Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 1 of 27

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA __________________________________________ TERI WOODS PUBLISHING, LLC Civil Action No. _______________ 4525 Sansom Street : Philadelphia, PA 19139 : : Jury Trial Demanded and : : TERI WOODS : 4525 Sansom Street : Philadelphia PA 19139 : Plaintiffs, : v. : : DeSEAN WILLIAMS a/k/a : J.M. BENJAMIN a/k/a : JIMMIE BENJAMIN : 125 Church Street : Plainfield, NJ 07060-1312 and : : GASCH PRINTING, .INC. : 1780 Crossroads Drive : Odenton, MD 21113 and : : THE GLOBE PRINTING CO., INC. : 129 W Neshannock Ave # B : New Wilmington, PA 16142 and : : SEABURN PUBLISHING GROUP : 33-18 Broadway : Astoria, New York 11106-1806 and : : URBAN KNOWLEDGE BOOKSTORE, LLC : 1200 Mondawmin Conc, Baltimore, MD 21217, and :

CONTD 1

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 2 of 27

CARL WEBER, d/b/a URBAN KNOWLEDGE BOOKSTORE 1200 Mondawmin Conc. Baltimore MD 21217, AMAZON.COM, INC. 1200 12th Ave. South Ste. 1200. SEATTLE, WA 98144-2734

: : :

: DEFENDANTS. ________________________________________ : CIVIL COMPLAINT Jurisdictions 1. Jurisdiction is vested in this Court by virtue of Title 17 U.S.C. 101-810, to wit, the Copyright Act of 1976. Parties 2. The Plaintiffs, Teri Woods Publishing, LLC and Teri Woods (hereinafter collectively referred to as WOODS), are a domestic limited liability company engaged as a mom-and-pop sort of book publishing company, and a private adult individual, respectively, doing business at the address above-indicated, and they are the rightful and lawful copyright holders of certain literary works, inclusive but not limited to the following books: Dutch I, Dutch II a/k/a Dutch II: Angels Revenge, Dutch III: International Gangster, Deadly Reigns I, Deadly Reigns II, and Deadly Reigns III. Copies of the WOODS Certificates of Registration and U.S. Copyright Office Receipt pertaining to said literary works are attached hereto collectively as Exhibits P-1 through P-6 inclusive, and are incorporated by reference as though fully set forth herein and made a part hereof.

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 3 of 27

3. Subsequent to Woods acquisition of the copyrights to the above-referenced books, there were two (2) illegal, unauthorized books released through the black market, which books were derivative of plaintiffs copyrighted works- to wit, Dutch: The Finale a/k/a Dutch: III and Deadly Reigns: The Next Generation. 4. Defendant DeSEAN WILLIAMS a/k/a J.M. BENJAMIN a/k/a JIMMIE

BENJAMIN (hereinafter WILLIAMS) is adult male individual doing business at the address above-indicated, and is the mastermind behind the unlawful and improper counterfeiting of WOODS copyrighted literary works, engaged in a scheme to unlawfully manufacture, distribute and sell WOODS copyrighted literary works for his own personal gain. 5. Defendants GASCH PRINTING, INC. (GASCH) and THE GLOBE PRINTING CO., INC. (GLOBE) are domestic corporations who are engaged in the manufacturing of, inter alia, books; Upon information and belief, defendants GASCH and GLOBE were hired by defendant WILLIAMS to illegally manufacture bootleg copies of WOODS copyrighted literary works and/or copies of the aforementioned illegal derivative works. 6A. Defendant SEABURN PUBLISHING GROUP (SEABURN) is a publishing company

engaged in the manufacturing, distribution, and/or sale of books; ; Upon information and belief, defendant SEABURN was hired by defendant WILLIAMS to illegally manufacture and/or distribute and/or sell bootleg copies of WOODS copyrighted literary works and/or copies of the aforementioned illegal derivative works. 6B. Defendants URBAN KNOWLEDGE BOOKSTORE, LLC and CARL WEBER

