Case 2:16-cv-14003-LMA-KWR Document 69 Filed 08/10/17 Page 1 of 16

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
-----------------------------------------------------ANA CHRISTINE SHELTON, in her capacity as
the natural tutrix of S.A. and T.A. and as the
administratix of Nelson Arce’s succession, and AMENDED COMPLAINT
LAZARO ARCE,
JURY TRIAL DEMANDED
Plaintiffs,
v.
THE STATE OF LOUISIANA; THE LOUISIANA
DEPARTMENT OF PUBLIC SAFETY AND
CORRECTIONS; THE PARISH OF JEFFERSON,
as the political entity that owns the Jefferson Parish
Correctional Center; and NEWELL NORMAND,
in his official capacity as the Sheriff of Jefferson
Parish;
Defendants.
-----------------------------------------------------PRELIMINARY STATEMENT
1.

Nelson Acre (herein after “Nelson” or “N. Arce”) was a deaf individual who communicated

primarily in American Sign Language (“ASL”), which was his expressed, preferred, and most effective
means of communication. Plaintiff Lazaro Arce (hereinafter “Mr. Arce” or “Plaintiff L. Arce”) is a
hearing individual and is Nelson Arce’s father. Nelson Arce passed away on May 9, 2017. He was survived
by his two minor children, T.A. and S.A. Plaintiff Ana Christine Shelton is the mother and natural tutrix
of T.A. and S.A. and the administratrix of Nelson Arce’s succession. Prior to his death, Nelson was
arrested regarding a drug related offense and was brought before Courts in both Jefferson and Plaquemines
Parishes, where he was sentenced to four years of probation with mandatory inpatient drug treatment.
Throughout the court process and N. Arce’s sentence, Defendants repeatedly discriminated against Nelson
and Lazaro Arce by failing and/or refusing to provide auxiliary aids and services necessary to ensure

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effective communication with N. Arce regarding complex and emotionally fraught matters. Defendants
repeatedly required Plaintiff L. Arce, who is not a qualified interpreter, to act as an interpreter for N. Arce.
As a result, N. Arce was unable to meaningfully engage in the court process and probation services, and
was unnecessarily incarcerated. Plaintiff L. Arce suffered emotional distress as a direct result of being
required to interpret legal matters of which he did not have an adequate understanding. L. Arce suffered
guilt surrounding Nelson’s incarceration as he was concerned that his lack of sufficient understanding and
interpretation directly resulted in Nelson’s misunderstanding of the terms and conditions of his probation.
Additionally, during Nelson’s incarceration at Jefferson Parish Correction Center (JPCC), Defendants
discriminated against him by failing and/or refusing to provide auxiliary aids and services necessary to
ensure effective communication with him. As a result, he was unable to understand the facility’s
expectations of him or the punishment he received when he failed to meet those expectations. Plaintiffs
seek declaratory, injunctive, and equitable relief; compensatory and exemplary damages; and attorneys’
fees and costs to redress Defendant’s unlawful discrimination on the basis of disability in violation of Title
II of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12181 et seq.; and Section 504 of the
Rehabilitation Act of 1973 (“RA”), 29 U.S.C. § 794.
2.

Based on Plaintiffs’ allegations herein, it is evident that Defendants have failed to

implement policies and to train their employees regarding the civil rights and communication needs of
deaf individuals. Plaintiffs bring this action to compel Defendants to cease unlawful discriminatory
practices and implement policies and procedures that will ensure effective communication, full and equal
enjoyment, and a meaningful opportunity for deaf individuals to participate in and benefit from
Defendants’ services.
NATURE OF THE CLAIMS
3.

Plaintiffs bring this lawsuit to compel Defendants to cease unlawful discriminatory

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practices and implement policies and procedures that will ensure effective communication, full and equal
enjoyment, and a meaningful opportunity to participate in and benefit from their services. Plaintiffs seek
declaratory and equitable relief, monetary damages, and attorneys’ fees to redress Defendants’ unlawful
discrimination on the basis of disability in violation of the United States Constitution, pursuant to 42
U.S.C. § 1983; the Americans with Disabilities Act (ADA), 42 U.S.C. § 12131 et seq., and its
implementing regulation, 28 C.F.R. Part 35 and Section 504 of the Rehabilitation Act of 1973, 29 U.S.C.
§ 791.
THE PARTIES
4.

