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Filing # 198257866 E-Filed 05/14/2024 11:46:17 AM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
RAY DAVIS,
Plaintiff,
vs. CASE NO.:
AEGIS INSURANCE GROUP, LLC,
a foreign corporation,
Defendant.
_______________________________________/
COMPLAINT
Plaintiff, RAY DAVIS, by and through his undersigned counsel, sues the Defendant,
AEGIS INSURANCE GROUP, LLC a Florida company, and states as follows:
JURISDICTION AND VENUE
1. This is an action for damages in excess of Fifty Thousand Dollars ($50,000.00),
exclusive of costs, interest, and attorney’s fees.
2. Venue lies within Hillsborough County because a substantial part of the events
giving rise to this claim arose in this Judicial District.
PARTIES
3. At all times material herein, Plaintiff, RAY DAVIS, (hereinafter “Davis” or
“Plaintiff”) was and is a resident of Polk County, Florida.
4. At all times material herein, Defendant, AEGIS INSURANCE GROUP, LLC
(hereinafter “Aegis” or “Defendant”), was and is a Florida, authorized to and doing business in
Hillsborough County, Florida.
5. Defendant is an “employer”, as defined by the laws under which this action is
5/14/2024 11:46 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
brought and employs more than ten (10) employees.
FACTUAL ALLEGATIONS
6. Plaintiff began his employment with the Defendant on or around October 2023, as
a Licensed Insurance Agent.
7. On March 14, 2024, Plaintiff was on a call and noticed that the Defendant could
not beat the current carrier rates. As he was going to transfer the call to another department, his
supervisor, Brandon Armogum, told Plaintiff to stage the call and make it seem like the other
company was cheaper so they could make the sale.
8. Plaintiff refused to deceive the customer and told Mr. Armogum that he could take
the call if he wanted to.
9. Manager, Thomas Grant, walked by and saw Mr. Armogum on Plaintiff’s telephone
call. Plaintiff told Mr. Grant that Mr. Armogum wanted him to lie about the rates.
10. On March 15, 2024, Plaintiff was called and was told that owners of the company
were listening to the call and it seemed like Plaintiff didn’t want to do his job because he refused
to lie to the customer.
11. Plaintiff was terminated in retaliation for refusing to violate Title XXXVII, Chapter
626.9541 and the Florida Deceptive and Unfair Trade Practices Act.
12. Later that morning, Plaintiff emailed HR, Lyny Grullon, regarding the illegal
activity that was going on within the company.
COUNT I
(Florida’s Private Whistleblower’s Act)
13. Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in
paragraphs 1 through 12.
14. This is an action for damages pursuant to Florida’s Private Whistleblower’s Act,
5/14/2024 11:46 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Section 448.102, Florida Statutes.
15. Pursuant to Section 448.102, Florida Statutes, an employer may not take any
retaliatory personnel action against an employee because the employee has objected to, or refused
to participate in, any activity, policy, or practice of the employer which is in violation of a law,
rule, or regulation.
16. In contravention of said statute, Defendant terminated Plaintiff in direct retaliation
for objecting to and/or refusing to participate in a policy, practice or activity that was a violation
of a law, rule, or regulation.
17. As a result of Defendant’s unlawful acts as above-described, Plaintiff has and will
continue to incur attorneys’ fees, which are recoverable under Section 448.104, Florida Statutes.
18. As a result of the retaliatory actions of Defendant, Plaintiff has suffered and will
continue to suffer damages, including, but not limited to, the following:
a. Compensation for lost wages, benefits, and other remuneration;
b. Prejudgment interest;
c. Emotional pain and suffering, humiliation, and any other compensatory
damages allowable by law;
d. Reinstatement of the Plaintiff to the same position held before the
retaliatory personnel action, or to an equivalent position;
e. Reinstatement of full fringe benefits and seniority rights;
f. An injunction restraining continued violation of the FWA;
g. Attorney’s fees and costs;
h. Such other relief as the Court may deem just and proper.
WHEREFORE, Plaintiff, RAY DAVIS, demands a trial by jury and judgment against
Defendant, AEGIS INSURANCE GROUP, LLC for damages as described above in an amount
5/14/2024 11:46 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
within the jurisdictional limits of this Court, to wit: More than Fifty Thousand Dollars
($50,000.00) plus interest, attorney’s fees, and costs, and for such other and further relief to which
Plaintiff may be justly entitled.
