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FORM 1.997. CIVIL COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing

and service of pleadings or other documents as required by law. This form must be filed by the

plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant

to section 25.075, Florida Statutes. (See instructions for completion.)

I. CASE STYLE

IN THE CIRCUIT/COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

WILLIAM SANDORF

Plaintiff Case #

Judge

vs.

MARY BRICKELL MANAGEMENT, LLC, SUNVIEW COMPANIES

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of

the claim is requested for data collection and clerical processing purposes only. The amount of the claim

shall not be used for any other purpose. 

 ☐ $8,000 or less

☐ $8,001 - $30,000

☐ $30,001- $50,000

☐ $50,001- $75,000

☐ $75,001 - $100,000

☒ over $100,000.00

III. TYPE OF CASE (If the case fits more than one type of case, select the most

definitive category.) If the most descriptive label is a subcategory (is indented under a broader

category), place an x on both the main category and subcategory lines.

Filing # 152458682 E-Filed 06/29/2022 04:56:35 PM Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 1 of 16
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CIRCUIT CIVIL

☐ Condominium

☐ Contracts and indebtedness

☐ Eminent domain

☐ Auto negligence

☐ Negligence—other

☐ Business governance

☐ Business torts

☐ Environmental/Toxic tort

☐ Third party indemnification

☐ Construction defect

☐ Mass tort

☐ Negligent security

☐ Nursing home negligence

☐ Premises liability—commercial

☐ Premises liability—residential

☐ Products liability

 ☐ Real Property/Mortgage foreclosure

☐ Commercial foreclosure

☐ Homestead residential foreclosure

☐ Non-homestead residential foreclosure

☐ Other real property actions

☐Professional malpractice

☐ Malpractice—business

☐ Malpractice—medical

☐ Malpractice—other professional

☒ Other

☐ Antitrust/Trade regulation

☐ Business transactions

☐ Constitutional challenge—statute or ordinance

☐ Constitutional challenge—proposed amendment

☐ Corporate trusts

☒ Discrimination—employment or other

☐ Insurance claims

☐ Intellectual property

☐ Libel/Slander

☐ Shareholder derivative action

☐ Securities litigation

☐ Trade secrets

☐ Trust litigation

COUNTY CIVIL

☐ Small Claims up to $8,000

☐ Civil

☐ Real property/Mortgage foreclosure 

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 2 of 16
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☐ Replevins

☐ Evictions

☐ Residential Evictions

☐ Non-residential Evictions

☐ Other civil (non-monetary)

COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the

Administrative Order. Yes ☐ No ☒

IV. REMEDIES SOUGHT (check all that apply):

☒ Monetary;

☒ Nonmonetary declaratory or injunctive relief;

☒ Punitive

V. NUMBER OF CAUSES OF ACTION: [ ]

(Specify)

3

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

☐ yes

☒ no

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

☒ no

☐ yes If “yes,” list all related cases by name, case number, and court.

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

☒ yes

☐ no

IX. DOES THIS CASE INVOLVE ALLEGATIONS OF SEXUAL ABUSE?

☐ yes

☒ no

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of

my knowledge and belief, and that I have read and will comply with the requirements of

Florida Rule of Judicial Administration 2.425.

Signature: s/ Alberto Naranjo Fla. Bar # 92923

Attorney or party (Bar # if attorney)

Alberto Naranjo 06/29/2022

(type or print name) Date

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 3 of 16
IN THE CIRCUIT COURT

OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY FLORIDA

)

WILLIAM SANDORFF )

)

Plaintiff, )

)

vs. ) CASE NO.: 2022-012041-CA-01

)

MARY BRICKELL MANAGEMENT, LLC )

and SUNVIEW COMPANIES D/B/A WEST )

BRICKELL HOTEL, LLC )

)

Defendant. )

__________________________________________)

SUMMONS IN A CIVIL CASE

TO: MARY BRICKELL MANAGEMENT, LLC, through its Registered Agent:

Pedro Villar

1001 SW 2nd Ave 3rd Floor

Miami, FL 33130

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

Alberto Naranjo

AN Law Firm, P.A.

7900 Oak Ln # 400 AN Law

Miami Lakes, FL 33016 

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.

