1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas New Case Electronically Filed: COMPLAINT  August 12,2020 15:16 By: JAMES S. WERTHEIM 0029464 Confirmation Nbr. 2049889 19.  In around August 2018, Plaintiff received a postcard from Superior Healthcare  advertising a seminar regarding the use of stem cell therapy for back problems.  20.  Plaintiff has had constant back problems for many years and was in severe pain  daily.  21.  She was desperate.  22.  Before her appointment, Plaintiff reviewed Superior HealthCare’s website which  made promises of a safe, effective and proven therapy.  23.  She could not afford to pay for the $10,000 treatment out of pocket.  24.  Superior Healthcare arranged for the financing of the $10,000 treatment through Defendant on the spot.  25.  Without this funding, Plaintiff could never have undertaken the procedure.  26.  Defendant implies that it will work with the provider regarding any complaints.  27.  Defendant does not do so.  28.  Defendant conspired with Superior Healthcare and preyed on Plaintiff, who was  in a desperate state.  29.  Plaintiff was harmed by Defendant’s actions.  30.  Plaintiff has been damaged in an amount of at least $10,000.  31.  Plaintiff is entitled to statutory damages and attorney fees. 32.  Plaintiff brings this action individually and on behalf of all others similarly  situated, as members of an Ohio class (the “Class”) preliminarily defined as: Electronically Filed 08/12/2020 15:16 / / CV 20 935892 / Confirmation Nbr. 2049889 / CLJSZ 4 (a) Residents of the State of Ohio at the time they received the treatment; (b) Who were treated at any facilities with any kind of stem cell therapy; (c) Whose treatment was financed by Defendant; (d) Within the four years prior to the date of the filing of this Complaint.  33.  Excluded from the proposed Class are the judicial officers and their immediate  family members and associated court staff assigned to this case, as well as all persons who make  a timely election to be excluded from the proposed Class. B. A Class Action is Superior  34.  This action is properly maintainable as a class action under Ohio Rule of Civil  Procedure 23.  35.  Numerosity. The proposed Class consists of at least hundreds or more persons,  such that joinder of all Class members is impracticable.  36.  Commonality. There are questions of law and fact that are common to the Class  members that relate to Defendant’s uniform conduct as set forth above.  37.  Typicality. The claims of Plaintiff are typical of the claims of the proposed Class  because Plaintiff’s claims are based on the same legal theories, and Plaintiff has no interests that  are antagonistic to the interests of the Class members.  38.  Adequacy. Plaintiff is an adequate representative of the Class and has retained  competent legal counsel experienced in class actions and complex litigation. Electronically Filed 08/12/2020 15:16 / / CV 20 935892 / Confirmation Nbr. 2049889 / CLJSZ 5  39.  Common Questions of Law and Fact. The questions of law and fact common to  the Class predominate over any questions affecting only individual Class members, particularly  because the focus of the litigation will be on the conduct of Defendant. The predominant questions of law and fact in this litigation include, but are not limited to: (a)  Whether Defendant had any scientific evidence to support the claims that  the treatment was clinically proven, was not experimental, that adverse side effects were  not possible and that the procedure had FDA approval; (b)  Whether Defendant’s conduct was necessary for the stem cell providers to  provide the services; (c)  Whether the stem cell providers engaged in fraud.  40.  Superiority. A class action is superior to other available methods for the fair and  efficient adjudication of this controversy, as the pursuit of hundreds of individual lawsuits would  not be economically feasible for individual Class members, and certification as a class action  will preserve judicial resources by allowing the common issues of the Class members to be  adjudicated in a single forum, avoiding the need for duplicative hearings and discovery in  individual actions that are based on an identical set of facts.  41.  This proposed class action does not present any unique management difficulties. A. Class Definition  MICHELLE OFFREDO )  CASE NO. 315 Sandstone Ridgeway ) Cleveland, OH 44017, ) 