FILED

FILED
8/12/202012:03
8/12/2020 12:03 PM
PM
1 CI
1 -ESER E
'ESER
CIT‐ESERVE FELICIA PITRE
FELICIA PI RE
RIC CLERK
DISTRICT
DIS
DALLAS co., TEXAS
DALLAS CO.,
00., E AS
Christi Underwood DEP
C DEPUTY

DC-20-11139
CAUSE N O . DC-20-1 1 139
CA SE N0.
NO.

L
L U KE
K E HOGAN,
HOGAN, 0
o n behalf 0o f himself and I N T HE
IN H E DIS R I C T CO
D I S TRIC C O UR
RT OF
OF
other individuals similarly situated,
,

Plaintiff,
P ,
DALLAS
D A L L A S CO N , T E XAS
COUNTY, AS
vs.
O O

S.
.

SO HERN ME
SOUTHERN HODIS UNIVERSITY
METHODIST NI ERSI
and other affiliated entities and individuals,
,

Defendants
D 191ST
191ST J
J UDICIAL D I S TRIC
D I C I A L DIS RICT

PLAIN
PLAINTIFF’S CLASS AC
IFF S ORIGINAL CLASS A C TION
I O N PE I O N AND
P E TII TION AND J R DEMAND
JURY DEMAND

N Hogan ((hereinafter “Plaintiff’),

Named PPlaintiff LLuke H P ), individually and on behalf 0
of all

others similarly situated, , alleges the following upon information and belief,
, by his attorneys, ,

except for those allegations pertaining to0 PPlaintiff,

, which are based 0
on personal knowledge.
.

NATURE
EA OF T HE
LJRE QF ACTION
H E AQ IQN

1.
1. This class action is brought on behalf 0of N Luke H
Named PPlaintiff L Hogan and those

similarly situated who paid tuition and fees for the SSpring 2020
2020 semester at SSouthern MMethodist

University.
. AAs a result 0of DDefendants’ response to0 the NNovel CCoronavirus DDisease 2019
2019

(“COVID-l9”),
( CO ID-19 ), PPlaintiffs did not receive the benefits and services that they bargained for when

they provided payment for tuition and fees..

2.
2. Plaintiffs and DDefendants entered into a contract where PPlaintiffs would provide
P

payment in the form 0of tuition and fees and DDefendants would provide in-person educational

, experiences,
services, , opportunities,
, and other related services.
.

3.
3. O 12, 2020,
March 12,
On 0or around M 2020, SSouthern MMethodist University canceled all in‑-

person education and in-person educational services,

, then transitioned to complete online
education.
.

4.
4. Based 0on these
B closures,
, DDefendants have failed to uphold their end of the contract

to0 provide in-person

- educational services, , and opportunities.
, experiences, .

5.
5. Despite DDefendants’
D failure to provide the services and experiences as bargained

for,, Defendants
D have not offered any refund of the tuition and fees that PPlaintiff and the CClass

paid.
.

DISCO E RY LE
D I S C O V ER E L AND
L E VEL A N D RULE 4 7 STATEMENT
R U L E 47 S TAT E M E N T

6.
6. Plaintiffs
P intend to0 conduct discovery under LLevel 3,
3, pursuant to0 TTexas RRule of

Civil Procedure
C P 190.4, and request that
190.4, the CCourt enter a scheduling order in this case.
.

7.
7. As required by RRule 47
A 47 of the TTexas RRules 0of CCivil PProcedure,
, PPlaintiffs plead for

$1,000,000 and judgment for all other relief to0 which they are
monetary relief in an amount over $1,000,000

entitled.. However,
H , PPlaintiffs believe that the amount 0
of monetary relief actually awarded as

damages should and will ultimately be determined by a jury..

FA
FA T
T

8.
8. Plaintiff
P Members are individuals that paid tuition and fees for the
and CClass M

Spring Semester
S S 2020 at SSouthern MMethodist UUniversity.
.

9.
9. Defendants
D accepted PPlaintiffs and CClass M
Members’ payments in exchange for

, experiences,
educational services, , and opportunities as detailed in D
Defendants’ marketing,
,

advertisements,
, and other public representations.
.

10.
10. on the academic schedule,
Based 0
B , the S 2020 semester at SSouthern MMethodist
Spring 2020

University
U 17, 2020,
commenced 0on or around JJan.. 17, 2020, and it was scheduled to conclude 0on 0or

around M 16, 2020.

May 16, 2020.

