Bryan Pringle v. William Adams Jr et al

Filing 161

DECLARATION of Tal Dickstein In Support of MOTION for Summary Judgment 159 filed by Defendants David Guetta, Frederick Riesterer, Shapiro Bernstein and Co. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q)(Miller, Donald)

Justin Righettini
Direct [phone]
[e-mail]

June 6, 2011

Bryan Cave LLP
3161 Michelson Drive
Suite 1500

VIA E-MAIL

Irvine, CA 92612-4414
Tel [phone]
Fax [phone]

Katharine Dunn
MILLER CANFIELD PADDOCK
AND STONE, P.L.C.
225 West Washington Street, Suite 2600
Chicago, IL 60606
Re:

Pringle v. Adams, et al.

www.bryancave.corn

Bryan Cave Offices
Atlanta
Charlotte
Chicago
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Dear Katharine:

Irvine
Jefferson City

Thank you for taking the time to discuss with us Plaintiffs responses to William
Adams' First Set of Request for Production of Documents and Things on June 2,
2011. This letter serves to confirm that, in our meeting, you stated that Mr. Pringle
currently has no additional responsive documents and/or things in his possession,
custody, or control beyond those which had already been produced at the time of our
meet and confer. You did, however, indicate that Mr. Pringle is still conducting a
search to determine if additional responsive documents and things do exist. Please
have Mr. Pringle complete that search as soon as possible, but no later than June 17,
2011. To the extent Mr. Pringle fails to produce additional documents or things by
that time, Defendants will assume that no such additional documents or things exist,
and will rely on that assumption in connection with any dispositive motions
(including a motion for summary judgment) that may follow.

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Bryan Cave International Trade
A TRADE CONSULTING SUBSIDIARY
OF NON-LAWYER PROFESSIONALS

In addition, you indicated that Mr. Pringle would make available for inspection
various computer files and musical equipment, and that you would get back to us
shortly with a proposal concerning logistics thereof. Please provide such a proposal,
including proposed dates and the location for that inspection, by June 17, 2011.
Beyond the musical equipment and computer software and hardware Mr Pringle
claims to have used, please confirm that Mr. Pringle will make available for inspection
each and every digital file, phonorecord, or copy that corresponds to every version of
"Take a Dive" (and sound recordings thereof) that he claims ever existed, including

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Bryan Cave LLP

Katharine Dunn
June 6, 2011
Page 2
without limitation, the original 1998 version, the 1999 "Dance Version," and those versions that have
the "guitar twang sequence" "soloed out as the introduction of the song."
Very truly yours,

cc:

Kara Cenar, Esq.
Jonathan Pink, Esq.
Barry Slotnick, Esq.
Linda Burrow, Esq.