SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: THIRD DEPARTMENT
CHRISTOPHER PORCO,
Plaintiff-Appellant,

Case No. 522707

-againstLIFETIME ENTERTAINMENT SERVICES, LLC,
Defendant-Respondent.
NOTICE OF MOTION FOR LEAVE TO FILE BRIEF AS AMICI CURIAE
IN SUPPORT OF DEFENDANT-RESPONDENT’S
MOTION FOR LEAVE TO APPEAL
PLEASE TAKE NOTICE that upon the annexed affirmation of Joseph M.
Finnerty, dated April 4, 2017, and the exhibit attached thereto, the Reporters
Committee for Freedom of the Press, and 15 news media organizations (“Proposed
Amici”) will move this Court on April 17, 2017, at the Appellate Division
Courthouse located at the Justice Building, 5th Floor, Empire State Plaza, Albany,
New York 12223, at 10:00 a.m. for an order granting Proposed Amici leave to file
the attached brief as amici curiae in support of Defendant-Respondent’s motion for
leave to appeal in the above-captioned action, and for such other and further relief
as the Court may deem just and proper in the circumstances.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b),
answering papers, if any, shall be served at least eight (8) days before the return
date of this motion.

 Dated: New York, NY
April 4, 2017
Respectfully submitted,
BARCLAY DAMON LLP
/s/ Joseph M. Finnerty
Joseph M. Finnerty
1270 Avenue of the Americas
Suite 600
New York, NY 10020
(212) 784-5800
jfinnerty@barclaydamon.com
Attorney for Proposed Amici

To:

Christopher Porco, Inmate
#06A6686
Clinton Correctional Facility
P.O. Box 2001
Dannemora, NY 12929
Plaintiff Pro Se
David A. Schulz
Cameron Stracher
Levine Sullivan Koch & Schulz, LLP
321 West 44th Street
Suite 1000
New York, NY 10036
(212) 850-6100
dschulz@lskslaw.com
cstracher@lskslaw.com
Counsel for Defendant-Appellant Lifetime Entertainment Services, LLC

 SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: THIRD DEPARTMENT
CHRISTOPHER PORCO,
Plaintiff-Appellant,

Case No. 522707

-againstLIFETIME ENTERTAINMENT SERVICES, LLC,
Defendant-Respondent.

AFFIRMATION OFJOSEPH M. FINNERTY IN SUPPORT OF MOTION
FOR LEAVE TO FILE BRIEF AS AMICI CURIAE IN SUPPORT OF
DEFENDANT-RESPONDENT’S MOTION FOR LEAVE TO APPEAL

I, JOSEPH M. FINNERTY, an attorney duly admitted to practice law before
the courts of the State of New York, hereby affirms the following under penalty of
perjury:
1. I am a partner at Barclay Damon LLP, located at 1270 Avenue of the
Americas, Suite 600, New York, NY 10020, and am counsel of record for Advance
Publications, Inc., The Center for Investigative Reporting, Discovery

 Communications, LLC, Gannett Co., Inc., Investigative Reporting Workshop at
American University, Media Law Resource Center, MPA – The Association of
Magazine Media, National Press Photographers Association, NBCUniversal
Media, LLC, The New York Times Company, Online News Association, Radio
Television Digital News Association, the Reporters Committee for Freedom of the
Press, The Seattle Times Company, and the Society of Professional Journalists
(“Proposed Amici”). I submit this affirmation in support of the motion of Proposed
Amici for leave to file a brief as amici curiae in support of DefendantRespondent’s motion for leave to appeal in the above-captioned action.
2. Attached hereto as Exhibit A is a true and correct copy of the brief that
Proposed Amici seek leave to file with the Court as amici curiae (the “Proposed
Amici Brief”). Proposed Amici have duly authorized me to submit the Proposed
Amici Brief on their behalf.
3. The Reporters Committee for Freedom of the Press is an unincorporated
nonprofit association of reporters and editors working to defend and preserve the
First Amendment rights and the freedom of information interests of the news
media. The Reporters Committee has provided guidance and research in First

