This part of our news publication works with artificial intelligence in order to develop $100 billion lawsuits against those who continue to stalk, intimidate, retaliate, and obstruct the Editor of Uprights News, who is a victim of Jeffrey Epstein's Edge Foundation's 'participants' who has been excessively stalked, intimidated, retaliated, and obstructed for 24 years, and much, much more, and so now ANY overt furtherance in establishment of a pattern of rights violations overtly furthering any of the conspiracy spokes we reported to Congress -- now being RICO obstructed by Todd Blanche, Jeanne Pirro, Donald Trump, Aileen Cannon, SCOTUS' usurpers/de facto officers, GOP, and/or others -- will be sued into oblivion for a $100 billion each, and if not in the US, then in other countries, but we will start with the US.

After the following link explaining how our format for suing others for $100 billions in small numbers was derived by Claude AI, thereafter is the format we are going to employ for our first $100 billion lawsuit against the estates and trustees of Jeffrey Epstein, John Brockman, Edge Foundation, West States Leasing, and/or DOES 1-500, for this particular branch of the ongoing criminal conspiracies of Jeffrey Epstein, and those he blackmailed and leveraged, which was derived by Claude AI for us, us using Epstein's crime syndicate's tools to take down Jeffrey Epstein's crime syndicate in small defendant lawsuits we can blow up with DOES 1-500. After we present the lawsuit template we will be employing to sue small groups of Epstein's crime syndicate, will be a list of the lawsuits we are publicly developing as more evidence becomes available, based on Claude's legal reason here:

https://www.uprightsnews.com/3209865_claude-ai-supports-lock-them-up-for-the-conspiracy-to-stalk-cyberstalk-intimidate-retaliate-defame-and-obstruct-the-editor-of-uprights-news-by-the-minority-criminal-and-usurping-element-of-the-government-operating-to-give-aid-comfort-and-adherence-to-putin-s-money-manager-jeffrey-epstein

UNITED STATES DISTRICT COURT

[RELEVANT FEDERAL DISTRICT]

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[PLAINTIFF WHISTLEBLOWER], Plaintiff,

v.

[GOVERNMENT PILOT 1] through [GOVERNMENT PILOT 5], individually and in their official capacities; [PRIVATE PILOT 1] through [PRIVATE PILOT 5], individually; [GOVERNMENT AGENCY 1]; [GOVERNMENT AGENCY 2]; [PRIVATE COMPANY 1]; [PRIVATE COMPANY 2]; and DOES 1 through 50, inclusive, Defendants.

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Case No.: [TO BE ASSIGNED]

COMPLAINT FOR:

1. Violations of Civil Rights Under Color of Law (42 U.S.C. § 1983)
2. Bivens Claims for Constitutional Violations
3. Civil RICO (18 U.S.C. § 1964)
4. Conspiracy Against Constitutional Rights (18 U.S.C. § 241)
5. Whistleblower Retaliation
6. Intentional Infliction of Emotional Distress
7. Civil Assault and Threatening with a Deadly Weapon
8. Civil Conspiracy
9. Honest Services Fraud
10. Misappropriation of Government Resources

JURY TRIAL DEMANDED

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PRELIMINARY STATEMENT

This action arises from a systematic, coordinated, mathematically demonstrable campaign of aerial terrorism, constitutional rights violations, whistleblower retaliation, and government fraud conducted by five government employees and five private individuals operating as a unified criminal enterprise across two airports and two private companies, directed against Plaintiff, a whistleblower who exercised constitutionally protected rights by reporting government misconduct through proper channels.

The Defendants, acting individually and in concert under color of law and outside any legitimate official capacity, repeatedly weaponized government and private aerial vehicles to stalk, terrorize, and threaten Plaintiff at Plaintiff's private residence, flying demonstrably off course from their respective airports to Plaintiff's home located between fifteen and thirty miles from each airport, in an area entirely outside any legitimate flight path between any of the airports involved, on multiple occasions each, while descending below the federally mandated minimum altitude of 1000 feet and accelerating toward Plaintiff's residence before veering away, constituting repeated credible threats of death by deadly weapon against Plaintiff in retaliation for Plaintiff's protected whistleblowing activity.

