Case 3:18-cv SB Document 1 Filed 08/22/18 Page 1 of 16

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1 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 1 of 16 Kristian Roggendorf, OSB # ksr@vf-law.com SW Boones Ferry Rd., Suite A Tel. (503) Of Attorneys for Plaintiff Doe 550 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON PORTLAND DIVISION JACK DOE 550, an individual proceeding under a pseudonym, v. Plaintiff, ROMAN CATHOLIC ARCHBISHOP OF PORTLAND IN OREGON, AND SUCCESSORS, A CORPORATION SOLE, an Oregon Corporation, d/b/a ARCHDIOCESE OF PORTLAND IN OREGON; and ARCHDIOCESE OF PORTLAND IN OREGON, an Oregon Corporation Case No. 3:18-cv (Sexual Battery of a Child; Intentional Infliction of Emotional Distress; Negligence) DEMAND FOR JURY TRIAL Defendants. Plaintiff alleges as follows: JURISDICTION AND VENUE 1. This Court has jurisdiction over claims against Defendant Roman Catholic Archbishop of Page 1

2 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 2 of 16 Portland in Oregon, and Successors, a Corporation Sole, an Oregon Corporation, d/b/a Archdiocese of Portland in Oregon for conduct by the Archdiocese agents prior to April 25, 2005, pursuant to 28 U.S.C. 1334(b) and paragraph of the Third Amended and Restated Joint Plan of Reorganization of Debtor, Tort Claimants Committee, Future Claimants Representative, and Parish and Parishioners Committee ( the Plan ). The Plan was confirmed by Hon. Elizabeth L. Perris in the Order Confirming Third Amended and Restated Joint Plan of Reorganization of Debtor, Tort Claimants Committee, Future Claimants Representative, and Parish and Parishioners Committee on April 17, 2007, in the United States Bankruptcy Court for the District of Oregon, Case Number elp11. Venue is proper pursuant to 28 U.S.C. 1409(a), together with the foregoing provision of the confirmed bankruptcy plan. COMMON ALLEGATIONS 2. Plaintiff Jack Doe 550 (hereinafter Plaintiff ) is an adult male citizen of the United States and an Oregon resident, born in the year Plaintiff is proceeding under a pseudonym pursuant to the accepted practices of the federal courts of the United States allowing those who have been victims of sexual assault and/or who fear reprisals from the particular litigation to commence cases under assumed names, so as to protect their identity. Plaintiff has reasonable fears over his identity being used publicly if used in the caption of this lawsuit. Plaintiff s identity is already known or will promptly be made known to Defendants, and they will not be hampered in their case by Plaintiff s use of a pseudonym or by redactions in documents submitted to this Court to maintain that anonymity. Page 2

3 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 3 of At the time of Plaintiff s abuse, Defendant Roman Catholic Archbishop of Portland in Oregon, and Successors, a Corporation Sole, an Oregon Corporation, d/b/a Archdiocese of Portland in Oregon, and its related entity the Archdiocese of Portland in Oregon, were Oregon corporations with principal places of business in Portland, Multnomah County, Oregon. Defendants merged in 1991, at which time the merged corporations became the Roman Catholic Archbishop of Portland in Oregon, and Successors, a Corporation Sole, and the Archdiocese of Portland in Oregon became the merged corporation s assumed business name. For ease of reference, all Defendants are collectively referred to hereinafter as the Archdiocese. 4. At all times relevant to this complaint, Fr. Cathal Brennan (hereinafter Fr. Cathal ) was a Roman Catholic priest incardinated in the Archdiocese and assigned by the Archdiocese to Holy Cross Parish and School, Portland, Oregon, where he served as a parish priest and parish administrator (i.e. pastor). At all times relevant to this complaint, Fr. Cathal was employed by, and an agent and servant of, the Archdiocese. During that employment and agency, Fr. Cathal provided ministerial services to Plaintiff, and was acting within the course and scope of his employment or agency in performing duties for and on behalf of the Archdiocese, including counseling Plaintiff, supervising Plaintiff during Mass while Plaintiff acted as an altar boy, and serving as priest to Plaintiff and his family. 5. At all times relevant to this complaint, Deacon James Creel (hereinafter Deacon Creel ) was a Roman Catholic deacon ordained in the Archdiocese and assigned by the Archdiocese to Holy Cross Parish and School, Portland, Oregon, where he served as a deacon and assistant to Fr. Page 3

