IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING NO.

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING NO."

Transcription

1 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING KENDALL BAKER, individually and collectively on behalf of all others similarly situated, v. Plaintiffs, U.S. LEGAL SUPPORT, INC.; ROE CORPORATIONS 1 through 0; DOE INDIVIDUALS 1 through 0; inclusive, Defendants. CLASS ACTION COMPLAINT - 1 NO. CLASS ACTION COMPLAINT Plaintiff KENDALL BAKER ( BAKER ), through undersigned counsel, for her class action complaint against Defendant U.S. LEGAL SUPPORT, INC. ( US LEGAL ) and ROE CORPORATIONS 1 through 0 and DOE INDIVIDUALS 1 through 0 (collectively Defendants ); inclusive, alleges as follows: STATEMENT OF THE CASE The price of a lawsuit is high and growing higher. How costly, and the history and rate of growth, are difficult to measure directly, but lawyers the individuals best positioned to witness the trend and effect of civil litigation costs overwhelmingly report a problem. 1 public policy concern is exponentially magnified when institutional litigants, such as casualty insurance companies and large corporations, are allowed to leverage their market share and 1 WSBA Task Force on the Escalating Costs of Civil litigation; ECCL Final Report (June 1, 1) at p.1. This SEATTLE, WA 1 Ph: -- FAX: --1

2 influence into undisclosed exclusivity and/or bulk purchasing agreements with Court Reporting Agencies to reap undisclosed financial discounts. In 1 alone, there were,0 total collisions in Washington This figure does not take into account the many thousands of nonvehicle related insurance claims occurring annually in Washington. The sheer volume affords institutional litigants unwieldy leverage when negotiating longterms, bulk services, including court reporting services. Undisclosed, unequal rates and terms (between litigants to the same case and receiving the same reporting services) function as costshifting mechanisms subsidizing part of the insurance carrier s litigation costs at the expense of injured individuals. By enacting the equal-terms requirement, the Washington legislature prohibited court reporting services from charging different rates, for the same service, to different parties in the same case. PARTIES 1. Plaintiff BAKER is domiciled in Washington and a resident of King County.. Defendant US LEGAL is a for-profit Texas corporation registered to do business and in fact engaged in commerce and trade in Washington. At all times material, US LEGAL acted as a business, consortium, or other organization providing and/or facilitating court reporting services to numerous Washington litigants, including KENDALL. JURISDICTION AND VENUE. King County Superior Court has jurisdiction pursuant to the Washington Constitution, Article, and RCW.1.0 & RCW Venue is proper pursuant to RCW.1.0; RCW..(a) & (b); and CR. CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

3 . US LEGAL acting agents and/or employees regularly engage in business transactions within this state. Defendant maintains a physical presence within this state. A substantial part of the events and tortious conduct giving rise to the claims in this lawsuit occurred within this state and county. Defendant availed itself of the benefits of the laws of Washington and its commercial market.. The claims of Plaintiff and the Class members are brought solely under state law causes of action and governed exclusively by Washington law. No claim exceeds $,000, exclusive of interest and costs, and thus raises no federal questions. BACKGROUND. Parties to a judicial action have the right to an impartial and independent court reporter, who has no bias, financial or otherwise, in the outcome of the court proceedings being 1 reported. However, an increasing number of insurance companies are entering into undisclosed long-term agreements with court-reporting agencies which require their counsel to use a particular agency for any deposition they note. In return, insurance companies realize reduced fees. These contracts may call for expedited transcript delivery, deposition databases, and even discounted or free deposition summaries.. What many plaintiffs do not appreciate is that they may be getting gouged on transcript copy rates and other reporting services to account for the discounts afforded to institutional litigants. Exclusivity and bulk-purchasing agreements that result in unequal reporting services and terms are illegal in Washington. Exxon Mobil Corp. v. Allapattah Servs., Inc., U.S. (0). CR (c). CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

4 . Washington found it necessary to regulate the practice of court reporting to protect the public safety and well-being and enacted the Court Reporting Practices Act ( CRPA ).. Certified reporters are officers of the court. They have ethical responsibilities to litigants and the bench. Professional ethics define the type of conduct litigants, courts, and attorneys have a right to expect from certified reporters. They include, inter alia, the obligation to fair and impartial toward all participants, in all aspects and avoiding unlawful agreements. They must guard against even the appearance of a conflict of interest, including undisclosed relationships with other parties to the transaction.. Compliance with the CRPA by certified reporters is mandatory. Under the CRPA a certified reporter can engage in unprofessional conduct in multiple ways: a. Violation of state statute or administrative rule regulating the profession; b. Dishonesty or corruption relating to the practice of court reporting or in the operation of the business, whether or not the act constitutes a crime; c. False, deceptive, fraudulent, or misleading conduct; d. Misrepresentation in any aspect of the conduct of the business or profession. 1. Certified court reporters ( CCR ) must offer arrangements on a case concerning court reporting services or fees to all parties on equal terms. 1 The equal terms rule applies to any agreement between the CCR, court reporting firm, consortium or other organization providing a court reporter and any party paying for court reporting services RCW.1.00 &.1. WCRA Resolution to Preserve Impartiality (January 1) RCW.1.() & RCW..(); WAC RCW.1.(1) & RCW..(1). RCW.1.() & RCW..(). RCW.1.() & RCW..(). 1 WAC 0-1-(1). CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

5 in the case, including any attorney, law firm, person or entity with a financial interest in the outcome of the litigation. 1 FACTUAL ALLEGATIONS 1. Upon information and belief, Famers Insurance Exchange ( FIE ) and US LEGAL were parties to an exclusivity and/or bulk purchasing agreement that called for FIE to receive discounted court reporting services from US LEGAL. 1. BAKER was a litigant in Huckabee v. Hanson, (KCSC case No SEA). Hollenbeck, Lancaster, Miller, & Andrews ( HLMA ) defended Dennis Hanson, an FIE insured. Attorneys for HLMA are employees of FIE. Keane Law Offices represented Kendall Baker in the prosecution of her claims against Mr. Hanson. 1. On November, 1, HLMA deposed BAKER. FIE, through HLMA, retained US LEGAL to provide court reporting services for this deposition. 1. On December, 1, US LEGAL invoiced Keane Law Offices (invoice #1) $1.0. BAKER is liable for litigation costs advanced by her attorney, including deposition services. 1. Litigation costs reduce the net recovery to litigants. To ensure US LEGAL was complying with Washington s equal terms requirement BAKER requested US LEGAL provide copies of charges invoiced to FIE for the same depositions.. On January, 1, US LEGAL refused to provide documentation but offered written assurances to Keane Law Offices [T]hat Famers Insurance was billed for both depositions in question and your firm was billed at a lower rate. These assurances were deceptive and masked direct evidence of professional misconduct and predatory billing. 1 Superior Court Civil Rules (d). 1 RPC 1.(e)(1). CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

