Free COMPLAINT - District Court of Delaware - Delaware

Case 1:99-mc-09999

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PAULA MCCLELLAN, : : : : : : : : : : : :

C.A. No. ______________

Plaintiff, v. JPMORGAN CHASE & CO., a Delaware Corporation, and JPMORGAN CHASE BANK, N.A., Defendants.

Trial by Jury Demanded

COMPLAINT AND NOW comes Plaintiff, by and through the undersigned counsel, and files this Civil Action Complaint averring as follows: I. 1. INTRODUCTION

The instant action has been initiated to redress violations by Defendants JPMorgan

Chase & Co. and JPMorgan Chase Bank, N.A. of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, the Equal Pay Act, and other applicable federal and state law. II. 2. JURISDICTION AND VENUE

The Court may maintain subject matter jurisdiction over the instant case in

accordance with 28 U.S.C. § 1331 because it arises under the laws of the United States. 3. The Court may properly maintain personal jurisdiction over Defendants because

Defendants' contacts with this state and this judicial district are sufficient for the exercise of jurisdiction over Defendants to comply with traditional notions of fair play and substantial justice, satisfying the standard set forth by the United States Supreme Court in International Shoe Co. v. Washington, 326 U.S. 310 (1945) and its progeny.

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4.

Pursuant to 28 U.S.C. § 1391(b)(1) and (b)(2), venue is properly laid in this judicial

district because the acts and/or omissions giving rise to the claims set forth herein occurred in this judicial district and because Defendants reside in and conduct business in the District of Delaware. III. 5. PARTIES

All of the allegations contained in the foregoing paragraphs of this Complaint are

incorporated by reference herein as if the same were set forth at length. 6. above. 7. Defendant JPMorgan Chase & Co. is a Delaware a corporation. Its registered agent Plaintiff is an individual of African-American descent with an address as set forth

for service of process in Delaware is CT Corp., which is located at 1209 Orange Street, Wilmington, DE 19801 8. Defendant JPMorgan Chase & Co. is a leading global financial services firm with

assets of $1.6 trillion. 9. At all times relevant herein, Defendant JPMorgan Chase & Co. acted through its

agents, servants and employees, each of whom was in the scope of his or her employment at all times relevant herein. 10. Defendant JPMorgan Chase & Co. operates in over 50 countries and employs more

than 170,000 people. 11. Defendant JPMorgan Chase Bank, N.A. is a subsidiary of Defendant JPMorgan Chase

& Co. Its registered agent for service of process in Delaware is CT Corp., which is located at 1209 Orange Street, Wilmington, DE 19801.

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12.

Defendant JPMorgan Chase Bank, N.A. is

a national banking institution with

branches in 17 states. 13. Defendants are each "employers" within the meaning of Title VII of the Civil Rights

Act of 1964 because they are engaged in an industry affecting commerce and because they maintain or maintained fifteen (15) or more employees for each working day in each of twenty (20) or more weeks in the current or preceding calendar year. 14. Upon information and belief, because of their interrelation of operations, common

ownership or management, centralized control of labor relations, common ownership or financial controls, and other factors, Defendants are sufficiently interrelated and integrated in their activities, labor relations, ownership and management that they may be treated as a single employer of Plaintiff for purposes of the instant action. IV. 15. EXHAUSTION OF ADMINISTRATIVE REMEDIES

All of the allegations contained in the foregoing paragraphs of this Complaint are

incorporated by reference herein as if the same were set forth at length. 16. Plaintiff has satisfied the procedural and administrative requirements for proceeding

under the Title VII of the Civil Rights Act of 1964 as follows: a. In or about March of 2007 and May of 2007, Plaintiff filed timely charges of discrimination with the Equal Employment Opportunity Commission (EEOC); b. The EEOC issued a Notice of Right to Sue to Plaintiff on or about January 2, 2008; c. The instant action is timely because it is filed within 90 days of the receipt of the aforementioned notice.

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V. 17.