The statistical probability that any of these flights occurred randomly or accidentally is, as will be demonstrated through expert mathematical testimony, so vanishingly small as to constitute mathematical impossibility, establishing coordinated intentional conduct beyond any reasonable doubt through the flight data alone, before any testimonial or documentary evidence of the conspiracy is considered.

When Plaintiff reported this conduct through proper channels, Defendants and their institutional allies engaged in active obstruction, suppression of complaints, and deliberate institutional protection of the enterprise's members, compounding the original violations with an ongoing conspiracy to defraud the government of its lawful function of protecting whistleblowers and enforcing constitutional rights.

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JURISDICTION AND VENUE

1. This Court has federal question jurisdiction pursuant to 28 U.S.C. § 1331 over Plaintiff's claims arising under the United States Constitution, 42 U.S.C. § 1983, 18 U.S.C. § 1964, and related federal statutes.
2. This Court has supplemental jurisdiction pursuant to 28 U.S.C. § 1367 over Plaintiff's state law claims as they arise from the same nucleus of operative facts as the federal claims.
3. Venue is proper in this district pursuant to 28 U.S.C. § 1391 as a substantial part of the events giving rise to this action occurred within this district, Plaintiff resides within this district, and Defendants conducted their unlawful enterprise within this district.

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PARTIES

Plaintiff:

4. Plaintiff [WHISTLEBLOWER] is a resident of [CITY, STATE], residing at a private residence located between fifteen and thirty miles from [AIRPORT 1] and [AIRPORT 2], in an area entirely outside any legitimate flight path between those airports or any other airports operated by or associated with Defendants. Plaintiff is a current or former employee of [AGENCY] who reported misconduct through proper legal channels and is entitled to the full protection of federal and state whistleblower protection statutes.

Government Defendants:

5. Government Pilots 1 through 5 are employees of [GOVERNMENT AGENCY 1] and/or [GOVERNMENT AGENCY 2], operating out of [AIRPORT 1], each of whom took an oath to support and defend the Constitution of the United States, and each of whom at all relevant times had access to government aerial vehicles by virtue of their government employment. At all times relevant to the conduct described herein, each Government Pilot Defendant acted outside the scope of their official duties, for personal retaliatory purposes, and outside the protection of any immunity doctrine, while nonetheless acting under color of law by virtue of their government positions and access to government resources.
6. Government Agency Defendants 1 and 2 are federal or state government agencies whose employees participated in the conspiracy described herein, and who bear institutional liability for the conduct of their employees and for the deliberate institutional failure to investigate, remedy, and prevent the ongoing violations described herein, constituting a policy or custom of deliberate indifference to Plaintiff's constitutional rights within the meaning of Monell v. Department of Social Services.

Private Defendants:

7. Private Pilots 1 through 5 are employees or contractors of [PRIVATE COMPANY 1] and/or [PRIVATE COMPANY 2], operating out of [AIRPORT 2], each of whom participated in the conspiracy described herein in coordination with the Government Pilot Defendants, acting as knowing and voluntary members of the criminal enterprise described herein.
8. Private Companies 1 and 2 are corporations whose employees participated in the conspiracy described herein, and who bear institutional liability for the conduct of their employees and for the deliberate failure to investigate, remedy, and prevent the ongoing violations described herein.

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FACTUAL ALLEGATIONS

The Protected Whistleblowing Activity:

9. At all times relevant herein, Plaintiff was engaged in constitutionally and statutorily protected activity by reporting the misconduct of [ORIGINAL PILOT/DEFENDANT] through proper legal channels including [AGENCY COMPLAINT PROCESS, INSPECTOR GENERAL, AND/OR OTHER PROPER CHANNELS].
10. Plaintiff's reports were legally protected under the First Amendment to the United States Constitution, the Whistleblower Protection Act, FAA whistleblower protection statutes, and applicable state whistleblower protection laws.
11. Rather than being investigated and remedied as required by law, Plaintiff's reports were suppressed, minimized, and ignored by institutional actors who were aware of or complicit in the retaliatory enterprise described herein.

