EXHIBIT D 

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IN THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

LARRY HEARD a/k/a “Mr. Fingers” and )

ROBERT OWENS, )

)

Plaintiffs, )

)

v. )

) Case No. 20-cv-03678

TRAX RECORDS, INC., PRECISION/TRAX )

RECORDS, an entity unknown legal origins, )

RACHAEL SHERMAN nee RACHAEL CAIN ) Honorable Sharon J. Coleman

p/k/a SCREAMIN’ RACHAEL, doing business )

as SCREAMING RACHAEL CAIN MUSIC ) Magistrate Sunil R. Harjani

and TRAX RECORDS, and JOHN DOES 1-10, )

)

Defendants. )

__________________________________________)

TRAX RECORDS INC. and )

RACHAEL CAIN, )

)

Third-Party Plaintiffs, )

v. )

)

CASABLANCA TRAX INC., )

a Canadian Corporation )

CASABLANCA TRAX LIMITED )

PARTNERSHIP, a Canadian Limited Partnership, )

)

Third-Party Defendants. )

THIRD-PARTY PLAINTIFFS’ COMPLAINT AGAINST CASABLANCA

TRAX INC. FOR DECLARATORY JUDGMENT AND OTHER RELIEF

Third-Party Plaintiffs, Trax Records Inc., an Illinois corporation (“Trax Records” or 

“Trax”) and Rachael Cain (“Cain”; Cain together with Trax Records are referred to as “ThirdParty Plaintiffs”) for their complaint for declaratory judgment, breach of contract, and other 

relief against third-party defendants, Casablanca Trax Inc. and Casablanca Trax Limited 

Partnership (collectively, “Casablanca” or “Third-Party Defendant”) state as follows: 

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I. PARTIES AND JURISDICTION

1. Trax Records is an Illinois corporation with its principal place of business located 

in Cook County, Illinois. Trax Records owned the Trax Music Catalogue (defined below) at all 

relevant times as alleged herein. Larry Sherman (“Sherman”) was the founder of Trax in 1986. 

Sherman passed away in 2020. 

2. Rachael Cain is a resident and citizen of the State of Illinois.

3. Casablanca Trax Inc. is an Ontario, Canada corporation with its principal place of 

business located in Toronto Canada. 

4. Casablanca Trax Limited Partnership is an Ontario, Canada limited partnership, 

the general partner of Casablanca Trax Inc., and has its principal place of business in Toronto 

Canada.

5. The “Trax Music Catalogue” or “Trax Catalogue”, as referenced herein means the 

collection of musical works, musical compilations, licensing agreements, copyrights in various 

artist works, master recordings and other works, rights, and, among other things, property 

interests from numerous artists around the world. 

6. The Trax Catalogue is the subject of a written license agreement between 

Casablanca and Demon Music Group Limited dated October 2007 (“Demon License 

Agreement”). A redacted copy of the Demon License Agreement is attached hereto as Exhibit 

1. The artists whose music and other works are the subject of the Trax Music Catalogue are 

referred to as the “Trax Artists”. The Trax Artists include Cain, Larry Heard and Robert Owens. 

7. Demon Music Group Limited of the BBC (“Demon”) is a music catalogue 

marketing company that is owned by BBC Studios (the commercial arm of the British 

Broadcasting Corporation). It engages in (and has engaged in since 2007) the exploitation of the 

Master Recordings and other works by the Trax Artists including the works of Heard and Owens

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pursuant to the Demon License Agreement. On information and belief, Demon has exploited 

their works around the world, on the internet, on apps such as Spotify and Pandora, and, among 

other mediums, through the sale of actual vinyl recordings and CDs of the Trax Music 

Catalogue. 

8. Casablanca, on the one hand, and Cain, Larry Sherman and Trax Records, on the 

other, are parties to a certain Settlement Agreement and Assignment dated November 19, 2012 

(“Settlement Agreement”), pursuant to which Casablanca assigned to Cain and Sherman certain 

rights and interests in the Trax Music Catalogue including the Master Recordings. A redacted 

copy of the Settlement Agreement is attached hereto as Exhibit 2. 

9. Subject matter jurisdiction is proper pursuant to 28 U.S.C. § 1332 because the 

Third-Party Plaintiffs and the Third-Party Defendants are completely diverse and the amount in 

controversy exceeds the sum of $75,000 exclusive of interest and costs.

