WHEREFORE, New York and Connecticut respectfully request that this Court enter judgment against EPA as follows: 1. In short, "the National Bank Act authorizes national banks to receive deposits without qualification or limitation.I have read this VERIFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE. They have failed to state a Declaratory Judgment claim upon which relief can be granted and the Complaint must be dismissed. Proposed Amended Complaint for Declaratory and Injunctive Relief, Planned Parenthood Southwest Ohio Region et al. IN THE COURT OF COMMON PLEAS HAMILTON COUNTY, OHIO PLANNED PARENTHOOD SOUTHWEST OHIO REGION, et al. Declaratory or injunctive relief in official-capacity suits. " Franklin, 505 U.S. at 827 (Scalia, J., concurring). In addition, Plaintiffs request injunctive relief, as well as declaratory judgment pursuant to the Declaratory Judgment Act, 28 U.S.C. § 2201. Complaint for Declaratory Judgment and Temporary, Preliminary, and Permanent Injunctive.