EXHIBIT A 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 1 of 55
Filing # 147571585 E-Filed 04/12/2022 06:26:40 PM 

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 FIFTEENTH JUDICIAL CIRCUIT, 

IN AND FOR PALM BEACH COUNTY, FLORIDA 

Sandra Weber 

Plaintiff Case # 

Judge 

vs. 

Home Depot USA Inc 

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 

E1 $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. 

1 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 2 of 55
CIRCUIT CIVIL 

❑ Condominium 

❑ Contracts and indebtedness 

o Eminent domain 

o Auto negligence 

o Negligence—other 

❑ Business governance 

O Business torts 

o Environmental/Toxic tort 

o Third party indemnification 

❑ Construction defect 

❑ Mass tort 

❑ Negligent security 

❑ Nursing home negligence 

o Premises liability—commercial 

❑ Premises liability—residential 

❑ Products liability 

o Real Property/Mortgage foreclosure 

❑ Commercial foreclosure 

❑ Homestead residential foreclosure 

❑ Non-homestead residential foreclosure 

O Other real property actions 

OProfessional malpractice 

❑ Malpractice—business 

❑ Malpractice—medical 

❑ Malpractice—other professional 

s Other 

❑ Antitrust/Trade regulation 

❑ Business transactions 

o Constitutional challenge—statute or ordinance 

o Constitutional challenge—proposed amendment 

O Corporate trusts 

s Discrimination—employment or other 

O Insurance claims 

O Intellectual property 

❑ Libel/Slander 

❑ Shareholder derivative action 

CI Securities litigation 

❑ Trade secrets 

❑ Trust litigation 

COUNTY CIVIL 

❑ Small Claims up to $8,000 

❑ Civil 

O Real property/Mortgage foreclosure 

2 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 3 of 55
Jason S Remer 

(type or print name) 

❑ 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 E8] 

IV. REMEDIES SOUGHT (check all that apply): 

• Monetary; 

Nonmonetary declaratory or injunctive relief; 

(81 Punitive 

V. NUMBER OF CAUSES OF ACTION: [ ] 

(Specify) 

3 

VI. IS THIS CASE A CLASS ACTION LAWSUIT? 

❑ yes 

(8) no 

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

® no 

❑ yes If "y s," list all related cases by name, case number, and court. 

VIII„ AS JURY TRIAL DEMANDED IN COMPLAINT? 

® yes 

0 no 

IX. DOES THIS CASE INVOLVE ALLEGATIONS OF SEXUAL ABUSE? 

❑ yes 

21 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/ Jason S Remer Fla. Bar # 165580 

Attorney or party (Bar # if attorney) 

04/12/2022 

Date 

- 3 - 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 4 of 55
Filing # 147571585 E-Filed 04/12/2022 06:26:40 PM 

IN THE CIRCUIT COURT OF THE 

15TH JUDICIAL CIRCUIT IN AND FOR 

PALM BEACH COUNTY, FLORIDA 

SANDARA WEBER, 

Plaintiff, 

vs. 

HOME DEPOT USA, INC. 

Defendant. 

Case No.: 

COMPLAINT 

Plaintiff, SANDRA WEBER ("Plaintiff"), on behalf of herself by and through 

undersigned counsel, in the above styled cause, sue Defendant, HOME DEPOT USA 

(hereinafter referred to as "Defendant"). This action is filed under the Florida Civil Rights Act, 

§760.01, et seq., with respect to disability discrimination and retaliation. Plaintiff states as 

follows: 

JURISDICTION AND VENUE 

1. This action seeks damages as a result of disability discrimination and retaliation against 

on Plaintiff's in violation of the Florida Civil Rights Act, §760.01, et seq., Florida 

Statutes (hereinafter the "FCRA"), 

2. The jurisdiction of the Court over this controversy is based upon the FCRA. 

3. Plaintiff is a covered employee for purposes of the FCRA. 

4. Defendant is authorized to conduct business in Palm Beach County, Florida, where 

Plaintiff worked for Defendant. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 5 of 55
5. Venue is proper in Palm Beach County because all of the actions that form the basis of 

this Complaint occurred within Palm Beach County, the discriminatory acts took place in 

Palm Beach County, and damages exceed $30,000. 

6. As more fully set forth below, Plaintiff filed a Charge of Discrimination with the Equal 

Employment Opportunity Commission ("EEOC") claiming discrimination Charge 510-

2021-03997 on April 30, 2021. 

7. More than 180 days have passed since Plaintiff filed her complaint with the EEOC, the 

1801h day was October 27, 2021. 

8. 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 

9. Plaintiff, a female with herniated discs in her neck, back and has a bulging disc which are 

chronic disabling conditions that qualify plaintiff as disabled under the ADA. 

10. Plaintiff was employed with Defendant from April 11, 2014 through February 17, 2021 

when she was terminated. . 

11. Plaintiff was paid an hourly rate of $13.26 per hour. 

12. Plaintiff worked part time for various hours per week.. 

13. Plaintiff's hour were clocked using a time clock. 

14. Plaintiff was subjected to disparate treatment based on her disability and/or perceived 

disability by Defendant through its supervisors including Kevin (LNU) and Elsa (LNU). 

15. Plaintiff claims the employees without a disability or requests for accommodations 

received preferential treatment from Plaintiff's supervisor. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 6 of 55
16. Plaintiff was injured on the job approximately five years ago and subsequent to this 

injury Defendant started implying that Plaintiff did not know how to do her job. 

17. Plaintiff would regularly be reprimanded for not being at her register while she was 

assisting customers pursuant to store policy. This did not happen to other employees that 

were not disabled. Defendant behaved in this manner as retaliation for her disability. 

18. Due to Plaintiff's prior work injury, she would experience redness in her eye, Defendant, 

though knowing that Plaintiff suffered this injury and that Plaintiff was not sick with Pink 

Eye, would imply same and send her home from work. This occurred on multiple 

occasions throughout Plaintiff's employment, after her work injury and through 

termination. This condition is permanent and qualifies plaintiff under the ADA as 

disabled due to impact on her vision. 

19. Plaintiff was in a car accident on February 4,'2019. 

20. Plaintiff applied for and received short term disability as a result of this motor vehicle 

accident in 2019. 

21. Upon returning from leave, defendant was slow to put the plaintiff back on the schedule 

and was not treated pursuant to store policy and seniority rules with respect to 

scheduling. 

22. Plaintiff can only describe the situation regarding her discriminatory treatment as 

compared to other co-workers by supervisors as favoritism. 

23. Plaintiff requested but was denied advancement while working for Defendant in 

retaliation for her disability. 

24. Plaintiff was an excellent employee and was promoted quickly receiving awards such as 

the Badger Award and is supposed to be rewarded with a $50 incentive for this award and 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 7 of 55
defendant has refused to pay Plaintiff yet has paid other non-disabled employees for this 

achievement. 

25. Plaintiff was not treated the same as other employees. 

26. Plaintiff complained to supervisors Kevin and Elsa. 

27. Plaintiff was terminated due to her disability on February 17, 2021. 

28. Plaintiff had worked for Defendant for years and had the qualifications and certifications 

necessary for the position but Defendant denied promotions giving them to other nondisabled employees based on discrimination for her disability. 

29. Any reason proffered by Defendant for the adverse employment action is mere pretext for 

unlawful discrimination and retaliation. 

COUN4' I 

DISABILITY DISCRIMINATION IN VIOLATION OF THE FCRA 

30. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-29 above as 

if set out in full herein. 

31. Plaintiff is a member of a protected class under the FCRA as she is disabled. 

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

because of Plaintiff's disability and subjected the Plaintiff to disability -based animosity. 

33. Such discrimination was based upon the Plaintiff's disability or perceived disability. 

34. Defendant's conduct complained of herein was willful and in disregard of Plaintiff's 

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

on the basis of Plaintiff's Race unlawful but acted in reckless disregard of the law. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 8 of 55
35. 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. 

36. Defendant retained all employees who exhibited discriminatory conduct toward the 

Plaintiff and did so despite the knowledge of said employees engaging in discriminatory__ 

actions. 

37. 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. 

38. 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 State and/or federal law. 

39. 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 state and/or federal law, to punish the Defendant for its actions and to deter it, and 

others, from such action in the future. 

40. 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 the FCRA, and has done so 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 9 of 55
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; 

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 attorneys' fees 

and; 

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

circumstances. 

COUNT II 

RETALIATION IN VIOLATION OF THE FCRA 

41. Plaintiff re-adopts each and every factual allegation as stated in paragraphs I through 29 

of this Complaint as if set out in full herein. 

42. Defendant is an employer as that term is used under the applicable statutes referenced 

above. 

