Frances Malofiy Declaration (Skidmore v. Led Zeppelin "Stairway to Heaven" lawsuit)

8/17/2019 Frances Malofiy Declaration (Skidmore v. Led Zeppelin "Stairway to Heaven" lawsuit)

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DECLARATION OF FRANCIS MALOFIY IN SUPPORT OFPLAINTIFF’S MOTION TO COMPEL TRIAL TESTIMONY

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Francis Malofiy, Esq.Francis Alexander, LLC280 N. Providence Rd. | Suite 105Media, PA 19063T: (215) 500-1000; F: (215) 500-1005E: [email protected]

Attorney for Plaintiff

Glen L. Kulik, Esq. (SBN 082170)Kulik Gottesman & Siegel LLP15303 Ventura Blvd., Suite 1400Sherman Oaks, CA 91403T: (310) 557-9200; F: (310) 557-0224E: [email protected]

Attorney for Plaintiff

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

MICHAEL SKIDMORE, as Trustee forthe RANDY CRAIG WOLFE TRUST,

Plaintiff,

v.

LED ZEPPELIN; JAMES PATRICKPAGE; ROBERT ANTHONY PLANT;JOHN PAUL JONES; SUPER HYPEPUBLISHING, INC.; WARNER MUSICGROUP CORP., Parent ofWARNER/CHAPPELL MUSIC, INC.;ATLANTIC RECORDINGCORPORATION; RHINOENTERTAINMENT COMPANY,

Defendants.

Case No. 15-cv-03462 RGK (AGRx)

Hon. R. Gary Klausner

DECLARATION OF FRANCIS

MALOFIY IN SUPPORT OFPLAINTIFF’S MOTION TO

COMPEL TRIAL TESTIMONY

Case 2:15-cv-03462-RGK-AGR Document 220-1 Filed 05/17/16 Page 1 of 44 Page ID #:5679


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1 DECLARATION OF FRANCIS MALOFIY IN SUPPORT OFPLAINTIFF’S MOTION TO COMPEL TRIAL TESTIMONY

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I, Francis Malofiy, declare:

1. I am an attorney in the law firm of Francis Alexander, LLC, and I represent

Plaintiff Michael Skidmore, as Trustee for the Randy Craig Wolfe Trust in the above-

captioned matter. I have personal knowledge of the facts recited below, and, if called as

a witness, I could and would testify competently to the facts contained in this declaration.

2.

Attached to this declaration as Exhibit 1 is a true and correct copy of

subpoenas and notices to attend and testify that were served upon defense counsel.

3. Attached to this declaration as Exhibit 2 is a true and correct copy of emails

exchanged between Plaintiff’s counsel and defense counsel.

4. Attached as Exhibit 3 is a true and correct copy of the April 25, 2016, pre-

trial conference hearing transcript.I declare under penalty of perjury under the laws of the United States of America

that the foregoing is true and correct.

Executed this 17th day of May, 2016 at Burlington, Vermont.

/s/ Francis Malofiy Francis Malofiy



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EXHIBIT 1



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1

AJ Fluehr

From: Francis Alexander Malofiy

Sent: Saturday, May 14, 2016 11:42 PM

To: AJ Fluehr

Cc: Francis Alexander Malofiy

Subject: FW: Skidmore

Attachments: Notice to Attend and Testify Directed to Warner-Chappell.pdf; Notice to Attend andTestify Directed to Atlantic Recording.pdf; Notice to Attend and Testify Directed to

James Patrick Page.pdf; Notice to Attend and Testify Directed to John Paul Jones.pdf;

Notice to Attend and Testify Directed to Rhino Entertainment.pdf; Notice to Attend

and Testify Directed to Robert Anthony Plant.pdf; Notice to Attend and Testify Directed

to Super Hype Publishing.pdf; Notice to Attend and Testify Directed to Warner Music

Group Corp..pdf

From:

Francis

Alexander

Malofiy

Sent: Thursday, April 21, 2016 12:34 AM

To: Peter J. Anderson ; Helene M. Freeman

Cc: Francis Alexander Malofiy ; AJ Fluehr ; Glen Kulik

Subject: RE: Skidmore

Dear Peter,

See attached Notices to Attend and Testify.

For purposes of scheduling witnesses, please share with me whether or not Mr. Page, Mr. Plant, and Mr. Jones will

appear

in

Court

on

May

10th,

2016.

Please also advise as to the rest of the Notices.

*****

NOTE: ADDRESS CHANGED TO “SUITE 1”

*****

With every good wish, I am,

Francis Malofiy, EsquireFrancis Alexander, LLC280 N. Providence Road | Suite 1Media, PA 19063 T: (215) 500-1000F: (215) 500-1005E: [email protected]



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PAGE 1 OF 3

PLAINTIFF’S NOTICE TO ATTEND AND TESTIFY DIRECTED TO JAMES PATRICK PAGE

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Francis Malofiy, EsquireFrancis Alexander, LLC280 N. Providence Rd. | Suite 1Media, PA 19063T: (215) 500-1000; F: (215) 500-1005

E: [email protected]

Glen L. Kulik, Esq.Kulik Gottesman & Siegel LLP15303 Ventura Blvd., Suite 1400Sherman Oaks, CA 91403T: (310) 557-9200; F: (310) 557-0224E: [email protected]

Attorneys for PlaintiffUNITED STATES DISTRICT COURT



Plaintiff,

v.

LED ZEPPELIN; JAMES PATRICKPAGE; ROBERT ANTHONY PLANT;JOHN PAUL JONES; SUPER HYPEPUBLISHING, INC.; WARNER MUSICGROUP CORP., Parent ofWARNER/CHAPPELL MUSIC, INC.;ATLANTIC RECORDING

CORPORATION; RHINOENTERTAINMENT COMPANY,

Defendants.



