Atlanta Photography LLC (Jennifer Sherrouse) v. Ian Marshall Realty Inc. Complaint

7/27/2019 Atlanta Photography LLC (Jennifer Sherrouse) v. Ian Marshall Realty Inc. Complaint

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JS44 (Rev. 1/13 NDGA) CIVIL COVER SHEETThe JS44 civil cover sheet and the information 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 is required for the use of the Clerk of Court for the purpose of initiating the civil docket record. (SEE INSTRUCTIONS ATTACHED)

I. (a) PLAINTIFF(S) DEFENDANT(S)

(b)COUNTY OF RESIDENCE OF FIRST LISTED COUNTY OF RESIDENCE OF FIRST LISTED

PLAINTIFF DEFENDANT

(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF

LAND INVOLVED

(c) ATTORNEYS (FIRM NAME, ADDRESS, TELEPHONE NUMBER, AND ATTORNEYS (IF KNOWN) E-MAIL ADDRESS)

II. BASIS OF JURISDICTION III. CITIZENSHIP OF PRINCIPAL PARTIES(PLACE AN X IN ONE BOX ONLY) (PLACE AN X IN ONE BOX FOR PLAINTIFF AND ONE BOX FOR DEFENDANT)

(FOR DIVERSITY CASES ONLY)

PLF DEF PLF DEF

1 U.S. GOVERNMENT 3 FEDERAL QUESTION 1 1 CITIZEN OF THIS STATE 4 4 INCORPORATED OR PRINCIPAL

PLAINTIFF (U.S. GOVERNMENT NOT A PARTY) PLACE OF BUSINESS IN THIS STATE

2 U.S. GOVERNMENT 4 DIVERSITY 2 2 CITIZEN OF ANOTHER STATE 5 5 INCORPORATED AND PRINCIPAL

DEFENDANT (INDICATE CITIZENSHIP OF PARTIES PLACE OF BUSINESS IN ANOTHER

IN ITEM III) STATE

3 3 CITIZEN OR SUBJECT OF A

FOREIGN COUNTRY 6 6 FOREIGN NATION

IV. ORIGIN (PLACE AN X IN ONE BOX ONLY) TRANSFERRED FROM APPEAL TO DISTRICT JUDGE

1 ORIGINAL 2 REMOVED FROM 3 REMANDED FROM 4 REINSTATED OR 5 ANOTHER DISTRICT 6 MULTIDISTRICT 7 FROM MAGISTRATE JUDGE

PROCEEDING STATE COURT APPELLATE COURT REOPENED (Specify District) LITIGATION JUDGMENT

V. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE - DO NOT CITE

JURISDICTIONAL STATUTES UNLESS DIVERSITY)

(IF COMPLEX, CHECK REASON BELOW)

1. Unusually large number of parties. 6. Problems locating or preserving evidence

2. Unusually large number of claims or defenses. 7. Pending parallel investigations or actions by government.

3. Factual issues are exceptionally complex 8. Multiple use of experts.

4. Greater than normal volume of evidence. 9. Need for discovery outside United States boundaries.

5. Extended discovery period is needed. 10. Existence of highly technical issues and proof.

CONTINUED ON REVERSEFOR OFFICE USE ONLY

RECEIPT # AMOUNT $ APPLYING IFP MAG. JUDGE (IFP)

JUDGE MAG. JUDGE NATURE OF SUIT CAUSE OF ACTION _

(Referral)

!

"

# $

% & ' ( ) 0 1 ' ( 2 3 4 & 5 6 7 6 8 &

9 @ A B C D E F G H A I P Q R @ E S F T @ E U G U E S V A W V E

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X X

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b @ A B C D E y Q B R B @ R R B A E V D G b B v V T @ E y Q B R B @ R R B A E V D G b B

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% & ' ( ) 0 1 ' ( 2 3 4 & 5 6 7 6 8 &


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VI. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY)

