Latest / Tom Althouse Podcast / Tom Meeting with Attorney Ranken 11.18.13

Transcript

Tom Meeting with Attorney Ranken 11.18.13 · Tom Althouse Podcast

• 0:00
  Speaker 1: That'd be good start for meeting a right do you
• 0:08
  Speaker 1: want to work with me? You cannot communicate with opposing
• 0:12
  Speaker 1: counsel anymore without going through me CC than anything.
• 0:16
  Speaker 2: Do you agree or not think?
• 0:18
  Speaker 3: Why did you do that? Just your team? By the way,
• 0:21
  Speaker 3: that was very embarrassing for me.
• 0:23
  Speaker 1: Just be your help opposing counsel and refer to your
• 0:26
  Speaker 1: team as if I was not a question?
• 0:29
  Speaker 4: Can we address the case of here's like a team.
• 0:34
  Speaker 2: Who you're referring to? Who is your team?
• 0:36
  Speaker 1: I'm curious who you're getting your advice from.
• 0:39
  Speaker 2: I thought it would I thought it was part.
• 0:40
  Speaker 5: Of your team here, I was to call it our team,
• 0:43
  Speaker 5: just having a team?
• 0:44
  Speaker 6: Were you talking about us just refer to ourselves as.
• 0:49
  Speaker 5: Our team, not me and Sam?
• 0:51
  Speaker 2: Obviously?
• 0:52
  Speaker 7: Well, it's just one of those where I mean, it's
• 0:54
  Speaker 7: definitely that email was startling. The fact that it really
• 0:58
  Speaker 7: sounded like confidentiality on the table, and that's just not
• 1:01
  Speaker 7: something that our.
• 1:03
  Speaker 1: Team is you two and no one else, no, no,
• 1:07
  Speaker 1: who else is on your team?
• 1:09
  Speaker 6: Hopefully all of us are on the same page, and
• 1:12
  Speaker 6: we're talking.
• 1:12
  Speaker 1: About other people that you're getting advice from that I'm
• 1:15
  Speaker 1: not aware of.
• 1:17
  Speaker 4: There's a lot of people that are trying to input
• 1:19
  Speaker 4: advice who we've been steering away from advice. There's a
• 1:22
  Speaker 4: lot of questions about what is actually going on. We
• 1:26
  Speaker 4: feel that we've been left out in the wind in
• 1:28
  Speaker 4: a lot of ways. So we can start angry at
• 1:31
  Speaker 4: each other, or we can set friends.
• 1:34
  Speaker 1: So confidentiality, let's talk about. You have two choices. Actually
• 1:42
  Speaker 1: it's our choice, but you're because this is a strategy
• 1:47
  Speaker 1: decision that the lawyers make. It's not something under the
• 1:51
  Speaker 1: client's control, really, and I don't want to, you know,
• 1:54
  Speaker 1: play that card. So I want to try to get
• 1:57
  Speaker 1: you to understand what.
• 1:58
  Speaker 2: We need to do, and I'm going to get.
• 2:00
  Speaker 1: On the same page and I will listen to your concerns.
• 2:03
  Speaker 1: The two choices this, either we sign a confidentiality agreement
• 2:07
  Speaker 1: of some sort controlling production of documents in discovery or else.
• 2:12
  Speaker 2: The if we.
• 2:13
  Speaker 1: Don't sign, then they go to the court and they
• 2:15
  Speaker 1: say we don't want to release these things at all
• 2:18
  Speaker 1: or discovery or any other purpose, and they get an
• 2:21
  Speaker 1: order from the court determining whether or not they even
• 2:24
  Speaker 1: have to produce it. The confidentiality agreement has an advantage
• 2:29
  Speaker 1: because what.
• 2:31
  Speaker 2: It says is that we do get everything.
• 2:35
  Speaker 1: The court doesn't get to Neither neither the other side
• 2:38
  Speaker 1: nor the court gets to keep materials away from us
• 2:41
  Speaker 1: if they if we say no, we won't sign it,
• 2:43
  Speaker 1: then they go to court and we may not get
• 2:46
  Speaker 1: everything the court. And it's a very conservative judge. We
• 2:49
  Speaker 1: do the worst possible judge.
• 2:51
  Speaker 2: For this case.
• 2:53
  Speaker 3: Do you want to look at this or not? It's
• 2:56
  Speaker 3: the same, right, Yeah, it's the same.
• 2:57
  Speaker 1: Thanks for having it handy, but we don't refer to that.
• 3:03
  Speaker 1: It's a really bad judge for the case. You can
• 3:05
  Speaker 1: go I found a website where he's reviewed and he's
• 3:08
  Speaker 1: this radical right Bush appointee, always favors the big corporations,
• 3:13
  Speaker 1: is not hesitant to.
• 3:15
  Speaker 2: Grant summary judgments.
• 3:18
  Speaker 1: Is really strict on the rules and procedures, as he's
• 3:22
  Speaker 1: already shown in this case where both parties agreed on
• 3:25
  Speaker 1: him or leisurely scheduled for discovery and trial, and he
• 3:29
  Speaker 1: just said no, I'm not paying attention to that him
• 3:32
  Speaker 1: and posting my own discovery and trial schedule which is
• 3:35
  Speaker 1: very strict and short timeframes. And you've got to go
• 3:39
  Speaker 1: to trial next June. So I'm obviously very disappointed in
• 3:44
  Speaker 1: the choice of judge. But we got it's you know, roulette,
• 3:48
  Speaker 1: but we've got to work with it, and he's kind
• 3:52
  Speaker 1: of judged it very well. May rant protective orders keep
• 3:55
  Speaker 1: materials away from us because he is big business, corporate orient.
• 4:02
  Speaker 2: I think we're better.
• 4:03
  Speaker 1: Off with the discovery stipulation if we can get terms
• 4:06
  Speaker 1: that we're all comfortable with. And the one thing, the
• 4:10
  Speaker 1: one thing that I worry.
• 4:11
  Speaker 2: About a little bit is that.
• 4:14
  Speaker 1: It's kind of silent on the whole issue of what
• 4:17
  Speaker 1: happens with documents that want to be introduced at trial.
• 4:21
  Speaker 1: So I've demanded, as you saw in my response to them,
• 4:24
  Speaker 1: I've demanded an explanation as to their point of view
• 4:30
  Speaker 1: as to how, if at all, this affects a mission
• 4:33
  Speaker 1: of documents at trial. My interpretation of the agreement is
• 4:37
  Speaker 1: that it simply does not affect a mission of documents
• 4:40
  Speaker 1: at trial. In other words, they can't say, because it's
• 4:42
  Speaker 1: confidential and we sign this agreement that we can't get
• 4:45
  Speaker 1: it in at trial.
• 4:47
  Speaker 2: They can go to the judge as they.
• 4:49
  Speaker 1: Could in any case, and say it shouldn't come in
• 4:52
  Speaker 1: for whatever grounds, or it should be limited in its
• 4:56
  Speaker 1: use when it comes in, or it should be protected
• 5:00
  Speaker 1: under seal as it's called which means that you know
• 5:02
  Speaker 1: the public can't get access to it as part of
• 5:05
  Speaker 1: the trial record. This is so that it seems to
• 5:09
  Speaker 1: me that you sacrifice nothing in terms of your case
• 5:12
  Speaker 1: with this, which brings me to the second thing that
• 5:14
  Speaker 1: we got to get clear about. The first was communications
• 5:18
  Speaker 1: directly with the other side, and who's your team and
• 5:21
  Speaker 1: are we working together or across purposes. The second thing
• 5:25
  Speaker 1: is this, what is the point of this case. My thinking,
• 5:32
  Speaker 1: the way I signed up is the goal of this
• 5:35
  Speaker 1: case is to get you monetary compensation. If your point
• 5:39
  Speaker 1: of this case is to put that second and give
• 5:44
  Speaker 1: first priority to publicity or redeeming your reputation or exposing
• 5:51
  Speaker 1: the fraud, then.
• 5:55
  Speaker 2: We're now on the.
• 5:56
  Speaker 1: Same page, and we need to have a real serious
• 5:57
  Speaker 1: talk because the only way, first of all, that you're
• 6:00
  Speaker 1: going to get any of that is to win at
• 6:02
  Speaker 1: trial or to get a settlement. If you do get
• 6:07
  Speaker 1: a settlement, it's probably confidential and you can't disclose it,
• 6:10
  Speaker 1: so you know you've got to put that check in
• 6:12
  Speaker 1: consideration aside. But if you're going to put monetary considerations
• 6:17
  Speaker 1: second to getting publicity or exposing the truth, then I
• 6:24
  Speaker 1: don't think I can work with you, because what's going
• 6:26
  Speaker 1: to happen is you'll refuse to settle the case even
• 6:28
  Speaker 1: if they make a good offer, because they will demand confidentiality.
• 6:33
  Speaker 1: And also you'll be making decisions or forcing me to
• 6:37
  Speaker 1: make decisions about things like the confidentiality clause that hamper
• 6:44
  Speaker 1: my effectiveness in representing it.
• 6:46
  Speaker 2: That's all I have to say. But of course we.
• 6:48
  Speaker 3: Can have a dialogut.
• 6:54
  Speaker 5: Where did the depositions come in with all of this?
• 6:59
  Speaker 1: My strategy is this in terms of time. First of all,
• 7:03
  Speaker 1: they want to take your depositions soon, We're gonna object
• 7:05
  Speaker 1: to lots of stuff. We're not gonna let them probe
• 7:08
  Speaker 1: into anything about your past. I'm going to just order
• 7:13
  Speaker 1: you not to answer those questions. That's something else we
• 7:15
  Speaker 1: need to be on the same page. Object on the
• 7:18
  Speaker 1: basis of relevance to anything that they try to bring
• 7:21
  Speaker 1: up about your past, because we.
• 7:25
  Speaker 2: Don't want them to.
• 7:27
  Speaker 1: We don't want to turn this into a referendum on
• 7:30
  Speaker 1: Tom out House's sanity or background or background you know,
• 7:35
  Speaker 1: in terms of playwriting and acting and all that, definitely,
• 7:39
  Speaker 1: but not in terms of any problems you've had in
• 7:44
  Speaker 1: your distance distant past or whatever, or affiliations or whatever.
• 7:54
  Speaker 1: So the strategy discovery wise on our side is to
• 8:00
  Speaker 1: get all the documents that they have that might possibly
• 8:05
  Speaker 1: be relevant or over those, analyze them, see what we don't.
• 8:10
  Speaker 2: Have, and get whatever we're missing.
• 8:13
  Speaker 1: And this will include, you know, drafts of screenplays, and
• 8:17
  Speaker 1: they say that they're going to be able to show
• 8:18
  Speaker 1: through these documents independent creation, in other words, that they
• 8:23
  Speaker 1: have things in their file that will show how it
• 8:26
  Speaker 1: wasn't it wasn't the immortals that inspired any of this,
• 8:33
  Speaker 1: but the specific inspirations you name, the specific similarities that.
• 8:40
  Speaker 3: You name.
• 8:42
  Speaker 1: Stemmed from ideas that they got from other sources that
• 8:48
  Speaker 1: were gradually developed during the course of drafts or whatever.
• 8:52
  Speaker 2: You know, they'll show. They say they intimate that they're going.
• 8:57
  Speaker 1: To show some history of these ideas that developing, so
• 9:01
  Speaker 1: that it doesn't just you know, pop out in a
• 9:06
  Speaker 1: screenplay ready for production with stuff that's lifted from who
• 9:10
  Speaker 1: knows where, and then we say, well, it's lifted from
• 9:13
  Speaker 1: your screenplay.
• 9:15
  Speaker 2: So I don't know.
• 9:15
  Speaker 1: I don't know what they'll say, but we do need
• 9:17
  Speaker 1: to know because I cannot do an effective deposition of
• 9:20
  Speaker 1: anyone until I see what they're saying.
• 9:23
  Speaker 2: And this is my one shot to do an oral
• 9:26
  Speaker 2: deposition of them.
• 9:27
  Speaker 1: So it's always been a strategy to get what they've got.
• 9:32
  Speaker 2: In writing, to get you know, whatever documents they can rely.
• 9:37
  Speaker 1: On that they would use a trial to counteract our
• 9:41
  Speaker 1: case and then craft my questions around those documents.
• 9:48
  Speaker 2: So we don't have them yet.
• 9:49
  Speaker 1: Because for one thing, we're still go around circles on
• 9:53
  Speaker 1: the confidentiality stipulation. And even when they do give us
• 9:57
  Speaker 1: the documents respons to the you know that are required
• 10:01
  Speaker 1: by the initial disclosure, there may be holes and we
• 10:04
  Speaker 1: need to serve them with a discovery request for further documents.
• 10:10
  Speaker 2: All right, we're all for settling the case.
• 10:13
  Speaker 4: We figure to settle case would mean that it's legitimacy
• 10:16
  Speaker 4: attacked with that.
• 10:17
  Speaker 2: There's no problem with that at all.
• 10:19
  Speaker 1: But are you okay with if they say you're not
• 10:21
  Speaker 1: allowed to disclose the terms or amount of the settlement. Sure,
• 10:25
  Speaker 1: because if the standard confidentiality clause will say that if
• 10:28
  Speaker 1: anyone asks you about what happened with that case, you say.
• 10:32
  Speaker 4: The matter has been resolved, and that's an answer in itself,
• 10:35
  Speaker 4: and it's fine.
• 10:36
  Speaker 2: I mean, it's a big joke in the business.
• 10:37
  Speaker 4: As we're driving around a nice car obviously something happened subtle. Okay,
• 10:42
  Speaker 4: it's not a problem at all. One of my concerns
• 10:44
  Speaker 4: is the clock has been running out. We get a
• 10:48
  Speaker 4: certain period of deposition time or discovery time that's going down.
• 10:52
  Speaker 2: We don't have an option if they you know, if
• 10:55
  Speaker 2: we show that they have.
• 10:58
  Speaker 1: Stalled and we're building a record to that, we've offered
• 11:01
  Speaker 1: to sign a protective order. We just have asked them
• 11:04
  Speaker 1: to clarify one aspect of it. They have not yet
• 11:06
  Speaker 1: responded to that. So it's kind of like the clocks.
• 11:11
  Speaker 1: We're making sure that we don't delay things on our end,
• 11:16
  Speaker 1: so that we can show the judge, if necessary.
• 11:21
  Speaker 2: That the delay is caused by the ball being in
• 11:24
  Speaker 2: their core and them not responding bricking out.
• 11:26
  Speaker 1: Then if we need to get an extension because of that,
• 11:29
  Speaker 1: we'll try with them to stipulate for an extension. The
• 11:32
  Speaker 1: judge will usually sign any stipulation. It may involve continuing
• 11:36
  Speaker 1: the trial data. I may need to fly there and
• 11:37
  Speaker 1: you know, make emotion at some point to continue the
• 11:41
  Speaker 1: whole discovery schedule. What judges do, and I assume this
• 11:45
  Speaker 1: one is no exception, is they may you know, set
• 11:48
  Speaker 1: dates that try to move things along quickly so that
• 11:51
  Speaker 1: the parties don't, you know, really get a chance to
• 11:54
  Speaker 1: drag their heels and have to keep.
• 11:58
  Speaker 2: The case moving.
• 11:59
  Speaker 1: But they also recognize is that there may be circumstances
• 12:03
  Speaker 1: that come up where the parties can't meet that schedule
• 12:07
  Speaker 1: because you know, one thing leads to another, their delays
• 12:09
  Speaker 1: along the way. The judge understands that, and so he
• 12:13
  Speaker 1: will when he's given reasons to show why it can't
• 12:17
  Speaker 1: be done on the schedule that he proposed, he'll modify
• 12:20
  Speaker 1: that schedule so that I, you know, we we're just
• 12:25
  Speaker 1: doing what we can here. I mean, I'm gonna it
• 12:28
  Speaker 1: may be there's reasons in terms of logistics and timing
• 12:30
  Speaker 1: with us being in Hawaii and the two of the
• 12:33
  Speaker 1: defends being in Chicago, and I've offered a letter to
• 12:36
  Speaker 1: the other side that if there's times when of the
• 12:39
  Speaker 1: Matowskis will be in la we can do the deposition there.
• 12:43
  Speaker 2: So there may be some working around.
• 12:46
  Speaker 1: Each other's schedules that delays things a little, And right
• 12:49
  Speaker 1: now the document production is delaying things. Sam, it wouldn't
• 12:52
  Speaker 1: hurt too after this meeting if you could send our
• 12:55
  Speaker 1: way a note that we're just a reminder we're still
• 12:58
  Speaker 1: waiting to hear back from them, and we're concerned because
• 13:01
  Speaker 1: there's a type timeline on discovery. Can they respond to
• 13:04
  Speaker 1: our letter about that one clause the stipulation? So yeah,
• 13:13
  Speaker 1: we won't let you know, we won't let the time
• 13:15
  Speaker 1: right out to depose.
• 13:16
  Speaker 4: Then all right, we're looking at the picture too, back
• 13:22
  Speaker 4: and I, and we're seeing that we did some research.
• 13:25
  Speaker 4: We're just looking on the line at their attorneys twenty
• 13:28
  Speaker 4: years experience, you know, TMZ, Warner Brothers, white collar crimes, insurance,
• 13:33
  Speaker 4: the top insurance agencies, China, Guatemala.
