RIAA and MPAA Legal Initiative (updated April 28, 2005*)
DISCLAIMER: The following information is provided for information purposes and does not constitute legal advice. We require an engagement letter of all our clients. Consequently, we can only provide general information and answer (if possible) general questions prior to one becoming a client of ours. Above all, we highly recommend you consult an attorney if you believe you may be involved at all in the RIAA Legal Initiative. You can contact the () and the web site for a list of attorneys. Of course, we would be happy to speak with you about any initial concerns and discuss representation with you. Simply email us or telephone us at 773.588.5410.
Please be aware that as of April 2005 the RIAA continues to pursue individuals who file share illegally or who appear to file share illegally. This pursuit includes users of the Internet and Internet2. Some individuals that may have engaged in suspect activities as far back as Spring 2004 have only recently been served. Consequently and unfortunately, any individuals that may have file-shared in some time ago may still yet be subject to potential suits.
Recent Updates
The Stages of the RIAA Legal InitiativeJohn Doe Lawsuits - Part I
John Doe Lawsuits - Part II - Questions and AnswersJudicial Opinions and Related Authority
MPAA Legal Initiative (to be updated)
RECENT UPDATES (see also Judicial Opinions and Related Authority):
The RIAA and MPAA have announced the filing of lawsuits against collegiate users of the Internet2 network. We have begun to collect articles on this aspect of the litigation and other resources. More information will will be posted as it becomes available.
The Supreme Court heard oral arguments in the Grokster case.
14 April 2005 The United States District Court for the Middle District of North Carolina issued an Order affirming the analysis of the D.C. and 8th Circuits holding that the Recording Industry Association of America (RIAA) misused the subpoena provisions of the Digital Millenium Copyright Act (DMCA). This does not have much significance at this juncture because the RIAA abandoned the DMCA approach to litigation some time ago (see below - Stages of the RIAA Legal Initiative: Subpoena). The Order does conclude that the universities at issue constitute 512(a) service providers concerned with transmission functions not storage functions. Thus, the subpoena provisions of 512(h) were not applicable. The court also addressed thematter of from where a subpoena must be issued under 512(h) concluding that the subpoena must be issued from a court that would have jurisdiction over the dispute. Privacy and other issues, though raised by the parties, were not addressed.
The Stages of the RIAA Legal Initiative
• Subpoena
• Identity Revealed by ISP
• Litigation Initiated
• John Doe Lawsuits (Part I) (Part II - Q&A)
• Amnesty
When the RIAA Initiative first began, the RIAA apparently issued more than one thousand subpoenas to various Internet Service Providers (ISPs) under the Digital Millenium Copyright Act. These ISPs include commercial, academic, and private providers of Internet service. For example, the RIAA would send a subpoena to Earthlink for any individual who the RIAA determined shares files and subscribes to Earthlink's DSL service. However, the D.C. Circuit Court of Appeals ruled that the RIAA misused the DMCA for this purpose.The RIAA continues to issue subpoenas but does so now under specific "John Doe" lawsuits.
So, the RIAA can't use subpoenas any more, right?
Wrong. Since the D.C. Circuit ruled that the RIAA improperly sought the issuance of subpoenas under the Digital Millenium Copyright Act, the RIAA has chosen to file "John Doe" lawsuits and issue subpoenas under the traditional rules of evidentiary procedure in federal courts. Although the Court must grant the RIAA permission to issue subpoenas in an "expedited discovery" fashion, most courts have granted the RIAA this permission. Thus, the RIAA can still and does still use subpoenas.
Are the subpoenas issued to me?
No, not the subpoenas described here. The subpoenas are issued and directed to the ISPs associated with specific IP addresses (this could be a cable company like Comcast, an academic institution like Purdue University, or a traditional ISP like Earthlink). Should you be the individual associated with an IP address at a particular time, the subpoena may seek information about you from the ISP. However, the subpoenas is issued and directed to the ISPs.
How did the RIAA find me?
Based on information we have obtained, the RIAA used automatic software and/or manual searches to search for individuals that shared large numbers of songs. In so doing, the RIAA also saved digital images of the songs offered for sharing on these individuals' computers. The RIAA would also record the username (the username at kazaa.com, for example) and the IP address (xxx.xxx.xxx.xxx) associated with the individual computer that contained the files.
