Steinbuch v. Cutler et al

Filing 51

RESPONSE to Motion re 46 MOTION for Extension of Time to File Response/Reply as to 38 MOTION to Dismiss for Lack of Jurisdiction, 44 MOTION to Dismiss, 36 Corporate Disclosure Statement (Rule 7.1), 43 Corporate Disclosure Statement (Rule 7.1), 45 Brief in Support, [ RESPONSE OPPOSING DEFENDANTS' MOTION TO STAY filed by Robert Steinbuch. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8# 9 Exhibit 9# 10 Exhibit 10# 11 Exhibit 11# 12 Exhibit 12# 13 Exhibit 13)(Rosen, Jonathan)

SteinbuchHBO: Boxing: Fighters: Bio: JERMAIN TAYLOR v. Cutler et al

Case 4:06-cv-00620-WRW

Document 51-12

Filed 09/10/2006

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Middleweight 25-0-1 | 17 KOs Nickname Bad Intentions Hometown Little Rock, AR Date of Birth August 11, 1978 Height 6'1"

"Meet the Taylor's" Jermain Taylor is the undisputed middleweight champion of the world, a hometown hero in Little Rock, Arkansas. He can't go anywhere in the city without being mobbed for autographs. Read More

Past Fight Event Pages WCB: Taylor vs. Wright PPV: Taylor vs. Hopkins 2 PPV: Hopkins vs. Taylor

BAD: Williams vs. Mitchell

JERMAIN TAYLOR
Fighter Bio | Fighter Record | Discuss updated June 18, 2006

PPV: Barerra vs. Juarez PPV: Pacquaio vs. Morales III

In what many called the most highly anticipated fight of the year, the rematch between Jermain "Bad Intentions" Taylor and Bernard Hopkins took place on December 3, 2005 at the Mandalay Bay Resort and Casino in Las Vegas. Both fighters opened the fight cautiously, but Taylor's left jab and dominating right hand began to take a toll on Hopkins. As he did six months earlier, Taylor scored a decision victory, this time unanimously. On July 16, 2005, the 2000 U.S. Olympic Bronze Medalist earned his first world championship with a hard-fought decision win over future hall-of-famer Bernard Hopkins. Boxing has a new star, one who encapsulates all the values we like to see in our sports heroes - class, hard work, enthusiasm, accessibility, and talent. It was a bout that captured the imagination of the sporting public, and catapulted Taylor into a seemingly endless stream of media appearances and celebrations. On August 2, 2005, Jermain's promoter Lou DiBella took the champion to former President Bill Clinton's Harlem office. During the meeting, Clinton praised Taylor for his recent achievement and boxers in general for the sacrifices they make in pursuit of their dreams. Taylor presented the former President with a replica of the robe that he wore into the ring prior to the Hopkins fight in July.

Good fight idea here. Step up in class. Sharmba is good enough to give guys a workout, though he is not an elite fighter. More than a journeyman, less than a contender at this point. Will make for a fun fight, because he will force Williams to be good to win. Williams should stop him around the 9th or so. It is hard to deal with his size and activity level. --sk7326 What do you think? Discuss

"I'm hoping that I can be a role model for the kids. Not the earrings, the long hair, the sagging pants and big clothes. I think kids need a new role model." -Jermain Taylor

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"It was amazing," said Taylor of meeting Clinton. "I always wanted to meet him; it was an honor." But even though Taylor is the toast of the sports world after his stirring victory over Hopkins, his road to glory wasn't paved with gold. Born on August 11, 1978 in Little Rock, Arkansas, Jermain Taylor and his three younger sisters were abandoned by his father when he was just five years old. Since his beloved mother Carlois had to work full-time as a nurse's assistant to support her children, Jermain had to grow up fast as he watched after his three younger sisters while his mom worked. Jermain was forced into changing diapers, doing laundry and washing dishes when all of Taylor's friends were outside being kids. Forced into the role of "man of the house", Taylor took care of his three younger sisters while his mother worked to support them. It was a tough time for the family. "I think about it all the time," Taylor admits. "Why did I have to do that and why did I have to grow up so fast like that? But I just say that I'm going to try and be a better man than that." Add in the fact that the Taylor family were not exactly living in the lap of luxury, and the rough road got even rougher. "When I look at where I come from, if it was a picture that I could show you, it would almost bring you to tears how poor we were," said Taylor. Christmas time was even tougher than usual to deal with. "Christmases were hard," admitted Taylor. "There were a couple of times when I didn't have Christmas." There was a lot of love in the house though, and the family persevered through the rocky times. And in a way, Taylor's speedy maturation process would come in handy when he began competing in the world's hardest game. Admirably, Taylor refuses to talk negatively about the father that left him and his family. "Even though there are a lot of things in my head that go against my father, in my heart I still love him to death, and every time I see him, my heart still jumps,' said Taylor. "It jumps up and down just to know he's my father." But if there is a silver lining in the clouds of Taylor's childhood, as he is determined not to repeat the mistakes of his own father. "It's changed me so much because I know you have to spend time with a child," said Taylor. "If not, the child will still love you, but he won't know you. I know my dad, but I don't know him. I don't know what he's like; I don't know his mean face. I want my kids to know me - to know what I like, and what I don't like - to know my facial expressions. And the same way for them. I want to know the way they look when they're mad, when they're sleepy. Little things like that are part of being a dad." At the age of 13, Jermain was getting restless and looking for something to do. But while other kids were going in the wrong direction, an uncle who had been a boxer took his nephew to the local gym. It was a rocky beginning for Taylor, as he took a severe beating the first time he stepped through the ropes. Worse yet, he also received a subsequent tongue lashing from his mother for wanting to participate in the sport. The boxing bug had bit him though, and he trudged back to the gym, eager to learn and compete. Enter Ozell Nelson.

