Case 1:17-cv-10703-RGS Document 1 Filed 04/21/17 Page 1 of 9

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

MARIE SAPIENZA CIVIL ACTION NO.:

Plaintiff

v.

ALEXANDER THEROUX

Defendant

April 21, 2017

COMPLAINT AND JURY TRIAL DEMAND

INTRODUCTION

1. This case arises out of the sexual abuse in Massachusetts of Plaintiff, Marie

Sapienza, when she was a minor by Defendant, Alexander Theroux, a former teacher at

Phillips Academy in Andover, Massachusetts. The Plaintiff met Defendant Alexander

Theroux when Plaintiff was a student at Phillips Academy and when Defendant

Alexander Theroux was a teacher at Phillips Academy.

2. The Plaintiff now seeks damages for her personal injuries pursuant to the

common law of Massachusetts.

STATEMENT OF JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1332 because

the Plaintiff is a citizen of New Hampshire, the Defendant is a citizen of Massachusetts,

 Case 1:17-cv-10703-RGS Document 1 Filed 04/21/17 Page 2 of 9

and the amount in controversy, without interest and costs, exceeds the sum or value of

$75,000.

4. Venue is proper in this District pursuant to 28 U.S.C. 1391(b)(2) in that a

substantial part of the events giving rise to the Plaintiffs claims occurred in this District.

PARTIES

5. Plaintiff Marie Sapienza (hereinafter referred to as Plaintiff Marie Sapienza

or the Plaintiff) is an individual with a residential address in Hampstead, New

Hampshire.

6. Defendant Alexander Theroux is an individual with a residential address is

West Barnstable, Barnstable County, Massachusetts.

STATEMENT OF FACTS

7. At all relevant and material times, Phillips Academy was a co-educational

boarding school located in Andover, Essex County, Massachusetts.

8. From approximately 1978 to approximately 1983, Defendant Alexander

Theroux was employed at Phillips Academy as an English teacher and writer-in-

residence, with responsibilities that included, among other things, teaching, directing,

counseling, supervising, or otherwise interacting with minor children who were students

at Phillips Academy.

9. In approximately the fall of 1981, when the Plaintiff was approximately

fourteen years old, the Plaintiff entered Phillips Academy as a full time student. The

Plaintiff continued as a full time student at Phillips Academy from approximately the

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 Case 1:17-cv-10703-RGS Document 1 Filed 04/21/17 Page 3 of 9

1981-1982 school year through approximately October 1984, when the Plaintiff

voluntarily left Phillips Academy.

10. The Plaintiff lived with her family in Andover, Massachusetts during the years

that the Plaintiff attended Phillips Academy as a student.

11. Not until recently did the Plaintiff have knowledge or sufficient notice that she

had been harmed and that the harm was caused by the explicit sexual behavior and lewd

and lascivious conduct of Defendant Alexander Theroux as explained below.

12. On one occasion in approximately 1982, when the Plaintiff was approximately

fifteen years old, Defendant Alexander Theroux engaged in explicit sexual behavior and

lewd and lascivious conduct with the Plaintiff including, but not limited to, Defendant

Alexander Theroux fondling the Plaintiffs breasts and Defendant Alexander Theroux

fondling the Plaintiffs buttocks, all for the purposes of Defendant Alexander Therouxs

sexual gratification. Defendant Alexander Therouxs explicit sexual behavior and lewd

and lascivious conduct with the Plaintiff occurred in Defendant Alexander Therouxs

residence in Andover, Massachusetts.

13. Following Defendant Alexander Therouxs explicit sexual behavior and lewd

and lascivious conduct with the Plaintiff, Defendant Alexander Theroux contacted the

Plaintiff by telephone at the Plaintiffs home to ask the Plaintiff to enroll in one of

Defendant Alexander Therouxs classes, promising the Plaintiff that Defendant

Alexander Theroux would give the Plaintiff a good grade if the Plaintiff enrolled in a

class taught by Defendant Alexander Theroux.

