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IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

 

Douglas Pennoyer, Jr. : 

 : 

 vs. : CIVIL ACTION NO. 03-5060 

 : 

Marriott Hotel Services, Inc. t/a and d/b/a Philadelphia Marriott : 

Hotel; Marriott International, Inc.; Philadelphia Market Street : 

Hotel Corp.; Philadelphia Market Street HMC Hotel Limited : 

Partnership; Philadelphia Market Street Marriott Hotel LP; New : 

Market Street, LP; HMC Market Street, LLC; Philadelphia Market : 

Street Hotel II, L.P.; Market Street Host, LLC; and Market Street : 

Marriott, LLC : 

 

DEFENDANTS' ANSWER TO PLAINTIFF'S COMPLAINT 

 Defendants, Marriott Hotel Services, Philadelphia Marriott Hotel, Marriott International, Inc., 

Philadelphia Market Street Hotel, Corp., Philadelphia Market Street HMC Hotel Limited Partnership, 

Philadelphia Market Street Marriott Hotel LP, New Market Street, LP, HMC Market Street, LLC, Philadelphia 

Market Street Hotel II, LP, Market Street Host, LLC and Market Street Marriott (hereinafter "Marriott 

Defendants"), by their attorneys, Marshall, Dennehey, Warner, Coleman & Goggin, answer plaintiff's 

Complaint as follows: 

 1. Admitted to the best of answering defendants' knowledge. 

 2. Admitted in part, denied in part. It is admitted only that Marriott Hotel Services, Inc. is a 

corporation and that it manages the Philadelphia Marriott. It is denied that Marriott Hotel Services, Inc. is a 

corporation duly organized and registered in the Commonwealth of Pennsylvania. 

 3. Denied as stated. It is denied that Marriott International, Inc. is a corporation duly organized and 

registered in the Commonwealth of Pennsylvania. It is further denied that Marriott International, Inc. has its 

principle place of business in the City of Philadelphia at 1201 Market Street. It is admitted, however, that 

Marriott International, Inc. regularly conducts business in the city of Philadelphia, Pennsylvania. It is also 

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admitted that Marriott International, Inc. manages the hotel in question. The remaining allegations of this 

paragraph are specifically denied and strict proof is demanded thereof. 

 4. Denied as stated. It is denied that Philadelphia Market Street Hotel Corporation is a corporation 

duly organized and registered in the Commonwealth of Pennsylvania. It is also denied that Philadelphia Market 

Street Hotel Corporation maintains, manages or controls the Philadelphia Marriott Hotel or the Philadelphia 

Downtown Marriott. While the Philadelphia Market Street Hotel Corporation does own a percentage of the 

Philadelphia Market Street HMC Hotel Limited Partnership, it is not responsible for the day to day operations 

or management of the Philadelphia Marriott. 

 5. Admitted in part, denied in part. It is denied that Philadelphia Market Street HMC Hotel Limited 

Partnership is a corporation duly organized and registered in the Commonwealth of Pennsylvania. It is admitted 

only that Philadelphia Market Street HMC Hotel Limited Partnership is the owner of the Philadelphia Marriott 

Hotel. The remaining allegations of this paragraph are specifically denied and strict proof is demanded thereof. 

 6. It is denied that Philadelphia Market Street Marriott Hotel Limited Partnership is a corporation 

duly organized and registered in the Commonwealth of Pennsylvania. It is further denied that this entity is the 

current owner of the Philadelphia Marriott. The remaining allegations of this paragraph are specifically denied 

and strict proof is demanded thereof. 

 7. Denied as stated. It is denied that New Market Street Limited Partnership is a corporation duly 

organized and registered in the Commonwealth of Pennsylvania. It is further denied that New Market Street 

Limited Partnership has its principle place of business in the City of Philadelphia at 1201 Market Street. It is 

admitted only that New Market Street Limited Partnership has an ownership interest in the LLC. The remaining 

allegations of this paragraph are specifically denied and strict proof is demanded thereof. 

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 8. Denied as stated. It is denied that HMC Market Street LLC is a corporation duly organized and 

registered in the Commonwealth of Pennsylvania. The remaining allegations of this paragraph are specifically 

denied and strict proof is demanded thereof. 

