Case 1:20-cv-02354 Document 1 Filed 08/07/20 USDC Colorado Page 1 of 17
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`UNITED STATES DISTRICT COURT
`DISTRICT OF COLORADO
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`CASE NO:
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`v.
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`Plaintiff,
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`DAVID ULERY, individually and
`on behalf of all others similarly situated,
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`
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`AT&T MOBILITY SERVICES, LLC,
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`Defendants.
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`______________________________/
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`CLASS ACTION COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL
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`Plaintiff, DAVID ULERY (hereinafter “Plaintiff”), brings this class action pursuant to Rule
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`23 of the Federal Rules of Civil Procedure against Defendant, AT&T MOBILITY SERVICES,
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`LLC (“AT&T”), for its violations of the Telephone Consumer Protection Act, 47 U.S.C. 227
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`(hereinafter “the TCPA”), and the regulations promulgated thereunder. In support, Plaintiff alleges
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`as follows:
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`PRELIMINARY STATEMENT
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`1.
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`Plaintiff brings this Class Action Complaint for damages, injunctive relief, and any
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`other available legal or equitable remedies, resulting from the illegal actions of Defendant in
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`negligently or willfully contacting Plaintiff on Plaintiff’s cellular telephone, in violation of the
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`Telephone Consumer Protection Act, 47 U.S.C. § 227 (“TCPA”), thereby invading Plaintiff’s
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`privacy. Plaintiff alleges as follows upon personal knowledge as to himself and his own acts and
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`experiences, and, as to all other matters, upon information and belief, including investigation
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`conducted by his attorneys.
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`Case 1:20-cv-02354 Document 1 Filed 08/07/20 USDC Colorado Page 2 of 17
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`2.
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`Between approximately July 23, 2020 and continuing through the filing of this
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`Complaint, Plaintiff and each Class member revoked their consent to receive text messages from
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`Defendant by texting “STOP”1 to Defendant. Thereafter, Defendant sent or caused to be sent
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`informational text messages to Plaintiff and Class Members despite the clear revocation of consent
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`that Plaintiff and each Class Member had expressed. The instant action challenges all post-
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`revocation text messages that were sent by Defendant to Plaintiff and Class Members from
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`approximately July 23, 2020, through the date of filing this class action complaint.
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`3.
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`“Month after month, unwanted robocalls and texts, both telemarketing and
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`informational, top the list of consumer complaints received by the [FCC].”2 The TCPA is designed
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`to protect consumer privacy by, among other things, prohibiting the making of autodialed or
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`prerecorded-voice calls to cell phone numbers and failing to institute appropriate do-not-call
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`procedures. 47 U.S.C. § 227(b)(1)(A)(iii); 47 C.F.R. § 64.1200(d).
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`4.
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`The TCPA was designed to prevent calls like the ones described within this complaint,
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`and to protect the privacy of citizens like Plaintiff. “Voluminous consumer complaints about
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`abuses of telephone technology – for example, computerized calls dispatched to private homes –
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`prompted Congress to pass the TCPA.” Mims v. Arrow Fin. Servs., LLC, 132 S. Ct. 740, 744
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`(2012).
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`5. Additionally, the FCC has explicitly stated that the TCPA’s prohibition on automatic
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`telephone dialing systems “encompasses both voice calls and text calls to wireless numbers
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`including, for example, short message service (SMS) calls.” U.S.C.A. Const. Amend. 5; Telephone
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`Consumer Protection Act of 1991, § 3(a), 47 U.S.C. § 227(b)(1)(A)(iii). Kramer v. Autobytel, Inc.,
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`759 F. Supp. 2d 1165 (N.D. Cal. 2010).
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`Or other written words reasonably evidencing an express revocation of consent.
`1.
`2. In re Rules & Regs. Implementing the TCPA, 30 FCC Rcd. 7961, ¶ 1 (2015).
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`2
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`6.
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`In enacting the TCPA, Congress intended to give consumers a choice as to how
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`companies may call them and made specific findings that “[t]echnologies that might allow
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`consumers to avoid receiving such calls are not universally available, are costly, are unlikely to be
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`enforced, or place an inordinate burden on the consumer. TCPA, Pub.L. No. 102–243, § 11.
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`Toward this end, Congress found that:
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`[b]anning such automated or prerecorded telephone calls to the home, except when
`the receiving party consents to receiving the call or when such calls are necessary
`in an emergency situation affecting the health and safety of the consumer, is the
`only effective means of protecting telephone consumers from this nuisance and
`privacy invasion.
