Vasquez V Nexus

Case 4:17-cv-00755-DMR Document 1 Filed 02/15/17 Page 1 of 28
1 JEFFREY KALIEL, California Bar No. 238293

TYCKO & ZAVAREEI LLP
2 483 Ninth Street, Suite 200
Oakland, CA 94607
3 Telephone (510) 254-6808
Facsimile (202) 973-0950
4 [email protected]
5 Attorney for Plaintiffs

Additional Attorneys on Signature Page
6
8 UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
9
JUAN QUINTANILLA VASQUEZ and Case No. 3:17-cv-755
10 GABRIELA PERDOMO ORTIZ, individually
and on behalf of all others similarly situated, CLASS ACTION COMPLAINT
11
JURY TRIAL DEMANDED
12 Plaintiffs,
1. Violation of the Unfair Prong of the
13 Unfair Competition Law, Cal. Bus. & Prof.
vs.
14 Code 17200, et seq.
2. Violation of the Fraudulent Prong of the
15 LIBRE BY NEXUS, INC. and JOHN DOES 1-50, Unfair Competition Law, Cal. Bus. & Prof.
Code 17200, et seq.
16 Defendants. 3. Violation of the Unlawful Prong of the
Unfair Competition Law, Cal. Bus. & Prof.
17
Code 17200, et seq.
18 4. Violation of the Consumers Legal Remedies
Act, Cal. Civ. Code 1750, et seq.
19 5. Violation of the California Translation Act,
Cal. Civ. Code 1632
20 6. Violation of the Prohibition on Peonage, 18
U.S.C. 1581
21 7. Violation of the Prohibition on Forced
Labor, 18 U.S.C. 1589
22
CLASS ACTION COMPLAINT
23
Plaintiffs Juan Quintanilla Vasquez and Gabriela Perdomo Ortiz (Plaintiffs), on behalf of
24
themselves and all others similarly situated, allege the following based upon personal knowledge as
25
to allegations regarding Plaintiffs and on information and belief as to other allegations:
26
INTRODUCTION
27
1. This is a civil class action seeking monetary damages, restitution, injunctive and
28
declaratory relief from Defendants Libre by Nexus (LBN) and John Does 1-50 (collectively,

