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FILED', - ^ CLERK
UNITED STATES DISTRICT COURT ' *EASTERN DISTRICT OF NEW YORK o
4Olu ~d PH
NEVILLE CLIVE CHIN a/k/a CLIVE CHIN,
Plaintiff,
V- COMPLAINT ':,w*''r'':-
DAVID CHIN a/k/a RANDY CHIN, PATRICIA . J ^CHIN, and CHRISTOPHER
CHIN, QU J
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4. Upon information and belief, the defendant STB Music, Inc.
("STB"), is acorporation incorporated in the State ofNew York
having its principal place ofbusiness at 89-05138th Street,
Jamaica, NY 11435.
5. Upon information and belief, defendant, Vincent David Chin
a/k/a Randy Chin, isaresident ofthe County ofNassau, State ofNew
York.
6. Upon information and belief, defendant, Patricia Chin, is
aresident ofthe Countyof Nassau, Stateof New York.
7. Upon information and belief, defendant, Christopher Chin, is
aresident of theCounty ofNassau, State ofNew York.
JURISDICTION
8. This action involves Defendants' conspiracy and concerted
illegal activity tocoerce Plaintiff to give up his ownership to
sound recordings he created and musicalcompositions he wrote, and
to copyrights and contract rights assigned to him in 2002 in
anacknowledged written assignment by his father, Vincent G. Chin.
Defendants have known foryears ofPlaintiffsrights, acknowledged
them, and even obtained licenses for them. Shortlyafter Defendants
thwarted alucrative licensing deal Plaintiff obtained from amajor
distributor,and realizing the value of his rights, the defendant,
Patricia Chin, started making specious claimsthat the written
assignment is void and that she owns Plaintiffs copyrights, even
for songs hehimself created and are not part of the assignment. At
the same time the remaining Defendantsengaged in aseries of
coordinated, malicious, and illegal acts to keep Plaintiff from
profitingfrom his property. Defendants stole the master tapes
embodying the sound recordings owned byPlaintiff; they took his
personal things, business equipment and other items kept at his
office atVP's premises; they interfered with his contracts and
prospective economic relations seeking to
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exploit his copyrights; they Ucensed his copyrights without his
consent and without
copyrights. AU the while Defendants demanded that Plaintiffgive
to Patricia Chin and VP two-tnirds ofthe rights he owns to "settle"
the "ownership dispute". Plaintiff has been severelyd^ged because
of these act. and, in addition to the declaration ofhis rights and
thecompensation he is entitled to, he should be awarded punitive
damages to punish Defendants fortheir illegal and malicious
actions.
9. This court has subject matter jurisdiction over this case
pursuant to 28 U.S.C. 1331 and 1338(a) as this is an action brought
under the Copyright Act and the CopyrightRevision Act, 17 U.S.C.
101, et seq. This court has supplemental jurisdiction
ofPlaintiffsremaining claims pursuant to 28 U.S.C. 1367(a).
VENUE
,0. Venueofthiscaseisproperin.hisdistric.pursuantto28U.S.C.
1391MO)and (2) and 1400(a).
RArKGROUNP
A. TVipRnsinessofVP.11. Plaintiff is the eldest son ofVincent G.
Chin and the stepson ofthe defendant,
Patricia Chin. Vincent O. Chin used the name and was known as
Randy Chin ("Randy Chin").R^y Chin was the son ofChinese immigrants
who left China in the 1920's and ultima*!,settled in Jamaica.
,2. Patricia Chin was the wife ofRandy Chin and the defendants,
Vincent David Chinand Christopher Chin, are their sons.
13. Randy Chin was apioneer in in the Jamaican music industry,
firs, in the sale of
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producing, recording and promoting the music of Jamaican
artists.14. In 1961 Randy Chin opened astore called Randy's Records
in Kingston, Jamaica
selling musical records, primarily by Jamaican artists, which
was subsequently moved in 1962 to17 North Parade, Kingston,
Jamaica.
15. From 1960 to 1968, at outside recording studios, and from
1969 to 1979 at arecording studio Randy Chin set up on the floor
above the record store which became known asStudio 17, Randy Chin
produced and created numerous sound recordings by prominent
andimportant Jamaican artists.
16. The businesses ofRandy's Records and Studio 17 were owned by
Randy Chin asasole proprietorship. The real estate located at 17
North Parade, Kingston, Jamaica was ownedsolely byRandy Chin.
17. In or about 1977, Randy Chin, Patricia Chin, Christopher
Chin and Plaintiffopened aretail store under the name, Randy's of
Jamaica/VP Records, initially at 17WBAJamaica Avenue, subsequently
moved to 107-21 Jamaica Ave., and moved finally in 1992 to 89-05
138* Street, Jamaica, Queens.
18. In 1993 Plaintiff left VP Records.19. In 1993 Randy Chin
retired and moved his residence to Pembroke Pines, Florida.
Patricia Chin did not accompany Randy Chin to Florida and
remained resident in Queens, NewYork. Randy Chin and Patricia Chin
remained in their respective residences until Randy Chin'sdeath in
2003. The parties never entered into aseparation agreement, never
divorced and nomatrimonial proceedings were ever commenced.
20. Upon information and belief, in or about 1994, the defendant
Vincent David
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Chin, left his employment with the aerospace contractor,
McDonneU Douglas, and commencedworkingfor VP.
21. Upon information and belief, Vincent David Chin and
Christopher Chin havebeen employed a, VP as officers, directors and
shareholders ofVP. Each own and personallydirect and supervise the
operation of, and each personally derives economic benefit fiom,
thebusiness of VP.
22. Since its incorporation in New York in 1993, VP has become
the largest andpreeminent record label involved in the promotion,
distribution, and sale of sound recordings ofJamaican music.