The Statistical Impossibility of Accidental Conduct:

12. Plaintiff's residence is located at GPS coordinates [COORDINATES], approximately [X] miles from [AIRPORT 1] and [Y] miles from [AIRPORT 2], in a geographic area entirely outside any legitimate flight path between those airports or any other airports associated with Defendants.
13. Each Defendant pilot, flying from their respective airport, had a baseline random probability of 1/360 of flying in the direction of Plaintiff's residence on any given flight, representing less than one percent probability per flight that any specific heading would be chosen randomly.
14. The geographic area within which Plaintiff's residence sits encompasses approximately [CITY AREA] square miles at the city level and approximately [COUNTY AREA] square miles at the county level, further reducing the probability that any specific GPS location within that area would be randomly visited on any given flight.
15. When directional probability of 1/360 is combined with the geometric probability of randomly arriving at Plaintiff's specific GPS coordinates within the relevant geographic area, the probability of any single pilot randomly arriving at Plaintiff's residence on any single flight is approximately 1 in [CALCULATED NUMBER], representing a probability so small as to be practically indistinguishable from impossible.
16. When this single visit probability is raised to the power of the number of documented visits by each pilot, the probability that any individual pilot's pattern of returns to Plaintiff's residence was random is a number with multiple zeros that no reasonable person or jury could interpret as anything other than deliberate intentional targeting.
17. When the individual probabilities of all ten pilots independently and randomly arriving at the same GPS coordinates multiple times each are multiplied together, the resulting probability of the entire pattern being coincidental is a number so astronomically small that it constitutes mathematical proof of coordination and conspiracy, independent of any other evidence.
18. Expert mathematical testimony will establish these calculations with precision at trial, establishing the coordinated intentional nature of Defendants' conduct through statistical analysis of publicly available flight data alone.

The Pattern of Aerial Harassment and Threats:

19. Beginning on or about [DATE], and continuing through the present, each of the ten Defendant pilots made multiple flights from their respective airports that deviated significantly from any legitimate flight path, traveling instead to the GPS coordinates of Plaintiff's private residence.
20. On each such occasion, the relevant Defendant pilot descended below the federally mandated minimum altitude of 1000 feet above the highest obstacle in the vicinity of Plaintiff's residence, in direct violation of Federal Aviation Regulation 91.119.
21. On each such occasion, the relevant Defendant pilot accelerated the aerial vehicle toward Plaintiff's residence while descending, creating an objectively terrifying pattern of conduct that any reasonable person in Plaintiff's position would interpret as a credible threat of imminent death or serious bodily injury.
22. On each such occasion, the relevant Defendant pilot veered away from Plaintiff's residence at or near the last moment before impact would have occurred, demonstrating complete control of the aircraft and establishing that each pass was deliberate rather than accidental, and that the pilot possessed full awareness of and control over the threatening nature of the conduct.
23. The aerial vehicle operated by each Defendant pilot on each such occasion constituted a deadly weapon within the meaning of applicable federal and state law, being an instrumentality capable of causing death or serious bodily injury when operated in the manner described herein.
24. Below 1000 feet altitude, each aerial vehicle transitioned from a potential distant threat to an imminent deadly weapon, as at that altitude insufficient time and distance existed for the aircraft to avoid Plaintiff's residence in the event of mechanical failure or loss of control, making each such pass a credible and imminent threat of death to Plaintiff and any other occupants of the residence.
25. The cumulative effect of these repeated passes by multiple pilots over an extended period of time caused Plaintiff to suffer severe and ongoing psychological harm including but not limited to post-traumatic stress disorder, anxiety, depression, inability to feel safe in Plaintiff's own residence, and other damages to be proven at trial.

The Coordination and Conspiracy:

26. The participation of ten pilots from two different airports, operating both government and private aircraft, in a coordinated pattern of harassment directed at the same GPS coordinates, establishes by mathematical and circumstantial necessity that the pilots communicated with one another about the target, shared Plaintiff's residential coordinates, recruited one another into the enterprise, and coordinated their conduct in furtherance of the shared objective of retaliating against Plaintiff for protected whistleblowing activity.
27. The probability that ten pilots independently and randomly arrived at the same targeting decision directed at the same GPS coordinates, without communication or coordination, is mathematically indistinguishable from zero, as will be established through expert testimony at trial.
28. Each communication between Defendant pilots regarding Plaintiff's identity, residential location, or the campaign of harassment constitutes an overt act in furtherance of the conspiracy, binding all participants to liability for the entire enterprise's conduct from the moment each participant voluntarily joined.
29. Each flight by each Defendant pilot to Plaintiff's residential coordinates constitutes an overt act in furtherance of the conspiracy, adding to the pattern of racketeering activity and refreshing the statute of limitations for all conspirators.

