`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 1 of 17 PAGEID #: 5
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`EXHIBIT A
`EXHIBIT A
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`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 2 of 17 PAGEID #: 6
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`IN THE COURT OF COMMONPLEAS OF DELAWARE COUNTY, OHIO
`
`SABINAR.KOEHLER
`
`Powell, Ohio 43065
`Plaintiff,
`
`vs.
`
`THE ANTHEM COMPANIES,INC.
`8940 LyraDrive, Suite 300
`Columbus, Ohio 43240
`and
`c/o CT Corp. System - Registered Agent
`4400 Easton Commons Way,Suite 125
`Columbus, Ohio 43219
`
`99-(WH-020053
`
`CASE NO.
`David M. Gormley
`JUDGEee
`
`JURY DEMAND ENDORSED
`HEREON
`
`Defendant.
`
`
`COMPLAINT
`
`
`Now comesPlaintiff, Sabina R. Koehler, who hereby alleges and asserts against Defendant,
`
`The Anthem Companies,Inc., as follows:
`
`L
`
`PARTIES
`
`1.
`
`Plaintiff, Sabina R. Koehler (“Koehler”), is an individual residing at 444 Heather
`
`Lane, Powell, Ohio 43065.
`
`2.
`
`Defendant, The Anthem Companies, Inc. (“Anthem”),
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`is an Indiana for-profit
`
`corporation doing business in the State of Ohio, with its principal place ofbusinesslocated at 8940
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`Lyra Drive, Suite 300, Columbus, Ohio 43230.
`
`II.
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`JURISDICTION AND VENUE
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`3.
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`This Court has jurisdiction over this matter as the relevant agreements entered into
`
`by the parties herein and the events relevant to this action occurred in Delaware County, Ohio.
`
`CLERK OF COURTS - DELAWARE COUNTY, OH - COMMON PLEAS COURT
`22 CV H 02 0053 - GORMLEY, DAVID M
`FILED: 02/06/2022 02:42 PM
`
`
`
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`4.
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`For the reason described above, venueis proper in Delaware County, Ohio pursuant
`
`to Rule 3 of the Ohio Rules of Civil Procedure.
`
`I.
`
`FACTS COMMON TO ALL CLAIMS
`
`5.
`
`Plaintiff realleges and incorporates all
`
`the allegations contained in above
`
`paragraphsas if fully rewritten herein.
`
`6.
`
`7.
`
`8.
`
`2008.
`
`Koehleris a former employee of Anthem.
`
`Koehlerfirst started working at Anthem as a Customer Service Representative in
`
`Over the next 12 years, Koehler would distinguish herself at Anthem through her
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`hard work and dedication with the hopes of making a career at Anthem until she was ready to
`
`retire.
`
`Koehler’s employment record at Anthem was unblemished, and she was being
`9.
`groomed for advancement.
`
`10.
`
`Koehler received glowing reviews from herdirect supervisors and/or managers and
`
`was regularly promoted into managerial positions.
`
`11.
`
`In 2017, Koehler received a promotion to serve as a Customer Service Manager
`
`Level 2 managing over 400 vendorrepresentatives and agents covering three different lines of
`business.
`|
`
`12.
`
`In Juneor July 2020, Koehler received what she believed to be an internal Anthem
`
`survey inquiring about an Anthem software platform and/or application called Sailpoint.
`
`13.
`
`Sailpoint allows managers to review each representative or agent under their
`
`supervision and ensure each one has the appropriate security access to applications necessary for
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`them to do their job.
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`
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`14.
`
`Sailpoint is intended to ensure Anthem protects its customer’s protected health
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`information (“PHI”), personally identifiable information (“PII”), Non-public information (“NPI”),
`
`and data privacy in compliance with state and federal laws,rules, and regulations.
`
`15.|Managers are required to review Sailpoint quarterly and validate that each
`representative or agent has the appropriate clearance for the security access applications assigned
`
`to them.
`
`16.
`
`The survey instructed Koehler to provide an accurate assessment and evaluation of
`
`Anthem’soperations andthe use ofthe Sailpoint in orderto identify issues and improve operations.
`
`17.
`
`Koehler responded to the survey by providing a detailed and accurate assessment
`
`of the Sailpoint application and identifying several problem areas with its use.
`
`18.
