Case 9:24-cv-80281-DMM Document 1 Entered on FLSD Docket 03/13/2024 Page 3 of 28
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collective conduct caused Plaintiff damages and significant emotional distress.
4. Plaintiff makes these allegations on information and belief, with the exception of those allegations that pertain to Plaintiff, or to Plaintiff’s counsel, which Plaintiff alleges on personal knowledge.
5. While many violations are described below with specificity, this Complaint alleges violations of the statute cited in its entirety.
6. Unless otherwise stated, all the conduct engaged in by Defendants took place in the Southern District of Florida.
7. Any violations by Defendants were knowing, willful, and intentional, and Defendants did not maintain procedures reasonably adapted to avoid any such violation.
8. Unless otherwise indicated, the use of Defendants’ names in this Complaint includes all agents, employees, officers, members, directors, heirs, successors, assigns, principals, trustees, sureties, subrogees, representatives, and insurers of Defendants named.
JURISDICTION AND VENUE
9. This Court has federal question jurisdiction because this case arises out
