Code Revision Commission et al v. Public.Resource.Org, Inc.

Filing 30

MOTION for Partial Summary Judgment with Brief In Support by Code Revision Commission, State of Georgia. (Attachments: #1 Brief in support, #2 Statement of Undisputed Material Facts, #3 Exhibit 1, #4 Exhibit 2, #5 Exhibit 3, #6 Exhibit 4)(Pavento, Lisa) --Please refer to http://www.gand.uscourts.gov to obtain the Notice to Respond to Summary Judgment Motion form contained on the Court's website.--

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
CODE REVISION COMMISSION on
behalf of and for the benefit of THE
GENERAL ASSEMBLY OF
GEORGIA, and THE STATE OF
GEORGIA,
Plaintiff,
v.

CIVIL ACTION NO.
1:15-CV-02594-MHC

PUBLIC.RESOURCE.ORG, INC.
Defendant.
PLAINTIFF’S LOCAL RULE 56.1 STATEMENT OF
UNDISPUTED MATERIAL FACTS IN SUPPORT OF ITS
MOTION FOR SUMMARY JUDGMENT
Pursuant to Local Rule 56.1(A), Plaintiff and Counterclaim-Defendant the
Code Revision Commission, on behalf of and for the benefit of the General
Assembly of Georgia, and the State of Georgia (“Commission”), and in support of
Plaintiff’s Motion for Summary Judgment, states that there is no genuine issue to
be tried as to the following material facts:
1.

Each Official Code of Georgia Annotated (“OCGA”) volume and

supplement in Exhibit A to the Stipulation of Facts (“Exhibit A”) contains
statutory text and non-statutory annotation text. Dkt. 17 ¶ 1.

2.

The 2014 and 2015 State of Georgia session laws each state in part:

Annotations; editorial notes; Code Revision Commission notes;
research references; notes on law review articles; opinions of the
Attorney General of Georgia; indexes; analyses; title, chapter, article,
part, and subpart captions or headings, except as otherwise provided in
the Code; catchlines of Code sections or portions thereof, except as
otherwise provided in the Code; and rules and regulations of state
agencies, departments, boards, commissions, or other entities which are
contained in the Official Code of Georgia Annotated are not enacted as
statutes by the provisions of this Act.
2014 Ga. Laws 866, § 54; 2015 Ga. Laws 5, § 54. Dkt. 17 ¶ 2.
3.

The non-statutory annotation text of each OCGA volume and

supplement in Exhibit A includes summaries of judicial decisions. Dkt. 17 ¶ 3.
4.

The summaries of judicial decisions in the non-statutory annotations

of each OCGA volume and supplement in Exhibit A are prepared by Matthew
Bender and Company, a member of the LexisNexis Group, a division of Reed
Elsevier Properties, Inc. (“LexisNexis”) under contract for the State of Georgia,
and are finalized under the direct supervision of and subject to the approval of the
Code Revision Commission. Dkt. 17 ¶ 4.
5.

The judicial decisions summarized in the judicial decision summaries

in each OCGA volume and supplement in Exhibit A have been selected by
LexisNexis to be summarized for inclusion in the OCGA, under the direct

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supervision and subject to the approval of the Code Revision Commission. Dkt. 17
¶ 5.
6.

The content of the summaries of judicial decisions in each OCGA

volume and supplement in Exhibit A has been selected for inclusion in the OCGA.
Dkt. 17 ¶ 6.
7.

The summaries of judicial decisions in each OCGA. volume and

supplement in Exhibit A have been coordinated with an OCGA. statute (statutory
text). Dkt. 17 ¶ 7.
8.

The summaries of judicial decisions in each OCGA volume and

supplement in Exhibit A are arranged under the heading “Judicial Decisions” prior
to or following an OCGA. statute (statutory text). Dkt. 17 ¶ 8.
9.

The summaries of judicial decisions are selected, coordinated and

arranged in each OCGA. volume and supplement listed in Exhibit A. Dkt. 17 ¶ 9.
10.

The non-statutory annotation text of each OCGA volume and

supplement in Exhibit A includes editor’s notes. Dkt. 17 ¶ 10.
11.

Editor’s notes in each OCGA. volume and supplement in Exhibit A

are prepared by LexisNexis under contract for the State of Georgia, and under the
direct supervision and subject to the approval of the Code Revision Commission.
Dkt. 17 ¶ 11.
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12.

