Bryan Pringle v. William Adams Jr et al

Filing 206

DECLARATION of Tal E. Dickstein in response to MOTION to Withdraw Transcripts and Re-File Portions of Previously Filed Transcripts Under Seal 202 filed by Defendants David Guetta, Frederick Riesterer, Shapiro Bernstein and Co. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Miller, Donald)

1 DONALD A. MILLER (SBN 228753)
[e-mail]
2 BARRY I. SLOTNICK (Pro Hac Vice)
[e-mail]
3 TAL E. DICKSTEIN (Pro Hac Vice)
[e-mail]
4 LOEB & LOEB LLP
10100 Santa Monica Boulevard, Suite 2200
5 Los Angeles, California 90067-4120
Telephone: [phone]
6 Facsimile: 310-282-2200
7 Attorneys for SHAPIRO, BERNSTEIN
& CO., INC., FREDERIC
8 RIESTERER, and DAVID GUETTA
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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SOUTHERN DIVISION

13 BRYAN PRINGLE, an individual,
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Plaintiff,
v.

16 WILLIAM ADAMS, JR.; STACY
FERGUSON; ALLAN PINEDA; and
17 JAIME GOMEZ, all individually and
collectively as the music group The
18 Black Eyed Peas, et al.,
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Defendants.

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Case No. SACV 10-1656 JST(RZx)
Hon. Josephine Staton Tucker
Courtroom 10A
DECLARATION OF TAL E.
DICKSTEIN IN SUPPORT OF
DEFENDANTS’ RESPONSE TO
PLAINTIFF’S MOTION TO REFILE TRANSCRIPTS UNDER SEAL
(DOC. 202)_AND IN SUPPORT OF
DEFENDANTS’ REQUEST TO
CONTINUE MOTION HEARING
DATE
Complaint Filed: October 28, 2010
Trial Date: March 27, 2012
Hearing Date: January 23, 2012
Time: 10:00 A.M.
Courtroom: 10A

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NY994882.1
217131-10001

DICKSTEIN DECLARATION

1 I, TAL E. DICKSTEIN, declare as follows:
2

1.

I am an attorney associated with the law firm Loeb & Loeb LLP,

3 attorneys for Defendants Shapiro, Bernstein & Co, Inc., Frederic Riesterer and
4 David Guetta (collectively “Defendants”) in this action. I am a member in good
5 standing of the Bar of the State of New York and was admitted to practice in this
6 Court pro hac vice by Order dated December 21, 2010 (Doc. 69). I have personal
7 knowledge of the facts set forth hereinafter, and I submit this declaration in support
8 of Defendants’ Motion for Summary Judgment, filed concurrently herewith.
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2.

Attached hereto as Exhibit A is a true and correct copy of excerpts of

10 email correspondence between counsel for Plaintiff and counsel for Defendants that
11 took place from June 6, 2011 to June 14, 2011.
12

3.

Attached hereto as Exhibit B is a true and correct copy of an email

13 dated July 7, 2011 from counsel for Plaintiff to counsel for Defendants. Relevant
14 portions of this email have been highlighted for the Court’s convenience.
15

4.

Attached hereto as Exhibit C is a true and correct copy of email

16 correspondence between counsel for Plaintiff and counsel for Defendants that took
17 place from September 25, 2011 to October 4, 2011.
18

5.

Attached hereto as Exhibit D is a true and correct copy of a letter from

19 counsel for Plaintiff to counsel for Defendants, dated June 20, 2011. Relevant
20 portions of this letter have been highlighted for the Court’s convenience.
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I declare under penalty of perjury that the foregoing is true and correct.

22 Executed this 30th day of December, 2011.
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s/ Tal E. Dickstein

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TAL E. DICKSTEIN

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NY994882.1

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NY994882.1
217131-10001

DICKSTEIN DECLARATION

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