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"If it weren't for him, there's no telling where I would have been," said Taylor of Nelson, who not only handles training duties for Jermain with Pat Burns, but who has also been a surrogate father to him. "Him and his wife took me in. I used to go over their house and eat, sleep, and do everything, just like I was a part of the family and they had kids of their own. Now that I look back on it, it must have been hard because he wasn't rich. But he still tried to bring me in and love me like I was one of his sons. A kid, and especially a young man, needs to have somebody who he can look up to, because if he doesn't, he's going to look to the streets. It's easier to pick up a bad habit than a good habit. Coach taught me how to work. He taught me that your word is the only thing a person can have. And if you mess your word up, you're worth nothing. He taught me that if you put in 100% it will definitely come out 110%. And I believe that." With a strong support system in place, as well as a Spartan work ethic and substantial talent, Taylor garnered strong notices on the Arkansas amateur circuit as he and Nelson traveled around in an old Chevy truck. But in the politically charged atmosphere of amateur boxing, Taylor was ignored until he started making some noise with his fists nationally. "I got picked over for everything," remembers Taylor. "Nobody was looking at Arkansas because Arkansas was small. They said, 'Don't worry about Jermain.' Then I started winning National tournaments and I started making a name. Then 'Bam' Jermain is all that." The first goal? The 2000 Olympics. "I told myself, 'I'm going to the Olympics,' and I wouldn't let anything stop me from getting there." To get there, Taylor piled up victory after victory. His amateur career was stacked with accolades beginning with the 1996 Under-19 Championship; he then won a pair of PAL Championships and National Golden Gloves titles and finished second and third at the 1997 and 1998 U.S. Championships respectively. He hit what was until that time the high point in his amateur career by winning a bronze medal at the 1998 Goodwill Games. This achievement was overshadowed by the subsequent murder of his grandmother, Gussie Robertson. The killer was her own son, who killed himself three days later. At her funeral, Taylor placed his Goodwill Games medal in her coffin. Taylor now uses his grandmother as inspiration every time he steps through the ropes. "Every time I get into the ring, she's the first person that pops into my head," Taylor reflected. "Before a fight, I go to a neutral corner, kneel down and say a prayer to God and my grandmother." A berth on the 2000 US Olympic team followed, and Taylor, who was the first boxer from Arkansas ever to compete in the Olympic Games, brought home a Bronze medal for his efforts. Needless to say, the quietly charismatic young man with the loud fists was the center of much attention from promoters until he signed with DiBella Entertainment after the Sydney Games. DiBella, a former executive with HBO Sports known for his integrity and love of the sport, made a great team with the young middleweight. "Lou was my only choice to represent me as a professional," said Taylor. "He was honest and straightforward with me and he knows the game. Most importantly, I trust him." Jermain's professional career was kicked off on HBO at Madison Square Garden on January 27, 2001 as a part of DiBella Entertainment's "Night of the Olympians". Facing a very experienced fighter in veteran Chris Walsh (17-5-6, 6 KO's), he showed poise beyond his years, winning via TKO. Jermain put on an impressive display of power, knocking the more experienced Walsh down twice before the bout was halted early in the 4th frame.

