Case 1:17-cv-00511-RBW Document 1 Filed 03/21/17 Page 1 of 14

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CHRISTINE LEVINSON, as Conservator for

ROBERT LEVINSON; CHRISTINE LEVINSON,
SUSAN LEVINSON BOOTHE, STEPHANIE
LEVINSON CURRY, SARAH LEVINSON
MORIARTY, SAMANTHA LEVINSON,
DANIEL LEVINSON, DAVID LEVINSON and
DOUGLAS LEVINSON,

Plaintiffs,

v. CIVIL ACTION NO.:

THE ISLAMIC REPUBLIC OF IRAN,

c/o Ministry of Foreign Affairs

Defendant.
/

COMPLAINT

1. Plaintiffs Robert Levinson, his wife Christine Levinson and their seven children,

Susan Levinson Boothe, Stephanie Levinson Curry, Sarah Levinson Moriarty, Samantha

Levinson, Daniel Levinson, David Levinson and Douglas Levinson (collectively the Levinson

family, the Levinsons or Plaintiffs) bring suit against the Islamic Republic of Iran (Iran)

under the Foreign Sovereign Immunities Act, 28 U.S.C. 1602 et seq (FSIA) for injuries

suffered by each of them as a result of Irans unlawful acts of hostage taking, torture and other

torts.

2. On March 9, 2007, Robert Levinson disappeared while visiting Kish Island, a

resort island that is a part of Iran and located in the Persian Gulf just off the Iranian mainland.

Three weeks after his disappearance an Iranian government news outlet, Press TV, announced

that he had been taken into custody by Iranian security authorities but was expected to be
 Case 1:17-cv-00511-RBW Document 1 Filed 03/21/17 Page 2 of 14

released shortly. Despite this report, Robert Levinson was not released and the Iranian

government began falsely denying any knowledge of his capture or whereabouts.

3. For the past ten years the Iranian government has held Robert Levinson captive

while at the same time denying any knowledge or involvement in the circumstances of his

capture. In order to maintain its false story, Iran has held Robert Levinson incommunicado. As

a result, for the last ten years he has had no contact with the outside world, including the

government of the United States and most importantly, his wife and seven children. The only

persons with whom Robert Levinson had contact since March of 2007 are his captors.

4. The government of the United States, the Levinson family and the United Nations

Human Rights Council have all pressed Iran to own up to the truth and to return Robert

Levinson. The Levinson family has employed Iranian counsel to seek any available legal

remedy, and the United States government has repeatedly pressed Iran for assistance and offered

to engage in whatever process was necessary to achieve that end. Christine Levinson,

accompanied by Daniel Levinson, traveled to Iran in December of 2007 to plead with the Iranian

government for her husbands release. Iran has repeatedly and falsely responded that they do not

know who is holding Robert Levinson. In a cynical effort to convince the government of the

United States and the Levinson family that it is others who are holding Robert Levinson, Iran has

arranged for extortion demands to be sent to the Levinson family, purportedly from some

unidentified terrorist group. These demands began with a series of emails to Levinsons family

and friends demanding changes in U.S. policy and threatening Levinsons life. This series of

emails began in August of 2007, but until November of 2010 none contained proof that the

source actually had access to Levinson and that he was still alive. This changed with the receipt

of two messages, one in November of 2010 and another in April of 2011. The first of these two

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messages was accompanied by a video of Levinson and the second by a series of photographs of

him. In the video he is dressed in what appears to be his own white collared shirt, now torn and

several sizes too large, and in a quivering voice pleads for help from the United States. In his

plea he states that he is not in good health. The video is attached to an email demanding

$3,000,000 and the release of certain named individuals and threatening to kill Robert Levinson

if their demands are not met. The Levinson family immediately replied with a message to the

sender of the email, but there was no response to their message. The persons whose release was

demanded could not be located and no instructions were ever received on how to deliver the

ransom. The second email message was received in April of 2011. It consisted of a series of five

photographs of Robert Levinson. In these photographs Robert Levinson has plainly lost a great

deal of weight, his hair is disheveled and he has a long beard. He is wearing an orange jump suit

comparable to those worn by prisoners in Guantanamo Bay and he is bound by chains. In each

photograph he holds a printed message pleading for help.

