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Case 0:17-cv-60327-WPD Document 1 Entered on FLSD Docket 02/13/2017 Page 1 of 28

IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Fort Lauderdale Division

Case Number:

TANNEN CAMPBELL,

Plaintiff,

vs.

MAGIC LEAP, INC., a Delaware
corporation,

Defendant.
/

Complaint — Jury Trial Demanded

Plaintiff, Tannen Campbell, sues defendant, Magic Leap, Inc. and

says:

Introduction and Summary

1. This is an action for hostile environment sex discrimination and

retaliation brought by Tannen Campbell ("Campbell" or "plaintiff"), former

Head of Strategic Marketing and Brand Identity and, later, Vice President of

Strategic Marketing and Brand Identity, against her former employer, Magic

Leap, Inc. (“Magic Leap” or “defendant”).

aa
pa The Amlong Firm ! 500 Northeast Fourth Street ! Fort Lauderdale, FL 33301 ! 954.462.1983
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Magic Leap is a “unicorn”—a startup company valued at more than $1

billion1 even though it has yet to bring a product on the market. It is

developing a mixed-reality headset—a headset containing a virtual retinal

display which superimposes 3D computer-generated imagery within the real

world. Magic Leap, touted as one of the most well-funded startups of all

time, employs over 1,000 employees in facilities in Broward County,

Florida; New Zealand; Dallas and Austin, Texas; Mountain View and Los

Angeles, California; and Seattle, Washington. Regretfully, few of those

employees are women, either in the ranks or in management.

Campbell, one of whose responsibilities was to help Magic Leap with

the “pink/blue problem,”2 had to endure hostile environment sex

discrimination while proposing ways, not only to make Magic Leap’s product

more woman friendly, but also to make the workplace more diverse and

inclusive. Campbell was terminated after (and because) she, like the child

in “The Emperor’s New Clothes”3 who blurted out that the Emperor was

1
Magic leap was valued at $5.7 billion prior to a critical report published
on December 8, 2016 by The Information, https://www.theinformation.com,
an online source of tech news that reported, “Magic Leap’s forthcoming product
won’t include the technology that has dazzled people in private
demonstrations.” Since then, Magic Leap stock has taken a 20 percent plunge
in the secondary market.
2
The “pink/blue problem” is a term used by Magic Leap internally to
define its marketing problem: the company is a large group of men designing
a device for men that doesn’t appeal to women; the only solution the company
has been able to come up with is to make a pink version of the product.
3
“The Emperor’s New Clothes” is a short story written by Hans Christian
Andersen, about two weavers who promise an emperor a new suit of clothes
(continued...)

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naked, challenged Magic Leap’s CEO, Rony Abovitz, to acknowledge the

depths of misogyny in Magic Leap’s culture and take steps to correct an

gender imbalance that negatively affects the company’s core culture and

renders it so dysfunctional it continues to delay the launch of a product that

attracted billions of investment dollars. Campbell also raised concerns that

what Magic Leap showed the public in marketing material was not what the

product actually could do—admonitions ignored in favor of her male

colleagues’ assertions that the images and videos presented on Magic Leap’s

website and on YouTube were “aspirational,” and not Magic Leap’s version

of “alternate facts.”

Campbell sues pursuant to Title VII of the Civil Rights Act of 1964, as

amended (“Title VII”), for damages, including punitive damages; equitable

relief including reinstatement or front pay; and her costs, including

reasonable attorneys’ fees.

Jurisdiction and Venue

2. This action arises under Title VII of the Civil Rights Act of 1964,

as amended, 42 U.S.C. § 2000e, et seq. (“Title VII”) Jurisdiction is founded

on 28 U.S.C. §§ 1331 and 1343(a)(4) and 42 U.S.C. § 2000e-5(f)(3). The

3
(...continued)
that they say is invisible to those who are unfit for their positions or
“hopelessly stupid.” The weavers mime dressing the Emperor. When the
Emperor parades before his subjects in his “new clothes,” the Emperor’s
ministers and the town’s people before whom he parades, as well as the
Emperor himself, cannot see the clothes but pretend they can for fear that
they will be seen as unfit for their positions, stupid, or incompetent. Finally,
a child cries out, “But he isn’t wearing anything at all!”

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Court has jurisdiction to grant declaratory and further relief pursuant to 28

U.S.C. §§ 2201 and 2202.

3. Venue is proper in the Fort Lauderdale Division of the Southern

District of Florida pursuant to 28 U.S.C. § 1391(b) because the claims arose

there and Magic Leap’s principal place of business is in Broward County,

Florida.

Parties

4. Campbell, at all times material, was protected by Title VII

because:

a. she is a woman who suffered discrimination; and

b. she opposed what she reasonably believed to be unlawful

under Title VII.

5. Magic Leap is a Delaware corporation, the principal office of

which is in Florida, that employs more than 501 persons. It is an

“employer” as envisioned by 42 U.S.C. § 2000e(b).

Satisfaction of Conditions Precedent

6. Campbell filed a charge of discrimination with the EEOC on or

about December 21, 2016. The EEOC issued Campbell a Notice of Right to

Sue dated February 8, 2017, within 90 days of her receipt of which she is

filing this action.

