Bryan Pringle v. William Adams Jr et al

Filing 264

STATUS REPORT , JOINT, filed by Plaintiff Bryan Pringle. (Holley, Colin)

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1 Dean A. Dickie (appearing Pro Hac Vice) Dickie@MillerCanfield.com 2 Kathleen E. Koppenhoefer (appearing Pro Hac Vice) Koppenhoefer@MillerCanfield.com 3 MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. 225 West Washington Street, Suite 2600 4 Chicago, IL 60606 Telephone: 312.460.4200 5 Facsimile: 312.460.4288 6 George L. Hampton IV (State Bar No. 144433) ghampton@hamptonholley.com 7 Colin C. Holley (State Bar No. 191999) cholley@hamptonholley.com 8 HAMPTONHOLLEY LLP 2101 East Coast Highway, Suite 260 9 Corona del Mar, California 92625 Telephone: 949.718.4550 10 Facsimile: 949.718.4580 11 Attorneys for Plaintiff BRYAN PRINGLE 12 13 14 15 16 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION 17 BRYAN PRINGLE, an individual, 18 19 20 21 22 23 24 25 ) Case No. SACV 10-1656 JST(RZx) ) ) JOINT STATUS REPORT Plaintiff, ) ) v. ) ) WILLIAM ADAMS, JR.; STACY ) FERGUSON; ALLAN PINEDA; and ) JAIME GOMEZ, all individually and collectively as the music group The Black ) ) Eyed Peas, et al., ) ) Defendants. ) Plaintiff Bryan Pringle (“Plaintiff”), Non-Moving Defendants, William 26 Adams, Stacy Ferguson, Allan Pineda, Jaime Gomez, individually and professionally 27 known as the musical group The Black Eyed Peas, Tab Magnetic Publishing, 28 Headphone Junkie Publishing, LLC, will.i.am. music, llc, Jeepney Music, Inc., 1 Cherry River Music Co., EMI April Music, Inc., UMG Recordings, Inc., Interscope 2 Records (the “Remaining Defendants” or “Nonmoving Defendants”), and defendants 3 Frederic Riesterer, David Guetta, and Shapiro, Bernstein & Co., Inc. (the “Moving 4 Defendants), and non-party Rister Editions, jointly submit the following status report 5 report pursuant to the Court’s Order dated April 2, 2012: 6 I. 7 8 PLAINTIFF’S STATEMENT A. Purpose of Joint Status Report Defendants David Guetta, Frederick Riesterer, and Shapiro Bernstein moved 9 for summary judgment on November 19, 2011 (Dckt. No 159). The Remaining 10 Defendants did not move for summary judgment and did not file a joinder. On April 11 2, 2012, the Court entered summary judgment on behalf of the Moving Defendants. 12 On the same date, the Court entered an order directing the parties to submit a joint 13 status report regarding the status of the case, specifically as to the Remaining 14 Defendants. On April 3, the parties engaged in correspondence regarding these 15 issues and they later participated in a phone call on April 5, 2012 to further discuss 16 the issues pursuant to the Court’s directive. 17 18 B. Status of Remaining Defendants As the Court noted in its April 2, 2012 Order, several defendants remain in the 19 case after the Court’s ruling on the Moving Defendants’ Motion for Summary 20 Judgment. During the parties’ April 5, 2012 telephone call, Plaintiff indicated his 21 intent to dismiss Defendant Rister Editions pursuant to Fed. R. Civ. P. 41(a)(1) 22 because that Defendant never filed an answer nor moved for summary judgment. 23 Counsel for Rister Editions indicated that they opposed the motion and would cross24 move for dismissal with prejudice. Plaintiff filed a notice of voluntary dismissal on 25 April 5, 2012 pursuant to Rule 41(a)(1) (Dckt No. 261). 26 During the April 5 meet and confer, the Remaining Defendants proposed that 27 Plaintiff stipulate to entry of judgment against him pursuant to Rule 56(f). Plaintiff 28 declined to volunteer to entry of judgment against him given the adverse impact it 2 1 could have on Plaintiff’s appellate rights, and further because it is Plaintiff’s position 2 Rule 56(f) does not contemplate action by the parties but rather, the Court’s own 3 action. This position was communicated to the Remaining Defendants. Instead, 4 Plaintiff indicated that he would move for a voluntary dismissal against the 5 Remaining Defendants under Rule 40(a)(2). Defendants objected to Plaintiff’s 6 motion and instead proposed entering a stipulation for summary judgment with 7 added language to the effect that the parties agreed that the stipulation would not 8 adversely impact Plaintiff’s appellate rights. Plaintiff declined this proposal as well 9 due to the same concern that Plaintiff’s voluntary entry of judgment against him 10 could adversely impact his appellate rights, regardless of the parties’ stipulation. The 11 parties fully discussed the matter and are unable to reach an agreement on this point. 