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 Case 1:17-cv-10703-RGS Document 1 Filed 04/21/17 Page 4 of 9

14. In approximately 1983 or 1984, when the Plaintiff was in her junior year at

Phillips Academy, the Plaintiff wrote a letter about sexual misconduct at Phillips

Academy and submitted the letter for inclusion in Phillips Academys school newspaper,

The Phillipian. A student who worked for The Phillipian informed the Plaintiff that her

letter would not be published in the newspaper. That student also informed the Plaintiff

that the Headmaster of Phillips Academy, Donald McNemar (hereinafter Mr.

McNemar), was aware of the Plaintiffs letter and requested to speak with the Plaintiff

about her letter.

15. In approximately 1983 or 1984, following her conversation with the student

who worked for The Phillipian as described above, the Plaintiff told Mr. McNemar about

Defendant Alexander Therouxs explicit sexual behavior and lewd and lascivious

conduct with the Plaintiff. In response, Mr. McNemar told the Plaintiff that, as of the time

of this conversation between the Plaintiff and Mr. McNemar, Defendant Alexander

Theroux had already ceased working for Phillips Academy, and, therefore, there was

nothing Mr. McNemar would do about Defendant Alexander Therouxs explicit sexual

behavior and lewd and lascivious conduct with the Plaintiff.

16. As a result of Defendant Alexander Therouxs explicit sexual behavior and

lewd and lascivious conduct with the Plaintiff, the Plaintiff suffers, has suffered, and will

continue to suffer in the future severe emotional distress and physical harm manifested

by objective symptomatology, including, but not limited to, suicidal ideation, depression,

sadness, anger, anxiety, sleep problems, and panic attacks.

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 Case 1:17-cv-10703-RGS Document 1 Filed 04/21/17 Page 5 of 9

17. At all relevant and material times, Defendant Alexander Theroux

misrepresented and concealed from the Plaintiff the wrongful nature of Defendant

Alexander Therouxs explicit sexual behavior and lewd and lascivious conduct with the

Plaintiff and that such explicit sexual behavior and lewd and lascivious conduct could

harm the Plaintiff.

18. As a result of Defendant Alexander Therouxs explicit sexual behavior and

lewd and lascivious conduct with the Plaintiff, the Plaintiff is unable at this time to fully

disclose in complete detail to what degree Defendant Alexander Theroux did abuse the

Plaintiff emotionally and physically.

CLAIMS FOR RELIEF

Count I: Plaintiff Marie Sapienza v. Defendant Alexander Theroux

Assault

19. The Plaintiff repeats, realleges, and incorporates by reference herein each and

every allegation heretofore pleaded in this Complaint.

20. By engaging in the explicit sexual behavior and lewd and lascivious conduct

with the Plaintiff described above, Defendant Alexander Theroux acted intentionally so

as to cause harmful and offensive contact with the Plaintiff.

21. By engaging in the explicit sexual behavior and lewd and lascivious conduct

described above, Defendant Alexander Theroux placed the Plaintiff in imminent and

reasonable apprehension of said harmful and offensive contact.

22. As a direct and proximate result of Defendant Alexander Theroux placing the

Plaintiff in imminent and reasonable apprehension of harmful and offensive contact, the

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 Case 1:17-cv-10703-RGS Document 1 Filed 04/21/17 Page 6 of 9

Plaintiff suffered and will continue to suffer in the future: severe and permanent mental

distress and emotional injuries as outlined above; financial expenses for medical and

therapeutic care and treatment; long term lost earning capacity; as well as other damages.

23. By reason of the foregoing, Defendant Alexander Theroux is liable to the

Plaintiff for assault, in an amount to be proved at trial.

Count II: Plaintiff Marie Sapienza v. Defendant Alexander Theroux

Battery

24. The Plaintiff repeats, realleges, and incorporates by reference herein each and

every allegation heretofore pleaded in this Complaint.

25. By engaging in the explicit sexual behavior and lewd and lascivious conduct

described above, Defendant Alexander Theroux acted intentionally so as to cause

unjustified harmful and offensive physical contact and touching of the Plaintiff, and

repeatedly performed such unjustified harmful and offensive physical contact and

touching of the Plaintiff.

