Bryan Pringle v. William Adams Jr et al

Filing 102

ANSWER to Amended Complaint,,, 9 filed by Defendant EMI April Music Inc.(Pink, Jonathan)

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1 BRYAN CAVE LLP Jonathan Pink, California Bar No. 179685 2 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 3 Telephone: (949) 223-7000 Facsimile: (949) 223-7100 jonathan.pink@bryancave.com 4 E-mail: 5 BRYAN CAVE LLP Kara E. F. Cenar, (Pro Hac Vice) 6 Mariangela M. Seale, (Pro Hac Vice) 161 North Clark Street, Suite 4300 7 Chicago, IL 60601-3315 Telephone: (312) 602-5000 8 Facsimile: (312) 602-5050 E-mail: Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 kara.cenar@bryancave.com merili.seale@bryancave.com 10 Attorneys for Defendants WILLIAM ADAMS; STACY FERGUSON; ALLAN PINEDA; JAIME GOMEZ; all individually and collectively as the music group 11 THE BLACK EYED PEAS; TAB MAGNETIC PUBLISHING; HEADPHONE JUNKIE PUBLISHING, LLC; will.i.am. music, llc; JEEPNEY MUSIC, INC.; 12 CHERRY RIVER MUSIC CO.; and EMI APRIL MUSIC, INC. 13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION 15 BRYAN PRINGLE, an individual, Plaintiff, 16 v. 17 18 WILLIAM ADAMS, JR.; STACY FERGUSON; ALLAN PINEDA; and 19 JAIME GOMEZ, all individually and collectively as the music group the 20 Black Eyed Peas; DAVID GUETTA; 21 22 23 24 25 FREDERICK RIESTERER; UMG RECORDINGS, INC.; INTERSCOPE RECORDS; EMI APRIL MUSIC, INC.; HEADPHONE JUNKIE PUBLISHING, LLC; WILL.I.AM. MUSIC, LLC; JEEPNEY MUSIC, INC.; TAB MAGNETIC PUBLISHING; CHERRY RIVER MUSIC CO.; SQUARE RIVOLI PUBLISHING; RISTER EDITIONS; and SHAPIRO, BERNSTEIN & CO., 26 Defendants. 27 28 CH01DOCS154690.5 Case No. SACV10-1656 JST(RZx) Hon. Josephine Staton Tucker Courtroom 10A DEFENDANT EMI APRIL MUSIC, INC. ANSWER AND AFFIRMATIVE DEFENSES Complaint Filed: Trial Date: October 28, 2010 Not Assigned Defendant EMI April Music, Inc. (“Defendant EMI April Music”) presents 1 2 the following Answer and Defenses to Plaintiff’s First Amended Complaint 3 (“Complaint”): INTRODUCTION 4 5 1. Answering paragraph 1, Defendant EMI April Music denies the allegations in 6 this paragraph. 7 2. Answering paragraph 2, Defendant EMI April Music admits that Plaintiff’s 8 Complaint seeks certain relief, but denies that he is entitled to such relief, and denies Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 all remaining allegations of the paragraph. 10 3. Answering paragraph 3, Defendant EMI April Music lacks sufficient 11 information to admit or deny the allegations contained in paragraph 3, and on that 12 basis denies each and every such allegation. 13 4. Answering paragraph 4, Defendant EMI April Music denies the allegations in 14 this paragraph. 15 5. Answering paragraph 5, Defendant EMI April Music denies the allegations in 16 this paragraph. 17 6. Answering paragraph 6, Defendant EMI April Music admits that legitimate 18 copyright owners have rights defined by the law, but denies the remaining 19 allegations of this paragraph. JURISDICTION AND VENUE 20 21 7. Answering paragraph 7, Defendant EMI April Music admits, on information 22 and belief, that this action appears to arise out of claims under the Copyright Act, 23 and that this Court would appear to have subject matter jurisdiction. Defendant EMI 24 April Music denies that the Complaint states a cause of action upon which relief can 25 be granted. 26 8. Answering paragraph 8, Defendant EMI April Music lacks sufficient 27 information to admit or deny the allegations contained in paragraph 8, and on that 28 basis denies each and every such allegation. Defendant EMI April Music does not CH01DOCS154690.5 1 ANSWER 1 dispute venue over Defendant EMI April Music. GENERAL ALLEGATIONS 2 3 A. Parties 4 9. Answering paragraph 9, Defendant EMI April Music lacks sufficient 5 information to admit or deny the allegations contained in paragraph 9, and on that 6 basis denies each and every such allegation. 