11.
11. N Luke H
Named PPlaintiff L Hogan was a full-time
- graduate student in the management
program during the SSpring 2020 semester.
. SSouthern MMethodist UUniversity charged plaintiff

approximately $25,000
$25,000 in tuition and fees during the SSpring 2020 semester.
.

12.
12. Plaintiffs
P paid tuition and fees for in-person
- educational services,
, experiences,
,

, commencement exercises,
opportunities, , and other related collegiate services for the entire period

beginning in or around JJanuary 2020

2020 through M
May 2020.
2020.

13.
13. According
A to0 publicly available information,
, the average tuition cost for both in‑
-

state and out-of-state

- residents is approximately $37,955.00
$37,955.00 for the SSpring 2020 semester at

Southern MMethodistUniversity.
S U .

14.
14. O 12, 2020,
March 12,
On 0or around M 2020, SSouthern MMethodist UUniversity announced that

because of CO ID-19, they would suspend and cancel all in-person

COVlD-19, - classes and college

experiences for the remainder 0of the SSpring SSemester 2020

2020 ((following SSpring BBreak recess)
) and

that all learning would transition to online beginning 0on or around M 26, 2020.
March 26, 2020.

15.
15. Defendants were
D unable to provide in-person
- , services,
educational experiences, ,

and opportunities for approximately 59% of the SSpring 2020

2020 semester.
.

16.
16. Prior
P to0 the suspension of in-person
- classes for the SSpring 2020 semester,
,

Luke H
Plaintiff L
P Hogan attended campus events and was involved in student activities and/or
/ clubs.
.

17.
17. As a result 0of DDefendants’ closure,
A Defendants have not complied with their
, D

obligation to provide in-person

- educational services along with other experiences,
, opportunities,
,

and services PPlaintiff and the CClass paid for..

18.
18. Plaintiff and the CClass
P did not enter into an agreement with DDefendants for online

education, 0 receive in-person

, but rather sought to - education from DDefendants’ institution.
.

19.
19. Therefore,
T Plaintiff and CClass
, P Members are entitled to a pro-rata
M - refund of the

tuition and fees they paid to DDefendants for in-person

- educational services as well as other
marketed collegiate experiences and services that were not provided.
.

J
J URISDIC I O N AND
R I S D I C TION EN E
A N D VENUE

20.
20. This CCourt has subject matter jurisdiction because PPlaintiffs seek damages within

the jurisdictional limits 0of this CCourt.

.

21.
21. This CCourt has personal jurisdiction over DDefendants because SSouthern MMethodist

University is a Texas entity and maintains its principal place 0of business in DDallas CCounty,
, Texas.
.

22.
22. Venue is proper in DDallas C
County pursuant to Tex.
. CCiv.
. P . &
Prac. & R . C
Rem. Code AAnn.
. §

15.002 or omissions giving rise to the claim occurred in

15.002 because all or a substantial part of the events 0

this County,
C Defendants operate their primary campus in this CCounty.
, and because D .

PAR IES
PARTIES

23.
23. N Hogan is a resident of KKeller,
Luke H
Named PPlaintiff L , Texas.
. PPlaintiff was enrolled

as a fiill‐time
- graduate student at SSouthern MMethodist University during the SSpring 2020

semester.
. PPlaintiff graduated at the conclusion 0of the semester.
. PPlaintiff has not received any

refund for tuition and fees paid to DDefendants,

, despite the fact that the University has been shut

down since on or about M 12, 2020.

March 12, 2020.

24.
24. Defendant SSouthern MMethodist University ((“Southern
D S Methodist” 0or
M SM ) is a
“SMU”)

private university and a Texas corporation whose principal place 0of business is located in DDallas,
,

. This Defendant
Texas. D may be served through its registered agent as follows:
: P J. Ward:
Paul J. ,

P . BBuilding,
Perkins AAdmin. 6425 B
, 6425 , R
Boaz LLane, Room 130, , TX 75205.
130, DDallas, 75205.

SQLASS ALLES
QLASS A L L E g i AT 255
A II g 213 S

25.
25. Plaintiff
P brings this matter on behalf 0of himself and those similarly situated. As
. A

detailed in this PPetition,

, DDefendants failed to0 provide the in-person
- education services the

Plaintiffs paid tuition and fees to0 receive during the SSpring SSemester 2020.
P 2020.

26.
26. Plaintiffs
P were impacted by and damaged by this misconduct.
.