The editor’s notes in each OCGA volume and supplement in Exhibit

A have been coordinated with an OCGA statute (statutory text). Dkt. 17 ¶ 12.
13.

The editor’s notes in each OCGA volume and supplement in Exhibit

A are arranged after the heading “Editor’s notes” prior to or following an OCGA
statute (statutory text). Dkt. 17 ¶ 13.
14.

The editor’s notes are coordinated and arranged in each OCGA

volume and supplement listed in Exhibit A. Dkt. 17 ¶ 14.
15.

Each OCGA. volume and supplement in Exhibit A is the subject of a

U.S. Copyright Registration as shown in Exhibit A. Dkt. 17 ¶ 17; Dkt. 17-1.
16.

The non-statutory annotation text of each OCGA volume and

supplement listed in Exhibit A includes summaries of opinions of the Attorney
General of Georgia. Dkt. 17 ¶ 18.
17.

The summaries of opinions of the Attorney General of Georgia in the

non-statutory annotations of each OCGA volume and supplement listed in Exhibit
A are prepared by LexisNexis under contract for the State of Georgia, and under
the direct supervision of and subject to the approval of the Code Revision
Commission. Dkt. 17 ¶ 19.

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18.

The opinions of the attorney general of Georgia referenced in each

OCGA volume and supplement listed in Exhibit A have been selected for inclusion
in the OCGA. Dkt. 17 ¶ 20.
19.

The opinions of the Attorney General of Georgia referenced in the

opinion of the attorney general summaries are selected in each OCGA volume and
supplement listed in Exhibit A. Dkt. 17 ¶ 21.
20.

The content of the summaries of opinions of the Attorney General of

Georgia in each OCGA volume and supplement listed in Exhibit A has been
selected for inclusion in the OCGA. Dkt. 17 ¶ 22.
21.

The summaries of opinions of the Attorney General of Georgia in

each OCGA volume and supplement listed in Exhibit A have been coordinated
with an OCGA statute (statutory text). Dkt. 17 ¶ 23.
22.

The summaries of opinions of the Attorney General of Georgia in

each OCGA volume and supplement listed in Exhibit A are arranged under the
heading “Opinions of the Attorney General” prior to or following an OCGA.
statute (statutory text). Dkt. 17 ¶ 24.
23.

The summaries of the opinions of the Attorney General of Georgia are

selected, coordinated and arranged in each OCGA volume and supplement listed in
Exhibit A. Dkt. 17 ¶ 25.
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24.

The non-statutory text of each OCGA volume and supplement listed

in Exhibit A includes summaries of research references. Dkt. 17 ¶ 26.
25.

The summaries of research references in the non-statutory annotations

of each OCGA volume and supplement in Exhibit A are prepared by LexisNexis
under contract for the State of Georgia, and under the direct supervision and
subject to the approval of the Code Revision Commission. Dkt. 17 ¶ 27.
26.

The research references referenced in each OCGA volume and

supplement in Exhibit A have been selected for inclusion in the OCGA. Dkt. 17 ¶
28.
27.

The research references are selected in each OCGA volume and

supplement listed in Exhibit A. Dkt. 17 ¶ 29.
28.

The content of the summaries of the research references in each

OCGA volume and supplement listed in Exhibit A has been selected for inclusion
in the OCGA. Dkt. 17 ¶ 30.
29.

The summaries of research references in each OCGA volume and

supplement listed in Exhibit A have been coordinated with an OCGA statute
(statutory text). Dkt. 17 ¶ 31.

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30.

The summaries of research references in each OCGA volume and

supplement listed in Exhibit A are arranged under the heading “Research
References” prior to or following an OCGA statute (statutory text). Dkt. 17 ¶ 32.
31.

The summaries of research references are selected, coordinated and

arranged in each OCGA volume and supplement listed in Exhibit A. Dkt. 17 ¶ 33.
32.

Public Resource purchased from LexisNexis and copied the entirety

of 186 volumes and supplements of the OCGA, including front and back covers,
which 186 volumes include the volumes and supplements of the OCGA listed in
Exhibit A. Dkt. 17 ¶ 34.
33.

Public Resource posted on its website https//law.resource.org the

copies it made of the OCGA including the volumes and supplements of the OCGA
listed in Exhibit A. Dkt. 17 ¶ 36.
34.

