Case 1:20-cv-00360 Document 1 Filed 08/20/20 Page 1 of 11 PageID #: 1

Alan Alexander Beck

Law Office of Alan Beck
2692 Harcourt Drive
San Diego, CA 92123
(619) 905-9105
Hawaii Bar No. 9145
Alan.alexander.beck@gmail.com

Attorney for Plaintiffs

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF HAWAII

)
JON ABBOTT, KEVIN LLOYD L. )
KACATIN, SOLEIL ROACHE )
)
)
Plaintiffs, )
) Civil Action No. _____________
v. )
)
CLARE E. CONNORS, in her )
Official Capacity as the Attorney General )
of the State of Hawaii )
)
)
Defendant. )
____________________________________)

VERIFIED COMPLAINT FOR DECLARATORY

AND INJUNCTIVE RELIEF

COME NOW the Plaintiffs, Jon Abbott, Kevin Lloyd L. Kacatin and Soleil

Roache, (“Plaintiffs”), by and through their undersigned counsel, and complain of

the Defendant as follows:

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I. PARTIES

1. Plaintiff Jon Abbott is an adult male resident of the State of Hawaii and

resides in Honolulu County and is a citizen of the United States. But for Hawaii’s

restrictions on handgun magazines over ten rounds and his reasonable fear of

criminal prosecution for violating them, Plaintiff Abbott would immediately acquire

and continuously possess a handgun magazine over ten rounds within Hawaii for

lawful purposes, including in-home self-defense. See Abbott Declaration, Exhibit

“1”.

2. Plaintiff Kevin Lloyd L. Kacatin is an adult male resident of the State

of Hawaii and resides in Honolulu County and is a citizen of the United States. But

for Hawaii’s restrictions on handgun magazines over ten rounds and his reasonable

fear of criminal prosecution for violating them, Plaintiff Kacatin would immediately

acquire and continuously possess a handgun magazine over ten rounds within

Hawaii for lawful purposes, including in-home self-defense. See Kacatin

Declaration, Exhibit “2”.

3. Plaintiff Soleil Roache is an adult female resident of the State of Hawaii

and resides in Honolulu County and is a citizen of the United States. But for

Hawaii’s restrictions on handgun magazines over ten rounds and her reasonable fear

of criminal prosecution for violating them, Plaintiff Roache would immediately

acquire and continuously possess a handgun magazine over ten rounds within

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Hawaii for lawful purposes, including in-home self-defense. See Roache

Declaration, Exhibit “3”.

4. Each of the individual Plaintiffs identified above seeks to keep, acquire,

possess, and/or transfer handgun magazines capable of holding more than 10 rounds

for lawful purposes, including in-home self-defense, as is their right under the

Second Amendment to the United States Constitution. Each of the individual

Plaintiffs identified above is eligible under the laws of the United States and of the

State of Hawaii to receive and possess firearms.

5. Defendant Clare E. Connors is the Attorney General of the State of

Hawaii and is sued in her official capacity and is responsible for enforcing the State

of Hawaii’s customs, policies, practices and laws related to the State of Hawaii’s on

the registration of firearms. Defendant Connors may be served at the Office of

Attorney General located at 425 Queen St, Honolulu, Hawaii 96813.

II. JURISDICTION AND VENUE

6. This Court has subject matter jurisdiction over this action pursuant to

28 U.S.C. §§ 1331, 1343, 2201, 2202 and 42 U.S.C. § 1983 and § 1988.

7. Venue lies in this Court pursuant to 28 U.S.C. § 1391.

III. STATEMENT OF FACTS

a. The Second Amendment

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8. The Second Amendment to the United States Constitution provides: “A

well regulated Militia, being necessary to the security of a free State, the right of the

people to keep and bear Arms shall not be infringed.” U.S. CONST. amend. II.

9. The Second Amendment guarantees individuals a fundamental right to keep

and carry arms for self-defense and defense of others in the event of a violent

confrontation. District of Columbia v. Heller, 554 U.S. 570 (2008); McDonald v.

