Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 1 of 15
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF PENNSYLVANIA
`
`
`DEAN E. WEISGOLD, P.C., a Pennsylvania
`Professional Corporation, individually and on
`behalf all others similarly situated,
`
`
`
`
`Plaintiff,
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`
`
`ALLIED MEDICAL ASSOCIATES P.C., DR.
`BRYAN H. EHRLICH, and JOHN DOES 1-12
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`CLASS ACTION
`
`
`
`Defendants.
`
`
`
`
`
`v.
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`
`
`CLASS ACTION COMPLAINT
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`Plaintiff, Dean E. Weisgold, P.C. (“Plaintiff”), brings this action on behalf of itself and all
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`
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`others similarly situated, through its attorneys, and except as to those allegations pertaining to
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`Plaintiff or its attorneys, which allegations are based upon personal knowledge, alleges the
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`following upon information and belief against Defendants Allied Medical Associates, P.C.
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`(“Allied Medical”), Dr. Bryan H. Ehrlich (“Ehrlich”), and John Does 1-12, (collectively
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`“Defendants”):
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`PRELIMINARY STATEMENT
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`1.
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`This case challenges Defendants’ practice of faxing unsolicited advertisements to
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`persons and businesses in violation of the Telephone Consumer Protection Act (the “TCPA”).
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`2.
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`Defendants sent advertisements in an attempt to market their physical rehabilitation
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`business.
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 2 of 15
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`3.
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`The federal Telephone Consumer Protection Act, 47 USC § 227, prohibits a person
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`or entity from faxing or having an agent fax advertisements without the recipient’s prior express
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`invitation or permission (“junk faxes” or “unsolicited faxes”).
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`4.
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`The TCPA mandates that when a person or entity sends a fax advertisement it must
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`always include a very specific opt-out notice that is clearly and conspicuously displayed on the
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`first page of the advertisement. See 47 U.S.C. § 227 (b) (2) (D); and 47 C.F.R. § 64.1200 (a) (4)
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`(iii).
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`5.
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`The TCPA provides a private right of action and provides statutory damages of
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`$500 - $1,500 per violation. If the Court finds the advertisements were sent knowingly or willfully,
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`then the Court can treble the damages.
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`6.
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`Unsolicited faxes damage their recipients. A junk fax recipient loses the use of its
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`fax machine, paper, and ink toner. An unsolicited fax wastes the recipient’s valuable time that
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`would have been spent on something else. A junk fax interrupts the recipient’s privacy. Unsolicited
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`faxes tie up the telephone lines, prevent fax machines from receiving authorized faxes, prevent
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`their use for authorized outgoing faxes, cause undue wear and tear on the recipients’ fax machines,
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`and require additional labor to attempt to discern the source and purpose of the unsolicited
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`message.
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`7.
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`On behalf of itself and all others similarly situated, Plaintiff brings this case as a
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`class action asserting claims against Defendants under the TCPA, and the common law of
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`conversion.
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`8.
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`Plaintiff seeks an award of statutory damages for each violation of the TCPA.
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 3 of 15
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`PARTIES, JURISDICTION AND VENUE
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`9.
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`Plaintiff is a Pennsylvania professional corporation with its principal place of
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`business in Philadelphia, Pennsylvania.
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`10.
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`Defendant Allied Medical is a Pennsylvania corporation, with its principal place of
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`business in Drexel Hill, Pennsylvania.
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`11.
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`12.
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`On information and belief, Defendant Ehrlich is a resident of Pennsylvania.
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`Plaintiff included Defendants John Does 1-12, as it is not clear whether any entities
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`or persons other than Allied Medical or Ehrlich actively participated in the transmission of the
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`subject fax advertisement, or benefitted from the transmissions.
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`13.
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`This Court has subject matter jurisdiction under 28 U.S.C. § 1331 and 47 U.S.C. §
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`227.
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`14.
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`Personal jurisdiction exists in Pennsylvania because Defendants have transacted
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`business and committed tortious acts within the State.