7 10. Answering paragraph 10, Defendant EMI April Music lacks sufficient 8 information to admit or deny the allegations contained in paragraph 10, and on that Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 basis denies each and every such allegation, except that Defendant Adams is a 10 member of The Black Eyed Peas. 11 11. Answering paragraph 11, Defendant EMI April Music lacks sufficient 12 information to admit or deny the allegations contained in paragraph 11, and on that 13 basis denies each and every such allegation, except that Defendant Ferguson is a 14 member of The Black Eyed Peas. 15 12. Answering paragraph 12, Defendant EMI April Music lacks sufficient 16 information to admit or deny the allegations contained in paragraph 12, and on that 17 basis denies each and every such allegation, except that Defendant Pineda is a 18 member of The Black Eyed Peas. 19 13. Answering paragraph 13, Defendant EMI April Music lacks sufficient 20 information to admit or deny the allegations contained in paragraph 13, and on that 21 basis denies each and every such allegation, except that Defendant Gomez is a 22 member of The Black Eyed Peas. 23 14. Answering paragraph 14, Defendant EMI April Music lacks sufficient 24 information to admit or deny the allegations contained in paragraph 14, and on that 25 basis denies each and every such allegation. 26 15. Answering paragraph 15, Defendant EMI April Music lacks sufficient 27 information to admit or deny the allegations contained in paragraph 15, and on that 28 basis denies each and every such allegation. CH01DOCS154690.5 2 ANSWER 1 16. Answering paragraph 16, Defendant EMI April Music lacks sufficient 2 information to admit or deny the allegations contained in paragraph 16, and on that 3 basis denies each and every such allegation. 4 17. Answering paragraph 17, Defendant EMI April Music lacks sufficient 5 information to admit or deny the allegations contained in paragraph 17, and on that 6 basis denies each and every such allegation. 7 18. Answering paragraph 18, Defendant EMI April Music admits that Defendant 8 EMI April Music, Inc. is a music publishing company. Defendant EMI April Music Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 admits that it is one of the publishers of the song “I Gotta Feeling.” Defendant EMI 10 April Music lacks sufficient information to admit or deny the remaining allegations 11 contained in paragraph 18, and on that basis denies each and every such allegation. 12 19. Answering paragraph 19, Defendant EMI April Music lacks sufficient 13 information to admit or deny the allegations contained in paragraph 19, and on that 14 basis denies each and every such allegation. 15 20. Answering paragraph 20, Defendant EMI April Music lacks sufficient 16 information to admit or deny the allegations contained in paragraph 20, and on that 17 basis denies each and every such allegation. 18 21. Answering paragraph 21, Defendant EMI April Music lacks sufficient 19 information to admit or deny the allegations contained in paragraph 21, and on that 20 basis denies each and every such allegation. 21 22. Answering paragraph 22, Defendant EMI April Music lacks sufficient 22 information to admit or deny the allegations contained in paragraph 22, and on that 23 basis denies each and every such allegation. 24 23. Answering paragraph 23, Defendant EMI April Music lacks sufficient 25 information to admit or deny the allegations contained in paragraph 23, and on that 26 basis denies each and every such allegation. 27 24. Answering paragraph 24, Defendant EMI April Music lacks sufficient 28 information to admit or deny the allegations contained in paragraph 24, and on that CH01DOCS154690.5 3 ANSWER 1 basis denies each and every such allegation. 2 25. Answering paragraph 25, Defendant EMI April Music lacks sufficient 3 information to admit or deny the allegations contained in paragraph 25, and on that 4 basis denies each and every such allegation. 