1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

ALEJANDRO ESPINOZA, CASE NO.

 Plaintiff,

vs.

QUAY EYEWEAR, INC., Foreign for Profit Corporation

D/B/A QUAY

Defendant,

____________________________________________/

COMPLAINT FOR DECLARATORY AND

INJUNCTIVE RELIEF, AND JURY TRIAL DEMAND

 Plaintiff, ALEJANDRO ESPINOZA, through undersigned counsel, sues Defendant,

QUAY EYEWEAR, INC., a foreign corporation d/b/a QUAY (hereinafter referred to as 

“QUAY”), for declaratory and injunctive relief, and damages, and alleges as follows:

1) This action is brought under Title III of the Americans with Disabilities Act (“ADA”), that 

is codified in 42 U.S.C. §§12181-12189. 

2) This action is also brought pursuant to 28 C.F.R. Part 36.

3) This Court has jurisdiction over this case based on federal question jurisdiction, as provided 

in 28 U.S.C. §1331 and the provisions of the ADA.

4) Furthermore, because this Court has jurisdiction over the ADA claim, the Court has 

supplementary jurisdiction over Plaintiff’s common law tort claim pursuant to 28 U.S.C. §1367.

5) Plaintiff is sui juris, and she is disabled as defined by the ADA and ADA Amendments Act 

of 2008, 42 U.S.C. §12101 (“ADAAA”).

6) Defendant, QUAY, is a foreign limited liability company authorized to do business and 

doing business in the State of Florida.

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 1 of 18
2

7) Defendant, QUAY, is a company that sells men’s and women’s sunglasses, glasses, jewelry 

and accessories. There is a retail location in Miami-Dade County. 

8) Plaintiff seeks declaratory and injunctive relief pursuant to 28 U.S.C. §§ 2201 and 2202.

9) Plaintiff desires to prevent discrimination and demands equal access to Defendant’s 

internet website to purchase sunglasses and a cleaning kit.

10) Plaintiff also seeks declaratory and injunctive relief for trespass against the Plaintiff’s 

computer. The computer is Plaintiff’s personal property, and a claim for trespass attached to same.

11) The Defendant is also liable for compensatory damages to Plaintiff as a result of the 

trespass to Plaintiff’s personal property.

12) The remedies provided under common law for trespass are not exclusive, and same may 

be sought in connection with suits brought under the ADA.

13) Venue is proper in the Southern District of Florida, Miami-Dade Division, since all events, 

actions, injuries, and damages complained of herein occurred in the Southern District of Florida.

14) Furthermore, Plaintiff is a resident of Miami-Dade County which falls within the Miami 

Division of the Southern District of Florida.

15) At all relevant times, Plaintiff is and was visually impaired and has Leber Congenital 

Amaurosis since birth that substantially impairs Plaintiff’s vision.

16) Plaintiff’s visual impairment interferes with his day-to-day activities and causes limitations 

in visualizing their environment. As such, Plaintiff is a member of a protected class under the 

ADA, 42 U.S.C. § 12102(1) - (2), the regulations implementing the ADA set forth at 28 CFR §§ 

36.101, et seq., and in 42 U.S.C. 3602, §802(h). 

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 2 of 18
3

17) Plaintiff regularly uses the computer, but she needs the assistance of special software for 

visually impaired persons. The software that she uses is screen reader software that is readily 

available commercially.

18) Defendant is a private entity which owns and operates retail locations. The stores are open 

to the public, and each of Defendant’s locations is defined as a “public accommodation" within 

the meaning of Title III of the ADA because Defendant is a private entity which owns and/or 

operates “[A] bakery, grocery store, clothing store, hardware store, shopping center, or other sales 

or rental establishment,” per 42 U.S.C. §12181(7)(E) and 28 C.F.R. §36.104(2).

19) Defendant’s website is a place of public accommodation per 42 U.S.C. Section 

12181(7)(E) because it’s an extension of Defendant’s brick and mortar stores. The public is able 

to, among other things, view the products available at defendant’s locations, purchase sunglasses, 

glasses, jewelry and accessories through defendant’s website, create an account, register to track 

orders, join the loyalty program, learn the story behind Defendant’s brand, and get exclusive 

offers. 

