Perfect 10 Inc v. Google Inc et al

Filing 543

SUPPLEMENT to MOTION to Compel Perfect 10, Inc. to Produce Documents, Comply with the Protective Order, and Affix Document Control Numbers to its Document Productions #407 Google Inc.'s Supplemental Memorandum in Support of its Motion to Compel Perfect 10, Inc. to Affix Document Control Numbers to its Document Production filed by Counter Claimant Google Inc, Defendant Google Inc. (Attachments: #1 Second Supplemental Declaration of Rachel Herrick Kassabian in Support Thereof, #2 Exhibit 1, #3 Exhibit 2)(Herrick, Rachel)

How'd You Get So Rich Video: Norm Zada Season 1, Episode 3 (Episode 104) Originally Aired August 19, 2009 Info Bubble: Rivers: Beverly Hills, CA Will you look at this place? The architecture. It could be the Getty Museum. I mean, it's huge and modern. Info Bubble: Rivers: This house was designed by Richard Landry. And his next door neighbors are Eddie Murphy, Sylvester Stallone. Yo! Rod Stewart. And in this house, Norm the Nerd. He couldn't get a date as a kid, but now he's got a mansion full of models. Info Bubble: Rivers: Norm Zada: $100 million A few years ago, he was making $19,000 a year. Now he's worth over $100 million, and his mansion is 20,000 sq. ft (info bubble repeats), with 11 bedrooms (info bubble repeats) and 18 bathrooms (info bubble repeats). His expenses are over $200,000 a month. How'd he get so rich? Come on, let's find out. Zada: Rivers: Oh, my God! He does look like a nerd. I am so excited to meet you. How lovely, how lovely. Info Bubble: Rivers: Norm got his Ph.D from U.C. Berkeley at age 22! Okay, before we even start, I want a tour of this amazing place. I want to know, how'd you get so rich? How? Tell me. Zada: Well actually, I've always been into gambling.

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Exhibit 2, Page 3

Info Bubble: Rivers: Zada: Info Bubble: Rivers: Info Bubble: Zada:

Norm made $100,000 a year gambling... Gambling? And I started off, I started gambling from a very early age. And turned it into $100 million by investing in the stock market! So your biggest gamble was investing $60 million in Perfect 10 Magazine? His earnings from the stock market funded Perfect 10 Magazine... Everything is basically a gamble. And if you take some chances and you're on the right side you can make a lot of money.

Info Bubble: Rivers: Zada: Rivers:

It is now available online. Will you show me? Will you show what gambling does? I would love to show you my house. This entrance is amazing. I feel like I'm at the Staples Center. Where are the Lakers?

Zada: Rivers: Info Bubble: Zada: Rivers: Zada: Rivers:

(Laughter) I don't want to say anything--you have no furniture. Although it looks like he just moved in... Norm has lived here for 8 years! You know I'm, I'm not really into furniture. We do have beds. Now where is your bedroom? My bedroom is right this way. Okay. All right. Again, very minimalistic, Norm. Wait a second. What's with all these pills?

Zada:

I suffer from the same infirmities that other people do.

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Exhibit 2, Page 4

Rivers:

Norm, you have the same medications that I do. Look! Stool softener and Midol.

Zada: Rivers: Info Bubble: Rivers: Zada: Rivers: Zada: Rivers: Zada: Rivers:

Laughter This is the bathroom, all right! Norm's mansion has 18 toilets...all with heated seats! This is great. His and her sinks. But no her. No her. No her? In fact I hardly ever have women in here, believe it or not. Norm, you gotta learn to share. Women are dirty, too. This is my hot tub that I never use. You never ha--? You lived here 8 years and you've never used this hot tub? What did this cost you? Do you remember?

Zada: Rivers: Zada: Rivers: Zada: Rivers: Narrator: Rivers:

I'm guessing $200 plus. (Bubble shows $200,000+ price tag) What's this built into the wall? It's a specially made shower. Wow, you have a shower big enough for 18 people or one Kristie Alley. Laughter. (Bubble puts price at $150,000) Look there's your vault. Oh Norm, please! Open it, come on. Commercial break. Nerdy Norm couldn't get a date for the prom. But he got rich gambling and now he lives in this $29 million mansion with lots and lots of cash. So there! Look, there's your vault. Oh Norm, please open it, come on. I'll block it.

