ESTTA Tracking number:
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`ESTTA1360562
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`Filing date:
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`05/23/2024
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding no.
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`91285651
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`Party
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`Correspondence
`address
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`Submission
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`Filer's name
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`Filer's email
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`Signature
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`Date
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`Defendant
`Metropolitan Area Agency on Aging, Inc.
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`KRISTINE M BOYLAN
`TAFT STETTINIUS & HOLLISTER LLP
`2200 IDS CENTER 80 SOUTH 8TH STREET
`MINNEAPOLIS, MN 55402-2210
`UNITED STATES
`Primary email: KBoylan@taftlaw.com
`Secondary email(s): MBoyle@taftlaw.com
`612-977-8400
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`Motion to Suspend for Civil Action
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`Hannah Fereshtehkhou
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`hfereshtehkhou@taftlaw.com, KBoylan@taftlaw.com, jbalthazor@taftlaw.com
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`/Hannah Fereshtehkhou/
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`05/23/2024
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`Attachments
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`TTAB - Applicants Motion to Suspend.pdf(592209 bytes )
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`TRADEMARK TRIAL AND APPEAL BOARD
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`In the Matter of Trademark Application
`Serial Nos.:
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`90281455, 97579523, and 97579610
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`Applications Filed on:
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`Marks:
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`October 27, 2020 (‘455 Appln.) & September 6,
`2022 (‘523 and ‘610 Applns.)
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`TRELLIS (word), T TRELLIS (design),
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`T TRELLIS (design)
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`Published in the Official Gazette:
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`June 21, 2023 & April 4, 2023
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`Trellis Co.,
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`Opposer,
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`v.
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`Metropolitan Area Agency on Aging, Inc.,
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`Applicant.
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`Opposition No. 91285651
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`APPLICANT’S MOTION TO SUSPEND FOR CIVIL ACTION
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`Pursuant to 37 C.F.R. § 2.117(a), the Board may, in its discretion, suspend a proceeding
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`pending the final determination of a civil action pending between the parties in a federal court.
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`TMBP § 510.02(a).
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`On May 20, 2024, Applicant Metropolitan Area Agency on Aging, Inc. filed a Complaint,
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`attached as Exhibit A, against Opposer Trellis Co. in the District of Minnesota seeking declaratory
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`judgment that Applicant’s mark does not infringe Opposer’s mark and that Opposer’s mark does
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`not have priority.
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`These issues bear on the above-captioned opposition and judicial economy would be served
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`by suspension. Therefore, Applicant respectfully requests that the Board grant its motion to
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`suspend pending the disposition of the federal civil case.
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`Dated: May 23, 2024
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`Respectfully submitted,
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`TAFT STETTINIUS & HOLLISTER LLP
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`/s/ Kristine M. Boylan
`Kristine M. Boylan, Esq. (#0284364)
`O. Joseph Balthazor Jr. (#0399093)
`2200 IDS Center 80 South 8th Street
`Minneapolis, MN 55402-2210
`Telephone: (612) 977-8400
`KBoylan@taftlaw.com
`JBalthazor@taftlaw.com
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`ATTORNEYS FOR APPLICANT
`METROPOLITAN AREA AGENCY ON
`AGING, INC., D/B/A TRELLIS
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`CERTIFICATE OF SERVICE
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`I hereby certify that on May 23, 2024, I caused a true and accurate copy of the foregoing
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`Applicant’s Motion to Suspend for Civil Action to be served via email upon the following party:
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`Nicholas S. Kuhlmann
`Minn. Bar No. #33750X
`Husch Blackwell LLP
`South Eighth Street, Suite 4800
`Minneapolis, MN 55402
`Nick.kuhlmann@huschblackwell.com
`Attorney for Opposer
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`/s/ Kristine M. Boylan
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`EXHIBIT A
`EXHIBIT A
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 1 of 12
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` Court File No.
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`COMPLAINT
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`JURY TRIAL DEMANDED
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`Plaintiff,
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`Defendant.
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`UNITED STATES DISTRICT COURT
`DISTRICT OF MINNESOTA
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`METROPOLITAN AREA
`AGENCY ON AGING, INC.,
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`v.
