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: gwilson@wilsonmccoylaw.comE:mail: nmccoy@wilsonmccoylaw.comAttorneys 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: mmoran@fordharrison.com, andAllen J. McKenna, Esq., E-mail: amckenna@fordharrison.com, and Bret C. Yaw, Esq., E-mail: byaw@fordharrison.com, 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

,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

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:

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

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

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

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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