UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO. 1:22-cv-23753-KMM

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated,

Plaintiffs, 

v. 

SAM BANKMAN-FRIED, et al.,

Defendants.

/

PLAINTIFFS’ MOTION TO SERVE DEFENDANT SHAQUILLE O’NEAL 

THROUGH APPROVED ALTERNATE MEANS

Defendant Shaquille O’Neal has had actual knowledge of the allegations against him in 

this matter since this suit was first filed November 15, 2022. While Plaintiffs understand that 

“actual knowledge” is not alone sufficient for effecting service, this fact is important to give 

context to Plaintiff’s request to serve him now via alternative methods. Mr. O’Neal’s conduct over 

the last 5 months in evading service in this action is unprecedented, and frankly shocking, based 

upon on the extent of his public appearances, persona, and presence. Mr. O’Neal is the sole

remaining defendant in this matter who has still not been served. Despite Plaintiffs’ dozens of 

attempts in multiple states and countries, to either effect service on him or have him (or a 

designated agent) accept service of process.

Just last week, after the eighth most recent attempt at O’Neal’s Texas residence, Plaintiffs’ 

process server in Texas received a threatening text message stating “shaq lives in the Bahamas u 

stupid fuck give beth shaw my regards.” See Declaration of Joseph Kaye, filed concurrently 

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herewith (“Kaye Decl.”), ¶ 12, Comp. Ex. E, at 3. Beth Shaw is the wife of our retained process 

server. Enough is enough.

Plaintiffs respectfully suggest that it is finally time to move this massive class action case 

along and therefore request the Court approve the suggested alternate service of process on O’Neal

through, among other methods, direct messages to his verified social media accounts, as set forth 

below.

News of this lawsuit, filed closely on the heels of the collapse of FTX—the largest financial 

debacle in history—has been disseminated through nearly every conceivable source of news, 

across almost every country, be it on television, the internet, or otherwise. Dozens of articles 

published globally and nationwide specifically call out Defendant O’Neal.

1 Defendant O’Neal, as 

set forth below, publicly acknowledged his actual notice of this suit shortly after it was filed. 

Plaintiffs respectfully request that under these specific, verified circumstances, the Court 

grant this motion to effect service on Shaquille O’Neal through various electronic means that are

reasonably calculated to provide O’Neal with additional actual notice of the lawsuit and the 

allegations against him, namely through his social media accounts, his attorneys’ emails, and 

through publication on a dedicated webpage, located at https://moskowitz-law.com/service-bypublication-of-garrison-v-bankman-fried-122-cv-23753-sd-fla-on-shaquille-oneal (the “Service 

Webpage”). 

1 See, e.g., “Shaq, Naomi Osaka, Steph Curry named as defendants in class-action suit against 

embattled crypto company FTX,” published November 17, 2022, at 

https://www.yahoo.com/video/shaq-naomi-osaka-steph-curry-164000087.html (accessed April 7, 

2023); “FTX Investors Sue Shaquille O’Neal, Naomi Osaka, Steph Curry,” published November 

28, 2022, at https://peopleofcolorintech.com/articles/ftx-investors-sue-shaquille-oneal-naomiosaka-steph-curry/ (accessed April 7, 2023); “Brady, Curry, Shaq Among Athletes Facing Lawsuit 

in FTX Debacle,” published November 16, 2022, at https://www.si.com/nfl/2022/11/16/bradycurry-shaq-among-athletes-facing-lawsuit-in-ftx-debacle (accessed April 7, 2023). 

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As explained below, shortly before filing this Motion, Plaintiffs served O’Neal with the 

above link (1) via direct message from The Moskowitz Law Firm’s Twitter account to one of 

O’Neal’s verified Twitter accounts (@DJDiesel);23 (2) via direct message from The Moskowitz 

Law Firm’s Instagram account to O’Neal’s verified Instagram accounts (@Shaq and @DJDiesel); 

and (3) via email to Shaq’s prior and current counsel in other matters. Kaye Decl. ¶ 15.