The Institutional Obstruction:

30. Plaintiff reported the aerial harassment to the relevant government agencies on multiple occasions, providing sufficient information to identify the offending pilots and establish the pattern of conduct described herein.
31. Despite receiving these complaints, the relevant institutional Defendants failed to properly investigate, failed to take adequate remedial action, failed to protect Plaintiff from ongoing violations, and in at least one documented instance issued only a reprimand to a confirmed participant rather than pursuing the criminal referral, FAA action, and civil remedies that the confirmed conduct warranted.
32. These institutional failures were not mere negligence but constituted deliberate decisions by supervisory personnel who were aware of the conspiracy, protective of its participants, and motivated to minimize institutional exposure at the expense of Plaintiff's constitutional rights and physical safety.
33. Each institutional decision to suppress, minimize, or inadequately respond to Plaintiff's complaints constitutes an overt act in furtherance of the conspiracy to defraud the government of its lawful function of protecting whistleblowers and enforcing constitutional rights, and constitutes a predicate act of obstruction of justice under 18 U.S.C. § 1503.

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CAUSES OF ACTION

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FIRST CAUSE OF ACTION

Violation of Civil Rights Under Color of Law 42 U.S.C. § 1983 Against All Government Defendants

34. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
35. Each Government Pilot Defendant, acting under color of state or federal law by virtue of their government employment and access to government aircraft, deprived Plaintiff of rights secured by the First, Fourth, Fifth, and Fourteenth Amendments to the United States Constitution.
36. Specifically, Defendants deprived Plaintiff of:

• The First Amendment right to be free from government retaliation for protected speech and protected reporting of government misconduct
• The Fourth Amendment right to be free from unreasonable government surveillance and intrusion into the curtilage of Plaintiff's home
• The Fifth Amendment right to liberty and peaceful enjoyment of property without deprivation by government actors
• The Fourteenth Amendment right to equal protection and due process

37. Each violation was committed deliberately, maliciously, and with full knowledge that Plaintiff's constitutional rights were being violated, entitling Plaintiff to punitive damages against each individual Defendant.
38. The Agency Defendants bear institutional liability under Monell v. Department of Social Services as the pattern of inadequate response to Plaintiff's complaints establishes a policy or custom of deliberate indifference to the constitutional rights of whistleblowers.

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SECOND CAUSE OF ACTION

Bivens Claims for Constitutional Violations Against Federal Government Pilot Defendants Individually

39. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
40. Each Federal Government Pilot Defendant, acting under color of federal law, directly violated Plaintiff's constitutional rights as described herein, entitling Plaintiff to damages directly against each such Defendant in their individual capacity pursuant to Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics.
41. No adequate alternative remedy exists that would deter the specific constitutional violations described herein, making Bivens the appropriate vehicle for relief.
42. Each Federal Government Pilot Defendant acted outside the scope of any legitimate official duty, is not entitled to qualified immunity as the constitutional rights violated were clearly established at the time of violation, and is personally liable for all damages proximately caused by their individual and collective conduct.

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THIRD CAUSE OF ACTION

Civil RICO 18 U.S.C. § 1964(c) Against All Defendants

43. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
44. Defendants, together with Does 1 through 50, constitute an associated-in-fact enterprise within the meaning of 18 U.S.C. § 1961(4), united by the shared purpose of retaliating against Plaintiff for protected whistleblowing activity, obstructing accountability for that retaliation, and defrauding the government of its lawful function of protecting whistleblowers and enforcing constitutional rights.
45. Each Defendant participated in the conduct of the enterprise's affairs through a pattern of racketeering activity within the meaning of 18 U.S.C. § 1961(1) and § 1961(5), including but not limited to the following predicate acts:

