-------------------

l

IN THE UNITED STATES DISTRICT COURT I /

FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

RAYMOND RANDALL 

PlaintitT JURY TRIAL 

vs. DEMAND 

THE CITY OF PHILADELPHIA, 

PHILADELPHIA POLICE OFFICER REYNOLDS, 

BADGE NUMBER 4268; PHILADELPHIA POLICE 

OFFICER LICIARDELLO, BADGE NUMBER 4383; C.A.#04- e..- \I - 4(fp '3 

PHILADELPHIA POLICE OFFICER CUJDIK, 

BADGE NUMBER 1574; PHILADELPHIA POLICE 

OFFICER MCGEE, BADGE NUMBER 4504, 

PHILADELPHIA POLICE OFFICER MCCUE, J:" Ii.. BADGE NUMBER 6628, individually and as police 

officers for the City ofPhiladelphia 8fp~ lJ 

Defendants 8t Af,.. 2 200/ 

COMPLAINT 

L JURISDICTION 

1. This action is brought pursuant to 42 U.S.c. §§ 1331,1332 and 

1343(1),(3),(4) and the aforementioned statutory provision. Plaintifffurther invokes 

the supplemental jurisdiction ofthis Court to hear and decide claims arising under state 

law. 

II. PARTIES 

2. Plaintiff, Raymond Randall is an adult male who was at all times relevant to 

this Complaint, a resident ofPennsylvania. 

3. Defendant City ofPhiladelphia is a City ofthe First Class in the 

Commonwealth ofPennsylvania and at all times relevant hereto operated under the 

color ofstate law in creating and maintaining a Police Department, was the employer 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 1 of 14
ofall Defendants and had the responsibility of adopting policies, implementing 

procedures and practices which would create an environment whereby citizens would 

be safe from police abuse. 

4. Defendant Police Officer Reynolds, Badge number 4268, is and was at all 

times relevant to this Complaint, a police officer for the City ofPhiladelphia and acting 

under the color of state law. He is being sued in both his individual and official 

capacities. 

5. Defendant Police Officer Cujdik, Badge number 1574, is and was at all times 

relevant to this Complaint, a police officer for the City ofPhiladelphia and acting 

under the color ofstate law. He is being sued in both his individual and official 

capacities. 

6. Defendant Police Officer Liciardello, Badge number 4383, is and was at all 

times relevant to this Complaint, a police officer for the City ofPhiladelphia and acting 

under the color of state law. He is being sued in both his individual and official 

capacities. 

a. Defendant Police Officer McCue, Badge number 6628, is and was at all 

times relevant to this Complaint, a police officer for the City ofPhiladelphia and acting 

under the color ofstate law. He is being sued in both his individual and official 

capacities. 

8. Defendant Police Officer McGee, Badge number 4504, is and was at all 

times relevant to this Complaint, a police officer for the City ofPhiladelphia and acting 

under the color of state law. He is being sued in both his individual and official 

capacities. 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 2 of 14
llLFACTS 

9. On September 16, 2003 Defendants claim that they received information 

from a confidential source that narcotics were being stored at 769 A North Preston 

Street, Philadelphia, Pennsylvania. 

10. As a result ofthis information Defendant Cujdik obtained a search warrant 

for 769 A North Preston Street. 

11. On September 25,2003, Defendants executed search warrant #110499 

at 769A North Preston Street. 

12. No narcotics or other contraband were confiscated. 

13. Defendants then executed a search warrant at another location at 606 N. 

Union Street, Philadelphia, Pennsylvania. 

14. Defendants searched that location and recovered no narcotics or other 

contraband. Defendants did however confiscate narcotics in a vacant lot that had no 

relation to 769A North Preston Street or 606 N. Union Street. 

15. Defendants however arrested Plaintiffwho was visiting the neighborhood 

and was outside in the area of606 N. Union Street. Plaintiffwas never near the vacant 

lot. 

16. Defendants McCue and McGee confiscated five (5) small packets of 

marijuana. Defendants thereafter provided information to the authorities which placed 

the possession ofthe recovered narcotics in the vacant lot on Plaintiff. 

