UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

DASSCHINKA STORANI,
CASE NO.:
Plaintiff,
v.
ARNSTEIN & LEHR LLP, a
limited liability partnership,
Defendant.
/
COMPLAINT
Plaintiff, Dasschinka Storani (Mrs. Storani or Plaintiff), by and through her
undersigned counsel, sues Defendant, Arnstein & Lehr, a limited liability partnership (the Firm
or Defendant) and in support thereof states the following:
NATURE OF THE CLAIMS, JURISDICTION, AND VENUE
1.

This is an action for monetary damages pursuant to Title VII of the Civil Rights

Act of 1964, as amended by the Civil Rights Act of 1991, 42 U.S.C. 2000 et seq. (hereinafter
Title VII); the Florida Civil Rights Act, Fla. Stat. 760.01, et seq. (hereinafter FCRA); and
the Florida Whistleblower Act, Fla. Stat. 448.101, et seq. (hereinafter Whistleblower Act).
2.

Plaintiff invokes the federal question and civil rights jurisdiction of this Court

pursuant to 28 U.S.C. 1331 and 1343(a)(4). Plaintiff also invokes this Courts supplemental
jurisdiction over her state law claims which arise from the same nucleus of operative facts as the
federal claims alleged herein pursuant to 28 U.S.C. 1367(a).
3.

Venue for this action lies in the Southern District of Florida pursuant to 28 U.S.C.

1391(b) and the actions upon which the matter are based took place in Broward County.

PROCEDURAL BACKGROUND
4.

Plaintiff has complied with all conditions precedent to filing this action by timely

filing charges of discrimination and retaliation based on sex against Defendant with the Equal
Employment Opportunity Commission (EEOC) on November 27, 2013, a copy of which is
attached hereto as EXHIBIT A and made a part hereof.
5.

Plaintiff received Notice of Right to Sue from the EEOC as to Defendant, dated

September 26, 2014, a copy of which is attached hereto as EXHIBIT B.

6.

Plaintiff timely files this Complaint within ninety (90) days of receipt of her Notice

of Right to Sue.
PARTIES
7.

Mrs. Storani is a resident of Broward County, Florida at all times pertinent hereto,

is over the age of eighteen (18) and otherwise sui juris.

8.

The Firm is a limited liability partnership organized under the laws of Illinois and

authorized to do business in the state of Florida.

9.

The Firms principal place of business is located at 120 S. Riverside Plaza, Suite

1200, Chicago, IL 60606.

10.

The Firm has several Florida offices with its main office and registered agent

located at 200 S. Biscayne Blvd., Suite 3600, Miami, FL 33131.

11.

Mrs. Storani worked in the Firms Fort Lauderdale Office currently located at 200

E. Las Olas Blvd., Suite 1000, Fort Lauderdale, FL 33301.

12.

At all times pertinent hereto the Firm was and still is engaged in an industry

affecting commerce with more than fifteen employees and is an employer as defined by Title VII,
FCRA, and the Whistleblower Act.

13.

At all times pertinent hereto Mrs. Storani was an employee of the Firm and was an

employee as defined by Title VII and the Whistleblower Act.

14.

Mrs. Storani is also an aggrieved person as defined by the FCRA.

FEDERAL LAWS AND REGULATIONS

15.

Under Title VII, it is unlawful for an employer to discriminate against an employee

based on the employees sex. 42 U.S.C. 2000e-2.

16.

Additionally, under Title VII, it is also unlawful to harass an employee via

unwelcomed verbal conduct of a sexual nature that creates an intimidating, hostile, or offensive
working environment. Id.; 29 C.F.R. 1604.11.
17.

Under Title VII, it is unlawful for an employer to discriminate against an employee

for opposing any practice made unlawful by Title VII. 42 U.S.C. 2000e-3.
FLORIDA LAWS AND REGULATIONS
18.

Under the FCRA, it is unlawful for an employer to discriminate against any

employee based on the employees sex. Fla. Stat. 760.10(1).

19.

Under the FCRA, it is also unlawful for an employer to discriminate against any

employee for opposing any practice that is made unlawful by the FCRA. Fla. Stat. 760.10(7).
20.

In Florida, it is unlawful and criminal to commit theft. Fla. Stat. 812.014.

21.

In Florida, it is unlawful and criminal to solicit payments for services not

performed. Fla. Stat. 817.061.

22.