4 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 4 of 16 Cathal. At all times relevant to this complaint, Deacon Creel was an agent and servant of the Archdiocese. During that agency, Deacon Creel provided ministerial services to Plaintiff, and was acting within the course and scope of his agency in performing duties for and on behalf of the Archdiocese, including counseling Plaintiff and supervising Plaintiff during Mass while Plaintiff acted as an altar boy. 6. At all times relevant to this complaint, Plaintiff was a minor parishioner and student at Holy Cross Church and School in North Portland ( Holy Cross ). Plaintiff was baptized Catholic, received first communion, and attended classes at Holy Cross between 1988 and Beginning in or around 1994, Fr. Cathal invited Plaintiff to spend the night the rectory at Holy Cross when Plaintiff s father would drive Plaintiff out of the family s home, supervised Plaintiff in Plaintiff s role as altar boy, and supervised Plaintiff in Plaintiff s performance of various chores and tasks around the Church, all as part of the priest s authorized interactions with parishioners. At some point between 1990 and 1993, Deacon Creel was allowed to work at Holy Cross as well. Once there, Deacon Creel would also allow Plaintiff to be in the rectory when Plaintiff experienced family troubles, supervise Plaintiff during Mass, and supervise Plaintiff in doing chores around the parish, all as part of the deacon s authorized interactions with parishioners. 7. Defendant Archdiocese empowered Fr. Cathal and Deacon Creel to perform all duties of a priest and deacon, respectively, including pastoral and religious services, education, spiritual, moral and ethical guidance, religious instruction, altar boy training, and other duties of parish priests, administrators, and deacons. The Archdiocese knew that as part of their respective duties Page 4

5 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 5 of 16 as priest and deacon, Fr. Cathal and Deacon Creel would be in positions of trust and confidence with children and their families, including Plaintiff in this case. Defendants retained the right to control the means, methods, and physical details of any authorized duties or actions performed by priests with faculties and ordained deacons operating within the geographic boundaries of the Archdiocese, including Fr. Cathal and Deacon Creel. The Archdiocese intended that Fr. Cathal and Deacon Creel act on its behalf and be subject to its control, and Fr. Cathal and Deacon Creel agreed to act under the direction of the Archdiocese as its agents. 8. At all times relevant to this complaint, the Archdiocese invited Plaintiff, his family, and all other members of the public to enter into a special relationship with the Roman Catholic Church through the Archdiocese, in part by inviting Plaintiff and his family to entrust the Church with their spiritual matters and encouraging Plaintiff to submit to the rules of the Church in exchange. At all times relevant to this complaint, one of the teachings of the Roman Catholic Church was a firm and consistent obedience to any instruction from a Roman Catholic priest, and a respect for and obedience to deacons. Plaintiff was raised with these beliefs, and they formed the basis for his relationship with Fr. Cathal and Deacon Creel in this case. In particular, the Archdiocese encouraged Plaintiff consistent with the Archdiocese s teachings on how children should act toward priests and deacons to respect, obey, and revere any ordained member of the Roman Catholic faith. 9. While acting as priest and deacon of the Archdiocese, respectively, and for the purpose of furthering their respective duties as priest and deacon, Fr. Cathal and Deacon Creel befriended Plaintiff, gained Plaintiff s trust and confidence as spiritual guides and as valuable and Page 5

6 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 6 of 16 trustworthy mentors, and counseled Plaintiff emotionally and spiritually when Plaintiff would be driven from his family home at a young age by an abusive father. This course of conduct is identified in this complaint under the term grooming. The grooming by Fr. Cathal and Deacon Creel included befriending Plaintiff and his brother, supervising Plaintiff as an altar boy, counseling and ministry to Plaintiff while allowing Plaintiff to stay overnight at the rectory, and showing pastoral love and affection to Plaintiff during the difficult times Plaintiff faced as a child. Defendant Archdiocese authorized, ratified, or acquiesced to Fr. Cathal and Deacon Creel allowing Plaintiff to spend time alone with the men at the Church, in furtherance of the duties of Fr. Cathal and Deacon Creel as agents of the Archdiocese. 10. From approximately 1993 through 1996, while Plaintiff was ages 11 to 14, Fr. Cathal and Deacon Creel acting within the course and scope of their agency and using the authority and respective positions of trust as priest and deacon for the Archdiocese, through grooming induced, directed, and forced Plaintiff to engage in various sexual acts with Fr. Cathal and Deacon Creel, independently on several separate occasions. 11. Specifically, Fr. Cathal engaged in sexual fondling of Plaintiff on at least three occasions and performed oral sex on Plaintiff on at least one occasion between 1993 or 1994 and 1996 while Plaintiff stayed in the rectory and on church or school grounds. Additionally, after Deacon Creel began to work at the Church, Deacon Creel sexually abused Plaintiff by performing oral sex on Plaintiff on at least one occasion in or about 1994 or Fr. Cathal s and Deacon Creel s grooming and interactions with Plaintiff were committed Page 6