http://www.hbo.com/boxing/fighters/taylor_jermain/bio.html

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Over the subsequent months the victories started to pile up. Yet despite a string of impressive wins, Taylor was seemingly ignored by many in the press, who lavished praise on other members of the Class of 2000. But with each successive month, some of Taylor's peers began to fall behind, either beaten in the ring or taken down by their reliance on their press clippings. Jermain Taylor made his move. I felt like if I kept working hard and kept my head on straight, there's no telling how far I could go," said Taylor, who truly arrived after a fifth round stoppage of Marcos Primera in March of 2003 before his home fans in Little Rock. Suddenly, the boxing world embraced Taylor, and was unable to ignore his jackhammer jab, concussive left hook, and veteran's poise between the ropes. Yet none of the acclaim - which includes modeling for Everlast, Vogue, and GQ, and receiving the 2003 Most Improved Fighter award from The Ring magazine - affected Taylor, and you won't see him walking the streets with an entourage.. It's a maturity he owes to his Arkansas roots. "That's the thing about Arkansas," said Taylor. "It's so small that you don't have to have an entourage or anything like that. I don't really need it. A person's friends have a lot to do with how people act. If a person has good friends, that's going to help them out a lot because they don't have to do all this stupid stuff and deal with peer pressure. I don't have to worry about that." Taylor hopes this attitude will rub off on the youth of America, who are sorely in need of positive role models. "I'm hoping that I can be a role model for the kids," said Taylor. "Not the earrings, the long hair, the sagging pants and big clothes. I think kids need a new role model." In 2004, Taylor gave boxing fans a new star, as he truly arrived on the world scene when he returned to his hometown on March 27, 2004 to face Alex Bunema (23-5, 18 KOs) on HBO's Boxing After Dark series, ten weeks after scoring a violent first round KO of southpaw Alex Rios on January 9. Taylor's jab pumped like a piston all night, confusing and frustrating his game opponent. He followed his jab with crushing right hands and by the middle rounds; Taylor could sense the feisty Bunema was wearing down. A left-right combination put Bunema down on the canvas for the first time in the seventh round. Bunema would beat the count but wouldn't last much longer as Taylor pummeled him against the ropes. With Bunema slumped down on a knee, the referee ended the onslaught. Taylor improved to 20-0, and earned his 15th KO. Including that stoppage, Jermain had registered KO victories in eight of his last nine bouts, facing stiffer competition every time. Squaring off against former World Champion Raul Marquez (35-2-0) on June 19, 2004, Taylor dominated his more experienced opponent throughout the contest at the Home Depot Center in Los Angeles. As the fight moved into the later rounds, Jermain had an answer for everything the cagey veteran threw his way and knocked Marquez down in the ninth. Taylor scored a TKO triumph when, between the ninth and tenth rounds, Marquez's corner, after seeing him absorb too much punishment, decided he shouldn't continue. On December 4, 2004, hometown fans packed Barton Coliseum in Little Rock, Arkansas to watch Jermain take on former three time World Middleweight Champion William Joppy (34-4-1, 25 KO's). In the opening minutes of the fight, both fighters exchanged stiff jabs, body shots and combinations. From a crushing right uppercut on the chin in the first round, followed by a punishing left hook to the face in the second round and finally a knockdown of Joppy in the fifth round, it was clear that Taylor would dominate the fight against the seasoned veteran. Taylor scored a unanimous decision (120-107 on all three scorecards) to retain his WBC Continental Americas Title. This impressive triumph, on HBO, established Jermain as the force to be reckoned with in the middleweight division.

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On February 19, 2005 at the Staples Center in Los Angeles, CA, Taylor proved worthy of the title of "heir apparent to Bernard Hopkins" with a devastating TKO victory over previously unbeaten Daniel Edouard (16-1-2, 9KO's), as the co-feature to Hopkins vs. Howard Eastman on HBO World Championship Boxing. In a bout many expected to be Taylor's toughest test to date, Jermain dominated from the start, connecting on over half of his punches thrown, dictating the fight and using his jab and power shots to overwhelm Edouard . As Taylor was connecting on a barrage of unreturned bombs, referee Ray Corona stopped the fight 2:26 into round three. And even though Taylor has dominated these high-profile opponents, he refuses to get overconfident, and before every fight he leaves the comfortable surroundings of home to train with Pat Burns in Miami. "There are no easy wins in the sport of boxing because everybody wants to be champion," said Taylor. "And I think that in order to train a person needs to be away from his surroundings to take his mind off everything," In August of 2003, Team Taylor added a new member when Jermain married the former Erica Smith, who is a world-class athlete herself as a former standout guard for the Louisiana Tech women's basketball team who was drafted by the WNBA's Washington Mystics in April of 2005. Jermain and Erica are the proud parents of a daughter, Nia, who was born on December 14, 2004. Married life took a bit of getting used to, especially for two athletes with vastly different training schedules. "It has its ups and downs because if I'm off, 9 times out of 10 Erica's in training, and I just want to be home, a husband to my wife, and when Erica's off, I'm away training, and Erica just wants a husband," admits Taylor. "But Erica knows what it takes to have to get up in the morning to go run, and if I'm having one of those days when I'm kinda lagging, she'll call me up and say 'are you running?' and I do the same thing with her. She tells me to just train hard and keep your head up, no matter what happens." So throughout the peaks and valleys of a life that was difficult to deal with at times, Jermain Taylor has excelled and is truly happy now. "I'm happy the way my life turned out," said Taylor. "I'm happy with the people I signed with. I was not rushed. I was not babied. And I'm right on schedule. There is no downside to this. I love it all."
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8/19/2006