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38. Within the applicable limitations period, in the spring of 2019, Plaintiff patronized Defendant’s property located at 380 Beaver Valley Mall Blvd #655, Monaca, PA 15061 (the “Subject Property"). 40. Plaintiff has shopped at Defendant’s stores in the past, including within the past month. During his visits to...
win
47,809
19. Sanofi is a pharmaceutical group engaged in the research, development, manufacture and marketing of healthcare products. The Company's business includes two main activities: pharmaceuticals and human vaccines. In its pharmaceutical activity, the Company specializes in six therapeutic areas: thrombosis, cardio...
win
37,193
14. Sometime prior to December 19, 2017, Plaintiff allegedly incurred financial obligations (the “Debt”) to a creditor. 15. Subsequently the Debt was assigned, placed, or otherwise transferred to Defendant for collection. 16. Prior to December 19, 2017, Plaintiff obtained representation from Attorney, Daniel G. ...
win
288,354
12. Defendants employed Plaintiff and class members as group fitness instructors. Group fitness instructors teach fitness classes to Defendants’ members, such as spinning, aerobics, and yoga. 13. Plaintiff worked as a group fitness instructor at Defendants’ Bloomington, Minnesota location as a group fitness inst...
lose
365,581
28. It is, upon information and belief, Defendant’s policy and practice to deny Plaintiff, along with other blind or visually-impaired users, access to Defendant’s website, and to therefore specifically deny the goods and services that are offered thereby. Due to Defendant’s failure and refusal to remove access barrier...
lose
296,064
(Breach of Fiduciary Duty) Against B&P and Chaitman LLP (Breach of Contract) Against B&P and Chaitman LLP (Unjust Enrichment) Against B&P and Chaitman LLP 20. FSPT brings this action as a class action pursuant to Federal Rules of Civil Procedure 23(a) and 23(b)(3) on behalf of all persons who were represente...
win
133,004
10. Plaintiff's alleged debt was primarily for personal, family or household purposes and is therefore a “debt” as defined by 15 U.S.C. § 1692a(5). 11. Sometime after the incurrence of the debt, but before the initiation of this action, Plaintiff is alleged to have fallen behind on payments allegedly owed on the ...
win
70,526
10. The alleged charges for repair consumed Plaintiff’s security deposit and more, leaving Plaintiff with an alleged and disputed debt owing to her former landlord. 11. The landlord apparently turned over to Defendant for collection the disputed charges. 12. As its initial communication with Plaintiff, Defe...
win
428,555
21. The language on the aforesaid website reads as follows: 31. This action is brought on behalf of a class consisting of: All persons in the United States who unsubscribed to receive text messages from Domino’s Pizza and were subsequently sent text message advertisements from Defendant (or any party on behalf o...
lose
105,026
4.1 Ryland Homes is a developer and new home builder with operations throughout the United States. In the past 3 years, Defendants have employed thousands of individuals throughout the country as salespersons, including Plaintiffs and all others similarly situated. 4.11 Defendants’ business operations, and the w...
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412,863
Background a. Publications Targeted by Defendants
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88,646
16. Defendants are flooring contractors, specializing in installing tile for businesses across the United States. Defendants have flown their employees to install tile at various jobsites throughout the United States, including in New Mexico, Arizona, Texas, Kansas, Utah, Colorado, Massachusetts, Virginia, Indiana,...
win
119,254
15. Plaintiffs bring this action pursuant to Rule 23, FRCivP, as a class action for himself and as representative of and for, and on behalf of, all other similarly situated persons ("Class Members"). The Class Members are defined as participants in EMSA’s Utility Fee Program from 2008 through 2013 who were detrimen...
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447,118
28. It is, upon information and belief, Defendant’s policy and practice to deny Plaintiff, along with other blind or visually-impaired users, access to Defendant’s website, and to therefore specifically deny the goods and services that are offered thereby. Due to Defendant’s failure and refusal to remove access bar...
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251,365
10. Sometime prior to November 20, 2012, Plaintiff entered into a contractual relationship with Defendant for the purpose of utilizing a gym membership offered by Defendant. 11. On or about November 20, 2012, Defendant sent a text message to Plaintiff’s cellular telephone number ending in “4700.” 25. Plaintiff...