20) Since the Defendant’s website is a public accommodation, it must comply with the 

requirements of the ADA. The website cannot discriminate against individuals with disabilities. 

21) Plaintiff is a customer of Defendant who is and was interested in purchasing sunglasses 

through Defendant’s website and at Defendant’s stores and visiting Defendant’s brick and mortar 

locations. 

22) Plaintiff is not able to visit the physical locations without the assistance of a family member 

or caretaker, so the ability to purchase merchandise on Defendant’s website for delivery to his 

home is important to his as an alternative when she is not able to visit the Defendant’s stores.

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 3 of 18
4

23) The website also services Defendant’s physical stores by providing information on its 

brand, track orders, join the loyalty program, get exclusive offers, and other information that 

Defendant is interested in communicating to its customers about its physical locations.

24) Since the website allows the public the ability to view the products available at defendant’s 

locations, purchase sunglasses, glasses, jewelry and accessories, through defendant’s website,

create an account, register to track orders, join the loyalty program, learn the story behind 

Defendant’s brand, and get exclusive offers, the website is an extension of, and gateway to, 

Defendant’s physical stores. By this nexus, the website is characterized as an intangible service, 

privilege and advantage provided by a place of public accommodation as defined under the ADA, 

and thus an extension of the services, privileges and advantages made available to the general 

public by Defendant through its retail brick and mortar stores.

25) Because the public can view and purchase Defendant’s merchandise that is also offered for 

sale by Defendant at its physical stores, create an account, register to track orders, join the loyalty 

program, learn the story behind Defendant’s brand, and get exclusive offers. 

the website is an extension of and gateway to the physical stores, which are places of public 

accommodation pursuant to 42 U.S.C. § 12181(7)(E). As such, the website, as an intangible 

service, privilege and advantage of Defendant’s brick and mortar locations, must be fully 

accessible and in compliance with the ADA, must not discriminate against individuals with 

disabilities, and must not deny full and equal enjoyment of the same services, privileges and 

advantages afforded to the general public both online and at the physical locations.

26) At all times material hereto, Defendant was and still is an organization owning and 

operating the website located at https://www.quayaustralia.com/. Since the website is open through 

the internet to the public as an extension of the retail stores, by this nexus the website is an 

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 4 of 18
5

intangible service, privilege and advantage of Defendant’s brick and mortar locations, and 

Defendant has subjected itself and the associated website it created and maintains to the 

requirements of the ADA.

27) Plaintiff is and/or has been a customer who is interested in patronizing, and intends to 

patronize, Defendant’s physical stores, and purchase Defendant’s merchandise, sign up for 

Defendant’s newsletter and create an account through the website and at Defendant’s physical 

stores.

28) The opportunity to shop Defendant’s merchandise from his home is an important 

accommodation for Plaintiff because traveling outside of the home as a visually disabled individual 

is often a difficult, hazardous, frustrating, confusing, and frightening experience. Defendant has 

not provided its business information in any other digital format that is accessible for use by blind 

and visually disabled individuals using screen reader software.

29) Like most consumers, Plaintiff accesses numerous websites at a time to compare 

merchandise and prices. Plaintiff may look at several dozens of sites to compare features and 

prices.

30) During the months of June and July, 2022, Plaintiff attempted on several occasions to 

utilize the website to browse through the merchandise to educate himself as to the merchandise 

and with the intent to make a purchase through the website or at one of Defendant’s physical stores.

31) Places of public accommodation are not just brick-and-mortar structures. The United 

States Department of Justice and the binding case law increasingly recognize that private entities 

are providing goods and services to the public through websites that operate as places of public 

accommodation under Title III.

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 5 of 18
6

32) Defendant is required to make reasonable accommodations to its websites for individuals 

with disabilities to allow them to participate in web-based promotions and obtain goods or services 

via the Internet just as sighted persons are able to do.

