Rupa Marya v. Warner Chappell Music Inc
Filing
224
EX PARTE APPLICATION MOTION for Consideration of Newly Discovered Evidence "Mistakenly" Withheld by Defendants During Discovery, EX PARTE APPLICATION for Summary Judgment as to First Claim for Relief filed by Plaintiffs Majar Productions LLC, Rupa Marya, Robert Siegel. (Attachments: # 1 Proposed Order) (Manifold, Betsy)
8
FRANCIS M. GREGOREK (144785)
gregorek@whafh.com
BETSY C. MANIFOLD (182450)
manifold@whafh.com
RACHELE R. RICKERT (190634)
rickert@whafh.com
MARISA C. LIVESAY (223247)
livesay@whafh.com
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
750 B Street, Suite 2770
San Diego, CA 92101
Telephone: 619/239-4599
Facsimile: 619/234-4599
9
Attorneys for Plaintiffs
1
2
3
4
5
6
7
10
UNITED STATES DISTRICT COURT
11
CENTRAL DISTRICT OF CALIFORNIA
12
WESTERN DIVISION
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
)
)
)
)
Plaintiffs,
)
)
v.
)
WARNER/CHAPPELL MUSIC, )
)
INC., et al.,
)
)
Defendants.
)
)
)
)
)
)
)
)
)
)
GOOD MORNING TO YOU
PRODUCTIONS CORP., et al.,
Case No. CV 13-04460-GHK (MRWx)
PLAINTIFFS’ EX PARTE
APPLICATION TO HAVE THE COURT
CONSIDER NEWLY DISCOVERY
EVIDENCE “MISTAKENLY”
WITHHELD BY DEFENDANTS
DURING DISCOVERY AND ENTER
SUMMARY JUDGMENT IN
PLAINTIFFS’ FAVOR
Judge:
Courtroom:
Fact Discovery Cutoff:
MSJ Hearings
Pretrial Conference:
Trial:
Hon. George H.
King, Chief Judge
650
July 11, 2014
March 23, 2015
and July 29, 2015
N/A
N/A
1
I.
INTRODUCTION
2
Plaintiffs make this ex parte application to have the Court (i) enter an Order
3
permitting Plaintiffs to supplement the record with the newly-discovered evidence
4
that Defendants “mistakenly” withheld during discovery; (ii) consider the newly-
5
discovered evidence in ruling on the pending Joint Cross-Motions for Summary
6
Judgment (“Summary Judgment Motions”) (Dkt. 179, 181, 182); and (iii) enter
7
summary judgment in Plaintiffs’ favor on the basis of the newly-discovered evidence
8
that proves conclusively that Happy Birthday has been in the public domain since no
9
later than 1922.
10
On July 13, 2015, Defendants gave Plaintiffs access to a database of
11
approximately 500 pages of documents, including approximately 200 pages of
12
documents they claim were “mistakenly” not produced during discovery, which
13
ended on July 11, 2014, more than one year earlier. 1 See Declaration of Betsy C.
14
Manifold in Support of Ex Parte Application (“Manifold Decl.”), ¶¶ 5,8, 9. One of
15
those documents – a 1927 publication of the Happy Birthday song that was expressly
16
authorized by defendants’ predecessor the Clayton F. Summy Co. – is a proverbial
17
smoking-gun. Id., Exhibits (“Ex.”) A and B. It and earlier versions of the song that
18
Plaintiffs subsequently located through their own investigative efforts conclusively
19
prove that any copyright that may have existed for the song itself (i.e., the setting of
20
the Happy Birthday lyrics to the melody of Good Morning) expired decades ago.
21
This newly-discovered evidence is fully consistent with Plaintiffs’ arguments
22
that (i) Patty Hill gave the lyrics to the public when she wrote them as a version of
23
the song she wrote with her sister Mildred Hill and (ii) that the 1935 copyrights
24
25
26
27
1
The initially set fact discovery deadline of June 27, 2014 (Dkt. 92) was
extended by Magistrate Judge Wilner, in consultation with this Court, and at the
request of both parties, to July 11, 2014. (Dkt. 119).
28
-1-
1
covered only specific piano arrangements of the song. More importantly, it trumps
2
all of Defendants’ arguments.
