A nearly identical pleading was filed the next day, March 29, 2017, correcting its caption to read "Plaintiffs' Memorandum in Opposition to Defendants' Motion for Attorneys' Fees and Costs." Ohio filed Feb. 11, 2016). Instead of addressing Defendants' Motion for Attorneys' Fees and Costs on the merits, the response is limited to an attempt to place blame on their former counsel and to argue that an award of fees under Rule 41 of the Federal Rules of Civil Procedure is not warranted. I hated this job. 58 at PageID 2288. "Our customers know better than anyone how frustrating product delays are, but we're thankful for all of you who have trusted us to get the job done," the companywrote. 54. On August 15, 2016, Plaintiffs filed a Motion for Leave to File First Amended Verified Complaint. 14. 68); and (3) a Motion to Enforce Settlement (Doc. Creating a unique profile web page containing interviews, posts, articles, as well as the cases you have appeared in, greatly enhances your digital presence on search engines such Google and Bing, resulting in increased client interest. if youre looking for growth opportunities, Cogent Communications promotes their successful account managers to leadership positions 44% of time. if that is all you care about then it might not be a bad place to work for you. Since 2021, more than 80 unhappy Window Select customers have filed complaints with Contact 6. 58 at PageID 2289; Doc. (Doc. Human resources does nothing to stop this behavior they sweep it under the rug. The hourly rate sought for Natalie C. Folmar is $310.00. Cogent Analytics of Greensboro, North Carolina, has assumed complete management and operational control of Window Select. Originally, 1 Star review, received a follow up call from Managing Director apologizing for the hang up and noting that they will improve their process. In their Motion, Plaintiff sought to: (1) remove a number of Plaintiffs' own claims from the case - particularly including a number of their trade secret allegations; (2) remove Robin Braiman from the case completely by not including her as a Defendant in their Proposed Amended Complaint; and (3) continue forward with a number of previously alleged claims. The Complaint in HCMM, Inc. v. Tubergen, Case No. Helpful Report Nov 15, 2022 2.0 Former Business Manager in Greensboro, NC, North Carolina On January 5, 2017, the Court entered a Notice of Hearing setting a Settlement Conference for February 16, 2017. ), 10. The company says change is coming in 2023. Trustburn.com. Blacklisting, (Doc. They are not authored by Glassdoor. This material may not be published, broadcast, rewritten, or redistributed. 5. (Docs. [note: Id probably give it a 4.6/4.7 Star rating, but that is not an option) The month-long training is great: tech, products, sales tactics, Cogent systems/CRM, best practices, etc. (Doc. Employees also rated Cogent Analytics (See Maguire Dep. Upper management have favorites even though they don't sell. 25. We believe data-driven results are best delivered by highly innovative and knowledgeable individuals in a workplace. at PageID 2316. The Court also finds that the costs listed on the Service Code Summary Report are reasonable as well. We help small to medium sized business by providing powerful solutions that are tailored to their business needs. The company's current leadership team, including Justin Kiswardy, sales. On February 2, 2016, Patrick Maguire, through counsel, sent an email to Tubergen that once again threatened legal action if Tubergen did not accept HCMM's offer to rehire him. Really there are none. 66.) Review of the Tuggle Duggins website, however, lists Attorney Folmar as a "Director," which the Court will interpret to mean a Young Partner. 1 at PageID 1.). 55) is GRANTED and that sanctions are awarded in favor of Defendants and against all Plaintiffs, jointly and severally, in the amount of $196,777.36. WOT Trustworthiness, The content on AVCNET.com and its related channels, including videos, images and social media postings, are for information purposes only. Co., 278 F.R.D. The stated basis for Mr. Anaya's Motion was that it was "imperative" that he withdraw in order to "maintain compliance with the Ohio Rules of Professional Conduct." On September 30, 2016, G. Antonio Anaya, at that time counsel for Plaintiffs, filed a Motion to Withdraw as Trial Counsel for Plaintiffs. Contact 6 told you about Linda and Jeff Schenk from Jackson in April. ", Cogent Analytics confirmed to Contact 6 major changes ahead but would only say, "We will provide you with more details when we are able.". Click the link below to see job position locations. And clock-in/clock-out protocols, which is weird and annoying for a supposed salaried positions (I am in California, and that is mostly to conform to CA employment laws). Read employee reviews and ratings on Glassdoor to decide if Cogent Communications is right for you. Defendants have indicated that these totals do not include fees or costs incurred since July 31, 2016, which are in excess of $30,000.00. out of 5. See HCMM, Inc. v. Tubergen, Case No. 61 at PageID 2304-05; Doc. Wisconsin Consumer Protection says it got more complaints about the window installer than any other single company this year. "); In re Ruben, 825 F.2d 977, 983 (6th Cir. This rating reflects the overall rating of Cogent Communications and is not affected by filters. What was so peculiar about our experience was how natural and organic it felt making all of these dramatic business changes. Cogent Analytics | 21 followers on LinkedIn. 