B. The Randy Music Catalog.23. At ayoung age in the late 1960's
Plaintiff started working at Randy's Records and
Studio 17. in the early 1970's he became the lead Producer at
Studio 17 helping to make it oneofthe most important Jamaican
recording studios. Studio 17 was popular with many ofJamaica's
leading music producers. Lee "Scratch" Perry recorded several
tracts there with BobMarley and the Wailers in 1970 , 1971, and
other major stars to record there included GregoryIsaacs, Dennis
Brown, Burning Spear, and Johnny Nash.
24. Plaintiffarranged, produced, created, recorded, and was
amusical artist innumerous sound recordings including sound
recordings by "Randy's All-Stars" which includedamong its members
Wailers bassist and keyboard player, Aston Barrett, Tyrone
Downie,drummer Sly Dunbar, and keyboard player Horace Swaby, later
to become known as AugustusPablo. He recorded and produced "Java"
an international hit by Augustus Pablo, and producedthe first "Dub"
album by Augustus Pablo in 1973 entitled Java, Java Dub. In
addition, heproduced and recorded numerous sound recordings for
Dennis Brown, Black Uhuru, Lloyd
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Parks, Delroy Wilson, Gregory Isaacs and Peter Tosh.25.
Plaintiffwas also acomposer or lyricist, or both, in virtually
every sound
recording!* produced and created and, as aresult, held
acopyright interest in the underlyingmusical composition ofeach
such sound recording.
26. Commencing in or about 1972, and continuing virtually to the
present time,Plaintiff, through his wholly-owned record label,
IMPACT!, has released and caused to bedistributed "singles" and
albums of the musical recordings he created and wrote, including
theinternationally acclaimed album, This is Augustus Pablo.
27. On the eve ofPlaintiffspromotional trip to China on the
"Back to China" tourcelebrating the 50th anniversary of Studio 17
in 2009, VP issued apress release (the "2009 PressRelease")
recognizing the release by Plaintiffof his sound recordings on the
IMPACT! label andhis work and achievements. It stated, inpart:
"In the 1970's, Vincent's son Clive [Plaintiffl took off in
theRandy's-*";*'Jf
SEEM!^-tSTE^S-SS suias The Wallers' and Senya's"Oh Jan Come"
28. Plaintiff and Randy Chin each individually produced and
recorded soundrecordings by Jamaican artists totaling together in
excess ofone thousand one hundred (1,100)recordings (the "Randy
Music Catalog"). The Randy Music Catalog is embodied on
one-quarterinch, one-half-inch, one inch and two inch magnetic tape
(the "Randy Catalog Tapes").Approximately five hundred seventy
(570) sound recordings of the Randy Music Catalog havenever been
released and distributed for sale to the public. Embodied on the
Randy CatalogTapes are all the sound recordings released by
Plaintiffon his IMPACT! Label. Fully sixty
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unreleased sound recordings created by and belonging to
Plaintiff.29 In the iate 1970's Studio 17 closed when Randy Chin,
Patricia Chin, Plaintiff and
the remainder oftheir family immigrated tothe United States and
settled in Queens, New York.Randy's Records remained open in
Jamaica until 1989.
30. The Randy Catalog Tapes were stored at the premises of
Studio 17,17 NorthParade, Kingston, Jamaica, until 1999.
Thereafter, at Plaintiffs request, and with the knowledgeof Randy
Chin, the Randy Catalog Tapes were kept in safekeeping at
Experience Music Projectin Seattle, Washington, which cataloged and
boxed the tapes. (A list of the Randy Catalog Tapesis attached as
Exhibit A.) In July 200, the Randy Catalog Tapes were sen, by
Experience MusicProject to Plaintiff in Queens, New York where they
were stored at his home.
31. On September 17,2013, a. the suggestion ofVincent David
Chin, Plaintiff causedthe Randy Catalog Tapes to be delivered to VP
for safekeeping at its premises in Queens NewYork.
32. On March 31,2014 Plaintiff sent atext message to Vincent
David Chin seeking topick up the Randy Catalog Tapes.
33. On the same day, Vincent David Chin refused Plaintiff access
to the tapes sendingatext message that "the tapes are safe where
they are."
34. Upon information and belief, the Randy Catalog Tapes are
currently being heldby VP at its premises at 89-05 138* Street,
Jamaica, Queens.C. -p.- "f A" Rihts
mThe^dxMusJc^atateto^iaintffi
35 Pursuant to "Agreement for the Transfer/Conveyance/Assignment
ofall RightsandOwnershiplnterestmMusicalCompilationKnownas'Randy
Music Catalog'" datedMarch
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26 2002 (the "AssignmenO, Randy Chin conveyed, transferred, and
assigned to Plaintiff(a) All "rights, invests, and otherwise ... of
every kind and description, tangible of
mintangible" in the Randy Music Catalog "regardless of whether
or [not] reflected in thebooks andrecords of Assignor and any of
the third-party bu, regarded as part of the interest ofthe Assignor
in the "Catalog".(b) All right, title, and interest in all
contracts, agreements, personal property leases,licenses and
commitments relating to the Randy Music Catalog.
(c) "Any and all goodwill of Assignor" which included all rights
in any trademarksassociated with the Randy Music Catalog.
(A copy ofthe Assignment is attached as Exhibit B.)36. The
Assignment operated only to assign and transfer whatever
intellectual
property, contract rights, brand and trademarks Randy Chin
possessed in the sound recordingsand musical compositions of the
Randy Music Catalog. The Assignment did no, assign andtransfer the
intellectual property rights ofPlaintiff in the Randy Music Catalog
sound recordingsmat Plaintiffhimself created because Randy Chin did
not own those rights.