• 13:36
  Speaker 2: Detainees on. It's unbelievable. These guys are the all stars.
• 13:40
  Speaker 4: And we think of it as like an arena and
• 13:42
  Speaker 4: we're walking in with a sword and our guys, well,
• 13:47
  Speaker 4: this is the thing I want to see where you
• 13:49
  Speaker 4: stand on, let's light on the table what our chances
• 13:52
  Speaker 4: are and what we could do to enhance our chances
• 13:55
  Speaker 4: to make this a win for us monetarily.
• 14:01
  Speaker 2: Just look at the picture together, we're bright.
• 14:03
  Speaker 4: I'm no longer suffering if I mean, I don't have
• 14:05
  Speaker 4: the effects of that stuff anymore. It's like, whatever the
• 14:08
  Speaker 4: reasons is the hope, whatever BAM's gone, laser focus now.
• 14:12
  Speaker 4: So it's like I'm really looking at things Needle Point
• 14:17
  Speaker 4: and I'm seeing that.
• 14:19
  Speaker 2: Their firm is also they clerked with Central District all
• 14:24
  Speaker 2: over the place. What do you want to well, I
• 14:25
  Speaker 2: want to lay on the table to discuss that.
• 14:28
  Speaker 3: Well, there's definitely work that Tom could do and Tom
• 14:31
  Speaker 3: Beckett could both do that would help us a lot
• 14:33
  Speaker 3: once we get it, Like if we get a whole
• 14:34
  Speaker 3: bunch of boxes of documents, for example, we've.
• 14:37
  Speaker 2: Been doing a lot of that. I mean, they put
• 14:38
  Speaker 2: together a lot of this case. They didn't do those matchups.
• 14:42
  Speaker 3: They did.
• 14:42
  Speaker 1: You know, I worked with them back and forth through
• 14:47
  Speaker 1: many many evenings together and reviews. But basically, you know,
• 14:52
  Speaker 1: they're the ones that balance stuff and put it together.
• 14:54
  Speaker 1: And you certainly can continue to do that, and we
• 14:57
  Speaker 1: will value and put at that stace.
• 15:00
  Speaker 2: You know, Tom, I cannot.
• 15:02
  Speaker 1: I would love to bring in a copyright attorney in LA.
• 15:07
  Speaker 1: We can do that one of two ways as co counsel,
• 15:11
  Speaker 1: and that's always been my goal.
• 15:14
  Speaker 3: We could do that one of two ways.
• 15:16
  Speaker 2: We could.
• 15:18
  Speaker 1: Hire someone by the hour, which I'm not going to
• 15:21
  Speaker 1: pay for, or we could get someone interested in coming
• 15:24
  Speaker 1: in on a contingency basis to share the fee, and
• 15:28
  Speaker 1: that's written into our contract that I can bring in
• 15:30
  Speaker 1: another council and share the fee with them. I do
• 15:35
  Speaker 1: not have experienced in copyright law, will do that. Since
• 15:39
  Speaker 1: the beginning, however, we've educated ourselves here as to the
• 15:45
  Speaker 1: areas that we need to understand in order to effectively
• 15:48
  Speaker 1: pursue this case. Don't feel that we're groping in the
• 15:52
  Speaker 1: dark in that arena of the law is not overly complicated,
• 15:57
  Speaker 1: and we've figured out the past and will continue to
• 16:01
  Speaker 1: refine that and figure out the aspects of this particular
• 16:04
  Speaker 1: case as it develops. We have the basic standards that
• 16:09
  Speaker 1: we're aware of that will guide our strategy in terms
• 16:12
  Speaker 1: of discovery and what we need to prove. You know,
• 16:17
  Speaker 1: you know I'm a smart lawyer. Sam's a smart lawyer.
• 16:20
  Speaker 1: We went to top law schools as well.
• 16:25
  Speaker 5: Yeah, no, no, we're not questioning that.
• 16:26
  Speaker 4: You understand what a very high As far as I
• 16:30
  Speaker 4: think mitigation, the idea that came.
• 16:32
  Speaker 6: Up, it wasn't it was an attack on you. As
• 16:36
  Speaker 6: far as imploying what team they have, it's just for me.
• 16:40
  Speaker 6: The the idea that came up with it was holy shit,
• 16:44
  Speaker 6: like they brought a nuclear Arsenal Arsenal, But I don't.
• 16:49
  Speaker 6: But but there's other cases I've seen them come forward.
• 16:51
  Speaker 6: They haven't quite packed themselves that heavy.
• 16:54
  Speaker 5: You know, which I was just thought it was just
• 16:56
  Speaker 5: very interesting.
• 16:57
  Speaker 4: Well we understand is that we have something that scares
• 17:02
  Speaker 4: them and they want to squash it like that, I said,
• 17:05
  Speaker 4: squash it. They do not want to have any chance
• 17:07
  Speaker 4: of surfacing. And so this is gonna make him look
• 17:10
  Speaker 4: really bad. You figured, I mean, Joel Silver was fired
• 17:13
  Speaker 4: when you were going to file.
• 17:15
  Speaker 2: This thing is huge to them. So you know, I
• 17:18
  Speaker 2: really don't know.
• 17:18
  Speaker 1: I got a reserve judgment on Joel Silver and what
• 17:22
  Speaker 1: lynch his fire really doubt it has to do with
• 17:24
  Speaker 1: this case. You would say, dos delusions here about the
• 17:28
  Speaker 1: impact we're having on.
• 17:32
  Speaker 6: Sorry, I guess well, as far as Joel Silver goes,
• 17:39
  Speaker 6: it's not the the whole fact that he's not with
• 17:43
  Speaker 6: them anymore and art working with him isn't really the point.
• 17:46
  Speaker 6: The point is is that he was a key pin
• 17:49
  Speaker 6: to the whole situation of how the witch Hawsky's in
• 17:53
  Speaker 6: our eyes got the script because he was the one there.
• 17:55
  Speaker 6: He's the one with the access to the database. He
• 17:57
  Speaker 6: was the one specifically working with them. That is why
• 18:01
  Speaker 6: he's important. It has nothing to do with anything that
• 18:03
  Speaker 6: happened even a year ago, two years ago. We're talking
• 18:05
  Speaker 6: about in nineteen ninety whatever, three, when all of this
• 18:09
  Speaker 6: ninety four, when all of.
• 18:10
  Speaker 5: This was going on, he was there.
• 18:12
  Speaker 6: That's why I feel, and that we all feel that
• 18:15
  Speaker 6: he's just one of the most important people the deposition.
• 18:18
  Speaker 2: Yeah, I I don't disagree, it's just the tining of it.
• 18:24
  Speaker 3: Yeah, I can't.
• 18:25
  Speaker 2: I don't want it to go through without seeing the
• 18:27
  Speaker 2: file cause then grew up in the dark. Do you
• 18:32
  Speaker 2: not agree?
• 18:33
  Speaker 6: Yeah, I mean, I definitely agree that we need to
• 18:36
  Speaker 6: see what papers they have and what they got going on.
• 18:39
  Speaker 5: But I mean, it's just I think on all of
• 18:42
  Speaker 5: our terms.
• 18:43
  Speaker 6: I mean, it's definitely we've talked a little bit about
• 18:45
  Speaker 6: what what we have going on, but I don't think
• 18:47
  Speaker 6: there's been the clarity.
• 18:48
  Speaker 2: Tokay, put that disagreement aside.
• 18:52
  Speaker 1: Okay, Beca's making the point that she's reminding me why
• 18:55
  Speaker 1: Joel Silver is so important, And I agree that he's
• 18:59
  Speaker 1: in for area put important. We really don't know, but
• 19:02
  Speaker 1: I'm certainly wanting to explore that.
• 19:04
  Speaker 2: And all I'm saying is we need.
• 19:05
  Speaker 1: To see the files, their files first to find out
• 19:10
  Speaker 1: where he comes in.
• 19:11
  Speaker 2: You know, I agree what you're talking about.
• 19:14
  Speaker 4: We needed to post Joel Silver to find out what
• 19:16
  Speaker 4: they're so afraid of. He is a loose cannon that
• 19:19
  Speaker 4: speaks off. It's all over. It's well known around the world.
• 19:22
  Speaker 4: He just speaks off. His spews, that's what he's known for.
• 19:25
  Speaker 2: He was involved in this thing, he said, even that
• 19:27
  Speaker 2: he submitted it to Warner Bros.
• 19:29
  Speaker 3: Ninety four.
• 19:30
  Speaker 4: It's on federal record on the sworn testimony. Also, yeah,
• 19:34
  Speaker 4: the brothers are claiming it. They had a fallout. That's
• 19:36
  Speaker 4: common knowledge in the world. We've got to we've got
• 19:39
  Speaker 4: the best setup in situation in the world. And if
• 19:42
  Speaker 4: we want to debate whether it's a grandiose delusion, whether
• 19:45
  Speaker 4: he's involved, I mean, seriously, it's totally.
• 19:48
  Speaker 2: Please not debate that, but let's find out. Now here's
• 19:51
  Speaker 2: what I like you to do in terms of Jill Soil.
• 19:53
  Speaker 1: Once we get the documents, I'd like you to write
• 19:55
  Speaker 1: out what you've been able to find from your investigation
• 19:58
  Speaker 1: about things like he's said about his history with the matrix,
• 20:02
  Speaker 1: all the statements he's made you hopefully drier litigation or whatever,
• 20:08
  Speaker 1: and then I can, you know, have those ready to
• 20:12
  Speaker 1: question him about when we do his deposition.
• 20:16
  Speaker 3: Now they would like to, you know, I'll tell you.
• 20:19
  Speaker 1: You know, you've told me many times your theories of
• 20:23
  Speaker 1: how Warner Brothers is reacting to this. I'll tell you
• 20:26
  Speaker 1: my theory, and then let's just agree to put it
• 20:29
  Speaker 1: aside because we'll find out later and it doesn't really matter.
• 20:33
  Speaker 1: But my theory is that Warner Brothers at this point
• 20:37
  Speaker 1: sees you as another Sophia Stuart, a fly that they
• 20:43
  Speaker 1: need to just rush away, and they're going to win
• 20:47
  Speaker 1: this case on summary judgment and be done with it.
• 20:52
  Speaker 1: And if they will not make you any offers until
• 20:54
  Speaker 1: they try their emotion for summary judgment and they're improves
• 20:58
  Speaker 1: the documents, they probably can't get out of having their
• 21:02
  Speaker 1: guys sit for depositions. And then they will make the
• 21:07
  Speaker 1: case to the judge that that even viewing the facts
• 21:13
  Speaker 1: and the light most favorable to us, no reasonable jury
• 21:16
  Speaker 1: could find that they copied you, and asked the judge
• 21:22
  Speaker 1: to dismiss the case and not let it go to trot.
• 21:25
  Speaker 3: And they hire a good law firm.
• 21:26
  Speaker 2: They hired a copyright law firm who.
• 21:29
  Speaker 1: Really knows their stuff in this area, and I'm sure
• 21:32
  Speaker 1: they've worked with that law firm before and they.
• 21:38
  Speaker 2: Have confidence in that firm.
• 21:40
  Speaker 1: Of course, they're gonna hire, you know, a high powered
• 21:45
  Speaker 1: LA law firm to do this. They're devoting that firm
• 21:49
  Speaker 1: has free license to devote lots of resources to it.
• 21:52
  Speaker 1: They have several attorneys on the job, and that's pretty
• 21:55
  Speaker 1: typical when the corporation hires.
• 21:57
  Speaker 2: A big law firm. That surely just a lot of
• 22:01
  Speaker 2: waste of time.
• 22:02
  Speaker 1: But the companies don't mind it because they just it's
• 22:06
  Speaker 1: an expense of doing business to pay these law firms
• 22:09
  Speaker 1: to do it right, And you don't mind spending some
• 22:12
  Speaker 1: extra money for three attorneys to be basically doing the
• 22:14
  Speaker 1: same thing, although it doesn't.
• 22:16
  Speaker 2: Really get them anywhere.
• 22:18
  Speaker 3: We got two.
• 22:18
  Speaker 1: Attorneys that are both overseeing and looking at this and
• 22:22
  Speaker 1: working together.
• 22:23
  Speaker 2: We're not too far behind them in that respect.
• 22:27
  Speaker 3: And we got you guys are secret.
• 22:29
  Speaker 1: Weapon and you're gonna you've done an incredible background job
• 22:32
  Speaker 1: on this.
• 22:32
  Speaker 2: You're going to continue to hunt.
• 22:34
  Speaker 1: Up stuff and I think we're equipped to go ahead
• 22:39
  Speaker 1: to ahead of them.
• 22:40
  Speaker 2: If we survived most of the Summery judgment.
• 22:42
  Speaker 1: Then I think we can bring in a big copyright firm,
• 22:46
  Speaker 1: planoffs copyright firm in LA on contingency, and it's probably
• 22:50
  Speaker 1: a good idea to co counsel with them for the
• 22:52
  Speaker 1: trial of the case and settlement negotiations going forward. I
• 22:55
  Speaker 1: don't think we can do that now. I don't think
• 22:57
  Speaker 1: we can get one interested. You've got to go it
• 23:01
  Speaker 1: alone at this point.
• 23:03
  Speaker 6: Yeah, no, we know there's Yeah, nobody's Tom. You wouldn't
• 23:06
  Speaker 6: touch anything at this point, Tom.
• 23:09
  Speaker 3: You would actually be suggesting to go and start deposing
• 23:13
  Speaker 3: jewel silver without any preparation.
• 23:15
  Speaker 2: Is that what you think? I can make it within
• 23:16
  Speaker 2: the time clock, and that's our way.
• 23:18
  Speaker 1: To do it, Yes, because I think that's not necessarily
• 23:21
  Speaker 1: we will be within the time but after getting a.
• 23:24
  Speaker 4: Production because I felt, yes, I felt we had enough
• 23:28
  Speaker 4: information to question him on. And obviously they they Sophia Stewarts,
• 23:32
  Speaker 4: couldn't even get him to the table.
• 23:34
  Speaker 2: They kept finding a way that they succeeded.
• 23:36
  Speaker 4: In keeping him shielded from being disposed and it was
• 23:39
  Speaker 4: her fault for not using the time and discovery to
• 23:41
  Speaker 4: do it.
• 23:41
  Speaker 3: Well, I there's no real way to keep somebody sheltered
• 23:45
  Speaker 3: from the deposition. If there if you can, if they're
• 23:48
  Speaker 3: within you know, the United States, and they can accept
• 23:51
  Speaker 3: service through this law firm, then yeah, they're representing it.
• 23:57
  Speaker 2: So here's how it put it out.
• 23:58
  Speaker 4: Tom's question for I think may did the imposing firm
• 24:02
  Speaker 4: request any sense and honestly any sense at all that
• 24:05
  Speaker 4: they would rather, you know, not bother with Joel Silver being.
• 24:10
  Speaker 1: All I've sold them, we're going to propose all the planets,
• 24:12
  Speaker 1: all the names.
• 24:14
  Speaker 3: Joel Silver and not a defendant. Yes, yes, that's right.
• 24:19
  Speaker 1: So uh yeah, So what will happen is this They'll
• 24:24
  Speaker 1: hopefully you know, will resolve this confidentiality things.
• 24:26
  Speaker 2: Then they'll produce the documents.
• 24:29
  Speaker 1: We'll look at the clock, you know, in terms of
• 24:31
  Speaker 1: when we can do Silver's deposition, how much notice we
• 24:34
  Speaker 1: need to give, and when we expecting to get Exam's
• 24:37
  Speaker 1: already drafted. Working with me and based on your input,
• 24:41
  Speaker 1: we've already drafted our request for a production of documents.
• 24:44
  Speaker 2: We served that after we get their initial.
• 24:47
  Speaker 3: That was disclosures. That was a great suggestion.
• 24:50
  Speaker 2: For example, the.
• 24:50
  Speaker 3: One that you after you talk with I think that
• 24:53
  Speaker 3: is or something like that dens about the nondisclosure agreement
• 24:58
  Speaker 3: for the production team. That was really good. So those
• 25:00
  Speaker 3: types of things are very useful. And that's going into
• 25:03
  Speaker 3: the certain.
• 25:04
  Speaker 1: Timeline is we get the confidentiality stip finalized that they
• 25:08
  Speaker 1: have to respond to our email. We get that stip
• 25:11
  Speaker 1: worked out any more details in language final lines, They
• 25:13
  Speaker 1: give us the initial disclosures.
• 25:15
  Speaker 2: That the court rules require. We lift those over quickly
• 25:18
  Speaker 2: to see where we think there are holes.
• 25:20
  Speaker 1: We amend our requests for production and get that filed
• 25:26
  Speaker 1: and we can then tell and then that has a
• 25:28
  Speaker 1: timeline on like thirty days they have to give us everything.
• 25:33
  Speaker 2: We schedule Joel Silver's.
• 25:34
  Speaker 1: Deposition or of all three depositions, we just send out
• 25:37
  Speaker 1: a notice of deposition that they're going to be done,
• 25:39
  Speaker 1: you know, maybe three weeks after the the response to
• 25:46
  Speaker 1: our quest for production is due, so they have a
• 25:49
  Speaker 1: time when.
• 25:50
  Speaker 2: Those depositions are scheduled. It's within the depositions schedule.