6 What follows are three examples of Plaintiff s allegations of professional misconduct against US LEGAL. EXAMPLE #1 Alhadenff v El Diablo, Inc SEA. US LEGAL invoice FIE # versus plaintiff #0: REPORTING SERVICE FIE KEANE LAW Exhibits Charges $0.0 per page $0.0 per page Handling Charges $1.00 $.00 End Line Discount <$1.00> N/A Pay After Date Escalation Charge N/A <$0.1> EXAMPLE # Huckabee v Hanson SEA (Deposition of Kendall Baker). US LEGAL invoice FIE #1 versus plaintiff #1: REPORTING SERVICE FIE KEANE LAW Handling Charges $1.00 $.00 End Line Discount $.00 N/A Pay After Date Escalation Charge N/A $1. EXAMPLE # Alhadenff v El Diablo, Inc SEA. US LEGAL invoice FIE #1 versus plaintiff #1: REPORTING SERVICE FIE KEANE LAW Handling Charges $1.00 $.00 End Line Discount $. N/A Pay After Date Escalation Charge N/A $. Exhibit Charges $0.0 per page $0.0 per page. US LEGAL invoices sent to plaintiffs display only full-balance charges and do not inform parties of the disparate billing practices. Many plaintiffs remain unaware they are CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

7 being illegally charged a higher fee for the exact same service. Consequently, business practices constituting professional misconduct and predatory billing go unnoticed. CLASS ACTION ALLEGATIONS. BAKER brings this case as a class action on behalf of a Class defined as: All persons and entities involved in litigation in Washington courts that received court reporting services from US LEGAL, its agents and/or employees, on unequal terms and/or unequal fees from February, 1 to present ( the Class ). 1. BAKER is a member of the Class.. Excluded from the Class is Defendant, any entity in which a Defendant has a controlling interest, and Defendant s legal representatives, assignees, and successors. Also excluded is the judge assigned to this case and any member of the judge s immediate family.. Upon information and belief, members of the Class are so numerous that joinder is impractical. The exact number and names of members of the Class are presently unknown, but can be readily ascertained through appropriate discovery. Plaintiff believes that there are hundreds, if not thousands, of affected members of the Class, whose names and addresses may be readily discovered upon examination of the records in the custody and control of Defendant. Moreover, the disposition of the claims of the Class in a single action will provide substantial benefits to all parties and the Court.. The central questions of law and fact are common to Plaintiff and Class members and are more fully laid out in BAKER s causes of action.. The nature and extent of class-wide injury and the measure of compensation for such injury is readily ascertainable and common to Plaintiff and Class members. 1 Washington Civil Rule CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

8 The claim of the representative Plaintiff is typical of the claims of the Class. Plaintiff received court reporting services from US LEGAL, its agents and/or employees, on unequal terms and/or fees in violation of Washington law and the Consumer Protection Act. Plaintiff s claims, like the claims of the Class, arise out of the same common course of conduct by Defendant and are based on the same legal and remedial theories. 1. Plaintiff will fairly and adequately protect the interests of the Class.. Plaintiff has retained competent and capable attorneys who are experienced trial lawyers with significant experience in complex and class action litigation, including consumer class action litigation. Plaintiff and her counsel are committed to prosecuting this action vigorously on behalf of the Class and have the financial resources to do so. Neither Plaintiff, nor her counsel, has interests that are contrary to or that conflict with those of the proposed Class.. Defendant has engaged, and upon information and belief, continues to engage, in repeated deceptive and illegal conduct subjecting consumers to court reporting services on unequal terms, including but not limited to, unequal fees. The common issues arising from this conduct that affect Plaintiff and members of the Class predominate over any individualized issues. Adjudication of these common issues in a single action has important and desirable advantages of judicial economy and public policy.. Plaintiff and Class members have suffered actual damages as a result of Defendant s unlawful, professional misconduct. Absent a class action, however, most Class members would find the cost of litigating their claims prohibitive. CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

9 Class treatment is superior to multiple individual suits or piecemeal litigation because it conserves judicial resources, promotes consistency and efficiency of adjudication, provides a forum for small claimants, and deters illegal and deceptive practices.. Litigation of the claims should occur in this Court as all claims are brought under Washington law. There will be no significant difficulty in the management of this case as a class action. The Class members are readily identifiable from Defendant s records. CAUSES OF ACTION. Plaintiff re-alleges and incorporates by reference each and every allegation set forth in the preceding paragraphs.. US LEGAL breached its ethical responsibility to BAKER and members of the Class by entering into agreements that would cause FIE attorneys, US LEGAL CCRs and other agents to violate the CRPA.. US LEGAL engaged in misleading and deceptive conduct that appears designed to prevent BAKER and members of the Class from discovering its contractual relationship with FIE and other insurers and large corporations. 0. US LEGAL, as alleged herein, engaged in dishonesty and corruption relating to the entrepreneurial aspects of the practice of court reporting. 1. US LEGAL engaged in false, deceptive, fraudulent, and/or misleading conduct, as alleged herein, relating to the entrepreneurial aspects of the practice of court reporting; including but not limited to, material deceptive and misleading representations and assurances pertaining to the illegal unequal billing practices for its reporting services.. US LEGAL failed to conduct its business in a manner consistent with the CRPA causing harm and damages to BAKER and other members of the Class, including but not limited CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

