2Plaintiffs Carol Treiber, Leslie Talman, Lori Slauter, Rodney Herring, PatriciaHuddleston, Carl Dorsey, Irene Evers, Kathryn Hovland, Isabelle Reali, GeraldineLangford, and Troy Fulwood by their undersigned attorneys, bring this class actioncomplaint against defendants Aspen Dental Management, Inc., ADMI Corporation,ADMI Holdings L.P., Robert A. Fontana, Leonard Green & Partners, L.P, Green EquityInvestors V, L.P., Green Equity Investors Side V, L.P., and LGP Smile Coinvest LLC(collectively, “Defendants”). Plaintiffs’ allegations are based upon knowledge as to their own acts and upon information and belief as to all other matters. Plaintiffs’ informationand belief is based upon, among other things, an extensive investigation undertaken bytheir attorneys.
NATURE OF THE ACTION
This is a class action against Aspen Dental Management, Inc., ADMICorporation, and ADMI Holdings L.P. (collectively, “ADMI”) for violations of NewYork General Business Law §§ 349, 350 (“GBL”), breach of implied covenant of goodfaith and fair dealing, and unjust enrichment. Plaintiffs and the members of the Classesthey seek to represent are all current and former consumers of dental services and products at ADMI dental clinics who were misled by ADMI’s unfair and deceptive trade practices.2.
As alleged herein, through ADMI’s corporate structure and businessmodel, ADMI engages in the unlawful corporate practice of medicine, and in doing so,induces consumers into purchasing dental services and products.3.
Plaintiffs, on behalf of themselves and on behalf of a class and subclass of similarly situated individuals, seek to obtain injunctive relief and/or recover
Case 3:12-cv-01565-DNH-DEP Document 26 Filed 01/18/13 Page 2 of 83