Mey v. Protect America, Inc. et al - 5:18cv161 · 2019-12-25 · Case 5:18-cv-00161-FPS Document 1...

Case 5:18-cv-00161-FPS Document 1 Filed 09/21/18 of 13 PagelD #: 1

UNITED STATE DISTRICT COURTNORTHERN DISTRICT OF WEST VIRGINIA ELECTRONICALL

WHEELING DIVISION FILED

Sep 21 2018DIANA MEY, individually and on behalf of a class U.S. DISTRICT COURT

Nof all persons and entities similarly situated,orthern District ofWV

Plaintiff,

vs. Case No. 5:18-CV-161 (Stamp)

PROTECT AMERICA, INC.,WAHAB GLOBAL COMMUNICATIONS, LLC,and MAHTAB AFGAN,

Defendants.

CLASS ACTION COMPLAINT

Preliminary Statement

Plaintiff Diana Mey brings this action under the Telephone Consumer Protection

Act (TCPA"), 47 U.S.C. § 227, et seq., a federal statute enacted in response to widespread

public outrage about the proliferation of intrusive, nuisance telemarketing practices. See Mims v.

Arrow Fin. Servs., LLC, 132 S. Ct. 740, 745 (2012).

2. Plaintiff brings the action to enforce the TCPA in the face of rampant illegal

telemarketing in the home-security industry.

Here, Defendant Protect America, Inc. ("PAI"), which describes itself as a leading

provider ofwireless home security in North America, retained Defendant Wahab Global

Communications, LLC (Wahab Global") to obtain new customers for PAI using telemarketing.

4. Defendant Wahab Global — acting on behalf ofDefendant PAI and as its agent —

placed an illegal telemarketing call to Plaintiff s cellular telephone number, which has been on

the National Do Not Call Registry for many years, without her express consent, in violation of

the TCPA.


Because the call to the Plaintiff was transmitted using technology capable of

generating thousands of similar calls per day, Plaintiff sues on behalf of a proposed nationwide

class of other persons who received similar illegal calls.

6. A class action is the best means of obtaining redress for the Defendantsillegal

telemarketing, and is consistent both with the private right of action afforded by the TCPA and

the fairness and efficiency goals ofRule 23 of the Federal Rules ofCivil Procedure.

Parties

7. Plaintiff Diana Mey resides in this district.

8. Defendant Protect America, Inc. is a Texas corporation with its principal place of

business in Austin, Texas. It transacts business throughout the United States, including in this

district.

9. Defendant Wahab Global Communications, LLC is an Ohio limited liability

company with its principal place ofbusiness at 5076 Criterion Way in Dublin, Ohio. Wahab

Global transacts business throughout the United States, including in this district.

10. Defendant Mahtab Afgan owns and operates Defendant Wahab Global. At all

times, Mr. Afgan directed Wahab Global's operations, and is liable for its illegal calls as alleged

below.

Jurisdiction & Venue

11. This Court has federal question jurisdiction under 28 U.S.C. § 1331.

12. Venue is proper under 28 U.S.C. § 1391(b)(2) because a substantial part of the

events or omissions giving rise to the claim — namely, the automated calls to the Plaintiff —

occurred in this district.

2


Statutory Background

13. In 1991, Congress enacted the TCPA to regulate the explosive growth of the

telemarketing industry. In so doing, Congress recognized that "[u]nrestricted telemarketing...

can be an intrusive invasion ofprivacyll" Telephone Consumer Protection Act of 1991, Pub. L.

No. 102-243, § 2(5) (1991) (codified at 47 U.S.C. § 227).

14. Perhaps the most well-known aspect of the TCPA was the creation of the National

Do Not Call Registry. By adding a telephone number to the Registry, a consumer indicates her

desire not to receive telephone solicitations. See 47 C.F.R. § 64.1200(c)(2).

15. Accordingly, the TCPA and its implementing regulations prohibit the initiation of

telephone solicitations to residential telephone subscribers to the Registry. 47 U.S.C. § 227(c);

47 C.F.R. § 64.1200(c)(2).

16. The TCPA also makes it unlawful to (1) make calls to cellular telephone lines

using an "automatic telephone dialing system," or (2) make calls to any cellular or residential

line using an artificial or prerecorded voice, without the call recipient's prior express consent.

See 47 U.S.C. § 227(b)(1)(A) & (B); In re Rules & Regulations Implementing the Tel. Consumer

Prot. Act of1991, 27 F.C.C. Rcd. 1830, 1844 (2012).