12613-001/00725721_1 Error! Unknown document property name.
1 Defendants), arising from their exploitation of Spanish-speaking migrant detainees with so-called
2 lease agreements for GPS trackers.
3 2. U.S. Immigration and Customs Enforcement (ICE) detains thousands of
4 undocumented immigrants each year. Once in detention, detainees who are deemed to not pose a
5 flight risk or a threat to public safety are afforded the opportunity to post bond. Bond is typically set
6 at an amount that well exceeds the detainees ability to pay, forcing them to obtain third-party
7 financing or remain in detention.
8 3. Some bond financing companies in the marketplace offer reasonable options in light
9 of credit risk. But LBN preys on detainees vulnerability and limited understanding of English to
10 foist crushing financial terms and GPS shackles on detainees in exchange for its service of
11 arranging for a third party to post detainees bonds. Contrary to its marketing representations, LBN
12 is not in the business of helping as a neutral advisor for families who would like to get a loved one
13 out of immigration detention. Rather, LBN is in the business of leasing GPS trackers under false
14 pretenses, and forcing detainees to haul and charge them, day-in and day-out.
15 4. Contrary to its misrepresentations, LBN has no association with ICE, and no power to
16 invoke the powers of ICE or otherwise incarcerate its consumers. LBN, however, takes advantage of
17 these misrepresentations and fear of ICE detention and incarceration to extort payment of fees and
18 continued shackling to the GPS trackers.
19 5. Detainees lack of knowledge about immigration bail bond offerings and limited
20 English-language ability are the bedrock of LBNs business. Using targeted English-language
21 misrepresentations and omissions, LBN appends GPS monitors onto the bodies of detainees, and
22 levies exorbitant feesnearly $10,000 in the first year alonefor doing so. LBN forces detainees to
23 sign an unconscionable English-language GPS ankle bracelet lease agreement on its customers
24 while providing a Spanish disclosure that never tells the true costs of the supposed bargain.
25 6. That supposed lease agreement allows LBN to install faulty ankle GPS tracking
26 devices on detaineesdevices which the company knows are defective, prone to cause injury, and
27 which require wearers to charge the devices for hours while tethered to the wall.
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2
1 7. The process by which detainees enter into supposed lease agreements, and append
2 GPS trackers to their bodies, is rife with misrepresentations. Specifically, LBN misrepresents the
3 amount of fees detainees will be liable to pay LBN. And LBN misrepresents the nature of those fees
4 in numerous ways, as discussed herein.
5 8. Through its false and deceptive advertising and pricing scheme, LBN violated (and
6 continues to violate) California law prohibiting misleading sales practices. Specifically, LBN
7 violated (and continues to violate) Californias Unfair Competition and False Advertising Laws,
8 Business & Professions Code 17200 and 17500, et seq. (the UCL), and the California
9 Consumers Legal Remedies Act, California Civil Code 1750, et seq. (the CLRA).
10 9. From its use of an English-language rental agreement with only selective Spanish-
11 language disclosures, LBN violated the California Translation Act, California Civil Code 1632.
12 10. Plaintiffs, individually and on behalf of all others similarly situated, seek declaratory
13 relief, damages, restitution, and other equitable remedies, including an injunction under the UCL,
14 FAL and CLRA.
15 11. LBN violates the Federal Prohibition on Peonage, 18 U.S.C. 1581, and the Federal
16 Prohibition on Forced Labor, 18 U.S.C. 1589. Plaintiffs, individually and on behalf of all others
17 similarly situated, seek compensatory damages, liquidated damages, punitive damages, declaratory
18 relief, and other equitable remedies, including an injunction.
19 PARTIES
20 12. Plaintiff Juan Quintanilla Vasquez is an individual who resides in the city of Oakland,
21 California. In reliance on LBNs false and deceptive advertising, marketing, and pricing schemes,
22 Mr. Vasquez paid LBN for rental of a GPS ankle monitor, beginning on April 1, 2016. As detailed
23 herein, Plaintiff was damaged as a result thereof.
24 13. Plaintiff Gabriela Jamileth Perdomo Ortiz is an individual who resides in the city of
25 Oakland, California. In reliance on LBNs false and deceptive advertising, marketing, and pricing
26 schemes, Ms. Ortiz paid LBN for rental of a GPS ankle monitor, beginning on August 1, 2015. As
27 detailed herein, Plaintiff was damaged as a result thereof.
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1 14. Defendant LBN is a corporation duly organized and existing under the laws of the
2 State of Virginia, with its principal place of business at 113 Mill Place Parkway, Suite 103, Verona,
3 Virginia 24482.
4 JURISDICTION AND VENUE
5 15. This Court has original jurisdiction of this action under the Class Action Fairness Act
6 of 2005. Pursuant to 28 U.S.C. 1332(d)(2) and (6), this Court has original jurisdiction because the
7 aggregate claims of the members of the putative Class exceed $5 million, exclusive of costs, and at
8 least two members of the proposed Class are citizens of a different state than LBN.
9 16. The Northern District of California has personal jurisdiction over LBN because LBN
10 is licensed and doing business in Alameda County, California, authorized to do business in
11 California, and has sufficient minimum contacts with California, having intentionally availed itself
12 of the California market so as to render the exercise of jurisdiction over it by this Court consistent
13 with traditional notions of fair play and substantial justice.
14 17. Venue is proper in the Northern District of California pursuant to 28 U.S.C. 1391,
15 because Plaintiffs are residents of Alameda County, California; Defendant LBN operates an office
16 location in or near Alameda County, California; and because the events giving rise to the claims
17 occurred in significant part in Alameda County, California.
18 FACTUAL ALLEGATIONS
19 18. According to its website LBN is part of Nexus Services, organized and existing under
20 the laws of Virginia, with its principal place of business at 113 Mill Place Parkway, Suite 103,
21 Verona, Virginia 24482. Upon information and belief, Nexus Services is engaged in the business of,
22 among other things, providing electronic monitoring services in connection with immigrant bond
23 securitization.
24 19. The company has undergone massive growth since 2013, and now has at least 26
25 offices nationwide, including six in California.
26 20. According to its website, When you secure an immigration bond through Libre, you
27 pay a premium payment to the bond company, which is based upon the total amount of the bond.
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4
1 Libre by Nexus is required to charge this fee and it is the fee of the bond company. Libre by Nexus
2 does not keep any of that money. Libre by Nexus also charges a service fee and a GPS installation
3 and tracking fee. Normally the total amount paid is roughly 20% of the bond. You are not required to
4 pay collateral when using the GPS bracelet!
5 21. LBN thus represents that its fees represent payments for the provision of the GPS
6 tracker. That is false.
7
LBN MISREPRESENTS ITS PURPORTED SERVICES
8 22. During the Class Period (defined below), LBN marketed its services to detainees in
9 the custody of ICE for whom a bondusually in amounts between $10,000 and $20,000has been
10 set. For detainees who cannot post that cash up front, LBN arranges for bail bonds through third
11 parties. It purports to securitize those bonds via placement of GPS ankle monitors on immigration
12 detainees, which purportedly keep detainees from fleeing.
13 23. Immigration bail bonds without GPS tracking are readily available in the marketplace
14 for immigration detainees unable to pay the full amount of the bond in cash while their case is
15 pending in immigration court. Typically, the cost for such bonds is between 10%-20%, and usually
16 requires additional collateral (in the form of real estate or personal property) as a security. Typically,
17 the 10%-20% up-front fee is the only non-refundable payment to an immigration bail bond
18 company.
19 24. LBN, on the other hand, charges a bond security payment of 20%at the highest end
20 of the going rate in the industryplus demands additional nonrefundable payments of $880 up front
21 and then $420 a month in perpetuity. To illustrate the unconscionable nature of these charges: on a
22 $10,000 bond, a consumer will pay to LBN approximately $9,000, nonrefundable, in the first year.
23 25. In short, there is little or no rational reason for detainees to choose to pay LBNs
24 massive fees. Yet through the use of aggressive and deceptive sales practices, LBN is able to affix a
25 GPS ankle monitoring device on the detainees, which they must wear at all times, and charge them
26 the unconscionable and debilitating price of $420 a month, plus an $880 activation fee, to lease the
27 device.
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5
1 26. All in all, this is a shockingly bad deal, even relative to the other bad options
2 available to immigrant detainees, and is unconscionable on its face. Moreover, LBN is only able to
3 foist this one-sided deal on consumers because it engages in a systematic campaign of
4 misrepresentation and omission with its indigent, Spanish-speaking clientele, who are under the
5 duress of detention.
6 27. Indeed, LBNs customers overwhelmingly possess limited or no ability to