Plaintiffs’ respectfully request, pursuant to Federal Rule of Civil Procedure 4(e)(1) and the 

specific law of the State of Texas, where O’Neal resides, that the Court enter an Order authorizing 

service of process on O’Neal and deeming him served as of April 6, 2023, the date when Plaintiffs’ 

Counsel sent these materials directly to O’Neal (or alternatively, the date the Court enters an order 

authorizing service through these means). To the extent necessary, Plaintiffs’ alternatively request 

an additional extension of time to effect service on O’Neal through these same types of methods.

FACTUAL BACKGROUND

Shaquille O’Neal has demonstrably had actual notice of this action since at least December 

15, 2022, when CNBC published an article containing O’Neal’s comments during his interview 

with CNBC Make It that week regarding the allegations in this suit, which also confirmed that his 

2 O’Neal made history back in 2008 as the first ever verified Twitter user with his @Shaq account, 

and it is common knowledge that he manages his own Twitter and social media accounts as a 

means of interacting directly with his fanbase. See https://www.essentiallysports.com/nbabasketball-news-way-before-elon-musks-twitter-blue-tick-fiasco-shaquille-oneal-made-historyon-1-billion-worth-social-media-platform/ (accessed April 7, 2023); see also

https://theathletic.com/1234609/2019/09/24/shaquille-oneal-early-adoption-twitter-changedathlete-relations-forever/ (accessed April 7, 2023). While it appears O’Neal disabled direct 

messages to his @Shaq Twitter account, the Service Website link was direct messaged to his 

@DJDiesel Twitter account and both his @Shaq and @DJDiesel Instagram accounts.

3 O’Neal moonlights as “DJ Diesel,” producing electronic music and DJing at festivals around the 

country. https://www.essentiallysports.com/nba-basketball-news-dj-diesel-shaquille-oneal-choseto-pursue-a-career-in-electronic-music-because-of-its-similarity-to-basketball/ (accessed April 7, 

2023).

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public FTX statement (namely that He was “All in, are You?” on FTX), for which he was paid 

likely millions of dollars by FTX to make, was simply false:

4

“A lot of people think I’m involved, but I was just a paid spokesperson for a 

commercial,” O’Neal says.

. . . 

Today, O’Neal cites his friendship with Curry as a reason he consented to appear 

in the ad. A spokesperson for Curry declined to comment.

In the ad, O’Neal told viewers that he checked his FTX account daily. But when 

asked now if he’s bullish on crypto, he offers a simple response: “No.”

“People know I’m very, very honest,” O’Neal says. “I have nothing to hide. If I was 

heavily involved, I would be at the forefront saying, ‘Hey.’ But I was just a paid 

spokesperson.”

It’s unclear how much money O’Neal made from his FTX endorsement deal.

Despite O’Neal’s actual knowledge of this action for at least the last four months, and his 

claim that he has “nothing to hide,” to date he has not allowed himself to be served with process, 

has not had any counsel confirm that they will represent him in this action, or otherwise appeared 

in this action.

Shaquille O’Neal owns and has owned a large number of homes all across the country, 

from Florida and Georgia, to Texas, to Nevada and California, and sometimes resides in Bahamas.

5

Plaintiffs’ Counsel’s investigation showed, however, that while Defendant O’Neal is regularly on 

the move between these locations (making personal service of process more difficult than with an 

average American), he was likely spending much of his time in Texas, based on reports that he “is 

4 See “Shaq distances himself from crypto and FTX collapse: ‘I was just a paid spokesperson,’” 

dated December 15, 2022, published at https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftxpost-collapse-i-was-just-a-paid-spokesperson.html (accessed April 7, 2023).

5 https://www.realtor.com/news/celebrity-real-estate/every-home-shaquille-oneal-has-ownedpast-and-present/ (accessed April 7, 2023). 

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expanding [his] Big Chicken franchise to Texas, and as a result, he has bought a house there to 

help facilitate the move.”6

The process servers made several service attempts at the most recent, last-known address 

listed for Defendant O’Neal in Texas. After learning that Defendant O’Neal sold his former 

Sugarland residence (apparently to his ex-wife, Arnetta Yardbourgh), our process server has also 

been trying to track Mr. O’Neal based upon various posts on his social media. Plaintiffs’ Counsel’s 

investigation showed that Defendant O’Neal recently purchased another home in Texas, but the 

address was not listed and did not show up in the process server’s skip trace. See Kaye Decl. ¶ 5, 

Comp. Ex. A. After combing through public records and reports of the purchase of the new home 

