already
suffered irreparable harm, and will continue to be irreparably damaged unless
this Court
enjoins
defendant from continuing its unlawful acts. Plaintiffs have no adequate remedy
at law.
JURY
DEMAND
Pursuant to Fed. R. Civ. P. 38(b), Plaintiffs Starbucks Corporation and
Starbucks U.S.
Brands,
Inc. hereby demand trial by jury of all issues so triable that are raised herein
or which
hereinafter
may be raised in this action.
WHEREFORE, Plaintiffs pray for judgment as follows:
1.
On each and every Claim for Relief alleged herein, for damages according
to
proof;
2. On
each and every Claim for Relief alleged herein, for preliminary and permanent
injunctive
relief as hereinabove described;
3. On
each and every Claim for Relief alleged herein, for attorneys' fees and
enhanced
damages as provided by law;
4. For
their costs of suit herein, including their reasonable attorneys' fees; and
5. For such other, further or different relief as this Court may deem just and proper.
DATED:
New York, New York
July 2, 2001
| JONES, DAY, REAVIS & POGUE | ||
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NY-H66l57vl