(collectively URBAN KNOWLEDGE), consist of a domestic limited liability company and its principal, respectively, doing business at their respective addresses above-indicated; said 3

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 4 of 27

defendants engaged in the unlawful distribution and/or sale of plaintiffs WOODS copyrighted literary works and or of the aforementioned illegal derivative works. 6c. Defendant AMAZON.COM, INC. (AMAZON) is a domestic company with its headquarters at he above address; defendant AMAZON is, inter alia, the seller of books. 7. At all times material hereto, the defendants acted on their own behalves, or they acted through the deeds of their employees, servants, agents, representatives, and the like, acting within their course of employment and scope of duties. Factual Allegations 8. In 2005, plaintiffs WOODS duly filed with the Library of Congress FORM TX copyright applications for the literary works entitled, Dutch and Dutch II Angels Revenge, and Certificates of Registration were duly issued in plaintiffs favor. Exhibit P-1 and P-2. 9. In 2011 plaintiffs WOODS duly filed with the Library of Congress FORM TX copyright application for the literary work entitled, Dutch III- International Gangster, and Certificate of Registration was duly issued in plaintiffs favor. Exhibit P-3. 10. Plaintiffs WOODS are also the owners of the copyrights to Deadly Reigns a/k/a Deadly Reigns I, Deadly Reigns II and Deadly Reigns III. Exhibit P-4 through P-6. 11. Plaintiffs WOODS are the undisputed copyright claimants in regard to these six (6) literary works. 12. Further, only WOODS possesses the legal right to publish derivative works,

such as sequels, to the above-mentioned six (6) literary works. 13A. In 2011, plaintiff TERI WOODS had a telephone conversation with Jeremy Hess, a principal and/or representative of defendant GASCH, which defendant informed 4

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 5 of 27

plaintiff WOODS that GASCH had been unlawfully printing books in violation of plaintiffs rights; this is the first time that plaintiffs had knowledge that GASCH had been involved in the unlawful violation of plaintiffs copyrights. 13B. During or about March of 2012, plaintiff TERI WOODS was at the

warehouse of defendant SEABURN, when she saw a large box containing Dutch: The Finale books with a shipping label addressed to SEABURN from co-defendant GLOBE; at which time plaintiff first learned that defendants Globe and Seaburn were engaged in the unlawful bootleg manufacturing, distribution and sale of books, in violation of plaintiffs rights, said books being unlawfully manufactured derivative books being inclusive but not necessarily limited to Deadly Reigns: The Next Generation and Dutch:III a/k/a Dutch: The Finale; upon information and belief, WILLAMS has been involved in the unlawful manufacturing, distribution and sale of many thousands of unlawfully manufacturer books, in violation of plaintiffs copyrights; defendant SEABURN enlisted the services of co-defendant GLOBE to print and manufacture certain of these books for SEABURN. 14. Plaintiffs as lawful copyright holders were required to grant permission to

defendants, in writing, failing which defendants were prohibited under the Copyright Act as amended to manufacture, distribute and/or sell any of the aforepleaded illegal books in violation of plaintiffs copyrights. 15. WILLIAMS enlisted the use of co-defendants GASCH, GLOBE and SEABURN to illegally manufacture, distribute and sell many thousands of unlawful, bootlegged books. 16. WILLIAMS further enlisted the use of co-defendants URBAN KNOWLEDGE to 5

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 6 of 27

assist WILLIAMS in the unauthorized and unlawful distribution and sale of plaintiffs WOODS copyrighted literary works. 17. WILLIAMS further enlisted the use of additional individuals and entities, the identities of which are unknown at this time to plaintiffs, but whose identities may become known to plaintiff through discovery, at which time such additional individuals and entities who were also involved in the unlawful manufacturing, distribution and sale of plaintiffs copyrighted literary works shall be named as additional defendants in this case. Claims COUNT I COPYRIGHT INFRINGEMENT: VIOLATION OF TITLE 17 U.S.C. 101-810 (TERI WOODS PUBLISHING, LLC VS. ALL DEFENDANTS) 18. Plaintiff TERI WOODS PUBLISHING, LLC is the lawful and dutiful holder of