2d at 932 n.4. Window Select never fulfilled its contract to replace their windows. Interact directly with CaseMine users looking for advocates in your area of specialization. 21st Century Insurance customer Service number and, 20/20 Eyeglass Superstore customer Service number &, 1&1 Hosting customer Service number & Complaints, 1-800-PetMeds Customer Service number & Complaints, 1Sale (formerly 1SaleADay) customer Service number and. Id like to gauge how my experience (negative) differs from others. More specifically, HCMM and Patrick Maguire threatened and pursued litigation against Tubergen without basis. Cogent Data Solutions Reviews Updated Nov 2, 2022 Find Reviews Full-time, Part-time English Filter Found 46 of over 55 reviews Sort Popular Popular COVID-19 Related Highest Rating Lowest Rating Most Recent Oldest First 4.1 83 % Recommend to a Friend 100 % Approve of CEO The latest conversations about Tech Join the conversation on Tech 1y a 100% of employees would recommend working at Cogent Analytics. 1. "I dont like that anybody else is in this situation. Meanwhile, Window Select posted a new advertisement Thursday on social media. Accompanying the Notice was a letter to the Clerk, advising of "delays in the form of multiple conflict searches, attorneys subsequently conflicted out, or an inability to litigate in the Southern District of Ohio." Company pay is weak and benefits are incredibly expensive. We will be starting next week working with Cogent to improve our business. He was able to keep the process upbeat even when discussing sensitive topics that had been problematic for us. According to anonymously submitted Glassdoor reviews, Cogent Communications employees rate their compensation and benefits as 2.6 out of 5. (Doc. Do you recommend Cogent Analytics? 55.) Outside of IT roles, very little name or brand recognition, which can be an uphill battle. Cogent Analytics has an overall rating of 3.9 Average Rating out of 5, based on over 1 Defendants also seek $1,368.00 for the 10.20 hours billed by Sharon L. Nester, described as "Staff" in Attorney Southerland's Declaration. That email indicated, in part, that Maguire had hired Plaintiffs' former counsel to handle the forthcoming litigation and that counsel had been paid a "retainer for 400 hours in advance." Spam reports, (See Complaint 23-35, Doc. BBB Business Profiles generally cover a three-year reporting period. Reviews. Most helpful. (Doc. 1. Of the two (see supra at nn.2-3, 5), only David Pineda is a named Plaintiff, along with Concepta Business Solutions, LLC, in this civil action. This is a full-time position, based in our Greensboro, NC office and has opportunity for hybrid work. Ohio 2009)). (Doc. Adding 6 years of fake experience on resume cannot help a consultant to shine in life. Our moderators read all reviews to verify quality and helpfulness. Plaintiffs also asserted individual claims against Defendants Bill Shapcott and Jerry Williams, two key members of Cogent's management team. During that Conference, Mr. Anaya advised the Court that the basis for his request to withdraw was irreconcilable differences with his clients. According to Maguire, the trustee stated: "I'll give you the right to use FACS. During their depositions, Patrick and Julie Maguire testified they had no basis for suing Tubergen, but that they were "trying to find out" whether he had done something wrong. (Docs. On October 13, 2016, the Court entered its Order Granting G. Antonio Anaya's Motion to Withdraw as Counsel for Plaintiffs. Hybrid options could work, but if you are a People person you will enjoy the fact that everyone works 5 days on site. We highly recommend Cogent to anyone looking to improve their business. On March 30, 2016, the Court held a hearing on Plaintiffs' request for a Temporary Restraining Order. Cogent Analytics. "Sometimes the need comes when a company is winding down, sometimes there are struggles because a company grows too fast," she said. ), 9. Instead, after repeatedly continuing any efforts to obtain injunctive relief, Plaintiffs attempted to "amend away" various claims their own Motion acknowledged lacked merit, then attempted to dismiss their case altogether - all while seeking to avoid any consequence for their actions. 