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10. FHL is wholly owned by Defendant. 11. Furthermore, Defendant does business as FHL in states where it is allowed to do so and does business as “InterContinental Capital Group, Inc.” in states where it is not, e.g., the State of New York. 23. Plaintiff brings this action individually and on behalf of all oth...
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66,367
10. On December 23, 2011, Plaintiff shopped and purchased items at a Sur La Table retail store location in Chestnut Hill, Massachusetts. 11. To consummate the purchase, Plaintiff elected to use, and did use, her credit card as her form of payment. 12. As a condition of using her credit card, Plaintiff was requ...
win
7,343
20. Defendant operates MANHATTAN WELLNESS Centers as well as the MANHATTAN WELLNESS website, offers it to the public and offers features that should allow all consumers to access the facilities and services that Defendant offers regarding its Wellness Centers (hereinafter, its “Centers”). 21. Defendant operates ...
win
245,892
AT NASHVILLE STATE OF TENNESSEE, Plaintiff, vs.
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240,022
31. BOS says it is “the leading provider of Solids and Liquids Waste Separation Solutions” operating throughout the United States, including in New Mexico. 32. To complete its business objectives, BOS hires personnel, such as Licon, to perform solids control services. 33. BOS labels Licon and the Putative Cla...
win
419,486
1. 52.4, Plaintiffs suffered harm, including shock, fright, distress, grief, and anguish, in an amount to be determined at trial. Heaps’s acts of gender violence against Plaintiffs entitle them to actual damages, compensatory damages, punitive damages, and an award of reasonable attorney’s fees and costs under Se...
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19,168
10. On or about November 17, 2016, Plaintiff Kara Teggerdine visited a Speedway gasoline station with the intent to purchase gasoline based on the posted and advertised price of gasoline on outdoor signs located at the premises. 11. The gas pumps at this station are equipped with self-service, point-of-sale, card...
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303,114
2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibility-related problems. 2.1 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website co...
win
312,162
12. Defendants manufacture, market and sell the Nivea line of skin and body care products. This lawsuit concerns one of those products – NIVEA Skin Firming Hydration Body Lotion with CoQ10 Plus. Defendants launched NIVEA CoQ10 Lotion in 2010. NIVEA CoQ10 Lotion is sold online and in virtually every major food, ...
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168,789
(Collective Action Claim for Violation of FLSA Wage Provisions) (Individual Claim for Unjust Enrichment) (Individual Claim for Violation of FLSA Wage Provisions) 17. Plaintiff repeats and realleges all preceding paragraphs of the Complaint, as if fully set forth herein. 18. At all times material and relevan...
win
418,610
13. This action is properly maintainable as a collective action pursuant to the FLSA 29 U.S.C. § 216(b) and as a Class Action under Rule 23 of the Federal Rules of Civil Procedure. 14. This action is brought on behalf of Named Plaintiffs and a class consisting of similarly situated employees who worked for Defend...
win
6,638
(Violation of the Rosenthal FDCPA) (Violation of the FDCPA) 18. Sometime after April 4, 2016, Plaintiff received his first collection notice dated April 4, 2016 (hereinafter referred to as “Validation Notice”) from Defendant, attempting to collect a debt in the amount of $23,450.21. The debt was allegedly ow...
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99,289
29. Each of Defendant Panera, LLC‟s bakeries and cafés are open to the general public and as such, are places public accommodation subject to the requirements of Title III of the ADA and its implementing regulation; 42 U.S.C. §12182, §§s 12181(7)(B) and (E) and 28 C.F.R. Part 36, by virtue of the fact that Defendan...
win
241,176
21. All conditions precedent to the filing of this Complaint have been performed or have occurred. 22. Conn’s, its agents, and/or vendors, violated the TCPA by placing unlawful telephone calls to Plaintiff’s cellular telephone, including the number ending in -6546. 23. Conn’s, at all material times, was attem...
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26,747
2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibility-related problems. 2.1 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website co...
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92,290
12. The Defendant’s letter is deceptive and misleading in violation of 15 U.S.C. §§ 1692e and 1692e(10) as it falsely implies that the Defendant has actual knowledge about Yehoshua C. Minsky’s financial conditions and what intentions he has or does not have regarding the alleged debt. 13. The said statement: “WE...