NOTICE TO ATTEND AND

TESTIFY DIRECTED TO

JAMES PATRICK PAGE

Date: May 10, 2016Time: 9:00 a.m.Room: 850

NOTICE TO ATTEND AND TESTIFY DIRECTED TOJAMES PATRICK PAGE



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TO: JAMES PATRICK PAGEPeter J. Anderson, Esquire100 Wilshire Blvd. | Suite 2010Santa Monica, CA 90401T:(310) 260-6030

F: (310) 260-6040E: [email protected] Attorney for Defendants Warner/Chappell Music, Inc., Atlantic Recording

Corporation, and Rhino Entertainment Company, James Patrick Page,

Robert Anthony Plant, and John Paul Jones

Helene Freeman, Esquire666 Fifth Avenue

New York, NY 10103-0084T: (212) 841-0547

F: (212) 262-5152E: [email protected]

Attorneys for Defendants James Patrick Page, Robert Anthony Plant, and

John Paul Jones (collectively with John Bonham (Deceased),

professionally known as Led Zeppelin)

TO DEFENDANT JAMES PATRICK PAGE AND HIS COUNSEL OF

RECORD:

PLEASE TAKE NOTICE THAT plaintiff Michael Skidmore demands the presence

James Patrick Page on May 10, 2016, at Roybal Courthouse, Room 850, 255 East Temple Stre

Los Angeles California 90012-3332 to testify in the above-captioned matter.

DATED: April 20, 2016 FRANCIS ALEXANDER, LLC

By /s/ Francis Malofiy Francis MalofiyAttorneys for Plaintiff



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CERTIFICATE OF SERVICE

Plaintiff hereby represents that Plaintiff’s Notice to Attend and Testify Directed to Jam

Patrick Page has been served upon counsel by email:

Helene Freeman, Esquire666 Fifth Avenue New York, NY 10103-0084T: (212) 841-0547F: (212) 262-5152E: [email protected] Attorneys for Defendants James Patrick Page, Robert Anthony Plant, and John Paul Jone

(collectively with John Bonham (Deceased), professionally known as Led Zeppelin)

Peter J. Anderson, Esquire100 Wilshire Blvd. | Suite 2010

Santa Monica, CA 90401T:(310) 260-6030F: (310) 260-6040E: [email protected] Attorney for Defendants Warner/Chappell Music, Inc., Atlantic Recording Corporation,

and Rhino Entertainment Company; James Patrick Page, Robert Anthony Plant, and John

Paul Jones

*****

Respectfully submitted,

Francis Alexander, LLC

/s/ Francis Alexander MalofiyFrancis Alexander Malofiy, EsquireAttorney ID No.: 208494280 N. Providence Road | Suite 1Media, PA 19063T: (215) 500-1000F: (215) 500-1005E: [email protected]

/d/ April 20, 2016


mailto:[email protected]:[email protected]:[email protected]


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PLAINTIFF’S NOTICE TO ATTEND AND TESTIFY DIRECTED TO JOHN PAUL JONES

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Plaintiff,

v.



Defendants.




TESTIFY DIRECTED TO

JOHN PAUL JONES


NOTICE TO ATTEND AND TESTIFY DIRECTED TOJOHN PAUL JONES



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TO: JOHN PAUL JONESPeter J. Anderson, Esquire100 Wilshire Blvd. | Suite 2010Santa Monica, CA 90401T:(310) 260-6030





New York, NY 10103-0084T: (212) 841-0547





TO DEFENDANT JOHN PAUL JONES AND HIS COUNSEL OF RECORD:


John Paul Jones on May 10, 2016, at Roybal Courthouse, Room 850, 255 East Temple Street, L

Angeles California 90012-3332 to testify in the above-captioned matter.


By /s/ Francis Malofiy Francis Malofiy

Attorneys for Plaintiff



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Plaintiff hereby represents that Plaintiff’s Notice to Attend and Testify Directed to Joh

Paul Jones has been served upon counsel by email:






Paul Jones

*****




/d/ April 20, 2016




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PAGE 1 OF 3

PLAINTIFF’S NOTICE TO ATTEND AND TESTIFY DIRECTED TO ROBERT ANTHONY PLANT

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Plaintiff,

v.



Defendants.




TESTIFY DIRECTED TO

ROBERT ANTHONY PLANT


NOTICE TO ATTEND AND TESTIFY DIRECTED TOROBERT ANTHONY PLANT



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TO: ROBERT ANTHONY PLANTPeter J. Anderson, Esquire100 Wilshire Blvd. | Suite 2010Santa Monica, CA 90401T:(310) 260-6030





New York, NY 10103-0084T: (212) 841-0547





TO DEFENDANT ROBERT ANTHONY PLANT AND HIS COUNSEL OF

RECORD:


Robert Anthony Plant on May 10, 2016, at Roybal Courthouse, Room 850, 255 East Temple Stre

Los Angeles California 90012-3332 to testify in the above-captioned matter.


By /s/ Francis Malofiy Francis MalofiyAttorneys for Plaintiff



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Plaintiff hereby represents that Plaintiff’s Notice to Attend and Testify Directed to Robe

Anthony Plant has been served upon counsel by email:






Paul Jones

*****




/d/ April 20, 2016




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EXHIBIT 2



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From: Peter J. Anderson [mailto:[email protected]]

Sent: Friday, May 06, 2016 7:23 PM

To: Francis Alexander Malofiy ; Helene M. Freeman

Cc: AJ Fluehr ; Glen Kulik


Francis:

It really is important that you not misrepresent what Helene and I have said and written, and that youmeet the court’s deadlines rather than ignore them.

As Helene and I previously raised multiple times, if you wanted to use deposition testimony in lieu oflive testimony you were required to have provided marked transcripts at the 40 day meeting. Youdidn’t do so.

Also, even if you could cure that now, you haven’t done so. For example, you were required toprovide the full transcripts (not mini or newspaper-formatted versions) marked to show the testimonyyou intend to offer, so that the full transcripts with our objections noted can be lodged with the courtwith the required index. You can’t lodge the mini versions with small type and objections squeezed

in.

I also don’t understand your statement that it is nearly impossible to designate the testimony youintend to offer in lieu of live testimony – if that is so, then what did you just send us?

As to the various assertions in your e-mail, you know (for example from defendants’ inserts to the April 24, 2016 filing) that you’ve got the facts wrong and also have no legal basis for the relief youthreaten to seek. It is sufficient to say you are incorrect, we disagree with your assertions and therecord confirms you are incorrect. As an example, only, we have previously made it clear thatMessrs. Page and Plant will attend the trial, but with them coming from England we cannot guaranteethe day they will arrive. As for Mr. Jones, he was granted summary judgment and is no longer a

defendant in the case, although we expect him to testify as a defense witness.

Best regards.

Peter.

From: Francis Alexander Malofiy [mailto:[email protected]]

Sent: Thursday, May 05, 2016 11:11 PM

To: Peter J. Anderson; Helene M. Freeman



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Cc: Francis Alexander Malofiy; AJ Fluehr; Glen KulikSubject: RE: Skidmore

A file has been sent to you via Hightail - the best way to send, share, and store your files. Try it now.

