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34. Plaintiff brings this claim for relief for violation of the FLSA as a collective action pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b), on behalf of all persons similarly situated as Mental Health Professionals who were or are employed by Defendant and who are entitled to payment for all of their ove...
win
114,060
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Kazerouni Law Group, APC 21. FoodState, is a leading producer in the United States of health supplements purported to be created from whole foods. Defendant sells One Daily Multivitamin in varying quantities, inclu...
lose
113,999
24. CSRs are typically paid at a rate of approximately $14.00 to $17.00 per hour. 25. CSRs are employed on a full-time basis (meaning more than 30 hours per week) and on some weeks worked over forty (40) hours in a single week, but in other weeks worked less than forty (40) hours. 26. Prior to being hired, CS...
win
193,416
(FLSA Overtime Wage Violations Against Defendants – Collective Action) (NYLL Failure to Pay Wages Against Defendants – Class Action) (NYLL Overtime Wage Violations Against Defendants – Class Action) 23. At all times relevant hereto, Defendants have committed the following acts and/or omissions with knowledge tha...
win
72,323
(Breach of Contract) (Breach of the Implied Covenant of Good Faith and Fair Dealing) 10. GEICO's car insurance policy (the "Policy") uses standard language provided by Insurance Services Office, Inc. As part of that standardized language, the Policy specifies that GEICO "will pay for collision loss to the owned...
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353,998
11. Stage 3 has, at all relevant times, paid its Day Rate Workers (including Rodriguez) a day rate for the work they perform. It maintains employment records on them, and can terminate their employment. 12. The Day Rate Workers are only paid for days they work. 13. Stage 3’s Day Rate Workers are non-exempt ...
win
122,337
14. Named Plaintiff and others who are similarly situated as name plaintiff are not executive, professional or otherwise exempt from the wage and hour laws. In essence, Named plaintiff and others who are similarly situated as Named plaintiff, are food service support personnel whose time is controlled by their emplo...
win
234,342
Violation of California Business & Professions Code §§17500, et seq. By Plaintiff and the Proposed Class against Defendant 22. In addition to asserting class claims, Plaintiff assert claims on behalf of class members pursuant to California Business & Professions Code § 17200, et seq. The purpose...
lose
54,927
10. Defendant sent EXHIBIT A to Plaintiff in an attempt to collect from her a debt arising from one or more transactions the subject of which were the purchase of personal or household goods and services; a debt within the meaning of l5 U.S.C. g 1692a(5). I https://www.nationalrecovery.com/ 2 11. language: Consistent ...
win
37,962
25. On or about August 14, 2020, Defendant caused a call with a prerecorded message to be transmitted to Plaintiff’s cellular telephone number ending in 9590 (the “9590 Number”). 26. Because Plaintiff did not answer her telephone after it rang, a voicemail containing a prerecorded message was left on Plaintiff’s ...
win
189,564
(Claim for Violation of 14(d) of the 1934 Act Against Defendants) (Claim for Violation of Section 14(e) of the 1934 Act Against Defendants) (Claim for Violation of Section 20(a) of the 1934 Act Against the Individual Defendants and MaxLinear) 27. Exar designs, develops, and markets high performance integrated ...
lose
357,657
23. On August 12, 2013, Plaintiff purchased four (4) cups of Yogurt from the grocery store chain, Albertsons, at a cost of $1.39 per cup. 24. On August 16, 2013, Plaintiff purchased four (4) cups of Yogurt from the grocery store chain, Albertsons, Albertsons, at a cost of $1.39 per cup. 25. On August 19, 2013, P...
lose
305,924
14. On or about June 15, 2014, Plaintiffs attended a timeshare sales presentation led by agents of Defendant. 15. During the timeshare sales presentation, Defendant's agents offered Plaintiffs the purchase of a timeshare vacation ownership interest in exchange for valuable consideration, as further described in ...
win
343,755
20. In late 2019, an outbreak of respiratory illness resulting from a novel coronavirus was first identified in Wuhan City, Hubei Province, China. That illness, now known as COVID-19, has spread across the world. COVID-19 has been designated a pandemic by the World Health Organization, the first pandemic resultin...
lose
121,825
23. The requirements of Federal Rule of Civil Procedure 23(a), 23(b)(1), 23(b)(2), and 23(b)(3) are met with respect to the Class defined below. 36. Waste Management offers a wide range of services including solid waste and recyclable materials collection services for residential, industrial, municipal and commer...