10 to, failing to provide court reporting services and associated fees to all parties on equal terms, harming BAKER and other members of the Class. VIOLATION OF CONSUMER PROTECTION ACT. Plaintiff re-alleges and incorporates by reference each and every allegation set forth in the preceding paragraphs.. At all times relevant, US LEGAL provided services directly and/or indirectly affecting the people of the state of Washington and engaged in unfair and deceptive actions and professional misconduct relating to court reporting services. 1. Upon information and belief, US LEGAL entered into exclusivity and/or bulk purchasing agreements that provided for deposition services on unequal terms in violation of Washington law.. BAKER and members of the Class are entitled to refund for moneys acquired by US LEGAL by means of prohibitive acts described herein.. BAKER and members of the Class were damaged by violation of the prohibitive conduct, as described herein, and are entitled to actual damages, together with costs of suit and reasonable attorney fees, and treble damages as the court deems appropriate.. The unfair and deceptive practices complained of herein are injurious to the public interest. RCW.1.00 contains specific legislative declaration of public interest impact in regulating court reporting services. Defendant s conduct has injured other persons, including members of the Class and will likely continue to injure.. US LEGAL s determinations as to how it priced its court reporting services; including the manner and terms the same were constituted, billed and collected, as well as, the 1 RCW..0; RCW.1.00 & RCW.1.; CR ; and WAC 0-1- RCW..00 CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

11 determination to enter into exclusivity and/or bulk discounting agreements with insurers and large corporations are entrepreneurial aspects of the practice of court reporting. 0. All acts and/or omissions by Defendant complained of herein occurred within four years of the filing of this lawsuit. 1. As a proximate result of the wrongful acts of Defendant, Class members, including Plaintiff, have suffered loss or injury, for which Defendant is liable. PRAYER FOR RELIEF WHEREFORE, Plaintiff, individually and on behalf of the members of the Class, prays for judgment against Defendants as follows: A. Certification of the proposed plaintiff Class; B. A determination that Defendant is financially responsible for notifying all Class members of its unlawful conduct; C. Appointment of Plaintiff as representative of the Class; D. Appointment of the undersigned counsel as counsel for the Class; E. A finding that Defendant s actions were deceptive, unfair and constitute professional misconduct in violation of RCW.1.; RCW ; CR ; and WAC 0-1-; G. An award to Plaintiff and the Class of compensatory damages, including actual damages and treble damages under RCW..00; H. Forfeiture and refund of fees charged and imposition of a fine not to exceed $,000 for each act of Defendant s professional misconduct under RCW..1; I. That this Court enters an order enjoining Defendant from further charging unequal fees and terms for depositions services within the state of Washington; J. Award Plaintiff and the Class attorneys fees and costs, as allowed by law; CLASS ACTION COMPLAINT - SEATTLE, WA 1 Ph: -- FAX: --1

12 1 1 1 K. Award Plaintiffs and the Class prejudgment and post-judgment interest, as provided by law; L. Permit Plaintiffs leave to amend the Complaint to conform to the evidence presented at trial; and M. Grant such other and further relief as the Court deems necessary, just, and proper. DATED this th day of February, 1 /s/ R. Travis Jameson R. Travis Jameson, WSBA#1 Paul Stritmatter, WSBA# Brad Moore, WSBA#0 Co- Counsel for Plaintiffs KEANE LAW OFFICES T. Jeffrey Keane, WSBA# Co-Counsel for Plaintiffs 1 1 CLASS ACTION COMPLAINT - 1 SEATTLE, WA 1 Ph: -- FAX: --1

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK KELVIN BLEDSOE, Plaintiff, v. SAAQIN, INC., No. COMPLAINT FOR VIOLATION OF FAIR LABOR STANDARDS ACT JURY TRIAL DEMANDED Defendant. Plaintiff Kelvin

More information

Case 2:14-cv-00244 Document 1 Filed 02/19/14 Page 1 of 9

Case 2:14-cv-00244 Document 1 Filed 02/19/14 Page 1 of 9 Case :-cv-00 Document Filed 0// Page of UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE DR. A. CEMAL EKIN, individually and on behalf of similarly situated individuals, v. Plaintiff,

More information

Plaintiff Carol Parker ( Plaintiff ), residing at 32 Coleman Way, Jackson, NJ 08527, by her undersigned counsel, alleges the following upon personal

Plaintiff Carol Parker ( Plaintiff ), residing at 32 Coleman Way, Jackson, NJ 08527, by her undersigned counsel, alleges the following upon personal UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY CAROL PARKER, on behalf of herself and all others similarly situated, v. Plaintiff, PARADE ENTERPRISES, LLC, No. 3:14-CV-08084-MAS-DEA AMENDED COMPLAINT

More information

THIRD JUDICIAL DISTRICT COURT IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

THIRD JUDICIAL DISTRICT COURT IN AND FOR SALT LAKE COUNTY, STATE OF UTAH James W. McConkie #2156 PARKER & McCONKIE Attorneys for Plaintiffs City Center I, Suite 900 175 East 400 South Salt Lake City, Utah 84111 Telephone (801) 264-1950 Facsimile (801) 328-4988 THIRD JUDICIAL

More information

Case 1:16-cv Document 1 Filed 05/17/16 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CLASS ACTION COMPLAINT

Case 1:16-cv Document 1 Filed 05/17/16 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CLASS ACTION COMPLAINT Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA GREGORY SELDEN, v. Plaintiff, Individually and on Behalf of all Others Similarly

More information

Case Number XXX I. INTRODUCTION. 1. Defendants E.G.O. and E.R.O., prepare immigration documents for customers for a

Case Number XXX I. INTRODUCTION. 1. Defendants E.G.O. and E.R.O., prepare immigration documents for customers for a STATE OF NORTH CAROLINA DURHAM COUNTY IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION Case Number XXX A.C.G., J.G.M., on behalf of themselves and ) all others similarly situated, ) Plaintiffs )

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

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 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

Case No.: CLASS ACTION COMPLAINT FOR BREACH OF IMPLIED WARRANTY OF WORKMANSHIP AND HABITABILITY. Plaintiffs,

Case No.: CLASS ACTION COMPLAINT FOR BREACH OF IMPLIED WARRANTY OF WORKMANSHIP AND HABITABILITY. Plaintiffs, 1 1 1 1 1 1 0 1 Stephen L. Weber, Esq. (AZ SBN 01) Michael J. White, Esq. (AZ SBN 01) James W. Fleming, Esq. (AZ SBN 0) KASDAN SIMONDS WEBER & VAUGHAN LLP 00 N. Central Ave., Suite 0 Phoenix, AZ 0 E-Mail:

More information

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND District Court, Denver County, Colorado 1437 Bannock Street Denver, Colorado 80202 GUILLERMO ARTEAGA-GOMEZ, Individually and on behalf of all others similarly situated, DATE FILED: January 22, 2015 6:02