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19,012
(Breach of Contract) (Breach of Warranty) (Cal. Bus. & Prof. Code) (§17200 (Unfair Competition)) (Cal. Bus. & Prof. Code) (§17500 and §17508 (False Advertising)) (Cal.Civ.Code § 1750 et seq.) 25. For example, Defendants’ Principal Display Panel on packaging of its L- Arginine-Ornithine stated a quantity...
win
192,743
(Breach of Fiduciary Duty) (Breach of Contract) (Negligence and Gross Negligence) (Negligent Misrepresentations and Omissions) (Violation of the Trust Indenture Act of 1939, 53 Stat. 1171) 1. The Duties and Obligations Set Forth in the PSA 24. The vast majority of residential mortgage loans that Countrywi...
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258,282
10. Despite the satisfaction, Experian has continued to report the judgment as outstanding on Plaintiff’s credit report. 11. Experian, itself or through a third party, affirmatively seeks out and purchases public records data, including Arizona civil judgments, to report to the world about Arizonans when it sell...
win
104,149
14. Defendant Express Scripts is a pharmacy benefits manager. It acts as a third-party intermediary in the healthcare market, administering prescription claims on behalf of large health plans and corporate clients. It also owns and operates certain mail-order pharmacies. 6 15. Defendant Medco is also a pharmacy...
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404,486
16. Founded in Australia in 2016, Afterpay has expanded to become one of the largest buy now, pay later services in the U.S. 17. The concept of "buy now, pay later" has existed since the birth of credit cards. Afterpay has expanded this concept to offer point-of-sale loans for online and in-store purchases throu...
lose
149,076
(INDIVIDUAL AND CLASS CLAIMS) VIOLATION OF NEW YORK EXECUTIVE LAW § 296, subd. 1(a) – GENDER DISCRIMINATION 285. This Cause of Action is brought on behalf of Plaintiffs and all members of the class 286. Defendant has discriminated against Plaintiffs and all members of the class in violation of Section 296, subd...
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252,141
11. On or about July 20, 2016, Greenspoon sent LaPan a letter containing a "NOTICE OF DEFAULT AND ELECTION TO SELL UNDER DEED OF TRUST" ("Default Notice"), an insert titled "FAIR DEBT COLLECTION PRACTICES ACT DISCLOSURE" ("FDCPA Notice") and an "EXHIBIT A" (the "List"). The Default Notice was pro-forma, containing...
lose
9,068
40. Plaintiffs and those similarly situated as part of a collective pursuant to the FLSA incorporate herein by this reference the allegations contained in this Complaint as if set forth verbatim. 41. Plaintiffs bring their First Claim for Relief, the FLSA claim, as an “opt-in” collective action pursuant to 29 U....
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210,372
16. Allied announces on its website that it has offices in 17 states and places employees in more than 30 states. 17. Upon information and belief, Allied has purchased consumer reports from consumer reporting agencies for the last five (5) years, which are used as a basis to take adverse action against job appli...
win
287,081
19. Collective and Class: Plaintiff bring this action on behalf of himself and an ascertainable nationwide collective and statewide class consisting of: FLSA Collective All persons currently or formerly employed by Tesla, Inc. throughout the United States as an Owner Advisor, Sales Advisor, or any other similar ...
win
67,888
(Knowing and/or Willful Violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227(b)(1)) On Behalf of Plaintiff and the Class (Violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227(b)(1)) On Behalf of Plaintiff and the Class 14. Robocalls Outlawed: Enacted in 1991, the TCPA makes it unl...
win
247,664
17. Defendants STAMATIS BILLILIS and JOANN BILLILIS actively participate in the day-to-day operation of the Restaurant. For instance, STAMATIS BILLILIS and JOANN BILLILIS personally supervise and direct the work of the employees, instruct the employees how to perform their jobs, and correct and/or reprimand the em...
win
289,717
11. Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 12. The Class consists of: a. all individuals with addresses in the State of Texas; b. to whom Defendant SG&B sent an initial collection letter attempting to collect a consumer debt; c. that decept...
