A Complaint Template for Legal Challenges to the Validity of the Statutory ‘Debt Ceiling’
Free to All Who Might Wish to Join Our Pending Class Actions in Court
The Statutory ‘Debt Ceiling’ appearing at 31 USC 3101(b), rooted in the Second Liberty Bond Act of 1917 aimed at expanding Treasury financing options during the First World War, is not valid in any application that would occasion default on U.S. sovereign debt, other contractual obligations, or Social Security or Veterans’ pension obligations.
There are at least seven mutually reinforcing legal grounds for so saying. These include preemption of such application of the Ceiling by the comprehensive and painstakingly detailed Congressional Budget and Impoundment Control Act of 1974, 31 USC §§ 1301 et seq. pursuant to both the Later-in-Time Rule and the Lex Specialis Canon; the Separation of Powers, the “Take Care” Clause, the “Presentment” Clause and the 14th Amendment “Debt Clause” found in our Constitution; and the “Absurd Result” Canon preempting applications of law that could not have been legislatively intended.
This Complaint Template is accordingly offered for use by any Social Security or Veterans’ Pension beneficiary, any Treasury Debt holder, and any other Contractual Creditor of the United States whose claims might be imperiled by ‘Debt Ceiling’ gamesmanship in the U.S. Congress. With any luck, a flood of lawsuits in federal courts might force a restoration of statesmanship and responsibility to both Congress and the White House.
Here is the template: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4458389. I’ll also copy it into the text just below.
If any of my readers are interested in joining one of the four plaintiff classes here contemplated - bondholder, other contract claimant, or Social Security and/or Veterans’ Benefit pensioner - please let me know. Two colleagues and I plan to handle these cases pro bono publico - that is, free of charge.
Herewith the template:
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
--------------------------------------------------x
:
_____ and :
_____, :
:
Plaintiffs, :
-against- :
:
JANET YELLEN, Secretary of the :
Treasury, in her official capacity, :
:
Defendant. :
:
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Civ. No. 23-cv-
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
Plaintiffs _____, by their attorneys, _____, for their complaint against Secretary of the Treasury Janet Yellen (hereinafter “Secretary Yellen” or “the Secretary”), allege as follows:
Introduction
1. This is an action to declare unenforceable the putative limit on the amount of U.S. government debt outstanding at any one time found in Title 31, U.S. Code, Section 3101(b) (the “Statutory Debt Limit”).
2. Defendant Yellen has stated that the Statutory Debt Limit will cause the United States to default on the public debt in early June, 2023. This it will do, she avers, by prohibiting the U.S. Department of the Treasury from borrowing sufficient funds to meet all of our government’s obligations, ranging from U.S. Treasury debt obligations through Social Security and Veterans’ benefit obligations to a plethora of separate contract obligations with scores of millions of contractual counterparties.
3. Multiple statutes enacted by Congress and signed into law by the President, buttressed both by the structure of our government as constituted by our Constitution and by specific Constitutional provisions, take priority over the Statutory Debt Limit invoked by Defendant Yellen. They vest the Secretary with the authority, indeed the obligation, to borrow any funds necessary to avoid default. One of these statutes trumps the Statutory Debt Limit as the specific trumps the general per the lex specialis canon of statutory interpretation. The other in effect “preempts the field” that would be occupied by the Statutory Debt Limit much as federal law sometimes preempts state law and state law sometimes preempts municipal law.
4. First, the Statutory Debt Limit, 31 USC § 3101(b), is an isolated general statutory provision that is a relic of the Second Liberty Bond Act of 1917, quite unenforceable insofar as it is contradicted by the specific pledge made later-in-time by Title 31, U.S. Code, Section 3123, promulgated in 1982. Section 3123(a) provides: “The faith of the United States Government is pledged to pay, in legal tender, principal and interest on the obligations of the Government issued under this chapter.” This provision is further buttressed by the 14th Amendment to the U.S. Constitution ratified in 1868, more on which infra. Plaintiffs accordingly seek a declaration that the specific and later-in-time pledge to pay the interest and principal on the public debt made in Section 3123, buttressed by the Debt Clause of the 14th Amendment, takes precedence over the more general and earlier-in time provision that is Section 3101(b).
