Original Collective Action Complaint Page 1

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

JOSEPH BAMBERG, 

Individually and on behalf of all others 

similarly situated, 

Plaintiff, 

v. 

THE RESULTS COMPANIES, LLC 

Defendant. 

 Civil Action No. _______________ 

 JURY TRIAL DEMANDED 

COLLECTIVE ACTION PURSUANT 

TO 29 U.S.C. § 216(B) 

ORIGINAL COLLECTIVE ACTION COMPLAINT 

Plaintiff Joseph Bamberg (“Plaintiff” or “Bamberg”), brings this action individually and on 

behalf of all current and former hourly call-center employees (hereinafter “Plaintiff and the Putative

Class Members” or “Plaintiff and the FLSA Collective Members”) who worked for The Results 

Companies, LLC (“The Results Companies” or “Defendant”), anywhere in the United States, at any 

time from July 13, 2017 through the final disposition of this matter, to recover compensation, 

liquidated damages, and attorneys’ fees and costs pursuant to the provisions of Sections 206, 207 

and 216(b) of the Fair Labor Standards Act of 1938, as amended 29 U.S.C. §§ 201, et seq, and the 

Virginia Wage Payment Act (“VWPA”), VA. CODE ANN. § 40.1–29. 

Both Plaintiff’s FLSA claim and Virginia state law claim are asserted as collective actions 

under Section 16(b) of the FLSA, 29 U.S.C. § 216(b). The following allegations are based on 

personal knowledge as to Plaintiff’s own conduct and are made on information and belief as to the 

acts of others. 

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I. 

OVERVIEW 

1. This is a collective action to recover overtime wages and liquidated damages brought 

pursuant to the Fair Labor Standards Act (“FLSA”), 29 U.S.C. §§ 201–19 and a collective action 

pursuant to the state laws of Virginia pursuant to VA. CODE ANN. § 40.1-29 (which incorporates the 

collective action mechanism in 29 U.S.C. § 216(b)) to recover unpaid wages, overtime wages, and 

other applicable penalties. 

2. Plaintiff and the Putative Class Members are those similarly situated persons who 

have worked for The Results Companies in call centers, anywhere in the United States, at any time 

from July 13, 2017 through the final disposition of this matter, and have not been paid for all hours 

worked nor the correct amount of overtime in violation of federal and state law. 

3. Specifically, The Results Companies enforced a uniform company-wide policy 

wherein it improperly required its hourly call-center employees—Plaintiff and the Putative Class 

Members—to perform work “off-the-clock” and without pay. 

4. The Results Companies’ illegal company-wide policy has caused Plaintiff and the 

Putative Class Members to have hours worked that were not compensated and further created a 

miscalculation of their regular rate(s) of pay for purposes of calculating their overtime compensation

each workweek. 

5. Although Plaintiff and the Putative Class Members have routinely worked in excess 

of forty (40) hours per workweek, Plaintiff and the Putative Class Members have not been paid 

overtime of at least one and one-half their regular rates for all hours worked in excess of forty (40)

hours per workweek. 

6. The Results Companies knowingly and deliberately failed to compensate Plaintiff 

and the Putative Class Members for all hours worked each workweek and the proper amount of 

overtime on a routine and regular basis during the relevant time period. 

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7. Plaintiff and the Putative Class Members did not (and currently do not) perform 

work that meets the definition of exempt work under the FLSA or relevant state law. 

8. Plaintiff and the Putative Class Members seeks to recover all unpaid overtime, 

liquidated damages, and other damages owed under the FLSA as a collective action pursuant to 29 

U.S.C. § 216(b), and to recover all unpaid overtime and other damages owed under Virginia state law 

as a collective action pursuant to 29 U.S.C. § 216(b). 

9. Plaintiff prays that all similarly situated workers (Putative Class Members) be notified 

of the pendency of this action to apprise them of their rights and provide them an opportunity to 

opt-in to this lawsuit. 

II. 

THE PARTIES 

10. Plaintiff Joseph Bamberg (“Bamberg”) was employed by The Results Companies 

during the relevant time period. Plaintiff Bamberg did not receive compensation for all hours 

worked or the correct amount of overtime compensation for all hours worked in excess of forty (40) 

hours per workweek.1

11. The FLSA Collective Members are those current and former hourly call-center 

employees who were employed by The Results Companies, anywhere in the United States, at any 

time from July 13, 2017 through the final disposition of this matter, and have been subjected to the 

same illegal pay system under which Plaintiff Bamberg worked and was paid. 

