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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 

ALBA RADA SIERRA,

 Plaintiff,

vs.

RAPHA HEALTH NETWORK INTERNATIONAL INC., 

A Florida Profit Corporation, and 

ALBERTO GUZMAN, individually,

 Defendant(s).

__________________________________________/

COMPLAINT

Plaintiff ALBA RADA SIERRA, (hereinafter “Plaintiff”) by and through her undersigned 

attorney hereby sues Defendants RAPHA HEALTH NETWORK INTERNATIONAL INC. 

(hereinafter RAPHA HEALTH), a Florida Profit Corporation and ALBERTO GUZMAN, 

individually (hereinafter “GUZMAN”) collectively “Defendants,” and says:

JURISDICTION AND VENUE

1. This is an action for damages excluding attorneys’ fees or costs and other relief based on 

unlawful employment practices committed by Defendants and jurisdiction of this Court is 

invoked pursuant to the provisions of Title VII of the Civil Rights Act of 1964, § 706(f) (42 

U.S.C. § 2000e-5(f)), the Florida Civil Rights Act (“FCRA”), §§ 760.01-760.11, and the Fair 

Labor Standards Act, 29 U.S.C. §§ 201 , et seq. (hereinafter the “Fair Labor Standards Act”, 

the “FLSA” or the “Act”).

2. This Court has jurisdiction of the claims herein pursuant to 29 U.S.C. § 2617, 28 U.S.C. § 

1331, and 28 U.S.C. § 1367.

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3. The claims asserted in this Complaint arose in Miami Dade County, Florida during the course 

of Plaintiff’s employment with Defendants.

4. Venue is proper in the United States Court for the Southern District of Florida because Plaintiff 

was employed in the Southern District of Florida by Defendants, which at all material times 

conducted, and continues to conduct, business in the Southern District of Florida, and because 

the acts that give rise to Plaintiff’s claims occurred within the Southern District of Florida.

PARTIES

5. Plaintiff at all times pertinent to this complaint resided within the Southern District of Florida. 

Plaintiff is over the age of eighteen and otherwise sui juris.

6. Plaintiff at all times relevant to this complaint was employed by Defendants as a technician. 

Plaintiff was therefore an employee as defined by 29 U.S.C § 203(e). 

7. RAPHA HEALTH is a Florida profit corporation organized and existing under and by virtue 

of the laws of Florida and is registered to do business within Florida. RAPHA HEALTH has 

its principal place of business in Doral, Florida. RAPHA HEALTH had, at all times material 

hereto, conducted substantial and continuous business within the Southern District of Florida, 

and is subject to the laws of the United States and the State of Florida. 

8. RAPHA HEALTH is an “employer” as defined by 29 U.S.C. § 203(d) and (s)(1), in that it has 

employees engaged in commerce or in the production of goods for commerce or that has 

employees handling, selling, or otherwise working on goods or materials that have been moved 

in or produced for commerce by any person.

9. At all times material to this Complaint, RAPHA HEALTH has had two (2) or more employees 

who have regularly sold, handled, or otherwise worked on goods and/or materials that have 

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been moved in or produced for commerce which as employees subject to the provisions of the 

FLSA, 29 U.S.C. § 207.

10. Specifically, RAPHA HEALTH is a worldwide renowned supplement manufacturer with 

offices in Miami, Spain, Costa Rica, Colombia, and Venezuela. RAPHA HEALTH,

manufactures products and supplements, which are sold and shipped worldwide. 

11. RAPHA HEALTH, upon knowledge and belief, has had gross revenue which exceeds 

$500,000 for each of the past three (3) years and utilizes goods in the flow of commerce across 

state lines.

12. Defendant GUZMAN is the CEO of, and exercised operational control over the activities of, 

corporate Defendant RAPHA HEALTH. 

13. Defendant GUZMAN acted directly in the interest of his company, RAPHA HEALTH, as the 

founder and CEO. Upon all available information, GUZMAN controlled the manner in which 

Plaintiff performed her work and the pay she was to receive. 

14. Defendants were an “employer” of Plaintiff as the term is defined under 29 U.S.C § 203(d).

GENERAL ALLEGATIONS RELATED TO PLAINTIFF’S OVERTIME CLAIMS

15. Plaintiff is a non-exempt employee of Defendants and is subject to the payroll practices and 

procedures set forth hereinafter, and who worked an excess of forty (40) hours during one or 

more workweeks within three (3) years of the filing of this complaint. 

