IN
THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN
AND FOR ORANGE COUNTY, FLORIDA
WRIGHT ENTERTAINMENT GROUP, LLC
and WRIGHT
ENTERTAINMENT
GROUP,
INC.,
Plaintiff(s),
vs.
BRITNEY SPEARS and BRITNEY
TOURING, INC.,
____
___:D=-e=-=fi:.::.en==-d=a=-=n=--=t""(
s:,.:)''--------
I
CASE NO.:
PLAINTIFFS' FIRST SET OF INTERROGATORIES
TO
DEFENDANTS
PLAINTIFFS, WRIGHT ENTERTAINMENT GROUP, LLC,
and
WRIGHT
ENTERTAINMENT GROUP, INC., (hereinafter collectively referred to as "WEG")
by
and through their undersigned attorneys and pursuant to Rule 1.340, Florida Rules
of
Civil
Procedure, request that Defendants, BRITNEY SPEARS
and
BRITNEY TOURING,
INC.,
answer the following interrogatories numbered 1 through 14, in writing and under
oath within forty-five ( 45) days
of
service hereof.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true
and
correct copy
of
the foregoing has been furnished,
by personal service
of
process, this
___
day
of
October, 2007,
to
Britney Spears, 3200
Retreat Court, Malibu, California 90265-3448; Britney Spears, 10960 Wilshire Blvd.,
Suit.e
2150,
Los
Angeles, CA 90024-3726; Bri e ears, 1010 anta Monica Boulevard, Suite
1300,
Los
Angeles,
CA
90067-4114; B · n urin
Inc.
/o
Corporat' 1
er
ice Company
(Registered Agent), 1201 Hays Street, T 1 a
ee,
F 3 1-2525.
WEG v. SPEARS,
BT!
CLAY
M.
OWNS
, ESQ.
Florida B
No.:
363375
KEITH MITNIK, ESQ.
Florida Bar
No.:
436127
GREGORIO FRANCIS, ESQ.
Florida Bar
No.:
8478
MORGAN & MORGAN, P.A.
20
N.
Orange Avenue, Ste. 1600
Orlando, FL 32801
PH:
(407) 420-1414
Fax:
(407) 425-8171
Attorneys for Plaintiffs
Page I
of
18 Tis' 1 ~
1 Set
of
Interrogatories to
6s
INSTRUCTIONS AND DEFINITIONS
A.
All information
is
to
be divulged which
is
in the possession
of
the
individual or corporate party, their attorneys, investigators, agents, employees or other
representatives
of
the named party.
B.
When an individual interrogatory calls for
an
answer which involves
more than one part, each part
of
the answer should be clearly set out so that it
is
understandable.
C.
When the terms "you" "your " "Defendant " or "Defendants" are used
' ' ' '
they are meant
to
include Britney Spears; Britney Touring, Inc., Britney Brands, Inc.;
Britney Films, Ltd.; Britney Television, LLC; The Britney Spears Foundation;
Britney On-Line, Inc.; Britney Management Corporation; One More Time Music,
Inc.;
and
SJB Revocable Trust
and
any other controlled entity, and their agents,
employees, attorneys, accountants, investigators or anyone else acting on their behalf.
Separate answers should be given for each person or entity named.
D.
When the term "document"
is
used, it
is
meant
to
include every
"writing" (including electronic correspondence and emails), "recording" and
"photograph"
as
those terms are defined in Rule 1001, Fed.R.Evid. In addition, the tetm
"document" also means every copy
of
a document where such copy is not
an
identical
duplicate
of
the original.
E.
Where the terms "claim" or "claims" are used, they are meant
to
mean
or to include a demand, cause
of
action or assertion for something due or believed
to
be
due.
WEG
v.
SPEARS,
BT!
Page 2
of18
Tis'
pt
Set
of
Interrogatories to
Lis
F.
Where the terms "defense" or "defenses" are used, they are meant to
mean or to include any justification, excuse, denial or affirmative defense in response to
the opposing party's claims.
G.
Where the term "negotiation(s)"
is
used, it is meant to mean or to
include conversations, discussions, meetings, conferences and other written or verbal
exchanges which relate to the contract.
WEG
v.
SPEARS, BT!
Page
3
ofl8
Tis'
1
st
Set
of
Interrogatories
to
Lis
INTERROGATORIES
1.
State your full name, and state any and all other names which you have ever used
or by which you have ever been known by.