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`Id. at § 12; see also Martin v. Leading Edge Recovery Solutions, LLC, 2012 WL 3292838,
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`at *4 (N.D. Ill. Aug. 10, 2012) (citing Congressional findings on TCPA’s purpose).
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`7.
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`In an action under the TCPA, a plaintiff must only show that the defendant “called a
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`number assigned to a cellular telephone service using an automatic dialing system or prerecorded
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`voice.” Breslow v. Wells Fargo Bank, N.A., 857 F. Supp. 2d 1316, 1319 (S.D. Fla. 2012), aff'd,
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`755 F.3d 1265 (11th Cir. 2014).
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`JURISDICTION AND VENUE
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`8. This Court has federal question subject matter jurisdiction pursuant to 28 U.S.C. § 1331
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`and 47 U.S.C. § 227.
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`9. Venue in this judicial district is proper under 28 U.S.C. § 1391(b)(2), because a
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`substantial part of the events or omissions giving rise to the claims in this case occurred in this
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`District, including Defendant’s transmission of the unlawful and unwanted calls to Plaintiff in this
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`District.
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`10. Plaintiff resides in Pueblo, Colorado, where the subject text messages were received,
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`within the jurisdiction of this Honorable Court.
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`11. The Court has personal jurisdiction over Defendant because it conducts business in this
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`state, maintain principle places of business in this state, markets its services within this state,
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`employs individuals in this state, and has availed itself to the jurisdiction of this state by placing
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`calls to Plaintiff and Class Members from this state.
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`12. Plaintiff’s domicile is in Pueblo, Colorado.
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`PARTIES
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`13. Defendant, AT&T is a Delaware Limited Liability Company and citizen of the state of
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`Georgia, listing its principal address at 1025 Lenox Park Blvd NE, Atlanta, Georgia 30319.
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`AT&T’s registered agent in the state of Colorado is listed as C T Corporation System, at 7700 East
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`Arapahoe Road Suite 220, Centennial, Colorado, 80112-1268.
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`14. AT&T is a national wireless and telephone company that promotes and markets its
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`services throughout the country, and during the relevant time period, sent unsolicited informational
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`text messages to wireless telephone users in violation of the TPCA.
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`15. Defendant, directly, individually, jointly, and/or in concert with another, or through
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`other persons, entities or agents acting on their behalf, conspired to, agreed to, contributed to,
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`authorized, assisted with, ratified, and/or otherwise caused all of the wrongful acts and omissions,
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`including the dissemination of the unsolicited text messages that are the subject matter of this
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`Complaint.
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`FACTUAL ALLEGATIONS
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`16. At all times relevant, Plaintiff, and at all times mentioned herein was, a “person” as
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`defined by 47 U.S.C. § 153 (39).
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`17. Defendant is authorized to engage in business in the State of Colorado, and at all times
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`mentioned herein was a corporation and “person,” as defined by 47 U.S.C. § 153(39).
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`18. At all times relevant Defendant conducted business in the State of Colorado, within
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`this judicial district.
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`19. AT&T utilizes bulk text messaging, to send unsolicited text messages, including at least
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`16 unwanted post revocation text messages to Plaintiff alone beginning on July 23, 2020 and
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`continuing through filing of this Complaint.
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`20. AT&T created and operated the unsolicited text messages that are the subject of this
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`lawsuit.
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`21. From April 2020 through approximately June 5, 2020, Plaintiff was employed by
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`Defendant as a customer service representative at one of its locations in Pueblo, Colorado.
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`Plaintiff’s employment with Defendant ceased on June 5, 2020.
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`22. Nearly seven (7) weeks after Plaintiff’s employment with Defendant ended, on July 23,
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`2020, at approximately 6:00 a.m., Defendant sent or caused to be sent to Plaintiff a text message
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`from the following short code number: 148507108.
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`23. The text message Defendant sent to Plaintiff contained the following message:
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`ATT Msg: Before you come into work today, ask yourself if you
`are experiencing any COVID-19 symptoms (such as a fever,
`chills, cough, shortness of breath, sore throat, etc.) or have been
`exposed to anyone with COVID-19 within the last 14 days.
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`If so, DO NOT report to your work location and contact your
`supervisor or the appropriate attendance number for your
`location. If you think you may have been exposed to COVID-
`19, reach out to your health provider immediately.
