Exhibits 1 To 5 (Skidmore v. Led Zeppelin "Stairway To Heaven" Lawsuit)

Case 2:15-cv-03462-RGK-AGR Document 210-1 Filed 05/09/16 Page 1 of 75 Page ID
#:5512
EXHIBIT 1

#:5513
From:
To:
Cc:
Subject:
Date:
Peter J. Anderson
Malofiy, Francis Alexander
Helene M. Freeman
Skidmore
Friday, March 25, 2016 2:43:00 PM
Francis:
Im following up regarding scheduling expert depositions. Since you havent provided
dates I propose the following (some experts didnt state their place of residence or
business, so please let me know asap if Ive got their cities wrong):
Stewart: April 6 in Burlington, VT, with a 9 or 9:30 a.m. start.
Bricklin, Johnson, Hanson and Somach: April 7 in Philadelphia, as follows:
o
o
o
o
Bricklin at 9 a.m.
Johnson at 11:00 a.m.
Hanson at 3:00 p.m.
Somach at 4:30 p.m.
Einhorn: April 8 in New Jersey, with a 9 or 9:30 a.m. start.

Please let me know if these dates work for you and these gentlemen, and also please
get back to me as to whether they will accept service of their subpoenas.
Thanks.
Peter.
______________________________
The Law Offices of Peter J. Anderson
A Professional Corporation
100 Wilshire Boulevard
Suite 2010
Santa Monica, CA 90401
Telephone: (310) 260-6030
Fax: (310) 260-6040
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THIS E-MAIL AND ANY ATTACHMENTS.
EXHIBIT 1
11

#:5514
From:
To:
Cc:
Subject:
Date:
Attachments:
Peter J. Anderson
Malofiy, Francis Alexander
Helene M. Freeman
RE: Skidmore
Monday, March 28, 2016 2:47:00 PM
Nottice of Subpoenas.pdf
Francis:
Since I didnt hear back from you, attached is a courtesy copy of the notice served
today of the subpoenas issued for your expert witnesses, for the dates proposed
below.
Of course, I remain willing to schedule these for other dates if we can reach
agreement on those dates beforehand.
Finally, I again ask that you let me know if your witnesses will accept service of their
subpoenas. Alternatively, please immediately provide their addresses, which were
not included with their disclosures.
Best regards.
Peter.
EXHIBIT 1
12

#:5515
From:
To:
Cc:
Subject:
Date:
Francis Alexander Malofiy

Peter J. Anderson; Helene M. Freeman
Francis Alexander Malofiy; AJ Fluehr; Glen Kulik
RE: Skidmore
Monday, March 28, 2016 2:59:39 PM
Dear Peter,
I will get back to you by Wednesday of this week.
*****
With every good wish, I am,
Francis Malofiy, Esquire
Francis Alexander, LLC
280 N. Providence Road | Suite 105
Media, PA 19063
T: (215) 500-1000
F: (215) 500-1005
E: [email protected]
EXHIBIT 1
13

#:5516
From:
To:
Cc:
Subject:
Date:
Peter J. Anderson
"Francis Alexander Malofiy"; "Helene M. Freeman"
"AJ Fluehr"; "Glen Kulik"
RE: Skidmore
Monday, March 28, 2016 3:01:00 PM
Francis:
Okay, but in the meantime please provide the experts addresses so that I can make
arrangements to have them served if they decline to accept service.
Thanks.
Peter.
EXHIBIT 1
14

#:5517
From: Peter J. Anderson [mailto:[email protected]]

Sent: Wednesday, March 30, 2016 12:36 PM
To: 'Francis Alexander Malofiy'
Cc: 'AJ Fluehr'; 'Glen Kulik'; 'Helene M. Freeman'
Subject: RE: Skidmore
Francis:
I do need to hear from you about the expert depositions and their addresses and
subpoenas. If you dont get back to me and dont provide addresses, that will be
another reason we will raise that you cant call your experts.
Also, we havent heard from you regarding conferring re exhibits and such. When do
you want to have that conference?
Best regards.
Peter.
EXHIBIT 1
15

#:5518
From: Francis Alexander Malofiy [mailto:[email protected]]