43. The foregoing allegations establish a cause of action for unlawful retaliation after 

Plaintiff reported unlawful employment practices adversely affecting Plaintiff under the 

FCRA. 

44. The foregoing unlawful actions by Defendant were purposeful. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 10 of 55
45. Plaintiff voiced opposition to unlawful employment practices during employment with 

Defendant and was the victim of retaliation thereafter, as related in part above. 

46. Plaintiff is a member of a protected class because Plaintiff reported unlawful employment 

practices and was the victim of retaliation thereafter. There is a causal connection 

between the reporting of the unlawful employment practices and the adverse employment. 

action taken thereafter. 

47. As a direct and proximate result of the foregoing unlawful acts and omissions, Plaintiff 

has suffered mental anguish, emotional distress, expense, loss of benefits, 

embarrassment, humiliation, damage to reputation, illness, lost wages, loss of capacity for 

the enjoyment of life, and other tangible and intangible damages. 

48. These damages are continuing and are permanent. 

WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter 

judgment against the Defendant; find that the Defendant indeed violated the FRCA and in 

addition, order the following additional relief: 

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

Act; 

H. Award PLAINTIFF compensatory damages for emotional distress, embarrassment 

and humiliation; 

I. Grant a permanent injunction enjoining the DEFENDANT, its officers, successors, 

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

any employment practice which discriminates; 

J. Reinstate PLAINTIFF to the same position she held before the retaliatory personnel 

action, or to an equivalent position; 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 11 of 55
K. Reinstate full fringe benefits and seniority rights to PLAINTIFF; 

L. Order DEFENDANT to make PLAINTIFF whole, by compensating PLAINTIFF for 

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

M. For a money judgment representing prejudgment interest; 

N. Award any other compensation allowed by law including punitive damages an, 

attorney's fees (448.104); 

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

P. Grant PLAINTIFF a trial by jury; and 

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

COUNT III 

Retaliation under Fla. Stat. § 440.205 Against Defendant 

49. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 29 

of this complaint as if set out in full herein. 

50. Plaintiff's work-related injury required medical treatment. 

51. Plaintiff reported his injuries to Defendant through its agent. 

52. Thereafter, Defendant discharged Plaintiff and did not allow him to re-commence work 

for the Defendant. 

53. Plaintiff's work prior to his discharge was satisfactory or more than satisfactory and the 

apparent reason for the termination of Plaintiff's employment was that Plaintiff sought or 

attempted to seek compensation under Florida Workers' Compensation Law, as Plaintiff 

was entitled to do. 

54. The motivating factor which caused Plaintiff's discharge as described above was the 

request and/or attempted request for worker's compensation benefits pursuant to Fla. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 12 of 55
Stat. §§ 440 et. seq. In other words, the Plaintiff would not have been fired but for 

claiming worker's compensation benefits. 

55. Defendant's termination of Plaintiff was in direct violation of Fla. Stat. § 440.205 and, as 

a direct result, Plaintiff has been damaged. 

56. By reason of Defendant's wrongful discharge of Plaintiff, Plaintiff has been damaged mi. 

that Plaintiff has suffered lost wages and has suffered emotional distress. 

57. Defendant's conduct in wrongfully discharging Plaintiff was willful, wanton, and in 

reckless disregard of Plaintiff's rights and therefore Plaintiff is entitled to punitive 

damages. 

WHEREFORE Plaintiff respectfully requests judgment against the Defendant for all 

back wages from the date of discharge to the present date and an equal amount of back wages as 

liquidated damages; costs; injunctive relief prohibiting the Defendant from wrongfully 

discharging in the manner described above; front wages; and for any and all other relief that this 

Court may deem just and proper. 

JURY DEMAND 

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

Dated: April 12, 2022. Respectfully submitted, 

/s/ 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, FL 33130 

Telephone: (305) 416-5000 

Facsimile: (305) 416-5005 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 13 of 55
Filing # 147571585 E-Filed 04/12/2022 06:26:40 PM 

IN THE CIRCUIT COURT OF THE 

15TH JUDICIAL CIRCUIT IN AND FOR 

PALM BEACH COUNTY, FLORIDA 

SANDARA WEBER, 

Plaintiff, 

vs. 

HOME DEPOT USA, INC. 

Defendant. 

Case No.: 

SUMMONS IN A CIVIL CASE 

TO: HOME DEPOT USA, INC., through its Registered Agent:. 

CORPORATION SERVICE COMPANY 

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, SUITE 2200 

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. 

JOSEPH ABRUZZO 

CLERK 

Apr 14 2022 

DATE 

(BY) DEPUTY CLERK 

BLAKE SMITH 

QUIT C000 , 

61-104.-•-

V e9 

tiP.Acti co‘'. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 14 of 55
IN THE CIRCUIT COURT FOR THE FIFTEENTH JUDICIAL CIRCUIT 

IN AND FOR PALM BEACH COUNTY, FLORIDA 

IN RE: STANDING ORDER FOR 

CASE MANAGEMENT FOR SUBMISSION 

OF AGREED CASE MANAGEMENT PLAN FOR 

CASES FILED ON OR AFTER APRIL 30, 2021 

STANDING ORDER FOR CASE MANAGEMENT AND SUBMISSION OF AGREED 

CASE MANAGEMENT PLAN IN CIVIL CASES 

IN THE FIFTEENTH JUDICIAL CIRCUIT FILED ON OR AFTER APRIL 30, 2021 

(DCMSO) 

Pursuant to Florida Rule of Civil Procedure 1.200(a), Florida Rule of General Practice and 

Judicial Administration 2.545, and Administrative Order 3.107 entered by the Chief Judge of this 

Circuit, the parties are informed of the following information and procedures applicable to civil 

lawsuits filed in the Circuit Court on or after April 30, 2021: 

1. SERVICE OF THIS ORDER. The Plaintiff is directed to serve a copy of this Order 

with each Summons issued in this case: One copy of this Order is to.be filed with the Clerk of the 

Circuit Court with proof of service. 

2. CIVIL CASE MANAGEMENT SYSTEM. The Supreme Court of Florida has 

established guidelines for the prompt processing and resolution of civil cases. This Court has 

adopted a case management system to help meet those guidelines. In contested cases, the parties 

are required to participate in the case management system. The case management system requires 

early consultation and cooperation among the parties for the preparation and submission of an 

Agreed Case Management Plan and early involvement by the Court. The Agreed Case 

Management Plan requires the parties to identify a case track, confer in good faith and attempt to 

narrow the matters in controversy, identify the issues that require direct involvement by the Court, 

and establish a schedule for addressing those issues•' The Agreed Case Management Plan may be 

accessed at the Court's website at: https://l5thcircuit.com/civil-differentiated-forms-and-orders.

Unless all of the Defendants have been served and have been defaulted or dropped, an Agreed 

Case Management Plan must be submitted to the assigned divisional queue via the Court's online 

scheduling system (OLS) as an attachment, in PDF format, to a proposed Order Accepting Agreed 

Case Management Plan on or before 130 days from the date of filing of the initial complaint. If 

the parties are unable to agree on an Agreed Case Management Plan by the applicable deadline, a 

I Case Track options include Expedited, Streamlined, General, or Complex. Case Tracks have been 

established in order to comply with the case disposition standards set forth in Florida Rule of General 

Practice and Judicial Administration 2.250(a)(1)(B). 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 15 of 55
case management conference will be scheduled by the Court or the. Court will review and issue an 

Order Implementing Case Management Plan without agreement of the Parties. No matters that 

arise as a result of this standing order, including lack of agreement, will be set on the Court's 

Uniform Motion Calendar and will, instead, be settled by the Court either at the case management 

conference or via an Order Implementing Case Management Plan without agreement of the parties. 

If a case management conference is scheduled, attendance by trial counsel and those parties who 

are not represented by counsel is mandatory. 

If all Defendants are served and defaulted or dropped, the Plaintiff will file the appropriate 

documentation to pursue a Default Final Judgment within 130 days of the filing of the complaint 

and Final Judgment is to be entered or set for hearing within 150 days of the filing of the complaint. 

3. MEDIATION/ALTERNATIVE DISPUTE RESOLUTION (ADM. ADR 

provides parties with an out-of-court alternative to settling disagreements. Mediation is a type of 

ADR wherein an independent third party attempts to arrange a settlement at a conference between 

the parties. The Court requires the parties to participate in Mediation prior to trial unless the parties 

agree to another form of ADR. 

DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, 

Florida, on this 26 day of April, 2021.. 

1 it. a-fit: 

• 

-A fli!q151 - I/ATIVI: CP l'FI CE Or r11t t: 

Administrative Circuit Judge 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 16 of 55
RECEIPT a wl Cou,,,_ 

--V,r, 

• *. 

