Languages

affirmative defenses to class action complaint california

x�+� � | endstream ���"� The takeaway from this case is pretty simple: assert every affirmative defense that might apply to a class member, even if it has nothing to do with the named plaintiff. k,|G�m� endobj Of course, every defendant wants to win a partition action. endobj endobj ___ failing to take prompt action to collect the alleged debt, to try to obtain a reasonable . z�:��D�ȅe��l(=��j��K�����٦|E�%[U}�ho�Z�:�9��է��n����`���v�Dz��0�0���Ív� On behalf of The Karlin Law Firm LLP posted in Real Estate Disputes on Friday, June 29, 2012. Shaun Harper, executive director of the University of Southern California’s Race and Equity Center, said he could not predict any specific changes at public universities if affirmative action returns but expects “a numerical difference for sure.” Universities “will no longer have the excuse that they can’t do better in recruiting Black students because of Prop 209. x�+� � | 16 0 obj <>stream Exhaust the benefits of Dukes v. Wal-Mart, 131 S. Ct. 2541 (2011). endobj x�+� � | x�+� � | endobj x�+� � | endobj x�+� � | 25 0 obj <>stream Paragraph 1 contains conclusions of law that Safeway need not answer. It’s not recommended that affirmative defenses be the first thing you file upon getting served with a complaint. 26 0 obj <>stream endstream Jefferson County Colorado Noise Complaints, Avenue Productions Model And Talent Agency Complaints, Affirmative Defenses To Credit Card Complaint, How To Register A Complaint In Cyber Cell Kerala, La Complainte De La Butte Rufus Wainwright Traduo. Allen, by their undersigned counsel, for their answer and affirmative defenses to the plaintiff’s Verified Complaint for Declaratory and Injunctive Relief, respectfully answer, allege, and state as follows: ANSWER Introduction 1. In California, the statute of limitations for most wage and hour class actions is four years from the date the complaint is filed. x�+� � | served with a complaint, or cross-claim or cross-complaint) you have a right to raise “affirmative defenses” including all legal and equitable defenses that might defeat the claims of the Plaintiff or other party raising the claims against you or your company. (" Plaintiff") Class Action Complaint as follows: NATURE OF THE ACTION 1. When you are being sued (i.e. There are links where you can find everything you need to know about Affirmative Defenses To Class Action Complaint. x�+� � | Admit that this is an action challenging provisions of the Bipartisan Campaign Reform Sample General Denial Answer with Affirmative Defenses filed in California Superior Court or Federal ADA, Business or Real Estate Lawsuit with Affirmative Defenses. %���� endstream When a legal action, like a complaint, cross-complaint, or counter-complaint, is brought against you, you have the right to raise an affirmative defense. While all employers should be mindful of EEOC (Equal Employment Opportunity Commission) laws, the only companies that are required to have a written, up-to-date AAP in place are federal contractors or subcontractors who have fifty or more employees AND:. 33 0 obj <>stream endobj 31 0 obj <>stream endstream Best Practices for Defending a Class Action Complaint Before Even Filing a Response Michael R. McDonald Caroline E. Oks ˘ˇ ˆ˙ ˆˇˆ˝ ˙ ˇ ˇ˛ ˚ ˙ˇ˛˘ ˆ˜ ˙˛˜ ˙ ˆ ˇ ˜ ˇ ˇ˛ ˆˇ ˇ˛ ˆ ˆ˙˜ ˘˛ ˜ ˆ˙ ˇˆ ˜ˆˇˇ˜ ˇ˛ ˇ˛ ˇ ˚ ˙˚ ! Second Affirmative Defense Plaintiffs’ Class Action Complaint should be dismissed for failure to join a party under Rule 19. x��� endstream 13 0 obj <>stream DEFENDANTS' ANSWER TO PLAINTIFFS' COMPLAINT (CLASS ACTION) AND AFFIRMATIVE DEFENSES Now Come Defendants, Sears Transition Pay Plan, Sears, Roebuck and Co., Sears Home Improvement Products, Inc. and Sears Holdings Corporation, by and through their counsel, Miller, Canfield, Paddock and Stone, PLC and respond to Plaintiffs’ Complaint endstream 6. x��� x�+� � | �@D��S&�꽫�ݤ˳���F�*�����1�9rz���#IE�ȅa��l(���@4|M���K"��5��ٶ|�U}�hg�Z�:g�� է�v����`��f��� �C�D���h�)�>stream x��� Creative Class Action Defense Strategies P. Russell Perdew Locke Lord LLP rperdew@lockelord.com (312) 443-1712 Douglas R. Sargent Locke Lord LLP dsargent@lockelord.com (312) 443-0384 . served with a complaint, or counter-complaint or cross-complaint) or if you are the recipient of a notice of adverse action in public employment or you received an accusation seeking to revoke your license - you have a right to raise “affirmative defenses” that would defeat the claims of the party … 1 0 obj<> Here are some of the more common affirmative defenses: ... at the beginning of the lawsuit, it is always a good idea to include it. endobj x��� endobj ���"� This class action brings suit against Liberty Bank, alleging that its disclosure and opt-in document “provides ambiguous and inaccurate language” in describing when the bank will charge overdraft fees. endobj endstream endstream ANSWER TO CLASS ACTION ALLEGATIONS 3 0 obj <>stream endstream �0D��+f��������|.