Electronically FILED by Superior Court of California, County of Los Angeles on 06/15/2022 01:56 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by R. Perez,Deputy Clerk

22STCV19481
Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Timothy Dillon

1 Scott J. Street (SBN 258962)

JW HOWARD/ATTORNEYS, LTD.
2 777 S. Figueroa Street, Suite 3800
Los Angeles, CA 90017
3
Telephone: (213) 205-2800
4 Email: sstreet@jwhowardattorneys.com

5 John W. Howard (SBN 80200)

Michelle D. Volk (SBN 217151)
6 JW HOWARD/ATTORNEYS, LTD.
701 B Street, Suite 1725
7
San Diego, California 92101
8 Telephone: 619-234-2842
Facsimile: 619-234-1716
9 Email: johnh@jwhowardattorneys.com
10 Attorneys for Plaintiffs JAMES WAHL and
11 TIMOTHY JAMES WAHL
JW HOWARD/ ATTORNEYS, LTD.

12 SUPERIOR COURT OF THE STATE OF CALIFORNIA

SAN DIEGO, CALIFORNIA 92101
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13 FOR THE COUNTY OF LOS ANGELES

14 CENTRAL DIVISION

15

16 JAMES WAHL, an individual, and Case No.

TIMOTHY JAMES WAHL,
17
Plaintiffs, COMPLAINT FOR DAMAGES AND
18 vs.
DECLARATORY/INJUNCTIVE RELIEF
19 AMERICAN BROADCASTING FOR VIOLATION OF CIVIL RIGHTS
COMPANIES, INC., a Delaware
20 corporation; and DOES 1 through 10, JURY TRIAL REQUESTED
inclusive,
21
Defendants.
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1
COMPLAINT
 1 Plaintiffs James Wahl (“Jim”) and Timothy James Wahl (“Tim”) (collectively, “Plaintiffs”)

2 allege as follows:

3 INTRODUCTION

4 1. In early 2020, the world discovered a novel coronavirus, Covid-19. Governments

5 responded with unprecedented restrictions on freedom. They closed schools and shut down

6 industries. They banned travel and prosecuted churches. They decided which activities were

7 “essential” and which weren’t.

8 2. During 2020, several experimental vaccines were developed to help limit the effects

9 of Covid-19. But they are not miracle cures. They were developed quickly to protect those who are
10 at highest risk of getting seriously ill from Covid, especially the elderly and those with multiple co-

11 morbidities. Government officials now admit that vaccinated people can contract and transmit
JW HOWARD/ ATTORNEYS, LTD.

12 Covid-19. Many fully vaccinated and fully boosted people fell ill with the Omicron variant last
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13 winter.

14 3. Some public health experts and epidemiologists predicted all along that the Covid

15 shots would not eradicate Covid. They pointed to evidence of “breakthrough” infections, among

16 other signs, as evidence of this. Nonetheless, the vaccines became the center of a political dispute

17 last summer, with President Joe Biden and other leading Democrats blaming the unvaccinated and

18 so-called “anti-vaxxers” for not doing their part to eliminate the virus. They encouraged local

19 officials to mandate the Covid shots for public and private employees.

20 4. The media has been among the most aggressive in mandating the Covid-19 shots for

21 its employees. To that end, during the summer of 2021, Defendant American Broadcasting

22 Companies., Inc. (“ABC”), a wholly owned subsidiary of The Walt Disney Company, ordered that

23 anybody working on a television show it produced would have to get the Covid-19 shot (the “Covid

24 Vaccine Mandate”).

25 5. Plaintiffs ran the construction shop and special effects department for the ABC-

26 produced soap opera General Hospital. Jim had worked on the show for 14 years. His son, Tim, had
27 worked on the show for 10 years. They are behind-the-scenes employees who were critical to

28 General Hospital’s success.

2
COMPLAINT
 1 6. Plaintiffs requested a religious exemption to the Covid Vaccine Mandate. Although

2 ABC said it would grant exemptions for sincerely held religious objections to the Covid-19 shots, it

3 refused to accept Plaintiffs’ request. It denied their requests without explanation, one week after they

4 requested them.

5 7. These actions were unlawful. ABC does not have the authority to force a medical

6 treatment on its employees against their will. Even if it did, it must offer religious exemptions to

7 anybody who requests one. It cannot discriminate among religions and cannot second-guess the

8 sincerity of one’s religious beliefs without an objective basis for doing so. It did not have one here.