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124,204
10. Yet in violation of this rule, Defendant fails to obtain any express written consent prior to making prerecorded collection calls to cellular telephone numbers such as Plaintiff’s. 11. Huntington Bank openly admits on its website that it places prerecorded calls and calls using an automatic telephone dialing ...
lose
394,219
10. Plaintiff brings this class action on his own behalf, and as a class action, pursuant to Federal Rule of Civil Procedure 23, on behalf of a class of people defined as follows: All disabled individuals who have been unable to obtain required accessibility information online, or to independently secure an online...
lose
411,103
16. Defendants committed the following alleged acts knowingly, intentionally and willfully. 17. Defendants knew that the nonpayment of minimum wage, overtime pay, spread of hours pay, unlawful retention of tips, and failure to provide the required wage notice at the time of hiring and failure to provide a correc...
win
288,100
13. Defendant Onity (formerly TESA Security Systems) was founded in 1941 as a lock manufacturer. 14. Onity represents that it has “set the standard” for locking devices with installations of more than 3.7 million locks worldwide since 1984. 15 U.S.C. §§ 2301 ET SEQ. 15. Onity represents that it provides the finest q...
lose
352,744
44. Pursuant to Fed. R. Civ. P. 23(a) and 23(b)(2), the named Plaintiffs bring this action individually and on behalf of all other persons similarly situated. The proposed Plaintiff Class consists of All unhoused persons who live outside within the City of Seattle, Washington and who keep their belongings on publ...
lose
410,559
15. Ford manufactures and sells trucks, including the Ford F-Series line of trucks. 17. Prior to purchase, Plaintiff viewed the Truck parked on the dealership’s inventory lot. As it sat on the lot prior to purchase, the Truck contained a pre-installed 6- inch lift kit and was fitted with tires that were larger...
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256,239
38. Plaintiff Kevin Robertson is forty-three years old, and resides in Fort Gay, Wayne County, West Virginia. 39. Mr. Robertson has an eighth-grade education and worked for approximately twenty years as a land surveyor. He worked until 2006 at which time he became unable to work due to constantly worsening mood...
lose
48,756
29. On or about January 16, 2019, Plaintiff responded to Defendant’s text messages with the word “Stop” as shown below, “Stop” was the “opt-out” preference provided by Defendant in its text messages: 30. Defendant’s text messages constitute telemarketing and advertising because they promote Defendant’s business,...
lose
435,372
21. Defendant is a football gear manufacturing company that owns and operates the website, www.xenith.com (its “Website”), offering features which should allow all consumers to access the goods and services which Defendant ensures the delivery of throughout the United States, including New York State. 22. Defend...
win
250,240
(Violation of New York State Civil Rights Law, NY CLS Civ R, Article 4 (CLS Civ R § 40 et seq.) (on behalf of Plaintiff and New York subclass) (Violation of 42 U.S.C. §§ 12181, et seq. — Title III of the Americans with Disabilities Act) (on behalf of Plaintiff and the Class) (Violation of New York State Human Ri...
win
421,675
2.1 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
win
226,770
10. Plaintiff brings claims, pursuant to the Federal Rules of Civil Procedure (hereinafter “FRCP”) Rule 23, individually and on behalf of the following consumer class (the “Class”): • All New York consumers who received a collection letter from Defendant attempting to collect an obligation owed to or allegedly owed...
win
114,395
1. a statement that the recipient is legally entitled to opt-out of receiving future faxed advertisements – knowing that he or she has the legal right to request an opt-out gives impetus for recipients to make such a request, if desired; 10. On behalf of itself and all others similarly situated, Plaintiff brings...
lose
258,446
11. Accordingly, as a matter of law, the practice of paying fees to real estate brokers in connection with their placing home warranties with home buyers, where the payment to the real estate agent is conditioned upon a successful transaction selling the warranty product, is a violation of Section 8(a) of RESPA, 1...