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

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT The Honorable Mariane Spearman 1 1 STATE OF WASHINGTON, V. STATE OF WASHINGTON KING COUNTY SUPERIOR COURT Plaintiff, ROTECH HOLDINGS LTD, a New York corporation, d/b/a ROTECH HOLDINGS, RH GROUP, RH HOLDINGS,

More information

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN. v. Case No.: 15-cv-157 CLASS ACTION COMPLAINT

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN. v. Case No.: 15-cv-157 CLASS ACTION COMPLAINT CORY GROSHEK, and all others, similarly situated, Plaintiff, UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN v. Case No.: 15-cv-157 TIME WARNER CABLE INC. Defendant. CLASS ACTION COMPLAINT Plaintiff,

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 1 1 Daniel G. Shay, CA Bar #0 danielshay@tcpafdcpa.com LAW OFFICE OF DANIEL G. SHAY 0 Camino Del Rio South, Suite 1B San Diego, California 0 Tel:.. Fax:.1. Benjamin H. Richman* brichman@edelson.com J.

More information

SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY

SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY THE HONORABLE CAROL MURPHY 1 1 1 1 1 SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY TARVA LEE, ) ) No: --00- Plaintiff, ) ) v. ) COMPLAINT FOR BREACH OF ) CONTRACT, BAD FAITH, FARMERS INSURANCE COMPANY

More information

Case 1:15-cv-13004-GAO Document 1 Filed 07/23/15 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

Case 1:15-cv-13004-GAO Document 1 Filed 07/23/15 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS Case 1:15-cv-13004-GAO Document 1 Filed 07/23/15 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS KEITH MATHEWS On behalf of himself and Others similarly situated Plaintiff, Case

More information

Case 3:08-cv-00920-JAP-JJH Document 1 Filed 02/20/2008 Page 1 of 13 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 3:08-cv-00920-JAP-JJH Document 1 Filed 02/20/2008 Page 1 of 13 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case 3:08-cv-00920-JAP-JJH Document 1 Filed 02/20/2008 Page 1 of 13 Laurence M. Rosen, Esq. THE ROSEN LAW FIRM, P.A. 236 Tillou Road South Orange, NJ 07079 Telephone: (973 313-1887 Fax: (973 833-0399 lrosen@rosenlegal.com

More information

Case 1:10-cv-00168-JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

Case 1:10-cv-00168-JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY Case 1:10-cv-00168-JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY SMART VENT INC., : : Plaintiff, : CIVIL ACTION NO.: : : : USA FLOODAIR VENTS,

More information

IN THE CIRCUIT COURT FOR THE COUNTY OF CUMBERLAND

IN THE CIRCUIT COURT FOR THE COUNTY OF CUMBERLAND VIRGINIA: IN THE CIRCUIT COURT FOR THE COUNTY OF CUMBERLAND JED FAULKNER and MICHAEL ALAN FAULKNER, Plaintiffs, v. CASE NO. HALEY CHEVROLET, OLDSMOBILE, BUICK, INC., SERVE: Barbara S. Picard Registered

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Bryana Bible, SECOND AMENDED CLASS Plaintiff, Court File No. 12-cv-01236-RHK-JSM INTRODUCTION

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Bryana Bible, SECOND AMENDED CLASS Plaintiff, Court File No. 12-cv-01236-RHK-JSM INTRODUCTION CASE 0:12-cv-01236-RHK-JSM Document 50 Filed 04/01/13 Page 1 of 16 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Bryana Bible, SECOND AMENDED CLASS Plaintiff, ACTION COMPLAINT v. JURY TRIAL DEMANDED

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 Case: 1:10-cv-03314 Document #: 17 Filed: 09/30/10 Page 1 of 17 PageID #:63 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION JAMES ROWE, ) individually and on

More information

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA FEDERAL TRADE COMMISSION, Plaintiff, Civil Action No. v. WEBVIPER, LLC; d/b/a Yellow Web Services; and TIGERHAWK, LLC; d/b/a Yellow

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 1:14-cv-00652 Document 1 Filed 07/14/14 Page 1 of 17 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

Case 1:14-cv-00652 Document 1 Filed 07/14/14 Page 1 of 17 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION Case 1:14-cv-00652 Document 1 Filed 07/14/14 Page 1 of 17 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION * FEDERAL TRADE COMMISSION, * * Civil Case No. Plaintiff, * * v.

More information

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF NORTH CAROLINA

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF NORTH CAROLINA Case 1:15-cv-00224-TDS-LPA Document 1 Filed 03/12/15 Page 1 of 15 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF NORTH CAROLINA JAMES J. MAZUR, DPM, and ) JAMES MAZUR, D.P.M., P.A., on behalf of ) themselves

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

ORDERED, ADJUDGED AND DECREED,

ORDERED, ADJUDGED AND DECREED, STEPHEN CALKINS General Counsel CAROLE A. PAYNTER (CP 4091) Federal Trade Commission 150 William Street, 13th floor New York, New York 10038 (212) 264-1225 Attorneys for Plaintiff UNITED STATES DISTRICT

More information

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON COUNTY OF KING. Plaintiff, NO.

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON COUNTY OF KING. Plaintiff, NO. IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON COUNTY OF KING 1 1 1 1 1 ALEXANDRIA PARRY, Plaintiff, NO. vs. COMPLAINT FOR DAMAGES FOR BREACH OF FIDUCIARY DUTY WINDERMERE REAL AND FOR VIOLATION OF ESTATE/EAST,

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) 1 1 1 1 1 1 1 0 1 ALAN HIMMELFARB - SBN 00 KAMBEREDELSON, LLP Leonis Boulevard Vernon, California 00 Telephone: ( - ahimmelfarb@kamberedelson.com JAY EDELSON MICHAEL J. ASCHENBRENER KAMBEREDELSON, LLC

More information

Case: 1:12-cv-01612 Document #: 1 Filed: 03/06/12 Page 1 of 6 PageID #:1

Case: 1:12-cv-01612 Document #: 1 Filed: 03/06/12 Page 1 of 6 PageID #:1 Case: 1:12-cv-01612 Document #: 1 Filed: 03/06/12 Page 1 of 6 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION GARY HANLEY on behalf of himself and