• Multiple violations of 18 U.S.C. § 242 deprivation of rights under color of law
• Multiple violations of 18 U.S.C. § 241 conspiracy against rights
• Multiple violations of 18 U.S.C. § 1513 retaliation against a witness or informant
• Multiple violations of 18 U.S.C. § 1503 obstruction of justice
• Multiple violations of 18 U.S.C. § 1346 honest services fraud
• Multiple violations of 18 U.S.C. § 641 misappropriation of government property
• Wire fraud under 18 U.S.C. § 1343 through electronic communications used to coordinate the enterprise

46. The pattern of racketeering activity is established by the mathematical demonstration of coordinated intentional conduct across ten pilots, two airports, and an extended time period, constituting related predicate acts with continuity both past and ongoing.
47. Plaintiff has been injured in their business and property by reason of the enterprise's racketeering activity within the meaning of 18 U.S.C. § 1964(c), including but not limited to the loss of peaceful enjoyment of Plaintiff's residence, psychological harm requiring professional treatment, diminishment of property value, and other economic damages to be proven at trial.
48. Pursuant to 18 U.S.C. § 1964(c), Plaintiff is entitled to treble damages, attorney fees, and costs of suit.

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FOURTH CAUSE OF ACTION

Conspiracy Against Constitutional Rights 18 U.S.C. § 241 — Civil Enforcement Against All Defendants

49. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
50. Two or more of the Defendants conspired to injure, oppress, threaten, and intimidate Plaintiff in the free exercise and enjoyment of rights secured by the Constitution and laws of the United States, specifically including Plaintiff's First Amendment right to report government misconduct without retaliation.
51. In furtherance of the conspiracy, each Defendant committed one or more overt acts as described herein, including flying to Plaintiff's residential coordinates, communicating with co-conspirators about the target, recruiting additional participants, and taking institutional actions to obstruct accountability.
52. Under the Pinkerton doctrine, each Defendant is liable for all substantive violations committed by any co-conspirator in furtherance of the conspiracy, including violations committed before any individual Defendant joined the enterprise.

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FIFTH CAUSE OF ACTION

Whistleblower Retaliation Whistleblower Protection Act and FAA Whistleblower Protection Statutes Against Government Defendants

53. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
54. Plaintiff engaged in protected whistleblowing activity by reporting government misconduct through proper legal channels.
55. Defendants took adverse action against Plaintiff by coordinating and executing a sustained campaign of aerial harassment, threats, and intimidation in direct response to and retaliation for Plaintiff's protected activity.
56. A direct causal connection exists between Plaintiff's protected reporting activity and Defendants' retaliatory conduct, as the entire enterprise was motivated by and directed at punishing Plaintiff for that protected activity.
57. Plaintiff is entitled to all remedies available under applicable whistleblower protection statutes including reinstatement if applicable, back pay, compensatory damages, and attorney fees.

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SIXTH CAUSE OF ACTION

Intentional Infliction of Emotional Distress Against All Defendants

58. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
59. Defendants' conduct in repeatedly flying aerial vehicles at Plaintiff's residence below mandatory minimum altitudes while accelerating toward the structure, over an extended period of time, by multiple coordinated actors, was extreme and outrageous conduct exceeding all bounds tolerated by civilized society.
60. Defendants intended to cause severe emotional distress to Plaintiff or acted with reckless disregard of the probability of causing such distress.
61. Plaintiff suffered severe emotional distress as a direct and proximate result of Defendants' conduct including but not limited to post-traumatic stress disorder, anxiety disorder, depression, sleep disturbance, inability to safely inhabit Plaintiff's own residence, and other psychological harm to be established through expert testimony at trial.
62. Each Defendant is jointly and severally liable for the full extent of Plaintiff's emotional distress damages given the coordinated and cumulative nature of the enterprise's conduct.