• 25:54
  Speaker 1: If that's a problem, if either side, you know, if
• 25:59
  Speaker 1: they can't make their witnesses can't make it, it's not
• 26:01
  Speaker 1: a convenient time to depose them whatever, then we say, okay,
• 26:06
  Speaker 1: well we can postpone that. Or if they need more
• 26:09
  Speaker 1: time to produce documents or something, then we say, well
• 26:11
  Speaker 1: we can postpone the depositions, but of course we've got
• 26:14
  Speaker 1: to do a stipulation for the judge's approval, and this
• 26:17
  Speaker 1: may affect the trial date as well. So then we
• 26:21
  Speaker 1: you know, work it out between council as necessary and
• 26:24
  Speaker 1: go to the court or the suggestion and most likely,
• 26:27
  Speaker 1: you know, if we lay it out for the judge,
• 26:29
  Speaker 1: he'll approve it in a written stipulation any modification that schedule.
• 26:33
  Speaker 1: But if we don't have them, if the judge won't
• 26:35
  Speaker 1: or if you know, we can't get them modified because
• 26:37
  Speaker 1: the other side doesn't content, whatever, then we just have
• 26:40
  Speaker 1: to go ahead with the depositions, make those guys show up.
• 26:43
  Speaker 1: And if they don't show up there and contempt to
• 26:46
  Speaker 1: court and we do get a continuance.
• 26:49
  Speaker 2: Can the judge do anything contrary to that? I mean,
• 26:51
  Speaker 2: since we judge, well, I mean, what can we do.
• 26:55
  Speaker 1: We should be aware of we can they can refuse
• 26:58
  Speaker 1: to grant extensions.
• 26:59
  Speaker 2: It will protect.
• 27:00
  Speaker 1: Ourselves against that, and just try to be prepared to
• 27:04
  Speaker 1: go with a certain date in case the judge denies it.
• 27:07
  Speaker 2: But we should know soon enough that we can plan
• 27:10
  Speaker 2: around that.
• 27:10
  Speaker 3: I mean, if the judge is very unreasonable with good
• 27:13
  Speaker 3: appealing and the question for you.
• 27:15
  Speaker 4: On that very soon throws out your case based on
• 27:17
  Speaker 4: some of my procedural thing or whatever, then we're making
• 27:20
  Speaker 4: our record.
• 27:21
  Speaker 2: That's right, you know, we have these emails.
• 27:23
  Speaker 4: But this is the other thing I wanted to share
• 27:25
  Speaker 4: is that I'm looking through their biographies and they're quite
• 27:28
  Speaker 4: extensive clerking with judges in Central District. And so it's
• 27:31
  Speaker 4: like if one of their attorneys, which I'm sure we're
• 27:34
  Speaker 4: going to find, clerk with this particular judge, he's brand new.
• 27:39
  Speaker 2: He's brand new.
• 27:40
  Speaker 3: I mean, it's not cloking doesn't work that way.
• 27:42
  Speaker 4: I know it can't be, but I wish it did,
• 27:45
  Speaker 4: because it's like, I mean, if you're clerking with somebody,
• 27:47
  Speaker 4: you're gonna.
• 27:49
  Speaker 3: I mean clerking. If you're suggesting that if somebody clerks
• 27:52
  Speaker 3: with the judge, then they can sort of win them over.
• 27:55
  Speaker 2: There's a conflict of interest. I would imagine probably.
• 27:57
  Speaker 3: Not, but you know, because I mean unless you actually
• 28:03
  Speaker 3: acquired knowledge about a specific case, in which case there's
• 28:05
  Speaker 3: a direct conflict of interest. Just that personal connection is
• 28:08
  Speaker 3: not allowed to.
• 28:09
  Speaker 2: Influence a judge.
• 28:10
  Speaker 3: And that's a very serious ethical violation, and judges are
• 28:12
  Speaker 3: careful about that, and if they're not, then there's definitely
• 28:16
  Speaker 3: complaints to be made, and.
• 28:17
  Speaker 2: We'll just keep eyes out.
• 28:18
  Speaker 4: Yeah, what I would like and when you stay your
• 28:24
  Speaker 4: thing when you first started. We have one that we
• 28:28
  Speaker 4: wish too, and it's just basic human request is that
• 28:33
  Speaker 4: faith in the case will sometimes help push it over
• 28:38
  Speaker 4: the hump when the hills come.
• 28:40
  Speaker 2: So if they see you have faith in us in
• 28:43
  Speaker 2: our case.
• 28:44
  Speaker 4: When you're dialoguing with them, that's gonna help our case
• 28:47
  Speaker 4: significantly because things are gonna come through or they're gonna
• 28:50
  Speaker 4: spot it. And they're smart, they know how to read people.
• 28:53
  Speaker 4: So we're asking for a look at the whole picture again,
• 28:58
  Speaker 4: look at the possibility that like Joe Silver and these
• 29:01
  Speaker 4: other things actually could be legit mustn't. Let's not be
• 29:04
  Speaker 4: surprised later and go oh, wow, really was happening.
• 29:06
  Speaker 2: It really did happen.
• 29:07
  Speaker 4: Wow, let's go ahead and go on the basis of
• 29:10
  Speaker 4: this happened, postpone the disbelief, and then let's see if
• 29:16
  Speaker 4: we're right.
• 29:17
  Speaker 1: Okay, I agree, And by the way, I misspoke.
• 29:20
  Speaker 2: Klausner is not a brand new.
• 29:21
  Speaker 1: That he was appointed by Bush, so but it was
• 29:24
  Speaker 1: right toward the end of Bush's term. But my point
• 29:26
  Speaker 1: is the senior counsel in their firm didn't clerk for him.
• 29:30
  Speaker 1: Certainly Linda Burrows his handly the case it may be,
• 29:35
  Speaker 1: who knows if Arwin.
• 29:36
  Speaker 2: Or the other guy may have.
• 29:39
  Speaker 4: Yeah, Lynda Burrows is I mean, she's the top. Looking
• 29:42
  Speaker 4: at their firm credentials, they put the biggest guns first.
• 29:44
  Speaker 4: What I've seen in the past is they put the
• 29:46
  Speaker 4: smaller guns first to play.
• 29:48
  Speaker 2: Down the importance of it, and then they bring the
• 29:50
  Speaker 2: big guns in.
• 29:51
  Speaker 3: So far I believe and Arn's just a kind of
• 29:54
  Speaker 3: young Well that's usually how you do it.
• 29:55
  Speaker 2: You don't understand you bring the small down.
• 30:00
  Speaker 4: Then is the big initial conversations with her, her backgrounds.
• 30:05
  Speaker 3: They're giving almost everything to our wine to handle right
• 30:09
  Speaker 3: and ours right, So that would make sense.
• 30:13
  Speaker 2: That would be she keeps she keeps side. I'll have
• 30:16
  Speaker 2: to get back to you because she has to live. Yeah,
• 30:20
  Speaker 2: that makes sense.
• 30:21
  Speaker 3: Is the other guy, Craig Craig Messenger.
• 30:23
  Speaker 2: Messenger, Yeah, very impressive. I mean they've picked.
• 30:27
  Speaker 4: Exactly what they needed, of course, But what what the
• 30:30
  Speaker 4: idea I wanted to plant in our minds was we
• 30:35
  Speaker 4: don't throw away the cards we have whatever that translates to,
• 30:38
  Speaker 4: and whatever procedures we have to follow in the process
• 30:40
  Speaker 4: to meet ends that they require us to meet. We
• 30:43
  Speaker 4: keep in mind we don't throw away the cards we have,
• 30:46
  Speaker 4: and we also ask ourselves the questions, what are they
• 30:48
  Speaker 4: most afraid of? What are they most concerned about being
• 30:52
  Speaker 4: maintained in our favor? And sometimes it's all we have,
• 30:57
  Speaker 4: which is some things that we don't want to be labeled,
• 31:04
  Speaker 4: you know, undisclosed. You can't be Confidentiality can't be used.
• 31:08
  Speaker 4: If we pay careful eye to what we don't the
• 31:11
  Speaker 4: playing cards we don't want to give away, then chances
• 31:14
  Speaker 4: are we'll bring them to the table a little more quicker,
• 31:17
  Speaker 4: a little more attentive, and a little more.
• 31:19
  Speaker 3: Part of the confidentiality. You can also insist on certain
• 31:23
  Speaker 3: documents being confidential if you really, if you have for
• 31:26
  Speaker 3: reason to say that they should be. Okay, So you know.
• 31:30
  Speaker 2: But that's just the mindset. I just think a mindset
• 31:33
  Speaker 2: goes a long way. Maybe it's the performance field and writing,
• 31:36
  Speaker 2: but it's just you get.
• 31:37
  Speaker 4: A sense of how humanity works together in business too,
• 31:41
  Speaker 4: and it's like, what is most important to their side?
• 31:44
  Speaker 2: What are they most.
• 31:45
  Speaker 4: Afraid of being revealed or lost? What do they want
• 31:48
  Speaker 4: us to play out of our hand.
• 31:50
  Speaker 3: Most Yeah, that's an interesting question, Sam.
• 31:52
  Speaker 1: I think we should try to figure out before times deposition.
• 31:57
  Speaker 2: I love please the question whether they can.
• 32:02
  Speaker 1: Ask him questions about what he perceives as the similarities
• 32:09
  Speaker 1: in the script. I mean, we've laid it out in
• 32:12
  Speaker 1: our complaint, but there are a few things or the
• 32:17
  Speaker 1: reasons he believes.
• 32:19
  Speaker 2: Let me put it this way, not similarities, but the
• 32:21
  Speaker 2: reasons he believes that they've.
• 32:26
  Speaker 1: Stolen, that they've borrowed from his work. And I'm a
• 32:33
  Speaker 1: little concerned because I want to surprise them with a
• 32:36
  Speaker 1: few things. The thing we talked about the other day, Sam,
• 32:40
  Speaker 1: about you know, the data sheet about NEO having surprising
• 32:47
  Speaker 1: similarities to Tom's background. You know a few other things
• 32:53
  Speaker 1: we may look at. They sleep my mind right now.
• 32:56
  Speaker 1: But Tom and Becca have some.
• 33:00
  Speaker 2: Discuss that we're.
• 33:00
  Speaker 5: Kind of the Hitler images.
• 33:02
  Speaker 3: And what is your what is your theory? Why would
• 33:06
  Speaker 3: they not be able.
• 33:06
  Speaker 1: To ask, well, is it within his I mean he's
• 33:14
  Speaker 1: a he's a witness.
• 33:18
  Speaker 2: Yeah, that's what I'm not sure it is.
• 33:22
  Speaker 1: But it's not necessarily within his testimony as a witness.
• 33:27
  Speaker 1: It's not something he has knowledge of that anyone else does.
• 33:31
  Speaker 1: I can present it at trial, I can well present.
• 33:36
  Speaker 3: That with very simple facts. You could say that that's
• 33:39
  Speaker 3: what I think because because I gave.
• 33:41
  Speaker 1: My inscription, right, But they're going to try to probe
• 33:46
  Speaker 1: for each and everything.
• 33:48
  Speaker 3: But you can just repeat that particular story if you
• 33:50
  Speaker 3: go by the facts I sent it in on this day.
• 33:52
  Speaker 8: And so they'll say, yeah, okay, mister else we get
• 33:56
  Speaker 8: that and there and you allege that there's similarities in
• 34:00
  Speaker 8: the script that indicate that we copied you, right, and
• 34:03
  Speaker 8: you say yes, and they'll say, what are those uh similarities?
• 34:08
  Speaker 1: What are these alleged clues that show we copied you?
• 34:11
  Speaker 1: That's the question.
• 34:12
  Speaker 4: I don't wanna have to give a complete answer because well,
• 34:15
  Speaker 4: because they've got maybe four or five and then they're gonna.
• 34:17
  Speaker 2: Cap it off with is are these all the similarities?
• 34:21
  Speaker 4: Yeah, And then they're trying to get me to say yes,
• 34:23
  Speaker 4: that's all instead of saying something like to the best
• 34:26
  Speaker 4: of my knowledge at this.
• 34:27
  Speaker 1: Time, no, No, I don't even want to say that
• 34:29
  Speaker 1: because that would be fair.
• 34:30
  Speaker 4: They're gonna try to set it at the campstone, so
• 34:32
  Speaker 4: there's no other ones that missing.
• 34:34
  Speaker 1: I I wanna be able to object to you testify
• 34:37
  Speaker 1: as to the similarities well.
• 34:41
  Speaker 3: You you can say there was there were extensive similarities
• 34:43
  Speaker 3: that I wrote.
• 34:44
  Speaker 2: Down my complaint. Yeah, And then they'll say are there
• 34:47
  Speaker 2: any others? So they're gonna try to say, you can
• 34:52
  Speaker 2: say possibly.
• 34:53
  Speaker 5: Possibly.
• 34:54
  Speaker 4: Well, then they'll say, oh, what are they We're still
• 34:56
  Speaker 4: discovering them.
• 35:01
  Speaker 1: And then they'll say what are those all the ones
• 35:03
  Speaker 1: that you're aware of at this time? And then you'll
• 35:06
  Speaker 1: have to say no, and they'll say what are the
• 35:08
  Speaker 1: others that you're aware of at this time? And then
• 35:10
  Speaker 1: I'll say, object to that question, and what are the
• 35:14
  Speaker 1: grounds for my injection?
• 35:20
  Speaker 2: She wanted that one. I mean, I'm not gonna blame
• 35:23
  Speaker 2: that really similarity.
• 35:24
  Speaker 1: If you characterize it that way, it's a clue, it's.
• 35:27
  Speaker 2: A reason to believe you can.
• 35:31
  Speaker 1: I mean, we want him to say that's a matter
• 35:35
  Speaker 1: to be presented as argument, not I.
• 35:38
  Speaker 2: Mean, see, here's the thing. His job as a witness
• 35:42
  Speaker 2: is to go into court and give facts. I'm not
• 35:44
  Speaker 2: gonna ask on the stand, did you see anything in.
• 35:49
  Speaker 1: The screenplay or screenshots that gave me reason to believe?
• 35:57
  Speaker 2: That's not time's role as a witness.
• 35:59
  Speaker 1: I I'm going to get the other side to produce
• 36:02
  Speaker 1: I'm going to have as an exhibit, and so the
• 36:04
  Speaker 1: other side the screenshot of Thomas Allhouse, Thomas Anderson and
• 36:12
  Speaker 1: Central whatever, all of those things, and then I'm going
• 36:17
  Speaker 1: to bring out, you know there that screen.
• 36:20
  Speaker 2: I'm going to interview them.
• 36:21
  Speaker 1: With the depositions about where that, where those ideas, where
• 36:25
  Speaker 1: those names come from, came from, and how they came
• 36:28
  Speaker 1: up with that screenshot. And I don't want them to
• 36:31
  Speaker 1: know about it before the depositions.
• 36:33
  Speaker 2: But the point is.
• 36:33
  Speaker 1: A trial, It's not going to be any knowledge that
• 36:37
  Speaker 1: Tom personally has, So his role as a witness is
• 36:42
  Speaker 1: a fact witness. I'm the one that argues the case,
• 36:45
  Speaker 1: and I'm not going to ask him about things that
• 36:50
  Speaker 1: are outside of his knowledge that I can prove through
• 36:53
  Speaker 1: the other side.
• 36:54
  Speaker 3: Like you could say privilege work product, because basically he's
• 36:58
  Speaker 3: started as a pro se a plantiff and the things
• 37:02
  Speaker 3: that he wrote down in his complaints were based on
• 37:04
  Speaker 3: work product, they weren't based on his personal knowledge.
• 37:08
  Speaker 2: So essentially, aly he may have filed as a pro
• 37:11
  Speaker 2: say plane.
• 37:12
  Speaker 1: If but they still remain well that's interesting, Okay, think
• 37:15
  Speaker 1: about that.
• 37:16
  Speaker 2: Think about that.
• 37:17
  Speaker 1: If the pro say, I mean, look it up please,
• 37:19
  Speaker 1: If pro state Planet is gonna have work product.
• 37:21
  Speaker 2: I've only heard it being attorneys.
• 37:23
  Speaker 3: They're not his personal knowledge. They're based on they're based on.
• 37:27
  Speaker 1: His work's done work as an attorney on this case.
• 37:30
  Speaker 2: You're right, you're right.
• 37:31
  Speaker 1: That's a good point. And and we're doing work as
• 37:35
  Speaker 1: an attorney. And it doesn't really matter where the idea originated.
• 37:38
  Speaker 2: But if he's.
• 37:40
  Speaker 4: Gotten the facts the dialogue, that's protected.
• 37:47
  Speaker 1: Okay, So I'll just say, you know, this deposition should
• 37:50
  Speaker 1: be limited to facts that Tom has knowledge of, not
• 37:55
  Speaker 1: work as a witness, not work product, not strategy, not
• 38:00
  Speaker 1: legal arguments, not things that you know we might argue try.
• 38:05
  Speaker 3: I mean, you can you They might be able to
• 38:07
  Speaker 3: ask you, when you first watched this film and you
• 38:09
  Speaker 3: hated watching it, what was the first thing that struck you?