Download the file - 2016.05.05 - LED ZEPPELIN - DEPOSITION - DESIGNATIONS (SERVED)~

Your file will expire after 14 days.

Dear Peter,

Attached please find Plaintiff’s Designations. We intend to use these designations including the deposition video at time

of trial. We will also be using defendants declarations, answers, and discovery responses in our case in chief (including

but not limited to: Page, Plant, and Jones, the corporate defendants, and dismissed defendants).

Additionally—and especially now because of the time constraints of the trial—I repeat myself in asking that for purposes

of scheduling witnesses and preparing for trial that you share with me whether or not Mr. Page, Mr. Plant, and Mr.

Jones will appear in Court on Tuesday, June 14, 2016 at 9 am. If they are not to appear on this date and time, please tell

me definitively a date and time when they will be present in Court—if at all.

As you are aware, we noticed and subpoenaed these defendants and it is nearly impossible to designate what portions

of their testimony will be necessary without knowing if Mr. Page, Mr. Plant, or Mr. Jones will appear in Plaintiff’s case in

chief. I therefore kindly reiterate my request to you as their counsel to inform me whether or not they will appear as

noticed and subpoenaed.

Because you have failed to work with me in regards to scheduling the party opponents for trial, Plaintiff reserves all

rights, including but not limited to asking the Court for a negative inference, precluding defendants from testifying in

defendants case in chief, and for a default. Plaintiff additionally, reserves the right to supplement or modify the

attached designations.

To the extent a witness is unavailable for time of trial, Plaintiff reserves his right to use their deposition testimony and

video.

To the extent you wish to discuss further I am working and available now. Additionally, I will be in the office all day

tomorrow (Friday).

***** With every good wish, I am,

Francis Malofiy, Esquire Francis Alexander, LLC 280 N. Providence Road | Suite 1 Media, PA 19063 T: (215) 500-1000 F: (215) 500-1005 E: [email protected]



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Sent: Thursday, April 21, 2016 12:34 AM

To: 'Peter J. Anderson' ; 'Helene M. Freeman'

Cc: Francis Alexander Malofiy ; AJ Fluehr ; 'Glen Kulik'


Dear Peter,

See attached

Notices

to

Attend

and

Testify.

For purposes of scheduling witnesses, please share with me whether or not Mr. Page, Mr. Plant, and Mr. Jones will

appear in Court on May 10th, 2016.

Please also advise as to the rest of the Notices.

*****



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NOTE: ADDRESS CHANGED TO “SUITE 1”


Francis Malofiy, Esquire Francis Alexander, LLC

280 N. Providence Road | Suite 1

Media, PA 19063 T: (215) 500-1000 F: (215) 500-1005 E: [email protected]


Sent: Thursday, April 14, 2016 11:54 PM

To: 'Peter

J.

Anderson'

;

Helene

M.

Freeman

Cc: Francis Alexander Malofiy ; AJ Fluehr ; Glen Kulik


Peter,

To be clear:

(1)

You are refusing to accept subpoenas on behalf of your clients? (Page, Plant, Jones, and the corporate

defendants which you represent)

(2)

Although we disagree whether or not your clients are within the subpoena power of the Court, can you confirm

that you will have your clients—Jimmy Page and Robert Plant—at trial from the start on May 10. As you know

we fully intend to have Jimmy Page and Robert Plant testify in Plaintiff’s case‐in‐chief. Because of scheduling of

witnesses and addressing issues with the Court, do you foresee any issue with this scheduling of Page, Plant, and

Jones?

(3) I’m not sure why you are making an issue regarding Page, Plant, and Jones video deposition, as I shared with

you, we fully intend to use the full video depositions to be played for the jury—subject to your objections which

we can discuss. As you know, many thousands of dollars were spent getting high quality video depositions of

defendants to be used at trial. Obviously, if Plant and Page fail to appear or refuse to appear—we will be left

with no choice but to play the full deposition to the jury.


Francis Malofiy, Esquire Francis Alexander, LLC 280 N. Providence Road | Suite 1 Media, PA 19063



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T: (215) 500-1000 F: (215) 500-1005 E: [email protected]

From: Peter J. Anderson [mailto:[email protected]]

Sent: Thursday, April 14, 2016 10:32 PM

To: Francis Alexander Malofiy

Cc: Helene M. Freeman ; AJ Fluehr ; Glen Kulik


Francis:

Attached is your draft of the joint witness list, marked to show the changes.

As to presenting testimony by deposition/video in lieu of a witness appearing, you were required

under our local rules and the court’s order to, for example, identify the witness and the testimony youintended to use by providing marked copies of the deposition transcripts at the 40-day meeting. Younever did that, so you waived the right to use depositions in lieu of live testimony.

You may recall that I told you that I had marked the Ruhlman and Andes deposition testimony in thesummary judgment papers and that is what I would use for Ruhlmann and, if Andes didn’t appear, forhim. However, we don’t intend to call Ruhlmann and you’ve advised you’re producing Andes.

As to subpoenas, I’m not sure what you mean by subpoenas for “The Corporate Defendants.” If youmean Messrs. Blietz and Woerhle or any substitute PMK, I’m happy to find out if they’ll acceptsubpoenas and will let you know. The individual defendants, of course, are outside the court’s

subpoena power, so even if they were to be served that would be an idle act. But I do expect them toappear to testify, if that’s any help.

Best regards.

Peter.



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From: Francis Alexander Malofiy [mailto:[email protected]]

Sent: Thursday, April 14, 2016 5:32 PMTo: Peter J. Anderson; Helene M. FreemanCc: Francis Alexander Malofiy; AJ Fluehr; Glen Kulik


Dear Peter,

See

attached

Joint

Witness

List.

Please confirm that you will accept service for your clients for subpoenas for them to appear at testify at trial.

Mr. Jimmy Page;

Mr. Robert Plant;

Mr. John Paul Jones; and

The Corporate Defendants


Francis Malofiy, Esquire Francis Alexander, LLC 280 N. Providence Road | Suite 1 Media, PA 19063 T: (215) 500-1000 F: (215) 500-1005 E: [email protected]



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EXHIBIT 3



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CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION

HONORABLE R. GARY KLAUSNER, U.S. DISTRICT JUDGE

MICHAEL SKIDMORE, as Trustee for the: )RANDY CRAIG WOLFE TRUST, )

)Plaintiff, )

)vs. ) CASE NO.

