SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION

AUGUSTO JIMENEZ, JR. individually and as

personal representative of the Estates of Maria
Auxiliadorai Castellon-Martinez and Augusto
Cesar Jimenez, Sr.,
ESKINDER AYELE,
ARMINA VIERA CARBAJAL, Case No. _________________
RANDY CARBAJAL,
ROSALIO CORTEZ CHOL,
ORLANDO RAMOS CRUZ, JURY TRIAL DEMANDED
MEMAR DEMEKE,
RAMON GOMEZ DIAZ,
ROMELIA GOMEZ ESCOBAR, individually
and on behalf of her minor children,
WENDY ESTRADA,
BOLIVAR FUENTES FUENTES,
BITSEAT GETANEH,
MIGUEL ANGEL MARTINEZ GONZALES,
ESTER JUAREZ GONZALEZ
CARLOS SORTO HERNANDEZ,
ERICK JIMENEZ,
DRAYDI SULEYKA MARTINEZ,
MARIA ESCOBAR MENDEZ, individually
and on behalf of her minor children,
EDWIN MUNOZ,
GERMAN MELENDEZ MELENDEZ,
MARIA PATRICIA ESCOBAR MENDEZ,
GABRIEL MENDOZA MENDOZA,
VIRGILIO ROMERO MENDEZ,
CLAUDIA LUCIA LOAYES ROMERO,
individually and behalf of her minor child,
MAXIMINA RIOS,
MARIO FRANCISCO GAMEZ TAPAZ,
APOLINARIO VELASQUEZ UMANA,
AROLDO VASQUEZ,
XUANLIN ZHENG, individually on behalf of
her minor child,

Plaintiffs,
v.

WASHINGTON GAS LIGHT COMPANY

101 Constitution Ave. NW
Washington, DC 20001;

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 WGL HOLDINGS, INC.
101 Constitution Ave. NW
Washington, DC 20001;

KAY MANAGEMENT COMPANY, INC.

8720 Georgia Ave., Suite 410,
Silver Spring, Maryland 20910,

and

JOHN DOES,
Manufacturers of residential gas delivery
equipment to Flower Branch Apartments,
Address Unknown at this Time,

Defendants.

COMPLAINT

Introduction

1. Close to midnight on Wednesday, August 10, 2016, a massive explosion ripped

through the 362-unit Flower Branch Apartments complex, creating a gas-fed inferno that nearly

levelled two four-story buildings.

2. In the course of the nightmare, Plaintiffs suffered serious physical and mental

traumas as they used any means necessary to get themselves and their families to safety.

3. Seven residents of the Flower Branch Apartments lost their lives to the fire.

Plaintiff Augusto Jimenez, Jr. lost both of his parents that night as Maria Auxiliadorai Castellon-

Martinez and Augusto Cesar Jimenez, Sr. were unable to escape the burning building.

4. Compounding the tragedy of this horrific event is the fact that it was entirely

preventable. Less than three weeks before the explosion and fire, residents had reported the smell

of natural gas, but the Defendants – Washington Gas Light Company, which supplied natural gas

to the complex, and Kay Management Company, which managed the complex – failed to take

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any action to address the complaints. They did not repair the gas leak, did not make an

appropriate inspection that would have identified a leak, and did not warn or evacuate residents.

Defendants also failed to perform routine inspections that would have uncovered the potential for

catastrophe and saved the lives and property of the residents.

5. The effects of these failures reach far beyond the residents of Flower Branch

Apartments. Washington Gas, which is headquartered in the District, makes corporate-wide

safety and maintenance decisions here, operates hundreds of miles of natural gas pipeline here,

and is the sole distributor of natural gas to D.C. residents and businesses. Kay Management

markets and rents its apartments extensively to D.C. residents. The District of Columbia

therefore has compelling interests – specifically, its interests in protecting the life, safety, and

property of its 675,000 citizens – that justify both the exercise of jurisdiction over the Defendants

in the District, and the application of the District’s law to this legal dispute.

6. Plaintiffs bring this action in this Court seeking just compensation from those

responsible for the incalculable suffering and losses that they have endured.