With the IP address, the RIAA can easily determine through ARIN which entity or individual "owns" the IP address. For example, when you send an email, the email header typically contains the IP address for your computer. Using the site www.arin.net, I can determine who "owns" the IP address your computer has been assigned, often this will be your ISP.
The RIAA would then send a subpoena to the ISP seeking the identity of the individual who has licensed the IP address from the ISP.
We also suspect that the RIAA may have established dummy sites or tagged certain files released onto the file-sharing networks. Thus, like the use of tagged money, these files can be traced.
How do I know whether my ISP received a subpoena?
In most cases, the ISP will provide you notice soon after receiving the subpoena. When the RIAA Legal Initiative first began in 2003, various web sites recorded the IP addresses and usernames that have been the subject of subpoenas by the RIAA. These typically were obtained from the DMCA subpoenas no longer used.
If you don't know your computer's IP address, you usually can check it in your TCP/IP settings or the complete header in the email you send from your computer (ie send yourself an email). If you still cannot determine your IP address, contact your ISP. Dial-up customers will be assigned a new IP address each time one connects to the Internet.
Please also understand that if your computer is on a network, you will have an internal network IP address. Usually, these IP addresses begin 192.168.xxx.xxx. This is not the IP address for which you should be looking.
IP addresses in the form 10.x.x.x and 172.16.x.x thru 172.31.x.x have also been reserved for private networks. [Thank you to James Ford for this technical clarification.] Consequently, you should not be looking for IP addresses falling within these blocks as well.
Whether you will hear from your ISP depends on your particular ISP. Some ISPs (such as Earthlink) will notify the customer and provide a small window of time in which to file an objection to the subpoena. Your ISP will be able to tell you its practices in response to subpoenas (whether or not from the RIAA).
Should you receive notice from your ISP that it has received a subpoena, you should contact an attorney immediately. The ISPs often provide a limited amount of time to see evidence of an objection before releasing information.
Will my ISP reveal my identity to the RIAA?
The answer to this question depends on your ISP. Contact your ISP's legal department for more information on their specific policy.
Many ISPs will provide the customer with an opportunity to object prior to disclosure of your identity. Consequently, should you receive notice from your ISP through email or snail mail, contact an attorney immediately.
You once indicated that the D.C. Circuit ruled subpoenas to be improper for use by the RIAA. Is this not the case any more?
This is not the case any more. Soon after the initiative began, the D.C. Court of Appeals issued an opinion holding that § 512(h) of the DMCA does not authorize the issuance of subpoenas to ISPs where the ISP is merely a conduit for the communications of others. At the time, we recommend that "If you learn that your ISP has received a subpoena, contact it immediately, object to the subpoena, and cite the D.C. Circuit opinion. Please note that file-sharing copyrighted material remains illegal. The D.C. opinion does not change this." This warning is no longer applicable. You still may object to a subpoena, but not on the grounds of the D.C. Circuit opinion as the RIAA changed its strategy. You should still contact an attorney immediately
What happens when my identity has been revealed to the RIAA by my ISP?
First, the ISP will reveal the identity of the customer in whose name the Internet account is registered.
For example, if you use your brother's computer to use the Internet or use your brother's Internet connection, the ISP will reveal your brother's identity. Consequently, should a lawsuit be filed, it will probably be your brother's name in the suit and not yours. This obviously poses several unique problems that will need to be addressed.
The RIAA has indicated that it intends to file lawsuits against those people who have shared its copyrighted songs as files on their computers. Consequently, the identity of the ISP's customer provides the RIAA with information enough to file a suit against that ISP customer. The RIAA has done this for some time as of Spring 2005.
Will I be sued if the RIAA obtains my identity?
Only the RIAA can answer this question. The RIAA has filed suitagainst some individuals whose identities it has obtained. Individuals have been sued through John Doe suits for an amount of songs below 600. The range can extend quite high.
What do I do if my ISP has revealed my identity to the RIAA?
Call an attorney immediately. Beyond this, each individual will be faced with individual circumstances that warrant individual responses and legal representation.
Has the RIAA actually sued anyone?
Yes. Upon our best information, the total number of individuals sued by the RIAA exceed seven thousand (7000). In the beginning, nearly all individuals that actually had a suit filed against them were personally named. Now, it appears that the RIAA personally names an individual when the RIAA states it did not receive communication from the individual. The bulk of the 7000 represent individuals sued as a John Doe.
