Gregory W. Alarcon in Department 36 Stanley Mosk Courthouse, Complaint; Filed by: AMANDA BOWERS (Plaintiff); SUSAN TIDWELL (Plaintiff); As to: PROLINK STAFFING SERVICES, LLC (Defendant); DOES 1-20, inclusive (Defendant), Civil Case Cover Sheet; Filed by: AMANDA BOWERS (Plaintiff); SUSAN TIDWELL (Plaintiff); As to: PROLINK STAFFING SERVICES, LLC (Defendant); DOES 1-20, inclusive (Defendant), Summons on Complaint; Issued and Filed by: AMANDA BOWERS (Plaintiff); SUSAN TIDWELL (Plaintiff); As to: PROLINK STAFFING SERVICES, LLC (Defendant); DOES 1-20, inclusive (Defendant), Notice of Case Assignment - Unlimited Civil Case; Filed by: Clerk. According to anonymously submitted Glassdoor reviews, ProLink Staffing employees rate their compensation and benefits as 3.9 out of 5. This rating has improved by 9% over the last 12 months. While Norwood-based ProLink Staffing might not be a Fast 55 winner this year, its percentage growth of 1,435% for the years 2019 through 2021 landed the company . The parties in the second proceedingor parties "in privity" with themmust have been parties to the first proceeding. We've made it our mission to #giveback to the communities we live and work in. 3.7 reservation no. 777 Employees . (Attachments: #1 Memorandum, #2 Declaration Matthew B. Hayes, #3 Declaration Deborah Clay, #4 Declaration Kevin Lee, #5 Proposed Order) (Pawlenko, Kye) (Entered: 10/09/2020), (#30) ORDER by Judge Jesus G. Bernal, Granting Stipulation RE Schedule for Class Notice and Final Approval Hearing #29 . No. (Hayes, Matthew) (Entered: 09/05/2019), (#2) Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening) #1 filed by Plaintiff Deborah Clay. R. Civ. 1:21-CV-01681 | 2021-11-22, U.S. District Courts | Labor | Accordingly, the Court vacates the hearing set on June 15, 2020. SHRM offers thousands of tools, templates and other exclusive member benefits, including compliance updates, sample policies, HR expert advice, education discounts, a growing online member community and much more. This rating has improved by 9% over the last 12 months. Whether you have your Registered Nursing (RN) license or youre working toward your ADN or BSN, well find a great fit. Learn how SHRM Certification can accelerate your career growth by earning a SHRM-CP or SHRM-SCP. This rating has improved by 11% over the last 12 months. Finally, one place to get all the court documents we need. Bernal.) Our team treats everyone they serve as extensions of their own families this includes our internal staff, talent, and clients. Berger Montague has a current lawsuit pending against AMN and Kaiser in the U.S. District Court for the Northern District of California. Its easy. (esa) (Entered: 09/06/2019), (#6) NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. You always get praised for accomplishments and if you're struggling, so many different people are there to lift you up and help in any way they can. We very much value work life balance in compliance however we also understand that our staffing needs fluctuate week by week and always make an effort to adapt in a way that is in the best interest of our talent, clients and team members". THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. click on the search button) he or she will have 1 search deducted from their total searches (i.e. Please enable scripts and reload this page. No. click on the next button). Attorney at Constangy Brooks Smith and Prophete LLP, Docket(#38) MINUTES (IN CHAMBERS) by Judge Jesus G. Bernal: Order (1) GRANTING Plaintiffs Motion for Final Approval of Class Action Settlement, (Dkt. I have honestly never worked with such a supportive team, there is none of the back stabbing, etc, that Ive seen in the past in competitive environments. Pick your next adventure, and we will get you there. #data #cloud #ethics #datagovernance School Social Worker. The following error(s) was/were found: Case number is incorrect or missing. (npo) TEXT ONLY ENTRY (Entered: 05/29/2020), (#25) NOTICE OF NON-OPPOSITION to NOTICE OF MOTION AND MOTION for Settlement Approval of Class Action #24 filed by Defendant Prolink Staffing Services, LLC. Motion set for hearing on 11/9/2020 at 09:00 AM before Judge Jesus G. Bernal. Click