The Parties

7. Plaintiff Augusto Jimenez, Jr. is the son and personal representative of the estates

of his parents, Maria Auxiliadorai Castellon-Martinez and Augusto Cesar Jimenez, Sr. both of

whom were killed in the August 10, 2016 explosion. Mr. Jimenez is a resident of Silver Spring,

MD and was duly appointed as personal representative of his parents’ estates by the Montgomery

County Orphan’s Court.

8. All other named plaintiffs suffered physical and emotional injuries as a result of

the explosion on August 10, 2016.

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 9. The Plaintiffs named in paragraphs 7 and 8 are herein after collectively referenced

as “Plaintiffs.”

10. Defendant Washington Gas Light Company is incorporated in, and has its

principal place of business in, Washington, D.C.

11. Defendant WGL Holdings, Inc. (“WGL”), is incorporated in, and has its principal

place of business in, Washington, D.C. It is a publicly traded company (NYSE: WGL) formed in

2000, and operates and owns Washington Gas.

12. WGL Holdings, Inc. and Washington Gas are collectively referred to herein as

“Washington Gas.”

13. Defendant Kay Management Co., Inc. (“Kay Management”), is incorporated in

Maryland, where it also has its principal place of business.

14. John Does are the manufacturers of the various parts that comprise the residential

gas service that serviced Building 8701 in the Flower Branch Apartments.

Jurisdiction and Venue

15. The Court has subject matter jurisdiction under D.C. Code § 11-921(a).

16. The Court has personal jurisdiction over Washington Gas and WGL because

Washington Gas is domiciled in, organized under the laws of, and maintains its principal place of

business in Washington, D.C. In addition, Washington Gas keeps its records and performs

significant corporate functions in the District — including the planning and implementation of

safety, inspection, and maintenance programs — and many of the acts and omission complained

of herein occurred within the geographic boundaries of the District of Columbia. D.C. Code

Ann. § 13-422.

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 17. The Court has personal jurisdiction over Kay Management because it transacts

business in the District of Columbia by, among other means that will be revealed through

discovery: (a) systematically and continuously advertising their properties to District residents;

(b) renting their properties to former District residents; (c) by conducting regular business with

Washington Gas and (d) by requiring every resident at the Flower Branch Apartments to enter

into a contract with Washington Gas in order to have cooking gas and hot water. Because of this

conduct, it is reasonable for Kay Management to anticipate that it would find itself in court in the

District. D.C. Code § 13-423(a)(1) and (b).

18. Venue is proper and convenient in this forum.

19. Venue is proper here in because a substantial part of the events or omissions

giving rise to Plaintiffs’ claims occurred in the District, and a substantial part of the wrongful

conduct of Washington Gas emanated from the District.

20. Moreover, both Defendants regularly and systematically conduct business in

Washington, D.C.

21. A central liability issue in this case arises from Washington Gas’s decisions and

failures to act, many of which took place at Washington Gas headquarters and its operations

located in the District.

22. The District and its citizens have an interest in regulating and holding accountable

businesses located in the District that engage in wrongful conduct alleged here.

23. The District is convenient for all parties to this litigation, and both Washington

Gas and Kay Management have bona fide connections to this forum.

24. Additionally, all physical evidence related to the cause of the explosion is no

longer located at the Flower Branch Apartments, but is instead in the possession of Washington

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Gas and various federal agencies, including the Bureau of Alcohol, Tobacco, and Firearms, and

the National Transportation Safety Board, both of which have assumed jurisdiction over and

have performed investigations into the cause of the explosion.

Factual Allegations

25. Late in the evening on August 10, 2016, a resident of Building 8701 at the Flower

Branch Apartments was taking his trash out. As he passed by the gas meter room on the first

floor of his building, he heard a strange hissing noise and could smell natural gas. Before he

could return to his apartment to call for help, an explosion described as a “sonic boom” rocked

the surrounding area.

26. The fire, caused by the explosion and fed by leaking natural gas, spread with such

force and speed that the residents, most of whom had been asleep, had just seconds to escape.

They were forced to use any possible means of getting out as the stairs and floors and walls

collapsed around them. With the hallways full of smoke and flames, many had to jump off their

balconies to the ground below.

27. Other residents, including those with children too small to jump, shouted

desperately from their upper floor windows, pleading for help. Some were forced to drop their

babies from the windows to terrified neighbors below.

28. Despite the residents’ efforts to save their families and one another, seven

residents died in the fire, including Plaintiff Augusto Jimenez, Jr.’s parents, Maria Auxiliadorai

Castellon-Martinez and Augusto Cesar Jimenez, Sr.