7. All other conditions precedent have been satisfied or waived.

Applicable Statutory Provisions

8. Title VII provides at 42 U.S.C. § 2000e-2(a):

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It shall be an unlawful employment practice for an employer —

(1) to fail or refuse to hire or to discharge any individual,
or otherwise to discriminate against any individual with respect
to his compensation, terms, conditions, or privileges of
employment, because of such individual’s ... sex ...; or

(2) to limit, segregate, or classify his employees ... in any
way which would deprive or tend to deprive any individual of
employment opportunities or otherwise adversely affect his
status as an employee, because of such individual’s ... sex....

9. Title VII further provides at 42 U.S.C. § 2000e-3(a):

Discrimination for making charges, testifying,
assisting, or participating in enforcement proceedings. It
shall be an unlawful employment practice for an employer to
discriminate against any of his employees ... because he has
opposed any practice made an unlawful employment practice by
this title, ....

General Allegations

Magic Leap hires Campbell to help with the “pink/blue problem.”

10. Campbell, who formerly was a creative director for a digital

advertising agency, was hired by Magic Leap in April 2015 as Head of

Strategic Marketing and Brand Identity by its CEO, Rony Abovitz.

11. Abovitz, who founded Magic Leap in 2011, interviewed Campbell

in March 2015 after she applied for a job with Magic Leap. During the

interview, Campbell joked that all of advertising was a “boys club.” Abovitz

replied that tech was the same way, but he wanted his company to be

different, and asked Campbell if she could help with that. Campbell happily

responded that she could.

12. Magic Leap had not a single woman in leadership at the time it

hired Campbell, and the company was designing a product and experience,

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that company leadership recognized was designed for men. All the

engineers and others in predominately-male Magic Leap could conceive of

to make the product female friendly was to produce a version in pink.

Abovitz articulated one of his reasons for hiring Campbell: “She can help

with the pink/blue problem.”

Magic Leap was run by Abovitz sycophants.

13. Magic Leap is run by people comprised largely of Abovitz

sycophants including:

a. Henk Vlietstra, Chief Administrative Office, who despite no

formal training in human resources, functions as the company’s chief

human resources officer. Vlietstra rarely disagrees with Abovitz; he

also—by ineptitude, ignorance or unwillingness to press Abovitz—has done

and failed to do things that have allowed a corporate culture inhospitable to

women to develop and persist. For example:

i. Vlietstra has not issued a company handbook and no

articulated official policies exist prohibiting illegal discrimination,

harassment and retaliation exist within Magic Leap —other than self-serving

tweets posted by Abovitz designed make himself appear in a favorable light.

ii. Vlietstra has not instituted programs or made the

right hires to fix major cultural issues at Magic Leap. For example, unlike

virtually every employer with a website, the Magic Leap website nowhere

states that it is an equal opportunity employer and wants women to be

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among the “Wizards” it is seeking in the “Wizards Wanted” section of its

website. Indeed, given that a “wizard” generally is defined as “a man who

has magical powers,” and virtually without exception images of wizards are

male, Magic Leap’s recruiting verbiage contains a not-so-subtle “women-

need-not-apply” message.

iii. Despite the substantial workforce, Vlietstra did not

hire a director of diversity when major complaints from all protected

classes, including women, arose.

b. Scott Henry, CFO, is the kind of man who sits a little too

close to women and makes them feel uncomfortable with his body

language, flirting and objectification. He generally treats women as objects

of beauty (or not) rather than co-workers worthy of respect. He is a bully

and when he does not get his way, he belittles his adversary.

c. Eric Akerman, Vice President of IT, is a high school buddy

of Abovitz. He is a loud and outspoken and several misogynistic comments

have emanated from his department and from him.

d. Mark Albert, General Counsel, is a transactional attorney

whose primary focus has been on mergers and acquisitions, venture capital

financings, and initial public offerings, not employment law.

e. Rachna Bhasin, a New Zealander hired in fall 2015, is

Chief Business Officer. She is the perfect Magic Leap female employee: she

went Harvard, never disagrees with Abovitz and always does Abovitz’s

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bidding even when common sense or her own experience run counter. She

makes the company appear diverse and inclusive although it is not.

14. At all material times, the employees identified in paragraph 13

were working within the course and scope of their employment and

authority.

Campbell prepared a presentation that describes Magic Leap’s
gender problem and proposed solutions, which Abovitz ignored.

15. In the first few months that Campbell worked for Magic Leap, in

addition to her regular work, she put together an approximately 50-slide

PowerPoint® presentation (“deck”) about gender diversity statistics across

the tech industry, as well as at Magic Leap, plus ideas of things Magic Leap

could do to improve diversity in its workplace and make it more woman

friendly.

16. For example, while only 30 percent of total jobs and 13 percent

of engineering jobs in tech are held by women, and only three percent of

leadership positions, Magic Leap’s track record was even worse: in addition

to having no women in leadership positions, only 14 percent of its

employees (including clerical, human resources and marketing) and three

percent of its engineers were female. As Campbell showed in one slide in

her deck, Magic Leap got an “F” in gender equality and equal employment

opportunity.

17. The deck also highlighted reasons why Magic Leap should care

about diversity, both in its workplace and with regard to marketing its

product, including:

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a. statistics demonstrating that companies who maintain

gender diversity and employ women in leadership roles see greater return

on their investments across the board, and

b. statistics showing that women make tech buying decisions

for the household, comprise the majority of gamers and use technology

more often than men.

