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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
446,957
23.Defendants operate TT locations throughout the United States, specifically in Georgia, North Carolina, South Carolina and Texas. 24.Defendant, TT provides lawn care, tree and shrub maintenance and pest control services to its residential and commercial clients. 25.Plaintiff was employed by Defendants as a non-exem...
win
58,796
14. GoPro claims that it is “maker of the world’s most versatile and durable cameras” and that the Hero3 “makes it possible to capture and share your life like never before.” 15. Notwithstanding such claims, the Hero3 does not work properly or as advertised, and it is not suitable for the ordinary purposes for wh...
lose
163,693
18. Sometime before January 8, 2018, Plaintiff incurred certain financial obligations to Defendant. 19. These alleged obligations were money, property, or their equivalent, which were due or owing, or alleged to be due or owing, from a natural person to another person and are therefore a “debt” as that term is def...
win
242,778
15. In October, 2012, Ms. Osterholt began taking classes at CorePower’s studio located at 3232 North Lincoln Ave., Chicago, IL 60657. Through her practice at CorePower, a CorePower employee recruited her to become an instructor and enroll in Corepower’s 200-Hour Teacher Training Program. 16. Ms. Osterholt paid C...
win
431,799
19. Defendants operate a restaurant and catering business in Tyler, Texas. The restaurant is called Traditions. 20. In the year 2015, Traditions had annual gross receipts in excess of $500,000 (exclusive of excise taxes). 21. In the year 2016, Traditions had annual gross receipts in excess of $500,000 (excl...
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115,440
44. Defendant Tilchin advertises its firm as being legal experts in all aspects of condominium and association law including a speciality in real estate: Right Legal Advice for Your Condominium and HOA Issues When you need legal advice and counseling for your condominium, HOA or Co-op trust that the legal experts...
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104,733
51. On January 27, 2017, Defendant Trump signed the Executive Order entitled, “Protecting the Nation from Foreign Terrorist Entry into the United States.” A copy of this Executive Order is attached to this Complaint as Exhibit A. 52. The Executive Order cites the threat of domestic terrorism committed by foreign ...
win
271,569
58. Plaintiffs reallege and incorporate by reference all allegations in all preceding paragraphs. 60. Defendants employ Exotic Dancers and Drink Serving Dancers at their aforementioned locations. 61. “Exotic Dancers” refers to individuals who worked for Defendants as exotic dancers, were treated as independen...
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319,520
16. MKC has conducted manufacturing operations at the Facility for many decades, dating back at least until 1967. 17. Various hazardous substances, including tetrachloroethylene (“PCE”) and trichloroethylene (“TCE”), known human carcinogens, were used at the Facility during MKC’s ownership and operation of the Facilit...
win
63,854
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 Capital sent a collection letter attempting to collect a consumer debt; c. that uses the ter...
win
186,376
14. In 1988, members of the United States Senate warned that records of consumers’ purchases and rentals of audiovisual and publication materials offer “a window into our loves, likes, and dislikes,” and that “the trail of information generated by every transaction that is now recorded and stored in sophisticated ...
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48,766
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
261,195
14. The instant action arises out of Defendants’ attempts to collect upon an outstanding obligation (“subject debt”) Plaintiff is said to owe to Cumberland. 15. The subject debt arose in connection with purchases made at Cumberland. 16. Upon information and belief, after Plaintiff’s purported default on the subjec...
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341,481
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
8,912
25. Defendant embarked upon an intrusive telemarketing campaign to promote its car insurance services. 26. Specifically, on numerous dates, including May 14, 2018, Defendant placed, or caused to be placed, an automated text message to Plaintiff’s cellular telephone number ending in 1818 (“1818 Number”): 28. D...
win
251,411
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...
lose
175,418
12. Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 14. The identities of all class members are readily ascertainable from the records of Defendants and those companies and entities on whose behalf they attempt to collect and/or have purchased debts. ...
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116,953
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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146,007
1. Meet and Greet 10. If Massage Envy did not intend to mislead consumers about the actual length of the massage, it would simply tell them the truth about it, clearly and conspicuously, beginning with its offer of a one-hour massage session on the home page of its website and continuing throughout its communic...
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178,662
15. On April 10, 2015, Party City filed its eighth amendment to the Registration Statement on Form S-1/A with the SEC, which was signed by Defendants Correale and Harrison. 16. On April 15, 2015, the SEC declared Party City’s Registration Statement effective. 17. On April 17, 2015, Party City filed the Prospect...
