v. CASE NO.: VERIFIED COMPLAINT FOR DAMAGES WITH REQUEST FOR EQUITABLE RELIEF AND DEMAND FOR JURY TRIAL

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1 Filing # Electronically Filed 09/26/ :39:11 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA PAUL E. FERRARO, Plaintiff, v. CASE NO.: THE BOARD OF TRUSTEES OF THE UNIVERSITY OF CENTRAL FLORIDA and UCF ATHLETICS ASSOCIATION, INC., Defendants. / VERIFIED COMPLAINT FOR DAMAGES WITH REQUEST FOR EQUITABLE RELIEF AND DEMAND FOR JURY TRIAL COMES NOW the Plaintiff, PAUL E. FERRARO ( Plaintiff or FERRARO ), and hereby sues Defendants, THE BOARD OF TRUSTEES OF THE UNIVERSITY OF CENTRAL FLORIDA ( UCF ) and the UCF ATHLETICS ASSOCIATION, INC., ( UCFAA and, collectively, Defendants ), and alleges as follows: INTRODUCTION 1. This is a claim for breach of express contract, unpaid wages, whistleblowing, tortious interferences, and civil conspiracy in which Plaintiff is seeking damages in excess of $15,000.00, exclusive of interest, attorneys fees and costs. 1

2 PARTIES 2. At all times material to this action, Defendant UCF was and is a public university within the State University System of the State of Florida, with its principal offices and primary campus located within Orange County, Florida. 3. At all times material hereto, Defendant UCF was and is an agency within the definitions of Florida Statutes and a state agency, pursuant to (1)(qq), Florida Statutes. 4. Defendant UCFAA is as private, not-for-profit corporation that operates the athletics program at Defendant UCF. 5. At all times material hereto, FERRARO was a resident of the State of Florida, and an employee of Defendant UCFAA. JURISDICTION 6. The instant suit includes claims for damages in excess of $15,000.00, and this Court therefore has original, exclusive jurisdiction pursuant to (2), Florida Statutes. 7. 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 8. Venue is proper pursuant to , Florida Statutes because Defendant maintains its primary offices and conducts business within Orange County, Florida. 2

3 9. 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 , Florida Statutes. FACTUAL ALLEGATIONS COMMON TO ALL COUNTS 10. FERRARO was initially hired by Defendant UCFAA on or about December 26, 2013, pursuant to a written contract with UCFAA ( Employment Agreement ). A copy of the Employment Agreement is attached as Exhibit A. 11. FERRARO was hired by UCFAA s head football coach George O Leary ( O Leary ), following the resignation of Defensive Coordinator Jim Fleming ( Fleming ). 12. FERRARO has more than 30 years of coaching experience, including many years as a defensive coordinator, and he previously coached at two other universities (Georgia Tech University and Syracuse University) under O Leary s supervision. 13. When hiring FERRARO, O Leary opined that Fleming had overcomplicated the defensive schemes by doing too much, and that he was seeking to simplify the UCF defense. 14. Upon his hire at UCF, FERRARO was instructed to delay his official Defensive Coordinator coaching duties until after the team played in the Fiesta Bowl football game in early January When FERRARO was hired by O Leary, he was 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. 3

4 16. FERRARO complied with O Leary s pre-fiesta Bowl instructions and, upon his hire, attended but merely observed the bowl preparation practices. 17. In the interim, O Leary elevated a young assistant coach, Tyson Summers ( Summers ), as Interim Defensive Coordinator for the Fiesta Bowl. 18. Summers performed well as Interim Defensive Coordinator both prior to and during UCF s victory in the 2014 Fiesta Bowl. 19. In fact, under Summers direction, UCF s defense held Baylor University s offense well below its statistical offensive per game averages for yards and points, which helped UCF win its first and only Bowl Championship Series ( BCS ) Bowl victory. 20. Following the Fiesta Bowl, FERRARO commenced his duties as Defensive Coordinator in earnest, including attending staff and unit meetings, performing player evaluations, reviewing game film, and implementing plans for spring practice. 21. After Summers performance in the Fiesta Bowl as Interim Defensive Coordinator, FERRARO noticed a marked change in behavior exhibited by O Leary towards FERRARO. 22. Specifically, after UCF s victory in the Fiesta Bowl, O Leary micromanaged the defense and instructed FERRARO to install a complex defensive scheme. 23. O Leary s instructions to FERRARO to implement a complex defensive scheme post the Fiesta Bowl countermanded his pre-fiesta Bowl instructions. 24. In addition, following the Fiesta Bowl, O Leary engaged in continuous and unwarranted criticism of FERRARO s work, including, by way of example, (a). after previously instructing FERRARO to simplify the defense, 4

