Galanis Post Trial Memorandum

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Reply Memorandum
Gerstl v. Galanis

UNITED STATES BANKRUPTCY COURT
DISTRICT OF CONNECTICUT
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:
ARTHUR J. GERSTL, INTERIM TRUSTEE, : Adv. No. 5-85-0024
: Ref. Civ. No. B-85-40
Plaintiff, : (EBB)
:
-against- :
:
JOHN P. GALANIS; MILTON I. SCHWARTZ; :
MISCO, INC.; and ARMSTRONG CAPITAL, :
S.A. and DAYTON COMPANY INC., :
:
Defendants, :
:
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:
ARMSTRONG CAPITAL, S.A., :
: ADV. NO. 5-85-0025
Plaintiff, : REF. CIV. NO. B-79-43
: (TFCD)
-against- :
:
FEINER, CURTIS, SMITH et al, :
:
Defendants :
:
- - - - - - - - - - - - - - - - - - - -X
:
In re : Chapter 7
: Case No. 5-80-00302
JOHN P. GALANIS, :
:
Debtor, :
:
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ARMSTRONG CAPITAL'S REPLY MEMORANDUM

MORE, PHILLIPS & HULL, P.C.
Attorneys for Armstrong Capital, S. A.
63 Mason Street
Greenwich, Connecticut 06830
(203) 629-2611

JOHN C. KLOTZ
Attorney for Armstrong Capital, S. A.

217 Broadway, Suite 407
New York, New York 10007
(212) 308-1162

TABLE OF CONTENTS

Page

Introduction .................................................... 1
POINT ONE: THIS COURT HAS JURISDICTION TO DETERMINE THE
GALANIS CLAIM TO THE LIMITED EXTENT THAT IT MAY
BE CONSIDERED AN INDEPENDENT EQUITABLE ACTION FOR
FRAUD. TO THE EXTENT THAT IT IS POSTURED AS A
MOTION PURSUANT TO RULE 60(b)(5) THE COURT LACKS
SUBJECT MATTER JURISDICTION........................... 3
POINT TWO: THE GALANIS RULE 60(b) CLAIMS ARE NOT TIMELY.......... 6
POINT THREE: GALANIS HAS NOT PROVEN A "FRAUD UPON THE COURT...... 9
POINT FOUR: NEW YORK STATE GENERAL OBLIGATIONS LAW SECTION
15-108 HAS NO APPLICATION TO PAYMENTS MADE PRIOR
TO SEPTEMBER 1, 1974. THEREFORE, IT CAN NOT
APPLY TO PAYMENTS PURSUANT TO THE DELFINO
AGREEMENT............................................ 11
Right of indemnification....................................... 12
POINT FIVE: THE GALANIS CLAIM RESTS ON THREE FACTUAL
FALLACIES: (1) THAT ARMSTRONG CAPITAL IS ITSELF
AN ASSIGNEE; (2) THAT THE CLAIM OF ITS PARENT'S
SHAREHOLDERS WAS LIMITED TO TWO MILLION DOLLARS;
(3) THAT IT SOUGHT "CONTRIBUTION" IN FEINER.......... 13

1. Armstrong Capital is not an assignee........................ 13
2. The claims of the shareholders of Armstrong Investors
have not been fully satisfied............................... 14
3. Armstrong Capital is not seeking contribution............... 15
CONCLUSION ...................................................... 16

Introduction

This memorandum is submitted by ARMSTRONG CAPITAL, S.A.
("Armstrong Capital") in reply to the Post-Trial Memorandum of
JOHN P. GALANIS ("Galanis"). On page two his memorandum, Galanis
admits the validity of the judgment obtained by Armstrong Capital
in the United States District Court for the Southern District of
New York in Armstrong Capital S.A. v. Feiner Curtis Smith &
Goldman, Index No. 74 Civ. 3154, Hon. Lloyd F. McMahon, U.S.D.J.,
("the Feiner action) and summarizes his case as follows:

"* * * Galanis has acknowledged the Armstrong
[Feiner] judgment and its registration in Connecticut.
The judgment however, should not be enforced.
"Armstrong Capital initiated the action [Feiner]
in which the judgment was entered against Galanis as
assignee of the rights and interest of others, and
those rights have been fully satisfied. Further,
Armstrong Capital was a named joint tortfeasor of
Galanis who obtained its own release, and is therefore
not entitled to recover any judgment against Galanis
based upon the same claims asserted against it.
Alternatively, Galanis' co-defendant Yamada was
equally culpable as Galanis, and Galanis is therefore
liable for only 50% of the judgment. (Emphasis
supplied)

