JETS FANS SUE PATRIOTS, BELICHICK
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
Carl J. Mayer, on behalf of himself and all others similarly situated,
Plaintiffs,
v.
Bill Belichick and The New England Patriots.
Defendants.
JURY TRIAL DEMANDED
CLASS ACTION
COMPLAINT
Plaintiffs, by their counsel, individually and on behalf of all others similarly situated, as and for their Complaint against Defendants assert upon information and belief as follows:
PRELIMINARY STATEMENT OF THE CASE
1. This case is brought by a New York Jets season ticket-holder on behalf of all similarly situated New York Jets season ticket-holders and other New York Jets ticket-holders against the Defendant New England Patriots and their coach, Defendant Bill Belichick. The core of this action is that the Defendants, during a game with the New York Jets on September 9, 2007, instructed an agent of the Defendants to surreptitiously videotape the New York Jets coaches and players on the field with the purpose of illegally recording, capturing and stealing the New York Jets signals and visual coaching instructions. The Defendants were in fact subsequently found by the National Football League (“NFL”) to have improperly engaged in such conduct. This violated the contractual expectations and rights of New York Jets ticket-holders who fully anticipated and contracted for a ticket to observe an honest match played in compliance with all laws and regulations.
2. Plaintiffs contend that in purchasing tickets to watch the New York Jets that, as a matter of contract, the tickets imply that each game played will be played in accordance with NFL rules and regulations as well as all applicable federal and state laws. Plaintiffs contend that Defendants tortuously interfered with their contractual relations with the New York Jets in purchasing the tickets. They further claim that Defendants violated the New Jersey Consumer Fraud Act and the New Jersey Deceptive Business Practices Act. Plaintiffs also claim that the Defendants violated federal and state racketeering laws by using the National Football League as an enterprise to carry out their illegal scheme. Because the Defendants have been found in other games by other teams to have illegally used video equipment, this action seeks damages for New York Jets ticket-holders for all games played in Giants stadium between the New York Jets and the New England Patriots since Bill Belichick became head coach in 2000.
JURISDICTION AND VENUE
3. This court has subject matter jurisdiction over the federal claims pursuant to 28 U.S.C. §1331, 28 U.S.C. §2201, 12 U.S.C. §3416, 12 U.S.C. §3417, 12 U.S.C. §3418, and over the state claims pursuant to 28 U.S.C. §1332 and 28 U.S.C. §1367.
4. Plaintiffs are informed, believe and thereon allege that Defendant has sufficient contacts with this district generally and, in particular, with the events herein alleged, that Defendants are subject to the exercise of jurisdiction of this court over the person of such Defendants and that venue is proper in this judicial district pursuant to 28 U.S.C. §1391. The proper venue for this is in the Newark vicinage because the acts complained of occurred in northern New Jersey.
5. Plaintiffs are informed, believe and thereon allege that, based on the places of business of Defendants identified above and/or on the national reach of Defendants, a substantial part of the events giving rise to the claims herein alleged occurred in this district and that Defendant and/or agents of Defendant may be found in this district. Plaintiffs and Defendants routinely engaged in business and transactions within this jurisdiction.
6. The amount in controversy exceeds $75,000.
PARTIES
7. Plaintiff Carl J. Mayer is a season ticket-holder and, as such, specifically purchased a ticket and parking pass for the game between the New York Jets and the New England Patriots on September 9 , 2007. Plaintiff is a life-long New York Jets fan and resides in Mercer County, New Jersey.
8. Defendant New England Patriots has its headquarters at One Patriot Place, Foxborough, Massachusetts 02035.
9. Defendant Bill Belichick resides at 116 Meadowbrook Road, Weston, Massachusetts 02493.
FACTUAL ALLEGATIONS RELATED TO ALL COUNTS
10. On September 9, 2007 the New York Jets and the New England Patriots played a professional football game in Giants Stadium, located in the Meadowlands in East Rutherford, New Jersey. Plaintiffs held tickets and parking passes to that game.
11. As first reported on the news website ESPN.com, the NFL began looking into claims a New England Patriots employee was videotaping signals by Jets coaches on New York's sideline during the season opener game played on September 9, 2007.
12. ESPN.com reported that NFL security confiscated a video camera and tape from a Patriots employee during New England's 38-14 victory over the Jets that day. The employee was accused of aiming his camera at the Jets' defensive coaches, who were sending signals out to the players, sources told ESPN.
13. The New England Patriots denied that they had violated League rules. New England cornerback Ellis Hobbs said publicly he was unwilling to believe his team had cheated. "We put too many hours in as individuals and a team to have to go out and cheat," he said. "If it's true, obviously, we're in the wrong. But I'm standing behind my team, my coaches. I don't think we do that stuff."
14. This was not the first time Defendants had been accused of cheating. In November 2006, the Green Bay Packers professional football team found a man wearing a Patriots staff credential and carrying a video camera on the sidelines at Lambeau Field, their home field. Teams are allowed to have a limited number of their own videographers on the sideline during the game, but they must have a credential that authorizes them to shoot video, and wear a yellow vest. But Packers spokesman Jeff Blumb said the person in question didn't have the right credential and wasn't wearing a yellow vest, so Packers security asked him to put away the camera and he was escorted out of the stadium.
15. After the videotape of the New York Jets game was confiscated on September 9, 2007, Patriots coach Bill Belichick apologized, saying: "Although it remains a league matter, I want to apologize to everyone who has been affected, most of all ownership, staff and players.” He refused to take questions from reporters about the NFL investigation, however, and stormed out of a weekly press conference with reporters on September 12, 2007.
16. On September 13, 2007, the NFL found the Defendants guilty of violating all applicable NFL rules by engaging in a surreptitious videotaping program. The New England coach, Bill Belichick, was fined $500,000 and the Patriots were ordered to pay $250,000 for stealing an opponent's defensive signals. NFL Commissioner Roger Goodell also ordered the Patriots to give up next year's first-round draft choice if it reaches the playoffs and second- and third-round picks if it doesn't. "This episode represents a calculated and deliberate attempt to avoid longstanding rules designed to encourage fair play and promote honest competition on the playing field," Goodell said in a letter to the Patriots. The Commissioner specifically imposed penalties on the Defendant Patriot organization because "Coach Belichick not only serves as the head coach but also has substantial control over all aspects of New England's football operations. His actions and decisions are properly attributed to the club." Patriot’s owner Robert Kraft refused to comment. The New York Jets issued a statement saying: "We support the commissioner and his findings."
17. The specific NFL rule violated by Defendants states: "no video recording devices of any kind are permitted to be in use in the coaches' booth, on the field, or in the locker room during the game." The rules also specifically state that all video for coaching purposes must be shot from locations "enclosed on all sides with a roof overhead." That was re-emphasized in a memo sent Sept. 6 to NFL head coaches and general managers. In it, Ray Anderson, the league's executive vice president of football operations wrote: "Videotaping of any type, including but not limited to taping of an opponent's offensive or defensive signals, is prohibited on the sidelines, in the coaches' booth, in the locker room, or at any other locations accessible to club staff members during the game."
18. Belichick appeared to accept full responsibility, stating on September 13, 2007: “Once again, I apologize to the Kraft family and every person directly or indirectly associated with the New England Patriots for the embarrassment, distraction and penalty my mistake caused. I also apologize to Patriots fans and would like to thank them for their support during the past few days and throughout my career.” But then, bizarrely, he attempted to deny responsibility, stating: “ We have never used sideline video to obtain a competitive advantage while the game was in progress…With tonight's resolution, I will not be offering any further comments on this matter. We are moving on with our preparations for Sunday's game."
19. The New York Jets ticket-holders who have purchased tickets to watch the Jets play the New England Patriots are not willing to move on. On information and belief, Defendants deployed their unlawful videotape program during every game played against the Jets in Giants stadium from 2000 through 2007, a total of eight games. The Defendants have turned over to the NFL many videotapes for further examination. Meanwhile, Jets fans have collectively spent well over $61 million on tickets to watch eight supposedly honest, competitive games between the New York Jets and New England Patriots between 2000 and 20007. This action seeks restitution for the money spent on games that were systematically and illegally tainted by the actions of defendants.
CLASS ACTION ALLEGATIONS
20. Pursuant to Federal Rules of Civil Procedure, Rule 23 (a) and (b), Plaintiff Carl J. Mayer brings this action on behalf of himself and a Nationwide Class of similarly situated persons defined as:
All New York Jets season ticket-holders and other ticket-holders who purchased tickets to games between the New York Jets and the New England Patriots in Giants stadium since Bill Belichick became the head coach of the New England Patriots in 2000.
