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.
CASE NO.: 48-2007-CA-014233-O
BRITNEY SPEARS and BRITNEY
TOURING, INC.,
____
____;;cD;;...ecc:fjc..cen"'d'-'-a"'n""t("'s)"".
_______
I
NOTICE OF
PRODUCTION
FROM NON-PARTIES
to: Zomba Recording Corporation
c/o Kim L. Rappaport, Esq.
SONY
BMG
MUSIC ENTERTAINMENT
550 Madison Avenue
New York,
NY
10022
YOU
ARE
NOTIFIED that after 10 days from the date
of
service
of
this notice,
if
service is
by
delivery, or
15
days
from
the
date
of
service,
if
service is by mail, and
if
no objection is received from any party, the undersigned will issue
or
apply to the Clerk
of
this Court for issuance
of
the attached Subpoena(s) directed to the foUowing non-
parties, whose names and addresses are listed below, to produce the items listed at the
time and place specified
in
the attached Subpoena( s ):
1.
Zomba Recording Corporation
c/o
Kim
L. Rappaport, Esq.
Law Department
SONY BMG MUSIC ENTERTAINMENT
550 Madison Avenue
New York,
NY
10022
Case
No.:
48-2007-CA-014233-O
Page
1 of2 ris• Notice
of
P:roduction from Non-Patties
2. Signatures Network, Inc.
c/o Michael Gunzburger, Esq.
Associate Counsel and Manager, Business Affairs
Two Bryant Street, Suite 300
San Francisco, CA 94105
CERTIFICATE
OF
SERVICE
I HEREBY CERTIFY that a
_true
and correct copy
of
the foregoing Notice
of
Production
of
Production from Non-Parties
i~
Subpoena Duces Tecum Without Deposition
has
been furnished,
by
U.S. mail, this day
of
February, 2008, to Britney Spears,
12095
Summit Circle, Beverly Hills, CA 90210; Britney Touring, Inc., c/o Corporation
Service Company (Registered Agent), 1
01
s Street, Tallahassee, FL 32301-2525.
Case
No.:
48-2007-CA-014233-O
SEND,ESQ.
o.:
363375
IK,ESQ.
Florida Bar
o.:
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
2 of2
ITs'
Notice of Production
ftom
Non-Parties
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.
CASE NO.: 48-2007-CA-014233-O
BRITNEY SPEARS and BRITNEY
TOURING, INC.,
------=D.c..efic.ce=nd=a=n=t(=s)=·------
I
SUBPOENA
DUCES
TECUM
WITHOUT
DEPOSITION
THE STATE OF FLORIDA:
TO: Zomba Recording Corporation
c/o Kim L. Rappaport, Esq.
SONY
BMG
MUSIC ENTERTAINMENT
550
Madison Avenue
New York,
NY
10022
YOU ARE COMMANDED
to
produce for inspection and/or mail to the
attorney whose name appears below, within thirty (30) days
of
receipt hereo~ the
following:
DOCUMENTS
TO
BE
PRODUCED
1.
Copies
of
any and all documents pertaining to Britney Spears, Britney
Touring, Inc., or any related entities
of
the ''Britney Spears" brand pertaining to or
Case
No.:
48-2007-CA-014233-O
Page
1 of4
[1s'
Subpoena
Duces
Tecum
w/o
Deposition
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 Receipts1 earned by Britney Spears, Britney Touring, Inc. or
any related entity owned or operated by Britney Spears between January
1,
1999
through February 20, 2003.
2.
Copies
of
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.
1
The
term
"Gross
Receipts"
as
used
he:rein
shall
mean
any
and
all
compensation,
in
whatever
form,
which
is
paid,
payable,
earned or accrued ( and including
any
deferred portion which
may
not actually be received
until
after
the
termination
of
the
Term hereof) ill
whole
or
in part, to Artist, Artist's
family,
heirs, executors, administrators,
assigns,
or applied
for
Artist's benefit, directly or indirectly (for example,
to
any corporation, partnership
or
any
oilier entity in which Artist or any
of
the
foregoing
persons have
an
interest), during
the
Term hereof,
as
a result
of
Artist's activities in the entertainment and related
industries,
including, without limitation, motion pictures,
television,
radio, recordings, theater, advertising, promotion,
music
pnblishing, song writing, book publishing,
video
games,
multimedia,
CD-Rom and all other
new
technologies
now
known or hereinafter devised.
Case
No.:
48-2007-CA-014233-O
Page2of4
Ils'
Subpoena
Duces
Tecum
w/o
Deposition
3.