How will I learn that I have been sued?
Most recently, the John Doe suits usually mean that you will learn from your Internet Service Provider that the RIAA or MPAA has targeted your IP address. As such, this means that you have been sued as a John Doe associated with your particular IP address. While it may appear that you have not actually been sued yet, this represents a significant misunderstanding. Sometimes, a party may proceed against a John Doe. Moreover, unless one intervenes, the Plaintiff (here the RIAA) usually obtaines the identity of the John Doe. In such a case, the Plaintiff can replace John Doe #XX with your personal name. Here, this will occur should the individual fail to respond to the letters sent by the RIAA and MPAA demanding settlement.
Previously, when this RIAA Legal Initiative began, individuals may have learned through a phone call from the media. Should this still occur (when one is personally named in the suit), it is always wise to consult with an attorney before communicating with the media (if ever). Simply state "No Comment" should you be contacted. Your statements to the media may be used against you. The media can be a great tool and resource. However, proceed with caution and consult an attorney before communicating with the media.
You may also be served by a sheriff, special process server, or United States Marshal.
Internet 2 Update: As the Internet2 users targeted by the RIAA have been associated with academic institutions, you may learn from your academic institution that you have been targeted. You should be cautious. Some academic institutions have been reported to instigate disciplinary proceedings. Should disciplinary proceedings be a possibility, we recommend that you consult with an attorney. However, we also encourage prompt attention to all requests by the academic institution. They may offer resources to assist you. YOU SHOULD BE AWARE THAT ILLEGAL FILE-SHARING MAY LIKELY VIOLATE COMPUTER USE POLICIES AT ACADEMIC INSTITUTIONS, and FOR GOOD REASON.
What do I do after I learn I have been sued by the RIAA?
Consult an attorney immediately. See the top of this page for information on how to contact attorneys handling these matters or simply email or telephone Charles Mudd at 773.588-5410 or cmudd@muddlawoffices.com.
Is it true the RIAA sued a twelve (12) year old?
The RIAA sued an individual whose name had been revealed to it. This individualhappened to be a 12 year old. This case has been settled.
Is it true the RIAA sued a deceased individual?
It appears to be true.
I have been sued, but its no where near where I live. Did they make a mistake?
While possible, it's unlikely. The most recent suits have been initiated near or in the jurisdiction in which the ISP intended to be subpoenaed happens to be located. The location or court in which the particular case has been filed should not be construed as a mistaken identity or mistake by the RIAA or the MPAA.
What about defenses?
Intent
The United States Copyright Act does not include a mental state (mens rea) requirement. So, an individual's intent becomes irrelevant for purposes of litigating a defense. It may have some relevance depending on the circumstances for purposes of settlement.
Motion to Quash
We know of no successful motion to quash a subpoena issued in a John Doe suit by the RIAA and/or MPAA.
Summary Judgment
A court in the United States District Court for the Northern District of Illinois granted summary judgment brought against a defendant by the RIAA based on the evidence it had collected and submitted to the Court.
Parental Liability
This certainly remains a theoretical argument. We know of no successful application of the argument.
It's April 2005, is the RIAA still pursuing people?
Yes. The most recent phase have targeted Internet2 users. However, suits against individuals using the Internet continue by both the RIAA and MPAA.
In response to the D.C. Circuit's December 9, 2003 opinion, the RIAA stated that it would file John Doe lawsuits. It did so. Although the D.C. Circuit opinion has binding authority only in the D.C. Circuit and only persuasive authority elsewhere, the RIAA proceeded to file the John Doe lawsuits against all perceived and/or alleged infringers with whom it has not yet settled. Thus, the RIAA has ceased using the DMCA as a vehicle to obtain the identifies of any perceived and/or alleged infringers prior to filing a lawsuit.
Under the DMCA, the RIAA would issue a subpoena to your ISP without filing a lawsuit or providing you with notice (it would likely not know your identity), as described above. Now, the RIAA will file a lawsuit with the defendant named "John Doe." It will then seek the court's leave to issue a subpoena to your ISP. While a John Doe suit imposes judicial discretion and oversight on the RIAA, the courts will very likely grant RIAA and the Record Companies the authority to send the subpoenas to your ISP.
