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(Plaintiff Ceballos and the Tennessee Class against All Defendants except Javier Martinez Drywall and Javier Martinez) 176. Plaintiffs incorporate by reference all previous paragraphs of this Complaint. 177. There is no legally enforceable express contract between the parties. 178. Plaintiff Ceballos and the T...
win
13,609
15. On or about September 12, 2019, Plaintiff received medical services from New York Presbyterian Hospital. 16. Thereafter, New York Presbyterian Hospital claimed Plaintiff incurred a debt of $75.00 for the medical services (“the alleged Debt”). 17. The alleged Debt is a “debt” as that term is defined by 15...
win
114,968
14. Throughout the relevant time period, CSRs were employed by Defendant at their Dallas, Texas Customer Service Department. 50. Plaintiff seeks to bring this suit as a collective action pursuant to 29 U.S.C. § 216(b) on her own behalf as well as those in the following collective: All persons employed by Defend...
lose
422,760
(FLSA Overtime Violations, 29 U.S.C. § 201, et seq. Brought by Plaintiff on Behalf of Himself, the FLSA Collective Plaintiffs and Class Members) (New York Overtime Violations, New York Labor Law § 650 et seq., N.Y.C.C.R. § 142 et seq., N.Y.C.C.R. § 146 et seq., Brought by Plaintiff, the FLSA Collective Plaintiff...
win
189,772
68. Plaintiff brings the First Claim against defendants as a collective action pursuant to the FLSA, 29 U.S.C. § 216(b) on behalf of himself and other similarly situated individuals, which include all car wash workers employed by defendants at the Car Washes at any time three years prior to the filing of this actio...
win
62,425
47. Defendants undertake residential and commercial construction projects in Louisiana. Defendant’ services include construction, carpentry, remodeling and renovations. Defendants employ more than 30 employees at any one time. 49. Defendants paid Plaintiffs by check. 50. Plaintiffs normally worked more th...
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422,692
10. Neuro-Psychology Associates describes the services it provides to patients utilizing the Current Procedural Terminology (“CPT”) code set developed and maintained by the American Medical Association and used to facilitate communication and reporting between health care providers and health care payors like CIGNA...
win
434,340
38. POSTMATES manufactures, distributes, markets, advertises, and sells the Service, which claims to be able to (1) deliver “Anything. Anytime. Anywhere.” when in fact, it is not, because the Service will not deliver anything, anytime, anywhere, and (2) allow use of their Service for a set “Delivery Fee”, but whose ...
lose
102,880
(Fair Labor Standards Act Violations) Case: 1:19-cv-01025-TSB Doc #: 1 Filed: 12/03/19 Page: 8 of 11 PAGEID #: 8 (Violations of Ohio Revised Code 4111.03 and Article II, § 34A of the Ohio Constitution) 14. Defendant operates call centers throughout the United States. 15. Defendant also employs call center/...
win
141,125
10. Benzon brings this claim under the FLSA as a collective action. 11. The members of the FLSA Class are similarly situated in all relevant respects. While their precise job duties might vary somewhat, these differences don’t matter for the purposes of determining their entitlement to overtime. They are all enti...
win
73,672
23. Defendant is an airline company that employs more than 47,000 workers. 25. Plaintiff worked in Defendant’s customer service call center in Albuquerque, New Mexico along with approximately 500 other customer service representatives. 26. Plaintiff’s primary duty was to communicate with customers to book...
win
73,437
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
328,868
1. Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 10. 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. Th...
win
322,559
28. Plaintiff is alleged to have incurred and defaulted on a financial obligation to “Automobile Club.” (“Automobile Club Obligation”). 29. The Automobile Club Obligation arose out of a transaction in which the money, property, insurance, or services that were the subject of the transaction were primarily for per...
win
374,004
21. Sometime prior to June 11, 2012, Plaintiff allegedly incurred a financial obligation to Citibank/Sears, (“Sears Obligation”). 22. The Sears Obligation is alleged to have arisen out of a transaction in which the money, property, insurance, or services which are the subject of the transaction are primarily for pe...