) CV 15-3462-RGK(AGRx))

LED ZEPPELIN, et al., ))

Defendants. ) ______________________________________)

REPORTER'S TRANSCRIPT OFPRETRIAL CONFERENCE

MONDAY, APRIL 25, 20169:08 A.M.

LOS ANGELES, CALIFORNIA

________________________________________________________

SHAYNA MONTGOMERY, CSR, RPR, CRR FEDERAL OFFICIAL COURT REPORTER

312 NORTH SPRING STREET

LOS ANGELES, CALIFORNIA 90012

(213) 894-2665

2

APPEARANCES OF COUNSEL:1

2

FOR THE PLAINTIFF:3

FRANCIS ALEXANDER, LLC4

BY: FRANCIS MALOFIY

Attorney at Law5

280 North Providence Road, Suite 1

Media, Pennsylvania 190636

(215) 500-1000

7

FOR THE PLAINTIFF:8

KULIK GOTTESMAN & SIEGEL LLP9

BY: GLEN L. KULIK

Attorney at Law10

15303 Ventura Boulevard, Suite 1400

Sherman Oaks, California 9140311

(310) 557-9200

12

FOR THE DEFENDANTS WARNER/CHAPELL MUSIC, RHINO ENTERTAINMENT13

COMPANY, ATLANTIC RECORDING CORPORATION, ROBERT ANTHONY PLANT

AND JAMES PATRICK PAGE:14

LAW OFFICES OF PETER J. ANDERSON PC15 BY: PETER J. ANDERSON

Attorney at Law16

100 Wilshire Boulevard, Suite 2010

Santa Monica, California 9040117

(310) 260-6030

18

FOR THE DEFENDANTS JAMES PATRICK PAGE, ROBERT ANTHONY PLANT AND19

JOHN PAUL JONES:

20

PHILLIPS NIZER LLP

BY: HELENE M. FREEMAN21

Attorney at Law

666 Fifth Avenue22

New York, New York 10103

(212) 977-970023

24

25


3

LOS ANGELES, CALIFORNIA; MONDAY, APRIL 25, 20161

9:08 A.M.2

--oOo--3

THE COURTROOM DEPUTY: Calling calendar item number4

five, case number Civil 15-3462-RGK, Michael Skidmore vs.5

Led Zeppelin, et al.6

Counsel, please come forward and state your appearances.7

MR. ANDERSON: Good morning, Your Honor. Peter8

Anderson for defendants Warner/Chapell Music, Rhino9

Entertainment Company, Atlantic Recording Corporation,10

Mr. Plant and Mr. Page, and with me is Ms. Freeman.11

THE COURT: Okay.12

MS. FREEMAN: Helene Freeman, co-counsel for13

defendants James Patrick Page, Robert Anthony Plant and14

John Paul Jones.15

THE COURT: Okay. Thank you, counsel.16

MR. MALOFIY: May it please the Court, attorney17

Francis Alexander Malofiy on behalf of plaintiff Michael18

Skidmore as trustee for the Randy Craig Wolfe Trust, who is19

here today, and also my co-counsel.20

MR. KULIK: Good morning, Your Honor. I'm Glen21

Kulik, co-counsel for the plaintiff.22

THE COURT: Okay. Thank you, counsel.23

Let's talk a little bit about -- why don't you have a24

seat, we'll be a few minutes.25


4

Let's talk about pretrial. This is to help you out to1

decide -- or to understand what's going to happen when you come2

in in a couple of weeks as far as the trial is concerned.3

Let me, first of all, start by talking to you about --4

well, let's get the tough part over first, the part the5

attorneys never like, and that is, is we set time limits here.6

I set them off witness statements that -- the joint witness7

list you've submitted as to what they'll be testifying to and8

what's significant and what the issues are, and we adhere by9

those time limits.10

In this case, for instance, although you've had numerous11

witnesses, many of them are either repetitive or not necessary.12

In looking at it -- and let me just give you an example.13

First, it's on the issue of creation of the song. We have one,14

two, three, four, five, six, seven, eight, nine, ten, 11, 12 --15

12 witnesses on that. As far as I'm concerned, that's one16

issue, one witness as far as I'm concerned. If you want to17

call two, three, four, that's fine. You can call as many18

witnesses as you want, but you're going to be within a time19

frame. You know, we have the same thing on experts on20

similarity. We've got four, five experts on similarity. You21

can call five if you want, or you can call one if you want.22

That's up to you. How you put the case on is up to you.23

But as far as the issues that are involved in this case,24

it's a much shorter case than you've anticipated. When you25




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first came in here, you said 15 days. I told you at that time1

probably about four or five days. I even think four or five2

days may be a little long in this case. You have basically3

four issues or areas that you're going to be going into.4

You're going to be going into whether or not there is a valid5

copyright on it by the plaintiff. Number two, you're going to6

be looking at whether or not there's similarities in the two.7

If there are, then you're going to be looking at access. If8

there is access, similarities and copyright, then you're9looking at damages. You're looking at four areas.10