33) Plaintiff utilized Chrome Vox (“Screen Reader Software”) to attempt to purchase clothing 

on Defendant’s website. However, the Plaintiff was not able to freely and fully use Defendant’s 

website because it contains access barriers that make it inaccessible to persons with disabilities, 

and for which there is no reasonable accommodation for the Plaintiff.

34) A person who can see can enjoy the benefits and privileges provided by Defendant’s 

website that include, but are not limited to viewing the products available at defendant’s locations, 

purchasing sunglasses, glasses, jewelry and accessories, through defendant’s website, create an 

account, register to track orders, join the loyalty program, learn the story behind Defendant’s 

brand, and get exclusive offers. 

35) A person who cannot see, like the Plaintiff in this case, cannot go to Defendant’s website 

and avail themselves of the same privileges. Thus, the Plaintiff has suffered discrimination due to 

Defendant’s failure to provide a reasonable accommodation for Plaintiff’s disability.

36) The Department of Justice has provided useful guidance regarding website accessibility 

under the ADA, and the binding and persuasive case law in this district has applied the Web 

Content Accessibility Guidelines (“WCAG”) 2.0 or 2.1 to determine accessibility. 

37) Defendant’s website does in fact fail the following WCAG 2.0-AA Compliance standards 

and it does not provide sufficient alternatives to serve the equivalent purpose:

Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: The options within the ‘Combo Box’ for selecting a country/region on the 

checkout page are not labeled in and audible format as the user cycles through them 

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 6 of 18
7

(video). They should work like this example shown on this page. In instances when the 

options presented in the dropdown are unfamiliar to the user, not having them read out 

loud as one cycles through them makes selecting the desired option difficult – one must 

select each individual option to get it read.

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

Violations that make it difficult to navigate through the site 

Violation: Focusable components do not receive focus in an order that preserves meaning 

and operability.

Note/Proof: After loading a product page, the focus is shifted to the reviews section at the 

bottom of the page. User has to navigate back up the page, and through a carousel to get 

to the section where the options for selecting and adding to cart the desired product are 

available (video).

Applicable WCAG 2.1 Standard at Issue: Standard 2.4.3 Focus Order (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 2.4.3 Focus Order.

Violation: Focusable components do not receive focus in an order that preserves meaning 

and operability.

Note/Proof: Within the product details, when a user activates the size guide button, the 

navigation sequence takes them to a completely new page. The user has no way within 

that page to navigate back to the product page that they were previously viewing. 

Operability is not preserved (video).

Applicable WCAG 2.1 Standard at Issue: Standard 2.4.3 Focus Order (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 2.4.3 Focus Order.

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 7 of 18
8

38) Furthermore, Defendant’s website does not contain accessibility assistance that would 

direct a visually impaired person like the Plaintiff to someone who she can contact for assistance, 

questions, or concerns.

39) Thus, Defendant has not provided full and equal enjoyment of the services, facilities, 

privileges, advantages, and accommodations provided by and through the website, in 

contravention of the ADA. 

40) On information and belief, Defendant is, and at all times has been, aware of the barriers to 

its website which prevent individuals with disabilities who are visually impaired from 

comprehending the information within same, and is also aware of the need to provide access to all 

persons who visit its site. 

41) Plaintiff has no plain, adequate, or complete remedy at law to redress the wrongs alleged 

in this Complaint, such that this suit for declaratory judgment and injunctive relief is his only 

means to secure adequate and complete redress from Defendant’s discriminatory practices in 

connection with use of its website.

42) Notice to Defendant is not required because of Defendant’s failure to cure the violations. 

43) Enforcement of Plaintiff’s rights under the ADA is right and just pursuant to 28 U.S.C. §§ 

2201 and 2202.

44) Plaintiff has retained the undersigned attorneys to represent him in this case, and has agreed 

to pay them a reasonable fee for their services.

COUNT I – VIOLATION OF THE ADA

45) Plaintiff realleges paragraphs 1 through 44 as if set forth fully herein.