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` Text STOP to opt out
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`24. After receiving this text message, Plaintiff replied “STOP” at 7:42 a.m. on July 23,
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`2020, so that he would no longer receive unwanted text messages from AT&T.
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`25. Plaintiff expressly revoked consent to receive “mobile alert” text messages by sending
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`an “opt-out” message to Defendant. Plaintiff specifically followed the instructions that Defendant
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`provided in its text messages to revoke consent by texting “STOP” to Defendant on July 23, 2020.
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`26. All text messages sent by Defendant or on behalf of Defendant to Plaintiff on or after
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`July 23, 2020, were sent without his consent.
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`27. Notwithstanding Plaintiff’s opt-out reply on July 23, 2020, Defendant sent the exact
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`same automated text message to Plaintiff at 6:00 a.m. every single day on July 24, July 25, July
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`26, July 27, July 28, July 29, July 30, July 31, and August 1, August 2, August 3, August 4, August
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`5, August 6, and August 7, 2020.
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`28. On July 29, 2020, at 12:43 p.m. Plaintiff again attempted to put an end to these
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`unwanted and harassing messages sent in the early hours of the morning and again replied
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`“STOP.”
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`29. Below is a copy of the text message that Defendant sent to Plaintiff on Wednesday,
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`July 29, 2020:
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`30. Below is a copy of Plaintiff’s “STOP” message sent to AT&T on Wednesday, July 29,
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`2020, at 12:43 p.m. revoking (for the second time) consent:
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`31. On at least two (2) occasions Plaintiff replied “STOP” to Defendant’s short code
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`148507108.
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`32. “STOP” is universally recognized by mobile message senders as an express revocation
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`of consent to receive text messages.
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`33. Plaintiff did not want to receive these text messages and followed Defendant’s opt-out
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`directions after receiving these unwanted text messages, but Defendant nevertheless continued to
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`send the text messages to Plaintiff.
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`34. Less than 24 hours after Plaintiff revoked his consent (for the second time), Defendant
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`sent another identical text message to Plaintiff at 6:00 a.m. on July 30, 2020.
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`35. Below is a copy of the text message Defendant sent to Plaintiff on Thursday, July 30,
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`2020:
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`36. As demonstrated by the sampling of these text messages provided above, AT&T
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`continued to send Plaintiff text messages despite Plaintiff replying to several text from Defendant
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`with “STOP.”
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`37. Defendant sent these unsolicited text messages to Plaintiff’s cellular telephone using
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`the short code number “148507108.”
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`38. Through the unsolicited messages, Defendant contacted Plaintiff on Plaintiff’s cellular
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`telephone regarding an unsolicited service via an “automatic telephone dialing system” (“ATDS”),
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`as defined by 47 U.S.C. § 227(a)(1) and prohibited by 47 U.S.C. § 227(b)(1)(A).
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`39. Upon information and belief, this ATDS has the capacity to store or produce telephone
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`numbers to be called, using a random or sequential number generator.
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`40. Upon information and belief, this ATDS has the capacity to store numbers and to dial
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`numbers without human intervention.
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`41. Upon information and belief, Defendant used a combination of hardware and software
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`systems which have the capacity to generate or store random or sequential numbers or to dial
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`sequentially or randomly in an automated fashion without human intervention.
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`42. The impersonal and generic nature of the text messages, along with the fact that
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`Defendant utilized a short code for the text messages that Defendant sent to Plaintiff further
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`demonstrates that Defendant used an ATDS to send the subject messages.
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`43. The fact that “STOP” messages revoking consent were sent to Defendant’s system
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`without any human seeing or responding to those messages, and that unconsented to blast texts
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`were automatically and continually sent after being told to “STOP,” further demonstrates that
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`Defendant used an ATDS to send the subject text message.
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`44. Defendant utilized short code number “148507108” to send the subject text messages
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`en masse to Plaintiff and Class Members using an autodial function.
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`45. The content of the text messages made to Plaintiff and the Class Members show that
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`they were for informational purposes and thus required Plaintiff’s prior express consent.
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`46. The telephone number Defendant called was assigned to a cellular telephone service
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`for which Plaintiff incurs a charge for incoming calls pursuant to 47 U.S.C. 227(b)(1).
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`47. These text messages constituted calls that were not for emergency purposes as defined
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`by 47 U.S.C. § 227(b)(1)(A)(i).
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`48. Plaintiff did not provide Defendants or their agents prior consent to receive these
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`messages to his cellular telephone; therefore, the unsolicited messages violated 47 U.S.C. §
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`227(b)(1).