If you receive notice of a subpoena from your ISP in connection with a John Doe suit, you should contact legal counsel immediately. Your legal counsel need not identify you and may proceed defending you as a John or Jane Doe. By having representation, you will ensure that your rights and arguments will be represented and the RIAA's motions and actions will not proceed without objection.
By filing a lawsuit first and avoiding DMCA concerns, the RIAA has eliminated some of the arguments used by the ISPs to refuse disclosing any identities. Consequently, some of the ISPs who fought the RIAA previously may be more reluctant to do so now. Therefore, your ISP may very well disclose your identity (see above).
Once the RIAA and the Record Companies learn of an individual's identity, they will very likely amend the Complaint to reflect the individual's true name rather than "John Doe." The RIAA will then have this individual served with a summons and copy of the Complaint.
At the same time, individuals should be forewarned that a party may proceed against a John Doe (or Jane Doe) and the failure to intervene in some manner may adversely affect one's rights.
John Doe Lawsuits - Part II - Questions
and Answers
Can the RIAA or Record Companies file suit against a "John Doe"?
Yes. The RIAA can pursue a defendant as a John Doe until that defendant has been identified. In some cases, a plaintiff may obtain a judgment against a John Doe. The failure to intervene either as a named individual or a John Doe (or Jane Doe) may seriously adversely affect one's rights. Should you know that you are the subject of a John Doe suit, you should contact an attorney immediately (contact Charles Mudd or go to ).
Are there specific time limits in which to respond to receiving a summons and Complaint?
Yes. The summons should inform you how many days you have to respond to the Complaint. These typically include weekends and holidays (unless the actual deadline falls on one of these days). As we cannot know without seeing your summons, any information provided here should be treated as general information and not relied upon in acting on your particular situation. You should contact an attorney immediately upon being served a summons and Complaint (contact Charles Mudd or go to ).
Will I be able to settle without a public record?
This is a very good question. If you are the subject of a John Doe suit, you will more than likely eventually be the subject of the lawsuit and be required as part of the settlement to sign a stipulated judgment. A lot depends on the timing and how soon after the RIAA learns your identity you or your attorney contact the RIAA. Should you act quickly, the RIAA will settle without naming you personally n the lawsuit.
Additional questions and answers will be provided as these issues continue.
Amnesty Initiative "Clean Slate"
The Recording Industry offered the "Clean Slate" program to provide existing file-sharers who had not yet been notified of a lawsuit or subpoena to voluntarily identify themselves, enter into an agreement with the Recording Industry, and obtain "amnesty" for the individual's prior conduct. There exist concerns with the "Clean Slate" program. For example, the RIAA and/or Recording Industry do not represent ALL recording companies to which copyrighted songs belong. Thus, the agreement would not apply to non-RIAA record companies. Nonetheless, one would be identifying themselves as a file-sharer. Consequently, if the non-RIAA record companies obtained the list of file-sharers, nothing in the Amnesty agreement would prevent these companies from pursuing the individual. Again, significant concerns exist with the Amnesty or "Clean Slate" program. It is always wise to consult an attorney before doing anything.
Judicial Opinions and Related Authority
There shall be quick references to judicial opinions and related authority forthcoming. These references shall be in two separate categories: Jurisdiction and Lay Holding. Jurisdiction shall refer to the Country of origin or, in the case of the United States, the specific Court of origin (eg D.C. Circuit Court of Appeals). Law Holding will be a brief phrase summarizing the popular understanding of the particular opinion's holding (eg File-Sharing Possibly Legal in Canada) with slight cautionary editorial modification (eg "Possibly"). Please note that the Lay Holding represents only a perception and should not be relied upon as legal representation or legal argument.
This represents but a summary of relevant legal documents. The Electronic Frontier Foundation also has a number of documents related to the various RIAA suits .
UNITED STATES
Motions to Quash
Effort to Quash Subpoenas Fails: United States District Court, Southern District of New York rules against motion to quash subpoenas, 04 CV 473 (DC).
On March 31, 2004, a Canadian Court issued an in BMG Canada Inc., et al v. John Doe, et al. (Docket T-292-04, Citation 2004 FC 488) that upheld a challenge by some Canadian ISPs to the disclosure of the identities of their Canadian customers sought by the Canadian recording industry.