In so far as the claim that the release of Yamada
somehow benefits Galanis, that is discussed in POINT FIVE, pages
16 et seq of Armstrong Capital's Post-Trial Memorandum and
Armstrong Capital will not repeat those arguments in this reply
memorandum. In addition, as argued in POINT SIX of the Post-Trial
memorandum, the claims of fraud against the court are also time
barred. However, the Galanis papers throughout this proceeding
have been a repetitive incantation of three factual premises:

(1) Armstrong Capital is an assignee;

(2) the claims that it is enforcing have been
fully satisfied;
(3) that as a "named" joint tortfeasor who
previously obtained its own release, it may not obtain
"contribution."

From the incantation of these "facts" (See POINT FIVE,
infra) Galanis seeks to invoke Rule 60(b) in order to nullify the
Feiner judgment. This memorandum will therefore focus on the
legal ramifications of the Galanis factual incantations although
those incantations have as much reality as an alchemist's
formulation for turning lead to gold.

POINT ONE

THIS COURT HAS JURISDICTION TO DETERMINE THE
GALANIS CLAIM TO THE LIMITED EXTENT THAT IT MAY
BE CONSIDERED AN INDEPENDENT EQUITABLE ACTION
FOR FRAUD. TO THE EXTENT THAT IT IS POSTURED AS
A MOTION PURSUANT TO RULE 60(b)(5) THE COURT
LACKS SUBJECT MATTER JURISDICTION.

On page "2" of the Galanis Post-trial Memorandum, it is
stated "Galanis has acknowledged the Armstrong [Feiner] judgment
and its registration in Connecticut." On page 7 of his
post-trial memorandum, Galanis cites Covington Industries, Inc.
v. Resintex A.G., 629 F.2d 730, 734 (2d Cir. 1980) for the broad
proposition that a motion pursuant to Federal Rules of Civil
Procedure ("Rule") 60(b) may be brought in a court of
registration.

In Covington , the Second Circuit limited the authority
of the court of registration under Rule 60(b) to those areas
where the jurisdiction of the court of origin is questioned and
the facts are therefore not within the special competence of the
court of rendition (629 F.2d 732 to 734). Thus the following
factors decide the issue:

"Although Rule 60(b) does not specify the
correct forum for presenting a motion for relief from
judgment, the motion is generally brought in the
district court rendering judgment. * * * In the usual
case, the court of rendition will be more familiar with
the facts than the court of registration and perhaps
more conversant with the applicable law. Where the Rule
60(b) motion is for relief from a default judgment,
however, the assumptions about the rendering court's
qualifications no longer apply. Where the defendant
does not appear to contest jurisdiction and the court
does not receive evidence or make findings in the
matter except on the issue of damages, the court of
rendition is no more familiar with the factual
situation than is the court of registration. Under
these circumstances the court of registration therefore
seems as qualified to determine jurisdiction of the
rendering court particularly when the later is a
federal court of coordinate authority.

"Recognizing the power in a different court
to determine jurisdiction of the rendering court is
particularly appropriate when the party who obtained
the default is attempting to enforce it in another
court. * * *" (629 F.2d at 733)

"In the instant case, [defendants] did not appear
in the district court of Georgia to contest the court's
jurisdiction and thus they have not been heard on this
issue." (629 F.2d at 734)

This distinction between (a) those motions which sound
in an equitable action to set aside a judgment as void for lack
of jurisdiction or fraud and (b) other motions under Rule 60(b)
was further articulated in Indian Head National Bank of Nashua v.
Brunelle, 689 F.2d 245 (1st Cir. 1982) which discussed and
explained the Covington decision in some detail (698 F.2d at 250,
251).

In Brunelle, the court determined that there were two
categories of cases where Rule 60(b) could be entertained in the
Court of registration.

"The first results from a parallel between
many of the grounds of relief and those which support
independent equitable actions. Because of this
overlap, courts other than rendering courts have in
some instances considered the requests of those who
proceeded by Rule 60(b) motions by treating the motions
as independent equitable actions. * * *" (689 F.2d at
249, 250).