26. As a direct and proximate result of Defendant Alexander Therouxs

unjustified harmful and offensive physical contact and touching, the Plaintiff suffered

and will continue to suffer in the future: severe and permanent mental distress and

emotional injuries as outlined above; financial expenses for medical and therapeutic care

and treatment; long term lost earning capacity; as well as other damages.

27. By reason of the foregoing, Defendant Alexander Theroux is liable to the

Plaintiff for battery, in an amount to be proved at trial.

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 Case 1:17-cv-10703-RGS Document 1 Filed 04/21/17 Page 7 of 9

Count III: Plaintiff Marie Sapienza v. Defendant Alexander Theroux

Intentional Infliction of Emotional Distress

28. The Plaintiff repeats, realleges, and incorporates by reference herein each and

every allegation heretofore pleaded in this Complaint.

29. By engaging in the explicit sexual behavior and lewd and lascivious conduct

described above, Defendant Alexander Theroux intended to inflict emotional distress

upon the Plaintiff, or Defendant Alexander Theroux knew or should have known that

emotional distress was the likely result of Defendant Alexander Therouxs conduct.

30. The conduct of Defendant Alexander Theroux in engaging in the explicit

sexual behavior and lewd and lascivious conduct described above is extreme and

outrageous, beyond all possible bounds of decency, and utterly intolerable in a civilized

community.

31. The mental distress and emotional injuries which the Plaintiff suffered and

will continue to suffer were severe, and of a nature that no reasonable person could be

expected to endure them.

32. As a direct and proximate result of the conduct of Defendant Alexander

Theroux in engaging in the explicit sexual behavior and lewd and lascivious conduct

described above, the Plaintiff suffered and will continue to suffer in the future: severe

and permanent mental distress and emotional injuries as outlined above; financial

expenses for medical and therapeutic care and treatment; long term lost earning capacity;

as well as other damages.

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 Case 1:17-cv-10703-RGS Document 1 Filed 04/21/17 Page 8 of 9

33. By reason of the foregoing, Defendant Alexander Theroux is liable to the

Plaintiff for intentional infliction of emotional distress, in an amount to be proved at trial.

Count IV: Plaintiff Marie Sapienza v. Defendant Alexander Theroux

Negligent Infliction of Emotional Distress

34. The Plaintiff repeats, realleges, and incorporates by reference herein each and

every allegation heretofore pleaded in this Complaint.

35. In his capacity as a teacher at Phillips Academy, Defendant Alexander

Theroux had a duty of care to properly and safely teach, direct, counsel, and supervise

minor children who were students at Phillips Academy, including the Plaintiff.

36. Defendant Alexander Theroux negligently breached such duty by failing to

exercise the care of a reasonable person in his contact with and supervision of the

Plaintiff, in that he violated boundaries concerning appropriate and inappropriate

touching between an adult teacher at Phillips Academy and a minor student at Phillips

Academy by engaging in the conduct described above.

37. At all relevant times to this action, Defendant Alexander Theroux knew or

should have known that violating boundaries concerning appropriate and inappropriate

touching and interactions by engaging in the conduct described above would result in

severe mental and emotional suffering by the Plaintiff.

38. A reasonable person in the Plaintiff's position would have suffered extreme

mental distress and emotional injuries under these circumstances.

39. As a direct and proximate result of Defendant Alexander Therouxs negligent

conduct, the Plaintiff suffered and will continue to suffer in the future: severe and

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 Case 1:17-cv-10703-RGS Document 1 Filed 04/21/17 Page 9 of 9

permanent mental distress and emotional injuries, including objective corroboration of

said mental distress and emotional injuries as outlined above; financial expenses for

medical and therapeutic care and treatment; long term lost earning capacity; as well as

other damages.

40. By reason of the foregoing, Defendant Alexander Theroux is liable to the

Plaintiff for negligent infliction of emotional distress, in an amount to be proved at trial.

