Immigration Consultant Act (ICA) in California

Plaintiff asserts that Defendants violated the ICA on multiple grounds. The Immigration Consultant Act Under California Business and Professions Code, Section 22446.5 “[a] person claiming to be aggrieved by a violation [of] [the] [ICA] by an immigration consultant may bring a civil action for injunctive relief” on their behalf or on behalf of the general public.

Lainez for violation of the Immigration Consultant Act (ICA). On October 26, 2022, Defendant filed a demurrer to the FAC. A demurrer for sufficiency tests whether the complaint states a cause of action. ( Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.) When considering demurrers, courts read the allegations liberally and in context, accepting the alleged facts as true. ( Nolte v. Cedars-Sinai Medical Center (2015) 236 Cal.App.4th 1401, 1406.)

As Plaintiff points out in the Opposition, any other party who is not aggrieved by violations of the Immigration Consultant Act, Business and Professions Code § 22440 et seq., who claims upon information and belief that the Act was violated by an immigration consultant may bring a civil action for injunctive relief. (Bus. & Prof. Code § 22446.5(b).)

.; NIW Korea; and Rex Counselor, Inc. alleging a single cause of action for violation of the Immigration Consultant Act pursuant to California Business and Professions Code, Section 22440 et seq.

Plaintiff asserts a cause of action for violations of the Immigration Consultant Act. /// II. LEGAL STANDARD Any other party who, upon information and belief, claims a violation of this chapter has been committed by an immigration consultant may bring a civil action for injunctive relief on behalf of the general public and, upon prevailing, shall recover reasonable attorneys fees and costs. Bus. & Prof. Code § 22446.5(B).

What is in dispute is the correct application of California surety law generally and the provisions of the bond provisions of the California Immigration Consultants Act (“ICA”) appearing at Bus. & Prof. Code § 22443.1(a) to an award of attorney fees and costs to a non-injured plaintiff as allowed by the “private attorney general” provisions of the ICA appearing at Bus. & Prof. Code § 22446.5(b).

The ICA also sets forth numerous other grounds in which the ICA may be violated under Bus. & Prof. Code, §§ 22440 et seq . Section 22440 governs nonlawyers who offer non-legal assistance in immigration matters in California. Under Bus. & Prof.

On January 18, 2017, plaintiff filed a complaint, on May 5, 2017, a first amended complaint for (1) violation of the Immigration Consultant Act (ICA; Business and Professions Code section 22440, et seq.; against LAIA and Does), (2) intentional deceit (against all defendants), (3) negligent deceit (against all defendants), (4) negligence per se (against all defendants), (5) negligence (against LAIA and Does), (6) professional negligence (against LAIA and Price), (7) intentional conduct (against LAIA and Price

Consultant Act: Business & Professions Code §§ 22440, 22441, 22441.1, 22442, 22442.1, 22442.2, 22442.3, 22442.4, 22442.5, 22442.6, 22443, 22443.1, 22443.2, 22443.3, 22444, 22445, 22446.5, and 22447. 7) EXHIBIT H: Conformed copy first page of Plaintiff's Opposition to Motion to Quash Service of Summons, filed on October 23, 2023.

MOTION TO TAX COSTS MOVING PARTY: Defendants Brandi Linton and Pecorelli Enterprises RESPONDING PARTY(S): Plaintiff Immigrant Rights Defense Counsel STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS: Plaintiff Immigrant Rights Defense Counsel filed this action against Defendants Brandi Linton, Luther Linton, and Pecorelli Enterprises, alleging violations of the Immigration Consultant Act. Defendant Luther Linton was dismissed on August 13, 2021.

Consultant Act [Whole]. 11) Exhibit K: Business and Professions Code §22446.5 with Suggested Form Pleading that Contains CCP §526(a) Pleading Allegations [Whole]. 12) Exhibit L: Defendant's Immigration Bond [Whole]. 13) Exhibit M: Secretary of State's Acknowledgment of Immigration Bond [Whole]. 14) Exhibit R: Public Portal Printout from LASC Website, Reflecting no Proof of Service Filed by Plaintiff [Whole]. 15) Exhibit S: Defendant's Request for Admissions, Set

Background IMMIGRANT RIGHTS DEFENSE COUNCIL, LLC (Plaintiff) filed a Complaint for Violation of the Immigration Consultant Act (ICA), alleging that Defendants are engaged in the business of an immigration consultant, but are not practicing in conformity with the ICA.

