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Filing # 27932581 E-Filed 06/01/2015 03:36:36 PM
IN THE CIRCUIT COURT OF THENINTH JUDICIAL CIRCUIT IN ANDFOR
ORANGE COUNTY, FLORIDA
PAUL E. FERRARO,
Plaintiff,
v. CASE NO.: 2014-CA-010117-0
UCF ATHLETICS ASSOCIATION, INC.,
Defendant./
SECOND AMENDED COMPLAINT FORDAMAGES WITH REQUEST FOR
EQUITABLE RELIEF AND DEMAND FOR JURY TRIAL
COMES NOW the Plaintiff, PAUL E. FERRARO ("Plaintiff' or
"FERRARO"),
and hereby sues Defendant, the UCF ATHLETICS ASSOCIATION, INC.,
("UCFAA"),
and alleges as follows:
INTRODUCTION
1. This is a claim for breach of express contract, and unlawful
retaliation
under the Florida Civil Rights Act of 1992, in which Plaintiff
is seeking damages in
excess of $15,000.00 for each count, exclusive of interest,
attorneys' fees and costs.
PARTIES
2. Defendant UCFAA is a private, not-for-profit corporation with
its office
located within Orange County, Florida.
3. Defendant UCFAA operates the athletics program at the
University of
Central Florida ("UCF"), a public university within the State
University System of the
State of Florida, also with its principal offices and primary
campus located within Orange
County, Florida.
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4. UCF was and is an "agency" within the definitions of Florida
Statutes and
a "state agency," pursuant to 216.011(1)(qq), Florida
Statutes.
5. At all times material hereto, FERRARO was a resident of the
State of
Florida.
6. At all times material hereto, FERRARO was an employee of
Defendant
UCFAA.
JURISDICTION
7. The instant suit includes claims for damages each in excess
of $15,000.00,
and this Court therefore has original, exclusive jurisdiction
pursuant to 26.012(2),
Florida Statutes.
8. This Court is vested with jurisdiction to order compensation
for lost
wages, benefits and other remuneration, injunctive relief,
reinstatement, attorneys' fees,
court costs, expenses, prejudgment and post-judgment interest,
and may permit a jury
trial.
VENUE
9. Venue is proper pursuant to 47.051, Florida Statutes because
Defendant
maintains its primary offices and conducts business within
Orange County, Florida.
10. In addition, the acts and omissions that give rise to this
action occurred in
Orlando, Orange County, Florida. Venue is therefore also proper
in this Circuit and
before this Court, pursuant to 47.011, Florida Statutes.
FACTUAL ALLEGATIONS COMMON TO ALL COUNTS
11. FERRARO was initially hired by Defendant UCFAA on or
about
December 26, 2013, pursuant to a written contract with UCFAA
("Employment
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Agreement"). A copy of the Employment Agreement is attached as
Exhibit "A".
12. FERRARO was hired by UCFAA's head football coach George
O'Leary
("O'Leary"), following the resignation of Defensive Coordinator
Jim Fleming
("Fleming").
13. FERRARO has more than 30 years of coaching experience,
including
many years as a defensive coordinator, and previously coached at
two other universities
(Georgia Institute of Technology ("Georgia Tech") and Syracuse
University) under
O'Leary's supervision.
14. When hiring FERRARO, O'Leary told FERRARO that Fleming had
over-
complicated the defensive schemes by "doing too much," and that
he was seeking to
simplify the UCF defense.
15. When hired by O'Leary, FERRARO was instructed to delay his
official
"Defensive Coordinator" coaching duties until after the UCF
football team played in the
Fiesta Bowl football game in early January 2014.
16. When FERRARO was hired by O'Leary, he was also told by
O'Leary to
"be seen, but not heard" during the Fiesta Bowl practices, as
O'Leary did not wish to
overhaul the UCF football team's defensive scheme prior to the
Fiesta Bowl.
17. FERRARO complied with O'Leary's pre-Fiesta Bowl instructions
and,
upon his hire, attended but merely observed the UCF football
team's Fiesta bowl
practices.
18. O'Leary elevated a young assistant coach, Tyson Summers
("Summers"),
as Interim Defensive Coordinator for the Fiesta Bowl.
19. Summers performed well as Interim Defensive Coordinator,
both prior to
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and during UCF's victory in the 2014 Fiesta Bowl.
20. Under Summers' direction, UCF's defense held Baylor
University's
offense well below its statistical per game averages for yards
and points, which helped
UCF win its first and only Bowl Championship Series ("BCS")
bowl.
21. Following the Fiesta Bowl, FERRARO commenced his duties
as
Defensive Coordinator in earnest. Such duties included attending
staff and unit meetings,
performing player evaluations, reviewing game film, and
implementing plans for spring
practice.
22. After Summers' performance in the Fiesta Bowl as Interim
Defensive
Coordinator, O'Leary's behavior towards FERRARO changed.
23. Specifically, after UCF's victory in the Fiesta Bowl,
O'Leary micro-
managed the defense and instructed FERRARO to install a complex
defensive scheme.
24. O'Leary's instructions to FERRARO to implement a complex
defensive
scheme post the Fiesta Bowl countermanded his pre-Fiesta Bowl
instructions.
25. Following the Fiesta Bowl, O'Leary engaged in frequent and
unwarranted
criticism of FERRARO's work as a long-time football coach,
including, by way of
example,
(a). after previously instructing FERRARO to "simplify the
defense,"
after the Fiesta Bowl asking FERRARO to install a complex
defense;
(b). by giving conflicting directives and messages, such as
approving
certain drills for an off season workout in UCF's indoor
practice facility on or
about February 12, 2014 and then, a few hours later, verbally
berating
FERRARO when O'Leary witnessed FERRARO leading the very same
approved
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drills;
(c). in early February 2014, after a student-athlete requested
to speak to
FERRARO before a defensive coaching staffmeeting, he (FERRARO)
ceased the
meeting because O'Leary had not yet arrived for the meeting. By
the time
FERRARO re-convened the meeting, O'Leary had arrived and berated
and
belittled FERRARO with profanities in the presence of
subordinate coaches and
staff;
(d). by quizzing FERRARO in defensive staff coach meetings
on
different scenarios in the presence of subordinate coaches and
staff, in hopes of
embarrassing or berating FERRARO depending upon his answers to
the
scenarios; and
(e). in general, by micro-managing the defense, contrary to what
he
had led FERRARO to be the case.
26. O'Leary's words and conduct appeared to indicate an
intention to not
honor FERRARO's Employment Agreement (an anticipatory breach);
and, instead, to
replace FERRARO with Summers after Summers' coaching performance
in the Fiesta
Bowl.
