IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION

Similar documents
Case 3:04-cv RLA Document 1-1 Filed 09/30/2004 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT DISTRICT OF PUERTO RICO

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF FLORIDA PENSACOLA DIVISION NATURE OF THE ACTION

)

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA STATESVILLE DIVISION ) ) ) ) ) ) ) ) NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA FORT PIERCE DIVISION

Case 2:05-cv JES-SPC Document 47 Filed 04/24/2006 Page 1 of 11

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

Case 4:07-cv JLH Document 1 Filed 06/29/2007 ( Page 1 of 6

Case 2:09-cv BSJ-RLE Document 67 Filed 10/28/11 Page 1 of 6

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 3:04-cv JSW Document 168 Filed 10/20/2005 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

Case 3:11-cv CRW-TJS Document 1 Filed 04/06/11 Page 1 of 7

NATURE OF THE ACTION. This is an action under Title VII of the Civil Rights Act of 1964, as amended by the

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NORTH DAKOTA ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT

Case 1:18-cv RDB Document 1 Filed 07/30/18 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND BALTIMORE DIVISION

UNITED STATES DISTRICT COURT DISTRICT OF HAWAII CV

IN THE UNITED STATES DISTRICT COURT ~,~,~,,.c~...,... ~~"~ ~ " FOR THE WESTERN DISTRICT OF NORTH CAROLI~ SEP -9 ;i ~ [~: 0~ CBA~OTTE OIVlSlON

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION ) ) ) NATURE OF THE ACTION

Case 1:11-cv LG-JCG Document 2 Filed 11/17/11 Page 1 of 7

-CIVIL RIGHTS EMPLOYMENT

ORIGINAL COMPLAINT OF THE UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION TO THE HONORABLE UNITED STATES DISTRICT COURT:

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NORTH DAKOTA ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

Case 1:06-cv LTB-CBS Document 1 Filed 09/29/2006 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN THE UNITED STATES DISTRICT COURT. FOR THE NORTHERN DISTRICT OF ILLINOIS eu,:".' IJ~:'LD~~?~:~~URT EASTERN DIVISION ) ) ) ) ) ) ) ) ) )

Case 3:06-cv JAP-TJB Document 1 Filed 03/27/2006 Page 1 of 5 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION ORIGINAL COMPLAINT

Case 4:16-cv Document 1 Filed in TXSD on 09/29/16 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA ) ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA NATURE OF THE ACTION

Case 4:17-cv Document 1 Filed in TXSD on 07/20/17 Page 1 of 8

Case: 1:10-cv Document #: 1-2 Filed: 06/03/09 Page 1 of 5 PageID #:2

This is an action under the Genetic Information Nondiscrimination Act of 2008

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF IOWA DAVENPORT DIVISION. Nature Of The Action

) I ClV a S - BUN. 18 This is an action under Title VII ofthe Civil Rights Act of 1964 and Title I of the Civil

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA. Plaintiff, Defendant. AMENDED COMPLAINT AND JURY TRIAL DEMAND NATURE OF ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA DUBLIN DIVISION

UNITED STATES DISTRICT COURT DISTRICT OF HAWAII ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

Case 4:04-cv LLP Document 1 Filed 12/28/2004 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA.

Case 8:04-cv SCB-TBM Document 32 Filed 10/07/2005 Page 1 of 6

Case 6:10-cv TC Document 1 Filed 09/24/10 Page 1 of 7 Page ID#: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ) ) ) Plaintiff, ) ) ) ) ) ) ) ) NATURE OF THE ACTION

Case 4:05-cv CLS Document 1 Filed 05/26/2005 Page 1 of 6

5:06cv1684 JUDGE HICKS MAG. JUDGE HORNSBY

FILED. , #, Case 5:05-cv WRF Document 29 Filed 06/06/2006Page 1 of 9 JUN COMMISSION, Plaintiff, ALICIA MANSEL, Civil Action No.

UNITED STATES DISTRICT COURT DISTRICT OF HA WAIl. Case No.: NATURE OF THE ACTION AND JURISDICTION

Case 7:17-cv KMK Document 1 Filed 07/06/17 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

Case 2:14-cv MPK Document 1 Filed 04/22/14 Page 1 of 6

IN THE UNITED STATES DISTRICT COUR~A I FOR THE NORTHERN DISTRICT OF ILLINO~ STRA~ E EASTERN DIVISION 0~U ) ) tl0v 1 0 7_604 ) ) NATURE OF THE ACTION


)

,,%, FOR THESOUTHERN DISTRICT OF FL,~ 8 0 -~- FT. LA UDERDA]~ I~ VIilO IN THE UNITED STATES DISTRICT COURT

Case 1:17-cv Document 1 Filed 09/27/17 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