3
Plaintiffs are mindful of the Court’s order directing the parties not to
4
supplement the summary judgment record when they submitted their supplemental
5
joint brief on whether Patty Hill abandoned any copyright to the Happy Birthday
6
lyrics. Dkt. 215 at 1. However, because the documents prove conclusively that the
7
song is in the public domain, thus making it unnecessary for the Court to decide the
8
scope or validity of the disputed copyrights, much less whether Patty Hill abandoned
9
any copyright she may have had to the lyrics – indeed, all those issues become moot
10
– Plaintiffs are compelled to bring them to the Court’s attention now, before more
11
time is needlessly spent on the pending Summary Judgment Motions and before the
12
oral argument scheduled for July 29, 2015 (Dkt.222).2
13
Pursuant to L.R. 7-19.1, Plaintiffs orally notified Defendants’ counsel on July
14
24, 2015 at 1:20 p.m. about this ex parte application. Details are provided both
15
below and in the Manifold Declaration.
16
Absent this relief, the Court will waste judicial resources in determining and
17
hearing further argument on the extensive Joint Cross Motions for Summary
18
Judgment filed by the parties in November 2014 because the evidence withheld by
19
Defendants during discovery and Plaintiffs’ investigation prompted by the withheld
20
evidence readily resolves the key issues in Plaintiffs’ favor. Plaintiffs are not at fault
21
in the need for this ex parte relief, any prejudice to Defendants was created by their
22
own conduct in “mistakenly” withholding evidence and good cause exists for the
23
review of this newly discovered evidence by the Court and the grant of Summary
24
25
26
27
28
2
Because the publication is definitive proof that there is no longer any
copyright for Happy Birthday, we are not asking the Court to permit us to submit any
of these additional documents described in the Manifold Declaration (¶ 10) at this
time. However, Plaintiffs expressly reserve their right to do so at a later time as may
be necessary or appropriate.
-2-
1
Judgment in Plaintiffs’ favor.
2
II.
3
CONTACT INFORMATION FOR OPPOSING COUNSEL
Pursuant to Local Rule 7-19, Plaintiffs provide the following contact
4
information for opposing counsel:
5
Kelly M. Klaus
Glen Pomerantz
Adam I. Kaplan
Melinda E. LeMoine
MUNGER TOLLES & OLSON LLP
MUNGER TOLLES & OLSON LLP
560 Mission St., 27th Floor
355 South Grand Ave., 35th Floor
San Francisco, CA 94105
Los Angeles, CA 90071
Telephone: 415/512-4000
Telephone: 213/683-9100
kelly.klaus@mto.com
glenn.pomerantz@mto.com
adam.kaplan@mto.com
melinda.lemoine@mto.com
6
7
8
9
10
11
12
13
14
Pursuant to Local Rule 7-19.1, on July 24, 2015, at 1:20 p.m., Plaintiffs
15
informed counsel for Defendants (Adam Kaplan and Kelly Klaus) that they intended
16
to file this application on July 27, 2015. Defendants advised Plaintiffs that they did
17
not oppose the submission of this newly discovered evidence to the Court but will
18
provide a written response opposing the grant of summary judgment in Plaintiffs’
19
favor. Manifold Decl., ¶ 3. On July 27, 2015, Plaintiffs electronically served a copy
20
of this ex parte application and supporting papers on Defendants’ counsel prior to
21
filing. Id., ¶ 4. No hearing date is requested, but, if the Court determines that a
22
hearing would be helpful, Plaintiffs could appear at any time convenient for the
23
Court and will be prepared to address this application at July 29, 2015 oral argument.
24
III.
FACTUAL BACKGROUND
25
In 1927, The Cable Co. (“Cable”), a Chicago music publisher, published the
26
15th edition of a compilation of children’s songs called The Everyday Song Book
27
(Graded). On July 13, 2015, Defendants provided Plaintiffs with access to an FTP
28
site that included (among several other documents) a PDF copy of the 15th edition of
-3-
1
The Everyday Song Book. See Manifold Decl., ¶ 9. The 16th song in that edition of
2
The Everyday Song Book, appearing on the page marked WC0002424 by
3
Defendants, was entitled “Good Morning and Birthday Song.” Manifold Decl., Ex.