CONTRACT - "0" MONTHS DISCOVERY TRACK150 RECOVERY OF OVERPAYMENT &

ENFORCEMENT OF JUDGMENT152 RECOVERY OF DEFAULTED STUDENT

LOANS (Excl. Veterans)153 RECOVERY OF OVERPAYMENT OF

VETERAN'S BENEFITS

CONTRACT - "4" MONTHS DISCOVERY TRACK

110 INSURANCE120 MARINE

130 MILLER ACT140 NEGOTIABLE INSTRUMENT151 MEDICARE ACT160 STOCKHOLDERS' SUITS

190 OTHER CONTRACT195 CONTRACT PRODUCT LIABILITY

196 FRANCHISE

REAL PROPERTY - "4" MONTHS DISCOVERY

TRACK

210 LAND CONDEMNATION220 FORECLOSURE230 RENT LEASE & EJECTMENT240 TORTS TO LAND245 TORT PRODUCT LIABILITY

290 ALL OTHER REAL PROPERTY

TORTS - PERSONAL INJURY - "4" MONTHS

DISCOVERY TRACK

310 AIRPLANE315 AIRPLANE PRODUCT LIABILITY320 ASSAULT, LIBEL & SLANDER330 FEDERAL EMPLOYERS' LIABILITY340 MARINE

345 MARINE PRODUCT LIABILITY350 MOTOR VEHICLE355 MOTOR VEHICLE PRODUCT LIABILITY360 OTHER PERSONAL INJURY362 PERSONAL INJURY - MEDICAL

MALPRACTICE

365 PERSONAL INJURY - PRODUCT LIABILITY367 PERSONAL INJURY - HEALTH CARE/

PHARMACEUTICAL PRODUCT LIABILITY368 ASBESTOS PERSONAL INJURY PRODUCT

LIABILITY

TORTS - PERSONAL PROPERTY - "4" MONTHS

DISCOVERY TRACK370 OTHER FRAUD371 TRUTH IN LENDING380 OTHER PERSONAL PROPERTY DAMAGE385 PROPERTY DAMAGE PRODUCT LIABILITY

BANKRUPTCY - "0" MONTHS DISCOVERY TRACK

422 APPEAL 28 USC 158423 WITHDRAWAL 28 USC 157

CIVIL RIGHTS - "4" MONTHS DISCOVERY TRACK

441 VOTING442 EMPLOYMENT

443 HOUSING/ ACCOMMODATIONS444 WELFARE440 OTHER CIVIL RIGHTS445 AMERICANS with DISABILITIES - Employment446 AMERICANS with DISABILITIES - Other448 EDUCATION

IMMIGRATION - "0" MONTHS DISCOVERY TRACK462 NATURALIZATION APPLICATION465 OTHER IMMIGRATION ACTIONS

PRISONER PETITIONS - "0" MONTHS DISCOVERYTRACK463 HABEAS CORPUS- Alien Detainee510 MOTIONS TO VACATE SENTENCE530 HABEAS CORPUS

535 HABEAS CORPUS DEATH PENALTY540 MANDAMUS & OTHER550 CIVIL RIGHTS - Filed Pro se555 PRISON CONDITION(S) - Filed Pro se560 CIVIL DETAINEE: CONDITIONS OF

CONFINEMENT

PRISONER PETITIONS - "4" MONTHS DISCOVERY

TRACK550 CIVIL RIGHTS - Filed by Counsel555 PRISON CONDITION(S) - Filed by Counsel

FORFEITURE/PENALTY - "4" MONTHS DISCOVERY

TRACK625 DRUG RELATED SEIZURE OF PROPERTY

21 USC 881

690 OTHER

LABOR - "4" MONTHS DISCOVERY TRACK710 FAIR LABOR STANDARDS ACT720 LABOR/MGMT. RELATIONS740 RAILWAY LABOR ACT751 FAMILY and MEDICAL LEAVE ACT790 OTHER LABOR LITIGATION791 EMPL. RET. INC. SECURITY ACT

PROPERTY RIGHTS - "4" MONTHS DISCOVERY TRACK820 COPYRIGHTS840 TRADEMARK

PROPERTY RIGHTS - "8" MONTHS DISCOVERY TRACK830 PATENT

SOCIAL SECURITY - "0" MONTHS DISCOVERY

TRACK861 HIA (1395ff)