Public Resource has facilitated, enabled, encouraged and induced

others to view, download, print, copy and distribute each OCGA volume and
supplement listed in Exhibit A without limitation or compensation to the State of
Georgia. Dkt. 17 ¶ 38.
35.

Public Resource created works containing each OCGA volume and

supplement listed in Exhibit A. Dkt. 17 ¶ 39.

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36.

The annotations to each OCGA volume and supplement listed in

Exhibit A include summaries of cases that relate to the OCGA, summaries of
Opinions of the Attorney General of Georgia and summaries of research references
related to the OCGA. Dkt. 17 ¶ 40.
37.

Public Resource actively encourages all citizens to copy, use, and

disseminate to others in Georgia and elsewhere and to create works containing the
OCGA volumes and supplements listed in Exhibit A. Dkt. 17 ¶ 41.
38.

The Commission does not assert copyright in the OCGA statutory text

itself because the laws of Georgia are and should be free to the public. Dkt. 17 ¶
45.
39.

Subsequent to July 22, 2015 and with full knowledge of the

Commission’s Complaint (Dkt. No. 1), Public Resource copied the entirety of the
volumes and supplements of the 2015 OCGA shown in Exhibit A and distributed
those copies via posting them on its website https://law.resource.org. Dkt. 17 ¶ 46.
40.

Public Resource’s posting of the entirety of the 114 volumes and

supplements of the OCGA listed in Exhibit A on its website
https://law.resource.org was for the purpose of facilitating, enabling, encouraging
and inducing others to view, download, print, copy and distribute those volumes
and supplements of the OCGA. Dkt. 17 ¶ 48.
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41.

Public Resource’s posting of the entirety of the 114 volumes and

supplements of the OCGA listed in Exhibit A on its website
https://law.resource.org resulted in the copying (downloading) of those volumes
and supplements from that website by members of the public. Dkt. 17 ¶ 49.
42.

Public Resource posted on a website, www.archive.org, copies of the

entirety of the volumes and supplements of the OCGA listed in Exhibit A. Dkt. 17
¶ 50.
43.

Subsequent to July 22, 2015 and with full knowledge of the

Commission’s Complaint (Dkt. No. 1), Public Resource copied the entirety of the
volumes and supplements of the 2015 OCGA listed in Exhibit A and posted them
on the website www.archive.org. Dkt. 17 ¶ 52.
44.

Public Resource’s posting of the entirety of the volumes/supplements

of the OCGA on the website www.archive.org, including those
volumes/supplements listed in Exhibit A, was for the purpose of facilitating,
enabling, encouraging and inducing others to view, download, print, copy and
distribute those volumes and supplements of the OCGA. Dkt. 17 ¶ 54.
45.

Public Resource’s posting of the entirety of volumes and supplements

of the OCGA on the website www.archive.org, resulted in the copying

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(downloading) of each of those volumes/supplements of the OCGA from the
website by members of the public as listed in Exhibit A. Dkt. 17 ¶ 55.
46.

Public Resource distributed USB thumb drives containing scanned

copies of the OCGA to members of the State of Georgia Legislature. Dkt. 17 ¶ 63.
47.

Public Resource distributed copies of the entirety of 90 volumes and

supplements of the OCGA to at least eight institutions in and around the state of
Georgia, Honorable David Ralston, Speaker of the House, Georgia House of
Representatives and Mr. Wayne Allen, Legislative Counsel, Office of Legislative
Counsel, Georgia General Assembly, including those shown in Exhibit A, by
placing those copies on USB thumb drives and mailing them. Dkt. 17 ¶ 64.
48.

Public Resource’s distribution of the entirety of 90 volumes and

supplements of the OCGA to at least eight institutions in and around the state of
Georgia, including those volumes and supplements shown in Exhibit A, was for
the purpose of facilitating, enabling, encouraging and inducing others to view,
download, print, copy and distribute those volumes and supplements of the OCGA.
Dkt. 17 ¶ 65.
49.

The Commission has not authorized Public Resource to copy,

distribute or make derivative works of any entire volume or supplement of the
OCGA, including those shown in Exhibit A, and upon receiving cease and desist
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letters from the Commission, Public Resource refused to remove any and all copies
of the OCGA that it had posted on any website. Dkt. 17 ¶ 66.
50.

