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NYSCEF DOC. NO. .1
RECEIVED NYSCEF: 02/14/2014
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
WORLD OF DISCOVERY DAY CAMP OF
QUEENS INC.,
Plaintiff,
-against-
LOREDANA JOHANSMEYER, EDWIN
JOHANSMEYER, DONNA JOHANSMEYER,
AND MICHELE BETTI,
SUMMONS
Index No.
Plaintiff designates New York
County as the place of trial.
Defendants.
C It) CO! (J
33D "6rd fJ-K:
Ny 1 (\J\( IOOOd-
To the above-named defendants:
Venue is based on the residence
of Defendants.
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer, or if the complaint is not served with this summons, to serve a notice of
appearance, on the plaintiff s attorney within twenty (20) days after the service of this summons,
exclusive of the day of service, or within thirty (30) days after service is complete if this
summons is not personally delivered to you within the State of New York. In case of your
failure to appear or answer, judgment will be taken against you by default for the relief
demanded in the complaint.
This is an action to obtain relief for defamation, tortious interference with actual and
prospective business relations, aiding and abetting, and injunctive relief.
Dated: February 13,2014
1017849\4 013390.0101
MOSES & SINGER LLP
By:
Jaso anales
C istina M. Gaudio
Attorn s for the Plaintiff
405 exington Avenue, 12'h Floor
Ne York, New York 10174
Tel: (212) 554-7800

.. _ ..... --. --_ .... - --......... ,- . ~ .... .... _,.- .. , ....... .- .. ,
NYSCEF DOC,. NO .. 2
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
WORLD OF DISCOVERY DAY CAMP OF
QUEENS INC.,
-against-
Plaintiff,
LOREDANA JOHANSMEYER, EDWIN
JOHANSMEYER, DONNA JOHANSMEYER,
AND MICHELE BETTI,
Defendants.
RECEIVED NYSCEF: 02/14/2014
VERIFIED COMPLAINT
Index No.
Plaintiff WORLD OF DISCOVERY DAY CAMP OF QUEENS ("Plaintiff' or the
"Camp"), for its complaint against Defendants EDWIN JOHANSMEYER, LOREDANA
JOHANSMEYER, DONNA JOHANSMEYER (collectively referred to herein as the
"Johansmeyer Defendants") and MICHELE BETTI ("Betti") (collectively, the "Defendants"),
alleges as follows:
NATURE OF ACTION
1. This is an action for defamation, tortious interference with actual and prospective
business relations, aiding and abetting the same, and injunctive relief. On December 1,2010,
Defendants Edwin Johansmeyer and Loredana Johnasmeyer, on behalf of themselves and their
son Anthony Johansmeyer, filed a lawsuit against the New York City Department of Education,
the City of New York, the Child Center of New York, Inc., and Plaintiff (hereinafter referred to
as the "Negligence Suit"), alleging, in part, that Anthony Johansmeyer was sexually assaulted
and abused on the premises of his public school, an after-school program and the Camp by an
individual named Joseph Denice.
2. During depositions in the Negligence Suit, Loredana Johansmeyer and Anthony
Johansmeyer each testified unequivocally that Anthony Johansmeyer was not sexually assaulted
1017849v4 013390.0101
or abused at the Camp, but instead, was sexually assaulted and abused by Joseph Denice at his
home, months prior to his attendance at the Camp.
3. Realizing that these admissions would prove fatal to their case, Anthony's parents
Edwin and Loredana Johansmeyer, through Michele Betti, Esq. ("Betti"), their attorney,
attempted to extort a settlement from the Camp. On January 2, 20I4, Betti sent an email to
counsel for the Camp stating that if the parties could not reach a settlement, the "[Johansmeyers]
are not going to live in silence anymore regarding this matter and will this spring and summer
under their First Amendment right warn other campers about the dangers of World of Discovery
Day Camp of Queens .... " A settlement was not reached and nine days later Defendants went
well beyond their threat: Rather than merely exercising "their First Amendment rights,"
Defendants began to actively deter parents from enrolling and re-enrolling their children in the
Camp through disseminating statements about the Camp that were false and defamatory by their
own prior sworn admissions. None of that is protected by the First Amendment or otherwise.
