Case 3:13-cv-02519-GPC-WVG Document 22 Filed 03/04/14 Page 1 of 19
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SIIUMENER, ODSON & OH LLP Betty M. Shumener (SBN 137220) John D. Spurling (SBN 252324) 550 South Hope Street, Suite 1050 Los Angeles, CA 90071-2678 Telephone: 213-344-4200 Facsimile: 213-344-4190 E-mail: bshumener@soollp.com E-mail: jspurlinga,soollp.com Jill A. Martin (SBN 245626) c/o Trump National Golf Club Los Angeles One Trump National Dr. Rancho Palos Verdes, California 90275 Telephone: 310-303-3225 Facsimile: 310-265-5522 Email: jmartin@trumpnational.com
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Attorneys for Defendant DONALD J. TRUMP
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UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF CALIFORNIA
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ART COHEN, Individually and on Behalf of All Others Similarly Situated, Plaintiff,
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VS.
DONALD J. TRUMP
Case No. 13-cv-2519 DMS RBB ANSWER OF DONALD J. TRUMP TO COMPLAINT FOR VIOLATIONS OF 18 U.S.C. ยง1962(c) JURY TRIAL DEMANDED CLASS ACTION
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ANSWER TO COMPLAINT
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DONALD J. TRUMP ("Defendant") hereby answers and responds to the
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correspondingly numbered paragraphs of the Complaint filed by ART COHEN
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("Plaintiff") as follows: NATURE OF ACTION
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1.
Denied.
6
2.
Denied.
7
3.
Defendant maintains that the alleged video speaks for itself as to its
8
content and that there were no "would-be student-victims" and, on those bases,
9
denies the allegations. Defendant is without knowledge or information sufficient to
10
form a belief as to the truth of the remaining allegations of this paragraph, and on
11
that basis, denies those allegations.
12
4.
Denied.
13
5.
Defendant admits that his image and name appeared in certain
14
advertisements for Trump University. Defendant denies the remaining allegations
15
contained in this paragraph.
16
6.
Defendant admits that the New York Department of Education, based
17
on a local statute, requested that Trump University change its name, which it did.
18
Defendant further admits that Trump University stopped selling Live Events in or
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around August 2010. As to the documents alleged in this paragraph, said
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documents speak for themselves as to their content and, on that basis, Defendant
21
denies the allegations. Defendant denies the remaining allegations contained in this
22
paragraph.
23
7.
Defendant admits that the New York Attorney General investigated
24
Trump University. As to the remaining allegations in this paragraph, Defendant is
25
without knowledge or information sufficient to form a belief as to the truth of the
26
allegations, and on that basis, denies those allegations.
27 28
8.
Defendant admits that Plaintiff claims to be bringing this action on his
own behalf and purportedly on behalf of others. Defendant denies others are
ANSWER TO COMPLAINT
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"similarly situated." As to the remaining portions of the paragraph, Defendant is
2
without knowledge or information to form a belief as to the truth of those
3
allegations, and on that basis, denies those allegations.
4
9.
Defendant admits that Plaintiff herein filed this action seeking
5
damages. Defendant denies that this case may properly be certified as a class action
6
or that Plaintiff is entitled to any of the relief sought in the Complaint. JURISDICTION AND VENUE
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10.
This paragraph states legal conclusions that require no response. To
9
the extent this paragraph states any factual allegations, Defendant denies that this
10
case may properly be certified as a class action. Defendant further denies that the
11
aggregate amount in controversy exceeds $5 million. Defendant denies the
12
remaining allegations of this paragraph.
13
11.
This paragraph states legal conclusions that require no response. To
14
the extent the paragraph states any factual allegations, Defendant is without
15
knowledge or information sufficient to form a belief as to the truth of the
16
allegations of this paragraph, and on that basis, denies those allegations.
17
12.
This paragraph states legal conclusions that require no response. To
18
the extent this paragraph states any factual allegations, Defendant denies that a
19
substantial part of the events or omissions giving rise to the claim occurred in this
20
District. PARTIES
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13.
Defendant is without knowledge or information sufficient to form a
23
belief as to the truth of the allegations of this paragraph, and on that basis, denies
24
those allegations.
25
14.
Defendant is without knowledge or information sufficient to form a
26
belief as to the truth of the allegations of this paragraph as to what Plaintiff believed
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or as to what Plaintiff would not have done, and on that basis, denies those
28
allegations. Defendant denies the remaining allegations of this paragraph. 2 ANSWER TO COMPLAINT
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15.