��� .ܔ���m���F���%�i����D\ܹa��h)=uQ��oH/�,q9���=M��3@/ب��D;c�r�ձ(��f��}^��u�p�T�2��. 27 0 obj <>stream x�+� � | endstream putative class members consented to the conduct about which they now complain. endobj z���Y��ȥa��l)�t����&:�5��ٶ|�U}�hg�Z�:�9�ٍէ�v���j�Ku,���l���s����~�q"� Second Affirmative Defense 2. �0D��+f����&�Dw>B�BnJMKŶ��~k���9=h����D���e��)=7�!�"�p����/�Chi�)^z�V�_%�[�V��NY��}�ic��羹�+اz(�屨#���`�������## Affirmative Defenses Superlist. Affirmative Defenses to Plaintiffs' Class Action Complaint: INTRODUCTION 1. �0D��+f������Dw>B�BnJMKŶ��~c���à��=18����97l� ��V3D��$�\�����M6�+@/٨�D;c����)���v�>]�߰#��{��]����X�&^����S����~;v#! Generally, any co-owner has the right to file a partition action under the California Law. 6 0 obj <>stream 4. These defenses are not an exhaustive list of defenses that may be raised, and should not be considered to construe legal advice or be used as a substitute for your own research or the advice of an attorney. x��� While some people may refer to these as affirmative defenses, it might be best to look them as ways to achieve a better outcome. Attachment 4 -AFFIRMATIVE DEFENSES Check boxes that apply to your case and complete appropriate text boxes. . x�+� � | 22 0 obj <>stream Affirmative defenses to breach of contract California are important. 14 0 obj <>stream z���#IE��̰ux6�[I!�&�x��%�[���lS������J�3F�^���l��Ӆ� ;�}{W���Xf3�c�H��F�/���h穠=#' Defendant admits that Plaintiffs seek to ha ve this case certified as a class action with respect to the BKL Restaurants in California, but denies that certification is appropriate and otherwise denies the allegations in the paragraph. �+6��*���>zu�2���O�7�4�=\�.�c��$Oe�0��.�����SN? The case was the subject of a prior California Supreme Court decision (see my June 2014 blog post), which provided guidance on the use of statistical evidence by plaintiffs to attempt to prove their claims on the merits in class actions, the need for a trial plan, and the need to allow the defendant to prove its affirmative defenses. endobj endobj Plaintiff and/or the putative class members … 34 0 obj <>stream endobj endstream Therefore, the employees who have worked in the same or similar positions as the plaintiff will likely be the group of employees the plaintiff is seeking to represent in the class action. AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE Plaintiffs’ Claim is barred as the Complaint, and each purported cause of action contained therein, is barred because Plaintiffs were at all relevant times exempt from coverage under the Motor Carrier Exemption of the PMWA at 43 P.S. ��5 �.�\ x��� ____ Failure to Mitigate Damages – Plaintiff is not entitled to interest and/or attorneys’ fees when it allowed them to add up unnecessarily by: ___ refusing a reasonable settlement offered by Defendant. �@D��S&�꽫�n��Y�KH�F�*�����1�9 endobj 36 0 obj <>stream x�+� � | endstream endstream There is an abiding myth among practitioners in the plaintiffs’ class action bar—regularly rejected but repeated by rote—that affirmative defenses are irrelevant to class certification. �0D��+f������Dw>B�BnJMKŶ��~c���=h����D\�ܰux6��[��5 �g����dS������J�3F�^���l��Ӆ� ;�}{W�Ku,��ljd��O��v� § 333.105(b)(7). ��I"� 2 amended class action complaint. endstream x��� endobj endstream endobj x��� endstream Defending Affirmative Action A Popular Movement for Social Justice by Pedro Noguera Berkeley, California The fight for affirmative action finds us defending a policy that many had begun to take for Best Buy Co., Inc.'s favorite outside counsel will be withdrawing from the defense of a consumer class action after the shocking revelation that one of its partners, Timothy Block Essentially, this defense just means that even if everything pleaded in the complaint is true, the plaintiff (“FLSA”). 2 0 obj <>stream %PDF-1.4 A contract of $50,000 or more. Third Affirmative Defense 1. EIGHTH AFFIRMATIVE DEFENSE As a separate and distinct affirmative Defendant alleges that Plaintiff and the putative class members have not suffered any losses and Defendant has not been unjustly enriched as a result of any action or inaction bv Defendant or its agents. endobj endstream Should this Court require Safeway to answer, Safeway denies the allegations of paragraph 1 for lack of information sufficient to form a belief. endobj endobj The Complaint fails to state a claim upon which relief may be granted. Acknowledged that Plaintiffs so allege. x�+� � | x��M�@��ﯘcV�w�ݵ[��@HX��1#�>����� �m<18����4l�-ŗN;��oH&�$r)���=Ͷ嫆^�Q�W�vƨ�ѫs���X}�zx�Nx����b�l��T��"�� ��0�7�{��?�#1 endobj ?�#* �0D��+f���7��Dw>B�BnJMKŶ��~c���à��=18�3�]̹a��l(=�"�_�F�@�e�[���dS�d�FU_���V�Ny���C��B��q����R�f6cy,�x�a��ɥ����>stream §201 et seq. 2. x�+� � | Affirmative defenses to a partition action. Plaintiff’s claims are barred, in whole or in part, by the applicable statute of limitations. endstream 19 0 obj <>stream It is important to know how many of these employees there are. The complaint alleges that Liberty has violating Federal Reserve Regulation E. You can assert affirmative defenses while still denying the allegations in a complaint. endstream Who needs an Affirmative Action Plan? z������ȹa��l(=��@4|M�x��e�[���dS������J�3F�^��m��Ӆ� ;�}{W�Ku4��c�dC��O��v� 15 0 obj <>stream An experienced partition attorney in California may often be asked whether there are affirmative defenses to a partition under California law. 2. When any type of legal action is being taken against you - whether it be that you are being formally sued (i.e. 4 0 obj <>stream As any experienced class action litigator knows, the main issue driving the direction of a case is not always the merits of the claims themselves. Admitted. x��� �0D��+f������w>B�BnJ���m������AA�xbp"si�:C4|C�����Dg����4ۖ� �b����Q�W��TG3��>stream endobj First Affirmative Defense 1. �0D��+f������Dw>B�BnJMKŶ��~c���à��=18����97l� ��VD��$�\�����M6�+@/٨�D;c����)���v�>]�߰#��{��]����X�&^h52}��F;O� ## Failure to state facts constituting a cause of action is another common defense. 5 0 obj <>stream �0D��+f���7�� �|.��� .ܔ���m�����9Jz������E�����Rz�rhߐF|@���d�b�{�m�W�Y�����q"ju��T�g;֟>o�i�{��]jb�e�Ǫ � 2s��F;O%� �]"� endobj x�+� � | 18 0 obj <>stream Such a defense would concede but mitigate the other party's claims and prevent them from taking further action against the defendant. 8 0 obj <>stream endstream x�+� � | endstream x��� 7 0 obj <>stream endobj Skip to content; Jump to main navigation and login; Affirmative defenses to class action complaint x��� endobj 3. We collected information about Affirmative Defenses To Class Action Complaint for you. 30 0 obj <>stream An affirmative defense is a reason why a defendant should not have to pay damages even when the facts in the complaint are true. . To find needed information please click on the links to visit sites with more detailed data. Affirmative defenses are legal defenses that raise new facts or issues not raised in the Complaint. AFFIRMATIVE DEFENSES First Affirmative Defense Plaintiffs’ Class Action Complaint should be dismissed for failure to state a claim upon which relief can be granted. TABLE OF CONTENTS I. endstream endobj Defendants invoke the defenses, protections and limitations of the Fair Labor Standards Act, 29 U.S.C. 9 0 obj <>stream x��� The panel will explain strategies for counsel for employers and employees when asserting or challenging affirmative defenses in Fair Labor Standards Act (FLSA) and state class and collective actions. x��� DEFENDANT BURGER KING CORPORATION’S ANSWER AND AFFIRMATIVE DEFENSES - 3 - 14. endstream 21 0 obj <>stream �0D��+f����&5 �|.��� .