DEMAND FOR JURY TRIAL
19. Plaintiff, RAY DAVIS, requests a jury trial on all issues so triable.
DATED this 14th day of May 2024
FLORIN | GRAY
/s/ Troy Longman II
TROY LONGMAN, II, ESQUIRE
Florida Bar No.: 1031921
Primary: tlongman@floringray.com
Secondary: debbie@floringray.com
16524 Pointe Village Drive, Suite 100
Lutz, FL 33558
Telephone (727) 220-4000
Facsimile (727) 483-7942
Attorney for Plaintiff
5/14/2024 11:46 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4
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Filing # 198257866 E-Filed 05/14/2024 11:46:17 AM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION RAY DAVIS, Plaintiff, vs. CASE NO.: AEGIS INSURANCE GROUP, LLC, a foreign corporation, Defendant. _______________________________________/ COMPLAINT Plaintiff, RAY DAVIS, by and through his undersigned counsel, sues the Defendant, AEGIS INSURANCE GROUP, LLC a Florida company, and states as follows: JURISDICTION AND VENUE 1. This is an action for damages in excess of Fifty Thousand Dollars ($50,000.00), exclusive of costs, interest, and attorney’s fees. 2. Venue lies within Hillsborough County because a substantial part of the events giving rise to this claim arose in this Judicial District. PARTIES 3. At all times material herein, Plaintiff, RAY DAVIS, (hereinafter “Davis” or “Plaintiff”) was and is a resident of Polk County, Florida. 4. At all times material herein, Defendant, AEGIS INSURANCE GROUP, LLC (hereinafter “Aegis” or “Defendant”), was and is a Florida, authorized to and doing business in Hillsborough County, Florida. 5. Defendant is an “employer”, as defined by the laws under which this action is 5/14/2024 11:46 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 brought and employs more than ten (10) employees. FACTUAL ALLEGATIONS 6. Plaintiff began his employment with the Defendant on or around October 2023, as a Licensed Insurance Agent. 7. On March 14, 2024, Plaintiff was on a call and noticed that the Defendant could not beat the current carrier rates. As he was going to transfer the call to another department, his supervisor, Brandon Armogum, told Plaintiff to stage the call and make it seem like the other company was cheaper so they could make the sale. 8. Plaintiff refused to deceive the customer and told Mr. Armogum that he could take the call if he wanted to. 9. Manager, Thomas Grant, walked by and saw Mr. Armogum on Plaintiff’s telephone call. Plaintiff told Mr. Grant that Mr. Armogum wanted him to lie about the rates. 10. On March 15, 2024, Plaintiff was called and was told that owners of the company were listening to the call and it seemed like Plaintiff didn’t want to do his job because he refused to lie to the customer. 11. Plaintiff was terminated in retaliation for refusing to violate Title XXXVII, Chapter 626.9541 and the Florida Deceptive and Unfair Trade Practices Act. 12. Later that morning, Plaintiff emailed HR, Lyny Grullon, regarding the illegal activity that was going on within the company. COUNT I (Florida’s Private Whistleblower’s Act) 13. Plaintiff realleges and adopts, as if fully set forth herein, the allegations stated in paragraphs 1 through 12. 14. This is an action for damages pursuant to Florida’s Private Whistleblower’s Act, 5/14/2024 11:46 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 Section 448.102, Florida Statutes. 15. Pursuant to Section 448.102, Florida Statutes, an employer may not take any retaliatory personnel action against an employee because the employee has objected to, or refused to participate in, any activity, policy, or practice of the employer which is in violation of a law, rule, or regulation. 16. In contravention of said statute, Defendant terminated Plaintiff in direct retaliation for objecting to and/or refusing to participate in a policy, practice or activity that was a violation of a law, rule, or regulation. 17. As a result of Defendant’s unlawful acts as above-described, Plaintiff has and will continue to incur attorneys’ fees, which are recoverable under Section 448.104, Florida Statutes. 18. As a result of the retaliatory actions of Defendant, Plaintiff has suffered and will continue to suffer damages, including, but not limited to, the following: a. Compensation for lost wages, benefits, and other remuneration; b. Prejudgment interest; c. Emotional pain and suffering, humiliation, and any other compensatory damages allowable by law; d. Reinstatement of the Plaintiff to the same position held before the retaliatory personnel action, or to an equivalent position; e. Reinstatement of full fringe benefits and seniority rights; f. An injunction restraining continued violation of the FWA; g. Attorney’s fees and costs; h. Such other relief as the Court may deem just and proper. WHEREFORE, Plaintiff, RAY DAVIS, demands a trial by jury and judgment against Defendant, AEGIS INSURANCE GROUP, LLC for damages as described above in an amount 5/14/2024 11:46 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 within the jurisdictional limits of this Court, to wit: More than Fifty Thousand Dollars ($50,000.00) plus interest, attorney’s fees, and costs, and for such other and further relief to which Plaintiff may be justly entitled. DEMAND FOR JURY TRIAL 19. Plaintiff, RAY DAVIS, requests a jury trial on all issues so triable. DATED this 14th day of May 2024 FLORIN | GRAY /s/ Troy Longman II TROY LONGMAN, II, ESQUIRE Florida Bar No.: 1031921 Primary: tlongman@floringray.com Secondary: debbie@floringray.com 16524 Pointe Village Drive, Suite 100 Lutz, FL 33558 Telephone (727) 220-4000 Facsimile (727) 483-7942 Attorney for Plaintiff 5/14/2024 11:46 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4