lose
405,212
(Violations of 47 U.S.C. § 227 et seq.) 27. In 2019, United and its affiliated carriers operated more than 1.7 million flights carrying more than 162 million customers.1 28. While operating its business, United actively chose to communicate with its customers through SMS text messages, which are sent to consume...
lose
84,659
56. This action is brought as a class action. Plaintiff brings this action on behalf of herself and on behalf of all other persons similarly situated pursuant to Rule 23 of the Federal Rules of Civil Procedure. 57. The identities of all class members are readily ascertainable from the records of the Defendant an...
win
211,625
17. Plaintiffs bring claims for relief as a collective action pursuant to FLSA Section 16(b), 29 U.S.C. §216(b), on behalf of all non-exempt front-of-house and back-of-house employees (including delivery persons, servers, runners, bussers, porters, cooks, line-cooks, food preparers and dishwashers) employed by Defe...
lose
162,461
22. Upon information and belief, almost all corn grown in the United States is grown from seeds that have been genetically modified (commonly referred to as genetically modified organisms, or, for short, “GMOs”), and as such, almost all corn and corn-based ingredients in the United States are in fact unnatural, syn...
lose
424,912
2.0 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
win
151,474
20. Plaintiff re-alleges and incorporates by reference the above paragraphs as if fully set forth herein. 21. Plaintiff and similarly-situated staff, including STNAs, work or worked for Defendants during the past three years. 22. These STNAs and similar staff were compensated at two pay rates, one for Medicare, ...
win
180,937
7. The Complaint and the FAC contain vague, ambiguous, and often conflicting allegations both internally and between the two pleadings. 8. In the Complaint, Plaintiffs’ alleged class is described as “All former and current employees (“Class Members”) employed by Defendants within the State of California within fo...
win
394,516
12. In 1991, Congress enacted the TCPA in response to a growing number of consumer complaints regarding certain telemarketing practices. 39. As a separate and distinct cause of action against all DEFENDANTS, PLAINTIFFS reallege and incorporate by reference, as though fully set forth herein, all the foregoing par...
lose
242,014
16. The COBRA amendments to ERISA included certain provisions relating to continuation of health coverage upon termination of employment or another “qualifying event” as defined by the statute. 17. Among other things, COBRA requires the plan sponsor of each group health plan normally employing more than 20 emplo...
win
134,451
14. Defendant North Star sells final expense insurance to consumers on the telephone.3 15. Defendant North Star uses telemarketing to solicit potential customers for its final expense insurance packages. 16. Defendant North Star calls consumers with a pre-recorded voice message without first obtaining the co...
lose
305,291
XII. CAUSES OF ACTION ............................................................................................. 20 First Cause of Action ................................................................................................ 20 Second Cause of Action .........................................................
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227,144
13. On December 31, 2014, Defendant sent an unsolicited advertisement to Plaintiff’s ink-and-paper facsimile machine. The fax advertises the Aeroflow Vista MultiPost Cervical Collar (the “Product”). It states that “in addition to back braces, Aeroflow Healthcare is pleased to announce that we now offer Cervical Col...
win
252,809
12. The products at issue in this case consist of all varieties (e.g., different types of roasts) and sizes (e.g., 11.5 oz., 30.6 oz., etc.) of Maxwell House ground coffee canisters, tins, and bricks which make a specific servings representation on the front label (e.g., “MAKES UP TO 90 6 FL CUPS”). 49. Plaintif...
lose
138,616
10. Defendant contacted or attempted to contact Plaintiff from telephone number (310) 356-0418 confirmed to be Defendant’s number. 19. Plaintiff brings this action individually and on behalf of all others similarly situated, as a member the two proposed classes (hereafter, jointly, “The Classes”). 8. Beginni...
win
242,276
10. The WCC houses approximately 230 women inmates. Most of the women have been convicted of, or are being detained for, nonviolent offenses. More than a third have mental health problems. Many have been victims of sexual assault or abuse. 11. Inmates at the WCC who cannot remain in general population because they hav...
win
182,980
10. Defendant Spinnaker is a Florida corporation. Upon information and belief, Defendant purchases lists of consumers to call without receiving their consent. 11. Spinnaker has turned to unsolicited telemarketing as a way to increase its customer base as it seeks to generate sales for its vacation ownership busin...
