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Comes now PlaintiIIs Kory Watkins and Open Carry Tarrant County, by and through
counsel, and Ior his cause oI action against DeIendant City oI Arlington, and avers the Iollowing:
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1. Pursuant to 42 U.S.C. 1983 and 1988, PlaintiIIs bring this civil rights action, seeking
injunctive relieI, declaratory relieI, and damages against DeIendant City oI Arlington,
Texas.
2. This action is premised on the United States Constitution and concerns the deprivation oI
PlaintiIIs' Iundamental right to Iree speech and expression.
3. DeIendant's actions have deprived and will continue to deprive PlaintiIIs oI their
Iundamental rights to Iree speech and expression as provided in the First and Fourteenth
Amendments to the United States Constitution.
4. Each and every act oI DeIendant alleged herein was committed under the color oI state
and municipal law and authority.

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5. Pursuant to 28 U.S.C. 1331 and 1343, this Court has jurisdiction over PlaintiIIs'
claims. Pursuant to 28 U.S.C. 2201-02 and 42 U.S.C. 1983-1988, this Court has
jurisdiction over PlaintiIIs' request Ior and declaratory relieI and other claims.
6. Pursuant to 28 U.S.C. 1391(b), venue is proper in the Northern District oI Texas
because all claims arise out oI this district and DeIendants reside in this district.
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7. PlaintiII Kory Watkins resides in MansIield, Texas.
8. PlaintiII Open Carry Tarrant County ("Open Carry") is an unincorporated association
operating in Tarrant County, Texas, and Ior which Kory Watkins serves as Coordinator,
and may be a proper party to suit by virtue oI FRCP 17(b)(3)(A).
9. DeIendant City oI Arlington is an incorporated political subdivision oI the State oI Texas
and can be served with summons upon City oI Arlington, Texas, Mayor Robert N. Cluck,
wherever he may be Iound, including his workplace, 101 W. Abram St.
Arlington, Texas 76004-0231, or his residence at 5820 Bay Club Dr., Arl., Texas 76013.
#17 .)+$(
10. PlaintiII Kory Watkins is the country coordinator Ior PlaintiII Open Carry Tarrant
County, an organization dedicated to the education oI Texans regarding gun rights.
11. Among the proper and legal activities oI this organization is the presentation oI speeches
on political topics, the organization oI rallies and other gatherings to hear these speeches,
and dissemination oI materials supporting gun rights.
12. One oI the common activities oI Open Carry are group "walks" in which participants
walk on sidewalks and providing pocket-sized copies oI the United States Constitution to
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those individuals who indicate that they would like one, including those who are
passengers oI cars that are stopped temporarily at a stop light.
13. Open Carry does not travel unbidden among stopped cars to ask Ior solicitations or
provide political material (such as the United States Constitution), but only approaches
vehicles in which a driver or passenger has requested a copy oI the Constitution.
14. No one has been hit, hurt, or damaged in any way during any Open Carry event.
15. PlaintiII has sought inIormation regarding accidents and political rallies in Arlington and
Iound literally no other accident or saIety issue associated with pedestrians involved in
such political or charitable organization participating in such events since at least as Iar
back as 1997. Aside Irom that event, no one has been hurt in recorded history during any
similar exercise by any type oI political group or organization, or any non-political event,
such as the many car washes, Iire-Iighting Iund-raising events, or "send my band member
on a Iield trip" Iund-raising eIIorts that are ongoing year-round in Arlington.
16. Two Open Carry participants were cited in late March Ior violating the Streets and
Sidewalks Chapter oI the City oI Arlington, when they provided United States
Constitutions to individuals who requested them Irom their vehicle. The vehicles were
stopped at a stop light, no one was hurt, and no one could colorably claim that any
dangerous activity was occurring or public saIety was threatened.
17. AIter the two Open Carry participants were cited, the charges were later dropped as the
Arlington City Council amended the 'Streets and Sidewalks Chapter oI the Code oI
Arlington, Section 15.02, making the ordinance more strict and raised the potential Iine to
$500 per occurrence, targeted the speciIic actions by Open Carry, and restricted the areas
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in which anyone could pass out copies oI the United States Constitution, as shown in the
diIIerences between the old and new versions oI the ordinance:
a. The previous language oI 15.02 stated:
"A person commits an oIIense iI he or she stands on or in any manner occupies a
shoulder, improved shoulder, sidewalk, median or public right-oI-way in the areas
set out in Section 15.03 to solicit or attempt to solicit a ride, employment or
business or charitable contributions Irom the occupants oI any vehicle, other than
a lawIully parked vehicle."

