COPsync, Inc.
Bankruptcy

Eastern District of Louisiana (Bankruptcy), laeb-2:2017-bk-12625

Exhibit C

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Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 1 of 13 Composite Exhibit C – Copy of D&O Notice 1315402v.2 Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 2 of 13 From the Desk of Danielle Pellegrin Chief Legal Officer m (504) 315-8989 315 dpellegrin@cs dpellegrin@cs-bankruptcy.com bankruptcy.com December 14, 2017 VIA FEDERAL EXPRESS Joseph Alosa 286 South Street Concord, NH 03301 RE: Notice of Claims to Insurers XL Specialty Insurance Company (Policy number ELU147983-16) ELU147983 16) and HCC Specialty Insurance Company (Policy number 14 14-SMG-16-A5513) A5513) relating to COPsync, Inc. Policy Period: December 18, 2016 2016-17 17 (the "Policie "Policies") Dear Sir or Madam, The undersigned is the Chief Legal Officer of COPsync, Inc. ("COPsync" or the "Debtor"), an insured under the above above-captioned captioned policies. I write to inform you of potential claims and causes of action which may be asserted agains againstt you arising from your tenure as officer and/or director of COPsync. On September 29, 2017, COPsync filed a voluntary petition for reorganization under Chapter 11 of the United States Bankruptcy Code in Case No. 17-12625 17 12625 on the docket of the United States Bankruptcy Court for the Eastern District of Louisiana. The Debtor expects to file a Plan of Liquidation Liquidation calling for creation of a Liquidation Trust (or like entity) and the appointment of a Liquidation Trustee to administer and liquidate the Debtor's remaining assets, including, but not limited to, all claims and causes of action against any and all oofficers fficers and directors listed below. Alternatively, the case could be converted to a Chapter 7 proceeding, which would result in appointment of a Chapter 7 Bankruptcy Trustee to administer and liquidate the assets comprising the Bankruptcy Estate, includin includingg all such claims and causes of action. As a result of investigation following COPsync's filing for Chapter 11 protection, the Debtor has learned of the following Wrongful Acts by COPsync's former officers and directors: COPsync's officers and directo directors, rs, individually and collectively, breached their duties of good faith, care, and loyalty to the company and other legal duties owed to the company by, among others, the following acts and omissions, which were committed either recklessly or with gross neg negligence: ligence: i. Failure to implement, maintain, and oversee appropriate financial controls and accounting, including, but not limited to, ensuring timely collection of receivables; COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380 75380-2108 2108 www.COPsync.com COMPOSITE EXHIBIT "C" Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 3 of 13 ii. Causing COPsync to enter into contracts and transactions with persons related to or affiliated with officers and directors of COPsync; iii. Issuing false or misleading financial statements and information; iv. Failure to install management having the knowledge, competency, and expertise necessary to discharge their respective duties and obligation and gross mismanagement of the Debtor; v. Manipulating and misstating COPsync's financial statements and reports to overstate assets and profitability; vi. Undertaking contractual obligations that officers and directors knew or should have known COPsync could not perform including sales agreements for products the company did not offer and never developed, and exposing the company to claims for substantial damages; vii. Undertaking contractual obligations that officers and directors knew or should have known would not provide any economic benefit to the company; viii. Waste and diversion of assets; ix. Failure to undertake any meaningful efforts to restructure as COPsync entered the zone of insolvency; x. Retaining employees on the basis of nepotism and employing persons related to officers and directors who received compensation but provided no corresponding services; xi. Possibly violating provisions of federal and state law including the Securities Act, Securities Exchange Act, Rule 10b-5 of the Securities and Exchange Commission, and rules of state securities regulators or self-regulatory organizations. xii. Failure to fulfill obligations to employees and incurring related liabilities to these employees and United States Department of Labor. COPsync's officers and directors, and each of