Case: 1:23-cv-01720 Document #: 1 Filed: 03/20/23 Page 1 of 8 PageID #:1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

RUDOLPH ISLEY,

Plaintiff, Case No. 23-cv-1720

vs.

RONALD ISLEY, DEMAND FOR JURY TRIAL

Defendant.

COMPLAINT

Plaintiff Rudolph Isley, by his attorneys, Reitler Kailas & Rosenblatt LLP and Mandell

Menkes LLC, as and for his Complaint against the Defendant herein, alleges as follows:

PRELIMINARY STATEMENT

1. Plaintiff brings this declaratory action pursuant to 28 U.S.C. §§ 2201 and 2202 in

order to obtain (A) a judicial declaration that all U.S. common-law and statutory rights in and to

a a THE ISLEY BROTHERS ( Ma ) a Pa a

Defendant equally, because the Mark is an asset of a partnership in which Plaintiff and

Defendant are the sole and equal members; a (B) a a a a Pa

share of all proceeds received by Defendant in connection with the provision of services and sale

of goods under the Mark within the applicable limitations period prior to the filing of this

Complaint.

JURISDICTION AND VENUE

2. This Court has diversity jurisdiction in this matter pursuant to 28 U.S.C. §1332

because Plaintiff and Defendant are citizens of different States and the amount in controversy

exceeds the minimum jurisdictional amount of $75,000.

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3. Venue lies within this judicial district pursuant to 28 U.S.C. §§ 1391(b)(2) in that

a substantial part of the events or omissions giving rise to the claim occurred in this judicial

district, because Defendant has engaged in use and exploitation of the Mark in commerce in this

judicial district.

PARTIES

4. Plaintiff Rudolph Isley ( R ), now 83 years of age, is a resident of the

State of Illinois and a founding member of the world-famous musical group The Isley Brothers

(the G ).

5. Defendant Ronald Isley ( R a ), now 81 years of age, is a resident of the State

of Missouri and, like Rudolph, is a founding member of the Group.

6. The Group was formed in Cincinnati, Ohio in or about 1954 by Rudolph, his

brother Ronald, a ,O K I Jr. ( O K ), a .

FACTUAL BACKGROUND

7. The three brothers, Rudolph, Ronald, an O K ,( B )a a

intended to operate and did operate the Group as a common-law partnership.

8. The Brothers at all times equally shared in t G a .

9. The Brothers at all times equally shared in the control of the business of the

Group.

10. The Brothers at all times equally contributed capital to operate the business of the

Group.

11. The Group collectively owned property, including without limitation the record

label T-Neck Records, Inc. a New Jersey corporation; the music publisher Teaneck Pub. Co., a

New Jersey corporation; the music publisher Bovina Music, Inc., a New York corporation;

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approximately 300 acres of land in upstate New York; and more than 100 registered copyrights

in musical compositions jointly authored by the Group.

12. The Group at all times collectively entered into contracts with providers of goods

a G a .

13. The Group actively toured and recorded between 1954 and 1973, and recordings

made and released by the Group during that period are still being manufactured and sold in

a Ma THE ISLEY BROTHERS ( Ma )a

mark.

14. I a 1973, G touring and recording personnel expanded to

Pa E I and Marvin Isley, and P a brother-in-law

Chris Jasper.

15. The new personnel left the Group in or around 1984 to perform under the name

Isley Jasper Isley.

16. Throughout this period, the Group remained an equal partnership under the sole

ownership, direction and control ,R ,R a ,a OK I .

17. OK a Ma 31, 1986.

18. Pursuant to Letters of Administration issued by the State of New Jersey Bergen

C S a C S 24, 1986, O K a Pa a

Defendant equally, leaving each with a 50% share of ownership in the Group and the Mark.

19. In recognition of the foregoing, both Plaintiff and Defendant are currently 50%

owners of all rights and interests of the Group, with neither party having the authority to enter

into deals concerning the Group or the exploitation of the Mark without consent of the other

party.

