Exhibits for Motion to Lift the Stay No. 21-13797-SMG 

Exhibit 2 

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Second Amended Complaint 1 No. 1:18-cv-10506-ADB 

UNITED STATES DISTRICT COURT FOR THE 

DISTRICT OF MASSACHUSETTS 

SAMUEL KATZ, ALEXANDER 

BRAURMAN, LYNNE RHODES, 

individually, and on their own behalf and 

on behalf of all others similarly situated, 

 Plaintiff, 

 v. 

LIBERTY POWER CORP., LLC, 

LIBERTY POWER HOLDINGS, LLC, 

Delaware limited liability companies, 

 Defendants. 

No. 1:18-cv-10506-ADB

SECOND AMENDED CLASS ACTION 

COMPLAINT AND JURY DEMAND 

 Plaintiffs Samuel Katz (“Plaintiff”), Lynne Rhodes, and Alexander Braurman make this 

complaint against Defendants Liberty Power Corp., LLC and Liberty Power Holdings, LLC 

(collectively “Liberty Power” or “Defendants”). Plaintiffs’ allegations as to their own actions are 

based on personal knowledge. The other allegations are based on their counsel’s investigation, 

and information and belief. 

Introduction 

1. Plaintiffs, individually and as class representatives for all others similarly situated, 

bring this action against Defendants for violations of the Telephone Consumer Protection Act, 47 

U.S.C. § 227 et seq. (“TCPA”) for unsolicited telemarketing calls made by or on behalf of 

Defendants. Plaintiffs, individually, and for class members, seek an injunction and an award of 

statutory damages to the members of the Classes under the TCPA, together with costs and 

reasonable attorneys’ fees. 

Parties 

2. Plaintiff Samuel Katz is a natural person. Mr. Katz was a resident of Bellingham, 

Massachusetts at all times during the events alleged in this Complaint. At all relevant times 

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Plaintiff Katz was the user, subscriber, owner, and possessor of the residential telephone number 

(508) 966-XXXX. 

3. Plaintiff Lynne Rhodes is a natural person. She was a resident of Barnstable 

County, Massachusetts at all times during the events alleged in this Complaint. At all relevant 

times, she was a user, subscriber, owner, and/or possessor of the residential telephone numbers 

508-540-XXXX and 617-962-XXXX. Telephone number 617-962-XXXX is a cellular 

telephone. Rhodes does not use 617-962-XXXX for business purposes, but for personal calls. 

4. Plaintiff Alexander Braurman is a natural person. He was a resident of New 

Jersey at all times during the events alleged in this Complaint. At all relevant times Plaintiff 

Braurman was the user, subscriber, owner, and possessor of the residential telephone number 

908-879-XXXX. 

5. Liberty Power Corp, LLC (“Corp”) is a limited liability company duly organized 

under the laws of the State of Delaware with a principal place of business located at 2100 West 

Cypress Creek Road, Suite 130, Fort Lauderdale, Florida. 

6. Liberty Power Holdings, LLC (“Holdings”) is a limited liability company duly 

organized under the laws of the State of Delaware with a principal place of business located at 

the same address as Corp. 

7. Corp. and Holdings are part of a joint enterprise. Corp. and its subsidiaries 

(including Holdings) operate under common branding and a shared registered trademark for 

“Liberty Power,” in connection with their common retail electric service business. This common 

branding describes “Liberty Power” as Corp.’s “registered trademark,” and describes Corp. as 

“encompassing Liberty Power Holdings LLC” and its other subsidiaries, or Corp. “whose 

subsidiaries are certified and licensed to provide retail electric service” in various states. 

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Likewise, Defendants’ website states “Liberty Power operates through various legal entities to 

provide retail electricity and related services in the states open to retail electric competition. 

Those Liberty Power companies and affiliates (as they may change from time to time) are 

collectively referred to in this website as ‘Liberty Power’, ‘we,’ ‘us’ or ‘our’ . . . “ Liberty 

Power, Terms of Use, at https://www.libertypowercorp.com/terms/ (last updated Jan. 28, 2013). 

Corp. and its subsidiaries (including Holdings) use the same facilities, including the same 

offices, the same form contracts, the same website, the same email server, and the same 

telephone number (1-866-769-3799). Corp. and Holdings have the same managers (David 

Hernandez, Alberto Daire, and Eliezer Hernandez). 

8. Corp. is the ultimate parent of Holdings and the other subsidiaries. Holdings (and 

Corp.’s other subsidiaries) have obtained and maintain licenses to operate as retail electric 

providers in various states. Corp. operates as a retail electric provider through Holdings and the 

other subsidiaries. For instance, Holdings is licensed to operate as a retail electric provider in 

Massachusetts. Holdings’ Massachusetts license allows it to enter into retail electric service 

contracts with consumers and businesses in the state of Massachusetts, and to collect revenue 

from those contracts. 

9. In contrast, Corp.’s officers, employees, and agents are responsible for actually 

operating the joint enterprise’s day-to-day business, and controlling that business. Corp. operates 

the business of registering and enrolling customers in Holdings’ contracts, scheduling and 

providing electricity, maintaining reliable electrical service, and settling payments with utilities 

which provide the electricity that Holdings sells to its customers. 

10. Corp. uses its own financial resources to provide the financial security Holdings 

needs to obtain and maintain its retail electricity service licenses with state regulators. Corp. has 

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posted collateral and paid regulatory fines for Holdings and other subsidiaries. Upon information 

and belief, the same set of personnel—the same officers, employees, and agents—often hold 

themselves out as having a title or position at either Corp. or Holdings (depending on whom the 

personnel are interacting with, including state regulators), and sometime use the exact same 

position. More frequently, however, the personnel provide their title at “Liberty Power,” simply 

leaving the identity of the relevant Defendant ambiguous. 

11. Corp. personnel are responsible for contracting and working with the 

telemarketers which Holdings uses to generate electric service contracts with consumers and 

businesses. Thus, for instance, Defendants’ counterclaim in this proceeding adduces a Telesales 

Channel Agreement with Mezzi Marketing LLC (“Mezzi”). (ECF No. 28-1.) While Holdings is 

Mezzi’s counterparty in the Telesales Channel Agreement, Harris Rosen signed the Telesales 

Channel Agreement as “VP, Law and General Counsel” of “Liberty Power Corp.” Likewise, 

Corp. alleges that it was the “known and intended third-party beneficiary” of Telesales Channel 

Agreement. (ECF No. 28 ¶13.) This arrangement (where Corp. actually executed the contract to 

which Holdings is the counterparty, while Corp. remains an intended beneficiary) reflects how 

Defendants’ business and operations are generally intertwined and interrelated. Defendants’ 

operations are so intertwined that it is often impossible to definitively attribute the acts of their 

personnel to Corp. or Holdings. 

12. Plaintiffs are informed and believe and based thereon allege that all Defendants 

were at all relevant times acting as actual agents, conspirators, ostensible agents, partners and/or 

joint venturers and employees of all other defendants, and that all acts alleged herein occurred 

within the course and scope of said agency, employment, partnership, and joint venture, 

conspiracy or enterprise, and with the express and/or implied permission, knowledge, consent, 

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authorization and ratification of their co-defendants; however, each of these allegations are 

deemed “alternative” theories whenever not doing so would result in a contradiction with the 

other allegations. 

13. Whenever this complaint refers to any act of Defendants or acts of Liberty Power, 

the allegations shall be deemed to mean the act of those defendants named in the particular cause 

of action, and each of them, acting individually, jointly and severally, unless otherwise alleged. 

Jurisdiction and Venue 

14. The Court has federal subject matter jurisdiction under 47 U.S.C. § 227. Cf. Mims 

v. Arrow Fin. Servs., LLC, 565 U.S. 368 (2012). 

15. This Court has personal jurisdiction over Defendants under Mass. Gen. Laws ch. 

223A, § 3, because they do business in the Commonwealth of Massachusetts (including 

obtaining and maintaining licensing with the Commonwealth to provide electricity to customers 

in Massachusetts, and telemarketing retail electricity contracts to Massachusetts residents), and 

because the wrongful acts alleged in this Complaint were committed in and/or caused injury in 

the Commonwealth of Massachusetts. 

16. Venue is also proper before this Court under 28 U.S.C. § 1391(b)(2) because a 

substantial part of the events or omissions giving rise to the claim occurred in this District. 

The Telephone Consumer Protection Act of 1991, 47 U.S.C. § 227 

17. In 1991, Congress enacted the TCPA, in response to a growing number of 

consumer complaints regarding certain telemarketing practices. Congress found that “automated 

and prerecorded calls are a nuisance and an invasion of privacy, regardless of the type of call,” 

and decided that “banning” such calls made without consent was “the only effective means of 

protecting telephone consumers from the nuisance and privacy invasion.” Pub. L. No. 102-243, 

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§§ 2 (10-13) (Dec. 20, 1991), codified at 47 U.S.C. § 227. See also Mims v. Arrow Fin. Services, 

L.L.C., 565 U.S. 368, 132 S. Ct. 740, 744, 181 L. Ed. 2d 881 (2012) (“The Act bans certain 

practices invasive of privacy”).

18. The TCPA makes it unlawful for any person to initiate any telephone call to any 

residential telephone line using an artificial or prerecorded voice to deliver a message without the 

prior express written consent of the called party, unless the call is initiated for emergency 

purposes. 47 U.S.C. § 227(b)(1)(B). 

19. The TCPA also makes it unlawful for any entity to make more than one call in a 

12-month period to any number that is registered with the National Do-Not-Call Registry. See 47 

U.S.C. § 227(c)(5); 47 C.F.R. § 64.1200(c)(2). 

20. The National Do-Not-Call Registry allows residential telephone subscribers to 

register their telephone numbers with the Registry to indicate their desire not to receive 

telephone solicitations at those numbers. See 47 C.F.R. § 64.1200(c)(2). A listing of the Registry 

“must be honored indefinitely or until the registration is cancelled by the consumer or the 

telephone number is removed by the database administrator.” Id. 

21. The Federal Communications Commission (“FCC”) has promulgated regulations 

under the TCPA which also require that sellers and telemarketers maintain an “internal do-notcall list” (“IDNC” list) — i.e., a “list of persons who request not to receive telemarketing calls 

made by or on behalf of that [seller]” — and further prohibits sellers from “initiat[ing] any call 

for telemarketing purposes to a residential telephone subscriber unless such person or entity has 

instituted procedures for maintaining a list of persons who request not to receive telemarketing 

calls by or on behalf of that person or entity[.]” 47 C.F.R. § 64.1200(d). Cf. 47 U.S.C. § 

227(b)(1). 

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22. The FCC’s regulations “generally establish that the party on whose behalf a 

solicitation is made bears ultimate responsibility for any violations.” In the Matter of Rules and 

Regulations Implementing the Tel. Consumer Prot. Act of 1991, 10 FCC Rcd. 12391, 12397, ¶ 13 

(1995). The FCC reiterated this principle in 2013, when it explained that “a seller .... may be 

held vicariously liable under federal common law principles of agency for violations of either 

section 227(b) or section 227(c) that are committed by third-party telemarketers.” In the Matter 

of the Joint Petition Filed by Dish Network, LLC, 28 FCC Rcd. 6574, 6574 (2013). 

Factual Allegations Regarding Liberty Power’s Telemarketing Activities 

23. Liberty Power uses telemarketers to solicit potential residential customers in 

several states to purchase Liberty Power’s products and services through aggressive, outbound 

telemarketing campaigns. These telemarketing campaigns are conducted for the benefit of and on 

behalf of Holdings, in order to enroll new customers for Holdings. Corp. operates, manages, 

monitors, and controls these telemarketing campaigns. 

24. Liberty Power and its agents use pre-recorded and/or artificial voices to make 

telephone calls to consumers en masse to promote and market Liberty Power’s products and 

services. 

25. The prerecorded messages utilized by Liberty and its agents induce consumers, 

including Plaintiff and Class Members, to press 1 to save on their electric bills by making 

specific reference to the consumer’s local electric utility. 

26. Liberty Power and its agents call consumers with whom they have no prior 

relationship and who did not provide consent for Liberty Power or its agents to call them. 

27. Liberty Power and its agents systemically fail to obtain legally effective consent 

before placing calls to potential customers, including Plaintiff and the Class Members (as defined 

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below). 

28. Liberty Power and its agents make repeated and unwanted calls to consumers 

whose telephones service numbers are listed on the National Do Not Call Registry. Consumers 

place their phone numbers on the National Do Not Call Registry for the express purpose of 

avoiding unwanted telemarketing calls like those alleged here. 

29. The outgoing telephone numbers used by Liberty Power and its agents include 

local area-code numbers, but the numbers are misleading and inaccurate—calls to the outgoing 

telephone numbers used by Liberty Power and its agents typically do not connect to any 

telephone line. 

30. Liberty Power had actual knowledge that its vendors used “spoofed numbers” to 

make unsolicited telemarketing calls to consumers on its behalf (that is, replacing the actual 

originating number displayed to recipients caller ID systems—which could be used to reliably 

identify the vendors’ calls—with a falsified ostensible outgoing telephone number). 

Notwithstanding this actual knowledge, when consumers complained to Liberty Power, it denied 

any responsibility for the calls and denied the spoofed numbers were used by any of its 

telemarketing vendors.1

 By causing its vendors to make calls with spoofed numbers, Liberty 

 

1

 According to the FTC, advancements in technologies, such as Voice Over Internet 

Protocol (VoIP) technology have increased the number of illegal telemarketing calls made to 

telephone numbers on the National Do Not Call Registry and allowed telemarketers to evade 

detection by “spoofing” the caller ID information that accompanies their calls: 

 VoIP technology allows callers, including law-breakers, to make higher volume of calls 

inexpensively from anywhere in the world...Technological developments also allow 

illegal telemarketers to easily fake the caller ID information that accompanies their calls, 

which allows them to conceal their identity from consumers and law enforcement. In 

2017, reports of “neighborhood” caller ID spoofing, where the caller displays a caller ID 

number with the same area code and exchange as the called party, have also increased. 

Further, many telemarketers use automated dialing technology to make calls that deliver 

prerecorded messages (commonly referred to as “robocalls”, which allow violators to 

make very high volumes of illegal calls without significant expense. The net effect of 

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Power has violated the TCPA. Cf. 47 U.S.C. § 227(e) (prohibiting “any person within the United 

States, in connection with any telecommunications service or IP-enabled voice service, to cause 

any caller identification service to knowingly transmit misleading or inaccurate caller 

identification information with the intent to defraud, cause harm, or wrongfully obtain anything 

of value”) 

31. Liberty Power and its agents systemically fail to honor Plaintiffs and Class 

Members’ requests to be placed on Liberty Power’s internal Do Not Call List. 

32. By making these robocalls, and ignoring the national Do-Not-Call registry and Do 

Not Call requests, Liberty Power has caused Plaintiffs and Class Members actual injury and 

harm, including the aggravation, nuisance, and invasion of privacy that results from the receipt 

of unsolicited and harassing telephone calls. 

33. Liberty Power controls the manner and method of their agent’s telemarketing 

campaigns. 

34. Liberty Power provides the agents with “lead lists,” lists of prospective consumers 

for the agents to call. Liberty Power requires their agents to call only those telephone numbers 

included in these lead lists. On information and belief, all recipients of Defendants’ calls—

including Katz, Braurman, and Rhodes—are on such lead lists. Defendants upload these lead 

lists to their agents multiple times, over a period of years, and Defendants never remove 

 

these technological developments is that individuals and companies who do not care 

about complying with the Registry or other telemarketing laws are able to make more 

illegal telemarketing calls cheaply and in a manner that makes it difficult for the FTC and 

other law enforcement agencies to find them. 

Federal Trade Commission, Biennial Report to Congress, Under the Do Not Call Registry Fee 

Extension Act of 2007: The Operation of the National Do Not Call Registry During Fiscal Year 

2016 and Fiscal Year 2017, December 2017, at 3. available at 

https://www.ftc.gov/reports/biennial-report-congress-under-do-not-call-registry-fee-extensionact-2007-operation (last visited July 16, 2018). 

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prospective customers from these lists. For instance, Defendants uploaded a list with Plaintiff 

Samuel Katz’s information to Defendants’ agents in 2015 and again in late 2016. When 

recipients of Defendants’ calls request not to receive further calls, Defendants may or may not 

indicate that request on their lead lists, and rely entirely on their agents to honor the request not 

to call that prospective customer. Because Defendants are (at a minimum) lax about enforcing 

policies which prohibit their agents from calling prospective customers who have requested not 

to receive calls from Defendants, or even actively discourage their agents from honoring such 

requests, Defendants’ lead lists do not protect call recipients who have requested not to receive 

further calls—any call recipient on Defendants’ lead lists is exposed to further calls. 

35. Liberty Power instructs the agents on the dates and times to place telemarketing 

calls on behalf of Liberty Power. 

36. Liberty Power provides the agents with telemarketing scripts and requires strict 

adherence to these scripts. 

37. Liberty Power requires the agents to advise prospective customers that they are 

calling on behalf of Liberty Power. 

38. Liberty Power requires the agents to have a certain number of full-time agents 

engaged on Liberty Power’s outbound calling campaigns. 

39. Liberty Power prohibits the agents from hiring subcontractors to telemarket for 

Liberty Power without Liberty Power’s prior written approval. 

40. Liberty Power trains and coaches the agents’ employees on strict adherence to 

Liberty Power’s telemarketing scripts and all other aspects of the telemarketing campaigns. 

41. Liberty Power trains and certifies the employees of its agents soliciting on its 

behalf. This training involves extensive scripting and coaching on script adherence. 

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42. Liberty Power restricts its agents to selling its products and services in 

geographical territories assigned by Liberty Power.

43. Liberty Power requires its agents to provide them with the names of any 

customers who were interested in purchasing electricity from Liberty Power on a daily basis. 

Liberty Power requires its agents to provide, among other information, the account name, utility 

name and account number, kWh rate, service address, billing address, and name of the person 

authorized to sign a contract on the customer’s behalf. 

44. Liberty Power knew or should have known that its agents were violating the 

TCPA. Liberty Power has the right to perform unannounced audit visits of its agents to assure 

compliance with the TCPA. 

45. Liberty Power requires agents to record all telephone solicitations. 

46. Liberty Power has the right to monitor its agents’ telemarketing activities to 

assure adherence to its telemarketing scripts and compliance with Liberty Power’s telemarketing 

rules and policies. Liberty Power had the right to terminate the agents for noncompliance. 

47. Liberty Power conducts evaluations of active employees of the agents who 

perform telemarketing of Liberty Power’s services/products. Liberty Power monitors these 

employees’ calls on a weekly basis, and reserves the right to address violations of its rules and 

policies in real-time with both the agent and their employees. Liberty Power also conducts 

weekly analysis of all of its agents to review quality assurance scores and determine whether the 

agents adhered to Liberty Power’s “best practices”. 

48. Liberty Power requires its agents to promptly notify Liberty Power and 

permanently remove any individual who has engaged in fraudulent or deceptive solicitation, or 

who violated any state or federal law or regulation. Such notification must include the nature of 

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the violation and customers that may be impacted. 

49. Liberty Power also reserved the right to suspend or terminate its relationships 

with its agents for non-compliance with TCPA rules and regulations. 

50. Holdings requires the agents to sign and comply with its telemarketing rules and 

policies, which included scripts controlling the wording that the agents must use in calls made on 

Liberty Power’s behalf. Holdings reserved the right to terminate agents in the event that the 

agents violated its telemarketing policies or deviated from its scripts. 

51. In recent years, Liberty Power’s telemarketing practices have been the subject of 

numerous consumer complaints and increased regulatory scrutiny. Liberty Power knew or should 

have known that its agents were violating the TCPA from the vast number of consumer and state 

regulatory complaints and investigations regarding Liberty Power’s unsolicited telemarketing 

practices. 

52. Liberty Power knew or should have known that the agents systemically violate the 

TCPA because of its strict telemarketing rules and policies, including Liberty Power’s ability to 

audit and perform quality controls, its weekly call audits, and the fact that Liberty Power itself 

supplied the list of numbers that its agents called. 

53. Nonetheless, Liberty Power and the agents made, and continue to make, these 

telemarketing calls to individuals nationwide without their prior written express consent to do so. 

54. Liberty Power also ratified the agents’ conduct by accepting the benefits of the 

calls, including but not limited to enrolling customers generated by these calls into Holdings’ 

contracts, despite being aware that these calls were unsolicited and made in violation of the 

TCPA. 

55. Liberty Power’s agents were, at all relevant times, acting as actual agents, 

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conspirators, ostensible agents, partners and/or joint venturers and employees of Liberty Power, 

and the acts alleged herein occurred within the course and scope of said agency, employment, 

partnership, joint venture, conspiracy or enterprise, and with the express and/or implied 

permission, knowledge, consent, authorization and ratification of Liberty Power. 

56. Each of these allegations are “alternative” theories of liability whenever not doing 

so would result in a contradiction with the other allegations. 

Plaintiff Samuel Katz’s Individual Allegations 

57. On or about August 16, 2003, Mr. Katz’s residential telephone number (508) 966-

XXXX was placed on the National Do-Not-Call Registry. Despite this, Mr. Katz received 

unsolicited calls by or on behalf of Liberty Power promoting Liberty Power’s products and/or 

services on the following dates and times: 

 Call Date and Time Calling Number 

 1 9/8/2016 12:17:11 (508) 202-1270 Framingham MA 

 2 9/8/2016 12:23:44 (508) 202-1270 Framingham MA 

 3 9/8/2016 12:23:46 (508) 202-1270 Framingham MA 

 4 9/8/2016 12:23:51 (508) 202-1270 

 5 9/8/2016 12:29:45 (508) 202-1270 Framingham MA 

 6 9/8/2016 12:35:56 (508) 202-1270 Framingham MA 

 7 9/8/2016 12:36:19 (508) 202-1270 

 8 9/23/2016 15:42:58 (508)-202-1270 

 9 9/27/2016 16:24:47 (508) 202-1270 

 10 10/3/2016 13:27:28 (508) 202-1270 Framingham MA

 11 10/3/2016 13:29:24 Anonymous 

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 12 10/14/2016 16:45:21 (508) 202-1270 Framingham MA 

 13 10/14/2016 16:45:51 (508) 202-1270 

58. There may be additional calls made by or on behalf of Liberty Power and Plaintiff 

reserves the right to identify such additional calls upon receipt of additional evidence which 

demonstrates such calls. 

59. While the caller ID identified above belongs to Liberty Power and/or its agents 

and reflect local Massachusetts area codes, calls to these telephone numbers do not connect to 

any telephone. 

60. Several of these calls used an artificial or prerecorded voice to deliver a message, 

including calls that started with a message that stated “Press 1 to save on your electricity bill,” or

words to that effect. 

61. In one of these calls, Mr. Katz advised Liberty Power’s caller that his telephone 

number was registered with the National Do Not Call Registry, that he did not consent to the 

calls, and asked to be placed on Liberty Power’s Do Not Call list. The caller advised Mr. Katz 

would have to purchase Liberty Power’s services to get on Liberty Power’s Do Not Call list and 

to stop getting calls. The caller in this call stated he was calling from Liberty Power, solicited 

Mr. Katz to enroll in Liberty Power’s electricity program, and provided Liberty Power’s 

telephone number (866-769-3799). 

62. In another of these calls, Mr. Katz asked for a copy of Liberty Power’s Do Not 

Call Policy, and the caller responded he did not have a copy; the caller hung up when Mr. Katz 

then asked if Liberty Power had a Do Not Call list. Again, the caller in this call solicited Mr. 

Katz to enroll in Liberty Power’s electricity program, and provided Liberty Power’s telephone 

number (866-769-3799). 

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63. Plaintiff Katz never gave Liberty Power or its agents legally effective consent to 

make telemarketing calls to him. 

64. None of Liberty Power’s calls to Plaintiff were for emergency purposes or were 

exempted by the FCC’s rules or orders. 

65. Plaintiff Katz complained to Liberty Power about calls from the 508-202-1270. In 

response, by email dated October 19, 2016, Defendants’ Compliance and Quality Assurance 

Team denied responsibility for the calls. Liberty Power denied that the number belonged to any 

of Liberty Power’s third party vendors: 

With your last email you alleged that you received another call again this time from the 

phone number 508-202-1270. We can confirm that phone number does not belong to any 

of our third party vendors and in calling that phone a recorded message responded with 

“this number is currently un-configured”. 

Please note that we had previously received similar allegations from consumers and upon 

conducting a google search with the phone number reflected upon the caller ID, the 

results confirmed “spoof” calls were made to other consumers. 

See KATZ 000147. 

66. Defendants’ subsequent investigation determined that Defendants’ telemarketing 

vendor, Mezzi, made the spoofed (508) 202-1270 calls on behalf of Liberty Power. Defendants 

failed to disclose this to Katz. (However, Plaintiffs further allege Defendants have not made any 

judicial admission about Mezzi’s involvement in these calls, and Plaintiffs cannot make any 

assumptions about the validity of Defendants’ investigation.) 

67. However, there is evidence that Liberty Power believes that Mezzi in fact made 

this calls on its behalf, despite its representations to Katz. The plaintiff in the related case, 

McDermet v. Liberty Power Corp., LLC, No. 18-10043 (also pending before this Court) alleges 

he received calls using the same originating number ((508) 202-1270) a few months after Mr. 

Katz received calls which spoofed the same 1270 number. Cf. Pl.’s Compl., ECF No. 1, ¶50 with

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Complaint by William McDermet, Ex. A to Notice of Removal, McDermet v. Liberty Power 

Corp., LLC, No. 18-10043 (D. Mass. Jan. 8, 2018), ECF No. 1-1, ¶8.) 

68. On June 25, 2018, Liberty Corp. filed a third party complaint against Mezzi in the 

McDermet Case based on the allegation that the calls complained of by Mr. McDermet were 

made by Mezzi pursuant to a telesales agreement. (See Third-Party Complaint by Liberty Power 

Corp., LLC, McDermet v. Liberty Power Corp., LLC, No. 18-10043 (D. Mass. Feb. 13, 2018), 

ECF No. 11, ¶14.). 

69. In support of the third party complaint, Liberty Corp. submitted a declaration 

which stated, in relevant part: “Liberty Power did not make any of the telephone calls that are the 

subject of [McDermet’s] Complaint. All such calls were made by Mezzi . . . ” (Declaration of 

Gary Donaldson, McDermet v. Liberty Power Corp., LLC, No. 18-10043 (D. Mass. June 5, 

2018), ECF No. 25-1, ¶8 (emphasis added).) 

70. Plaintiff Katz and Mr. McDermet are not the only consumers who complain about 

unwanted telemarketing calls by or on behalf of Liberty Power from the spoofed (508) 202-1270 

number. On or about May 11, 2018, Plaintiff’s received a response to Freedom of Information 

Act request from the Federal Trade Commission regarding Liberty Power’s telemarketing. A true 

and correct copy of the response, together with pdf containing portions of the data provided 

together with the FTC’s response, which has been edited and altered for reproduction and 

convenient viewing in a pdf file, is attached to as Exhibit 1 to this Complaint. Other consumers 

complained to the Federal Trade Commission about calls by or on behalf of Liberty Power 

originating from the same number. (See Ex. 1, Rows 108, 188, 198, 202, 213, and 230 (reflecting 

complaints to the FTC about calls regarding Liberty Power from (508) 202-1270 between July 

20, 2016 and July 5, 2017).) 

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71. These calls damaged and harmed Plaintiff. Plaintiff found these repeated 

unsolicited calls to be intrusive and harassing, as they diverted attention away from his daily 

activities. Plaintiff continually screens the calls he receives to avoid telemarketing calls from 

Defendants and others. Plaintiff put his telephone number on the national Do-Not-Call registry 

specifically to avoid telemarketing calls. However, Plaintiff only seeks statutory damages and 

does not seek actual damages. 

72. On or about January 5, 2018, Liberty Power’s in-house counsel informed Mr. 

Katz that Liberty Power had two individual owners, and that every dollar that goes into Liberty 

Power goes into their wallets, so that every dollar that comes out of Liberty Power comes out 

their wallets, or words to that effect. On information and belief, Katz alleges Hernandez and 

Daire are the two individuals referenced by Liberty Power’s in-house counsel. 

Plaintiff Braurman’s Individual Allegations 

73. On or about September 28, 2003, Mr. Alexander Braurman’s residential telephone 

number 908-879-XXXX was placed on the National Do-Not-Call Registry. Despite this, Mr. 

Braurman received unsolicited calls by or on behalf of Liberty Power promoting Liberty Power’s 

products and/or services on the following dates and times: 

 Call Date and Time Calling Number 

 1 10/24/2016 12:13 p.m. (908) 387-4845 

 2 12/23/2016 1:31 p.m. (508) 523-6101 

 3 12/24/2016 12:52 p.m. (508) 523-6101 

74. There may be additional calls made by or on behalf of Liberty Power and Plaintiff 

reserves the right to identify such additional calls upon receipt of additional evidence which 

demonstrates such calls. 

75. All of these calls used an artificial or prerecorded voice to deliver a message, 

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including calls that started with a message that stated “Press 1 to save on your electricity bill,” or

words to that effect. 

76. On October 24, 2016, Braurman received a phone call at his residential number, 

908-879-XXXX. When Braurman answered the call, he heard a pre-recorded message inviting 

him to press “1” to receive a discount on his energy bill. Braurman pressed “1” and was 

transferred to a live telemarketer who attempted to sell to him Liberty’s electricity supplier 

services. During this call, the caller stated he was calling from Liberty Power, solicited Mr. 

Braurman to enroll in Liberty Power’s electricity program, and provided Liberty Power’s 

telephone number (866-769-3799). Plaintiff Braurman stated that he was not interested and 

asked, “Put my name and number on your Do-Not-Call list and never call again.” 