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`TRELLIS CO.,
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`Plaintiff Metropolitan Area Agency on Aging, Inc. (“Plaintiff”), by
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`and through its undersigned counsel, for its Complaint here against Defend-
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`ant Trellis Co. (“Defendant”) alleges the following:
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`NATURE OF THE ACTION
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`1.
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`This is an action for declaratory judgment arising from Defend-
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`ant’s June 21, 2023 Opposition to Plaintiff’s trademark applications for the
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`wordmark TRELLIS and various T TRELLIS Designs filed in the Trademark
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`Trial and Appeal Board (“TTAB”) at the United States Patent and Trademark
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`Office. Plaintiff disputes Defendant’s claim of ownership of prior rights in
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`Defendant’s alleged TRELLIS trademark (“Defendant’s Mark”) and denies
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`that it has infringed or otherwise violated any rights of Defendant. Plaintiff
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`EXHIBIT A - 1
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 2 of 12
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`seeks a declaration that Defendant owned no cognizable rights in Defend-
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`ant’s Mark as of any date that would give Defendant prior trademark rights,
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`along with an award of attorneys’ fees and costs. Plaintiff seeks a declaration
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`that its conduct does not infringe Defendant’s Mark or constitute unfair
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`competition under the Lanham Act, 15 U.S.C. §§ 1051-1127 or violate Min-
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`nesota law.
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`PARTIES
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`2.
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`Plaintiff Metropolitan Area Agency on Aging, Inc. is a Minne-
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`sota nonprofit corporation having its principal place of business at 1265
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`Grey Fox Road, Suite 2, Arden Hills, Minnesota 55112.
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`3.
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`Defendant Trellis Co. is a Minnesota nonprofit corporation
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`having its principal place of business at 614 North First Street, Suite 100
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`Minneapolis, Minnesota 55401.
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`JURISDICTION AND VENUE
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`4.
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`This action arises under the Declaratory Judgment Act, 28
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`U.S.C. §§ 2201 and 2202, and the trademark laws of the United States, 15
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`U.S.C. §§ 1051-1127.
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`5.
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`This Court has original jurisdiction over the subject matter of
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`this action pursuant to 15 U.S.C. §§ 1121(a), 28 U.S.C. §§ 1331 and 1338(a),
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`and pursuant to the principles of supplemental jurisdiction under 28 U.S.C.
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`§ 1367.
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`EXHIBIT A - 2
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 3 of 12
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`6.
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`Defendant is subject to this Court’s exercise of jurisdiction be-
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`cause of its principal place of business in this state and it has availed itself
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`of the rights and benefits of the laws of Minnesota.
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`7.
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`Venue is proper in this district pursuant to 28 U.S.C. § 1391.
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`FACTS
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`8. With a history going back more than three decades, Plaintiff is
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`a quasi-governmental and non-profit provider of social support services for
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`older adults and their caregivers. Applicant is the manager of the federal
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`Older Americans Act grant program for the seven-county Twin Cities met-
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`ropolitan region
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`9.
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`Defendant is a property development and management com-
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`pany that intended to adopt the TRELLIS name but has no pending federal
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`application or registration for the mark TRELLIS.
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`10. On October 27, 2020, Plaintiff, filed an intent-to-use trademark
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`application at the United States Patent and Trademark Office for TRELLIS,
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`App. No. 90281455 (‘455 Application), for the following services (collec-
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`tively, “Plaintiff’s Services”):
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`INTERNATIONAL CLASS 35: Administration and manage-
`ment of research grants; regulatory submission management,
`namely, assisting others in preparing and filing applications for
`grants with governmental regulatory bodies; business consult-
`ing services to community-based organizations in the field of
`aging on budgeting, service implementation, and program
`evaluation; business support services, namely business plan-
`ning and consulting to community-based organizations in the
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`EXHIBIT A - 3
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 4 of 12
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`field of aging; Writing of grant proposals for older adults and
`their caregivers
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`INTERNATIONAL CLASS 36: Providing financial consultation
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`services to older adults and their caregivers; Provide infor-
`mation and assistance to older adults and their caregivers,
`namely, providing information about medicare insurance plans
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`INTERNATIONAL CLASS 41: Educational services, namely,
`providing educational programs and classes in the field of
`health promotion and aging for older adults; conducting work-
`shops for community-based organizations that serve older
`adults and family caregivers in the field of sustainable business
`practices.
