EXHIBIT A

Case 1:22-cv-23221-BB Document 1-4 Entered on FLSD Docket 10/04/2022 Page 1 of 11
Filing# 153161068 E-Filed 07/12/2022 01:32:36 PM 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

LAURENE SASSINE, 

Plaintiff, 

V. 

SEVEN FOR ALL MANKIND, LLC 

a Foreign Limited Liability Company, 

Defendant. ________________ / 

Case No. 2022-012030-CA-01 

CERTIFIED PROCESS SERVER# (2L. r-<7 

SECOND JUDICIAL CIRCUIT COURT~ 

DATESERVED9·-0·12 TIM~ 

SUMMONS IN A CML CASE 70 

TO: SEVEN FOR ALL MANKIND, LLC through its Registered Agent: 

CORPORATION SERVICE COMP ANY 

1201 HAYS STREET 

TALLAHASSEE, FL 32301-2525 

YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY 

JASON S. REMER, ESQ. 

REMER & GEORGES-PIERRE, PLLC. 

44 WEST FLAGLER STREET 

SUITE2200 

MIAMI, FL 33130 

an answer to the complaint which is herewith served upon you, within 20 days after service of 

this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default 

will be taken against you for the relief demanded in the complaint. You must also file your 

answer with the Clerk of this Court within a reasonable period of time after service. 

Harvey Ruvin, 

Clerk of Courts 

(BY) DEPUTY CLERK 

7/18/2022 

DATE 

Case 1:22-cv-23221-BB Document 1-4 Entered on FLSD Docket 10/04/2022 Page 2 of 11
Filing# 152452598 E-Filed 06/29/2022 04:17:51 PM 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

LAURENE SASSINE, 

Plaintiff, 

V. 

SEVEN FOR ALL MANKIND, LLC 

a Foreign Limited Liability Company, 

Defendant. 

I -----------------

COMPLAINT 

COMES NOW Plaintiff, LAURENE SASSINE ("Plaintiff'), by and through the 

undersigned counsel, and hereby sues Defendant, SEVEN FOR ALL MANKIND, LLC 

("Defendant"), and alleges as follows: 

1. This is an action by the Plaintiff for damages exceeding $30,000, excluding attorney fees or 

costs, pursuant to the Florida Civil Rights Act of 1992, Florida Statutes, Chapter 760, et seq. 

("FCRA") to redress injuries resulting from Defendant's unlawful, discriminatory treatment 

of Plaintiff. 

2. Plaintiff is a resident of Miami-Dade County, Florida, within the jurisdiction of this 

Honorable Court. 

3. Defendant is a Foreign Limited Liability Company authorized to conduct business in the 

State of Florida. 

4. At all relevant times Defendant was an employer within the meaning of state and federal 

discrimination law in that it employed 15 or more employees for at least twenty calendar 

weeks in this year or the previous year. 

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5. The violations complained of herein occurred in Miami-Dade County, Florida and as such, 

venue is proper in this Court. 

6. All conditions precedent for the filing of this action before this Court has been previously 

met, including the exhaustion of all pertinent administrative procedures and remedies. 

FACTUAL ALLEGATIONS COMMON TO ALL COUNTS 

7. Plaintiff is a Black woman of Haitian national origin, and within a class of individuals 

protected by the FCRA. 

8. Plaintiff began working for Defendant in 2012 as an assistant manager. 

9. Plaintiff was the only Black Haitian female working at that location. 

10. Plaintiffs supervisor, Billy Wood, is a white male. 

11. In the five years that Plaintiff was employed with Defendant she maintained an exemplary 

record. 

12. However, in October 2019, after Billy Wood assumed his role as Plaintiff's supervisor, 

Wood created a hostile work environment for Plaintiff and writing her up unnecessarily 

based on the fact that Billy Wood did not want a black and/or Haitian and/or female manager 

working the position. 

13. Defendant through Billy Wood treated white male non-Haitian supervisory employees such 

as Alex Melendez different from Plaintiff based on race and/or gender and/or national origin. 

14. Plaintiff complained about unfair treatment in the workplace to management of Defendant. 

15. Defendant through Billy Wood terminated Plaintiff based on discriminatory intent. 

16. Plaintiff was replaced with a white man. 

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17. Throughout her employment Plaintiff was able to perform the essential functions of her job 

duties and responsibilities, and at all relevant times she did perform her job at satisfactory or 

above-satisfactory levels. 

18. Any reason proffered by Defendant for Plaintiffs termination is mere pretext for unlawful 

discrimination. 

19. Plaintiff filed a Charge of Discrimination with the Equal Employment Opportunity 

Commission. 