10. The Court has personal jurisdiction over Casablanca because it: (a) entered into 

written agreements with Cain, Sherman, and Trax Records that are substantially connected with 

Illinois, (b) acquired ownership, possession or control of an asset or thing of value that was 

present within the State of Illinois when ownership, possession or control was acquired, (c) 

transacted business within the State of Illinois, and (d) consented to jurisdiction in Cook County 

Illinois as part of the Settlement Agreement (Ex. 2 ¶ 8). 

11. Venue is proper in this Judicial District pursuant to 28 U.S.C. § 1391 because: (a) 

a substantial part of the events or omissions giving rise to the claim occurred in Cook County, 

Illinois, (b) each Defendant is subject to the Court’s personal jurisdiction in Cook County, 

Illinois, and (c) Casablanca consented to venue in this Judicial District as part of the Settlement 

Agreement (Ex. 2 ¶ 8). 

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II. BACKGROUND FACTS

12. Cain and Sherman are producers, artists and musicians who spent their lives 

creating and recording music generally known as “House Music”. 

13. Sherman, who passed away in April 2020, founded Trax Records in the mideighties. 

14. Trax Records is an iconic Chicago label that played a major role in the birth of 

House Music. In its infancy, Sherman was the driving force behind Trax Records. Throughout 

the eighties to early 2000, Sherman created and recorded a consortium of House Music and 

compiled a significant compilation of music, musical compositions, master recordings, 

copyrights and licenses to the artistic works of a significant number of artists including, Larry 

Heard and Robert Owens. 

CASABLANCA / TRAX JOINT VENTURE 2002

15. Other than recording some songs with Trax Records in the mid-eighties, Cain did 

not become involved with the management or operation of Trax Records or the Trax Music 

Catalogue until early 2000. Sherman and/or Trax Records owned the Trax Catalogue and had 

signed most of the Trax Artists before Cain’s involvement in any management of Trax Records. 

16. In December 2002, Trax Records, Sherman and Cain entered into a Joint Venture 

Agreement with Casablanca, which was amended in or around March 2004 (the Joint Venture 

Agreement together with its amendment are collectively referred to as the “JVA”), pursuant to 

which Casablanca acted as trustee for the joint venture to collect all revenues generated under the 

JVA, to provide Trax with accountings, and, among other things, to account and pay Trax Artists 

the revenue and royalties to which they were entitled as a result of the exploitation and 

distribution of their music and other works. Notwithstanding its role and obligations, Casablanca 

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did not pay royalties to the Trax Artists or provide Cain, Sherman, or Trax Records with required 

accountings. 

Casablanca / Trax 2005 Lawsuit

17. In 2005, Casablanca filed suit against Trax Records, Cain and Sherman for an 

alleged breach of the JVA. The Court awarded Casablanca judgment in its favor and against 

Cain, Sherman and Trax Records (the “2005 Judgment”).

18. In June 2006 and on the basis of the 2005 Judgment, Casablanca purchased for 

itself the Master Recordings and Trax Music Catalogue pursuant to a sale under the Illinois 

Uniform Commercial Code (“UCC”). 

The 2007 Demon License Agreement

19. In or around October 31, 2007, Casablanca and Demon entered into the Demon 

License Agreement, pursuant to which Casablanca licensed to Demon certain rights to the Trax 

Catalogue and the Master Recordings. (Ex. 1.) On information and belief, Demon paid 

Casablanca a significant advance under the Demon License Agreement (“Advance”). 

20. Cain, Sherman, and Trax Records did not receive any portion of the Advance that 

Demon paid to Casablanca. On information and belief, Casablanca did not pay any of the 

Advance to Heard or Owens. 

Trax Records Prevails on Appeal in 2008

21. Cain, Sherman and Trax Records appealed the trial court’s 2005 Judgment. After 

years of court battles and after Casablanca entered into the Demon License Agreement, the 

Illinois Appellate Court overturned the 2005 Judgment. 

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2012 Settlement Agreement and Assignment

22. After Cain, Sherman, and Trax Records overturned the 2005 Judgment, they filed 

another lawsuit in Illinois State Court against Casablanca to regain ownership of the Trax 

Catalogue. Litigation ensued. 

