American Atheists, Inc. et al v. Port Authority of New York and New Jersey et al

Filing 2

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Governor Chris Christie, Church Of The Holy Name Of Jesus, Brian Jordan, Lower Manhattan Development Corporation, Port Authority of New York and New Jersey, Silverstein Properties, Inc., State of New Jersey, World Trade Center Memorial Foundation/National September 11 Memorial And Museum, World Trade Center Properties, LLC.(pl)

UNITED rflrT^y&KTCT COURT
SOUTHERN DISTRICT OF NEW YORK
AMERICAN ATHEISTS, INC.; DENNIS
HORVITZ; KENNETH BRONSTEIN;
MARK PANZARINO; AND JANE
EVERHART,
Plaintiffs,
v.
PORT AUTHORITY OF NEW YORK
AND NEW JERSEY; STATE OF NEW
JERSEY; GOVERNOR CHRIS
CHRISTIE, in his official capacity;
SILVERSTEIN PROPERTIES, INC.;
LOWER MANHATTAN
DEVELOPMENT CORPORATION;
WORLD TRADE CENTER MEMORIAL
FOUNDATION / NATIONAL
SEPTEMBER 11 MEMORIAL AND
MUSEUM; WORLD TRADE CENTER
PROPERTIES, LLC; CHURCH OF THE
HOLY NAME OF JESUS; AND BRIAN
JORDAN,

No. 11 Civ.

ECF Case
Removed from the Supreme Court of the
State of New York,
Index No. 11-108670 (Hon. Richard F.
Braun)

ffE^

Defendants.

RULE 7.1 CORPORATE DISCLOSURE STATEMENT
Pursuant to Federal Rule of Civil Procedure 7.1(a), the undersigned
counsel for defendants World Trade Center Memorial Foundation / National September
11 Memorial and Museum1 and Lower Manhattan Development Corporation state as
follows:

As stated in defendants' notice of removal which is being filed contemporaneously, plaintiffs
have named "World Trade Center Memorial Foundation / National September 11 Memorial
and Museum" as a defendant. Plaintiffs appear to be referring to the National September 11
Memorial & Museum at the World Trade Center Foundation, Inc. At the appropriate time,
that defendant will petition the Court for an order that the pleadings reflect its correct name.

1.

National September 11 Memorial & Museum at the World Trade

Center Foundation, Inc. is a public charity registered under section 501(c)(3) of the
Internal Revenue Code, 26 U.S.C. § 501(c)(3). National September 11 Memorial &
Museum at the World Trade Center Foundation, Inc. has no parent corporation and no
stock, meaning that there is no "publicly held corporation owning 10% or more of its
stock" within the meaning of Federal Rule of Civil Procedure 7.1(a)(1).
2.

Lower Manhattan Development Corporation is a subsidiary of the

New York State Urban Development Corporation, doing business as Empire State
Development. New York State Urban Development Corporation is a public benefit
corporation of the State of New York.

Dated: New York, New York
August 26, 2011
Respectfully submitted,
PAUL, WEISS, RIFKIND, WHARTON &
GARRISON LLP

B y : , . t;>>i/'<~ i±_i
Mark H. Alcott
Gerard E. Harper
Hannah S. Sholl
Paul A. Paterson
1285 Avenue of the Americas
New York, New York 10019-6064
Tel: [phone]
Fax:[phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants National
September 11 Memorial & Museum at the
World Trade Center Foundation, Inc. and
Lower Manhattan Development Corporation