COUNTI 

Race Discrimination in Violation of the FCRA 

20. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-19 above as if 

set out in full herein. 

21. Plaintiff is a member of a protected class under the FCRA. 

22. By the conduct describe above, Defendant has engaged in discrimination against Plaintiff 

because of Plaintiffs race and subjected the Plaintiff to race-based animosity. 

23. Such discrimination was based upon the Plaintiffs race in that Plaintiff would not have been 

the object of discrimination but for the fact that Plaintiff is Black. 

24. Defendant's conduct complained of herein was willful and in disregard of Plaintiffs 

protected rights. Defendant and its supervisory personnel were aware that discrimination on 

the basis of Plaintiffs disability was unlawful but acted in reckless disregard of the law. 

25. At all times material hereto, the employees exhibiting discriminatory conduct towards 

Plaintiff possessed the authority to affect the terms, conditions, and privileges of Plaintiffs 

employment with the Defendant. 

26. Defendant retained all employees who exhibited discriminatory conduct toward the Plaintiff 

and did so despite the knowledge of said employees engaging in discriminatory actions. 

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27. As a result of Defendant's actions, as alleged herein, Plaintiff has been deprived of rights, has 

been exposed to ridicule and embarrassment, and has suffered emotional distress and 

damage. 

28. The conduct of Defendant, by and through the conduct of its agents, employees, and/or 

representatives, and the Defendant's failure to make prompt remedial action to prevent 

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

federal law. 

29. The actions of the Defendant and/or its agents were willful, wanton, and intentional, and with 

malice or reckless indifference to the Plaintiff's statutorily protected rights, thus entitling 

Plaintiff to damages in the form of compensatory and punitive damages pursuant to federal 

law, to punish the Defendant for its actions and to deter it, and others, from such action in the 

future. 

30. Plaintiff has suffered and will continue to suffer both irreparable injury and compensable 

damages as a result of Defendant's discriminatory practices unless and until this Honorable 

Court grants relief. 

WHEREFORE, Plaintiffs respectfully prays for the following relief against Defendant: 

a. Adjudge and decree that Defendant has violated the FCRA, and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff's rights; 

b. Enter a judgment requiring that Defendant pay Plaintiff appropriate back pay, 

benefits' adjustment, and prejudgment interest at amounts to be proved at trial for the 

unlawful employment practices described herein; 

c. Enter an award against Defendant and award Plaintiff compensatory damages for 

mental anguish, personal suffering, and loss of enjoyment of life; 

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d. Require Defendant 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 

Defendant, or in lieu of reinstatement, award front pay; 

e. Award Plaintiff the costs of this action, together with a reasonable attorney fees; and 

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

circumstances. 

COUNT II 

National Origin Discrimination in Violation the FCRA 

31. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-19 of this 

complaint as if set out in full herein. 

32. Plaintiff is a member of a protected class under the FCRA. 

33. By the conduct describe above, Defendant has engaged in discrimination against Plaintiff 

because of Plaintiff's national origin and subjected the Plaintiff to animosity based on 

national origin. 

34. Such discrimination was based upon the Plaintiffs national origin in that Plaintiff would not 

have been the object of discrimination but for the fact that Plaintiff is Haitian. 

35. Defendant's conduct complained of herein was willful and in disregard of Plaintiffs 

protected rights. Defendant and its supervisory personnel were aware that discrimination on 

the basis of national origin was unlawful but acted in reckless disregard of the law. 

36. At all times material hereto, the employees exhibiting discriminatory conduct towards 

Plaintiff possessed the authority to affect the terms, conditions, and privileges of Plaintiff's 

employment with the Defendant. 

37. Defendant retained all employees who exhibited discriminatory conduct toward the Plaintiff 

and did so despite the knowledge of said employees engaging in discriminatory actions. 

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38. As a result of Defendant's actions, as alleged herein, Plaintiff has been deprived of rights, has 

been exposed to ridicule and embarrassment, and has suffered emotional distress and 

damage. 

39. The conduct of Defendant, by and through the conduct of its agents, employees, and/or 

representatives, and the Defendant's failure to make prompt remedial action to prevent 

continued discrimination against the Plaintiff, deprived the Plaintiff of stah1tory rights under 

federal law. 

40. The actions of the Defendant and/or its agents were willful, wanton, and intentional, and with 

malice or reckless indifference to the Plaintiffs statutorily protected rights, thus entitling 

Plaintiff to damages in the form of compensatory and punitive damages pursuant to federal 

law, to punish the Defendant for its actions and to deter it, and others, from such action in the 

future. 

