AAA Reference No AMENDED ARBITRATION DEMAND. Claimant, COVENANT DEBT SOLUTIONS, a California corporation, Respondent.

Size: px
Start display at page:

Download "AAA Reference No. 73 516 00309 11 AMENDED ARBITRATION DEMAND. Claimant, COVENANT DEBT SOLUTIONS, a California corporation, Respondent."

Transcription

1 1 Jonathan P. Cothran (0) KIET COTHRAN & ZIRILLO, APC North Batavia Street, Suite 1C Orange, California (). (telephone) () 1.00 (facsimile) David C. Parisi () Suzanne Havens Beckman () Azita Moradmand (01) PARISI & HAVENS LLP Valleyheart Drive Sherman Oaks, California 0 () 0- (telephone) () 01- (facsimile) dcparisi@parisihavens.com shavens@parisihavens.com amoradmand@parisihavens.com Ethan Preston () PRESTON LAW OFFICES 001 North Tatum Boulevard, Suite 0-0 Phoenix, Arizona 00 (0) -0 (telephone) () 0- (facsimile) ep@eplaw.us Attorneys for Claimant Frank Maldonado IN ARBITRATION BEFORE THE AMERICAN ARBITRATION ASSOCIATION FRANK MALDONADO, an individual, v. Claimant, COVENANT DEBT SOLUTIONS, a California corporation, Respondent. AAA Reference No. 000 AMENDED ARBITRATION DEMAND Claimant Frank Maldonado ( Maldonado or Claimant ), submits this demand against Respondent Covenant Debt Solutions ( Covenant or Respondent ) through the American Arbitration Association (AAA). Claimant s allegations as to his own actions are based on personal knowledge. The other allegations are based on his counsel s investigation of publicly Amended Arbitration Demand

2 1 available documents and interviews with witnesses, and information and belief. Introduction 1. Respondent is a debt relief and/or debt settlement company. Respondent purports to negotiate settlements with its customers creditors, in order to reduce the overall level of debt Respondent s customers owe to such creditors. The services Respondent offers are debt relief services under the definition of the Federal Trade Commission s Telemarketing Sales Rule ( TSR ), at C.F.R..(m).. In exchange for its purported services, Respondent charges and receives an upfront fee before Respondent negotiates all of the settlements with the customers creditors. The TSR prohibits such upfront fees as abusive practices.. Claimant paid Respondent substantial sums of money to settle alleged debts with Claimant s creditors. Respondent received these monies before settling these alleged debts.. Claimant has lost money and property in the form of payments made to Respondent which were prohibited under the FTC s Telemarketing Sales Rule. On his own behalf, Claimant seeks restitution under the unlawful and unfair prongs of the unfair competition law, Business and Professions Code section 0 and under the Consumer Legal Remedies Act ( CLRA ). Parties. Claimant Frank Maldonado is a natural person residing in Hesperia, California. Maldonado brings this action on behalf of himself.. Respondent Covenant Debt Solutions is a California corporation which maintains its offices at 1 Rancho Viejo Road, Suite 1, San Juan Capistrano, California. Covenant purports to provide debt relief services to its customers, as that term is defined in the TSR. Application of AAA s Commercial Dispute Resolution Procedures and the Supplementary Procedures for Consumer-Related Disputes. Maldonado entered into a Debt Settlement Agreement with Covenant on January,. The Debt Settlement Agreement contained a clause requiring that the parties submit Amended Arbitration Demand

3 1 disputes related to the agreement to binding arbitration in accordance with the rules of American Arbitration Association within 0 days from the dispute date or claim, and that arbitration proceedings brought by Client shall take place in Orange County, California. (A redacted copy of the Debt Settlement Agreement is attached as Exhibit A.). On April,, Maldonado filed a class action complaint against Covenant in the Superior Court of California, County of San Bernardino. On June,, that court ordered Maldonado to arbitrate his claims pursuant to the arbitration clause in the Debt Settlement Agreement. The trial court also ruled that the injunctive relief portions of Maldonado s claims are not arbitrable and were stayed pending resolution of the arbitration.. Covenant is a business. Maldonado is a consumer. The debt relief services Maldonado purchased from Covenant were for personal or household use. Most or all of the terms, conditions, features, or choices with respect to the services Covenant provided under the Debt Settlement Agreement were non-negotiable or primarily non-negotiable. Accordingly, the American Arbitration Association s (AAA) Commercial Dispute Resolution Procedures and the Supplementary Procedures for Consumer-Related Disputes apply to this dispute. See C-1(a).. Under the Debt Settlement Agreement, the locale of the arbitration seat is fixed in Orange County, California. See R-. The Telemarketing Sales Rule. Congress enacted the Telemarketing Consumer Fraud and Abuse Prevention Act ( TCFPA ) in. The TCFPA authorizes the FTC to enact regulations prohibits deceptive and abusive telemarketing acts or practices. The FTC enacted the TSR and has regularly amended the TSR to combat new and evolving forms of deceptive and abusive telemarketing acts or practices. In particular, the TSR regulates debt relief services. The TSR defines debt relief services as any program or service represented, directly or by implication, to renegotiate, settle, or in any way alter the terms of payment or other terms of the debt between a person and one or more unsecured creditors or debt collectors, including, but not limited to, a reduction in the balance, interest rate, or fees owed by a person to an unsecured creditor or debt collector. C.F.R..(m).. The TSR prohibits abusive telemarketing acts or practices. C.F.R... In Amended Arbitration Demand

4 1 particular, the TSR prohibits charging or receiving upfront fees for any debt relief service: It is an abusive telemarketing act or practice and a violation of this Rule for any seller or telemarketer to engage in the following conduct:... Requesting or receiving payment of any fee or consideration for any debt relief service until and unless: (A) the seller or telemarketer has renegotiated, settled, reduced, or otherwise altered the terms of at least one debt pursuant to a settlement agreement, debt management plan, or other such valid contractual agreement executed by the customer; (B) the customer has made at least one payment pursuant to that settlement agreement, debt management plan, or other valid contractual agreement between the customer and the creditor or debt collector; and (C) to the extent that debts enrolled in a service are renegotiated, settled, reduced, or otherwise altered individually, the fee or consideration either: (1) bears the same proportional relationship to the total fee for renegotiating, settling, reducing, or altering the terms of the entire debt balance as the individual debt amount bears to the entire debt amount. The individual debt amount and the entire debt amount are those owed at the time the debt was enrolled in the service; or () is a percentage of the amount saved as a result of the renegotiation, settlement, reduction, or alteration. The percentage charged cannot change from one individual debt to another. The amount saved is the difference between the amount owed at the time the debt was enrolled in the service and the amount actually paid to satisfy the debt. C.F.R..(a)()(i). Claimant s Individual Allegations 1. Covenant s Debt Settlement Agreement: Under the Debt Settlement Agreement, Covenant agreed to provide debt settlement services to Client under the terms and conditions of this Agreement (the Service ). The Service consists of the negotiation and settlement with creditors of unsecured debt on behalf of Client. The Company will use commercially reasonable efforts to reduce the principal balance of debt enrolled into the program. (Ex. A at 1.) Maldonado enrolled a total of $,. of debts into Covenant s program. (See Ex. A at.). In exchange, Maldonado agreed to pay Covenant a service fee equal to % of the debt enrolled into the program ($,.). Covenant s fee schedule required Maldonado to (a) make four payments of $. Covenant between February and April, and then (b) pay Covenant a fee of $. for the next fourteen months (between May to June ). (Maldonado was also required to make payments to fund an account from which settlement payments could be made.) Amended Arbitration Demand