27. O'Leary also created a work environment that was permeated
with
bullying, threatening behavior, and repeated discriminatory
remarks by O'Leary. This
conduct was different from O'Leary's conduct towards FERRARO
when FERRARO had
worked under him at Georgia Tech and Syracuse.
28. Some of the discriminatory remarks were uttered about
FERRARO in his
presence and concerned his Italian heritage. Specifically,
O'Leary called FERRARO a
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"Guinea."
29. O'Leary also made discriminatory remarks about
African-Americans and
persons of Jewish descent. Specifically, when discussing with
O'Leary the possible hire
of an African-American coach if Summers left for a position at
the University of Georgia
(as was rumored at the time), the conversation turned to UCF not
having an African
American coach on the defensive staff. O'Leary stated, "if we
can find one [an African-
American coach], hire one," but lamented that "all those coons
are in the NFL. It's [the
NFL] one big 'Ru-Ru' tribe."
30. While in O'Leary's office the following week, O'Leary stated
to
FERRARO that he had spoken with a former assistant, who is now a
head coach in the
NFL, and that he (O'Leary) had advised his former assistant
that, while at the upcoming
NFL combine in Indianapolis, to "check the [African-American]
players to make sure
that their gums are blue, because they are bigger, faster and
stronger than [African-
American] players with red gums."
31. FERRARO eventually had enough of the offensive and
discriminatory
remarks. As a result, on February 25, 2014, FERRARO wrote and,
with the assistance of
Graduate Assistant Andrew Dodge, sent an e-mail message to
O'Leary objecting to
O'Leary's actions. FERRARO copied his fellow assistant coaches
on the e-mail. A copy
of the e-mail sent by FERRARO is attached hereto as Exhibit
"B".
32. After FERRARO sent his e-mail to O'Leary, he returned to
Homewood
Suites, the hotel where FERRARO had been residing since
commencing his duties for
UCF and UCFAA, pending the acquisition of a permanent
residence.
33. Because spring practice was not set to commence for
approximately two
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(2) weeks and no defensive staff meetings were scheduled that
day, FERRARO hoped
that his concerns would be addressed prior to the start of
spring practice.
34. While at his hotel that day, February 25, 2014, the only
call FERRARO
received from anyone within UCF or the UCFAA was by UCF's
Associate Athletic
Director for Human Resources, Brian Reed ("Reed"), shortly after
5:00 pm.
35. As Assistant Athletic Director, Reed reports directly to
UCF's Vice
President and UCFAA's Director ofAthletics, Todd Stansbury
("Stansbury").
36. During their brief call, FERRARO confirmed the
discriminatory and
hostile work environment to Reed as referenced in FERRARO's
e-mail.
37. When FERRARO was asked by Reed what were his (FERRARO's)
intentions and if he was tendering his resignation, FERRARO
expressly told Reed that he
was not resigning, but simply reported the conduct in hopes that
it would be addressed.
38. Upon information and belief, Reed reported FERRARO's
compliant to
Stansbury.
39. Upon further information and belief, Reed advised Stansbury
that
FERRARO was not resigning.
40. Based upon his conversation with Reed not providing any
assurance to
FERRARO during their brief telephone conversation on February
25th that anything
would be done immediately to address the situation, Reed called
FERRARO again, early
on February 26, 2014, and stated that he (Reed) needed to bring
something to
FERRARO.
41. The two met in the lobby of FERRARO's hotel. During the
meeting with
Reed on the afternoon of February 26, 2014 (the very next day
after sending his e-mail),
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FERRARO was placed on notice of his alleged resignation, with
the effective date being
March 11, 2014, by Stansbury ("Termination Letter"). A copy of
the Termination Letter
from Stansbury is attached as Exhibit "C".
42. Reed hand delivered to FERRARO the Termination Letter from
Stansbury
at the hotel meeting.
43. During their meeting, Reed stated, or said words to the
effect, "You've got
Stansbury concerned. Maria Beckman ("Beckman") [UCF's Equal
Employment
Opportunity Director] is involved. You should make them an offer
to settle."
44. Because he had heard from no one except Reed, on the evening
of
February 26th FERRARO called Defensive Line Coach Lorenzo
Costantini to assess
what was happening within the staff following FERRARO' s
e-mail.
45. Costantini confirmed their mutual desire to hopefully work
together again,
but also relayed that Assistant Head Coach Brent Key had stated
that O'Leary had
claimed that FERRARO "stabbed me [O'Leary] in the back."
46. FERRARO made airline reservations on February 26th to return
to Maine
to visit his girlfriend, whose mother was hospitalized at the
time.
47. FERRARO flew to Maine early on the morning of February
27th
believing there to be sufficient time for UCF and/or the UCFAA
to address his complaint
since spring practice did not begin until March 12, 2014,
48. However, in his letter, Stansbury concluded that that
FERRARO was
"leaving the Orlando area permanently... [and] ha[d] no intent
to return to [his] post as
Defensive Coordinator...".
49. Stansbury's conclusion that FERRARO resigned was reached
despite the
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fact that FERRARO never tendered a resignation verbally to
anyone or in writing, as
required by the Employment Agreement.
50. Nowhere within FERRARO's e-mail to O'Leary ofFebruary 25,
2014 did
FERRARO expressly indicate that he was resigning, quit, or left
his position as
Defensive Coordinator for personal reasons.
51. Stansbury was the authorized signatory of UCFAA on the
Employment
Agreement with FERRARO. Stansbury was thus well aware that
"written notice" from
FERRARO was required to effectuate his alleged resignation.
52. Stansbury's Termination Letter to FERRARO was dated February
26,
2014, just one day following FERRARO' s e-mail to ofFebruary 25,
2014 to O'Leary.
53. Stansbury had knowledge of FERRARO's February 25, 2014
e-mail to
O'Leary.
54. Stansbury referenced FERRARO's February 25, 2014 e-mail to
O'Leary
in the Termination Letter.
55. Stansbury never spoke directly to FERRARO following the
submission of
FERRARO' s e-mail on February 25, 2014 to O'Leary.
56. After sending the February 25, 2014 e-mail to O'Leary,
FERRARO was
later contacted and interviewed by telephone on February 28,
2014 by Beckman, UCF's
Equal Employment Opportunity Director.
57. Beckman had knowledge ofFERRARO's Agreement with UCFAA.
58. FERRARO again reiterated to Beckman some, but not all of
O'Leary's
discriminatory, bullying and threatening comments.
59. Beckman asked FERRARO if there were any video or audio
recordings to
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substantiate his claims.