18. Campbell proposed ideas for the short term that could be

implemented immediately, including:

a. creating and appending an “Equal Pay Guarantee” stamp

or seal on all Magic Leap’s position descriptions in recruiting material and

elsewhere, evidencing Magic Leap’s commitment to equal pay for equal

work within the same tier;

b. “fishing where the fish are” by recruiting employees from

a list of colleges, provided by Campbell, with the highest number of women

in STEM (Science, Technology, Engineering and Mathematics) departments;

c. assigning a recruiter whose only job would be “partner

placement” — helping the husbands and partners of women job applicants

who were not the primary earners in their households get a great job, too,

thus making moving to Florida easier;

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d. implementing a gender-focused Rooney Rule4 in

recruiting, requiring that for every five candidates brought in, two must be

women and must be interviewed and considered; and

e. demonstrating a commitment to encouraging young girls’

interest in tech education by replacing the “swag”—T-shirts, notebooks and

the like—handed out to important visitors with a donation in the important

visitor’s name to Girls Who Code, an organization devoted to overcoming

the gender gap in tech jobs.

19. Campbell also proposed mid-term goals that could be

implemented in the next six-months-to-a-year including:

a. creating an internal mentorship program pairing men with

women;

b. increasing paternity leave to show that Magic Leap values

a man’s role in child caregiving and allows busy moms to return to work

sooner if they choose;

c. tying diversity to extra bonuses, e.g., giving a department

head an additional bonus for increasing gender diversity;

d. implementing mandatory “unconscious bias training” for

leadership;

4
The Rooney Rule is a National Football League policy that requires
league teams to interview minority candidates for head coaching and senior
football operation jobs. It is sometimes cited as an example of affirmative
action, though there is no quota or preference given to minorities in the hiring
of candidates.

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e. creating “parents’ guides” for cities where Magic Leap had

offices, and listing recommended doctors, babysitters, etc. for newcomers;

and

f. establishing internships for female students to code/build

for mixed reality.

20. Finally, Campbell’s presentation proposed long-term goals,

including:

a. having an onsite daycare facility;

b. sponsoring an internal Girls Who Code project, where girls

from the program are mentored and taught mixed reality technology onsite;

c. creating inviting and private “mom rooms” where nursing

mothers could pump breast milk;

d. donating to the organizations that made the biggest

difference in solving the “pipe flow problem”—the fact that few women

apply for tech jobs; and

e. establishing a speaker series at Magic Leap that brings in

tech’s most successful female thinkers, e.g., Sheryl Sandberg and Meg

Whitman.5

5
Sandberg is the COO of Facebook and the author of Lean In: Women,
Work, and the Will to Lead. Time magazine named her as among the 100 most
influential people in the world. Whitman currently is the President and CEO
of Hewlett Packard Enterprise; she ran unsuccessfully for President of the
United States in the 2016 primaries. Previously, Whitman held a number of
high level executive positions including as President and CEO of Hewlett-
Packard Company and of eBay.

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21. The first deck was ready for Abovitz’s review in July 2015, but

despite Campbell’s efforts—the meeting was scheduled and cancelled six

times—Abovitz did not meet with Campbell to review the presentation until

February 10, 2016. At that meeting—which also was attended by Campbell,

Vlietstra and Laura Laugenhaug, Magic Leap’s then-Vice President of Human

Resources who has since left the company—Abovitz arrived late and allowed

Campbell to get through only about half of the presentation before

terminating the meeting, and telling her to schedule a second meeting to

finish going over the deck.

22. Campbell attempted three times over the next three months to

schedule a meeting with Abovitz to finish presenting the deck, but each

attempt resulted in the same response from his secretary: this was not

among Abovitz’s priorities. After the third time, Campbell got the message

and gave up.

23. Campbell did not speak again to Abovitz about the deck until

September 2016, when she was promoted to Vice President of Strategic

Marketing and Brand Identity, as more particularly described in paragraph

48.

Meanwhile, Abovitz paid lip-service to gender issues and created
the Female Brain Trust Initiative (“FBI”) and Women’s Inclusion
Network (“WIN”), which did nothing.

24. Abovitz, in May 2016, asked Bhasin to head up a “female brain

trust initiative”—the “FBI.” Originally, the FBI was tasked to influence

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product design and content to insure Magic Leap was not designing just for

men.

25. The group’s initial meeting took place May 18, 2016 and

included Bhasin, Campbell and five other women from around the company

as well as Abovitz and Gary Natsume, Vice President of Product Design and

a couple of m ale members of his team. Bhasin had not prepared an

agenda for the meeting and no one took notes. Natsume presented a

prototype of the device and its power supply, which was housed in a “belt

pack.” Women recommended changes to the design, such as not having

the headset connect in the back of the head because such a connection is

difficult for people with ponytails or long hair. The women also

recommended using a less stiff, lighter cable to connect the device to the

belt pack, because the existing one got caught in hair and jewelry. They

also recommended a new way to attach the “belt pack,” since women often

do not wear belts. A chaotic discussion with people talking over each other

followed. The group made no decisions and none of the proposed changes

were made to the design.

