CAM4-003959-18 10/18/2018 11:50:32 AM Pg 1 of 8 Trans ID: LCV20181819213 BARON & BRENNAN, P.A. Jeffrey | Baron, Esquire ‘Attomey LD. No, 001451973 SEAPFORDSHIKE PROrEESIONAL CENTER 1307 White Horse Road Building F~ Suite 600 ‘Voorhees, New Jersey 08043, Phone: 856-627-6000 Fax: 856-627-4548 Attorneys for Plaintift [ANNE KOONS, SUPERIOR COURT OF NEW JERSEY LAW DIVISION Paint, ‘CAMDEN COUNTY ws DOCKET NO. CAM-L- JETSMARTER, INC., JOSHUA RAIA, : CIVIL ACTION and JON DOES 1-5, : COMPLAINT AND DEMAND FOR Defendants 5 JURY TRIAL Plaintiff Anne Koons, by and through her undersigned attomeys and by way of int defendants JetSmarer, In., Joshua Raia and John Does 1-5, says the PARTIES Plaintiff Anne Koons (*Koons") is resident of the State of New Jersey ‘maintaining her address at 9 New London Court, Voothees, New Jersey. formation and belief, defendant JeSmartr, Ine. (“JetSmarter”) is a 2 Upo Delaware corporation maintaining its offies at $00 East Broward Boulevard, Suite 1900, Fort Lavderdale, Florida 33394, 3. Upon information and belief, defendant Joshua Raia (“Raia”) was a sales agent or representative of JetSmarter.CAM1-003959-18 10/18/2018 11:50:32 AM Pg 2 of 8 Trans ID; LCV20181819213 4. Upon information and bli, defendants John Does 1-5 are directors, ofiers n/or managers of JetSmarter who developed, approved andor implemented JetSmarte's ‘marketing and sales programs and may have otherwise been involved inthe misrepresenatons sade to Koons. OPERATIVE FACTS 5. Plain incorporates al ofthe foregoing paragraphs by reference os if those ‘Paragraphs were fully set forth at length herein. 6. Inor about 2016, JetSmarter began sending unsolicited emails o Koons advertising its private jet concierge se 7. Ineddition to receiving emails from Jet Smarter, Koons viewed other promotional ‘materials which JetSmarter caused to be publicly disseminated during 2016 und 2017. 8, Inorabout December 2017, based on the solicitations and advertisements which she received, Koons entered into discussions with JetSmarter and its sles representative Raia bout purchasing JetSmarier's serve. 9. Koons explained to JetSmarter and Raia that she had an interest in JetSmaster's service because she frequently flew to South Florida and Los Angeles. 10. Koons expressed concem, however, about the availability ofthe flights sponsored by JotSmarter as wel a the distance ofthe airport from which they would be based given the location of her residence in Voorhees, New Jersey. 11, JetSmarter and Raia assured Koons that she would have access to regularly scheduled fights based out of Teterboro Airport which routinely serviced both South Florida and Los Angeles.CAM4-003959-18 10/18/2018 11:50:32 AM Pg 3 of 8 Trans ID: LCV20181819213 12, JetSmarter and Raia further indieated to Koons that they intended to establish Aight ou of Philadephia Intemational Aiport (a loaton closer Koons residence) based on an inceasing demand for JetSmarter’s services inthe Philadelphia metropolitan are. 15, _JetSmarter and Reis explained to Koons that upon payment ofa members fee she would be entitled to lyon lights with a duration of up to three hours at no additonal east. 14 Koons paid $14,000.00 for a one-year membership. 15. Almost immediately after her purchase, Je‘Smarter sent Koons various solicitations and other materials urging her to upgrade her membership based upon addtional promised benefits, including a 10,000 flight credit bonus and a free trip to Augusta. 16. Based on these and other additional promised benefits, Koons purchased a three- year Sophisticated level membership for $98,000.00. 17. Within a matter of few months, JetSmarter advised Koons that despite the substantial sum that she paid, it was unilaterally changing the Sophisticated membership program including, inter alia, the elimi ion of no addtional cost lights andthe elimination of complimentary helicopter service. 18, Making matters worse, and despite the prior representations made by JetSmarter and Raia to Koons, the frequency of scheduled flights based out of Teterboro Airport have realy decreased and service was never etblished out ofthe Philadelphia Intemational Agport. 19, Over this same period of time, the costs ofthe flights available through JetSmarter 20, Koons attempted to speak to JesSmarter and Raia multiple times about the various ‘changes made without her consent and without reimbursement of the money which she paid,