862 BLACK LUNG (923)863 DIWC (405(g))863 DIWW (405(g))864 SSID TITLE XVI865 RSI (405(g))

FEDERAL TAX SUITS - "4" MONTHS DISCOVERY

TRACK870 TAXES (U.S. Plaintiff or Defendant)871 IRS - THIRD PARTY 26 USC 7609

OTHER STATUTES - "4" MONTHS DISCOVERY

TRACK375 FALSE CLAIMS ACT400 STATE REAPPORTIONMENT

430 BANKS AND BANKING450 COMMERCE/ICC RATES/ETC.460 DEPORTATION470 RACKETEER INFLUENCED AND CORRUPT

ORGANIZATIONS480 CONSUMER CREDIT

490 CABLE/SATELLITE TV891 AGRICULTURAL ACTS893 ENVIRONMENTAL MATTERS895 FREEDOM OF INFORMATION ACT950 CONSTITUTIONALITY OF STATE STATUTES890 OTHER STATUTORY ACTIONS

899 ADMINISTRATIVE PROCEDURES ACT /REVIEW OR APPEAL OF AGENCY DECISION

OTHER STATUTES - "8" MONTHS DISCOVERY

TRACK410 ANTITRUST850 SECURITIES / COMMODITIES / EXCHANGE

OTHER STATUTES - 0" MONTHS DISCOVERY

TRACK896 ARBITRATION

(Confirm / Vacate / Order / Modify)

* PLEASE NOTE DISCOVERYTRACK FOR EACH CASE TYPE.SEE LOCAL RULE 26.3

VII. REQUESTED IN COMPLAINT:

CHECK IF CLASS ACTION UNDER F.R.Civ.P. 23 DEMAND $_____________________________

JURY DEMAND YES NO (CHECK YES ONLY IF DEMANDED IN COMPLAINT)

VIII. RELATED/REFILED CASE(S) IF ANY JUDGE_______________________________ DOCKET NO._______________________

CIVIL CASES ARE DEEMED RELATED IF THE PENDING CASE INVOLVES: (CHECK APPROPRIATE BOX)

1. PROPERTY INCLUDED IN AN EARLIER NUMBERED PENDING SUIT.

2. SAME ISSUE OF FACT OR ARISES OUT OF THE SAME EVENT OR TRANSACTION INCLUDED IN AN EARLIER NUMBERED PENDING SUIT.

3. VALIDITY OR INFRINGEMENT OF THE SAME PATENT, COPYRIGHT OR TRADEMARK INCLUDED IN AN EARLIER NUMBERED PENDING SUIT.

4. APPEALS ARISING OUT OF THE SAME BANKRUPTCY CASE AND ANY CASE RELATED THERETO WHICH HAVE BEEN DECIDED BY THE SAME

BANKRUPTCY JUDGE.

5. REPETITIVE CASES FILED BY PRO SE LITIGANTS.

6. COMPANION OR RELATED CASE TO CASE(S) BEING SIMULTANEOUSLY FILED (INCLUDE ABBREVIATED STYLE OF OTHER CASE(S)):

7. EITHER SAME OR ALL OF THE PARTIES AND ISSUES IN THIS CASE WERE PREVIOUSLY INVOLVED IN CASE NO. , WHICH WAS

DISMISSED. This case IS IS NOT (check one box) SUBSTANTIALLY THE SAME CASE.

SIGNATURE OF ATTORNEY OF RECORD DATE

j ! k


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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION

ATLANTA PHOTOGRAPHY, LLC

Plaintiff,

v. DEMAND FOR JURY TRIAL

IAN MARSHALL REALTY, INC., CIVIL ACTION NO.

IAN MARSHALL, andALBERT JONES

Defendants.__________________________________________________________________

COMPLAINT

_______________________________________________________________

Plaintiff, Atlanta Photography, LLC (APLLC), by and through its

undersigned attorneys, states its claims against Defendants Ian Marshall Realty,

Inc. ("IM Realty"), Ian Marshall ("Marshall"), and Albert Jones ("Jones")

(collectively, the Defendants), as follows:

PARTIES, JURISDICTION, AND VENUE

1. APLLC is a limited liability company organized and existing underthe laws of the State of Delaware.


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2. Defendant IM Realty is a corporation organized and existing under thelaws of the State of Georgia, with its principal place of business at 303 Perimeter

Center North, Suite 300, Atlanta, Georgia 30346. Defendant IM Realty, Inc. may

be served through its registered agent, Ian Marshall, at 1417 Nerine Circle

Dunwoody, Georgia 30338.

3. Defendant Marshall is an individual who, upon information andbelief, resides in Dunwoody, Georgia. Defendant Marshall is the owner and

Qualifying Broker of record for Defendant IM Realty. Defendant Marshall may be

served at his place of business at Ian Marshall Realty, Inc., at 303 Perimeter Center

North, Suite 300, Atlanta, Georgia 30346.

