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25. Plaintiff, Monica Aniszewski, is a resident of the State of Illinois. MAWKS CORPORATE FACTS 26. Defendant MAWKS EDEWEISS, LTD., d/b/a Edeweiss Restaurant (Hereinafter referred to as “Mawks”), is a corporation or business which does business in Illinois. 27. Mawks operates a large restaurant in Norridge I...
win
395,996
10. Defendant contacted or attempted to contact Plaintiff from telephone number (510) 573-7243, confirmed to be Defendant’s number. 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 placed to telephone number assigned...
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241,204
14. Defendant Safelife sells medical alert devices. 15. Defendant Safelife hired Defendant John Doe to make robocalls promoting Safelife’s products. 16. To increase their sales and avoid paying for legitimate forms of advertising, John Doe called and sent artificial and prerecorded voice messages to thousands ...
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315,961
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; 11. On information and belief, on or about August 19, 2015, Defendants trans...
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448
11. Part 2.5 of the purchase agreement, termed “Assumed Liabilities,” stated that Defendant assumed “all Suzuki Product Liability[.]” Part 16 of the purchase agreement defined “Product Liability” to include “any Liability of Seller [American Suzuki Motor Corporation], regardless of whether arising before or after ...
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21,792
14. Defendant employs personnel who work in Afghanistan providing non- combat support services to deployed United States forces and other government agencies. 15. In 2008, Fluor was awarded the LOGCAP IV contract by the United States Army to provide logistics support to troops stationed in Afghanistan. Becaus...
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41,928
Intrusion Upon Seclusion / Invasion of Privacy (On behalf of Plaintiff and All Class Members against Defendant PaperlessPay and on behalf of Plaintiff and all PHM Subclass Members against Defendant PHM) Plaintiff repeats and re-alleges each and every allegation contained in all Paragraphs above as if fully set for...
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23,690
12. On information and belief, on or about September 5, 2017, Defendants transmitted by telephone facsimile machine an unsolicited facsimile to Plaintiff. A copy of the facsimile is attached hereto as Exhibit A. 13. On information and belief, Defendants receive some or all of the revenues from the sale of the p...
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170,728
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...
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204,418
10. Defendant used an “automatic telephone dialing system” as defined by 47 U.S.C. § 227(a)(1) to place its call to Plaintiff seeking to solicit its services. 11. Defendant contacted or attempted to contact Plaintiff from telephone number (602) 483-1403, which Plaintiff alleges on information and belief was a s...
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51,636
16. Pursuant to 29 U.S.C. §207, Plaintiffs seek to prosecute their FLSA claims as a collective action on behalf of all persons who are or were formerly employed by Defendants at any time since December 4, 2009 to the entry of judgment in this case (the “Collective Action Period”) (statute of limitations tolled by f...
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111,256
22. On or about December 22, 2020 and December 28, 2020, Defendant caused the following automated marketing text messages to be transmitted to Plaintiff’s cellular telephone number ending in 7451 (the “7451 Number”): 23. At the time Plaintiff received these messages she was the subscriber and/or sole user of the...
win
190,453
20. 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. -4- 21. The identities of all class members are readily ascertainable from the records of American Co...
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125,526
28. Plaintiff still has and had, at all relevant times to this action, telephone facsimile service at (714) 333-1840 at its place of business at 2240 N. Harbor Blvd., Suite 110, Fullerton, CA 92835. Plaintiff receives facsimile transmissions (“faxes”) at this number, using a telephone facsimile machine (“fax machi...
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350,692
22. On or around August of 2020, Plaintiff visited the Website, using a popular screen reading software called NonVisual Desktop Access, with the intent of browsing and potentially making a purchase. 24. As a result of visiting the Website, Plaintiff is aware that the Website includes multiple barriers making i...
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286,169
22. While employed by Defendants, Plaintiff, Cynthia Fuerte, was paid at a rate of $8.75 per hour, plus commission and bonus. 23. While employed by Defendants, Plaintiff, Terry Dimery, was paid at a rate of $9.00 per hour. 24. Defendants mission statement states that they are “a people-focused business of ...