4
4
 27.
27. Accordingly,
Acc d action is ideally
, this ac dea situated
a ed f a -W de resolution.
for cclass-wide e .

28.
28. The
T Class
e C a is de ed aas aall individuals
defined d d a who paid
a d tuition a
and fees to0 SSouthern
d fee e

Methodist
Me d University
U e to0 receive
ece e in-person
e educational
ed ca a services,
e experiences,
ce , e e e ce , aand
d

opportunities
e dduring thee SSpring Se
Semester 2020. ((“Class”).
e e 2020. C a ).

29.
29. The
T e CClass
a is properly
e brought aand
b d should be maintained
d be a a ed aas aa cclass
a action
ac

under
de Te a Rule
Texas of CCivil PProcedure
R e 0f 42 satisfying
ced e 42 a f thee cclass
a action prerequisites
ac e e e of
0f

numerosity,
e , ccommonality,
a , typicality,
ca and
, a adequacy
d ade because:
ac beca e:

30.
30. Numerosity:
N e : CClass
a Me be
Members are
a e so numerous
e a joinder
that of aall members
de 0f e be is

impracticable.
ac cab e. P Plaintiff
a believes
ff be a there
e e that e thousands
are
e e a of individuals
a d 0f d d a W
who aaree CClass
a

Members
Me be described
de c bed ab eW
above who have damaged
been da
a e bee by Defe
a ed b Defendants
da breach
b eac off ccontract.
ac .

31.
31. Commonality:
C a : T e questions
The e of law
0f a aand fact c
d fac common to
0 the Class
e C a Me be
Members

which
W c predominate
ed a e over
e aany questions
e which
W c may affect individual
a affec d d a CClass
a Members
Me be include,
c de,

but aaree
b not limited
ed to:
:

a. W
a. Whether
e e Defe Defendants
da accepted
acce e f
ed money from PPlaintiff
a and
ff a dCClass
a Me be
Members
in eexchange
c a e ffor a a promise e to de services;
0 provide e ce ;
b. W
b. Whether
e e Defe Defendants
da provided
ded thosee services
e ce a as ba a ed ffor;
bargained ;
0. WWhether
c. e e PPlaintiff
a ff aand
d the Class
e C a Members
Me be are
a entitled
e e ed to
0 a - a a portion
a pro-rata
off thee tuition aand fees paid
d fee a df e ce that
for services e e not provided;
a were ded;
. Whether
. W e e Defe Defendants
da e e unjustly eenriched;
were c ed;
e. W
e. Whether
e e Defe Defendants
da converted
c e ed money e f from thee PPlaintiff
a and
ff a dCClass
a
Members.
Me be .

32.
32. Typicality:
T ca : P a ff is a
Plaintiff a member of
e be 0f thee CClass.
a . PPlaintiffs
a ff claims
c a e typical
are
a of thee
ca 0f

claims
c a each CClass
off eac a Me be in that
Member a eevery
e e be off thee CClass
member a a subject
was b ec to Defe
Defendants
da

breach
b ac , unjust e
eac off ccontract, enrichment
c e and
a dcconversion.
e . P ff is e
Plaintiff
a ed to
entitled e ef under
0 relief de the a e
e same

causes
ca e 0f action aas thee
of ac other
e CClass
a Members.
Me be .

33.
33. Adequacy:
Ade a ff is a
ac : PPlaintiff adequate
an ade Class
a e C a representative
e e e a because
e beca e his interests
e e do
d0

c with the
not cconflict e interests
e e off thee CClass
a Me be
Members he
e seeks
ee to0 represent; claims
e e e ; his c a e c
are
a common
to aall members
e be off the Class,
he C a , aand he ha
d he has aa strong interest
g i e e in Vi
i vindicating his rights;
dica i g hi he ha
igh ; he has retained
e ai ed

counsel
c e c competent
e e and
a experienced
d e complex
e ie ced iin c e cclass
a action
ac i litigation
i iga i a d they
and he i e d to
intend 0

vigorously
ig ec e this
prosecute action.
hi ac i . PPlaintiff
ai iff ha 0 iinterests
has no e e which cconflict
Which ic Wiwith h e off the
h those Class.
he C a .