here to generate a list of documents relating to the docket for this case. (ima) (Entered: 09/11/2019), (#7) 21 DAY Summons issued re Complaint #1 as to defendant Prolink Staffing Services, LLC. Not really a con, just know that you have to work hard to be successful, no slackers allowed. They include Abby Zimmerman, Brent Wallace, Joby Myers and Matt Frankey; all will serve as area . Data Breach Lawsuit. We can work remotely or go to the office, and that is a permanent option, which allows great balance and the ability to have access to what you are working on at any time. (mga) TEXT ONLY ENTRY (Entered: 11/06/2020), (#34) NOTICE OF NON-OPPOSITION to REQUEST for Attorney Fees , Costs, Enhancement Payment, and Settlement Administration Fees #32 filed by Defendant Prolink Staffing Services, LLC. (twdb) (Entered: 11/23/2020), (#37) MINUTES OF Hearing held before Judge Jesus G. Bernal: (Telephonic Hearing) Plaintiffs Motion for Final Approval of Class Action Settlement, (Dkt. Contract. We thrive on forming lasting connections with people. We are so glad that you have found your home and we look forward for you to continue being part of the family. We agree that ProLink is amazing and are glad you experience has been the same! Thank you! Every employee is disposable. ProLink is hereto ensure you have the best peoplein your organization. Were hiring. View job. Since this is a WFH position, more often than not you are praised or encouraged to work over time or on weekends to really push production. Workers sue staffing company, client over wages, overtime We look forward to many more years working together! (Attachments: #1 Memorandum, #2 Proposed Order) (Pawlenko, Kye) (Entered: 10/09/2020), Docket(#31) Final NOTICE OF MOTION AND MOTION for Settlement Approval of Class Action filed by Plaintiff Deborah Clay. After speaking with our Compliance Manager, they wanted me to share the following with you: "We give everyone an equal opportunity to apply and interview for all team lead positions. var temp_style = document.createElement('style'); 04/28/2023 at 1:30 PM in Department 24 at 111 North Hill Street, Los Angeles, CA 90012; Case Management Conference. The Court, HEREBY ORDERS AS FOLLOWS: This case is hereby stayed for 90 days. Easily build your profile with our secure platform. A separate order will issue ruling on the motions. With that said, we also strongly believe in a positive work life balance and are implementing several solutions such as our 24/7 helpdesk so that we can give our producers some much deserved rest time at night, on the weekends and for your PTO. Become a SnapNurse | Flexible Hours + Paid Daily Travel Nursing Unpaid Overtime Class Action Lawsuit - Berger Montague Sports Newsletter. Permanent Placement - Add full-time employees early- to mid-career or executive level. When the economy is unstable, employers are faced with difficult decisions around staffing, pay and benefits. ProLink Healthcare has 32 verified ratings from their clients earning them 4.4 out of 5 stars! 2019-10-04, Santa Clara County Superior Courts | Labor | App., No. If you would like to voice specific concerns other than the ones mentioned above, please reach out to [email protected]. 1,000 total searches in the Enterprise Plan). Attorney Brian C Sinclair; Peter Hering and James L Morris terminated. Please note that all such forms and policies should be reviewed by your legal counsel for compliance with applicable law, and should be modified to suit your organizations culture, industry, and practices. prolink staffing lawsuit (Attachments: #1 Memorandum, #2 Declaration Matthew B. Hayes, #3 Declaration Deborah Clay, #4 Declaration Kevin Lee, #5 Proposed Order) (Pawlenko, Kye) (Entered: 10/09/2020), (#30) ORDER by Judge Jesus G. Bernal, Granting Stipulation RE Schedule for Class Notice and Final Approval Hearing #29 . Our Culture and our People are our greatest strength so this was done to promote that and we are happy that you are enjoying working at ProLink! On . Contract Talent - Hire skilled professionals on a temporary basis for short- or long-term assignments. -They preach work/life balance..unless you're in compliance -Its literally a joke in