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Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 1 of 11

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA
GREGORY SELDEN,
Plaintiff, Individually and on
Behalf of all Others Similarly Situated,

Civil Action: 1:16-cv-00933

v.
AIRBNB, INC.
Defendant.
________________________________________________________________________
CLASS ACTION COMPLAINT

Plaintiff Gregory Selden, individually, and on behalf of all others similarly


situated, by and through his counsel Emejuru & Nyombi L.L.C, brings this action against
Airbnb., Inc. (Airbnb), and states as follows:
NATURE OF THE ACTION
1. Plaintiff maintains that pursuant to FRCP 23, the class is so numerous that joinder
of all members is impracticable, there are questions of law or fact common to the
class; the claims or defenses of the representative parties are typical of the claims
or defenses of the class; and the representative parties will fairly and adequately
protect the interests of the class.
2. This action is necessary to protect the civil rights of Plaintiff and all others
similarly situated who have been injured by the pertinent discriminatory acts or
practices committed by Airbnbs host agents, representatives, servants of any
type.

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 2 of 11

3. This action is necessary and increasingly important to protect the civil rights of
Plaintiffs and all others similarly situated that participate in the sharing
economy in which businesses connect people offering goods and services with
other people who want to pay for them.
4. The reason for not joining all potential class members as Plaintiffs is that upon
information and belief, there are thousands of potential plaintiffs making it
impractical to bring them before the Court. All plaintiffs participate in the sharing
economy, including that of Defendant Airbnb, its agents, representatives,
employees, and/or servants. The discriminatory actions complained of were taken
in the line and scope of such individuals employment, agency or representation.
5. There are many persons, both in Plaintiffs residential district and in regions
surrounding Defendant who are similarly situated that have been affected and the
question to be determined is one of common and general interest to many persons
constituting the Class to which Plaintiff belongs and the group is so numerous as
to make it impracticable to bring them all before the Court, for which reason
Plaintiff initiates this litigation for all persons similarly situated pursuant to FRCP
23.
6. Issues and questions of law and fact common to the members of the class
predominate over questions affecting individual members and the claims of
Plaintiffs are typical of the claims of the proposed class.
7. The maintenance of this litigation as a Class Action will be superior to the other
methods of adjudication in promoting the convenient administration of justice.

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 3 of 11

8. Plaintiff Gregory Selden will fairly and adequately assert and protect the interests
of the Class.
JURISDICTION
9. Personal jurisdiction exists over Defendant as it does business and has the
necessary minimum contacts within the District of Columbia. The defendant has
purposely availed itself of the privilege of conducting activities with in the
District of Columbia and invokes the benefits and protection of the laws of the
District of Columbia.
10. Subject matter jurisdiction exists through diversity jurisdiction pursuant to
28.U.S.C. 1332 as the action is between citizens of different states and the
amount in controversy, exclusive of interest and costs, exceeds seventy-five
thousand dollars ($75,000.00).
11. Federal Question jurisdiction exists because this lawsuit is brought under federal
laws pursuant to 28 U.S.C. 1331
VENUE
1. Venue is proper pursuant to 28 U.S.C. 1391(b)(1) as Defendant resides and
conducts business in this judicial district and have their principal offices in this
judicial district.
2. Further venue is also proper in this judicial district pursuant to 28 U.S.C.
1391(b)(2) because a substantial part of the events or omissions giving rise to
this claim occurred in this judicial district. Mr. Selden made the application for
accommodation with Defendant while physically present in the District of
Columbia.

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 4 of 11

PARTIES
1. Plaintiff Gregory Selden is a current resident of Virginia.
2. Defendant Airbnb Inc. (hereinafter Airbnb) is a duly registered business
incorporated in the State of California and with its principal offices located at 888
Brannan Street, 4th Floor, San Francisco, CA 94197.
FACTUAL ALLEGATIONS
1. Plaintiff Gregory Selden is a 25 year-old African American [black] male. At the
time of the allegations set forth herein, Mr. Seldon was physically present in
Washington DC.
2. In or around March 2015, Plaintiff Gregory Selden planned a trip to go to
Philadelphia, Pennsylvania with some friends for a weekend vacation. Prior to
executing his trip, a friend traveling with Mr. Selden suggested that Mr. Selden
use the housing accommodation service known as Airbnb.
3. The Airbnb platform is accessible through an internet portal and through a mobile
application.
4. In or around March 2015, while at his job in Washington D.C., Mr. Seldon signed
up for Airbnb on his mobile device through another mobile application platform,
Facebook. Subsequently, Mr. Selden used the mobile application platform to book
accommodation on the Airbnb platform.
5. As a young global traveler, Mr. Selden understood that the platform was a
cheaper option amongst the other competitive public accommodation operations
in the United States.