7 communicate in, or read, English. Yet virtually all contract documents provided by LBN are solely
8 in English.
9 28. The detainees enter into the bargain only because LBNs misrepresentations and
10 omissions leave them with little idea as to the reality and implications of the lease agreement. For
11 example, LBN never once informs its consumers in the Spanish-language documents provided that
12 they will be liable for a $420 monthly fee after making initial payment of the 20% and activation fee,
13 much less indefinitely, and much less that the fee is not being used to pay down the debt of the bond.
14 29. Rather than communicating the purported benefits and risks of its services in a
15 clear, straightforward, and comprehensible fashion, LBN makes numerous misrepresentations and
16 material omissions during the high-pressure ankle monitor bracelet sign-up process.
17 30. First, written materials provided to detainees and their families are almost exclusively
18 in English, despite LBNs knowledge that virtually none of the detainees they target are able to
19 understand and read English. To wit, LBN asks detainees to sign a lengthy and dense lease
20 agreement, almost all in English. The only information provided in Spanish is a one-page key facts
21 document, which actually conceals the most material facts about the nature of the accompanying
22 agreement.
23 31. Second, LBN misrepresents its association with ICE in order to confuse detainees and
24 their families by creating the impression that LBN is an official organ of the U.S. Government, with
25 the power to determine whether a detainee is released or detained. In reality, LBN has zero formal
26 association with ICE, and has no power to order release or detention of immigrants.
27
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1 32. Third, LBN misrepresents the financial implications of the arrangement. It never
2 discloses in writing in Spanish that detainees will be required to pay $420 a month in perpetuity.
3 Moreover, LBN leads detainees to believe that the exorbitant monthly payments made to lease the
4 ankle shackles are actually payment for their outstanding bond amount. In reality, the crippling $420
5 fee in no way reduces the bond amount the migrant detainees owe.
6 33. Fourth, LBN charges an initial fee for affixing and activating the ankle shackle, plus
7 $420 a month. LBN fails to inform detainees that they will continue to pay the monthly fee
8 indefinitely. Indeed, detainees regularly end up paying total amounts to LBN that exceed or
9 approximate the amount of the bond.
10 34. Fifth, because LBNs core goal is to affix ankle shackles at exorbitant prices, LBN
11 has a concerted corporate practice of preventing the use of collateral instead of an ankle shackle to
12 securitize the bond, while actively discouraging detainees from exploring the use of collateral with
13 other companies.
14 35. The language from its website indicates this effort even goes so far as to exploit
15 detainees understanding of the term collateral:
16 The GPS program at Libre is about providing a critical service to our clients, the
17 securitization of their immigration bond so that they can be released from immigration
custody. Libre by Nexus guarantees the immigration bond, and uses the GPS to secure
18 the bond. This means that Libre clients are not required to pay collateral or post property
to be released.
19
There are many horror stories about families struggling to pay collateral for immigration
20
bonds. We've met families who have been forced to sell everything that they have to
21 pay collateral for a family member. We've seen families forced to go into their
communities to beg people for the use of their property as collateralLibre by Nexus
22 represents the hope that this may never have to happen again. We are constantly
innovating our services to help more detainees in crisis. We are here to help you. Contact
23 us today!
24
36. One does not sell to make collateral; one puts up collateral without disposing of it.
25
Despite LBNs scare tactics, families are not forced to sell everything to put up collateral on
26
immigration bonds when they use other companies.
27
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1 37. Sixth, LBN fails to inform detainees of a crucial fact: by arranging for the posting of
2 a bond, LBN ensures detainees will be moved from ICEs detained docket to ICEs non-
3 detained docket. The latter docket moves much more slowly, meaning that detainees will often
4 remain obligated to pay LBNs monthly fees for years on enda fact never disclosed by LBN.
5 38. Compounding this omission is another crucial one: LBN never informs people of the
6 total amount consumers are likely to end up paying in non-refundable fees. After one year on a
7 $10,000 bond, consumers will have paid LBN nearly $9,000 in nonrefundable fees. After two years,
8 that amount rises to $13,000 in nonrefundable payments.
9 39. Indeed, after just one year and five months, consumers on a $10,000 bond will have
10 paid LBN the full value of the bondin which case LBN bears no risk of flight or forfeiture. Yet,
11 LBN still keeps collecting the obscene monthly fee.
12 40. Seventh, after sign-up, LBN engages in aggressive debt collection practices to ensure
13 that detainees continue to pay the exorbitant monthly fee. For example, LBN falsely tells detainees
14 that they will be placed back in ICE custody if they fail to pay the $420 monthly fee.
15 41. Eighth, even within the confines of the unconscionable bargain, LBN adds even
16 more fees. For example, it automatically charges consumers a 50 cent-per-day insurance fee for
17 the ankle shackle, but never discloses that fact in Spanish and does not receive affirmative consent
18 for charging that fee.
19 42. Ninth, LBN conceals the burdensome nature of the ankle monitors. Its poor Spanish
20 translation for the device pulsera indicates that it will be lightweight and non-intrusive. In
21 reality, the ankle monitor is a heavy shackle that causes bruising when it is hauled by the wearer and
22 forces the migrant to be tethered to a wall electrical outlet for hours each day for charging, none of
23 which is disclosed at signup. The forced hauling and charging of the monitor is labor performed as a
24 condition of the bond, or debt servitude.
25 MARKETING
26 43. LBN is engaged in systematic, saturation-level marketing efforts in the immigrant
27 community.
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1 44. LBN consistently touts itself as an organization with the best interests of immigrants
2 in minda supposedly neutral advisor to get immigrants out of detention.
3 45. According to its website: If your loved one is in immigration detention, you need
4 help right away. Libre by Nexus is here to help. We will listen to you and we care about you and
5 your family. Our goal is to get your loved one released from jail as quickly as possible. In most
6 cases, we can have your loved one out the same or next day.
7 THE SIGN UP PROCESS
8 46. LBN targets families of detainees, providing partial and untrue representations about
9 its service, largely via verbal representations made in Spanish by its employees.
10 47. LBN then introduces written disclosures very late in the process, and those
11 disclosures are almost entirely in English.
12 48. Those disclosures directly conflict with representations given to detainees and their
13 families prior to provision of written disclosures.
14 49. Misrepresentations and omissions made by LBN representatives to Plaintiffs are
15 detailed in the Plaintiffs factual section below.
16
THE ONLY SPANISH LANGUAGE DOCUMENT PROVIDED BY LBN
17 MISREPRESENTS THE TRUE NATURE OF THE LEASE AGREEMENT, THE
MONTHLY RENTAL CHARGES, AND THE MONTHLY INSURANCE CHARGES
18
50. The only document provided in Spanish is a one-page document providing certain
19
summary disclosures and requiring initials from the detainee.
20
51. That document never states that detainees will be charged $420 a month in tracker
21
rental feesmuch less that they will be charged such fees indefinitely.
22
52. That document never states that detainees will be charged 50 cents per day to insure
23
those trackers.
24
53. Instead, the one-page Spanish language contract disclosure makes at least four
25
misleading and incomplete representations in check box formall of which are misleading.
26
54. LBN states that it will post the bond, and will pay the bail premium to a licensed bail
27
bond company after deducting applicable fees, including collateral processing fees. This indicates
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1 to reasonable consumers that they will not be liable for further charges by LBN, but rather that LBN
2 will compensate itself out of the bail premium paid by detainees.
3 55. Next, LBN misrepresents the consequences of a fail[ure] to meet program
4 conditions by stating that I may be remanded to the custody of the jurisdiction wherein I face
5 charges in the above referenced case. But that is not true either: LBN has no power to order
6 detention or invoke any ICE powers.
7 56. LBN also conceals the burdensome nature of the ankle monitors. The poor Spanish
8 translation for the device pulsera indicates that it will be lightweight and non-intrusive. The
9 ankle monitor, however, is a heavy shackle that causes bruising when it is hauled by the wearer and
10 forces the migrant to be tethered to a wall electrical outlet for hours each day for charging, none of
11 which is disclosed at signup.
12 57. Reasonable consumers like Plaintiffs, who could only understand the Spanish-
13 language disclosures provided by LBN, simply did not understand at the time of sign up that they