OPERATIVE FACTS

All of the allegations contained in the foregoing paragraphs of this Complaint are

incorporated by reference herein as if the same were set forth at length. 18. 19. Plaintiff is an African American female. Plaintiff holds a Master of Business Administration degree and a Bachelor of Science

degree in Finance. 20. At all times relevant herein, Plaintiff worked for Defendants as a project analyst at

their location in the Morgan Christiana Center in Newark, DE 19713. 21. At the time she was employed with Defendants as a project analyst, Plaintiff was the

only minority in a department of Caucasian females. 22. During her employment with Defendants as a project analyst, Plaintiff was subjected

to a hostile environment based upon her race (African American) by agents of Defendants, including but not limited to vice-president Robert Bowley (Caucasian). 23. Bowley deliberately prevented Plaintiff from doing her work, harassed Plaintiff as a

result of her race, and disregarded reasonable requests from Plaintiff for more information to complete the work he had assigned her, thereby creating a hostile work environment for Plaintiff. 24. During her time as a project analyst for Defendants, Plaintiff worked out of

Defendants' Delaware office and traveled once a week to Defendants' office at 270 Park Avenue in New York. 25. It was made clear to Plaintiff by Defendants that she was required to be the Delaware

location "spy" on a large SAP Conversion project. 26. Plaintiff objected to this because it would hinder her relationships with some of the

key Vice Presidents and Project Managers in the Delaware office.

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27.

On or about October 18th and 19th of 2006, Plaintiff requested clarification on several

requests made of her by Bowley and Bowley refused same. 28. At this time, Plaintiff had held her current position for only four weeks and had

simply sought information she required in order to fulfill her duties. 29. Bowley became frustrated with Plaintiff and verbally abused her when she sought

clarification as aforesaid and implied, through his responses to Plaintiff's questions, that she, as a black woman, was incapable of understanding the information he gave her. 30. As a result of Bowley's hostility, Plaintiff suffered extreme anxiety, panic attacks,

and severe stomach pain. 31. 2006. 32. Upon information and belief, Plaintiff was paid less for her work in Bowley's Plaintiff was constructively terminated from Defendants' employ on November 20,

department than similarly-situated male employees with equal or less experience and/or credentials. 33. Plaintiff's salary was not even increased when she first accepted Defendants' offer of

the Project Analyst Position. 34. Plaintiff worked with male peers in New York and Delaware who, upon information

and belief, were earning more than her, even though she had 12 years of experience, a Master of Business Administration degree, and a Bachelor of Science degree in Finance. 35. Plaintiff also worked with two management service analysts who were making more

than her despite the fact that they had just graduated from college in May of 2006.

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COUNT I TITLE VII VIOLATIONS (RACE DISCRIMINATION, RACIALLY-MOTIVATED HARASSMENT, RACIALLY-MOTIVATED TERMINATION OF EMPLOYMENT, AND RETALIATION) 36. All of the allegations contained in the foregoing paragraphs of this Complaint are

incorporated by reference herein as if the same were set forth at length. 37. The foregoing actions by Defendants constitute unlawful discrimination against

Plaintiff on the basis of her race (African-American). 38. Defendants by and through their agents, harassed and belittled Plaintiff because of her

race (African-American) and constructively terminated her employment as a result thereof. 39. After the termination of Plaintiff's employment and the filing of an EEOC charge by

Plaintiff, Defendants also retaliated against her by engaging in efforts to "collect" monies from her which were not owed to Defendants. These efforts are ongoing and constitute actionable post-employment retaliation. 40. As a result of Defendants' unlawful discrimination, Plaintiff has suffered damages as

set forth herein. COUNT II TITLE VII/EQUAL PAY ACT VIOLATIONS (SEX DISCRIMINATION AND DISPARATE TREATMENT/COMPENSATION BASED ON SEX) 41. All of the allegations contained in the foregoing paragraphs of this Complaint are

incorporated by reference herein as if the same were set forth at length. 42. The foregoing actions by Defendants constitute unlawful discrimination against

Plaintiff on the basis of her sex (female). 43. Defendants by and through their agents, paid Plaintiff less than similarly-situated

males performing the same or similar work.

