throbber
Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 1 of 13
`Filing # 133156879 EAMGOYS3BUYOSse3SpT Pt Filed 11/03/21 Page 1 of 13
`
`IN THE CIRCUIT COURT OF THE
`SECOND JUDICIAL CIRCUIT, IN AND
`FOR LEON COUNTY, FLORIDA
`
`2021 CA 001483
`CASE NO.: 21-CA-
`FLA BAR NO.: 0739685
`
`ROBIN GROVES,
`
`Plaintiff,
`
`v.
`
`PILGRIM'S PRIDE CORPORATION,
`
`Defendant.
`
`/
`
`COMPLAINT
`
`Plaintiff, ROBIN GROVES, hereby sues Defendant, PILGRIM'S PRIDE
`
`CORPORATION,andalleges:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action brought under Family and Medical Leave Act (FMLA)of 1993,
`
`29 U.S.C. §§ 2601-2654, as originally written, and as temporarily modified pursuant to the
`
`Families First Coronavirus Response Act (“FFCRA”), Public Law 116-127, the Florida Civil
`
`Rights Act, codified at Chapter 760, Florida Statutes and the Americans with Disabilities Act,
`
`codified at 42 U.S.C. §12101 et seq.
`
`2.
`
`This action involves claims whichare, individually, in excess of Thirty Thousand
`
`Dollars ($30,000.00), exclusive of costs and interest.
`
`THE PARTIES
`
`3.
`
`Atall times pertinent hereto, Plaintiff, ROBIN GROVES, has beena residentof the
`
`State of Florida and was employed by Defendant. Plaintiff is a memberof a protected class because
`
`of her actual or perceived disability and/or record of impairment and because she is a mother of
`
`school age children (minor children S.B. and IB.) impacted by the COVID-19 pandemic and
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 2 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 2 of 13
`
`because she sought leave under the Family & Medical Leave Act for her children and wasdenied,
`
`leave for herself which wasinterfered with, and she wasretaliated against thereafter. She is also a
`
`memberofa protected class due to her association with a person with disabilities, 1.e., her child.
`
`4.
`
`Atall times pertinent hereto, Defendant, PILGRIM'S PRIDE CORPORATION,
`
`has been organized and existing underthe laws of the State of Florida. At all times pertinentto this
`
`action, Defendant has been an “employer”as that term is used underthe applicable lawsidentified
`
`above. Defendant was Plaintiffs employerasit relates to these claims. Defendant purportsto offer,
`
`among other things, food production. During Plaintiff's employment with Defendant, Defendant
`
`was engaged in interstate commerce, and/or was an enterprise engaged in interstate commerce or
`
`in the production of goods for interstate commerce operated by the Defendant within the meaning
`
`of 29 U.S.C. §203(s)(1)(A).
`
`CONDITIONS PRECEDENT
`
`5.
`
`Plaintiff worked for Defendant for more than 1,250 hours in the year immediately
`
`preceding his need for leave and was employed with Defendant for more than one year.
`
`Defendant employees more thanfifty (50) employees within a seventy-five (75) mile radius and
`
`has satisfied all conditions precedentto bringing this action,if any.
`
`STATEMENT OF THE ULTIMATE FACTS
`
`6.
`
`Plaintiff, a disabled mother of school age children whose learning was impacted
`
`by COVID-19, began her employment with Defendant on or about June 26, 2013 and held the
`
`position of Lift Operator/ Stacker at the time of her wrongful termination on September10,
`
`2020.
`
`7.
`
`When Defendanthired Plaintiff, it informed her of its points-based attendance
`
`policy where calling out or leaving early earned an employee a point. Three (3) points meant the
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 3 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 3 of 13
`
`employee received a warning, and the discipline progressed until the employee received seven
`
`(7) points, at which time they would befired.
`
`8.
`
`Defendant combinesthis policy with a FMLA policy whereby if an employee’s
`
`children are not listed on their FMLA forms, the employee would not be allowed to take
`
`attendant care for the children even when they had a legitimate serious medical need. By the
`
`time of the events set forth below, Plaintiff's children had not yet been added to her FMLA
`
`forms.
`
`9.
`
`Plaintiff's younger daughter was born with a diaphragmatic hernia whereherliver
`
`intruded three-quarters into her lung. Although she has had surgery to reduce the intrusion, her
`
`breathing problemspersist and Plaintiff must take her to doctor’s offices and the hospital for
`
`treatment. Defendant has been callous with Plaintiff about the need to care for her daughter. For
`
`example, on one occasion,Plaintiff was called by her older daughter and told that her younger
`
`daughter was having breathing problemsand neededto goto the hospital, Plaintiff told her
`
`supervisor, who respondedby saying Plaintiff would be given a point for leaving early,
`
`Defendant thereby took adverse employmentactions against Plaintiff for prioritizing her
`
`daughter’s health andlife.