7 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 7 of 16 or begun in direct connection with, and at least in part for the purposes of fulfilling the men s employment and/or agency with the Archdiocese; were committed within the time and space limits of their employment and/or agency; were done directly in the performance of their respective duties as parish priest or deacon; generally consisted of actions of a kind and nature which Fr. Cathal and Deacon Creel were required to perform; and were done at the direction of, and pursuant to, the power vested in them by the Archdiocese. Fr. Cathal and Deacon Creel used the grooming process and their authorized contact with Plaintiff to accomplish their acts of sexual abuse. The sexual abuse resulted from a progressive series of actions that began with and continued to involve both Fr. Cathal's performance of the ordinary and authorized duties of a priest and Deacon Creel s performance of the ordinary and authorized duties of a deacon, and the abuse occurred during occasions when Fr. Cathal and Deacon Creel had authority over Plaintiff or were authorized to interact with Plaintiff in their official positions as priest and deacon for the Archdiocese. 13. As a result of Fr. Cathal s and Deacon Creel s sexual abuse, molestation, breach of authority, trust and positions as authority figures to Plaintiff, Plaintiff has suffered a severe and debilitating emotional injury, pain and suffering, physical and emotional trauma, and permanent psychological damages, all to Plaintiff s noneconomic damages in the approximate amount of $6,000,000.00, the exact amount to be determined by the jury at trial. 14. As an additional result and consequence of Fr. Cathal s and Deacon Creel s sexual abuse, molestation, breach of authority, trust and positions as priest and deacon and authority figures to Plaintiff, Plaintiff has incurred and/or will incur in the future costs for counseling, psychological Page 7

8 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 8 of 16 and psychiatric medical treatment, all to Plaintiff s economic damages in the approximate amount of $250,000.00, the exact amount to be proven to and determined by the jury at trial. 15. Plaintiff is under age 40 at the time of the filing of this complaint, and never received notice of the Archdiocese s bankruptcy prior to 2016 or knew of any requirement to bring a claim prior to the claims bar date. FIRST CLAIM FOR RELIEF Sexual Battery of a Child/Respondeat Superior Against All Defendants 16. Plaintiff realleges and incorporates by reference paragraphs 1 through 15, above. 17. The separate molestation of Plaintiff by Fr. Cathal and Deacon Creel each constituted harmful or offensive contacts to Plaintiff s person. Plaintiff did not, and legally could not, consent to any sexual contact with Fr. Cathal or Deacon Creel. 18. Fr. Cathal s and Deacon Creel s performance of their agency duties on behalf of the Archdiocese, as described above, led to and resulted in the sexual abuse of Plaintiff as described in paragraphs 10 and 11, above. As a direct result of the sexual abuse, Plaintiff suffered the damages alleged in paragraphs 13 and 14, above. 19. Page 8

9 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 9 of 16 SECOND CLAIM FOR RELIEF Intentional Infliction of Emotional Distress/Respondeat Superior Against All Defendants 20. Plaintiff realleges and incorporates by reference paragraphs 1 through 19, above. 21. Fr. Cathal and Deacon Creel, while engaging in their ministry to and grooming of Plaintiff, knowingly and intentionally caused severe emotional distress to Plaintiff when they independently sexually abused Plaintiff. Plaintiff did, in fact, suffer severe emotional distress as a result of their respective abuse, and the sexual abuse of a child is beyond the bounds of all socially tolerable conduct. 22. Fr. Cathal s and Deacon Creel s performance of their agency duties on behalf of the Archdiocese led to and resulted in the sexual abuse of Plaintiff as described in paragraphs 10 and 11, above. 23. As a direct result of the sexual abuse, Fr. Cathal s and Deacon Creel s intentional infliction of emotional distress, and their breach of authority, trust, and position as authority figure to Plaintiff, Plaintiff suffered the damages alleged in paragraphs 13 and 14, above. THIRD CLAIM FOR RELIEF Negligence Against All Defendants 24. Plaintiff realleges and incorporates by reference paragraphs 1 through 23, above. Page 9