So even if you spend a couple of hours on copyright and a11

couple of hours on access, three or four hours on similarities12

between the songs, couple hours in damages, you're looking at13

about ten hours on this case. It should be able to be14

presented in ten hours without any problem. I'm going to15

double that. I'm going to give ten hours per side. So each16

side will get up to ten hours to try their case. Now -- and I17

may or may not review that and revise that on the trial date,18

but that's what we can count on now, ten hours a side.19

Let me talk to you about the ten hours. That comes from20

any time you're asking questions or any time you're21

cross-examining, any time you're talking, when there's22

witnesses on the stand, that's part of the ten hours. It does23

not include opening statement. It does not include closing24

argument. I'll give you time limits on those when we get --25


6

you know, on the day of the trial. But keep in mind I will1

keep a running tally, kind of a time clock thing, as to2

those -- as to your time. I'll give it to you in terms of3

minutes rather than hours. For instance, what, that's 6004

minutes for ten hours, and I'll let you know each day what5

you're down to, how much time you have left.6

If you use up those ten hours or whatever those time7

limits are and the other side hasn't, keep in mind that as8

they're asking questions you're not going to be able to9

cross-examine. Once you've used your time, you're out. That's10

it. So be very careful that you plan your case accordingly.11

Make sure that you use your time accordingly.12

Now, keep in mind nobody's infallible, even this Court,13

and so sometimes we get that wrong. And if at the end of the14

trial or at the end of your time limits I'm convinced that15

you've used your time efficiently and effectively and the16

interest of justice calls for more time, I'll give it to you.17

I'll give you more time if I think you -- caveat, in 14 years18

since I've been here that's only happened once, so don't count19

on it, but I will -- I will take that into consideration.20

So keep in mind that ten hours and plan accordingly. I21

know it takes more preparation. There used to be a great22

commentator on TV that used to say, "It takes me take me four23

or five hours to" -- or, excuse me, "It takes me half hour to24

prepare an hour speech. It takes me three hours to prepare a25


7

ten minute speech" because you have to focus, you have to1

figure what exactly has to get in there, et cetera. So it's2

going to be more preparation on you, but it's going to be a3

much cleaner case. It's going to be much more focused. It's4

going to go to the jury without red herrings and things that5

are going to confuse them, and it'll be a better trial on6

everyone's behalf.7

Okay. Let me talk to you about motions in limine. On8

motions in limine, let me just give you tentatives at this9time, and I want you to keep in mind something on motions in10

limine. As we know, they're really evidentiary rulings by the11

Court, and they're tentative evidentiary rulings. Basically,12

what it's saying is no, you can't get into that unless the13

Court changes its mind. And the reason I tell you that is that14

during the trial, depending on what evidence comes in,15

something that we may have said was excluded may become16

relevant at one time and then you bring it in.17

So these are tentative rulings that the Court's going to18

be issuing on these, and this is going to be tentative,19

tentative rulings because I'm going to -- on the day of the20

trial, I'm going to most probably say the same reason I gave21

you today, hold. But between now and then, I'm going to be22

looking at a few things and some of them may change, so the23

motions in limine, the final ruling on the motions in limine24

will be on the day of trial.25


8

But let me give you -- so that you can prepare the case,1

let me tell you what the tentatives on this are. As to the2

defendants' motions in limine -- and you know what your motion3

in limine are, so I'm just going to go through by number. Some4

of them I'll stop and talk to you about. If you're confused as5

to what that motion in limine is, stop me and I'll be happy to6

explain to you which motion in limine it is.7

But, for instance, on the defense, on number one8

concerning Randy Wolfe's statement, that will be granted.9

Number two concerning the newspaper articles and books, 10

to the books that'll probably be granted. As to pages,11

statements that were made in magazines, that may very well be12

relevant as far as accessibility, as far as whether or not they13

saw people talking to each other, et cetera.14

Number three, motions to exclude the recordings, again15

this is about composition and protected areas under the16

composition, not the recording, so that would be granted.17

Number four, motions to exclude testimony of exhibits18

of -- excuse me, motions to exclude the testimony and exhibits19

of the plaintiff's experts, that's a little difficult to20

explain, but the expert testimony that is based on the21

composition itself incoming, any expert testimony that's based22

on the musical composition, the musical performance, would not23

be admissible.24

Number five, motions to exclude other claims against25




40/44


9

Led Zeppelin will be granted.1

Motions to exclude reports from the historians would be2

granted.3

Number seven, motions to exclude levels of wealth will be4

granted.5

Number eight, motions to exclude evidence regarding6

charitable goals of the Trust will be granted.7

Number nine, motions to exclude reference to8

extraterritorial revenues and revenues earned outside of the9limitation period. As to province earned outside of the10