77. Upon information and belief, Braurman received additional calls which were part 

of a telemarketing campaign which was directed at Massachusetts residents, and/or which made 

calls from Massachusetts. The area code 508 corresponds to the greater Boston metropolitan 

area. On December 23, 2016, Braurman received another pre-recorded call stating that he was 

eligible to receive a discount on his energy bill. Following the voice prompt, Braurman pressed 

“1” and got transferred to a live telemarketer, who identified himself as calling from Liberty 

Power and attempted to sell Braurman Liberty Power’s electricity supplier services. Once again, 

Braurman said, “I’m not interested, just take my name and my phone number off your calling list 

and don’t call again” (or words to that effect) and hung up. 

78. Despite Braurman’s clear instructions to cease calling, Liberty called Braurman 

the next day, on December 24, 2016. This time, Braurman recognized Liberty’s Caller ID and 

didn’t answer the call, which got routed to Braurman’s voice mail system. Liberty left a 

prerecorded message “...Phone now to talk to an account representative to receive your discount 

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off your energy bill...” 

79. These December 2016 telephone calls were part of a telemarketing campaign 

directed at Massachusetts residents. In each of the December calls, Liberty Power used the caller 

ID Number (508) 523-6101 and corresponding caller ID name “Cell Phone MA.” Either this call 

originated from Massachusetts, or the caller spoofed the caller ID and caller ID name to suggest 

the call originated from Massachusetts, as part of an effort specifically designed to induce 

Massachusetts residents to pick up what appeared to be local call. However, when Braurman 

tried to call back at that number to demand for Liberty to cease calling him, he heard the 

message that the number he dialed was “disconnected or out of service.” 

80. Plaintiff Braurman is not the only consumer who complains about unwanted 

telemarketing calls by or on behalf of Liberty Power from the spoofed (508) 523-6101 number. 

Other consumers complained to the Federal Trade Commission about calls by or on behalf of 

Liberty Power originating from the same number. (See e.g., Ex. 1, Rows 120, 166, 169, 172, 175, 

and 179, from November 7, 2016 to May 17, 2017.) Indeed, several of these complaints also 

reflect calls to Massachusetts around the same time Plaintiff Braurman received a call. (Id., 

Rows 172 (November 25, 2016); 175 (November 17, 2016); 179 (November 7, 2016).) 

81. Another consumer has complained, that during the same period, in or around 

November 2016, they, too, received repeated unsolicited calls offering a discount on electricity 

rates from this same caller ID number (508) 523-6101 and another number 508-202-1270 – the 

same number used by Liberty and its agents to call Plaintiff Katz and Mr. McDermet in 

Massachusetts. (See https://800notes.com/Phone.aspx/1-508-523-6101 (last visited July 14, 

2018)). 

82. FTC complaints show that Defendants’ Massachusetts-directed marketing reached 

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other customers outside of Massachusetts like Braurman. One former Massachusetts resident 

complained of telemarketing calls from Liberty Power, which stated the recipient “qualif[ied] for 

a rebate because [she was] an Eversource customer,” but the recipient lived in Texas. (See ECF 

No. 34-1, line 235 (calls to former Eversource customer; “Eversource is an electric company I 

used in MA and I have lived in Austin since August 2015.”)) Eversource operates in 

Massachusetts, but does not operate in Texas. 

83. Plaintiff never gave Liberty Power or its agents legally effective consent to make 

telemarketing calls to him. 

84. None of Liberty Power’s calls to Plaintiff were for emergency purposes or were 

exempted by the FCC’s rules or orders. 

85. These calls damaged and harmed Plaintiff. Plaintiff found these repeated 

unsolicited calls to be intrusive and harassing, as they diverted attention away from his daily 

activities. Plaintiff continually screens the calls he receives to avoid telemarketing calls from 

Defendants and others. Plaintiff put his telephone number on the national Do-Not-Call registry 

specifically to avoid telemarketing calls. However, Plaintiff only seeks statutory damages and 

does not seek actual damages. 

Plaintiff Lynne Rhode’s Individual Allegations 

86. On or about February 4, 2008, Plaintiff Lynne Rhodes’ residential telephone 

number 508-540-XXXX was placed on the National Do-Not-Call Registry. 

87. During the calls alleged in this Complaint, Plaintiff Rhodes lived with her father, 

Scoba Rhodes, a senior citizen who was suffering from dementia. In mid-November 2017, Scoba 

Rhodes had a stroke; he passed away on June 23, 2018 at the age of 79. Plaintiff Rhodes will be 

the executrix of Scoba Rhodes’s estate. 

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88. Beginning in November 2017, Plaintiff Rhodes began receiving numerous 

unsolicited calls several times a week by or on behalf of Liberty Power promoting Liberty 

Power’s products and/or services. 

89. During these calls, she told Liberty Power to stop calling and to add the phone 

number to the company Do-Not-Call list. 

90. During at least one call in November 2017, she told the caller that she would not 

do business with telemarketers over the phone. 

91. Notwithstanding the clear direction that the calls stop and that the Rhodes family 

was not interested in the services offered by Liberty Power, on or about December 6, 2017, the 

Rhodes residence received yet another unsolicited call by or on behalf of Liberty Power 

promoting Liberty Power’s products and/or services. Scoba Rhodes answered this call. He 

provided information that was requested by the caller and was signed up for Liberty Power’s 

services over the phone. 

92. Several days later, on or about December 15, 2017, upon discovering that the 

household’s electricity service was switched to Liberty Power without permission, Plaintiff 

Lynne Rhodes cancelled the enrollment with Liberty Power and again demanded that Liberty 

Power add the 508-540-XXXX to its Internal Do Not Call List. On or about December 20, 2017, 

Plaintiff Rhodes obtained power of attorney for Scoba Rhodes. Ms. Rhodes’s complaint that 

Defendants’ telemarketers targeted vulnerable elderly people is not isolated. (See Ex. 1, Rows 8, 

44 (Defendants calling father with dementia), 149, 153 (Defendants calling mother who has 

Alzheimer’s; “I believe they are preying on the elderly”), 284 (Defendants calling elderly parents 

for about a year; “My mother has memory problems and can not remember they are scammers”), 

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364 (“I am an elderly woman and this company is preying on me”).)2

93. On or about January 15, 2018, Liberty Power called yet again trying to get 

Plaintiff Rhodes to enroll in the electricity services. When she demanded that Liberty Power stop 

calling her, she was told that Liberty Power would continue to call until and unless she switched 

the services over to Liberty Power. 

94. On or about January 25, 2018, Plaintiff Lynne Rhodes received another 

unsolicited telemarketing call from Liberty Power promoting Liberty Power’s services. 

95. On or about March 17, 2018, Plaintiff Lynne Rhodes received another unsolicited 

telemarketing call from Liberty Power promoting Liberty Power’s services. 

96. There may be additional calls made by or on behalf of Liberty Power and Plaintiff 

reserves the right to identify such additional calls upon receipt of additional evidence which 

demonstrates such calls. 

97. Neither Plaintiff Lynne Rhodes nor Scoba Rhodes gave Liberty Power or its 

agents legally effective consent to make telemarketing calls to the residential telephone number 

508-540-XXXX. 

98. None of Liberty Power’s calls to Plaintiff were for emergency purposes or were 

 

2

 Likewise, one consumer complained to the BBB with a startlingly similar issue: 

I am filing this complaint on the behalf of my mother, ***** ******* I take care 

of my mom's billing due to the fact that she has dementia. Liberty power had got 

her to switch over to them (she didn’t understand what it was about). I talked to 

her about it and we decided to cancel with them. They canceled it with no 

problem but still keep calling her trying to get her to switch back. I have called 

them, a couple of times, and told them to take her name off their list and to not 

call her anymore. They say they won't call her anymore. Last week they called 

while I was at her house. So I checked her caller ID and found that they call her 

every week day. I just want them to stop calling. Her address is   ** **** *** 

*** ******** ** XXXXX. The phone # that they call is XXX-XXX-XXXX 

See Better Business Bureau, Liberty Power Corp., LLC, at https://www.bbb.org/us/fl/fortlauderdale/profile/electric-companies/liberty-power-corp-llc-0633-23005899/complaints (last 

visited September 18, 2018). 

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exempted by the FCC’s rules or orders. 

99. On or about August 12, 2006, Plaintiff Rhodes’ wireless residential number 617-

962-XXXX was placed on the National Do-Not-Call Registry. 

100. Despite this, on or about June 21, 2018, Plaintiff Rhodes received an unsolicited 

prerecorded message stating that she was eligible to receive a discount on her energy bill, or 

words to that effect. 

101. The call prompted the listener to “Press 1 to save on your electricity bill,” or 

words to that effect. When Ms. Rhodes was transferred to a representative, the representative 

identified himself as calling from Liberty Power. The caller ID that appeared on Ms. Rhodes’ 

cellphone was 339-888-6412.

102. There may be additional calls made by or on behalf of Liberty Power and Plaintiff 

reserves the right to identify such additional calls. 

103. Plaintiff Rhodes did not give Liberty Power or its agents legally effective consent 

to make telemarketing calls to her residential wireless telephone number. 

104. None of Liberty Power’s calls to Plaintiff Rhodes were for emergency purposes or 

were exempted by the FCC’s rules or orders. 

105. These calls damaged and harmed Plaintiff Rhodes. Plaintiff found these repeated 

unsolicited calls to be intrusive and harassing, as they diverted attention away from her daily 

activities. Plaintiff continually screens the calls she receives to avoid telemarketing calls from 

Defendants and others. Plaintiff put her telephone numbers on the national Do-Not-Call registry 

specifically to avoid telemarketing calls. However, Plaintiff only seeks statutory damages and 

does not seek actual damages.

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Class Certification Allegations 

106. Class Definitions: Plaintiffs bring this Complaint against Defendants, pursuant to 

Federal Rule of Civil Procedure 23, on behalf of himself and the following Classes: 

Robocall Class: All persons in the United States who received one 

or more telemarketing calls to their wireless telephone numbers by 

or on behalf of Liberty Power, that were made using an autodialer 

or an artificial or prerecorded voice, from March 16, 2014 through 

the date the Court certifies the class.

Residential Class: All persons in the United States who received 

one or more telemarketing calls to their residential (wireless or 

landline) telephone numbers by or on behalf of Liberty Power, that 

were made using an artificial or prerecorded voice, from March 16, 

2014 through the date the Court certifies the class. 

National Do Not Call Class (“NDNC Class”): All persons in the 

United States whose residential (wireless or landline) telephone 

number was registered with the national Do-Not-Call registry for 

at least thirty days prior to receiving at least two telemarketing 

calls by or on behalf of Liberty Power to such number within any 

12-month period at any time from March 16, 2014 through the date 

the Court certifies the class. 

Internal Do Not Call Class (“IDNC Class”): All persons in the 

United States who received at least two telemarketing calls to their 

residential (wireless or landline) telephone number by or on behalf 

of Liberty Power within any 12-month period at any time from 

March 16, 2014 through the date the Court certifies the class. 

107. Excluded from the classes are any entity in which Defendants have a controlling 

interest or which has a controlling interest in Defendants, and Defendants’ agents, legal 

representatives, predecessors, successors, assigns, and employees. Also excluded from the 

classes are the judge and staff to whom this case is assigned, and any member of the judge’s 

immediate family. Plaintiffs reserve the right to revise the class definitions based on facts learned 

during discovery. 

108. Class Numerosity: The exact number of members of each class is unknown and 

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is not available to Plaintiffs at this time, but such information is readily ascertainable by 

Defendants and their agents’ call records and customer relations management databases. The 

classes are so numerous that joinder of all members is impractical. Plaintiffs allege that there are 

more than 40 members of each Class. 

109. Class Commonality: Plaintiffs and class members’ experiences receiving calls 

by or on behalf of Liberty Power are common. They received multiple, incessant, uninvited calls 

that included a prerecorded message/artificial voice for the purposes of marketing Liberty 

Power’s products or services. The calls were made irrespective to whether Plaintiffs and class 

members were on the National Do Not Call Registry and their requests that the calls cease. 

110. In addition, common questions of fact and law exist as to all members of the 

classes and predominate over the questions affecting only individual members of the classes. 

Identification of the individuals who qualify as a member of the classes will be sufficient to 

establish liability to the class member. The predominant common questions include: 

a. Whether Defendants and/or their agents used an “artificial or prerecorded 

voice” when placing calls, as such terms are defined or understood under 

the TCPA and applicable FCC regulations and orders; 

b. Whether Defendants are vicariously liable for their agents’ calls; 

c. Whether Defendants and/or their agents had legally effective consent to 

place telemarketing calls to Plaintiffs and class members; 

d. Whether Defendants and/or their agents made telephone calls to members 

of the National DNC Class whose telephone numbers were registered with 

the national Do-Not-Call registry; 

e. Whether Defendants and/or their agents instituted procedures and 

minimum standards prescribed by 47 C.F.R. § 64.1200(d) for maintaining 

a list of persons who request not to receive telemarketing calls made by or 

on behalf of that person or entity; 

f. Whether Plaintiffs and class members are entitled to damages, including 

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whether Defendants’ violations were performed willfully or knowingly 

such that Plaintiff and class members are entitled to treble damages; 

g. Whether Plaintiffs and class members are entitled to injunctive relief for 

violations of their privacy and attorney’s fees and costs. 

111. Typicality: Plaintiffs’ claims are typical of the claims of the other members of the 

classes. Plaintiffs are not different in any relevant way from any other member of the classes, and 

the relief he seeks is common to each class. 

112. Adequate Representation: Plaintiffs will fairly and adequately represent and 

protect the interests of the other members of the classes: Plaintiffs’ interests do not conflict with 

the interests of the other class members. Plaintiffs have retained counsel competent and 

experienced in complex class actions, including class actions arising under the Telephone 

Consumer Protection Act and other consumer protection laws, and they intend to prosecute this 

action vigorously. 

113. Predominance and Superiority: The classes alleged in this Complaint are 

appropriate for certification because class proceedings are superior to all other available methods 

for the fair and efficient adjudication of this controversy, since joinder of all members is 

impracticable. The damages suffered by each individual member of the classes will likely be 

relatively small, especially given the burden and expense of individual prosecution of the 

complex litigation necessitated by Defendants’ actions. It would be virtually impossible for class 

members to individually obtain effective relief from Defendants’ misconduct. Even if class 

members themselves could sustain such individual litigation, it would still not be preferable to a 

class action, because individual litigation would increase the delay and expense to all parties due 

to the complex legal and factual controversies presented in this Complaint. By contrast, class 

actions present far fewer management difficulties and provide the benefits of single adjudication, 

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economy of scale, and comprehensive supervision by a single Court. Economies of time, effort, 

and expense will be fostered and uniformity of decisions will be ensured. 

114. Generally Applicable Policies: This class action is also appropriate for 

certification because Defendants have acted or refused to act on grounds generally applicable to 

the classes, thereby making appropriate final injunctive relief or corresponding declaratory relief 

with respect to each class a whole. The policies of the Defendants challenged herein apply and 

affect members of each class uniformly, and Plaintiffs’ challenge of these policies hinges on 

Defendants’ conduct, not on facts or law applicable only to Plaintiffs. 

115. Injunctive Relief is Appropriate: Based on information and belief, Defendants 

continue to engage in the improper practices discussed above. Injunctive relief is necessary and 

appropriate to enjoin Defendants’ conduct and to prevent irreparable harm to Plaintiffs and class 

members for which they have no adequate remedy at law. In particular, Plaintiffs seek the 

following specific relief: 

a) Require Defendants to purchase the subscription to the National DNC registry 

and scrub their “lead lists” against the up-to-date federal DNC list at least every 30 

days; 

b) Require Defendants to retain call records; 

c) Prohibit Defendants from hiring telemarketers which do not comply with state 

regulations to maintain a valid license, registration, and/or bond to call 

customers/prospects residing in that state. 

The presence of Plaintiffs and other class members’ information on Defendants’ lead lists 

exposes them to further calls from Defendants and their agents in the future. 

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FIRST CLAIM FOR RELIEF 

Violation of 47 U.S.C. § 227(b)(1)(a)(iii) Against All Defendants 

by Lynne Rhodes, Individually, and on Behalf of the Robocall Class 

116. Plaintiffs hereby incorporate by reference the allegations contained in all 

preceding paragraphs of this complaint. Plaintiff Lynne Rhodes asserts this claim on behalf of 

herself and the members of the Robocall Class. 

117. The TCPA prohibits certain uses of telecommunication equipment that would 

interfere with telephone service subscribers’ privacy and/or property rights with respect to their 

telephone. In particular, the TCPA provides that: 

It shall be unlawful for any person within the United States, or any person outside 

the United States if the recipient is within the United States to make any call 

(other than a call made for emergency purposes or made with the prior express 

consent of the called party) using any automatic telephone dialing system or an 

artificial or prerecorded voice to any telephone number assigned to a . . . cellular 

telephone service . . . 

47 U.S.C. § 27(b)(1)(A). 

118. The TCPA provides telephone service subscribers a private right of action for 

injunctive relief and statutory damages for violations: 

A person or entity may . . . bring . . . an action based on a violation of [47 U.S.C. 

§ 227(b)] to enjoin such a violation, an action to recovery for actual monetary loss 

from such a violation, or to receive $500 in damages for each such violation, 

whichever is greater, or both . . . If the court finds that the defendant willfully or 

knowingly violated [47 U.S.C. § 227(b),] the court may, in its discretion, increase 

the amount of the award to an amount equal to not more than 3 times the 

[statutory damages available above]. 

47 U.S.C. § 227(b)(3). 

119. Defendants make outgoing calls to consumers and others in the regular course of 

their business. 

120. Defendants placed calls to Rhodes and other Robocall Class members using 

predictive dialers. The predictive dialers are an automatic telephone dialing system; no human 

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manually entered the cellular telephone numbers which Defendants called at the time the call 

was made. Rather, the predictive dialers electronically dialed the Robocall Class members’ 

cellular telephones in an automated fashion. The predictive dialers are capable of storing, 

producing, and dialing any telephone number, and are capable of storing, producing, and dialing 

telephone numbers using a random or sequential number generator. The predictive dialers 

otherwise constitute an “automatic telephone dialing system” under the meaning of 47 U.S.C. § 

227(a)(1). 

121. Defendants also utilized artificial and/or prerecorded voice calls to call the 

cellular telephones of Plaintiff and Robocall Class Members. 

122. Defendants do not and did not obtain legally effective prior express consent to 

call the Robocall Class members’ cellular telephone numbers. 

123. Defendants violated 47 U.S.C. § 227(b)(1)(A)(iii) by placing telephone calls to 

Plaintiffs and the other members of the Robocall Class that were automatically dialed by 

Defendants’ telephone system and/or used an artificial or prerecorded voice; made to a cellular 

telephone number; and not as the result of the Robocall Class member’s transaction with 

Defendants or its agents. 

124. Defendants’ violations are willful because Defendants knew that Rhodes and 

members of the Robocall Class had not given prior express consent to receive calls made using 

an automatic telephone dialing system, artificial, and/or prerecorded voice and that Defendants 

used these methods to call the cell phones of Plaintiff and Robocall Class members. 

125. Plaintiff Lynne Rhodes, on her own behalf, and on behalf of the other members of 

the Robocall Class, seeks to recover statutory damages (including treble damages for willful 

violation of the TCPA), as well as injunctive and equitable relief under 47 U.S.C. § 227(b)(3), 

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against Defendants. 

SECOND CLAIM FOR RELIEF 

Violation of 47 U.S.C. § 227(b)(1)(B) Against All Defendants 

by Plaintiffs, Individually, and on Behalf of the Residential Class 

 

126. Plaintiffs hereby incorporate by reference the allegations contained in all 

preceding paragraphs of this complaint. Plaintiffs assert this claim on behalf of themselves and 

the members of the Residential Class. 

127. The TCPA prohibits certain uses of telecommunication equipment that would 

interfere with telephone service subscribers’ privacy and/or property rights with respect to their 

telephone. In particular, the TPCA makes it unlawful for any person: 

to initiate any telephone call to any residential telephone line using an 

artificial or prerecorded voice to deliver a message without the prior 

express consent of the called party, unless the call is initiated for 

emergency purposes or is exempted by rule or order by the Commission 

under paragraph (2)(B). 

47 U.S.C. § 227(b)(1)(B). 

128. The TCPA provides telephone service subscribers a private right of action for 

injunctive relief and statutory damages for violations of 47 U.S.C. § 227(b) or “regulations 

prescribed under” 47 U.S.C. § 227(b) “to enjoin such a violation” and/or to recover actual 

damages or “$500 in damages for each such violation,” as well as treble damages where the 

“court finds that the defendant willfully or knowingly violated [47 U.S.C. § 227(b).]” 47 U.S.C. 

§ 227(b)(3). 

129. Liberty Power and its agents also utilized artificial and/or prerecorded voice 

messages in calls to residential telephones of Plaintiffs and Residential Class members. 

130. Liberty Power and its agents do not and did not obtain legally effective prior 

express consent to call the Residential Class members’ residential telephone numbers. 

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131. Liberty Power and its agents violated 47 U.S.C. § 227(b)(1)(B) by placing 

telephone calls to the residential telephone numbers of Plaintiffs and the other members of the 

Residential Class using an artificial or prerecorded voice without their prior express written 

consent. 

132. Liberty Power willfully violated 47 U.S.C. § 227(b)(1)(B) because it knew that 

Plaintiffs and the other Residential Class members had not given prior express consent to receive 

calls made using an artificial, and/or prerecorded voice and that Liberty Power and its agents 

used these methods to call the residential telephone numbers of Plaintiffs and the other 

Residential Class members. 

133. Plaintiffs, individually, and on behalf of the other members of the Residential 

Voice Class, seek to recover statutory damages (including treble damages for willful violations), 

as well as injunctive and equitable relief under 47 U.S.C. § 227(b)(3) against Liberty Power. 

THIRD CLAIM FOR RELIEF 

Violation of 47 U.S.C. § 227 (c)(5) Against All Defendants 

by Plaintiffs, Individually and on Behalf of the NDNC Class 

134. Plaintiffs hereby incorporate by reference the allegations contained in all 

preceding paragraphs of this complaint. Plaintiffs assert this claim on behalf of themselves and 

members of the NDNC Class. 

135. The TCPA provides that any “person who has received more than one telephone 

call within any 12-month period by or on behalf of the same entity in violation of the regulations 

prescribed under this subsection [i.e., 47 C.F.R. § 64.1200(c)(2)] may” bring an action for 

injunctive relief and statutory damages of $500 per violation. 47 U.S.C. § 227(c)(5). 47 C.F.R. § 

64.1200(c)(2) provides that “[n]o person or entity shall initiate any telephone solicitation” to a 

“residential telephone subscriber who has registered his or her telephone number on the national 

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do-not-call registry of persons who do not wish to receive telephone solicitations that is 

maintained by the Federal Government.” 47 C.F.R. § 64.1200(e) extends the privacy protection 

in subsection 64.1200(c) to wireless telephone numbers. 

136. Liberty Power and its agents violated 47 C.F.R. § 64.1200(c) by initiating 

telephone solicitations to wireless and wireline residential telephone subscribers such as 

Plaintiffs and the other NDNC Class members. 

137. Liberty Power did not have an established business relationship with Plaintiffs 

and the other NDNC Class members. 

138. Liberty Power and its agents made more than one unsolicited telephone call to 

Plaintiffs and members of the NDNC class within a 12-month period without their legally 

effective consent to receive such calls. Plaintiffs and members of the NDNC Class never 

provided any form of consent to receive telephone calls from Liberty Power and/or Liberty 

Power does not have any evidence of consent to place telemarketing calls to them. 

139. Plaintiffs and the other members of the NDNC Class have a claim against Liberty 

Power because Plaintiffs and the other members of the NDNC Class received more than one 

telephone call within a 12-month period made by or on behalf of the Liberty Power in violation 

of 47 C.F.R. § 64.1200. As a result of the conduct of Liberty Power and its agents, Plaintiffs and 

the class suffered actual damages and have a claim for $500 in statutory damages for each such 

violation of 47 C.F.R. § 64.1200, and injunctive relief. 47 U.S.C. § 227(c)(5). 

140. Liberty Power willfully violated 47 C.F.R. § 64.1200(c). Liberty Power knew 

Plaintiffs and the other NDNC Class members had not given legally effective consent to receive 

telemarketing calls, and that many of the calls made by Liberty Power and its agents were 

received by individuals on the National Do Not Call registry. 

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141. Plaintiffs, individually, and on behalf of the other members of the NDNC Class, 

seeks to recover statutory damages (including treble damages for willful violations), as well as 

injunctive and equitable relief under 47 U.S.C. § 227(c)(5) against Liberty Power. 

FOURTH CLAIM FOR RELIEF 

Violations of the TCPA, 47 U.S.C. § 227 (c)(5) Against All Defendants 

by Plaintiffs, Individually, and on Behalf of the Internal DNC Class 

142. Plaintiffs hereby incorporate by reference the allegations contained in all 

preceding paragraphs of this complaint. Plaintiffs assert these claims on behalf of themselves and 

members of the IDNC Class. 

143. 47 C.F.R. § 64.1200(d) provides that “[n]o person or entity shall initiate any call 

for telemarketing purposes to a residential telephone subscriber unless such person or entity has 

instituted procedures for maintaining a list of persons who request not to receive telemarketing 

calls made by or on behalf of that person or entity. The procedures instituted must meet the 

following minimum standards: 

(1) Written policy. Persons or entities making calls for telemarketing purposes must have 

a written policy, available upon demand, for maintaining a do-not-call list. 

(2) Training of personnel engaged in telemarketing. Personnel engaged in any aspect of 

telemarketing must be informed and trained in the existence and use of the do-not-call 

list. 

 

(3) Recording, disclosure of do-not-call requests. If a person or entity making a call for 

telemarketing purposes (or on whose behalf such a call is made) receives a request from a 

residential telephone subscriber not to receive calls from that person or entity, the person 

or entity must record the request and place the subscriber's name, if provided, and 

telephone number on the do-not-call list at the time the request is made. Persons or 

entities making calls for telemarketing purposes (or on whose behalf such calls are made) 

must honor a residential subscriber's do-not-call request within a reasonable time from 

the date such request is made. This period may not exceed thirty days from the date of 

such request. . . . 

(4) Identification of sellers and telemarketers. A person or entity making a call for 

telemarketing purposes must provide the called party with the name of the individual 

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caller, the name of the person or entity on whose behalf the call is being made, and a 

telephone number or address at which the person or entity may be contacted. The 

telephone number provided may not be a 900 number or any other number for which 

charges exceed local or long distance transmission charges. 

(5) Affiliated persons or entities. In the absence of a specific request by the subscriber to 

the contrary, a residential subscriber's do-not-call request shall apply to the particular 

business entity making the call (or on whose behalf a call is made), and will not apply to 

affiliated entities unless the consumer reasonably would expect them to be included given 

the identification of the caller and the product being advertised.” 

 

144. The TCPA creates a private right of action for injunctive and monetary relief for 

any “person who has received more than one telephone call within any 12–month period by or on 

behalf of the same entity in violation of [e.g., 47 C.F.R. § 64.1200(d).]” 47 U.S.C. § 227(c)(5). 

See also 47 C.F.R. § 64.1200(d)(3) (liability for company specific DNC list violations). 

145. Liberty Power and its agents made more than one unsolicited telephone call to 

Plaintiffs and members of the IDNC class within a 12-month period in violation of 47 C.F.R. § 

64.1200(d). 

146. Liberty Power did not institute minimum procedures required under 47 C.F.R. § 

64.1200(d); Liberty Power consistently fail to honor the requests of Plaintiffs and other 

individuals to stop calling, and specifically to place their name and telephone number on Liberty 

Power’s internal do not call list and to otherwise maintain an adequate do not call policy required 

under 47 C.F.R. § 64.1200(d). 

147. Liberty Power and its agents violated 47 C.F.R. § 64.1200(d) by initiating calls 

for telemarketing purposes to wireless and wireline residential telephones of Plaintiffs and 

members of the class without instituting minimum procedures required under 47 C.F.R. § 

64.1200(d). 

148. Liberty Power willfully violated 47 C.F.R. § 64.1200(d). Liberty Power knew that 

it and its agents failed to institute minimum procedures for maintaining a list of persons who 

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request not to receive telemarketing calls made by or on behalf of Liberty Power and that they 

repeatedly ignored and/or refused to honor Plaintiffs and class members’ requests to be placed on 

a company DNC list. 

149. Plaintiffs, individually, and on behalf of the other members of the IDNC Class, 

seeks to recover statutory damages (including treble damages for willful violations), as well as 

injunctive and equitable relief under 47 U.S.C. § 227(c)(5) against Liberty Power. 

FIFTH CLAIM FOR RELIEF 

Actual Fraudulent Transfers under Fla. Stat. § 726.105(1)(a) 

Against All Defendants by Plaintiffs 

 Individually and on Behalf of the All Classes 

150. Plaintiffs hereby incorporate by reference the allegations contained in all 

preceding paragraphs of this complaint. Plaintiffs assert these claims on behalf of themselves and 

members of each Class alleged in this complaint. 

151. Plaintiffs allege that Liberty Power regularly and continuously transfers its assets 

(including its profits) to its owners or others (“Transfers”). On information and belief, Liberty 

Power’s assets exist and are maintained in Florida, and the Transfers primarily occur within 

Florida. These Transfers qualify as fraudulent transfers under Florida’s Uniform Fraudulent 

Transfer Act (“UFTA”) (as well as the corresponding UFTA of any other state which might 

conceivably apply), and Plaintiffs seek to prevent further Transfers. 

