Filing 83841980 E?Filed 01/24/2019 01:07:45 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA GRAHAM RANDALL, CASE NO.: Plaintiff, vs. MAR-A-LAGO CLUB, AARON FULLER, and, BOGDAN BOEREAN, Defendant. VERIFIED COMPLAINT 1. Plaintiff, GRAHAM RANDALL, hereby sues Defendant, CLUB, for violations of his rights under the Florida Civil Rights Act of 1992, ?760.01, Fla. Stat, et seq. (hereinafter because he was retaliated against after he engaged in protected activity by participating in a sexual harassment investigation he initiated when two female employees who reported to him complained of sexual harassment against them by two of Defendant?s Mar-a-Lago Club high level managers, the Food and Beverage Director, Aaron Fuller and the Executive Chef, Bogdan Boerean. Plaintiff also sues Defendants Fuller and Boerean, for tortious interference with Plaintiff? 3 employment, because, subsequently to Plaintiff exposing and opposing their sexual harassment against Plaintiff? 3 two female employees, Fuller and Boerean retaliated against him by terminating Plaintiff employment for wholly pretextual reasons. Plaintiff also sues MAR-A-LAGO for violations of his rights under the Florida private sector Whistleblower Act, ?448.101 et seq., which protects employees from retaliation for reporting a violation of the law, including sexual harassment of others. JURISDICTION AND VENUE 2. This is an action for damages in excess of $15,000, exclusive of attorney?s fees and costs. 3. Venue is proper in this Court, because all acts complained of occurred in Palm Beach County, Florida. PARTIES 4. Plaintiff is a natural person and was employed by the Defendant in Palm Beach County, Florida. 5. Defendant is a foreign limited liability company, with its principal place of business in Palm Beach County, Florida. Defendant MAR-A-LAGO was, at all times relevant to this claim, Plaintiff ?employer? as that term is defined by the FCRA, ?760.01 et seq. Defendant FULLER is a natural person who is residing in Palm Beach County, Florida. Defendant BOEREAN is a natural person who is residing in Palm Beach County, Florida and is believed to still be employed by the Defendant. EXHAUSTION OF ADMINISTRATIVE REMEDIES 6. Prior to ?ling this action, Plaintiff filed a charge of employment discrimination with the Equal Employment Opportunity Commission and Florida Commission on Human Relations on or about November 16, 2017, attached hereto as Exhibit 1. More than 180 days have elapsed since the charges were ?led, and the FCHR has not made any determination on the merits of the charges. Accordingly, Plaintiff is authorized by law to file this action and is filing same Within four (4) years of the adverse actions complained of. M915. 7. Plaintiff, at all times relevant hereto, was employed by Defendant MAR-A-LAGO as an Executive Pastry Chef from on or about September 20, 2012, until he was terminated on or about October 24, 2017. Plaintiff performed his work very well and was never disciplined. 