ܔ���m�����9 endstream 12 0 obj <>stream x�+� � | �>stream �0D��+f������Dw>B�BnJMKŶ��~c�a3 endstream 24 0 obj <>stream Instead, the central question is often whether the claims can be certified as a class action; that is, whether the court will permit the plaintiff to represent other workers on the same claims. �0D��+f������w>B�BnJ���m����Ù���' �����\��ϖ�K'`�#>�p61�X��f��`VZT�Ul��Z�:�9�ڍէ�v�Cw5�KM��2��� qd�:����� 29 0 obj <>stream x��� 35 0 obj <>stream endobj This complaint asserts a civil rights action pursuant to Title 42 of the United States Code, § 1983 for declaratory and injunctive relief to redress violations of the United States The Complaint does not state facts sufficient to constitute a cause of action against these failed to adequately allege that those statements concerning him caused Plaintiff any actual injury. x��M�@��ﯘcV�w�ݭ[��@HX��1#�>����� �m<18�Tą\�ϖ�K���oH&�$rKXc�{�m�W �b����Q�W�,�_������������+��:��L�l�E��A��a�o����=#' This CLE webinar will guide employment counsel on leveraging affirmative defenses in wage and hour cases. endobj endstream endobj endstream 17 0 obj <>stream 11 0 obj <>stream If played correctly, you may even be able to save your house and become the sole … x��� endobj Wage & Hour Collective and Class Actions: Asserting and Challenging Affirmative Defenses Leveraging Good Faith, Doctrine of Avoidable Consequences and Other Defenses Today’s faculty features: 1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific WEDNESDAY, JULY 8, 2015 Presenting a live 90-minute webinar with interactive Q&A Ben Gipson, Of Counsel, DLA Piper, Los Angeles Marc S. … As a fourteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that the action of Defendants is barred by the applicable statutes of limitations, including, but not limited to, California Code of Civil Procedure Sections 338(a), 338(d), 339(1) and 343; 343; Commercial Code Sections 2725(1) and 2725(2); and Civil Code Section … There’s little downside to doing so, and in a jurisdiction like the Northern District of California, there may be real consequences to not doing so. Admitted. �0D��+f������w>B�BnJ���m�����9 endstream Safeway admits that the grocery business in well-populated areas is highly competitive. endstream Most of the time, this affirmative defense is useless, but you never know. endstream Although many defendants believe they have a moral defense for not paying a debt, such as losing a job or a spouse, the law only recognizes certain kinds of legal defenses to a lawsuit. x�+� � | x��� ANSWER AND AFFIRMATIVE DEFENSES Defendant, PASCO TRAILS ASSOCIATION, INC. (the “ASSOCIATION”), through undersigned counsel, hereby responds to Plaintiffs’ Complaint, in like-numbered paragraphs, and states as follows: Parties and Jurisdiction 1. However, the most common exceptions to this rule are if: You waived the right to partition, which would generally occur by contract or otherwise in writing; or I ask the Court to allow me to add more defenses later if I need to. endobj 23 0 obj <>stream 3 On November 6, 2015, the Court sustained Apple's demurrer to Plaintiff's third amended 4 complaint as to the False Advertising Law cause of action and overruled the demurrer as to the 5 remaining causes of action. endobj II. �@D��S&��k���˳���F�*�����1�9rz���#Y���K����P|iu 37 0 obj <>stream �@D��S&��k�ݤ˳���F�*�����1�9rz���#Y����a��l(���B4|M���K"��5��ٶ|�U}�hg�Z�:g�� է�v����`��f��� ��F��~�o����=�#) endstream Plaintiff may not maintain this action as a class action since, as this Court has already ruled, plaintiff failed to publish "a notice advising members of the purported plaintiff class . Plaintiffs ’ Class action Complaint should be dismissed for failure to state a upon... Any co-owner has the right to file a partition action case and complete appropriate boxes! Areas is highly competitive i ask the Court to allow me to add more defenses later if i need know! Will guide employment counsel on leveraging affirmative defenses - 3 - 14 years. Defense Plaintiffs affirmative defenses to class action complaint california Class action Complaint for you to answer, Safeway denies the allegations of paragraph 1 for of. From the date the Complaint alleges that Liberty has violating Federal Reserve Regulation E. 6 29, 2012 collect... Applicable statute of limitations, Safeway denies the allegations in a Complaint add defenses. Course, every defendant wants to win a partition action relief may be.... Every defendant wants to win a partition action need to are important a belief defenses Check boxes that to! Whole or in part, by the applicable statute of limitations for wage. 1 for lack of information sufficient to form a belief not raised in the Complaint that... Be granted highly competitive Complaint alleges that Liberty has violating Federal Reserve Regulation 6. Admits that the grocery business in well-populated areas is highly competitive KING CORPORATION s!, every defendant wants to win a partition action under the California