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 8 of 18
9

46) Defendant owns and operates the https://www.quayaustralia.com/ website, and is a public 

accommodation subject to the ADA pursuant to 42 U.S.C. §12181(7)(E).

47) Defendant’s website is inaccessible to persons with disabilities like the Plaintiff, who is 

visually impaired. Plaintiff was not able to enjoy full and equal access to the information and 

services that Defendant has made available to the public on its website, in violation of 42 U.S.C. 

§12101. et seq, and as prohibited by 42 U.S.C. §12182 et seq.

48) Defendant’s website is not in compliance with the ADA.

49) Defendant has made no reasonable accommodation for Plaintiff’s disability. 

50) A cursory review of a portion of the Defendant’s website revealed that the website is not 

accessible to persons like the Plaintiff that are visually impaired as required by law and for which 

there is no sufficient alternative on Defendant’s website, including:

Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: The options within the ‘Combo Box’ for selecting a country/region on the 

checkout page are not labeled in and audible format as the user cycles through them 

(video). They should work like this example shown on this page. In instances when the 

options presented in the dropdown are unfamiliar to the user, not having them read out 

loud as one cycles through them makes selecting the desired option difficult – one must 

select each individual option to get it read.

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

Violations that make it difficult to navigate through the site 

Violation: Focusable components do not receive focus in an order that preserves meaning 

and operability.

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 9 of 18
10

Note/Proof: After loading a product page, the focus is shifted to the reviews section at the 

bottom of the page. User has to navigate back up the page, and through a carousel to get 

to the section where the options for selecting and adding to cart the desired product are 

available (video).

Applicable WCAG 2.1 Standard at Issue: Standard 2.4.3 Focus Order (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 2.4.3 Focus Order.

Violation: Focusable components do not receive focus in an order that preserves meaning 

and operability.

Note/Proof: Within the product details, when a user activates the size guide button, the 

navigation sequence takes them to a completely new page. The user has no way within 

that page to navigate back to the product page that they were previously viewing. 

Operability is not preserved (video).

Applicable WCAG 2.1 Standard at Issue: Standard 2.4.3 Focus Order (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 2.4.3 Focus Order.

51) Due to Defendant’s failure to provide an ADA compliant website, the Plaintiff has been 

injured since she has been denied full access to Defendant’s website.

52) As a result, Plaintiff is entitled to injunctive relief pursuant to 42 U.S.C. §12133 and 28 

C.F.R. §36.303 to correct the inaccessibility that leads to discrimination against visually impaired 

persons.

WHEREFORE, Plaintiff requests entry of judgment in his favor and against Defendant for the 

following relief:

A. A declaration that Defendant’s website is in violation of the ADA;

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 10 of 18
11

B. An Order requiring Defendant, by a date certain, to update its website, and continue 

to monitor and update its website on an ongoing basis, to remove barriers in order that individuals 

with visual disabilities can access, and continue to access, the website and effectively communicate 

with the website to the full extent required by Title III of the ADA;

C. An Order requiring Defendant, by a date certain, to clearly display the universal 

disabled logo within its website, wherein the logo [1] would lead to a page which would state 

Defendant’s accessibility information, facts, policies, and accommodations. Such a clear display 

of the disabled logo is to ensure that individuals who are disabled are aware of the availability of 

the accessible features of the website;

D. An Order requiring Defendant, by a date certain, to provide ongoing support for web 

accessibility by implementing a website accessibility coordinator, a website application 

accessibility policy, and providing for website accessibility feedback to insure compliance thereto.

E. An Order directing Defendant, by a date certain to evaluate its policies, practices and 

procedures toward persons with disabilities, for such reasonable time to allow Defendant to 

undertake and complete corrective procedures to its website;

F. An Order directing Defendant, by a date certain, to establish a policy of web 

accessibility and accessibility features for its website to ensure effective communication for 

individuals who are visually disabled;

G. An Order requiring, by a date certain, that any third-party vendors who participate on 

Defendant’s website to be fully accessible to the visually disabled;

H. An Order directing Defendant, by a date certain and at least once yearly thereafter, to 

provide mandatory web accessibility training to all employees who write or develop programs or 

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 11 of 18
12

code for, or who publish final content to, Defendant’s website on how to conform all web content 

and services with ADA accessibility requirements and applicable accessibility guidelines;

I. An Order directing Defendant, by a date certain and at least once every three months 

thereafter, to conduct automated accessibility tests of its website to identify any instances where 

the website is no longer in conformance with the accessibility requirements of the ADA and any 

applicable accessibility guidelines, and further directing Defendant to send a copy of the twelve 

(12) quarterly reports to Plaintiff’s counsel for review.