14 would be required to pay $420 every month, indefinitely, and be forced to haul and charge an ankle
15 shackle monitor, every day, indefinitely.
16
LBN REQUIRES UNCOMPREHENDING CONSUMERS TO SIGN AN ENGLISH-
17
LANGUAGE CONTRACT OF ADHESION
18 58. LBN then foists upon uncomprehending detainees a much longer English language
19 document entitled Libre by Nexus Respondent ContactConditions of Monitoring and Lease
20 Agreement. LBN is aware that the vast majority of its customers, including Plaintiffs, do not and
21 cannot understand this English-language document.
22 59. For the first and only time, LBN discloses in the lease document that a condition of
23 participation in the program referenced in the Spanish-language disclosure is a $420 monthly
24 program participant fee. LBN later specifies in the lease document that the $420 monthly fee is
25 for the GPS bracelet.
26 60. LBN also for the first and only time states in the lease document that GPS DEVICE
27 REQUIRED UNTIL CASE IS COMPLETE OR COLLATERAL PAID.
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1 61. The clauses reference to paying collateral fosters the understanding, for reasonable
2 consumers, that any monthly fees are going to pay down the amount of the bond. That is not true.
3 62. The very structure of the lease is deceptive. It is structured as a tripartite
4 documentbetween LBN, the detainee (or Leasee) and Agency. As a matter of course, LBN
5 does not fill in the name of the Agency. Consumers reasonably understand it means ICE. But ICE
6 has no involvement whatsoever in the lease agreement.
7 63. LBN implies ICE involvement expressly in the lease when it states that Lessee has
8 voluntarily undertaken to use the Equipment in order toavoid incarceration by Agency.
9 64. The contract repeatedly refers to the agency throughout the agreement, again
10 falsely implying ICE involvement.
11 65. According to the lease, the tracking device is charged at $14 per day.
12 66. In addition, insurance is charged at 50 cents per day with a deductible in the event
13 of loss @$50. Upon information and belief, LBN as a matter of corporate policy prechecks the
14 insurance option and does not allow consumers to rent a device without purchasing insurance.
15 67. Putting aside the specific provisions of the lease agreement, its fundamental premise
16 is a sham. Lessees are not in actuality paying $420 a month for rental of an ankle bracelet. Rather,
17 they are paying (excessively) for LBN to indemnify their immigration bail bond, which is provided
18 by a third party. But LBN never informs consumers that this is the true nature of the monthly fee.
19 68. LBN is a bond broker much more than it is a lessor of GPS trackers. That means the
20 $420 monthly GPS tracker fee does not primarily compensate LBN for use of the GPS tracker
21 itself. Rather, the fees represent a hidden indemnification fee that LBN charges for indemnifying
22 immigration bail bonds it procures from third parties.
23 69. Indeed, the GPS trackers cost LBN nowhere near $14 per day. According to public
24 filings in litigation against Nexus in the Northern District of Georgia, LBN pays no more than $3.00
25 per day, and $450 per tracker, to the supplier of its GPS ankle bracelets.
26 70. Yet it charges consumers $14 per day for those same bracelets, and nearly $4,000 for
27 their replacement.
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1 71. That is because a massive portion of the GPS rental fee is meant to excessively
2 compensate LBN for its role, as a middleman, in indemnifying the immigration bonds it arranges for
3 with third parties. Again, LBN never once informs detainees that the lease fee is actually for this
4 purpose.
5 72. A second document, entitled GPS Monitoring Disclosure Statements, also provided
6 only in English, exclusively governs the privacy concerns regarding the tracker.
7 73. The Monitoring Disclosure Statements contains an arbitration provision, written
8 entirely in English, which states that transactions that arise out of or relate to this Agreement shall
9 be resolved by arbitration. Plaintiffs claims do no arise out of or relate to claims regarding the
10 tracking of their location or similar matters and thus do not arise out of that agreementbut rather
11 arise out of the Lease Agreement and marketing practices. Plaintiff does not allege breaches of, or
12 misrepresentations in, the Monitoring Disclosure Statement.
13
THE TRACKERS DO NOT PERFORM AS INTENDED AND SEVERELY LIMIT
14
DAILY ACTIVITY OF WEARERS
15 74. The product LBN is offering for lease fails to perform its intended task. In fact, the
16 burdensome and intrusive act of perpetually hauling and charging the ankle shackle inverts the
17 transaction: it is the detainee who is performing a service to LBN, rather than LBN giving a product
18 to the detainee.
19 75. LBN never discloses the debilitating nature of the ankle shackle monitor and breaches
20 even the English warranties contained in the lease agreement that the GPS tracker will perform
21 properly.
22 76. According to LBNs own statements in prior litigation against Omnilink, the supplier
23 of its GPS trackers, Case No. 1:15-cv-03181-CC (N.D. Ga.):
24 77. Its hardware and software systems suffered from serious design flaws and other
25 defects that caused extensive failure rates, which in turn resulted in significant economic harm to
26 Plaintiffs customers, unnecessary disruptions to the lives of individuals who wore Plaintiffs
27 equipment[.] Answer, p. 2.
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1 78. At certain points in time between June 2014 and August 2015 Libre experienced a
2 product defect rate for Omnilink-supplied equipment and software in excess of 50%. Id., 29.
3 79. Moreover, the failure of the power cords meant that individuals who were required
4 to wear and recharge the power cords were left tethered to charging stations for hours a time,
5 which was disruptive to their daily lives. Id., 31-32.
6 80. LBN had experienced massive software and firmware and product defects and
7 failures such as inoperative charging devices, software that would drop (and not reset) signals
8 between cell towers, and other flaws that would make the electronic tracking service unavailable for
9 large numbers of individuals. Id., 39.
10 81. A substantial percentage of the equipment provided by the supplier failed to function
11 in conformity with the terms of the Lease Agreement. Id., 31.
12 82. A substantial percentage of the power cords provided by the supplier failed to
13 properly charge their accompanied electronic monitoring devices, leaving those devices inoperable
14 and Services incapable of providing geophysical monitoring for the impacted end user. Moreover,
15 the failure of the power cords meant that individuals who were required to wear and recharge the
16 power cords were left tethered to charging stations for hours a time, which was disruptive to their
17 daily lives. Id.
18 83. Even if the financial facets of the program had been disclosed properly and fairly to
19 detainees (they were not), reasonable consumers would not have entered into any contract with LBN
20 if they had known the true nature of the faulty ankle monitors, including its persistent intrusion on
21 daily life.
22
LBN DOES NOT RECEIVED INFORMED CONSENT TO CHARGE INSURANCE
23
FEES
24 84. Upon information and belief, LBN automatically charges consumers an insurance
25 fee for the GPS ankle shackle, but never discloses that fact in Spanish and does not receive
26 affirmative consent for charging that fee.
27
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1 85. Upon information and belief, LBN uniformly prechecks an insurance option and
2 does not allow consumers to rent a device without purchasing insurance.
3 Plaintiff Vasquezs Experience
4 86. Plaintiff Vasquez is an asylum-seeker who fled his native Honduras because he was a
5 target of gang violence.
6 87. In December 2015, he came to the United States and was placed in detention in
7 Houston, Texas.
8 88. An Immigration Judge set Mr. Vasquezs bond at $10,000.
9 89. Early last year, while in detention, he heard from other detainees that LBN could
10 assist him in posting bond, and one other detainee gave him a phone number to contact LBN by
11 Nexus.
12 90. Plaintiff Vasquez gave the information to his wife, who communicated with LBN
13 while Plaintiff was detained.
14 91. While in detention, Plaintiff Vasquezs impression was that he would pay some
15 money upfront to LBN, LBN would pay the bond, and that he would owe LBN that money on the
16 bond. Plaintiff Vasquez understood that there would be a monthly payment but believed it would pay
17 down the bond. Plaintiff was never informed that a third party was posting his bond.
18 92. Immediately after his release, an LBN representative met with Plaintiff Vasquez and
19 gave him a contract to sign. This contract is attached hereto as Exhibit A. It is entirely in English
20 even though Plaintiff Vasquez is not proficient in written or spoken English. The Libre
21 representative verbally explained some portions of the contract in Spanish, including that he owed
22 Libre the $8,000 remaining on the $10,000 bond (of which Plaintiff Vasquez had paid $2,000
23 upfront) and that Plaintiff Vasquez would have to wear an ankle bracelet at all times. The
24 representative also said that Plaintiff Vasquez could not disturb or remove the ankle monitor because
25 doing so would be a crime and he would be incarcerated for doing so. He was also told that any
26 damage to the monitor would result in a $3,000 fine.
27 93. Due to such misrepresentations, Plaintiff Vasquez believed that LBN was affiliated
28
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1 with United States Immigration Customs Enforcement (ICE).