• 38:14
  Speaker 3: And that is a legal question you'd I mean a
• 38:17
  Speaker 3: lawful question. You'd have to answer that. Probably why because
• 38:22
  Speaker 3: that's asking about your facts.
• 38:24
  Speaker 2: It might be relevant to statue of limitations or something.
• 38:27
  Speaker 3: Yeah, so you would, maybe Sam well, because it's his
• 38:36
  Speaker 3: to that extent, it's his factual knowledge of copying. And
• 38:41
  Speaker 3: to that extent, he's being a witness as a as
• 38:44
  Speaker 3: a factiveness, that's not something that he did research on
• 38:49
  Speaker 3: is something that he saw that that struck him immediately
• 38:54
  Speaker 3: as a first person.
• 38:55
  Speaker 1: Viewer, So why it relevant a trial to any dispute? Actually,
• 39:02
  Speaker 1: she's the one.
• 39:03
  Speaker 2: The one disputed issue at trial basically is he did
• 39:08
  Speaker 2: Warner Brothers copy Tom's work.
• 39:11
  Speaker 1: And the sub questions are are there substantial similarities?
• 39:16
  Speaker 3: But they also would probably be based on what the
• 39:20
  Speaker 3: average reasonable viewer would see as a similar.
• 39:26
  Speaker 2: Similar And so.
• 39:27
  Speaker 3: If Tom, when Tom first viewed the film, he was
• 39:30
  Speaker 3: viewing it as an ordinary viewer, distracted ordinary viewer. Yeah,
• 39:35
  Speaker 3: and to that extent, he was a fact witness to
• 39:38
  Speaker 3: the types of things that would trigger a reaction of
• 39:41
  Speaker 3: similarity to some he was.
• 39:43
  Speaker 1: In ordinary view He had his own mindset anyway, And
• 39:46
  Speaker 1: I don't think that they can convert him into a
• 39:49
  Speaker 1: witness as to that. I mean they contrive that he can.
• 39:52
  Speaker 1: I guess that questions harmless. You just say you can't remember.
• 39:56
  Speaker 1: There are a lot of things I.
• 39:57
  Speaker 4: Saw that confiden that condition later down the road. If
• 40:01
  Speaker 4: you play that confidential on the condition doesn't hurt us
• 40:05
  Speaker 4: as a family, it doesn't hurt us as.
• 40:07
  Speaker 2: A legal team.
• 40:08
  Speaker 4: But it sure means that you would answer that question
• 40:12
  Speaker 4: as an ordinary viewer.
• 40:13
  Speaker 2: Tom wasn't an ordinary viewer.
• 40:17
  Speaker 5: When you're talking about the party, you weren't even watching it.
• 40:20
  Speaker 2: You talked about the party, No, it was it was yeah,
• 40:23
  Speaker 2: it was a group of the four people. But yeah,
• 40:25
  Speaker 2: I wasn't really paying attention. But the thing was, I'm
• 40:28
  Speaker 2: just throwing on the car.
• 40:29
  Speaker 4: But another card, that card that we keep going back
• 40:32
  Speaker 4: and forth with or shoving aside, is that if needed
• 40:35
  Speaker 4: to be if ordinary viewer became a question, and it's like, well,
• 40:38
  Speaker 4: if Tom had this condition at the time documented, then
• 40:42
  Speaker 4: he's not an ordinary viewer.
• 40:45
  Speaker 2: It's an easy play. No condition, well not seventy effects
• 40:52
  Speaker 2: of it now.
• 40:52
  Speaker 4: But the thing is that then, yeah.
• 40:57
  Speaker 2: Anyway, we don't need that, right are you? Are you
• 41:01
  Speaker 2: willing to stay away from making this case about.
• 41:04
  Speaker 4: Your It's not about that I'm trying to put any
• 41:06
  Speaker 4: car in your table, i'd are.
• 41:10
  Speaker 2: You willing to go along with my strategy of avoiding that, Well,
• 41:13
  Speaker 2: it's just trying to contribute to the strategy.
• 41:16
  Speaker 1: So my decision and its final decision, as far as
• 41:19
  Speaker 1: what I think is the best strategy.
• 41:20
  Speaker 2: Is we're going to keep out any mention of.
• 41:24
  Speaker 1: Any psychological problems or struggles that you've had my understanding.
• 41:30
  Speaker 4: What fine, My understand was that you were going to
• 41:33
  Speaker 4: elicit that or use that as a protected thing that
• 41:36
  Speaker 4: was going to be entered in as you even gave
• 41:38
  Speaker 4: some dialogue with Sam about you know, will want or
• 41:41
  Speaker 4: it is this, or we'll look at doing it this.
• 41:43
  Speaker 1: Way if we have if it has to come in,
• 41:45
  Speaker 1: then we got to limit it and make sure it
• 41:47
  Speaker 1: doesn't you go to the jury.
• 41:49
  Speaker 4: Fine, but the whole edition was it was regarding you
• 41:52
  Speaker 4: snational limitations, things like that.
• 41:53
  Speaker 2: You said like, well, here's this thing we'll just put in. Yeah, no,
• 41:56
  Speaker 2: I think that's.
• 41:58
  Speaker 5: Only the first one.
• 41:59
  Speaker 6: I mean the second two movies, it's not even.
• 42:03
  Speaker 2: A first one. Limitations.
• 42:07
  Speaker 1: Then we can look at whether we need to defend
• 42:12
  Speaker 1: with any of that.
• 42:14
  Speaker 6: My opinion about the first one in the first place
• 42:17
  Speaker 6: is that there aren't enough that you couldn't as an
• 42:20
  Speaker 6: ordinary viewer, anybody just watch the first one.
• 42:24
  Speaker 5: Okay, that's that.
• 42:26
  Speaker 6: It wasn't until the two and three and then you
• 42:29
  Speaker 6: look at it as a package that literally going through the
• 42:32
  Speaker 6: first one, I had to go through it frame by
• 42:34
  Speaker 6: frame to find the little thing yeah that were in there.
• 42:38
  Speaker 1: I mean it's really were they hard for them to
• 42:42
  Speaker 1: use to say, well, yeah, we ripped, but you should
• 42:45
  Speaker 1: have noticed earlier.
• 42:49
  Speaker 5: You could watch the original and go oh yeah, no.
• 42:52
  Speaker 2: It's even have to go there.
• 42:54
  Speaker 1: I get what you're saying, but I don't think that
• 42:56
  Speaker 1: the case will even turn out to be about that
• 42:59
  Speaker 1: at all, because it would be just too too much
• 43:02
  Speaker 1: talking out of both sides of their mouth.
• 43:04
  Speaker 2: If they argue it that way, you see what I'm saying.
• 43:06
  Speaker 2: They can't.
• 43:07
  Speaker 3: They can't say.
• 43:08
  Speaker 1: And it's obvious matrix that it's a copy of the Immortals,
• 43:13
  Speaker 1: but these other two they're not copies.
• 43:15
  Speaker 2: Of the right something on throne.
• 43:17
  Speaker 6: Yeah, well, I mean, and that's just then it comes
• 43:20
  Speaker 6: down because I forget what the original question was as
• 43:23
  Speaker 6: far as whether or not it's a normal viewer that
• 43:27
  Speaker 6: you would have noticed.
• 43:29
  Speaker 2: I will think about.
• 43:29
  Speaker 1: That some more, and Sam will look up a little
• 43:32
  Speaker 1: about work product and make sure we're ready to voice
• 43:35
  Speaker 1: the appropriate direct objections at your deposition.
• 43:38
  Speaker 2: That's our job, Tom.
• 43:41
  Speaker 1: We're going to try to really limit your deposition, and
• 43:43
  Speaker 1: we're going to think about what questions.
• 43:46
  Speaker 2: Sam.
• 43:47
  Speaker 1: You're free to start on brainstorming this on your own,
• 43:50
  Speaker 1: on paper or on the computer, what questions they are
• 43:53
  Speaker 1: likely to ask of you or categories of questions and
• 43:58
  Speaker 1: which ones we want to answer, which ones we want
• 44:00
  Speaker 1: to object to, and why what basis we have for objecting?
• 44:05
  Speaker 6: Okay, because I think the paper trowl is the strongest
• 44:11
  Speaker 6: factual thing that's going on.
• 44:12
  Speaker 5: It's just the fact that it was submitted.
• 44:15
  Speaker 1: That's totally going to answer everything about the background. I
• 44:19
  Speaker 1: mean that is that is arguably the only relevant subject
• 44:23
  Speaker 1: for your testimony. Now there's a there's another subject that
• 44:29
  Speaker 1: we have to think hard about whether we want to
• 44:31
  Speaker 1: get into and how.
• 44:32
  Speaker 2: Much we're going to be willing to say.
• 44:34
  Speaker 1: Which is your thought process in creating the movies and
• 44:40
  Speaker 1: creating the script and what it is in your background
• 44:47
  Speaker 1: that inspired things. Now, let's talk about that a little.
• 44:52
  Speaker 1: On the one hand, on the negative.
• 44:54
  Speaker 2: Side, that could mean.
• 44:59
  Speaker 1: That it'll opens the door to problems that you've had
• 45:04
  Speaker 1: in your life.
• 45:06
  Speaker 2: On the positive.
• 45:08
  Speaker 1: Side, it could mean it could mean we're able to
• 45:14
  Speaker 1: show that there was that it wasn't that these ideas
• 45:23
  Speaker 1: don't just we're able to use that as an example
• 45:25
  Speaker 1: of how these ideas don't just spring from Zerthol fully formed,
• 45:30
  Speaker 1: but their product of you know, influences in the background and.
• 45:35
  Speaker 4: Experiences artistic expression of actual events.
• 45:41
  Speaker 2: So maybe what we need to do. Else they would start, well,
• 45:48
  Speaker 2: where did you get the idea for this?
• 45:50
  Speaker 1: And that I can need to just object and say
• 45:53
  Speaker 1: where he got the ideas?
• 45:55
  Speaker 2: Not relevant? The scripts he speaks for itself.
• 45:58
  Speaker 1: It's not reasonably calculated to lead to a discovery of
• 46:01
  Speaker 1: any relevant evidence.
• 46:02
  Speaker 2: And I'm not going to let them answer any of that.
• 46:05
  Speaker 2: Do we still play it later in trial? We can't.
• 46:08
  Speaker 2: We can't, ye if you admit it, okay?
• 46:12
  Speaker 1: Or we could try a middle ground, and what will happen?
• 46:15
  Speaker 1: By the way, if I do that, then the other
• 46:19
  Speaker 1: side may go to the judge, but the motion to compel,
• 46:22
  Speaker 1: and then if if they win the motion to compel,
• 46:29
  Speaker 1: they can get a judgment against you for their attorney's
• 46:32
  Speaker 1: fees to.
• 46:33
  Speaker 2: Fight that motion to file and argue that motion.
• 46:36
  Speaker 1: But they probably would not enforce that except as an
• 46:39
  Speaker 1: offset if any eventual jury burden or whatever.
• 46:42
  Speaker 2: So it's not a.
• 46:43
  Speaker 1: Huge word, but they can't get an award of court
• 46:46
  Speaker 1: costs and fees.
• 46:48
  Speaker 4: Well, in your toolbag for fighting the case, I mean
• 46:51
  Speaker 4: you got real high marks.
• 46:52
  Speaker 2: For litigating, would you see that tool is very useful
• 46:57
  Speaker 2: with the.
• 46:57
  Speaker 4: Jury to have the ability to say this came from
• 47:03
  Speaker 4: his personal experience in mind, it.
• 47:10
  Speaker 3: Doesn't seem like it to me. I mean, I don't know.
• 47:12
  Speaker 3: It's basically a copyright question though.
• 47:15
  Speaker 2: Yeah, the only thing I mean that it is irrelevant anyway.
• 47:19
  Speaker 2: But maybe maybe it's the other side of the jets.
• 47:23
  Speaker 2: But the thing is with the empirical and the like.
• 47:27
  Speaker 4: The matchups the two like they say about where it
• 47:29
  Speaker 4: came from factually and where it came from.
• 47:32
  Speaker 3: The fact is basically you really need to do that
• 47:38
  Speaker 3: type of question. You'd really need to talk with someone
• 47:41
  Speaker 3: who had very clear litigation copyright experience, you know, and
• 47:45
  Speaker 3: because basically what you're saying is, Okay, here's one plausible
• 47:49
  Speaker 3: explanation for how these ideas originated. Now, if you're if
• 47:52
  Speaker 3: you're really talking about two sides, which both have very
• 47:56
  Speaker 3: creative screenwriters behind them, I'm sure that every side I
• 48:00
  Speaker 3: could think of at least seven other very plausible explanations
• 48:04
  Speaker 3: for where these ideas originated. But that's not that's not
• 48:07
  Speaker 3: a legal question because to give one very plausible explanation
• 48:11
  Speaker 3: is where an idea originated.
• 48:12
  Speaker 4: It doesn't prove anything, but you just hit upon something
• 48:15
  Speaker 4: really fascinating. It just sparked something there was if they
• 48:19
  Speaker 4: present that side of the events like that that testimony
• 48:23
  Speaker 4: where it's like this came from this, it came from
• 48:25
  Speaker 4: thissca and they go, mister Rankin, you know Sam, what's
• 48:30
  Speaker 4: your side for this?
• 48:31
  Speaker 2: And then we have nothing.
• 48:33
  Speaker 4: It definitely goes like in the minds of the jury,
• 48:36
  Speaker 4: they've got all this behind it.
• 48:38
  Speaker 2: He doesn't have anything.
• 48:40
  Speaker 4: So if we show they if they go that route
• 48:43
  Speaker 4: and take that path where it's like we got it
• 48:45
  Speaker 4: from this, we got it from this, we got it
• 48:46
  Speaker 4: from this to my mother shit bricks and I got that,
• 48:49
  Speaker 4: and then we're like, well, here's our experience. You know
• 48:52
  Speaker 4: this happened, this happens like this happened. You actually turned
• 48:54
  Speaker 4: into the scene. That scene, that scene. Here's where the
• 48:56
  Speaker 4: agents come from, Here's where the architect comes from. Here's
• 48:58
  Speaker 4: his personal experience that caused to be written. And that's
• 49:01
  Speaker 4: why this little girl point the sun at the end.
• 49:05
  Speaker 2: Suddenly, if they're gonna play that field, we're up here.
• 49:07
  Speaker 3: If you're if you're running a murder groups, right, I mean,
• 49:10
  Speaker 3: if you're running a murder case and one side school
• 49:12
  Speaker 3: argument is based on motive and then the other side's
• 49:15
  Speaker 3: case is based on the fact, well, you know, the
• 49:17
  Speaker 3: identifying witness was drunk. I mean, you have to figure
• 49:20
  Speaker 3: out what your strategy is and really like the stronger
• 49:23
  Speaker 3: question in a copyright case is copying and access. Well,
• 49:26
  Speaker 3: so basically that's what you really need and if you can,
• 49:30
  Speaker 3: if you're an effective attorney in that point of the litigation,
• 49:32
  Speaker 3: and it really comes to that and you show well,
• 49:34
  Speaker 3: look they have no case. That's why they're going totally
• 49:36
  Speaker 3: on the sources. That actually ends up working in your
• 49:40
  Speaker 3: favor in.
• 49:41
  Speaker 2: The jury's good.
• 49:41
  Speaker 3: Yes, you just have to be good about it, you know.
• 49:44
  Speaker 3: But these are all like way down.
• 49:46
  Speaker 2: The road, right, But it's a good one. They're good
• 49:48
  Speaker 2: questions because it's like if you've got to planning fields.
• 49:50
  Speaker 4: We have to work on for the jury's mindset. Jury's
• 49:53
  Speaker 4: are fickle. I mean, is there going to be like
• 49:56
  Speaker 4: some little idea is gonna log in their head.
• 49:58
  Speaker 2: They're gonna hold on to it.
• 49:59
  Speaker 4: The guy's not gonna let the go lady, And it's
• 50:01
  Speaker 4: like sudden to be like, well, this is the point though,
• 50:03
  Speaker 4: but they did this, but they kept saying this, but
• 50:05
  Speaker 4: they kept saying that they're not going to switch. As
• 50:07
  Speaker 4: I've been on Jerry, I've seen this happen and it's
• 50:09
  Speaker 4: like they lock into something. But if we have two
• 50:12
  Speaker 4: playing fields and we went on this one, access blow
• 50:15
  Speaker 4: them away and then you bring in the other.
• 50:17
  Speaker 2: Field, Let's blow them away another one too.
• 50:19
  Speaker 3: But the one thing that might be good to do
• 50:21
  Speaker 3: based on this conversation is supposing you do want to
• 50:24
  Speaker 3: split with someone for for fees. Right at some point,
• 50:28
  Speaker 3: is there any way that you can consult with someone
• 50:30
  Speaker 3: who has that type of experience.
• 50:31
  Speaker 4: At this point that's not we are for the deposition
• 50:35
  Speaker 4: that might be a friend.
• 50:41
  Speaker 2: Talk to about about that. Yeah, whether.
• 50:50
  Speaker 1: To get into how it play?
• 50:56
  Speaker 2: Hell do you alleged victims of the.
• 51:00
  Speaker 5: French Match later created the work.
• 51:05
  Speaker 2: I don't remember their voice, these kind of super mm
• 51:13
  Speaker 2: we have tried it. You gotta have.