L 

`EACH C° 

JOSEPH ABRUZZO 

CLERK OF THE CIRCUIT COURT & COMPTROLLER 

PALM BEACH COUNTY, FLORIDA 

4426852 

Printed On: 

04/14/2022 11:16 

Page 1 of 1 

Receipt Number: 4426852 - Date 04/1412022 Time 11:16AM 

Received of: Jason S Remer 

44 West Flagler Street 

Miami, FL 33130 

Cashier Name: ADMIN Balance Owed: 411.00 

Cashier Location: E-Filing Total Amount Paid: 411.00 

Receipt ID: 10778097 Remaining Balance: ' 0.00 

Division: AD: Circuit Civil Central - AD(Civil) 

Case# 50-2022-CA-003492-)OCXX-MB -- PLAINTIFF/PETITIONER: WEBER, SANDRA 

Item Balance Paid Bal Remaining 

Fees 411.00 411.00 0.00 

Case Total 411.00 411.00 0.00 

Payments 

Type Ref# Amount 

EFiling_ACH 

Total Received 

Total Paid 

3436756 411.00 

411.00,

411.00 

How was your service today? Please visitywww.mypalmbeachclerk.com/survey or send your 

feedback to clerkweb@mypalmbeachclerk.com.

For office locations and information about Clerk & Comptroller services: 

Visit www.mvoalmbeachclerk.com or call (561) 355-2996. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 17 of 55
Filing # 150257634 E-Filed 05/25/2022 09:46:05 AM 

IN THE CIRCUIT COURT OF THE 

15TH JUDICIAL CIRCUIT IN AND 

FOR PALM BEACH COUNTY, 

FLORIDA 

SANDARA WEBER, 

Plaintiff, CASE NO: 2022-CA-003492 

v. 

HOME DEPOT USA, INC., 

Defendant. 

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT 

OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT 

Defendant Home Depot USA, Inc. hereby moves for a 14-day enlargement of time, 

through and including June 14, 2022, to respond to Plaintiff's' Complaint. In support of this 

Motion, Defendant states the following: 

1. Plaintiff served initial Process`on Defendant on or about May 9, 2022. Thus, 

Defendant's response is presently due on May 31, 2022. 

2. Defendant's undersigned counsel was just recently assigned to defend this action. 

Thus, Defendant requires additional time to investigate the averments in Plaintiffs Complaint. 

3. For the reasons described above, Defendant requires a 14-day extension of time to 

prepare a response to Plaintiff's Complaint. 

4. This motion is not being presented for purposes of delay or any other improper 

purpose. The requested extension will not prejudice Plaintiff or any other individual with an 

interest in this action. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 18 of 55
5. Counsel for Defendant certifies that he has consulted with Plaintiff's counsel in an 

effort to resolve the relief requested herein by agreement. Plaintiff's counsel Jason Remer, 

Esquire, agreed to the requested 14-day extension for Defendant to respond to Plaintiff's 

Complaint, through and including June 14, 2022. 

6. For the reasons described above, good cause exists for the requested extension. 

WHEREFORE, Defendant Home Depot USA, Inc., requests a 14-day enlargement of 

time, through and including June 14, 2022, within which to respond to Plaintiff's Complaint. 

Dated: May 25, 2022. 

Respectfully submitted, 

OGLETREE, DEAKINS, NASH, 

SMOAK & STEWART, P.C. 

9130 S. Dadeland Blvd., Suite 1625 

Miami, Florida 33156 

Telephone: 305.374.0506 

Facsimile: 305.374.0456 

s/ Gregory R. Hawran 

Christopher P. Hammon 

Florida Bar Number 176753 

chris.hammon@ogletree.com 

Gregory R. Hawran 

Florida Bar Number 55989 

gregory.hawran@ogletree.com 

Counsel for Defendant Home Depot USA, Inc. 

2 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 19 of 55
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on May 25, 2022, the foregoing document is being provided 

this day on all counsel of record identified on the attached Service List in the manner specified. 

s/ Gregory R. Hawran 

Gregory R. Hawran 

3 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 20 of 55
SERVICE LIST 

Sandara Weber v. Home Depot USA, Inc. 

15th Judicial Circuit in and for Palm Beach County, Florida 

Case No. 2022-CA-003492 

Jason S. Remer 

REMER & GEORGES-PIERRE, PLLC 

44 West Flagler Street 

Suite 2200 

Miami, Florida 33130 

Telephone: 305.416.5000 

Facsimile: 305.416.5005 

Email: jremer@rgpattorneys.com 

Counsel for Plaintiff „, 

Method of Service: eFiling Portal 

Christopher P. Hammon 

chris hammon@ogletree.com 

Gregory R. Hawran 

gregory.hawran@ogletree.com 

OGLETREE, DEAKINS, NASH, 

SMOAK & STEWART, P.C. 

9130 S. Dadeland Blvd., Suite 1625 

Miami, Florida 33156 

Telephone: 305.374.0506 

Facsimile: 305.374.0456 

Counsel for Defendant 

4 

51645942.v1-OGLETREE 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 21 of 55
Filing # 150310226 E-Filed 05/25/2022 03:45:41 PM 

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR 

PALM BEACH COUNTY, FLORIDA 

CIRCUIT CIVIL DIVISION AD 

CASE NO. 50 2022-CA-003492 XXXXMB 

SANDRA WEBER, 

Plaintiff, 

v. 

HOME DEPOT USA, INC., 

Defendant. 

AGREED ORDER GRANTING DEFENDANT'S UNOPPOSED MOTION FOR 

ENLARGEMENT OF TIME 

THIS ACTION came before the Court on Defendant, Home Depot USA, Inc.'s 

Unopposed Motion for Enlargement of Time to Respond to Plaintiff's Complaint. The Court 

having reviewed the motion, considered the agreement of the parties, and being otherwise fully 

advised in the premises, it is hereby 

ORDERED AND ADJUDGED that the Motion be and the same is hereby GRANTED. 

Defendant shall have to and including June 14, 2022 in which to file its Response to Plaintiff's 

Complaint. 

DONE AND ORDERED in Chambers, at West Palm Beach, Florida. 

:fit),120.22:6Aiaiia4kiivy%.?%,:mEi:,70512 ;u?272,;.-er .;!;..;;„ • ., •

- • • • • ""?.

a 4)&tilizifb kk,Jtba,kb 

.400t0: "c raiii;;Judge 4... • 

Copies furnished: 

via Judicial E-Service: 

Jason S. Remer, Esq., 44 W. Flagler Street, Suite 2200, Miami, FL 33130; 

jremerQrgpattorneys.com;ngazimiloie_meom • n ,• pn@rgpattorneys.com 

via U.S. Mail: 

Home Depot USA, Inc. 

c/o Corporation Service Company 

1201 Hays Street 

Tallahassee, FL 32301 

Page 1 of 1 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 22 of 55
Filing # 151434494 E-Filed 06/14/2022 09:57:50 AM 

IN THE CIRCUIT COURT, 15TH 

JUDICIAL CIRCUIT IN AND FOR 

PALM BEACH COUNTY, FLORIDA 

CASE NO.: 2022-CA-003492 

SANDARA WEBER, 

Plaintiff, 

vs. 

HOME DEPOT U.S.A., INC., 

Defendant. 

DEFENDANT'S ANSWER AND DEFENSES TO PLAINTIFF'S COMPLAINT 

Defendants Home Depot U.S.A, Inc. ("Defendant" or "Home Depot"), pursuant to Fla. R. 

Civ. P. 1.110(c), hereby answers the numbered paragraphs of the Complaint filed by Plaintiff 

• 

Sandra Weber and presents the following defenses: 

"JURISDICTION AND VENUE" 

1. Paragraph 1 of the Complaint contains a legal conclusion to which no response is 

required. To the extent a response is required, Defendant does not contest that Plaintiff purports 

to bring suit pursuant to the Florida Civil Rights Act, § 760.01 et seq. (FCRA) but Defendant 

denies violation of any law and denies the existence of facts and circumstances justifying relief. 

2 Defendant admits only that this Court has subject matter jurisdiction over this 

action. 

3. Defendant admits only that it employed Plaintiff at one time. Otherwise, denied. 

4. Admitted. 

5. Defendant admits that venue is proper in Palm Beach County, Florida. 

Otherwise, denied. Defendant specifically denies that it has violated any law arising from 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 23 of 55
Plaintiff's employment with Home Depot or otherwise, or that any action has occurred that 

would entitle Plaintiff to any relief 

6. Defendant is without knowledge or information sufficient to form a belief as to 

the allegations in this paragraph and therefore denies them. 

7. Defendant is without knowledge or information sufficient to form a belief as to 

the allegations in this paragraph and therefore denies them. 