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`11.
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`Plaintiff subsequently filed an Amendment to Allege Use for
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`the ‘455 Application, stating dates of first use on March 16, 2021 for all of
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`Plaintiff’s Services.
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`12.
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`In furtherance of its use of the TRELLIS name, Plaintiff on Sep-
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`tember 6, 2022, Plaintiff filed two trademark applications for two different
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`versions of the mark T TRELLIS and Design (collectively, “Trellis Designs”)
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`as depicted here:
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`EXHIBIT A - 4
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 5 of 12
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`13. As shown above, Plaintiff operates a website using the domain
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`<www.trellisconnects.org>
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`EXHIBIT A - 5
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 6 of 12
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`14.
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`Since March 16, 2021, Plaintiff has extensively used, advertised,
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`and promoted the Trellis Marks.
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`15. On June 21, 2023, Defendant filed a Notice of Opposition with
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`the TTAB, opposing the registration of the Trellis Marks on the ground of
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`likelihood of confusion under Section 2(d) of the Lanham Act, 15 U.S.C.
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`1052(d), with Defendant’s “Trellis Co.” mark, shown below:
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`16.
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`In the Notice of Opposition, Defendant claims priority of use to
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`Plaintiff—based on Defendant’s alleged use of TRELLIS and TRELLIS CO.
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`at common-law with the following design:
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`17. On information and belief, before Plaintiff filed the ‘455 appli-
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`cation on October 27, 2020, Defendant had not used the Trellis name such
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`EXHIBIT A - 6
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 7 of 12
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`that its use of the mark created in the minds of the relevant public an asso-
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`ciation between Defendant’s services and their source. Particularly, before
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`October 27, 2020, Defendant had only used the “Trellis” name internally on
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`an employee handbook, an employee ID card, and employee clothing; it also
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`used it in connection with an employee picnic. Defendant also displayed a
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`“Trellis” name on its website.
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`18. However, not only does Defendant not have priority nor does
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`it render services similar or related to Plaintiff’s Services, additionally De-
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`fendant’s design is not similar to Plaintiff’s designs. A side-by-side compar-
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`ison of the design elements of both, as shown here, shows a strong dissimi-
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`larity:
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`Plaintiff’s Designs
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`Defendant’s Design
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`EXHIBIT A - 7
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 8 of 12
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`19.
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`Further, Defendant’s “Trellis” name is commercially weak,
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`given the amount of marks on the Principal Register containing the term
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`“Trellis.”
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`20. On information and belief, Defendant does not engage in large-
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`scale advertising.
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`21.
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`Plaintiff’s prospective purchasers are sophisticated in that they
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`tend to be older adults (and caregivers) who take time to make decisions
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`about their health and finances. Plaintiff accepts referrals from health plans
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`and healthcare providers, and deploys services via community engagement,
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`grants management, technical assistance, information and assistance, out-
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`reach, education, legal services, resource coordination and Medicare coun-
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`seling
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`22. Defendant has a website.
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`23. On July 28, 2024, Plaintiff answered Defendant’s opposition,
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`and on March 28, 2024, Plaintiff filed a motion for summary judgment with
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`the TTAB. On April 4, 2024, the TTAB suspended the proceedings pending
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`the disposition of Plaintiff’s motion for summary judgment.
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`EXHIBIT A - 8
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 9 of 12
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`24.
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`Based on the foregoing, a justiciable controversy exists between
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`Plaintiff and Defendant as to whether Plaintiff’s conduct constitutes trade-
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`mark infringement, unfair competition under the Lanham Act, unfair com-
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`petition under Minnesota law, and whether Defendant owns valid trade-
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`mark rights in Defendant’s Mark that existed prior to Plaintiff’s priority
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`date.
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`25. An actual controversy exists within the jurisdiction of this
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`Court under 28 U.S.C. §§ 2201 and 2202 regarding the parties rights to the
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`TRELLIS mark.
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`26.