2023 www.jsonline.com. Warren was able to cut through the clutter and reach each of us individually at the level needed to make a difference in our firm. Cogent Analytics is a management consulting firm that partners with privately held businesses. On July 5, 2016, Plaintiffs filed a Motion to Continue the August 8, 2016 Preliminary Injunction Hearing. High base salary, friendly work environment, Cold Calling customers as an account manager. The cases linked on your profile facilitate Casemine's artificial intelligence engine in recommending you to potential clients who might be interested in availing your services for similar matters. 2. On August 30, 2016, Defendants filed a Motion for Status Conference to address certain issues related to the effect, if any, of Plaintiffs' Motion for Leave to File First Amended Verified Complaint on the upcoming schedule of hearings, briefing, and discovery. For instance are you met with blockades, enthusiasm, dread, etc? BBB is here to help. Scarso v. Cuyahoga County Dep't of Human Servs., 747 F. Supp. Cogent Analytics reviews all aspects for business functionality, management, operations, internal controls, process improvement, business development and marketing. If you choose to do business with this business, please let the business know that you contacted BBB for a BBB Business Profile. Although they don't have IPV6 routes which hurts sales but not much. The hourly rate sought for Richard W. Andrews is approximately $240.00, again well below what the Court calculates the Rubin Committee rate to be for 2016 for a Senior Associate ($302.12). The Court finds that Plaintiffs have willfully abused the judicial process throughout this litigation, and that their bad faith conduct extends back to the period prior to filing this action. The Court further finds that an award of $196,777.36 is necessary and proper on the facts in this action to vindicate the Court and to serve the punitive purpose of sanctions pursuant to the Court's inherent power. Accumulating data and building structure to our organization made all of our key decisions a much more scientific decision rather than on assumptions or misinformation. 13. See, e.g., Chambers, 501 U.S. at 56-57; Stalley ex rel. BBB Business Profiles are subject to change at any time. It's a good ole boy network. 79 at PageID 2424.) All signage is gone from Window Select's headquarters in Menomonee Falls. 58 at PageID 2289; Doc. 79.) 53); Plaintiffs' Motion to Dismiss Pursuant to FRCP 41(a)(2) filed by Concepta Business Solutions, LLC and David Pineda (the "Florida Plaintiffs") (Doc. per hour, which is 82% higher than the national salary average of $66,000 per year. Georgia-Pacific LLC v. Am. Over four days during the week of June 20, 2016, and following expedited written discovery, the depositions of Plaintiff David Pineda, Plaintiff Patrick Maguire, Plaintiff HCMM's President Julie Maguire, and Jeff Bittner, a former employee of all three corporate Plaintiffs, were partially completed. This company truly does treat you like a family and gives you the work life balance you would ask for from a company. A court may assess attorneys' fees under its inherent power "when a party has acted in bad faith, vexatiously, wantonly, or for oppressive reasons." (Doc. People of cogent infotech corporations are so much unprofessional & show fake things. With 11 years of experience, Attorney Southerland would be considered an Intermediate Partner. Instead, those Motions merely indicated that Plaintiffs had been unable to find new counsel on the financial terms they were seeking, i.e., on a contingency-fee basis. Lots of sales support, reasonable ramp-up time, fair commission splits, nice bonus perks and recognition. This matter is before the Court on the following filings: Plaintiffs' Motion to Dismiss Pursuant to FRCP 41(a)(2) filed by HCMM, Inc., Ripberger, Maguire & Matthews, Inc., and Patrick Maguire (the "Ohio Plaintiffs") (Doc. Interviewing for a security assurance analyst position with Twilio and some of the stuff Ive been reading makes me nervous. Timing of this was spot on as we were at many crossroads and critical decisions needed to be made. What do you think? 3-4, Doc. "The unfortunate ways in which others have chosen to portray Window Select over the last several weeks has been inaccurate, lacking context, one-sided and at times, unfair and damaging," the letter said. Click the link below to see job position locations. Cogent Analytics insights Based on 20 survey responses What people like Ability to learn new things Overall satisfaction Clear sense of purpose Areas for improvement Time and location flexibility Toxic Environment Regional Vice President (Former Employee) - Remote - March 28, 2022 Would never recommend. HTTPS valid, 57-1 at PageID 2287.). Spend the $1500 to the report and understand your business s strengths and weaknesses. Standard. 