them, breached their duties of good faith, care, and loyalty by mismanaging or interfering in the bidding process for the sale of Debtor's assets to a third party. COPsync's officers and directors, and each of them, breached their duties of good faith, care, and loyalty by actively engaging in and/or negligently failing to prevent COPsync from engaging in improper and wasteful business practices, including, but not limited to, COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 4 of 13 securing accommodations from vendors and/or payees by promising future equity transfers. COPsync believes the above-referenced acts and omissions, as well as other acts and omissions, constitute Wrongful Acts under the Policies, and give rise to Claims by the Debtor and its bankruptcy estate against COPsync's former officers and directors. These Claims include, but are not limited to, the following causes of action: (1) breach of the fiduciary duties of care, loyalty, and good faith; (2) aiding and abetting breach of such fiduciary duties; (3) usurpation of corporate opportunity; (4) corporate waste and (5) any and all claims which may be asserted under Chapter 5 of the United States Bankruptcy Code. COPsync further believes that various acts and omissions of officers and directors constituting Wrongful Acts may give rise to claims, demands and causes of action by persons who acquired securities issued by the Debtor including without limitation, claims asserting violations of provisions of various State Blue Sky Laws, the Securities Act, the Securities Exchange Act, and rules and regulations of the Securities and Exchange Commission, state securities regulators, and self-regulatory organizations. Please be advised that the Debtor's analysis of acts and omissions constituting Wrongful Acts is in a preliminary stage and has been handicapped by the facts that (i) most employees, officers, and directors have terminated any relationship with the Debtor; (ii) current management of COPsync has only been in place for the past few months and has been principally focused on planning and conducting the Chapter 11 case; and (iii) the press of other obligations as debtor in possession has substantially impaired the Debtor's ability to conduct a comprehensive investigation of possible Wrongful Acts. The analysis is continuing and COPsync expressly reserves the right to amend and supplement this Notice. The Debtor has not calculated the damages or other consequences of the Wrongful Acts outlined above, but believes that its damages are substantial. COPsync believes, and hereby advises you that you do or should qualify as an Insured under director and officer insurance policies purchased by COPsync and identified as (i) XL Specialty Insurance Company, Policy No. ELU147983-16 and (ii) HCC Specialty Insurance Company, Policy No. 14-SMG-16-A5513. Please note that both policies are claims made policies and the deadline for providing notice of claims is December 18, 2017. COPsync has provided notice of potential claims against you to both insurers and copies of that correspondence is enclosed. We further urge you to give notice to each insurer that you have been apprised of potential claims against you and assert any and all rights you may have with respect to both policies. The addresses and email addresses for the insurers are as follows: HCC Specialty Insurance Company Claims Manager Tokio Marine HCC – D&O Group 8 Forest Park Drive Farmington, CT 06032 usclaims@tmhcc.com COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 5 of 13 XL Professional Insurance Attention: Claim Department 100 Constitution Plaza, 17th Floor Hartford, CT 06103 proclaimnewnotices@xlcatlin.com Sincerely yours, COPsync, Inc. Danielle L. Pellegrin Chief Legal Officer DLP/ Enclosure COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 6 of 13 From the Desk of Danielle Pellegrin Chief Legal Officer m (504) 315 315-8989 dpellegrin@cs dpellegrin@cs-bankruptcy.com bankruptcy.com December 14, 2017 VIA E-MAIL <usclaims@tmhcc.com usclaims@tmhcc.com> usclaims@tmhcc.com Claims Manager Tokio Marine HCC – D&O Group 8 Forest Park Drive Farmington, CT 06032 RE: Insurer: HCC Specialty Insurance Company Company: COPsync, Inc. Policy No.: 14--SMG-16-A5513 A5513 Policy Period: December 18, 2016-17 2016 Dear Sir or Madam, The undersigned is the Chief Legal Officer of COPsync, Inc. ("COPsync" or the "Debtor"), an insured under the above-captioned above captioned policy. On September 29, 2017, COPsync filed a voluntary petition for reorganization