2 94. Plaintiff Vasquez agreed to what he believed to be the agreement with LBN in part
3 because he believed it was his only option for release from detention.
4 95. Plaintiff was not informed that he would need to pay $420 per month in perpetuity;
5 that LBN was charging these monies to compensate itself for indemnifying his bond with a third
6 party; that he would be moved from the detained to the non-detained docket, meaning he could be
7 required to pay LBN for years; that the tracker was poorly designed and would force him to stay
8 tethered to a wall for hours a day; that the device becomes extremely hot when charging; and that the
9 tracker was intrusive and bulky.
10 96. After he signed the agreement, LBN brought out the ankle shackle monitor, which
11 was much bulkier than Plaintiff Vasquez was led to believe, and affixed the monitor to his leg.
12 97. LBN also failed to disclose to Plaintiff Vasquez that the monitor would be as
13 intrusive as it was. The device must be charged for two hours every day, otherwise it will start
14 vibrating intensely. It is charged by a charger connected to a wall outlet, which means that Plaintiff
15 Vasquez is tethered to the wall for two hours a day. After minutes of charging, the device becomes
16 very hot, preventing Plaintiff Vasquez from sleeping while the device charges. An LBN
17 representative told him that he should not sleep while the device is charging because it could catch
18 fire.
19 98. Hauling the ankle monitor has significantly impeded Plaintiff Vasquezs work as a
20 day laborer. It has caused Plaintiff Vasquez severe leg pain, prevented him from carrying out some
21 tasks like climbing a ladder, and caused him to trip and fall when he was doing yard work. When
22 Plaintiff Vasquez complained to LBN about the physical pain the ankle monitor was causing him,
23 LBN responded that there was nothing it could do and that he should see a doctor. Plaintiff Vasquez
24 has not sought medical attention because of the financial cost it would entail.
25 99. The financial burden of payments to LBN has been crushing for Plaintiff Vasquez. In
26 addition to the $2,000 he paid up front, he has paid about $2,000 in monthly rental fees, and will
27 pay much more since his immigration case is not set to be heard until the end of 2017.
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15
1 100. To pay the monthly fees to LBN, Plaintiff must remit a substantial portion of his
2 modest wages as a day laborer. In addition to his work as a day laborer, Plaintiff Vasquez does
3 miscellaneous side jobs like collecting cans for recycling to earn enough money to pay LBN.
4 101. Even though Plaintiff has kept up with his monthly rental fees, he received a call a
5 few months ago from an LBN representative saying that he had missed two payments and could be
6 incarcerated as a result. Plaintiff kept his financial records of payment, though, and showed that he
7 had, in fact, made all of his required payments to LBN. LBN eventually agreed. Nevertheless, the
8 nature of the call further solidified in Plaintiffs mind that he needed to keep up with payments
9 otherwise he would be sent to jail or back to Honduras.
10 102. Plaintiff would not have entered into the lease agreement if terms had been disclosed
11 accurately and truthfully.
12 103. Plaintiff would not have entered into the lease agreement if he knew the intrusive and
13 burdensome nature of the ankle monitor.
14 104. Plaintiff did not receive any payment for maintaining, charging and hauling his ankle
15 monitor for LBNs benefit and under threat of detention by LBN.
16 105. Plaintiffs and class members reliance on LBNs false and misleading
17 representations and omissions in the Spanish-language document and in verbal representations was
18 reasonable.
19 Plaintiff Ortizs Experience
20 106. Plaintiff Ortiz is an asylum-seeker who fled her native Honduras because she was a
21 target of gang violence and gang-affiliated sexual assault.
22 107. In April 2015, she came to the United States and was placed in detention in Houston,
23 Texas.
24 108. An Immigration Judge set Ms. Ortizs bond for $20,000.
25 109. In 2015, while in detention, she heard from other detainees that LBN could assist her
26 in posting bond. One other detainees family had seen commercials on television and gave Plaintiff
27 Ortiz LBNs telephone number.
28
16
1 110. Plaintiff Ortiz gave the information to her husband who communicated with LBN
2 while she was in detention.
3 111. While in detention, Plaintiff Ortizs understanding, based on LBNs representations,
4 was that LBN would pay the $20,000 on the bond, and that she would owe LBN that money, which
5 she believed was being loaned by LBN. She was never informed a third party was posting her bond.
6 In addition, she understood would need to pay $5,000 upfront, plus pay a monthly fee of $420 and
7 that she would need to wear an ankle monitor at all times. She believed the monthly fee would go
8 toward paying down the bond.
9 112. Immediately after her release, an LBN representative picked Plaintiff Ortiz up from
10 the detention facility, took her to an office and gave her a contract to sign. This contract is attached
11 hereto as Exhibit B. It is almost entirely in English, with just one page of limited disclosures in
12 Spanish, even though Plaintiff Ortiz is not proficient in written or spoken English. The LBN
13 representative verbally explained some portions of the contract in Spanish, including that she owed
14 LBN the $15,000 remaining on the bond and that Plaintiff Ortiz would have to wear an ankle
15 bracelet at all times. She was also led to believe that she could not disturb or remove the ankle
16 monitor because doing so would be a crime and she would be detained, incarcerated or deported.
17 113. LBN also took several mugshot like photos of Ms. Ortiz, leading her to believe that
18 ICE or the police would come after her if she did anything wrong to the device or failed to keep up
19 on payments.
20 114. Plaintiff Ortiz believed that LBN was affiliated with United States Immigration
21 Customs Enforcement (ICE).
22 115. Plaintiff Ortiz agreed to what she believed to be the agreement with LBN in part
23 because she believed it was her only option for release from detention.
24 116. Plaintiff was not informed that she would need to pay $420 per month in perpetuity;
25 that LBN was charging these monies to compensate itself for indemnifying her bond with a third
26 party; that she would be moved from the detained to the non-detained docket, meaning she could be
27 required to pay LBN for years; that the tracker was poorly designed and would force her to stay
28
17
1 tethered to a wall for hours a day; that the device becomes extremely hot when charging; and that the
2 tracker was intrusive and bulky.
3 117. After she signed the agreement, LBN brought out the ankle shackle monitor, which
4 was much bulkier than Plaintiff Ortiz was led to believe, and affixed the monitor to her leg.
5 118. LBN failed to disclose to Plaintiff Ortiz that the monitor would be as intrusive as it
6 was. Originally, Plaintiff Ortiz had a monitor that would die very quickly after charging, requiring
7 her to charge the device for hours every day. LBN would frequently call her to let her know that her
8 device was not charged and needed to be.
9 119. Eventually, LBN gave her a new monitor, which was still burdensome, albeit less so.
10 She still must charge the monitor for two hours every day, otherwise it will start vibrating intensely.
11 It is charged by a charger connected to a wall outlet, which means that Plaintiff Ortiz is tethered to
12 the wall for two hours a day. After minutes of charging, the device becomes very hot, preventing
13 Plaintiff Ortiz from sleeping while the device charges. The tethering is especially burdensome
14 because Plaintiff is pregnant, a concern that she has expressed to LBN, but that has not been
15 addressed.
16 120. Hauling the ankle monitor has also significantly impeded Plaintiff Ortizs day-to-day
17 life in other ways. It has, for example, caused bruising.
18 121. The financial burden of payments to LBN by Nexus has been crushing for Plaintiff
19 Ortiz and her family. In addition to the $5,000 she paid up front, she has paid about $7,140 in
20 monthly rental fees, and will pay much more since her immigration case is not set to be heard until
21 the end of this year.
22 122. To pay the monthly fees to LBN, Plaintiff must remit a substantial portion of her
23 husbands modest wages. Their family has undergone substantial hardship from keeping up with the
24 payments. For example, Ms. Perdomo Ortiz and her husband have had to forgo buying groceries in
25 order to make her monthly payment to LBN.
26 123. Even though Plaintiff has kept up with her monthly rental fees, she has received calls
27 from a LBN representative saying that she had missed payments and could be incarcerated as a
28
18
1 result. The nature of the calls further solidified in Plaintiffs mind that she needed to keep up with
2 payments otherwise she would be sent to jail, detention or back to Honduras.
3 124. Plaintiff would not have entered into the lease agreement if terms had been disclosed
4 accurately and truthfully.
5 125. Plaintiff would not have entered into the lease agreement if she knew the intrusive
6 and burdensome nature of the ankle monitor.
7 126. Plaintiff did not receive any payment for maintaining, charging and hauling her ankle
8 monitor for LBNs benefit and under threat of detention by LBN.
9 127. Plaintiffs and class members reliance on LBNs false and misleading
10 representations and omissions in the Spanish-language document and in verbal representations was
11 reasonable.
12 CLASS ALLEGATIONS
13 128. Plaintiffs incorporate and reallege each and every preceding paragraph as if fully set
14 forth herein.
15 129. Plaintiffs bring this action on behalf of themselves and the members of the proposed
16 National Class and California Subclass. The proposed National Class consists of:
17 All individuals residing in the United States who, within the applicable
18 statute of limitations preceding the filing of this action and going forward
from the date of this Complaint, paid monies to LBN and wore a GPS tracker
19 provided by LBN.
20
130. The proposed California Subclass consists of:
21
All individuals residing in the State of California who, within the applicable
22
statute of limitations preceding the filing of this action and going forward
23 from the date of this Complaint, paid monies to LBN and wore a GPS tracker
provided by LBN.
24
25 131. Excluded from the Class and Subclass are LBN, its parents, subsidiaries, affiliates,
26 officers and directors, any entity in which LBN has a controlling interest, all customers who make a
27 timely election to be excluded, governmental entities, and all judges and their staff assigned to hear
28
19
1 any aspect of this litigation, as well as their immediate family members.