8. On or about the end of April 2017, Ms. Chelsea Braswell, a young Pastry Chef, complained to Plaintiff, who was her direct supervisor, that Defendants Fuller and Bogdan Boerean, were engaging in unwelcome and inappropriate sexual harassment of her. Ms. Braswell showed Plaintiff sexually offensive text messages Mr. Fuller was sending her, including ?Show me your boobs? or words to that affect. Ms. Braswell, then, a young women twenty (20) years of age, explained to Plaintiff she felt very demeaned and intimidated by Mr. Fuller because of his higher position. Keep in mind Mr. Fuller was a married man about forty (40) years of age. 9. On the same day as Ms. Braswell, Ms. Elisa Cordon, another young Pastry Chef, also complained to Plaintiff about similar sexual harassment issues by Mr. Boerean. Ms. Cordon also explained to Plaintiff she felt intimidated by Mr. Boerean?s demeaning and offensive sexually harassing behaviors towards her. Ms. Cordon was a young woman, about twenty three (23) years of age at the time, and expressed how intimidated she felt by Mr. Boerean, a married man in his thirties, due to his high level position with the Defendant. 10. Determining Mr. Fuller?s and Mr. Boerean?s actions to be in violation of company policy, and that their behaviors were in violation of law that prohibits sexual harassment in the work place, Plaintiff referred Ms. Braswell and Ms. Cordon to the Human Resources Department. Mr. Fuller and Mr. Boerean both held higher positions than Plaintiff and Mr. Randall did not have the authority to discipline them. 11. Plaintiff was interviewed about these complaints on two separate occasions by Ms. Janine Gill a/k/a Janine Valez, Human Resources Director, hence he participated in the investigation. Plaintiff expressed his concern about his bosses interfering with his employees and their conduct against two young female employees who were intimidated by their actions. During one of these interviews, Ms. Gill told Plaintiff that this was a situation that could have both of these senior managers terminated. 12. Ms. Gill a/k/a Ms. Valez subsequently followed up with Plaintiff in person after she concluded her investigation and told him that Mr. Fuller and Mr. Boerean received written reprimands. Both Fuller and Boerean subsequently apologized to the Plaintiff for their conduct, and thanked him for saving their careers, because Plaintiff had told Ms. Gill during the investigation that this misconduct seemed out of character for the two men. 13. About six (6) months following the conclusion of the investigation, on or about October 24, 2017, Fuller and Boerean, with Ms. Gill present, terminated the Plaintiff from his employment; the new ?season? had just started at Mar-a?Lago at the beginning of October 2017, and Plaintiff had insisted that the two young women that had made the complaints to Plaintiff be returned to their employment because he did not want to be a part of any retaliation against them. Plaintiff contends that he was retaliated against for his opposition to Fuller and Borean?s conduct against the young women and for insisting that they be allowed to return to work there at the start of the season. 14. Defendant?s reason for terminating Plaintiff, economic losses the club was taking because of seasonal cancellations by charitable organization of events at Mar-a-Lago Club, is pretextual because Mar?a?Lago has pro?ted immensely from President Donald J. Trump?s election. While some charities initially canceled events at Mar-a?Lago, this loss has been made up by other income ?owing into the Club. In addition, on belief and information, Defendant Mar-a-Lago 4 requested more foreign employees in 2017 and 2018 to ?ll its staf?ng needs. Further, Defendants did not offer the Plaintiff an opportunity to take a demotion from Executive Pastry Chef to Pastry Chef, several of whom continued to be employed by the Defendant following Plaintiff? termination. COUNT I: FCRA RETALIATION 15. Plaintiff incorporates the allegations set forth in ?