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`15.
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`Venue is proper in the Eastern District of Pennsylvania because Defendants
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`committed a statutory tort within this District and a significant portion of the events took place
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`there.
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`FACTS
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`16.
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`On or about December 3, 2020 an unsolicited fax advertisement was sent to
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`Plaintiff. See Subject Fax Advertisement, attached hereto as Exhibit A. The fax advertisement was
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`sent, or caused to be sent, by Defendants.
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`17.
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`The subject faxes advertise the goods, products or services of Defendants. Id.
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`Exhibit A is a one-page fax that attempts to market Defendants’ physical rehabilitation services.
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`Exhibit A contains information about their services for both new and “established clients/patients,”
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`3
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 4 of 15
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`and methods to get in contact with Defendants. Defendants sent or caused this unsolicited fax
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`advertisement to be sent to Plaintiff and a class of similarly situated persons.
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`Plaintiff did not invite or give permission to anyone to send Exhibit A to it.
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`The fax contained within Exhibit A does not contain a clear and conspicuous opt-
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`18.
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`19.
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`out notice.
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`20.
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`On information and belief, Defendants sent the same facsimile to Plaintiff and more
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`than 39 other recipients without first receiving the recipients’ express permission or invitation.
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`This allegation is based, in part, on the fact that Plaintiff never gave permission to anyone to send
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`the subject fax advertisement to it, that Plaintiff never conducted business with Defendants, and
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`that sending advertisements by fax is a very cheap way to reach a wide audience.
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`21.
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`There are no reasonable means for Plaintiff (or any other putative Class member)
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`to avoid receiving illegal faxes. Fax machines are left on and ready to receive the urgent
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`communications their owners desire to receive.
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`CLASS ACTION ALLEGATIONS
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`22.
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`Plaintiff brings this action as a class action on behalf of itself and all others similarly
`
`situated as members of the Class, initially defined as follows:
`
`All persons who were sent one or more telephone facsimile messages on or after
`four years prior to the filing of this action, that advertised the commercial
`availability of property, goods, or services offered by “Allied Medical Associates”
`that did not contain an opt-out notice that complied with federal law.
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`23.
`
`Excluded from the Class are Defendants, any entity in which Defendants have a
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`controlling interest, any officers or directors of Defendants, the legal representatives, heirs,
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`successors, and assigns of Defendants, and any Judge assigned to this action, and his or her family.
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`24.
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`This action is brought and may properly be maintained as a class action pursuant to
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`Fed. R. Civ. P. 23. This action satisfies the numerosity, commonality, typicality, adequacy
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`4
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 5 of 15
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`requirements under Rule 23(a). Additionally, prosecution of Plaintiff’s claims separately from the
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`putative class’s claims would create a risk of inconsistent or varying adjudications under Rule
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`23(b)(1)(A). Furthermore, the questions of law or fact that are common in this action predominate
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`over any individual questions of law or fact making class representation the superior method to
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`adjudicate this controversy under Rule 23(b)(3).
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`25.
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`Numerosity/Impracticality of Joinder: On information and belief, the Class
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`consists of more than thirty-nine people and, thus, is so numerous that joinder of all members is
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`impracticable. The precise number of Class members and their addresses are unknown to Plaintiff,
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`but can be obtained from Defendants’ records or the records of third parties.
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`26.
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`Commonality and Predominance: There is a well-defined community of interest
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`and common questions of law and fact that predominate over any questions affecting only
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`individual members of the Class. These common legal and factual questions, which do not vary
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`from one Class member to another, and which may be determined without reference to the
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`individual circumstances of any Class member, include, but are not limited to the following:
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`a.
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`b.
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`Whether Defendants sent fax advertisements;
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`Whether the fax contained in Exhibit A advertised the commercial
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`availability of property, goods or services;
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`c.
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`The manner and method Defendants used to compile or obtain the lists of
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`fax numbers to which they sent the faxes contained in Exhibit A and other unsolicited fax
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`advertisements;
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`d.