21. The Nationwide Class seeks certification of claims for declaratory relief, injunctive relief and damages pursuant to 18 U.S.C. § 1961 et. seq., 12 U.S.C. § 3417 and 12 U.S.C. § 3418.
22. Plaintiffs also bring the claims on behalf of the following New Jersey Subclass defined as:
All individuals that are residents of the State of New Jersey and that purchased tickets to watch the New York Jets play the New England Patriots between 2000 and 2007 in Giants stadium.
23. The New Jersey Subclass seeks certification of claims for declaratory and injunctive relief, and for restitution.
24. Excluded from the Nationwide Class and New Jersey Subclass are the officers, directors, and employees of Defendants, and the legal representatives, heirs, successors, and assigns of Defendants.
25. This action is brought as a class action and may properly be so maintained pursuant to the provisions of the Federal Rules of Civil Procedure, Rule 23. Plaintiffs reserve the right to modify the Nationwide Class and the New Jersey Subclass definitions and the class period based on the results of discovery.
26. Numerosity of the Nationwide Class and New Jersey Subclass: Members of the Nationwide Class and New Jersey Subclass are so numerous that their individual joinder is impracticable. The precise numbers and addresses of members of the Nationwide Class and New Jersey Subclass are unknown to the Plaintiffs. Plaintiffs estimate that the Nationwide Class consists of tens of thousands of members and the New Jersey Subclass consists of thousands of members. The precise number of persons in both the Nationwide Class and New Jersey Subclass and their identities and addresses may be ascertained from Defendant’s records or the records of interested parties.
27. There is a well-defined community of interest in the questions of law and fact involved affecting the members of the Nationwide Class and New Jersey Subclass. These common legal and factual questions include: (a) Whether Defendants have engaged in racketeering by using the enterprise of the NFL to further an illegal scheme in violation of Racketeer Influenced and Corrupt Organizations Act (“RICO”) 18 U.S.C. 1961 et.seq. (b) Whether Defendants committed consumer fraud and engaged in unlawful business practices in violation of the New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. seq. and whether, as regards the New Jersey Subclass members’, the Defendants engaged in unfair, unlawful and/or fraudulent business practices in violation of the New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. seq.; (c) Whether Plaintiffs and New Jersey Subclass members are entitled to restitution, disgorgement of profits, or other equitable relief to remedy Defendant’s unfair, unlawful and/or fraudulent business practices; (d) Whether Plaintiffs and class members are entitled to recover compensatory, statutory and punitive damages, whether as a result of Defendant’s fraudulent, illegal and deceitful conduct, and/or otherwise; and (e) Whether Plaintiffs and class members are entitled to an award of reasonable attorneys’ fees, pre-judgment interest, and costs of this suit.
28. Typicality: Plaintiffs’ claims are typical of the claims of the members of the Nationwide Class and New Jersey Subclass because Plaintiff is a season ticket-holder and lifelong fan of the New York Jets. Plaintiffs and all members of the Nationwide Class and New Jersey Subclass have similarly suffered harm arising from Defendant’s violations of law, as alleged herein.
29. Adequacy: Plaintiffs are adequate representatives of the Nationwide Class and New Jersey Subclass because their interests do not conflict with the interests of the members of the classes they seek to represent. Plaintiffs have retained counsel competent and experienced in complex class action litigation and intend to prosecute this action vigorously. Plaintiffs and their counsel will fairly and adequately protect the interests of the members of the Nationwide Class and New Jersey Subclass.
30. This suit may also be maintained as a class action pursuant to Federal Rules of Civil Procedure, Rule 23(b)(2) because Plaintiffs and both the Nationwide Class and New Jersey Subclass seek declaratory and injunctive relief, and all of the above factors of numerosity, common questions of fact and law, typicality and adequacy are present. Moreover, Defendant has acted on grounds generally applicable to Plaintiffs and both the Nationwide Class and New Jersey Subclass as a whole, thereby making declaratory and/or injunctive relief proper.
31. Predominance and Superiority: This suit may also be maintained as a class action under Federal Rules of Civil Procedure, Rule 23(b) (3) because questions of law and fact common to the Nationwide Class and New Jersey Subclass predominate over the questions affecting only individual members of the classes and a class action is superior to other available means for the fair and efficient adjudication of this dispute. The damages suffered by each individual class member may be relatively small, especially given the burden and expense of individual prosecution of the complex and extensive litigation necessitated by Defendant’s conduct. Furthermore, it would be virtually impossible for the class members, on an individual basis, to obtain effective redress for the wrongs done to them. Moreover, even if class members themselves could afford such individual litigation, the court system could not. Individual litigation presents a potential for inconsistent or contradictory judgments. Individualized litigation increases the delay and expense to all parties and the court system presented by the complex legal issue of the case. By contrast, the class action device presents far fewer management difficulties, and provides the benefits of a single adjudication, economy of scale and comprehensive supervision by a single court.
COUNT I
Tortuous Interference With Contractual Relations.
32. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
33. Plaintiff and members of the class had a contract with the New York Jets under which the ticket-holders purchased the right to attend and observe the matches between the New York Jets and the New England Patriots.
34. Plaintiff and members of the class purchased tickets and entered into the contract with the New York Jets with the understanding, both express and implied, that the game will be played honestly and according to established rules and conditions that are known in advance by all parties.
35.The understanding that the New York Jets football games are to be played honestly and according to the agreed rules and conditions is a material condition of the ticket-holders’ contract.
36.Defendants’ intentionally and knowingly interfered with the ticket-holders’ contractual right and expectation to an honest match played according to the agreed rules and conditions by illegally recording and capturing the New York Jets’ coaching and player signals; Defendants did so for their own private benefit seeking to gain an illegal advantage over the New York Jets.
37. Accordingly, Defendants tortuously interfered with the contract and relationship between the members of the nationwide class and the New York Jets and are liable to plaintiff and other members of the class for restitution of the ticket prices for each of said games along with interest, attorney’s fees and cost of suit.
COUNT II
Common Law Fraud.
38. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
39. Defendants contracted repeatedly with the New York Jets and/or the NFL to play home football games at the New York Jets’ stadium at which it was known and understood that New York Jets ticket-holders would pay for the right to observe and attend the game.
40. New York Jets ticket-holders purchased tickets to said games under the express and implied condition that the game is to be played honestly and according to agreed rules and conditions.
41. Defendants individually and in concert violated this expectation and understanding by illegally recording and capturing New York Jets coaching and player signals, a direct violation of the agreed rules and conditions.
42. The ticket-holders including plaintiff and other members of the class, are direct beneficiaries, i.e., third party beneficiaries, of the contract between the Defendants and the New York Jets and/or the NFL.
43. Defendants entered into the game contracts with the New York Jets and/or the NFL with the intent to violate the agreed rules and conditions or entered into the individual games with such knowing intent.
44. Defendants concealed and omitted to make any disclosure of their intent to illegally record and capture the New York Jets coaching and player signals, an act that violated the agreed rules and conditions of the game contract.
45. It is a material condition to the purchase of tickets by Plaintiff and other members of the class that the participants in the game will pay honestly and according to the agreed rules and conditions.
46. Defendants concealed their intent to violate this material understanding.
47. Defendants committed the violation of the rule by stealth and surreptitious conduct by recording and capturing New York Jets signals by the use of a non-uniformed agent on the field.
48. Plaintiff and other members of the class relied to their detriment in purchasing tickets to the New York Jets-Patriots games.
49. Plaintiff and other members of the class were injured by their payment of money for the New York Jets – Patriots games.
50. It is a material and agreed fact, understanding and condition that the NFL games are to be played honestly and to be a match of contestants following the same essential rules and conditions. Plaintiff and, upon information and belief, other members of the class, would not have purchased tickets to the games if the Patriots and Belichick had disclosed that they intended to play the game corruptly and in violation of an essential and material game rule.
51. Accordingly, Defendants are liable in fraud to plaintiff and other members of the class for monies paid by the ticket-holders for the New York Jets’ home games with the Patriots, as set forth above, along with interest, attorney’s fees and costs of suit.
52. Defendants intentionally and knowingly acted to violate the game rule and knew or should have known that such rule is material to the honest performance of the game contract.