37. In addition, Plaintiffs rights as acomposer and lyricist
ofthe musicalcompositions are separate and distinc, from his righ,s
as me producer and crea,or oftire RandyMusic Catalog sound
recordings upon which tire compositions are embodied. Rights in
soundrecordings are subject to the rights ofme composers, and me
Assignmen, did no, transfer any ofPlaintiffs proprietary rights in
me compositions embodied in me sound recordings becauseRandy Chin
did not own those rights.
38. On February 2,2003 Randy Chin passed away leaving aLas, WiU
and Testamentdated January 8,1999 (the "Will"). Pursuant , the
Will, Randy Chin made specific bequests of
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estate located at 17 North Parade, Kingston, Jamaica to
Plaintiff.3,. Patricia Chin and Robert Lilly, as the named
executors in the Will, sought probate
fthe Will in the Broward County Probate Court, For, Lauderdale,
Florida, under Case NumberPRC030001424. The Will was admitted to
probate, and the Estate of Vincent G. Chin (theEstate") was
established, on September 20,2004. Notice to creditors was
published on March21,2005 resulting in two claims for medical bills
totaling approximately $1,000. No otherclaims were made against the
Ese. The Estate was closed by order ofthe court on
December27,2010.
40. Prior to, and at the time of the death of Randy Chin, and
during me period oftheadministtation ofme Estate, Patricia Chin,
Vincent David Chin, and Christopher Chin wereaware ofthe existence
of the Randy Music Catalog, and Plaintiffs ownership ofthe
Catalog.
41. Shortly after the Assignment, Plaintiff showed Patricia Chin
the Assignment andto,d her that Randy Chin had transferred and
assigned the Randy Music Catalog to him.
42. In 2004, Plaintiff, with the knowledge and consent ofVincent
David Chin andChristopher Chin, commenced occupying office space a,
VP's premises to exploit the RandyMusic Catalog
soundrecordingsusingthe name, "Randy's Music". On November
19,2013Piaintiffincorporated aNew York Corporation, Randy's Music
Group, Inc. Defendants were allwd, aware that P,aintiff was seeking
to expioit the Randy Music Catalog from his office a,
VP'spremises.
43. VP and Vincen, David Chin recognized and acknowledged
Plaintiffs rights in theRandy Music Catalog in tire 2009 Press
Release, and in multiple licenses entered into by VP, and
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Irspublishingsubsidiary.withPlaintiffforthesoundrecordingsandmusica,
compositions of theRandy Music Catalog songs.
44. Patricia Chin, recognizing Plaintiffs rights in the Randy
Music Catalog, insistedand urged Plaintiffto enter into one or more
of such licenses with VP.
45. If the Assignment was invalid, as VP, Patricia Chin and
Vincen, David Chin haverecently ciaimed, me Randy Music Caalog
and
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Chin as part ofthe Assignment.49. On or about July 7,2009,
Plaintiff entered into an Administration Agreement (the
"Administration Agreement") with Greensleeves pursuant ,o which
Grcensleeves was toadminisrer, for me period from October 1,2009 to
September 30,2012, with asix-monthcollection period, Plaintiffs
rights in musical compositions in which possessed an
interestincluding licensing and otherwise exploiting the musical
compositions, and collecting and payingto Plaintiffhis portion
ofroyalties due him from such exploitation.E. VP and Greensleeve's
Licenses of Randy Catalog Sound Recordings and Musical
Compositions.50. On or about October 7,2013, STB, ostensibly as
agen, for Greensleeves, licensed
Plaintiffs fifty (50%) percent portion ofthe musical
composition, "Ska Beat", to72andSunnypartners, LLC for aone year
period for use for use in athirty (30) secondcommercial for Google,
Inc. (the "Google Musical Composition License"). The license fee
underthe agreement was $50,000 which was received by
STB/Greensleeves.
51. STB entered into me Google Musical Composition License on
behalfofPlaintiff,without prior notice to Plaintiff,
notwithstanding that the Administration Agreement had expiredon
September 30,2012.
52. Upon information and belief, on or about October 7,2013, VP
entered into alicense agreement with 72andSunnypartners, LLC for
Plaintiffs 100% interest in me soundrecording of "Ska Bea," for use
in the commercial for Google Inc. (me "Google SoundRecording
License"). Upon information and belief, me Google Sound Recording
License wasfor aone-year period and me license fee was $100,000
win, 25% payable to Rhino Records asplacemen, agent, and 50% ofthe
remainder, $37,500, payable to Plaintiff.F.
ConrtyedCJairniCiRi^^
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53. Upon information and belief, as aresult ofthe offer made by
ADA, detailedfce-ow, to distribute the Randy Music Catalog, the
negotiations leading to the Google MusicalComposition License and
the Google Sound Recording License, and the issuance
oflicensesthemselves, Defendants came to realize the actual and
potential value ofme Randy MusicCatalog. Patricia Chin, and tire
remaining Defendants, through Patricia Chin's "attorney",Declan P.
Redfem, Esq. ("Redfern"), commenced contriving aseries of shifting
and inconsistentarguments in letters to Plaintiffs attorneys
claiming ma, me Randy Music Catalog did no, belongto Plaintiff.
54. By letters dated March 4, 2014 and March 31,2014, Redfem
claimed that thecopyrights in the Randy Music Catalog were par, of
the "marital estate" of Patticia ChinandRandy Chin, and since the
Assignmen, was made without me consent of Patricia Chin it was"void
ab initio ".
55. By letter dated April
ll,2014,RedferndiscardedhisassertionthattheAssignmen, was void ab
initio and instead claimed that the Assignment did not convey
theinterest ofPatricia Chin in the Randy Music Catalog, implying
ma, me Assignment did conveythe inters, ofRandy Chin. In such
letter, Redfem advised that he instructed VP to continuemaking
royalty payments due Plaintiff in the ordinary course of VP's
business.
