case 2:15-cv-00462 document 1 filed 03/25/15 page...

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NOTICE OF REMOVAL - 1 (_______________) DWT 26398157v4 0025936-002255

Davis Wright Tremaine LLP LAW OFFICES

1201 Third Avenue, Suite 2200 Seattle, WA 98101-3045

206.622.3150 main · 206.757.7700 fax

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

GEORGE E. ENGSTROM, an individual, and JOHN E. STOCKWELL, an individual, Plaintiffs, v. MICROSOFT CORPORATION, a Washington Corporation, Defendant.

No. ______________ NOTICE OF REMOVAL

TO: United States District Court for the Western District of Washington

Defendant Microsoft Corporation (“Microsoft” or “defendant”) gives notice that it is

removing this case from the Superior Court of the State of Washington for King County to the

United States District Court for the Western District of Washington at Seattle, pursuant to

28 U.S.C. § 1331, 28 U.S.C. § 1441 and 28 U.S.C. § 1446, on the grounds set forth below.

I. BACKGROUND FACTS

1. The Summons, Complaint, and Jury Demand were filed in the King County

Superior Court on February 25, 2015, and denominated Cause No. 15-2-04785-0 SEA.

2. Plaintiffs served the Summons, Complaint, and Jury Demand on Microsoft on

February 27, 2015. True and correct copies of the Summons, Complaint, and Jury Demand that

were served on Microsoft are separately attached hereto as Exhibit A (Summons & Complaint)

Case 2:15-cv-00462 Document 1 Filed 03/25/15 of 5

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206.622.3150 main · 206.757.7700 fax

and Exhibit B (Jury Demand) pursuant to LCR 101(b). Microsoft will separately file a

Verification of State Court Records and Proceedings pursuant to LCR 101(b).

3. The Complaint asserts that plaintiffs were wrongfully discharged in violation of

public policy as set forth in the Foreign Corrupt Practices Act, 15 U.S.C. § 78m. Complaint

¶¶ 2.25, 3.2.

4. Plaintiffs allege that they were wrongfully discharged in retaliation for reporting

their belief that a Microsoft employee allegedly submitted improper expenses. Complaint

¶ 2.24.

II. GROUNDS FOR REMOVAL

5. Pursuant to 28 U.S.C. § 1331, this Court “shall have original jurisdiction of all

civil actions arising under the Constitution, laws, or treaties of the United States.”

6. A case “arises” under the laws of the United States if it implicates a significant

federal issue. Grable & Sons Metal Products, Inc. v. Darue Eng’g & Mfg., 545 U.S. 308, 312

(2005) (“a federal court ought to be able to hear claims recognized under state law that

nonetheless turn on substantial questions of federal law, and thus justify resort to the

experience, solicitude, and hope of uniformity that a federal forum offers on federal issues”).

7. Plaintiffs’ claim relies upon and/or is intertwined with significant issues of

federal law, making federal law an essential element of their claim. This case is analogous to

Franks v. Civigenics, Inc., No. C05-5637RJB, 2005 WL 3211422, at *2-3 (W.D. Wash. Nov.

29, 2005), where this Court held that plaintiff’s claim of wrongful discharge in violation of the

public policies set forth in the federal Family and Medical Leave Act and Washington Law

Against Discrimination was properly removed because “[i]n making a claim for wrongful

discharge in violation of public policy, the plaintiff was entitled to refer to only state laws

creating or illustrating the public policy at issue. Rather than relying solely upon Washington’s

laws against discrimination, the plaintiff amended the complaint to add a reference to the

Family and Medical Leave Act.… This reference makes the policy of the Family and Medical

Leave Act an essential element of the plaintiff’s claim of wrongful discharge in violation of


jacksheridan

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206.622.3150 main · 206.757.7700 fax

public policy.” Id.; see also Grable & Sons Metal Products, Inc. v. Darue Eng’g & Mfg., 545

U.S. 308, 312 (2005) (federal court should decide state claims that “turn on substantial

questions of federal law”); cf. Cross v. King Cnty., C08-944JLR, 2009 WL 2475444, at *1

(W.D. Wash. Aug. 11, 2009) (plaintiff’s claim of wrongful termination based on alleged denial

of full Loudermill hearing rights remanded because “the federal issue lacks any additional

significance other than being a necessary and disputed element in Mr. Cross’s state wrongful

discharge claim” and “therefore does not predominate over other state law issues”). For the

same reasons discussed in Franks, this Court has original jurisdiction over this action pursuant

to 28 U.S.C. § 1331. In this case, plaintiffs must prove, among other elements, that other

means of promoting the public policy are inadequate and that the actions the plaintiffs took

were the only available adequate means to promote the public policy. Cudney v. ALSCO, Inc.,

172 Wash. 2d 524, 530, 259 P.2d 244 (2011). Resolution of this issue will require

interpretation of the federal Foreign Corrupt Practices Act, the alleged source of the public

policy that plaintiffs identify. This court is better equipped than a state court to interpret

federal law and any alleged public policy arising from federal law.