10 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 10 of Defendant Archdiocese created a special relationship with Plaintiff by inviting Plaintiff to form a trust relationship with its agents, Fr. Cathal and Deacon Creel. As part of this relationship, the Archdiocese had a duty to inform Plaintiff of reasonably foreseeable known dangers in forming a relationship with its agent. Alternatively to forming a special relationship, Defendant Archdiocese created a dangerous condition by allowing Deacon Creel to be in contact with minors when, as alleged on information and belief, Defendant knew that Deacon Creel had sexually abused other persons prior to allowing him to reside at the rectory. In fact, Deacon Creel was convicted in November of 1995 of multiple counts of sexual abuse in Multnomah County, Oregon, for abuse dating as far back as On information and belief, Plaintiff s abuse by Creel occurred after Defendant possessed knowledge of Creel s sexual abuse of another individual or individuals, and allowed Creel to operate at the parish unsupervised despite this knowledge. In a second alternative to the formation of a special relationship, Defendant Archdiocese had a duty to warn or remedy all non-obvious, known or foreseeable, unreasonable risks of physical harm and unsafe conditions on its own property, and given that knowledge of the risk posed by Deacon Creel alleged on information and belief, the Archdiocese had a duty to warn minors at Holy Cross about him. In the third alternative, Deacon Creel posed an unreasonable risk of harm to minors at Holy Cross, and a reasonable person in Defendant Archdiocese s position would warn of the risk due to the likelihood of harm, the severity of the possible harm, the lack of any significant financial burden involved in warning about Deacon Creel, and Defendant s position as owner of a church open to the public. Defendant Archdiocese had a duty to warn all those who interacted with Deacon Creel at Holy Cross based on the Archdiocese s knowledge of the danger posed by Creel in particular, in addition to the Page 10

11 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 11 of 16 foreseeability garnered through the Archdiocese s unique awareness of the risk of sexual abuse posed by child molesting agents of the Church, gleaned over the prior several decades as described below. 26. Prior to Fr. Cathal s and Deacon Creel s sexual abuse of Plaintiff, the Archdiocese had learned and were aware that a significant number of their priests were child molesters or were inclined to commit child molestation, and that those agents used their position in the Church to complete their molestation of children, as follows: A. By the 1950s, and certainly by 1990, the Archdiocese was aware of a systemic danger of child molestation by its priests. In 1957 and certainly by 1990, the Archdiocese was aware that Fr. Maurice Grammond had abused dozens of boys over multiple postings throughout the Archdiocese in the preceding decades, with several documented reports of abuse between 1957 and In 1955 and certainly by 1990, the Archdiocese knew that Fr. Rocco Perone had abused a number of boys at St. Philip Neri Catholic Church before he was forced to leave Oregon in By the late 1960s, the Archdiocese knew that Fr. Thomas Laughlin had molested perhaps a dozen children, and by 1984 knew that Laughlin was a convicted child molester who had used his position in the Church to molest children. By the 1960s and certainly by 1990, the Archdiocese knew that Fr. Aldo Orso-Manzonetta had molested boys for years and had continued to allow them to spend the night in the rectory with him. By 1990, the Archdiocese also knew that many of its other priests had often engaged in similar sexual contact with minors because of numbers of other reports of child abuse involving priests and religious in the Archdiocese, as well as based on the interaction by and between the Archdiocese of Portland and other dioceses within the Catholic Church and the Catholic hierarchy. The Archdiocese kept Page 11