NELSON ARCE (hereinafter “Nelson” or “L. Arce”) was an individual residing at 3812

Crossmoor Drive, Marrero, LA 70072. Nelson was profoundly deaf and communicated primarily in
American Sign Language. He was substantially limited in the major life activities of hearing and speaking,
and was a qualified person with a disability within the meaning of the ADA and the Rehabilitation Act.
Nelson Arce passed away on May 9, 2017. He was never married and resided in Louisiana at the time of
his death. Nelson Arce was survived by his two minor children S.A. and T.A.
5.

Plaintiff ANA CHRISTINE SHELTON (herein after “Ms. Shelton” or “Plaintiff Shelton”)

is the mother and natural tutrix of T.A. and S.A. Ms. Shelton has letters of tutorship for both S.A. and
T.A. Additionally, Ms. Shelton is the independent administratrix of Nelson Arce’s succession. Pursuant
to State and Federal law, Nelson Arce’s claims survive his death in favor of Ms. Shelton in her capacity
as the natural tutrix of his surviving children and in her capacity as the administratrix of his succession.
6.

Plaintiff LAZARO ARCE (hereinafter “L. Arce”) is an individual residing at 3812

Crossmoor Drive, Marrero, LA 70072. Mr. Arce is hearing and is Nelson’s father.
7.

Defendant THE STATE OF LOUISIANA is a state government.

8.

Defendant THE LOUISIANA DEPARTMENT OF PUBLIC

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CORRECTIONS is a governmental agency of The State of Louisiana.
9.

The JEFFERSON PARISH CORRECTIONAL CENTER (hereinafter the “JPCC”) is a

correctional facility run by the Louisiana Department of Public Safety and Corrections, Division of
Probation and Parole, Jefferson Parish.
10.

Defendant THE PARISH OF JEFFERSON, as the political entity that owns the Jefferson

Parish Correctional Center, is a municipal entity.
11.

Defendant NEWELL NORMAND, the Sheriff of Jefferson Parish, is sued in his official

capacity and is the political official responsible for the administration of the Jefferson Parish Correctional
Center.
12.

As the owner of the facility where the correctional programs discussed below are offered,

THE PARISH OF JEFFERSON is obligated to comply with the requirements of the ADA.
13.

As the operator and administrator of the correctional services which are offered at the

JPCC, NEWELL NORMAND is obligated to comply with the requirements of the ADA.
14.

As the operator and administrator of the probation services discussed below, the STATE

OF LOUISIANA and THE LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS
are obligated to comply with the requirements of the ADA.
15.

Defendants THE STATE OF LOUISIANA, THE LOUISIANA DEPARTMENT OF

PUBLIC SAFETY AND CORRECTIONS, THE PARISH OF JEFFERSON, and NEWELL NORMAND
are each public entities and recipients of federal financial assistance, thus making each entity identified
above subject to the requirements of the ADA and the Rehabilitation Act.
16.

Defendants are jointly obligated to comply with the requirements of the ADA.
JURISDICTION & VENUE

17.

This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §§

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1331 and 1343 for Plaintiffs’ claims arising under federal law.
18.

Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) because the Defendants

reside within the jurisdiction of this District, and/or a substantial part of the events that give rise to the
claims occurred in this District, and/or the Defendants have sufficient contacts with this District to subject
it to personal jurisdiction at the time this action is commenced.
STATEMENT OF FACTS
19.

Nelson was profoundly deaf and communicated primarily in American Sign Language

20.

Plaintiff Nelson had limited proficiency in written English, and required auxiliary aids and

(ASL).

services to communicate effectively regarding legal matters.
21.

Plaintiff L. Arce is Nelson’s father. L. Arce is hearing.

22.

On May 9, 2017, Nelson Arce passed away.

23.

During his life, Nelson Arce never married.

24.

At the time of his death, Nelson Arce resided in Louisiana.

25.

T.A. and S.A. are Nelson Arce’s surviving minor children. Aside from T.A. and S.A.,

Nelson Arce had no other surviving children.
26.

Plaintiff Shelton is the mother of T.A. and S.A. She holds letters of tutorship for T.A. and

S.A. and is the independent administratrix of the succession of Nelson Arce.
27.