In Florida, it is unlawful to collect proceeds with criminal intent or to collect

unlawful debt. Fla. Stat. 772.103.

GENERAL FACTUAL ALLEGATIONS COMMON TO ALL COUNTS

23.

Mrs. Storani began working at the Firms Fort Lauderdale Office through a staffing

agency in August 2008 and was officially hired in October 2008.

24.

Mrs. Storani was the legal secretary to the Fort Lauderdales Office Managing

Partner, Alan G. Kipnis (Mr. Kipnis).

25.

Throughout her employment with the Firm, Mrs. Storani worked for Mr. Kipnis up

until approximately three (3) months prior to her termination.

26.

Mrs. Storani worked without incident, receiving the highest ratings available on

every annual performance evaluation, which also resulted in the highest amount of monetary
increases and bonuses permitted by the Firm at the insistence of Mr. Kipnis.
27.

There were several times during Mrs. Storanis employ that she also worked as the

Acting/Interim Office Administrator for the Fort Lauderdale Office at the request of both Mr.
Kipnis and the Firm.
28.

It was common practice for Mr. Kipnis to run Office Administrators out of their job

when the Office Administrators, in an attempt to properly and effectively perform their job duties,
started questioning the hours worked by Mr. Kipnis daughters or Mr. Kipnis work related
spending habits.
29.

The only staff member that could handle Mr. Kipnis was Mrs. Storani, despite his

constant vulgarity, profanity, and abusive behavior.

30.

Mr. Kipnis abused Mrs. Storanis willingness to go above and beyond for the Firm

and required her to be available and accessible to assist him twenty-four (24) hours a day, seven
(7) days a week, three-hundred sixty five (365) days a year.

31.

In the event Mrs. Storani did not respond to messages, including both e-mails and

texts, sent in the middle of the night, Mr. Kipnis would set out the next morning to try and get Mrs.
Storani terminated by contacting Jeffrey Shapiro, the head of all Florida offices (Mr. Shapiro)1,
Ed OConnell, Chief Operating Officer (Mr. OConnell) and Todd Theobald, Head of the
Human Resources Department (Mr. Theobald).
32.

Because Mr. Kipnis was so particular about Mrs. Storani being able to work around

the clock and to be at his beacon call, he granted her remote access to the office computers via a
software program called Citrix that is generally reserved for attorneys and staff that billed their
hours out to clients.
33.

Mr. Kipnis was very demanding and controlling and preferred that Mrs. Storani be

at the office very early in the morning at approximately 7:00 a.m., when he arrived, despite the
fact that the Firms office hours were 8:30 a.m. to 5:00 p.m.
34.

At one point in time, after receiving permission from Mr. Kipnis, Mrs. Storani

attempted to switch her hours to more regular working hours of 8:30 a.m. to 4:30 p.m. so she could
take her daughter to and from pre-school.
35.

Despite his approval, these times did not work for Mr. Kipnis, and he made

additional efforts to have Mrs. Storani terminated for attempting to work these new hours.
36.

Due to Mr. Kipnis preference, Mrs. Storani was unable to take her daughter to

school and had to go back to her original hours.

37.

Mr. Kipnis was often inappropriate in what he said to the female staff, including

Mrs. Storani.

Mr. Shapiro has since been promoted to Chairman of the entire Firm.
5

38.

Mr. Kipnis often spoke about his sex life to Mrs. Storani, often saying things to her

like, Your husband is a lucky guy. I bet you still give him blowjobs. My wife wont give me
blowjobs anymore.
39.

Mr. Kipnis also said the following to Mrs. Storani on a continuous basis:
a. If I was 30 years younger, what I would do to you.
b. You would be a perfect wife.
c. You could be my wife.
d. Ill know when I lost enough weight when I can see my penis.

40.

Mr. Kipnis had Mrs. Storani inject him in the buttocks with vitamin B-12 after an

alleged medical event because he could not do it himself and his own wife allegedly refused.
41.

When Mrs. Storani would pick up Mr. Kipnis dry cleaning he would say this is

the only way our clothes will touch or be mixed together.

42.

Mr. Kipnis invited Mrs. Storani to travel on a cruise with his family. When Mrs.

Storani asked if her husband could also come, Mr. Kipnis responded affirmatively. He then
immediately sent his daughter, Lauren Kipnis, to rescind the offer to travel on the cruise with his
family because he did not want Mrs. Storanis husband to travel with them.
43.

Mr. Kipnis also enjoyed speaking to Mrs. Storani about the sex life of another law

firm partner, specifically, how that partner could not perform sexually and fathered the most recent
child had by this other partners secretary.
44.

In an effort to add credibility to the story how this other partner fathered the

secretarys most recent child, Mr. Kipnis would tell Mrs. Storani that the secretary would attend
business trips with the other partner and that Mrs. Storani could accompany Mr. Kipnis on
similar trips.

45.

Mrs. Storani also heard a variety of other sexually lewd comments made to other

female staff and/or about female staff.

46.

Mr. Kipnis directed Mrs. Storani to invite an attractive secretary on a cruise with

Mr. Kipnis family so Mr. Kipnis son could have sex with the attractive secretary.
47.

Mr. Kipnis preferred that the staff be young and attractive and made this fact known

to Mrs. Storani for her to remember each time she was the Acting Office Administrator and
responsible for staff interviews.
48.

The Firm was aware of Mr. Kipnis abusive behavior and did nothing to control it

or eliminate it, upon information and belief, because of Mr. Kipnis significant book of business
comprised of banking and finance industry clients.
49.

On or about March 2013, one secretary, Lanette Fidone, was constructively

discharged after she could not take any more abuse and wrote a letter to the Firm immediately after
her departure, alleging sexual harassment, nepotism, mental abuse, fraud, and theft, amongst other
things, by Mr. Kipnis.
50.

In or around mid-April 2013, in response to the allegations in Fidones letter, Ray

Werner, chairman of the Firm (Mr. Werner)2, hired outside counsel and investigators to
investigate the allegations of Mrs. Fidone.
51.

Mr. Werner came down from the Chicago office of the Firm to the Fort Lauderdale

office of the Firm to speak to the staff and attorneys about the impending investigation.
52.

Mr. Werner informed everyone that an investigation was being conducted and that

if anyone was selected to be interviewed, the selected persons were to answer any and all questions
honestly and to tell the investigators and lawyers what they knew.

Mr. Werner has since retired on or about September 30, 2014.

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53.

Prior to Mr. Werner coming to the Fort Lauderdale office, Mrs. Storani feared

speaking out against Mr. Kipnis because she knew that it would result in her imminent termination
based upon the numerous past terminations spearheaded by Mr. Kipnis.
54.

Given the fact that Mr. Werner was the head of the Firm and higher up the chain of

command than Mr. Kipnis, Mrs. Storani mistakenly believed it was safe to speak truthfully to the
investigators and honestly participate in the investigation, even if said truths were against Mr.
Kipnis, believing the Firm would take corrective action.
55.

Mrs. Storani was able to corroborate the allegations in Mrs. Fidones letter by

providing evidence to the investigators, which included but was not limited to, that facts that Mr.
Kipnis stole from the Firm and his clients via fraudulent receipts and billing entries, that Mr. Kipnis
was verbally abusive, that Mr. Kipnis was sexually inappropriate around the staff, and that Mr.
Kipnis gave special treatment to his daughters.
56.

For approximately six (6) weeks until the end of May, Mrs. Storani complied with

continuous requests of Mr. Werner on a daily basis wherein she was requested to provide additional
evidence of the fraudulent practices of Mr. Kipnis.
57.

During the investigation, Mr. Kipnis was removed from the Fort Lauderdale office

of the Firm and relocated to the Miami office of the Firm to allegedly foster honest discussions
about the allegations in Mrs. Fidones letter, without staff and employees of the Firm fearing
intimidation by Mr. Kipnis.
58.

Despite the removal of Mr. Kipnis, Mrs. Storani had to deal with Mr. Kipnis

daughters every single day wherein they intimidated and harassed Mrs. Storani on behalf of their
father in an attempt to get Mrs. Storani to lie for Mr. Kipnis in order to protect Mr. Kipnis from
any repercussions.

59.

One daughter, Lisa Kipnis, went so far as to threaten the life of Mrs. Storani, in

writing: Im going to say one more thing about all of this and you won't hear a word from me
about it ever again. Dacha if I find out you ever do or say anything that hurts my father and family
to save yourself or help lanette I will do everything i can to destroy and I will make it my personal
job. Just FYI.
60.

Upon information and belief, the real reason Mr. Kipnis was in Miami was so Mr.

