JS44 (Rev.

1/13 NDGA)

CIVIL COVER SHEET

The 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)
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DEFENDANT(S)
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(b) COUNTY OF RESIDENCE OF FIRST LISTED

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

PLAINTIFF
(EXCEPT IN U.S. PLAINTIFF CASES)

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT

(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

E-MAIL ADDRESS)
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 X @ Y ` a a I b V B a 9 @ A B C D E F G H A I P Q R c X X 9

ATTORNEYS

(IF KNOWN)

h s s

II. BASIS OF JURISDICTION

(PLACE AN X IN ONE BOX ONLY)

III. CITIZENSHIP OF PRINCIPAL PARTIES

(PLACE AN X IN ONE BOX FOR PLAINTIFF AND ONE BOX FOR DEFENDANT) (FOR DIVERSITY CASES ONLY) PLF DEF 1 CITIZEN OF THIS STATE PLF 4 DEF 4 INCORPORATED OR PRINCIPAL PLACE OF BUSINESS IN THIS STATE INCORPORATED AND PRINCIPAL PLACE OF BUSINESS IN ANOTHER STATE FOREIGN NATION

1 U.S. GOVERNMENT PLAINTIFF 2 U.S. GOVERNMENT DEFENDANT

3 FEDERAL QUESTION (U.S. GOVERNMENT NOT A PARTY) 4 DIVERSITY (INDICATE CITIZENSHIP OF PARTIES IN ITEM III)

CITIZEN OF ANOTHER STATE

CITIZEN OR SUBJECT OF A FOREIGN COUNTRY

IV. ORIGIN

(PLACE AN X IN ONE BOX ONLY) 2 REMOVED FROM STATE COURT 3 REMANDED FROM APPELLATE COURT 4 REINSTATED OR REOPENED TRANSFERRED FROM 5 ANOTHER DISTRICT (Specify District) 6 MULTIDISTRICT LITIGATION APPEAL TO DISTRICT JUDGE 7 FROM MAGISTRATE JUDGE JUDGMENT

1 ORIGINAL PROCEEDING
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V. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE - DO NOT CITE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. 2. Unusually large number of claims or defenses. 3. Factual issues are exceptionally complex 4. Greater than normal volume of evidence. 5. Extended discovery period is needed. 6. Problems locating or preserving evidence 7. Pending parallel investigations or actions by government. 8. Multiple use of experts. 9. Need for discovery outside United States boundaries. 10. Existence of highly technical issues and proof.

CONTINUED ON REVERSE
FOR OFFICE USE ONLY RECEIPT # JUDGE AMOUNT $ MAG. JUDGE (Referral) APPLYING IFP NATURE OF SUIT MAG. JUDGE (IFP) CAUSE OF ACTION _

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

CONTRACT - "0" MONTHS DISCOVERY TRACK
150 RECOVERY OF OVERPAYMENT & ENFORCEMENT OF JUDGMENT 152 RECOVERY OF DEFAULTED STUDENT LOANS (Excl. Veterans) 153 RECOVERY OF OVERPAYMENT OF VETERAN'S BENEFITS

CIVIL RIGHTS - "4" MONTHS DISCOVERY TRACK

441 VOTING 442 EMPLOYMENT 443 HOUSING/ ACCOMMODATIONS 444 WELFARE 440 OTHER CIVIL RIGHTS 445 AMERICANS with DISABILITIES - Employment 446 AMERICANS with DISABILITIES - Other 448 EDUCATION

SOCIAL SECURITY - "0" MONTHS DISCOVERY TRACK

861 HIA (1395ff) 862 BLACK LUNG (923) 863 DIWC (405(g)) 863 DIWW (405(g)) 864 SSID TITLE XVI 865 RSI (405(g))

CONTRACT - "4" MONTHS DISCOVERY TRACK

110 INSURANCE 120 MARINE 130 MILLER ACT 140 NEGOTIABLE INSTRUMENT 151 MEDICARE ACT 160 STOCKHOLDERS' SUITS 190 OTHER CONTRACT 195 CONTRACT PRODUCT LIABILITY 196 FRANCHISE

IMMIGRATION - "0" MONTHS DISCOVERY TRACK

462 NATURALIZATION APPLICATION 465 OTHER IMMIGRATION ACTIONS

FEDERAL TAX SUITS - "4" MONTHS DISCOVERY TRACK

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

PRISONER PETITIONS - "0" MONTHS DISCOVERY TRACK

463 HABEAS CORPUS- Alien Detainee 510 MOTIONS TO VACATE SENTENCE 530 HABEAS CORPUS 535 HABEAS CORPUS DEATH PENALTY 540 MANDAMUS & OTHER 550 CIVIL RIGHTS - Filed Pro se 555 PRISON CONDITION(S) - Filed Pro se 560 CIVIL DETAINEE: CONDITIONS OF CONFINEMENT