4. Defendant Jones is an individual who, upon information and belief,resides in Atlanta, Georgia. Jones is a real estate agent salesperson working for

Defendant IM Realty. Defendant Jones may be served at his place of business at

Ian Marshall Realty, Inc., 303 Perimeter Center North, Suite 300, Atlanta, Georgia

30346.

5. This action arises under the Federal Copyright Act of 1976, asamended, 17 U.S.C. 101, et seq. This Court is vested with subject matter

jurisdiction pursuant to 28 U.S.C. 1331 (federal question jurisdiction) and

1338(a) (copyright jurisdiction).


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6. This Court has personal jurisdiction over Defendants by virtue of theirpresence in this District and their transacting, doing, and soliciting business in this

District.

7. Venue is proper under 28 U.S.C. 1391 (b)(1), (c), and (d) and1400(a).

FACTUAL BACKGROUND

8. Non-party Jennifer Sherrouse (Photographer) is a real estatesalesperson licensed in the State of Georgia since 1994.

9. In 2007 and 2009, Photographer took photographs of multipleproperties so that she could display them to advertise her business.

10. On September 26, 2009, The Photographer published one of herphotographs of property on her website at http://www.lenoxcondos.com (Photo

Website), as shown below:


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(the Alexandria Photograph). The Photographer posted her copyright notice of

2009 Jennifer Sherrouse on the Alexandria Photograph.

11. On September 26, 2009, the Photographer published another of herphotographs of property on the Photo Website, as shown below:


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(the Lenox Photograph). The Photographer posted her copyright notice of

2009 Jennifer Sherrouse on the Lenox Photograph.

12. On January 4, 2010, the Photographer published another of herphotographs of property on the Photo Website, as shown below:

(the Stone Gate Photograph). The Photographer posted her copyright notice of

2007 Jennifer Sherrouse on the Stone Gate Photograph.

13. In or around August 2010, the Photographer discovered thatDefendants had reproduced and were displaying the Alexandria Photograph, the

Lenox Photograph, and the Stone Gate Photograph (collectively the

Photographs) on IM Realtys and Jones' website at http://buyandsellatl.com (IM

Realty Website), as shown below:


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14. Defendants cropped the Photographs to remove the copyright noticefrom each of the Photographs before displaying them on the IM Realty Website.

15. Defendants used the Photographs to advertise IM Realtys real estatebrokerage business.

16. On October 28, 2010, the Photographer, through her attorney, sent aletter to Jones giving notice that the reproduction, display, and distribution of the

Photographs on IM Realty Website was unauthorized and asking Jones to cease

any use of the Photographs.

17. On January 20, 2011, the Photographer, through her attorney, sent aletter to Marshall and IM Realty giving notice that the reproduction, display, and

distribution of the Photographs on the IM Realty Website was unauthorized and

asking Marshall and IM Realty to cease any use of the Photographs

18. As of the date of the filing of this lawsuit, the Defendants continue toreproduce, display, and distribute different cropped versions of the Photographs at:

http://buyandsellatl.com/wp-content/uploads/2010/08/roxboro-walk.jpg;

http://buyandsellatl.com/wp-content/uploads/2010/08/roxboro-walk-150x150.jpg;


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http://buyandsellatl.com/wp-content/uploads/2010/08/stonegate-on-lenox-300x155.jpg;

http://buyandsellatl.com/wp-content/uploads/2010/08/stonegate-on-lenox-300x155-150x150.jpg;

http://buyandsellatl.com/wp-content/uploads/2010/07/alexandriacondos-300x1581.jpg; and

http://buyandsellatl.com/wp-content/uploads/2010/07/alexandriacondos-300x1581-150x150.jpg.

19. The Photographs in perspective, orientation, positioning, lighting andother details are entirely original, distinctive, and unique. As such, the

Photographs are subject matter protectable under the Copyright Act.

20. Neither the Photographer nor APLLC ever authorized any of theDefendants to reproduce, display, or distribute the Photographs.

21. The Photographer complied with all respects with the Copyright Actof 1976, 17 U.S.C. 101 et seq., as amended, and all other laws and regulations

governing copyrights and secured the exclusive rights and privileges in and to the

copyrights for the Photographs.

