on health & workplace 

productivity of the target and the 

coworkers who witness the behavior

– Job Turnover 

– Harm to the County’s Reputation

MDC_000012

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Discrimination

8

February 2021

• Disparate Treatment

• Disparate Impact

Discrimination is the practice of unfairly

treating a person or group of people

differently from another person or groups

of people.

There are four types of illegal discrimination:

• Harassment

• Retaliation

MDC_000013

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Harassment – Unlawful vs. Awful

9

February 2021

• Verbal or physical conduct

• Demeans, stereotypes, or shows hostility 

based on a protected class

• Unwelcome

• Can be one serious incident or several small 

incidents over time

• Harassers include supervisors, co-workers, 

or non-employees

• Intent is not a defense

Unlawful:

MDC_000014

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Harassment – Unlawful vs. Awful

10 February 2021

• Inappropriate behavior

• Unwelcome and offensive

• Not related to a protected class

• Isolate or infrequent

• Can be a violation of policy even though it is 

not unlawful behavior

Awful:

MDC_000015

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Distinction Between Harassment and 

Legitimate Management Actions

11 February 2021

• Management must be able to make 

certain decisions and take action that may 

negatively impact individual employees

• If there is a legitimate reason for the 

action – this is not harassment

MDC_000016

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Sexual Harassment

12 February 2021

• Unwelcome sexual advances

• Request for sexual favors

• Sex based verbal or physical acts

• Made a term or condition of employment

• Basis for employment decisions

• Can involve individuals of the same or 

different genders

• Again, intent is not a defense

MDC_000017

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Retaliation

13 February 2021

• Complained about unlawful discrimination, 

harassment or retaliation

• Opposed unlawful discrimination, 

harassment or retaliation

• Participated in an internal investigation or 

lawsuit, including as a witness

• Associated with an individual who engaged 

in a protected activity

Adverse actions taken against an employee 

because they:

MDC_000018

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What Else is Covered

14 February 2021

• The policy extends to conduct that 

occurs at any location that could 

be reasonably regarded as an 

extension of the workplace, 

including during travel, training 

conference, in a vehicle, or any 

other location or facility where 

county government business is 

being conducted

MDC_000019

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Social Media

15 February 2021

• It also extends to 

inappropriate, discriminatory 

or harassing posts or 

communication on personal 

social media.

• Includes Social Networks (Facebook, Twitter, 

LinkedIn), Community Blogs (Tumblr, 

WordPress), Discussion forums (Reddit, Quora), 

Review networks (Yelp, Trip Advisor), Media 

Sharing (Instagram, Snapchat, YouTube), etc.

MDC_000020

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Reporting

16 February 2021

If you experience (or witness) a policy violation:

•Tell them their behavior is offensive 

and ask them to stop; if they don’t, 

report it or file a complaint

• Any employee witnessing this conduct 

is strongly encouraged to report it

• If you are a supervisor, reporting is MANDATORY!!

• Investigations are discrete and confidential

• Prompt and effective steps are taken to stop the 

behavior, including corrective action depending on 

the circumstances

MDC_000021

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Bystander Intervention

17 February 2021

• Bystander intervention is safe and positive options 

that may be carried to prevent or intervene when 

there is a risk of discriminatory behavior

• We have all been bystanders in our lives, and we will 

all be in situations where we are bystanders in the 

future. 

• Any employee who witnesses discriminatory, 

harassing or retaliatory conduct or becomes aware 

of such conduct or a violation of this policy is strongly 

encouraged to immediately report this information to 

their departmental FEPL and/or HRFEP.

You can make a difference!

MDC_000022

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Complaint Filing Methods

18

Complaints may be submitted to HRFEP by any of 

the following methods by:

• visiting our office on the 21st floor

• fax at (305) 375-2114

• e-mail at ofep@miamidade.gov

• completing an on-line complaint form available at 

http://www.miamidade.gov/humanrights

The complaint must be submitted in writing.

February 2021

MDC_000023

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Anonymous Complaints

19 February 2021

• Anonymous complaints can be filed through 

web-based reporting system at 

www.miamidade.gov/humanrights

• Will be investigated to greatest extent 

possible

• All complaints are kept confidential to the 

extent possible 

Anonymous complaints are accepted:

MDC_000024

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 25 of

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Non-Employee Complaints

20 February 2021

• Includes customers, visitors, lobbyist, contractors, 

vendors, board members, volunteers, custodians, 

security

• Similar protections are given to non-employees when 

they are the victims

• Protects county employees from inappropriate 

behavior from non-employees

• Can result in notification to their employer, removal, 

exclusion, protective orders, etc.