`
`10.
`
`Defendant has given Plaintiff several points for leaving or calling out for
`
`legitimate needs to care for her daughter despite Plaintiff having doctors notes and being her
`
`minor children’s primary caregiver. She wasentitled to attendant care time off under the FMLA
`
`initially and as amended by the FFCRA which Defendant denied. Defendant’s denial of
`
`attendant care continued through the FFCRA’s passage through Plaintiff’s unlawful termination.
`
`Further, Defendant did not follow its own progressive discipline point policy as Plaintiff was
`
`never given a sixth point before Defendant terminated her for caring for herself and her daughter.
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 4 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 4 of 13
`
`11.|Defendantis well aware that her daughter and Plaintiff herself suffer from
`
`multiple serious medical conditions. Plaintiff suffers from Reactive Airway Disease (RAD),
`
`Gastroesophageal Reflux Disease (GERD), Depression, Anxiety, and Post Traumatic Stress
`
`Disorder (PTSD). These conditions adversely affect Plaintiff's ability to perform multiple
`
`substantial life activities including breathing, concentrating, and remaining calm understress.
`
`However, these conditions did not impact Plaintiffs ability to perform the essential functions of
`
`her job with and/or without accommodations.
`
`12.
`
`Despite her stellar work performance during her employment with Defendant,
`
`Plaintiff's legitimate leave requests for self and attendant care have been interfered with and she
`
`has been retaliated against because she took time off to care for herself and her children due to
`
`the Coronavirus pandemic and because of her actual or perceived disability and/or record of
`
`impairment.
`
`13.
`
`The retaliation came at the hands of specifically but not limited to supervisor
`
`Allen Hickey and HR Manager Will Snipes.
`
`14.
`
`On April 1, 2020, the FFCRA was signedinto law and in relevant sections
`
`provided that employeeslike Plaintiff were entitled to at least two weeks (up to eighty (80)
`
`hours) of paid leave at her regular rate of pay and up to ten (10) additional weeksofpaid leave at
`
`two-thirds of her regular rate of pay if they could not work in an office or telework due to the
`
`closure of a child’s school or daycare center due to the Coronavirus pandemic.
`
`15.
`
`Plaintiff has two school age children (S.B. and I.B.) whose learning was impacted
`
`by the Coronavirus pandemic. As the pandemicintensified and schools eventually released their
`
`plans, Plaintiff learned that her children’s schools would not be opening back up and realized her
`
`children would have to continue distance learning.
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 5 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 5 of 13
`
`16.
`
`Because of the school closure, it was imperative Plaintiff remain at home to care
`
`for her children’s needs. However, even after the FFCRA’s passage, Defendant ignored the law
`
`and continued to refuse Plaintiff her attendant care rights guaranteed under the FMLA,as
`
`amended. Plaintiff thus requested she be allowed to extend herself-care leave, which Defendant
`
`approved.
`
`17.
`
`The FFCRA provided employees with Coronavirus symptoms, a doctor’s note, a
`
`need to care for children with coronavirus symptoms, or whoare enrolled in distance learning
`
`with additional FMLA leave which Defendantfailed to fully extend to Plaintiff.
`
`18.
`
`Because Plaintiffs conditions occasionally flare up, she had requested FMLA and
`
`sick leave throughout her tenure with Defendant. Because of her condition, Plaintiff was out on
`
`Short Term Disability from July 13, 2020 through August 18, 2020.
`
`19.
`
`Shortly after her return, Plaintiff experienced a flare up and was out on FMLA
`
`leave from August 28, 2020 through September3, 2020.
`
`20.
`
`On September 1, 2020, Plaintiff was seen at Lake City Medical Center for
`
`complications with her GERD.
`
`21.
`
`On September 3, 2020, Plaintiff and her school aged daughter (1.B.) began
`
`exhibiting Coronavirus symptoms, she notified Defendant’s nurse whoinstructed Plaintiff to stay
`
`homeandgettested.
`
`22.
`
`That day, Plaintiff and her daughter were seen at Lake City Medical Center and
`
`tested for a potential viral upper respiratory infection, believed to be Coronavirus. She had a
`
`follow-up appointment set with her Primary Care Provider, Palms Medical Group for September
`
`8, 2020.
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 6 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 6 of 13
`
`23.