`
`Specifically, Koehler pointed out that the validation process was flawed becauseit
`
`was impossible for Anthem managers like herself, managing a large number of vendor
`
`representatives and agents over multiple lines of business, to review each representative or agent
`
`under
`
`their
`
`supervision
`
`regarding
`
`security
`
`access
`
`due
`
`to
`
`the
`
`sheer
`
`number of
`
`representatives/agents,
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`lines of business, and applications that required regular review and
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`certification.
`
`19.
`
`Koehler also indicated that Anthem failed to provide any training on the Sailpoint
`
`application or the validation process.
`
`20.
`
`Asa result of issues with the SailPoint system and the lack of training, Koehler
`
`indicated that Anthem maybefailing to adequately protect consumerdata, PHI, PII, and NPI, and
`
`maybein violation of relevant state and federal laws.
`
`
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`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 5 of 17 PAGEID #: 9
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`21.
`
`Koehlerfelt obligated to honestly and accurately respondto the survey and provide
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`as much information as possible to improve the Sailpoint application and Anthem operations for
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`several reasons:
`
`a.
`
`to comply with the survey’s instructions;
`
`b.
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`to be true to her nature to act with honesty, integrity, and actively improve the
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`company she had dedicated herself to for the past 12-years; and
`
`c.
`
`to meet the expectations of Anthem’s culture change and leadershipinitiatives, in
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`which Anthem’s leadership repeatedly emphasized to its employees, via video
`
`recordings, manager meetings, training sessions, and townhall meetings, the need
`
`to actively and honestly speak up to help identify and solve problemsin order to
`
`improve Anthem.
`
`22.
`
`In August 2020, Koehler learned that the Sailpoint survey had not been an internal
`
`Anthem survey, but was part of an independent external compliance audit.
`23.|Apparently, Koehler’s honest and truthful appraisal ofSailpoint and its validation
`
`process unwittingly exposed gaps in Anthem’s training, operations, and compliance programs, and
`
`resulted in a negative audit finding against Anthem.
`24.
`Soon thereafter, Koehler
`spoke at
`
`length with an Anthem representative
`
`investigating the Sailpoint issues raised by Koehler’s survey response.
`25.|The Anthem representative agreed that Koehler did nothing wrong by answering
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`the survey truthfully and honestly, that senior leadership did not fully understand the issue, that
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`the survey was deceptive asto its purpose and pointof origin, and that he understoodherintention
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`was merely to respond honestly to improvethe validation process.
`
`
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`26.
`
`On October 13, 2020, two Anthem representatives met with Koehler to discuss the
`
`“fallout from the audit.”
`27.
`It was at this point that Koehler was told she was being terminated by Anthem
`
`without any corrective action and despite the fact that Koehler had been an exemplary employee
`
`over her 12-year career with Anthem.
`
`28.
`
` Koehler’s employeefile with Anthem was updated to indicate she was terminated
`
`for just cause and wasineligible to bere-hired.
`
`29.
`
` Anthem’s purported reason for Koehler’s termination was that she submitted
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`falsified records whenusingthe Sailpoint application regarding her review ofrepresentative and/or
`
`agent accessto sensitive data.
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`30.|Anthem’s purported reasons for Koehler’s termination are pretextual.
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`31.|Koehler wasactually terminated in retaliation for her survey response regarding her
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`concerns regarding the Sailpoint application, which resulted in a negative audit finding for
`
`Anthem.
`
`32.
`
`The above facts demonstrate that Anthem engaged in a pattern and practice of
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`unlawfulretaliation in violation of Ohio law and publicpolicy.
`
`33.
`
`There was a causal connection between Koehler’s survey response about Sailpoint
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`and Anthem’s termination of Koehler.
`
`34.
`
`As a result of being wrongfullyterminated by Anthem, Koehler has suffered
`
`damages, including severe emotional distress, anxiety, and depression.
`
`
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`IV.
`
`LEGAL CLAIMS
`
`COUNT ONE
`Wrongful Termination in Violation of Public Policy
`
`35.
`
`Plaintiff realleges and incorporates all
`
`the allegations contained in above
`
`paragraphsas if fully rewritten herein.
`
`36.|Aclear and well-established public policy exists to protect consumers’ private data,
`
`information, PHI, PII, and NPI as manifest in numerous state and federal laws, regulations, and
`
`rules, including, but not limited to, The Gramm-Leach-Bliley Act, The Dodd-Frank Wall Street
`
`Reform and ConsumerProtection Act, The Health Information Portability and Accountability Act,
`
`Federal Trade Commission Act, Children’s Online Privacy Protection Act, The Fair Credit
`Reporting Act as amended by The Fair and Accurate Credit Transactions Act, The Payment Card
`
`Industry Data Security Standard, the Telephone ConsumerProtection Act.