b. The new language oI the law states:
"A person commits an oIIense iI he or she stands on or in any manner occupies a
shoulder, improved shoulder, sidewalk, median or public right-oI-way in the areas
set out in Section 15.03 to solicit or attempt to solicit Ior purpose oI an exchange
with the occupants oI a vehicle, sell or oIIer Ior sale any merchandise or service
directly to the occupants oI a vehicle, or distributes or attempts to distribute any
object directly to the occupants oI a vehicle, other than a lawIully parked vehicle."
!". (Underlining added.)

18. The amended law's text is Ireely available on the City's website since passage, which
includes an exhaustive list oI prohibited streets, which eIIectively removes all streets with
signiIicant traIIic:
http://www.arlingtontx.gov/citysecretary/pdI/codeoIordinances/STREEChapter.pdI
19. In addition, police oIIicers threatened to jail event participants Ior these alleged
violations, Iurther chilling political speech by threatening jail Ior a misdemeanor oIIense.
20. Statements made by the Council City members at various points near the passage oI the
ordinance on May 13, 2014 indicate that this ordinance was deliberately targeted to
intended to preclude and make Open Carry events illegal, which occur on public
sidewalks and typically near streets.
21. At the same time that the Arlington City Council passed this ordinance, it amended
another law which restricted concealed handgun license holders at public meetings.
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22. No event precipitated this sudden interest in these restrictions other than the Open Carry
events and public demonstrations, irrespective oI the Iact that the Shriners and
IireIighters have been standing directly in the busiest streets with the blessing oI the City
Council Ior decades. The City has conducted no study to show that the actions oI Open
Carry supporters is dangerous or has caused dangerous circumstances.
23. The City oI Arlington argues that state law provides Ior discriminatory treatment Iavoring
municipal and state employees, but it is the City oI Arlington that determines that it will
allow municipal employees to actually stand in the street with moving traIIic, while
prohibiting Open Carry supporters Irom handing copies oI the Constitution Irom a
sidewalk to a stopped vehicle, thereby discriminating on the basis oI viewpoint.
24. PlaintiII Watkins was told that he would be arrested by a police oIIicer even under the
unamended law Ior handing out Constitutions as he prepared one to the passenger oI a car
who had requested one, while the car was stopped and without entering the street.
Violation oI the ordinance is merely a misdemeanor, not subject to punishment by jail.
25. Open Carry Tarrant County conducts multiple walks a week throughout Tarrant County,
particularly on weekends when they can interact with large numbers oI people and
exercise their First Amendment right to share the United States Constitution. However,
they have been told and reasonably Iear citation and arrest because they have been told
that they will be cited and arrested Ior these activities by police and city council
members. This has caused a chilling eIIect on members oI Open Carry's willingness to
participate as they had in the past, as no one wants to be harassed and threatened with
time in jail Ior doing nothing more than handing out the United States Constitution to
those who have stated that they wish to receive it.
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26. The City will suIIer no hardship by being enjoined Irom enIorcement oI the new law.
27. Though council members couch supportive language Ior this amended ordinance as
though it is about saIety, they had no such concerns Ior the decades that they have been
involved in public "service", until Open Carry became politically active, and though no
accident has occurred, or even near accidents or complaints oI near accidents, in
connection with their political speech and demonstrations.
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28. Prior Restraint Violation oI the First Amendment - Section 15.02 oI the Streets and
Sidewalks Chapter oI the Code oI the City oI Arlington on its Iace acts as an invalid prior
restraint on speech, and is discriminatory as construed and applied to the individual
speech oI Watkins and members oI Open Carry Tarrant County, as it concerns their use
oI oral communication, signs, and literature distribution on public property that is
historically the home oI Iree speech. As such, the policy is mere pretext to violate their
right to Ireedom oI speech under the First and Fourteenth Amendments to the United
States Constitution.
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WHEREFORE, PlaintiIIs respectIully prays Ior relieI in that this Court:
A. Assume jurisdiction over this action;
B. Enter a judgment and decree declaring that the Section 15.02 oI the Streets and
Sidewalks Chapter oI the Code oI the City oI Arlington, pertaining to the distribution oI
political materials Irom public property to other individuals on public property, is
unconstitutional on its Iace and as applied to PlaintiIIs' expression because it violates
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their right oI Ireedom to speech as guaranteed by the United States Constitution and
operation oI Iederal laws;
C. Enter a preliminary and permanent injunction enjoining deIendants, their agents,
oIIicials, servants, employees, and all persons in active concert or participation with
them, or any oI them, Irom enIorcing Section 15.02 oI the Streets and Sidewalks Chapter
oI the Code oI the City oI Arlington, so as to restrict constitutionally-protected speech oI
on open public areas.
D. Award PlaintiIIs an award oI actual and/or nominal damages in an amount deemed
appropriate by this Court;
E. Grant to PlaintiIIs an award Ior their costs Ior litigation, including reasonable
attorney's Iees and expenses, pursuant to 42 U.S.C. 1988; and
F. Grant such other and Iurther relieI as appears to this Court to be equitable and just.