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306,526
12. Plaintiff repeats and realleges the allegations contained in paragraphs numbered “1” through “11” herein with the same force and effect as if the same were set forth at length herein. 13. Upon information and belief, Defendant, on behalf of a third-party, began efforts to collect an alleged consumer debt fro...
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451,246
16. On or about February 27, 2010, Plaintiff successfully registered his residential cellular telephone number ending in -2220 with the National Do Not Call Registry. 17. During or about January of 2017, Defendant began placing unsolicited telemarketing calls to Plaintiff’s cellular telephone. 18. Defendant co...
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334,129
23. On or about June 12, 2020, Defendant sent an automated unsolicited marketing text message to Plaintiff Brooks’ cellular telephone number from the telephone number (206) 775- 7325. 24. Then, on June 14, 2020, Defendant sent a second automated unsolicited marketing text message to Plaintiff Brooks’ cellular t...
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395,762
11. On information and belief, on or about September 12, 2016, Defendants used a telephone facsimile machine, computer, or other device to send an unsolicited facsimile to Plaintiff. A copy of the facsimile is attached hereto as Exhibit A. 13. Plaintiff did not give prior express invitation or permission to Def...
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208,289
10. Discovery may reveal the transmission of additional faxes as well. 11. Enterprise Medical Services is responsible for sending or causing the sending of the fax. 13. Enterprise Medical Services either negligently or wilfully violated the rights of Plaintiff and other recipients in sending the fax. 14. Plaintiff ...
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253,132
14. At all times relevant, Plaintiff was a citizen of the State of Florida. Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47 U.S.C. § 153 (39). 15. AIA 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...
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119,521
27. Plaintiff’s claims are brought on its own behalf and as a class action pursuant to Federal Rule of Civil Procedure 23 on behalf of all owners of Lionbridge common stock and their successors in interest, except defendants and their affiliates (the “Class”). 28. Plaintiff’s claims are properly maintainable as a...
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160,449
11. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs numbered above herein with the same force and effect as if the same were set forth at length herein. 12. Some time prior to August 20, 2020, an obligation was allegedly incurred to T-Mobile 40. Plaintiff brings this claim on...
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313,579
18. In or around December of 2007, a third party, CSGA, LLC obtained a default judgment against Plaintiff. 19. Between December of 2009 and July of 2013, Plaintiff received multiple collection letters from four different creditors, each claiming at they owned the judgment. 20. In or around May 30, 2016 Plai...
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354,481
17. Microsoft maintains uniform employment, compensation, performance review, and promotion policies throughout the United States. Microsoft also cultivates and promotes a common corporate culture. 18. Microsoft’s offices throughout the U.S. use a common organizational structure, organizing technical employees...
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395,239
17. Amicus Therapeutics, Inc. is a biotechnology company that developed therapies for rare and orphan diseases. 18. The Company has developed a therapy, an oral small molecule pharmacological chaperone called migalastat, for the treatment of Fabry disease. Amicus’ treatment purports to be a new option for patien...
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290,243
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 August 16, 2014, an obligation was allegedly incurred to First Premier Bank. (“FPB”) 15...
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396,162
16. Progrexion employs more than 1,500 employees at its call centers in Utah, Idaho, Arizona, and Oklahoma. Progrexion’s hourly call-center employees receive calls from Progrexion’s clients and assist those clients with repairing their credit reports.2 17. Upon information and belief, Progrexion is a privately-he...
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153,460
22. Plaintiff brings this action as a class action, pursuant to Federal Rule of Civil Procedure 23, on behalf of all holders of the common stock of the Company (except the Defendants herein and any person, firm, trust, corporation, or other entity related to or affiliated with any of the Defendants) and their succe...
