A fourth robocall fraud lawsuit has been filed against Family First Life’s parent company, Integrity Marketing Group.

Plaintiff Aaron Rapp filed suit in Indiana back in June.

As per Rapp’s filed Complaint, IMG (dba Family First Life) violated the Telephone Consumer Protection Act and National Do Not Call provision of the Code of Federal Regulations.

Rapp claims his cell phone number has “been registered on the National Do Not Call Registry for almost twenty years”.

Despite this however, Family First Life “made numerous unauthorized telephone calls … for the purpose of soliciting business”.

Family First Life contacted Rapp multiple times in January 2023. Text messages sent to Rapp’s cell urged him to register for a “Million Dollar Agency Workshop”.

The individuals involved in conducting the Recruitment Session were identified as Ryan Montalto, Managing Partner of Integrity Marketing Group, and Donnie Tuttle.

Ryan Montalto is a former Integrity Marketing Group executive employee.

Montalto and three other defendants were sued by Integrity Marketing Group back in March. The case entered into arbitration as of July 2023.

Donnie Tuttle is also from Florida. I couldn’t find anything directly linking him to Family First Life, so it appears he actively hides any involvement with the company.

Family First Life purportedly sent out the marketing SMS they sent to Rapp to an additional one hundred and eighty individuals.

On one call, Rapp attempted to ascertain how Family First Life obtained his number.

Plaintiff had a conversation with an individual exhibiting limited proficiency in English. Plaintiff asked where the individual was calling from, to which the individual responded Connecticut.

Furthermore, Plaintiff asked how the individual obtained his contact information; however, the individual abruptly ended the call without answering his question.

The last call Rapp received was on January 25th from Sue Stephens.

At 6:35 p.m., Plaintiff initiated a return call to the individual, who identified herself as Ryan Montalto’s recruiter.

Plaintiff questioned where their office was located, to which the individual responded Destin, Florida. Additionally, Plaintiff requested Ryan Montalto’s phone number; however, the recruiter declined his request.

Rapp maintains he never gave Family First Life his contact details.

The next day, Rapp attended the Family First Life marketing event and confronted Montalto personally.

Ryan Montalto openly acknowledged that Defendant had hired a third-party company to oversee the recruitment process.

Rapp is seeking an injunction against Family First Life, as well as

statutory damages for himself and all members of the Class (defined below) per violation, together with court costs, reasonable attorneys’ fees, and treble damages (for knowing and/or willful violations).

On July 31st Integrity Marketing Group requested an extension of time to file an answer to Rapp’s class-action complaint. A preliminary trial conference has been scheduled for August 30th.

Of the four recent robocall fraud lawsuits filed against Integrity Marketing Group and Family First Life, two have been settled (case 1 and case 2).

The third case, filed by Plaintiff Mark Dobronski in Michigan last year, is still playing out.


Update 14th September 2023 – The August 30th preliminary trial conference was vacated pending the outcome of Integrity Marketing Group’s filed Motion to Dismiss.

Then on September 13th, Plaintiff Rapp filed an Amended Complaint. I believe this resets previous filings.