OTHER STATUTES - "4" MONTHS DISCOVERY TRACK

375 FALSE CLAIMS ACT 400 STATE REAPPORTIONMENT 430 BANKS AND BANKING 450 COMMERCE/ICC RATES/ETC. 460 DEPORTATION 470 RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS 480 CONSUMER CREDIT 490 CABLE/SATELLITE TV 891 AGRICULTURAL ACTS 893 ENVIRONMENTAL MATTERS 895 FREEDOM OF INFORMATION ACT 950 CONSTITUTIONALITY OF STATE STATUTES 890 OTHER STATUTORY ACTIONS 899 ADMINISTRATIVE PROCEDURES ACT / REVIEW OR APPEAL OF AGENCY DECISION

REAL PROPERTY - "4" MONTHS DISCOVERY TRACK

210 LAND CONDEMNATION 220 FORECLOSURE 230 RENT LEASE & EJECTMENT 240 TORTS TO LAND 245 TORT PRODUCT LIABILITY 290 ALL OTHER REAL PROPERTY

PRISONER PETITIONS - "4" MONTHS DISCOVERY TRACK

550 CIVIL RIGHTS - Filed by Counsel 555 PRISON CONDITION(S) - Filed by Counsel

TORTS - PERSONAL INJURY - "4" MONTHS DISCOVERY TRACK

310 AIRPLANE 315 AIRPLANE PRODUCT LIABILITY 320 ASSAULT, LIBEL & SLANDER 330 FEDERAL EMPLOYERS' LIABILITY 340 MARINE 345 MARINE PRODUCT LIABILITY 350 MOTOR VEHICLE 355 MOTOR VEHICLE PRODUCT LIABILITY 360 OTHER PERSONAL INJURY 362 PERSONAL INJURY - MEDICAL MALPRACTICE 365 PERSONAL INJURY - PRODUCT LIABILITY 367 PERSONAL INJURY - HEALTH CARE/ PHARMACEUTICAL PRODUCT LIABILITY 368 ASBESTOS PERSONAL INJURY PRODUCT LIABILITY

FORFEITURE/PENALTY - "4" MONTHS DISCOVERY TRACK

625 DRUG RELATED SEIZURE OF PROPERTY 21 USC 881 690 OTHER

OTHER STATUTES - "8" MONTHS DISCOVERY TRACK

410 ANTITRUST 850 SECURITIES / COMMODITIES / EXCHANGE

LABOR - "4" MONTHS DISCOVERY TRACK

710 FAIR LABOR STANDARDS ACT 720 LABOR/MGMT. RELATIONS 740 RAILWAY LABOR ACT 751 FAMILY and MEDICAL LEAVE ACT 790 OTHER LABOR LITIGATION 791 EMPL. RET. INC. SECURITY ACT

OTHER STATUTES - 0" MONTHS DISCOVERY TRACK

896 ARBITRATION (Confirm / Vacate / Order / Modify)

PROPERTY RIGHTS - "4" MONTHS DISCOVERY TRACK

TORTS - PERSONAL PROPERTY - "4" MONTHS DISCOVERY TRACK

370 OTHER FRAUD 371 TRUTH IN LENDING 380 OTHER PERSONAL PROPERTY DAMAGE 385 PROPERTY DAMAGE PRODUCT LIABILITY

820 COPYRIGHTS 840 TRADEMARK

* PLEASE NOTE DISCOVERY

TRACK FOR EACH CASE TYPE. SEE LOCAL RULE 26.3

PROPERTY RIGHTS - "8" MONTHS DISCOVERY TRACK

830 PATENT

BANKRUPTCY - "0" MONTHS DISCOVERY TRACK

422 APPEAL 28 USC 158 423 WITHDRAWAL 28 USC 157

VII. REQUESTED IN COMPLAINT:

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

YES

NO (CHECK YES ONLY IF DEMANDED IN COMPLAINT)

VIII. RELATED/REFILED CASE(S) IF ANY

JUDGE_______________________________ DOCKET NO._______________________
(CHECK APPROPRIATE BOX)

CIVIL CASES ARE DEEMED RELATED IF THE PENDING CASE INVOLVES:

1. 2. 3. 4.

PROPERTY INCLUDED IN AN EARLIER NUMBERED PENDING SUIT. SAME ISSUE OF FACT OR ARISES OUT OF THE SAME EVENT OR TRANSACTION INCLUDED IN AN EARLIER NUMBERED PENDING SUIT. VALIDITY OR INFRINGEMENT OF THE SAME PATENT, COPYRIGHT OR TRADEMARK INCLUDED IN AN EARLIER NUMBERED PENDING SUIT. 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. DISMISSED. This case IS IS NOT (check one box) SUBSTANTIALLY THE SAME CASE.