5 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 drills; (c). in early February 2014, after a student-athlete requested to speak to FERRARO before a defensive coaching staff meeting, 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. 25. 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. 26. O Leary also created a work environment that was permeated by bullying, 5

6 threatening behavior, and repeated discriminatory epithets by O Leary. This was different from O Leary s conduct towards FERRARO when FERRARO had worked under him at Georgia Tech and Syracuse. 27. Some of the discriminatory remarks were uttered about FERRARO in his presence and concerned his Italian heritage. Specifically, O Leary called FERRARO a Guinea. 28. 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. 29. O Leary stated, if we can find one [an African-American coach], hire one, but 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 sent an message to O Leary objecting to O Leary s actions. FERRARO copied his fellow assistant coaches on the . A copy of the sent by FERRARO is attached 6

7 hereto as Exhibit B. 32. After FERRARO sent his to O Leary, he was called by UCF s Associate Athletic Director for Human Resources, Brian Reed ( Reed ), later that same day, February 25 th. 33. As Assistant Athletic Director, Reed reports directly to Defendant UCF s Vice President and UCFAA s Director of Athletics, Todd Stansbury ( Stansbury ). 34. During their call, FERRARO confirmed the discriminatory and hostile work environment to Reed. 35. When FERRARO was asked by Reed if he was tendering his resignation, FERRARO expressly told Reed that he was not resigning, but simply reporting the conduct. 36. Upon information and belief, Reed reported FERRARO s compliant to Stansbury. 37. Upon further information and belief, Reed also advised Stansbury that FERRARO was not resigning. 38. On February 26, 2014, the very next day after sending his , 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. 39. 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. 40. Stansbury s conclusion that FERRARO resigned was reached despite the 7

8 fact that FERRARO never tendered a resignation, verbally or in writing, as required by the Employment Agreement. 41. Nowhere within FERRARO s to O Leary of February 25, 2014 did FERRARO expressly indicate that he was resigning, quit, or left his position as Defensive Coordinator for personal reasons. 42. 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. 43. Stansbury s termination letter to FERRARO was dated February 26, 2014, just one day following FERRARO s to of February 25, 2014 to O Leary. 44. Stansbury referenced FERRARO s February 25, to O Leary in the termination letter. 45. Stansbury never spoke directly to FERRARO following the submission of FERRARO s on February 25, 2014 to O Leary. 46. After sending the February 25, to O Leary, FERRARO was later contacted and interviewed by telephone on February 28, 2014 by Maria Beckman ( Beckman ), UCF s Equal Employment Opportunity Director. 47. FERRARO again reiterated to Beckman some, but not all of O Leary s discriminatory, bullying and threatening comments. 48. FERRARO signed a prepared summary of the telephone interview on March 11, 2014, which was drafted by Beckman, entitled Interview Report ( Report ). 49. The Report did not include all facts discussed with Beckman. 50. Additionally, FERRARO admittedly did not disclose all of the offensive 8

9 and discriminatory remarks uttered by O Leary to Beckman. Instead, he merely summarized some of his concerns. 51. By way of example, FERRARO omitted discussing the coon, Ru-Ru tribe and blue gum comments made by O Leary. 52. Nowhere within the Report prepared by Beckham does it state that FERRARO expressly resigned. 53. The words resign or quit are not found in the Report. Moreover, the phrase leave for personal reasons is also not within the Report. 54. It was not FERRARO s intention to create disruption or have O Leary fired but, instead, to merely have his work environment improve. 55. After he was advised of his termination, FERRARO wanted to amicably resolve his dispute with the Defendants and negotiate a fair resolution. 56. 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 tactics and that he did not and was not resigning. 57. It was FERRARO s understanding that Defendants would investigate and take action to improve his work environment. 58. 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. 59. When Reed returned his call, FERRARO inquired of the status of the situation; however, Reed did not provide any details or any update. 9

