Mr. Wachtel will petition the court on an expedited basis. Application for a summons DC-430 File with a verified complaint to request the court to issue a summons if you do not have an attorney.The complaint should conclude with a paragraph in which the plaintiff sets forth all the relief against the defendant that he or she is seeking from the court. WHEREFORE, New York and Connecticut respectfully request that this Court enter judgment against EPA as follows: 1. For a Rule 23(b)(2) class, "where plaintiffs request declaratory and injunctive relief against a defendant engaging in a common course of conduct toward them . Plaintiff's Claim for Declaratory and Injunctive Relief. Nothing more is needed to state a claim for declaratory relief. Additionally, this action seeks monetary, injunctive, and declaratory relief under state law and the New York State Constitution. 3.