;st!

J/ 0

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 1 of 13

:., IL COVER SHEET

JS 44 (Rev. 12/12)

The JS 44 civil cover sheet and the informal

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, ap
y the Judicial Conference of the United States in September 1974, is reqwred for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT ?_AGE OF THIS FORM)

DEFENDANTS

I. (a) PLAINTIFFS

MICHAEL DRUCTOR, BRIAN HILLS.

TONETIE PRAY
(b) County of Residence of First Listed Plaintiff
DELAWARE
(EXCEPT JN U.S. PLAI
FF CASES)

PA

County of Residence of First Listed Defendant

(JN U.S. PLAINTIFF CASES ONLY)
NOTE:

IN LAND CONDEMNATION CASES, USE THE LOCATION OF

THE TRACT OF LAND INVOLVED.

Attorneys (If Known)

Stephen T. O'Hanlon, O'Hanlon Law Firm, 15

Philadelphia, PA 19102. (267) 546-9066.

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box for Plaintiff
0 I

(For Diversity Cases Only)

PTF
Citizen of This State
0 I

Federal Question
(U.S. Government Not a Party)

U.S. Government
Plaintiff

Diversity
(Indicate Citizenship of Parties in Item Ill)

0 2 U.S. Government
Defendant

and One Box for Defendant)

PTF
DEF
Incorporated or Principal Place
0 4
0 4
of Business In This State

DEF

Citizen of Another State

0 2

Incorporated and Principal Place

of Business In Another State

0 5

Citizen or Subject of a
Forei nCoun

0 3

Foreign Nation

0 6

IV NATURE OF SUIT (Place an "X" in One Box Only)

l: ~ ; ;:::,:. CON:rRAeT~ .'c

0
0
0
0
0
0
0
0
0
0
0
0

...

.ORN'.fTtTREZPENAl!J!F.Wfl

ll 0 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovel)' of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovel)' of Defaulted
Student Loans
(Excludes Veterans)
153 Recovel)' of Overpayment
of Veteran's Benefits
160 Stockholders' Suits
190 Other Contract
195 Contract Product Liability
196 Franchise

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0

PERSONAL INJURY
0 365 Personal Injury Product Liability
0 367 Health Care/
Phannaceutical
Personal Injury
Product Liability
0 368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
0 3 70 Other Fraud
0 371 Truth in Lending
0 3 80 Other Personal
Property Damage
0 385 Property Damage
Product Liability

0 625 Drug Related Seizure

of Property 21 USC 881
0 690 Other

0 710 Fair Labor Standards

Act

0 720 Labor/Management
Relations

0 740 Railway Labor Act

0 751 Family and Medical
Leave Act

0 790 Other Labor Litigation

";;JU;AI;:;pROPERTY"'1:!\l[dli! "'"'"''1'71E\RIGHTS~1!0'.\% lWPRISONER,;pE'fl11fONSi!. 0 791 Employee Retirement
/"'

Vii

PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers'
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Maloractice

2 IO Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectrnent
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

1!!1440 i:er Civil Rights

0 441 otmg
0 442 mployment

~Housing/

02 Removed from

roceeding

State Court

~CAUSE OF ACTION

0 530 General
0 535 Death Penalty

0
0
0
0

0
0
0
0
"'"""'<RORE oc.:RIGH:rS7l<;1;;:lil 0
0 820 Copyrights
0
0 830 Patent
0
0 840 Trademark
0
11>.'Jll'SlE
0
0 861 HIA (1395f!)
0
0 862 Black Lung (923)
0 863 DIWC/DIWW (405(g)) 0
0 864 SSID Title XVI
0
0 865 RSI (405(g))
0
0

375 False Claims Act

400 State Reapportionment
410 Antitrust
430 Banks and Banking
0
450 Commerce
460 Deportation
4 70 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutol)' Actions
891 Agricultural Acts
893 Environmental Matrers
895 Freedom of Information
Act
0 896 Arbitration
il!i~!FED1'RA'llll'IIAiXSSUJTSiillJrti 0 899 Administrative Procedure
0 870 Taxes (U.S. Plaintiff
Act/Review or Appeal of
or Defendant)
Agency Decision
0 871 IRS-Third Party
0 950 Constitutionality of
7609
26
State Statutes