RespectIully submitted,

Norred Law, PLLC


By:
Warren Norred, Texas Bar 24045094
wnorrednorredlaw.com
C. Chad Lampe, Texas Bar 24045042
chadnorredlaw.com
200 E. Abram St., Ste. 300;
Arlington, TX 76010
O 817-704-3984; F 817-524-6686
Attorneys Ior PlaintiIIs

Davis Miles McGuire Gardner, PLLC
Joshua Carden, Texas Bar 24050379
jcardendavismiles.com
545 E John Carpenter Frwy, Suite 300
Irving TX, 75062
Phone: (972) 674-3885
Fax: (972) 674-2935
Attorney Ior PlaintiIIs


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Case 4:l4-cv-0038l-O Document l Filed 05/28/l4 Page 8 of 8 PagelD 8
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
Plaintiff
Defendant
v.
Civil Action No.
CERTIFICATE OF INTERESTED PERSONS
(This form also satisfies Fed. R. Civ. P. 7.1)
Pursuant to Fed. R. Civ. P. 7.1 and LR 3.1(c), LR 3.2(e), LR 7.4, LR 81.1(a)(3)(D), and LR 81.2,
provides the following information:
For a nongovernmental corporate party, the name(s) of its parent corporation and any
publicly held corporation that owns 10% or more of its stock (if none, state "None"):
*Please separate names with a comma. Only text visible within box will print.
A complete list of all persons, associations of persons, firms, partnerships, corporations,
guarantors, insurers, affiliates, parent or subsidiary corporations, or other legal entities that are
financially interested in the outcome of the case:
*Please separate names with a comma. Only text visible within box will print.
Case 4:l4-cv-0038l-O Document l-l Filed 05/28/l4 Page l of 2 PagelD 9
Date:
Signature:
Print Name:
Telephone:
Address:
City, State, Zip:
Bar Number:
Fax:
E-Mail:
NOTE: To electronically file this document, you will find the event in our Case Management (CM/ECF) system, under Civil/Other
Documents/Certificate of Interested Persons
Case 4:l4-cv-0038l-O Document l-l Filed 05/28/l4 Page 2 of 2 PagelD l0
JS 44 (Rev. 12/12)
CIVIL COVER SHEET
The JS 44 civil cover sheet and the inIormation contained herein neither replace nor supplement the Iiling and service oI pleadings or other papers as required by law, except as
provided by local rules oI court. This Iorm, approved by the Judicial ConIerence oI the United States in September 1974, is required Ior the use oI the Clerk oI Court Ior the
purpose oI initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
(b) County oI Residence oI First Listed PlaintiII County oI Residence oI First Listed DeIendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
PlaintiII (U.S. Government Not a Party) Citizen oI This State 1 1 Incorporated or Principal Place 4 4
oI Business In This State
2 U.S. Government 4 Diversity Citizen oI Another State 2 2 Incorporated and Principal Place 5 5