Pursuant to a February 9, 2015 order of Judge Michael P. Mentz, N. Arce was sentenced

to two years of active probation and two years of inactive probation with a condition that he enter and
complete an in-house substance abuse treatment program approved by the Probation Department.
28.

One term of N. Arce’s probation required him to meet with Probation Officer Maise

regularly.

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29.

Defendants failed to provide ASL interpreters for any of N. Arce’s meetings with Probation

Officer Maise.
30.

Defendants and Probation Officer Maise were aware that N. Arce was deaf and required a

sign language interpreter to effectively communicate.
31.

Upon information and belief, the assigned probation officer is required to explain the terms

and conditions of probation to the probationer during their first meeting.
32.

Upon information and belief, Probation Officer Maise routinely explains the terms and

conditions of probation to her hearing probationers during her first meeting with them.
33.

Probation Officer Maise never utilized an ASL interpreter to explain the terms and

conditions of probation to N. Arce at any time.
34.

Probation Officer Maise relied on L. Arce to interpret for N. Arce despite both N. Arce’s

and L. Arce’s repeated requests for qualified interpreters.
35.

N. Arce, with the assistance of his father, was able to secure a bed at an inpatient drug

treatment facility for the deaf in California. In an attempt to comply with the Court’s order, N. Arce
enrolled in that program on or about October 9, 2015 and went to California to engage in its services.
36.

On or about October 12, 2015 the program in California sent a letter to the Court informing

the Court that Nelson was enrolled in and engaging in their inpatient program with an anticipated duration
of approximately one year.
37.

On or about October 20, 2015, Probation Officer Maise filed a Motion and Order for

hearing to revoke N. Arce’s probation because he had left the State in violation of the terms and conditions
of Probation.
38.

At no time between February 9, 2015 and October 20, 2015 had Defendants provided an

interpreter to explain the terms and conditions of Probation to N. Arce and L. Arce in American Sign

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Language. For this reason, N. Arce was not aware that leaving the State to attend drug treatment as
ordered by the Court was a violation of his probation.
39.

On or about December 8, 2015, Judge Michael P. Mentz found that Nelson had committed

a technical violation of the conditions of his probation by leaving the state of Louisiana and ordered Nelson
to serve 90 days at the JPCC. Judge Mentz further ordered, among other things that upon Nelson’s release
from JPCC, Nelson was to immediately meet with his probation officer and was to enter and complete a
an in-house substance abuse program approved by the probation department.
40.

Nelson was incarcerated at JPCC from on or about December 8, 2015 to on or about March

7, 2016 as a result of the probation violation.
41.

During Nelson’s incarceration at JPCC, inmates were entitled to two (2) thirty (30) minute

telephone conversations per day. JPCC did not have video phones installed at the facility, but did have a
TTY machine.
42.

Throughout his approximately three month stay at JPCC, there were several instances when

Nelson was provided no access to the TTY machine or was provided access to the TTY machine only
once a day. Other inmates continued to receive two (2) thirty (30) minute telephone conversations per
day during that time.
43.

At one point during his stay, Nelson was informed that he would only be provided access

to the TTY machine once per day for the remainder of his stay at JPCC. Other inmates continued to
receive two (2) thirty (30) minute telephone conversations per day during that time.
44.

During Nelson’s incarceration, JPCC utilized a publication entitled “The Inmate

Handbook” (Handbook) to outline inmates’ expected conduct while inside the facility. Upon information
and belief, the Handbook details the rules and regulations for the facility and the consequences for
breaking said rules and regulations. The Handbook is in written English. At no time was Nelson provided

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with a live ASL interpreter to read the Handbook to him in ASL to ensure that Nelson understood the
Handbook.
45.

Despite not being provided with interpretation of the Handbook and not understanding the

Handbook, Nelson was penalized on two separate occasions (December 16, 2015 and January 25, 2016)
for disciplinary infractions in violation of rules contained in the Handbook.
46.

Following the January 25, 2016 “infraction,” Nelson was placed on restriction. As a part

of this restriction, Nelson was without Visitation and without any means of communication with persons
outside of JPCC for 14 days. Nelson is still unaware of what rule he violated resulting in this restriction.
47.