under Chapter 11 of the United States Bankruptcy Code in Case No. 17 17-12625 12625 on the docket of the United States Bankruptcy Court for the Eastern District of Louisiana. The Debtor expects to file a Plan of Liquidation Liquidation calling for creation of a Liquidation Trust (or like entity) and the appointment of a Liquidation Trustee to administer and liquidate the Debtor's remaining assets, including, but not limited to, all claims and causes of action against any and all oofficers fficers and directors listed below. Alternatively, the case could be converted to a Chapter 7 proceeding, which would result in appointment of a Chapter 7 Bankruptcy Trustee to administer and liquidate the assets comprising the Bankruptcy Estate, including including all such claims and causes of action. Pursuant to CONDITION (B)(3) of the above-referenced above referenced insurance policy (the "Policy") "Policy"), 1 please regard this letter as written notice by and/or on behalf of COPsync, its past aand nd present officers and directors, including Ronald Woessner, Russell Chaney, Shane Rapp, Joel Hochberg, Robert Harris, Luisa Ingargiola, Brian Tuskan, Ward Leber, Joe Alosa, Brad Powers, Phil Anderson, Barry Wilson, Cesar D'Onofrio, Larry Schafran and any anyone one else who may be deemed an Insured Insured Person under the Policy, to HCC Specialty Insurance Company of the following Wrongful Acts, the damages resulting therefrom, the potential claimants, and the circumstances by which they first became aware of such Wrongful Wrongful Acts. 1 COPsync gives such notice in its own right and as debtordebtor-in-possession, possession, which, under 11 U.S.C. § 1007, authorizes it to exercise the rights, and perform the functions and duties, of a bankruptcy trustee. COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 7 of 13 As a result of investigation following COPsync's filing for Chapter 11 protection, the Debtor has learned of the following Wrongful Acts by COPsync's former officers and directors: COPsync's officers and directors, individually and collectively breached their duties of good faith, care, and loyalty to the company and other legal duties owed to the company by, among others, the following acts and omissions, which were committed either recklessly or with gross negligence: i. Failure to implement, maintain, and oversee appropriate financial controls and accounting, including, but not limited to, ensuring timely collection of receivables; ii. Causing COPsync to enter into contracts and transactions with persons related to or affiliated with officers and directors of COPsync; iii. Issuing false or misleading financial statements and information; iv. Failure to install management having the knowledge, competency, and expertise necessary to discharge their respective duties and obligation and gross mismanagement of the Debtor; v. Manipulating and misstating COPsync's financial statements and reports to overstate assets and profitability; vi. Undertaking contractual obligations that officers and directors knew or should have known COPsync could not perform including sales agreements for products the company did not offer and never developed, and exposing the company to claims for substantial damages; vii. Undertaking contractual obligations that officers and directors knew or should have known would not provide any economic benefit to the company; viii. Waste and diversion of assets; ix. Failure to undertake any meaningful efforts to restructure as COPsync entered the zone of insolvency; x. Retaining employees on the basis of nepotism and employing persons related to officers and directors who received compensation but provided no corresponding services; COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 8 of 13 xi. Possibly violating provisions of federal and state law including the Securities Act, Securities Exchange Act, Rule 10b-5 of the Securities and Exchange Commission, and Rules of state securities regulations on self-regulatory organizations. xii. Failure to warn obligations to employees and incurring related liabilities to these employees and United States Department of Labor. COPsync's officers and directors, and each of them, breached their duties of good faith, care, and loyalty by mismanaging or interfering the bidding process for the sale of Debtor's assets to a third party. COPsync's officers and directors, and each of them, breached their duties of good faith, care, and loyalty by actively engaging in and/or negligently failing to prevent COPsync from engaging