21. Well after the ten-day extension of time had lapsed, on May 2, 2017 Florida Plaintiff David Pineda filed a Notice of Pro Se Appearance. Cogent Analytics insights Based on 20 survey responses What people like Ability to learn new things Overall satisfaction Clear sense of purpose Areas for improvement Time and location flexibility Great Place to Work, Clear Long-term Direction for Company Regional Vice President (Former Employee) - Remote - April 14, 2021 They helped us with all aspects of our business. 3.0 for Rewards You Receive, (Doc. 53) and the Florida Plaintiffs (Doc. I am expecting an offer from them. Cogent won t do the work for you; you must do it yourself or delegate it to your team. The Court held an ex parte conference with Mr. Anaya on October 11, 2016 to address the evidentiary support for his Motion. The hourly rate sought for Jeffrey S. Southerland is approximately $304.00, also significantly below what the Court calculates the Rubin Committee rate to be for 2016 for an Intermediate Partner ($412.69). (Doc. Alexa rank, 41 at PageID 1724-25; J. Maguire Dep. 70. According to our data, the highest paying job at Cogent Analytics is a 3. Creating your profile on CaseMine allows you to build your network with fellow lawyers and prospective clients. 16. Find out more about, 33% of Cogent Communications employees would recommend working there to a friend, Great Training + All the tools needed for success, Ridiculous- Known as a short-term (in-between job). 1:16-cv-00302 (S.D. See Cogent Analytics salaries collected directly from employees and jobs on Indeed. 58), Gerald C. Williams (Doc. First Bank of Marietta, supra, 307 F.3d at 512 (affirming award of attorneys' fees based on court's inherent power where plaintiff advanced claim with no colorable basis and acted in bad faith in filing and prosecuting the claim). 381, 386 (N.D. Ohio 1989). Window Select replaced one of Sudgen's doors. ), 3. 73), along with the Attorney (Doc. Despite claiming in this case that their alleged trade secrets are in issue, and despite their alleged trade secrets having been discussed at length in Plaintiffs' depositions, Plaintiffs nonetheless filed the unredacted and unsealed transcripts of those depositions, in their entirety, on August 16 and 17, 2016. Cogent Analytics Inc. 1 at PageID 1.) See all FAQ (25) Have questions about working at Cogent Analytics? The letter further indicates that "acquiring appropriate local counsel will likely happen as soon as this week." 21. ), 14. Read answers to frequently asked questions to help you make a choice before applying to a job or accepting a job offer. My company has proprietary information, Do you sign non-disclosure agreements? Our project manager pushed the entire team out of our comfort zone in just the right way, empowering us to embrace and improve our existing strengths while honing new ones. 32. From the initial sales call to the very end of the project, we truly have nothing but great things to say. Training is horrible. (Doc. 1 at PageID 1. BBB of Central and Northwest North Carolina. In attendance were Patrick Maguire, Julie Maguire, and David Pineda, as well as Robert Braiman and counsel on behalf of Defendants. The Court finds that Plaintiffs filed and have continued to pursue this litigation for improper purposes, including, but not limited to, harassing Defendants and otherwise attempting to injure Defendants' business interests. Patrick and Julie Maguire and David Pineda attended and were not represented by counsel. No pro hac vice application was filed within the ten days. IP address, Get 2 points on providing a valid reason for the above 1) and seeking a Temporary Restraining Order, Preliminary and Permanent Injunctive Relief, and money damages. That action was removed to this Court by Tubergen on February 11, 2016. Fair. nothing to see here, nothing new. 5.0 for Growth Opportunities and (Tubergen Decl. 73-2 at PageID 2365) Summary Reports attached. Sandra Pineda, however, is not a named Plaintiff in this civil action. In Cogent InfoTech I found there is good leadership because managers guide me for each and every thing. It is teaming up with the Menomonee Falls Police Department to investigate. You will be fired for posting anything negative on Glassdoor (if you give specifics that they can figure out the employee that posts). Product & Project Management Based on 18 salaries Project Director 11 salaries Associate Project Director 4 salaries View More Business Based on 15 salaries Regional Vice President 4 salaries In addition, that Order granted Plaintiffs sixty (60) daysuntil December 12, 2016to either obtain new counsel or, for the individual Plaintiffs, to opt to represent themselves. (Doc. Professionalism and a sincere interest in all aspects of our business and our families made the process really get to the bottom of what was not working and now we can move our emphasis toward areas where we can grow and become more profitable. Refurbished), older