gretchen scott v. gerwitt complaint.pdf

8/10/2019 Gretchen Scott v. Gerwitt complaint.pdf

1/17

J344C/SDNY

REV. 4/2014

CIVIL

COVER SHEET

The Jg.-44.civil

cover

sheet

and

theinformation contained herein neither replace nor

supplement the

filing

and

service of

pleadings

or

other papers

as

required by

law,

except

as

provided

by

local rules of court. This form,

approved by

the

Judicial

Conference

ofthe United States inSeptember1974, is required foruseof theClerk ofCourt forthe purposeof

initiating the civildo cket

sheet.

PLAINTIFFS

Gretchen

Scott LLC d/b/a

Gretchen Scott Designs

DEFENDANTS

Barbara Gerwit, Textile Center, Inc., and KB

Sales

Corp.

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER

Reed Smith LLP

599

Lexington

Avenue, 28th Floor, NewYork, NewYork 10022

(212)521-5400

ATTORNEYS (IF KNOWN)

f. f

(C

-

CAUSE OF ACTION (CITE THE U.S.CIVIL STATUTE

UNDER

WHICH

YOU

ARE

FILING

(DO NOT

CITE JURISDICTIONAL

STATUTES UNLESS DIVERSITY)

1 1

aHbwb*C/

a

briePstatementofcausq

a l s t a t u t e s un l e s s divers i ty)

U.S. Copyright Act, 17U.S.C. 101,etseq.

Has

this action,

case, or proceeding, or one

essentially the

same been

previously filed

in SDNY at

any

time?

NdZVesOjudge Previously

Assigned

Ifyes,

was this case Vol.

Invol.

Dismissed. No Yes If yes, give date.

ISTHISAN INTERNATIONAL ARBITRATION CASE?

PLACEAN[x]INONEBOXONLY

TORTS

No

0

Yes

NATURE

OF

SUIT

PERSONAL

INJURY

[ ] 367 HEALTHCARE/

PHARMACEUTICAL PERSONAL

INJURY/PRODUCT

LIABILITY

[ ] 365 PERSONALINJURY

PRODUCT

LIABILITY

[ ] 368 ASBESTOSPERSONAL

INJURY

PRODUCT

LIABILITY

PERSONALPROPERTY

[ ] 370 OTHER FRAUD

[ ] 371 TRUTH INLENDING

CONTRACT

PERSONAL

INJURY

[ 1110

INSURANCE

[ )310 AIRPLANE

[

]120

MARINE

[ ] 315 AIRPLANEPRODUCT

I ]130

MILLER

ACT

LIABILITY

[ 1140

NEGOTIABLE

I I 320 ASSAULT,LIBEL&

INSTRUMENT

SLANDER

[ 1150

RECOVERY

OF

[ I330 FEDERAL

OVERPAYMENT

&

EMPLOYERS

ENFORCEMENT

LIABILITY

OF JUDGMENT

( J340 MARINE

[ ]151

MEDICARE ACT

[ J 345 MARINE PRODUCT

i

1152

RECOVERY OF

LIABILITY

DEFAULTED

[ I 350 MOTORVEHICLE

STUDENT LOANS

[ ]355 MOTOR

VEHICLE

(EXCLVETERANS)

PRODUCT

LIABILITY

I 1153

RECOVERY OF

[ J360 OTHER PERSONAL

OVERPAYMENT

INJURY

OF VETERAN S

[ ] 362 PERSONAL INJURY-

BENEFITS MED MALPRACTICE

I 1160

STOCKHOLDERS

SUITS

[ )190 OTHER

CONTRACT

[ 1195

CONTRACT

PRODUCT

ACTIONS UNDERSTATUTES

LIABILITY

[ ]196 FRANCHISE

CIVIL RIGHTS

[ J 440 OTHER

CIVIL

RIGHTS

REAL

PROPERTY

(Non-Prisoner)

I 1441 VOTING

I

1210

LAND

[ ] 442 EMPLOYMENT

CONDEMNATION

[ ]443 HOUSING/

[

]220

FORECLOSURE

ACCOMMODATIONS

[

]230

RENT

LEASE

&

[ J445 AMERICANSWITH

EJECTMENT

DISABILITIES -

I 1240

TORTS

TO LAND

EMPLOYMENT

1

]245

TORT PRODUCT

[ J446 AMERICANS WITH

LIABILITY

DISABILITIES

-OTHER

[

[290

ALL

OTHER

REAL PROPERTY

[ ]448 EDUCATION

FORFEITURE/PENALTY

[ ]625 DRUGRELATED

SEIZURE

OF

PROPERTY

21

US C

881

( I690 OTHER

Checkifdemanded incomplaint:

CHECK IF THIS IS A CLASS ACTION

UNDER F .R .C .P .