5 1. Per the fee schedule, Maldonado paid Covenant a total of $1,1. from February until January. During that time, Covenant only attempted to negotiate a settlement with one of Maldonado s alleged creditors, American Express. Maldonado canceled the Debt Settlement Agreement in early February, prior to his scheduled February payment.. Covenant s Fees Violated the TSR: The fees Covenant charged and received from Maldonado were abusive under the TSR. Covenant s fees violated C.F.R..(a)()(i)(A). Covenant received payments from Maldonado before Covenant had negotiated a reduction in and/or settlement of Maldonado s alleged debt to American Express.. Covenant s fees also separately violated C.F.R..(a)()(i)(C). Covenant s fees were a total percentage of the amount of debt enrolled in Covenant s program, not a percentage of the reduction of debt achieved via negotiation. Covenant s fees therefore could not comply with the TSR under C.F.R..(a)()(i)(C)(). Moreover, Covenant collected approximately % of its fee by February, but it only negotiated a single settlement with American Express. Maldonado allegedly owed $,. to American Express, which constituted less than 1% of the total debt that Maldonado enrolled with Covenant. Because Maldonado s alleged debt to American Express constituted well under % of the total debt Maldonado enrolled with Covenant, Covenant s fees violated the TSR pursuant to C.F.R..(a)()(i)(C)(1). COUNT I: Violation of the UCL. Claimant hereby incorporates by reference the allegations contained in all preceding paragraphs of this complaint. Claimant asserts this claim on behalf of himself.. The services offered under Covenant s Debt Relief Agreements with its clients are debt relief services under C.F.R..(m).. Covenant communicates with its customers by, i.e., telephone. Covenant s marketing of its services has involved more than one interstate telephone call.. Covenant s fees are abusive and violate the TSR. Covenant violates C.F.R..(a)()(i)(A) by receiving payments from Plaintiffbefore Covenant has negotiated any Amended Arbitration Demand

6 1 reduction in and/or settlement of Plaintiff s alleged debt.. Covenant s fees also violated C.F.R..(a)()(i)(C). Covenant s fees are a total percentage of the amount of debt enrolled in Covenant s program, not a percentage of the reduction of debt achieved via negotiation. Hence, Covenant s fees cannot comply with the TSR under C.F.R..(a)()(i)(C)(). Additionally, Covenant s fees violate C.F.R..(a)()(i)(C)(1) whenever Covenant receives a fee from a client and the percentage of Covenant s fee which has been received by Covenant exceeds the percentage of debt enrolled by that client which Covenant has settled and/or renegotiated.. As alleged above, Covenant s foregoing practices and acts are abuse and violate the TSR. Covenant s foregoing practices and acts are unlawful and constitute unfair competition in violation of the UCL, Business and Professions Code section 0.. In the alternative, Covenant s conduct alleged above violates Business and Professions Code section 0 because it is unfair.. Covenant s conduct is unfair because it caused a substantial injury to consumers and competition that outweighed any countervailing benefits to consumers or to competition and was not an injury the consumers themselves could reasonably have avoided. Monterey s conduct violates the policy or spirit of the TSR, because its effects are comparable to or the same as a violation of the TSR, and otherwise significantly threatens or harms the interests Congress intended to protect under the TSR.. Maldonado has lost money and property in the form of fees paid to Covenant. Maldonado has standing to bring a claim.. Maldonado seeks restitution from Respondent. COUNT II: Violation of the CLRA. Claimant hereby incorporates by reference the allegations contained in all preceding paragraphs of this complaint.. Maldonado is a consumer with respect to the Debt Settlement Agreements under the CLRA s definition. (Civ. Code, 1 subd. (d).) 0. Maldonado s execution of and performance under the Debt Settlement Agreement Amended Arbitration Demand

7 1 (including their payments to Covenant) and Covenant s receipt of such payments all constitute transactions under the CLRA. (Civ. Code, 1, subd. (e) (transaction defined as an agreement between a consumer and any other person, whether or not the agreement is a contract enforceable by action, and includes the making of, and the performance pursuant to, that agreement ). 1. Covenant s Debt Settlement Agreements represent directly and by implication that Covenant s fees are lawful and enforceable. In fact, Covenant s fees violate the TSR.. Covenant s representations and acts above were likely to mislead reasonable consumers such as Maldonado into believing that the Debt Settlement Agreements conferred rights and obligations which they did not involve (namely that the Covenant s fees were valid and enforceable). Covenant violated Civil Code section 0(a)().. Covenant also violated Cal. Civ. Code 0(a)() because Covenant s Debt Settlement Agreements made express and implied representations about Covenant s fees, when in fact such fees were prohibited by law (namely, the TSR).. Maldonado incurred damages because of Covenant s violations of Civil Code section 0(a)(). Maldonado would not have paid Covenant any fees in excess of what was required under the TSR if he had known that Covenant s fees were illegal and prohibited under the TSR.. Maldonado seeks damages and attorneys fees from Covenant pursuant to the CLRA. WHEREFORE, Claimant Frank Maldonado prays that the arbitration panel enter an award in his favor and against Covenant Debt Solutions as follows: a. Equitable relief, including restitution, against Covenant; b. Damages pursuant to the CLRA; c. An order granting costs and attorneys fees; and d. Such other and further relief as the arbitration panel may deem appropriate. Amended Arbitration Demand

8 1 Dated: January, By: ~ Jonathan P. Cothran (0) KIET COTHRAN & ZIRILLO, APC North Batavia Street, Suite lc Orange, California () - (telephone) () 1-00 (facsimile) cothran@kcz1aw.com David C. Parisi () Suzanne Havens Beckman () Azita Moradmand (01) PARISI & HA YENS LLP Valleyheart Drive Sherman Oaks, California 0 () 0- (telephone) () 01- (facsimile) dcparisi~parisihavens.com shavens parisihavens.com amoradmand@parisihavens.com Ethan Preston () PRESTON LAW OFFICES 001 N. Tatum Blvd., Suite 0-0 Phoenix, Arizona 00 (0) -0 (telephone) () 0- (facsimile) ep@eplaw.us Attorneysfor Claimant Frank Maldonado, on his own behalf, and behalfofall others similarly situated Amended Arbitration Demand

