Private Sector Florida Whistleblower Act Amended Complaint.

Case 8:10-cv-02003-RAL-TGW Document 7-1 Filed 11/02/10 Page 12 of 25 PageID 164
stopping of production lines. He explained that Defendant’s failure to properly respond to
nonconformities had mandated his actions. He further suggested that the Defendant was in effect
ratifying the wrongful and/or illegal conduct of its employees in its inadequate responses to the
nonconformities.
40. From June 16 -30, 2008, the scheduled manufacturing operations were shut
down. During this time, the Plaintiff attended a meeting conducted by the new Quality
Assurance Direction WENDY GOULD. During said meeting, the Plaintiff raised many of his
above stated concerns, in the presence of all attendees, and urged review of the apparent
shortcomings in business ethics within the Quality Department.
41. On July 14, 2008, the Plaintiff observed defects in the product similar to those
referenced above and reported these to the maintenance mechanic and operator. Plaintiff
requested that operator GUDALUPE stop the line, but GORDON overruled the Plaintiff. Later
that day, the Plaintiff was called to a meeting with THOMAS, GUADALUPE, and GORDON in
which he was subjected to hostile questions as to his justifications in stopping the production line
being operated by GUADALUPE. The Plaintiff informed the attendees of his reasons, and
offered proof in the form of a defect sample bottle he had secured.
42. On July 15, 2008, the Plaintiff reported to MQA Manager MONICA BRIGGS,
Team Leader Quality ANITA MUJAGIC, and HR Representative JAVIER CALLEJAS of many
of the anomalies referenced above and the ongoing resistance and hostility he was facing for
stopping the line in order to adhere to production and safety standards. The Plaintiff expressed
his view that the Defendant was committing and ratifying violations of the CFRs and SOPs. The
Plaintiff produced the secured sample referenced above to BRIGGS, CALLEJAS, and
First Amended Complaint, page 12