Amicus Curiae Brief of VLA for plaintiff Chapman Kelley

8/7/2019 Amicus Curiae Brief of VLA for plaintiff Chapman Kelley

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. c;\. Nos.08-3'701& 08- 3712 .'1\\\IN THE \.\P\Mniteb $tates (tourt of ppeals for tbe $ebentb (tirc

C \.

Chapman Kelley,PlaintifAppellant, Cross-Appellee

Chicago Park District;- Defendant-Appellee, Cross-Appellant.ON APPEAL FROM THE UNTED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF ILLINOISNO. 04-CV-07715THE HONORALE DAVID H. COAR

BRIEF OF 'VOLUNTEER LAWYERS FOR THE ARTS ASAMICUS CURIAE IN SUPPORT OF PLAINTIFF-APPELLANT'

PETITION FOR REHEARNG EN BANC

Sergio Mufioz Sariento (admission pending)Dena Bouchard (N admission pending)Anna Kadyshevich (N admiss-ion pending)VOLUNTEER LA WYRS FOR TH ARTS1 EaSt 53rd Street, 6th FloorNew York, New York 10022(212) 319-2787

George M. SandersLAW OFFICES OF GEORGE M. SANERS150 N. Michigan Ave., Suite 2800Chicago, Ilinois 60601(312) 462-0324

Hillel I. Paress (admssion pending)David LeichtmanROBINS , KALAN, MILLER & CIRESI L.L.P.601 Lexigton Avenue, SUite 3400New York, New York 10022(212) 980-7400

Counsel for Amicus Curiae Volunteer Lawyers for the Arts

March 21 2011


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CIRCUIT RULE 26.08-3701 & 08-3712

Chapman Kelley v. Chicago Park District

DISCLOSURE STATEMENT

, an attorney for a non-governental party or, or a private attorney representing a governent party, must furnish a disclosure statement providing the

1 and Fed. R. App. P. 26.be fied immediately following docketing; but, the disclosure statement must, response, petition, or answer in this court, whichever occursfie an amended statement to reflect any material changes in the required information. The textfront of the table of contents of the party s main brief. Counsel is required to

Nt A for any information that is not applicable if this form is used.PLEASE CHECK HERE IF ANY INFORMATION ON THIS FORM IS NEW OR REVISEDAND. INDICATE WHICH INFORMATION IS NEW OR REVISED.

name of every party that the attorney represents in the case (if the party is a corporation , you must provide thecorporate disclosure information required by Fed. R. App. P 26.1 by completing item #3):Volunteer Lawyers for the Arts

all law firms whose partners or associates have appeared for the part in the case (including proceedingsin the district court or before an administrative agency) or are expected to appear for the part in this court:Volunteer Lawyers for the ArtsRobins, Kaplan, Miller & Ciresi L.L.P.Law Offices of George M. Sanders

party or amicus is a corporation:i) Identify all its parent corporations , if any; and

NtAii) list any publicly held company that owns 10% or more of the party s or amicus , stock:

NtA

s Signatue:s Printed Name:

Date: March 22, 2011

Counsel a/Record for the above listed paries pursuant to Circuit Rule 3(d). Yes NoRobins , Kaplan , Miller & Ciresi L.L.P.601 Lexington Avenue, Suite 3400 , New York , New York 10022

212-980-7400er: 212-980-7499ax urn er:hiparness(grkmc.comal A ress:

rev. 01/08 AK


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CIRCUIT RULE 26.08-3701 & 08-3712

Chapman Kelley v. Chicago Park District

DmCLOSURE STATEMENT

To enable the judges to determine whether recusal is necessary or appropriate, an attorney for a non-governmental party or, or a private attorney representing a government party, must furnish a disclosure statement providing the1 and Fed. R. App. P. 26.immediately following docketing; but, the disclosure statement mustfiing of a motion , response , petition, or answer in this court, whichever occursin the required information. The texts main brief. Counsel is required toA for any information that is not applicable if this form is used.