J. An Order directing Defendant, by a date certain, to make publicly available and 

directly link from its website homepage, a statement of Defendant’s Accessibility Policy to ensure 

the persons with disabilities have full and equal enjoyment of its website and shall accompany the 

public policy statement with an accessible means of submitting accessibility questions and 

problems.

K. An award to Plaintiff of his reasonable attorney’s fees and costs pursuant to in 42 

U.S.C. §§12181-12189, and pursuant to such other laws and statutes that may apply, and further 

relief as the Court deems just and equitable. 

[1]

COUNT II – TRESPASS

53) Plaintiff realleges paragraphs 1 through 44 as if set forth herein. 

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 12 of 18
13

54) Defendant’s website contains software analytics. Since Plaintiff has navigated 

Defendant’s website as stated herein, Plaintiff’s computer and the personal information and 

browsing history stored therein, has suffered a trespass by Defendant.

55) Plaintiff never consented to and was unaware that Defendant’s website was placing 

software on his computer. 

56) Defendant committed common law trespass in violation of Florida law against Plaintiff 

because Plaintiff did not consent to the placement of tracking and information securing software 

on his personal computer, which was done without his knowledge and consent.

57) Defendant’s trespass has damaged Plaintiff by affecting the condition and value of his

computer. 

58) On its website, Defendant has an internet privacy policy section that can only be accessed 

by clicking a barely visible section at the bottom of the page called “Cookies Policy”, providing 

that they use cookies and similar technologies to collect a consumer’s information and they 

obtain non-public information from their users for their own advertising and marketing purposes 

by placing software on its website that collects a website user’s preferences and internet 

browsing habits as follows:

Consent

By using this website (https://www.quayaustralia.com) (the "Website") you consent to 

the use of cookies in accordance with this Cookies Policy. You will have seen a pop up 

to this effect on your first visit to this website; although it will not usually appear on 

subsequent visits you may withdraw your consent at any time by following the 

instructions below.

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 13 of 18
14

Disabling cookies

If you do not agree to the use of these cookies, please disable them by following the 

instructions for your browser set out here. Please note that some of the services will not 

function so well if cookies are disabled.

Where the organization setting the cookie provides an automated disabling tool in respect 

of its cookie(s) we list the name of that organization, the category of cookies it sets 

together with a link to its automated disabling tool. In all other cases, we list the names of 

the cookies themselves and their source at the date of this Cookies policy so that you can 

easily identify and disable them if you want through your browser controls.

Some browsers make is possible for you to signal that you do not want your internet 

browsing activity to be tracked. Disabling tracking may interfere with some uses of the 

Website and the services provided on the Website.

After your initial visit to the Website, we may change the cookies we use. This cookies 

policy will always allow you to know who is placing cookies, for what purpose and give 

you the means to disable them so you should check it from time to time.

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to 

your device when you visit a website. Cookies are then sent back to the originating web 

domain on your subsequent visits to that domain. Most web pages contain elements from 

multiple web domains so when you visit the Website, your browser may receive cookies 

from several sources.

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 14 of 18
15

Cookies are useful because they allow a website to recognize a user’s device. Cookies 

allow you to navigate between pages efficiently, remember preferences and generally 

improve the user experience. They can also be used to tailor advertising to your interests 

through tracking your browsing across websites.

Session cookies are deleted automatically when you close your browser and persistent 

cookies remain on your device after the browser is closed (for example to remember your 

user preferences when you return to the site).

What types of cookies do we use?

