Belgrade, March 20th 2006
Barry Lituchy
Jasenovac Research Institute
P.O. Box 10-0674
Brooklyn, New York 11210
CC: David A. Gottfried
CC: United States District Court 50 West 34th Street, Suite 11A13 Eastern District of New York
New York, New York 10001 Civil Action No. 05-CV-3735
(RJD/KAM)
CC: Milo Yelisijevich
Publishing Company “Serbian Classics”
234 E. 14th Street, Apt. 1B
New York, New York 10003
CC: Memory Film Productions
CC: Mr Joseph W. Friendly Mr. Joseph W. Friendly, Producer 203 West 107th Street, # 8A
P.O. Box 250560 Columbia Station New York, New York 10025
New York, New York 10025
Dear Mr. Lituchy,
As duly empowered to act on behalf of participants to the Jasenovac Conference, held in October 1997 at the Kingsborough Community College in Brooklyn, New York, esteemed Mr. Bozo Svarc, Mr. Cadik Danon, Mr. Dragoljub Ackovic, Mr. Josip Erlih, Ms. Mara Vejnovic and Ms. Dr Eta Najfeld, we are, hereby informing you on the following:
All the above named Gentlemen/Ladies did explicitly revoke their non-exclusive license to publish speeches they delivered in October 1997 at Kingsborough Community College about their experiences at the Jasenovac concentration camp, once granted to the Jasenovac Research Institute. Therefore, we must strongly object to the announced release of the book containing the speeches for which you are not authorized, or have any right regarding the speeches, whatsoever.
Moreover, we are also pointing out that none of the above named Gentlemen/Ladies granted permission or any license to Memory Film Productions and/or JRI to use any film footage delivering the speeches in any film they created or intended to create. To the extent that you, Memory Film Productions and/or JRI has created a film which includes such footage, we are requesting that you immediately cease and desist from reproducing, selling, distributing or broadcasting that film.
Further, regarding your Claim for Copyright Infringement against Wanda Schindley a/k/a Dallas Publishing and Kingsborough Community College, we are, hereby, informing you that the esteemed Mr. Bozo Svarc, Mr. Cadik Danon, Mr. Dragoljub Ackovic, Mr. Josip Erlih, Ms. Mara Vejnovic and Ms. Dr Eta Najfeld granted non-exclusive license to Wanda Schindley a/k/a Dallas Publishing and Kingsborough Community College to publish the speeches they delivered at the Conference in October 1997 at Kingsborough Community College. To support Mrs. Schindley’s Motion for Dismissal, we shall provide the Court with the affidavits of the above named Gentlemen/Ladies certifying that the licenses given to the JRI were revoked, and that only Wanda Schindley a/k/a Dallas Publishing and Kingsborough Community College are licensed to publish the speeches delivered at the Conference in 1997.
We fell obligated to emphasize that, in case you proceed with the release of the book disregarding our clients’ free will to rightfully dispose their consent for publication of their own speeches, we shall be forced to take all legal actions at our disposal to protect our clients rights.
In case you do not inform us on the matter within reasonable period of five days, we shall understand that you did not find our arguments acceptable; therefore, we shall proceed with the said actions.
Expecting your prompt response on the matter,
Sincerely,
Marina Gacic, attorney at law
