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_e_fe_n_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 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-O Page 1
of2
ns
â–º
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-Partiesi~
Subpoena Duces Tecum Without Deposition
has been furnished,
by
U.S. mail, this day
of
February, 2008, to Britney Spears,
12095 Sum:mit Circle, Beverly Hills, CA 9021
0;
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
IIs'
Notice
of
Production from 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_e_fe_n_d_an_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 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-O
Pagelof4
fls~ Subpoena
Due
es T ecum 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 I, 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 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
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
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, without 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
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ITs'
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 I, 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
of4
ITs'
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
this_
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
of4
ITs'
Subpoena Duces Tecwn
w/o
Deposition