Greggs v. Grande and Guetta - Complaint PDF
Greggs v. Grande and Guetta - Complaint PDF
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Alan G. Dowling
(California Bar No. 70686)
Email: [email protected]
ALAN G. DOWLING, P.C.
1043 Pacific Street, No. 1
Santa Monica, California 90405
Telephone: (818) 679-6395
Fax: (424) 238-5366
Attorney for Plaintiff Alex Greggs,
professionally known as Alex G
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WESTERN DIVISION
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
vs.
Ariana Grande-Butera, an
individual, professionally known as
Ariana Grande, Pierre David
Guetta, an individual, professionally
known as David Guetta, Savan
Harish Kotecha, an individual,
professionally known as Savan
Kotecha, Giorgio Hesdey Tuinfort,
an individual, professionally known as
Giorgio Tuinfort, Rami Yacoub, an
individual, professionally known as
Rami, Carl Anthony Falk, an
individual, professionally known as
Carl Falk, Ilya Salmanzadeh, an
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
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Defendants.
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1.
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copyright infringement under the Copyright Act of the United States, 17 U.S.C.
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101, et seq.
ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
2.
the Court has federal question jurisdiction in this matter, in that Plaintiff seeks
injunctive relief and damages against the Defendants named herein under Sections
501, 502, 503, 504 and 505 of the Copyright Act of 1976 (17 U.S.C. 501-505,
inclusive);
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each resides in, is domiciled in and/or does systematic and continuous business in
the State of California and in this judicial district, various acts complained of herein
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occurred in the State of California and in this judicial district, and/or Defendants
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have caused injury to Plaintiff and to Plaintiffs intellectual property within the
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4.
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THE PARTIES
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PLAINTIFF
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5.
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Greggs and Alex G (Plaintiff), is now and at all times material hereto was an
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individual citizen of the United States of America, residing at some relevant times
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in the States of California and Florida, and currently residing in Toronto, Ontario,
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Canada. At all times material hereto, Plaintiff has done business throughout the
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United States, and in this judicial district. For many years, Plaintiff has been and is
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engaged in, among other things, the business of creating, composing, writing,
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
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Plaintiff has worked with some of the top names in pop, hip hop and
electronic and dance music, and is known internationally. His catalog includes
hundreds of musical compositions. Among the renowned artists for whom he has
the late Michael Jackson, Janet Jackson, N Sync, M.I.A., Ricky Martin, JC Chasez,
Brandy, T-Pain, Lil Jon, Ray J, South Rakkas Crew, Love Inc., Skye Stevens, Paris
Hilton, and Keshia Chante. As a prolific producer and mixer, Plaintiff has worked
with such artists as Christina Aguilera, the late Michael Jackson, Chris Brown,
Beck, Duran Duran, Janet Jackson, Jessica Simpson, Britney Spears, Pink, Justin
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Depeche Mode, Def Leppard, Enrique Iglesias, Julio Iglesias, Fall Out Boy, Good
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Charlotte, T-Pain, M.I.A., Akon, Calvin Harris, Lily Allen, Tinie Tempah, Cheryl
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Cole and Will.I.Am, Jessie James, Soulja Boy, South Rakkas Crew, Love Inc.,
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Skye Stevens, Tata Young, Tricky, Tiesto, A.D.D. (Audio Day Dream), and the 50th
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Anniversary Remixes of Bob Marley. Plaintiff has also ghost produced for many
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DEFENDANTS
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times material hereto has been an individual citizen of the United States of
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America, residing principally in the State of Florida. At all times material hereto,
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Ariana Grande has done business throughout the United States, including in this
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judicial district. On information and belief, Ariana Grande was a co-author of, and
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composition entitled "One Last Time, which musical composition was first
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registered
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PA0001941577, effective January 28, 2015 (the One Last Time Principal
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
with
the
U.S.
Copyright
Office,
under
registration
number
8.
professionally known as David Guetta (Guetta) is now and at all times material
presently unknown to Plaintiff. At all times material hereto, Guetta has done
business throughout the United States, including in this judicial district. Guetta is a
co-author of the One Last Time Principal Composition, and on information and
belief Guetta was a co-author of, and performer on, each of one or more sound
recordings of the One Last Time Principal Composition featuring the musical
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material hereto has been an individual citizen of The Netherlands, whose principal
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has done business throughout the United States, including in this judicial district.