9 PROOF OF SERVICE 1 I am employed in the County of Los Angeles, State ofcalifornia. I am over the age of and not a party to the within action; my business address is: Valleyheart Drive, Sherman Oaks, California 0. On January,, I served the foregoing document described as: AMENDED DEMAND FOR ARBITRATION On interested parties in this action by placing () the original (x) a true copy thereof enclosed in a sealed envelope addressed as follows: William R. Mitchell, Esq. COUNSEL FOR COVENANT DEBT Justin M. Buhr SOLUTIONS LOGAN RETOSKE LLP Rancho Viejo Road, Suite BY MAIL AND San Juan Capistrano, California bill anretoske.com Ethan Preston, Esq. COUNSEL FOR FRANK MALDONADO PRESTON LAW OFFICES 001 North Tatum Boulevard, Suite 0-0 Phoenix, Arizona 00 e (a)e law. us BY ONLY Jonathan P. Cothran, Esq. COUNSEL FOR FRANK MALDONADO KIET COTHRAN & ZIRILLO, APC W. Katella, Suite 1 Orange, California cothran{@kczlaw.com BY MAIL AND [xl [xj (BY MAIL) I am "readily familiar" with the firm's practice ofcollection and processing correspondences for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of business. I am aware that on motion ofthe party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. (BY ) By causing this document to be delivered in pdf format to the addresses ofthe persons identified above. Executed on January,, at Sherman Oaks, California. I declare under penalty ofperjury under the laws ofthe State, of Cali ornia that the above is true and correct. Amended Arbitration Demand

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA DEBRA WONG YANG United States Attorney GARY PLESSMAN Assistant United States Attorney Chief, Civil Fraud Section California State Bar No. 1 Room 1, Federal Building 00 North Los Angeles Street Los Angeles,

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION JAMES C. STURDEVANT (SBN 94551 JESPER I. RASMUSSEN (SBN 121001 THE STURDEVANT LAW FIRM A Professional Corporation 475 Sansome Street, Suite 1750 San Francisco, California 94111 Telephone: (415 477-2410

More information

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA, TAMPA DIVISION

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA, TAMPA DIVISION UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA, TAMPA DIVISION Consumer Financial Protection Bureau and Office of the Attorney General, State of Florida, Department of Legal Affairs, Case No.

More information

Attorneys for Plaintiff People of the State of California FOR THE COUNTY OF ORANGE. Defendants.

Attorneys for Plaintiff People of the State of California FOR THE COUNTY OF ORANGE. Defendants. BILL LOCKYER, Attorney General of the State of California HERSCHEL T. ELKINS Senior Assistant Attorney General ALBERT NORMAN SHELDEN Supervising Deputy Attorney General HOWARD WAYNE (State Bar No. ) Deputy

More information

Case 2:15-cv-09340 Document 1 Filed 10/21/15 Page 1 of 11 UNITED STATES DISTRICT COURT DISTRICT OF KANSAS KANSAS CITY-LEAVENWORTH DIVISION

Case 2:15-cv-09340 Document 1 Filed 10/21/15 Page 1 of 11 UNITED STATES DISTRICT COURT DISTRICT OF KANSAS KANSAS CITY-LEAVENWORTH DIVISION Case 2:15-cv-09340 Document 1 Filed 10/21/15 Page 1 of 11 UNITED STATES DISTRICT COURT DISTRICT OF KANSAS KANSAS CITY-LEAVENWORTH DIVISION UNITED STATES OF AMERICA, Plaintiff, v. Sprint Corporation, a

More information

Determining Whether Debt Relief Service Complies with FTC Rule (Telemarketing Sales Rule 16 C.F.R. Part 310) INTERNAL BBB IMPLEMENTATION GUIDE

Determining Whether Debt Relief Service Complies with FTC Rule (Telemarketing Sales Rule 16 C.F.R. Part 310) INTERNAL BBB IMPLEMENTATION GUIDE Determining Whether Debt Relief Service Complies with FTC Rule (Telemarketing Sales Rule 16 C.F.R. Part 310) INTERNAL BBB IMPLEMENTATION GUIDE The FTC amended its Telemarketing Sales Rule (16 C.F.R. Part

More information

New Federal Regulation of Tax Resolution, Tax Negotiation and Tax Settlement Services: FTC Telemarketing Sales Rule

New Federal Regulation of Tax Resolution, Tax Negotiation and Tax Settlement Services: FTC Telemarketing Sales Rule New Federal Regulation of Tax Resolution, Tax Negotiation and Tax Settlement Services: FTC Telemarketing Sales Rule October 5, 2010, 3:00 4:00 pm ET Jonathan L. Pompan, Esq. Venable LLP, Washington, D.C.

More information

- "'. --, ,-~ ') " UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA. Federal Trade Commission,

- '. --, ,-~ ')  UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA. Federal Trade Commission, - "'. --, -.:li ') " :::; ),-~ --' DA VlD SHONKA Acting General Counsel 2 BARBARA Y.K. CHUN, Cal. BarNo. 0 3 JOHN D. JACOBS, Cal. Bar No. 1344 Federal Trade Commission 4 Wilshire Blvd., Ste. 00 Los Angeles,

More information

Case 6:09-bk-33340-CB Doc 32 Filed 02/01/10 Entered 02/01/10 12:20:27 Desc Main Document Page 1 of 6 UNITED STATES BANKRUPTCY COURT

Case 6:09-bk-33340-CB Doc 32 Filed 02/01/10 Entered 02/01/10 12:20:27 Desc Main Document Page 1 of 6 UNITED STATES BANKRUPTCY COURT Main Document Page of P.J. Zimmermann, Trustee Railroad Canyon Road #0 Canyon Lake CA Telephone: ( - Facsimile: ( - ORIGINAL 0 0 UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE

More information

United States District Court Southern District of Florida. Case No. 1:12-cv-24410-

United States District Court Southern District of Florida. Case No. 1:12-cv-24410- Case 1:12-cv-24410-XXXX Document 1 Entered on FLSD Docket 12/14/2012 Page 1 of 14 United States District Court Southern District of Florida Case No. 1:12-cv-24410- Consumer Financial Protection Bureau;

More information

OFFICE OF ATTORNEY GENERAL, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS,

OFFICE OF ATTORNEY GENERAL, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS, IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA OFFICE OF ATTORNEY GENERAL, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS, Case No.: v. Plaintiff, BASS PRELITIGATION

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case :-cv-000-jah -CAB Document Filed 0// Page of 0 Joshua B. Swigart, Esq. (SBN: ) josh@westcoastlitigation.com Robert L. Hyde, Esq. (SBN: ) bob@westcoastlitigation.com Hyde & Swigart Camino Del Rio South,

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA VERA WILLNER, ET AL. V. MANPOWER INC., CASE NO. 3:11-CV-02846-JST (MEJ)

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA VERA WILLNER, ET AL. V. MANPOWER INC., CASE NO. 3:11-CV-02846-JST (MEJ) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA VERA WILLNER, ET AL. V. MANPOWER INC., CASE NO. 3:11-CV-02846-JST (MEJ) IMPORTANT: You are not being sued. Please read this Notice carefully.