0 423 Withdrawal

28 USC 157

fL'.'.5,k'!:1fK:tJIMMIG~lF.lQNlit~ltI1~lffi~

Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement

Remanded from
Appellate Court

o 422 Appeal 28 use 158

use

Sentence

Accommodations
Amer. w/Disabilities Employment
0 446 Amer. w/Disabilities Other
0 448 Education

!'"
V.. (S RIGIN (Place an '"X'' in One Box Only)
)I{ I .firiginal

Income Security Act

Habeas Corpus:

0 463 Alien Detainee

0 510 Motions to Vacate

!t$l#J,;t;i$itlB~:NKRUlrr:EMl:&?~~r~: l:c{C"";0.0llHER!lSTAFtroTES~ 1'~1

0 462 Naturalization Application

0 465 Other Immigration
Actions

0 4 Reinstated or

0 5 Transferred from

Reopened

0 6 Multidistrict

Another District
(specifY)

Litigation

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional staJutes unless diversity):

42 USC 1983; 1985(3).

Brief description of cause:

Improper prosecution and free speech violations.

VII. REQUESTED IN
0
COMPLAINT:
VIII. RELATED CASE(S)
IFANY
DATE

CHECK IF THIS IS A CLASS ACTION

UNDER RULE 23, F.R.Cv.P.

/"""'\
CHECK YES only ifr~ in complaint:

DEMAND$

200,000.00

JURY DEMAND: 1

(See instn1ctions):
WDGE

10/07/2015
FOR OFFICE USE ONLY
RECEIPT#

AMOUNT

APPL YING IFP

--

DOCKET NUMBER

SIGNATURE OF ATTORNEY OF RECORD

JUDGE

)!I

0 No

~ - 7 2015'

MAG.JUDGE

~r1

bAM

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 2 of 13

15

UNITEDSTATESDISTRICTCOURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA assignment to appropriate calendar.

5510

DESIGNATION FORM to be used by counsel to indicate the category of the case for the purpose of

__,/i,._;_/~?___..._fa_~~/-<f."-&--..7_ _ _A_z.,p
__C~--;;)t---C_o_~_W_~_"IV_:J-+--~-~---/-f,_'fl_2_S_ _ __
Address ofDefendant:_ __,,.,7."'"""~2~2.~--S~/Ji_'lf_lll_t:._E
__J;_7'_~"-e_e_7-+-_-C_o_,,_At,,__~~~-~r~'1f
___~/~~-~l-Z~--.
~I..)'~
,.1?'9-.
)
Place of Accident, Incident or Transactlon: _ _ _ _~---.....,,.,~(U._s_e~R-e_v_e-rs_e_S_i_d_e_F:_o_r_A_d'""'d,-it-io_n_a..,.l..,.Sp_a_c_e,...)----------------------

Address of Plaintiff: _

Does this civil action involve a nongovernmental corporate party with any parent corporation and any publicly held corporation owning I 0% or more of its stock?
(Attach two copies of the Disclosure Statement Form in accordance with Fed.R.Civ.P. 7.l(a))
Does this case involve multidistrict litigation possibilities?

YesD

NoD

YesD

NoD

RELATED CASE, IF ANY:

Case Number: _ _ _ _ _ _ _ _ _ _ _ _ Judge _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Date T e r m i n a t e d : - - - - - - - - - - - - - - - - - - - Civil cases are deemed related when yes is answered to any of the following questions:
I. Is this case related to property included in an earlier numbered suit pending or within one year previously terminated action in this court? . /

YesD
Noi!f
2. Does this case involve the same issue of fact or grow out of the same transaction as a prior suit pending or within one year previously terminated
action in this court?
/
YesD
Nol!!'
3. Does this case involve the validity or infringement of a patent already in suit or any earlier numbered case pending or within one year previo~
terminated action in this court?