16. Plaintiff worked for Defendants from on or about October 19, 2020, through July 2, 2021, as 

a technician. 

17. As a “technician”, Plaintiff did not actually have any decision-making authority as she could 

not hire or fire employees, or otherwise make decisions which impacted the business. 

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18. During the course of her employment, Plaintiff regularly worked 45-55 hours per workweek. 

Plaintiff was to be compensated at $10.00/hour. 

19. At all times pertinent to this action, Defendants failed to comply with 29 U.S.C §§ 201-219 in 

that Plaintiff performed services for Defendants for which no provision was made to properly 

pay for those hours worked over forty (40) in a given workweek. 

20. A review of the records in Plaintiff’s possession reflected that Plaintiff was not compensated 

at time and one half for her overtime hours. Rather, Plaintiff was compensated at her regular 

rate for all hours worked. 

21. Defendants and their representatives knew that Plaintiff was working overtime, and that federal 

law requires employees to be compensated at time and one-half per hour for overtime pay. 

22. Defendants maintained complete control over the hours Plaintiff worked and the pay she was 

to receive. 

23. Plaintiff has retained the undersigned firm to prosecute this action on her behalf and has agreed 

to pay it a reasonable fee for its services.

24. Plaintiff is entitled to her reasonable attorneys’ fees and costs if she is the prevailing party in 

this action. 

GENERAL ALLEGATIONS RELATED TO ALL OTHER COUNTS

25. Plaintiff is a person who practices Catholicism. Plaintiff is a member of a class protected under 

Title VII of the Civil Rights Act of 1964 and the Florida Civil Rights Act because the terms, 

conditions, and privileges of her employment were altered because of her religion.

26. Plaintiff is a member of a class protected under the FCRA and Title VII because she 

complained of discrimination to Defendant and was terminated thereafter. 

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27. RAPHA HEALTH has, at all times material, employed 15 or more employees for each working 

day in each of twenty or more calendar weeks in the current or preceding year in accordance 

with Title VII and the FCRA (42 U.S.C. §2000e(b); Fla. Stat. §760.02(7)).

28. Plaintiff alleges causes of action for violations of the FCRA, Title VII, as a result of the adverse 

treatment to which Defendant subjected Plaintiff, Defendant's dismissal of Plaintiff from 

employment. 

29. Plaintiff has exhausted her administrative remedies by filing a timely charge of discrimination 

("Charge") against the Defendant with the Equal Employment Opportunity Commission which 

was dually filed with the Florida Commission on Human Relations. 

30. Plaintiff’s Charge was filed on or about July 22, 2021. The actions complained of herein 

occurred within 300 days thereof and/or continued from that date stemming from the same 

actions set forth in the Charge. 

31. Plaintiff was terminated from her position on or about July 2, 2021. Her Charge was therefore 

timely filed. 

32. Plaintiff was issued a Notice of Right to Sue on April 27, 2022. This suit is filed in accordance 

with that Notice and within the applicable 90-day time limitation (a copy of the Notice is 

attached hereto as Exhibit “A”).

33. The Florida Commission on Human Relations did not issue a finding on Plaintiff’s charge 

within 180 days of the filing of said charges. 

34. In March 2021, GUZMAN (Christian) invited a pastor to host meetings three times a week 

(Mondays, Wednesdays, and Fridays) to preach Christian teachings to all employees.

35. On the outset, GUZMAN advised that these meetings were not mandatory to employees and 

that only those who wished to participate could attend. Plaintiff (Catholic) opted out. 

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36. In April 2021, Plaintiff’s manager Hector (LNU) (hereinafter “Hector”) asked Plaintiff why 

she was not attending the meetings. Plaintiff responded that she is not Christian and that some 

of the teachings made her uncomfortable.

37. Plaintiff was out on vacation from May 31, 2021, through June 4, 2021, which had been 

requested in advance and previously approved by her supervisor. 

38. Upon Plaintiff’s return on or about June 7, 2021, she was called by Hector and advised that 

she was being terminated for job abandonment, to which Plaintiff objected and requested to 

speak to management as her vacation had been previously approved. 

39. That same day, GUZMAN met with Plaintiff per her request. During the meeting Guzman 

inquired about Plaintiff’s absence from the meetings. He offered Plaintiff her job back 

contingent upon the request that she attend all religious meetings moving forward. 