"There is a second category of cases in which
courts of registration have entertained requests * *
*. Several courts of registration have considered Rule
60(b)(4) motions for relief from default judgments on
the grounds that the judgments were void because the
rendering courts lacked jurisdiction over the party
against whom enforcement is sought. * * *" 689 F.2d at
250)

"* * * Neither the district court or
[defendant] cites a case, and we have found none, where
a court of registration was willing to entertain
directly a Rule 60(b) motion other than one attacking a
default judgment for lack of personal jurisdiction."
689 F.2d at 251

To the extent that the Galanis case raises issues that
may be classified as "fraud upon the court" this Court would have
jurisdiction to hear his claim. Such claims attack in a very
real manner the competence of the original court to have heard
the case and the ability of the defendant to present his claim.
(See POINT THREE, infra). However, to the extent that he seeks
relief pursuant to Rule 60(b) for matters that were within the
competence and province of the rendering court, his claim may not
be heard here.

These issues, involving so-called contribution by
Armstrong Capital and credits against judgment arise out of
events that occurred not later than 1972, two years before the
Feiner action was commenced and four years before the Feiner
judgment was entered. The facts on which Galanis relies were in
fact placed before the Feiner court. In this case, Galanis
testified but claimed no memory independent of the transcript of
the prior record from which two questions were read by his
counsel. If there ever was a case where the competence of the
court of rendition which heard all the evidence is manifest, it
is this one.

Moreover, Galanis appeared, answered and testified.
There is no question of default or lack of jurisdiction. Thus,
insofar as Rule 60(b) is concerned, the remedy is limited to
those grounds that would support an independent equitable action.
Only the presence of fraud that vitiates the Feiner judgment can
be reached.

Galanis seems to read significance into Armstrong
Capital's consent to allow this Court to issue a dispositive
order beyond that plainly intended. The consent was to the
Court's power to decide the issues in the first instance --
including the issue of jurisdiction of claims-- it was not a
waiver of any jurisdictional defense to individual claims,
particularly when the issue raised is just as applicable to a
constitutional district judge as it is to this Court.

POINT TWO

THE GALANIS RULE 60(b) CLAIMS ARE NOT TIMELY.

Rule 8 requires that claims of payment be affirmatively
pleaded and Rule 9(a) requires that defenses of lack of capacity
be pleaded with particularity. Therefore, the Galanis claims of
"real party in interest," "payment" and "contribution," are bar-
red by the conclusion of the Feiner case and entry of judgment
against him. See Fox v. McGrath, 152 F.2d 616 (2d Cir. 1945) and
the other cases cited in POINT TWO of Armstrong Capital's
Post-Trial Memorandum.

Galanis seeks to avoid this by bringing a motion
pursuant to Rule 60 (b)(5) that payment has been made. Certainly,
the only manner in which Rule 8 and Rule 60(b)(5) can be
harmonized is to understand that Rule 60(b)(5) by its plain
meaning applies to payments after judgment (or at least after
joinder of issue) and Rule 8 applies to payment prior to trial.
In the instant case, the last "payment" (April, 1972; I-34, JPG
Ex. 5) predates the October 1975 Galanis answer (ARM. EX. Q,
sub. ex. C).

Rule 60(b)(5) provides no escape for Galanis. Motions
pursuant to Rule 60(b) must be made within a reasonable time but
in less than a year. Amoco Overseas Oil Co. v. Compagne Nationale
Algerienne de Navigation, 605 F.2d 648, 656 (2d Cir. 1979)
(motion made within year but untimely because not within a
reasonable time); Scola v. Boat Frances R, Inc., 618 F.2d 147,
154, 155 (one month too long for motion).

Specifically, in regards to claims of payment or
release, delays of 13 months and 2 months have been held untimely
and therefore fatal to such motions. Friedman v. Wilson Freight
Forwarding Co., 320 F.2d 244 (3d Cir. 1963) (13 months); Willets
v. Yellow Cab Co., 214 F.2d 612 (7th Cir. 1954) (2 months).

The cases cited by Galanis where credits for payments
were allowed all involve applications brought within weeks of
final judgment. In Caraway v. Swain, 23 F.R.D. 657 (N.D. Fla.
1959) cited on page 19 of the Galanis memorandum, the motion was
made within 58 days of judgment and the court noted that the
motion must be made within one year (23 F.R.D. at 559). In
Snowden v. D.C. Transit System, Inc., 454 F.2d 1047, 1048-49
(D.C. Cir. 1971) the motion had been made within 16 days of
verdict. In no case does it appear that amendment was allowed for
payments that preceded pleading. In Snowden for example the
payment deducted occurred "during the course of trial."

United States v. Karahalis, 205 F.2d 331 (2d Cir. 1953)
did not involve claims of payment that ought to have been pleaded
pursuant to Rule 8, but rather relief from a default judgment so
that the merits of a deportation proceeding could be contested.
The reason for the 17 year delay was that the defendant had been
in Greece tending for his wife during her terminal illness when
the proceeding was brought and that after she died, World War II
prevented any action to lift the default. It is almost shameful
for Galanis -- a convicted swindler who has not repaid one dime
of the money he stole -- to cite the equities of such a case. In
any event, in Amoco Overseas Oil Co. v. Compagne Nationale
Algerienne de Navigation, supra, the Second Circuit denied a
motion to reopen a default because of prejudice in attempting to
reconstruct evidence even though the motion was brought within
one year of the default. In the instant case, the delay is over a
decade.

Because more than a year as elapsed since entry of
judgment, the Galanis claim is untimely as a Rule 60 motion and
must therefore be weighed as a "independent equitable action."
Pfotzer v. Amercoat Corp., 548 F.2d 51 (2d Cir. 1977).

POINT THREE

GALANIS HAS NOT PROVEN A "FRAUD UPON THE COURT."

The evidence is beyond cavil that adversaries of
Armstrong Capital in the Feiner litigation were completely
informed of all the facts that constitute the Galanis claim and
placed these facts before the Court. For an exceptionally
detailed recitation of those facts, the Court is respectfully
referred to the "Order to Show Cause and Petition for Writ of
Mandamus to Honorable LLoyd F. Mc Mahon" dated March 23, 1976
(ARM. EX. L) particularly par. 8 to 11 beginning on page 5 of the
petition). There can be no question that at the time of that
application in 1976, the Feiner defendants had been fully
informed of the intimate details of the Delfino settlement and
afforded an opportunity to depose an officer of Citibank, Mr.
John Rulon-Miller (ARM. EX. W).

It is impossible, therefore, to discern the reason for
Galanis citing Israel Aircraft Ind. Ltd. v. Standard Precision,
559 F.2d 203 (2d Cir. 1977) and Kuperfman v. Consolidated
Research & Mfg. Corp., 459 F.2d 1072, 1078 (2d Cir. 1972) in
support of his claim of fraud upon the court. Kuperfman is
discussed on page 12 of Armstrong Capital's Post-trial
Memorandum. That case specifically held that the belief of
counsel that his adversary possessed a crucial release, meant
that counsel's failure to reveal the same was not "fraud upon the
court." (459 F.2d at 1081). In the Israel Aircraft case, the
Court of Appeals reversed the dismissal of a complaint for fraud
against the court where there was no evidence of intentional
deception in the concealment of a crucial document.

In the Feiner case, there is no evidence of any
concealment. All the necessary documents were made available to
the defendants during discovery and an officer of Citibank
appeared and testified during discovery in complete candor about
the nature of the Delfino agreements.

Mr. McIntyre's affidavit was argument about the legal
effect of documents in possession of his adversary. If his
adversary thought they were deceitful in anyway, he could have
taken action at that time. To the contrary, before the Court of
Appeals, the Feiner defendants argued not that McIntyre was
concealing evidence but that he had -- in the same affidavit
cited by Galanis-- admitted everything. On page 9, the Feiner
defendants' petition for mandamus (ARM. EX. L), states:

"12. This motion returnable on March 12, 1976 [to
implead Citibank] was denied in its entirety despite
the fact that counsel for plaintiff, by affidavit sworn
to by James J. McIntyre on March 11, 1976, admitted
that the shareholders of Armstrong Investors, S.A. (the
parent of the instant plaintiff in the sense that it
owned all the plaintiff's stock) had assigned there
shares of stock to an independent affiliate of
[Citibank] as part of the Delfino settlement.* * *
(Emphasis supplied)

Under all the circumstances, to hold that a lawyer
committed a fraud in arguing the legal effects of documents that
he knew -- and which were in fact -- in possession of its
adversary, is to make a shambles of the concept of the
adversarial system. Under the authority cited by Galanis it just
isn't so. There can be no concealment when the documents are in
possession of the adversary.

POINT FOUR

NEW YORK STATE GENERAL OBLIGATIONS LAW
SECTION 15-108 HAS NO APPLICATION TO PAYMENTS
MADE PRIOR TO SEPTEMBER 1, 1974. THEREFORE,
IT CAN NOT APPLY TO PAYMENTS PURSUANT TO THE
DELFINO AGREEMENT.

The preponderant part of the Galanis claim is that
because of the payments and relationships arising from the
settlement agreement in the Delfino case, that Armstrong Capital
is an "assignee" who has "paid for its release" and is therefore
barred from seeking contribution pursuant to N.Y. General
Obligations Law, {15-108(c). Factually, this is simply not true.
In any event, all the shareholders of Armstrong Investors except
the Delfino plaintiffs had executed the agreements in 1971 and
the Delfino plaintiffs executed theirs in April, 1972 (JPG EX.
2) and were the last of the shareholders to sign (II-68).

However, that provision of General Obligations Law
Section 15-108 did not become effective until September 1, 1974.
It has been specifically held that a tortfeasor who settled prior
to September 1, 1974 may seek contribution after September 1,
1974. Gates-Chili Central School District v. State, 55 A.D.2d 44,
389 N.Y.S.2d 716 (4th Dept. 1976). In Gates-Chili, the New York
court said:

"* * * The settling tort-feasor may reasonably be
deemed to have acted with full knowledge of the law as
it existed at the time the release was executed. [cita-
tion omitted] Consequently in would be inappropriate on
these facts to undo what had been done and, on the
basis of present law, to nullify actions taken by
parties in reliance on the law as it then stood.
[citation omitted]

"We thus reject the State's position and hold that
where the settlement agreement was executed prior to
September 1, 1974, any rights of contribution which
existed at the date settlement are not affected by the
1974 amendment of Section 15-108 of the General
Obligations Law despite the fact that the claim for
contribution may not have been asserted until after the
effective date of the amendment." 55 A.D.2d at 47.

Thus, even if all the factual leaps and incantations of
Galanis were conceded [and they aren't -- see POINT FIVE, infra]
General Obligations Law {15-108 would not apply to Armstrong
Capital's claim in Feiner. Under New York State law since the
Delfino agreement predated September 1, 1974, an individual
claimed to be a tortfeasor in the Delfino action could seek
contributions for payments made pursuant to the agreement. See
Dole v. Dow Chemical Co., 30 N.Y.2d 143 (1971).

Armstrong Capital must emphasize that it does not
accept the Galanis description of the legal relationships between
it, Armstrong Investors, the Shareholders of Armstrong Investors
and Citibank. But even if Galanis were accurate, Gates-Chili
Central School District v. State, supra, holds conclusively that
Armstrong Capital would not be barred from any claim.

Right of indemnification.

Moreover, there can be no doubt that upon all the
evidence before the Court, that whatever liability that may have
existed -- and none has been proven -- Armstrong Capital was not
in pari delicto with Galanis who was its fiduciary and thus
Armstrong Capital was entitled to common law indemnification.
Those rights have survived the enactment of {15-108 even after
September 1, 1974. See N.Y. Civil Practice Act and Rules,
{1404(b); McDermot v. City of New York, 50 N.Y.2d 643 (1980).

In McDermot, the New York Court of Appeals explicitly
held that the General Obligations Law was not a bar to a
tortfeasor seeking indemnity from one who was primarily liable.
Defenses of pari delicto would apply but that, like payment, is
an affirmative defense. Under McDermot, even if everything
Galanis claimed was relevant, he would still be required to
allege and prove as an affirmative defense that Armstrong Capital
-- or Citibank -- was in pari delicto and therefore barred from
seeking indemnity.

POINT FIVE

THE GALANIS CLAIM RESTS ON THREE FACTUAL FALLACIES:

(1) THAT ARMSTRONG CAPITAL IS ITSELF AN ASSIGNEE;
(2) THAT THE CLAIM OF ITS PARENT'S SHAREHOLDERS
WAS LIMITED TO TWO MILLION DOLLARS;
(3) THAT IT SOUGHT "CONTRIBUTION" IN FEINER.

Galanis has created an Alice-in-Wonderland world where
nothing is quite what it seems. Central to his claim are three
propositions that simply aren't true.

1. Armstrong Capital is not an assignee.

The evidence is absolutely clear that the claims of the
shareholders of Armstrong Investors were assigned to Citibank and
its nominee who was not Armstrong Capital but First National
Nominees Ltd. (JPG EX. 28, pg. 8, par. 7). There is no evidence
of any transfer of anything to Armstrong Capital. There is
evidence cited and recited by Galanis that Citibank, having
undertaken to pursue Galanis, fostered the retention of Weisman,
Celler, Spett, Modlin and Wertheimer ("Weisman, Celler) as
counsel for Armstrong Capital and obtained the consent of the
former shareholders to that retention. However, nothing was
assigned to Armstrong Capital and Weisman Celler pursued claims
against Galanis that were the property of Armstrong Capital (JPG
EX. 9, paras. 3, 8; I-79, 81; II-52, 53, 57 to 59).

No matter how many frequently or vigorously asserted
and/or chanted by Galanis, the simple fact remains that no claims
were assigned to Armstrong Capital and the claim asserted in
Feiner was not an assigned claim. That Citibank fostered the
retention of Weisman, Celler pursuant to its obligations under
the Delfino agreement did not effect a transfer of property to --
or from-- Armstrong Capital. The fundamental relationship of
Armstrong Investors to Armstrong Capital as parent-subsidiary
remained unchanged.

The simple fact that shareholders of the parent would
be the ultimate beneficiaries of the recovery by Armstrong
Capital has no effect on the rights of Armstrong Capital to
recapture the property looted by Galanis and his confederates.

2. The claims of the shareholders of Armstrong Investors have
not been fully satisfied.

Also crucial to the Galanis claim is that the rights
"assigned" have been "fully satisfied." Even a cursory reading of
the Delfino complaint reveals that the claims of the shareholders
and thus the assigned claims reached $22.8 million. At the very
least, the claims of the shareholders equaled $4 million --
their investment in the Armstrong Investors. They received
one-half that sum in the Delfino agreement. Therefore, even if
Armstrong Capital were an assignee -- and it was not -- the
assigned claims have not been fully satisfied by the payments in
Delfino. The best descriptions of the true situation appear in
papers filed by former adversaries. For example, the petition for
mandamus to the Court of Appeals for the Second Circuit filed by
the Feiner defendants (ARM. EX. L).

3. Armstrong Capital is not seeking contribution.

Armstrong Capital never paid out any money to anyone.
It was a victim whose property was stolen. The complaint in the
Feiner action is not a complaint for contribution. It is a
complaint for the property of Armstrong Capital embezzled by
Galanis and his confederates in the United Assets "joint
venture." In support of the Feiner complaint, Galanis was called
as a witness and testified. A verdict was directed against him.
That was more than a decade ago. No matter how many times Galanis
may chant that the Feiner claim was an application for
contribution, the fact remains that it was not -- and the
evidence is uncontroverted that the proceeds of the Feiner
settlements -- for which Galanis did get credit -- were paid to
Armstrong Capital and no one else (II-69; ARM. EX. J).

CONCLUSION

John Peter Galanis and his confederates embezzled the
property of Armstrong Capital in the United Assets "joint
venture." Armstrong Capital in Feiner recovered a judgment for a
part of the damages suffered at the hands of Galanis. All of the
facts concerning the Delfino settlement were known to the
adversaries of Armstrong Capital at the time of the Feiner
action. The claim that the Delfino settlement is "payment" is
untimely if asserted pursuant to Rule 60(b) and totally without
merit -- and time barred -- if pursued as an independent
equitable action. Armstrong Capital is entitled to judgment upon
the law and the facts granting its claim and denying that of
Galanis.

Dated: New York, New York
October 22, 1986

Respectfully submitted,

JOHN C. KLOTZ
Attorney for ARMSTRONG CAPITAL
217 Broadway, Suite 407
New York, New York 10007
(212) 308-1162

WILLIAM A. PHILLIPS
MORE, PHILLIPS & HULL, P.C.
Attorneys for Armstrong Capital, S. A.
63 Mason Street
Greenwich, Connecticut 06830
(203) 629-2611

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Reply Memorandum Gerstl v. Galanis

Reply Memorandum
Gerstl v. Galanis