DeIendant (Indicate Citizenship of Parties in Item III) oI Business In Another State
Citizen or Subject oI a 3 3 Foreign Nation 6 6
Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - oI Property 21 USC 881 423 Withdrawal 400 State Reapportionment
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 410 Antitrust
140 Negotiable Instrument Liability 367 Health Care/ 430 Banks and Banking
150 Recovery oI Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 450 Commerce
& EnIorcement oI Judgment Slander Personal Injury 820 Copyrights 460 Deportation
151 Medicare Act 330 Federal Employers` Product Liability 830 Patent 470 Racketeer InIluenced and
152 Recovery oI DeIaulted Liability 368 Asbestos Personal 840 Trademark Corrupt Organizations
Student Loans 340 Marine Injury Product 480 Consumer Credit
(Excludes Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY 490 Cable/Sat TV
153 Recovery oI Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395II) 850 Securities/Commodities/
oI Veteran`s BeneIits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) Exchange
160 Stockholders` Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 890 Other Statutory Actions
190 Other Contract Product Liability 380 Other Personal Relations 864 SSID Title XVI 891 Agricultural Acts
195 Contract Product Liability 360 Other Personal Property Damage 740 Railway Labor Act 865 RSI (405(g)) 893 Environmental Matters
196 Franchise Injury 385 Property Damage 751 Family and Medical 895 Freedom oI InIormation
362 Personal Injury - Product Liability Leave Act Act
Medical Malpractice 790 Other Labor Litigation 896 Arbitration
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 791 Employee Retirement FEDERAL TAX SUITS 899 Administrative Procedure
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: Income Security Act 870 Taxes (U.S. PlaintiII Act/Review or Appeal oI
220 Foreclosure 441 Voting 463 Alien Detainee or DeIendant) Agency Decision
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRSThird Party 950 Constitutionality oI
240 Torts to Land 443 Housing/ Sentence 26 USC 7609 State Statutes
245 Tort Product Liability Accommodations 530 General
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION
Employment Other: 462 Naturalization Application
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions oI
ConIinement
V. ORIGIN (Place an X in One Box Only)
1 Original
Proceeding
2 Removed Irom
State Court
3 Remanded Irom
Appellate Court
4 Reinstated or
Reopened
5 TransIerred Irom
Another District
(specify)
6 Multidistrict
Litigation
VI. CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are Iiling (Do not cite jurisdictional statutes unless diversity):

