MESSAGE
| DATE | 2026-05-02 |
| FROM | Ruben Safir
|
| SUBJECT | Re: [Hangout - NYLXS] amicus
|
I want to also just put this out there as plain text for anyone else to
comment on. Mutt if not found of even openxml and pdfs
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
MCM GROUP 22 LLC,
Plaintiff,
v.
LYNDON PERRY,
Defendant.
Case No.: 22-cv-06157
Hon. George B. Daniels
BRIEF OF AMICUS CURIAE
NEW YORKERS FOR FAIR USE
IN SUPPORT OF DEFENDANT'S
MOTION FOR PREVAILING
PARTY ATTORNEYS' FEES
AND COSTS
BRIEF OF AMICUS CURIAE NEW YORKERS FOR FAIR USE IN SUPPORT OF
DEFENDANT’S MOTION FOR PREVAILING PARTY ATTORNEYS’ FEES AND COSTS
IDENTITY AND INTEREST OF AMICUS CURIAE
Amicus curiae New Yorkers for Fair Use (“NYFU”) is an unincorporated New
York association of writers, technologists, librarians, educators,
archivists, and creative professionals devoted to preserving the balance
the Constitution and the Copyright Act both demand: meaningful
protection for authors, and meaningful breathing room for the public.
From its base in this District—the media capital of the United States,
and the principal forum in which American fair use doctrine is developed
in the first instance—NYFU advocates for a copyright regime in which
neither the rights of creators nor the freedoms of the public are
sacrificed to whichever enforcement campaign happens to be loudest. NYFU
supports robust protection of copyrighted works against piracy. It is
equally committed, however, to preserving the fair use
defense—copyright’s “built-in First Amendment accommodation,” Eldred v.
Ashcroft, 537 U.S. 186, 219 (2003)—without which copyright would lose
its constitutional grounding.
NYFU has a direct and substantial interest in this case. Its members
live, work, write, teach, code, publish, and create here, in this
District. They are the natural population of fair use defendants in the
Southern District of New York, and they are also the cultural,
journalistic, and scholarly commentators whose ability to engage in
protected speech depends on whether the fair use doctrine functions as a
real defense or only as an aspiration. They include precisely the sort
of person who, on Defendant Lyndon Perry’s record, posts a single image
to comment on a matter of public concern—and, equally, the sort of
person who can be financially ruined by the cost of defending against a
copyright claim that should never have been brought. The question
whether prevailing fair use defendants in this District can recover
their fees under 17 U.S.C. § 505 will determine whether this Court
remains a forum in which ordinary speakers can defend themselves under
Section 107, or whether it becomes a forum in which fair use survives
only in those rare cases where a defendant happens to attract pro bono
counsel or finds a lawyer willing to absorb the loss.
NYFU has a particular interest in this case because it is one of the
rare instances—empirical work has identified fewer than five dozen such
opinions in over four decades of reported fair use decisions—in which a
court has dismissed a copyright claim on fair use grounds at the
pleading stage. See Barton Beebe, An Empirical Study of U.S. Copyright
Fair Use Opinions, Updated, 1978–2019, 10 N.Y.U. J. Intell. Prop. & Ent.
L. 1 (2020). Where the law functioned as it should—affording a clear,
early adjudication that the defense was sound—the question whether that
defense produced its full statutory consequence under Section 505 is the
question on which fair use doctrine in this District will turn for the
next generation of NYFU’s members.
Pursuant to the disclosure practice customarily observed by amici in
federal court, NYFU states that no party or party’s counsel authored
this brief in whole or in part, and that no party, party’s counsel, or
any person other than NYFU and its counsel contributed money intended to
fund the preparation or submission of this brief. NYFU has no parent
corporation, and no publicly held corporation owns any interest in it.