23

[ I 380 OTHER PERSONAL

PROPERTY DAMAGE

[ ] 385 PROPERTY

DAMAGE

PRODUCT

LIABILITY

PRISONER

PETITIONS

( ]463 ALIENDETAINEE

[ ]510 MOTIONSTO

VACATE SENTENCE

28

USC 2255

[ ] 530 HABEASCORPUS

I I535 DEATH PENALTY

[ I540 MANDAMUS&OTHER

PRISONER

CIVIL

RIGHTS

[ ) 550

CIVIL

RIGHTS

[ I555 PRISON CONDITION

I560

CIVIL

DETAINEE

LABOR

I ] 710 FAIRLABOR

STANDARDS ACT

[ I 720 LABOR/MGMT

RELATIONS

( ] 740 RAILWAY LABOR ACT

[ I 751 FAMILYMEDICAL

LEAVEACT (FMLA)

[ J790 OTHER LABOR

LITIGATION

[ ]791 EMPLRET INC

SECURITY ACT

IMMIGRATION

( ] 462 NATURALIZATION

APPLICATION

[ ]465 OTHER

IMMIGRATION

ACTIONS

CONDITIONS

OF

CONFINEMENT

&

Case No .

ACTIONS

UNDER STATUTES

BANKRUPTCY

[ J422 APPEAL

28

USC

15 8

[ ]423 WITHDRAWAL

28 USC

157

PROPERTY

RIGHTS

[XI 820 COPYRIGHTS

[ J830 PATENT

I 1

84 0

TRADEMARK

SOCIAL SECURITY

[ ]861 HIA(1395ff)

[ J862 BLACKLUNG(923)

[ 1863 DIWC/DIWW(405(g))

[ J864 SSID TITLE XVI

[ ] 865 RSI (405(g))

FEDERAL TAX

SUITS

[

1870

TAXES (U.S. Plaintiffor

Defendant)

[ 1871 IRS-THIRDPARTY

26 US C

7609

OTHER

STATUTES

( J375 FALSECLAIMS

( J400 STATE

REAPPORTIONM

[ ]410 ANTITRUST

[ j

430

BANKS &BANKIN

[ I 450 COMMERCE

[ ]460 DEPORTATION

I I470 RACKETEERINF

ENCED

&

CORR

ORGANIZATION

(RICO)

I ]480 CONSUMER CRE

[ I490 CABLE/SATELLI

[ J850 SECURITIES/

COMMODITIES/

EXCHANGE

1890 OTHERSTATUTO

ACTIONS

]891

AGRICULTURAL

A

]893 ENVIRONMENTA

MATTERS

]895 FREEDOM OF

INFORMATION A

I 896 ARBITRATION

I 899 ADMINISTRATIV

PROCEDURE

ACT/RE

APPEAL OF AGENCY

[ ) 950 CONSTITUTION

STATE STATUTES

DEMAND $

OTHER

DO

YOULCLAJM

THIS CASE IS RELATED TO A

CIVIL

CASE NOW PENDING INS.D.N.Y

JUDGE DOCKET NUMBER

Check YES onlyifdemandedincomplaint

JURY

DEMAND:

DYES

EjNO

NOTE: You

must

also submit at the time offilingthe

Statement

of

Relatedness

form (Form


2/17

PLACEAN

x

INONEBOXONLY

ORIGIN

S1 Original D 2 Removed from 3 Remanded 4 Reinstated or 5 Transferred from Q 6 Multidistrict Q 7Appeal to D

Proceeding

stateCourt from

Reopened Specify

District) Litigation

g^Jud

[~J

a.

all parties represented

Appellate

Judgment

| | b. At

least

one

party is pro se.

PLACEAN x INONEBOXONLY BASIS

OF

JURISDICTION

IF

DIVERSITY INDIC TE

1 U

S.