9 ABC’s actions constitute religious discrimination and violate Plaintiffs’ rights under state law.
10 8. Furthermore, like all Californians, Plaintiffs have a right to bodily autonomy, which

11 the Covid Vaccine Mandate violates. They also have a right to informational privacy. ABC violated
JW HOWARD/ ATTORNEYS, LTD.

12 those rights.
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13 9. Plaintiffs bring this action to hold ABC accountable for its unlawful discrimination

14 and invasion of their privacy rights.

15 PARTIES, JURISDICTION AND VENUE

16 10. Plaintiff James Wahl is an individual who resides in Los Angeles County.

17 11. Plaintiff Timothy James Wahl is an individual who resides in Los Angeles County.

18 12. Defendant ABC is a corporation formed under the laws of the State of Delaware. Its

19 principal place of business is in Burbank, within Los Angeles County.

20 13. Defendant DOES 1 through 10 are individuals who at all relevant times were

21 officials, agents or employees of ABC and who bear some responsibility for the actions alleged in

22 this Complaint. Their identities are not yet known and thus they are sued fictitiously but Plaintiffs

23 will amend the Complaint after they discover them.

24 14. Venue exists in Los Angeles County under sections 393(b) and 394(a) of the Code of

25 Civil Procedure because the parties reside here and the effects of ABC’s actions are felt here.

26 FACTUAL ALLEGATIONS
27 15. In early 2020, health officials discovered a novel coronavirus circulating in Wuhan,

28 China. They named the disease caused by the virus “Covid-19.”

3
COMPLAINT
 1 16. Though nobody knew it at the time, the Covid-19 pandemic would lead to

2 unprecedented restrictions on liberty. Many of the restrictions started in California, including the

3 first statewide “lockdown” and unprecedented mass closures of businesses and criminalization of

4 ordinary activities that unelected health officials deemed too dangerous.

5 17. During 2020, at the urging of then President Donald Trump, several pharmaceutical

6 companies began developing experimental treatments to mitigate the effects of Covid-19 and,

7 potentially, reduce its spread.

8 18. The Covid-19 shots were so controversial that then presidential candidate Joe Biden

9 would not commit to receiving one. Then vice presidential candidate Kamala Harris said she would
10 not take them if Trump recommended it. Governor Gavin Newsom also questioned the treatments,

11 saying he did not trust the Trump Administration and would review the treatments independently.
JW HOWARD/ ATTORNEYS, LTD.

12 19. Then Mr. Biden won the presidency and many tunes changed. Still, President-elect
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13 Biden said he would not mandate that Americans get the Covid shots.

14 20. By the summer of 2021, tens of millions of Americans had chosen to take the Covid-

15 19 vaccines, including more than half of adults in California. They did so by choice not by coercion.

16 But Covid-19 had not disappeared. That should not have surprised anyone. Public health officials

17 have repeatedly said that eliminating a respiratory virus is impossible once it begins spreading in the

18 community.

19 21. Thus, anyone can still contract and spread the Covid-19 virus. Like the flu, Covid-19

20 is becoming endemic. The world will have to learn to live with it, as we live with many other

21 pathogens.

22 22. That includes people who have received one of the Covid-19 shots. Although the

23 shots have been declared a miracle by many, the Department of Health and Human Services’ Centers

24 for Medicare and Medicaid Services admitted that “the duration of vaccine effectiveness in

25 preventing COVID-19, reducing disease severity, reducing the risk of death, and the effectiveness of

26 the vaccine to prevent disease transmission by those vaccinated are not currently known.”
27 23. This was not an isolated comment. Moderna and Pfizer executives have both

28 conceded that their shots, unlike others that have helped eradicate diseases like polio and smallpox,
4
COMPLAINT
 1 have little known long-term benefit. The CMS has also said that “major uncertainties remain as to

2 the future course of the pandemic, including but not limited to vaccine effectiveness in preventing

3 ‘breakthrough’ disease transmission from those vaccinated, [and] the long-term effectiveness of

4 vaccination.”

5 24. These uncertainties played out last winter as the Omicron variant of COVID-19

6 spread throughout the world, infecting millions of fully vaccinated people. The CDC finally

7 conceded in February 2022 that “anyone with Omicron infection can spread the virus to others, even

8 if they are vaccinated or don’t have symptoms.”