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 5 of 11

6. Mr. Seldens Airbnb platform profile included his face as well as other details
such as his name, education, sex, age and residential location.
7. For the first time, Mr. Selden attempted to use the online sharing platform for
public accommodation in or around March 2015.
8. Airbnb agents or employees, representatives or servants are classified specifically
as Airbnb Hosts for the web based sharing platform
9. In or around March 2015, the Defendants Host agents public accommodation
listing included favorable dates available for Mr. Selden in Philadelphia,
Pennsylvania.
10. In or around March 2015, Mr. Selden inquired about the availability of a
Philadelphia, Pennsylvania accommodation from [a person listed with a Screen
name Paul] an Airbnb Host agent, representative or employee. Mr. Selden sought
to obtain the accommodation from the agent or employee.
11. In or about March 2015, Mr. Selden heard back from the Host agent rejecting his
request for the vacation accommodation. The Host agent indicated that the
accommodation was not available.
12. Soon after and on the same day he was rejected by the Airbnb agent or employee,
Mr. Selden stumbled across the same listing by Paul the Airbnb agent or
employee indicating that the accommodation on the platform was still available.
This is despite the fact that the Airbnb agent or employee told Mr. Selden that the
accommodation was not available.

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 6 of 11

13. With the belief that he was discriminated against because of his race, Mr. Selden
created two imitation Airbnb profiles in order to seek accommodation once again
for the same Host agent or employee listing that previously rejected him.
14. The first imitation profile created by Selden was named Jessie. Jessie was
created with similar demographics as Selden. However, the race of the imitation
profile was white. From the Host agents view, only Jessies name, profile picture,
location and how long the imitation had been a member of the Airbnb community
(since March 2015) were visible.
15. The second imitation profile created by Selden was named Todd. Todd was an
older white male and no education information was entered for him. Only Todds
name, profile picture, location and how long the imitation had been a member of
the Airbnb community (since March 2015) were visible.
16. Selden used the two imitation profiles to request accommodations for the exact
same dates and from the exact same Airbnb Host agent that rejected him.
17. Subsequently, and on the same day in March 2015, the same Airbnb Host agent
that originally rejected Selden immediately accepted both of the white imitation
Airbnb accounts.
18. Selden contacted Airbnb indicating to the entity that its Host agent or employee
discriminated against him because he was African American, but Airbnb did not
respond.
19. Subsequently, Selden confronted Paul the Airbnb Host agent regarding the
discrimination. However, the Airbnb host agent merely shamed Selden for

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 7 of 11

speaking out against the intentional discriminatory act. Specifically, the Host
agent stated that Selden or people like [him] were simply victimizing [himself].
20. Defendants host had no legitimate reason for denying Mr. Selden
accommodation . Any asserted reasons were a pretext for discrimination.
21. Selden continued to contact Airbnb through March 2015. However, his cries to
Airbnb would fall on deaf ear.
22. Selden took his complaint of discrimination to twitter, which spawned the viral
hashtag titled #airbnbwhileblack thousands of retweets from individuals who
experienced the exact same disparate treatment from Airbnb Host agents,
representatives, servants or employees.
COUNT 1
VIOLATION OF TITLE II OF THE CIVIL RIGHTS ACT OF 1964
23. Title II of the Civil Rights Act of 1964 explicitly prohibits discrimination in
places of public accommodation, such as hotels, restaurants, movie theatres and
sports arenas.
24. Airbnb is an establishment affecting interstate commerce or supported in their
activities by the State as places of public accommodation and lodgings.
25. Specifically, Airbnb is an inn, hotel, motel or other establishment which provides
lodging to transient guests.
26. Plaintiff Gregory Selden was denied full and equal enjoyment of the goods,
services, facilities, privileges, advantages, and accommodations of the public
accommodation as defined in 2000a of this count because of his race as an