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417,533
(Declaratory Relief) (Failure to Pay Proper Overtime Wages – FLSA – 29 U.S.C. § 207) (Misclassification as Independent Contractor) 20. Defendants provide, among other services, out-sourced technical support for firms involved in sales, marketing and/or telemarketing. 21. Two of the firms for whom Defendants ...
win
160,473
(Declaratory Relief) 113. Plaintiff repeats, realleges and incorporates by reference the allegations contained in paragraphs 1 through 112 of this Complaint as though set forth at length herein. 26 114. An actual controversy has arisen and now exists between the parties in that Plaintiff contends, and is informed ...
win
426,005
10. 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. 11. Excluded from the Plaintiff Class are the Defendant and all officer, members, partners, managers, directors an...
win
114,701
(Breach Of Express Warranty) (Breach Of Implied Warranty Of Merchantability) (Deceptive Acts Or Practices, New York Gen. Bus. Law § 349) (False Advertising, New York Gen. Bus. Law § 350) (Fraud) (Negligent Misrepresentation) (Unfair and Deceptive Acts and Practices in Violation of the California Consumers ...
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374,630
11. Plaintiff brings this action on behalf of himself and as a class action pursuant to Rule 23(a) and (b)(3) of the Federal Rules of Civil Procedure on behalf of the following class (the “Class”): All persons who are royalty owners in Oklahoma wells where Defendants (including their affiliated predecessors and affil...
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96,032
(Failure to Pay Overtime Compensation in Violation of the FLSA) 172. Plaintiffs allege and incorporate by reference the allegations in the preceding paragraphs. 173. Plaintiffs consent in writing to be a part of this action, pursuant to 20 U.S.C. § 216(b). Plaintiffs’ written consent forms are attached hereto. ...
win
186,244
1. An award of the maximum statutory damages for Michael Beeh and the Plaintiff Class pursuant to 15 U.S.C. §1692k; 12. On January 12, 2013 at 11:42am, being within one year immediately preceding the filing of this Complaint, the Plaintiff received the following message on his cellular voicemail system which could...
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290,630
10. Plaintiff was charged a fee by the ATM. A redacted copy of the receipt issued to plaintiff is attached as Exhibit A. 11. No notice stating that a fee would or may be charged was posted at or near the ATM. Photographs of the ATM are attached as Exhibit B, 18. This claim is brought on behalf of a class, ...
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424,779
10. Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 11. The Class consists of: a. all individuals with addresses in New York; b. to whom Defendant sent a collection letter related to a consumer debt; c. attributing “adjustments” to the consumer that ...
win
171,135
24. Purple Land Management operates throughout the United States, including Pennsylvania, Ohio, and West Virginia. To complete its business objectives, Purple Land Management hires personnel, such as Prinkey, to perform landman services. 25. Purple Land Management’s Landmen are required to assist Purple Land Mana...
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142,432
(Declaratory Relief) (on behalf of Plaintiff and the Class) 106. Plaintiff realleges and incorporates by reference the foregoing allegations as if set forth fully herein. 107. 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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22,596
11. Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 12. The Class consists of: a. all individuals with addresses in the State of New York; b. to whom Defendant sent a collection letter attempting to collect a consumer debt; c. that imposed an additio...
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184,065
23. On or about August through November 2020, Defendant caused a prerecorded voice message to be transmitted to Plaintiff’s cellular telephone number ending in 8280 (“8280 Number”): 24. The prerecorded voice message states that the prerecorded message was being sent from Defendant and sought for Plaintiff to com...
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172,383
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. 2.0 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’...
win
196,338
127. Individually named Plaintiffs bring this action on behalf of themselves and all other similarly situated, pursuant to Fed. R. Civ. P. 23 (a) and 23(b)(2). 128. Plaintiffs Brose, Volkman, Tambor, and Finkelstein seek certification of a class defined as: 19 All chronic ventilator users who are or will be su...
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122,753
23. Defendant operates, manages, and markets 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...
win
213,637
47. Plaintiff realleges and incorporates by reference all allegations in all preceding paragraphs. 48. Defendants own and/or operate as Freightco Acquisitions LLC, an enterprise located in Denver County, Colorado. 49. Freightco is a third-party logistics company headquartered in Denver, Colorado, that facilit...
win
184,815
127. Plaintiffs incorporate by reference paragraphs 1 through 126 as if written herein. 128. Defendant's actions violated Plaintiffs' individual rights under the FLSA, 29 U.S.C. §§ 207 et seq. 129. Plaintiffs incorporate by reference paragraphs 1 through 128 as if written herein. 130. Defendant's actions violated Plain...
win
53,269
22. This action is brought against Apple on behalf of Plaintiff and all current and former owners of the Watches. 23. Apple designed, manufactured, distributed, marketed, warranted, and sold the Watches. Upon information and belief, Apple has sold—directly or indirectly through authorized stores and other retail...