PLAINTIFF

2

U.S. DEFENDANT

\E\

3

FEDERAL

QUESTION

Q4

DIVERSITY

CITIZENSHIP ELOW

(U.S. NOT A PARTY)

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES

ONLY)

(Place an [X] inone boxforPlaintiff and one box for Defendant)

PTF DEF PTF DEF PTF DE

CITIZEN

OF THIS

STATE [11 [11

CITIZEN

OR SUBJECT OF A []3[]3

INCORPORATED

andPRINCIPAL

PLACE []5 []5

FOREIGN COUNTRY OF BUSINESS INANOTHER STATE

CITIZEN

OF ANOTHER STATE [ ]2 [ ]2 INCORPORATED orPRINCIPAL PLACE [ ] 4 [ ] 4 FOREIGN

NATION

[ ]6 [ ]

OF BUSINESS

IN THIS STATE

PLAINTIFF(S)

ADDRESS(ES) AND

COUNTY(IES)

DEFENDANT(S) ADDRESS(ES) ANDCOUNTY(IES)

DEFENDANT(S) ADDRESS UNKNOWN

REPRESENTATION IS HEREBY

MADE

THAT, ATTHISTIME, I

HAVE

BEEN

UNABLE,

WITH REASONABLE DILIGENCE, TOASCERTAIN

RESlbENCE

ADDRESSES

OF THE

FOLLOWING

DEFENDANTS:

Check one: THIS ACTION SHOULD EASSIGNED TO:

WHITE PLAINS [x] MANHATTAN

(DONOTcheck either box ifthis a PRISONERPETITION/PRISONER

CIVIL

RIGHTS

COMPLAINT.)

DATE

12/23/2014

SIGNATURE OFjOTTORNEY

OF

RECORD ADMITTED TO PRACTICE IN THIS DISTRICT

Magistrate Judge is to be designated by the Clerk ofthe Coiiftr-;

Magistrate Judge is so Designated.

Ruby J. Krajick, Clerk of Court by Deputy Clerk,

DATED

.

UNITED STATES DISTRICT

COURT

(NEW YORK SOUTHERN)

S/ [X

YES (DATE ADMITTED Mo.OJ Yr. 2011

)

RECEIPT*

l

Attorney

Bar

Code

PS0304


3/17

UNITED STATES DISTRICT COURT i / i^ u_^ ;

SOUTHERN DISTRICT OF NEW

YORK

GRETCHEN

SCOTT

LLC d/b /a

GRETCHEN

SCOTT

DESIGNS,

Plaintiff,

BARBARA GERWIT, TEXTILE CENTER,

INC.,

KB SALES CORP.,

Defendants .

v-f - J

iU

---

^

COMPLA INT

Plaintiff Gretchen Scott LLC d/b/a Gretchen Scott Designs ( Gretchen Scott Designs or

Plaintiff), by and through its attorneys, Reed SmithLLP,as and for its complaint against

defendants Barbara Gerwit, Textile Center, Inc., and KB Sales Corp. (collectively,

Defendants ), hereby alleges as follows:

NATURE OF

THE

ACT ION

1. Plaintiff brings this action for injunctive reliefand damages resulting from

Defendants' flagrant infringement of Plaintiffs registered copyrights in two distinctive fashion

designs.

2. Plaintiff is an internationally recognized fashion designer who is famous for its

original lines of women's resortwearclothing and accessories. These fashion designs are sold

throughout the world, both at Plaintiffs own brick-and-mortar and online stores, as well as at

exclusive boutiques. Plaintiffs ability to exclusively offer these designs to its customers is

crucial to Plain t i f fs success.

3. Defendants, in an attempt to illegally profit of f of two of Plaintiffs most

successful tunic designs, have manufactured fabric and garments bearing an almost exact copy of

two of

Plaintiff

s proprietary designs, and have marketed and sold those products to others in the


4/17

fashion market and the public.

4. Defendants' blatant and willful infringement

of

Plaintiffs registered copyrights in

its proprietary fashion designs haveresulted in significant damage to Plaintiff, as alleged herein.

PART IE S

5. PlaintiffGretchen Scott LLC d/b/a Gretchen Scott Designs is a limited liability

corporation dulyorganized andexisting underthe lawsof the StateofNew

York,

withoffices

located at 216 Washington Street, Mt. Vernon,

New

York 10553.

6. Upon informationand belief, defendant Barbara Gerwit ( Ms. Gerwit ) is an

individual residing at 425 East 10th Court, Hialeah, Florida 33010.

