Case 3:18-cv-00484-HEH Document 96 Filed 02/15/19 Page 1 of 16 PageID# 996

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION

ROY COCKRUM; SCOTT COMER; and
ERIC SCHOENBERG,
Plaintiffs,
v.
DONALD J. TRUMP FOR PRESIDENT,
INC.,
Defendant.

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Civil Action No. 3:18-cv-484-HEH

PLAINTIFFS’ SUPPLEMENTAL REPLY BRIEF ON CHOICE OF LAW

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TABLE OF CONTENTS
TABLE OF AUTHORITIES ........................................................................................................... i
CONCLUSION ................................................................................................................................9
CERTIFICATE OF SERVICE ......................................................................................................15

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TABLE OF AUTHORITIES
Federal Cases
ABLV Bank v. Center for Advanced Defense Studies Inc.,
2015 WL 12517012 (E.D. Va. April 21, 2015) ...................................................................... 7, 8
And Wiest v. E-Fense, Inc.,
356 F. Supp. 2d 604 (E.D. Va. 2005) ......................................................................................... 8
Beard v. Akzona, Inc.,
517 F. Supp. 128 (E.D. Tenn. 1981) .......................................................................................... 6
Brown v. Am. Broad. Co.,
704 F.2d 1296 (4th Cir. 1983) .................................................................................................... 6
Ford Motor Co. v. Nat’l Indem. Co.,
972 F. Supp. 2d 850 (E.D. Va. 2013) ..................................................................................... 2, 5
Gen. Assur. of Am., Inc. v. Overby-Seawell Co.,
893 F. Supp. 2d 761 (E.D. Va. 2012) ......................................................................................... 4
Insteel Industries, Inc. v. Costanza Contracting Co.,
276 F. Supp. 2d 479 (E.D. Va. 2003) ................................................................................. 2, 3, 5
Johnson v. Oroweat Foods Co.,
785 F.2d 503 (4th Cir. 1986) ...................................................................................................... 4
Mattox v. News Syndicate Co.,
176 F.2d 897 (2d Cir. 1949) ....................................................................................................... 8
McNally v. Pulitzer Pub. Co.,
532 F.2d 69 (8th Cir. 1976) ........................................................................................................ 6
Miller v. Holiday Inns, Inc.,
436 F. Supp. 460, 462 (E.D. Va. 1977) ...................................................................................... 2
Milton v. IIT Research Institute,
138 F.3d 519 (4th Cir. 1998) .......................................................................................... 2, 3, 4, 5
Quillen v. Int’l Playtex, Inc.,
789 F.2d 1041 (4th Cir. 1986) ............................................................................................ 2, 3, 5
Time, Inc. v. Hill,
385 U.S. 374 (1967) ................................................................................................................... 6

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Wells v. Liddy,
186 F.3d 505 (4th Cir. 1999) .................................................................................................. 4, 7
State Cases
Buchanan v. Doe,
431 S.E. 2d 289 (Va. 1993) ........................................................................................................ 3
Hollander v. Lubow,
351 A.2d 421 (Md. 1976) ........................................................................................................... 6
McMillan v. McMillan,
253 S.E.2d 662 (Va. 1979) ......................................................................................................... 4
Smith v. Datla,
164 A.3d 1110 (N.J. App. Div. 2017) ........................................................................................ 6
Mid-Atlantic Telecom, Inc. v. Long Distance Services, Inc.,
1993 WL 13031406 (Va. Cir. Sep. 22, 1993) ............................................................................ 8
Additional Authorities
Restatement (First) of Conflict of Laws § 377 ........................................................................ 2, 5, 7
R. Pound, Interests of Personality, 28 Harv. L. Rev. 343 (1915) ................................................... 6
Restatement (Second) of Torts §652I ............................................................................................. 6
Restatement (Second) of Torts §652A. ........................................................................................... 6

