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I. INTRODUCTION
1.(a) Defendant Wanda Schindley a/k/a Dallas Publishing Company was sued for copyright infringement for publishing Jasenovac: Proceedings of the First International Conference and Exhibit on the Jasenovac Concentration Camps [hereafter, the Book], a document containing the proceedings of the historic 1997 conference, hosted by Dr. Bernard Klein, Chair of the Department of History, Philosophy, and Political Science at Kingsborough College and Copyright holder of the Book, with assistance from Dr. Milan Bulajic, then Director of the Museum for Genocide Research in Belgrade who brought the Exhibit of authentic artifacts and photographs to Kingsborough College and who coordinated with survivors in Belgrade to solicit their travel and testimony for the conference, raised funds for their transportation and for translations of their texts, and was a key speaker at the conference. (b) Petar Makara was jointly sued with Wanda Schindley a/k/a Dallas Publishing but is not and has never been a copyright holder of the Book or a partner, an officer or member of a board, or an employee of Dallas Publishing Company, which has existed since 1985 as a sole proprietorship of Wanda Schindley.
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