17. As a result ofhis arrest, Plaintiffwas charged with narcotic related crimes of: 

CS13A30-Controlled Substance Act (Manufacture, Delivery); CS13AI6-Controlled 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 3 of 14
Substance Act (Knowingly and Intentional), CSI3A31-Controlled Substance Act 

(Marijuana For Personal Use) and CC09030-Criminal Conspiracy. These charges 

reflected Plaintiff's involvement with the narcotics confiscated from the vacant lot. 

17. Defendants made a high bail request and bail was set at $25,000.00. 

18. As a result ofhis arrest Plaintiffwas incarcerated. 

19. On July 20,2004 the Court dismissed all criminal charges against Plaintiff 

20. The foregoing conduct ofthe Defendants, acting under the color ofstate 

law, was undertaken in concert and conspiracy and as part of an effort in conducting 

an illegal search, unlawfully arresting Plaintilf, imprisoning him and maliciously 

prosecuting Mr. Randall and otherwise depriving Plaintiff of his civil and constitutional 

rights including Plaintiff's rights, privileges and immunities under the Fourth and 

Fourteenth Amendments to the United States Constitution and the laws ofthe 

Commonwealth ofPennsylvania. 

21. At no time did Plaintiff commit any offense against the laws ofthe 

Commonwealth ofPennsylvania for which an arrest may be lawfully made. At no time 

did Plaintiff commit any illegal acts or engage in any conduct, which in any way 

justified the actions ofall Defendant police officers. 

22. As a direct and proximate result ofthe Defendants' actions, Plaintiffsuffered 

and continues to suffer serious mental anguish, psychological and emotional distress, 

and pain and suffering, some or all ofwhich may be permanent. 

23. As a direct and proximate result ofthe Defendants' actions, Plaintiffhas 

suffered and continues to suffer damage to his personal and business reputation. 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 4 of 14
24. As a direct and proximate result ofthe Defendants' actions, Plaintiffwas 

arrested, incarcerated and maliciously prosecuted without just or probable cause. 

25. The actions ofDefendants were undertaken in a menacing and arbitrary 

manner, designed to cause Plaintifffear, distress and embarrassment. 

26. The acts ofDefendants Reynolds, Liciardello, Cujdik, McGee and McCue 

were committed willfully, wantonly, maliciously, intentionally, outrageously, 

deliberately and/or by conduct so egregious as to shock the conscience. 

27. The acts and omissions ofthe undivided Defendants were committed without 

cautious regard to due care, and with such wanton and reckless disregard ofthe 

consequences as to show Defendants' indifference to the danger of harm and injury. 

28. The individual Defendants conspired to deprive Plaintiffhis constitutional 

rights. 

29. Defendants Reynolds, Liciardello, Cujdik, McGee and McCue made 

statements to police, the district attorney and others in order to conceal their unlawful 

and unconstitutional conduct and in an attempt to deny Plaintiff access to the Courts 

and to due process. 

30. Defendants Reynolds, Liciardello, Cujdik, McGee and McCue engaged in 

the aforesaid conduct for the purpose ofviolating Plaintiff's constitutional rights by 

subjecting him to unreasonable search and seizure, depriving Plaintiffof property and 

liberty without due process oflaw, unlawfully arresting him, and attempting to deprive 

Plaintiff access to the Courts and to due process. 

31. As a direct and proximate result ofthe Defendants' illegal and 

unconstitutional actions, Plaintiffsuffered pain, fear, anxiety, embarrassment, loss of 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 5 of 14
liberty, confinement, severe emotional trauma, and the loss ofthe enjoyment oflife, all 

to his great detriment and loss. 

32. As a direct and proximate cause ofthe Defendants' illegal and 

unconstitutional actions, Plaintiff suffered and continues to suffer financial loss and 

deprivation ofother liberty interests to his great financial detriment and loss. 

FIRST CAUSE OF ACTION 

FEDERAL CIVIL RIGHTS VIOLATIONS 

33. The allegations set forth in paragraphs 1-32 inclusive, are incorporated 

herein as iffully set forth. 

34. As a direct and proximate result ofDefendants' above described unlawful 

and malicious conduct, committed under the color ofstate law, and while acting in 

that capacity, the Defendants deprived Plaintiff'ofthe equal protection ofthe laws and 

Plaintiff's rights, privileges and immunities under the laws and the Constitution ofthe 

United States. Plaintiff's right to be free from unreasonable searches and seizures, false 

arrest, false imprisonment, malicious prosecution, to be secure in one's person and 

property, to access to the Courts, and to due process and equal protection ofthe law, 

all to Plaintiff's great detriment and loss. As a result, Plaintiff suffered grievous harm, 

in violation of his rights under the laws and Constitution ofthe United States in 

particular the Fourth and Fourteenth Amendments thereof, and 42 U.S.C. § 1983. 