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`49. Defendant is and was aware that it was transmitting unsolicited text messages to
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`Plaintiff and other consumers without their prior consent.
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`50. Defendant is and was aware that it was placing unsolicited robocalls to Plaintiff and
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`other consumers without their prior consent.
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`51. Plaintiff was damaged by Defendants’ messages. In addition to using Plaintiff’s
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`residential cellular data, phone storage, and battery life, his privacy was wrongfully invaded, his
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`seclusion was intruded upon, and Plaintiff has become understandably aggravated with having to
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`deal with the frustration of repeated, unwanted messages at 6:00 a.m. every single day (including
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`weekends), forcing him to divert attention away sleep and causing disruption to his work and other
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`activities. Not only did the receipt of the text messages distract Plaintiff away from his personal
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`activity, Plaintiff was forced to spend time investigating the calls. See Muransky v. Godiva
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`Chocolatier, Inc., 905 F.3d 1200, 1211 (11th Cir. 2018). (“[T]ime wasting is an injury in fact”….
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`“[A] small injury… is enough for standing purposes”).
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`CLASS ACTION ALLEGATIONS
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`52. Plaintiff brings this class action under Rule 23(a),(b)(2), and(b)(3) of the Federal Rules
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`of Civil Procedure on behalf of herself and of a similarly situated “Class” or “Class Members”
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`defined as:
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`Revocation Class: All persons within the United States who, between July 23,
`2020 and the date of class certification, sent a “STOP”3 message to AT&T
`unsubscribing from receiving text messages from AT&T and who were
`subsequently sent informational text messages from Defendant to their cellular
`telephone contrary to their instructions and did not re-subscribe to receive text
`messages.
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`53. Excluded from the Class are Defendant, and any subsidiary or affiliate of Defendant,
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`and the directors, officers and employees of Defendant or their subsidiaries or affiliates, and
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`members of the federal judiciary.
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`Or other words evidencing express revocation of consent, including but not limited to “cancel” or
`3.
`“unsubscribe.”
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`54. This action has been brought and may properly be maintained as a class action against
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`Defendant pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-
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`defined community of interest in the litigation and the proposed Class is easily ascertainable.
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`Plaintiff reserves the right to amend the Class definition if discovery and further investigation
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`reveal that any Class should be expanded or otherwise modified.
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`55. Numerosity: At this time, Plaintiff does not know the exact number of Class Members,
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`but among other things, given the nature of the claims and that Defendant’s conduct consisted of
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`standardized SPAM campaign calls placed to cellular telephone numbers, Plaintiff believes, at a
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`minimum, there are greater than forty (40) Class Members. Plaintiff believes that the Class is so
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`numerous that joinder of all members of the Class is impracticable and the disposition of their
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`claims in a class action rather than incremental individual actions will benefit the Parties and the
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`Court by eliminating the possibility of inconsistent or varying adjudications of individual actions.
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`56. Upon information and belief, a more precise Class size and the identities of the
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`individual members thereof are ascertainable through Defendant’s records, including, but not
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`limited to Defendant’s calls and personnel records.
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`57. Members of the Class may additionally or alternatively be notified of the pendency of
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`this action by techniques and forms commonly used in class actions, such as by published notice,
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`e-mail notice, website notice, fax notice, first class mail, or combinations thereof, or by other
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`methods suitable to this class and deemed necessary and/or appropriate by the Court.
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`58. Existence and Predominance of Common Questions of Fact and Law: There is a
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`well-defined community of common questions of fact and law affecting the Plaintiff and members
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`of the Class. Common questions of law and/or fact exist as to all members of the Class and
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`Case 1:20-cv-02354 Document 1 Filed 08/07/20 USDC Colorado Page 12 of 17
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`predominate over the questions affecting individual Class members. These common legal and/or
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`factual questions include, but are not limited to, the following:
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`a. Whether, between July 23, 2020, and the filing of this complaint, Defendant or its
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`agents called (other than a message made for emergency purposes or made with the
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`prior consent of the called party) to a Class member using any automatic dialing to
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`any telephone number assigned to a cellular phone service;
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`b. How Defendant obtained the numbers of Plaintiff and Class members;
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`c. Whether the dialing system used to call is an Automatic Telephone Dialing System;
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`d. Whether Defendant engaged in sending informational content when it sent the text
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`messages which are the subject of this lawsuit;
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`e. Whether the calls made to Plaintiff and Class Members violate the TCPA and its
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`regulations;
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`f. Whether Defendant willfully or knowingly violated the TCPA or the rules
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`prescribed under it;
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`g. Whether Plaintiff and the members of the Class are entitled to statutory damages,
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`treble damages, and attorney fees and costs for Defendant’s acts and conduct;
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`h. Whether Plaintiff and members of the Class are entitled to a permanent injunction
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`enjoining Defendant from continuing to engage in its unlawful conduct; and
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`i. Whether Plaintiff and the Class are entitled to any other relief.