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231,765
34. The crux of the FLSA, PA State Laws, and New Hampshire State Laws is, inter alia, that all employees are entitled to be paid mandated minimum wages for all hours worked. 35. Contrary to these basic protections, Plaintiff and the members of the Classes were deprived of the mandated minimum wage for all hours t...
lose
436,396
2.1 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
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221,409
20. Defendant is an online glasses shop, and owns and operates the website, www.opticsplanet.com (its “Website”), offering features which should allow all consumers to access the goods and services and which Defendant ensures the delivery of such goods throughout the United States, including New York State. 21. ...
win
155,441
(Declaratory Relief) (on behalf of Plaintiff and the Class) 103. Plaintiff realleges and incorporates by reference the foregoing allegations as if set forth fully herein. 104. An actual controversy has arisen and now exists between the parties in that Plaintiff contends, and is informed and believes that Defendan...
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353,686
Knowing and/or Willful Violation of the Telephone Consumer Protection Act (47 U.S.C. 227, et seq.) on behalf of all Classes and Subclasses as to all Defendants Statutory Violations of the Telephone Consumer Protection Act (47 U.S.C. 227, et seq.) on behalf of all Classes and Subclasses as to all Defendants. 25...
lose
162,509
41. Plaintiffs bring this case as a class action pursuant to Federal Rules of Civil Procedure 23(b)(1)(A) and (b)(2), and, alternatively, 23(b)(3), for themselves and for all others similarly situated, and any subclasses deemed appropriate by this Court. The class consists of all individuals: 1) who are Washington St...
lose
291,387
26. Jedson is an “integrated engineering, procurement, and construction management (EPCm) company[.]”1 1 https://jedson.com/about/ (last visited December 9, 2019). 4 27. To complete its business objectives, Jedson hires personnel, such as Wiggins, to perform construction management services. 28. Many of thes...
win
419,459
(5 U.S.C. § 706(2)(A)) 44. Named plaintiff HFTX brings this action on behalf of itself and all other similarly situated grantees, excluding the grantees named as plaintiffs in already pending actions brought to challenge HHS’s termination of TPPP grants. 46. Excluded from the class are the plaintiffs in the fo...
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339,425
(Fair Labor Standards Act – Unpaid Overtime) (Fair Labor Standards Act – Unpaid Minimum Wage) (New York Labor Law – Unpaid Minimum Wage) 18. From the start of Plaintiffs’ employment through March 21, 2020, La Floridita was open for breakfast, lunch and dinner, seven days per week. 20. From March 22, 2020 thr...
win
161,126
(South Carolina Payment of Wages Act) (Individual and Class Action) 15. Plaintiffs reallege each and every allegation contained in the above paragraphs as if repeated here verbatim. 16. Defendants own and operate Hudson’s. 18. Carlock was employed by Hudson’s from August of 2016 through March of 2017 as a se...
win
373,534
13. Defendant Paul Didelius is the Owner and President of Frontier Rail Corporation, Frontier Rail Group, YCR Corporation, Yakima Central Railway, Western Washington Railroad, Kennewick Terminal Railroad, Oregon Railconnect, Lake Railway, and Cincinnati East Terminal Railroad (“The Short Lines”). 42. Johnson bring...
lose
322,284
23. This action is properly maintainable as a class action. 24. The Class is so numerous that joinder of all members is impracticable. As of April 25, 2017, there were 83,539,116 shares of Swift class A common stock and 49,741,938 shares of Swift class B common stock outstanding held by hundreds, if not thousan...