 Amendment and freedom of information litigation since 1970, and it frequently
files friend-of-the-court briefs in significant media law cases.
4. The interests of all other Proposed Amici are set forth in Appendix A to
the Proposed Amici Brief attached hereto as Exhibit A.
5. Proposed Amici are news media companies and organizations that
represent the interests of journalists and news media in the United States.
Proposed Amici seek leave to file this brief in support of Defendant-Respondent’s
motion for leave to appeal because the issues presented are of great importance to
them. Specifically, Proposed Amici are concerned that allowing claims like those
made against Defendant-Respondent to survive a motion to dismiss will encourage
claims against members of the news media.
6. Given Proposed Amici’s substantial interests in this matter, as described
above and in the attached Proposed Amici Brief, I respectfully submit that the
Proposed Amici Brief will be of special assistance to the Court in ruling on
Defendant-Respondent’s motion for leave to appeal. The Proposed Amici Brief
presents arguments that might otherwise escape the Court’s consideration as to the

 impact its decision could have on the news media generally, and provide further
support for Defendant-Respondent’s request for further review of that decision by
the Court of Appeals.
7. Proposed Amici have attempted to obtain Plaintiff-Appellant’s consent to
the filing of its Proposed Amici Brief via a request made through U.S. Mail.
Defendant-Respondent consents to the filing of the Proposed Amici Brief.
8. WHEREFORE, I respectfully request that the instant motion be granted
in all respects and that Proposed Amici be given leave to file the attached brief in
this appeal.
Dated:

New York, NY
April 4, 2017
/s/ Joseph M. Finnerty
Joseph M. Finnerty

 Exhibit A

SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: THIRD DEPARTMENT
CHRISTOPHER PORCO,
Plaintiff-Appellant,

Case No. 522707

-againstLIFETIME ENTERTAINMENT SERVICES, LLC,
Defendant-Respondent.

BRIEF OF
THE REPORTERS COMMITTEE FOR FREEDOM OF THE PRESS AND
14 ADDITIONAL MEDIA ORGANIZATIONS AS AMICI CURIAE IN
SUPPORT OF DEFENDANT-RESPONDENT
JOSEPH M. FINNERTY
BARCLAY DAMON LLP
1270 Avenue of the Americas,
Suite 600
New York, NY 10020
(212) 784-5800
jfinnerty@barclaydamon.com
Counsel for Amici Curiae
Of Counsel:
BRUCE D. BROWN
GREGG P. LESLIE
ARIEL B. GLICKMAN
THE REPORTERS COMMITTEE
FOR FREEDOM OF THE PRESS
1156 15th Street NW, Suite 1250
Washington, D.C. 20005
(202) 795-9300
(Additional counsel listed on inside cover)
Clinton County Clerk’s Index No. 190/13

 RICHARD A. BERNSTEIN
SABIN, BERMANT & GOULD LLP
One World Trade Center
New York, NY 10007
Counsel for Advance Publications, Inc.
SAVALLE SIMS
Exec. V.P., Deputy Gen. Counsel
LEAH MONTESANO
V.P., Litigation
DISCOVERY COMMUNICATIONS, LLC
One Discovery Place
Silver Spring, MD 20910
BARBARA W. WALL
Senior Vice President
& Chief Legal Officer
GANNETT CO., INC.
7950 Jones Branch Drive
McLean, VA 22107
JAMES CREGAN
Executive Vice President
MPA – THE ASSOCIATION OF
MAGAZINE MEDIA
1211 Connecticut Avenue NW
Suite 610
Washington, DC 20036
MICKEY H. OSTERREICHER
1100 M&T Center, 3 Fountain Plaza
Buffalo, NY 14203
Counsel for National Press
Photographers Association

BETH R. LOBEL, ESQ.
Senior Vice President
NBCUNIVERSAL NEWS GROUP
NBCUNIVERSAL MEDIA, LLC
30 Rockefeller Plaza
New York, NY 10112
DAVID MCCRAW
V.P./Assistant General Counsel
THE NEW YORK TIMES COMPANY
620 Eighth Avenue
New York, NY 10018
LAURA R. HANDMAN
ALISON SCHARY
DAVIS WRIGHT TREMAINE LLP
1919 Pennsylvania Avenue NW
Suite 800
Washington, DC 20006
THOMAS R. BURKE
DAVIS WRIGHT TREMAINE LLP
500 Montgomery Street
San Francisco, CA 94111
Counsel for Online News Association
BRUCE E. H. JOHNSON
DAVIS WRIGHT TREMAINE LLP
1201 Third Ave., Suite 2200
Seattle, WA 98101
Counsel for The Seattle Times Co.
BRUCE W. SANFORD
MARK I. BAILEN
JAMES ROMOSER
BAKER & HOSTETLER LLP
1050 Connecticut Ave. NW
Suite 1100
Washington, DC 20036
Counsel for Society of Professional
Journalists