152. These Transfers may take the form of dividends, loans, release of loans, wages, 

payment of expenses, or any other compensation to the owners, assignment of liens, debts, or 

accounts receivables held by Liberty Power, or Liberty Power’s acceptance of any sort of lien or 

other encumbrance to its owners’ benefit, or any and every other form of payment. The Transfers 

also include indirect payments to the benefit of Liberty Power’s owners—for example, payments 

to spendthrift trusts, gifts (or other payments without reasonably equivalent value) to their 

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children or relatives, or to nominally exempt assets in owners’ names or for their benefits. Other 

Transfers include inter-corporate payments from Holdings to Corp. All these Transfers fit within 

the Florida UFTA’s broad definition of “transfer.” See Fla. Stat. § 726.102(14) (“every mode, 

direct or indirect, absolute or conditional, voluntary or involuntary, of disposing of or parting 

with an asset or an interest in an asset, and includes payment of money, release, lease, and 

creation of a lien or other encumbrance”). 

153. Upon information and belief, Liberty Power’s owners operate Corp. and Holdings 

as a closely-held corporation. Upon information and belief, throughout the class period, Corp. 

and Holdings pay Transfers (in the various forms alleged above) to their owners to coincide with 

the end of Liberty Power’s tax year and/or Liberty Power’s quarterly tax filings throughout the 

class period. Liberty Power has not received reasonably equivalent value for the Transfers: as a 

matter of law, Liberty Power does not receive value for payment of profits (or any other return 

on equity) to its owners. 

154. Under the Florida UFTA’s definitions, Liberty Power’s liability on the TCPA 

claims of Plaintiff and the other class members alleged above constitutes a “debt,” Plaintiffs and 

the other class members are “creditors” of Liberty Power, and Liberty Power is a “debtor” in 

relation to Plaintiffs and the other class members. See Fla. Stat. § 726.102(5), (6), (7). 

155. In 2014, Liberty Power reported it had nearly 200,000 customers—it is reasonable 

to infer Liberty Power’s telemarketing activity is very significant from this large customer base. 

It is further reasonable to infer from Plaintiffs’ experience with Liberty Power’s telemarketing 

that Liberty Power’s corresponding TCPA liability is equally significant. The potential liability 

for large-scale TCPA litigation is frequently massive. Cf. United States v. Dish Network LLC, 

256 F. Supp. 3d 810, 982 (C.D. Ill. 2017) (awarding $280 million in TCPA case after significant 

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reductions from face value of statutory penalties). Plaintiffs allege, on information and belief, 

that Liberty Power and its agents routinely violate the TCPA on a massive scale, and their total 

liability on the class TCPA claims alleged above significantly exceeds Liberty Power’s assets. 

156. Hence, Transfers of Liberty Power’s assets alleged above inevitably reduce the 

total amount of assets available to satisfy a judgment in favor of Plaintiffs and the other class 

members. The Transfers have injured and threaten to injure Plaintiffs and the other class 

members by impairing or prejudicing (or threatening to do so) their ability to collect a class 

judgment and/or settlement which covers the total value of the TCPA claims asserted against the 

Defendants in this Complaint. 

157. Liberty Power’s revenue has declined over the last few years. Liberty Power’s 

gross revenue has declined from $891 million in 2015, to $595 million in 2016, to $335 million 

in 2017. Upon information and belief, this decline is because Liberty Power cannot economically 

compete with electric utilities which have the capacity to generate and supply their own 

electricity to customers, as well as actions by state regulators to increasingly curtail Liberty 

Power's operations and marketing. 

158. For instance, the Office of the Attorney General for Massachusetts has released a 

report supporting Plaintiffs’ allegations that Defendants’ business model is not viable, absent 

significant abuse of their customer base: 

Competitive suppliers generally do not generate electricity themselves. Rather, 

they buy electric supply on the wholesale market and sell it to retail consumers. . . 

. Electricity consumers taking service from a competitive supplier receive their 

electric supply from a supplier, but continue to have that electricity delivered to 

them by their electric company. . . . 

Massachusetts residential electricity consumers who took service from a 

competitive supplier paid a total of $176.8 million more than they would have 

paid if they had received basic service from their electric company over the 

course of the two study periods. . . . 

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The large and growing annual consumer losses (which disproportionately harm 

low-income and minority communities) suggest that suppliers have found 

Massachusetts markets to be attractive precisely because they are able to charge 

high rates. 

State of Massachusetts, Office of the Attorney General, Are Consumers Benefiting from 

Competition? 1, 6, 41 (Mar. 2018), at https://www.mass.gov/files/documents/2018/03/29/ 

Comp%20Supply%20Report%20Final%20032918.pdf. The report concludes that “stronger 

consumer protection measures are insufficient to transform the competitive supply market from 

one that causes significant net harm to one that provides net benefits,” and calling for the 

complete elimination of “the electric supply market for individual residential consumers.” Id. at 

x. 

159. The report from the Massachusetts Attorney General also collects data of 

customer complaints which is strikingly consistent with many of the allegations above, and 

which suggests that retail electricity suppliers’ business model is ultimately not sustainable 

absent significant marketing abuses: 

In the seven years from 2006 to 2013, the AGO received approximately 215 

complaints about competitive suppliers. Since 2014, however, the AGO has 

received more than 700 complaints regarding competitive suppliers. The 

complaints often allege a variety of unfair or deceptive acts or practices, many 

times alleging more than one type of misconduct per complaint. 

The complaints typically include one or more of the following common 

allegations: 

• the competitive supplier promised savings, but the consumer ultimately pays 

substantially more for electric supply than he or she did before; 

• the competitive supplier took advantage of the consumer’s age, disability, or 

language barrier in order to sign the consumer up for the supplier’s product; 

competitive suppliers employing high-pressure, aggressive sales tactics, including 

harassing consumers by coming to their door or calling their phone over and over 

again in a short time span; 

• the competitive supplier solicited the consumer on the phone, even where the 

consumer is on the “Do Not Call” list . . . 

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These allegations are not just common in Massachusetts, but across the fourteen 

states and jurisdictions in which the electric supply market was deregulated for 

residential consumers (the “deregulated states”). A perfunctory internet search 

indicates that in the last five years, thirteen of the fourteen deregulated states have 

launched investigations regarding unfair or deceptive acts or practices by electric 

suppliers who also are licensed to do business in Massachusetts. This includes at 

least 35 investigations or lawsuits by state public utility commissions and state 

attorneys general and/or consumer advocates. Moreover, suppliers who are 

licensed to do business in Massachusetts have been the subject of at least 59 class 

action lawsuits, as well as numerous individual lawsuits—all alleging unfair and 

deceptive acts and practices consistent with the types of complaints regularly 

received by the AGO. Unfortunately, the investigations and lawsuits appear to 

have little deterrent effect—rather, they seem to be borne by the suppliers as a 

mere cost of doing business. 

Id. at 39. 

160. Likewise, on April 19, 2018, the Connecticut Office of Consumer Counsel has 

petitioned the Connecticut Public Utility Regulatory Authority to order Holdings to cease and 

desist telesales and door-to-door marketing because it alleged Holdings overcharged Connecticut 

customers over $7.7 million the prevailing rates of electric utilities. Connecticut Office of 

Consumer Counsel, News Release, at http://www.ct.gov/occ/lib/occ/occ_press_release_cease 

__desist_liberty_power_04_19_18.pdf (dated April 19, 2018). The OCC identified other state 

regulatory actions against Liberty Power: 

On April 11, 2018, the New York Attorney General announced a settlement with 

Liberty, under which Liberty agreed to implement new restrictions on its 

marketing practices to prevent future frauds and pay $550,000 to refund eligible 

New York consumers. The New York Attorney General found that Liberty’s 

contractors and subcontractors lured consumers with false promises of savings 

and other deceptive means to enroll consumers, such as falsely claiming to 

represent the consumer’s current utility provider. In 2013, the New York Public 

Service Commission suspended Liberty’s authorization to conduct door-to-door 

marketing in New York after finding that Liberty exhibited a pattern of marketing 

that appeared to include misrepresentations and unauthorized account transfers. 

Liberty is also under investigation by the Massachusetts Attorney General Maura 

Healey, who recently issued a report calling for an end to the competitive 

electricity supply market for individual residential customers in Massachusetts. 

Id. See also State of Massachusetts, Office of the Attorney General, Press Release AG Healey 

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Calls for Shut Down of Individual Residential Competitive Supply Industry to Protect Electric 

Customers, at https://www.mass.gov/news/ag-healey-calls-for-shut-down-of-individualresidential-competitive-supply-industry-to-protect (Mar. 29, 2018). 

161. The financial strain on Liberty Power and its scramble to alleviate that strain is 

evident in other regulatory actions. For instance, the Connecticut Public Utilities Regulatory 

Authority has also found that Holdings charged its customers vastly inflated rates for electricity, 

and violated Connecticut law by attempting to back-bill these customers without offering a 

payment plan. 

162. These regulatory actions threaten the continued ability of Holdings to generate 

revenue for Defendants (and indeed the viability of Liberty Power’s market in Massachusetts). 

Further, any financial assets which remain in Liberty Power are threatened not only with 

depletion from the costs of running Liberty Power’s business but also by the prospect of 

continued regulatory action (as well as liability for TCPA violations). Indeed, during the class 

period, Liberty Power has faced several significant and material class action lawsuits which have 

threatened its financial viability. Plaintiffs further allege, on information and belief, that Liberty

Power’s owners know that Liberty Power regularly and routinely violates the TCPA in the 

course of operating its business, so that Liberty Power’s TCPA liability dwarfs its profits. 

Nonetheless, upon information and belief, Liberty Power routinely and regularly Transfers every 

dollar in profit to its owners—the owners deliberately keep Liberty Power very thinly 

capitalized. On information and belief, this inadequate capitalization has created financial 

problems for Liberty Power, including problems attracting and retaining employees. One former 

employee sued Defendants, and alleged that he was told Defendants were “having financial 

problems and [were] in need of raising capital,” and Defendants’ owners “misrepresented the 

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financial problems and amount of capital needed by [Defendants.]” Upon information and belief, 

Liberty Power’s owners routinely strip out as much of Liberty Power’s assets as they can while 

continuing to operate its business. On information and belief, Liberty Power’s owners expressly 

organized and operate Corp. and Holding to convey the impression and pretense they are 

“bankruptcy remote,” so that once Liberty Power Transfers its assets to its owners, those assets 

are no longer available to satisfy Liberty Power’s liability. 

163. Liberty Power has not received reasonably equivalent value for such Transfers: as 

a matter of law, Liberty Power does not receive value for payment of profits (or any other return 

on equity) to its owners. Finally, Liberty Power has been insolvent (and/or its assets have been 

unreasonably small in relation to its TCPA liability) throughout the class period. The 

circumstances alleged above indicate that Liberty Power and its owners intended the Transfers 

“to hinder, delay, or defraud any creditor” of Liberty Power. See Fla. Stat. § 726.105(1)(a). The 

Transfers are fraudulent under the Florida UFTA’s actual fraud prong. 

164. Plaintiffs, individually, and on behalf of the other members of the classes, seek 

injunctive and equitable relief against Defendants including prospectively enjoining fraudulent 

Transfers, attachment of assets, appointment of a receiver, and imposition of a constructive trust 

under Florida Statute 726.108. 

SIXTH CLAIM FOR RELIEF 

Constructive Fraudulent Transfers under Fla. Stat. §§ 726.105(1)(b), 726.106 

Against All Defendants by Plaintiffs 

 Individually and on Behalf of the All Classes 

165. Plaintiffs hereby incorporate by reference the allegations contained in all 

preceding paragraphs of this complaint. Plaintiffs assert these claims on behalf of themselves and 

members of each class alleged in this complaint. 

166. Consistent with paragraphs in the Fifth Claim above, Plaintiffs allege that Liberty 

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Power has made Transfers to its owners throughout the class period. Liberty Power has not 

received reasonably equivalent value for the Transfers: as a matter of law, Liberty Power does 

not receive value for payment of profits (or any other return on equity) to its owners. The 

Transfers did not preserve or increase the net worth of Liberty Power, and were not for fair 

market value of the assets transferred. Upon information and belief, Liberty Power engages 

business or transactions (including telemarketing campaigns which inevitably serve to increase 

its TCPA liability) for which its remaining assets are unreasonably small in relation to the 

business or transaction, especially considering its TCPA liability. Nonetheless, Liberty Power 

continues to conduct telemarketing campaigns that subject it to additional TCPA liability. By 

doing so, Liberty Power is both insolvent (in light of its TCPA liability) and intends to incur, or 

reasonably should have believed it would incur debts on TCPA claims beyond its ability to pay 

as such debts became due. The Transfers are fraudulent under the Florida UFTA’s constructive 

fraud prong. See Fla. Stat. §§ 726.105(1)(b), 726.106. 

167. Plaintiffs, individually, and on behalf of the other members of the classes, seek 

injunctive and equitable relief against Defendants including prospectively enjoining fraudulent 

Transfers, appointment of a receiver, and imposition of a constructive trust under Florida Statute 

726.108. 

Prayer for Relief 

 WHEREFORE, Plaintiffs pray that the Court enter judgment and orders in their favor and 

against Defendants as follows: 

a. An order certifying the classes, directing that this case proceed as a class action, 

and appointing Plaintiffs and their counsel to represent the classes; 

b. Judgment against Defendants, and in favor of Plaintiffs and the other class 

members in the amount of $1,500 per violation of the TCPA as proven at trial; 

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c. Equitable and injunctive relief, including injunctions enjoining further violations 

of the TCPA; 

d. Injunctive and equitable relief including enjoining fraudulent transfers, 

attachment of assets, appointment of a receiver, and imposition of a constructive 

trust under Florida Statute 726.108; 

e. And such other and further relief as this Court may deem appropriate. 

Dated: November 14, 2018 By: /s/Ethan Preston 

Yitzchak H. Lieberman (pro hac vice) 

ylieberman@parasmoliebermanlaw.com 

Grace E. Parasmo (pro hac vice) 

gparasmo@parasmoliebermanlaw.com 

PARASMO LIEBERMAN LAW 

7400 Hollywood Blvd, #505 

Los Angeles, California 90046 

Telephone: (844) 200-5623 

Facsimile: (877) 501-3346 

John L. Fink, Esq. 

jfink@westborolawyer.com 

FINK LAW OFFICE 

18 Lyman St., Suite 208 

J&N Professional Building 

Westborough, Massachusetts 01581 

Telephone: (508) 433-0529 

David C. Parisi (pro hac vice) 

dcparisi@parisihavens.com 

Suzanne Havens Beckman (pro hac vice) 

shavensbeckman@parisihavens.com 

PARISI & HAVENS LLP 

Santa Monica, California 90405 

Telephone: (818) 990-1299 

Facsimile: (818) 501-7852

Ethan Preston (pro hac vice) 

ep@eplaw.us 

PRESTON LAW OFFICES 

4054 McKinney Avenue, Suite 310 

Dallas, Texas 75204 

Telephone: (972) 564-8340 

Facsimile: (866) 509-1197 

Matthew R. Mendelsohn (pro hac vice) 

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Second Amended Complaint 44 No. 1:18-cv-10506-ADB 

 mrm@mazieslater.com

MAZIE SLATER KATZ & FREEMAN, LLC 

103 Eisenhower Parkway 

Roseland, New Jersey 07068 

Telephone: (973) 228-0391 

Facsimile: (973) 228-0303 

Attorneys for Plaintiffs Samuel Katz, Lynne 

 Rhodes, and Alexander Braurman, individually and 

 on behalf of similarly situated individuals

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JURY TRIAL DEMAND

 Plaintiffs hereby demand a trial by jury of all issues so triable. 

Dated: November 14, 2018 By: /s/Ethan Preston 

Yitzchak H. Lieberman (pro hac vice) 

ylieberman@parasmoliebermanlaw.com 

Grace E. Parasmo (pro hac vice) 

gparasmo@parasmoliebermanlaw.com 

PARASMO LIEBERMAN LAW 

7400 Hollywood Blvd, #505 

Los Angeles, CA 90046 

Telephone: (844) 200-5623 

Facsimile: (877) 501-3346 

John L. Fink, Esq. 

jfink@westborolawyer.com 

FINK LAW OFFICE 

18 Lyman St., Suite 208 

J&N Professional Building 

Westborough, Massachusetts 01581 

Telephone: (508) 433-0529 

David C. Parisi (pro hac vice)

dcparisi@parisihavens.com 

Suzanne Havens Beckman (pro hac vice) 

shavensbeckman@parisihavens.com 

PARISI & HAVENS LLP 

Santa Monica, CA 90405 

Telephone: (818) 990-1299 

Facsimile: (818) 501-7852 

Ethan Preston (pro hac vice) 

ep@eplaw.us 

PRESTON LAW OFFICES 

4054 McKinney Avenue, Suite 310 

Dallas, Texas 75204 

Telephone: (972) 564-8340 

Facsimile: (866) 509-1197 

 

Matthew R. Mendelsohn (pro hac vice to be filed) 

 mrm@mazieslater.com

MAZIE SLATER KATZ & FREEMAN, LLC 

103 Eisenhower Parkway 

Roseland, New Jersey 07068 

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Second Amended Complaint 46 No. 1:18-cv-10506-ADB 

Telephone: (973) 228-0391 

Facsimile: (973) 228-0303 

Attorneys for Plaintiffs Samuel Katz, Lynne Rhodes,

and Alexander Braurman, individually and on 

behalf of similarly situated individuals 

CERTIFICATE OF SERVICE 

I, Grace E. Parasmo, hereby certify that this document filed through the ECF system will be sent 

electronically to the registered participants as identified on the Notice of Electronic Filing 

(NEF). 

Dated: November 14, 2018 By: /s/Ethan Preston 

Ethan Preston (pro hac vice) 

ep@eplaw.us 

PRESTON LAW OFFICES 

4054 McKinney Avenue, Suite 310 

Dallas, Texas 75204 

Telephone: (972) 564-8340 

Facsimile: (866) 509-1197 

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Exhibit to Second Amended Complaint No. 1:18-cv-10506-ADB 

Exhibit 1 

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 3 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 50 of 70
 Complaint Date Company Name Complaint Info Comments

o Ottawa IL 60 - 64 LIBERTY POWER 312 4488590

09/18/2013 Aledo IL 70 - 79 Liberty Power 309 3627035 Consumer is calling to file a complaint against Liberty Power. Calling to get her to change her power company.

01/10/2014 Chicago IL 50 - 59 Liberty Power 954 4897148

01/22/2014 New Baden IL 70 - 79 Liberty Power 618 2410498

01/23/2014 Bethesda MD 70 - 79 866 7693799

01/24/2014 Lincoln| IL| 80 and Over| Liberty Power 866 7693799

b(3);21(f) b(3);21(f) b(3);21(f) b(3);21(f) b(3);21(f) b(3);21(f) b(3);21(f) b(3);21(f)

04/03/2014 Sewell NJ 60 - 64 Liberty Power 769 7693799

04/16/2014 Mercer PA 65 - 69 866 7693799

04/16/2014 40 - 49 Liberty Power 877 2899925

04/16/2014 Roulette PA 60 - 64

07/15/2014 Franklin OH 65 - 69 Liberty Power 86676997

07/31/2014 Skaneateles NY 50 - 59 Liberty Power 800 6424272

12/01/2014 Baltimore MD 80 and Over Liberty Power 551 4976849

Consumer Address, 

City

Consumer 

Address, State 

Code

Consumer Age 

range

Company 

Phone, 

Area Code

Company 

Phone, 

Number

I was contacted TWICE by LIBERTY POWER1). 09/06/2013 @ 5:06 PM2). 09/10/2013 @ 11:13 AMI called back and got a 

"receptionist" (girl claimed this role) and she said they were calling from a CALL CENTER IN CALIFORNIA and that they 

SERVICE CALIFORNIA, ILLINOIS, DELAWARE, ETC.CA SEC'Y of STATE shows this company SUSPENDED IN CALIFORNIA?The 

address of a subjective person who may have been solicited to make this approx 175th call this year to me is at 3023 N. Clark Street; 

Chicago, IL. He is associated with N. American Aviation, same company as one of my believed solicitors, ATTORNEY, STEVEN M. 

ROGERS who also has another association in this building to ATTORNEY STEVEN M. ROGERS; e.g., SINGLE SOURCE....This guy 

needs to leave me alone; quit stalking me. He's been doing it for 17 years Other-Other Update

Consumer states that he is receiving unwanted calls from Liberty Power, offering him utility services. Consumer has informed the 

company that he is not interested and has asked them to stop calling but, the calls have continued.

Consumer states that someone called her from Liberty Power to offer a service and asked her for her existing account number from 

Ameran. Consumer states that they continue to call her after she asked them to stop. UPDATE 01.15.2014 Consumer reports that she is 

still receiving calls from the same company. Consumer reports that they have been told to discontinue calling but continue calling. 

Consumer reports that they believe it to be a scam. ANELSON UPDATE: 1/22/14 Consumer called back to report that the calls from 

Liberty Power continue. NLazar.

Liberty Power 

Corporation 

On September 19, a representative from Liberty Power Corporation (hereafter, LPC) named Alex called The World Market and spoke with 

the owner, Mr. (b)(6) with the aim of encouraging (b)(6) to become an LPC customer. (b)(6) explained that he already had a contract with 

a power company, Direct Energy, and that this contract was active through June 2014. (b)(6) told Alex that he would like a quote from 

Alex so he can compare LPC’s rate to the current rate offered by Direct Energy. Alex assured (b)(6) that he would give him a quote and 

(b)(6) would be able to choose whether or not to accept LPC’s power. Alex proceeded to sign (b)(6) up for service with LPC and assured 

(b)(6) that he could cancel his service without any fees. The account number given to (b)(6) is (b)(6). (b)(6), who is 75 years old and for 

whom English is his second language, proceeded speaking with Alex, believing that he was simply receiving a quote and he did not 

understand that he was verbally agreeing to sign up for LPC’s services and that this was a legally binding contract. Alex told (b)(6) that 

he would send him paperwork related to their discussion. On September 21, 2 days after the phone conversation with Alex, (b)(6) called 

Alex at the phone number he was given (1-877-436-7162, ext. 3859) and told him that he did not receive any paperwork and that he 

decided not to switch his service from Direct Energy to LPC because Direct Energy’s rate was better. Based on his conversation with 

Alex, (b)(6) believed he had no obligation to LPC. (b)(6) received a bill from Pepco dated December 3, 2013. The bill noted that Liberty 

Power was the power supplier for The World Market. On December 6, 2013, (b)(6) called LPC and explained to them that he believed he 

was a Direct Energy customer and that he had not intended to switch to LPC and that he called and told the LPC representative that he 

did not want LPC’s service. (b)(6) then called Direct Energy and explained the situation to them and told them he never intended to 

switch to LPC and wanted Direct Energy’s services. On December 19, 2013, (b)(6) received a letter from Direct Energy stating that they 

were now the energy supplier for The World Market. On December 31, 2013, (b)(6) received a letter from LPC stating that he was 

responsible for an $1881.00 termination fee. On January 7, 2014, (b)(6)’s daughter placed a number of calls to LPC attempting to 

understand the situation. She spoke with 3 separate people and explained to them that (b)(6) did not understand and was very confused 

when he spoke with their representative Alex. She requested that they waive the termination fee since (b)(6) is an elderly man, he never 

received a paper contract from LPC and English is (b)(6)’s second language. Her request was refused. In addition to the $1881.00 

termination fee, (b)(6) has been billed a total of $1155.48, which he has paid. We are asking for the termination fee to be waived and a 

refund in the amount of $1155.48 because (b)(6) was not aware that he was signing up for services with LPC. He told the representative 

from LPC multiple times that he was only interested in a quote, he did not want LPC’s services and he was under a contract with Direct 

Energy until June 2014. (b)(6) never received any paperwork from LPC outlining the terms of his contract.

The consumer's daughter states that this company Liberty Power out of Florida called her mother and signed her up for changing power. 

She did not understand. Her mother is on the do not call list.

Signed 1 year contract with Liberty. At end of 1st year Liberty sent new 1 year contract which I signed and returned. Was notified by 

Liberty soon after that the new contract I signed had wrong rate as the wrong code for my business was used. I had no problem with that 

and awaited corrected contract which did not come for several months. During the time between end of first contract and getting the new 

corrected contract Liberty billed me the rate for a non contracted customer. I, however, continued to pay the rate I had under the first 

contract until I received the new corrected contract. Once I received the new corrected contract I adjusted the payments I made for the 

time between the old contract and the new corrected contract. The adjusted was based on the new corrected rate. Liberty, however, 

insisted that I pay the non contracted rate I was billed during this period. I refused stating that it was their mistake that caused the lapse 

between the old and new contract. I paid them the new rate which should have applied immediately after the old contract expired. 

Eventually they terminated my account for failure to pay the difference and then billed me another $174 for early termination. Other-Other 

Update

Liberty Power 

Holdings LLC

We are the American Legion, we got a call from Liberty Power and told we would save money by going with them. We were lied to and it 

is costing a lot more than they said. We tried to cancelle and they want a big fee, according to their contract that we never got. They 

charged us about $1,364.22 to much over the last 3 months. Other-Other Update

They called me repeatedly trying to sell me Liberty Power as a electricity distribution company. They should not be calling me, as my 

phone is on the "do not call List". Other-Other Update

Liberty power. 877-

289-9925

we have been receiving 1-3 calls per day from (877-289-9925) they ask to speak to the head of the household telling us he is from Liberty 

Power and can offer us better electric rates. he has been told numerous times that we are not interested and not to call again. this 

request is totally disregarded by the caller. the caller sounds to be foreign possibly Indian. this can be considered harassment! OtherOther Update

the consumer said that a person saying that she was from Duke Energy and talked to his wife. they had her sign a contract but it was 

Liberty Power. Duke Energy resinded the contract.

Consumer states she is getting calls from Liberty Power & she is on the NDNC register. Consumer has asked them to stop calling but 

they still call.

Consumer received a phone call from someone claiming to be from Liberty Power offering him services for a lower price. Consumer was 

being asked for his gas account information and suspects this was a fraudulent phone call.

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 4 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 51 of 70
01/12/2015 Deep River CT 50 - 59 Liberty Power 860 7267903

01/14/2015 Antonia CT 50 - 59 Liberty Power 860 7267903 Consumer called to report that she is getting telemarketing calls and the consumer is registered on the NDNC List.

01/15/2015 West hartford CT 60 - 64 Liberty power I am on the do not call list and still recieve these calls all the time. Other-Other Update

02/05/2015 Boston MA 20 - 29 Liberty Power Corp 186 6769379

03/05/2015 Joliet IL 20 - 29 Liberty Power

03/12/2015 Jamaica Plain MA 30 - 39 Liberty Power 123 4567890

03/28/2015 Brighton MA 20 - 29 Liberty Power

04/08/2015 Liberty Power

05/13/2015 Skokie IL 70 - 79 Liberty Power 866 7693799

06/17/2015 Palatine IL 30 - 39 866 7693799

08/13/2015 Allston MA 30 - 39 Liberty Power 186 6769379

08/22/2015 Liberty Power

10/28/2015 Worcester MA 20 - 29 Liberty power

11/07/2015 Chicago IL 30 - 39 Liberty power

This company first called, speaking in English, it was a company wanting to get me to switch my power company. They were cold calling. 

I told them that I was not interested, and that my number was on the "Do Not Call" list, and requested that they not call again. They 

proceeded to continue to call at least 3 times a day. I answered the phone on another occasion, and this time someone was speaking in 

Spanish. I told them if they continue to call my number I would file a complaint against them. They apologized, and I did not get a call 

from that number for a few days. Now since after Christmas 2014 to currant time, today 1/12/15 they continue to call but now no-one says 

anything. I called the number back and they answered in spanish so I could not get the name of the company.I just called them again 

blocking my number, and was able to get a broken english speaking person and asked the name of their company and they told me its 

Liberty Power, I told him that I had requested they stop calling my number, and yet they continue to call, and now when they call and I 

answer they do not say anything. He told me that it is because they have to many clients to speak at the time. I told him, I am sorry, Your 

company Calls My Number and then refuses to speak, it is Not because your to busy to talk, your making the call, its called harrassment. 

I again told them Not to call my number. And also told them I was filing this complaint. I was unable to get the persons name at that time 

either.

A representative claiming to be apart of eversource made me sign a contract to fix my rate but at the end i realized that it was a liberty 

power corp to change my electric bill. It was 2 people who pressured me to sign the contract claiming they were representing NSTAR's 

takeover. For me to find out later that it was eversource. I was contacted earlier today by a door-to-door rep Other-Other Update

Consumer states someone came to her home offering her cheaper services then her existing service provider. Consumer states her 

boyfriend signed up with this company but later found out he cannot cancel for at least four years. Consumer was also told it would be a 

charge to transfer her service to a different location as well. Consumer states the company won't give her any information about her 

service because it is not in her name.

Representatives who are likely scammers are arriving at our door periodically to request to see our power bills to get us a lower rate from 

NSTAR. Today they claimed to be from Liberty Power. I did not catch their names. We had a similar incident occur 4-6 weeks ago where 

the rep had entered our building and arrived at our apartment door requesting to see the power bill. I spoke with the reps today at the 

apartment building front door and did not offer any info.TOPIC:Referrals

Woman came to our door claiming to be from a 3rd party representing the local government to monitor electric utilities now that NStar is 

Eversource. Insisted on being given information on our electric bill, and refused to leave when asked. We are now signed up for Liberty 

Power, which is not allowing us to cancel immediately, even though the contract my husband signed says we can cancel at any 

time.TOPIC:Referrals

The consumer called to report that he is receiving calls from an individual claiming to be from Liberty Power. The consumer is on the 

DNCR

Consumer states that she received a phone call from someone claiming to be with Liberty Power asking if she wanted to switch over to 

get a lower rate of her electricity bill. Consumer started to ask the caller questions and the caller hung up.

