28.Beyonce'sofficialwebsite,www.beyonce.com,listsBryan Younceamong thosecredited for working on
Beyonces
2013album,
Beyoncé
,produced byColumbia Records/SonyMusic.Exhibit4.9.In July2015,non-partyChris Thomas, an artist manager at C3 PresentsLLC
(“C3”)
in San Antonio, Texas, contacted Plaintiff about anopportunityto direct and produce avideo for themusical groupMSMR, also represented by C3 and affiliated with Columbia.Exhibit5.10.On July 22, 2015,ChrisThomas emailed MS MR's manager Brian Becklinks toPlaintiff's work, includinga link to the complete
PALINOIA
Work.Exhibit6.11.On July 24,2015, MS MR manager Brian Beck forwarded the email string thatincludedthe link
to Plaintiffs
PALINOIA
Work to Younceat Columbia. Exhibit6.12.On July 24, 2015, Younce sent a follow-up email toBrian Beckrequesting
Plaintiffs email address.
The e
mail string included Chris Thomass ori
ginal July 22, 2015 emailtoMS MR management that containedlinks to the
PALINOIA
Work. Exhibit6.In the sameemail string, Younce notes that he previouslytried to reach Plaintiff through the video sharingsite "Vimeo" without success. Exhibit6.13.
Chris Thomas provided the MS MR manager with Plaintiffs contact information
by email and textdated July 29, 2016. Exhibit6.14.On July 29, 2015,the same day that Chris Thomas providedYouncewith
Plaintiffs
contact information, Youncecontacted Plaintiffdirectlyby emailacknowledgingthathe had received Plaintiff
’s “info
.
”
Younceinvited Plaintiffto submit additionalstoryboardsandadevelopment plan
(commonly referred to as a “treatment”
)for considerationby Columbia.Exhibit7.
Case 1:16-cv-04278 Document 1 Filed 06/08/16 Page 3 of 28