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`In view of Defendant’s allegations, Plaintiff needs and is enti-
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`tled to a judicial declaration that Plaintiff’s conduct does not infringe De-
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`fendant’s alleged trademark rights in Defendant’s Mark or constitute unfair
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`competition, and that Defendant owns no protectable trademark rights in
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`Defendant’s Mark that existed prior to any date on which Plaintiff may rely.
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`Absent a declaration to this effect, Defendant will continue to wrongfully
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`allege that Plaintiff’s Services advertised or sold under the Trellis Marks
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`infringe Defendant’s alleged trademark rights. Defendant’s allegations will
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`have a chilling effect with a negative impact on Plaintiffs charitable fund-
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`raising and social services activities in Minnesota, thereby causing Plaintiff
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`irreparable injury and damage.
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`COUNT 1
`(Declaratory Judgment of Priority)
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`27.
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`Plaintiff incorporates the allegations of all above paragraphs.
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`EXHIBIT A - 9
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 10 of 12
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`28. Defendant cannot establish priority of use of the TRELLIS mark
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`before October 27, 2020.
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`29.
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`Plaintiff has priority of use of the TRELLIS mark.
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`30. A judicial declaration is necessary and appropriate so that
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`Plaintiff may ascertain its right to continue using Plaintiff’s Trellis Marks in
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`connection with Plaintiff’s Services.
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`31.
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`Plaintiff is entitled to a declaratory judgment that Plaintiff’s use
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`of Plaintiff’s Trellis Marks in connection with Plaintiff’s Services is not likely
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`to cause consumer confusion and does not infringe, either directly or indi-
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`rectly, any trademark rights of Defendant under 15 U.S.C. § 1114(1) or 15
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`U.S.C. § 1125(a) because Defendant does not have priority.
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`32.
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`There is no damage to Defendant under 15 USC § 1063.
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`COUNT 2
`(Declaratory Judgment of Non-Infringement)
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`33.
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`Plaintiff incorporates the allegations of all above paragraphs
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`34. As a result of the acts described in the preceding paragraphs,
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`there exists a controversy of sufficient immediacy and reality to warrant the
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`issuance of a declaratory judgment that Plaintiff has not infringed and is not
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`infringing Defendant’s alleged trademark rights in Defendant’s Mark.
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`35. A judicial declaration is necessary and appropriate so that
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`Plaintiff may ascertain its right to continue using Plaintiff’s Trellis Marks in
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`connection with Plaintiff’s Services.
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`EXHIBIT A - 10
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 11 of 12
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`36.
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`Plaintiff is entitled to a declaratory judgment that Plaintiff’s use
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`of Plaintiff’s Trellis Marks in connection with Plaintiff’s Services is not likely
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`to cause consumer confusion and does not infringe, either directly or indi-
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`rectly, any trademark rights of Defendant under 15 U.S.C. § 1114(1) or 15
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`U.S.C. § 1125(a).
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`37.
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`There is no damage to Defendant under 15 USC § 1063.
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`JURY TRIAL DEMANDED
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`38.
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`Plaintiff hereby requests a trial on all issues so triable.
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`REQUEST FOR RELIEF
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`WHEREFORE Plaintiff requests judgment as follows:
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`39. Adjudging that there is no damage to Defendant under 15
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`U.S.C. § 1063 such that the Opposition should not be sustained.
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`a. Adjudging that Plaintiff has not infringed and is not infring-
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`ing, either directly or indirectly, any valid and enforceable
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`trademark rights of Defendant under 15 U.S.C. § 1114(1) or
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`15 U.S.C. § 1125(a);
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`b. Restraining and enjoining Defendant and each of its officers,
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`directors, agents, counsel, servants, employees, and all of
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`persons in active concert or participation with any of them
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`from alleging, representing, or otherwise stating that Plain-
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`tiff’s use of Plaintiff’s the Trellis Marks infringe any rights of
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`Defendant in Defendant’s Mark or constitutes unfair com-
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`petition or is unlawful under Minnesota law;
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`EXHIBIT A - 11
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`CASE 0:24-cv-01854 Doc. 1 Filed 05/20/24 Page 12 of 12
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`c. Declaring Plaintiff the prevailing party and this case as ex-
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`ceptional, and awarding Plaintiff its reasonable attorneys’
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`fees, pursuant to 15 U.S.C. § 1117(a);
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`d. Awarding Plaintiff all fees, expenses, and costs associated
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`with this action; and
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`e. Awarding such other and further relief as this Court deems
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`just and proper.
