Mutua Rule 56.1 Statement 6-7-2014

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK

___________________________________

J EFFREY MALKAN,

Plaintiff,
12-CV-0236(A)
-vs-

MAKAU W. MUTUA and
CHARLES P. EWING,

Defendants.
____________________________________

STATEMENT OF UNDISPUTED FACTS
Pursuant to Rule 56 of the Federal Rules of Civil Procedure and Rule 56 of the
Local Rules of Civil Procedure for the Western District of New York, Defendant Makau
Matua submits this statement of undisputed material facts in support of his Motion for
Summary J udgment. The only facts material to this motion are not in dispute, and are as
follows:
1. This is an action brought pursuant 42 U.S.C. 1983 seeking redress of alleged
constitutional violations by Defendants. The operative pleading is Plaintiffs
complaint filed on March 23, 2012. Docket No. 1 (Complaint).
2. This action arises out of the non-renewal of Plaintiffs term contract of
employment with the State University of New York at Buffalo Law School (Law
School). Id.
3. Plaintiff alleges that Defendants denied him his Fourteenth Amendment right to
procedural due process in connection with the non-renewal of his term contract.
Id. As to Defendant Matua, Plaintiff alleges that he denied him due process by
1
Case 1:12-cv-00236-RJA-HKS Document 56 Filed 06/07/14 Page 1 of 18
failing to seek review of his decision to non-renew by the Law Schools
Committee on Clinical Promotion and Renewal (CCPR) both before and after
the non-renewal. Id. at 34. As to Defendant Ewing, Plaintiff alleges that he
denied him due process by preventing his grievance regarding the non-renewal
from being heard by the Law School faculty. Id. at 35.
4. At all times relevant to the events underlying the Complaint, Defendant Matua
was the Dean of the Law School. Id at 5.
5. At all times relevant to the events underlying the Complaint, Defendant Ewing
was a tenured member of the faculty at the Law School and chairperson of the
facultys Grievance Committee. Id at 6.
A. The State University of New York
1

6. The State University of New York (SUNY) is governed by a Board of
Trustees.
2
The SUNY system administration oversees all of the campuses.
3

7. The Board of Trustees maintains Policies that constitute the rules for governance
of SUNY and its institutions.
4
The Policies appear in the Official Compilation of
Codes, Rules and Regulations of the State of New York as Subchapter b of
Chapter V of Volume 8 entitled Education.
5

1
Defendant Matuas Statement of Undisputed Facts borrows liberally from the Statement of Undisputed
Facts submitted by Defendant Ewing in support of his motion for summary judgment (Docket 54-2). We
hereby acknowledge Ewings counsels excellent work in marshalling the facts relevant to both
Defendants motions.
2
See Policies of the Board of Trustees (hereafter Policies), p.1, attached hereto as Exhibit A.
3
Excerpts of the deposition transcript of J ames J arvis are attached hereto as Exhibit B (hereafter J arvis
Tr. __). J arvis Tr. 42-43.
4
See Exhibit A, p.1.
5
Id.
2

8. The Policies contain procedures and requirements for the appointment of
employees.
6
The Policies contain specific requirements for term appointments,
which are appointments for a specified period of time, at Title D of Article XI of
the Polices.
7
Term appointments (the type that Plaintiff had) may only be for a
specified period of not more than three years which shall automatically expire at
the end of that period unless terminated earlier because of resignation, retirement
or termination.
8
Moreover, term appointments may be renewed for
successive periods of not more than three years each[.]
9
Term appointments may
only be made by chief administrative officer (i.e., the president) of the college.
10

9. The Policies provide that [n]o term appointment, of itself, shall be deemed to
create any manner of legal right, interest or expectancy in any other appointment
or renewal.
11
The Policies provide further that: [t]he services of academic and
professional employees having term appointments shall cease automatically at the
end of their specified terms. There shall be no right of appeal from a nonrenewal
of a term appointment.
12

B. State University of New York at Buffalo
10. The State University of New York at Buffalo (UB) is an agency of the State of
New York.
13
The UB Faculty Senate is the elected, official representative body
of the Voting Faculty [of UB].
14

6
Id. at pp. 10-19.
7
Id. at pp. 13-14.
8
Id. at p. 13.
9
Id. at p. 14.
10
Id. at pp. 1, 14.
11
Id. at p. 14.
12
Id. at p. 36.
13
By-Laws of the Voting Faculty, State University of New York at Buffalo, attached as Exhibit B, 2.2.1.
14
http://faculty-senate.buffalo.edu/.
3

11. Several documents govern the faculty at UB, including the Bylaws of the Voting
Faculty, State University of New York at Buffalo (the Bylaws.).
15
The UB
Faculty Senate also maintains a Charter of the Faculty Senate of State University
of New York at Buffalo (the Charter) and Standing Orders of the UB Faculty
Senate (Standing Orders.).
16
The Charters function is to define the membership
and describe its duties, responsibilities, and powers of the Faculty Senate.
17
The
Standing Orders provide rules relating to the procedures of the Faculty Senate.
18

12. The Bylaws provide in Article II, paragraph 4: The Voting Faculty may establish
procedures for investigating, hearing, and reporting to appropriate persons or
bodies with respect to charges or complaints brought by faculty members against
other faculty members, or against administrative officers of the University, or
brought against faculty members by students or other members of the University
community.
19

13. The Charter provides: Complaints of charges. The Senate shall establish by
standing orders, the procedures called for in an Article II, Paragraph 4 of the
Bylaws of the Voting Faculty.
20

14. The Standing Orders contain an entire section relating to Complaints and/or
Charges By and Against Faculty.
21
Section 7(b) of the Standing Orders provides:
[c]omplaints arising within departments, faculties, or schools shall initially be
dealt with according to procedures established at those levels. Those matters that
15
Exhibit B.
16
Copies of the Charter and Standing Orders are attached as Exhibit C and D, respectively.
17
Exhibit C.
18
Exhibit D.
19
Exhibit B.
20
Exhibit C.
21
Exhibit D.
4

have not been resolved at those levels or that involve more than one
administrative unit will become of concern to the Faculty Senate and will fall
under the provisions of this Article.
22

15. The Faculty Senate has standing regarding various issues, including, alleged
violations of faculty rights under faculty, school, and/or department bylaws which
have not been resolved at those levels; conflicts among faculty or between faculty
and administration which jeopardize the integrity of the academic program of the
University; and any other matter over which the Senate has authority under the
Charter or the Bylaws.
23
But, the Standing Order provide that if a party to a
complaint to the Faculty Senate commences a lawsuit or files a complaint with
an outside administrative agency or court involving the same underlying factual
issues, the Faculty Senates involvement in the matter shall terminate.
24

16. UB also maintains a Faculty/Staff Handbook (the Handbook.).
25
The Handbook
provides: The following set of guidelines has been established by the provost in
order to provide guidance concerning the handling of complaints that concern
members of the faculty. It is fully expected that each faculty or school will have
established definitive procedures in this regard that address these issues and
which adhere to these more general guidelines.
26
The Handbook identifies a
process for addressing complaints against faculty.
27
It then provides:
The preceding principles are intended primarily to aid in the prompt and
appropriate disposition of complaints arising out of the day-to-day
22
Id.
23
Exhibit D.
24
Id. at p. 11.
25
A copy of the Faculty Staff Handbook is attached as Exhibit E.
26
Id. at p. 21.
27
Id. at p. 30-31.
5

functioning of the universitys academic programs, and where the
underlying events are not likely to give rise to civil actions or criminal
prosecutions. In cases where the events could lead to a civil proceeding by
or against the State of New York, or its agencies, including the university,
or in cases that are governed by contracts binding on the state or its
agencies, administrative officers of the state must observe their obligations
as officers of the state and refer the matter to proper authorities for
disposition within the applicable legal or contractual framework.
28

C. The UB Law School

17. The Law School likewise maintains bylaws, which serve as the guiding principles
of faculty governance.
29
The By-Laws in effect in 2006 provide: These By-Laws
constitute the regulations for the internal government of the Faculty of Law and
J urisprudence, subject in all cases to the provisions of the Policies of the Board
of Trustees of the State University of New York and the By-Laws of the Faculty
of the State University of New York at Buffalo.
30

18. The 2006 By- Laws established a Committee on Promotion and Tenure.
31
The
2006 By-Laws provided that the Committee on Promotion and Tenure had
jurisdiction over, and the power to make recommendations with respect to
promotion of members of the faculty including the granting of tenure, and
dismissal, or termination of the appointment of members of the
faculty
32
(emphasis added).
19. The Law Schools By-Laws were amended as of April 22, 2008.
33
The 2008 By-
Laws created two standing committees tasked with considering the continued
28
Id. at p. 31.
29
Excerpts of the deposition transcript of Makau Matua are attached hereto as Exhibit F (hereafter
Matua Tr. __). Matua Tr. 94.
30
A copy of the By-Laws in effect in April 2006 is attached as Exhibit G (2006 By-Laws).
31
Id. at p. 7.
32
Id.
33
A copy of the By-Laws that were amended as of April 22, 2008 is attached as Exhibit H (2008 By-
Laws).
6

terms of employment of Law School faculty: the Committee on Promotion and
Tenure and the Committee on Clinical Promotion and Renewal.
34

20. The 2008 By-Laws provided that the Committee on Promotion and Tenure had
jurisdiction over and the power to make recommendations with respect to
promotion, including the granting of tenure, dismissal, or termination of the
appointment of a Faculty Member who is tenured or on a tenure
track
35
(emphasis added).
21. The 2008 By-Laws provided that the Committee on Clinical Promotion and
Renewal had jurisdiction over and power to make recommendations with
respect to promotion, including the granting of an indefinitely renewable long-
term contract, renewal, dismissal, or termination of the appointment of a Faculty
Member who is on an indefinitely renewable long-term contract
36
(emphasis
added).
22. Under the 2008 By-Laws, the Dean of the Law is not required to seek the
facultys recommendation to non-renew Clinical Faculty appointments.
37
Indeed,
Olsen, Matua and even Malkan all testified that recommendations by the
Committee on Promotion and Tenure and the Committee on Clinical Promotion
and Renewal regarding appointments and non-renewals were just that;
recommendations, and that the Dean had the discretion to either accept them or
reject them.
38

34
Id. at p. 7-8.
35
Id. at p. 7.
36
Id. at p. 8.
37
Mutua Tr. 97-98. Excerpts of the deposition transcript of R. Nils Olsen, J r., are attached hereto as
Exhibit I (hereafter Olsen Tr. __). Olsen Tr. 37.
38
Olsen Tr. 36-38; Matua Tr. 96-100; 153-154. Excerpts of the deposition transcript of J effery Malkan are
attached hereto as Exhibit L (hereafter Malkan Tr. __). Malkan Tr. 8-10.
7

23. On October 14, 1994, the Law School adopted policies governing Clinical Faculty
Appointments.
39

D. Malkans Appointment
24. Malkan was hired as Clinical Associate Professor and Director of Research and
Writing beginning with the 2000-2001 academic year.
40
The initial appointment
was for three years.
41
The Directorship was an administrative appointment at the
discretion of the Dean.
42
Malkans faculty appointment was renewed for a second
three-year term.
43

25. Even though Malkans title was Clinical Associate Professor, he never taught a
clinic during his entire time at the Law School.
44
There was no other faculty at the
Law School that held the title of Clinical Associate Professor that did not teach
clinics.
45
The Dean at the time of his hire, R. Nils Olsen, gave him the title of
Clinical Associate Professor because there was no separate appointment provision
for the Director of Research and Writing and to provide him with a longer
contract period than the Research and Writing instructors, who at the time were
on year-to-year term contracts.
46

26. Matua testified that, in his opinion, the category of Clinical Professor had been
used irregularly prior to his deanship.
47
In the case of Malkan, he said that he
considered giving him the title of Clinical Professor when he did not actually
39
A copy of the policies governing Clinical Faculty Appointments is attached as Exhibit J.
40
See appointment letter dated J uly 25, 2000, attached as Exhibit K.
41
Id.
42
Malkan Tr. 37
43
Id.
44
Malkan Tr. 40.
45
Id. at 40-41; Olsen Tr.27.
46
Olsen Tr. 14-16.
47
Matua Tr. 100-103; 111-116; 173-176.
8

teach in the clinics as an attempt to subvert established rule and give him more
job security than that which he was entitled to.
48
He said that when he became
Dean, he discovered other instances of the title Clinical Professor having been
used irregularly, discontinued the practice, and tried to regularize the use of the
title of Clinical Professor so that it comported with the rules.
49

27. On April 28, 2006, a meeting of the Committee on Promotion and Tenure was
convened by Vice Dean for Academics Susan Mangold to consider the promotion
of Malkan from Clinical Associate Professor to full Clinical Professor.
50
Mangold
presided over the meeting because Dean Olsen was out of town attending to his
sick father.
51

28. Prior to the meeting, several faculty members expressed strong opposition to
Malkans promotion and his continued Directorship of the Legal Research and
Writing Program, and questioned what it was the Committee members were being
asked to vote upon.
52

29. There is sharp disagreement regarding what occurred at the meeting and what
exactly the Committee voted on. Malkan and several third party witnesses
deposed in this action claim that a vote was taken on whether the Committee
should recommend to the Dean that he be promoted to full Clinical Professor, and
that the vote was in his favor.
53
Defendant Matua, on the other, recalls that the
meeting quickly devolved to a discussion of whether Malkan should continue as
48
Id. at 100-103.
49
Id. at 101, 173-176.
50
Excerpts of the deposition transcript of Susan Mangold are attached hereto as Exhibit M (hereafter
Mangold Tr. __). Mangold Tr. 11-12.
51
Id. at 12.
52
See memorandum of J ames Gardner and Lucinda Finely to Promotion and Tenure Committee dated
April 3, 2006 and April 5, 2006, respectively, attached as Exhibit N.
53
See Complaint 11-12.
9

Director of the Research and Writing Program, and that a vote was eventually
taken on whether the Committee should recommend that the Dean offer Malkan a
terminal one year appointment, and that vote came out in Malkans favor.
54

30. On August 7, 2006, the UB Presidents Office issued Malkan an appointment letter
which provided: In accordance with Article XI of the Policies of the SUNY Board of
Trustees, I am pleased to offer you an appointment to the position described in the
enclosed document(s).
55
The enclosed document was an Appointment Data Sheet.
56

The Appointment Data Sheet provided that Malkans appointment was a term
appointment from September 1, 2006 to August 31, 2009.
57
Malkan signed the
Appointment Data Sheet on September 21, 2006.
58
The Appointment Data Sheet
stated that the Appointment is made in accordance with the policies of the Board of
Trustees, specifically Article XI, and the rules and regulations which govern such
Appointments in the State University of New York.
59

31. The President sent Malkan a second, substantially similar appointment letter and
Appointment Data Sheet on October 16, 2007.
60
The term of that appointment
likewise ended on August 31, 2009, and was made in accordance with the policies of
the Board of Trustees and regulations which govern such Appointments in the State
University of New York.
61

32. Prior to the P and T Committee meeting on April 28, 2006, Vice Dean Mangold
sought clarification regarding how changes to the ABA Standards regarding term
54
Matua Tr. 27-43.
55
A copy of the appointment letter is attached as Exhibit O.
56
A copy of the Appointment Data Sheet is attached as ExhibitP.
57
Id.
58
Id.
59
Id.
60
A copy of the letter and second Appointment Data Sheet are attached as Exhibit Q.
61
Id.
10

contracts for full time Clinical Professors might impact the Law Schools term
contracts with its clinical faculty. On October 17, 2005, Mangold reached out to
Professor Lucinda Finley, who served as Vice Provost of Faculty Affairs regarding
Malkans promotion.
62
The SUNY Board of Trustees Policies limited term
appointments to three years.
63
But, the American Bar Association, which accredited
the Law School, required full-time, clinical faculty contracts of at least five years.
64

33. Finley contacted J ames J arvis, then-Director of Human Resources.
65
On October 19,
2005 J arvis informed Finley that the limit applied to clinical faculty.
66
J arvis advised
Finley that he would contact Ray Haines, Head of Employee Relations at the SUNY
level, to discuss the issue.
67

34. J arvis and Haines discussed the issue and explored whether there was a way to
accommodate the ABA Standard in light of the limitation on term appointments
imposed by the Trustees Policies.
68
They determined that there was no way for the
Law School to offer clinical faculty five year term appointments under the Trustees
Policies because it would impermissibly create an expectation of a term appointment
beyond three years.
69
This information was conveyed to Finley.
70

35. After the P&T Committee meeting on April 28, 2006, Malkan negotiated a letter
agreement with the Deans Office regarding the terms and conditions of a promotion
to Full Clinical Professor.
71
Malkan proposed various provisions pertaining to job
security that he wanted included in the agreement, including a presumptively
62
See e-mail exchange attached as Exhibit R.
63
Exhibit A, p. 13.
64
Exhibit R.
65
Id.
66
Id.
67
Id. See also J arvis Tr. 42-43
68
J arvis Tr. 43-46.
69
Id.
70
Id. at 47.
71
Malkan Tr. 81-91.
11

renewable five year contract that could only be non-renewed for good cause, with
good cause being defined as the same standard that would justify terminating the
employment of a tenured faculty member.
72

36. At their depositions, neither Olsen nor Mangold admitted to being the primary drafter
and negotiator of the agreement that was ultimately entered into with Malkan, with
each testifying that it was the other that did it.
73
In any event, virtually all of the terms
and conditions that Malkan had proposed including in the agreement regarding job
security ended up in the agreement, including a presumptively renewable five year
contract term that could only be non-renewed for good cause and a provision
providing that a change in the structure or staffing of the Law Schools Research and
Writing Program would not equate to good cause to non-renew.
74

37. The letter agreement was dated October 19, 2006.
75
The letter agreement also
renewed Malkans administrative appointment as Director of the Research and
Writing Program.
76
Malkan signed the letter agreement on November 16, 2006.
77

38. In order to get around the prohibition in Trustees Policies against term appointments
greater than three years, the letter agreement created a fiction that the official contract
term would only be for three years, but that the Dean would routinely a provide an
automatic two year extension at the end of each three year period.
78
Olsen testified at
his deposition that the three-two contact term provision was explicitly meant as an
attempt to get around the SUNY prohibition on term appointments greater than three
72
See e-mail exchanges attached as Exhibit S.
73
Olsen Tr. 11-12, 29; Mangold Tr. 121-127.
74
See letter agreement dated October 19, 2006, attached as Exhibit T.
75
Id.
76
Id.
77
Id.
78
Id.
12

years.
79
Malkan also acknowledged that he was aware of the prohibition in Trustees
Policies against term appointments greater than three years and that the three-two
contact term provision was explicitly intended to get around the Trustees Policies.
80

Neither Malkan nor Olsen knew of any other member of the Law School faculty that
was ever given a term appointment with three-two contact term provision.
81

39. Matua testified that he recalled seeing Malkans letter agreement in his personnel file
shortly after he became interim Dean and being struck by its contents.
82
He said that
he believed it to violate the SUNY Board of Trustees prohibition of term
appointments greater than three years because it essentially gave him a six year
presumptively renewable contract that continued indefinitely.
83
He viewed the letter
agreement as an attempt to grant tenure by other means.
E. MALKANS REMOVAL AS RESEARCH AND WRITING DIRECTOR AND
NON-RENEWAL OF HIS TERM APPOINTMENT

40. Mutua was appointed Interim Dean of the Law School in December 2007. Mutua
identified certain issues that he wanted to address as Interim Dean, including the
admissions process and the Legal Research and Writing Program.
84

41. On March 12, 2008, Mutua asked Malkan to resign as Director of the Legal
Research and Writing program.
85
This was Mutuas polite way of firing Malkan
as Director.
86
This was an administrative appointment and Mutua was not
79
Olsen Tr. 11-16; 29-32.
80
Malkan Tr. 82-86.
81
Id. at 90-91; Olsen Tr. at 32.
82
Matua Tr. 106.
83
Id. at 106-110.
84
Id. at 50
85
Id. at 58-59. See also e-mails attached as Exhibit U.
86
Matua Tr. 59.
13

required to provide Malkan with any reason for his discharge.
87
Malkan continued
to teach at the Law School.
88

42. After Malkans Directorship was terminated, Mutua then appointed another
faculty member, George Kannar, to evaluate and rethink the Legal Research and
Writing Program with input from faculty and to determine how to rebuild the
program.
89
Mutua decided to create a new, professional program with a new
cadre of instructors who would be employed after a national competitive
search.
90
Thus, Mutua issued letters of non-renewal to each Legal Research and
Writing Instructor.
91
On August 28, 2008, he issued such a letter to Malkan.
92

(Tab C: Mutua Dep. 69-71.)
43. Malkans non-renewal letter provided: As you know, the Law School has
terminated the Research and Writing Program such as it was and under which you
were hired as Director and Clinical Professor and is replacing it with the Skills
Program to be headed by a tenured faculty member. The position of Director of
Research and Writing does not now exist. As a result of these changes, I have
given non-renewal notices to all the instructors in the defunct program.
93
(Tab H:
Defendants Ex. 17.) It goes on: I have carefully reviewed the October 19, 2006
letter of appointment issued to you by former Dean Nils R. Olsen. . . . The official
interpretation of ABA Rule 405 states that a clinical professor may be terminated
only for good cause, including termination or material modification of the entire
87
Id. at 60; Malkan Tr. at 96.
88
Matua Tr. at 68.
89
Id. at 69.
90
Id.
91
Id. at 69-70.
92
A copy of Malkans non-renewal letter is attached as Exhibit V.
93
Id.
14

clinical program.
94
The letter also explained that Malkans five-year contract is
not permitted under SUNY Board of Trustees Policies.
95
The letter further
provided that: This official notice of non renewal can be modified only by
explicit withdrawal of it and concurrent notice of further appointment at this
University by the President of the University.
96
Malkan never asked the
President of the University to reverse the non-renewal.
97

44. Mutua testified that he viewed Malkans contract as null and void because it was
written in an attempt to evade SUNY policy in that it was indefinitely renewable
and essentially gave Malkan tenure.
98

45. Following his non-renewal, Malkan took several steps to reverse the decision.
99
He
sent a letter to the entire faculty alleging that Mutua was violating faculty by-laws, he
spoke to several faculty members, and he went to his Union for advice.
100
Malkan
also attempted to speak with Mutua regarding his dismissal at a meeting of the
Academic Policy and Planning Committee meeting.
101

46. Malkan also pursued several additional avenues of redress regarding the non-renewal
of his term appointment: 1) he prompted his union to file an improper practice charge
under his union contract; 2) he filed a claim for breach of contract in the N.Y. Court
of Claims; and, 3) he filed a grievance with the Law Schools Grievance
Committee.
102

94
Id.
95
Id.
96
Id.
97
Malkan Tr. at 100.
98
Matua Tr. at 108-112, 125-126.
99
Malkan Tr. at 100.
100
Id.
101
Id.
102
The details regarding these additional avenues of redress are more fully explained in Defendant Ewings
Statement of Undisputed Facts at 42-59.
15

DATED: Buffalo, New York
J une 6, 2014

ERIC T. SCHNEIDERMAN
Attorney General of the
State of New York
Attorney for Defendants
BY:
s/David J. Sleight
DAVID J . SLEIGHT
Assistant Attorney General
of Counsel
Main Place Tower, Suite 300
Buffalo, New York 14202
(716) 852-6274
David.Sleight@ag.ny.gov

16
CERTIFICATE OF SERVICE

I hereby certify that on J une 7, 2014, I electronically filed the foregoing with the
Clerk of the District Court using its CM/ECF system, which would then electronically
notify the following CM/ECF participants on this case:

Frederic D. Ostrove
Leeds Brown Law, PC
One Old Country Road
Suite 347
Carle Place, New York 11514
rostrove@lmblaw.com

Bryan Arbeit
Leeds Brown Law, PC
One Old Country Road
Suite 347
Carle Place, NY 11514
barbeit@leedsbrownlaw.com

Randolph C. Oppenheimer
Damon Morey LLP
200 Delaware Avenue
Suite 1200
Buffalo, NY 14202
roppenheimer@damonmorey.com

Robert E. Ruggeri
SUNY Office of General Counsel
University Plaza
Albany, NY 12246
robert.ruggeri@suny.edu

J essica M. Baker
SUNY Office of General Counsel
University at Buffalo
3435 Main Street
216 Harriman Hall
Buffalo, NY 14214
jbaker4@buffalo.edu

DATED: Buffalo, New York
J une 6, 2014

17
ERIC T. SCHNEIDERMAN
New York State Attorney General
BY:
S/David J . Sleight
DAVID J . SLEIGHT
Assistant Attorney General
Of Counsel
Main Place Towers
350 Main Street-Suite 300A
Buffalo, New York 14202
(716) 852-6274
david.sleight@ag.ny.gov

18

Mutua Rule 56.1 Statement 6-7-2014

Caricato da

Informazioni sul documento

Copyright

Formati disponibili

Condividi questo documento

Condividi o incorpora il documento

Opzioni di condivisione

Hai trovato utile questo documento?

Questo contenuto è inappropriato?

Copyright:

Formati disponibili

Mutua Rule 56.1 Statement 6-7-2014

Caricato da

Copyright:

Formati disponibili

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF NEW YORK

Potrebbero piacerti anche