53. Defendants conspired to violate the game rule and did so by stealth and deception and have been previously caught committing similar acts.
54. Such violation corrupted the sport of football. Accordingly, Plaintiff and the class respectfully seek punitive damages be assessed against Defendants, along with interest, attorneys fees and costs of suit.
COUNT III
Deceptive Business Practices, N.J.S.A. 2C:21-7
55. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
56. By the aforesaid acts, Defendants violated N.J.S.A., 2C:21-7.
57. Accordingly, defendants are liable for the value of tickets purchased by Plaintiff and other members of the class for the New York Jets – Patriots games, along with treble damages, interest, attorney’s fees and cost of suit.
COUNT IV
New Jersey Racketeering, N.J.S.A., 2C:41-2
58. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
59. By their above described acts, Defendants, in violation of N.J.S.A. 2C:41-2, Defendants, individually and jointly, through a pattern of racketeering activity, (A) derived income, directly or indirectly, through certain enterprises owned and/or controlled by them that are engaged in the playing and performance of professional football games; (B) acquired and/or maintained, directly or indirectly, an interest in or control of the Enterprises, which affected trade or commerce; and (C) conducted and/or participated, directly or indirectly, in the conduct of the Enterprises’ affairs.
60. Upon information and belief, the Enterprises are (a) the New England Patriots football organization, (b) the National Football League; c) the New York Jets football organization.
61. The Enterprises engaged employees to perform and play the professional football games and to carry out the scheme to defraud and deceive.
62.Defendants engaged in a practice and pattern of racketeering by engaging in at least two incidents of racketeering conduct, one of which occurred after the effective date of N.J.S.A. 2C:41-1 et seq. and the last of which occurred within 10 years after a prior incident of such activity.
63.Defendants, by the above described acts, fraudulently induced consumers of New Jets tickets to purchase said tickets by concealing their intent to violate the agreed rules and conditions of the game contracts with the New Jersey Jets and/or the NFL and concealed and omitted to disclose to the ticket-holders their intent to subvert and corrupt the New York Jets home games by illegally recording and capturing the New York Jets coaching and player signals in violation of N.J.S.A. 2C:21-7 (deceptive business practices), causing damage to Plaintiff and class members.
64. Accordingly, Defendants are liable under the New Jersey racketeering statutes to the Plaintiff and other class members for restitution of the ticket prices paid for said games, along with treble damages, interest, attorneys fees and costs of suit.
COUNT V
The Racketeer Influenced and Corrupt Organizations Act,
18 U.S.C., 1961(a), (b), (c), (d)
65. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
66. Defendants, by their above described acts, engaged in a pattern of racketeering activity through the performance of at least two acts of racketeering within a ten year period through the use of the mails and/or the interstate wires as a material element of their scheme to defraud New York Jets ticket-holders.
67. Defendants received income derived, directly or indirectly, from a pattern of racketeering activity to use or invest or used, directly or indirectly, any part of such income, or the proceeds of such income, in acquisition of any interest in, or the establishment or operation of, any enterprise which is engaged in, or the activities of which affect, interstate or foreign commerce in violation of 18 U.S.C. 1962(a).
68.Defendants through a pattern of racketeering activity acquired or maintained, directly or indirectly, an interest in or control of an enterprise which is engaged in, or the activities of which affect, interstate or foreign commerce in violation of 18 U.S.C. 1962(b).
69.Defendants employed themselves or others in, or were ,associated with an enterprise engaged in, or the activities of which affect, interstate or foreign commerce, to conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs through a pattern of racketeering activity in violation of 18 U.S.C. 1962(c).
70. Defendants conspired to violate subsections (a), (b), or (c) of 18 U.S.C. 1962, as described in 18 U.S.C. 1962(d).
71. The above-described enterprises consisted of a) the New England Patriots football organization, b) the National Football League and c) the New York Jets football organization.
72. Defendants, by the above described acts, committed predicate acts through the use of the mails or interstate wires in furthering their fraudulent inducement of consumers of New Jets tickets to purchase said tickets by concealing their intent to violate the agreed rules and conditions of the Defendants’ game contracts with the New Jersey Jets and/or the NFL and concealed and omitted to disclose to the ticket-holders their intent to subvert and corrupt the New York Jets home games by illegally recording and capturing the New York Jets coaching and player signals, causing damage to Plaintiff and class members.
73. Accordingly, Defendants are liable under to Plaintiff and other class members for restitution of the ticket prices paid for said games, along with treble damages, interest, attorney’s fees and costs of suit.
COUNT VI
Violation of Ticket-holders rights as Third Party Beneficiaries.
74. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
75. Plaintiff and other class members is an intended third party beneficiary of the contracts between the New York Patriots and the New York Jets and/or the NFL.
76. The understanding that the New York Jets football games are to be played honestly and according to the agreed rules and conditions is a material condition of the Patriots’ contract with the New York Jets and/or the NFL and the ticket-holders are the intended third party beneficiaries of said contracts.
77. Defendants violated and interfered with the third party benefit to the ticket-holders by illegally recording and capturing the New York Jets’ coaching and player signals.
78. Accordingly, are liable to plaintiff and other members of the class as third party beneficiaries of the Patriots’ contract with the New York Jets and/or the NFL for restitution of the ticket prices for each of said games along with interest, attorney’s fees and cost of suit.
COUNT VII
CONTRACT
79. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
80. Plaintiffs plead in the alternative that they have an implied or quasi contract with the New England Patriots who violated such contract by illegally recording and capturing the New York Jets’ coaching and player signals.
81. Accordingly, Defendants are liable to Plaintiff and other members of the class as third party beneficiaries of the Patriots’ contract with the New York Jets and/or the NFL for restitution of the ticket prices for each of said games along with interest, attorney’s fees and cost of suit.
COUNT VIII
New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. Seq.
82. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
83. Defendants conduct violated The New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. Seq. by committing a fraud, deception, misrepresentation, unconscionable business practice, concealment, suppression and omissions in conducting their business in the State of New Jersey.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiffs for themselves and all others similarly situated respectfully request that the Court:
A. Declare that Defendant’s fraud, tortuous interference with contractual relations and violations of NFL policy as alleged herein violates applicable law including without limitation:
(i) The New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. Seq.
(ii) The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq.
(iii) The common law of tortuous interference with contractual relations.
(iv) The New Jersey Racketeering Law N.J.S.A., 2C:41-2
(v) The common law of fraud and contract.
(vi) Deceptive Business Practices, N.J.S.A. 2C:21-7
B. Award equitable relief, including without limitation, a preliminary and permanent injunction prohibiting Defendants’ continued or future videotaping in violation of NFL rules and New Jersey and federal law:
(i) Pursuant to The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq., as to the Plaintiffs and the Nationwide Class; and
(ii) Pursuant to the New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. seq., and the Deceptive Business Practices, N.J.S.A. 2C:21-7
C. Award statutory damages to the extent permitted by law to each Plaintiff and class member in the sum of:
(i) actual damages sustained by the customers in the amount of $61,6000,000 for the amount paid by New York Jets ticket-holders to watch eight fraudulent games between the New England Patriots and the New York Jets between 2000 and 2007.
(ii) treble damages pursuant to The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq.and the New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1 et. seq. for a total amount of compensatory damages of $184,800,000.00.
D. Award punitive damages to the extent permitted by law to each Plaintiff and class member, including without limitation:
(i) An appropriate sum pursuant to The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq.
(ii) An appropriate sum pursuant to the New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. seq.
E. Award to Plaintiffs attorneys’ fees and other costs of suit to the extent permitted by law, including without limitation pursuant to The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq. and the New Jersey Consumer Fraud Act. N.J.S.A. 56:8-1 et. Seq.
F. Award restitution, disgorgement, and all other relief allowed under the New Jersey Consumer Fraud Act as to the New Jersey Subclass.
G. Grant such other and further relief as the Court deems just and proper.
JURY DEMAND
Plaintiffs hereby request a jury trial for all issues triable by jury including, but not limited to, those issues and claims set forth in any amended complaint or consolidated action.
DATED: September 28, 2007 CARL J. MAYER, ESQ., on behalf of himself and all others similarly situated.
By: /s/ Carl J. Mayer, Esq. .
CARL J. MAYER, ESQ.
MAYER LAW GROUP LLC
66 Witherspoon Street, Suite 414
Princeton, NJ 08542
Telephone: 609/921-8025
Facsimile: 609/921-6964
_____________________
BRUCE I. AFRAN, ESQ.