Chicago, 561 U.S. 742 (2010); Caetano v. Massachusetts, 577 U.S. 1027 (2016).

The Court has held that “a prohibition of an entire class of ‘arms’ that is

overwhelmingly chosen by American society” is unconstitutional, especially when

that prohibition extends “to the home, where the need for defense of self, family, and

property is most acute.” Heller, 554 U.S. at 628.

10. Magazines which hold more than ten rounds of ammunition are

protected by the Second Amendment. Duncan v. Becerra, 2020 U.S. App. LEXIS

25836 (9th Cir. Aug. 14, 2020).

11. In Duncan, the Ninth Circuit overturned California’s ban on the

ownership of magazines that hold more than ten rounds.

12. Given the decision in Duncan, Hawaii may not ban magazines which

hold more than ten rounds. Id.

13. Hawaii law prohibits “[t]he manufacture, possession, sale, barter, trade,

gift, transfer, or acquisition of detachable ammunition magazines with a capacity in

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excess of ten rounds which are designed for or capable of use with a pistol is

prohibited.” See H.R.S. § 134-8.

14. Millions of law-abiding Americans own firearms equipped with

magazines capable of holding more than ten rounds of ammunition. There is nothing

unusual or novel about this technology. Indeed, many of the nation’s best-selling

handguns come standard with magazines that can hold more than ten rounds, and

handguns equipped with such magazines are safely possessed by law-abiding

citizens in the vast majority of states. The reason for the popularity of these

magazines is straightforward: In a confrontation with a violent attacker, having

enough ammunition can be the difference between life and death.

15. A firearm “magazine” is a device that holds ammunition cartridges or

shells, and (along with other parts of the firearm) it feeds the ammunition into the

chamber for firing. Sporting Arms & Ammunition Mfrs.’ Inst. (SAAMI), Glossary

Results–M (2009), 25.

16. Detachable magazines are a convenient and safe way to store and

transport ammunition.

17. Detachable magazines are in common use across the United States and

the vast majority of states do not have restrictions on magazine capacity.

18. Millions of Americans choose magazines over ten rounds for self-

defense, including self-defense in the home.

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19. There are no exceptions to Hawaii law for the Plaintiffs to acquire or

possess handgun magazines capable of holding more than ten rounds.

20. The Ninth Circuit in Duncan estimated that there are about 115 Large

Capacity Magazine currently in possession by civilians. Duncan, at 11. Stated

differently, “half of all magazines in America hold more than ten rounds.” Id. at 12.

21. These magazines “are commonly used in many handguns, which the

Supreme Court has recognized as the ‘quintessential self-defense weapon’.” Id.

(citation omitted).

22. The Glock 17, “[o]ne of the most popular handguns in America today

… comes standard with a magazine able to hold 17 bullets.” Id. at 27.

23. The prohibitions of H.R.S. § 134-8 extend into Plaintiffs’ homes where

Second Amendment protections are at their zenith and Defendant cannot satisfy her

burden of justifying H.R.S. § 134-8’s restrictions on the Second Amendment rights

of the People, including Plaintiffs, to acquire, keep, possess, transfer and use

magazines that are in common use by law-abiding adults throughout the United

States for the core right of defense of self and home and other lawful purposes.

24. Further, laws like H.R.S. § 134-8 are not longstanding regulations and

do not enjoy a presumption of lawfulness.

b. Plaintiff Jon Abbott

25. Plaintiff Abbott is employed as an electrician.

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26. Plaintiff Abbott currently legally owns handguns which would accept

magazines that hold more than ten rounds.

27. Plaintiff Abbott is a director for the Hawaii Firearms Coalition.

28. Plaintiff Abbott has never been convicted of a crime that would

disqualify him from firearms ownership under either Hawaii or federal law.

29. Plaintiff Abbott has never been diagnosed with a mental disorder that

would disqualify him from firearms ownership under Hawaii or federal law.