17. The FCC has explained that such calls are prohibited because, as Congress found,

automated or prerecorded telephone calls are a greater nuisance and invasion ofprivacy than live

solicitation calls and can be costly and inconvenient.

18. Because allowing an entity "to avoid potential liability by outsourcing its

telemarketing activities to unsupervised third parties would leave consumers in many cases

without an effective remedy for telemarketing intrusions," the FCC has consistently held that a

corporation or other entity "may be held vicariously liable under federal common law principles


of agency for violations of either section 227(b) or section 227(c) that are committed by third-

party telemarketers." In re Joint Petition Filed by DISH Network, LLC et al. for Declaratory

Ruling Concerning the TCPA Rules, 28 FCC Rcd. 6574, 6574 (1 1) (2013) ("May 2013 FCC

Ruline).

19. Under the TCPA, an individual such as Defendant Afgan may be personally liable

for TCPA violations under 47 U.S.C. § 217, which provides that "the act, omission, or failure of

any officer, agent, or other person acting for or employed by any common carrier or user,

acting within the scope of his employment, shall in every case be also deemed to be the act,

omission, or failure of such carrier or user as well as ofthatperson." Id. (emphasis added). See

alsoackson Five Star Catering, Inc. v. Beason, 2013 U.S. Dist. LEXIS 159985, *10 (E.D.

Mich. Nov. 8, 2013) ([M]any courts have held that corporate actors can be individually liable

for violating the TCPA "where they 'had direct, personal participation in or personally authorized

the conduct found to have violated the statute.); Maryland v. Universal Elections, 787 F. Supp.

2d 408, 415-16 (D. Md. 2011) (If an individual acting on behalf of a corporation could avoid

individual liability, the TCPA would lose much of its force.").

20. Defendant Afgan is personally liable under the "participation theory" of liability

because he is believed to be the only officer ofDefendant Wahab Global, knew of its TCPA

violations, and caused it to commit those violations.

21. Defendant Afgan authorized and oversaw all ofDefendant Wahab Global's

telemarketing processes.

22. Defendant Afgan identifies himself as a "seasoned call center executive, sales

leader and strategist." See https://www.freelancer.es/u/mahtab7 (Last Visited July 9, 2018).

4


Factual Allegations

Calls from Defendants PAI and Wahab Global

23. On May 24, 2018, Defendant Wahab Global made a telemarketing call to

Plaintiff s cellular telephone line, (304) 242-XXXX, a number that had been listed on the

National Do Not Call Registry for more than 31 days prior to the calls at issue.

24. Plaintiff s caller ID showed that the call was placed from (703) 225-5000.

25. Other persons have complained about receiving calls from this number. For

example, the website Nomorobo identifies this number as "a Robocaller." See

https://www.nomorobo.com/lookup/703-225-5000 (Last Visited July 9, 2018).

26. Additionally, the website "Should I Answer?" has identified four ratings for this

number, all ofwhich are "negative and associated with unsolicited telemarketing. See

https://www.shouldianswer.com/phone-number/7032255000 (Last Visited July 9, 2018).

27. The telephone number (703) 225-5000 is not the Defendantsactual number. It is

a number for persons to call to request birth certificates in Alexandra, Virginia. See

https://www.alexandriava.gov/uploadedFiles/Homepage_Quicldinks/info/annual_report_1999/ar

99_frequentlycallednos.pdf (Last Visited July 9, 2018).

28. Defendant Wahab Global "spoofee the number on the caller ID. That is, it used

a false number on the caller ID in order to mask the fact that the caller was a telemarketer, and to

mask the identity of the caller generally.

29. When Plaintiff received the call, she heard a distinctive "click and pause" sound

when she picked up the phone.

30. This sound is consistent with use of a predictive dialer, which is automated

dialing equipment subject to the TCPA's restrictions.

5


31. When Plaintiff answered the phone, she said "hello" at least four times into the

telephone before anyone appeared on the telephone.

32. During the call, Defendant Wahab Global made a scripted sales pitch to Plaintiff

regarding home security and monitoring services.

33. During a later call, a telemarketing representative for Defendant Wahab Global

told Plaintiff he was having an issue with the "dialer."

34. All of these facts indicate that the calls were made with an automatic telephone

dialing system as that term is defined in 47 U.S.C. § 227(a)(1).