4. Specifically, on January 12,2014, Edwin and Loredana Johansmeyer and their
daughter Donna J ohansmeyer appeared at an "open house" hosted by the Camp for prospective
and returning campers and their parents. At that open house they distributed to parents a flyer
(attached hereto as Exhibit A), drafted upon information and belief by their lawyer Betti,
containing false and defamatory statements about the Camp. For instance, the very first sentence
of the flyer distributed by these Defendants falsely stated "We are parents of a child who was
molested at World of Discovery Day Camp of Queens by a counselor, Joseph Denice (who
worked here roughly from 2003 through 2009)." On February 9, 2014, the Johansmeyer
Defendants appeared again at an open house hosted by the Camp and distributed the same flyer.
1017849v4 013390.0101
2
Upon information and belief, Defendants have also posted and continue to post negative reviews
containing false and defamatory statements about the Camp on the internet.
5. The Camp has demanded that Defendants cease and desist from disseminating
false and defamatory statements about the Camp and from otherwise interfering with the Camp's
business. Defendants have failed and refused to do so, and have promised to continue their
crusade to destroy the Camp's business and coerce it into a settlement by appearing at future
open houses to continue distributing the flyers.
THE PARTIES
6. Plaintiff is a non-profit corporation, incorporated under the laws of New York,
with its principal place of business in Queens, New York. The Camp has provided a summer
day-camp to residents of Queens for over 30 years and has never before been accused of
allowing a child to be sexually abused or molested on its premises.
7. Defendant Loredana Johansmeyer is an individual residing at 45-25 Utopia
Parkway, Flushing, New York.
8. Defendant Edwin Johansmeyer is an individual residing at 45-25 Utopia Parkway,
Flushing, New York.
9. Defendant Donna Johansmeyer is an individual residing at 45-25 Utopia Parkway,
Flushing, New York.
10. Defendant Michele Betti is an attomey duly licensed to practice law in this State
with an office located at 110 Wall Street, II th Floor, New York, New York. She also maintains a
California office located at 1732 Knoll Field Way, Encinitas, Califomia 92024.
1017849v4 013390.0101
3
JURISDICTION
11. Jurisdiction within the Supreme Court of the State of New York is appropriate as
the acts complained of took place within the State and the parties reside and/or regularly conduct
business in the State.
12. Venue within Queens County is appropriate pursuant to CPLR 503 as at least
one of the parties to this action resides in Queens County.
FACTS COMMON TO ALL CAUSES OF ACTION
13. On December 1,2010, Defendants Loredana Johansmeyer and Edwin
Johansmeyer, on behalf of themselves and their son Anthony Johansmeyer, filed the Negligence
Suit alleging, amongst other things, that Anthony Johansmeyer was sexually assaulted and
abused at his public school, an after-school program and the Camp by an individual named
Joseph Denice.
14. During depositions in that lawsuit, Defendant Loredana Johansmeyer and her son
Anthony Johansmeyer testified unequivocally under oath that Anthony Johansmeyer was not
sexually assaulted or abused at the Camp. Instead, he was molested by Joseph Denice at his
home, prior to his attendance at the Camp.
15. Anthony Johansmeyer's sworn testimony was as follows (emphasis added):
Q: Where did the first body scan take place?
A: In my room.
Q: When was the next time he was doing these body scans on you?
A: A couple of days later, a couple of days or a week. It was the same thing.
Q: Did he come over after school again?
A: Yeah, he only came over after school and just like a little bit after school
sometimes got out a little late, 6:00 or 7:00. And when he came over on
weekends, and the first couple of scans were the same thing ....
Q: Do you know how many times in total he did that?
A: Five, I think, yeah, that's it.
1017849v4 013390.0101
4
Q: Five times in your home?
A: Yes.
Q: Did [Joseph Denice] ever touch you in a way that made you uncomfortable at
the day camp?
A: No, just friendly touches (indicating), holding my shoulder, going like, quick
massage (indicating).
Q: Did Joseph Denice perform any body scans of you during that summer?
A: No, not during the summer.
Q. SO, during the time period there which you attended the camp, there were no
body scans performed, correct?
A: Yes.
Q: You testified earlier that Joseph Denise did not touch you inappropriately
while you were at the day camp; is that correct?
A: Yes.