29. Scores more, including the other Plaintiffs, suffered physical injuries including

serious burns, lacerations, broken and dislocated bones, concussions, and smoke inhalation.

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 30. Many of the Plaintiffs, including the children, suffer on-going mental injuries

from the traumatic events of August 10 — waking to the sound of the explosion, escaping from

the burning buildings by any means that they could, and fearing for the safety of their parents

and children.

31. Those with physical and mental injuries also endured other losses. Due to fire,

smoke, and water damage, residents lost their homes, family photos, life savings, identification

documents, furniture, and the contents of every room, closet, cabinet and shelf. Some were left

with nothing but what they grabbed when they fled their apartments.

32. Those residents who were eventually able to return home had no gas service, and

could not cook or run hot water. Many were displaced for several days, and were unable to get to

work. The heavy smell of smoke and gas remains, and the remnants of the collapsed and burned

out buildings still stand just feet from their doors as a daily reminder of that horrific evening and

the suffering that followed.

33. Before the tragic explosion on August 10, residents of the Flower Branch

Apartments had informed Kay Management on many occasions that they could smell natural gas.

34. On July 25, 2016, a resident of Building 8701 called 911 reporting a gas smell.

35. Despite this report and others, neither Kay Management nor Washington Gas

undertook appropriate inspections or repairs.

36. Washington Gas is the sole distributor of natural gas to Washington D.C.

residents through its residential gas service. Washington Gas serves over 1.1 million customers

in the Washington, D.C. region.

37. Washington Gas operates roughly 200 miles of Department of Transportation-

regulated transmission pipelines and thousands of miles of distribution pipelines.

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 38. The underground pipe, service lines, and equipment that distribute natural gas to

Building 8701 of the Flower Branch Apartments were installed by Washington Gas and should

have been monitored, inspected, serviced, and maintained by Washington Gas.

39. The Flower Branch Apartments, including Building 8701, are owned, managed

and maintained by the Kay Management.

40. Kay Management should have monitored, inspected, serviced, and maintained the

meter room and equipment in the meter room of Building 8701.

41. John Does manufactured and sold to Washington Gas the underground pipes,

service lines, and equipment that distribute natural gas to Building 8701 of the Flower Branch

Apartments.

42. Despite the 911 call from the resident of Building 8701 and numerous complaints

of natural gas odors by other residents, the Defendants did not properly inspect or remedy the

problem, resulting in the tragedy of August 10, 2016.

COUNT ONE
(Negligence - Washington Gas)
(As to all Plaintiffs)

43. Washington Gas owed a duty to Plaintiffs to exercise due care in the installation,

monitoring, inspection, servicing, and maintenance of the underground pipe, service lines, and

other equipment that distributes natural gas to Building 8701 of the Flower Branch Apartments.

44. Washington Gas had a duty to exercise the degree of care commensurate with the

danger inherent in providing residential natural gas service.

45. Washington Gas had notice of the natural gas leak prior to the explosion and had

a duty to take immediate and proper corrective action to inspect, service, and repair the gas leak.

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 46. Washington Gas breached its duties to Plaintiffs by failing to use due care when

installing, monitoring, inspecting, servicing, and maintaining the underground pipe, service lines,

and other equipment that distributes natural gas to Building 8701 of the Flower Branch

Apartments. Further, Washington Gas breached their duty to Plaintiffs by failing to take

corrective action to properly inspect, monitor, service, and repair the gas leak.

47. Washington Gas’s failure to exercise the degree of caution commensurate with

the danger in providing gas services was the proximate cause of Plaintiffs’ injuries.

48. The damages sustained by Plaintiffs were a direct or a reasonably probable

consequence of the gas leak at Building 8701 of the Flower Branch Apartments.

49. Plaintiffs demand judgement against Defendant Washington Gas for all

compensatory and punitive damages available at law or in equity.

COUNT TWO
(Wrongful Death Act - Washington Gas)
(As to Erick Jimenez and Augusto Jimenez, Jr.)

50. Washington Gas owed a duty to safely install, monitor, inspect, service, repair and

maintain the underground pipe, service lines, and other equipment that distributes natural gas to

Building 8701 of the Flower Branch Apartments.