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information and belief Tuinfort was a co-author of, co-producer of, and performer
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on, each of one or more sound recordings of the One Last Time Principal
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known as Carl Falk (Falk), is now and at all times material hereto has been an
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Plaintiff. At all times material hereto, Falk has done business throughout the
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United States, including in this judicial district. Falk is a co-author of the One Last
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Time Principal Composition, and on information and belief Falk was a co-author
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of, producer of, and performer on, each of one or more sound recordings of the One
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
Grande.
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
11.
known as Rami (Rami), is now and at all times material hereto has been an
Plaintiff. At all times material hereto, Rami has done business throughout the
United States, including in this judicial district. Rami is a co-author of the One
Last Time Principal Composition, and on information and belief Rami was a co-
author of, producer of, and performer on, each of one or more sound recordings of
the One Last Time Principal Composition featuring the musical performance of
Ariana Grande.
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material hereto has been an individual citizen of the United States of America,
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hereto, Kotecha has done business throughout the United States, including in this
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judicial district.
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Composition, and on information and belief Kotecha was a co-author of, co-
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producer of, and performer on, each of one or more sound recordings of the One
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Grande.
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On
information
and
belief,
Defendant
Ilya
Salmanzadeh,
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professionally known as Ilya (Ilya), is now and at all times material hereto has
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unknown to Plaintiff.
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throughout the United States, including in this judicial district. Ilya is a co-author
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of the One Last Time Principal Composition, and on information and belief Ilya
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was a co-author of, co-producer of, and performer on, each of one or more sound
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
recordings of the One Last Time Principal Composition featuring the musical
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
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known as Kendji Jirac (Kendji) is now and at all times material hereto has been
Plaintiff. At all times material hereto, Kendji has done business throughout the
United States, including in this judicial district. On information and belief, Kendji
is a co-author of, and featured performer on, each of one or more sound recordings
of the One Last Time Principal Composition featuring the musical performance of
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upon the One Last Time Principal Composition, with lyrics altered and/or translated
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professionally known as Fedez (Fedez) is now and at all times material hereto
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unknown to Plaintiff.
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throughout the United States, including in this judicial district. On information and
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belief, Fedez is a co-author of, and featured musical performer on, each of one or
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more sound recordings of the One Last Time Principal Composition featuring the
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One Last Time Italian Version), and a co-author of the musical composition
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embodied in the One Last Time Italian Version in so far as it is a derivative work
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based upon the One Last Time Principal Composition, with lyrics altered and/or
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translated into Italian, and music (including without limitation rap vocals) altered or
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added, as well.
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
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A Publishing) Inc., is now and at all times material hereto was a private limited
company duly organized and existing under and pursuant to the laws of the United
Kingdom, with its principal place of business in London, England, but doing
Defendant Shapiro Bernstein & Co., Inc., (Shapiro Bernstein), which is, on
information and belief, a corporation duly organized and existing under and
pursuant to the laws of the state of New York, with its principal place of business in
Shapiro Bernstein have each done business throughout the United States, including
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in this judicial district. On information and belief, What A Publishing is one of the
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publishers (if not the only publisher), and Shapiro Bernstein is either a co-publisher,
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Last Time Principal Composition, and may also have rights with regard to the
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on the One Last Time Principal Composition, including without limitation the
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compositions embodied in the Attends-Moi and One Last Time Italian Version
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sound recordings.