Defendant admits that he resides in the State of New York. Defendant
2
admits that he was the chairman of Trump University as well as the chairman and
3
president of the Trump Organization. Defendant denies the remaining allegations
4
of this paragraph.
5
16.
Denied.
6
17.
Defendant admits that he has conducted business within the State of
7 8
California. 18.
Denied. COMMON FACTUAL ALLEGATIONS
9 10
19.
Denied.
11
20.
Denied.
12
21.
This paragraph states legal conclusions that require no response. To
13
the extent this paragraph states any factual allegations, Defendant admits that
14
Trump University used his name, photos and quotes and sent materials with his
15
name, image and quotes. As to the documents alleged in this paragraph, said
16
documents speak for themselves as to their content and, on that basis, Defendant
17
denies the allegations. Defendant admits that he wrote certain blogs. Defendant
18
denies the remaining allegations in this paragraph.
19
22.
Denied.
20
23.
Denied.
21
24.
Defendant admits that Mr. Sexton and Mr. Highbloom helped select
22
instructors for Trump University. Defendant denies the remainder of the
23
allegations contained in paragraph 24.
24
25.
Defendant admits that Mr. Sexton and other third parties helped
25
compile materials for Trump University. Defendant denies the remainder of the
26
allegations contained in paragraph 25.
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26.
Denied.
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27.
Denied. 3 ANSWER TO COMPLAINT
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28.
The alleged "Trump University PlayBook" speaks for itself as to its
contents, and on that basis, Defendant denies those allegations.
3
29.
Denied.
4
30.
Denied.
5
31.
Denied.
6
32.
As to the documents and/or other media alleged in this paragraph, said
7
documents and/or other media speak for themselves as to their content and, on that
8
basis, Defendant denies the allegations. Defendant is without knowledge or
9
information sufficient to form a belief as to the truth of the allegations of this
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paragraph, and on that basis, denies the allegations. 33.
Defendant is without knowledge or information sufficient to form a
12
belief as to the truth of the allegations of this paragraph, and on that basis, denies
13
the allegations.
14
34.
This paragraph is uncertain in that it has failed to identify any such
15
instructor, and is on that basis denied. Defendant is without knowledge or
16
information sufficient to form a belief as to the truth of the remaining allegations of
17
this paragraph, and on that basis, denies the allegations.
18
35.
This paragraph is uncertain in that it has failed to identify any such
19
speaker, and is on that basis denied. Defendant is without knowledge or
20
information sufficient to form a belief as to the truth of the remaining allegations of
21
this paragraph, and on that basis, denies the allegations.
22
36.
This paragraph is uncertain in that it has failed to identify any such
23
speaker, and is on that basis denied. Defendant is without knowledge or
24
information sufficient to form a belief as to the truth of the remaining allegations of
25
this paragraph, and on that basis, denies the allegations.
26
37.
This paragraph is uncertain in that it has failed to identify any such
27
instructor, and is on that basis denied. Defendant is without knowledge or
28
information sufficient to form a belief as to the truth of the remaining allegations of 4 ANSWER TO COMPLAINT
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this paragraph, and on that basis, denies the allegations. 38.
This paragraph is uncertain in that it has failed to identify any such
3
instructor, and is on that basis denied. Defendant is without knowledge or
4
information sufficient to form a belief as to the truth of the remaining allegations of
5
this paragraph, and on that basis, denies the allegations.
6
39.
To the extent that this paragraph alleges or implies that Defendant
7
taught staff to "close sales" or "work the room," Defendant denies the allegations.
8
To the extent that anyone else is alleged to have done so, this paragraph is uncertain
9
in that it has failed to identify any such person or staff, and is on that basis denied.
10
As to all other matters alleged in this paragraph, Defendant is without knowledge or
11
informaton sufficient to form a belief as to the allegations of this paragraph, and on
12
that basis, denies the allegations.
13
40.
Denied.
14
41.
Defendant is without knowledge or information sufficient to form a
15
belief as to the truth of the allegations of this paragraph, and on that basis, denies
16
the allegations.
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42.
Defendant is without knowledge or information sufficient to form a
18
belief as to the truth of the allegations of this paragraph, and on that basis, denies
19
the allegations.
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43.
