Mem. in Support of Mot. for Additional Costs · MICHAEL SKIDMORE, etc., Plaintiff, vs. LED...

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Peter J. Anderson, Esq., Cal. Bar No. 88891 E-Mail: [email protected] LAW OFFICES OF PETER J. ANDERSON A Professional Corporation 100 Wilshire Boulevard, Suite 2010 Santa Monica, CA 90401 Tel: (310) 260-6030 Fax: (310) 260-6040 Attorneys for Defendants JAMES PATRICK PAGE, ROBERT ANTHONY PLANT, JOHN PAUL JONES, WARNER/CHAPPELL MUSIC, INC., SUPER HYPE PUBLISHING, INC.,ATLANTIC RECORDING CORP., RHINO ENTERTAINMENT COMPANY and WARNER MUSIC GROUP CORP.

Helene Freeman, Esq., admitted pro hac vice E-Mail: [email protected] PHILIPS NIZER LLP 666 Fifth Avenue New York, NY 10103-0084 Tel: (212) 977-9700 Fax: (212) 262-5152Attorneys for Defendants JAMES PATRICK PAGE, ROBERT ANTHONY PLANT and JOHN PAUL JONES

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

Case No. 2:15-cv-03462 RGK (AGRx)

DEFENDANT WARNER/ CHAPPELL MUSIC, INC.’S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR AWARD OF ADDITIONAL COSTS; DECLARATION

Date: August 8, 2016 Time: 9:00 a.m.

Courtroom of the Honorable R. Gary Klausner

United States District Judge

MICHAEL SKIDMORE, etc.,

Plaintiff,

vs.

LED ZEPPELIN, et al.,

Defendants.

)))))))))))

Case 2:15-cv-03462-RGK-AGR Document 295-1 Filed 07/07/16 of 66 Page ID #:8852

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MEMORANDUM OF POINTS AND AUTHORITIES

1. INTRODUCTION

Defendant Warner/Chappell Music, Inc. (“Warner/Chappell”) respectfully

submits this Memorandum in support of its Motion for the award of additional costs

not taxable by the Clerk.

In this copyright infringement action, the Court has discretion to award

Warner/Chappell “full costs” (17 U.S.C. § 505), and the award of full costs is

appropriate. As a prevailing party, Warner/Chappell is presumably entitled to costs,

and its successful defense against plaintiff’s copyright claim furthered the purposes

of the Copyright Act. See, Warner/Chappell Motion for Attorneys’ Fees, at Memo.

at 2-5. Accordingly, Warner/Chappell should be awarded its non-taxable costs,

including expert witness fees, video deposition costs, trial transcript charges and

counsel’s travel expenses for depositions in this action, as well as any service of

process charges, deposition costs and witness fees that Warner/Chappell has

concurrently applied to the Clerk to tax, but which the Clerk deems non-taxable.

2. WARNER/CHAPPELL IS PROPERLY AWARDED ITS NON-

TAXABLE COSTS

The Copyright Act provides:

“In any civil action under this title, the court in its discretion may

allow the recovery of full costs by or against any party other than the

United States or an officer thereof.”

17 U.S.C. § 505. Giving “full costs” meaning, the Ninth Circuit has held in a

copyright infringement action the “district courts may award otherwise non-taxable

costs, including those that lie outside the scope of [28 U.S.C.] § 1920, under § 505.

Twentieth Century Fox Film Corp. v. Entm’t Distrib., 429 F.3d 869, 885 (9th Cir.

2005), cert. denied 548 U.S. 919 (2006). “In addition to regular taxable costs,

allowable costs under section 505 include costs for service of process, depositions

expenses, copying, computer assisted legal research, expert witness fees, and travel


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costs.” Perfect 10, Inc. v. Giganews, Inc., No. CV 11-07098-AB SHX, 2015 WL

1746484, at *6 (C.D. Cal. Mar. 24, 2015) (compiling cases).