PLEASE CHECK HERE IF ANY INFORMATION ON THIS FORM IS NEW OR REVISEDAND INDICATE WHICH INFORMATION IS NEW OR REVISED.full name of every party that the attorney represents in the case (if the part is a corporation, you must provide thecorporate disclosure information required by Fed. R. App. P 26. 1 by completing item #3):

Volunteer Lawyers for the Arts

all law firms whose partners or associates have appeared for the party in the case (including proceedingsin the district court or before an administrative agency) or are expected to appear for the part in this court:Volunteer Lawyers for the ArtsRobins , Kaplan, Miler & Ciresi L.L.P.Law Offices of George M. Sanders

the party or amicus is a corporation:i) Identify all its parent corporations , if any; and

NtAii) list any publicly held company that owns 10% or more of the party s or amicus ' stock:

N/A

s Signature:s Printed Name: Sergio

Date: March 22 , 2011

Counsel of Record for the above listed parties pursuant to Circuit Rule 3(d), Yes LX: No L .Volunteer Lawyers for the Arts1 East 53rd Street, 6th Floor , New York , New York 10022

(212) 319-2787urn er: Fax Number: 212.752.6575ssarmiento vlany.orgAd ress:

rev. 01108 AK


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CIRCUIT RULE 26.Appellate Court No: 08-3701 & 08-3712Short Caption: Chapman Kelley v. Chicago Park District

To enable the judges to determine whether recusal is necessary or appropriate , an attorney for a non-governmental party oramicus curiae, or a private ttorney representing a government party, must funish a disclosure statement providing thefollowing information in compliance with Circuit Rule 26. 1 and Fed. R. App. P. 26.

DISCLOSURE STATEMENT

The Court prefers that the disclosure statement be filed immediately following docketing; but, the disclosure statement mustbe fied within 21 days of docketing or upon the fiing of a motion , response, petition, or answer in this cour, whichever occursfirst. Attorneys are required to fie an amended statement to reflect any material changes in the required infonnation. The textof the statement must also be included in front of the table of contents of the party s main brief. Counsel is required tocomplete the entire statement and to use Nt A for any information that is not applicable if this form is used.

PLEASE CHECK HERE IF ANY INFORMATION ON THIS FORM IS NEW OR REVISEDAND INDICATE WHICH INFORMA nON IS NEW OR REVISED.(1) The full name of every party that the attorney represents in the case (if the party is a corporation , you must provide the

corporate disclosure information required by Fed, R. App. P 26. 1 by completing item #3):Volunteer Lawyers for the Arts

(2) The names of all law firms whose partners or associates have appeared for the party in the case (including proceedingsin the district court or before an admnistrative agency) or are expected to appear for the party in this court:Volunteer Lawyers for the ArtsRobins, Kaplan , Miler & Ciresi L.L.P.Law Offces of George M. Sanders

is ,a corporation:i) Identify all its parent corporations , if any; and

NtAii) list any publicly held company that owns 10% or more of the party s or amicus ' stock:

N/A

s Signature: Date: March 22 , 2011

Counsel of Record for the above listed parties pursuant to Circuit Rule 3(d), Yes NoLaw Offices of George M. Sanders150 N. Michigan Ave. , Suite 2800 , Chicago, Illnois 60601

312-624-7645one um er: Fax Number: 312-624-7701Add george.sandersfl(gearthlink.net- al ress:

rev. 01108


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CIRCUIT RULE 26.Appellate Court No: 08-3701 & 08-3712Short Caption: Chapman Kelley v. Chicago Park District

DffCLOSURE STATEMENT

To enable the judges to determine whether recusal is necessary or appropriate, an attorney for a non-governmental party oramicus curiae , or a private attorney representing a government party, must furnish a disclosure statement providing thefollowing information in compliance with Circuit Rule 26. 1 and Fed. R. App. P. 26.The Court prefers that the disclosure statement be filed immediately following docketing; but, the disclosure statement mustbe fied within 21 days of docketing or upon the filing of a motion , response, petition, or answer in this court, whichever occursfirst. Attorneys are required to fie an amended statement to reflect any material changes in the required information. The textof the statement must also be included in front of the table of contents of the party s main brief. Counsel is required tocomplete the entire statement and to use N/A for any information that is not applicable ifthis form is used.