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20. In 1989, a a a , Plaintiff

discontinued his performances with the Group and did not participate in making new recordings

after that date, but has remained active in promoting and managing the Group ,

including a major multi-million dollar music publishing deal in 2018, under which Plaintiff and

Defendant each received 50%, and most recently the negotiation of a lucrative license deal for

G S a al that was aired on the broadcast of the 2023

Super Bowl.

21. The Group has been highly successful and has won many awards and accolades

for their music, including induction into the Rock and Roll Hall of Fame in 1992 and receiving

gold, platinum or multi-platinum certification of thirteen of their albums by the Recording

Industry Association of America.

22. The Group received the Grammy Lifetime Achievement Award in 2014, and was

inducted into the Songwriters Hall of Fame in June of 2022.

23. The G have sold over 18 million units in the United States alone.

With their first major hit charting in 1959 ("Shout"), and their most recent hit in 2022 (a remake

G 1975 Ma M Sa I A a Girl, Beyoncé with Ron Isley and

T I B ) they are among the few artists ever to have been recognized on the

Billboard Hot 100 chart with new music in six different decades.

24. T T I B Pa ( G

R ) a a a Ma a a .

25. Until the date of this Complaint, Plaintiff has continued to receive royalties

a a G Recordings.

26. Ma G R a a a -hop and rap

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producers under license from the Group, and Plaintiff continues to receive payments for such

uses of the Group Recordings.

27. Accordingly, all the goodwill in the Mark from 1954 until the present have inured

to the Group and not to any individual member, and Plaintiff has not abandoned his rights in the

Mark.

28. A OK death, the Group established a Delaware corporation, Isley

Brothers Royalty Venture I SPC Inc. ( IBRV ).

29. The IBRV was owned equally by Rudolph and Ronald and performed certain

business and administrative functions on behalf of the Group a G a

income.

30. In June of 2000, Rudolph and Ronald established a Delaware limited liability

a ,I B L.L.C. ( LLC ), a a behalf of

the Group in connection with a certain identure entered into between the LLC and Manufacturers

and Traders Trust Company and a related Note Purchase Agreement for the sale of notes issued

under the indenture.

31. The members of the LLC were Rudolph and Ronald, and the IBRV was named as

Managing Member. The LLC is classified by the IRS as a partnership, and every year since the

formation of the LLC it has issued Schedule K-1 income statements to Rudolph and Ronald for

submission to the IRS with Form 1065, U.S. Return of Partnership Income.

RONALD S BELATED CHALLENGE TO OWNERSHIP OF THE MARK

32. On November 2, 2021, Ronald, acting without the knowledge or approval of

Rudolph, filed an application to register exclusive rights in the Mark in the U.S. Patent and

Trademark Office in his own personal name, for the following goods and services: Visual

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recordings and audiovisual recording a a a a ( A a ).

33. The Application was approved by the U.S. Patent and Trademark Office, and

Pa , a gistered on August 16, 2022 ( R a ). A

Registration is attached as Exhibit A.

34. Significantly, the Application and Registration claim exclusive rights in the Mark

dating back to a priority date of 1954, when the Brothers first formed the Group.

35. Contradicting the claimed priority date, the Application, and Registration, assert

that Defendant Ronald Isley claims sole exclusive rights in and to the Mark in his individual

capacity.

36. Counsel for Defendant Ronald Isley has asserted in correspondence that

Defendant alone has exclusive ownership of the Mark, see letter attached as Exhibit B.

37. These assertions in correspondence to Plaintiff, and under penalty of perjury to

the U.S. Patent and Trademark Office, are false.

38. Upon information and belief, Defendant has within the past year offered goods

and services in commerce to the public under the Mark within this judicial district and in other

locations, without the authorization or approval of Plaintiff, and has failed to account to or make

payment to Plaintiff in connection with such exploitation of the Mark.

FIRST CLAIM DECLARATION OF OWNERSHIP

39. Plaintiff repeats and re-alleges each and every allegation in paragraphs 1 through

38 above as if fully set forth herein.]

