10.  CCA-Leavenworth’s phone and videoconference services are provided by Securus.  Securus charges families and others a fee for speaking to a detainee. It shares those proceeds with  CCA-Leavenworth, which creates profit for both entities.    11.  Plaintiffs were detained through a Pretrial Order of Detention issued by a United  States Magistrate Judge, and remanded to the custody of the United States Marshal Service to be  held pending resolution of their criminal cases.   12.  Plaintiff Huff was remanded to the custody of United States Marshal Service through  a Pretrial Detention Order entered in United States v. Gregory Rapp, et al., Case No. 14-cv-20067- DJW, and was detained at CCA-Leavenworth on or about October 6, 2015. During the course of  representation, Plaintiff Huff had numerous conversations with her attorney, both telephonically  and in-person.   14.  Detainees, including Plaintiffs Huff and Rapp, routinely contact their attorneys by  phone and/or in person to discuss confidential matters. They do so with the understanding that their  conversations are private. Similarly, detainees understand that in-person and remote conversations  with their attorneys are confidential and not recorded.    15.  Plaintiffs Huff and Rapp routinely communicate with their attorneys both in person  and also from locations in Kansas City, Missouri.    16.  Plaintiffs Huff and Rapp made calls to their attorneys’ cellular phone. Plaintiff Huff  and Rapp would use a prepaid phone card to call their attorneys. Upon information and belief, some  or all of the calls to or from Plaintiffs occurred in the States of Kansas and Missouri.   17.  Upon information and belief, Defendants recorded communications between  detainees at CCA-Leavenworth and the outside world. The equipment they used to intercept, record,  and/or share detainees’ calls neither facilitates those telephone calls and in-person meetings, nor  were the recordings a necessary incident of the calls and meetings.   18.  Upon information and belief, during in-person meetings between attorneys and their  client/detainees, CCA and/or Securus also routinely recorded those meetings, without either the  consent of either attorneys or their client/detainees. Video cameras were placed in attorney/client  visitation rooms and those video cameras recorded communications between the attorneys and their  client/detainees.   19.  Courts in the District of Kansas have issued orders noting the extent to which CCA  and Securus were involved in the systematic accessing and recording of attorney-client  conversations at CCA-Leavenworth. See exhibits A and B attached hereto.   21.  CCA and/or Securus were aware that they were operating a system that captured and  recorded confidential attorney-client communications.   22.  Plaintiffs were, and current detainees are, at substantial risk of having their attorney  calls and meetings monitored, recorded and used against them to prejudice their cases.   23.  The unlawful practices and procedures of Defendants described above affected all  detainees at CCA-Leavenworth.  24.  Unless otherwise specifically stated herein, and pursuant to Fed. R. Civ. P. 23(b)(3),  this action is instituted by Plaintiffs on behalf of themselves and  All detainees at CCA-Leavenworth, from June 1, 2012 to the present whose  confidential communications with their attorneys were intercepted, disclosed or  used by Defendants.   25.  Upon information and belief, the class referenced above includes hundreds of  putative class members residing in Missouri and Kansas and therefore, the class is so numerous that  joinder of all members of the class would be impractical.   27.  The claims of the Plaintiffs are typical of the claims of the putative class in that:  a.  Plaintiffs and the putative class members were all detained at CCA-Leavenworth;  b.  Plaintiffs and the putative class members were all subjected to the same unlawful  wiretapping policies and procedures of Defendants, and  c.  The facts common to Plaintiffs and the putative class members give rise to the same  claims asserted in this Complaint.   28.  Plaintiffs, as representatives for the putative class, will fairly and adequately protect  the interests of the putative class because:  a.  Plaintiffs have knowledge regarding the facts and circumstances that give rise to  their claims and the claims of the putative class members;  b.  Plaintiffs are strongly interested and highly motivated to assert and protect their own  rights and the rights of the putative class in a vigorous fashion; and  c.  Plaintiffs have retained class counsel with substantial experience and expertise in  class actions, commercial litigation and business litigation and which have the  necessary and requisite resources. These law firms will vigorously assert and protect  the interests of the putative class members.   30.  Plaintiffs incorporate by reference the foregoing paragraphs of this Complaint.   31.  The Missouri wiretap statute broadly prohibits the interception, disclosure or use of  any wire, oral or electronic communication.   32.  Defendants have violated (and may continue to violate) detainees’ rights under the  Missouri Wiretap statute. The individual Plaintiffs, and all class members, are directly affected.   33.  