PLEASE CHECK HERE IF ANY INFORMATION ON THIS FORM IS NEW OR REVISEDAND INDICATE WHICH INFORMATION IS NEW OR REVISED.(1) The full name of every party that the attorney represents in the case (if the party is a corporation , you must provide thecorporate disclosure information required by Fed. R. App. P 26. 1 by completing item #3):

Volunteer Lawyers for the Arts

(2) The names of all law firms whose partners or associates have appeared for the party in the case (including proceedingsin the district court or before an administrative agency) or are expected to appear for the party in this court:Robins , Kaplan , Miler & Ciresi L.L.P.Law Offices of George M. Sanders

(3) If the party or amicus is a corporation:i) Identify all its parent corporations, if any; and

N/Aii) list any publicly held company that owns 10% or more of the party s or amicus ' stock:

N/A

Attorney s Signature:Attorney s Printed Name: Hillel I. Parness

Date: March 21 2011

Please indicate if you are Counsel of Record for the above listed paries pursuant to Circuit Rule 3(d). Yes rx. No C--Address: Robins , Kaplan, Miler & Ciresi L.L.P.

601 Lexington Avenue, Suite 3400, New York , New York 10022212-980-7400one urn er: 212-980-7499ax urn er:hi parness (g rkmc.comMail Address:

rev. 01/08 AK


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TABLE OF CONTENTSPage

STATEMENT OF INTEREST OF AMICUS CURIAE .....................................,.........................SUMMAY OF ARGUMENT..................................................................................................... 1ARGUMENT................................................................................................................................. 21. THE PANEL' S ATTEMPT TO DISTINGUISH AMONGPROTECTABLE AND UNPROTECTABLE "LIVING" ART ISWITHOUT SUPPORT .................................................................................. ........ 2

II. WILDFLOWER WORKS IS FIXED FOR PURPOSES OF COPYRGHT ........WILDFLOWER WORKS IS A WORK OF AUTHORSHIP ............................... 4III.

IV. THE PANEL' S OPINION WOULD HAVE SEVERE CONSEQUENCESFOR VISUAL ARTISTS AND ARTS ORGANIZATIONS ................................ 5CONCLUSION.............................................................................................................................. 7


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TABLE OF AUTHORITIESPage

CasesBaltimore Orioles, Inc. v. Major League Baseball Players Ass

805 F.2d 663 (7th Cir. 1986) .............................................................................................. 7Bleistein v. Donaldson Lithographing Co.

188 V.S. 239 (1903)............... ........................ ....... ......................................................... 2MAl System Corps. v. Peak Computer, Inc.991 F.2d 511 (9th Cir. 1993) .............................................................................................. 4Statutes17 V. S. c. 9 1 06A............................................................................................................................ 2

Aricle Section 8 of the V. S. Constitution......Other Authorities1 Melvile B. Nimmer and David NimmerNimmer on Copyright 9 2.03(B) (Matthew Bender, Rev. Ed. 2010) .................................Bruce D. KurtzContemporary Ar 1965-1990 (1992) ................................................................................. 5Campbell Robertson

Want to Use My Suit? Then Throw Me Something, Y. Times , Mar. 23 , 2010................ 6Central Garden (Robert Irwin, 1997)......................................................................................... 6 , 7Gnaw (Janine Antoni, 1992)........................................................................................................... 6Puppy (Jeff Koons , 1992).................................. """'"'''''''''''''''''''''''''''''''''''''''''''''''''''''''' .''''''''''' 2All Things Considered: Mardi Gras Indians Seek to Copyright Costumes

(National Public Radio broadcast, Feb. 8 2011) .......................... ......................... 6Rosalind Krauss

Sculpture in the Expanded Field October, Spring 1979.................................................... 5Spiral Jetty (Robert Smithson, 1970).............................................................................................. 6The Library for the Birds, of Antwerp (Mark Dion, 1993) ............................................................. 6

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TABLE OF AUTHORITIES(continued)Page

S. Copyright OfficeCircular 66: Copyright Registrationfor Online WorksMay 2009, http://ww.copyright.gov/circs/circ66. pdf....................................................... 4

White Cabinet and White Table (Marcel Broodthaers, 1965).........................................................

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STATEMENT OF INTEREST OF AMICUS CURIAEEstablished in 1969, Volunteer Lawyers for the Arts ("VLA") is a pioneer in arts-related

legal aid and educational programing concerng the legal issues that impact arists and artsorganizations. Individual artists and arts organizations deserve access to dedicated legalrepresentation and advocacy to ensure that their voices are heard and that their interests areprotected. To achieve these goals , VLA provides low-income artists and nonprofit ars andcultural organizations with pro bono legal representation, legal counseling, and educationalprograms. Since its establishment, VLA has played a significant role in the life of the artscommunity, serving more than 300 000 low-income arists and nonprofit organizations across theUnited States. The Panel' s opinion on subjects of authorship and fixation is wrong. Ifitsdecision is allowed to stand, it would severely constrict the abilty of artists to enforce theirrights, and create uncertainty for what are otherwise clear guidelines on those issues in otherCircuits. VLA thus respectfully asks that the Circuit accept and consider VLA' amicus briefsubmitted in support of Plaintiff-Appell ant' s Petition for Rehearing En Banc.