12. The Virginia Class Members are those current and former hourly call-center 

employees who were employed by The Results Companies, anywhere in the state of Virginia, at any 

time from July 13, 2017 through the final disposition of this matter, and have been subjected to the 

same illegal pay system under which Plaintiff Bamberg worked and was paid. 

 

1

 The written consent of Joseph Bamberg is hereby attached as Exhibit “A.” 

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13. Defendant The Results Companies, LLC (“The Results Companies”) is a Foreign 

Limited Liability Company, licensed to and doing business in the State of Florida, and can be served 

through its registered agent: Cogency Global Inc., 115 North Calhoun Street, Suite 4,

Tallahassee, Florida 32301. 

III. 

JURISDICTION & VENUE 

14. This Court has federal question jurisdiction over the FLSA claims pursuant to 28 

U.S.C. § 1331 as this is an action arising under 29 U.S.C. §§ 201 et. seq. 

15. This Court has supplemental jurisdiction over the additional Virginia state law claims 

pursuant to 28 U.S.C. § 1367. 

16. This Court has personal jurisdiction over The Results Companies because the cause 

of action arose within this District as a result of The Results Companies’ conduct within this District 

and Division. 

17. Venue is proper in the Southern District of Florida because this is a judicial district 

where a substantial part of the events or omissions giving rise to the claim occurred. 

18. Specifically, The Results Companies’ corporate headquarters are located in Fort 

Lauderdale, Florida, which is located in this District and Division. 

19. Venue is therefore proper in this Court pursuant to 28 U.S.C. § 1391. 

 

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IV. 

ADDITIONAL FACTS 

20. The Results Companies, LLC is a customer engagement and contact center that 

provides customer services, technical support, and sales and marketing support to their business 

clients.2

21. Plaintiff and the Putative Class Members’ job duties consisted of making and 

answering phone calls made by The Results Companies’ business clients’ customers. 

22. Plaintiff Bamberg was employed by The Results Companies as a customer service 

agent in Martinsville, Virginia from approximately May 2017 until November 2019. 

23. Plaintiff and the Putative Class Members are non-exempt call-center employees who 

were (and are) paid by the hour. 

24. Plaintiff and the Putative Class Members typically worked approximately forty (40) 

“on-the-clock” hours per week. 

25. In addition to their forty (40) “on-the-clock” hours, Plaintiff and the Putative Class 

Members worked up to five (5) hours “off-the-clock” per week and have not been compensated for 

that time. 

Unpaid Start-Up Time

26. Plaintiff and the Putative Class Members have not been compensated for all of the 

hours they worked for The Results Companies as a result of The Results Companies’ corporate 

policy and practice of requiring their hourly call-center employees to clock-in only when ready to 

take their first call. 

27. Specifically, Plaintiff and the Putative Class Members are required to start and log-in 

to their computer, read emails and alerts from The Results Companies, open multiple different 

 

2 https://www.theresultscompanies.com/company/about-us. 

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computer programs, log in to each program, and ensure that each program is running correctly—

all of which can take up to twenty-five minutes each day—before they are allowed to clock in on the 

hard phone or computer software application and then take their first phone call. 

28. If Plaintiff and the Putative Class Members are not ready and on the phone at shift 

start, they can be (and often are) subject to discipline. 

29. If Plaintiff and the Putative Class Members clock in and do not begin accepting calls 

within a minute of clocking in, they are also subject to discipline. 

30. Therefore, the only way to be ready on time, and avoid discipline, is to prepare the 

computer “off-the-clock.” 

31. During this start up time, Plaintiff and the Putative Class Members were not 

compensated although they were expected to have completed this process in advance of their 

official start times. 

32. Since the beginning of the Corona Virus pandemic, The Results Companies now 

requires Hourly Call-Center Employees to complete a health-related questionnaire, which must be 

completed at least one hour to thirty (30) minutes prior to the employee’s shift start time. 

33. Plaintiff and the Putative Class Members cannot clock in prior to their shift start 

time, therefore this health-related quiz must also be performed off-the-clock. 

Unpaid Work During the Meal Period Break 

34. The Results Companies provides Plaintiff and the Putative Class Members with one 

unpaid meal break each day. 

35. However, The Results Companies requires Plaintiff and the Putative Class Members 

to perform “off-the-clock” work during their unpaid meal break. 

36. Plaintiff and the Putative Class are required to stay on the clock and on call until the 

minute their meal break begins, then they must clock out, perform a lengthy shut down process, 

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then log out of the phone system or otherwise go into an aux mode, and then log off of their 

computer prior to leaving their desk for their meal break. 