35. Shortly after the first call ended, Defendant Wahab Global made another

telemarketing call to Plaintiff s same cellular telephone line.

36. During that call, Plaintiff was transferred to Aaron Burlingame, a "security

specialistat PAI.

37. On that call, Mr. Burlingame told Plaintiff that "protectamerica.com" was the

company's website.

38. That website is owned and operated by Defendant PAI.

39. Mr. Burlingame later sent Plaintiff an e-mail from the address

"[email protected]," an address belonging to Defendant PAI.

40. Mr. Burlingame also told Plaintiff that Defendant Wahab Global placed the call to

her, and that it operated out of the State ofWashington — further evidence of the Defendants'

spoofing, given the fact that the caller ID displayed a Virginia area code.

41. Mr. Burlingame told Plaintiff that Defendant Wahab Global was a "lead

generate' for Defendant PAI, paid to generate sales leads for PAI.

6


42. Plaintiff told Mr. Burlingame that her number was on the National Do Not Call

Registry and was a wireless number that could not be autodialed without her consent.

43. She asked that her number be placed on Defendant PAI's internal Do Not Call

list, and that she participated in the illegal call in order to determine who placed the call so that

the calls would stop.

44. Despite this request, "Joey" with Defendant PAI called her on May 27, 2018 in

order to sell her PAI's alarm services.

45. Plaintiff and all class members were harmed by these calls in that they were

temporarily deprived of legitimate use of their phones, and their privacy and seclusion was

invaded.

46. Plaintiff did not give the Defendants prior express written consent to place the

telemarketing calls.

47. In fact, before she filed suit, Plaintiff wrote the Defendants requesting any

evidence they had ofher prior express written consent to make these calls. The Defendants did

not provide that information.

Defendant PAI is Vicariously Liablefor Illegal Calls Placed by Wahab Global

48. It has long been the law that a seller of goods or services can be liable for TCPA

violations even if the seller does not directly place or initiate the calls.

49. As explained by the FCC, the TCPA and its regulations "generally establish that

the party on whose behalf a solicitation is made bears ultimate responsibility for any violations."

See Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991,

Mem. and Order, 10 FCC Rcd. 12391, 12397 If 13 (1995).

7


50. The FCC reiterated this principle in 2005, when it stated that "a company on

whose behalf a telephone solicitation is made bears the responsibility for any violation of our

telemarketing rules, and calls placed by a third party on behalf of that company are treated as if

the company itself placed the call." See Rules and Regulations Implementing the Telephone

Consumer Protection Act of 1991; Request of State Farm Mutual Automobile Insurance

Company for Clarification and Declaratory Ruling, Declaratory Ruling, 20 FCC Rcd. 13664,

13667 If 7 (2005).

51. The FCC reaffirmed this in 2013, when it held (a) with respect to violations of

§ 227(b), a seller may be liable under principles of apparent authority, actual authority, and

ratification for telemarketing violations placed by third parties, and (b) with respect to violations

of § 227(c), a seller may be liable under those same principles, and, under the express terms of

the statute, for calls placed "on behalf ofthe seller. In re Joint Pet. Filed by Dish Network, 28

FCCR 6574 (2013).

52. Under these principles, Defendant PAI is vicariously liable for illegal calls placed

by Defendant Wahab Global and other telemarketers.

Class Action Allegations

53. As authorized by Rule 23 of the Federal Rules of Civil Procedure, Plaintiff sues

on behalf of all other persons or entities similarly situated throughout the United States.

54. The classes ofpersons Plaintiff proposes to represent include:

CLASS 1:

All persons within the United States to whom, within the four years prior to thefiling of this action, Defendants placed a call on his or her cellular telephone line,using equipment that has the capacity to dial numbers automatically withouthuman intervention, attempting to sell Defendants' goods or services and whereDefendants' records do not indicate prior express consent from the recipient.

8


CT,ASS 2!

All persons within the United States whose telephone numbers were listed on the Do NotCall Registry, and to whom, at any time within the four years prior to the filing of thisaction, more than one call within any twelve-month period was placed by or at thedirection ofDefendants called to promote the sale ofDefendantsproducts or services.

55. Excluded from the classes are the Defendants, any entities in which the

Defendants have a controlling interest, the Defendants' agents and employees, any Judge to

whom this action is assigned, and any member of the Judge's staff and immediate family.