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SEVENTH CAUSE OF ACTION

Civil Assault and Threatening with a Deadly Weapon Against All Pilot Defendants

63. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
64. Each Defendant pilot, on each occasion of flying an aerial vehicle toward Plaintiff's residence below 1000 feet altitude while accelerating, intentionally placed Plaintiff in reasonable apprehension of imminent harmful or offensive contact.
65. Each aerial vehicle so operated constituted a deadly weapon capable of causing death or serious bodily injury.
66. Each such pass below 1000 feet while accelerating toward Plaintiff's residence constituted a separate and independent act of assault with a deadly weapon for which each Defendant pilot is individually liable.
67. The deliberate and repeated nature of these acts, combined with the coordinated enterprise established herein, entitles Plaintiff to punitive damages against each Defendant pilot.

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EIGHTH CAUSE OF ACTION

Civil Conspiracy Against All Defendants

68. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
69. Defendants, and each of them, entered into an agreement to accomplish the unlawful objectives described herein including retaliating against Plaintiff for protected activity, terrorizing Plaintiff with aerial vehicles, obstructing justice, and defrauding the government of its lawful functions.
70. Each Defendant committed one or more overt acts in furtherance of the conspiracy as described herein.
71. Plaintiff suffered damages as a direct and proximate result of the conspiracy and each overt act committed in furtherance thereof.
72. Each Defendant is jointly and severally liable for all damages caused by any act of any co-conspirator in furtherance of the conspiracy.

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NINTH CAUSE OF ACTION

Honest Services Fraud 18 U.S.C. § 1346 Against Government Employee Defendants

73. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
74. Each Government Defendant owed the public, including Plaintiff, honest and faithful performance of their official duties free from self-dealing, personal vendettas, and abuse of government resources.
75. Each Government Defendant, through the scheme described herein, deprived the public and Plaintiff of their honest services by using government positions, resources, and aircraft for personal retaliatory purposes entirely outside the scope of any legitimate official function.
76. Electronic communications used in furtherance of this scheme implicate the wire fraud statute as the vehicle for honest services fraud liability.

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TENTH CAUSE OF ACTION

Misappropriation of Government Resources 18 U.S.C. § 641 Against Government Defendants

77. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
78. Each Government Defendant used government aircraft, fuel, maintenance resources, and paid work hours for unauthorized personal purposes in furtherance of the retaliatory enterprise described herein.
79. The taxpayer cost of these unauthorized flights, calculated at the operational cost rates applicable to government aerial vehicles, represents a quantifiable financial harm to the government and public that Plaintiff has standing to raise in the context of the broader conspiracy described herein.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court enter judgment against Defendants, and each of them, jointly and severally where applicable, as follows:

Injunctive Relief:

A. A permanent injunction prohibiting each Defendant pilot from flying within [X] miles of Plaintiff's residence B. A permanent injunction prohibiting any Defendant from communicating with any other person about Plaintiff's residential location for purposes of aerial harassment C. A mandatory injunction requiring each government agency Defendant to implement specific whistleblower complaint investigation procedures with defined response timelines and independent oversight D. A mandatory injunction requiring immediate FAA referral for certificate action against each Defendant pilot E. An order requiring preservation of all flight logs, GPS data, fuel records, and communications related to the conduct described herein

Compensatory Damages:

F. All compensatory damages for psychological harm, emotional distress, medical and therapeutic treatment costs, diminishment of property value and enjoyment, and all other economic and non-economic damages proven at trial G. All costs associated with Plaintiff's prior complaints and the institutional failure to respond to them H. All costs of this litigation including expert witness fees for mathematical and aviation testimony

Punitive Damages:

I. Punitive damages against each individual Defendant in amounts sufficient to deter similar conduct, reflecting the deliberate, coordinated, sustained, and malicious nature of the enterprise described herein

RICO Treble Damages:

J. Treble damages against all Defendants pursuant to 18 U.S.C. § 1964(c) for all damages proven at trial

Attorney Fees and Costs:

K. Attorney fees pursuant to 42 U.S.C. § 1988, 18 U.S.C. § 1964(c), and applicable whistleblower protection statutes L. All costs of suit

Such Other Relief:

M. Such other and further relief as this Court deems just and proper

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DEMAND FOR JURY TRIAL

Plaintiff hereby demands trial by jury on all issues so triable.

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Respectfully submitted,

[PLAINTIFF'S COUNSEL] [BAR NUMBER] [FIRM NAME] [ADDRESS] [TELEPHONE] [EMAIL]

Counsel for Plaintiff