Rupa Marya v. Warner Chappell Music Inc
Filing
126
SUPPLEMENT to MOTION for Order for (i) OVERRULING DEFENDANTS' CLAIM OF PRIVILEGE IN DOCUMENTS PRODUCED BY A NON-PARTY, OR PERMITTING A SECOND RULE 30(b)(6) DEPOSITION TO DETERMINE THE FACTUAL BASIS FOR THAT CLAIM; (ii) GRANTING RELIEF FROM THE DISCOVERY CUTOFF 123 [REDACTED] filed by Plaintiffs Good Morning to You Productions Corp, Majar Productions LLC, Rupa Marya, Robert Siegel. (Attachments: # 1 Declaration Supplemental Decl of Betsy C. Manifold, # 2 Exhibit 13, # 3 Exhibit 14, # 4 Exhibit 15, # 5 Exhibit 16, # 6 Exhibit 17 [REDACTED & FILED UNDER SEAL])(Manifold, Betsy)
EXHIBIT 16
Ex. 16
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Page 1
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
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WESTERN DIVISION
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GOOD MORNING TO YOU PRODUCTIONS CORP,
et al.
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Plaintiffs,
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-againstWARNER/CHAPPELL MUSIC INC., et al.,
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Defendants.
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Lead Case No. CV 13-04460-GHK (MRWx)
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DATE:
July 11, 2014
TIME:
2:00 p.m.
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VIDEOTAPED DEPOSITION of Richard
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Reimer, taken by Plaintiffs, held at the
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Offices of Paul, Weiss, Rifkind, Wharton &
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Garrison, LLP, 1285 Avenue of the Americas,
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New York, New York 10019, before Gilbert J.
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Bowles, a Notary Public of the State of New
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York.
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Job No: 81987
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TSG Reporting - Worldwide
877-702-9580
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A P P E A R A N C E S:
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WOLF HALDENSTEIN ADLER FREEMAN & HERZ
Attorneys for the Plaintiffs
270 Madison Avenue
New York, NY 10016
BY: MARK C. RIFKIN, ESQ.
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MUNGER TOLLES & OLSON
355 South Grand Avenue
Los Angeles, CA 90071
BY: MELINDA EADES LeMOINE, ESQ.
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PAUL, WEISS, RIFKIND, WHARTON & GARRISON
1285 Avenue of the Americas
New York, NY 10019
BY: DARREN W. JOHNSON, ESQ.
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ALSO PRESENT:
STEVE SANPIETRO
Legal Video Specialist
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*
RANDALL S. NEWMAN, ESQ.
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*
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S T I P U L A T I O N S
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IT IS HEREBY STIPULATED AND AGREED, by and between
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the attorneys for the respective parties herein,
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that filing and sealing be and the same are
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hereby waived.
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IT IS FURTHER STIPULATED AND AGREED that all
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objections, except as to the form of the
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question, shall be reserved to the time of the
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trial.
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IT IS FURTHER STIPULATED AND AGREED that the within
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deposition may be sworn to and signed before any
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officer authorized to administer an oath, with
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the same force and effect as if signed and sworn
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to before the Court.
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move on.
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Q
Mr. Reimer, in the period from
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1974 through 1979, did ASCAP provide services
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to Summy-Birchard individually as opposed to
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part of the services you provided to all of
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your members in issuing blanket licenses?
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MS. LeMOINE:
Objection to form.
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MR. JOHNSON:
Objection.
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A
I really don't know.
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Q
What services did ASCAP provide to
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Summy-Birchard in the period from 1974
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through 1979?
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MS. LeMOINE:
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Speculation.
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A
Objection to form.
Well, you know, apart from the
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documents that we already produced I'm
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unaware of any specific services.
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Q
Okay, that's fine.
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Does ASCAP have any interest in
the music it licenses?
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A
Again, we produced documents that
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I believe make clear whatever interest ASCAP
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has.
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have no interest in the copyrights
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themselves.
I also said in my declaration that we
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Q
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music?
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Do you have any interest in the
MR. JOHNSON:
Objection.
That's
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also beyond the scope of the topics
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here.
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very specific.
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royalties interest in any copyrights.
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Interest in any fees or
MR.RIFKIN:
Okay.
Are you going
to instruct him not to answer?
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Your topics about interest are
MR. JOHNSON:
Well, are you
insisting -- are you continuing --
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MR.RIFKIN:
I asked a question.
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simply asked a question as a yes or no
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answer.
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to answer go ahead, if not, let him
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I
answer and we can move on.
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If you want to instruct him not
MR. JOHNSON:
First, I'm going to
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object to the form of the question.
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Second, I'm going to instruct him not to
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answer.
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MR.RIFKIN:
Q
Okay, that's fine.
Does ASCAP have any interest in
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the copyright or any copyright to the song
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Happy Birthday To You?
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A
Again, I think my response is that
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the documents we produced speak for
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themselves.
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Q
Did ASCAP ever have any interest
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in any copyright to the song Happy Birthday
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To You?
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A
I would make the same response I
just made.
Q
Can you answer that yes or no for
the record, please?
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I will answer it by saying I think
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the documents we produced are
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self-explanatory.
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Q
Do you know if any of those
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documents identify any interest in the
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copyright that ASCAP has the copyright to the
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song Happy Birthday To You?
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MS. LeMOINE:
Objection.
Vague.
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MR. JOHNSON:
Objection.
This is
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also -- he's already testified to this
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in his declaration in this case.
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know what the answer is.
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try to suggest on the record that he
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hasn't already provided this information
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to you.
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MR.RIFKIN:
You
So let's not
I simply want him to
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