10 60. During his last conversation with Reed, FERRARO once again confirmed that he had not and would not be resigning. 61. 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. 62. UCF and UCFAA treated FERRARO s February 25, to O Leary as if FERRARO had resigned. 63. FERRARO was not terminated pursuant to Paragraph 3(A) of the Employment Agreement. 64. FERRARO was not terminated pursuant to Paragraph 3(B) of the Employment Agreement. 65. FERRARO was not terminated pursuant to Paragraph 3(C) of the Employment Agreement. 66. FERRARO was not terminated pursuant to Paragraph 3(D) of the Employment Agreement. 67. FERRARO was not terminated pursuant to Paragraph 3(E) of the Employment Agreement. 68. FERRARO was not terminated pursuant to Paragraph 3(F) of the Employment Agreement. 69. FERRARO was not terminated pursuant to Paragraph 3(G) of the Employment Agreement. 10

11 70. FERRARO did not resign from his position with UCFAA. 71. FERRARO was terminated by Defendants without cause. 72. Following his separation from UCFAA, FERRARO was replaced by Summers as Defensive Coordinator. 73. 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.\ From April 2014 to the time of filing this Complaint, FERRARO has not been told anything more about the status or outcome of UCF s investigation into his complaints, as he has not heard further from Reed, Beckman, or anyone within UCF or UCFAA. CONDUCT COMPLAINED OF: COUNT I BREACH OF EXPRESS CONTRACT BY UCFAA 75. This is a cause of action by Plaintiff FERRARO seeking damages for breach of the parties Employment Agreement by UCFAA. 76. FERRARO repeats, adopts, and re-alleges the allegations of paragraphs 1 through 74, as if set forth more fully herein. 1 On July 1, 2014, FERRARO filed a Charge of Discrimination asserting retaliation under 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 ), , Florida Statutes. Upon the passage of 180 days from the date of its filing, the Charge will become judicially ripe for purposes of seeking to amend the Complaint and add a count for retaliation. 11

12 77. Defendant UCFAA entered into the Employment Agreement with FERRARO attached as Exhibit A. 78. Under such Employment Agreement, FERRARO was to be provided compensation for coaching services for two years. 79. FERRARO provided and was ready, willing and able to continue to provide coaching services for UCFAA under the Employment Agreement. 80. Defendants (through Stansbury), caused the termination of the Employment Agreement without notice and based upon false reasons. 81. UCFAA did not terminate FERRARO with cause as such term is defined in the Employment Agreement. 82. 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. 83. 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. 84. Defendants refusal to honor the terms of the Employment Agreement has caused FERRARO to incur damages. 85. As a result of the Defendants conduct alleged herein, FERRARO has retained the legal services of the law firm Wilson McCoy, P.A. to litigate the claims alleged herein. DEMAND FOR RELIEF WHEREFORE, FERRARO demands judgment against UCFAA for: 12

13 (a) All sums found to be due and owing under the Employment Agreement; (b) (c) Prejudgment interest; and Such other relief as this Court deems just and equitable. COUNT II UNPAID WAGES UNDER FLORIDA STATUTES AGAINST UCFAA 86. This is a cause of action by Plaintiff FERRARO solely against UCFAA, seeking recovery of unpaid wages due under the terms of the parties Employment Agreement. 87. Plaintiff FERRARO re-alleges and incorporate herein the allegations contained in paragraphs 1 through 74 above, as if set forth more fully herein. 88. The foregoing conduct has and continues to result in unpaid wages due Plaintiff under Florida law within the meaning of , Florida Statutes. 89. As a result of Defendants failure to pay the wages due and owing to FERRARO, Defendants have violated and continue to violate Florida law. for: DEMAND FOR RELIEF WHEREFORE, Plaintiff FERRARO demands a judgment against UCFAA (a) (b) (c) (d) Unpaid wages found to be due and owing; Prejudgment interest; His reasonable attorney s fee and costs; and Such other relief as this Court deems just and equitable. 13

