IN THE CIRCUIT COURT OF THE
EIGHTEENTH JUDICIAL CIRCUIT
IN AND FOR BREVARD COUNTY, FLORIDA
GLORIA M. MULLINGS Case No.
Plaintiff,
-vs-
MEDERI, INC.
Defendant.
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, GLORIA M. MULLINGS, by and through her undersigned attorney, sues Defendant, MEDERI, INC., and alleges as follows:
1. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000.00), exclusive of interest, costs and attorney’s fees.
2. This action is brought pursuant to Chapter 760, Florida Statutes, the “Florida Civil Rights Act of 1992”.
3. The unlawful employment practices alleged below were committed
in Brevard County, Florida.
4. Plaintiff currently resides in Palm Bay, Brevard County, Florida, and
at all time material hereto resided in Brevard County, Florida.
5. Defendant, MEDERI, INC. is a Florida corporation.
6. Plaintiff was employed by Defendant, MEDERI, INC., in the
position of Registered Nurse, Case Manager.
7. Plaintiff was discharged by Defendant on June 26, 1996.
8. Plaintiff filed a claim with the Florida Commission on Human Relations and more than one hundred eighty (180) days have passed since the filing of said claim. A copy of said claim is attached as Exhibit A.
9. Plaintiff has exhausted her administrative remedies.
10. Plaintiff has retained the undersigned attorney and agreed to pay him a reasonable fee.
COUNT I
11. Plaintiff re-alleges and incorporates paragraphs 1 through 10 of this Complaint as if set forth in full herein.
12. Plaintiff was fifty (57) years of age, having been born on October 22, 1939, at the time Defendant terminated Plaintiff.
13. Defendant subsequently hired younger applicants to fill the position
of Registered Nurse, Case Manager.
14. Plaintiff was discriminated against in violation of Section 760.10(1), Florida Statutes, 1997, in that she was discharged from employment in favor of younger applicants.
15. Plaintiff has suffered and continues to suffer grave and severe damage to her financial welfare, employment prospects and her reputation in the community in which she lives and among her professional peers by reason of Defendant’s discriminatory actions against Plaintiff.
16. Defendant willfully, knowingly and intentionally discriminated
against Plaintiff on the basis of her age.
WHEREFORE, Plaintiff prays for judgment against Defendant, MEDERI, INC., for back pay, front pay, compensatory damages, punitive damages and all other damages to which she may be entitled, together with her attorney fees and costs of this action.
Count II
17. Plaintiff re-alleges and incorporates paragraphs 1 through 10 of this Complaint as set forth in full herein.
18. Plaintiff is a black female.
19. Plaintiff was discriminated against in violation of Section 760.10(1), Florida Statutes, 1997, in that she was discharged from employment in favor of white applicants.
20. Defendant willfully, knowingly and intentionally discriminated
against Plaintiff on the basis of her race.
WHEREFORE, Plaintiff prays for judgment against Defendant, MEDERI, INC., for back pay, front pay, compensatory damages, punitive damages and all other damages to which she may be entitled, together with her attorney fees and costs of this action.
DEMAND FOR JURY TRIAL
Plaintiff demands a jury trial on all issues herein triable by jury.
DATED: This ____ day of May, 1998.
Wayne L. Allen, Trial Counsel
Florida Bar No. 110025
Wayne L. Allen, P.A.
Attorney for Plaintiff
700 N. Wickham Road
Suite 107
Melbourne, Florida 32935
Phone: (407) 254-7550
Fax: (407) 242-1681