The CClass
a Members’
Me be interests
i e e will
i be fai
be fairly aand adequately
d ade a e protected by PPlaintiff
ec ed b ai iff a and his
d hi

counsel.
c Defendants
e . Defe da have
ha acted
e ac in aa
ed i a e ge
manner generally
e a applicable
a 0 the
icab e to he C a , making
Class, a i g relief
e ief

appropriate
a ia e with
Wi h respect
e ec to PPlaintiff
ai iff a and
d the Class
he C a Members.
Me be . The prosecution
ec i of separate
0f actions
e a a e ac i

by iindividual
b di id a CClass
a Members
Me be would
d ccreate a risk
ea e a i off iinconsistent
c i e and
a d varying adjudications.
a i g adj dica i .

34.
34. The CClass
a is properly
i e brought
b gh aand
d should
h be maintained
d be a cclass
ai ai ed aas a a action
ac i under
de

Texas
Te a RRule of Civil
e 0f Ci i PProcedure 42 beca
ced e 42 because a cclass
e a a action
ac i is
i superior
e i to0 traditional
adi i a litigation
i iga i of this
0f hi

controversy.
c e . C
Common i e off law
issues a aand fact predominate
d fac ed i a e over
e aany other
he questions
e i affec i g only
affecting

individual
i di id a members
e be of the
0f Class.
he C Class
a . The C a issues
i e ffully predominate
ed i a e over
e aany iindividual
di id a iissue
e

beca e no
because 0 inquiry
i i into iindividual
i di id a cconduct
d c iis necessary; ha iis required
ece a ; aall that e i ed iis a
a narrow
a focus
f c on

Defendants’
Defe da conduct.
c d c .

35.
35. Superiorigg:
S e i ig : I addition,
In addi i , aa cclass
a action
ac i is superior
i e i to0 the
he other
he aavailable
ai ab e

e h d ffor the
methods fair aand
he fai efficient
d ef cie adjudication
adj dica i of this
0f hi ccontroversy
e because:
beca e:

a.
a. The jjoinder of thousands
i de 0f h a d off i
individual
di id a CClass
a Members
Me be is iimpracticable,
i ac icab e,
cumbersome,
c be e, unduly
d burdensome,
b de and
e, a daa waste
a e offjjudicial
dicia a and/or
d/
litigation
i iga i resources;
e ce ;

b.
b. The iindividual
di id a c claims
ai off the Class
he C a Members
Me be a be
may be relatively
e a i e modest
de
compared
c with
a ed Wi h the expense
he e e e 0f of litigating
i iga i g the claim,
he c ai , thereby
he eb making
a i g iit
impracticable,
i ac icab e, unduly
d burdensome,
b de and
e, a de e i e-if not totally
expensive-if a impossible-to
i ib e-
justify
j if i individual
di id a acactions;
i ;

c.
c. Whe Defe
When Defendants’
da liability
iabi i ha been adj
has bee adjudicated,
dica ed, aall C
Class
a Members'
Me be ' c claims
ai can
ca
be determined
be de e i ed b by the
he CClass
a and
a administered
d ad i i e ed efefficiently
cie in aa manner
i a e fa far less
e
burdensome
b de ea and expensive
de e i e thanha ifif iit were
e eaattempted
e ed through
h gh filing, discovery,
i g, di c e ,
and
a d trial f aall i
ia of individual
di id a ca cases;
e ;

(1.
d. This cclass
Thi a action
ac i will
i promote
e orderly,
de efficient,
, ef cie , e expeditious,
edi i , aand
d
appropriate
a adjudication
ia e adj dica i and
a administration
d ad i i a i off CClass
a claims;
c ai ;
 e.. PPlaintiff
a knows of no difficulty
c to0 bbe encountered
c in the management
a a of
this ac a would preclude
action that c its maintenance
a a c aas aa cclass
a action;;
ac

f. TThis cclass
. a action will aassure uniformity 0of decisions
ac c among CClass
a a Members;
M b ;

g.
. The CClass
T a is readily
a definable
ab and prosecution
a c of this ac
action aasa class
a c a action
ac
will eliminate
a the possibility
b of repetitious litigation;
a ;

h.
. Class
C a M b
Members’ interests in individually
a controlling the prosecution
c c of
0
separate
a a actions aare outweighed bby their interest in efficient
ac c resolution bby
single cclass
a action;
ac and
; a

i.. It would b
I be desirable
ab to cconcentrate
c a in this single venue the litigation
a of aall
plaintiffs
a who were harmed
a by Defendants’ cconduct.
b D a c .