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261,492
) F.N.B. CORP; ) ) HONAT BANCORP; ) 16. On January 21, 2020, the Center for Disease Control and Prevention (“CDC”) confirmed the first U.S. case of a new coronavirus, also known as COVID-19. 18. On March 11, 2020, the WHO declared that the spread of COVID-19 had become a pandemic. 19. On March 13, 2020, ...
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196,191
Defendant. Plaintiff LORIANN MILLER (hereinafter, “Plaintiff”), a New Jersey resident, brings this amended class action complaint by and through the undersigned attorneys, against Defendant CAPITAL ACCOUNTS, LLC (hereinafter “Defendant”), individually and on behalf of a class of ...
win
55,135
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
365,451
14. You Select Health markets and sells health insurance plans for individuals, families, and small businesses. 15. In order to boost sales and increase its revenues, You Select Health sends numerous faxes advertising its health insurance plans. 16. You Select Health sends these fax advertisements to individua...
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224,356
(Disparate Treatment Pregnancy Discrimination in Violation of the NYCHRL – Individual and Class Claims) 209. Plaintiff, on behalf of herself and the Proposed Disparate Treatment Class, hereby repeats, reiterates and re-alleges each and every previous allegation as if fully set forth herein. 210. As described abo...
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277,133
23. Plaintiff has visited Defendant’s facilities located at 9999 W 38th Ave., Wheat Ridge, Colorado, including within the last year, where he experienced unnecessary difficulty and risk due to excessive slopes in a purportedly accessible parking area and other ADA accessibility violations as set forth in more detai...
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341,837
12. On information and belief, Defendant is a for-profit company which provides offsite clinical laboratory testing services. 13. On or about June 9, 2020 and June 11, 2020, Defendant sent two unsolicited facsimiles to Plaintiff using a telephone facsimile machine, computer, or other device. See Exhibit A. 14...
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169,619
10. On November 22,2016, Business Health Solutions received the unsolicited fax advertisement attached as Exhibit A on its facsimile machine. The fax offered to purchase participation in a survey in exchange for a payment of $10.00. 11. Such faxes are advertisements subject to the TCPA. Fischbein v. Olson Research G...
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76,700
11. Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 12. The Class consists of: a. all individuals with addresses in the State of New York; b. to whom Defendant EOS sent an initial collection letter; c. attempting to collect a consumer debt; d. that ...
win
115,246
17. Plaintiffs bring Count I of this Complaint as a collective action, alleging violations of the FLSA on behalf of themselves and all similarly situated individuals. This “Federal Collective Group” is defined as: all individuals who, through a contract with Defendants or otherwise, distribute or distributed for D...
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42,195
40. Plaintiff brings this case as a class action pursuant to Fed. R. Civ. P. 23, on behalf of himself and all others similarly situated. 52. Plaintiff re-alleges and incorporates the foregoing allegations as if fully set forth herein. 53. It is a violation of the TCPA to make “any call (other than a call made...
lose
113,014
(Count I: 15 U.S.C. § 1681b(b)(1)) 16. Congress has imposed a comprehensive statutory scheme governing the reporting and use of information concerning consumers’ backgrounds in the employment context. A key component of Congress’s oversight is giving consumers the right to control the dissemination of their pr...
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267,185
12. Plaintiffs files this case an “opt-in” class action as specifically allowed by 29 U.S.C. §216(b). 13. The class that the Plaintiffs seeks to represent may be described as follows: 1) All current and former employees of the above-named Defendants who worked as “cleaning and sanitation” workers at HEB warehouse...
