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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
ORDER FOR PRESERVATION OF RECORDS
This cause having come to be heard on the Plaintiffs’ Motion for Entry
of an Order For Preservation of Records;
It is hereby ORDERED and ADJUDGED that:
1. Preservation. During the pendency of this litigation, and for 2 years
after entry of a final order closing out this case, each of the parties herein and their
respective officers, agents, servants, employees, and attorneys, and all persons in
active concert or participation with them who receive actual notice of this order by
personal service or otherwise, are restrained and enjoined from altering, interlining,
destroying, permitting the destruction of, or in any other fashion changing any
“document” in the actual or constructive care, custody, or control of such person,
wherever such document is physically located, or irrevocably changing the form or
sequence of the files in which the document is located. Such persons are also
enjoined from changing the location of any such documents except to facilitate
compilation, review or production.
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2. Scope.
(a) “Document” shall mean any writing, drawing, film, videotape,
chart, photograph, phonograph record, tape record, mechanical or electronic sound
recording or transcript thereof, retrievable data (whether carded, taped coded,
electrostatically or electromagnetically recorded, or otherwise), or other data
compilation from which information can be obtained, including (but not limited to)
notices, memoranda, diaries, minutes, purchase records, purchase invoices, market
data, correspondence, computer storage tapes, computer storage cards or disks,
books, journals, ledgers, statements, reports, invoices, bills, vouchers, worksheets,
jottings, notes, letters, abstracts, audits, charts, checks, diagrams, drafts,
recordings, instructions, lists, logs, orders, recitals, telegram messages, telephone
bills and logs, résumés, summaries, compilations, computations, and other formal
and informal writings or tangible preservations of information.
(b) This order pertains only to documents containing information
that may be relevant to, or may lead to the discovery of information relevant to:
i. any and all documents pertaining to Britney Spears,
Britney Touring, Inc., or any related entities of the “Britney Spears” brand
pertaining to or reflecting income generated by any negotiations, transactions,
sales, written and oral agreements (consummated, proposed, or in negotiation, i.e.,
amendments, revisions, modifications or riders thereto), statements regarding sub-
licensing, merchandising, and performing whether offered or solicited as they
relate to the accounting of Gross Receipts earned by Britney Spears, Britney
Touring, Inc. or any related entity owned or operated by Britney Spears between
January 1, 1999 through February 20, 2008.
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Any document described or referred to in any discovery request or response made
during this litigation shall, for the time of the request or response, be treated for
purposes of this order as containing such information unless and until the court
rules such information to be irrelevant.
(c) Counsel are directed to confer to resolve questions as to what
documents are outside the scope of this order or otherwise need not be preserved
and as to an earlier date for permissible destruction of particular categories of
documents. If counsel are unable to agree, any party may apply to the court for
clarification or relief from this order upon reasonable notice. A party failing,
within 60 days after receiving written notice from another party that specified
documents will be destroyed, lost or otherwise altered pursuant to routine policies
and programs, to indicate in writing its objection shall be deemed to have agreed to
such destruction.
3. Implementation. Each party will, within 10 days after receiving this
order, designate an individual who shall be responsible for ensuring that the party
carries out the requirements of this order.
Dated in Chambers, this 6 day of March, 2008.
th
/s/Honorable Judge Renee A. Roche
Circuit Court Judge
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished,
by electronic mail or U.S. mail, this 6 day of March, 2008, to: Clay Townsend, Esq., 20 N.
th
Orange Avenue, Suite 1600, Orlando, FL 32801; Britney Spears, 12094 Summit Circle, Beverly
Hills, CA 90210; James P. Spears, c/o Jeryll S. Cohen, Esq., 601 S. Figueroa Street, Suite 3900
Los Angeles, CA 90017; Andrew Wallet, Esq., 2215 Colby Avenue, Los Angeles, CA 90064;
Samuel D. Ingham, III, Esq., 9440 Santa Monica Blvd., Suite 510, Beverly Hills, CA 90210;
Britney Touring, Inc., c/o Corporation Service Company, 1201 Hays Street, Tallahassee, FL
32301-2525.
/s/Sheri Presutti
Judicial Assistant