• 51:16
  Speaker 6: Oh, I was just gonna say that we got We
• 51:18
  Speaker 6: finally got through the copyright office.
• 51:21
  Speaker 5: It's been a process this whole time. So the papers
• 51:24
  Speaker 5: are on their way.
• 51:25
  Speaker 4: The original scripts they're copying. Yeah, plus they certificate from
• 51:28
  Speaker 4: ninety six to ninetys.
• 51:29
  Speaker 2: We made the original scripts copy.
• 51:31
  Speaker 5: Of the copyright. We got copies of everything that was copyright.
• 51:35
  Speaker 2: On the pile. So we're gonna exactly what they had
• 51:38
  Speaker 2: predating their there was the.
• 51:39
  Speaker 5: Screenplay okay, and the hopefully.
• 51:42
  Speaker 4: The music and apparently preceding what they put pen to
• 51:45
  Speaker 4: paper ninety six is when they see it.
• 51:47
  Speaker 5: But regardless, it's what we have that's copyrighted.
• 51:50
  Speaker 3: Yeah, we we Maybe once you you're done, we could
• 51:55
  Speaker 3: just like go over the production and stuff.
• 51:57
  Speaker 1: Okay, yeah, you do that with them, Sam turn Okay,
• 52:03
  Speaker 1: So maybe on.
• 52:05
  Speaker 2: This other question we can tread of fine line. Try to.
• 52:12
  Speaker 2: First of all, it's not for sure that they'll raise
• 52:15
  Speaker 2: this in the in the deposition, but if.
• 52:19
  Speaker 1: They do ask you, you know where to come with
• 52:21
  Speaker 1: this idea, maybe we can have some pad answers ready
• 52:26
  Speaker 1: to go that don't devote too.
• 52:29
  Speaker 2: Much, you know, like you can talk about your daughter
• 52:34
  Speaker 2: that you lost.
• 52:38
  Speaker 3: It's a daughter.
• 52:40
  Speaker 2: And you know.
• 52:44
  Speaker 1: But why don't you do this? Tom? Have you ever
• 52:48
  Speaker 1: prepared a written summary of where you got ideas in
• 52:53
  Speaker 1: your life? M okay, why don't you do this for me?
• 53:00
  Speaker 1: Then you get me a copy of that, revised it
• 53:03
  Speaker 1: to fit up a little, so that I can think
• 53:05
  Speaker 1: about this difficult question not in a vacuum, but with
• 53:08
  Speaker 1: reference to exactly play out in our case, what you
• 53:13
  Speaker 1: would say, if you did come up with it, and.
• 53:16
  Speaker 2: Then maybe we can avoid getting.
• 53:19
  Speaker 1: Into too much either at the deposition or trial.
• 53:25
  Speaker 2: Debt reflects poorly on you. Mine has chosen me too.
• 53:29
  Speaker 4: The PTSD or whatever it is is a condition that's
• 53:35
  Speaker 4: obviously brought about by trauma and things and unjustice injustice sometimes,
• 53:40
  Speaker 4: So it's not something I'm born with.
• 53:42
  Speaker 3: It's something that I'm.
• 53:44
  Speaker 2: Like, not feeling effects at all now, not at all.
• 53:48
  Speaker 4: So what's interesting is, I mean, you'll see me very focused,
• 53:51
  Speaker 4: not losing any trans I can think five trains of
• 53:53
  Speaker 4: thoughts again like I used to be.
• 53:54
  Speaker 2: Four, not lose them at all. So it's in the
• 53:57
  Speaker 2: whole that way. But the thing is today, did they
• 54:01
  Speaker 2: bring up the issue of okay he did this.
• 54:04
  Speaker 4: Yeah, I suffered when I wrote the piece and I
• 54:06
  Speaker 4: turned it into art, and yes that it affected my
• 54:09
  Speaker 4: being able to extrapolate ideas and stuff in the process
• 54:13
  Speaker 4: of seeing the film for the first time. But as
• 54:15
  Speaker 4: far as my present condition, there's no effects.
• 54:20
  Speaker 2: So what do we do things about your past with
• 54:24
  Speaker 2: the abuse and the Robertson and all rights are that
• 54:28
  Speaker 2: I really don't want to get in. Would that hurt us?
• 54:31
  Speaker 2: I mean, I'm a little fucking how it would hurt us?
• 54:33
  Speaker 2: I mean with the jury they think like what would
• 54:36
  Speaker 2: they think?
• 54:36
  Speaker 1: Like? I mean, seriously, people have all kinds of pregance
• 54:39
  Speaker 1: epsoms and ideas, and just they might see you as kind.
• 54:42
  Speaker 9: Of like not profit seeker or no, no, they might
• 54:48
  Speaker 9: seek you, see you as not very well balanced or
• 54:54
  Speaker 9: completely saying.
• 54:55
  Speaker 1: They won't necessarily take your word for it. That's all
• 54:58
  Speaker 1: in the past. You're over that.
• 54:59
  Speaker 2: You're a different now, and I don't want the case
• 55:02
  Speaker 2: to be about you.
• 55:03
  Speaker 1: And I want it to be about showing the parallels
• 55:08
  Speaker 1: of the movies.
• 55:10
  Speaker 3: Not about.
• 55:12
  Speaker 2: Is Tom Mantlehouse let me, I know, I want to
• 55:16
  Speaker 2: say this, Excuse me.
• 55:18
  Speaker 1: I don't want to present the cases this is Tom
• 55:21
  Speaker 1: Malhouse's idea of how the play, the screenplay and these
• 55:27
  Speaker 1: movies are related and similar. Because then the other side
• 55:32
  Speaker 1: will come up and say, well, okay, but Tom Malthhouse
• 55:35
  Speaker 1: is crazy. He admitted himselfie blah blah blah blah blah.
• 55:37
  Speaker 1: Do you think that's the same person. You can't believe
• 55:39
  Speaker 1: there's wacko theories about this. I don't want the case
• 55:43
  Speaker 1: to turn out that way. I want it to be
• 55:45
  Speaker 1: I'm presenting how the similarity, where the similarities are, and
• 55:50
  Speaker 1: why the.
• 55:51
  Speaker 2: Jury should believe this. If we give them any kind
• 55:57
  Speaker 2: of opening where you're the one.
• 55:59
  Speaker 1: Presenting that evidence, then maybe it is relevant why you
• 56:03
  Speaker 1: believe that, and then maybe it's relevant just to damage
• 56:08
  Speaker 1: your credibility, and they will try to damage your credibility
• 56:10
  Speaker 1: with a jury. But if you're just testifying about issues
• 56:14
  Speaker 1: relating to submission of the script, etc. Then they can't
• 56:19
  Speaker 1: question this was your script, you copyrighted it. Here it
• 56:22
  Speaker 1: all is, and they can't even raise it's just irrelevant
• 56:28
  Speaker 1: what was behind it.
• 56:29
  Speaker 2: So you know, you just raise something for me, which
• 56:31
  Speaker 2: is really cool. While you're talking like that and what
• 56:34
  Speaker 2: you're relaying. What I've seen too to offer also from
• 56:39
  Speaker 2: my side of it is.
• 56:40
  Speaker 4: I've seen jury coming down to a simple thing.
• 56:44
  Speaker 2: Do they like the person or not? Do they believe
• 56:46
  Speaker 2: them or not? What we're saying was what we're talking about.
• 56:49
  Speaker 4: And if they see a cold, calculated person just relaying
• 56:54
  Speaker 4: the facts.
• 56:55
  Speaker 2: I've seen this happen.
• 56:55
  Speaker 4: Whether a person came up and they were a government
• 56:57
  Speaker 4: witness in the federal child remove people and she gave
• 57:01
  Speaker 4: great facts and she was but she seemed cold and
• 57:03
  Speaker 4: just kind of gave them, gave them, gave them, and
• 57:06
  Speaker 4: they were solid, and we went to the liberation room.
• 57:08
  Speaker 4: They didn't want to They didn't like her. They thought
• 57:11
  Speaker 4: she was cold and prickly. She was simply doing what
• 57:13
  Speaker 4: she was told to do, and they were against her.
• 57:15
  Speaker 4: And everything was thrown out, and I kept saying, look,
• 57:18
  Speaker 4: they said they had bombs. No they didn't know, they
• 57:21
  Speaker 4: didn't They totally in their minds. They gated to create
• 57:24
  Speaker 4: their own field of what she said.
• 57:26
  Speaker 3: And so I said, well, let's have it.
• 57:27
  Speaker 2: Come in and read.
• 57:28
  Speaker 4: They came in and read the statement. Yes they had bombs.
• 57:31
  Speaker 4: We had bombs, point blank. Can't get similar. Still, they
• 57:36
  Speaker 4: didn't want to believe it because they didn't like her.
• 57:38
  Speaker 4: But when you have a person who's real, a John Doe,
• 57:41
  Speaker 4: who really they can associate with, and he was shit
• 57:44
  Speaker 4: on them by the big Goliath. And that guy's telling
• 57:47
  Speaker 4: his story how he lost his daughter and how you know,
• 57:50
  Speaker 4: I'm an actor too, But the thing is I share
• 57:52
  Speaker 4: how I lost my daughter and how'm a real person.
• 57:55
  Speaker 4: And yes it mattered to me, and this is where
• 57:56
  Speaker 4: it came from. And I had that problem I did,
• 58:00
  Speaker 4: so I turned into art.
• 58:05
  Speaker 2: Will probably do is this? I'll object une relevance at
• 58:08
  Speaker 2: the deposition.
• 58:09
  Speaker 1: And I'll make sure that all all possible objections are preserved.
• 58:12
  Speaker 2: And then at trial we'll have.
• 58:15
  Speaker 1: To decide if it goes that far, whether we want
• 58:18
  Speaker 1: to go that route or not, and how much it
• 58:20
  Speaker 1: comes in. But even at the deposition, we'll plan in advance,
• 58:24
  Speaker 1: and you're going to draft something to show origins, and
• 58:27
  Speaker 1: then we're going.
• 58:28
  Speaker 3: To try to edit, chat and.
• 58:29
  Speaker 2: Plan in advance so that we can keep out.
• 58:34
  Speaker 1: The stuff that we don't want them to know and
• 58:37
  Speaker 1: certainly don't want.
• 58:38
  Speaker 2: To go to present to the jury under any circumstances.
• 58:44
  Speaker 2: And then then we'll at least have our options.
• 58:47
  Speaker 4: Preserved and goes through trials perfect because I'll tell you what.
• 58:50
  Speaker 10: Anthony just on the table here without my condition affecting me,
• 58:54
  Speaker 10: and with my background, which was offered Broadway, offered you know, Hollywood,
• 59:00
  Speaker 10: by Allen Gear, playing clothes for Broadway.
• 59:03
  Speaker 3: I mean, I was offered these things because I can.
• 59:05
  Speaker 4: I can do a good job presenting, feeling and connecting
• 59:10
  Speaker 4: with audiences and juris. So the thing is, if you
• 59:13
  Speaker 4: put me on the stand and I'm in my as
• 59:16
  Speaker 4: I am now, I will be able to reach them
• 59:20
  Speaker 4: and I'll be able to give them the tears, and
• 59:21
  Speaker 4: I'll be able and it'll be real, but I'll be
• 59:23
  Speaker 4: able to tell them about my daughter. I'll be able
• 59:24
  Speaker 4: to tell them about that stuff, and They're going to connect.
• 59:26
  Speaker 4: We'll make a connection with jury guarantee you. I don't
• 59:30
  Speaker 4: think anybody else can do it much better.
• 59:32
  Speaker 2: All right, Well, maybe we can do that.
• 59:36
  Speaker 1: Maybe we can have you make a connection without having
• 59:38
  Speaker 1: to get into your history, you know, open a potential
• 59:41
  Speaker 1: can of worms that if we can limit the cannib worms,
• 59:44
  Speaker 1: we'll know after the deposition how much they've been able
• 59:48
  Speaker 1: to find out and.
• 59:49
  Speaker 2: Whether we can limit the cannib worms more positive than negative.
• 59:54
  Speaker 2: And if we decide to nit positive and we think
• 59:56
  Speaker 2: that the judge can you know, allow it, then we
• 1:00:00
  Speaker 2: might go for it. Good t I mean, I'd ask
• 1:00:03
  Speaker 2: for faith in that that. Yes, I'll tell you we
• 1:00:05
  Speaker 2: don't need to make the decision for a long time
• 1:00:07
  Speaker 2: done just that. Yeah, I know I can becondoze me.
• 1:00:10
  Speaker 2: She knows I can come through with that.
• 1:00:12
  Speaker 1: Oh, I'm sure you can do well, understand, And we're
• 1:00:14
  Speaker 1: certainly going to give you a chance to shine and
• 1:00:19
  Speaker 1: ingratiate yourself to the jury effectively. Whatever the subject of
• 1:00:23
  Speaker 1: your testimony, even if we have to limit it to
• 1:00:28
  Speaker 1: present any presentation of the script and all that, and.
• 1:00:32
  Speaker 2: That your background. We can get any information about your background.
• 1:00:35
  Speaker 4: And see that's one of our biggest advantage I think
• 1:00:37
  Speaker 4: is mister Smith went to Washington.
• 1:00:39
  Speaker 2: It's like Jimmy Stewart on the stand. Okay, that's good,
• 1:00:44
  Speaker 2: all right, Okay, I think.
• 1:00:47
  Speaker 3: If we're done, you can go over the RPD.
• 1:00:50
  Speaker 1: Yeah, alexcuse myself, thank you, Yeah, you can.
• 1:00:59
  Speaker 3: Seemed to go over this in life thinks about which
• 1:01:01
  Speaker 3: documents you have, which ones you can find? Okay, So
• 1:01:08
  Speaker 3: they are asking for services in.
• 1:01:09
  Speaker 2: The gios referred to relied on, used.
• 1:01:12
  Speaker 3: In writing and prepared in conjunction with the Aft House screenplay.
• 1:01:16
  Speaker 3: But that's what we just had a whole discussion about it.
• 1:01:18
  Speaker 1: I think that's right.
• 1:01:19
  Speaker 3: Should have any writings like what would that actually be
• 1:01:21
  Speaker 3: bractice speaking? Do you have any documents like that?
• 1:01:23
  Speaker 2: Is there a penalty for what we do not disclosed?
• 1:01:26
  Speaker 2: Like if there? Do we have a gray area where
• 1:01:28
  Speaker 2: these things can surface if we're not sure from now? Good? Okay,
• 1:01:32
  Speaker 2: thank you, it's not right, God bless that phrase.
• 1:01:34
  Speaker 6: That's what we just were discussing all his evidence would
• 1:01:37
  Speaker 6: be court case documents and tribulation through the Robertson case
• 1:01:43
  Speaker 6: and things like.
• 1:01:44
  Speaker 5: That, which is what Anthony was saying. He's not sure
• 1:01:47
  Speaker 5: he wants to bring up right now.
• 1:01:48
  Speaker 3: So I guess we would we all all times, but
• 1:01:51
  Speaker 3: we're gonna say that number one, We're gonna.
• 1:01:53
  Speaker 4: Say it is not road Okay, Sam, do you see
• 1:01:59
  Speaker 4: this as a paper war?
• 1:02:00
  Speaker 2: Just broad strokes and everything exhaust us and let's.
• 1:02:03
  Speaker 3: Just try to come up with just.
• 1:02:05
  Speaker 2: Want to get feel what we're doing.
• 1:02:07
  Speaker 3: Shows as much good faith as possible.
• 1:02:10
  Speaker 2: Okay with that? Actually, just I totally agree.
• 1:02:12
  Speaker 4: I just want to get all documents relating to any
• 1:02:15
  Speaker 4: copyright registration that they all have screenplay.
• 1:02:19
  Speaker 3: So I've sent them everything we have.
• 1:02:20
  Speaker 2: Do you have anything, Well, the things are coming in
• 1:02:22
  Speaker 2: the mail, and then we can say is they've been
• 1:02:24
  Speaker 2: ordered there ordered right? So we have two scrubs.
• 1:02:29
  Speaker 3: The quest for production number three is Writer Skills of America,
• 1:02:35
  Speaker 3: so that would send them what we had. Do you
• 1:02:37
  Speaker 3: have anything else.
• 1:02:38
  Speaker 2: Besides what we have?
• 1:02:39
  Speaker 6: You have the thing with the good you have the
• 1:02:43
  Speaker 6: contacting in the past, and they don't keep anything past
• 1:02:46
  Speaker 6: like ten years, but you'll keep that.
• 1:02:49
  Speaker 2: Basically, we have the letters that you have.
• 1:02:52
  Speaker 6: Photocopies of is the receipt of the money orders sent
• 1:02:56
  Speaker 6: to them, and the envelope reply to them, and the
• 1:02:59
  Speaker 6: copy of the right But.
• 1:03:01
  Speaker 4: What's nice to them is the copyright of ninety six
• 1:03:03
  Speaker 4: will be what we send to Writers Guild.
• 1:03:05
  Speaker 2: That's what's beauty of it is that the same thing, right.
• 1:03:08
  Speaker 3: So the one that so what I'm asking those that
• 1:03:11
  Speaker 3: you have the original of what we photocopy for them?
• 1:03:14
  Speaker 2: Yes, right, good job.
• 1:03:16
  Speaker 3: Then request for production of report. It's all versions of
• 1:03:19
  Speaker 3: the screenplay. So that's like interesting, that's.