12 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 12 of 16 extensive records on all such reports and complaints regarding priests in the archdiocese in a secured filing system. B. Clerical abuse of children was a problem in the Catholic Church generally, and known to the Catholic hierarchy including Defendant Archdiocese though the problem was never discussed with the laity. For instance, the need to protect children from molestation was evident in 1917, when Church policy (the Code of Canon Law) was promulgated that forbade sexual contact between clerics and children. Another provision required priests to inform their bishop of reports that other priests had engaged in sexual contact with children. Adhering to these policies was considered a mandatory part of employment with the Church. In 1922, De modo procedendi in causis sollicitationis ("The Manner of Proceeding in Cases of Solicitation") was published by the Holy See's Congregation of the Holy Office and was distributed to bishops worldwide. It described procedures for the ecclesiastical prosecution of priests who solicited sexual contact from parishioners, and required strict secrecy, including from the victim. In 1962, Instructio de Modo Procedendi in Causis Sollicitationis ("Instructions on the Manner of Proceeding in Cases of Solicitation," also known as "the 1962 Vatican protocol"), Title V, was distributed to bishops worldwide, setting forth procedures for processing clerics who violated the prohibition against solicitation for sexual purposes. Included in the 1962 Vatican protocol was a section that addressed sexual contact with children. As with the 1922 directive, strict secrecy was imposed by the 1962 Vatican protocol. In 1983, the Church issued revised policy directives, making the sexual abuse of a child by a priest into an internal crime. Policy at this time obligated a bishop to investigate allegations of child abuse. Failure to observe the mandatory application of canons itself violated Church policy. All of these rules were enacted to protect children entrusted to the care of the Church, and the Archdiocese was required to follow these canons to Page 12

13 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 13 of 16 ensure the protection of children in the care of the Archdiocese. 27. Despite the Archdiocese s knowledge of Deacon Creel s past sexual abuse of others, and despite all of the Church s and this Archdiocese s knowledge of the dangers of sexual abuse of children by priests, the Archdiocese did nothing to warn Plaintiff or his family about the danger of ordained agents of the Church taking sexual liberties with children, nor did it protect Plaintiff from such dangers by removing Deacon Creel from ministry or by closely monitoring his activities with minors after allowing him to work at Holy Cross. Given the prevalence of its child abuse reports and knowledge by the late-1960s, it was reasonably foreseeable by the 1990s that, absent warnings or other precautions, the class of children who were interacting with ordained church leaders not to mention staying in the rectory alone with ordained individuals faced a danger of being sexually molested. 28. The Archdiocese s failure to warn and/or protect Plaintiff caused or were substantial contributing factors in his abuse. Because of the duration and consistency of child molestation in the Archdiocese, the Archdiocese's knowing failure to warn of the danger of abusive priests and of Deacon Creel in particular, to establish or enforce guidelines to minimize this danger, or to otherwise protect children created a foreseeable risk of harm to the safety of children interacting with agents of the Archdiocese. Plaintiff was a member of the class of individuals to be protected by a warning, protective measures, the removal or isolation of Creel, or the close monitoring of Creel. These measures would have prevented some or all of Fr. Cathal s and Deacon Creel s molestation of Plaintiff. Page 13

14 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 14 of The Archdiocese was negligent in one or more of the following particulars: A. In allowing Deacon Creel to remain at the rectory even after they knew of his propensity to sexually abuse individuals; B. In permitting Fr. Cathal or Deacon Creel to have young boys spend private time with them individually on Holy Cross parish premises, particularly in allowing or condoning Plaintiff spending nights at the rectory; C. In failing to properly supervise Deacon Creel after learning of his propensity to sexually abuse individuals; and F. In failing to notify or warn the parents, students, and parishioners of Holy Cross, or other Archdiocesan facilities and entities, or the North Portland community at large after learning of Deacon Creel s propensity to sexually abuse individuals. 30. As a direct and proximate cause of the Archdiocese's failure to warn about, establish guidelines concerning child abuse, or otherwise protect children from the danger posed by child molesting agents of the Church, and Deacon Creel in particular, Plaintiff suffered the sexual molestation alleged in paragraphs 10 and 11, above. 31. As a direct and foreseeable consequence of the Archdiocese s negligence, Plaintiff has suffered economic and non-economic damages as detailed in paragraphs 13 and 14, above. 32. Defendant Archdiocese knew that by allowing Deacon Creel to work at Holy Cross, he would pose a risk of sexual molestation to minors who attended Holy Cross church and school. Page 14