2 132. The members of the Class and Subclass are so numerous that joinder is impractical.
3 The Class and Subclass consist of thousands of members, the precise number of which is within the
4 knowledge of and can be ascertained only by resort to LBNs records.
5 133. There are numerous questions of law and fact common to the Class and Subclass
6 which predominate over any questions affecting only individual members of the Class and Subclass.
7 Among the questions of law and fact common to the Subclass are:
8 (a) Whether LBN engaged in unfair, unlawful and/or fraudulent business practices under
9 California law;
10 (b) Whether LBN misrepresented and/or failed to disclose material facts.
11 (c) Whether LBN made false or misleading statements of fact;
12 (d) Whether LBNs conduct, as alleged herein, was intentional and knowing;
13 (e) Whether Class members are entitled to damages and/or restitution, and in what
14 amount;
15 (f) Whether an injunction is necessary; and
16 (g) Whether Plaintiff and Class members are entitled to an award of reasonable attorneys
17 fees, pre-judgment interest, and costs of suit.
18 Among the questions of law and fact common to the Class are:
19 (a) Whether LBN held Class Members in a condition of peonage in violation of 18
20 U.S.C. 1581;
21 (b) Whether LBN forced Class Members to labor in violation of 18 U.S.C. 1589;
22 (c) Whether Class Members are entitled to damages and in what amount;
23 (d) Whether an injunction is necessary; and
24 (e) Whether Plaintiffs and Class members are entitled to an award of reasonable
25 attorneys fees, pre-judgment interest, and costs of suit.
26 134. Plaintiffs claims are typical of the claims of the members of the Class and Subclass.
27 Plaintiffs have no interests antagonistic to the interests of any other member of the Class and
28
20
1 Subclass.
2 135. Plaintiffs are adequate representatives who will fully and adequately assert and
3 protect the interests of the Class and Subclass, and have retained counsel experienced in prosecuting
4 class actions.
5 136. A class action is superior to all other available methods for the fair and efficient
6 adjudication of this lawsuit, because individual litigation of the claims of all members of the Class
7 and Subclass is economically unfeasible and procedurally impracticable. While the aggregate
8 damages sustained by the Class and Subclass are in the millions of dollars, the individual damages
9 incurred by each member of the Class and Subclass resulting from LBNs wrongful conduct are too
10 small to warrant the expense of individual lawsuits. The likelihood of individual Class and Subclass
11 members prosecuting their own separate claims is remote, and, even if every member of the Class
12 and Subclass could afford individual litigation, the court system would be unduly burdened by
13 individual litigation of such cases.
14 137. The prosecution of separate actions by members of the Class and Subclass would
15 create a risk of establishing inconsistent rulings and/or incompatible standards of conduct for LBN.
16 For example, one court might enjoin LBN from performing the challenged acts alleged herein,
17 whereas another might not. Additionally, individual actions may be dispositive of the interests of the
18 Class and Subclass, although certain class members are not parties to such actions.
19 138. LBNs alleged misconduct is generally applicable to the Class and Subclass as a
20 whole, and Plaintiffs seek, inter alia, equitable remedies with respect to the Class and Subclass as a
21 whole. As such, the systematic policies and practices of LBN make declaratory relief with respect to
22 the National Class and California Subclass as a whole appropriate.
23 COUNT I
(Violation of the Unfair Prong of the UCL,
24 California Business & Professions Code 17200, et seq.)
(California Subclass Only)
25
139. Plaintiffs incorporate and reallege each and every preceding paragraph as if fully set
26
forth herein.
27
140. The UCL defines unfair business competition to include any unlawful, unfair or
28
21
1 fraudulent act or practice, as well as any unfair, deceptive, untrue or misleading advertising. Cal.
2 Bus. & Prof. Code 17200.
3 141. A business act or practice is unfair under the UCL if the reasons, justifications and
4 motives of the alleged wrongdoer are outweighed by the gravity of the harm to the alleged victims.
5 142. LBN has violated the unfair prong of the UCL through its acts and omissions
6 detailed herein, including the imposition of an exploitative English-language agreement onto non-
7 English speakers, who are required to pay exorbitant fees and haul GPS ankle monitors over a
8 number of years under the threat of detention.
9 143. The acts and practices alleged herein are unfair because they caused Plaintiff, and
10 reasonable consumers like them, to incur substantial financial loss.
11 144. The gravity of the harm to members of the Class resulting from these unfair acts and
12 practices outweighs any conceivable reasons, justifications and/or motives of LBN for engaging in
13 such deceptive acts and practices. By committing the acts and practices alleged above, LBN engages
14 in unfair business practices within the meaning of California Business & Professions Code
15 17200, et seq.
16 145. Through its unfair acts and practices, LBN has improperly obtained money from
17 Plaintiffs and the Class. As such, Plaintiffs request that this court cause LBN to restore this money to
18 Plaintiffs and all Class members, and to enjoin LBN from continuing to violate the UCL as
19 discussed herein and/or from violating the UCL in the future. Otherwise, Plaintiffs and the Class
20 may be irreparably harmed and/or denied an effective and complete remedy if such an order is not
21 granted.
COUNT II
22
(Violation of the Fraudulent Prong of the UCL,
24
25
forth herein.
26
27
fraudulent act or practice, as well as any unfair, deceptive, untrue or misleading advertising. Cal.
28
22
1 Bus. & Prof. Code 17200.