23. In or around November 19, 2012, the parties entered into the Settlement 

Agreement (attached hereto as Exhibit 2), pursuant to which Casablanca assigned certain 

interests of the Trax Music Catalogue and Master Recordings among other assets to Cain and 

Sherman. Casablanca did not assign to Third-Party Plaintiffs the Demon License, any obligation 

to pay royalties to Trax Artists, or any debts or obligations owed by Casablanca to any party 

including the Trax Artists such as Heard and Owens.

The Demon License Agreement

24. Since October 2007 and pursuant to the Demon License Agreement, Demon had 

the right to exploit certain aspects of the Trax Catalogue and Master Recordings. Paragraph 2 of 

the “General Terms and Conditions” of the Demon License Agreement identifies the license that 

Casablanca granted to Demon, which allowed Demon to, among other things, exploit: (a) the 

Masters and all recordings therefrom in all media, and, among other limited rights, (b) the right 

to use and publish the likeness of each artist whose work is embodied in the Masters. (Ex. 1, p. 9 

¶ 2 (emphasis added).) 

25. Casablanca was obligated to pay royalties to the Trax Artists for revenue 

generated under the Demon License Agreement at all times during the existence of the 

agreement but has failed to do so. (Ex. 1 ¶ 5, p. 3.) The term of the Demon License Agreement 

is stated as the greater of 10 years from November 1, 2007, or 3 years from the date Demon 

Music recouped the “Advances” to Casablanca from “Royalties” generated by the license (as 

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those terms are defined in the Demon License Agreement). (Ex. 1 ¶ 6 p. 3.) On information and 

belief, Demon has not recouped the Advance. And it will not recoup the Advance at the current 

pace until 2027. 

26. Neither Cain, Sherman, nor Trax is a signatory to the Demon License Agreement. 

It was not assigned to Cain, Sherman, or Trax as part of the Settlement Agreement. The 

obligation to pay royalties to Trax Artists including Heard and Owens for revenues generated 

under the Demon License Agreement was not assigned to Trax Records, Sherman or Cain. 

27. In addition and as part of the Settlement Agreement, Trax Records, Cain and 

Sherman refused to accept any obligation to pay any debts or obligations under the Demon 

License Agreement or otherwise from Casablanca; the obligation to pay Trax Artists such as 

Heard and Owens was at all times Casablanca’s obligation and remained so all times and 

remains with Casablanca to date. 

Demon and Casablanca’s Failure to Pay Royalties

28. Since 2002, Casablanca has been required to account for and pay royalties to the 

Trax Artists including Heard and Owens whose music and other works were exploited by 

Casablanca as part of the JVA from 2002 to 2007 and then by Demon Music under the Demon 

License Agreement from November 1, 2007 and continuing to date. Despite these obligations, 

Casablanca has not paid Heard and Owens all of the royalties they claim are due. 

29. As a result of the wrongful conduct of Casablanca, Third-Party Plaintiffs have 

been wrongfully and repeatedly accused of failing to pay royalties. The lawsuit filed by Heard 

and Owens is evidence of this very issue. Indeed, Cain is a Trax Artist who has not received the 

royalty payments from either Casablanca to which she is entitled. 

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30. Other Trax Artists who have not received royalty payments have resorted to the 

internet and social media to wrongfully blame Cain, Trax, and Sherman for Casablanca’s failure 

and refusal to pay royalties. Their postings have significantly harmed the reputation of the 

Third-Party Plaintiffs.

31. This lawsuit seeks to redress (a) Casablanca’s breach of the Settlement Agreement, 

(b) the inaccuracy of Casablanca’s position regarding the enforceability of the Demon License 

Agreement against Third-Party Plaintiffs, who are neither signatories to nor assignees of the 

Demon License Agreement; and (c) the contractual obligation of Casablanca – not Cain, Sherman 

or Trax – to pay royalties to Heard and Owens and to account for revenue generated thereby to all 

parties. 

COUNT I

DECLARATORY JUDGMENT, 28 U.S.C. § 2201

32. Plaintiffs reallege their allegations in the preceding paragraphs as their allegations 

to this paragraph. 

33. First, Casablanca contends that it has the right to enforce paragraph 12 of the 

Casablanca License Agreement to require the sale of the Trax Catalogue, Master Recordings and 

intellectual property rights therein to Demon for $150,000. (Ex. 1 ¶ 12.) Third-Party Plaintiffs 

disagree. 

