Private Sector Florida Whistleblower Act Amended Complaint.

Case 8:10-cv-02003-RAL-TGW Document 7-1 Filed 11/02/10 Page 18 of 25 PageID 170
76. WHEREFORE, the Plaintiff, respectfully prays that this Honorable Court take
jurisdiction of the subject matter and parties hereto, and grant his request for trial by jury, declare
that the Defendant violated the rights of Plaintiff as protected by the laws of the State of Florida,
and award back pay, front pay, prejudgment interest, compensatory damages for mental anguish,
emotional distress, embarrassment, humiliation, loss of enjoyment of life, loss of dignity,
impairment of working ability and earning capacity and loss of reputation, reasonable attorney’s
fees pursuant to Florida Statute, § 760.11 and costs, and such other relief as deemed appropriate
by this Court.
COUNT III – FCRA (Retaliation)
77. Plaintiff realleges and incorporates by reference Paragraphs 1 through 76, as
though set forth herein verbatim.
78. This action is based on a violation of the Florida Statute, Chapter 760, Florida
Civil Rights Act.
79. B&L, via its agents, representatives, and employees, retaliated against Plaintiff
because of his complaints about discrimination and B&L’s failure to promote him on the basis of
his national origin. As a result of B&L’s unlawful employment practices, Plaintiff has been
damaged.
80. WHEREFORE, the Plaintiff, respectfully prays that this Honorable Court take
jurisdiction of the subject matter and parties hereto, and grant his request for trial by jury, declare
that the Defendant violated the rights of Plaintiff as protected by the laws of the State of Florida,
and award back pay, front pay, prejudgment interest, compensatory damages for mental anguish,
emotional distress, embarrassment, humiliation, loss of enjoyment of life, loss of dignity,
impairment of working ability and earning capacity and loss of reputation, reasonable attorney’s
First Amended Complaint, page 18