 TABLE OF CONTENTS
TABLE OF AUTHORITIES .................................................................................... ii 
IDENTITY AND INTEREST OF AMICI CURIAE ................................................. 1 
SUMMARY OF ARGUMENT ................................................................................ 2 
ARGUMENT ............................................................................................................ 3
I.

The Court's decision addresses issues of substantial importance to the news
media which warrant consideration by the Court of Appeals. ....................... 3
A.

The scope of liability under Section 51 and its application to alternative
forms of communication about a matter of public interest affect the
news media. ............................................................................................ 3

B.

Early disposition of Section 51 claims arising out of the publication of
newsworthy information is an issue of critical importance to the news
media. ..................................................................................................... 5

 

i

 TABLE OF AUTHORITIES
Cases ............................................................................................................... Page(s) 
Finger v. Omni Publ’ns. Int’l, 566 N.E.2d 141 (N.Y. 1990) .................................... 3
Messenger ex rel. Messenger v. Gruner + Jahr Printing & Publ’g, 727 N.E.2d 549
(N.Y.), cert. denied, 531 U.S. 818 (2000)) ............................................................ 4
Statutes 
New York Civil Rights Law § 51 ......................................................................... 1, 2
Other Authorities 
Mem. ..................................................................................................................... 2, 3
Vincent Blasi, The Checking Value in First Amendment Theory, 1977 AM. B.
FOUND. RES. J. 521 (1977) ..................................................................................... 6

ii

 IDENTITY AND INTEREST OF AMICI CURIAE
Amici, filing in support of Defendant-Respondent Lifetime Entertainment
Services, LLC (“Lifetime”), urge this Court to grant Lifetime leave to appeal the
Court’s order reversing the Supreme Court’s order granting Lifetime’s motion to
dismiss and allowing Plaintiff’s commercial misappropriation claim under New
York Civil Rights Law § 51 to proceed. This Court’s order addresses issues of
significant importance to amici which warrant consideration by the Court of
Appeals.
Amici are Advance Publications, Inc., the Center for Investigative Reporting,
Discovery Communications, LLC, Gannett Co., Inc., Investigative Reporting
Workshop at American University, Media Law Resource Center, MPA – The
Association of Magazine Media, National Press Photographers Association,
NBCUniversal Media, LLC, The New York Times Company, Online News
Association, Radio Television Digital News Association, the Reporters Committee
for Freedom of the Press, The Seattle Times Company, and the Society of
Professional Journalists.
Amici publish, broadcast, produce, and distribute constitutionally protected
material of interest and concern to millions of New Yorkers on a regular basis, or
represent the interests of journalists and news media organizations that do.1 Amici

1

A full description of amici is set forth in Appendix A to this brief.
1

 write to emphasize the significance of this case to members of the news media who
routinely develop and disseminate journalistic works about matters of public
interest. Amici depend upon the existence of clear legal protections for gathering
and reporting information to the public, including information about matters of
public interest that, given their format, may not readily be identified as “hard
news.” Because amici are concerned that this Court’s decision, absent further
appellate review, will create uncertainty concerning the scope of liability under
Civil Rights Law § 51 and could encourage prolonged litigation against members
of the news media, amici respectfully urge this Court to grant Lifetime’s motion
for leave to appeal.
SUMMARY OF ARGUMENT
Plaintiff Christopher Porco’s complaint in this case arises out of Defendant
Lifetime Entertainment’s film, Romeo Killer: The Chris Porco Story (“Romeo
Killer”), a dramatized portrayal of a newsworthy event: a murder of which the
Plaintiff was convicted. The Supreme Court’s order below, dismissing Plaintiff’s
complaint for failure to state a cause of action, was reversed by this Court on the
basis of an allegation concerning a producer’s reference in a letter to “a nonfictional program” to run “after [Romeo Killer] airs.” Mem. at 4. The Court held
that the producer’s statement was sufficient to “suggest[ ]” that Lifetime
“knowingly produced a materially and substantially fictitious biography” of

