Inc. defendant Case No. Demand for Trial by Jury Parties 1. Named plaintiff, Maury M. Tepper, is a consumer residing in Hamilton County, Ohio near the City of Cincinnati, Ohio who files this action both on behalf of himself and all similarly persons, pursuant to Ohio Civil Rule 23, seeking to recover monetary damages and to further obtain an Order for a permanent injunction and a declaration that a certain advertisement and sales practices of the defendant are fraudulent, deceptive, unfair and unconscionable pursuant to statute and common law. Defendant is a supplier of retail goods and services and who, in the ordinary course of its business, engages in certain advertisement and sales practices with respect to the consumers with whom it does business.
Defendant does business in Hamilton County, Ohio, as well as several other Ohio counties.
1345.01, et seq. By engaging in an act or practice which has been previously declared deceptive by a Court of competent jurisdiction in this State which decision was further contained in the Public Inspection File of the Ohio Attorney General and available for inspection by the defendant at the time of the acts complained of herein. 1345.01, et seq. 1345.01.01 et seq. Named plaintiff brings this action both individually on his own behalf and as a class action on behalf of all other persons similarly situated, for defendant's unlawful conduct as it affects all other consumers residing within the State of Ohio.