Jacquelyn Bouazizi v. Hillsborough County Civil Service Board, et al.

Should the Doctrine of Equitable Tolling be expanded to include a situation in which a pro se party previously represented by counsels, having received substandard legal advice and representation, relying solely on the notion that the hired counsels were competent and can therefore move client’s cause of action involving employment discrimination litigation on the basis of gender, age, retaliation, equal pay, FMLA claim, and race (against Respondents Hillsborough County and the County Civil Service Board) believing on the representation of previous counsels that after filing the Original Complaint, Exhibit 4, Amended Complaint, Exhibit 5, Second Amended Complaint, Exhibit 5-A, Third Amended Complaint, Exhibit 5B; hiring two attorneys who have been practicing labor law and representing to the Petitioner that this is their profession. Petitioner's lawyers Craig Berman, Erik Del E’toile, and Carl R. Hayes enormously failed by failing to comprehend all that is needed in a discrimination case, whose actions were convoluted and confusing to Judge Robert Foster and Judge Virginia Hernandez Covington which resulted to both Judges' failure to verify that Petitioner filed a FMLA Claim as opposed to the alleged Disability Claim of the Petitioner which the latter did not have.

Does failure of attorneys to include in the complaints what needed to be included at the time it should have been, constitutes negligence entitling Petitioner to avail of the application of the Doctrine of Equitable Tolling? Out of filing five complaints and hiring three attorneys, yet Petitioner's attorneys failed to include what needed to be included at the time it should have been included by failing to satisfactorily plead Petitioner's cause of action. Petitioner's attorney's failed to present valid claims, failed to include Equal Pay claim and only included the same after the lapse of its statute of limitations, failed to adduce a prima facie claim, failed to allege how the law applies to the facts, failed to state a cause of action, failed to include comparison with the comparators. Craig Berman filed the original complaint on November 18, 2015 where he failed to amend the complaint as per Judge Robert Foster’s order on two occasions, while attorney Erik Del E’toile filed the two Amended Complaint on January 18, 2018 and Carl R. Hayes filed the Second Amended Complaint on February 19, 2019 as well as the Third Amended Complaint May 9, 2019.

Should a pro se litigant be penalized for the misrepresentation, fraud, and incompetence manifested by her previously hired attorneys, with the fraud committed by Attorneys Todd and Zinober by adding a disability to Petitioner’s EEOC charge to later get Petitioner’s complaints against Respondents Board and County be dismissed with prejudice based on a fraudulent disability claim that they added to Petitioner EEOC charge 511-2014-01711.