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108,122
14. World-Wide owns and manages buildings throughout the United States, including The Luna, located at 42-15 Crescent Street, Long Island City, New York. It rents within this building, studio apartments, and apartments with one or more bedrooms. 15. The Website is heavily integrated with The Luna, serving as a ga...
win
64,076
27. The Pennsylvania Legislature has authorized the City of Philadelphia to impose a fee of $300.00 per day for each offense under the Philadelphia Code to “[a]ny person who violates any provision of [the] code or regulations adopted thereunder; or who fails to comply with any order issued pursuant to any Section t...
win
368,416
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...
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274,268
10. Equifax has not retrieved actual public records from courthouses or actual government offices for many years. 11. Nevertheless, on its credit reports that it provides to consumers, Equifax falsely still lists the names of courthouses or other government offices as the true “source” of its public records inf...
win
278,255
14. Plaintiff seeks to bring this suit to recover from Defendants unpaid overtime compensation and liquidated damages pursuant to the applicable provisions of the FLSA, 29 U.S.C. § 216(b), individually, on her own behalf, as well as on behalf of those in the following collective: Current and former non-managerial ...
win
434,602
49. Plaintiff brings this action pursuant to Rules 23(a) and 23(b)(2) of the Federal Rules of Civil Procedure on behalf of himself and all legally blind individuals who have attempted to access, or will attempt to access, Defendant’s ATMs. 50. The class described above is so numerous that joinder of all individua...
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316,220
16. State Farm issued the Subject Policies in the United States using standardized contracts notated as FORM-94030 between roughly January 1, 1994 and June 30, 2004. On information and belief, State Farm continues to accept payments on the ’94 Policy from roughly 540,000 policyholders in the United States. 17. Own...
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280,140
(For Violation of the Magnuson-Moss Warranty Act) (Illinois Consumer Fraud and Deceptive Business Practices Act 815 ILCS 505/1, et seq. and 720 ILCS 295/1a) 101. Plaintiff DeLisle and Class Members re-allege and incorporate by reference each allegation set forth above. 102. Plaintiff DeLisle brings this count ...
win
37,308
(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 York City Human Rights Law, N.Y.C. Administrative Code § 8-102, et seq.) (on behalf of Plaintiff and New York subclass) (Violation of 42 U.S.C. §...
win
276,705
1. Certification of this case as a class action pursuant to M.G.L. c. 149, § 150 and/or Fed. R. Civ. P. 23; 2. With respect to the FLSA overtime claim, certification of this case as a collective action and an order conditionally certifying classes of similarly-situated individuals, permitting the issuance of not...
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236,572
13. McAfee markets and sells subscriptions to its anti-virus computer software products. Generally, the subscriptions are one year in length. Three of the software products that McAfee has marketed and sold subscriptions to throughout the relevant time period are McAfee AntiVirus Plus, McAfee Internet Security, a...
win
328,630
10. In or around January 2018, Plaintiff SEBASTIAN LEON was hired by Defendants to work as a cook for Defendants’ Murray’s Bagels Restaurant located at 242 8th Avenue, New York, NY 10011. In or around March 2018, Plaintiff LEON was transferred by Defendants to work at Defendant’s Zucker’s Bagels & Smoked Fish Resta...
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217,606
24. Plaintiff, GRACE LAMEY, readopts and realleges the allegations contained in Paragraphs 1 through 23 above. 25. Plaintiff is entitled to be paid time and one-half of her applicable regular rate of pay for each hour she worked for Defendants in excess of Forty (40) hours per work week during the three (3) ...
win
439,758
1.5 times his regular rate of pay, which should have included all wages received and not just those labeled as hourly rates of pay. As a result, BAR S significantly underpaid Shaw for overtime hours worked. 19. Consistent with their policies and patterns or practices as described herein, Defendant harmed Plaintiff...
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4,666
20. For all times relevant herein, Mr. Thompson was the owner of a cellular telephone line with the (216) prefix and ending in 3056. 21. Mr. Thompson registered the phone number referenced above on the National Do Not Call Registry on June 25, 2009. 22. Mr. Thompson received a text message from Defendants on D...