YesD

4. Is this case a second or successive habeas corpus, social security appeal, or prose civil rights case filed by the same individual?
YesD
CIVIL: (Place
A

NoiB"

No~

t/ in ONE CATEGORY ONLY)

Federal Question Cases:

B. Diversity Jurisdiction Cases:

1. o Indemnity Contract, Marine Contract, and All Other Contracts

1.

D Insurance Contract and Other Contracts

2.

2.

3. o Jones Act-Personal Injury

3.

D Assault, Defamation

4. o Antitrust

4.

D Marine Personal Injury

5.

D Motor Vehicle Personal Injury

6.

D Other Personal Injury (Please specify)

D FELA

Airplane Personal Injury

7.

D Products Liability

8.

D Products Liability -

9.

D All other Diversity Cases

10. o Social Security Review Cases

Asbestos

(Please specify)

11. D All other Federal Question Cases

ARBITRATION CERTIFICATION

/. p l'~tN
f(ChecdkdApphropbriate c_afytegory)
---,-------------'7~'7----~ counse1o recor o ere y cert1 :

rsuant to Local Civil Rule 53.2, Section 3(c)(2), that to the best of my knowledge and belief, the damages recoverable in this civil action case exceed the sum of
00.00 exclusive of interest and costs;
o Relief other than monetary damages is sought.
DATE:

10/-:r/2.01r
Attorney-at-Law
Attorney I.D.#
NOTE: A trial de novo will be a trial by jury only if there has been compliance with F.R.C.P. 38.

I certify that, to my knowledge, the within case is not related to any case now pending or within one year previously terminated action in this court

except as noted above.

DATE:

11

201-~2<1-

/1/ ~1r
Attorney-at-Law

CIV. 609 (5/2012)

Attorney I.D.#

OCT - 7 2015'

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 3 of 13

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
CASE MANAGEMENT TRACK DESIGNATION FORM
CIVIL ACTION

v.
#eH/fu
/Jlt.11 c rrre - 4 ,,,6'NO.
8 If 1/1111 Ht'-4
In accordance with the Civil Justice Expense and Delay Reduction Plan of this court, counsel for
plaintiff shall complete a Case Management Track Designation Form in all civil cases at the time of
filing the complaint and serve a copy on all defendants. (See 1:03 of the plan set forth on the reverse
side of this form.) In the event that a defendant does not agree with the plaintiff regarding said
designation, that defendant shall, with its first appearance, submit to the clerk of court and serve on
the plaintiff and all other parties, a Case Management Track Designation Form specifying the track
to which that defendant believes the case should be assigned.
SELECT ONE OF THE FOLLOWING CASE MANAGEMENT TRACKS:
(a) Habeas Corpus - Cases brought under 28 U.S.C. 2241 through 2255.

( )

(b) Social Security - Cases requesting review of a decision of the Secretary of Health
and Human Services denying plaintiff Social Security Benefits.

( )

(c) Arbitration - Cases required to be designated for arbitration under Local Civil Rule 53.2.

( )

(d) Asbestos - Cases involving claims for personal injury or property damage from
exposure to asbestos.

( )

(e) Special Management - Cases that do not fall into tracks (a) through (d) that are
commonly referred to as complex and that need special or intense management by
the court. (See reverse side of this form for a detailed explanation of special
management cases.)
(f) Standard Management - Cases that do not fall into any one of the other tracks.

Date

1/-r/211r

2J1 S<t:I
Telephone

'lo

Jlt-/1161

T IW'1N~ lu11~7)~

Attorney-at-law

21r.

511-. /?fl

FAX Number

'?':A>'ernf /6f y

Attorney for

.flt've

e 01,,#11 J,. ~IVI krl!J. U.,,,,

E-Mail Address

(Civ. 660) 10/02

OCT - 7 2015

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 4 of 13

IN THE UNITED STA

S
CT COURT FOR THE
EASTERN DISTRICT OF PENNSYLVANIA
Civil No. _ _ __...i.._l~~

TONETTE PRAY,
Plaintiff,

v.
LIEUTENANT MICHAEL DRUCTOR
-andPOLICE CHIEF BRIAN HILLS,
Defendants.