56. The proposed class members are identifiable through phone records and phone

number databases that will be obtained through discovery.

57. The potential class members number in the thousands, at least. Individual joinder

of these persons is impracticable.

58. Plaintiff is a member of the classes.

59. There are questions of law and fact common to Plaintiff and the proposed class,

including but not limited to:

a. Whether the Defendants used an ATDS to send telemarketing calls;

b. Whether the Defendants placed telemarketing calls without obtaining the

recipients' valid prior express written consent;

c. Whether the Defendants' placed more than one call within a 12-month

period to numbers on the Do Not Call Registry;

d. Whether the Defendants' violations of the TCPA were negligent, willful, or

knowing; and

e. Whether the Plaintiff and the class members are entitled to statutory

damages because of the Defendants' actions.

9


60. Plaintiff s claims are based on the same facts and legal theories, and therefore are

typical of, the claims of class members.

61. Plaintiff is an adequate representative of the classes because her interests do not

conflict with the interests of the classes, she will fairly and adequately protect the interests of the

class, and she is represented by counsel skilled and experienced in class actions, including TCPA

class actions.

62. The actions of the Defendants are applicable to the classes and to Plaintiff.

63. Common questions of law and fact predominate over questions affecting only

individual class members, and a class action is the superior method for fair and efficient

adjudication of the controversy. The only individual question concerns identification of class

members, which will be ascertainable from records maintained by Defendants and through

reliable databases.

64. The likelihood that individual class members will prosecute separate actions is

remote due to the time and expense necessary to prosecute an individual case, and given the small

recoveries available through individual actions.

65. Plaintiff is not aware of any litigation concerning this controversy already

commenced by others who meet the criteria for class membership described above.

Legal Claims

Count One:Violation of the TCPA's provisions

Prohibiting Autodialer Calls to Cell Phones

66. Plaintiff incorporates the allegations from all previous paragraphs as if fully set

forth herein.

10


67. The Defendants violated the TCPA by (a) initiating a telephone call using an

automated dialing system or prerecorded voice to Plaintiff s telephone number assigned to a

cellular telephone service, or (b) by the fact that others caused the initiation of those calls on

their behalves. See 47 C.F.R. 64.1200(a)(1)(iii); 47 U.S.C. § 227(b)(1).

68. The Defendantsviolations were negligent and/or knowing.

Count Two:Violation of the TCPA's Do Not Call Provision

69. Plaintiff incorporates the allegations from all previous paragraphs as if fully set

forth herein.

70. The Defendants violated the TCPA by (a) initiating more than one telephone call

to the Plaintiff in a twelve-month period while her number was on the National Do Not Call

Registry or (b) by the fact that others caused the initiation of those calls on their behalves. See

47 U.S.C. § 227(c).

71. The Defendants' violations were negligent and/or knowing.

Relief Sought

Plaintiff requests the following relief:

A. That the Court certify the proposed classes;

B. That the Court appoint Plaintiff as class representative;

C. That the Court appoint the undersigned counsel as counsel for the class;

D. That the Court enter a judgment permanently enjoining the Defendants from

engaging in or relying upon telemarketing, or, alternatively, from engaging in or relying upon

telemarketing that violates the TCPA;

E. That, should the Court permit Defendants to engage in or rely on telemarketing, it

enter a judgment requiring them to adopt measures to ensure TCPA compliance, and that the

11


Court retain jurisdiction for a period of six months to ensure that the Defendants comply with

those measures;

F. That the Court enter a judgment awarding any other injunctive reliefnecessary to

ensure the Defendantscompliance with the TCPA;

G. That the Court enter a judgment finding that Defendants are jointly and severally

liable to Plaintiffs and all class members for all violations arising from the calls;

H. That Defendants and their agents, or anyone acting on their behalves, be

immediately restrained from altering, deleting or destroying any documents or records that could

be used to identify class members;

I. That the Court enter a judgment awarding Plaintiff and all class members

statutory damages of $500 for each negligent violation of the TCPA and $1,500 for each

knowing or willful violation;

J. That the Court enter an order awarding the Plaintiff reasonable attorneys' fees and

costs; and

K. That the Plaintiff and all class members be granted other relief as is just and

equitable under the circumstances.

Plaintiffs requests a jury trial as to all claims of the complaint so triable.