SUMMARY OF ARGUMENTThe three-judge Panel of this Cour issued a ruling that Chapman Kelley s Wildflower

Works did not warant copyright protection because it was neither "authored" nor "fixed" underthe Panel' s interpretation of the Copyright Act. VLA supports rehearing en banc becauseWildflower Works - like many other works on the cutting edge of creativity - is plainly authoredand sufficiently fixed to warrant protection under the Copyright Act. VLA urges the Circuit toreconsider the Panel' s deCision, both on the facts of this case, and because of the impact thisdecision would have on the larger ars community.


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ARGUMENTFor purposes of this amicus brief, VLA does not address the ultimate question ofliabilty

under The Visual Arists Rights Act , 17 U.S.c. 9 106A, but rather focuses on section II.A.4 ofthe Panel' s opinion, in which the Panel asked "Is Wildflower Works copyrightable?" AlthoughDefendant-Appellee had not even raised the issue , the Panel answered in the negative , and madethese statements: " (A) living garden lacks the kind of authorship and stable fixation normallyrequired to support copyright." " living garden like Wildflower Works is neither ' authored'nor ' fixed' in the senses required for copyright." " Although the planting material is tangible andcan be perceived for more than a transitory duration , it is not stable enough or permanent enoughto be called ' fixed. '" Op. at 29-33 (emphases added). Faced with the example of Jeff KoonsPuppy" sculpture, the Panel attempted to distinguish it as follows: " In 'Puppy ' the artist

assembled a huge metal frame in the shape of a puppy and covered it with thousands of bloomingflowers sustained by an irrigation system within the frame. This may be sufficient fixation forcopyright (we ventue no opinion on the question), but Wildflower Works is quite different. It isquintessentially a garden; Puppy ' is not." (Op. at 34- 35) (emphasis added).

THE PANEL'S ATTEMPT TO DISTINGUISH AMONG PROTECTABLEAND UNPROTECTABLE "LIVING" ART IS WITHOUT SUPPORTAs the excerpts above show, the Panel appears to have substituted itself as an ar critic

espousing the view that Wildflower Works was a "garden " as somehow distinct from any kindof two- or three-dimensional arork, such as Puppy. The courts have long instructed that theirrole is not to decide what is or is not art. See Bleistein v. Donaldson Lithographing Co. 188

S. 239 , 251 (1903) ("it would be a dangerous undertaking for persons trained only to the lawto constitute themselves final judges of the worth of pictorial illustrations. " However thePanel' s opinion seems infected by a belief that arranging living plants within a metal framework


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in shapes upon the ground Call10t be "art " while arranging living plants on a three-dimensionalframe in the shape of a puppy may be. Copyright protection afforded on the basis of aristicconventionality and aesthetic categorization is contrary to the law, creates uncertainty, and limitsthe progress of aristic and cultural endeavors. The Panel' s opinion creates a two-tieredcopyright regime, where only works using traditional processes and materials wil be afordedprotection. Were the Panel's decision to stand, artists would have to speculate as to how courtsmight classify their ar to predict whether they would ultimately be protected under copyright.

II. WILDFLOWER WORKS IS FIXED FOR PURPOSES OF COPYRGHTThe Panel' s statements regarding fixation fall apar under scrutiny. The Panel cited

Professor Nimmer for the unobjectionable proposition that fixation requires that the work be ableto be perceived, reproduced, or otherwise communicated for a period or more than transitory

duration. Gp. at 30, citing, 1 Melvile B. Nimmer and David Nimmer, Nimmer on Copyright03(B) (Matthew Bender, Rev. Ed. 2010). Kelley s Wildflower Works was able to be

perceived, reproduced or otherwise communicated" for a period of twenty years. In the Panel'view, however, because the individual elements of Wildflower Works would change over timethe work as a whole could never be "fixed" as a matter of copyright law. In reality, however, nopiece of ar is permanent. Artwork (whether displayed indoors or outdoors) wil always changereact and ultimately succumb to the elements , and the natural ingredients that comprise mosttraditional" ar (whether alive or dead) are particularly susceptible, but the Panel' s decision

suggests that such works lack fixation. Yet, if an artist chooses to subject her ar to the forces ofnature - such as laying her painted canvas out to change under the sun - she would not loseauthorship because nature helped shape her painting.