More information

NC General Statutes - Chapter 66 Article 19 1

NC General Statutes - Chapter 66 Article 19 1 Article 19. Business Opportunity Sales. 66-94. Definition. For purposes of this Article, "business opportunity" means the sale or lease of any products, equipment, supplies or services for the purpose

More information

Case 1:13-cv-11944 Document 1 Filed 08/13/13 Page 1 of 9 : : : : : : : : : : :

Case 1:13-cv-11944 Document 1 Filed 08/13/13 Page 1 of 9 : : : : : : : : : : : Case 113-cv-11944 Document 1 Filed 08/13/13 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS Robert Pegg, on behalf of himself and all others similarly situated, v. Plaintiff, Collecto,

More information

SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY. No. I. INTRODUCTION

SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY. No. I. INTRODUCTION 1 1 1 1 1 SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY DANIEL MADISON, SEBRINA MOORE, LARENCE BOLDEN, BEVERLY DUBOIS, and DANIELLE GARNER, v. Plaintiffs, STATE OF WASHINGTON; GARY LOCKE, Governor,

More information

CAUSE NO. IN THE DISTRICT COURT. Xxxxx Yyyyy Plaintiffs JUDICIAL DISTRICT. Aaaaa Bbbbb Cccccc Ddddd WHAT COUNTY, TEXAS. Defendants

CAUSE NO. IN THE DISTRICT COURT. Xxxxx Yyyyy Plaintiffs JUDICIAL DISTRICT. Aaaaa Bbbbb Cccccc Ddddd WHAT COUNTY, TEXAS. Defendants CAUSE NO. Xxxxx Yyyyy Plaintiffs V. Aaaaa Bbbbb Cccccc Ddddd Defendants IN THE DISTRICT COURT JUDICIAL DISTRICT WHAT COUNTY, TEXAS PLAINTIFF S ORIGINAL PETITION AND APPLICATION FOR TEMPORARY RESTRAINING

More information

Complaint as permitted by Case Management Order # 4 and Implementing Order PARTIES, JURISDICTION AND VENUE

Complaint as permitted by Case Management Order # 4 and Implementing Order PARTIES, JURISDICTION AND VENUE [INSERT NAME], Plaintiff(s) vs. HOWMEDICA OSTEONICS CORPORATION, a New Jersey Corporation, d/b/a STRYKER ORTHOPAEDICS, JILL DOE MANUFACTURERS (1-10), JACK DOE WHOLESALERS (1-10), JAKE DOE SELLERS (1-10),

More information

FILED 15 JUL 27 AM 9:22

FILED 15 JUL 27 AM 9:22 FILED JUL AM : KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: --- KNT JUDITH JORGENSEN, vs. SUPERIOR COURT OF WASHINGTON KING COUNTY Plaintiff, JAMES WONG and TYRA WONG, husband and wife creating

More information

FILED 15 JAN 23 PM 3:46

FILED 15 JAN 23 PM 3:46 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY FILED JAN PM : KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: --0- SEA SOLTERRA CITIES, LLC, a Washington company, Plaintiff, v. DUSTIN VAN WYCK, an

More information

Case4:15-cv-04219-DMR Document1 Filed09/16/15 Page1 of 11

Case4:15-cv-04219-DMR Document1 Filed09/16/15 Page1 of 11 Case:-cv-0-DMR Document Filed0// Page of MICHAEL G. RHODES () (rhodesmg@cooley.com) California Street, th Floor San Francisco, CA Telephone: Facsimile: BRENDAN J. HUGHES (pro hac vice to be filed) (bhughes@cooley.com)

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. Case No Civ. Middlebrooks/Bandstra

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. Case No Civ. Middlebrooks/Bandstra UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.01-9096-Civ. Middlebrooks/Bandstra Carmelina Martinez, Jorgelia Velasquez, Esther Ramos, Maria Ester Escobar Torres, Maria Jose Alarcon,

More information

Case: 1:10-cv-02365-SO Doc #: 22 Filed: 07/27/11 1 of 11. PageID #: 564

Case: 1:10-cv-02365-SO Doc #: 22 Filed: 07/27/11 1 of 11. PageID #: 564 Case: 1:10-cv-02365-SO Doc #: 22 Filed: 07/27/11 1 of 11. PageID #: 564 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION ESTATE OF FRANK TOWNSEND, (by Fiduciary and Administrator

More information

Case 2:13-cv-00279-TOR Document 1 Filed 07/30/13 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON

Case 2:13-cv-00279-TOR Document 1 Filed 07/30/13 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 0 JONATHAN E. NUECHTERLEIN General Counsel ROBERT J. SCHROEDER Regional Director NADINE SAMTER, WA Bar # JENNIFER LARABEE, CA Bar # nd Ave., Suite Seattle, WA ( 0- (Samter; ( 0-0 (Larabee Email: nsamter@ftc.gov;

More information

Case 3:13-cv FLW-DEA Document 1 Filed 01/23/13 Page 1 of 21 PageID: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

Case 3:13-cv FLW-DEA Document 1 Filed 01/23/13 Page 1 of 21 PageID: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY Case 3:13-cv-00465-FLW-DEA Document 1 Filed 01/23/13 Page 1 of 21 PageID: 1 MARKS & KLEIN, LLP Gerald A. Marks, Esq. Louis D. Tambaro, Esq. Kristen A. Curatolo, Esq. 63 Riverside Avenue Red Bank, NJ 07701

More information

IN THE UNITED STATES DISTRICT COURT FOR NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

IN THE UNITED STATES DISTRICT COURT FOR NORTHERN DISTRICT OF TEXAS DALLAS DIVISION IN THE UNITED STATES DISTRICT COURT FOR NORTHERN DISTRICT OF TEXAS DALLAS DIVISION JPM NETWORKS, LLC, ) d/b/a KWIKBOOST ) ) Plaintiff, ) ) v. ) Civil Action No. ) 3:14-cv-1507 JCM FIRST VENTURE, LLC )

More information

Case 2:14-cv-00967 Document 1 Filed 07/01/14 Page 1 of 17

Case 2:14-cv-00967 Document 1 Filed 07/01/14 Page 1 of 17 Case :-cv-00 Document Filed 0/0/ Page of 0 DAVID C. SHONKA Acting General Counsel BRIAN S. SHULL JANE M. RICCI bshull@ftc.gov, jricci@ftc.gov, CC-0 Washington, DC 0 P: () -, () - F: () - Attorneys for