in improper and wasteful business practices, including, but not limited to, securing accommodations from vendors and/or payees by promising future equity transfers. COPsync believes the above-referenced events, as well as other acts and omissions, constitute Wrongful Acts under the Policy, and therefore give rise to Claims by the Debtor and its bankruptcy estate against the officers and directors. These Claims include, but are not limited to, the following causes of action: (1) breach of the fiduciary duties of care, loyalty, and good faith; (2) aiding and abetting breach of such fiduciary duties; (3) usurpation of corporate opportunity; (4) corporate waste and (5) any and all claims which may be asserted under Chapter 5 of the United States Bankruptcy Code. COPsync further gives notice that various acts and omissions of officers and directors constituting Wrongful Acts may give rise to claims, demands and causes of action by persons who acquired securities issued by the Debtor including without limitation, claims asserting violations of provisions of various State Blue Sky Laws, the Securities Act, the Securities Exchange Act, and rules and regulations of the Securities and Exchange Commission, state securities regulators, and self-regulatory organizations. Please be advised that the Debtor's analysis of acts and omissions constituting Wrongful Acts is in a preliminary stage and has been handicapped by the facts that (i) most employees, officers, and directors have terminated any relationship with the Debtor; (ii) current management of COPsync has only been in place for the past few months and has been principally focused on planning and conducting the Chapter 11 case; and (iii) the press of other obligations as debtor in possession has substantially impaired the Debtor's ability to conduct a comprehensive investigation of possible Wrongful Act. The analysis is continuing and COPsync expressly reserves the right to amend and supplement this Notice. The Debtor has not calculated the damages or other consequences of the Wrongful Acts outlined above, but believes that its damages are substantial. COPsync and its past and present officers and directors, including Ronald Woessner, Russell Chaney, Shane Rapp, Joel Hochberg, Robert Harris, Luisa Ingargiola, Brian Tuskan, Ward Leber, Joe Alosa, Brad Powers, Phil Anderson, Barry Wilson, Cesar D'Onofrio, Larry Schafran and anyone else who may be deemed an Insured Person under the Policy, and each of them, hereby provide written notice and the officers and directors request coverage under the COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 9 of 13 Policy, more particularly, Policy No. ELU147983-16, for any and all subsequently resulting Claims for any of the Wrongful Acts described in this letter and/or any related Wrongful Acts. The undersigned is authorized to make this request on behalf of COPsync and all such officers, directors, and other persons. Kindly acknowledge both receipt of this letter and coverage under the Policy for all such subsequently resulting Claims. Thank you for your cooperation. With kind regards, I remain Sincerely yours, COPsync, Inc. Danielle L. Pellegrin Chief Legal Officer DLP Enclosure Cc: Ronald Woessner 5108 Pinehurst Dr. Frisco, TX 75034 Russell Chaney 1617 Shady Hollow, New Braunfels, TX 78132, USA Shane Rapp P.O. Box 1424, Canyon Lake, TX 78133 Joel Hochberg 1930 Harrison Street Suite 302, Hollywood, FL 33020 Robert Harris 2831 Palmer Highway, Texas City, TX 77590 Luisa Ingargiola 930 Florida Ave, Palm Harbor, FL 34683 Brian Tuskan 4012 148th St. SE Suite #11 Mill Creek, WA 98012 Ward E Leber 4626 Tarantella Ln, San Diego, Ca 92130 Joe Alosa 286 South Street Concord, NH 03301 Brad Powers 325 North End Ave, PHD, New York, NY 10282 Phil Anderson 60 W. 23rd Street Apt 601, New York, NY 10010 Barry Wilson 804 Woodridge Dr., Fort Worth, TX 76120 Cesar D'Onofrio c/o Making Sense, LLC, 401 E. Houston Street, San Antonio, TX 78205 Larry Schafran lgschafran@schafran.com COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 10 of 13 From the Desk of Danielle Pellegrin Chief Legal Officer m (504) 315 315-8989 dpellegrin@cs dpellegrin@cs-bankruptcy.com bankruptcy.com December 14, 2017 VIA E-MAIL <proclaimnewnotices@xlcatlin.com proclaimnewnotices@xlcatlin.com> proclaimnewnotices@xlcatlin.com XL Professional Insurance Attention: Claim Department 100 Constitution Plaza, 17th Floor Hartford, CT 06103 RE: Insurer: XL Specialty Insurance Company Company: COPsync, Inc. Policy No.: ELU147983-16 ELU147983 16 