5. Experts from the FBI have concluded that the messages described above were part

of an Iranian attempt to create a false scenario that Robert Levinson was being held by some

entity, other than the Iranian government, so that Iran would not be held responsible for his

ultimate fate.

6. The threatening messages, along with the video and photographs described above,

were enormously disturbing to the Levinson family. They were intended to and did create

significant emotional trauma in the entire family.

7. In October of 2011, the Iranian government made quiet offers to the United States

that reflected their control over Robert Levinsons fate. In that month, the Iranian ambassador to

France, on very short notice asked for a meeting with representatives of an American religious

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organization that had prior ties with Iranian officials. The purpose of the meeting was to make a

back channel offer to the United States government. At the time, the International Atomic

Energy Agency (IAEA) was about to release a report on Irans nuclear program. This report

greatly concerned the Iranian government, which feared it would draw conclusions damaging to

Iran. It was largely this concern that led the Iranian ambassador to request a meeting. The

meeting took place at the Iranian ambassadors residence and was shortly followed by a second

meeting. In each meeting the Iranian ambassador outlined a series of demands by the Iranian

government, the most important of which was a postponement of the release date of the IAEAs

report. In both of the meetings, the Iranian ambassador told the American representatives that

Iran, in return for Americas agreement to their demands, was prepared to release Robert

Levinson. The Americans were asked to take this offer to their government, which they

promptly did. Despite this admission, the Iranian government has continued to deny publicly

any knowledge of Robert Levinsons situation.

8. Over the years of his captivity, there have been a series of meetings between

American officials concerned with Robert Levinsons fate and their Iranian counterparts. In

early 2011, Iranian representatives threatened to cut off discussions if the United States did not

issue a statement absolving Iran from Robert Levinsons disappearance. In various other

meetings and in messages sent through third-parties, the Iranian government has made it clear

that they would be able to arrange for Robert Levinsons release if the United States would

arrange for the return to Iran of an Iranian Revolutionary Guard general who had defected

from Iran after being involved in Irans nuclear programs. The general had defected just a few

weeks prior to Irans seizure of Robert Levinson.

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9. The Levinson family is aware, from multiple reports, that Iran routinely uses

physical and psychological torture in the questioning of its prisoners. Given this pattern, Robert

Levinsons circumstances and his appearance and actions in the hostage-related videos and

photographs described above, it is reasonable to believe that Iran has used various forms of

physical and psychological torture on Levinson in addition to those inherent in keeping him

incommunicado for ten years.

10. Iran has, for many years, established a pattern of seizing and holding hostages in

order to extract concessions from the hostages home country. That Robert Levinsons seizure is

a part of that pattern is reflected in Irans multiple attempts to use Robert Levinsons

imprisonment to extort concessions from the United States, and in the fact that Robert Levinson

was taken shortly after the defection of the Iranian general. These actions, and others, evidence

Irans intent to use Robert Levinson as a hostage to extract concessions from the United States.

11. To deprive a prisoner of any contact with his family or his homeland for ten years

constitutes psychological torture. To deprive the prisoners family of any contact with him as

well as any knowledge of his status, his whereabouts or his well-being is wanton cruelty. The

Levinson family has suffered grievously from these actions and continues to suffer.

THE PARTIES

12. Robert Levinson was, at the time of his seizure, a long-time resident of Florida.

He served as a federal law enforcement agent for the Drug Enforcement Administration and

Federal Bureau of Investigation for 28 years. After his retirement from the FBI he worked as a

private investigator, working for a wide range of private and public organizations. He has been

married to Christine Levinson since 1974 and together they have seven children. Until his

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disappearance in 2007, the Levinsons were a close knit and loving family with Robert Levinson

at its center.

13. Christine Levinson is a resident of Florida. She has been married to Robert

Levinson for 42 years. For the last ten years she and their seven children have worked tirelessly,

including traveling to Iran, to have her husband released and returned home. The circuit court of

Broward County, Florida has appointed Christine Levinson as Conservator for her husband. She

brings this suit both as Conservator on his behalf and on behalf of herself personally.

