Case Document 1 Filed 06/16/16 Page 1 of 13 PageID 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA r, 3.8% I Pg Ml INDLANAPOLIS DIVISION 2: 5-JANE DOE NO. 62, . Plaintiff, - COMPLAINT I Civil Action No.: [Trial by Jury Demanded] INDIANA UNIVERSITY BLOOMINGTON, BETA ALPHA SHELTER OF DELTA TAU DELTA FRATERNITY, INC, and DELTA TAU DELTA, Defendants. I. INTRODUCTION 1. This Complaint alleges a violation of Title IX, 20 U.S.C. ?1681 et. seq., and negligence. It is brought by a female former student at INDIANA UNIVERITY BLOOMINGTON against INDIANA UNIVERSITY BLOOMINGTON, BETA ALPHA SHELTER OF DELTA TAU DELTA FRATERNITY, INC., and DELTA TAU DELTA, based on the sexual assault perpetrated by John Phillip Enochs, a former Indiana University Bloomington Student and member of the DELTA TAU DELTA fraternity in or about April, ZOI 5. John Phillip Enochs had previously been accused of sexual assault by another female student in 2013. INDIANA UNIVERSITY BLOOMINGTON of?cials and administrators showed deliberate indifference to actual notice of this sexual assault and condoned DELTA TAU DELTA fostering an environment of illegal and dangerous activity, as well as sexual assault. DELTA TAU DELTA, et. al., ignored Enochs? history of sexual assault and failed to institute corrective measures to protect invitees from a foreseeable sexual assault at a DELTA TAU DELTA social event at the DELTA TAU DELTA House. Case Document 1 Filed 06/16/16 Page 2?of 13 PageID 2 II. JURISDICTION 2. This court has federal question subj ect matter jurisdiction of this action pursuant to 28 U.S.C. ?133l and 20 U.S.C. ?1681(a). 3. This Court has venue of this action under 28 U.S.C. ?1391 as INDIANA UNIVERSITY BLOOMINGTON is located in this District, the BETA ALPHA SHELTER OF DELTA TAU DELTA FRATERNITY, INC., House is located in this district, the Plaintiff resided in this District at all material times, and a substantial part of the events and omissions giving rise to the claim occurred in this District. 4. JANE DOE also ?les this action to recover for state law claims arising under Indiana common law, pursuant to 28 U.S.C. ?l367, which arise out of the same common nucleus of facts as the aforementioned claims under Title IX. PARTIES 5. JANE DOE NO. 62 is a resident of Montgomery County, -Maryland. This action is brought anonymously for the following reasons: Plaintiff seeks to preserve her privacy in this sensitive and highly personal matter; she wishes to avoid further embarrassment and damage, as this case concerns an alleged sexual assault, which is a matter of the utmost intimacy; identi?cation of Plaintiff poses a high risk of mental harm; the action is against a governmental entity; and, there is no risk of prejudice to Defend-ants from Plaintiff proceeding anonymously, because Defendants and counsel will be fully aware of the identity, age, and address of the Plaintiff. 6. Defendant, INDIANA UNIVERSITY BLOOMINGTON 107 S. Indiana Ave, Bloomington, Indiana 47405 is a public research university. IU receives federal ?nancial- assistance. JANE DOE was a student at IU at all relevant times. I Case Document 1 Filed 06/16/16 Page 3 of 13 PageID 3 7. Defendant, BETA ALPHA SHELTER OF DELTA TAU DELTA FRATERNIT Y, INC., is a non-pro?t domestic corporation. DTD is a male fraternal organization at IU. The House?, where DTD members live and associate is located at 1431 North Jordan Avenue, Bloomington, Indiana 47406. 8. Defendant, DELTA TAU DELTA is a non-pro?t foreign corporation with its principle place of business in Fishers, Indiana. DELTA TAU DELTA is the controlling body of the national DELTA TAU DELTA FRATERNITY and owns, controls, operates, and provides guidelines and rules for the BETA ALPHA SHELTER OF DELTA TAU DELTA FRATERNITY, INC. 9. All Delta Tau Delta entities will be hereinafter referred to collectively as IV. FACTUAL ALLEGATIONS 10. John Phillip Enochs. (?Enochs?) is an adult male. At all material times, Enochs was a student at IU and a member of DTD. 11. At all material times, JANE DOE was a student at IU. 12. Prior to the alleged sexual assault of JANE DOE by Enochs, IU was well aware of the prevalence of sexual assaults on the IU campus, and IU fostered an environment of foreseeable, rampant, and unpunished sexual assault. 