The statutory text and numbering of the OCGA is accessible by the

public through the Georgia General Assembly website at www.legis.ga.gov and the
Georgia Senate website at www.senate.ga.gov by clicking on the “Georgia Code”
link on each of those websites which will direct the user to the LexisNexis website
operated for the State of Georgia. Dkt. 17 ¶ 73.
51.

The “Georgia Code” links on the websites www.legis.ga.gov and

www.senate.ga.gov link to the LexisNexis website
http://www.lexisnexis.com/hottopics/gacode/Default.asp (“LexisNexis GA Code
website”), which is operated for the State of Georgia, and the LexisNexis GA Code
website contains the statutory text and numbering of the OCGA. Dkt. 17 ¶ 74.
52.

There is no fee to access the statutory text and numbering of the

OCGA through the LexisNexis GA Code website. Dkt. 17 ¶ 75.
53.

The statutory text and numbering of the OCGA can be electronically

copied and/or printed from the LexisNexis GA Code website. Dkt. 17 at ¶ 76.
54.

The statutory text of the OCGA is searchable by term on the

LexisNexis GA Code website. Dkt. 17 ¶ 77.

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55.

Public Resource operates the websites public.resource.org,

law.resource.org, house.resource.org, bulk.resource.org and others. Dkt. 17 ¶ 79.
56.

At least one copy of each OCGA volume and supplement that Public

Resource posted on its https//law.resource.org website is in an electronic format
that displays an image of the printed publication as copied by Public Resource,
which image allows for electronic page turning of the printed publication. Exhibit
B to the Stipulation of Facts (Dkt. 17-2) is a true and correct copy of the front
cover of one such image. Dkt. 17 ¶ 37.
57.

The preface in each OCGA volume and supplement in Exhibit A of

the Stipulation of Facts (Dkt. 17-1) is prepared under contract by LexisNexis for
the State of Georgia and under the direct supervision and subject to the approval of
the Code Revision Commission. Dkt. 17 ¶ 15.
58.

Public.Resource.Org has argued:

The distinction between ‘the statutory text itself’ and additional
materials perhaps would have some bearing if the publication in
question were the independent commercial endeavor of a publication
firm. If such firm were to copy the state statutes and compile that
information with additional analyses and summaries and were to do so
as a strictly commercial endeavor, we understand and respect that this
material would be their private property. Dkt. No. 17-4, p. 2.

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59.

The Official Code of Georgia Annotated is a compilation of the Georgia

statutes and other non-statutory materials, or annotations, which has been published
yearly since 1982. Exhibit 1, Declaration of Elizabeth P. Howerton ¶ 3.
60.

The annotations in the OCGA provide analyses and other information

that allow for a better or easier understanding of a relevant statute. The annotations
included in the OCGA are original and creative summaries of judicial decisions,
editor’s notes, summaries of opinions of the Attorney General of Georgia, and
compilations thereof. Ex. 1 ¶¶ 3, 4.
61.

The OCGA is published by Matthew Bender and Company, Inc., a

member of the LexisNexis Group (“LexisNexis”), a division of Reed Elsevier
Properties, Inc. under a work for hire agreement with the State of Georgia. Ex. 1 ¶
5.
62.

When entering the contract with LexisNexis, the ability of the state to

keep the price of the OCGA low for the benefit of the citizens of Georgia was an
important consideration. Ex. 1 ¶ 6.
63.

West’s Code of Georgia Annotated is another compilation of the

Georgia statutes and annotations thereof that is published by West Publishing. Ex. 1
¶ 7.

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64.

The OCGA contains the official, or State of Georgia-approved,

codified statutory text (OCGA. 1-1-1), whereas the statutory text in West’s Code of
Georgia Annotated is not approved by the State. Ex. 1 ¶ 8.
65.

The current price of a complete OCGA set is $404.00 as compared to

$2,570.00 for a complete set of West’s Code of Georgia Annotated. Ex. 1 ¶ 9.
66.

The entire OCGA, including the annotations, is available for viewing

on compact disc at over 60 state- and county-operated facilities such as state and
county libraries, state universities, and county law enforcement offices within the
State of Georgia. Ex. 1 ¶ 10.
67.