16. Loredana Johansmeyer's sworn testimony was as follows (emphasis added):
Q. Previously you mentioned that the body scans took place between April and
June of2009 [prior to plaintiff's attendance at the Camp]; is that correct?
A. Yes.
Q. That was the only time Joseph Denice had inappropriately touched
Anthony; is that correct?
A. As far as I know, yes.
Q. As far as you know, that is the only time period where any sexual abuse
occurred?
A. Yes.
17. Realizing that these admissions proved fatal to their case, Edwin Johansmeyer and
Loredana Johansmeyer, upon information and belief through Betti, their attorney, attempted to
extort a settlement from the Camp. On January 2, 2014, Betti sent an email to counsel for
Plaintiff requesting a certain sum in settlement and threatened to harm the Camp's business if it
did not comply. The e-mail stated:
Please pass on to [the Camp's principal] that my clients are not
going to live in silence anymore regarding this matter and will this
spring and summer under their First Amendment right warn other
campers about the dangers of World of Discovery Day Camp of
Queens ....
1017849v4 013390.0101
5
18. Thereafter, upon information and belief, Defendants drafted a flyer containing
false and defamatory statements about the Camp (Ex. A). Amongst other false and defamatory
statements contained in the flyer, the very first sentence states that: "We are parents of a child
who was molested at World of Discovery Day Camp of Queens by a counselor, Joseph Denice
(who worked here roughly from 2003 through 2009)." At all material times hereto, Defendants
knew this statement to be false.
19. Upon the Camp's refusal to pay the requested settlement sum, nine days after the
e-mail threat was sent, on January 12,2014, the Johansmeyer Defendants attended an open
enrollment meeting hosted by the Camp at 141-01 32
nd
Avenue, Flushing, New York,
approached the Camp's potential customers (parents considering whether to enroll or re-enroll
their children at the Camp for the summer of2014), distributed the defamatory flyer (Ex. A) and,
upon information and belief, made knowingly false and defamatory oral statements to those
potential customers.
20. On January 17,2014, Plaintiff, through counsel, sent a letter to Betti demanding
that she and the J ohansmeyer Defendants cease and desist from disseminating false and
defamatory information about the Camp.
21. However, on February 9, 2014, again the Johansmeyer Defendants stood outside
of the Camp's open house located at 141-01 32
nd
Avenue, Flushing, New York, approached
parents who were potential customers of the Camp, distributed the defamatory flyer (Ex. A) and,
upon information and belief, made knowingly false and defamatory oral statements to potential
customers of the Camp.
22. Upon information and belief, Defendant Betti participated in her clients'
interference with the Camp's business, by drafting or assisting in the drafting of the defamatory
1017849v4 013390.0101
6
flyer (Ex. A) in an effort to coerce the Camp into offering the Johansmeyer Defendants a higher
settlement amount.
23. Defendants' conduct has directly resulted in damage to Plaintiff s reputation in
the community and has caused the loss of business as potential customers have refused to enter
the open houses and/or enroll their children in the Camp as a result of reading the flyer anlor
upon information and belief, speaking with the Defendants (or others who had spoken to the
Defendants).
24. The Johansmeyer Defendants have stated that they plan to attend future open
houses held by the Camp to pass out additional copies of the flyer and to continue to make
defamatory oral statements to actual and prospective customers ofthe Camp for the purpose of
putting the Camp out of business.
25. Upon information and belief, on or about January 28, 2014, Loredana
Johansmeyer and/or other Defendants published a false and misleading statement about the
Camp in a review on Google with the intent of harming the Camp's reputation and business.
Among the false and/or misleading statements that were published were the statements:
"Discovery Day Camp had a counselor who was convicted of child molestation ... This counselor
was providing alcohol and cigarettes to a 12 year old - others witnessed but did not say a
word .... WTF is wrong with the parents that keep sending their children there."
26. The false and defamatory Google review has resulted in damage to Plaintiffs
reputation and business.
27. Upon information and belief, between January 2014 and the present, Defendants
have made numerous oral and written communications to various third-parties, including without
1017849v4 013390.0101
7
limitation falsely stating or implying that the Camp engaged in improper or illegal conduct, or
otherwise imputing wrongful conduct to the Camp.