5 26. Answering paragraph 26, Defendant EMI April Music lacks sufficient 6 information to admit or deny the allegations contained in paragraph 26, and on that 7 basis denies each and every such allegation. Plaintiff’s Creation and Protection of His Original Work 9 27. Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 8 B. Answering paragraph 27, Defendant EMI April Music lacks sufficient 10 information to admit or deny the allegations contained in paragraph 27, and on that 11 basis denies each and every such allegation. 12 28. Answering paragraph 28, Defendant EMI April Music lacks sufficient 13 information to admit or deny the allegations contained in paragraph 28, and on that 14 basis denies each and every such allegation. 15 29. Answering paragraph 29, Defendant EMI April Music lacks sufficient 16 information to admit or deny the allegations contained in paragraph 29, and on that 17 basis denies each and every such allegation. 18 30. Answering paragraph 30, Defendant EMI April Music lacks sufficient 19 information to admit or deny the allegations contained in paragraph 30, and on that 20 basis denies each and every such allegation. 21 C. Defendants’ Access to and Copying of Plaintiff’s Copyrighted Song “Take a 22 Dive” 23 31. Answering paragraph 31, Defendant EMI April Music lacks sufficient 24 information to admit or deny the allegations contained in paragraph 31, and on that 25 basis denies each and every such allegation. 26 32. Answering paragraph 32, Defendant EMI April Music lacks sufficient 27 information to admit or deny the allegations contained in paragraph 32, and on that 28 basis denies each and every such allegation. CH01DOCS154690.5 4 ANSWER 1 33. Answering paragraph 33, Defendant EMI April Music lacks sufficient 2 information to admit or deny the allegations contained in paragraph 33, and on that 3 basis denies each and every such allegation. 4 34. Answering paragraph 34, Defendant EMI April Music lacks sufficient 5 information to admit or deny the allegations contained in paragraph 34, and on that 6 basis denies each and every such allegation. 7 35. Answering paragraph 35, Defendant EMI April Music lacks sufficient 8 information to admit or deny the allegations contained in paragraph 35, and on that Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 basis denies each and every such allegation. 10 36. Answering paragraph 36, Defendant EMI April Music lacks sufficient 11 information to admit or deny the allegations contained in paragraph 36, and on that 12 basis denies each and every such allegation. 13 37. Answering paragraph 37, Defendant EMI April Music lacks sufficient 14 information to admit or deny the allegations contained in paragraph 37, and on that 15 basis denies each and every such allegation. 16 38. Answering paragraph 38, Defendant EMI April Music denies that any 17 “authorization” was required, and the remaining allegations are denied. 18 39. Answering paragraph 39, Defendant EMI April Music denies the allegations 19 in this paragraph. 20 D. Substantial Similarity Between “Take a Dive” and “I Gotta Feeling” 21 40. Answering paragraph 40, Defendant EMI April Music lacks sufficient 22 information to admit or deny the allegations contained in paragraph 40, and on that 23 basis denies each and every such allegation. 24 41. Answering paragraph 41, Defendant EMI April Music lacks sufficient 25 information to admit or deny the allegations contained in paragraph 41, and on that 26 basis denies each and every such allegation. 27 42. Answering paragraph 42, Defendant EMI April Music lacks sufficient 28 information to admit or deny the allegations contained in paragraph 42, and on that CH01DOCS154690.5 5 ANSWER 1 basis denies each and every such allegation. 2 43. Answering paragraph 43, Defendant EMI April Music lacks sufficient 3 information to admit or deny the allegations contained in paragraph 43, and on that 4 basis denies each and every such allegation. 