35. As a direct and proximate result ofthe acts and omissions ofDefendants, 

Plaintiffwas forced to endure great pain and mental suffering, and was deprived of 

physical liberty, all to Plaintiff's great detriment and loss. 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 6 of 14
36. The City ofPhiladelphia permitted, encouraged, tolerated, ratified and was 

deliberately indifferent to a pattern, practice and custom of: 

a. Abuse of police powers, including false arrest, improper 

identification ofsuspects, improper use of"confidential information", 

harassment and improper searches; 

b. Psychologically or emotionally unfit persons serving as police officers; 

and 

c. Failure of police officers to prevent, deter, report or take action against 

the unlawful conduct of police officers under such circumstances as 

presented herein. 

37. Defendant, City ofPhiladelphia was deliberately indifferent to the need to: 

a. Test its officers for emotional and psychological fitness to serve as 

police officers; 

b. Monitor officers whom it knew or should have known were suffering 

from emotional and/or psychological problems that impair their ability to 

function as police officers; 

c. Train its police officers in the appropriate exercise of police powers; 

d. Facilitated, encouraged, tolerated, ratified, and/or was deliberately 

indifferent to officers using their status as police officers to have persons 

falsely arrested, maliciously prosecuted, or to achieve ends not 

reasonably related to their police duties; and 

e. Failure to properly train, supervise and discipline officer officers with 

regard to such police practices. 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 7 of 14
38. The City ofPhiladelphia was deliberately indifferent to the need for more or 

different training, supervision, investigation or discipline in the areas of: 

a. Exercise of police powers~

b. Police officers with emotional or psychological problems; 

c. Police officers use oftheir status as police officers to have persons 

falsely arrested, or to achieve ends not reasonably related to their police 

duties~ and 

d. False arrest, evidence planting, use ofwarrants for an improper cause, 

illegal use ofinformants and malicious prosecution of citizens. 

39. The City ofPhiladelphia failed to properly sanction or discipline officers, 

who are aware of and conceal and/or aid and abet violations of constitutional rights of 

citizens by other police officers, thereby causing and encouraging police officers, 

including the Defendant police officers in this case, to violate the rights of citizens 

such as Plaintiff 

40. The foregoing acts, omissions, systemic deficiencies and deliberate 

indifference to the danger or harm to citizens like the Plaintiff and the need for more or 

different training, investigation and discipline are policies and customs ofthe City of 

Philadelphia and have caused police officers, including Defendant police officers in this 

case, to believe that they can violate the rights of citizens, with impunity, including the 

use offraud and falsehood and to believe that such conduct would be honestly and 

properly investigated, all with the foreseeable result that officers are more likely to 

violate the constitutional rights of citizens. 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 8 of 14
41. The actions of all Defendants, acting under the color ofstate law and/or in 

concert or conspiracy with each other, deprived Plaintiffofhis rights, privileges and 

immunities under the laws and Constitution ofthe United States, in particular, the 

rights to be secure in one's person and property, unlawful searches, malicious 

prosecution and from false arrest and to due process oflaw. 

42. Defendants, City ofPhiladelphia and the individual named Defendants, acting 

in concert and conspiracy with each other, have by the aforementioned actions 

deprived Plaintiffofhis constitutional and statutory rights. 

43. By these actions, all Defendants have deprived Plaintiffofhis rights secured 

by the Fourth and Fourteenth Amendments to the United States Constitution in 

violation of42 U.S.C. § 1983. 

SECOND CAUSE OF ACTION
 

SUPPLEMENTAL STATE CLAIMS
 

44. Plaintiff hereby re-alleges paragraph 1-43 ofthis complaint, as though fully 

set forth herein. 

45. The acts and conduct of all Defendants alleged in the above stated cause of 

action constitute false arrest, false imprisonment and malicious prosecution under the 

laws ofthe Commonwealth ofPennsylvania, and this Court has supplemental 

jurisdiction to hear and adjudicate said claims. 