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`59. One or more questions or issues of law and/or fact regarding Defendant’s liability are
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`common to all Class Members and predominate over any individual issues that may exist and may
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`serve as a basis for class certification under Rule 23(c)(4).
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`60. Typicality: Plaintiff’s claims are typical of the claims of the members of the Class. The
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`claims of the Plaintiff and members of the Class are based on the same legal theories and arise
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`from the same course of conduct that violates the TCPA.
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`61. Plaintiff and members of the Class each received at least one SPAM text message,
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`providing informational content, which Defendant placed or caused to be placed to Plaintiff and
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`the members of the Class.
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`62. Adequacy of Representation: Plaintiff is an adequate representative of the Class
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`because Plaintiff’s interests do not conflict with the interests of the members of the Class. Plaintiff
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`will fairly, adequately and vigorously represent and protect the interests of the members of the
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`Class and has no interests antagonistic to the members of the Class. Plaintiff has retained counsel
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`competent and experienced in litigation in the federal courts, TCPA litigation, and class action
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`litigation.
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`63. Superiority: A class action is superior to other available means for the fair and efficient
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`adjudication of the claims of the Class. While the aggregate damages which may be awarded to
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`the members of the Class are likely to be substantial, the damages suffered by individual members
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`of the Class are relatively small. As a result, the expense and burden of individual litigation makes
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`it economically infeasible and procedurally impracticable for each member of the Class to
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`individually seek redress for the wrongs done to them. Plaintiff does not know of any other
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`litigation concerning this controversy already commenced against Defendant by any member of
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`the Class. The likelihood of the individual members of the Class prosecuting separate claims is
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`remote. Individualized litigation would also present the potential for varying, inconsistent or
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`contradictory judgments, and would increase the delay and expense to all parties and the court
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`system resulting from multiple trials of the same factual issues. In contrast, the conduct of this
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`matter as a class action presents fewer management difficulties, conserves the resources of the
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`parties and the court system, and would protect the rights of each member of the Class. Plaintiff
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`knows of no difficulty to be encountered in the management of this action that would preclude its
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`maintenance as a class action.
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`64. Class-Wide Injunctive Relief and Rule 23(b)(2): Moreover, as an alternative to or in
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`addition to certification of the Class under Rule 23(b)(3), class certification is warranted under
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`Rule 23(b)(2) because Defendant has acted on grounds generally applicable to Plaintiff and
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`members of Class, thereby making appropriate final injunctive relief with respect to Plaintiff and
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`Class Members as a whole. Plaintiff seeks injunctive relief on behalf of Class Members on grounds
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`generally applicable to the entire Class in order to enjoin and prevent Defendant’s ongoing
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`violations of the TCPA, and to order Defendant to provide notice to them of their rights under the
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`TCPA to statutory damages and to be free from unwanted calls.
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`COUNT I
`VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT
`47 U.S.C. § 227(b)
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`65. Plaintiff incorporates by reference all of the allegations contained in all of the above
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`paragraphs 1 through 64 of this Complaint as though fully stated herein.
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`66.
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`It is a violation of the TCPA to make “any call (other than a call made for emergency
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`purposes or made with the prior express consent of the called party) using any automatic telephone
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`dialing system. . .to any telephone number assigned to a . . . cellular telephone service . . .” 47
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`U.S.C. § 227(b)(1)(A)(iii).
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`67. Automatic telephone dialing system refers to “equipment which has the capacity---(A)
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`to store or produce telephone numbers to be called, using a random or sequential number generator;
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`and (B) to dial such numbers.” 47 U.S.C. § 227(a)(1).
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`68. Defendant—or third parties directed by Defendant—used equipment having the
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`capacity to randomly or sequentially generate telephone numbers and to dial such numbers without
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`human intervention to make non-emergency telephone calls to the cellular telephones of Plaintiff
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`and the other members of the Class defined above.