28. Unless enjoined, the Johansmeyer Defendants' tortious interference will continue
to result in immediate and irreparable injury, loss, or damage to the Camp, for which there is no
adequate remedy at law, including, but not limited to, loss of its business, loss of its goodwill,
loss of its client contacts, and loss of its reputation.
29. The Johansmeyer Defendants' statements concerning the Camp as aforesaid are
defamatory per se, as they tend to expose the Camp to hatred, contempt or aversion, or to induce
an evil or unsavory opinion of the Camp in the minds of a substantial number ofthe members of
the community, and tend to injure the Camp's business.
30. Fmiher, on their face and in context, the Johansmeyer Defendants' statements
state and imply, through innuendo and context, that the Camp engaged in unlawful and improper
conduct, when, in truth and in fact, this was untrue.
First Cause of Action
(Defamation Against the Johansmeyer Defendants)
31. Plaintiff repeats and realleges each and every allegation contained in paragraphs I
through 30 of the Complaint as if set forth fully herein.
32. The Johansmeyer Defendants published false statements about Plaintiff to third-
parties, with knowledge or reckless disregard as to the falsity, or did so negligently or in a
grossly negligent manner, which caused actual injury to Plaintiff and prejudiced it in the eyes of
a substantial and respectable part of the community.
33. The Johansmeyer Defendants' statements conceming Plaintiff were false and
defamatory.
1017849v4 013390.0101
8
34. The Johansmeyer Defendants' statements concerning Plaintiff were defamatory
per se because they impute conduct adversely reflecting on Plaintiffs fitness to conduct its
business.
35. The Johansmeyer Defendants published the false, defamatory statements in
written form to Plaintiff's customers and potential customers.
36. Upon information and belief, the Johansmeyer Defendants published the false,
defamatory statements in oral form to Plaintiff's customers and potential customers.
37. As a proximate result of the Johansmeyer Defendants' conduct, Plaintiff has
sustained and will continue to sustain substantial damages in an amount to be proven at trial.
38. The acts by the J ohansmeyer Defendants as described above were willful,
malicious and done with evil intent. As such, Plaintiff is entitled to an award of exemplary and
punitive damages.
Second Cause of Action
(Tortious Interference with Prospective
Business Relations Against the Johansmeyer Defendants)
39. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 38 of the Complaint as if fully set forth herein.
40. Plaintiff has a reasonable expectation of entering into business relations with its
customers.
41. Plaintiff has a reasonable expectation that its relationship with its customers will
continue.
42. At all times mentioned herein, the Johansmeyer Defendants were aware that
Plaintiff had relationships with its customers and were aware of Plaintiff's expectation that those
relationships would continue.
1017849v4 013390.0101
9
43. Despite the Johansmeyer Defendants awareness of these relationships, they
intentionally and maliciously interfered with those relationships.
44. The Johansmeyer Defendants acted with the sole purpose of causing harm to
Plaintiff.
45. The Johansmeyer Defendants used wrongful means to interfere with Plaintiffs
business.
46. As a proximate result of the Johansmeyer Defendents' conduct, Plaintiff has
sustained and will continue to sustain substantial damages in an amount to be proven at trial.
47. The acts by the J ohansmeyer Defendants as described above were willful,
malicious and done with evil intent. As such, Plaintiff is entitled to an award of exemplary and
punitive damages.
Third Cause of Action
(Tortious Interference with Actual Business
Relations Against the Johansmeyer Defendants)
48. Plaintiff repeats and realleges each and every allegation contained in paragraphs I
through 47 of the Complaint as iffully set forth herein.
49. Plaintiff had advantageous business relationships with identifiable third-parties
creating actual and prospective legal rights in Plaintiff.
50. The Johansmeyer Defendants had knowledge of those relationships.
51. By engaging in their conduct as aforesaid, the Johansmeyer Defendants
intentionally and without justification, tortiously interfered with those relationships, causing
damages to Plaintiff.
1017849v4 013390.0101
10
52. Further, the Iohansmeyer Defendants failed to exercise ordinary care and ignored
the foreseeable harm to Plaintiff, and accordingly, they intentionally and/or negligently
interfered with Plaintiff s relationships, causing damages to Plaintiff.
53. As a proximate result of the Iohansmeyer Defendants' conduct, Plaintiff has
sustained and will continue to sustain substantial damages in an amount to be proven at trial.