 9. Denied. It is denied that Philadelphia Market Street Hotel II Limited Partnership is a corporation 

duly organized and registered in the Commonwealth of Pennsylvania. It is further denied that Philadelphia 

Market Street Hotel II Limited Partnership has its principle place of business in the City of Philadelphia at 1201 

Market Street. Philadelphia Market Street Hotel II Limited Partnership did not exist as a business entity at any 

time relevant to plaintiff's Complaint. The remaining allegations of this paragraph are specifically denied and 

strict proof is demanded thereof. 

 10. It is denied that Market Street Host LLC is a corporation duly organized and registered in the 

Commonwealth of Pennsylvania. It is further denied that Market Street Host LLC has its principle place of 

business in the City of Philadelphia at 1201 Market Street at any time relevant to plaintiff's Complaint. 

 11. It is denied that Market Street Marriott, LLC is a corporation duly organized and registered in the 

Commonwealth of Pennsylvania. It is further denied that Market Street Marriott, LLC has its principle place of 

business in the City of Philadelphia at 1201 Market Street at any time relevant to plaintiff's Complaint. 

 12. Denied. It is specifically denied that the Philadelphia Marriott Hotel was owned, operated, 

possessed, controlled, maintained and managed, jointly and severally, by all Marriott defendants. Further, 

"Philadelphia Marriott Hotel" is a fictitious name used on occasion by the Hotel at 12th and Market Streets in 

Philadelphia, Pennsylvania. The remaining allegations of this paragraph are specifically denied and strict proof 

is demanded thereof. 

 13. Denied. The allegations of this paragraph are specifically denied and strict proof is demanded 

thereof. Further, this paragraph contains conclusions of law to which no response is required. 

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 14. Denied. The allegations of this paragraph are specifically denied and strict proof is demanded 

thereof. Further, this paragraph contains conclusions of law to which no response is required. 

 15. Denied as stated. It is specifically denied that the Marriott defendants permitted the American 

Guild of Organists to use the entire hotel and convention premises at the Philadelphia Marriott for the national 

convention from and after July 1, 2002. By way of further answer, Marriott defendants entered into an 

agreement with the American Guild of Organists, whereby the American Guild of Organists was permitted to 

use limited areas of the premises for their national convention, from July 2, 2000 to July 5, 2002, and for set-up 

and take-down on July 1, 2002 and July 6, 2002, respectively. 

 16. Admitted. 

 17. Denied. It is specifically denied that Marriott defendants, at any time relevant to plaintiff's 

Complaint, permitted unrestricted access to individuals to circulate about the registration, hospitality, meeting 

and exhibition areas of the convention. By way of further answer, at the time of the events giving rise to 

plaintiff's Complaint, access to the convention area was restricted and was closed to the public. In fact, the 

convention was not scheduled to open until the following day, July 2, 2002. 

 18. Denied. It is specifically denied that the convention was open to the public at any time relevant 

to plaintiff's Complaint. By way of further answer, at the time of the events giving rise to plaintiff's Complaint, 

access to the convention area was restricted and was closed to the public. In fact, the convention was not 

scheduled to open until the following day, July 2, 2002. 

 19. Denied at stated. It is specifically denied that plaintiff Douglass Pennoyer, Jr. was permitted to 

enter the area at issue in this litigation at any time relevant to plaintiff's Complaint. Additionally, this paragraph 

contains conclusions of law and no response is required. 

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 20. After reasonable investigation, Marriott defendants are without knowledge or information 

sufficient to form a belief as to the truth of the averments contained in paragraph 20 of plaintiff's Complaint and 

therefore, can neither admit nor deny the same. 

 21. After reasonable investigation, Marriott defendants are without knowledge or information 

sufficient to form a belief as to the truth of whether plaintiff purchased a Convention Program on or about July 

1, 2002 and therefore, can neither admit nor deny the same. 

Further, with respect to the remaining allegations of paragraph 21, it is specifically denied that, on or about July 

1, 2002, the exhibition area was open and that plaintiff was welcome to enter and visit the various exhibitors' 

booths. In fact, the convention was not scheduled to open until the following day, July 2, 2002. 

 22. Denied. It is specifically denied that the access to the exhibition area was unrestricted at the time 

of the events that give rise to plaintiff's Complaint. By way of further answer, the exhibition area was closed to 

the public at the time of the events that give rise to plaintiff's Complaint, and the exhibition was not scheduled 

to begin until the following day, July 2, 2002. 