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126,039
22. The crux of the FLSA and South Carolina state law is, inter alia: (i) that all employees are entitled to be paid mandated minimum wages for all hours worked; (ii) that all employees are entitled to premium overtime compensation for all hours worked in excess of 40 hours a week; (iii) that all gratuities earned ...
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231,084
32. Cynthia L. Czuhaj brings this action on behalf of herself and all others similarly situated as a class action pursuant to Rule 23 of the Federal Rules of Civil Procedure. 33. The classes which Consumer Representative seeks to represent are defined as follows: 34. A class consisting of all "consumers" as ...
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187,640
46. Plaintiff incorporates the foregoing paragraphs as though the same were set forth at length herein. 47. Plaintiff and Defendant are parties to a contract regarding the use of the Uber platform, including terms regarding eligible vehicles stating that Acura MDX, Audi Q7, Chevrolet LTZ, Chevrolet Tahoe, Ford E...
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136,473
21. Plaintiff incorporates the preceding paragraphs by reference as if set forth fully in this section. 23. On information and belief, Encinal, Texas is/was the single site of employment, as defined by the WARN Act, for employees of Defendant, such as Martinez and the Class Members. On information and belief, ma...
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165,229
5.1 Defendant Capital Alliance Group provides short term business loans and equipment financing and leasing to small to middle-sized companies. On information and belief, part of Defendant’s strategy for increasing the volume of its customers involves sending unsolicited facsimile advertisements to solicit busine...
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61,830
10. The debt arose from services which were primarily for family, personal, or household purposes, specifically, repairs relating to a personal vehicle for Ms. Heistand, and meets the definition of “debt” under 15 U.S.C. § 1692a(5). 11. Around October 2015, United began attempts to collect the debt from the Heis...
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111,706
12. At all times relevant to the complaint herein, Defendant engaged in telecommunications by means of telephone facsimile machines as defined by the TCPA 47 U.S.C. § 227(a)(3). 13. Upon information and belief, Defendant regularly advertises its goods and services to recipients by transmitting fax advertisements...
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115
10.  Plaintiff alleges that at all times relevant herein Defendant conducted business within this judicial district. 11.  At no time did Plaintiff ever enter into a business relationship with Defendant. 12.  Beginning in 2017, Plaintiff began receiving telephonic communications from Defendant in order to solicit...
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246,473
(Declaratory Relief) (on behalf of Plaintiff and the Class) 110. Plaintiff realleges and incorporates by reference the foregoing allegations as if set forth fully herein. 111. 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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382,157
15. At all relevant times, Defendant has marketed its Products in a consistent and uniform manner. Defendant sells the Products in all 50 states on its website and through various distributors. 31. Plaintiff brings this action individually and as representatives of all those similarly situated, pursuant to Feder...
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250,400
(FLSA – COLLECTIVE ACTION FOR UNPAID OVERTIME) (O.R.C. § 4111.03 – RULE 23 CLASS ACTION FOR UNPAID OVERTIME) 30. In or around September, 2014, Named Plaintiff Parton began working for Defendants as a service technician and/or general laborer until his employment ended on or about May 1, 2017. 31. Service tech...
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338,615
10. Defendants specialize in providing a variety of landscape and grounds keeping services, including some landscaping related construction services, for business and residential clients. 12. Defendant Gregory Hamann has operational control over the Defendant Prime Lawn Care Inc. business by exercising control o...
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181,536
- FDCPA 23. On information and belief, Rushmore acquired servicing of plaintiff s loan in June 2013, after it was in default. 24. The loan was accelerated substantially prior to June 2013. 25. GMAT 2013 claims to have acquired ownership of the loan on or about February 15, 2014, after the loan was in default. 26. O...
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123,963
11. At all relevant times, Plaintiff was an individual residing in the State of Florida. He is a “person” as defined by 47 U.S.C. § 153(39), and the “called party.” See Breslow v. Wells Fargo Bank, N.A., 755 F. 3d 1265 (11th Cir. 2014) and Osorio v. State Farm Bank, F.S.B., 746 F.3d 1242 (11th Cir. 2014). 12. P...