To: Peter J. Anderson; Helene M. Freeman
Cc: Francis Alexander Malofiy; AJ Fluehr; Glen Kulik
Peter,
Im confused by your request.
The Discovery Cut-Off Date identified by Judge Klausners Order was February 11, 2016. See attached
Order.
The deadline to conduct discovery and depositions has long passed.
Kindly review Judge Klausners Orders:
In regards to Discovery Cut-Off:
The Court has established a cut-off date for discovery in this action [February 11, 2016]. All discovery
shall be complete by the discovery cut-off date specified in the Scheduling Order. This is not the date by
which discovery requests must be served; it is the date by which all discovery is to be completed.
In regards to Depositions:
All depositions shall be scheduled to commence sufficiently in advance of the discovery cut-off date
[February 11, 2016] to permit their completion and to permit the deposing party enough time to bring
any discovery motion concerning the deposition prior the cut-off date.
Peter, if you recall, I had repeatedly reached out to you with the hopes of addressing the expert
discovery issue and extending the discovery deadline so that we would have ample time to conduct
expert depositions. You refused to submit a joint stipulation to extend the deadlines or set the expert
deadlines.
*****
Media, PA 19063
T: (215) 500-1000
F: (215) 500-1005
EXHIBIT 1
16

#:5519
From: Peter J. Anderson [mailto:[email protected]]

To: 'Francis Alexander Malofiy'; 'Helene M. Freeman'
Cc: 'AJ Fluehr'; 'Glen Kulik'
Francis:
Feigning confusion is very dangerous for you and your client, both because the Court
will not buy it and because if you refuse to cooperate and disclose the experts
addresses you are likely, and perhaps certainly, going to be precluded from calling
them.
February 11, 2016 was the fact discovery cut-off and these are expert, not fact,
depositions. Also, since the Court left experts to code, expert disclosures were due
and provided on February 10, 2016. It is absurd for you to suggest that the depositions
of the experts disclosed on February 10, 2016, as well as any rebuttal experts disclosed
in March, 30 days later, were supposed to occur by February 11.
I ask you once again to cooperate in the taking of these expert depositions and, if you
refuse to arrange for them to accept service of their deposition subpoenas, provide the
experts addresses.
Peter.
EXHIBIT 1
17

#:5520
From:
To:
Cc:
Subject:
Date:
Attachments:
Glen Kulik
Francis Alexander Malofiy; Peter J. Anderson; Helene M. Freeman
AJ Fluehr
RE: Skidmore
Wednesday, March 30, 2016 4:40:46 PM
image001.png
I wasnt directly involved in the scheduling but the order does say Discovery Cut Off Date. If the judge meant percipient
witness cut-off date only then in my experience he would have distinguished, or he would have set a separate date for expert
discovery cut off. Isnt that your experience, too, Peter?
___________________________________________________________________________
Glen L. Kulik, Esq.
KULIK GOTTESMAN SIEGEL & WARE LLP
15303 Ventura Boulevard, Suite 1400
Sherman Oaks, California 91403
(310) 557-9200
Main
(310) 557-0224
Fax
___________________________________________________________________________
This electronic message contains information which may be confidential and privileged and is intended only for the named addressee. Unless you are the
addressee of this message you may not use, copy or disclose the contents of this message to anyone. If you have received this message in error, please delete
the message and advise the sender by reply e-mail or by calling (310) 557-9200. Thank you.
To ensure compliance with Internal Revenue Service Circular 230, we inform you that any U.S. Federal Tax advice contained in this communication is not
intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or
recommending to another party any tax-related matter(s) addressed herein.
EXHIBIT 1
18

#:5521
From:
To:
Cc:
Subject:
Date:
Attachments:
Peter J. Anderson
"Glen Kulik"; "Francis Alexander Malofiy"; "Helene M. Freeman"
"AJ Fluehr"
RE: Skidmore
image001.png
He also said that morning that he was leaving experts to code, meaning the FRCP 26 default provisions,
which necessarily means that expert depositions occur after the fact discovery cut-off. Theres no getting
around that Glen.
EXHIBIT 1
19

#:5522
From:
To:
Cc:
Subject:
Date:
Attachments:
Glen Kulik
Peter J. Anderson; Francis Alexander Malofiy; Helene M. Freeman
AJ Fluehr
RE: Skidmore
image002.png
image003.png
Peter,
What specific language are you referring to in Rule 26?
EXHIBIT 1
20