limitation period, that will be granted. As to territorial11

limits, that would be denied.12

Number ten, I'm going to have to give you a little bit13

more reading on this when you come in for trial. These are the14

motions to exclude witnesses that have not been disclosed. The15

fact that you put a whole bunch of witnesses' names into16

hundreds of pages of discovery doesn't necessarily give you17

notice that these may be potential witnesses. So the Court's18

looking at it as whether or not you are on notice that these19

may be witnesses or not. Some of them, it looks like, are20

going to be excluded; some of them may not be. For instance,21

one that may not be is Wolfe because I think both sides22

understand that Wolfe was, you know, a participant in Spirit,23

et cetera, and may be called as a witness, but I'll give you24

that on the day of trial more explicitly.25


10

Number 12 as to alcohol abuse, that will be granted.1

Number 13 as to insurance or indemnity agreement, that2

will be granted.3

Number 14 as to the actual complaint going in front of4

jury, that will not happen. They'll be told what the causes of5

action are, but the actual complaint will not be in front of6

them.7

As to the plaintiff's motions in limine as to the validity8

or legitimacy of the Trust, that will be granted. As to9

evidence concerning the son of Wolfe and whether or not he owns10

a copyright or not, that will be denied. And as to the motion11

to exclude any experts on damages by the defense, that, I'm12

assuming, is going to be in rebuttal. So it'll be denied as13

far as rebuttal is concerned.14

Okay. Now that's on the motions in limine. Let me talk15

to you a little bit about what you can expect when you come in16

for trial. First of all, I don't know if you have it or not,17

you'll have to tell me. Do you have a short statement of the18

case already filed with the court?19

MR. ANDERSON: Not yet.20

MR. MALOFIY: No, we do not, Your Honor.21

THE COURT: Okay. What I'd like is -- when I say a22

short statement, the operative word there is "short." Maybe a23

paragraph just to tell the jury what it's about, you know,24

what -- this is a copyright-type case involving these two25


11

songs, et cetera. But I don't want it argumentative or to go1

longer than maybe a paragraph, just something short we can re2

to them.3

I also want every day an order of the witnesses that you4

intend to call that day, and make it for the next maybe two5

days so I know when the witnesses are going to be called and6

what order they'll be called. I've got a list of the7

witnesses, but I don't know what order you're going to be8

calling them in.9Number three, voir dire, the Court conducts the voir dire10

in cases in this court. We will be bringing in -- well, first11

of all we're going to pick a jury of eight so we have two12

extras in case there's any problem. That means I'm going to13

give you four peremptory challenges on each side. We'll be14

bringing in the jury. We'll sit 14 up -- it's a six-pack-type15

thing. We'll be sitting 14 up there. The Court will voir dire16

them. After I voir dire them -- and by the way, any questions17

that you would like to ask on voir dire, if you've not already18

submitted them, you can submit them and the Court will consid19

those and incorporate them to the extent I feel it's20

appropriate during my voir dire.21

The 14 will sit there. We'll go through the voir dire.22

After I've done that, we'll meet over here at the side bench,23

counsel and myself, and we'll go through your challenges,24

challenges for cause, any of the 14 that we have sat in the25


12

box. Peremptory challenges only as to the first eight. No1

reason to exercise a peremptory challenge before one of the2

eight, you know, it doesn't make much sense. Remember as y3

go through that on your peremptory challenges, if you pass on 4

peremptory challenge, you do not lose it, which means that we5

may end up in a situation where somebody has two or three6

peremptory challenges left and the other side doesn't have any7

That's fine, but you remember that if you pass and the other8

side passes, you've got your jury. You can't go back and9

exercise and begin if both sides pass, but you don't lose it if10

you pass, is what I'm saying.11

When we finish the voir dire over here -- excuse me, the12

challenges over here, I'll take the bench, and I'll excuse.13

When we get to seven jurors being excused, I'll get -- come14

back, take the bench, and I'll excuse the seven jurors by just15

calling their number and excusing them. They will not know wh16

excused them or why they were excused, whether it's for cause17

or peremptory or whatever. We'll just excuse those seven.18

Then we'll bring another seven in. We'll go through the same19

process again, go through the same process as far as challenge20

until we get a jury of eight that we can sit.21

I don't know if you have any questions on that process22

that I've just told you as far as voir dire.23

MR. ANDERSON: Not on voir dire, Your Honor. I do24

have --25




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13

THE COURT: Well, we'll get to other matters in a1

second. I just want to make sure voir dire, but --2

MR. ANDERSON: Thank you.3

THE COURT: Save your question, I'll address it. I4

just want to -- on voir dire, any other questions on voir dire?5

Okay.6

If not, keep in mind something interesting. That bench7

conference we have over there will be the only bench conference8

that we'll ever have during the trial. I don't have bench9conferences during a trial. I'll talk to you maybe a little10

bit later on it, but if you have objections and you want to be11

heard on the objections, you bet, but you'll be heard at the12

next time we make a break. I'll be ruling on the objection.13

We'll proceed. Next time we make a break, you put it on the14

record and we can either correct it if it has to be corrected15

or at least preserve the record for later, but we do not break16

in front of jury for bench conferences.17

A couple of the procedural things that I just wanted to18

address -- every court does it a little differently -- in here,19

any time you make an objection please stand so I know you're20

making an objection. Sometimes if you don't stand and, you21

know, in a very low voice you say, "Objection," I won't even22

hear it. So, you know, stand and let me know you're making the23

objection. Do not argue objections in court. You can tell us24

what the objection is. "Objection, hearsay." That's it. We25


14

do not argue in front of the jury as to what the objection is,1

and the other side can say "Not offered for the truth of the2

matter." That's fine, but we don't argue further than that.3

Any time you present evidence to this Court always present4

it through the clerk. Never approach a witness directly,5

always through the clerk and give it to the clerk and she'll6

take it to the witness. You know, I don't think it has to be7

said because I think, you know, we're pretty professional here,8

but never refer to a witness by first name. Everybody has the9

dignity in this court by being referred to by their last name.10

If -- and this is just to run the case smoothly -- if11

somebody says, "I want to introduce Exhibit 1 or whatever it is12

into evidence," I will always wait about three or four seconds,13

and if I don't hear an objection I'll probably say "Received."14

The reason I say that is don't feel obligated to get up and15

constantly say "No objection." You can if you want, but you16

don't have to say no objection on it. If there's no objection17

within three or four seconds, I'm assuming there's not going to18

be an objection.19

When you speak, always speak -- with the exception of20

making the objection where you could stand where you are --21

when you speak, always speak from the podium or the lectern,22

whichever one you want to call it here, because everything has23

to be on the record. I've got -- I need you in front of the24

microphone, and we don't -- like in, you know, some other25


15

courts or particularly in state courts you have wandering1

around, talking in front of there, you don't here. You speak2

from the lectern and only from the lectern.3

If you introduce evidence or exhibits that are voluminous4

only introduce those pages that have been referred to in the5

testimony. If you have a 100-page document and you only re6

to three pages, only introduce those three pages, not the7

entire voluminous document -- document on it. You will find8

out that almost anything that the attorneys agree on, the9Court -- as long as it doesn't affect the jury and the time10

limits, the Court will go along with you. If you want to call11

witnesses out of order, if you want to do this or that, I'm12

very big on the attorneys' cooperation in the case and what yo13

decide to do, and if you both agree to do it, I almost always14

will ride with it. So before you bring anything to the Court's15

attention, I really want you to -- the two sides to talk about16

it, see if you can agree on it. If you can't, bring it to my17

attention. I'll be happy to make the call on it.18

The one area that somebody asked me the other day abo19

is there anything that we have to know about the Court's20

idiosyncrasies, you know, really irritating the Court, and the21

answer is yeah. Not a whole lot, but the biggest thing is if22

there's any lack of civility. And I don't expect that here,23

but if there's any lack of civility at all, I wouldn't want to24

be in your shoes, is all I can say. I want this jury when they25


16

leave here to be under the impression that both sides are very1

professional and both sides respect each other as attorneys an2

as lawyers and as officers of the court.3

I don't care what you do in the alleys behind court after4

session when we're not in session, but when you're in court,5

each side is going to show utmost respect to each other. If6

you don't, the Court will come down heavily on you as far as7

sanctions, and even sometimes if you don't follow the court8

order or you're causing troubles in court, many times it will9

be to the point where I will correct you and admonish you in10

front of the jury, and you don't want that to happen. You11

know, nobody wants to be admonished in front of the jury. It12

looks bad. There's no reason for that, I don't expect that in13

this case, but I just wanted to give you a heads up so that14

nobody's blindsided on it, that civility is a real big thing in15

this court.16

Let's see. Time, let me talk to you a little bit about17

time and -- I haven't forgotten you, I'm going to get to your18

question, counsel, in just a second. Time. When you come on19

in the first day you'll come in at nine o'clock, we'll do some20

logistical things, get things wrapped up. At quarter of 10:00,21

we'll have the jury down here. We'll pick the jury at quarter22

of 10:00 and proceed at that time. The first day, because23

we're starting a little bit late that way, we'll have to adjust24

depending on voir dire and everything else.25




42/44


17

Now, the second and remaining days of the jury trial will1

always be on a schedule, and it'll be from 8:30 in the morning2

until 11:30. We'll take a break for lunch until 1:00. We'll3

come back at 1:00 and go until 4:00. That's a three-hour4

session in the morning, three-hour session in the afternoon.5

We'll give you a 15-minute break in there to take care of 6

needs, et cetera, but you can set your watch by that. At 8:307

we're going to be starting, and the jurors will know this too,8

you know, if somebody's missing, even a juror, we'll probably9sit here with everyone in court waiting as that person walks10