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16,164
6.12 Plaintiff and the Class Members were at all times “non-exempt” employees and eligible to receive overtime pay pursuant to Section 207 of the FLSA. 6.15 During his employment, there were other internet installers/technicians in Texas working for Defendants who were/are subject to the same pay policy/plan desc...
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415,680
113. Plaintiffs incorporate by reference as if fully set forth herein the allegations contained in the preceding paragraphs of this Complaint. 114. Count II is brought on behalf of Plaintiff Maloney. 115. Exhibit A falsely threatens to send Maloney’s account to an attorney and/or threaten a lawsuit against Plain...
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203,003
(FLSA Collective Action) (NYLL Class Action) 15. Defendants own and operate two restaurants in the New York City area under the trade name Libertador. 16. From on or around September 2, 2019 until her termination on or around October 2, 2019, Plaintiff worked for Defendants as a food server at the Libertador ...
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440,162
20. Defendant is a global online marketplace for print-on-demand products based on user-submitted artwork and operates www.redbubble.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 S...
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303,524
(Declaratory Relief) (On behalf of Plaintiffs, the Nationwide Class, and all Subclasses) 171. Plaintiffs incorporate by reference the preceding allegations pled in paragraphs 1- 170 of this Complaint. 172. An actual controversy has arisen and now exists between the parties in that Plaintiffs contend, and are info...
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20
VIOLATIONS OF CALIFORNIA’S FALSE ADVERTISING LAW CAL. BUS. & PROF. CODE §§ 17500, ET SEQ. • Restitution and injunctive relief pursuant to Bus. & Prof. Code § 17203; and • recovery of reasonably attorney’s fees pursuant to, inter alia, California Code of Civil Procedure § 1021.5. VIOLATIONS OF CALIFORNI...
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373,611
22. Plaintiff has never been on a cruise nor has Plaintiff provided Defendant with her email address. 23. Notwithstanding, on or about September 24, 2019, Defendant sent an e-mail to Plaintiff with the following subject line: “1-Day Exclusive Royal Sale! Up to $1,100 to Spend on Board + Hundreds in Discounts.” ...
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293,428
5.1. In January 2018, Plaintiff was treated for a serious medical condition at MultiCare Deaconess Hospital in Spokane, WA. 5.2. MultiCare billed Plaintiff Born for the services it claimed to have performed for her. 5.3. Plaintiff could not afford to pay the balance in full at the time that she was billed. 5....
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10,126
10. In addition, the written agreement must include a clear and conspicuous disclosure informing the signer that: By executing the agreement, such person authorizes the seller to deliver or cause to be delivered to the signatory telemarketing calls using an automatic telephone dialing system or an artificial or pr...
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55,345
24. Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47 U.S.C. § 153(39). 25. Beginning in or around March of 2019, Plaintiff began receiving numerous autodialed calls on her cellular telephone ((XXX) XXX-7223) from Defendant. 26. When Plaintiff did not pick up the phone, Defendan...
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81,224
(Breach of the Implied Covenant of Good Faith and Fair Dealing) (On Behalf of the Class) (Restitution / Unjust Enrichment) (On Behalf of the Class) (In the Alternative) (Violation of New York General Business Law § 349) (On Behalf of the New York Sub-Class) (Violation of Various Consumer Protection Acts) (On...
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165,473
(NOTICE AND ABATEMENT CONSIDERATIONS INCLUDED) 12. At all relevant times herein, Steven and Joanna Cone were the owners of the residence located at 12237 Bethel Drive, Frisco, Collin County, Texas 75033 (the “Property”). Plaintiffs home contained multiple toilet tanks marked with the Vortens, Inc. logo believed...
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90,707
10. FFIF also attempted to collect debts against numerous Arkansas residents through dunning letters and phone calls, while it was not licensed as a debt collector with theASBCA. 11. Additionally, FFIF was also not a licensed debt collector with the ASBCA at the time it filed its Complaint against Lucas. 12. ...