56. By letter dated April 29,2014, Redfern claimed that Patticia
Chin "jointly held" aproprietary interest in the Randy Music
Catalog, different and distinct from 'ownership as.enants-in-common
or through join, corporate ownership", and ma, Plaintiff took titie
to meRandy Music Cat*g subjec, to the "legal and equitable
interests" of Patricia Chin.
57. By letter dated May 28,2014, Redfem discarded his assertion
that Patticia Chindid no, own an interest in the copyrights ofthe
Randy Music Catalog through joint corporate
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ownership, and instead alleged she and Randy Chin owned all
assets ofme music busmessincluding me copyrights in me Randy Music
Catalog as "shareholders and as de facto partners. "Redfern alleged
fha, Patticia Chin's righ, titie and interes, in me Randy Music
Catalog "arose byvirtue ofCommon Law and under me copyright law
itself."
58. In making the legal pronouncements and conclusory statements
in the abovereferenced letters, Redfem did not address Plaintiffs
ownership ofme sound recordingcopyrights as the creator ofamajority
ofthe master recordings in the Randy Music Catalog, orPlaintiffs
ownership in the copyrights ofamajority ofthe musical compositions
as author. Noattempt was made by Redfern to claim ma, Patticia Chin
had a'proprietary" or "legal andequitable interest" in such sound
recordings or musical compositions.
59. Each ofthe letters sent by Redfem expressed a"hope" for
"constructivediscussions" to resolve issues relating to the Randy
Music Catalog. There were in fact no suchissues to resolve since
all claims made by Redfem were patently specious and without
merit.Notwithstanding this, VP sought ,o extort aresolution through
an agrecmen, seeking to takeftom Plaintifftwo-thirds ofhis
copyright interest in the Randy Music Catalog, allocating one-ted ,
Patricia Chin and one-third to VP. In an attempt to coerce
Plaintiff to accept sucharesolution Defendants stymied and
prevented any attempts by Plaintiff to exploit the RandyMusic
Catalog mrough active and successful interference with Plaintiffs
prospective economicrelations.
O. The Interference ofPlaintiffsProspective Economic Relations
By Vincent David Chin,VP1 andGreensleeves.60 During the Summer
of20,3 Plaintiffwas negotiating in the United Kingdom with
Howard Corner of Warner Music UK Limited trading as ADA UK
("ADA") for the worldwidesale and disttibution of the Randy Music
Catalog. ADA offered Plaintiff an advance of
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130,000, or approximately $208,000, and on July 16,2013
Plaintiffwas sen, adraft agreementby ADA as an e-mail
attachment.
61. Upon information and belief, shortly after the draft
agreement was sent toPlaintiff, Vincent David Chin spoke with
Howard Comer and made statements andrepresentations regarding
Plaintiffs ownership ofthe Randy Catalog Tapes which caused ADAto
withdraw the offer contained in the draft agreement and to cease
negotiations. At the time,Plaintiffwas told by Vincent David Chin
during atelephone conversation to "get on aplane andcome back."
Howard Corner told Plaintiff he would "have to work something out
with yourbrother."
62. As aresult no agreement was reached between Plaintiff and
ADA.63. During 2013 into 2014 Plaintiff had been in discussions and
negotiations with
Naoki lenaga ofDub Store Sound Inc. ("Dub Store") in Japan to
license for sale and distributionsound recordings embodied on the
Randy Catalog Tapes. In Angus, 2013 adraft agreemen, wassent to
Plaintiffproviding for an advance of$22,000. Upon information and
belief, duringAugust 2014, before the transaction could be
consummated, Michael McGraw ("McGraw"),Senior Director ofNew Media
a. VP, had contact with Dub Store and made statements
andrepresentations regarding Plaintiffs ownership ofthe Randy
Catalog Tapes which caused DubStore to withdraw the offer contained
in the draft agreement and to cease negotiations.
64. As aresult no agreement was reached between Plaintiff and
Dub Store.65. Upon information and belief, in or about September
20,4 Greensleeves sen. a
,eer to PRS, the performance rights society in the United
Kingdom, representing that Plaintiffhad been forging documents and
had no rights to the Randy Catalog Tapes and the soundrecordings
embodied thereon.
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H VP and Vincent David Chin Excludes Plaintiff from His Office
a, VP's Premises and' p.fi,^s to Relea- "' """"al Pronertv.
66 In or about March 2014 Vincent David Chin advised
Plaintiffmat he should notreturn to his office at VP's premises
until the dispute over me ownership of me Randy MusicCatalog had
been worked out.
67. VP and Vincen, David Chin have refused to permit Plaintiff
to remove hispersonal items and business equipment from his office
and continue ,o refuse to permit theirrelease despite his request
that they do so.
68. VP and Vincen, David Chin are currently holding, in part,
the following propertyand equipment:
a) Office supplies, blank music contract's and invoices.b)
Promotional posters from all Plaintiffs overseas tours (China, Hong
Kong, Japan,
UK, France, Belgium, Poland, Germany, Switzerland, Spain,
Austria, and SouthAfrica.
c) Promotional music CD's, DVD's, VHS, and cassettes.d) Twenty
boxes of 10" vinyl records "One Day You'll Know" by ChaCha and
Ranking Joe produced by Plaintiff in 2010.e) Two hard-drives
with some ofPlaintiffsun-released musical productions.f) Assorted
music books.g) Acouple pair of 7" metal stampers, and record labels
(Randy's and IMPACT!),h) Two hundred fifty 7", 10", and 12" vinyl
records test pressings.i) Cassette voice recorder,j) Framed artiest
wall placards,k) Personal memorabilia items.
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1) One brand new blackberry cell phone.(Referred to hereafter as
"Plaintiffs Personal Items".)
SHE HAS rw tMT>vrATAlor, TAPES
69. There exists an actual controversy between Plaintiff and
Patricia Chin as to thevalidity of the Assignment and their
respective rights in the Randy Music Catalog and the RandyCatalog
Tapes. This Court is empowered to issue adeciaratory judgment
declaring the rightsand other legal relations ofthe parties
pursuant ,o 28 U.S.C. 2201(a).