CCA and Securus have acted (and continue to act) unlawfully to intercept  communications between Class members, like Plaintiffs, and their attorneys, and disclose those  confidential communications to third parties, including law enforcement, in violation of the Act.   34.  CCA and Securus violate the Missouri Wiretap Act when they intercept, disclose,  use, or procure other persons to intercept, disclose or uses communications between class members,  like Plaintiffs, and their attorneys. See R.S.Mo. § 542.418.   35.  Plaintiffs are entitled to the rights, protections, and benefits provided under the  Missouri Wiretap Act, codified at R.S.Mo. §§ 542.400 et seq.   36.  Defendants are Persons within the meaning of the Missouri Wiretap statute.   37.  Plaintiffs and the putative class are “aggrieved persons” within the meaning of the  Missouri Wiretap statute.   38.  As set forth herein, Defendants unlawfully recorded confidential communications  between Plaintiffs, the putative class and their attorneys.   40.  Pursuant to the Missouri Wiretap Act, Plaintiffs and the Class Members are each  entitled to damages not less than one hundred dollars a day for each day of violation or ten thousand  dollars, whichever is greater.   41.  Plaintiffs and the Class Members are entitled to punitive damages. Defendants’  conduct has at all times been willful or intentional within the meaning of the Missouri Wiretap  statute. Defendant is also liable pursuant to R.S.Mo. § 542.418 for Plaintiffs’ attorneys’ fees and  costs/expenses incurred in this action.   42.  The Plaintiffs and the Class Members are all similarly situated in that they were all  subject to Defendants’ policy and practice of recording confidential attorney-client communications  without consent of either party, in violation of the Missouri Wiretap statute.  43.  Plaintiffs incorporate by reference the foregoing paragraphs of this Complaint.   44.  The Kansas wiretap statute broadly prohibits the interception, disclosure or use of  any wire, oral or electronic communication.   45.  Defendants have violated (and may continue to violate) detainees’ rights under the  Kansas Wiretap statute. The individual Plaintiffs, and all class members, are directly affected.   46.  CCA and Securus have acted (and continue to act) unlawfully to intercept  communications between Class members, like Plaintiffs, and their attorneys, and disclose those  confidential communications to third parties, including law enforcement, in violation of the Act.   48.  Plaintiffs are entitled to the rights, protections, and benefits provided under the  Kansas Wiretap Act, codified at K.S.A. §22-2502, et seq.   49.  Defendants are Persons within the meaning of the Kansas Wiretap statute.   50.  Plaintiffs and the putative class are “aggrieved persons” within the meaning of the  Kansas Wiretap statute.   51.  As set forth herein, Defendants unlawfully recorded confidential communications  between Plaintiffs, the putative class and their attorneys.   52.  Upon information and belief, in some cases the Defendants disclosed class members’  confidential communications to third parties, such as law enforcement, in further violation of the  Kansas Wiretap statute.   53.  Pursuant to the Kansas Wiretap Act, Plaintiffs and the Class Members are entitled  to damages, but not less than liquidated damages computed of one hundred dollars a day for each  day of violation or ten thousand dollars, whichever is greater.   54.  Plaintiffs and the Class Members are further entitled to punitive damages.   55.  Defendants are liable pursuant to K.S.A. 22-2518 for Plaintiffs’ attorneys’ fees and  costs/expenses incurred in this action.   56.  The Plaintiffs and the Class Members are all similarly situated in that they were all  subject to Defendants’ policy and practice of recording confidential attorney-client  communications without consent of either party, in violation of the Kansas Wiretap statute.  57.  The Federal Wiretap Act broadly prohibits intercepting, disclosing, or using the  contents of any wire, oral, or electronic communication.   59.  CCA and/or Securus have acted unlawfully to intercept communications between  Class members, like Plaintiffs, and their attorneys, and possibly disclosed those confidential  communications to third parties, including prosecutors, in violation of the Act.   60.  Defendants violate the Federal Wiretap Act when they:    Intentionally intercept, disclose, use, or procure other persons to intercept, disclose  or use wire oral or electronic communications (including, but not limited to phone  calls and in-person meetings) between Plaintiffs and the putative class and their  attorneys.    Intentionally discloses, or endeavors to disclose, to any other person the contents  of any wire, oral, or electronic communication, knowing or having reason to know  that the information was obtained through the interception of a wire, oral, or  electronic communication in violation of 18 U.S.C. § 2511.  9.  Defendant CCA is a private, for-profit corporation that manages detention facilities,  including CCA-Leavenworth. The United States Marshal’s Service uses detention facilities  operated and managed by CCA, including CCA-Leavenworth, to house federal inmates charged in  the Western District of Missouri.   Violation of the Federal Wiretap Statute (18 U.S.C. § 2510, et. seq.)   Violation of the Kansas Wiretap Statutes   Violations of the Missouri Wiretap Statutes  