PUNITIVE DAMAGES 

46. Plaintiffre-alleges paragraphs 1-45 ofthis complaint as though fully set forth 

herein. 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 9 of 14
47. The conduct ofthe individual Defendants were outrageous, malicious, 

wanton, willful, reckless and intentionally designed to inflict harm upon Plaintiff. 

48. As a result ofthe acts ofthe individual Defendants alleged in the preceding 

paragraphs, Plaintiffis entitled to punitive damages as to each cause of action. 

JURY DEMAND 

49. Plaintiffdemands a jury trial as to each Defendant and as to each count. 

WHEREFORE, Plaintiffrequests the following relief: 

a. Compensatory damages; 

b. Punitive damages; 

c. A declaratory judgment that the practices and policies complained of 

are unconstitutional; 

d. Reasonable attorney's fees and costs; and 

e. Such other and further relief as appears reasonable and just. 

MI L PILEGGI, E 

303 Chestnut Street 

Philadelphia, PA 19106 

(215) 627-8516 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 10 of 14
IN THE UNITED STATES DISTRICT COURT
 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA
 

RAYMOND RANDALL 

PlaintitT JURY TRIAL 

vs. DEMAND 

THE CITY OF PHILADELPHIA, 

PHILADELPHIA POLICE OFFICER REYNOLDS, 

BADGE NUMBER 4268; PHILADELPHIA POLICE 

OFFICER LICIARDELLO, BADGE NUMBER 4383; C.A.#04­

PHILADELPHIA POLICE OFFICER CUJDIK, 

BADGE NUMBER 1574; PHILADELPHIA POLICE 

OFFICER MCGEE, BADGE NUMBER 4504, 

PHILADELPHIA POLICE OFFICER MCCUE, 

BADGE NUMBER 6628, individually and as police 

officers for the City ofPhiladelphia 

Defendants 

CERTIFICATION OF SERVICE 

Michael Pileggi, Esquire, counsel for the Plaintiffin the above matter, hereby 

certifies that he served a copy ofPlaintifPs Complaint in the above matter, upon the 

following parties, by letter dated September 2,2004, mailed by first class, postage 

prepaid, to the following address: 

Lee Holliday, Claims Coordinator 

One Parkway, 1515 Arch Street 

15th Floor 

Philadelphia, PA 19102-1595 

303 Chestnut Street 

Philadelphia, PA 19106 

215-627-8516 

Counsel for Plaintiff 

Mic ael Pileggi, Esquire 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 11 of 14
::::~.~:, 'y law. except as 