70. Patricia Chin has no claim of rights in the Randy Music
Catalog and RandyCatalog Tapesbecause:(a) Pursuant to 17 U.S.C. 301
Federal Copyright law preempts State matrimonial
taw in determining acopyright interest in intellectual property,
and State matrimonial lawcannot be used either to determine that
aspouse possesses acopyright interest inintellectual property as
part of"community property" or the "marital estate", or as abasisto
cause the transfer ofa copyright interest to aspouse.
(b) U.S. Copyright law provides only four ways in which aparty
may obtain acopyright interest in intellectual property: (1) by
authoring the work; (2) through transferby written agreement or by
operation of law; (3) by bequest and will; or (4) bydistribution
according to aState's intestacy laws. Patricia Chin has not
claimed, and infact has not obtained, an interest in me Randy Music
Catalog by any ofthese four means,(c) Assuming State matrimonial
law applied, which it does not, and the copyrightinterest was
"community property" or part ofthe "marital estate", aspouse
possessingsuch acopyright interest is free to transfer and assign
me interest any time prior to the
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commencement ofmatrimonial proceeding, There was no commencement
ofdivorce orseparation proceedings by either Randy Chin or Patricia
Chin,(d) Assuming Patricia Chin had aproprietary interest in the
Randy Music Catalog,such interest does no. render the Assignment
void ab initio or ineffective. Moreover,Patricia Chin is precluded
by me applicable statute oflimitations from now claiming suchan
interest.
71. In addition, to the extent Plaintiff was the creator of
sound recordings and theauthor of musical compositions of songs in
the Randy Music Catalog, Randy Chin never had aninterest in such
works, they were not transferred by the Assignment, and Patricia
Chin could nothave had aproprietary interest in such sound
recordings and musical compositions.
72. Plaintiff is entitled to adeclaratory judgment that the
Assignment is valid andenforceable, that he possesses all the
rights the Assignment gives to him concerning the RandyMusic
Catalog and the Randy Catalog Tapes, and that Patricia Chin has no
legal or equitableinterest on either the Randy Music Catalog or the
Randy Catalog Tapes.
73. Alternatively, Plaintiff is entitled to adeclaratory
judgment that Patricia Chin hasno legal or equitable interest in
the musical compositions he authored and the sound recordingshe
created forming part of the Randy Music Catalog as embodied on the
Randy Catalog Tapes.
SECOND CLAIM AGAINST PATRICIA CHIN FOR TORTIOUSSECOND
CL^yttFFRENCir WTTH CONTRACT74. Plaintiff repeats the allegations
set forth in paragraphs 1through 73.75. Upon information and
belief, at all times relevant, Patricia Chin had actual
knowledge of the Master Use Agreement between Plaintiff and
VP.76. By letter dated October 23,2014 sent to VP, Redfern stated
on behalfof Patricia
Chin:
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"As Ipreviously informed you in my letter dated March 32014,1
represent, PatriciaChin with respect to her right, title and
ownership interest m*W** J* .intellectual property known as the
Randy catalog (the "Copyrights ). This letter shallSSJSctot
continues to assert her rights in Wfttg^ggg-title and interest in
the copyrights or royalty income generated therefrom_ Please
takefurther notice that my client expressly and unconditionally
reserves all of her rights with^S to an acSunnng and payment ofall
royalties paid or payable and claims on^pTdt third-irties in
derogation of her rights in the copyrights and
copyrightroyalties."
77. On November 3,2014 VP's attorney sent aletter to Plaintiffs
attorneys, attachingacopy of the Redfern's October 23,2014, letter
stating:
"VP is in receipt of the attached letter dated October 23,2104
(sic) sent by DeclanR^LmE^n behalfofhis client Patricia Chin
reserving all for rights mand to the[Randy Music]
Catalog.Accordingly, VP is now withholding any and all royalties
due or becoming payable under^"ents until such time as all of the
relevant parties enter into^written settlementagreement with
respect to the Catalog resolving any and all applicable claims.78.
Patricia Chin, through Redfern, has intentionally caused VP to
breach the Master
Use Agreement by not paying royalties due to Plaintiffunder the
Agreement.79. As aresult, Plaintiffhas been damaged in an amount to
be determined at trial, not
less than $50,000. Plaintiff is also entitled to punitive
damages in an amount to be determined attrial, not less than
$150,000.
rr aim XC ATNST VP AND VINCENT DAVID CHIN FOR TORTIOUS^j^S^^
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83. Vincent David Chin acted with malice in that his sole
purpose was to harmPlaintiffby preventing him from entering into
adistribution agreement with ADA. Additionally,Vincent David Chin
acted with malice in that his intent was to prevent Plaintiff from
having anymeans of distribution of the Randy Music Catalog so as to
force him to transfer two-thirds ofhisproprietary interest in the
Randy Music Catalog to VP and Patricia Chin.
84. As aresult, Plaintiffhas been damaged in an amount to be
determined at trial, notless than $250,000. Plaintiff is also
entitled to punitive damages in an amount to be determined attrial,
not less than $750,000.
FOURTH CLAIM AGAINST VP FOR TORTIOUS INTERFERENCE WITHFOURTH
CLAIMA^ ^ ^ ^roivnMTr RFLATIONS
85. Plaintiff repeats the allegations set forth in paragraph
1through 84.86. Dub Store was prepared to act on behalfofPlaintiff
in the sale and distribution of
recordings in the Randy Music Catalog in the country of
Japan.87. McGraw, on behalf ofVP, with knowledge
ofPlaintiffsprospective economic
relationship Dub Store, interfered with such relationship by
causing Dub Store to withdraw itsoffer and to refuse to enter into
adistribution agreement with Plaintiff.
