Case 2:15-cv-03462-RGK-AGR Document 156-1 Filed 04/04/16 Page 1 of 5 Page ID

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Peter J. Anderson, Esq., Cal. Bar No. 88891

E-Mail: pja@pjanderson.com
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: hfreeman@phillipsnizer.com
PHILIPS NIZER LLP
666 Fifth Avenue
New York, NY 10103-0084
Tel: (212) 977-9700
Fax: (212) 262-5152
Attorneys for Defendants
JAMES PATRICK PAGE, ROBERT ANTHONY
PLANT and JOHN PAUL JONES

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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MICHAEL SKIDMORE, etc.,

Plaintiff,

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vs.
LED ZEPPELIN, et al.,
Defendants.

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

DEFENDANTS WITNESS LIST
Pretrial:
Date: April 25, 2016
Time: 11:00 a.m.
Trial:
Date: May 10, 2016
Time: 9:00 a.m.
Courtroom of the Honorable
R. Gary Klausner
United States District Judge

Case 2:15-cv-03462-RGK-AGR Document 156-1 Filed 04/04/16 Page 2 of 5 Page ID

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DEFENDANTS WITNESS LIST

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Witness

Brief Statement of Testimony

Time Estimate

Lou Adler
Hollenbeck Music
3969 Villa Costera 1
Malibu, CA 90265-5151

The 1967 creation and ownership,

and performance and exploitation
of, the musical composition
Taurus

2 hours

Howard Frank
Hollenbck Music
3969 Villa Costera 1
Malibu, CA 90265-5151

The ownership of the musical

composition Taurus, and
Hollenbeck Musics knowledge of
and inaction re Stairway to
Heaven

1 hour

Mark Andes (by

deposition if witness does
not appear)

The 1967 creation and ownership,

and performance and exploitation
of, the musical composition
Taurus (as a surviving member of
Spirit, his knowledge re
performance is different than
Adlers and Franks)

4 hours

David Woerhaye or other

PMK on behalf of Rhino
Entertainment Co. and
Atlantic Recording
Corporation

Atlantic Recording Corporations

deductible expenses as to Stairway
to Heaven; the marketing and
promotion of Led Zeppelin and the
Stairway to Heaven recording
and/or the products in which it
appears, and the allocation of
claimed profits between the
allegedly infringing portion of
Stairway to Heaven and noninfringing elements

3 hours

Jay Ferguson

The 1967 creation and ownership,

and performance and exploitation
of, the musical composition
Taurus (as a surviving member of
Spirit, his knowledge re
performance is different than
Adlers and Franks)

4 hours

Dr. Lawrence Ferrara

Lack of striking or substantial

similarity between the works;
prior art and common musical

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Case 2:15-cv-03462-RGK-AGR Document 156-1 Filed 04/04/16 Page 3 of 5 Page ID

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Witness

Brief Statement of Testimony

Time Estimate

ideas and devices; quantitative

importance of the allegedly
similar portions

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John Paul Jones

Authorship of the composition

Stairway to Heaven, including
independently of Taurus; prior art;
lack of familiarity with Taurus

James Patrick Page

Authorship of the composition

Stairway to Heaven, including
independently of Taurus; session
musician work and prior art; lack
of familiarity with Taurus;
demonstrative evidence as to
Stairway to Heaven and allegedly
similar portions

Robert Mathes

Lack of striking or substantial

similarity between the works;
prior art; qualitative importance of
the allegedly similar portions;
importance and appeal of Stairway
to Heaven; allocation of Stairway
to Heaven profits to elements (for
example, performance, other
compositional elements, lyrics,
recording) other than portions
claimed to be similar to Taurus

Robert Anthony Plant

Authorship of the composition

Stairway to Heaven, including
independently of Taurus; prior art;
lack of familiarity with Taurus

William Ruhlmann (by

deposition)

Randy Craig Wolfes

acquiescence in alleged copying
from Taurus

Michael Skidmore

Randy Craig Wolfe Trust and

ownership and/or disposition of
Randy Wolfes rights, including
with respect to musical
composition Taurus; knowledge
of and action/inaction re Stairway

4 hours

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5 hours

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3 hours

4 hours

.5 hours

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4 hours

Case 2:15-cv-03462-RGK-AGR Document 156-1 Filed 04/04/16 Page 4 of 5 Page ID

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Witness

Brief Statement of Testimony

Time Estimate

to Heaven

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Jeremy Blietz or other

PMK on behalf of
Warner/Chappell Music,
Inc.

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Warner/Chappell Music, Inc.s

deductible expenses as to Stairway
to Heaven; the allocation of
claimed profits between the
allegedly infringing portion of
Stairway to Heaven and noninfringing elements

3 hours

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Defendants may call if the need arises:

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Joan Hudson or other

PMK of
Joan Hudson & Co.

The individual defendants

respective deductible expenses as
to Stairway to Heaven; the
allocation of claimed profits
between the allegedly infringing
portion of Stairway to Heaven and
non-infringing elements; *postMay 31, 2011 revenues

*Scott McDowell or
other PMK on behalf of
Super Hype Publishing,
Inc.

Super Hype Publishing, Inc.s lack

of exploitation of Stairway to
Heaven in the three years
preceding plaintiffs filing of this
action

*Paul Robinson or other

PMK on behalf of
Warner Music Group
Corp.

Warner Music Group Corp.s lack

of exploitation of Stairway to
Heaven in the three years preceding
plaintiffs filing of this action; to
the extent any revenues from
Stairway to Heaven are attributed to
Warner Music Group, its deductible
expenses and the allocation of
claimed profits between the
allegedly infringing portion of
Stairway to Heaven and the noninfringing elements

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3 hours

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1 hour

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1 hour

Case 2:15-cv-03462-RGK-AGR Document 156-1 Filed 04/04/16 Page 5 of 5 Page ID

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Insofar as plaintiff has not cooperated in the preparation of a joint witness list,
the above estimated times are on direct examination.

Defendants reserve the right to call witnesses identified by plaintiff, to call

witnesses not listed for impeachment purposes and to amend or supplement this

witness list as provided by law.

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Dated: April 4, 2016

/s/ Peter J. Anderson

Peter J. Anderson, Esq.
LAW OFFICES OF PETER J. ANDERSON
A 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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Helene M. Freeman, Esq.

PHILLIPS NIZER LLP
Attorney for Defendants
JAMES PATRICK PAGE,
ROBERT ANTHONY PLANT and
JOHN PAUL JONES

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