14. Susan Levinson Boothe, Stephanie Levinson Curry, Sarah Levinson Moriarty,

Samantha Levinson, Daniel Levinson, David Levinson and Douglas Levinson are the adult

children of Robert and Christine Levinson. They are a close and loving family. Like their

mother, they have each been involved for the last ten years in a desperate effort to locate and free

their father. They have repeatedly watched other hostages released when Iranian demands were

met, while their father remained held. They know that both physical and psychological torture is

routinely used by the Iranians. They have seen the death threats and they have seen the images

and video of their father pleading for his life. Each of them had strong emotional ties to their

father but, as a result of Irans actions, has been deprived of his love and companionship. For ten

years, he has missed all of the important family events, including the high school graduation of

Samantha and Douglas, the graduation from college of David, Samantha and Douglas, the birth

of three grandchildren (with two more on the way), the diagnosis of cancer, chemotherapy

treatment and recovery from cancer by his three year old grandson, Bobby (Robert Levinsons

namesake), as well as the weddings of his daughters Susan and Sarah and his son David. As a

result of his loss and their knowledge of his extraordinary suffering, they have each suffered

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severe emotional trauma. Susan, Daniel and David all reside in Florida. Stephanie lives in

Texas, Sarah in New Jersey, Samantha in New York and Douglas in Washington, D.C.

15. Robert Levinson has, for ten years, suffered physically and emotionally from his

cruel treatment. He has also suffered significant financial damage by virtue of his imprisonment.

JURISDICTION AND VENUE

16. This Court has jurisdiction pursuant to 28 U.S.C. 1330, 1331 and 1605A.

17. This action falls within the terrorism exception to sovereign immunity under the

FSIA, 29 U.S.C. 1605A(a)(1), which provides, in relevant part, that [a] foreign state shall not

be immune from the jurisdiction of courts of the United States . . . in any case . . . in which

money damages are sought against a foreign state for personal injury or death that was caused by

an act of torture . . . [or] hostage taking . . . if such act is engaged in by an official, employee, or

agent of such foreign state while acting within the scope of his or her office, employment, or

agency.

18. Under the terrorism exception to the FSIA, torture is defined to have the

meaning given . . . in section 3 of the Torture Victim Protection Act of 1991 (28 U.S.C. 1350

note). 28 U.S.C. 1605A(h)(7). The Torture Victim Protection Act defines torture as any act,

directed against an individual in the offenders custody or physical control, by which severe pain

or suffering (other than pain or suffering arising only from or inherent in, or incidental to, lawful

sanctions), whether physical or mental, is intentionally inflicted on that individual for such

purposes as obtaining from that individual or a third person information or a confession,

punishing that individual for an act that individual or a third person has committed or is

suspected of having committed, intimidating or coercing that individual or a third person, or for

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any reason based on discrimination of any kind. Pub. L. No. 102-256, 3(b)(1), 106 Stat. 73,

73 (1992), codified at 28 U.S.C. (note).

19. Seizing an individual in an effort to extract concessions from the United States,

and others, is hostage taking within the definition of the FSIA. E.g., Massie v. Govt of

Democratic Peoples Republic of Korea, 592 F. Supp. 2d 57, 67-69, 74 (D.D.C. 2008); Daliberti

v. Republic of Iraq, 146 F. Supp. 2d 19, 25 (D.D.C. 2001). A plaintiff need not show that the

hostage taker actually extracted such concessions, or even that it communicated its intent to the

United States, Simpson v. Socialist Peoples Libyan Arab Jamahiriya, 470 F.3d 356, 357 (D.C.

Cir. 2006) although in this case Defendant did both.

20. This suit seeks money damages against Iran and its agencies and instrumentalities

for injury and harm caused to the Plaintiffs by acts of terrorism, torture and hostage taking

against Plaintiffs.

21. These acts of terrorism, torture and hostage taking were perpetrated by officials,

members, agents and instrumentalities of Iran while acting within the scope of their official

capacities.