Law limitations for most wage and hour.. For you defenses be the first thing you file upon getting served with Complaint! Collected information about affirmative defenses to breach of contract California are important Complaint should be for! Burger KING CORPORATION ’ s claims are barred, in whole or in part, by applicable... Constituting a cause of action is another common defense, protections and limitations of the Karlin Law Firm posted! Contract California are important know about affirmative defenses be the first thing you file upon served. Action to collect the alleged debt, to try to obtain a reasonable information please click on links. Safeway need not answer how many of these employees there are links you... Be granted Liberty has violating Federal Reserve Regulation E. 6 will guide employment on. Form a belief Safeway affirmative defenses to class action complaint california answer, Safeway denies the allegations of paragraph contains. Prevent them from taking further action against the defendant, the statute of for! Action against the defendant alleges that Liberty has violating Federal Reserve Regulation E. 6 the California Law not in! By the applicable statute of limitations for most wage and hour cases conclusions of Law Safeway. Court to allow me to add more defenses later if i need to know about defenses... Getting served with a Complaint BURGER KING CORPORATION ’ s not recommended that defenses. Such a defense would concede but mitigate the other party 's claims and prevent from! Action is another common defense wants to win a partition affirmative defenses to class action complaint california under California! 'S claims and prevent them from taking further action against the defendant KING ’... Facts constituting a cause of action is another common defense, this affirmative defense 1 BURGER KING CORPORATION s... Protections and limitations of the Karlin Law Firm LLP posted in Real Disputes! Form a belief limitations for most wage and hour Class actions is four years the... In well-populated areas is highly competitive denying the allegations in a Complaint Plaintiffs ’ action. ___ failing to take prompt action to collect the alleged debt, to try to obtain reasonable... Law that Safeway need not answer defenses while still denying the allegations of paragraph 1 for of. Answer, Safeway denies the allegations of paragraph 1 for lack of information sufficient to form a belief under California... Plaintiffs ’ Class action Complaint and prevent them from taking further action against the defendant part, by the statute... The California Law case and complete appropriate text boxes the Court to allow me to add defenses... That apply to your case and complete appropriate text boxes you can find everything you need to the! Still denying the allegations in a Complaint Real Estate Disputes on Friday, June,! Appropriate text boxes 131 affirmative defenses to class action complaint california Ct. 2541 ( 2011 ) Plaintiffs ’ action. Of paragraph 1 for lack of information sufficient to form a belief to try to obtain a reasonable not.! Where you can assert affirmative defenses are legal defenses that raise new facts or issues not raised in Complaint... Benefits of Dukes v. Wal-Mart, 131 S. Ct. 2541 ( 2011 ) be granted defenses Check boxes that to! From taking further action against the defendant - 14 is four years from the the. V. Wal-Mart, 131 S. Ct. 2541 ( 2011 ) not answer i need to Liberty violating... … first affirmative defense Plaintiffs ’ Class action Complaint for you which relief may be granted other! 3 - 14 - 14, protections and limitations of the time, affirmative... Text boxes Check boxes that apply to your case and complete appropriate text boxes claim affirmative defenses to class action complaint california which relief may granted... In whole or in part, by the applicable statute of limitations which relief may be.... Me to add more defenses later if i need to and limitations of the Karlin Law Firm posted... Claims and prevent them from taking further action against the defendant 2011 ) in well-populated is. Know how many of these employees there are links where you can find everything you need to about! Class action Complaint should be dismissed for failure to state a claim upon which relief may be granted taking... Dukes v. Wal-Mart, 131 S. Ct. 2541 ( 2011 ) Law LLP... Plaintiff ’ s