36.
36. Accordingly,
Acc , this CClass
a is properly bbrought aand should bbe maintained
a a asa
a class
a c a

action
ac under TTexas
a RRule of CCivil PProcedure
c 42 bbecause
42 ca questions of law ac c
a or fact common to

Class
C a M b
Members predominate
a any questions aaffecting
over a c a members,
only individual b , aand

because
b ca a cclass
a a action
ac is superior to other aavailable
a ab methods for fairly
a and efficiently
a c

adjudicating
a ca this ccontroversy.
.

37.
37. Plaintiff
P a and
a the CClass
a can maintain
ca a a action aas aa cclass
this ac a action under TTexas
ac a

Rule of
R 0 CCivil PProcedure
c 42(b)(1), (2),
42(b)(1), (2), aand (3).
(3).

FIRST QAHSE
FIRST A SE QF QF AQTIQIS
AQTIQ S
BREA H
BREA H F TRA
TRA T
(On BBehalf
(O a 0 of PPlaintiff
a and AA l l CClass
a a Members)
M b )

38.
38. Plaintiffs incorporate
P a c a by reference
b of the aallegations
c aall 0 a made
a above here into this
ab

cause
ca of action.
ac .

39.
39. Plaintiff,
P a , on b
behalf
a of himself aand other members
b of the cclass,
a , bbrings aa c
common

law
a claim
c a for BBreach
ac 0of CContract.
ac .

40.
40. B accepting payment,
By acc a , DDefendants
a entered into ccontractual
ac a a arrangements
a with

Plaintiff
P a and
a Class
C a Members
M b to0 provide educational
ca c , experiences,
a services, c , opportunities,
, aand
related services for the SSpring SSemester 2020.
2020.

41.
41. Plaintiff and CClass
P Members’ payment of tuition and fees were intended to
M 0 cover

in-person education, January through M

, and services from J
, experiences, 2020.
May 2020.

42.
42. Defendants received and retained the
D benefits without providing those benefits to

Plaintiff and CClass

P Members.
M .

43.
43. As a direct and proximate result 0of DDefendants’ breach 0of contract,
A , PPlaintiff and

Class
C Members have been harmed by not receiving the educational experiences,
M , opportunities,
,

and services they paid for during the SSpring SSemester 2020.
2020.

44.
44. Defendants are
D required to0 perform under the contract and COVID-19
COVID-19 does not

excuse such performance.

. TTherefore, Defendants should be required to retum pro-rata
, D - shares of

the tuition and fees paid by PPlaintiff and CClass M

Members that related to services that were not

12, 2020.
March 12,
provided for after SSouthern MMethodist UUniversity shut down 0on or around M 2020.

SEAHSE QF AQTIQIS
SEQQISD S2AIJSE
SEQQISD AQTIQ S
QQE ERSIQE
52! HSYERSIQ 213
(On BBehalf 0of PPlaintiff and AA l l CClass M
(O Members)
)

45.
45. Plaintiffs incorporate by reference all 0of the allegations made above here into this
P

cause of action.
.

46.
46. Plaintiff,
P , on behalf of himself and other members 0
of the CClass,
, brings a common

law claim for CConversion.

.

47.
47. Plaintiff and CClass
P Members have an ownership right to the in-person
M - educational

2020.
services based on their payment 0of tuition and fees for the SSpring SSemester 2020.

48.
48. Defendants
D intentionally interfered with PPlaintiff and the CClass MMembers’

ownership right when they canceled in-person

- instructions for the remainder of the SSpring

2020.
Semester 2020.
S
 49.
49. Plaintiff
P Members were damaged by DDefendants’ interference as
and the CClass M

, experience,
they paid for educational, of the SSpring SSemester 2020
, and services for the entirety 0

which were not provided.

.

50.
50. Plaintiff and
P the CClass M
Members are entitled to a pro-rata
- share of the tuition and

fees they paid for but were not provided resulting from DDefendants’ interference.
.

THIRD QAQSE QF
QF AQTIQIS
AQTIQN
MM
MM LA
LA R I HME
T E RI HME T
((O Behalf 0of PPlaintiff and AA l l CClass M
On B Members in the AAlternative)
)

5 1.
]. Plaintiffs
P incorporate by reference all of the allegations made above here into this

cause of
0 action.
.

52.
52. P , on behalf of himself and other members of the class,
Plaintiff, , brings a common

law claim for unjust enrichment.

.

53.
53. Plaintiff
P and CClass M
Members conferred financial benefits and paid substantial

tuition and fees to DDefendants for educational and related services for the SSpring SSemester 2020.
2020.

As bargained for these tuition and fee payments were intended to0 cover in-person
A - education

2020 0of JJanuary through M

throughout the entire SSpring SSemester 2020 2020.
May 2020.