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39,425
(Individually And On Behalf Of The Class) (Individually And On Behalf Of The Class) (On Behalf Of Plaintiff and on behalf of the Class) 1. Compensatory damages in an amount according to proof; 1. A declaration that Apple’s sales practices as described herein are wrongful, unfair, unconscionable and in violat...
win
24,443
27. Despite this difficulty and risk, Plaintiff plans to return to Defendants’ facilities. Plaintiff likes Arby’s and enjoys eating there several times a year. Plaintiff would like to return to this Arby’s in the future, but is deterred from doing so given the limitations of the facility. Furthermore, Plaintiff int...
win
224,432
22. Defendant alleges Plaintiff owes a debt (“the alleged Debt”). 23. 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 pu...
win
15,580
20. Sandia maintains uniform employment, compensation, performance review, and promotion policies throughout the United States. Sandia also cultivates and promotes a common corporate culture. These policies and this culture originate in Sandia headquarters in the State of New Mexico, and are disseminated to its o...
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129,826
27. During the relevant time period, the Defendant was an “employer” as defined in 29 U.S.C. §2611(4). 28. Plaintiff was an “eligible employee,” as defined in 29 U.S.C. §2611(2), because she had worked in excess of 1,250 hours during the twelve-month period preceding her June 2020 leave request. 29. Plaintiff...
win
143,977
(FLSA – COLLECTIVE ACTION FOR UNPAID OVERTIME) (R.C. § 4113.5 – RULE 23 CLASS ACTION FOR VIOLATIONS OF THE OHIO PROMPT PAY ACT) (R.C. § 4111.03 – RULE 23 CLASS ACTION FOR UNPAID OVERTIME) 23. At all times relevant herein, Plaintiff was jointly employed by Defendants as an inside insurance sales agent. 24. ...
win
2,362
(Against SquareTrade and Allstate for Violation of New York General Business Law §349) (Against Costco for Violation of the New York General Business Law §349) (Against Costco for Violation of New York GBL §350) (Against SquareTrade and Allstate for Violation of New York GBL §350) (Breach of Contract against Sq...
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106,643
(Collective Action Alleging FLSA Violations) A. FLSA COVERAGE (Class Action Alleging Violations of Texas Common Law) A. VIOLATIONS OF TEXAS COMMON LAW 21. Sagora Senior Living, Inc. (“Sagora”) “provides customized lifestyles and care for independent senior living, assisted living, and memory care in Texas, O...
win
53,014
1. (773) 717-5652; j. (361) 271-4092; and k. (310) 773-5113. 14. In March of 2015, Plaintiff began receiving phone calls on his cellular phone from a phone number that was unknown to him - (469) 619-6420 - that appeared to have been initiated by an automatic telephone dialing system. 15. Plaintiff believes...
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91,020
20. On or about February 9, 2018, Defendant sent an initial written communication to Plaintiff in connection with the collection of the Debt. 21. A true and correct copy of the February 9, 2018 written communication is attached as Exhibit A. 22. The February 9, 2018 communication was the first communication P...
win
417,912
13. Defendant ACF is a merchant processing account company for small to medium sized businesses. 15. On information and belief, Defendant Blake Zinke personally controlled and maintained the dialing equipment 3CLogic that was used in the telemarketing campaign and oversaw and set the company’s policies with re...
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107,587
10. During Plaintiff’s employment with Defendant, Defendant employed two or more employees which handled goods, materials and supplies which had travelled in interstate commerce. 11. Included in such goods, materials and supplies were computers, telephones, office equipment and furniture, as well as numerou...
win
307,919
11. At all times relevant, Plaintiff was a citizen of the State of California. Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47 27. Plaintiff brings this action on behalf of himself and on behalf of and all others similarly situated (“the Class”). 39. Plaintiff incorporates by refer...
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402,264
2.0 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.0 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Website, with contact information for users to report accessibility-...
win
136,662
28. The Plaintiff incorporates by reference all of the above paragraphs as though set forth herein in their entirety. 29. According to 28 U.S.C. § 2201, this Court has the power to adjudicate a dispute between the Plaintiff and the Defendants involving any issue involving federal law. 30. The Plaintiff is agg...