Liberty Power 

Corporation 

This company has quite an extensive listing of complaints with the Better Business Bureau, so you may have them on record already. In 

case not, an Indian Female came to my parents apartment at 2100 hours and insisted that she "was" their service provider and was very 

persistent on seeing a copy of their current power/electric bill. When my mother was reluctant, claiming she had doubts of her affiliation; 

this unknown individual became increasingly persistant and claimed that seeing this bill was important and that she had made several 

other attempts to contact my parents prior. At this point my mother told her point blank; if she doesn't leave, the police will be notified; at 

which point she left. Before, Even, if she didn't make a false claim of being affiliated with our power company; their complex has blatently 

posted signs saying "no solicitors" are allowed on premise. Nothing about this companies tactics seems on the level to me and here are 

two additional articles to back-up these claims.... Website #1: http://www.bbb.org/south-east-florida/business-reviews/electriccompanies/liberty-power-in-fort-lau derdale-fl-23005899 Website #2: http://nypost.com/2013/03/14/state-to-crack-down-on-deceptiveelectricity-seller-officials/ There is no compensation necessary, as my parents didn't give them any information/money, but I strongly 

believe you should investigate their business practices. Not even looking at my parents situation, but rather their track record with the 

Better Business Bureau; it's very apparent to me that this company is not conducting business on the level.

Two men somehow got through the front door of my apartment complex and were going door to door, identifying themselves as 

representatives from the municipality of Boston helping citizens save money on their electric bills. They claimed a law entitled people to 

lock in a lower rate as long as the customer opted into the government sponsored program, aimed at protecting low income households 

(like my own). After asking them questions for over an hour (where they lied multiple times that they worked for the government, and not 

a private entity - Liberty Power) I became exhausted and signed their form. After they left, I went online and read about the Liberty Power 

scam of lying and coercision to get people to sign a contract where customers get stuck at a fixed, higher rate for electricity. I asked 

multiple times if I was signing a contract and was told explicitly no, another lie on their part. These people really need to be stopped as 

they target low income and immigrant households. I have higher level education and english is my native language, and yet I still 

succumbed to their scam!TOPIC:Referrals

I have received a call EVERY DAY from the same number - 6467796616. The first call was on 8/10/2015, I answered and the caller 

identified himself from "Liberty Power." My response was "I am not interested." "Do not call me again." 

"Take me off you call list." Since then, I have received a call EVERY SINGLE DAY from the same number, I have not 

answered any. I have received a call early in the morning, late at night, on the weekends, in the middle of day. Other-Other Update

I was approached by two representatives of Liberty Power ( with Identificstion) they asked to see a copy of my electricity bill.they 

promised to offer a "price protection" free for 24 months.they took my bill and entered my person details.it was later that i 

realized the tarrif per KWH is way high than what i normally pay.I was deceived by the sales person to change my supplier to 

LibertyPower and sign a contract.I am a student who recently moved to USA and I am not aware of the electrcity billing works in the US 

( supply vs distribution) . I really think some action should be taken against these practices being followed by liberty Power and their sales 

representative. Other-Other Update

was changed electric carriers, I was sent an email of a change and apparently a letter of my switch came to my apartment Because my 

service was disconnected, my lease was cancelled and now im forced to move. I don't have a job and i may have to move into a shelter 

because i have no place to go.TOPIC:Referrals

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 5 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 52 of 70
06/24/2016 Crest Hill IL 80 and Over Liberty Power 866 7693799

07/29/2016 Milford MA 20 - 29 Liberty Power 866 7693799

09/20/2016 Worcheter MA 50 - 59 Liberty Power 866 7693799

10/24/2016 Silver Spring MD 20 - 29 866 7693799

10/27/2016 Spring Valley IL 80 and Over Liberty Power Corp 866 7693799

11/01/2016 CT 40 - 49 954 7711463

09/29/2015 MA 18 - 19 Liberty power

08/01/2016 HOUSTON TX 40 - 49 800 2799048

01/16/2017 Burlington MA 40 - 49 Liberty Power

01/21/2017 Wilkes Barre PA 20 - 29 Liberty Power 

My name is (b)(6), I'm (b)(6) Neighbor, she is 89 years old and hard of hearing. Liberty Power knocked on her door, she usually doesn't 

answer the door, I don't know why she did this time, she must have been out there quite a while and I did n't hear her, because by the 

time I opened my door she was signing the IPAD. I asked the rep. who he was, he proceeded to tell me, first he was sent by ComEd( our 

power supplier) to check our bills to make sure we had the right supplier and he asked for my bill also, I didn't show him mine but I said 

ComEd is my supplier, he asked to see my bill. I asked again who are you, he stated I work for ComED. I told him none of this is true, its 

a scam, i'm going to check with ComEd. He told me while you do that I will check with your other neighbors. That man ran out the door 

faster than you can say I scammed an 89 yo woman.That was on 6/17/16 I can take care of myself, but to scamm an old lady...come on. I 

emailed Liberty that night and they apologized and asked for (b)(6) account number with ComEd so they can make sure nothing was put 

thru. That was on 6/20/16.I sent them the information.They emailed me back stating they couldn't find any account for (b)(6). On 6/23/16, 

(b)(6) received a letter from ComEd stating they were notified by Liberty that (b)(6) was switching suppliers. This compant couldn't tell the 

truth if they tried. I called customer service the night of 6/23, I was told if (b)(6) didn't want it she shouldn't have signed for it. I had to 

argue for a good 15 minutes to get them to cancel it, but with a $50 fee. I asked for a supervisor, but was told the supervisor would tell me 

the same thing so I didn't need to speak to one. That agent spoke to (b)(6) to confirm she wanted to cancel, the agent had to keep 

repeating herself because (b)(6) is hard of hearing. There is no excuse for this

On 7/28/2016 at 7:30pm a Liberty Power sales rep knocked on our door. He asked to see our electric bill and told us we were being 

charged $4.00/kwh by National Grid (in reality its about $0.04). He offered us a fixed rate of $0.138/kwh for 24 months. At the time he had 

the bill and I did not look at it to make sure he was correct. In the middle of the application his tablet froze and he said he needed to get 

his boss to reset it and he would return for my signatures in about 15 minutes. He never returned that night. I called Liberty Power on 

7/29/2016 at 8:30am to see if the contract wetn through. It had not showed up in their system. The woman was very understanding and 

sent a cancellation request right away. In 3-5 business days I can check in with them to make sure the service contract was cancelled. If it 

is not then I will consider the fact that it was even submitted criminal, since my signatures would had to have been forged/left off. OtherOther Update

The consumer stated that she received something in the mail from Liberty Power for a contract for service. The consumer stated that the 

company mailed the consumer a contract with her a signature twice and did not how the company got her information.

Liberty Power Corp., 

LLC

For the last 4 years, I have been enrolled with Autopay for my Pepco Bill. Twomonths ago, I saw in my bill and found out that I was signed 

up with LibertyPower Corp as my electricity supplier. I never authorized to be signed up withthem and I am not even aware of that 

company. I never received anycorrespondence from them regarding a contract or acknowledgement. When Irequested a copy of a so 

called contract and sign-up confirmation, they cannotprovide any information. All they can say is that a third party sales channel,American 

Efficient Inc., was the one who submitted my name to sign up withthem. And since they no longer work with American Efficient, they 

cannotprovide the information I am requesting. Please see BBB Complaint (b)(6).

The consumer reports that he is receiving numerous calls from Liberty Power Corp offering him a discount on his utilities bills. The 

consumer has declined and told them to stop calling but they continue to call. The consumer is not on the DNC Registry.

Liberty Power Corp 

LLC

I have filed several complants against this company, and countless others like them... I put my phone number on the donot call list... That 

hasn't worked either.. There are calling my cell phone now... This is a Goverment phone... filed it with the No call list too.. still getting 

harrassed by them.,..... Can someone tell these morons to stop calling me..... I'm tired of it!

Guy came to out door and said he could save us money on our electric bill. He said they have lower rates. He had us sign a form for a 

quote. Than he automatically enrolled us. My electric bill went from $200 to $400. They increased my bill without permission. Company 

name name is. Liberty power. IsVictim:true --- Initial Means of Contact: Unknown

Liberty Power 

Company

CFPB Sub product: Other (i.e. phone, health club, etc.) --- CFPB Issue Type: Improper contact or sharing of info | Talked to a third party 

about my debt --- What Happened: i was not aware of any moneys owed, Liberty Power waited for 1 year and 5 months before sending 

me any notice of informing me moneys are owed, i not only question the validity of this money, i also question the tactics used, the call 

me on July 26 2016, informing me that moneys were owed, i ask for written details, which i was told was on its way to me, i got a mail on 

on July 27th 2016. i called Liberty Power on July 27th with intent to resolve this and was told the debt was sent to collection, does this not 

violate every single FTC rules, i was not given the opportunity to pay or investigate the validity of this debt, i was sent a letter which is the 

first notification i ever got from Liberty that unless they receive payment in 5 days they would send account to collection agency, they did 

not give 3 day room for Post Office delivery, the letter was not expedited or sent with any delivery confirmation. now they forwarded it 

straight to collection before the 5 days was concluded. this violated FTC rules. if payment request is made, i should be given a decent 

amount of time to review ad understand the validity of the debt and ask any questions to satisfy their claims these were denied to me. and 

i called same day i received the letter only to be told it was in collections already.i was asked to call on Monday August 1, 2016 to speak 

with a Supervisor so we could clear up any balance if owed.only for supervisor to inform me it has been sent to IC Systems and nothing 

could be done on this account.first of all i never switched my account to Liberty Power, they never had my permission to transfer my 

service, i questions them on how did my service get managed by them and also i transferred back to Power company of choice and now 

it seems they are attempting to penalize me for this, why should i pay a cancellation fee if they fraudulently moved my account to their 

organization, what number was this call from that moved service. was there a recording? anyway i am willing to pay it off just for a 

settlement but i protest and would pursue every legal action if reported to my credit report --- Fair Resolution: not reporting to my credit 

and giving me the opportunity to understand what this is about and avenue to make payment, if found to be legitimate

Knocked on door on MLK holiday, pretended to be from state, offerred lower fixed electricity rates, took down my address, phone number 

and photo of my current bill. Searched online and found them to be a scamming company with very high rates and fees. Browbeating 

other neighbors into signing up for contracts with early termination fees and other fees. Please issue cease and desist order.

A person knocked on my door claiming he needed to see our power bill and needed our personal information to be able to supply us with 

electricity. He claimed he was with Liberty Power and had a jacket with a company logo as well as an ID badge which I could not make 

out. I did not get any personal details about him and did not give out any of our details of our household. He claimed he was not working 

for PPL but that PP&L would need us to give him our info in order to keep our power on. I told him this was fradulent and he 

continued to ensure me he was not going to switch our power over and he simply needed our information to continue our electric service. 

He said Liberty Power was based in Florida and was a reputable company but I have since learned otherwise. I told him to come back 

another day at which point he was aggressive in trying to get us to give him information now. I told him no and eventually he left. I feel he 

was fradulent because he tried to say as little as possible and said PPL had sent him which I confirmed with PP&L that they had not. 

He made it seem like he was with PPL until I directly asked him if he worked for them, noticing his jacket. He was a average height black 

man with no significant details I can recall. His jacket was navy blue and he did have an ID badge in an orange holder with a black string 

around his neck. He also had a gold watch on. He talked very quietly and raspy as if to not let other people hear him. Other-Other Update

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 6 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 53 of 70
01/31/2017 Winthrop MA 30 - 39 Liberty Power Corp 866 7693799

02/15/2017 Carrollton IL 30 - 39 Liberty Power

03/28/2017 New Haven CT 20 - 29 Liberty Power 646 5938644

04/04/2017 Glastonbury CT Liberty Power 877 2899925

04/04/2017 Liberty Power 866 7693799

04/14/2017 Glastonbury CT Liberty Power 877 2899925

04/14/2017 Pekin IL 80 and Over Liberty power holdings 866 7693799

04/24/2017 Southington CT 65 - 69 866 7693799

08/31/2017 Bronx NY 20 - 29 Liberty Power 973 4196332

06/26/2017 Boston MA 20 - 29 Liberty Power

06/28/2017 Acton MA 30 - 39 Liberty Power 866 7693799

08/15/2017 Glens Falls NY 80 and Over Liberty Power

This company sends door to door representatives advertising cheap electricity rates trying to make you switch power suppliers. The first 

time the deal looked good. I called my utility provider and they said if that's what they are offering you should take advantage of it. 

However, the price they quoted was not the one they put on the contract when I received it a month later. I cancelled the service promptly, 

they waived their cancellation fee. A few months latter I find out that one of their reps had signed my name on another contract without 

my knowledge or consent. Called the company again, they cancelled and assured me that would not happen again. Today they had sent 

another agent who talked to my father and tried to make him sign a consent form, although he didn't understand them. My father didn't 

sign anything. I am worried that I would find myself again into a contract that I didn't want or consent to. I plan on moving in the next few 

months, and if they sign on a contract without my knowledge I'm afraid I wouldn't know about it and it will affect my credit. Please help me 

with this company. This is very frustrating. Other-Other Update

A door to door sales person led my wife to believe he was with ameren and checking on our rate plan,ade her sign up to lock in a rate for 

power usage. Did not mention he was with Liberty Power until after she signed a contract. She intialed her name even though my name is 

on the ameren bill. Then the salesman proceeded to ask for my phone which he then used to call and verify with Liberty Power. He 

pressed all of the buttons and had my phone in his hands. After doing some research we do not want to be in a contract with anyone. We 

would like to continue service with Ameren only. When we called this Liberty Power Company they are telling us we are in a contract and 

will have to pay to cancel with them. The entire time I feel like we were being pushed into thinking we were locking in a rate with Ameren. 

Please contact Liberty Power Corp in Illinois. They are using deceptive practices to reel in customers. Other-Other Update

Consumer is receiving calls from someone representing Liberty Power but they will not leave a message. When the consumer calls them 

back, he asks them to stop calling, but they continue. Consumer is on the DNCR.

The caller ID shows incoming call "From 800 Service" with phone number of 877-289-9925. They have called every day for the past 

month and I have repeatedly asked them to stop! I spoke to someone 3 times who assures me my phone number would be removed and 

the calls would stop. This a rented unit and we don't get to choose our power supplier which I have also notified the company. These 

calls need to be stopped as this is illegal practice by this company. The government needs to make the phone companies more 

accountable for preventing fraud and scams to consumers as they are providing a service.

On the evening of Tuesday, April 4, 2017, a man named William Jones with Liberty Power knocked on my door multiple times and would 

not leave until I opened the door. He claimed that the city gave Liberty Power permission to be doing what he was doing. He said that 

Liberty Power was going to guarantee my electicity rate for two years and that he needed my current account to do it. I was very reluctant 

to provide him this information. I even asked to see the permit. He showed it to me. He sid that Ameren would send me a confirmation 

letter in the mail and two gift cards. He told me this after I initialed and signed. I told him multiple times that I was not comfortable with 

providing my information and even asked if there was a way I could call Liberty Power and complete the process myself. He would not 

leave my apartment until I agreed to initial three boxes and sign. I initialed differently and did not sign my complete name. I did not pay 

and he did not ask me to pay. He did say that there would be a $50 cancelation fee. Once he finally left my apartment, I tried to call 

Ameren, but it was after their customer service hours so I emailed them. I also went outside to look for some sort of official vehicle, but 

there was none. It is alarming that they were in my building because it has a locked entrance. I also researched the company online and 

read only negative reviews with similar experiences. I felt like I had no out while I was in the situation. I was so flustered and frustrated 

that he was not leaving that I did not think to just be rude and shut the door in his face. In general I feel like Liberty Power is taking 

advantage of young adults who need jobs by telling them that they will be doing residents good. I also feel as though Liberty Power is 

taking advantage of residents who are trying to be good citizens and give everyone a chance as well as people who are not fluent in the 

English language. For these reasons, I feel Liberty Power is not operating ethically. I understand that companies need to make a profit, 

but this needs to be done in a moral and ethical way. Other-Other Update

We received a phone call on 3:42 pm to our phone (b)(6) from caller id showing 18772899925. Upon answering and repeatedly saying 

hello, there was dead air and no one responded. The line was then disconnected on their end. I called the number back and was 

redirected to a general voice mail box. I left a message for the third time to request this company remove our phone number from their 

calling sequence. This company has repeatedly called our same phone line multiple times a day over the past month and half. In 

addition to the 3 voice messages I've left to remove our number, I have also called back and spoken to a person twice to tell them they 

MUST remove our number. Both times I was assured by the representative that our phone number would be removed. But yet again, 

they are still calling. We are a business and we lease our space so we are not in charge of selecting who our power supplier is. The 

company has been told this hence why they have NO BUSINESS calling us. Furthermore, this company is calling a phone number that 

has been taken out of public distribution for 5 years and is used solely for internal purposes so they further have no business calling our 

number. PLEASE HOLD LIBERTY POWER ACCOUNTABLE FOR THEIR ILLEGAL SOLICITATION PRACTICES. Any further calls are 

deemed harassment and they need to be made to stop making illegal calls.

This utility supplier keeps switching our Ameren account supply choice to them. We realized when we received a supplier choice 

notification from Ameren. We made a phone call to Liberty Power, who indicated we have a contract with them. We do not. When we 

switch our supplier choice back to Ameren, it must trigger something to Liberty, who proceeds to call and aggressively intimidate us. 

When we have asked for a copy of the contract they claim to have, and they refuse to provide and have hung up on us. The utility 

account belongs to an elderly person.

Liberty Power Holding 

LLC

The consumer is reporting received a phone call and they told the consumer they could lower his electric bill. The consumer said that they 

offer less money for the bill. They charged the consumer more money. The consumer said the company is called Liberty Power Holding 

LLC.

Consumer states he received a call from Liberty Power of Conn Edison and call at least 2 a day. They are making a sales pitch. They are 

asking for information of the party that holds this account. UPDATE: 8/31/17 Consumer provided ph#'s. rbaconsr.

Consumer reports multiple unknown utility companies called Liberty Tower have been coming to his door attempting to sign consumer up 

for an alternative energy sources.

I received a knock on my door at around 8pm on Tuesday, June 27. There was a woman, Katrina Busser, with a Liberty Power company 

name badge and an ipad. She said she was from Liberty Power and wanted to make sure I was signed up for clean energy. She asked to 

see my electric bill to check that I was using clean energy. She said that I wasn't and then she proceeded to enter my information in her 

ipad, all the while talking to me politely and keeping up friendly chit chat. I was not wary of her as she had a name badge and a pamphlet 

with a phone number and website information, I had no idea that it was false information. After she entered my information in her ipad she 

proceeded to call a customer service number to make sure that I was signed up. She went through a lot of prompts on her phone and 

asked me to respond to a few of the prompts. The she asked me to sign three different times to make sure that I was getting the correct 

energy supply. I kept asking her if I was going to get a bill from the company. She kept insisting that I was only signing up for clean energy 

and that all my information and billing would still come from Eversource. She even showed me a website with company information when 

I asked. Now I know that it was a false website. She also mentioned that by signing up for clean energy, the way I would be charged for 

electric would not change with the fluctuating market. She said I was locked in for 24 months at a fixed rate. She mentioned that if I 

moved then contact them and they will make sure I am still receiving clean energy. She also mentioned that by signing up I would get a 

choice of a $25 gift card to Target, Amazon, or a Visa gift card. When I gave her my email address she said that I would be receiving an 

email with the details of the plan and I should check my inbox when she left. She also said that I was going to get information in the mail 

too. She said that nothing was going to change with my Eversource bill except now my energy will be coming from wind rather than a 

power plant.

Consumer is on the DNCR, but is still receiving calls from Liberty Power wanting to get him to switch to their service. He's told them to 

stop, but they continue to call him. The Caller ID doesn't show their number.

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 7 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 54 of 70
08/23/2017 CYPRESS TX 40 - 49 |918 |7867071

09/21/2017 Streetsboro OH 30 - 39 Liberty Power 866 7693799

10/05/2017 Chicago IL 30 - 39 Liberty Power 866 7693799

10/12/2017 Garfield Heights OH 40 - 49 Liberty Power

10/13/2017 Waban MA 80 and Over Liberty Power 866 7693799

11/07/2017 IL Liberty Power 510 7672676

11/17/2017 Natick MA 65 - 69 Liberty Power 877 3824357

12/29/2014 BRIDGEPORT PA Liberty Power 866 7693799

12/20/2017 Greenwich CT 50 - 59 866 7693799

01/12/2018 Boston MA 70 - 79 Liberty Power 866 7693799

01/19/2018 Elyria OH 60 - 64 Liberty Power

04/03/2018 IL 60 - 64 Liberty Power 866 7693799

Liberty Power Corp|

Federal Trade 

Commission

CFPB Sub product: Other debt --- CFPB Issue Type: Attempts to collect debt not owed | Debt was result of identity theft --- What 

Happened: it came to my knowledge that an account was opened in my name with Liberty Power Corp, at this time i had and still do have 

an account with Reliant Energy, so i called my Utility Company and informed them i did not give anyone power to transfer my electricity 

and this was fix, so i thought until i started getting calls from Collection Agents. --- Fair Resolution: close out account and not report to my 

credit as this would be a violation of fair credit reporting act

Consumer states that she wanted to make a report against an individual who came to her stating to be from Liberty Power telling her they 

can give her a quote. Consumer shoed her a bill and the individual took it down. Consumer believes it was a scam.

Two men from Liberty Power knocked on my apartment door and told me I needed to show them my ComEd bill so that they could verify 

my service. Since I live in a secured building, I believe that they were official. I questioned it several times and they said I did not have a 

choice, they needed to verify my bill for ComEd. When I gave it to them, I asked them many times to explain what they needed and why, 

but I did not understand. They seemed to keep changing what they said they needed from me. They had me sign a tablet, telling me that 

nothing about my service or billing would change and that it was protecting my service to ensure the cost per kilowatt did not increase 

over time. I said I didn't care and didn't want anything to change about my service or billing. They said I needed to do this anyway. They 

asked a lot more questions about my contact information and then had me fill out a survey confirming that they did their job. I was so 

confused that I contacted my landlord, who then told me they were solictiors, they are not with ComEd and they are not allowed in the 

building. Now I am trying to find out what they are doing with my information and if they are changing my service. This was a total scam 

that I did not understand until someone sent me an article about it afterward. Other-Other Update

a young man came to my door at 7:35 or so. he was acting like he was with the power company i signed up for at my apartment. he 

stated he wanted to see if things were correct on my bill. he was wearing a Liberty Power polo and name tag. we have First Energy. i did 

not show him my bill. he stated when i signed up i was supposed to get a gift card for pizza hut. i told him i did not want the card. OtherOther Update

Consumer received a phone call stating to be from Liberty Power offering utility offering a lower rate. Consumer refused what he is 

currently paying and they started to provide a plan higher than what he is currently paying. Consumer was sent a plan description 

enrollment by mail, consumer did not comply.

Indian accent telling you that your electric rate is locked in. Also offering a $200 Visa gift card. IsVictim:true --- Initial Means of Contact: 

Unknown

consumer reported that Liberty Power has ben contacted her asking her to change her service to them, they have also posed as her 

service provider which is Ever Source stating that they will be sending her a gift card.

Note: Please note that the Consumer Sentinel Network cannot presently categorize this data contributor's Product Service Code. The 

comments field may have a description of the good or service offered to the consumer. --- Received letter from Liberty Power with a copy 

of my forged signature stating I agreed to switch energy companies. I have never had contact with them. On 12/13/14 I received a letter 

from Liberty Power stating I signed a contract to switch over power companies. The letter has my forged signature (which is misspelled) 

dated 12/5/14 at 2:18pm. I was at work at this time and date. I am a teacher and have documentation of this. I never had contact with this 

company and did not give them permission to switch over my energy/power services/supplier. My name was also misspelled on the 

contract several times. On 12/14/14 I contacted local Bridgeport, PA police and on 12/15/14 made a formal police complaint. When I 

attempted to contact the company that same week I was cut off four times. When I selected the option to pay my bill I was directed to a 

representative and when asked to speak to a supervisor I was placed on hold for 30 minutes and was disconnected again. Bridgeport 

officer Bailey stated when he attempted to contact the company he was unsuccessful and after further research it seems the company 

has many complaints against them. I was then advised to contact BBB and the Attorney General. --- Consumer desired outcome: Cancel 

my illegitimate/fraudulent contact with zero penalties and free credit monitoring services for one year due to the fact my signature was 

forged. I believe the solicitor who may have been going door to door to homes should be held accountable for forging my signature. --- 

The action taken by other agencies: made local police report; police attempted to make contact with company and was unsuccessful; was 

advised to contact AG and BBB --- Products Purchased: received a contract with my forged signature, did not give company permission 

to switch my energy supplier --- Consumer Age Range: 18 - 34

Liberty Power 

Holdings LLC

consumer reported that he generally deals with an electric company, he recently switched to Liberty Power Holding as his supplier, the 

company had stated they would charge him less then the service provider he had before, consumer has been receiving bills and the rate 

is not cheaper.

Consumer states that he rcv'd a call from Liberty Power offering utility services. He later discovered that this may not be legitimate. 

Liberty Power has no record of a call or the agent he spoke with. UPDATE 01/12/2018: The consumer called to update their complaint. 

GJONES

Consumer states someone from the company Liberty Power came to his trying to get him to sign up for service. Consumer states he 

declined the offer and the individual told him thanks for wasting his time. Consumer feels Liberty Power should not be soliciting their 

service.

I am writing on behalf of my son. He lives in a locked apartment building. Yesterday some sales (didn't realize this at the time) person 

got in the building and knocked on his apartment door. He could hardly understand the accent. They asked to see his ComEd bill and got 

his account number and address from his own bill. A very deceptive sales person, Alexandra Chiseliov told him ComEd is still delivering 

the electricity but they needed his signature on this device they were holding. They even tape recorded him saying he understood what 

he was doing. Obviously, he didn't. He then called me. While on the phone, this new company Liberty Power sent him the contract he 

just signed. He had no idea he was signing with a new company and cancelling his current company, ComEd. Liberty should be 

ashamed of themselves, going around soliciting unknowing people. I would like to know how they even got into the LOCKED building. 

My son is calling today to try to rescind the contract, if he can get a hold of someone. In the meantime, I have looked up this company 

and there are many complaints about Liberty Power and their deceptive practices. If you have any advice on what other steps should be 

taken, please let me know. Thank you. Other-Other Update

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 8 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 55 of 70
Other Information Comments

Y MA 978 2160136 04/03/2018

Y Palos Hills IL Liberty Power 000 0000000 03/28/2018

Y Tiverton RI Liberty Power 866 7693799 03/27/2018

Y NJ Liberty Power 973 5590796 03/22/2018

N NY liberty power 718 3424534 03/19/2018 they use several phone numbers to make their calls --- Subject matter of the call: Energy, solar, & utilities

N NY liberty power 718 3424534 03/19/2018 they use several phone numbers to make their calls --- Subject matter of the call: Energy, solar, & utilities

Y Springfield MA Liberty Power 954 7711463 03/16/2018

Y Rockford IL Liberty Power 954 7711463 03/13/2018 Other Information Comments

N IL 630 3586242 03/12/2018

Y Crofton MD Liberty Power 03/07/2018 Subject matter of the call: Energy, solar, & utilities

Y Morrison IL Liberty Power 954 7711463 03/06/2018 They call daily for about the last month. I answered once and told them to quit calling, but they continue to call. --- Subject matter of the call: Energy, solar, & utilities

N stamford CT liberty power 954 7711463 02/27/2018 Subject matter of the call: Energy, solar, & utilities

Y Budd Lake NJ Liberty power 02/27/2018

Y Budd Lake NJ Liberty power 02/24/2018

Y Trenton IL Liberty Power 954 7711463 02/16/2018

Y PA Liberty Power 954 7711463 02/15/2018 Liberty Power calls EVERY day, sometimes twice. This has been going on for months. Thanks for your help. --- Subject matter of the call: Dropped call or no message

Y watertown MA 857 2457945 02/14/2018 Subject matter of the call: Energy, solar, & utilities

Y watertown MA 857 2457945 02/09/2018 Subject matter of the call: Energy, solar, & utilities

Y watertown MA 857 2457945 02/09/2018 Subject matter of the call: Energy, solar, & utilities

Y MA Liberty Power 954 7711463 01/30/2018

Y Jerseyville IL Liberty Power 01/25/2018

Y Rockland MA Liberty power 954 7711463 01/23/2018 Subject matter of the call: Energy, solar, & utilities

Y CT Liberty Power 954 7711463 01/19/2018 Subject matter of the call: Energy, solar, & utilities

Y Willowbrook IL 872 2104369 01/17/2018 Calls 1-3 times a day for last few weeks. Have asked repeatedly to remove this number from their call sheet. --- Subject matter of the call: Energy, solar, & utilities

Y IL Liberty Power 954 7711463 01/11/2018

Y Pekin IL Liberty Power 877 4367161 01/09/2018 We've asked them to stop calling and they've continued to contact us on multiple occasions. --- Subject matter of the call: Energy, solar, & utilities

Y milford MA liberty power 866 7698799 01/06/2018 called them and asked them to stop calling yet they continue. --- Subject matter of the call: Energy, solar, & utilities

Y watertown MA 857 2457945 12/12/2017

Y watertown MA 857 2457945 12/12/2017

Y Frankfort IL Liberty Power 12/09/2017

Y IL Liberty Power 773 6256601 12/06/2017 Subject matter of the call: Energy, solar, & utilities

Y Lockport IL Liberty Power 12/04/2017

Y CA Liberty Power 877 4367161 11/28/2017 Telemarketing is persistent and harassing me !! --- Subject matter of the call: Energy, solar, & utilities

Y Everett PA Liberty Power 954 7711463 11/28/2017 Subject matter of the call: Energy, solar, & utilities

Y Woodbury CT Liberty Power 203 8771310 11/27/2017 Subject matter of the call: Energy, solar, & utilities

Phone In 

Registry?