5. Second, the Congressional Budget and Impoundment Control Act of 1974 (“CBICA”), 88 Stat. 297 et seq., 31 USC §§ 1301 et seq., prescribes a comprehensive and intricately detailed set of procedural steps that Congress and the President must take in formulating their own budgets, which budgets are then reconciled and collated before being legislated into law through authorization and appropriation acts passed by Congress and signed by the President. The resulting duly legislated and signed federal budget laws comprehensively determine federal revenue and spending, and assign the President and the Treasury the task of filling any gaps between the former and the latter through debt issuance. See 31 USC §§ 1322-32. Since the President and the Treasury are furthermore prohibited under this regime from not spending what the comprehensively detailed federal budget mandates them to spend, see 31 USC §§ 1400 et seq., the CBICA of 1974 effectively mandates borrowing any time mandated spending exceeds mandated revenue. This requirement is, moreover, buttressed by the “Take Care” Clause of Article II, Section 3 of our Constitution, which requires the President and his Administration to “take care that the Laws be faithfully executed.” Plaintiffs accordingly seek a declaration that the Statutory Debt Limit, rooted in the Second Liberty Bond Act of 1917 – an enactment originally intended, ironically enough, to expand Executive financing options (to handle the exigencies of the First World War mobilization) – has been superseded, as it were “field-preempted,” by the comprehensively detailed federal budgeting laws of 1974 and 1982 as buttressed by the “Take Care” Clause of Article II, Section 3 of the Constitution, and is accordingly null and void in any application that would purport to prohibit Treasury debt issuance to cover sovereign obligations.
6. Finally, the Fourteenth Amendment to the U.S. Constitution, even as a freestanding rather than statute-buttressing provision of law, provides in Section 4 that “[t]he validity of the public debt of the United States, authorized by law, . . ., shall not be questioned.” The Fourteenth Amendment further provides in Section 4 that “debts incurred for payment of pensions [such as Social Security and Veterans’ pensions] . . . shall not be questioned.” Section 4 is referred to as the “Public Debt Clause”. Section 5 in turn provides that “Congress shall have the power to enforce, by appropriate legislation, the provisions of this article,” on which the aforementioned 31 USC § 3123 cited above and further discussed makes good.
7. Plaintiffs accordingly seek a declaration that any application of the Statutory Debt that called into question the validity of the public debt of the United States, or the validity of debts incurred for the payment of Social Security benefits, Veterans’ pension benefits, or any other bona fide contractual claims would be an application that violates the 14th Amendment. Any such application of the Statutory Debt Limit must under such circumstances be declared constitutionally unlawful for its abrogating the constitutional obligation of the United States to pay public debt, federal pension benefits, and other contractual claims both in full and on time.
8. Plaintiffs additionally seek a declaration that the Statutory Debt Limit would be unconstitutional as applied if a resulting shortage of funds required the President and his designee the Secretary to violate binding spending decisions made by Congress in appropriations statutes, either by not spending at all or by “prioritizing” payments in violation of (a) the separation of powers principles manifest in Articles I and II of the Constitution; (b) the President’s obligation not to “impound” budget-mandated appropriations, as President Nixon did in occasioning passage of the CBICA of 1974, but instead to carry out all appropriations decisions mandated by Congress and signed into law by the President pursuant to prior budget legislation; or (c) the President’s obligation not to “prioritize” payments in violation of the “Presentment Clause” of Article I, Section 8 of the U.S. Constitution, as interpreted in Clinton v. City of New York, 524 U.S. 417 (1998) invalidating the “line item veto.”
Jurisdiction and Venue
9. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 because this is a civil action arising under the Constitution and laws of the United States.
10. Venue is properly lodged in this district under 28 U.S.C. § 1391(e)(1)(A) in that the office of defendant Secretary Yellen for the performance of her official duties is located in this district.
Parties
11. Plaintiffs _____, _____, and _____ own Treasury bills, Treasury bonds, and Treasury notes maturing on _______, ______ and _____, 2023. These United States debt obligations are due and payable to Plaintiffs on their respective maturity dates.
12. Plaintiffs _____, _____, and _____ are retired _____, _____, and _____. Plaintiffs receive monthly pension payments from the United States in the form of Social Security Administration (“SSA”) benefits. These monthly SSA benefit payments are Plaintiffs’ principal sources of income.