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225,016
19. Plaintiff brings this action as a class action on behalf of himself and the other public stockholders of Mines Management (the “Class”). Excluded from the Class are Defendants herein and any person, firm, trust, corporation, or other entity related to or affiliated with any Defendant. 20. This action is pro...
lose
360,295
17. On March 13, 2020, President Donald J. Trump declared the 2020 coronavirus global pandemic (“COVID-19”) a national emergency. Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak, WHITEHOUSE.GOV (March 13, 2020), https://www. whitehouse.gov/presidential-ac...
lose
373,250
24. Defendant’s text messages were transmitted to Plaintiff’s cellular telephone, and within the time frame relevant to this action. 25. Defendant’s text messages constitute telemarketing because they encouraged the future purchase or investment in property, goods, or services, i.e., selling Plaintiff storage a...
lose
197,023
10. At all times relevant, Plaintiffs were citizens of the State of California. Plaintiffs are, and at all times mentioned herein were, “persons” as defined by 47 U.S.C. § 153 (10). 11. Defendant is, and at all times mentioned herein was, a corporation and a “person,” as defined by 47 U.S.C. § 153 (10). 12. At a...
lose
45,204
28. Plaintiff, for himself and on behalf of others similarly situated, seeks class action certification pursuant to the Federal Rules of Civil Procedure Rule 23(a) and 23 (b)(2) of all deaf and hard of hearing individuals in the United States who have been denied equal access to goods and services of the Defendant’...
win
336,745
24. Upon information and belief, the individual identified in the above prerecorded messages is Kirk Watson, is the owner of Watson Auto Group. 25. The prerecorded telemarketing calls were transmitted to Plaintiff’s cellular telephone, and within the time frame relevant to this action. 26. Defendant’s prer...
win
27,784
(Class Action) VIOLATION OF THE CONNECTICUT WAGE STATUTE 1. Awarding pre- and post-judgment interest to Plaintiffs on these damages; and m. Such further relief as this court deems appropriate. 1. Granting judgment in favor of Plaintiffs and against Defendants and awarding the amount of unpaid overtime wages ca...
lose
373,781
27. Gen 1 provides an array of security and protection services to its clients in the Denver, Colorado area.2 28. Rader and Gen 1’s other Security Guards are the employees who perform the services Gen 1’s provides to its clientele. 30. Gen 1 pays all its Security Guards at straight-time-for-overtime regardles...
win
170,299
13. Defendant Pipeline Safety, L.L.C. is a pipeline services company that inspection, safety, and document management services to pipeline companies. 14. Plaintiff worked for Defendant as an NDE (Non-Destructive Examination) Auditor from 2012 until 2016. 15. Plaintiff worked for Defendant in multiple states ...
win
73,680
10. During much of Plaintiff’s employment, he was required to travel out of state to perform his work. 11. As part of Plaintiff’s work assignments, Defendants required he and a work crew consisting of approximately six to eight individuals to report to their shop between 5:00 a.m. – 7:00 a.m. each Monday mornin...
win
429,255
15. Defendant alleges Plaintiff owes a debt (“the alleged Debt”). 16. The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of a transaction in which the money, property, insurance, or services which are the subject of the transaction are primarily for personal, family, or household purp...
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398,938
16. GIS furnished consumer reports concerning Plaintiff to Genesis as part of its hiring process. During the FCRA statute-of-limitations period, GIS was a “consumer reporting agency” as defined by the FCRA. 17. During the FCRA statute-of-limitations period, GIS was regularly engaged in the business of assembling...
win
63,349
18. On March 23, 2014, the World Health Organization (“WHO”) announced an outbreak of Ebola in West Africa. After the first confirmed case in March 2014, Ebola spread rapidly throughout Guinea, Liberia, and Sierra Leone. 20. By fall 2014, doctors were diagnosing hundreds of new cases each week in West Africa. O...
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23,794
(FAILURE TO PAY OVERTIME WAGES DUE AT TERMINATION – RCW 49.48.010) (FAILURE TO PAY OVERTIME WAGES – RCW 49.46.130) (WILLFUL REFUSAL TO PAY WAGES – RCW 49.52.050) 1. Employment at Les Schwab Tire Centers. ...................................................3 1. Employment at Les Schwab Tire Centers. 15. L...
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232,163
15. 16. The Yahoo Contract incorporates Yahoo's Privacy Policy. j One of the provisions ("Personal-Information Provision") of the Yahoo Contr~t I 27 states, · relevant part: 28 Yahoo! collects personal information when you register with Yahoo! Plaintiff brings this action individually, and as a Class Action ...