Case 1:13-cv Document 1 Filed 06/28/13 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Case 9:06-cv RHC Document 1 Filed 02/28/2006 Page 1 of 7

Case 6:17-cv JA-GJK Document 1 Filed 12/14/17 Page 1 of 7 PageID 1 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION

Case 1:14-cv KMT Document 1 Filed 09/24/14 USDC Colorado Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN TI-[E UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO. ..-ECHOSTAR COMMUNICATIONS CORPORATION n/k/a DISH, LTD.,

Case 1:15-cv KMW Document 1 Entered on FLSD Docket 10/13/2015 Page 1 of 9

COMPLAINT (Jury Trial Demand)

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION. Plaintitl, Defendants. COMPLAINT AND JURY TRIAL DEMAND

Case: 1:06-cv JRA Doc #: 28 Filed: 05/08/09 1 of 9. PageID #: 220

Case 3:16-cv L Document 1 Filed 11/01/16 Page 1 of 9 PageID 1

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION SETTLEMENT AGREEMENT

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

2:04-cv HAB-DGB # 1 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS URBANA DIVISION ) ) ) ) ) ) ) ) ) )

FIRST AMENDED COMPLAINT

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS

PLAINTIFF AVA SMITH- THOMPSON S COMPLAINT AGAINST DEFENDANT SARA LEE CORPORATION

Case 5:02-cv WTH Document 12 Filed 10/23/2002 Page 1 of 14

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ROME DIVISION

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAII

Case 2:16-cv RSL Document 1 Filed 08/05/16 Page 1 of 13

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ROME DIVISION

CASE NO. 5:00-CV COMPLAINT IN INTERVENTION ON BEHALF OF JACKQULINE STOKES

Case 1:17-cv RNS Document 1 Entered on FLSD Docket 01/31/2017 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.

Case 3:16-cv MO Document 1 Filed 09/29/16 Page 1 of 13

Case 2:16-cv GMN-VCF Document 1 Filed 04/26/16 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

FILED: RICHMOND COUNTY CLERK 01/16/ :56 AM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2017

Case 1:17-cv KMW Document 1 Entered on FLSD Docket 07/19/2017 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.

Case 1:17-cv YK Document 1-1 Filed 02/14/17 Page 1 of 2 CIVIL COVER SHEET

Case 1:16-cv JAL Document 1 Entered on FLSD Docket 11/09/2016 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.

Case 2:03-cv BBD-sta Document 14 Filed 08/05/2004 Page 1 of 7

Case 1:17-cv UU Document 1 Entered on FLSD Docket 03/22/2017 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

Case: 1:17-cv SA-DAS Doc #: 1 Filed: 05/19/17 1 of 5 PageID #: 1

Case 4:16-cv Document 1 Filed in TXSD on 10/24/16 Page 1 of 9

2:18-cv PDB-EAS Doc # 1 Filed 03/06/18 Pg 1 of 16 Pg ID 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION CASE NO.

Case 4:16-cv Document 1 Filed in TXSD on 10/24/16 Page 1 of 9

Case 1:16-cv Document 1 Filed 11/21/16 Page 1 of 10 PageID #: 1 UNITED STATES DISTRICT COURT STATE OF RHODE ISLAND COMPLAINT INTRODUCTION

Case: 1:13-cv Document #: 1 Filed: 07/25/13 Page 1 of 7 PageID #:1

1/29/2019 8:49 AM 19CV04626

Transcription:

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION --~j~ U.S. EQUAL EMPLOYMENT OPPORTUNITY) COMMISSION, ) Plaintiff, CIVIL ACTION NO. PATTERSON COMPANIES INC. f/k/a Patterson Dental Company d/b/a Patterson Dental Supply, Inc. Defendant. COMPLAINT JURY TRIAL DEMANDED INJUNCTIVE RELIEF SOUGHT NATURE OF THE ACTION This is an action under Title VII of the Civil Rights Act of 1964, as amended ("Title VII"), and Title I of the Civil Rights Act of 1991 to correct unlawful employment practices on the basis of sex and retaliation, and to provide appropriate relief to Terri Wallace who was adversely affected by such practices. As stated with greater particularity in paragraph 7, the Commission alleges that Ms. Wallace was subjected to sexual harassment by a coworker and employee of the Defendant corporation. The Commission further alleges that Defendant subsequently retaliated against Ms. Wallace for complaining of the unlawful sexual harassment by altering the terms and conditions of her employment thus leading to her constructive discharge. JURISDICTION AND VENUE Jurisdiction of this Court is invoked pursuant to 28 U.S.C. 451, 1331, 1337, 1343 and 1345. This action is authorized and instituted pursuant to Section 706(f)(1) and (3) of

Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e-5(f)(1) and (3) ("Title VII"), and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. 1981A. 2. The employment practices alleged to be unlawful were committed within the jurisdiction of the Untied States District Court for the Middle District of Florida, Orlando Division. PARTIES 3. Plaintiff, the Equal Employment Opportunity Commission (the "Commission"), is the agency of the United States of America charged with the administration, interpretation and enforcement of Title VII, and is expressly authorized to bring this action by Section 706(f)(1) and (3) of Title VII, 42 U.S.C. 2000e-5(f)(1) and (3). 4. At all relevant times, Patterson Companies, Inc. f/k/a Patterson Dental Company d/b/a Patterson Dental Supply Inc. Minnesota corporation, has continuously been doing business in the State of Florida and the City of Orlando, and has continuously had at least 15 employees. 5. At all relevant times Patterson Companies, Inc. f/k/a Patterson Dental Company d/b/a Patterson Dental Supply, Inc. has continuously been an employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.C. 2000e(b), (g) and (h). STATEMENT OF CLAIMS 6. More than thirty days prior to the institution of this lawsuit, Terri Wallace filed a charge with the Commission alleging violations of Title VII by the Defendant. All conditions precedent to the institution of this lawsuit have been fulfilled. 7. Since at least August 2001, Defendant Employer engaged in unlawful employment practices at its Orlando, Florida location in violation of Section 703(a) and Section 704(a) of Title

VII, 42 U.S.C. 2000e-2(a) and 2000e-3(a). a. Terri Wallace was subjected to sexual harassment by her co-worker in the form of unwelcome verbal conduct and writings of a sexual nature which was sufficiently severe and pervasive to constitute an intimidating, hostile and offensive work environment. b. Defendant failed to take prompt corrective action when it knew or should have known of the sexual harassment. c. Defendant retaliated against Terri Wallace for complaining of the unlawful sexual harassment when it adversely affected the terms and conditions of her employment by placing her on a "performance plan" d. Defendant s conduct rendered the terms and conditions of Teri Wallace s employment so intolerable that she was compelled to end her employment with Defendant. 8. The effect of the conduct complained of in paragraph 7 above has been to deprive Teri Wallace of equal employment opportunities and otherwise adversely affect her status as an employee because of her sex and/or in retaliation for her opposition to unlawful employment practices. 9. The unlawful employment practices complained of in paragraph 7 above were intentional. 10. The unlawful employment practices complained of in paragraph 7 above were done with malice or with reckless indifference to the federally protected rights of Teri Wallace.

PRAYER FOR RELIEF Wherefore, the Commission respectfully requests that this Court: A. Grant a permanent injunction enjoining Defendant, its officers, successors, assigns, and all persons in active concert or participation with Defendant, from engaging in sexual harassment, retaliatory conduct and/or any other employment practice which discriminates on the basis of sex and/or opposition to an unlawful employment practice. B. Order Defendant, to institute and carry out policies, practices, and programs which provide equal employment opportunities for all employees regardless of sex, and which eradicates the effects of its past unlawful employment practices. C. Order Defendant to make whole Teri Wallace by providing appropriate back pay with prejudgment interest, in amounts to be determined at trial, and other affirmative relief necessary to eradicate the effects of its unlawful employment practices, including but not limited to reinstatement or front pay. D. Order Defendant to make whole Teri Wallace by providing compensation for past and future pecuniary losses resulting from the unlawful employment practices described in paragraph 7 above, including out of pocket losses in amounts to be determined at trial. E. Order Defendant to make whole Teri Wallace by providing compensation for past and future nonpecuniary losses resulting from the unlawful practices complained of in paragraph 7 above, including emotional pain, suffering, inconvenience, humiliation, and loss of enjoyment of life, in amounts to be determined at trial. F. Order Defendant to pay Teri Wallace punitive damages for its malicious and reckless conduct described in paragraph 7 above, in amounts to be determined at trial.

Grant such further relief as the Court deems necessary and proper in the public interest. H. Award the Commission its costs of this action. JURY TRIAL DEMAND The Commission requests a jury trial on all questions of fact raised by its complaint. Respectfully Submitted, ERIC S. DRIEBAND General Counsel JAMES L. LEE Deputy General Counsel GWENDOLYN YOUNG REAMS Associate General Counsel DELNER FRANKLIN-THOMAS Regional Attorney MICHAEL J. FARRELL Supervisory Trial Attorney T~al Nttomey t~, Florida Bar. No. 532231 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION MIAMI DISTRICT OFFICE One Biscayne Tower 2 South Biscayne Boulevard Suite 2700 Miami, Florida 33131 Phone: (305) 530-6012 Fax: (305) 536-4494

CIVIL COVER SHEET The JS-44 civil cover ~heet end the information ontzinnd herein neither replzce nor =u~olement the filing end zervlce of ple=die,~ or other pzper~ ~ required by law, except a= provided by IDea njles of coort~ This form. spprovki by the Judk:ial Conference of the Ur~ited Seat. in ~teml~ 1974. b required for the use of the Oe~ of Court fo~ the purpo=e of nitjeting the civil docke d ~ecl (SEE INSTRUCTtON$ON THE REVERSE OF THE FORM.) I (a) PLAINTIFFS United States Equal ~np]nsanent Oppo~tunit Ccm.ission DEFENDANTS Patterson Ccmpanies, Inc., flk/a Patterson Dental Company, d/b/a Patterson Dental Supply, Inc. (b) coum v OF RESIDENCE OF FIRST LISTED PLAINTIFF (EXCEPT IN U.S. PLAINTIFF CASES) COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT O~"-d~e (IN U.S. PI.AiNTIFF CASES ONLY) NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LANO INVOLVED (C) ATTORNEYS (FIRM NAME. ADDRESS, AND TELEPHONE NUMBER) Jennifer Bz own, Esq. Tel#: (305)530-6012 EEOC, One Biscayne Tc~er, Suite 2700 2 S. Biscayne Blvd., Miami, FL 33131 ATTORNEYS (IF KNOV~N) II. BASIS OF JURISDICTION ~ 1 U.S. Government PlalnUff U.S. Government Defendant I-I 4 Federal Oueetlon (U.S. Government No( a Patty) (Indicate Cit~zenship el parties in Item III) IlL CITIZENSHIP OF PRINCIPAL PARTIES PTF OFF Citlze~ of Thla State [] 1 ~l 1 Ctttze~ of Another State [] 20 2 CIUzen m Subject of a n3 [33 ~n Co..W PTF DEF Ircorporated or Principal Place O 40 4 of Business In This State IncorpOrated and Principal Peace [3 S [3 of Business In Another State Foreign Nation VI 6 I-I 6 IV..CAUSE OF ACTION ~:,~,.u=ow~,,,~,~=o,~,,.=,~.,~,.,~,,o,~,~,~,~.~=,,~,.~=. Tlds.~ m ~ti~ ~ Titl~ ~,~~,~.~~ ~I of ~ Civ~ ~ts ~t of 1964, ~ ~, ~ Tit~ I of ~ ~V~ ~ ~t of 1991 ~ ~t ~ ~~t ~ti~ ~ ~ ~ of ~x ~ ~ta~ti~, ~ to ~e ~te ~ef to ~ W~ ~ ~ ~ely ~f~t~ ~ ~ p~ti~, " V. NATURE OF SUrf (P~CE AN x IN ONE BOX ONLD CONTRkCT [] 110 ktsut~n ~ []120 uwt~ [3 130 Mal~/ z O 140 N~g~ab~ V~.rume~ ~ 152 ~~. TORTS FORFEITURE/FENALTf BANKRUPTCY P~RSONAL INJURY PERSONAL INJURT 0 310 Nq~e 0 422 0 362 " O 31 $ Akpcw~ Pmducl t.~bmy 042~ D 320 ~ ~ ~ 03~5 P~x~ INure- ~ ~ LABOR []S30 mop~m~ RIGHTS socu~ SZCURmr 0400 0 410 0 4~ O4~ 0470 ~~ 0 810 A~L PR0~ []210 Lan4~ [] 220 Fo~K*~ 0 230 men Lea.~ & Ejmctrnent [3 240 T~.~ ~o Lmra 0 245 To~ Pro~ ~ L~twi~y O 290 AI O(her ~ Pro~oedy 0 443 0440 ~VIL RIGHT~ I~ISONER PETmON$ 0 SmS 0 @63 0@64 s~o Tee X~ RDEFIAL TAX SUITS [] 871 ~RS-- n~ P~ ~ 891 0 8~ 0 8~ 0895 VI. ORIGIN (PLACE AN x IN ONE BOX ONLY) Transferred from AppeaJ to Distdct [] 7 Judge from ]~1 Original O 2 Removed from [] 3 Remanded from I-I 4 Reinstated o [3 5 another ~strid [] 6 MultJdistdct Magislrale Proceedi~j State Court Appellate Couri Reopened (specigf) UU9atio~ Judgment VII. REQUESTED IN CHECK IF THIS is A CLASS ACTION DEMAND $ "Check YES only if demanded in complajnt: COMPLAINT: [] UNDER V.R.C.P. 23 JURY DEMAND: ~ YES [] NO VIII. RELATED CASE(S) (See in=r=ctions>: IF ANY ~UO~E DOCKET NUMBER UNITED STATE.DISTRICT COURT