[143. 16. The Defendant retaliated against the Plaintiff because Plaintiff engaged in activities protected by the law, including participating in a sexual harassment investigation of the two female employees who complained to him of sexual harassment by Fuller and Boerean. 17. Plaintiff was damaged as a result of Defendant?s retaliation sustaining lost wages, bene?ts, and mental and physical anguish. WHEREFORE, Plaintiff respectfully requests the following relief against Defendant: a) An award of damages, including lost wages and bene?ts; b) Compensatory damages for mental anguish; loss of dignity and reputation; inconvenience; loss of the enjoyment of life; 0) Attorney?s fees and costs; d) Equitable relief including a reinstatement to his position prior to termination, and retraining if needed; c) Any other relief deemed just and proper, including declaratory relief that his rights were violated by the Defendant. COUNT 11: PRIVATE SECTOR WHISTLEBLOWER ACT CLAIM 18. Plaintiff brings this claim against Defendant Mar-a Lago Club for violations of his rights pursuant to the Florida Private Sector Whistleblower Act, ??448.101, Fla. Stat. et seq. 19. Plaintiff incorporates the allegations set forth in 11111-13. 5 20. Plaintiff engaged in protected activity under Fla. Stat. ,when he opposed conduct on the part of Fuller and Boerean that he reasonably believed was against the law, and also when participated in a sexual harassment investigation of two employees who complained to him that they were being sexually harassed. Plaintiff ?objected to, or refused to participate in, any activity, policy, or practice of the employer which is in violation of a law, rule, or regulation.? 21 . After Plaintiff engaged in protected activity by opposing and participating in a sexual harassment investigation of Fuller and Boerean, Defendant terminated his employment. 22. Plaintiff?s protected activity and the adverse employment action taken against him are causally related. WHEREFORE, Plaintiff respectfully requests that this Court, in accordance with ?448. 103 Fla. Stat: A. Award Plaintiff lost wages, bene?ts, and other economic damages, as appropriate; B. Reinstatement by a preliminary and permanent injunction or, in lieu thereof, front pay; C. Award Plaintiff compensatory damages; D. Award Plaintiff a reasonable attorneys? fees and his costs; and, B. Any other relief deemed just and proper, including permitting future amendment to claim punitive damages for the Defendant? wilful and intentional retaliation against him. COUNT TORTIOUS INTERFERENCE v. Defendant FULLER 23. Plaintiff incorporates the allegations set forth in ?ll?13. 24. Defendant FULLER, acting outside the course and scope of his employment, without justi?cation, and for improper, personal and vindictive purposes, to wit, to punish and to humiliate the Plaintiff for having exposed his sexually harassing behaviors towards young female employees to the Human Resources Department, and punish Plaintiff for his disclosures and participation in the investigation. Defendant FULLER was fully aware that Mr. Randall was a part of the investigation conducted by human resources regarding the complaints made against him. 25. As a result of said conduct, Plaintiff was terminated from his employment, and suffered damages. WHEREFORE, Plaintiff respectfully requests that this Court: A. Award Plaintiff compensatory damages for lost wages and bene?ts, mental anguish, humiliation, loss of reputation, loss of the enjoyment of life, and pain and suffering; and, B. Award Plaintiff the costs of this action. COUNT IV: TORTIOUS INTERFERENCE v. Defendant BOEREAN 26. Plaintiff incorporates the allegations set forth in ?l?l 3. 