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435,574
20. Prior to the year 2020, Plaintiff successfully registered his cellular telephone number ending in -7262 with the National Do-Not-Call Registry 21. On or about December 11, 2020, Defendants began placing unsolicited, automated telemarketing telephone calls to Plaintiff’s cellular telephone numbers ending in -7...
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145,192
10. The Admiral has misclassified its exotic dancers as independent contractors, when in reality they are employees. 11. The Admiral has exercised extensive control over the manner in which its exotic dancers perform their jobs and conduct themselves while on the club’s premises, including where to be on the pre...
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381,374
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; 12. On information and belief, on or about June 6, 2011, June 7, 2011, and J...
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10,137
(Claim for Failure to Establish the Plans Pursuant to a Written Instrument Meeting the Requirements of ERISA Section 402 Against Defendant Trinity) 165. Plaintiffs incorporate and re-allege by reference the foregoing paragraphs as if fully set forth herein. 166. ERISA section 402, 29 U.S.C. § 1102, provides tha...
win
211,216
1. Whether Defendant’s employees and agents such as managers, bell staff, doormen, concierges, transportation providers, security personnel, front desk and other staff are trained to assist blind and vision-impaired guests with basic needs such as: completing the hotel registration; learning about and completing ser...
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185,289
19. MENN regularly engages in the collection of defaulted consumer debts. 2. Unless Attorney William P. McKinley of Menn Law Firm, Ltd. is notified of a dispute of the indebtedness within thirty (30) days of the date hereof, the debt will be assumed to be valid. 20. According to its website, MENN has wide-...
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122,378
10. Defendant is a business entity engaged in the business of collecting consumer debts. 11. Defendant regularly collects or attempts to collect, directly or indirectly, debts owed or due or asserted to be owed or due another. 26. This action is brought on behalf of the following “FDCPA Class.” 27. The “FD...
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243,864
Breach of Contract and Breach of the Covenant of Good Faith and Fair Dealing 11. Plaintiff re-alleges and hereby incorporates by this reference each and every preceding and subsequent allegation as though fully set forth herein. 12. In or about 2014, Plaintiff purchased the “DualTools PS7000” (the “polisher/sande...
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7,907
43. Plaintiff incorporates by reference each and every preceding paragraph as though fully set forth herein. Plaintiff brings this cause of action on behalf of herself and the Class solely for breach of federal law. This cause of action is not based on any violation of state law. 44. The MMWA, 15 U.S.C. §§ 230...
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435,322
1.”) 21. Defendant alleges Plaintiff owes a debt (“the alleged Debt”). 22. 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 house...
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147,442
27. Plaintiff incorporates the above paragraphs of this complaint as if fully alleged herein. Plaintiff brings his first cause of action as a nationwide "opt-in" collective action pursuant to 29 U.S.C. § 216(b), on behalf of himself and on behalf of the following class of persons ("FLSA Class"): All persons who we...
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412,294
20. Prior to November of 2018, Kathleen visited Menorah Medical Center in Overland Park, Kansas. 22. In or around November of 2018, Menorah Medical Center referred the Debt to Defendant for collection from Plaintiffs and Defendant then contacted Plaintiffs regarding the Debt. 23. Plaintiffs and Defendant agre...
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304,147
1. Kroger Does Not Disclose That Its Products Are Artificially Flavored. 1. Kroger Does Not Disclose That Its Products Are Artificially Flavored. ......................... 4 2. Federal and State Laws Require Kroger to Disclose the Artificial Flavor in Its Products. ....................................................
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313,617
16. Defendants have regularly denied plaintiffs freedom of religion and the right to marry. 17. Plaintiffs hereby incorporate by reference as though fully set forth at length herein paragraphs 1 - 16 of this Complaint. 18. Plaintiffs assert that defendants have regularly denied them freedom of religion and the ri...