SUMMARY OF ARGUMENT
Fair use is one of the few defenses on which the constitutional
structure of American copyright law actually rests. Eldred, 537 U.S. at
219–20. By design, it is a doctrine developed not by statutory
enumeration but by litigation—and it cannot be developed if it cannot be
afforded. Section 505 of the Copyright Act addresses that risk by
granting district courts discretion to award reasonable attorneys’ fees
to the prevailing party in copyright litigation. 17 U.S.C. § 505. The
Supreme Court has instructed that this discretion be exercised
evenhandedly, treating prevailing plaintiffs and defendants alike,
Fogerty v. Fantasy, Inc., 510 U.S. 517, 534 (1994), and that the
objective reasonableness of the losing party’s position, while entitled
to substantial weight, is not dispositive, Kirtsaeng v. John Wiley &
Sons, Inc., 579 U.S. 197, 202–03 (2016). Amicus respectfully submits
that the Court should award prevailing party attorneys’ fees and costs
here, for the reasons that follow.
First, the failure to award prevailing party attorneys’ fees dissuades
experienced intellectual property counsel from representing defendants
who cannot afford to pay the prevailing rates in this District. Hourly
rates for experienced IP litigation partners in the Southern District of
New York range from $750 to $950 or more per hour, with total defense
costs in copyright cases routinely reaching hundreds of thousands of
dollars. When counsel knows that even a successful defense will leave
the client bearing those costs, with no prospect of recovery, the
rational economic decision is to decline the representation. The result
is that fair use defendants are left without adequate counsel and the
development of fair use doctrine is impoverished.
Second, prevailing party attorneys’ fees incentivize defendants to raise
and properly litigate fair use defenses—which is critical because fair
use doctrine in the United States is developed through precedent, not by
legislative enumeration. Unlike the United Kingdom’s Copyright, Designs
and Patents Act of 1988, which specifically enumerates the categories of
conduct that constitute “fair dealing,” the American doctrine of fair
use is an open-ended common-law defense rooted in the First Amendment.
Without fee-shifting, risk-averse defendants choose to license rather
than litigate, creating what Professor James Gibson has described as a
“doctrinal feedback” loop that steadily erodes the scope of fair use—the
paradox of fair use.
Third, fair use cases are rarely resolved on a motion to dismiss.
Empirical data demonstrates that the overwhelming majority of fair use
cases proceed through discovery and are resolved at the summary judgment
stage or later, making them among the most expensive categories of
copyright disputes. A prevailing defendant who must litigate through
summary judgment or trial without any prospect of fee recovery bears an
unjust and disproportionate burden.
Fourth, other circuits—most notably the Seventh—have recognized a strong
presumption that prevailing copyright defendants are entitled to
attorneys’ fees. The Second Circuit’s comparatively restrictive approach
leaves this District as the place where the real deterrent against
abusive anti-fair-use litigation must come from the trial courts. This
Court should exercise its discretion to award fees and send a clear
signal that frivolous or aggressive copyright claims targeting fair use
will carry meaningful consequences.
These principles are not abstract here. Plaintiff MCM Group 22 LLC is a
litigation vehicle formed for the sole purpose of “prosecuting the use
of copies, still images, and derivatives” of a pornographic video
produced by a criminal sex trafficking enterprise. ECF 38 at p. 2. This
Court granted Defendant’s motion to dismiss on fair use grounds, finding
on the face of the complaint alone that all four statutory factors
favored the defense: the Tweet was transformative commentary on a matter
of substantial public interest; it reproduced only a single non-explicit
frame of a forty-six-minute video; and it posed no cognizable market
harm. Plaintiff effectively conceded the fourth factor, arguing not that
the Tweet harmed the video’s market, but that it increased public
interest in it. This was not a close case. Yet Defendant was forced to
retain counsel, brief a motion to dismiss, and litigate through a full
opposition-and-reply cycle before obtaining the dismissal to which he
was clearly entitled. The question now before this Court is whether
Defendant must bear those costs alone, or whether Section 505 will serve
its intended purpose of deterring overreaching copyright claims and
ensuring that meritorious fair use defenses can actually be defended.
The answer should be the latter.
