IN THE CIRCUIT COURT OF THE

11
TH
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA

CASE NO.

AYLER AYALA,

Plaintiff,

vs.

GLOBAL CONCESSIONS, INC., a Florida
corporation, GATEWAY AIRPORT
CONCESSIONS, INC., a Florida corporation,
and AIRPORT CONCESSIONS GROUP, INC.,
a Florida corporation, all d/b/a
GLOBAL MIAMI JOINT VENTURE,

Defendants.
______________________________________/

COMPLAINT AND JURY TRIAL DEMAND

Plaintiff AYLER AYALA, through undersigned counsel, sues Defendants
GLOBAL CONCESSIONS, INC., a Florida corporation, GATEWAY AIRPORT
CONCESSIONS, INC., a Florida corporation, and AIRPORT CONCESSIONS GROUP,
INC., a Florida corporation, all d/b/a GLOBAL MIAMI JOINT VENTURE (collectively
referred to as either Defendant or Global), and alleges as follows:
1. This is an action for unlawful national origin harassment and
discrimination in violation of the Florida Civil Rights Act, 760.01 et seq., Fla. Stat.
(FCRA).
2. Plaintiff AYLER AYALA was at all relevant times a resident of Miami-
Dade County, Florida, and is sui juris.
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3. Defendant Global is, and at all relevant times was, a Florida for-profit
corporation authorized to do business, and doing business in Miami-Dade County,
Florida. Defendant was at all relevant times in the business of operating food
concessions at Miami International Airport in Miami, Florida, and was an employer as
defined under the FCRA.
4. Plaintiff was employed by Defendant as a cashier at the Miami
International Airport from on or about May 15, 2010 until March 10, 2013.
5. However, prior to her employment with Defendant, Plaintiff was
employed at the Cafeteria at Versailles Cuban Restaurant (Versailles), a restaurant
owned and/or operated by members of the Valls family, including Felipe Valls, Sr. and
Felipe Valls, Jr. The Valls family, including Felipe Valls,, Jr., at all relevant times had
and maintained ownership and operating interests in Defendant, specifically in one of
Defendants joint venture partners, Global Concessions, Inc.
6. Plaintiff began her employment with Versailles on or about January 2005,
(approximately 1 week after she arrived to this country from Cuba). At the time, Plaintiff
was approximately 29 years old. Plaintiff obtained her employment at Versailles after she
was personally introduced to Mr. Felipe Valls, Sr., by her mother and father who (at the
time) both worked for the Valls family. After a brief introduction, Mr. Valls, Sr., offered
Plaintiff a part time position at the Versailles cafeteria.
7. Soon after Plaintiff began her employment at the Versailles cafeteria,
Felipe Valls, Sr. began to visit her place of employment on a regularly basis during her
working hours. Routinely, Mr Felipe Valls Sr. would approach Plaintiff and order a
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Menesier a Cuban pastry that costs about $1.50 upon being presented with his bill, he
would routinely pay for the tab and place a $100.00 bill in Plaintiffs pocket.
8. As time passed, Mr. Valls, visits to the cafeteria where Plaintiff was
working became more frequent and extended and they would often engage in
conversations. During one of their conversation, Plaintiff, who was only working part-
time at the time, informed Mr. Valls Sr., that she really needed to obtain more work hours
because she was not earning enough money to cover all her living expenses. Felipe Valls
Sr., responded that she should give him a call at his cellular number and that he would
attempt to obtain full time employment for Plaintiff.
9. After several phone conversation with Felipe Valls Sr., he finally told
Plaintiff to meet him at his office so that they could discuss her future job prospects with
in private. Hence, Plaintiff met Felipe Valls Sr., at his office thinking that she was there
to obtain a full time position at the Versailles Cafeteria. Instead, Felipe Valls, Sr., insisted
that she should not be looking to work so much and began to question why she wanted
to work full time instead he told Plaintiff that she should live her dreams and that he
could make all of her dreams come true. Thereafter, Felipe Valls Sr., offered Plaintiff
a full time job and a new BMW for her to travel from one restaurant to another as a secret
shopper and that way she could report personally to Felipe Valls Sr..
10. At the time, Plaintiff who had only been in Miami for a very short period
of time felt that she did not know the city enough to be driving around from restaurant to
restaurant on a daily basis. Consequently, Plaintiff declined the Secret Shopper
employment offer. Thereafter, Felipe Valls, Sr., told Plaintiff to think about his offers and
to please get back to him if she changed her mind.
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11. From that point forward, Felipe Valls, Sr., continued his pattern of
regularly visiting her at her employment, giving her irregularly large tips. Eventually, Mr.
Felipe Valls, Sr., also began to invite Plaintiff to meet him during her non-working hours.
Plaintiff initially refused Mr. Valls invitations, however, in the hopes of obtaining a full
time position, Plaintiff finally accepted Mr. Valls invitation to meet with him to discuss
her future and her dreams.
12. The events that followed, were extremely sordid and included having Ms.
Ayala engage in sexual relations with Mr. Valls, requesting that Ms. Ayala engage in
sexual relationships with another female Valls Group employees at the Miami Princess
hotel, photographing and videotaping Ms. Ayala naked and in sexually explicit poses,
and engaging in sexual relations with Ms. Ayala in a secret room at the back of Mr.
Valls private office in the restaurant that contained a bed and bathroom and was littered
with sex toys and sex paraphernalia. Ms. Ayala thus was and is well aware that Mr. Valls
followed this modus operandi with other female victims.