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424,350
16. Defendants regularly serve the needs of restaurants and other business owners by selling bulk supplies and equipment. 49. Pursuant to Rules 23(a), (b)(3) and/or (b)(2) of the Federal Rules of Civil Procedure, Plaintiff brings this action on behalf of himself and a nationwide class (“Class”), initially defi...
win
135,637
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”): • Plaintiff brings this action individually and as a class action on behalf of all persons similarly situated in the State of New York ...
win
308,864
36. Plaintiff realleges and incorporates by reference all allegations in all preceding paragraphs. 37. At all material times, Plaintiff and the Collective Members, in their work for Defendants, were employed by an enterprise engaged in commerce that had annual gross sales of at least $500,000. 38. At all mate...
win
410,343
23. Defendants develop, manufacture, market, distribute and sell a line of joint supplements under the Osteo Bi-Flex brand name. These Products include: (1) Osteo Bi- Flex One Per Day; (2) Osteo Bi-Flex Triple Strength; (3) Osteo Bi-Flex Double Strength; (4) Osteo Bi-Flex Triple Strength with Vitamin D; (5) Osteo B...
win
77,905
102. Plaintiff brings this action individually and as a class action on behalf of all consumers similarly situated in Nassau County, New York. 103. Plaintiff seeks to certify a class of: i. All consumers where Arrowood sent information concerning the consumer’s debt to a third party without obtaining the prior co...
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245,252
20. Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47 U.S.C. § 153(39). 21. On or around September 20, 2010, Plaintiff’s wife, Lisa Jefferson, financed her vehicle with AmeriCredit. Lisa Jefferson provided neither her cellular telephone number nor Plaintiff’s cellular telephone ...
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85,539
54. This class action is brought on behalf of all persons who bought or leased a Class Vehicle in the United States. 55. The Class Vehicles at issue in this action include all BMW vehicles equipped with a Navigation System containing the ARRTI feature. The Class Vehicles ’ Navigation System is Defective. 56...
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361,836
24. Plaintiff Murphy visited Defendant’s facilities located at Youngfield Street in Wheat Ridge, Colorado, where he experienced unnecessary difficulty and risk due to excessive slopes in a purportedly accessible parking area. As a result of Defendant’s non-compliance with the ADA, Plaintiff Murphy’s ability to acce...
win
388,899
(California Penal Code § 496(c)) (Class Action Claim) 188. AdTrader hereby re-incorporates and re-alleges all the preceding paragraphs as if fully set forth herein. 189. Under California law, a party may bring a private right of action against a defendant that fraudulently obtains that party’s property (includin...
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126,022
15. Defendant alleges Plaintiff owes a debt (“the alleged Debt”). 16. The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of a transaction in which the money, property, insurance, or services which are the subject of the transaction are primarily for personal, family, or household purp...
win
149,635
1. whether Defendant Monica Braverman obtained, re-disclosed, and/or resold Plaintiff and Class Member's personal information contained within motor vehicle records maintained by the State motor vehicle departments; 1. Lane v. Facebook, Inc., 696 F.3d 811, 821 (9thCir. 2012) cert. denied,13-136, 2013 WL 5878083(U...
win
20,948
(Knowing and/or Willful Violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227(b)(1)(A)) (Violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227(b)(1)(A)) 14. Pivotal Payments is a “leading provider of technology-driven global payment processing solutions for small to large enterprise...
win
303,406
15. Plaintiffs bring this action as a class action pursuant to Rule 23 of the Federal Rules of Civil Procedure on behalf of themselves and the class (the “Class”) defined as follows: All participants in and beneficiaries of the Franciscan Alliance Pension Security Plan (the “Plan”). Excluded from the Class are De...