8. This Notice of Removal is timely under 28 U.S.C. § 1446(b)(1) as it is being

filed within 30 days of defendant’s receipt of plaintiffs’ Complaint, the “initial pleading setting

forth the claim for relief upon which such action or proceeding is based.” 28 U.S.C. §

1446(b)(1).

9. The sole defendant consents to removal. Therefore, this action may be removed

to federal court pursuant to 28. U.S.C. § 1441.

10. Under 28 U.S.C. § 1441(c), the right of removal applies to the entire lawsuit.

Removal is proper to the Western District of Washington because the district embraces King

County.

11. Intradistrict Assignment. Removal is proper to the Western District of

Washington at Seattle because Microsoft has its principal place of business in King County and

the claim arose in King County. LCR 3(d). See Complaint ¶ 2.1


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206.622.3150 main · 206.757.7700 fax

12. A true and correct copy of the entire state court file will be transmitted to the

United States District Court for the Western District of Washington.

13. Pursuant to 28 U.S.C. § 1446(d), defendant will promptly give written notice of

the filing of this Notice of Removal to plaintiffs.

14. Pursuant to 28 U.S.C. § 1446(d), defendant will promptly file a copy of this

Notice of Removal with the Clerk of the King County Superior Court.

WHEREFORE, defendant gives notice that the court action against it in King County

Superior Court has been removed from that court to the United States District Court for the

Western District of Washington.

DATED this 25th day of March, 2015.

Davis Wright Tremaine LLP Attorneys for Defendant

By s/Robert J. Maguire By s/Taylor S. Ball By s/John A. Goldmark

Robert J. Maguire, WSBA #29909 Taylor S. Ball, WSBA #46927 John A. Goldmark, WSBA # 40980 1201 Third Avenue, Suite 2200 Seattle, Washington 98101 [email protected] [email protected] [email protected]


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206.622.3150 main · 206.757.7700 fax

CERTIFICATE OF SERVICE

I hereby certify that on this date I electronically filed the foregoing with the Clerk of the

Court using the CM/ECF system and I caused to be served in the manner noted below a copy of

the foregoing document on the following:

John P. Sheridan The Sheridan Law Firm, PS Hoge Building, Suite 1200 705 Second Avenue Seattle, WA 98104 Email: [email protected]

BY: U.S. MAIL X HAND DELIVERED – via Legal Messenger OVERNIGHT MAIL FACSIMILE X ELECTRONIC DELIVERY

DATED this 25th day of March, 2015.

Davis Wright Tremaine LLP Attorneys for Defendant

By s/Robert J. Maguire Robert J. Maguire, WSBA #29909


Exhibit A

Case 2:15-cv-00462 Document 1-1 Filed 03/25/15 Page 1 of 16

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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY

GEORGE E. ENGSTROM, an individual, and JOHN E. STOCKWELL, an individual, Plaintiffs, vs. MICROSOFT CORPORATION, a Washington corporation, Defendant.

Case No.: SUMMONS

TO: MICROSOFT CORPORATION

A lawsuit has been started against you in the above-entitled court by George E.

Engstrom and John E. Stockwell, Plaintiffs. Plaintiffs’ claims are stated in the written

complaint, a copy of which is served upon you with this summons.

In order to defend against this lawsuit, you must respond to the complaint by

stating your defense in writing, and by serving a copy upon the person signing this

summons within 20 days after the service of this summons, excluding the day of

service, or a default judgment may be entered against you without notice. A default

COMPLAINT - 1 THE SHERIDAN LAW FIRM, P.S. Attorneys at Law

Hoge Building, Suite 1200 705 Second Avenue Seattle, WA 98104

Tel: 206-381-5949 Fax: 206-447-9206


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judgment is one where plaintiffs are entitled to what they ask for because you have not

responded. If you serve a notice of appearance on the undersigned person, you are

entitled to notice before a default judgment may be entered.