More information

SETTLEMENT AGREEMENT AND RELEASE

SETTLEMENT AGREEMENT AND RELEASE SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release (hereinafter "the Agreement") is entered into by and between Plaintiff, CITY OF PIEDMONT, CALIFORNIA, and its respective City entities,

More information

Case 4:11-cv-00650 Document 1 Filed 10/12/11 Page 1 of 13 PageID #: 1 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION

Case 4:11-cv-00650 Document 1 Filed 10/12/11 Page 1 of 13 PageID #: 1 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION Case 4:11-cv-00650 Document 1 Filed 10/12/11 Page 1 of 13 PageID #: 1 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION UNITED STATES OF AMERICA, Plaintiff, v. Civil Action

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE CHRISTOPHER LEVANOFF; ALISON DIAZ; ANDREW GAXIOLA; JENNA STEED; ROES 1 through 25, inclusive, as individuals and on behalf of all similarly situated

More information

United States District Court Southern District of Florida. Case No. -Civ- -

United States District Court Southern District of Florida. Case No. -Civ- - United States District Court Southern District of Florida Case No. -Civ- - Consumer Financial Protection Bureau, v. Plaintiff, American Debt Settlement Solutions, Inc., a Florida corporation, and Michael

More information

CREDIT REPAIR ORGANIZATIONS ACT 15 U.S.C. 1679 et. seq.

CREDIT REPAIR ORGANIZATIONS ACT 15 U.S.C. 1679 et. seq. CREDIT REPAIR ORGANIZATIONS ACT 15 U.S.C. 1679 et. seq. Please note that the information contained herein should not be construed as legal advice and is intended for informational purposes only. In addition,

More information

SETTLEMENT AGREEMENT AND MUTUAL GENERAL RELEASE. This Settlement Agreement and Mutual General Release ( Agreement ) is entered into

SETTLEMENT AGREEMENT AND MUTUAL GENERAL RELEASE. This Settlement Agreement and Mutual General Release ( Agreement ) is entered into SETTLEMENT AGREEMENT AND MUTUAL GENERAL RELEASE This Settlement Agreement and Mutual General Release ( Agreement ) is entered into by and between George Liberman Enterprises, Inc. ( Liberman ), on one

More information

APPENDIX A IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF TEXAS

APPENDIX A IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF TEXAS APPENDIX A IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF TEXAS In re: MICHELE GRAHAM, Case No.: 02-43262 (Chapter 7 Debtor. FEDERAL TRADE COMMISSION, Plaintiff, v. Adversary Proceeding

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ) FEDERAL TRADE COMMISSION, ) i'" 17-1 1 - - -a* 1, T Plaintiff, ) ) v. ) ) 3R BANCORP; ) ) 3R E-SOLUTIONS, INC.,

More information

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS CAROL LANNAN and ANN WINN, on behalf of themselves and others similarly situated, Plaintiffs, v. LEVY & WHITE and ROBERT R. WHITE, ESQ., Case No.

More information

The Debt Adjusting Act and The Consumer Economic Protection Act

The Debt Adjusting Act and The Consumer Economic Protection Act The Debt Adjusting Act and The Consumer Economic Protection Act 1 Lynne Weaver Assistant Attorney General CONSUMER PROTECTION DIVISION NORTH CAROLINA DEPARTMENT OF JUSTICE Phone: 919-716-6000 email: lweaver@ncdoj.gov

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF LOS ANGELES ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF LOS ANGELES ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) 1 2 3 4 5 6 7 8 9 Joseph Antonelli, Esq. (SBN 137039 jantonelli@antonellilaw.com Janelle Carney, Esq. (SBN 201570 jcarney@antonellilaw.com Jason Hatcher, Esq. (SBN 285481 jhatcher@antonellilaw.com LAW

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO - CENTRAL DIVISION. Plaintifl. Defendants.

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO - CENTRAL DIVISION. Plaintifl. Defendants. 1 EDMUND G. BROWN JR. Attorney General of California CATHERINE Z. YSRAEL Supervising Deputy Attorney General JUDITH FIORENTINI Deputy Attorney General State Bar No. 1 West A Street, Suite 10 San Diego,

More information

LITIGATION RETAINER AGREEMENT

LITIGATION RETAINER AGREEMENT PROCUREMENT AND ENFORCEMENT OF INTELLECTUAL PROPERTY 1332 Anacapa St. Suite 120 Santa Barbara, CA 93101-2090 (805) 962-1515 C ISLO & T HOMAS LLP 1333 2 nd Street Suite 500 Santa Monica, CA 90401-1211 L.A.

More information

How To Get A Student Loan Processed For Free

How To Get A Student Loan Processed For Free Case :-cv-0 Document Filed // Page of Page ID #: 0 ANTHONY ALEXIS, DC Bar # Email: Anthony.Alexis@cfpb.gov Phone: 0-- ORI LEV, DC Bar # Email: Ori.Lev@cfpb.gov Phone: 0-- FRANK KULBASKI, DC Bar # Email:

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION Case 4:13-cv-00594 Document 1 Filed in TXSD on 03/06/13 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. Civ. No.: VERMA HOLDINGS,

More information

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION UNITED STATES OF AMERICA, v. Plaintiff, ENTREPRENEURIAL STRATEGIES, LTD.; and Civil No. 2:06-CV-15 (WCO) DALE ALLISON,

More information

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY CIVIL DIVISION. MARIA GODINEZ, an individual,

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY CIVIL DIVISION. MARIA GODINEZ, an individual, VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY

More information

AMENDED CLASS ACTION COMPLAINT

AMENDED CLASS ACTION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. KIM WALLANT and LOUIS BOREK, on behalf of themselves and all others similarly situated, vs. Plaintiffs, FREEDOM

More information

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION. v. CASE NO.: 8:13-cv-1647-T-23TGW ORDER