2

 Plaintiff and, thus, that the allegations of his complaint were sufficient to state a
cause of action under Civil Rights Law § 51 (“Section 51”). Id. at 2.
The news media have a substantial interest in ensuring (1) that the scope of
liability under Section 51 for the creation and dissemination of factual
information—regardless of format—is both clearly and narrowly defined and (2)
that claims brought under Section 51 that are based on newsworthy publications
are properly dismissed at the pleading stage. Given the importance of these issues
to journalists and news organizations, amici respectfully urge this Court to grant
Lifetime’s motion for leave to appeal.
ARGUMENT
I.

The Court’s decision addresses issues of substantial importance to the
news media which warrant consideration by the Court of Appeals.
A.

The scope of liability under Section 51 and its application to
alternative forms of communication about a matter of public
interest affect the news media.

As stated in this Court’s opinion, the legislature intended for Section 51 to
be “strictly limited to nonconsensual commercial appropriations of the name,
portrait or picture of a living person.” Mem. at 2 (quoting Finger v. Omni Publ’ns.
Int’l, 566 N.E.2d 141, 143 (N.Y. 1990). Moreover, it has long been recognized
that Section 51 does “not apply to reports of newsworthy events or matters of
public interest.” Id. (quoting Messenger ex rel. Messenger v. Gruner + Jahr

3

 Printing & Publ’g, 727 N.E.2d 549, 552 (N.Y.), cert. denied, 531 U.S. 818
(2000)).
Members of the news media, who may face frivolous lawsuits brought under
Section 51 for their reporting, have a strong interest in ensuring that the scope of
liability for commercial appropriation under that provision is consistently given a
narrow interpretation, and that the newsworthiness exception to Section 51 is
interpreted broadly enough to ensure adequate breathing space for free speech on
matters of public interest, regardless of the format in which speech is presented.
In a digital age where more people are obtaining information through social
media and messaging applications, news outlets are developing new ways to
convey news to the public. The practice of journalism is expanding to include new
types of application and web-based presentations and video productions, with some
formats used to provide a first-person narrative or a stand-alone interview, while
others simply present information in a traditional journalistic manner.
Many news outlets also employ a combination of different approaches to
provide the public with a complete “package” of information. The New York
Times, for example, engages the public with a number of different forms of
storytelling by offering morning, evening, and live briefings, visual articles
accompanied by graphics that include interactive audio and video content, and a
podcast called “The Daily.” News organizations may also use non-traditional
4

 elements and representational footage to report on crime. These various formats
can appeal to a vast audience while at the same time giving individual readers and
viewers a wide array of choices on how to receive information which interests
them.
In short, because publishers strive to make the audience’s experience of
reading, watching, and/or hearing a story as captivating as the story itself, news
organizations rely on multiple ways of delivering journalism. While the different
methods employed may change the way a story is told, that alone does not
diminish the truthfulness of one form of storytelling merely because the reporter
does a follow-up using another format. For that reason, the issue presented by this
case—namely, the scope of liability under Section 51 for the creation and
dissemination of factual information in a dramatic format, particularly if that
format is viewed as the opposite of a factual or “nonfiction” work—is an issue of
existential significance to the news media, and one that warrants consideration by
the Court of Appeals.
B.

Early disposition of Section 51 claims arising out of the
publication of newsworthy information is an issue of critical
importance to the news media.

Journalists and news organizations play a vital role in our democracy. “The
inevitable size and complexity of modern government” requires “well-organized,
well-financed, professional critics to serve as a counterforce to government—

5

 critics capable of acquiring enough information to pass judgment on the actions of
government, and also capable of disseminating their information and judgments to
the general public.” Vincent Blasi, The Checking Value in First Amendment
Theory, 1977 AM. B. FOUND. RES. J. 521, 541 (1977). In order to perform this
function effectively for the benefit of the public, journalists and news organizations
need strong protections from the threat of prolonged, frivolous litigation.
This Court’s decision reversing the Supreme Court’s order granting
Lifetime’s motion to dismiss Plaintiff’s complaint calls into question when a media
defendant may successfully obtain dismissal of a complaint at the pleading stage
on the basis of the newsworthiness exception to Section 51 liability. Because the
threat of increased and protracted litigation has a chilling effect on speech, review
of this matter by the Court of Appeals is necessary to maintain New York’s robust
record defending the flow of information to the public.