Made by or against Non-Employees:

MDC_000025

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Complaint Resolutions

21 February 2021

• No Violation – the behavior did not violate this policy

• Inappropriate Behavior Not Rising to the Level of a 

Violation – the behavior was inappropriate and 

unprofessional but did not violate this policy

• Violation – HRFEP, the HR Director, and Labor 

Relations will make recommendations to remedy the 

effects and ensure it is not repeated

Possible Outcomes of the Investigation:

MDC_000026

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Appeals

22 February 2021

• Request must be received within 15 days from receipt 

of determination.

• Request must be submitted in person, via certified 

mail or via email. Requests via fax or telephone are 

not accepted.

• Employees covered by a CBA complaining about 

discipline, may not be entitled to this type of appeal. 

• Contact Labor Relations & Compensation at 

(305)375-4171 for information regarding disciplinary 

action appeals and/or the career service grievance 

process.

Right to Appeal the Outcome:

MDC_000027

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External Agencies

23 February 2021

EEOC

Miami District Office 

100 S.E. 2nd Street, 

Suite 1500 

Miami, FL 33131

Ph: (305) 808-1745

www.eeoc.gov

Employees also have the right to file with 

outside agencies:

FCHR

4075 Esplanade Way, 

Room 110

Tallahassee, FL 32399 

Ph: (800) 342-8170

fchr.myflorida.com

MDC_000028

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Mandatory Training

24 February 2021

• All County employees are required to take training 

regarding IO 7-45

• HRFEP also facilitates specialized training programs 

for departments, including:

• Workplace Civility and Respect

• Tackling Unconscious Bias

• Tackling Racial Bias

• Preventing Sexual Harassment 

• Preventing Harassment 

• Disability Etiquette

• LGBTQ Awareness

Specialized Training Programs:

MDC_000029

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Employee & Department 

Responsibilities

25 February 2021

Think before you act...model respectful, 

professional conduct

• If you become aware that you have offended someone:

– Start with an apology 

– Stop the offensive behavior immediately

• If you are a victim or a witness, take steps to stop the 

offensive behavior:

– Understand the County’s policy

– Report the conduct to Supervisor/ Manager/ DPR/ 

Fair Employment Practices Liaison or HRFEP

MDC_000030

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Contact Information

Human Resources Department

Human Rights and Fair Employment Practices Division

111 NW 1 Street, 21st Floor

Miami, FL 33128

(305) 375-2784

(305) 375-2114 fax

ofep@miamidade.gov

www.miamidade.gov/humanrights

26 February 2021

MDC_000031

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 32 of

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Human Resources Department

Official Student Transcript

LABRIOLA, JOHN Emp. Id. 210098 

NEO NEW EMPLOYEE ORIENTATION Certification Pending

ETHFEOL ETHICS TRAINING FOR EMPLOYEES 8/21/2019 Core

KYCG-71 KNOW YOUR COUNTY GOVERNMENT ONLINE 7/24/2013 Core

SE-5 SERVICE EXCELLENCE ONLINE 7/24/2013 Core

ETHN5-3 ETHICS PHASE V ONLINE 7/24/2013 Core

Classes

NEO NEW EMPLOYEE ORIENTATION 7/23/2013

OD ORGANIZATIONAL DEVELOPMENT 7/2/2007

ETHN5-2 ETHICS PHASE V NEW HIRE-CLASS 5/31/2006

NEKK NEW EMPLOYEE ORIENTATION - KNOW YOUR COUNTY G 5/31/2006

NEK1 NEW EMPLOYEE ORIENTATION MORNING 5/30/2006

NEK2 NEW EMPLOYEE ORIENTATION AFTERNOON 5/30/2006

OnLine Classes

EPO EMPLOYEE PROTECTION ORDINANCE 9/22/2017

KYCG-71 KNOW YOUR COUNTY GOVERNMENT ONLINE 7/24/2013

4/24/2023 Page 1 of 1

MDC_000032

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 33 of

37
1

From: Orlando Gonzales <orlando@save.lgbt> 

Sent: Friday, March 5, 2021 3:09 PM 

To: New, Erin (HR) 

Cc: Justin Klecha; Cava, Daniella Levine (Office of the Mayor); Cervone, Johanna (Office of the Mayor); Higgins, 