14 COUNT III VIOLATION OF PRIVATE SECTOR WHISTLEBLOWER ACT BY UCFAA UNDER FLORIDA STATUTES, et seq. 90. This is a cause of action by Plaintiff FERRARO solely against UCFAA for breach of Florida s private-sector whistleblower act, pursuant to , et. seq., Florida Statutes. 91. Plaintiff FERRARO re-alleges and incorporate herein the allegations contained in paragraphs 1 through 74 above, as if set forth more fully herein. 92. At all times hereto, UCFAA was and is a private, not-for-profit corporation that operates the athletics program at Defendant UCF and, in such capacity, is a recipient of donations and is bound by the laws, rules and regulations governing a non-profit corporate recipient of such funds. 93. Pursuant to (3), Florida Statutes, a cause of action exists for any employee who has been the object of a retaliatory personnel action for object[ing] to or refusing to participate in any activity, policy, or practice of the employer which is in violation of a law, rule, or regulation. 94. At all times material to this action, FERRARO was an employee within the meaning of (2), Florida Statutes, in that he performed services for and under the control and direction of an employer for wages and other remuneration. 95. At all times material to this action, UCFAA was and is an employer within the meaning of, (3) Florida Statutes, in that UCFAA is a corporation that regularly employed ten (10) or more persons. 14

15 96. UCFAA is also an employer as defined by (7), Florida Statutes; the Florida Civil Rights Act ( FCRA ). 97. UCFAA must comply with the requirements of the FCRA. Through the actions of O Leary as described herein, UCFAA violated the FCRA. 98. FERRARO notified UCFAA of and objected to actual violations of laws, rules or regulations governing UCFAA s conduct including, but not limited to, O Leary creating a work environment that was permeated by repeated discriminatory epithets. 99. As a direct result and proximate cause of FERRARO s legally protected objection to O Leary s conduct, which is in violation of the FCRA, both to O Leary via dated February 25, 2014 and his conversation with Reed the same day, FERRARO was involuntarily terminated on February 26, 2014, effective March 11, 2014, by Defendant UCFAA s Director of Athletics, Stansbury UCFAA s agents, managers, officers and/or directors, primarily through Stansbury, actively and knowingly participated in the retaliatory personnel action against FERRARO because of his objections to the violation of civil rights laws concerning the work environment UCFAA s agents, managers, directors and/or officers, primarily through Stansbury, possessed constructive and/or actual knowledge of the wrongfulness of their conduct and the high probability that injury or damage to FERRARO would result and/or acted with such reckless disregard or absence of reasonable care to constitute a conscious disregard or indifference to the rights of FERRARO, and/or acted with such gross negligence that they contributed to FERRARO s damages, injuries and losses. 15

16 102. As a consequence of these actions, FERRARO has and continues to suffer damages including, but not limited to: loss of income, lost wages and benefits; as well as damage to his personal and professional reputation, damage to his standing in the college football coaching community, emotional distress, shame, embarrassment, humiliation and other non-pecuniary injuries. DEMAND FOR RELIEF WHEREFORE, Plaintiff FERRARO demands a judgment against Defendant UCFAA for: (a) compensatory damages for lost wages, benefits and any other applicable remuneration; (b) (c) (d) other compensatory damages as permitted by law; prejudgment interest; Plaintiff s attorneys fees and costs of this action; pursuant to , Florida Statutes; (e) injunctive relief consisting of an Order prohibiting further retaliatory action as provided under (2)(a), Florida Statutes; and (f) any other such relief as this Court deems just and proper. COUNT IV TORTIOUS INTERFERENCE WITH A CONTRACTUAL RELATIONSHIP AGAINST DEFENDANT UCF 103. This is a cause of action by Plaintiff FERRARO solely against UCF for tortious interference with a contractual relationship Plaintiff re-alleges paragraphs 1 through 74 as though fully set forth and incorporated herein. 16