13. Upon information and belief, IU had the 7th most reported sexual offenses of any university in the country. 14. Upon information and belief, prior to the alleged sexual assault of JANE DOE by Enochs, between January 2008 and November 2014, 712 allegations of alleged sexual assaults were reported to Bloomin'gton and IU police departments. 15. Prior to the sexual assault of JANE DOE, DTD was well aware of the prevalence of sexual assaults on-the IU campus and the ubiquitousness of sexual assaults in fraternity houses 3 Case Document 1 Filed 06/16/16 Page 4 of 13 PageID 4 at IU and across the country and multiple previous allegations of sexual assault speci?cally at DTD at IU. 16. Prior to the alleged sexual assault of JANE DOE by Enochs, DTD had been fosteringra dangerous environment of illegal, illicit, and sexually abusive behavior that was well known by fraternity of?cials. 17. Prior to the alleged sexual assault of JANE DOE by Enochs, a DTD fraternity member was arrested for buying and distributing large quantities of the drug Xanax out of the DTD House. Xanax, a brand of Aplrazolam, is a commonly used ?date-rape? drug on college campuses. Due to its ability to cause extreme intoxication when mixed with alcohol, as well as causing the inability to remember events that took place while under the in?uence, Xanax is commonly used in the college community to facilitate sexual assault. 18. Upon information and belief, prior to the sexual assault of JANE DOE by Enochs, DTD was the subject of numerous violations and complaints for dangerous and illegal activities that took place at the DTD House. Such infractions included, but were not limited to: alleged sexual assaults by DTD members, encouraging and facilitating underage drinking, encouraging and facilitating the use and distribution of narcotics, incidents of forced drinking, incidents of sexual harassment, and incidents of assault. 19. Despite the multiple infractions against DTD fOr dangerous activity that made it reasonably foreseeable that sexual assaults would take place at DTD House, 1U continued to allow DTD to remain on campus and throw parties at the DTD House. 20. Despite the multiple infractions against DTD for dangerous activity that made it reasonably foreseeable that sexual assaults would take place at DTD House, DTD continued to Case Document 1 Filed 06/16/16 Page 5 of 13 PageID 5 disobey laws and the safety of its guests and invitees by failing to take reasonable precautions to prevent sexual assault at the DTD house. Actual Notice of Sexual Harassment by John Phillip Enochs 21. On or about October, 2013, a female IU student, M.S., was allegedly sexually assaulted by Enochs. 22. The alleged sexual assault of MS. took place after Enochs plied-her with alcohol at the DTD House, despite M.S. being under the legal drinking age at the time. 23. MS. reported her sexual assault to the IU Police Department. 24. Upon information and belief, IU was aware of the alleged sexual assault by Enochs. 25. Upon information and belief, DTD was aware of the alleged sexual assault by Enochs. 26. .It was foreseeable that if Enochs were allowed to stay on the IU campus, he would sexually assault another female IU student. 27. It was foreseeable that if Enochs were allowed to continue his membership with DTD and continue to attend DTD parties where alcohol was served to underage females, he would sexually assault another female. Deliberate Indifference 28. In response to the actual notice of sexual assault by Enochs, IU administrators with authority to take corrective measures showed deliberate indifference by taking no responsive action. Enochs continued to be enrolled at IU and continued to have unfettered access to females on a campus that fostered sexual assault. 29. In response to the actual notice of sexual assault by Enochs, DTD showed deliberate indifference by taking no responsive action. Enochs continued to be a member of DTD, where he was free to attend parties where underage girls were encouraged and pressured to drink alcohol. 5 Case Document 1 Filed 06/16/16 Page 6 of 13 PageID 6 30. Further, DTD continued to foster and facilitate an environment of sexual assault and dangerous illicit activity, without providing reasonable safety measures for invited guests at the DTD House. Sexual Assault of JANE DOE 31. On or about April 1 1, 2015, JANE DOE was at a party hosted by DTD at the DTD House. 