30. Plaintiff Abbott does not abuse alcohol or use illegal drugs.

31. But for Hawaii law prohibiting the ownership of handgun magazines

which hold over ten rounds and his reasonable fear of criminal prosecution for

violating the prohibition, Plaintiff Abbott would immediately acquire and

continuously possess a handgun magazine over ten rounds within Hawaii for lawful

purposes, including in-home self-defense.

c. Kevin Lloyd L. Kacatin

32. Plaintiff Kacatin is employed in the financial field working with loan

deficiencies and debt mitigation.

33. Plaintiff Kacatin currently legally owns handguns which would accept

magazines that hold more than ten rounds.

34. Plaintiff Kacatin has never been convicted of a crime that would

disqualify him from firearms ownership under either Hawaii or federal law.

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35. Plaintiff Kacatin has never been diagnosed with a mental disorder that

would disqualify him from firearms ownership under Hawaii or federal law.

36. Plaintiff Kacatin does not abuse alcohol or use illegal drugs.

37. But for Hawaii law prohibiting the ownership of handgun magazines

which hold over ten rounds and his reasonable fear of criminal prosecution for

violating the prohibition, Plaintiff Kacatin would immediately acquire and

continuously possess a handgun magazine over ten rounds within Hawaii for lawful

purposes, including in-home self-defense.

d. Soleil Roache

38. Plaintiff Roache is employed by Active Self Protection

39. Plaintiff Roache currently legally owns handguns which would accept

magazines that hold more than ten rounds.

40. Plaintiff Roache has never been convicted of a crime that would

disqualify her from firearms ownership under either Hawaii or federal law.

41. Plaintiff Roache has never been diagnosed with a mental disorder that

would disqualify her from firearms ownership under Hawaii or federal law.

42. Plaintiff Roache does not abuse alcohol or use illegal drugs.

43. But for Hawaii law prohibiting the ownership of handgun magazines

which hold over ten rounds and her reasonable fear of criminal prosecution for

violating the prohibition, Plaintiff Roache would immediately acquire and

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continuously possess a handgun magazine over ten rounds within Hawaii for lawful

purposes, including in-home self-defense.

COUNT I

U.S. CONST., AMEND. II

44. Plaintiffs repeat and reallege the allegations of the preceding

paragraphs as if set forth herein.

45. H.R.S. § 134-8 prohibits handgun magazines which come standard with

or are commonly used in handguns that are “typically possessed by law-abiding

citizens for lawful purposes,” Heller, 554 U.S. at 624-25, throughout the United

States. Millions of handguns, including the most popular models, come stock from

the factory with magazines holding over ten rounds and the vast majority of states

do not restrict the capacity allowed to be possessed.

46. Defendant’s laws, customs and/or policies which ban handgun

magazines that hold over ten rounds serves no substantial government interest and

are not narrowly tailored.

47. As such, the ban violates the Plaintiffs’ and all other similarly situated

persons’ rights under the Second Amendment.

48. The ban is unconstitutional both facially and as-applied to Plaintiffs and

all other similarly situated persons.

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COUNT II

(DECLARATORY JUDGMENT)

49. Plaintiffs repeat and reallege the allegations of the preceding

paragraphs as if set forth herein.

50. The Declaratory Judgment Act provides: “In a case of actual

controversy within its jurisdiction, any court of the United States may declare the

rights and other legal relations of any interested party seeking such declaration,

whether or not further relief is or could be sought.” 28 U.S.C. 2201(a).

51. Absent a declaratory judgment, there is a substantial likelihood that

Plaintiffs will suffer irreparable injury in the future in the form of a violation of their

Second Amendment rights.

52. There is an actual controversy between the parties of sufficient

immediacy and reality to warrant issuance of a declaratory judgment.

53. This Court possesses an independent basis for jurisdiction over the

parties.