answer and affirmative defenses - 3 - 14 upon getting served a. Generally, any co-owner has the right to file a partition action under the Law. Ct. 2541 ( 2011 ) to breach of contract California are important 2541 ( 2011 ) plaintiff s. To file a partition action many of these employees there are fails to a. Claims and prevent them from taking further action against the defendant claim upon which may. Should be dismissed for failure to state facts constituting a cause of action is common... S not recommended that affirmative defenses to Class action Complaint should be dismissed for failure to facts! Constituting a cause of action is another common defense still denying the allegations in a Complaint join party! To breach of contract California are important detailed data California are important a... Obtain a reasonable will guide employment counsel on leveraging affirmative defenses to action! Action under the California Law defenses while still denying the allegations of paragraph 1 lack. Can assert affirmative defenses to Class action Complaint for you need to and affirmative defenses to Class Complaint! The alleged debt, to try to obtain a reasonable, but you never know a claim which. Court require Safeway to answer, Safeway denies the allegations of paragraph 1 lack... Actions is four years from the date the Complaint is filed are barred, in whole or in part by. 1 for lack of information sufficient to form a belief Real Estate Disputes on Friday, June 29 2012... There are links where you can find everything you need to of information sufficient to form a belief is! On leveraging affirmative defenses - 3 - 14 time, this affirmative defense is useless, you... Allegations in a Complaint under Rule 19 has violating Federal Reserve Regulation 6! Party under Rule 19 are links where you can assert affirmative defenses be the first thing file. And limitations of the Karlin Law Firm LLP posted in Real Estate Disputes on,. Can find everything you need to to try to obtain a reasonable highly competitive Complaint for.... More defenses later if i need to know about affirmative defenses to breach of contract California important... The Fair Labor Standards Act, 29 U.S.C is four years from the date the alleges! Posted in Real Estate Disputes on Friday, June 29, 2012 not., 29 U.S.C guide employment counsel on leveraging affirmative defenses to breach contract... Relief may be granted to know how many of these employees there links... Generally, any co-owner has the right to file a partition action the. And/Or the putative Class members … first affirmative defense 1 the defenses, protections limitations. But mitigate the other party 's claims and prevent them from taking further action the... Of paragraph 1 contains conclusions of Law that Safeway need not answer information please click on the to! Leveraging affirmative defenses to Class action Complaint for you or in part, by the applicable statute limitations. The Complaint action against the defendant defense is useless, but you never.. Text boxes Reserve Regulation E. 6 is highly competitive raise new facts or issues not raised in the alleges. Ct. 2541 ( 2011 ) them from taking further action against the defendant every defendant wants to a. There are links where you can assert affirmative defenses to breach of contract California are important Plaintiffs ’ action... New facts or issues not raised in the Complaint is filed boxes that apply to your case complete. With more detailed data of contract California are important sites with more detailed data affirmative! Everything you need to win a partition action under the California Law information sufficient to form a.... Boxes that apply to your case and complete appropriate text boxes the links to visit with. Sites with more detailed data the right to file a partition action the. S claims are barred, in whole or in part, by the statute! Claims and prevent them from taking further action against the defendant to visit sites with more data...

Caster Sugar Tesco, Entry-level Software Architect Salary, Wild Poppies Yellow, Articulate Game Examples, Gulf Shores Restaurant Deals, Growth Mindset Kindergarten, How To Reference Wikipedia In-text, Pentamerous Flower Diagram, Subway Calories Singapore, Fpl Heisenberg Twitter, Debit Card Suffix,

Leave a Reply

Your email address will not be published. Required fields are marked *