(all of which did not list the address of the property because (1) O’Neal did not purchase the home 

in his individual capacity and (2) the reports only stated his home was in “Carrollton, Texas” and 

gave the statistics for the home, such as the square footage and number of bedrooms or bathrooms), 

Plaintiffs’ Counsel finally located an article that gave away the full address of 4012 Sahara Court, 

Carrollton, Texas 75010.7 Id. Since obtaining the address, the process server has made numerous 

attempts at effecting service on O’Neal at his Carrollton address, including through personal 

service and through FedEx (serving the summons, complaint, and the pending MDL petition), and 

Plaintiffs’ Counsel have directed them to continue attempting service. Id.

At the same time, Plaintiffs’ Counsel worked to determine whether there are any attorneys 

who represent or have previously represented Defendant O’Neal who either (1) intend to represent

6 https://thesportsrush.com/nba-news-shaquille-oneal-has-a-new-1-22-million-home-in-northtexas-amid-big-chicken-restaurant-expansion-plans/ (accessed April 7, 2023). 

7 https://www.housedigest.com/913481/take-a-tour-of-shaquille-oneals-stunning-new-texashome/ (accessed April 7, 2023). 

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him, (2) will accept service on his behalf, or (3) would provide information to facilitate his service.

Kaye Decl. ¶ 6.

Plaintiffs’ counsel first reached out to Benjamine Reid, Clifton R. Gruhn, and Jeffrey A. 

Cohen, shareholders at the Miami office of Carlton Fields who recently represented Mr. O’Neal 

in many different litigation,

8 with Notice of Commencement and Request for Waiver of Service 

forms and a copy of the operative Amended Complaint. Kaye Decl. ¶ 7, Comp. Ex. B. They

disclaimed knowledge of O’Neal’s representation and declined to forward the materials to Mr. 

O’Neal. Id.

Then, Plaintiffs’ Counsel contacted Peter W. Ross and Eric C. Lauritsen of Ross LLP, who 

represented O’Neal as recently as two months ago,

9 with Notice of Commencement and Request 

for Waiver of Service forms and a copy of the operative Amended Complaint. Kaye Decl. ¶ 8, Ex. 

C. On a phone call, attorney Lauritsen similarly disclaimed any personal knowledge of O’Neal’s 

representation or whereabouts. Mr. Ross’s response to Plaintiffs’ Counsel’s email is outstanding.

Id.

Finally, Plaintiffs’ Counsel contacted attorney Dennis Roach, who has apparently 

represented and worked with O’Neal in various matters for years.10 Kaye Decl. ¶ 9. On a phone 

call, Mr. Roach confirmed that O’Neal was his client. When asked whether he represented him in 

8 https://www.law.com/dailybusinessreview/2021/05/13/slam-dunk-carlton-fields-lawyers-score413k-in-attorney-fees-for-shaquille-oneal/ (accessed April 7, 2023); see also 

https://www.abajournal.com/news/article/biglaw_lawyers_sanctioned_for_advising_shaquille_o

neal_he_didnt_need_to_att (accessed April 7, 2023). 

9 https://www.law360.com/articles/1570921/shaq-settles-suit-against-pot-co-allegingmismanaged-funds (accessed April 7, 2023). 

10 https://abcnews.go.com/Sports/shaq-lawyer-calls-incident-horseplay/story?id=23045999

(accessed April 7, 2023); https://www.prnewswire.com/news-releases/shaquille-oneal-unveils-allstar-board-of-directors-for-the-shaquille-oneal-foundation-301273421.html (accessed April 7, 

2023). 

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this action or if he knew who did, he said to send him the information and he would “speak to the 

powers that be” to confirm and would “get back” to Plaintiffs’ Counsel. Id. Plaintiffs’ Counsel 

followed up with an email with Notice of Commencement and Request for Waiver of Service 

forms and a copy of the operative Amended Complaint. Id. 

Plaintiffs’ Counsel followed up with Mr. Roach on March 29, 2023, but to date has received 

no further response. Kaye Decl. ¶ 10. O’Neal’s deadline to execute that waiver (if he decides to 

do so) is Monday, April 10, 2023.