88. McGraw, on behalf ofVP, acted with malice in that his sole
purpose was to harmPlaintiffby preventing him from entering into
adistribution agreement with Dub Store.Additionally, McGraw acted
with malice in that his intent was to prevent Plaintiff from
havingany means of distribution of the Randy Music Catalog so as to
force him to transfer two-thirds ofhis proprietary interest in the
Randy Music Catalog to VP and Patricia Chin.
89. As aresult, Plaintiffhas been damaged in an amount to be
determined at trial, notless than $250,000. Plaintiff is also
entitled to punitive damages in an amount to be determined attrial,
not less than $750,000.
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^, a.M APAINSTVP AND VINCENT DAVID CHIN FOR CONVERSION OFFIFTH
CLAM^GAINST VF AND Vlr^^^mr nAMAGES90. Plaintiffrepeats the
allegations set forth in paragraph 1through 89.9,.
By,ex,meSsagedatedMarch31,2014toVmcen,DavidChinPlain,iffsough,to
arrange to pick up the Randy Catalog Tapes from VPs premises.92.
By text message of the same date ,o Plaintiff, Vincent David Chin
refused access
to the Randy Catalog Tapes stating that "tapes are safe where
they are". In the same text,Vincen, David Chin made clear mat the
Randy Catalog Tapes were being held hostage pendingan agreement
which VP and Patricia Chin to their benefit. He stated:"Alex IVPs
attorney] is going to reach out to Janis [Plaintiffs attorney]
today or tomorrow. IdoS you sLuld come to the office until we get
the situation resolved.
93. By letter dated April 7,2014 sen, to Vincen, David Chin,
Plaintiffs attorney madeaformal demand upon Vincen, David Chin and
VP for areturn ofme Randy Catalog Tapes.
94. VP and Vincen, David Chin failed and refused to return the
Randy Catalog Tapesdespite the demand.
95. As aresult ofthe conversion ofthe Randy Catalog Tapes,
Plaintiff is entitled todamages in an amount to be determined at
trial not less than Sl.000,000. Plaintiffis also entitled,o
punitive damages in an amount to be determined at trial no. less
titan $3,000,000.
96. Plaintiffrepeats the allegations set forth in paragraph
1through 94.97. The Randy Catalog Tapes are unique and
irreplaceable and Plaintifftherefore has
no adequate remedy atlaw.98.
PlaintiffisentitledtoanorderagainstVincentDavidChinandVPdirectingthereturn
to Plaintiffof the Randy Catalog Tapes as listed on the attached
Exhibit A.
20
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99. Plaintiffrepeats the allegations set forth in paragraph
1through 98.,00. Plaintiffs Personal Property is unique and
irreplaceable and Plaintiff therefore
has no adequate remedy atlaw.,01. Plaintiff is entitled to an
order against VP directing the return ofPlaintiffs
Personal Property.
JUDGMENl 1HA1 Mglrimi,.Mt>F,it30.2012
102. Plaintiff repeats the allegations set forth in paragraph
1through 101.,03. By its terms the administration agreement
terminated on September 30,2012 with
asix-month collection ending on April 30,2013. During me
collection period Greensleeves andSTB were entitled only to collect
royalties earned prior to September 30,2012.
,04. Notwithstanding that the term ofthe Administiation
Agreement had terminated,me collection periodhad elapsed, and
Greensleeves had no authority to act on behalfof Plaintiff,on or
about October 7,2013, STB, as agent for Greensleeves, entered into
me Google MusicalComposition License.
,05. On October 21,2013, Plaintiff, tirroughhis attorney,
notified Greensleeves by,e^ti,atme Administration Agreementhad
expired on September 30,2012, and thatGreensleeves did not have the
right ,o receive or collect funds, sign third-party agreements,
orotherwise administer the rights to Plaintiffs musical composition
copyrights.
,06. Notwithstanding that the Administration Agreement provides
mat it can only bemodified in writing, Greensleeves and STB have
taken the position that AdministrationAgreement continued after the
termination date.
21
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,07. There exists an actual controversy between Plaintiffon the
one hand, andOreensleeeves and STB on the other, as to whether me
Administtation Agreemen, terminated onSeptember 30,2012.
108. Plaintiff is entitled*^
the Administration Agreement terminated on September
30,2012.NINTH CLAIM AGAINST GREENSLEEVES AND STB FOR
MONT?VHAD AND RECEIVED
109. Plaintiff repeats the allegations set forth in paragraph
1through 108.110. After the expiration of the Administration
Agreement, and the collection period
provided for in the Administration Agreement, Greensleeves
and/or STB received $50,000 fromthe Google Musical Composition
License.
111. Neither Greensleeves nor STB had the authority to enter
into me Google MusicalComposition License on behalfofPlaintiffor to
receive me paymen, ofme $50,000 which wasdue to Plaintiff.
,,2. Greensleeves and STB have retained the $50,000 payment
despite demand that i,be paid to Plaintiffand has thereby benefited
from the receipt ofthe payment.
,13. Upon information and belief, Oreensleeeves and STB have
received additionalpublishing royalties due Plaintiff under the
expired Administration Agreement.
,,4. Greensleeves and STB should no, be allowed to retain such
monies which shouldhave been paid directly to Plaintiff.
1,5. Plaintiff is entitiedto ajudgmen, against Greensleeves and
STB, in an amount tobe determined at trial, not less than
$50,000.
116. Plaintiff repeats the allegations set forth in paragraph
1through 115.22
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1,7. Greensleeves and STB have been unjustiy enriched by their
receip, ofme $50,000under the Google Musical Composition License,
and by the receip. ofadditional publishingroyalties which should
have been paid directly to Plaintiff.