`
`On September8, 2020, Plaintiff's was given a Coronavirustest and doctor’s note
`
`excusing her from work for one week while she awaited hertest results, with a return-to-work date
`
`of September 15, 2020. Plaintiff faxed the note to Defendant.
`
`24.
`
`Plaintiff received her results early on September 10, 2020, with an updated return
`
`to work date of September 11, 2020. Plaintiff faxed the update to Defendant. While she wascleared
`
`of Coronavirus, she wasstill experiencing symptoms of someupperrespiratory infection, possibly
`
`attributable to her RAD.
`
`25.
`
`However, this early return was apparently not enough for Defendant and she was
`
`fired sometime while she was still out on FMLA/FFCRA leave for issues with her disabling
`
`conditions and while awaiting Coronavirustest results.
`
`26.
`
`On September 10, 2020, Plaintiff discovered that she had been terminated indirectly
`
`via a letter that her work-provided healthcare benefits were being cancelled.
`
`27.
`
`Plaintiff immediately called Defendant’s HR office to try and find out why she had
`
`been fired. Defendant gave a false reason, claiming Plaintiff was a three day no call/no show.
`
`Plaintiff had available leave when she was fired and had kept Defendant abreast of all the
`
`developments with her disabling condition flare up and Coronavirustest results. Defendant cannot
`
`plausibly claim Plaintiff did not call when it knew what medical procedures she was undertaking
`
`in real time. As such, Defendant’s reasons are pretextual and the real reason Defendant fired
`
`Plaintiff was because she requested leave for her disabling conditions and to care for her school
`
`age children. She was also fired because of her association with her disabled child and time off
`
`she neededto care for her.
`
`28.
`
`Plaintiff was entitled to leave under the laws stated above and Defendantactively
`
`interfered with and retaliated against her for taking leave she had a legal right to take.
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 7 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 7 of 13
`
`29.
`
`Thus, Defendant unlawfully terminated Plaintiff on September 10, 2020, because
`
`she took protected leave and because of her actual or perceived disability and/or record of
`
`impairment. Defendant also unlawfully terminated Plaintiff due to her association with her child,
`
`whois disabled and for requesting leave under the FFCRA. Plaintiff's need to take leave under
`
`the FMLA motivated Defendant’s decision to terminate her.
`
`30.
`
`Plaintiff has retained the undersigned to represent her interests in this cause and is
`
`obligated to pay a fee for these services. Defendant should be made to pay said fee under the laws
`
`referenced above.
`
`COUNT I
`FFCRA INTERFERENCE
`
`31.
`
`32.
`
`Paragraphs 1 through 30 are re-alleged and are incorporated herein by reference.
`
`This is an action against Defendant for refusing to allow Plaintiff to take protected
`
`leave time under the FMLA,29 U.S.C. §§ 2601-2654. This is thus an interference claim.
`
`33.
`
`The FFCRA includes an amendment to the FMLA thatis titled the “Emergency
`
`Family Medical Leave Expansion Act” (“EFMLEA”).
`
`34.
`
`Plaintiff had worked for Defendants for over seven years in advance of the
`
`FFCRA’s passage and waseligible forits benefits.
`
`35.
`
`Plaintiff was specifically entitled to at least two weeks(up to eighty (80) hours) of
`
`paid sick leave at her normal rate of pay due to the closure of her children’s school, her and her
`
`child’s Coronavirus symptoms,and herand her child’s Coronavirustest. Thereafter Plaintiff was
`
`entitled to up to an additional ten (10) weeks of paid expanded family and medical leave at two-
`
`thirds her normalrate of pay. Plaintiff did not exceed the amountof leave she was allowed under
`
`the FFCRA.
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 8 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 8 of 13
`
`36.
`
`Plaintiff informed Defendantof her need to care for her school-aged children during
`
`the school closure, her and her child’s symptoms, andhertest results and her need to take time off
`
`for such care as described more fully above.
`
`37.
`
`After requesting to take leave to care for her children, Defendant refused her request
`
`and failed or refused to pay Plaintiff leave which she wasentitled to under the FFCRA.
`
`38.
`
`Plaintiff was denied rights and benefits conferred by the FMLA,as amendedby the
`
`FFCRA and was terminated because she requested and took protected leave.
`
`39.
`
` Defendant’s violations of the FFCRA were willful.
`
`40.
`
`As a direct and proximate result of Defendant’s willful, wanton, and maliciousacts
`
`described in part above,Plaintiff has sustained damagesfor the loss of employment, as well as the
`
`security and peace of mindit provided. Plaintiff has incurred damagesfor lost wages, and other
`
`damages attendant with the loss of his job. These damages have occurredin the past, are occurring
`
`at present and will continue in the future.