7. Upon information and belief, defendant Textile Center, Inc. is a corporation

registered underthe laws of the stateof Florida, and havinga principal placeof business located

at 6073

Northwest

167th Street,

Suite C-6,

Miami,

Florida

33015.

8. Upon information and belief, defendant KB Sales Corp. is a corporation

registeredunder the laws of the state of Florida, and having a principal place ofbusiness located

at 7000 Island Boulevard, Apartment 903, Aventura, Florida 33160.

JUR ISD IC TION AND

VENUE

9. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.

1331 and the Copyright Act, 17 U.S.C. 101, et seq.

10. Defendants are subject to the personal jurisdiction of this court, and venue is

proper pursuant to 28 U.S.C. 1391(b),because, upon information and belief, Defendants do

extensive business within this District, including the sale

of

the infringing fashion designs.

F A CTU A L B AC KGROUND

11. Gretchen Scott Designs is a leading fashion designer and international distributor

of

women's clothing and accessories employing unique and proprietary designs. Since its


5/17

founding in 2001, Gretchen ScottDesigns has expanded to threededicated retail locations in

Jupiter, Florida, Southampton, New York, andNantucket, Massachusetts, as well as an

extremely successful onlineretail store. Its designs are also soldat more than 1,000 unaffiliated

stores throughout the world.

12. Like Plaintiff, Defendants sell their own line ofwomen s clothing under the trade

name, Barbara Gerwit, through their online store and in various unaffiliated retail stores

globally.

Defendants Willfully and latantly Infringes on Plaintiffs opyright

13. Two ofPlaintiffs most popular and best-selling designs are its Coral Perfection

and

Reef

Tunics (together, the Gretchen Scott Designs' Tunics ).

14. The fabric designs and decorations of the Coral Perfection and ReefTunics are

protected by the Copyright Act, 17U.S.C. 101.

15. OnAugust 13,2014, Plaintiff obtained a federal copyright registration for the

Coral Perfection Tunic design. A copy of the Certificate

of

Registration, bearing Registration

Number

VA

1-917-704 is

annexed

as

Exhibit

A.

16. OnAugust 13, 2014, Plaintiff obtained a federal copyright registration for the

ReefTunic design. A copy of the Certificate ofRegistration, bearing Registration Number VA

1-917-731 i s annexed as

Exhibit

B.

17. Upon information and belief, Defendants have been marketing and selling tunics

containing designs which are substantially similar to Gretchen Scott Designs' Tunics (the

Infringing Tunics ). Photographs showing the Gretchen Scott Designs' Tunics (left) next to the

Infringing Tunics (right) are annexed hereto as Exhibit C.

18. On or around September 25, 2014, Plaintiffsent a letter to defendant Barbara


6/17

Gerwit demanding that she immediate

cease

and desist from any further sales ofthe Infringing

Tunics and immediately providean accounting of all purchases, inventory and salesof the

infringing goods. A copy of the letter, dated

September

25,

2014,

is annexed hereto as Exhibit

D.

19. To date, Ms. Gerwit has not responded to Plaintiffs cease and desist letter.

F IR ST CAU S E OF ACT ION

(Copyright Infringement

of

Gretchen Scott Designs Coral Perfection Tunic)

20. Plaintiffincorporates by reference all of the foregoing allegations.

21. The designof Gretchen ScottDesigns' Coral PerfectionTunic is the subjectof a

validCopyright Registration, obtainedprior to the filingof this Complaint. SeeExhibitA.

22. Defendants have, with willful disregard

of

Plaintiffs rights under the Copyright

Act, wrongfullyobtained, reproduced, and distributed Plaintiffs copyright-protectedCoral

Perfection Tunic fashion design.

23. Upon information and belief,Defendants havemadeand will continueto make

substantial profits and gains to which they are not entitled in law or equity.

24. As a result of Defendants' infringement of Plaintiff s exclusive rights under the

Copyright Act, Plaintiff is entitledto statutory damages pursuantto 17U.S.C. 504;and, as a

result of the clearly willful and intentional nature of Defendants' infringement, Plaintiff is also

entitled to the maximum statutory damages, including punitive damages, and recovery of its

attorneys' fees and costs.

25. Alternatively, as a result

of

Defendants' infringement of Plaintiff s exclusive

rights under the Copyright Act, Plaintiff is entitled to actual damages according to proof as well

as an accounting and recovery

of

Defendants' revenues and profits obtained by or through such

infringement.