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147,310
26. Consumers have become increasingly concerned about the effects of synthetics and chemical ingredients in cosmetic products. As a result, consumers are willing to pay, and have paid, a premium for products labeled “natural” over ordinary products that contain synthetic ingredients. 38. Plaintiff Meyers ...
win
208,576
56. This Action is brought on behalf of Plaintiffs and the class members under the FDCPA, MOC and RCPA with the class made up of the following class consumers: All persons against whom Defendants filed a STATE COLLECTION COMPLAINT and/or obtained a settlement, default or default judgment or judgment related to the ...
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226,298
21. Defendant is a ticket retailer that markets and sells tickets for entertainment venues and events, and owns and operates the website, www.entertainment-link.com, offering features which should allow all consumers to access the goods and services and which Defendant ensures the delivery of such goods throughout ...
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106,617
16. Definition of Class. J.R. proposes the following class: All individuals who: (a) have been, are, or will be participants or beneficiaries under Catholic Health Initiatives Medical Plan in effect or renewed on or after August 10, 2012 and/or the relevant limitations period; and (b) have received, require, or...
win
256,560
40. Plaintiffs incorporate by reference all of the above paragraphs of this Complaint as though fully stated herein. 44. Plaintiffs incorporate by reference all of the above paragraphs of this Complaint as though fully stated herein. 45. Sirius’ made repeated telephone calls to Plaintiffs’ cellular telephones ...
win
440,453
10. Furthermore, as explained by the Federal Communications Commission (“FCC”) in its 2012 order, the TCPA requires “prior express written consent for all autodialed or prerecorded telemarketing calls to wireless numbers and residential lines.” In the Matter of Rules and Regulations Implementing the Telephone Consu...
win
263,110
1. Warren is a resident of the State of Indiana, and is domiciled in Plymouth, Marshall County, Indiana. 10. Warren is specifically alleging that Oasis has taken illegal deductions in violation of the Indiana Wage Assignment Statute, I.C. 22-2-6-2, and in so doing, Oasis has failed and refused to pay Warren and ...
win
41,237
(Declaratory Relief) 24 111. Plaintiff repeats, realleges and incorporates by reference the allegations contained in paragraphs 1 through 110 of this Complaint as though set forth at length herein. 112. An actual controversy has arisen and now exists between the parties in that Plaintiff contends, and is informed ...
win
109,000
13. Many federal and state consumer protection and labeling laws prohibit deceptive packaging and labeling of products and commodities. In California, the Fair Packaging and Labeling Act (“CFPLA”) “is designed to protect purchasers of any commodity within its provisions against deception or misrepresentation. Pack...
win
305,938
18. Pursuant to 29 U.S.C. §§ 206, 207 & 2 l 6(b), plaintiff brings her first and second causes of action as a collective action under the FLSA on behalf of herself and the following collective: All persons employed by defendants at any time since June 1, 2015 and through the entry of judgment in this case (the “co...
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198,344
23. Defendant owns, operates and/or controls its retail stores, sells store gift cards to the public, and uses them as a form of communication. One or more of its retail stores is located in New York City. Defendant’s retail stores constitute places of public accommodation. Defendant’s retail stores provide importa...
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241,976
73. Plaintiff brings this action as a class action pursuant to Federal Rule of Procedure 23(b)(2) and 23(b)(3) on behalf of the following “class:” All persons in the United States since May 4, 2008 who purchased Eskimo Pie Dark Chocolate with labels that state “No Sugar Added.” 74. The following persons are ex...
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350,148
34. Plaintiffs Hutto and Melnyk completed Defendants’ standard electronic documents relating to their anticipated employment, including an electronic authorization to conduct a background check. 35. Defendants’ online authorization causes a background check to be procured by a third-party company. 3...
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331,304
1.5 times the regular hourly rate for all hours worked over 40 in a week. 13. As healthcare information technology firm, Defendant provides training and support to healthcare facilities in connection with the implementation of new electronic recordkeeping systems. 14. Defendant employs consultants, such as Dys...
win
203,961
12. Defendant Hertz, through its subsidiaries, engages in the car and equipment rental businesses worldwide. As of November 2012, Hertz was the second-largest U.S. car rental company by sales. The Company operates in two segments, Car Rental and Equipment Rental. Hertz also offers claims administration services...
