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Case No.: 48-2007-CA-014233-O Page 1 of 5 ∏s’ Motion to Appoint Commissioners

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 APPOINTMENT

OF COMMISSIONERS AND ISSUANCE OF SUBPOENAS

COME NOW the Plaintiffs, WRIGHT ENTERTAINMENT GROUP, LLC

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

undersigned counsel, and pursuant to Fla. R. Civ. P. 1.300 and moves this Court to:

1. Appoint Michael Friedman, Esquire, at Baker and Hostetler, LLP, 45

Rockefeller Plaza, 11th Floor, New York, NY 10111, or his agent, as a

Commissioner in the above-styled cause to serve a Subpoena Duces Tecum

Without Deposition (Exhibit A) upon the following Records Custodian:

Zomba Recording Corporation

c/o Kim L. Rappaport, Esq.

SONY BMG MUSIC ENTERTAINMENT

550 Madison Avenue

New York, NY 10022

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Case No.: 48-2007-CA-014233-O Page 2 of 5 ∏s’ Motion to Appoint Commissioners

2. Appoint E & L Management, c/o Manatt, Phelps & Phillips, LLP,

11355 West Olympic Boulevard, Los Angeles, CA 90064, or his agent, Ed

Warnecke, as a Commissioner in the above-styled cause to serve a Subpoena

Duces Tecum Without Deposition (Exhibit B) upon the following Records

Custodian:

Signatures Network, Inc.

c/o Myles B. Silton, Esq.

General Counsel & Senior Vice President, Business Affairs

Two Bryant Street, Suite 300

San Francisco, CA 94105

3. Enter an Order Appointing the above-referenced Commissioners to

serve the attached subpoenas (Exhibits A & B) on the respective Records

Custodians to compel the production of discovery in aid of execution as set forth in

the attached subpoenas and in support thereof, the Plaintiffs would state:

(a) The instant case is a breach of contract action arising out of a

personal management contract between the Plaintiffs and the Defendants initiated

on October 26, 2007.

(b) On November 1, 2007, the Plaintiffs served discovery requests

on the Defendants which to date have not been responded to. (Composite Exhibit

C – Plaintiffs’ First Request for Production and First Set of Interrogatories)

(c) On December 18, 2007, the Plaintiffs obtained a Clerk’s

Default against the Defendants. (Composite Exhibit D – Clerk’s Default against

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Case No.: 48-2007-CA-014233-O Page 3 of 5 ∏s’ Motion to Appoint Commissioners

Britney Spears and Britney Touring, Inc.)

(d) On February 14, 2008, the Plaintiffs obtained Final Judgments

against the Defendants. (Composite Exhibit E – Final Judgment By Default

against Britney Spears and Britney Touring, Inc.)

(e) On February 14, 2008, the Plaintiffs also obtained an Order

(Exhibit F) compelling the Defendants, Defendants’ agents, Defendants’

representatives and those in possession of Defendants’ records to produce and

respond to the discovery requests (Composite Exhibit C) in aid of execution of the

Final Judgments entered.

(f) On February 14, 2008, the Plaintiffs issued a Notice of

Production from Non-Party as to Zomba Recording Corporation, 550 Madison

Avenue, New York, NY 10022 and a Notice of Production from Non-Party as to

Signatures Network, Inc., Two Bryant Street, Suite 300, San Francisco, CA

94105. (Composite Exhibit G).

(g) On March 4, 2008, Plaintiffs’ counsel forwarded a copy of the

Notice of Production from Non-Party as to Zomba Recording Corporation and

Notice of Production from Non-Party as to Signatures Network, Inc., to the counsel

for the Conservator of the Estate of Britney Spears, Jeryll Cohen, Esq., via

electronic transmission.

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Case No.: 48-2007-CA-014233-O Page 4 of 5 ∏s’ Motion to Appoint Commissioners

(h) As of March 14, 2008, no objection to the Notices of

Production from Non-Party as to Zomba Recording Corporation or Signatures

Network, Inc. have been received by any party.

WHEREFORE, Plaintiffs respectfully request that this Court enter an

Order Appointing Commission to appoint the above representatives of Baker &

Hostetler, LLP and E & L Management, c/o Manatt, Phelps & Phillips, LLP as

Commissioners for the service of process and/or administering of oaths and/or

reporting depositions of the above-named Records Custodians and such other

depositions in the State of New York and the State of California as may be

necessary and authorize the Clerk of the Superior Court for San Francisco County

and the Clerk of the Supreme Court for New York County to issue the respective

subpoenas to compel the aforementioned Records Custodians to produce the

requested documentation on the date and time specified on the respective

subpoenas and authorize the undersigned Counsel to make inquiries at the time of

production and/or depositions and to such other further relief as this Court deems

just and proper.

Dated this 17th day of March, 2008. Respectfully Submitted,

_/s/ Clay M.

/s/ Clay M./s/ Clay M.

/s/ Clay M. Townsend

Townsend Townsend

Townsend______

CLAY M. TOWNSEND, ESQ.

Florida Bar No.: 363375

KEITH MITNIK, ESQ.

Florida Bar No.: 436127

GREGORIO FRANCIS, ESQ.

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Case No.: 48-2007-CA-014233-O Page 5 of 5 ∏s’ Motion to Appoint Commissioners

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

CERTIFICATE OF SERVICE

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

furnished, by U.S. mail, this 17th day of March, 2008, to: Judith Mercier, Esq.,

Jorge Hernandez-Torano, Esq. and Bill Wilson, Esq., Holland & Knight, LLP, 200

S. Orange Avenue, Suite 2600, Orlando, FL 32801; 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; Michael Friedman, Esq., Baker and Hostetler, LLP, 45

Rockefeller Plaza, 11th Floor, New York, NY 10111; and Ed Warnecke, E & L

Management, c/o Manatt, Phelps & Phillips, LLP, 11355 West Olympic

Boulevard, Los Angeles, CA 90064.

__/s/ Clay

/s/ Clay/s/ Clay

/s/ Clay M. Townsend

M. Townsend M. Townsend

M. Townsend_

CLAY M. TOWNSEND, ESQ.

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