`
`37.
`
` Aclear and well-established public policy exists to protect consumers’ private data,
`
`information, PHI; PIJ, and NPI as manifest in the umbrella of privacy protections afforded under
`
`the Ohio Constitution and the United States Constitution.
`
`38.|Aclear and well-established public policy exists that professionals should provide
`
`truthful and accurate responses to independent auditors regarding a corporation’s policies,
`
`practices, operations, and regulations concerning the protection of consumers’ private data,
`information, PHI, PII, and NPI understate and federal laws, regulations, andrules.
`|
`
`39.|Aclear and well-established public policy exists and is manifested in Ohiostatutes
`
`and/or administrative regulations, or in the common law,against terminating and/orretaliating
`
`against an employee because she engagedin protected activity under Ohio law.
`
`40.
`
`Aclear and well-established public policy exists and is manifested in Ohio statutes
`
`and/or administrative regulations, or in the commonlaw,against terminating an employee based
`
`
`
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`upon her responsesto independentauditors regarding a corporationspolicies, practices, operations,
`
`and regulations.
`
`41.|Anthem’s retaliation against Koehler jeopardizes said public policies.
`
`42.
`
` Anthem’s termination ofKoehler was motivated by conducted related to said public
`
`policies.
`
`43.|Anthem had no overriding business justification for terminating Koehler.
`
`44.
`45.
`
`Anthem hadno overriding businessjustification for retaliating against Koehler.
`Asa direct and proximate result of Anthem’s conduct, Koehler has suffered and
`
`will continue to suffer damages,
`
`including economic damages in an amount
`
`in excess of
`
`$25,000.00 to be determinedat trial and emotional distress damages.
`
`COUNT TWO
`Promissory Estoppel
`
`46.
`
`Plaintiff realleges and incorporates all
`
`the allegations contained in above
`
`paragraphsasif fully rewritten herein.
`
`47.
`Anthem made numerousrepresentations to Koehler and its employees that Anthem
`was undergoing a culture change and wanted its employeesto openly and honestly point out issues
`
`and problemsin order to improveits operations.
`
`48.
`
`Koehler reasonably relied upon Anthem’s representations and was induced thereby
`
`to provide a detailed, accurate, and honest appraisal of the Sailpoint application and its issues in
`responseto the audit survey to Koehler’s detriment.
`|
`
`49.
`
`As a direct and proximate result of Anthem’s conduct, Koehler has suffered and
`
`will continue to suffer damages,
`
`including economic damages in an amount
`
`in excess of
`
`$25,000.00 to be determinedattrial and emotional distress damages.
`
`
`
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`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 9 of 17 PAGEID #: 13
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`V.
`
`REQUEST FOR RELIEF
`
`WHEREFORE, Plaintiff hereby demands judgment against Defendant and requests the
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`following relief and damages:
`
`(a) Issue an order requiring Defendant to expunge her personnel file of all negative
`
`documentation andthat sheis eligible for re-hire;
`
`(b) Compensatory, monetary, special, and consequential damages in an amount in excess
`
`of $25,000.00 to be determinedattrial;
`
`(c) An award of punitive damages in an amountin excess of $25,000.00 to be determined
`
`at trial;
`
`(d) Plaintiff's cost, expenses,and reasonable attorney fees incurredin thislitigation; and
`
`(e) Any other legal and/or equitable relief deemed appropriate by this Court.
`
`Respectfully submitted,
`
`/s/ Craig J. Spadafore
`Craig J. Spadafore (0081279)
`Spadafore Law, LLC
`6545 McVey Blvd
`Columbus, Ohio 43235
`Phone: 614-441-1255
`Email: craig@spadaforelaw.com
`Counselfor Plaintiff
`
`JURY DEMAND
`
`Plaintiff hereby requests a jury of eight (8) on all triable issues offact.
`
`/s/ Craig J. Spadafore
`Craig J. Spadafore (0081279)
`
`
`
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`
`IN THE COURT OF COMMONPLEAS OF DELAWARE COUNTY, OHIO
`
`CLASSIFICATION FORM
`
`CASE NO.