27. Defendant BOEREAN, acting outside the course and scope of his employment, without justification, and for improper, personal and vindictive purposes, to wit, to punish and to humiliate the Plaintiff for having exposed his sexually harassing behaviors towards young female employees to the Human Resources Department, and punish Plaintiff for his disclosures and participation in the investigation. Defendant BOEREAN was fully aware that Mr. Randall was a part of the investigation conducted by human resources regarding the complaints made against him. 28. As a result of said conduct, Plaintiff was terminated from his employment, and suffered damages. WHEREFORE, Plaintiff respectfully requests that this Court: 7 A. Award Plaintiff compensatory damages for lost wages and bene?ts, mental anguish, humiliation, loss of the enjoyment oflife, and pain and suffering; A and, B. Award Plaintiff the costs of this action. JURY DEMAND PLAINTIFF DEMANDS A JURY TRIAL ON ALL ISSUES SO TRIABLE. I DECLARE UNDER PENALTY OF PERJURY that the foregoing factual allegations are true and correct to the best Of my and belief. aw wt 1a GRAHAM RANDALL Flo da Bar No. 437883 GARCIA LAW FIRM, PA. 120 South Olive Ave, Suite, 401 West Palm Beach, FL 33401 Telephone: (561) 832-7732 Telecopier: (561) 832-7137 E?mail: COUNSEL FOR PLAINTIFF GARCIA LAW FIRM, P.A. Telecopier: (561) 832?7137 FACSIMILE TRAN SMITTAL SHEET THE INFORMATION CONTAINED IN THIS FACSINIILE MESSAGE IS ATTORNEY PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED BELOW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMIVIUNICATION IN ERROR, PLEASE NOTIFY US BY TELEPHONE INIMEDIATELY. THANK YOU. DATE: November 16, 2017 TOTAL NUMBER OF PAGES (including this page): 5 PLEASE DELIVER THE FOLLOWING PAGES IMMEDIATELY TO: NALIE: Michael Farrell and Dante Bonner LOCATION: 305/808-1855 and 850/487-1007 FROM: Isidro Garcia 6) REFERENCE: Graha Club, LLC ENCLOSED: Please see with Charge of Discrimination. 120 South Olive Ave, Suite 401, West Palm Beach, Florida, 33401 Telephone (561) 832-7732 Telecopier (561) 832-7137 e-mail: EXHIBI. -.3 I GARCIA LAW FIRM, P.A. Isidro M. Garcia November 16, 2017 VIA FACSEVHLE AND CERTIFIED MAIL Michael Farrell, District Director FAX 305/808-1855 EEOC Miami District Of?ce Miami Tower 100 SE. 211d Street, Suite 1500 Miami, FL 33 131 Dante Bonner, Customer Service/Intake Manager FAX 850/487-1007 Florida Commission on Human Relations 4075 Esplanade Way, Room 110 Tallahassee, FL 32399?7020 Re: Graham Randall vs. Mar-a-Lago Club, LLC Dear Mr. Farrell and M. Bonner: Enclosed please ?nd a Charge of Discrimination on behalf of my client, Graham Randall. Please ?le same and call if you need any ?irther information or have any questions. This charge is not 4 being dual ?led, but is ?led separately with each of your agencies. I am submitting this joint letter to you so that you are aware that the charge is being ?led independently with each agency. Enclosure Copy without enclosure: Client 120 South Olive Ave., Suite 401, West Palm Beach, Florida 33401 Telephone (561) 832-7732-Telecopier (561) 832?7137 CHARGE OF DISCRIMINATION This form is affected by the Privacy Act of 1974; See Privacy Act Statement before completing this form. AGENCY CHARGE NUTMBER El FEPA EEOC Florida Commission on Human Relations and EEOC State or