4
A. The Good Morning and Birthday Song consists of Mildred Hill’s melody for
5
Good Morning together with Patty Hill’s lyrics for both Good Morning and Happy
6
Birthday (if the Court finds that she wrote the Happy Birthday lyrics).
7
A line of text is printed directly below the song’s title in the song book. See
8
Manifold Decl., Ex. A. The line of text in the PDF copy provided by the Defendants
9
is blurred almost beyond legibility – curiously, it is the only line of the entire PDF
10
that is blurred in that manner. After Plaintiffs learned of the existence of The
11
Everyday Song Book, they promptly obtained original samples of the first, fourth,
12
and 15th editions of the book. See Manifold Decl., ¶¶ 11,12, Ex. B. The line of text
13
(illegibly blurred in the PDF copy provided by Defendants, but clearly printed in
14
Exhibit B) reads as follows: “Special permission through courtesy of The Clayton F.
15
Summy Co.” Unlike other individual works in the book, for which a copyright was
16
identified, no copyright was claimed or identified for the Good Morning and
17
Birthday Song.
18
The first edition of The Everyday Song Book, published in 1916, did not
19
include the Good Morning and Happy Birthday song. However, Plaintiffs obtained
20
samples of earlier editions of The Everyday Song Book. A revised fourth edition,
21
published in 1922, included the Good Morning and Birthday Song. See Manifold
22
Decl., Ex. C. The Good Morning and Birthday Song also appeared, with the same
23
legend but without a copyright notice, in the 15th editions of The Everyday Song
24
Book.
25
Publication of the Good Morning and Birthday Song in The Everyday Song
26
Book in 1922 and thereafter, with Summy’s authorization but without a copyright
27
notice, is fully consistent with Plaintiffs’ position that the Happy Birthday lyrics had
28
been dedicated to the public many years before then. Because the lyrics were in the
-4-
1
public domain, there was no reason for a copyright notice to be set forth in the song
2
book. Moreover, the authorized publication of the Good Morning and Birthday Song
3
in 1922 without a copyright notice also is fully consistent with Plaintiffs’ position
4
that the 1935 copyrights (E51988 and E51990) covered only the specific piano
5
arrangements written by Summy’s employees Orem and Forman (as well as the
6
second verse written by Forman). Since the lyrics were already in the public domain
7
long before 1935, there was nothing else to be copyrighted other than the new work
8
that Summy’s employees contributed when those copyrights were registered.3
9
IV.
LEGAL STANDARD
10
An application for ex parte relief is granted when (1) the moving party would
11
be “irreparably prejudiced if the underlying motion is heard according to regular
12
noticed motion procedures” and (2) the moving party is without fault in creating the
13
situation requiring ex parte relief. Mission Power Engineering Co. v. Continental
14
Casualty Co., 883 F. Supp. 488, 492 (C.D. Cal. 1995).
15
A pre-trial scheduling order may be modified “upon a showing of good cause.”
16
Fed. R. Civ. P. 16(b)(4); Zivkovic v. Southern California Edison Co., 302 F.3d 1080,
17
1087 (9th Cir. 2002). Good cause is shown if the schedule “cannot reasonably be met
18
19
20
21
22
23
24
25
26
27
28
3
The Everyday Song Book also flatly contradicts two of defendants’ so-called
“undisputed” facts in the Corrected Joint Statement of Uncontroverted Facts [Dkt.
183] filed on Dec. 1, 2014:
There is no evidence that Clayton F. Summy Co. ever authorized, prior to
1936, any “publication” (for purposes of the Copyright Act of 1909) of the
lyrics of Happy Birthday to You by a different person or entity. D57.
There is no evidence that Clayton F. Summy Co. was ever aware, prior to
1936, of any “publication” (for purposes of the Copyright Act of 1909) of the
lyrics of Happy Birthday to You by a different person or entity. D56.
Summy expressly authorized the Happy Birthday lyrics to be published in the Good
Morning and Birthday Song in the second edition of the Everyday Song Book. Since
Summy expressly authorized publication of the Good Morning and Birthday Song in
1922, it was certainly aware of the publication prior to 1936.
-5-
1
despite the diligence of the party seeking the extension.” Photomedex, Inc. v. Irwin,
2
No. 04-CV-0024, 2007 U.S. Dist. LEXIS 56774, at *4.