Royalty statements or any other documents reflecting revenue earned
by, and/or paid to Britney Spears pursuant to the recording agreements between
Jive/Zomba
and
Britney Spears between January
1,
1999 through February 20,
2008.
These items will
be
inspected and may
be
copied at that time. You will not
be
required to surrender original items.
You may comply with this subpoena by providing access
to
the
documents for inspection and/or legible copies
of
the items to
be
produced
to
the attorney whose name appears on this subpoena on or before the scheduled
date of production. You may condition the preparation
of
the copies upon the
payment in advance
of
the reasonable cost
of
preparation.
You
may
mail or deliver
the copies to the attorney whose name appears on this subpoena and thereby
eliminate your appearance at the time and place specified above.
You have the right to object to the production pursuant
to
this subpoena at
any time before production
by
giving written notice to the attorney whose name
appears on this subpoena. Any privileges you wish to assert must
be
supported by
a privilege log.
THIS WILL NOT
BE
A DEPOSITION. NO TESTIMONY WILL
BE
TAKEN.
Case No.: 48-2007-CA-014233-0 Page 3
of
4
fls'
Subpoena
Duces
Tecum w / o Deposition
If
you fail to appear at the time and place specified; furnish the records
instead
of
appearing as provided above; or objection to this subpoena, you may
be
in contempt
of
court.
You are subpoenaed to appear
by
the following attorneys, and unless
excused from this subpoena
by
these attorneys or the court, you shall respond to
this subpoena as directed.
Dated
on
tJ:iis
_ day
of
February, 2008.
For the Court
CLAY
M.
TOWNSEND,
ESQ.
Florida Bar 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
In
accordance with the Americans With Disabilities Act, persons with disabilities needing a
special accommodation to participate
in
this proceeding should contact the offices
of
Morgan, &
Morgan, P.A., 20 North Orange Avenue, Suite 1600, Orlando, Florida 32801, telephone 407-
420-1414, not later than seven (7) days prior to the proceedings.
If
hearing impaired, (TDD)
1-
800-955-8771,
or
Voice (V) 1-800-955-8770, via Florida Relay Service.
Case No.: 48-2007-CA-014233-O
Page
4
of
4 Ils'
Subpoena
Du.ces
Tecum
w / o Deposition
IN
THE
CIRCUIT COURT
OF
THE NINTH JUDICIAL CIRCUIT
IN AND
FOR
ORANGE COUNTY, FLORIDA
WRIGHT ENTERTAINMENT GROUP, LLC
and WRIGHT ENTERTAINMENT GROUP,
INC.,
Plalntiff(s),
vs. CASE NO.: 48-2007-CA-014233-O
BRITNEY SPEARS
and
BRITNEY
TOURING, INC.,
----~D_e_fe_n_d_a_n~t(~s>~•-------
I
NOTICE
OF
PRODUCTION FROM NON-PARTIES
TO: Signatures Network, Inc.
c/o Michael Gunzburger, Esq.
Associate Counsel and Manager, Business Affairs
Two Bryant Street, Suite 300
San Francisco,
CA
94105
YOU ARE NOTIFIED that after
10
days from the date
of
service
of
this notice,
if
service is
by
delivery,
or
15
days
from
the
date of service,
if
service
is
by
mail,
and
if
no objection is received from any party, the undersigned will issue
or
apply to the Clerk
of
this Court for issuance
of
the attached Subpoena( s) directed to the following non-
parties, whose names and addresses are listed below, to produce the items listed at the
time and place specified in the attached Subpoena(s):
1.
Zomba Recording Corporation
c/o Kim L. Rappaport, Esq.
Law Department
SONY BMG MUSIC ENTERTAINMENT
550 Madison Avenue
New York,
NY
10022
Case
No.:
48-2007-CA-014233-0 Page I
of2
IIs>
Notice
of
Production
from
Non-Parties
/
2. Signatures Network, Inc.
c/o Michael Gunzburger, Esq.
Associate Counsel and Manager, Business Affairs
Two
Bryant
Street, Suite 300
San
Francisco,
CA
94105
CERTIFICATE
OF
SERVICE
I
HEREBY
CERTIFY that a true and correct copy
of
the foregoing Notice
of
Production
of
Production from
Non-Parti7
~d
Subpoena Duces
Tecum
Without Deposition
has been furnished,
by
U.S. mail, this day
of
February, 2008, to Britney Spears,
12095 Summit Circle, Beverly Hills, CA 90210; Britney Touring, Inc., c/o Corporation
Service Company (Registered Agent) 20 Hays Street, Tallahassee,
FL
32301-2525 .
Case
No.:
48-2007-CA-014233-O
. TOWNSEND, ESQ.
arNo.: 363375
IT TNIK,ESQ.