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Plaintiffs demonstrated in their opening supplemental brief on choice of law that the last
acts necessary to complete the torts alleged in this action occurred where the Plaintiffs were
located because that is where their personal privacy was invaded, and, in the case of Mr. Comer,
where that invasion also caused emotional distress. Because the legal injury addressed by each
of these tort claims accrued when Plaintiffs were injured, lex loci delicti commissi doctrine
requires the application of New Jersey, Tennessee, and Maryland law, respectively, to Plaintiffs’
state-law tort claims.
Defendant’s arguments in favor of applying the law of New York or Virginia contradict
the law as set forth by the courts of Virginia, the Fourth Circuit, and this Court. ECF No. 89,
Def’s Supp. Response Br. on Choice of Law (“Def’s Supp. Br.”). First, Defendant incorrectly
asserts that the place of the wrong for every tort must be the place where the defendant was
located at the time of the wrongful act—an argument long rejected by this Court. Second,
Defendant ignores the Fourth Circuit’s conclusion that the injury in the invasion of privacy tort is
a personal injury—which means that the last act necessary to complete this tort occurred where
the plaintiff suffers that personal injury. Third, addressing Plaintiffs’ alternative argument about
the location of publication in a multi-state publication tort, Defendant misconstrues the law of
Virginia as employing a “presumption” that the location of publication is a defendant’s
headquarters. There is no such presumption.
1.

Defendant’s argument in favor of New York law is predicated on misreading lex

loci to turn on a defendant’s location at the time of its wrongful act. Def’s Supp. Br. at 1
(arguing that the place of the wrong was New York because Defendant should be understood to
have acted from its New York headquarters). As Plaintiffs demonstrated in their opening
supplemental brief, “The place of the wrong for purposes of the lex loci delicti rule, however, is

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defined as the place where ‘the last event necessary to make an act liable for an alleged tort takes
place.’” Quillen v. Int’l Playtex, Inc., 789 F.2d 1041, 1044 (4th Cir. 1986) (quoting Miller v.
Holiday Inns, Inc., 436 F. Supp. 460, 462 (E.D. Va.1977)); see Ford Motor Co. v. Nat’l Indem.
Co., 972 F. Supp. 2d 850, 857 (E.D. Va. 2013); Restatement (First) of Conflict of Laws §377.
Crucially, the event that completes a tort does not always occur where the defendant is located.
Plfs’ Supp. Br. (ECF No. 86) at 3. As this Court has explained, the lex loci doctrine looks to the
last event necessary to complete the tort, “even if the actor has no control over the location of
that last event.” Insteel Indus., Inc. v. Costanza Contracting Co., 276 F. Supp. 2d 479, 486 (E.D.
Va. 2003); see also Quillen, 789 F.2d at 1044 (last act necessary to complete the tort was injury
to plaintiff).1
Defendant tries to avoid this conclusion by treating the entirety of every tort as if it
comprised only an “act” of the defendant and not also the separate element of injury to the
plaintiff. To that end, it quotes the statement in Milton v. IIT Research Institute, 138 F.3d 519,
522 (4th Cir. 1998) that Virginia law “selects the law of the place where the wrongful act
occurred[.]” Def’s Br. at 2. Defendant would read “the place where the wrongful act occurred”
to mean “defendant’s location when it acted wrongfully.” That reading is incorrect because it
would make Milton conflict with the many authorities holding that Virginia law chooses the

Applying this principle, this Court concluded in Insteel Industries that the fraud action would
be governed by the law of North Carolina, when a North Carolina-based plaintiff had received in
North Carolina, and relied upon, allegedly false invoices created by a Maryland-based defendant,
and North Carolina was where those false invoices were paid by plaintiff. 276 F. Supp. 2d at
486-87. None of the events that the Court held were the last events necessary to complete the
fraud tort claim were actions of the defendant. Id. This Court expressly concluded that its
analysis which resulted in application of the law of the plaintiff’s domicile state—was consistent
with the First, not the Second, Restatement of Conflicts. Id.
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place where the last event needed to complete the tort took place, regardless of the defendant’s
location.
In reality, there is no conflict between Milton and Virginia law. Milton is consistent with
those other authorities because “wrongful act” in Milton does not mean only the action of a
defendant. As Defendant acknowledges, Milton relied on the Virginia Supreme Court’s
definition of “tort” as “a wrongful act.” See Def’s Br. at 2 (quoting Milton quoting Buchanan v.
Doe, 431 S.E. 2d 289 (Va. 1993).2 The “wrongful act” in this context refers to the complete tort.
Thus, Milton’s statement that Virginia law selects the place where the wrongful act occurred
simply means that Virginia law selects the place where the tort occurred. And a tort does not
occur until the last event needed to complete the tort occurs. On that correct understanding,
Milton is perfectly consistent with Quillen, Insteel, and the other authorities holding that Virginia
law selects the place where the last event necessary to complete the tort occurs, regardless of the
defendant’s location.
Milton involved the tort of wrongful discharge. The plaintiff in Milton—a Virginian—
had lost his job through an arguably wrongful discharge in Maryland, but argued that Virginia
law should apply to his claim because he would experience the effects of lost income while home
in Virginia. The Fourth Circuit, using Virginia choice of law principles, applied Maryland law
because the injury that completed that tort occurred “in Maryland, where Milton had his office

