Private Sector Florida Whistleblower Act Amended Complaint.

Case 8:10-cv-02003-RAL-TGW Document 7-1 Filed 11/02/10 Page 3 of 25 PageID 155
III.
JURISDICTION AND VENUE
6. This court has original jurisdiction under 28 U.S.C. § 1332, as the matter in
controversy exceeds the sum or value of $75,000, exclusive of interest and costs, and is between
citizens of different States.
7. Venue lies in this United States District Court under 28 U.S.C. § 1991(b) and (c) by
virtue of the fact that the Plaintiff resides in this judicial district, and the conduct complained of
herein occurred in this judicial district.
IV.
PROCEDURAL BACKGROUND
8. Plaintiff complied with the administrative prerequisites by filing his initial charge of
discrimination based on national original and disability with the Equal Employment Opportunity
Commission (EEOC) and Florida Commission on Human Relations on or about December 10,
2008.
9. The initial charge was amended on or about September 28, 2009, adding “retaliation”
as an additional “cause of discrimination”.
10. A Notice of Right to Sue was issued and mailed on or about March 4, 2010. A
copy of the Dismissal and Notice of Rights was attached to the original complaint and
incorporated by reference as Exhibit “A” to the original complaint.
11. Plaintiff filed his original Complaint within ninety (90) days of receipt of the
Notice of Rights.
V. GENERAL FACTS
12. Defendant B&L manufactures medical devices and pharmaceuticals including
contact lenses, products for cleaning and disinfecting contact lenses, eye care products,
prescription and over-the-counter pharmaceutical products for eye conditions including allergies,
First Amended Complaint, page 3