Bryan Pringle v. William Adams Jr et al

Filing 283

DECLARATION of Tal E. Dickstein in support of MOTION for Attorney Fees of all Defendants 280 filed by Defendants David Guetta, Frederick Riesterer, Shapiro Bernstein and Co. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15)(Miller, Donald)

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Dean A. Dickie (appearing Pro Hac Vice)
[e-mail]
Kathleen E. Koppenhoefer (appearing Pro Hac Vice)
[e-mail]
Katharine N. Dunn (appearing Pro Hac Vice)
[e-mail]
MILLER, CANFIELD, PADDOCK AND STONE, P.L.C.
225 West Washington Street, Suite 2600
Chicago, IL 60606
Telephone: [phone]
Facsimile: 312.460.4288
Ira Gould (appearing Pro Hac Vice)
[e-mail]
Ryan L. Greely (appearing Pro Hac Vice)
[e-mail]
GOULD1_,AW GROUP
120 North LaSalle Street, Suite 2750
Chicago, IL 60602
Telephone: [phone]
Facsimile: 312.726.1328
George L. Hampton IV (State Bar No. 144433)
[e-mail]
Colin C. Holley (State Bar No. 191999)
hamptonholley.com
TONI-TOLLEY LLP
2101 East Coast Highway, Suite 260
Corona del Mar, California 92625
Telephone: [phone]
Facsimile: 949.718.4580

ax1W

Attorneys for Plaintiff
BRYAN PRINGLE

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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SOUTHERN DIVISION

22 BRYAN PRINGLE, an individual,
Plaintiff,

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v.

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

Case No. SACV 10-1656 JST(RZx)
PLAINTIFF'S AMENDED
ANSWERS TO DEFENDANT
HEADPHONE JUNKIE
PUBLISHING, LLC'S FIRST SET
OF INTERROGATORIES

1 PROPOUNDING

Defendant HEADPHONE JUNKIE PUBLISHING,
LLC

2 PARTY:
3 RESPONDING PARTY: Plaintiff BRYAN PRINGLE
One

4 SET NO.:
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Plaintiff Bryan Pringle ("Pringle" or "Plaintiff') submits these Amended
Answers to Defendant Headphone Junkie Publishing, LLC's ("Headphone Junkie" or
"Defendant") First Set of Interrogatories (the "Interrogatories"):

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GENERAL OBJECTIONS
1.

Pringle objects to each interrogatory insofar as it is vague, overly broad,

not limited in time and scope, oppressive, harassing or vexatious, imposes burden or
expense that outweighs the likely benefit, seeks legal conclusions, and/or seeks
information not relevant to the lawsuit nor reasonably calculated to lead to the
discovery of admissible evidence.
2.

Pringle objects to the extent that these interrogatories seek information

protected by the attorney/client or the work product privilege. Pringle will not
provide any such privileged information.
3.

The following answers are given based upon the information and

documents of which Pringle's counsel is currently aware. Pringle's investigation
continues and Pringle specifically reserves the right to supplement the following
answers as this litigation proceeds. The following answers are given herein without
prejudice to Pringle's right to supplement or change his answers or objections and to
produce evidence of additional facts.
4.

Pringle's answers are not an admission that any such information is

relevant or admissible.
5.

Pringle objects to each interrogatory, instruction or definition that

purports to impose any obligation greater than or different from those required under
the Federal Rules of Civil Procedure and Local Orders of the Court.

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2

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expert, for the purpose of demonstrating how to use the ASR-10

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keyboard. Plaintiff further states that he had telephonic and email

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contact with Dave Gallant but does not recall the dates of such contact.
INTERROGATORY NO. 24: Provide the date when Mr. Pringle allegedly

6 placed his musical equipment in the storage unit reflected in his police report
7 produced in this case.
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ANSWER: Objection. Plaintiff objects to Interrogatory No. 24 because
it is overly broad, unduly burdensome and not likely to lead to the

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discovery of relevant evidence. Without waiving said objections,
Plaintiff states that his music equipment was placed in the storage unit
sometime during 2000 and prior to October 2000. Plaintiff does not

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recall the specific date or dates on which his music equipment was
placed in storage.
INTERROGATORY NO. 25: If you contend that any Defendant has infringed
any copyright of Plaintiff Bryan Pringle other than Take A Dive or Take A Dive
(Dance Version), provide a complete factual basis for contending that they
Defendant had access and that the accused work is substantially similar.
ANSWER: Objection. Plaintiff objects to Interrogatory No. 25 because
it is overly broad, unduly burdensome and not likely to lead to the
discovery of relevant evidence. Without waiving said objections, at this
particular time, Plaintiff states that David Guetta's song "Love is Gone"
contains the guitar twang sequence of "Take a Dive" and as stated in his
deposition, the Defendants may have infringed "If We Ever," "One
Love," "Meet Me Halfway," "Someday," "Where Them Girls At,"

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"Best One Yet," "One More Chance," "Invisible," and "Showdown."

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Investigation continues.

3 Dated: November 2, 2011
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Dean A. Dickie (appearing Pro Hac Vice)
Kathleen E. Koppenhoefer (appearing Pro Hac
Vice)
Katharine N. Dunn (appearing Pro Hac Vice
MILLER, CANFIELD, PADDOCK AND STONE,
P.L.C.
Ira Gould (appearing Pro Hac Vice)
Ryan L. Greely (appearing Pro Hac Vice)
GOULD LAW GROUP
George L. Hampton IV (State Bar No. 144433)
Colin C. Holley (State Bar No. 191999)
HAMPTONHOLLEY LLP

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By:
Attorneys for Plaintiff Bryan Pringle

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VERIFICATION

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I, Bryan Pringle, state that the answers made to Defendant Headphone Junkie
Publishing, LLC's First Set of Interrogatories are true and correct to the best of my
knowledge. I declare the foregoing to be true under penalty of perjury.

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Bryan P g

8 November 2, 2011
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