You may demand that the plaintiffs file this lawsuit with the court. If you do

so, the demand must be in writing and must be served upon the person signing this

summons. Within fourteen days after you serve the demand, the plaintiffs must file

this lawsuit with the court, or the service on you of this summons and complaint will

be void.

If you wish to seek the advice of an attorney in this matter, you should do so

promptly so that your written response, if any, may be served on time.

This summons is issued pursuant to Rule 4 of the Superior Court Civil Rules of

the State of Washington.

DATED this 25th day of February, 2015.

THE SHERIDAN LAW FIRM, P.S. By: s/John P. Sheridan

John P. Sheridan, WSBA # 21473 Attorney for Plaintiffs



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Case No.: COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

I. JURISDICTION

1.1 Plaintiffs, George E. (“Eric”) Engstrom and John E. (“Ted”) Stockwell

(hereinafter referred to jointly as “Plaintiffs” and individually by their last names), are

citizens of King County, Washington.

1.2 The defendant, Microsoft Corporation (“Microsoft”), is a Washington

corporation, and is organized and exists under the laws of the State of Washington.

Microsoft has its principal place of business in King County.



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15-2-04785-0 SEA

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II. FACTS

A. Background

2.1 Engstrom worked for Microsoft in the 1990s, and is credited with being one

of three inventors of DirectX, which are the application programming interfaces, upon

which Xbox is based. Engstrom was in charge of creating technology for Windows that

allows software developers to incorporate audio, video, and animation into their programs.

2.2 Stockwell started at Microsoft directly from University of Waterloo in 1987

working as a developer Microsoft’s OS/2, and left Microsoft as a Program Manager in

1998 with a “Director of Audio Technologies” title, working in MSN on acquisition

integrations, business partnerships and agile production of weekly content for MSN 2.0.

2.3 In the second quarter of 2008, Stockwell returned to Microsoft as a Level 67

employee, earning him the distinction of being at the top level of the “Principal Band” at

Microsoft. Approximately 3% of Microsoft’s employees hold this title.

2.4 Engstrom joined Microsoft on October 1, 1991, as a Level 11 employee, the

equivalent of a Level 62 under Microsoft’s modern system. He was promoted in

September 1995 out of band to Level 13, the modern equivalent of a Level 65, for his

contributions to DirectX. This was a very rare “double promotion” at the time, but moved

him two whole bands in the modern system. Engstrom was instrumental in 1997

negotiations with Intel Corp. He convinced the chipmaker to adopt the Microsoft

multimedia package, DirectX, rather than a competing product from Sun Microsystems.

Engstrom was also successful in convincing Microsoft to allow his team to enable

Windows 98 to play DVDs, making it the first Operating System that could play movies.



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2.5 In another Engstrom-piloted deal, Microsoft purchased a company called

Dimension X, which, at the time, was working with a third company, Marimba, that had

ties to Netscape Communications Corp.

2.6 In his June 1997 review, Engstrom was promoted to a Level 14 employee,

the equivalent of a Level 68 under Microsoft’s modern system. When Microsoft changed

its leveling system in 1999, Engstrom was made a Level 69 employee, earning him the

distinction of being a “Partner” at Microsoft. Approximately 1% of Microsoft’s employees

hold this title.

2.7 The plaintiffs left Microsoft in 1998 and 1999, respectively, and both

returned in 2008.

2.8 In or about January 2010, General Manager Eric Engstrom began working

for Qi Lu in Microsoft’s Online Services Division (OSD). This is the division responsible

for both Bing and MSN globally.

2.9 Engstrom was hired to lead Bing Mobile Program Management after

interviewing with the President of the Online Services Division Qi Lu, Sr. Vice President

Satya Nadella and Corporate Vice President Erik Jorgensen.

2.10 Qi Lu joined Microsoft in 2008. Lu had been an executive at Yahoo for

many years. At Microsoft, Lu held the positions of president, executive vice president,

and senior partner.

2.11 Over time, Lu surrounded himself with other Yahoo alumni including David

Ku, who was hired in October 2010 as Corporate Vice President, OSD New Initiatives.



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2.12 Heung-Yeung “Harry” Shum, Corporate Vice President of Bing Product

Development, was a close friend of Lu’s from their time together at Carnegie Mellon

University. Lu credited Shum with getting him the job as President of Microsoft’s Online

Services Division.

2.13 Engstrom worked directly for CVP Erik Jorgensen, who reported to Satya

Nadella. Nadella at that time reported to President of the Online Services Division Qi Lu.