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4,354
16. Plaintiff brings this action pursuant to Fed. R. Civ. P. 23 seeking injunctive and monetary relief for Oracle’s systemic refusal to pay full commissions earned by sales employees. A. Class Definition 17. The proposed Class consists of all commissioned sales employees who have been or will be employed by O...
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234,946
10. Through its own website, through online third party retailers (such as Amazon), and likely through some brick-and-mortar retailers, Slendertone markets and sells an over- the-counter medical device called the “Flex Belt,” an electronic muscle stimulating device, approved by the FDA to rehabilitate muscles throug...
win
376,497
25. To compete in the increasingly competitive world of insurance sales, Farm Bureau relies on an army of nearly 2,000 Insurance Agents to sell its insurance policies throughout 14 states. 26. Its Insurance Agents are solicited and managed by agency managers, who Farm Bureau also classifies as independent contr...
win
264,722
10. In July 2018, Simmons experienced chronic and severe pain stemming from a previous Achilles rupture. 11. The previous fall, Simmons was off of work and had surgery to rupture. 12. On July 19, 2019, Dr. Patricia Antero informed Mercedes that do to the nature of the degeneration and previous rupture tha...
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10,927
(Against All Defendants for Violations of Section 14(a) of the Exchange Act and Rule 14a-9 Promulgated Thereunder) (Against the Individual Defendants for Violations of Section 20(a) of the Exchange Act) 27. Plaintiff brings this action as a class action pursuant to Fed. R. Civ. P. 23 on behalf of himself and ...
lose
598
(Violation of USERRA, 38 U.S.C. § 4318, Against the American Plan) (Violation of ERISA §§ 404(a)(1)(A), (B) and (D) Against the PBAC Defendants) 26. The class is so numerous that joinder of all members is impracticable. According to the most recent Form 5500 for the year 2012, the number of active participants i...
win
363,520
10. Doe exercises operational control over Mellow Mushroom; he has the authority to hire, discipline, and fire employees of Mellow Mushroom; he was involved in the decisions to set the wages and pay for Plaintiff and all other similarly situated employees; and, therefore, Doe is individually liable to Plaintiff and...
win
195,551
(FLSA Overtime Violations - 29 U.S.C § 207) Collective Action (FRCP Rule 23 - Oregon Wage Class Action) 1. There is no conflict between his claims and the Rule 23 Class Members’ claims; 1. This is a collective and class action suit to recover unpaid overtime brought under the Fair Labor Standards Act, 29 U.S....
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419,999
25. Defendant operates its physical location at 442 East Bennett Avenue, Cripple Creek, Colorado 80813. 26. Defendant offers its Website in connection with its physical location. The goods and services offered by Defendant through its Website include but are not limited to the following: resort location and hour...
lose
330,682
11. This Action is properly maintained as a class action. The Class is initially defined as: All New York consumers for whom Defendant communicated to any person credit information, which is known to be false and/or for whom Defendant failed to communicate to any person that a disputed debt was disputed as set fo...
win
237,800
1. The amount of the debt; 12. Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 13. The Class consists of: a. all individuals with addresses in the State of New York; b. to whom Defendant Advanced sent an initial collection letter attempting to coll...
win
330,251
(FLSA Overtime Violations - 29 U.S.C § 207; Collective Action) (Failure to Pay Wages When Due – Violation of Oregon Wage and Hour Laws) 16. Defendants’ Retail Merchandisers perform a variety of tasks related to the management of in-store displays in retail stores on behalf of Defendants’ clients. Merchandiser d...
win
323,258
10.   Sometime before 2017, Plaintiff is alleged to have incurred certain financial obligations to Defendant. 11.   Plaintiff allegedly fell behind in the payments allegedly owed on the alleged debt. 12.   Thereafter, Plaintiff retained the services of the Law Office of Daniel G. Shay (“DGS”) to assist Plainti...