7/17

26. As a result of the Defendants' infringementof Plaintiffs exclusive rights under

theCopyright Act, Plaintiffis also entitled to injunctive reliefprohibiting Defendants

from

further

suchinfringement, andordering Defendants to destroy all reproductions of the infringing

products made anddistributed in violation of Plaintiffs exclusive rights.

S ECOND CAUSE OF ACT ION

(Copyright Infringement of Gretchen Scott Designs ReefTunic)

27. Plaintiff incorporatesby reference all of the foregoing allegations.

28. The design of Gretchen ScottDesigns' Reef Tunic is the subject of a valid

Copyright

Registration, obtained prior to the

filing

of thisComplaint. SeeExhibit B.

29. Defendants have, with willful disregard ofPlaintiffs rights under the Copyright

Act,

wrongfully obtained, reproduced, anddistributed Plaintiffs copyright-protected ReefTunic

fashion design.

30. Uponinformation and belief, Defendants havemadeandwill continue tomake

substantial profits and gains to which they are not entitled in law or equity.

31. As a result

of

Defendants' infringement

of

Plaintiffs exclusive rights under the

Copyright Act,Plaintiffis entitled to statutory damages pursuant to 17U.S.C. 504;and, as a

result of theclearly willful and intentional nature of Defendants' infringement, Plaintiffis also

entitled to the maximum statutory damages, including punitive damages, and recoveryof its

attorneys' fees and costs.

32. Alternatively, as a result ofDefendants' infringement of Plaintiffs exclusive

rights under theCopyright Act,Plaintiffis entitled to actual damages according to proofas well

as an accountingand recoveryof Defendants' revenues and profits obtained by or through such

infringement.

33. As a result of the Defendants' infringement of

Plaintiff

s exclusive rights under


8/17

theCopyright Act, Plaintiffis alsoentitled to injunctive reliefprohibiting Defendants from

further

such infringement, and

ordering

Defendants to destroy all reproductions of the infringing

products

made

anddistributed in violation of Plaintiffs exclusive rights.

PRA YE R

FOR

REL IEF

WHEREFORE, Plaintiff respectfullyrequests that judgment be entered in its favor and

against the Defendants as follows:

1. For an injunction, pursuant to 17 U.S.C. 502 and 503, and 15U.S.C 1116,

providing:

A. Defendants, including any and all

of

its subsidiaries, affiliates, agents,

employees, successors-in-interest, or assigns, shallbe and hereby is enjoined

from infringingPlaintiffs copyrights in the Coral PerfectionTunic and Reef

Tunic designs, except pursuant to a lawful license or with the express authority of

Plaintiff.

B. Defendants shall also, within two weeks

of

the entry

of

this order, recall

and have destroyed each and every unit of their Infringing Tunics currently in the

marketplace.

2. For statutory damages, pursuant to 17 U.S.C. 504(c), for each instance of

copyright infringement, taking into account the obvious willfulness of Defendants' infringement;

or, in the alternative, for actual damages and punitive damages in amounts to be determined at

trial but totaling not less than $1,000,000;

3. For Plaintiffs costs and reasonable attorneys' fees incurred in this action; and

4. For such other and further relief as the Court may deem just and proper.

6


9/17

Dated: New York, New

York

December 23 , 2014

REED SMITH LLP

>eter D. Raymond

Pamela L. Schoenberg

599 Lexington Avenue

New York, NY 10022

Telephone: 212.521.5400

Facsimile: 212.521.5450

Counsel

for

Plaintiff

Gretchen Scot t LLC d b a Gretchen Scott

Designs


10/17

Certificate ofRegistration

Thu.

Certificate

issued under

the

.seal of

the

Copyright

Office inaccordance with title 17, United States Code,

attests that registrationhas beenmade for the work

identified below.

The information on this

certificate

has

been

made a

part

ofthe Copyright Office records.

m

lA^it

ucu

4'tster

ofCopy

right

s,Un .

rates o'

lerica

Title

. , _

Title ofWork: Coral Perfection Tunic Fabric Design

Completion/Publication

Registration Number

V A 1 917 704

Effective date of

registration:

August 13,2014

Year of Completion: 2003

Date of 1st Publication: February 27, 2004

Nation of 1st Publication: UnitedStates

Au t ho r

B

Author:

Gretchen Scott LLC

Author Created:

2-D

artwork

Work made fo r hire: Yes

Citizen of: United

States

Copyright

claimant

Copyright Claimant: Gretchen Scott LLC

216

Washington Street,

Ml. Vernon,

NY,

10553, United States

Rights and

Permissions

Organization Name: Reed Smith, LLP

Name: PeterJ). Raymond

Email:

[email protected]

Address: 599 Le\snp.on Avenue

New York.