15 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 15 of 16 In allowing Deacon Creel to work at the rectory without any warning to minors or adequate supervision of Creel, Defendant Archdiocese showed extraordinary disregard of or indifference to known or highly probable risks to others, including Plaintiff. Defendants thereby acted with malice or a reckless and outrageous indifference to a highly unreasonable risk of harm and with a conscious indifference to the health, safety and welfare of Plaintiff. Plaintiff is therefore entitled to punitive damages against Defendants in the amount of $10,000, JURY DEMAND 33. Plaintiff demands trial by jury, pursuant to 28 U.S.C DEMAND FOR JUDGMENT 34. WHEREFORE, if Plaintiff demands judgment against Defendant Archdiocese as follows: 1. For non-economic damages in the estimated amount of $6,000,000.00, the actual amount to be determined by the jury; 2. For economic damages in the estimated amount of $250,000.00, the actual amount to be determined by the jury. 3. If successful on Plaintiff s Third Claim for Relief, punitive damages in the amount of $10,000,000.00, the actual amount to be determined by the jury; / / / / / / / / / / / / Page 15

16 Case 3:18-cv SB Document 1 Filed 08/22/18 Page 16 of Plaintiff s costs and disbursement incurred herein; and 4. Any other relief the Court deems just and equitable. DATED this 22nd day of August, s/ Kristian Roggendorf Kristian Roggendorf, OSB # ksr@vf-law.com Phone: (503) Of Attorneys for Plaintiff Doe 550 Page 16

17 S 44 (Rev. 08/18) Case 3:18-cv SB Document 1-1 Filed 08/22/18 Page 1 of 1 CIVIL COVER SHEET (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) I. (a) PLAINTIFFS, an individual proceeding under a pseudonym (b) (EXCEPT IN U.S. PLAINTIFF CASES) (c) (Firm Name, Address, and Telephone Number) II. BASIS OF JURISDICTION (Place an X in One Box Only) DEFENDANTS Defendant Roman Catholic Archbishop of Portland in Oregon, and Successors, a Corporation Sole, an Oregon Corporation; and Archdiocese of Portland in Oregon Multnomah County, OR (IN U.S. PLAINTIFF CASES ONLY) (If Known) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff (For Diversity Cases Only) and One Box for Defendant) PTF DEF PTF DEF (U.S. Government Not a Party) or and (Indicate Citizenship of Parties in Item III) V. ORIGIN (Place an X in One Box Only) VI. CAUSE OF ACTION VII. REQUESTED IN : VIII. RELATED CASE(S) IF ANY FOR OFFICE USE ONLY (specify) (Do not cite jurisdictional statutes unless diversity) 28 U.S.C. 1334(b) Child Sexual Abuse by Priest CLASS ACTION DEMAND $, (See instructions): Hon. Elizabeth L. Perris /s/ Schwabe Williamson & Wyatt 1211 SW 5th Ave., Suite 1900 Portland, OR IV. NATURE OF SUIT (Place an X in One Box Only) Click here for: Nature of Suit Code Descriptions. CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES PERSONAL INJURY PERSONAL INJURY 422 Appeal 28 USC False Claims Act 423 Withdrawal 376 Qui Tam (31 USC 28 USC (a)) 400 State Reapportionment PROPERTY RIGHTS 410 Antitrust 820 Copyrights 430 Banks and Banking 830 Patent 450 Commerce 835 Patent - Abbreviated 460 Deportation New Drug Application 470 Racketeer Influenced and LABOR 840 Trademark Corrupt Organizations PERSONAL PROPERTY SOCIAL SECURITY 480 Consumer Credit 861 HIA (1395ff) 485 Telephone Consumer 862 Black Lung (923) Protection Act 863 DIWC/DIWW (405(g)) 490 Cable/Sat TV 864 SSID Title XVI 850 Securities/Commodities/ 865 RSI (405(g)) Exchange 890 Other Statutory Actions 891 Agricultural Acts REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS FEDERAL TAX SUITS 893 Environmental Matters Habeas Corpus: 870 Taxes (U.S. Plaintiff 895 Freedom of Information or Defendant) Act 871 IRS Third Party 896 Arbitration 26 USC Administrative Procedure Act/Review or Appeal of IMMIGRATION Agency Decision Other: 950 Constitutionality of State Statutes 6 Multidistrict Litigation - Transfer JURY DEMAND: 8 Multidistrict Litigation - Direct File Bkry. # elp11

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