Werner could bring in a new group of attorneys with a substantial book of business, that otherwise
would not have been possible with Mr. Kipnis in Fort Lauderdale.
61.

Upon learning that the head of the new attorney group, was given Mr. Kipnis old

office, Mr. Kipnis proclaimed to Mrs. Storani that he had felt like he had been evicted from Fort
Lauderdale.
62.

Mrs. Storani began working for the new group of attorneys, aiding with their

transition into the Firm because the Office Administrator, Sandra Borriello (Ms. Borriello), was
often absent. The new group of attorneys, the Firm and Ms. Borriello relied upon Mrs. Storani to
help Ms. Borriello do her job in Fort Lauderdale.
63.

One of the new Fort Lauderdale attorneys, said that Mrs. Storani was instrumental

to his group and advised that he would like to keep her as a member of his group.
64.

Mr. Kipnis could not allow Mrs. Storani to stay in Fort Lauderdale while he had

been evicted from same and put an immediate stop to that, upon information and belief through
the powers of Mr. Shapiro, Mr. Kipnis best friend.
65.

Prior to the investigation, and as early as January 2014, the Firm began a

comparative analysis of certain staff members garage keycard swipe times compared against their

clock in times with ADP, the payroll administrator website that could only be accessed on the
computer.
66.

Once Mr. Werner was finished obtaining all the information he needed from Mrs.

Storani about Mr. Kipnis for his internal investigation to keep Mr. Kipnis in Miami and keep Mr.
Kipnis book of business with the Firm, in an effort to appease Mr. Kipnis, Mrs. Storani was
targeted for alleged stolen time.
67.

Although the comparative analysis covered several staff members, including, but

not limited to, Mr. Kipnis daughters and Mrs. Fidone, Mrs. Storani was the only one targeted for
same in retaliation for participating in the internal investigation at the behest of the chairman of
the Firm.
68.

On July 3, 2014, one day prior to her pre-planned family vacation, her first in

approximately five (5) years, Mrs. Storani was called into the office of Ms. Borriello along with
Richard Ivans, the Acting Fort Lauderdale Managing Partner, and Mrs. Storani was told that she
was being investigated for allegedly stealing time and would have to answer to their findings upon
her return.
69.

When Mrs. Storani returned from her vacation, Mrs. Storani was given the analysis

that covered the period of January 1, 2012 through May 15, 2013. The Firm reached an
unsupported and absurd position that Mrs. Storani owed the Firm approximately twenty seven
thousand dollars ($27,000.00) in alleged stolen time.
70.

Apparently, after paying Mrs. Storani for the time, waiting an additional nine (9)

weeks from the last day analyzed to present Mrs. Storani with the Firms findings, the Firm
expected Mrs. Storani to remember, without access to her records at the office, each day she ever

10

worked in those approximately eighteen (18) months to justify alleged discrepancies or repay the
Firm twenty seven thousand dollars ($27,000.00) in order to save her job.
71.

Not one time, until after the Firm was done using Mrs. Storani for the Firms own

agenda, was the alleged stolen time ever addressed with Mrs. Storani.
72.

Mrs. Storani explained to the Firm that even if there was an alleged discrepancy,

she worked via remote access granted to her by the Firm and Mr. Kipnis pursuant to Mr. Kipnis
instructions and demands.
73.

The Firm did not find that explanation adequate, despite it being truthful.

74.

The Firm also requested Mrs. Storani return documentation already supplied to Mr.

Werner during the investigation so she had nothing more to return to the Firm as the Firm had
everything.
75.

The Firm terminated Mrs. Storanis employment with the Firm August 14, 2013

via a letter sent Federal Express to her home for not allegedly not complying with the Firms
demands when, in fact, Mrs. Storani had already complied.
76.

Mr. Kipnis is still a partner of the Firm in the Miami office.

77.

All conditions precedent have been met prior to the filing of this action.
COUNT IVIOLATION OF TITLE VII 42 U.S.C. 2000e-2(a)

78.

Plaintiff repeats and realleges the allegations set forth above in paragraphs 1

through 17 and 23 through 77 as if specifically set forth herein.

79.

Prior to the filing of this action, the Firm, through its agents, violated Plaintiffs

rights under Title VII of the Civil Rights Act of 1964, as amended.
80.

Plaintiffs sex was a substantial and motivating factor in the conduct alleged above

in 28-48.