9 25. This deficiency seems to extend to the booster shots that were developed in response
10 to new Covid variants. As Fortune reported in January: “Booster shots with messenger RNA

11 vaccines such as those made by Pfizer Inc. and BioNTech SE failed to block Omicron in a study of
JW HOWARD/ ATTORNEYS, LTD.

12 some of the first documented breakthrough cases caused by the highly contagious variant.” The
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13 same report stated that “[p]reliminary data from an Israeli trial involving 154 health workers,

14 showed that a fourth dose of Pfizer’s shot didn't prevent infection with Omicron.”

15 26. Other studies have reached similar findings. For example, according to one

16 investigation, which analyzed data from California and other states: “When the delta strain circulated

17 from mid-November to mid-December of last year, the vaccinated accounted for 21% of all COVID-

18 related deaths in California and Georgia, and 38% in Illinois. After delta was overtaken by the

19 omicron variant, the proportions in California and Georgia rose substantially to over 33% -- a level

20 comparable to Illinois, which remained at its already higher rate.”

21 27. Studies have also revealed potential serious side effects from the Covid-19 shots. For

22 example, a British report that examined data from more than 42 million people found an increase in

23 myocarditis with mRNA vaccines like the COVID-19 shots that increased with each additional shot,

24 including the booster shots. That report’s authors concluded that “[a]n association between Covid-19

25 infection and myocarditis was observed in all ages for both sexes.” According to another report, a

26 recent study from Sweden found that the “messenger RNA from Pfizer’s COVID-19 vaccine
27 reportedly can enter human liver cells and be converted into DNA, contrary to what the CDC has

28 said.” These disturbing trends—actual evidence that contradicts the CDC’s pro-vaccine narrative—
5
COMPLAINT
 1 may explain why a CDC panel recently proposed extending the gap between Covid shots. They may

2 also explain why several countries, including Denmark, Finland, Norway, and Sweden, suspended

3 use of the Moderna vaccine for young people last fall.

4 28. This growing body of evidence confirms what many public health officials have said

5 all along. As former Yale professor Dr. David Gortler put it: “Vaccines are one of the most

6 important inventions in human history, having saved millions of lives. That does not mean every

7 person should get every vaccine. Also, like every drug out there, it is critically important to quickly

8 detect and report safety problems.” Dr. Gortler concluded that the Covid-19 shots are “clearly no

9 longer effective, and [are] potentially causing additional illness and death.” Many other doctors and
10 public health officials agree with him.

11 29. Those who have touted the effectiveness of the Covid shots have often relied on the
JW HOWARD/ ATTORNEYS, LTD.

12 CDC’s recommendation and statement that they work. But in a February 20 article, New York Times
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13 reporter Apoorva Mandavilli wrote that the CDC “has published only a tiny fraction of the data it

14 has collected” regarding the shots’ effectiveness in preventing hospitalizations, much less death. Ms.

15 Mandavilli quoted a government official as saying the CDC was “reluctant” to make this information

16 available because it “might be misinterpreted as the vaccines being ineffective.” The CDC’s

17 credibility is eroding with reports like these and as the public learns about the results of studies (like

18 the Swedish DNA study) that contradict the CDC’s prior statements about the vaccines.

19 30. Despite this history, and mounting evidence that the Covid shots do not prevent

20 people from contracting or spreading Covid-19, much of which was available last summer, many

21 government officials and other leaders have mandated that people get the shot to participate in daily

22 life or keep their jobs.

23 31. To that end, during the summer of 2021, ABC decided that anybody who works on a

24 television show it produces would have to get one of the Covid-19 shots or would be fired. The

25 mandate was unprecedented. ABC has never required that individuals get a vaccine to work on a

26 television show. It never even inquired about such private medical information before the Covid
27 pandemic, recognizing that California prohibits employers from conditioning employment on

28 medical conformity.
6
COMPLAINT
 1 32. ABC said it would respect an individual’s sincere religious objection to the Covid

2 Vaccine Mandate. Therefore, during October 2021, Plaintiffs requested religious exemptions to the

3 mandate.

