Case 2:22-cv-00157-AWA-RJK Document 1 Filed 04/15/22 Page 1 of 9 PageID# 1

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA
Norfolk Division

UNITED STATES OF AMERICA, )

)
Plaintiff, )
) CASE NO.: 2:22-cv-157
v. )
) JURY TRIAL DEMANDED
STEVE’S TOWING, INC., )
)
Defendant. )
__________________________________________)

COMPLAINT

The United States, by and through the undersigned attorneys, alleges as follows:

INTRODUCTION AND NATURE OF ACTION

1. This action is brought by the United States under the Servicemembers Civil Relief

Act (“SCRA”), 50 U.S.C. §§ 3901-4043, against Steve’s Towing, Inc. (“Steve’s Towing”) for

illegally auctioning off, selling, or otherwise disposing of motor vehicles belonging to at least

seven SCRA-protected servicemembers.

2. The purpose of the SCRA is to provide certain protections to servicemembers so

that they can devote themselves fully to the Nation’s defense.

3. One of the SCRA’s protections is that a towing company cannot enforce a storage

lien on a servicemember’s vehicle during, or within ninety days after, a period of military service

without a court order. 50 U.S.C. § 3958.

4. Any court reviewing a request for a court order made under 50 U.S.C. § 3958 may

delay enforcement of the storage lien or adjust the amount of the servicemember’s obligation to

the towing company. Id. at § 3958(b).

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5. When a towing company fails to obtain a court order prior to auctioning off a

servicemember’s vehicle, that servicemember is deprived of his or her right to have a court

decide whether to postpone the sale or adjust the amount of the fees charged to the

servicemember.

JURISDICTION AND VENUE

6. This Court has jurisdiction over this action under 28 U.S.C. § 1331, 28 U.S.C.

§ 1345, and 50 U.S.C. § 4041.

7. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b)(1)-(2),

because Defendant Steve’s Towing is headquartered and conducts business in the Eastern

District of Virginia, and because the events giving rise to this action occurred in this judicial

district.

PARTIES

8. Plaintiff, the United States, is authorized to file suit in any appropriate federal

district court whenever the United States Attorney General has reason to believe that an

individual or entity has engaged in “a pattern or practice of violating” the SCRA, or that “a

violation of [the SCRA] . . . that raises an issue of significant public importance [has occurred].”

50 U.S.C. § 4041(a).

9. Defendant Steve’s Towing is a Virginia corporation in good standing with a

principal address of 5890 Thurston Avenue #B, Virginia Beach, Virginia 23455.

FACTUAL ALLEGATIONS

10. United States Navy Sea, Air, and Land Team (“SEAL”) Team 2 is based at Joint

Expeditionary Base Little Creek-Fort Story (“JEB Little Creek”) in Virginia Beach, Virginia.

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From about October 2019 to about April 2020, members of SEAL Team 2 were deployed

overseas.

11. Prior to deploying with SEAL Team 2 in about October 2019, a Navy Petty

Officer First Class SEAL Team 2 member (hereinafter “SEAL Team member”) parked his 1992

Toyota Land Cruiser HZJ73 and 1987 Toyota 4Runner, both of which had Arizona license plates

and registrations, in a parking lot at the intersection of Helicopter and Cove Roads across from

SEAL Team 2’s headquarters at JEB Little Creek. Stored inside the SEAL Team member’s

Land Cruiser was evidence of his military service in the form of a duffel bag of military

uniforms and a Naval Special Warfare Development Group Sniper challenge coin.

12. Prior to his deployment, the SEAL Team member had his mail forwarded to his

parents’ home address in Arizona.

13. The SEAL Team member has been an active duty member of the United States

Navy continuously since about March 19, 2013.

14. On or about January 3, 2020, Defendant Steve’s Towing towed the SEAL Team

member’s Land Cruiser and 4Runner from the parking lot across from SEAL Team 2’s

headquarters at JEB Little Creek.

15. In January 2020, Defendant Steve’s Towing requested and received from the

Virginia Department of Motor Vehicles (“VA DMV”) two transcripts of vehicle records, one for

the SEAL Team member’s Land Cruiser, and the other for the SEAL Team member’s 4Runner.

The transcripts stated that no automated record was found in Virginia for either vehicle.