3
Plaintiffs meet the requirements for ex parte relief and for the underlying
4
request to have the Court consider newly discovered evidence “mistakenly” withheld
5
by Defendants during discovery and during the extensive briefing of cross-motions
6
for Summary Judgment and, therefore, respectfully request that the Court grant this
7
application and enter Summary Judgment in favor of Plaintiffs.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
A.
The Court Should Exercise Its Discretion to Consider
This Newly Discovered Evidence
This Court has broad discretion to permit a litigant to supplement the factual
record on the cross-motions for summary judgment. Bell v. City of Los Angeles, 835
F. Supp. 2d 836, 848 (C.D. Cal. 2011) (Matz, J.) (citing Betz v. Trainer Wortham &
Co., 610 F.3d 1169, 1171 (9th Cir. 2010)); Fed. R. Civ. P. (“Rule”) 56(e). District
courts in the Ninth Circuit routinely allow parties to supplement the summary
judgment record with newly-discovered evidence. See, e.g., George v. Northwestern
Mut. Life Ins. Co., 2011 U.S. Dist. LEXIS 99454, *9-10 (W.D. Wash. Sept. 1, 2011);
LimoStars, Inc. v. N.J. Car & Limo, Inc., 2011 U.S. Dist. LEXIS 87771, *11 (D.
Ariz. Aug. 8, 2011) (citing United States v. Maris, 2011 U.S. Dist. LEXIS 15088, * 5
n. 5 (D.Nev. Feb. 4, 2011); Mitchel v. Holder, 2010 U.S. Dist. LEXIS 21088, * 1 n.1
(N.D. Cal., Mar. 9, 2010). As the Supreme Court explained in Celotex Corp. v.
Catrett, 477 U.S. 317, 327 (1986) (quoting Fed. R. Civ. P. 1), permitting an
amendment to consider newly-discovered evidence is “an integral part of the Federal
Rules as a whole, which are designed ‘to secure the just, speedy and inexpensive
determination of every action.’”
The Court previously directed the parties not to supplement the summary
judgment record when they submitted the supplemental joint brief on whether Patty
Hill abandoned any copyright to the Happy Birthday lyrics. Dkt. 215 at 1. However,
Plaintiffs prepared their motion for summary judgment, their portion of the Corrected
Joint Statement of Uncontroverted Facts, and their portion of the Joint Appendix
-6-
1
before they learned of the publication of The Everyday Song Book, which Defendants
2
“mistakenly” withheld from production during discovery.4 This was through
3
absolutely no fault of Plaintiffs, who acted diligently immediately after obtaining
4
access to the 1927 edition of that compilation.
5
Now that this evidence has been uncovered, fairness, economy, and due
6
process compel the Court to exercise its discretion to allow Plaintiffs to supplement
7
the record, to consider the newly-discovered evidence – which proves conclusively
8
that there is no copyright to the Happy Birthday lyrics – and to decide the cross-
9
motions for summary judgment in Plaintiffs’ favor based upon this newly-discovered
10
evidence.
11
B.
12
13
14
15
16
The Newly-Discovered Evidence Proves Conclusively That
the Happy Birthday Lyrics Entered the Public Domain No
Later Than 1922
Under Section 9 of the 1909 Copyright Act, “any person entitled thereto by
this Act may secure copyright for his work by publication thereof with the notice of
copyright required by this Act” affixed to all copies of the work. 17 U.S.C. § 9.5 At a
minimum, Section 18 of the 1909 Copyright Act required the notice to include the
17
18
19
20
21
22
23
24
25
26
27
28
4
Defendants have provided no details of the nature of their so-called “mistake”
in not producing any of these documents before discovery ended on July 11, 2014,
such as when they were first discovered, where they were stored, how they were
located, who located them, and the nature of defendants’ “mistake” in not timely
producing the documents. Timely production of documents, and in particular the
1927 publication of the Good Morning and Birthday Song, would have affected
Plaintiffs’ conduct of discovery, their briefing on the cross-motions for summary
judgment, and (no doubt) the Court’s consideration of the summary judgment crossmotions. Plaintiffs reserve all of their rights regarding Defendants’ untimely
production of the documents.
5
At the initial hearing on the cross-motions for summary judgment, defendants’
counsel admitted that a copyright was not obtained unless the work was published
with the requisite notice: “What was necessary was publication with notice.” Dkt.