51. Washington Gas had notice of the natural gas leak prior to the explosion and had

a duty to take immediate and proper corrective action to inspect, service, monitor and repair the

gas leak.

52. Washington Gas breached its duty by not safely installing, monitoring, inspecting,

servicing, and maintaining the underground pipe, service lines, and other equipment which

distributes natural gas to Building 8701 of the Flower Branch Apartments. Further, Washington

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Gas breached its duty to Plaintiffs by not taking corrective action to properly inspect, service,

monitor and repair the gas leak.

53. The gas leak at Building 8701 of the Flower Branch Apartments led to the

explosion that caused the wrongful deaths of Maria Auxiliadorai Castellon-Martinez and

Augusto Cesar Jimenez, Sr.

54. Washington Gas’s breach of its duties was the proximate cause of the wrongful

deaths of Maria Auxiliadorai Castellon-Martinez and Augusto Cesar Jimenez, Sr. and therefore

the proximate cause of the injuries suffered by Augusto Jimenez, Jr. and Erick Jimenez.

55. Plaintiffs Augusto Jimenez, Jr., and Erick Jimenez demand judgement against

Defendant Washington Gas for all compensatory and punitive damages available at law or in

equity.

COUNT THREE
(Survival Action – Washington Gas)
(As to Augusto Jimenez, Jr., as personal representative of the estates of Maria Auxiliadorai
Castellon-Martinez and Augusto Cesar Jimenez, Sr.)

56. Plaintiff Augusto Jimenez, Jr., as the personal representative of the estates of his

parents Maria Auxiliadorai Castellon-Martinez and Augusto Cesar Jimenez, Sr., brings claims

that could have been asserted by his parents had they survived. Md. Code Ann., Cts. & Jud. Proc.

§ 6-401.

57. These claims include all Counts against Washington Gas and the paragraphs

related to those Counts are incorporated as though fully set forth herein.

58. Plaintiff Augusto Jimenez, Jr., as the personal representative of the estates of his

parents Maria Auxiliadorai Castellon-Martinez and Augusto Cesar Jimenez, Sr., demands

judgement against Defendant Washington Gas for all compensatory and punitive damages.

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 COUNT FOUR
(Product Liability – Washington Gas)
(As to all Plaintiffs)

59. Washington Gas delivered gas to the Flower Branch Apartments through their

system of transmission, distribution, and service lines. Washington Gas is also responsible for

the gas meters and related equipment at the Flower Branch Apartments. All of the products

within this system used to deliver natural gas to the Flower Branch Apartments are products

owned and controlled by Washington Gas.

60. A defect in one or more of the products within the natural gas delivery system

was the proximate cause of the explosion.

61. Washington Gas had actual knowledge of the product defects but consciously and

deliberately disregarded the foreseeable harm that might result from the defects.

62. The actual knowledge of Washington Gas includes, but is not limited to: (a) its

belief that it was probable that there was a problem, accompanied by a purposeful failure to

make a reasonable inquiry; and (b) its willful refusal to know of the defects.

63. The defects within the gas delivery system were the proximate cause of Plaintiffs’

injuries.

64. Plaintiffs demand judgement against Defendant Washington Gas for

compensatory and punitive damages available at law or in equity.

COUNT FIVE
(Negligent Failure to Inspect and Maintain - Kay Management)
(As to all Plaintiffs)

65. Kay Management owed a duty to Plaintiffs to maintain the Flower Branch

Apartments, including, the gas meter room of Building 8701, in a reasonably safe condition

failed to do so.

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 66. Kay Management knew or should have known that the failure to maintain the

Flower Branch Apartments, including the gas meter room of Building 8701, would create an

unreasonable risk of harm to Plaintiffs.

67. The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition created by Kay Management’s failure to inspect, maintain,

monitor and make necessary repairs.

68. The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition of which Kay Management had notice. By failing to properly

inspect, maintain, repair, or notify Washington Gas of the known unsafe condition, Kay

Management breached its duty to Plaintiffs.

69. Kay Management’s actions or omissions in the face of repeated complaints

regarding the smell of gas in and around the Flower Branch Apartments reflect a reckless

indifference for Plaintiffs’ safety.

70. The damages sustained by Plaintiffs were a direct or a reasonably probable

consequence of the Kay Management’s breach of its duty to Plaintiffs.

