10 itt 2 B 14 15 16 7 18, 19 20 au 23 24 25 26 27 28 Patricia A. Meyer, Esq., SBN 109621 Trevor M. Flynn, Esq., SBN 253362 a CONFO) PATRICA A. MEYER & ASSOCIATES, APC RMED 550 West C Street, Suite 990 LOR ORIGINAL P.GOPY San Diego, CA 92101 °S Superior Court Telephone: (619) 235-8636 MAR i Facamile: (619) 235-0510 02 2069 Atlorneys for Plaintiff John A. Clarkefecutive Officer/Clen BYMARY GARCIA, Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES BC 408693 J, VIRGIL WAGGONER, ON BEHALF OF Case No. HIMSELF AND ALL OTHERS SIMILARLY aera SITUATED, | COMPLAINT - CLASS ACTION PLAINTIFFS, JURY TRIAL DEMANDED CHADBOURNE & PARKE, LLP, AND DoE ACTION IS AN UNLIMITED CIVIL CASE DEFENDANTS 1 -100 IN THAT THE AMOUNT DEMANDED EXCEEDS $25,000 Defendants Plaintiff, J. Virgil Waggoner, hereby brings this complaint, on behalf of himself and all others similarly situated, and alleges as follows: I, INTRODUCTION AND NATURE OF CASE 1 J. Virgil Waggoner (sometimes referred to as “Plaintiff” or “Waggoner”) is a client of the Defendant law firm, comprised of general and limited partners (hereinafter referred to as, “Defendant”). Waggoner and the other putative class members were overcharged for 1 COMPLAINTa wos Cea ae 10 i 13 14 15 16 7 18 19 20 21 22 23 24 25 26 28 computerized legal research and information retrieval as part of a standardized corporate custom, policy and practice. Waggoner brings this lawsuit under California's consumer protection statute, Business and Professions Code § 17200 et. seq. (informally known as the “Unfair Competition Law” or “UCL"”) and other state consumer protection statutes where applicable, California Rules of Professional Conduct Rule 4-200 and other Rules of Professional Conduct where applicable, ‘and common law. Asa proposed class representative, Waggoner secks as relief from the Defendant for himself and all other putative class members who are clients of the Defendant, compensatory or actual damages, restitution, disgorgement, declaratory and injunctive relief TL JURISDICTION AND VENUE 2. This Court has personal jurisdiction over the Defendant and venue is proper. Additionally, this Court has jurisdiction over the subject matter of this lawsuit (a state law class action) seeking compensatory or actual damages, restitution, disgorgement, declaratory and injunctive relief. I. PARTIES 3. Plaintiff Virgil Waggoner is a resident of the State of Texas where he maintains an office and place of business at 605 Cypresswood Drive, Suite 250, Spring, Texas 77379. 4, Defendant Chadbourne & Parke, LLP (“Chadbourne”) is an international law firm. Chadbourne has offices located in Los Angeles, Califomia. Their California office address is 350 South Grand Ave., 32nd Floor, Los Angeles, CA 90071. Chadbourne also has branch offices in New York, Texas and Washington, D C. IV. AGENTS AND CO-CONSPIRATORS 2 ‘COMPLAINT5 The acts alleged against the Defendant in this class action Complaint were authorized, ordered, or done by their directors, officers, partners, agents, employees, or representatives, in the scope of and while actively engaged in the management and operation of Defendant’s business or affairs. 6. Various persons and/or firms not named as a Defendant herein may have participated as co-conspirators in the violations alleged herein and may have performed acts and sade statements in furtherance thereof. 7. Bach Defendant acted as the principal, agent, or joint venturer of, or for, other ‘Defendants with respect to the acts, violations, and common course of conduct alleged by the Plaintiff. Vv. FACTUAL ALLEGATIONS 8. Onor around January 15, 2002, Waggoner entered into an attomey-client relationship with Defendant. See Exhibit “1,” attached hereto, incorporated herein by reference and hereby made a part of the record hereof (with all confidential information redacted as required by California Rules of Court Rule 1.20). As part of the attorney-client relationship, the Defendant billed Waggoner for computerized legal research and information retrieval. AAs part of its standard corporate custom, policy and practice, Waggoner was overcharged and billed for computerized legal research and information retrieval in excess of the actual cost incurred by Defendant for this legal service. See, ¢ g., bill from Defendant attached hereto as Exhibit “ attached hereto, incorporated herein by reference and hereby made a part of the record hereof (with all confidential information redacted as required by California Rules of Court Rule 1.20) ‘As part of its custom, practice and policy, Defendant did not disclose its practice of billing in excess of actual costs incurred to members of the Defined Class. ‘COMPLAINT