`
`COUNT I
`FFCRA RETALIATION
`
`41.
`
`42.
`
`Paragraphs 1 through 30 are re-alleged and are incorporated herein by reference.
`
`This is an action against Defendantfor retaliating against Plaintiff due to Plaintiffs
`
`use of protected leave time as set forth more fully above. This is thusaretaliation claim.
`
`43.
`
`The FFCRA includes an amendment to the FMLA thatis titled the “Emergency
`
`Family Medical Leave Expansion Act” (“EFMLEA”).
`
`44. While taking leave to care for herself and her school-aged children during the
`
`school closure and while both were exhibiting Coronavirus symptoms, Defendant terminated
`
`Plaintiff.
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 9 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 9 of 13
`
`45.
`
`Defendants unlawfully discharged Plaintiff based upon exercise of her rights under
`
`the FFCRA byterminating her for attempting to take her protected FFCRA paid sick leave during
`
`the Coronavirus pandemic.
`
`46.
`
`Plaintiff was denied rights and benefits conferred by the FMLA as amended by the
`
`FFCRA and wasterminated after taking protected leave.
`
`47.
`
` Defendant’s violations of the FFCRA were willful.
`
`48.
`
`As a direct and proximate result of Defendant’s willful, wanton, and maliciousacts
`
`described in part above,Plaintiff has sustained damagesfor the loss of employment, as well as the
`
`security and peace of mind it provided. Plaintiff has incurred damagesfor lost wages, and other
`
`damages attendant with the loss of his job. These damages have occurredin the past, are occurring
`
`at present and will continue in the future.
`
`COUNT II
`VIOLATION OF THE FAMILY AND MEDICAL LEAVE ACT
`
`49.
`
`50.
`
`Paragraphs 1 through 30 are re-alleged and are incorporated herein by reference.
`
`This is an action against Defendantfor retaliating against Plaintiff due to Plaintiffs
`
`use of protected leave time for both self and attendant care as set forth more fully above. This is
`
`thusa retaliation claim.
`
`51.
`
`After taking leave for her own serious health conditions and being denied leave for
`
`her daughter’s serious medical conditions, Defendant took adverse personnel actions against
`
`Plaintiff for using leave.
`
`52.
`
`Plaintiff was denied rights and benefits conferred by the FMLA and wasterminated
`
`after taking protected leave.
`
`53.
`
`Defendant’s violations of the FMLA were willful.
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 10 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 10 of 13
`
`54.
`
`As a direct and proximate result of Defendant’s willful, wanton, and maliciousacts
`
`described in part above,Plaintiff has sustained damagesfor the loss of employment, as well as the
`
`security and peace of mind it provided. Plaintiff has incurred damages for lost wages, and other
`
`damages attendant with the loss of his job. These damages have occurredin the past, are occurring
`
`at present and will continue in the future.
`
`COUNT IV
`DISABILITY DISCRIMINATION
`
`55.
`
`56.
`
`Paragraphs 1 through 20 are realleged and incorporated herein by reference.
`
`This is an action against Defendant for disability discrimination brought under
`
`Chapter 760, Florida Statutes.
`
`57.
`
`Plaintiff has been the victim of discrimination on the basis of her disability or
`
`perceived disability. During the course of Plaintiff's employment with Defendant, she was treated
`
`differently than similarly situated nondisabled/perceived-as-disabled employees. This is a
`
`differential treatment claim.
`
`58.|Defendant is liable for the differential treatment and its refusal to reasonably
`
`accommodate Plaintiff, which adversely affected the terms and conditions of Plaintiff's
`
`employment with Defendant. Defendant controlled the actions and inactions of the persons
`
`making decisions affecting Plaintiff or it knew or should have knownofthese actions and inactions
`
`and failed to take prompt and adequate remedial action or took noactionat all to prevent the abuses
`
`to Plaintiff.
`
`59.
`
`In essence, the actions of agents of Defendant, which were each condoned and
`
`ratified by Defendant, were disability/perceived-disability based and in violation of the laws set
`
`forth herein.
`
`10
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 11 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 11 of 13
`
`60.
`
`The discrimination complained of herein affected a term, condition, or privilege of
`
`Plaintiff's continued employment with Defendant. The eventsset forth herein lead, at least in part,
`
`to Plaintiff's termination.
`
`61.
`
`Defendant's conduct and omissions constitutes intentional discrimination and
`
`unlawful employment practices based upon disability or perceived disability or her record of
`
`having an impairment under the laws enumeratedherein.
`
`62.