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106,925
(Fair Labor Standards Act Violations) (Violations of Ohio Revised Code 4111.03) 13. Defendant Norman Noble manufactures products for the medical and aerospace industries and has manufacturing facilities in Highland Heights and Cleveland, Ohio. 14. Defendant employed Plaintiff as an hourly, non-exempt manufactu...
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150,353
11. Lytx, pursuant to its uniform compensation policy during the calendar year of 2015, required Plaintiff and the Class to pre-enter their hours in advance of actually having worked them. Lytx required that employees enter the hours they believed they would work. Lytx paid Plaintiff and the Class based on these pr...
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145,168
50. The foregoing paragraphs are incorporated herein as if set forth in their entirety. 51. Farm Bureau regularly permitted and required the Named Plaintiffs and members of the putative class to work more than 40 hours per week without overtime compensation. 52. Upon information and belief, Farm Bureau knew tha...
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320,983
13. On or about July 4, 2014, Enerson mailed a debt collection letter to Plaintiff regarding an alleged debt owed to “CAPITAL ONE, N.A.” A copy of this letter is attached as Exhibit A. 14. Upon information and belief, Enerson first became involved in the collection of the alleged debt identified in Exhibit A aft...
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57,489
10. Defendant contacted or attempted to contact Plaintiff from telephone number (925) 359-2273. 11. Defendant’s calls constituted calls that were not for emergency purposes as defined by 47 U.S.C. § 227(b)(1)(A). 19. Plaintiff brings this action individually and on behalf of all others similarly situated, as ...
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33,674
25. On or about January 5, 2019, 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 a number to be connected to a live representative if he was interested in sav...
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130,807
19. Pursuant to 29 U.S.C. §§ 207 & 216(b), Plaintiffs brings their First Cause of Action as a collective action under the FLSA on behalf of themselves and the following collective: All persons employed by Defendant at any time since January 10, 2014 and through the entry of judgment in this case (the “Collective A...
win
281,014
1. The planter was model year 2014 or later and number 1770NT or 1775NT; and/or 106. John Deere, either directly and/or through its agents, represented to the world, Plaintiff, and class members that the planters provided even distribution and emergence. 107. The planters were not capable of providing even distr...
win
441,627
70. ERISA § 502(a)(2), 29 U.S.C. § 1132(a)(2), permits a plan fiduciary, participant, beneficiary, or the Secretary of Labor to bring a suit individually on behalf of the Plan to recover for the Plan the remedies provided under ERISA § 409, 29 U.S.C. § 1109(a).
win
449,210
14. Plaintiff has a checking account with Members 1st. 16. Pursuant to its standard account agreement, Members 1st charges fees (currently in the amount of $37) for debit card transactions that purportedly result in an overdraft. A. Members 1st Account Documents 17. Plaintiff’s checking account with Membe...
win
392,309
10. Plaintiff and those she seeks to represent in this action were employed as servers and bartenders for Bobby Hotel. 11. Bobby Hotel paid Plaintiff and other servers and bartenders an hourly wage below $7.25. Typically, they earned $4.15 per hour. During special events and banquets, servers were paid $6.00 per...
win
289,938
2.0 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
win
325,336
234. The foregoing paragraphs are incorporated herein as if set forth in their entirety. 235. SFBL's practice of failing to pay the Plaintiffs and other Agents similarly situated at a time-and-a-half rate of pay for hours in excess of 40 hours per workweek violates the FLSA. See 29 U.S.C. § 207(a)(1). 236. None...
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203,946
19. AZZ provides galvanizing and metal coating services, welding solutions, specialty electronic equipment and highly engineered services to the power generation, transmission, distribution, refining, and industrial markets. Materially False and Misleading Statements Issued During the Class Period 34. Plaintiff...
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237,528
10. Defendant is an accounts receivable management company. 11. Defendant’s regular business practices include contacting alleged debtors and third parties by telephone in connection with collecting alleged debts. 12. Within the four years prior to the filing of this action, Defendant initiated telephone call...
win
403,942
(CONVERSION AND MISAPPROPRIATION) 111. The allegations contained in the previous paragraphs are incorporated by reference. 112. Plaintiff brings this claim on behalf of the Nationwide Class under the laws of all states. 113. Defendants have no authority to charge and collect “Taxes & Fees” amounts in excess of...
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97,046
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 January, 2015, Defendants transmi...