FIRST CAUSE OF ACTION – VIOLATION OF THE IMMIGRATION CONSULTANT ACT The Immigration Consultant Act (“ICA”) provides that “[i]t is unlawful for any person, for compensation, other than persons authorized to practice law or authorized by federal law to represent persons before the Board of Immigration Appeals or the United States Citizenship and Immigration Services, to engage in the business or act in the capacity of an immigration consultant within this state except as provided by this chapter.”

Discussion Plaintiffs counsel provides that the effect of the amendment is to remove any allegations against dismissed party Grace University including the fourth cause of action for civil conspiracy, to add a seventh cause of action for violation of the California Immigration Consultant Act (ICA), and to add an eighth cause of action for injunctive relief pursuant to ICA. (Luan Decl., ¶ 7-8.)

On September 27, 2023, Plaintiff Immigration Rights Defense Council, LLC (“Plaintiff”) filed a Complaint against Defendant Sofia Solis (“Defendant”) for Injunctive Relief, alleging a single cause of action for Violation of the Immigration Consultant Act (“ICA”) - California Bus. & Prof. Code § 22440, et seq. Plaintiff alleges that Defendant is engaged in the unauthorized practice of law and provides legal advice to her customers.

Defendants have violated numerous provisions of the ICA in the course of their business. PROCEDURAL HISTORY On May 16, 2022, IRDC filed the Complaint asserting a single cause of action for Violation of the Immigration Consultant Act. On July 29, 2022, Sim filed an Answer. On August 12, 2022, IRDC filed the instant Motion to Deem Request for Admission Admitted as to Global MJ. On December 20, 2022, the Court held a hearing on this matter.

In the sole cause of action, the SAC alleges that Defendants engaged in certain conduct that violates the Immigration Consultant Act. (SAC ¶¶ 13-20.) Unlike the FAC, which was nothing more than a recitation of the possible violations, the SAC contains factual allegations. For example, Defendants advertise and market their services on various internet media, including without limitation, Google My Business, and via their website inmigracionla.com. (FAC ¶ 14.)

BACKGROUND On May 18, 2018, Plaintiff filed the operative First-Amended Complaint (“FAC”) against Defendants alleging a single cause of action for violation of the Immigration Consultant Act (“ICA”) pursuant to California Business and Professions Code, Section 22440, et seq. Plaintiff’s complaint arises from Defendants’ alleged improper actions with respect to her National Interest Waiver (“NIW”) petition for immigration purposes.

Background IMMIGRANT RIGHTS DEFENSE COUNCIL, LLC (Plaintiff) filed suit against Defendants for alleged violation of the Immigration Consultant Act (ICA) Plaintiff has filed four motions to compel Defendants IRBusiness, Inc. and Alexandra Imelda Rodriguez (Defendants) to serve verified responses to Plaintiffs form interrogatories and document requests, and for sanctions against each Defendant in the amount of $2,560.00. Defendants oppose the motions. .

The Second Amended Complaint (SAC) alleges a single cause of action for a violation of the Immigration Consultant Act (Bus. & Prof. Code, § 22440, et seq .). On June 30, 2023, Plaintiff filed a Motion for Terminating, Evidence, and/or Issue Sanctions and Request for Monetary Sanctions Re: Spoilation of Evidence. Defendant filed opposing papers on July 13, 2023. Plaintiff filed a reply on July 20, 2023.

BACKGROUND On May 18, 2018, Plaintiff filed the operative First-Amended Complaint (“FAC”) against Defendants alleging a single cause of action for violation of the Immigration Consultant Act (“ICA”) pursuant to California Business and Professions Code, Section 22440, et seq. Plaintiff’s complaint arises from Defendants’ alleged improper actions with respect to her National Interest Waiver (“NIW”) petition for immigration purposes.