On March 10, 2023, Plaintiffs filed a Response to the Court’s Show Cause Order, [ECF 

No. 99], explaining the specific issues with serving O’Neal with process and requesting an 

extension of time to continue their efforts, which the Court granted by an Order extending the 

deadline for Plaintiffs to serve Defendant O’Neal to April 17, 2023. ECF No. 101.

In addition to the previous attempts to serve O’Neal outlined above, Plaintiffs have also

attempted personal service on Defendant O’Neal at his Texas residence on eight additional 

occasions over nearly a month. Kaye Decl. ¶ 12, Comp. Ex. E (affidavits of nonservice and 

affidavit of due diligence). After the eighth attempt, Plaintiffs’ process server in Texas received a 

text message later that night, stating “shaq lives in the Bahamas u stupid fuck give beth shaw my 

regards.” Id. at 3 (emphasis added). Plaintiffs’ investigation confirms O’Neal does not live in the 

Bahamas. Id.

Beth Shaw is the process server’s wife, which the sender of the text (from 518-816-0323) 

would only have known after conducting a background check into Mr. Shaw, who left his business 

card at O’Neal’s residence during his attempts at service, which included his name and phone 

number. Kaye Decl. ¶ 13, Comp. Ex. E. Believing the text to have originated from O’Neal or 

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someone acting on his behalf, Mr. Shaw was no longer comfortable attempting to personally serve 

Mr. O’Neal with process, fearing for his and his wife’s safety. Id.

Plaintiffs’ counsel have also made efforts to serve Defendant O’Neal in Georgia, where he 

also maintains a residence. Process servers made 12 attempts at O’Neal’s Georgia residence, and 

were unable to locate or contact O’Neal. Kaye Decl. ¶ 14, Comp. Ex. F (affidavits of nonservice). 

Plaintiffs’ counsel also sent the summons and operative complaint via FedEx to O’Neal’s Georgia 

residence and his office at Turner Sports in Atlanta (from where O’Neal regularly appears on 

TNT). Kaye Decl. ¶ 14, Comp. Ex. G (FedEx Delivery Confirmations with Pictures). Further, 

Plaintiffs’ counsel sent via FedEx the summons, operative complaint, necessary check, and cover 

letter to the Civil Unit of Henry County Sheriff’s Office (where O’Neal is a Director of Community 

Relations),

11 requesting assistance in effecting service of process on Mr. O’Neal. Kaye Decl. ¶ 14,

Comp. Ex. H. The check cleared April 3, 2023, though to date Plaintiffs’ Counsel have received 

no response from the Henry County Sheriff’s Office. Kaye Decl. ¶ 14.

As we have done in prior cases before this Court, on April 6, 2023, Plaintiffs created the 

Service Webpage, and served O’Neal with the link to the Service Webpage (1) via direct message 

from The Moskowitz Law Firm’s Twitter account to one of O’Neal’s verified Twitter account 

(@DJDiesel); (2) via direct message from The Moskowitz Law Firm’s Instagram account to 

O’Neal’s verified Instagram accounts (@Shaq and @DJDiesel); and (3) via email to Shaq’s prior 

and current counsel in other matters. See Kaye Decl. ¶ 15, Comp Ex. I. The direct message to 

O’Neal’s accounts read as follows:

Mr. O’Neal, in accordance with Federal Rule of Civil Procedure 4(e)(1) and Texas 

Rule of Civil Procedure 106(b)(2), please find the summons, operative complaint, 

and other important materials regarding the claims filed against you in the action 

11 https://www.safehenry.com/keep-in-touch-with-site-visitors-and-boost-loyalty (accessed April 

7, 2023).

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pending in the Southern District of Florida before the Honorable Judge K. Michael 

Moore, styled Garrison, et al. v. Bankman-Fried, et al., No. 1:22-cv-23753 (S.D. 

Fla.): https://moskowitz-law.com/service-by-publication-of-garrison-v-bankmanfried-122-cv-23753-sd-fla-on-shaquille-oneal

This is the same action you publicly commented on December 15, 2022: “Shaq 

distances himself from crypto and FTX collapse: ‘I was just a paid spokesperson,’” 

dated December 15, 2022, published at https://www.cnbc.com/2022/12/15/shaqon-crypto-ftx-post-collapse-i-was-just-a-paid-spokesperson.html

Thank you.