PRAYER FOR RELIEF

WHEREFORE Plaintiff Marie Sapienza respectfully demands judgment of

$5,000,000.00 in damages against Defendant Alexander Theroux for each claim Plaintiff

Marie Sapienza states against Defendant Alexander Theroux, plus costs, interest,

attorneys' fees, and such other and further relief as this Court deems just and equitable.

PLAINTIFFS JURY TRIAL DEMAND

The Plaintiff demands a trial by jury on all claims so triable.

Dated: April 21, 2017

By Plaintiffs Attorney,

/s/ Mitchell Garabedian

Mitchell Garabedian, BBO #184760
mgarabedian@garabedianlaw.com
LAW OFFICES OF MITCHELL GARABEDIAN
100 State Street, 6th Floor
Boston, MA 02109
Phone: (617) 523-6250
Fax: (617) 523-3687

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 Case 1:17-cv-10703-RGS Document 1-1 Filed 04/21/17 Page 1 of 1

JS44 {Rov.0B/!6) ^ ^
TheJS 44civil cover sheet andthe information contained herein neither replace norsupplement thefiling andservice of pleadings orother papers as required bylaw, except as
provided by local rules ofcourt. This form, approved by the Judicial Conference ofthe United Stales in September 1974, isrequired for the use ofthe Clerk ofCourt for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ONNl^XT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

Marie Sapienza Alexander Theroux

(b) Countyof Residence of First Listed PlainlifT County of Residence ofFirst Listed Defendant Bamstable
(EXCEPT IN U.S PLAINTIFF CASES) (IN U.S. PUINTIFF CASESONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

fc) Attorneys (Firm Name, Aildrcs.i, and Telephone Number) Attorneys (If Known)
Mitcnell Garabedian, Esq.
Law Offices of Mitchell Garabedian
100 State Street, 6th Floor, Boston, MA 02109 - (617) 523-6250

II. BASIS OF JURISDICTION (Placean"X"inOneBox Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X"inOneBoxfor Plaintiff
(ForDiversity CasesOnly) andOneBoxfor Defendant)
O I U.S. Government 3 Federal Question PTE DEF PTF DEF
Plaintiff (U.S. Government Not a Parly) Citizenof ThisState 1 ^ \ Incorporated or Principal Place 0 4 0 4
of Business In This Stue

2 U.S. Government H 4 Diversity Citizen of Another State Incorporated and Principal Place
Defendant (Indicate Cilizenshipof Parlies in Item III) of Business In Another State

Citizen or Subject of a 3 O 3 Foreign Nation 0 6 0 6

Forciun Coun

IV. NATURE OF SUIT (Place an "X"in OneBox Only) Click here for: Nature of Suit Code Descriptions.
TOR'TS B:(t)t)n>lliilil!lsridai:iiiW ;Mili NtUi u

no Insurance
120 Marine
O 130 Miller Aci
D 140 Negotiable Instrument
O 150 Recovery of Overpayment 320 Assault, Libel &
& Enforcement of Judgment
151 Medicare Act
O 152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 RecoveryofOverpayment
of Veteran's Benefits
D t60 Stockholders'Suits
0 190 Other Contract
0 195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
O 240 Torts to Land
245 Tort Product Liability
290 AHOther Real Property
PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 use 158 375 False Claims Act
310 Airplane 365 Personal Injury of Property 21 USC881 423 Withdrawal 376QuiTam(31USC
O 315 Airplane Product Product Liability 690 Other 28 use 157 3729(a))
Liability 367 Health Care/ 400 State Reapportionmenl
Pharmaceutical 410 Antitrust
Slander Personal Injury O 820 Copyrights 430 Banks and Banking
330 Federal Employers' Product Liability 830 Patent 450 Commerce
Liability O 368 Asbestos Personal 840 Trademark 460 Deportation
340 Marine Injury Product 470 Racketeer Influenced and
O 345 Marine Product Liability 1 LAROR 1 SOCIAL SECURITY CoiTuptOrganizations
Liability PERSONAL PROPERTY 710 Fair Labor Standards a 861 HlA(1395fl) 480 Consumer Credit
350 Motor Vehicle 370 Other Fraud Act O 862 Black Lung (923) 490 Cable/Sat TV
355 Motor Vehicle O 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 850 Securities/Commodities/
Product Liability 380 Other Personal Relations 864 SSID Title XVI Exchange
H 360 OtherPersonal Property Damage 740 Railway Labor Act 865 RSI (405(g)) 890 Other Statutory Actions
Injuty 385 Property Damage 751 Family and Medical 891 Agricultural Acts
D 362 Persona]Injury - Product Liability Leave Act 893 Environmental Matters
Medical Malpractice 790 Other Labor Litigation 895 Freedom oflnformation
791 Employee Retirement Act
CIVIL RIGHTS
440 Other Civil Rights Habeas Corpus: Income Security Act O 870 Taxes (U.S. PiaintiiT 896 Arbitration
441 Voting O 463 Alien Detainee or Defendant) 899 Administrative Procedure
442 Employment 510 Motions to Vacate 871 IRSThird Party Act/Review or Appeal of
443 Housing/ Sentence 26 use 7609 Agency Decision
Accommodations 530 Genera! 950 Constitutionality of
535 Death Penalty IMMIGRATION State Statutes
O 445 Amcr. w/Disabilities
Employment Other: 462 Naturalization Application
O 446 Aincf. w/Disabilities 540 Mandamus & Other D 465 Other Immigration
Other 550 Civil Rights Actions
443 Education O 555 Prison Condition
O 560 Civil Detainee
Conditions of
Confinement