32. Although she was under the legal drinking age, DTD permitted and encouraged her to drink copious amounts of alcohol by passing around a large bottle of liquor and encouraging the under-age? girls to drink straight from the bottle. This was a common practice at the DTD House, referred to as ?handles?. 33. Although Enochs had previously been accused of sexually assaulting a female attendee at the DTD House where underage drinking was encouraged, DTD allowed Enochs to attend this party and have unfettered access to females. 34-. After being encouraged and pressured to drink alcohol by DTD members, JANE DOE passed out and then awakened to Enochs sexually assaulting her in a room in the DTD House. 35. JANE DOE pleaded for him to stop repeatedly and attempted to push Enochs off of her. Enochs ignored JANE pleas, overpowered JANE DOE, and forcefully raped-JANE DOB. 36. As a result of the alleged sexual assault by Enochs, JANE DOE has suffered, and continues to suffer from physical, mental and emotional anguish with permanent harmful effects. 37. Plaintiff is entitled to a judgment against Defendants for actual and punitive damages in an amount to be determined by a jury. Case Document 1 Filed 06/16/16 Page 7 of 13 PageID 7 COUNT I VIOLATION OF TITLE IX, EDUCATION AMENDMENTS OF 1972 - 20 U.S.C. ?1681 ET SEQ. (Against Indiana University Bloomington) 38. Plaintiff, JANE DOE, repeats and re-alleges the allegations set forth in paragraphs 1 through 37 above, 39. At all relevant times, IU received federal ?nancial assistance. 40. JANE DOE had a right to not be subject to sexualdiscrimination, harassment or abuse while she participated in education program or activity receiving federal ?nancial assistance. 41. IU had actual notice that Enochs had sexually harassed and assaulted a female student and posed a grave danger to female students at IU of further sexual harassment and abuse, prior to the time that JANE DOE was sexually abused by Enochs. 42. IU of?cials and administrators With actual notice had authority to institute corrective measures on behalf of IU in response to the danger posed by Enochs. 43. Upon information and belief, the decision of IU, after receipt of actual notice of sexual assault by En0chs, to allow Enochs to continue to attend IU without instituting any corrective measures, were of?cial decisions to ignore the danger of sexual harassment or sexual abuse to the female students in their care. 44. As a result of this gross failure to act, JANE DOE was sexually harassed and sexually abused by Enochs. 45. As a direct result and moving force behind the sexual discrimination, harassment and abuse described herein, JANE DOE was deprived of the bene?ts of an education at IU, and has suffered severe and permanent and physical injuries, mental anguish, pain and suffering, and loss of enjoyment of life. Case Document 1 Filed 06/16/16 Page 8 of 13 PageID 8 WHEREFORE, Plaintiff, JANE DOE, demands compensatory damages, attorneys? fees and costs pursuant to 42 U.S.C. ?1988, against Defendant, INDIANA UNIVERSITY BLOOMINGTON, and such other and further relief as this Court deems just and proper. COUNT II NEGLIGENCE (Against Indiana University Bloomington) 46. Plaintiff, JANE DOE, repeats and re-alleges the allegations in paragraphs 1 through 37 above. 47. JANE DOE and IU had a special relationship based on JANE status as a 7 student enrolled at IU. 48. IU and Enochs had a special relationship based on Enochs? status as a student enrolled in Defendant?s school. 49. Upon information and belief, IU knew or should have known that Enochs had a history of alleged sexual assault, and posed a foreseeable risk of danger to female students at IU. 50. Upon information and belief, it was foreseeable to Defendant that Enochs would sexually assault another female student. 51. IU owed a duty to JANE DOE to protect her from the foreseeable criminal misconduct of Enochs. 52. IU could have, and should have, expelled Enochs from the IU campus. 53. IU breached its duty by allowing Enochs, who had been accused of sexual assault of a female IU student, to continue his enrollment at IU and have access to female IU students. 