Private Sector Florida Whistleblower Act Amended Complaint.
Plaintiff Ramirez.
Plaintiff Ramirez.
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Case 8:10-cv-02003-RAL-TGW Document 7-1 Filed 11/02/10 Page 15 of 25 PageID 167<br />
VII.<br />
FACTS REGARDING ADVERSE ACTIONS<br />
53. The adverse actions taken against the Plaintiff exhibit a pattern of retaliation for<br />
the above referenced protected activity. These adverse actions included:<br />
54. Plaintiff was subjected to the ongoing maintenance and failure to abate a hostile<br />
work environment against him, which included abusive and berating language, insults, ridicule,<br />
threats, and hostile interrogations.<br />
55. On March 13, 2008, THOMAS verbally abused Plaintiff because he stopped<br />
the production line and stated his intent to contacting higher management regarding compliance<br />
violations.<br />
56. On or about March 25, 2008, Plaintiff’s Second Shift Quality Group Leader<br />
threatened Plaintiff with words to the effect that, “remember HR leaves at 17:00, after that you<br />
are stuck with us”, and “I don’t know how much you need your job but...”.<br />
57. On June 10, 2008, in response to the Plaintiff’s concerns regarding improper attire<br />
in violation of SOPs, THOMAS informed Plaintiff she was unwilling to discuss the problem and<br />
dismissively rebuked him with words to the effect of “go to HR”.<br />
58. On June 12, 2008, GORDON forbade Plaintiff from (a) observing work lines<br />
during his lunch hour as other employees could; (b) observing or making compliance reports<br />
about production lines to which he was not assigned; or (c) communicating his compliance<br />
concerns directly to manufacturing leaders without prior approval of GORDON. Plaintiff was<br />
also admonished against emailing other department’s managers about his compliance concerns.<br />
59. On July 14, 2008, Defendant managers and Human Resources falsely accused and<br />
reprimanded Plaintiff for improperly stopping the production line and breaching protocol by not<br />
first communicating with the operator of the offending line. BRIGGS verbally reprimanded<br />
First <strong>Amended</strong> <strong>Complaint</strong>, page 15