5 E. The Aftermath of “I Gotta Feeling’s” Release 6 44. Answering paragraph 44, Defendant EMI April Music admits, on information 7 and belief, that I Gotta Feeling was released in or around June 2009 and was the 8 second single off of the group’s album The E.N.D. Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 45. Answering paragraph 45, Defendant EMI April Music lacks sufficient 10 information to admit or deny the allegations contained in paragraph 45, and on that 11 basis denies each and every such allegation. 12 46. Answering paragraph 46, Defendant EMI April Music denies the allegations 13 in this paragraph. 14 F. Defendants’ Conspiracy to Engage in and Conduct a Pattern and Practice of 15 Ongoing Willful Copyright Infringement as to Others 16 47. Answering paragraph 47, Defendant EMI April Music denies the allegations 17 in this paragraph. 18 48. Answering paragraph 48, Defendant EMI April Music denies the allegations 19 in this paragraph. 20 49. Answering paragraph 49, Defendant EMI April Music lacks sufficient 21 information to admit or deny the allegations contained in paragraph 49, and on that 22 basis denies each and every such allegation. 23 50. Answering paragraph 50, Defendant EMI April Music denies the allegations 24 in this paragraph. 25 51. Answering paragraph 51, Defendant EMI April Music denies the allegations 26 in this paragraph. 27 52. Answering paragraph 52, Defendant EMI April Music denies the allegations 28 in this paragraph. CH01DOCS154690.5 6 ANSWER 1 53. Answering paragraph 53, Defendant EMI April Music denies the allegations 2 in this paragraph. 3 54. Answering paragraph 54, Defendant EMI April Music denies the allegations 4 in this paragraph, except that Defendant EMI April Music admits that the song I 5 Gotta Feeling is and has been publically performed. 6 55. Answering paragraph 55, Defendant EMI April Music denies the allegations 7 in this paragraph. 8 56. Answering paragraph 56, Defendant EMI April Music denies the allegations Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 in this paragraph. 10 57. Answering paragraph 57, Defendant EMI April Music denies the allegations 11 in this paragraph. 12 58. Answering paragraph 58, Defendant EMI April Music denies the allegations 13 in this paragraph. 14 59. Answering paragraph 59, Defendant EMI April Music lacks sufficient 15 information to admit or deny the allegations contained in paragraph 59, and on that 16 basis denies each and every such allegation. 17 60. Answering paragraph 60, Defendant EMI April Music denies the allegations 18 in this paragraph. 19 COUNT I 20 Copyright Infringement Against All Defendants 21 61. Answering paragraph 61, Defendant EMI April Music incorporates its 22 answers and responses to paragraphs 1-60 herein, as if fully restated herein. 23 62. Answering paragraph 62, Defendant EMI April Music denies the allegations 24 in this paragraph that refer to Defendant EMI April Music. Defendant EMI April 25 Music lacks sufficient information to admit or deny the remaining allegations 26 contained in this paragraph, and therefore denies the remaining allegations. 27 63. Answering paragraph 63, Defendant EMI April Music denies the allegations 28 in this paragraph that refer to Defendant EMI April Music. Defendant EMI April CH01DOCS154690.5 7 ANSWER 1 Music lacks sufficient information to admit or deny the remaining allegations 2 contained in this paragraph, and therefore denies the remaining allegations. 3 64. Answering paragraph 64, Defendant EMI April Music denies the allegations 4 in this paragraph that refer to Defendant EMI April Music. Defendant EMI April 5 Music lacks sufficient information to admit or deny the remaining allegations 6 contained in this paragraph, and therefore denies the remaining allegations. 7 65. Answering paragraph 65, Defendant EMI April Music denies the allegations 8 in this paragraph that refer to Defendant EMI April Music. Defendant EMI April Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 Music lacks sufficient information to admit or deny the remaining allegations 10 contained in this paragraph, and therefore denies the remaining allegations. 