37. Plaintiff and the Putative Class Members are required to log back into their 

computer, perform a restart process, log back into the phone system, then clock in, and be back on 

the phone before their meal break ends. 

38. The log off process used prior to taking a meal break can take anywhere from one to 

three minutes. 

39. The log in process used after returning from a meal break can take anywhere from 

another one to three minutes. 

40. This lengthy log off and log in procedure had to be performed during Plaintiff and 

the Putative Class Members’ meal break per The Results Companies’ policy. 

Unpaid Re-Boot Times 

41. Further, Plaintiff and the Putative Class Members’ computers crashed multiple times 

each week and required Plaintiff and the Putative Class Members to reset them, which took ten (10) 

minutes or more each time. 

42. Plaintiff and the Putative Class Members were also not compensated for the time 

they worked for The Results Companies rebooting The Results Companies’ computers after they 

crashed. 

Unpaid Rest Breaks Lasting Twenty Minutes or Less 

43. In addition, The Results Companies also enforced a uniform company-wide policy 

wherein they improperly required Plaintiff and the Putative Class Members—to clock out for rest 

breaks lasting twenty minutes or less. 29 C.F.R. § 785.18; see also Sec’y U.S. Dep’t of Labor v. Am. Future 

Sys., Inc., 873 F.3d 420, 425 (3d Cir. 2017). 

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44. The Results Companies permitted Plaintiff and the Putative Class Members to take 

two fifteen-minute breaks each day but required them to clock out for any and all breaks taken 

outside the two fifteen-minute breaks. 

45. As a result of The Results Companies’ corporate policy and practice of requiring 

Plaintiff and the Putative Class Members to perform their computer start up tasks before the 

beginning of their shifts, perform log-in log out processes during their unpaid meal breaks, and 

requiring Plaintiff and the Putative Class Members to clock out for short breaks, Plaintiff and the 

Putative Class Members were not compensated for all hours worked, including all worked in excess 

of forty (40) in a workweek at the rates required by the FLSA. 

46. The Results Companies has employed other individuals who perform(ed) the same 

or similar job duties under the same pay provisions as Plaintiff Bamberg. 

47. The Results Companies is aware of its obligation to pay overtime for all hours 

worked and the proper amount of overtime for all hours worked in excess of forty (40) each week, 

but has failed to do so. 

48. Because The Results Companies did not pay Plaintiff and the Putative Class 

Members for all hours worked and time and a half for all hours worked in excess of forty (40) in a 

workweek, The Results Companies’ pay policies and practices violate the FLSA. 

49. Because The Results Companies did not pay Plaintiff and the Putative Class 

Members for all hours worked on behalf of The Results Companies, The Results Companies’ pay 

policies and practices also violate Virginia state law. 

 

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V. 

CAUSES OF ACTION 

COUNT ONE 

(Collective Action Alleging Violations of the FLSA for Overtime Compensation) 

A. FLSA COVERAGE 

50. Plaintiff Bamberg incorporates by reference paragraphs and allegations 1-49 set forth 

above as though fully and completely set forth herein. 

51. The FLSA Collective is defined as: 

ALL HOURLY CALL-CENTER EMPLOYEES WHO WERE EMPLOYED 

BY THE RESULTS COMPANIES, LLC, ANYWHERE IN THE UNITED 

STATES, AT ANY TIME FROM JULY 13, 2017 THROUGH THE FINAL 

DISPOSITION OF THIS MATTER. (“FLSA Collective” or “FLSA 

Collective Members”) 

52. At all times hereinafter mentioned, The Results Companies has been an employer 

within the meaning of Section 3(d) of the FLSA, 29 U.S.C. § 203(d). 

53. At all times hereinafter mentioned, The Results Companies has been an enterprise 

within the meaning of Section 3(r) of the FLSA, 29 U.S.C. § 203(r). 

54. At all times hereinafter mentioned, The Results Companies has been an enterprise 

engaged in commerce or in the production of goods for commerce within the meaning of Section 

3(s)(1) of the FLSA, 29 U.S.C. § 203(s)(1), in that said enterprise has had employees engaged in 

commerce or in the production of goods for commerce, or employees handling, selling, or otherwise 

working on goods or materials that have been moved in or produced for commerce by any person, 

or in any closely related process or occupation directly essential to the production thereof, and in 

that that enterprise has had, and has, an annual gross volume of sales made or business done of not 

less than $500,000.00 (exclusive of excise taxes at the retail level which are separately stated). 