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294,397
(Declaratory Relief) (on behalf of Plaintiff and the Class) 105. Plaintiff realleges and incorporates by reference the foregoing allegations as if set forth fully herein. 106. An actual controversy has arisen and now exists between the parties in that Plaintiff contends, and is informed and believes that Defenda...
win
246,106
21. Defendants are a theater and restaurant that operates their theater and restaurant as well as the Website to the public. The theater and restaurant is located at 12 East 94th St., New York, New York. Defendants’ theater and restaurant constitutes a place of public accommodation. Defendants’ theater and restaur...
win
52,957
17. Plaintiff incorporates by reference and realleges all paragraphs previously alleged herein. 18. At all times relevant, Defendant made and continues to make automatic renewal offers and continuous service offers, as those terms are defined by Cal. Bus. & Prof. Code § 17600, et seq. (“California’s Automatic Pu...
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96,485
66. Ms. Tolton graduated from Harvard Law School, where she was selected as the Commencement 2010 Class Day Student Speaker. At Harvard, Ms. Tolton served on the Graduate Council, the 2010 Class Committee, the Harvard Law School Student Government, and the Executive Board of the Harvard Law California Club. She joi...
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333,416
12. Defendant Integrated Media Solutions, LLC is a media and marketing company that owns and operates magazines, websites, direct mail programs, database marketing operations, and service programs for dental professionals and dental products suppliers. 13. On information and belief, Defendant Integrated Media is...
win
284,213
10. This public ruse is maintained by the defendants in order to impose and collect fines and costs from citizens, and is accomplished by allowing JCS to determine how much each municipal court defendant will be charged for the collection “services” of JCS each month, how much of the public money paid will be kep...
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428,107
10. Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 11. The Class consists of: a. all individuals with addresses in the State of New York; b. to whom CCC sent a collection letter attempting to collect a consumer debt; c. after the consumer’s bankrupt...
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127,023
1. Occurrence. .................................................................................. 14  1. 2004 National Athletic Trainers’ Association 1. 2. Two Forces. ................................................................................. 14  3. Subconcussive Hits. .........................................
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242,603
14. Sony’s PlayStation 4 (“PS4”) is a home video game console designed, developed, marketed, and sold by Defendants. The PS4 was released in North America on November 15, 2013, and retailed for approximately $400.00. 15. The PS4 was a massive success for Sony and, as of May 22, 2016, 40 million PS4s have been s...
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429,607
10. Plaintiff Morgan entered into one or more consumer transactions with “ATI Physical Therapy” (“ATI”) or an affiliate or predecessor corporation. 11. Each consumer transaction was incurred for personal medical services. 12. Further, each consumer transaction involved agreements to render services and defer ...
win
205,767
23. Defendant offers the https://www.nine-ten.com/ website to the public. The website offers features which should allow all consumers to access the goods and services which Defendant offers in connection with its physical location. The goods and services offered by Defendant include but are not limited to the f...
win
379,306
11. This Court has personal jurisdiction over NAP because NAP maintains its headquarters in Connecticut and because NAP has tens of thousands of customers in Connecticut and thereby conducts business in this state. 13. In the late 90s and early 2000s, many states moved to deregulate at least part of the electr...
win
382,627
19. Artech provides staffing services for many industries worldwide, including information technology and project management. 20. Haynes worked for Artech from approximately June 2019 until February 2020. 21. Haynes performed work for Artech’s customer at the Tennessee Valley Authority Gallatin Fossil Plant i...
win
94,905
11. Sugar Leaf is, and was at all times relevant herein, in the business of, among other things, making and selling foodstuffs both at its retail location, for catering outside events, for shipment nationwide through its internet sales website. 12. Plaintiff was employed by Sugar Leaf in its bakery. The principa...
win
19,447
14. On or around August 19, 2013, Lowery mailed a debt collection letter to Plaintiff regarding an alleged debt allegedly owed to CACH and allegedly previously owed to “Bank of America, N.A.” A copy of this letter is attached to this complaint as Exhibit A. 15. The alleged debt identified in Exhibit A was for an ...