#:5523
From:
To:
Cc:
Subject:
Date:
Attachments:
Peter J. Anderson
"AJ Fluehr"
RE: Skidmore
image001.png
Rule 26(a)(2)(D) It provides that absent the court setting or the parties agreeing to a different schedule, the
default is initial expert disclosures go out 90 days before the trial date, etc., and 90 days before the trial date
was February 10, the day before the discovery cut-off.
EXHIBIT 1
21

#:5524
From:
To:
Cc:
Subject:
Date:
Attachments:
Glen Kulik
AJ Fluehr
RE: Skidmore
image002.png
image003.png
Ok, Im aware of that language but it has to do with expert disclosures, not expert depositions. I dont recall Rule 26 saying
anything about the timing of expert depositions. When the judge mentioned the default date, I have a faint recollection he
meant for expert designations.
As for whether the schedule was logical, Ive seen a few examples the last two months where I thought the schedule set by the
court did not make sense in hindsight, but the judge does not seem inclined to modify it.
EXHIBIT 1
22

#:5525
From:
To:
Cc:
Subject:
Date:
Attachments:
Peter J. Anderson
"AJ Fluehr"
RE: Skidmore
image001.png
Im not sure what to make of your e-mail, but the fact remains that (1) we could not have possibly taken the
expert depositions before the February 11, 2016 discovery cut-off date and (2) we cannot assume that the
Judge meant to prevent the parties from taking expert depositions. That leads inexorably to the conclusion
that the February 11 date didnt apply to experts.
EXHIBIT 1
23

#:5526
From:
To:
Cc:
Subject:
Date:
Attachments:
Peter J. Anderson
"AJ Fluehr"
RE: Skidmore
image001.png
And, to add to that: Rule 26(b)(4)(A) expressly directs that parties are entitled to depose those identified as
experts.
EXHIBIT 1
24

#:5527
From:
To:
Cc:
Subject:
Date:
Attachments:
Glen Kulik
AJ Fluehr
RE: Skidmore
image002.png
image003.png
I dont know what was intended but I know what the order says, and it refers to discovery cut-off without making any
distinction between expert discovery and percipient witness discovery.
That said, I see that youve proposed Friday to meet and confer with Francis so hopefully hell be available and youll work
something out.
EXHIBIT 1
25

#:5528
From:
To:
Cc:
Subject:
Date:
Attachments:
Glen Kulik
AJ Fluehr
RE: Skidmore
image002.png
image003.png
Of course there is a right to depose experts, just as there is the right to depose percipient witnesses. But there is a cut-off.
EXHIBIT 1
26

#:5529
From:
To:
Cc:
Subject:
Date:
Attachments:
Peter J. Anderson
"AJ Fluehr"
RE: Skidmore
image001.png
image002.png
Rule 26(b)(4)(A) is specific to deposing experts, and that confirms experts are treated separately from
percipient witnesses. Otherwise, there would be no need for Rule 26(b)(4)(A).
And, with all respect, it makes no sense to acknowledge that we have the right to depose the experts you
identified on February 10, 2016 but, as Francis and perhaps you contend, we had to do so by February 11,
2016.
The position plaintiff is taking is untenable and the consequences of taking that untenable position include
adding to the reasons plaintiff is properly precluded from calling these experts.
EXHIBIT 1
27

#:5530
From:
To:
Cc:
Subject:
Date:
Attachments:

RE: Skidmore
image001.png
image005.png
image006.png
image010.png
Dear Peter,
It was Plaintiff who complained that expert discovery would not be completed before the February 25, 2016 deadline for
dispositive motions. This was an issue we discussed at length. Both sides attempted to come up with a proposed schedule for
expert disclosures and depositions. In the end you, Peter, refused to enter into a joint stipulation to set the expert disclosures
and depositions so that both sides with have time to conduct the depositions.
Plaintiff was forced to file a motion with the court to extend expert disclosures and depositions.
You, Peter, opposed that motion and opposed setting a time for expert disclosures and depositions.
In fact, Judge Klausner was clear that he would not entertain any of the set deadlines including Expert Reports or Expert
Depositions. See below:
EXHIBIT 1
28

#:5531
Theres no getting around the fact that Plaintiff addressed the exact issue of Expert Depositions with the Court, you opposed
the extensioneven as it related to expert depositions! The Court ruled and DENIED any extension of Expert Depositions.
Theres no getting around that fact Peter.
You cant decide that the Courts ruling is no longer applicable because it no longer favors your client. That would be
gamesmanship. Plaintiff will not agree to violate Judge Klausners Order.
*****
Media, PA 19063
T: (215) 500-1000
F: (215) 500-1005
EXHIBIT 1
29