_________________________________________

CLERK DATE

_________________________________________

(BY) DEPUTY CLERK

Filing # 154012909 E-Filed 07/25/2022 05:11:26 PM

8/1/2022

Harvey Ruvin,

Clerk of Courts

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 4 of 16
IN THE CIRCUIT COURT

OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY FLORIDA

)

WILLIAM SANDORFF )

)

Plaintiff, )

)

vs. ) CASE NO.: 2022-012041-CA-01

)

MARY BRICKELL MANAGEMENT, LLC )

and SUNVIEW COMPANIES D/B/A WEST )

BRICKELL HOTEL, LLC )

)

Defendant. )

__________________________________________)

SUMMONS IN A CIVIL CASE

TO: SUNVIEW COMPANIES D/B/A WEST BRICKELL HOTEL, LLC, through its Registered 

Agent:

Pedro Villar

1001 SW 2nd Ave 3rd Floor

Miami, FL 33130

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

Alberto Naranjo

AN Law Firm, P.A.

7900 Oak Ln # 400 AN Law

Miami Lakes, FL 33016 

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.

_________________________________________

CLERK DATE

_________________________________________

(BY) DEPUTY CLERK

Filing # 154012909 E-Filed 07/25/2022 05:11:26 PM

8/1/2022

Harvey Ruvin,

Clerk of Courts

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 5 of 16
Filing # 152458682 E-Filed 06/29/2022 04:56:35 PM 

 | 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY FLORIDA 

 

| Case No. : 

WILLIAM SANDORFF, 

Plaintiff, | | 

MARY BRICKELL MANAGEMENT, LLC and SUNVIEW COMPANIES | 

D/B/A WEST BRICKELL HOTEL, LLC, | | 

Defendants. | | | 

/ | 

COMPLAINT | 

1. WILLIAM SANDORF R Plant 1”), brings this action against MARY BRICKELL 

MANAGEMENT, LLC ond SUNVIEW COMPANIES D/B/A WEST BRICKELL HOTEL, 

LLC, (“Defendants”) aleging as follows: 

JURY DEMAND | 

2. Plaintiff demands a trial ty jury on all claims properly triable by : jury. 

PARTIES, VENUE, AND JURISDICTION 

3. Plaintiff was at all relevant times hereto employed by Defi endarts, Plaintiff is over the age of 

18 and is otherwise sui us | H 

4. Defendants are employers within Miami-Dade County, which at al relevant times hereto 

violated Plaintiffs emplogment rights under, the Florida Civil Righ Act (FCRA), Title VII 

H

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 6 of 16
of the Civil Rights Act (Title VII), and/or 42 U.S.C. § 1981 (“Section 1981”). Defendants are 

otherwise sui juris. | 5. Venue is proper in Miami-Dade County because Defendants employed Plaintiff in the county, 

if and because the causesof action otherwise occurred in the County. 

 

6. Venue is also proper inithat Plaintiff and/or Defendants (“Parties”) reside in this district, in 

that a substantial part of the events or omissions giving rise to the claim occurred in this 

district, and in that the Barties are subject to personal jurisdiction in this district with respect 

to this action, and/or thzre is no other district in which the action may otherwise be brought, 

7. All conditions precedent to the bringing of this action have occurred or been performed, i.e., 

a Charge of Discrimination was filed, a Right to Sue Letter issued, and a lawsuit filed before 

the expiration of the Right to Sue letter from the EEOC. 

8. This Court has jurisdiction over this action pursuant as well as supplemental jurisdiction over 

i i Plaintiff’s related claimg arising under federal, state, and/or local laws. 

t H 

i 

COUNT 1 

Retaliation 

FCRA, Title VII and Section 1981 

9. Plaintiff repeats and real eges paragraphs 1 through 8 as if fully set forth herein. 

i i 10. Defendants, despite having different names, operated as one entity, using employees interchangeably, and all entities controlled the terms and conditions of employment for all the 

same employees and/or Plaintiff. 

11. At all relevant times, Pldintifr was an employee of Defendants. { 12. At all relevant times, Plaintiff was and was qualified to work for Defendants. 

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 7 of 16
 

13. At all times material hereto, Defendants failed to comply with the law, which provides, in 

relevant part, the employer may not take any retaliatory personnel action against an employee 

HE i because the employee performed a protected activity and/or had a good-faith, obj ectionably 

reasonable belief for performing such protected activity. 