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300,892
23. Defendant offers the https://www.loewshotels.com/ website to the public. The website offers features which should allow all consumers to access the goods and services which Defendant offers in connection with its physical locations. The goods and services offered by Defendant include but are not limited to t...
win
260,352
19. Plaintiff worked for Defendant as a tool pusher from approximately March of 2014 to April of 2016. 20. As a tool pusher, Plaintiff’s primary duty involved manual labor at oil well sites. He performed physical labor tasks at the well sites and worked outdoors, exposed to the elements. He also acted as a liaison bet...
win
447,072
21. Swift is a multinational corporation that operates an international trucking terminal network, and provides long-haul transportation services and other logistics services throughout the continental United States, Mexico, and Canada, and in this Judicial District. 22. Swift operates nearly 18,000 trucks, and it...
win
92,156
46. Plaintiffs were hourly employees of NYHMC, many of whom worked at NYHMC for over 20 years in all facets of the management of the New Yorker Hotel. Plaintiffs included maintenance/repair staff, housekeeping, frontdesk and all other non-exempt hourly paid employees. 47. However, in or around December 2018, ma...
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55,580
10. Beginning in or around February 2016, Defendants contacted Plaintiff on Plaintiff’s cellular telephone number ending in -1554, in an attempt to solicit Plaintiff to purchase Defendants’ services. 11. Defendants used an “automatic telephone dialing system” as defined by 47 U.S.C. § 227(a)(1) to place its ca...
win
383,384
10. Upon information and belief, Defendant utilizes third party vendors to market its services. 11. Upon information and belief, Defendant’s vendors are essential to their telemarketing activities. 12. Upon information and belief, Defendant’s ability to increase revenues depends significantly on their acces...
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34,323
(Violation of N.C. Gen. Stat. §§ 75-1 & 75-2) (Violation of the Sherman Act, § 1) 13. Plaintiff does not, as yet, know the exact size of the Proposed Class because such information is in the exclusive control of Duke and UNC. Based upon publically available information, there are at least thousands of Class me...
win
412,850
(Class Action Alleging Violations of the Arizona Wage Laws) A. VIOLATIONS OF ARIZONA LAW (Collective Action Alleging FLSA Violations) A. FLSA COVERAGE 23. Web.com provides website development and marketing services to its clients at its call centers.3 24. Plaintiffs and the Putative Class Members’ job duti...
win
295,728
15. Plaintiff is, and has been at all times relevant to this action, the regular and sole user of his cellular telephone number—(802) 238-XXXX. 16. Plaintiff is not a customer of Defendant, nor has Plaintiff ever done business with Defendant. Plaintiff never sought Defendant’s business and did not authorize any pr...
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342,689
10. Defendant contacted or attempted to contact Plaintiff from telephone numbers (813) 295-2840, (646) 813-2670, and (617) 581-0895, confirmed to belong to Defendant. 11. Defendant’s calls constituted calls that were not for emergency purposes as defined by 47 U.S.C. § 227(b)(1)(A). 12. Defendant’s calls were...
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175,112
10. Upon information and belief, Exhibit A is a form letter, generated by computer, and with the information specific to Plaintiff inserted by computer. 11. Exhibit A is the first letter that Plaintiff received from Life Line regarding the alleged debt referenced in Exhibit A. 12. In Exhibit A, Life Line ident...
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101,682
39. Plaintiffs re-allege and re-aver each and every allegation and statement contained in paragraphs above of this Complaint as if fully set forth herein. 40. At all relevant times, upon information and belief, Defendants were and continue to be an employer engaged in interstate commerce and/or the production of ...
win
207,429
1. An order certifying that Count I may be maintained as a class action pursuant to Rule 23 of the Federal Rules of Civil Procedure and appointing Plaintiffs and the undersigned counsel to represent the class as previously set forth and defined above; 15. On February 29, 2012, Jonbu Tunji Adebo allegedly incurred a...
win
131,566
(Violations of 18 U.S.C. § 1962(b) of the Racketeer Influenced and Corrupt Organizations Act [18 U.S.C. §§ 1961-68]) ................................................. 41  By Plaintiffs against All Defendants .................................................................... 41  (Violation of 18 U.S.C. § 1962(d) of t...
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367,205
ARISING OUT OF, THIS AGREEMENT OR ANY ACCOUNT OR THE DEALINGS OF THE RELATIONSHIP BETWEEN YOU OR US, OR (B) SEEK TO CONSOLIDATE ANY SUCH ACTION IN WHICH A JURY CONTROL, INCLUDING, BUT NOT LIMITED TO, ACTS OF BANKING AUTHORITIES, NATIONAL EMERGENCIES, ACTS OF GOD, FAILURE OF TRANSPORTATION, COMMUNICATION OR POWER S...