8. Greensleeves and STB have been unjustly enriched at
Plaintiffsexpense and inequity and good conscience should be
required to pay such monies to Plaintiff.
,,9. Plaintiff is entitled to ajudgment against Greensleeves and
STB, in an amount tobe determined at trial, not less than
$50,000.
ELEVENTH CLAIM AGAINST VP FOR DAMAGES RESULTING FROMELEVEN 1H
C1.A. TOPArHnBAr,RFEMENT120. Plaintiff repeats the allegations set
forth in paragraph 1through 119.,2,. VP has breached the Master Use
Agreement by failing to pay Plaintiffs portion of
the license fee received on the Google Sound Recording License
bthe amount of$37,500.122. Moreover, VP has failed and refused to
pay additional royalties due to Plaintiff
under such agreement.
,23. Plaintiff is entitled to judgment against VP in an amount
to be determined at trial,not less than $50,000.
, .,, .riMOTVP VINCENT DAVID CHIN AND CHRISTOPHERTWELFTH
C^MrA^S^L^,^,v.nrar.EMENT,24. Plaintiff repeats the allegations set
forth in paragraph 1through 123.,25. Plaintiff is the owner ofthe
copyrights in the sound recordings listed below, by
the musical artists listed, and owns me copyright in the
underlying musical composition in theproportion set forth
below:"Away from It AU"-Don Drummond/50% of musical
composition;"Babylon King *Queen" AKA "King *Queen (Babylon)" -Lord
Creator^/o ofmusicalcomposition;
23
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"Black Joe"- The Skatalites/no copyright interest in musical
composition;"Evening News" -Lord Creator/50% of musical
composition;"Hello Mother" -The Skatalites/no copyright interest in
musical composition."I Love The Reggay" -The Gaylads/50% ofmusical
composition;"I'm Wasting My Time"-Lord Creator/50% of musical
composition;"Ifs Now or Never"- Jimmy London/ no copyright interest
in musical composition:"Lost Penny"- The Maytals/50% ofmusical
composition;"Man to Man" -Lord Creator/50% ofmusical
composition.
126. All of the Infringed Works were created by nationals of the
country of Jamaicaand first released outside the United States.
127. VP embodied Infringed Works upon albums it manufactured,
distributed and sold.Below are the names of the albums, the years
released, and the names of the Infringed Work,
Infringing Work: Total Reggae: This is SkaYearof Release:
2008InfringedWork(s):"Away from It All" -Dan Drummond"Black Joe" -
The Skatalites"Evening News" - Lord Creator
"Man to Man" - Lord Creator"Lost Penny" - The Maytals."Hello
Mother" - The Skatalites
Infringing Work: Total Reggae: Pop Hits (Album)VSgfi^ Now or
Never" -Jimmy London;Infringing Work: Out of Many 50 Years of
Reggae 2012 (Album)Year of Release: 2012 Ti,ravi!.H'Infringed
Work(s): "I Love The Reggay" -The Gaylads,
24
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128. Infringed Works were licensed by VP to third parties
without the consent ofPlaintiff. Set forth below is alist of the
names ofthe infringing works, the nature ofthe licensesgiven by VP,
the name of the licensee and country of location, and the names
ofthe InfringedWorks.
Infringing Work: Claude Challe Presents Lovely Reprises Vol
2(Album)Nature of license: Sound recording/Musical composition
LicenseYear of License: 2013 _Licensee/Country: Chall'o Music
International/FranceInfringed Work(s): It's Now or Never" -Jimmy
London;Infringing Work: WMTV206 Ska AlbumNatoe of license: License
(Sound recording/Musical composition)Year of License:
2013Licensee/Country: Rhino UKInfringed Work(s): "Babylon King
&Queen" AKA King &Queen(Babylon)"- Lord CreatorInfringing
Work: WMTV206 Ska AlbumNature of license: License (Sound
recording/Musical composition)YearofLicense: 2013Licensee/Country:
Rhino UKInfringed Work(s): "Lost Penny" -The Maytals.,29. Upon
information and belief, in addition to as se, forth above, VP,
Vincent David
Chin, and Christopher Chin have all infringed the Infringed
Works in anumber of waysincluding the following: (1) creating
aderivative work by including the Infringed Works in meinfringing
Works; (2) through the manufacture, disttibution and sale, and/or
the authorizing ofothers to distribute and sell the Infringing
Works; (3) authorizing and/or licensing the InfringingWorks
including for digital downloads; (4) commercially exploiting me
Infringing Works; (5)performing or authorizing the performance
ofthe infringing Works; and/or (6) causing and/ormaterially
contributing to and/or by substantially participating in and
furthering the above-mentioned infringing acts, and/or sharing the
proceeds therefrom, all through unlicensed sales ofthe Infringing
Works.
25
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130. Upon information and belief, Vincent David Chin and
Christopher Chin had theobligation, right and ability to supervise
each infringing activity but allowed the infringement tooccur, and
they had an obvious and direct financial interest in exploiting the
copyrightedInfringed Works.
131. Accordingly, VP, Vincent David Chin, and Christopher Chin
are liable for direct,contributory, and vicarious copyright
infringement of the Infringed Works.
132. Upon information and belief, VP, Vincent David Chin, and
Christopher Chin haveand continue to receive payments for the
unlicensed sale of the Infringing Works.
133. Upon information and belief, VP, Vincent David Chin, and
Christopher Chin havereceived payments for the unlicensed sale of
the Infringed Works without accounting for andremitting the
appropriate amount of such royalties to Plaintiffor providing for
the appropriatecopyright interest ofPlaintiff in the Infringing
Works.
134. Upon information and belief, VP, Vincent David Chin, and
Christopher Chin havereceived royalties for the licensing of the
Infringed Works for digital downloads and streamingvia the
Internet.