8. Defendant is without knowledge or information sufficient to form a belief as to 

the allegations in this paragraph and therefore denies them. 

"FACTUAL ALLEGATIONS COMMON TO ALL COUNTS" 

9. Defendant admits only that Plaintiff identifies as a female. Defendant is without 

knowledge or information sufficient to form a belief as to the remaining allegations in this 

paragraph and therefore denies them. 

10. Defendant admits only that it employed Plaintiff rom on or about April 13, 2014 

through on or about February 17,''2021. 

11. Admitted. 

12. Defendant admits that Plaintiff worked in a part-time status. Otherwise, denied. 

13 , Defendant admits that Plaintiff was an hourly employee who clocked in at the 

beginning of her shift and clocked out at the end of her shift. 

14. Denied. 

15. Denied. 

16. Denied. 

17. Defendant admits only that management reprimanded Plaintiff on numerous 

occasions for violations of various store policies and procedures. Otherwise, denied. 

2 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 24 of 55
18. Denied. 

19. Defendant is without knowledge or information sufficient to form a belief as to 

the allegations in this paragraph and therefore denies them. 

20. Defendant admits only that Plaintiff was approved for short term disability 

benefits between December 19, 2019 and February 29, 2020. Otherwise, denied. 

21. Denied. 

22. Denied. 

23. Denied. 

24. Denied. 

25. Denied. 

26. Denied. 

27. Defendant admits only that it terminated Plaintiffs employment with the 

company on or about February 17, 2021 for violation of Home Depot's attendance policy. 

Otherwise, denied. 

28. Defendant admits only that it employed Plaintiff at one time. Otherwise, denied. 

29. Denied. 

"COUNT I" 

"DISABILITY DISCRIMINATION IN VIOLATION OF THE FCRA" 

30. Defendant readopts and re-alleges its responses to Paragraphs 1 through 29 as if 

fully set forth herein. 

31. Denied. 

32. Denied. 

33. Denied. 

3 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 25 of 55
34. Denied. 

35. Denied. 

36. Denied. 

37. Denied. 

38. Denied. 

39. Denied. 

40. Denied. 

Defendant denies that Plaintiff is entitled to any of the relief requested in the unnumbered 

"WHEREFORE" clause following Paragraph 40 of Plaintiff's Complaint 

"COUNT II" 

"RETALIATION IN VIOLATION OF THE FCRA" 

41. Defendant readopts and re-alleges its responses to Paragraphs 1 through 29 as if 

fully set forth herein. 

42. Defendant admits only that it employed Plaintiff at one time. Otherwise, denied. 

43. Denied. 

44. Denied. 

45. > Denied. 

46. Denied. 

47. Denied. 

48. Denied. 

Defendant denies that Plaintiff is entitled to any of the relief requested in the unnumbered 

"WHEREFORE" clause following Paragraph 48 of Plaintiff's Complaint. 

4 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 26 of 55
"COUNT III" 

"RETALIATION UNDER FLA. STAT. § 440.205 AGAINST DEFENDANT" 

49. Defendant readopts and re-alleges its responses to Paragraphs 1 through 29 as if 

fully set forth herein. 

50. Defendant is without knowledge or information sufficient to form a belief as to, 

the allegations in this paragraph and therefore denies them. 

51. Defendant is without knowledge or information sufficient to form a belief as to 

the allegations in this paragraph and therefore denies them. 

52. Denied. 

53. Denied. 

54. Denied. 

55. Denied. 

56. Denied. 

57. Denied. 

Defendant denies that Plaintiff is entitled to any of the relief requested in the unnumbered 

"WHEREFORE" clause following Paragraph 57 of Plaintiff's Complaint. 

"JURY DEMAND" 

Defendant admits that Plaintiff demands a jury trial. 

AFFIRMATIVE AND OTHER DEFENSES 

Defendant denies each and every allegation in Plaintiff's Complaint that is not expressly 

admitted in this Answer. Defendant does not assume the burden of any defense asserted that is 

adjudged not to be an affirmative defense. Defendant also reserves the right to assert additional 

affirmative defenses and matters in avoidance that may be disclosed by additional investigation 

5 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 27 of 55
and discovery. Defendant asserts the following defenses, each as a separate and distinct defense 

to Plaintiff's alleged causes of action as well as to the entire Complaint. 

FIRST DEFENSE 

The Complaint should be dismissed, in whole or in part, to the extent it fails to state a 

claim upon which relief can be granted. 

SECOND DEFENSE 

All actions taken by Defendant and its agents with regard to Plaintiff were based on 

legitimate and reasonable business factors, and not in any way related to any discriminatory or 

retaliatory intent. 

THIRD DEFENSE 

Plaintiff's claims against Defendant are barred, in whole or in part, because all actions 

taken by Defendant regarding or affecting Plaintiff were based upon valid, legitimate, nonretaliatory, and reasonable business reasons that were not the result of any intention or purpose, 

past or present, to retaliate. 

FOURTH DEFENSE 

Defendant's actions with regard to Plaintiff's employment were job-related and 

consistent with business necessity. 

FIFTH DEFENSE 

Any improper, illegal, or retaliatory acts taken against Plaintiff by any employee of 

Defendant occurred outside of the course and scope of employment, were contrary to 

Defendant's policies, and were not ratified, confirmed, or approved by Defendant. Thus, any 

such actions cannot be attributed or imputed to Defendant. 

6 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 28 of 55
SIXTH DEFENSE 

Plaintiff is not a handicapped individual under Chapter 760, Florida Statutes. 

SEVENTH DEFENSE 

Plaintiff was not a "qualified individual with a disability" as those terms have been 

defined and/or interpreted under the Americans with Disabilities Act and/or Chapter 760, Florida;, 

Statutes. 

EIGHTH DEFENSE 

Defendant exercised reasonable care to prohibit, prevent, and promptly correct 

discriminatory, retaliatory or unlawful behavior, if any. Defendant has a policy prohibiting 

discrimination and retaliation and a procedure by which its employees should inform it of any 

such complaints. The policy provides that such complaints will be the subject of prompt remedial 

action reasonably calculated to end alleged discrimination and retaliation. Defendant cannot be 

held liable for alleged injuries where Plaintiff failed to take advantage or use preventative or 

corrective procedures provided in due care by Defendant to avoid harm or for acts of its 

employees committed outside the scope of employment. 

NINTH DEFENSE 

Without conceding that Plaintiff has suffered any damages as a result of any wrongdoing 

by Defendant, Plaintiff's damages demands are limited to the extent that Plaintiff has failed to 

reasonably mitigate such damages. 

TENTH DEFENSE 

To the extent Plaintiff's cause of action, claim and item of damages did not accrue within 

the time prescribed by law for them before this action was brought, such claims must be 

dismissed. 

7 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 29 of 55
ELEVENTH DEFENSE 

Plaintiff's claims are barred, either in whole or in part, by the applicable statute of 

limitations. 

TWELFTH DEFENSE 

Defendant reserves the right to assert the after-acquired evidence defense should 

Defendant uncover evidence during the course of this action that would otherwise justify any 

action taken with respect to Plaintiff The discovery of any such evidence would bar any 

recovery of damages by Plaintiff. 

THIRTEENTH DEFENSE 

Plaintiff's claim is barred by the equitable doctrines of estoppel, waiver, unclean hands 

and/or laches. 

FOURTEENTH DEFENSE 

At all times relevant to this suit, Defendant acted in good faith with regard to Plaintiff, 

and had reasonable grounds for believing that its actions were not in violation of any law, rule, or 

regulation. 

FIFTEENTH DEFENSE 

Plaintiff's claims are barred in whole or in part to the extent Plaintiff failed to exhaust 

administrative remedies, or brings claims or relies upon facts which exceed the scope of or are 

inconsistent with Plaintiff's FCHR and EEOC charge(s), or are time barred by the applicable 

limitations period for such claims. Further, Plaintiff must exhaust all mandatory administrative 

remedies. 

8 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 30 of 55
SIXTEENTH DEFENSE 

Without conceding that Plaintiff has suffered any damages as a result of any wrongdoing 

by Defendant, Plaintiff's damages demands must be set off against or reduced by any wages, 

compensation or other benefit received by Plaintiff or which was earnable or receivable with the 

exercise of due diligence by Plaintiff. 

SEVENTEENTH DEFENSE 

Without conceding that Plaintiff has suffered any damages as a result of any wrongdoing 

by Defendant, Plaintiffs alleged damages are controlled and/or are limited by ihedamages caps 

imposed by state law and Constitutional limits. 

EIGHTEENTH DEFENSE 

There should be no award of compensatory damages for mental anguish or emotional 

distress absent expert medical testimony concerning the cause and existence of any emotional or 

mental injury. 