11

81.

The conduct by Defendant discriminated against Plaintiff with respect to

compensation, terms, conditions or privileges of employment because of Plaintiffs sex.

82.

The sexual discriminatory conduct of Defendant and its agents proximately,

directly and foreseeable caused Plaintiff damages, including but not limited to, emotional pain and
suffering, inconvenience, mental anguish, loss of enjoyment of life, loss of reputation, and other
non-pecuniary losses.
83.

Plaintiff is entitled to recover attorneys fees and costs under 42 U.S.C. 2000e-

5(k).
WHEREFORE, Plaintiff, Dasschinka Storani, respectfully requests this Court grant
judgment in her favor:
(a) awarding judgment against Defendant for front pay in lieu of reinstatement;
(b) awarding judgment against Defendant for compensatory damages;
(c) awarding judgment against Defendant for punitive damages;
(d) awarding Plaintiff reasonable attorneys fees and costs; and
(e) for all other and further relief this Court deem just and proper.
COUNT IIVIOLATION OF TITLE VII 42 U.S.C. 2000e-3(a)
84.

Plaintiff repeats and realleges the allegations set forth above in paragraphs 1

through 17 and 23 through 77 as if specifically set forth herein.

85.

Plaintiff engaged in a protected activity by opposing the sexual harassment and

hostile work environment created and perpetuated by Defendant and its agents.
86.

Plaintiffs protected activity was a substantial and motivating factor in Defendants

decision to terminate Plaintiffs employment.

87.

The conduct of Defendant discriminated against Plaintiff with respect to

12

compensation, terms, conditions, or privileges of employment because of Plaintiffs protected

activity.
88.

The retaliatory conduct of Defendant and its agents proximately, directly and

foreseeably caused Plaintiff damages, including but not limited to, emotional pain and suffering,
inconvenience, mental anguish, loss of enjoyment of life, loss of reputation, and other nonpecuniary losses.
89.

Plaintiff is entitled to recover attorneys fees and costs under 42 U.S.C. 2000e-

5(k).
WHEREFORE, Plaintiff, Dasschinka Storani, respectfully requests this Court grant
judgment in her favor:
(a) awarding judgment against Defendant for the back pay and benefits to which
Plaintiff would have been entitled but for Defendants retaliatory acts;
(b) awarding judgment against Defendant for front pay in lieu of reinstatement;
(c) awarding judgment against Defendant for compensatory damages;
(d) awarding judgment against Defendant for punitive damages;
(e) awarding Plaintiff reasonable attorneys fees and costs; and
(f) for all other and further relief this Court deem just and proper.

COUNT IIIVIOLATION OF FCRA FLA. STAT. 760.10 (1)

90.

Plaintiff repeats and realleges the allegations set forth above in paragraphs 1

through 14, 18, 19, and 23 through 77 as if specifically set forth herein.
91.

Prior to the filing of this action, the Firm, through its agents, violated Plaintiffs

rights under the Florida Civil Rights Act.

13

92.

Plaintiffs sex was a substantial and motivating factor in the conduct alleged above

in 28-48.
93.

The conduct by Defendant discriminated against Plaintiff with respect to

compensation, terms, conditions or privileges of employment because of Plaintiffs sex.

94.

The sexual discriminatory conduct of Defendant and its agents proximately,

directly and foreseeable caused Plaintiff damages, including but not limited to, emotional pain and
suffering, inconvenience, mental anguish, loss of enjoyment of life, loss of reputation, and other
non-pecuniary losses.
95.

Plaintiff is entitled to recover attorneys fees and costs under Fla. Stat. 760.11(5).

WHEREFORE, Plaintiff, Dasschinka Storani, respectfully requests this Court grant

judgment in her favor:
(a) awarding judgment against Defendant for front pay in lieu of reinstatement;
(b) awarding judgment against Defendant for compensatory damages;
(c) awarding judgment against Defendant for punitive damages;
(d) awarding Plaintiff reasonable attorneys fees and costs; and
(e) for all other and further relief this Court deem just and proper.
COUNT IVVIOLATION OF FCRA FLA. STAT. 760.10 (7)
96.

Plaintiff repeats and realleges the allegations set forth above in paragraphs 1

through 14, 18, 19, and 23 through 77 as if specifically set forth herein.
97.

Plaintiff engaged in a protected activity by opposing the sexual harassment and

hostile work environment created and perpetuated by Defendant and its agents.
98.