Diana Mey,By Counsel,

/s/John W. BarrettJohn W. Barrett (WV Bar No. 7289)Sharon F. Iskra (WV Bar No. 6582)BAILEY & GLASSER LLP209 Capitol StreetCharleston, WV 25301

Telephone: (304) [email protected]@baileyglasser.com

12


Edward A. Broderick (pro hac vice pending)Anthony Paronich (pro hac vice pending)BRODERICK & PARONICH, P.C.99 High St., Suite 304Boston, MA 02110

Telephone: (617) [email protected]@broderick-law.com

Matthew P. McCue (pro hac vice pending)THE LAW OFFICE OF MATTHEW P. McCuE1 South Avenue, Suite 3Natick, MA 01760

Telephone: (508) [email protected]

13

JS44 (Rev. 12/07) CiVIL COVER SHEET 5:18-CV-161 Received: 09/21/2018The JS44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service ofpleadings or other papers as required bylaw, except as providedby local rules of court. This form, approved by the Judicial Conference ofthe United States in September1974, is required for the use of the Clerk ofCourt for the purpose of mitiatingthe civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

I. (a) PLAINTIFFS

PROTECT AMERICA, INC., WAHAB GLOBALCOMMUNICATIONS, LLC and MAHTAB AFGAN

County of Residence of First Listed Defendant

__________________________

(IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THELAND INVOLVED.

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) Ill. CITIZENSHIP OF PRINCIPAL PARTIES(Place an “X” in One Box for Plaintiff(For Diversity Cases Only) and One Box for Defendant)

El 1 U.S. Government 3 Federal Question PTF DEF PTF DEFPlaintiff (U.S. Government Not a Party) Citizen of This State X I El 1 Incorporated or Principal Place El 4 El 4

of Business In This State

El 2 U.S.Govermnent El 4 Diversity Citizen of Another State [El 2 El 2 IncorporatedandPrincipalPlace El 5 5Defendant . of Business In Another State(Indicate Citizenship of Parties m Item III)

Citizen or Subject of a El 3 El 3 Foreign Nation El 6 El 6Foreign Country

IV. NATURE OF SUIT (Place an “X” in One Box Only)CONTRACT :TORTS FORFEITURE/PENALTY . BANKRUPTCY: OTRERSTATUTESZ1

El 110 Insurance PERSONAL INJURY PERSONAL INJURY El 610 Agriculture El 422 Appeal 28 USC 158 El 400 State ReapportionmentEl 120 Marine El 310 Airplane El 362 Personal Injury - El 620 Other Food & Drug [El 423 Withdrawal El 410 AntitrustEl 130 Miller Act El 315 Airplane Product Med. Malpractice El 625 Drug Related Seizure 28 USC 157 El 430 Banics and BankingEl 140 Negotiable Instrument Liability [El 365 Personal Injury - of Property 21 USC 881 El 450 CommerceEl 150 Recovery of Overpayment El 320 Assault, Libel & Product Liability El 630 Liquor Laws PRO1’ERTY RIGHTS:: El 460 Deportation

& Enforcement ofJudgment Slander El 368 Asbestos Personal El 640 R.R. & Truck El 820 Copyrights El 470 Racketeer Influenced andEl 151 Medicare Act El 330 Federal Employers’ Injury Product El 650 Airline Regs. El 830 Patent Corrupt OrganizationsEl 152 Recovery of Defaulted Liability Liability El 660 Occupational El 840 Trademark El 480 Consumer Credit

Student Loans [El 340 Marine PERSONAL PROPERTY Safety/Health [El 490 Cable/Sat TV(ExcI. Veterans) El 345 Marine Product [El 370 Other Fraud tEl 690 Other El 810 Selective Service

El 153 Recovery of Overpayment Liability El 371 Truth in Lending &:SOCT4LSECIJRJ’IY::: El 850 Securities/Commodities!of Veteran’s Benefits El 350 Motor Vehicle El 380 Other Personal El 710 Fair Labor Standards El 861 lIlA (1395ff) Exchange