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254,108
(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 New York State Human Rights Law, N.Y. Exec. Law, Article 15 (Executive Law § 292 et seq.) (on behalf of Plaintiff and New York Subclass) (Violation of 42 ...
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143,925
25. On or about August 11, 2018, Defendant caused the following automated text message to be transmitted to Plaintiff’s cellular telephone number ending in 9808 (“9808 Number”): 27. The Website provides marketing information such as the “benefits of cannabidiol” and contains a “RUSH MY ORDER NOW” and “GET MY BOTT...
win
348,301
10. Defendants’ account transfer and lead distribution policies and practices disproportionately steer lucrative business opportunities to FSRs who are not African American. Likewise, “orphaned” accounts are routinely steered disproportionately to non-African American FSRs. 11. Further, Defendants allow certain FSRs t...
win
59,851
(FLSA Violations Prior To January Of 2018) (Plaintiff John Kreischer’s Employment With Defendants) 120. Wastebuilt Defendants employed Kreischer as a Piece Rate Employee from December of 2013 through December 31, 2017. 121. Kreischer left his employment with Wastebuilt Defendants in or around May or June of 201...
win
370,486
1. JADWIGA NOWAK ("Plaintiff') is a natural person, over 18-years-of-age, who at all times relevant resided at 2617 North Monitor Avenue, Chicago, Illinois 60639. 2. Plaintiff is a "consumer" as defined by 15 U.S.C. § 1692a(3). 2021CH03714 JADWIGA NOWAK, individually, and on behalf of all others similarly situated...
win
123,034
65. Plaintiff incorporates the foregoing paragraphs as though the same were set forth at length herein. 66. Defendant is a “person” and “consumer reporting agency” as defined by sections 1681a(b) and (f) of the FCRA. 67. Plaintiff is a “consumer” as defined by section 1681a(c) of the FCRA. 68. The above-me...
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69,971
14. Defendant’s labeling and advertising scheme is deliberately intended to give consumers the false impression that the Products are composed only of natural flavors and “no artificial colors or flavors.” 58. Plaintiff brings this action on behalf of herself and all others similarly situated (the “Class”) pursu...
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40,136
1. The amount of the debt; 1. where the letter: a. states that there are multiple creditors; b. without stating the amount owed to each individual creditor; 11. Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 12. The Class consists of all individ...
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181,587
11. On December 1, 2010, sections 17600-17606 of the Cal. Bus. & Prof. Code came into effect. The Legislature’s stated intent for this Article was to end the practice of ongoing charges to consumers’ Payment Methods without consumers’ explicit consent for ongoing shipments of a product or ongoing deliveries of ser...
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447,013
10. Defendant alleges Plaintiff owes a debt (“the Debt”). 11. The Debt was primarily for personal, family or household purposes and is therefore a “debt” as defined by 15 U.S.C. § 1692a(5). 12. Sometime after the incurrence of the Debt, Plaintiff fell behind on payments owed. 13. Thereafter, at an exact ...
win
182,358
51. Plaintiff brings this case as a class action pursuant to Fed. R. Civ. P. 23, on behalf of himself and all others similarly situated. 62. Plaintiff re-alleges and incorporates the foregoing allegations as if fully set forth herein. 63. It is a violation of the TCPA to make “any call (other than a call made...
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443,248
29. Plaintiff brings this action on behalf of itself and as a class action under the provisions of Rule 23(a), (b)(2) and (b)(3) of the Federal Rules of Civil Procedure on behalf of the members of the following Class: All persons who purchased Containerboard Products directly from any of the Defendants or their subsidi...
win
49,162
90. Plaintiff incorporates by reference and realleges each and every allegation set forth above, as though fully set forth herein. 91. The Individual Defendants owed and owe Alibaba fiduciary obligations. By reason of their fiduciary relationships, the Individual Defendants owed and owe Alibaba the highest obli...