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 2:06-cv-15766-JF-SDP Document 69 Filed 02/25/2008 Page 1 of 15

Case 2:06-cv-15766-JF-SDP Document 69 Filed 02/25/2008 Page 1 of 15 Case 2:06-cv-15766-JF-SDP Document 69 Filed 02/25/2008 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. MAZZONI

More information

Case 3:14-cv-00929-AWT Document 1 Filed 06/26/14 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

Case 3:14-cv-00929-AWT Document 1 Filed 06/26/14 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT Case 3:14-cv-00929-AWT Document 1 Filed 06/26/14 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT ZIPLINK, INC., Plaintiff, Civil Action No. v. VERIZON COMMUNICATIONS, INC., JURY

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

SUPERIOR COURT OF WASHINGTON FOR ISLAND COUNTY

SUPERIOR COURT OF WASHINGTON FOR ISLAND COUNTY 1 ROGER L. CLOSE, vs. Plaintiff, ADMIRAL'S COVE BEACH CLUB, INC., a Washington non-profit corporation, now known as ADMIRALS COVE HOMEOWNERS ASSOCIATION, INC., Defendants. SUPERIOR COURT OF WASHINGTON

More information

FILED: NEW YORK COUNTY CLERK 08/28/2013 INDEX NO. 157912/2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/28/2013

FILED: NEW YORK COUNTY CLERK 08/28/2013 INDEX NO. 157912/2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/28/2013 FILED: NEW YORK COUNTY CLERK 08/28/2013 INDEX NO. 157912/2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/28/2013 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK VALENTINO SMITH, individually and on

More information

Case: 1:13-cv-08310 Document #: 1 Filed: 11/19/13 Page 1 of 10 PageID #:1

Case: 1:13-cv-08310 Document #: 1 Filed: 11/19/13 Page 1 of 10 PageID #:1 Case: 1:13-cv-08310 Document #: 1 Filed: 11/19/13 Page 1 of 10 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION MICHAEL GRANT, individually and on

More information

Case 1:16-cv-00320-CBA-PK Document 1 Filed 01/21/16 Page 1 of 8 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK

Case 1:16-cv-00320-CBA-PK Document 1 Filed 01/21/16 Page 1 of 8 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK Case 116-cv-00320-CBA-PK Document 1 Filed 01/21/16 Page 1 of 8 PageID # 1 Frank J. Martinez (FJM-2149) THE MARTINEZ GROUP PLLC 55 Washington Street, Suite 253-C Brooklyn, New York 11201 718.797.2341 Telephone

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

Case3:13-cv-02858-JST Document27 Filed11/27/13 Page1 of 14

Case3:13-cv-02858-JST Document27 Filed11/27/13 Page1 of 14 Case:-cv-0-JST Document Filed// Page of 0 Clayeo C. Arnold, California SBN 00 carnold@justiceyou.com Christine M. Doyle, California SBN 0 cdoyle@justiceyou.com CLAYEO C. ARNOLD, A PROFESSIONAL LAW CORPORATION

More information

Case 1:13-cv-00034-UNA Document 1 Filed 01/04/13 Page 1 of 11 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

Case 1:13-cv-00034-UNA Document 1 Filed 01/04/13 Page 1 of 11 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE Case 1:13-cv-00034-UNA Document 1 Filed 01/04/13 Page 1 of 11 PageID #: 1 STEELHEAD LICENSING LLC, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE v. Plaintiff, AT&T, INC., and AT&T MOBILITY

More information

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

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

0004853 O8. RECEIVED Civil Clk' Office. JUN 2 7 2008 Superior Court of th District of Cohmibja

0004853 O8. RECEIVED Civil Clk' Office. JUN 2 7 2008 Superior Court of th District of Cohmibja C C IN THE SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION 1111 PENNSYLVANIA HOLDINGS LLC, A Delaware Limited Liability Company By and Through Its Managing Member 1111 Penn Holdings-i LLC A

More information

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION. Case No. :

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION. Case No. : UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION PAUL BARRETT, individually and on behalf of all others similarly situated, v. Plaintiff, Case No. : CLASS ACTION

More information

Case 1:13-cv-03258-PAB-KMT Document 23 Filed 02/18/14 USDC Colorado Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 1:13-cv-03258-PAB-KMT Document 23 Filed 02/18/14 USDC Colorado Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case 1:13-cv-03258-PAB-KMT Document 23 Filed 02/18/14 USDC Colorado Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 1:13-cv-03258-PAB-KMT KATHY WORNICKI,

More information

IN THE SUPERIOR COURT FOR THE COUNTY OF RICHMOND, STATE OF GEORGIA. NOW COMES the named plaintiff, for himse_if and all

IN THE SUPERIOR COURT FOR THE COUNTY OF RICHMOND, STATE OF GEORGIA. NOW COMES the named plaintiff, for himse_if and all ! IN THE SUPERIOR COURT FOR THE COUNTY OF RICHMOND, STATE OF GEORGIA L. WAYNE GRIFFIN, and all other persons similarly situated, v. Plaintiffs AMERICAN DEFENDER LIFE INSURANCE COMPANY, Defendant CIVIL

More information

CIVIL DICTRICT COURT PARISH OF ORLEANS STATE OF LOUISIANA

CIVIL DICTRICT COURT PARISH OF ORLEANS STATE OF LOUISIANA CIVIL DICTRICT COURT PARISH OF ORLEANS STATE OF LOUISIANA LESTER ANSARDI, INDIVIDUALLY, AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED SUIT NO. PLAINTIFF VERSUS UNITED STATES MARITIME SERVICES, INC., UNITED

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE ) ) ) ) ) ) ) ) ) ) ) ) ) ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MICROSOFT CORPORATION, a Washington Corporation v. Plaintiff, SALESFORCE.COM, INC., a Delaware Corporation Defendants. UNITED STATES DISTRICT

More information

Case 3:14-cv-00645-ST Document 126 Filed 06/04/15 Page 1 of 15

Case 3:14-cv-00645-ST Document 126 Filed 06/04/15 Page 1 of 15 Case 3:14-cv-00645-ST Document 126 Filed 06/04/15 Page 1 of 15 Beth E. Terrell, Admitted Pro Hac Vice Email: bterrell@tmdwlaw.com Michael D. Daudt, Admitted Pro Hac Vice Email: mdaudt@tmdwlaw.com Jennifer