Here, Warner/Chappell has currently applied to the Clerk to tax the taxable

costs, including deposition transcript costs and service of process charges. As for

non-taxable costs recoverable under 17 U.S.C. Section 505, Warner/Chappell is

properly awarded:

The video costs Warner/Chappell paid for the videotaped depositions

taken by plaintiff or by defendant, totaling $12,227.90;

The expert witness fees charged by plaintiff’s experts for providing

their deposition testimony in this action, of at least $6,355.00;

The expert witness fees Warner/Chappell incurred to defense expert

witnesses, totaling $138,571.00;

The trial transcript costs totaling $10,791.63; and

Coach airfare and hotel charges Warner/Chappell incurred for its

counsel’s attendance at depositions outside this judicial district,

totaling $$11,753.53.

See, attached Declaration at 4-7, ¶¶ 3-8, & Exhibits 1-5.

In addition, Warner/Chappell respectfully requests that the Court award under

Section 505 any service of process charges, deposition costs and witness fees that

Warner/Chappell has asked the Clerk to tax but which the Clerk deems non-taxable.

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3. CONCLUSIONWarner/Chappell respectfully submits that its Motion is properly granted and

its non-taxable costs awarded.

Dated: July 7, 2016 /s/ Peter J. Anderson Peter J. Anderson, Esq.

LAW OFFICES OF PETER J. ANDERSONA Professional Corporation

Attorney for Defendants JAMES PATRICK PAGE, ROBERT

ANTHONY PLANT, JOHN PAUL JONES, WARNER/CHAPPELL MUSIC, INC., SUPER HYPE PUBLISHING, INC.,

ATLANTIC RECORDING CORP., RHINO ENTERTAINMENT COMPANY and WARNER MUSIC GROUP CORP.


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DECLARATION OF PETER J. ANDERSON

I, Peter J. Anderson, declare and state:

1. I am an attorney admitted to practice before this Court and all Courts of

the State of California. I have personal knowledge of the following facts and could

competently testify to these facts if called upon to do so.

2. In this action, I represent defendants James Patrick Page, Robert Plant,

John Paul Jones, Warner/Chappell Music, Inc. (“Warner/Chappell”), Atlantic

Recording Corporation, Rhino Entertainment Company and Warner Music Group

Corp. This Declaration is submitted in support of Warner/Chappell’s Motion for the

award of additional costs not taxable by the Clerk.

Video Costs of Depositions

3. While there are important reasons to videotape depositions, videotape

depositions in this case were especially important because this case involves musical

works and, as a result, all but one of the videotaped depositions included the playing

of recordings and in some instances the deponents’ performance of compositions.

Accordingly, both plaintiff and defendants took videotaped depositions in this

action.

4. Plaintiff took the videotaped depositions of Mr. Page, Mr. Plant and Mr.

Jones, and videotaped depositions of defendants’ experts, Dr. Lawrence Ferrara and

Robert Mathes. Warner/Chappell incurred costs in order to obtain copies of the

video recordings of those depositions. In addition, defendants took the videotaped

depositions of Jay Ferguson and Mark Andes and videotaped depositions of

plaintiff’s experts, Dr. Alexander Stewart, Erik Johnson, Kevin Hanson, Brian

Bricklin and Dr. Michael Einhorn. Attached to this Declaration as Exhibit 1 are true

and correct copies of the invoices and my firm’s checks or check stubs for the

following payments for video recordings of these depositions, and which video

charges total $12,227.90:

(a) Video charges of $1,238.75 for defendants’ deposition of Jay


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Ferguson;

(b) Video charges of $1,020.70 for defendants’ deposition of Mark

Andes;

(c) Video charges of $900.00 for plaintiff’s deposition of James

Patrick Page;

(d) Video charges of $900.00 for plaintiff’s deposition of John Paul

Jones;

