SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION

ERICKA JINETH HERCULES RAMIREZ,

ROSALI AMAYA BENITEZ,
ABEBA HEYI,
ENCARNACION DUBON ORTIZ,
DONALDO MONDRAGON,
YAMILETH REYES VALLADAREZ and Case No. _________________
SOLOMON M. WELDEMARIAM, on behalf
of themselves and all of those similarly
situated,
JURY TRIAL DEMANDED
Plaintiffs,
v.

WASHINGTON GAS LIGHT COMPANY

101 Constitution Ave. NW
Washington, DC 20001,

WGL HOLDINGS, INC.

101 Constitution Ave. NW
Washington, DC 20001,

KAY MANAGEMENT COMPANY, INC.

8720 Georgia Ave., Suite 410,
Silver Spring, Maryland 20910,

and

JOHN DOES,
Manufacturers of residential gas delivery
equipment to Flower Branch Apartments,
Address Unknown at this Time,

Defendants.

CLASS ACTION COMPLAINT

Introduction

1. Close to midnight on Wednesday, August 10, 2016, a massive explosion ripped

through the 362-unit Flower Branch Apartments complex, creating a gas-fed inferno that nearly

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levelled a four-story building, killed seven residents, injured more than 30, and left dozens of

families homeless.

2. Compounding the tragedy of this horrific event is the fact that it was entirely

preventable. Less than three weeks before the explosion and fire, residents had reported the smell

of natural gas, but the Defendants – Washington Gas Light Company, which supplied natural gas

to the complex, and Kay Management Company, which managed the complex – failed to take

any action to address the complaints. They did not repair the gas leak, did not make an

appropriate inspection that would have identified a leak, and did not warn or evacuate residents.

Defendants also failed to perform routine inspections that would have uncovered the potential for

catastrophe and saved the lives and property of the residents.

3. The effects of these failures reach far beyond the residents of Flower Branch

Apartments. Washington Gas, which is headquartered in the District, makes corporate-wide

safety and maintenance decisions here, operates hundreds of miles of natural gas pipeline here,

and is the sole distributor of natural gas to D.C. residents and businesses. Kay Management

markets and rents its apartments extensively to D.C. residents. The District of Columbia

therefore has compelling interests – specifically, its interests in protecting the life, safety, and

property of its 675,000 citizens – that justify both the exercise of jurisdiction over the Defendants

in the District, and the application of the District’s law to this legal dispute.

4. Plaintiffs therefore bring this action in this Court on behalf of a class of persons

affected by the explosion at Building 8701 at the Flower Branch Apartments. Plaintiffs seek

justice in pursuit of two principle aims: first, to obtain compensation for themselves and other

residents who lost personal property and sustained damages; and second, to secure injunctive

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relief and structural reforms at Washington Gas and Kay Management to ensure that tragedies

like that at Flower Branch never happen again.

Parties

5. Plaintiff Ericka Jineth Hercules Ramirez, a resident of Silver Spring, Maryland,

currently lives in Building 8650 at the Flower Branch Apartments.

6. Plaintiff Rosali Amaya Benitez, a resident of Silver Spring, Maryland, currently

lives in Building 8640 at the Flower Branch Apartments.

7. Plaintiff Abeba Heyi, a resident of Silver Spring, Maryland, lived in Building

8703 at the Flower Branch Apartments. Ms. Heyi continues to reside in Silver Spring, MD.

8. Plaintiff Encarnacion Dubon Ortiz, a resident of Silver Spring, Maryland,

currently lives in Building 8644 at the Flower Branch Apartments.

9. Plaintiff Donaldo Mondragon, a resident of Silver Spring, Maryland, currently

lives in Building 8670 at the Flower Branch Apartments.

10. Plaintiff Yamileth Reyes Valladarez, a resident of Silver Spring, Maryland, lived

in Building 8701 at the Flower Branch Apartments. Ms. Valladarez continues to reside in Silver

Spring, MD.

11. Plaintiff Solomon M. Weldemariam, a resident of Silver Spring, Maryland, lived

in Building 8701 at the Flower Branch Apartments. Mr. Weldemariam continues to reside in

Silver Spring, MD.