compliance meetings how undervalued and overworked we are -No incentive for getting talent in the door while recruiters/crms make bonuses, Thank you for taking the time out of your day to leave your honest feedback. : 756937525202: Name Extension: blank; Exact Name: Plaintiffs Objection to Prolink Staffing Services LLC's Request for Permission to Present Oral Testimony at Hearing reservation no. -PTO -I had a very nice lead who was very understanding - The pay is good compared to a lot of jobs right now -Lots of opportunities for OT, -overworked to the point of burn out -Workloads are uneven across the board, I had coworkers who would have 5-10 talent going in a week while I was responsible for 15-18 talent a week. Finally, one place to get all the court documents we need. The only con I can think of is, the base salary isnt very high, and itll take a little bit of time to build your book of business. Gregory W. Alarcon in Department 36 Stanley Mosk Courthouse, DocketComplaint; Filed by: AMANDA BOWERS (Plaintiff); SUSAN TIDWELL (Plaintiff); As to: PROLINK STAFFING SERVICES, LLC (Defendant); DOES 1-20, inclusive (Defendant), DocketCivil Case Cover Sheet; Filed by: AMANDA BOWERS (Plaintiff); SUSAN TIDWELL (Plaintiff); As to: PROLINK STAFFING SERVICES, LLC (Defendant); DOES 1-20, inclusive (Defendant), DocketSummons on Complaint; Issued and Filed by: AMANDA BOWERS (Plaintiff); SUSAN TIDWELL (Plaintiff); As to: PROLINK STAFFING SERVICES, LLC (Defendant); DOES 1-20, inclusive (Defendant), DocketNotice of Case Assignment - Unlimited Civil Case; Filed by: Clerk, Contra Costa County Superior Courts | Other | The hearing on the Motion for Final Settlement Approval of Class and request for Attorney Fees will proceed telephonically on Monday, November 9, 2020 at 9:00 a.m. Counsel/parties shall dial in at least 5 minutes before the hearing to the following number: (877) 336-1831; Access Code: 4899258. 500 total searches in an Business Plan) every 30 days. The plaintiffs filed suit against the client company for unpaid minimum wages, unpaid overtime wages, and meal- and rest-break violations. ProLink emphasizes their culture and values but it is really hypocritical. No. Gain the intel you need now to successfully anticipate and navigate employment laws, stay compliant and mitigate legal risks. (esa) (Entered: 09/06/2019), (#5) NOTICE OF ASSIGNMENT to District Judge Jesus G. Bernal and Magistrate Judge Kenly Kiya Kato. Get the best route to anywhere you want to go, with step by step directions, maps and schedules for any transit line. Patricia D. Nieto; Reason: Challenge / Recusal, by Plaintiff, DocketCase Management Conference scheduled for 10/12/2021 at 08:30 AM in Stanley Mosk Courthouse at Department 36, DocketNotice of Case Management Conference; Filed by: Clerk, DocketCase assigned to Hon. SEE DOCUMENT FOR FURTHER INFORMATION. The most common ethnicity at ProLink Staffing is White (73%). Bernal.) Cancellation and Refund Policy, Privacy Policy, and 2019-09-13, Los Angeles County Superior Courts | Labor | Our recruiters function as career consultants, with the flexibility to place you in any of our thousands of jobs across the country. 2:19-CV-07091 | 2019-08-14. : 756937525202; As To Parties: removed, Updated -- Plaintiffs Objection to Prolink Staffing Services LLC's Request for Permission to Present Oral Testimony at Hearing reservation no. 78% of employees would recommend working at ProLink Staffing to a friend and 77% have a positive outlook for the business. Your task will change daily -your manager will use you and put all the work on you -micromanaging is at alll time high. Amanda Bowers, Et Al. Vs Prolink Staffing Services, Llc, Et Al. 76% of ProLink Staffing employees are women, while 24% are men. (Attorney James L Morris added to party Prolink Staffing Services, LLC(pty:dft))(Morris, James) (Entered: 10/04/2019), (#9) PROOF OF SERVICE Executed by Plaintiff Deborah Clay, upon Defendant Prolink Staffing Services, LLC served on 9/18/2019, answer due 10/9/2019. Enjoy job flexibility and benefitslike housing bonuses and tax-free income. if(currentUrl.indexOf("/about-shrm/pages/shrm-china.aspx") > -1) { Select We make credentialing as easy as uploading documents and updating your profile. And, through the settlement, the plaintiffs were compensated for any errors made in paying their wages. if you have a dinger for Amazon and Walmart in an Individual Plan, you can delete Walmart and now have available 1 dinger to set up). The Judge overseeing this case is KRISTIN S. ESCALANTE. This class action lawsuit was filed on 09-05-2019 in U.S. District Court. 