Id.

The irony is that O’Neal is extremely active on his social media accounts. The number of 

posts made on each account since this action was filed and the date of the most recent posts are as 

follows:

• @Shaq (Instagram – 30 million followers and 3,752 posts): April 4, 2023; 127 posts 

since this action was filed. O’Neal includes what is apparently his cell phone 

number on this account, stating “Text me 818-583-8345” in the headline. O’Neal 

posted on April 9, 2020, confirming this was his number: 

https://www.instagram.com/p/B-xlr1nl1Qn/ (accessed April 7, 2023).

• @DJDiesel (Instagram – 397K followers and 399 posts): March 21, 2023; 21 posts 

since this action was filed.

• @Shaq (Twitter – 15.9M followers and 10.4K tweets since November 2008): April 

5, 2023; 57 posts since this action was filed.

• @DJDiesel (Twitter – 77.3K followers and 550 tweets since September 2019):

April 5, 2023; 30 posts since this action was filed.

Kaye Decl. ¶ 16.

LEGAL ARGUMENT

Federal Rule of Civil Procedure 4(e)(1) allows service pursuant to the law of the state either 

where the district court is located or where service is effected. Izen v. Catalina, 256 F.3d 324, 327 

(5th Cir. 2001) (citing Fed. R. Civ. Proc. 4(e)(1) and approving service of complaint filed in federal 

district court in Texas on Defendant in Oklahoma pursuant to Oklahoma law); see also, e.g., Doe 

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v. Islamic Salvation Front (FIS), 993 F. Supp. 3, 7 (D.D.C. 1998) (approving personal service in 

Virginia of complaint filed in D.C. and explaining Rule 4(e) service “is not limited to the district 

in which the complaint was filed”).

Under the law of Texas, where Defendant O’Neal resides at 4012 Sahara Court, Carrollton, 

Texas 75010, Defendant O’Neal may be served personally or by registered or certified mail (return 

receipt requested) as approved under Texas Rule of Civil Procedure 106(a), or, if service under 

either method prescribed under 106(a) is unsuccessful, the court may authorize another method of 

service under Texas Rule 106(b). Joe Hand Promotions, Inc. v. Wash That Baby, LLC, MO:21-

CV-211-DC-RCG, 2022 WL 2761734, at *1 (W.D. Tex. May 9, 2022) (authorizing service 

through direct message to defendant’s Facebook account where plaintiffs submitted sworn 

statements from process servers that personal service on defendant was unsuccessful, that 

defendant had left the state and his return date was unknown, and that defendant actively used the 

Facebook account).

Texas Rule of Civil Procedure 106(b) allows for substitute service:

(b) Upon motion supported by a statement—sworn to before a notary or made under 

penalty of perjury—listing any location where the defendant can probably be found 

and stating specifically the facts showing that service has been attempted under 

(a)(1) or (a)(2) at the location named in the statement but has not been successful, 

the court may authorize service:

(1) ...; or

(2) in any other manner, including electronically by social media, email, or other 

technology, that the statement or other evidence shows will be reasonably effective 

to give the defendant notice of the suit.

Id. (emphasis added); see also Chrisenberry v. Ketcher, No. MO:21-CV-146-DC-RCG, 2022 WL 

2762219, at *1 (W.D. Tex. May 18, 2022) (authorizing service through direct message to 

defendant’s Facebook account where plaintiffs submitted sworn statements from process servers 

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that personal service on defendant was unsuccessful, “despite reasonable investigation and 

efforts,” and that defendant actively used the Facebook account).

Here, Plaintiffs have attempted to effect service of process at 4012 Sahara Court, 

Carrollton, Texas 75010 at least a dozen times pursuant to Texas Rule of Civil Procedure 

106(a)(1), which ended when the process server was sent an ominous and threatening text message 

by O’Neal or someone acting on his behalf. Kaye Decl. ¶¶ 12–13, Comp. Ex. E. The only way that 

O’Neal or someone acting on his behalf would have gotten the information necessary to send this 

text to Mr. Shaw is if they physically went to 4012 Sahara Court and retrieved the business card 

he left there with his contact information. Id. That the text included misinformation in addition to 

the veiled threat (that they knew who Mr. Shaw’s wife was and asked he give her their “regards”)

is clear evidence that O’Neal is evading service, by any means necessary. 