41. Plaintiff has suffered and will continue to suffer both irreparable injury and compensable 

damages as a result of Defendant's discriminatory practices unless and until this Honorable 

Court grants relief. 

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

a. Adjudge and decree that Defendant has violated Title VII, and has done so willfully, 

intentionally, and with reckless disregard for Plaintiffs' rights; 

b. Enter a judgment requiring that Defendant pay Plaintiff appropriate back pay, 

benefits' adjustment, and prejudgment interest at amounts to be proved at trial for the 

unlawful employment practices described herein; 

c. Enter an award against Defendant and award Plaintiff compensatory damages for 

mental anguish, personal suffering, and loss of enjoyment of life; 

Case 1:22-cv-23221-BB Document 1-4 Entered on FLSD Docket 10/04/2022 Page 8 of 11
d. Require Defendant 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 

Defendant, or in lieu of reinstatement, award front pay; 

e. Award Plaintiff the costs of this action, together with a reasonable attorney fees; and 

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

circumstances. 

COUNT III 

Gender Discrimination in Violation oj the FCRA 

42. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 19 of 

this Complaint as if set out in full herein. 

43. At all times material hereto, Defendant failed to comply with the Florida Civil Rights Act of 

1992 Florida Statues Section 760.10 which in its relevant section states it is an unlawful 

employment practice for an employer to discriminate or discharge or otherwise to 

discriminate against any individual with respect to compensation, terms, conditions, or 

privileges of employment, because of such individual's sex/gender. 

44. The applicable statute, FCRA, prohibits an employer from maldng employment decisions, or 

from taldng any personnel action, affecting the terms, conditions and privileges of one's 

employment, based upon sex/gender-conformity considerations or reasons. 

45. The Plaintiff is a female and former employee of Defendant and she possessed the requisite 

qualifications and skills to perform her position with Defendant. 

46. While employed with Defendant, Plaintiff was subjected to discrimination and harassment 

based on her gender. 

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. ' ' ' 

4 7. As a direct and proximate result of the Defendant unlawful acts, Plaintiff has suffered great 

and irreparable economic harm and other associated losses such as emotional distress, 

humiliation, embarrassment, and economic losses. 

48. Moreover, as a further result of the Defendant unlawful gender based discriminatory 

conduct, the Plaintiff has been compelled to file this action and she has incurred the costs of 

litigation. 

49. Plaintiff was qualified for her position with Defendant. 

50. Defendant violated the Florida Civil Rights Act of 1992 (FCRA) by discriminating against 

Plaintiff because of her gender in the terms, conditions, and privileges of employment. 

51. The Defendant's actions were malicious and were reckless indifferent to the Plaintiffs rights 

pursuant to Florida Statute Section 760, protecting a person from discrimination. 

52. The aforementioned actions of Defendant were done wantonly, willfully, maliciously, and 

with reckless disregard of the consequences of such actions. 

WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter 

judgment against the Defendant; find that the Defendant indeed violated the FCRA, and in 

addition, order the following additional relief: 

a. Declare that the acts complained of herein are in violation of the Florida Civil 

Rights Act; 

b. Award PLAINTIFF compensatory damages for emotional distress, 

embarrassment and humiliation; 

c. Grant a permanent injunction enjoining the DEFENDANT, its officers, 

successors, assigns, and all persons in active concert or participation with it, from 

engaging in discriminatory conduct; 

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.. ' , 

d. Reinstate PLAINTIFF to the same position he held before the retaliatory 

personnel action, or to an equivalent position; 

e. Reinstate full fringe benefits and seniority rights to PLAINTIFF; 

f. Order DEFENDANT to make PLAINTIFF whole, by compensating PLAINTIFF 

for lost wages, benefits, including front pay, back pay with prejudgment interest; 

g. For a money judgment representing prejudgment interest; 

h. Award any other compensation allowed by law including punitive damages and 

attorney's fees; 

1. Grant PLAINTIFF's costs of this action, including reasonable attorney's fees; 

j. Grant PLAINTIFF a trial by jury; and 

k. Grant such other and further relief as the Court deems just and proper. 

JURY DEMAND 

Plaintiff demands trial by jury of all issues triable as of right by jury. 

Dated: June 29, 2022 Respectfully submitted, 

Isl Jason S. Remer 

Jason S. Remer, Esq. 

Florida Bar No.: 165580 

jremer@rgpattorneys.com 

REMER & GEORGES-PIERRE, PLLC 

44 WEST FLAGLER STREET, SUITE 2200 

Miami, Florida 33130 

Telephone: (305) 416-5000 

Facsimile: (305) 416-5005 

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