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297,332
1. Whether Defendant’s employees and agents such as managers, security personnel and other staff are trained to assist blind and vision-impaired guests with basic needs such as: completing the hotel registration; learning about and completing service requests like reviewing the hotel bill and charges; counting and ...
win
276,678
45. The Plaintiffs bring this action individually and as a class and collective action on behalf of all persons similarly situated and proximately damaged by the Defendants’ unlawful conduct as follows: (a) failure to pay wages for all hours worked and overtime compensation at rates not less than one and one-half t...
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107,445
20. Plaintiff re-states, re-alleges, and incorporates herein by reference, paragraphs one (1) through nineteen (19) as if set forth fully in this cause of action. 21. This cause of action is brought on behalf of Plaintiff and the members of a class. 22. The class consists of all persons whom Defendant's records...
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404,740
1. To enter an Order certifying the proposed Class under Rule 23 and appointing Plaintiffs and the undersigned counsel of record to represent the Class; 12. Law enforcement agencies in North Carolina are obligated to investigate crashes which are reported to them, such as those described below. 13. In conduct...
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94,356
(BOAC Aided and Abetted the Bank’s Breach of Fiduciary Duty) (Breach of Fiduciary Duty: Prudent Investing) (Self-Dealing in Violation of the Fiduciary Duties of Loyalty and to Avoid Conflicts of Interest) (Unjust Enrichment) (Violation of Bus. & Prof. Code §17200 et seq.) 40. Plaintiff brings this action on ...
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279,393
21. Tidal was originally launched in 2014 as a high fidelity music-streaming platform by a company named Aspiro. 22. Soon thereafter, Project Panther BidCo Ltd., a holding company created by Defendant SCE (which is controlled by Jay Z) acquired Aspiro.6 50. Plaintiff Baker-Rhett is a fan of Defendant Kanye We...
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250,324
13. Slice markets to consumers using the names of the pizzerias in its network, and encourages consumers to place orders to these local pizzeria through the Slice app or website. 15. The pizzerias that join Slice’s network do not maintain control or ownership over the VOIP phone number that Slice assigns to them,...
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146,378
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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435,551
19. INCR provides Phase I to Phase IV clinical development services to pharmaceutical, biotechnology and medical device companies. Materially False and Misleading Statements Issued During the Class Period 30. Plaintiff brings this action as a class action pursuant to Federal Rule of Civil Procedure 23(a) and (...
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211,249
12. 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 the Defendant attempting to collect an obligation owed to or allegedly ...
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302,057
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 solicit its services. 23. Plaintiff brings this action individually and on behalf of all others similarly situated, as a member the four proposed classes (hereafter, jointly, ...
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165,833
39. Representative Plaintiffs Brazile, Mote, and Motes bring this action against Defendant PRCA under Rule 23(a) and (b)(2) of the Federal Rules of Civil Procedure on behalf of all members of the following Class (collectively, the “Class”): “All present and future professional rodeo athletes who are or will be an ...
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241,856
11. TracFone is a provider of cellular telephones and cellular telephone services. 12. According to TracFone’s User Agreement, through its SafeLink brand, Defendant purports to offer those who meet certain income-based eligibility requirements a cellular telephone provided by TracFone together with a certain al...
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278,851
1. Certify the proposed Classes under Federal Rule of Procedure 23 and appoint Ms. Munroe and her counsel to represent the Classes; 10. Award the FCRA Class costs and reasonable attorneys’ fees pursuant to 15 U.S.C. § 1681n(a)(3); and 11. Grant such other further relief as is necessary and proper. Jury Demand...
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18,646
36. Plaintiffs bring this action as a class action pursuant to Rule 23 of the Federal Rules of Civil Procedure on behalf of the following class: All persons or entities in the United States who made retail purchases of Products during the applicable limitations period, and/or such subclasses as the Court may deem ...
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223,787
16. Plaintiff re-states, re-alleges, and incorporates herein by reference. paragraphs one (I) through fifteen ( 15) as if set forth fully in this cause of action. 17. This cause of action is brought on behalf of Plaintiff and the members of a class. 18. The class consists of all persons whom Defendant's records...