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46,786
11. Defendants sent advertisements by facsimile to Plaintiff and a class of similarly-situated persons. Whether Defendants did so directly or with the assistance of a third party (yet unknown to Plaintiff), Defendants are directly liable for violating the TCPA. 12. Plaintiff has received at least one of Defendan...
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349,500
1. Issuance of notice as soon as possible to all students of Texas Chiropractic College Foundation who worked in the Moody Clinic from January 1, 2016 to the present. Generally, this notice should inform them that this action has been filed, describe the nature of the action, and explain their right to opt into th...
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235,676
18. UNIVERSAL regularly collects, and attempts to collect, defaulted debts incurred, or alleged to have been incurred, for personal, family, or household purposes on behalf of creditors using the U.S. Mail, telephone, and Internet. 19. By letter dated June 19, 2017 (“Long Letter”), UNIVERSAL attempted to collect ...
lose
446,000
2.1 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
win
50,520
(All Plaintiffs individually and on behalf of the FLSA collective v. All Defendants) (All Plaintiffs individually and on behalf of the FLSA collective v. All Defendants) (Plaintiff Muhammad on behalf of himself and similarly-situated officers v. All Defendants) 15. This is a collective action brought under the Fa...
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339,784
1. This case is about Regional Transportation District’s (RTD’s) and First Transit, Inc.’s (First Transit’s) admitted policy of automatically denying employment to potential bus drivers with more than ten points on their driver’s licenses, whether or not those points arise from violations that might bear on an appl...
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88,736
13. Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 14. The Class consists of: a. all individuals with addresses in the State of Washington; b. to whom Defendant Convergent sent a collection letter attempting to collect a consumer debt; c. on behal...
win
56,655
(VIOLATION OF FLSA) A. FLSA COVERAGE 17. 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.3 18. Upon information...
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441,393
11. The instant action arises out of Defendants’ attempts to collect upon outstanding credit card debt (“subject debt”) said to be owed by Plaintiff. 12. The subject debt stems from Plaintiff’s purported past due payments on a personal credit card said to be issued to Plaintiff by Credit One Bank, N.A. (“Credit One...
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207,620
12 MEAL-PE?IOD LIABILITY UNDER LABOR CODE S 226.7 13 (Against All Defendants) 14 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 26 27 28 JENNIFER CAMPOS, an individual, on behalf of herself and others similarly situated, Plaintiff, vs. 14 FAILURE TO PAY MINIMUM WAGES '5 (Against All Defendants)...
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149,413
23. The Property is commercial property with a public accommodation, a convenience store/restaurant, located right on McKinney Ave. The Property has its own parking. There are public transportation stops located right on McKinney Ave and a trolley that runs in front of the Property as well. L.P. and HERMITAGE INVESTME...
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400,403
11. Upon information and belief, Restaurant Depot employs over one thousand employees. Plaintiff James Goodman 12. On or about April 15, 2018, Plaintiff James Goodman commenced working for Restaurant Depot in Milwaukee, Wisconsin. He began work as a cashier, and generally worked 40 hours per week. 13. When ...
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172,311
(Declaratory Relief on behalf of Plaintiffs and the Class) 11 20. Pursuant to Rules 23(a), 23(b)(2), and 23(b)(3) of the Federal Rules ofCiv 1 7 Procedure, the Named Plaintiffs bring this action, for injunctive and declaratory relief, an 8 statutory damages, on their own behalf and on behalf of all persons sim...
win
91,357
NEW YORK LABOR LAW – OVERTIME VIOLATIONS (On Behalf of the NY Class) 194. Plaintiffs, on behalf of themselves and all NY Class members, reallege and incorporate by reference the paragraphs above as if they were set forth again herein. 195. Plaintiffs were employed by Aldi within the meaning of the NYLL. 196. A...
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321,995
13. On information and belief, Defendants launched their Flavor God seasoning business in 2012. Defendants first generated sales by selling their seasonings at farmer’s markets. On information and belief, Flavor God began selling products to customers in the United States through its website (https://flavorgod.com...
win
438,716
(FAIR LABOR STANDARDS ACT) (MISSOURI WAGE PAYMENT LAW) Mo. Rev. Stat. § 290.527 111. This count sets forth a claim by the Farmworkers for Defendants’ violations of the Missouri wage payment law, Mo. Rev. Stat. § 290.527, during the 2018 southeastern Missouri watermelon harvest. 112. By their actions described ...