• 1:03:22
  Speaker 2: That box of stuff. I mean, that's just fishing all versions.
• 1:03:25
  Speaker 3: Well, I mean there's a.
• 1:03:27
  Speaker 2: Problem with.
• 1:03:29
  Speaker 4: Well, the only thing is we'll have to make like
• 1:03:31
  Speaker 4: a pair of world to make a ton of copies
• 1:03:32
  Speaker 4: of a there's so many scripts that like which has
• 1:03:38
  Speaker 4: a word change or or a sentence change, or has
• 1:03:41
  Speaker 4: notes on it from witnesses that they wrote on it.
• 1:03:44
  Speaker 2: So it's a great technique by them. But no, I'm not.
• 1:03:47
  Speaker 5: Saying you will send every copy though.
• 1:03:50
  Speaker 3: The point is if you have that and you bring
• 1:03:53
  Speaker 3: that to this office, making sure of course that there
• 1:03:57
  Speaker 3: is nothing in there that we don't want to give
• 1:03:59
  Speaker 3: to them.
• 1:04:00
  Speaker 2: Yeah, let's bring it in.
• 1:04:01
  Speaker 3: Bring it into here, and we'll tell them that like
• 1:04:04
  Speaker 3: it's available if they if they pay.
• 1:04:06
  Speaker 7: For the copy and thank you, thank you, So you
• 1:04:11
  Speaker 7: bring anything, it's just because people read it and made
• 1:04:14
  Speaker 7: notes on it, you need to bring in that.
• 1:04:15
  Speaker 2: Box to the office. I like what you're saying, because
• 1:04:18
  Speaker 2: that means they can fit all that stuff.
• 1:04:20
  Speaker 3: It's fun to do. Okay, all documents relating to the pictures,
• 1:04:25
  Speaker 3: including any screen for the pictures. So basically that's their
• 1:04:29
  Speaker 3: matrix stuff. I think the.
• 1:04:30
  Speaker 5: Pictures is box of all working scripts.
• 1:04:37
  Speaker 3: Okay, So basically, do you have a whole bunch of
• 1:04:40
  Speaker 3: the documents relating.
• 1:04:41
  Speaker 4: To the matrix document you like, background studies stuff, and.
• 1:04:47
  Speaker 5: You just have they downloaded on the internet.
• 1:04:51
  Speaker 6: And then we printed them and then we made notes
• 1:04:54
  Speaker 6: on them. And it's our notes that.
• 1:04:55
  Speaker 4: We were making as well for you guys the case.
• 1:04:59
  Speaker 4: It's the case notes on the materials.
• 1:05:03
  Speaker 5: What specifically are so.
• 1:05:04
  Speaker 3: Let's say, documents relating to the pictures, including but not
• 1:05:07
  Speaker 3: limited to, any copies of any screenplay of the pictures.
• 1:05:11
  Speaker 3: So why don't you, first of all, if you can
• 1:05:19
  Speaker 3: gather gather together all the stuff and then anything that
• 1:05:22
  Speaker 3: has your notes for the case sort of put in
• 1:05:25
  Speaker 3: a separate pile and everything else put.
• 1:05:29
  Speaker 2: Piles.
• 1:05:30
  Speaker 3: Okay, the the one that you put in the pile
• 1:05:34
  Speaker 3: with your notes, uh, label it you're a product, so
• 1:05:39
  Speaker 3: that we know, and then we're gonna basically claim that
• 1:05:43
  Speaker 3: it's privileged and we'll.
• 1:05:44
  Speaker 4: Keep it here in the office so it doesn't negate
• 1:05:47
  Speaker 4: it as evidence.
• 1:05:48
  Speaker 2: It's just as it's not.
• 1:05:50
  Speaker 3: It's not. Actually your notes are not evidence, but they
• 1:05:54
  Speaker 3: would be useful for us in preparing the case. Now
• 1:05:57
  Speaker 3: if you, I mean, is there a reason why you
• 1:06:02
  Speaker 3: actually need those notes right now? Okay? Better if they're here,
• 1:06:06
  Speaker 3: and they'll there'll be a pile that's labeled work products
• 1:06:08
  Speaker 3: that we're not producing right now.
• 1:06:10
  Speaker 2: Okay.
• 1:06:10
  Speaker 3: But the other documents relating to the matrix, that is,
• 1:06:13
  Speaker 3: if you have a screenplay that you've printed out doesn't
• 1:06:16
  Speaker 3: have your notes on it, or if you have copies
• 1:06:19
  Speaker 3: of the DVDs.
• 1:06:21
  Speaker 4: Well, I have things such as, you know, a picture
• 1:06:24
  Speaker 4: from a magazine back in ninety two ninety three, which
• 1:06:27
  Speaker 4: has silver letters of flames around it, And that's what
• 1:06:30
  Speaker 4: I was saying, would be used for the titling things
• 1:06:32
  Speaker 4: like that.
• 1:06:33
  Speaker 2: So I mean a risk records I mean, it's like
• 1:06:35
  Speaker 2: all the stuff that we're just trying to get it for.
• 1:06:38
  Speaker 4: Yeah, all these different articles in the Holocaust that I
• 1:06:40
  Speaker 4: used as a background for coming up with the scenes
• 1:06:43
  Speaker 4: with the train station in the wire.
• 1:06:47
  Speaker 2: Well, that's number one.
• 1:06:48
  Speaker 3: That would be number one. If you if you make
• 1:06:51
  Speaker 3: a pile for number one that you don't think discloses
• 1:06:55
  Speaker 3: your personal.
• 1:06:56
  Speaker 4: Or your product, Yeah, then you should make a pile
• 1:06:59
  Speaker 4: like very good, very good.
• 1:07:01
  Speaker 3: So basically, I mean, I'm assuming that this stuff is
• 1:07:05
  Speaker 3: going to end up being a bunch of boxes that
• 1:07:07
  Speaker 3: you would drive over here one day.
• 1:07:10
  Speaker 2: Yeah, we'll pick a dated Okay, So we did documents
• 1:07:15
  Speaker 2: restroom real quick, concerned.
• 1:07:20
  Speaker 3: Picture later because then we didn't like stand inside it's
• 1:07:24
  Speaker 3: all right, okay, So basically, all documents relating to your
• 1:07:29
  Speaker 3: allegations and claim for relief a certain the second any complaint. Yeah,
• 1:07:37
  Speaker 3: I don't know exactly what that would be question. I mean, uh,
• 1:07:45
  Speaker 3: documents that have to do with your discovery of the
• 1:07:49
  Speaker 3: copying and so on.
• 1:07:57
  Speaker 2: Uh.
• 1:08:03
  Speaker 3: So again, if you have stuff like alright, maybe it
• 1:08:07
  Speaker 3: work product and bringing into the office, we're looking for
• 1:08:11
  Speaker 3: stuff that triggers your sense or your ideas about similarities,
• 1:08:16
  Speaker 3: and we're basically gonna say that that struck was your
• 1:08:21
  Speaker 3: research for the for the cases of pro sage plaintiff.
• 1:08:26
  Speaker 2: Okay, so we're gonna say it's work product.
• 1:08:29
  Speaker 3: Uh A request for production number seven. All documents supporting
• 1:08:32
  Speaker 3: your allegations and claim for relief. Again, it's very similar
• 1:08:36
  Speaker 3: to six things that prove that they're similarities and it
• 1:08:44
  Speaker 3: sort of triggered your sense of copy. Uh. All documents
• 1:08:48
  Speaker 3: relating to any alleged similarity between the pictures and the
• 1:08:50
  Speaker 3: ALTA screen flavors and learn. All documents relating to defendants,
• 1:08:54
  Speaker 3: alleged access, all documents relating to defendants, alligience copying of
• 1:08:59
  Speaker 3: the AUF. I'll just being like, all documents relating to
• 1:09:06
  Speaker 3: any submission distributions.
• 1:09:08
  Speaker 5: So that's all just the Internet.
• 1:09:09
  Speaker 3: This is all six six to twelve, six six two
• 1:09:20
  Speaker 3: or six two Okay, six to fourteen is pretty much
• 1:09:34
  Speaker 3: all documents that will trigger your your research on the complaints.
• 1:09:38
  Speaker 3: So think about anything that you have that you use
• 1:09:42
  Speaker 3: during that writing of the first complaint, and and then
• 1:09:48
  Speaker 3: it's probably something that we'll say is work product, but
• 1:09:52
  Speaker 3: just gathering together so that we have it in our office, Okay,
• 1:09:55
  Speaker 3: cause I mean in my mind everything that triggered.
• 1:09:58
  Speaker 5: That is just going back and forth.
• 1:10:02
  Speaker 3: Between the scripts, going back and forth between the scripts
• 1:10:05
  Speaker 3: and your communication with us, right and all of your research.
• 1:10:08
  Speaker 3: So from our perspective, six to fourteen's basically stuff that
• 1:10:13
  Speaker 3: we were I'm going to produce. But you should still try
• 1:10:17
  Speaker 3: to gather it all together so that we know what we're.
• 1:10:19
  Speaker 5: Talking I mean, because the only other thing that kind of.
• 1:10:21
  Speaker 6: Came up with you were saying something like why we
• 1:10:24
  Speaker 6: think they have access? That would be all those things
• 1:10:27
  Speaker 6: internet research about finding about their database.
• 1:10:32
  Speaker 3: So all of that kind of stuff, all documents relating
• 1:10:37
  Speaker 3: to your attempts to sell any rights. Did you ever
• 1:10:40
  Speaker 3: try to sell that all of that screenplayed anyone else?
• 1:10:43
  Speaker 3: So twenty three No, there was no cells. Okay, did
• 1:10:47
  Speaker 3: you ever try to get any credit.
• 1:10:50
  Speaker 2: In any other on the Immortals? No? So we did
• 1:10:56
  Speaker 2: is no.
• 1:10:56
  Speaker 3: Twenty three is no. Did you ever get any Did
• 1:11:00
  Speaker 3: you ever try to make it into its own movie?
• 1:11:03
  Speaker 2: No?
• 1:11:04
  Speaker 3: So twenty four is no.
• 1:11:05
  Speaker 4: Now there is the one thing, Sam where we send
• 1:11:07
  Speaker 4: it to the people at water World. They requested to
• 1:11:10
  Speaker 4: look at it, so I send it into them. Did
• 1:11:12
  Speaker 4: you have and they we have a letter from them?
• 1:11:15
  Speaker 2: Or return and it said.
• 1:11:16
  Speaker 4: They said that, yeah, because I think they're trying to
• 1:11:18
  Speaker 4: say that we had nothing, this never was going anywhere.
• 1:11:21
  Speaker 2: But they said that if it was you know second okay,
• 1:11:23
  Speaker 2: So yeah, water World guys Keith Keith out, Keith Valor.
• 1:11:29
  Speaker 3: Okay, so yeah, forget that twenty five sorry.
• 1:11:36
  Speaker 4: Tricia Fike, the one that was in LA writer requested
• 1:11:40
  Speaker 4: to and make comments and wanted to see it go
• 1:11:42
  Speaker 4: through or something and has all the comments written on it.
• 1:11:44
  Speaker 2: But I don't know if.
• 1:11:45
  Speaker 3: That's well, that'll.
• 1:11:48
  Speaker 2: That'll go with four Okay.
• 1:11:51
  Speaker 4: I just wonder if it's if if I'm trying to
• 1:11:53
  Speaker 4: go through their their question, if their question is trying
• 1:11:57
  Speaker 4: to establish that so you never had a thing, never
• 1:12:00
  Speaker 4: was know nothing work, they never went anywhere.
• 1:12:02
  Speaker 3: Did we find anywhere address info on any.
• 1:12:05
  Speaker 2: Of the witness? Yes? I did.
• 1:12:06
  Speaker 4: I found your ATICA person and you found yeah, I
• 1:12:10
  Speaker 4: got her address in phone number.
• 1:12:11
  Speaker 3: Okay, so can you right call him back though.
• 1:12:13
  Speaker 4: She can call I said that the attorneys want to
• 1:12:15
  Speaker 4: contact her too though, So yeah, we had those.
• 1:12:18
  Speaker 3: Yeah, so just send send me that stuff alright. Can
• 1:12:21
  Speaker 3: you make an order to take and what about Lenny Coco?
• 1:12:28
  Speaker 2: We have what uh Becka dug up.
• 1:12:31
  Speaker 6: I went on to one of those people search okay things,
• 1:12:34
  Speaker 6: and it came up with like twenty different addresses he's
• 1:12:38
  Speaker 6: had in the past, and we tried to call him.
• 1:12:39
  Speaker 2: A few didn't get.
• 1:12:40
  Speaker 4: But what's interesting, he's under the Warner Brothers label results whatever.
• 1:12:44
  Speaker 2: No, he's under the Warner Bros. Label Lenny Coco and
• 1:12:46
  Speaker 2: the Chimes.
• 1:12:47
  Speaker 3: Just give whatever you found, okay, search and uh, what
• 1:12:51
  Speaker 3: about any of the other people, Nadia.
• 1:12:55
  Speaker 2: Stina, you found you found information on her.
• 1:12:57
  Speaker 7: I don't have.
• 1:12:58
  Speaker 2: Any of that.
• 1:12:59
  Speaker 3: Okay, we'll look at it, alright, we'll see if you've
• 1:13:01
  Speaker 3: been finding as people.
• 1:13:02
  Speaker 2: Just look at the one I sent you, alright, Nania.
• 1:13:05
  Speaker 4: And then we also have to find about Diane Bellis
• 1:13:07
  Speaker 4: unless that's the responsibility of Warner Brothers.
• 1:13:09
  Speaker 3: But no, uh, write down whatever you have.
• 1:13:10
  Speaker 2: Yeah, that's very important.
• 1:13:12
  Speaker 4: Yeah, okay.
• 1:13:12
  Speaker 3: Uh did you five any other lawsuits?
• 1:13:14
  Speaker 2: Secenumber twenty eight. The only one was that's why this
• 1:13:17
  Speaker 2: is interesting. The one was with the backstory of this
• 1:13:21
  Speaker 2: whole piece CBN pat Robinson. Though alright, pre oh, they're
• 1:13:25
  Speaker 2: asking before ninety three.
• 1:13:26
  Speaker 4: They're asking about the case, aren't they They're asking any
• 1:13:29
  Speaker 4: lawsuits at a they're trying to establish a pattern of
• 1:13:31
  Speaker 4: the suit's happy that.
• 1:13:33
  Speaker 3: An auction, No that relate to this case? Did it
• 1:13:35
  Speaker 3: involve planes or allegations?
• 1:13:37
  Speaker 2: No?
• 1:13:37
  Speaker 3: Not this case, No twenty sis is no twenty six.
• 1:13:43
  Speaker 3: Uh do you have you tried to publish other Have
• 1:13:51
  Speaker 3: you tried to publish other screenplays, theater pieces?
• 1:13:56
  Speaker 2: I've been I've written other.
• 1:14:00
  Speaker 4: Scripted work under contract, So I've written other scripted work
• 1:14:04
  Speaker 4: that has been used.
• 1:14:06
  Speaker 2: So if they're trying to establish that nothing's been done.
• 1:14:08
  Speaker 3: Relating to your attempt to make any published work by
• 1:14:11
  Speaker 3: you other than the Allas screenplay, we might say that that's.
• 1:14:14
  Speaker 2: Not relevant, it's not releatant anything.
• 1:14:17
  Speaker 3: Of theatrical stuff that we've been trying. You can give
• 1:14:21
  Speaker 3: a brief description, get write up the brief for a
• 1:14:24
  Speaker 3: number twenty six we're talking about, write a brief description
• 1:14:28
  Speaker 3: of your other work in a way it is favorable
• 1:14:33
  Speaker 3: to you, and basically tell them, can we be pretty
• 1:14:36
  Speaker 3: general about that for starts like saying that there's just
• 1:14:39
  Speaker 3: say because.
• 1:14:41
  Speaker 2: It's a lot of stuff.
• 1:14:42
  Speaker 3: So basically, yeah, no, say what you say. What you're
• 1:14:45
  Speaker 3: saying is that was any of your theater stuff actually,
• 1:14:55
  Speaker 3: let's say published in a in some sort of let's
• 1:14:59
  Speaker 3: do if they've be probably defined page.
• 1:15:01
  Speaker 2: Well, it's done. Yeah, it's been done and produced.
• 1:15:05
  Speaker 6: It hasn't been published that we haven't been able to
• 1:15:07
  Speaker 6: get published, to publish anything.
• 1:15:09
  Speaker 2: Not question.
• 1:15:10
  Speaker 3: So why do you say that? Say, plaintiff has you know,
• 1:15:15
  Speaker 3: made a number of theatrical productions, right, and none of
• 1:15:20
  Speaker 3: which have been published.
• 1:15:21
  Speaker 8: And so but have been produced, might have been produced,
• 1:15:24
  Speaker 8: and they're not relevant to this action.
• 1:15:26
  Speaker 2: That's right, very good, love it.
• 1:15:28
  Speaker 3: And say plaintiff has also written on anymerous other screenplays,
• 1:15:34
  Speaker 3: but none of them have been made into emotional pictures.
• 1:15:37
  Speaker 2: Right, very good.