Plaintiffs protected activity was the substantial and motivating factor in Firms

decision to terminate Plaintiffs employment.

14

99.

The conduct of Defendant discriminated against Plaintiff with respect to

compensation, terms, conditions, or privileges of employment because of Plaintiffs protected

activity.
100.

The retaliatory conduct of Defendant and its agents proximately, directly and

foreseeable caused Plaintiff damages, including but not limited to, emotional pain and suffering,
inconvenience, mental anguish, loss of enjoyment of life, loss of reputation, and other nonpecuniary losses.
101.

Plaintiff is entitled to recover attorneys fees and costs under Fla. Stat. 760.11(5).

WHEREFORE, Plaintiff, Dasschinka Storani, respectfully requests this Court grant

judgment in her favor:
(a) awarding judgment against Defendant for the back pay and benefits to which
Plaintiff would have been entitled but for Defendants retaliatory acts;
(b) awarding judgment against Defendant for front pay in lieu of reinstatement;
(c) awarding judgment against Defendant for compensatory damages;
(d) awarding judgment against Defendant for punitive damages;
(e) awarding Plaintiff reasonable attorneys fees and costs; and
(f) for all other and further relief this Court deem just and proper.
COUNT VVIOLATION OF FLA. STAT. 448.102(2)
102.

Plaintiff repeats and realleges the allegations set forth above in paragraphs 1

through 77 as if specifically set forth herein.

103.

Defendant violated the Whistleblower Act by terminating Plaintiff for participating

in an internal investigation at the behest of the Chairman of the Firm.

104.

Defendant acted intentionally, with malice and reckless disregard for Plaintiffs

15

rights under the Whistleblower Act.

WHEREFORE, Plaintiff, Dasschinka Storani, respectfully requests this Court grant
judgment in her favor:
(a) awarding judgment against Defendant for the back pay and benefits to which
Plaintiff would have been entitled but for Defendants retaliatory acts;
(b) awarding judgment against Defendant for front pay in lieu of reinstatement;
(c) awarding judgment against Defendant for compensatory damages;
(d) awarding judgment against Defendant for punitive damages;
(e) awarding Plaintiff reasonable attorneys fees and costs; and
(f) for all other and further relief this Court deem just and proper.
COUNT VIVIOLATION OF FLA. STAT. 448.102(3)
97.

Plaintiff repeats and realleges the allegations set forth above in paragraphs 1

through 77 as if specifically set forth herein.

98.

Defendant violated the Whistleblower Act by terminating Plaintiff for participating

in an internal investigation at the behest of the Chairman of the Firm.

99.

Defendant acted intentionally, with malice and reckless disregard for Plaintiffs

rights under the Whistleblower Act.

WHEREFORE, Plaintiff, Dasschinka Storani, respectfully requests this Court grant
judgment in her favor:
(a) awarding judgment against Defendant for the back pay and benefits to which
Plaintiff would have been entitled but for Defendants retaliatory acts;
(b) awarding judgment against Defendant for front pay in lieu of reinstatement;
(c) awarding judgment against Defendant for compensatory damages;

16

(d) awarding judgment against Defendant for punitive damages;

(e) awarding Plaintiff reasonable attorneys fees and costs; and
(f) for all other and further relief this Court deem just and proper.
DEMAND FOR JURY TRIAL
Plaintiff respectfully demands a trial by jury for all issues so triable.
Dated: December 27, 2014.

Respectfully submitted,

By: /s/ Angelena M. Root

Angelena M. Root, Esq.
FBN: 101751
Angelena M. Root, P.A.
1931 Cordova Road, #303
Fort Lauderdale, Florida 33316
Ph: (954) 986-2101
Fax: (954) 212-0774
Email: [email protected]

17

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
DASSCHlNKA STORANI,
CASE NO.:
Plaintiff,
v.

ARNSTEIN & LEHR LLP, a foreign

limited liability partnership,
Defendant.

_______________________1
VERIFICATION OF COMPLAINT PURSUANT TO 28 U.S.c. 1746
I, Dasschinka Storani, the above-named Plaintiff, hereby verify under penalty of perjury
pursuant to 28 U.S.c. 1746 that the facts alleged in the foregoing Com aint are true and correct
to the best of my knowledge.
This 27th day of December, 2014.

By: DasscRmka Storani

18