10 Braeburn Drive
Princeton, NJ 08540
Telephone : 609-924-2075
FOR THE DISTRICT OF NEW JERSEY
Carl J. Mayer, on behalf of himself and all others similarly situated,
Plaintiffs,
v.
Bill Belichick and The New England Patriots.
Defendants.
JURY TRIAL DEMANDED
CLASS ACTION
COMPLAINT
Plaintiffs, by their counsel, individually and on behalf of all others similarly situated, as and for their Complaint against Defendants assert upon information and belief as follows:
PRELIMINARY STATEMENT OF THE CASE
1. This case is brought by a New York Jets season ticket-holder on behalf of all similarly situated New York Jets season ticket-holders and other New York Jets ticket-holders against the Defendant New England Patriots and their coach, Defendant Bill Belichick. The core of this action is that the Defendants, during a game with the New York Jets on September 9, 2007, instructed an agent of the Defendants to surreptitiously videotape the New York Jets coaches and players on the field with the purpose of illegally recording, capturing and stealing the New York Jets signals and visual coaching instructions. The Defendants were in fact subsequently found by the National Football League (“NFL”) to have improperly engaged in such conduct. This violated the contractual expectations and rights of New York Jets ticket-holders who fully anticipated and contracted for a ticket to observe an honest match played in compliance with all laws and regulations.
2. Plaintiffs contend that in purchasing tickets to watch the New York Jets that, as a matter of contract, the tickets imply that each game played will be played in accordance with NFL rules and regulations as well as all applicable federal and state laws. Plaintiffs contend that Defendants tortuously interfered with their contractual relations with the New York Jets in purchasing the tickets. They further claim that Defendants violated the New Jersey Consumer Fraud Act and the New Jersey Deceptive Business Practices Act. Plaintiffs also claim that the Defendants violated federal and state racketeering laws by using the National Football League as an enterprise to carry out their illegal scheme. Because the Defendants have been found in other games by other teams to have illegally used video equipment, this action seeks damages for New York Jets ticket-holders for all games played in Giants stadium between the New York Jets and the New England Patriots since Bill Belichick became head coach in 2000.
JURISDICTION AND VENUE
3. This court has subject matter jurisdiction over the federal claims pursuant to 28 U.S.C. §1331, 28 U.S.C. §2201, 12 U.S.C. §3416, 12 U.S.C. §3417, 12 U.S.C. §3418, and over the state claims pursuant to 28 U.S.C. §1332 and 28 U.S.C. §1367.
4. Plaintiffs are informed, believe and thereon allege that Defendant has sufficient contacts with this district generally and, in particular, with the events herein alleged, that Defendants are subject to the exercise of jurisdiction of this court over the person of such Defendants and that venue is proper in this judicial district pursuant to 28 U.S.C. §1391. The proper venue for this is in the Newark vicinage because the acts complained of occurred in northern New Jersey.
5. Plaintiffs are informed, believe and thereon allege that, based on the places of business of Defendants identified above and/or on the national reach of Defendants, a substantial part of the events giving rise to the claims herein alleged occurred in this district and that Defendant and/or agents of Defendant may be found in this district. Plaintiffs and Defendants routinely engaged in business and transactions within this jurisdiction.
6. The amount in controversy exceeds $75,000.
PARTIES
7. Plaintiff Carl J. Mayer is a season ticket-holder and, as such, specifically purchased a ticket and parking pass for the game between the New York Jets and the New England Patriots on September 9 , 2007. Plaintiff is a life-long New York Jets fan and resides in Mercer County, New Jersey.
8. Defendant New England Patriots has its headquarters at One Patriot Place, Foxborough, Massachusetts 02035.
9. Defendant Bill Belichick resides at 116 Meadowbrook Road, Weston, Massachusetts 02493.
FACTUAL ALLEGATIONS RELATED TO ALL COUNTS
10. On September 9, 2007 the New York Jets and the New England Patriots played a professional football game in Giants Stadium, located in the Meadowlands in East Rutherford, New Jersey. Plaintiffs held tickets and parking passes to that game.
11. As first reported on the news website ESPN.com, the NFL began looking into claims a New England Patriots employee was videotaping signals by Jets coaches on New York's sideline during the season opener game played on September 9, 2007.
12. ESPN.com reported that NFL security confiscated a video camera and tape from a Patriots employee during New England's 38-14 victory over the Jets that day. The employee was accused of aiming his camera at the Jets' defensive coaches, who were sending signals out to the players, sources told ESPN.
13. The New England Patriots denied that they had violated League rules. New England cornerback Ellis Hobbs said publicly he was unwilling to believe his team had cheated. "We put too many hours in as individuals and a team to have to go out and cheat," he said. "If it's true, obviously, we're in the wrong. But I'm standing behind my team, my coaches. I don't think we do that stuff."
14. This was not the first time Defendants had been accused of cheating. In November 2006, the Green Bay Packers professional football team found a man wearing a Patriots staff credential and carrying a video camera on the sidelines at Lambeau Field, their home field. Teams are allowed to have a limited number of their own videographers on the sideline during the game, but they must have a credential that authorizes them to shoot video, and wear a yellow vest. But Packers spokesman Jeff Blumb said the person in question didn't have the right credential and wasn't wearing a yellow vest, so Packers security asked him to put away the camera and he was escorted out of the stadium.
15. After the videotape of the New York Jets game was confiscated on September 9, 2007, Patriots coach Bill Belichick apologized, saying: "Although it remains a league matter, I want to apologize to everyone who has been affected, most of all ownership, staff and players.” He refused to take questions from reporters about the NFL investigation, however, and stormed out of a weekly press conference with reporters on September 12, 2007.
16. On September 13, 2007, the NFL found the Defendants guilty of violating all applicable NFL rules by engaging in a surreptitious videotaping program. The New England coach, Bill Belichick, was fined $500,000 and the Patriots were ordered to pay $250,000 for stealing an opponent's defensive signals. NFL Commissioner Roger Goodell also ordered the Patriots to give up next year's first-round draft choice if it reaches the playoffs and second- and third-round picks if it doesn't. "This episode represents a calculated and deliberate attempt to avoid longstanding rules designed to encourage fair play and promote honest competition on the playing field," Goodell said in a letter to the Patriots. The Commissioner specifically imposed penalties on the Defendant Patriot organization because "Coach Belichick not only serves as the head coach but also has substantial control over all aspects of New England's football operations. His actions and decisions are properly attributed to the club." Patriot’s owner Robert Kraft refused to comment. The New York Jets issued a statement saying: "We support the commissioner and his findings."
17. The specific NFL rule violated by Defendants states: "no video recording devices of any kind are permitted to be in use in the coaches' booth, on the field, or in the locker room during the game." The rules also specifically state that all video for coaching purposes must be shot from locations "enclosed on all sides with a roof overhead." That was re-emphasized in a memo sent Sept. 6 to NFL head coaches and general managers. In it, Ray Anderson, the league's executive vice president of football operations wrote: "Videotaping of any type, including but not limited to taping of an opponent's offensive or defensive signals, is prohibited on the sidelines, in the coaches' booth, in the locker room, or at any other locations accessible to club staff members during the game."
18. Belichick appeared to accept full responsibility, stating on September 13, 2007: “Once again, I apologize to the Kraft family and every person directly or indirectly associated with the New England Patriots for the embarrassment, distraction and penalty my mistake caused. I also apologize to Patriots fans and would like to thank them for their support during the past few days and throughout my career.” But then, bizarrely, he attempted to deny responsibility, stating: “ We have never used sideline video to obtain a competitive advantage while the game was in progress…With tonight's resolution, I will not be offering any further comments on this matter. We are moving on with our preparations for Sunday's game."
19. The New York Jets ticket-holders who have purchased tickets to watch the Jets play the New England Patriots are not willing to move on. On information and belief, Defendants deployed their unlawful videotape program during every game played against the Jets in Giants stadium from 2000 through 2007, a total of eight games. The Defendants have turned over to the NFL many videotapes for further examination. Meanwhile, Jets fans have collectively spent well over $61 million on tickets to watch eight supposedly honest, competitive games between the New York Jets and New England Patriots between 2000 and 20007. This action seeks restitution for the money spent on games that were systematically and illegally tainted by the actions of defendants.