71. Plaintiffs demand judgement against Defendant Kay Management for all

compensatory and punitive damages available at law or in equity.

COUNT SIX
(Negligent Failure to Act - Kay Management)
(As to all Plaintiffs)

72. Kay Management knew or should have known that its failure to take corrective

action after repeatedly being made aware of natural gas odors would create an unreasonable risk

of harm to Plaintiffs.

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 73. The natural gas leak in the meter room which caused the explosion was the result

of an unreasonably unsafe condition created by Kay Management’s failure to take the

appropriate corrective action after being made aware of natural gas odors.

74. The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition of which Kay Management had notice. By failing to properly

inspect, maintain, repair, or notify Washington Gas of the known unsafe condition, Kay

Management breached its duty to Plaintiffs.

75. Kay Management’s actions or omissions in the face of repeated complaints of the

smell of gas in and around the Flower Branch Apartments reflect a reckless indifference for

Plaintiffs’ safety.

76. The damages sustained by Plaintiffs were a direct or a reasonably probable

consequence of Kay Management’s breach of its duty to Plaintiffs.

77. Plaintiffs demand judgement against Defendant Kay Management for all

compensatory and punitive damages available at law or in equity.

COUNT SEVEN
(Wrongful Death - Kay Management)
(As to Augusto Jimenez, Jr. and Erick Jimenez)

78. Kay Management had a duty to maintain the Flower Branch Apartments,

including, the gas meter room of Building 8701, in a reasonably safe condition but failed to do

so.

79. Kay Management knew or should have known that the failure to maintain the

Flower Branch Apartments in a reasonably safe condition, including, the meter room of Building

8701, would create an unreasonable risk of harm and death.

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 80. The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition created by Kay Management’s failure to inspect, maintain,

monitor and make necessary repairs.

81. Kay Management knew or should have known that the failure to take corrective

action after repeatedly being made aware of natural gas odors would constitute an unreasonable

risk of harm or death.

82. The natural gas leak in the meter room that caused the explosion was the result of

an unreasonably unsafe condition of which Kay Management had notice. By failing to properly

inspect, maintain, repair, or notify Washington Gas of the known unsafe condition, Kay

Management breached its duty to Plaintiffs.

83. The gas leak at Building 8701 of the Flower Branch Apartments led to the

explosion that caused the deaths of Maria Auxiliadorai Castellon-Martinez and Augusto Cesar

Jimenez, Sr.

84. Kay Management’s actions or omissions in the face of repeated complaints of the

smell of gas in and around the Flower Branch Apartments reflect a reckless indifference for

Plaintiffs’ safety.

85. Kay Management’s breach of their duty was the proximate cause of the wrongful

deaths of Maria Auxiliadorai Castellon-Martinez and Augusto Cesar Jimenez, Sr. and therefore

the proximate cause of the injuries suffered by Augusto Jimenez, Jr. and Erick Jimenez.

86. Plaintiffs Augusto Jimenez, Jr. and Erick Jimenez demand judgement against

Defendant Kay Management for all compensatory and punitive damages available at law or in

equity.

COUNT EIGHT
(Survival Action – Kay Management)

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(As to Augusto Jimenez, Jr., as personal representative of the estates of Maria Auxiliadorai
Castellon-Martinez and Augusto Cesar Jimenez, Sr.)

87. Plaintiff Augusto Jimenez, Jr., as the personal representative of the estates of his

parents Maria Auxiliadorai Castellon-Martinez and Augusto Cesar Jimenez, Sr., brings claims

that could have been asserted by his parents had they survived. Md. Code Ann., Cts. & Jud. Proc.

§ 6-401.

88. These claims include all Counts against Kay Management, and the paragraphs

related to those Counts are incorporated as though fully set forth herein.

89. Plaintiff Augusto Jimenez, Jr., as the personal representative of the estates of his

parents Maria Auxiliadorai Castellon-Martinez and Augusto Cesar Jimenez, Sr., demands

judgement against Defendant Kay Management for all compensatory and punitive damages

available at law or in equity.

COUNT NINE
(Intentional Infliction of Emotional Distress – Washington Gas and Kay Management)
(As to all Plaintiffs)

90. Defendants’ conduct as described in this Complaint was (a) intentional or

reckless; (b) extreme and outrageous; (c) caused emotional distress to Plaintiffs; and (d) the

emotional distress was severe.