 23. Denied. It is specifically denied that, at any time relevant to plaintiff's Complaint, exhibitors and 

members of the public were present in the exhibition area. By way of further answer, at the time of the events 

giving rise to plaintiff's Complaint, access to the convention area was restricted and was closed to the public. 

The convention was not scheduled to open until the following day, July 2, 2002. 

 24. Denied. It is specifically denied that plaintiff Douglass Pennoyer, Jr. was permitted to enter the 

area at issue in this litigation at any time relevant to plaintiff's Complaint. 

Additionally, it is denied that plaintiff was given complimentary materials or purchased books and CDs from 

the exhibitors in the convention center area on July 1, 2002. In fact, as previously stated, the convention was 

not open to the public at that time. 

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 25. Denied. It is specifically denied that plaintiff was lawfully and permissibly in the convention 

area at the Philadelphia Marriott at the time of the events that give rise to plaintiff's Complaint. It is further 

denied that plaintiff had any documentation or information to provide to Marriott security which would have 

established that plaintiff was in lawful custody of the materials in plaintiff's possession at the time he was 

questioned by Marriott security. In fact, plaintiff was provided with every opportunity to produce a witness or 

documentation to establish that he had purchased the materials at issue. Plaintiff produced nothing. 

Additionally, it is denied that plaintiff was unlawfully detained by Marriott defendants' security persons at any 

time relevant to plaintiff's Complaint. By way of further answer, Marriott's decision to approach plaintiff and 

question him was reasonable and necessary under the circumstances. 

 26. Admitted. 

 27. Admitted. 

 28. Admitted. 

 29. Denied. It is specifically denied that Marriott defendants, at any time relevant to plaintiff's 

Complaint, falsely, recklessly, maliciously and/or intentionally accused plaintiff of theft and trespass. By way 

of further answer, Marriott's decision to approach plaintiff and question him was reasonable and necessary 

under the circumstances. 

 30. Denied. It is specifically denied that, at any time relevant to plaintiff's Complaint, Marriott 

defendants' above-named security personnel forcibly and unlawfully detained and restrained plaintiff. By way 

of further answer, Marriott's actions concerning the events at issue in this matter were reasonable and necessary 

under the circumstances. 

 31. Denied. It is specifically denied that Marriott defendants in any way threatened plaintiff with 

force or did anything which could have placed plaintiff in reasonable apprehension of force or fear of the same 

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at any time relevant to plaintiff's Complaint. It is also denied that plaintiff was, at any time relevant to this 

matter, deprived of his liberty or forced to remain on defendants' premises against his will by defendants. 

 32. Denied. It is specifically denied that, at any time relevant to plaintiff's Complaint, Marriott 

defendants' personnel acted intentionally or confined plaintiff within boundaries fixed by them. 

 33. Denied. It is specifically denied that defendants confined plaintiff at any time relevant to this 

matter. The remaining allegations of this paragraph are denied and strict proof is demanded thereof. To the 

extent that this paragraph contains conclusions of law, no response is required. 

 34. Denied. It is specifically denied that plaintiff was in any way confined by Marriott defendants at 

the time of the events that give rise to plaintiff's Complaint. To the extent that the allegations in this paragraph 

contain conclusions of law, no response is required. 

 35. Denied. It is specifically denied that plaintiff was in any way confined by Marriott defendants at 

the time of the events that give rise to plaintiff's Complaint. To the extent that this paragraph contains 

conclusions of law, no response is required. 

 36. Denied. It is specifically denied that Marriott defendants, at any time relevant to plaintiff's 

Complaint, acted without probable cause or reasonable foundation. In fact, Marriott's actions concerning the 

events at issue in this matter were reasonable and necessary under the circumstances. 

 37. Denied. This paragraph contains conclusions of law to which no response is required. 

 38. Denied. It is specifically denied that Marriott defendants refused to listen and/or permit plaintiff 

to explain the lawfulness of the materials in his possession. To the contrary, Marriott defendants asked plaintiff 

to explain how he came to possess the materials, and the plaintiff provided inconsistent explanations for his 

possession of the materials, could not produce any documentation to establish that the materials were lawfully 

in his possession and did not identify a single person who could support his statements. 