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`Date: May 20, 2024
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`TAFT STETTINIUS & HOLLISTER LLP
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`s/Kristine M. Boylan
`Kristine M. Boylan (#0284634)
`O. Joseph Balthazor Jr. (#0399093)
`80 South Eighth Street
`2200 IDS Center
`Minneapolis, Minnesota 55402
`612.977.8400
`kboylan@taftlaw.com
`jbalthazor@taftlaw.com
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`Counsel for Metropolitan Area
`Agency on Aging, Inc.
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`EXHIBIT A - 12
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`JS 44 (Rev. 04/21)
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`CASE 0:24-cv-01854 Doc. 1-1 Filed 05/20/24 Page 1 of 1
`CIVIL COVER SHEET
`The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
`provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
`purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
`I. (a) PLAINTIFFS
`DEFENDANTS
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`METROPOLITAN AREA AGENCY ON AGING, INC.
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`TRELLIS CO.
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`(b) County of Residence of First Listed Plaintiff
`(EXCEPT IN U.S. PLAINTIFF CASES)
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`(c) Attorneys (Firm Name, Address, and Telephone Number)
`Kristine Boylan, (612) 977 - 8878
` O. Joseph Balthazor, (612) 977 - 8043
` Taft Stettinius & Hollister LLP,
` 2200 IDS Center, 80 S 8th Street, Minneapolis MN 55402
`II. BASIS OF JURISDICTION (Place an “X” in One Box Only)
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`1 U.S. Government
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`Plaintiff
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`3 Federal Question
`(U.S. Government Not a Party)
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`Hennepin County
`County of Residence of First Listed Defendant
`(IN U.S. PLAINTIFF CASES ONLY)
`IN LAND CONDEMNATION CASES, USE THE LOCATION OF
`THE TRACT OF LAND INVOLVED.
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`NOTE:
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`Attorneys (If Known)
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`III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
`and One Box for Defendant)
`(For Diversity Cases Only)
`PTF
`PTF
`1
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`DEF
`1
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`Incorporated or Principal Place
`of Business In This State
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`DEF
`4
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`4
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`Citizen of This State
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`2 U.S. Government
`Defendant
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`4 Diversity
`(Indicate Citizenship of Parties in Item III)
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`Citizen of Another State
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`IV. NATURE OF SUIT (Place an “X” in One Box Only)
`CONTRACT
`TORTS
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`110 Insurance
`120 Marine
`130 Miller Act
`140 Negotiable Instrument
`150 Recovery of Overpayment
`& Enforcement of Judgment
`151 Medicare Act
`152 Recovery of Defaulted
`Student Loans
`(Excludes Veterans)
`153 Recovery of Overpayment
`of Veteran’s Benefits
`160 Stockholders’ Suits
`190 Other Contract
`195 Contract Product Liability
`196 Franchise
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`REAL PROPERTY
`210 Land Condemnation
`220 Foreclosure
`230 Rent Lease & Ejectment
`240 Torts to Land
`245 Tort Product Liability
`290 All Other Real Property
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`PERSONAL INJURY
`310 Airplane
`315 Airplane Product
`Liability
`320 Assault, Libel &
`Slander
`330 Federal Employers’
`Liability
`340 Marine
`345 Marine Product
`Liability
`350 Motor Vehicle
`355 Motor Vehicle
`Product Liability
`360 Other Personal
`Injury
`362 Personal Injury -
`Medical Malpractice
`CIVIL RIGHTS
`440 Other Civil Rights
`441 Voting
`442 Employment
`443 Housing/
`Accommodations
`445 Amer. w/Disabilities -
`Employment
`446 Amer. w/Disabilities -
`Other
`448 Education
`
`PERSONAL INJURY
`365 Personal Injury -
`Product Liability
`367 Health Care/
`Pharmaceutical
`Personal Injury
`Product Liability
`368 Asbestos Personal
`Injury Product
`Liability
`
`PERSONAL PROPERTY
`370 Other Fraud
`371 Truth in Lending
`380 Other Personal
`Property Damage
`385 Property Damage
`Product Liability
`
`PRISONER PETITIONS
`Habeas Corpus:
`463 Alien Detainee
`510 Motions to Vacate
`Sentence
`530 General
`535 Death Penalty
`Other:
`540 Mandamus & Other
`550 Civil Rights
`555 Prison Condition
`560 Civil Detainee -
`Conditions of
`Confinement
`
`Citizen or Subject of a
`Foreign Country
`
`FORFEITURE/PENALTY
`
`625 Drug Related Seizure
`of Property 21 USC 881
`690 Other
`
`LABOR
`710 Fair Labor Standards
`Act
`720 Labor/Management
`Relations
`740 Railway Labor Act
`751 Family and Medical
`Leave Act
`790 Other Labor Litigation
`791 Employee Retirement
`Income Security Act
`
`IMMIGRATION
`462 Naturalization Application
`465 Other Immigration
`Actions
`
`2
`
`3
`
`2
`
`Incorporated and Principal Place
`of Business In Another State
`
`3
`
`Foreign Nation
`
`5
`
`6
`
`5
`
`6
`
`Click here for: Nature of Suit Code Descriptions.
