Bryan Pringle v. William Adams Jr et al

Filing 254

DECLARATION of TAL E. DICKSTEIN In Further Support of MOTION for Sanctions Rule 11 237 filed by Defendants David Guetta, Frederick Riesterer, Shapiro Bernstein and Co. (Attachments: # 1 Exhibit 23, # 2 Exhibit 24, # 3 Exhibit 25)(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 FURTHER
SUPPORT OF MOTION FOR
SANCTIONS AGAINST PLAINTIFF
AND HIS COUNSEL PURSUANT
TO FED. R. CIV. P. 11
Complaint Filed: October 28, 2010
Hearing Date: April 16, 2012

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NY1008723.1
217131-10001

DICKSTEIN DECLARATION

1 I, TAL E. DICKSTEIN, declare as follows:
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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 in this action. I am a member in good standing of the Bar of the State
5 of New York and was admitted to practice in this Court pro hac vice by Order dated
6 December 21, 2010 (Doc. 69). I have personal knowledge of the facts set forth
7 hereinafter, and I submit this declaration in further support of Defendants’ Motion
8 for Rule 11 Sanctions against Plaintiff Bryan Pringle and his Counsel.
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2.

Attached hereto as Exhibit 23 is a copy of Plaintiff’s Original Petition

10 in Bryan Pringle, et al. v. USAA, Insurance Agency, Inc., Cause No. 2003/16046
11 (District Court, 224th Judicial District, Bexar County, Texas).
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3.

Attached hereto as Exhibit 24 is a copy of excerpts of the January 26,

13 2004 deposition transcript of Bryan Pringle in Bryan Pringle, et al. v. USAA,
14 Insurance Agency, Inc., Cause No. 2003/16056 (District Court, 224th Judicial
15 District, Bexar County, Texas), as well as a copy of a list of lawsuits brought by
16 Bryan Pringle, which was attached as Exhibit 15 to said deposition transcript.
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4.

Attached hereto as Exhibit 25 is a copy of Plaintiff’s Response to

18 Defendant David Guetta’s First Set of Interrogatories, dated November 14, 2011.
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I declare under penalty of perjury that the foregoing is true and correct.

20 Executed this 2nd day of April, 2012.
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/s/ Tal E. Dickstein

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TAL E. DICKSTEIN

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NY1008723

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NY1008723.1
217131-10001

DICKSTEIN DECLARATION

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