`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF IOWA
`
`WESTERN DIVISION
`
`GORDON GARRISON,
`
`Plaintiff,
`
`VS.
`
`NEW FASHION PORK LLP, and
`
`BWT HOLDINGS LLLC,
`
`Defendants.
`
`Vvvvvvvvvv
`
`No.
`
`COMPLAINT
`
`Comes now the Plaintiff and for cause of action states:
`
`INTRODUCTION
`
`1. Plaintiff, Gordon Garrison,
`
`owns
`
`real estate in
`
` Emmet County,
`
`Iowa.
`
`2. Defendant, New Fashion Pork LLP, owns and operates a
`
`
`
`confined animal feeding operation adjacent to Mr. Garrison’s
`
`
`property in Emmet County,
`
`Iowa. This confined animal feeding
`
`operation is permitted to hold 4,400 head of hogs weighing
`
`55 pounds or more and up to 8800 hogs
`
`if they weigh less
`
`than 55 pounds.
`
`3.
`
`BWT Holdings LLLC is a subsidiary of New Fashion
`
`Pork LLP.
`
`BWT Holdings owns
`
`the land where the waste from
`
`the
`
`confinement operation referred to in the preceding
`
`paragraph is applied to crop fields.
`
`4. The aforementioned animal
`
`feeding operation began
`
`operation on or about January I, 20l6.
`
`1
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`Case 3:18-cv-03073-CJW—MAR Document 1 Filed 12/20/18 Page 1 of 16
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`
`
`5. The aforementioned animal
`
`feeding operation is in
`
`violation of
`
`state
`
`and
`
`federal
`
`law in
`
`the
`
`following
`
`respects:
`
`a.The Defendants have violated and continue to violate
`
`Section 7002(a)
`
`of
`
`the Resource Conservation and
`
`Recovery Act
`
`(RCRA) by contributing to the past and
`
`present
`
`handling,
`
`storage,
`
`treatment,
`
`transportation,
`
`and/or
`
`disposal
`
`of
`
`solid
`
`and
`
`hazardous waste in such a manner that may present an
`
`imminent and substantial endangerment
`
`to health and
`
`the
`
`environment.
`
`42 U.S.C.
`
`§ 6972(a). Plaintiff
`
`further alleges that
`
`the Defendants employ improper
`
`manure management practices
`
`that
`
`constitute
`
`the
`
`“open
`
`dumping”
`
`of
`
`solid waste
`
`in violation of
`
`Section 4005(a) of RCRA. 42 U.S.C. § 6945(a).
`
`b.The manure management plan submitted for the above
`
`operation allows a nitrogen application rate of 232
`
`pounds/acre.
`
`
`Iowa Code
`
`§ 459.312(10)(f)
`
`requires
`
`that a manure management plan provide for methods,
`
`structures, or practices to prevent or diminish soil
`
`loss
`
`and potential
`
`surface water pollution.
`
`The
`
`manure management plan in this case does not comply
`
`with this requirement. Therefore,
`
`the Defendants are
`
`
`
`in violation of Iowa law.
`
`2
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`Case 3:18-cv—03073-CJW-MAR Document 1 Filed 12/20/18 Page 2 of 16
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`
`
`C.The Defendants’ confinement feeding operation is in
`
`violation of the Clean Water Act, 33 U.S.C. §§ 1251
`
`et
`
`seq.,
`
`by discharging pollutants
`
`into surface
`
`waters and groundwater without a National Pollutant
`
`
`
`Discharge Elimination System (NPDES) permit.
`
`Ci.The Defendants’
`
`are in violation. of
`
`Iowa
`
`law and
`
`regulations
`
`by
`
`discharging manure
`
`through
`
`air
`
`emissions
`
`from their confinement
`
`feeding operation
`
`
`
`at times other than periods of manure disposal.
`
`e.The
`
`land on which manure
`
`from the Defendants’
`
`confinement
`
`feeding' operation is being' applied is
`
`highly erodible land and does not comply with the
`
`conservation plan required by the Natural Resource
`
`
`
`Conservation Service (NRCS).
`
`f.The construction and operation of
`
`the Defendants’
`
`confinement
`
`feeding operation is
`
`in violation of
`
`Iowa drainage law.