Buchanan itself contains no holding relevant to the issue of lex loci for torts. The dispute in
Buchanan was whether an insurance dispute sounded in contract or tort law, and the Court held
the claim was resolved by applying Virginia’s statutory law governing contracts. See 431 S.E.2d
292-93. The definition of tort as a “wrongful act (not involving a breach of contract),” id. at 291,
is perfectly consistent with Plaintiffs’ analysis here, as the Virginia Supreme Court made clear
that tort refers to legal injury: “Stated differently, a ‘tort’ is a ‘legal wrong committed upon the
person or property independent of contract,’” id. at 292. The Court never held, as Defendant
argues, that the elements of various torts are comprised only of acts of the defendant—that has
never been the law.
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and where his dismissal was communicated to him.” 138 F.3d at 522. Milton relied on
McMillan v. McMillan, 253 S.E.2d 662 (Va. 1979), a case in which a Virginia resident was
involved in a car accident in Tennessee. “[S]ome of the ill effects of [the plaintiff’s] injuries
were experienced by Mrs. McMillian at home in Virginia,” the Fourth Circuit wrote, but “the
Virginia Supreme Court readily applied Tennessee law to the suit, deeming Tennessee the place
of the injury.” Milton, 138 F.3d at 522.
In both McMillan and Milton, the relevant distinction is between legal injury (wrongful
discharge, car accident) and the later practical effects of that injury (lost income, pain and
suffering). Thus Milton distinguishes the place where the tort becomes complete from other
jurisdictions where the plaintiff might (also) experience subsequent harm. See 138 F.3d at 522
(“Virginia clearly selects the law of the place where the wrongful act occurred, even when that
place differs from the place where the effects of injury are felt.” (emphasis added)). In each case,
the later consequential effects are irrelevant to the choice of law. Also irrelevant is the location
of the defendant: in neither Milton nor McMillan did the court settle a choice-of-law question by
asking about a defendant’s location.3

Defendant’s contention the Virginia law somehow applies a “distinctive” or “unique”
conceptualization of tort or legal injury is belied by closer examination of Buchanan, 431 S.E. 2d
289, as discussed above, and has no basis in law. Def’s Br. at 7. Defendant cites for this
principle a discussion of the difference between Virginia and Maryland choice of law principles
in Gen. Assur. of Am., Inc. v. Overby-Seawell Co., 893 F. Supp. 2d 761, 778 (E.D. Va. 2012).
But the distinction between Virginia and Maryland law in the eyes of the Fourth Circuit is
simple, and is not based on any relevant difference in the definition of tort: Virginia follows the
First Restatement of Conflicts of Law, while the Fourth Circuit has concluded that Maryland
follows the Second Restatement in the context of multistate publication torts. Id. (citing Johnson
v. Oroweat Foods Co., 785 F.2d 503, 511 (4th Cir. 1986); see also Wells v. Liddy, 186 F.3d 505,
528 (4th Cir. 1999) (“[T]he Court of Appeals of Maryland has indicated its willingness to apply
more flexible choice-of-law rules from the Second Restatement in situations when the First
Restatement rules have become unworkable.”).
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Contrary to Defendant’s characterization, Def’s Supp. Br. at 7, Plaintiffs contend that it is
the place of their legal injury, not the place of any later consequential “harm the plaintiff
experiences as a consequence of the wrongful act,” that settles the choice-of-law question. Thus,
Plaintiffs do not rely, as Defendant contends, on location of the subsequent consequential effects
of these torts which ranged from identity theft and financial damages, chilling effect on political
contributions, and harm to Mr. Comer’s career and mental health, among other things to be
proven at trial. In this respect Milton and McMillian are consistent with Plaintiffs’ argument.
Defendant also fails to recognize that the location of legal injury can be the location of a
plaintiff, where the injury that completes a tort is personal, as in Quillen. See 789 F.2d at 1044.
The Fourth Circuit’s analysis in Quillen did not conflict with Virginia law. To the contrary, the
Court relied on Virginia law to assess the last act necessary to complete the tort at issue. Quillen
is not the only case where lex loci, properly applied, leads a court to apply the law of the location
of the plaintiff, in light of the last act necessary to complete a tort. See, e.g., Insteel Indus., 276
F. Supp. 2d at 486-87; Restatement (First) of Conflict of Laws §377 cmt. a, n.4 (in fraud cases,
the place of the wrong is “where the loss is sustained, not where fraudulent representations are
made”).
2.