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252,758
10. Advantage employs CDMs, including the Plaintiff, to be responsible for inventory and advertising display within as many as 45 assigned retail stores within a designated geographic region. 11. The CDMs are organized into teams that are singularly focused on a manufacturer and/or class of trade, such as groce...
win
96,174
37. The Subaru Impreza is a compact family car that was first manufactured in 1992 and is now in its fifth generation of manufacturing. 38. Subaru also manufactures a “WRX” (short for world rally) version of the Impreza which features increased performance over the standard Impreza. 39. Subaru has and contin...
win
253,688
(Alleging FLSA Violations) 11. Defendant is a “T-Mobile Premium Retailer” that according to the Employee Handbook it provided to Plaintiff, “is guided by a relentless focus to build a company that will be the leader in the wireless industry for T-Mobile products.” 12. According to its website, Defendant operat...
win
130,121
23. Pursuant to 29 U.S.C. § 207, Plaintiff seeks to prosecute her FLSA claim as a collective action on behalf of herself and others who currently work or formerly worked as Home Health Aides for VNSNY (the “Collective Action Members”) who worked a 24-hour shift at any time during the 3-year period immediately prece...
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149,619
12. Plaintiff brings 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 employees (including cooks, line-cooks, food preparers, dishwashers, cleaning persons, waiters, busboys, runners, bartenders, barbacks and hostesses) employed by ...
win
392,658
12. Defendant PLANNERNET acts as a temporary staffing agency that provides its clients with attendee personnel for seminars, conferences, symposia, trade shows, corporate meetings, and dinners at various events throughout the United States and in California (hereinafter “Client Events.”). PLANNERNET Client Events r...
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206,483
17. At all times relevant, Plaintiff is and was an individual residing in the County of San Diego, within the State of California. 18. Upon information and belief, at all times relevant, Defendant conducted business in the State of California. 19. Sometime prior to April of 2017, Plaintiff allegedly incurred...
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157,079
10. Which is why Hardee Jr. teaches his agents what he calls the “Mojo system,” named after the Mojo Dialer, a web-based based autodialer that provides “Automated multi-line power dialing up to 300 calls per hour.”3 13. By placing the unsolicited telephone calls at issue in this Complaint, Defendant caused Pla...
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381,677
CREF SOCIAL CHOICE ACCOUNT; TIAA GLOBAL PUBLIC INVESTMENTS, MBS LLC; TIAA-CREF DURATION CORPORATE BOND PORTFOLIO; PIMCO FUNDS: PRIVATE ACCOUNT PORTFOLIO SERIES DUTY OF INDEPENDENCE (In The Right Of The Trustee And On Behalf Of The Trusts Against HSBC) ................................................................
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362,676
11. In addition, RPI alleges HSBC discovered and knew of numerous loan servicer events of default (“Events of Default”) committed by the loan Servicers or Master Servicers (collectively “Servicers”) under the Governing Agreements, but failed to give notice and cure those Events of Default. HSBC also willfully fail...
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41,397
(Breach of Contract) 208. Plaintiffs repeat and reallege each and every allegation of the preceding paragraphs hereof with the same force and effect as though fully set forth herein. 209. Plaintiffs and members of the Class entered into employment contracts with Defendants. 210. Plaintiffs and members of the Cl...
win
193,890
66. Martinez, individually and on behalf of the Collective Class Members, incorporates the preceding paragraphs herein as though set forth at length. 67. Under the FLSA, an employer is “any person acting directly or indirectly in the interest of an employer in relation to an employee […] or anyone acting in the c...
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214,340
55. Plaintiff brings this action on behalf of himself and all similarly situated current and former drivers, namely, all other individuals who have performed courier and/or delivery services for the Defendants and/or their parent organizations, successors and assigns within Massachusetts, and who were not paid prop...
win
107,638
(CAL. CIV. CODE § 1750, ET SEQ.) ................................................................................... 23  THIRD CAUSE OF ACTION VIOLATIONS OF THE FALSE ADVERTSING LAW (CAL. BUS. & PROF CODE §§ 17500, ET SEQ.) .................................................................................... 26  16. ...
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156,234
(Conversion – On behalf of Plaintiffs and the Subclasses) (For Violations of CUTPA (Conn. Gen. Stat. §§ 42-110a, et seq.) – On behalf of Plaintiff Vasquez and the CUTPA Class)7 (For Violations of the Electronic Funds Transfer Act – On Behalf of Plaintiffs and the Subclasses) (Money Had and Received – On behalf ...