12 Because the parties are at an impasse, further efforts to meet and confer will not 13 lessen the burden of litigation on either the parties or the Court. 14 On April 6, 2012, Plaintiff moved for voluntary dismissal of the Remaining 15 Defendants pursuant to Rule 40(a)(2) (Dckt. No. 262). The Remaining Defendants 16 who are represented by Bryan Cave object to the motion. It is their position that the 17 parties never engaged in a meet and confer regarding the Rule 40(a)(2) motion 18 during the April 5 call and that Plaintiff did not did not wait ten days before moving. 19 It is Plaintiff’s contention that during the April 5 call, Plaintiff’s counsel 20 specifically advised all parties that Plaintiff would be making the motion, and 21 outlined the basis for it. The parties then meaningfully discussed the motion, and 22 each party provided their position. The Remaining Defendants indicated that they 23 would not agree to the motion. Ms. Cenar further indicated that in opposition to 24 Plaintiff’s motion, the Remaining Defendants would instead ask the Court to dismiss 25 them with prejudice, with all costs and attorneys fees to be awarded to them. 26 27 C. Rule 11 Motion The only other matter currently pending is the Motion for Rule 11 Sanctions, 28 made by Defendants Riesterer, Guetta and Shapiro Bernstein and joined by the 3 1 Adams Defendants. That motion is set for oral argument on April 16, 2012 at 10:00 2 a.m. D. 3 4 Other Matters The Moving Defendants have advised Plaintiff that it is their intention to make 5 a motion for attorneys’ fees under Section 505 of the Copyright Act, and for 6 sanctions under the Court’s inherent power and 28 U.S.C. § 1927. The Moving 7 Defendants and Plaintiff have met and conferred on this motion and Plaintiff 8 indicated his intent to oppose the motion. 9 II. NONMOVING DEFENDANTS’ STATEMENT 10 A. 11 On November 17, 2011, Defendants David Guetta, Frederic Riesterer, and Procedural Posture 12 Shapiro, Bernstein & Co., Inc. (“Guetta Defendants”) filed a motion for summary 13 judgment as to Pringle’s copyright infringement claim. Dkt. No. 159. Joinders to 14 that motion were not filed by Defendants William Adams; Stacy Ferguson; Allan 15 Pineda; and Jaime Gomez, all individually and collectively as the music group The 16 Black Eyed Peas; will.i.am Music, llc; Tab Magnetic Publishing; Cherry River Music 17 Co.; Headphone Junkie Publishing, LLC; Jeepney Music, Inc.; EMI April Music, 18 Inc. (“Adams Defendants”). Nor were they filed by UMG Recordings, Inc.; and 19 Interscope Records (UMG, Interscope and the Adams Defendants collectively 20 referred to herein as the “Nonmoving Defendants”). Joinders were not filed because 21 the same law and facts applied to all defendants in this action. As such, if the Court 22 granted the motion as to the Guetta Defendants, it could readily grant summary 23 judgment as to the Nonmoving Defendants sua sponte under Fed. R. Civ. P. 56(f) 24 and its inherent authority. 25 On March 30, 2012, the Court granted that motion based on substantive 26 grounds as well as Pringle’s willful spoliation of evidence. See Dkt. No. 252. On 27 the same day, the Court issued a further Order requiring the parties to file a joint 28 report as to the status of the case, “specifically as to the remaining defendants.” Dkt. 4 1 No. 256. On April 5, 2012, the parties held a telephonic conference pursuant to the 2 Court’s Order with a view to bringing this case to a close and preparing the instant 3 report. 