2 148. A business act or practice is fraudulent under the UCL if it is likely to deceive
3 members of the consuming public.
4 149. LBN deceived consumers into believing, inter alia, that LBN was their only option to
5 leave detention, that the financial terms were manageable, that LBC was connected to and could
6 invoke the powers of a U.S. government agency, and that wearing an LBN ankle bracelet would
7 not be onerous. LBNs acts and practices as described herein have deceived Plaintiffs and were
8 highly likely to deceive members of the consuming public. Accordingly, Plaintiffs suffered monetary
9 loss as a direct result of LBNs practices described herein.
10 150. As a result of the conduct described above, LBN has been unjustly enriched at the
11 expense of Plaintiffs and members of the proposed Class. Specifically, LBN has been unjustly
12 enriched by obtaining revenues and profits that it would not otherwise have obtained absent its false,
13 misleading and deceptive conduct.
14 151. Through its unfair acts and practices, LBN has improperly obtained money from
19 granted.
COUNT III
20
(Violation of the Unlawful Prong of the UCL,
22
23
forth herein.
24
25
fraudulent act or practice, as well as any unfair, deceptive, untrue or misleading advertising. Cal.
26
Bus. & Prof. Code 17200.
27
154. A business act or practice is unlawful under the UCL if it violates any other law or
28
23
1 regulation.
2 155. California Civil Code 1770(a)(9) prohibits a business from [a]dvertising goods or
3 services with intent not to sell them as advertised.
4 156. As a result of the conduct described above, LBN has been unjustly enriched at the
5 expense of Plaintiff and members of the proposed Class. Specifically, LBN has been unjustly
6 enriched by obtaining revenues and profits that it would not otherwise have obtained absent its false,
7 misleading and deceptive conduct.
8 157. Through its unlawful acts and practices, LBN has improperly obtained money from
13 granted.
14 COUNT IV
(Violation of the Consumers Legal Remedies Act,
15 California Civil Code 1750, et seq.)
16
17
forth herein.
18
159. This cause of action is brought pursuant to the CLRA.
19
160. Plaintiffs and each member of the proposed class are consumers within the meaning
20
of California Civil Code 1761(d).
21
161. LBNs selling of LBN Outlet Products to Plaintiffs and the Class were transactions
22
within the meaning of California Civil Code 1761(e). The LBN services purchased by Plaintiffs
23
and the Class are goods within the meaning of Civil Code 1761(a).
24
162. As described herein, LBN violated Civil Code 1770(a)(8), by [a]dvertising goods
25
or services with intent not to sell them as advertised.
26
163. Plaintiffs relied on LBNs false representations in deciding to purchase LBN services.
27
Plaintiffs would not have purchased LBN services or would have paid less for them absent LBNs
28
24
1 unlawful conduct.
2 164. Plaintiffs request this Court enjoin LBN from continuing to violate the CLRA as
3 alleged herein in the future and to order restitution to Plaintiffs and each member of the proposed
4 class. Otherwise, Plaintiffs, the Class and members of the general public may be irreparably harmed
5 and/or denied effective and complete remedy if such an order is not granted.
COUNT V
6
(Violation of the California Translation Act,
7 California Civil Code 1632)
8
9
forth herein.
10
166. This cause of action is brought pursuant to California Civil Code 1632, the
11
California Translation Act.
12
167. LBN is engaged in a trade or business and orally negotiated primarily in
13
Spanish in the course of entering into rental contracts with Plaintiffs and Class members.
14
168. For the rental contracts, LBN failed to translate every term and condition in those
15
contracts. LBN deliberately and selectively translated certain terms into Spanish to mislead
16
consumers such as Plaintiffs and Class members into believing they were receiving a materially
17
better deal than they ultimately did.
18
169. Plaintiffs and Class members reliance on LBNs false and misleading
19
representations and omissions in the Spanish language document and in verbal representations was
20
reasonable.
21 COUNT VI
22 (Violation of the Prohibition on Peonage,
18 U.S.C. 1581)
23 (National Class)
24 170. Plaintiffs incorporate and reallege by reference each and every preceding paragraph
25 as if fully set forth herein.
26 171. This cause of action is brought pursuant to 18 U.S.C. 1581, the Federal Prohibition
27 on Peonage.
28
25
1 172. LBN holds vulnerable and indigent Spanish-speaking immigrant detainees, including
2 Plaintiffs, in a condition of peonage. LBN lures detainees into hauling ankle shackle monitors, which
3 are heavy and prone to cause injuries including sharp pain and bruises, and charging the devices
4 while tethered to an electronic outlet for hours at a time.
5 173. The detainees are compelled to provide the labor or service of hauling and charging
6 the devices as a condition of debts brokered by LBN.
7 174. The detainees are victims authorized to bring a civil action against LBN since it is the
8 perpetrator of a violation of the Peonage statute or knowingly benefitted from participation in a
9 venture in violation of the Peonage statute. 18 U.S.C. 1595.
10 COUNT VII
(Violation of the Prohibition on Forced Labor,
11 18 U.S.C. 1589)
(National Class)
12
175. Plaintiffs incorporate and reallege by reference each and every preceding paragraph
13
as if fully set forth herein.
14
176. This cause of action is brought pursuant to 18 U.S.C. 1589, the Federal Prohibition
15
on Forced Labor.
16
177. LBN knowingly obtained the labor or services of vulnerable and indigent Spanish-
17
speaking immigrant detainees, including Plaintiffs. LBN lures the detainees into hauling ankle
18
shackle monitors, which are heavy and prone to cause injuries including sharp pain and bruises, and
19
charging the devices while tethered to an electronic outlet for hours at a time.
20
178. LBN obtained this labor or service from the detainees to secure loans from bail-
21
bondsmen that it would use to, on the one hand, pay the detainees bond, while, on the other hand,
22
extract exorbitant sums from detainees that far exceed the original bond by charging them to rent and
23
insure the devices.
24
179. LBN obtained the labor or service from the detainees by means of threats of physical
25
restraint, the abuse or threatened abuse of law or legal process, and by scheme to cause the detainees
26
to believe that, if they did not perform such labor or services, the detainees would suffer physical
27
restraint. LBN told the detainees or otherwise led them to believe that if they did not provide the
28
26
1 labor or service of hauling and charging the ankle shackle monitors they would be returned to
2 detention.
3 180. The detainees are victims authorized to bring a civil action against LBN since it is the
4 perpetrator of a violation of the Forced Labor statute or knowingly benefitted from participation in a
5 venture in violation of the Forced Labor statute. 18 U.S.C. 1595.
6 PRAYER FOR RELIEF
7 WHEREFORE, Plaintiffs Juan Quintanilla Vasquez and Gabriela Perdomo Ortiz, and the
8 members of the Class, demand a jury trial on all claims so triable and judgment against Defendants,
9 as follows:
10 A. An order certifying that this action may be maintained as a class action, that Plaintiffs
11 be appointed Class Representative and Plaintiffs counsel be appointed Class Counsel;
12 B. A judgment awarding Plaintiffs and all members of the Class restitution and/or other
13 equitable relief, including, without limitation, restitutionary disgorgement of all profits and unjust
14 enrichment that LBN obtained from Plaintiffs and the Class as a result of its unlawful, unfair and
15 fraudulent business practices described herein;
16 C. An order enjoining LBN from continuing to violate the UCL, CLRA, California
17 Translation Act, Prohibition on Peonage, and Prohibition on Forced Labor, as described herein;
18 D. A judgment awarding actual and punitive damages to Plaintiffs and the Class in an
19 amount to be determined at trial;
20 E. A judgment awarding Plaintiffs costs of their suit; including reasonable attorneys
21 fees pursuant to California Civil Code 1780(d), Code of Civil Procedure 1021.5 and as otherwise
22 permitted by statute; and pre and post-judgment interest; and
23 F. Such other and further relief as may be deemed necessary or appropriate.
24 JURY TRIAL DEMANDED
25 PLAINTIFFS demand a jury trial on all triable issues.
26
27
28
27
2 Dated: February 15, 2017 Respectfully Submitted,
3 By: /s/ Jeffrey Kaliel