To the extent that this paragraph implies that Defendant told anyone
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"at the Preview that the Fulfillment is 'all you need" or that "student-victims are
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told what they really need is the Gold Elite program ....," Defendant denies the
23
allegations. To the extent that anyone else is alleged to have done so, this
24
paragraph is uncertain in that it has failed to identify any such person. As to all
25
other matters alleged in this paragraph, Defendant is without knowledge or
26
informaton sufficient to form a belief as to the allegations of this paragraph, and on
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that basis, denies the allegations.
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44.
The alleged "PlayBook" speaks for itself as to its contents, and on that 5 ANSWER TO COMPLAINT
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basis, Defendant denies those allegations. Defendant denies that there were any
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"student-victims." Defendant is without knowledge or information sufficient to
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form a belief as to the truth of the remaining allegations of this paragraph, and on
4
that basis, denies the allegations.
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45.
This paragraph is uncertain in that it has failed to identify any such
6
speakers or representatives. Defendant further denies that such persons were his
7
representatives. As to all other matters alleged in this paragraph, Defendant is
8
without knowledge or information sufficient to form a belief as to the truth of the
9
allegations of this paragraph, and on that basis, denies the allegations.
10
46.
This paragraph is uncertain in that it has failed to identify any such
11
representatives. Defendant further denies that such persons were his
12
representatives. As to all other matters alleged in this paragraph, Defendant is
13
without knowledge or information sufficient to form a belief as to the truth of the
14
allegations of this paragraph, and on that basis, denies the allegations.
15
47.
Denied that "none of the mentors was handpicked by Donald Trump or
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trained in his investing `secrets'." Defendant is without knowledge or information
17
sufficient to form a belief as to the truth of the remaining allegations of this
18
paragraph, and on that basis, denies the allegations.
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48.
This paragraph is uncertain in that it has failed to identify any person
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who allegedly exerted "up-sell pressure" or any person who was allegedly subjected
21
to any "up-sell pressure." Defendant is without knowledge or information
22
sufficient to form a belief as to the truth of the allegations of this paragraph, and on
23
that basis, denies the allegations.
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49.
Defendant is without knowledge or information sufficient to form a
25
belief as to the truth of the allegations of this paragraph, and on that basis, denies
26
those allegations.
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50.
Defendant admits that the New York Attorney General investigated
Trump University, and that the Texas Attorney General dropped his investigation. 6 ANSWER TO COMPLAINT
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Defendant denies that he "suspended" "Live Events in Texas." As to the remaining
2
allegations in this paragraph, Defendant is without knowledge or information
3
sufficient to form a belief as to the truth of the allegations, and on that basis, denies
4
those allegations.
5
51.
Defendant admits that the New York Attorney General investigated
6
Trump University. As to the remaining allegations in this paragraph, Defendant is
7
without knowledge or information sufficient to form a belief as to the truth of the
8
allegations, and on that basis, denies those allegations.
9
52.
Defendant is without knowledge or information sufficient to form a
10
belief as to the truth of the allegations of this paragraph, and on that basis, denies
11
those allegations.
12
53.
Defendant is without knowledge or information sufficient to form a
13
belief as to the truth of the allegations of this paragraph, and on that basis, denies
14
the allegations.
15
54.
Defendant is without knowledge or information sufficient to form a
16
belief as to the truth of the allegations of this paragraph, and on that basis, denies
17
the allegations.
18
55.
Defendant is without knowledge or information sufficient to form a
19
belief as to the truth of the allegations of this paragraph, and on that basis, denies
20
the allegations.
21
56.
Defendant is without knowledge or information sufficient to form a
22
belief as to the truth of the remaining allegations of this paragraph, and on that
23
basis, denies those allegations. RICO ALLEGATIONS
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57.
Defendant admits that Trump University is a limited liability company
26
registered in New York with its principal place of business in New York, New
27
York. Defendant admits that Trump University changed its name to The Trump
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Entrepreneur Initiative. Defendant denies the remaining allegations of this 7 ANSWER TO COMPLAINT
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paragraph. 58.
Defendant admits that Trump University did not hold a "license to
3
operate out of the State of New York as an 'educational institution' and that
4
Trump University does not offer any "degrees, licenses or credits." Defendant
5
denies the remainder of the allegations in this paragraph.
6
59.
Denied.
7
60.
Defendant admits that Trump University had a call center in Utah.
8
61.
Defendant admits that Trump University has conducted business in the
9
State of California. Defendant denies the remaining allegations of this paragraph.
10
62.
Denied.
11
63.