ARGUMENT
I. FAILURE TO AWARD PREVAILING PARTY ATTORNEYS’ FEES DISSUADES DEFENSE
COUNSEL FROM REPRESENTING FAIR USE DEFENDANTS WHO CANNOT AFFORD
EXPERIENCED INTELLECTUAL PROPERTY COUNSEL
The economics of copyright defense in the Southern District of New York
present a stark reality. This District sits in one of the most expensive
legal markets in the nation, and intellectual property
litigation—particularly copyright litigation involving fair use—demands
specialized counsel with deep expertise in a complex and evolving area
of law. The prevailing hourly rates for such counsel are substantial.
Courts in this District apply the lodestar method to determine
reasonable attorneys’ fees, multiplying the number of hours reasonably
expended by a reasonable hourly rate. The prevailing rates for
experienced intellectual property litigation attorneys in this District
are among the highest in the nation. Senior partners at established IP
litigation firms routinely command rates of $750 to $950 per hour or
more. Mid-level associates bill between $400 and $650 per hour, and even
junior associates bill between $300 and $450 per hour. These rates
reflect the specialized nature of copyright fair use litigation, which
requires not only mastery of the Copyright Act and its extensive case
law, but also a sophisticated understanding of the First Amendment
principles that undergird fair use doctrine.
The aggregate cost of defending a copyright fair use case in this
District is staggering. According to the American Intellectual Property
Law Association’s 2023 Economic Survey, the median cost of litigating a
copyright infringement case through trial ranges from approximately
$200,000 to over $2 million, depending on the amount in controversy.
Even where a case settles or is resolved on summary judgment, defense
costs regularly exceed $150,000 to $500,000. For a defendant of modest
means—an independent artist, a small business, a nonprofit organization,
or an individual content creator—these sums are prohibitive.
When prevailing party fees are not regularly awarded, the consequences
cascade through the market for legal representation. Experienced IP
defense counsel, aware that even a successful outcome will leave the
client bearing the full weight of litigation costs, face a difficult
calculus. Contingent-fee arrangements are rarely available to copyright
defendants, because there is no affirmative recovery to fund the
contingency. Pro bono representation, while laudable, is insufficient to
meet demand and often cannot provide the sustained, intensive effort
that a complex fair use case requires. The practical result is that many
defendants with meritorious fair use defenses simply cannot find
experienced counsel willing to take their cases.
This gap in representation does not merely disadvantage individual
defendants—it impoverishes the development of fair use law for
everyone.1 Every meritorious fair use defense that goes unlitigated for
lack of counsel is a precedent that never gets made, a boundary of fair
use that never gets clarified, and an invitation for copyright holders
to bring the same aggressive claims against the next defendant. The
regular award of prevailing party fees in fair use cases would
materially alter this dynamic by assuring defense counsel that a
successful result will be compensated, thereby expanding the pool of
attorneys willing to represent fair use defendants.
II. PREVAILING PARTY ATTORNEYS’ FEES INCENTIVIZE THE PROPER LITIGATION
OF FAIR USE DEFENSES, WHICH IS ESSENTIAL TO THE DEVELOPMENT OF THIS
FIRST AMENDMENT DOCTRINE
The doctrine of fair use occupies a unique and critical position in
American copyright law. It serves as copyright’s principal “built-in
First Amendment accommodation”—the primary mechanism by which courts
balance the exclusive rights of copyright holders against the public’s
interest in the free flow of information, commentary, criticism, and
creative expression. The failure to incentivize the assertion of fair
use defenses through fee-shifting does not merely affect individual
litigants: it threatens the continued vitality of the doctrine itself.