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION. v. CASE NO.: 8:13-cv-1647-T-23TGW ORDER Case 8:13-cv-01647-SDM-TGW Document 10 Filed 07/17/13 Page 1 of 11 PageID 61 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION UNITED STATES OF AMERICA, Plaintiff, v. CASE NO.: 8:13-cv-1647-T-23TGW

More information

ASSEMBLY BILL No. 597

ASSEMBLY BILL No. 597 AMENDED IN ASSEMBLY APRIL 14, 2015 california legislature 2015 16 regular session ASSEMBLY BILL No. 597 Introduced by Assembly Member Cooley February 24, 2015 An act to amend Sections 36 and 877 of, and

More information

January 24, 2013. Via Federal Express. Los Angeles County v. Superior Court (Anderson-Barker) Supreme Court Case No. S207443

January 24, 2013. Via Federal Express. Los Angeles County v. Superior Court (Anderson-Barker) Supreme Court Case No. S207443 GMSR Greines, Martin, Stein & Richland LLP Law Offices 5900 Wilshire Boulevard, 12'' Floor Los Angeles, California 90036 (31 O) 859-7811 Fax (31 0) 276-5261 www.gmsr.com Writer's E-Mail: tcoates@gmsr.com

More information

Title IV of the Consumer Credit Protection Act (Public Law 90-321, 82 Stat. 164) is amended to read as follows:

Title IV of the Consumer Credit Protection Act (Public Law 90-321, 82 Stat. 164) is amended to read as follows: The Credit Repair Organizations Act CHAPTER 2--CREDIT REPAIR ORGANIZATIONS(1) SEC. 2451. REGULATION OF CREDIT REPAIR ORGANIZATIONS. Title IV of the Consumer Credit Protection Act (Public Law 90-321, 82

More information

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK. Plaintiff, the Federal Trade Commission ("FTC"), for its Complaint alleges:

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK. Plaintiff, the Federal Trade Commission (FTC), for its Complaint alleges: ... ~- - -... UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK FEDERAL TRADE COMMISSION, v. Plaintitl: COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF Mikael Marczak, a/k/a

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF MONTEREY. No.

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF MONTEREY. No. TREVOR A. GRIMM, State Bar No. JONATHAN M. COUPAL, State Bar No. 1 TIMOTHY A. BITTLE, State Bar No. 00 Howard Jarvis Taxpayers Foundation 1 Eleventh Street, Suite 1 Sacramento, CA 1 (1-0 Attorneys for

More information

JAIME M. HAWLEY, NAN X. ESTRELLA, UNITED STATES DISTRICT COURT i~, I:, ~lsn~ict FOR THE MIDDLE DISTRICT OF FLORID CQU?

JAIME M. HAWLEY, NAN X. ESTRELLA, UNITED STATES DISTRICT COURT i~, I:, ~lsn~ict FOR THE MIDDLE DISTRICT OF FLORID CQU? r J UNITED STATES DISTRICT COURT i~, I:, ~lsn~ict FOR THE MIDDLE DISTRICT OF FLORID CQU?T. r'f,'$ble D1STH1CT FLOfUOA ORLANDO DIVISION GHUJ;;}O. FL FEDERAL TRADE COMMISSION, v. Plaintiff, JPMACCELERATED

More information

IN THE IOWA DISTRICT COURT FOR POLK COUNTY

IN THE IOWA DISTRICT COURT FOR POLK COUNTY IN THE IOWA DISTRICT COURT FOR POLK COUNTY STATE OF IOWA ex rel. ) THOMAS J. MILLER, ) ATTORNEY GENERAL OF IOWA, ) Equity No. 99AG25112, ) ) ) Plaintiff, ) ) v. ) ) HOUSEHOLD INTERNATIONAL, INC.) PETITION

More information

IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA, TAMPA DMSION

IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA, TAMPA DMSION IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA, TAMPA DMSION Consumer Financial Protection Bureau and Office of the Attorney General, State of Florida, Department of Legal Mfairs, Plaintiff,

More information

ex rel. BILL LOCKYER, ATTORNEY GENERAL OF THE STATE OF CALIFORNIA,

ex rel. BILL LOCKYER, ATTORNEY GENERAL OF THE STATE OF CALIFORNIA, BILL LOCKYER Attorney General of the State of California RICHARD M. FRANK Chief Assistant Attorney General DENNIS ECKHART Senior Assistant Attorney General MICHELLE L. FOGLIANI Deputy Attorney General

More information

Case 2:06-cv-00532-FCD-KJM Document 220 Filed 06/02/2009 Page 1 of 11

Case 2:06-cv-00532-FCD-KJM Document 220 Filed 06/02/2009 Page 1 of 11 Case :0-cv-00-FCD-KJM Document 0 Filed 0/0/00 Page of 0 EDMUND G. BROWN JR., State Bar No. 00 Attorney General of California PAUL REYNAGA, State Bar No. Supervising Deputy Attorney General ELIZABETH A.

More information

Case3:12-cv-05980-CRB Document265 Filed07/20/15 Page2 of 12

Case3:12-cv-05980-CRB Document265 Filed07/20/15 Page2 of 12 Case:-cv-00-CRB Document Filed0// Page of UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 0 IN RE HP SECURITIES LITIGATION, This Document Relates To: All Actions MASTER

More information

CLAIMS ADMINISTRATION SERVICES AGREEMENT

CLAIMS ADMINISTRATION SERVICES AGREEMENT Attachment D.13 CLAIMS ADMINISTRATION SERVICES AGREEMENT This AGREEMENT is made and entered into by and between SANTA BARBARA SCHOOL DISTRICTS hereinafter referred to as "DISTRICT", and KEENAN & ASSOCIATES,

More information

Credit Repair Organizations Act

Credit Repair Organizations Act Credit Repair Organizations Act Title IV of the Consumer Credit Protection Act (Public Law 90-321, 82 Stat. 164) is amended to read as follows: TITLE IV--CREDIT REPAIR ORGANIZATIONS'' Sec. 401. Short title.