NINETEENTH DEFENSE 

The punitive damages demanded in the Complaint are barred in whole on the grounds 

that Plaintiff failed to allege any actionable conduct on behalf of Defendant that would support 

an award for punitive damages. 

TWENTIETH DEFENSE 

In the alternative, the punitive damages demanded in the Complaint are barred in whole 

on the grounds that any actionable conduct on behalf of Defendant was not willful, wanton, or 

negligent, such that no punitive damages should be awarded. 

9 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 31 of 55
TWENTY-FIRST DEFENSE 

Plaintiff's request for attorneys' fees and costs is in part discretionary before this Court, 

and therefore, any amount awarded must be limited by the requirement, including, but not 

limited to, that Plaintiff be successful on the merits and that fees and costs awarded be 

reasonable and necessary. 

TWENTY-SECOND DEFENSE 

To the extent that the relief sought by Plaintiff falls under the exclusive remedy of 

Florida Worker's Compensation Benefits Law, Plaintiff cannot recover. _ 

TWENTY-THIRD DEFENSE/:. 

To the extent that Plaintiff failed to engage in valid protected activity under Chapter 440, 

Florida Statutes, Plaintiff is barred from recovery.,

TWENTY-FOURTH DEFENSE 

Plaintiff is barred from any injunctive relief sought because Plaintiff has adequate 

remedies at law. 

WHEREFORE, Defendant prays that the Complaint be dismissed with prejudice, that 

judgment be entered in favor of Defendant and against Plaintiff, and that Defendant be awarded 

its costs and reasonable attorneys' fees and such other relief the Court deems appropriate. 

10 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 32 of 55
Dated: June 14, 2022. 

Respectfully submitted, 

OGLETREE, DEAKINS, NASH, 

SMOAK & STEWART, P.C. 

9130 S. Dadeland Boulevard 

Suite 1625 

Miami, Florida 33156 

Telephone: 305.374.0506 

Facsimile: 305.374.0456 

s/ Grego!), R. Hawran 

Christopher P. Hammon 

Florida Bar No. 176753 

chris.hamtnon@ogletreedeakins.com 

Gregory R. Hawran 

Florida Bar No. 55989 

gregory.hawran@ogletreedeakins.com 

:Counsel for Defendant, 

Home Depot U.S.A., Inc. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 33 of 55
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on June 14, 2022, the foregoing document is being served this 

day on all counsel of record or pro se parties identified on the attached Service List in the 

manner specified. 

s/ Gregory R. Hawran 

Gregory R. Hawran 

12 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 34 of 55
SERVICE LIST 

Sandara Weber• v. Home Depot U.S.A., Inc. 

15th Judicial Circuit in and for Palm Beach County, Florida 

CASE NO.: 2022-CA-003492 

Jason S. Remer 

jremer@rgpattorneys.com 

REMER & GEORGES-PIERRE, PLLC 

44 West Flagler 

Suite 2200 

Miami, FL 33130 

Telephone: 305.416.5000 

Facsimile: 305.416.5005 

Counsel for Plaintiff, Sandara Weber 

Method of Service: Florida E-Filing Portal 

Christopher P. Hammon 

cluis.hammon@ogletreedeakins.com 

Gregory R. Hawran 

gregory.hawran@ogletreedeakins.coni 

OGLETREE, DEAKINS, NASH, 

SMOAK & STEWART, P.C. 

9130 S. Dadeland Boulevard 

Suite 1625 

Miami, Florida 33156 

Telephone: 305.374.0506 

Facsimile: 305.374.0456 

Counsel for Defendant, 

Home Depot U.S.A., Inc. 

13 

51498249.v1-OGLETREE 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 35 of 55
filing # 153206126 E-Filed 07/12/2022 09:32:31 PM 

IN THE CIRCUIT COURT, 15TH JUDICIAL 

CIRCUIT IN AND FOR PALM BEACH 

COUNTY, FLORIDA 

CASE NO.: 2022-CA-003492XXXXMB 

SANDARA WEBER, 

Plaintiff, 

vs. 

HOME DEPOT U.S.A., INC., 

Defendant. 

NOTICE OF APPEARANCE AS COUNSEL 

( 

4 

PLEASE TAKE NOTICE that the undersigned counsel, Mercy'rKLPina-Brito, Esq., hereby tiles 

this Notice of Appearance as counsel on behalf of the Plyinfiti Ville above-styled cause. The 

undersigned associate counsel requests that copies of ai,L,Nst1dhols; notices, correspondence, and 

communications of any type, be furnished to her in ac.cdrdaRueftherewith. 

7. ` 

Dated: July 12, 2022. 

Respectffilly submitted, 

/s/Mercy 13. Pina-Brito 

REMER & GEORGES-PIERRE, PLLC 

Jason S. Reiner, Esq. 

Florida Bar No. 0165580 

jremer@)rgpattorneys.eom 

Mercy 13. Pina-Brito, Esq. 

Florida Bar No. 135161 

mpbqtrgpattorneys.com 

Courthouse Tower 

44 West Flagler Street, 

Suite 2200 Miami, FL 33130 

Tel: (305) 416-5000 

Fax: (305) 416-5005 

Attorney for Plaintiff 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on July 12, 2022 the undersigned counsel has electronically filed the 

foregoing document with the Clerk of Court using the Florida Courts E- filing Portal. I also certify 

that the foregoing document is being served on this day on all counsel of record or pro se parties, 

either via electronic transmission of Notices generated by the Florida Courts Efiling Portal or in 

some other authorized manner for those counsel or parties who are not authorized to receive such 

Notices. By: /s/Mercy B. Pina-l3rito Mercy B. Pina-Brito, Esq. Florida Bar No. 135161. 

I crl• DAI Pul DCAf•LI r•ni lArTV CI IflOCOLI AUDI I7 -7r1 f-NI CM/ f17/4ninfIntl rinolf).024 DI

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 36 of 55
CASE NO.: 2022-CA-003492XXXXMB 

SERVICE LIST 

OGLETREE, DEAKINS, NASH, 

SMOAK & STEWART, P.C... 

Christopher P. Hammon 

Florida Bar No. 176753 

chris.liammon@ogletreedeakins.com 

Gregory R. Haman 

Florida Bar No. 55989 

O-egory.hawran@ogletreedeakins.com 

9130 S. 1)adcland Boulevard 

Suite 1625 

Miami, Florida 33156 

Telephone: 305.374.0506 

Facsimile: 305.374.0456 

Counsel for Defendant, 

Home Depot U.S.A., roe. 

,r Zak

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 37 of 55
Filing # 153379527 E-Filed 07/14/2022 08:34:19 PM 

IN THE CIRCUIT COURT, 15TH JUDICIAL 

CIRCUIT IN AND FOR PALM BEACH 

COUNTY, FLORIDA 

CASE NO.: 2022-CA-003492XXXXMB 

SANDARA WEBER, 

Plaintiff, 

vs. 

HOME DEPOT U.S.A., INC., 

Defendant. 

PLAINTIFF'S NOTICE OF SERVING PLAINTIFF'S FIRST SET OF 

INTERROGATORIES PROPOUNDED ON DEFENDANT HOME DEPOT U.S.A., INC. 

Plaintiff, SANDRA WEBER ("Plaintiff'), by alyCilyp g ) undersgned i counsel, hereby 

Y 

gives notice of the service upon Defendant, HOME pgPOTO:S.A., INC., via e-mail of Plaintiff s 

First Set of Interrogatories to Defendant pursont•fkRitje 1.340, Florida Rules of Civil Procedure. 

Dated: July 14, 2022. 

Respectfully submitted, 

/s/Mercy B. Pina-Brito 

REMER & GEORGES-PIERRE, PLLC 

Jason S. Reiner, Esq. 

Florida Bar No. 0165.580 

3. jy_emer(q)rgpattorneys.com 

Mercy B. Pina-Brito, Esq. 

Florida Bar No. 135161 

imt).@r,gpattorneys.com 

Courthouse Tower 

44 West Flagler Street, 

Suite 2200 Miami, FL 33130 

Tel: (305) 416-5000 

Fax: (305) 416-5005 

Attorney for Plaintiff 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 38 of 55
CASE NO.: 2022-CA-003492XXXXMB 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on July 14, 2022 the undersigned counsel has electronically 

filed the foregoing document with the Clerk of Court using the Florida Courts F- filing Portal. I 

also certify that the foregoing document is being served on this day on all counsel of record or pro 

se parties, either via electronic transmission of Notices generated by the Florida Cottrts Efiling 

1 

Portal or in some other authorized manner for those counsel or parties who are riot authorized to 

receive such Notices. By: /s/Mercy B. Pina-Brito Mercy B. Pina-Brito;, Es4:'Florida Bar No. 

135161. 