17 105. Defendant UCF, through its officers, managers, supervisors, employees and agents, including Stansbury, knew or should have known that UCFAA and FERRARO had an existing employment relationship, as evidenced by, the Employment Agreement attached to this Complaint as Exhibit A Defendant UCF, through its officers, managers, supervisors, employees and agents, intentionally and unjustifiably interfered with the relationship between FERRARO and UCFAA Specifically, Defendant UCF, through its officers, managers, supervisors, employees and agents, willfully encouraged, persuaded, or induced UCFAA to violate the terms of the Employment Agreement between UCFAA and FERRARO Defendant UCF s actions constitute tortious interference with the contractual relationship FERRARO had with UCFAA As a result of the tortious interference with business and/or contractual relationships, FERRARO has suffered damages including, but not limited to: loss of income, lost wages and benefits; as well as damage to his personal and professional reputation, damage to his standing in the college football coaching community, emotional distress, shame, embarrassment, humiliation and other non-pecuniary injuries arising out of the Employment Agreement between FERRARO and UCFAA. DEMAND FOR RELIEF WHEREFORE, Plaintiff FERRARO demands judgment against UCF as follows: (a) General damages; (b) Compensatory damages for Defendant s tort violations; 17

18 employment; and (c) Plaintiff s reasonable expenses for searching for other (d) Any and all further relief this Court deems just and proper. COUNT V CIVIL CONSPIRACY AGAINST DEFENDANTS UCFAA AND UCF 110. This is a cause of action by Plaintiff FERRARO against Defendants UCFAA and UCF for civil conspiracy Plaintiff re-alleges Paragraphs 1 through 74 as though fully set forth and incorporated herein UCFAA, through its officers, managers, supervisors, employees and agents, and UCF, through its officers, managers, supervisors, employees and agents, conspired to terminate Plaintiff s employment with UCFAA On or about February 25, 2014 or February 26, 2014, Defendants knowingly and willfully conspired and agreed among themselves to damage the Plaintiff by causing UCFAA to terminate FERRARO s employment with UCFAA Because the termination of FERRARO s employment as conspired by Defendants could not be accomplished as set forth in FERRARO s Employment Agreement with UCFAA, it could only be accomplished by UCFAA willfully breaching its Employment Agreement with FERRARO Pursuant to the conspiracy, and in furtherance of the conspiracy, UCFAA did wrongfully terminate FERRARO s employment on or about February 26, 2014, effective March 11, 2014, at the demand of UCF. 18

19 117. FERRARO s termination resulted in the breach of the Employment Agreement between FERRARO and UCFAA As a direct and proximate result of these wrongful, intentional, and malicious acts on the part of both Defendants, FERRARO has suffered humiliation and actual damages. DEMAND FOR RELIEF WHEREFORE, the Plaintiff FERRARO demands judgment against the Defendants, jointly and severally, for: (a) general damages; (b) pre-judgment interest; (c) Plaintiff s reasonable expenses for searching for other employment; (d) costs of suit as incurred in this action; and (e) any other and further relief as this Honorable Court may deem appropriate. RESERVATION OF RIGHTS Plaintiff reserves the right to amend this Complaint to seek punitive damages against Defendant UCFAA in accordance with the requirements of , 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. 19

20 DATED this 26th day of September, Respectfully submitted, s/ Gary D. Wilson Gary D. Wilson, Esq. Florida Bar No.: Nathan A. McCoy, Esq. Florida Bar No.: WILSON MCCOY, P.A. 711 N. Orlando Ave., Suite 202 Maitland, FL Telephone: (407) Facsimile: (407) E:mail: Attorneys for Plaintiff, PAUL E. FERRARO 20

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22 Filing # Electronically Filed 09/26/ :39:11 PM EXHIBIT A

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26 Filing # Electronically Filed 09/26/ :39:11 PM EXHIBIT B

27 Filing # Electronically Filed 09/26/ :39:11 PM EXHIBIT C

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