ANSWER:
WEG
v.
SPEARS,
BT!
Page 4
of
18
ITs'
1st Set
of
Interrogatories to
/is
2.
If
you are a business entity:
a.
State the name or names you used, or went by, during your
involvement in the events that are the subject
of
the pleadings;
b. State any other names or "d/b/a's" under which you have ever
transacted business;
ANSWER:
c.
Are you a corporation?
___
If
so, state:
(
1)
The name stated in the current Articles
of
Incorporation;
(2) All the other names used by the corporation during the past
10
years and the dates each was used;
(3) The date and place
of
the incorporation;
(4) The address
of
the principal place
of
business; and
(5) The name
of
the person with the most knowledge
of
the
management
of
such entity.
d.
Are you a partnership?
___
If
so, state:
e.
(
1)
The current partnership name;
(2) All
of
the names used by the partnership during the past
10
years
and the dates each was used;
(3) Whether you are a limited partnership and,
if
so, under the laws
of
what jurisdiction;-
( 4) The name and address
of
each general partner;
(5) The address
of
the principal place
of
business; and
(6) The name
of
the person with the most knowledge
of
the
management
of
such entity.
Are you a joint venture?
___
If
so, state:
(1) The current joint venture name;
(2) All the names used by the joint venture during the past
10
years
and the dates each was used;
(3) The name and address
of
each joint venturer;
(4) The address
of
the principal place
of
business; and
(5) The name
of
the person with the most knowledge
of
the
management
of
such entity.
WEG
v.
SPEARS, BT! Page 5
of!S
ITs'
1 H Set
of
Interrogatories
to
6s
3.
Have you done business under a fictitious name during the past
10
years?
IfYES, for each fictitious name, state:
a.
The name;
b.
The date each was used;
c.
The state and county
of
each fictitious name and filing; and
d.
The address
of
the principal place
of
business.
ANSWER:
WEG
v.
SPEARS, BT! Page 6
ofl8
Ils'
1s
t Set oflnterrogatories to
As
4.
Have you utilized a business manager from January 1999 to the present?
If
YES, state:
a.
The name;
b.
The date each was used; and
c.
The address
of
the principal place
of
business.
ANSWER:
WEG
v.
SPEARS, BT! Page 7
of
18
ITs'
1st
Set
of
Interrogatories
to
/}.s
5.
Have you utilized a cetiified public accountant from January 1999 to the present?
IfYES, state:
a.
The name;
b. The date each was used; and
c.
The address
of
the principal place
of
business.
ANSWER:
WEG
v.
SPEARS,
BT!
Page
8
of
18
Ils'
1
~t
Set
of
Interrogatories
to
Lis
6.
State whether you have been a party
to
a civil lawsuit, other than personal injury or
premises liability.
If
so, please provide the following info1mation:
ANSWER:
a.
Were you the plaintiff or the defendant?
b.
What was the nature
of
the Plaintiff's claim?
c.
The date and location, along with the case number and title
of
the
court in which the action was commenced.
d.
The names
of
all the parties other than yourself involved in the
action.
WEG
v.
SPEARS,
BT!
Page 9
of
18
ITs'
1"
Set
of
Interrogatories to
D.s
7.
State the name, address and telephone number
of
all employees and/or agents
involved in the negotiations and/or execution
of
the Agreement referenced in the
Complaint.
ANSWER:
WEG
v.
SPEARS,
BTI Page
10
of
18
CTs'
1
st
Set
of
Interrogatodes to
.6.s
8.
State the name, address and telephone number
of
all persons whom you believe
may have knowledge or relevant information concerning each claim or defense.
If
you
have disclosed multiple claims or multiple defenses, state the claim(s) or defense(s) you
believe the person has information or knowledge about.
ANSWER:
WEG
v.
SPEARS, BT! Page
11
of
18
ITs'
1
st
Set
of
Interrogatories
to
6.s
9.
Identify and list any document you believe may be relevant to each separate claim
or defense.
If
you disclosed multiple claims or multiple defenses, state which claim(s) or
defense(s) you believe the document may be relevant to.
As
to
each
of
the documents
identified, please provide the following:
ANSWER:
a.
The location
of
the documents.
b.
The name, address, and telephone number
of
the individual who has
custody or control over the document.
WEG
v.
SPEARS,
BT!
Page
12of18
TTs'
1s
t Set
of
Interrogatories
to
Lis
10.