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63,733
12. Although no comprehensive study focusing on the accuracy of criminal record reports industrywide, several recent studies demonstrate the prevalence of major inaccuracies in criminal background reports. For example, a 2013 study by the National Employment Law Project examined criminal background checks conducted...
win
5,124
14. Plaintiff Brian Miller is a resident of the State of Arizona, who after serving time in prison, complied with all aspects of the law, and after repaying his debt to society, had his convictions set aside and expunged from his record in accordance with the laws of the State of Arizona, with the most recent order...
win
351
10. A second distinct revenue-augmenting surcharge FedEx Express charges and collects in certain circumstances is the residential delivery component of the delivery area surcharge. The FedEx Service Guide defines the delivery area surcharge as a per package fee for “shipments destined to select U.S. ZIP codes” tha...
win
93,518
63. This matter is brought by Plaintiff on behalf of itself and those similarly situated, under Federal Rules of Civil Procedure 23(b)(1), 23(b)(2), and 23(b)(3). COMPLAINT JURY TRIAL DEMANDED I.
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204,624
33. In December 2019, an initial cluster of nine patients with an unknown cause of viral pneumonia was found to be linked to the Huanan seafood market in Wuhan, China, where many non-aquatic animals such as birds were also on sale. However, one of the patients never visited the market, though he had stayed in a ho...
lose
197,026
Violation of California Business & Professions Code § 17200, et seq. By Plaintiff and the Proposed Class against Defendant Violation of California Business & Professions Code §§17500, et seq. By Plaintiff and the Proposed Class against Defendant 26. In addition to asserting clas...
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258,752
28. The number of persons in the class makes joinder of the individual class members impractical. 29. There are questions of fact and law common to all class members. Factually, all class members are public employees and union nonmembers who have been forced to pay “fair-share fees” to Education Minnesota as a con...
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441,337
14. In addition to the facts pled above, at various times prior to the filing of the instant complaint, including within one year preceding the filing of this complaint, DEFENDANT contacted PLAINTIFF in an attempt to collect an alleged outstanding debt. 15. On or about 2014, Plaintiff began receiving numerous ...
lose
427,399
11. This Action is properly maintained as a statewide class action. The Class consists of:  All New Jersey consumers who were sent collection letters and/or notices from the Defendant that contained at least one of the alleged violations arising from the Defendant's violations of 15 U.S.C. § 1692 et seq.  The C...
win
161,661
(COMMON LAW CONTRACT AND/OR QUASI-CONTRACT) (FAIR LABOR STANDARDS ACT) 1. Permitting the Collective Action Plaintiffs to join this case as Plaintiffs. 2. Declaring that the Defendant violated the Fair Labor Standards Act; 3. Declaring that the Defendant’s violations of the FLSA were willful; 4. Granting...
win
224,638
15. Defendant Strom, a privately-held corporation, provides staffing in the form of strike and lockout replacement labor for unionized employers at locations throughout the United States. 17. In doing so, these strike-busting agencies and the companies that hire them not only exert downward pressure on working s...
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415,599
26. Since 2008, Defendant Rue La La has maintained a “members-only” private sale website that promises consumers discounted deals on various products and services. 27. To receive the deals offered by Defendant Rue La La, consumers must sign up and provide their email addresses and other personal information to ...
win
330,259
5.0 Prior to April 30, 2014 VHA had approximately 475 public housing units. 6.0 Plaintiffs seek to maintain this lawsuit as a class action under Fed. R. Civ. P. 23(a). They ask the Court to certify a declaratory and injunctive relief class under Fed. R. Civ. P.23(b)(2) and a separate damages class under Fed. R...
win
309,952
11. Plaintiffs incorporate paragraphs 1 through 10 of this complaint as if fully alleged 6 17. Plaintiffs incorporate paragraphs 1 through 10 of this complaint as if fully alleged 25 herein. 26 18. At all relevant times, Plaintiffs and the other members of the Rest Periods Class were 27 employees of Defenda...
win
233,701
12. Plaintiff incorporates herein by reference paragraphs 1-11 as if set forth fully herein. 13. Plaintiff brings this Count on behalf of himself and a Class of all persons who were charged a transaction fee for the use of automated teller machine number TRA819364CD00001 located at 4999 Old Orchard Center, Skoki...
win