Policy Period: December 18, 2016-17 2016 Dear Sir or Madam, The undersigned is the Chief Legal Officer of COPsync, Inc. ("COPsync" or the "Debtor"), an insured under the above-captioned above captioned policy. On September 29, 2017, COPsync filed a voluntary petition for reorganization under Chapter 11 of the United States Bankruptcy Code in Case No. 17 17-12625 12625 on the docket of the United States Bankruptcy Court for the Eastern District of Louisiana. The Debtor eexpects xpects to file a Plan of Liquidation calling for creation of a Liquidation Trust (or like entity) and the appointment of a Liquidation Trustee to administer and liquidate the Debtor's remaining assets, including, but not limited to, all claims and causes of of action against any and all officers and directors listed below. Alternatively, the case could be converted to a Chapter 7 proceeding, which would result in appointment of a Chapter 7 Bankruptcy Trustee to administer and liquidate the assets comprising the the Bankruptcy Estate, including all such claims and causes of action. Pursuant to Section VI. GENERAL CONDITIONS, sub sub-section section (A) NOTICE, of the above above- referenced insurance policy (the "Policy"), please regard this letter as written notice by and/or on behalf of COPsync,1 its past and present officers and directors, including Ronald Woessner, Russell Chaney, Shane Rapp, Joel Hochberg, Robert Harris, Luisa Ingargiola, Brian Tuskan, Ward Leber, Joe Alosa, Brad Powers, Phil Anderson, Barry Wilson, Cesar D'O D'Onofrio, nofrio, Larry Schafran and anyone else who may be deemed an Insured Person under the Policy, to XL Specialty Insurance Company of the following Wrongful Acts, the damages resulting therefrom, 1 COPsync gives such notice in its own right and as debtordebtor-in-possession, possession, which, under 11 U.S.C. § 1007, authorizes it to exercise the rights, and perform the functions and duties, of a bankruptcy trustee. COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 11 of 13 the potential claimants, and the circumstances by which they first became aware of such Wrongful Acts. As a result of investigation following COPsync's filing for Chapter 11 protection, the Debtor has learned of the following Wrongful Acts by COPsync's former officers and directors: COPsync's officers and directors, individually and collectively breached their duties of good faith, care, and loyalty to the company and other legal duties owed to the company by, among others, the following acts and omissions, which were committed either recklessly or with gross negligence: i. Failure to implement, maintain, and oversee appropriate financial controls and accounting, including, but not limited to, ensuring timely collection of receivables; ii. Causing COPsync to enter into contracts and transactions with persons related to or affiliated with officers and directors of COPsync; iii. Issuing false or misleading financial statements and information; iv. Failure to install management having the knowledge, competency, and expertise necessary to discharge their respective duties and obligation and gross mismanagement of the Debtor; v. Manipulating and misstating COPsync's financial statements and reports to overstate assets and profitability; vi. Undertaking contractual obligations that officers and directors knew or should have known COPsync could not perform including sales agreements for products the company did not offer and never developed, and exposing the company to claims for substantial damages; vii. Undertaking contractual obligations that officers and directors knew or should have known would not provide any economic benefit to the company; viii. Waste and diversion of assets; ix. Failure to undertake any meaningful efforts to restructure as COPsync entered the zone of insolvency; x. Retaining employees on the basis of nepotism and employing persons related to officers and directors who received compensation but provided no corresponding services; COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 12 of 13 xi. Possibly violating provisions of federal and state law including the Securities Act, Securities Exchange Act, Rule 10b-5 of the Securities and Exchange Commission, and Rules of state securities regulations on self-regulatory organizations. xii. Failure to warn obligations to employees and incurring related liabilities to these employees and United States Department of Labor. COPsync's officers and directors, and each of them, breached their duties of good faith, care, and loyalty by