13. Plaintiffs _____, _____, and _____ are retired _____, _____, and _____. Plaintiffs receive monthly pension payments from the United States in the form of Veterans’ Administration (“VA”) pension benefits. These monthly VA payments are Plaintiffs’ principal sources of income.
14. Plaintiffs _____, _____ and _____ are _____, _____, and _____. Plaintiffs are party to contracts with the United States pursuant to _____, _____, and _____. Default by the U.S. Government on Plaintiffs’ contracts would not only constitute breach of contract, but also would do Plaintiffs contractual injury valued at $_____.
15. Defendant Janet Yellen is the Secretary of the Treasury of the United States and head of the U.S. Department of the Treasury (hereinafter “Treasury” or “the Treasury”). She is responsible for managing the public debt and serves as the financial agent for the United States government.[1]
Facts
16. With the approval of the President, Secretary Yellen is authorized by law to borrow on the credit of the United States Government all amounts necessary for government expenditures. Secretary Yellen determines the amount of money that the United States must borrow at any given time in order to pay Social Security and Medicare benefits, military salaries, interest owed on the national debt, tax refunds, contractual obligations, agricultural support payments, and myriad other programs and obligations of the United States government.
17. The Treasury exercises its borrowing authority by issuing Treasury bills, notes and bonds. Treasury bills have a maturity of four weeks to one year. Treasury notes have a maturity of two to ten years. Treasury bonds are twenty to thirty-year debt obligations. All of these debt instruments, which are referred to herein as “Treasurys,” “Treasury Securities” or “Treasury Debt Instruments,” are contractual in nature: they contain express written promises to repay principal at maturity and to pay interest according to specific coupon schedules.
18. U.S. Treasurys have long been in high demand worldwide as the safest of “safe assets” for inclusion in asset portfolios, for use as collateral, and even as “real world” instantiations of the hypothetical “risk-free assets” on which the use of all traders’ asset-pricing models, from the Capital Asset Pricing Model (“CAPM”) to Arbitrage Pricing Theory (“ABT”), is predicated. This renders the U.S. Treasury market, valued at over $24 trillion outstanding, by far the largest financial asset market in the world. This in turn enables the U.S. to borrow at home and abroad more cheaply by far than can any other borrower public or private. So advantageous to Americans is this global role of U.S. Treasury Securities that foreign officials have often complained of the “exorbitant privilege” that demand for U.S. Treasurys confers upon the U.S. and its citizens in comparison to all other borrowers, state or non-state.
19. U.S. Treasury Securities also are treated as the safest of “safe assets” under all U.S. banking and finance-regulatory regimes. They are considered near cash-equivalents for both liquidity- and capital-regulatory purposes, receiving risk weights of zero under all risk-weighted renditions of these familiar regulatory regimes. For this reason, scores of millions of American retirees and other investors rely directly or indirectly on the sanctity of the covenant represented by U.S. Treasurys for the security of their retirement savings and other investment portfolios.
20. The Statutory Debt Limit currently provides that the United States government may not borrow more than $31.381 trillion at any one time.
21. On January 13, 2023, Secretary Yellen in a letter addressed to Speaker Kevin McCarthy of the U.S. House of Representatives advised him that the outstanding public debt of the United States was projected to reach the Statutory Debt Limit on January 19, 2023. Secretary Yellen advised that the Department of the Treasury would thereafter have to take available “extraordinary measures” to limit the outstanding public debt to the statutory limit – in this case, suspending investment by the Treasury in certain government retirement funds. Secretary Yellen further advised that the length of time that these measures could be used to enable the government to meet its legal obligations without additional borrowing was not certain but was likely in June, 2023.
22. On or about January 19, 2023, the outstanding public debt of the United States reached the statutory limit. Thereafter the Treasury could not borrow the additional amounts needed to fund the government, and it accordingly commenced its resort to the extraordinary measures described by Secretary Yellen six days earlier on January 13, 2023.
23. These extraordinary measures have now run their course. They no longer suffice to enable the Treasury to meet its obligations to Plaintiffs _____ and other debtholders to make repayment in full on the debt instruments issued by the Treasury.