208 at 7:24.
-7-
1
word “Copyright,” the abbreviation “Copr., ” or the “©” symbol as well as the year
2
of first publication and the name of the author of the copyrighted work. 17 U.S.C. §
3
18. If the strict notice requirements of the 1909 Copyright Act were not met, the
4
“published work was interjected irrevocably into the public domain.” Twin Books
5
Corp. v. Walt Disney Co., 83 F.3d 1162, 1165 (9th Cir. 1996) (emphasis added).
6
None of these notice requirements was met for the Good Morning and Birthday Song
7
included in the fourth edition of The Everyday Song Book published in 1922.6
8
Forfeiture occurs for individual works included with the author’s permission in
9
a compilation published by another person. With few exceptions, none of which
10
apply here, when an individual work is included in a compilation and the copyright
11
notice includes only the compilation publisher’s name, the author of the individual
12
work loses his copyright and the author’s work falls into the public domain. See New
13
York Times Co. v. Tasini, 533 U.S. 483, 494-95 (2001). Copyright in the individual
14
work is forfeited and the work falls into the public domain when, as here, it is
15
published as part of a collective work with permission of the author but without a
16
copyright notice in the name of its author. Milton H. Green Archives, Inc., v. BPI
17
Communs., Inc., 378 F. Supp. 2d 1189, 1195-97 (C.D. Cal. 2005) (copyright notice
18
must be issued “in the name of the copyright holder, not merely in the name of the
19
publishing newspaper, magazine or campaign book) (citing Tasini, 533 U.S. at 494
20
(2001).
21
22
23
24
25
26
27
28
6
Because Cable attributed Good Morning and Birthday Song to Summy Co.,
Cable’s copyright in the compilation did not cover that individual work. Under
Section 24 of the 1909 Copyright Act, the proprietor of a compilation owns
copyrights “in the collective itself (i.e., the collection, arrangement, and display of
the constituent parts) and any individual contributions that it initially held copyright
ownership in,” but not in the work of others included with their permission. Faulkner
v. Nat’l Geographic Soc’y, 220 F. Supp. 237, 239 (S.D.N.Y. 2002) (citing SelfRealization Fellowship Church v. Ananda Church of Self-Realization, 206 F.3d 1322,
1329-30 (9th Cir. 2000), cert. denied, 531 U.S. 1126 (2001) (compilation copyright
does not include copyright in work of others included in compilation)).
-8-
1
Thus, Cable’s failure to include a mandatory copyright notice, as required by
2
the 1909 Copyright Act, meant that the Happy Birthday lyrics would have been
3
“interjected irrevocably into the public domain” upon the publication in 1922, had
4
they not already been given to the public by Patty Hill many years before.
5
After learning of the Everyday Song Book, Plaintiffs also promptly
6
investigated the copyrights for the various editions of the work. We have discovered
7
the following copyrights, and no others, for The Everyday Song Book:
Reg. No. A453345, for the first edition, filed on Aug. 5, 1916 (which
8
did not include the Good Morning and Birthday Song); and
9
Reg. No. A624750 for a revised edition, filed on Oct. 6, 1921 (which
10
included the Good Morning and Birthday Song).7
11
12
Neither of those two copyrights was ever renewed – not by Cable or by
13
Summy. Thus, for A453345, the copyright expired 28 years later on Aug. 5, 1944,
14
and for A624750, the copyright expired on Oct. 6, 1949. Whatever work those two
15
copyrights may have protected, it is now unquestionably in the public domain.
16
Therefore, even if the Court overlooks the absence of a copyright notice in the 1922
17
publication of the fourth edition of The Everyday Song Book and does not determine
18
that the Happy Birthday lyrics passed into the public domain when published in 1922
19
(if Patty Hill had not already given them to the public), then the copyright expired no
20
later than 1950 when it was not renewed. Of course, even if federal copyright for the
21
Happy Birthday melody and lyrics were properly gained by publication with notice
22
in 1922 (which it was not), and that copyright had been properly renewed in 1949
23
(which it was not), the song would have fallen into the public domain at midnight on
24
December 31, 1997. See 17 U.S.C. § 304, n.7 (explaining that, before the enactment
25
26
27
28
7
See Manifold Decl., Exs. D and E. Plaintiffs believe the revised edition for
which this copyright was obtained was not published until 1922 (i.e., as the fourth
edition of The Everyday Song Book), which therefore bears the copyright date of
1922.