A. The Paradox of Fair Use and Doctrinal Feedback
In a seminal article published in the Yale Law Journal, Professor James
Gibson identified what he termed the “doctrinal feedback” loop that
steadily erodes the scope of fair use.2 The mechanism is both elegant
and alarming. Because the fourth factor of the fair use analysis—the
effect of the use upon the potential market for the copyrighted
work—looks to the existence of licensing markets, the very act of
licensing creates evidence that undermines future fair use claims.3
Gibson described the process as follows. When a risk-averse user faces
uncertainty about whether a use is fair, the rational decision is to
seek a license rather than risk litigation. Over time, as more users
seek licenses, an established licensing market emerges. Once that market
exists, courts treating the fourth fair use factor weigh it against
future defendants, reasoning that the existence of a willing licensing
market demonstrates market harm. The odds that were once favorable to
fair use shift dramatically against it.4
This is the paradox of fair use: the defense’s scope is determined in
part by the very licensing behavior that the defense is supposed to make
unnecessary. The more that risk-averse parties choose to license rather
than assert fair use, the weaker the defense becomes for everyone.
Gibson recognized that “risk-averse behavior prevents fair use claims
from being litigated, so a licensing culture emerges based on very few
and very infrequent guidelines from the positive law.”5
The failure to award prevailing party fees exacerbates this doctrinal
feedback loop. When defendants know that even a successful fair use
defense will saddle them with hundreds of thousands of dollars in
unrecoverable legal costs, the rational decision is to pay the license
fee—or, in the case of litigation, the settlement—rather than to
litigate. Each such capitulation feeds the licensing market, which in
turn erodes the fair use defense for the next defendant. Strategic
behavior by copyright holders compounds the problem: cease-and-desist
campaigns and aggressive enforcement actions are designed to cultivate
precisely this risk-averse response.6
B. The Enclosure of the Public Domain
Professor Robert A. Heverly’s work on the ethics of information
enclosure provides a complementary perspective.7 Heverly documented how
powerful media entities simultaneously invoke First Amendment
protections for their own speech while seeking to use intellectual
property law to restrict the speech of others.8 Drawing on the
historical analogy of the English enclosure movement, in which common
lands were “fenced off and made ‘private’ with the support of the
state,” Heverly argued that a parallel process of “information
enclosure” is underway, in which formerly public domain uses are being
captured through the expansion of copyright claims.9
This enclosure dynamic is directly relevant to the fee-shifting question
before this Court. When defendants lack the economic incentive to
challenge overbroad copyright claims—because even prevailing defendants
cannot recover their costs—the practical effect is to allow copyright
holders to “enclose” previously free uses without judicial scrutiny.
Each unchallenged claim becomes a de facto expansion of copyright,
shrinking the public domain and the scope of permissible fair use. As
Heverly recognized, this process is fundamentally at odds with the
ethical and constitutional principles that animate copyright law.10
C. Fair Use as a First Amendment Safeguard Requires Judicial Development
The structural importance of fee-shifting becomes clearer when one
considers the unique nature of fair use doctrine in the United States.
Section 107 of the Copyright Act provides an open-ended, non-exhaustive
list of purposes that may qualify as fair use—including criticism,
comment, news reporting, teaching, scholarship, and research—and directs
courts to consider four statutory factors in making the determination.
17 U.S.C. § 107. As the Supreme Court emphasized in Campbell v.
Acuff-Rose Music, Inc., the analysis is necessarily case-by-case and
resists reduction to “bright-line rules.” 510 U.S. 569, 577 (1994) (“The
task is not to be simplified with bright-line rules, for the statute,
like the doctrine it recognizes, calls for case-by-case analysis.”).
This stands in contrast to the approach taken by the United Kingdom,
where the Copyright, Designs and Patents Act of 1988 specifically
enumerates the categories of permissible “fair dealing”: research and
private study, criticism and review, and news reporting.11 Under the
British system, the boundaries of permissible use are defined by
statute. Under the American system, those boundaries are defined by
precedent, which requires applying the four-factor test to the
particular facts at hand. Fair use in the United States is, by design, a
common-law doctrine that requires ongoing judicial development to
maintain its vitality.