3.7, Response - RESPONSE TO PROLINKS OBJECTION TO THE DECLARATION OF PLAINTIFFS EXPERTS DECLARATION, Proof of Service (not Summons and Complaint), Declaration - DECLARATION OF ASHKAN SHAKOURI IN SUPPORT OF PLAINTIFFS RESPONSE TO PROLINKS OBJECTION TO THE DECLARATION OF PLAINTIFFS EXPERTS DECLARATION, Declaration - DECLARATION OF EXPERT TERESA FULIMENI IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS RENEWED MOTION TO STRIKE PLAINTIFFS FIRST AMENDED COMPLAINT AS UNMANAGEABLE, Declaration - DECLARATION OF ASHKAN SHAKOURI IN SUPPORT OF PLAINTIFFS OPPOSITION TO PROLINKS RENEWED MOTION TO STRIKE PLAINTIFFS FIRST AMENDED COMPLAINT AS UNMANAGEABLE, Opposition - OPPOSITION TO PROLINKS RENEWED MOTION TO STRIKE PLAINTIFFS FIRST AMENDED COMPLAINT AS UNMANAGEABLE, Reply - REPLY DEFENDANT PROLINK STAFFING SERVICES, LLCS REPLY IN SUPPORT OF MOTION TO STRIKE PLAINTIFFS FIRST AMENDED COMPLAINT AS UNMANAGEABLE, Objection - OBJECTION DEFENDANT PROLINK STAFFING SERVICES, LLCS OBJECTION TO DECLARATION OF EXPERT TERESA FULIMENI, Cases involving other labor matters not classified elsewhere, 790, 1750, 1790, 2750, 2790, 3750, 3790, 4790. Under the legal doctrine known as "res judicata," a matter already settled in court cannot be raised again in another proceeding. We are also in the middle of a Compliance Rework in which we are revisiting each process and adapting it to be the most accurate and efficient as possible. ProLink Staffing pays the highest-paid employees over $92,000 a year, while the lowest-paid employees are paid less than $25,000. Cases involving other labor matters not classified elsewhere, 790, 1750, 1790, 2750, 2790, 3750, 3790, 4790, Deborah Clay v. Prolink Staffing Services, LLC, et al, (#38) MINUTES (IN CHAMBERS) by Judge Jesus G. Bernal: Order (1) GRANTING Plaintiffs Motion for Final Approval of Class Action Settlement, (Dkt. Submit your resume and a recruiter will connect with you to guide the entire process. Service of the Summons and Complaint were executed upon Registered Agent for Service of Process in compliance with Federal Rules of Civil Procedure by personal service.Original Summons NOT returned. It is so remote friendly! Deborah Clay v. Prolink Staffing Services, LLC, et al. 2:19-CV-06457 | 2019-07-25, U.S. District Courts | Labor | Court watch: Travel healthcare staffing firms to pay $2.75 million On top of that, we have a collaborative and team driven culture here so that no one ever feels alone and left out. (Kroll-Rosenbaum, Sarah) (Entered: 05/08/2020), (#24) NOTICE OF MOTION AND MOTION for Settlement Approval of Class Action filed by Plaintiff Deborah Clay. Read employee reviews and ratings on Glassdoor to decide if ProLink Staffing is right for you. The hearing on the Motion for Final Settlement Approval of Class and request for Attorney Fees will proceed telephonically on Monday, November 9, 2020 at 11:00 a.m. Counsel/parties shall dial in at least 5 minutes before the hearing to the following number: (877) 336-1831; Access Code: 4899258. Recruiting is a bit of a rollercoaster and I feel I have the support I need whether at the top or the bottom. (mga) TEXT ONLY ENTRY (Entered: 11/06/2020), Docket(#35) SCHEDULING NOTICE by Judge Jesus G. Bernal. TheClassActionNews.com is a place to gather news, information, join lawsuits, learn about lawyers, learn about class actions and find justice. Please log in as a SHRM member before saving bookmarks. However, the plaintiffs' claims against the client raised the same claims, for the same work done, covering the same time period as the claims asserted in the action brought against the staffing agency. People: ProLink Staffing, Korn Ferry, GigRonin, LegalPartners Group (Attachments: #1 Memorandum, #2 Proposed Order) (Pawlenko, Kye) (Entered: 10/09/2020), (#31) Final NOTICE