Professional Documents
Culture Documents
Defendants.
Jets LLC (“Jets LLC”) (JSD and Jets LLC are referred to, together,
PRELIMINARY STATEMENT
purchase season tickets for 200-level seats for all New York Jets
substantially worthless.
PARTIES
Connecticut.
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jurisdiction.
jurisdiction.
the New York Jets football team plays its home games at Metlife
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11. Jets LLC owns and operates the New York Jets professional
13. Jets LLC and JSD are affiliated entities, both owned by
JSD a PSL for two 200-level seats in the Stadium (the “Seats”), at
a cost of $4,000 per seat, for a total of $8,000 (the “PSL Fee”).
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and PSL Seat Confirmation are referred to, together, as the “PSL
Agreement”).
Plaintiff to pay the PSL Fee and states that Plaintiff: “shall
for the Seats for all pre-season and regular season home games of
the Jets scheduled to be played at the Stadium and (ii) shall have
for the Seats for all post-season home games of the Jets scheduled
case for as long as the Jets play home games at the Stadium and at
“PSLs are good for as long as the Jets play in the new building in
http://www.newyorkjets.com/tickets-and-stadium/faq.html (last
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at the Stadium.
Plaintiff, for the first time, that season tickets for seats
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29. Upon information and belief, Jets LLC has sold and is
CLASS ALLEGATIONS
defined as follows:
33. The members of the Class for whose benefit this action
impracticable.
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Even if: (i) putative Class members purchased PSLs covering only
half of the 200-level seats, and (ii) the average putative Class
1,000 members.
members;
members;
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violations thereof;
Agreements; and
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individual litigation.
orderly and expeditious process for the Class members, and will
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Counsel has knowledge of the applicable law for this action and
COUNT I
(BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING –
Jets Stadium Development, LLC)
length herein.
47. JSD’s conduct, as set forth above, has had the effect of
under its PSL Agreement with Plaintiff and the proposed Class
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COUNT II
(Violations of the New Jersey Consumer Fraud Act – Jets Stadium
Development, LLC and New York Jets LLC)
length herein.
2.
right to purchase season tickets for 200-level seats for all Jets
level seats for all Jets home football games at Metlife Stadium
of purchasing a PSL.
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dealing.
COUNT III
(Truth-in-Consumer Contract, Warranty and Notice Act – Jets
Stadium Development, LLC)
length herein.
15.
Plaintiff, and the PSL Agreements used by JSD with members of the
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N.J.S.A. 56:12-15.
PSL Agreement shall not exceed the amount of the PSL Fee paid by
less than $100 for each such violation or actual damages, together
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follows:
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BY:/s/Jeffrey W. Herrmann
Jeffrey W. Herrmann
A Member of the Firm
Dated: March 16, 2018
in this matter.
BY:/s/Jeffrey W. Herrmann
Jeffrey W. Herrmann
A Member of the Firm
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follows:
Member of the firm Cohn Lifland Pearlman Herrmann & Knopf LLP,
attorneys for the Plaintiff and the Putative Class in the above-
proceeding.
contemplated.
this action.
/s/Jeffrey W. Herrmann
Jeffrey W. Herrmann
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Case Caption: GENGO JAMES VS JETS STADIUM Case Type: COMPLEX COMMERCIAL
DEVELOP MENT, LLC Document Type: Complaint
Case Initiation Date: 03/16/2018 Jury Demand: NONE
Attorney Name: JEFFREY W HERRMANN Hurricane Sandy related? NO
Firm Name: COHN LIFLAND PEARLMAN HERRMANN & Is this a professional malpractice case? NO
KNOPF Related cases pending: NO
Address: PARK 80 WEST - PLAZA ONE 250 PEHLE AVE If yes, list docket numbers:
STE 401 Do you anticipate adding any parties (arising out of same
SADDLE BROOK NJ 07663 transaction or occurrence)? YES
Phone:
Name of Party: PLAINTIFF : Gengo, James, T
Name of Defendant’s Primary Insurance Company
(if known): Unknown
I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)