4 5 6 B. Summary Judgment Should Be Granted to All Defendants in This Action It is the position of the Nonmoving Defendants that, based on the Court’s 7 March 30, 2012 Order Granting the Guetta Defendants’ Motion for Summary 8 Judgment, and Pringle’s own recognition that his case cannot currently proceed as to 9 any of the remaining defendants, the Court should grant summary judgment as to 10 each remaining defendant. The Court has the power to do this under Fed. R. Civ. P. 11 56(f) and under its inherent authority. See Fed. R. Civ. P. 56(f)(1) (providing that 12 “[a]fter giving notice and a reasonable time to respond,” district courts may “grant 13 summary judgment for a nonmovant.”); see also Celotex Corp. v. Catrett, 477 U.S. 14 317, 326 (1986) (courts have power to enter summary judgment sua sponte, “so long 15 as the losing party was on notice that [he] had to come forward with all of [his] 16 evidence.”); Corales v. Bennett, 567 F.3d 554, 570 (9th Cir. 2009) (“[T]he district 17 court has the authority to decide an issue on summary judgment sua sponte, if the 18 losing party was on notice to come forward with its evidence.”). 19 In ruling on summary judgment, the Court held that Pringle had no standing 20 to pursue a claim of copyright infringement with respect to “Take a Dive (Dance 21 Version).” Order Granting Defendants’ Motion for Summary Judgment [Dkt. No. 22 252], dated Mar. 30, 2012, at 8. In addition, the Court held that “no reasonable juror 23 could find substantial similarity between ‘Take a Dive’ and ‘I Gotta Feeling.’” Id. at 24 11 (citation omitted). Finally, the Court held that outright dismissal was “an 25 appropriate sanction for Pringle’s willful despoliation of his Hard Drives.” Id. at 17. 26 These specific rulings are not unique to the Guetta Defendants; they apply equally to 27 all of the defendants in this action, and as such, it is simply not possible for Pringle to 28 pursue his claim against any of the remaining defendants. 5 1 Summary judgment can be granted here as to the Nonmoving defendants 2 because Pringle was on notice to come forward with evidence of his copyright 3 infringement claim as to all defendants in this action, and not just those who moved 4 for summary judgment. The same facts and analyses with respect to the elements for 5 copyright infringement apply to all of the parties Pringle alleges were direct 6 infringers.1 The parties that Pringle alleged were indirect infringers should also be 7 dismissed, because there is no secondary liability for copyright infringement without 8 an underlying act of direct infringement. See A&M Records, Inc. v. Napster, Inc., 9 239 F.3d 1004, 1013 n. 2 (9th Cir. 2001) (“There can be no contributory 10 infringement by a defendant without direct infringement by another.”) (citation 11 omitted); UMG Recordings, Inc. v. Sinnott, 300 F. Supp. 2d 993, 997 (E.D. Cal. 12 2004) (“Establishing direct copyright infringement by the MFM vendors is a 13 prerequisite to both the contributory and vicarious copyright infringement claims.”). 14 Several courts have granted summary judgment sua sponte as to nonmoving 15 defendants in copyright cases, including the other case brought by Pringle’s counsel 16 against the Nonmoving Defendants. See, e.g., Batts et al. v. Adams et al., CV1017 8123 JFW (RZx) (C.D. Cal. 2010), Order Granting Defendants’ Motion for 18 Summary Judgment [Dkt. No. 251], dated Oct. 21, 2011, at 9 (granting motion for 19 summary judgment as to single claim for copyright infringement as to moving 20 defendants and sua sponte as to all non-moving defendants “because the identical 21 law and facts on the issue of substantial similarity appl[ied] to all of the 22 1 As discussed in the summary judgment and Rule 11 briefing, the instrumental 23 portion of “I Gotta Feeling” was composed by David Guetta and Frederic Riesterer, the Adams pursuant to 24 and it was subsequently acquired by contributed Defendants Feeling” by a written agreement. The Adams Defendants to “I Gotta providing lyrics and concomitant vocal melodies. Given that only the instrumental portions of 25 “I Gotta Feeling” and “Take a Dive (Dance Version)” are relevant to this action, the a 26 Court’s rulings on lack of standing (as to “Take of Dive (Dance Version)” and lack of substantial similarity (as to the original version “Take a Dive”), and thus, the 27 exoneration of the Guetta Defendants, necessarily means that there can be no infringement by the Adams Defendants. 