Filing # 194252076 E-Filed 03/18/2024 03:13:37 PM
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`EXHIBIT A
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`NOT A CERTIFIED COPY
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`FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 03/18/2024 03:13:37 PM
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`BETH COKE
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`EMPLOYMENT LAW
`February 8, 2023
`Via Electronic Mail
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`NOT A CERTIFIED COPY
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`Rachelle McBride, Esq.
`Cheney Brothers, Inc.
`One Cheney Way
`Riviera Beach, FL 33404
`RachelleM@CheneyBrothers.com
`Re: Wesley Richards
`Dear Ms. McBride:
`I am in receipt of your February 3, 2023 letter to Mr. Richards. Please direct
`all future correspondence concerning this matter to me and not to my client directly.
`At the outset, there are additional facts of which you need to be aware. Mr.
`Richards has been discussing with Byron Russell leaving Cheney Bros, for over a
`year. Until recently there were two issues that caused Mr. Richards to want to leave.
`The first is that Mr. Richards was significantly underpaid from the standard, which
`can be determined by organizations such as the National Business Aviation
`Association (“NBAA”), based on experience and type of aircraft. The second issue
`was the micromanagement and demeaning, disrespectful manner in which the Chief
`Pilot treats pilots, including Mr. Richards.
`In January 2022, Mr. Russell gave Mr. Richards a raise and promised that he
`would work to resolve the issues with the ChiefPilot to convince him to stay another
`year. Prior to going to the training, Mr. Richards approached the Chief Pilot about
`getting a raise to bring him to the minimum standard. The response was to wait until
`after the training. Mr. Richards was originally scheduled to go to the training at issue
`in the middle of the year, but five days prior to going was advised that he would be
`, the Chief Pilot
`going. Regardless, after the training was completed by
`REDACTED
`indicated that he would not be receiving a raise. At that point, Mr. Richards applied
`for a job at another company. A week or so before he gave notice, Mr. Richards was
`I 3 I NORTH SECOND STREET. SUITE 204 • FORT PIERCE. FL 34950
`TELEPHONE: (772) 252-4230 • beth@cokeemploymentlaw.com • FAX: (772) 252-4575
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`Rachelle McBride, Esq.
`February 8, 2023
`Page 2
`open about seeking another opportunity with the ChiefPilot who indicated that there
`was nothing that could be done if he wanted to leave because there are no contracts.
`In addition, prior to leaving, after repeatedly speaking with the Chief Pilot
`about the raise, he set a meeting for Mr. Richards to meet directly with Mr. Russell
`about the pay issue as well as a significant safety issue offlying the new plane, which
`is much larger than their other aircrafts, out of a small airfield. When they met, Mr.
`Richards told Mr. Russell that he needed a raise as he had recently been offered an
`opportunity to make significantly more money, to which Mr. Russell responded that
`was something he should consider. At no time did
`indicate that Mr.
`REDACTED
`Richards was under any obligation to repay the training costs. That only occurred
`after Mr. Richards gave his notice and Mr. Russell was angry that he was leaving.
`Having litigated these types of cases, I am keenly aware that the standard in
`the industry is to have pilots sign contracts agreeing to pay back training costs before
`the training is provided. That was not done here. Instead, you are seeking to rely on
`tort claims that simply do not apply. First, none of the claims will be successful
`because Mr. Richards did not promise to stay in Cheney Brothers’ employ. Rather
`that is contrary to the facts. However, had Mr. Richards been given a suitable raise
`and removal of the safety issue by flying the new plane out of a larger field such as
`Palm Beach or Stuart, he may not have left.
`There is no legal basis for Cheney Brothers to pursue training costs against
`my client so if legal proceedings are initiated, we will defend vigorously and seek
`fees and costs for having to do so. Further, if your client takes any action that
`jeopardizes his new employment, we will be filing suit for tortious interference. If
`you have case law that supports your threatened actions, please immediately provide
`it for my review. Otherwise I will consider the matter closed.
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`NOT A CERTIFIED COPY
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`Sincerely,
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`cc: Wesley Richards
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