El 160 Stockholders’ Suits El 355 Motor Vehicle Property Damage Act El 862 Black Lung (923) El 875 Customer ChallengeEl 190 Other Contract Product Liability El 385 Property Damage El 720 Labor/Mgmt. Relations [El 863 DIWC/DIWW (405(g)) 12 USC 3410El 195 Contract Product Liability [El 360 Other Personal Product Liability [El 730 Labor/Mgmt.Reporting El 864 Sfl) Title XVI 890 Other Statutory ActionsEl 196 Franchise Injury & Disclosure Act El 865 RSI (405(g)) El 891 Agricultural Acts[::;REALPROPERTY :;CIVJLRIGHTh::::, PRlSONERpETmONS El 740 Railway Labor Act S-FEDERALTAXSU8TS:: El 892 Economic Stabilization ActEl 210 Land Condemnation El 441 Voting El 510 Motions to Vacate El 790 Other Labor Litigation El 870 Taxes (U.S. Plaintiff [El 893 Environmental MattersEl 220 Foreclosure El 442 Employment Sentence El 791 EmpI. Ret. Inc. or Defendant) El 894 Energy Allocation ActEl 230 Rent Lease St Ejecinient El 443 Housing! Habeas Corpus: Security Act [El 871 IRS—Third Party El 895 Freedom of InformationEl 240 Torts to Land Accommodations El 530 General 26 USC 7609 ActEl 245 Tort Product Liability El 444 Welfare El 535 Death Penalty ‘:lMMIGRATJON El 900AppeaI of Fee DeterminationEl 290 All Other Real Property El 445 Amer. w/Disabililies - El 540 Mandamus & Other El 462 Naturalization Application Under Equal Access

Employment El 550 Civil Rights El 463 Habeas Corpus - to Justice[El 446 Amer. w/Dissbilities - [El 555 Prison Condition Alien Detainee El 950 Constitutionality of

Other [El 465 Other Immigration State StatutesEl 440 Other Civil Rights Actions

V. ORIGIN (Place an “x” in One Box Only) Appeal to DistrictEli Original 1] 2 Removed from 3 Remanded from C] 4 Reinstated or C] 5 Tranfetd om C] 6 Multidislrict from

Proceeding State Court Appellate Court Reopenedeci’)

lstflct Litigation

I C under which you are filing (Do not cite jurisdictional statutes unless diversity):

VI. CAUSE OF ACTION Brief description of cause:Violation to TUPA, including calls to phone numbers on Do Not Gall Registry and use ot autodialer

VII. REQUESTED IN h7J CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:

COMPLAINT: UNDER F.R.C.P. 23 JURY DEMAND: Yes [El No

VIII. RELATED CASE(S)

IF ANY(See instructions):

JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

09/21/2018 /s/John W. BarrettFOR OFFICE USE ONLY

DEFENDANTS

DIANA MEY

(b) County of Residence of First Listed Plaintiff OHIO(EXCEPT IN U.S. PLAINTIFF CASES)

(c) Attorney’s (Firm Name, Address, and Telephone Number)

See attachment.

Attomeys (If Knoun)

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 5:18-cv-00161-FPS Document 1-1 Filed 09/21/18 Page 1 of 2 PageID #: 14

DIANA MEY v. PROTECT AMERICA, INC., et al.

I. PLAINTIFF

(c) Attorneys (Firm Name, Address and Telephone Number)

John W. Barrett, WVSB #7289Sharon F. Iskra, WVSB #6582BAILEY & GLAssER LLP209 Capitol StreetCharleston, WV 25301(304) 345-6555 — Telephone(304)342-1110—FaxE-mail: jbarrett(baileyg1asser.comE-mail: siskra(baileyglasser.com

Edward A. BroderickAnthony ParonichBroderick & Paronich,P.C. 99 High St., Suite 304Boston, MA 02110(508) 221-1510ted(broderick-law.comanthony(broderick-law.com

Subject to Pro Hac Vice

Matthew P. McCue, Esq.The Law Office of Matthew P. McCue1 South Avenue, Suite 3Natick, MA 01760(508) 655-1415(508) [email protected]

Subject to Pro Hac Vice

Case 5:18-cv-00161-FPS Document 1-1 Filed 09/21/18 Page 2 of 2 PageID #: 15

ClassAction.orgThis complaint is part of ClassAction.org's searchable class action lawsuit database and can be found in this post: Protect America, Wahab Global Communications Facing Class Action Over Telemarketing Practices

https://www.classaction.org/news/protect-america-wahab-global-communications-facing-class-action-over-telemarketing-practices

Mey v. Protect America, Inc. et al - 5:18cv161 · 2019-12-25 · Case 5:18-cv-00161-FPS Document 1...

Documents

Transcript of Mey v. Protect America, Inc. et al - 5:18cv161 · 2019-12-25 · Case 5:18-cv-00161-FPS Document 1...