mismanaging or interfering the bidding process for the sale of Debtor's assets to a third party. COPsync's officers and directors, and each of them, breached their duties of good faith, care, and loyalty by actively engaging in and/or negligently failing to prevent COPsync from engaging in improper and wasteful business practices, including, but not limited to, securing accommodations from vendors and/or payees by promising future equity transfers. COPsync believes the above-referenced events, as well as other acts and omissions, constitute Wrongful Acts under the Policy, and therefore give rise to Claims by the Debtor and its bankruptcy estate against the officers and directors. These Claims include, but are not limited to, the following causes of action: (1) breach of the fiduciary duties of care, loyalty, and good faith; (2) aiding and abetting breach of such fiduciary duties; (3) usurpation of corporate opportunity; (4) corporate waste and (5) any and all claims which may be asserted under Chapter 5 of the United States Bankruptcy Code. COPsync further gives notice that various acts and omissions of officers and directors constituting Wrongful Acts may give rise to claims, demands and causes of action by persons who acquired securities issued by the Debtor including without limitation, claims asserting violations of provisions of various State Blue Sky Laws, the Securities Act, the Securities Exchange Act, and rules and regulations of the Securities and Exchange Commission, state securities regulators, and self-regulatory organizations. Please be advised that the Debtor's analysis of acts and omissions constituting Wrongful Acts is in a preliminary stage and has been handicapped by the facts that (i) most employees, officers, and directors have terminated any relationship with the Debtor; (ii) current management of COPsync has only been in place for the past few months and has been principally focused on planning and conducting the Chapter 11 case; and (iii) the press of other obligations as debtor in possession has substantially impaired the Debtor's ability to conduct a comprehensive investigation of possible Wrongful Act. The analysis is continuing and COPsync expressly reserves the right to amend and supplement this Notice. The Debtor has not calculated the damages or other consequences of the Wrongful Acts outlined above, but believes that its damages are substantial. COPsync and its past and present officers and directors, including Ronald Woessner, Russell Chaney, Shane Rapp, Joel Hochberg, Robert Harris, Luisa Ingargiola, Brian Tuskan, Ward Leber, Joe Alosa, Brad Powers, Phil Anderson, Barry Wilson, Cesar D'Onofrio, Larry Schafran and anyone else who may be deemed an Insured Person under the Policy, and each of them, hereby provide written notice and the officers and directors request coverage under the COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380-2108 www.COPsync.com Case 17-12625 Doc 216-3 Filed 04/30/18 Entered 04/30/18 18:41:23 Exhibit C Page 13 of 13 Policy, more particularly, Policy No. ELU147983-16, for any and all subsequently resulting Claims for any of the Wrongful Acts described in this letter and/or any related Wrongful Acts. The undersigned is authorized to make this request on behalf of COPsync and all such officers, directors, and other persons. Kindly acknowledge both receipt of this letter and coverage under the Policy for all such subsequently resulting Claims. Thank you for your cooperation. With kind regards, I remain Sincerely yours, COPsync, Inc. Danielle L. Pellegrin Chief Legal Officer DLP/ Enclosure Cc: Ronald Woessner 5108 Pinehurst Dr. Frisco, TX 75034 Russell Chaney 1617 Shady Hollow, New Braunfels, TX 78132, USA Shane Rapp P.O. Box 1424, Canyon Lake, TX 78133 Joel Hochberg 1930 Harrison Street Suite 302, Hollywood, FL 33020 Robert Harris 2831 Palmer Highway, Texas City, TX 77590 Luisa Ingargiola 930 Florida Ave, Palm Harbor, FL 34683 Brian Tuskan 4012 148th St. SE Suite #11 Mill Creek, WA 98012 Ward E Leber 4626 Tarantella Ln, San Diego, Ca 92130 Joe Alosa 286 South Street Concord, NH 03301 Brad Powers 325 North End Ave, PHD, New York, NY 10282 Phil Anderson 60 W. 23rd Street Apt 601, New York, NY 10010 Barry Wilson 804 Woodridge Dr., Fort Worth, TX 76120 Cesar D'Onofrio c/o Making Sense, LLC, 401 E. Houston Street, San Antonio, TX 78205 Larry Schafran lgschafran@schafran.com COPsync™ (COYN) Headquarters: 400 Poydras Street, Suite 2100, New Orleans, Louisiana 70130 P.O. Box 802108, Dallas, Texas 75380-2108 www.COPsync.com