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(UMG) is now and at all times material hereto was a corporation duly organized
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and existing under and pursuant to the laws of the State of Delaware, with its
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doing business in the State of California. At all times material hereto, UMG has
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done business throughout the United States, including in this judicial district. At
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various times, UMG has been variously known as Universal Music Group,
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UMG and UMG Recordings, Inc. On information and belief, UMG is the
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parent corporation of Defendant Republic Records, the record label on which the
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
Ariana Grande recording of One Last Time was released and under whose auspices
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
the recordings of Attends-Moi and One Last Time Italian Version were released,
and UMG was thus involved in the production, recording, release, use, licensing
and other exploitation of the Ariana Grande recording of One Last Time, Attends-
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is now and at all times material hereto was division of UMG, with its principal
Republic has done business throughout the United States, including in this judicial
district. Republic was involved in the production, recording, release, use, licensing
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and other exploitation of the Ariana Grande recording of One Last Time, Attends-
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Recordings) is now and at all times material hereto was a corporation duly
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organized and existing under and pursuant to the laws of the State of Delaware,
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with its principal place of business in Santa Monica, California, and qualified to do
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and doing business in the State of California. At all times material hereto, UMG has
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done business throughout the United States, including in this judicial district. On
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information and belief, UMG is one of the entities through which UMG conducts
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its business as a record company, and was involved in the production, recording,
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release, use, licensing and other exploitation of the Ariana Grande recording of One
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(UMD), is now and at all times material hereto was a unit of Universal Music
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Group, Inc., with its principal place of business in Santa Monica, California. At all
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times material hereto, UMD has done business throughout the United States,
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including in this judicial district, and was one of the entities through which UMG
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
conducts its business as a record company, and was involved in the release,
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
distribution, use, licensing and other exploitation of the Ariana Grande recording of
One Last Time, Attends-Moi and One Last Time Italian Version.
information and belief, UMD is in some manner, related to, affiliated with, or a
Services, Inc. (UMDS), which is now and at all times material hereto was a
corporation duly organized and existing under and pursuant to the laws of the State
of Delaware, with its principal place of business in Santa Monica, California, and
qualified to do and doing business in the State of California. At all times material
hereto, UMDS has done business throughout the United States, including in this
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judicial district. On information and belief, UMDS is one of the entities through
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which UMG conducts its business as a record company, and was involved in the
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release, distribution, use, licensing and other exploitation of the Ariana Grande
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recording of One Last Time, Attends-Moi and One Last Time Italian Version.
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On further
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does business under the name Apple ITunes (Apple), is now and at all times
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material hereto was a corporation duly organized and existing under and pursuant to
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the laws of the State of California, with its principal place of business in Cupertino,
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California, and qualified to do and doing business in the State of California. At all
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times material hereto, Apple has done business throughout the United States,
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including in this judicial district. On information and belief, Apple is one of the
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entities through which the other Defendants released, distributed, sold and exploited
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the Ariana Grande recording of One Last Time, Attends-Moi and One Last Time
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Italian Version.
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unknown to Plaintiff, who therefore sues said defendants by such fictitious names
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
(the Doe Defendants). On information and belief, each of the Doe Defendants is
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
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the acts hereinafter set forth, is responsible in some manner for the occurrences
herein alleged, and Plaintiffs damages as herein alleged were proximately caused
by the acts or omissions of said Doe Defendant. Plaintiff will seek leave of Court
to amend this complaint to state the true names and capacities of the Doe
Defendants when they have been ascertained. The defendants specifically named in
the caption set forth herein above and the Doe Defendants are referred to
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of the Defendants was the agent, representative, employee, servant, partner, joint
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venturer and/or alter ego of each of the other Defendants and, in doing the things
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alleged in this complaint, was acting within the course and scope of such agency,
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relationship, with the knowledge and consent of the other Defendants, and each is
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liable to Plaintiff in connection with one or more of the claims sued upon herein
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and are responsible in some manner for the wrongful acts and conduct alleged
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herein.
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For many years, including at all times material hereto, Plaintiff has
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invested substantial sums of money, as well as time, effort, resources and creative
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talent, to create, produce, record, acquire, own, publish, license and otherwise
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exclusive rights, under United States copyright law with respect to the copyrighted
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musical composition Takes All Night (Takes All Night) which is the subject of
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
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Act (17 U.S.C. 106) with respect to the musical composition Takes All Night are
the following:
a.
b.
c.
d.
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e.
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f.
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licensing and other means of use and exploitation of the infringing musical
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compositions One Last Time Principal Composition, Attends-Moi and One Last
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a.
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b.
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Rami, Kotecha and Ilya) of the sound recording of One Last Time,
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
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c.
Ariana Grande, Guetta, Tuinfort, Falk, Rami, Kotecha, and Ilya, likely
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are not yet known to Plaintiff, but who Plaintiff shall seek leave to
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e.
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f.
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and/or authorized all versions of One Last Time, including the Ariana
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g.