13. Therefore, while employed at Versailles, Plaintiff, who was financially
and emotionally vulnerable, was subjected to various acts of sexual abuse, sexual
harassment, and exploitation by one of the owners, Felipe Valls, Sr. Specifically, in
exchange for hundreds of dollars in cash payments, offers of expensive gifts and more
favorable working conditions and working hours, and continuing employment,
promotions and promises provided by Felipe Valls, Sr., Plaintiff was compelled to
engage in the following acts both off and on the premises of Versailles:
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a) Engaging in sexual relations with Felipe Valls, Sr. at the Miami Princess
Hotel in Miami, sometimes with Andrea, another young female employee of a Valls
family owned and operated restaurant; and
b) Engaging in sexual relations with Felipe Valls, Sr. in a hidden back room
in Felipe Valls, Sr.s office on the premises of Versailles that was equipped with a bed,
bathroom, and sexual toys.
14. During the period of time that Plaintiff was sexually exploited by Felipe
Valls, Sr., members of the management and ownership of Versailles, including Max
Tabua, Felipe Valls, Jr. and Jeanette Valls, were aware of Felipe Valls, Sr.s
inappropriate and repeated conduct with female employees of the Valls familys owned
and operated restaurants, including Plaintiff.
15. During 2008, Plaintiff ceased her sexual relations with Felipe Valls, Sr.,
and commenced seeing a new boyfriend, another employee of Versailles. At some later
time, Felipe Valls, Sr. sought to resume the sexual relation with Plaintiff, but Plaintiff
refused. In response, Plaintiff was terminated from her employment with Versailles at
the end of 2009.
16. Following her termination from Versailles, Plaintiff attempted to make an
unemployment benefits claim. However, Versailles submitted a false response to the
unemployment agency that indicated that Plaintiff had never been employed by
Versailles. Plaintiff then went to Felipe Valls, Sr.s office and sought to confront Mr.
Valls about the issue, but Mr. Valls was allegedly not available at the time. However,
apparently to avoid problems with Plaintiff at the time, and to stall Plaintiff from taking
legal action against Felipe Valls, Sr., Plaintiff was a week later offered a job with
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Defendant, through Plaintiffs father, who also was an employee of Felipe Valls, Sr.
17. While Plaintiffs employment with Defendant was uneventful for a period
of time, in 2012, Felipe Valls, Jr. and one of his daughters, Nicole Valls, while visiting
Plaintiffs work location, discovered that Plaintiff was still employed by a Valls owned
entity. Thereafter, Plaintiff was subjected to relentless and continuous acts of
harassment, including on the basis of Plaintiffs Hispanic national origin, from an
assistant manager, a non-Hispanic. This harassment included but was not limited to the
following:
a) Micromanaging and excessive scrutiny of Plaintiffs work;
b) Unfair and disparate disciplinary actions, warnings and reprimands;
c) Harassing and obscene comments such as referring, in front of Plaintiff to
Hispanics as Fucking Latins, and telling Plaintiff to speak only English because her
paychecks were written in English, not Spanish.
18. Plaintiff verbally complained to her general manager, Joe, another non-
Hispanic, about the harassment and asked to be separated from the assistant manager,
including asking for a shift change, but no investigation or corrective actions was taken.
Instead, the assistant managers harassment was permitted to continue.
19. Plaintiff thereafter internally complained to Brian, the Unit Manager,
another non-Hispanic and to Lourdes, Defendants human resources representative about
the harassment, and again no investigation was done or corrective action was taken.
20. As a result of the earlier sexually harassing and exploitive actions of
Felipe Valls, Sr. while she was at Versailles, the events surrounding her termination from
Versailles, the continuous harassment by Defendants assistant manager, and the failure
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of Defendant to address her complaints and take corrective action, Plaintiff suffered an
emotional breakdown at work in or about February 2013, resulting in Fire Recue being
called and treating Plaintiff.
21. As a result of the earlier sexually harassing and exploitive actions of
Felipe Valls, Sr. while she was at Versailles, the events surrounding her termination from
Versailles, the continuous harassment by Defendants assistant manager, and the failure
of Defendant to address her complaints and take corrective action, Plaintiff felt that she
had no choice but to resign her employment or continue to endure the harassment and
humiliation surrounding the current employment with Defendant. Therefore, on or about