34. Paragraph 12 of the Demon License provides in pertinent part:

For a period of ninety (90) days (“the Option Period”) following the expiry of the 

Term the Licensee shall have the exclusive option (but not the obligation) to 

purchase from Owner the full copyright and all other rights in the Masters in 

perpetuity throughout the World for One Hundred and Fifty Thousand U.S. dollars 

(US$150,000) . . .

(Ex. 1 ¶12.) 

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35. Casablanca does not have the right to enforce the terms of the Demon License 

Agreement against the Third-Party Plaintiffs (the assignees of the Trax Music Catalogue) because: 

(a) Casablanca assigned the Trax Catalogue and Master Recordings, among other assets, to Trax, 

Cain and Sherman as part of the Settlement Agreement; (b) the Demon License Agreement was 

not assigned to Third-Party Plaintiffs; (b) the Third-Party Plaintiffs are not parties or signatories 

to the Demon License Agreement; (c) the Demon License Agreement is unenforceable and/or 

terminable because of its indefinite Term of the license agreement; (d) the Trax Artists are not 

receiving royalties from either Demon or Casablanca; and, among other reasons, (e) the Settlement 

Agreement makes clear that Trax Records, Cain, and Sherman expressly refused to assume any of 

Casablanca’s debts or liabilities such as selling the Trax Catalogue or paying royalties to Trax

Artists. 

36. Accordingly, Third-Party Plaintiffs request a declaratory judgment from this Court 

that paragraph 12 of the Demon License Agreement is not enforceable against Third-Party 

Plaintiffs. 

37. Second, Casablanca contends that it is not obligated to pay royalties to artists such 

as Heard and Owens whose music and other works have been exploited by Demon under the 

Demon License Agreement. Casablanca contends it became the responsibility of Cain and 

Sherman to pay royalties to the Trax Artists upon execution of the Settlement Agreement such that 

Third-Party Plaintiffs are obligated to pay royalties beginning on November 19, 2012 and 

continuing until the expiration of the “Term” of the Demon License Agreement. Third-Party 

Plaintiffs disagree. 

38. The obligation to pay royalties to Trax Artists whose music was exploited as part 

of the Demon License Agreement remains with Casablanca. Third-Party Plaintiffs are not now, 

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and have never been, obligated to pay royalties to the Trax Artists including Heard and Owens 

under the Demon License Agreement because, among other reasons: (a) the Demon License 

Agreement was never assigned or transferred to Third-Party Plaintiffs, Cain, Sherman or Trax 

Records; (b) Third-Party Plaintiffs are not parties to, or third-party beneficiaries of, the Demon 

License Agreement; (c) Third-Party Plaintiffs did not receive any portion of the Advance; and (d) 

the Settlement Agreement makes clear that Trax Records, Cain, and Sherman expressly refused to 

assume any of Casablanca’s debts or liabilities such as paying royalties to artists. (Ex. 1 ¶ 3.) For 

these reasons, among others, the Third-Party Plaintiffs are not now, and never have been, obligated 

to perform any of the obligations of Casablanca or Demon under the Demon License Agreement. 

39. Accordingly, Third-Party Plaintiffs request a declaratory judgment from this Court 

that: (a) Third-Party Plaintiffs are not obligated to pay royalties to artists whose music was 

exploited pursuant to the Demon License Agreement; and (b) Casablanca and/or Demon are 

obligated to pay all royalties to the Trax Artists whose music has been exploited as part of the 

Demon License Agreement. 

40. Third, Casablanca claims the Demon License Agreement is an existing and 

enforceable license. Third-Party Plaintiffs disagree. Because of the indefinite term and lack of 

certainty, the Demon Licensing Agreement is unenforceable under Illinois law and terminable 

under English law. (Ex. 1 ¶ 6 p. 4; ¶ 2 p. 2.) Accordingly, Third-Party Plaintiffs request a 

declaration that the Demon License Agreement is unenforceable. 

41. The Declaratory Judgment statute, 28 U.S.C. § 2201, provides in part: 

In a case of actual controversy within its jurisdiction . . . any court of the United 

States . . . may declare the rights and other legal relations of any interested party 

seeking such declaration, whether or not further relief is or could be sought.

