Private Sector Florida Whistleblower Act Amended Complaint.

Case 8:10-cv-02003-RAL-TGW Document 7-1 Filed 11/02/10 Page 2 of 25 PageID 154
Florida Statutes. This is also a complaint for discrimination against the Plaintiff due to his
national origin (Chilean) and disability (amblyopia, a monocular vision impairment), and for
retaliation for objecting to employer’s discriminatory practices under Florida Statute, Chapter
760, Florida Civil Rights Act.
2. Plaintiff, formerly a Quality Coordinator in the Manufacturing Quality Assurance
Department for the Defendant Bausch & Lomb, Inc., alleges herein that he was terminated from
his job in retaliation for his disclosures of lack of product quality and safety and violations of
laws, rules, and regulations and for objecting to the Defendant’s discriminatory practices.
3. Plaintiff seeks reinstatement to his position as a Quality Coordinator of Bausch &
Lomb, back pay and benefits, and compensatory damages, including an award for emotional
distress, together with an award of reasonable costs and attorneys fees. If reinstatement is not
found to be the appropriate remedy, then Plaintiff should be awarded front pay in lieu of
reinstatement.
II.
PARTIES
4. Plaintiff is a citizen of the Republic of Chile, and a legal resident alien of the United
States for 20 years, and a resident of Hillsborough County, Florida. Plaintiff is of Hispanic
descent, from the country of Chile, and is male.
5. Defendant B&L is a corporation headquartered in New York, with its principal place
of business in New York, doing business in Hillsborough County, Florida, engaged in an
industry affecting commerce, and employing in excess of 15 employees. B&L employs over 20
employees.
First Amended Complaint, page 2