IN THE COUNTY COURT
 BREVARD COUNTY, FLORIDA

Michael Thomas Harbuck
655 N. Burnett Road
Cocoa, FL 32936

VS.

Half Halt L.L.C   / Registered Agent:  Mr. Richard Benne
611 SEVILLE COURT
SATELLITE BEACH FL 32937 

COMPLAINT
	Having occurred, and containing a seat of the defendant who is a registered Florida company ,  within the jurisdiction of the court,
	The PLAINTIFF,  Michael Thomas Harbuck,  contends  herewith, and files with the court,  that he has suffered damages from the defendant due to breach of employment contract with the DEFENDANT, Half Halt L.L.C which did cause loss of wages, emotional distress, and substantial inconvenience.
The plaintiff contends that there was a verbal employment contract of both express and implied responsibilities which was wrongfully terminated without cause.  
I
Verbal Employment Agreement 
1.  Having learned of a possible posistion at the Half Half L.L.C,  aka Half Halt Stables, from a person who was then under employment for the defendant, the plaintif did contact  a registered manager of the employer.  The manager did request a day of work the 27th of  July, 2012.   A further day of work was requested for the following Monday, the 30th of July.  The plaintif was informed that due to severe ethical and qualification problems with the current  employee, that a full time position was available.  
2.  The plaintiff did express the necessity for a written contract, however was never given any contractual documents in writing during anytime during the employment.  
3.   The express contractual details below were discussed with the staff accountant, when at that time it was requested to offer bank information for paperless payment.
	a.  Hours of work
	b. General Responsibilities
	c. Compensation
	d. Live-In arrangements
4.  Due to the agricultural and veterinary aspects of the employment responsibilities it was necessary for the plainatif to change residency to the work location, as requested by the defendant, who also viewed residency as a night security service.  
5.   The implied body of the contract was discussed as casual conversation throughout the hiring process.  It was both suggested and implied that this was to be a term of employment lasting as long as possible, with the knowledge that the plaintif planned to return to school in the fall of 2013.    
6.  The term of six months to one year was the implied minimum length of employment.  The defendant did appear very concerned about the fact that it was important to be both reliable, as well as an employee who would not quit after a brief period of time.   
7.  The plaintiff was truthful with the defendant regarding past employment history.  
8.  The plaintiff was truthful regarding his background check.  
9.  The term "direct hire" without probationary term was the type of employment the plaintiff  entered into in good faith.  
II
Employment Period
1.  The plaintiff now an employee was lauded often for excellent work and work ethic.
2.  The plaintiff did ask each employee daily if there would be anyway the plaintiff could help the fellow employees.  
3.  The plaintiff did execute all duties and responsibilities in a professional and ethical manner.
4.  The plaintiff did go above and beyond expectation and compensatory boundaries to work both extra hours well above a 40 hour work week without complaint or demand for overtime compensation.  
5.  The plaintiff did work holidays without the expectation of legally alloted holiday pay compensation.  (Labor Day).  Nor recieve any.  
6.  The plaintiff is professionally qualified for the demanded responsibilities therefore meeting all employment requirements.  

III
Termination

1.  The plaintiff did not  enjoy working with a young student who had blatant disregard for the request by the plaintiff to try to refrain from foul language in common areas when the plaintiff was near.  
2.   The plaintiff did lose respect for and therefore not enjoy the company of the above mentioned student due to being informed by the same that she had lied about her  need  to attend a probation appointment to the manager.   The young student employee did  angrily demand of the plaintiff that there be  no use of a foreign langauge where the student was living.  
3.  The plaintiff did recieve a caution from the manager for "talking too much" on approximately the 10th of October, 2012.
4.  The defendant did hire an employee after the reprimand who was never introduced to the plaintiff and was therefore being trained, never having been discussed with the plaintiff, nor even introduced, although communication between employees at such a facility is necessary for the well being of live animals.  
5.  The plaintiff did work two weeks without a free day for two weeks so that the manager and associated persons would be able to attend a professional event.  
6.  The defendant did call the plaintiff into the office on October 23rd, 2012 to communicate the decision to terminate the plaintiff.   The plaintiff did aks if there would be anything which could be said or done to change the decision.  The plaintiff did request a reason for the termination.  The only response was the manager did not like the personality of the plaintiff.  
7.  The plaintiff did leave the office and return to work, being bewildered and upset.
8.  The manager did follow the plaintiff and an argument ensued.    If it pleases the court, this may be expounded upon if it wishes.   The manager did eject the plaintiff from the work area,  not allowing further work, stating that there would now be no two week termination notice given.  
9.  The plaintiff did immediately contact the Brevard County Sheriff to request information on the legallity of the living arangement at the employer site, having experienced the fate of the previous employee.  

IV
Defamation
1.  The registered agent Mr. Benne did arrive the same day at the work address and contacted the plaintiff with demands that the plaintiff leave immediately.  
2.  The plaintiff then attempted to explain that information about the type of rental agreement had already been obtained from the Brevard County Sheriff.  The defendant and registered agent then called the Brevard County Sheriff reporting a false claim of a disturbance as well as belittling the plaintiff with derogatory names.  
3.  The defendant did make false and unfounded claims against the plaintiff  to  the deputies of such a nature, that the plaintiff was extremely offended.  

THEREFORE the actual performance of the plaintif did not warrant termination, nor had the defendant upheld the verbal agreement for employment for a certain time period.  

Demand for Damages	
WHEREFORE is it demanded that damages be paid by the DEFENDANT to the PLAINTIFF, and that the  following be satisfied before the court :
1.  The amount of lost wages for the minimum verbally implied period which is 	twelve (12) weeks "salary" 				12 x $430.00 = $5160.00
The plaintiff does agree to repay any unemployment compensation recieved the 	three months after wrongful termination.
2.  A monetary punitive damage of the courts determination regarding the 	emotional distress and inconvenience to the plaintiff.
3.  Any and all legal fees incured in the process of this claim including court costs and legal council if necessary.  
	4. Any compensation the court deems acceptable using current laws and cases.  

	5.  Reasonable relocation costs due to the necessity to change residence.

STATE OF FLORIDA
COUNTY  OF BREVARD

	I,  Michael Thomas Harbuck, the PLAINTIFF, state that the foregoing is a just and true statement, and or complaint, and an accurate account of the occurrences described herein.  

______________________________ 			Sworn to and subscribed before me 								by
Plaintiff																			____________________________
								
Michael Thomas Harbuck				who is personally know to me or 
655 N. Burnett Road					produced	
Cocoa, FL 32926			  		_____________________________
Tel. (407) 408- 3009					as identification this ______ day 								of__________, in the year_______.
					
							Deputy Clerk or Notary Public
							State of ___________________
							My commission expires: