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Case 1:17-cv-02492-JHR-AMD Document 1 Filed 04/11/17 Page 1 of 11 PageID: 1Case 1:17-cv-02492-JHR-AMD Document 1 Filed 04/11/17 Page 1 of 11 Page|_D: 1

HOLTZMAN8: MCCLAIN, FCA Professional Corporation524 Maple Avenue, Suite 200Linwood, NJ 08221(609) 601-0900 «

Stephen D. Holtzman, Esquire (SDH 9921)Jeffrey S. McClain, Esquire (JSM 0966)Attorneys for PlaintiffGJJM ENTERPRISES,LLC d/b/a Stiletto

G1IM ENTERPRISES,‘LLC, d/b/a Stiletto, UNITED STATESDISTRICTCOURTI85 8. SouthCarolinaAve. District of New JerseyAtianticCity, NJ 08401,

Plaintiff, Case No.

V. Civil Action

CITY OF ATLANTIC CITY,1301 BacharachBlvd.AtlanticCity, NJ 08401, .

VERIFIED COMPLAINT FORCITY OF ATLANTIC CITYPOLICE DECLARATORY,INJUNCTIVE,DEPARTMENT, AND MONETARYRELIEF2715 AtlanticAve.AtlanticCity, NJ 08401,

HENRY WHITE,Chiefl AtlanticCity PoliceDepartment, In His Official CapacityOnly,272 5 AtlanticAve.Atlantic City, NJ 0840},

Defendants.

Now comes Plaintiff GJJM Enterprises, LLC (“GJJM”), by and through counsel, who

complains against Defendants City of Atlantic City, New Jersey, City of Atlantic City Police

Department, and Horny White, in his official capacity as Chief of the Atlantic City Police

Department, as follows:

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PRELIMINARYSTATEMENT

1. This is an action under the Constitution and laws of the United States asserting

thatN.J.S.A. 2C:33—27(a)(2),a New Jersey statute thatprohibits restaurants fiom advertising that

patrons are permitted to bring and consume their own beer and wine on premises, violates the

First Amendment. On its face, the statute bans truthful, non-misleading advertising about the

lawful consumption of “BYOB” beverages at restaurants and cafes and therefore acts as a prior

restraint on constitutionally-protected commercial speech. In this Complaint, GEJM seeks

declaratory and injunctivereliefprohibitingthe enforcement of the statute by theCity of Atlantic

City and its police department, as well as monetary relief to compensate GJJM for the loss of its

protected free speech rights.

JURISDICTION

2. This is a lawsuit authorizedby law to redress deprivations, under coior of state

law, of rights, privileges and immunities secured by the First and Fourteenth Amendments of the

United States Constitution. Jurisdiction is conferred on this Court by 28 U.S.C. § 1331; 28

U.S.C. § 1343; 28 U.S.C. § § 2201 and 2202; and by 42 U.S.C. § .1983.3. Plaintiff also states causes of action under the Constitution and laws of the State

iiiiiiiiiiiiiiiiiiiiiiiiiiiiiiii

2

this Court has original jurisdiction, that they are a part of the same case or controversy under

Article III of the United States Constitution. Accordingly, this Court has supplemental

jurisdictionof these claims under 28 Use. § 1367.

4. ‘ Venue is appropriate in the District of New Jersey because the acts described in

thisComplaint have all occurred withinthe state ofNew Jersey.


PARTIES

5. Plaintiff G3JM Enterprises, LLC d/b/a Stiletto owns and operates a nightclub,

Stiletto, located at 185 S. South CaroiinaAve. in Atlantic City, New Jersey. Stilettopresents live

A

erotic dance performances and other forms of live expressive entertainment geared towards an

adult audience. Stiletto is open to the general adult public and serves non-alcoholic liquid

refreshments to its patrons, althoughStiletto does not maintain an alcoholicbeverage license and

does not sell alcoholic drinks. Stiletto customers are permitted to bring and consume their own

beer and wine on the premises consistent with New Jersey law. GJJM maintains a valid 9

mercantile license for thisestablishment issued by the City of AtlanticCity.

6. Defendant City of Atlantic City,New Jersey is a municipal corporation located in

and organized under the laws of the State of New Jersey. The actions taken by the City and its

officials thatare described in this Complaint have been at all times under color of state law.

7. DefendantAtlanticCity Police Department is the official law enforcement agency

for the City of Atlantic City. Organized under Chapter 52 of the Atlantic City Code of

Ordinances, the Police Department retains the authority to investigate, arrest, and prosecute

individuals who violate New Jersey state law. The actions taken by the Police Department and~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

8. Defendant Henry White is the Chief of the Atlantic City Police Department and

oversees the policies and procedures that govern the Police Department and its investigations.

The actions taken by the ChiefWhite that are described in this Complaint have been at all times

under coior of state law. He is sued in his official capacityonly.


STATEMENTOF THE CASE

9. Stiletto is one of Atlantic City’s premier nightlife destinations. Located adjacent

to the Atlantic City boardwalk, the club features nonalcoholic beverages, upscale live

entertainment, and frequently hosts tourists, convention groups, and bachelor parties. Stiletto

draws the vast majority of its customer base from AtlanticCity resorts and hotels and is open to

thegeneral adult public.

l0. As a service to its customers, Stiletto permits its clientele to bring their own

outside beer and wine to consume on the premises, but does not allow customers to bring in or

consume liquor or mixed drinks. Stiletto does, however, sell and serve non-alcoholic liquid

refreshments to its customers. Stiletto does not maintain a state-issued license to serve alcoholic

beverages.

ll. Section 2C:33~27 of theNew Jersey Code governs the consumption of alcohol at

public places that serve liquid refreshment, but that, like Stiletto, do not have a license to sell

alcoholic beverages. Under the statute, patrons may bring their own beer and wine to the

restaurant, but may not bring outside liquor. See N.J.S.A. 2C:33-2”/(a)(l). The restaurant may

not, however, advertise «- either inside or outside the establishment -~ thatpatrons are perrnitted to

..............................

places serving liquid refreshments are prohibited from notifying customers that their

establislunents are “BYOB,” even though it is fully lawful for patrons to bring and consume their

own alcoholicbeverages on thepremises. Id.

12. Violations of the advertising ban are treated as criminal offenses. See N.J.S.A.

2C:33~27(c). Individuals who advertise that customers may “BYOB” to their restaurants face

prosecution as disorderly persons. Id. In addition to the criminal penalties for that offense,


courts may also prohibit individnais who violate the advertising ban from permitting the

consumption of “BYOB”beverages at theirbusinesses. Id.

13. Because violations of N.J.S.A. 2C:33~27 involve businesses without an alcohoiic

beverage license and are treated as crimes, they are investigated and prosecuted by local law

enforcement agencies ratherthan theNew Jersey Division ofAlcoholicBeverage Control. Thus,

violations of N.}.S.A. 2C:33—27 in Atlantic City fall to the Atlantic City Police Department to

detect and pursue.

l4. Stiletto does not presently advertise the opportunity to bring outside beer and

wine to its customers for fear of prosecution under N.5.S.A. 2C:33-27(c). As such, Stiletto has

censored its expression as a direct result of the advertising ban’s chillingeffect.

15. Absent the ban, Stiletto would provide truthful, nomnisleading advertising to its

customer base by using the term “BYOB” on its Website, print advertising materials (including

print ads in magazines and newspapers), signage, and customer literature, includingmenus and

price lists. Because it is both lawful and permissible to consume “BYOB” beverages at Stiletto,

this information would enable customers to make more informed decisions about their dining

and entertainment options.««««««««««««««««««««««««««««««««««««««««««««««««««««««««««««««««

Amendment to the United States Constitution and related provisions of the New Jersey

Constitution because it prohibits truthful and nonmisieading advertising about a lawful business

activity. The Court should accordinglyenjoin theCity of Atlantic City and its‘Police Chief and

Department from enforcing the “BYOB” advertising ban.


STATEMENTOF CLAIMSCOUNT ONE:

Violation of First AmendmentRightsUnder 42 U.S.C. § 1983

E7. Each of the foregoing paragraphs is incorporated by reference as if repeated here.

18. Plaintiff GJJ retains a protected First Amendment right to distribute truthfiil,

nonmisleacling commercial speech and advertising about its products, services, and business

model. This includes the right to label itself as a “BYOB” establishment and to provide

informationto customers about theoption ofbringing their‘own beer and wine to consume on the

premises.

19. N.J.S.A. 2C:33-27 imposes a content—hased ban on advertising by restaurants that

is presumptively unconstitutionaland cannot survive strict scrutiny. The City lacks a compelling

governmental interest in prohibiting speech about “BYOB” while permitting other commercial

speech related to the sale and consumption of alcoholicbeverages.

20. By and through the potential enforcement of N.J.S.A. 2C:33~27, the City of

Atlantic City and its police force have created a chilling effect on GJJ'M’s constitutionally

protected right to commercial speech...................................................................................

the distribution of truthful, nonmisleading informationabout the option for GJJlVI’s customers to

bring alcohol for on-site consumption.

22. Even if the City did retain such an interest, enforcement of N.I.S.A. 2C:33-27

through criminal prosecution and the imposition of restrictions on alcohol consumption are not

the least restrictive means of accomplishingthe City’s goals, nor are these enforcement remedies

narrowlytailored to the City’s interests.


23. GJJM is therefore entitled to a declaration that the “BYOB” advertising ban

contained in N..¥.S.A. 2C:33-2”/(a)(2) is unconstitutional, to preliminary and permanent

injunctive relief enjoining the City from enforcing N.J.S.A. 2C:33-2’7(a)(2), and monetary

damages in an amount to be determined at trial to compensate GJJM for the loss of its right to

present truthful commercial speech to the consenting adult public.

COUNT TWO:Violations of New Jersey Constitution

24. Each of the foregoing paragraphs is incorporated by reference as if repeated here.

25. GillM pleads each of the foregoing federal constitutional claims in the alternative

as state constitutional claims under the New Jersey Constitution. More specifically, GJJM

pleads a violation of its right to free expression under Article 1, Section 6 of the New Jersey

Constitution.

WHEREFORE, Plaintiff GJJM Enterprises, LLC seeks the following relief againstDefendants City of Atlantic City, New Jersey; Atlantic City Police Department; and Henry

White, Chiefof theAtlantic City Police Department:

1. A declaration that the “BYOB” advertising ban contained in N.J.S.A. 2C:33—

...................................i..i.i...i..2r7.ga)(,2.9W101ateg.r..ghe...1a;1=gti.iAmanamem..mtr..thermnnea...s1;ates,t,constjtgution...and.tA1:tic1e.i.1.,.._scation,anc....-.....i....,...t,t,i,................._,.........,.t.__,..t§of theNew Jersey Constitution;

2. Preliminary and permanent injunctive relief, to be sought by separate motion,

enjoining Defendants City of Atlantic City, New iersey; Atlantic City Police Department; and

Chief I-lenry White fiorn enforcing the“BYOB” advertising ban contained in N.J.S.A. 2033-27;

3. Monetary damages in an amount to be determined at trial to compensate GJJM for

the chillingeffect N.J.S.A. A2C:33—27 has imposed on its First Amendmentrights;

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4. An award of P1aintiff’s reasonable attorney fees and costs pursuant to 42 U.S.C.

1988; and

5. Any such other relief in law or equity thatthis Court deems appropriate under the

circumstances.

Respectfully submitted,

/s/ Steghen D. HoItzn1an1SDH99211STEPHEN D. HOLTZMAN,ESQU§REHoltzman & McClain, PC524 Maple Ave, Suite 200Linwood, NE 0822}(609) 601 -0900

.

SHo}[email protected]

JENNZFER M. KENSLEY, ESQUIRE*Pro Hac Vice PendingKinsleyLaw Office90st Office Box 19478Cincinnati,Ohio 45219(513) [email protected]

DANEEL A. SILVER,ESQUIRE*Pro Hac Vice PendingSilver& SilverOne LibertySquare

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

(860) [email protected]

Counsel for PlaintiffGJEM Enterprises, LLC

Case 1:17-cv-02492-JHR-AMD Document 1 Filed 04/11/17 Page 9 of 11 PageID: 9Case 1:17-cv-02492-JHR-AMD Document 1 Filed 04/11/17 Page 9 of 11 Page|D: 9VERIFICATION

I,PhiliipGrififo, hereby declare as foliows:

1. Pursuant £0 a managementagreementbetweena corporationowned by me and GJJM Enterprises, LLC, thePiaintifi‘in this lawsuit, I serve as themanager ofStiletto.

2. i have personal ktiowledgeof the factsalleged in the foregoingCompiaint and believe,under penalty efper}u1y, each aiieged fastto be true and accurate to thebestofmy knowledgeand belief.

Executed this day ofApril,2017;

STATE01; NEW JERSEY

CO'LIN'i“{0:4‘ OCj_1’;gr‘\

Sworn to and subscribedbeforeme in my presence on the ‘Tm day of

ABIGAILE. MURPHYNOTARYPUBUCOF NEW JERSEYMY CC*MMlS8¥ONEXPIRES DEC.30. 2021

Notary Public

Case 1:17-cv-02492-JHR-AMD Document 1 Filed 04/11/17 Page 10 of 11 PageID: 10‘S44 “‘°V'°"1T’3ase 1:17—cv—02492—JHR—ANlOI\EIdciIEi@lVlELRlSH(EQ‘4l'1l/17 Page 10 of 11 Page|D: 10The IS 44 civil cover sheet and the information contained herein neither replace nor supplement the filingand service of pleadings or other papers as required by law, except asprovided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for thepurpose of initiating the ClVIl docket sheet. {SEE INSTRUCTIONSONNEXT PAGE OF THISFORM)I. (a) PLAINTIFFS DEFENDANTS

_ _ VCity of Atlantic City, City of Atlantic City Police Department, HenryGJJM Enterprises, LLC d/b/a Stiletto White, Chief, Atlantic City Police Department

(b) County ofResidence of First Listed Plaintiff Atlantic County of Residence ofFirst Listed Defendant Atlantic(EXCEPTIN US. PLAINTIFF CASES) (IN US. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OFTHE TRACT OF LAND INVOLVED‘

(C) Attorneys (Firm Name, Address, Emailand TelephoneNumber) AKOTUCYS(1fK"0W")

Holtzman & McClain, PC, 524 Maple Avenue, Suite 200, Linwood, NJ08221, [email protected],(609) 601-0900

II. BASIS OF JURISDICTION (Placean “X" in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X” in One Box/or P/aiimxf(Fur Diversity Cases Only) and One Boxfor l)efendanl)El 1 US. Government 5 3 Federal Question PTF DEF PTF DEFPlaintiff (US. Government Not a Party) Citizen of This State 3 1 l2‘ 1 Incorporated or Principal Place Cl 4 3 4

of Business In This State

El 2 US. Government El 4 Diversity Citizen ofAnother State Cl 2 2| 2 Incorporated andPrincipal Place E! 5 3 5Defendant (Indicate Citizenship ofParties in Item 11]) of Business In Another State

Citizen or Subject of a Cl 3 II 3 Foreign Nation El 6 :1 6Forei Count

IV. NATUREOF SUIT (Place an “X" in One Box Only)

FORFEITURE/PENALTY BANKRUPTCY

OTHER STATUTES

3 110 Insurance PERSONAL INJURY PERSONAL INJURY CI 625 Drug Related Seizure El 422 Appeal 28 USC 158 E] 375 False Claims ActD 120 Marine D 310 Airplane CI 365 Personal Injury - of Property 21 USC 881 CI 423 Withdrawal D 376 Qui Tam (31 USC3 130 MillerAct D 315 Airplane Product Product Liability U 690 Other 28 USC 157 3729(a))CI 140 Negotiable Instrument Liability I3 367 Health Care/ Cl 400 State Reapportionment[3 150 Recovery of Overpayment Cl 320 Assault, Libel & Pliamiaceutical CI 410 Antitrust& Enforcement of Judgment Slander Personal Injury Cl 820 Copyrights D 430 Banks and BankingCl 151 Medicare Act III 330 Federal Employers’ Product Liability Cl 830 Patent Cl 450 CommerceCl 152 Recovery of Defaulted Liability CI 368 Asbestos Personal CI 840 Trademark Cl 460 DeportationStudent Loans I3 340 Marine Injury Product [3 470 Racketeer Influencedand(Excludes Veterans) Cl 345 Marine Product Liability Corrupt OrganizationsCI 153 Recovery of Overpayment Liability PERSONAL PROPERTY ID 710 Fair Labor Standards D 861 HIA (1395ff) D 480 Consumer Creditof Veteran’s Benefits '3 350 Motor Vehicle D 370 OtherFraud Act III 862 BlackLung (923) El 490 Cable/SatTVCI 160 Stockholders’ Suits El 355 Motor Vehicle II 371 Truthin Lending Cl 720 Labor/Mariageinent CI 863 DIWC/DIWW(405(g)) El 850 Securities/Coinmodities/Cl 190 Other Contract Product Liability El 380 OtherPersonal Relations Cl 864 SSID Title XVI ExchangeD 195 ContractProduct Liability 3 360 OtherPersonal Property Damage [3 740 RailwayLabor Act Cl 865 RSI (405(g)) D 890 Other Statutory ActionsCI 196 Franchise Injury 3 385 Property Damage 3 751 Familyand Medical D 891 Agricultural ActsD 362 Personal Injury — Product Liability Leave Act III 893 Environmental MattersMedical Malractice Cl 790 OtherLabor Litigation Cl 895 Freedom of Information

REAL PROPERTY lI PRISONER PETITIONS 3 791 Employee Retirement FEDERAL TAX SUITS Act

