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Case 2:15-cv-03462-RGK-AGR Document 230-2 Filed 06/11/16 Page 1 of 3 Page ID

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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


the RANDY CRAIG WOLFE TRUST,

Hon. R. Gary Klausner

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Plaintiff,

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

v.
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,

[PROPOSED] ORDER GRANTING


PLAINTIFFS MOTION FOR
SANCTIONS AND TO PRECLUDE
DR. LAWRENCE FERRARA FROM
TESTIFYING AT TRIAL

Date: June 14, 2016


Time: 9:00 a.m.
Courtroom: 850

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Defendants.

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ALTERNATIVE [PROPOSED] ORDER GRANTING PLAINTIFFS MOTION FOR SANCTIONS AND


TO PRECLUDE DR. FERRARA FROM TESTIFYING AT TRIAL

Case 2:15-cv-03462-RGK-AGR Document 230-2 Filed 06/11/16 Page 2 of 3 Page ID


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ORDER RE: RE: MOTION FOR SANCTIONS

The Court having considered the MOTION TO COMPEL AND SANCTION of

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

and reply papers and the oral argument at the hearing on the Motion, the Court rules as

follows:

IT IS HEREBY ORDERED

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That Plaintiffs Motion be and hereby is GRANTED and that Dr. Ferrara is
precluded from testifying at trial because of

- Dr. Ferraras conflict of interest in having previously worked for Plaintiffs

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publisher on the exact subject material in dispute for this case,

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- Defendants failure to disclose a known conflict,

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- Defendants failure to provide documents requested by Plaintiff,

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- Defendants attempt to conceal the conflict,

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- Defendants coaching of a witness, and Defendants frivolous objections:

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Defendants are ordered under 1927 to pay the costs and fees for the deposition of Dr.

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Ferrara, including Dr. Ferraras expert witness fee because of

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- Defendants bad faith failure to disclose a known conflict,

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- Defendants failure to provide documents requested by Plaintiff,

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- Defendants attempt to conceal the conflict,

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- Defendants coaching of a witness, and

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- Defendants frivolous objections:

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Defendants and Dr. Lawrence Ferrara are ordered to produce by Wednesday, June 15,

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2016:

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- Any and all communications (and related documents) between Dr. Ferrara and

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Rondor Music, Universal Music Publishing Group, and/or Hollenbeck Music

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concerning Taurus and/or Stairway to Heaven, or the instant lawsuit.

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- Any and all communications (and related documents) between Dr. Ferrara and

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Defendants and defense counsel concerning Dr. Ferraras previous engagement


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ALTERNATIVE [PROPOSED] ORDER GRANTING PLAINTIFFS MOTION FOR SANCTIONS AND
TO PRECLUDE DR. FERRARA FROM TESTIFYING AT TRIAL

Case 2:15-cv-03462-RGK-AGR Document 230-2 Filed 06/11/16 Page 3 of 3 Page ID


#:6285
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with Rondor Music, Universal Music Publishing Group, and/or Hollenbeck

Music concerning Taurus and/or Stairway to Heaven.

- Any

and

all

communications

(and

related

documents)

between

Defendants/defense counsel and Rondor Music, Universal Music Publishing

Group, and/or Hollenbeck Music concerning Taurus and/or Stairway to Heaven,

especially concerning Dr. Ferraras previous engagement to analyze the Taurus

sound recording versus the Stairway to Heaven sound recording.

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Dated:

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________________________________
The Honorable R. Gary Klausner
United States District Judge

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ALTERNATIVE [PROPOSED] ORDER GRANTING PLAINTIFFS MOTION FOR SANCTIONS AND
TO PRECLUDE DR. FERRARA FROM TESTIFYING AT TRIAL