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which Republic Records distributed One Last Time, and under whose
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auspices Attends-Moi and One Last Time Italian Version were allowed
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
to be distributed; and
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
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h.
of One Last Time in digital form, through its online ITunes Store.
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a.
the One Last Time Principal Composition, the Ariana Grande 2014-
2015 sound recording of One Last Time, the duet composition and
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b.
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images, published music (e.g., sheet music, lyrics, and the like), and so
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on;
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c.
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and among Defendants themselves and/or with third parties, for the
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ancillary thereto, for the use and exploitation of the infringing works;
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and
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d.
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
Ariana Grande, Kendji and Fedez, and others whose names are
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streamed, performances.
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Takes All Night and Once Last Time, are embodied in the chorus of each, which
also constitute the hook, or catchy, memorable section of each song that lyrically
coincides with the song title. The choruses in the two songs use a similar melodic
contour. Although the rhythm of the two compositions may differ to accommodate
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the prosody of the lyrics, there is substantial similarity on the most important
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rhythmic placement of the pitches on strong melodic and harmonic beats (1 and 3),
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which are what the listener perceives as most definitive of melody and, to a lesser
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remains the same in both songs for the entire sixteen measures of the chorus.
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Significantly, also, the introductions in both songs are based on the chorus
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sections. In both songs, the introduction is based on the same notes in the scale
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(when both songs have been transposed to the same key). These pitches align on the
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important rhythmic beats. Also notable is the use of a single four-measure musical
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phrase, based on a similar harmonic and melodic form in both works, as the
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material for both the verses and the choruses. Other similarities in the two songs
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(including the timing of the introduction of drum beats on the start of the verse), the
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use of repetition and variation in the chorus section and with return to a direct
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statement of the first phrase at the end of a sixteen measure chorus, the use of
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contrasting bridge material, the use of the lyric statement take(s) [or takeing]
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you home as the final lyric statement, and the use of particular melodic pitches,
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
their rhythmic placement, the pitch choices in the bass line, and the compositional
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
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structure of the songs, including the use of the introductions, interludes, pre-chorus
many similar elements of these kinds, used in the similar manner in which they are
used in the two songs, in the aggregate, evidences substantial similarity between the
works to such a degree that it is evident that the infringing work(s), One Last Time
Principal Composition, Attends-Moi and One Last Time Italian Version, are each
based upon, derived from and copied, to a substantial degree, the infringed work,
31.
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Principal Composition, had access to Takes All Night, that is, they had a reasonable
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opportunity to hear, view and copy Takes All Night, before the One Last Time
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Principal Composition and the various sound recordings thereof (or based thereon)
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were created. Takes All Night, as recorded and successfully released worldwide by
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club play, and high rankings on various Billboard and other charts. Skye Stephens
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performed the song on tour and in live performances at festivals and in clubs
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throughout the United States and Canada in particular, and also appeared on
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numerous radio shows, in addition to promoting the song through social media.
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Moreover, the similarity between Takes All Night and One Last Time is so striking
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that it is highly likely the works were not created independently of one another.
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32.
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summarizing Plaintiffs claims asserted herein, and demanding the Defendants, and
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each of them, cease and desist any further unauthorized infringing activities,
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
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34.
copyright in Takes All Night, as alleged herein, constitutes a separate and distinct
act of infringement.
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Defendants have been willful and intentional, in disregard of and with indifference
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36.
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37.
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and costs incurred in connection with this action, pursuant to 17 U.S.C. 505.
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this Court, will continue to cause Plaintiff great and irreparable injury that cannot
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
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40.
length each and all of the allegations set forth in Paragraphs 1 through 39, inclusive,
herein above.
41.
Through the conduct alleged herein, Defendants and each of them have
composition Takes All Night, including the creation of the various derivative works
and the infringing distribution, licensing, performances, and other uses and
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ratification, in violation of Sections 106 and 501 of the Copyright Act, 17 U.S.C.
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42.
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length each and all of the allegations set forth in Paragraphs 1 through 41, inclusive,
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herein above.
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43.
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to, intentionally induced, and/or caused each other, among others, to infringe
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Night, copied and used in the various versions of One Last Time musical
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the various versions of One Last Time, in various forms and by various means,
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
501 of the Copyright Act, 17 U.S.C. 106 et seq. and 501. Defendants and each
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
18
of them knew, or in the exercise of reasonable diligence should have known, of the
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44.
copyright infringement.