14. Plaintiff started working for Defendants on December 27, 2019 and was term inated on 

November 18, 2020. | 

15. Plaintiff worked as a Director, assisting with Sales and Marketing. 

i s 

16. Plaintiff was discriminated against due to his National Origin/Race, American Caucasian, i.e. 

his protected category. 1 

17. Plaintiff was terminatediby Allen Neira (Hispanic ~ Venezuela). 

18. Plaintiff was the only employee in his position that was fired and was the only employee of 

his same National Origi /Race. 

19. It's telling, that Plaintiffiwas terminated within months of complaining about discrimination 

to Alberto Ovadia (Hispanic - Venezuela), and later escalating complaints to upper 

management. 

20. Plaintiff complained thay Allen Neira (Hispanic from Venezuela) was excluding Plaintiff 

from meetings and employees would only speak Spanish which Plaintiff does not understand, 

21. Plaintiff had no real “T of the termination as the only significant dissatisfaction ever 

expressed was with the face/color of customers Plaintiff brought to the hotel. 

22. During Plaintiff’s employment, he was able to increase Defendants ranking from worst to top 

3 in almost every ranking from May to November. 

23. The real reason Plaintiffjwas terminated was because of the discrimination complaint just J months before. { 

i 

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 8 of 16
24. 

25. 

26. 

27. 

28. 

 

 

 

 

 

Defendants did not act in good faith, nor did they have an objective, reasonable ground to 

believe that their action did not violate the law. 

As a direct and proximate result of the aforementioned acts, Plaintiff has suffered damages: 

wages, both in the past, present, and future, as well as compensatory damages, etc. 

Defendants’ actions we’e harsh, oppressive, and malicious, and as a further and proximate 

cause, Plaintiff has suff: ed emotional distress. The wrongs done by the Defendants were 

aggravated by the kind of willfulness, wantonness, and malice for which the law allows the 

imposition of exempl amages. Plaintiff, therefore, seeks exemplary damages in a sum to 

be determined by the trier of fact to serve as punishment to deter Defendants from such 

conduct in similar situations, 

Defendants’ actions and conduct as described herein and the resulting damage and loss to 

Plaintiff have necessitatsd Plaintiff’s retaining the services of AN Law Firm, P.A., 7900 Oak 

Lane #400 AN Law, Miami Lakes, FL 33016, to initiate this proceeding. Plaintiff seeks 

recovery of reasonable and necessary attorney’s fees. 

Plaintiff hereby requests jury trial. 

WHEREFORE, PREM SES CONSIDERED, Plaintiff respectfully requests judgment as 

follows: that the court accept jurisdiction over this matter; award Plaintiff for past and future 

i 

loss of wages and benefis, plus interest; award Plaintiff compensatory and punitive damages; 

order Defendants’ to rifstate Plaintiff to a position comparable to the former position or, in 

lieu of reinstatement, avrd front pay (including benefits); injunctive relief, order Defendants 

from refraining from wd action in the future, to attend mandatory training, to have a third 

party administer claims of discrimination/retaliation, to have Defendants develop and 

implement new anti-discimination/retaliation policies and procedures and/or from I + 

} 

H 

| i | 

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 9 of 16
COUNT 2 

Discrimination — National Origin 

FCRA, Title VII and Section 1981 

 

29. Plaintiff repeats and reaileges paragraphs 1 through 8 as if fully set forth herein. 

30. Defendants, despite having different names, operated as one entity, using employees 

interchangeably, and alllentities controlled the terms and conditions of employment for all the 

i 

same employees and/or Plaintiff. 

3 — . At all relevant times, Plaintiff was an employee of Defendants, 

32. At all relevant times, Plaintiff was and was qualified to work for Defendants. 

33. Plaintiff started working for Defendants on December 27, 2019 and was terminated on 

 

November 18, 2020. 

34. Plaintiff worked as a Dirgetor, assisting with Sales and Marketing, 

35. Plaintiff was discriminated against due to his National Origin, American, i.e. his protected 

category. 

36. Plaintiff was terminated . Allen Neira (Hispanic - Venezuela). 

37. Plaintiff was the only canployee i in his position that was fired and was the only employee of | his same National Origin, 

 

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 10 of 16
 

 

 

 

 

 

 

38. Plaintiff was being excluded from meetings by Allen Neira (Hispanic -Venezuela) and 

employees would onl peak Spanish which Plaintiff does not understand. 

 

39. Plaintiff had no real notice of the termination as the only significant dissatisfaction ever 

race/color of customers Plaintiff brought to the hotel. | 

40. During Plaintiffs emple 

expressed was with th 

ment, he was able to increase Defendants ranking from worst to top 

3 in almost every ranking from May to November. 