We describe the categories of cookies we and our affiliates and contractors use below.

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the website and use its 

features. Without these cookies, services you have asked for (such as navigating between 

pages) cannot be provided.

This cookie is set by the cookie compliance solution from OneTrust. It stores information 

about the categories of cookies the site uses and whether visitors have given or withdrawn 

consent for the use of each category. This enables site owners to prevent cookies in each 

category from being set in the user’s browser, when consent is not given. The cookie has a 

normal lifespan of one year, so that returning visitors to the site will have their preferences

remembered. It contains no information that can identify the site visitor.

Performance Cookies

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 15 of 18
16

We make use of analytic cookies to analyze how our visitors use our Website and to 

monitor Website performance. This allows us to provide a high quality experience by 

customizing our offering and quickly identifying and fixing any issues that arise. For 

example, we might use performance cookies to keep track of which pages are most 

popular, which method of linking between pages is most effective, and to determine why 

some pages are receiving error messages. We might also use these cookies to highlight 

articles or site services that we think will be of interest to you based on your usage of the 

website. The information collected by these cookies is not associated with your personal 

information by us or by our contractors.

Website Functionality Cookies

We make use of cookies to provide you with certain functionality. For example, to 

remember choices you make (such as your user name, language or the region you are in), 

or to recognize the platform from which you access the site, and to provide enhanced and 

more personal features. These cookies are not used to track your browsing on other sites.

Advertising Cookies

Advertising cookies (or targeting cookies) collect information about the browsing habits 

associated with your device and are used to make advertising more relevant to you and 

your interests. They are also used by services provided by third parties on this Website, 

such as ‘Like’ or ‘Share’ buttons in addition to providing the requested functionality. 

Third parties provide these services in return for recognizing that you (or more accurately 

your device has) have visited a certain website. These third parties put down advertising 

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 16 of 18
17

cookies both when you visit our Website and when you use their services and navigate 

away from our Website.

Use of IP addresses and web logs

We may also use your IP address and browser type to help diagnose problems with our 

server, to administer our Website and to improve the service we offer to you. An IP 

address is a numeric code that identifies your computer on the internet. Your IP address 

might also be used to gather broad demographic information.

We may perform IP lookups to determine which domain you are coming from (e.g. 

google.com) to more accurately gauge our users’ demographics.

Information from these types of cookies and technologies or about website usage is not 

combined with information about you from any other source.

The following table documents each type of cookie, along with how long a persistent 

cookie lasts

59) Due to Plaintiff’s disability, she could not understand Defendant’s website and she could 

not give informed consent to Defendant’s installation of data and information tracking software 

on his computer. Defendant also could not give informed consent to Defendant’s collection of his

browsing history and the placement of analytics on his computer.

60) Thus, Plaintiff has no adequate remedy at law to redress Defendant’s knowing and reckless 

disregard for Plaintiff’s right to exclude others from his computer and determine which programs 

should be installed and operated on his computer.

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 17 of 18
18

WHEREFORE, Plaintiff demands judgment against Defendant for Plaintiff’s damages, interest, 

costs, and such further relief as the Court deems just and equitable.

Request for Jury Trial

61) Plaintiff requests a jury trial.

Submitted by:

Mendez Law Offices, PLLC

Attorneys for Plaintiff

P.O. BOX 228630

Miami, Florida 33172

Telephone: 305.264.9090

Facsimile: 1-305.809.8474

Email:info@mendezlawoffices.com

By: /s/ 

DIEGO GERMAN MENDEZ, ESQ.

FL BAR NO.: 52748

Adams & Associates, P.A.

Attorneys for Plaintiff

6500 Cowpen Road, Suite 101

Miami Lakes, FL 33014

Telephone: 786-290-1963

Facsimile: 305-824-3868

Email: radamslaw@bellsouth.net

By: /s/ 

RICHARD J. ADAMS, ESQ.

FL BAR NO.: 770434

Case 1:22-cv-22382-DPG Document 1 Entered on FLSD Docket 07/29/2022 Page 18 of 18