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45.
length each and all of the allegations set forth in Paragraphs 1 through 44, inclusive,
herein above.
46.
Defendants each had the right and ability to supervise and/or control
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the infringing conduct of Defendants Ariana Grande, Guetta, Tuinfort, Falk, Rami,
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Kotecha, and Ilya, among others, as the joint authors and joint producers of (and as
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the artists recording) One Last Time, in its various versions and forms, by insisting
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upon and verifying that adequate clearance documents and contracts (including
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without
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agreements, and the like) were executed by and with Plaintiff, from the outset,
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sufficient to authorize Defendants acts. All of the Defendants each likewise had
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the right and ability to supervise and/or control the infringing conduct of the
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as the infringing conduct of all others following those production Defendants in the
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chain of distribution, licensing, use and exploitation of the said infringing works, all
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the way down to the level of digital distribution and sale of the various versions of
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One Last Time to the general public via the Apple ITunes Store, the sale of compact
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disks, albums, singles and the like at wholesale and retail, the performance of the
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various versions of One Last Time in live performance and over radio, television,
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
limitation
copyright
license
agreements,
synchronization
license
and the Internet, via broadcast, cablecast, satellite transmission, streaming and
Greggs v. Ariana Grande-Butera, et al.,
USDC, CD Cal, Case No. 2:16-cv-06320
19
distribution, licensing, use and exploitation of the infringing works without any of
Defendants having first established that all necessary rights clearances and
Plaintiff.
47.
supervise and control the infringing conduct of others in the chain of creation,
production, distribution and exploitation of the various versions of One Last Time.
As a direct and proximate result of such failure and refusal, Plaintiffs copyrights in
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Plaintiffs copyrighted musical composition Takes All Night have been infringed, as
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and Section 501 of the Copyright Act, 17 U.S.C. 106 et seq. and 501.
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48.
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their own activities and from those of others in the chain of creation, production,
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49.
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PRAYER
WHEREFORE, Plaintiff prays for judgment in its favor and against
Defendants, as follows:
1.
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
2.
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3.
partners and assigns, and all persons acting in concert or participation with each of
composition Takes All Night, including without limitation an injunction against any
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future exploitation of the One Last Time Principal Composition, the Ariana Grande
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2014-2015 sound recording of One Last Time, the duet composition and sound
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recording Attends-Moi, and the duet composition and sound recording One Last
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4.
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5.
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6.
For such other and further relief in favor of Plaintiff as the Court may
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
Respectfully Submitted,
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Respectfully Submitted,
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ALAN G.
DOWLING, A
PROFESSIONAL
CORPORATION
SANTA MONICA, CA
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Case 2:16-cv-06320
Document
2 Filed
08/23/16
Page
1 of 3 Page ID #:23
UNITED STATES
DISTRICT COURT,
CENTRAL
DISTRICT
OF CALIFORNIA
CIVIL COVER SHEET
DEFENDANTS
(c) Attorneys (Firm Name, Address and Telephone Number) If you are
DEF
1. U.S. Government
Plaintiff
2. U.S. Government
Defendant
Citizen or Subject of a
Foreign Country
3 Foreign Nation
2. Removed from
State Court
3. Remanded from
Appellate Court
Yes
4. Reinstated or
Reopened
Yes
No
6. Multidistrict
Litigation Transfer
PTF
DEF
8. Multidistrict
Litigation Direct File
No
VI. CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a brief statement of cause.
CONTRACT
110 Insurance
120 Marine
400 State
Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce/ICC
Rates/Etc.