~.- provIded by ond 

local· 

hb·mn

Uo~'S n~:~~! form. approved 

~~~:O~P~:!fi~_ by the Judicial Conference of the United States ,"Moe 

In 

m

September 

£~:O~~~: 1974. is reqUIred tor ~w~ the use 

f the Cieri< of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) 

(8) PLAINTIFFS	 DEFENDANTS 

tf/rfJ1()JJp /(IrJDItU-	 ~I rY tJt /;1/l-4bt:;~(~ e!: q/ 

(b> COUNTY OF RESIDENCE OF FIRST USTED P 

(EXCEPT IN U.S. PLAI 

COUNTY OF AESlDENa: OF FIRST LJSTE) DEFENDANT ~/~b-~A 

(IN U.S. PLAINTIFF CASES ONLY) 

NOTE: IN LAND CONDEMNATION CASES. USE THE LOCATION OF THE 

TRACT OF LAND INVOLvED. 

ATIORNEYS IIF KNOWN) 

BASIS OF JURISDICTION IPLACE AN 'X' IN ONE BOX ONLY) 

1 U.S, Government 

Plaintiff G""tS'"~tNm a Party) 

U.S. Government DD~MSity . Defendant	 (Indicate Citizenship of Parties 

in Item III) 

III. CmZENSHIP OF PRINCIPAL PARTIES IPLACE AN ·X· IN ONE BOX FOR PLAINTIFF 

(For Diversity Cases Only) AND ONE BOX FOR DEFENDANT) 

PT~~EV PTF DEF 

Citizen of This State e(i Incorporated or Principal Place 0 • 0 • 

of Business In This State 

Citizen of Another State 0 2 02 Incorporated and Principal Place 0 5 05 

of Business In Another State 

Citizen or Subject of a 0 3 0 3 Foreign Nation 06 08 

Foreign Country 

(PLACE AN '?(" IN ONE BOX ONLY) Appeal to District 

Transferred from J~from o 2 Removed from 0 3 Remanded from o • Reinstated or o 5 another district o • Multidistrict o 7 Magistrate State Court Appellate Court Reopened (specify) Uligation JUdgment 

NATURE OF SUIT (PLACE AN '?(" IN ONE BOX ONLY) 

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES 

10 Insuranc. PERSONAl INJURY ~ERSONAlINJURY o .,0 Agrlcunura o AppHl 28 USC 1se o <100 S1a1. ANj)pOI1lOnmant 

20 Ma~n. 0"0 AlrpI_ o X2 Pe~naIlnlury o 120 .01"., Foocl & Drug 0.,0 Amnrust 

)0 MUlar /lCl o 'IS AIrplane 

LJal)IIIIy ProauCl	 , Med MalpraCllca o 125 Drug R.lalad Sellur. o m WnnOrawal o UO Banlrs and 8anlc'"" to NagollaDIa IMlrumehl o .5 Personal InJury .. Property 21 USC 881 28 USC :~7 o UO ComrnateellCC Rat_ate 

RaccMlry 01 o.arpaymem o 3ZO AssaIIn, Ullel &	 ProauCl LlaDlllIy o 1)0 uQUOl Laws o - eapor1allon & Enlorc.menl 01 JUOgmehl Slanoar o :til Asllnlos PeBONlI O..a RA &Truck PROPERTY RIGHTS o UO Aac:kat_ Inft....nced ano 

~1 Medlcar. ACl o 330 "-ral Efnployers InJury ProauCl LJal)IIIIy o 'SO Almne Aags Corrupr OlQanllatlons o 120 CopyI1gnls 52 I\acovary 01 ealaunad UallUIIy o 110 Occupallonal o .,0 SaledIW SaMc:e DUO Pal_ S1uO.nl Loans O:MO Ma~ne PERSONAL PROPERTY SaI.lylHUnn o O 'SO SacumlasICommoOnleSl IEKcl Vet.rans) NO Traoamart< o M5 Manne ProouCl 0'70 OIner Frauo 0.10 OIner Excnanga

LJal)IIIIy AecOWlry 01 o.arpaymenl o 371 TMn In Lano'ng o .75 Customer Cnallenge 

of Vat...an', Ilanellls o ,~ t.Ioler Vallie.. o MO OIner Personal LABOR SOCIAL SECURITY 12 USC 3410

10 S1ocklloloars· Suns o 355 Moler ValIlcIa Property Damage 0." Agrlcunural ACls

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REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS o 1M SSID Tn", XVI o .ts FrMOom 

o 7)0 LADorlMgml A.ponlng D 115 ASlI405lgl1 Inlomlallon ACl 10 U1nO ConO.mnalion 0'" Vollng o 510 MoIIOns 10 vacar. & DisclOSur. ACl o 100 AppHl Fee Datermtnallon !O Foreclosur. Sentence o 7.a ~Ilway LallOr ACl FEDERAL TAX SUITS Undet Equal Access 10 JustICe HA8EA8 CORPUS: 10 R.nl L.... & E)aClmenl o PO General o 'SO ConslnUllOllal1ly d 10 Tons 10 Lana i AccommoclallOns o US OaaJn Panany o 710 OIner laW Lnlgallon Sla•• SlalUI.. D .70 TAXes IU SPlain,," IS To~ PrOOuCl LieD/Illy ~~Ollar. o Mel loWlOamus & 01"., er eal.noanll o .10 01"* SlatUlory AClIons J(I All OIn.r A.al Prope~y OIner CMI AIgI11S o 550 CMI AIgIns 0,., Empl Re. Inc D .71 IRS TnirO Pany

o m SacumyACl PrIson ConOnlon 28 USC 7800 

CAUSEOF ACTION"-16re THE US CML STATIJ'TE UNDEA WHICH YOU ARE FlUNG AND WRITE BRIEF STATEMENT OF CAUSE 

00 NOT CITE JUAISOlCTlONAL STATlJ'TES UNLESS DlVEASITY) 