28 6 1 defendants.”); Whitehead v. Paramount Pictures Corp., 53 F. Supp. 2d 38, 54 2 (D.D.C. 1999) (granting summary judgment sua sponte as to non-moving defendants 3 in copyright infringement case because “the causes of action against the individual 4 and corporate defendants are identical and are premised on the same theory—that the 5 films BAD COMPANY and MISSION: IMPOSSIBLE and the novelization of the 6 film MISSION: IMPOSSIBLE infringed the copyright of Mr. Whitehead's book— 7 there is no point in requiring the individual defendants to brief and argue the same 8 issues already briefed by the corporate defendants.”); Kalmansohn v. J.M. 9 Productions Co., 1988 WL 1517050, at *3 (C.D. Cal. Jul. 18, 1988) (granting 10 summary judgment sua sponte as non-moving defendants in copyright infringement 11 case because “the dispositive issues addressed [with respect to the moving party] are 12 identical to those that would be relevant against the other defendants.”). 13 C. 14 Given the Court’s summary judgment ruling, the Nonmoving Defendants seek Pringle’s Rule 41 Motion 15 to close this matter with permanency in the most efficient and economic manner 16 possible. As such, during the parties’ April 5, 2012 conference concerning the joint 17 status report, the Nonmoving Defendants suggested that the parties stipulate that the 18 Court’s Summary Judgment Order would apply equally to the Nonmoving 19 defendants as it does to the moving defendants. Pringle declined that invitation, 20 stating a desire to seek dismissal instead under Fed. R. Civ. P. 41(a)(2) without 21 prejudice, due to the preservation of undisclosed “appellate rights.” The Nonmoving 22 Defendants stated that they would oppose such a motion, and asked Pringle’s counsel 23 to reconsider their position, especially given that an additional round of briefing 24 would be costly and wholly unnecessary in light of the fact that this matter could be 25 resolved through Fed. R. Civ. P. 56(f) and the Court’s inherent authority. The 26 Adams Defendants also stated their intent to seek fees and costs if they were forced 27 to entertain a round of unnecessary briefing. Again, Pringle declined and instead, 28 filed his Rule 41 motion a day after the parties’ conference and prior to the 7 1 submission of this report.2 Nevertheless, the Court should—and has the power to— 2 grant summary judgment as to the Remaining Defendants and simply deny Pringle’s 3 motion as moot. It is respectfully submitted that another purpose of Pringle’s Rule 41 Motion, 4 5 which, again, seeks dismissal without prejudice, is simply to prevent the Adams 6 Defendants (or any of the remaining defendants in this action) from attaining 7 prevailing party status when Pringle’s claim is inevitably dismissed. See 8 Buckhannon Board & Care Home v. West Virginia Department of Health & Human 9 Resources, 532 U.S. 598, 603 (2001) (“prevailing party” is one who has been 10 awarded some species of relief by a court); Bridgeport Music, Inc. v. London Music, 11 U.K., 345 F. Supp. 2d 836, 839-40 (M.D. Tenn. 2004) (voluntary dismissal without 12 prejudice does not “constitute the judicially sanctioned change in the parties' legal 13 relationship required by Buckhannon in order for one party to prevail over the other.” A voluntary dismissal without prejudice should not be countenanced here 14 15 because it will not yield a permanent resolution. Given that: (1) Pringle has been 16 known to file scores of lawsuits (See Dkt. No. 253, at pp. 1-2) and (2) his attorneys 17 18 19 20 21 22 23 24 25 26 27 2 While the parties did discuss Pringle’s contemplated Rule 41 motion during the conference call, that discussion was in response to the Court’s directive to prepare a joint status report, in which various options to bring this case to a close were discussed, not a discrete meet and confer for the filing of a Rule 41 Motion. Even if that discussion satisfied the meet and confer requirement of C.D. Cal. L.R. 7-3, the timing requirement of that rule has not been met. Local Rule 7-3 provides that the "conference shall take place at least five (5) days prior to the last