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55. During the respective periods of Plaintiff and the FLSA Collective Members’ 

employment by The Results Companies, these individuals have provided services for The Results 

Companies that involved interstate commerce for purposes of the FLSA. 

56. In performing the operations hereinabove described, Plaintiff and the FLSA 

Collective Members have been engaged in commerce or in the production of goods for commerce 

within the meaning of §§ 203(b), 203(i), 203(j), 206(a), and 207(a) of the FLSA. 29 U.S.C. §§ 203(b), 

203(i), 203(j), 206(a), 207(a). 

57. Specifically, Plaintiff and the FLSA Collective Members are non-exempt hourly callcenter employees of The Results Companies who assisted The Results Companies by calling and 

receiving calls from The Results Companies’ business clients’ customers throughout the United 

States. 29 U.S.C. § 203(j). 

58. At all times hereinafter mentioned, Plaintiff and the FLSA Collective Members have 

been individual employees who were engaged in commerce or in the production of goods for 

commerce as required by 29 U.S.C. §§ 206–07. 

59. The proposed class of similarly situated employees, i.e. putative class members, 

sought to be certified pursuant to 29 U.S.C. § 216(b), is defined in Paragraph 51. 

60. The precise size and identity of the proposed class should be ascertainable from the 

business records, tax records, and/or employee and personnel records of The Results Companies.

B. FAILURE TO PAY WAGES AND OVERTIME UNDER THE FLSA 

61. The Results Companies has violated provisions of Sections 6, 7 and 15 of the FLSA, 

29 U.S.C. §§ 206–7, and 215(a)(2) by employing individuals in an enterprise engaged in commerce or 

in the production of goods for commerce within the meaning of the FLSA for workweeks longer 

than forty (40) hours without compensating such non-exempt employees for all of the hours they 

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worked in excess of forty (40) hours per week at rates at least one and one-half times the regular 

rates for which they were employed. 

62. Moreover, The Results Companies knowingly, willfully, and with reckless disregard 

carried out its illegal pattern of failing to pay Plaintiff and other similarly situated employees the

proper amount of overtime compensation for all hours worked. 29 U.S.C. § 255(a). 

63. The Results Companies is a sophisticated party and employer, and therefore knew 

(or should have known) its pay policies were in violation of the FLSA. 

64. Plaintiff and the FLSA Collective Members, on the other hand, are (and were) 

unsophisticated employees who trusted The Results Companies to pay them according to the law. 

65. The decisions and practices by The Results Companies to not pay for all hours 

worked and the proper amount of overtime for all hours worked was neither reasonable nor in good 

faith. 

66. Accordingly, Plaintiff and the FLSA Collective Members are entitled to be paid 

overtime wages for all hours worked in excess of forty (40) hours per workweek pursuant to the 

FLSA in an amount equal to one-and-a-half times their regular rate of pay, plus liquidated damages, 

attorneys’ fees and costs. 

C. COLLECTIVE ACTION ALLEGATIONS 

67. Pursuant to 29 U.S.C. § 216(b), this is a collective action filed on behalf of all of The 

Results Companies’ employees who have been similarly situated to Plaintiff with regard to the work 

they performed and the manner in which they have not been paid. 

68. Other similarly situated employees of The Results Companies have been victimized 

by The Results Companies’ patterns, practices, and policies, which are in willful violation of the 

FLSA. 

69. The FLSA Collective Members are defined in Paragraph 51. 

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70. The Results Companies’ failure to pay Plaintiff and the FLSA Collective Members 

for all hours worked and overtime compensation at the rates required by the FLSA, results from 

generally applicable policies and practices of The Results Companies, and does not depend on the 

personal circumstances of Plaintiff or the FLSA Collective Members. 

71. Thus, Plaintiff’s experiences are typical of the experiences of the FLSA Collective 

Members. 

72. The specific job titles or precise job requirements of the various FLSA Collective 

Members do not prevent collective treatment. 

73. All of the FLSA Collective Members—regardless of their specific job titles, precise 

job requirements, rates of pay, or job locations—are entitled to be paid for all hours worked and at 

the proper overtime rate for all hours worked in excess of forty (40) hours per workweek. 

74. Although the issues of damages may be individual in character, there is no detraction 

from the common nucleus of liability facts. 

75. Absent a collective action, many members of the proposed FLSA collective likely 

will not obtain redress of their injuries and The Results Companies will retain the proceeds of its 

rampant violations. 