`
`PLEASE INDICATE CLASSIFICATION INTO WHICH THIS CASE FALLS:
`
`CIVIL
`
`DOMESTIC RELATIONS
`
`(
`
`(
`
`(
`
`(
`
`(
`
`(
`
`)
`
`Professional Tort ------------ A
`
`) Product Liability ------------
`
`B
`
`) Other Torts ------------------- C
`
`) Workers Compensation ---- D
`
`) Foreclosure ------------------
`
`) Administrative Appeal-----
`
`E
`
`F
`
`(
`
`(
`
`(
`
`(
`
`(
`
`(
`
`)
`
`)
`
`Termination of Marriage, with children -
`
`Termination of Marriage, no children ---- B
`
`) Dissolution of Marriage, with children--
`
`C
`
`) Dissolution of Marriage, no children ----- D
`
`)
`
`Change of Custody -------------------------- E
`
`) Visitation Enforcement/Modification ----
`
`F
`
`(
`)
`Support Enforcement/Modification ------
`G
`*—Complex Litigation --------- G
`
`* Complex Litigation designation
`requires judicial approval. Sup. R. 42
`
`J Other Civil ------------------- H
`
`(
`
`(
`
`(
`
`) Domestic Violence -------------------------- H
`
`)
`
`)
`
` ULLENS.A,----------------------2222222222222
`
`I
`
` AITl Others ------------------------------------ K
`
`PLEASE PRINT OR TYPE THE INFORMATION REQUESTED BELOW
`
`TRIAL ATTORNEY:
`£8104.Spadafore
`DATE:_02/06/2022
`
`Ohio Supreme Court
`Registration No.:
`
`(0081279)
`
`Address: Spadafore Law, LLC
`
`6545 McVey Blvd
`
`Columbus, Ohio 43235
`
`Telephone: 614-441-1255
`
`Fax Number:
`
`Email Address:
`
`C’aig@spadaforelaw.com
`
`CLERK OF COURTS - DELAWARE COUNTY, OH -
`22 CV H 02 0053 - GORMLEY, DAVID M
`
`COMMON PLEAS COURT
`
`FILED: 02/06/2022 02:42 PM
`
`
`
`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 11 of 17 PAGEID #: 15
`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 11 of 17 PAGEID #: 15
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`IN THE COURT OF COMMON PLEAS
`
`DELAWARE COUNTY, OHIO
`
`INSTRUCTIONS FOR SERVICE
`
`Sabina R. Koehler
`
`The Anthem Companies, Inc.
`
`PLAINTIFF(S)
`Vs.
`
`DEFENDANT(S)
`
`CASE NO.
`
`TO THE CLERK OF COURTS, YOU ARE INSTRUCTED TO MAKE:
`CERTIFIED MAIL SERVICEX
`
`ORDINARY MAIL SERVICE___
`
`PERSONALSERVICE BY THE SHERIFF OF
`
`RESIDENCE SERVICE BY THE SHERIFF OF
`
`PERSONAL SERVICE BY PROCESS SERVER
`
`RESIDENCE SERVICE BY PROCESS SERVER
`
`COUNTY
`
`COUNTY
`
`OF THE FOLLOWING DOCUMENTS: Complaint and Summons
`
`UPON:
`
`The Anthem Companies, Inc.
`
`(NAME #1)
`8940 Lyra Drive, Suite 300
`
`(ADDRESS)
`
`Columbus, Ohio 43240
`
`(CITY-STATE-ZIP CODE)
`
`The Anthem Companies, Inc.
`
`(NAME #2)
`c/o CT Corp. System
`
`(ADDRESS)
`4400 Easton Commons Way, Suite 125
`
`Columbus, Ohio 43219
`
`(CITY-STATE-ZIP CODE)
`
`(NAME #3)
`
`(ADDRESS)
`
`(NAME #4)
`
`(ADDRESS)
`
`(CITY-STATE-ZIP CODE)
`
`(CITY-STATE-ZIP CODE)
`
`Craig J. Spadafore (0081279)
`
`Attorney Name and SupremeCourt I.D. No.