More information

TO: ALL PERSONS AND BUSINESSES WITH A VERIZON.NET EMAIL ADDRESS

TO: ALL PERSONS AND BUSINESSES WITH A VERIZON.NET EMAIL ADDRESS TO: ALL PERSONS AND BUSINESSES WITH A VERIZON.NET EMAIL ADDRESS This Notice Is Given To Inform You Of The Proposed Settlement Of A Class Action. If The Settlement Is Approved By The Court, Certain Benefits

More information

ASSEMBLY BILL No. 597

ASSEMBLY BILL No. 597 california legislature 2015 16 regular session ASSEMBLY BILL No. 597 Introduced by Assembly Member Cooley February 24, 2015 An act to amend Sections 36 and 877 of, and to add Chapter 6 (commencing with

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 1 1 1 1 1 1 1 1 0 1 LAW OFFICES OF RONALD A. MARRON RONALD A. MARRON (SBN 10) ron@consumersadvocates.com ALEXIS WOOD (SBN 000) alexis@consumersadvocates.com KAS GALLUCCI (SBN 0) kas@consumersadvocates.com

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION UNITED STATES OF AMERICA, Plaintiff,

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION UNITED STATES OF AMERICA, Plaintiff, Case :-cv-0 Document Filed 0// Page of Page ID #: BENJAMIN C. MIZER Principal Deputy Assistant Attorney General, Civil Division JONATHAN F. OLIN Deputy Assistant Attorney General MICHAEL S. BLUME Director,

More information

CUSTOMER LIST PURCHASE AGREEMENT BY AND BETWEEN RICHARD PENNER SELLER. and S&W SEED COMPANY BUYER

CUSTOMER LIST PURCHASE AGREEMENT BY AND BETWEEN RICHARD PENNER SELLER. and S&W SEED COMPANY BUYER EXHIBIT 10.1 CUSTOMER LIST PURCHASE AGREEMENT BY AND BETWEEN RICHARD PENNER as SELLER and S&W SEED COMPANY as BUYER CUSTOMER LIST PURCHASE AGREEMENT THIS CUSTOMER LIST PURCHASE AGREEMENT ( Agreement )

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18 JAMES W. JOHNSTON ATTORNEY AT LAW 00 S. Flower Street, Suite 10 Los Angeles, California 001 State Bar No. (1) 1- Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO,

More information

CHAPTER 2--CREDIT REPAIR ORGANIZATIONS SEC. 2451. REGULATION OF CREDIT REPAIR ORGANIZATIONS.

CHAPTER 2--CREDIT REPAIR ORGANIZATIONS SEC. 2451. REGULATION OF CREDIT REPAIR ORGANIZATIONS. CODES COMPLAINTS EMPLOYEE CERTIFICATION FEDERAL LAWS NACSO GUIDELINES LOG OUT CHAPTER 2--CREDIT REPAIR ORGANIZATIONS SEC. 2451. REGULATION OF CREDIT REPAIR ORGANIZATIONS. Title IV of the Consumer Credit

More information

-1- SECOND AMENDED COMPLAINT

-1- SECOND AMENDED COMPLAINT VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES

More information

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13 Case -00-LT Filed 0// Entered 0// :: Doc Pg. of NANCY L. STAGG, CA Bar No. 0 nstagg@foley.com MATTHEW J. RIOPELLE, CA Bar No. 0 mriopelle@foley.com FOLEY & LARDNER LLP VALLEY CENTRE DRIVE, SUITE 00 SAN

More information

As a current or former non-exempt PPG employee, you may be entitled to receive money from a class action settlement.

As a current or former non-exempt PPG employee, you may be entitled to receive money from a class action settlement. NOTICE OF PROPOSED CLASS ACTION SETTLEMENT AND HEARING DATE FOR COURT APPROVAL Penaloza, et al., v. PPG Industries, Inc., Case No. BC471369 As a current or former non-exempt PPG employee, you may be entitled

More information

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION 1 1 1 1 1 1 1 1 0 1 WILLIAM E. KOVACIC General Counsel KATHERINE ROMANO SCHNACK THERESE L. TULLY Federal Trade Commission East Monroe Street, Suite Chicago, Illinois 00 (1 0- [Ph.] (1 0-00 [Fax] FAYE CHEN

More information

How To Settle A Class Action Lawsuit Against Jimmy Johns

How To Settle A Class Action Lawsuit Against Jimmy Johns LOS ANGELES SUPERIOR COURT FOR THE COUNTY OF LOS ANGELES STARKS vs. JIMMY JOHN S LLC, et al. CASE NO. BC01 NOTICE OF PROPOSED CLASS ACTION SETTLEMENT THIS NOTICE MAY AFFECT YOUR RIGHTS. PLEASE READ IT

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA COMMODITY FUTURES TRADING COMMISSION, v. Plaintiff, ULRICH GARBE, a/k/a ULI GARBE and SUNSTATE FX INC., a Florida corporation, Defendants.

More information

Case 1:14-cv-01414-RBW Document 21 Filed 01/29/15 Page 1 of 15 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA

Case 1:14-cv-01414-RBW Document 21 Filed 01/29/15 Page 1 of 15 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA Case 1:14-cv-01414-RBW Document 21 Filed 01/29/15 Page 1 of 15 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA FEDERAL TRADE COMMISSION, 600 Pennsylvania Ave NW Washington, DC 20580, Plaintiff, v. Case

More information

MRMLS LISTING INFORMATION LICENSE AGREEMENT

MRMLS LISTING INFORMATION LICENSE AGREEMENT MRMLS LISTING INFORMATION LICENSE AGREEMENT (MRMLS data feed to Affiliated VOW Partner) This Listing Information License Agreement (the Agreement ) is made and entered into by and between MULTI REGIONAL

More information

SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF RIVERSIDE

SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF RIVERSIDE 1 1 1 1 1 1 1 1 0 1 SEMNAR & HARTMAN, LLP Babak Semnar (SBN 0) bob@semnarlawfirm.com Jared M. Hartman (SBN 0) jared@jmhattorney.com 00 S. Melrose Dr., Suite 0 Vista, CA 01 Telephone: (1) -1; Fax: () 1-0

More information

SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN DIEGO. The People of the State of California (hereinafter "People") are represented by Bill

SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN DIEGO. The People of the State of California (hereinafter People) are represented by Bill 1 BILL LOCKYER Attorney General of the State of California HERSCHEL T. ELKINS, Special Assistant Attorney General ALBERT NORMAN SHELDEN Senior Assistant Attorney General DAVID M. TIEDE Deputy Attorney

More information

UNITED STATES DISTRICT COURT.,"",,,'I '5..,! I: " 9 MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION ". "\T

UNITED STATES DISTRICT COURT.,,,,'I '5..,! I:  9 MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION . \T UNITED STATES DISTRICT COURT.,"",,,'I '5..,! I: " 9 MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION ". "\T ~. '.- ~ ~_ 1'~ I ~1 A..~ UNITED STATES OF AMERICA, v. Plaintiff, COMPLAINT FOR CIVIL PENALTIES, PERMANENT

More information

CREDIT REPAIR SERVICES (California Civil Code 1789.10 et seq.; 15 U.S.C.A. 1679 et seq.)