L. Arce requested interpretation of the Handbook for Nelson, but this request was denied.

Specifically, L. Arce was informed that Nelson is an adult and “can ask for assistance whenever he needs
it.”
48.

Nelson was released from Jefferson Correctional Center on or about March 7, 2016.

49.

Pursuant to the terms and conditions of Nelson’s parole, Nelson reported to the Jefferson

Parish District Department of Corrections Office of Probation and Parole (JPD) the day following his
release. At this time, he met with Probation Officer Maise.
50.

Probation Officer Maise had been Nelson’s probation officer since February 9, 2015 and

knew Nelson was deaf and required an ASL interpreter to effectively communicate.
51.

Probation Officer Maise was aware that Nelson was scheduled to meet with her following

his release from JCPP pursuant to the terms and conditions of his probation.
52.

During Nelson’s meeting with Probation Officer Maise immediately following his release

from JPCC, no ASL Interpreter was provided. Probation Officer Maise attempted to write instructions to
Nelson in English during this visit. Upon information and belief, Nelson did not understand these
instructions and informed Probation Officer Maise that he was leaving the meeting because there was no

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ASL interpreter present. Probation Officer Maise then handed Nelson a list of Interpreting agencies in
the area and instructed him to secure an interpreter for the next meeting. Nelson informed Probation
Officer Maise that it is the Office of Probation and Parole’s responsibility to provide an ASL interpreter.
Immediately following that meeting, Probation Officer Maise informed L. Arce that in her 25 years of
working for the State, the State does not provide any form of interpreting services and that obtaining an
interpreter was thus Nelson’s responsibility. Nelson was scheduled to meet with Probation Officer Maise
again on March 23, 2016.
53.

On March 22, 2016, Probation Officer Maise emailed Plaintiffs cancelling the March 23,

2016 meeting because she had been unable to secure an interpreter for the appointment. Instead of
securing an ASL interpreter, Probation Officer Maise told Nelson that she would meet him at his scheduled
court appearance – for an unrelated offense – and request the use of the interpreter secured by the Court.
54.

L Arce reached out to Probation Officer Maise via email and telephone to inquire as to the

reason no sign language interpreter was being provided. No explanation was provided.
55.

Nelson was accepted into a dual treatment program in Georgia which regularly works with

persons with disabilities, such as Nelson.
56.

Upon Nelson’s request, the Court approved the transfer of Nelson’s probation to Georgia.

57.

N. Arce and L. Arce met with Probation Officer Maise to sign paperwork regarding the

orders and conditions of Nelson’s transfer to Georgia. At that time, no ASL interpreter was provided. N.
Arce and L. Arce again requested an ASL interpreter. Probation Officer Maise insisted that L. Arce
interpret. L. Arce indicated that he did not feel comfortable interpreting. Probation Officer Maise
indicated that if L. Arce did not interpret for Nelson, Nelson would have to return on or about July 27,
2016 so that an ASL interpreter could be present. Upon information and belief, by that date, the bed at
the treatment facility in Georgia would no longer be available. For that reason, L. Arce agreed to interpret.

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Because L. Arce is not a certified legal interpreter, Nelson did not fully understand the conditions of his
transfer to Georgia.
Further Allegations
58.

Upon information and belief, Defendants were aware of Nelson’s obvious disability, as

both Plaintiffs brought it to Defendants’ attention.
59.

Defendants’ staff failed to undertake any meaningful assessment of Nelson’s

communication needs and abilities.
60.

Defendants’ staff never asked Nelson about his communication preference.

61.

Defendants’ staff ignored L Arce’s requests regarding Nelson’s communication needs and

abilities and communication preference.
62.

Defendant’s staff often forced Nelson to attempt to communicate through either lip-reading

or reading or writing in English, neither of which are effective modes of communication for Nelson in a
legal setting.
63.

Defendants’ staff often forced L Arce to act as an interpreter for Nelson. L. Arce is not a

certified ASL interpreter and given the complexity of the subject matter and the emotional connection L.
Arce has to the subject matter, utilizing him as an interpreter was inappropriate.
64.

As a result of Defendants’ failure to ensure effective communication with Nelson, he

received services that were objectively substandard and that were inferior to those provided to
litigants/inmates/probationers who are hearing, was unnecessarily incarcerated, and was subjected to
discriminatory treatment because of his disability.
65.