certain copyrights pertaining to certain literary works. Exhibit P-1. 19. All defendants violated the Copyright Act of 1976, to wit, Title 17, U.S.C. Secs. 101 et seq., by engaging in the unlawful manufacturing, sale and distribution of plaintiffs protected, copyrighted literary works and illegal derivative sequels. 20. Defendants violations have been repeated numerous times, and are continuous

and ongoing, and outrageous, willful, wanton, malicious, and committed with reckless disregard for the rights of plaintiffs. 21. As a result of defendants infringement, plaintiffs suffered pecuniary damages, as well as damage to its reputation, goodwill, and other damages. 22. Defendants are liable to plaintiffs for unlawful copyright infringement. 6

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 7 of 27

WHEREFORE, on Count I, plaintiff TERI WOODS PUBLISHING, LLC demands judgment in its favor, and against all defendants, jointly and severally, as follows: a. For actual damages in the amount of Ten Million Dollars ($10,000,000.00); b. For statutory damages of Nine Hundred Thousand Dollars ($900,000)- [$150,000 X 6 books] c. For reasonable counsel fees and litigation costs; d. For such other relief as this Court may deem proper. COUNT II COPYRIGHT INFRINGEMENT: VIOLATION OF TITLE 17 U.S.C. 101-810 TERI WOODS VS. ALL DEFENDANTS) 23. 24. Plaintiffs incorporate all paragraphs above as if set forth in full herein. Plaintiff TERI WOODS is the lawful and dutiful holder of certain copyrights

pertaining to her literary works. Exhibit P-1. 25. All defendants violated the Copyright Act of 1976, to wit, Title 17, U.S.C. Secs.

101 et seq., by engaging in the unlawful manufacturing, sale and distribution of plaintiffs protected, copyrighted literary works. 26. Defendants violations were repeated numerous times, and were outrageous,

willful, wanton, malicious, and were committed with reckless disregard for the rights of plaintiffs. 27. As a result of defendants infringement, plaintiffs suffered pecuniary damages, as well as damage to her reputation, goodwill, and other damages. 28. Defendants are liable to plaintiffs for unlawful copyright infringement. 7

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 8 of 27

WHEREFORE, on Count II, plaintiff TERI WOODS demands judgment in her favor, and against all defendants, jointly and severally, as follows: a. For actual damages in the amount of Ten Million Dollars ($10,000,000.00); b. For statutory damages of Nine Hundred Thousand Dollars ($900,000) [$150,000 X 6 books.] c. For reasonable counsel fees and litigation costs; d. For such other relief as this Court may deem proper. COUNT III CIVIL CONSPIRACY (TERI WOODS PUBLISHING, LLC VS. ALL DEFENDANTS) 29. 30. Plaintiffs incorporate all paragraphs above as if set forth in full herein. Defendants WILLIAMS, GASCH, GLOBE, SEABURN, and URBAN

KNOWLEDGE have engaged in a civil conspiracy to deprive plaintiff TERI WOODS PUBLISHING, LLC of its rights. 31. Defendants actions have been outrageous, and have been willful, wanton, malicious,

and were committed with reckless disregard for the rights of plaintiffs. 32. As a result of defendants civil conspiracy, plaintiff TERI WOODS PUBLISHING, LLC has sustained damages in the form of lost profits, lost goodwill, lost prospective business, and other monetary losses. 33. Defendants are liable to plaintiffs for actionable civil conspiracy.