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`Whether Defendants faxed advertisements without first obtaining the
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`recipients’ express permission or invitation;
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`e.
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`Whether Defendants’ opt-out notice violated the TCPA;
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`5
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 6 of 15
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`f.
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`Whether each Defendant is, respectively, directly or vicariously liable for
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`violating the TCPA;
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`g.
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`Whether Plaintiff and the other Class members are entitled to statutory
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`damages;
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`h.
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`Whether Defendants should be enjoined from faxing advertisements in the
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`future;
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`i.
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`j.
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`Whether the Court should award trebled damages; and
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`Whether Defendants’ conduct as alleged herein constituted conversion.
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`27.
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`Typicality of claims: Plaintiff’s claims are typical of the claims of the Class
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`because Plaintiff and all Class members were injured by the same wrongful practices. Plaintiff and
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`the members of the Class are all individuals who received unsolicited fax advertisements from
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`Defendants that also did not contain an opt-out notice pursuant to the TCPA. Under the facts of
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`this case, because the focus is upon Defendants’ conduct, if Plaintiff prevails on its claims, then
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`the putative Class members must necessarily prevail as well.
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`28.
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`Adequacy of Representation: Plaintiff is an adequate representative of the Class
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`because its interests do not conflict with the interest of the members of the Class it seeks to
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`represent. Plaintiff has retained counsel competent and experienced in complex class action
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`litigation and Plaintiff intends to vigorously prosecute this action. The interest of members of the
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`Class will be fairly and adequately protected by Plaintiff and its counsel.
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`29.
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`Prosecution of Separate Claims Would Yield Inconsistent Results: Even
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`though the questions of fact and law in this action are predominately common to Plaintiff and the
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`putative Class members, separate adjudication of each Class member’s claims would yield
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`inconsistent and varying adjudications. Such inconsistent rulings would create incompatible
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`6
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 7 of 15
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`standards for Defendants to operate under if/when Class members bring additional lawsuits
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`concerning the same unsolicited fax advertisements of if Defendants choose to advertise by fax
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`again in the future.
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`30.
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`Class Action is the Superior Method to Adjudicate the Common Questions of
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`Law and Fact that Predominate: A class action is superior to other available methods for the
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`fair and efficient adjudication of this lawsuit, because individual litigation of the claims of all Class
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`members is economically unfeasible and procedurally impracticable. The likelihood of individual
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`Class members prosecuting separate claims is remote, and even if every Class member could afford
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`individual litigation, the court system would be unduly burdened by individual litigation of such
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`cases. Plaintiff knows of no difficulty to be encountered in the management of this action that
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`would preclude its maintenance as a class action. Relief concerning Plaintiff’s rights under the
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`laws herein alleged and with respect to the Class would be proper. Plaintiff envisions no difficulty
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`in the management of this action as a class action.
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`COUNT I
`TELEPHONE CONSUMER PROTECTION ACT, 47 U.S.C. § 227
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`Plaintiff incorporates the preceding paragraphs as though fully set forth herein.
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`Plaintiff brings Count I on behalf of itself and a class of similarly situated persons.
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`The TCPA prohibits the “use of any telephone facsimile machine, computer or
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`31.
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`32.
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`33.
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`other device to send, to a telephone facsimile machine, an unsolicited advertisement….” 47 U.S.C.
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`§ 227(b)(1)(C).
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`34.
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`The TCPA defines “unsolicited advertisement,” as “any material advertising the
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`commercial availability or quality of any property, goods, or services which is transmitted to
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`any person without that person’s prior express invitation or permission, in writing or otherwise.”
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`47 U.S.C. § 227(a)(5).
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 8 of 15
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`35.
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`The TCPA provides:
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`Private right of action. A person may, if otherwise
`3.