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 39. Denied. It is specifically denied that Marriott defendants' personnel did not act to determine the 

bona fide nature of plaintiff's possession. To the contrary, Marriott defendants asked plaintiff to explain how he 

came to possess the materials, and the plaintiff provided inconsistent explanations for his possession of the 

materials, could not produce any documentation to establish that the materials were lawfully in his possession 

and did not identify a single person who could support his statements. 

 40. Denied. This paragraph contains conclusions of law to which no response is required. By way 

of further answer and without waiver of these objections, it is specifically denied that Marriott defendants, at 

any time relevant to plaintiff's Complaint, acted unlawfully, recklessly, maliciously or intentionally. It is further 

denied that Marriott defendants made any false accusations with respect to the plaintiff. Additionally, it is 

specifically denied that Marriott defendants unlawfully imprisoned plaintiff at any time relevant to the 

Complaint. The remaining allegations of this paragraph are specifically denied at strict proof is demanded 

thereof. 

 41. Denied as stated. It is specifically denied that Marriott defendants, at any time relevant to 

plaintiff's Complaint, acted unlawfully, recklessly, maliciously or intentionally. It is further denied that the 

Marriott defendants arrested plaintiff and charged him with crimes. By way of further answer, Marriott did not 

arrest plaintiff nor did it have the authority or power to do so. While Marriott security did contact the 

Philadelphia Police when plaintiff failed to provide anything to establish his ownership of the convention 

materials, the Philadelphia Police opted to arrest plaintiff based upon their investigation. 

 42. Denied. It is specifically denied that Marriott defendants, at any time relevant to plaintiff's 

Complaint, acted unlawfully, recklessly, maliciously or intentionally. In fact, Marriott security's actions 

concerning the events at issue were reasonable and necessary under the circumstances. It is also denied that the 

Marriott defendants placed plaintiff in jail. In fact, Marriott security did not have the authority or power to 

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arrest plaintiff, charge him with crimes or place him in jail. The remaining allegations of this paragraph are 

specifically denied and strict proof is demanded thereof. 

 43. After reasonable investigation, Marriott defendants are without knowledge or information 

sufficient to form a belief as to the truth of the averments contained in paragraph 43 and therefore, can neither 

admit nor deny the same. 

 44. Denied as stated. This paragraph contains conclusions of law to which no response is required. 

By way of further answer without waiver of this objection, it is specifically denied that Marriott defendants, at 

any time relevant to plaintiff's Complaint, acted unlawfully, recklessly, maliciously or intentionally. It is further 

denied that Marriott defendants acted without probable cause at any time relevant to plaintiff's Complaint. 

Additionally, it is denied that Marriott defendants made any false and/or defamatory communications, or that 

Marriott defendants made any false statements in its communications at any time relevant to plaintiff's 

Complaint. The remaining allegations are specifically denied, and strict proof is demanded thereof. 

 45. Denied. It is specifically denied that Marriott defendants acted with malice at any time relevant 

to plaintiff's Complaint. It is further denied that Marriott defendants made any false, malicious, scandalous 

and/or defamatory communications at any time relevant to plaintiff's Complaint. Additionally, it is denied that 

Marriott defendants made any false statements in its communications. The remaining allegations are 

specifically denied, and strict proof is demanded thereof. To the extent that this paragraph contains conclusions 

of law, no response is required. 

 46. Denied. It is specifically denied that Marriott defendants made any false and/or defamatory 

communications at any time relevant to plaintiff's Complaint. Additionally, it is denied that Marriott defendants 

made any false statements in its communications to the plaintiff or the Philadelphia Police. The remaining 

allegations are specifically denied, and strict proof is demanded thereof. 

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 47. Denied. It is specifically denied that Marriott defendants made any false and/or defamatory 

communications at any time relevant to plaintiff's Complaint. Additionally, it is denied that Marriott defendants 

made any false statements in its communications to the plaintiff or the Philadelphia Police. The remaining 

allegations are specifically denied, and strict proof is demanded thereof. 

 48. Denied. It is specifically denied that Marriott defendants made any false and/or defamatory 

communications at any time relevant to plaintiff's Complaint. Additionally, it is denied that Marriott defendants 

made any false statements in its communications to the plaintiff or the Philadelphia Police. By way of further 

answer, the convention was not open to the public at any time relevant to plaintiff's Complaint. The convention 

was not scheduled to open until the following day, July 2, 2002, and thus conventioneers were not present in the 

exhibit area, as plaintiff suggests. The remaining allegations are specifically denied, and strict proof is 

demanded thereof. 