16. At no time before or after towing the SEAL Team member’s vehicles did

Defendant Steve’s Towing make any effort to contact the Arizona Department of

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Transportation’s Motor Vehicle Division for information on the vehicles, despite the fact that

both the Land Cruiser and the 4Runner had Arizona license plates.

17. On or about February 7, 2020, Defendant Steve’s Towing filed two Mechanics or

Storage Lien Applications with the VA DMV to record storage liens on the SEAL Team

member’s Land Cruiser and 4Runner. Each of these recorded storage liens was for $970.

18. On or about February 7, 2020, Steven E. Gilliam, the President, Officer, and

Director of Defendant Steve’s Towing, reported to the VA DMV that Defendant Steve’s Towing

had enforced its two $970 storage liens on the SEAL Team member’s Land Cruiser and 4Runner

by purchasing both vehicles from itself for $500 each.

19. On or about February 7, 2020, Edwin L. Gilliam, an individual acting as an agent

of Defendant Steve’s Towing, filed Certificates of Title and Registration with the VA DMV to

have the SEAL Team member’s Land Cruiser and 4Runner titled in the name of Defendant

Steve’s Towing.

20. At no point between January 3, 2020, the date Defendant Steve’s Towing towed

the SEAL Team member’s Land Cruiser and 4Runner, and February 7, 2020, the date Defendant

Steve’s Towing transferred ownership of both of the SEAL Team member’s vehicles into the

company’s name, did Defendant Steve’s Towing obtain a court order allowing the company to

sell, auction off, or otherwise dispose of either vehicle.

21. At no point between January 3, 2020, the date Defendant Steve’s Towing towed

the SEAL Team member’s Land Cruiser and 4Runner, and February 7, 2020, the date Defendant

Steve’s Towing transferred ownership of both of the SEAL Team member’s vehicles into the

company’s name, did the SEAL Team member’s parents receive any correspondence from

Defendant Steve’s Towing.

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22. At all times relevant to this complaint, Defendant Steve’s Towing’s policies and

procedures failed to comply with Section 3958 of the SCRA, 50 U.S.C. § 3958. In fact, the

policies and procedures failed to include any mention at all of the SCRA or the protections it

grants to servicemembers whose vehicles have been towed.

23. At all times relevant to this complaint, Defendant Steve’s Towing’s policies and

procedures did not include using any commercially available database to match vehicle

identification numbers to the vehicles’ current owners and registrants prior to selling, auctioning

off, or otherwise disposing of vehicles it had towed.

24. At all times relevant to this complaint, Defendant Steve’s Towing’s policies and

procedures did not include looking to see what state’s license plate was on any vehicle it towed,

and then obtaining motor vehicle records for that vehicle from that state. Instead, Defendant

Steve’s Towing requested motor vehicle records only from the VA DMV for all vehicles it

towed and subsequently placed a lien on, regardless of which state’s license plate was on the

vehicle.

25. At all times relevant to this complaint, Defendant Steve’s Towing’s policies and

procedures did not include any sort of presumption that vehicles towed from JEB Little Creek or

other military installations were likely to be owned by an SCRA-protected servicemember.

26. At all times relevant to this complaint, Defendant Steve’s Towing’s policies and

procedures did not include any sort of presumption that vehicles containing military uniforms

and/or military related objects were likely to be owned by an SCRA-protected servicemember.

27. At all times relevant to this complaint, the Department of Defense provided

individuals and entities seeking to comply with the SCRA a free automated database run by the

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Defense Manpower Data Center (“DMDC database”) to check whether an individual is an

SCRA-protected servicemember.

28. At all times relevant to this complaint, Defendant Steve’s Towing’s policies and

procedures did not include checking the DMDC database to determine a vehicle owner’s military

status prior to selling, auctioning off, or otherwise disposing of a vehicle without a court order.

29. At all times relevant to this complaint, Defendant Steve’s Towing had no written

policies requiring it to obtain a court order before selling, auctioning off, or otherwise disposing

of a servicemember’s vehicle.

30. At all times relevant to this complaint, it was Defendant Steve’s Towing’s

practice not to seek or obtain court orders prior to enforcing storage liens.

31. The Hampton Roads area of Virginia, which includes Virginia Beach, where

Defendant Steve’s Towing is based, has one of the largest military populations in the United

States. It is home to approximately 83,000 servicemembers.