12. The Plaintiffs named in paragraphs 5 through 11 are herein after collectively

referenced as “Class Representatives” or “Plaintiffs.”

13. Defendant Washington Gas Light Company is incorporated in, and has its

principal place of business in, Washington, D.C.

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 14. Defendant WGL Holdings, Inc. (“WGL”), is incorporated in, and has its principal

place of business in, Washington, D.C. It is a publicly traded company (NYSE: WGL) formed in

2000, and operates and owns Washington Gas.

15. WGL Holdings, Inc. and Washington Gas are collectively referred to herein as

“Washington Gas.”

16. Defendant Kay Management Co., Inc. (“Kay Management”) is incorporated in

Maryland, where it also has its principal place of business.

17. John Does are the manufacturers of the various parts that comprise the residential

gas service that serviced Building 8701 in the Flower Branch Apartments.

Jurisdiction and Venue

18. The Court has subject matter jurisdiction under D.C. Code § 11-921(a).

19. The Court has personal jurisdiction over Washington Gas and WGL because

Washington Gas is domiciled in, organized under the laws of, and maintains its principal place of

business in Washington, D.C. In addition, Washington Gas keeps its records and performs

significant corporate functions in the District – including the planning and implementation of

safety, inspection, and maintenance programs – and many of the acts and omission complained

of herein occurred within the geographic boundaries of the District of Columbia. D.C. Code

Ann. § 13-422.

20. The Court has personal jurisdiction over Kay Management because it transacts

business in the District of Columbia by, among other means that will be revealed through

discovery: (a) systematically and continuously advertising their properties to District residents;

(b) renting their properties to former District residents; (c) conducting regular business with

Washington Gas; and (d) requiring every resident at the Flower Branch Apartments to enter into

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a contract with Washington Gas in order to have cooking gas and hot water. Because of this

conduct, it is reasonable for Kay Management to anticipate that it would find itself in court in the

District. D.C. Code § 13-423(a)(1) and (b).

21. Venue is proper and convenient in this forum.

22. Venue is proper here in because a substantial part of the events or omissions

giving rise to Plaintiffs’ claims occurred in the District, and a substantial part of the wrongful

conduct of Washington Gas emanated from the District.

23. Moreover, both Defendants regularly and systematically conduct business in

Washington, D.C.

24. A central liability issue in this case arises from Washington Gas’s decisions and

failures to act, many of which took place at Washington Gas headquarters and its operations

located in the District.

25. The District and its citizens have an interest in regulating and holding accountable

businesses located in the District that engage in the wrongful conduct alleged here.

26. The District is convenient for all parties to this litigation and both Washington

Gas and Kay Management have bona fide connections to this forum.

27. Additionally, all physical evidence related to the cause of the explosion is no

longer located at the Flower Branch Apartments, but is instead in the possession of Washington

Gas and various federal agencies, including the Bureau of Alcohol, Tobacco, and Firearms, and

the National Transportation Safety Board, both of which have assumed jurisdiction over and

have performed investigations into the cause of the explosion.

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 Factual Allegations

28. Late in the evening on August 10, 2016, a resident of Building 8701 at the Flower

Branch Apartments was taking his trash out. As he passed by the gas meter room on the first

floor of his building, he heard a strange hissing noise and could smell natural gas. Before he

could return to his apartment to call for help, an explosion described as a “sonic boom” rocked

the surrounding area.

29. The fire, caused by the explosion and fed by leaking natural gas, spread with such

force and speed that the residents, most of whom had been asleep, had just seconds to escape.

They were forced to use any possible means of getting out as the stairs and floors and walls

collapsed around them. With the hallways full of smoke and flames, many jumped from their

balconies to the ground below.

30. Other residents, including those with children too small to jump, shouted

desperately from their upper floor windows, pleading for help. Some were forced to drop their

babies from the windows to terrified neighbors below.

31. Despite the residents’ efforts to save their families and one another, seven

residents died in the fire, including two young children. Scores more suffered physical injuries.

32. Those lucky enough to survive nonetheless endured great losses. Due to fire,

smoke, and water damage, residents lost their homes, family photos, life savings, identification

documents, furniture, and the contents of every room, closet, cabinet and shelf. Some were left

with nothing but what they grabbed when they fled their apartments.

