Private Sector Florida Whistleblower Act Amended Complaint.

Case 8:10-cv-02003-RAL-TGW Document 7-1 Filed 11/02/10 Page 19 of 25 PageID 171
fees pursuant to Florida Statute, § 760.11 and costs, and such other relief as deemed appropriate
by this Court.
COUNT IV: NEGLIGENT SUPERVISION/TRAINING/RETENTION
81. Plaintiff realleges and incorporates by reference Paragraphs 1 through 80, as
though set forth herein verbatim.
82. This is a common law action of negligent supervision, training and/or retention.
During the course of Plaintiff’s employment with B&L, B&L via its agents, representatives, and
employees in supervisory or management positions, had a duty to Plaintiff to properly supervise,
train and discipline his supervisors regarding the legal responsibilities of an employer under
Florida law regarding discrimination and retaliatory treatment.
83. During the course of Plaintiff’s employment with B&L, B&L via its agents,
representatives, and employees in supervisory or management positions, failed in its duty to
properly supervise, train and discipline Plaintiff’s supervisors regarding the legal responsibilities
of an employer under Florida law regarding discrimination and retaliatory treatment.
84. As a direct and proximate result of B&L’s negligent breach of duty, Plaintiff
suffered permanent and/or continuing injuries and sustained the following past and future
damages:
A. Mental pain;
B. Severe emotional distress in the form of fear, nervousness, anxiety, worry and
indignity;
C. Embarrassment;
D. Humiliation;
E. Loss of enjoyment of life;
First Amended Complaint, page 19