32. From April 15, 2019, through the date of the filing of this Complaint, Defendant

Steve’s Towing has auctioned off, sold, or otherwise disposed of motor vehicles and personal

effects belonging to at least seven SCRA-protected servicemembers, including the SEAL Team

member, without first obtaining court orders.

SERVICEMEMBER CIVIL RELIEF ACT VIOLATIONS

33. The SCRA provides that “[a] person holding a lien on the property or effects of a

servicemember may not, during any period of military service of the servicemember and for 90

days thereafter, foreclose or enforce any lien on such property or effects without a court order

granted before the foreclosure or enforcement.” 50 U.S.C. § 3958(a)(1) (emphasis added).

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There is no requirement that a servicemember inform the lien holder of his or her military

service.

34. For purposes of 50 U.S.C. § 3958(a)(1), “the term ‘lien’ includes a lien for

storage, repair, or cleaning of the property or effects of a servicemember or a lien on such

property or effects for any other reason.” 50 U.S.C. § 3958(a)(2).

35. Defendant Steve’s Towing’s actions in selling, auctioning off, or disposing of the

vehicles and personal belongings of at least seven servicemembers, including the SEAL Team

member, without court orders are violations of the SCRA that raise an issue of significant public

importance under 50 U.S.C. § 4041(a)(2).

36. Defendant Steve’s Towing’s actions in selling, auctioning off, or disposing of the

vehicles and personal belongings of at least seven servicemembers, including the SEAL Team

member, without court orders constitute a pattern or practice of SCRA violations under 50

U.S.C. § 4041(a)(1).

37. The SEAL Team member and the other servicemembers whose motor vehicles

were sold, auctioned off, or otherwise disposed of during periods of military service without

court orders in violation of the SCRA are “person[s] aggrieved” pursuant to 50 U.S.C. §

4041(b)(2) and have suffered damages as a result of Steve’s Towing’s conduct.

38. Defendant Steve’s Towing’s conduct was intentional, willful, and taken in

reckless disregard for the rights of servicemembers.

PRAYER FOR RELIEF

WHEREFORE, the United States prays that the Court enter an order that:

1. Declares that Defendant Steve’s Towing’s conduct violated the SCRA;

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2. Enjoins Defendant Steve’s Towing, its agents, employees, and successors, and all

other persons and entities in active concert or participation with them, pursuant to 50 U.S.C. §

4041(b)(1), from:

a. selling, auctioning off, or otherwise disposing of the motor vehicles of

SCRA-protected servicemembers without court orders, in violation of the

SCRA, 50 U.S.C. § 3958;

b. failing or refusing to take such affirmative steps as may be necessary to

restore, as nearly as practicable, each identifiable victim of Defendant

Steve’s Towing’s illegal conduct to the position he or she would have

been in but for that illegal conduct; and

c. failing or refusing to take such affirmative steps as may be necessary to

prevent the recurrence of any illegal conduct in the future and to eliminate,

to the extent practicable, the effects of Defendant Steve’s Towing’s illegal

conduct;

3. Awards appropriate monetary damages to each identifiable victim of Defendant

Steve’s Towing’s violations of the SCRA, pursuant to 50 U.S.C. § 4041(b)(2); and

4. Assesses civil penalties against Defendant Steve’s Towing in order to vindicate

the public interest, pursuant to 50 U.S.C. § 4041(b)(3).

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The United States further prays for such additional relief as the interests of justice may

require.

Dated: __________, 2022.

Respectfully submitted,

MERRICK B. GARLAND
Attorney General

JESSICA D. ABER KRISTEN CLARKE

United States Attorney Assistant Attorney General
Eastern District of Virginia Civil Rights Division