33. Those residents who were eventually able to return home had no gas service, and

could not cook or run hot water. Many were displaced for several days, and were unable to get to

work. The heavy smell of smoke and gas remains, and the remnants of the collapsed and burned

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out buildings stand just feet from their doors as a daily reminder of that horrific evening and the

suffering that followed.

34. Before the explosion on August 10, residents of the Flower Branch Apartments

had informed Kay Management and authorities on many occasions that they could smell natural

gas.

35. Just weeks before the explosion, on July 25, 2016, a Building 8701 resident called

911 reporting a gas smell.

36. Despite this report and others, neither Kay Management nor Washington Gas

undertook appropriate inspections or repairs.

37. Washington Gas is the sole distributor of natural gas to Washington D.C.

residents through its residential gas service. Washington Gas serves over 1.1 million customers

in the Washington, D.C. region.

38. Washington Gas operates roughly 200 miles of Department of Transportation-

regulated transmission pipelines and thousands of miles of distribution pipelines.

39. The underground pipe, service lines, and equipment that distribute natural gas to

Building 8701 of the Flower Branch Apartments were installed by Washington Gas and should

have been monitored, inspected, serviced, and maintained by Washington Gas.

40. The Flower Branch Apartments, including Building 8701, are owned, managed

and maintained by Kay Management.

41. Kay Management should have monitored, inspected, serviced, and maintained the

meter room of Building 8701.

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 42. John Does manufactured and sold to Washington Gas the underground pipes,

service lines, and equipment that distribute natural gas to Building 8701 of the Flower Branch

Apartments.

43. Despite the 911 call from the resident of Building 8701 and numerous complaints

of natural gas odors by other residents, the Defendants did not properly inspect or remedy the

problem resulting in the tragedy of August 10, 2016.

Facts Related to Class Representatives

44. Plaintiff Ericka Jineth Hercules Ramirez lives in Building 8650 and witnessed the

events of August 10, 2016. Following the explosion, she and her family were displaced from

their home for a night. When they returned they did not have hot water or gas to cook. She still

does not feel safe in her apartment.

45. Plaintiff Rosali Amaya Benitez lives in Building 8640 and witnessed the events of

August 10, 2016. Following the explosion, he and his family were unable to return to their

apartment for several days and Mr. Benitez was unable to return to work until he could get back

into his apartment.

46. Plaintiff Abeba Heyi lived in Building 8703 and witnessed the events of August

10, 2016. As a result of the explosion and fire, her home was entirely destroyed. She lost

everything she owned. She was unable to return to her apartment and was permanently displaced.

47. Plaintiff Encarnacion Dubon Ortiz lives in Building 8644 and witnessed the

events of August 10, 2016. Following the explosion, he and his wife were unable to work until

they could return to their home several days later. They had extensive smoke damage to their

home and possessions.

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 48. Donaldo Mondragon lives in Building 8670 and witnessed the events of August

10, 2016. Following the explosion, he and his family were temporarily displaced from their

home.

49. Yamileth Reyes Valladarez lived in Building 8701 and witnessed the events of

August 10, 2016. As a result of the explosion, her home was entirely destroyed. She lost

everything she owned. She and her family were unable to return to her apartment and were

permanently displaced.

50. Plaintiff Solomon M. Weldemariam lived in Building 8701. His home was

entirely destroyed. He lost everything he owned. He was unable to return to his apartment and

was permanently displaced.

Class Definition and Class Action Allegations

51. Class Plaintiffs bring this action on behalf of themselves and others under Rule 23

of the District of Columbia Superior Court Rules of Civil Procedure.

52. Subject to revision as the case progresses through pretrial rulings and discovery,

the proposed class consists of all residents and residents’ guests of the Flower Branch

Apartments who sustained damages as a result of the August 10, 2016 explosion, excluding those

who sustained damages for personal injury or wrongful death.

53. Specifically excluded from the Class are Defendants, any entities in which

Defendants have a controlling interest, and Defendants’ agents and employees.

54. Numerosity: The Class is composed of approximately 75 households, and it is

impractical to individually join each household in a single action.