local Agency, if any NAME (Indicate Mr., Ms, Mrs.) MR. GRAHAM RANDALL HOME TELEPHONE (Include Area Code) 561-727-7554 STREET ADDRESS 12309 Court North CITY, STATE AND ZIP CODE WEST PALM BEACH, FL 33411 DATE OF BIRTH 05-09-1970 NAMED IS THE EMPLOYER, LABOR ORGANIZATION, ENIPLOYMENT AGENCY APPRENTICESHIP COMMITTEE, STATE OR LOCAL GOVERNMENT AGENCY WHO DIS CRIMINATED AGAINST ME (If more than one list below.) NAME MAR A LAGO CLUB LLC NUIVIBER OF TELEPHONE EMPLOYEES, (Include Area Code) MEMBERS 561-832-2600 +150 STREET ADDRESS CITY, STATE AND ZIP CODE THE TRUMP ORGANIZATION 725 FIFTH AVENUE NEW YORK, NY. 10022 NAME TELEPHONE (Include Area Code) STREET ADDRESS CITY, STATE AND ZIP CODE COUNTY CAUSE OF BASED ON (Check appropriate box(es)) RACE COLOR SEX RELIGION XRETALIATION AGE DISABILITY DATE TOOK PLACE EARLIEST LATEST 10/24/2017 I. INTRODUCTORY STATEMENT I WAS EMPLOYED AS EXECUTIVE PASTRY CHEF FOR THIS EMPLOYER FROM 20, 2012 UNTIL I WAS FIRED ON OCTOBER 24, 2017. I PERFORIVIED MY WORK VERY WELL AND WAS NEVER DISCIPLINED. I WAS TOLD THAT I WAS BEING LAID OFF DUE TO SEASONAL CANCELLATIONS AND THAT THE CLUB EXPECTED TO LOSE REVENUES OF $2.5 MILLION, THEREFORE I HAD TO BE RELEASED. HOWEVER, I BELIEVE THAT THIS IS NOT THE REAL REASON FOR MY LAYOFF SINCE THE CLUB REQUESTED AN INCREASE IN THE NUMBER OF GUEST WORKERS FROM ABROAD FROM THE DEPARTMENT OF LAB OR FOR THIS SEASON AND THIS INCLUDES ADDITIONAL PASTRY CHEFS. II. STATED REASON FOR DISCRIMINATORY TREATMENT. THE EMPLOYER, THROUGH HR MANAGER JANINE GILL, FOOD AND BEVERAGE DIRECTOR AARON FULLER AND EXECUTIVE CHEF BOGDAN BOEREAN MET WITH ME AND TOLD ME THAT I WAS BEING LAID OFF DUE TO ECONOMIC LOSSES THE CLUB WAS TAKING BECAUSE OF SEASONAL CAN CELLATIONS OF CHARITABLE ORGANIZATION EVENTS. DISCRIMINATION STATEMENT I BELIEVE I HAVE BEEN AGAINST BECAUSE OF MY OPPOSITION AND PARTICIPATION IN A SEXUAL HARASSMENT INVESTIGATION OF SEVERAL EMPLOYEES WHO COMPLAINED TO ME OF THE ACTIONS AGAINST THEM BY MR. FULLER AND MR. BOEREAN. PASTRY CHEF CHELSEA BRASWELL APPROACHED IVIE AND WAS VERY UPSET ABOUT BEING PRES SURED BY MR. SHE SHOWED ME SEXUALLY OFFENSIVE TEXTS FROM MR. FULLER, INCLUDING ME YOUR OR WORDS TO THAT EFFECT AND EXPLAINED SHE FELT VERY DEMEANED AND INTIMIDATED BY FULLER BECAUSE OF HIS HIGHER POSITION. CHELSEA WAS THEN A YOUNG WOMAN, 20 YEARS OF AGE, FULLER WAS A MARRIED MAN ABOUT 40 YEARS OF AGE. ANOTHER PASTRY CHEF, ELISE CARBON, ALSO COMPLAINED TO ME ABOUT SIMILAR SEXUAL HARASSMENT ISSUES BY MR. BOEREAN. ELISE WAS A YOUNG WOMAN ABOUT 23 YEARS OLD, BOEREAN A MARRIED MAN IN HIS THIRTIES. DETERMINING THIS WAS A VIOLATION OF COMPANY POLICY, AND MY UNDERSTANDING OF THE LAW THAT PROHIBITS SEXUAL HARASSMENT IN THE WORK PLACE, I REFERRED BOTH OF THESE WOMEN TO HR. FULLERAND BOEREAN HELD HIGHER POSITIONS THAN ME, SO I COULD NOT DISCIPLINE THEM. I WAS INTERVIEWED BY MS. GILL FROM HR. AND EXPRESSED MY DISAPPOINTMENT AND SURPRISE THAT MY BOSSES WOULD ENGAGE IN THIS TYPE OF CONDUCT AND INTERFERE WITH MY EMPLOYEES. THE REFERRAL AND MY CONVERSATIONS WITH HR OCCURRED ON OR ABOUT APRIL, 2017. THE HR DIRECTOR, MS. GILL, LATER CALLED ME TO ASK IF INEEDED ANYTHING ELSE AND THAT FULLER AND BOEREAN HAD RECEIVED WRITTEN REPRIMANDS. I BELIEVE THAT NIR. ULLERAND IVIR. BOEREAN WAITED SUFFICIENT TIME TO COVER THEIR TRACKS, AND THEN RETALIATED AGAINST ME FOR OPPOSITION TO THEIR SEXUAL HARASSMENT OF MY SUBORDINATE FEMALE EMPLOYEES. I BELIEVE THAT I ALSO LOST ANOTHER FEMALE PASTRY CHEF NAMED TARA WILLIAMSON AND SARAH (LAST NAME UNKNOWN) BECAUSE