The

Georgia

General

Assembly

has

websites

at

http://www.legis.ga.gov, http://www.house.ga.gov, and http://www.senate.ga.gov
that provide live broadcasts of both legislative houses, links to the Georgia Code,
and the ability to search pending legislation, obtain contact information for
legislators, and obtain state budget documents. Ex. 1 ¶ 11.
68.

The Georgia Code was accessed almost 79 million times between 2007

and 2015 via the website that is linked to the Georgia General Assembly websites.
Ex. 1 ¶ 12.

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69.

In 1994, the Board of Regents of the University System of Georgia and

the University of Georgia created GALILEO, the first state wide digital library. Ex.
1 ¶ 13.
70.

GALILEO can be found at http://dlg.galileo.usg.edu. Ex. 1 ¶ 13.

71.

GALILEO provides access to the Georgia Laws, which is a publication

of Georgia laws (both codified and uncodified) as enacted by the Georgia
Legislature. Ex. 1 ¶ 14.
72.

In 1996, the Georgia Government Publications database (GGP) was

created as GALILEO's first digital conversion initiative of publications released by
agencies of Georgia's executive branch. Ex. 1 ¶ 15.
73.

Georgia law (OCGA. 20-5-2) requires Georgia state agencies to submit

publications to GALILEO that they produce for the public. Ex. 1 ¶ 16.
74.

The GGP database consists of over 70,000 documents produced by

Georgia state agencies. Ex. 1 ¶ 17.
75.

Prior to the State of Georgia filing a lawsuit against Public Resource,

Public Resource copied and distributed hundreds of annotated state code volumes of
several states, including Georgia, Mississippi and Idaho, and then informed each
state of its actions. Ex. 1 ¶ 18.

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76.

Under the Publication Agreement between the State of Georgia and

LexisNexis, the annotations in the OCGA remain the property of the State of
Georgia and LexisNexis obtains copyright registrations therefore. Exhibit 2,
Agreement for Publication, § 6.1.
77.

LexisNexis is granted the exclusive right to publish and sell the

OCGA according to the prices set in the publication contract, with any price
increases at the sole discretion of the Commission. Ex. 2 §§ 5, 8.
78.

LexisNexis created the summaries of judicial decisions in the OCGA

works using a lengthy process of selection, analysis and summarization. Exhibit 3,
Declaration of Anders X. Ganten ¶¶ 3-15.
79.

LexisNexis identified and read each potentially relevant judicial

decision, determined how the case relates to a statute, and then determined the type
of annotation that should be created. Ex. 3 ¶¶ 4, 5.
80.

For those cases of significance, LexisNexis created an original several

line summary of the case that distills the case’s relevant holding relating to the
statute. Ex. 3 ¶¶ 7, 8.
81.

The OCGA annotation of the judicial decision Cho Carwash

Property, LLC. v. Everett (326 Ga. App. 6 (2014)) published in the 2014 edition of
the OCGA. as associated with Georgia statute § 34-9-260 is as follows:
16

Average weekly wage calculated correctly. – Award of workers’
compensation benefits was upheld because there was some evidence
to support the administrative law judge’s calculation of the
claimant’s average weekly wage under OCGA. § 34-9-260(3) based
on the claimant’s testimony that the claimant was supposed to work
from the car wash’s opening until its close. Cho Carwash Property,
LLC. v. Everett, 326 Ga. App. 6, 755 S.E.2d 823 (2014).
Ex. 3 ¶¶ 9, 13.
82.

Each of the OCGA Works further contains original and creative

compilations of summaries of judicial decisions, editor’s notes, summaries of
opinions of the Attorney General of Georgia, summaries of research references,
and compilations of these compilations. Ex. 3 ¶ 5.
83.

Each judicial decision summary, editor’s note, and summary of an

opinion of the Attorney General of Georgia was first selected for inclusion in the
OCGA by LexisNexis and then coordinated with a particular statute. Ex. 3 ¶ 3.
84.

When multiple summaries or editor’s notes were coordinated with a

single code section, each was arranged in a particular order. Ex. 3 ¶ 4.
85.

The correspondence shown in Exhibit C to the Stipulation of Facts

(Dkt. 17-3) is a true and exact copy of a letter written by Mr. Malamud and sent to
David Ralston and Wayne Allen on May 30, 2013. Dkt. 17 ¶ 67.

17

86.

