Académique Documents
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WESTERN DIVISION
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vs.
LED ZEPPELIN, et al.,
Defendants.
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facts and could competently testify to those facts if called upon to do so.
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I, along with Jimmy Page, John Paul Jones and the late John Bonham,
I first heard what would become the song Stairway to Heaven at Headley
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Grange in England in November 1970. Jimmy Page played on his guitar the music he
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had written. I wrote the lyrics to go with the Jimmys music for Stairway to Heaven
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while the song was worked on by the band in rehearsals for its recording. Stairway to
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Heaven was recorded in December 1970 to January 1971 in London, England. It was
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first performed at a Led Zeppelin concert in March 1971 at Ulster Hall in Belfast,
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London, England, was included in the Led Zeppelin album usually referred to as Led
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matter. It has no lyrics and has nothing to do with my lyrics for Stairway to Heaven.
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7.
Led Zeppelin and the band Spirit never performed together and were
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available to me, the only occasions when Led Zeppelin performed at the same venue
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on the same date on which Spirit was scheduled to perform were: the Auditorium
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Arena in Denver, Colorado, on December 26, 1968, the Atlanta International Pop
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Festival at the Atlanta Speedway in Atlanta, Georgia, on July 5, 1969 and the Seattle
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Pop Festival in Woodinville, Washington, on July 27, 1969. The latter two events
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Colorado, the day after Christmas in 1968, opening for Vanilla Fudge. I understand
that Spirit also performed that night, but I do not recall seeing or hearing Spirits
performance.
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10.
Mothers was a club near my home in England that was popular with
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musicians who lived nearby in the period 1968 through 1970. When I was home, I
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often met friends there. The club had a long room with a stage at one end and a bar at
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the other. I would meet friends at the bar. I have no recollection of seeing Spirit
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perform at Mothers.
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12.
I am advised that a member of Spirit claims that I went to a pub with him
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following their performance at Mothers. That is not possible. The pubs in England
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were required to close by 10 p.m., which is before the shows at Mothers typically
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ended. On January 31, 1970, I had a car accident returning from Mothers with my
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wife. She had been with me at the club and we were returning home together, having
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December 1968, Led Zeppelin performed live concerts in England and Scandinavia
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that included Led Zeppelins performance of the song As Long As I Have You in a
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medley with other songs. John Bonham and I had performed the song As Long As I
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Have You before we joined Led Zeppelin. John Paul Jones used a short bass riff,
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similar to the bass riff in the song Fresh Garbage, over which I sang other songs in the
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medley in Led Zeppelins earliest concert tours. At the time, I had a record album
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