OF SIMILAR ISSUES BUT THEY DID NOT COMPLAIN KNOW TO HR. IV. RELIEF SOUGHT I SEEK LOST WAGES AND BENEFITS FROM THE DATE OF TERMINATION TO THE DATE OF TRIAL, LIQUIDATED DAMAGES, REINSTATEIVIENT TO MY EMPLOYMENT WITH INJUN TIVE RELIEF OR FRONT PAY IN LIEU OF REINSTATEMENT, COMPENSATORY DAMAGES FOR MENTAL AN GUISH, PHYSICAL PAIN AND SUFFERING AND PUNITIVE DAMAGES, PLUS FEES AND COSTS. I do not want this charge ?led with both the EEOC and the NOTARY - When necessary for State and local State or local Agency, if any. I will advise the agencies if I Requirements) change my address or telephone number and cooPerate fully with them in the processing of my charge in accordance with their procedures. I swear or af?rm that I have read the above charge and that it is true to the best of my knowledge, information and belief. I declare under penalty of perjury that the foregoing is true and SIGNATURE OF COMPLAJNANT correct. SUBSCRIBED AND SWORN TO IVIE THIS DATE November 16, 2017 (Day, month, and year) Date Charging Party (Signature) i i" P. 1 Result Report Nov.i6. 2017 3 Date/Time: Nov.i6e 20i7 Fite Page No. Mode Destination Pg(s) Result Not Sent 0832 Memory TX FCHR FAX P. 5 OK Reason for error E. 1) Hang up or line fa?t 2) Busy E. 3) No answer 4) No facsumlte connection E. S) Exceeded max. E-mai] size 6) Destlnai?ion does not support GARCIALAWFIRNLPA Tclboapiu'; (551) 332-7137 THE INFORMATION COMPARED IN THIS FACSIMJIE MESSAGE ATTORNEY PREVEEGED AND CONFIDENTIAL ION INTENDED ONLYFOR THEUSE OF THE INDIVIDUAL (1R Mm BELOW. THE READER OF THIS MESSAGEIS NOT RECIPIENT, YOUAREHEREBYNOTIFED THAT ANY DISSEWATION, DISTRIBUTION 0R COPY OF THIS COMMUNICATION IS STRICTLY YOU HAVE RECEIVED THIS 1N ERROR, PLEASE NOTIFY US BY TELEPHONE IMMEDIATELY. THANK. YOU. DATE: Novomba? 16, 2017 TOTAL NULIBER OF PAGES (?mcluding this page): 5 2! {Egg 2Q IEE PAGES MEDIATBLY NAME: Mixhwl Fund] un? Dani: Bonn:- LOCATION: 305/508-1855 and 8501487-1097 FROM: lsidm Gm REFERENCE: Graham mil-l n. Club. LE ENQOSED: Pin-ac so: 1mm WM 120 Smith Olin Ava, Satin 40], Wat Mm Bomb. Fluid-I. 33401 Turpin-a (551) BIL-7732 sznop-?Ier (561) 832-7137 until: lemmi?thudmxm i" i P. 1 3 Communication Result Report Nov.16. 2017 %i ate/Time: Nov.16. 2017 Fiie Page No. Mode Destination Pg(s) Result Not Sent 0831 Memory TX EEOC FAX P. 5 3058881855 E-i f0 6 5.1) Hang: up or 'line fail E.2) Susy E. 3) No answer 4) No faCSImIie connection E. 5) Exceeded max. E-maii size 6) Destination does not: support GARCIA LAW FIRM, RA. Tdocepim (561) 832-7137 EACSIMILE IMMI EAL g?gl THE INFORMATION CONTAINED IN THIS EACSIMILE WEAGE IS ATTORNEY PRIVILEGEDAND COMIDBGTIALINFORMATIONBVTENDED ONLY OF THE INDIVIDUAL OF. ENTITY NAMED BELOW. IF THEREADER OF THIS MESSAGE ISNOT HEIIEBYNOTIFIED THAT ANY DISTRIBUTION 0R COPY OF THIS COMMUNICATION IS STRICTLY IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US BY TEIIEPHONE IMMEDIATELY. THANK YOU. DATE: November 16, 2017 TOTAL OF PAGE (including ?ak mac): 5 EASE EL THE 01.10 MEDIATELY NAME: andDimte Bonnet LOCATION: 305?808-1855 and. 850337-1007 FROM mam Garcia REFERENCE: Grimm Knuth! VI. MAPl-ngg Club. LDC ENCLOSED: Please see latte: with Charge ofDiaczbnina?un. '.hbm.