The correspondence shown in Exhibit D to the Stipulation of Facts

(Dkt. 17-4) is a true and exact copy of a letter written by Mr. Malamud and sent to
Joshua McKoon, David Ralston and David Shafter on July 30, 2013. Dkt. 17 ¶ 68.
87.

The correspondence shown in Exhibit E to the Stipulation of Facts

(Dkt. 17-5) is a true and exact copy of a letter written by Joshua McKoon and sent
to Mr. Malamud on July 25, 2013. Dkt. 17 ¶ 69.
88.

The correspondence shown in Exhibit F to the Stipulation of Facts

(Dkt. 17-6) is a true and exact copy of a letter written by Joshua McKoon and sent
to Mr. Malamud on August 15, 2013. Dkt. 17 ¶ 70.
89.

The correspondence shown in Exhibit G to the Stipulation of Facts

(Dkt. 17-7) is a true and exact copy of a letter written by Joshua McKoon and sent
to Mr. Malamud on April 2, 2014. Dkt. 17 ¶ 71.
90.

To access the statutory text and numbering in the OCGA via the

website link found on the State of Georgia website, www.legis.ga.gov, one must
accept the terms and conditions of use generally applicable to the LexisNexis
websites (“LexisNexis Website Use Terms and Conditions”). A true and correct
copy of the LexisNexis Website Use Terms and Conditions is attached to the
Stipulation of Facts as Exhibit I (Dkt. 17-9). The access page that allows users to
access the online publication by accepting the LexisNexis Website Use Terms and
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Conditions explicitly states that the LexisNexis Website Use Terms and Conditions
do not apply to the OCGA statutory text and numbering. A true and correct copy of
this access page is attached to the Stipulation of Facts as Exhibit J (Dkt. 17-6). Dkt.
17 ¶ 86.
WHEREFORE, there being no genuine issue of material fact and being
entitled to judgment as a matter of law on the issues addressed herein, Plaintiff
requests that this Court grant its motion as to all of Plaintiff’s counts of copyright
infringement, pursuant to Rule 56 and Local Civil Rule 56.1.
Respectfully submitted, this 17th day of May, 2016.
/s/Lisa C. Pavento
Lisa C. Pavento (G.A. Bar: 246698)
Anthony B. Askew (G.A. Bar: 025300)
Warren Thomas (G.A. Bar: 164714)
Meunier Carlin & Curfman LLC
999 Peachtree Street, NE, Suite 1300
Atlanta, Georgia 30309
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Counsel for the Plaintiff, Code Revision
Commission on behalf of and for the benefit
of the General Assembly of Georgia, and the
State of Georgia
19

CERTIFICATE OF COMPLIANCE
I hereby certify that, pursuant to L.R. 5.1C and 7.1D of the Northern District
of Georgia, the foregoing PLAINTIFF’S LOCAL RULE 56.1 STATEMENT OF
UNDISPUTED MATERIAL FACTS IN SUPPORT OF ITS MOTION FOR
SUMMARY JUDGMENT complies with the font and point selections approved
by the Court in L.R. 5.1C. The foregoing pleading was prepared on a computer
using 14-point Times New Roman font.

/s/Lisa C. Pavento
Lisa C. Pavento (G.A. Bar: 246698)
Meunier Carlin & Curfman LLC
999 Peachtree Street NE, Suite 1300
Atlanta, Georgia 30309
Telephone: [phone]
Email: [e-mail]

20

CERTIFICATE OF SERVICE
I certify that on Tuesday, May 17, 2016, I electronically filed the foregoing
PLAINTIFF’S LOCAL RULE 56.1 STATEMENT OF UNDISPUTED
MATERIAL FACTS IN SUPPORT OF ITS MOTION FOR SUMMARY
JUDGMENT with the Clerk of Court using the CM/ECF system, which constitutes
service of the filed document on all counsel of record in this proceeding under LR
5.1(A)(3), N.D. Ga.

By:

/s/Lisa C. Pavento
Lisa C. Pavento (G.A. Bar: 246698)
Anthony B. Askew (G.A. Bar: 025300)
Warren Thomas (G.A. Bar: 164714)
Meunier Carlin & Curfman LLC
999 Peachtree Street, NE, Suite 1300
Atlanta, Georgia 30309
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Counsel for the Plaintiff, Code Revision
Commission on behalf of and for the benefit
of the General Assembly of Georgia, and the
State of Georgia

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