22. Plaintiffs are U.S. citizens and nationals of the United States within the meaning

of the FSIA, and were such at the time of the acts of torture and hostage taking alleged herein.

See 28 U.S.C. 1605A(a)(ii) (The court shall hear a claim under [the FSIA] if . . . the claimant

or the victim was, at the time of the act . . . occurred a national of the United States.).

23. Defendant Iran has, since January 19, 1984, been designated a state sponsor of

terrorism by the Secretary of State for purposes of section 6(j) of the Export Administration Act

of 1979, section 620A of the Foreign Assistance Act of 1961, and section 40 of the Arms Expert

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Control Act. Thus Defendant is a state sponsor of terrorism within the meaning of the FSIA. 1

See 28 U.S. C. 1605A(a)(2)(A)(i)(I) (The court shall hear a claim under [FSIA] if . . . the

foreign state was designated as a state sponsor of terrorism at the time the act . . . occurred[.].

Defendant Iran, and other responsible agencies or instrumentalities of the Government of Iran,

are each and collectively a foreign state within the meaning of the FISA. See 28 U.S.C.

1603.

24. Venue for a civil action against a foreign state lies in this Court pursuant to 28

U.S.C. 1391(f)(4) (venue is proper in the United States District Court for the District of

Columbia if the action is brought against a foreign state or political subdivision thereof).

COUNT ONE

Intentional Infliction of Emotional Distress

By Christine Levinson as Conservator for Robert Levinson

25. Plaintiffs incorporate by reference all prior paragraphs.

26. Beginning on or about March 9, 2007, and continuing through the date of filing of

this Complaint the Iranian government has held Robert Levinson captive. They have done so

without legal process and have attempted to hide their actions from his family and the outside

world.

27. They have prevented him from having any communication with his family other

than to plead for his life in video and photographs sent to his family. They have, for those ten

years, prevented him from engaging in any communication with persons other than his captors.

They have repeatedly and falsely denied any knowledge of or responsibility for his

disappearance. They have used him as a hostage to attempt to extort favorable concessions from

the United States government. They have engaged in both psychological and physical torture of

1
State Sponsors of Terrorism, U.S. Dept of State, http://www.state.gov/j/ct/list/c14151.htm (last visited Oct. 3,
2016).

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Robert Levinson. Their behavior is both cruel and cynical and constitutes torture and hostage

taking.

28. The result of Irans intentional and reckless actions has been to inflict severe

emotional distress on Robert Levinson.

29. Because Irans use of hostage taking and torture were calculated to and did create

severe emotional distress they are liable for the damage caused by that distress.

COUNT TWO

Property Loss By Christine Levinson as Conservator for Robert Levinson

30. Plaintiffs incorporate by reference all prior paragraphs.

31. Irans torture of Robert Levinson and their use of him as a hostage have caused

him significant financial damages. Such damages were the foreseeable and predictable result of

their holding him incommunicado for more than ten years.

32. Robert Levinsons damages include the loss of all income for the ten year period

he has been held captive.

33. Under the law, Iran is responsible for any property loss caused by the actions

described above.

COUNT THREE

Intentional Infliction of Emotional

Distress/Solatium for Christine Levinson

34. Plaintiffs incorporate by reference all prior paragraphs.

35. By holding Robert Levinson captive and incommunicado for more than ten years,

by sending to this family, threats to kill Robert Levinson and videos and photographs of him

pleading for help, by refusing to confirm whether he was dead or alive and his physical

condition, Iran intentionally and recklessly inflected extreme emotional distress on his wife,

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Christine Levinson. Christine Levinson has labored ceaselessly to find out what happened to her

husband. She has traveled to Iran where she met with Iranian officials. She has repeatedly met

with Irans ambassador to the United Nations. All of her contacts and pleas to Iran have been

met with cold, cynical and false denials of any complicity in Robert Levinsons condition.

Christine Levinson has been in a state of distress for ten years. She has had nightmares about his

torture. She has seen her large and loving family tormented by the loss of their husband and

father. She has received video and photographs of her plainly tormented husband pleading for

his life. She has received emails threatening to kill her husband if American policy did not

change.