2.14 In approximately April 2010, Eric Engstrom hired Senior Director Ted

Stockwell to run Bing Mobile International, at that time, a new group whose charter was

to increase online search share internationally.

2.15 The plaintiffs observed a cultural shift from when they worked at Microsoft

in the 1990s. In the 1990s, innovation drove Microsoft, but under Lu, it began to appear

that innovation was replaced with managing loyalty to one’s supervisors as the primary

concern.

2.16 In or about September 2010, Engstrom and Stockwell developed a strategic

initiative known as Bing as a Platform (“BaaP”).

2.17 At that time, a Microsoft employee who will hereinafter be referred to as

John Doe was working in Microsoft’s Search Technology Center Asia, Harry Shum’s

organization. On information and belief, Doe and Shum are close friends, and there was a

mentor relationship between the two.

2.18 Based in part on Doe’s close friendship to an executive of a Microsoft

corporate partner, Shum’s organization loaned Doe to Engstrom and Stockwell’s team in

Bing Mobile International to assist them in pitching a pilot project to the corporate partner.



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2.19 In October 2010, Stockwell attended meetings with Doe pitching the pilot

project. Stockwell was impressed with Doe’s abilities. Doe continued working for

Engstrom and Stockwell.

2.20 While working in Korea, Doe incurred travel and business expenses, which

he submitted in expense reports to Stockwell for approval. Stockwell approved a number

of Doe’s expense reports after a cursory review.

2.21 Doe’s expense reports were difficult to analyze because the expenses were

incurred in South Korean Won and then converted to Japanese Yen in the report. It

required a further conversion to U.S. Dollars, which was not provided in the report, for

Stockwell to make sense of it. Stockwell initially believed he was approving $700 expense

reports for dinners with executives from the corporate partner. He later determined that

some of reports he approved were in excess of $7000.

B. Protected Activity

2.22 In or about the end of February or beginning of March 2011, Stockwell

became concerned with vaguely described “entertainment expenses” that Doe submitted

for reimbursement. When the two next met, Doe told Stockwell that he was meeting with

corporate partner executives at “hostess bars”. Stockwell asked Doe if he was “expensing

prostitution services of hostesses,” which Doe denied.

2.23 Stockwell soon realized that the expense reports Doe had filed were an

entire order of magnitude greater than what Stockwell initially understood. Stockwell

notified Engstrom, his manager, about the size of the expenses he had approved and told

him that he believed Doe was “expensing hostess bars” and potentially prostitution.



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Stockwell and Engstrom were both aware that in Korea and other parts of Asia, “hostess

bars” often provide sexual services to their customers.

2.24 Engstrom reported to his boss, Corporate Vice President Erik Jorgensen,

that he and Stockwell believed Doe was “expensing hostess bars” and potentially

prostitution. Jorgensen referred Engstrom and Stockwell to Human Resources Manager

Jeff Williams, who received the same report from Plaintiffs.

2.25 The Foreign Corrupt Practices Act is a clear expression of public policy that

companies such as Microsoft must make and keep books, records, and accounts, which, in

reasonable detail, accurately and fairly reflect and do not mischaracterize the transactions

and dispositions of the assets of the company.

2.26 On March 22, 2011, Stockwell provided Williams a spreadsheet showing

more than $22,000 in “entertainment expenses” that Doe incurred while assigned to work

on Stockwell’s team in Korea.

2.27 Microsoft commenced an investigation into Doe’s expense reports.

Engstrom and Stockwell then asked to not have to approve further expense reports from

Doe until the investigation was complete.

2.28 As a part of the annual performance evaluation, Microsoft employees

receive a rating. “1” is the highest rating and 5 is the lowest rating given. Most

employees receive ratings of “3”. A “4” rating is below average and can subject an

employee to difficulties transferring, below average stock options (if any), and lower

bonus and pay increase (if any). A “5” rating is a poor performance rating that has certain



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consequences, including preventing the employee from transferring out of his division, no

stock options, no bonus, no salary increase, and likely discharge.

2.29 In or around June 2011, Stockwell’s rating of Doe reflected the expense

voucher issue and other performance issues.

2.30 In or about June 2011, as Microsoft’s investigation was ongoing, HR

Manager Williams called Stockwell at home after hours and asked him to drop the

complaint against Doe and to raise his performance rating of Doe.

2.31 Stockwell responded that he would do as requested, but only if CVP

Jorgenson sent him an email asking that he agree to the plan and confirming what was

requested. HR Director Williams responded, “Oh, wow” and dropped the request.