This design reflects the First Amendment dimension of fair use. The
Supreme Court has recognized that fair use is one of copyright’s
“built-in free speech safeguards” that reconciles the Copyright Clause
with the First Amendment. Eldred v. Ashcroft, 537 U.S. 186, 219–20
(2003) (“[C]opyright’s built-in free speech safeguards are generally
adequate to address” First Amendment concerns, including “the fair use
defense”). But a safeguard that exists only in theory—because defendants
cannot afford to invoke it—provides no protection. If fair use is to
serve its constitutional function, it must be developed through actual
litigation. And if it is to be developed through actual litigation,
defendants must have an adequate incentive to assert it. The regular
award of prevailing party fees provides precisely that incentive.
Without fee-shifting, the incentive to license rather than litigate
becomes overwhelming. This is Gibson’s point: as fewer defendants assert
fair use, fewer precedents are created; as fewer precedents are created,
the doctrine becomes less predictable; as the doctrine becomes less
predictable, risk-averse defendants become even less willing to
litigate.12 The result is a self-reinforcing cycle in which fair use
withers not because courts reject it, but because defendants never
invoke it.13 Copyright holders, meanwhile, exploit this dynamic through
enforcement actions—cease-and-desist campaigns, demand letters, and
aggressive litigation—designed to create and sustain the risk aversion
that feeds the cycle.14
III. FAIR USE CASES ARE RARELY RESOLVED ON A MOTION TO DISMISS, MAKING
THEM DISPROPORTIONATELY EXPENSIVE TO LITIGATE
The economic burden of defending a fair use case is compounded by the
procedural reality that fair use defenses are almost never resolved at
the earliest stages of litigation. Empirical evidence demonstrates that
fair use claims overwhelmingly proceed through discovery and are
resolved, if at all, at the summary judgment stage or later,
dramatically increasing the cost borne by defendants.
Professor Barton Beebe’s comprehensive empirical study of U.S. copyright
fair use opinions from 1978 through 2019 provides the most authoritative
data on this point.15 Of all reported fair use opinions spanning more
than four decades, Beebe identified only 53 opinions addressing motions
to dismiss on fair use grounds.16 The vast majority of these post-dated
the Supreme Court’s decisions in Twombly and Iqbal, which raised the
pleading standard generally but did not materially alter the landscape
for fair use defenses—which courts continue to treat as inherently
fact-intensive questions not amenable to resolution on the pleadings.
By contrast, 58.7% of all fair use opinions in Beebe’s dataset addressed
motions for summary judgment, confirming that the majority of fair use
issues are resolved on summary judgment.17 This means that a fair use
defendant typically must endure the entirety of fact discovery—document
production, interrogatories, depositions, and expert discovery—before
obtaining any ruling on the merits of the defense. The cost implications
are enormous.
The AIPLA’s 2023 Economic Survey confirms that the bulk of copyright
litigation costs accrue during the discovery and dispositive motion
phases.18 A defendant who must litigate through summary judgment will
typically incur $200,000 to $500,000 or more in legal fees, and this
figure escalates dramatically if the case proceeds to trial, where costs
can exceed $1 million to $2 million.
The combination of these two facts—that fair use is rarely resolved
early, and that late-stage litigation is extraordinarily
expensive—creates a very large disincentive for defendants to assert
fair use at all. When a defendant faces protracted, expensive litigation
with no prospect of recovering fees even if successful, the rational
choice is to pay a license fee or settle, regardless of the merits of
the fair use defense. This reinforces the feedback loop described by
Professor Gibson and further erodes the scope of fair use. The regular
award of prevailing party fees in fair use cases is necessary to
counterbalance this disadvantage.
IV. OTHER CIRCUITS RECOGNIZE A STRONG PRESUMPTION IN FAVOR OF PREVAILING
PARTY FEES IN COPYRIGHT CASES; THIS COURT SHOULD FOLLOW SUIT
The Seventh Circuit has developed an instructive framework for awarding
prevailing party attorneys’ fees in copyright cases that resolves these
issues. In Live Face on Web, LLC v. Cremation Society of Illinois, Inc.,
the Seventh Circuit held that “when denying a prevailing copyright
defendant his attorney’s fees, a district court’s discretion is very
narrow.” 77 F.4th 630, 632 (7th Cir. 2023). There is, in effect, a
presumption that prevailing defendants will recover their fees, placing
the burden on the losing plaintiff to justify denial.