55. Commonality: Defendants have engaged in a standardized course of conduct that

affects all Class Members. A critical question of law and fact common to the Class will

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materially advance the litigation: whether the gas explosion was the result of Defendants’

wrongful conduct. Other questions of law and fact common to the Class exist as to all members

and predominate over any questions affecting only individual members, including the following:

a. Whether Washington Gas owed a duty to Plaintiffs and Class Members to

exercise due care in the installation, monitoring, inspection, servicing, and maintenance of the

underground pipe, service lines, and other equipment that distributes natural gas to Building 8701

of the Flower Branch Apartments;

b. Whether Washington Gas had a duty to exercise the degree of care

commensurate with the danger inherent in providing residential natural gas service;

c. Whether Washington Gas had notice of the natural gas leak prior to the

explosion and had a duty to take immediate and proper corrective action;

d. Whether Washington Gas is responsible for the gas meters and related

equipment at the Flower Branch Apartments;

e. Whether a defect in one or more of the products within the natural gas

delivery system was the proximate cause of the explosion;

f. Whether Kay Management owed a duty to maintain the Flower Branch

Apartments, including the gas meter room of Building 8701, in a reasonably safe condition;

g. Whether the natural gas leak in the meter room that caused the explosion

was the result of an unreasonably unsafe condition created by Kay Management’s failure to

inspect, maintain, and make necessary repairs;

h. Whether Kay Management knew or should have known that the failure to

take corrective action after repeatedly being made aware of natural gas odors would constitute an

unreasonable risk of harm to Plaintiffs;

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 i. Whether Kay Management failed to care for, maintain, and otherwise

operate so as to give Plaintiffs free and quiet enjoyment of said premises thereby breaching the

lease;

j. Whether Plaintiffs and Class Members were deprived of possession and

leasehold interest in part or all of the leased property; and

k. Whether Defendants owed a duty of care (prior to the explosion) to provide

truthful information regarding the existence of the natural gas leak and the risk associated

therewith.

56. Typicality: Plaintiffs’ claims are typical of the claims of the Class Members, as all

such claims arise out of the Defendants’ wrongful conduct, which is the proximate cause of the

damages sustained by Plaintiffs and Class Members. Further, the wrongful conduct of

Defendants renders each Class Member’s claims, legal theory, and injury common and typical.

57. Adequate Representation: Plaintiffs are adequate representatives of the Class

because their interests do not conflict with the interests of the Class, they will fairly and

adequately protect the interests of the Class, and the Plaintiffs are represented by counsel skilled

and experienced in class actions.

58. Predominance and Superiority: Class certification is appropriate because common

questions of law and fact predominate over questions affecting only individual Class Members

and a class action is the superior method of fair and efficient adjudication of this controversy.

The common liability issues in this class action may be resolved efficiently on a class-wide basis.

Should individual Class Members be required to bring separate actions, this Court and/or other

courts would be confronted with a multiplicity of lawsuits burdening the court system while also

creating the risk of inconsistent rulings and contradictory judgments. In contrast to proceeding on

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a case-by-case basis, in which inconsistent results will magnify the delay and expense to all

parties and the court system, this class action presents far fewer management difficulties while

providing unitary adjudication, economies of scale and comprehensive supervision by a single

court. The likelihood that individual members of the Classes will prosecute separate actions is

remote due to the time and expense necessary to conduct such litigation.

COUNT ONE
(Negligence – Washington Gas)

59. Washington Gas owed a duty to Plaintiffs to exercise due care in the installation,

monitoring, inspection, servicing, and maintenance of the underground pipe, service lines, and

other equipment that distributes natural gas to Building 8701 of the Flower Branch Apartments.

60. Washington Gas had a duty to exercise the degree of care commensurate with the

danger inherent in providing residential natural gas service.

61. Washington Gas had notice of the natural gas leak prior to the explosion and had

a duty to take immediate and proper corrective action to inspect, service, and repair the gas leak.

62. Washington Gas breached its duties to Plaintiffs by failing to use due care when

installing, monitoring, inspecting, servicing, and maintaining the underground pipe, service lines,

and other equipment that distributes natural gas to Building 8701 of the Flower Branch

Apartments. Further, Washington Gas breached its duty to Plaintiffs by failing to take corrective

action to properly inspect, service, and repair the gas leak.