Defendants intentionally discriminated against N. Arce and L. Arce with deliberate

indifference to their rights and to Nelson’s communication needs, causing N. Arce and L. Arce to endure
loss of liberty, humiliation, fear, anxiety, isolation, guilt, and emotional distress.

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CLAIM 1: VIOLATIONS OF TITLE II OF THE AMERICANS WITH DISABILITIES
ACT
66.

Plaintiffs repeat and reallege all preceding paragraphs in support of this claim.

67.

At all times relevant to this action, Title II of the ADA, 42 U.S.C. § 12131, et seq. has been

in full force and effect and has applied to Defendants’ conduct.
68.

At all times relevant to this action, the United States Department of Justice regulations

implementing Title II of the ADA, 28 C.F.R. Part 35, have been in full force and effect and have applied
to the Defendants’ conduct.
69.

At all times relevant to this action, N. Arce was substantially limited in the major life

activities of hearing and speaking, and was an individual with a disability within the meaning of the ADA,
42 U.S.C. § 12102(2).
70.

Defendants are public entities within the meaning of Title II of the ADA, 42 U.S.C. §

12131(1).
71.

Title II of the ADA provides that “no qualified individual with a disability shall, by reason

of such disability, be excluded from participation in or be denied the benefits of the services, programs,
or activities of a public entity, or be subjected to discrimination by any such entity.” 42 U.S.C. § 12132.
72.

Federal regulations implementing Title II of the ADA provide that a public entity may not

“(i) deny a qualified individual with a disability the opportunity to participate in or benefit from the aid,
benefit, or service; (ii) afford a qualified individual with a disability an opportunity to participate in or
benefit from the aid, benefit, or service that is not equal to that afforded others; [or] (iii) provide a qualified
individual with a disability with an aid, benefit, or service that is not as effective in affording equal
opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement
as that provided to others.” 28 C.F.R. § 35.130(b)(1).
73.

Federal regulations implementing Title II of the ADA further provide that “a public entity

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shall operate each service, program, or activity so that the service, program or activity, when viewed in its
entirety, is readily accessible to and usable by individuals with disabilities.” 28 C.F.R. § 35.150(a).
74.

Federal regulations implementing Title II of the ADA further provide that a public entity

“shall take appropriate steps to ensure that communications with applicants, participants, members of the
public, and companions with disabilities are as effective as communications with others.” 28 C.F.R. §
35.160(a)(1).
75.

Federal regulations implementing Title II of the ADA further provide that a public entity

“shall furnish appropriate auxiliary aids and services where necessary,” and “in order to be effective,
auxiliary aids and services must be provided in accessible formats, in a timely manner, and in such a way
as to protect the privacy and independence of the individual with a disability.” 28 C.F.R. § 35.160(b).
76.

Defendants discriminated against N. Arce and L. Arce, on the basis of disability, in

violation of Title II of the ADA and its implementing regulations.
77.

Plaintiffs are therefore entitled to injunctive relief, as well as an award of attorneys’ fees,

costs, and disbursements pursuant to the ADA, 42 U.S.C. § 12188(a)(1), and/or common law.
CLAIM 2: VIOLATIONS OF SECTION 504 OF THE REHABILITATION ACT
78.

Plaintiffs repeat and reallege all preceding paragraphs in support of this claim.

79.

At all times relevant to this action, Section 504 of the Rehabilitation Act, 29 U.S.C. § 794,

has been in full force and effect and has applied to Defendant’s conduct.
80.

At all times relevant to this action, the United States Department of Health and Human

Services (“HHS”) regulations implementing Section 504 of the Rehabilitation Act, 45 C.F.R. Part 84, have
been in full force and effect and have applied to Defendant’s conduct.
81.

At all times relevant to this action, N. Arce had substantial limitations to the major life

activities of hearing and speaking, and was an individual with a disability within the meaning of the

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Rehabilitation Act, 29 U.S.C. § 705(9).
82.

At all times relevant to this action, Defendants have been offering programs, services,

activities, or accommodations receiving federal financial assistance pursuant to 29 U.S.C. § 794(b).
83.

Section 504 of the Rehabilitation Act provides that “[n]o otherwise qualified individual

with a disability . . . shall, solely by reason of her or his disability, be excluded from the participation in,
be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal
financial assistance.” 29 U.S.C. § 794.
84.