`permitted by the laws or rules of court of a state, bring in an
`appropriate court of that state:
`
`
`(A) An action based on a violation of this
`subsection or
`the regulations prescribed under
`this
`subsection to enjoin such violation,
`
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`(B) An action to recover for actual monetary loss
`from such a violation, or to receive $500 in damages for each
`such violation, whichever is greater, or
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`(C)
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`Both such actions.
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`36.
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`In relevant part, the TCPA states that “[t]he Commission shall prescribe regulations
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`to implement the requirements of this subsection . . . in implementing the requirements of this
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`subsection, the Commission shall provide that a notice contained in an unsolicited advertisement
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`complies with the requirements under this subparagraph only if . . . (i) the notice is clear and
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`conspicuous . . .” 47. U.S.C. § 227(b)(2)(D)(i).
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`37.
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`Additionally, “a notice contained in an unsolicited advertisement complies with the
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`requirements under this subparagraph only if . . . (ii) the notice states that the recipient may make
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`a request to the sender of the unsolicited advertisement not to send any future unsolicited
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`advertisements to a telephone facsimile machine or machines and that failure to comply, within
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`the shortest reasonable time, as determined by the Commission, with such a request meeting the
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`requirements under subparagraph (E) is unlawful . . .” 47 U.S.C. § 227 (b)(2)(D)(ii). The shortest
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`reasonable time has been determined to be thirty (30) days. 47 C.F.R. § 64.1200(a)(4)(iii)(B).
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`38.
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`The opt-out notice must also include “a domestic contact telephone and facsimile
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`machine number for the recipient to transmit such a request to the sender” as well as a “cost-free
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 9 of 15
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`mechanism for a recipient to transmit a request pursuant to such notice . . .” 47 U.S.C. §
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`227(b)(2)(D)(iv)(I)(II).
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`39. Moreover, “a notice contained in an unsolicited advertisement complies with the
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`requirements under this subparagraph only if . . . (v) the telephone and facsimile machine numbers
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`and the cost-free mechanism . . . permit an individual or business to make such a request at any
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`time on any day of the week.” 47 U.S.C. § 227(b)(2)(D)(v).
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`40.
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`The Court, in its discretion, can treble the statutory damages if the violation was
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`knowing. 47 U.S.C. § 227.
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`41.
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`Defendants violated 47 U.S.C. § 227 et seq. by sending advertisements by fax (such
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`as Exhibit A) to Plaintiff and the other Class members without first obtaining their prior express
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`invitation or permission.
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`42.
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`Defendants violated 47 U.S.C. § 227 et seq. by not providing a clear and
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`conspicuous opt-out notice. The subject fax did not include any opt-out notice, as required by 47
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`U.S.C. § 227, thereby leaving Plaintiff and other Class members with no way to stop the deluge of
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`fax advertisements sent by Defendants. Exhibit A. While Defendants did include a phone number
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`at the bottom of the fax, it did not indicate that it would allow recipients to opt-out of receiving
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`any additional faxes, but instead was advertised as a method by which they could purchase
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`Defendants’ services.
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`43.
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`Defendants violated 47 U.S.C. § 227 et seq. by not including in the opt-out notice
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`that Defendants were to comply with any opt-out request within 30 days, or their conduct would
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`be considered unlawful. Furthermore, Defendants violated 47 U.S.C. § 227 et seq. by not including
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`a domestic facsimile number for the recipients to make an opt-out request. Exhibit A.
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`44.
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`Facsimile advertising imposes burdens on unwilling recipients that are distinct from
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`the burden imposed by other types of advertising. The content of the required opt-out notice is
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`designed to ensure that the recipients have the necessary contact information to opt-out of future
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`fax transmissions. If senders do not clearly and conspicuously provide the opt-out content to the
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`recipients, then the senders fail to enable the recipients with the appropriate information to stop
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`the burden imposed by this form of advertisement.
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`45.
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`The TCPA is a strict liability statute and Defendants are liable to Plaintiff and the
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`other Class members even if their actions were negligent.