WHEREFORE, on Count III, plaintiff TERI WOODS PUBLISHING, LLC demands judgment in its favor, and against all defendants, jointly and severally, as follows: a. For compensatory damages in the amount of Ten Million Dollars ($10,000,000.00); 8

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 9 of 27

b. For punitive damages for a sum to be determined by the jury at trial; c. For costs of suit and reasonable counsel fees; d. For such other relief as this Court may deem proper COUNT IV - CIVIL CONSPIRACY (TERI WOODS VS. ALL DEFENDANTS) 34. 35. Plaintiffs incorporate all paragraphs above as if set forth in full herein. Defendants WILLIAMS, GASCH, GLOBE, SEABURN and URBAN

KNOWLEDGE have engaged in a civil conspiracy to deprive plaintiff TERI WOODS of her rights. 36. Defendants actions have been outrageous, and have been willful, wanton,

malicious, and were committed with reckless disregard for the rights of plaintiffs. 37. As a result of defendants civil conspiracy, plaintiff TERI WOODS has sustained

damages in the form of lost profits, lost goodwill, lost prospective business, and other monetary losses. 38. Defendants are liable to plaintiffs for actionable civil conspiracy.

WHEREFORE, on Count IV, plaintiff TERI WOODS demands judgment in her favor, and against all defendants, jointly and severally, as follows: a. For compensatory damages in the amount of Ten Million Dollars ($10,000,000.00); b. For punitive damages for a sum to be determined by the jury at trial; c. For costs of suit and reasonable counsel fees; d. For such other relief as this Court may deem proper COUNT V: UNJUST ENRICHMENT 9

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 10 of 27

(TERI WOODS PUBLISHING, LLC VS. ALL DEFENDANTS) 39. 40. Plaintiffs incorporate all paragraphs above as if set forth in full herein. An implied-in-law, quasi-contract existed between plaintiff TERI WOODS

PUBLISHING, LLC and all of the defendants, which provided, in relevant part, that in consideration for defendants use of plaintiffs copyrighted materials for defendants personal gain, albeit without plaintiffs consent, plaintiff shall be entitled to a quantum meruit portion of the monies gained by defendants. 41. Defendants received a monetary benefit, to plaintiffs detriment. 42. Defendants are liable to plaintiff for breach of implied-in-law, quasi-contract, because the defendants have been unjustly enriched at plaintiffs detriment. WHEREFORE, on Count V, plaintiff TERI WOODS PUBLISHING, LLC demands judgment in its favor, and against all defendants, jointly and severally, as follows: a. For compensatory damages in the amount of Ten Million Dollars ($10,000,000.00); b. For costs of suit and reasonable counsel fees; c. For such other relief as this Court may deem proper COUNT VI: UNJUST ENRICHMENT (TERI WOODS VS. ALL DEFENDANTS) 43. Plaintiffs incorporate all paragraphs above as if set forth in full herein. 44. An implied-in-law, quasi-contract existed between plaintiff TERI WOODS and all of the defendants, which provided, in relevant part, that in consideration for defendants use of plaintiffs copyrighted materials for defendants personal gain, albeit without plaintiffs consent, plaintiff shall be entitled to a quantum meruit portion of the monies gained by 10

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 11 of 27

defendants. 45. Defendants received a monetary benefit, to plaintiffs detriment. 46. Defendants are liable to plaintiff for breach of implied-in-law, quasi-contract, because the defendants have been unjustly enriched at plaintiffs detriment. WHEREFORE, on Count V, plaintiff TERI WOODS demands judgment in her favor, and against all defendants, jointly and severally, as follows: a. For compensatory damages in the amount of Ten Million Dollars ($10,000,000.00); b. For costs of suit and reasonable counsel fees; c. For such other relief as this Court may deem proper COUNT VII: ACCOUNTING TERI WOODS PUBLISHING, LLC AND TERI WOODS VS. ALL DEFENDANTS) 47. Plaintiffs incorporate all paragraphs above as if set forth in full herein. 48. Plaintiffs are entitled to a complete accounting from defendants, which accounting shall provide a detailed picture into all pertinent factors, inclusive but not limited to: Identification of All Books Manufactured Identification of All Books Distributed (including to whom and for how much) Identification of All Books Sold (including to whom and for how much) Gross Revenues Gross Sales Such other pertinent information WHEREFORE, on Count VII, plaintiffs TERI WOODS PUBLISHING, LLC and TERI WOODS demand judgment in their favor, and against all defendants, jointly and severally, as 11

