Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 1 of 10

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF NEW YORK
ACACIA COMMUNICATIONS, INC.,
Plaintiff,
v.
THE RESEARCH FOUNDATION FOR
THE STATE UNIVERSITY OF NEW
YORK,

CIVIL ACTION NO. ________________

1:16-CV-1506 (LEK/CFH)

SUNY POLYTECHNIC INSTITUTE,

and
COLLEGE OF NANOSCALE SCIENCE
AND ENGINEERING,
Defendants.
COMPLAINT AND JURY DEMAND
Plaintiff Acacia Communications, Inc. (Acacia or Plaintiff) brings this civil
action against Defendants The Research Foundation for the State University of New York
(the Foundation), SUNY Polytechnic Institute (SUNY Poly), and the College of
Nanoscale Science and Engineering (CNSE) (collectively Defendants).
THE PARTIES
1.

Plaintiff Acacia is a Delaware Corporation having a place of business at

Three Clock Tower Place, Suite 100, Maynard, MA 01754.

2.

Upon information and belief, Defendant Foundation is a private non-profit

educational corporation established pursuant to Section 216-a of the New York State
Education Law, with its principal offices located at 35 State Street, Albany, New York
12207.

Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 2 of 10

3.

Upon information and belief, Defendant CNSE, formerly known as

College of Nanoscale Science and Engineering at the University at Albany, is a college of

SUNY Poly, with its principal offices located at 257 Fuller Road, Albany, New York
12203.
4.

Upon information and belief, Defendant SUNY Poly is a non-profit

educational corporation established pursuant to Section 216-a of the New York State
Education Law, with its principal offices located at 100 Seymour Road Utica, New York
13502, and is jointly and severally liable for Defendant CNSEs obligations and
liabilities.
JURISDICTION AND VENUE
5.

Plaintiff is a Delaware Corporation and Defendants are educational

corporations under the laws of the State of New York. Acacia seeks damages for
Defendants failure to perform under a contract entered into with Acacia, damages
associated with the Defendants past disclosure of Acacias proprietary and confidential
information, and injunctive relief associated with the Defendants ongoing disclosure of
such information. Damages and other relief sought herein are in an amount greater than
$75,000. As a result, this Court has jurisdiction pursuant to 28 U.S.C. 1332.
Jurisdiction over the state law claims is proper under 28 U.S.C. 1367.
6.

Venue is proper in this judicial district under 28 U.S.C. 1391(b).

BACKGROUND

7.

Acacia is a leader in network technology. Acacias mission is to deliver

high-speed coherent optical interconnect products that transform communications

networks, relied upon by cloud infrastructure operators and content and communication

Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 3 of 10

service providers, through improvements in performance and capacity and a reduction in

associated costs.
8.

In December 2013, Acacia and the Foundation, acting on behalf of CNSE,

entered into an agreement titled Research Agreement (the Agreement).

9.

The Agreement relates to research and development activities in the area

of silicon photonics. By the terms of the Agreement, Acacia approved funding to support
a research and development project, which would be conducted and supervised by a
principal investigator, Douglas Coolbaugh, at CNSE, pursuant to the Scope of Work
(SOW) incorporated into the Agreement. (Agreement at 1).
10.

The Agreement contemplates the receipt of confidential information by

the parties during the course of the research collaboration. (Agreement at 7).
Defendants agreed to hold and maintain all such [confidential] information, whether oral
or written, in confidence and not disclose to others, not make copies of it, not use it,
except as expressly agreed beforehand by [Acacia]. (Agreement at 7(a)).
11.

Under the Agreement, Defendants were not permitted to publish the

results of research conducted under the Agreement unless, prior to any publication, or
presentation they provided Acacia with at least thirty (30) days notice of any proposed
publication as well as the full content of that publication for [Acacias] review.
(Agreement at 8).
12.