(e) Video charges of $900.00 for plaintiff’s deposition of Robert

Plant;

(f) Video charges of $1,295.00 for defendants’ deposition of

plaintiff’s expert, Dr. Alexander Stewart;

(g) Video charges of $1,455.00 for defendants’ depositions of

plaintiff’s experts, Erik Johnson and Kevin Hanson;

(h) Video charges of $2,075.00 for defendants’ deposition of

plaintiff’s expert, Dr. Michael Einhorn;

(i) Video charges of $175.00 for plaintiff’s deposition of Michael

Ware;

(j) Video charges of $700.00 for plaintiff’s deposition of defendants’

expert, Rob Mathes;

(k) Video charges of $525.00 for plaintiff’s deposition of defendants’

expert, Dr. Lawrence Ferrara (misspelled on the invoice as “Jerrara”); and

(l) Video charges of $1,043.45 for defendants’ deposition of

plaintiff’s expert, Brian Bricklin.

Expert Witness Fees Charged by

Plaintiff’s Experts for Deposition Testimony

5. Defendants took the depositions of plaintiff’s five expert witnesses. To

date, plaintiff’s counsel has provided invoices for only two of those experts and the

invoices overstated the amounts because plaintiff’s counsel and I agreed that


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preparation and travel time would not be charged, and because the two invoices

included plaintiff’s questioning of his own experts. I calculate the actual expert fee

payable to those two experts, Dr. Stewart and Dr. Einhorn, at $3,325 and $3,030,

respectively, and have asked plaintiff’s counsel to provide a W-9 for each.

Warner/Chappell respectfully requests that the Court award Warner/Chappell as

additional costs, the sums Warner/Chappell pays plaintiff’s five experts for their

deposition testimony.

Defense Expert Fees

6. Warner/Chappell has paid or incurred expert witness fees for the expert

analysis and testimony of Dr. Ferrara and Mr. Mathes, both of whom testified at

trial, and for which Warner/Chappell incurred a total of $138,571.00:

(a) Attached to this Declaration as Exhibit 2 is a true and correct

copy of the Dr. Ferrara’s redacted invoices in this action, which total

$102,621.00.

(b) Attached to this Declaration as Exhibit 3 is a true and correct

copy of Mr. Mathes’ redacted invoices in this action, which total

$35,950.

Trial Transcript Charges

7. My firm paid on behalf of Warner/Chappell a total of $10,931.56 in

deposits and an additional charge for trial transcripts in this action, and received a

partial refund of $139.93 of one deposit, resulting in a total of $10,791.63 paid for

trial transcripts. Attached to this Declaration as Exhibit 4 are the invoices of the two

court reporters who reported the trial in this action.

Counsel’s Travel and Lodging Expenses

8. Plaintiff took the depositions of Mr. Page, Mr. Plant and Mr. Jones in

London, England, and the depositions of defense experts Dr. Ferrara and Mr. Mathes

in New York, New York. In addition, I took the depositions of plaintiff in Boston,

Massachusetts, Bruce Pates in Memphis, Tennessee, Dr. Stewart in Burlington,


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Vermont, Mr. Johnson and Mr. Hanson in Philadelphia, Pennsylvania, and Dr.

Einhorn in Pine Brook, New Jersey. These depositions out of the country and out of

the State, required travel by air and hotel lodging. All of my airfare was billed to

Warner/Chappell at coach rates, irrespective of the actual charge my firm incurred. I

also took the deposition of Jay Ferguson in Santa Barbara, California, which

required one night of hotel lodging there. Attached to this Declaration as Exhibit 5

are true and correct copies of excerpts of invoices my firm rendered to

Warner/Chappell, showing charges of $8,908.56 for airfare and $2,844.97 for

lodging expenses, that Warner/Chappell incurred in connection with my attendance

at the foregoing depositions, and which total $11,753.53.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on July 7, 2016.