, WHICH WAS

SIGNATURE OF ATTORNEY OF RECORD

DATE

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ATLANTA PHOTOGRAPHY, LLC Plaintiff, v. IAN MARSHALL REALTY, INC., IAN MARSHALL, and ALBERT JONES DEMAND FOR JURY TRIAL CIVIL ACTION NO.

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 under

the laws of the State of Delaware.

2.

Defendant IM Realty is a corporation organized and existing under the

laws 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 and

belief, 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, as

amended, 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). 2

6.

This Court has personal jurisdiction over Defendants by virtue of their

presence in this District and their transacting, doing, and soliciting business in this District. 7. 1400(a). FACTUAL BACKGROUND 8. Non-party Jennifer Sherrouse (Photographer) is a real estate Venue is proper under 28 U.S.C. 1391 (b)(1), (c), and (d) and

salesperson licensed in the State of Georgia since 1994. 9. In 2007 and 2009, Photographer took photographs of multiple

properties so that she could display them to advertise her business. 10. On September 26, 2009, The Photographer published one of her

photographs of property on her website at http://www.lenoxcondos.com (Photo Website), as shown below:

(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 her

photographs of property on the Photo Website, as shown below:

(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 her

photographs 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 that

Defendants 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: 5

14.

Defendants cropped the Photographs to remove the copyright notice

from each of the Photographs before displaying them on the IM Realty Website. 15. Defendants used the Photographs to advertise IM Realtys real estate

brokerage business. 16. On October 28, 2010, the Photographer, through her attorney, sent a

letter 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 a

letter 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 to

reproduce, display, and distribute different cropped versions of the Photographs at: http://buyandsellatl.com/wp-content/uploads/2010/08/roxborowalk.jpg; http://buyandsellatl.com/wp-content/uploads/2010/08/roxboro-walk150x150.jpg;

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

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

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

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

19.

The Photographs in perspective, orientation, positioning, lighting and

other 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 the

Defendants to reproduce, display, or distribute the Photographs. 21. The Photographer complied with all respects with the Copyright Act

of 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 the

Photographer two Certificates of Registration for the copyrights to the 10

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 in

the 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. 23 above. 25. On information and belief, the Defendants had access to the APLLC re-alleges and incorporates by reference paragraphs 1 through

Photographs 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 17

U.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 the

Alexandria 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, the

Defendants 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 damages

for 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 with

knowledge 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). 21

SECOND CAUSE OF ACTION Digital Millennium Copyright Act Violations 17 U.S.C. 1201 et seq. 32. 23 above. 33. The copyright notice on each of the Photographs constitutes copyright APLLC re-alleges and incorporates by reference paragraphs 1 through

management information pursuant to 17 U.S.C. 1202(c)(2), (3) and (7). 34. Upon information and belief, the Defendants, without the authority of

the 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 pursuant

to 17 U.S.C. 1203(c)(2).

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37.

In the alternative, APLLC is entitled to and seeks statutory damages

pursuant 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 38. 23 above. 39. Marshall, without the authority of the Photographer, APLLC, or the APLLC re-alleges and incorporates by reference paragraphs 1 through

law 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 of

direct infringement by knowingly taking steps which were substantially certain to result in direct infringement. 41. As a direct and proximate result of Marshalls contributory

infringement, 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 42. 23 above. 43. As owner and Qualifying Real Estate Broker of IM Realty, Marshall APLLC re-alleges and incorporates by reference paragraphs 1 through

had 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, Marshall

gained 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 control

the 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 rights under the Federal Copyright Act at 17 U.S.C. 101, et seq.;

2.

Order the Defendants to account to APLLC for all gains, profits, and advantages derived from the Defendants infringement of the Photographs;

3.

Order the Defendants to pay APLLC all profits and damages in such amount as 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 for each 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 of APLLCs copyrights in the Photographs;

6.

Order that Marshall is vicariously liable for the direct infringement of APLLCs copyrights in the Photographs; 25

7.

Award APLLC actual damages suffered and profits for each violation of 17 U.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 for each 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 reasonable attorneys 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 and all 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 the pendency 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 and equitable. 26

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. WRIGHT Georgia Bar No. 777718 EVAN A. ANDERSEN Georgia Bar No. 377422 P.O. Box 250208 Atlanta, GA 30325 775-589-2229 (telephone) 404-496-6606 (telephone) 775-580-7322 (facsimile) carolyn@photoattorney.com evan@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 250208 Atlanta, GA 30325 775-589-2229 (telephone) 775-580-7322 (facsimile) carolyn@photoattorney.com Counsel for Plaintiff Atlanta Photography, LLC

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