6

 CONCLUSION
For the foregoing reasons, amici respectfully urge this Court to grant
Lifetime’s motion for leave to appeal.
Dated:

New York, NY
April 4, 2017
Respectfully submitted,
BARCLAY DAMON LLP
/s/ Joseph M. Finnerty
By: Joseph M. Finnerty
1270 Avenue of the Americas,
Suite 600
New York, NY 10020
(212) 784-5800
jfinnerty@barclaydamon.com
Attorney for Amici Curiae

Of Counsel:
Bruce D. Brown
Gregg P. Leslie
Ariel B. Glickman
THE REPORTERS COMMITTEE
FOR FREEDOM OF THE PRESS
1156 15th Street NW, Suite 1250
Washington, D.C. 20005
(202) 795-9300

 PRINTING SPECIFICATIONS STATEMENT
I hereby certify pursuant to 22 NYCRR § 600.10 that the foregoing brief
was prepared on a computer using Microsoft Word.
Type. A proportionally spaced typeface was used, as follows:
Name of typeface: Times New Roman
Point size: 14
Line spacing: Double
Word Count. The total number of words in this brief, inclusive of point
headings and footnotes and exclusive of pages containing the table of contents,
table of citations, proof of service and this Statement is 1,337.
Dated:

New York, NY
April 4, 2017

 APPENDIX A: DESCRIPTION OF AMICI
Advance Publications, Inc., directly and through its subsidiaries, publishes
more than 20 print and digital magazines with nationwide circulation, local news in
print and online in 10 states, and leading business journals in over 40 cities
throughout the United States. Through its subsidiaries, Advance also owns
numerous digital video channels and internet sites and has interests in cable
systems serving over 2.3 million subscribers.
The Center for Investigative Reporting (CIR) believes journalism that
moves citizens to action is an essential pillar of democracy. Since 1977, CIR has
relentlessly pursued and revealed injustices that otherwise would remain hidden
from the public eye. Today, we're upholding this legacy and looking forward,
working at the forefront of journalistic innovation to produce important stories that
make a difference and engage you, our audience, across the aisle, coast to coast
and worldwide.
Discovery Communications LLC satisfies curiosity and engages superfans
with a portfolio of premium nonfiction, sports and kids programming brands.
Reaching 3 billion cumulative viewers across pay-TV and free-to-air platforms in
more than 220 countries and territories, Discovery’s portfolio includes the global
brands Discovery Channel, TLC, Investigation Discovery, Animal Planet, Science
and Turbo/Velocity, as well as OWN: Oprah Winfrey Network in the U.S.,
Discovery Kids in Latin America, and Eurosport, the leading provider of locally
relevant, premium sports content across Europe. Discovery reaches audiences
across screens through digital platforms, as well as over-the-top and TV
Everywhere offerings, including Eurosport Player, Dplay, Discovery K!ds Play
and Discovery GO.
Gannett Co., Inc. is an international news and information company that
publishes 109 daily newspapers in the United States and Guam, including USA
TODAY. Each weekday, Gannett’s newspapers are distributed to an audience of
more than 8 million readers and the digital and mobile products associated with the
company’s publications serve online content to more than 100 million unique
visitors each month.
The Investigative Reporting Workshop, a project of the School of
Communication (SOC) at American University, is a nonprofit, professional
newsroom. The Workshop publishes in-depth stories at
investigativereportingworkshop.org about government and corporate
A-1