C. Retaliation

2.32 Microsoft retained John Doe. The company raised Doe’s performance rating

without Stockwell or Engstrom’s involvement, which is a significant departure from

company practice. It also permitted Doe to transfer out of the division. Stockwell was told

that Harry Shum had stepped in to dismiss the charges against Doe.

2.33 Management of the Bing as a Platform initiative that Engstrom and

Stockwell developed was taken away from the pair. Following their removal from the

initiative they developed, their former managers released and publicly touted the immense

potential of Bing as a Platform. Qi Lu, the President of the Online Services Division, was

quoted in the press as saying, “Bing as a platform presents the universal platform.”

2.34 Still, after Engstrom and Stockwell reported Doe’s expense reports, their

success in developing the BaaP initiative went unacknowledged. During the 2011 annual



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review process, Engstrom’s manager told him that Stockwell and his team would receive

performance ratings of “4”, signifying that it would likely be an “improvement” if

Microsoft replaced them. Engstrom and Stockwell reported to management that this

appeared to be retaliation and the ratings for Stockwell and his team were adjusted to “3.”

2.35 Engstrom, for his part, still received a performance rating of “4” in the 2011

annual review. Additionally, within months of reporting concerns that Doe could be

“expensing hostess bars”, Engstrom was threatened with a demotion from Level 70 to

Level 68. CEO Steve Ballmer blocked this demotion in 2011.

2.36 After reporting Doe, Engstrom and Stockwell were unassigned from the

potent BaaP initiative and given a significantly smaller team than before (down from

approximately 100 to roughly 5). They developed and presented phased plans for their

new assignment, but their managers declined to implement their plans.

2.37 Sensing that his efforts in Bing Mobile International went unsupported,

Engstrom took the position of Engineering Manager of the User-Centric Advertising team

within CVP David Ku’s organization (Microsoft Advertising). There, Engstrom reported

to Peter Mansour, his former subordinate. After Mansour left Microsoft, Engstrom took

over Mansour’s General Manager role, but then only as “interim,” which was announced

to Engstrom’s team in an email without Engstrom’s prior knowledge. This was a

significant departure from company practice. Engstrom was subsequently rolled into the

team of another direct report of David Ku's, who had worked for Lu and Ku at Yahoo.

2.38 In or about February 2012, Stockwell was told that Bing Mobile

International no longer had a role for him to fill. Stockwell joined Engstrom’s team as the



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Senior Director of Online Advertising, within the Online Service Division’s Advertising

group; despite the fact that Corporate Vice President David Ku initially indicated to

Stockwell that there were no openings in the Advertising group for him.

2.39 In or about June 2012, Engstrom invited CVP David Ku to meet with him

and his User-Centric Advertising (“UCA”) team. At the meeting, to the team’s surprise

David Ku referred to Engstrom as “his brother” but forbade Engstrom from speaking.

When Stockwell attempted to fill the role of team lead and ask “soft-ball” questions of Ku

for the team’s benefit, Ku began to dismiss Stockwell as well, asking at one point “Does

anyone else other than Ted [Stockwell] have a question?”

2.40 In or about June 2012, Engstrom and Stockwell were both given

performance ratings of “4” in the annual review process, again signifying that it would

likely be an “improvement” for Microsoft to replace them. Qi Lu and David Ku each

participated in and influenced the review process. Engstrom’s numeric rating was not

reflective of the glowing written review he was given for the same time period by Ku, who

was not his direct manager. Neither Stockwell nor Engstrom’s ratings were reflective of

their actual performance during that time period.

2.41 In 2012, Qi Lu, President of the Online Service Division successfully

demoted Engstrom from Level 70 to Level 69. On information and belief, Engstrom was

the first partner demoted in band from Level 70 to Level 69. Lu did so only after devising

and applying a new, heretofore unwritten rule that allowed him to demote Engstrom

through a wholly subjective determination of whether he, Lu, would later support



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Engstrom to become a Corporate Vice President, Level 80. Lu determined Engstrom

would not and demoted him to Level 69.

2.42 In 2012, Engstrom and his team developed the “Brazil” initiative, including

the creation of a commercial app. and partnering with large consumer brands in an effort

to compete with Amazon. Additional personnel were promised to Engstrom and necessary

for the success of Brazil, which were not provided.

2.43 Despite not getting promised resources for the project, Stockwell was

successful in lining up numerous potential partners and identifying technology

acquisitions that proved the concept and would support the project.