Plaintiff filed a First Amended Complaint on 12/29/17 against Defendants for: (1) Violation of the Immigration Consultant Act. This is a private attorney general action. Plaintiff alleges that defendant unlawfully holds himself out as an attorney offering immigration services and that defendant is not actually a licensed attorney. ANALYSIS: The instant motion was filed on 12/17/17. Plaintiff filed a First Amended Complaint on 12/29/17. As a result, defendant’s demurrer is moot.

Plaintiff has sufficiently alleged that, on numerous occasions, Plaintiff and/or his counsel informed Defendants that ICA did not apply to Plaintiff. A reading of the plain language of Business and Professions Code section 22440 would clearly inform Defendants that the ICA did not apply to Plaintiff.

Lainez for Violation of the Immigration Consultant Act. On May 18, 2022, Plaintiff served its Request for Production of Documents, Set One; Request for Admissions, Set One; and Form Interrogatories, Set One. On July 25, 2022, Plaintiff filed a first amended complaint.

Code § 22440 (2nd Cause of Action) Section 22440 et seq. of California Business and Professions Code governs nonlawyers who offer non-legal assistance in immigration matters in California.

Code § 22446.5(b) states: “Any other party who, upon information and belief, claims a violation of this chapter has been committed by an immigration consultant may bring a civil action for injunctive relief on behalf of the general public and, upon prevailing, shall recover reasonable attorneys’ fees and costs.”

The Complaint alleges one cause of action for violation of the Immigration Consultant Act. Plaintiff indicates that on August 28, 2023, Plaintiff served Request for Admissions, Set One, on Defendant. (Medvei Decl., ¶ 4, Ex. 1.) On November 3, 2023, Plaintiff filed this motion before participating in an informal discovery conference. On March 6, 2024, the parties participated in an Informal Discovery Conference.

On 10/16/2023, Plaintiff Immigrant Rights Defense (Plaintiff) filed suit against Guadalupe Avitia-Dominguez and Income Tax Solutions, seeking injunctive relief for violation of the Immigration Consultant Act. On 1/16/2024, Plaintiff moved to have its Requests for Admission (RFAs) deemed admitted as to Defendant Income Tax Solutions (Defendant). The motion is unopposed. Discussion On 11/7/2023, Plaintiff served Defendant with RFAs.

(Business & Professions Code §22446.5.) Defendant contends that Plaintiff violated section 22443.3 by making false or misleading statements while providing services to a client. (SACC ¶56.)

(Business & Professions Code §22446.5.) Defendant contends that Plaintiff violated section 22443.3 by making false or misleading statements while providing services to a client. (SACC ¶56.)

(Business & Professions Code §22446.5.) Defendant contends that Plaintiff violated section 22443.3 by making false or misleading statements while providing services to a client. (SACC ¶56.)

(Business & Professions Code §22446.5.) Defendant contends that Plaintiff violated section 22443.3 by making false or misleading statements while providing services to a client. (SACC ¶56.)

On 10/16/2023, Plaintiff Immigrant Rights Defense (Plaintiff) filed suit against Guadalupe Avitia-Dominguez and Income Tax Solutions, seeking injunctive relief for violation of the Immigration Consultant Act. On 1/16/2024, Plaintiff moved to compel Defendant Guadalupe Avitia-Dominguez (Defendant) to respond to Form Interrogatories. Separately, on 1/16/2024, Plaintiff also moved to have its Requests for Admission (RFAs) deemed admitted as to Defendant.

In opposition, Plaintiff primarily argues that information about Defendants financial condition is necessary as part of her claims that are based on Business and Professions Code section 22440 (Section 22440).