• 1:15:38
  Speaker 3: So yeah, okay, so just back it up, check into
• 1:15:42
  Speaker 3: it and see what you want to write. Number twenty
• 1:15:44
  Speaker 3: six we're talking about it.
• 1:15:45
  Speaker 2: Good, okay.
• 1:15:45
  Speaker 3: Number twenty seven is your employment history and in comes
• 1:15:48
  Speaker 3: since nineteen ninety two?
• 1:15:49
  Speaker 2: Is that relevant?
• 1:15:51
  Speaker 3: It is because you're claiming damages from loss of income
• 1:15:54
  Speaker 3: from the screenplay. So the question is how can we
• 1:15:57
  Speaker 3: do that? What what sort of documents would that be?
• 1:16:01
  Speaker 4: Can we base that also on what the what they
• 1:16:03
  Speaker 4: made off it, like what they what they've grossed office?
• 1:16:06
  Speaker 3: We're talking about stuff that you would have documents, you
• 1:16:09
  Speaker 3: would have in your possession, So what is the what
• 1:16:11
  Speaker 3: certain documents? Is that what we've been talking about in
• 1:16:13
  Speaker 3: the first place.
• 1:16:15
  Speaker 4: Well, that's an interesting area because basically, if you're talking
• 1:16:18
  Speaker 4: about if we're talking about what the screenplay is based on.
• 1:16:21
  Speaker 3: No, we're talking about money that you were paid by employers.
• 1:16:25
  Speaker 3: We're talking about jobs.
• 1:16:27
  Speaker 2: And how it applies to the screenplay. I mean, or
• 1:16:31
  Speaker 2: is just what do you make?
• 1:16:32
  Speaker 3: The dirs is talking about all that sort of stuff.
• 1:16:34
  Speaker 3: We're not talking about content based stuff. We're talking about money.
• 1:16:40
  Speaker 2: So they what they're saying is what were you making?
• 1:16:43
  Speaker 2: Really like, what is your worth?
• 1:16:46
  Speaker 3: Certainly all documents relating to to show your employment history
• 1:16:50
  Speaker 3: and anythoff. Maybe you just give them a resume.
• 1:16:53
  Speaker 2: You can just give us write that down cumit resume.
• 1:16:55
  Speaker 5: So number twenty eight, yeah, twenty seven, Oh that was sorry.
• 1:17:00
  Speaker 2: Soon that sounds like they're gearing up for a personal text.
• 1:17:03
  Speaker 6: That's all.
• 1:17:04
  Speaker 2: No, But I mean, or to say like, well you
• 1:17:06
  Speaker 2: never made anything about that.
• 1:17:08
  Speaker 3: I mean, I'll talk to Anthony, but you can expect that.
• 1:17:10
  Speaker 3: But basically, try.
• 1:17:11
  Speaker 4: To come up with a general resume, a general resume, right,
• 1:17:14
  Speaker 4: because it sounds like.
• 1:17:15
  Speaker 2: Trying to open the door to personal character or something.
• 1:17:18
  Speaker 3: There's something about the fact that whether or not it
• 1:17:23
  Speaker 3: makes sense that you would produce.
• 1:17:26
  Speaker 2: A scream, but when you're nobody, because we keep harping
• 1:17:31
  Speaker 2: that in the news, so I guess, yeah, it sounds.
• 1:17:34
  Speaker 3: Like we're gonna have to figure that out.
• 1:17:38
  Speaker 2: That's why it doesn't apply. McDonald's Yeah, it doesn't apply.
• 1:17:41
  Speaker 4: If he wrote something that was really, really good and
• 1:17:43
  Speaker 4: they took it, it doesn't matter that you didn't make anything,
• 1:17:46
  Speaker 4: because that's why you did that.
• 1:17:47
  Speaker 3: So documents sufficient to show your employment history were you
• 1:17:51
  Speaker 3: did you ever have like any kind of documented uh
• 1:17:55
  Speaker 3: employment during that time.
• 1:17:56
  Speaker 4: Or are you always kind of working lands for I
• 1:17:59
  Speaker 4: was acting as performing the resumes.
• 1:18:02
  Speaker 2: Off the chart for performing. I was at Colonial Willimsburg
• 1:18:04
  Speaker 2: at the time performing.
• 1:18:06
  Speaker 3: What sort of documents would you produce to show that.
• 1:18:14
  Speaker 2: I almost far back.
• 1:18:16
  Speaker 4: You have to contact the organization, say you send my
• 1:18:20
  Speaker 4: statement of employment history there or something.
• 1:18:22
  Speaker 3: I'd have to say, you know, could you avidate.
• 1:18:25
  Speaker 2: Or you know that what was there for these years?
• 1:18:27
  Speaker 2: Of these years?
• 1:18:28
  Speaker 4: I don't see how it's so far back, because I
• 1:18:32
  Speaker 4: was at Colonial Williamsburg from ninety three.
• 1:18:34
  Speaker 2: To God help us.
• 1:18:37
  Speaker 4: We have some magazines like a long time there doing
• 1:18:41
  Speaker 4: many many things, and then I was on international tours, like.
• 1:18:45
  Speaker 5: Tours helps us your picture with your sister there, so.
• 1:18:48
  Speaker 4: We have we have a long extended period in the
• 1:18:51
  Speaker 4: same place. That's justn't help them. And you have me
• 1:18:54
  Speaker 4: on international tours and the chase for festivals the same time,
• 1:18:57
  Speaker 4: doing multiple jobs.
• 1:19:00
  Speaker 5: You are women in l A in l A.
• 1:19:06
  Speaker 2: Probably partial.
• 1:19:09
  Speaker 11: Yeah, I mean, I'm that's I'm tempted to stand that
• 1:19:14
  Speaker 11: we we give them that, like you're saying the part
• 1:19:16
  Speaker 11: like the resume and let them keep going.
• 1:19:20
  Speaker 2: Oh god, that's your saying. There's we're trying to get
• 1:19:26
  Speaker 2: difficulties paper.
• 1:19:27
  Speaker 6: Yeah, documents, Okay, I'd love the fireback the same things.
• 1:19:32
  Speaker 6: Can you please not list a million? Can't you just
• 1:19:37
  Speaker 6: do the trail enough to get you to hear? Depends
• 1:19:40
  Speaker 6: on what we got the theater, it's incredible.
• 1:19:44
  Speaker 2: So many jobs, so many freelance things. No, no, no, no,
• 1:19:46
  Speaker 2: we wouldn't put all of those. Can we go numerous or.
• 1:19:51
  Speaker 5: Williamsburg, the Shakespeare Festival.
• 1:19:54
  Speaker 6: Ellen Gear Theater, national tours and you just hop to hear?
• 1:20:01
  Speaker 2: But he says they want documents supporting him.
• 1:20:04
  Speaker 3: Yeah, it would be good.
• 1:20:05
  Speaker 4: Maybe let's say, can we say the same thing to them.
• 1:20:09
  Speaker 3: They'd answer, you could, you could.
• 1:20:11
  Speaker 4: What would they say though, if they'd ask to reach
• 1:20:13
  Speaker 4: one of the defendants?
• 1:20:14
  Speaker 2: Yes, and what do you think they'd answer?
• 1:20:18
  Speaker 3: Warner brothers And they should have document said it.
• 1:20:20
  Speaker 2: That's it read a million I'm just curious how to
• 1:20:27
  Speaker 2: approach this.
• 1:20:28
  Speaker 12: Well, no, but the question I have is if we
• 1:20:30
  Speaker 12: don't include certain things, it's hide really But if you
• 1:20:33
  Speaker 12: don't include certain things, is that considered perjury and you know,
• 1:20:38
  Speaker 12: not admitting Yeah, I mean, it would.
• 1:20:39
  Speaker 3: Be a basis for them.
• 1:20:40
  Speaker 2: To start to start crying at with the cord.
• 1:20:45
  Speaker 3: But the thing is that we need to we need
• 1:20:47
  Speaker 3: to make a very rational claim of why something's not
• 1:20:52
  Speaker 3: relevant or object on certain bases.
• 1:20:55
  Speaker 2: Right, And then it sounds like they're bringing a box
• 1:20:58
  Speaker 2: of my employment to the table.
• 1:20:59
  Speaker 3: Handle is you can say four places and you've got
• 1:21:04
  Speaker 3: a document pretty each place that just said he was
• 1:21:06
  Speaker 3: employed with esthering this in this state and so on.
• 1:21:09
  Speaker 3: That that might be something that you could do with
• 1:21:11
  Speaker 3: four emails. You do with four emails you sent you say,
• 1:21:15
  Speaker 3: these four places that could just mentioned, send each one
• 1:21:17
  Speaker 3: of them an email, get some sort of document in response,
• 1:21:21
  Speaker 3: and then you've done a good faith answer to them,
• 1:21:23
  Speaker 3: then everything else you say is overburdens it.
• 1:21:26
  Speaker 2: Thank you, that's the answer I'm looking for, Okay, thank you.
• 1:21:29
  Speaker 3: So the point is that that's that's very that's like
• 1:21:32
  Speaker 3: already going pretty.
• 1:21:33
  Speaker 4: Far, and that still keeps the door open for us
• 1:21:36
  Speaker 4: if something is questioned later, we can bring it forward.
• 1:21:38
  Speaker 2: Yeah.
• 1:21:38
  Speaker 3: I mean if they're saying, well, really, we absolutely need
• 1:21:41
  Speaker 3: to know every single little theater on off off Broadway
• 1:21:45
  Speaker 3: that she worked in, and then you'd say, well, why
• 1:21:49
  Speaker 3: it's just being annoying, right and h and so then
• 1:21:52
  Speaker 3: we fight about it. But the point is that, like
• 1:21:54
  Speaker 3: if you do something like there's four documents, that's the
• 1:21:57
  Speaker 3: reasonable number. Excellent, So try to do that one. Okay,
• 1:22:02
  Speaker 3: twenty eight. You said you haven't fought any other lawsuits
• 1:22:07
  Speaker 3: relating to the claims. Okay, twenty nine contact each individual.
• 1:22:12
  Speaker 3: So we said, you found some addresses and you're gonna
• 1:22:15
  Speaker 3: send those to me, right, So that's twenty nine. Okay, yeah, fine,
• 1:22:18
  Speaker 3: just give me the ideas, throw tack of ball that
• 1:22:20
  Speaker 3: you found the print out one people search for Lenny
• 1:22:23
  Speaker 3: Coco and what have you found that any of the
• 1:22:25
  Speaker 3: other guys. Okay, okay, And then that that means, I
• 1:22:30
  Speaker 3: mean you didn't find the w G A person. You
• 1:22:33
  Speaker 3: didn't figure them out. We'll say they were still looking
• 1:22:36
  Speaker 3: for them, and you know, go over the list their
• 1:22:41
  Speaker 3: initial discosures and c find. Okay, the writers, that's number
• 1:22:46
  Speaker 3: twenty nine, the writer scale.
• 1:22:47
  Speaker 2: You found you have, that's big fact, the right don't. Well,
• 1:22:51
  Speaker 2: we have the name on the sheet.
• 1:22:53
  Speaker 4: We have a name on the sheet of who sent
• 1:22:55
  Speaker 4: it back to us from writer scaled.
• 1:22:57
  Speaker 2: Our name's on there. So if we search her first
• 1:23:00
  Speaker 2: name or something.
• 1:23:01
  Speaker 4: Yeah, like theason, it's something to look for or yeah, somebody.
• 1:23:07
  Speaker 3: Maybe you could if you could find that out.
• 1:23:09
  Speaker 2: In like one or two phone calls.
• 1:23:13
  Speaker 3: But maybe if not, then well, okay. Request for production
• 1:23:17
  Speaker 3: thirty is Charograph fourteen and decided. In nineteen ninety three,
• 1:23:22
  Speaker 3: Planted was placed in contact with personnelity Warner Brothers to
• 1:23:25
  Speaker 3: discuss his work The Immortals, and was invited to submit
• 1:23:28
  Speaker 3: a copy of The Immortals. So that's your meeting with
• 1:23:33
  Speaker 3: Lenny Coco in which Lenny.
• 1:23:35
  Speaker 2: Coco put you on the phone, right, executive, Right.
• 1:23:37
  Speaker 3: Do you have any docments for that meeting or anything
• 1:23:39
  Speaker 3: like that? So you don't have documents for that meeting.
• 1:23:45
  Speaker 3: That's the question is that what we want to say.
• 1:23:46
  Speaker 3: So I'll ask they.
• 1:23:49
  Speaker 2: We have witnesses from the meeting.
• 1:23:51
  Speaker 11: We have witness many witnesses, and the witnesses are Artika.
• 1:23:56
  Speaker 4: Nadia, Lenny Coco himself, so I'm pretty sure.
• 1:24:01
  Speaker 3: Yeah, and uh, and the meeting happened in some apartment
• 1:24:06
  Speaker 3: in New York stity.
• 1:24:06
  Speaker 2: No, actually it's home in New York.
• 1:24:09
  Speaker 3: City, New York City. And do you remember where that
• 1:24:11
  Speaker 3: address was or anything like that.
• 1:24:13
  Speaker 6: She has the addresses that are I have all the addresses,
• 1:24:16
  Speaker 6: and there was one that he said, look familiar.
• 1:24:18
  Speaker 2: Very familiar.
• 1:24:19
  Speaker 3: Al Right, See if you can just write that down
• 1:24:21
  Speaker 3: to just say that our we don't have any documentations
• 1:24:23
  Speaker 3: that there are witnesses and the address didn't happen visit
• 1:24:27
  Speaker 3: this address, and this is a description, well we described it.
• 1:24:33
  Speaker 6: Maybe, which something's right to boy and Boyd, Well, what
• 1:24:35
  Speaker 6: if you can sit and describe his house in the detail.
• 1:24:41
  Speaker 2: We'll fine.
• 1:24:42
  Speaker 3: That's fine, But it's not a it's not an interrogatory.
• 1:24:45
  Speaker 3: You don't need to just say anything, okay.
• 1:24:47
  Speaker 2: In fact that the witnesses is good.
• 1:24:49
  Speaker 3: Yeah, yeah, you can just say the plaintiff is able
• 1:24:53
  Speaker 3: to describe.
• 1:24:53
  Speaker 2: The meeting very good easy.
• 1:24:56
  Speaker 3: Yeah, it's easy doing. The witnesses were president of the.
• 1:24:59
  Speaker 2: Meeting writers in the documentation, which is nice to.
• 1:25:02
  Speaker 3: See if you can find the address of where it happened. Okay,
• 1:25:05
  Speaker 3: thirty one is quotation.
• 1:25:09
  Speaker 2: Yeah, what was that allegation?
• 1:25:11
  Speaker 3: One eighteen the Warren Brothers a canolage receipt of a copy.
• 1:25:17
  Speaker 3: So we produced that letter to Warner brothers. But did
• 1:25:21
  Speaker 3: you ever get anything back? But there was a certified
• 1:25:23
  Speaker 3: letter back from them. Was there a certain not for
• 1:25:26
  Speaker 3: Warner Brothers?
• 1:25:27
  Speaker 4: Right, No, not saying we're a receipt of but that
• 1:25:31
  Speaker 4: was that thing that was sent through the attorney certified mail.
• 1:25:34
  Speaker 3: Okay, so we'll just say what we have produced. I
• 1:25:37
  Speaker 3: guess think if if you had anything.
• 1:25:42
  Speaker 2: Else strong about the dim bellus is the winners. But wow,
• 1:25:44
  Speaker 2: it's a tough one. Okay.
• 1:25:47
  Speaker 1: Then it.
• 1:25:49
  Speaker 3: Came across information leading you to begin investigating possible similarities.
• 1:25:56
  Speaker 3: You know, Matrix reloaded, the Matrix revolutions. What just what
• 1:26:01
  Speaker 3: was that information?
• 1:26:01
  Speaker 6: Did you down?
• 1:26:02
  Speaker 4: Tenebruary twenty that was the scene that the picture little
• 1:26:07
  Speaker 4: girl at the train station on the website.
• 1:26:12
  Speaker 3: Uh, it was just.
• 1:26:12
  Speaker 6: A a random chance viewing on yeah.
• 1:26:20
  Speaker 4: Girl, And then I saw that I wanted to produce
• 1:26:23
  Speaker 4: a copy of their website as it was in February
• 1:26:27
  Speaker 4: twenty time.
• 1:26:27
  Speaker 3: Do you have anything like that?
• 1:26:30
  Speaker 5: We can find something?
• 1:26:32
  Speaker 2: Okay, cause we could a picture. That's tricky, but we
• 1:26:37
  Speaker 2: did kind of we could. Could we cut and pasted
• 1:26:39
  Speaker 2: the picture.
• 1:26:39
  Speaker 3: From it production? Thid screen? Why do you have teens
• 1:26:45
  Speaker 3: screenplay for the pictures? How did you get matrix screenplayce
• 1:26:49
  Speaker 3: screen safe?
• 1:26:51
  Speaker 2: No? What is it?
• 1:26:54
  Speaker 3: Did you get a membership or something? Huh did you
• 1:26:56
  Speaker 3: get a membership to that? To three safe?
• 1:26:59
  Speaker 1: No?
• 1:27:00
  Speaker 3: Who? How did you get a screen.
• 1:27:01
  Speaker 2: How did you get the screenplay the matrixes? How did
• 1:27:06
  Speaker 2: we download 'em? How do we find 'em online?