`
`g.The operation of Defendants’
`
`confinement
`
`feeding
`
`operation
`
`constitutes
`
`a
`
`nuisance
`
`affecting the
`
`Plaintiff’s use and enjoyment of his property.
`
`h.The operation of Defendants’
`
`confinement
`
`feeding
`
`operation
`
`has
`
`been,
`
`and
`
`is,
`
`a
`
`trespass
`
`on
`
`
`
`Plaintiff’s property.
`
`3
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`Case 3:18-cv—03073-CJW-MAR Document 1 Filed 12/20/18 Page 3 of 16
`
`
`
`
`
`
`
`
`dUR SD CT ON AND VENUE
`
`6. This Court has
`
`jurisdiction over
`
`this action by
`
`virtue of 28 U.S.C.
`
`§ l33l because it arises under federal
`
`statutes. Venue
`
`is proper
`
`in this Court pursuant
`
`to 28
`
`U.S.C.
`
`§
`
`l39l because
`
`the parties
`
`are present
`
`in the
`
`Northern District of
`
`Iowa Western Division and the events
`
`constituting the Plaintiff’s cause of action occur
`
`there.
`
`This Court has pendent jurisdiction over Plaintiff’s claims
`
`brought under Iowa state law. 28 U.S.C. § l367(a).
`
`
`CAUSES OF ACTION
`
`RESOURCE CONSERVATION AND RECOVERY ACT
`
`7. Section 7002(a)(l)(B) of RCRA,
`
`42 U.S.C.
`
`§ 6972(a)
`
`(l)(B), provides that citizens may commence a citizen suit
`
`against
`
`“any person,”
`
`“including any past
`
`or present
`
`generator, past or present
`
`transporter, or past or present
`
`owner or operator of
`
`a
`
`treatment,
`
`storage,
`
`or disposal
`
`facility who has contributed or who is contributing to the
`
`past
`
`or
`
`present
`
`handling,
`
`storage,
`
`treatment,
`
`transportation, or disposal of any solid or hazardous waste
`
`which may present an imminent and substantial endangerment
`
`to health or
`
`the environment.” A notice pursuant
`
`to 42
`
`U.S.C. 6972(b)(2)(A) was served on the Defendants. A copy of
`
`the notice is hereto attached.
`
`4
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`Case 3:18-cv—03073-CJW-MAR Document 1 Filed 12/20/18 Page 4 of 16
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`
`
`8. Section lOO2(b) of RCRA, 42 U.S.C. § 690l(b), states
`
`that “disposal of solid waste
`
`.
`
`.
`
`.
`
`in or on the land
`
`without careful planning and management can present a danger
`
`to human health and the environment;” and that “open dumping
`
`is particularly harmful
`
`to health,
`
`contaminates drinking
`
`water
`
`from underground and surface supplies,
`
`and pollutes
`
`the air and the land .
`
`.
`
`.
`
`.”
`
`9. As required by statute,
`
`the Environmental Protection
`
`Agency (EPA) has promulgated criteria under RCRA,
`
`42 U.S.C.
`
`§ 6907(a)(3), defining solid waste management practices that
`
`constitute open dumping. See, 42 U.S.C. § 6944(a);
`
`4O C.F.R.
`
`Parts 257 and 258. These regulations outline certain solid
`
`waste
`
`disposal
`
`practices which,
`
`if violated,
`
`pose
`
`a
`
`reasonable probability of adverse effects on health or the
`
`environment. 40 C.F.R. § 257.3.
`
`10. The purpose of RCRA is “to promote the protection
`
`of health and the environment.” RCRA seeks
`
`to accomplish
`
`this by “prohibiting future open dumping on the land and
`
`requiring
`
`the
`
`conversion
`
`of
`
`existing
`
`open
`
`dumps
`
`to
`
`facilities which do not pose a danger to the environment or
`
` to health .
`
`.
`
`.
`
`.” 42 U.S.C. § 6902(a).
`
`11. Section 4005(a) of RCRA prohibits “any solid waste
`
`management practice or disposal of solid waste .
`
`.
`
`. which
`
`5
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`Case 3:18-cv—03073-CJW-MAR Document 1 Filed 12/20/18 Page 5 of 16
`
`
`
`constitutes the open dumping of solid waste
`
`.
`
`.