40. Plaintiff began to attend the meetings as requested. However, Plaintiff was extremely 

uncomfortable and in disagreement with the teachings. 

41. On or about June 30, 2021, the pastor began his sermon and made a comment condemning 

homosexual which went against Plaintiff’s beliefs. Plaintiff was very upset and offended by 

the comment and discussed with coworkers on how offensive she found these meetings and 

the matters discussed. 

42. On July 1, 2021, Dr. Durnes Garcia (Dr. Guzman’s wife) announced that due to the lack of 

appreciation from the staff that no more meetings were going to be held. 

43. On or about July 2, 2021, Plaintiff was terminated. The reason provided by RAPHA HEALTH, 

that Plaintiff’s department was being eliminated.

44. Plaintiff requested to be moved to another department, as she had experience in other 

departments, but her request was denied. 

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45. RAPHA HEALTHt's alleged reason(s) for Plaintiff's termination are pretextual as Plaintiff was 

in fact terminated from employment because of her religion and her complaints. 

46. Upon information and belief, Plaintiff was replaced by another individual. 

47. RAPHA HEALTH’s justification(s) for its treatment of Plaintiff, if any, are a mere pretext for 

unlawful discrimination and retaliation.

48. If, however, the reason(s) proffered by RAPHA HEALTH are found to be with merit, 

Plaintiff’s religion and/or complaints were a motivating factor in the decision for the adverse 

employment action(s). 

49. Plaintiff has retained the undersigned firm to prosecute this action on her behalf and has agreed 

to pay it a reasonable fee for its services.

50. Plaintiff is entitled to her reasonable attorneys’ fees and costs if she is the prevailing party in 

this action.

COUNT I

VIOLATION OF FLSA/OVERTIME against RAPHA HEALTH

51. Plaintiff, re-alleges and reaffirms paragraphs 1 through 24 as if fully set forth herein.

52. Since the commencement of Plaintiff’s employment, RAPHA HEALTH has willfully violated 

the provisions of § 7 of the FLSA [29 U.S.C. § 207] by employing employees engaged in 

commerce for workweeks longer than forty (40) hours without compensating them for all hours 

worked in excess of forty (40) hours at a rate not less than one- and one-half times her regular 

rate.

53. Specifically, when Plaintiff worked over forty (40) hours in a designated workweek, she was 

compensated at her regular rate for the hours worked over forty (40). 

54. RAPHA HEALTH is and was, during all times hereafter mentioned, an enterprise engaged in 

commerce or in the production of goods for commerce as defined in §§ 3 (r) and 3(s) of the 

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FLSA, 29 U.S.C. § 203(r) and 203(s). RAPHA HEALTH’s business activities involve those 

to which the Fair Labor Standards Act applies as alleged above. 

55. Plaintiff was not exempt from the overtime provision of the Act, 29 U.S.C. § 213(a), in that 

she was neither a bona fide executive, administrative, or professional employee. Plaintiff 

performed manual labor tasks and did not have decision-making authority.

56. RAPHA HEALTH has knowingly and willfully failed to pay Plaintiff at time and one half of 

her regular rate of pay for all hours worked in excess of forty (40) per week between the 

relevant time period.

57. By reason of the said intentional, willful, and unlawful acts of RAPHA HEALTH, Plaintiff has 

suffered damages plus incurring costs and reasonable attorneys' fees.

58. Plaintiff seeks to recover for unpaid wages accumulated from the date of hire.

59. RAPHA HEALTH never posted any notice, as required by the Fair Labor Standards Act and 

federal law, to inform employees of their federal rights to overtime and minimum wage 

payments.

60. As a result of RAPHA HEALTH’s willful violations of the Act, Plaintiff is entitled to 

liquidated damages.

61. Plaintiff has retained the undersigned counsel to represent her in this action, and pursuant to 

29 U.S.C. § 216(b), Plaintiff is entitled to recover all reasonable attorneys' fees and costs

incurred in this action from RAPHA HEALTH.