day for filing the motion; otherwise, the conference shall take place at least ten (10) days prior to the filing of the motion." Even though none of the Nonmoving Defendants consented to the filing of Pringle’s motion prior to the time period set forth in L.R. 7-3, Pringle filed it the day after the parties’ conference call concerning the joint status report. This appears to be nothing more than a thinly veiled attempt to get a motion on file prior to date the joint status report was to be submitted and/or frustrate the Court’s ability to grant summary judgment as to the remaining defendants. Though the hearing date on Pringle’s Rule 41 Motion was previously set for May 7, 2012, Pringle has agreed to continue it to accomodate a scheduling conflict of the Adams Defendants’ counsel. 28 8 1 have filed multiple lawsuits against the Adams Defendants (including levying 2 unfounded allegations of a conspiracy and violations of Cal. Bus. & Prof. Code § 3 17200 et seq.), there is the very real possibility that Pringle will simply re-file his 4 claim anew. Dismissal without prejudice is improper because Pringle should not be 5 permitted to drag more than a dozen defendants through litigation for more than a 6 year and force them to incur very substantial attorneys’ fees and costs and then walk 7 away with impunity when it became clear that he could not proceed with his claim. 8 This is especially so given that the bases upon which the Court granted summery 9 judgment were raised by defense counsel prior to and in the very early stages of 10 litigation. Pringle had every opportunity to seek a Rule 41 dismissal early on, but 11 chose instead to wait until the end and force everybody to incur substantial fees and 12 costs. 13 Moreover, dismissal without prejudice would be improper here in light of 14 Pringle’s spoliation of evidence, saying nothing of his frivolous and counterfactual 15 claim for infringement. It would be a waste of judicial resources (as well as those of 16 the parties) and contravene public policy to permit a spurious claim for which no 17 evidence exists to be filed anew given that the same result would obtain: dismissal. 18 Finally, should summary judgment be granted in favor of the Adams Defendants, 19 they will also seek their costs, including attorneys’ fees under 17 U.S.C. § 505, 28 20 U.S.C. § 1927, and the Court’s inherent authority. The Adams Defendants’ counsel 21 expressed this intention during the April 5, 2012 conference, but Pringle’s counsel 22 refused to discuss it or consider it as a meet and confer (thus requiring a follow-up 23 call), regarding the discussion as premature. 24 D. 25 On March 1, 2012, the Guetta Defendants filed a motion for sanctions under Rule 11 Motion 26 Fed. R. Civ. P. 11 against Pringle and his counsel, in which the Adams Defendants 27 joined. That motion is fully briefed and is set for hearing on April 16, 2012. 28 9 1 III. STATEMENT OF NON-PARTY RISTER EDITIONS 2 Non-party Rister Editions (“Rister”) submits this statement in response to the 3 Court’s April 2, 2012 Order For Case Status Report concerning the then-remaining 4 Defendants. As the Court will recall, on three separate occasions, Pringle improperly 5 attempted to serve process on Rister, a foreign corporation based in France, by 6 serving process on Shapiro Bernstein in the United States. In quashing Pringle’s 7 third such service attempt, the Court granted Rister’s motion for attorneys fees under 8 28 U.S.C. § 1927 for “Plaintiff’s decision to disregard this Court’s order with regard 9 to its service on Rister [which] amounts to recklessness, and unreasonably and 10 vexatiously multiplied the proceedings[.]” (Apr. 12, 2011 Order, Doc. 126.) 11 Although the Court once again “order[ed] Plaintiff to serve Rister promptly 12 pursuant to Rule 4(f), as Rister is a foreign corporation” (id. at 3), Plaintiff 13 disregarded that Order as well. During the April 5, 2012 conference call, Rister’s 14 counsel asked Pringle’s counsel whether, during the nearly twelve months since the 15 Court’s April 12, 2011 Order, Pringle had properly served Rister. Pringle’s counsel 16 gave no audible response. Rister’s counsel followed up with an email asking 17 Pringle’s counsel for their “position as to when and how Rister Editions has been 18 properly served in this action[.]” Rather than respond to that email and acknowledge 19 their continued disregard of the Court’s April 12, 2011 Order, Pringle’s counsel 20 proceeded to file a Notice of Dismissal without prejudice under to Rule 41(a). (Doc. 21 261.) 