V. ORIGIN (Place an "X"inOneBox Only)

X 1 Original 2 Removed;dfrom
from 3 Remanded from 4 Reinstated or 0 5 Transferred from ^ Mitltidjstricl O 8 Multidistrict
Proceeding )urt
State Court Appellate Court Reopened Another District Litigation- Litigation-
(specify) Transfer Direct File
Cite the US Civil Statute under which you are filing (DonotciteJitrlsdlctlonal statutesunlessdiversity):
28U.S.C. 1332
VI. CAUSE OF ACTION Brief description of cause; . . . .
Plaintiffand Defendant are of diverse citizenship and the sum in controversy exceeds $75,000.00
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMANDS CHECK YES only if demanded in complaint:
COMPLAINT: UNDERRULE 23. F.R.Cv.P. 5,000,000.00 JURY DEMAND: X Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

04/21/2017 Isl Mitchell Garabedian
FOR OFFICE USE ONLY

APPLYING IFP MAG. JUDGE

 Case 1:17-cv-10703-RGS Document 1-2 Filed 04/21/17 Page 1 of 1

JS44 {Rov.0B/!6) ^ ^
TheJS 44civil cover sheet andthe information contained herein neither replace norsupplement thefiling andservice of pleadings orother papers as required bylaw, except as
provided by local rules ofcourt. This form, approved by the Judicial Conference ofthe United Stales in September 1974, isrequired for the use ofthe Clerk ofCourt for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ONNl^XT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

Marie Sapienza Alexander Theroux

(b) Countyof Residence of First Listed PlainlifT County of Residence ofFirst Listed Defendant Bamstable
(EXCEPT IN U.S PLAINTIFF CASES) (IN U.S. PUINTIFF CASESONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

fc) Attorneys (Firm Name, Aildrcs.i, and Telephone Number) Attorneys (If Known)
Mitcnell Garabedian, Esq.
Law Offices of Mitchell Garabedian
100 State Street, 6th Floor, Boston, MA 02109 - (617) 523-6250

II. BASIS OF JURISDICTION (Placean"X"inOneBox Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X"inOneBoxfor Plaintiff
(ForDiversity CasesOnly) andOneBoxfor Defendant)
O I U.S. Government 3 Federal Question PTE DEF PTF DEF
Plaintiff (U.S. Government Not a Parly) Citizenof ThisState 1 ^ \ Incorporated or Principal Place 0 4 0 4
of Business In This Stue

2 U.S. Government H 4 Diversity Citizen of Another State Incorporated and Principal Place
Defendant (Indicate Cilizenshipof Parlies in Item III) of Business In Another State