`BANKRUPTCY
`OTHER STATUTES
`
`422 Appeal 28 USC 158
`423 Withdrawal
`28 USC 157
`
`INTELLECTUAL
`PROPERTY RIGHTS
`
`820 Copyrights
`830 Patent
`835 Patent - Abbreviated
`New Drug Application
`840 Trademark
`880 Defend Trade Secrets
`Act of 2016
`
`SOCIAL SECURITY
`861 HIA (1395ff)
`862 Black Lung (923)
`863 DIWC/DIWW (405(g))
`864 SSID Title XVI
`865 RSI (405(g))
`
`FEDERAL TAX SUITS
`870 Taxes (U.S. Plaintiff
`or Defendant)
`871 IRS—Third Party
`26 USC 7609
`
`375 False Claims Act
`376 Qui Tam (31 USC
`3729(a))
`400 State Reapportionment
`410 Antitrust
`430 Banks and Banking
`450 Commerce
`460 Deportation
`470 Racketeer Influenced and
`Corrupt Organizations
`480 Consumer Credit
`(15 USC 1681 or 1692)
`485 Telephone Consumer
`Protection Act
`490 Cable/Sat TV
`850 Securities/Commodities/
`Exchange
`890 Other Statutory Actions
`891 Agricultural Acts
`893 Environmental Matters
`895 Freedom of Information
`Act
`896 Arbitration
`899 Administrative Procedure
`Act/Review or Appeal of
`Agency Decision
`950 Constitutionality of
`State Statutes
`
`V. ORIGIN (Place an “X” in One Box Only)
`1 Original
`2 Removed from
`Proceeding
`State Court
`
`3 Remanded from
`Appellate Court
`
`4 Reinstated or
`Reopened
`
`5 Transferred from
`Another District
`(specify)
`
`6 Multidistrict
`Litigation -
`Transfer
`
`8 Multidistrict
`Litigation -
`Direct File
`
`VI. CAUSE OF ACTION
`
`Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
`28 U.S.C. §§ 2201, 2202; 15 U.S.C. §§ 1051-1127
`
`Brief description of cause:
`Plaintiff seeks declaratory judgment of priority of its trademark and non-infringement of Defendant's trademark
`
`VII. REQUESTED IN
`COMPLAINT:
`
`VIII. RELATED CASE(S)
` IF ANY
`
`DATE
`5/20/2024
`
`FOR OFFICE USE ONLY
`
`CHECK IF THIS IS A CLASS ACTION
`UNDER RULE 23, F.R.Cv.P.
`
`DEMAND $
`
`CHECK YES only if demanded in complaint:
`
`JURY DEMAND:
`
`Yes
`
`No
`
`(See instructions):
`
`JUDGE
`
`DOCKET NUMBER
`
`SIGNATURE OF ATTORNEY OF RECORD
`
`s/ Kristine M. Boylan
`
`RECEIPT #
`
`AMOUNT
`
`APPLYING IFP
`
`JUDGE
`
`MAG. JUDGE
`EXHIBIT A - 13
`
`