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COUNT III VIOLATIONS OF 42 U.S.C. § 1981 44. All of the allegations contained in the foregoing paragraphs of this Complaint are

incorporated by reference herein as if the same were set forth at length. 45. At all times relevant herein, Plaintiff maintained or sought to maintain a contractual

relationship with Defendants. 46. At all times relevant herein, Defendants acted by and through their agents, servants,

and employees to intentionally discriminate against Plaintiff as a result of her race (AfricanAmerican) and thereby deny her the benefits of the contractual relationship she had entered or sought to enter with Defendants. 47. actions. AD DAMNUM CLAUSE/PRAYER FOR RELIEF WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against Defendants and that it enter an Order providing that: A. Defendants are to be permanently enjoined from discriminating against Plaintiff on any basis forbidden by Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 1981, and any other applicable federal and state law. B. Defendants are to be prohibited from continuing to maintain their illegal policy, practice or custom of discriminating against employees based on their race and sex and are to be ordered to promulgate an effective policy against such discrimination and to adhere thereto; C. Defendants are to compensate Plaintiff, reimburse Plaintiff and make Plaintiff whole for any and all pay and benefits Plaintiff would have received had it not Plaintiff has suffered the aforesaid damages as a direct result of Defendants' unlawful

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been for Defendants' illegal actions, including but not limited to back pay, front pay, salary, pay increases, bonuses, travel, medical and other benefits, training, promotions, pension, seniority, and loss of future earning capacity. Plaintiff

should be accorded those benefits illegally withheld from the date she first suffered discrimination at the hands of Defendants until the date of verdict; D. Plaintiff is to be awarded actual damages, as well as damages for the pain, suffering and humiliation caused to her by Defendants' actions; E. Plaintiff is to be awarded punitive damages as permitted by applicable law, in an amount believed by the Court or trier of fact to be appropriate to punish Defendants for its willful, deliberate, malicious and outrageous conduct and to deter Defendants or other employers from engaging in such misconduct in the future; F. Plaintiff is to be accorded any and all other equitable and legal relief as the Court deems just, proper and appropriate; G. Plaintiff is to be awarded the costs and expenses of this action and reasonable legal fees as provided by applicable federal and state law.

Respectfully submitted, MARTIN D. HAVERLY, ATTORNEY AT LAW By: /s/ Martin D. Haverly Martin D., Haverly, Esquire Two East Seventh Street, Suite 201 Wilmington, DE 19801 DE Bar No. 3295 [email protected] (302) 654-2255

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OF COUNSEL: TIMOTHY M. KOLMAN AND ASSOCIATES By: /s/ Timothy M. Kolman Timothy M. Kolman, Esquire (Pro Hac Vice to be filed) 225 North Flowers Mill Road Langhorne, PA 19047 PA Bar No. 51982 [email protected] (215) 750-3134

April 1, 2008

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Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons

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Filed 04/01/2008

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UNITED STATES DISTRICT COURT
for the

District of Delaware
Paula McClellan
Plaintiff
)

v.
Morgan Chase & Co. and JP Morgan Bank, N.A.
Defendant

) ) ) )

Civil Action No.

Summons in a Civil Action To: (Defendant's name and address)
JP Morgan Chase & Co. c/o CT Corp. 1209 Orange Street Wilmington, DE 19801

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not counting the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are:
Martin D. Haverly Two East 7th St., Suite 201 Wilmington, DE 19801

If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. Name of clerk of court Date:
Deputy clerk's signature (Use 60 days if the defendant is the United States or a United States agency, or is an officer or employee of the United States allowed 60 days by Rule 12(a)(3).)