36. All of Christine Levinsons distress is the direct and foreseeable result of Irans

actions and its use of torture and hostage taking. Iran is, therefore, responsible to her for her

distress.

COUNT FOUR

Property Loss For Christine Levinson

37. Plaintiffs incorporate by reference all prior paragraphs.

38. Irans treatment of Robert Levinson has forced Christine Levinson to become an

advocate for her husbands freedom. In that role, she has had to travel extensively to such places

as Iran, Washington D.C. and New York to meet with Iranian and American officials regarding

her husbands condition. She has also employed attorneys to help her husband. In addition to

losing her husbands income, Christine Levinson has had to expend significant amounts of

money in her campaign to have him freed. These expenditures and the loss of her husbands

income constitute financial losses compensable under the law.

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39. Because the expenditures and losses described above are the direct and

foreseeable result of Irans use of torture and hostage taking, Iran is responsible for these losses.

COUNTS FIVE, SIX, SEVEN, EIGHT, NINE, TEN AND ELEVEN

Intentional Infliction of Emotional Distress/Solatium For Susan Levinson Boothe

(Count Five), Stephanie Levinson Curry (Count Six), Sarah Levinson Moriarty
(Count Seven), Samantha Levinson (Count Eight), Daniel Levinson (Count Nine),
David Levinson (Count Ten) and Douglas Levinson (Count Eleven)

40. Plaintiffs incorporate by reference all prior paragraphs.

41. The Levinsons are a close and loving family. Each of the seven Levinson

children has been devastated by what has happened to their father. They have lived a nightmare

for more than ten years. They have seen the video and photographs of their loving father

pleading for his life while wrapped in chains. They have seen the emailed threats to kill him.

They have endured Irans refusal to provide any information on their father knowing that Iran

was holding him. They know that, in addition to psychological torture, Iran routinely uses

physical torture on its American prisoners. They have each lost the love and companionship of

their father.

42. As the direct and foreseeable result of Irans cruel and cynical actions, including

its use of torture and hostage taking, each of the children of Robert Levinson has suffered severe

emotional distress. Iran is, therefore, responsible for their distress.

REQUEST FOR RELIEF

Wherefore, Plaintiffs demand judgment against

Iran and respectively request the following relief

43. Plaintiffs incorporate by reference all prior paragraphs.

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44. Robert Levinson is entitled to compensatory damages for the intentional infliction

of emotional distress suffered as a result of Irans use of torture and hostage taking.

45. Robert Levinson is entitled to compensatory and consequential damages for the

financial losses he has suffered and will continue to suffer as a result of Irans use of torture and

hostage taking.

46. Christine Levinson, Susan Levinson Boothe, Stephanie Levinson Curry, Sarah

Levinson Moriarty, Daniel Levinson, Samantha Levinson, David Levinson and Douglas

Levinson are entitled to compensatory solatium damages for the intentional infliction and

emotional distress resulting from Irans use of torture and hostage taking.

47. Christine Levinson is entitled to compensatory and consequential damages for the

financial losses she has suffered as a result of Irans use of torture and hostage taking.

48. All Plaintiffs are entitled to aggravated damages for Irans cruelty, torture and

abuse.

49. All Plaintiffs are entitled to punitive damages under 28 U.S.C. 1605(A)(c)(4).

50. The Court should award Plaintiffs their full costs and attorneys fees as incidental

damages.

51. The Court should award such further relief as it deems just and proper.

PLAINTIFFS REQUEST TRIAL BY JURY.

Dated this the 21st day of March, 2017. Respectfully submitted,

/s/ James A. Byram, Jr.