Danielle Cohen (DIST8); Zea, Natalia (DIST8); Clayton, Jeve (DIST8); Higgins, Eileen (DIST5); Fernandez, Maggie 

M. (DIST5); Cohen, Rachel (DIST5); District10; District2 (DIST2); gerardp@miamidade.gov; District11;

Bustamante, Ana (DIST11); District12; Gomez, Andrenella (DIST12); Justin Funck; District3; District9; District1;

District7; Fernandez, Alejandro J. (DIST6); District6; Aguirre, Betty (DIST6); District 13; District4; Needelman,

Heather

Subject: Miami Herald article entitled “A Miami-Dade government employee wrote a slur-laden tirade against

transgender people”

EMAIL RECEIVED FROM EXTERNAL SOURCE 

Dear Director New, 

Kindly find my letter concerning the Miami Herald article entitled “A Miami-Dade government employee 

wrote a slur-laden tirade against transgender people” attached. 

Many thanks in advance for your time and attention to this matter.

Orlando

-- 

 M m m Orlando Gonzales (he, el, they)

Executive Director at SAVE Inc / SAVE Foundation

Address 1951 NW 7th Avenue Suite 600, Miami, FL 33136

Phone 305-751-7283 Mobile 305-968-8522 

Email orlando@save.lgbt 

Website http://www.save.lgbt/ 

M

m

m 

M

m

m 

M

m

m 

MDC_000033

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MDC_000034

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 35 of

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MDC_000035

Case 1:22-cv-23196-PCH Document 46-10 Entered on FLSD Docket 08/16/2023 Page 36 of

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 MEMORANDUM 

Date: May 4, 2021

To: Arleene Cuellar, Director 

 Human Resources Department 

 

From: Erin A. New, Division Director 

 Human Rights & Fair Employment Practices 

 

 Subject: John Labriola (BCC) - Complaint Investigative Findings 

On March 5, 2021, the Human Rights & Fair Employment Practices Division (HRFEP) of the 

Human Resources Department received a written complaint from Orlando Gonzales, Executive 

Director of SAVE Inc., in which he alleged that John Labriola, Media Aide, Board of County 

Commissioners (BCC), engaged in discriminatory and harassing conduct based on sexual 

orientation, gender identity and gender expression in an online article he wrote for a section called

“UNcensored” in the March 2021 edition of “Sophie’s Voice,” a newsletter published by Sophie’s 

Publishing House Inc. Specifically, Mr. Gonzales alleged that Mr. Labriola used offensive and 

derogatory slurs toward the LGBTQ+ community in the article, in violation of the County’s Human 

Rights Ordinance and Implementing Order 7-45. Mr. Gonzales included a link to an article 

published in the Miami Herald on March 5, 2021, titled, “A Miami-Dade government employee 

wrote a slur-laden tirade against transgender people.”

On March 15, 2021, HRFEP received another complaint against Mr. Labriola from a resident 

named Jacob Joseph, which was submitted on the Human Resources Department’s Facebook 

page. Mr. Joseph’s complaint included a screenshot of a public Facebook post Mr. Labriola made 

on his personal Facebook page, in which he criticized the Miami Herald’s depiction of his 

“Sophie’s Voice” article and stated, among other things, that “there is no such thing as 

transgender.”

As part of HRFEP’s review of this complaint and in order to ensure that Mr. Labriola was not 

engaging in this type of conduct in the workplace, all of the employees that work with Mr. Labriola 

in BCC Media Division were interviewed. Overall, our review did not find any evidence to establish 

that Mr. Labriola engaged in any harassing or discriminatory behavior based on any protected 

characteristic within the workplace. However, the findings revealed that Mr. Labriola’s use of 

extremely inappropriate and offensive language in the newsletter article did constitute a violation 

of County policies, including Implementing Order 7-45. 

Records show that on March 5, 2021, Mr. Labriola was issued a Disciplinary Action Report and a 

3 day suspension in connection with this incident. In addition to the suspension, the DAR directed 

Mr. Labriola to register for diversity training within 7 days of receipt. Due to his failure to register 

for the required training, Mr. Labriola’s employment with the County was terminated on April 13, 

2021. 

Accordingly, HRFEP has determined that the BCC has taken appropriate action to address Mr. 

Labriola’s violation of County policies and no further action is warranted. 

Please feel free to contact me if you have any questions. 

 

MDC_000036

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