CLASS ACTION ALLEGATIONS
20. Pursuant to Federal Rules of Civil Procedure, Rule 23 (a) and (b), Plaintiff Carl J. Mayer brings this action on behalf of himself and a Nationwide Class of similarly situated persons defined as:
All New York Jets season ticket-holders and other ticket-holders who purchased tickets to games between the New York Jets and the New England Patriots in Giants stadium since Bill Belichick became the head coach of the New England Patriots in 2000.
21. The Nationwide Class seeks certification of claims for declaratory relief, injunctive relief and damages pursuant to 18 U.S.C. § 1961 et. seq., 12 U.S.C. § 3417 and 12 U.S.C. § 3418.
22. Plaintiffs also bring the claims on behalf of the following New Jersey Subclass defined as:
All individuals that are residents of the State of New Jersey and that purchased tickets to watch the New York Jets play the New England Patriots between 2000 and 2007 in Giants stadium.
23. The New Jersey Subclass seeks certification of claims for declaratory and injunctive relief, and for restitution.
24. Excluded from the Nationwide Class and New Jersey Subclass are the officers, directors, and employees of Defendants, and the legal representatives, heirs, successors, and assigns of Defendants.
25. This action is brought as a class action and may properly be so maintained pursuant to the provisions of the Federal Rules of Civil Procedure, Rule 23. Plaintiffs reserve the right to modify the Nationwide Class and the New Jersey Subclass definitions and the class period based on the results of discovery.
26. Numerosity of the Nationwide Class and New Jersey Subclass: Members of the Nationwide Class and New Jersey Subclass are so numerous that their individual joinder is impracticable. The precise numbers and addresses of members of the Nationwide Class and New Jersey Subclass are unknown to the Plaintiffs. Plaintiffs estimate that the Nationwide Class consists of tens of thousands of members and the New Jersey Subclass consists of thousands of members. The precise number of persons in both the Nationwide Class and New Jersey Subclass and their identities and addresses may be ascertained from Defendant’s records or the records of interested parties.
27. There is a well-defined community of interest in the questions of law and fact involved affecting the members of the Nationwide Class and New Jersey Subclass. These common legal and factual questions include: (a) Whether Defendants have engaged in racketeering by using the enterprise of the NFL to further an illegal scheme in violation of Racketeer Influenced and Corrupt Organizations Act (“RICO”) 18 U.S.C. 1961 et.seq. (b) Whether Defendants committed consumer fraud and engaged in unlawful business practices in violation of the New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. seq. and whether, as regards the New Jersey Subclass members’, the Defendants engaged in unfair, unlawful and/or fraudulent business practices in violation of the New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. seq.; (c) Whether Plaintiffs and New Jersey Subclass members are entitled to restitution, disgorgement of profits, or other equitable relief to remedy Defendant’s unfair, unlawful and/or fraudulent business practices; (d) Whether Plaintiffs and class members are entitled to recover compensatory, statutory and punitive damages, whether as a result of Defendant’s fraudulent, illegal and deceitful conduct, and/or otherwise; and (e) Whether Plaintiffs and class members are entitled to an award of reasonable attorneys’ fees, pre-judgment interest, and costs of this suit.
28. Typicality: Plaintiffs’ claims are typical of the claims of the members of the Nationwide Class and New Jersey Subclass because Plaintiff is a season ticket-holder and lifelong fan of the New York Jets. Plaintiffs and all members of the Nationwide Class and New Jersey Subclass have similarly suffered harm arising from Defendant’s violations of law, as alleged herein.
29. Adequacy: Plaintiffs are adequate representatives of the Nationwide Class and New Jersey Subclass because their interests do not conflict with the interests of the members of the classes they seek to represent. Plaintiffs have retained counsel competent and experienced in complex class action litigation and intend to prosecute this action vigorously. Plaintiffs and their counsel will fairly and adequately protect the interests of the members of the Nationwide Class and New Jersey Subclass.
30. This suit may also be maintained as a class action pursuant to Federal Rules of Civil Procedure, Rule 23(b)(2) because Plaintiffs and both the Nationwide Class and New Jersey Subclass seek declaratory and injunctive relief, and all of the above factors of numerosity, common questions of fact and law, typicality and adequacy are present. Moreover, Defendant has acted on grounds generally applicable to Plaintiffs and both the Nationwide Class and New Jersey Subclass as a whole, thereby making declaratory and/or injunctive relief proper.
31. Predominance and Superiority: This suit may also be maintained as a class action under Federal Rules of Civil Procedure, Rule 23(b) (3) because questions of law and fact common to the Nationwide Class and New Jersey Subclass predominate over the questions affecting only individual members of the classes and a class action is superior to other available means for the fair and efficient adjudication of this dispute. The damages suffered by each individual class member may be relatively small, especially given the burden and expense of individual prosecution of the complex and extensive litigation necessitated by Defendant’s conduct. Furthermore, it would be virtually impossible for the class members, on an individual basis, to obtain effective redress for the wrongs done to them. Moreover, even if class members themselves could afford such individual litigation, the court system could not. Individual litigation presents a potential for inconsistent or contradictory judgments. Individualized litigation increases the delay and expense to all parties and the court system presented by the complex legal issue of the case. By contrast, the class action device presents far fewer management difficulties, and provides the benefits of a single adjudication, economy of scale and comprehensive supervision by a single court.
COUNT I
Tortuous Interference With Contractual Relations.
32. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
33. Plaintiff and members of the class had a contract with the New York Jets under which the ticket-holders purchased the right to attend and observe the matches between the New York Jets and the New England Patriots.
34. Plaintiff and members of the class purchased tickets and entered into the contract with the New York Jets with the understanding, both express and implied, that the game will be played honestly and according to established rules and conditions that are known in advance by all parties.
35.The understanding that the New York Jets football games are to be played honestly and according to the agreed rules and conditions is a material condition of the ticket-holders’ contract.
36.Defendants’ intentionally and knowingly interfered with the ticket-holders’ contractual right and expectation to an honest match played according to the agreed rules and conditions by illegally recording and capturing the New York Jets’ coaching and player signals; Defendants did so for their own private benefit seeking to gain an illegal advantage over the New York Jets.
37. Accordingly, Defendants tortuously interfered with the contract and relationship between the members of the nationwide class and the New York Jets and are liable to plaintiff and other members of the class for restitution of the ticket prices for each of said games along with interest, attorney’s fees and cost of suit.
COUNT II
Common Law Fraud.
38. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
39. Defendants contracted repeatedly with the New York Jets and/or the NFL to play home football games at the New York Jets’ stadium at which it was known and understood that New York Jets ticket-holders would pay for the right to observe and attend the game.
40. New York Jets ticket-holders purchased tickets to said games under the express and implied condition that the game is to be played honestly and according to agreed rules and conditions.
41. Defendants individually and in concert violated this expectation and understanding by illegally recording and capturing New York Jets coaching and player signals, a direct violation of the agreed rules and conditions.
42. The ticket-holders including plaintiff and other members of the class, are direct beneficiaries, i.e., third party beneficiaries, of the contract between the Defendants and the New York Jets and/or the NFL.
43. Defendants entered into the game contracts with the New York Jets and/or the NFL with the intent to violate the agreed rules and conditions or entered into the individual games with such knowing intent.
44. Defendants concealed and omitted to make any disclosure of their intent to illegally record and capture the New York Jets coaching and player signals, an act that violated the agreed rules and conditions of the game contract.
45. It is a material condition to the purchase of tickets by Plaintiff and other members of the class that the participants in the game will pay honestly and according to the agreed rules and conditions.
46. Defendants concealed their intent to violate this material understanding.
47. Defendants committed the violation of the rule by stealth and surreptitious conduct by recording and capturing New York Jets signals by the use of a non-uniformed agent on the field.
48. Plaintiff and other members of the class relied to their detriment in purchasing tickets to the New York Jets-Patriots games.
49. Plaintiff and other members of the class were injured by their payment of money for the New York Jets – Patriots games.
50. It is a material and agreed fact, understanding and condition that the NFL games are to be played honestly and to be a match of contestants following the same essential rules and conditions. Plaintiff and, upon information and belief, other members of the class, would not have purchased tickets to the games if the Patriots and Belichick had disclosed that they intended to play the game corruptly and in violation of an essential and material game rule.
51. Accordingly, Defendants are liable in fraud to plaintiff and other members of the class for monies paid by the ticket-holders for the New York Jets’ home games with the Patriots, as set forth above, along with interest, attorney’s fees and costs of suit.