 49. Denied as stated. It is specifically denied that Marriott defendants, at any time relevant to 

plaintiff's Complaint, acted unlawfully, recklessly, maliciously or intentionally. It is also denied that defendants 

charged plaintiff with any crime. Marriott security did not have the authority or power to arrest plaintiff, charge 

him with a crime or place him in jail. It is admitted only that the Philadelphia Police opted to drop the charges 

they brought against plaintiff. Defendants do not have knowledge or information sufficient to form a belief as 

to whether plaintiff was guilty or not guilty of a crime. To the extent this paragraph contains conclusions of 

law, no response is required. 

 50. Denied as stated. It is denied that defendants were in a position of authority as plaintiff 

describes. Marriott defendants did not have the authority or power to arrest plaintiff, charge him with a crime 

or place him in jail. Marriott security only has the authority to secure its own premises. The remaining 

allegations of this paragraph are specifically denied and strict proof is demanded thereof. 

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 51. Denied. It is specifically denied that the questions raised by Marriott defendants were known to 

be, or should have been known to be, false and untrue. In fact, Marriott security's actions concerning the events 

at issue in this matter were reasonable and necessary under the circumstances. The remaining allegations of this 

paragraph and specifically denied and strict proof is demanded thereof. 

 52. Denied that defendants' actions, at any time relevant, were negligent, reckless, careless or 

malicious. It is also denied that the defendants acted intentionally or with reckless disregard. In fact, 

defendants' actions concerning the events at issue in this matter were reasonable and necessary under the 

circumstances. To the extent this paragraph contains conclusions of law, no response is required. The 

remaining allegations of this paragraph and specifically denied and strict proof is demanded thereof. 

 53. Denied. It is specifically denied that Marriott defendants, at any time relevant to plaintiff's 

Complaint, acted in an extreme or outrageous manner. The remaining allegations of this paragraph and 

specifically denied and strict proof is demanded thereof. To the extent that the allegations in this paragraph 

contain conclusions of law, no response is required. 

COUNT I - DEFAMATION 

PLAINTIFF vs. ALL DEFENDANTS

 54. Marriott defendants incorporate by reference paragraphs 1 through 53 as though fully set forth 

herein. 

 55. Denied. It is specifically denied that Marriott defendants, at any time relevant to plaintiff's 

Complaint, acted negligently, recklessly, maliciously or intentionally. It is further denied that plaintiff's 

reputation was blackened as a result of any acts or omissions of Marriott defendants. To the extent this 

paragraph contains conclusions of law, no response is required. 

 56. Denied as stated. This paragraph contains conclusions of law to which no response is required. 

By way of further answer and without waiver of these objections, it is specifically denied that Marriott 

defendants, at any time relevant to plaintiff's Complaint, acted negligently, recklessly, maliciously or 

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intentionally. Further, it is denied that Marriott defendants made any false and/or defamatory statements or 

communications at any time relevant to plaintiff's Complaint. Additionally, it is denied that Marriott defendants 

made any false statements in its communications to the plaintiff or to the Philadelphia Police. The remaining 

allegations are specifically denied, and strict proof is demanded thereof. 

 57. Denied. It is specifically denied that Marriott defendants, at any time relevant to plaintiff's 

Complaint, acted negligently, recklessly, maliciously or intentionally. Further, it is denied that Marriott 

defendants, at any time relevant to plaintiff's Complaint, made any false statements regarding the plaintiff. In 

fact, Marriott's actions as they pertain to this matter were reasonable and necessary under the circumstances. 

The remaining allegations are specifically denied, and strict proof is demanded thereof. 

 58. Denied. It is specifically denied that Marriott defendants, at any time relevant to plaintiff's 

Complaint, made any false and/or defamatory statements regarding the plaintiff. The remaining allegations are 

specifically denied, and strict proof is demanded thereof. To the extent this paragraph contains conclusions of 

law, no response is required. 

 WHEREFORE, answering defendant demands judgment in its factor and against plaintiff. 

COUNT II - FALSE IMPRISONMENT 

PLAINTIFF vs. ALL DEFENDANTS

 59. Marriott defendants incorporate by reference paragraphs 1 through 58 as though fully set forth 

herein. 

