by and through counsel, and for their amended cause of action against all “Plaintiffs”), Defendants, state and allege as follows: PARTIES Plaintiff Markeeta Rivera is a citizen and resident of the State of New York. That at all times relevant herein, Plaintiff owned and operated a franchise of Impressive Cleaning Solutions, Inc., doing business as Stratus Building Solutions of Upstate New York. Plaintiff Guadalupe Clemente is a citizen and resident of the State of Arizona. That at all times relevant herein, Plaintiff owned and operated a franchise of PHSCCH SBS, LLC, doing business as Stratus Building Solutions of Metro Phoenix. This is a class action that the above named Plaintiffs bring on behalf of themselves and on behalf of all others similarly situated in the United States of America who have purchased franchises from Master Franchisees of Defendant Stratus Franchising, LLC, seeking a declaration that Defendants Simpatico, Inc., and Stratus Franchising, LLC, are liable to Plaintiffs and the class members for Defendants wrongful acts and the wrongful acts and conduct of the Master Franchisees. Defendant Stratus Franchising, LLC, (“Stratus Franchising”), is a limited liability company organized and existing under the laws of the State of Missouri; that Stratus Franchising, LLC, sold master franchises throughout the United States pursuant to Master Franchise Agreements entered into and accepted within the State of Missouri. Defendant Simpatico, Inc., (“Simpatico”) is a corporation organized and existing under the laws of the State of Missouri which previously did business as JAN-PRO
“Plaintiffs”), by and through counsel, and for their amended cause of action against all Defendants, state and allege as follows: PARTIES Plaintiff Markeeta Rivera is a citizen and resident of the State of New York. That at all times relevant herein, Plaintiff owned and operated a franchise of Impressive Cleaning Solutions, Inc., doing business as Stratus Building Solutions of Upstate New York. Plaintiff Guadalupe Clemente is a citizen and resident of the State of Arizona. That at all times relevant herein, Plaintiff owned and operated a franchise of PHSCCH SBS, LLC, doing business as Stratus Building Solutions of Metro Phoenix. This is a class action that the above named Plaintiffs bring on behalf of themselves and on behalf of all others similarly situated in the United States of America who have purchased franchises from Master Franchisees of Defendant Stratus Franchising, LLC, seeking a declaration that Defendants Simpatico, Inc., and Stratus Franchising, LLC, are liable to Plaintiffs and the class members for Defendants wrongful acts and the wrongful acts and conduct of the Master Franchisees. Defendant Stratus Franchising, LLC, (“Stratus Franchising”), is a limited liability company organized and existing under the laws of the State of Missouri; that Stratus Franchising, LLC, sold master franchises throughout the United States pursuant to Master Franchise Agreements entered into and accepted within the State of Missouri. Defendant Simpatico, Inc., (“Simpatico”) is a corporation organized and existing under the laws of the State of Missouri which previously did business as JAN-PRO