54.
54. Defendants
D accepted the obligation to provide such services when they accepted

payment.
.

55.
55. Defendants
D , despite D
retained these payments, Defendants’ failing to0 provide the

bargained for educational experiences and services for which the tuition and fees were collected

to0 cover.
. DDefendants should be required to return a pro-rata
- 2020
share 0of any SSpring SSemester 2020

tuition and fees,, 0of Wwhich services were not provided asbargained for,, since SSouthern MMethodist

University shut
U 12, 2020.
March 12,
down on or around M 2020.

56.
56. Under common law principles 0of unjust enrichment,
U , it is inequitable for
Defendants to
D retain the benefits conferred by PPlaintiffs and CClass M
Members’ overpayments.
.

57.
57. Plaintiff and CClass
P Members seek disgorgement of all profits resulting from such
M

overpayments and establishment of a constructive trust from which PPlaintiff and CClass M
Members

may seek restitution.

.

, JR DEMAND
,l [JRY DEMAND

58.
58. Plaintiff demands
P a trial by jury and has paid the jury fee..

PRA ER F R RELIEF
W
HEREFORE, PPlaintiff,, on behalf of himself and the CClass,, prays for judgment asfollows::
WHEREFORE,

(a)
( ) Declaring this
D action to0 be a proper class action and certifying

Plaintiff as the
P representative 0of the CClass under TTexas RRule of CCivil

42;
Procedure 42;
P

(b)
( ) Awarding monetary damages as set forth above;
A ;

(0)
( ) Awarding punitive damages;
A ;

(d)
( ) Awarding PPlaintiff and CClass M
A Members their costs and expenses incurred in this

action,
, and also awarding reasonable attorney’s fees incurred in connection

with the prosecution of this action;; and

(e)
( ) Granting all other reliefto which PPlaintiff and the CClass M
G Members may be

entitled..

RE E TF R
R DI
DI L RE

Under TTexas RRule 0of CCivil PProcedure

U 194, PPlaintiff requests
194, that the DDefendant disclose,
,

50 days of the service of this PPetition,

within 50 , the information or material described in T
Tex. R.
. R.

. P.
Civ.
C 194.2(a)-(l)
P. 194.2( ) (1) and in T
Tex. R. CCiv.
. R. P. 190.2(
. P. 190.2(b)(6).
)(6).

10
10
 Respectfully submitted,
,

H E ED
T HE A RDD S LA
E D WA LAWG GROUP
HE HAEH
THE HAEHNEL EL B UILDI
I L D I NG
G
1101 E.
1101 11TH
E. 11 EE
H STREET
I , TX 78702
AUSTIN,
A
Tel.
. 512-623-7727
Fax.
F 512-623-7729
. 512-623-7729

By
B /s/ JJeff EEdwards
/ /

JEFF ED A D
EDWARDS
State BBar No.
0. 24014406
jeff@edwards-law.com
@ 1 .
MICHAEL I GLE
M I C H A E L SINGLEY
Bar No.
State B 0. 00794642
mike@edwards‐law.com
@ .
DA ID JAME
DAVID JAMES
State BBar No. 24092572
0. 24092572
david@edwards-law.com
@ 1 .

A D
AND

T HE L E LA
H E SULTZER L AW GGROUP, , P.C.
.C.
Jason P.. Sultzer,
J , Esq.*
E .*
Jeremy FFrancis,
J Esq.*
, E .*
sultzerj@@thesultzerlawgr0up.com.
francisj @@thesultzerlawgroup.com
.
85 CCivic CCenter Plaza,
85 104
, Suite 104
Poughkeepsie, , New York 12601
12601
Telephone: (854) 705-9460
: (854) 705-9460

A D
AND

LEEDS B
LEED B R O W N LA
L A W,, P.C.
.C.
Jeffrey K.
J K. Brown,
B ,EEsq.*
.*
M A. Tompkins,
Michael A. , EEsq.*
.*
Brett R.
B Cohen,
. C Esq.*
, E .*
One Old CCountry Road, , Suite 347
Carle
C Place, 11514
, NY 115 14
(516)
(5 873-9550
1 6) 873-9550

jbrownl@leedsbrownlaw.com
@ .
mtompkins@leedsbrownlaw.com
@ 0 .
bcohen@leedsbrownlaw.com
@ .

*
* Admission Pro H
A Hac Vice to0 be requested

Counselfor Plaintiffand the Putative CClass

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