54. As a result of IU ignoring the prior allegation of sexual assault against Enochs and allowing him to stay on campus, Enochs was able to sexually assault JANE DOE. Case DocUment 1 Filed 06/16/16 Page 9 of 13 PageID 9 55. Defendant owed a duty to JANE DOE to ensure that any fraternity sanctioned by and associated with IU was safe, and was not fostering and encouraging an environment of sexual assault. 56. Defendant could have, and should have, in response to any of the prior complaints and infractions against DTD: suspended DTD, forbade DTD from hosting social events at the DTD House, supervised DTD to ensure that underage drinking, criminal activity, and sexual assault were not taking place, or permanently removed DTD from campus. 57. Defendant breached its duty by not taking any of the Safety precautions above, or any safety precautions at all, in response to actual and/or constructive knowledge of multiple instances of sexual assault, underage drinking, distribution of a date rape drug, and other complaints and infractions that made it foreseeable that another sexual assault was likely to occur at the DTD House. 58. As a result of IU ignoring the danger posed to female students at DTD, DTD was able to foster a lawless and dangerous environment of illicit drug use, underage drinking, and sexual assault. 59. As a result of negligence, JANE DOE has suffered severe and permanent physical and injuries, shame, humiliation and inability to lead a normal life. WHEREFORE, Plaintiff, JANE DOE, demands judgment against Defendant, INDIANA UNIVERSITY BLOOMINGTON, for damages, attorneys? fees and costs and any additional relief to which they may be entitled. Case Document 1 Filed 06/16/16 Page 10 of 13 PageID 10 NEGLIGENCE: RETENTION AND SUPERVISION (Against Delta Tau Delta, et. al.) I 60. Plaintiff, JANE DOE, repeats and re-alleges the allegations set forth in paragraphs 1 through 37 abovespecial relationship with Enochs based upon Enochs? membership in DTD. 62. DTD was in a special relationship with JANE DOE as she was an invitee to its fraternity house. 63. DTD knew, or in the exercise of reasonable care, should have known, that Enochs had been accused of sexually assaulting a female after drinking alcohol with her at a DTD social event. - 64. It was foreseeable that if DTD allowed Enochs to attend a DTD social event where underage females were not only permitted to drink alcohol, but were encouraged to drink straight liquor out of the bottle, that Enochs. would commit another sexual assault. 65. DTD had a duty to take reasonable precautions to protect female guests at the DTD House from a foreseeable sexual assault by Enochs. 66. DTD could have, and should have, in the wake of allegations of sexual assault against Enochs: forbade Enochs from attending social events where alcohol was served, supervised Enochs to ensure he was not sexually assaulting female guests, or revoked Enochs DTD membership altogether. . I 67. DTD breached its duty owed to JANE DOE, by not taking any of the above precautions, -or any reasonable precaution at all, to prevent Enochs from committing a sexual assault at the DTD social event. 10 Case Document 1 Filed 06/16/16 Page 11 of 13 PageID 11 68. As a result of negligence, JANE DOE was sexually assaulted by Enochs, and has suffered severe and permanent physical and injuries, shame, humiliation and inability to lead a normal life. WHEREFORE, Plaintiff, JANE DOE, demands judgment against Defendants BETA ALPHA SHELTER OF DELTA TAU DELTA FRATERNITY, INC, and DELTA TAU DELTA, for damages, attorneys? fees and costs and any additional relief to which they may be entitled. COUNT IV NEGLIGENCE: PREMISES LIBALITY (Against Delta Tau Delta, et. a1.) 69. Plaintiff, JANE DOE, repeats and re-alleges the allegations set forth in paragraphs 1 through 37 above. 70. DTD was in an host invitee relationship with JANE DOE, based upon her attendance as a guest at a social event at the DTD House. 