DC Bar No. AL0001
jbyram@balch.com
Balch & Bingham, LLP
105 Tallapoosa Street, Suite 2000
Montgomery, AL 36104
(334) 269-3159 (Main)

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(334) 269-3115 (Facsimile)

Counsel for Plaintiffs

/s/ David L. McGee

David L. McGee
FL Bar No. 220000
dlm@beggslane.com
J. Nixon Daniel, III
FL Bar No. 228761
jnd@beggslane.com
Gregory R. Miller
FL Bar No. 284777
grm@beggslane.com
Beggs & Lane, RLLP
P.O. Box 12950
Pensacola, Florida 32591-2950
(850) 432-2451 (Main)
(850) 469-3331 (Facsimile)
Counsel for Plaintiffs (Pro Hac Vice
Applied For)

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that pursuant to local procedures as outlined in the Courts

Attorney Manual for Service of process on a Foreign Defendant, because the defendant in this
case is Iran, plaintiff need not attempt service pursuant to provisions 28 U.S.C. 1608(a)(1)-(3)
prior to requesting service under 1608(a)(4). In such circumstances, under 28 U.S.C.
1608(a)(4), the Clerk of the Court shall send two copies of the summons and complaint and a
notice of suit, together with a translation of each into the official language of the foreign state [in
this case, a Farsi translation], by any form of mail requiring a signed receipt, to be addressed and
dispatched by the clerk of the court to the Secretary of State in Washington, District of
Columbia, to the attention of the Director of Special Consular Services. The Secretary of State
shall then take steps to effect service through diplomatic channels.

Islamic Republic of Iran

c/o Ministry of Foreign Affairs
Khomeni Avenue, United Nations Street
Tehran, Iran

/s/ James A. Byram, Jr.

DC Bar No. AL0001
jbyram@balch.com
Balch & Bingham, LLP
Counsel for Plaintiffs

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 Case 1:17-cv-00511-RBW Document 1-1 Filed 03/21/17 Page 1 of 2
CIVIL COVER SHEET
JS-44 (Rev. 7/16 DC)
I. (a) PLAINTIFFS DEFENDANTS

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________ COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________
(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)

II. BASIS OF JURISDICTION III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR
(PLACE AN x IN ONE BOX ONLY) PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!

o 1 U.S. Government o 3 Federal Question

PTF DFT PTF DFT

Plaintiff (U.S. Government Not a Party)
o 2 U.S. Government o 4 Diversity
Defendant (Indicate Citizenship of
Parties in item III)
IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)
o A. Antitrust o B. Personal Injury/
Malpractice
410 Antitrust
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 Medical Malpractice
365 Product Liability
367 Health Care/Pharmaceutical
Personal Injury Product Liability
368 Asbestos Product Liability
Citizen of this State o1 o1 Incorporated or Principal Place o4 o4
of Business in This State
Citizen of Another State o2 o2 Incorporated and Principal Place o5 o5
of Business in Another State
Citizen or Subject of a
Foreign Country
o3 o3 Foreign Nation o6 o6
o C. Administrative Agency o D. Temporary Restraining
Review Order/Preliminary
Injunction
151 Medicare Act
Any nature of suit from any category
Social Security
may be selected for this category of
861 HIA (1395ff)
case assignment.
862 Black Lung (923)
863 DIWC/DIWW (405(g)) *(If Antitrust, then A governs)*
864 SSID Title XVI
865 RSI (405(g))
Other Statutes
891 Agricultural Acts
893 Environmental Matters
890 Other Statutory Actions (If
Administrative Agency is
Involved)

o E. General Civil (Other) OR o F. Pro Se General Civil

Real Property
210 Land Condemnation
220 Foreclosure
230 Rent, Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
Personal Property
370 Other Fraud
371 Truth in Lending
380 Other Personal Property
Damage
385 Property Damage
Product Liability
Bankruptcy Forfeiture/Penalty
422 Appeal 27 USC 158 625 Drug Related Seizure of 470 Racketeer Influenced
423 Withdrawal 28 USC 157 Property 21 USC 881 & Corrupt Organization
690 Other 480 Consumer Credit
Prisoner Petitions 490 Cable/Satellite TV
535 Death Penalty 850 Securities/Commodities/
540 Mandamus & Other Other Statutes Exchange
550 Civil Rights 375 False Claims Act 896 Arbitration
555 Prison Conditions 376 Qui Tam (31 USC 899 Administrative Procedure
560 Civil Detainee Conditions 3729(a)) Act/Review or Appeal of
of Confinement 400 State Reapportionment Agency Decision
430 Banks & Banking 950 Constitutionality of State
Property Rights 450 Commerce/ICC Statutes
820 Copyrights Rates/etc. 890 Other Statutory Actions
830 Patent 460 Deportation (if not administrative agency
840 Trademark 462 Naturalization review or Privacy Act)
Application
Federal Tax Suits 465 Other Immigration
870 Taxes (US plaintiff or
Actions
defendant)
871 IRS-Third Party 26 USC 7609
 Case 1:17-cv-00511-RBW Document 1-1 Filed 03/21/17 Page 2 of 2
o G. Habeas Corpus/ o H. Employment o I. FOIA/Privacy Act o J. Student Loan
2255 Discrimination
530 Habeas Corpus General 442 Civil Rights Employment 895 Freedom of Information Act 152 Recovery of Defaulted
510 Motion/Vacate Sentence (criteria: race, gender/sex, 890 Other Statutory Actions Student Loan
463 Habeas Corpus Alien national origin, (if Privacy Act) (excluding veterans)
Detainee discrimination, disability, age,
religion, retaliation)