41. The real reason Plaintiff was terminated was because of his National Origin as there is no 

other truthful reason. 

42. Plaintiff's protected category was the motivating factor for termination as there was no other 

reason for such action. 

 

43. The causal link between ‘Plaintiff ’s protected category and Defendants’ actions by and 

through its employees; caused Defendants’ harassment, discrimination, and/or termination, 

adverse employment actions; lead to a pattern, practice, and/or policy of illegal employment 

<4 

action; misconduct which is 50 regular as to become a de facto policy; failure to enforce any 

3 

policy against such illege! activity; failure to follow Defendants’ own employment policies; 

and/or Defendants took those adverse employment actions in substantial part because of 

Plaintiff’s protected category. 

44. Defendants did not act good faith, nor did they have an objective, reasonable ground to 

believe that their action did not violate the law, 

45. As a direct and proximate result of the aforementioned acts, Plaintiff has suffered damages: i 

wages, both in the past, present, and future, as well as compensatory damages, etc, 

 46. Defendants’ actions wer Ji harsh, oppressive, and malicious, and as a further and proximate 

H cause, Plaintiff has suffered emotional distress. The wrongs done by the Defendants were 

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 11 of 16
47. 

49, 

aggravated by the ine of willfulness, wantonness, and malice for which the law allows the 

imposition of cxempy damages. Plaintiff, therefore, seeks exemplary damages in a sum to 

be determined by the re of fact to serve as punishment to deter Defendants from such 

conduct in similar sitalions. 

Defendants’ actions and conduct as described herein and the resulting damage and loss to 

Plaintiff have necessitated Plaintiff’s retaining the services of AN Law Firm, P.A., 7900 Oak 

Lane #400 AN Law, Miami Lakes, FL 33016, to initiate this proceeding. Plaintiff seeks 

 

WHEREFORE, PREM ES CONSIDERED, Plaintiff respectfully requests judgment as 

 

follows: that the court accept Jurisdiction over this matter; award Plaintiff for past and future | loss of wages and benefits, plus interest; award Plaintiff compensatory and punitive damages; 

order Defendants’ to reinstate Plaintiff to a position comparable to the former position or, in 

lieu of reinstatement, rd front pay (including benefits); injunctive relief, order Defendants 

 

from refraining from sugh action in the future, to attend mandatory training, to have a third 

party administer claims pt discrimination/retaliation, to have Defendants develop and 

implement new stidisciminationstaliion policies and procedures and/or from 

disallowing Defendants’ ‘employees responsible for the actions against Plaintiff to return to 

Defendants property or work for Defendants; award to Plaintiff all costs and reasonable | attorneys' fees incurred j in 1 connection with this action; and grant Plaintiff such additional or 

alternative relief as the Gour deems just and proper and/or which Plaintiff may be entitled to 

 

under the applicable law: 

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 12 of 16
i : i i { 

| 

 

COUNT 3 

| : Discrimination — Race 

| FCRA, Title VII and Section 1981 

H 

t 

50. Plaintiff repeats and reglleges paragraphs 1 through 8 as if fully set forth herein. 

51. Defendants, despite h : g different names, operated as one entity, using employees 

 

interchangeably, and allientities controlled the terms and conditions of employment for all the 

 

 

same employees and/or: Plaintiff, 

52. At all relevant times, ntiff was an employee of Defendants. 

53. At all relevant times, tiff was and was qualified to work for Defendants. 

54. Plaintiff started working or Defendants on December 27, 2019 and was terminated on 

November 18, 2020. | 

55. Plaintiff worked as a Difector, assisting with Sales and Marketing. 

56. Plaintiff was discriminated against due to his Race, American Caucasian, i.e. his protected 

 

category. 

57. Plaintiff was terminated oy Allen Neira (Hispanic - Venezuela). 

58. Plaintiff was the only er 4 loyee in his position that was fired and was the only employee of 

the same Race. | 

59. Plaintiff was excluded fom meetings by Allen Neira (Hispanic -Venezuela) and employees 

would only speak Spans which Plaintiff does not understand. 

60. Plaintiff had no real wri of the termination as the only significant dissatisfaction ever 

expressed was with the ri zce/color of customers Plaintiff brought to the hotel. 

61. During Plaintiff’s emplogiment, he was able to increase Defendants ranking from worst to top | 

 

3 in almost every ranking from May to November, 

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 13 of 16
62. The real reason Plaintiff was terminated was because of his Race as there is no other truthful 

reason. 