60. FERRARO conceded that he did not record any of O'Leary's
remarks as
that was not his custom, but that he believed one of the
Graduate Assistants had recorded
a profanity laced tirade by O'Leary towards the Graduate
Assistants as a group, which
had occurred in approximately mid-February.
61. Graduate Assistant Paul Carrington had advised FERRARO of
O'Leary's
conduct towards the Graduate Assistants and stated to FERRARO
that he believed one of
the Graduate Assistants had recorded the incident.
62. FERRARO signed a prepared summary of the telephone interview
on
March 11, 2014, which was drafted by Beckman, entitled
"Interview Report" ("Report").
63. The Report was mailed to FERRARO in Maine for his review
prior to
executing it and returning it by mail.
64. The Report did not include all facts discussed with
Beckman.
65. Additionally, FERRARO admittedly did not disclose all of the
offensive
and discriminatory remarks uttered by O'Leary to Beckman.
Instead, he merely
summarized some of his concerns.
66. By way of example, FERRARO omitted discussing the "coon,"
"Ru-Ru
tribe" and "blue gum" comments made by O'Leary.
67. Nowhere within the Report prepared by Beckham does it state
that
FERRARO expressly resigned.
68. The words "resign" or "quit" are not found in the
Report.
69. Moreover, the phrase "leave for personal reasons" is also
not within the
Report.
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70. It was not FERRARO's intention to create disruption or have
O'Leary
fired but, instead, to merely have his work environment
improve.
71. After he was advised of his termination, FERRARO wanted to
amicably
resolve his dispute with UCFAA and negotiate a fair
resolution.
72. Although he did return to Maine prior to the start of spring
practice on
March 12th, FERRARO made it clear that he wanted to return to
work in an environment
free from O'Leary's bullish and discriminatory behavior, and
that he did not and was not
resigning.
73. It was FERRARO's understanding that Defendant UCFAA and/or
UCF
would investigate and take action to improve his work
environment.
74. As a further illustration of his hope that the investigation
would result in
changes in the work environment and FERRARO returning to his
coaching position,
FERRARO left his personal effects in Orlando in the same storage
facility that he secured
after he commenced the job, and where they still remain at the
present time.
75. At the conclusion of the interview with Beckman, FERRARO
asked
Beckman about the next steps in the investigation and how long
it would take, whereupon
Beckman said that it "would likely take 30 to 60 days" and that
she "would then decide
whether the Report went to the President [of UCF] or to the
Athletic Director
[Stansbury]."
76. FERRARO then asked Beckman to have Stansbury contact
him.
77. Stansbury left FERRARO a voice mail message later that day
or the next,
March 1, 2014. FERRARO attempted to reach him shortly
thereafter, but likewise was
unsuccessful and had to leave a voicemail message.
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78. Stansbury never attempted to reach FERRARO again and never
spoke to
him at all about the allegations in his (FERRARO's) e-mail or
the Termination Letter.
79. After the interview with Beckman, FERRARO waited for a
period of time
for a response. After several weeks passed, he attempted to
reach Reed in April and left
him a voice message.
80. When Reed returned his call, FERRARO inquired of the status
of the
situation; however, Reed did not provide any details or any
update.
81. During his last conversation with Reed, FERRARO once again
confirmed
that he had not and would not be resigning.
82. The Employment Agreement expressly states, "Employee may
terminate
this agreement without cause upon written notice to the Director
of Athletics effective
14 days after receipt of said notice (Athletic Director may
waive 14 day notice)."
(Emphasis added). FERRARO never tendered a written resignation
as required by his
Employment Agreement.
83. UCFAA and UCF treated FERRARO's February 25, 2014 e-mail
to
O'Leary as ifFERRARO had resigned.
84. FERRARO was not terminated pursuant to Paragraph 3(A) of
the
Employment Agreement.
85. FERRARO was not terminated pursuant to Paragraph 3(B) of
the
Employment Agreement.
86. FERRARO was not terminated pursuant to Paragraph 3(C) of
the
Employment Agreement.
87. FERRARO was not terminated pursuant to Paragraph 3(D) of
the
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Employment Agreement.
88. FERRARO was not terminated pursuant to Paragraph 3(E) of
the
Employment Agreement.
89. FERRARO was not terminated pursuant to Paragraph 3(F) of
the
Employment Agreement.
90. FERRARO was not terminated pursuant to Paragraph 3(G) of
the
Employment Agreement.
91. FERRARO did not resign from his position with UCFAA.
92. FERRARO was terminated by Defendant UCFAA without cause.
93. Following his separation from UCFAA, FERRARO was replaced
by
Summers as Defensive Coordinator.
94. FERRARO's separation, in the form of an alleged resignation,
was merely
a pretext to breach the Employment Agreement so that Summers
could be elevated to the
position of Defensive Coordinator, and out of retaliation
against FERRARO for reporting
discrimination.
95. From April 2014 to the time of filing this Complaint,
FERRARO has
been told nothing more about the status or outcome of UCFAA's
and/or UCF's
investigation into his complaints, nor heard further from Reed,
Beckman, or anyone
within UCFAA or UCF.
COUNT I
BREACH OF EXPRESS CONTRACT BY UCFAA
96. This is a cause of action by Plaintiff FERRARO seeking
damages for
breach of the parties' Employment Agreement by UCFAA.
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97. FERRARO repeats, adopts, and re-alleges the allegations of
paragraphs 1
through 95, as if set forth more fully herein.
98. Defendant UCFAA entered into the Employment Agreement
with
FERRARO attached as Exhibit "A".
99. Under such Employment Agreement, FERRARO was to be
provided
compensation for coaching services for two years.
100. FERRARO provided and was ready, willing and able to
continue to provide
coaching services for UCFAA under the Employment Agreement.
101. Defendant UCFAA (through Stansbury), caused the termination
of the
Employment Agreement without notice and based upon false
reasons.
102. UCFAA did not terminate FERRARO "with cause" as such term
is
defined in the Employment Agreement.
103. Because FERRARO was not terminated "with cause" as defined
in the
Employment Agreement, he is owed the balance of the compensation
owed under the
Employment Agreement, less any interim earnings.
104. To date, UCFAA has failed to pay FERRARO any additional
amounts
owed under the Employment Agreement since the effective date of
his separation of
employment with UCFAA.
105. Defendant's refusal to honor the terms of the Employment
Agreement has
caused FERRARO to incur damages.
106. As a result of the Defendant's conduct alleged herein,
FERRARO has
retained the legal services of the law firm Wilson McCoy, P.A.
to litigate the claims
alleged herein.
