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Case No.: 48-2007-CA-014233-O Page 1 of 3 ∏s’ Mtn Entry Order Preservation of Recs

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,

IN AND FOR ORANGE COUNTY, FLORIDA

WRIGHT ENTERTAINMENT

GROUP, LLC and WRIGHT

ENTERTAINMENT GROUP, INC.,

Plaintiffs,

vs.

BRITNEY SPEARS and BRITNEY

TOURING, INC.,

Defendants. /

CASE NO: 48-2007-CA-014233-O

DIVISION: 32

PLAINTIFFS’ MOTION FOR ENTRY OF AN

ORDER FOR PRESERVATION OF RECORDS

COME NOW the Plaintiffs, WRIGHT ENTERTAINMENT GROUP, LLC

and WRIGHT ENTERTAINMENT GROUP, INC., by and through their

undersigned counsel, and file this Motion for Entry of an Order for Preservation of

Records and states:

1. The Plaintiffs filed a Notice Regarding Non-Destruction of Electronic

Data or Computer Files with this Court on October 27, 2007.

2. This notice was served on the Defendant, BRITNEY SPEARS,

personally on November 1, 2007 and on the Registered Agent for the Defendant,

BRITNEY TOURING, INC., personally on November 9, 2007.

3. On February 14, 2008, this Court issued an Order compelling

Defendants to respond to Plaintiffs’ discovery requests previously served upon the

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Case No.: 48-2007-CA-014233-O Page 2 of 3 ∏s’ Mtn Entry Order Preservation of Recs

Defendant, BRITNEY SPEARS, on November 1, 2007 and Defendant, BRITNEY

TOURING, INC., on November 9, 2007, in aid of execution.

4. On February 14, 2008, Plaintiffs filed Notices of Production from

Non-Parties to conduct discovery in aid of execution.

5. In order to preserve the integrity of documents to be produced from

the Defendants and non-parties pursuant to the Order issued by this Court

compelling discovery in aid of execution on February 14, 2008, the Plaintiffs

request the entry of an order for the preservation of documents prior to the

commencement of discovery.

WHEREFORE, Plaintiffs’ counsel requests that this Honorable Court issue

an order for the preservation of records to be produced pursuant to the Order

compelling discovery in aid of execution.

Respectfully submitted this 5th day of March, 2008.

/s/ Clay M. Townsend

CLAY M. TOWNSEND, ESQ.

FBN: 363375

Morgan & Morgan, P.A.

20 N. Orange Ave., 16th Floor

P.O. Box 4979

Orlando, FL 32802-4979

Telephone: (407) 420-1414

Facsimile: (407) 425-8171

Attorneys for Plaintifs

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Case No.: 48-2007-CA-014233-O Page 3 of 3 ∏s’ Mtn Entry Order Preservation of Recs

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished,

by facsimile and U.S. Mail – postage paid, this 5th day of March, 2008, to: James P. Spears, c/o

Jeryll S. Cohen, Esq., Luce, Forward, Hamilton & Scripps, LLP, 601 S. Figueroa Street, Suite

3900, Los Angeles, CA 90017; Andrew Wallet, Esq., Hinojosa & Wallet, 2215 Colby Avenue,

Los Angeles, CA 90064; Samuel D. Ingham, III, Esq., 9440 Santa Monica Blvd., Suite 510,

Beverly Hills, CA 90210; and Britney Touring, Inc., c/o Corporation Service Company, 1201

Hays Street, Tallahassee, FL 32301-2525.

_/s/ Clay M. Townsend

CLAY M. TOWNSEND, ESQ.

FBN: 363375

Morgan & Morgan, P.A.

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