26. Bhasin planned to announce the formation of the group—albeit

without any goals or support—to the company December 22, but didn’t due

to the events described in paragraph 59 below. When planning the

announcement, Campbell suggested Abovitz or Vlietstra make the

announcement to give the impression that the group’s formation was an

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important event and not just a women’s “sewing circle.” Vlietstra did not

respond to Campbell’s request.

27. The FBI, far from being a company effort to support gender

diversity and inclusion, never had any charter, financial support or a true

leader. It was window dressing.

28. Later meetings did not include Abovitz or any of the other men,

but like the first, resulted in no recommendations and no clear path

forward.

And all the while, Magic Leap tolerated sexist comments and attitudes.

29. Campbell, in May 2015, presented several composited images

she had created to a group of people. One of the images depicted a male

and female doctor. One of the members in the group commented that the

male doctor looked like actor George Takei. Another male employee piped

in commenting, “Yeah, and look, it’s Bring Your Wife to Work Day.”

30. One of the only three or four core apps that will ship on Magic

Leap’s standard headset is a game, “Dr. G.,” that has no female heroes or

lead characters and the one female character, who is in the game back

story, but not the game itself, is a busty woman depicted on her knees

goveling at the heroes’ feet in admiration. During her tenure with Magic

Leap, Campbell complained repeatedly and to no avail to the game’s

developer that the game was misogynistic, and included the game in the

her gender diversity deck as an example of what Magic Leap was doing

wrong.

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31. Senior Engineer Eric Adams sent out an email December 4,

2015 through a company email list serv for social activities for Magic Leap

employees and their families, which email bore the subject line, “Board (sic)

Wives at home while you are loving it at the Leap,” which stated:

Hello Leapers:

My wife is starting a Google group outside of the MagicLeap
locked domain.

It is called “Magic Leap spouses” and should be findable as such.

https://groups.google.com/forum/#!forum/magic-leap-spouses

It is sort of a social meeting place for all the spouses that have
been displaced, alone in the daytime and are new to the area,
would like to have lunch with or just to have someone local to
hang out with when their significant other is slaving away at
work thru-out the 12-Hr day. Or are they just nagging you
because you moved here?

Please forward this Email to your wife if she would like to get
better acclimated to South Florida. The group is not public and
is reasonably private (by email invite/accept) as to not
accidentally disclose any Magic Leap secrets.

The gender-neutral reference to “spouses” notwithstanding, implicit in the

subject line and the reference to “your wife” is the assumption—which is not

too far from wrong—that all the employees were men with wives who didn’t

work outside the home and were “alone in the daytime.”

32. Euen Thompson, an IT Support Lead, on November 16, 2016,

gave a tutorial to a group of seven new hires, including two women, how to

use Magic Leap’s IT equipment and resources. One woman asked

Thompson a question in front of the group and Thompson responded, “Yeah,

women always have trouble with computers.” The women in the group, in

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apparent disbelief, asked Thompson to repeat what he said and Thompson

replied, “In IT we have a saying; stay away from the Three Os: Orientals,

Old People and Ovaries.”

33. A female direct report and a male peer told Campbell of the

comments and Campbell immediately went to then-Vice President of Human

Resources, Laura Langenhaug, told her what happened and that she

expected Thompson to be fired. Langenhaug said she would get back to

Campbell, but did not for over a week despite several follow-up calls and

emails.

34. Finally, approximately two weeks later, Laugenhaug’s boss,

Chief Administrative Officer Vlietstra spoke to Campbell and told her that he

understood what Thompson did was very offensive, but Thompson was both

humiliated and sorry and would not be allowed to do the new hire

orientation in the future. Campbell asked Vlietstra why Magic Leap hadn’t

fired Thompson and Vlietstra responded that he couldn’t fire Thompson

because he was African American and there were white men who had done

“far worse” and if Magic Leap fired Thompson, he could sue them because

he had been fired, but not the white guys. Campbell, outraged, asked,

“Why not fire them all?” Vlietstra answered: “Because we need the white

guys. They’re important. We need them. I know you’re upset, but my

hands are tied.”

35. Later, Thompson resumed giving new hire orientations.

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36. Jeremy Liebs, a male engineer in the Mountain View office, in

August, September and October 2016, constantly posted to Slack, a

company-wide messaging platform, comments that were aggressive and

critical toward Campbell and Devin Zimmerman, the woman who runs social

media for Magic Leap whom Campbell managed. Both Campbell and

Zimmerman complained in writing in September and October to Vlietstra,

who responded to Campbell, “We’re taking care of it,” but nothing was

done.

37. Campbell met September 28, 2016 with Magic Leap CFO Henry

and Head of Operations Tina Tuli for a conference call with the CFO and

leadership team at R/GA, an award-winning international advertising

agency that was Magic Leap’s advertising agency of record. During the call,

Henry said of the product under development, “I’m sitting here between two

beautiful ladies. They’re not going to want to put a big ugly device over

their pretty faces. And I have an office with glass doors, I don’t want people

to see me with these beautiful girls with ugly things on their faces.” Later,

one of the male R/GA executives on the call asked Campbell if Henry

frequently made sexist comments like he had made. A female executive at

R/GA also was offended by Henry’s remarks.

38. Just before the call with R/GA had started, Henry who had

printed an email from Tuli that had a photo icon with Tuli’s picture on it,

pointed to the picture and said in the presence of Campbell, “You know

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what I love most about all the emails you send me, Tina? I get to see your

beautiful smile smiling back at me.”