52. Defendants intentionally and knowingly acted to violate the game rule and knew or should have known that such rule is material to the honest performance of the game contract.
53. Defendants conspired to violate the game rule and did so by stealth and deception and have been previously caught committing similar acts.
54. Such violation corrupted the sport of football. Accordingly, Plaintiff and the class respectfully seek punitive damages be assessed against Defendants, along with interest, attorneys fees and costs of suit.
COUNT III
Deceptive Business Practices, N.J.S.A. 2C:21-7
55. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
56. By the aforesaid acts, Defendants violated N.J.S.A., 2C:21-7.
57. Accordingly, defendants are liable for the value of tickets purchased by Plaintiff and other members of the class for the New York Jets – Patriots games, along with treble damages, interest, attorney’s fees and cost of suit.
COUNT IV
New Jersey Racketeering, N.J.S.A., 2C:41-2
58. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
59. By their above described acts, Defendants, in violation of N.J.S.A. 2C:41-2, Defendants, individually and jointly, through a pattern of racketeering activity, (A) derived income, directly or indirectly, through certain enterprises owned and/or controlled by them that are engaged in the playing and performance of professional football games; (B) acquired and/or maintained, directly or indirectly, an interest in or control of the Enterprises, which affected trade or commerce; and (C) conducted and/or participated, directly or indirectly, in the conduct of the Enterprises’ affairs.
60. Upon information and belief, the Enterprises are (a) the New England Patriots football organization, (b) the National Football League; c) the New York Jets football organization.
61. The Enterprises engaged employees to perform and play the professional football games and to carry out the scheme to defraud and deceive.
62.Defendants engaged in a practice and pattern of racketeering by engaging in at least two incidents of racketeering conduct, one of which occurred after the effective date of N.J.S.A. 2C:41-1 et seq. and the last of which occurred within 10 years after a prior incident of such activity.
63.Defendants, by the above described acts, fraudulently induced consumers of New Jets tickets to purchase said tickets by concealing their intent to violate the agreed rules and conditions of the game contracts with the New Jersey Jets and/or the NFL and concealed and omitted to disclose to the ticket-holders their intent to subvert and corrupt the New York Jets home games by illegally recording and capturing the New York Jets coaching and player signals in violation of N.J.S.A. 2C:21-7 (deceptive business practices), causing damage to Plaintiff and class members.
64. Accordingly, Defendants are liable under the New Jersey racketeering statutes to the Plaintiff and other class members for restitution of the ticket prices paid for said games, along with treble damages, interest, attorneys fees and costs of suit.
COUNT V
The Racketeer Influenced and Corrupt Organizations Act,
18 U.S.C., 1961(a), (b), (c), (d)
65. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
66. Defendants, by their above described acts, engaged in a pattern of racketeering activity through the performance of at least two acts of racketeering within a ten year period through the use of the mails and/or the interstate wires as a material element of their scheme to defraud New York Jets ticket-holders.
67. Defendants received income derived, directly or indirectly, from a pattern of racketeering activity to use or invest or used, directly or indirectly, any part of such income, or the proceeds of such income, in acquisition of any interest in, or the establishment or operation of, any enterprise which is engaged in, or the activities of which affect, interstate or foreign commerce in violation of 18 U.S.C. 1962(a).
68.Defendants through a pattern of racketeering activity acquired or maintained, directly or indirectly, an interest in or control of an enterprise which is engaged in, or the activities of which affect, interstate or foreign commerce in violation of 18 U.S.C. 1962(b).
69.Defendants employed themselves or others in, or were ,associated with an enterprise engaged in, or the activities of which affect, interstate or foreign commerce, to conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs through a pattern of racketeering activity in violation of 18 U.S.C. 1962(c).
70. Defendants conspired to violate subsections (a), (b), or (c) of 18 U.S.C. 1962, as described in 18 U.S.C. 1962(d).
71. The above-described enterprises consisted of a) the New England Patriots football organization, b) the National Football League and c) the New York Jets football organization.
72. Defendants, by the above described acts, committed predicate acts through the use of the mails or interstate wires in furthering their fraudulent inducement of consumers of New Jets tickets to purchase said tickets by concealing their intent to violate the agreed rules and conditions of the Defendants’ game contracts with the New Jersey Jets and/or the NFL and concealed and omitted to disclose to the ticket-holders their intent to subvert and corrupt the New York Jets home games by illegally recording and capturing the New York Jets coaching and player signals, causing damage to Plaintiff and class members.
73. Accordingly, Defendants are liable under to Plaintiff and other class members for restitution of the ticket prices paid for said games, along with treble damages, interest, attorney’s fees and costs of suit.
COUNT VI
Violation of Ticket-holders rights as Third Party Beneficiaries.
74. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
75. Plaintiff and other class members is an intended third party beneficiary of the contracts between the New York Patriots and the New York Jets and/or the NFL.
76. The understanding that the New York Jets football games are to be played honestly and according to the agreed rules and conditions is a material condition of the Patriots’ contract with the New York Jets and/or the NFL and the ticket-holders are the intended third party beneficiaries of said contracts.
77. Defendants violated and interfered with the third party benefit to the ticket-holders by illegally recording and capturing the New York Jets’ coaching and player signals.
78. Accordingly, are liable to plaintiff and other members of the class as third party beneficiaries of the Patriots’ contract with the New York Jets and/or the NFL for restitution of the ticket prices for each of said games along with interest, attorney’s fees and cost of suit.
COUNT VII
CONTRACT
79. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
80. Plaintiffs plead in the alternative that they have an implied or quasi contract with the New England Patriots who violated such contract by illegally recording and capturing the New York Jets’ coaching and player signals.
81. Accordingly, Defendants are liable to Plaintiff and other members of the class as third party beneficiaries of the Patriots’ contract with the New York Jets and/or the NFL for restitution of the ticket prices for each of said games along with interest, attorney’s fees and cost of suit.
COUNT VIII
New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. Seq.
82. Plaintiffs repeat and incorporate herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein.
83. Defendants conduct violated The New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. Seq. by committing a fraud, deception, misrepresentation, unconscionable business practice, concealment, suppression and omissions in conducting their business in the State of New Jersey.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiffs for themselves and all others similarly situated respectfully request that the Court:
A. Declare that Defendant’s fraud, tortuous interference with contractual relations and violations of NFL policy as alleged herein violates applicable law including without limitation:
(i) The New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. Seq.
(ii) The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq.
(iii) The common law of tortuous interference with contractual relations.
(iv) The New Jersey Racketeering Law N.J.S.A., 2C:41-2
(v) The common law of fraud and contract.
(vi) Deceptive Business Practices, N.J.S.A. 2C:21-7
B. Award equitable relief, including without limitation, a preliminary and permanent injunction prohibiting Defendants’ continued or future videotaping in violation of NFL rules and New Jersey and federal law:
(i) Pursuant to The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq., as to the Plaintiffs and the Nationwide Class; and
(ii) Pursuant to the New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. seq., and the Deceptive Business Practices, N.J.S.A. 2C:21-7
C. Award statutory damages to the extent permitted by law to each Plaintiff and class member in the sum of:
(i) actual damages sustained by the customers in the amount of $61,6000,000 for the amount paid by New York Jets ticket-holders to watch eight fraudulent games between the New England Patriots and the New York Jets between 2000 and 2007.
(ii) treble damages pursuant to The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq.and the New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1 et. seq. for a total amount of compensatory damages of $184,800,000.00.
D. Award punitive damages to the extent permitted by law to each Plaintiff and class member, including without limitation:
(i) An appropriate sum pursuant to The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq.
(ii) An appropriate sum pursuant to the New Jersey Consumer Fraud Act N.J.S.A. 56:8-1 et. seq.
E. Award to Plaintiffs attorneys’ fees and other costs of suit to the extent permitted by law, including without limitation pursuant to The Racketeer Influenced and Corrupt Organization Act. 18 U.S.C. § 1961 et.seq. and the New Jersey Consumer Fraud Act. N.J.S.A. 56:8-1 et. Seq.
F. Award restitution, disgorgement, and all other relief allowed under the New Jersey Consumer Fraud Act as to the New Jersey Subclass.
G. Grant such other and further relief as the Court deems just and proper.
JURY DEMAND
Plaintiffs hereby request a jury trial for all issues triable by jury including, but not limited to, those issues and claims set forth in any amended complaint or consolidated action.