/s/ Peter J. Anderson PETER J. ANDERSON


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EXHIBIT 2


LAWRENCE FERRARA, INC. MUSIC ANALYSIS

17 HOBART AVENUE SHORT HILLS, NEW JERSEY 07078

tel. (973) 467-5080 e-mail: [email protected]

November 20, 2015 Invoice #: Stairway Sept. – Nov. 2015

Nathaniel A. Osher, Esq. Vice President, Legal & Business Affairs Warner/Chappell Music, Inc. 10585 Santa Monica Boulevard Los Angeles, CA 90025-4950

Re: : musicological services

Bill for Professional Services

7.6 hours, $3,002

21.4 hours, Prior art search, transcriptions and analysis: $8,453

(Telephone conversations, professional courtesy: NC)

TOTAL, 29 Billed hours: $11,455 due

Thank you for your courtesy and interest in my professional services.

Sincerely,

By: Lawrence Ferrara, Ph.D.

Copy to: Ellen Hochberg, VP. Warner Music Group Corp. Peter Anderson, Esq.

EXHIBIT 230


1

LAWRENCE FERRARA, Inc. MUSIC ANALYSIS



March 21, 2016 Invoice #: S vs LZ 2/16/16 – 3/16/16


Re: Skidmore vs. Led Zeppelin: musicological services


4.2 hours, completion of a Declaration dated 2/23/2016: $1,659

22.4 hours, completion of a Rebuttal Report to three of Plaintiff dated 3/12/2016: $8,848

5 hours, completion of a Declaration dated 3/12/2016: $1,975


(Overnight mailing of Audio Exhibit, professional courtesy: NC)

TOTAL, 31.6 Billed hours: $ 12,482 due

EXHIBIT 2 31


2


Sincerely,


Copies to: Ellen Hochberg, VP. Warner Music Group Corp. Peter Anderson, Esq.

EXHIBIT 2 32


1

LAWRENCE FERRARA, Inc. MUSIC ANALYSIS



June 29, 2016 Invoice #: S vs LZ April – June 2016


Re: Skidmore vs. Led Zeppelin: musicological services in April, May, and June 2016


4 hours, Review prior art works and links to other materialssent by defendants’ counsel, 4/13 – 4/15: $1,580

3.8 hours, Revisit plaintiff’s FOUR experts’ Feb. affirmative Reports and March rebuttal reports and prepare a six-page written response, 4/16: $1,501

4.4 hours, Review the Declaration of plaintiff’s experts Johnson and Stewart OPPOSING DEFENDANTS’MOTION IN LIMINE (dated 4/15) and prepare an eight-page written response, 4/17: $1,738

1.6 hours, review, transcribe, and compare “Sonata di Chitarra” and “Summer in the City” as requested by defendants’ counsel, 4/19: $632

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2

3 hours, Review all musical examples in my reports, select twenty-one visual exhibits, and explicate specific use and visual needs for Demonstratives for the visual graphics technologist, 4/24-4/25: $1,185

1.4 hours, Further back-and-forth and explanation regarding demonstratives, 4/26: $553

3.6 hours, Preliminarily review the 4 Amended Reports by plaintiff’s four experts and compare with

earlier reports, 5/4 – 5/5: $1,422

2 hours, Review audio exhibits to plaintiff experts’ Amended Reports, 5/11: $790

2.6 hours, At the request of defendants’ counsel, review New York article and Ravel’s “Bolero”, double-time finger picking, and mashups, 5/12: $1,027

6.2 hours, Draft a rebuttal report to the Stewart Amended Report, 5/14: $2,449

7.2 hours, Draft rebuttal reports to the Johnson, Hanson, and Bricklin Amended Reports, and search for Audio Exhibits 1-11 to the Bricklin report which were not attached but purportedly submitted earlier but without corresponding audio exhibits #’s, 5/15: $2,844