39. Vice President of IT Akerman, on November 8, 2016, told a

large group of people who asked why he voted for Trump that it was

“because Melania is hot.”

Magic Leap kept women in their place.

40. Women are not seen fit to manage men in any Magic Leap

department (hence their lack of number in leadership).

41. Women are not seen as capable of the engineering jobs closely

tied to Magic Leap’s product. Instead they are allocated to the “softer”

sciences like marketing, human resources and administrative roles.

42. Women were not seen as contributors to the design of the

product—the Product Design department is all male—and the FBI, which

gave feedback regarding the product, was ignored.

43. Women were not treated like part of the team, but rather were

absent from large lunch tables and happy hours of all men.

44. Women were not mentored by senior leadership, who spent

their valuable time with men.

45. Women even were told not to speak up in company meetings at

times, something Campbell never witnessed happen to men.

Magic Leap made Campbell a Vice President only after she asked
to be promoted.

46. Campbell met with Vlietstra at Campbell’s request on or about

September 20. Campbell never had had a formal evaluation. During the

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meeting, Vlietstra gave Campbell no negative feedback and told Campbell

more than once during the meeting, “We love you here and your work

speaks for itself.” Validated, Campbell asked for a raise and the title of Vice

President. She also told Vlietstra during the meeting that she still had

issues with leadership and decision making—that Abovitz was incapable of

making decisions, but rather kept putting things off pending more meetings

and assigning more people to solve the problem, which was one of the

primary reasons Magic Leap could not bring its product to market.

Campbell also told Vlietstra she continued to have issues with gender

diversity, in response to which Vlietstra told Campbell he was”working on it”

and offered to set up a meeting with Abovitz to discuss the promotion.

47. Campbell met with Abovitz on or about September 22, 2016.

Abovitz went over his 24-point description of the ideal “Leaper” (employee)

in an hour-long monologue. When time ran out, Campbell pointed out that

the purpose of the meeting was to discuss her future at Magic Leap and

Abovitz told her to set up another meeting.

48. At a the third meeting on or about September 27, which

Campbell, Abovitz and Vlietstra attended, Abovitz also asked Campbell how

things were going and she told him she had some “pain points” around the

product definition and decision making and still had problems with gender

diversity and inclusion issues. Abovitz asked her to elaborate on the gender

discrimination issue. In response, Campbell asked Abovitz to remember the

deck and how it was ignored. She also told Abovitz that misogyny comes

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on a sliding scale from “unconscious bias to malicious hate” and that she

had seen both at the company and everything in between.

49. As an example of more egregious comments, Campbell told

Abovitz of the “Three Os” incident and Vlietstra’s lack of any meaningful

discipline in response. As an example of unconscious bias, she told him of

an IT employee who was helping Campbell a new logo into the email

system. Cognizant that she was taking up a lot of the employee’s time with

minor changes to get the logo “perfect,” Campbell apologized for taking up

so much of the employee’s time, to which he responded, “Oh, don’t worry, I

get it. You’re a woman and you care that things look pretty. I’m a man. I

just get the work done.”

50. Abovitz demanded an explanation from Vlietstra why nothing

more had been done. Campbell could tell Vlietstra was furious with her for

bringing it up, and Vlietstra told Abovitz the two men needed to talk alone

about why the issue had not been resolved.

51. By the end of the third meeting, Campbell, Abovitz and Vlietstra

still had not talked about the promotion Campbell had requested. Campbell

tried to turn the conversation to the promotion, but Abovitz was non-

committal. He told her to follow-up with Vlietstra and that “we’ll figure this

out.” In the days that followed, Campbell followed up with Vlietstra two or

three times.

52. Finally, in early October, Vlietstra told Campbell the promotion

was “done.” But Magic Leap made no announcement either to her team or

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to the company as a whole. Campbell never was listed as an officer on the

website as were other male vice presidents. Only her title changed and she

received a small raise.

Magic Leap marginalized Campbell after her promotion.

53. During Campbell’s last four months at Magic Leap, Abovitz—who

always had been pouty and prone to temper-tantrums, began to dig his

heels in even more in the face of dissenting ideas and to explode ever more

frequently into child-like fits of rage, threatening retribution when he didn’t

get his way, felt betrayed or was portrayed publically in an unfavorable

light.

54. CFO Henry, on September 14, 2016, told Campbell he wanted

James Temple, creative partner at Magic Leap’s advertising agency of

record, R/GA, to join the agency team. Campbell told Henry this was not a

good idea because she already had established and trained the existing

agency team over the last nine months and they were doing excellent work

and because Temple lived in London.

55. Henry told Campbell she was being “emotional” and “sensitive”

and accused her of feeling “threatened.” Campbell denied feeling

threatened and explained her logical business reasons for not

accommodating his request. Henry disregarded Campbell’s position and

invited Temple to join the team anyway.

56. Abovitz and Bhasin, the Chief Business Officer who had never

met anyone from either agency and had no idea what value they provided,

Page 21 of 28
Case 0:17-cv-60327-WPD Document 1 Entered on FLSD Docket 02/13/2017 Page 22 of 28

in October 2016, fired both agencies Campbell relied upon to do her work:

R/GA and Pentagram. This left her powerless to execute her strategies and

plans.