91. Plaintiffs were within the zone of physical danger caused by Defendants’

negligence and (a) feared for their own physical safety or (b)witnessed injury to a family

member.

92. The damages sustained by Plaintiffs were a direct or a reasonably probable

consequence of the Defendants’ intentional or reckless conduct.

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 93. Plaintiffs demand judgement against Defendants for all compensatory and

punitive damages available at law or in equity.

COUNT TEN
(Product Liability – John Does)
(As to all Plaintiffs)

94. John Does are manufacturers of the various parts that comprise the Washington

Gas system of transmission, distribution, and service lines for residential gas service to the

Flower Branch Apartments.

95. A defect in one or more of the products within the natural gas delivery system

was the proximate cause of the explosion.

96. John Does possessed actual knowledge of the product defects and consciously and

deliberately disregarded the foreseeable harm that might result from the defects.

97. The actual knowledge of John Does includes, but is not limited to, their willful

refusal to know of the defects, their belief that it was probable that there was a defect

accompanied by a failure to make a reasonable inquiry with a conscious purpose to avoid

learning the truth.

98. Plaintiffs demand judgment against the John Doe Defendants for compensatory

and punitive damages, available at law or in equity.

Relief Sought

99. Plaintiffs seek the following relief:

a. Judgment in favor of Plaintiffs for all economic and non-economic

damages, including, physical pain and mental anguish suffered in the past and future, the

disfigurement and humiliation or embarrassment associated with such disfigurement, the medical

and other expenses incurred in the past and future, the lost earnings in the past and reduction in

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earning capacity in the future, pre-impact fright, loss of enjoyment of life, being rendered homeless

and/or displaced, injuries to personal property, loss of use of personal property, loss of the benefit

of leasehold interests, lost wages, additional expenses, nuisance, interference with enjoyment of

property, annoyance and inconvenience and punitive damages.

b. Attorneys’ fees and costs,

c. Pre-judgment and post-judgment interest; and

d. All other relief as the Court deems just and proper.

100. For the wrongful deaths of Maria Auxiliadorai Castellon-Martinez and Augusto

Cesar Jimenez, Sr., Plaintiffs Augusto Jimenez, Jr., and Erick Jimenez seek the following relief:

a. All economic and non-economic damages, including, mental anguish,

emotional pain and suffering, loss of society, companionship, comfort, protection, care, attention,

advice, counsel, and guidance and financial benefits, future pecuniary benefits and punitive

damages;

b. Attorneys’ fees and costs;

c. Pre-judgment and post-judgment interest; and

d. All other relief as the Court deems just and proper.

101. For the survival claim, Plaintiff Augusto Jimenez, Jr., as personal representative

of the estates of Maria Auxiliadorai Castellon-Martinez and Augusto Cesar Jimenez, Sr., seeks

the following relief:

a. Conscious pain and suffering, pre-impact fear or fright, future lost earnings,

injury to and loss of property, burial and funeral expenses and punitive damages, available at law

or in equity.

b. Attorneys’ fees and costs,

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 c. Pre-judgment and post-judgment interest; and

d. All other relief as the Court deems just and proper.

Jury Demand

Plaintiffs demand a trial by jury on all counts.

November 2, 2016 Respectfully submitted,

________________________
Brian A. Glasser (DC 1024003)
Cary Joshi (DC 1028594)
Bailey Glasser LLP
1054 31st Street NW, Suite 230
Washington, DC 20007
T: (202) 463-2101
F: (202) 463-2103
bglasser@baileyglasser.com
cjoshi@baileyglasser.com

John W. Barrett (pro hac to be filed)

Bailey Glasser LLP
209 Capitol Street
Charleston, WV 25301
T: (304) 345-6555
F: (304) 342-1110
jbarrett@baileyglasser.com

Nicholas Katz (pro hac to be filed)

CASA
8151 15th Ave.
Hyattsville, MD 20793
T: (240) 491-5743
nkatz@wearecasa.org

Deepak Gupta (DC 495451)

Matthew W.H. Wessler (DC 985241)
Gupta Wessler PLLC
1735 20th Street NW
Washington, DC 20009
T: (202) 888-1741
deepak@guptawessler.com
matt@guptawessler.com

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Counsel for Plaintiffs and the Putative Class

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