Expectation of Privacy:
All parties in the dispute (members of the Canadian recording industry, on the one hand, and Canadian ISPs, on the other hand) agreed that "ISP account holders have an expectation of privacy that their identity will be kept private and confidential." The expectation arises from the contractual relationship with the ISPs and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA). However, section 7(3)(c) of the PIPEDA permits the disclosure of personal information pursuant to a court order.
Holding:
The Court denied the Canadian recording industry's motion for expedited discovery. This ultimate decision came about because of a number of factors the court addressed. However, the two most significant aspects of the holding are
(1) That "[t]he mere fact of placing a copy on a shared directory in a computer where that copy can be accessed via a P2P service does not amount to distribution;" and,
(2) That the privacy interests outweighed the public interest concerns in favor of disclosure because the Plaintiffs delayed in proceeding to obtain the information (2-5 months), the unreliability of the information (as determined it seems from the ISPs affidavits) and "the serious possibility of an innocent account holder being identified.
Limitations of Holding:
I believe caution should be made before making too much of the Canadian opinion.
(1) While the Court appears to suggest that file-sharing may be legal, the holding can be construed to be much more limited than this broad interpretation. The Court followed by stating that "[b]efore it constitutes distribution, there must be a positive act by the owner of the shared directory, such as sending out the copies or advertising that they are available for copying." Significantly, the Court next stated that "[n]o such evidence was presented by the plaintiffs in this case. They merely presented evidence that the alleged infringers made copies available on their shared drives." Thus, should evidence be provided to support what the Court determined to be necessary, the Court may rule differently.
(2) The Court specifically noted that the motion before the Court was not novel and that all other courts addressing the issue (the disclosure of documents indentifying a defendant previously identified by only an IP address) had determined that the interests in obtaining the identification outweighed the privacy interests. Thus, the Court's holding on the balance between privacy and copyright should be viewed very cautiously and narrowly.
Impact on United States:
(1) United States law may differ as to whether "placing a copy on a shared directory in a computer where that copy can be accessed via a P2P service" constitutes distribution or infringement under United States copyright law. Only a United States court can determine this interpretation of United States copyright law (as opposed to common law copyright infringement). Moreover, if jurisdictions differ on this interpretation (as they have in other varying aspects of RIAA jurisprudence), there may not be consensus until either the Circuits or the Supreme Court resolves the potential inconsistent opinions.
(2) As persuasive authority, the Canadian holding certainly suggests limitations and deficiencies in the presentation of evidence by the recording industry.
(3) The Court also implicitly suggested that a different ruling may be obtained under the , specifically Chapter II, Article 10. The Court did not address the WPPT further because Canada has not yet implemented the treaty. However, the United States has implemented the treaty as of May 20, 2002.
Interesting Notes:
I found it interesting that the Court took the time to express the limitations on the order that it would have issued had it found that the balancing factors weighed more heavily on the side of the recording industry. Importantly, this suggests that the Court foresaw the possibility of granting the motion under different circumstances. Interestingly, the Court provided a means by which only the online pseudonym would replace the IP address in the public portion of the pleadings. The Court stated that a confidential addendum would then match the pseudonyms with actual identities of the individuals. In any case involving the disclosure of identities, all of us who may challenge the disclosure should push for such a privacy approach in the alternative should the Court grant the Recording Industry's motion.
A more detailed analysis of the opinion is beyond the scope of this web page. Some people may differ in their interpretation of the opinion. Because this page has been established to provide individuals with information regarding the issues involved, I have taken a very cautious approach to the interpretation of this and other opinions. People should not take the Canadian opinion to suggest that file-sharing of copyrighted material is legal in the United States.
AUSTRALIA
In early February, the Australian recording industry raided Kazaa's Syndey, Australia offices. A law known as the "Anton Pillar" permits parties in civil copyright suits to obtain evidence from opposing parties (more information on the Anton Pillar law is available at ). This information can apparently be obtained through raids of the opposing parties premises without prior notification.
D.C. Circuit Rules Subpoenas Not Proper Under DMCA in RIAA Initiative: The D.C. Circuit Court of Appeals has issued an holding that subpoenas sent to ISPs (in this case Verizon) by the RIAA pursuant to the DMCA are not enforceable because § 512(h) of the DMCA "does not authorize the issuance of a subpoena to an ISP acting solely as a conduit for communications the content of which is determined by others." The D.C. Circuit did not address Verizon's larger constitutional arguments. Stay tuned for a more in depth summary. In the meantime, individuals who receive notice from their ISP regarding a subpoena from the RIAA should immediately contact their ISP, inform them they object to the subpoena and any release of their information, and cite the D.C. Circuit opinion. Thereafter, they should immediately contact legal counsel.