LAUREN WETZLER SAMEENA SHINA MAJEED

Chief, Civil Division Chief
Assistant United States Attorney Housing and Civil Enforcement Section
Eastern District of Virginia
ELIZABETH A. SINGER
Director
U.S. Attorneys’ Fair Housing Program
Housing and Civil Enforcement Section
/s/
DEIRDRE G. BROU TANYA ILONA KIRWAN
Assistant United States Attorney Trial Attorney
Attorney for Plaintiff United States Maryland Bar
United States Attorney’s Office Attorney for Plaintiff United States
2100 Jamieson Avenue Housing and Civil Enforcement Section
Alexandria, VA 22314 Civil Rights Division
Tel: (703) 299-3770 U.S. Department of Justice
Fax: (703) 299-3983 4 Constitution Square
Email: deirdre.g.brou@usdoj.gov 150 M Street, N.E., Suite 8.125
Washington, D.C. 20530
SEAN D. JANSEN Tel: (202) 532-3826
Assistant United States Attorney Fax: (202) 514-1116
Va. State Bar No. 82252 Email: tanya.kirwan@usdoj.gov
Attorney for Plaintiff United States
United States Attorney’s Office
101 W. Main Street, Suite 8000
Norfolk, VA 23510
Tel.: (757) 441-6331
Fax: (757) 441-6689
Email: sean.jansen@usdoj.gov

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JS 44 (Rev. 0) 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

United States of America Steve's Towing, Inc.

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant Virginia Beach, Virginia
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Deirdre G. Brou, Assistant U.S. Attorney; United States Attorney's Office Registered Agent: Ronald M. Gates. Esq., 200 Bendix Road, Suite
for the Eastern District of Virginia; 2100 Jamieson Avenue, Alexandria, 300, Virginia Beach, Virginia 23452
Virginia 22314; (703) 299-3770

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State

u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 3729(a))
u 140 Negotiable Instrument Liability u 367 Health Care/ u 400 State Reapportionment
u 150 Recovery of Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 410 Antitrust
& Enforcement of Judgment Slander Personal Injury u 820 Copyrights u 430 Banks and Banking
u 151 Medicare Act u 330 Federal Employers’ Product Liability u 830 Patent u 450 Commerce
u 152 Recovery of Defaulted Liability u 368 Asbestos Personal u 835 Patent - Abbreviated u 460 Deportation
Student Loans u 340 Marine Injury Product New Drug Application u 470 Racketeer Influenced and
(Excludes Veterans) u 345 Marine Product Liability u 840 Trademark Corrupt Organizations
u 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY u 480 Consumer Credit
of Veteran’s Benefits u 350 Motor Vehicle u 370 Other Fraud u 710 Fair Labor Standards u 861 HIA (1395ff) u 485 Telephone Consumer
u 160 Stockholders’ Suits u 355 Motor Vehicle u 371 Truth in Lending Act u 862 Black Lung (923) Protection Act
u 190 Other Contract Product Liability u 380 Other Personal u 720 Labor/Management u 863 DIWC/DIWW (405(g)) u 490 Cable/Sat TV
u 195 Contract Product Liability u 360 Other Personal Property Damage Relations u 864 SSID Title XVI u 850 Securities/Commodities/
u 196 Franchise Injury u 385 Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) Exchange
u 362 Personal Injury - Product Liability u 751 Family and Medical u 890 Other Statutory Actions
Medical Malpractice Leave Act u 891 Agricultural Acts
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 790 Other Labor Litigation FEDERAL TAX SUITS u 893 Environmental Matters
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: u 791 Employee Retirement u 870 Taxes (U.S. Plaintiff u 895 Freedom of Information
u 220 Foreclosure u 441 Voting u 463 Alien Detainee Income Security Act or Defendant) Act
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRS—Third Party u 896 Arbitration
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 u 899 Administrative Procedure
u 245 Tort Product Liability Accommodations u 530 General Act/Review or Appeal of
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION Agency Decision
Employment Other: u 462 Naturalization Application u 950 Constitutionality of
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration State Statutes
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
u 1 Original u 2 Removed from u 3 Remanded from u 4 Reinstated or u 5 Transferred from u 6 Multidistrict u 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Servicemembers Civil Relief Act ("SCRA"), 50 U.S.C. § 3958
VI. CAUSE OF ACTION Brief description of cause:
enforced storage liens on servicemembers' vehicles without first obtaining court orders
VII. REQUESTED IN u CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
D
04/15/2022
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

 Case 2:22-cv-00157-AWA-RJK Document 1-1 Filed 04/15/22 Page 2 of 2 PageID# 11
JS 44 Reverse (Rev. 0)

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) 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.
(b) 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.)
(c) 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)".

,, 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.)

,,, 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.

,9 Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.

9 Origin. Place an "X" in one of the seven 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.
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 – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.PLEASE
NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due tochanges in
statue.

9, 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

9,, 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.

9,,, 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.