Eight Mile Style, LLC et al v. Apple Computer, Incorporated
Filing 86
RESPONSE to 80 MOTION Exclude Late Produced Documents re 66 Renewed MOTION for Summary Judgment MOTION Exclude Late Produced Documents re 66 Renewed MOTION for Summary Judgment MOTION Exclude Late Produced Documents re 66 Renewed MOTION for Summary Judgment filed by Aftermath Records, Apple Computer, Incorporated. (Attachments: # 1 Index of Exhibits, # 2 Exhibit A - Declaration of Kelly M. Klaus In Support of Defendants Opposition to Plaintiffs Motion to Exclude Late Produced Documents, # 3 Exhibit A-1 - Order Granting in Part and Denying In Part Plaintiffs Motion to Compel Discovery Responses entered on June 25, 2008 (Docket No. 50), # 4 Exhibit A-2 - Proposed Scheduling Order entered on January 8, 2008 (Docket No. 20), # 5 Exhibit A-3 - Plaintiffs Initial Disclosures dated February 12, 2008, # 6 Exhibit A-4 - Plaintiffs First Set of Interrogatories dated February 12, 2008, # 7 Exhibit A-5 - Plaintiffs First Set of Requests for Production of Documents dated February 12, 2008, # 8 Exhibit A-6 - Aftermath Records Responses and Objections to Plaintiffs First Set of Interrogatories dated March 20, 2008, # 9 Exhibit A-7 - Aftermath Records Responses and Objections to Plaintiffs First Set of Requests for Production of Documents dated March 20, 2008, # 10 Exhibit A-8 - Apple Inc.s Responses and Objections to Plaintiffs First Set of Interrogatories dated March 20, 2008, # 11 Exhibit A-9 - Apple Inc.s Responses and Objections to Plaintiffs First Set of Requests for Production of Documents dated March 20, 2008, # 12 Exhibit A-10 - Letter dated April 1, 2008 from Richard Busch to Kelly Klaus and Daniel Quick, # 13 Exhibit A-11 - Email dated April 16, 2008 from Richard Busch to Kelly Klaus et al., # 14 Exhibit A-12 - List of Unresolved Issues submitted on June 10, 2008, # 15 Exhibit A-13 - Excerpts from transcript of Hearing on Plaintiffs Motion to Compel Discovery on June 12, 2008, # 16 Exhibit A-14 - Aftermath Records Supplemental Responses and Objections to Plaintiffs First Set of Interrogatories (No. 18) and to Plaintiffs First Set of Requests for Production (No. 6) dated July 3, 2008, # 17 Exhibit A-15 - Chart summarizing Plaintiffs late-produced and previously undisclosed documents that were relied on in their Summary Judgment Opposition, # 18 Exhibit A-16 - Plaintiff Eight Mile Style, LLCs Responses to Defendants First Set of Interrogatories dated March 21, 2008, # 19 Exhibit A-17 - Plaintiff Martin Affiliated, LLCs Responses to Defendants First Set of Interrogatories dated March 21, 2008, # 20 Exhibit A-18 - Plaintiff Eight Mile Style, LLCs Responses to the Defendants First Set of Requests for Production of Documents dated March 21, 2008, # 21 Exhibit A-19 - Plaintiff Martin Affiliated, LLCs Responses to Defendants Requests for Production of Documents dated March 21, 2008, # 22 Exhibit A-20 - Copyright Assignment and Co-Publishing Agreement dated February 4, 1999 between Ensign Music Corporation, Mark Bass and Jeff Bass, doing business as F.B.T. Productions and 8 Mile Style Music, c/o Joel Martin (Filed Under Seal), # 23 Exhibit A-21 - Copies of several mechanical licenses granted by Ensign Music Corporation (Filed Under Seal), # 24 Exhibit A-22 - FBT-00144, # 25 Exhibit B - Declaration of Rand Hoffman In Support of Defendants Opposition to Plaintiffs Motion to Exclude Late Produced Documents, # 26 Exhibit C - Declaration of Cynthia Oliver In Support of Defendants Opposition to Plaintiffs Motion to Exclude Late Produced Documents, # 27 Exhibit D - Declaration of Melinda LeMoine In Support of Defendants Opposition to Plaintiffs Motion to Exclude Late Produced Documents, # 28 Exhibit D-1 - Defendants Second Set of Interrogatories to Plaintiff Eight Mile Style, LLC dated April 30, 2008, # 29 Exhibit D-2 - Defendants Second Set of Interrogatories to Plaintiff Martin Affiliated, LLC dated April 30, 2008, # 30 Exhibit D-3 - Defendants Second Set of Requests for Production of Documents to Plaintiff Eight Mile Style, LLC dated April 30, 2008, # 31 Exhibit D-4 - Defendants Second Set of Requests for Production of Documents to Plaintiff Martin Affiliated, LLC dated April 30, 2008, # 32 Exhibit D-5 - Plaintiff Eight Mile Style, LLCs Responses to Defendants Second Set of Interrogatories dated August 8, 2008, # 33 Exhibit D-6 - Plaintiff Eight Mile Style, LLCs Responses to Defendants Second Set of Requests for Production of Documents dated August 8, 2008, # 34 Exhibit D-7 - Plaintiff Martin Affiliated, LLCs Responses to Defendants Second Set of Interrogatories dated August 8, 2008, # 35 Exhibit D-8 - Plaintiff Martin Affiliated, LLCs Responses to Defendants Second Set of Requests for Production of Documents dated August 8, 2008, # 36 Exhibit E - Declaration of Irek Lacki In Support of Defendants Opposition to Plaintiffs Motion to Exclude Late Produced Documents) (Klaus, Kelly)
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