[xwm 120 IZSo-nthiiveAw, Sui.? 40]. Telephone (5 61) 332- 7732 Telempit: (551) 7137 Hui}: can stal Service? Wit RECEIPT a. F685 (check box, add is (hardcopy) I sr Restricted Delivery 9 Required '6 Restricted Detivery and Pegssq SENDER: COMPLETE THIS I Complete ite' s1, 2, and 3 I Print your name and address on the reverse so that we can return the card to you. Attach this card to the back of the maiipiece, or on the front if space permits. COMPLETE THIS SECTION ON DELIVERY A. Signature ?;j7hi21?UU1214h7 ece ed by (Printed Name) El Agent El Addresse . Date of De ive: 27* I latte. Voownqr 1+4- 0t" 15.. stal Service? FIED RECEIPT Mai! Only int-325329 to? no April 2015 PSN 7530- 02- 000- 9047 -, 1. Artiste Addressed to: that?. i?ormu guts?rota 9590 9402 1403 5329 7763 20 D. is delivery address different from item 1? Yes if YES. enter delivery address below: El No 31010 See Reverse for instructions 2. Articte Number (?ansfer from service iabeD 7o15 173n once noes 7an g] SBWIGB Type El Priority Mali Express? Aduit Signature Registered Mail? El dult Signature Restricted Detivery El Registered Mail ?esh-i: Certi?ed Mait? elivery [Ii Certi?ed Mail Restricted Delivery Return Receipt for Merchandise El Collect on Deiivery Collect on Delivery Restricted Delivery Es Slgnature Continuation Insured Mail Signature Contim-Iatlon El Insured Mail Restricted Delivery Restricted Deliver (over $50 0) .1- PS Form 3811. July 2015 PSN 7530027003053 ??9913th I Complete items 1, 2, and 3. I Print your name and address on the reverse so that we can return the card to you. I Attach this card to the back of the mailpiece, or on the front if space permits. Domestic Return Receir COMPLETE THIS secrrorv orv DELIVERY Went El Addressr C. Date of Delive '9 ~11: -..I--.I I Melee-ironic) testi?ed Delivery 5 Required 3 9 Restricted Delivery . 4 9 and Fees 6 . 59 med ?$qu to?. . 3.91 No" or POB 813%? ,Aprii 2015 PSN 7530- 02- 000- 9047 See Reverse for instructions . Article?ddr?E'sed to: I mama Eerie.? \00 the sash. \500 [News YL 3?5031 9590 9402 1403 5329 7763 13 2. Article Number (Transfer from service iabeD _?Dl5 l?3? none nose 7595! 3. ervice Type Adult Signature dult Signature Restricted Delrvery Certi?ed Mal ? El Certi?ed Mail Restricted Deiivery El Collect on Delivery - El Collect on Delivery Restricted Delivery [3 Signet 6 CoanrmatIcn Insured Mall El Signature Confirmation Insured Mall Restricted Delivery Restricted Delivery (over $500) PS Form 3811, July 2013 PSN Ieuu- Ud-UUu-uuth?bHLL Dgreestie?eturn Receit vice provides the following benefited I Jerti?ed Mail label}. rallplece. very or attempted :9 the recipient's rthe Postal Service" Niall service with Package Service't,? tavallabie for availabletor purchase 4 However. the purchase res not change the . iatlcally Included With with a proper llece,you may request which provides a record he recipient?s signature). of this label. ar?x It to the maliplece, apply mill! retum an appropriate postage, and deposit the mallpiece. a hardcopy return receipt. 1. Domestic He no . 3811 to your mallplece'. IMPORTANT: Save this receiptfor your records. a (Reverse) PSN 7530-0200080? tur an electronic retum receipt. see a retail mime tor assistance.To receive a duplicate retum receipttur no additional tee, present this .7. USPS?-postmarked Certi?ed Mail receipt to the retail associate. 7? Restricted delivery service. which provides delivery to the'addresl'seespecilied by' name, or to the addressee's authorized agent. - Adult signature service. which requires the slgnee to be at least 21 years of age (not available at retail). 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WEE 33 United ?tates Postal Service Sender: Please print your name. address, and in this box' I GARCIA LAW FIRM, P.A. Guaranty Building 120 S. Olive Avenue, Suite 401 West Palm Beach, FL 33401