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Case No.: 48-2007-CA-014233-O Page 1 of 4 Πs’ Subpoena Duces 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.,
Plaintiff(s),
vs.
BRITNEY SPEARS and BRITNEY
TOURING, INC.,
Defendant(s). /
CASE NO.: 48-2007-CA-014233-O
AMENDED 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, including royalty statements,
pertaining to Britney Spears, Britney Touring, Inc., or any related entities of the
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Case No.: 48-2007-CA-014233-O Page 2 of 4 Πs’ Subpoena Duces Tecum w/o Deposition
“Britney Spears” brand pertaining to or reflecting Gross Receipts1 (i.e., from
agreements with you and/or third parties related to sub-licensing, merchandising,
and performing) 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 (the term of the WEG Management Agreement).
2. Copies of any and all documents pertaining to Britney Spears, Britney
Touring, Inc., or any related entities of the “Britney Spears” brand reflecting Gross
Receipts (i.e., from sub-licensing, merchandising, and performing) earned by
Britney Spears, Britney Touring, Inc. or any related entity owned or operated by
Britney Spears between February 20, 2003 through February 20, 2008 (the
“sunset” term) pursuant to agreements entered into, negotiated or in connection
with services rendered by WEG during the term of the Management Agreement
(January 1, 1999 through February 20, 2003).
3. Royalty statements or any other documents reflecting revenue earned
by, and/or paid to, Britney Spears, BTI, or any related entity between January 1,
1999 and February 20, 2008 pursuant to agreements between Jive/Zomba and
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.
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Case No.: 48-2007-CA-014233-O Page 3 of 4 Πs’ Subpoena Duces Tecum w/o Deposition
Britney Spears that were entered into, substantially negotiated, or in connection
with services performed by WEG in whole or in part between January 1, 1999
through February 20, 2003.
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.
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Case No.: 48-2007-CA-014233-O Page 4 of 4 Πs’ 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 8th day of April, 2008.
For the Court
_Clay M. Townsend____
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.
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