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`46. Moreover, Defendants are liable to Plaintiff and the other Class members under the
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`TCPA for not including a compliant opt-out notice even if Defendants ultimately prove that they
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`obtained prior express permission to send the advertisements by fax or prove that Defendants had
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`an established business relationship with Plaintiff and the other Class members.
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`47.
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`Each Defendant is liable because, respectively, they sent the faxes, caused the faxes
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`to be sent, participated in the activity giving rise to and/or constituting the violation, the faxes were
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`sent on their behalf, and/or under general principles of vicarious liability applicable under the
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`TCPA, including actual authority, apparent authority and ratification.
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`48.
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`Defendants knew or should have known that Plaintiff and the other Class members
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`had not given express invitation or permission for Defendants or anyone else to fax advertisements
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`about Defendants’ goods, products, or services, that Plaintiff and the other Class members did not
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`have an established business relationship with Defendants, that the fax contained in Exhibit A is
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`an advertisement, and that Exhibit A did not display an opt-out notice as required by the TCPA.
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`49.
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`Defendants’ actions caused damages to Plaintiff and the other Class members.
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`Receiving Defendants’ junk faxes caused the recipients to lose paper and toner consumed in the
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 11 of 15
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`printing of Defendants’ faxes. Moreover, the subject faxes used Plaintiff’s and the Class’s fax
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`machines. The subject faxes cost Plaintiff time, as Plaintiff and its employees wasted their time
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`receiving, reviewing and routing Defendants’ illegal faxes. That time otherwise would have been
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`spent on Plaintiff’s business activities. Defendants’ faxes unlawfully interrupted Plaintiff’s and the
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`other class members’ privacy interests in being left alone. Finally, the injury and property damage
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`sustained by Plaintiff and the other Class members from the sending of Exhibit A occurred outside
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`Defendants’ premises.
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`50.
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`Even if Defendants did not intend to cause damage to Plaintiff and the other Class
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`members, did not intend to violate their privacy, and did not intend to waste the recipients’ valuable
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`time with Defendants’ advertisements, those facts are irrelevant because the TCPA is a strict
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`liability statute.
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`WHEREFORE, Plaintiff, individually and on behalf of all others similarly situated,
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`demands judgment in its favor and against Defendants, jointly and severally as follows:
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`A.
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`That the Court adjudge and decree that the present case may be properly maintained
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`as a class action, appoint Plaintiff as the representative of the class, and appoint Plaintiff’s counsel
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`as counsel for the class;
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`B.
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`That the Court award $500.00-$1,500.00 in damages for each violation of the
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`TCPA;
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`C.
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`That the Court enter an injunction prohibiting Defendants from engaging in the
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`statutory violations at issue in this action; and
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`D.
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`That the Court award costs and such further relief as the Court may deem just and
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`proper.
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`COUNT II
`CONVERSION
`
`51.
`
`52.
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`53.
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`Plaintiff incorporates the preceding paragraphs as though fully set forth herein.
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`Plaintiff brings Count II on behalf of itself and a class of similarly situated persons.
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`By sending Plaintiff and the other Class members unsolicited faxes, Defendants
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`improperly and unlawfully converted their fax machines, toner and paper to its own use.
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`Defendants also converted Plaintiff’s employees’ time to their own use.
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`54.
`
`Immediately prior to the sending of the unsolicited faxes, Plaintiff and the other
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`Class members owned an unqualified and immediate right to possession of their fax machines,
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`paper, toner, and employee time.
`
`55.
`
`By sending the unsolicited faxes, Defendants permanently misappropriated the
`
`Class members’ fax machines, toner, paper, and employee time to their own use. Such
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`misappropriation was wrongful and without authorization.
`
`56.
`
`Defendants knew or should have known that their misappropriation of paper, toner,
`
`and employee time was wrongful and without authorization.
`
`57.
`
`Plaintiff and the other Class members were deprived of the use of the fax machines,
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`paper, toner, and employee time, which could no longer be used for any other purpose. Plaintiff
`
`and each Class member thereby suffered damages as a result of their receipt of unsolicited fax
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`advertisements from Defendants.