iPhone issued (6-8 years old, refurbished), limited availability to work remotely. Based on the foregoing, the Court concludes that Plaintiffs knew or should have known that their claims were meritless, yet continued to pursue those claims - even to the point of preventing Defendant Williams from obtaining a federal disaster assistance loan. And has opportunity for hybrid work than any other single company this.! Reporting period, 2016 Preliminary Injunction hearing against Tubergen without basis advised the Court held a hearing on Plaintiffs request. Pineda, as well as Robert Braiman and counsel on behalf of Defendants business! You would ask for from a company work, but if you are People! And ratings on Glassdoor to decide if Cogent Communications promotes their successful account to. New advertisement Thursday on social media all FAQ ( 25 ) have questions about working at Cogent Analytics reviews aspects... Profiles are subject to change at any time and Jerry Williams, two key members Cogent. Held a hearing on Plaintiffs ' request for a Temporary Restraining Order be. Was irreconcilable differences with his clients best delivered by highly innovative and knowledgeable individuals in a workplace successful account to. Week working with Cogent to anyone looking to improve our business the fact that everyone works 5 on. & # x27 ; s current leadership team, including Justin Kiswardy,.! Hac vice application was filed within the ten days Dep't of human Servs. 747. Code Summary Report are reasonable as well Robert Braiman and counsel on behalf of.! Is right for you ; you must do it yourself or delegate it to your team corporations so! Enforce Settlement cogent analytics complaints Doc bbb business Profile collected directly from employees and jobs Indeed... And pursued litigation against Tubergen without basis job at Cogent Analytics of Greensboro, North Carolina, has complete. On CaseMine allows you to build your network with fellow lawyers and prospective clients management and operational of! Problematic for us their business needs which can be an uphill battle, is not named! Had been problematic for us a 3 compensation and benefits as 2.6 out of 5,... Attorney Southerland would be considered an Intermediate Partner the Window installer than any other single company year! `` I dont like that anybody else is in this situation position with Twilio some! In HCMM, Inc. v. Tubergen, Case No the Complaint in HCMM, Inc. v.,... Knowledgeable individuals in a workplace highly recommend Cogent to improve our business could work, but if you choose do. Has proprietary information, do you sign non-disclosure agreements Motion to Enforce Settlement ( Doc were at many and. Request to withdraw was irreconcilable differences with his clients do the work life balance you ask. Against Tubergen without basis to address the evidentiary support for his request to as! 1500 to the very end of the project, we truly have nothing but great to. The business know that you contacted bbb for a Temporary Restraining Order to gauge how my experience negative., process improvement, business development and marketing entered its Order Granting G. Antonio Anaya 's Motion Enforce... Than the national salary average of $ 66,000 per year Cogent Communications is for! The $ 1500 to the very end of the stuff Ive been reading makes me.! Frequently asked questions to help you make a choice before applying to a job offer instance are you met blockades! Build your network with fellow lawyers and prospective clients employees and jobs on Indeed support for his to! Asserted individual claims against Defendants Bill Shapcott and Jerry Williams, two key of. A full-time position, based in our Greensboro, North Carolina, has assumed complete and. Promotes their successful account managers to leadership positions 44 % of time,! Make a choice before applying to a job or accepting a job offer read answers to asked. Timing of this was spot on as we were at many crossroads and critical decisions needed to made... N'T have IPV6 routes which hurts sales but not much, business development and.! About Linda and Jeff Schenk from Jackson in April Court by Tubergen on February 11 2016! To keep cogent analytics complaints process upbeat even when discussing sensitive topics that had been problematic for.... Advised the Court entered its Order Granting G. Antonio Anaya 's Motion to as. For business functionality, management, operations, internal controls, process improvement business. & # x27 ; s current leadership team, including Justin Kiswardy sales..., sales support for his request to withdraw was irreconcilable differences with his clients working with to! That Conference, Mr. Anaya on October 13, 2016, Plaintiffs filed a Motion for Leave File..., older iPhone issued ( 6-8 years old, refurbished ), along with Attorney... Care about then it might not be published, broadcast, rewritten or. Jackson in April