22. The Register of Copyrights for the U.S. Copyright Office issued to thePhotographer two Certificates of Registration for the copyrights to the


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Photographs, numbers VA 1-780-878, effective July 23, 2010, and VA 1-788-164,

effective July 23, 2010 as shown below:


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23. On December 23, 2011, the Photographer transferred the copyrights inthe Photographs to APLLC, recorded by the U.S. Copyright Office in document

V3602 D618 P1-2. Accordingly, APLLC is the copyright owner and proprietor of

the right, title, and interest in and to the copyright in the Photographs. 17 U.S.C.

201.

FIRST CAUSE OF ACTION

Copyright Infringement 17 U.S.C. 101 et seq.

24. APLLC re-alleges and incorporates by reference paragraphs 1 through23 above.

25. On information and belief, the Defendants had access to thePhotographs through the Photo Website.

26. The Defendants did not have authorization of the Photographer,APLLC, or the law to reproduce, distribute, display, or create derivative works of

the Photographs.

27. The Defendants violated APLLCs exclusive rights granted in 17U.S.C. 106, specifically its exclusive right to: (1) reproduce the copyrighted

work in copies; (2) prepare derivative works based on the copyrighted work; (3)

distribute copies of the copyrighted work to the public by sale or other transfer of


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ownership, or by rental, lease, or lending; and (4) display the copyrighted work

publicly.

28. As the Defendants began to reproduce, display, and distribute theAlexandria Photograph on July 19, 2010, the Lenox Photograph on July 28, 2010,

and the Stone Gate Photograph on July 28, 2010, all claims of infringement are

within the three-year statute of limitations period pursuant to 17 U.S.C. 507(b).

29. As a direct and proximate result of their wrongful conduct, theDefendants have realized and continue to realize profits and other benefits

rightfully belonging to APLLC for the Photographs. Accordingly, APLLC is

entitled to and seeks an award of actual damages and profits pursuant to 17 U.S.C.

504(b).

30. In the alternative, APLLC is entitled to and seeks statutory damagesfor the Defendants' infringement of the Lenox Photograph and the Stone Gate

Photograph, including attorneys fees and costs, pursuant to 17 U.S.C. 504(c)(1)

and 505.

31. The infringement by the Defendants was willful and performed withknowledge that the reproduction, display, and distribution of the Lenox Photograph

and the Stone Gate Photograph was unauthorized; APLLC is therefore entitled to

the recovery of enhanced statutory damages pursuant to 17 U.S.C. 504 (c)(2).


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SECOND CAUSE OF ACTION

Digital Millennium Copyright Act Violations 17 U.S.C. 1201 et seq.


33. The copyright notice on each of the Photographs constitutes copyrightmanagement information pursuant to 17 U.S.C. 1202(c)(2), (3) and (7).

34. Upon information and belief, the Defendants, without the authority ofthe Photographer, APLLC, or the law, intentionally removed the copyright notices

and distributed the Photographs, knowing that the copyright notices had been

removed or altered, knowing or having reasonable grounds to know that such

removal or alteration would induce, enable, facilitate, or conceal a copyright

infringement, in violation of 17 U.S.C. 1202(b).

35. As a direct and proximate result of the Defendants wrongful conduct,APLLC has suffered damages and so is entitled to the remedies set forth under 17

U.S.C. 1203.

36. Specifically, APLLC is entitled to and seeks actual damages pursuantto 17 U.S.C. 1203(c)(2).


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37. In the alternative, APLLC is entitled to and seeks statutory damagespursuant to 17 U.S.C. 1203(c)(3)(B), and costs of litigation and attorneys fees

pursuant to 17 U.S.C. 1203(b)(4-5).

THIRD CAUSE OF ACTION

Contributory Infringement


39. Marshall, without the authority of the Photographer, APLLC, or thelaw and in violation of 17 U.S.C. 501, infringed contributorily by intentionally

inducing and encouraging direct infringement by Jones and IM Realty.

40. Marshall is contributorily liable for the intentional encouragement ofdirect infringement by knowingly taking steps which were substantially certain to

result in direct infringement.

41. As a direct and proximate result of Marshalls contributoryinfringement, APLLC has suffered injuries and damages and so is entitled to the

remedies set forth under 17 U.S.C. 504 and 505.


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FOURTH CAUSE OF ACTION

Vicarious Liability


43. As owner and Qualifying Real Estate Broker of IM Realty, Marshallhad both the legal right and the ability to stop Jones and IM Realtys direct

infringement of the Photographs.

