Motion to Stay Proceedings in Arjuna C Fernando v. Karen Ellemann, Thorkil Juul, Jan Henriksen, Lise Beder, Lene Conrad, Henrik Horster, Nini Christensen, Helle Haxgart, Jette Rogild, Annette Gregersen, Julie Bronden-Wijngaard, Andrea Jedrzejwska, Lone Buhl, Louise Brydov| Trellis.Law

On November 16, 2016 a Motion-Secondary was filed involving a dispute between Arjuna C Fernando, and Andrea Jedrzejwska, Annette Gregersen, Helle Haxgart, Henrik Horster, Jan Henriksen, Jette Rogild, Julie Bronden-Wijngaard, Karen Ellemann, Lene Conrad, Lise Beder, Lone Buhl, Louise Brydov, Nini Christensen, Thorkil Juul, for Torts - Other (NYPL 260.10) in the District Court of New York County.

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
---------------------------------------------------------------x
:
ARJUNA C. FERNANDO, :
:
Petitioner, :
:
-against- : I.A.S. Part to be assigned
:
KAREN ELLEMANN, THORKIL JUUL, JAN : Index No. 159641/2016
HENRIKSEN, MERETE PANTMANN, LISE :
GRY BEDER, LENE CONRAD, HENRIK : Motion Seq. No. 001
HORSTER, NINI CHRISTENSEN, HELLE :
HAXGART, JETTE RØGILD, ANNETTE :
GREGERSEN, JULIE BRØNDEN WIJNGAARD, :
ANDREA JEDRZEJOSKA, LONE BUHL, AND :
LOUISE BRYDOV, :
:
Respondents. :
:
---------------------------------------------------------------x

PROPOSED INTERVENORS’ MEMORANDUM OF LAW IN SUPPORT OF
THEIR MOTION TO INTERVENE AND TO STAY THE PROCEEDINGS

Dated: New York, New York
January 30, 2017

DUANE MORRIS LLP
1540 Broadway
New York, New York 10036-4086
(212) 692-1000

Attorneys for Proposed Intervenors
Danish Ministry for Children and Social Affairs
and the Danish National Social Appeals Board

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TABLE OF CONTENTS

Page

TABLE OF AUTHORITIES .......................................................................................................... ii

PRELIMINARY STATEMENT .....................................................................................................1

STATEMENT OF FACTS ..............................................................................................................3

ARGUMENT ...................................................................................................................................6

a. This Court Should Permit Proposed Intervenors to Intervene as a Matter of
Right As the Real Parties In Interest ....................................................................... 6

b. This Court Should Allow Proposed Intervenors to Intervene on a
Permissive Basis ..................................................................................................... 8

c. This Court Should Allow Stay The Proceedings Pursuant to C.P.L.R. 2201
Until This Application To Intervene Is Decided..................................................... 9

CONCLUSION ..............................................................................................................................10

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TABLE OF AUTHORITIES

Cases

Berkoski v. Bd. of Trustees of Incorporated Village of Southampton,
67 A.D.3d 840, 889 N.Y.S.2d 623 (2d Dep’t 2009) ..................................................................8

Gen. Ins. Co. of Am. v. Tilcon N.Y., Inc.,
1996 WL 389265 (S.D.N.Y. July 11, 1996) ..............................................................................3

Israel v. Wood Dolson Co.,
1 N.Y.2d 116, 151 N.Y.S.2d 1 (1956) .......................................................................................6

Lamboy v. Gross, 129 Misc. 2d 564, 493 N.Y.S.2d 709 (Sup. Ct. N.Y. Co. 1985),
aff’d, 126 A.D.2d 265, 513 N.Y.S.2d 393 (1st Dep’t 1987) ......................................................8

Odhiambo v. Republic of Kenya, 930 F. Supp. 2d 17 (D.D.C. 2013), aff’d, 764
F.3d 31 (D.C. Cir. 2014), cert. denied, 136 S. Ct. 2504 (U.S. 2016) ........................................7

Research Corp. v. Singer-Gen. Precision, Inc.,
36 A.D.2d 987, 320 N.Y.S.2d 818 (3d Dep’t 1971) ..................................................................9

Samantar v. Yousuf, 560 U.S. 305 (2010) .......................................................................................7