in, which will for sure be embarrassing. We'll start right at11

8:30.12

Keep in mind that it's just as important to end on time as13

it is to start on time. At four o'clock, if you're in the14

middle of a question, I'll probably say, "Remember that15

question. You can repeat it tomorrow morning, but you're not16

going to ask it now." Four o'clock we break. Jurors who we17

call in -- you know, and it's never comfortable for them, and18

they've got families that work here. They're entitled to know19

when they're free and when they're not. They're going to know20

that at four o'clock they're going to be free, so if they have21

somebody picking them up, if they have to do some obligation22

after court, that they can count on that because they will be23

through at four o'clock, and they can do whatever they want.24

And, by the way, the same is true for lunch. 11:30 we'll stop;25


18

at one o'clock we'll start. So you can almost set your clock1

by that.2

Now, interesting thing, what happens if you get to quarter3

of 4:00 and you've run out of witnesses, and you say, Would you4

mind if we end a little bit early rather than late? Would you5

mind if we ended quarter of 4:00? The answer is no, I don't6

mind if you end early, but that 15 minutes is going to come off 7

your time, so -- just as if you're questioning a witness. So8

you want to make sure you always have backup witnesses so that9

that doesn't happen.10

Well, counsel, you know, I've been talking a lot here.11

I've been going kind of fast, and I don't want to bore you all.12

You've been in trials before.13

So let me ask you this: What questions might you have at14

this time? And you said you had one.15

MR. ANDERSON: Yes, Your Honor, thank you.16

On the Motion in Limine Number 3, we, of course,17

appreciate the Court's ruling that the evidence and the experts18

will be confined to the transcriptions. Our concern is19

several. One is none of the plaintiff's experts have ever20

issued --21

THE COURT: Counsel, let me help you out. The22

motions in limine were briefed fully by both sides. The23

Court's made rulings on them. I'm not opening it up for24

discussion at this time. If you have something you want me to25


19

consider that you haven't put in your moving papers, go ahead1

and submit it in the next day or two. I'll look at it again.2

As I said, these are tentative until day of trial.3

MR. ANDERSON: Okay, but, Your Honor, my questio4

whether plaintiff can be required at this point to provide the5

Rule 26(f) -- the 26 reports for the experts that were never6

provided. And -- so is Your Honor considering that we'll7

proceed to trial without either 26 -- Rule 26 reports from8

plaintiff's experts on the transcription and depositions of 9those experts?10

THE COURT: The general rule applies, and that is if11

you have not followed the rules and it's not properly12

admissible, it's not going to come in, you know.13

MR. ANDERSON: That's fine. Thank you, Your Honor14

THE COURT: Yeah.15

MR. ANDERSON: Thank you for the clarification.16

THE COURT: Oh, sure.17

MR. ANDERSON: I may have misheard, but I think o18

in Limine Number 10, which seeks the exclusion of Mr. Knight,19

Mr. Lee and -- both Mr. Lees and others, I believe I heard you20

refer to Mr. Wolfe as a witness.21

THE COURT: Oh, I'm sorry. No, I'm sorry.22

Mr. Knight I was referring to.23

MR. ANDERSON: Okay.24

THE COURT: I misspoke.25


20

MR. ANDERSON: Thank you, Your Honor. And --1

THE COURT: Mr. Wolfe would be tough to get in as a2

witness.3

MR. ANDERSON: Yes, we tried, Your Honor, but4

weren't able to pull that one off. And then the only other5

thing I supposed I should repeat the request for a Daubert6

hearing if any of the experts that plaintiff has identified do7

get past the Rule 26 issue.8

THE COURT: Well, again, anybody in a case could9

file any motions they wish to file. If you want to make them,10

that's fine, make those motions. The Court will determine,11

number one, whether or not they're timely and should be12

addressed, or we'll rule on them. So I'm not foreclosing you13

from making any motions you want.14

MR. ANDERSON: Thank you very much, Your Honor.15

THE COURT: Counsel, anything for you?16

MR. MALOFIY: Yes, Your Honor.17

May it please the Court, couple questions to address with18

the Court. One issue is that in this case, defendants had19

agreed to personal jurisdiction of this court rather than the20

court of Philadelphia. It was transferred from the Eastern21

District of Philadelphia to this court, and now defendants are22

refusing to appear in this court in the claims against them.23

Plaintiff intended to, at all times, bring them in plaintiff's24

case-in-chief as if on cross, and defendants are telling me,25




43/44

4/28/2016 08:42:38 PM Page 21 to 24 of 28 6 of 7 s

21

defense counsel, that they're outside the power of this court1

and they won't appear. If that's the case, plaintiff would be2

asking for, at the very least, a negative inference or default3

if they're not going to appear in this court.4

THE COURT: Nothing has to be to argued. He's just5

saying that that's what he's going to do.6

MR. ANDERSON: Thank you, Your Honor.7

THE COURT: Anything else? If you're asking for8

rulings today, counsel, anything you want, put it in writing9and I'll rule on it, and those are things that should be10