57. Abovitz, in October, November and December, disinvited

Campbell to senior leadership meetings and told her she didn’t own the

brand and, instead, she needed to set up a “brand brain trust” consisting of

a male comic book artist, the male Vice President of Product Design and the

male Lead UX/UI.6

58. Abovitz, in mid-November 2016, directed Campbell to interview

people within the company about their opinions of the company and the

brand in the hope of gathering some themes that appealed to the inner

company. Campbell protested that they needed to build a brand for a

target audience that would buy the product, not the people in the building

(or Abovitz himself), but Abovitz insisted.

59. Campbell complied with Abovitz’s request and developed a

presentation of which she was very proud that she believed perfectly

balanced the target’s needs with those of Abovitz that she was due to

present on December 20. Instead, she was called into a meeting with

Vlietstra, General Counsel Albert, her newly hired boss, Brenda Freeman

and another woman from HR and told her position was being eliminated and

her employment was terminated.

6
UX is user experience. UI is user interface.

Page 22 of 28
Case 0:17-cv-60327-WPD Document 1 Entered on FLSD Docket 02/13/2017 Page 23 of 28

60. Magic Leap offered Campbell three-months severance if she

signed an agreement releasing all claims against the company. She

refused, turned in her computer and badge and left the building.

Magic Leap’s conscious and unconscious bias against women
created dysfunctionality in the workplace.

61. Due in large part to its gender imbalance and the misogynistic

attitudes and behavior of its male employees, including executive

management, Magic Leap’s corporate culture is one of macho bullying,

where women’s work and ideas, including those of Campbell, are ridiculed

openly and their opinions are ignored in favor of those of those of their

male counterparts.

62. The macho bullying atmosphere at Magic Leap fosters a

dysfunctional culture which creates chaos and lack of process and structure,

hinders the company from achieving key product deadlines (including

launch, which has shifted back at least 4 times in Campbell’s 1.5 years at

the company) and, literally, prevented Campbell from doing the job she was

hired to do or achieving the goals she and Abovitz had discussed during her

initial interview: helping with the “pink/blue problem” or making Magic

Leap less of a “boys club.”

63. Sadly, because Magic Leap seldom hires and does not actively

recruit female candidates, the company loses competitive advantage to

products like Microsoft’s Hololens. Microsoft, which employs far more

females on its team, developed its similar product on a faster time line with

more content that appeals to both genders.

Page 23 of 28
Case 0:17-cv-60327-WPD Document 1 Entered on FLSD Docket 02/13/2017 Page 24 of 28

Count I: Hostile Environment Sex Discrimination
in Violation of Title VII

64. Plaintiff realleges and adopts, as if fully set forth in this Count,

all of the allegations in paragraphs 1 through 63.

65. Magic Leap, through its CEO Abovitz and other highly placed

executive officers of the company, caused or allowed the conditions and

conduct described in paragraphs 12, 13, 16, 21, 22 and 25-63, which

evidenced that:

a. women were not welcome in the Magic Leap workplace;

b. women had limited opportunities to advance in the Magic

Leap workplace;

c. women’s ideas and contributions were not valued in the

Magic Leap workplace; and

d. women were not viewed as having the skills critical to the

tech world because they were stereotyped as wives, homemakers, sex

objects and adorers of men in the Magic Leap workplace.

66. The conditions and conduct referred to in paragraphs 12, 13, 16,

21, 22 and 25-60 were both subjectively and objectively offensive, and

were sufficiently severe or sufficiently pervasive, or both, to create a

discriminatorily abusive work environment that affected plaintiff in the

“compensation, terms, conditions and privileges of employment” as

envisioned by 42 U.S.C. § 2000e-1(a)(1), including as more particularly

described in paragraphs 46 through 52, 53 through 60, 61 and 62, and

violated plaintiff’s rights under Title VII of the Civil Rights Act of 1964.

Page 24 of 28
Case 0:17-cv-60327-WPD Document 1 Entered on FLSD Docket 02/13/2017 Page 25 of 28

67. Campbell’s gender was the substantial, motivating factor in the

treatment of Campbell and other women in the Magic Leap workplace.

68. As a direct, natural, proximate and foreseeable result of the

actions of Magic Leap, Campbell has suffered past and future pecuniary

losses, emotional pain, suffering, inconvenience, mental anguish, loss of

enjoyment of life, and other non-pecuniary losses.

69. Magic Leap’s upper management, including its CEO, Abovitz,

was aware both that discrimination based on sex is against the law and of

the gender-based hostility that women who worked there suffered and

countenanced or approved it. Magic Leap’s intentional and purposeful acts

of creating and sustaining an environment so hostile to women exhibits

oppression, malice, gross negligence, willful or wanton misconduct,

or a reckless disregard for Campbell’s rights so as to entitle her to an

award of punitive damages against Magic Leap to punish it for its conduct

and to deter others like it from such conduct in the future.

70. The sex discrimination that Campbell is suffering, in violation of

the statutory rights to be free from such discrimination, constitutes

irreparable harm for which there is no adequate remedy at law.

71. Campbell is entitled to recover reasonable attorneys’ fees and

litigation expenses pursuant to 42 U.S.C. § 2000e-5(k) for her Title VII

claims.