-9-
1
of the Sonny Bono Copyright Term Extension Act on October 27, 1998, § 304(b) of
2
the Copyright Act granted a term of copyright of 75 years – which § 305 extended to
3
the end of the calendar year – for all works still in their renewal period as of
4
December 31, 1976). Thus, given the authorized publication of Happy Birthday in
5
1922 without a copyright notice, there is no conceivable set of facts under which the
6
song would be under copyright after December 31, 1997.
7
Because the untimely, thirteenth-hour discovery from defendants conclusively
8
resolves this part of the copyright dispute and renders consideration of all other
9
issues presently before the Court moot, we respectfully request that the Court
10
consider The Everyday Song Book as definitive proof that the copyright for Happy
11
Birthday was forfeited in 1922 or, in the alternative, that any copyright for Happy
12
Birthday expired in 1949.
13
V.
CONCLUSION
14
For the reasons stated above, Plaintiffs respectfully submit that this Ex Parte
15
Application should be granted. The Court should (i) enter an Order permitting
16
Plaintiffs to supplement the record with the newly-discovered evidence that
17
Defendants “mistakenly” withheld during discovery; (ii) consider the newly-
18
discovered evidence in ruling on the pending cross-motions for summary judgment;
19
and (iii) enter summary judgment in Plaintiffs’ favor on the basis of the newly-
20
discovered evidence that proves conclusively that Happy Birthday has been in the
21
public domain since no later than 1922.
22
Dated: July 27, 2015
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
23
24
25
26
27
28
By:
/s/ Betsy C. Manifold
BETSY C. MANIFOLD
FRANCIS M. GREGOREK
gregorek@whafh.com
BETSY C. MANIFOLD
manifold@whafh.com
- 10 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
RACHELE R. RICKERT
rickert@whafh.com
MARISA C. LIVESAY
livesay@whafh.com
750 B Street, Suite 2770
San Diego, CA 92101
Telephone: 619/239-4599
Facsimile: 619/234-4599
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
MARK C. RIFKIN (pro hac vice)
rifkin@whafh.com
JANINE POLLACK (pro hac vice)
pollack@whafh.com
270 Madison Avenue
New York, NY 10016
Telephone: 212/545-4600
Facsimile: 212-545-4753
15
Interim Lead Counsel for Plaintiffs
16
RANDALL S. NEWMAN PC
RANDALL S. NEWMAN (190547)
rsn@randallnewman.net
37 Wall Street, Penthouse D
New York, NY 10005
Telephone: 212/797-3737
17
18
19
20
21
22
23
24
25
26
27
28
HUNT ORTMANN PALFFY NIEVES
DARLING & MAH, INC.
ALISON C. GIBBS (257526)
gibbs@huntortmann.com
OMEL A. NIEVES (134444)
nieves@huntortmann.com
KATHLYNN E. SMITH (234541)
smith@ huntortmann.com
301 North Lake Avenue, 7th Floor
Pasadena, CA 91101
Telephone 626/440-5200
Facsimile 626/796-0107
- 11 -
DONAHUE FITZGERALD LLP
WILLIAM R. HILL (114954)
rock@donahue.com
ANDREW S. MACKAY (197074)
andrew@donahue.com
DANIEL J. SCHACHT (259717)
daniel@donahue.com
1999 Harrison Street, 25th Floor
Oakland, CA 94612-3520
Telephone: 510/451-0544
Facsimile: 510/832-1486
1
2
3
4
5
6
7
8
9
GLANCY BINKOW & GOLDBERG LLP
LIONEL Z. GLANCY (134180)
lglancy@glancylaw.com
MARC L. GODINO (188669)
mgodino@glancylaw.com
1925 Century Park East, Suite 2100
Los Angeles, CA 90067
Telephone: 310/201-9150
Facsimile: 310/201-9160
10
11
12
13
14
15
16
Attorneys for Plaintiffs
17
18
19
20
21
22
23
24
25
26
27
28
WARNER/CHAPPELL:21970.exparte
- 12 -
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?