6.4 hours, Prepare suggested questions for the Stewart deposition, 5/16: $2,528

6.2 hours, (1) Further questions RE Stewart deposition, (2) review a dissertation at the request of defendants’ counsel, and begin my own trial preparation, 5/17: $2,449

5.8 hours, Trial prep, 5/18: $2,291

4.6 hours, Trial prep including further work on the Demonstratives, 5/19: $1,817

5 hours, Further work on my rebuttals to plaintiff’s four experts’ reports, 5/21: $1,975

7 hours, Further work on my rebuttals to plaintiff’s four experts’ reports, 5/22: $2,765

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6.8 hours, Prep for my deposition and trial, 5/23: $2,686

9.8 hours, Prep for my deposition, 5/26: $3,871

2.4 hours, Work on Rebuttals, 5/29: $948

8.6 hours, Work on Rebuttals and trial prep, 5/30: $3,397

7.8 hours, Complete Rebuttal and trial prep, 5/31: $3,081

3 hours, Demonstratives for trial, 6/1: $1,185


9.2 hours, Trial prep including Demonstratives, 6/3: $3,634

5 hours, Trial prep, 6/5: $1,975

8.2 hours, Trial prep including Demonstratives,6/6 – 6/7: $3,239






6.2 hours, Trial prep and meetings in LA, 6/14: $2,449

7.4 hours, Trial prep and meetings in LA, 6/15: $2,923

8 hours, Trial prep and meetings in LA, 6/16: $3,160

5.4 hours, At courthouse to give testimony and meetings during breaks (9:30 AM – 3:00 PM), 6/17: $2,133

2.2 hours, prepare suggested musicological summary and Demonstratives for Closing Argument: $869


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4

(Travel time, professional courtesy: NC)

TOTAL: 199.2 BILLED HOURS: $78,684 due


Sincerely,


Copies to: Peter Anderson Karrie Von Heldt

EXHIBIT 236


EXHIBIT 3


INVOICE-#02-12-16-1 FROM: ROB MATHES MUSIC INC. FOR: Warner/Chappell c/o The Law Offices of Peter J. Anderson (Santa Monica, CA) Re. Zeppelin Stairway to Heaven Legal Report

Hours @ $300.00 per hour. Wednesday 2/3/16—4:00 to 10:30pm – ½ hour break = 6 Hours Thursday 2/4/16---3:15 to 7:00pm – 15 min break = 3.5 Hours Sunday 2/7/16---7:30 to 10:40pm = 3 Hours and 10 Minutes Monday 2/8/16---8:00 to 8:50pm = 50 minutes Tuesday 2/9/16---2:45 to 9:30pm – 20 min break = 6 Hours and 25 Minutes Wednesday 2/10/16---4:30pm to 6:15pm = 1 hour and 45 minutes Total Hours—21 Hours and 40 Minutes ($6500.00) + Music Prep for Appendix #2 - $350

TOTAL----$6850.00

Here are my wire details: Rob Mathes Music Inc.Account #Wire #Bank:

[Bank Representative- ]

If you need to pay by check, please make it payable to: Rob Mathes Music Inc.

Thanks so much.

Rob Mathes

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INVOICE-#02-25-16-1 FROM: ROB MATHES MUSIC INC. FOR: Warner/Chappell c/o The Law Offices of Peter J. Anderson (Santa Monica, CA) Re. Zeppelin Stairway to Heaven Initial Rebuttal on Plaintiff’s Experts Reports and Recording Taurus Sheet Music on Acoustic Guitar-Mathes Second Invoice

Hours @ $300.00 per hour.Monday 2/22/16—8:00 to 10:45pm = 2 & 3/4 HoursTuesday 2/23/16---1:00 to 6:00 – 1 hour break for Lunch = 4 HoursWednesday 2/24/16---4:15 to 5:45 = 1 hour and ½ hoursTotal Hours—8 Hours and 15 minutes ($2475)

TOTAL----$2475.00

Here are my wire details:Rob Mathes Music Inc.Account #Wire #Bank:

[Bank Representative-]

If you need to pay by check, please make it payable to:Rob Mathes Music Inc.