WHEREFORE, plaintiff, Tannen Campbell, prays that this Court will:

Page 25 of 28
Case 0:17-cv-60327-WPD Document 1 Entered on FLSD Docket 02/13/2017 Page 26 of 28

One, issue a declaratory judgment that Magic Leap’s practices toward

Campbell violated Campbell’s rights against sex discrimination under Title

VII;

Two, enjoin Magic Leap and its agents from continuing to violate

Campbell’s statutory rights under Title VII and to make Campbell whole

through reinstatement, back pay and restoration of seniority and benefits;

Three, enter a judgment for Campbell and against Magic Leap for

damages, including punitive damages;

Four, grant Campbell her costs and reasonable attorney’s fees

pursuant to 42 U.S.C. § 2000e-5(k); and

Five, grant Campbell such other and further relief as the

circumstances and law provide.

Count II:
Opposition-Clause Retaliation in Violation of Title VII

72. Plaintiff realleges and adopts, as if fully set forth in this Count,

all of the allegations in paragraphs 1 through 63 and 65 through 67.

73. Campbell reasonably believed that the conditions and conduct

she encountered at Magic Leap and about which she complained to Abovitz

and others as alleged in paragraphs 15 through 22, 30, 33, 34, 36, 46, 48

and 49 above, constituted unlawful employment practices under Title VII.

74. Magic Leap terminated Campbell because of her protected

activity in opposing unlawful sex discrimination.

75. The actions of Magic Leap violated § 2000e-3(a) of Title VII of

the Civil Rights Act of 1964.

Page 26 of 28
Case 0:17-cv-60327-WPD Document 1 Entered on FLSD Docket 02/13/2017 Page 27 of 28

76. As a direct, natural, proximate and foreseeable result of the

actions of Magic Leap, Campbell has suffered past and future pecuniary

losses, emotional pain, suffering, inconvenience, mental anguish, loss of

enjoyment of life, and other non-pecuniary losses.

77. Magic Leap’s upper management, including its CEO, Abovitz,

was aware retaliation for opposing illegal gender discrimination is against

the law and countenanced or approved it. Magic Leap’s intentional and

purposeful acts of terminating Campbell exhibits oppression, malice, gross

negligence, willful or wanton misconduct, or a reckless disregard for

Campbell’s rights so as to entitle her to an award of punitive damages

against Magic Leap to punish it for its conduct and to deter others like it

from such conduct in the future.

78. The retaliatory discrimination that Campbell is suffering, in

violation of the statutory rights to be free from such discrimination,

constitutes irreparable harm for which there is no adequate remedy at law.

79. Campbell is entitled to recover reasonable attorneys’ fees and

litigation expenses pursuant to 42 U.S.C. § 2000e-5(k) for her Title VII

claims.

WHEREFORE, plaintiff, Tannen Campbell, prays that this Court will:

One, issue a declaratory judgment that Magic Leap’s practices toward

Campbell violated Campbell’s rights against retaliation under Title VII;

Page 27 of 28
Case 0:17-cv-60327-WPD Document 1 Entered on FLSD Docket 02/13/2017 Page 28 of 28

Two, enjoin Magic Leap and its agents from continuing to violate

Campbell’s statutory rights under Title VII and to make Campbell whole

through reinstatement, back pay and restoration of seniority and benefits;

Three, enter a judgment for Campbell and against Magic Leap for

damages, including punitive damages;

Four, grant Campbell her costs and reasonable attorney’s fees

pursuant to 42 U.S.C. § 2000e-5(k); and

Five, grant Campbell such other and further relief as the

circumstances and law provide.

Respectfully Submitted,

/s/ Karen Coolman Amlong
KAREN COOLMAN AMLONG
Florida Bar Number 275565
KAmlong@TheAmlongFirm.com
WILLIAM R. AMLONG
Florida Bar Number 470228
WRAmlong@TheAmlongFirm.com
AMLONG & AMLONG, P.A.
500 Northeast Fourth Street
Fort Lauderdale, Florida 33301-1154
Phone: (954) 462-1983
Fax: (954)523-3192

Attorneys for Plaintiff

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Page 28 of 28
Case 0:17-cv-60327-WPD Document
JS 44 (Rev. 07/16) FLSD Revised 07/01/2016 1-1 COVER
CIVIL EnteredSHEET
on FLSD Docket 02/13/2017 Page 1 of 2
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose
of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.
I. (a) PLAINTIFFS TANNEN CAMPBELL DEFENDANTS MAGIC LEAP, INC., a Florida Corporation

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Amlong & Amlong, P.A.,
500 NE 4th Street, Fort Lauderdale, Florida 33301
(d) Check County Where Action Arose: MIAMI- DADE MONROE BROWARD PALM BEACH MARTIN ST. LUCIE INDIAN RIVER OKEECHOBEE HIGHLANDS

