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Civil Case: Friedman and Nellis V. Dollar Thrifty Automotive Group

Civil Case: Friedman and Nellis V. Dollar Thrifty Automotive Group

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Published by ABCActionNews
Civil Case: Friedman and Nellis V. Dollar Thrifty Automotive Group
Civil Case: Friedman and Nellis V. Dollar Thrifty Automotive Group

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Published by: ABCActionNews on Apr 26, 2013
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09/06/2014

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADOCivil Action No. 12-cv--2432-WYD-KMTDR. ALLEN FRIEDMAN andMICHAEL J. NELLIS, individually and onbehalf of all others similarly situated,Plaintiffs,v.DOLLAR THRIFTY AUTOMOTIVE GROUP,INC., d/b/a DOLLAR RENT A CAR;DOLLAR RENT A CAR, INC.; andDTG OPERATIONS, INC. d/b/a/ DOLLARRENT A CAR,Defendants. ______________________________________________________________________________ FIRST AMENDED CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL ______________________________________________________________________________ 
Plaintiffs Dr. Allen Friedman and Michael J. Nellis (collectively, “Plaintiffs”), by andthrough their undersigned counsel, file this First Amended Class Action Complaint for violationof the laws stated herein on behalf of themselves and all other consumers similarly situated, asdefined below, against Dollar Thrifty Automotive Group, Inc. d/b/a Dollar Rent A Car, DollarRent A Car, Inc., and DTG Operations, Inc. d/b/a Dollar Rent A Car (collectively referred toherein as “Dollar” or “Defendants”). Plaintiffs hereby allege, on information and belief, exceptfor information identified as being based on personal knowledge, which allegations are likely to
Case 1:12-cv-02432-WYD-KMT Document 22 Filed 11/30/12 USDC Colorado Page 1 of 34
 
 2have evidentiary support after a reasonable opportunity for further investigation and discovery,as follows:
 JURISDICTION AND VENUE
1.
 
 This Court has jurisdiction over all causes of action asserted herein pursuant to 28U.S.C. §1332(d), because the aggregate claims of the proposed Class (defined below) exceed thesum or value of $5,000,000, and there is diversity of citizenship between proposed Classmembers and Defendants.2.
 
Venue is proper in this District pursuant to 28 U.S.C. §§1391(a)(1) & (2).Substantial acts in furtherance of the alleged improper conduct occurred within this District. Atleast one of the Plaintiffs, as well as other Class members, were illegally charged by Defendantsfor services they did not approve within this District, and many of the acts and practicescomplained of herein were approved or took place in this District.
 THE PARTIES
 3.
 
On personal knowledge, Plaintiff Dr. Allen Friedman is an individual consumerwho, at all times material hereto, was a resident of Sarasota, Florida, and as detailed below wassubject to the practices at issue.4.
 
On personal knowledge, Plaintiff Michael J. Nellis is an individual consumerwho, at all times material hereto, was a resident of Austin, Texas, and as detailed below wassubject to the practices at issue.5.
 
Defendant Dollar Thrifty Automotive Group, Inc. d/b/a/ Dollar Rent A Car(“Dollar”) is organized and existing under the laws of the State of Delaware, with its principalplace of business located in Tulsa, Oklahoma. For purposes of diversity jurisdiction, Dollar may
Case 1:12-cv-02432-WYD-KMT Document 22 Filed 11/30/12 USDC Colorado Page 2 of 34
 
 3be considered a “citizen” of either Delaware or Oklahoma. At all times relevant hereto, Dollarwas and is doing business within this District either directly or indirectly through the sale of itscar rental services in this District.6.
 
Defendant Dollar Rent A Car, Inc., a wholly-owned subsidiary of Dollar ThriftyAutomotive Group, Inc., is organized and existing under the laws of the State of Oklahoma, withits principal place of business located in Tulsa, Oklahoma. For purposes of diversity jurisdiction,Dollar may be considered a “citizen” of Oklahoma. At all times relevant hereto, Dollar was andis doing business within this District either directly or indirectly through the sale of its car rentalservices in this District.7.
 
Defendant DTG Operations, Inc. d/b/a Dollar Rent A Car, a wholly-ownedsubsidiary of Dollar Thrifty Automotive Group, Inc., is organized and existing under the laws of the State of Oklahoma, with its principal place of business located in Tulsa, Oklahoma. Forpurposes of diversity jurisdiction, Dollar may be considered a “citizen” of Oklahoma. At alltimes relevant hereto, Dollar was and is doing business within this District either directly orindirectly through the sale of its car rental services in this District.8.
 
At all times herein mentioned, the employees of Defendants, their subsidiaries,affiliates and other related entities, were the agents, servants and employees of Defendants, andat all times herein mentioned, each was acting within the purpose and scope of said agency andemployment, and pursuant to Defendants’ training and directives. Whenever reference in thisComplaint is made to any act or transaction of Defendants, such allegations shall be deemed tomean that the principals, officers, directors, employees, agents, and/or representatives of 
Case 1:12-cv-02432-WYD-KMT Document 22 Filed 11/30/12 USDC Colorado Page 3 of 34

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