Consumer 

Address, 

City

Consumer 

Address, 

State

Company 

Name

Company 

Phone, Area 

Code

Company 

Phone, 

Number

Other 

Information 

Complaint 

Date

Liberty Power 

Company

They called us at least 10 times a day, I called them 3 times and asked to remove our number they advised us that they will but 10 minutes later would call us back. --- Subject 

matter of the call: Energy, solar, & utilities

After repeatedly telling these callers, telling them we are not interested, they keep calling - on March 27 they called ten times! Annoying does not describe the calls - and when 

we've tried to reason with them, we barely understand them anyway. When asking for a name, the response was "Mike." Our understanding is that the do not call registry 

prevents these calls. Why do they keep happening. Ten calls on March 27 is not the only day - it was the worst day. We have received these calls over a period of months. 

Please please make them stop!!! --- Subject matter of the call: Energy, solar, & utilities

These people have been called me every day for the last month. I asked him not to call me anymore. I'm elderly and sick. These nuisance calls a very aggravating --- Subject 

matter of the call: Energy, solar, & utilities

Liberty Power 

Holdings LLC

Company calls at least 4 times a week or even 4 times on the same day. It keeps showing up on my iPhone as a possible "scammer" so I do not pick up , but an automatic 

voice message keeps leaving me messages from that states they are Liberty Power Holdings LLC company. Tried blocking the company but they keep calling from different 

numbers. Please help. --- Subject matter of the call: Energy, solar, & utilities

I gave them information about my account and they were offering less payments for me. I had just been out of the hospital and not thinking straight. They called me 3 times to 

say yes to go through with the transfer and offered me a $200 visa. Someone in the background was yelling say yes and when I hung up, they called 3times while I was at the 

doctor’s. My friend even witnessed that. I blocked them for the rest of the day and checked out their history and they are known to get customers to lock in 24 months and 

charge higher prices. That is exactly what happened with me. I would have been locked in for 24 mos. , but PS&G still we’re responsible for services. What company does 

that? I unblocked this morning and sure enough, they called and I heard someone in the background saying,”say yes”. I told them I say no to anything from their company 

and do not allow them to be my new company. I will call PSE&G to make sure the switch does not happen. Not Approved! --- Subject matter of the call: Switching over to liberty 

power and receive $200

I gave them information about my account and they were offering less payments for me. I had just been out of the hospital and not thinking straight. They called me 3 times to 

say yes to go through with the transfer and offered me a $200 visa. Someone in the background was yelling say yes and when I hung up, they called 3times while I was at the 

doctor’s. My friend even witnessed that. I blocked them for the rest of the day and checked out their history and they are known to get customers to lock in 24 months and 

charge higher prices. That is exactly what happened with me. I would have been locked in for 24 mos. , but PS&G still we’re responsible for services. What company does 

that? I unblocked this morning and sure enough, they called and I heard someone in the background saying,”say yes”. I told them I say no to anything from their company 

and do not allow them to be my new company. I will call PSE&G to make sure the switch does not happen. Not Approved! --- Subject matter of the call: Switching over to liberty 

power and receive $200

This energy supplier, Liberty Power, has been calling me constantly as of November/December 2017. I have not NOT confirmed them as my energy supplier. I have a caller ID 

in my home phone and an answering machine. They have not left one message, at any time, in my answering machine. I have called Ameren Illinois today for information 

about this situation. They gave me some tips and to call "Do Not Call List" with a phone number for complaints. I have had several different energy suppliers come up to my 

door to apply me into their supplier at a cheaper and better energy rate. I have told them I am NOT interested, but they continue to insist. That is why I called Ammeren Illinois 

today to put to a stop to this annoying situation. I do not want Liberty Power to call me again starting today. I have NOT confirmed them as my energy supplier all this time. --- 

Subject matter of the call: Energy, solar, & utilities

Mechanicsb

urg

Liberty Power 

Company

Liberty Power 

Company

Liberty Power 

Company

This utility has called my everyday for 6 months. Nomorobo stops the call from coming through, but it hasn't stopped them from calling. I also have it blocked with Xfinity and 

yet they call everyday! --- Subject matter of the call: Energy, solar, & utilities

Liberty Power 

Co.

Liberty Power 

Company

This number calls up multiple times per day, and it seems to be getting to be more frequent. There is never anyone on the line, so I can't simply ask them to stop calling. 

Please help!! --- Subject matter of the call: Energy, solar, & utilities

Liberty Power 

Company

This number calls up multiple times per day, and it seems to be getting to be more frequent. There is never anyone on the line, so I can't simply ask them to stop calling. 

Please help!! --- Subject matter of the call: Energy, solar, & utilities

8667693779

9

Mount 

Prospect

Robocall, and I Pressed 1 to talk to agent to ask to get my number removed, but didn't get that far in the conversation. He told me that the company is in Ft. Lauderdale, FL, 

and was struggling to figure out how his company got my number, then the connection was broken. I bet his supervisor/trainer cut it off. He's supposed to ask questions, not 

answer them. --- Subject matter of the call: Energy, solar, & utilities

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 9 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 56 of 70
Y PA Liberty Power 954 7711463 11/24/2017

Y Brockton MA Liberty Power 954 7711463 11/22/2017

Y IL Liberty Power 510 7672676 11/21/2017

Y Rockland MA Liberty power 954 7711463 11/21/2017 They called twice a day for the last week.

Y Franklin Park IL Liberty Power 866 7693799 11/13/2017

Y ELMHURST IL Liberty Power 954 7711463 11/13/2017

Y Milford CT Liberty power 954 7711146 11/10/2017

Y Whitehall PA Liberty Power 866 7693799 11/09/2017

Y IL Liberty Power 708 7192041 11/03/2017 Seems like a legitimate business that is ignoring the do not call list. --- Subject matter of the call: Energy, solar, & utilities

Y So.Attleboro MA 954 7711463 11/02/2017

Y PA Liberty Power 954 7711463 10/31/2017

Y Berlin MA Liberty Power 954 7711463 10/26/2017

Y Stamford CT Liberty Power 954 7711463 10/24/2017

Y CHICAGO IL 816 8489318 10/24/2017 Subject matter of the call: to save money on com.ed w/Liberty Power Holdings

Y MA Liberty Power 954 7711463 10/13/2017 Subject matter of the call: Energy, solar, & utilities

Y Belleville IL Liberty Power 954 7711463 10/10/2017 I have asked this company to stop calling, I am not interested in their product. --- Subject matter of the call: Energy, solar, & utilities

Y Coatesville PA 954 7711463 10/09/2017 Subject matter of the call: Energy, solar, & utilities

Y Belleville IL Liberty Power 954 7711463 10/09/2017 I have asked this company to stop calling several times and I do not wish to use their energy source. --- Subject matter of the call: Energy, solar, & utilities

Y IL 954 7711463 10/06/2017

Y IL Liberty Power 877 4367162 10/06/2017 Subject matter of the call: Energy, solar, & utilities

Y Benton IL 954 7711463 10/06/2017 I have asked this company to stop calling me and they keep calling. --- Subject matter of the call: Energy, solar, & utilities

Y Tiskilwa IL Liberty Power 866 7693799 10/06/2017 Subject matter of the call: Energy, solar, & utilities

Y IL Liberty Power 708 6408016 10/05/2017 Asked several times to stop calling very rude reps --- Subject matter of the call: Energy, solar, & utilities

Y IL Liberty Power 773 2693294 10/05/2017 I have asked several times for the past year to stop calling me --- Subject matter of the call: Loan

Y Belleville IL Liberty Power 954 7711463 10/05/2017 I have told this company that I do not want their product and to stop calling. --- Subject matter of the call: Energy, solar, & utilities

Y Belleville IL Liberty Power 954 7711463 10/05/2017 I have asked this company to stop calling several times. --- Subject matter of the call: Energy, solar, & utilities

Y Belleville IL Liberty Power 954 7711463 10/05/2017 I have informed this company that I do not want their product and to stop calling. --- Subject matter of the call: Energy, solar, & utilities

N Delmar NY 315 2932714 10/04/2017 I have been asking them to take me off the list and stop calling me for almost a year. --- Subject matter of the call: Energy, solar, & utilities

Y Rochester NY Liberty Power 646 8449759 09/27/2017 They call non stop. I've never done business with them. --- Subject matter of the call: Energy, solar, & utilities

Y Des Plaines IL Liberty Power 954 4349390 09/26/2017

Y BROOKLYN NY Liberty Power 954 7711463 09/26/2017 Subject matter of the call: Energy, solar, & utilities

Y Rochester NY Liberty Power 646 8449759 09/26/2017 They call non stop. I've never done business with them. --- Subject matter of the call: Energy, solar, & utilities

Y Worcester MA Liberty Power 954 7711463 09/25/2017

Y IL Liberty Power 877 4367162 09/25/2017 This company calls multiple times a year and we've asked them to stop before. --- Subject matter of the call: Energy, solar, & utilities

Y CT Liberty Power 954 7711463 09/24/2017

N Rochester NY Liberty Power 646 8449759 09/20/2017

Y Springfield MA Liberty Power 954 7711463 09/18/2017 I have asked this company to stop calling several times and they keep calling!!! --- Subject matter of the call: Energy, solar, & utilities

Y Benton IL 954 7711463 09/15/2017 Subject matter of the call: Energy, solar, & utilities

Y Rochester NY Liberty Power 646 8449759 09/13/2017 Many calls --- Subject matter of the call: Energy, solar, & utilities

Y Rochester NY Liberty Power 646 8449759 09/13/2017 Many calls --- Subject matter of the call: Energy, solar, & utilities

Y Rochester NY Liberty Power 646 8449759 09/13/2017 Non stop calls. Has been told to stop. --- Subject matter of the call: Energy, solar, & utilities

Y Rochester NY Liberty Power 646 8449759 09/13/2017 Call almost every day after being told to stop. --- Subject matter of the call: Energy, solar, & utilities

Y Rochester NY Liberty Power 646 4959811 09/13/2017

Y Fairfield CT 475 2820592 09/13/2017

NORTHAMP

TON

LIBERTY POWER HAS BEEN CALLING ME EVERY WEEK, FOR THE PAST 2MONTHS. SOME WEEKS THEY CALL TWO OR THREE TIMES.THEY JUST WON'T TAKE 

ME OFF THERE LIST, TO SPOT CALLING. --- Subject matter of the call: Energy, solar, & utilities

THIS UTILITY COMPANY CALLS EVERY DAY. ON AT LEAST TWO OCCASIONS I HAVE ASKED THEM TO CEASE AND DESIST. AT THAT POINT THEY HANG UP 

WITHOUT COMMENT. --- Subject matter of the call: Energy, solar, & utilities

Liberty power has contacted me about 5 times within the past few months. Each time I have asked them to remove my number and then they say “sure” or just hang up. The 

last representative who called on 11/10/17 stated she was sending an email to have my number removed. I asked who she was sending the email to butvshe would not advise. 

--- Subject matter of the call: Energy, solar, & utilities

Over the last few years, this company has been verbally harassing my dad (name listed above). He has dementia and they are trying to take advantage of his condition to 

obtain business. --- Subject matter of the call: Energy, solar, & utilities

Elk grove 

village

Liberty Power 

Co

This company has been reported on here before & not only have they NOT stopped,They are now calling twice a day.I have asked them to stop.Explained we have no 

business with them.I also stated how they are harassing calls.They were told they would be reported to the Better Business Bureau & a class action suit should be sought after 

against them.Most companies stop calling.There is no reason this company needs to call here daily & repeatedly.The number provided in this complaint should be shut down 

for fraud!I do hope this will stop or else this registry is worthless. The Company name being used in the calls ARE NOT any company I have done business with or will do. --- 

Subject matter of the call: Energy, solar, & utilities

NORTHAMP

TON

They been calling every day now, for 2 weeks. Driving me nuts. I asked them to stop calling, but they won't. I asked to be taking off there list. Guess they won't. Please stop 

them from calling. Thank you very much. --- Subject matter of the call: Energy, solar, & utilities

Liberty Power has been asked on several occasions to stop calling my cell phone number. And each time they say they will take me off their telemarketing list. But they are still 

calling me constantly. Please help and stop these annoying calls. Thank you --- Subject matter of the call: Dropped call or no message

These guys call 5-10 time per day. We had used them last year when we figured out it was a scam. There are multiple scams from these people reported. --- Subject matter of 

the call: Energy, solar, & utilities

Liberty Power 

Savings

Liberty Power 

Co.

Liberty Power 

Corporation

This electric power company over charges and I don't want them to call here trying to regain their service here. I have told them not to call here and that this number (b)(6) is 

on the do not call list. Please make them stop calling. Thank you

Liberty Power 

Corporation

West 

Dundee

West 

Dundee

Liberty Power 

Co

In the past week I have asked three different people to take my name and number off the call list for this company. No one seems to get the message. Instead of the 3 to 5 

calls a day I am getting one when I want NONE.I don't know what else to do to stop these annoying calls. Please help. --- Subject matter of the call: Energy, solar, & utilities

I called them 9/21/17 at 7:03PM and requested they stop calling me. The person who took my call said that he entered my number as "do not contact" in their computer. But, I 

received a phone call again today. The person calling said there was no such information. Moreover, the company called me from the same number: 9/21 (6:09pm), 9/19 

(6:46pm), 9/15 (5:35pm), 9/15 (4:47pm) --- Subject matter of the call: Energy, solar, & utilities

This company is harassing me to do business with them. I clearly tools them I'm not interested. They have deep foreign accents. They call me daily. --- Subject matter of the 

call: Energy, solar, & utilities

Liberty Power 

Corp

I don't know why they keep calling. I have asked adamantly to stop. Many different phone numbers. Very unprofessional and can barely speak English. --- Subject matter of 

the call: Energy, solar, & utilities

Calibrus on 

behalf of 

Liberty Power

Telemarketers called me to try to get me to switch my electricity generation provider to Liberty Power. They offered me a $0.12060/kwh rate for 12 months. It took me a while 

for them to tell me which company they are calling from. It turns out they are calling from Calibrus telemarketing, as I finally got the name "Bella" and her company name, 

"Calibrus." They would only give me a callback number of 866-POWER99, which is the number for Liberty Power. --- Subject matter of the call: Energy, solar, & utilities

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 10 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 57 of 70
Y IL Liberty Power 09/12/2017 He wouldn't give the company phone number --- Subject matter of the call: Energy, solar, & utilities

Y Walnut Hill IL Liberty Power 954 7711463 09/01/2017 This happens at least 2 times a day --- Subject matter of the call: Energy, solar, & utilities

Y Bingahmton NY Liberty Power 09/01/2017 Subject matter of the call: Energy, solar, & utilities

Y IL 08/30/2017 THey call 2-3 times a day. EVERY DAY. We have asked them to stop and they do not. --- Subject matter of the call: Energy, solar, & utilities

Y IL Liberty Power 866 7693799 08/30/2017 THey call 2-3 times a day. EVERY DAY. We have asked them to stop and they do not. --- Subject matter of the call: Energy, solar, & utilities

Y New Britain CT 866 7693799 08/28/2017 they have switched my utilities to them even after I said ABSOLUTELY NOT --- Subject matter of the call: Energy, solar, & utilities

Y Belleville IL Liberty Power 954 7711463 08/28/2017 I have told this company to stop calling me and that I do not need or want their product. --- Subject matter of the call: Energy, solar, & utilities

Y Lindenwold NJ Liberty Power 954 7711463 08/25/2017 Subject matter of the call: Energy, solar, & utilities

Y Belleville IL Liberty Power 954 7711463 08/24/2017 I have advised this company that I no longer need or want their service and to stop calling me. --- Subject matter of the call: Energy, solar, & utilities

Y Waltham MA 954 7711463 08/22/2017 This is the 3rd call in two days. I reported 1 of 2 calls yesterday. --- Subject matter of the call: Energy, solar, & utilities

Y Waltham MA 954 7711463 08/21/2017

Y IL Liberty Power 954 7711463 08/21/2017 Subject matter of the call: Dropped call or no message

Y MA 954 7711463 08/18/2017

Y Chicago IL Liberty Power 954 7711463 08/17/2017 This company calls me every day. Kept asking them to put me on their do not call list. --- Subject matter of the call: Energy, solar, & utilities

Y MA 954 7711463 08/17/2017

Y MA Liberty Power 957 7711463 08/17/2017 We get call from Liberty Power almost daily. We have NEVER asked them to contact us. We would like the calls to STOP. --- Subject matter of the call: Energy, solar, & utilities

Y Loves Park IL Liberty Power 08/08/2017

Y IL 954 7711463 08/09/2017

Y Berlin MA Liberty Power 978 6311320 08/01/2017 Subject matter of the call: Energy, solar, & utilities

Y Berlin MA Liberty Power 617 6069240 08/01/2017 Subject matter of the call: Energy, solar, & utilities

Y Berlin MA Liberty Power 774 6338031 08/01/2017 Subject matter of the call: Energy, solar, & utilities

Y Berlin MA Liberty Power 718 5772849 08/01/2017

Y Lawrence MA Liberty Power 954 7711463 07/31/2017

Y MA Liberty Power 954 7711463 07/28/2017

Y Beach Park IL Liberty Power 510 7672676 07/20/2017 0 --- Subject matter of the call: electric savings

Y bensalem PA liberty power 877 2899925 07/20/2017 they call all the time --- Subject matter of the call: Energy, solar, & utilities

Y MD 954 7711463 07/07/2017

Y IL Liberty power 508 2021270 07/05/2017 Call wanting us to change electric company. Numerous times 3-4 a day --- Subject matter of the call: Energy, solar, & utilities

Y Springfield MA Liberty Power 954 7711463 06/29/2017 Subject matter of the call: Energy, solar, & utilities

Y Bowie MD 877 2899925 06/27/2017 Subject matter of the call: Energy, solar, & utilities

Y Orleans MA liberty power 866 7693799 06/22/2017 I get about 10-20 calls a week from energy companies and have been o the do not call list since 2003 --- Subject matter of the call: Energy, solar, & utilities

Y MD Liberty Power 877 2899925 06/21/2017 Subject matter of the call: Energy, solar, & utilities

Y Brooklyn NY Liberty Power 718 5147113 06/21/2017 I have asked them twice already to stop calling, and they keep calling trying to sell me their utility service. --- Subject matter of the call: Energy, solar, & utilities

Y Woodbury CT Liberty Power 877 2899925 06/20/2017

Y huntingtown MD liberty power 877 2899925 06/19/2017 Subject matter of the call: Energy, solar, & utilities

Y NY Liberty Power 718 5147113 06/16/2017

Y Belleville IL Liberty Power 954 7711463 05/26/2017 I have asked this company to remove my phone number, I do not want their services. --- Subject matter of the call: Energy, solar, & utilities

Y Liberty Power 05/22/2017

Y Chicago IL 708 8584095 05/20/2017

Y IL Liberty power 508 5236101 05/17/2017 Subject matter of the call: Energy, solar, & utilities

Y Brooklyn NY Liberty Power 857 9729380 05/02/2017

Y Blue Bell PA Liberty Power 877 2899925 04/30/2017 Subject matter of the call: Energy, solar, & utilities

Y CT 877 2899925 04/27/2017 Subject matter of the call: Energy, solar, & utilities

Y NY 866 7693799 04/20/2017 Subject matter of the call: Energy, solar, & utilities

Y Chicago IL Liberty Power 773 8405076 04/17/2017 Subject matter of the call: Energy, solar, & utilities

prospect 

heights

9544771146

3

Elk Grove 

Village

Liberty Power 

Co

Elk Grove 

Village

liberty power 

holdings llc

Liberty Power 

LLC

Liberty Power 

LLC

I stopped using this company in February 2016 and they have been hassling me ever since, and have told them on numerous occasions to not call me, I don't want their 

product. They call me daily. I'm sure I will be logging another complaint tomorrow. --- Subject matter of the call: Energy, solar, & utilities

Needham 

Heights

LIBERTY 

POWER

I am being bombarded by phone calls from this company. They have increased frequency from weekly to DAILY. I had written to them and I have repeatedly told them Do Not 

Call. I entered a complaint after their call yesterday. --- Subject matter of the call: Energy, solar, & utilities

Needham 

Heights

LIBERTY 

POWER

Up until about a year ago I canceled business with this company by mail, which they agreed. They continue to call frequently. Recently it has been weekly. This week I have 

received calls every day. I have REPEATEDLY asked them to stop and remove my name. --- Subject matter of the call: Energy, solar, & utilities

Hoffman 

Estates

Liberty Power 

Corp

Three time for last fours months they still calling to me and offering energy service. I asked manager and informed him to remove my cell number from his system and stop 

calling to me. No any results. Please register my message about it. Thank you. --- Subject matter of the call: Energy, solar, & utilities

I have been getting multiple calls from this company on a weekly basis. All from different phone numbers. I have asked them every single time to stop calling my cell phone 

and they still continue to do so. Getting really tired of these unwanted phone calls. Please try to help. Thank you Kim Gonzales --- Subject matter of the call: Energy, solar, & 

utilities

This company lied and said I agreed to go back to them as my electricity provider over a year ago. I had to jump through hoops to get them to admit I did not and give me a 

partial refund. They still call often, even though I have told them to stop calling and that I was on the do not call lists, I continue to get calls at least once a week. --- Subject 

matter of the call: Energy, solar, & utilities

South 

Weymouth

Have been receiving repeated calls since past 3 days. I had specified to them priorly that I am not interested in their product. --- Subject matter of the call: Energy, solar, & 

utilities

LIBERTY 

POWER

THIS IS A POWER COMPANY IN FLORIDA. I LIVE IN MARYLAND. THERE ARE COMPLAINTS AGAINST THIS NUMBER ON GOOGLE. THANK YOU. --- Subject matter of 

the call: Dropped call or no message

Chicago 

heights

Liberty Power 

Corp.

Asked to be removed from the list, man on the other end ignored my request and insisted that I tell him what our current rates are with the company we are currently using. I 

kept repeating myself asking to be removed and he refused and told me that he will call me back in an hour and hung up. --- Subject matter of the call: Energy, solar, & utilities

Liberty Power 

Electric 

Company/Inn

ovative 

Teleservices

Prairie du 

Rocher

I get calls from them once a week and have explained at least 5 times that utilities are no longer in my name and I would like my number removed from their list. --- Subject 

matter of the call: Energy, solar, & utilities

LIBERTY 

POWER

liberty power 

co

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 11 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 58 of 70
Y Roslindale MA Liberty Power 617 3901615 04/08/2017

Y PA 877 2899925 04/04/2017

Y IL 774 2411006 03/29/2017

Y Collinsville IL Liberty Power 954 7711463 03/27/2017

Y Olney MD Liberty Power 877 2899925 03/24/2017 Subject matter of the call: Energy, solar, & utilities

Y IN 954 7711463 03/21/2017

Y Hartford CT Liberty Power 818 6711881 03/18/2017 Call several times a week. --- Subject matter of the call: Computer & technical support

Y Chicago IL Liberty Power 917 7203952 03/14/2017

Y Chicago IL Liberty Power 917 7203952 03/14/2017

Y Philadelphia PA liberty power 954 7711463 03/13/2017

Y Indiana PA Liberty Power 877 4367162 03/10/2017 Subject matter of the call: Energy, solar, & utilities

Y CT Liberty Power. 860 3183501 03/09/2017

Y Lititz PA Liberty Power 877 7693799 03/07/2017

Y PA Liberty Power 877 2899925 03/06/2017 The person called several times in a row. This is a business number, and we asked them to stop calling us last year. --- Subject matter of the call: Energy, solar, & utilities

Y CT 866 7693799 02/28/2017

Y CT Liberty Power 866 7693799 02/24/2017

Y Rockford IL Liberty Power 02/23/2017

Y Thomaston CT Liberty Power 510 7672676 02/14/2017

Y Hartford CT Liberty Power 877 2899925 02/13/2017 THEY call DAILY. Continuously. --- Subject matter of the call: Energy, solar, & utilities

Y Canton IL Liberty Power 309 3001010 02/07/2017 Subject matter of the call: Energy, solar, & utilities

Y IL Liberty Power 309 3001010 02/07/2017 Speaker was from India. --- Subject matter of the call: Energy, solar, & utilities

Y PA Liberty Power 877 2899925 02/06/2017

Y Greenfield MA 508 3421563 02/06/2017

Y Bloomfield CT Liberty Power 866 7693799 02/04/2017

Y PA Liberty Power 877 2899925 02/01/2017 Subject matter of the call: Energy, solar, & utilities

Y Fairfield CT Liberty Power 866 7693799 02/01/2017

Y Danbury CT Liberty Power 866 7693799 01/30/2017 They keep calling many times per month. Phone number on caller id is 203-308-4672 --- Subject matter of the call: Energy, solar, & utilities

Y Pinckneyville IL Liberty Power 866 7693799 01/27/2017

Y WALDWICK NJ 312 2196131 01/27/2017 These calls are excessive. --- Subject matter of the call: Warranties & protection plans

Y Berwyn PA Liberty Power 216 4169188 01/25/2017

Y Branford CT Liberty Power 866 7693799 01/23/2017

Y Branford CT Liberty Power 866 1693799 01/21/2017 Message said I could reduce my electric charges and to press 1 t speak with rep. Told them I was on Do Not Call list.

Y Wexfotd PA Liberty Power 877 4367162 01/19/2017 Subject matter of the call: Energy, solar, & utilities

Y Hartford CT Liberty Power 877 2899925 01/17/2017 They have called many times. --- Subject matter of the call: Energy, solar, & utilities

Y Roselle IL Liberty Power 217 2804261 01/05/2017 They call every 2-3 months, I tell them I'm not interested and to stop calling --- Subject matter of the call: Energy, solar, & utilities

About 2 or 3 years ago I signed up as a consumer with Liberty Power. For several months now they have been harassing me with phone calls. They call to try to get me to sign 

up with them. I let them know that I'm already on eod their customers. The calls continued. I then asked them not to call me anymore and to remove my number from their 

system. They began calling from different numbers. Again I told them I'm already a customer, remove my number. Then they started calling me and speaking spanish. I told 

them to stop calling me. Now they call me from "Private Numbers". I told them to stop calling me, I'm going to end my business with them, and I will be reporting the harassing 

phone calls. They call at random, at any time of day. These phone calls are causing me distress and anxiety. --- Subject matter of the call: Energy, solar, & utilities

HARLEYSVI

LLE

LIBERTY 

POWER

I HAVE ASKED THEM AT LEAST 6 TIMES OVER THE PAST 2 MONTHS TO NOT CALL AND THAT I AM ON A DO NOT CALL LIST. THE TIME THEY CALLED IS NOT 

EXACT. --- Subject matter of the call: Energy, solar, & utilities

Liberty Power 

/ Comed

Liberty Power called saying it was Comed and that I am to receive a subsidy through Federal Deregulation Law. They said that they are the supplier of Comed's power and the 

call was being recorded. I asked if this is legitimate, and he said yes it is and it regarding the Federal Deregulation law. They said from the law, I would received a subsidy with 

a better, fixed price for 2 years. They also said they were sending me 2 Visa gift cards. Then they asked me to bring up my bill for my Account # and asked me to verify by 

billing address. They transferred me to another number and I hung up the phone since it said I was switching to Liberty Power (which I was not aware that they were doing). 

They have now called me at least 6 times in the last 10 minutes. --- Subject matter of the call: Energy, solar, & utilities

Someone from their company signed me up for their "energy savings" awhile back without my consent. Once I learned of this, I cancelled them. I have been repeated called for 

the past 6 mths and have repeated asked them to stop calling me each time they call. I have also sent over an email to them last week in regards to this, they promised to stop 

but the calls are still coming. --- Subject matter of the call: Energy, solar, & utilities

Liberty Power 

TX Holdings 

LLC

I have not yet answered the phone, but have done research on the number. I live in Indiana, not Florida. They've no reason to be calling me. They've called me 4 times within 

the last 2 business days without leaving a message. --- Subject matter of the call: Energy, solar, & utilities

Liberty power continues calling from the following numbers. 9177203952, 7184465272, 8574534018, 6174090084, 6465938644. --- Subject matter of the call: Energy, solar, & 

utilities

Liberty power continues calling from the following numbers. 9177203952, 7184465272, 8574534018, 6174090084, 6465938644. --- Subject matter of the call: Energy, solar, & 

utilities

I got a call from them a week ago and requested to be added to their do not call list, yet they have called me twice since I've made that request. --- Subject matter of the call: 

Energy, solar, & utilities

Pomfret 

Center

Caller ID:W CORWALL CT starred with robocall saying I could get a discount on my Eversource bill Pressed 1 Got a human Asked 3 times for name of company Finally told 

me Liberty Power I said not interested and requested they stop calling. --- Subject matter of the call: Energy, solar, & utilities

Spoke with "Nick" (probably not his real name). I have never done business nor do I desire to do business with Liberty Power or it's affiliates. --- Subject matter of the call: 

Energy, solar, & utilities

Liberty Power 

Corp, LLC

The caller ID showed 203-409-0839, a local number. That number is no good. I answered a robo call. I played along and finally a live person got on the line. After I acted 

very interested in switching to their company for electricity, I kept asking questions. The boiler room person must be new because over time I was able to coax out of him the 

name of the company that he wanted me to switch to as a new electricity provider. As soon as he disclosed "Liberty Power Corp" I overhead a colleague of his yell at him to 

hang up. These people should be heavily fined and or shut down! --- Subject matter of the call: Energy, solar, & utilities

Phone number did not show up in my caller ID. This is second time this company has called and told me they received a notice I am a customer which is not correct. And I 

told them such and to put me on the do not call list for a second time. --- Subject matter of the call: Energy, solar, & utilities

This company keeps calling me and i have asked them to stop. I gave them my daughters phone number 203-509-5798 and they called her. She asked them to put me on no 

call list and they refused and wanted to discuss why we are requesting that. Please call my daughter, i am 88 and on a fixted income. --- Subject matter of the call: Energy, 

solar, & utilities

The people call my home at least once per day. They also call us at work one or more times per day. I've asked them to take my number off their list. They agree to do it but 

three years later...they are still calling. --- Subject matter of the call: Energy, solar, & utilities

liberty power 

green 

energies

.This call was made to my 95 year old Father in law, Leo Novarr. He is on the do not call registry. I am not sure of the exact date of the call. They changed is electric supplier. 