For any given tort, the last event necessary to complete the tort depends on the

particular elements of that tort. Plfs’ Supp. Br. at 4-5. As this Court explained:
The location where “the last event necessary to make an act[or] liable for an
alleged tort takes place” will vary amongst different claims, depending on what
elements comprise the particular claim and which element is deemed to provide
the “last event necessary” to make the actor liable for the particular tort at issue.
Ford Motor Co., 972 F. Supp. 2d at 857 (emphasis added); see also Restatement (First) of
Conflict of Laws §377 cmt. a (“What acts and events are necessary to constitute a tort is a
question of the law of Torts[.]”). Defendant has no response to this principle of law. This Court

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must, under this well-established law, look to the elements of the torts at issue to determine
where the last event necessary to complete the torts took place. In the present case, the torts
became complete when the Plaintiffs sustained legal injury by having their privacy invaded by
the publication of their private facts. Plfs’ Br. at 4 (citing Brown v. Am. Broad. Co., 704 F.2d
1296, 1302 (4th Cir. 1983) (tort of invasion of privacy accrues upon plaintiffs’ injury);
Restatement (Second) of Torts §652A.4
The Fourth Circuit has identified the nature of the injury that completes this tort as
personal to the individual. Brown, 704 F.2d at 1302 (citing Time, Inc. v. Hill, 385 U.S. 374, 384
n.9 (1967) (“In the ‘right of privacy’ cases the primary damage is the mental distress from
having been exposed to public view[.]”)); see also Restatement (Second) of Torts § 652I, cmt, a
(“The right protected by the action for invasion of privacy is a personal right[.]” (emphasis
added)). The Fourth Circuit’s analysis is consistent with the way that New Jersey, Tennessee,
and Maryland treat these torts: as personal injury torts. See Smith v. Datla, 164 A.3d 1110, 1124
(N.J. App. Div. 2017) (describing the injury as “injury to the person”); Beard v. Akzona, Inc.,
517 F. Supp. 128, 132 (E.D. Tenn. 1981); Hollander v. Lubow, 351 A.2d 421, 427 (Md. 1976)
(quoting R. Pound, Interests of Personality, 28 Harv. L. Rev. 343, 362-63 (1915): “Another
phase of the same interest is the demand which the individual may make that his private personal
affairs shall not be laid bare to the world and be discussed by strangers. . . . Such publicity with

Defendant has found an Eighth Circuit case reciting the elements of this tort without
specifically mentioning injury. Def’s Br. at 8-9 (citing McNally v. Pulitzer Pub. Co., 532 F.2d
69, 78 (8th Cir. 1976)). That does not establish the last act necessary to complete the legal injury
protected against by this tort in the Eighth Circuit, much less in the states relevant here. For
example, the model jury instructions from New Jersey—the relevant state for Mr. Schoenberg—
for publication of private facts clearly contain the element of injury. See N.J. Model Jury
Instructions, Charge 3.14, at 8-9, available at
https://njcourts.gov/attorneys/assets/civilcharges/3.14.pdf?c=IMt.
4

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respect to private matters of purely personal concern is an injury to personality.”). In other
words, the invasion of privacy is a personal injury in the same way that physical injury is
personal. For any plaintiff, it occurs at the plaintiff’s location. Plfs’ Supp. Br. at 4-5. The same
is true of the emotional distress tort. Id. at 5.
3.