*(If pro se, select this deck)* *(If pro se, select this deck)*

o K. Labor/ERISA o L. Other Civil Rights o M. Contract o N. Three-Judge

(non-employment) (non-employment) Court
110 Insurance
710 Fair Labor Standards Act 441 Voting (if not Voting Rights 120 Marine 441 Civil Rights Voting
720 Labor/Mgmt. Relations Act) 130 Miller Act (if Voting Rights Act)
740 Labor Railway Act 443 Housing/Accommodations 140 Negotiable Instrument
751 Family and Medical 440 Other Civil Rights 150 Recovery of Overpayment
Leave Act 445 Americans w/Disabilities & Enforcement of
790 Other Labor Litigation Employment Judgment
791 Empl. Ret. Inc. Security Act 446 Americans w/Disabilities 153 Recovery of Overpayment
Other of Veterans Benefits
448 Education 160 Stockholders Suits
190 Other Contracts
195 Contract Product Liability
196 Franchise

V. ORIGIN
o 1 Original o 2 Removed o 3 Remanded o 4 Reinstated o 5 Transferred o 6 Multi-district o 7 Appeal to o 8 Multi-district
Proceeding from State from Appellate or Reopened from another Litigation District Judge Litigation
Court Court district (specify) from Mag. Direct File
Judge

VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)

VII. REQUESTED IN CHECK IF THIS IS A CLASS DEMAND $ Check YES only if demanded in complaint
ACTION UNDER F.R.C.P. 23 YES NO
COMPLAINT JURY DEMAND:

VIII. RELATED CASE(S) (See instruction) If yes, please complete related case form
YES NO
IF ANY

DATE: _________________________ SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________

INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET 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 services 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. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed.
Listed below are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet.

I. COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, and 99999 if plaintiff is outside the United States.

III. CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.

IV. CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best
represents the primary cause of action found in your complaint. You may select only one category. You must also select one corresponding
nature of suit found under the category of the case.

VI. CAUSE OF ACTION: Cite the U.S. Civil Statute under which you are filing and write a brief statement of the primary cause.

VIII. RELATED CASE(S), IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from
the Clerks Office.

Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.
 Case 1:17-cv-00511-RBW Document 1-2 Filed 03/21/17 Page 1 of 2
28 USC 1608 Summons
12/11

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

)
Plaintiff )
)
v. ) Civil Action No.
)
)
Defendant )

SUMMONS IN A CIVIL ACTION

To: (Defendants name and address)

A lawsuit has been filed against you.

Within 60 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 or plaintiffs attorney, whose name and
address are:

If you fail to respond, judgment by default may be entered against you for the relief demanded in the
complaint. You also must file your answer or motion with the court.

ANGELA D. CAESAR, CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
 Case 1:17-cv-00511-RBW Document 1-2 Filed 03/21/17 Page 2 of 2
28 USC 1608 Summons (12/11) (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

I personally served the summons on the individual at (place)

on (date) ; or

I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individuals last known address; or

I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

I returned the summons unexecuted because ; or

Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:
Servers signature

Printed name and title

Servers address

Additional information regarding attempted service, etc: