Bryan Pringle v. William Adams Jr et al
Filing
264
STATUS REPORT , JOINT, filed by Plaintiff Bryan Pringle. (Holley, Colin)
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
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
SOUTHERN DIVISION
17 BRYAN PRINGLE, an individual,
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) Case No. SACV 10-1656 JST(RZx)
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) JOINT STATUS REPORT
Plaintiff,
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v.
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WILLIAM ADAMS, JR.; STACY
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FERGUSON; ALLAN PINEDA; and
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JAIME GOMEZ, all individually and
collectively as the music group The Black )
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Eyed Peas, et al.,
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Defendants.
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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.
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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.
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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).
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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
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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.
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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.
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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.
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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
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1 Adams Defendants. That motion is set for oral argument on April 16, 2012 at 10:00
2 a.m.
D.
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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
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A.
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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.
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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.
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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.
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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.”).
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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.
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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
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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.
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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.”).
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C.
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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
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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,
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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
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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
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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.
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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.
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D.
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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.
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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.
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1 Dated: April 10, 2012
2
3
George L. Hampton IV (State Bar No. 144433)
Colin C. Holley (State Bar No. 191999)
HAMPTONHOLLEY LLP
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By: /s/ Dean A. Dickie
Dean A. Dickie
Attorneys for Plaintiff BRYAN PRINGLE
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8 Dated: April 10, 2012
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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.
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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
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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.
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24 Dated: April 10, 2012
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CALDWELL LESLIE & PROCTOR, PC
By: /s/ Linda M. Burrow _____
Linda M. Burrow______________________
Attorneys for Defendants UMG RECORDINGS
INC. and INTERSCOPE RECORDS
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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
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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
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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
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ND: 4833-3883-8536, v. 1
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