WHEREFORE, Plaintiff respectfully prays for the following relief against RAPHA HEALTH:

A. Adjudge and decree that RAPHA HEALTH has violated the FLSA and has done so 

willfully, intentionally and with reckless disregard for Plaintiff’s rights;

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B. Award Plaintiff actual damages in the amount shown to be due for overtime 

compensation for hours worked in excess of forty (40) weekly, with interest; and

C. Award Plaintiff an equal amount in double damages/liquidated damages; and

D. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT II

VIOLATION OF FLSA/OVERTIME against ALBERTO GUZMAN

62. Plaintiff, re-alleges and reaffirms paragraphs 1 through 24 as if fully set forth herein.

63. At the times mentioned, Defendant GUZMAN was, and is now, the founder and CEO of 

corporate Defendant, RAPHA HEALTH, in a management capacity.

64. Specifically, GUZMAN supervised Plaintiff, determined company payroll decisions, and 

maintained the right to hire and fire Plaintiff during all pertinent times hereto. 

65. GUZMAN had operational control of the business and is thus jointly liable for Plaintiff’s 

damages.

66. GUZMAN was an employer of Plaintiff within the meaning of Section 3(d) of the FLSA, in 

that GUZMAN acted directly in the interests of Corporate Defendant RAPHA HEALTH in 

relation to its employees including Plaintiff. 

67. Defendant GUZMAN willfully and intentionally refused to properly pay Plaintiff overtime 

wages as required by the law of the United States as set forth above and remains owing Plaintiff 

these wages since the commencement of Plaintiff’s employment with Defendants as set forth 

above. 

WHEREFORE, Plaintiff respectfully prays for the following relief against GUZMAN: 

A. Adjudge and decree that Defendant GUZMAN has violated the FLSA and has done so 

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willfully, intentionally and with reckless disregard for Plaintiff’s rights;

B. Award Plaintiff actual damages in the amount shown to be due for unpaid overtime 

compensation for hours worked in excess of forty (40) weekly, with interest; and

C. Award Plaintiff an equal amount in double damages/liquidated damages; and

D. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT III

VIOLATION OF THE CIVIL RIGHTS ACT 

(DISCRIMINATION BASED ON RELIGION)

68. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 5, and 

again in paragraphs 25 through 50 of this complaint as if set out in full herein:

69. Plaintiff is a member of a protected class under Title VII of the Civil Rights Act of 1964, § 

706 (f) (42 U.S.C § 2000e-5(f)), because Plaintiff was discriminated based on her religion.

70. RAPHA HEALTH’s disparate treatment of Plaintiff, including but not limited to Plaintiff’s 

termination, was directly and proximately caused by RAPHA HEALTH’s unjustified 

discrimination against Plaintiff because of the fact that she practiced Catholicism, and did not 

want to participate in the christian teaching meetings in violation of the Act.

71. If, however, the reason(s) proffered by RAPHA HEALTH are found to be with merit, 

Plaintiff’s religion, was a motivating factor in the decision for the adverse employment 

action(s). 

72. As a direct and proximate result of RAPHA HEALTH’s intentional conduct, Plaintiff suffered 

serious economic losses as well as mental pain and suffering.

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73. Plaintiff is entitled to such affirmative relief as may be appropriate, including, but not limited 

to, lost wages, benefits, and compensation for emotional distress, pursuant to the provisions 

of Title VII of the Civil Rights Act of 1964, §706(g).

74. Plaintiff, based on information and belief, alleges that RAPHA HEALTH’s actions were done 

with malice, and with intentional disregard for her protected rights under Title VII of the Civil 

Rights Act of 1964. RAPHA HEALTH, by and through their officers, and/or supervisors, 

authorized, condoned, and/or ratified the unlawful conduct of Hector and/or other employees. 

Therefore, Plaintiff is also entitled to punitive damages from RAPHA HEALTH in a sum 

according to proof at trial. 

WHEREFORE, Plaintiff respectfully requests that:

A. The Court grant Plaintiff judgment award Plaintiff judgment against RAPHA HEALTH 

to compensate her for past and future pecuniary losses, including injury to her 

professional reputation, and emotional pain and suffering caused by RAPHA HEALTH’s 

discriminatory treatment in an amount to be determined at trial and in accordance with 

the Civil Rights Act of 1964, §706(g);

B. The Court award punitive damages as permitted under the law;

C. The Court award Plaintiff the costs of this action together with her reasonable attorney’s 

fees incurred herein, pursuant to contract and/or statute; and

D. Require RAPHA HEALTH to reinstate Plaintiff to the position at the rate of pay and with 

the full benefits Plaintiff would have had Plaintiff not been discriminated against by 

RAPHA HEALTH, or in lieu of reinstatement, award front pay;

E. The Court award Plaintiff such other and further relief as the Court deems appropriate.

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COUNT IV

VIOLATION OF THE CIVIL RIGHTS ACT

(RETALIATION)

75. Plaintiff incorporates herein the allegations contained in paragraphs 1 through 5, and again in 

paragraphs 25 through 50, inclusive, as though same were fully re-written, and says:

76. Plaintiff is a member of a protected class under Title VII, to wit she complained of 

discriminatory treatment based on her religion. 