24. The total amount of U.S. debt coming due in June and July, 2023 is greater than $1 trillion.
25. Within less than one month from the filing date of this complaint, the United States will not be able to meet its legal obligations to Plaintiffs _____, _____, _____, or to literally scores of millions of other holders of U.S. Treasury Debt Instruments because the Statutory Debt Limit is, at least facially, prohibiting the Treasury from borrowing the necessary funds. Failure to pay the principal or interest due on Treasury bills, notes and bonds in full and on time will constitute a default.
26. On May 1, 2023, Secretary Yellen in a letter addressed to Speaker Kevin McCarthy of the U.S. House of Representatives advised him that the Treasury will default on U.S. Treasury debt instruments by early June of 2023. Default will potentially occur as early as June 1, 2023, but not more than a few weeks later than June 1st. An outright default on the billions of dollars in United States debt that matures in June is thus imminent.
27. Since 1945 the United States dollar has been the foundation of the global financial system, with the dollar functioning as the sole international reserve currency and Treasury debt long regarded as the world’s safest and most liquid financial asset. Moreover, since the U.S. ceded manufacturing and hence export supremacy to rival nations from the 1990s onward, global demand for U.S. Treasurys has become the principal source of global demand for the U.S. dollar itself, hence for a significant portion of the dollar’s value both within the U.S. and without.
28. A default on U.S. sovereign debt would accordingly subvert the dollar’s value, spike interest rates, and rapidly escalate borrowing and other costs for both the United States and its citizens – thereby “blowing up” the very deficits and inflation rates about which the Congressmembers now holding up a debt ceiling hike profess concern. It would also bring widespread, catastrophic disruption to domestic and global financial markets, and hence the macroeconomy as well. Domestic housing costs would rise dramatically due to the higher interest rates that a default would occasion, while home sales could fall by 25% or more due to higher mortgage rates – a tanking on par with that of 2006-2014, instantly placing millions of home-owners “underwater.” Consumer prices, already subject to disquieting inflation thanks to pandemic-wrought supply disruptions, would spike much, much higher. According to Moody’s Analytics, the stock market could lose as much as one third of its value – a percentage not seen since the Great Depression.
29. The cutoff in federal spending would thus likely result in a deep recession in which millions, if not indeed tens of millions, of people would lose their jobs. This calamity surely would constitute an “absurd result” that the drafters of the 1917 Liberty Bond Act in which the debt ceiling originates – again, ironically, an enactment through which Congress sought to expand Treasury financing options – could not have intended. (In consequence, the Statutory Debt Ceiling as it would be applied by Secretary Yellen could be deemed contrary to law on grounds of the Absurd Result Canon in addition to the other grounds above elaborated.)
30. Turning back to more immediate consequences of default, in this case affecting not only bondholders and financial markets but now other contractual counterparties and pension promisees too, Secretary Yellen has stated that default “would mean that Social Security recipients and veterans and people counting on money from the government that they’re owed, contractors, we just would not have enough money to pay the bills.”
31. This imminent default is not the result of any actual solvency problem or other economic challenge; nor is it the result of the federal budget deficit. The imminent default is the entirely voluntary, if not sought, consequence of wanton disregard by certain members of the U.S. Congress of the wholesale calamity that will ensue if the U.S. Treasury fails to honor our country’s sovereign obligations as they come due.
FIRST CAUSE OF ACTION
(Statutory Conflict)
32. Plaintiffs repeat and reallege each and every allegation contained in the foregoing paragraphs as if fully set forth here.
33. Title 31, U.S. Code, Sections 1322-32 comprehensively prescribe minutely detailed procedures for formulating and enacting each year’s federal budget. These include provisions for expenditure, revenue, and debt. Title 31, U.S. Code, Section 3123(a), then provides that “[t]he faith of the United States Government is pledged to pay, in legal tender, principal and interest on the obligations of the Government issued under this chapter,” while Title 31, U.S. Code, Section 3123(b), then further provides that “[t]he Secretary of the Treasury shall pay interest due or accrued on the public debt.”
34. These comprehensive and minutely detailed provisions on the one hand, and the general Statutory Debt Limit on the other hand, impose conflicting obligations on our Treasury Secretary. In order to pay the principal and interest due on the public debt as prescribed and vouchsafed, respectively by the aforementioned provisions, Secretary Yellen must borrow greater amounts than purportedly authorized by the Statutory Debt Limit. In the face of this conflict, there is but one proper course of action.