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DEMAND FOR RELIEF
WHEREFORE, FERRARO demands judgment against UCFAA for:
(a). All sums found to be due and owing under the Employment
Agreement;
(b). Prejudgment interest; and
(c). Such other relief as this Court deems just and
equitable.
COUNT II
UNLAWFUL RETALIATION BY UCFAA UNDER THE FCRA
107. This is a cause of action by Plaintiff FERRARO against
Defendant
UCFAA for intentional unlawful retaliation based upon FERRARO
complaining of,
objecting to, and reporting discrimination, brought pursuant to
760.01 760.11,
Florida Statutes, the Florida Civil Rights Act ("FCRA")
108. Plaintiff re-alleges paragraphs 1 through 95 as though
fully set forth and
incorporated herein.
109. The FCRA prohibits employers from discriminating and/or
retaliating against
an employee for participating in a protected activity.
110. FERRARO participated in protected activity by complaining
of, objecting to,
and reporting discrimination, in writing, to Defendant UCFAA by
virtue of his e-mail of
February 25, 2014. (Exhibit "B" hereto).
111. FERRARO reported his opposition of the racial slurs by
O'Leary to not only
O'Leary, but also to Reed.
112. Stansbury and Beckman were also informed, as noted in
paragraphs 38 and
58 herein.
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113. Stansbury acknowledged FERRARO's e-mailed objections to
racial slurs to
O'Leary in the Termination Letter he issued to Stansbury.
(Exhibit "C" hereto).
114. Accordingly, Defendant UCFAA was aware of FERRARO's
complaint of
and opposition to the discriminatory conduct.
115. As set forth in paragraphs 41 and 94, as well as the
Termination Letter,
FERRARO suffered an adverse personnel action, by being
involuntarily terminated on
February 26, 2014 by Stansbury, effective March 11, 2014, in the
form of an alleged
resignation.
116. On July 1, 2014, FERRARO timely filed a Charge of
Discrimination
("Charge") asserting retaliation for reporting and opposing
discrimination, in violation of
Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, as
amended by the Civil Rights
Act of 1991, 42 U.S.C. 1981a (collectively "Title VII"): as well
as the Florida Civil Rights
Act of 1992, ("FCRA"), 760.01-760.11, Florida Statutes. A copy
of the Charge, cover
letter to the EEOC, and facsimile confirmation is attached
hereto as composite Exhibit "D."
117. Because the FCHR failed to reach a determination as to the
merits of
Plaintiff's Charge within one hundred eighty (180) days since
the date of filing the Charge,
the Charge is thereby statutorily cloaked with a presumptive
finding of "cause," pursuant to
760.11(8) of the FCHR, and Plaintiff is authorized to proceed
with the instant claim,
pursuant to 760.11(4) (a), Florida Statutes.
118. Plaintiff's Charge is now judicially "ripe," and Plaintiff
has satisfied any and
all administrative prerequisites and all conditions precedent
prior to the filing of this action,
pursuant to the FCRA.
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119. There is a causal link between FERRARO' s complaint of,
opposition to and
report of the discrimination, and his immediate involuntary
termination the following day, in
the form of an alleged resignation.
120. No legitimate business reasons existed under UCFAA's
policies and/or
procedures to justify FERARO' s termination.
121. FERRARO' s purported "resignation" was merely a pretext for
unlawful
retaliation under the FCRA.
122. UCFAA, through its authorized agents and employees,
including but not
limited to Stansbury, engaged in the retaliatory conduct of
involuntarily terminating
FERRARO with full knowledge, but in willful disregard, of his
civil rights, in violation of
the FCRA.
123. As a direct and proximate result of UCFAA's wrongful,
intentional, and
malicious acts through its agents, including but not limited to
Stansbury, FERRARO has
suffered humiliation and actual damages.
WHEREFORE, FERRARO demands judgment against UCFAA for:
(a). damages for lost wages, benefits and any other
applicable
remuneration;
(b). compensatory damages for emotional anguish, pain and
suffering
as permitted by law;
(c). prejudgment interest;
(d). front pay in lieu of reinstatement;
(e). Plaintiff's attorneys' fees and costs of this action, if
Plaintiff
prevails, as permitted pursuant to 760.11(5), Florida
Statutes;
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(f). injunctive relief consisting of an Order prohibiting
further
retaliatory action as provided under 760.11(5), Florida
Statutes; and
(g). any other such relief as this Court deems just and
proper.
RESERVATION OF RIGHTS
Plaintiff reserves the right to amend this Complaint to seek
punitive damages
against UCFAA in accordance with the requirements of 768.72,
Florida Statutes.
DEMAND FOR JURY TRIAL
Plaintiff FERRARO hereby respectfully demands trial by jury on
all issues triable
of right before a jury, as permitted.
DATED this 1st day of June, 2015.
Respectfully submitted,s/ Gary D. WilsonGary D. Wilson,
Esq.Florida Bar No.: 0846406Nathan A. McCoy, Esq.Florida Bar No.:
0676101WILSON MCCOY, P.A.711 N. Orlando Ave., Suite 202Maitland, FL
32751Telephone: (407) 803-5400Facsimile: (407) 803-4617E-mail:
[email protected]:mail:
[email protected] for Plaintiff, PAUL E.
FERRARO
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that, on this 1st day of June, 2015, I
electronically filedthe foregoing with the Orange County Clerk of
Court by using the Florida Courts' efilingportal, with a true and
correct copy of the foregoing being furnished thereby to counsel
forDefendant UCFAA: Marilyn G. Moran, Esq., E-mail:
[email protected], andAllen J. McKenna, Esq., E-mail:
[email protected], and Bret C. Yaw, Esq., E-mail:
[email protected], FORD & HARRISON LLP, 300 South Orange
Avenue,Suite 1300, Orlando, FL 32801.
s/ Gary D. WilsonGary D. Wilson, Esq.
