IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT,IN AND FOR DUVAL COUNTY, FLORIDA
CASE NO.:DIVISION:[CONSUMER 1] and [CONSUMER 2], on behalf of themselves and those similarly situated,Plaintiffs,v.JOHN GILL, an individual, KIMBERLY DANIELS, an individual and JAG FL, LLC., a Floridacorporation doing business as Florida Internet,Defendants.
CLASS REPRESENTATION COMPLAINT
The Plaintiffs, [Consumer 1] and [Consumer 2], on behalf of themselves and otherssimilarly situated, by and through their undersigned attorneys, sue the Defendants, Jag Fl, LLC, aFlorida corporation doing business as Florida Internet Florida Internet (collectively referred to as“Florida Internet”), John Gill and Kimberly Daniels and allege:
1. This is a class action lawsuit brought pursuant to the Florida Usury laws, the federalTruth in Lending Act, the federal Electronic Funds Transfer Act, the Florida ConsumerCollection Practices Act and the Florida Deceptive and Unfair Trade Practices Act based uponFlorida Internet’s loan scheme created in an effort to avoid Florida usury laws and to misledFlorida consumer into signing its criminally usurious loans without the benefit of the federally-mandated consumer credit disclosures. Defendants use a standardized, form, consumer loancontracts entitled “Internet Computer Access Rebate Purchase Application and Contract” in thesubject transactions. The Defendants also use illegally extortionate practices in their attempts tocollect these illegal loans.2. The Plaintiffs are seeking class declaratory and injunctive relief (temporary andpermanent), statutory and damages, in excess of $15,000.00, exclusive of interest, costs andattorney’s fees.
3. The Plaintiffs are consumers residing in Jacksonville, Duval County, Florida.4. At all times relevant herein, Florida Internet was and is a Florida corporation doingbusiness in Jacksonville, Duval County, Florida as a consumer lender.