CREDIT REPAIR SERVICES (California Civil Code 1789.10 et seq.; 15 U.S.C.A. 1679 et seq.) Legal Affairs 1625 North Market Blvd., Suite S 309, Sacramento, CA 95834 www.dca.ca.gov Legal Guide CR-9 CREDIT REPAIR SERVICES (California Civil Code 1789.10 et seq.; 15 U.S.C.A. 1679 et seq.) January

More information

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS SHERMAN DIVISION

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS SHERMAN DIVISION UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS SHERMAN DIVISION FEDERAL TRADE COMMISSION, Plaintiff, Civil Action No. v. NATIONAL HOMETEAM SOLUTIONS, LLC; NATIONAL FINANCIAL SOLUTIONS, LLC; COMPLAINT

More information

Construction Defect Action Reform Act

Construction Defect Action Reform Act COLORADO REVISED STATUTES Title 13. Courts and Court Procedure Damages Regulation of Actions and Proceedings Article 20. Actions Part 8. Construction Defect Actions for Property Loss and Damage Construction

More information

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY STATE OF MISSOURI, ex rel. ) JEREMIAH W. (JAY) NIXON, ) Attorney General, ) ) Plaintiff, ) ) v. ) ) Case No. ACCESS RESOURCE SERVICES, )

More information

SETTLEMENT AGREEMENT AND MUTUAL RELEASE RECITALS

SETTLEMENT AGREEMENT AND MUTUAL RELEASE RECITALS SETTLEMENT AGREEMENT AND MUTUAL RELEASE This Settlement Agreement and Mutual Release (the "Agreement") is made as of December 5, 2007 (the "Effective Date"), by and between RELIABLE HEALTH CARE SERVICES,

More information

STATE OF NEW JERSEY. SENATE, No. 1988. 213th LEGISLATURE. Sponsored by: Senator JEFF VAN DREW District 1 (Cape May, Atlantic and Cumberland)

STATE OF NEW JERSEY. SENATE, No. 1988. 213th LEGISLATURE. Sponsored by: Senator JEFF VAN DREW District 1 (Cape May, Atlantic and Cumberland) SENATE, No. STATE OF NEW JERSEY th LEGISLATURE INTRODUCED JUNE, 00 Sponsored by: Senator JEFF VAN DREW District (Cape May, Atlantic and Cumberland) SYNOPSIS "New Jersey Fair Debt Collection Practices Act."

More information

FOR PROPERTY LOSS AND DAMAGE 1

FOR PROPERTY LOSS AND DAMAGE 1 13-20-801. Short title Colorado Revised Statutes Title 13; Article 20; Part 8: CONSTRUCTION DEFECT ACTIONS FOR PROPERTY LOSS AND DAMAGE 1 This part 8 shall be known and may be cited as the Construction

More information

How To Answer A Complaint In A Civil Case

How To Answer A Complaint In A Civil Case Revised: April 1 Federal Pro Se Clinic CENTRAL DISTRICT OF CALIFORNIA: WESTERN DIVISION How to Answer the Complaint What is an Answer? An answer is your written response to the allegations made in the

More information

COPYRIGHT LICENSE AGREEMENT

COPYRIGHT LICENSE AGREEMENT COPYRIGHT LICENSE AGREEMENT THIS LICENSE AGREEMENT (this Agreement ) is made and entered into effective as of the day of, 2002 (the Effective Date ), by and between HIRST ARTS FANTASY ARCHITECTURE and

More information

Case 2:15-cv-03432-DDP-AGR Document 1 Filed 05/07/15 Page 1 of 15 Page ID #:1 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA

Case 2:15-cv-03432-DDP-AGR Document 1 Filed 05/07/15 Page 1 of 15 Page ID #:1 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA Case :-cv-0-ddp-agr Document Filed 0/0/ Page of Page ID #: 0 Matthew T. Walsh, Esq. (Bar No. ) CARROLL, McNULTY & KULL LLC 00 North Riverside Plaza, Suite 00 Chicago, Illinois 00 Telephone: () 00-000 Facsimile:

More information

Case 1:14-cv-10612-PBS Document 1 Filed 03/10/14 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS. Case No.

Case 1:14-cv-10612-PBS Document 1 Filed 03/10/14 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS. Case No. Case 1:14-cv-10612-PBS Document 1 Filed 03/10/14 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS UNITED STATES OF AMERICA, Plaintiff, v. VERSATILE MARKETING SOLUTIONS, INC., a Massachusetts

More information

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) 1 1 1 1 1 Matthew A. Silverman (0 Jessica R. Kenney (01 McCarthy Holthus Levine North Central Avenue Suite 0 Phoenix, AZ 01 (0 0- Attorneys for Movant, First Horizon Home Loans a division of First Tennessee

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION Case :-cv-0 Document Filed 0// Page of Page ID #: 0 ANTHONY ALEXIS, DC Bar # Email: anthony.alexis@cfpb.gov Phone: (0) - JEFFREY PAUL EHRLICH, FL Bar # Email: jeff.ehrlich@cfpb.gov Phone: (0) - JOHN C.

More information

Case 1:07-cv-00558-RPM Document 1 Filed 03/20/2007 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 1:07-cv-00558-RPM Document 1 Filed 03/20/2007 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case 1:07-cv-00558-RPM Document 1 Filed 03/20/2007 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO FEDERAL TRADE COMMISSION, Plaintiff, Case No. v. DEBT SET, INC., a Colorado corporation;

More information

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION JONATHAN DANIEL, ) ) Plaintiff, ) No. 14 CV 01232 ) vs. ) ) Honorable Michael M. Mihm THE CITY OF PEORIA, et al.,

More information

Case 3:14-cv-00675-H-JMA Document 1 Filed 03/24/14 Page 1 of 11. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case No.

Case 3:14-cv-00675-H-JMA Document 1 Filed 03/24/14 Page 1 of 11. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case No. Case :-cv-00-h-jma Document Filed 0// Page of 0 ERIC H. HOLDER, JR. Attorney General STEWART F. DELERY Assistant Attorney General Civil Division MAAME EWUSI-MENSAH FRIMPONG Deputy Assistant Attorney General

More information

FINANCIAL RESCUERS, LLC

FINANCIAL RESCUERS, LLC DEBT SETTLEMENT AGREEMENT Financial Rescuers, LLC (hereinafter the Company ), whose address is noted above, and (hereinafter Client ), residing at hereby agree as follows: 1. Client is retaining the Company

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES CENTRAL DISTRICT ) ) ) ) ) ) ) ) ) ) ) )

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES CENTRAL DISTRICT ) ) ) ) ) ) ) ) ) ) ) ) Burton C. Jacobson, SBN Franklin S. Adler, SBN ATTORNEYS AT LAW Beverly Hills Law Building South Beverly Drive Beverly Hills, California 01-1 Tel: (- Attorneys for Plaintiffs/Petitioners C. D. Michel -