Please give me a call if you have any questions. Thanks. (b)(6) --- Subject matter of the call: Energy, solar, & utilities

A third-party working on behalf of Liberty Power in the State of CT calls to try to get me to switch my electricity energy supplier. They call from disconnected phone numbers: 

203-308-4672 and 774-241-1006. The robo call says press 1 to talk to a representative and press 2 to be removed from the list. I've pressed 2 multiple times. I've pressed 1 

and asked to be removed (they immediately hang up). I've pressed 1 and yelled. My number has been listed in the National Do Not Call Registry since 21-MAR-2012. Today 

I spoke with Liberty Power Vice President of Law and General Counsel Mr. Harris Rosen. Phone number: 954-598-7061. He was sympathetic to my concerns but made it 

clear that it is a third-party calling me trying to get a commission by connecting me to Liberty Power. Companies like Liberty Power that deploy this tactic should be held 

responsible when the fly-by-night third-parties can not be policed. --- Subject matter of the call: Energy, solar, & utilities

The number called and listed above is for my mother, (b)(6) at (b)(6), Pinckneyville, IL. She is 88, has Alzheimer's, and can't make decisions about switching her electric 

provider. I'm not sure if she switched it tonight or not, but she has done so twice before. The time of the call is approximate, since I was not there, and she doesn't have caller 

ID. My brother has twice told them not to call her, yet they continue to do so. They said they would not call her again, but that was obviously a lie. I believe they are preying 

on the elderly. She has been on the do not call list for years. I believe there should be severe consequences for repeated violations such as this. My phone number is (b)(6), 

and my email address is (b)(6) Thank you for your help. --- Subject matter of the call: Energy, solar, & utilities

Liberty Power 

or Liberty 

Energy

First call of the day was @ 2:28PM, told caller we had requested many times to be taken off their list and not to call again. 2nd call was 5 minutes later, it was the same 

individual. He said "You did not answer my question" again, I told caller to take our number off of his list. --- Subject matter of the call: Energy, solar, & utilities

Electric power- complainant rec'd recorded message about saving on his electric bill- press '1' to speak with rep. C told them he was on the Nat'l DNC List. --- Subject matter of 

the call: Energy, solar, & utilities

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 12 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 59 of 70
Y Berwyn PA Liberty Power 877 2999925 01/04/2017

Y Needham MA Liberty Power 01/03/2017 Subject matter of the call: Energy, solar, & utilities

Y Woodbury CT Liberty Power 860 5808098 01/02/2017 Tried to sell me electricity. --- Subject matter of the call: Energy, solar, & utilities

Y hazleton PA liberty power 877 2899925 01/02/2017

Y Waterbury CT Liberty Power 860 5808098 12/30/2016

Y NJ Liberty Power 508 5236101 12/30/2016 Subject matter of the call: Energy, solar, & utilities

Y Phillipsburg NJ Liberty power 12/27/2016

Y Libertyville IL Liberty Power 773 8390188 12/21/2016

Y Dunellen NJ Liberty Power 508 5236101 12/20/2016

Y NY liberty power 877 4367162 12/16/2016 Arrogant SOB - Did not want to hear that I was on the Govt. DO-Not-Call list. He kept saying "That doesnt matter". --- Subject matter of the call: Energy, solar, & utilities

Y Easthampton MA Liberty Power 866 7693799 12/10/2016

Y Newton MA Liberty Power 5236101 11/25/2016 Indian caller tried to sell electric power contract --- Subject matter of the call: Energy, solar, & utilities

Y IL Liberty Power 877 2899925 11/22/2016 called asking for the person in charge of the power bill, unsolicited calls, i asked them to stop calling. --- Subject matter of the call: Electric Bill

Y IL Liberty Power 815 9245130 11/18/2016 I have requested a stop to all calls from this company but they continue to call multiple times a day. --- Subject matter of the call: Energy, solar, & utilities

Y MENDON MA Liberty Power 508 5236101 11/17/2016

Y Scotia NY Liberty Power 518 6312239 11/17/2016 Subject matter of the call: Energy, solar, & utilities

Y Lincolnwood IL Liberty Power 773 2450099 11/11/2016

Y Bellingham MA liberty power 978 6311895 11/10/2016

Y N Weymouth MA Liberty Power 508 5236101 11/07/2016 I have asked them multiple time to take me off of their list. --- Subject matter of the call: Energy, solar, & utilities

Y NJ 815 3154725 11/03/2016 Subject matter of the call: Energy, solar, & utilities

Y Milford PA liberty power 877 2899925 11/03/2016

Y IL liberty power 773 2450099 11/02/2016 Subject matter of the call: Energy, solar, & utilities

Y Cary NC Liberty power 815 3154725 11/01/2016 Subject matter of the call: Energy, solar, & utilities

Y LEESPORT PA 877 4367162 10/26/2016 This company calls us at least once a day and we have asked them several times to remove our name from their list. --- Subject matter of the call: Energy, solar, & utilities

Y Indianapolis IN Liberty Power 877 2899925 10/21/2016 Subject matter of the call: Energy, solar, & utilities

Y Evanston IL Liberty Power 866 7692799 10/19/2016 Subject matter of the call: Energy, solar, & utilities

Y Burlington MA Liberty Power 781 2021276 10/19/2016

Y Franklin MA Liberty Power 508 2021270 10/18/2016

Y Pittsfield MA Liberty Power 886 7693799 10/12/2016

Y Shrewsbury MA Liberty Power 978 6311895 10/12/2016 I am not sure if the woman was an employee of Liberty and an independent agent --- Subject matter of the call: Energy, solar, & utilities

Y WALDWICK NJ 732 3449172 10/11/2016

Y IL 309 7274474 10/05/2016 Subject matter of the call: Energy, solar, & utilities

Y Boston MA Liberty Power 413 2590127 10/03/2016

Y CT 203 6439344 10/03/2016

Y Marlborough MA Liberty Power 10/01/2016

Y Marlborough MA Liberty Power 09/29/2016

First call from Liberty Power was at 2:39, I asked to be removed from their list, mind you, they call us daily. They have been asked many times to be taken off the list. They 

immediately called back, it was still 2:39. The caller asked "what happened" and then hung up. The caller called a 3rd time at 2:40 and stood on the line without saying 

anything. --- Subject matter of the call: Energy, solar, & utilities

we have asked this company several times to stop calling us, and to put us on there do no call list, but they still call us every day. --- Subject matter of the call: Energy, solar, & 

utilities

This was a robo call at first. I had to select #1, to speak with pitchman. Once he came on, he would not let me speak for 2 minutes. Finally, I asked him who he was 

representing, and stated Liberty power. I asked how he received my number as it is registered in the do not call registry for over several years. He stated it was a random 

selection. I asked if he was aware that this was on the do not call registry. He said no. I told him I was reporting his number and he stated he was reporting my number as well. 

--- Subject matter of the call: Energy, solar, & utilities

The call was a robo call that asked if I wanted to hear about lowering my electric bill press 1. It was calling from an unknown caller and we receive a lot of theses calls. When I 

was connected I asked for the company name and the person I was speaking too. I was given the name of Jason Roberts from liberty electric. When i asked how he got my 

number an electronic voice came in and said "DNC" if the government is selling my number I want to know because I am going to reach out to my local congressman about 

this deceptive practice. Please provide a written explanation as to WHY I am am constantly receiving these calls. I thought the government was to protect it citizens from 

harassing phone calls and that was the purpose of the DI NOT CALLlist. Another waste of tax payers money going into some politicians pocket I guess maybe president elect 

Trump will do something about this but I doubt it --- Subject matter of the call: Energy, solar, & utilities

I am a senior citizen who is tired of being called by scammers. Prior complaints have not stopped these calls. The do not call registry appears to be a nonexistent protection 

measure. Does anyone ever do anything about these telemarketers and scammers? --- Subject matter of the call: Energy, solar, & utilities

The caller refused to provide a company address, but did say the company was from Fort Lauderdale, Florida before abruptly hanging up. A search I performed resulted in the 

following in that city: 1901 W Cypress Creek Rd., #600 Fort Lauderdale, FL 33309. --- Subject matter of the call: Energy, solar, & utilities

This is their real phone number: 866–769–3799 1901 W Cypress Creek Rd., #600 Fort Lauderdale, FL 33309 https://www.libertypowercorp.com Repeated calls to sell electric 

power under the Mass. competitive supply program. Callers say they're calling from Liberty Power's Ft. Lauderdale office, but the thick accents every caller speaks with 

suggest an off-shore call center. Callers say they use the federal no-call list but that many numbers that are supposed to be on it are "not visible" to them. They offer to put my 

number on their internal no call list, but the calls keep coming. --- Subject matter of the call: Energy, solar, & utilities

Saint 

Charles

Caller ID showed "Illinois Call". I punched 5 on their menu and asked a live person to remove this number from their calling list. --- Subject matter of the call: Energy, solar, & 

utilities

person called and asked to speak with person responsible for paying electric bill. i asked who they were. when i didn't recognize the company as the one i use i told the 

representative i was on the no call list. She hung up. why do i keep getting calls when i am on the list? --- Subject matter of the call: Energy, solar, & utilities

Liberty Power 

Supply

This company is calling us every day. They have been told multiple times to not call us and take us off the list. Our business, Yetter Insurance Agency, Inc, has 4 phone lines 

(and all are subscribed to the do not call). --- Subject matter of the call: Energy, solar, & utilities

Elk Grove 

Village

Liberty Power 

- Peter

"receive a discount on your Eversource bill". press#1 to speak with rep. I asked what company name was - indian accented guy said Liberty Power from Framingham MA. 

Asked to opt-out future calls. They continue to call me. 14x last few months. --- Subject matter of the call: Energy, solar, & utilities

I have been receiving call from this company every evening sometimes around 6:30 p.m, sometimes around 7 p.m sometimes as late as 8:30 p.m. I even asked them to 

remove my number from their registry, but they still keep calling me. The caller is most probably sitting somewhere in India and is really rude. I am really frustrated by this 

whole thing. Please shut down these guys --- Subject matter of the call: Energy, solar, & utilities

I don't feel like there is any action being taken against these companies. I report them and I am still getting two three sometimes as many as five or more calls a day! --- 

Subject matter of the call: Energy, solar, & utilities

Liberty Power 

or Liberty 

Energy

This company call my home and cell # almost everyday from a different phone number. I have asked them numerous times to remove my number from their list. It is getting out 

of control. If I block the number they call from, they continue to call from another number. --- Subject matter of the call: Energy, solar, & utilities

Liberty Power 

Co

they call me all they long i appears they are using a spoofing device to make the number local but when you call it it won't go through! I tell them every time not to call me but 

they keep calling!!! --- Subject matter of the call: Energy, solar, & utilities

Liberty Power 

(callerID: 

BRANDFORD 

CT)

I took the time to explain that I was on the DNC list and how the fines worked, but it didn't faze her one bit. She shrugged it off and kept on doing her pitch. --- Subject matter 

of the call: Energy, solar, & utilities

Company called 3x within a 20 minute span when I was on the phone. Finally took the call. Recording was about reducing EverSource cost. Waited for rep. Liberty Power. 

Rep refused to give me the phone number. Asked to be put on do not call list. --- Subject matter of the call: Energy, solar, & utilities

call from man w/ Indian accent. Said he was calling about a discount on electricity I aked him what company her was calling from. he said "an affiliate of Eversource" my elec 

provider. I asked again what company? "Liberty Power an associate of Eversource" I said no your not and he began to go on some explanation. I asked what I had to do to get 

this discount.He said" verify the name address and account number . I asked where is your company located? "he said "I am not going to tell you that, good bye" and hn 

located? he paused and said"Iam not going to tell you that good bye" and hung up Funny but my number is on the Do Not call List and this company is deceiving in its 

information to consumers

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 13 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 60 of 70
Y PA Liberty Power 866 7693799 09/29/2016

Y Danvers MA 508 2021270 09/28/2016 I spoke to a person and asked them to take me off of their calling list.

Y NJ Liberty Power 09/26/2016

Y Portland PA Liberty Power 877 2899925 09/22/2016 Caller Keeps calling here even though I told them I am on the do not call list and do not call this phone number. They call me twice a week and won't stop

Y PA Liberty Power 877 2899925 09/20/2016 3 calls in 3 weeks

Y Bridgewater MA Liberty Power 508 2021270 09/19/2016

Y Wyomissing PA Liberty Power 877 2899925 09/19/2016 I informed them I was on the do not call list and please do not call this number again .

Y Haddon Twp NJ Liberty power 908 3685132 09/16/2016 I believe they are a scam

Y Wayne NJ Liberty Power 973 2211145 09/14/2016 I have previously asked them to stop calling but yet they continue to call. Today I said hello 2-3 times and they just hung up on me.

Y PA Liberty power 877 2899925 09/12/2016

Y New Fairfield CT Liberty Power 203 6439344 09/09/2016

Y PA liberty power 717 2209125 09/09/2016

Y Brockton MA Liberty Power 413 2590127 09/08/2016

Y Wayne NJ Liberty Power 973 2211145 09/07/2016

Y Plainfield CT Liberty Power 203 6439344 09/07/2016

Y PA Liberty Power 717 2209125 08/31/2016

Y Framingham MA Liberty Power 508 2021270 08/30/2016

Y Ithaca NY Liberty Power 08/26/2016

Y Bethlehem PA Liberty Power 717 8598748 08/26/2016

Y Dracut MA liberty power 413 2590127 08/25/2016 The calls started back in January 2016, The caller continues to call offering to change the electric service, the caller only speaks Spanish, I have asked for the calls to stop

N Bellingham MA Liberty Power 508 5615075 08/19/2016

Y Boston MA Liberty Power 508 4590019 08/18/2016

Y Plymouth MA Liberty Power 508 8818573 08/16/2016

Y Brookline MA Liberty Power 781 7210347 08/15/2016

Y Belleville PA Liberty Power 866 7693799 08/12/2016

Y PA Liberty Power 724 6138531 08/10/2016

Y Nutley NJ Liberty Power 973 5848548 08/09/2016

Y Boston MA Liberty Power 866 7693799 08/05/2016

Y Brockton MA Liberty Power 781 7292582 08/04/2016

Y NJ 973 2211145 08/02/2016

Y PA Liberty Power 724 6318531 07/29/2016 3 different numbers have called all within a week saying they are representing Liberty Power. Have asked all 3 to add phone number to do not call list.

Y IL 866 7693799 07/26/2016

Y Greenfield MA Liberty Power 413 2590127 07/26/2016

Y Southwick MA Liberty Power 508 2021270 07/20/2016

Y Allentown PA Liberty Power 724 6354308 07/21/2016

Y Easthampton MA Liberty Power 07/21/2016

Y Belleville IL Liberty Power 866 7693799 07/18/2016

Y Chicago IL 804 4912130 07/18/2016

Y Austin TX Liberty Power 481 7210844 07/15/2016

Y Westville IL Liberty Power 847 3159265 07/15/2016

Y Chicago IL Liberty Power 815 3900015 07/12/2016

Mechanicsb

urg

Liberty Power keeps calling me to renew my contract with them. I am not renewing with them and have asked them each time they call (over 30 by now) to please stop calling 

me. They always say they will but they don't. Sometimes they call 5 times a day. I am trying to run a business and can't be bothered with a power supplier wanting to renew a 

contract that won't ever be renewed. Can you tell them to stop calling me because my words to them are useless. Thank you. --- Subject matter of the call: Energy, solar, & 

utilities

eversourse 

(Liberty 

Power)

We get frequent calls from Liberty Power. It starts with a recording, then transfers to a live operator. They at first imply they are with PSE&G, then after prodding admit they are 

with Liberty Power. We've requested to be removed from their list multiple times.

For the past three months Liberty Power has called me on average eight times per day. I have told them repeatedly to stop calling. When I ask for a supervisor they just hang 

up and call back four minutes later. They also call from 6174464090.

They called 3 times on 9/7, 12:47 PM, 4:04 PM and 8:07 PM 9/9 at 2:42 PM. They have called before, but I can only go back a few days. I have repeatedly told them to stop 

calling and take my number off their list. Please help!!!!

shiremansto

wn

this company has been calling for months they only want to speak Spanish I told them I'm on the do not call list but they continue to call. I believe they are using a device that 

makes up phone number to make it seem like they are local! if you try to call number back it won't work. They keep asking who is in charge of electric bill. PLEASE MAKE 

THEM STOP

I am tired of these harassing phone calls. I have told these people (can hardly understand them as they do not speak english very well) to STOP calling me as I have NO 

dealings with this company. It is VERY frustrating when these calls just keep coming. Don't we as AMERICANS have any rights anymore? Please help me to stop these calls

WEST 

MILTON

They are calling about my electric bill. I have never asked for anyone to call and I have never even checked out switching anything with my electric bill. The person calling 

does have a foreign accent but says they are based in Harrisburg PA

As with previous instances, this started as a robocall, and I pushed "1" to speak to a live operator to get the company name and tell them they were in violation. First, they 

denied that they had actually called - I asked how I was on the phone in that case. Then they denied that they were in violation while asking what was the DNC - I told them. 

They then asked why I had purchased a phone if I didn't want anyone to call. I asked to speak to a supervisor, and they hing up.

This company has continued to call us on multiple occasions despite our demanding to be removed from their call list. What good is the Do Not Call List we get a barrage of 

telemarketing calls. It almost seems like the Do Not Call List is actually a list for them to call from.

We continue to receive calls even though we have registered land line and cell phones to no call, what's the good? What ever the punishment, it doesn't seem to stop them 

from making unwanted calls to seniors like me.

This is about the 15th call from them. I get one just about every day. It is a recorded message saying "Press "1" to get my Eversource discount". I've pressed one and got a 

person and asked them to stop calling me or what company they are with and they usually hang up immediately. I finally got one of them to tell me the company name by 

playing along with them. They make it sound like they are with Eversource if you ask them who they are.

I have been receiving phone calls from this and other "authorized energy suppliers" several times a day. Most are robocalls when you press a number to connect to an actual 

person, and ask for their company name, they most often hang up. This is harassmentI am on the do not call list for a reasonbut these telemarketing robocalls for this, other 

companies like it, and other different companies are getting out of control! Please outlaw this practice! Thanks (b)(6)

This was a call that was used to fraudulently acquire access to the electricity account of seniors. The caller used the answers to questions to set up a "voice contract" despite 

the recipients being under the impression that it was an informational call.

Shippensbur

g

Called today at 1:19 pm. When I answered, I could hear the call center noises in the background but no one spoke to me. I hung up. Two minutes later they called again. 

This time there was a person - I told her this was a Don not call number. That I don't do business with them and they should stop calling. They previously called me on 8/5 

and I had told them the same thing on that call. They do not seem to want to stop bothering me.

Caller wanted me to change my electric generation company. Told caller I was not interested and asked to be removed from list. This was the same company that contacted 

me yesterday.

This company called me three times in one day using a robodialer from 718-475-9208, 508-639-1369, and 781-729-2582 selling solar panel solutions. Obviously spoofing the 

telephone number. Last call I waited for an operator to answer. I asked the name of the company (Liberty Power) located in Ft Lauderdale, FL.

Liberty 

Power?

Not sure of the name of the company, but learned they represent 27 companies that can supply electricity. They have called multiple times the past few weeks and I have 

asked them to put me on their company do not call list and informed them this number was no the national do not call registry.

Liberty Power 

Holdings

The Caller ID said: Amherst, MA. The woman said she was calling from Liberty Power. This is the 5th call we've received this afternoon!! Personally, I'm tired of these 

assholes calling!!

I'm getting many calls from several power companies I keep telling them to stop calling but they continue. This call was from Scott Daniels, so he said. Also, getting many credit 

card calls ditto above.

Liberty Power 

Electric 

Company

I have asked them to stop calling me at least 4 times and I am still receiving phone calls. I have probably received these phone calls for several months now. They say that I 

qualify for a rebate (or something) because I am an Eversource customer. Eversource is an electric company I used in MA and I have lived in Austin since August 2015. I try to 

explain this to the callers and they continue with their . I will try to record my calls in the future if they continue to call.

They called and wanted my power bill account info and wanted all my personal information so they could switch me to their company. The caller spoke very broken English and 

after I asked them to stop calling they called 3 more times from different numbers

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 14 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 61 of 70
Y Chicago IL Liberty Power 815 3900015 07/12/2016

Y CT Liberty power 860 9152480 07/13/2016

Y IL Liberty Power 312 7625238 07/08/2016

Y athens NY liberty power 877 4367162 07/08/2016 foreign calls 10 per day from rediculous companies

Y Homer Glen IL 815 3900015 06/29/2016

Y MA Liberty Power 413 6282225 06/27/2016

Y aurora IL 815 3900015 06/27/2016

Y Chicago IL Liberty Power 815 3900015 06/24/2016

Y Rockford IL Liberty Power 815 3900015 06/24/2016

Y NY Liberty Power 877289925 06/17/2016 They call multiple times a day and every day even after requesting to stop.

Y Colfax IL Liberty Power 773 3644191 06/13/2016

Y NJ Liberty Power 201 2495491 06/13/2016 They say there selling cheaper electricity

Y PA Liberty Power 215 2772414 06/10/2016 They said they would lower my PECO rate and wanted my PECO account number. If they are a reputable company, why don't they honor the do not call registry?

Y Urbana IL Liberty Power 847 3159265 06/07/2016 Selling electrical power.

Y Chicago IL Liberty Power 847 3159265 06/04/2016

Y Barrington IL Liberty Power 847 3159265 05/31/2016 Asked them again to take me off list! Caller ID showed Deerfield IL but the man said he was in Des Plaines, IL working for Liberty Power.............

Y Pekin IL Liberty Power 05/23/2016

Y PA Liberty power 877 2899925 05/24/2016 Calls daily

Y Cottage Hills IL Liberty Power 05/20/2016

Y Wheaton IL Liberty Power 773 3368882 05/16/2016

Y Lake Bluff IL 866 7693799 05/10/2016 These guys just keep calling. Tired of it.

Y mashpee MA liberty power 05/10/2016

Y northbrook IL Liberty power 866 7693799 05/06/2016 A recording first says if you are a com ed customer who pays their bills on time press 2, then this person, Brian tries to sell on their stuff.

Y Urbana IL Liberty Power 224 2509923 05/06/2016

Y Alton IL Liberty power 224 2509923 05/05/2016 They lie about who they are claiming to be Ameren and this was the tenth time I have called and put my number on the do not call list and they continue to call

Y Evanston IL Liberty Power 224 2509923 05/05/2016

Y North Aurora IL Liberty Power 224 2509923 05/04/2016 It's a robo call asking me to press "1" to save money on my electric bill. They make it seem like it's ComEd call, but it's not.

Y Elmhurst IL Liberty Power 224 2509923 05/03/2016

Y IL 224 2509923 04/29/2016 Foreign sounding person said they could lower my Comm Ed bill. Have asked them to stop calling me before but they did it again today. Said he was from Liberty Power.

N IL Liberty Power 224 2509923 04/27/2016 I get a call from this group every 20 days or so and I always tell them to take me off their list and that my number it on the do not call registry.

Y IL Liberty Power 224 2509923 04/26/2016

Y Forest Park IL 224 2509923 04/25/2016 Robo call. I've received calls from this number over the past 6 months offering savings over com ed.

Y Waterloo IL Liberty Power 224 2509923 04/22/2016

Y Lake Bluff IL 866 7693799 04/18/2016 Another alternative energy provider.

Y IL Liberty Power 04/14/2016

Y IL 224 2509923 04/13/2016 Continue to ask to be removed from their calling list but they continue to call.

Y Chicago IL Liberty Power 224 2509923 04/12/2016 I have told these people three times that this number is on the "do not call" list, but they keep calling.

Y Chicago IL Liberty Power 224 2509923 04/01/2016

Y SWANSEA IL Liberty Power 224 2509923 03/31/2016

Y Worcester MA Liberty power 508 5566692 03/29/2016 Person has called every day for a week. I told him to take me off the list first day. Still calling

This was a sales call / scam. The representative was trying to sell Liberty Power as a new energy supplier, but did so by saying they were with ComEd, my current supplier. 

That was not true. It was fraud. Please stop them from calling my number.

Liberty Power 

Corp.

This company has called me at least a dozen times. Every time I ask them who they represent they hang up but this time I lead the caller on far enough for him to tell me who 

he represents. Liberty Power Corporation. I have repeatedly ask them not to call and they disconnect immediately. When I try to call their number back using caller I.D. it says 

the number is not a working number. I want to prosecute these people to the fullest extent of the law. At least a dozen times and I am on the do not call list. Please contact me 

if you need any other info. Thank You, (b)(6)

claims to be 

liberty power

keep receiving phone calls from different #'s to lower comed power bills. call gets transfer to india call center. when you ask the name of the company they make something 

up. when you ask where they are based they wont answer. have repeatedly told them # is on do not call list.

I was called on 6/24/2016 at 2pm from 815-390-0015 with a robo call saying press 5. After pressing 5 I was immediately connect to an individual who said his name was 

Cameron White. He mentioned Com Ed's name 5 or 6 times before stating the company he represented was Liberty Power. He used a run on sentence saying how he would 

fix my electric bill pricing for 24 months and also send me a $50 gift card and would I would to get my gift card and move forward. I stated a number of times I do not want to 

make a decision and he said I would have a 10 day period anyways. I am on the do not call registry. Why do they keep calling?

I have received numerous calls from this company over several months. Sometimes I press the number to ask not to be called again, other times I have told the caller, yet I 

still receive the calls, typically from various spoofed phone numbers.

East 

Rutherford

West 

Chester

The robot said that if I have paid my last 6 Commonwealth Edison (electric) bills on time and wanted to save 15% off my Commonwealth Edison bill I should dial "1". After I did 

that, I was connected to a man who said his name was Jason Smith and had a VERY heavy Indian accent. Additionally I heard a delay after every thing I said so I'm pretty 

sure I was talking to someone in India. He said he was an energy consultant for ComEd. When I asked him if he worked for ComEd directly, I got a run around until he finally 

admitted that he worked for Liberty Power, a supplier to ComEd. I explained that I was on the do not call list and unless he worked for a company that I was presently doing 

business with, he was breaking the law by calling me. I was professional and firm and told him I would report this call and wanted him to remove me from his calling list. He 

then said "Go Fuck Yourself!" and hung up. This company and this employee need to be stopped immediately.

Liberty Power, 

https://www.li

bertypowercor

p.com/contact

-us/

I have asked them to take our number off of their call list repeatedly. Sometimes they are nice about pretending to do so, other times they've either sworn or bellowed 'no' and 

hung up on me.

WILLOWBR

OOK

LIBERTY 

POWER

Unknown 

possibly 

liberty power

Liberty Power, 

https://www.li

bertypowercor

p.com/contact

-us/

LAKE IN 

THE HILLS

Shopping 

Rewards / 

Liberty Power

The automated recording stated that this is for ComEd customers and that I qualify for a 15% discount on my bill. When I pressed #1 to speak to a live representative, a very 

rude man with a very heavy Indian accent would not tell me what company this is. After a couple of minutes of back and forth arguing he finally said it is "Liberty Power." 

Liberty Power has called us repeatedly and we have repeatedly told them to stop calling, take us of their list, and that we are on the "do not call list" and will file a complaint. 

This does not to deter Liberty Power and they keep calling us.

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 15 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 62 of 70
Y IL Liberty Power 224 2509923 03/24/2016 Alexander was quite rude to me and ended up hanging up on me.

Y Gurnee IL Liberty Power 224 2509923 03/22/2016 Sales call trying to get me to change my electric service. Lots of noise in background like a call center.

Y CT Liberty power 860 2158001 03/21/2016

Y Easton PA 610 8654424 03/18/2016

Y Chicago IL liberty power 224 2509923 03/15/2016

Y Tinley Park IL Liberty Power 309 8320753 03/14/2016 When I blocked the number 3098320567, they started calling from this number. I have told them not to call many times.

Y Tinley Park IL Liberty Power 309 8320567 03/14/2016

Y Niles IL Liberty Power 224 2509923 03/08/2016

Y CA Liberty power 978 5896589 03/03/2016 They keep calling me every week from a different number, in Spanish. Don't know how they got my number. I keep asking then to stop. I already read it's a scam.

Y IL Liberty Power 224 2509923 03/03/2016

Y IL Liberty Power 224 2509923 03/01/2016

Y IL Liberty Power 224 2509923 03/01/2016

Y MD 877 2899925 03/01/2016

Y HOME IL Liberty Power 224 2509923 02/24/2016 lots of calls from energy companies wanting me to change to their service. please have them stop.

Y IL 224 2509923 02/22/2016

Y Alsip IL Liberty Power 774 2080038 02/11/2016 These sales reps are very aggressive and do not listen at a simple no. One even claimed that I was already a customer of theirs.

Y CA Liberty Power 305 3968428 02/06/2016 It's the second time in a week this company calls me and I've asked them not to do so.

Y Williamstown MA Liberty Power 508 9276673 02/03/2016 Called around 1:55PM asking about my electric company and if I knew about lower rates to lock-in.

Y Shrewsbury MA Liberty Power 508 9276673 02/02/2016 Receiving multiple calls from this company after asking them to stop. Appears on the caller ID as a fictitious number.

Y Orland Park IL Liberty Power 224 2509923 02/02/2016

Y CT Liberty Power 877 2899925 02/01/2016

Y Liberty Power 877 2899925 02/01/2016 Liberty Power called twice today. Both callers had Indian accents. The second call was at 4:06pm.

