Download - Enrique Graf counterclaim
UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA
CHARLESTON DIVISION John Doe, )
)C/A No. 2:14-cv-01749-PMD
Plaintiff, ))
Versus ))
College of Charleston; Enrique Graf, individually and in his official capacity as former Music Professor and University Artist in Residence at the College of Charleston; P. George Benson, individually and in his official capacity as President of the College of Charleston; and Steve Rosenberg, individually and in his official capacity as former Dean of the Department of Music at the College of Charleston,
))))))))))
)Defendants. )
DEFENDANT ENRIQUE GRAF’S ANSWER TO PLAINTIFF’S COMPLAINT AND COUNTERCLAIMS AGAINST THE
PLAINTIFF (Jury Trial Requested)
Comes now, the Defendant, Enrique Graf, individually and in his official capacity as
former Music Professor and University Artist in Residence at the College of Charleston
(hereinafter “this Defendant”), answering the allegations of the Plaintiff’s Complaint, subject to
all applicable motions, affirmative defenses, and other pleadings, as follows:
1. Each and every allegation not specifically admitted in this Answer is denied.
AS TO JURISDICTION
2. This Defendant is without knowledge or information at this time to form a belief
as to the truth of the allegations contained in Paragraph 1 of the Plaintiff’s Complaint and
therefore, those allegations are denied.
3. In response to the allegations contained in Paragraph 2 of the Plaintiff’s
Complaint, this Defendant admits the College of Charleston is designated as one of the
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universities and colleges of the State of South Carolina and is located in Charleston, South
Carolina.
4. This Defendant admits the allegations contained in Paragraph 3 of the Plaintiff’s
Complaint.
5. The allegations contained in Paragraphs 4, 5, 6 and 7 of the Plaintiff’s Complaint
are not directed toward this Defendant and no response is required. To the extent a response is
required, this Defendant is without knowledge or information sufficient to form a belief as to the
truth of the allegations contained in Paragraphs 4, 5, 6 and 7 of the Plaintiff’s Complaint at this
time and therefore, those allegations are denied.
6. The allegations contained in Paragraphs 8 and 9 of the Plaintiff’s Complaint state
conclusions of law to which no response is required.
AS TO FACTUAL BACKGROUND
7. In response to the allegations contained in Paragraph 10 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
8. In response to the allegations contained in Paragraphs 11 and 12 of the Plaintiff’s
Complaint, this Defendant admits only that the Plaintiff was previously enrolled as a student at
the College of Charleston and this Defendant was employed as a Professor of Music and
University Artist in Residence at the College of Charleston. All remaining and inconsistent
allegations contained in Paragraphs 11 and 12 of the Plaintiff’s Complaint are denied.
9. The allegations contained in Paragraph 13 of the Plaintiff’s Complaint state
conclusions of law to which no response is required.
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10. The allegations contained in Paragraphs 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24,
25, 26, 27, 28, 29, 30, 31, 32, 33 and 34 of the Plaintiff’s Complaint contain allegations of the
Plaintiff’s personal history and relationship with this Defendant. Unless otherwise admitted
herein, this Defendant denies the allegations contained in Paragraphs 14, 15, 16, 17, 18, 19, 20,
21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33 and 34 of the Plaintiff’s Complaint.
11. The allegations contained in Paragraphs 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45,
46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71,
72, 73, 74, 75, 76, 77, 78, 79 and 80 of the Plaintiff’s Complaint contain statements of alleged
“inappropriate sexual advances” as to this Defendant. Unless otherwise admitted herein, this
Defendant denies the allegations contained in Paragraphs 35, 36, 37, 38, 39, 40, 41, 42, 43, 44,
45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70,
71, 72, 73, 74, 75, 76, 77, 78, 79 and 80 of the Plaintiff’s Complaint.
12. This Defendant denies the allegations contained in Paragraphs 81, 82, 83 and 84
of the Plaintiff’s Complaint.
13. The allegations contained in Paragraphs 85, 86, 87, 88, 89, 90, 91 and 92 of the
Plaintiff’s Complaint contain allegations of prior lawsuits or complaints and allegations not
directed to this Defendant to which no response is required. To the extent a response is required,
this Defendant denies the allegations contained in Paragraphs 85, 86, 87, 88, 89, 90, 91 and 92 of
the Plaintiff’s Complaint.