NETHERLANDS
A court in the Netherlands has ruled that KaZaA is legal. The presently is only available in Dutch but a of the opinion exists in English (scroll down for the English version).
INTERNET2 (We will continue to update this as more information becomes available)
Articles
Resources
Schools Targeted
Apparently the schools targeted include:Boston University, Carnegie Mellon University, Columbia University, Drexel University, the Georgia Institute of Technology, Harvard University, the Massachusetts Institute of Technology, Michigan State University, New York University, Ohio State University, Princeton University, Rensselaer Polytechnic Institute, the Rochester Institute of Technology, the University of California-Berkeley, the University of California-San Diego, the University of Massachusetts-Amherst, the University of Pittsburgh and the University of Southern California.
Litigation Notes:
Motown Record Company, L.P., et al. v. Does 1-252, Northern
District of Georgia, Case No. 1:04-CV-439-WBH
ISP: Cox Communication, 1400 Lake Hearn Drive, NE, Atlanta, Georgia 30319
Subpoena Served on Cox Communications, Inc.: March 10, 2004
Local Counsel for Record Industry:
James A. Lamberth, Troutman Sanders
LLP, 600 Peachtree Street NE, Suite 5200, Atlanta, Georgia 3308
Historical Notes:
US Senate Passes Pirate Act: United States Senate passes the Pirate Act that would allow the government to bring suit against file-sharers for civil penalties.
Costs of Legal Downloading Increase: The Wall Street Journal reported in its Wednesday April 7, 2004 edition that the costs involved in downloading songs from the Internet through legal pay sites (eg iTunes, Napster 2004, musicmatch) have recently shown some increase. This has prompted some concern that the increase in prices for albums online will promote illegal filesharing. Along with this, concerns exist that the increase in prices for albums online (sometimes higher than through retail stores) will stunt the economic growth of this medium. The articles reports that the now-legal-Napster held out against raising its prices until recently. The record companies and online companies dispute from whom the higher prices come. It will remain interesting to determine (a) why this has occurred, (b) its affect on the online market, (c) its affect on file-sharing, and (d) the legal implications of such an industry-wide phenomenon.
RIAA Initiative Continues into June: The week of June 21, the RIAA filed suit against an additional 482 individuals alleged to have infringed copyrights belonging to the RIAA's members. An RIAA spokesperson stated that the average number of songs available for distribution by each individual is around 800.
RIAA Initiative Continues into June: As the RIAA's initiative continues. the Internet Service Providers who have received subpoenas through the John Doe lawsuits (see below) proceed along varying paths. Cox Communications has informed some of its subscribers that their information will be released pursuant to the subpoenas it has received.
More John Doe Lawsuits in February: On February 17, 2004, the RIAA and its Record Companies filed suit against an additional 500+ individuals.
John Doe Lawsuits Begin: On January 21, 2004, the major players in the United States recording industry filed suit against 532 individual "John Does." Consequently, the RIAA file-sharing saga continues. Indeed, this major initiative suggests that the RIAA will not address the suits on a jurisdiction by jurisdiction basis. Rather, the D.C. Circuit Court of Appeals opinion (see below) has apparently prompted the RIAA's attorneys to avoid similar judicial outcomes and proceed directly with filing "John Doe" suits against individuals it believes to have infringed the copyrights of the "Record Companies."
* This page shall be updated from time to time. Unless significant changes occur, the relevance of the information provided should remain the same. Should several days or a couple of weeks pass between page updates, one should not be concerned. If anyone has specific questions, please contact Charles Mudd. Specific updated text can be found in green italicized print.
This page and its contents (except where quoted and otherwise indicated herein) are © 2004 Law Offices of Charles Lee Mudd Jr. Anyone may link to this site. As stated above, this page and its contents have been provided for informational purposes only and SHOULD NOT BE CONSIDERED LEGAL ADVICE or LEGAL REPRESENTATION. While anyone may quote portions of this page, Law Offices of Charles Lee Mudd Jr. requests notification of such use.