It is worth noting that the U.S. Copyright Office has taken a decidedly opposite viewwhen it comes to the fixation requirement for copyrighted Internet websites: "Many works


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transmitted online, such as websites, are revised or updated frequently," and thereforecopyrightable revisions to online works that are published on separate days must each be

registered individually. ) While this statement suggests that the registration of a paricularwebsite at a particular moment covers only that iteration of the website, it demonstrates thatworks in a constant state 9f change - even if change is known and expected at the moment ofregistration - are stil undoubtedly fixed for puroses of copyright. Furthermore, as noted byPlaintiff-Appellant, other courts have held that fleeting and ephemeral digital works are fixed.See, e. g., MAl System Corps. v. Peak Computer, Inc. 991 F.2d 511 518 (9th Cir. 1993). Ifsoftware stored in RAM -: which is automatically wiped clean when a computer is turned off - isfixed for puroses of copyright infringement, why should an arrangement of living plants , thevisual experience of which wil remain reasonably unchanged for days or weeks , be treateddifferently?

III. WILDFLOWER WORKS IS A WORK OF AUTHORSHIPThe Panel declined to find authorship in Wildflower Works because it is uses natural

materials, so that "the colors , shapes, textures, and scents of the plants - originates in nature , notin the mind of the gardener." Op. at 32. However this surely canot be the rule, for there is nomeaningful difference between Kelley s selection of plants, and another arist' s decision to paintwith a particular pigment, carve a particular stone or whittle a paricular piece of wood.Likewise, an arist who uses a feather in her arwork owes the colors , shapes and textures of that

feather to the forces of nature , but how she chooses to use it is undeniably of her own authorship.The Panel' s opinion is built on the mistaken premise that Wildflower Works originates in

nature, rather than from the creative mind of man , as opposed to the Puppy living sculpture. The

1 U.S. Copyright Office Circular 66: Copyright Registration/or Online Works May 2009http://ww . copyright. gov / c ircs/ circ66. pdf.


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opinion, if allowed to stand, would seriously undermine that comfort and certainty, andeffectively strip away the protection of works in existence, and deter futue artists fromexperimenting with new materials and methods. By way of example, all of the following worksuse natural materials to convey their aristic messages: White Cabinet and White Table (MarcelBroodthaers, 1965) is comprised of painted eggshells piled upon a table. Central Garden(Robert Irwin, 1997) is a large outdoor work at The Getty Museum in Los Angeles, whichincludes a ravine, a tree-lined walkway, a floating azalea maze and over 500 types of plants.Spiral Jetty (Robert Smithson, 1970) is a spiral arrangement of black basalt rocks and earth onthe Great Salt Lake in Utah. The Library for the Birds of Antwerp (Mark Dion, 1993) has a treeat its center, upon which are aranged (among other things) birds , a rat, a snake and birds nests.Gnaw (J anine Antoni, 1992) is comprised of two large blocks - 600 pounds of chocolate and 600pounds of lard - each of which is gnawed in a unique pattern by the artist. Photographs of thereferenced works are available at ww.vlany.org/vla bancyetition images.php.

If the Panel' s opinion is allowed to stand, then the protection of the above works , andindeed of all works that use natural materials in new ways , are called into question. If arists losecopyright protection, they lose the right to stop other paries from commercializing their works.Anyone would be free to copy and commercialize such works without any benefit to the aristcontrary to Aricle I, Section 8 of the U.S. Constitution and also the Copyright Act.3 WildflowerWorks, for example, could be recreated by another city without payment or attribution to Kelley,

while the party doing the copying could enjoy uneared reputational and financial gain. Whenone factors in the potential revenues derived from the sale of derivative items, such as posters , t-2 VLA can also provide photographs of these works to the Court upon request.3 See All Things Considered: Mardi Gras Indians Seek to Copyright Costumes(National Public Radio broadcast, Feb. 8 2011) and Campbell Robertson Want to Use My Suit? ThenThrow Me Something, Y. Times, Mar. 23, 2010, at A13 (efforts to obtain compensation throughcopyright for use of traditional garb in images).