40. By reason of the foregoing, an actual and justiciable controversy of sufficient

immediacy and reality has arisen and now exists between Plaintiff and Defendant, concerning

their respective rights and interests in the Mark.

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41. Plaintiff contends that the Mark is jointly owned by Plaintiff and Defendant.

42. Defendant contends, by virtue of his sworn filing in the U.S. Patent and

Trademark Office, that he is the sole owner of the Mark.

43. Declaratory relief from this Court is necessary pursuant to the Declaratory

Judgment Act, 28 U.S.C. §§2201 et seq., so that the Parties may know their respective rights and

obligations with respect to the Mark.

44. By reason of the foregoing, Plaintiff is entitled to a declaratory judgment and

related relief, declaring that the Mark is jointly owned by Plaintiff and Defendant.

45. Plaintiff has no adequate remedy at law.

SECOND CLAIM ACCOUNTING AND PAYMENT

46. Plaintiff repeats and re-alleges each and every allegation in paragraphs 1 through

45 above as if fully set forth herein.

47. Rudolph is unaware of the degree to which Ronald exploited the Mark, the

licenses and/or other transactions that Ronald entered into for the use of the Mark, or the revenue

Ronald garnered through such exploitation. Consequently, Rudolph has a need to discover the

a a a a R a a

Mark.

48. By reason of the foregoing, Plaintiff is entitled to a judgment ordering Defendant

a a a Pa Pa 50% share of all results and

proceeds of the past exploitation of the Mark realized by Defendant.

JURY DEMAND

Pursuant to Fed. R. Civ. P. Rule 38(b), Plaintiffs demand a trial by jury on all issues

properly triable.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request that this Court enter judgment as follows:

A. On the First Claim, a judgment declaring that the Mark is jointly owned by

Plaintiff and Defendant.

B. On the Second Claim, a judgment ordering Defendant to account for and pay over

Pa Pa 50% share of all results and proceeds of the

exploitation of the Mark realized by Defendant.

C. Awarding Plaintiff his costs and di , a a a

fees, incurred in prosecuting this action; and

D. Awarding Plaintiff such other and further equitable and legal relief as this Court

may deem necessary, just and proper.

Dated: March 20, 2023 Respectfully submitted,

RUDOPLH ISLEY

By: /s/ Steven P. Mandell

One of his attorneys

Steven P. Mandell (ARDC #6183729)

MANDELL MENKES LLC
333 W. Wacker Dr., Suite 450
Chicago, IL 60606
Tel.: (312) 251-1000
[email protected]

Brian D. Caplan
Robert W. Clarida
885 Third Avenue, 20th Floor
New York, New York 10022
Telephone: (212) 209-3050
Facsimile: (212) 371-5500
[email protected]
[email protected]

Attorneys for Plaintiff

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EXHIBIT A
 Case: 1:23-cv-01720 Document #: 1-1 Filed: 03/20/23 Page 2 of 3 PageID #:10
#$%$&'(() +$%,-. /)
/)0 1,$&-. +&'&-2 3'&-,& ',. 45'.-6'57 899$;-
<=;'&$=,0 1,$&-. +&'&-2 3'&-,& ',. 45'.-6'57 899$;-
#'&-0 >?>>@?A@BC ?D
?D0DE
DE0CF
CF G?DH??
?DH??H

Reg. No. 6,820,951 Isley, Ronald (UNITED STATES INDIVIDUAL)

100 Chesterfield Business Pkwy, 2nd Fl
Registered Aug. 16, 2022 St. Louis, MISSOURI 63005
Int. Cl.: 9 CLASS 9: Visual recordings and audiovisual recordings featuring music and animation
Trademark FIRST USE 1-1-1954; IN COMMERCE 1-1-1954
Principal Register THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO
ANY PARTICULAR FONT STYLE, SIZE OR COLOR

No claim is made to the exclusive right to use the following apart from the mark as
shown: "BROTHERS"

SEC.2(F)

SER. NO. 97-104,679, FILED 11-02-2021

Case: 1:23-cv-01720 Document #: 1-1 Filed: 03/20/23 Page 3 of 3 PageID #:11

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION

WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE

DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years*

What and When to File:

• First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.

• Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods*

What and When to File:

• You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with the
payment of an additional fee.

*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an

extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use (or
Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO). The
time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for nationally
issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations do not file
renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying international
registration at the International Bureau of the World Intellectual Property Organization, under Article 7 of the
Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the date of the
international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the international
registration, see http://www.wipo.int/madrid/en/.

NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at
http://www.uspto.gov.

NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.

Page: 2 of 2 / RN # 6820951
Case: 1:23-cv-01720 Document #: 1-2 Filed: 03/20/23 Page 1 of 4 PageID #:12

EXHIBIT B
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THE GRAY LAW FIRM

A LIMITED LIABILITY COMPANY
10 BANTA PL, SUITE 114
HACKENSACK, NEW JERSEY 07601
201-342-4064 New York Office
42 Broadway, Suite 12-148
!"NAVARRO W. GRAY, ESQ ⬥ New York, New York 10004
Office: 917-775-0089
YOHAYRA AZCONA, ESQ FAX Fax: 212-954-5397
____________ 201-336-9098
*ALL REPLIES TO NJ OFFICE
E-MAIL: [email protected]
!"Also Member of New York Bar WEB SITE: www.TheGrayFirm.com

January 10, 2023

VIA CERTIFIED MAIL RRR and Email ([email protected])
Reitler Kailas & Rosenblatt, LLP
885 Third Avenue, 20th Floor
New York, NY 10022
Attn: Brian D. Caplan, Esq.

Dear Mr. Caplan,

My office represents Ronald Isley and I am receipt of your correspondence dated December
20, 2022. My client would also like to resolve these issues without litigation and the fact that they
are of kin should be all the better reason. Ronald’s responses are as follows:

1. In Response to your Paragraph (1): On or around December 31, 2012, Ronald did receive
$2,000,000 from Rudolph but it was repaid. On or about September 2018 Rudolph voided
their agreement. Considering, arguendo that Rudolph still claimed that Ronald owed him the
funds, at the time of the Assets Purchase Agreement Ron allowed Rudolph to receive the entire
tax benefit from the K1’s from the Isley Brothers, LLC from the 2012 – 2018 tax periods.
Again, this amount equates to well over $2,000,000. Ronald, was entitled to ½ of those monies
and forfeited all the funds in the account to Rudolph to allow him to recover the $2,000,000.;

2. In Response to your Paragraph (2): Ronald did not set up a separate entity to receive Isley
Brothers related revenue. He set up his own corporate entity to do business solely related to
his own musical/entertainment career as Ronald Isley p/k/a “Ron Isley”.;

3. In Response to your Paragraph (3): There has always been more than two (2) members in the
Isley Brother’s Group. Thus, your client could not have a fifty percent (50%) ownership in the
name and mark. Furthermore, In regard to any ownership or claim of “The Isley Brothers”
Trademark, the Trademark Act §1, 15 U.S.C. §1051 states that a Trademark owner is the party
who controls the nature and quality of the services provided in connection with the brand. The
owner of a trademark is the person who applies the mark to the services that they perform, and
 Case: 1:23-cv-01720 Document #: 1-2 Filed: 03/20/23 Page 3 of 4 PageID #:14

THE GRAY FIRM

Brian D. Caplan, Esq.

January 5, 2023
Page 2

who is actually and actively using the mark in commerce during or near the time of
registration. Our research shows that Rudolph Isley has not used the mark or been part of
The Isley Brothers brand since 1986 and has not performed with The Isley Brothers since the
death of their brother Okelly Isley. Even if Rudloph had applied for a Trademark while he was
using the mark in commerce, it would eventually have become abandoned as abandonment of
a trademark occurs when the owner ceases from using the mark in commerce for at least three
years. Currently, Rudolph has not used the mark in approximately thirty-six (36) years. Thus,
Ronald’s profits from the business endeavors he has sought and created for himself, in relation
to The Isley Brother’s brand, are not to be shared as he has been the party actually using the
mark in commerce and ownership of the mark is not what has procured such opportunities for
Ronald Isley. Furthermore, Ronald’s ownership of the mark does not preclude Rudolph from
procuring his own business endeavors or from using his natural name “Isley” in relation to any
business endeavors.;