Smith Rocke Ltd. v. Republica Bolivariana de Venezuela, No. 12 Cv. 7316 (LGS),
2014 WL 288705 (S.D.N.Y. Jan. 27, 2014) ..............................................................................7

St. Joseph’s Hosp. Health Ctr. v. Dep’t of Health,
224 A.D.2d 1008, 637 N.Y.S.2d 821 (4th Dep’t 1996) .............................................................8

Teleprompter Manhattan CATV Corp. v. State Bd. of Equalization & Assessment,
34 A.D.2d 1033, 311 N.Y.S.2d 46 (3d Dep’t 1970) ..................................................................6

United Servs. Auto. Ass’n v. Graham,
21 A.D.2d 657, 249 N.Y.S.2d 788 (1st Dep’t 1964) .................................................................8

Vantage Petroleum v. Bd. of Assessment Review of the Town of Babylon, 61
N.Y.2d 695 (1984) .....................................................................................................................6

Yuppie Puppy Pet Prod., Inc. v. St. Smart Realty, LLC, 77 A.D.3d 197, 906
N.Y.S.2d 231 (1st Dep’t 2010) ..................................................................................................8

Zonghetti v. Jeromack,
150 A.D.2d 561, 541 N.Y.S.2d 235 (2d Dep’t 1989) ................................................................9

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Statutes and Rules

28 U.S.C. § 1602 ..............................................................................................................................2

C.P.L.R. 103(c) ................................................................................................................................1

C.P.L.R. 1012(a) ........................................................................................................................1, 10

C.P.L.R. 1012(a)(2) .........................................................................................................................6

C.P.L.R. 1013.........................................................................................................................1, 8, 10

C.P.L.R. 2201...........................................................................................................................1, 3, 9

New York Penal Law § 260.10(1) ...............................................................................................1, 4

New York Penal Law § 260.10(2) ...............................................................................................1, 4

iii

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The Danish Ministry for Children and Social Affairs (the “Ministry”) and the Danish

National Social Appeals Board (the “Appeals Board”) (collectively, the “Proposed Intervenors”),

by and through their undersigned counsel, Duane Morris LLP, respectfully submit this

Memorandum of Law, along with the accompanying Affirmation of Jane Vinther dated January

30, 2017 (the “Vinther Affirmation”); the Affirmation of Evangelos Michailidis dated January

30, 2017, together with exhibits annexed thereto (the “Michailidis Affirmation”); and the

Emergency Affirmation of Evangelos Michailidis dated January 30, 2017 (“Michailidis

Emergency Affirmation”) in support of their ex parte motion for an Order: (1) pursuant to

C.P.L.R. 1012(a) and 1013 granting Proposed Intervenors leave to intervene as the real parties in

interest in place of the named defendants Karen Ellemann, Thorkil Juul, Jan Henriksen, Merete

Pantmann, Lise Gry Beder, Lene Conrad, Henrik Horster, Nini Christensen, Helle Haxgart, Jette

Røgild, Anette Gregersen, Julie Brønden Wijngaard, Andrea Jedrzejoska, Lone Buhl, and Louise

Brydov (collectively, the “Foreign Official Defendants”); and (2) pursuant to C.P.L.R. 2201

staying this action as against the Foreign Official Defendants.

PRELIMINARY STATEMENT

Plaintiff pro se Arjuna Fernando (“Plaintiff Pro Se”) filed his Petition with this Court on

November 16, 2016 against the Foreign Official Defendants, all of whom are current and former

officials of the Ministry or the Appeals Board, which are agencies and/or instrumentalities of the

Kingdom of Denmark, alleging that they violated New York Penal Law §§ 260.10(1) and

260.10(2) by denying him visitation and custody of his daughter, who is also a resident in

Denmark.1 Setting aside the issue of whether Plaintiff Pro Se can bring a civil suit in New York

1
Although denominated as a Petition, the pro se pleading should in actuality be construed as a
Complaint. See C.P.L.R. 103(c). Consequently, Proposed Intervenors refer to Mr. Fernando as

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state court for alleged violations of New York’s criminal statutes against Danish governmental

officials, the allegations set forth in the Petition relate solely to the actions of Foreign Official

Defendants in their official capacity as current and former officials of agencies and

instrumentalities of the Danish Government. As a result, any determination rendered in this case

would necessarily implicate the interests of the Kingdom of Denmark, including its immunity

from suit in the United States, as well as the concomitant immunity of its governmental officials

and employees.