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329,523
25. On or about July 12, 2018, Defendant called Plaintiff’s cellular telephone number ending in 6305 (“6305 Number”) with a pre-recorded message. 26. Upon Plaintiff answering the phone, a pre-recorded message asked Plaintiff to press 1 if he was interested in purchasing insurance. 27. After Plaintiff pressed ...
win
282,933
16. Plaintiff brings 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 tipped employees, including bartenders, barbacks, waiters, runners, bussers and delivery persons, employed by Defendants on or after the date that is six years before the fil...
win
73,663
Violation of the Availability Requirement of the Medicaid Act 200. Plaintiffs repeat and re-allege Paragraphs 1-199 as if set forth fully herein. 201. As set forth above, Defendants have failed to provide Plaintiffs with the available assistance that is medically necessary and that they have requested. Defendants’...
win
385,822
11. On or about March 10, 2010, Defendants transmitted by telephone facsimile machine an unsolicited fax to Plaintiff. A copy of the facsimile is attached hereto as Exhibit A. 12. Defendants created or made Exhibit A which Defendants knew or should have known is a good or product which Defendants intended to and...
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211,951
17. Plaintiffs bring this action as a class action pursuant to Rule 23 of the Federal Rules of Civil Procedure on behalf of the following defined class: Each and every person who has worked for Defendants in the United States as an outside salesperson at any time within three (3) years prior to the filing of thi...
win
301,598
UNJUST ENRICHMENT (Pled in the Alternative) (Brought on behalf of Plaintiff) 26. The claims in this Complaint arising out of the FLSA are brought by Plaintiff on behalf of himself and other similarly asbestos removers who are current and former employees of NSC since the date three years prior to the filing of...
win
224,489
CIVIL DIVISION GINA SIGNOR, individually and on behalf of all those similarly situated, Plaintiff, CIVIL DIVISION GINA SIGNOR, individually and on behalf of all those similarly situated, Plaintiff, I,, SHIPPED TO DEALER VEHICLE MANUFACTURED AND
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445,604
19. On or about December 24, 2015, Defendant sent a written communication to Plaintiff in connection with the collection of the Debt. A true and correct copy of the relevant page of the December 24, 2015 communication is attached hereto as Exhibit A. 20. The December 24, 2015 communication was the first communic...
win
168,876
29. Plaintiff brings suit on behalf of herself and on behalf of all other participants and beneficiaries similarly situated under the provisions of Rule 23 of the Federal Rules of Civil Procedure with respect to violations alleged herein. 30. The proposed Class is defined as follows: All persons who participated in ...
win
428,765
19. Mr. and Ms. Lewis moved into the Complex in March 2007. It was the first home that they had purchased together. 20. They chose to purchase in the Complex because it appeared to be a nice place to raise children, it was close to their immediate family, and Mrs. Lewis was expecting their first child. Sho...
win
451,975
20. Plaintiff brings this action as a class action on behalf of himself and the other public stockholders of U.S. Geothermal (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. 21. This action is prope...
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8,359
15. Defendant, DAVID MANDELL, actively participates in the day-to-day operation of KEY FOOD. For instance, he is responsible for the facilities management of at least five (5) of Key Food supermarket locations. As such, he supervises and directs the work of the employees, including individual store managers, to ens...
win
66,349
26. USO is a commodity pool and ETF designed to allow investors to gain exposure to fluctuations in the price of oil. Because most retail investors are not equipped to buy and sell barrels of oil or authorized to trade oil futures contracts, they utilize ETFs such as USO to make investments based on the price of o...
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8,095
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 contains the following text: Exhibit A. 12. Exhibit A falsely states that the settlement payment “must be received on or before 08/29/13.” 14...
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44,302
29. Plaintiff brings this action individually and as a class action pursuant to Federal Rule of Civil Procedure 23 on behalf of all public holders of Interactive common stock who are being and will be harmed by defendants’ actions described below (the “Class”). Excluded from the Class are defendants herein and any...
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29,958
Defendant. ======================================= CLASS ACTION COMPLAINT Introduction 1) Plaintiff Tova Hartman files this Complaint seeking redress for the illegal practices of Defendant First Step Group, LLC who, inter alia, used false, deceptive, and misleading practices, and other illegal practices, in con...
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440,894
10. The Big 3 consumer reporting agencies—Experian, Equifax, and Trans Union— regularly receive information from various sources around the country including banks, credit unions, automobile dealers, student loan providers, public information vendors, the Social Security Administration, and other furnishers. 11. ...