SERVICE LIST 

OGLETREE, DEAKINS, NASH, 

SMOAK & STEWART, P.C. 

Christopher P. Hammon 

Florida Bar No. 176753 

chris.hammon@ogletreedeakins.com-,,, 

Gregory R. Hawran 

Florida Bar No. 55989 

gregory.hawran@ogletreedOlcins.com 

9130 S. Dadeland Boulevard 

Suite 1625 

Miami, Flori433156 

Telephone:"30,5.374.0506 

Facsimile:. 305.374.0456 

Counsel for Defendant, 

Home Depot U.S.A., Inc. 

sj 

2 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 39 of 55
Filing # 153379527 E-Filed 07/14/2022 08:34:19 PM 

IN THE CIRCUIT COURT, 15TH JUDICIAL 

CIRCUIT IN AND FOR PALM BEACH 

COUNTY, FLORIDA 

CASE NO.: 2022-CA-003492XXXXMB 

SANDARA WEBER, 

Plaintiff, 

vs. 

HOME DEPOT U.S.A., INC., 

Defendant. 

PLAINTIFF'S NOTICE OF SERVING PLAINTIFF'S FIRST I. QUEST FOR 

PRODUCTION TO DEFENDANT HOME DEPQT INC. 

Plaintiff, SANDRA WEBER ("Plaintiff'), by ansl/throlWundersigned counsel, hereby 

k„, 7

gives notice of the service upon Defendant, HOME DEPOT .A., INC., via e-mail of Plaintiff's 

First Request for Production to Defendant„pursuaiit-to Rule 1.350, Florida Rules of Civil 

Procedure. 

za 

Dated: July 14, 2022. 

Respectfully submitted, 

/s/Mercy B. Pina-Brito 

REMER & GEORGES-PIERRE, PLLC 

Jason S. Reiner, Esq. 

Florida Bar No. 0165580 

jrctileignmattgowp,com 

Mercy B. Pina-Brito, Esq. 

Florida Bar No. 135161 

mpb@rgpattorneys.com 

Courthouse Tower 

44 West Flagler Street, 

Suite 2200 Miami, FL 33130 

Tel: (305) 416-5000 

Fax: (305) 416-5005 

Attorney for Plaintiff 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 40 of 55
CASE NO.: 2022-CA-003492XXXXMB 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on July 14, 2022 the undersigned counsel has electronically 

filed the foregoing document with the Clerk of Court using the Florida Courts E- filing Portal. I 

also certify that the foregoing document is being served on this day on all counsel of re/cord or pro 

se parties, either via electronic transmission of Notices generated by the Florida Court s Efiling 

Portal or in some other authorized manner for those counsel or parties who arc not,authorized to 

receive such Notices. By: /s/Mercy B. Pina-Brito Mercy B. Pina-Brito,. Esci Florida Bar No. 

135161. 

SERVICE LIST 

OGLETREE, DEAKINS, NASH, 

SMOAK & STEWART, P.C. 

Christopher P. Hammon 

Florida Bar No. 176753 

chris.hammon@ogletreedeakins.cOm 

Gregory R. Hawran 

Florida Bar No. 55989 

gregoryhawran@ogletreedeakins.com 

9130 S. Dadeland BottIevard 

Suite 1625 

Miami, Floti433156 

TelephOfie: 305374.0506 

Facsimile: 95.374.0456 

Counsel for Defendant, 

Home Depot U.S.A., Inc. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 41 of 55
Filing # 153900586 E-Filed 07/22/2022 03:38:49 PM 

IN THE CIRCUIT COURT OF THE 

15TH JUDICIAL CIRCUIT IN AND 

FOR PALM BEACH COUNTY, 

FLORIDA 

SANDARA WEBER, 

Plaintiff, CASE NO: 2022-CA-003492 

v. 

HOME DEPOT USA, INC., 

Defendant. 

(47

DEFENDANT'S NOTICE OF SERVING, ) 

FIRST SET OF INTERROGATORIES TO PLAINTIFF SANDARA WEBER 

Defendant Home Depot U.S.A., Inc. ("Defendant"Xiiisusiignt to Rule 1.340 of the Florida 

Rules of Civil Procedure, certifies that it has served oh Ju 2 0 2 2 , on Plaintiff Laura Sandara 

Weber the following interrogatories. DefendaptatqueS,ts that Plaintiff answer each separately 

and fully in writing and under oath, and se e a COpy of said answers upon Defendant's attorneys 

within thirty (30) days from the dato,oeser*e of these interrogatories. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 42 of 55
Dated: July 22, 2022. 

Respectfully submitted, 

OGLETREE, DEAKINS, NASH, 

SMOAK & STEWART, P.C. 

9130 S. Dadeland Blvd., Suite 1625 

Miami, Florida 33156 

Telephone: 305.374.0506 

Facsimile: 305.374.0456 

s/ Grego?), R. Hawran 

Christopher P. Hammon 

Florida Bar Number 1746753 

chris.hanunon@ogletrec,co 

Gregory R. Hawrap-- 

Florida Bar Nuiiiber''55989 \

gregory.hafwfa`t @ifl&ree.com 

Counselfor'Dgfrndant Home Depot USA, Inc. 

2 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 43 of 55
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on July 22, 2022, the foregoing document is being provided 

this day on all counsel of record identified on the attached Service List in the manner specified. 

s/ Gregory R. Hawran 

Gregory R. Hawran 

3 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 44 of 55
SERVICE LIST 

Sandara Weber v. Home Depot USA, Inc. 

15th Judicial Circuit in and for Pahn Beach County, Florida 

Case No. 2022-CA-003492 

Jason S. Remer 

REMER & GEORGES-PIERRE, PLLC 

44 West Flagler Street 

Suite 2200 

Miami, Florida 33130 

Telephone: 305.416.5000 

Facsimile: 305.416.5005 /1; 

Email: jremer@rgpattorneys.cotn,,, 

Counsel for Plaintiff( 

Method of Service. ening Portal 

t 

,e1F.MIP 

4,

/

aT 

Chriqupl erj). ammon 

cpris.litupfrion@ogletree.com 

Qi'egpry R. Hawran 

-'gregPry.hawran@ogletree.com 

,OGLETREE, DEAKINS, NASH, 

ySMOAK & STEWART, P.C. 

' -7 9130 S. Dadeland Blvd., Suite 1625 

' Miami, Florida 33156 

Telephone: 305.374.0506 

Facsimile: 305.374.0456 

Counsel for Defendant 

4 

52355606A/1-OGLETREE 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 45 of 55
Filing # 157581012 E-Filcd 09/16/2022 01:55:54 PM 

IN THE CIRCUIT COURT OF THE FIFTEENTH 

JUDICIAL CIRCUIT IN AND FOR PALM BEAM COUNTY, FLORIDA 

CIRCUIT CIVIL DIVISION: AD 

CASE NO.: 50-2022-CA-003492-XXXX-MB 

SANDRA WEBER, 

Plaintiff/Petitioner 

vs. 

HOME DEPOT USA INC, 

Defendant/Respondent. 

-„2-/

ORDER IMPLEMENTING DIFFERENTIATED CASE MANAGE 'NT PLAN, 

DESIGNATING CASE TO THE GENERAL TRACK.- 

ORDER SETTING JURY TRIAL AND PRE-TRIAL CONFERENCE, 

AND DIRECTING PRETRIAL AND MEDIATION, PROCEDURES 

(DCMJT) 

THIS CAUSE came before the Court, SIM SpOille„44 eisstrilanagement review pursuant to 

Rule 2.545 (b), Fla. R. hid. Admin., Rule 1,200, an *Ii Order 3.107. At least one 

hundred and thirty (130) days has passed and the5bniies have failed to submit an Agreed Case 

Management Plan with an Order Approving (ei)1,i4ement Plan within the time deadlines 

outlined in the administrative order, and the4CUifojuwing reviewed the file, hereby designates 

this case to the General Track to be disp( .1_0f,Within eighteen months from the date of filing. 

Based upon a review of the tile, FlaRl jtiokAdmin. 2.250(a)(1)(B) and 2.545(b), the Court finds 

that this case is at issue and hereby O D RS that: 

1. SCIIEDULING 

This action is set *Jay Trial on the Court's trial docket sometime between June 19, 

2023 and August l,1 `2023. CALL IS SET FOR JUNE 09. 2023. 

COMPLETION OP" E-CALENDAR CALL FORM IS REQUIRED BY THE 

SCHE,DULIti) ITE OF E-CALENDAR CALL. The Court has reserved FOUR (4) DAYS 

for the tritdohhix, ause. 