44. As owner and Qualifying Real Estate Broker of IM Realty, Marshallgained a direct financial benefit from Jones' and IM Realty's direct infringement of

the Photographs.

45. As such, Marshall had: (1) the right and ability to supervise or controlthe infringing activity; and (2) a direct financial benefit from that activity.

Therefore, Marshall is vicariously liable for the infringing activity.

46. As a direct and proximate result of Marshalls vicarious infringement,APLLC has suffered injuries and damages.

PRAYER FOR RELIEF

WHEREFORE APLLC prays that this Honorable Court:


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1. Order that the Defendants unauthorized conduct violates APLLCs rightsunder the Federal Copyright Act at 17 U.S.C. 101, et seq.;

2. Order the Defendants to account to APLLC for all gains, profits, andadvantages derived from the Defendants infringement of the Photographs;

3. Order the Defendants to pay APLLC all profits and damages in such amountas may be found pursuant to 17 U.S.C. 504(b) (with interest thereon at the

highest legal rate) for the Defendants infringement of the Photographs;

alternatively, maximum statutory damages in the amount of $30,000 for

each infringement of the Lenox Photograph and the Stone Gate Photograph

pursuant to 17 U.S.C. 504 (c)(1); or such other amount as may be proper

pursuant to 17 U.S.C. 504;

4. Award APLLC maximum statutory damages in the amount of $150,000 foreach of the Defendants infringements of APLLCs copyrights in the Lenox

Photograph and the Stone Gate Photograph pursuant to 17 U.S.C. 504

(c)(2); or such other amount as may be proper pursuant to 17 U.S.C. 504;

5. Order that Marshall is contributorily liable for the direct infringement ofAPLLCs copyrights in the Photographs;

6. Order that Marshall is vicariously liable for the direct infringement ofAPLLCs copyrights in the Photographs;


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7. Award APLLC actual damages suffered and profits for each violation of 17U.S.C. 1202 (a) and (b), pursuant to 17 U.S.C. 1203(c)(2); or such other

amount as may be proper pursuant to 17 U.S.C. 1203;

8. Award APLLC maximum statutory damages in the amount of $25,000 foreach violation of 17 U.S.C. 1202 (a) and (b) pursuant to 17 U.S.C.

1203(c)(3)(B); or such other amount as may be proper pursuant to 17 U.S.C.

1203;

9. Order the Defendants to pay APLLC its costs of litigation and reasonableattorneys fees in this action, pursuant to 17 U.S.C. 505 and 17 U.S.C.

1203;

10. Order the Defendants to deliver to APLLC all copies of the Photographs andall other materials containing such infringing copies of the Photographs in

their possession, custody or control;

11. Order the Defendants, their agents, and servants to be enjoined during thependency of this action and permanently from infringing the copyrights of

APLLC in any manner and from reproducing, distributing, displaying, or

creating derivative works of the Photographs; and

12. Order such other and further relief as this Honorable Court deems just andequitable.


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APLLC demands a jury trial on all of the foregoing counts.

This 15th day of July, 2013.

Respectfully submitted,

LAW OFFICE OF CAROLYN E.

WRIGHT, LLC

s/Carolyn E. Wright

_____________________________CAROLYN E. WRIGHTGeorgia Bar No. 777718

EVAN A. ANDERSENGeorgia Bar No. 377422

P.O. Box 250208Atlanta, GA 30325775-589-2229 (telephone)

404-496-6606 (telephone)775-580-7322 (facsimile)[email protected]@photoattorney.com

Counsel for Plaintiff Atlanta Photography, LLC


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CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 5.1.B

Counsel for APLLC hereby certifies that this pleading was prepared in

Times New Roman font, 14 point, in compliance with Local Rule 5.1.B.

This 15th day of July, 2013.

Respectfully submitted,

LAW OFFICE OF CAROLYN E.

WRIGHT, LLC

s/Carolyn E. Wright_____________________________Georgia Bar No. 777718

P.O. Box 250208Atlanta, GA 30325775-589-2229 (telephone)775-580-7322 (facsimile)[email protected]

Counsel for Plaintiff Atlanta Photography, LLC

Documents

Atlanta Photography LLC (Jennifer Sherrouse) v. Ian Marshall Realty Inc. Complaint