4 33. Rather than accept Plaintiffs’ request for a religious exemption, ABC scheduled an

5 interview between them and an ABC employee to discuss their requests. Although ABC described

6 the interview as an “interactive process,” the interview was conducted by a lawyer who works for

7 Disney. It was a cross-examination designed to elicit information that ABC could use to deny

8 Plaintiffs’ requests for an exemption, as it denied almost all such requests during 2021.

9 34. On November 9, 2021, ABC officially denied Plaintiffs’ requests for religious
10 exemptions to the Covid Vaccine Mandate. It gave no reason for its decision, except to say that the

11 company was “unable to conclude that you are prevented from receiving the Covid-19 vaccine due
JW HOWARD/ ATTORNEYS, LTD.

12 to a sincerely-held religious belief, practice, or observance.”

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13 35. ABC said nothing else. It did not ask Plaintiffs whether they could perform the

14 essential functions of their jobs. It did not show that the company would be unduly burdened by

15 continuing to employ Plaintiffs even if they did not get the Covid shots. It made no effort whatsoever

16 to comply with its obligations under the law and, on information and belief, it violated numerous

17 ABC/Disney policies about how to handle requests for religious accommodations, even when health

18 is involved.

19 36. These actions were unlawful. Once ABC decided to recognize exemptions to its

20 vaccine mandate, it had to honor them. Questioning the sincerity of an individual’s religious beliefs

21 without an objective basis to do so, which ABC did not have here, violates federal and state civil

22 rights laws.

23 37. Plaintiffs complied with generally applicable rules related to Covid-19. They tested

24 frequently and wore a mask when appropriate. They did those things for months, without incident.

25 They would have continued doing those things. Instead, they were let go so ABC could support a

26 political policy.
27 38. This should not be a political issue. There is no need for everybody to get the Covid-

28 19 shot, especially since the shots do not prevent infection. Furthermore, Plaintiffs have a right to
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COMPLAINT
 1 privacy and a right to bodily autonomy, the right to choose what they do with their bodies. Lawsuits

2 decided a hundred years ago cannot eliminate that right. They cannot undo the progress that

3 Californians have made in recognizing medical freedom during the past 50 years.

4 39. Indeed, ABC/Disney have historically been overly protective of these rights. They

5 went to great lengths to accommodate people’s religious beliefs and medical conditions. They

6 developed reams of policies and procedures to govern that process. They ignored them all this time.

7 40. Plaintiffs bring this action to protect those rights and to seek damages for ABC’s

8 unlawful discrimination against their religious beliefs and physical condition. Plaintiffs received a

9 right to sue letter from the California Department of Fair and Employment and Housing and thus
10 exhausted their administrative remedies.

11 FIRST CAUSE OF ACTION

JW HOWARD/ ATTORNEYS, LTD.

12 (Violation of Article I Section 1 of the Cal. Constitution)

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13 41. Plaintiffs incorporate paragraphs 1 through 40 of this Complaint as though set forth

14 fully herein.

15 42. Individuals have a right to privacy under the California Constitution. This state law

16 privacy right, which was added by voters in 1972, is far broader than the right to privacy that exists

17 under the federal Constitution. It is the broadest privacy right in America and has been interpreted by

18 the California Supreme Court to protect both the right to bodily integrity and bodily autonomy—the

19 right to choose what to do with one’s own body, free from coercion. Unlike the right to privacy that

20 has been recognized to exist under the federal Constitution, the right to privacy embodied in

21 California's Constitution at Article 1, Section 1 thereof, is enforceable against private actors.

22 43. Plaintiffs have a legally protected privacy interest in their bodily autonomy and

23 private medical information, as the California Supreme Court recognized in Hill v. NCAA. Their

24 expectation of privacy was reasonable under the circumstances as ABC has never had a vaccination

25 requirement for employment before now and has never disciplined, much less fired, an employee for

26 declining an injection. The only compulsory vaccination laws adopted in California during the past
27 century concerned certain vaccines that children need to attend school. Those laws do not undermine

28 the expectation of privacy that adults have in their bodily autonomy.

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COMPLAINT
 1 44. Moreover, in 2005, the California Court of Appeal identified compulsory vaccination

2 as the type of “invasive and highly personalized medical treatments used in cases where the state

3 sought to override a person’s freedom to choose and where the Supreme Court has recognized a

4 liberty interest in freedom from such unwanted medical treatment.” Coshow v. City of Escondido,

5 132 Cal. App. 4th 687, 710 (2005). Although ABC is a private party, the California constitutional

6 right to privacy applies to private parties. It is also not the only entertainment company that adopted

7 a Covid vaccine mandate. Like many companies, ABC instituted the mandate because the

8 government said it wants universal vaccination. Therefore, the vaccine mandate constitutes a serious

9 invasion of Plaintiffs’ privacy rights, as alleged above.