#:5532
From:
To:
Cc:
Subject:
Date:
Attachments:
Peter J. Anderson
"Francis Alexander Malofiy"; "Helene M. Freeman"
"AJ Fluehr"; "Glen Kulik"
RE: Skidmore
image002.png
image003.png
image004.png
image005.png
Francis:
You are confusing issues: the judges denial of your request to move the dates, including when expert
disclosures would be provided, has nothing to do with deposing experts after they have been identified.
Defendants have the express right under Rule 26(b)(4)(A) to take the depositions of those you identified as
experts. If you continue to refuse to cooperate and dont provide their addresses, you solidify yet another
reason that you cant call the experts. Its that simple.
Best regards.
Peter.
EXHIBIT 1
30

#:5533
From:
To:
Cc:
Subject:
Date:
Attachments:
Glen Kulik
AJ Fluehr
RE: Skidmore
image001.png
image002.png
image003.png
image004.png
image005.png
You havent provided any authority that you have a right to conduct expert depositions after the discovery cut-off date set by
the court. You have given us authority on the default date to disclose experts. You have given us authority that parties have a
right to take expert depositions, just as they have a right to depose percipient witnesses. You are correct on both of those
points. But youve given us no authority which says that you have a right to take discovery after the deadline set by the court
for discovery cut off.
EXHIBIT 1
31

#:5534
From:
To:
Cc:
Subject:
Date:
Attachments:
Peter J. Anderson
"AJ Fluehr"
RE: Skidmore
image001.png
image002.png
image003.png
image004.png
This is not productive. It is patently absurd for you to suggest that the Court cut off expert discovery on
February 11, with expert disclosures left to code and initial expert disclosures due February 10 and
rebuttal disclosures due a month later. But, if thats the position you and Francis continue to take, you take
the position knowing full well the consequences.
EXHIBIT 1
32

#:5535
EXHIBIT 2

#:5536
From:
To:
Cc:
Subject:
Date:
Peter J. Anderson
Helene M. Freeman; Glen Kulik; AJ Fluehr
Re: Skidmore
Tuesday, April 05, 2016 7:00:11 AM
Francis:
I'm leaving for a mediation and will be out of the office all day, and I haven't had a chance to
review your filings, but please send us a Word copy of your exhibit and witness lists so that
we can shoot for getting you back revised joint versions tomorrow.
I won't comment on the rest of your e-mail, but please also note that I'll be re-noticing the
depositions of Dr. Stewart et al. and, accordingly, their depositions won't be proceeding this
week.
Best regards.
Peter.
On Tue, Apr 5, 2016 at 1:00 AM, Francis Alexander Malofiy
<[email protected]> wrote:
Dear Peter,
As you know, I was under the weather and Plaintiff was under time constraints to get the
Contentions of Fact & Law filed, along with the Witness List and Exhibit List.
In regards to the Witness List which Plaintiff filed:

I combined Plaintiffs Witness List with Defendants Witness List. I labeled it as follows and filed it
with the Court:
WITNESS LIST (COMBINED) FILED BY PLAINTIFF MICHAEL SKIDMORE, AS TRUSTEE FOR THE RANDY
CRAIG WOLFE TRUST
Please note that I did not call it a Joint Witness List because you didnt have the opportunity to
review it and for that reason I also did not put your name to the bottom of it.
In regards to the Exhibit List which Plaintiff filed:

I combined Plaintiffs Exhibit List with Defendants Exhibit List. I labeled it as follows and filed it
with the Court:
EXHIBIT 2
33

#:5537
EXHIBIT LIST (Combined)
Please note that I did not call it a Joint Witness List because you didnt have the opportunity to
review it and for that reason I also did not put your name to the bottom of it.
Additionally, please notice that I initially broke down our Exhibits by Deposition. Additionally, I
started Defendants Exhibit at 1000 rather than 1 so that there would not be overlap with the
Exhibits which we marked and used throughout the depositions and throughout the case. So,
Plaintiffs Exhibits are 0-999. Defendants are 1000 on up. I figured this would make it easier for
the Court and for both sides in working with the exhibits, depositions, and at time of trial.
I will be filing either Declaration and/or Notice of Errata with the Court tomorrow to address the
above. I would still like to get a Joint Witness List and Joint Exhibit List to the Court. I am hoping
we can work together in the coming days/weeks towards this goal. Of course, we will need to do
so for trial, regardless, as the final Meet & Confer regarding Exhibits is Friday, April 29, 2016.
Will you be available to discuss the above tomorrow? Please share with me a time that works for
you. Thank you.
*****
Media, PA 19063
T: (215) 500-1000
F: (215) 500-1005
EXHIBIT 2
34