COMPLAINT AND JURY DEMAND

Plaintiff, Tonette Pray, by and through her undersigned counsel, The O'Hanlon Law
Firm, P.C., hereby demands a trial by jury and complains against the above-captioned
Defendants as follows:

Statement of Claim and Jurisdiction

1.

This is an action for money damages brought pursuant to 42 U.S.C. 1983 and

1988, and the Fourth and Fourteenth Amendments to the United States Constitution against
Defendant Police Officers, in their individual capacities and official/policymaker capacity as to
Defendant Brian Hills.

These Defendants also sought to deprive Plaintiff of the rights and

privileges afforded by 42 U.S.C. 1983 in a conspiracy that is conspiracy is violative of 42

U.S.C. 1985(3). Jurisdiction is based upon 28 U.S.C. 1331 and 1343.
2.

It is alleged that Defendants violated Plaintiffs Fourth and Fourteenth

Amendment rights to the United States Constitution by initiating and perpetuating a malicious
and selective prosecution and by abridging Plaintiffs free speech and political process

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 5 of 13

participation rights protected by the First Amendment to the United States Constitution and
incorporated via the Fourteenth Amendment.
3.

It is further alleged that these Constitutional violations were committed as a result

of direct actions, policies, customs, omissions, and deliberate indifference of policymaker and
Chief of Police, Brian Hills.
Parties

4.

Tonette Pray (hereinafter "Plaintiff') is a resident of Colwyn Borough and

Delaware County and is a citizen of the United States and the Commonwealth of Pennsylvania.
Plaintiff was also a member of the Borough Council of Colwyn Borough at all relevant times.
5.

Defendant Police Officers, Dructor and Hills (hereinafter "Defendant Police

Officers" or "Defendant Dructor" or "Defendant Hills") were at all times relevant to this
Complaint duly appointed and acting as police officers, acting under color of law, to wit, under
color of the statutes, ordinances, regulations, policies, customs, and usages of the
Commonwealth of Pennsylvania and/or Colwyn Borough.
6.

Defendant Hills is also chief of police of Colwyn Borough and was, at all relevant

times, a policymaker for said Borough.

Facts

7.

On January 9 and March 20, 2014, there were council meetings at council

chambers in Colwyn Borough.

8.

According to Defendant Dructor, police were present because council meetings

can be tumultuous.
9.

Defendant Hills instructed Defendant Dructor to write criminal citations relating

to Plaintiffs use of bad language at these council meetings.

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 6 of 13

10.

Other individuals at these meetings including Mayor Mike Blue, Paul Meuser,

and Martha Van Auken also used bad language at these council meetings. Citations were not
issued for these individuals and criminal proceedings were not initiated by Defendants against
these individuals. Plaintiff is African-American. These other individuals are white.
11.

Plaintiff was charged with Disorderly Conduct pursuant to 18 Pa. Cons. Stat.

5503(a)(3) as of docket numbers MJ-32237-NT-0000045-2014 and MJ-32237-NT-00005202014. Under threat of police summons and a potential bench warrant, Plaintiffs liberty was
constrained on two occasions when she had to attend Magisterial District Court relating to these
charges. Plaintiff also had to retain private counsel.
12.

Plaintiff was adjudicated guilty by Magisterial District Judge on May 13, 2014.

13.

Plaintiff appealed these matters to the Court of Common Pleas of Delaware

County as of docket number CP-23-SA-0000632-2014 and a trial proceeded before the

Honorable Kathrynann W. Durham in Media on August 12, 2014.
14.

Judge Durham dismissed the charges brought against Plaintiff because of

selective enforcement. CP-23-SA-0000632-2014, Notes of Testimony, 8/12/2014, at 29-30.

15.

At all times during the events described above, Defendant Police Officers were

engaged in a joint venture. The individual Defendant Police Officers assisted each other in
performing the various actions described used the authority of their office to each other during
the said events.
16.

As a direct and proximate result of the said acts of Defendant Police Officers,

Plaintiff suffered the following injuries and damages:

a.

Violation of her Constitutional rights under the First, Fourth, and Fourteenth

Amendments to the United States Constitution;

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 7 of 13

b.