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429,078
& REPRESENTATIVE ACTION COMPLAINT FOR DAMAGES, RESTITUTION AND OTHER RELIEF 1. Failure to Compensate Piece Rate Employees for Rest and Recovery Periods and Other Non-Productive Time (Cal. Lab. Code §§ 226.2); 15. Defendant MNG publishes and distributes newspapers of general circulation. Many of MNG’s customers ...
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119,797
1. whether Defendant National Recall & Data Services Inc. and Defendant Charles Holley obtained, re-disclosed, and/or resold Plaintiffs and Class Member's personal information contained within motor vehicle records maintained by the State motor vehicle departments; 2. whether Defendant Naviss obtained, re-dis...
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209,129
10. Defendant used an “automatic telephone dialing system”, as defined by 47 U.S.C. § 227(a)(1) to place its calls to Plaintiff seeking to sell or solicit its business services. 11. Defendant’s calls constituted calls that were not for emergency purposes as defined by 47 U.S.C. § 227(b)(1)(A). 12. Defendant’...
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256,799
35. Plaintiff has repeatedly visited Defendant’s stores including Defendant’s store located at 2011 Route 19, Cranberry Township, Pennsylvania (the “Subject Property”) and encountered unlawful and discriminatory interior access barriers including, but not necessarily limited to, merchandise displays, boxes, and lad...
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234,862
14. At all times relevant, Plaintiff was a citizen of the State of Florida, and at all times mentioned herein was, a “person” as defined by 47 U.S.C. § 153 (39). 15. Defendant is, and at all times mentioned herein was, a corporation and “persons,” as defined by 47 U.S.C. § 153 (39). 16. At all times relevant...
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164,871
13. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs numbered “1” through “12” herein with the same force and effect as if the same were set forth at length herein. 14. Some time prior to March 23, 2015, an obligation was allegedly incurred to Nellie Mae. 15. The Nellie Mae ...
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442,462
11. Plaintiff and those he seeks to represent in this action are current and former servers and bartenders at Defendants’ Local Gastropub restaurants in Memphis, Tennessee. 12. Defendants pay Plaintiff and other servers and bartenders at their Local Gastropub restaurants an hourly wage below $7.25. For example, D...
win
410,210
1. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs above herein with the same force and effect as if the same were set forth at length herein. 10. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's conduct violated Section 1692f et seq. of the ...
win
397,815
18. At all relevant times, Plaintiff and FLSA Collective Members are and have been similarly situated, have had substantially similar job requirements and pay provisions, and are and have been subject to Defendants’ common policies, practices, procedures and patterns with regards to their compensation, including th...
win
19,801
(New York Labor Law: Unpaid Overtime Premium Hourly Wages) 117. Plaintiffs re-allege and incorporate by reference all allegations set forth in all preceding paragraphs of this Complaint. 118. At times relevant to this action, Plaintiffs were employees and Defendants have been employers within the meaning of the N...
win
193,016
2.0 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.0 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
win
411,914
21. Defendant is an art studio that operates art studios as well as the Website to the public. Defendant operates an art studio located at 9714 Metropolitan Avenue, Forest Hills, New York. Defendant’s art studio constitutes a place of public accommodation. Defendant’s art studio provides to the public important go...
win
304,091
24. Defendant operates the NAVA REAL ESTATE DEVELOPMENT, LLC Residential Complex and Leasing Office as well as its website, www.lakehouse17.com, and offers it to the public and offers features that should allow all consumers to access the facilities and services that Defendant offers regarding its physical location...
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305,045
14. Beginning in or around August of 2014, Defendant repeatedly placed automated calls and text messages to Plaintiff’s cellular telephone 270-XXX-9408. 15. The telephone number that Defendant used to contact Plaintiff was and is assigned to a cellular telephone service as specified in 47 U.S.C. § 227(b)(1)(A)(ii...
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