71. DTD owed a duty to Plaintiff, JANE DOE as an invitee to the DTD House and a guest at a DTD social event, to take reasonable precautions to prevent foreseeable criminal acts against her. 72. DTD knew, or in the exercise of reasonable care, should have known, that sexual assaults were rampant among college fraternities, particularly at IU, and particularly at DTD. 73. Upon information and belief, DTD was informed of the dangers and prevalence of sexual assaults at fraternity houses. - 74. Upon information and belief, DTD was aware of multiple sexual assault allegations against DTD members at IU, multiple sexual assault allegations against DTD members across the country, multiple sexual assault allegations that took place at the DTD House at IU, and multiple sexual assault allegations that took place at other fraternity houses at IU. 11 Case Document 1 Filed 06/16/16 Page 12 of 13 PageID 12 75. It was common knowledge at DTD, and all fraternity houses at IU, that sexual assault was a foreseeable and dangerous risk at ?aternity parties. 76. DTD was aware that a DTD member had been arrested for buying, selling, and distributing a known date-rape drug out of the DTD House. 77. DTD knew, or in the exercise of reasonable care, should have known, that permitting and encouraging underage drinking greatly increases the risk of sexual asSault. 7 8. DTD was aware that the social events thrown at the DTD House, and the culture of the DTD members, fostered and encouraged an environment of dangerous activity and sexual assault. 79. DTD knew, or in the exercise of reasonable care, should have known, that Enochs, an attendee at the DTD social event, had been previously accused of sexual assault after drinking alcohol with the alleged victim at a DTD social event. 80. It was foreseeable that the female invitees at the DTD House could be at risk of being sexually assaulted, particularly those being encouraged to drink dangerous amounts of alcohol, despite being under the legal drinking age. 81. As an invitee, DTD owed a duty to JANE DOE to take reasonable precautions to prevent her from being sexually assaulted at the DTD House during a DTD Social event. 82. Not only did DTD breach that duty by not taking any reasonable precautions to protect JANE DOE from sexual assault, but DTD acted recklessly, willfully, and with wanton disregard to the safety of JANE DOE, by permitting, sanctioning, and encouraging behavior that increased the risk of sexual assault. 12 ?mm- T. Case Document 1 Filed 06/16/16 Page 13 of 13 PageID 13 83. As a result of DTD breaching its duty'owed to JANE DOE, and acting recklessly in encouraging behavior that increased the risk of sexual assault, JANE DOE was sexually assaulted on the premises of the DTD House, by a DTD fraternity member. 84. As a result of negligence, JANE DOE has suffered severe and permanent physical and injuries, shame, humiliation and inability to lead a normal life. WHEREFORE, Plaintiff, Plaintiff, JANE DOE, repeats and re-alleges the allegations set forth in paragraphs 1 through 37 above, demands judgment against Defendants BETA ALPHA SHELTER OF DELTA TAU DELTA FRATERNITY, INC., and DELTA TAU DELTA, for damages, attorneys? fees and costs and any additional relief to which they may be entitled. DEMAND FOR JURY TRIAL Plaintiff demands a jury trial in this action. Dated: June 5, 2016 Respectfully submitted: HERMAN LAW 3351 NW Boca Raton Blvd. Boca Raton, FL 33431 Tel: 212-390?0100 Fax: 305-931-0877 By: Jeffrey M. Herman jhemiangaiheimanlawcom (pending pro hac admission) Arick W. Fudali afudali@hemanlaw.com Cpending pro hac admission) 1.3 1544 (Revmlgase sFW/lB/m Page 1 of 1 PageID 14 The I 44 civil cover sheet and the information contained herein neither riplace nor supplement the ?lin and service of pleadings or other papers as re uired by law, except as provrded by local rules of?court. This form, approved by the Judrcral Con erence of the United States in eptember 1974, is required for the use of the lerk of Court for the purpose of Initiating the cm] docket sheet. INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) 1. a PLAINTIFFS DEFENDANTS JATJE DOE 62 INDIANA UNIVERSITY BLOOMINGTON, BETA ALPHA SHELTER - VI OF DELTA TAU DELTA FRATERNITY, INC., and DELTA TAU County of Residence of 2 5 DELTA (EXCERTW LAJNJIEE County of Residence Of First Listed Defendant Monroe (IN US. PLAINTIFF CASES ONLY) i NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED. int r, Attorneys (Firm Name, Address, Teleplibtie Arlc Fudali, Esq., Jeff Herman. Esq. Herman Law, 3351 NW Boca Raton Blvd, Boca Raton, FL 33431 (305) 931 -2200 JMS -DKL (Place an in One Box for Pi'ainri?r H. (Place an in One Box Only) (F or Diversity Cases Only) and One Box for Defendant) 13 1 US. Government 2! 