2.44 Stockwell sourced for Microsoft two of the Bing Venture funds’ first three

announced partnerships, including Selectable Media, which became a high priority

investment of the Bing Fund. Following this significant contribution, Ku rated Stockwell’s

performance as a “5.”

2.45 One potential corporate acquisition discovered by Stockwell received

Approval to Negotiate by 2 of the 3 required decision makers. CVP David Ku was the

lone dissenter. Ku refused to authorize proceeding with the acquisition, claiming he could

only approve funding for 25 additional “heads.” The deal in fact only required 20 “heads”.

This was one of several actions that Ku and his managers took to sabotage the Brazil

project developed by Engstrom, Stockwell, and their team.

2.46 Within days of denying approval to negotiate, Ku shuttered the larger Brazil

project, effectively killing the acquisition for good. Ku’s actions robbed Engstrom and

Stockwell of what would have been an undeniable and significant “win” that management



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would have had to recognize. This action enabled the terminal reviews used to “justify”

Plaintiffs’ terminations.

2.47 In the 2013 annual review process, Engstrom and Stockwell were both given

performance ratings of “5,” Microsoft’s lowest possible rating. Qi Lu and David Ku each

participated in and influenced the review process. Engstrom and Stockwell were rendered

unable to transfer within the company, based on their “5” ratings.

2.48 Yet, in October 2013, Engstrom was recognized with a

“OneG.R.E.A.T_Team” award for his leadership and technical abilities, based on multiple

nominations from across the Microsoft Advertising organization. His picture was hung on

the wall in recognition of his undeniable success.

2.49 In or about July 2013, CVP David Ku took away Engstrom’s entire team,

excepting Stockwell and his direct reports.

2.50 In December 2013, Stockwell was terminated with the few remaining

members of his team. Microsoft contacted Engstrom in December 2013 to terminate him,

but upon being informed that he was on paternity leave at the time, his termination was

delayed until he returned from paternity leave in January 2014.

2.51 After Engstrom and Stockwell were terminated, Microsoft restarted portions

of the Brazil project that they had conceived under another name.

D. Damages

2.52 The plaintiffs suffered damages proximately caused by the actions of the

defendant as set forth below.



Tel: 206-381-5949 Fax: 206-447-9206


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2.53 Microsoft is liable for the actions of its officers, employees, and agents

under the doctrine of respondeat superior.

III. CAUSES OF ACTION

3.1 Plaintiffs reallege the facts set forth in paragraphs 2.1-2.53 above and

incorporates same by reference.

3.2 The facts set forth above state a claim against Microsoft Corporation

for wrongful discharge in violation of public policy.

IV. PRAYER FOR RELIEF

WHEREFORE, plaintiffs pray for relief as follows:

4.1 Damages for back pay, front pay, lost benefits, in an amount to be

proved at trial;

4.2 Damages for emotional distress, loss of enjoyment of life, humiliation,

personal indignity, embarrassment, fear, anxiety, and/or anguish;

4.3 Prejudgment interest in an amount to be proved at trial;

4.4 Reasonable attorney fees under RCW 49.48.030;

4.5 Reasonable costs;

4.6 Injunctive relief;

4.7 Compensation for the tax penalty associated with any recovery; and

4.8 Whatever further and additional relief the court shall deem just and

equitable.

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COMPLAINT - 12 THE SHERIDAN LAW FIRM, P.S.

Attorneys at Law Hoge Building, Suite 1200

705 Second Avenue Seattle, WA 98104

Tel: 206-381-5949 Fax: 206-447-9206


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V. DEMAND FOR JURY

5.1 Plaintiff hereby demands that this case be tried before a jury of twelve.






Tel: 206-381-5949 Fax: 206-447-9206


Exhibit B


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Case No.: JURY DEMAND

TO: THE CLERK OF THE COURT AND TO THE DEFENDANT:

The plaintiffs elect to have all claims and all issues tried by a jury of twelve

(12) persons. Plaintiffs have paid to the Clerk of the Court of King County the jury

fee as required by law.

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JURY DEMAND - 1 THE SHERIDAN LAW FIRM, P.S. Attorneys at Law


Tel: 206-381-5949 Fax: 206-447-9206


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JURY DEMAND - 2 THE SHERIDAN LAW FIRM, P.S. Attorneys at Law


Tel: 206-381-5949 Fax: 206-447-9206


case 2:15-cv-00462 document 1 filed 03/25/15 page...

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