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff)
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6
Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729 (a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 840 Trademark 460 Deportation
Student Loans 340 Marine Injury Product 470 Racketeer Influenced and
(Excl. Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) 490 Cable/Sat TV
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Mgmt. Relations 863 DIWC/DIWW (405(g)) 850 Securities/Commodities/
190 Other Contract Product Liability 380 Other Personal 740 Railway Labor Act 864 SSID Title XVI Exchange
195 Contract Product Liability 360 Other Personal Property Damage 751 Family and Medical 865 RSI (405(g)) 890 Other Statutory Actions
196 Franchise Injury 385 Property Damage Leave Act 891 Agricultural Acts
362 Personal Injury - Product Liability 790 Other Labor Litigation 893 Environmental Matters
Med. Malpractice 791 Empl. Ret. Inc. 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS Security Act FEDERAL TAX SUITS Act
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 870 Taxes (U.S. Plaintiff 896 Arbitration
220 Foreclosure 441 Voting 463 Alien Detainee or Defendant) 899 Administrative Procedure
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRS—Third Party 26 Act/Review or Appeal of
Sentence USC 7609
240 Torts to Land 443 Housing/ Other: Agency Decision
Accommodations
245 Tort Product Liability 445 Amer. w/Disabilities - 530 General IMMIGRATION 950 Constitutionality of State
Statutes
290 All Other Real Property Employment 535 Death Penalty 462 Naturalization Application
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee –
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
1 Original 2 Removed 3 Re-filed 4 Reinstated 5 Transferred from 6 Multidistrict 7 Appeal to Remanded from
9 Appellate
8 Multidistrict Court
Proceeding from State (See VI or another district Litigation
(specify) Transfer District Judge Litigation
Court below) Reopened
from Magistrate – Direct
Judgment File

VI. RELATED/ (See instructions): a) Re-filed Case YES NO b) Related Cases YES NO
RE-FILED CASE(S) JUDGE: DOCKET NUMBER:
Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):
VII. CAUSE OF ACTION Title VII of the Civil Rights Act of 1964. Hostile environment sex discrimination and retaliation
retaliation
LENGTH OF TRIAL via 5 days estimated (for both sides to try entire case)
VIII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION
CHECK YES only if demanded in complaint:
DEMAND $
COMPLAINT: UNDER F.R.C.P. 23
JURY DEMAND: Yes No
ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE
DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY
RECEIPT # AMOUNT IFP JUDGE MAG JUDGE

Save As... Print Reset
Case 0:17-cv-60327-WPD Document 1-1 Entered on FLSD Docket 02/13/2017 Page 2 of 2
JS 44 (Rev. 07/16) FLSD Revised 07/01/2016

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I. (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the
official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the “defendant” is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment,
noting in this section “(see attachment)”.
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an “X” in
one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an “X” in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the
Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and
box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship of
the different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an “X” in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerks in the Administrative Office to determine the nature of suit. If the cause fits more than one nature
of suit, select the most definitive.
V. Origin. Place an “X” in one of the seven boxes.
Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the
petition for removal is granted, check this box.
Refiled (3) Attach copy of Order for Dismissal of Previous case. Also complete VI.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict
litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When this
box is checked, do not check (5) above.
Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judge’s decision.
Remanded from Appellate Court. (8) Check this box if remanded from Appellate Court.
VI. Related/Refiled Cases. This section of the JS 44 is used to reference related pending cases or re-filed cases. Insert the docket numbers and the
corresponding judges name for such cases.

VII. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553
Brief Description: Unauthorized reception of cable service
VIII. Requested in Complaint. Class Action. Place an “X” in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

Date and Attorney Signature. Date and sign the civil cover sheet.
Case 0:17-cv-60327-WPD Document 1-2 Entered on FLSD Docket 02/13/2017 Page 1 of 2

United States District Court
SOUTHERN DISTRICT OF FLORIDA

CASE NUMBER:

TANNEN CAMPBELL, SUMMONS IN A CIVIL
Plaintiff,
ACTION

vs.

MAGIC LEAP, INC., a Florida
corporation,

Defendant.
/

TO: Magic Leap, Inc., a Florida corporation
By Serving It’s Registered Agent: Paracorp Incorporated
155 Office Plaza Drive
1st Floor
Tallahassee, Florida 32301

YOU ARE HEREBY SUMMONED and required to file with the Clerk of this Court and

serve upon Plaintiff’s Attorney:

Karen Coolman Amlong, Attorney at Law
Kamlong@TheAmlongFirm.com
AMLONG & AMLONG, P.A.
500 Northeast Fourth Street, Second Floor
Fort Lauderdale, Florida 33301
(954) 462-1983

an answer to the Complaint which is herewith served upon you, within Twenty One (21)
days after service of this Summons upon you, exclusive of the day of service. If you fail
to do so, judgment by default will be taken against you for the relief demanded in the
Complaint. You must also file your answers with the Clerk of the Court within a reasonable
period of time after service.

You are further served with the following:

??????????

CLERK DATE

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Case 0:17-cv-60327-WPD Document 1-2 Entered on FLSD Docket 02/13/2017 Page 2 of 2

By DEPUTY CLERK

RETURN OF SERVICE
Service of the Summons and Complaint was made Date
by me.

Name of Server (Print) Title

Check one box below to indicate appropriate method of service

 Served personally upon the Defendant. Place where served:

 Left copies thereof at the Defendant’s dwelling house or usual place of abode with a
person of suitable age and discretion then residing therein: Name of person with
whom the Summons and Complaint were left:
 Returned unexecuted:

 Other (Specify):

STATEMENT OF SERVICE FEES
TRAVEL SERVICES TOTAL

DECLARATION OF SERVER

I declare under penalty of perjury under the laws of the United State of America that the
foregoing information contained in the Return of Service and Statement of Fees is true and correct.

Executed on
Signature of Server Date

Address of Server

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