11---- u.S.c. 11r3; 1bL-/~ f//S~.J.DtJC/

DEMAND S	 CHECK YES only if inCCllTlplaint: REQUESTED IN CHECK IF THIS IS A CLASS ACTION 

COMPLAItfr. S o NO o UNDER F.R.C.P. 23	 JURY DEMAND: 

•RELATED CASE(S) (See instructions): DOCKET NUMBER	 _ IF ANY	 JUDGE 

5E? 022004 

:'IPT 1/ AMOUNT APPLYING IFP.~ JUDGE	 _ MAG. JUOGE -­

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 12 of 14
"	 lr TED STATES DISTRICT COURT 0f ~V Y(0 3 

FO.R THE EASTERN ~~TnDENNSYLVANIA - DESIGNATION FORM to be used by counsel to indicate the category of the case for the purpose of 

"lSslgnment to approPrJa~;Y.D

Address 

Place 

Ad"'", 

ofAccident, 

,'P,.m'iff, 

ofDefendant: 

Incident 

38'91,; 

'£

or 

\<1 

Transaction: 

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V,!­

A 

(Use Reverse Side For AJdditional Space) I 

Does this case involve multidistrict litigation possibilities?	 Yes O 

RELA TED CASE, IF ANY: 

Case Number: Judge Date Terminated:	 _ 

Civil cases are deemed related when yes is answered to any ofthe 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? 

Yes O NoW' 

2.	 Does this case involve the same issue of fact or grow out ofthe same transaction as a prior suit pending or within one year previously terminated 

action in this court? YesO No~

3. Does this case involve the validity or infringement ofa patent already in suit or any earlier numbered case pending or within one year previously 

terminated action in this court? Yes0 No 

Does this civil action involve a nongovernmental corporate party with any parent corporation and any publicly held corporation owning 100/< or re of its stock? 

(Attach two copies ofthe Disclosure Statement Form in accordance with Fed.R.Civ.P. 7. I(a». YesO 

CIVIL: (place V in ONE CATEGORY ONLY) 

A. Federal Question Cases:	 B. Diversity Jurisdiction Cases: 

I.	 0 Indemnity Contract, Marine Contract, and All Other Contracts I. 0 Insurance Contract and Other Contracts 

2.	 0 FELA 2. 0 Airplane Personal Injury 

3.	 0 Jones Act-Personal Injury 3. 0 Assault, Defamation 

4.	 0 Antitrust 4. 0 Marine Personal Injury 

5.	 0 Patent 5. 0 Motor Vehicle Personal Injury 

6.~Labor-ManagementRelations 6.	 0 Other Personal Injury (please specify) 

7. Civil Rights	 7. 0 Products Liability 

8. Habeas Corpus	 8. 0 Products Liability - Asbestos 

9.	 0 Securities Act(s) Cases 9. 0 All other Diversity Cases 

10.	 0 Social Security Review Cases (please specify) 

I I. 0 All other Federal Question Cases 

(please specify) 

ARBITRATION CERTIFICATION 

(Check appropriate Category) 

I,	 . counsel ofrecord do hereby certify: 

o Pursuant to Local Civil Rule 53.2, Section 3(c)(2), that to the best ofmy knowledge and belief, the damages recoverable in this civil action case 

exceed the sum of$150,OOO.00 exclusive of interest and costs; 

o Reliefother than monetary damages is sought. SEP 02 2004 

DATE:	 _ 

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 certiry that, to my knowledge, the within case is not related to any c!se now pend' or within one year previously terminated action in this court 

except as noted above. 

DATE:~,hl°'1	 I 

Attorney I.D.# 

CIV. 609 (4/03) 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 13 of 14
IN THE UNITED STATES DISTRICT COURf
 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA
 

CASE MANAGEMENT TRACK DESIGNATION FORM 

CIVIL ACTION 

v. 

CITY orfJffli--A-Dt.~/A NO. 

e-J.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 ofthe 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 ofthis form for a detailed explanation of special 

management cases.) ( ) 

(f) Standard Management - Cases that do not fall into anyone of the other tracks. fj 

4JC!IJk,..j?4>-oM Attorney-at-law 

'2/'; -627- ~/OS Telephone	 FAX Number 

SEP 02 201M 

(Civ. 660) 10/02 

Case 2:04-cv-04163-ER Document 1 Filed 09/02/04 Page 14 of 14