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 8 of 11

African American. The same discriminatory actions have been unleashed on


persons who are similarly situated to Plaintiffs.
27. WHEREFORE, for the claim of Violation of Title II of the Civil Rights Act of
1964, Plaintiff, individually, and on behalf of others prays for judgment against
Defendant for all damages allowable by law, including injunctive, statutory
damages, compensatory damages, punitive damages, pre-judgment interest at the
legal rate, post-judgment interest at the judgment rate, attorney's fees as may be
awarded by the Court, the costs of this action, equitable relief, and such other and
further relief as may appear warranted by this action.
COUNT II
VIOLATION OF FEDERAL CIVIL RIGHTS STATUTE 42 U.S.C. 1981
28. Plaintiff incorporates by reference all paragraphs of this Complaint as though
fully stated herein seriatim
29. By the above acts, Defendant violated 42 U.S.C 1981 by discriminating
against Mr. Selden individually and others similarly situated because of his
race as an African American[black].
30. Section 1981 guarantees freedom from racial discrimination in the making,
enforcement performance, modification, and termination of contracts.
31. Section 1981 also guarantees enjoyment of all benefits, privileges, terms,
and conditions of the contractual relationship.
32. Plaintiffs use of the airbnb service for housing accommodation falls under
section 1981 protection.

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 9 of 11

33. Airbnbs agent or employee refused to provide rental accommodations to Plaintiff


because he was African American.
34. Airbnbs agent, representative, servant or employee Hosts purposefully and
intentionally discriminated against Plaintiff because he was an African American
by race. Any reasons given by Defendants agent Airbnb host were a mere pretext
for discrimination.
35. WHEREFORE, for the claim of violation of Federal Civil Rights Statute 42
U.S.C. 1981, Plaintiff, individually and on behalf of others prays for judgment
against Defendant for all damages allowable by law, including injunctive relief,
statutory damages, unlimited compensatory damages, punitive damages, prejudgment interest at the legal rate, post-judgment interest at the judgment rate,
attorney's fees as may be awarded by the Court, the costs of this action, equitable
relief, and such other and further relief as may appear warranted by this action.
COUNT III
VIOLATION OF FAIR HOUSING ACT
36. Plaintiff incorporates by reference all paragraphs of this Complaint as though
fully stated herein seriatim.
37. The Fair Housing Act prohibits discriminatory practices on the basis of race by
housing agents for rental accommodation.
38. Specifically, the Airbnb agent was not truthful in disclosing information
concerning the availability of housing. Any reasons given by Defendants agent
were a mere pretext for discrimination.

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 10 of 11

39. Plaintiff was the object of a misrepresentation made unlawful under the Fair
Housing Act and suffered the precise injury the statute was designed to guard
against.
40. WHEREFORE, for the claim of violation of the Fair Housing Act, Plaintiff,
individually and on behalf of others prays for judgment against Defendant for all
damages

allowable

by

law,

including

injunctive,

statutory

damages,

compensatory damages, punitive damages, pre-judgment interest at the legal rate,


post-judgment interest at the judgment rate, attorney's fees as may be awarded by
the Court, the costs of this action, equitable relief, and such other and further
relief as may appear warranted by this action.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff, Gregory Selden, and on behalf of all others prays for
judgment in his favor and against Defendant Airbnb for: any and all damages
acceptable by law, including compensatory damages, statutory damages, punitive
damages, pre-judgment interest at the legal rate, post-judgment interest at the
judgment rate, attorney's fees as may be awarded by the Court, the costs of this
action, equitable relief, relief pleaded in the preceding paragraphs, injunctive
relief and such other and further relief as Plaintiff may be entitled to by bringing
this action.

JURY DEMAND
PLAINTIFF DEMANDS A TRIAL BY JURY IN THIS CASE
Respectfully submitted on this 17th day of May 2016.