`614-441-1255
`
`Phone Number
`
`Spadafore Law, LLC, 6545 McVey Blvd, Columbus, OH 43235
`
`Address,City, State, Zip Code
`
`CLERK OF COURTS - DELAWARE COUNTY, OH -
`22 CV H 02 0053 - GORMLEY, DAVID M
`
`COMMON PLEAS COURT
`
`FILED: 02/06/2022 02:42 PM
`
`
`
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`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 12 of 17 PAGEID #: 16
`
`IN THE COURT OF COMMON PLEAS DELAWARE COUNTY, OHIO
`
`Plaintiff(s):
`SABINA R KOEHLER
`444 HEATHER LANE
`POWELL,OH 43065
`
`SUMMONS
`
`Case Number: 22 CV H 02 0053
`
`VS
`
`Defendant(s):
`ANTHEM COMPANIES INC
`C/O CT CORP SYSTEM - REG AGENT
`4400 EASTON COMMONS WAYSTE
`125
`COLUMBUS, OH 43219
`
`TOTHEABOVENAMEDDEFENDANT:
`
`CO i
`
`You are hereby summonedthat a complaint (a copy of whichis hereto attached and made
`a part hereof) has beenfiled against you in this court by the plaintiff(s) named herein.
`
`You are required to serve upon the plaintiff(s) attorney, or upon the plaintiff(s) if
`he/she/they have/has no attorney of record, a copy of your answerto the complaint within twenty-
`eight (28) days after service of this summons upon you, exclusive of the day of service. Said
`answer mustbefiled with this court within three (3) days after service on plaintiff(s) attorney.
`
`The nameand address ofthe plaintiff(s) attorney is as follows:
`
`CRAIG J SPADAFORE
`513 E RICH STREET
`COLUMBUS, OH 43215
`
`If you fail to appear and defend, judgment by default will be taken against you for
`the relief demanded in the complaint.
`
`Date: February 7, 2022
`
`
`
`rearFravel, : Natalie
`
`ertified Article Number
`Delaware County Clerk of Courts
`Bate TON e635 a
`sincnat
`
`Saat
`
`,
`
`2
`
`Deputy Clerk
`
`
`
`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 13 of 17 PAGEID #: 17
`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 13 of 17 PAGEID #: 17
`
`IN THE COURT OF COMMONPLEAS DELAWARE COUNTY, OHIO
`
`SUMMONS
`
`Case Number: 22 CV H 02 0053
`
`Plaintiff(s):
`SABINA R KOEHLER
`444 HEATHER LANE
`POWELL, OH 43065
`
`VS
`
`Defendant(s):
`ANTHEM COMPANIESINC
`8940 LYRA DRIVE STE 300
`COLUMBUS, OH 43240
`
`TO THE ABOVE NAMED DEFENDANT:
`
`cor*
`
`You are hereby summonedthat a complaint (a copy of whichis hereto attached and made
`a part hereof) has beenfiled against you in this court by the plaintiff(s) named herein.
`
`You are required to serve upon the plaintiff(s) attorney, or upon the plaintiff(s) if
`he/she/they have/hasno attorney of record, a copy of your answerto the complaint within twenty-
`eight (28) days after service of this summons upon you, exclusive of the day of service. Said
`answer mustbefiled with this court within three (3) days after service on plaintiff(s) attorney.
`
`The name and addressof the plaintiff(s) attorney is as follows:
`
`CRAIG J SPADAFORE
`513 E RICH STREET
`COLUMBUS, OH 43215
`
`If you fail to appear and defend, judgment by default will be taken against you for
`the relief demandedin the complaint.
`
`Date: February 7, 2022
`NatalieFravel
`
`PP
`Po
`Delaware County Clerk of Courts
`117 North Union Street
`Certified Article Number
`|
`Fuhe Feb 9904 2487 8498 97 |
`Delaware, OH 43015
`SENDER’S RECORD
`Oo
`
`Deputy Clerk
`
`
`
`
`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 14 of 17 PAGEID #: 18
`ms Plagent ~
`
`CAddresse
`
`
`
`|D. 1s delivery address different from item 1? [7] Yes
`If YES, enter delivery address below:
`
`
`RIN
`
`9590 Webb FOX Bla? ahaa 83
`
`[CINo
`
`_ Article Addressedto:
`
`ANTHEM COMPANIES INC
`C/O CT.CORP SYSTEM - REG AGENT
`4400 EASTON COMMONS WAY STE 125
`COLUMBUS, OH 43219
`
`22 CV H 02 0053
`
`. Certified Mail (Form 3800) Article Number
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`Age Type:ol fama g47 [
`ofa3 heeReference Information
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`CRTSepa 2187 8498 80
`DELAWARE ‘counry COMMON PLEA
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`Pid
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`
`Case: 2:22-cv-01418-MHW-KAJ Doc #: 1-1 Filed: 03/08/22 Page: 15 of 17 PAGEID #: 19
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`:22-CV-01418-0SPERRACKINGIDC #: 1-1 Filed:|0 /P2 Page:|Bretidsymd?AGE
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