March 10, 2013, Plaintiff was constructively discharged.
22. All conditions precedent have been satisfied, waived, or otherwise
excused.
23. Plaintiff has hired the undersigned attorneys to represent her in this suit,
and has agreed to pay them a reasonable fee for their services.
COUNT I NATIONAL ORIGIN DISCRIMINATION IN VIOLATION OF FCRA
24. Plaintiff re-alleges paragraphs 1 through 13 as if set forth fully herein.
25. The FCRA prohibits national origin discrimination against an employee
by a covered employer, such as Defendant.
26. Defendant, through the actions of its managers and assistant managers,
acting in the course and scope of their employment, engaged in unlawful national origin
discrimination against Plaintiff in violation of the FCRA as set forth herein above.
27. As a direct and proximate result of Defendants unlawful discrimination,
Plaintiff has suffered in the past, and will continue to suffer into the future, damages in
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the form of lost back pay and lost benefits, out of pocket pecuniary losses, and
compensatory damages, including damages for severe emotional distress, mental pain and
anguish, humiliation and loss of dignity.
28. Defendants engaged in their discriminatory conduct willfully,
maliciously, intentionally, and in reckless disregard for Plaintiffs rights under the law.
29. Plaintiff is entitled to recover her costs, including her reasonable
attorneys fees, per the FCRA.
WHEREFORE, Plaintiff demands judgment against Defendant for the following
relief:
A. A declaration that Defendants conduct constitutes unlawful national
origin discrimination in violation of the FWA;
B. An award to Plaintiff of her lost back pay and lost benefits;
C. Reinstatement of Plaintiff with appropriate accommodation, or an award
to Plaintiff of reasonable front pay if reinstatement is not feasible;
D. An award to Plaintiff of compensatory damages, including damages for
severe emotional distress, mental pain and anguish, humiliation, and loss of dignity;
E. An award to Plaintiff of punitive damages;
F. An award to Plaintiff of her reasonable attorneys fees, expenses and other
costs;
G. An award to Plaintiff of pre- and post-judgment interest; and
H. Such further relief as the Court deems just and proper.
COUNT II NATIONAL ORIGIN HARASSMENT IN VIOLATION OF FCRA
30. Plaintiff re-alleges paragraphs 1 through 13 as if set forth fully herein.
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31. The FCRA prohibits national origin harassment of an employee by a
covered employer, such as Defendant.
32. Defendant, through the actions of its assistant manager, acting in the
course and scope of his employment, engaged in unlawful national origin discrimination
against Plaintiff in violation of the FCRA as set forth herein above.
33. As a direct and proximate result of Defendants unlawful harassment,
Plaintiff has suffered in the past, and will continue to suffer into the future, damages in
the form of lost back pay and lost benefits, out of pocket pecuniary losses, and
compensatory damages, including damages for severe emotional distress, mental pain and
anguish, humiliation and loss of dignity.
34. Defendants engaged in their discriminatory conduct willfully,
maliciously, intentionally, and in reckless disregard for Plaintiffs rights under the law.
35. Plaintiff is entitled to recover her costs, including her reasonable
attorneys fees, per the FCRA.
WHEREFORE, Plaintiff demands judgment against Defendant for the following
relief:
A. A declaration that Defendants conduct constitutes unlawful national
origin discrimination in violation of the FWA;
B. An award to Plaintiff of her lost back pay and lost benefits;
C. Reinstatement of Plaintiff with appropriate accommodation, or an award
to Plaintiff of reasonable front pay if reinstatement is not feasible;
D. An award to Plaintiff of compensatory damages, including damages for
severe emotional distress, mental pain and anguish, humiliation, and loss of dignity;
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E. An award to Plaintiff of punitive damages;
F. An award to Plaintiff of her reasonable attorneys fees, expenses and other
costs;
G. An award to Plaintiff of pre- and post-judgment interest; and
H. Such further relief as the Court deems just and proper.
DEMAND FOR JURY TRIAL
Plaintiff hereby demands trial by jury of all issues so triable.
DATED this 29th day of August, 2014.

RODERICK V. HANNAH, ESQ., P.A. LAW OFFICE OF PELAYO
Counsel for Plaintiff DURAN, P.A.
4018 Sheridan St. Co-Counsel for Plaintiff
Hollywood, FL 33021 4640 N.W. 7
th
Street
954/362-3800 Miami, FL 33126-2309
954/362-3779 (Facsimile) 305/266-9780
305/269-8311 (Facsimile)


By____s/ Roderick V. Hannah __ By ___s/ Pelayo M. Duran ______
RODERICK V. HANNAH PELAYO M. DURAN
Fla. Bar No. 435384 Fla. Bar No. 0146595