14. This Defendant denies the allegations contained in Paragraphs 93, 94, 95, 96, 97
and 98 of the Plaintiff’s Complaint.
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15. The allegations contained in Paragraph 99 of the Plaintiff’s Complaint are not
directed toward this Defendant and no response is required. To the extent a response is required,
this Defendant denies the allegations contained in Paragraph 99 of the Plaintiff’s Complaint.
16. This Defendant denies the allegations contained in Paragraph 100 (including
subparts 1., 2., 3., 4., 5., 6., 7., 8., 9., 10., 11., 12., 13., 14., 15., 16., 17., 18. and 19.) of the
Plaintiff’s Complaint.
AS TO THE FIRST CAUSE OF ACTION (Violation of Title IX, 20 USC § 1681(a), as to College Defendants)
17. In response to the allegations contained in Paragraph 101 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
18. The allegations contained in Paragraphs 102, 103 and 104 of the Plaintiff’s
Complaint are not directed toward this Defendant and no response is required. To the extent a
response is required, this Defendant admits only the Plaintiff was previously enrolled as a
student at the College of Charleston. This Defendant is without knowledge or information
sufficient at this time to form a belief as to the truth of the remaining allegations contained in
Paragraphs 102, 103 and 104 of the Plaintiff’s Complaint and therefore, denies the those
allegations.
19. This Defendant denies the allegations contained in Paragraphs 105, 106, 107, 108,
109 and 110 of the Plaintiff’s Complaint.
20. The allegations contained in Paragraph 111 of the Plaintiff’s Complaint state
conclusions of law not directed to this Defendant and no response is required. To the extent is a
required, this Defendant denies the allegations contained in Paragraph 111 of the Plaintiff’s
Complaint.
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21. This Defendant denies the allegations contained in Paragraph 112 (including
subparts 1., 2., 3., 4., 5., 6., 7., 8., 9., 10., 11., 12., 13., 14., 15., 16., 17., 18. and 19.) of the
Plaintiff’s Complaint.
22. The allegations contained in Paragraphs 113 and 114 of the Plaintiff’s Complaint
state conclusions of law not directed to this Defendant and no response is required. To the extent
is a required, this Defendant denies the allegations contained in Paragraphs 113 and 114 of the
Plaintiff’s Complaint.
AS TO THE SECOND CAUSE OF ACTION (Violation of Plaintiff’s Fourteenth Amendment Equal Protection Right to be Free From
Sexual Harassment as to All Defendants, Violation of 42 U.S.C. § 1983)
23. In response to the allegations contained in Paragraph 115 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
24. The allegations contained in Paragraphs 116 and 117 of the Plaintiff’s Complaint
state conclusions of law to which no response is required.
25. This Defendant denies the allegations contained in Paragraphs 118, 119, 120 and
121 of the Plaintiff’s Complaint.
AS TO THE THIRD CAUSE OF ACTION (Intentional Infliction of Emotional Distress as to Graf)
26. In response to the allegations contained in Paragraph 122 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
27. This Defendant denies the allegations contained in Paragraph 123, 124, 125, 126,
127 and 128 of the Plaintiff’s Complaint.
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AS TO THE FOURTH CAUSE OF ACTION (Negligence / Gross Negligence as to College Pursuant to the South Carolina Tort Claims
Act, Sections 15-78-10, et seq., CODE OF LAWS OF SOUTH CAROLINA, 1976, as amended)
28. In response to the allegations contained in Paragraph 129 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
29. The allegations contained in Paragraphs 130, 131 (including subparts 1., 2., 3., 4.,
5., 6., 7., 8., 9. and 10.), 132 and 133 of the Plaintiff’s Complaint are not directed to this
Defendant and no response is required. To the extent a response is required, this Defendant
denies the allegations contained in Paragraphs 130, 131 (including subparts 1., 2., 3., 4., 5., 6., 7.,
8., 9. and 10.), 132 and 133 of the Plaintiff’s Complaint.
