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)
DunngMillerCanfield.com
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. freely (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 Hampton TV State Bar No_ 144433)
hampton@hamptonhol ey.com
olin C.1-ThIley (State Bar No. 191999)
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cholleyghamptonholley.com
14 1-1AMPTONFIOLLEY LLP
2101 East Coast Highway, Suite 260
15 Corona del Mar, California 92625
Telephone: [phone]
16 Facsimile: 949.718.4580
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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.

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25 WILLIAM ADAMS, JR.; STACY
FERGUSON; ALLAN PINEDA; and
26 JAIME GOMEZ, all individual]. 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 RESPONSE TO
DEFENDANT WILLIAM ADAMS'
FIRST SET OF
INTERROGATORIES
Complaint Filed: October 28, 2010
Trial Date:
January 24, 2012

1 PROPOUNDING PARTY:

Defendant WILLIAM ADAMS

2 RESPONDING PARTY:

Plaintiff BRYAN PRINGLE

3 SET NO.:

One

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Plaintiff Bryan Pringle submits this Answer to Defendant, William Adams'

6 ("Adams"), First Set of Interrogatories (the "Interrogatories ").
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GENERAL OBJECTIONS
1.

Plaintiff 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.

Plaintiff objects to the extent that these interrogatories seek information

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

The following answers are given based upon the information and

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

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

relevant or admissible.
5.

Plaintiff 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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Plaintiff specifically reserves the right to assert additional objections.
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1 INTERROGATORY NO. 5: IDENTIFY all other PERSONS besides YOU who
2 assisted with, participated in, have knowledge concerning, or are in any way
3 connected with, the creation of the MUSICAL COMPOSITION TAKE A DIVE.
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ANSWER: Objection. Plaintiff objects to Interrogatory No. 5 because

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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, none.

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Investigation continues.

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9 INTERROGATORY NO. 6: IDENTIFY all other PERSONS besides YOU who a
10 who assisted with, participated in, have knowledge concerning, or are in any way
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11 connected with, the creation of TAKE A DIVE SR, including by rendering a
12 performance of the MUSICAL COMPOSITION embodied therein.

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ANSWER: Objection. Plaintiff objects to Interrogatory No. 6 because

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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, none.

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Investigation continues.

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INTERROGATORY NO. 7: Do YOU claim that the MUSICAL
COMPOSITION, TAKE A DIVE, was infringed by DEFENDANTS?

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ANSWER: Objection. Plaintiff objects to Interrogatory No. 7 because

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it asks for a legal conclusion. Without waiving said objection, yes.

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Investigation continues.

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INTERROGATORY NO. 8: If YOU responded to Interrogatory No. 7, above, in
the affirmative, state all FACTS that YOU contend demonstrate that any of the
DEFENDANTS had ACCESS to the MUSICAL COMPOSITION, TAKE A DIVE,
prior to 2009. The term "ACCESS" as used herein means to have actually heard, or
had a reasonable opportunity or possibility to hear, the MUSICAL COMPOSITION
at issue.
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1 Dated: April 13, 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, CANFIE D, PADDOCK AND STONE,
P.L.C.
Ira Gould (appearing Pro Hac Vice)
Ryan L. Greelyappearing Pro Hac Vice)
GOULDLAWGROUP
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

3 I, Bryan Pringle, state that I have knowledge of the foregoing events, and that the
answers made to Defendant Adams' First Set of Interrogatories are true and correct,
4 to the best of my knowledge.
5 I declare the foregoing to be true under penalty of perjury.
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April 12, 2011.