IN THE COUNTY COURT FOR
BREVARD COUNTY, FLORIDA
RONALD C. JULIEN,
Case No.
Plaintiff,
v.
JOHN HANCOCK MUTUAL LIFE INSURANCE COMPANY,
Defendant. _____________________________
COMPLAINT
Plaintiff, RONALD C. JULIEN, by and through his undersigned attorney, sues Defendant, JOHN HANCOCK MUTUAL LIFE INSURANCE COMPANY, and alleges as follows:
1. This is an action for breach of contract and damages that do not exceed $15, 000.
2. Plaintiff, RONALD C. JULIEN, (hereinafter “JULIEN”) is a resident of Brevard County, Florida.
3. Defendant, JOHN HANCOCK MUTUAL LIFE INSURANCE COMPANY, (hereinafter “JOHN HANCOCK”) is a foreign corporation doing business in the State of Florida.
4. Plaintiff was employed by the Defendant in the Defendant’s Suntree Office in Brevard County, Florida.
5. On October 8, 1998, Plaintiff and Defendant executed an employment contract, which is attached and marked as Exhibit “A”.
6. Plaintiff began the employment and continued to perform Plaintiff’s duties under the employment contract until January 4, 1999 at which time Defendant breached the contract and ceased paying Plaintiff his weekly salary.
7. Plaintiff was terminated by Defendant but was not given written notice of his termination as is required by subsection three (3) of the employment contract, Exhibit “A”, until he received a letter dated May 12, 1999, which is attached and marked as Exhibit “B”, that terminated his employment as of May 7, 1999.
8. Despite demand being made upon Defendant, Defendant has refused to pay Plaintiff the wages that Plaintiff would have earned pursuant to the employment contract from January 4, 1999 until May 7, 1999.
9. Defendant owes Plaintiff wages in the amount of $ 11,400.00 plus interest.
10. Plaintiff is obligated to pay his attorneys a reasonable fee for their services.
11. This is an action for unpaid wages and Plaintiff is entitled to his attorney fees pursuant to Section 448.08, Florida Statutes, 1999.
12. Plaintiff has complied with all conditions precedent prior to bringing this action.
WHEREFORE, Plaintiff prays for judgment against Defendant for unpaid wages with interest and all other damages to which he may be entitled, together with his attorney fees and costs of this action.
DATED: This ____ day of January, 2000.
_______________________
Wayne L. Allen, Esquire
Florida Bar No. 110025
Adrienne E. Trent
Florida Bar No. 0060119
Trial Counsel
Attorneys for Plaintiff
WAYNE L. ALLEN, P.A.
700 N. Wickham Road, Ste. 107
Melbourne, FL 32935
Phone (407)254-7550
Fax (407)242-2681