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AO 440 (Rev. 03/08) Civil Summons

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Proof of Service

I declare under penalty of perjury that I served the summons and complaint in this case on , by: (1)personally delivering a copy of each to the individual at this place, ; or (2)leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3)delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4)returning the summons unexecuted to the court clerk on My fees are $ for travel and $ . for services, for a total of $
0.00

0.00

.

Date:
Server's signature

Printed name and title

Server's address

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons

Document 39-3

Filed 04/01/2008

Page 1 of 2

UNITED STATES DISTRICT COURT
for the

District of Delaware
Paula McClellan
Plaintiff
)

v.
Morgan Chase & Co. and JP Morgan Bank, N.A.
Defendant

) ) ) )

Civil Action No.

Summons in a Civil Action To: (Defendant's name and address)
JP Morgan Bank, N.A. c/o CT Corp. 1209 Orange Street Wilmington, DE 19801

A lawsuit has been filed against you. Within 20 days after service of this summons on you (not counting the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are:
Martin D. Haverly Two East 7th St., Suite 201 Wilmington, DE 19801

If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. Name of clerk of court Date:
Deputy clerk's signature (Use 60 days if the defendant is the United States or a United States agency, or is an officer or employee of the United States allowed 60 days by Rule 12(a)(3).)

Case 1:99-mc-09999
AO 440 (Rev. 03/08) Civil Summons

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Filed 04/01/2008

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Proof of Service

I declare under penalty of perjury that I served the summons and complaint in this case on , by: (1)personally delivering a copy of each to the individual at this place, ; or (2)leaving a copy of each at the individual's dwelling or usual place of abode with who resides there and is of suitable age and discretion; or (3)delivering a copy of each to an agent authorized by appointment or by law to receive it whose name is ; or (4)returning the summons unexecuted to the court clerk on My fees are $ for travel and $ . for services, for a total of $
0.00

0.00

.

Date:
Server's signature

Printed name and title

Server's address

OJS 44 (Rev. 3/99)

Case 1:99-mc-09999

Document 39-4 Filed CIVIL COVER SHEET04/01/2008

Page 1 of 2

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 THE REVERSE OF THE FORM.)

I. (a)

PLAINTIFFS
Paula McClellan

DEFENDANTS
JP Morgan Chase & Co. and JP Morgan Chase Bank, N.A.

(b) County of Residence of First Listed Plaintiff (EXCEPT IN U.S. PLAINTIFF CASES)

County of Residence of First Listed (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE LAND INVOLVED.

(c) Attorney's (Firm Name, Address, and Telephone Number)
Martin D. Haverly Two East 7th Street, Suite 201 Wilmington, DE 19801

Attorneys (If Known)

II. BASIS OF JURISDICTION
G 1 U.S. Government Plaintiff 2 U.S. Government Defendant

(Place an "X" in One Box Only)

III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an "X" in One Box for Plaintiff
(For Diversity Cases Only)
PTF DEF and One Box for Defendant) PTF DEF

X 3 Federal Question (U.S. Government Not a Party) G 4 Diversity (Indicate Citizenship of Parties in Item III)

Citizen of This State

G 1

G 1

Incorporated or Principal Place of Business In This State

G 4

G4

G

Citizen of Another State

G 2

G 2

Incorporated and Principal Place G 5 of Business In Another State Foreign Nation G 6

G5

Citizen or Subject of a Foreign Country

G 3

G 3

G6

IV. NATURE OF SUIT
CONTRACT G G G G G G G G G G G 110 Insurance 120 Marine 130 Miller Act 140 Negotiable Instrument 150 Recovery of Overpayment & Enforcement of Judgment 151 Medicare Act 152 Recovery of Defaulted Student Loans (Excl. Veterans) 153 Recovery of Overpayment of Veteran's Benefits 160 Stockholders' Suits 190 Other Contract 195 Contract Product Liability REAL PROPERTY G G G G G G 210 Land Condemnation 220 Foreclosure 230 Rent Lease & Ejectment 240 Torts to Land 245 Tort Product Liability 290 All Other Real Property G G G G G G G G G