`
`.
`
`.” 42
`
`U.S.C. § 6945(a).
`
`12. Under § 1004(3) of RCRA,
`
`42 U.S.C.
`
`§ 6903(3), “The
`
`term.
`
`‘disposal’ means
`
`the discharge, deposit,
`
`injection,
`
`dumping,
`
`spilling,
`
`leaking,
`
`or
`
`placing
`
`of
`
`any
`
`solid
`
`waste .
`
`.
`
`.
`
`into or on any land or water so that such solid
`
`waste or hazardous waste or
`
`any constituent
`
`thereof may
`
`enter
`
`the
`
`environment
`
`or
`
`be
`
`emitted into the air
`
`or
`
`
`
`discharged into any waters,
`
`including ground—waters.”
`
`13. RCRA defines “solid waste” as “any garbage, refuse,
`
`sludge
`
`from a waste
`
`treatment plant
`
`.
`
`.
`
`.
`
`and other
`
`discarded material,
`
`including solid,
`
`liquid,
`
`semisolid, or
`
`contained gaseous material resulting from .
`
`.
`
`. agricultural
`
`operations .
`
`.
`
`.
`
`.” 42 U.S.C. § 6903(27)(emphasis added).
`
`14. EPA criteria for solid waste disposal practices
`
`prohibit the contamination of any underground drinking water
`
`source beyond the solid waste boundary of a disposal site.
`
`15. An “underground drinking water source” includes (1)
`
`.E
`an aquifer supplying drinking water _or human consumption or
`
`
`
`(2) any aquifer in which the groundwater contains less than
`
`10,000 milligrams per liter of
`
`total dissolved solids.
`
`40
`
`C.F.R. § 257.3—4(c)(4).
`
`16. “Contaminate” an underground drinking water source
`
`means
`
`to cause the groundwater concentration of
`
`a
`
`listed
`
`6
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`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 6 of 16
`
`
`
`substance to exceed its corresponding maximum contaminant
`
`level specified in .Appendix I
`
`'to 40 C.F.R. Part 257, or
`
`cause an increase in the concentration of
`
`that
`
`substance
`
`where the existing concentration already exceeds the maximum
`
`contaminant level in Appendix I.
`
`l7.
`
`In the Defendants’ confinement
`
`feeding operation
`
`the manure from the hogs
`
`is collected in a pit below the
`
`confinement structure. The pit is then emptied once or twice
`
`a year and the waste is applied to crop fields as designated
`
`in the Defendants’ manure management plan.
`
`18. The application of the manure from the Defendants’
`
`confinement feeding operation on the crop fields pursuant to
`
`the manure management plan exceeds accepted agronomic rates.
`
`The excessive application of manure on the crop fields has
`
`and will cause manure nutrients,
`
`including but not
`
`limited
`
`to nitrates and phosphorus,
`
`that are not
`
`taken up by the
`
`crop to be discharged to groundwater and surface water. This
`
`renders the manure incapable of serving its intended purpose
`
`as a fertilizer.
`
`19. The October 2016 application of hog manure by the
`
`Defendants was based on
`
`the Defendants’
`
`sampling. This
`
`sample nutrient analysis showed only 2.4% solids. This
`
`is
`
`not representative of what would be expected at
`
`a similar
`
`operation. This allowed the Defendants to justify a higher
`
`7
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`
`
`application rate. The Plaintiff alleges that
`
`this resulted
`
`in over application and subsequent discharges of pollutants
`
`to his property.
`
`The Defendants
`
`are
`
`in violation of
`
`§
`
`459.3l2(l0)(b) because that section requires accurate manure
`
`analysis.
`
`20.
`
`The October
`
`2016 manure application by
`
`the
`
`Defendants
`
`took place when
`
`saturated field conditions
`
`existed and
`
`resulted in discharges
`
`to the Plaintiff’s
`
`property.
`
`2l. Manure that has been over-applied by the Defendants
`
`on fields and permitted to discharge into groundwater and
`
`surface water
`
`is
`
`a
`
`“discarded material”
`
`from an
`
`“agricultural operation,” and is therefore a “solid waste”
`
`under § 1004(27) of RCRA, 42 U.S.C. § 6903(27).