Cl 210 Land Condemnation lX 440 OtherCivil Rights Habeas Corpus: Income Security Act Cl 870 Taxes (US Plaintiff Cl 896 ArbitrationD 220 Foreclosure El 441 Voting D 463 Alien Detainee or Defendant) Cl 899 AdministrativeProcedureCl 230 Rent Lease & Ejecunent Cl 442 Employment El 510 Motions to Vacate Cl 871 IRS—Third Party Act/Review or Appeal of3 240 Torts to Land O 443 Housiiig/ Sentence 26 USC 7609 Agency Decision3 245 Tort Product Liability Accommodations [3 530 General CI 950 ConstitutionalityofCI 290 All OtherReal Property [3 445 Amer. w/Disabilities— Cl 535 DeathPenalty State StatutesEmployment Other: El 462 NaturalizationApplicationEl 446 Amer. w/Disabilities- El 540 Mandamus & Other CI 465 Other ImmigrationOther Cl 550 Civil Rights Actions

III 448 Education Cl 555 Prison ConditionCl 560 Civil Detainee -

Conditions ofConfiiieirient

V. ORIGIN (Place an “X" in One Bax Only)Ml Original El 2 Removed from El 3 Remanded from D 4 Reinstated or D 5 Transferred from El 6 Multidistrict El 8 MultidistrictProceeding State Court Appellate Court Reopened AngtherDistrict Litigation - Litigation -

(specify) Transfer Direct F1 le

Cite the US. Civil Statute under which you are fllittlg (Do not cite jurisdictionalstatutes unless diversity):First Amendment to US Constitution, 42 SC 1983, New Jersey ConstitutionBriefdescription of cause:Deprivation of commercial free speech, prohibition of truthful and nonmisleading advertising by N.J.S.A. 2C:33—27

VI. CAUSE OF ACTION

VII. REQUESTED IN D CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:COMPLAINT: UNDER RULE 23, F -R.Cv-P. JURY DEMAND: D Yes a(No VIII. RELATED CASE(S)_ _IF ANY (Seemstructzons):

JUDGE DOCKET NUMBERDATE SIGNATUREOF ATTORNEYOF RECORD04/11/2017 /s/ Stephen D. Holtzman (SDH 9921)FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

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INSTRUCTIONSFOR ATTORNEYSCOMPLETING CIVIL COVER SHEET FORM JS 44

AuthorityFor Civil Cover Sheet

The J S 44 civil cover sheet and the information contained herein neither replaces nor supplements the filingsand service of pleading or other papers asrequired by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, isrequired for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk ofCourt for each civil complaint filed. The attorney filinga case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiffand defendant. If the plaintiffor defendant is a government agency, useonly the full name or standard abbreviations. If the plaintiffor defendant is an official withina government agency, identify first the agency andthen the official, giving bothname and title.

(b) County of Residence. For each civil case filed, except U.S. plaintiffcases, enter the name of the county where the first listed plaintiff resides at thetime of filing. In U.S. plaintiffcases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In landcondemnationcases, the county of residence of the "defendant" is the location of the tract of land involved.)

(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, notingin this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires thatjurisdictions be shown in pleadings. Place an "X"in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.United States defendant. (2)When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdictionarises under the Constitution of the United States, an amendmentto the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiffor defendant code takesprecedence, and box 1 or 2 should be marked.Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, thecitizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversitycases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark thissection for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, issufficient to enable the deputy clerk or the statistical clerk(s) in the AdministrativeOffice to determine the nature of suit. If the cause fits more thanone nature of suit, select the most definitive.

V. Origin. Place an "X" in one ofthe seven boxes.Original Proceedings. (1) Cases which originate in the United States district courts.Removed from 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 for removal is granted, check this box.Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filingdate.Reinstated or Reopened. (4) Check thisbox for cases reinstated or reopened in the district court. Use the reopening date as the filingdate.Transferred from AnotherDistrict. (5) For cases transferred under Title 28 U.S.C. Section l404(a). Do not use this for withindistrict transfers ormultidistrict litigation transfers.Multidistrict Litigation — Transfer. (6) Check this box when a multidistrict case is transferred into the district under authorityof Title 28 U.S.C.Section 1407.Multidistrict Litigation — Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.PLEASE NOTETHAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due tochanges in statue.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a briefdescription of the cause. Do not cite jurisdictionalstatutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 BriefDescription: Unauthorizedreception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box ifyou are filing 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 of the J S 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docketnumbers and the correspondingjudge names for such cases.

Date and Attorney Signature. Date and Sign the civil cover sheet.

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