4. In Response to your Paragraph (4): Ronald is only selling merch pertaining to Ronald Isley
and Ernie Isley. However, there are fakes sites selling unauthorized merch that are no way
affiliated with The Isley Brothers or Ronald Isley.;

5. In Response to your Paragraph (5): We are unaware of any such corrections. SoundExchange
pays all featured and primary artists an equal share of SoundExchange monies. We believe
that if Rudolph is educated on the payout of SoundExchange he will also come to the
conclusion that no corrections need to be made.;

6. In Response to your Paragraph (6): Ronald has no problem jointly deciding and incorporating
Rudolph in Isley Brothers business. However, it would be only for the years that Rudolph was
a working member of the Isley Brother’s group. Rudolph retired in 1986, has had no
involvement in any of the compositions/body of works done after he retired, and has not
performed with The Isley Brother’s since the death of Okelly Isley.;

7. In Response to your Paragraph (7): No such documents exist.; and

8. In Response to your Paragraph (8): The songs requested were recorded under a record deal
with Rhino Records. Ronald does not have a list of these compositions. Michael Frish, Esq.
did that deal and would have a copy of same.

Ronald hereby demands a formal accounting of any and all monies Rudolph received from 2012-
2018 from Rudolph’s K1 tax statement received from the Isley Brother’s LLC.
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THE GRAY FIRM

Brian D. Caplan, Esq.

January 5, 2023
Page 3

The foregoing responses are being submitted without prejudice and not to be deemed conclusive
responses to your requests. Ronald is sending them as a courtesy to Rudolph and in an attempt to
avoid litigation.

Very Truly Yours,

THE GRAY LAW FIRM, LLC

BY: s/ Navarro W. Gray

NAVARRO W. GRAY

NWG:jb
cc: Ronald Isley (via email)
ILND 44 (Rev. 09/20) CIVIL #:
Case: 1:23-cv-01720 Document COVER SHEET
1-3 Filed: 03/20/23 Page 1 of 1 PageID #:16
The ILND 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
Rudolph Isley Ronald Isley

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(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)
Mandell Menkes LLC
333 W. Wacker Dr., Suite 450, Chicago, IL 60606

II. BASIS OF JURISDICTION (Check one box, only.) III. CITIZENSHIP OF PRINCIPAL PARTIES (For Diversity Cases Only.)
(Check one box, only for plaintiff and one box for defendant.)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government not a party.) Incorporated or Principal Place of
Citizen of This State o 1 1 4 4
Business in This State

2 U.S. Government o 4 Diversity Citizen of Another State 2 o 2 Incorporated and Principal Place 5 5
Defendant (Indicate citizenship of parties in Item III.) of Business in Another State