76. Moreover, individual litigation would be unduly burdensome to the judicial system. 

Concentrating the litigation in one forum will promote judicial economy and parity among the 

claims of the individual members of the classes and provide for judicial consistency. 

77. Accordingly, the FLSA collective of similarly situated plaintiffs should be certified as 

defined as in Paragraph 51 and notice should be promptly sent. 

COUNT TWO 

(Collective Action Alleging Violations of the VWPA for Overtime Compensation) 

A. VWPA COVERAGE 

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78. Plaintiff Bamberg incorporates by reference paragraphs and allegations 1-49 set forth 

above as though fully and completely set forth herein. 

79. The VWPA Collective is defined as: 

ALL HOURLY CALL-CENTER EMPLOYEES WHO WERE EMPLOYED 

BY THE RESULTS COMPANIES, LLC, ANYWHERE IN THE STATE

OF VIRGINIA, AT ANY TIME FROM JULY 13, 2017 THROUGH THE 

FINAL DISPOSITION OF THIS MATTER. (“Virginia Collective” or 

“Virginia Collective Members”) 

80. At all times hereinafter mentioned, The Results Companies has been an employer 

within the meaning of the VWPA. VA. CODE ANN. § 40.1–29(a). 

81. At all times hereinafter mentioned, Plaintiff Bamberg and the VWPA Collective 

Members have been employees within the meaning of the VWPA. VA. CODE ANN. § 40.1–29(a). 

82. Plaintiff Bamberg and the VWPA Collective Members were or have been employed 

by The Results Companies since July 13, 2017, and have been covered employees entitled to the 

protections of the VWPA and were not exempt from the protections of the VWPA. 

83. The employer, The Results Companies, is not exempt from paying overtime benefits 

under the VWPA. 

84. The proposed class of similarly situated employees, i.e. putative class members, 

sought to be certified pursuant to 29 U.S.C. § 216(b), is defined in Paragraph 79. 

85. The precise size and identity of the proposed class should be ascertainable from the 

business records, tax records, and/or employee and personnel records of The Results Companies. 

B. FAILURE TO PAY WAGES IN ACCORDANCE WITH THE VWPA 

86. All previous paragraphs are incorporated as though fully set forth herein. 

87. The VWPA requires that The Results Companies pay Plaintiff Bamberg and the 

VWPA Collective Members all earned wages, including earned overtime, at least twice per month, 

for wages earned by Plaintiff and the VWPA Collective Members during that calendar month. 

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88. Plaintiff Bamberg and the VWPA Collective Members were or have been employed 

by The Results Companies since July 13, 2017 and have been covered employees entitled to the 

protections of the VWPA. 

89. The Results Companies is an employer covered by the requirements set forth in the 

VWPA. 

90. Plaintiff Bamberg and the VWPA Collective Members are not exempt from 

receiving overtime benefits under the VWPA. 

91. Plaintiff Bamberg and the VWPA Collective Members worked more than forty (40) 

hours in workweeks during times relevant to this case, however, The Results Companies violated the 

VWPA by failing to pay Plaintiff Bamberg and the VWPA Collective Members the overtime 

premium for all hours worked over 40 per week. 

92. Plaintiff Bamberg and the VWPA Collective Members were not paid all wages, 

including overtime wages at one and one-half times their regular rates within the month in which 

those wages were earned. 

93. The wages of Plaintiff Bamberg and the VWPA Collective Members remain unpaid 

for more than thirty (30) days beyond their regularly scheduled payday. 

94. Plaintiff Bamberg and the VWPA Collective Members have suffered damages and 

continue to suffer damages as a result of The Results Companies’ acts or omissions as described 

herein; though The Results Companies is in possession and control of necessary documents and 

information from which Plaintiff Bamberg would be able to precisely calculate damages 

95. In violating the VWPA, The Results Companies acted willfully and with intent to 

defraud, without a good faith basis, and with reckless disregard of applicable Virginia law. 

96. The proposed class of employees, i.e. putative class members sought to be certified 

pursuant to the VWPA, is defined in Paragraph 79. 

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97. The precise size and identity of the proposed class should be ascertainable from the 

business records, tax records, and/or employee or personnel records of The Results Companies. 

C. VWPA COLLECTIVE ALLEGATIONS

98. Plaintiff Bamberg brings his VWPA claims as a collective action pursuant 29 U.S.C. § 

216(b) on behalf of all similarly situated individuals employed by The Results Companies in Virginia 

since July 13, 2017. 