BrieI description oI cause:
VII. REQUESTED IN
COMPLAINT:
CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P.
DEMAND $ CHECK YES only iI demanded in complaint:
JURY DEMAND: Yes No
VIII. RELATED CASE(S)
IF ANY
(See instructions):
JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
Kory Watkins, and
Open Carry Tarrant County
Tarrant
Warren Norred
200 E. Abram, Suite 300
Arlington, TX 76010
City of Arlington
Tarrant County
First Amendment
Prior Restraint against First Amendment expression of free speech
10,000.00
05/15/2010 /Warren V. Norred/
Case 4:l4-cv-0038l-O Document l-2 Filed 05/28/l4 Page l of 2 PagelD ll
JS 44 Reverse (Rev. 12/12)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the inIormation contained herein neither replaces nor supplements the Iilings and service oI pleading or other papers as
required by law, except as provided by local rules oI court. This Iorm, approved by the Judicial ConIerence oI the United States in September 1974, is
required Ior the use oI the Clerk oI Court Ior the purpose oI initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk oI
Court Ior each civil complaint Iiled. The attorney Iiling a case should complete the Iorm as Iollows:
I.(a) Plaintiffs-Defendants. Enter names (last, Iirst, middle initial) oI plaintiII and deIendant. II the plaintiII or deIendant is a government agency, use
only the Iull name or standard abbreviations. II the plaintiII or deIendant is an oIIicial within a government agency, identiIy Iirst the agency and
then the oIIicial, giving both name and title.
(b) County of Residence. For each civil case Iiled, except U.S. plaintiII cases, enter the name oI the county where the Iirst listed plaintiII resides at the
time oI Iiling. In U.S. plaintiII cases, enter the name oI the county in which the Iirst listed deIendant resides at the time oI Iiling. (NOTE: In land
condemnation cases, the county oI residence oI the "deIendant" is the location oI the tract oI land involved.)
(c) Attorneys. Enter the Iirm name, address, telephone number, and attorney oI record. II there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis oI jurisdiction is set Iorth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one oI the boxes. II there is more than one basis oI jurisdiction, precedence is given in the order shown below.
United States plaintiII. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and oIIicers oI the United States are included here.
United States deIendant. (2) When the plaintiII is suing the United States, its oIIicers or agencies, place an "X" in this box.
Federal question. (3) This reIers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution oI the United States, an amendment
to the Constitution, an act oI Congress or a treaty oI the United States. In cases where the U.S. is a party, the U.S. plaintiII or deIendant code takes
precedence, and box 1 or 2 should be marked.
Diversity oI citizenship. (4) This reIers to suits under 28 U.S.C. 1332, where parties are citizens oI diIIerent states. When Box 4 is checked, the
citizenship oI the diIIerent parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section oI the JS 44 is to be completed iI diversity oI citizenship was indicated above. Mark this
section Ior each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. II the nature oI suit cannot be determined, be sure the cause oI action, in Section VI below, is
suIIicient to enable the deputy clerk or the statistical clerk(s) in the Administrative OIIice to determine the nature oI suit. II the cause Iits more than
one nature oI suit, select the most deIinitive.
V. Origin. Place an "X" in one oI the six boxes.
Original Proceedings. (1) Cases which originate in the United States district courts.
Removed Irom State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition Ior removal is granted, check this box.
Remanded Irom Appellate Court. (3) Check this box Ior cases remanded to the district court Ior Iurther action. Use the date oI remand as the Iiling
date.
Reinstated or Reopened. (4) Check this box Ior cases reinstated or reopened in the district court. Use the reopening date as the Iiling date.
TransIerred Irom Another District. (5) For cases transIerred under Title 28 U.S.C. Section 1404(a). Do not use this Ior within district transIers or
multidistrict litigation transIers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transIerred into the district under authority oI Title 28 U.S.C. Section 1407.
When this box is checked, do not check (5) above.
VI. Cause of Action. Report the civil statute directly related to the cause oI action and give a brieI description oI the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 BrieI Description: Unauthorized reception oI cable service
VII. Requested in Complaint. Class Action. Place an "X" in this box iI you are Iiling a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section oI the JS 44 is used to reIerence related pending cases, iI any. II there are related pending cases, insert the docket
numbers and the corresponding judge names Ior such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Case 4:l4-cv-0038l-O Document l-2 Filed 05/28/l4 Page 2 of 2 PagelD l2