`
`Asa direct and proximate result of Defendant's conduct described above, Plaintiff
`
`has suffered emotional distress, mental pain and suffering, past and future pecuniary losses,
`
`inconvenience, bodily injury, mental anguish, loss of enjoymentoflife and other non-pecuniary
`
`losses, along with lost back and front pay, interest on pay, bonuses, and other benefits. These
`
`damages have occurred in the past, are permanent and continuing. Plaintiff is entitled to
`
`injunctive/equitable relief and to punitive damages.
`
`COUNT V
`ASSOCIATIONAL DISABILITY DISCRIMINATION
`
`63.
`
`64.
`
`Paragraphs | through 30 are realleged and incorporated herein by reference.
`
`This is an action against Defendant for disability discrimination brought underthe
`
`ADAforPlaintiffs association with her disabled child.
`
`65.
`
`Plaintiff has been the victim of discrimination on the basis of her child’s disability.
`
`During the course of Plaintiff's employment with Defendant, she was treated differently than
`
`similarly situated employees who were not associated with nondisabled/perceived-as-disabled
`
`employees.
`
`66.
`
`Defendant is liable for the differential treatment of Plaintiff which adversely
`
`affected the terms and conditionsofPlaintiff's employment with Defendant. Defendant controlled
`
`the actions and inactions of the persons making decisions affecting Plaintiff or it knew or should
`
`11
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 12 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 12 of 13
`
`have knownofthese actions and inactions and failed to take prompt and adequate remedial action
`
`or took no actionat all to prevent the adverse actions against Plaintiff.
`
`67.
`
`In essence, the actions of agents of Defendant, which were each condoned and
`
`ratified by Defendant, were disability/perceived-disability based and in violation of the laws set
`
`forth herein.
`
`68.
`
`The discrimination complained of herein affected a term, condition, or privilege of
`
`Plaintiff's continued employment with Defendant. The eventsset forth herein lead, at least in part,
`
`to Plaintiffs termination.
`
`69.
`
`Defendant's conduct and omissions constitutes intentional discrimination and
`
`unlawful employment practices based upon Plaintiff’s association with a person whois disabled
`
`under the laws enumerated herein.
`
`70.
`
`Asadirect and proximate result of Defendant's conduct described above, Plaintiff
`
`has suffered emotional distress, mental pain and suffering, past and future pecuniary losses,
`
`inconvenience, bodily injury, mental anguish, loss of enjoymentoflife and other non-pecuniary
`
`losses, along with lost back and front pay, interest on pay, bonuses, and other benefits. These
`
`damages have occurred in the past, are permanent and continuing. Plaintiff is entitled to
`
`injunctive/equitable relief and to punitive damages.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff demands judgment against Defendantfor the following:
`
`(a)
`
`(b)
`
`that process issue and this Court take jurisdiction overthis case;
`
`that this Court grant equitable relief against Defendant underthe applicable
`
`counts set forth above, mandating Defendant’s obedience to the laws
`
`enumerated herein and providing other equitable relief to Plaintiff;
`
`12
`
`

`

`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 13 of 13
`Case 4:21-cv-00442-AW-MAF Document 1-1 Filed 11/03/21 Page 13 of 13
`
`(c)
`
`enter judgment against Defendant and for Plaintiff awarding all legally-
`
`available general and compensatory damages and economiclossto Plaintiff
`
`from Defendant for Defendant’s violations of law enumerated herein;
`
`(d)
`
`enter judgment against Defendant and for Plaintiff permanently enjoining
`
`Defendant from future violations of law enumerated herein;
`
`(c)
`
`enter judgment against Defendant and for Plaintiff awarding Plaintiff
`
`(f)
`
`(g)
`
`attorney's fees and costs;
`
`award Plaintiff interest where appropriate; and
`
`grant such other
`
`further relief as being just and proper under the
`
`circumstances, including but not limited to reinstatement.
`
`DEMAND FOR TRIAL BY JURY
`
`Plaintiff hereby demandsa trial by jury onall issues herein that are sotriable.
`
`DATEDthis 22™ day of August 2021.
`
`Respectfully submitted,
`
`/s/ Marie A. Mattox
`Marie A. Mattox [FBN 0739685]
`MARIE A. MATTOX,P. A.
`203 North GadsdenStreet
`Tallahassee, FL 32301
`Telephone: (850) 383-4800
`Facsimile:
`(850) 383-4801
`Marie@mattoxlaw.com
`Secondary emails:
`
`marlene(@mattoxiaw.com
`michelle@mattoxlaw.com
`
`ATTORNEYS FOR PLAINTIFF
`
`13
`
`

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