35. 31 USC §§ 1322-32, rooted in the Congressional Budget and Impoundment Control Act of 1974, and 31 USC § 3123(a), rooted in subsequent 1982 “housekeeping” legislation, respectively prescribe Congressional line-item budgeting in comprehensive and minute detail while pledging the full faith and credit of the United States to pay all principle and interest incurred on debt issued pursuant to all federal budgets formulated through this mandated process. 31 USC § 3101(b), by contrast, purports simply to apply a general limit on debt issuance across the board while also, importantly, subjecting that limit to changes periodically made in the plenary debt amount “by law through the congressional budget process” prescribed in detail by 31 USC §§ 1322-32.
36. The upshot, per the lex specialis principle, is that the “limit” is effectively repealed to whatever extent specific budget legislation, passed later-in-time pursuant to the comprehensive budgeting process prescribed in detail by 31 USC §§ 1322-32 and guaranteed by 31 USC § 3123, that subsequently happens to exceed this more general “limit” imposed earlier-in-time.
37. Accordingly, Plaintiffs seek a declaration that Secretary Yellen is not bound by Section 3101(b) to the extent that compliance with it would prevent her from complying with Sections 1322-32 and 3123.
38. The balance of harms favors injunctive relief as well. Defendant Yellen has stated that a default will cause irreparable harm to the United States as well as financial injury to untold millions of its citizens.
SECOND CAUSE OF ACTION
(Statutory Conflict)
39. Plaintiffs repeat and reallege each and every allegation contained in the relevant paragraphs above as if fully set forth here.
40. The Congressional Budget and Impoundment Control Act of 1974 (again, “CBICA”), 88 Stat. 297 et seq., 31 USC §§ 1301 et seq., provides detailed procedural steps for Congress and the President to take in formulating their own comprehensively detailed federal budget proposals. These budgets are then reconciled and collated to constitute the final blueprint for subsequent authorization and appropriations acts passed by Congress and signed into law by the President. Id., Sections 300-311. The resultant duly legislated federal budget determines revenue and spending, and does not require that expenditure equate to tax revenues. Rather, it requires that a concurrent joint resolution of Congress first specify the amount by which the statutory limit on the public debt is to be changed and then direct all committees with relevant jurisdiction to recommend such change. CBICA § 310(a)(3). The President and the Treasury are then required to issue debt that is consistent with the budget, not the Statutory Debt Ceiling.
41. The President and the Treasury are also required, moreover, to spend the amounts that the budget mandates them to spend. This is a second way in which the CBICA, in this case buttressed by Article II’s “Take Care” Clause, requires borrowing whenever mandated spending exceeds authorized revenue.
42. Plaintiffs accordingly seek a declaration that the Statutory Debt Limit rooted in the Second Liberty Bond Act of 1917 has been superseded by the Congressional Budget and Impoundment Control Act of 1974, and is null and void to the extent that it conflicts with that comprehensive regime enacted later-in-time .
THIRD CAUSE OF ACTION
(Violation of 14th Amendment, Section 4)
43. Plaintiffs repeat and reallege each and every allegation contained in the relevant paragraphs above as if fully set forth here.
44. In 1868 the 14th Amendment to the U.S. Constitution was ratified in specific contemplation of the fact that legislators from former Confederate states were planning both to retake control of Congress upon readmission to the Union and then to subvert the Union from within by repudiating the public debt and pension obligations incurred in the course of putting down the Confederacy’s attempt at destroying the Union from without through rebellion. In Section 4 it provides: “The validity of the public debt of the United States, authorized by law, including debts incurred for payment of pensions and bounties for services in suppressing insurrection or rebellion, shall not be questioned.”
45. In 1935 the United States Supreme Court stated that the 14th Amendment is “confirmatory of a fundamental principle, which applies as well to the government bonds [issued in 1918], and to others duly authorized by the Congress, as to those issued before the [14th] Amendment was adopted. Nor can we perceive any reason for not considering the expression ‘the validity of the public debt’ as embracing whatever concerns the integrity of the public obligations.”[2]
46. Congress thus may not alter, repudiate or impair the public debt instruments that it has authorized the Treasury to issue or the pension obligations that it has undertaken through our Social Security or Veterans’ Benefit legislation. Nor may Secretary Yellen alter, repudiate or impair the public debt obligations that the Congress has authorized her to enter into or the pension obligations undertaken through that legislation.