DATED: September 28, 2007 CARL J. MAYER, ESQ., on behalf of himself and all others similarly situated.
By: /s/ Carl J. Mayer, Esq. .
CARL J. MAYER, ESQ.
MAYER LAW GROUP LLC
66 Witherspoon Street, Suite 414
Princeton, NJ 08542
Telephone: 609/921-8025
Facsimile: 609/921-6964
_____________________
BRUCE I. AFRAN, ESQ.
10 Braeburn Drive
Princeton, NJ 08540
Telephone : 609-924-2075
posted by The Untouchables | 4:31 AM
83 Comments:
This is probably the saddest and most pathetic, frivolous thing i've ever seen in my life
Hey how about letting Eagle fans who attended the superbowl into your suit!
This is whats wrong with this country. Too many damn lawyers with nothing to do but waste the taxpayers money.
AMBULANCE CHASING LOSER
Maybe you should sue the company that made the camera too, because without it the pats could never have filmed the jets. Maybe you should sue yourself for booing your QB, Maybe you should sue Mangina for being such a turncoat.
Dear whack job,
Is business so bad that you need to resort to this to get your name in the paper ? LOL
Moron
Way to represent the profession as terribly as you possibly could with this publicity stunt. Your entire claim is predicated on facts that you don't even ALLEGE, namely the existence of a supposedly express contact that these games would be played accordingly to the rules. You don't allege that, because it's not true, and it's ludicrous: the implication is that a ticketholder is owed damages as soon as there's a penalty in a football game. And furthermore, you aren't even suing the alleged promisor: if your claim had any legs, you should be suing the JETS, not the Patriots.
Even the joke lawsuit against God a couple of weeks back had some actual thought behind it. This is such a terribly written complaint that it doesn't even serve any purpose as a thought exercise. It's an exercise in malpractice at best and a terrible publicity stunt and massive cry for intellectual help by an obviously failed activist at worst. Do yourself a favor and withdraw this thing before you get disbarred for incompetence.
"I sue because I can."
Way to tie up MY legal system!
It's not YOUR legal system. It is OUR legal system.
Why don't you use your time to do something productive.
To the other laywers: How can we get a class action suit against Carl J. Mayer? Isn't there some violation of the laywer code of ethics? This is not the first time this "man" has done this type of thing.
you are a pathetic excuse for a professional. there are far more pressing issues in our country and the world than this. for pete's sake why don't you concentrate on your own state...cleaning up the "armpit" of the united states. its pricks like you that don't deserve to hold season tickets. you only have them because you can. you only filed frivolous lawsuits because you can. how much paper did you waste preparing and filing this lawsuit?
Hey dickhead,
Face it, the jets suck, their fans suck, you suck. get over it. Low Rent lawyers, shoot them all. HAVE A NICE DAY.
RDMartin
Technically, you should be suing for compensation for seven games. The tape was confiscated early in the first quarter and the NFL said it had no effect on the outcome of the ass kicking the Pats put on the Jets.
That said, in my opinion, not only do you give the law profession a bad name, you are a complete asshole who should crawl back into the Jersey sewer you came from. Of course, this is only my opinion.
Next up...
The NBA for employing a corrupt referee. MLB for failing to suspend Bonds. NHL for allowing players to fight.
Then, on to...
The vendor who sold you a hot dog at the game for price gouging. The fan who sat next to you and passed gas.
And finally...
The law school that granted you a degree -- for failing to properly access your competence.
The state of NJ for allowing you to clog up the courts with frivolous lawsuits.
This is a load of crap. The Jets are 49-50 in the regular season since 2000. The Patriots have outscored their opponents this year 114 - 35. If you think that first game was all cheating then you can't argue with the beating they put on the Chargers in week 2...not with the league watching their every move.
If listen to those in the know around the league at least 20 other teams were doing something (like the Patriots)to gain an advantage. Teams will always try to steal signals, hell might as well sue them all.
And Eagles fans, be quiet about the Superbowl loss. The last time the Patriots and Eagles played before that superbowl was in Week 2 of the 2003 season.
why not include all who attended Patriot home games and road games in addition to those at Giant's Stadium? Were they not deceived in the same way you claim the Jets fans were? Are you suing for damages associated with all games or only those the Jets lost? Wait...since 2000 they lost 7 of 8 at home against the Pats...what the hell, sue for all 8!
Rodney Harrison admitted to prescribed steroid use, better throw that in as well...could have influenced a game at some point.
I think that people go way to far when it comes to stupid lawsuits. If anyone should sue the patriots it should be the jets but be realistic do you honestly think that the Patriots were the only team stealing signals? NO they arn't. I am so sick of sue happy people who are looking for outragous amounts of money for stupid reasons. If someone is going to sue the patriots for stealing signals I might as well sue the jets for wearing green because they are stealing the eagles color!
How pathetic to be a Jets fan...a rat for a coach and whiners for fans.
Poor poor Jet fans, cannot compete on playing field - so take to the court room - what a JOKE.
J-O-K-E, joke, joke joke
You should sue the Jets for impersonating a football team, and intentional infliction of emotional distress for all the pathetic losers who attend their home games.
I have noticed that a few other people have left comments indicting the actions of you, Carl Mayer, all while referencing the corruption of other sports, like basketball's referee situation and Baseball's steroid situation.
They write that this lawsuit wastes people's time and they talk as if we should all expect the Patriots to cheat. Should we just expect every athlete and major corporation to cheat? Can we afford to be that apathetic? I feel cheated by my credit card company, my bank, my phone company, my government, etc. I personally feel cheated on a constant basis and I feel that there is little that I can do about it. Should I let those that are cheating me, to go ahead and steal what is mine?
Most recently though, I have felt cheated by professional sports. Boxing and basketball seem steeped in a tradition of doctored outcomes and Hockey and baseball have broken the hearts of so many fans by squabbling over money. The last publicized threat of a MLB strike came the year after the September 11th attacks, a time when a bruised American public badly needed a distraction from how complex life could be. And that is just the point. Sports are so important in this country because they allow for us to dream. They allow for us to identify with an athlete or a team who exists in a simple world of rules and points and right and wrong. As opposed to the world we really live in, it is a world where even if your team does not win, they can battle righteously and lose with dignity. American sport is a place where it is acceptable for a grown man to have heroes.
In February of 2002 the New England Patriots were my heroes. At the beginning of the Super Bowl they requested to be called out onto the field as a team. That was how they had gotten there and that is how they would go on to win, depending on each other to overcome an insurmountable opponent (The St. Lois Rams). But alas, the Patriots have become an Evil Empire, no longer concerned with fair play, but only concerned with domination. They have made a mockery of what they purport to represent with their colors and their mascot, which is Patriotism. I don't take that lightly. I am not so cynical that I consider all politicians to be corrupt, all companies to be thieves, and all sporting competitions rigged. I still want to believe there is something fair and true in the world.
Should teams be allowed to videotape each other during games, so that coaching can keep up with an ever changing technological paradigm? Maybe, but until then, teams who are caught breaking a predetermined rule need to be punished, and not just by Roger Goodell, but by fans. It sends a stronger message when the people whom they are supposedly attempting to entertain are disappointed and dissatisfied. It is not wrong to demand that teams adhere to a predetermined set of rules. If they do not, they will no longer be playing sports.
I consider what Carl Mayer is doing to be an effort to demand the integrity of a sport. This is not about the Jets or the Patriots (I live in Chicago and I am a Bears fan) or about videotaping in football. It is not even about football. It is about fans letting owners, coaches and players of every sport know that their product is predicated on fair play. It is a warning to other teams, to other sports even, that fans don’t want football turn into the tangled mess baseball and hockey and basketball and boxing have become. Carl Mayer is doing everything he can to preserve the concept of heroism in this country. In a world where heroes are more and more scarce, Carl Mayer (and I never thought I would say this about a lawyer) has become my hero.
Sincerely,
Matthew Meade
Jimmy Hoffa would roll over in his grave at the Meadowlands if he found out about this lawsuit. He is buried at the Meadowlands, isn't he? It gives the RICO act a bad name.
I think this is a colorable complaint - the law student above was way out of line when he opined that there is no implied warranty of fairness in the contract/license to view the game.
The NJ Consumer Fraud Act and the RICO statute, as I read them, definitely admit of broad enough interpretations that this claim should survive a 12(b)(6) motion.