This paragraph states legal conclusions that require no response. To
12
the extent this paragraph states any factual allegations, Defendant denies such
13
allegations.
14
64.
This paragraph states legal conclusions that require no response. To
15
the extent this paragraph states any factual allegations, Defendant denies such
16
allegations.
17
65.
Denied.
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66.
This paragraph states legal conclusions that require no response. To
19
the extent this paragraph states any factual allegations, Defendant denies such
20
allegations.
21
67.
This paragraph states legal conclusions that require no response. To
22
the extent this paragraph states any factual allegations, Defendant denies such
23
allegations.
24
68.
This paragraph states legal conclusions that require no response. To
25
the extent this paragraph states any factual allegations, Defendant denies such
26
allegations.
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69.
This paragraph states legal conclusions that require no response. To
the extent this paragraph states any factual allegations, Defendant denies such 8 ANSWER TO COMPLAINT
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allegations. 70.
This paragraph states legal conclusions that require no response. To
3
the extent this paragraph states any factual allegations, Defendant denies such
4
allegations.
5
71.
This paragraph states legal conclusions that require no response. To
6
the extent this paragraph states any factual allegations, Defendant denies such
7
allegations.
8 9 10 11
72.
This paragraph states legal conclusions that require no response. To
the extent this paragraph states any factual allegations, Defendant denies such allegations. 73.
This paragraph states legal conclusions that require no response. To
12
the extent this paragraph states any factual allegations, Defendant denies such
13
allegations. CLASS ACTION ALLEGATIONS
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74.
This paragraph states legal conclusions that require no response.
Defendant denies that this case may properly be certified as a class action. 75.
This paragraph states legal conclusions that require no response. To
18
the extent this paragraph states any factual allegations, Defendant denies such
19
allegations. Defendant further denies that this case may properly be certified as a
20
class action or that Plaintiff is an adequate representative of the proposed class.
21
76.
This paragraph states legal conclusions that require no response.
22
Defendant denies that this case may properly be certified as a class action and
23
denies the remaining allegations of this paragraph or that Plaintiff is an adequate
24
representative of the proposed class.
25
77.
Defendant admits that Trump University has certain information about
26
attendees of its programs. Defendant denies that this case may properly be certified
27
as a class action or that Plaintiff is an adequate representative of the proposed class.
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78.
This paragraph states legal conclusions that require no response. To 9 ANSWER TO COMPLAINT
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the extent this paragraph states any factual allegations, Defendant denies such
2
allegations. Defendant further denies that this case may properly be certified as a
3
class action or that Plaintiff is an adequate representative of the proposed class. COUNT Violations of Racketeer Influed and Corrupt Organizations Act, 18 U.S.C. ยง 1962(c)
4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
79.
Defendant re-alleges and incorporates by reference as though fully set
forth herein his responses to Paragraphs 1-78 above. 80.
This paragraph states legal conclusions that require no response. To
the extent this paragraph states any factual allegations, Defendant denies such allegations. 81.
This paragraph states legal conclusions that require no response. To
the extent this paragraph states any factual allegations, Defendant denies such allegations. 82.
This paragraph states legal conclusions that require no response. To
the extent this paragraph states any factual allegations, Defendant denies such allegations. 83.
This paragraph states legal conclusions that require no response. To
the extent this paragraph states any factual allegations, Defendant denies such allegations. 84.
This paragraph states legal conclusions that require no response. To
the extent this paragraph states any factual allegations, Defendant denies such allegations. 85.
Denied.
86.
Denied.
87.
Denied.
88.
This paragraph states legal conclusions that require no response. To
the extent this paragraph states any factual allegations, Defendant denies such
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allegations.
2
89.
Denied.
3
90.
This paragraph states legal conclusions that require no response. To
4
the extent this paragraph states any factual allegations, Defendant denies such
5
allegations.
6
91.
This paragraph states legal conclusions that require no response. To
7
the extent this paragraph states any factual allegations, Defendant denies such
8
allegations. PRAYER FOR RELIEF
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Defendant prays for judgment against Plaintiff as follows:
11
1.
That Defendant be discharged without liability;
12
2.
For all costs of suit and attorneys' fees where applicable; and
13
3.
For such other and further relief as the Court deems just and proper.
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AFFIRMATIVE DEFENSES
2
As and for affirmative defenses to the class action complaint, Defendant
3
alleges as follows, provided however, that by alleging the matters set forth in these
4
defenses, Defendant does not hereby allege or admit that he has the burden of proof
5
and/or persuasion with respect to any of these matters.