99. Other similarly situated employees of The Results Companies have been victimized 

by The Results Companies’ patterns, practices, and policies, which were carried out with an intent to 

defraud and were in willful violation, of the VWPA.

100. The VWPA Collective Members are defined in Paragraph 79. 

101. The Results Companies’ failure to pay Plaintiff and the VWPA Collective Members 

for all hours worked and overtime compensation at the rates required by the VWPA, results from 

generally applicable policies and practices of The Results Companies, and does not depend on the 

personal circumstances of Plaintiff or the VWPA Collective Members. 

102. Thus, Plaintiff’s experiences are typical of the experiences of the VWPA Collective 

Members. 

103. The specific job titles or precise job requirements of the various VWPA Collective 

Members do not prevent collective treatment. 

104. All of the VWPA Collective Members—regardless of their specific job titles, precise 

job requirements, rates of pay, or job locations—are entitled to be paid for all hours worked and at 

the proper overtime rate for all hours worked in excess of forty (40) hours per workweek. 

105. Although the issues of damages may be individual in character, there is no detraction 

from the common nucleus of liability facts. 

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106. Absent a collective action, many members of the proposed VWPA collective likely 

will not obtain redress of their injuries and The Results Companies will retain the proceeds of its 

rampant violations. 

107. Moreover, individual litigation would be unduly burdensome to the judicial system. 

Concentrating the litigation in one forum will promote judicial economy and parity among the 

claims of the individual members of the classes and provide for judicial consistency. 

108. Accordingly, the VWPA collective of similarly situated plaintiffs should be certified 

as defined as in Paragraph 79 and notice should be promptly sent. 

VI. 

RELIEF SOUGHT 

109. Plaintiff Bamberg respectfully prays for judgment against The Results Companies as 

follows: 

 a. For an Order certifying the FLSA Collective as defined in Paragraph 51 and 

requiring The Results Companies to provide the names, addresses, e-mail addresses, telephone 

numbers, and social security numbers of all putative FLSA Collective Members; 

 b. For an Order certifying the VWPA Collective as defined in Paragraph 79 and 

requiring The Results Companies to provide the names, addresses, e-mail addresses, telephone 

numbers, and social security numbers of all putative VWPA Collective Members; 

c. For an Order approving the form and content of a notice to be sent to all 

putative FLSA Collective Members advising them of the pendency of this litigation and of their 

rights with respect thereto; 

d. For an Order approving the form and content of a notice to be sent to all 

putative VWPA Collective Members advising them of the pendency of this litigation and of their 

rights with respect thereto; 

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e. For an Order pursuant to Section 16(b) of the FLSA finding The Results 

Companies liable for unpaid back wages due to Plaintiff (and those FLSA Collective Members who 

have joined in the suit), civil penalties, and for liquidated damages equal in amount to the unpaid 

compensation found due to Plaintiff (and those FLSA Collective Members who have joined in the 

suit). 

f. For an Order pursuant to Virginia law awarding Plaintiff Bamberg and the 

VWPA Collective Members unpaid wages, treble damages, and other damages allowed by law; 

g. For an Order awarding the costs and expenses of this action; 

 h. For an Order awarding attorneys’ fees; 

 i. For an Order awarding pre-judgment and post-judgment interest at the 

highest rates allowed by law; 

 j. For an Order awarding Plaintiff Bamberg a service award as permitted by 

law; 

k. For an Order compelling the accounting of the books and records of The 

Results Companies, at The Results Companies’ expense; and 

 l. For an Order granting such other and further relief as may be necessary and 

appropriate. 

 

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Date: July 14, 2020 Respectfully submitted, 

MORGAN & MORGAN, P.A.

By: /s/ C. Ryan Morgan 

C. Ryan Morgan, Esq. 

FBN 0015527 

20 N. Orange Ave., 16th Floor 

P.O. Box 4979 

Orlando, FL 32802-4979 

Telephone: (407) 420-1414 

Facsimile: (407) 245-3401 

Email: rmorgan@forthepeople.com 

 ANDERSON ALEXANDER, PLLC 

By: /s/ Clif Alexander 

Clif Alexander 

(pro hac vice application forthcoming)

 Texas Bar No. 24064805 

 clif@a2xlaw.com 

 Austin W. Anderson 

(pro hac vice application forthcoming)

 Texas Bar No. 24045189 

 austin@a2xlaw.com 

819 N. Upper Broadway 

Corpus Christi, Texas 78401 

Telephone: (361) 452-1279 

Facsimile: (361) 452-1284 

 Attorneys for Plaintiff and the Putative 

Class Members 

 

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