List the dates
of
all conversations and meetings between any Defendants and any
other person or entity wherein the discussions involved licensing, development,
manufacturing, and distribution
of
items containing the "Britney Spears" brand between
January 1999 and the present. For each conversation, list all individuals present, their
addresses and phone numbers, and a brief statement regarding what was stated at the
conversation and/or meeting. Specifically, list what conversations were held with each
Plaintiff regarding the above.
ANSWER:
WEG
v.
SPEARS,
BT!
Page
13
of
18
Ils'
1s
t Set
of
Interrogatories
to
!is
11.
List the dates
of
all conversations and meetings between any Defendants and any
other person or entity wherein the discussions involved appearances
by
Britney Spears in
musical performances or musical recordings, or tours. For each conversation, list all
individuals present, their addresses and phone numbers, and a brief statement regarding
what was stated at the conversation and/or meeting. Specifically, list what conversations
were held with each Plaintiff regarding the above.
ANSWER:
WEG
v.
SPEARS,
BT!
Page
14
of
18
ITs'
1
st
Set
of
Interrogatoi-ies
to /is
12. List the dates
of
all conversations and meetings between any Defendants and any
other person or entity wherein the discussions involved the te1mination
of
the "Personal
Management Agreement with WRIGHT ENTERTAINMENT GROUP, INC. or
WRIGHT ENTERTAINMENT GROUP, LLC". For each conversation, list all
individuals present, their addresses and phone numbers, and a brief statement regarding
what was stated at the conversation and/or meeting. Specifically, list what conversations
were held with each Plaintiff regarding the above.
ANSWER:
WEG
v.
SPEARS,
BT!
Page
15
of
18
11s'
1 ~
1 Set
of
Interrogatories to
6.s
13.
Are you aware
of
or do you suspect that any other paiiies may have liability for
any claim contained in Plaintiffs' Complaint?
_.
If
your answer
is
anything other than
an unqualified No, please state the following:
ANSWER:
a.
The name, address, telephone number
of
any other parties whom
Defendants believe may have liability for any claim contained in
Plaintiffs complaint; and
b.
Why you believe they are liable for Plaintiffs' claims.
WEG
v.
SPEARS, BT!
Page
16of18
Tis'
1st Set oflnterrogatories to
.6.s
14.
Please list and describe any additional business endeavors, contracts and/or
agreements related to or involving the "Britney Spears" brand, entered into by
Defendants from January 1999 through the present. Provide the following information:
ANSWER:
a.
The name, address, telephone numbers
of
all parties involved in the
business relationship;
b.
The reason for the business relationship; and
c.
Copies
of
any such documents, including contracts or agreements,
that would reflect the nature
of
the relationship between Defendants
and other involved parties.
WEG
v.
SPEARS,
BT!
Page
17of18
ITs'
1st Set
of
Interrogatories to
6.s
STATEOFFLORJDA )
COUNTY OF ORANGE )
SIGNATURE PAGE
BRITNEY SPEARS
By:
Its:
The foregoing instrument was acknowledged before me this
___
day
of
_____
, 2007, by
_______
, who, after being first duly sworn, deposes and
says she/he/it
ts
the
_____________
of
____________
is fully authorized by said corporation, and the foregoing
Answers to Interrogatories are true and correct.
NOTARY PUBLIC -State
of
FL
Print Name:
___________
_
Serial Number:
__________
_
MY COMMISSION EXPIRES:
____
_
__
Personally Known; or
__
Produced Identification
WEG
v.
SPEARS,
BT!
Page
18
ofl8
Tis' 1
st
Set oflntetrogatories
to
Lis
STATE OF FLORIDA )
COUNTY OF ORANGE )
SIGNATURE PAGE
BRITNEY TOURING, INC.
By:
Its:
The foregoing instrument was acknowledged before me this
___
day
of
_____
, 2007, by
______
_,
who, after being first duly sworn, deposes and
she/he/it
1s
the
_____________
of
says
____________
.is
fully authorized by said corporation, and the foregoing
Answers to Interrogatories are true and correct.
NOTARY
PUBLIC-
State
of
FL
Print Name:
------------
Serial Number:
-----------
MY COMMISSION EXPIRES:
__
Personally Known; or
Produced Identification
--
WEG v. SPEARS,
BT!
Page
18
of
18
Tis'
1s
t Set
of
Interrogatories to
.6.s