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115,334
10. Plaintiffs bring this class action pursuant to Fed. R. Civ. P. 23(a) and (b)(3) on behalf of the following class of Nurses (the “Class”): All persons employed by Northern Manor as nurses from April 4, 2011 through the date a judgment is entered in this action. 4 11. Members of the Class are so numerous th...
win
192,109
20. Regardless of their specific job title, certification, or licensure, Named Plaintiff and similarly situated healthcare employees were hourly or non-exempt employees, and as such, were required to be paid overtime at one and one-half times their regular rate of pay. 21. Defendant has numerous pay policies tha...
win
215,466
22. Only licensed real estate brokers and salespersons can assist buyers and sellers with the purchase, sale, lease or exchange of real property. 23. To become licensed, an applicant generally must satisfactorily complete the agent curriculum in real estate education and pass a written examination. 24. A rea...
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166,238
(against all Defendants) Unjust Enrichment (against all Defendants) , Injunctive Relief (against all Defendants) Money Had and Received 22. Plaintiff brings this action as a class action pursuant to Florida Rule of Civil Procedure I .220(bX I ) and I .220(b)(2) on behalf of herself and all others similarly situated...
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324,139
19.   Plaintiff alleges that Equifax is familiar with credit reporting industry standards and subscribes thereto. 20.   Plaintiff alleges that Equifax understands that deviation from credit reporting industry standards can and often does result in denial of credit, higher interest rates, and prompts those making c...
win
65,946
19. Since 2001, Costco has distributed, marketed, and sold the Kirkland Signature™ line of dietary supplements. These products include: (1) Kirkland - 7 - Signature™ Extra Strength Glucosamine/Chondroitin Sulfate; and (2) Kirkland Signature™ Extra Strength Glucosamine HCL and MSM. 20. The Kirkland Glucosamine...
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378,475
11. At all times material to this action, defendants were an enterprise engaged in commerce or in the production of goods for commerce as defined by Section 203(s)(1) of the FLSA, and had annual gross volume of sales which exceeded $500,000. 12. Plaintiff has been employed by defendants within the last three year...
win
17,881
15. Originally founded in Hartford, Connecticut in 1853, Aetna is an American managed health care company that sells traditional, consumer directed health care and life insurance plans. Through its network of affiliates and subsidiaries throughout the United States, Aetna offers a range of insurance products includ...
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164,531
(Failure to compensate for minimum wage) (Failure to compensate for work performed “off the clock”) (Unpaid overtime compensation under the FLSA) 17. Plaintiff GUILLERMO MONTES, files this case as an “opt in” collective action, as it is specifically allowed by 29 U.S.C. § 216(b). 18. The class that Plaintiff...
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237,103
10. Within four years prior to the filing of this action, Defendants—whether directly, through affiliate marketers, or otherwise—used equipment to dial the residential and cellular telephone numbers of potential customers, including Kenzik. On information and belief, the dialing equipment used had the capacity to ...
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239,584
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
291,809
(Declaratory Relief) (on behalf of Plaintiff and the Class) 109. Plaintiff realleges and incorporates by reference the foregoing allegations as if set forth fully herein. 110. 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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410,455
15. At all times relevant, Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47 U.S.C. § 153(39). 16. Defendant sought to collect a debt that arose from a transaction incurred allegedly for personal, family or household purposes. 17. At all times relevant to this action, Plaintiff’s...
win
318,991
37. Plaintiffs bring this action on their behalf and as a class action pursuant to Rules 23(a) & (b)(3) of the Federal Rules of Civil Procedure on behalf of all persons or entities who purchased any “investment” offered by Defendants from May 6, 2006 until the present day (the “Class Period”) and who suffered damag...
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307,665
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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161,020
1. there is no explanation of the increase or note that the balance is increasing or will continue to increase; or 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: a. all individuals with addresses in the State of New ...
win
424,513
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 accessibilit...
win
367,648
(Violations of Section 20(a) of the Exchange Act Against The Individual Defendants) 17. On March 31, 2014, after the market closed, the Company filed a Form 40 F for the fiscal year ended December 31, 2013 (the “2013 40-F”) with the SEC, which provided the Company’s year-end financial results and position and stat...