10 45. As the California Supreme Court has explained, the “rational basis” test that courts

11 employ when analyzing alleged violations of the United States Constitution does not apply in a state
JW HOWARD/ ATTORNEYS, LTD.

12 law privacy case. The California Supreme Court uses a fact-intensive balancing test to decide
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13 whether a mandate violates an individual’s state constitutional right to privacy. Moreover, while

14 ABC may argue that its vaccine mandate serves a compelling interest in reducing the spread of

15 Covid-19, there are feasible and effective alternatives to it that have a lesser impact on privacy

16 interests.

17 46. Indeed, evidence now shows that the vaccines do not prevent people from contracting

18 and transmitting Covid-19. That is why millions of vaccinated people, including ABC employees,

19 fell ill with the Omicron variant last winter. This trend will continue as other Covid variants emerge.

20 Thus, ABC’s vaccine mandate does not serve its stated purpose of preventing infection. The most

21 the Covid shots can do is, potentially, reduce the severity of Covid-19 symptoms but even that has

22 not been scientifically proven and there are other ways to reduce the severity of Covid-19 without

23 compelling people to get a shot they do not want. In any event, taking a shot to potentially reduce the

24 severity of illness is a private health issue, which state and federal law prohibit employers from

25 interfering with.

26 47. On information and belief, ABC contends that its vaccine mandate does not violate
27 Plaintiffs’ privacy rights or that the mandate was justified.

28 48. Plaintiffs desire a judicial declaration that ABC’s vaccine mandate is unconstitutional
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COMPLAINT
 1 because it violates their right to privacy under Article I, section 1 of the California Constitution. This

2 is both a facial and an as-applied challenge.

3 49. A judicial determination of these issues is necessary and appropriate because such a

4 declaration will clarify the parties’ rights and obligations, permit them to have certainty regarding

5 those rights and potential liability, and avoid a multiplicity of actions.

6 50. As a result of ABC’s actions, Plaintiffs’ contract was terminated, as alleged above.

7 They suffered damages to be proven at trial but which exceed $25,000.

8 51. This action serves the public interest, justifying an award of attorneys’ fees under

9 section 1021.5 of the California Code of Civil Procedure.

10 SECOND CAUSE OF ACTION

11 (Violation of Cal. Fair Employment and Housing Act/Failure to Accommodate)

JW HOWARD/ ATTORNEYS, LTD.

12 52. Plaintiffs incorporate paragraphs 1 through 40 of this Complaint as though set forth
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13 fully herein.

14 53. California’s Fair Employment and Housing Act (FEHA) forbids an employer from

15 firing someone “because of a conflict between the person’s religious belief or observance and any

16 employment requirement, unless the employer or other entity covered by this part demonstrates that

17 it has explored any available reasonable alternative means of accommodating the religious belief or

18 observance . . . but is unable to reasonably accommodate the religious belief or observance without

19 undue hardship.” Cal. Gov’t Code § 12940(l)(1).

20 54. Plaintiffs worked for ABC. They had sincerely held religious beliefs or practices that

21 conflicted with a stated job requirement (the Covid-19 vaccine mandate). ABC was aware of this

22 conflict but did not explore any available reasonable alternatives for accommodating Plaintiffs’

23 beliefs and it refused to consider the accommodations they proposed, none of which would have

24 imposed a substantial burden on ABC.

25 55. As a result of ABC’s actions, Plaintiffs suffered damages in an amount to be proven

26 at trial. These actions were the actual and proximate cause of those damages.
27 56. ABC acted with malice or reckless indifference to Plaintiffs’ rights, justifying an

28 award of punitive damages.

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COMPLAINT
 1 57. Under the FEHA, Plaintiffs should recover their costs and legal fees.

2 THIRD CAUSE OF ACTION

3 (Violation of Cal. Fair Employment and Housing Act/Disability Discrimination)

4 58. Plaintiffs incorporate paragraphs 1 through 40 of this Complaint as though set forth

5 fully herein.

6 59. The FEHA prohibits California employers from firing someone because of their

7 physical, or a medical, condition.