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shirts and other souvenirs , the significance canot be ignored. Indeed, based on the Panel'statement that it would protect Wildflower Works ' blueprints (Op. at 33), one could photographWildflower Works, fie a copyright registration for and commercialize the photograph , withoutany compensation to Kelley.

As the values of society change and focus more on urban space and the environment , artoo follows this trend. The arist's media changes , as do the messages underlying the work.VLA has noted this trend through the experience of its clients. The Supreme Cour has long heldthat "the purpose of federal copyright protection is to benefit the public by encouraging works inwhich it is interested. To induce individuals to underte the personal sacrifices necessary tocreate such works, federal copyright law extends to the authors of such works a limitedmonopoly to reap the rewards oftheir endeavors. Baltimore Orioles, Inc. v. Major LeagueBaseball Players Ass 805 F.2d 663 678 (7th Cir. 1986) (citing Supreme Court opinions). ThePanel' s opinion would lead to a reversal of these incentives - artists would shy away fromexperimentation and boundary-pushing, and their counselors , like VLA, would have to advisethem accordingly. The economic incentives created by copyright law should not be withheld onthe basis of an artist's choice of materials or subject matter , but rather the protections should beguaranteed in equal measure to all those who promote the progress of the useful ars.

CONCLUSIONThe Court should grant Plaintiff-Appellant' s motion for rehearing en banco

Sergio ' 0' nto (admission pending)Dena Bouchard (NY admission pending)Ana Kadyshevich (NY admission pending)VOLUNTEER LA WYERS FOR THE ARTS4 Robert Irin licensed The Gett Museum to reproduce and sell images of Central Gardens.


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1 East 53rd Street, 6th FloorNew York, New York 10022(212) 319-2787ssarmiento vlany.orgdbouchard v1any.orgakadyshevich vlany.orgHilel 1. Paress (admission pending)David LeichtmanROBINS , KAPLAN, MILLER & CIRESI L.L.P.601 Lexington Avenue, Suite 3400New York, New York 10022(212) 980-7400hiparness rkmc.comdleichtman rkmc.comGeorge M. SandersLAW OFFICES OF GEORGE M. SANDERS150 N. Michigan Ave. , Suite 2800Chicago, Ilinois 60601(312) 462-0324george.sandersfl earhlink.netAttorneys for Amicus CuriaeVolunteer Lawyers for the Arts

Dated: March 21 , 2011


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CERTIFICATE OF COMPLIANCEI hereby certify that the foregoing brief complies with the page-length limitation of Fed.

R. App. P. 29( d) and 3 5(b )(2), because this brief is no more than one-half the maximum lengthauthorized for Plaintiff-Appellant's principal brief , excluding the pars of the brief excluded byFed. R. App. P. 32(a)(7)(B)(iii).

I fuher certify that this brief complies with the typeface requirements of Fed. R. App.P. 32(a)(5) and Circuit Rule 32(b), and the type-style requirements of Fed. R. App. P. 32(a)(6),because this brief has been prepared in proportionately spaced typeface using Microsoft Word in12-point Times New Roman font (with footnotes in II-point Times New Roman font).

uted fMarch, 2011.

Wile! I. P ess


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CERTIFICATE OF SERVICEHilel 1. Parness, hereby certify that I caused to be served true and correct copies of the

foregoing Brief of Amicus Curiae on the following by Federal Express, including a digital copyin accordance with Circuit Rule 31 (e):

Micah E. MarcusKIRKLAND & ELLIS LLP300 N. LaSalleChicago, Ilinois 60654Diana TorresKhaldoun ShobakiGunar B. GundersenKIRKLAND & ELLIS LLP333 South Hope StreetLos Angeles, California 90071Counsel for P laintifAppellant/Cross-Appellee Chapman KelleyAnette M. McGaryMCGARRY & MCGARRY, LLC120 N. LaSalle, #1100Chicago , Ilinois 60602David DonnersbergerNelson A. Brown, Jr.CHICAGO PARK DISTRICTLaw Deparment541 N. Fairbans Cour , 3WChicago, Ilinois 60611Counsel for Defendant-Appellee/Cross-Appellant Chicago Park District

fMarch 2011.

Documents

Amicus Curiae Brief of VLA for plaintiff Chapman Kelley