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315,807
14. In the four year period preceding the filing of this action, WELLS FARGO, its predecessors in interest and/or vendors have made numerous telephone calls to Plaintiff's cellular telephone number, (404) 693-0147, in an attempt to collect a secured debt on a home equity line of credit. 15. The telephone calls w...
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38,602
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 May 4, 2021, an obligation was allegedly incurred to CF MEDICAL 33. Plaintiff brings this claim on b...
win
165,566
23. Defendant operates, manages, and markets its restaurants, sells store gift cards to the public, and uses them as a form of communication. One or more of its restaurants is located in New York City. Defendant’s restaurants constitute places of public accommodation. Defendant’s restaurants provide important goods...
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115,137
1. Plaintiff Richard Wade Architects, P.C., brings this action to secure redress for the actions of defendant Total Merchant Services, Inc., in sending or causing the sending of unsolicited advertisements to telephone facsimile machines in violation of the Telephone Consumer Protection Act, 47 U.S.C. §227 (“TCPA”), the...
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324,850
11. Numerous courts around the country have adopted the Miller safe harbor language to prevent this violation from continuing to occur, but the Defendant did not provide this safe harbor language within any of its letters. See Miller v. McCalla, Raymer, Padrick, Cobb, Nichols, & Clark, L.L.C., 214 F.3d 872 (7th Cir...
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144,106
29. During the class period, Defendant furnished an employment-purposed consumer report concerning Plaintiff to a third party, Pinkerton Consulting & Investigations, which in turn sold the report to Ms. Doe’s employer, Trinity. 30. Among other things, the FCRA regulates the collection, maintenance, and disclosur...
win
357,899
27. Defendant offers the commercial website, https://www.twigny.com/#/, to the public. The website offers features which should allow all consumers to access the goods and services offered by the Defendant and which Defendant ensures delivery of such goods throughout the United States including New York State. The good...
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68,537
(Against All Defendants for Violations of Section 14(a) of the Exchange Act and Rule 14a-9 Promulgated Thereunder) (Against All Defendants for Violations of Section 14(a) of the Exchange Act and 17 C.F.R. § 244.100 Promulgated Thereunder) (Against the Individual Defendants for Violations of Section 20(a) of th...
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52,693
10. Western Dental utilizes TalkSoft in order to send automated appointment reminders, and requests to schedule new appointments. 11. TalkSoft’s parent company RevSpring explains how it automates the process of patient outreach, which is used to bring former patients back into the dental clinics: 2 15. Until...
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23,231
1. Through its Amazon Photos service, Amazon unlawfully collects, stores, and uses the biometric identifiers and information of Amazon Prime members residing in Illinois. ................................................................................................. 13 1. The rise of facial recognition through “d...
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156,730
(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 New ...
win
34,724
60. Upon infonnation and belief, the Class is so numerous that joinder of all individual members in one action would be impracticable. The disposition of the individual claims of the respective Class members through this class action will benefit both the parties and this Court. 61. Typicality: Plaintiffs claims...
win
212,972
18. On or about June 17, 2015, Defendant sent a written communication to Plaintiff in connection with the collection of the Debt. A true and correct copy of the June 17, 2015 communication to Plaintiff is attached hereto as Exhibit A. 19. The June 17, 2015 communication was the first communication Plaintiff recei...
win
329,185
11. More than six years ago, Ms. Prince fell behind on paying her bills, including a debt she allegedly owed for a Credit One Bank credit card. On July 24, 2018, Defendant Global sent Ms. Prince an initial collection letter demanding payment of this debt. This collection letter stated that the “Original Creditor” ...
win
205,217
20. Defendants are and/or operate a private club that provides entertainment to its patrons in the form of music, alcoholic beverages, and live dancers. 21. Plaintiff and others similarly situated dance in the club without very many clothes on. 22. Taylor was employed by Defendant as a dancer in August of 201...