47. Plaintiff _____ and all other holders of Treasury debt instruments maturing in June, 2023 and thereafter are entitled to timely payment in full of the principal and interest due to them.
48. Under Section 4 of the 14th Amendment, the validity of the pension rights of Plaintiffs _____ and of all other recipients of Social Security or Veterans’ Administration pensions may not be questioned. Plaintiffs _____ and all other recipients of Social Security or Veterans’ Administration pensions are entitled to timely payment in full of the principal and interest due to them.
49. The Statutory Debt Limit is unconstitutional as Secretary Yellen would apply it because it will cause the Secretary either to default on the debt instruments the Treasury has issued and on the pension benefits due to Plaintiffs _____ and all other recipients of Social Security or Veterans’ Administration pensions, or to “prioritize” payments in violation of Article I’s “Presentment Clause” as interpreted in Clinton v. City of New York, 524 U.S. 417 (1998).
50. Plaintiffs are therefore entitled to a judgment declaring the Statutory Debt Limit to be unconstitutional as applied.
51. The balance of harms favors injunctive relief as well. Defendant Yellen has stated that a default will cause irreparable harm to the United States as well as financial injury to untold millions of its citizens.
FOURTH CAUSE OF ACTION
(Separation of Powers Violation)
52. Plaintiffs repeat and reallege each and every allegation contained in the relevant paragraphs above as if fully set forth here.
53. Article I of the Constitution vests the federal government’s spending power in Congress. See U.S. Const. art. I, § 8, cl. 1. The U.S. Supreme Court has held that the Constitution does not give the President or his delegee Secretary Yellen discretion to suspend, cancel or fail to carry out spending already mandated by Congress and signed into law by the President.
54. Under the facts set forth above, and in violation of the separation of powers established by Articles I and II as well as the “Presentment” and “Take Care” Clauses of those provisions, the Statutory Debt Limit necessarily requires the Defendant Secretary to cancel, suspend, or refuse to carry out spending mandated by Congress and signed into law by the President, without the consent or approval of Congress.
55. Because the Statutory Debt Limit as applied by the Secretary necessarily delegates spending decisions to the President and his delegee Defendant Yellen in order to meet its terms, this Court should declare that 31 U.S.C. § 3101(b) is unconstitutional.
WHEREFORE, Plaintiffs prays that this Court enter judgment:
A. Declaring the Debt Ceiling Statute unenforceable to the extent that it impairs compliance by the Secretary with the specific pledge made in Title 31, U.S. Code, Sections 3123(a);
B. Declaring the Debt Ceiling Statute null and void in light of the Congressional Budget and Impoundment Control Act of 1974;
C. Declaring the Debt Ceiling Statute unconstitutional as applied to the extent that it calls into question the validity of the public debt of the United States by preventing Secretary Yellen from borrowing amounts sufficient to pay the public debt;
D. Declaring the Debt Ceiling Statute unconstitutional as applied to the extent that it deprives Plaintiff _____ and all Social Security recipients of their pension benefits by preventing Secretary Yellen from borrowing amounts sufficient to pay these benefits;
E. Directing the defendant Secretary to borrow sufficient amounts to repay principal and interest on U.S. debt instruments in accordance with their terms and to pay the Social Security benefits of all Social Security pension beneficiaries; and
F. Enjoining the defendant Secretary from limiting the borrowing of the United States to the extent that the Statutory Debt Limit would otherwise require the Secretary to make de facto appropriations decisions that the Constitution directs Congress to make; and
G. Granting Plaintiffs such other and additional relief as is just and proper.
Dated: New York, New York
May 24, 2023
/s/ _____
_____
_____
_____
Tel: _________
Email: _______
and
___________________________
_____
_____
_____
_____
Tel: ________
Email: ______
[1] https://home.treasury.gov/subfooter/faqs/duties-and-functions-faqs (last accessed May 24, 2023).
[2] Perry v. United States, 249 U.S. 330, 354 (1935) (emphasis in original).
What is your preferred way of receiving enlistments from co-plaintiffs?
What information do you need above and beyond name, postal address, telephone and email address?