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171,409
ALLEGATIONS 13. On a date or dates unknown to Plaintiff, Plaintiff incurred a financial obligation, namely a consumer credit account issued by Wells Fargo Bank, N.A. (hereinafter “the debt”). The debt was incurred primarily for personal, family, or household purposes (e.g. purchase of clothing, groceries, gasoli...
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34,819
88.Title XIX of the Social Security Act establishes the federal-state Medicaid program. See 42 U.S.C. §§1396–1396w-5. The purpose of Medicaid is to furnish, as far as practicable, “medical assistance on behalf of . . . aged, blind or disabled individuals, whose income and resources are insufficient to meet the costs of...
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410,907
19. The Class Period begins on May 12, 2014. On that day, Kandi filed with the SEC its Quarterly Report on Form 10-Q for the quarter ended March 31, 2014, providing the Company’s consolidated financial results for that period. 20. The Company’s May 12, 2014 10-Q also summarized the Company’s investment in the ...
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270,509
(Cal. Bus. & Prof. Code § 17200, et seq.) 20. The spread of COVID-19 was declared a pandemic by the World Health Organization (“WHO”) on March 11, 2020. 21. On March 13, 2020, President Donald Trump issued the Coronavirus Disease 2019 (COVID-19) Emergency Declaration, which declared that the pandemic was of “s...
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67,878
10. naviHealth, Inc. manages post-acute care and care transitions on behalf of health plans, hospitals, health systems, and post-acute providers in the United States. It offers clinical service support, proprietary technology, and advisory solutions for payers and providers. The company provides clinical support se...
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243,652
12. Upon information and belief, Plaintiff asserts the following Factual Allegations, which in addition to other facts, support Plaintiff’s causes of action set out herein. 14. Beginning in or around April 2016, Defendant called Plaintiff on her cellular telephone number ending in “1651” using an automatic diali...
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96,275
23. GPB Capital was formed in March 2013 by David Gentile. 25. GPB Capital claims to have invested, through its funds, in automotive dealerships and waste management companies, among other businesses. 26. GPB Capital investments, including in GPB Holdings II and GPB Automotive, are illiquid, high-commission a...
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436,203
2. Whether Defendant accepts guide dogs and, if so, if there are any charges associated with the guide dogs, their policies with respect to guide dogs and if there are any rest areas for guide dogs. 26. Defendant’s Website offers features to the public that should allow all consumers to access the facilities and ...
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296,611
10. Defendant contacted or attempted to contact Plaintiff from a telephone number confirmed to be Defendant’s number. 11. Defendant’s calls constituted calls that were not for emergency purposes as defined by 47 U.S.C. § 227(b)(1)(A). 20. Plaintiff brings this action individually and on behalf of all others s...
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321,129
19. Sundance operates as a travel company. On its website, Sundance claims to have encouraged tens of thousands of clients to explore, dream and discover. 20. Unfortunately for consumers, Sundance utilizes a sophisticated telephone dialing system to call consumers with pre-recorded messages en masse promoting its se...
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345,730
Defendant. § § § § § § § § § CASE NO.: 5:17-cv-00081-DAE 10. Defendant lacks information or knowledge sufficient to form a belief about the truth of Paragraph 10. Therefore, Defendant denies Paragraph 10. 11. Defendant lacks information or knowledge sufficient to form a belief about the truth of P...
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420,192
10. The 2015 FCC Order also clarified that telephone calls and text messages have the same protections under FCC rules, and that text messages are “calls” for purposes of the 38. Plaintiff brings this action as a class action pursuant to Fed. R. Civ. P. 23(b)(2) & (b)(3) on behalf of herself, on behalf of all othe...
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132,241
22. A prospective student or graduate who is interested in initiating or consolidating his or her student loans has hundreds of lenders in the nation to choose from. Although the original interest rates on federal consolidation loans are set by statute, lenders are free to, and often do, compete for graduates’ bus...
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