AS TO THE FIFTH CAUSE OF ACTION (Negligence / Gross Negligence as to College Negligent Hiring, Retention, and Supervision of Professor Graf Pursuant to the South Carolina Tort Claims Act, Sections 15-78-10, et
seq., CODE OF LAWS OF SOUTH CAROLINA, 1976, As amended)
30. In response to the allegations contained in Paragraph 134 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
31. The allegations contained in Paragraphs 135, 136 (including subparts 1., 2., 3., 4.,
5. and 6.), 137, 138 and 139 of the Plaintiff’s Complaint are not directed to this Defendant and
no response is required. To the extent a response is required, this Defendant denies the
allegations contained in Paragraphs 135, 136 (including subparts 1., 2., 3., 4., 5. and 6.), 137, 138
and 139 of the Plaintiff’s Complaint.
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AS TO THE SIXTH CAUSE OF ACTION (Outrage as to College and Graf)
32. In response to the allegations contained in Paragraph 140 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
33. This Defendant denies the allegations contained in Paragraphs 141, 142, 143 and
144 of the Plaintiff’s Complaint.
34. The allegations contained in Paragraph 145 of the Plaintiff’s Complaint state
conclusions of law to which no response is required.
35. This Defendant denies the allegations contained in Paragraph 146 of the
Plaintiff’s Complaint.
AS TO THE SEVENTH CAUSE OF ACTION (Outrage as to College for Failing to Take Action Despite Knowledge of Prior Complaints
Against Graf)
36. In response to the allegations contained in Paragraph 147 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
37. The allegations contained in Paragraphs 148, 149, 150, 151, 152, 153, 154, 155,
156 and 157 of the Plaintiff’s Complaint are not directed to this Defendant and no response is
required. To the extent a response is required, this Defendant denies the allegations contained in
Paragraphs 148, 149, 150, 151, 152, 153, 154, 155, 156 and 157 of the Plaintiff’s Complaint.
AS TO EIGHTH CAUSE OF ACTION (Assault & Battery as to Graf)
38. In response to the allegations contained in Paragraph 158 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
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39. This Defendant denies the allegations contained in Paragraphs 159, 160 and 161
of the Plaintiff’s Complaint.
AS TO THE NINTH CAUSE OF ACTION (Violation of the South Carolina Campus Sexual Assault Information Act)
40. In response to the allegations contained in Paragraph 162 of the Plaintiff’s
Complaint, this Defendant reasserts and realleges the above paragraphs as if fully restated herein
verbatim.
41. The allegations contained in Paragraphs 163 and 164 of the Plaintiff’s Complaint
are not directed to this Defendant and no response is required. To the extent a response is
required, this Defendant denies the allegations contained in Paragraphs 163 and 164 of the
Plaintiff’s Complaint.
42. This Defendant denies the WHEREFORE paragraph (including subparts A., B.,
C., D. and E.), being the remaining allegations of the Plaintiff’s Complaint.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Failure to State a Claim)
43. The allegations in the Plaintiff’s Complaint fail to state a claim upon which relief
may be granted against this Defendant. Therefore, this Complaint should be dismissed for all
applicable reasons in accordance with Rule 12(b)(6) of the Federal Rules of Civil Procedure.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Sovereign Immunity-Tort Claims Act)
44. This Defendant alleges that Plaintiff’s Complaint is barred or otherwise limited by
all applicable provisions of the South Carolina Tort Claims Act, including, but not limited to,
S.C. Code Ann. §15-78-60.
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FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Limitation of Remedies-Tort Claims Act)
45. Any recovery by Plaintiff must be limited to the remedies allowed under the
South Carolina Tort Claims Act, including, but not limited to, S.C. Code Ann. §§15-78-120(a)(1)
and 15-78-120(b).
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES: (Sole Remedy-Tort Claims Act)
46. The Plaintiff’s exclusive and sole remedy for any tort committed by an employee
of a governmental entity while acting within the scope of the employee’s official duty is the
South Carolina Tort Claims Act, and any claims asserted by Plaintiff not in compliance therewith
must be dismissed.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES: (Eleventh Amendment Immunity)
47. Eleventh Amendment Immunity in accordance with the Constitutions of the
United States of America and the State of South Carolina bars Plaintiff’s Claims in totality
against this Defendant.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Qualified Immunity)
48. This Defendant was at all times acting within its official and discretionary
capacity and as such, is entitled to qualified immunity.