 accountability, ranging widely from the environment and health to national
security and the economy.
The Media Law Resource Center, Inc. (“MLRC”) is a non-profit
professional association for content providers in all media, and for their defense
lawyers, providing a wide range of resources on media and content law, as well as
policy issues. These include news and analysis of legal, legislative and regulatory
developments; litigation resources and practice guides; and national and
international media law conferences and meetings. The MLRC also works with its
membership to respond to legislative and policy proposals, and speaks to the press
and public on media law and First Amendment issues. The MLRC was founded in
1980 by leading American publishers and broadcasters to assist in defending and
protecting free press rights under the First Amendment.
MPA – The Association of Magazine Media, (“MPA”) is the largest
industry association for magazine publishers. The MPA, established in 1919,
represents over 175 domestic magazine media companies with more than 900
magazine titles. The MPA represents the interests of weekly, monthly and
quarterly publications that produce titles on topics that cover politics, religion,
sports, industry, and virtually every other interest, avocation or pastime enjoyed by
Americans. The MPA has a long history of advocating on First Amendment issues.
The National Press Photographers Association (“NPPA”) is a 501(c)(6)
non-profit organization dedicated to the advancement of visual journalism in its
creation, editing and distribution. NPPA’s approximately 7,000 members include
television and still photographers, editors, students and representatives of
businesses that serve the visual journalism industry. Since its founding in 1946, the
NPPA has vigorously promoted the constitutional rights of journalists as well as
freedom of the press in all its forms, especially as it relates to visual journalism.
The submission of this brief was duly authorized by Mickey H. Osterreicher, its
General Counsel.
NBCUniversal Media, LLC is one of the world’s leading media and
entertainment companies in the development, production and marketing of news,
entertainment and information to a global audience. Among other businesses,
NBCUniversal Media, LLC owns and operates the NBC television network, the
Spanish-language television network Telemundo, NBC News, several news and
entertainment networks, including MSNBC and CNBC, and a television-stations
group consisting of owned-and-operated television stations that produce substantial
amounts of local news, sports and public affairs programming. NBC News
A-2

 produces the “Today” show, “NBC Nightly News with Lester Holt,” “Dateline
NBC” and “Meet the Press.”
The New York Times Company is the publisher of The New York
Times and The International Times, and operates the news website nytimes.com.
Online News Association (“ONA”) is the world’s largest association of
online journalists. ONA’s mission is to inspire innovation and excellence among
journalists to better serve the public. ONA’s more than 2,000 members include
news writers, producers, designers, editors, bloggers, technologists, photographers,
academics, students and others who produce news for the Internet or other digital
delivery systems. ONA hosts the annual Online News Association conference and
administers the Online Journalism Awards. ONA is dedicated to advancing the
interests of digital journalists and the public generally by encouraging editorial
integrity and independence, journalistic excellence and freedom of expression and
access.
Radio Television Digital News Association (“RTDNA”) is the world’s
largest and only professional organization devoted exclusively to electronic
journalism. RTDNA is made up of news directors, news associates, educators and
students in radio, television, cable and electronic media in more than 30 countries.
RTDNA is committed to encouraging excellence in the electronic journalism
industry and upholding First Amendment freedoms.
The Reporters Committee for Freedom of the Press is a voluntary,
unincorporated association of reporters and editors that works to defend the First
Amendment rights and freedom of information interests of the news media. The
Reporters Committee has provided assistance and research in First Amendment
and Freedom of Information Act litigation since 1970.
The Seattle Times Company, locally owned since 1896, publishes the daily
newspaper The Seattle Times, together with The Issaquah Press, Yakima HeraldRepublic, Walla Walla Union-Bulletin, Sammamish Review and Newcastle-News,
all in Washington state.
Society of Professional Journalists (“SPJ”) is dedicated to improving and
protecting journalism. It is the nation’s largest and most broad-based journalism
organization, dedicated to encouraging the free practice of journalism and
stimulating high standards of ethical behavior. Founded in 1909 as Sigma Delta
Chi, SPJ promotes the free flow of information vital to a well-informed citizenry,
A-3

 works to inspire and educate the next generation of journalists and protects First
Amendment guarantees of freedom of speech and press.

A-4

 CERTIFICATE OF SERVICE
I hereby certify that I caused to be served a true and correct copy of the foregoing
amicus brief to be served by U.S. mail to:
David A. Schulz
Cameron Stracher
Levine Sullivan Koch & Schulz, LLP
321 West 44th Street
Suite 1000
New York, NY 10036
Counsel for Defendant Lifetime Entertainment Services, LLC
Christopher Porco, Inmate
#06A6686
Clinton Correctional Facility
P.O. Box 2001
Dannemora, NY 12929
Plaintiff Pro Se
Dated: April 4, 2017
/s/ Ariel B. Glickman
Ariel B. Glickman