As such, Proposed Intervenors seek leave of this Court to intervene in order to protect

their sovereign interests, as well as those of its officials and employees. Once leave is granted,

Proposed Intervenors intend to remove this case to the United States District Court for the

Southern District of New York under Foreign Sovereign Immunities Act, 28 U.S.C. § 1602 et

seq. (the “FSIA”). Under that statute, Plaintiff Pro Se’s claims are subject to dismissal for lack

of subject matter jurisdiction. The Petition is subject to dismissal on numerous other bases, all of

which will be addressed in the appropriate federal forum once this case is timely removed to that

court.

In addition to foreign sovereign immunity and foreign official immunity, among the other

bases for dismissal that Proposed Intervenors intend to raise in federal court is that Plaintiff Pro

Se is collaterally estopped from bringing the claims in his Petition. In three separate cases, the

federal courts have dismissed nearly identical claims brought by Plaintiff Pro Se’s claims against

Danish government officials, including many of the Foreign Official Defendants named in the

instant Petition. At bottom, Plaintiff Pro Se is engaged in a campaign of serial litigation against

“Plaintiff Pro Se” and the Danish officials named as respondents as “Foreign Official
Defendants.”

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Danish government officials in United States federal court and seeking to game the system by

shifting the individuals named in this case in an unavailing attempt to evade the preclusive effect

of the earlier dismissals. Indeed, Plaintiff Pro Se implicitly acknowledges as much in his

Petition, in which he contends that “Collateral Estoppel is also not applicable to any of the

Respondents listed in this Petition, because New York State, where this suit is filed against

Respondents by Petitioner, is a sovereign State within the United States of America.” (Pet. ¶ 7.)

Consequently, intervention is necessary so that the Danish Government can seek appropriate

relief to ensure that Plaintiff Pro Se’s misuse of the United States courts comes to an end.

Additionally, a stay of this action is appropriate as to the Foreign Official Defendants

pursuant to C.P.L.R. 2201 who are immune from suit for the alleged actions taken in their

official capacities as current and former officials of the Danish Government.

Proposed Intervenors respectfully request that this Court grant them leave to intervene as

the real parties in interest in place of the Foreign Official Defendants and stay this action as

against the Foreign Official Defendants.2

STATEMENT OF FACTS3

In the Petition, Plaintiff Pro Se, a resident of Denmark, alleges that the Foreign Official

Defendants, all of whom are current and former officials of agencies and/or instrumentalities of

2
This matter is time sensitive because certain authority suggests that Proposed Intervenors’
thirty-day period within which to remove this case to federal court begins to run from the date of
this application. See Gen. Ins. Co. of Am. v. Tilcon N.Y., Inc., 1996 WL 389265, at *1 (S.D.N.Y.
July 11, 1996) (“Courts confronting the special issue of the timeliness of removal by an
intervener rather than a defendant have held that the thirty day statutory periods begins to run
either on the date an intervention petition is filed in the state court from which removal is sought
or on the date the state court grants the motion to intervene.”) (emphases added). (Michailidis
Emergency Aff. ¶ 7.)
3
Proposed Intervenors hereby incorporate the facts set forth in the accompanying Vinther
Affirmation and Michailidis Affirmation.

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the Danish Government, violated New York Penal Law §§ 260.10(1) and 260.10(2) by denying

him visitation and custody of his daughter, who is also a resident in Denmark. (Michailidis Aff.

¶ 4 & Ex. A.)

Each of the Foreign Official Defendants is a current or former officer or employee of an

agency or instrumentality of the Kingdom of Denmark. (Vinther Aff. ¶¶ 4-19; Michailidis Aff.

¶¶ 4-5.)

Although the caption of the Petition names the Foreign Official Defendants “in their

official and individual capacities,” the allegations set forth in Plaintiff Pro Se’s Petition relate

solely to actions claimed to have been taken by the Foreign Official Defendants in their official

capacity as officers and employees of the various agencies and instrumentalities of the Danish

government. (Michailidis Aff. ¶ 5 & Ex. A, Pet. ¶¶ 10-21.)