 60. Denied. It is specifically denied that Marriott defendants, at any time relevant to plaintiff's 

Complaint, acted negligently, recklessly, maliciously or intentionally. It is further denied that plaintiff was 

confined against his will and within boundaries fixed by Marriott defendants. To the extent this paragraph 

contains conclusions of law, no response is required. 

 61. Denied. This paragraph contains conclusions of law to which no response is required. By way 

of further answer and without waiver of this objection, it is denied that plaintiff was ever confined by 

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defendants. The remaining allegations of this paragraph are specifically denied and strict proof is demanded 

thereof. 

 62. Denied as stated. It is specifically denied that plaintiff was in any way confined by Marriott 

defendants at the time of the events that give rise to plaintiff's Complaint. The remaining allegations are 

specifically denied, and strict proof is demanded thereof. To the extent this paragraph contains conclusions of 

law, no response is required. 

 63. Denied. It is specifically denied that plaintiff was in any way confined by Marriott defendants at 

the time of the events that give rise to plaintiff's Complaint. It is further denied that Marriott defendants, in any 

way, engaged in the acts of physical force, duress and/or coercion at any time relevant to plaintiff's Complaint. 

To the extent this paragraph contains conclusions of law, no response is required. 

 64. Denied as stated. This paragraph contains conclusions of law to which no response is required. 

By way of further answer and without waiver of this objection, it is specifically denied that Marriott defendants, 

at any time relevant to plaintiff's Complaint, acted without probable cause or reasonable foundation. By way of 

further answer, Marriott defendants' actions, at all times relevant to the events at issue, were reasonable and 

necessary under the circumstances. 

 65. Denied as stated. It is specifically denied that Marriott defendants, at any time relevant to 

plaintiff's Complaint, acted negligently, recklessly, maliciously or intentionally. It is also denied that plaintiff's 

arrest resulted from anything but plaintiff's own actions. While Marriott security did contact the Philadelphia 

Police when plaintiff failed to provide anything to establish his ownership of convention materials or his right to 

be in the convention area one day before the convention opened to the public, the Philadelphia Police opted to 

arrest plaintiff based upon their investigation. In fact, Marriott security did not have the authority to arrest 

plaintiff, charge him with crimes or place him in jail. 

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 66. Denied. This paragraph contains conclusions of law to which no response is required. By way 

of further answer and without waiver of this objection, the remaining allegations of this paragraph are 

specifically denied and strict proof is demanded thereof. 

 WHEREFORE, answering defendant demands judgment in its favor and against plaintiff. 

NEW MATTER DIRECTED TO PLAINTIFF

1. Plaintiff's Amended Complaint fails to state a cause of action upon which relief may be granted 

against the Marriott defendants. 

2. Plaintiff's Complaint fails to set forth a valid claim of defamation against the Marriott 

defendants. 

3. Plaintiff's Complaint fails to set forth a valid claim of false imprisonment against the Marriott 

defendants. 

4. Plaintiff's claims are barred or limited by the applicable statute of limitations. 

5. To the extent that plaintiff's Complaint sets forth allegations of negligence, plaintiff's claims are 

barred or limited by the terms and conditions of the Pennsylvania Comparative Negligence Act. 

6. At no time did the Marriott defendants breach any duty owed to plaintiff. 

7. Any communications of the Marriott defendants enjoyed a qualified privilege. 

WHEREFORE, answering defendant demands judgment in its favor and against plaintiff. 

 MARSHALL, DENNEHEY, WARNER, 

 COLEMAN & GOGGIN 

 

 BY:______________________________________ 

 STEPHANIE K. RAWITT 

 Attorney for Marriott Defendants 

 

Dated:________________________ 

\01_19\LIAB\SJS\LLPG\390229\SJS\13050\00612 

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CERTIFICATE OF SERVICE

 I, Stephanie K. Rawitt, Esquire, do hereby certify that a true and correct copy of Defendants' 

Answer to Plaintiff's Complaint was served upon plaintiff's counsel by first class mail at the 

following address: 

Peter C. Gardner, Esquire 

525 Baird Road 

Merion Station, PA 19066 

 

 STEPHANIE K. RAWITT 

DATED: 

\01_19\LIAB\SJS\LLPG\390229\SJS\13050\00612 

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