The Rehabilitation Act extends relief to “any person aggrieved” by discrimination in

violation thereof. 29 U.S.C. § 794a(a)(2).
85.

Defendants discriminated against N. Arce and L. Arce, on the basis of disability, in

violation of 29 U.S.C. § 794.
86.

Plaintiffs are therefore entitled to seek and recover compensatory damages for the injuries

and loss he sustained as a result of Defendants’ discriminatory conduct and deliberate indifference as
hereinbefore alleged, pursuant to 29 U.S.C. § 794(a).
87.

Plaintiffs are further entitled to injunctive relief, as well as an award of attorneys’ fees,

costs, and disbursements pursuant to the Rehabilitation Act, 29 U.S.C. § 794(a) and/or common law.

PRAYER FOR RELIEF
WHEREFORE, Plaintiffs respectfully pray that this Court grant the following relief:
a.

Enter a declaratory judgment, pursuant to Rule 57 of the Federal Rules of Civil Procedure,

stating that Defendants’ policies, procedures, and practices have subjected N. Arce and L. Arce to
unlawful discrimination in violation of Title II of the Americans with Disabilities Act and Section 504 of
the Rehabilitation Act;

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b.

Issue an injunction forbidding Defendants from implementing or enforcing any policy,

procedure, or practice that denies deaf or hard of hearing individuals, or their companions, meaningful
access to and full and equal enjoyment of Defendants’ facilities, services or programs;
c.

Issue an injunction ordering Defendants:
i. to develop, implement, promulgate, and comply with a policy prohibiting future
discrimination against N. Arce and L. Arce or other deaf or hard of hearing individuals
and their companions by failing to provide effective communication;
ii. to develop, implement, promulgate, and comply with a policy requiring that a certified inperson legal ASL interpreter be provided to all deaf or hard of hearing individuals for
effective communication in all services offered by Defendants;
iii. to install video phones in all of their correctional facilities;
iv. to develop and implement a new system, or integrate into a currently existing system a
means of identifying litigants/inmates/parolees as Deaf, Deaf Blind, Deaf Disabled,
Hard of Hearing, and other persons with other disabilities;
v. to produce an ASL accessible version of any all information available on Defendants’
website including, but not limited to, inmate handbooks, sex offender registry, and
explanation of pre-release programs
vi. to create and maintain a list of sign language interpreters and ensure availability of such
interpreters at any time of day or night;
vii. to train all their employees, staffs, and other agents on a regular basis about the rights of
individuals who are deaf or hard of hearing under the ADA and the RA;

d. Award to Plaintiffs:
i. Compensatory damages pursuant to the ADA and the RA;

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ii. Reasonable costs and attorneys’ fees pursuant to the ADA and the RA;
iii. Interest on all amounts at the highest rates and from the earliest dates allowed by law;
iv. Any and all other relief that this Court finds necessary and appropriate.
DEMAND FOR JURY TRIAL
Plaintiffs demand trial by jury for all of the issues a jury properly may decide, and for all of the
requested relief that a jury may award.

Dated: July 10, 2017
Respectfully Submitted,
BIZER & DEREUS
Attorneys for Plaintiff
Andrew D. Bizer (LA # 30396)
andrew@bizerlaw.com
Garret S. DeReus (LA # 35105)
gdereus@bizerlaw.com
Marc P. Florman (LA # 35128)
mflorman@bizerlaw.com
3319 St. Claude Ave.
New Orleans, LA 70117
T: 504-619-9999; F: 504-948-9996
By:/s/ Andrew D. Bizer
Andrew D. Bizer
***AND***
EISENBERG & BAUM, LLP
24 Union Square East, Fourth Floor
New York, NY 10003
212-353-8700 (tel.)
212-353-1708 (fax)
Attorneys for Plaintiff
By:
________
Andrew Rozynski, Esq. (NY # 5054465)
Admitted Pro hac vice

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arozynski@eandblaw.com

Eric Baum, Esq. (NY # 2591618)
Admitted Pro hac vice
ebaum@eandblaw.com
___________________
Brittany Shrader, Esq. (NY # 4768909)
Admitted Pro hac vice
bshrader@eandblaw.com

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