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AEI v Xcentric First Amended Complaint

AEI v Xcentric First Amended Complaint

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Published by Eric Goldman

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Published by: Eric Goldman on Jul 30, 2010
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10/25/2012

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had a regular business practice of secretly recording or causing to be recorded all

telephone conversations to its business telephone number, in association with an

Case 2:10-cv-01360-SVW-PJW Document 96 Filed 07/27/10 Page 6 of 84 Page ID #:2327

First Amended Complaint - 7

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unidentified vendor, without disclosure to or consent of all parties to the telephone

conversations, in violation of, inter alia, the wiretapping laws of the State of

California. The Ripoff Report has used or attempted to use the contents of such

secret recordings as a surprise litigation tactic in actions in, inter alia, California

and Arizona. Defendants used instrumentalities of interstate commerce,

specifically wire, to record such telephone calls.

15. The true names and capacities, whether individual, corporate, or

otherwise, of Defendants DOES 1 to 100 are unknown to Plaintiffs at the present

time, who therefore sue such Defendants by fictitious names, and will amend this

Complaint to show their true names and capacities when ascertained. Plaintiffs are

informed and believe and thereon allege that each of the defendants assigned as a

DOE is responsible in some manner for the events and happenings herein referred

to, and thereby proximately caused injuries and damages to the Plaintiffs. Plaintiffs

will amend this complaint to add as defendants in this action those individuals and

entities who have assisted Defendants in perpetrating the acts and omissions

complained of herein, including additional individuals and entities complicit in

managing and operating the affairs of the Ripoff Report enterprise.

III.

SUMMARY OF THE ALLEGATIONS

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