1.  To enter an Order certifying the proposed Class under Rule 23 and  appointing Plaintiffs and the undersigned counsel of record to represent the Class;   12.  Law enforcement agencies in North Carolina are obligated to investigate  crashes which are reported to them, such as those described below.    13.  In conducting crash investigations, law enforcement officers in North  Carolina must use a DMV-349 to record their investigations of reportable crashes, as  defined by N.C. Gen. Stat. § 20-4.01(33b).   14.  When law enforcement officers complete the DMV-349 in connection with  a crash investigation, they are obligated to comply with the then-current edition of the  Instruction Manual for the DMV-349 (“the Manual”).   16.  At the time of the collisions described below, the Manual instructed officers  to review the registration information for each vehicle involved in the wreck and to  record the name and address of the registered owner of each involved vehicle on the  2.  To permanently enjoin each Defendant, pursuant to 18 U.S.C. §2724(b)(4),  from:  a.  Obtaining names and addresses sourced from DMV-349s for  purposes of marketing legal services;  b.  Sending letters marketing legal services to drivers whose names  and/or addresses are obtained by Defendants by means of DMV- 349s; and  c.  Sending letters containing a copy of a completed DMV-349 for the  purpose of marketing legal services.   3.  To award liquidated damages, pursuant to 18 U.S.C. §2724(b)(1), to each  Plaintiff in the amount of $2,500.00 for instance in which a Defendant knowingly  obtained or used that Plaintiff’s protected personal information;    4.  To award reasonable attorneys’ fees and other litigation costs reasonably  incurred, pursuant to 18 U.S.C. §2724(b)(3);   5.  To award pre- and post-judgment interest as allowed by law;    53.  Plaintiffs bring this action on behalf of a class defined as follows:  a.  All natural persons  b.  residing in North Carolina  c.   identified on a DMV-349 as either   i.  a driver whose address is designated on the DMV-349 as  matching the address on that person’s driver’s license or   ii.  a registered owner of a vehicle registered with the North  Carolina Division of Motor Vehicles  d.  to whom a Defendant named in this action sent a mailing with the  words “This is an advertisement for legal services” printed on the  outside of the envelope   e.  within the 4 years preceding the filing of this action through  conclusion of this action.   55.  Existence and Predominance of Common Questions of Law and Fact  (Fed. R. Civ. P. 23(a)(2)): Common questions of law and fact exist as to all members of  the Class, and predominate over the questions affecting only individual members. The  common legal and factual questions include:  a.  Whether Defendants knowingly obtained protected personal  information from a motor vehicle record;  b.  Whether Defendants’ primary purpose in obtaining protected  personal information was the marketing of legal services; and  c.  Whether Defendants violated section 2722(a) of the DPPA by  obtaining or disclosing personal information from a motor vehicle  record without a permissible purpose under section 2721(b) of the  6.  For a trial by jury on all issues so triable; and   60.  Defendants knowingly obtained and used one or more Plaintiff’s protected  personal information from a motor vehicle record as described above.   61.  Each Defendant knowingly obtained and used one or more Plaintiff’s  protected personal information from a motor vehicle record for the purpose of marketing  that Defendant’s legal services.   62.  When each Defendant knowingly obtained and used one or more Plaintiff’s  protected personal information, said Defendant lacked Plaintiffs’ express consent as  required by the DPPA.   63.  When each Defendant sent its above-described mailing containing the  words “This is an advertisement for legal services” to one or more Plaintiffs, Defendants  knowingly used said Plaintiff’s personal information from a motor vehicle record.   64.  Defendants knowingly both obtained and used Plaintiffs’ personal  information from a motor vehicle record for the purpose of marketing legal services.   65.  Advertising for legal services for the solicitations of new potential clients is  not a permissible purpose for obtaining motor vehicle records under the DPPA. Maracich  v. Spears, 133 S. Ct. 2191 (2013).   66.  Defendants knowingly both obtained and used Plaintiffs’ personal  information from a motor vehicle record in violation of the DPPA.   68.  Under 18 U.S.C. § 2724(b)(4), the Court should enter a permanent  injunction prohibiting Defendants from obtaining or using personal information from  motor vehicle records for marketing purposes. Specifically, the Court should enjoin  Defendants from:  a.  Obtaining names and addresses sourced from DMV-349s for  purposes of marketing legal services;  b.  Sending mailings marketing legal services to drivers whose names  and/or addresses are obtained by Defendants by means of DMV- 349s; and  c.  Sending letters containing a copy of a completed DMV-349 for the  purpose of marketing legal services.   7.  For such other and further relief as the Court deems just and proper.  The DMV-349 Accident Report   VIOLATION OF  THE DRIVER’S PRIVACY PROTECTION ACT  (18 U.S.C. § 2721 ET SEQ.)  