63. Plaintiff's protected category was the motivating factor for termination as there was no other 

Pi 

reason for such action. ; 

i! 

64. The causal link betweeri Plaintiffs protected category and Defendants’ actions by and 

through its employees; r caused Defendants’ harassment, discrimination, and/or termination, 

adverse employment actions; lead to a pattern, practice, and/or policy of illegal employment I . . JA action; misconduct which Is so regular . . 

as to become a de facto policy; failure to enforce any 

3 | 

policy against such illegal activity; failure to follow Defendants’ own employment policies; 

and/or Defendants took these adverse employment actions in substantial part because of 

Plaintiff’s protected category. 

65. Defendants did not act i good faith, nor did they have an objective, reasonable ground to 

believe that their action 4 id not violate the law. 

66. As a direct and proximahe result of the aforementioned acts, Plaintiff has suffered damages: 

wages, both in the past, resent, and future, as well as compensatory damages, etc. 

67. Defendants’ actions wes harsh, oppressive, and malicious, and as a further and proximate 

cause, Plaintiff has suffered emotional distress. The wrongs done by the Defendants were 

aggravated by the kind & willfulness, wantonness, and malice for which the law allows the { imposition of exemplary-damages, Plaintiff, therefore, seeks exemplary damages in a sum to 

be determined by the trier of fact to serve as punishment to deter Defendants from such 

conduct SPUR in similar Situatipns. 

4 . i . . . 08. Defendants’ actions and zonduct 

1% 

as described herein and the resulting damage and loss to 

| Plaintiff have necessitated 

i} 

Plaintiff’s retaining the services of AN Law F irm, P.A., 7900 Oak 

H i i} i | g 3 |

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 14 of 16
69. 

70. 

 

Lane #400 AN Law, Miami Lakes, FL 33016, to initiate this proceeding. Plaintiff seeks 

! 

recovery of reasonable and necessary attorney’s fees. 

 

Plaintiff hereby requesis.a jury trial. 

WHEREFORE, PRE SES CONSIDERED, Plaintiff respectfully requests judgment as 

 

follows: that the court accept jurisdiction over this matter; award Plaintiff for past and future 

 

loss of wages and benefits, plus interest; award Plaintiff compensatory and punitive damages; 

 

 order Defendants’ to reinstate Plaintiff to a position comparable to the former position or, in 

lieu of reinstatement, 

rd front pay (including benefits); injunctive relief, order Defendants 

in . from refraining from such action in the 

. future, to attend mandatory training, to have a third 

 

 

party administer claims of discrimination/retaliation, to have Defendants develop and 

implement new anti-distrimination/retaliation policies and procedures and/or from 

disallowing Defendants’ employees responsible for the actions against Plaintiff to return to 

Defendants property or 2votk for Defendants; award to Plaintiff all costs and reasonable 

attorneys’ fees incurred in connection with this action; and grant Plaintiff such additional or 

alternative relief as the ¢ 

 

urt deems just and proper and/or which Plaintiff may be entitled to 

under the applicable [a : 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff respectfully requests judgment as follows: 

A. Accept jurisdiction cer this matter; 

. & i 

B. Award Plaintiff for past and future loss of wages and benefits, plus interest; 

C. Award Plaintiff compensatory and punitive damages; 

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 15 of 16
. Order Defendants 

Vv 

1 

i i to reinstate Plaintiff to a position comparable to the former position or, 

i 

i 4 | | { i bi Ed i i i H 

3 i I i 

in lieu of reinstatement, award front pay (including benefits); 

: i 

 

E. Award to Plaintiff all costs and reasonable attorneys’ fees incurred in connection with this 

action; and | | 

F. Grant Plaintiff such additional or alternative relief as the Court deems just and proper 

and/or which Plaintiff may be entitled to under the applicable laws. 

1 

Dated: June 24, 2022 Respectfully submitted, 

/s/Alberto Naranjo ! 

AN Law Firm, PA. 7900 Oak Lane #400 

Miami Lakes, FL 33016-5888 

United States 

 

i Office: 305-942-8070 

g Email: an@anlawfirm.com 

B Counsel for Plaintiff 

 Bh AAA. pt 5 3  

Case 1:22-cv-23076-JEM Document 1-2 Entered on FLSD Docket 09/23/2022 Page 16 of 16