E-CALE DAR CALL 

DIVISION AD has adopted an E-Calendar Call. Counsel/parties must comply with the 

instructions for E-Calendar Call as listed on the Division Al) webpage and in "Exhibit A" of this 

Order. The "E-Calendar Call Form" (Exhibit A) shall be completed and submitted by email to 

CAD-DivisionADRpbcgov.org no later than the date E-Calendar Call is scheduled. 

The trial will be scheduled sometime during the trial docket period at a date and time to 

be provided by counsel in the E-Calendar Call Form, subject to the Court's ordering a later case 

setting. The trial shall be set during each of the weeks of this trial period unless counsel sets 

I cn• nnI &A DC/le -NU fsni IAITV CI inecrau ADDI I7 -7n cos net/ininrinf) fli•CC•CA 12)11A 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 46 of 55
forth specific conflict dates, which dates shall be limited to personal conflicts and prepaid 

vacations. 

II. UNIFORM PRETRIAL PROCEDUREAll pretrial deadlines set forth in this Order shall be strictly adhered to by the parties. 

A. On the last business day no later than 90 DAYS PRIOR TO CALENDAR CALL, the 

parties shall exchange lists of all trial exhibits, names and addresses of all trial 

witnesses, and names and addresses of all expert witnesses. 

• 

13. On the last business day no later than 60 DAYS PRIOR TO CALENDAWCALL, the 

parties shall exchange lists of names and addresses of all rebuttal NOP—

C. In addition to names and addresses of each expert retained 40 fo date an expert 

opinion with regard to this cause, both on the initial listin -and'ippre uttal, the parties 

shall provide: 

1. the subject matter about which the expert is expestidIR testify; 

2. the substance of the facts and opinions to whfehthe.exipert is expected to testify; 

3. a summary of the grounds for each opinion ),,

4, a copy of any written reports issued by 410v395'641regarding this case; 

5. a copy of the expert's curriculum vitae': 

„. 

D. On the last business day no later 0 DAYS PRIOR TO CALENDAR CALL, the 

parties shall confer and: -(11 

1. discuss settlement 

2. simplify the issue, nd pipulate, in writing, as to as many facts and issues as 

possible; 

3. prepare a Pre Trial Stipulation in accordance with paragraph E; and 

4. list alkibjectiOs to trial exhibits. 

E. AMTIOAL STIPULATIONS AND PRETRIAL MOTIONS MUST BE FILED. 

ffk-§lftlibe the duty of counsel for the Plaintiff to see that the Pre-Trial Stipulation is 

drawn, executed by counsel for all parties, and filed with the Clerk no later than 20 

DAYS PRIOR TO CALENDAR CALL. All pre-trial motions shall be filed no 

later than 30 days prior to CALENDAR CALL. UNILATERAL PRETRIAL 

STATEMENTS ARE DISALLOWED, UNLESS APPROVED BY THE COURT, 

AFTER NOTICE AND HEARING SHOWING GOOD CAUSE. Counsel for all 

parties are charged with good faith cooperation in this regard. The Pre-Trial Stipulation 

shall contain in separately numbered paragraphs; 

1. a list of all pending motions, including MOTIONS IN LIMINE and DAUBERT 

MOTIONS requiring action by the Court and the dates those motions are set for 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 47 of 55
hearing (MOTIONS IN LIMINE and DAUI3ERT HEARINGS shall not be heard 

the day of the trial or thereafter). 

2. stipulated facts which require no proof at trial which may be read to the trier of fact; 

3, a statement of all issues of fact for determination at trial; 

4. each party's numbered list of trial exhibits with specific objections, if any, to 

schedules attached to the Stipulation; 

5. each party's numbered list of trial witnesses with addresses (including all known 

rebuttal witnesses); the list of witnesses shall be on separate schedules attached to 

the Stipulation; 

6, a statement of estimated trial time; 

7. names of attorneys to try case; and 

8, number of peremptory challenges per party. 

9, proposed jury instructions to be attached. 

I 

F. FILING OF PRE-TRIAL STIPULATION. Failure to t e th0 Pre-Trial Stipulation 

or a Court Approved Unilateral Stipulation as above.:provided may result in the case 

being stricken from the Court's calendar at its sounding i other sanctions. 

G. ADDITIONAL EXHIBITS, WITNESSES OR OBJECTIONS. At trial, the parties 

shall be strictly limited to exhibits and witneSses disclosed and objections reserved on 

the schedules attached to the Pre-' rfill„,:StipWation prepared in accordance with 

paragraphs D and E, absent agree9ient specifically stated in the Pre-Trial Stipulation 

or order of the Court upon good .0iise sliOcVn. - Failure to reserve objections constitutes 

a waiver. A party desiring torus e anexhibit or witness discovered after counsel have 

conferred pursuant to para1,4O h,'D' shall immediately furnish the Court and other 

counsel with a descriptio

a

li oft *exhibit or with the witness' name and address and the 

O- ‘e' expected subject matter- the.witness' testimony, together with the reason for the late 

discovery of the extithit O1 witness. Use of the exhibit or witness may be allowed by 

the Court for good cause-'shown or to prevent manifest injustice. 

H. DISCO yERY!,,thiless otherwise agreed in the Pre-Trial Stipulation, all discovery must 

- - be corcied nolater than 20 DAN'S BEFORE THE DATE SET FOR CALENDAR 

CALL, *pit agreement for later discovery specifically stated in the Pre-Trial 

Stcpura ion)br for other good cause shown. 

--TRIAL CONFERENCE. No pre-trial conference pursuant to Fla. R. Civ. P. 

1.200 is set by the Court on its own motion. If a pre-trial conference is set upon motion 

f a party, counsel shall meet and prepare a stipulation pursuant to paragraphs D and F. 

and file the stipulation no later than 10 DAYS BEFORE THE CONFERENCE. 

Failure to request a pre-trial conference in a timely fashion constitutes a waiver of the 

notice of requirement of Rule 1.200. Motions for Summary Judgment will not be heard 

at any pre-trial conference. 

J. UNIQUE QUESTIONS O1? LAW. Five days prior to calendar call, counsel for the 

parties arc directed to exchange and simultaneously submit to the Court appropriate 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 48 of 55
memoranda with citations to legal authority in support of any unique legal questions 

which may reasonably be anticipated to arise during the trial. 

K. MODIFICATION TO UNIFORM PRE-TRIAL PROCEDURE. Shall be by court 

order only. 

L. PRE-MARKING EXHIBITS. Prior to trial, each party shall meet with and assist the 

clerk in marking for identification all exhibits, as directed by the clerk. 

M. DEPOSITION DESIGNATIONS. No later than 20 DAYS PRIOR TO 

CALENDAR CALL, each party shall serve his, her, or its designation of depositions, 

or portions of depositions, each intends to offer as testimony in his/her or. ts case in 

chief'. No later than 10 DAYS PRIOR TO CALENDAR CALL, C'ieh!jopposing party 

shall serve his, her, or its counter (or "fairness") designations tOnitipnit4)f depositions 

designated, together with objections to the depositions, or,pOrtionsftereof, originally 

designated. No later than calendar call, each party shall se:ive hiS;her or its objections 

to counter designations served by an opposing party. 

N. REQUIRED PRE-CALENDAR CALL MEETING.)No later than FIVE DAYS 

PRIOR TO CALENDAR CALL, counsel for ,the pitrties are required to meet and 

exchange all pre-marked exhibits and den aiistratiye that will be used at trial. Counsel 

for the parties are directed to collaborateOpple*oduction of proposed jury instructions 

and verdict form and submit same to:thc Court, prior to calendar call. 

III. MEDIATION 

A. All parties are required tcFpartieipate in mediation. 

y 

.‘‹ 1. The appearance olyotins43:Vho will try the case and representatives of each party 

with full authority‘entier into a complete compromise and settlement is 

mandatory. insurance is involved, an adjuster with authority up to the policy 

limits or the,Svecent demand, whichever is lower, shall attend. 

2. At leasIONE yvEEK BEFORE THE CONFERENCE, all parties shall file with 

the Mediator a brief, written summary of the case containing a list of issues as to 

etteWpartOf an attorney or party filing the summary wishes its content to remain 

x onfig''''ential, he/she must advise the mediator in writing when the report is fi led. 

3. ‘AtiLd scussions, representations, and statements made at the mediation conference 

Shall be privileged consistent with Florida Statutes sections 44.102 and 90.408. 

4'.'YThe mediator has no power to compel or enforce a settlement agreement. If a 

settlement is reached, it shall be the responsibility of the attorneys or parties to 

reduce the agreement to writing and to comply with Florida Rule of Civil Procedure 

1.730(b), unless waived. 

B. The Plaintiffs attorney shall be responsible for scheduling mediation. The parties 

should agree on a mediator. if they arc unable to agree, any party may apply to the 

Court fur appointment of a mediator in conformity with Rule 1.720 (0, Fla. R. Civ. P. 