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May. 12. 2014 1:02PM Ut 1 izat ion Review No. 3013 P. 5
Err-7 IRTERCOLLEGIRTE ATHLETICSOFFICE 1lF THE DIRECTORDecember
23, 2013 PA..-----'Paul Ferraro (4000 Central Florida Blvd.
rOrlando, FL 32816l
Dear Mr. Ferraro:
Tho following serves as confirmation of thejob offer made to you
on behalfofthe UCF AthleticsAssociation, Inc.:
Position: Defensive Coordinator, FootballEmployer: UCPAA,
Inc.Semi-monthly Rate: fieL, $8,750 (equivalent to n4-8-00.0.0
(leEffective Date: tAild:e0P- January 3, 2014 iiaor rtbLength
ofTerms: I'll Two Years (Expirer January 2, 2016)FLSA Mahn:
Exempt1.ICFAA benefits for this position include:
1) Reimbursement ofrelocation expenses up to a maximum
$15,000.002) Sick leave, holidays3) R.etirement plan4) Membership
options in a variety ofhealth, life and/or supplemental group
Insurance
Programs
Employment with the UCFAA is governed by the UCFAA Employee
Handbook (attached). Please note thatif employee voluntarily
terminates employment with the UCFAA prior to completing one
calendar year'sfull-time service, he/the will be responsible for
reimbursing the UCFAA the relocation expenses mentionedabove
Reimbursement of relocation is at the discretion of the Director
ofAthletics, and unless agreed uponotherwise, payment to the UCFAA
shall be made within 90 days oftermination by employee.In
accordance with UCFAA, Inc. policy, all information that you have
provided to us regarding yourcredentials is subject to verification
as a condition ofemployment. Please acimowledge receipt ofthis
letterand your acceptance of the terms noted by signing in the
space pmvided so that we may proceed accordingly.We look forward to
having you jom UCF Athletics.
Sinc_edykh/I/ 7 Mt
Todd StansburyVice President and Dire
Signature acknowledges acceptance ofabove terms Date
EXHIBIT A1A UCF ATHLETICS ASSOCIATION, INC P.0 BOX
153555ORLANDO, FL 32816-3555 (407) 823.3132 FAX (407) 823.1274 s
WWW.UCFKNIGHTS.COMMN
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,May. 1 2. 2014 1: 0 3 P M Ut i 1 i tat ion Rev i ew No. 3013 P.
6
1:1CF ATBLETICS ASSOCIATION, INC.
17EMPLOYMENTAGREEMENTLILIOn behalf of the ucF Athletics
Association, Inc. (Athletics), it is a pleasure to offer you this
agreement for services as describedbelow. This agreement is subject
to the Constitution and Laws of the State of Florida and the
policies set forth in the AthleticsEmployee handbook. Neither this
agreement, nor any action of commitment taken pursuant to it, is
final or binding upon the partiesuntil, and unless, the signature
ofthe Director ofAthletics or representative as approving
authority, and the signature ofthe Employeehave been affixed. This
agreement must be returned to the approving authority (indicated by
the signature below) within 10 days ofthe date ofoffer.
Employee Name; PAUL FERRAROPosition Title: IJefensive
Coordinator ,Department: FootballLength ofAgreement: From: December
26, 2013 To: January 2, 2016Annual Rate ofPay: $220,000.00
Classification: ExemptB enefits: Eligible Leave: Sick
Special Conditions ofbnployment:Attached is the position
description, Addendum "A", associated with the position title
stated above, and this addendum is incorporatedby reference and
made a part hereof. The aforementioned position description,
position title, and classification may be modified orchanged at any
time during employee's employment and such changes shall be in the
sole discretion of the Director ofAthletics or hisdesignee.
Further, such a change shall not in any way be a breach of this
agreement.F1111 imowledge of NCAA, American Athletic Conference
(Conference) or any conference hereinafter that the University
ofCentralFlorida (UCF) may be a member, UCF and Athletics rules,
regulations and policies is a critical element ofthis position.
Therefore,employee must comply with all NCAA, Conference, UCF, and
Athletics titles, regulations and policies. Failure to comply with
theserules, regulations and policies will result in disciplinary
action appropriate to the offense and may include termination
ofemployment.This agreement viith all Addendum embodies the
complete agreement regarding employment and it replaces any
previous agreementthat Covers all or part of this period and
supersedes any such previous agreement Nothing in this agreement
shall be deemed to createany right, interest, or expectancy of
continued employment. flirther, Athletics reserves the right to
terminate this agreement at anytime. Accordingly, Employee may be
notified of termination at any time during the term of this
agreement Employee may beterminated for cause as noted on reverse
immediately upon written notice from the Director ofAthletics or
his designee.Employee may be terminated without cause upon written
notice from the Director ofAthletics or his designee. In the event
ofsuchtermination, Employee acknowledges and accepts a duty to
mitipte damages hereunder, and shall diligently search for
employment.Employee agrees to immediately notify Athletics if
subsequent employment is obtained. Upon such termination Employee
shall beentitled to receive at the option of the Athletics either
(1) the remaining balance of the salary payable, in accordance with
normalAthletics payroll procedures, for the remainder of the Tenn,
provided that such amount shall be reduced by any
subsequentemployment compensation; or (ii) a negotiated lump sum
amount as identified in Addendum "B", if attached hereto and
incorporatedby reference and made a part hereof.
Employee may terminate this agreement without cause upon written
notice to the Director ofAthletics effective 14 days after
receiptofsaid notice (Athletic Director may waivo 14 dv
notice).Nothing herein shall be construed as a guarantee of income
derived from any duties associated with sports camps or other
outsideemployment income. Employee may be eligible for additional
benefits and / or incentive compensation set forth on Addendum
"C".
LI Check hero ifAddendum "B" is attached
1:0 Check here ifAddendum "C" is attached,
UCIF Athletics Associa
EmployeeR.,c,By: By:Name: Todd Stans ry Name: Paul FerraroTitle:
Direlorofrtios Title: Defense CordinatorDate: 211 Date: I 114
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May. 12. 2014 1:03PM Utilization Review No.3013 P. 7
I. OUTSIDE EmpLoymurrAND ACTIVITIES. Employee shall obtain the
Athletics Director's advance approval to orange In any
outsideathletically related Income activities whIch could impact
the Employee's responribillties to Association, azd accurately
report all MOW and amounts ofincomeand benefits. Source, ofsuch
income and types ofactivilles shall include, but tre not limited
to, the following
A. Outside employment (paid or unpaid) B. lacome Rom annuities
C. Affillation with other sports groups or teamsD. Television and
radio programs E. Sports campa F. Housing (Including preferential
housing arnmatemenb)G. Countsy Club memberships H. Complimentary
ticket sales I. Endorsement or censultalion COntracts (shoe,
apparel, etc.)
STANDARDS.
A. Employee shall pawn his or her dudes and personally comport
himself or herself at all times in a manner consistent with good
aportsmanshlp and with thehigh moral, ethical and academic
standards ofAssocietion and University. At all times he or she
shall exercise due cam that all personnel and students under his
orher supervision or subject to his Or her Gomml or authority shall
compon themselves in liko manner. Employee shall &ohm observe
and respect the principles ofinstitutional control ofevery aspect
of all athletic programs.