`
`58.
`
`Each of Defendants’ unsolicited faxes effectively stole Plaintiff’s employees’ time
`
`because persons employed by Plaintiff were involved in receiving, routing, and reviewing
`
`Defendants’ illegal faxes. Defendants knew or should have known employees’ time is valuable to
`
`Plaintiff.
`
`
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`12
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 13 of 15
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`WHEREFORE, Plaintiff, individually and on behalf of all others similarly situated,
`
`demands judgment in its favor and against Defendants, jointly and severally as follows:
`
`A.
`
`That the Court adjudge and decree that the present case may be properly maintained
`
`as a class action, appoint Plaintiff as the representative of the class, and appoint Plaintiff’ counsel
`
`as counsel for the class;
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`That the Court award appropriate damages;
`
`That the Court award punitive damages;
`
`That the Court award attorney’s fees;
`
`That the Court award costs of suit; and
`
`That the Court award such further relief as it may deem just and proper.
`
`
`Respectfully submitted,
`
`By:
`
`
`
`
`
`DEAN E. WEISGOLD, P.C., a Pennsylvania Professional
`Corporation, individually and on behalf all others similarly
`situated
`
`/s/ Ellen Meriwether
`
`Ellen Meriwether
`CAFFERTY CLOBES MERIWETHER
`
`& SPRENGEL LLP
`205 North Monroe Street
`Media, Pennsylvania 19063
`Phone: (215) 864-2800
`Email: emeriwether@caffertyclobes.com
`
`Nyran Rose Rasche
`Christopher P.T. Tourek
`CAFFERTY CLOBES MERIWETHER
`
`& SPRENGEL LLP
`150 South Wacker Drive, Suite 3000
`Chicago, Illinois 60606
`Phone: (312) 782-4880
`Email: nrasche@caffertyclobes.com
`Email: ctourek@caffertyclobes.com
`
`
`
`13
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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 14 of 15
`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 14 of 15
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`EXHIBIT A
`
`EXHIBIT A
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`

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`Case 2:21-cv-01664-KSM Document 1 Filed 04/08/21 Page 15 of 15
`3‘113‘3'232'1‘1‘Gase Qigl-cflfmfi'émwufiéémfil Filed 04/08/21 Page 15 of 15
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`" ASSOCIATES
`North Phiia.
`Northeast Phila.
`Cherry i-iili, NJ
`
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`demographic information and ciick submit. We will take itfrom there.
`
`You can also send an email to: Agpointments@alliedmedassoc.com inciude your clients’
`name, date of accident, and cell phone number and we wiii do the rest.
`
`Not sure if we have a location convenient to your clients? Go to the web site
`https:ilaiiiedmedassoc.oomi and click on the locations tab. Click on any location for the
`SEPTA bus routes. PLEASE NOTE: We also offer transportation, when needed.
`
`Lastly, if you or your staff are working remotely, fee! free to send any documents which
`require your oiients’ signature to our office in PDF format. We will have your client sign
`the forms. We‘wiii then scan them and emaii them to your office and send the originais
`by mail.
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`éétAstiéie—n CLIENTSIPATIENTS:
`
`For status of your clients’ care contact Nicholas Morrison, Marketing Director and
`Attorney Liaison at: nmorrison@eiiiedmedassoc.com or 800-342-1153 Ext. 4030.
`
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`click the Medical Records tab, enter your clients’ information and ciick submit, or email
`us at: MedicaLRecmds@alliedmedassoo-com ..iT-Eleasebe sure-.to.ioclode yourclientsf._._.___ ___.. _
`name, and detect accident. Records can be sent by UPS, reguiar mail; or by email in
`PDF format. [Please note for HIPAA compliance records sent by email wili be password
`protected}.
`
`Not sure who to contact? Emaii: ln€o@alliedmedassoo.com and your message will be
`forwarded to the right staff member to heip you.
`
`And of course we are aiways availabie by phone at:
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`800-3424 1 53
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