• 1:27:08
  Speaker 3: Oh?
• 1:27:09
  Speaker 5: They're free on.
• 1:27:11
  Speaker 3: Just take to say the name of the website.
• 1:27:12
  Speaker 4: I N I know it is that one of them
• 1:27:14
  Speaker 4: right there, it'll be No.
• 1:27:16
  Speaker 6: No, Uh, horror layer h O R R O R
• 1:27:22
  Speaker 6: L A R. I think dot com is one.
• 1:27:26
  Speaker 3: Are you remind the websites that you have incentives to that?
• 1:27:29
  Speaker 3: You know? Yeah? Thirty four? Uh postings or comments by
• 1:27:35
  Speaker 3: you to the Internet. Did you post a whole bunch
• 1:27:40
  Speaker 3: of stuff to the.
• 1:27:40
  Speaker 2: Internet on this No?
• 1:27:42
  Speaker 4: I we we made our own web page after we
• 1:27:45
  Speaker 4: discovered and then.
• 1:27:46
  Speaker 3: We take it to best public.
• 1:27:48
  Speaker 2: No not now, Anthony's allus to take it down.
• 1:27:54
  Speaker 3: Huh, so we might did. Was it damaging?
• 1:27:58
  Speaker 2: Any said no, it wasn't. I don't think it was damaging.
• 1:28:02
  Speaker 3: I don't know. There's only like two articles on there.
• 1:28:06
  Speaker 2: Alright.
• 1:28:06
  Speaker 3: We might need to produce some sort of print out
• 1:28:08
  Speaker 3: of that. Oh, that's ye. Think about it.
• 1:28:13
  Speaker 7: She's a tom going off Tallinn's two guys and nut
• 1:28:17
  Speaker 7: jobs and you know takes it.
• 1:28:19
  Speaker 6: Yeah.
• 1:28:19
  Speaker 3: See if you have a print out there you can
• 1:28:22
  Speaker 3: get for that. It's not complete.
• 1:28:25
  Speaker 4: And that actually posted a little girl picture with one.
• 1:28:27
  Speaker 4: I saw the post the little girl picture from the site.
• 1:28:31
  Speaker 5: I have to say, if I still have I think
• 1:28:33
  Speaker 5: I'll save them.
• 1:28:34
  Speaker 2: Pretty cool.
• 1:28:35
  Speaker 3: Okay, Documents relating to those post games are common. It's
• 1:28:40
  Speaker 3: the same theme. Thirty four, thirty five that website.
• 1:28:44
  Speaker 1: You might need to.
• 1:28:47
  Speaker 3: So put just put those together. Thirty four and thirty five,
• 1:28:51
  Speaker 3: thirty six is the same, thirty seven is the same,
• 1:28:55
  Speaker 3: thirty n thirty eight, thirty nine, They're all the same thing.
• 1:29:00
  Speaker 3: They all have to do with postings for the internet, okay,
• 1:29:03
  Speaker 3: and by you or other people that you know, okay,
• 1:29:08
  Speaker 3: And they relate probably to that website, so and people's
• 1:29:13
  Speaker 3: comments on that website. So what I would do is
• 1:29:19
  Speaker 3: I would get together those types of things they relate
• 1:29:23
  Speaker 3: to that website and uh again just kind of pay
• 1:29:27
  Speaker 3: per click. Then label them response to thirty four to
• 1:29:31
  Speaker 3: fifty nine, and we'll look at them if you want,
• 1:29:33
  Speaker 3: we'll look at them together, and we'll just think about that,
• 1:29:36
  Speaker 3: whether it's relevant, whether we want to produce it whither.
• 1:29:38
  Speaker 3: There's stuff in there that is not relevant for them
• 1:29:43
  Speaker 3: to ask for. But I I think I'm basically thinking
• 1:29:46
  Speaker 3: that that's.
• 1:29:46
  Speaker 2: Just something we're gonna produce, you know, right.
• 1:29:49
  Speaker 3: With public for a while, and it's just what it is.
• 1:29:54
  Speaker 5: And they all can see it.
• 1:29:55
  Speaker 2: Finally, when you think about the other thing, too, is
• 1:29:57
  Speaker 2: you just hit upon two? Is their interview? Now?
• 1:30:00
  Speaker 4: I know that interviews in a paper are not necessarily
• 1:30:03
  Speaker 4: legal submission that kind of thing, or valid testimonies, But
• 1:30:07
  Speaker 4: if they're submitting to us the interviews they did, then
• 1:30:10
  Speaker 4: they're submitting to us their words. If we just have
• 1:30:14
  Speaker 4: them disclosed the interviews they've made about the matrix's poem,
• 1:30:19
  Speaker 4: then cannot we possibly be able to say this is
• 1:30:23
  Speaker 4: their submission from their own their interviews?
• 1:30:27
  Speaker 3: We might be able to I'm not.
• 1:30:28
  Speaker 2: Sure that could be really validcause she found it. She
• 1:30:30
  Speaker 2: found a ton of stuff.
• 1:30:31
  Speaker 3: If you see an interview in which they say something
• 1:30:35
  Speaker 3: it's it could theoretically be admissible as a hearsay.
• 1:30:38
  Speaker 4: Exception unless they what unless they submit it.
• 1:30:42
  Speaker 2: So she said, let's say that it doesn't matter if.
• 1:30:44
  Speaker 3: They submit it, if it's if it's a published interview,
• 1:30:48
  Speaker 3: and unless they say that it's not an authentic account
• 1:30:52
  Speaker 3: of the words. But the problem with anything that's different
• 1:30:56
  Speaker 3: out on the internet is there's two levels of hearsay, right,
• 1:31:00
  Speaker 3: So you don't actually have a witness that this is
• 1:31:02
  Speaker 3: what they said. You would need to find the person
• 1:31:05
  Speaker 3: that conducted the interview, and if that person. If you
• 1:31:09
  Speaker 3: can find the person who conducted the interview and they
• 1:31:11
  Speaker 3: can testify that this record of the interview is a
• 1:31:14
  Speaker 3: true and accurate form of what was said at that time,
• 1:31:17
  Speaker 3: then the statements by the person that was giving the interviews,
• 1:31:22
  Speaker 3: who might be a defendant in this case, would be
• 1:31:25
  Speaker 3: possibly admissible as as as evidence.
• 1:31:31
  Speaker 2: And that would be valuable. Absolutely following that one, Yeah.
• 1:31:36
  Speaker 6: That particular site that I know you're thinking of, I
• 1:31:39
  Speaker 6: don't even want to alert them that we even have
• 1:31:42
  Speaker 6: it because it's on a what Warner's Brother website.
• 1:31:46
  Speaker 3: Well, the question is, can you figure out who gave
• 1:31:48
  Speaker 3: the interviews?
• 1:31:50
  Speaker 5: Yeah, no, the guy whose name is on there.
• 1:31:52
  Speaker 2: Perfect.
• 1:31:52
  Speaker 6: It was an online chat like they're doing a live
• 1:31:58
  Speaker 6: interviews people from all over the internet. We're typing in
• 1:32:01
  Speaker 6: questions to them and they were responding answers that.
• 1:32:05
  Speaker 2: What's really huge, it's for our data sheet. When that
• 1:32:07
  Speaker 2: comes as.
• 1:32:08
  Speaker 6: Evidence, Well, they just had different statements in there about
• 1:32:12
  Speaker 6: where the origin was for different ideas that they had,
• 1:32:15
  Speaker 6: and the irrelevance of certain things that they didn't think
• 1:32:18
  Speaker 6: were relevant, like religion and things that.
• 1:32:22
  Speaker 4: They didn't even think It limits what they can respond
• 1:32:25
  Speaker 4: to and say that.
• 1:32:25
  Speaker 6: And also on one of the main things in there
• 1:32:28
  Speaker 6: is that all names, all numbers had significant multiple means
• 1:32:31
  Speaker 6: and they work.
• 1:32:32
  Speaker 2: They tell you whether it meant yeah, they'd never tell me.
• 1:32:34
  Speaker 6: And this is something that's really it's really kind of
• 1:32:37
  Speaker 6: a crucial point because with the data sheet.
• 1:32:39
  Speaker 2: It's like, why is it's all in here?
• 1:32:41
  Speaker 6: Well, not just the data sheet, but just so many Okay, well,
• 1:32:44
  Speaker 6: you don't need obviously, you don't need to do any
• 1:32:46
  Speaker 6: of that stuff.
• 1:32:46
  Speaker 3: It's not in your possession it's not yours, it's not
• 1:32:48
  Speaker 3: produced by you, it's not coming by you. So all
• 1:32:51
  Speaker 3: these interview things are not relevant to what we're doing
• 1:32:55
  Speaker 3: right here.
• 1:32:55
  Speaker 2: Right now, right.
• 1:32:56
  Speaker 3: But I mean from there, I think that Daniel, you
• 1:32:59
  Speaker 3: want to do is you want to try to track
• 1:33:01
  Speaker 3: down the person who gave the interview, and you want
• 1:33:03
  Speaker 3: to try to find an addressing, the phone number. But then,
• 1:33:05
  Speaker 3: as I possible, all right, somehow and then we might
• 1:33:10
  Speaker 3: I don't know exactly how or when or why be
• 1:33:13
  Speaker 3: able to call them in as a witness and have
• 1:33:15
  Speaker 3: them authenticate that witness transcript.
• 1:33:19
  Speaker 2: And this is yeah, this is the one where they
• 1:33:20
  Speaker 2: really slipped up.
• 1:33:21
  Speaker 3: Well yeah, But what I'm saying is that this is
• 1:33:24
  Speaker 3: all further down the road, right exactly exactly, But we
• 1:33:29
  Speaker 3: have four more questions. Okay, okay, Communications with any defendant.
• 1:33:32
  Speaker 3: Have you spoken directly with any of these defendants?
• 1:33:36
  Speaker 2: Okay?
• 1:33:37
  Speaker 3: So forty is no? Soay forty one? Communications relating to
• 1:33:44
  Speaker 3: the all toouse screenplay with anyone to Dana Bellisty, tap
• 1:33:48
  Speaker 3: the ball, James Boyd not a just email that you
• 1:33:50
  Speaker 3: pick a cocoa keeps bowing great nature. So we already
• 1:33:54
  Speaker 3: produced a lot of that stuff, right, you saw. All
• 1:33:56
  Speaker 3: the stuff I produced is basically all the dominance we
• 1:33:59
  Speaker 3: have is I think about if there's any other documents
• 1:34:02
  Speaker 3: or communications do you have with these people?
• 1:34:05
  Speaker 2: Do we have the sportsmith notary one?
• 1:34:07
  Speaker 4: Do you have that one? The notarized sports mis statement,
• 1:34:11
  Speaker 4: the poor men's packet thing? We're the sealed envelope of
• 1:34:15
  Speaker 4: everything in it?
• 1:34:16
  Speaker 3: Sorry that I'm all right. So forty one and forty
• 1:34:21
  Speaker 3: two are almost the same, and they basically relate to
• 1:34:23
  Speaker 3: these communications. So just look through your stuff, think about
• 1:34:27
  Speaker 3: do you have communications other than the ones that you've
• 1:34:29
  Speaker 3: given us and find them? And a little one Now
• 1:34:33
  Speaker 3: that forty three is agreements or contracts relating to the screenplay,
• 1:34:36
  Speaker 3: did you make any No? Forty three is no? All right,
• 1:34:40
  Speaker 3: So that's basically what we're gonna do. So do you
• 1:34:45
  Speaker 3: have questions on that stuff?
• 1:34:47
  Speaker 4: That one question? How far are you to go with?
• 1:34:49
  Speaker 4: Who we've spoken to about the screenplay? Is that the
• 1:34:52
  Speaker 4: question who we've had contact with?
• 1:34:54
  Speaker 3: Talking you've contact I.
• 1:34:55
  Speaker 2: Could be forever after the case has gone down.
• 1:34:58
  Speaker 3: But they're asking for docum of documents. So if you
• 1:35:03
  Speaker 3: have notes or diaries around.
• 1:35:06
  Speaker 2: Those scripts, there'ld be the note scripts. You know, people
• 1:35:09
  Speaker 2: have the notes on the script back in ninety five
• 1:35:11
  Speaker 2: and such. Yeah, great, Mazer.
• 1:35:15
  Speaker 3: So the the screenplays with notes from people that you've
• 1:35:19
  Speaker 3: sent them to from comments, there might not be a
• 1:35:22
  Speaker 3: good pace reason to not produce it, but we would
• 1:35:25
  Speaker 3: have to think about we'd have to talk about that together.
• 1:35:28
  Speaker 3: So what I suggest is that you bring all that
• 1:35:30
  Speaker 3: stuff into the office and we look at it carefully
• 1:35:32
  Speaker 3: together and we think about it. And possibly because if
• 1:35:35
  Speaker 3: we don't produce it, we're also not being able to
• 1:35:38
  Speaker 3: use it. And you know, and maybe you do want
• 1:35:41
  Speaker 3: to produce it. Maybe it's good for us, maybe it's not.
• 1:35:44
  Speaker 3: We'll think about that stright. So first of all, get
• 1:35:46
  Speaker 3: it all together in boxes, and you should try to
• 1:35:49
  Speaker 3: separate it by stuff that you think, stuff that you
• 1:35:52
  Speaker 3: think is fine to get to them, and then stuff
• 1:35:55
  Speaker 3: that you think is not fine. And also try to
• 1:35:57
  Speaker 3: label it by questions here okay, yeah.
• 1:36:00
  Speaker 2: Also right, and try to do this.
• 1:36:02
  Speaker 3: We have two more weeks still, it's due.
• 1:36:04
  Speaker 5: Well, if you can get it by the end.
• 1:36:05
  Speaker 3: Of the week, if you can get it sooner rather
• 1:36:07
  Speaker 3: than later, we're well within their deadline. And they don't
• 1:36:11
  Speaker 3: have any basis for the ways. That's that's all general stuff.
• 1:36:17
  Speaker 2: The other question is the because right on the internet. Yeah, okay,
• 1:36:23
  Speaker 2: if you want me to give you another copy, sure,
• 1:36:24
  Speaker 2: this one is going on, you know. And then the
• 1:36:27
  Speaker 2: other question is that what we talked about Wayne the beginning,
• 1:36:30
  Speaker 2: was the I.
• 1:36:31
  Speaker 5: Mean a print copy I was just taking. Is there
• 1:36:33
  Speaker 5: an email copy of it?
• 1:36:34
  Speaker 1: Yeah?
• 1:36:35
  Speaker 4: And your email? Yeah?
• 1:36:36
  Speaker 5: So can you see me because I don't, I don't know,
• 1:36:39
  Speaker 5: get them all.
• 1:36:40
  Speaker 3: Yeah.
• 1:36:41
  Speaker 2: There's also the sealed.
• 1:36:44
  Speaker 4: I think it was sent when this thing was being
• 1:36:46
  Speaker 4: copyright and some of the register whatever's that the Writers
• 1:36:48
  Speaker 4: Guild should match with what's in the sealed envelope, which
• 1:36:50
  Speaker 4: is addressed at my original address when I was writing
• 1:36:52
  Speaker 4: this thing.
• 1:36:53
  Speaker 3: Well, if it's an original sealed version, you don't need
• 1:36:55
  Speaker 3: to produce it. You just need to say the original
• 1:36:58
  Speaker 3: and you have a.
• 1:36:59
  Speaker 4: Copy perfect, because that would be inside this envelope with
• 1:37:03
  Speaker 4: the test with the notary signs statement from ninety to
• 1:37:07
  Speaker 4: ninety three. It's our ace card, so that has not
• 1:37:10
  Speaker 4: been opened, and it's sitting there with the testimony. It
• 1:37:13
  Speaker 4: would take a ball there, notarized script, the.
• 1:37:17
  Speaker 2: Story treatment testimony. That's not really okay, but that's right.
• 1:37:21
  Speaker 3: That's what we're talking about now is a whole bunch
• 1:37:23
  Speaker 3: of people's writing and notes on them. Okay, that's fine,
• 1:37:28
  Speaker 3: and those things. I mean personally, I.
• 1:37:31
  Speaker 2: Spend if we had to disclose that stuff. Now what
• 1:37:33
  Speaker 2: if we have to disclose that.
• 1:37:35
  Speaker 3: Now yeah, screenplace with versions and notes.
• 1:37:38
  Speaker 4: I don't know.
• 1:37:39
  Speaker 3: I mean it seems to be like we do, but
• 1:37:42
  Speaker 3: think we'll think about it. It's a problem. Then this
• 1:37:44
  Speaker 3: shouldn't be a bunch of versions with all these comments
• 1:37:47
  Speaker 3: from friends on them.
• 1:37:48
  Speaker 2: That's not bad people in the business.
• 1:37:50
  Speaker 5: Yeah.
• 1:37:51
  Speaker 3: So on the contrary, that's actually.
• 1:37:54
  Speaker 2: Good, really good, right, thanks for all that.
• 1:37:59
  Speaker 5: Yeah, awesome, thanks so yeah as thank you.
• 1:38:05
  Speaker 2: Yeah, thank you for a yuch.
• 1:38:09
  Speaker 4: Oh oh that's the other thing too, is one of
• 1:38:16
  Speaker 4: the other two