Y Batavia IL Liberty Power 224 2509923 01/29/2016

Y MA Liberty Power 877 2899925 01/28/2016

Y Hamburg PA liberty power 877 2899925 01/26/2016

Y Norwell MA 617 6124449 01/26/2016

Y MA Liberty Power 877 2899925 01/25/2016

Y Dayton PA Liberty power 877 2899925 01/20/2016

Y Prairie View IL 224 2509923 01/18/2016 SEVERAL CALLS AND REQUESTIED BEING REMOVED ALWAYS ASKING FOR INFORMATION THAT I WILL NOT PROVIDE

Y Orland Park IL Liberty Power 224 2509923 01/07/2016 Tried to tell me I was eligible for all extra charges to be taken off my ComEd billing for next 24 months if I went with Liberty Power. Caller ID only indicated Des Planes, Il.

Y Chicago IL Liberty Power 866 7693799 01/05/2016 Recorded message asked you to press # I did, spoke w/ someone possibly in India. Told him to remove from call list, that it was illegal. He said, "I understand."

Y MA Liberty Power 815 7707145 12/30/2015

Y Beltsville MD Liberty Power 410 8810504 12/30/2015 This person call daily harrasing me

Y IL Liberty power 224 2509923 12/29/2015

Y Chicago IL Liberty power 708 8984876 11/27/2015 This company has continued to call me and solicit my buisiness after repeated being told to stop.

Y Aurora IL Liberty Power 708 8984876 11/19/2015 Asked if i spoke Spanish and hung up.

Y Roscoe IL Liberty Power 312 9404286 11/11/2015

Y Chelsea MA Liberty Power 857 3276921 11/05/2015 This company keeps calling over and over again.

Y Homewood IL Liberty Power 312 9404286 11/05/2015

Y NY liberty power 877 2899925 10/21/2015 they calling me almust evry day u may contact me @ (b)(6)

Y Agawam MA Liberty Power 617 4090593 10/15/2015

Y Chicago IL Liberty Power 312 9404340 10/12/2015

Y NJ Liberty Power 201 4145952 09/22/2015

West 

Dundee

Liberty Power 

Corp. LLC

I have told them I do not wish to sign up with them and told them to put me on their DO NOT CALL list. This is about changing my electric energy supplier. A man named Mark 

Johnson (Said he was calling from Asia) threated to get me kicked off my PCAP Program because I refused him. They are using threating and harassing means to get you to 

sign with them.

This company has been calling my elderly parents for about a year. I have instructed them not to call anymore on at least 3 separate occasions. They have tricked my mother 

into agreeing to use their services multiple times. My mother has memory problems and can not remember they are scammers. If possible, I would like to file charges 

because they have violated the do not call registry many times, even after being warned. Please contact me at (b)(6) if you need further information. I have power of attorney 

for my parents and handle all of their financial business.

The call started with a recorded message and then was forwarded to a live operator. I asked the operator for the street address of the company, but he only told me that the 

company's URL is libertypower.com and that he was calling from northern Florida. The caller ID indicated that he was calling from Des Plaines, IL. He hung up on me before I 

got a chance to tell him not to call me again.

Sherman 

Oaks

This company called me two days ago and again today. The automated message gives the impression that they are ComEd. "As a ComEd customer you may qualify for a 

discount on your bill" - paraphrasing. Then when you switch over to a live representative, they say the company is called Liberty Power. I've again asked to be removed from 

their calling list and told them they shouldn't have called in the first place because this number is on the federal do not call list.

The recorded message said that I qualify for a discount on my People's Gas bill. When I asked for a live representative and asked him is this People's Gas, he replied that this 

is Liberty Power and hung up on me.

The recorded message said that I qualify for a discount on my People's Gas bill. When I asked for a live representative and asked him is this People's Gas, he replied that this 

is Liberty Power and hung up on me.

LIBERTY 

POWER

Liberty power 

via comed

Call was from India stating that they were affiliated with com Ed and could save me money on my bill. Wanted account number for my com Ed account and when refused was 

very angry and rude. I aske for mail information but was refused. Liberty power was who they said was calling it was clearly a call center and had many other callers heard in 

the background noise. Please do not let them call anyone anymore.

Sherman 

Oaks

This seems like it's not actually Liberty Power calling. An "out of area" number calls and someone with a heavy indian accent calls claiming they are Liberty Power, but Liberty 

has posted on their website that there is a scam claiming to be them. They call multiple times a day even though we have asked to be taken off their list.

I called them on 1/25/16 and asked them to stop calling me - this after at least 4 calls per day, every day. I told them to take my name off their list and they said they would. 

Then, on 1/26/16, I received another 2 calls before 1015am. Make them stop!

Liberty Power, 

FL

I have received 4 calls from this company over the past 6 months. Each time I have asked them if they have heard of the "Do not call list" and they have said they have. I said 

please delete my number from your call list. They said they would and hung up. Then a month later they call again.

I answered, there was a pause, they asked to speak with person who handles electric bill I asked who was calling. He gave a first name I couldn't understand. He sounded like 

he was from India and that he was with Liberty Power. I've never heard of liberty power. Our town has their own electric company.

We have received numerous calls from Liberty Power. They are very persistent . Each time we have told them to not call us back to no avail. We redialed the number after 

speaking to the representative and left a message telling them to remove our number from their call list. They continue to call. I would appreciate any help to get this company 

to stop calling us. Thank you. Sincerely

LIBERTY 

POWER

Caller ID said Des Plaines, IL. Received a call from this number, got a recording that said if I made my ComEd payment on-time for the last 6 months I was eligible for a 15% 

discount.

Probably a year ago I said I would use their service. I had a number of days to change my mind and I did. When the paperwork arrived in the mail 3 days later, I did not fill it 

out. I called and canceled the electrical power service. No paperwork was filled out and nothing sent. They have called me many times since and each time I tell them I don't 

want their service, stop calling and they hang up, but still continue to call.

Was switched to a live representative, "Mark," who said he represented Liberty Power. He went through three bogus questions and told me I was eligible for a 15% discount 

on my electric supply for the next two years.

RIO 

GRANDE

This person called and said they can give us a better deal than Atlantic City Electric. I said to provide a quote and he told me he could not provide a quote. I told him that we 

have been on "Do Not Call Registry" since 2009 and he is breaking law. I do not know if the phone number which came up on our caller ID is the correct number for this 

company, since he refused to provide me with his callback number.

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 16 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 63 of 70
Y NJ 609 7984003 09/14/2015

Y NJ 609 7984003 09/11/2015

Y Cherry Hill NJ 609 7984003 09/11/2015 Address of the company that called me: Address: 1901 W Cypress Creek Rd #600, Fort Lauderdale, FL 33309 Phone:(866) 769-3799

Y streamwood IL Liberty Power 312 8095220 09/11/2015 They keep calling and hang up on me when I tell them I am on the do not call list. They try to make you think they are from ComEd.

Y NJ 609 7984003 09/11/2015 AGAIN, THESE PEOPLE HAVE CALLED MY PHONE ASKING FOR SEVERAL DIFFERENT PEOPLE. I'VE TOLD THEM TIME AND AGAIN TO STOP CALLING.

Y cherry hill NJ liberty power 609 7984003 09/11/2015

Y NJ Liberty Power 609 7984003 09/09/2015

Y Garden City NY Liberty Power 877 2899925 09/09/2015 This call was asking for confidential info about power bills. They should be blocked

Y IL Liberty Power 815 3205002 09/04/2015

Y Sewell NJ Liberty Power 609 7984003 09/03/2015 Female caller claimed to be from Liberty Power, a green energy supplier, asking for the person responsible for the electric bill. Caller ID read "Egg Harbor C, NJ"

Y CT Liberty Power 754 2053123 09/02/2015 Company claimed to be unaware of Federal do-not-call restrictions.

Y NJ Liberty Power 888 5315596 08/31/2015 Sales rep Kayce von Dolteren called offering to switch me to Liberty Power as my electric power provider. I'm on the DNC list...are they allowed to do this? J

Y Providence RI Liberty Power 877 4367162 08/18/2015

Y IL 08/13/2015 Change from Com Ed scam THEY HAD MY NAME AND ADDRESS!!!

Y NY 646 7796616 08/13/2015 Calling me everyday and bothering me.

Y NJ Liberty Power 973 8415074 08/13/2015 I have been receiving similar calls from many companies trying to sell me Electric supply. They all seem to have knowledge that I am an Atlantic City Electric customer.

Y NJ Liberty Power 973 8415074 08/10/2015

Y OXFORD NJ 973 8415074 08/07/2015

Y IL liberty Power 866 7693799 08/06/2015 Called about switching electric companies.

Y IL Liberty Power 945 5987090 07/31/2015

Y Cos Cob CT liberty power 877 2899925 07/30/2015 Tried to call number back to speak tosomeone and was directed right into a recorded message and then placed on hold. Hung up after 40 minutes.

Y Old Lyme CT Liberty Power 888 5315596 07/29/2015 The phone number CALLED was (b)(6). I would prefer to be reached at (b)(6)

Y NY Liberty Power 877 2899925 07/28/2015 I have asked this company not to call several times, but they persist.

Y IL 866 7693799 07/27/2015

Y Rocky Hill CT Liberty Power 877 2899925 07/24/2015

Y Takoma Park MD Liberty Power 866 7693799 07/23/2015

Y CT liberty power? 877 2899925 07/22/2015 They have been calling several times per week for several months.

Y nyc NY liberty power 347 5473524 07/18/2015

Y PA Liberty Power 866 7693799 07/14/2015

Y CT 860 3788930 07/13/2015

Y CT liberty power 860 3788930 07/08/2015

Y Newton NJ Liberty Power 609 2255262 07/07/2015 They call every week even though I keep telling them I am not interested.

Y Flemington NJ Liberty Power 609 2255262 07/06/2015

Y Plainfield IL 312 3405562 07/02/2015 I continue to receive robo-calls, even after asking them to stop calling or to be removed from their calling lists.

Y CT Liberty Power 07/01/2015

Y East Hartford CT Liberty Power 860 3788930 06/30/2015

Y New Britain CT 860 3788930 06/25/2015

Y Harwich MA 857 3059424 06/24/2015

Y New Britain CT Liberty Power 06/23/2015

Y IL Liberty Power 312 3405561 06/17/2015

Y Wethersfield CT Liberty Power 866 7693799 06/18/2015 Liberty Power claims to maintain their own Do Not Call List however they obviously do adhere to the requirements of the National list.

Y NJ Liberty Power 866 7693799 06/16/2015

Liberty Power 

Energy 

Supplier of 

Egg Harbor, 

NJ

Liberty Power 

Energy 

Supplier of 

Egg Harbor, 

NJ

Liberty Power 

Corporation

SOMERDAL

E

LIBERTY 

POWER

The phone call began with a robocall that claimed I can get a discount on my ComEd (electric utility)bill. When I spoke to a live representative, he didn't want to give me the 

name of his company at first. Finally he said it's Liberty Power in Chicago. He spoke with an Indian accent. I asked to be removed from their list and also that I'm on the 

"National Don Not Call Registry."

South 

Glastonbury

This company keeps calling from different numbers, sometimes it is a private number, sometimes not. The number given to me by the person who keeps calling is 877-436-

7162 ext. 4567. They have called repeatedly even though I keep asking them to stop. They are trying to sell electricity and are very insistent about speaking to someone 

about the rates. I speak to a live person every time, it is not a robocall. When I ask them to stop calling I get an "OK" but they call back the next week.

LIBERTY 

POWER

Jackson 

Heights

Liberty power 

supply

LIBERTY 

POWER

Liberty Power 

Company

Caller ID was blocked for the incoming call. Claimed to be a supplier for ComEd. Identified themselves as Liberty Power when I asked. I have done no business with this 

company.

Liberty Power 

(callerID: 

SOUTHINGT

ON CT)

Stafford 

Springs

Although I spoke to a live person, it was a few seconds after I said Hello before anyone responded. There was a slight "beep" prior to anyone talking. So it MAY have been a 

robocall and then switched me to a real person when it heard the Hello.

Liberty power 

-Illinois

8665423789

7693799

Liberty Power, 

Southington 

CT

Company selling Electric Power. They call almost every day at approximately 2PM. They have repeatedly been asked to remove our numberit hasn't happened yet. An internet 

search shows that number to be served by Level 3 Communications in CT. Maybe Level 3 Communications should be held liable for this bull!

Cambridge 

aka Liberty 

Power

Can offer me low utility rates based on new law passed, sure wish the law included that these companies MUST honor do not call registry, as they said I must register with 

THEM to be on a do not call list. So again the 4 th call today to decrease my utility bill, sure wish u didn't pass the law as it would pay anything to stop these daily calls!! I 

calledthe office at 727-940-8624, which is just a voicemail "Hello, Please leave a message". yea, like I'm going to request they call me, duh! Ps that Florida # is Utility Discount 

Group, Palm Harbor, Fl 38543

This is a supplier for electricty I have asked many, many times to stop calling me that was my contract is up I will be using a different supplier but they keep insisting to try to 

get me to stay on as their supplier.Now I switch over to another supplier and this company still is calling me I hung up on them. I hope you can do something Thank you

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 17 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 64 of 70
Y Palatine IL Liberty Power 312 3405561 06/16/2015

Y MA Liberty Power 866 7693799 06/15/2015

Y IL 312 3405561 06/11/2015

Y New York NY Liberty Power 315 2903147 06/05/2015 They offered to switch my electricity provider

Y MA Liberty Power 978 6311021 06/04/2015

Y PLYMOUTH MA Liberty Power 508 9306907 06/04/2015

Y IL Liberty power 06/01/2015 electric rate scam

Y Crestwood IL 312 3405562 05/31/2015

Y Westwood MA Liberty Power 617 5539619 05/22/2015

Y stafford CT liberty power 718 2853924 05/14/2015

Y Waltham MA Liberty power 05/14/2015

Y Watertown MA Liberty Power 866 7693799 05/13/2015 Liberty Power called twice each time said not Interested hope they get message. I have Ever source for Electric

Y Marshfield MA 508 5566756 05/08/2015

Y mattapoisett MA liberty power 508 5566756 05/01/2015 i tried calling this number back and it is "not in service." when i asked them to take us off of the list, they hung up on me.

Y Plymouth MA Liberty Power 708 5294723 04/29/2015

Y Worcester MA Liberty Power 888 5315596 04/28/2015 Asked them to stop calling. They are very rude and continue to call.

Y Barnstable MA Liberty Power 708 5294723 04/24/2015 I am a staunch DO NOT CALL member. I want accountability.

Y Springfield MA Liberty Power 04/24/2015 I have asked them to remove my telephone number and not call me again. They just hang up the telephone without a word and the calls continue.

Y stafford CT liberty power 876 2899925 04/24/2015 Call ID says 800 service. Asked caller to remove my name and number from their list but he persisted to try and keep me on the line.

Y Cambridge MA Liberty Power 708 5294723 04/20/2015

Y Mashpee MA Liberty Power 508 8863410 04/10/2015 The minute I mentioned the "do not call" list they hung up

Y Florence MA Liberty Power 314 3229999 04/07/2015 A man named something like Gerard said he could lower our electric rates for a certain period of time.

Y New Milford CT Liberty Power 04/07/2015

Y New Milford CT Liberty Power 04/07/2015

Y weymouth MA 866 7693799 04/07/2015

Y MA Liberty Power 888 5315596 04/01/2015

Y Oakdale CT Liberty Power 877 2899925 04/02/2015 They also called on 04/01/2015 at 1007 (am) and again on 04/02/2015 at 0958(am).

Y CT Liberty Power 877 4367162 04/02/2015

Y Syracuse NY Liberty Power 877 2899925 03/31/2015

Y MD Liberty Power 877 2899925 03/31/2015

Y MD Liberty Power 877 2899925 03/31/2015

Y Ridgefield CT Liberty Power 203 5380930 03/26/2015

Y longmeadow MA Liberty Power 617 5539619 03/25/2015 Told them they were being reported...they claimed multiple locations....i said go by do not call and it should not matter

Y Springfield MA Liberty Power 978 6310289 03/12/2015 They claimed to be calling from a power company about my electric bill, but my electric is included into my rent, so I don't have a bill.

Y Medway MA Liberty Power 617 2063357 03/10/2015

Y Medway MA Liberty Power 866 7693799 03/10/2015

Y MA Liberty Power 03/11/2015

Y CT Liberty Power 877 2899925 03/06/2015 Live person requested to speak with the person involved with paying electrical bills. I said I wasn't interested and requested to be removed from their list.

Y Canton MA Liberty Power 617 2063357 03/05/2015

Y Gold Canyon AZ Liberty Power 860 7916711 03/05/2015 Person hung up on me before I could tell him this number is on the federal do not cll list.

Y Medfield MA Liberty Power 617 2063357 03/05/2015 Caller identified himself as Saveid Rapp. He said he called from "Liberty Power". He said his callback number is 888-531-5596.

Y CT 860 7916711 02/27/2015

Y MA Liberty Power 888 7242966 02/27/2015

Y Niantic CT Liberty Power 866 7693799 02/24/2015

Y CT Liberty Power 661 4340655 02/23/2015 Saying they were calling all Connecticut Light and Power customers to offer a better deal. Caller ID had LAMKTG but caller identified the company as Liberty Power.

Y New Britain CT Liberty Power 860 7916711 02/21/2015

Y Stonington CT Liberty Power 877 2899925 02/18/2015

Y Stonington CT Liberty Power 877 2899925 02/17/2015

Y Wilton CT Liberty power 877 2899925 02/17/2015 They wanted us to change electric suppliers. I told them we were on the do not call list. We both hung up.

I am an elderly woman and this company is preying on me. They tell me (even though I have not signed any paperwork) that my voice recording binds me into a contract with 

them. They are forcing me to use them for my 2nd party power supplier. I want them to leave me alone!!!!!

Liberty Power 

(Ft. 

Lauderdale)

Called again and again. Finally answered them and a woman started to tell me about Liberty Power and how I can save money on electric bill. Been there. done that. GEt them 

to stop.

members 

services 

Liberty Power

The call ID only says New York. I have received multiple phone calls from Liberty Power about reducing my electric bill and every time I have asked them to remove my name 

from the call list. They keep calling from different numbers.

Upon receiving this call, I asked "who is calling, please?" When the male voice at the other end identified Liberty Power, I informed him that this phone number was on the Do 

Not Call registry, that I had never done business with his company, that they had no right to violate the Do Not Call stipulations, and that I would be immediately filing a 

complaint on my computer.

Engel Liberty 

Power

Liberty Power has called me several times. I have asked nicely (3 times) to remove me from their list. That is not happened nor do I expect it will. PLEASE help me! I am 

happy to answer any questions you have.

I received an automated call saying that I might be eligible for lower electric rates and was told to press 5 to speak to a customer service representative. The automated 

message did not identify the company. When I reached a person, I asked the name of the company, which he gave, and the phone number at that point he hung up on me. I 

found the number by dialing *69.

Liberty Power 

of 1901 w. 

Cypresscre 

Fort 

Lauderdale, 

Florida

these companies call to try to solicit changes in power. someone took the call and said yes but they said we can cancel with in 3 days. called them back the next day to say we 

dont want any part of them and to tell them we are on the do not call list and they shouldn't be calling,. a guy in phillipines said Id have to call back in 2 or 3 days.

West 

Hartford

Person ID self as Roger DeSusa [sp] from "Liberty Power" called to have the office change electrical service suppliers. Call back 877-456-7162 ext 4561. This was a cold 

marketing call since we have record of doing business with this entity.

North 

Stonington

Liberty Power 

 (callerID: 

MEMBER 

SERVICES)

I do not know the number they called from. But I verified the identity of the company to my satisfaction. They are competing for CL&P customers. They are based out of Ft. 

Lauderdale.

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 18 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 65 of 70
Y Stamford CT Liberty Power 877 2899925 02/13/2015

Y CT Liberty Power 02/12/2015

Y Wallingford CT Liberty Power 203 5380930 02/11/2015 Caller ID showed up as "Quality Care" Person on the phone said his name was Sean and that he worked for Liberty Power

Y Westport CT 203 5380930 02/10/2015 PLEASE STOP THESE CALLS!!!! This is the 100th time I have reported them.

Y Thomaston CT Liberty Power 877 2899925 02/06/2015

Y Danielson CT Liberty Power 866 7693799 02/03/2015 Liberty Power has called almost every day for the last 3 weeks ask for me to change power company and I have ask them to stop calling and they will not

Y Killingworth CT liberty power 02/02/2015

Y Salem CT Liberty Power 877 2899925 02/02/2015 This 800 Service phone number will not stop calling my home number. I have told them to stop calling and yet they continue to do so at all hours of the day.

Y NJ Liberty Power 201 2348516 01/29/2015

Y DC Liberty Power 877 2899925 01/28/2015

Y CT Liberty Power 661 4340655 01/28/2015

Y New Haven CT Liberty Power 860 7267903 01/27/2015

Y Williamstown NJ Liberty Power 201 2348516 01/23/2015

Y Merrick NY 877 4367162 01/26/2015

Y PA Liberty Power 210 7645008 01/23/2015 first call was this afternoon. I told them i was on the do not call list, and that I would be reporting it.

Y New Milford CT Liberty Power 860 7267903 01/20/2015 Liberty Powers has been calling between one and three times per day for the last few weeks. Enough is enough!

Y Pottstown PA Liberty Power 877 7266421 01/16/2015

Y Grafton MA Liberty Power 01/16/2015

Y Bridgeport CT Liberty Power 860 7267903 01/16/2015

Y Danbury CT Liberty Power 860 7267903 01/13/2015

Y AMHERST MA Liberty Power 413 6253379 01/07/2015

Y MD Liberty Power 443 6200380 01/02/2015 Robo-call then talked to a person to get the name of the company. Callid ID said Service Care but the person said Liberty Power.

Y Agawam MA Liberty Power 01/02/2015

Y Agawam MA Liberty Power 12/31/2014 computer dialed, when I say hello I am connected to a call center-they ask for the person responsible for the electric bill.

Y Shelton CT Liberty Power 203 2785038 12/19/2014

Y Cambridge MA Liberty Power 866 7693799 12/18/2014 I have received repeated calls.

Y Revere MA Liberty Power 866 7693799 12/17/2014

Y CT Liberty Power 860 3195320 12/16/2014 "May I speak to the person that pays the electric bills?"

Y Summit NJ Liberty Power 877 4367162 12/11/2014

Y Waterbury CT Liberty Power 860 3195320 12/09/2014

Y MD Liberty Power 855 4193586 12/05/2014 Asked week and a half ago to stop calling us.

Y Takoma Park MD Liberty Power 443 6200380 12/03/2014

Y MA 978 8671241 12/02/2014 This company has called a number of times. I don't answer. I would like them to stop calling!

Y Columbia MD 11/26/2014

Y Columbia MD 11/26/2014

Y Glenelg MD Liberty Power 866 7693799 11/24/2014 We are on DO NOT CALL REGISTRY. Liberty called my house, spoke to an elderly member, then began their process to change our electric account from BGE to Liberty.

Y Hermitage PA Liberty Power 857 4440140 11/18/2014 Caller said she was from Liberty Power, a green power supplier, and was calling all Pa residents. I have no established business relationship with this company

Y Crownsville MD Liberty Power 855 4193586 11/13/2014

Y MA Liberty Power 857 4440140 11/12/2014

Y MA Liberty Power 857 4440140 11/07/2014

Y Dartmouth MA Liberty Power 857 4440140 10/31/2014

I have REPEATEDLY told them to stop calling. They call multiple times per day, after I tell them not to call I am assured at least one or more call back/hangups from them. My 

number is on the do not call list. They are clearly not referring to that list and are abusive in nature.

West 

Hartford

1166143406

55

This was a spamed number but it was definitely identified as Liberty Power. She played dumb when I said I am on the do not call list. She said there is no reason to report 

them.

Liberty Power 

in Fort 

Lauderdale

I have received several calls recently from this company, Liberty Power.Most recent is today at 10:45am. My telephone numbers are on the Do Not Call List for several years. 

This company is a scam and I do not want to receive calls from them.

This is some power company with its main office in Florida and an office in Connecticut. They speak poor Englisk. They are rude and I have asked repeatedly that they do not 

call me. You may audit my cell phone for verification.

Liberty Power 

of Ft. 

Lauderdale

plymouth 

meeting

Have been receiving calls all week. Some have identified themselves as 800 service. This is the first one where I got a legitimate call back number (I think) and the name of a 

company.

Time: Fri, 16 Jan 2015 14:12 Company: Liberty Power Presumably this is: Liberty Power Corp., LLC Phone: (866) 769-3799 Caller: Human male I hung up. No 

transaction was begun or completed.

This company calls me almost every day offering me service for electricity, I have told them on several occasions not to call me, and to put me on their do not call list, but they 

still call anyways, this has been going on for over 3 weeks now.

They only speak Spanish and hang up on you when you cannot speak Spanish back to them. Sounds like a "boiler room" operation. I called back and asked for a supervisor. 

I spoke to "Mariella Flores" and told her not to call again. We shall see if that works. This company calls nearly every week.

My phone number that received this call has the ringer shut off. If you need to contact me by phone, that can be done on my cellphone at (b)(6). By email at (b)(6). You may 

have some aol email addresses on file but they are no longer being used. thank you jf

WHITE 

HALL

I received a call with a Caller ID of LA MKtg and phone # 1-661-434-0655 claiming to be representing Liberty Power when I told them we are on the DNC list they said they 

would put me on their DNC list. I said I didn't want the first phone call and they hung up. When I called Liberty Power to ask them if they made sure none of their or their 

marketing companies out going calls violated the DNC list they wouldn't give me a clear answer. And then they put me on hold and then hung up. This is teh second alternative 

power company that called in the last two weeks violating the DNC list. I can't tell if the comapnies are violating the list or if scammers are using the power companies as a way 

to scam us. But we would like to see the FTC step up and track down these companies. Thank you.

Cold call. They tried to trick me into believing they were with my utility company but I knew to ask them which company they were with and why were they calling me. I also 

informed them that I was on the DNCR and to remove me.

North 

Billerica

Liberty Power 

Corp

Liberty Power 

Corp

Received an automated call about lowering my electric bill. Curious as to the company, I pressed 5 to speak with someone. Eventually, a non-native English speaking woman 

came on the line wanting to sell me lower rates. But, I interrupted her and asked the name and address of the company she represented. She said Liberty Power Corp., 1901 

West Cypress Creek Road, Ft. Lauderdale, FL. I then told her that my number was on the Do Not Call list and, as I had no previous business dealings with her company, they 

were violating FTC regulations by calling me. I also asked her to put me on their do not call list. Later, I found the Liberty Power website and it listed a contact number of 1–

866–769–3799.

Liberty Power 

Corp

Received an automated call about lowering my electric bill. Curious as to the company, I pressed 5 to speak with someone. Eventually, a non-native English speaking woman 

came on the line wanting to sell me lower rates. But, I interrupted her and asked the name and address of the company she represented. She said Liberty Power Corp., 1901 

West Cypress Creek Road, Ft. Lauderdale, FL. I then told her that my number was on the Do Not Call list and, as I had no previous business dealings with her company, they 

were violating FTC regulations by calling me. I also asked her to put me on their do not call list. Later, I found the Liberty Power website and it listed a contact number of 1–

866–769–3799.

I received a call from Liberty Power today. They were acting as if they were my present electric company and wanted me to verify personal information in order to lock in a new 

lower rate. When I asked what their company's name was, I realized this was not my electric company. I told them I was on the do not call list and they hung up on me.

This was the 3rd call I have gotten in the last week. I told the 1st caller to send me the info in mail, he became argumentative and hung up. I told 2nd caller the same thing and 

I was not interested w/o written info and told him to take me off call list. 3rd caller today was told the same thing. Was very condescending. Kept pursuing despite my telling him 

not interested. I am also wondering how this company would get my phone number if I was on the FTC's Do Not Call list. PLEASE ADVISE

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 19 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 66 of 70
Y Baltimore MD Liberty Power 443 6200380 10/29/2014

Y Pittsburgh PA Liberty Power 877 4367164 10/29/2014

Y Pittsburgh PA Liberty Power 877 4367164 10/28/2014

Y Beverly MA Liberty Power 857 4440140 10/23/2014

Y Westford MA 857 4440140 10/22/2014

Y MA Liberty Power 978 8671241 10/15/2014 This company keeps calling with rude and persistent agents trying to switch customers from National Grid

Y Baltimore MD Liberty Power 973 2737827 10/10/2014

Y MA liberty power 888 5315596 10/07/2014

Y IL 773 3404486 09/30/2014 Eric wanted to argue that this was not a sales call!!

Y Natick MA Liberty Power 978 5284968 09/29/2014

Y Auburn MA 508 9347387 09/15/2014 This is their website: http://www.libertypowercorp.com/

N Brooklyn NY Liberty Power 518 3096550 09/08/2014

Y glastonbury CT liberty power 877 4367162 08/25/2014 please follow through on this. the do not call list is not well respected by telemarketers.

Y Worcester MA Liberty Power 08/20/2014 They wanted to talk to the person who pays the electric bill. I assume they wanted us to switch to their electric service. I did not talk to them about it.

Y Springfield MA Liberty Power 413 6505015 08/15/2014

Y Lee MA Liberty Power 413 3586751 08/01/2014

Y Worthington MA Liberty Power 413 2402029 07/25/2014

Y Agawam MA Liberty Power 07/22/2014

Y Lancaster NY Liberty Power 07/16/2014 Again, my number is on this registry yet I continue to get unsolicited phone calls

Y Corning NY Liberty Power 07/08/2014

Y NY Liberty Power 607 3043103 07/02/2014

Y Yakima WA 06/28/2014

Y Oneonta NY Liberty Power 585 9783772 06/23/2014

Y Greene NY Liberty Power 866 7693799 06/11/2014

Y owego NY Liberty Power 585 4712849 06/10/2014 i told rude liberty power rep who kept interrupting me that i was on a do not call registery. she they were given phone#s that they call every day and she hung up on me.