54. The acts by the Iohansmeyer Defendants as described above were willful,
malicious and done with evil intent. As such, Plaintiff is entitled to an award of exemplary and
punitive damages.
Fourth Cause of Action
(Aiding and Abetting Against Defendant Betti)
55. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 54 ofthe Complaint as iffully set forth herein.
56. The Johansmeyer Defendants have defamed the Camp and have tortiously
interfered with the Camp's actual and prospective business relations.
57. Upon information and belief, Defendant Betti had knowledge of the torts
committed by the Iohansmeyer Defendants against the Camp.
58. Upon information and belief, Defendant Betti substantially assisted the
J ohansmeyer Defendants in committing their tortious acts against the Camp.
59. As a proximate result of Defendant Betti's conduct, Plaintiff has sustained and
will continue to sustain substantial damages in an amount to be proven at trial.
60. The acts by Defendant Betti as described above were willful, malicious and done
with evil intent. As such, Plaintiff is entitled to an award of exemplary and punitive damages.
Fifth Cause of Action
(Preliminary and Injunctive Relief Against the Johansmeyer Defendants)
1017849v4 013390.0101
11
61. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 60 of the Complaint as if fully set fOlih herein.
62. There is a likelihood that Plaintiff will succeed on the claims it has asserted
herein.
63. Plaintiff has asserted a clear right of interest that is in immediate need of
protection.
64. Plaintiff will suffer continuing irreparable harm if injunctive relief is not granted.
65. Unless the Johansmeyer Defendants are immediately enjoined from continuing to
interfere with Plaintiff's business as set forth above, Plaintiff will be immediately and irreparably
harmed by, among other things:
a. The loss of all or a substantial part of the goodwill associated with Plaintiffs
business;
b. Damage to Plaintiffs reputation; and,
c. The loss of an incalculable amount of customers.
66. Plaintiff is entitled to the entry of a Temporary Restraining Order, and
Preliminary and Permanent Injunctions prohibiting the Johansmeyer Defendants from (i)
disseminating flyers containing false and defamatory statements concerning Plaintiff; (ii)
appearing at or near Plaintiffs place of business for the purpose of defaming and disparaging
Plaintiff; and/or (iii) posting false and defamatory reviews concerning Plaintiffs business on the
internet
WHEREFORE, Plaintiff demands judgment against Defendants and each of them:
1017849v4 013390.0101
12
(l) On its First, Second and Third Causes of Action against the Johansmeyer
Defendants, damages in an amount to be determined at trial, including exemplary and punitive
damages;
(2) On its Fourth Cause of Action against Defendant Betti, damages in an amount to
be determined at trial, including exemplary and punitive damages;
(3) On its Fifth Cause of Action against the Johansmeyer Defendants, temporarily
and permanently enjoining and restraining the Johansmeyer Defendants from (i) disseminating
flyers containing false and defamatory statements concerning Plaintiff; (ii) appearing at or near
Plaintiff's place of business for the purpose of defaming and disparaging Plaintiff and interfering
with Plaintiff's business; and (iii) posting false and defamatory reviews concerning Plaintiff's
business on the internet;
(4) awarding it costs and expenses in this action, including attorney's fees; and,
(5) granting it such other relief as the Court deems just and proper.
Dated: February 13, 2014
1017849v4 013390.0101
13
MOSES & SINGER LLP
Attorneys for Plaintiff
istina M. Gaudio
405 L ington Avenue
Ne York, New York 10022
(2 2) 554-7800
please ho!:lp us protect the vulnerablel
We are parents of a child who was molested at World of Discovery Day Camp of Queens by a counselor, Joseph
Denice (who worked here roughly from 2003 through 2009).
We are here today because we are concerned about others who might be hurt or have been hurt by Denice,
especially those who may be suffering in shame, secrecy and self-blame.
For the past several years, we have tried to get World of Discovery Day Camp officials to publicly admit that our
child's allegations against Denice are credible. They have refused. Camp officiills have refused to turn over
their 'investigation report' to us despite numerous requests.
In December of 2013, Steve Bonomo, one of the directors of World of Discovery Day Camp admitted that
Denice, without telling us, wrote a check for our child's tuition. (It bounced twice.) We were never told about
this. Had we been told, we would have known something was wrong. (Why would a camp counselor be writing a
check for our child when we, his/her parents, had already done so?)