I wonder though, shouldn't the Jets and the NFL be added - won't they need to be joined at some point regardless for most of the counts (excluding the tortious interference)?
I can not believe what I'm seeing from you. What a complete waist of your time and tax payers money all for you to get a bit of spotlight shinning on you. What you don't know about heat is that for you the spotlight will fade and you will be remembered as the idiot who sued the PATS. Do you really think this is going to go anywhere? As a football fan, you should know that teams always try to get a leg up on the other, sometimes the rules get bent, but taking a coach to court for 186 million is silly. I know you think you are a smart guy... But sometimes smart people do really stupid things and this tops it all... You make lawyers look as many of them are, like money grubbing looser... GO PATS GO!!!! ALL THE WAY TO THE SUPER BOWL!!!!! The best part is you think the Jets even have a chance... Maybe Coach Man-g(v)agina should try cheating cause that's the only way the Jets will make the playoffs... YOU LOOSER!!!!
Well,
This is firstly that biggest waste of time ever. I hope you and your law firm are quite proud of yourself for using this event to bring light to yourself rather than for general concern for the wrongdoings being done to the public.
Congratulations, you'll go down in the history books, but I assure you it won't be for making the most intelligent decisions.
I didn't know it was so hard pressed for lawyer's to get work now-a-days..
Joseph: "the law student above was way out of line when he opined that there is no implied warranty of fairness in the contract/license to view the game."
I'm guessing you don't watch a lot of football. There are infractions on the rules of the NFL in EVERY SINGLE PROFESSIONAL FOOTBALL GAME. They're called "penalties." Some result in loss of yardage/downs, and some result in monetary fines or suspensions after the fact. If there WAS some implied warranty here, then everyone who bought an NFL ticket would have an action as soon as a defensive player jumped offsides or an offensive lineman false-started.
At most, there is an implication that if the rules are broken in an NFL game, then the proper sanctions prescribed by the NFL's rulebook will be applied. And in this instance, they already have.
So either A.) there was no "implied warranty" as described above, or B.) that warranty was in fact fulfilled when Roger Goodell exercised the sole discretion he has under the current rulebook in penalizing the Patriots and Bill Bellichek.
If there was an express or implied warranty in the form that Mayer alleges here, then he'd be able to allege the specific of that warranty in his complaint. He doesn't, because THERE ISN'T ONE. As such, the best Mayer can hope for is to walk out of the courtroom with his law license intact, because he WON'T walk out with this lawsuit intact. There's nothing "heroic" about making a mockery of the legal system and the profession of law in this way. It's self-serving attention-prostitution.
Seriously? Get a freakin life. Why waste time or money on this case when either way, the Jets would have lost those games. The Patriots have better players, coaches, and schemes. This is one of the most frivolous lawsuits I've ever heard of.
I hope the Patriots file a Rule 11 motion for sanctions forcing you to pay their legal costs.
I dont suppose you were one of the people cheering for Pennington getting injured were you?
Shakespeare had a good quote on lawyers. A man ahead of his time.
penalties and what the Patsies did are two different things. cheating as the patriots did is SO out of the ordinary for an NFL football game, that it can constitute fraud.
its like finding out that all the games are rigged -- cheating like the Pats did is fraud; roughing the passer is within the context of the game and is expected by fans, and thus not actionable.
I am glad you are suing because the league let the pats off easy and DESTROYED the freaking evidence after.
good job!
C'mon people. The point of this lawsuit is the discovery process, not the remedy.
Everybody trashes lawyers until they need one. You may not like this suit, but it's the only chance we have of ever knowing what happened.
Wow! Ambulance chasing at it's best! Well played lawyers, well played. So why not got after the MLB because of players using steroids? How about NBA at it's crooked ref? NCAA and all the player violations? You know what though? I like you guys so here is a tip. Go for the WWE! Yup, rumor has it might ALL be staged! Cha-ching!
One more thing, how come Mangini gets off so easy and is even looked upon as a hero? He was with the Pats when this was going on and he didn't say anything at the time. What, now that it's done against him it's wrong all of a sudden? This type of relative morality is retarded.
You must feel so inadequate, douche bag.
C'mon people. The point of this lawsuit is the discovery process, not the remedy.
And what, pray tell, is the point of the discovery process when you already know that all of the relevant evidence was DESTROYED? That negates what you claim is the "point" here. Even if there was a legitimate public interest in abusing the legal process to "find out what happened" in a professional sport, we already know that that CANNOT happen in this case.
There is no "point" to this lawsuit other than pseudo-legal attention-whoring, and that is a disgrace to the legal system and the legal profession.
If you're wanting to sue the Pats organization under some BS stipulation, you might as well add the JETS too. You can sue them for fraud as well. They are trying to pass themselves off as a professional NFL team. Posers! As bad as they are, you wasted money earned, no doubt chasing ambulances. J.E.T.S. suck! suck! suck!
Get a f'n life. Im surprised you haven't been shot dead yet for all your stupidity in NJ aka the black hole in the Northeast
Mr. Mayer,
Good luck circling the wagons on this one. It seems that no one has considered video taping at NFL games, as a whole. Taping is allowed from booths on the 50 yard line and in the end zone, but not on the sidelines - seems like a very slippery slope to me.
you truly believe this is justified?
Mr. Mayer,
Perhaps you would also like to sue Major League Baseball, Barry Bonds, Jose Canseco, Pete Rose, Shoeless Joe Jackson and every other athlete or program who has ever cheated. And as you are crusading so vehemently for the cause of yourself, and all Jets fans for that matter, perhaps you should add Coach Mangini to your lawsuit - or do you think that while he was a coach with New England he was 'unaware' of the activities of the all too sinister Mr. Belichick?
Perhaps, as a loyal Jets fan, you ought to crusade for his removal as head coach of the Jets? If not for cheating, then perhaps for his record of 1-3?
T.S.
Gonna have to add the Buffalo Bills to the defendant list. They obviously had some sort of advantage today when they won against the JETS. Face it. Your JETS suck!!!
Jets season tix holders should sue Mangini and the Jets ownership for failing to field a team worthy of the price they are paying.
ITS FUNNY HOW THE PATS MADE ALL THE RIGHT ADJUSTMENTS VS. THE EAGLES IN THE SUPERBOWL IN 2004. THE PHILADELPHIA FANS NEED TO BE ADDED AS WELL.
And the perfect adjustment was to have Donovan McNabb throw a pick during that last chance drive. Sue him. He was obviously on the PATS' payroll. I'm surprised Philly fans didn't start throwing batteries at that point. They didn't live up to their reputation as well. Sue them too. See how ridiculous this can get? This lawyer needs to get legitimate. what a farce!
And the perfect adjustment was to have Donovan McNabb throw a pick during that last chance drive. Sue him. He was obviously on the PATS' payroll. I'm surprised Philly fans didn't start throwing batteries at that point. They didn't live up to their reputation as well. Sue them too. See how ridiculous this can get? This lawyer needs to get legitimate. what a farce!
I think you mean "tortious interference." But don't worry, I'm sure the Patriots' lawyers will point that out to the judge in their motion to kick you out of court on your ass! I just hope they include a motion for Rule 11 sanctions for filing such a poorly put together nuisance lawsuit. I mean really, if you're going to waste the court's time harassing people, can't you at least spell things correctly?!
How about Pro Wrestling? Do they caution their patrons that the show is staged prior to selling their tickets? If by some insane twist of fate you were to prevail, guess the WWF would have to close up shop...
Seriously, get over it the NFL has already handled the situation. Every football team does it the Patriots just got caught because some people don't want them to do well. Just because they stole signals doesn't mean that won them the game. It really comes down to how well you can play football and the Patriots are playing are really playing good football. So do something better with your time then trying to bring down the Patriots because it isn't going to happen. So get over you pathetic selves and you guys sounded so stupid on Jamn 945 this morning.
GET SERIOUS GUYS, THERE IS NO POSSIBLE WAY THE JETS WOULD HAV BEAT THE PATS N E WAYS, KEEP DREAMIN N STOP HATIN ON JAMN...
Is this suit going to get any coverage on HBO's Realsports program?
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Well I guess the People have spoken and the self-proclaimed "Lawyer for the People" is pretty much despised by the People and a genuine laughing stock. Perhaps you should have gone to Harvard or Princeton Mr. Mayer and learned something other than how to look foolish. Guess the adage, if you can't be famous, you might as well be infamous fits you to a T.
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