Demurrer sustained with leave. 5th COA (Business & Professions Code Section 22440) - Business & Professions Code §22440 (part of the Immigration Consultants Act) provides: It is unlawful for any person, for compensation, other than persons authorized to practice law or authorized by federal law to represent persons before the Board of Immigration Appeals or the United States Citizenship and Immigration Services, to engage in the business or act in the capacity of an immigration consultant within this state except

Plaintiff alleges that he was terminated in violation of public policy because he raised concerns that Defendant was violating the Immigration Consultants Act (the ICA). The ICA requires written contracts to contain certain information, per Business and Professions Code section 22442(b). This discovery is relevant to establish that Plaintiff had a good-faith belief that Defendant was violating the ICA, which is an element of a wrongful termination claim.

Case Number: 22STCV29698 Hearing Date: August 29, 2023 Dept: 48 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT ICA SPICES CORP, Plaintiff, vs.

Plaintiff provided evidence that he is not an immigration consultant as defined in the Immigrations Consultants Act (ICA), for violating the ICA. Plaintiff informed Defendant that the ICA does not apply to attorneys, per Congress language in the statute itself. Plaintiff repeatedly asked Defendant to dismiss the case and Defendant refused. Eventually, Plaintiff served a motion for sanctions under Code of Civil Procedure section 128.7 on Defendant.

In his supplemental brief, petitioner argues the FAA applies, citing to section 1 of the Investment and Consulting Agreement ("ICA"). Section 1 of the ICA refers to a list (not 1 attached) called "Schedule 1" of petitioner's investment interests. ROA # 1, Ex. A. The ICA does not mention the FAA, nor does it show on its face that the agreement involves interstate or foreign commerce. Petitioner has also cited to his reply declaration.

Plaintiff provided evidence that he is not an immigration consultant as defined in the Immigrations Consultants Act (ICA), for violating the ICA. Plaintiff informed Defendant that the ICA does not apply to attorneys, per Congress language in the statute itself. Plaintiff repeatedly asked Defendant to dismiss the case and Defendant refused. Eventually, Plaintiff served a motion for sanctions under Code of Civil Procedure section 128.7 on Defendant.

.: BC716413 Hearing Date: August 12, 2021 ICA is awarded $595,340 in reasonable attorney fees. On 8/6/2018, Plaintiff Institute of Contemporary Art, Los Angeles (ICA) filed suit against 1717 UDT, LLC, seeking specific performance and declaratory relief. On 5/20/2021, after a bench trial, the Court issued a final statement of decision ruling in favor of ICA.

As to the allegations regarding Sotheby's failure to obtain the errors and omissions insurance policy, the ICA is reasonably susceptible to plaintiffs' proffered interpretation of the ICA. As to the allegations regarding the administrative fee, plaintiffs adequately allege that the parties' contract does not allow for such a fee and thus the imposition of such a fee breached the parties' contract. As to the Sotheby's statute of limitations arguments, Mr.

On 8/6/2018, Plaintiff Institute of Contemporary Art, Los Angeles (ICA) filed suit against 1717 UDT, LLC, seeking specific performance and declaratory relief. On 5/20/2021, after a bench trial, the Court issued a final statement of decision ruling in favor of ICA. Now, ICA moves for $695,340.00 in attorney fees as the prevailing party under the option agreement. The motion is unopposed.

P23-01363 GUARDIANSHIP OF: RADWAN AMEN OMER 9:30 AM HEARING IN RE: PETITION FOR APPOINTMENT OF GUARDIAN FILED ON 07/28/23 BY INTERNATIONAL CHRISTIAN ADOPTIONS dba ICA Need: 1. Appearances in person, not via Zoom 2. Court Investigator’s Report Notes: 1. Proposed ward is 18 years old. 2. Attachment 15 to proposed Order requests that order be effective as of 6-19- 2023. 3.

regulated by the ICA.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

by the ICA.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

the ICA.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

are regulated by the ICA.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

by the ICA.

by the ICA.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

by the ICA.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

by the ICA.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.

Each response sets forth the history of the ICA and argues that the defendants in the subject cases are unrelated to each other and have violated the ICA though different facts and transactions involving different subsets of the immigrant population – which have been more specifically pleaded in amended complaints in response to demurrers filed in some of the cases.