JEFFREY KALIEL, CA Bar No. 238293
4 TYCKO & ZAVAREEI LLP
483 Ninth Street, Suite 200
5 Oakland, CA 94607
Telephone (510) 254-6808
6 Facsimile (202) 973-0950
[email protected]
7
8 PAUL CHAVEZ, CA Bar No. 241576

JESSE NEWMARK, CA Bar No. 247488
9 AIDIN CASTILLO, CA Bar No. 280262
CENTRO LEGAL DE LA RAZA
10 3400 E. 12th Street,
Oakland, CA 94601
11 Telephone (510) 437-1554
[email protected]
12 [email protected]
[email protected]
13
NICHOLAS A. MIGLIACCIO, pro hac vice forthcoming
14 JASON S. RATHOD, pro hac vice forthcoming
MIGLICACCIO & RATHOD LLP
15 412 H St NE, Suite 302
Washington DC 20002
16 Telephone (202) 470-3520
[email protected]
17 [email protected]
18 Attorneys for Plaintiffs
19
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22
23
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Case 4:17-cv-00755-DMR Document 1 Filed 02/15/17 Page 1 of 28

1 JEFFREY KALIEL, California Bar No. 238293

5 Attorney for Plaintiffs

8 UNITED STATES DISTRICT COURT

CLASS ACTION COMPLAINT

1 with United States Immigration Customs Enforcement (ICE).

1 any aspect of this litigation, as well as their immediate family members.

1 Bus. & Prof. Code 17200.

25 as if fully set forth herein.

2 Dated: February 15, 2017 Respectfully Submitted,

3 By: /s/ Jeffrey Kaliel

8 PAUL CHAVEZ, CA Bar No. 241576

18 Attorneys for Plaintiffs

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