IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND
FOR
ORANGE COUNTY, FLORIDA
WRIGHT ENTERTAINMENT GROUP,
L.L.C., and WRIGHT
ENTERTAINMENT GROUP, INC.,
Plaintiffs,
vs.
BRITNEY SPEARS and BRITNEY
TOURING, INC.,
Defendants.
---------------
I
CASE NO.: 48-2007-CA-014233-O
Div. 32
AFFIDAVIT OF DAVID PIERFY
STATE OF FLORIDA
COUNTY OF ORANGE
Before me, the undersigned authority, personally appeared
DA
VE PIERFY,
who, after being duly sworn, deposes and says:
1.
I am over the age
of
21
years and have personal knowledge
of
the
contents
of
this Affidavit.
2.
I have served as the Business Manager for Wright Entertainment Group,
Inc. since its inception in April 1998 to the present date.
3.
I also currently serve as the Business Manager for Wright Entertainment
Group, LLC, and have since its inception in June 2001.
4.
On July 26, 2001, I sent an email to Pat Marchese, the Business
Manager for Britney Spears, advising her that due to an internal reorganization,
effective immediately, all checks were to be made payable to Wright Entertainment
Group, LLC, rather than Wright Entertainment, Inc. (Exhibit "A")
Page I
of2
5.
In that same communication, I advised Ms. Marchese that
if
for any
reason this request could not be accommodated, to please contact me as soon as
possible.
6.
I did not receive any communication from Pat Marchese, Britney
Spears, or any other representative for RHF Management Services, LLC
on
behalf
of
Britney Spears, advising me
of
any conflict with our request that all payments be
issued to Wright Entertainment Group, LLC.
7.
In fact, Ms. Spears' Business Manager(s) complied with our request
and issued payments on the commissions due
to
Wright Entertainment Group, LLC
as well
as
WEG, LLC and simply Wright Entertainment Group. (Exhibit "B")
8.
The checks received from Ms. Spears' Business Manager(s) were issued
by
the SJB Revocable Trust c/o RHF Management Services, LLC, located at 10100
Santa Monica Blvd., Suite 1300, Los Angeles, CA 90067, as well
as
by
Britney
Brands, Inc. and Britney Touring, Inc. (see Exhibit "B")
9.
Checks received were not payable to Johnny Wright personally.
STATE OF FLORIDA
COUNTY OF ORANGE
FURTHER AFFIANT SA YETH NAUGHT.
D
The foregoing instrument was aclmowledged before me this
/0
day
of
April, 2008,
by
DA YID
PIERFY, who is personally !mown to me and/or who produced
/(NO
LU
P~
as
identification and who did/did not take an oath.
tate
of
Florida at Large
My
Commission Number:
My Commission Expires:
Page 2
of2
JEANETTE
WILFERD
MY
COMMISSION
I
OD
389670
EXPIRES:
January
25,
2009
Bondedlhru
Notary
Public
Unc181W(it'"'5
Dave Pierfy
From:
Sent:
To:
Cc:
Subject:
Dave Pierfy [davep@ifms.org] on behalf
of
Dave Pierfy
Thursday, July 26, 2001 2:17 PM
'Pat Marchese'
'Theresa Page';
'JW
'email'
Wright
Entertainment Group commission checks
Due to an internal reorganization, effective immediately, please make all checks payable to Wright Entertainment Group, LLC (Fed
ID#
59-3732787) rather than Wright Entertainment Group, Inc. If, for any reason, this request cannot be accomodated, please let
me
know as soon as possible.
As
always, thanks for your assistance.
· EXHIBIT
IB REVOCABLE TRUST Datr Check No.
1792
Invoice Descrinfion Account·· . Distribution
Number 2693 2004
COMMISSIONS
Vendor
WRIGHT
Date
12-26-06
I
Payment
58,301.00
LE
TRUST}
\'\
:,.,~/2/o
RHf.·Management
Services·
LLCt
·:,,,,.,,«·:·,(°".