This is not a new doctrine. In Woodhaven Homes & Realty, Inc. v. Hotz,
the Seventh Circuit declared that “prevailing defendants in copyright
cases … are presumptively entitled (and strongly so) to recover attorney
fees.” 396 F.3d 822, 824 (7th Cir. 2005). Judge Posner, writing for the
Seventh Circuit in Assessment Technologies of WI, LLC v. WIREdata, Inc.,
explained the policy rationale: “The point is only that when a
meritorious claim or defense is not lucrative, an award of attorneys’
fees may be necessary to enable the party possessing the meritorious
claim or defense to press it to a successful conclusion rather than
surrender it because the cost of vindication exceeds the private benefit
to the party.” 361 F.3d 434, 437 (7th Cir. 2004) (Posner, J.). Other
circuits have adopted similar approaches, recognizing that the statutory
fee-shifting provision serves an important policy function that is
undermined when prevailing defendants are denied fees. See, e.g.,
Ets-Hokin v. Skyy Spirits, Inc., 323 F.3d 763, 766 (9th Cir. 2003);
Positive Black Talk Inc. v. Cash Money Records Inc., 394 F.3d 357,
380–81 (5th Cir. 2004), abrogated on other grounds.
The Supreme Court’s decisions in Fogerty and Kirtsaeng are fully
consistent with this approach. In Fogerty, the Court emphasized that
prevailing plaintiffs and defendants should be treated alike under
Section 505 and identified “frivolousness, motivation, objective
unreasonableness, and the need in particular circumstances to advance
considerations of compensation and deterrence” as factors guiding the
exercise of discretion. 510 U.S. at 534 n.19. In Kirtsaeng, the Court
clarified that, while objective reasonableness of the losing party’s
position should receive “substantial weight,” it should not be treated
as a “presumption against granting fees” that forecloses further
analysis. 579 U.S. at 202–04.
The Kirtsaeng Court specifically criticized the tendency of some
courts—including courts in this Circuit—to treat a finding that the
losing party’s position was objectively reasonable as effectively
dispositive against a fee award. The Court made clear that other
considerations, including the need for deterrence and compensation,
remain relevant even when the losing party’s position was not
objectively unreasonable.
The Second Circuit, however, has not adopted the Seventh Circuit’s
strong presumption in favor of prevailing party fees. That leaves the
trial courts in this District as the primary line of defense against
abusive copyright enforcement targeting fair use. In the absence of a
circuit-level presumption favoring fee awards, it falls to this Court to
exercise the discretion recognized by Fogerty and Kirtsaeng in a manner
that advances the statutory policy of encouraging meritorious defenses
and deterring overreaching claims. The award of fees in this case would
serve precisely those purposes.
CONCLUSION
For the foregoing reasons, New Yorkers for Fair Use respectfully urges
this Court to award prevailing party attorneys’ fees and costs to
Defendant Lyndon Perry. This case presents a compelling basis for a fee
award. Plaintiff is a litigation vehicle whose sole stated purpose is to
pursue copyright claims over a video produced by a criminal sex
trafficking enterprise. Defendant did nothing more than post a single
non-explicit still frame as part of commentary on a matter of genuine
public interest—the collapse of Celsius Network and the conduct of its
executives. This Court found, on the face of the complaint alone, that
all four fair use factors favored the defense and dismissed the action
without requiring discovery or summary judgment briefing.