Defendant contends that Virginia law presumes that publication-based torts occur

at the location of a corporate defendant’s headquarters. Def’s Supp. Br. at 3. Such a
“presumption” would be, as Plaintiffs previously demonstrated, inconsistent with both the First
Restatement of Conflicts of Law, and how reputational torts have long been treated for lex loci
purposes, including by this Court. Rather, for publication-based torts, courts have consistently
held that the legal injury occurs at the location where the information reaches the public and
causes reputational harm, not the location where the document was created. See Wells, 186 F.3d
at 521-22 (“In defamation actions, the place of the harm has traditionally been considered to be
the place where the defamatory statement was published, i.e., seen or heard by non-parties.”
(emphasis added)); see also Plfs’ Supp. Br. at 6-7; Restatement (First) of Conflict of Laws § 377
cmt. a, n.5.5

The commentary to the First Restatement of Conflict of Law is directly contrary to Defendant’s
assertion that the place of publication is where the document was created (where the website was
controlled) rather than where the information was viewed:
5

Where harm is done to the reputation of a person, the place of wrong is where the
defamatory statement is communicated.
Illustration:
7. A, broadcasting in state X, slanders B. B is well and favorably known in state Y and
the broadcast is heard there by many people conversant with B’s good repute. The place
of wrong is Y.
Restatement (First) of Conflict of Laws § 377 cmt. a, n.5 (emphasis in original).
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None of the cases Defendant cites employed such a presumption. In ABLV Bank v.
Center for Advanced Defense Studies Inc., 2015 WL 12517012 (E.D. Va. April 21, 2015), the
Court held that the place of the wrong for a libel claim—which accrues when a defendant
communicates the alleged defamatory statement to any third party—was the District of Columbia
because it was “undisputed” that publication took place there. Id. at *2. Similarly, in MidAtlantic Telecom, Inc. v. Long Distance Services, Inc., 1993 WL 13031406 (Va. Cir. Sep. 22,
1993) —a case about tortious interference with contracts and unfair competition not an invasion
of privacy or any other reputational tort—the court established Virginia as the place of that
particular wrong not on the basis of a presumption but on the basis of the specific “facts of the
case presented to the court.” Id. at *1. And Wiest v. E-Fense, Inc., 356 F. Supp. 2d 604 (E.D.
Va. 2005), involved a pro se plaintiff and choice of law was not contested. See id. 608 n.2; Plfs’
Supp. Br. at 7. None of these cases remotely holds that Virginia law presumes that the last act
necessary to complete any publication-based tort occurs at corporate headquarters.6
Defendant’s argument also does not withstand factual scrutiny, when compared to the
allegations in Plaintiffs’ Amended Complaint. Defendant may have been headquartered in New
York, but there is no allegation whatsoever that the Defendant provided the material or
controlled the WikiLeaks website from New York. Again, Defendant is conflating its actions in

As Plaintiffs previously explained in the alternative, even if this Court analogizes these privacy
torts to reputational torts, the location of the legal injury would be the location where the
information reaches the public, not the location where a document was created or from which it
was sent (the doorstep, not the printing press). Plfs’ Supp. Br. at 6-8. The Court would then
need to solve the multi-state publication problem by choosing as the place of the wrong, in the
way most consistent with the nature of this tort, a single state from among the many states where
the information was made available. Given the nature of the privacy interests invaded, the
outcome of the multi-state publication analysis should land on the states where the plaintiffs
were located, just as Judge Hand did in Mattox v. News Syndicate Co., 176 F.2d 897, 900 (2d
Cir. 1949). Plfs’ Supp. Br. at 7-8.
6

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furtherance of the conspiracy, some but not all of which occurred in New York, with the last act
necessary to complete these torts, which occurred elsewhere. Plfs’ Supp. Br. at 9-10.
4.

Finally, Defendant argues that this Court should conclude that the law of the

forum state, Virginia, should apply because the Court cannot discern from the face of the
complaint where Plaintiffs’ legal injuries occurred. Def’s Supp. Br. at 4-5. Defendant only
reaches this conclusion by misconstruing the lex loci standard, ignoring the applicable law on the
nature of the specific torts at issue, and ignoring the relevant factual allegations. The personal
injury to these Plaintiffs could not have occurred in New York, nor in Virginia, where the
Defendant, and the Defendant only, was located. The location of each of these Plaintiffs was his
home state: Tennessee for Mr. Cockrum, New Jersey for Mr. Schoenberg, and Maryland for Mr.
Comer. Those locations control these torts.