63. Washington Gas’s failure to exercise the degree of caution commensurate with

the danger in providing gas services was the proximate cause of Plaintiffs’ injuries.

64. The damages sustained by Plaintiffs were a direct or a reasonably probable

consequence of the gas leak at Building 8701 of the Flower Branch Apartments.

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 65. Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Washington Gas for all compensatory damages for themselves and each member of

the Class.

COUNT TWO
(Product Liability – Washington Gas)

66. Washington Gas delivered gas to the Flower Branch Apartments through their

system of transmission, distribution, and service lines. Washington Gas is responsible for the gas

meters and related equipment at the Flower Branch Apartments. All of the products within this

system used to deliver natural gas to the Flower Branch Apartments are products owned and

controlled by Washington Gas.

67. A defect in one or more of the products within the natural gas delivery system

was the proximate cause of the explosion.

68. Washington Gas possessed actual knowledge of the product defects and

consciously and deliberately disregarded the foreseeable harm that might result from the defects.

69. The actual knowledge of Washington Gas includes, but is not limited to: (a) its

belief that there was likely a problem, accompanied by a failure to make a reasonable inquiry,

and (b) its willful refusal to know of the defects.

70. The defects within the gas delivery system were the proximate cause of injury to

Plaintiffs.

71. Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Washington Gas for all compensatory damages for themselves and each member of

the Class.

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 COUNT THREE
(Negligent Failure to Inspect and Maintain – Kay Management)

72. Kay Management owed a duty to Plaintiffs to maintain the Flower Branch

Apartments, including the gas meter room of Building 8701, in a reasonably safe but failed to do

so.

73. Kay Management knew or should have known that the failure to maintain the

Flower Branch Apartments, including, the gas meter room of Building 8701, would create an

unreasonable risk of harm to Plaintiffs.

74. The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition created by Kay Management’s failure to inspect, maintain, and

make necessary repairs.

75. The natural gas leak in the meter room was the result of an unreasonably unsafe

condition of which Kay Management had notice. By failing to properly inspect, maintain, repair,

or notify Washington Gas of the known unsafe condition, Kay Management breached its duty to

Plaintiffs. For all conduct described herein, all of the employees or agents of Kay Management

acted within their scope of employment.

76. Kay Management’s breach of its duty was the proximate cause of Plaintiffs’

injuries.

77. Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of

the Class.

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 COUNT FOUR
(Negligent Failure to Act - Kay Management)

78. Kay Management knew or should have known that the failure to take corrective

action after repeatedly being made aware of natural gas odors would constitute an unreasonable

risk of harm to Plaintiffs.

79. The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition created by Kay Management’s failure to take the appropriate

corrective action after being made aware of natural gas odors.

80. The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition of which Kay Management had notice. By failing to properly

inspect, maintain, repair, or notify Washington Gas of the known unsafe condition, Kay

Management breached its duty to Plaintiffs.

81. Kay Management’s breach of its duty was the proximate cause of Plaintiffs’

injuries.

82. Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of

the Class.

COUNT FIVE
(Breach of Contract – Kay Management)

83. Before August 10, 2016, Plaintiffs entered into or were the beneficiaries of a lease

agreement with Defendant Kay Management wherein it warranted and agreed that Plaintiffs

would be permitted to occupy a portion of the subject premises, and that the said premises would

be cared for, maintained, and otherwise operated so as to give Plaintiffs free and quiet enjoyment

of said premises.

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 84. On multiple occasions prior to the explosion, Kay Management was informed that

residents of Flower Branch Apartments could smell natural gas.

85. As a result of its acts or omissions, Kay Management failed to care for, maintain,

and otherwise operate the Flower Branch Apartments so as to give Plaintiffs free and quiet

enjoyment of said premises thereby breaching the lease.

86. Kay Management’s breach of the lease was the proximate cause of Plaintiffs’

injuries.

87. Plaintiffs suffered damages as a result of Kay Management’s breach.

88. Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of

the Class.