These facts describe precisely the kind of overreaching claim that
Section 505 is designed to deter. Plaintiff wielded federal copyright
law not to protect any legitimate creative or economic interest, but to
suppress commentary on a public controversy, using litigation costs as a
weapon against a defendant of modest means. Awarding fees here would
compensate Defendant for the burden of vindicating a clear fair use
defense, deter similarly abusive enforcement actions in this District,
and affirm what the Constitution and Section 107 actually provide: a
right to publish, not a right to hire a lawyer and pray. This Court
should grant the motion.
Respectfully submitted,
/s/ Ronald D. Coleman
Ronald D. Coleman
Coleman Law Firm, PC
50 Park Place, Suite 1105
Newark, NJ 07102
(973) 264-9611
rcoleman-at-colemanlaw-pc.com
Counsel for Amicus Curiae
New Yorkers for Fair Use
Dated: April 28, 2026
On 5/1/26 1:41 PM, Ronald D. Coleman wrote:
> Maybe I sent to everyone EXCEPT Ruben. I just re-sent it.
>
> Ronald D. Coleman
> COLEMAN LAW FIRM, PC
> 50 Park Place, Suite 1105
> Newark, NJ 07102
> 973-264-9611
> Admitted to practice in New Jersey and New York
>
> -----Original Message-----
> From: Marc John Randazza
> Sent: Friday, May 1, 2026 1:36 PM
> To: Ruben Safir
> Cc: Ruben Safir ; Ronald D. Coleman
> Subject: Re: amicus
>
> Wanna make sure you guys are not miscommunicating because Ron sent it to you. Maybe it’s in a spam folder or something
>
>
> Marc John Randazza, JD, MAMC, LLM
>
> Randazza Legal Group
>
> Las Vegas - Gloucester - Miami
>
> Sent from iPhone (maybe even using Siri). If the message is at all intelligible, it is a minor miracle.
>
>
>> Il giorno 1 mag 2026, alle ore 12:58, Ruben Safir ha scritto:
>>
>> On Fri, May 01, 2026 at 12:31:57PM -0400, Marc Randazza wrote:
>>> all set?
>>>
>>
>> I haven't heard anything back from him yet. He asked for background
>> info. I gave it to him and then he asked me what we wanted done :(
>>
>> I so told him to write the amius and we'll sign it. But he then went
>> radio silent
>>
>>
>>> --
>>>
>>> ______________________________________
>>>
>>> *Marc John Randazza, JD, MAMC, LLM* *| *Randazza Legal Group*
>>> 8991 W. Flamingo Road, Unit B, Las Vegas, NV 89147
>>> 30 Western Avenue, Gloucester, MA 01930
>>> 2 S Biscayne Boulevard, Suite 2680, Miami, FL 33131
>>> Tel: 702-420-2001 | Email: mjr-at-randazza.com Firm Offices - Las Vegas
>>> | Miami | New England ______________________________________
>>>
>>> * Licensed to practice law in Arizona, California, Florida,
>>> Massachusetts, and Nevada.
>>
>> --
>> So many immigrant groups have swept through our town that Brooklyn,
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>> ing.com&d=DwIFaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=VVbV5
>> ht1vRGQt5SRJ8brlLM6OLtqVjPlCSmjsHlXyso&m=82_QE8tXUWmAQQPfNhTwhF9KET2Wz
>> hYeNXzU3WqTcFfAxosQmkArcOdZxYgiAAJC&s=9dZO-F6xNWjRPXlyG0r7nTr4pOsX6ZWE
>> 6sj5NGXYPkU&e=
>>
>> Being so tracked is for FARM ANIMALS and extermination camps, but
>> incompatible with living as a free human being. -RI Safir 2013
>>
--
So many immigrant groups have swept through our town
that Brooklyn, like Atlantis, reaches mythological
proportions in the mind of the world - RI Safir 1998
http://www.mrbrklyn.com
DRM is THEFT - We are the STAKEHOLDERS - RI Safir 2002
http://www.nylxs.com - Leadership Development in Free Software
http://www.brooklyn-living.com
Being so tracked is for FARM ANIMALS and extermination camps,
but incompatible with living as a free human being. -RI Safir 2013
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