Loss of physical liberty;

c.

Emotional injury;

d.

Malicious prosecution.

e.

Selective prosecution.

17.

The actions violated the following clearly established and well-settled federal

constitutional rights of Plaintiff:

a.

Unwarranted abridgment of speech and participation in the political process;

b.

Malicious prosecution.

c.

Selective prosecution.

18.

Defendant Hills by his policies, acts, omissions, lack of supervision, and willful

indifference, allows the perpetuation of the present actions complained of herein despite multiple
civil complaints.

This has been caused by, inter alia, inadequate supervision, inadequate

investigation of police complaints, and the actual initiation of conspiratorial unconstitutional

practices detailed herein by Defendant Hills, acting as an individual and policymaker.
Causes of Action
COUNT ONE: 42 U.S.C. 1983 - FOURTH AMENDMENT AND
FOURTEENTH AMENDMENT MALICIOUS PROSECUTION
AGAINST ALL DEFENDANTS
19.

Paragraphs 1 through 18 are incorporated herein by reference as though fully set

20.

Defendants Dructor and Hills initiated a meritless criminal proceeding against

forth.

Plaintiff, the criminal proceeding ended in Plaintiffs favor when the charges were dismissed due
to the fact that Defendants Dructor and Hills initiated the criminal proceedings without probable
cause to target Plaintiff based on her race and because Plaintiff was instrumental in the process

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 8 of 13

that led to Defendant Hills' termination because of his alleged racism, Defendants Dructor and
Hills acted maliciously and for a purpose other than bringing Plaintiff to justice and they did so
in order to racially intimidate and retaliate against Plaintiff because of her on-going political
activity, and Plaintiff suffered deprivation of liberty when she was obligated to appear at court
under police summons and under threat of a bench warrant being issued.
21.

Defendant Hills is additionally liable as a policymaker because he implemented

policies and procedures that allow police officers to implement baseless criminal proceedings
without censure and individuals, such as Plaintiff, are subjected to baseless criminal proceedings
intended only to harass and bully.
22.

The judicial determination based upon a finding of selective enforcement upholds

the contention that the prosecution initiated by Defendants was done so for nefarious reasons
intended to harass Plaintiff because of her race and/or political activity.
23.

Plaintiff should, therefore, be compensated for the violation of her Fourth

Amendment rights not to suffer malicious prosecution.

COUNT TWO: 42 U.S.C. 1983 - FOURTEENTH
AMENDMENT, EQUAL PROTECTION CLAUSE,
SELECTIVE ENFORCEMENT AGAINST ALL
DEFENDANTS

24.

Paragraphs 1 through 23 are incorporated herein by reference as though fully set

25.

Defendants, acting under color of law, selectively and adversely treated Plaintiff

forth.

differentially compared with others similarly situated individuals.

To wit, other individual

politicians such as Paul Meuser and Martha Van Auken used bad language at the council
meetings at issue but none of these individuals was issued with a citation or summons by
Defendants.

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 9 of 13

26.

Defendants initiated and continued the selective treatment based on Plaintiffs

race and her prior involvement in the decision to terminate Defendant Hills based upon prior
allegation of racism. Defendants' actions were malicious and based upon bad faith with intent to
injure. This was indicated by the fact that Defendant Hills smirked at Plaintiff following the
latter council meeting and Defendant Hills informed Plaintiff that she would be receiving a
surprise in the mail. By initiating criminal charges against Plaintiff, Defendants also sought to
injure Plaintiff by putting her through the criminal justice process and undermining Plaintiffs
position on the council.
27.

Defendant Hills is additionally liable as a policymaker because he implemented

policies and procedures that allow police officers to implement baseless criminal proceedings
without censure and individuals, such as Plaintiff, are subjected to baseless criminal proceedings
intended only to harass and bully.
28.

The judicial determination based upon a finding of selective enforcement upholds

the contention that the prosecution initiated by Defendants was done so for nefarious reasons
intended to harass and injure Plaintiff because of her race and/or political activity.
29.