(Place an "X" in One Box Only)
TORTS 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 CIVIL RIGHTS G 441 Voting X 442 Employment G 443 Housing/ Accommodations G 444 Welfare G 440 Other Civil Rights PERSONAL INJURY G 362 Personal Injury-- Med. Malpractice G 365 Personal Injury -- Product Liability G 368 Asbestos Personal Injury Product Liability PERSONAL PROPERTY G 370 Other Fraud G 371 Truth in Lending G 380 Other Personal Property Damage G 385 Property Damage Product Liability PRISONER PETITIONS G 510 Motions to Vacate Sentence Habeas Corpus: 530 General 535 Death Penalty 540 Mandamus & Other 550 Civil Rights 555 Prison Condition G G G FORFEITURE/PENALTY G G G G G G G G 610 Agriculture 620 Other Food & Drug 625 Drug Related Seizure of Property 21 USC 881 630 Liquor Laws 640 R.R. & Truck 650 Airline Regs. 660 Occupational Safety/Health 690 Other LABOR G G G 710 Fair Labor Standards G Act G 720 Labor/Mgmt. Relations G G 730 Labor/Mgmt.Reporting G & Disclosure Act 740 Railway Labor Act 790 Other Labor Litigation 791 Empl. Ret. Inc. Security Act G G BANKRUPTCY 422 Appeal 28 USC 158 423 Withdrawal 28 USC 157 PROPERTY RIGHTS G G G 820 Copyrights 830 Patent 840 Trademark SOCIAL SECURITY 861 HIA (1395ff) 862 Black Lung (923) 863 DIWC/DIWW (405(g)) 864 SSID Title XVI 865 RSI (405(g)) FEDERAL TAX SUITS G 870 Taxes (U.S. Plaintiff or Defendant) G 871 IRS--Third Party 26 USC 7609 G G G G G G G G G G G G G G G OTHER STATUTES 400 State Reapportionment 410 Antitrust 430 Banks and Banking 450 Commerce/ICC Rates/etc. 460 Deportation 470 Racketeer Influenced and Corrupt Organizations 810 Selective Service 850 Securities/Commodities/ Exchange 875 Customer Challenge 12 USC 3410 891 Agricultural Acts 892 Economic Stabilization Act 893 Environmental Matters 894 Energy Allocation Act 895 Freedom of Information Act 900Appeal of Fee Determination Under Equal Access to Justice

G G G G G

G 950 Constitutionality of State Statutes G 890 Other Statutory Actions

V. ORIGIN
X 1 Original G 2 Removed from Proceeding State Court

(PLACE AN "X" IN ONE BOX ONLY)

G 3 Remanded from Appellate Court

G 4 Reinstated or Reopened

G 5 Transferred from
another district (specify)

G 6 Multidistrict G 7 Judge from Magistrate Litigation Judgment

Appeal to District

VI. CAUSE OF ACTION

(Cite the U.S. Civil Statute under which you are filing and write brief statement of cause. Do not cite jurisdictional statutes unless diversity.) This action redresses violations of Title VII of the Civil Rights Act of 1964, 42 U.S. Section 1981 and The Equal Pay Act.

VII. REQUESTED IN COMPLAINT: VIII. RELATED CASE(S) IF ANY
DATE FOR OFFICE USE ONLY RECEIPT #

G

CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23 (See instructions):

DEMAND $

CHECK YES only if demanded in complaint: X Yes G No JURY DEMAND: DOCKET NUMBER

JUDGE
SIGNATURE OF ATTORNEY OF RECORD

AMOUNT

APPLYING IFP

JUDGE

MAG. JUDGE

JS 44 Reverse (Rev. 3/99)

Case 1:99-mc-09999

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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.C.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; 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 IV below, is sufficient to enable the deputy clerk or the statistical clerks 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 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 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. Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judge's decision. VI. VII. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. 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 dollar amount (in thousands of dollars) 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.