For example, in his Petition, Plaintiff Pro Se contends that this Court has jurisdiction over

his claims because “[t]he Government of Denmark, whom Respondents are employed by,

transacts business and provides services within New York State and uses and possesses real

property situated within New York State to conduct business and to provide the services.”

(Michailidis Aff. ¶ 6 & Ex. A, Pet. ¶ 3.)

Further, Plaintiff Pro Se makes unsubstantiated and false allegations against the Danish

Government such as the following: “any case that involves foreign nationals, including

American citizens, such as Petitioner and his daughter SK, that is handled by Danish

Government officials and their employees, such as Respondents, the civil rights of foreign

nationals in Denmark will be wil[l]fully and flagrantly violated with impunity.” (Michailidis

Aff. ¶ 7 & Ex. A, Pet. ¶ 26.)

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An immediate stay of the instant action is of particular importance in light of the issues of

sovereign immunity implicated by the pro se Petition. Proposed Intervenors assert foreign

sovereign immunity, and seek leave to intervene – whether as a matter of right or on a permissive

basis – as the real parties in interest for the purpose of removing the instant action to the United

States District Court for the Southern District of New York. In addition, the Proposed

Intervenors assert foreign official immunity on behalf of the Foreign Official Defendants.

(Michailidis Aff. ¶ 9.)

A stay of this action is also warranted because Plaintiff Pro Se has engaged in a campaign

of serial litigation in United States federal courts concerning his child custody proceeding in

Denmark against various Danish officials. In each of three federal cases, the courts have

dismissed his claims, and two of those rulings were affirmed on appeal. (Michailidis Aff. ¶ 10 &

Ex. B.) Despite the preclusive effect of those courts’ rulings, Plaintiff Pro Se is seeking to game

the system by effectively rehashing his earlier dismissed claims, by filing with this Court and

naming different Danish government officials as parties. (See id. Ex. B.)

Indeed, the pro se Petition tacitly acknowledges that Plaintiff Pro Se’s claims in this

action are subject to attack based on collateral estoppel. Plaintiff Pro Se alleges as follows:

Collateral Estoppel is also not applicable to any of the Respondents
listed in this Petition, because New York State, where this suit is
filed against Respondents by Petitioner, is a sovereign State within
the United States of America. Therefore, any civil or criminal action
taken against Respondents, together or individually, in a court of law
of the State of New York can be adjudicated, irrespective of whether
civil action has been initiated against any of the Respondents in a
U.S. Federal Court.”).

(Michailidis Aff. ¶ 11 & Ex. A, Pet. ¶ 7.)

Once the action is removed to federal court, the Proposed Intervenors intend to move to

dismiss the action based on lack of subject matter jurisdiction pursuant to the FSIA, as well as

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several other bases, including, but not limited to: (1) collateral estoppel; (2) lack of personal

jurisdiction; (3) improper venue; (4) insufficient service of process; and (5) failure to state a

claim upon which relief can be granted. In addition, in light of Plaintiff Pro Se’s serial filings,

Proposed Intervenors intend to seek relief from the federal court in the form of an order

enjoining him from filing additional suits against Danish government officials in United States

courts based on his custody dispute in Denmark. (Michailidis Aff. ¶ 12.)

ARGUMENT

THIS COURT SHOULD GRANT LEAVE TO INTERVENE AND STAY THE
CURRENT PROCEEDINGS AS AGAINST THE FOREIGN OFFICIAL DEFENDANTS

a. This Court Should Permit Proposed Intervenors
to Intervene as a Matter of Right As the Real Parties In Interest

A nonparty may intervene as a matter of right “when the representation of the person’s

interest by the parties is or may be inadequate and the person is or may be bound by the

judgment.” See C.P.L.R. 1012(a)(2). Whether a person seeking intervention will be bound by

the judgment is determined by its res judicata effect. See Vantage Petroleum v. Bd. of

Assessment Review of the Town of Babylon, 61 N.Y.2d 695, 698 (1984). The circumstances in

which the principles of res judicata can bind a person who is not a party to an action are few in

number. However, a finding of “privity” between one of the parties and the person to be bound

is required. See Israel v. Wood Dolson Co., 1 N.Y.2d 116, 119, 151 N.Y.S.2d 1, 3-4 (1956) (“In

such situations when the complaining party has been given a full opportunity to litigate those

issues against one of the parties, and has been defeated on grounds other than a personal defense,

he is not permitted to relitigate the same issue in a new action against the other.”); see also

Teleprompter Manhattan CATV Corp. v. State Bd. of Equalization & Assessment, 34 A.D.2d

1033, 1034, 311 N.Y.S.2d 46, 47 (3d Dep’t 1970) (holding that the city, as the real party in

interest, had the right to intervene in challenging the Board’s assessment).