More information

CAUSE NO. DC-12-07825

CAUSE NO. DC-12-07825 CAUSE NO. DC-12-07825 Filed 13 September 9 P4:46 Gary Fitzsimmons District Clerk Dallas District CADE MANNETTI, v. Plaintiff, VISIONARY RESTAURANTS LLC, VISIONARY STAFFING LLC, WILLIAM McCROREY, AND THOMAS

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE. No. 2:11-cv-908

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE. No. 2:11-cv-908 1 1 1 1 1 1 0 1 HTC AMERICA, INC., a Washington corporation, HTC CORPORATION, a Taiwanese corporation, and EXEDEA INC., a Texas corporation, v. UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) FEDERAL TRADE COMMISSION, ) ) Plaintiff, ) ) v. ) ) Civil No. CONTROLSCAN, INC., ) a corporation, ) ) Defendant. ) ) COMPLAINT

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

STATE OF WASHINGTON SNOHOMISH COUNTY SUPERIOR COURT NO. Attorney General, and Audrey L. Udashen, Assistant Attorney General, brings this action

STATE OF WASHINGTON SNOHOMISH COUNTY SUPERIOR COURT NO. Attorney General, and Audrey L. Udashen, Assistant Attorney General, brings this action 1 1 1 1 1 STATE OF WASHINGTON, V. STATE OF WASHINGTON SNOHOMISH COUNTY SUPERIOR COURT Plaintiff, MICHAEL'S OFFICE LLC; MYKHAYLO BENDZAR a/k/a MICHAEL BENDZAR, in his individual capacity and d/b/a MICHAEL'S

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

Case 6:14-cv-00011-WSS Document 1-24 Filed 01/13/14 Page 1 of 35 EXHIBIT F

Case 6:14-cv-00011-WSS Document 1-24 Filed 01/13/14 Page 1 of 35 EXHIBIT F Case 6:14-cv-00011-WSS Document 1-24 Filed 01/13/14 Page 1 of 35 EXHIBIT F Case 6:14-cv-00011-WSS Document 1-24 Filed 01/13/14 Page 2 of 35 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS FEDERAL

More information

No. ) ) COMES NOW the plaintiff by and through her attorney, Roger K. Anderson, and states her I. PARTIES AND JURISDICTION

No. ) ) COMES NOW the plaintiff by and through her attorney, Roger K. Anderson, and states her I. PARTIES AND JURISDICTION FILED 1 MAY 1 AM :0 1 KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: 1--8-1 SEA 3 8 IN THE SUPERIOR COURT OF WASHINGTON FOR KING COUNTY SANDRA S. NOREEN, Plaintiff, vs. 1 MICHAEL W. BUGNI, individually

More information

Case 3:15-cv-00592-LAB-BLM Document 1 Filed 03/16/15 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA

Case 3:15-cv-00592-LAB-BLM Document 1 Filed 03/16/15 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA Case :-cv-00-lab-blm Document Filed 0// Page of 0 ERIC H. HOLDER, JR. Attorney General VANITA GUPTA Acting Assistant Attorney General STEVEN H. ROSENBAUM Chief, Housing and Civil Enforcement Section ELIZABETH

More information

Case 1:12-cv-01374-RJJ Doc #28 Filed 06/10/13 Page 1 of 15 Page ID#165 UNITED STATES DISTRICT COURT IN THE WESTERN DISTRICT OF MICHIGAN

Case 1:12-cv-01374-RJJ Doc #28 Filed 06/10/13 Page 1 of 15 Page ID#165 UNITED STATES DISTRICT COURT IN THE WESTERN DISTRICT OF MICHIGAN Case 1:12-cv-01374-RJJ Doc #28 Filed 06/10/13 Page 1 of 15 Page ID#165 CHRISTOPHER FRANKE, Plaintiff, UNITED STATES DISTRICT COURT IN THE WESTERN DISTRICT OF MICHIGAN -vs- Case No. 12-1374 Hon. Robert

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION PLAINTIFF S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION PLAINTIFF S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT WIRELESS MOBILE DEVICES LLC, IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION v. Plaintiff, HUAWEI TECHNOLOGIES CO. LTD.; HUAWEI DEVICE USA INC.; and T-MOBILE US,

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Case 1:13-cv-02282-RWS Document 1 Filed 07/09/13 Page 1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION DE ANGELO BENTLEY, ) MARQUES ROBERTSON, ) IKEYMA MCKENTRY, ) individually,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION SIMON DOMINGUEZ, PEDRO DOMINGUEZ, JOSE FRANCISCO BRIONES, and ROBERT PEREZ On Behalf of Themselves and All

More information

Florida Senate - 2016 SB 872

Florida Senate - 2016 SB 872 By Senator Bean 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 A bill to be entitled An act relating to federal immigration enforcement; providing a short title; creating

More information

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA H.L. WATKINS AND COMPANY, INC., ) ) PLAINTIFF, ) ) CIVIL ACTION FILE NO. v. ) ) 06-CV8980-3 THE HOT LEAD COMPANY, LLC, ) ROBERT MICHAEL HORNE, )

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Harvey C. Berger (SBN POPE & BERGER 0 West "C" Street, Suite 100 San Diego, California 1 Telephone: (1-1 Facsimile: (1 - Attorneys for Plaintiff PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND

More information

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 CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA DEAN KUMANCHIK, vs. Plaintiff, Case No.: UNIVERSAL CITY DEVELOPMENT PARTNERS, LTD d/b/a UNIVERSAL STUDIOS, a Florida

More information

CAUSE NO. PLAINTIFF S ORIGINAL PETITION. Greg Abbott, and complains of OLD UNITED LIFE INSURANCE COMPANY ( Defendant ), and I.