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 12 of 27

follows : a. For a full and complete accounting; b. For costs of suit and reasonable counsel fees; c. For such other relief as this Court may deem proper COUNT VIII: CONSTRUCTIVE TRUST (TERI WOODS PUBLISHING, LLC AND TERI WOODS VS. ALL DEFENDANTS) 49. Plaintiffs incorporate all paragraphs above as if set forth in full . 50. Plaintiffs are entitled to the imposition of a constructive trust in plaintiffs favor. WHEREFORE, on Count VIII, plaintiffs TERI WOODS PUBLISHING, LLC and TERI WOODS demand judgment in their favor, and against all defendants, jointly and severally, as follows: a. For imposition of a constructive trust in plaintiffs favor; b. For costs of suit and reasonable counsel fees; c. For such other relief as this Court may deem proper COUNT IX: PERMANENT INJUNCTION (TERI WOODS PUBLISHING LLC AND TERI WOODS VS. ALL DEFENDANTS) 51. Plaintiffs incorporate all paragraphs above as if set forth in full . 52. Plaintiffs are entitled to the imposition of a permanent injunction in their favor, and

against defendants, thereby barring defendants from forevermore engaging in any manner in the manufacture, distribution, and/or sale of any of plaintiffs copyrighted materials. 53. Plaintiffs seek a bond from defendants to ensure that plaintiffs rights shall nevermore be violated. 12

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 13 of 27

WHEREFORE, on Count IX, plaintiffs TERI WOODS PUBLISHING, LLC and TERI WOODS demand judgment in their favor, and against all defendants, jointly and severally, as follows: a. For imposition of a permanent injunction against all defendants, with the proviso that defendants post a bond as security to attempt to ensure that plaintiffs rights will not be violated in the future; b. For costs of suit and reasonable counsel fees; c. For such other relief as this Court may deem proper COUNT X: VIOLATION OF N.J. RICO STATUTE N.J.S.A. Sec. 2C:41-1 ET SEQ. (TERI WOODS VS. ALL DEFENDANTS) 54. Plaintiffs incorporate all paragraphs above as if set forth in full . 55. Defendants, through their conduct, engaged in a pattern of racketeering activity with the specific purpose of defrauding plaintiffs by their enterprise. 56. Defendants by their conduct participated, directly or indirectly, in the enterprises affairs. 57. Furthermore, defendants by their conduct, so participated in the enterprises affairs with knowledge that someone associated with the enterprise- inclusive but not necessarily limited to the co-defendants- will commit at least two (2) predicate acts. 58. Prior to fleecing plaintiff, defendants Benjamin et al. had several communications in furtherance of the enterprise to defraud plaintiffs with the other co-defendants. 59. Defendants engaged in multiple steps in order to manufacture, distribute and sell 13

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 14 of 27

plaintiffs books, inclusive but not limited to: illegally and unlawfully duplicating the books; presenting the books to a printing company for mass unlawful duplication, counterfeiting and copyright infringement; illegally transporting the counterfeit books; illegally distributing the counterfeit books to an underground black market network of booksellers; illegally and unlawfully attempting to hold these books to be authentic as if original; in otherwise engaging in unlawful racketeering actions. 60. Accordingly, all defendants are liable to plaintiff, jointly and severally, under N.J.s civil RICO Statute. WHEREFORE, on Count X, plaintiff TERI WOODS demands judgment in her favor, and against all defendants, jointly and severally, as follows 1. Compensatory damages for a sum to be proven at trial; 2. Treble damages; 3. Reasonable counsel fees, costs and interest; 4. Such other and further relief as this Court may deem proper.

COUNT XI: VIOLATION OF N.J. RICO STATUTE N.J.S.A. Sec. 2C:41-1 ET SEQ. (TERI WOODS PUBLISHING LLC VS. ALL DEFENDANTS) 61. Plaintiffs incorporate all paragraphs above as if set forth in full . 62. Defendants, through their conduct, engaged in a pattern of racketeering activity with the specific purpose of defrauding plaintiffs by their enterprise. 63. Defendants by their conduct participated, directly or indirectly, in the enterprises 14

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 15 of 27

affairs. 64 . Furthermore, defendants by their conduct, so participated in the enterprises affairs with knowledge that someone associated with the enterprise- inclusive but not necessarily limited to the co-defendants-will commit at least two (2) predicate acts. 65. Prior to fleecing plaintiff, defendants Benjamin et al. had several communications in

furtherance of the enterprise to defraud plaintiffs with the other co-defendants. 66. Defendants engaged in multiple steps in order to manufacture, distribute and sell plaintiffs books, inclusive but not limited to: illegally and unlawfully duplicating the books; presenting the books to a printing company for mass unlawful duplication, counterfeiting and copyright infringement; illegally transporting the counterfeit books; illegally distributing the counterfeit books to an underground black market network of booksellers; illegally and unlawfully attempting to hold these books to be authentic as if original; in otherwise engaging in unlawful racketeering actions. 67. Accordingly, all defendants are liable to plaintiff, jointly and severally, under N.J.s civil RICO Statute. WHEREFORE, on Count XI, plaintiff TERI WOODS PUBLISHING, LLC demands judgment in its favor, and against all defendants, jointly and severally, as follows 1. Compensatory damages for a sum to be proven at trial; 2. Treble damages; 3. Reasonable counsel fees, costs and interest; 4. Such other and further relief as this Court may deem proper. COUNT XII: INVASION OF PRIVACY (FALSE LIGHT) 15

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 16 of 27

(TERI WOODS VS. ALL DEFENDANTS) 68. Plaintiffs incorporate all paragraphs above as if set forth in full . 69. Defendants presented TERI WOODS in a false light, thereby invading her privacy, by manufacturing inferior quality books, by altering the books so as to present an inferior, diminished product, and by misrepresenting these books to be a bona fide, authentic book by plaintiff. 70. The above-stated conduct constitutes actionable invasion of privacy, by presenting plaintiff in an inferior and false light. WHEREFORE, on Count XII, plaintiff TERI WOODS demands judgment in her favor, and against all defendants, jointly and severally, as follows 1. Compensatory damages for a sum to be proven at trial; 2. Treble damages; 3. Reasonable counsel fees, costs and interest; 4. Such other and further relief as this Court may deem proper. COUNT XIII: INVASION OF PRIVACY- FALSE LIGHT TERI WOODS PUBLISHING LLC VS. ALL DEFENDANTS) 71. Plaintiffs incorporate all paragraphs above as if set forth in full . 72. Defendants presented TERI WOODS PUBLISHING, LLC in a false light, thereby invading her privacy, by manufacturing inferior quality books, by altering the books so as to present an inferior and diminished product, and by misrepresenting these books to be a bona fide, authentic book by plaintiff. 73. The above-stated conduct constitutes actionable invasion of privacy, by presenting 16

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 17 of 27

plaintiff in an inferior and false light. WHEREFORE, on Count XIII, plaintiff TERI WOODS PUBLISHING, LLC demands judgment in its favor, and against all defendants, jointly and severally, as follows 1. Compensatory damages for a sum to be proven at trial; 2. Treble damages; 3. Reasonable counsel fees, costs and interest; 4. Such other and further relief as this Court may deem proper. COUNT XIV: STATE CIVIL RIGHTS VIOLATIONS (TERI WOODS VS. ALL DEFENDANTS) 74. Plaintiffs incorporate all paragraphs above as if set forth in full . 75. Defendants conduct as aforepleaded acted to deprive plaintiff TERI WOODS of her civil rights as assured under the New Jersey Constitution. 76. Such civil rights violations are inclusive but not limited to plaintiffs right to gainful employment, her right to earn a living, and her right to privacy. 77. Defendants are liable to plaintiff for deprivation of her civil rights as guaranteed by the New Jersey Constitution. WHEREFORE, on Count XIV, plaintiff TERI WOODS demands judgment in her favor, and against all defendants, jointly and severally, as follows 1. Compensatory damages for a sum to be proven at trial; 2. Treble damages and statutory damages; 3. Reasonable counsel fees, costs and interest; 4. Such other and further relief as this Court may deem proper. 17

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 18 of 27

REQUEST FOR RELIEF WHEREFORE, Plaintiffs further request the following relief: a. The relief set forth in each of the above stated causes of action; and b. Such other relief at law or equity as this Court deems just.

Respectfully submitted,

Dated: August 23, 2012

/Simon Rosen, Esquire/ (#6279) Attorney I.D. #38603

LAW OFFICE OF SIMON ROSEN 1760 Market Street, Suite 600 Philadelphia, PA 19103 Tel. (215)564-0212 Fax (215)972-5390 [email protected]

18

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 19 of 27

Public Catalog Copyright Catalog (1978 to present) Search Request: Left Anchored Name = Woods Teri Search Results: Displaying 9 of 15 entries -------------------------------------------------------------------------------Dutch. Type of Work: Text Registration Number / Date: TX0006125969 / 2005-02-08 Title: Dutch. Notes: Cataloged from appl. only. Copyright Claimant: Teri Woods Publishing Date of Creation: 2002 Date of Publication: 2003-11-15 Authorship on Application: Kwame Teague, 1972- (Dutch, pseud.) & Teri Woods, 1968-. Previous Registration: Prev. reg. 2003, TXu 1-100-936. Names: Teague, Kwame, 1972Woods, Teri, 1968Teri Woods Publishing Dutch, pseud.

Save, Print and Email (Help Page) Select Download Format Full Record Report 1 Latin1 MARC Enter your email address:

-------------------------------------------------------------------------------Help Search History Titles Start Over -------------------------------------------------------------------------------Contact Us | Request Copies | Get a Search Estimate | Frequently Asked Questions (FAQs) about Copyright | Copyright Office Home Page | Library of Congress Home Page

EXHIBIT P-1 19

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 20 of 27

Public Catalog
Copyright Catalog (1978 to present) Search Request: Left Anchored Name = Woods Teri Search Results: Displaying 10 of 15 entries

Dutch II : Angel's revenge : the second of a trilogy.

Type of Work: Text Registration Number / Date: TXu001200973 / 2005-02-02 Title: Dutch II : Angels revenge : the second of a trilogy. Description: 269 p. Notes: Fiction. Copyright Claimant: Teri Woods, 1968Date of Creation: 2005 Authorship on Application: Terri Woods & Kwame Teague, 1972- (Dutch, pseud.) Variant title: Dutch II : Angels revenge Names: Woods, Teri, 1968Teague, Kwame, 1972Dutch, pseud.

EXHIBIT P-2

20

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 21 of 27

Public Catalog
Copyright Catalog (1978 to present) Search Request: Left Anchored Name = Woods Teri Search Results: Displaying 11 of 15 entries

Dutch III-International Gangster.

Type of Work: Text Registration Number / Date: TXu001726014 / 2011-03-01 Application Title: Dutch III-International Gangster. Title: Dutch III-International Gangster. Description: Print material,. Copyright Claimant: Teri Woods, 1968- . Address: 816 Undercliff Avenue, Edgewater, NJ, 07020, United States. Date of Creation: 2010 Authorship on Application: Teri Woods, 1968- ; Domicile: United States; Citizenship: United States. Authorship: text. Rights and Permissions: Teri Woods, 816 Undercliff Avenue, Edgewater, NJ, 07020, United States, (201) 969-4830, [email protected] Names: Woods, Teri, 1968-

Save, Print and Email (Help Page) Select Download Format Enter your email address: EXHIBIT P-3 21
Full Record

Format for Print/Save

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 22 of 27

EXHIBIT P-4

22

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 23 of 27

EXHIBIT P-4 23

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 24 of 27

EXHIBIT P-5 24

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 25 of 27

EXHIBIT P-5 25

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 26 of 27

EXHIBIT P-6 26

Case 2:12-cv-04854-RK Document 1 Filed 08/23/12 Page 27 of 27

EXHIBIT P-6 27