28 U.S.C. § 2201. 

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42. An actual controversy exists between Casablanca, on the one hand, and Third-Party 

Plaintiffs, on the other hand, concerning: (a) the right to enforce paragraph 12 of the Demon 

License Agreement against Third-Party Plaintiffs, (b) Casablanca’s obligation to pay royalties to 

Trax Artists that were generated as a result of the exploitation of the Demon License Agreement, 

and (c) the existence and enforceability of the Demon License Agreement.

43. There exists a concrete dispute admitting of an immediate and definitive 

determination of the parties’ rights, the resolution of which will aid in the termination of this 

controversy or some part thereof between the parties. 

44. A declaratory judgment is likely to prevent or redress the ongoing controversy 

between the parties.

45. The Third-Party Plaintiffs do not have an adequate remedy at law to redress their 

dispute with Casablanca. 

WHEREFORE, Third-Party Plaintiffs request that this Court: (A) enter a declaratory 

judgment that (1) paragraph 12 of the Demon License Agreement is not enforceable against ThirdParty Plaintiffs; (2) Third-Party Plaintiffs are not now, and never have been, obligated to pay 

royalties to artists whose music was exploited pursuant to the Demon License Agreement; (3) 

Casablanca and/or Demon are currently, and always have been, obligated to pay all royalties to the 

artists whose music has been exploited as part of the Demon License Agreement; and (4) the 

Demon License Agreement is not an existing or enforceable license agreement; and (B) enter any 

additional relief the Court deems just and proper.

COUNT II

BREACH OF THE SETTLEMENT AGREEMENT 

46. Third-Party Plaintiffs reallege their allegations in paragraphs 1-31 as their 

allegations to this paragraph. 

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47. The Settlement Agreement and Assignment (Exhibit 2 hereto) is a binding and 

enforceable contract. 

48. Casablanca materially breached the Settlement Agreement by failing to pay Trax 

Artists the royalties that they were allegedly due as a result of the Demon License Agreement. 

49. Casablanca’s breach has harmed Third-Party Plaintiffs because they have been 

forced to pay attorneys’ fees and costs to defend against the claims in this case by Heard and 

Owens, Cain has not received royalty payments to which she was entitled, and the reputation of 

the Third-Party Plaintiffs in the industry has been harmed as a result of Casablanca’s failure to pay 

royalties. 

WHEREFORE, Third-Party Plaintiffs request that the Court: (1) enter judgment in their 

favor and against Casablanca in an amount exceeding $75,000 exclusive of interest and costs, 

attorneys, costs and expenses; and (2) grant any additional relief the Court deems just.

COUNT III

AN ACTION FOR AN ACCOUNTING

50. Third-Party Plaintiffs reallege their allegations in paragraphs 1-31 as their 

allegations to this paragraph. 

51. Third-Party Plaintiffs are entitled to an accounting from Casablanca on behalf of 

each Trax Artist, including Cain, Heard and Owens because Third-Party Plaintiffs own or have 

specific rights in the music and each copyrighted work that Third-Party Defendant is and has been 

exploiting under the Demon License Agreement. 

52. In addition, the Third-Party Plaintiffs are entitled to an equitable accounting of the 

revenues generated by Third-Party Defendant to adjust the accounts concerning the royalties owed 

to the Trax Artists. The revenue and profits generated as a result of the JVA and the Demon 

License Agreement is a one-sided account held exclusively by Casablanca to the exclusion of the 

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Trax Artists that is of a complicated nature that requires relief, by way of discovery, for their 

settlement. What revenues are subject to royalty payments, the amount of the royalty payments 

that are owed, and to whom the royalties are payable are complicated issues and are voluminous 

in nature. 

53. In addition, the Trax Artists do not know, and would have no way of knowing, the 

various mediums Demon and Casablanca used to exploit the Trax Catalogue, or the amounts 

recovered as a result thereof. The Trax Artists must place (and have placed) a significant level of 

trust in licensees such as Casablanca to properly and accurately account for revenues and royalties, 

which trust further warrants an accounting and additional discovery.

54. Third-Party Plaintiffs do not have an adequate remedy at law to address Third-Party 

Defendant’s failure and refusal to account for the profits, losses, and royalty payments that were 

received pursuant to the Demon License Agreement.