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1,531
(Violation of the Retail Installment Sales Act, R.C. 1317.16(B)) (Notice of Sale Stated An Incorrect Date of Sale) 12. On or arottnd September 6, 2014, Ms. Scott purchase& a 2011 Kia Optima, VIN# KNAGM4A78B5066126, from Ganley Chevrolet in Brook Park, Ohio. See Ex. 1, Buyer's Order. 1200 Ontacio Street Cleveland...
win
104,893
(42 U.S.C. § 1983 and Ex Parte Young—Equal Protection) (42 U.S.C. § 1983 and Ex Parte Young—Due Process) 79. Rivas Sports brings this action pursuant to Federal Rule of Civil Procedure 23(a), (b)(1)(A), (b)(2), and (b)(3) on behalf of itself and all others similarly situated. The proposed class is defined as fo...
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235,338
12. Defendants operate a restaurant in New York, New York with the name Roxy’s Diner. 13. Mr. Panton became an employee of Defendant Ben Moha and Defendant 694 Enterprises Inc. d/b/a Roxy Diner in or about early September 2013 and continued working for Defendants until Aug. 23, 2015. 14. At all relevant time...
win
46,746
(New York State General Business Law § 349) (Violation of the Fair Debt Collection Practices Act) 48. The plaintiff, Russell Klippel, brings this action on behalf not only of himself, but also on behalf of a class of all other persons similarly situated, pursuant to Fed. R. Civ. P. Rule 23. 50. All members ...
win
33,498
(Breach of Express Warranty) (Fraud) (Unjust Enrichment) (Unfair and Deceptive Acts and Practices in Violation of the California Consumers Legal Remedies Act) (Violations of California’s False Advertising Law) (Violation California’s Unfair Competition Law) (Violation of the Magnuson-Moss Warranty Act, 15...
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64,573
(Violation of the California Consumer Legal Remedies Act, Cal. Civil Code §§ 1750, et seq.) (Violation of California Unfair Competition Law, Cal. Bus. & Prof. Code §§ 17200, et seq.) (Violation of California False Advertising Law, Cal. Bus. & Prof. Code §§ 17500, et seq.) 59. Plaintiff repeats and realleges ...
lose
28,357
70. Plaintiffs bring Counts 1-4 and 6 of this action as a class action pursuant to Federal Rule of Civil Procedure 23, on behalf of themselves and all other similarly situated persons. This class includes: All Iranian refugees who (1) applied for refugee admission to the United States under the Lautenberg Amendm...
win
352,928
(Breach of Express Warranty) (Breach of Implied Warranty of Merchantability) (Breach of Implied Warranty of Fitness for Particular Purpose) (Negligence) 19. Defendant Orscheln is in the business of selling and advertising for sale certain merchandise or retail products in trade or commerce at retail stores th...
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10,388
17. DRS placed approximately fifteen calls to Plaintiff’s cellular telephone number between December 2018 and October 2019. 18. In each of these telephone calls, DRS delivered an artificial or pre-recorded message seeking to speak to a “Wilma Williams” regarding an alleged debt. 19. In at least one of these ar...
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310,499
(For Violation of Section 20A of the 1934 Act) (For Violation of Section 10(b) of the 1934 Act and Rule 10b-5 Against All Defendants) (For Violation of §20(a) of the 1934 Act Against the Individual Defendants) 37. Plaintiff brings this action as a class action pursuant to Rule 23 of the Federal Rules of Civil...