B. Employee thriller agrees that he or alto, as well as all
personnel and students under his or her control / authority, will
remain conont and comply with applicabJefederal and slam laws
including the Buckley Amendment, IITPA (Hera Insuraoee %lability
and Accountability Act), University regulations, and
governingathletic rules. In pa:Ocular, Employee recognitea an
obllgaticn for self and personnel / =dente under hts or her control
/ authority to comply with laWs andgoverning athletic rules
including, but not limited to: recruiting Bed furnishing of
unauthorized extra benefits to recaults and student athletes;
illegal gambling;Illegal betting and bookmaldng; and Illegal us;
sale or pomesslon of narcotics, drugs, controlled substances or
other chemicals or steroids. In the event thatEmployee becomes
aware, or has reasonable cause to believe, that violations
Ofgoverning athletic ndes may have taken place, ho or she shall
report ibtly andacanal* thc stmte to the Athletics Director in a
timely manner.C. Unless notice hts been given by Association to
terminate employment, Employee shall not undes any circumstances
discuss or negotiate directly or indirectlyPomPective emPloroffit
with any other institution ofhigher !earning or professional
athletic team without the express pezmIsslan ofAucclation.D.
Amooistion shall have the right to lake disciplinary or COTTCCIlVB
action, short of suspension or termination for cause, against
Employee fer violation ofanyprovision of thie contract or for any
reason which would allow termination for cause listed below. Such
disciplinary gallon may include, but is nct limited toreprimand or
probation and shall not affect Association's rights of termination.
In addition, Employee shall be subject to disciplinary or
corrective action byappropriate officials for any violation of NCAA
or Conference regulations. Such action or Inaction by appropriate
officials shall not prethide or in any manneraffect Association's
right to take corrective or disciplinary action.E. ErtMloYee
recognize, that the primarY mission ofUniverrity is to serve as an
instlMilo ofhigher learning and shall Italy cooperate with academic
counselon orsimiier persons designated by Aesociation to aesiet
student athlete, and the faculty and administrators of Universiq in
connection with the medallic pursuite ofsludeut athletes end shall
use hislher personal best efforts to encourage and promote those
effons. In that respect Employee recognizes that the goal
ofAssociationand the University is that every student athlete
obtains a baocataumate degree and agrees to fully support the
attainment ofthis goal.F. Employee shall at ell times take every
action necessary to remain current, comply with, and implement the
policies of Association and UniversitY relating tosubstance abuse
and to class attendance by students subject to his/her direct
control or authority, and to exercise due care that all personnel
and students subject tohis/her direct control or authority comply
with such policies.3. TERMINATION FOR CAUSE
A. Neglect. inattention, or refloat by Employee to perform the
duties as specified in Addendum "A".E. Failure to comply with
Athletics policies and procedures set forth in the employee
handbook and policies and procedures manual; orC. Material,
significant or repetitive violation or breach ofcontract by
Employee, including above Standards and Outeide Employment and
Activities; orD. CommIsslon by Employee ofa criminal violation of
law whether prosecuted ornot (excluding minor Emilio offenses);
orE. Fraud or dishonesty ofEmployee In the preparation,
falsification, Or Aeration ofUniversity, Association, OT
COnferefICO documents or records; orF. Use or consumption by
Employee of alcoholic beverages Or narcotics, drugs, controlled
substances, steroids, or other chemicals in such degree and for
suchappreciable period as to impair significantly or materially his
ability to perform his duties hereunder; or0. Commission ofor
participation in by Employee of any act, situation, or occunenee
which brings Employee into public disrepute, contempt, scandal or
ridicule.or Thilure to conform personal conduct to conventionel
standards of good citizenship, with such conduce offending
prevailing social mores and values and/orreflecting unfavorably
upon University's or Association's reputation and overall printasy
mission end objectivee, including but not limited to, acts of
dishonesty,minute-imitation, fraud, or violence that may or may not
rise to a level warranting criminal prosecution by relevant
authorities.4. SUSPENSION EOR CRIMINAL OR OTHER CHARGES As an
alternative to the above, the Association,, at the discretion of
theDirector of Athletics, may suspend Employee with or without pay
In tho event of any farmal criminal inquiries or charges being
filed against the Employee orcondoning of such activities by
personnel and/cr students under such control or authority which the
Employee failed to act reasonably lo limit or Fermi, and
suchsuspension may continue until final reaolut ion ofthe matter or
proceeding.The Association, et the discretion of the Director of
Athletics, may also suspend Employee with or without pay in the
event ofany Gomel charges being filed withthe NCAA (major
infractions) against the Employee or condoning of such activities
by personnel and/or students under such control or authority whIch
theEmployee failed to act reasonably to limit or prevent. and such
suspension may continue until Anil resolution of tho matter or
proceeding.
TERMINATION FOR DEATH OR DISABILITY This contract shall
terminate automatically upon the death of 13mployco or ifEmployee
becomes totally disabled, preventing him or her front pe&rming
Om defined duties for a period ofnot less than three (3)
consecutive months. In theevent of termination by death or
dIsebIlity, neither Employee nor hls or her cattle shall be
entitled to any compensation or benefits provided for lit this
contractexcept any group insurance benefits as required by law.
GOVERNING LAWS, This contract shall be enforced end construed in
accordance with the laws ofFlorida.
CAlsIFS AND CLINICS,; During the term of this contract, Employee
shall be permitted to operate approved camps and clinics subject to
therestrictions set forth by the Associallon. Einployci agrees to
operate all activities Waled to approved camps and clinics through
the appropriate Association officesas designated by the Camp
Liaison.
EE Initial:
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May. 1 2. 2014 1:04PM Ut i 1 izat ion Review No. 3013 P. 8
UCF ATBLETICS ASSOCIATION, INC,
rir-F EMPLOYMENT AGREEMENTAddendum "C" Additional TermsAs stated
in the employment agreement between the UCFAA and Paul Pentro,
below are the additional termsduring the period ofDecember 26, 2013
to January 2, 2016:
Incentive Compensation
Upon participation by UCF in an NCAA sanctioned bowl gain;
Employee shall receive a bowl bonus in the amountofup to one (1)
month's base salary. Such a bonus is subject to approval by the
Athletics Director and contingentupon available finding.