OF MOTION AND MOTION for Settlement Approval of Class Action filed by Plaintiff Deborah Clay. Find out more about, 78% of ProLink Staffing employees would recommend working there to a friend, Get started with your Free Employer Profile, training I have received here has been amazing, always rushed because something was forgotten/missed, mediocre benefits. (Kroll-Rosenbaum, Sarah) (Entered: 10/20/2020), (#32) REQUEST for Attorney Fees , Costs, Enhancement Payment, and Settlement Administration Fees filed by Plaintiff Deborah Clay. Find your private company bowl on Fishbowl, join the hottest conversation with your colleagues anonymously. Was this article useful? Your IT projects need to be delivered on time and on budget. In fact, the majority of mismanagement claimsjust over 60%are brought on by employees. (Attachments: #1 Memorandum Points & Authorities, #2 Appendix Compendium of Evidence, #3 Exhibit 1 to Compendium of Evidence (Hayes Declaration), #4 Exhibit 2 to Compendium of Evidence (Settlement Agreement), #5 Proposed Order) (Hayes, Matthew) (Entered: 04/21/2020), (#23) STATUS REPORT filed by Plaintiff Deborah Clay. Need help with a specific HR issue like coronavirus or FLSA? Virtual & Washington, DC | February 26-28, 2023. (mga) TEXT ONLY ENTRY (Entered: 11/06/2020)THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. #32 ). Motion set for hearing on 6/1/2020 at 09:00 AM before Judge Jesus G. Bernal. Pretty much a glorified assistant - pointless meetings every morning that you have to have your camera on for - training was absolutely NOTHING like the role you will be actually doing - No real direction as to what your role actually is. Many people I speak to are sad and unsatisfied and burnt out, yet put on a happy face and stick around for the money. 3.7 reservation no. SnapNurses have the option to be fully paid immediately after a shift ends. : 756937525202; As To Parties: removed, DocketUpdated -- Plaintiffs Objection to Prolink Staffing Services LLC's Request for Permission to Present Oral Testimony at Hearing reservation no. 7-15. (ad) (Entered: 10/22/2019), (#13) NOTICE of Appearance filed by attorney Sayaka Karitani on behalf of Defendant Prolink Staffing Services, LLC (Attorney Sayaka Karitani added to party Prolink Staffing Services, LLC(pty:dft))(Karitani, Sayaka) (Entered: 10/21/2019), (#12) [DOCUMENT ORDERED STRICKEN PER DOCUMENT NO. Your recruiter will always find the best contract or long-term role for you throughout your career no matter where you want to go. Toxic environment. 3.1306(b) and L.R. They are fine for the single plan but family plans are extremely high and there's been minimal improvement in the cost over the last couple of years. Your ProLink recruiter will reach out to you on a weekly basis to ensure your assignment is going smoothly and to help you decide what comes next. So, for res judicata to apply, the agency must have been "in privity" with the client, the court said. We are glad to hear that ProLink has met all of your expectations and you are experiencing our positive culture firsthand! (Hayes, Matthew) (Entered: 09/05/2019), (#1) COMPLAINT Receipt No: 0973-24386305 - Fee: $400, filed by Plaintiff Deborah Clay. #data #cloud #ethics #datagovernance Sometimes rosters are up to date, other times they are completely incorrect. Find out more about salaries and benefits at ProLink Staffing. Overlapping Case Dingers allow subscribers to set up automatic email notifications of any potential overlapping class action cases filed after that date which match the criteria of your search. Service of the Summons and Complaint were executed upon Registered Agent for Service of Process in compliance with Federal Rules of Civil Procedure by personal service.Original Summons NOT returned. Prior to ProLink Staffing, they both held senior level management positions at a national staffing company where they gained invaluable knowledge of the staffing industry. Culture, face value, is welcoming and helpful depending what team you are put on. No. This is the first job I've ever had that I feel like I have a work-life balance. Get customized staffing solutions to stay ahead of the competition in your industry. Bait and Switch Lawsuit | The Class Action News . 