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11,039
18. Defendant employs a Store Manager at each of its retail stores and gas stations. 19. Employees who work for Defendant as Store Managers are classified by Defendant as exempt under the FLSA and state wage and hour laws. 20. Defendant tracks Store Managers’ hours worked by requiring them to clock in and out...
win
92,667
1.5 times the higher average straight time wage rate earned by the employee during the workweek. 10. At the end of the day Jim Fischer required all jobsite employees to drive from their last jobsite for the day back to the Appleton shop. Once at the shop employees would fill out their time cards. Jim Fischer r...
win
65,319
24. Plaintiffs bring this action on behalf of themselves and all other persons similarly situated. 25. Plaintiffs propose the following Class definition, subject to amendment as appropriate: All persons within the United States who (a) received a telephone call; (b) on his or her cellular telephone or residenti...
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351,076
19. Plaintiff brings this action on behalf of himself and on behalf of all others similarly situated (“The Class”). 20. Plaintiff represents, and is a member of, “The Class” defined as follows: “All persons in California whose inbound cellular telephone conversations were recorded without their consent, by Defendan...
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40,369
10. Mr. Cole’s financial woes caused him to fall behind and default on some of his debts and obligations, including a credit card account with Chase Bank (USA), N.A. (“Chase”) and a medical debt to Norton Hospitals, Inc. (“Norton”). 11. Chase charged off Mr. Cole’s account and assigned it to First Resolution Inve...
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38,559
(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 t...
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220,065
21. Defendant is a clothes store that operates its clothes store as well as the Website to the public. The clothes store is located at 53 Greene Street, New York, New York. Defendant’s clothes store constitutes a place of public accommodation. Defendant’s clothes store provides to the public important goods and se...
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149,225
61. Plaintiff incorporates by reference the foregoing paragraphs as if fully set forth. 63. Because of the Defendants’ violations of 47 U.S.C. § 227 et seq., Plaintiff and Class members are entitled to an award of $500 in statutory damages for every call in violation of the statute, under 47 U.S.C. § 227(b)(3)(B)...
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69,172
(AGAINST ALL DEFENDANTS) A. FACTUAL ALLEGATIONS 29. Defendants operate adult-oriented entertainment facilities located at 1350 SW 2nd Street, Pompano Beach, Florida, 33069. (Figure 1 – Solid Gold Pompano) 88. Plaintiff hereby incorporates by reference and re-alleges each and every allegation set forth in ea...
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201,561
2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibility-related problems. 2.1 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website co...
win
348,672
18. Plaintiff brings this lawsuit pursuant to 29 U.S.C. § 216(b) on behalf of himself and all similarly situated persons who work or have worked for Pace as bus operators within the last 3 years, and who elect to opt-in to this action. 19. Pace unlawfully required plaintiff and all individuals employed as bus op...
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314,399
12. Swagway sells the Swagway Hoverboard. 13. According to Swagway’s, website, “SWAGWAY is very meticulous” with respect to the manufacture of Swagway Hoverboards. “We make sure our boards are made with the finest parts. All of our boards come with a high quality aluminum alloy frame. Our batteries are a high-po...
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92,097
12. On information and belief, on a date better known to Defendants, Defendants began their campaign of communicating with the Plaintiff via the use of an automated telephone dialing system and prerecorded messages throughout the past year by calling her cell phone number of (661) 472-4330 numerous times in attempt...
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99,559
21. Despite the FCRA’s requirements, Equifax regularly declines to block the reporting of fraudulent information by wrongfully rejecting valid identity theft reports outright and relying instead on the same verification procedures it uses for common disputes. 22. In violation of the FCRA, Equifax willfully and ne...
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146,678
14. Plaintiff began working for Defendants in June or July 1997 as a general laborer, earning about $6.50 per hour. 15. Sometime around late 2000 or early 2001, Plaintiff began working for Defendants as a concrete framer/finisher. 17. In October 2006, Plaintiff received a pay increase to $22.00 per hour. ...
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313,757
20. On March 19, 2020, Governor Wolf issued the COVID-19 Closure Order, which mandated the shutdown of all business not deemed “life sustaining.” 21. The World Health Organization (“WHO”) and the Center for Disease Control and Prevention (“CDC”) identified the novel coronavirus (“COVID-19”) as a “public health e...
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32,695
21. Defendant is a hot sauce manufacturing company that owns and operates the website, www.mohotta.com (its “Website”), offering features which should allow all consumers to access the goods and services which Defendant ensures the delivery of throughout the United States, including New York State. 22. Defendant...
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