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`69. These calls were made without regard to whether or not Defendant had first obtained
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`permission from the called party to make such calls. In fact, Defendant did not have prior consent
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`to call the cellular phones of Plaintiff and the other members of the putative Class when its calls
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`were made.
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`70. Defendant has, therefore, violated Section 227(b)(1)(A)(iii) of the TCPA by using an
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`automatic telephone dialing system to make non-emergency telephone calls to the cellular phones
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`of Plaintiff and the other members of the putative Class without their prior consent.
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`71. The foregoing acts and omissions of Defendant constitute numerous and multiple
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`violations of the TCPA, including but not limited to each and every one of the above-cited
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`provisions of 47 U.S.C. § 227.
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`72. As a result of Defendant’s negligent violations of 47 U.S.C. § 227, Plaintiff and the
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`Class are entitled to an award of $500.00 in statutory damages, for each and every violation,
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`pursuant to 47 U.S.C. § 227(b)(3)(B).
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`73. At all relevant times, Defendant knew or should have known that its conduct as alleged
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`herein violated the TCPA.
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`74. Defendant knew that it did not have prior consent to make these calls and knew or
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`should have known that its conduct violated the TCPA.
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`75. Because Defendant knew or should have known that Plaintiff and Class Members did
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`not give prior consent to receive autodialed calls, the Court should treble the amount of statutory
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`damages available to Plaintiff and members of the Putative Class pursuant to Section 227(b)(3)(C).
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`76. As a result of Defendant knowing and/or willful violations of 47 U.S.C. § 227(b),
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`Plaintiff and the Class are entitled to an award of $1,500.00 in statutory damages, for each and
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`every violation, pursuant to 47 U.S.C. § 227(b)(3)(C).
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`77. Plaintiff and the Class are also entitled to and seek injunctive relief prohibiting such
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`conduct in the future.
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`WHEREFORE, Plaintiff respectfully requests the Court grant Plaintiff and the Class
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`members relief against Defendant, AT&T MOBILITY SERVICES, LLC, as set forth in the Prayer
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`for Relief below.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff requests that the Court enter judgment in her favor and in favor
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`of the class, against Defendant for:
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`a. An order certifying this case as a class action, certifying Plaintiff as representative
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`of the Class, and designating Plaintiff’s counsel as Class counsel;
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`b. Statutory damages of $500 per call in violation of the TCPA;
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`c. Willful damages at $1,500 per call in violation of the TCPA;
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`d. A declaration that Defendants’ practices described herein violate the Telephone
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`Consumer Protection Act, 47 U.S.C. § 227(b)(1)(A)(iii);
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`e. An injunction prohibiting Defendants from using an automatic telephone dialing
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`system to call numbers assigned to cellular telephones without the prior express
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`written consent of the called party;
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`Case 1:20-cv-02354 Document 1 Filed 08/07/20 USDC Colorado Page 17 of 17
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`f. Reasonable attorney’s fees and costs; and
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`g. Such further and other relief as this Court deems reasonable and just.
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`DEMAND FOR JURY TRIAL
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`Plaintiff, DAVID ULERY, demands a trial by jury on all appropriate claims.
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`Dated this 7th day of August 2020. Respectfully Submitted,
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`EGGNATZ | PASCUCCI
`7450 Griffin Road, Suite 230
`Davie, Florida 33314
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`Tel: (954) 889-3359
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`Counsel for Plaintiff
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`By: /s/ Joshua H. Eggnatz
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`JOSHUA H. EGGNATZ, ESQUIRE
`Florida Bar No.
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`MICHAEL PASCUCCI, ESQUIRE
`Florida Bar No.
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`jeggnatz@justiceearned.com
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`mpascucci@justiceearned.com
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`JORDAN RICHARDS, PLLC
`805 East Broward Blvd. Suite 301
`Fort Lauderdale, Florida 33301
`Tel: (954) 871-0050
`Counsel for Plaintiff
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`By: /s/ Jordan Richards
`JORDAN RICHARDS, ESQUIRE
`Florida Bar No. 108372
`Jordan@jordanrichardspllc.com
`Melissa@jordanrichardspllc.com
`Jake@jordanrichardspllc.com
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that the foregoing document was filed via CM/ECF on August 7,
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`2020.
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`By: /s/ Jordan Richards
`JORDAN RICHARDS, ESQUIRE
`Florida Bar No. 108372
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`SERVICE LIST:
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`17
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