Accordingly, given the circumstances, substitute service of process through social media 

pursuant to Texas Rule of Civil Procedure 106(b)(2) is necessary to complete service of process 

on Defendant O’Neal. This case needs to proceed.

Not only is service through O’Neal’s social media accounts necessary and proper under 

Rule 106(b)(2), but the evidence also shows it will be reasonably effective to give O’Neal notice 

of this action. To be sure, while O’Neal has demonstrated he has notice of this action since 

December 15, 2022,

12 the evidence demonstrates that he has made 235 posts between his two 

verified Twitter accounts and two verified Instagram accounts since this lawsuit was filed against 

him, with the most recent ones being posted April 5, 2023. The accounts are filled with personal 

videos apparently filmed by O’Neal himself, who made history back in 2008 as the first ever 

12 See “Shaq distances himself from crypto and FTX collapse: ‘I was just a paid spokesperson,’” 

dated December 15, 2022, published at https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftxpost-collapse-i-was-just-a-paid-spokesperson.html (accessed April 7, 2023).

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verified Twitter user, and is commonly known to personally manage these accounts as a means of 

interacting directly with his fanbase.13

On April 6, 2023, Plaintiffs sent the messages with the link to the Service Webpage to 

O’Neal’s Instagram and Twitter accounts, as well as to the emails of the counsel known to have 

recently represented him in other matters. Kaye Decl. ¶ 15, Comp. Ex. I. For the reasons explained 

in this motion, Plaintiffs respectfully submit the Court should authorize service by these means in 

accordance with applicable law and deem O’Neal served as of April 6, 2023, so that this action 

may finally proceed with all Defendants before the Court. 

CONCLUSION

Plaintiffs respectfully request, pursuant to Federal Rule of Civil Procedure 4(e)(1) and the 

law of the State of Texas, where O’Neal resides, that the Court grant this motion to effect service 

on Shaquille O’Neal through various electronic means reasonably calculated to provide O’Neal 

with additional actual notice of the lawsuit and the allegations against him, namely through direct 

message of the Service Webpage to three of his social media accounts, his attorneys’ emails, and 

through publication on the dedicated Service Webpage as set forth in this motion, deeming O’Neal 

served as of April 6, 2023, the date when Plaintiffs’ Counsel sent these materials directly to O’Neal 

(or alternatively, the date the Court enters an order authorizing service through these means, and,

to the extent necessary, granting an additional extension of time to effect service in this regard),

together with such other and further relief the Court deems just, equitable and proper.

13 See https://www.essentiallysports.com/nba-basketball-news-way-before-elon-musks-twitterblue-tick-fiasco-shaquille-oneal-made-history-on-1-billion-worth-social-media-platform/

(accessed April 7, 2023); see also https://theathletic.com/1234609/2019/09/24/shaquille-onealearly-adoption-twitter-changed-athlete-relations-forever/ (accessed April 7, 2023).

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Dated: April 7, 2023 Respectfully submitted,

By: /s/ Adam Moskowitz

Adam M. Moskowitz

Florida Bar No. 984280

adam@moskowitz-law.com 

Joseph M. Kaye

Florida Bar No. 117520

joseph@moskowitz-law.com

THE MOSKOWITZ LAW FIRM, PLLC

2 Alhambra Plaza, Suite 601

Coral Gables, FL 33134 

Telephone: (305) 740-1423

By: /s/ David Boies

David Boies

(Pro Hac Vice)

Alex Boies

(Pro Hac Vice)

BOIES SCHILLER FLEXNER LLP

333 Main Street

Armonk, NY 10504

Phone: (914) 749–8200

dboies@bsfllp.com

By: /s/ Stephen Neal Zack

Stephen Neal Zack

Florida Bar No. 145215

BOIES SCHILLER FLEXNER LLP

100 SE 2nd St., Suite 2800

Miami, FL 33131

Office: 305-539-8400

szack@bsfllp.com

Co-Counsel for Plaintiff and the Class

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the forgoing was filed on April 7, 2023, via 

the Court’s CM/ECF system, which will send notification of such filing to all attorneys of record. 

By: /s/ Adam M. Moskowitz______

ADAM M. MOSKOWITZ

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