Further, under no circumstances did Defendants have any right, under the

Agreement, to publish any of Acacias proprietary and confidential information: The

parties agree that in the event [Acacia] provides written notice to the Foundation that the
information proposed to be disclosed or published contains confidential or proprietary

Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 4 of 10

information of [Acacia], the Foundation, CNSE and their personnel shall not publish or
disclose the information as proposed and the parties shall negotiate an acceptable version
of the proposed disclosure. (Agreement at 8).
DEFENDANTS UNAUTHORIZED DISCLOSURE OF PLAINTIFFS
CONFIDENTIAL AND PROPRIETARY INFORMATION
13.

In April 2016, Acacia became aware that CNSE made certain confidential

and proprietary information of Acacias publicly available in violation of the Agreement.

14.

Upon information and belief, CNSE disclosed a document entitled AIM

Photonics Design Guide (the Guide) to members of the American Institute for
Manufacturing Integrated Photonics (AIM) in anticipation of AIMs First Quarter
Project Status Update Meeting on April 14, 2016 (AIM Meeting).
15.

Upon information and belief, the Guide was thereafter presented and made

available to any members of AIM or the public attending the AIM Meeting.
16.

The Guide expressly references Acacias confidential and proprietary

information.
17.

On April 8, 2016, pursuant to Paragraph 8 of the Agreement, Acacia

notified CNSE that CNSE had disclosed Acacias confidential and proprietary
information and of Acacias understanding of CNSEs plan for additional, future
disclosures of such information
18.

In its April 8, 2016 letter, Acacia also noted that CNSE had failed to

provide Acacia of its intent to disclose such information thirty days prior to the proposed
disclosure or publication pursuant to Section 8 of the Agreement.

Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 5 of 10

19.

Upon information and belief, CNSE refused and failed to cease such

publication or to remedy such breach, and continues to disclose Acacias confidential and
proprietary information to members of AIM and the general public.
PLAINTIFFS TERMINATION OF THE AGREEMENT
20.

On July 28, 2016, Acacia wrote to CNSE regarding CNSEs failure to

provide to Acacia certain products it was required to deliver to Acacia under the
Agreement and CNSEs refusal to collaborate with Acacias personnel as mandated by
the Agreement.
21.

In the July 28, 2016 letter, Acacia notified CNSE, pursuant to Sections 5

and 11 of the Agreement, that Acacia would terminate the Agreement thirty (30) days
from the date of the notice because of these deficiencies. (Agreement at 5, 11).
22.

In the July 28, 2016 letter, Acacia requested that CNSE return the sum of

$51,000 for work for which Acacia had paid but that CNSE had failed to perform under
the Agreement.
23.

Upon termination of the Agreement, CNSE was required to perform

certain obligations under the Agreement, including returning to Acacia or destroying any
and all items provided to CNSE by Acacia under the Agreement. (Agreement at 5).
24.

To date, CNSE has not responded to Acacias July 28, 2016 notification of

termination, has upon information and belief failed to comply with its obligations under
the Agreement to return or destroy any and all items provided to CNSE by Acacia under
the Agreement, and has not provided Acacia with the refund to which it is entitled for
CNSEs failure to perform under the Agreement. (Agreement at 5).

Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 6 of 10

COUNT I
(Breach of Contract- Disclosure of Proprietary & Confidential Information)
25.

The allegations of paragraphs 1-24 are restated and re-alleged as though

fully set forth herein.

26.

Defendants, as part of the Agreement, undertook not to disclose Acacias

confidential and proprietary information except as expressly agreed by Acacia

beforehand.
27.

Defendants, as part of the Agreement, undertook to provide Acacia 30

days notice of any proposed disclosure or publication involving Acacias proprietary and
confidential information.
28.

Acacia has fully performed its obligations under the Agreement.

29.

Defendants failed to provide Acacia notice of any proposed disclosure of

Acacias confidential and proprietary information pursuant to the Agreement.

30.

Defendants disclosed Acacias proprietary and confidential business

information in violation of the Agreement by circulating the Guide to AIM members and
by presenting the Guide to those in attendance of the AIM Meeting.
31.

By failing to notify Acacia of its proposed disclosure and by disclosing

and continuing to disclose Acacias confidential and proprietary information, Defendants

have materially breached their obligations under the Agreement.
32.

Defendants material breaches of the Agreement have proximately caused

Acacia to suffer substantial damages, in an amount to be proven at trial.

Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 7 of 10

COUNT II
(Breach of the Implied Covenant of Good Faith and Fair Dealing)
33.

The allegations of paragraphs 1-32 are restated and re-alleged as though

fully set forth herein.

34.

Implied in the Agreement was a covenant of good faith and fair dealing,

pursuant to which the Defendants were obliged to refrain from any acts or conduct which
would deny Acacia the receipt and enjoyment of its legitimate expectations flowing from
the Agreement.
35.

Defendants violated this covenant by materially breaching the contract by,

among other things, publicly disclosing Acacias confidential and proprietary information
owned by Acacia and failing to maintain the confidentiality of such information.
36.

Defendants material breach has proximately Acacia to suffer substantial

damages, in an amount to be proven at trial.

COUNT III
(Breach of Contract Failure to Perform)
37.

The allegations of paragraphs 1-36 are restated and re-alleged as though

fully set forth herein.

38.

Pursuant to the SOW, incorporated into the Agreements as Appendix A,

CNSE was required to deliver six functional wafers to Acacia under Phase II of the
project. (Agreement at 1, Appendix A).
39.

Pursuant to the SOW, CNSE was required to schedule technical meetings

with Acacia personnel in order to continue progress on the project set forth in the SOW
attached to the Agreement. (Agreement at 1).

Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 8 of 10

40.

Acacia has fully performed its obligations under the Agreement.

41.

Defendants have failed to deliver the six functional wafers to Acacia

pursuant to the SOW attached to the Agreement. (Agreement at 1).

42.

Defendants have failed and/or refused to schedule or hold technical

meetings with Acacia personnel in order to continue progress on the project as required
by the Scope of Work attached to the Agreement. (Agreement at 11).
43.

Said failure and refusal constitutes a material breach of the Agreement,

which breach has proximately caused Acacia to suffer substantial damages, in an amount
to be proven at trial.
COUNT IV
(Injunctive Relief)
44.

The allegations of paragraphs 1-43 are restated and re-alleged as though

fully set forth herein.

45.

As alleged above, Defendants have publicly disclosed Plaintiffs

confidential and proprietary information in material breach of the Agreement.

46.

In addition to this unauthorized disclosure, the Defendants have failed to

comply with their obligation to return or destroy Plaintiffs confidential and proprietary
information in possession of CNSE upon termination of the Agreement.
47.

As a result of Defendants unauthorized public disclosure and continued

retention of Plaintiffs confidential and proprietary information, Plaintiff has suffered,

and absent injunctive relief will continue to suffer, damage and injuries to its business,
reputation, and good will, for which Plaintiff has no adequate remedy at law.

Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 9 of 10

48.

Defendants conduct has caused and will continue to cause irreparable

harm to Plaintiff.
RELIEF REQUESTED
WHEREFORE, Plaintiff requests that this Court:
A.

Declare that Defendants unauthorized disclosure of Plaintiffs

confidential and proprietary information, failure to provide six functional wafers pursuant
to the SOW, failure reimburse Acacia for sums advanced on work that Defendants have
not completed, and failure to comply with their obligation to return and/or destroy
confidential Acacia materials in their possession violate the Agreement;
B.

Order Defendants to remove all of Plaintiffs confidential and proprietary

information from their publicly available presentations;

C.

Preliminarily and permanently enjoin the Defendants, including all

partners, officers, agents, servants, employees, attorneys, and all those persons and
entities in active concert or participation with them, from disclosing Plaintiffs
confidential and proprietary information without Plaintiffs authorization;
D.

Direct Defendants to pay Plaintiff its actual damages for Defendants

breach of the Agreement, including prejudgment and postjudgment interest thereon;

E.

Award Plaintiff its attorneys fees and costs under applicable law; and

F.

Award Plaintiff such further relief as this Court may deem just and proper.
JURY DEMAND

Plaintiff demands a trial by jury of all issues so triable.

Case 1:16-cv-01506-LEK-CFH Document 1 Filed 12/19/16 Page 10 of 10

ACACIA COMMUNICATIONS, INC.