Flo · a 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
2
of2
fis' Notice
of
Production
fi:om
Non-Parties
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.
CASE NO.: 48-2007-CA-014233-O
BRITNEY SPEARS
and
BRITNEY
TOURING, INC.,
-------'-'-D""efjc....e_n-'--dac....n_t""'(s~).
______
I
SUBPOENA
DUCES
TECUM
WITHOUT
DEPOSITION
THE STATE OF FLORIDA:
TO: Signatures Network,
Inc.
c/o Michael Gunzburger, Esq.
Associate Counsel & Manager, Business Affairs
Two Bryant Street, Suite 300
San Francisco, CA 94105
YOU ARE COMMANDED to provide for inspection and/or mail to the
attorney whose name appears below, within thirty (30) days
of
receipt hereof, the
following:
DOCUMENTS
TO
BE
PRODUCED
1.
Copies
of
any and all documents pertaining to Britney Spears, Britney
Touring, Inc., or any related entities
of
the "Britney Spears" brand pertaining to or
Case No.: 48-2007-CA-014233-0 Page I
of4
Tis' Subpoena Duces Tecum
w/o
Deposition
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 Receipts1 earned by Britney Spears, Britney Touring, Inc. or
any related entity owned or operated by Britney Spears between January
l,
1999
through February 20, 2003.
2.
Copies
of
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.
1
The
term
icGross
Receiptsn
as
used
herein
shall
mean
any
and
all
compensation,
in
whatever
form,
which
is
paid,
payable,
earned
or
accrued (and including
any
deferred
portion
which
may
not actually
be
received
until
after
the
termination
of
the
Term
hereof)
in
whole
or
in
part,
to
Artis~
Artist's
family,
heirs,
executors,
administrators,
assigns,
or
applied
for
Artist's benefit, directly
or
indirectly
(for
example,
to
any
corporation, partnership
or
any
other
entity
in
which
Artist or
any
of
the
foregoing
persons
have
an
interest),
during
the Term hereof,
as
a
result
of
Artist's
activities·
in
the
entertainment
and
related
industries,
including,
with.out
limitation,
motion
pictures,
television,
radio, recordings, theater, advertising,
promotion,
music
publishing,
song
writing, book
publishing,
video
games,
multimedia,
CD-Rom
and
all other new
technologies
now
known
or
hereinafter devised.
Case
No.:
48-2007-CA-014233-O
Page
2 of 4
Tis'
Subpoena
Duces
Tecum
w/o
Deposition
These items will be inspected and may be copied at that time. You will not
be required to surrender original items.
You may comply with this subpoena by providing access to the
documents for inspection and/or legible copies
of
the items to
be
produced
to
the attorney whose name appears on this subpoena on or before the scheduled
date
of
production. You may condition the preparation
of
the copies upon the
payment in advance
of
the reasonable cost
of
preparation. You may mail or deliver
the copies to the attorney whose name appears on this subpoena and thereby
eliminate your appearance at the time and place specified above.
You have the right to object to the production pursuant to this subpoena at
any time before production by giving written notice to the attorney whose name
appears on this subpoena. Any privileges you wish to assert
must
be supported by
a privilege log.
THIS WILL
NOT
BE
A DEPOSITION.
NO
TESTIMONY WILL BE
TAKEN.
If
you fail to appear at the time and place specified; furnish the records
instead
of
appearing as provided above; or objection fo this subpoena, you may
be
in contempt
of
court.
Case
No.:
48-2007-CA-014233-O
Page
3 of 4
Tis'
Subpoena
Duces
Tecum
w / o Deposition
You are subpoenaed to appear by the following attorneys, and unless
excused from this subpoena by these attorneys or the court, you shall respond to
this subpoena as directed.
Dated on
this_
day
of
February, 2008.
For the Court
CLAY M. TOWNSEND, ESQ.
Florida Bar No.: 363375
KEITH MITNIK, ESQ.
Florida Bar No.: 436127
GREGOR1O 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
In
accordance with the Americans With Disabilities Act, persons with disabilities needing a
special accommodation to participate in this proceeding should contact the offices
of
Morgan, &
Morgan, P.A., 20 North Orange Avenue, Suite 1600, Orlando, Florida 32801, telephone 407-
420-1414, not later than seven (7) days prior to the proceedings.
If
hearing impaired, (TDD)
1-
800-955-8771, or Voice (V) 1-800-955-8770, via Florida Relay Service.
Case No.: 48-2007-CA-014233-0
Page4
of4
Ils' Subpoena Duces Tecum
w/o
Deposition