More information

How To File A Lawsuit Against A Corporation In California

How To File A Lawsuit Against A Corporation In California 1 2 3 4 5 [ATTORNEY NAME] (ATTORNEY STATE BAR NUMBER) [ATTORNEY EMAIL ADDRESS] [LAW FIRM NAME] [LAW FIRM STREET ADDRESS] [LAW FIRM CITY/STATE/ZIP CODE] [LAW FIRM TELEPHONE NUMBER] [LAW FIRM FAX NUMBER]

More information

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA TERRY GODDARD Attorney General Firm Bar No. 000 Cherie L. Howe State Bar No. 0 Assistant Attorney General Consumer Protection & Advocacy Section W Washington Street Phoenix, Arizona 00- Telephone: (0)

More information

Sample Representation Agreement

Sample Representation Agreement OAK VIEW LAW GROUP Head Office Address: 8421 Auburn Blvd. #145, Suite B ATTORNEYS & COUNSELORS AT LAW Citrus Heights, CA 95610-0394 800.530.6854 TELEPHONE 800.637.6854 FACSIMILE Sample Representation Agreement

More information

E-FILED. Attorneys for Plaintiff, Peter MacKinnon, Jr. SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA CASE NO. 111 CV 193767

E-FILED. Attorneys for Plaintiff, Peter MacKinnon, Jr. SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA CASE NO. 111 CV 193767 ADAM J. GUTRIDE (State Bar No. ) adam@gutridesafier.com SETH A. SAFIER (State Bar No. ) seth@gutridesafier.com TODD KENNEDY (State Bar No. 0) todd@gutridesafier.com GUTRIDE SAFIER LLP Douglass Street San

More information

SETTLEMENT AND RELEASE AGREEMENT. to herein individually as a "Party" and collectively as the "Parties." RECITALS

SETTLEMENT AND RELEASE AGREEMENT. to herein individually as a Party and collectively as the Parties. RECITALS SETTLEMENT AND RELEASE AGREEMENT This Settlement and Release Agreement ("Agreement") is made as of this 10th day of August, 2011, by, between, and among the following undersigned parties: The Federal Deposit

More information

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION TWO

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION TWO Filed 8/27/14 Tesser Ruttenberg etc. v. Forever Entertainment CA2/2 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying

More information

case 3:12-md-02391-RLM-CAN document 2756 filed 09/18/14 page 1 of 11

case 3:12-md-02391-RLM-CAN document 2756 filed 09/18/14 page 1 of 11 case 3:12-md-02391-RLM-CAN document 2756 filed 09/18/14 page 1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION IN RE: BIOMET M2a MAGNUM ) CAUSE NO. 3:12-MD-2391-RLM-CAN

More information

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8 Case :0-cv-0-JCM-LRL Document Filed 0//0 Page of Reno, NV ( -00 Fax ( 0-0 0 Mark R. Thierman, NV# laborlawyer@pacbell.net THIERMAN LAW FIRM, P.C. Reno, Nevada Tel: ( -00 Fax: ( 0-0 David R. Markham, CAL#

More information

Rule 6. Civil Practice

Rule 6. Civil Practice Page 1 Rule 6. Civil Practice 6.01 Pretrial procedure. A pretrial conference may be ordered by the judge to whom a civil case is assigned. Upon notice of the scheduling of a pretrial conference it shall

More information

Case 0:13-cv-61747-RSR Document 4 Entered on FLSD Docket 08/16/2013 Page 1 of 9

Case 0:13-cv-61747-RSR Document 4 Entered on FLSD Docket 08/16/2013 Page 1 of 9 Case 0:13-cv-61747-RSR Document 4 Entered on FLSD Docket 08/16/2013 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 0:13-cv-61747-RSR KURT S. SOTO, an individual, on behalf

More information

Case 0:15-cv-60423-WJZ Document 6-2 Entered on FLSD Docket 03/03/2015 Page 1 of 21

Case 0:15-cv-60423-WJZ Document 6-2 Entered on FLSD Docket 03/03/2015 Page 1 of 21 Case 0:15-cv-60423-WJZ Document 6-2 Entered on FLSD Docket 03/03/2015 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 0:15-cv-60423-WJZ FEDERAL TRADE COMMISSION, STATES

More information

IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO

IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO STATE OF OHIO, ex rel. ) CASE NO. ATTORNEY GENERAL ) MICHAEL DEWINE ) JUDGE 30 E. Broad St., 14 th Floor ) Columbus, Ohio 43215 ) ) PLAINTIFF, ) ) V.

More information

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY FEDERAL TRADE COMMISSION and JOHN J. HOFFMAN, Acting Attorney General of the State of New Jersey, and STEVE C. LEE, Acting Director of the New

More information

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA AMENDED COMPLAINT I. INTRODUCTION

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA AMENDED COMPLAINT I. INTRODUCTION Case 3:08-cv-01939-JMM Document 12 Filed 03/18/2009 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA v. Plaintiff, Docket 3:08-cv-01939-JMM (JUDGE JAMES M. MUNLEY)

More information

Case 9:13-cv-80670-DPG Document 4 Entered on FLSD Docket 07/11/2013 Page 1 of 8

Case 9:13-cv-80670-DPG Document 4 Entered on FLSD Docket 07/11/2013 Page 1 of 8 Case 9:13-cv-80670-DPG Document 4 Entered on FLSD Docket 07/11/2013 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 9:13-cv-80670-KAM AJA DE LOS SANTOS, an individual, on

More information

THIS NOTICE MAY AFFECT YOUR RIGHTS PLEASE READ IT CAREFULLY

THIS NOTICE MAY AFFECT YOUR RIGHTS PLEASE READ IT CAREFULLY THIS NOTICE MAY AFFECT YOUR RIGHTS PLEASE READ IT CAREFULLY NOTICE OF PENDENCY OF CLASS ACTION AND PRELIMINARY APPROVAL OF SETTLEMENT REGARDING WORKERS COMPENSATION INSURANCE TO CERTAIN CALIFORNIA EMPLOYERS

More information

MANAGEMENT AGREEMENT

MANAGEMENT AGREEMENT Revised 9/19/2013 MANAGEMENT AGREEMENT In consideration of the covenants herein contained (hereinafter called "Owner") and Rudulph Real Estate, Inc. (hereinafter called "Agent"), agree as follows: 1. EMPLOYMENT:

More information

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL

More information

Case 1:11-cv-01918-LGS Document 151 Filed 06/08/15 Page 1 of 7 : : : : :

Case 1:11-cv-01918-LGS Document 151 Filed 06/08/15 Page 1 of 7 : : : : : Case 111-cv-01918-LGS Document 151 Filed 06/08/15 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------- 6/8/15 X In re SHENGDATECH,

More information