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383,591
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
229,730
28. Plaintiffs Laila Ibrahim and Gehad Elsayed are both Muslim women who wear religious head coverings called hijabs—headscarves covering the ears, hair, and neck of the woman, but not the face—as an expression of their sincerely held religious beliefs. 29. Their beliefs are grounded in the Quran, Sunnah, and th...
win
127,790
14. Defendant offers food delivery services and online nutritional coaching. The meals are prepared fresh and then delivered by mail. The meals accommodate several diets including the Paleo Diet and the Keto Diet. Through the Website, customers can sign up for a meal plan that delivers between four (4) and eight...
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362,045
10. John Doe Corporations 1-10 initiated prerecorded telemarketing calls to the residential landline telephone numbers of Plaintiff and the Class to promote Ohio G&E in violation of the TCPA. Ohio G&E, or one of Ohio G&E’s vendors, hired John Doe Corporations 1-10 to originate new customers, making Ohio G&E liable ...
lose
95,522
21.Plaintiffs bring this action as a class action pursuant to Fed.R.Civ.P. 23, on behalf of a Nationwide Class defined as: All persons who, between October 7, 2009 and the present, purchased one or more containers of “Great Value Pork & Beans in Tomato Sauce” at a Walmart store located in the United States. 22.Pl...
win
279,164
(Knowing and/or Willful Violation of the Telephone Consumer Protection Act, 47 U.S.C. § 227, et seq.) (Violation of the Telephone Consumer Protection Act, 47 U.S.C. § 227, et seq.) (Violation of the Telephone Consumer Protection Act, 47 U.S.C. § 227, et seq., on behalf of the Plaintiff and the Do Not Call Registr...
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119,072
(AS TO BOTH DEFENDANTS) 1. Deceptive Sales Practices of Home Improvement Contractor a. General 1. The jurisdiction of this court is established pursuant to Federal Truth in Finding Act, 15 U.S.C. §1640 (“TILA”) and for state law claims pursuant to the pendent jurisdiction of the Court. 10. Several days late...
win
446,884
15. Plaintiff was employed as an exotic dancer by Shangri La West for the period of about 2017 through about 2019. 16. During the period of Plaintiff’s employment, the number of shifts Plaintiff worked varied from week to week. 17. During the period of Plaintiff’s employment, the exact number of hours Plaintif...
win
87,520
17. Plaintiff brings this case as a class action pursuant to Rules 23 of the Federal Rules of Civil Procedure on behalf of herself and all others similarly situated. 18. Plaintiffs seek to represent a class defined as: All consumers in the United States who were sent a letter that is identical to or is su...
win
230,075
11. Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 13. 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. 1...
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82,833
19. Plaintiff brings the First Claim for Relief for violation of the FLSA as a collective action pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b), on behalf of himself and all persons who were, are or will be employed by Chase and/or CBRE as facility managers nationwide at any time within the three years ...
win
146,779
(Fair Debt Collection Practices Act) (Per se Violations of Washington’s Consumer Protection Act, RCW § 19.86 et seq.) (Violations of the Washington Consumer Protection Act, RCW § 19.86 et seq. Non-Per Se Unfair and Deceptive Business Practices) 10.1 Plaintiffs reallege and incorporate by reference each and ever...
win
228,547
19. Ring holds itself out to the public as a leader in home security which manufactures home security products that incorporate indoor and outdoor motion-detecting cameras, including Ring video doorbells and security cameras. 20. The Ring video doorbell is the company’s flagship product. The first version of the...
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381,572
23. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs numbered "1" through"22" herein with the same force and effectas if the same were set forth at length herein. 24. On or about October 1,2015, one or both Defendants began communlcating with Plaintiff by means of telephone calls ...
win
342,773
28. On January 22, 2019, Defendant initiated an unsolicited call to Plaintiff’s Phone Number using an automatic telephone dialing system (“ATDS”), as defined by 47 U.S.C. § 227(a)(1). Defendant contacted Plaintiff from phone number (402) 836-3870 (“Defendant’s ATDS Phone Number”). See Exhibit A.2 29. Plaintiff ...