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Exhibit 2, Page 5

No one should know your combination but you and me, Norm. Zada: Rivers: Zada: Rivers: Zada: Rivers: All right, Joan. Oh my God! I'm not sure if it's enough. Oh my God. I can't stand it. My God, Norm. Just let me know what you.... I love him. Joan and Norm. I see it. Melissa, your mother died like she lived: a happy woman. Zada: Rivers: Zada: Rivers: Laughter. You know how much is here, Norm? $100,000. (Bubble shows $100,000.) Norm I'm feeling faint. Could you get me a glass of water? Doesn't this make you feel secure? Info Bubble: Zada: At restaurants, Norm tips 50% of the bill! Not really, because unfortunately, it's probably like about, uh, you know, my expenses. It's probably like, uh, 2 weeks. Rivers: Wait, wait, wait. Your expenses are like $100,000 every 2 weeks? I mean that's $2.5 million a year. With that kind of money we could furnish the whole house and go on a honeymoon. (Laughter) Zada: Rivers: Zada: I'd like to show you the gym. I like a double door to a gym. It's very bowing. Oh, is this great! Thanks. It's exhausting to walk from the main house to the gym, so I work out in my bedroom.

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Exhibit 2, Page 6

Rivers: Zada:

In your bedroom? Because it's too long of a walk. The house actually is in two pieces. This is the main house here and I have kind of a guest area here.

Rivers: Info Bubble: Zada:

When did you know "I'm rich"? While at IBM, Norm made $19,000 a year. Probably by '94, '95 you start to feel rich. If you have a big year and you make like maybe $10 million dollars, $20 million dollars in a year.

Rivers:

Wow. Nerdy Norm sure gets the last laugh. (Laughter) This is wonderful!

Zada:

You know this is the kind of thing that, you know, rich people have. I don't ever use it. You know, I mean, people said well you should do it, so I did it.

Rivers: Zada: Info Bubble: Zada: Rivers:

So what are other things that rich people do? I think that if you're rich you have an obligation to give things back. Norm's favorite charity is the Clinton Foundation. You need to give to charity. You need to be aware of the suffering of others. That's nice. Rich and generous. Norm, my pussycat, rich people also have full-time staffs. Let's go and meet yours.

Info Bubble: Rivers:

Norm spends $100,000 a year on lawn care! Look at this. This is amazing. And there's your staff. No, no, keep working!

Zada:

Wendy Augustine works very well in Excel.

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Exhibit 2, Page 7

Rivers: Zada: Rivers: Zada: Rivers: Zada:

I can see her boobs are XL. (Laughter) Naureen Zaim is a fantastic softball player, tennis player. Yeah, oh your parents must be really proud. (Laughter) Sheena Chou, brilliant. Very good on a computer. Can you spell computer? (Laughter) C O.... (Laughter) Leilani Dowding is very, very intelligent. If you have any chemistry questions you'd like to ask her--

Rivers: Zada: Rivers:

Yes. Please do so. (Laughter) Can you tell if there is any chemistry between Norm and I? (Laughter) What does it take to be part of your staff? And how much do you pay?

Zada:

I try to pick models that can simultaneously do two things for me. They can model for Perfect 10...

Info Bubble:

Perfect10.com features women who have never had cosmetic surgery...there are no pictures of Joan on the website.

Zada: Rivers: Zada: Rivers: Zada: Rivers: Zada: Rivers:

...and they can actually do non-trivial work for us as well. How much do you pay these girls? They get around $100,000 a year for doing.... Each? Yes, each. Each. Each, each. ($100,000 sticker flashes over each of the four models.) For doing this? Move over bitch! (Laughter) I could be a Perfect 10 for

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Exhibit 2, Page 8

people with cataracts. (Laughter) I could be in your glaucoma issue. (Laughter) Tell me, if this what you wear while you're working, what happens on casual Friday? (Laughter) Info Bubble: Rivers: The girls do clerical work in Norm's home office. With all due respect, I know you are all very smart, but this is not life girls. This is called you fell into a bucket of (expletive) and came out smelling like a rose. (Laughter) This is amazing. (Laughter) Oh Norm, I love you so much. I have seen Revenge of the Nerds, but this is ridiculous. I mean, you have really made it! (Laughter) Norm it was so much fun. Thank you so much. If he can do it, you can do it. And one day soon, I hope I will be knocking on your door and saying, "Hey, how'd you get so rich?"

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Exhibit 2, Page 9