Additional Benefits
Employee may from time to timo be offered additional benefits in
connection with his/her employment. The use ofsuch benefits is not
an element of employment; it is an optional item that is not
provided as, or in lieu ot othercompensation. Further, the employee
acknowledges and agrees that the employee has no rights or claims
foradditional benefits under this agreement, and such use is at the
discretion ofthe A.D. In the event that the employeeis provided
such benefits, employee agrees to comply with all then in effect
mks, regulations and policies.
c'sEmployee Initial
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Exhibit IMien Reed
From: Paul FerraroSent Tuesday, February 25, 2014 6:14 AMTo:
George O'Leary; MartyO'Leary; Tyson Summers; Lorenzo Costantini;
Kirk Callahan; Brent
Key; Danny Barrett; Sean Beckton; Mike Buscerni; Keegan Kennedy;
Brian Reed; Todd
Stansbury; Robert Jones; MaryVander Heiden; John Kvatek; Andrew
Dodge; Sean
Fitzgerald; Paul Carrington; Rob Calabrese; Will Glover
Coach Oleary,
No longer will I put up with your constant verbal abuse of both
our coaching and support staff. Threatening coacheson a
regular basis with their Jobs and racial slurs mixed in to make
a point is wrong.
I guess that formula ofbullying has worked in terms of wins +
losses but it is not the working environment that I want tobe
associated with.
I accepted this job because you said you wanted to simplify the
Defense. I was told multiple times "Fleming did toomuch'll Then you
force me to install 8 Pressures on in and 2" Downs; when I wanted 3
in Spring Ball. That is not simpleand not what I signed up for.
EXHIBIT B
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May. 1 2. 2 0 1 4 1: 0 2 P M Ut i 1 i zat ion Rev i ew No. 3013
P. 4
IIITERCOLLEGIRTE IITHLETICSOFFICE OF THE DIRECTOR
February 26, 2014
Todd StansburyDirector ofAthleticsUCF Athletics4000 Central
Florida Blvd., Bldg. #38Orlando, FL 32816
Paul FerraroDefensive Coordinator, FootballUCF Athletics4000
Central Florida Blvd., Bldg. it77Orlando, FL 32816
Dear Mr. Ferraro:
Based on your conversation last evening with Brian Reed,
Assistant A.D., HRRM yesterday at approximate 5:10pm thisletter is
to acknowledge that you have left your UCF issued property on your
desk and aro leaving the o areapermanently, flying back to Maine on
Thursday, February 27, 2014.
Per your employment agreement, you may terminate the agreement
without cause upon written notice to the Director ofAthletics
effective 14 days after receipt of said notice. As your actions
show that you have no intent to return to your postas Defensive
Coordinator of the Football program, we are accepting these actions
as your 14 day notice ofresignation fromUCF Athletics, and will
consider your last date of employment March 11, 2014. Please
provide Brian Reed immediatelywith a contact number by which to
coordinate your exit paperwork, including NCAA compliance
documents, payroll andinsurance information.
As stated in your offer letter, you are responsible for
reimbursing UCF Athletics the relocation expenses you have
incurredduring your transition. To date, we have incurred
$14,401.87 worth of relocation expense (temp housing at
HomewoodSuites, and relocation ofhousehold items and vehicle
through United Van Lines). As this is at my discretion, I am
willingto consider waiving the reimbursement requirement at this
time.
Your email to Coach O'Leary a 6:14am n February 25, 2014
contained comments that I am concerned about. To thatend, I have
assigned David Hans Ir. Associate A.D., Internal Operations to
assist UCF Equal Opportunity DirectorMaria Beckman in an
investigation of your claims As a component of this Investigation.
David will contact you at thenumber you provide Brian by which to
set up a time and discuss the email and actions leading up to this
email.
Ifyou have any questions, please direct them to Brian, David, or
myselfat yOur earliest convenience.
We reci a _guRervice to TJCF Athletics, and wish you the best
ofluck in your future endeavors./6 I
'Todd StansburyDirector ofAthle
AUCF ATHLETICS ASSOCIATION, INC P.O. BOX 163555 EXHIBIT
CORLANDO, FL 32816-3555 (407) 823.3132 FAX (407) 823.1274
WWW.UCFKNIGHTS.COMHMO
fir
-
WILSON MCCOYRA.WORK MATTERS
711 N. Orlando Ave., Suite 202 Representing employees,
employers, and unions (407) 803-5400 Tel.Mania nd, Florida 32751 in
work matters and related litigation. (407) 803-4617
Faxwiviv.wilsonnwcoylaw.com gwilson(ipvilsonmecoylaw.com
July 1, 2014
VIA FACSIMILE (305) 808-1855 & U.S. MAILIntake
SupervisorEEOC, Miami District OfficeOne Biscayne Tower, Suite
27002 South Biscayne BoulevardMiami, Florida 33131
Re: Paul Ferraro v. The University of Central Florida and UCF
Athletics Association, Inc.
Dear Intake Supervisor:
Please be advised that our office represents Mr. Paul Ferraro,
the above referencedcharging party. Enclosed please fmd Mr.
Ferraro's original Charge of Discrimination to be filedwith the
Equal Employment Opportunity Commission in this matter. Please also
dual file theCharge with the Florida Commission on Human Relations
pursuant to your WorkshareAgreement. Additionally, we request to
take part in the agency's Alternative DisputeResolution's mediation
process.
Should you wish to speak to our client, please contact our
office directly so that we cancoordinate a mutually agreeable date
and time.
Our office is happy to assist the EEOC in its investigation of
Mr. Ferraro's Chargeagainst The University of Central Florida and
UCF Athletics Association, Inc., the Respondentsin this matter.
Please do not hesitate to contact our office if we can provide you
with anyadditional information.
Bcst Regards,
Michael J. AugelloParalegal
Enclosure
-
CHARGE OF DISCRIMINATION AGENCY CHARGE NUMBERThis form is
affected by the Privacy Act of 1974. See Privacy Act Statement
before G FEPA 0 EEOCcompleting this form. FLORIDA COMMISSION ON
HUMAN RELATIONS and EEOC State or localAgency, ifanyNAME (Indicate
Mrs, Ms., Mrs.) DATE OF BIRTHMr. Paul E. Ferraro 4-30-59
1STREET ADDRESS CITY, STATE AND ZIP CODE HOME TELEPHONE (Include
Area Code)72 Western Rd. Warren, ME 04864 (207) 951-3820NAME OF THE
EMPLOYER, LABOR ORGANIZATION, EMPLOYMENT AGENCY APPRENTICESHIP
COMMITTEE,STATE OR LOCAL GOVERNMENT AGENCY WHO DISCRIMINATED
AGAINST ME (Ifmore than one, list below)NAME NUMBER OF EMPLOYEES,
MEMBERS TELEPHONE (IncludeArea Code)The University of Central
Florida andUCF Athletics Association, Inc. 15+ (407) 823-3132
STREET ADDRESS CITY, STATE AND ZIP CODE COUNTYUCF Athletics4000
Central Florida Blvd., Bldg. #38 Orlando, FL 32816 Orange
CAUSE OF DISCRIMINATION BASED ON (Check Appropriate Box) DATE
DISCRIMINATION TOOK PLACE
11:1 RACE C] COLOR El SEX El RELIGION 0 NATIONAL ORIGIN EARLIEST
LATESTEi RETALIATION CI AGE El DISABILITY 2-26-14 Ongoing to the
presentTHE PARTICULARS ARE:
I. Personal Harm: On February 26, 2014, I was placed on notice
of termination as Defensive Coordinator for the University
ofCentral Florida ("UCF") football team, effective March 11, 2014,
by the Director of Athletics for UCF, Todd Stansbury. I was hired
byUCF on December 26, 2013.1 was replaced by an assistant coach
with less overall experience in terms of years of coaching.II.