`
`22. The solid waste from the Defendants’ operation as
`
`described above has caused solid waste to be discharged to
`
`the Plaintiff’s property and has caused an imminent
`
`and
`
`substantial
`
`endangerment
`
`to
`
`public
`
`health
`
`and
`
`the
`
`environment.
`
`23. Defendants’
`
`confinement
`
`feeding operation
`
`constitutes an “open dump” under RCRA § 1004(14),
`
`42 U.S.C.
`
`§ 6903(14). Any waste management practice that constitutes
`
`the open dumping of solid waste is prohibited.
`
`42 U.S.C.
`
`§
`
`8
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`
`
`
`6945. Defendants’
`
`are
`
`therefore
`
`in violation of
`
`this
`
`prohibition against open dumping.
`
`24. Plaintiff’s interests are harmed and will continue
`
`to be
`
`harmed by the above-described violations of RCRA
`
`unless the Court grants the relief sought herein.
`
`CLEAN WATER ACT
`
`25. The Clean Water Act
`
`(CWA) was created by Congress
`
`to protect
`
`the quality of the country’s water resources. To
`
`achieve its objectives the CWA relies on the NPDES permit
`
`program that controls water pollution by regulating “point
`
`sources” that discharge pollutants.
`
`26. Concentrated animal
`
`feeding operations
`
`(CAFOs),
`
`such
`
`as
`
`the Defendants’
`
`confinement
`
`operation,
`
`are
`
`specifically designated in the CWA. as point
`
`sources.
`
`33
`
`U.S.C. § l362(l4).
`
`27. The stated objective of the CWA is to “restore and
`
`maintain the chemical, physical and biological integrity of
`
`the Nation’s waters” by,
`
`among other things, achieving the
`
`goal of “eliminat[ing]
`
`“the discharge of pollutants into
`
`II
`
`the navigable waters.” 33 U.S.C. § 125l(a).
`
`28. Under
`
`the CWA and implementing regulations,
`
`the
`
`discharge of a pollutant by any person is prohibited, except
`
`in compliance with other sections of the CWA,
`
`including 33
`
`9
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`
`
`
`U.S.C.
`
`§
`
`1342, which governs activities subject
`
`to the
`
`issuance of NPDES permits.
`
`29. A “pollutant” is defined to include,
`
`“among other
`
`things .
`
`.
`
`.
`
`industrial, municipal, and agricultural waste.”
`
`33 U.S.C. § 1362(6).
`
`30. The “discharge of a pollutant” is defined as
`
`any
`
`\\
`
`addition of any pollutant to navigable waters from any point
`
`source.” 33 U.S.C. § 1362(12).
`
`31. The Defendants, by owning and operating their CAFO,
`
`including
`
`application of manure
`
`on
`
`crop
`
`fields,
`
`have
`
`discharged and will continue to discharge pollutants
`
`to
`
`waters on the Plaintiff’s property without an NPDES permit.
`
`32. Under
`
`the CWA citizens suit provision a civil
`
`action may be maintained against
`
`the Defendants
`
`by the
`
`Plaintiff. 33 U.S.C. § l365. A notice, pursuant to 33 U.S.C.
`
`§ l365(b)(l)(A), was served on the Defendants. A copy of the
`
`notice is hereto attached.
`
`DEFENDANTS’ MANURE MANAGEMENT PLAN
`
`33. Pursuant to Iowa Code § 459.312 the Defendants were
`
`required to submit
`
`to the Iowa DNR a manure management plan
`
`specifying the manure application rate on the crop fields.
`
`34.
`
`Iowa Code § 459.312(10)(f)
`
`requires that a manure
`
`management
`
`plan
`
`provide
`
`for methods,
`
`structures,
`
`or
`
`10
`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 10 of 16
`Case 3:18-cv—03073-CJW-MAR Document 1 Filed 12/20/18 Page 10 of 16
`
`
`
`practices 'to prevent
`
`or‘ diminish. soil
`
`loss and potential
`
`surface water pollution.
`
`35. The Defendants’ manure management plan allows a
`
`nitrogen application rate of 232 pounds/acre. This does not
`
`take
`
`into account
`
`for
`
`the
`
`lack of
`
`NRCS designed and
`
`maintained grass waterways
`
`to limit
`
`erosion on highly
`
`erodible
`
`land,
`
`the use of outdated guidelines
`
`for
`
`the
`
`application of nitrogen, and that there is no restriction on
`,_
`
`the manner and method 0: field drainage.