The lead attorney or party shall file and serve on all parties and the mediator a Notice 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 49 of 55
of Mediation giving the time, place, and date of the mediation and the mediator's name. 

The mediator shall be paid S175,00 per hour, unless otherwise agreed by the parties. 

C. Completion of mediation prior to calendar call is a prerequisite to trial. If 

mediation is not conducted, or if a party fails to participate in mediation, the case, at 

the Court's discretion, may be stricken from the trial calendar, pleadings may be 

stricken, and other sanctions may be imposed. 

D. Any party opposing mediation may proceed under Florida Rule of Civil Procedure 

1.7000). 

IV. NONCOMPLIANCE 

NONCOMPLIANCE WITH ANY PORTION OF THIS ORDER -RESULT IN 

S'i'RiKiNG OF THE CASE, WITNESSES, OR EXHIBITS:4* IMPOSITION OF 

SUCH OTHER SANCTIONS AS ARE JUST. 

NOTE: In accordance with the 15th Judicial Circuit's Admkiistrative Order 2.310, please 

ensure that primal:), and secondary email addresses are regliftgre(4vith Court Administration at 

www. 5Theircu it .candott linesovices. The filing of an eirigde, ssiOaiion with the Clerk's Office is 

NOT a registration with Court Administration for judicitket'SeFvite of orders. If you do not register 

with the 15th Circuit as set forth above, your e-service'liddress4ill auto-populate with your Florida 

Bar address and..may. result. in orders going to; addresses which ore not frequently 

checked or are no longer in use, ,

In accordance with Administrative-Order2.-311, when an attorney is no longer counsel of 

record on a case, the attorney must up4ategis,or her primary and secondary email addresses with 

the Clerk of Court. (Sec exhibits attichbd 0.A.O. 2.311.) 

s;,,,t • 

DONE AND ORDERED in 6M Palm Beach, Palm Beach County, Florida. 

COPIESTUkNISHED: 

,( 

5020210003492XXXXMB 

R. Goodman (Circuit Judge 

/ 

502022CA0034192XXXXIM 09116r2022 

Jainile R. Goodman 

Circuit Judge 

Name Address Email 

GREGORY R. 

HAWRAN ESQ 

GREGORY.HAWRAN@OGLETREE.COM; 

9130 S. DADELAND greg.hawran@ogletreedeakins.com; 

BLVD. STE 1625 roberlborroto@ogletreedeakins.com; 

MIAMI, FL 33156 veronica.alarcon@ogletreedeakins.com; 

gregory.hawran@ogletreedeakins.com 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 50 of 55
Name Address Email 

JASON S. REMER 

ESQ 

JREMER@RGPATTORNEYS.COM; 

44 W FLAGLER ST ng@rgpattorneys.com; 

STE 2200 MIAMI, pn@rgpattorneys.com; 

FL 33130 mpb@rgattorneys.com; 

cdelgado@rgpattorneys.com 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 51 of 55
EXHIBIT A 

CIRCUIT CIVIL DIVISION AD: E-CALENDAR CALL FORM 

PLAINTIFF'S COUNSEL SHALL CONFER ON THE ISSUES OUTLINED IN THIS 

ORDER AND COMPLETE THIS FORM WITH ALL INFORMATION REQUESTED 

(INCLUDING CONFLICTS FOR ALL COUNSEL OF RECORD). ONCE THE "E: 

CALENDAR CALL FORM" IS COMPLETE, THE E-CALENDAR CALL FORM MUST 

BE E-MAILED TO CAD-DivisionAD©pbcgov.org no later than the end of business 

day on the date of your scheduled calendar call. 

CALENDAR CALL DATE: 

FOR THE TRIAL PERIOD OF: 

CASE NAME: 

CASE NUMBER: 

PLAINTIFF'S TRIAL COUNSEL CONTACT INFORMATION: 

Full Name: 

Phone: 

Primary Email: 

Secondary Email 

DEFENDANT'S TRIAL COUNSEL CONTACT INFORMATION: 

Full Name: 

Phone: 

Primary Email: 

Secondary Email: 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 52 of 55
NUMBER OF DAYS/HOURS REQUESTED FOR TRIAL/HEARING: 

DATE PRE-TRIAL STIPULATION WAS FILED: 

DATE MEDIATION CONFERENCE WAS CONDUCTED: 

*DATES AND SPECIFIC NATURE OF CONFLICTS DURING TRIAL DOCKET: 

**PREFERRED TRIAL WEEKS: 

*The Court will only recognize the following conflicts: 

• Prepaid vacations 

• Personal conflicts,-

All conflicts must indicate the date and reason for the conflict listed. 

"The preferred trial weeks are not necessarily the weeks you will be set for trial. The 

court will try to accommodate your requests to the best of its ability: however, the case 

may still be set for trial during the other weeks of the docket. The more dates you 

provide the greater chance of the court accommodating your requests, Upon 

determination of availability for setting trial in this trial period, the Court will post the trial 

on the DIVISION AD website, 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 53 of 55
Filing # 157713630 E-Filcd 09/19/2022 05:08:39 PM 

IN THE CIRCUIT COURT, 15TH JUDICIAL 

CIRCUIT IN AND FOR PALM BEACH 

COUNTY, FLORIDA 

CASE NO.: 2022-CA-003492XXXXMB 

SANDARA WEBER, 

Plaintiff, 

vs. 

HOME DEPOT U.S.A., INC., 

Defendant. 

NOTICE OF DISASSOCIATION OF COUNSEL) 

The Plaintiff in this action is represented by the firM;'Reirier & Georges-Pierre, PLLC. 

n/k/a Remer, Georges-Pierre and Hoogerwoerd, PLLC. The,,,tindersigned entered a Notice of 

Disassociation of Counsel on the matter in its, handling of the matter for the Firm, Reiner & 

Georges-Pierre, PLLC. n/k/a Remer, Georges-Pierre' and Hoogerwoerd, PLLC. and in the course 

of employment was associated as rePtese tinfthe Plaintiff in this action. As of September 23, 

2022, the undersigned will no *ger 1?e;einployed by the firm of Remer & Georges-Pierre, PLLC. 

n/k/a Remer, Georges-Pierre and Hoogerwoerd, PLLC. 

As the underSignekwill not be employed by the firm Remer & Georges-Pierre, PLLC. 

n/k/a Remer, Georges-Pierre and Hoogerwoerd, PLLC., after September 23, 2022, the undersigned 

;.\ 

will no longer. represent the Plaintiff in this action. However, the Plaintiff remains represented by 

the firm teiner & Georges-Pierre, PLLC. n/k/a Remer, Georges-Pierre and I Ioogerwoerd, PLLC. 

and its constituent attorneys. 

Dated: September 19, 2022. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 54 of 55
CASE NO.: 2022-CA-003492XXXXMB 

Respectfully submitted, 

/s/Mercy B. Pina-Brito 

REM ER & GEORGES-PIERRE, PLLC 

Jason S. Remer, Esq. 

Florida Bar No. 0165580 

jremer@rgpattomeys.com 

Mercy B. Pina-Brito, Esq. 

1?lorida Bar No. 135161 

mpb@rpspatiorneys.com 

2745 Ponce de Leon Blvd. 

Coral Gables, FL 33134 

Tel: (305) 416-5000 

Fax: (305) 416-5995 tN 

Attorney for Plaintiff 

CERTIFICATE OF SERVIVr'b 

I HEREBY CERTIFY that on September 19, 2022 the under4110-counsel . has electronically filed 

the foregoing document with the Clerk of Court usi9t.the'Rtortda Courts E- filing Portal. I also 

certify that the foregoing document is being servedf(Onthrt)day on all counsel of record or pro se 

parties, either via electronic transmission of Notices generated by the Florida Courts Efiling Portal 

or in some other authorized manner for those.c9uniet o'r parties who are not authorized to receive 

such Notices. By: /s/Mercy B. Pina-Brito Mgrckp) Pina-Brito, Esq. Florida Bar No. 135161. 

SERVICE LIST 

OGLETREE, DEAKINS, NO11,7 

SMOAK & STEWART, 

Christopher P. HammOk. 

Florida Bar Noi;176453 

chris.hanunnhOogleireedcakins.com 

GregorS/R146Wran -

Florida Bar No. 55989 

gregory.hawran@ogletrcedeakins.com 

9130 S. Dadeland Boulevard 

Suite 1625 

Miami, Florida 33156 

Telephone: 305.374.0506 

Facsimile: 305.374.0456 

Counsel for Defendant, 

Home Depot U.S.A., Inc. 

Case 9:22-cv-81515-DMM Document 1-2 Entered on FLSD Docket 09/29/2022 Page 55 of 55