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As such, Proposed Intervenors – while asserting their foreign sovereign immunity – seek

leave to intervene, whether as a matter of right or on a permissive basis, as the real parties in

interest for the purpose of removing the instant action to federal court. The interests of the

Proposed Intervenors are not adequately represented in the instant action and they are required to

defray the costs of the Foreign Official Defendants’ defense in this action given that the

allegations in the pro se Petition pertain solely to the alleged actions of the Foreign Official

Defendants in their official capacity as current and former officials of the Danish Government.

(Vinther Aff. ¶ 20.) Thus, as a matter of right, the Proposed Intervenors should be permitted to

intervene in order to remove this case to federal court under the FSIA.

Thereafter, Proposed Intervenors may properly move to dismiss this action for lack of

subject matter jurisdiction pursuant to the FSIA, as well as on the bases of a plethora of other

deficiencies in the pro se Petition. See Odhiambo v. Republic of Kenya, 930 F. Supp. 2d 17, 34

(D.D.C. 2013) (dismissing a suit against Kenyan government and its officials in their official

capacity under FSIA because “the Kenyan government was ‘the real party in interest’”), aff’d,

764 F.3d 31 (D.C. Cir. 2014), cert. denied, 136 S. Ct. 2504 (U.S. 2016). Where, as here, an

official is sued in his or her official capacity, and where, as here, the action is clearly against the

foreign state, the case should be treated as an action against the foreign state itself, as the state is

the real party in interest. See Samantar v. Yousuf, 560 U.S. 305, 334-35 (2010); see also Smith

Rocke Ltd. v. Republica Bolivariana de Venezuela, No. 12 Cv. 7316 (LGS), 2014 WL 288705, at

*11 (S.D.N.Y. Jan. 27, 2014) (“The Supreme Court noted that where an official is sued in his

official capacity, and where the action is clearly against the foreign state itself as the real party in

interest, the case may be treated as an action ‘against the foreign state itself, as the state is the

real party in interest.’”) (quoting Samantar, 560 U.S. at 325).

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b. This Court Should Allow Proposed Intervenors
to Intervene on a Permissive Basis

In the alternative, a nonparty may intervene on a permissive basis at the discretion of the

Court, provided that the intervention will not result in undue delay or prejudice the substantial

rights of any party. See C.P.L.R. 1013. In exercising its discretion, the Court should consider

the extent to which the proposed intervenor has a “real and substantial interest in the outcome of

the proceedings.” See Berkoski v. Bd. of Trustees of Incorporated Village of Southampton, 67

A.D.3d 840, 843, 889 N.Y.S.2d 623, 626 (2d Dep’t 2009); St. Joseph’s Hosp. Health Ctr. v.

Dep’t of Health, 224 A.D.2d 1008, 1008, 637 N.Y.S.2d 821, 823 (4th Dep’t 1996); United Servs.

Auto. Ass’n v. Graham, 21 A.D.2d 657, 657, 249 N.Y.S.2d 788, 790 (1st Dep’t 1964). The rule

also specifies three additional factors that should inform the Court’s exercise of discretion:

(1) the potential for undue delay in the determination of the action; (2) the potential for

substantial prejudice to any of the original parties, and (3) the timeliness of the motion to

intervene. Yuppie Puppy Pet Prod., Inc. v. St. Smart Realty, LLC, 77 A.D.3d 197, 200-01, 906

N.Y.S.2d 231, 235 (1st Dep’t 2010). See also Lamboy v. Gross, 129 Misc. 2d 564, 576, 493

N.Y.S.2d 709, 717 (Sup. Ct. N.Y. Co. 1985) (giving consideration to extent to which judicial

economy would be served by intervention), aff’d, 126 A.D.2d 265, 513 N.Y.S.2d 393 (1st Dep’t

1987).

In the instant case, intervention by the Proposed Intervenors will not result in undue delay

or prejudice the substantial rights of any party. The action was only commenced by Plaintiff Pro

Se in November 2016, and he has made no effort to prosecute this case since that time.