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292,123
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 Ohio; b. to whom Defendant sent a collection letter attempting to collect a consumer debt; c. regarding collection of a d...
win
85,778
14. Beginning on or about September 15, 2017, Plaintiff began receiving text messages from Defendant on his cellular telephone number ending in -7558. 26. Plaintiff brings this action on behalf of himself and on behalf of and all others similarly situated (“the Class”). 27. Plaintiff represents, and is a memb...
win
207,942
25. Defendant operates multiple kiosks throughout the United States, including its kiosk located at 8401 Park Meadows Center Dr. Littleton, CO 80124. 26. Defendant offers its Website in connection with its physical locations. The goods and services offered by Defendant through its Website include but are not limi...
win
105,760
11. Hall was a Trican employed as an Equipment Operator and was paid on an hourly basis. 12. Trican is an independent oilfield services contractor that provides various specialized products, equipment, services and technology for use in the drilling, completion, stimulation and reworking of oil and gas wells in ...
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404,950
34. To provide an incentive for foreign investment to benefit the American economy by creating or preserving U.S. jobs, Congress created the EB-5 Immigrant Investor Visa Program (the “EB-5 Program”) in 1990 with the enactment of the Immigration Act of 1990. Pub. L. 101- 649, 104 Stat. 4978. The EB-5 Program enabled ...
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22,823
1. The amount of the debt; 10. Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 12. The identities of all class members are readily ascertainable from the records of Defendants and those companies and entities on whose behalf they attempt to collect a...
win
321,663
(Collective Action Claim for Violations of the FLSA) (Individual Claims for Violation of the FLSA) (Individual Claims for Violation of the AMWA) 31. Plaintiffs repeat and re-allege all the preceding paragraphs of this Original Complaint as if fully set forth in this section. 32. At all times relevant hereto,...
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158,338
XIII.  CAUSES OF ACTION ................................................................................................................... 18  First Cause of Action ...................................................................................................................... 18  Second Cause of Action ...........
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389,244
26. Defendant owns and operates a telecommunication company that specializes in selling minutes for overseas phone calls. 28. Plaintiff himself was sent at least two marketing text messages without his express written consent. 29. Below is a depiction of an actual text message received by Plaintiff from Defen...
win
143,642
14. Plaintiff brings this action as a class action, pursuant to Rule 23 of the Federal Rules of Civil Procedure (hereinafter “FRCP”), on behalf of himself and all consumers and their successors in interest (the “Class”), who were sent debt collection letters and/or notices from the Defendants which are in violation...
win
31,207
24. Defendants employ exotic dancers and have employed hundreds of dancers over the years at The Club. 25. Plaintiff Smith was previously employed as an exotic dancer at Defendants’ adult entertainment club during the statutory time period. 26. Plaintiff Smith worked on a regular basis for Defendants’ establis...
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346,489
10. Plaintiff then received a letter dated October 5, 2015 from RTR, attached as Exhibit A, attempting to collect $237.00 allegedly due based on the Citation (the “October 5 Letter”). 11. The October 5 Letter stated, in pertinent part: Dear ALIZA D LEVI: 3 Please be advised that the Nassau County Traffic and Par...
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195,199
27. 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
277,424
(Invasion of Privacy and Wrongful Intrusion upon the Seclusion and Solitude of the Plaintiff) (Negligent Violations of the Telephone Consumer Protection Act 47 U.S.C. § 227 et seq.) (Violations of the Fair Debt Collection Practices Act 15 U.S.C. § 1692 et seq.) (Willful Violations of the Telephone Consumer Pro...
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254,176
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
254,756
10. CCA-Leavenworth’s phone and videoconference services are provided by Securus. Securus charges families and others a fee for speaking to a detainee. It shares those proceeds with CCA-Leavenworth, which creates profit for both entities. 11. Plaintiffs were detained through a Pretrial Order of Detention issued ...
win
268,645
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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228,584
15. On or about January 16, 2014 at 12:44 pm, Defendant or its agent/s began contacting Plaintiff Martinez on Plaintiff Martinez’s cellular telephone number ending in 5779 via an automatic telephone dialing system (“ATDS”) as defined by 47 U.S.C. § 227(a)(1) using an “artificial or prerecorded voice” as prohibited ...
win
14,452
33. Defendants are in the business of home elevation, foundation repair, and general construction for commercial and residential projects in Louisiana. Defendants’ services include home elevation, general construction, carpentry, bricklaying, sheet rocking, and installing doors, windows, and flooring. 34. Defe...
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