Citizen or Subject of a
3 3 Foreign Nation 6 6
Foreign Country
IV. NATURE OF SUIT (Check one box, only.)
CONTRACT TORTS PRISONER PETITIONS LABOR OTHER STATUTES
510 Motions to Vacate 710 Fair Labor Standards
110 Insurance PERSONAL INJURY PERSONAL INJURY Sentence 375 False Claims Act
Act
376 Qui Tam (31 USC
120 Marine 310 Airplane 530 General 530 General 720 Labor/Management
3729 (a))
315 Airplane Product 5D<=DEDLO
367 Health Care& 535 Death Penalty Relations
320 Assault, Libel & Slander 400 State Reapportionment
Pharmaceutical
130 Miller Act **' 4@?@J<E 3FIEHO@JK" Personal Injury
5D<=DEDLO Habeas Corpus: 740 Railway Labor Act 410 Antitrust
Product Liability
140 Negotiable Instrument 340 Marine 368 Asbestos Personal 540 Mandamus & Other 751 Family and Medical 430 Banks and Banking
150 Recovery of Overpayment 345 Marine Product Liability Injury Product 55' 1DNDE 8DBCLK Leave Act 450 Commerce
& Enforcement of Judgment 350 Motor Vehicle Liability ,,, 7JDKHG 1HG?DLDHG 790 Other Labor Litigation 460 Deportation
151 Medicare Act 355 Motor Vehicle Product 560 Civil Detainee - 791 Employee Retirement 470 Racketeer Influenced
152 Recovery of Defaulted Liability PERSONAL PROPERTY Conditions and Corrupt
Income Security Act
Student Loan 360 Other Personal Injury of Confinement Organizations
(Excludes Veterans) 362 Personal Injury - Medical 370 Other Fraud 480 Consumer Credit
153 Recovery of Veteran’s Malpractice PROPERTY RIGHTS
371 Truth in Lending 485 Telephone Consumer
Benefits 820 Copyright
160 Stockholders’ Suits 380 Other Personal 830 Patent Protection Act (TCPA)
190 Other Contract Property Damage 835 Patent - Abbreviated 490 Cable/Sat TV
195 Contract Product Liability 385 Property Damage New Drug Application 850 Securities/Commodities/
196 Franchise Product Liability 840 Trademark Exchange
..' 2@A@G? ;J<?@ 9@>J@LK 890 Other Statutory Actions
0>L HA )'(- #2;90$ 891 Agricultural Arts
REAL PROPERTY CIVIL RIGHTS BANKRUPTCY FORFEITURE/PENALTY SOCIAL SECURITY 893 Environmental Matters
210 Land Condemnation ++' 6LC@J 1DNDE 8DBCLK 422 Appeal 28 USC 158 625 Drug Related Seizure 861 HIA (1395ff) 895 Freedom of Information
423 Withdrawal of Property 862 Black Lung (923) Act
220 Foreclosure 441 Voting 21 USC 881
230 Rent Lease & Ejectment 442 Employment 28 USC 157 690 Other 863 DIWC/DIWW 896 Arbitration
(405(g)) 899 Administrative
240 Torts to Land 443 Housing&0>>HFFH?<LDHGK Procedure
2+, ;HJL 7JH?M>L 5D<=DEDLO 445 Amer. w/ Disabilities% IMMIGRATION 864 SSID Title XVI Act/Review or Appeal of
o )/' 0EE 6LC@J 8@<E 7JHI@JLO Employment 462 Naturalization 865 RSI (405(g)) Agency Decision
446 Amer. w/Disabilities - Application 950 Constitutionality of
Other 463 Habeas Corpus – FEDERAL TAXES State Statutes
448 Education Alien Detainee 870 Taxes (U.S. Plaintiff
(Prisoner Petition) or Defendant
465 Other Immigration 871 IRS—Third Party
Actions 26 USC 7609
V. ORIGIN (Check one box, only.)
1 Original 2 Removed from 3 Remanded from 4 Reinstated 5 Transferred 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court or Reopened from Another Litigation - Litigation -
District Transfer Direct File
(specify)

VI. CAUSE OF ACTION ( Enter U.S. Civil Statute under which you are filing and VII. PREVIOUS BANKRUPTCY MATTERS (For nature of suit 422 and
423, enter the case number and judge for any associated bankruptcy matter previously adjudicated by
write a brief statement of cause.) a judge of this Court. Use a separate attachment if necessary.)
Declaratory action pursuant to 28 U.S.C. §§ 2201 and 2202

VIII. REQUESTED IN Check if this is a class action under Rule 23, Demand $ CHECK Yes only if demanded in complaint:
COMPLAINT: F.R.CV.P. Jury Demand: Yes No o

IX. RELATED CASE(S) IF ANY (See instructions): Judge Case Number

X. Is this a previously dismissed or remanded case? Yes No If yes, Case # o Name of Judge
March 20, 2023
Date: ___________________________________________ /s/ Steven P. Mandell
Signature of Attorney of Record ______________________________________________