10

Case 1:16-cv-00933 Document 1 Filed 05/17/16 Page 11 of 11

EMEJURU & NYOMBI LLC


By: / s / Ikechukwu Emejuru______________
Ikechukwu Ike Emejuru, Esq, Bar No. 19262
Andrew Nyombi, Esq, MD0010
Emejuru & Nyombi L.L.C.
Attorneys and Counselors at Law
8403 Colesville Road
Suite 1100
Silver Spring, MD 20910
Telephone: (240) 638 2786
Facsimile: 1-800-250-7923
iemejuru@enylaw.com
anyombi@enylaw.com
Attorneys for Plaintiff Individually and others similarly situated

11

Case 1:16-cv-00933 Document 1-1 Filed 05/17/16 Page 1 of 2

JS 44 (Rev. 12/12)

CIVIL COVER SHEET

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS

DEFENDANTS

GREGORY SELDEN

Airbnb, Inc.

(b) County of Residence of First Listed Plaintiff

County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES)


NOTE:

(IN U.S. PLAINTIFF CASES ONLY)


IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

Attorneys (If Known)

(c) Attorneys (Firm Name, Address, and Telephone Number)


Emejuru & Nyombi LLC
8403 Colesville Road, Suite 1100
Silver Spring, Maryland 20910

Unknown

II. BASIS OF JURISDICTION (Place an X in One Box Only)


1

U.S. Government
Plaintiff

Federal Question
(U.S. Government Not a Party)

U.S. Government
Defendant

Diversity
(Indicate Citizenship of Parties in Item III)

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff


(For Diversity Cases Only)
PTF
Citizen of This State
1

DEF
1

and One Box for Defendant)


PTF
DEF
Incorporated or Principal Place
4
4
of Business In This State

Citizen of Another State

Incorporated and Principal Place


of Business In Another State

Citizen or Subject of a
Foreign Country

Foreign Nation

IV. NATURE OF SUIT (Place an X in One Box Only)


CONTRACT

TORTS

110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise

REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education

FORFEITURE/PENALTY

PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement

625 Drug Related Seizure


of Property 21 USC 881
690 Other

BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark

LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act

SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))

FEDERAL TAX SUITS


870 Taxes (U.S. Plaintiff
or Defendant)
871 IRSThird Party
26 USC 7609

OTHER STATUTES

375 False Claims Act


400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes

IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions

V. ORIGIN (Place an X in One Box Only)


1 Original
Proceeding

2 Removed from
State Court

Remanded from
Appellate Court

4 Reinstated or
Reopened

5 Transferred from
Another District

6 Multidistrict
Litigation

(specify)

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Title II of Civil Rights Act of 1964, 42 U.S.C. Section 1981, Fair Housing Act

VI. CAUSE OF ACTION Brief description of cause:


Fair Housing

CHECK IF THIS IS A CLASS ACTION


VII. REQUESTED IN
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
IF ANY
JUDGE
DATE

CHECK YES only if demanded in complaint:


Yes
No
JURY DEMAND:

DEMAND $

DOCKET NUMBER

SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY


RECEIPT #

AMOUNT

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MAG. JUDGE

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JS 44 Reverse (Rev. 12/12)

Case 1:16-cv-00933 Document 1-1 Filed 05/17/16 Page 2 of 2

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44


Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a)

(b)

(c)

Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II.

Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III.

Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV.

Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.

V.

Origin. Place an "X" in one of the six boxes.


Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407.
When this box is checked, do not check (5) above.

VI.

Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII.

Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.

Case 1:16-cv-00933 Document 1-2 Filed 05/17/16 Page 1 of 2


AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT


for the

District
of Columbia
__________
District
of __________
)
)
)
)
)
)
)
)
)
)
)
)

Gregory Selden

Plaintiff(s)

v.
Airbnb., Inc.

Defendant(s)

Civil Action No. 1:16-cv-00933

SUMMONS IN A CIVIL ACTION


To: (Defendants name and address) Airbnb., Inc.
888 Brannan Street, 4th Floor
San Francisco, CA 94197

A lawsuit has been filed against you.


Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,
whose name and address are: Ikechukwu Emejuru
8403 Colesville Road
Suite 1100
Silver Spring, MD 20910

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

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

Case 1:16-cv-00933 Document 1-2 Filed 05/17/16 Page 2 of 2


AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No. 1:16-cv-00933


PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

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


on (date)

; or

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

, and mailed a copy to the individuals last known address; or

I served the summons on (name of individual)

, who is

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


on (date)

; or

I returned the summons unexecuted because

; or

Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

0.00

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

Date:
Servers signature

Printed name and title

Servers address

Additional information regarding attempted service, etc:

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