11 66. Answering paragraph 66, Defendant EMI April Music denies the allegations 12 in this paragraph that refer to Defendant EMI April Music. Defendant EMI April 13 Music lacks sufficient information to admit or deny the remaining allegations 14 contained in this paragraph, and therefore denies the remaining allegations. 15 67. Answering paragraph 67, Defendant EMI April Music denies the allegations 16 in this paragraph that refer to Defendant EMI April Music. Defendant EMI April 17 Music lacks sufficient information to admit or deny the remaining allegations 18 contained in this paragraph, and therefore denies the remaining allegations. 19 68. Answering paragraph 68, Defendant EMI April Music denies the allegations 20 in this paragraph that refer to Defendant EMI April Music. Defendant EMI April 21 Music lacks sufficient information to admit or deny the remaining allegations 22 contained in this paragraph, and therefore denies the remaining allegations. 23 69. Answering paragraph 69, Defendant EMI April Music denies the allegations 24 in this paragraph that refer to Defendant EMI April Music. Defendant EMI April 25 Music lacks sufficient information to admit or deny the remaining allegations 26 contained in this paragraph, and therefore denies the remaining allegations. GENERAL RESPONSE 27 28 Answering generally to all paragraphs of the Complaint, unless specifically CH01DOCS154690.5 8 ANSWER 1 and expressly admitted, all allegations are denied. 2 Answering generally to the request for relief, Defendant EMI April Music 3 denies that the Complaint states a claim upon which relief should be granted, and 4 Defendant EMI April Music denies that Plaintiff is entitled to the relief requested. 5 Defendant EMI April Music respectfully requests that the Complaint be dismissed 6 with prejudice, and that Plaintiff’s request for relief be denied, and for an award of 7 its attorneys fees and costs. AFFIRMATIVE DEFENSES 9 Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 8 FIRST DEFENSE 10 (Failure to State A Claim) 11 1. The Complaint and all claims for relief alleged therein fail to state a 12 claim against Defendant upon which relief can be granted. 13 SECOND DEFENSE 14 (Laches) 15 2. The Complaint is barred in whole or in part by laches. 16 THIRD DEFENSE 17 (Failure to Mitigate) 18 3. Plaintiff has failed to mitigate and lessen damages, if any it sustained, 19 as required by law, and is barred from recovery by reason thereof against Defendant. 20 FOURTH DEFENSE 21 (17 U.S.C. § 411) 22 4. Plaintiff has failed to register the alleged copyrighted materials and, 23 therefore, is precluded from bringing a claim for copyright infringement pursuant to 24 17 U.S.C. § 411. 25 FIFTH DEFENSE 26 (17 U.S.C. § 412) 27 5. Plaintiff has failed to timely register the alleged copyrighted materials 28 and, therefore, is precluded from bringing a claim for statutory damages and CH01DOCS154690.5 9 ANSWER 1 attorneys’ fees pursuant to 17 U.S.C. § 412. 2 SIXTH DEFENSE 3 (Implied License) 4 6. Plaintiff’s claim and the relief requested is barred based on implied 5 license. 6 SEVENTH DEFENSE 7 (17 U.S.C. § 409) 8 7. Plaintiff’s claim and the relief requested is barred based on Plaintiff’s Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 failure to comply with 17 U.S.C. § 409. 10 EIGHTH DEFENSE 11 (17 U.S.C. §301) 12 8. Plaintiff’s allegations are barred by preemption 17 U.S.C. § 301. 13 NINTH DEFENSE 14 (Unclean Hands) 15 9. Plaintiff’s claim and the relief requested is barred based on Plaintiff’s 16 unclean hands. 17 TENTH DEFENSE 18 (Unjust Enrichment) 19 10. Plaintiff’s relief requested is barred as a result of unjust enrichment. 20 ELEVENTH DEFENSE 21 (Set Off) 22 11. Plaintiff’s relief requested is barred as a result off set. Any amount 23 sought to be recovered in this action is barred in whole or in part by the amount 24 owing from Plaintiff to Defendant. 