`
`
`
` .E
`
`36. Because the De_endants’ manure management plan does
`
`not provide for consideration of the site specific issues on
`
`the Defendant’s disposal
`
`fields,
`
`the Defendants
`
`are
`
`in
`
`violation of Iowa law.
`
`37. As
`
`a proximate cause of
`
`the overapplication of
`
`manure
`
`on the Defendants’ application fields pursuant
`
`to
`
`their manure management
`
`plan,
`
`pollutants
`
`are
`
`being
`
`discharged to the Plaintiffs’ property.
`
`
`
`38. Pursuant to Iowa Code § 455B.lll a civil action may
`
`be maintained against
`
`the Defendants by the Plaintiff for
`
`violating any provision of Chapter 459 of the Iowa Code or
`
`any
`
`rule
`
`adopted pursuant
`
`to that
`
`chapter.
`
`A notice,
`
`pursuant
`
`to § 455B.lll(2), was served on the Defendants. A
`
`copy of the notice is hereto attached.
`
`ll
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`Case 3:18-cv—03073—CJW-MAR Document 1 Filed 12/20/18 Page 11 of 16
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`
`
`.L
`
`
`
`DISCHARGE OF MANURE THROUGH AIR EMISSIONS
`
`39. Emission of
`
`the air
`
`inside the Defendants’
`
`confinement structure is discharged continuously into the
`
`ambient outside air
`
`through an
`
`array of
`
`fans
`
`on
`
`the
`
`structure.
`
`40. The air being discharged to the outside is laced
`
`with chemicals, bacteria,
`
`and other pollutants excreted by
`
`the animals inside the structure.
`
`41.
`
`Iowa Code § 459.3ll(l) and 567 IAC § 65.2(3) state
`
`that manure must be controlled by
`
`retaining it
`
`in the
`
`confinement
`
`structure until
`
`it
`
`is
`
`applied to the
`
`crop
`
`fields.
`
`42.
`
`Iowa Code § 459.102(39) defines manure as “animal
`
`excreta
`
`or
`
`other
`
`commonly
`
`associated
`
`wastes
`
`of
`
`animals,
`
`II
`
`.E
`43. Based on the foregoing definition 0_ manure and the
`
`requirement
`
`that manure
`
`be
`
`retained in the
`
`confinement
`
`
`
`
`
`structure until it is applied to the crop fields,
`
`the air
`
`emissions from the structure containing pollutants excreted
`
`by the animals place the Defendants
`
`in 'violation of
`
`the
`
`statute and regulation.
`
`44. The
`
`illegal discharge of manure
`
`through air
`
`emissions from the confinement structure adversely impacts
`
`12
`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 12 of 16
`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 12 of 16
`
`
`
`the Plaintiff’s health.
`
`and.
`
`the use and. enjoyment of his
`
`property.
`
`45. Pursuant
`
`to Iowa Code § 455B.11 a civil action may
`
`be maintained against
`
`the Defendants by the Plaintiff for
`
`violating any provision of Chapter 459 of the Iowa Code or
`
`any
`
`rule
`
`adopted pursuant
`
`to that
`
`chapter.
`
`A notice,
`
`pursuant
`
`to § 455B.lll(2), was served on the Defendants. A
`
`copy of the notice is hereto attached.
`
`IMPROPER APPLICATION OF MANURE ON HIGHLY ERODIBLE LAND
`
`46. The waste from the Defendants’ confinement feeding
`
`operation is being applied to fields on highly erodible land
`
`owned by BWT Holdings.
`
`47. The Federal Farm Bill
`
`requires farm operators who
`
`farm highly erodible land to sign and submit
`
`a Form 1026
`
`
`
`-hat certifies that
`
`the operator has a conservation plan and
`
`is following it.
`
`48. The Form 1026 signed and submitted by BWT Holdings
`
`for 2015 and following years state that BWT Holdings has a
`
`conservation plan and is complying with it.
`
`49.