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FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(No Proximate Cause)
49. That any injuries sustained by the Plaintiff were not proximately caused by any
actions or inactions of this Defendant.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Compliance with Statutes, Codes, and Regulations)
50. This Defendant alleges that Plaintiff’s claims are barred, in whole or in part,
because this Defendant complied with the applicable statutes codes, and regulations.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Failure to Mitigate)
51. That the Plaintiff has failed to take reasonable actions to adequately mitigate his
damages, if any, by not undertaking proper preventative or curative measures.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Election of Remedies)
52. The Plaintiff has pleaded alternative tort-based and statutory Causes of Action.
The Plaintiff is not entitled to a “double recovery” and must forthwith make an election of
remedies.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Punitive Damages Unconstitutional / Limitation)
53. That any award or assessment of punitive damages would violate this Defendant’s
constitutional rights under the Fifth, Sixth and Fourteenth Amendments of the United States
Constitution and comparable provisions of the South Carolina Constitution. In addition, if
punitive damages are awarded, they must be limited as set forth at S.C. Code Section 15-32-530.
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FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Unclean Hands)
54. To the extent that Plaintiff was negligent, grossly negligent, willful, wanton and
reckless, resulting in any damages to Plaintiff, the existence of which expressly denied, Plaintiff
comes to this Court with unclean hands and such inequitable conduct on part of Plaintiff
constitutes a bar and complete defense to any claim for relief by Plaintiff.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Statute of Limitations)
55. Plaintiff’s claims are barred by the applicable Statute of Limitations.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(No Constitutional Violation)
56. That alleged actions/inactions claimed by the Plaintiff did not rise to the level of
constitutional violations and the Plaintiff did not suffer any infringement of constitutional and/or
federal rights, state rights, privileges or immunities.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES:
(Official Capacity)
57. This Defendant acting as a state official in his official capacity is not subject to
suit under 42 U.S.C. § 1983 as a matter of law.
FURTHER ANSWERING AND AS AN AFFIRMATIVE DEFENSE, THIS DEFENDANT ALLEGES: (Reservation and Non-Waiver)
58. This Defendant reserves any additional and affirmative defenses as may be
revealed or become available to it during the course of their investigation and/or discovery in the
case and is consistent with the Federal Rules of Civil Procedure.
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FURTHER ANSWERING AND AS A COUNTERCLAIM, THIS DEFENDANT ALLEGES:
(Defamation)
59. Defendant is a citizen and resident of Charleston County, South Carolina.
60. Upon information and belief, Plaintiff is a citizen and resident of Charleston
County, South Carolina.
61. Plaintiff sought out the Defendant to serve as a piano teacher for the Plaintiff
because of the Defendant's excellent abilities and Defendant's work history as a concert pianist
and piano instructor.
62. Neither Plaintiff nor his mother is indigent or impoverished. Upon information
and belief, his mother has chartered two corporations in the State of Hawaii. Upon information
and belief she owns and operates a successful restaurant and a cultural arts program.
63. The Plaintiff and his piano teacher discussed the possibility of the Plaintiff
attending the College of Charleston and studying piano under the Defendant's tutelage. The
decision was made that the Plaintiff would attend the College of Charleston and study piano
under the tutelage of the Defendant.
64. For over four years, the Defendant's tutelage of the Plaintiff was unremarkable.
The Plaintiff never complained to the Defendant, and to the best of the Defendant's knowledge,
the Plaintiff never complained about the Defendant to anyone else.
65. Upon information and belief, at some point while enrolled at the College of
Charleston, the Plaintiff was arrested on account of his involvement with marijuana. At some
point thereafter, Defendant is informed and believes that Plaintiff began using synthetic
marijuana a/k/a "spice" a/k/a "k2", and that Plaintiff's drug usage spiraled out of control in the
Summer of 2012 when he began to evidence irrational thoughts and behavior.
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66. This behavior became evident during a trip to Italy and attendance at an Italian
music festival during the Summer of 2012. The behavior was witnessed by the Defendant, other
faculty members of the music festival, and the Defendant's other students.
67. The Plaintiff was romantically involved with another student contemporaneously
taught by the Defendant, and she has provided an affidavit which describes the Plaintiff's
behavior during this trip to Italy and afterward. This redacted affidavit is attached as Exhibit
One to this Answer and Counterclaim and incorporated herein.
68. Upon information and belief, during this period of heavy drug use, the Plaintiff
irrationally came to view the Defendant as somehow responsible for difficulties that had arisen
between the Plaintiff and his romantic interest, as well as for the disapproval of the Plaintiff's
behavior which had arisen among the Plaintiff's peers.
69. Upon information and belief, the Plaintiff, maliciously, irrationally, and without
any legitimate basis in fact, began - in the Fall of 2012 - to defame the Defendant by telling a
third party repeatedly that the Defendant had subjected the Plaintiff to unwelcome sexual
advances and sexual misconduct throughout his tenure at the College of Charleston. This third
party was prompted to report these false reports to officials of the College of Charleston in
December of 2012.
70. The Plaintiff has willfully, wantonly, maliciously, and intentionally defamed the
Defendant, per se, by maliciously publishing false statements to third parties which indicated
that the plaintiff was unfit in his business or profession.
71. The acts and omissions of the Plaintiff were willful, wanton, reckless, malicious,
and occurred in bad faith, and have proximately caused damages, both actual and exemplary to
the Defendant.
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72. The within lawsuit is nothing more than an attempt by the Plaintiff to get money
from the Defendants for conduct that never occurred, and for injuries which do not exist.
FURTHER ANSWERING AND AS A COUNTERCLAIM, THIS DEFENDANT ALLEGES:
(Tortious Interference with Contract and/or Prospective Contractual Relations)
73. The Defendant incorporates all the foregoing paragraphs of this Answer and
Counterclaim.
74. At the time of the afore-referenced wrongful acts of the Plaintiff, the Defendant
was a party to a contract of employment with the Defendant College of Charleston.
75. The Plaintiff had knowledge of the afore-referenced contract; by his conduct
intentionally procured its breach without justification; and thereby proximately caused actual and
punitive damages to the Defendant.
76. At the time of the afore-referenced wrongful acts of the Plaintiff, the Defendant
had potential contractual relations with the Defendant College of Charleston as well as other
entities. The Plaintiff intentionally interfered with the Defendant's potential contractual relations
for an improper purpose or by improper methods thereby proximately causing actual and
punitive damages to the Defendant.
JURY TRIAL DEMAND
77. Defendant demands a jury trial of all claims which may be tried to a jury.
WHEREFORE, having fully answered the Plaintiff’s Complaint, and having asserted
these affirmative defenses and counterclaims, the Defendant, Enrique Graf, individually and in
his official capacity as former Music Professor and University Artist in Residence at the College
of Charleston, prays that:
A) the Plaintiff’s Complaint be dismissed with prejudice and that the Defendant be awarded the costs and reasonable fees associated with this matter;
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B) the Defendant's counterclaims be set down for a trial by jury;
C) Judgment for actual and punitive damages be entered against the Plaintiff and in favor of the Defendant on the Defendant's counterclaims;
D) This Court grant such other and further relief as may be deemed just and proper.
HOOD LAW FIRM, LLC 172 Meeting Street Post Office Box 1508 Charleston, SC 29402 Phone: (843) 577-4435 Facsimile: (843) 722-1630 Email: [email protected] s/ Elloree A. Ganes Robert H. Hood (1939) Elloree A. Ganes (9022) Brian E. Johnson (10098) Attorneys for the Defendant Enrique Graf, individually and in his official capacity as former Music Professor and University Artist in Residence at the College of Charleston
May 8, 2014 Charleston, South Carolina
GIBBS & HOLMES s/ Allan R. Holmes Allan R. Holmes (Fed. Bar #1925) Cheryl H. Ledbetter (Fed. Bar #11446) Suite 110, 171 Church Street Charleston, South Carolina 29401 Email: [email protected] Attorneys for the Defendant Enrique Graf on Counterclaim
May 8, 2014 Charleston, South Carolina
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