COUNT SIX
(Constructive Eviction – Kay Management)

89. Before August 10, 2016, Plaintiffs entered into or were the beneficiaries of a lease

agreement with Defendant Kay Management wherein it warranted and agreed that Plaintiffs

would be permitted to occupy a portion of the subject premises, and that the said premises would

be cared for, maintained, and otherwise operated so as to give Plaintiffs free and quiet enjoyment

of said premises.

90. On multiple occasions prior to the explosion, Kay Management was informed that

residents of the Flower Branch Apartments could smell natural gas.

91. As a proximate result of Kay Management’s acts or omissions, Plaintiffs were

deprived of possession and leasehold interest in part or all of the leased property.

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 92. Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of

the Class.

COUNT SEVEN
(Breach of Implied Warranty of Habitability – Kay Management)

93. Kay Management had a duty to maintain the leased premises in habitable

condition.

94. On multiple occasions prior to the explosion, Kay Management was informed that

residents of the Flower Branch Apartments could smell the odor of natural gas.

95. As a proximate result of Kay Management’s acts or omissions, Plaintiffs’

premises were left in an uninhabitable condition.

96. Plaintiffs, individually, and on behalf of the Class, demand judgment against

Defendant Kay Management for all compensatory damages for themselves and each member of

the Class.

COUNT EIGHT
(Product Liability – John Does)

97. John Does are manufacturers of the various parts that comprise the Washington

Gas system of transmission, distribution, and service lines for residential gas service to the

Flower Branch Apartments.

98. A defect in one or more of the products within the natural gas delivery system

was the proximate cause of the explosion.

99. John Does possessed actual knowledge of the product defects and consciously and

deliberately disregarded the foreseeable harm that might result from the defects.

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 100. The actual knowledge of John Does includes, but is not limited to: (a) their belief

that it was probable that there was a defect accompanied by a purposeful failure to make a

reasonable inquiry, and (b) their willful refusal to know of the defects.

101. Plaintiffs, individually, and on behalf of the Class, demand judgment against the

John Doe Defendants for all compensatory damages for themselves and each member of the

Class.

Relief Sought

102. Plaintiffs seek the following relief for themselves and the class:

a. An Order certifying the proposed class, naming Plaintiffs as the Class

representatives for the Class, and appointing their counsel as Class Counsel;

b. Judgment in favor of Plaintiffs and the Class for all damages, including

damages for being rendered homeless and displaced, harm to personal property, loss of use of

personal property, loss of use of household goods or wearing apparel, loss of the benefit of

leasehold interests, lost wages, additional expenses, nuisance, interference with enjoyment of

property, annoyance and inconvenience, the total of which does not exceed $5 million.

c. A declaration that Defendants are financially responsible for providing

notice to the Class;

d. Injunctive and equitable relief designed to prevent similar tragedies in the

future, both at Flower Branch Apartments and at other locations serviced by Washington Gas or

Kay Management.

e. Attorneys’ fees and costs,

f. Pre-judgment and post-judgment interest; and

g. All other relief as the Court deems just and proper.

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 Jury demand

Plaintiffs demand a trial by jury on all counts.

November 2, 2016 Respectfully submitted,

________________________
Brian A. Glasser (DC 1024003)
Cary Joshi (DC 1028594)
Bailey Glasser LLP
1054 31st Street NW, Suite 230
Washington, DC 20007
T: (202) 463-2101
F: (202) 463-2103
bglasser@baileyglasser.com
cjoshi@baileyglasser.com

John W. Barrett (pro hac to be filed)

Bailey Glasser LLP
209 Capitol Street
Charleston, WV 25301
T: (304) 345-6555
F: (304) 342-1110
jbarrett@baileyglasser.com

Nicholas Katz (pro hac to be filed)

CASA
8151 15th Ave.
Hyattsville, MD 20793
T: (240) 491-5743
nkatz@wearecasa.org

Deepak Gupta (DC 495451)

Matthew W.H. Wessler (DC 985241)
Gupta Wessler PLLC
1735 20th Street NW
Washington, DC 20009
T: (202) 888-1741
deepak@guptawessler.com
matt@guptawessler.com

Counsel for Plaintiffs and the Putative Class

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