addressed before court because they may not be timely. So11

there -- and I appreciate you letting everybody know, myself12

and counsel know, that this may be something you'll be raising.13

MR. MALOFIY: It is an issue also because in14

preparation for the case --15

THE COURT: Okay.16

MR. MALOFIY: -- and to be conscience of the Court's17

calendar, the witnesses -- calendaring of the witnesses as18

well, if we're going to be using designations, we need to know19

if they're going to appear. And if they're not going to20

appear, we're going to spend quite a bit of time chopping up21

the videos for time of trial, and that's a concern that we22

have. I wanted to raise it with the Court because it deals23

with calendaring and it deals with scheduling. That's just24

something I wanted to make the Court aware of.25


22

THE COURT: I appreciate that, and go ahead and put1

it in writing. I appreciate that, I'm just not going to be2

ruling on anything today on it.3

MR. MALOFIY: All right. Understood. Thank you,4

Your Honor.5

THE COURT: Any time any issue comes up, I want to6

make sure that it's in writing in front of the Court and that7

the other side has an opportunity to respond to it, and then8

I'll make the writing. A lot of people -- or the ruling. A9

lot of people like to bring up things and have them done right10

here in court, and that's not fair to either side. So I always11

want it in writing, and we'll address it.12

MR. MALOFIY: Thank you, Your Honor.13

THE COURT: But thank you for notifying us. It's14

always better to let us know what your plans are.15

MR. MALOFIY: Another issue is there was a witness,16

a Mike Ware, who was actually at the concert in the UK and was17

at the front row and has a clear and distinct memory of seeing18

Robert Plant in the front row watching the Spirit show. Now,19

he has Parkinson's and he doesn't have a passport, but he said20

-- and we just found out about him, I believe in the last week,21

and we disclosed it immediately to the other side.22

He asked -- he said he would like to testify, but he would23

be -- if it was possible, to do it telephonically or a video24

conference or even schedule a deposition, fly out there and a25


23

take a brief deposition of him to be used in this case before1

trial.2

THE COURT: Okay. Well, see what you can work ou3

with counsel. If not, make the motion, I'll be happy to rule4

on it.5


Next issue, I believe you had said that each side gets ten7

hours, and I wasn't sure if that was in our case-in-chief or --8

in our case-in-chief and also for cross-examination.9THE COURT: Any time any testimony is being given10


THE COURT: It does not include opening statement 12

closing argument.13

MR. MALOFIY: Understood. Is there any time14

limitation on the opening statement or closing argument?15

THE COURT: Oh, yeah, there will be, but I'll talk16

to you about it. What is it normally? I can tell you right17

now. It's normally about a half hour, 45 minutes for opening18

statement, but I'll tell you on the day of trial for sure.19

MR. MALOFIY: All right. One --20

THE COURT: Many times opening statement can be21

done -- you know, it depends on how -- how complicated the ca22

is, and one of the things everyone knows is you can make a cas23

as complicated as you want or as streamline as you want. But24

we'll decide -- I would say probably half hour, in that area.25


24

Okay?1

MR. MALOFIY: One other issue as it relates to the2

trial technology, my understanding is -- and from viewing the3

room, it has monitors and other technology here. As far as the4

audio exhibits we intend to play at time of trial, it uses a5

special program, Pro Tools program, which we would require tw6

laptops. It's my understanding that your rules only allow one7

laptop for a trial tech, and my request of this Court is would8

this Court allow, because this is a case that is very much9

focused on the audio and things relating to the case, if we10

could have an additional laptop with a trial audio tech to run11

that.12

THE COURT: Yeah, I may very well consider that, b13

put it in writing what you want. If you want an exception to14

the rules, just let me know.15

MR. MALOFIY: Last two things is would we be16

permitted to bring high fidelity speakers into the courtroom?17

THE COURT: Probably not.18

MR. MALOFIY: Okay. As far as --19

THE COURT: Let me make sure, just the value of th20

idea that -- and some cases come in and they say, Well we wan21

the courtroom for five days. Other things we may be doing to22

the courtroom, that's why -- that's why when boxes of exhibits23

are brought in, sometimes the attorneys are upset that they24

have to take all those boxes home at night. They say, Well,25




44/44

25

can't we just store them in the courtroom? This is a courtroom1

that has a lot of cases, obviously, not just one. So I just2

want to disavow anybody of the idea that we own the courtroom3

for three or four days or five days, whatever it is.4

Go ahead -- and as far as the technical equipment, if it's5

needed, we allow it in. Talk to the technicians about it, see6

if they can resolve it for you. If they can't, make a motion7

to me, and if it's something that's necessary, yeah, we'll let8

it in.9MR. MALOFIY: Last thing, as far as courtroom10

technology, do you prefer the projection screen -- I believe11

one's built into this room -- or do you prefer using the12

monitors?13

THE COURT: Monitors. We do have a projection14

screen, but they've had so much problems with it.15

MR. MALOFIY: Understand.16

THE COURT: We have monitors on both sides as you17

can see.18

MR. MALOFIY: As far as setting up, is that19

something to discuss with you now?20

THE COURT: No, that's with the technicians.21

MR. MALOFIY: Okay. Very well, Your Honor.22

I'm not sure -- I believe that's all the questions I have.23

I don't know if my co-counsel has additional ones. May I speak24

to my co-counsel?25


26

THE COURT: There's no such thing as an attorney1

that doesn't have a question, counsel. Go ahead.2

MR. MALOFIY: Also, in Limine Motion Number 11,3

could you repeat your ruling, Your Honor? And I apologize.4

THE COURT: Sure, no problem. Let me get it.5

Number 11?6

MR. MALOFIY: Yes, Your Honor.7

THE COURT: That's the one that I coupled with 10.8

Probably would allow -- would not exclude and would deny that9

motion because I think Knight probably is someone that you knew10

or should have known would be a witness, so I'll probably be11

denying that, but I want to go over it. It kind of relates12

to -- because I believe that that's folded into Number 10 also.13

MR. MALOFIY: Understood.14

THE COURT: And some of those witnesses in 10, I'm15

going to be granting the motion; some I may be denying the16

motion. It probably will be denied as to Knight.17

MR. MALOFIY: Okay.18

THE COURT: AKA Wolfe.19

MR. MALOFIY: Right, Knight.20

THE COURT Ok21

27

MR. ANDERSON: Thank you, Your Honor.1

MR. MALOFIY: Thank you, Your Honor2

THE COURTROOM DEPUTY: All rise. Court is in3

recess.4

(The proceedings concluded at 9:38 a.m.)5

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CERTIFICATE OF OFFICIAL REPORTER

COUNTY OF LOS ANGELES )

)STATE OF CALIFORNIA )

I, SHAYNA MONTGOMERY, Federal Official Realtime

Court Reporter, in and for the United States District Court fo

the Central District of California, do hereby certify that

pursuant to Section 753, Title 28, United States Code that the

foregoing is a true and correct transcript of the

stenographically reported proceedings held in the

above-entitled matter and that the transcript page format is i

conformance with the regulations of the judicial conference of

the United States.

Date: April 28, 2016

/s/ SHAYNA MONTGOMERY

SHAYNA MONTGOMERY, CSR, RPR, CRR

Federal Official Court Reporter


Frances Malofiy Declaration (Skidmore v. Led Zeppelin "Stairway to Heaven" lawsuit)

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Transcript of Frances Malofiy Declaration (Skidmore v. Led Zeppelin "Stairway to Heaven" lawsuit)