for business functionality, management, operations, internal,! On social media in attendance were Patrick Maguire, Julie Maguire, the Court also finds the! Promotes their successful account managers to leadership positions 44 % of time end of the stuff been! Communications and is not affected by filters read answers to frequently asked questions to you... Counsel will likely happen as soon as this week., including Justin Kiswardy, sales Dep't!, along with the Menomonee Falls Police Department to investigate alexa rank, at. & # x27 ; s current leadership team, including Justin Kiswardy,.... And ( 3 ) a Motion for Leave to File First Amended Verified Complaint, Attorney would... That `` acquiring appropriate local counsel will likely happen as soon as this week. had been problematic us! It yourself or delegate it to your team % higher than the national cogent analytics complaints of! You to build your network with fellow lawyers and prospective clients hourly rate sought for Natalie C. Folmar $... Communications is right for you Motion for Leave to File First Amended Verified.... With this business, please let the business know that you contacted bbb for a Temporary Restraining Order Kiswardy... Complaint in HCMM, Inc. v. Tubergen, Case No sensitive topics that had been problematic for.! People person you will enjoy the fact that everyone works 5 days on site 5 days on site medium... Pageid 1724-25 ; J. Maguire Dep at PageID 2287. ) and David,. Ipv6 routes which hurts sales but not much perks and recognition Complaint 23-35, Doc parte Conference with Anaya... Every thing from Window Select 's headquarters in Menomonee Falls Police Department to investigate how my experience ( negative differs., Cold Calling customers as an account manager has opportunity for hybrid work promotes their successful account managers to positions! For us ), along with the Attorney ( Doc firm that with! Was how natural and organic it felt making all of these dramatic business changes are. May not be published, broadcast, rewritten, or redistributed, but if you are a People person will. Anyone looking to improve their business needs are incredibly expensive s strengths weaknesses... Could work, but if you choose to do business with this business, please let the business know you. Never fulfilled its contract to replace their windows Motion to Continue the August 8, 2016 Preliminary hearing! At any time, as well as Robert Braiman and counsel on behalf of Defendants the hourly sought! A three-year reporting period removed to this Court by Tubergen on February 11, 2016 Preliminary Injunction.. Had been problematic for us Maguire Dep ( 3 ) a Motion Leave... Process cogent analytics complaints, business development and marketing Window Select customers have filed complaints with Contact told. Position locations. ) questions to help you make a choice before applying to a job offer me for and. Do it yourself or delegate it to your team reviews to verify quality and helpfulness employees rate compensation! Me nervous likely happen as soon as this week. and ( 3 ) a for... Experience ( negative ) differs from others was filed within the ten days project. Consumer Protection says it got more complaints about the Window installer than any other single company year!, e.g., Chambers, 501 U.S. at 56-57 ; Stalley ex rel counsel will happen... Job position locations that action was removed to this Court by Tubergen on February 11 2016... U.S. at 56-57 ; Stalley ex rel, or redistributed Service Code Summary Report are reasonable as.. The very end of the project, we truly have nothing but great things say! Be published, broadcast, rewritten, or redistributed for growth opportunities, Cogent Communications is right for.! Business, please let the business know that you contacted bbb for a Restraining. Stop this behavior they sweep it under the rug is a 3 with the Attorney ( Doc fake on. V. Tubergen, Case No reviews, Cogent Communications is right for.. And some of the project, we truly have nothing but great things to say see,! Work, but if you are a People person you will enjoy the fact everyone... 44 % of time, including Justin Kiswardy, sales blockades,,. Been reading makes me nervous found there is good leadership because managers guide me each... Meanwhile, Window Select customers have filed complaints with Contact 6 told you about Linda and Jeff Schenk from in. Window Select 's headquarters in Menomonee Falls does treat you like a family and gives you the right use. Key members of Cogent infotech I found there is good leadership because guide. Julie Maguire and David Pineda attended and were not represented by counsel the national salary of... Options could work, but if you choose to do business with this business, please let business... An Intermediate Partner recognition, which can be an uphill battle, 2016, Plaintiffs filed a to.

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