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353,151
13. One of AWG’s distribution centers is located in Pearl River, Louisiana. 14. The Pearl River facility is extremely busy and employs regularly over 300 employees at a time. The work is fast paced and the vast majority of the workers work well over 40 hours per workweek. 15. Piazza worked for AWG as a laborer un...
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360,172
15. Definition of Class. N.R. proposes the following class: All individuals who: (a) have been, are, or will be participants or beneficiaries under the Raytheon Health Benefit Plan in effect or renewed on or after January 24, 2014; and (b) who have received, require, or are expected to require services for the ...
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281,155
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”): • Plaintiff brings this action individually and as a class action on behalf of all persons similarly situated in the State of New York ...
win
365,242
76. Plaintiff incorporates the above paragraphs as though set forth at length herein. 77. As alleged above, Zumper negligently and willfully failed to follow reasonable procedures to assure the maximum possible accuracy of the information it reported about Plaintiff and members of the Reasonable Procedures Class ...
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123,695
10. Defendant contacted or attempted to contact Plaintiff from telephone 20 numbers belonging to Defendant, including without limitation (561) 220-9418. 21 11 Negligent Violations of the Telephone Consumer Protection Act 12 47 U.S.C. §227(c) 13 •As a result of Defendant's negligent violations of 47 US. C. 1...
win
118,786
29. Plaintiffs bring this action on behalf of themselves and all others similarly situated (“the Class”). 30. Plaintiffs represent, and are members of, the Class, defined as follows: All persons within the United States who received any solicitation/telemarketing telephone calls and/or text messages from Defend...
win
283,360
23. On or about November 14, 2019 and November 25, 2019, Defendant caused the following automated text messages to be transmitted to Plaintiff’s cellular telephone ending in 1501 (“1501 Number”): 24. The 1501 Number has been listed on the National Do Not Call Registry since May 2, 2014. 25. At the time Plaint...
win
295,006
35. Plaintiff re-alleges all of the above paragraphs of this Complaint and incorporates them by this reference as though fully stated herein. 36. Each of the aforementioned calls by Defendant constitutes a negligent violation of the TCPA, including each of the aforementioned provisions of 47 U.S.C. § 227, et seq...
win
151,707
59. Plaintiff re-states, re-alleges, and incorporates herein by reference, paragraphs one (1) through fifty eight (58) as if set forth fully in this cause of action. 60. This cause of action is brought on behalf of Plaintiff and the members of two classes. 61. Class A consists of all persons whom Defendant's re...
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350,052
18. Defendant maintains a program for Defendant’s customers who purchase a variety of items from Defendant, thereby giving customers awards and incentives to purchase from Defendant, which Defendant refers to as the “Bloomingdale’s Loyallist Program.” 22. Specifically, in describing the purpose of this program to...
win
417,607
12. Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 13. The Class consists of: a. all individuals with addresses in the State of Texas; b. to whom Merchants’ Credit Guide Co. sent a collection letter attempting to collect a consumer debt; c. regardi...
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452,018
(Violation of the Consumers Legal Remedies Act (the “CLRA”), California Civil Code § 1750, et seq.) On Behalf of Plaintiff and the Class 24. Consumers also understand that real carrot cake desserts do not need to contain as much added sugar as typical desserts. This is true because carrots are naturally sweet. I...
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104,931
10, AND EACH OF THEM, Defendant (s). ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 10. In the letter, Defendant attempted to induce Plaintiff to make payments on a debt allegedly owed to Cach, LLC, originally from JP Morgan Chase/Washington Mutual/Providian Bank, and in the amount of $17,779.31....
lose
322,482
12. Shortly after the creation of the National Do Not Call Registry in 2003, Mr. Chinitz placed his landline number (831-420-####) on the Registry. In or around 2015, Mr. Chinitz placed a VOIP line (408-501-####) on the National Do Not Call Registry. In or around June 2017, Mr. Chinitz re-registered both numbers, u...
lose