Respondent's Reason for Adverse Action: According to the letter
from Athletic Director Stansbury, an e-mail that I sentthe prior
day to UCF's head football coach, George O'Leary and my fellow
assistant football coaches was deemed as a notice ofresignation.
However, I never tendered a resignation, verbally or in writing;
with written notice required by my Employment Agreement.III.
Discrimination Statement: I believe that I was the subject of
retaliation for reporting and opposing discrimination in the
workenvironment, based on the following: (1) Since shortly after my
hire by UCF pursuant to an Employment Agreement, I was subjected to
awork environment that was permeated by pervasive bullying,
threatening, and repeated racial epithets by UCF's Head football
coach,George O'Leary. He was my supervisor and the person who hired
me. The racial remarks were uttered about me and in my presence
andconcerned my Italian heritage, as well as racial remarks about
African-Americans and persons ofJewish descent. Notably, I had
previouslyworked for Coach O'Leary at two prior universities and
had not observed him engage in such behavior; (2) I eventually had
enough of theoffensive remarks and hostile work environment and
wrote an e-mail to Coach O'Leary and copied my fellow assistant
coaches early onFebruary 25, 2014; (3) I was called by Associate
Athletic Director for Human Resources, Brian Reed, that same day,
February 25`11,wherein I confirmed the hostile and threatening work
environment to him. When asked by Mr. Reed if I was resigning, I
told him that Iwas not resigning, but simply reporting the conduct.
Although I returned to Maine prior to the start of spring practice
on March 12th, Imade it clear that I could not work in the hostile
environment, but was not resigning. (4) After sending the e-mail, I
was contacted andinterviewed by telephone on February 28'h by Maria
Beckman, UCF's Equal Employment Opportunity Director. I again
reiterated some,but not all of Coach O'Leary's conduct, and also
brought to her attention the constant bullying and threatening
comments by CoachO'Leary. I then signed a prepared summary of the
telephone interview on March 1 eh; (5) I attempted to contact Mr.
Reed in April and lefthim a voice message. When he returned my
call, I inquired of the status of the situation, but he was
noncommittal. I once again confirmedthat I was not resigning. In
fact, I never tendered a written resignation as required by my
contract; and (6) I was replaced by assistantcoach Tyson Summers as
Defensive Coordinator for UCF, who had served admirably in the
interim role for UCF's bowl game, prior to myfirst official day on
the job. Based upon the foregoing, my termination, in the form of
an alleged resignation, was merely a pretext forretaliation
(because ofmy report of discrimination).
Accordingly, I believe that I have been subjected to retaliation
for reporting and opposing discrimination, in violation of Title
VIIof the Civil Rights Act of 1964, 42 U.S.C. 2000e, as amended by
the Civil Rights Act of 1991, 42 U.S.C. 1981a (collectively
"TitleVII"): as well as the Florida Civil Rights Act of 1992,
("FCRA"), 760.01-760.11, Florida Statutes. I hereby request all
legal andequitable relief to which I am entitled, including
recovery of all my attorney's fees and costs.Ix)! want this charge
filed with both the EEOC and the State or NOTARY - (When necessary
for State and Local Requirements)
local Agency, if any. I will advise the agencies if I change
myaddress or telephone number and cooperate fully with them in
theprocessing of my charge in accordance with their procedures. 441
4 Or- aAL.,I declare under penalty of perjury that the foregoing is
true and correct. SUBSCRIBED AND SWORN TO BEFORE ME THIS DATE
SIGN AA' E It CON 'LAINANT Iczq 1I(Day,month, and year)- c.)
I swear or affirm that have read the above charge and that it
istrue to the best of my knowledge, information and belief.
DIANA L. DAREDATE: 6 / / Notary Publtc, State of MaineMY
Commission Expires March
17 2016
-
To: EEOC
FA X Fax number: 305-808-1855From: Gary Wilson
Wilson McCoy, P.A. Fax number: 407-803-4617711 N. Orlando Ave.,
Suite 202Maitland, Florida 32751Tel. 407-803-5400 Date: 7/1/2014Fax
407-8034617
www.wilsonmccoylaw.com Re: Charge ofDiscrimination Paul Ferraro
v. The7111111111111 University of Central Florida and UCF
Athletics
Association, Inc.
Total Number of Pages (including coversheet):(3)
Comments:
This facsimile is intended only for the use of the party to
which it is addressed and may contain information that
isprivileged, confidential, or protected by law. If you are not the
intended recipient you are hereby nofified that anydissemination,
copying or distribution of this facsimile or its contents is
strictly prohibited. If you have received thisfacsimile in error,
please notify us immediately and destroy this document and all
attachments, if any
-
Fax Send Image Page 1Date E. Time: JUL-01-2014 11:41AM TUEModel
Name: B1265dnf Laser MFPMachine Serial Number: 667J7S1
No Name/Number Start Time Time Mode Page Result
156 13058081855 07-01 11:39AM 0114" ECM 003/003 OK
To: EEOC
F A X Fax number. 305-808-1855-,From: Gaty WilsonWilson
McCoy,P.A.: Fax number 407-803-4617711 N. Orlando Ave., Suite
202
r-
Maitland, Florida 32751TeL 407-803-5400 Datc: 7/1/2014Fax
407-003-4617
www.vammmyhm.mm Re: Charge ofDiscrimination Paul Ferraro v;
Thewmegmee. University of Central Florida and UCF Athletics
mk Association, Inc.
1:1111 Total Number ofPages (including coversheet):(3)
I Comments:
This facsimile is intended only for the use of the party to
which it is addressed and may contain information that
Isprivileged, confidential, or protected by law. If you are not the
intended recipient you are hereby notified that anydissemination,
copying or distribution of this facsimile or its contents is
strictly prohibited. If you have received Wsfacsimite in error,
please notify us immediately and destroy this document and all
attachments, if any