24] set for hearing on June 1, 2020, is hereby continued to June 15, 2020, at 9:00 A.M. (Morris, James) (Entered: 10/04/2019), (#10) STIPULATION Extending Time to Answer the complaint as to Prolink Staffing Services, LLC answer now due 11/8/2019, re Complaint (Attorney Civil Case Opening) #1 filed by Defendant Prolink Staffing Services, LLC. Very positive and supportive managers and team members. (esa) (Entered: 09/06/2019), (#5) NOTICE OF ASSIGNMENT to District Judge Jesus G. Bernal and Magistrate Judge Kenly Kiya Kato. Fastaff LLC and US Nursing Corp. agreed to pay $2.75 million to settle a class-action lawsuit that claimed the staffing firms did not take the value of travel healthcare workers . Find one near you. Request set for hearing on 11/9/2020 at 09:00 AM before Judge Jesus G. Bernal. Workers Who Settled Staffing Agency Claims Can't Sue Client By continuing to use this website, you agree to UniCourts General Disclaimer, Terms of Service, Internal and external. click on the next button). Prolink Staffing | Company Overview & News Benefits are mediocre. That's the only thing that made this job and company remotely bearable. PROLINK makes the road to insurance solutions simpler. Professional Pointer: Although the issues raised here may seem quite complicated and legalistic ("res judicata" and "privity"), this decision has everyday practical ramifications for staffing agencies and companies that use employees provided by staffing agencies: Under certain circumstances, courts may treat the two as inextricably linked for purposes of employment-related lawsuits. Founded in 2011 and headquartered in Cincinnati, Ohio, ProLink Staffing is a full-service staffing and recruiting firm offering comprehensive workforce management programs including contract, contract-to-hire (temp to perm), direct placement and managed services. You have successfully saved this page as a bookmark. (#10) STIPULATION Extending Time to Answer the complaint as to Prolink Staffing Services, LLC answer now due 11/8/2019, re Complaint (Attorney Civil Case Opening) #1 . Hearing04/28/2023 at 1:30 PM in Department 24 at 111 North Hill Street, Los Angeles, CA 90012; Hearing on Motion to Strike Plaintiffs' First Amended Complaint as unmanageable; DocketAmended Complaint (2nd); Filed by: Amanda Bowers (Plaintiff); Susan Tidwell (Plaintiff); As to: Prolink Staffing Services, LLC (Defendant), DocketNotice of Ruling; Filed by: Prolink Staffing Services, LLC (Defendant), DocketOn the Court's own motion, Case Management Conference scheduled for 11/04/2022 at 01:30 PM in Stanley Mosk Courthouse at Department 24 Held - Continued was rescheduled to 04/28/2023 01:30 PM, DocketOn the Court's own motion, Hearing on Motion to Strike Plaintiffs' First Amended Complaint as unmanageable; scheduled for 11/04/2022 at 01:30 PM in Stanley Mosk Courthouse at Department 24 Held - Continued was rescheduled to 04/28/2023 01:30 PM, DocketOrder Appointing Court Approved Reporter as Official Reporter Pro Tempore; Filed by: Prolink Staffing Services, LLC (Defendant), DocketMinute Order (Case Management Conference; Hearing on Motion to Strike Plain), DocketUpdated -- ProLink Staffing Services, LLC's request for permission to present oral testimony at hearing pursuant to C.R.C. Subscribers are able to delete current dingers at any time to replace new ones (i.e. Motion set for hearing on 11/9/2020 at 09:00 AM before Judge Jesus G. Bernal. 2:19-CV-09477 | 2019-11-04, U.S. District Courts | Labor | temp_style.textContent = '.ms-rtestate-field > p:first-child.is-empty.d-none, .ms-rtestate-field > .fltter .is-empty.d-none, .ZWSC-cleaned.is-empty.d-none {display:block !important;}'; } You are fully remote worker Weekly pay PTO starts first day, - the role that applied for was not what I ended up doing when I started. Request set for hearing on 11/9/2020 at 09:00 AM before Judge Jesus G. Bernal. (Hayes, Matthew) (Entered: 09/05/2019), (#2) Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening) #1 filed by Plaintiff Deborah Clay. Subscribers are able to delete current dingers at any time to replace new ones (i.e.
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