CONCLUSION
Plaintiffs respectfully submit that the proper outcome of the application of the lex loci
delicti commissi doctrine to the claims at issue in this case is to apply the law of Tennessee to
Mr. Cockrum’s claim, the law of New Jersey to Mr. Schoenberg’s claim, and the law of
Maryland to Mr. Comer’s claims.

Respectfully submitted,

Dated: February 15, 2019

By: /s/ Elizabeth C. Burneson
Counsel for Plaintiffs
KELLY J. BUNDY (VSB No. 86327)
ELIZABETH C. BURNESON (VSB No. 93413)
Hirschler Fleischer, a Professional Corporation

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2100 E. Cary Street (23223)
Post Office Box 500
Richmond, VA 23218-0500
Telephone: (804) 771-9505
(804) 771-9528
Facsimile: (804) 644-0957
E-mail:
kbundy@hirschlerlaw.com
lburneson@hirschlerlaw.com
BENJAMIN L. BERWICK (MA Bar No. 679207)
(pro hac vice)
United to Protect Democracy
10 Ware St.
Cambridge, MA 02138
202-579-4582
Ben.Berwick@protectdemocracy.org
IAN BASSIN (NY Attorney Registration No.
4683439) (pro hac vice)
United to Protect Democracy
222 Broadway, 19th Floor
New York, NY 10038
202-579-4582
Ian.Bassin@protectdemocracy.org
JUSTIN FLORENCE (D.C. Bar No. 988953)
(pro hac vice)
ANNE TINDALL (D.C. Bar No. 494607)
(pro hac vice)
CAMERON KISTLER (D.C. Bar No. 1008922)
(pro hac vice)
United to Protect Democracy
2020 Pennsylvania Ave. NW, #163
Washington, DC 20006
202-579-4582
Justin.Florence@protectdemocracy.org
Anne.Tindall@protectdemocracy.org
Cameron.Kistler@protectdemocracy.org
JESSICA MARSDEN (N.C. Bar No. 50855)
(pro hac vice)
United to Protect Democracy
510 Meadowmont Village Circle, No. 328
Chapel Hill, NC 27517
202-579-4582
jess.marsden@protectdemocracy.org

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STEPHEN P. BERZON (CA State Bar No. 46540)
(pro hac vice)
BARBARA J. CHISHOLM (CA State Bar No.
224656) (pro hac vice)
DANIELLE LEONARD (CA State Bar No. 218201)
(pro hac vice)
Altshuler Berzon LLP
177 Post Street, Suite 300
San Francisco, CA 94108
(415) 421-7151
sberzon@altber.com
bchisholm@altber.com
dleonard@altber.com
NANCY GERTNER (MA Bar No. 190140)
pro hac vice)
Fick & Marx
100 Franklin Street, 7th floor
Boston, MA 02110
(857) 321-8360
ngertner@fickmarx.com
RICHARD PRIMUS (MI Bar No. P70419)
(pro hac vice)
The University of Michigan Law School*
625 S. State Street
Ann Arbor, MI 48109
(734) 647-5543
PrimusLaw1859@gmail.com
* For identification purposes.
STEVEN A. HIRSCH (CA State Bar No. 171825)
(pro hac vice)
Keker, Van Nest & Peters LLP
633 Battery Street
San Francisco, CA 94111-1809
(415) 391-5400
shirsch@keker.com

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CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of February, 2019, I caused a true and correct copy
of the foregoing to be electronically filed with the Clerk of Court for the Eastern District of
Virginia, Richmond Division, using the Court’s CM/ECF system, which thereby caused the
above to be served electronically on all registered users of the Court’s CM/ECF system who
have filed notices of appearance in this matter of such filing (NEF) to all registered parties.
Dated: February 15, 2019

By: /s/ Elizabeth C. Burneson

Counsel for Plaintiffs
KELLY J. BUNDY (VSB No. 86327)
ELIZABETH C. BURNESON (VSB No. 93413)
Hirschler Fleischer, a Professional Corporation
2100 E. Cary Street (23223)
Post Office Box 500
Richmond, VA 23218-0500
Telephone: (804) 771-9505
(804) 771-9528
Facsimile: (804) 644-0957
E-mail: kbundy@hirschlerlaw.com
lburneson@hirschlerlaw.com

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