55. To properly and sufficiently account for the royalties due and owing the Trax 

Artists and Third-Party Plaintiffs, they request appointment of a receiver in this case for the limited 

purpose of: (i) auditing the books and records of Casablanca from 2002 to date, (ii) providing the 

Court and Third-Party Plaintiffs with an accounting of revenues, expenses, profits, royalties due 

and owing and other financial information generated as a result of, or concerning, the Trax Music 

Catalogue, and (iii) collecting from Casablanca and/or Demon all royalty payments due and owing 

the Trax Artists and distributing all royalty payments to all Trax Artists. 

WHEREFORE, Third-Party Plaintiffs requests that the Court: (1) enter judgment in their 

favor and against Casablanca for an accounting; (2) appoint a receiver for the purpose of auditing 

the books and records of Casablanca concerning revenue generated by the Trax Music Catalogue, 

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and paying third parties entitled to royalties as a result thereof as noted above; and (3) grant any 

additional relief the Court deems just.

COUNT IV

UNJUST ENRICHMENT

56. Third-Party Plaintiffs reallege their allegations in paragraphs 1 -31 as their 

allegations to this paragraph. 

57. Neither Third-Party Plaintiffs nor the Trax Artists is a signatory to the Demon 

License Agreement. 

58. Casablanca and Demon have exploited the Trax Music Catalogue pursuant to the 

Demon License Agreement since 2007, collected revenues generated thereby, but failed to pay all 

alleged royalties due and owing to the Trax Artists whose music is subject to the Demon License 

Agreement. 

59. Casablanca has unjustly retained revenue and royalties due and owing to the Trax 

Artists including Heard and Owens to the detriment of Third-Party Plaintiffs and the Trax Artists. 

60. The retention of the revenue and royalties by Casablanca violates the fundamental 

principles of justice, equity, and good conscience. 

61. Third-Party Plaintiffs do not have an adequate remedy at law to compensate them 

or the Trax Artists for the Third-Party Defendant’s wrongful conduct. 

WHEREFORE, the Third-Party Plaintiffs request that the Court: (1) enter judgment in 

their favor and against Third-Party Defendants in amount to be determined at trial but in no event 

less than $75,0000, plus costs, and attorneys’ fees as an element of damages; (2) order an audit 

and accounting of the books and records of Casablanca of all revenue generated as a result of their 

exploitation of the Trax Music Catalogue and Demon License Agreement; and (3) grant any 

additional relief the Court deems just and proper.

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COUNT V

INJUNCTIVE RELIEF

62. Third-Party Plaintiffs reallege their allegations in paragraphs 1-31 as their 

allegations to this paragraph. 

63. Third-Party Plaintiffs are entitled to an injunction ordering Third-Party Defendant 

to cease all licensing of the Trax Music Catalogue and Master Recordings under the Demon 

License Agreement. 

64. Plaintiffs have a clearly ascertainable right in need of protection because they own 

the Trax Music Catalogue and all rights and interests therein, the Third-Party Plaintiffs have the 

right to license the Trax Catalogue free from unlawful interference from Third-Party Defendant in 

the form of their failure and refusal to pay Trax Artists royalties. 

65. Third-Party Plaintiffs do not have an adequate remedy at law because no monetary 

award can provide them with a complete, clear, practical and efficient remedy to stop the continued 

and unauthorized exploitation of the Trax Catalogue by Demon and Casablanca and their refusal 

and failure to pay royalties to Trax Artists. 

66. Third-Party Plaintiffs have a likelihood of success on the merits of their claims.

67. The balance of harms favors Third-Party Plaintiffs and the Trax Artists because 

they are suffering immeasurable harm as a result of the wrongful conduct by the Third-Party 

Defendant. 

WHEREFORE, Plaintiff respectfully prays that the Court grant the following relief: (1) 

A temporary, preliminary and permanent injunction prohibiting Third-Party Defendant, its 

agents, servants, employees and/or all persons acting in concert or participation with them, or 

any of them, from continuing to use the Demon License Agreement for any purpose; (2) an 

order compelling Third-Party Defendant to account for all revenue, losses, profits and royalties 

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generated by the exploitation of the Trax Music Catalogue; and (3) All other relief to which 

Third-Party Plaintiffs are entitled. 

DATED: July 21, 2021

TRAX RECORDS INC. AND RACHAEL CAIN

BY:

___________________________________

One of their Attorneys

Richard P. Darke

Duane Morris LLP

190 S. LaSalle Street, Suite 3700

Chicago, IL 60601

(312) 499-6700

rpdarke@duanemorris.com

rciambrone@duanemorris.com

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