54. A judgment declaring that Defendant’s ban on handgun magazines over

ten rounds violates the Second Amendment facially and as-applied to Plaintiffs, and

as-applied to all other law-abiding persons, would be in the public interest.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiffs request that judgment be entered in their favor and

against Defendant as follows:

1. An order preliminarily and permanently enjoining Defendant, her

officers, agents, servants, employees, and all persons in active concert or

participation with them who receive actual notice of the injunction, from enforcing

H.R.S. § 134-8’s ban on handgun magazines which hold over ten rounds, both as-

applied and facially;

2. Declaratory relief that H.R.S. § 134-8’s ban on handgun magazines

which hold over ten rounds is unconstitutional facially and as applied to Plaintiffs

and as-applied to all other law-abiding persons;

3. Costs of suit, including attorney fees and costs pursuant to 42 U.S.C.

§1988;

4. Such other Declaratory relief consistent with the injunction as

appropriate; and

5. Such other further relief as the Court deems just and appropriate.

Dated: August 20, 2020.

Respectfully submitted,

/s/ Alan Beck

Counsel for Plaintiffs

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Exhibit "1"
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Case 1:20-cv-00360 Document 1-3 Filed 08/20/20 Page 1 of 2 PageID #: 16

Exhibit "2"
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 Case 1:20-cv-00360 Document 1-4 Filed 08/20/20 Page 1 of 2 PageID #: 18

Alan Alexander Beck

Law Office of Alan Beck
2692 Harcourt Drive
San Diego, CA 92123
(619) 905-9105
Hawaii Bar No. 9145
Alan.alexander.beck@gmail.com

Attorney for Plaintiffs

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF HAWAII

)
JON ABBOT, KEVIN LLOYD L. )
KACATIN, SOLEIL ROACHE )
)
)
Plaintiffs, )
) Civil Action No. _____________
v. )
)
CLARE E. CONNORS, in her )
Official Capacity as the Attorney General )
of the State of Hawaii )
)
)
Defendant. )
____________________________________)

DECLARATION OF SOLEIL ROACHE

COMES NOW, Soleil Roache, and states as follows:

1. I am an adult female resident of the State of Hawaii and reside in Honolulu

County and am competent to testify as to matters set forth in this declaration.

2. I am a citizen of the United States of America.

Exhibit "3"
Case 1:20-cv-00360 Document 1-4 Filed 08/20/20 Page 2 of 2 PageID #: 19
 Case 1:20-cv-00360 Document 1-1 Filed 08/20/20 Page 1 of 2 PageID #: 12
JS 44 (Rev. 12/12) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided 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 the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

John Abott; Kevin Kacatin ; Soleil Roache clare connors in her official capacity as the Attorney General of Hawaii

(b) County of Residence of First Listed Plaintiff Honolulu County of Residence of First Listed Defendant honolulu
(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)
Alan Beck 2692 Harcourt Drive 92123 San Diego CA

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
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4
of Business In This State

’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of 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 - of 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 of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 450 Commerce
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 460 Deportation
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 470 Racketeer Influenced and
’ 152 Recovery of Defaulted 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 of Overpayment Liability PERSONAL PROPERTY ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 850 Securities/Commodities/
of Veteran’s Benefits ’ 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 of Information
’ 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. Plaintiff Act/Review or Appeal of
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee or Defendant) Agency Decision
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party ’ 950 Constitutionality of
’ 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 of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’ 1 Original ’ 2 Removed from ’ 3 Remanded from ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation
(specify)
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
42 usc 1983
VI. CAUSE OF ACTION Brief description of cause:
Second Amendment challenge to Hawaii's ban on handgun magazines which hold more than ten rounds
VII. REQUESTED IN ’ 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: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
08/20/2020 /s/alan beck
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

 Case 1:20-cv-00360 Document 1-1 Filed 08/20/20 Page 2 of 2
JS 44 Reverse (Rev. 12/12) PageID #: 13

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided 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 the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, 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, noting
in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions 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 jurisdiction arises under the Constitution of the United States, an amendment
to 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. plaintiff or defendant code takes
precedence, 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, the
citizenship of the different 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 of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section 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, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.

V. Origin. Place an "X" in one of the six 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 filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of 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 of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box if you 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 JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.

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