#:5538
EXHIBIT 3

#:5539
From:
To:
Cc:
Subject:
Date:
Attachments:

LED ZEPPELIN - EXPERT REPORTS (SERVED)
Monday, May 02, 2016 11:58:36 PM
2016.05.02 - FINAL - Amended Expert Report of
C.V. Alexander Stewart 2016 (selected).pdf
Erik Johnson (SERVED).pdf

Brian Bricklin (SERVED).pdf
Kevin Hanson (SERVED).pdf
Alexander Stewart (SERVED).pdf
Dear Peter,
Please see attached expert reports.
*****
NOTE: ADDRESS CHANGED TO SUITE 1

*****
Media, PA 19063
T: (215) 500-1000
F: (215) 500-1005
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EXHIBIT 5

#:5586
From:
To:
Cc:
Subject:
Date:
Attachments:
Glen Kulik
Peter J. Anderson
[email protected]; Francis Alexander Malofiy ([email protected])
Expert Depositions
Saturday, May 07, 2016 8:40:41 AM
image001.png
Peter,
We respond again on the subject of your request to take expert depositions. We have been consistently telling you since
March that your right to do so expired. The discovery cut-off date was in February. At that time we sought your cooperation
in extending the deadline. Not only did you decline to cooperate, you opposed our efforts to obtain more time for the
parties to complete discovery and the court denied our application. In addition, you withdrew your subpoenas for expert
depositions, failed to file a motion to extend the deadline, did not raise the issue with Court at the Pretrial Conference, and
are now attempting to take advantage of the unexpected continuance of the trial date. When we were notified of the trial
continuance, the court said nothing about re-opening discovery.
If you intended to raise this issue again you should have brought it to the attention of the judge at the Pretrial Conference.
Francis and I raised certain issues at that time but you did not. Thus, we respectfully repeat what we told you before, that
absent a court order re-opening discovery or extending the Court-mandated deadline,
it is our position that the right to take expert depositions has expired.
Thank you for your courtesy and cooperation.
Glen Kulik
___________________________________________________________________________y
Glen L. Kulik, Esq.
KULIK GOTTESMAN SIEGEL & WARE LLP
15303 Ventura Boulevard, Suite 1400
Sherman Oaks, California 91403
(310) 557-9200
Main
(310) 557-0224
Fax
___________________________________________________________________________
This electronic message contains information which may be confidential and privileged and is intended only for the named addressee. Unless you are the
addressee of this message you may not use, copy or disclose the contents of this message to anyone. If you have received this message in error, please delete
the message and advise the sender by reply e-mail or by calling (310) 557-9200. Thank you.
To ensure compliance with Internal Revenue Service Circular 230, we inform you that any U.S. Federal Tax advice contained in this communication is not
intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or
recommending to another party any tax-related matter(s) addressed herein.
EXHIBIT 5
80

Exhibits 1 To 5 (Skidmore v. Led Zeppelin "Stairway To Heaven" Lawsuit)

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Case 2:15-cv-03462-RGK-AGR Document 210-1 Filed 05/09/16 Page 1 of 75 Page ID

Case 2:15-cv-03462-RGK-AGR Document 210-1 Filed 05/09/16 Page 2 of 75 Page ID

Einhorn: April 8 in New Jersey, with a 9 or 9:30 a.m. start.

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Francis Alexander Malofiy

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From: Peter J. Anderson [mailto:[email protected]]

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From: Francis Alexander Malofiy [mailto:[email protected]]

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From: Peter J. Anderson [mailto:[email protected]]

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Francis Alexander Malofiy

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In regards to the Witness List which Plaintiff filed:

In regards to the Exhibit List which Plaintiff filed:

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Francis Alexander Malofiy

Erik Johnson (SERVED).pdf

NOTE: ADDRESS CHANGED TO SUITE 1

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