·
1
□
1oo·santa
Monica-Blvd~,
Suite
1300
Los Angeles,
CA
90067
(310)
229-5128
. .
..
, '
4104-002
B1~\tif.·'HQ(Qt£{lll¾\Ni
❖
i[lv«.mi@½r\.l;vi¥1af.iiin;l!t#\Mt+W::rniNFhlHtUIQBl>~i
6
1i4n°1ij@t§3ffiaj{Q)4YJfoWdlili1
EXHIBIT
58,301.00
BRITNEY
BRANDS
INC.
1016
l.500
l.S:l
2[;.811•
SECORln'
FEATURES:
MICRO
PAINT
'rOfl a 80TTOM
BORDER$
COLOf\£0
PAffiRN
,
ARTIFICIAL
WATERMARK
ON
REVERSE
SIDE
•
MlSSlNG
FEATlJAE
INDICATES
A
COPY
\
00025222
BRi~ri
Tou~n1ai
INC;
_·
t/o
PNFW 156WES'l':56IBSTREET
NEW YORK,
N¥
1001~.
-.
TO.
THE
ORDER
OF
. .
·····
·
•-,,:·;
:.;,~,i~,~'.~2i~:z
:·:
W
E·
.G
LLC
6% $6.,
412,704.18
.
TOURING.
INCOME
NET
OF S & L &
1ST
DEPOSIT
SIGNATURE
BANK
300
PARK
AVENUE
NEW
YORK,
NY.
10022
12/04/01
l.
500
• S 3 :!0tin•
00025616
I
00025616
$384762.25
dave pierfy
From: Mabel Tash [MTash@rhfmgt.com]
Sent: Friday, October 20, 2006
11
:52 AM
To:
Dave Pierfy
Cc: Richard Feldstein; Hilaria Taub
Subject: RE: britney
Dave,
I will double check and
let
you know next week.
Mabel
From: Dave Pierfy [mailto:davep@wegmusic.com]
Sent: Friday, October 20, 2006 8:00
AM
To: Mabel Tash
Cc:
Richard Feldstein; Hilarie Taub
Subject:
RE:
britney
Mabel,
We
received a check for $41,762 earlier this week. Thank you very much.
Page 1
of2
Can you provide some supporting documentation to show how this amount was calculated? Also, the
"Description" on the check indicates that the payment is for commissions for June 2005 -June 2006. I still
believe that
we
are entitled to commissions on 2004 royalty accountings, which were not paid by Britney's
previous business manager.
Please advise.
Best regards,
Dave Pierfy
Wright Entertainment Group
From: Mabel Tash [mailto:MTash@rhfmgt.com]
Sent: Wednesday, June 28, 2006 2:
16
PM
To:
Dave Pierfy
Cc:
Richard Feldstein; Hilarie Taub
Subject:
RE:
britney
We
will look into
it
and
get
back
to
you.
Mabel
From: Dave Pierfy [mailto:davep@wegmusic.com]
Sent: Wednesday, June 28, 2006 10:52
AM
To: Mabel Tash
4/10/2008
Cc:
Richard Feldstein; Hilarie Taub
Subject:
RE:
britney
Page 2
of2
That is true. However, we have not been paid for record royalties since the period ended December
31,
2003.
From: Mabel Tash [mailto:MTash@rhfmgt.com]
Sent: Wednesday, June 28, 2006 1:22
PM
To:
davep@wegmusic.com
Cc:
Richard Feldstein; Hilarie
Taub
Subject: britney
Dear Dave,
Good
talking to
you
this morning.
As
we discussed, I will look into
the
accounting
next week. I quickly ran some reports and I see
that
Wright Entertainment has been paid as
recently as
5/6/06.
Regards,
'M.a6d'I'asn
Director
RHF Management, LLC
10100 Santa Monica Blvd., Suite 1300
Los Angeles, CA 90067
310-229-5155 tel
310-229-5138 fax
MTash@rhfmgt.com
4/10/2008