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FIRST AFFIRMATIVE DEFENSE
8
(Waiver)
9
Defendant is informed and believes and thereupon alleges that Plaintiff has
10
engaged in conduct and activities by reason of which Plaintiff has knowingly and
11
intentionally waived any and all claims against Defendant and thus is barred from
12
any recovery on those claims.
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SECOND AFFIRMATIVE DEFENSE
15
(Accord and Satisfaction)
16
Defendant is informed and believes and thereupon alleges that Plaintiff is
17
barred from any recovery against Defendant by reason of a prior accord and
18
satisfaction. Plaintiff participated in, enjoyed and gained a benefit from Trump
19
University's programs, and represented that he was pleased with Trump
20
University's programs.
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THIRD AFFIRMATIVE DEFENSE
23
(Injunctive Relief Barred As a Matter of Law)
24
For an injunction to issue, there must be no adequate remedy at law.
25
Throughout the Complaint and in the Prayer for Relief, Plaintiff contends he has
26
adequate remedies at law and seeks monetary compensation. Further, Trump
27
University is no longer offering any seminars, rendering the requested injunction
28
moot. Therefore, Plaintiff's claim for injunctive relief is barred as a matter of law. 12 ANSWER TO COMPLAINT
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FOURTH AFFIRMATIVE DEFENSE
2
(Statute of Limitations)
3
Defendant is informed and believes and thereupon alleges that the 4 year
4
statutes of limitation applicable to RICO claims bar the claim asserted by Plaintiff.
5
Agency Holdings Corp. v. Malley-Duff & Associates, Inc., 483 U.S. 143 (1987).
6
Defendant is informed and believes and thereupon alleges that Plaintiff did not file
7
the Complaint until long after the applicable statute of limitations had run.
8 9
FIFTH AFFIRMATIVE DEFENSE
10
(Estoppel)
11
Defendant is informed and believes and thereupon alleges that Plaintiff's
12
claim is barred by the doctrine of is estoppel. Plaintiff participated in, enjoyed and
13
gained a benefit from Trump University's programs, and represented that he was
14
pleased with Trump University's programs. Plaintiff should be estopped from
15
asserting otherwise now.
16 17
SIXTH AFFIRMATIVE D7FENSE
18
(Laches)
19
Defendant is informed and believes and thereupon alleges that Plaintiff's
20
claim is barred by the doctrine of laches. Plaintiff participated in, enjoyed and
21
gained a benefit from Trump University's programs several years ago. Plaintiff's
22
delay in asserting his claim has caused Defendant prejudice.
23 24
SEVENTH AFFIRMATIVE DEFENSE
25
(Failure to State a Claim)
26 27
The Complaint, and the cause of action alleged therein, fails to state facts sufficient to constitute a cause of action against Defendant.
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EIGHTH AFFIRMATIVE DEFENSE
2
(Uncertainty)
.3
The Complaint, and the cause of action alleged therein, fails in that the
4
Complaint is fatally uncertain.
5 6
NINTH AFFIRMATIVE DEFENSE
7
(Failure to Mitigate)
8 9 10
To the extent that Plaintiff claims any entitlement to recover damages from Defendant, Plaintiff failed to use reasonable care to mitigate and reduce as much as reasonably possible the damages, if any, allegedly sustained by Plaintiff.
11 12
TENTH AFFIRMATIVE DEFENSE
13
(Contributory Negligence)
14
Defendant is informed and believes and thereon alleges that the Complaint,
15
and the cause of action alleged therein, fails as a result of Plaintiffs own negligent
16
conduct.
17 18
ELEVENTH AFFIRMATIVE DEFENSE
19
(Unclean Hands)
20
Defendant is informed and believes and thereon alleges that the Complaint,
21
and the cause of action alleged therein, is barred by the doctrine of unclean hands.
22
Plaintiff participated in, enjoyed and gained a benefit from Trump University's
23
programs, and represented that the Trump University programs were excellent, that
24
the programs far exceeded his expectations, and that the quality of those programs
25
was so high that he either did or would recommended the programs to others.
26
Plaintiff was either dishonest in his evaluations of Trump University, or the
27
allegations in the Complaint are false. To the extent that Plaintiff was dishonest in
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his evaluations of the Trump University program, or has been dishonest in his
2
allegations in the Complaint, Plaintiff has come to Court with unclean hands.