25 TWELFTH DEFENSE 26 (Copyright Misuse) 27 12. Plaintiff’s copyright is unenforceable because he has committed 28 copyright misuse in one or more of the following ways: CH01DOCS154690.5 10 ANSWER 1 • Plaintiff is asserting copyright rights beyond its scope. 2 • Plaintiff is asserting copyright ownership in unprotectable elements. 3 • Plaintiff is asserting copyright ownership in portions of the work that are 4 unoriginal to Plaintiff. 5 • Plaintiff is asserting copying based upon similarities known to exist in 6 musical works which predate Plaintiff’s works. 7 • Plaintiff is asserting copying based upon similarities that are not 8 copyrightable. Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 • Plaintiff is asserting copying based upon similarities that are music 10 commonplaces. 11 • Plaintiff is asserting copying based upon similarities between works that are 12 not original to Plaintiff. 13 THIRTEENTH DEFENSE 14 (Waiver) 15 13. Plaintiff’s claims and relief requested are barred by the doctrine of 16 waiver. 17 FOURTEENTH DEFENSE 18 (Acquiescence) 19 14. Plaintiff’s claims and relief requested are barred by the doctrine of 20 acquiescence. 21 FIFTEENTH DEFENSE 22 (Estoppel) 23 15. Plaintiff’s claims and relief requested are barred by estoppel. 24 SIXTEENTH DEFENSE 25 (Speculative Damages) 26 16. The damages alleged in Plaintiff’s Complaint are impermissibly remote 27 and speculative, and therefore, Plaintiff is barred from the recovery of any such 28 damages against Defendant. CH01DOCS154690.5 11 ANSWER 1 SEVENTEENTH DEFENSE 2 (Fraud on the U.S. Copyright Office) 3 17. Plaintiff’s claims and relief requested are barred because the copyrights 4 claimed by Plaintiff were obtained fraudulently from the Copyright Office. 5 EIGHTEENTH DEFENSE 6 (Unenforceability) 7 18. Plaintiff’s claims and relief requested are barred because the 8 registrations referenced in the Complaint are unenforceable. Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 NINETEENTH DEFENSE 10 (Invalidity) 11 19. Plaintiff’s claims and relief requested are barred because the 12 registrations referenced in the Complaint are invalid. RESERVATION OF RIGHTS 13 14 Defendant EMI April Music reserves the right, upon completion of its 15 investigation and discovery, to file such additional defenses and/or counterclaims as 16 may be appropriate. 17 WHEREFORE, having fully answered Plaintiff’s Complaint, Defendant EMI 18 April Music prays for judgment against Plaintiff and awarding Defendant EMI April 19 Music its costs, interest, reasonable attorneys’ fees, together with such other and 20 further relief as the Court may deem proper. 21 22 Dated: February 10, 2011 23 24 25 BRYAN CAVE LLP Kara Cenar Jonathan Pink Mariangela Seale By: /s/ Jonathan Pink Jonathan Pink Attorneys for Defendants WILLIAM ADAMS; STACY FERGUSON; ALLAN PINEDA; JAIME GOMEZ; all individually and collectively as the music 26 27 28 CH01DOCS154690.5 12 ANSWER group THE BLACK EYED PEAS; TAB MAGNETIC PUBLISHING; HEADPHONE JUNKIE PUBLISHING, LLC; will.i.am. music, llc; JEEPNEY MUSIC, INC.; CHERRY RIVER MUSIC CO.; and EMI APRIL MUSIC, INC. 1 2 3 4 5 6 7 8 Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CH01DOCS154690.5 13 ANSWER JURY DEMAND 1 2 Defendant EMI April Music demands a jury trial. 3 4 Dated: February 10, 2011 5 6 7 By: /s/ Jonathan Pink Jonathan Pink Attorneys for Defendants WILLIAM ADAMS; STACY FERGUSON; ALLAN PINEDA; JAIME GOMEZ; all individually and collectively as the music group THE BLACK EYED PEAS; TAB MAGNETIC PUBLISHING; HEADPHONE JUNKIE PUBLISHING, LLC; will.i.am. music, llc; JEEPNEY MUSIC, INC.; CHERRY RIVER MUSIC CO.; and EMI APRIL MUSIC, INC. 8 9 Bryan Cave LLP 3161 Michelson Drive, Suite 1500 Irvine, California 92612-4414 BRYAN CAVE LLP Kara Cenar Jonathan Pink Mariangela Seale 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CH01DOCS154690.5 14 ANSWER

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