Denice was giving' cigarettes and alcohol to our child at the camp in Crocheron Parr< and cn an overnight trip to
Hershey Park. In addition, World of Discovery Day Camp had no protective measures In place to make sure
adult camp counselors, like Denice, were not sleeping in the same bed as the children on the overnight trips. As
a direct result of the negligence by camp officials, our child was abused.
Our fear is that there are other children and young adults who were hurt as kids by Denice and who are now
depressed, isolated, addicted, ashamed, and struggling. World of Discovery Day Camp's staff should be reaching
out to them, but are not. We want to find and help those children and young adults (men and women). Please
help us do this.
Here's what we are asking you to do:
--Please use every means possible - personal conversations, websites, emails.newsletters.mailings.
announcements, anything - to ask others about Denice. (It's a qUick conversation: "I've heard that Joseph
Denice has been accused of molesting boys and girls. Did you know him? Did he ever do anything to you?")
-Ask Directors Steve Bonomo and Paul Winter, Assistant Directors Richie Martinez, Steve Blum, and Jimmy
Rampula, and any other staff at World of Discovery Day Camp to post Denice's name on their website and
encourage other victims to come forward.
--Insist that World of Discovery Day Camp officials publicly disclose every credible report of child sex crimes they
receive, especially if the alleged predator hasn't been publicly exposed before as a likely molester.
These steps help keep kids safe. They help adults who are in pain to feel better. They are simple, inexpensive,
and could save someone's life.
Please, find the courage to do what's right. Ask current and former World of Discovery Day camp of Queens
staff, volunteers, alums of the camp, and parents about Denice.
(By the way, Denice was also a counselor at Adrien Block Intermediate School-iS 25 in Flushing, NY and in the
after-school program (Child Center of New York) at IS 25.)
Thank you.
Lori and Edwin Johansmeyer
Flushing, NY 11358
P.S. With us today are members of a support group called SNAP, the Survivors Network of those Abused by Priests
(SNAPnetwork.org). Please feel free to contact them, especially If you find anyone who saw, suspected or Denice's
r i"nnt::lrt 1:\vld C!r;h,:l"V ::tt j '=t 1 1.\ I:;,{\h.Q7Q[l l"If .nm\ Th.:tnk' \/nll
VERIFICATION
STATE OF NEW YORK
) 55.:
COUNTY OF NEW YORK )
Steven Bonomo. being sworn. states as tallows:
[am the Director of World Discovery Day Camp orOueens, a New York Corporation.
I have read the foregoing complaint and know the contents thereof; the same are true to
my knowledge, exccpt as to the matters therein alleged lIpon information and belief, which I
believe to be true.
I base this Verification on my own personal knowledge and my revicw of the documents
attached hereto.
Sworn to before me this
of February, 20 J 4

/.2::. Notary Public
1017849\'2 013390,0101
Michael Anthony Labruzzo
Notary Public, State of New York
No 01lA60B4606
in Nassau County
COmmJlHIJOn EXpirt1!i OeC;ember 09. 20 ! '/
14
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NYSCEF DOC. NO.3- RECEIVED NYSCEF: 02/14/2014
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SUPREME COURT OF THE STATE OF NEW YORK
____ _
-----------------------------------------------------)(
World of Discovery Day Camp of Queens,
Plaintiff( s )lPetitioner( s),
- against-
Loredana Johansmeyer et al.
Defendant( s )/Respondent( s).
------------------------------------------------------)(
Inde)( No. 701030/2014
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efile@courts.state.ny.us).
Dated: 2/14/14
____________ (Signature) _2_1_2-_5_54_-_7_80_0 _____ (phone)
_J_8_s_o_n_C_8_n_8_le_s ______ (Name)
_2-'1_2--'-5....:.5....:.4-_7_70-'-0'--____ (Fax)
_M_o_s_e_s_&_S_i--'n9"-e_r_L_L_P ____ (Firm) jC8n8Ies@mosessinger.com (E-mail)
_4_0_5_L_e_x_in...c9=-t_o_n_A_v_e_n_u_e ____ (Address)
New York, NY 10174-1299
Attorney(s) for ...:.P....:.18=icc n..;.:tiff"-_____ _
2/l1113
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