CAUSE NO. PLAINTIFF S ORIGINAL PETITION. Greg Abbott, and complains of OLD UNITED LIFE INSURANCE COMPANY ( Defendant ), and I. CAUSE NO. STATE OF TEXAS, Plaintiff, v. OLD UNITED LIFE INSURANCE COMPANY, Defendant. IN THE DISTRICT COURT OF TRAVIS COUNTY, TEXAS JUDICIAL DISTRICT PLAINTIFF S ORIGINAL PETITION TO THE HONORABLE JUDGE

More information

Case 1:08-bk-16378 Doc 221 Filed 03/30/09 Entered 03/30/09 15:26:41 Desc Main Document Page 1 of 22

Case 1:08-bk-16378 Doc 221 Filed 03/30/09 Entered 03/30/09 15:26:41 Desc Main Document Page 1 of 22 Document Page 1 of 22 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF TENNESSEE AT CHATTANOOGA IN RE: STEVE A. MCKENZIE CHAPTER 11 Debtor 08-bk-16378-rts WENDY BETTS, DONNA REUTER, TIFFANY KELLY, and

More information

) CIVIL NO. v. ) WORLD CLASS NETWORK, INC., ) a Nevada corporation; ) COMPLAINT FOR ) RELIEF. DANIEL R. DIMACALE, an individual; )

) CIVIL NO. v. ) WORLD CLASS NETWORK, INC., ) a Nevada corporation; ) COMPLAINT FOR ) RELIEF. DANIEL R. DIMACALE, an individual; ) 1 1 1 1 1 1 1 0 1 STEPHEN CALKINS General Counsel ANN I. JONES RAYMOND E. McKOWN Federal Trade Commission 100 Wilshire Blvd., Suite Los Angeles, California 00 ( -00 JOHN ANDREW SINGER Federal Trade Commission

More information

2:14-cv-03460-RMG Date Filed 08/27/14 Entry Number 1 Page 1 of 8

2:14-cv-03460-RMG Date Filed 08/27/14 Entry Number 1 Page 1 of 8 2:14-cv-03460-RMG Date Filed 08/27/14 Entry Number 1 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION DANIEL CHRISTOPHER DRUMMOND AND PAULANN PERRY,

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO UNLIMITED CIVIL CASE

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO UNLIMITED CIVIL CASE Christopher B. Dolan (SBN ) Shawn R. Miller (SBN ) Market Street San Francisco, CA Tel: () -00 Fax: () -0 Attorneys for Plaintiff CHARLENE HASTINGS IN SUPERIOR COURT OF STATE OF CALIFORNIA IN AND FOR COUNTY

More information

Colorado Revised Statutes 2013 TITLE 21

Colorado Revised Statutes 2013 TITLE 21 Colorado Revised Statutes 2013 TITLE 21 STATE PUBLIC DEFENDER ARTICLE 1 State Public Defender 21-1-101. Public defender - policy - commission. (1) The office of state public defender is hereby created

More information

4:15-cv-00432-RBH Date Filed 01/29/15 Entry Number 1 Page 1 of 10

4:15-cv-00432-RBH Date Filed 01/29/15 Entry Number 1 Page 1 of 10 4:15-cv-00432-RBH Date Filed 01/29/15 Entry Number 1 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION Ryan Michael Stinnett, on behalf of himself CASE

More information

CASE 0:11-cv PAM-LIB Document 1 Filed 11/01/11 Page 1 of 11 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA FIFTH DIVISION - DULUTH

CASE 0:11-cv PAM-LIB Document 1 Filed 11/01/11 Page 1 of 11 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA FIFTH DIVISION - DULUTH CASE 0:11-cv-03226-PAM-LIB Document 1 Filed 11/01/11 Page 1 of 11 ------------------------------------------------------ DIRECTV, Inc., a California corporation, UNITED STATES DISTRICT COURT FOR THE DISTRICT

More information

Case 1:15-cv RGS Document 1 Filed 12/14/15 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

Case 1:15-cv RGS Document 1 Filed 12/14/15 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS Case 1:15-cv-14131-RGS Document 1 Filed 12/14/15 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS DOCKET NO.: STRATHMORE INSURANCE COMPANY a/s/o PIZZI FARMS CONDOMINIUM TRUST

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

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in Weld County, Colorado, District Court, 901 9 th Avenue Greeley, CO 80631 970.351.7300 Plaintiff: vs. Defendants: JENNIFER BELL, individually and on behalf of all others similarly situated, BRADLEY PETROLEUM,

More information

Case: 3:12-cv-00012-wmc Document #: 1 Filed: 01/05/12 Page 1 of 11 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN. Defendants.

Case: 3:12-cv-00012-wmc Document #: 1 Filed: 01/05/12 Page 1 of 11 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN. Defendants. Case: 3:12-cv-00012-wmc Document #: 1 Filed: 01/05/12 Page 1 of 11 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN FATWALLET, INC., a Delaware corporation, v. ANDREW CHIU, an individual, and

More information

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF NORTH CAROLINA GREENSBORO DIVISION CLASS ACTION COMPLAINT

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF NORTH CAROLINA GREENSBORO DIVISION CLASS ACTION COMPLAINT Case 1:15-cv-00937-CCE-JLW Document 1 Filed 11/09/15 Page 1 of 7 MICHELE A. TRAPP, on behalf of herself and others similarly situated Plaintiffs, UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF NORTH CAROLINA

More information

misleading labeling and marketing of merchandise it sells at its company-owned Levi s Outlet stores

misleading labeling and marketing of merchandise it sells at its company-owned Levi s Outlet stores 1 misleading labeling and marketing of merchandise it sells at its company-owned Levi s Outlet stores ( Levi s Outlet ).. During the Class Period (defined below), Levi s misrepresented the existence, nature

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION WAYNE WILLIAMS, on behalf of himself and all others similarly situated, v. Plaintiff, PROTECT SECURITY, LLC. Defendant.

More information

SUPERIOR COURT OF WASHINGTON, COUNTY OF KING THIS NOTICE MAY AFFECT YOUR RIGHTS PLEASE READ IT CAREFULLY

SUPERIOR COURT OF WASHINGTON, COUNTY OF KING THIS NOTICE MAY AFFECT YOUR RIGHTS PLEASE READ IT CAREFULLY SUPERIOR COURT OF WASHINGTON, COUNTY OF KING MYSPINE, PS, a Washington professional services corporation; BODY RECOVERY CLINIC LLC, a Washington Limited Liability Company; and YAROSLAV KUTSY, Plaintiffs,

More information

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) )

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) Case :-cv-00-loa Document Filed 0// Page of 0 Bradley Jardis, vs. Keith M. Knowlton, L.L.C. SBN 0 S. Rural Road, Suite 0, PMB# Tempe, Arizona -00 (0 -; FAX (0 - Keith M. Knowlton - SBN 0 Attorney for Plaintiff

More information