8 60. Plaintiffs worked for ABC. They had a perceived physical disability (being

9 unvaccinated) that conflicted with a stated job requirement (the Covid-19 vaccine mandate). ABC
10 was aware of this conflict but did not explore any available reasonable alternatives for

11 accommodating Plaintiffs and it refused to consider the accommodations Plaintiffs proposed, none
JW HOWARD/ ATTORNEYS, LTD.

12 of which would have imposed a substantial burden on ABC. ABC fired Plaintiffs because of their
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13 perceived physical disability.

14 61. As a result of ABC’s actions, Plaintiffs suffered damages in an amount to be proven

15 at trial. These actions were the actual and proximate cause of those damages.

16 62. ABC acted with malice or reckless indifference to Plaintiffs’ rights, justifying an

17 award of punitive damages.

18 63. Under the FEHA, Plaintiffs should recover their costs and legal fees.

19 FOURTH CAUSE OF ACTION

20 (Violation of Cal. Fair Employment and Housing Act/Retaliation)

21 64. Plaintiffs incorporate paragraphs 1 through 40 of this Complaint as though set forth

22 fully herein.

23 65. State law prohibits discrimination on the basis of race, color, sex, national origin,

24 religion, age, disability and genetic information. An individual engages in protected activity when he

25 or she speaks out about, or exercises rights related to, workplace discrimination.

26 66. Plaintiffs were engaged in protected activity when they sought a religious exemption
27 to ABC’s enforcement of Covid Vaccine Mandate.

28 67. ABC retaliated against Plaintiffs for engaging in this protected activity, as alleged
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COMPLAINT
 1 above. The retaliatory acts included, but are not limited to, denying Plaintiffs’ requests for an

2 exemption to the Covid vaccine mandate and firing them for not complying with the mandate while

3 granting requests for exemptions from people who follow certain other religions.

4 68. As a result of ABC’s actions, Plaintiffs suffered damages in an amount to be proven

5 at trial. These actions were the actual and proximate cause of those damages.

6 69. ABC acted with malice or reckless indifference to Plaintiffs’ rights, justifying an

7 award of punitive damages.

8 70. Under the FEHA, Plaintiffs should recover their costs and legal fees

9 FIFTH CAUSE OF ACTION

10 (Wrongful Termination)

11 71. Plaintiffs incorporate paragraphs 1 through 40 of this Complaint as though set forth
JW HOWARD/ ATTORNEYS, LTD.

12 fully herein.
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13 72. ABC fired Plaintiffs for asserting their constitutional rights, including their rights to

14 religious freedom and bodily integrity/autonomy, and their statutory rights.

15 73. The assertion of these rights was a substantial motivating reason for ABC’s actions,

16 as alleged above, and thus constituted wrongful termination, in violation of public policy.

17 74. As a result of ABC’s actions, Plaintiffs suffered damages in an amount to be proven

18 at trial. These actions were the actual and proximate cause of those damages.

19 75. ABC acted with malice or reckless indifference to Plaintiffs’ rights, justifying an

20 award of punitive damages.

21 76. This action serves the public interest, justifying an award of attorneys' fees under

22 section 1021.5 of the California Code of Civil Procedure.

23 PRAYER FOR RELIEF

24 Wherefore, Plaintiffs pray for relief as follows:

25 1. For an order declaring ABC’s Covid-19 vaccine mandate unconstitutional;

26 2. For compensatory damages in an amount to be proven at trial;

27 3. For punitive damages in an amount to be proven at trial;

28 4. For costs and attorneys’ fees under section 1021.5 of the California Code of Civil
12
COMPLAINT
 1 Procedure; and

2 5. For such other relief that the Court determines is just and proper.

3 Dated: June 14, 2022 JW HOWARD/ ATTORNEYS, LTD.

4 By:
5

6 John W. Howard
Scott J. Street
7 Attorneys for Plaintiffs JAMES WAHL and
TIMOTHY JAMES WAHL
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 1 JURY TRIAL DEMAND

2 Plaintiffs demand a trial by jury on all claims for which it is available.

4 Dated: June 14, 2022 JW HOWARD/ ATTORNEYS, LTD.

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By:
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8 John W. Howard
Scott J. Street
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Attorneys for Plaintiffs JAMES WAHL and
10 TIMOTHY JAMES WAHL

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