Citizen or Subject of a 3 O 3 Foreign Nation 0 6 0 6

Forciun Coun

IV. NATURE OF SUIT (Place an "X"in OneBox Only) Click here for: Nature of Suit Code Descriptions.
TOR'TS B:(t)t)n>lliilil!lsridai:iiiW ;Mili NtUi u

no Insurance
120 Marine
O 130 Miller Aci
D 140 Negotiable Instrument
O 150 Recovery of Overpayment 320 Assault, Libel &
& Enforcement of Judgment
151 Medicare Act
O 152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 RecoveryofOverpayment
of Veteran's Benefits
D t60 Stockholders'Suits
0 190 Other Contract
0 195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
O 240 Torts to Land
245 Tort Product Liability
290 AHOther Real Property
PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 use 158 375 False Claims Act
310 Airplane 365 Personal Injury of Property 21 USC881 423 Withdrawal 376QuiTam(31USC
O 315 Airplane Product Product Liability 690 Other 28 use 157 3729(a))
Liability 367 Health Care/ 400 State Reapportionmenl
Pharmaceutical 410 Antitrust
Slander Personal Injury O 820 Copyrights 430 Banks and Banking
330 Federal Employers' Product Liability 830 Patent 450 Commerce
Liability O 368 Asbestos Personal 840 Trademark 460 Deportation
340 Marine Injury Product 470 Racketeer Influenced and
O 345 Marine Product Liability 1 LAROR 1 SOCIAL SECURITY CoiTuptOrganizations
Liability PERSONAL PROPERTY 710 Fair Labor Standards a 861 HlA(1395fl) 480 Consumer Credit
350 Motor Vehicle 370 Other Fraud Act O 862 Black Lung (923) 490 Cable/Sat TV
355 Motor Vehicle O 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 850 Securities/Commodities/
Product Liability 380 Other Personal Relations 864 SSID Title XVI Exchange
H 360 OtherPersonal Property Damage 740 Railway Labor Act 865 RSI (405(g)) 890 Other Statutory Actions
Injuty 385 Property Damage 751 Family and Medical 891 Agricultural Acts
D 362 Persona]Injury - Product Liability Leave Act 893 Environmental Matters
Medical Malpractice 790 Other Labor Litigation 895 Freedom oflnformation
791 Employee Retirement Act
CIVIL RIGHTS
440 Other Civil Rights Habeas Corpus: Income Security Act O 870 Taxes (U.S. PiaintiiT 896 Arbitration
441 Voting O 463 Alien Detainee or Defendant) 899 Administrative Procedure
442 Employment 510 Motions to Vacate 871 IRSThird Party Act/Review or Appeal of
443 Housing/ Sentence 26 use 7609 Agency Decision
Accommodations 530 Genera! 950 Constitutionality of
535 Death Penalty IMMIGRATION State Statutes
O 445 Amcr. w/Disabilities
Employment Other: 462 Naturalization Application
O 446 Aincf. w/Disabilities 540 Mandamus & Other D 465 Other Immigration
Other 550 Civil Rights Actions
443 Education O 555 Prison Condition
O 560 Civil Detainee
Conditions of
Confinement

V. ORIGIN (Place an "X"inOneBox Only)

X 1 Original 2 Removed;dfrom
from 3 Remanded from 4 Reinstated or 0 5 Transferred from ^ Mitltidjstricl O 8 Multidistrict
Proceeding )urt
State Court Appellate Court Reopened Another District Litigation- Litigation-
(specify) Transfer Direct File
Cite the US Civil Statute under which you are filing (DonotciteJitrlsdlctlonal statutesunlessdiversity):
28U.S.C. 1332
VI. CAUSE OF ACTION Brief description of cause; . . . .
Plaintiffand Defendant are of diverse citizenship and the sum in controversy exceeds $75,000.00
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMANDS CHECK YES only if demanded in complaint:
COMPLAINT: UNDERRULE 23. F.R.Cv.P. 5,000,000.00 JURY DEMAND: X Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

04/21/2017 Isl Mitchell Garabedian
FOR OFFICE USE ONLY

APPLYING IFP MAG. JUDGE