Moreover, as the Proposed Intervenors have a real and substantial interest in the outcome of

these proceedings, which concern official actions of the Danish Government. Absent

intervention, Plaintiff Pro Se would in effect be allowed to circumvent well-settled principles of

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sovereign immunity and the FSIA simply by the tactical omission of the foreign governmental

entities that are the real parties at interest. As a consequence, this Court should permit Proposed

Intervenors to intervene in order to remove this case to federal court and rightfully invoke

foreign sovereign immunity as to Proposed Intervenors and foreign official immunity as to the

Foreign Official Defendants.

c. This Court Should Allow Stay The Proceedings Pursuant to C.P.L.R. 2201
Until This Application To Intervene Is Decided

C.P.L.R. 2201 provides: “Except where otherwise proscribed by law, the court in which

an action is pending may grant a stay of proceedings in a proper case, upon such terms as may be

just.” The broad language of the statute affords the trial court substantial discretion when

considering a stay of the proceedings. See Zonghetti v. Jeromack, 150 A.D.2d 561, 562, 541

N.Y.S.2d 235, 237 (2d Dep’t 1989) (holding that a court has “broad discretion to grant a stay in

order to avoid the risk of inconsistent adjudications, application of proof and potential waste of

judicial resources”); Research Corp. v. Singer-Gen. Precision, Inc., 36 A.D.2d 987, 988, 320

N.Y.S.2d 818, 820 (3d Dep’t 1971) (holding that the issuance of a stay pursuant to CPLR 2201 is

discretionary in the trial court).

In the instant case, given the issues of foreign sovereign immunity and foreign official

immunity implicated by Plaintiff Pro Se’s Petition, as well as his demonstrated history as a serial

litigant, this Court should stay the action as against the Foreign Official Defendants in order to

permit Proposed Intervenors to remove this case to federal court under the FSIA, which is the

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appropriate forum for the Danish Government to protect its interests and those of its current and

former officials. (Michailidis Aff. ¶ 14; Michailidis Emergency Aff. ¶ 7.)4

CONCLUSION

For all of the foregoing reasons, Proposed Intervenors respectfully request that the Court

(1) grant them leave to intervene pursuant to N.Y. C.P.L.R. 1012(a) and 1013; (2) stay the

proceedings in the instant action as to the Foreign Official Defendants; and (3) grant such further

relief as the Court may deem just and proper.

Dated: New York, New York
January 30, 2017
Respectfully submitted,

DUANE MORRIS LLP

By: s/ Evangelos Michailidis
Evangelos Michailidis
Ralph Carter
1540 Broadway
New York, New York 10036-4086
Tel: (212) 692-1000

Email: emichailidis@duanemorris.com
rcarter@duanemorris.com

Attorneys for Proposed Intervenors

4
An additional basis for a stay would be the apparent deficiencies in Plaintiff Pro Se’s attempt to
effect service of process on the Foreign Official Defendants. The service deficiencies are set
forth in detail in the Michailidis Affirmation.

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Case Info

Judge

Arlene P Bluth Track Judge’s New Case

Case No.

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Document Filed Date

January 30, 2017

Case Filing Date

November 16, 2016

County

Parties

Andrea Jedrzejwska Defendant
Annette Gregersen Defendant
Arjuna C Fernando Plaintiff
CARTER, RALPH JEFFREY Attorney for the Defendants
Fernando, Arjuna C. Attorney for the Plaintiff
Helle Haxgart Defendant
Henrik Horster Defendant
Jan Henriksen Defendant
Jette Rogild Defendant
Julie Bronden-wijngaard Defendant
Karen Ellemann Defendant
Lene Conrad Defendant
Lise Beder Defendant
Lone Buhl Defendant
Louise Brydov Defendant
MICHAILIDIS, EVANGELOS Attorney for the Defendants
Nini Christensen Defendant
Thorkil Juul Defendant

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Motion-Secondary: Arjuna C Fernando v. Karen Ellemann, Thorkil Juul, Jan Henriksen, Lise Beder, Lene Conrad, Henrik Horster, Nini Christensen, Helle Haxgart, Jette Rogild, Annette Gregersen, Julie Bronden-Wijngaard, Andrea Jedrzejwska, Lone Buhl, Louise Brydov

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