Here is the expert report we filed on the issue of ATDS.  PRA uses a “Click to Dial” for cell calls.  We are arguing it is still an ATDS  because it is all one system.

Randy Snyder Report – Snyder Declaration

 

Documents related to the case are listed and downloadable from this page.

593 Order on Discovery

597 Order Appointing Co-Lead Counsel

600 Joint Discovery Plan

609 Case Management Order

611 Protective Order

Plaintiffs’ Interrogatories and Requests for Production – Set One

Plaintiffs’ Interrogatories and Requests for Production – Set Two

Defendants’ First Set of Interrogatories, Requests for Production, and Requests for Admission

PRA’s Responses to Plaintiffs’ First Set of Interrogatories and Requests for Production of Documents

Plaintiffs’ Responses to Discovery – Set One

Defendant’s Responses to Plaintiffs’ Second Set of Interrogatories and Requests for Production of Documents