Thank you very much. It is an honor to be serving as an expert in this case. The very questions we ask about variation and the uniqueness of individual creativity within certain classic harmonies and tradition are crucial.

Rob Mathes

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Law Offices of Peter J. Anderson

A Professional Corporation100 Wilshire Boulevard, Suite 2010Santa Monica, CA 90401

Nathan OsherVice President, Legal & Business AffairsWarner/Chappell Music, Inc.10585 Santa Monica Blvd.Los Angeles, CA 90025

July 01, 2016

Invoice submitted to:

In Reference To: Warner/Chappell adv. Skidmore

Invoice # 19455

For services rendered through 6/30/16

Hrs/Rate Amount

06/01/16 9.60 3,168.00330.00/hr

E-mails from and to Dr. Ferrara, from Ms.Parry, and to Mr. Mathes; telephone callfrom Mr. Mathes; e-mails from and to Mr.Meade; e-mails from and to Mr. Mathes;e-mails from and to Mr. Fleuhr; telephonecall from ; e-mails from andto Mr. Mathes; e-mails from and to Mr.Osher, and e-mail to Mr. Self; e-mails fromand to ; e-mails to and fromMr. Duvall and e-mail to Mr. Duvall; e-mailto Mr. McDowell et al. and from and to Mr.Cohen; e-mails from and to Mr. Mathes;prepare Defendants' Rebuttal Reports forattachment to Dr. Ferrara's and Mr. Mathes'reports, and e-mails to Mr. Malofiy and toMr. McDowell et al.; e-mail to Ms. Freeman;e-mails from and to Ms. Freeman and to Mr.Duvall and Mr. Mongoluzo and from and toMr. Duvall; complete review of transcriptof deposition of Mr. Johnson and selection

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Nathan Osher 11Page

Hrs/Rate Amount

06/29/16 2.70 891.00330.00/hr

Begin draft of Memorandum of Points andAuthorities in support of Motion forattorneys' fees; telephone call from Ms.Freeman; e-mail to Mr. Malofiy et al.

06/30/16 4.30 1,419.00330.00/hr

Continue preparation of draft of Memorandumof Points and Authorities in support ofMotion for attorneys' fees; e-mails fromand to Mr. Eidel, Mr. Osher and Mr.Robinson, and review Court of Appeals'decision re plaintiff's counsel'ssuspension; e-mails from and to Ms.Freeman; continue preparation of draft ofMemorandum of Points and Authorities insupport of Motion for attorneys' fees

$107,481.00325.70

Additional Charges :

05/13/16 272.03Outside Copying Service

91.70Books and recordings/exhibits

05/14/16 1,315.61Airfare


05/20/16 40.00Parking

05/27/16 4,721.10Deposition Costs for Robert Mathes and Laurence Ferrara

05/31/16 1,153.60Deposition Costs for Michael Ware

06/01/16 65.61FedEx

06/03/16 34.20FedEx

06/04/16 20.00Copy of Article


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Nathan Osher 12Page

Amount

06/07/16 65.93FedEx

06/08/16 66.10Messenger Service


4,000.00Court Reporter - Sandra MacNeil

4,000.00Court reporter - Cindy Nirenberg

47.47Messenger Service

06/10/16 2,727.60Transcript of Brian Bricklin






06/30/16 1,043.45Video deposition for Brian Bricklin

Total additional charges $20,244.77

Total amount of this bill $127,725.77

Previous Balance $161,301.15

6/27/2016 Payment - Thank You. Check No. 28678041 ($55,030.40)6/27/2016 Credit for witness fee - Howard Frank ($71.05)6/27/2016 Credit for witness fee - Lou Adler ($71.05)

($55,172.50)

Balance due $233,854.42

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