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Case 2:15-cv-03462-RGK-AGR Document 301 Filed 07/19/16 Page 1 of 9 Page ID #:9040

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Francis Malofiy, Esq.


Francis Alexander, LLC
280 N. Providence Rd. | Suite 1
Media, PA 19063
T: (215) 500-1000; F: (215) 500-1005
E: francis@francisalexander.com
Attorney for Plaintiff
Glen L. Kulik, Esq. (SBN 082170)
Kulik Gottesman & Siegel LLP
15303 Ventura Blvd., Suite 1400
Sherman Oaks, CA 91403
T: (310) 557-9200; F: (310) 557-0224
E: gkulik@kgslaw.com
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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MICHAEL SKIDMORE, as Trustee for


15 the RANDY CRAIG WOLFE TRUST,
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Hon. R. Gary Klausner

Plaintiff,
DECLARATION OF AJ FLUEHR IN
OPPOSITION TO DEFENDANTS
MOTIONS FOR COSTS AND FEES

v.

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

LED ZEPPELIN; JAMES PATRICK


PAGE; ROBERT ANTHONY PLANT;
JOHN PAUL JONES; SUPER HYPE
PUBLISHING, INC.; WARNER MUSIC
GROUP CORP., Parent of
WARNER/CHAPPELL MUSIC, INC.;
ATLANTIC RECORDING
CORPORATION; RHINO
ENTERTAINMENT COMPANY,

Filed concurrently with Motion


Response; and [Proposed] Order
Trial Date: August 8, 2016
Time:
1 p.m.
Courtroom: 850

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Defendants.

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DECLARATION OF AJ FLUEHR IN OPPOSITION TO
DEFENDANTS MOTIONS FOR COSTS AND FEES

Case 2:15-cv-03462-RGK-AGR Document 301 Filed 07/19/16 Page 2 of 9 Page ID #:9041

I, AJ Fluehr, declare:

1.

I am an attorney in the law firm of Francis Alexander, LLC, and I

represent Plaintiff Michael Skidmore, as Trustee for the Randy Craig Wolfe Trust in

the above-captioned matter. I have personal knowledge of the facts recited below,

and, if called as a witness, I could and would testify competently to the facts

contained in this declaration.

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2.

Defendants have complained that a photograph depicting Robert Plant

and Mark Andes speaking while Mr. Andes was a member of Heart was altered.

3.

I have personal knowledge that this is absolutely false.

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4.

While compiling the exhibit list, I was given a link to the Getty Images

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website and subsequently screenshotted the photo. Attached as Exhibit 1 is the

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picture

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http://www.gettyimages.co.uk/event/classic-entertainment-bestsellers-from-hulton-

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archive-1980s-146427040#british-musician-robert-plant-visits-members-of-the-

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rock-group-heart-picture-id3460358.

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5.

included

in

the

exhibit

list.

The

link

is:

At the time I screenshotted the picture, I did not realize that the Getty

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Images website had automatically cropped the picture based on the size of the

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browser window (I was using Firefox).

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6.

Attached as Exhibit 2 is a full screen shot of the Firefox browser

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demonstrating how the Getty Images website subtly crops the photo based on

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window size. Attached as Exhibit 3 is the full photo.

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7.

Defendants accusation that the photo was altered is completely false,

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and any cropping of the photo was unintentional. Nothing about this photo was

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altered.

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8.

Defendants were given the full photo by local counsel Glen Kulik

which clearly refutes Robert Plants denial that he knew Mark Andes.
I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
DECLARATION OF AJ FLUEHR IN OPPOSITION TO
DEFENDANTS MOTIONS FOR COSTS AND FEES

Case 2:15-cv-03462-RGK-AGR Document 301 Filed 07/19/16 Page 3 of 9 Page ID #:9042

Executed this 19th day of July, 2016 at Media, PA.

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/s/ AJ Fluehr
AJ Fluehr

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DECLARATION OF AJ FLUEHR IN OPPOSITION TO
DEFENDANTS MOTIONS FOR COSTS AND FEES

Case 2:15-cv-03462-RGK-AGR Document 301 Filed 07/19/16 Page 4 of 9 Page ID #:9043

Exhibit 1

Case 2:15-cv-03462-RGK-AGR Document 301 Filed 07/19/16 Page 5 of 9 Page ID #:9044

535-0001

Case 2:15-cv-03462-RGK-AGR Document 301 Filed 07/19/16 Page 6 of 9 Page ID #:9045

Exhibit 2

Case 2:15-cv-03462-RGK-AGR Document 301 Filed 07/19/16 Page 7 of 9 Page ID #:9046

Case 2:15-cv-03462-RGK-AGR Document 301 Filed 07/19/16 Page 8 of 9 Page ID #:9047

Exhibit 3

K-AGR Document 301 Filed 07/19/16 Page