Plaintiff should, therefore, be compensated for the violation of her Fourteenth

Amendment rights not to be subjected to selective prosecution.

COUNT THREE: 42 U.S.C. 1983 - FIRST AMENDMENT
AND FOURTEENTH AMENDMENT FREE SPEECH AND
POLITICAL PARTICIP A TI ON VIOLATIONS AGAINST
ALL DEFENDANTS

30.

Paragraphs 1 through 29 are incorporated herein by reference as though fully set

forth.

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 10 of 13

31.

Defendant Officers initiation of the prosecution of Plaintiff subsequent the council

meetings infringed upon Plaintiffs free speech and political participation rights in that Plaintiff
was participating as a council member in council meetings.
32.

Defendants speech activity was protected in that it was political speech which was

part of political debate and was aimed at Paula Brown, former Borough Manager, who was
accused of racially targeting Plaintiff and other council members and generally undermining
Plaintiff and other council members.
33.

Plaintiff was also subjected to disparate and retaliatory enforcement in relation to

her speech and political participation activity for the reasons outlined above.
34.

Defendant Hills is additionally liable as a policymaker because he implemented

policies and procedures that allow police officers to violate First Amendment rights without
censure.
35.

Plaintiff should, therefore, be compensated for the violation of her First

Amendment rights.
COUNT FOUR: 42 U.S.C. 1985(3) - CONSPIRACY TO
DEPRIVE PLAINTIFF OF HER PREVIOUSLYARTICULATED RIGHTS AGAINST ALL DEFENDANTS
36.

Paragraphs 1 through 35 are incorporated herein by reference as though fully set

3 7.

Defendant Dructor testified under oath that Defendant Hills told Defendant

forth.

Dructor to initiate the criminal proceedings against Plaintiff and, following the conversation,
Defendant Dructor did the same.
38.

Defendant Hills smirked at Plaintiff and said that Plaintiff womd be getting a

surprise in the mail, the criminal summonses.

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 11 of 13

39.

The criminal proceedings initiated constitute not only malicious and selective

prosecution in that they were baseless and targeted, said criminal proceeding were also initiated
in a conspiratorial manner between Defendants in an attempt to retaliate against Plaintiff and
ensure that Plaintiff was no longer critical of Defendants. The conspiracy entered into and
executed by Defendants was designed to frustrate Plaintiffs rights guaranteed by the
Constitution of the United States of America.

The conspiracy injured Plaintiff by causing

emotional distress associated with the criminal prosecution of Plaintiff.

Prayer for Relief

WHEREFORE, Plaintiff requests that this Court:

a.

Award compensatory and emotional mJury damages to Plaintiff and against

Defendants;
b.

Award costs of this action to Plaintiff;

c.

Award reasonable attorney's fees to Plaintiff;

d.

Award punitive damages to Plaintiff;

e.

Award such other and further relief as this Court may deem appropriate.

The O'Hanlon Law Firm, P.C.

STEPHEN T. O'HANLON, ESQUIRE

DATE: October 7, 2015

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 12 of 13

The O'Hanlon Law Firm, P.C.

BY: Stephen T. O'Hanlon, Esquire
Attorney for Plaintiff
PA Bar ID# 208428
2 Penn Center, Suite 1850
1500 John F. Kennedy Boulevard
Philadelphia, PA 19102
Tel: (267) 546-9066
Fax: (215) 567-1998
steve@ohanlonlawfirm.com

Case 2:15-cv-05510-GAM Document 1 Filed 10/07/15 Page 13 of 13

Demand for Jury Trial

Plaintiff hereby demands a jury trial.

The O'Hanlon Law Firm, P.C.

STEPHEN T. O'HANLON, ESQUIRE

DATE: October 7, 2015

The O'Hanlon Law Firm, P.C.
BY: Stephen T. O'Hanlon, Esquire
Attorney for Plaintiff
PA Bar ID # 208428
2 Penn Center, Suite 1850
1500 John F. Kennedy Boulevard
Philadelphia, PA 19102
Tel: (267) 546-9066
Fax: (215) 567-1998
steve@ohanlonlawfirm.com

10