`
`In fact,
`
`BWT Holdings is not complying with its
`
`conservation plan. The conservation plan calls for 7.7 acres
`
`of grass waterways
`
`to avoid erosion of
`
`the soil
`
`and to
`
`filter runoff
`
`from the fields. These waterways are either
`
`non—existent or nonfunctional.
`
`13
`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 13 of 16
`Case 3:18-cv—03073-CJW-MAR Document 1 Filed 12/20/18 Page 13 of 16
`
`
`
`50. Based on the foregoing, BWT is in violation of its
`
`conservation plan for highly erodible land and submitted a
`
`false Form lO26.
`
`51. As a proximate result of the foregoing violations
`
`by BWT, pollution from the waste applied to the land from
`
`the Defendants’ confinement operation is being discharged to
`
`the Plaintiff’s property.
`
`
`
`VIOLATION OF IOWA DRAINAGE LAW
`
`52. Under
`
`Iowa drainage law,
`
`liability exists if the
`
`manner or method of drainage on to the land of another is
`
`substantially changed and actual damage results.
`
`53.
`
`The manner or method of drainage
`
`from the
`
`Defendants’ manure application fields to the Plaintiff’s
`
`property has been substantially changed by allowing the
`
`over—application
`
`of manure
`
`to
`
`drain
`
`onto Plaintiff’s
`
`property and causing damage to the Plaintiff’s property.
`
`54. The manner and method of discharge has been changed
`
`by pattern tiling, conducted by the Defendants in the Spring
`
`of 20l7. This
`
`increases the total yearly discharges. The
`
`pattern tiling removed water from an adjacent watershed and
`
`deposits that water into the Plaintiff’s watershed, which is
`
`a violation of Iowa drainage law.
`
`l4
`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 14 of 16
`Case 3:18-cv—03073-CJW-MAR Document 1 Filed 12/20/18 Page 14 of 16
`
`
`
`NUISANC L‘LJ
`
`55. The operation of
`
`the Defendants’
`
`confinement
`
`operation creates odor that interferes with the Plaintiffs’
`
`use and enjoyment of his property.
`
`56.
`
`In addition, runoff of waste and pollution from the
`
`manure
`
`on Defendants’
`
`application
`
`fields
`
`onto
`
`the
`
`Plaintiff’s property interferes with the Plaintiff’s use and
`
`
`
`enjoyment of his property.
`
`57. Based
`
`on
`
`the
`
`foregoing,
`
`the Defendant’s
`
`have
`
`created a nuisance that interferes with the Plaintiff’s use
`
`and enjoyment of his property.
`
`58. Plaintiff has obtained the necessary mediation
`
`release.
`
`TRESPASS
`
`59. The waste running off of
`
`the Defendants’ manure
`
`application fields enters the Plaintiff’s property, causing
`
`damage to Plaintiff’s property.
`
`60. The waste running off onto the Plaintiff’s property
`
`constitutes a trespass.
`
`WHEREFORE,
`
`the Plaintiff requests the following relief:
`
`A. A declaratory judgment
`
`that
`
`the Defendants’ animal
`
`feeding
`
`operation
`
`is
`
`in
`
`violation
`
`of
`
`the
`
`laws
`
`and
`
`regulations as described above;
`
`15
`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 15 of 16
`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 15 of 16
`
`
`
`B.
`
`An
`
`injunction prohibiting the Defendants
`
`from
`
`engaging in the practices described above
`
`that
`
`cause or
`
`allow pollution to impact
`
`the Plaintiff and his property,
`
`and his use and enjoyment of his property;
`
`C. An award of fair and reasonable damages caused by
`
`the nuisance as alleged herein;
`
`D. An award of attorney fees and expenses as authorized
`
`by law, and the costs of this action; and
`
`E. Such other and further relief as
`
`the Court deems
`
`just and equitable.
`
`mgggm
`
`WALLACE L. TAYLOR AT00077l4
`
`Law Offices of Wallace L. Taylor
`4403 lSt Ave. S.E., Suite 402
`
`Iowa 52402
`Cedar Rapids,
`3l9—366—2428;(Fax)3l9—366—3886
`
`e—mail: wtaylorlaw@aol.com
`
`
`ATTORNEY FOR PLAINTI FF
`
`l6
`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 16 of 16
`Case 3:18-cv-03073-CJW-MAR Document 1 Filed 12/20/18 Page 16 of 16
`
`
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