22 In light of the Court’s entry of summary judgment on grounds that apply to all 23 Defendants, Rister has chosen not to engage in additional costly motion practice to 24 convert Pringle’s Notice of Dismissal without prejudice into a dismissal with 25 prejudice for insufficient service of process. Rister nevertheless believed it 26 appropriate to bring to the Court’s attention Pringle’s counsel’s continued disregard 27 of the Court’s April 12, 2011 Order and attempt to conceal that disregard through 28 their April 5, 2012 Notice of Dismissal. 10 1 Dated: April 10, 2012 2 3 George L. Hampton IV (State Bar No. 144433) Colin C. Holley (State Bar No. 191999) HAMPTONHOLLEY LLP 4 5 By: /s/ Dean A. Dickie Dean A. Dickie Attorneys for Plaintiff BRYAN PRINGLE 6 7 8 Dated: April 10, 2012 9 BRYAN CAVE LLP By: /s/ Kara E. F. Cenar Kara E. F. Cenar Attorneys for Defendants WILLIAM ADAMS; STACY FERGUSON; ALLAN PINEDA; and JAIME GOMEZ, all individually and collectively as the music group THE BLACK EYED PEAS; will.i.am music, llc; TAB MAGNETIC PUBLISHING; CHERRY RIVER MUSIC CO.; HEADPHONE JUNKIE PUBLISHING, LLC; JEEPNEY MUSIC, INC.; EMI APRIL MUSIC, INC. 10 11 12 13 14 15 16 17 Dean A. Dickie (appearing Pro Hac Vice) Kathleen E. Koppenhoefer (appearing Pro Hac Vice) MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. Dated: April 10, 2012 18 19 20 21 22 LOEB & LOEB LLP By: /s/ Tal E. Dickstein Tal E. Dickstein Attorneys for Non-Party RISTER EDITIONS, and Defendants DAVID GUETTA, FREDERIC RIESTERER and SHAPIRO, BERNSTEIN & CO., INC. 23 24 Dated: April 10, 2012 25 26 27 CALDWELL LESLIE & PROCTOR, PC By: /s/ Linda M. Burrow _____ Linda M. Burrow______________________ Attorneys for Defendants UMG RECORDINGS INC. and INTERSCOPE RECORDS 28 11 1 2 3 4 CERTIFICATE OF SERVICE On April 10, 2012, I electronically filed the foregoing JOINT STATUS REPORT using the CM/ECF system which will send notification of such filing to the following registered CM/ECF Users: 5 Barry I. Slotnick 6 Donald A. Miller Tal Efriam Dickstein 7 Linda M. Burrow 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 bslotnick@loeb.com dmiller@loeb.com, vmanssourian@loeb.com tdickstein@loeb.com wilson@caldwell-leslie.com, burrow@caldwell-leslie.com, popescu@caldwell-leslie.com, robinson@caldwell-leslie.com Ryan Christopher Williams williamsr@millercanfield.com Kara E. F. Cenar kara.cenar@bryancave.com Robert C. Levels levels@millercanfield.com Kathleen E. Koppenhoefer koppenhoefer@millercanfield.com Rachel Aleeza Rappaport rrappaport@loeb.com Jonathan S. Pink jonathan.pink@bryancave.com, elaine.hellwig@bryancave.com Dean A. Dickie dickie@millercanfield.com, smithkaa@millercanfield.com, deuel@millercanfield.com, christensen@millercanfield.com, seaton@millercanfield.com Edwin F. McPherson emcpherson@mcphersonrane.com, astephan@mcphersonrane.com Joseph G. Vernon vernon@millercanfield.com James W. McConkey mcconkey@millercanfield.com Justin Michael Righettini justin.righettini@bryancave.com, elaine.hellwig@bryancave.com Tracy B. Rane trane@mcphersonrane.com Thomas D. Nolan tnolan@loeb.com 1 I am unaware of any attorneys of record in this action who are not registered 2 for the CM/ECF system or who did not consent to electronic service. 3 I certify under penalty of perjury under the laws of the United States of 4 America that the foregoing statements are true and correct. 5 Dated: April 10, 2012 6 /s/Colin C. Holley George L. Hampton IV (State Bar No. 144433) Colin C. Holley (State Bar No. 191999) HAMPTONHOLLEY LLP 2101 East Coast Highway, Suite 260 Corona del Mar, California 92625 Telephone: 949.718.4550 Facsimile: 949.718.4580 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ND: 4833-3883-8536, v. 1

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