Y palisades NY liberty power 877 2899925 06/06/2014

Y Columbia MD 877 2899925 06/04/2014

Y NY Liberty Power 585 4712849 06/03/2014

Y petersburg NJ liberty power 732 7846633 05/27/2014

Y Rensselaer NY Liberty Power 397 3177591 05/24/2014

Y Chatham NJ Liberty Power 05/15/2014 As soon as I asked where they got our number and said we were on the Do Not Call Registry the caller cut me off without giving me the opportunity to ask them not to call again.

Y Brick NJ Liberty Power 732 4918208 05/13/2014

Y Brick NJ Liberty Power 732 4918208 05/12/2014

Y brick NJ liberty power 732 4918208 05/12/2014

Y Lakewood NJ Liberty Power 732 4918209 05/09/2014

Y Lakewood NJ Liberty Power 732 4918209 05/09/2014

Y NJ Liberty Power 860 5166030 05/06/2014 This call was the third in a 2 week span. They had been told very explicitely not to call again.

Y Atlanta GA Liberty Power 877 2899925 05/05/2014

Y Bayville NJ Liberty Power 888 5315591 05/01/2014

Y smithville NJ liberty power 609 5037003 04/28/2014 please have these people stop calling me.

The robocall was inviting BGE customers to "lower energy costs". They invited to press 5 to speak to someone, and I did, waited a couple of minutes on hold and spoke to an 

"Energy consultant" named Claire. She offered to put me on *their* D.N.C. list, and I had her do that. I asked her if they respect the national do not call list, and she said that 

they do not use that. She did not seem to know about it.

I have asked them repeatedly to stop calling. We have no use for their services and we have never done business with them. If I tell them no or disconnect the call, they keep 

calling back and harassing the office. I have also emailed the company and not received anything back.

The call every day. They have been notified not to call us and that we are on this list, but it has not relieved the calls as of yet. Once they called back repeatedly in one day 

because we said we weren't interested and disconnected the call before they could object. They are trying to sell "lower rates" on your energy supplier.

They called asked to speak with "the person that handles the National Grud bills" and I asked who they were "Liberty Power, a green energy company" was the answer. I 

informed them that I am on the DNCR and they said they would remove me. I've been hearing reports of scams in town from supposed power companies with unsolicited 

calls.

Liberty Power 

(listed as MA 

Energy on 

Call Log)

After a delay when I answered the phone, a man came on the line, said he was with "Liberty Power" and started talking about energy prices. I interrupted and asked if he 

bothered to check the National Do Not Call Registry to see that I am on the Do Not Call list, but he just said I am "not on his computer list", which he had in front of him. That 

sounded like a Do Not Call List for his business, but I said his company needs to pay attention to who's on the National Do Not Call Registry list, too.He agreed to put me on 

HIS list, but I said his company is supposed to check the National list, too - he just said he was "doing his job".

Representative "Adam Jones" refused to provide manager or corporate address, said they are from Dallas Texas. Violation of Do Not Call List. calling the number shown on 

caller ID allows only "press 1 to be put on our do not call list" but this company is violating the Federal Do Not Call List by even calling my number.

Liberty Power 

Supply / 

Chicagozn08 

IL

Liberty Power 

Corp

I have been receiving "robo-calls" with no messages from this company from 2 different numbers for the past 2 months, here are the latest: 1) 518.309.6550 on 9/8 @ 8:12pm, 

2:47pm & 2) 443.487.4118 on 8/30 @ 2:44pm, 10:30am 8/29 @ 1:35pm 8/28 1:38pm On 8/30 spoke to supervisor Rolando Santana (443.487.4118) who promised me my # 

would be removed from his list, then they started calling from another # and I spoke to supervisor Fausto Duran (518.309.6550) who said the same thing.

I was called at 12:09 PM on Aug. 14, 2014 by Mr. Charrez. I answered the phone to tell them that I am on the do not call list. He said that my power company authorized him to 

call me because I had to pick a power supplier to protect my rate. I had the feeling that this was a mandate from the government or my power company (WMECO) and he 

implied that this was in conjunction with WMECO wishes.He Knew my bill format and lead me all over the bill to look at various items. Then he told me that my current rate is 

0.13844 and that he can keep me at this rate for 48 months. He seemed irritated that I was skeptical and reluctant to take advantage of this program. then he said if I cancel 

this program it would cost me $10.00 a month. I told him I was not interested and do not sign me up. I want no part in anything I have to pay to get out of. He was abrupt and 

said he would not submit the application. His name is David Charrez 888-531-5596 from Liberty Power. This is why I want the do not call.

Caller refused to give his name. Claimed he was our power provider, but we don't do business with Liberty Power, we use WMECO. He didn't know the name of the person he 

was looking for.

6073054310

3

"Liberty 

Power 

Company"

We have never heard of this supposed power company - it is not one we have ever used. Looking it up online, "Liberty Power Company" appears to be a power company on 

the east coast (including Washington DC) - we live in Washington STATE. We suspect the caller took a wild guess that we lived in DC. Caller told us to "use more power 

because our rate is going down." By the sound of the caller, it was the same "technical support" people that called 5 minutes ago.

The name of the person that called was "David Silva". He promised a kw hour rate freeze. He said that the call was being recorded. He refused to provide a contact 

telephone number.

i have reported this number and company NUMEROUS times on your site and i see it does no good. this number from liberty power has called me at least 20 times and refuse 

to stop. eventhough i have complained on the dnc.gov site numerous times as well.

Liberty Power 

Corp

I was unable to ask to be put on the Do Not Call list. I tried. I DID FOLLOW the directions on their website but was UNABLE to reach ANYONE who could put us on Do Not 

Call. Their Directions are as follows: "We respect your right to privacy. To be placed on the Liberty Power Do Not Call list, please call us at 866-POWER-99 (866-769-3799) 

and we will fulfill your request. If you prefer, send an e-mail to info@libertypowercorp.com with Do Not Call in the subject line and include your name, name of business (if 

commercial service customer), as well as all applicable account numbers and phone numbers in the body of the message. We will process your request within 48 hours." 

There is no way to get to anyone with our Do-Not-Call request at this number.

This call came in at 4:42 PM on Friday May 23,2014. The person identified himself as Jack. I asked him his phone number and he gave a different number than my caller ID - 

800-642-7591. I told him I was on the DO NOT Call registry and to not call me anymore. This same company has called before and I told not to call anymore.

New 

Brunswick

The man told me I don't understand the DO NOT CALL rules and was very rude. He didn't like me questioning him as to how he called me. He said he just has the computer 

connect him he doesn't dial . I get calls at least every few days about switching my electric service. At times its a recorded message.Most of them hang up when I ask the 

company name.

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 20 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 67 of 70
Y Monroeville NJ Liberty Power 609 5037003 04/27/2014

Y Westport, CT 860 5166030 04/24/2014

Y NJ Liberty Power 914 3687042 04/15/2014

Y NJ Liberty Power 914 3687042 04/15/2014

Y NJ Liberty Power 914 3687042 04/15/2014

Y NJ Liberty Power 914 3687042 04/15/2014

Y NJ Liberty Power 914 3687042 04/15/2014

Y Chestertown MD liberty power 410 4065034 04/11/2014

Y MD Liberty Power 04/09/2014 These people have been auto dialing me for several weeks

Y Owings Mills MD Liberty Power 888 5315596 04/04/2014

Y Rye NY Liberty power 760 5140144 04/04/2014

Y NJ liberty power 240 4373606 04/02/2014 I never ask for this services the calling person name is Noel Rodriguez

Y Washington DC 866 7693799 04/02/2014

Y Washington DC Liberty Power 202 3707463 04/01/2014

Y DC Liberty Power 04/01/2014

Y NJ Liberty Power 250 4373606 03/28/2014

Y DC Liberty Power 202 3707463 03/26/2014 I have asked this company repeatedly to take me off their list. They have not.

Y Morris IL Liberty Power 618 3270430 03/24/2014

Y Morris IL Liberty Power 618 3270430 03/24/2014

Y palisades NY liberty power 877 2899925 03/24/2014

Y Washington DC 202 3707463 03/20/2014

Y Mattoon IL Liberty Power 03/17/2014

Y Washington DC Liberty Power 03/13/2014

Y Washington DC 292 8172946 03/12/2014

Y DC 202 8172946 03/12/2014 This was pure marketing solicitation and I am on the do not call list. This is harassament

Y horseheads NY 732 8135546 03/07/2014

Y NJ 908 8290084 03/05/2014

Y ellicott city MD Liberty Power 877 2899925 03/04/2014

Y Morris IL Liberty Power 618 3270430 02/26/2014 I spoke with Bobby Bradshaw, who attempted to convince me to buy electric power from Liberty Power instead of my current electric supplier.

Y Bethalto IL Liberty Power 02/24/2014 Have ask them to stop call.

Y IL liberty power 02/20/2014

Y IL Liberty Power 618 3013423 02/05/2014

Y IL Liberty Power 866 7693799 01/30/2014

Y Fleetwood PA Liberty Power 866 7693799 01/31/2014

Y Hull IL Liberty Power 618 3013423 01/30/2014

Y PA Liberty Power 01/27/2014 I have told this company three times now to take me off their call list. I told them I was going to file a complaint after the second call a few months ago and they called me again!!

Y Gaithersburg MD Liberty Power 877 2899925 01/24/2014 They keep calling and there is a long delay with them saying 'hello?, hello?' and then they hang up on me. I've told them to remove us from their list during the delay.

The person called and asked if I was the person responsible for paying the utility bills in the household. I asked who they were and why were they were calling. The person (a 

female) replied that they represent Liberty Power. I told her that I'm on the do not call list and they shouldn't be calling me. She said that she knows that I'm on the do not call 

list and apologized but thought I might be interested anyway. When I informed her that I was going to file a complaint she hung up. This is a clear violation.

liberty power 

company - 

bristol, CT

I have been called repeatedly during the day and at night by this number/company. Most times I do not answer the phone but 3 times I have answered and asked to be taken 

off the list. I asked for the caller today - Paul Sheldon and asked to speak to the manager. I was told the manager was not available and the person hung up. I tried to call the 

company and was put on hold for over 5 minutes - after which time I hung up. The Liberty Power website for NY says there are phone problems and ask for caller information 

to be completed in the website. I have a website for my phone service that will show each time a call came in and time and number of the call if that is needed. These calls 

are very disruptive and intrusive. Help me stop this aggravation.

I looked up their information. They call my house regularly after asking to stop phone calls. I am not a customer, I must be on some list of theirs. 

customercare@libertypowercorp.com Phone Toll Free: 1-866 POWER-99 (1–866–769–3799) 1901 W Cypress Creek Rd., #600 Fort Lauderdale, FL 33309

I looked up their information. They call my house regularly after asking to stop phone calls. I am not a customer, I must be on some list of theirs. 

customercare@libertypowercorp.com Phone Toll Free: 1-866 POWER-99 (1–866–769–3799) 1901 W Cypress Creek Rd., #600 Fort Lauderdale, FL 33309

I looked up their information. They call my house regularly after asking to stop phone calls. I am not a customer, I must be on some list of theirs. 

customercare@libertypowercorp.com Phone Toll Free: 1-866 POWER-99 (1–866–769–3799) 1901 W Cypress Creek Rd., #600 Fort Lauderdale, FL 33309

I looked up their information. They call my house regularly after asking to stop phone calls. I am not a customer, I must be on some list of theirs. 

customercare@libertypowercorp.com Phone Toll Free: 1-866 POWER-99 (1–866–769–3799) 1901 W Cypress Creek Rd., #600 Fort Lauderdale, FL 33309

I looked up their information. They call my house regularly after asking to stop phone calls. I am not a customer, I must be on some list of theirs. 

customercare@libertypowercorp.com Phone Toll Free: 1-866 POWER-99 (1–866–769–3799) 1901 W Cypress Creek Rd., #600 Fort Lauderdale, FL 33309

received call at approximately 423 pm. Asked to be taken off call list - Too late - they had already call - should have never call - ie. DO NOT CALL list.......Please do what 

you can to stop ALL unsolicited calls.

I asked them to stop calling as the number was on the do not call list and was told the number was not on the list. I asked to speak to a supervisor and was told the same 

thing. advised that I was filing a complaint

Liberty Power 

Corp.

Telemarketer called asking for our current electric company provider and stating that we needed to renew with his company immediately to avoid service interruption. He said 

the call was being recorded at the beginning of the conversation, making himself sound like a debt collector that we had to listen to. He said his name was Ben Gomez. He 

provided a company number of 888-531-5596. Our Caller ID said 410-406-5034.

I told the woman when she called I was not interested. She became angry and said she would keep calling. The woman called my house an additional two times at 10:30 am 

and 10:29 am, hanging up both times. Originally, when this company first called I mentioned we were not interested, and we were on the Do Not Call Registry.

So sick of this!! I have contacted my representative, Rodney Frelinghuysen, to see if anything is being done about this. EVERY DAY I get some kind of telemarketing call. 

STOP IT!!!!!

Liberty Power called both of my phone lines within 2 minutes of each other. I have previously spoken with Liberty Power and told them that I am on the DNC list and they 

should not call me again in the future.

Liberty Power called both of my phone lines within 2 minutes of each other. I have previously spoken with Liberty Power and told them that I am on the DNC list and they 

should not call me again in the future.

liberty power has called me at least 15 times after i have been enlisted on the do not call list and after i have repeatedly told them to stop calling me!! i cant take it. they call 

constantly. It is always from an overseas call center where i can barely understand them. I NEED THIS TO STOP

Liberty Power 

Company

the caller asked for, "the person who pays the electric bill." when I asked who was calling, he said Liberty electric Company, licensed to do business in DC - and replied, did 

you know we are on the Do Not Call List and it is illegal to solicit business by phone to numbers on the Federal List. he apologized but was clueless

The Caller identified himself as Gary Bernhardt representing Liberty Power offering an electric rate of $0.08369/KWH. He inquired my electric Billing company and Supply 

company. (I did NOT supply an account number and have contacted my electric supplier)He stated that it was "Green Power" and ICC Certified. There were numerous voices 

in the background. He did Not give a telephone number and I did not ask. This is the First time this company has called me. Just before I hung up, I told him that I was on the 

DO-NOT-CALL registry, and he stated that he would enter that information with the company. The call was between about 3:00 and 4:00 PM CDT March 17, among the 

POLITICAL, pre-recorded "vote for" calls that (unfortunately) are allowed. By your database, my telephone number has been on the DO-NOT-CALL list since October 18, 2007.

Liberty Power 

Corp.

The call was from out of the area and the telephone number is obviously not that of the company. I found its actual telephone number and address on line: (866) 769–3799, 

1901 W Cypress Creek Rd., #600 Fort Lauderdale, FL 33309. They were trying to sell me on the idea of switching power companies.

Liberty Power 

company

liberty power 

holdings, llc

This company called me in regards to switching my bill, I stated that I was a consultant for a competitor of theirs and the person on the phone got very defensive. After a short 

discussion of what I was getting, I asked him to please take my number off his list and hung up. About 2 minutes later, I received a return call from the same person with a very 

sarcastic message and that I was pushing a scam on people. Please follow up with their business etiquette on the phone and have them take my number off their list.

Liberty Power 

but caller ID 

shows name 

of Diane 

Krencik

The company calls my home phone and hangs up when you answer so that you will call and see who it is. Then they answer saying that I called them. More and more 

companies are doing this to avoid the fines associated with the do not call registry but they are still soliciting and I have never done business with them.

Todays call was from "Cain Dcosta" 877-436-7162. He is a sales agent for Liberty and claims to have not phoned previously. It is apparent that they are moving my number 

between their 5 marketing centers in India. Liberty Power is an Electricity Utility provider of deceptive practice at best. After overcharging me for services they continue to solicit 

even though I cancelled them as my service provider over a year ago. They even denied receipt of my cancellation letter and entered a renewal on my behalf. Very 

DECEPTIVE COMPANY.

New 

Bethlehem

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 21 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 68 of 70
Y New York NY Liberty Power 877 2899925 01/23/2014

Y PA Liberty Power 877 2899925 01/23/2014 They keep calling 2- 3 times a week to solicit.

Y MD Liberty Power 877 2899925 01/16/2014 This is at least the third time I have reported this company. Calling my cell.

Y PA Liberty Power 877 2899925 01/10/2014 This company keeps calling using an auto dialer. You then wait for the live person to pick up.

Y PA Liberty Power 877 2899925 01/08/2014 This company has called multiple times. I have already reported them weeks ago. What gives?

Y Aledo IL Liberty Power 01/06/2014 The caller identified himself as John Burke.

Y new york NY 01/06/2014

Y MD Liberty Power 667 4011478 12/19/2013

Y PA Liberty Power 877 2899925 12/12/2013

Y MD Liberty Power 667 4011478 12/12/2013

Y smithsburg MD liberty power 866 7693799 12/12/2013

Y smithsburg MD liberty power 866 7693799 12/12/2013

N Larchmont NY Liberty Power 866 7693799 12/11/2013

Y PA Liberty Power 877 2899925 12/10/2013 They called again yesterday, 12/9/13.

Y new york NY Liberty Power 877 4367162 12/06/2013

Y NY liberty power 877 2899925 12/04/2013 i already have reported this company. this is the fourth time they have called me in the past two days and i told them i am on the DNC list. i want it to end

Y New York NY liberty power 866 7693799 12/03/2013

Y IL 815 4759390 11/22/2013

Y Mokena IL Liberty Power 973 2737843 11/18/2013

Y OHIO IL 11/17/2013 THEY ALL ABOUT EVERYDAY . WANT YOU TO SWITCH ELECTRIC OWER CO

Y galva IL liberty power 11/15/2013

Y MD Liberty Power 877 2899925 11/14/2013 Fourth Time Reporting

Y Towson MD Liberty Power 877 2899925 11/12/2013

Y IL 618 5375679 11/05/2013

Y Bethesda MD Liberty Power 877 2899925 11/06/2013

Y Lebanon IL Liberty Power 618 5375679 11/05/2013

Y MD Liberty Power 877 2899925 11/01/2013 This is my cell, and this is the second time they have called, and the second time I have reported it to you.

Y MD 866 7693799 10/30/2013

Y Brooktondale NY Liberty Power 10/29/2013 Please prosecute. I asked if the company checked the do not call list, and the caller said that they did not. Prosecute, or the registry is useless.

Y IL Liberty Power 815 4759390 10/23/2013

Y MD Liberty Power 877 2899925 10/24/2013

Y Wyomissing PA Liberty Power 10/24/2013

Y Beecher IL Liberty Power 815 4759390 10/23/2013

Y Ottawa IL Liberty Power 815 4759390 10/22/2013

Y Marengo IL Liberty Power 773 3090162 10/21/2013 Sounds like a scam, guy said was calling from Dominican Republic when finally answered it after multiple calls over course of a few days. Despite Chicago area code.

Y Marengo IL 773 3090162 10/21/2013

Y Washington IL liberty power 217 6154126 09/26/2013 I have asked numerous times for them to take me off the list...I am so tired of this.

Y danville IL 888 5315596 09/20/2013 we tell them to stop calling and every day they call back, dawn ray x 101

Y Elmira NY Liberty Power 866 7693799 09/17/2013

Y North East MD 410 4175321 09/13/2013 This is at least the third time that they have called my house.

Y Washington IL Liberty Power 618 5030722 09/11/2013 what happened to the law that no soliciting? It's still happening.

Y Peoria IL Liberty Power 312 4488590 09/11/2013

Y Crystal Lake IL Liberty Power 773 3090162 09/11/2013 Not interested in lowering rates and requested that 'Edwin' remove our number from their call list.

Y Bloomington IL Liberty Power 312 4488590 09/10/2013

Y Peoria IL Liberty Power 312 4488590 09/09/2013

Y NJ Liberty Power 866 7693799 09/06/2013 Shows as unavailabe

They are an alternative power company - their robo calls come way too frequently. Since I don't pay for electricity where I live, their calls are ludicrous and a waste of their time. 

Not, that I would ever do business with them

LIBERTY 

POWER

These people keep calling. I keep asking them to stop and to remove my name from their list. it interrupts my work day and is a total nuisance. What will stop this. Caller voices 

sound out-sourced to India. sometimes, callers sound more US-based. I don't care where the person is from. No number appears on caller ID.

They have foreigners calling non-stop. Please do something about it. This is the third call I have received in less than a week. Hit them with a drone strike or something. 

Thanks.

They have called me three times in the last month. The caller ID says "blocked" and they are using offshore telemarketers. However they all indicate that they are calling on 

behalf of Liberty Power

Liberty Power is one of hundreds of companies which are selling "discounts" on electricity. Every month I get a dozen calls from these companies, despite the fact that my 

phone number has been on the DNC list for years. Does the do-not-call list have any teeth? Is there any enforcement?

liberty power 

co.

LIBERTY 

POWER

The liberty power phone number is 866 769 3799. I don't have caller ID so don't know what number they called from. The man gave his name as jeff and was from liberty 

power. It was in the afternoon around 3:30 to 4:30 on the 14 of november.

This is at least the third time they have called my cell, which is registered on do not call, even though it does not have to be. If you look up this phone number (877) 289-9925, 

you will see many others who are complaining about them as well.

Liberty Power 

Telemarketer wanting me to switch to Liberty Power. Obviously in Illinois the Do Not Call List means nothing to telemarketers. Caller ID indicated "LEBANON IL" so the phone 

number is probably spoofed. Liberty Power is located in FLA.

SMITHSBUR

G

LIBERTY 

POWER

Liberty Power (and their affiliates) have called us at least 100 times on our business phone numbers. Our office is small, but they have called each of our lines for the past 

several months. We continue to tell them to stop calling us. After doing some research, they have also been harassing others. We tell them to stop calling, and then we hang 

up. Not 1 minute later, we get another call. They must be getting paid to just keep calling. That must be their incentive. Liberty Power, and their calling affiliates, are scam 

artists.

This is the first known call I have received from this company. I did let them know I was on the do not call list and would be filing a complaint. I assume that is the same as 

letting them know to stop calling.

Liberty 

Power- Rob 

Winter

Lou's son (me) Lance Boyd answered finally after days consecutive of them calling and found out guy's name calling and he claimed it was "Rob Winter" and said company he 

was calling for was Liberty Power. He said he was calling out of he Domincan Republic when I asked where he was out of. He said the company was in IL. Sounds like a 

scam. I told him why are you a 773 Chicago area area code if calling from Dominican Republic? Spoofing? Tricking caller ID? He had no answer. Might want to pass along 

to FEDS sounds like a scam posing as power company savings switch sales pitch. Or Liberty Power if it exists is using out of country telemarketers to avoid US law. They 

should be fined if true and exist. Or have FBI investigate this likely scam.

liberty power 

choice 

consultants

Liberty Power 

Corp

Brianna Sanchez with Liberty Power, her direct line is 855-506-1442 ext 1900 Calling about switching power companies. I have told them to NOT call my REGISTERED do 

NOT call number.

Calling regatding lowering my electric rates. I never received any similar calls until our city council approved a consolidated rate program earlier this year. Received a call from 

them last week, and told them do not call back, and pointed out I am on the national do not call list. They responded that they would add me to the Illinois Electric Program do 

not call list, whatever that bogus crap is supposed to be.

Telemarketer wants me to call him "back" at 855-506-1442. I am on do NOT call list, have never done biz with them, and do NOT want to. This is another power company 

wanting me to switch providers. NOT interested!

Monmouth 

Junction

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 22 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 69 of 70
Y champaign IL Liberty Power 08/30/2013

Y MD Liberty Power 443 5903224 08/29/2013

Y Elkton MD Liberty Power 888 5315596 08/28/2013 We get scads of robo calls, but don't have caller ID to complain about them. This guy's given name is Jabari. Website given was libertypowercorp.com

Y Urbana IL Liberty Power 888 5315596 08/26/2013

Y Barnegat NJ Liberty Power 000 0000000 08/24/2013 They ignor reqsuest to stop calling.

Y IL Liberty Power 217 6345066 08/22/2013 I have asked this comkpany no to call me on several ocassions. Can you please stop this herassment.

Y Sparta NJ Liberty Power 773 3090162 08/20/2013 How can I receive compensation from this company for calling me?

Y Sparta NJ Liberty Power 08/18/2013

Y Hopatcong NJ Liberty Power 773 3090162 08/14/2013 I spoke to Michael Delancy and he said we would take me off their list. I have asked this company multiple times to do this and they have not.

Y MD Liberty Power 08/12/2013

Y Sewell NJ Liberty Power 773 3090162 08/07/2013

Y flemington NJ Liberty Power 877 4367162 08/05/2013

Y NJ liberty power 877 4367162 07/31/2013

Y IL Liberty Power 07/29/2013

Y Anna IL Liberty Power 309 3627035 07/26/2013

Y Salisbury MD Liberty Power 813 7490764 07/02/2013

Y Chicago IL Liberty Power 877 4367162 06/25/2013 They called 4 times yesterday and once already today.

Y IL Liberty Power 815 6765121 06/06/2013 Caller ID was "Plainfield,IL" regarding electricity choices.

Y IL Liberty Power 877 4367162 05/29/2013

Y Titusville PA Liberty Power 877 2899925 05/20/2013 this company is relentless

Y Crisfield MD Liberty Power 410 3949585 05/15/2013

Y NJ Liberty Power 801 8933332 05/13/2013

Y Titusville PA liberty power 877 2899925 05/13/2013

Y des plaines IL liberty power 773 3090162 05/08/2013 Told me they were not selling anything by not asking for a credit card. thank you.

Y IL Liberty Power 05/07/2013

Y Des Plaines IL Liberty Power 773 3090162 05/07/2013 They also have a toll free number at 866-257-5822 and this is their website: http://www.libertypowercorp.com/ Thank you.

Y Northbrook IL Liberty Power 773 3090162 05/06/2013

Y staten Island NY Liberty Power 877 2899925 05/06/2013 Liberty Power electric charge lower rate. Keep calling me please stop them. Thank you.

Y IL Liberty Power 05/02/2013

Y NJ Liberty Power 801 8933332 04/29/2013

Y Galena MD Liberty Power 410 3465108 04/29/2013

Y Burlington NJ Liberty power 801 8933332 04/29/2013

Y Northbrook IL Liberty Power 866 7643799 04/23/2013

Y Vernon Hills IL Liberty Power 773 3090162 04/20/2013 I have reveived several calls from this number over the past few weeks.

Y Elkton MD Liberty Power 888 5315596 04/15/2013 The person I spoke with, Alex Sinclair, said if my number was on the Do Not Call List he wouldn't be calling me. They have been calling almost every day for over 2 weeks.

Y saint charles IL liberty power 866 7697399 04/12/2013 They called before, I told them not to call again

Y Wheaton IL Liberty Power 773 3090162 04/12/2013

The Illinois Commerce Commission has authorized many new companies to offer electric service however, several are violating the do-not-call law in an effort to sign up new 

customers. This is at least the third I have been contacted by and I have registered a complaint with the ICC too.

Does anyone actually follow up on these complaints? I have the feeling my reports are being filed in a black hole. I'm getting an increasing number of unwanted calls, despite 

my listing in the do-not-call registry.

Mount 

Vernon

Liberty Power called also on Aug. 10 in the afternoon. I told them then I was on the No Call List and they were NEVER to call again. At that call the person was unclear as to 

whether he was calling from Chicago or Ft Lauderdale (hum !) We have been getting a tremendous number of calls from power brokers.

Caller asked to speak with person who handles electric bill. I asked who was calling. He stated he was calling from Liberty Power and had a fixed rate energy offer for 

customers of the electric company we use. I told him we were happy with our electric service he responded with a hard sell speech. After several attempts to politely decline 

the offer, I hung up on him.

A live person with a thick accent said his name was "Andrew Smith" calling from Liberty Power asking for the person responsible for the electric bills and pitching "clean 

energy". Caller ID read "Unknown Name". Told him he was in violation of the DNC and that I was reporting their violation before hanging up.

Continues to call after I told them DO NOT call, very rude, persistent, high pressure, said they have a right to call,said they are calling EVERYONE of delmarva power 

customers even if they are on do not call list.

Caller was a male, maybe Caucasian, sounded about thirty-ish. His tone was very argumentative, demanding and rude. I wouldn't give out any personal info. The caller hung 

up. I could hear several people having conversations in the background.

Buffalo 

Grove

I am on the do not call list so this company should not have called. When I told the gentleman I wanted his company to not call me in the future he continued with his pitch. 

When I again told him to not call me he said "but sir, you don't know why I'm calling." I again told him to not call me and he again tried to give me his pitch. I then advised him 

I'd file a complaint about his firm with the FTC.

"JOE" wanted to talk with the person who pays the "light bill" - I told him that we are on the "do not call list" and that I was reporting this call to the Federal Government - 

PLEASE stop these calls - I have reported probably more than 20 during the past several weeks

The call was from overseas, and it was hard to understand the man through his thick indian accent. But, they should not be calling my phone at all. he claimed it was with 

regard to my electric bill. Meanwhile, I don't pay an electric bill (my parents do) and we do not have Liberty Power. Even if we did, they wouldn't be calling my cell phone. This 

is ridiculous. They're lying now.

This number may have be a private house since my ID on the phone said it was from Silver Run, MD. She represented Liberty Power. However she said she was from Liberty 

Power and wanted me to tell her about my electric power usage by giving information from electric bill. When I told her I was not interested in changing power companies, she 

became insistent I read her the information. We have Choptank Electric and she said she could not save us any money there. What a scam! This phone number has been 

registered many years with do not call.

This company keeps calling me on my cell phone from area code 801 with different numbers, I have told them to stop calling but everyday I still get another call, I need them to 

stop.

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Case 1:18-cv-10506-ADB Document 109-1 Filed 11/14/18 Page 23 of 23 Case 21-13797-SMG Doc 159-2 Filed 05/28/21 Page 70 of 70