3 4
TWELFTH AFFIRMATIVE DEFENSE
5
(Consent)
6
Defendant is informed and believes and thereon alleges that the Complaint,
7
and the cause of action alleged therein, is barred because Plaintiff consented to the
8
conduct about which he now complains.
9 10
THIRTEENTH AFFIRMATIVE DEFENSE
11
(Ratification)
12 13
Defendant is informed and believes and thereon alleges that the Complaint, and the cause of action alleged therein, is barred by the doctrine of ratification.
14 15
FOURTEENTH AFFIRMATIVE DEFENSE
16
(Unjust Enrichment)
17
Defendant is informed and believes and thereon alleges that the Complaint,
18
and the cause of action alleged therein, is barred because an award on such a cause
19
of action would result in unjust enrichment to Plaintiff. Plaintiff participated in,
20
enjoyed and gained a benefit from Trump University's programs, and represented
21
that the Trump University programs were excellent, that the programs far exceeded
22
his expectations, and that the quality of those programs was so high that he either
23
did or would recommended the programs to others. Allowing Plaintiff to obtain
24
such benefits and awarding damages to Plaintiff against Defendant would be unjust.
25 26
FIFTEENTH AFFIRMATIVE DEFENSE
27
(Good Faith)
28
Defendant acted in good faith in all matters and things alleged in the 15 ANSWER TO COMPLAINT
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1
Complaint and did not directly or indirectly induce acts in purported violation of
2
any duties allegedly owed to Plaintiff.
3 4
SIXTEENTH AFFIRMATIVE DEFENSE
5
(Fraud/Misrepresentation)
6
The Complaint, and the cause of action contained therein, is barred due to
7
Plaintiff's own intentional and/or negligent misrepresentations. Defendant is
8
informed and believes and thereon alleges that on or about May 8-10, 2009,
9
Plaintiff attended a Fast Track to Foreclosure Training program ("Training
10
Presentation"). During or shortly after the Training Presentation, Plaintiff
11
represented to Trump University and its staff members, among other things, that (1)
12
the quality of the presentation was excellent; (2) the information was very useful;
13
(3) the instructor exceeded his expectations as a subject matter expert, that he
14
"already had very high expectations" and the instructor "did a great job!"; and (4)
15
the remaining staff members were professional, approachable, and answered his
16
questions. Plaintiff also represented to Trump University and its staff members that
17
he would attend another Trump University seminar, that he would recommend
18
Trump University seminars to a friend, and that he had the opportunity to meet with
19
a Trump University Team Member to discuss his personal goals. Indeed, the only
20
suggestion that Plaintiff offered to improve the seminar was to "[Nave lunch
21
sandwhiches brought in" and to make lunch 45 minutes.
22
Defendant is informed and believes and thereon alleges that Plaintiff's
23
representations were representative of a vast majority of the attendees of Trump
24
University programs, and that Trump University had over a 97% approval rating
25
from its attendees.
26
Defendant is informed and believes and thereon alleges that when Plaintiff
27
made the representations described above, among others, Plaintiff knew them to be
28
true, as Plaintiff had just completed his participation in those programs. Defendant 16 ANSWER TO COMPLAINT
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is informed and believes and thereon alleges that, nevertheless, Plaintiff then filed a
2
complaint making allegations and representations that directly contradict the
3
represenations made to Trump University and upon which Trump University relied.
4
Trump University and/or Defendant relied on the representations made by Plaintiff
5
after he completed the Trump University programs, as well as the representations
6
made by the other students whom Plaintiff attempts to include in his proposed class,
7
which representations relate to the quality of the seminars and materials that had
8
been provided by Trump University.
9
JURY DEMAND
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Defendant Donald J. Trump hereby demands a trial by jury on all issues so triable.
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Dated: March 4, 2014
SHUMENER, ODSON & OH LLP /s/ Betty M. Shumener By: BETTY M. SHUMENER JOHN D. SPURLING Attorneys for Donald J. Trump
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Case 3:13-cv-02519-GPC-WVG Document 22 Filed 03/04/14 Page 19 of 19
CERTIFICATE OF SERVICE I hereby certify that on March 4, 2014, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the e-mail addresses denoted on the Notice of Electronic Filing.
I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on March 4, 2014.
/s/ Betty M. Shumener Betty M. Shumener Shumener, Odson & Oh LLP Attorneys for Defendant Donald J. Trump