460 Deportation
470 Racketeer Influenced & Corrupt Org.
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/Exchange
890 Other Statutory
Actions
891 Agricultural Acts
893 Environmental
Matters
895 Freedom of Info.
Act
896 Arbitration
899 Admin. Procedures
Act/Review of Appeal of
Agency Decision
950 Constitutionality of
State Statutes
FOR OFFICE USE ONLY:
CV-71 (07/16)
IMMIGRATION
462 Naturalization
Application
PRISONER PETITIONS
Habeas Corpus:
PROPERTY RIGHTS
820 Copyrights
830 Patent
Other:
540 Mandamus/Other
465 Other
Immigration Actions
TORTS
PERSONAL PROPERTY
370 Other Fraud
FORFEITURE/PENALTY
625 Drug Related
Seizure of Property 21
USC 881
690 Other
840 Trademark
SOCIAL SECURITY
861 HIA (1395ff)
863 DIWC/DIWW (405 (g))
865 RSI (405 (g))
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff or
Defendant)
871 IRS-Third Party 26 USC
7609
LABOR
710 Fair Labor Standards
Act
720 Labor/Mgmt.
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor
Litigation
791 Employee Ret. Inc.
Security Act
2:16-cv-06320
Page 1 of 3
Case 2:16-cv-06320
Document
2 Filed
08/23/16
Page
2 of 3 Page ID #:24
UNITED STATES
DISTRICT COURT,
CENTRAL
DISTRICT
OF CALIFORNIA
CIVIL COVER SHEET
VIII. VENUE: Your answers to the questions below will determine the division of the Court to which this case will be initially assigned. This initial assignment is subject
to change, in accordance with the Court's General Orders, upon review by the Court of your Complaint or Notice of Removal.
QUESTION A: Was this case removed
from state court?
Yes
No
Western
Orange
Southern
Eastern
QUESTION B: Is the United States, or B.1. Do 50% or more of the defendants who reside in
the district reside in Orange Co.?
one of its agencies or employees, a
PLAINTIFF in this action?
Yes
No
QUESTION C: Is the United States, or C.1. Do 50% or more of the plaintiffs who reside in the
district reside in Orange Co.?
one of its agencies or employees, a
DEFENDANT in this action?
Yes
No
A.
Orange County
B.
Riverside or San
Bernardino County
C.
Los Angeles, Ventura,
Santa Barbara, or San
Luis Obispo County
Indicate the location(s) in which 50% or more of plaintiffs who reside in this district
reside. (Check up to two boxes, or leave blank if none of these choices apply.)
Indicate the location(s) in which 50% or more of defendants who reside in this
district reside. (Check up to two boxes, or leave blank if none of these choices
apply.)
D.1. Is there at least one answer in Column A?
Yes
No
Yes
No
SOUTHERN DIVISION.
EASTERN DIVISION.
WESTERN
Yes
No
Page 2 of 3
Case 2:16-cv-06320
Document
2 Filed
08/23/16
Page
3 of 3 Page ID #:25
UNITED STATES
DISTRICT COURT,
CENTRAL
DISTRICT
OF CALIFORNIA
CIVIL COVER SHEET
IX(a). IDENTICAL CASES: Has this action been previously filed in this court?
NO
YES
NO
YES
IX(b). RELATED CASES: Is this case related (as defined below) to any civil or criminal case(s) previously filed in this court?
If yes, list case number(s):
Civil cases are related when they (check all that apply):
A. Arise from the same or a closely related transaction, happening, or event;
B. Call for determination of the same or substantially related or similar questions of law and fact; or
C. For other reasons would entail substantial duplication of labor if heard by different judges.
Note: That cases may involve the same patent, trademark, or copyright is not, in itself, sufficient to deem cases related.
A civil forfeiture case and a criminal case are related when they (check all that apply):
A. Arise from the same or a closely related transaction, happening, or event;
B. Call for determination of the same or substantially related or similar questions of law and fact; or
C. Involve one or more defendants from the criminal case in common and would entail substantial duplication of
labor if heard by different judges.
X. SIGNATURE OF ATTORNEY
(OR SELF-REPRESENTED LITIGANT): /s/ Alan G. Dowling
Notice to Counsel/Parties: The submission of this Civil Cover Sheet is required by Local Rule 3-1. This Form CV-71 and the information contained herein
neither replaces nor supplements the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. For
more detailed instructions, see separate instruction sheet (CV-071A).
Abbreviation
861
HIA
862
BL
All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. (30 U.S.C.
923)
863
DIWC
All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, as amended; plus
all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405 (g))
863
DIWW
All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security Act, as
amended. (42 U.S.C. 405 (g))
864
SSID
All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security Act, as
amended.
865
RSI
All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended.
(42 U.S.C. 405 (g))
CV-71 (07/16)
Page 3 of 3