3 Federal Question PTF DEF PTF DEF Plaintiff (US. GovemmentNot a Party) Citizen of This State CI 1 CI 1 Incorporated or Principal Place 4 4 of Business In This State Cl 2 US. Government l3 4 Diversity Citizen of Another State El 2 El 2 Incorporated and Principal Place Cl 5 CI 5 Defendant (Indicate Citizenship of Parties in Item 111) of Business In Another State Citizen or Subject of a El 3 El 3 Foreign Nation El 6 6 Foreig Country IV. NAT RE OF SUIT (Place an in One Box Only) 110 Insurance PERSONAL INJURY PERSONAL INJURY CI 625 Drug Related Seizure El 422 Appeal 28 USC 158 El 375 False Claims Act 1 CI 120 Marine El 310 Airplane El 365 Personal Injury - of Property 21 USC 881 [3 423 Withdrawal 130 Miller Act CI 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a)) El 140 Negotiable Instrument Liability Cl 367 Health Care/ El 400 State Reapportionment CI 150 Recovery of Overpayment Cl 320 Assault, Libel Pharmaceutical 2 13 410 Antitrust Enforcement of Judgment Slander Personal Injury 820 Copyri CI 430 Banks and Banking 151 Medicare Act 330 Federal Employers? Product Liability El 830 Patent 13 450 Commerce Cl 152 Recovery of Defaulted Liability CI 368 Asbestos Personal I3 840 Trademark 460 Deportation Student Loans 340 Marine Injury Product ID 470 Racketeer In?uenced and (Excludes Veterans) 345 Marine Product Liability Corrupt Organizations El 153 Recovery of Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards El 861 HIA (1395ff) I3 480 Consumer Credit of Veteran?s Bene?ts CI 350 Motor Vehicle CI 370 Other Fraud Act El 862 Black Lung (923) 490 Cable/Sat TV CI 160 Stockholders? Suits El 355 Motor Vehicle 13 371 Truth in Lending 720 Labor/Management 863 (405(g)) Cl 850 Securities/Commodities/ CI 190 Other Contract Product Liability [3 380 Other Personal Relations 864 SSID Title XVI Exchange 195 Contract Product Liability 5 360 Other Personal Property Damage El 740 Railway Labor Act El 865 RSI (405(g)) CI 890 Other Statutory Actions El 196 Franchise Injury 0 385 Property Damage El 751 Family and Medical El 891 Agricultural Acts Cl 362 Personal Injury - Product Liability Leave Act El 893 Environmental Matters Medical Malraclice CI 790 Other Labor Litigation El 895 Freedom of Information 5, A a El 791 Employee Retirement Act Cl 210 Land Condemnation El 440 Other C1v11 Rights Habeas Corpus: Income Security Act El 870 Taxes (US. aintiff 896 Arbitration 220 Foreclosure El 441 Voting 13 463 Alien Detainee or Defendant) El 899 Administrative Procedure El 230 Rent Lease Ejectment El 442 Employment 510 Motions to Vacate 871 IRS?Third Party Actheview or Appeal of Cl 240 Torts to Land 443 Housing] Sentence 26 USC 7609 Agency Decision 245 Tort Product Liability - Accommodations 530 General El 950 Constitutionality of 290 All Other Real Property 13 445 Amer. w/Disabilities - 535 Death Penalty '7 State Statutes Employment Other: Cl 462 Naturalization Applicatio CI 465 Other Immigration Actions 446 Amer. waisabilities El 540 Mandamus Other Other El 550 Civil Rights CI 448 Education 555 Prison Condition 560 Civil Detainee - Conditions of Con?nement V. ORIGIN (Place an in One Box Only) K1 Original El 2 Removed from El 3 Remanded from El 4 Reinstated or Cl 5 Transferred from El 6 Multidistrict Proceeding State Court Appellate Court Reopened Anotljagr District Litigation spec: Cite the US. Civil tute under which on are ?lin (Do not cite jurisdictional statutes unless diversity): Title Ix, 20 us. Brief description of cause: I . Female student sexually assaulted in fraternity house on school campus VI. CAUSE OF ACTION VII. REQUESTED IN [3 CHECK IF THIS IS A CLASS ACTION DEMAND 8 CHECK YES only if demanded in complaint: COMPLAINT: UNDER RULE 23, JURY DEMAND: Yes El No RELATED IF ANY (See instructions): JUDGE DOCKET NUMBER DATE 0 ll SIGNATURE OF ATTORNEY OF RECORD FOR OFFICE USE ONLY RECEIPT AMOUNT APPLYING IFP JUDGE MAG. JUDGE Page 1 of 3 DNBPA (212} 390-01011 SI-IP DATE: ISJUNIE RMAN LAW 1 Wain 41 MANSON AVENUE SUITE 3: NY 10310 BILL SEW UNITED ST US TO OFFICE USDC, SOUTHERN DISTRICT INDIANA 46 EAST OHIO STREET ROOM 105 INDIANAPOLIS IN 45204 REF PECK WEI-2200 Peri DEPTbl.? I'OVERNIGHT 7765 3130 41 46204 IND 3 a CD a 4129 96.16 R1806 I030