By its attorneys,
Dated: December 19, 2016

s/Lee Palmateer
____________
Lee Palmateer (BRN 509188)
LEE PALMATEER LAW OFFICE LLC
90 State Street
Suite 700
Albany, New York 12207
Tel: (518) 591-4636
Fax: 1-518-677-1886
Email: lee@palmateerlaw.com
Michael A. Albert
malbert@wolfgreenfield.com
WOLF, GREENFIELD & SACKS, P.C.
600 Atlantic Avenue
Boston, Massachusetts 02210
Tel: (617) 646-8000
Fax: (617) 646-8646
Email: Michael.Albert@WolfGreenfield.com
Attorneys for Plaintiff

Case 1:16-cv-01506-LEK-CFH Document 1-1 Filed 12/19/16 Page 1 of 2

CIVIL COVER SHEET

JS 44 (Rev. 07/16)

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS

DEFENDANTS

THE RESEARCH FOUNDATION FOR THE STATE UNIVERSITY OF

NEW YORK,SUNY POLYTECHNIC INSTITUTE, and COLLEGE OF
NANOSCALE SCIENCE AND ENGINEERING
Albany
County of Residence of First Listed Defendant

ACACIA COMMUNICATIONS, INC.,

(b) County of Residence of First Listed Plaintiff

(EXCEPT IN U.S. PLAINTIFF CASES)

NOTE:

(c) Attorneys (Firm Name, Address, and Telephone Number)

(IN U.S. PLAINTIFF CASES ONLY)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

Attorneys (If Known)

LEE PALMATEER LAW OFFICE LLC, 90 State Street, Suite 700

Albany, New York 12207, Tel: (518) 591-4636, Lee Palmateer

II. BASIS OF JURISDICTION (Place an X in One Box Only)

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff

(For Diversity Cases Only)
PTF
Citizen of This State
1

U.S. Government
Plaintiff

Federal Question
(U.S. Government Not a Party)

U.S. Government
Defendant

Diversity
(Indicate Citizenship of Parties in Item III)

DEF
1

and One Box for Defendant)

PTF
DEF
Incorporated or Principal Place
4
4
of Business In This State

Citizen of Another State

Incorporated and Principal Place

of Business In Another State

Citizen or Subject of a
Foreign Country

Foreign Nation

IV. NATURE OF SUIT (Place an X in One Box Only)

CONTRACT

TORTS

110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise

REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education

FORFEITURE/PENALTY

PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement

625 Drug Related Seizure

of Property 21 USC 881
690 Other

BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark

LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act

SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))

FEDERAL TAX SUITS

870 Taxes (U.S. Plaintiff
or Defendant)
871 IRSThird Party
26 USC 7609

IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions

OTHER STATUTES
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes

V. ORIGIN (Place an X in One Box Only)

1 Original
Proceeding

2 Removed from
State Court

4 Reinstated or
Reopened

6 Multidistrict
Litigation Transfer
(specify)
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Remanded from
Appellate Court

5 Transferred from
Another District

8 Multidistrict
Litigation Direct File

28 U.S.C. 1332

VI. CAUSE OF ACTION Brief description of cause:

Breach of Contract; Breach of the Implied Covenant of Good Faith and Fair Dealing; Injunctive Relief

CHECK IF THIS IS A CLASS ACTION

VII. REQUESTED IN
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
IF ANY
JUDGE
DATE

CHECK YES only if demanded in complaint:

Yes
No
JURY DEMAND:

DEMAND $

DOCKET NUMBER

SIGNATURE OF ATTORNEY OF RECORD

s/Lee Palmateer

12/19/2016
FOR OFFICE USE ONLY
RECEIPT #

0206-3879366
AMOUNT
Print

$400.00
Save As...

APPLYING IFP

JUDGE

Case No. 1:16-CV-1506

LEK

MAG. JUDGE

CFH
Reset

JS 44 Reverse (Rev. 07/16)

Case 1:16-cv-01506-LEK-CFH Document 1-1 Filed 12/19/16 Page 2 of 2

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a)

(b)

(c)

Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II.

Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III.

Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV.

Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.

V.

Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.

VI.

Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII.

Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.