77. Plaintiff requested to not be forced to attend religious meetings because they went against her 

religion, Catholicism, but was told she could only keep her position if she attended all religious 

meetings going forward. 

78. Thereafter, on or about July 2, 2021, Plaintiff was terminated after complaining for being 

forced to participate in a meeting that went against her beliefs. 

79. The conduct of RAPHA HEALTH, by and through the conduct of its agents, employees, and/or 

representatives, and RAPHA HEALTH’s failure to make prompt remedial action to prevent 

continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights under 

federal law. 

80. Plaintiff, based on information and belief, alleges that RAPHA HEALTH’s actions were done 

with malice, and with disregard for her protected rights under the Title VII. RAPHA HEALTH, 

by and through its officers, and/or supervisors, authorized, condoned, and/or ratified the 

unlawful conduct of its employees. Therefore, Plaintiff is also entitled to punitive damages 

from RAPHA HEALTH in a sum according to proof at trial. 

81. RAPHA HEALTH’s stated reason(s) for terminating Plaintiff is pretextual. 

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82. If, however, the reason(s) proffered by RAPHA HEALTH are found to be with merit, 

Plaintiff’s complaints of discrimination, were a motivating factor in the decision for the 

adverse employment action(s). 

WHEREFORE, Plaintiff respectfully requests that:

A. The Court grant Plaintiff judgment award Plaintiff judgment against RAPHA HEALTH 

to compensate her for past and future pecuniary losses, including appropriate back pay, 

benefits' adjustment, injury to her professional reputation, and emotional pain and 

suffering caused by RAPHA HEALTH’s discriminatory treatment in an amount to be 

determined at trial and in accordance with the Civil Rights Act of 1964, §706(g);

B. The Court award punitive damages as permitted under the law;

C. The Court award Plaintiff the costs of this action together with her reasonable attorney’s 

fees incurred herein, pursuant to contract and/or statute; and

D. Require RAPHA HEALTH to reinstate Plaintiff to the position at the rate of pay and with 

the full benefits Plaintiff would have had Plaintiff not been discriminated against by 

RAPHA HEALTH, or in lieu of reinstatement, award front pay;

E. The Court award Plaintiff such other and further relief as the Court deems appropriate.

COUNT V

VIOLATION OF THE FLORIDA CIVIL RIGHTS ACT

(DISCRIMINATION BASED ON RELIGION)

83. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 5, and 

again in paragraphs 25 through 50 of this complaint as if set out in full herein:

84. Plaintiff is a member of a protected class under the Florida Civil Rights Act (“FCRA”), 

Sections 760.01-760.11, based on her religion, Catholic.

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85. Plaintiff requested to not be forced to attend religious meetings because they went against her 

religion, Catholicism, but was told she could only keep her position if she attended all religious 

meetings going forward. 

86. RAPHA HEALTH’s disparate treatment of Plaintiff, including but not limited to Plaintiff’s 

termination, was directly and proximately caused by RAPHA HEALTH’s unjustified 

discrimination against Plaintiff because of the fact that she practiced Catholicism, in violation 

of the Act.

87. If, however, the reason(s) proffered by RAPHA HEALTH are found to be with merit, 

Plaintiff’s religion, was a motivating factor in the decision for the adverse employment 

action(s). 

88. As a direct and proximate result of RAPHA HEALTH’s intentional conduct, Plaintiff suffered 

serious economic losses as well as mental pain and suffering.

89. Plaintiff is entitled to such affirmative relief as may be appropriate, including, but not limited 

to, lost wages, benefits, and compensation for emotional distress, pursuant to the provisions 

of the FCRA. 