NTY

10022 United States

Telephone:

212-521

Certif ication

Name: Peter D. Raymond

Date: August 13,2014

Applicant's Tracking Number: 506721.60001

Page


11/17

Certificate

of

Registration

O-

/, '

:-..*s% ' *

X '

'ITits Certificate issued 'in^er the smi of the Copyright

Office in a

t

n n a le

ro>- the work

identified be'o\ T lie

*

1L01 co.tb.i-. certificate has

beenmade a pait ut th . C


12/17

G r e tc h en S c ot t Designs Tunics

The Coral Perfect ion Tunic

The Ree f Tunic

The I n fr i n gi n g T u n ic s


13/17

ReedSmith

Peter

D. Raymond

Direct

Phone:

+1

212

549

0364

Email: [email protected]

September 25, 2014

Via Federal

Express

and

Electronic Mail ([email protected])

Barbara Gerwit

425 E

10th Ct

Hialeah,FL,

33010-5152

Dear Ms.

Gerwit :

Reed

Smith

l ip

599 Lexington Avenue

New

York, NY

10022-7650

Tei +1 212

52 1

5400

Fax +1

212

521 5450

reedsmith.com

We are attorneys for Gretchen Scott, LLC ( Gretchen Scott ) an international designer and distributor of

women's clothing and accessories employing unique and proprietary designs.

It has come to our client's attention that you are selling and/or distributing garments which infringe our

client's federally registered copyrights in its ReefTunic and Coral Perfection designs. Copies

of

your

infringing products and our client's copyrighted designs are set forth below:

Gretchen

Scott s

Reef

Tunic

(U.S. Copyright No. VA 1-917-731)

Your Infringing Product

NEW YORK LONDON HONG KONG

CHICAGO WASHINGTON.

D.C. BEIJING PARIS LOSANGELES SAN FRANCISCO PHILADELPHIA

SHANGHAI PITTSBURGH

HOUSTON

SINGAPORE MUNICH ABU DHABI PRINCETON . NORTHERN VIRGINIA WILMINGTON SILICON VALLEY DUBAI CENTURY CITY RICHMONO ATHENS^KAZAKHSTAN


14/17


15/17

Barbara

Gerwit

ReeuSlTlith

September

25,2014

Page 3

3. The total quantity

of

such garments and/or fabric which your company sold at any time

up to and including the present, and the identity of each and every wholesaler or retail

store that purchased such garments from you.

4. The total revenues and gross profits relating to the manufacture and sale

of

such garments

including a breakdown of the cost to manufacturing such garments and the revenues

generated from the sale.

We further demand that you immediately contact any and all customers to whom you have sold the

infringing garments to advise them of this claim and instruct them to remove any and all such garments

from sale. As stated above, any further sales which occur after your receipt of this notice will be further

evidence

of

intentional infringement subjecting your company to heightened damages under the

Copyright Act.

Lastly, we demand that you notify the undersigned within five (5) days of your receipt of this letter

confirming that you have taken, or are in the process

of

taking, all of these actions, including the

immediate stoppage

of

any and all sales

of

the infringing garments.

If

we do not receive your response

in the timeframe indicated, our client will take all appropriate action to enforce its rights.

This letter is written without prejudice to, or waiver of, any and all claims, rights and/or remedies

of

Gretchen Scott LLC, in fact or law, all ofwhich are expressly reserved.

SJncerely,

Peter D. Raymond

cc: Gretchen Scott, LLC


16/17

Certificate of Registration

,vsl-* >

L 7>

L_ **>,. ^

o

'fhts Certificate issuedunder the sea of the Copyright

Office in accordance with title

17,

United States Code,

atteststhat registration hasbeen madefor thework

identified below,

The

information civthis certificate has

beenmadea part of theCopyrightOffice records


17/17

Certificateof Registration

This Certificateissuedunder theseal of theCopyright

Office in

accordance

with title 17,

United States Code,

attests that registrationhasbeen made for the work

identified

below. The

information on this certificate has

been madea part ofthe Copyright Office records.

Tla^L

A-

^M

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