90. Plaintiff, based on information and belief, alleges that RAPHA HEALTH’s actions were done 

with malice, and with intentional disregard for her protected rights under the FCRA. RAPHA 

HEALTH, by and through their officers, and/or supervisors, authorized, condoned, and/or 

ratified the unlawful conduct of Hector and/or other employees. Therefore, Plaintiff is also 

entitled to punitive damages from RAPHA HEALTH in a sum according to proof at trial. 

WHEREFORE, Plaintiff respectfully requests that:

A. The Court grant Plaintiff judgment award Plaintiff judgment against RAPHA HEALTH 

to compensate her for past and future pecuniary losses, including injury to her professional 

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reputation, and emotional pain and suffering caused by RAPHA HEALTH’s 

discriminatory treatment in an amount to be determined at trial and in accordance with the 

FCRA;

B. The Court award punitive damages as permitted under the law;

C. The Court award Plaintiff the costs of this action together with her reasonable attorney’s 

fees incurred herein, pursuant to contract and/or statute; and

D. Require RAPHA HEALTH to reinstate Plaintiff to the position at the rate of pay and with 

the full benefits Plaintiff would have had Plaintiff not been discriminated against by 

RAPHA HEALTH, or in lieu of reinstatement, award front pay;

E. The Court award Plaintiff such other and further relief as the Court deems appropriate

COUNT VI

VIOLATION OF THE FLORIDA CIVIL RIGHTS ACT 

(RETALIATION)

91. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 5, and 

again in paragraphs 25 through 50 of this complaint as if set out in full herein:

92. Plaintiff brings this claim under the Florida Civil Rights Act, Florida Statutes § 760.01 et seq.

for Defendant’s retaliatory conduct. 

93. Plaintiff requested to not be forced to attend religious meetings because they went against her 

religion, Catholicism, but was told she could only keep her position if she attended all religious 

meetings going forward. 

94. Shortly thereafter, Plaintiff was terminated. 

95. The conduct of RAPHA HEALTH, by and through the conduct of its agents, employees, and/or 

representatives, and RAPHA HEALTH’s failure to make prompt remedial action to prevent 

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continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights under 

state law. 

96. Plaintiff, based on information and belief, alleges that RAPHA HEALTH’s actions were done 

with malice, and with disregard for her protected rights under the FCRA. RAPHA HEALTH, 

by and through its officers, and/or supervisors, authorized, condoned, and/or ratified the 

unlawful conduct of Hector and/or other employees. Therefore, Plaintiff is also entitled to 

punitive damages from RAPHA HEALTH in a sum according to proof at trial. 

97. RAPHA HEALTH’s stated reason(s) for terminating Plaintiff is pretextual. 

98. If, however, the reason(s) proffered by RAPHA HEALTH are found to be with merit, 

Plaintiff’s complaints of discrimination, were a motivating factor in the decision for the 

adverse employment action(s). 

WHEREFORE, Plaintiff respectfully requests that:

A. The Court grant Plaintiff judgment award Plaintiff judgment against RAPHA HEALTH to 

compensate her for past and future pecuniary losses, including appropriate back pay, 

benefits' adjustment, injury to her professional reputation, and emotional pain and suffering 

caused by RAPHA HEALTH’s discriminatory treatment in an amount to be determined at 

trial and in accordance with the FCRA;

B. The Court award punitive damages as permitted under the law;

C. The Court award Plaintiff the costs of this action together with her reasonable attorney’s 

fees incurred herein, pursuant to contract and/or statute; and

D. Require RAPHA HEALTH to reinstate Plaintiff to the position at the rate of pay and with 

the full benefits Plaintiff would have had Plaintiff not been discriminated against by 

RAPHA HEALTH, or in lieu of reinstatement, award front pay;

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E. The Court award Plaintiff such other and further relief as the Court deems appropriate.

DEMAND FOR JURY TRIAL

Plaintiff ALBA RADA SIERRA demands trial by jury on all issues and all counts of this 

Complaint so triable as a matter of right.

Dated: July 26, 2022

PEREGONZA THE ATTORNEYS PLLC

5201 Blue Lagoon Drive, 

Suite 290

Miami, FL 33126

Tel. (786) 650-0202

Fax. (786) 650-0200

By: /s/ Nathaly Saavedra

Nathaly Saavedra, Esq. 

Fla. Bar No. 118315

Email: nathaly@peregonza.com

By: /s/ Juan J. Perez

Juan J. Perez, Esq. 

Fla. Bar No. 115784

Email: juan@peregonza.com

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