135. By reason of the infringement of the Infringed Works, and
the continuousinfringement ofthe Infringed Works, Plaintiffhas
sustained and will continue to sustainsubstantial injury, loss and
damage to his rights in the Infringed Works.
136. Further irreparable harm to Plaintiff is imminent as
aresult ofthe conduct ofVP,Vincent David Chin, and Christopher
Chin, and Plaintiff is without adequate remedy at law.Plaintiff is
entitled to an injunction restraining VP, Vincent David Chin, and
Christopher Chin,their officers, directors, agents, employees and
representatives and all persons acting in concertwith them from
engaging in further acts of copyright infringement.
26
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137. Plaintiff is further entitled to recover from VP, Vincent
David Chin, andChristopher Chin the damages sustained by Plaintiff
as aresult of their acts of copyrightinfringement. Plaintiff is at
present unable to ascertain the foil extent of the monetary
damagePlaintiffhas suffered by reason of the acts of copyright
infringement but believe such damagesexceed $150,000.
138. Plaintiff is further entitled to recover from VP, Vincent
David Chin, andChristopher Chin the gains, profits and advantages
they obtained as aresult of their acts ofcopyright infringement.
Plaintiff is at present unable to ascertain the full extent of the
gains,profits, and advantages VP, Vincent David Chin, and
Christopher Chin have obtained by reasonof their acts of copyright
infringement, but Plaintiff is informed and believe that VP,
VincentDavid Chin, and Christopher Chin have obtained such gains,
profits, and advantages in anamount exceeding $150,000.
THreTFFNTHCI ~ Ar.A,MT A,.LnFFFNDANTSFORCrVII.CONSPIRACY139.
Plaintiff repeats the allegations set forth in paragraph 1through
138.140. The claim ofownership by Patricia Chin ofPlaintiffs
property rights have been
used as justification by VP and Vincent David Chin to interfere
with Plaintiffs prospectiveeconomic relations, to refuse to release
the Randy Catinog Tapes, and by Greensleeves, STB andVP to refuse
to pay monies due Plaintiff, evidencing acorrupt agreement in
furtherance ofacommon scheme among all Defendants to coerce
Plaintiff to give up his valuable property rights.
141. Each ofthe Defendants acted tortiously or refused to abide
by their contractualagreements as part of such conspiracy to
unlawfully coerce Plaintiff to give up his propertyrights.
,42. As aresult, all ofthe Defendants are jointly and severally
liable for the conduct of27
-
the other in an amount to be determined at trial not less than
$1,000,000, with punitive damagesof not lessthan$3,000,000.
143. Plaintiff repeats the allegations set forth in paragraph
1through 142.144. Defendants had an express and/or tacit
understanding to participate in acommon
plan to deprive Plaintiff ofhis valuable property rights.145.
Each of the Defendants either acted tortiously or breached its
agreement with
Plaintiff infurtherance ofsuch understanding.146. As aresult,
all of the Defendants are jointly and severally liable for the
conduct of
the other in an amount to be determined at trial not less than
$1,000,000, with punitive damagesof not less than $3,000,000.
WHEREFORE, Plaintiff demands:
a) On his First Claim, declaratory judgment against Patricia
Chin that theAssignment is valid and enforceable, that
Plaintiffpossesses all the rights the Assignmentgives to him
concerning the Randy Music Catalog and the Randy Catalog Tapes, and
thatPatricia Chin has no legal or equitable interest on either the
Randy Music Catalog or theRandy Catalog Tapes, or, in the
alternative, adeclaratory judgment that Patricia Chin hasno legal
or equitable interest in the musical compositions he authored and
the soundrecordings he created.
b) On his Second Claim, Judgment against Patricia Chin awarding
an amount to bedetermined at trial, not less than $50,000, and
punitive damages in an amount to bedetermined at trial, not less
than $150,000, together with interest from March 14,2014.
c) On his Third Claim, Judgment against Vincent David Chin and
VP in an amount28
-
to be determined at trial, not less than $250,000, and punitive
damages in an amount to bedetermined at trial, not less than
$750,000, together with interest from July 16,2013.
d) On his Fourth Claim, Judgment against Vincent David Chin and
VP in an amountto be determined at trial, not less than $250,000,
and punitive damages in an amount to bedetermined at trial, not
less than $750,000, together with interest from August 1,2013.
e) On his Fifth Claim, Judgment against Vincent David Chin and
VP for damages inan amount to be determined at trial not less than
$1,000,000, and punitive damages in anamount to be determined at
trial not less than $3,000,000 together with interest fromMarch
31,2014.
f) On his Sixth Claim, for an Order against Vincent David Chin
and VP directingthereturn of theRandy Catalog Tapes to
Plaintiff.
g) On his Seventh Claim, for an Order against Vincent David Chin
and VP directingthe return ofthe Plaintiffs Personal Property
toPlaintiff.
h) On his Eighth Claim, for declaratory judgment against
Greensleeves and STB thatthe Administration Agreement terminated on
September 30,2012.
i) On his Ninth Claim, Judgment against Greensleeves and STB in
an amount to bedetermined at trial, not less than $50,000, with
interest from October 7,2013.
j) On his Tenth Claim, Judgment against Greensleeves and STB in
an amount to bedetermined at trial, not less than $50,000, with
interest from October 7,2013.
k) On his Eleventh Claim, Judgment against VP for damages in an
amount to bedetermined at trial not less than $50,000, together
with interest from October 7,2013.
1) On his Twelfth Claim, Judgment against VP, Vincent David Chin
and ChristopherChin:
29
-
11.
111.
IV.
V.
That they be found liable for direct, contributory, and/or
vicarious copyrightinfringement.
That they be ordered to submit to an accounting so that all
gains, sales, profits,and advantages derived by them from each of
their acts may be determined.For apreliminary and permanent
injunction enjoining them and all persons actingin concert with
them from copying, reproducing, performing,
manufacturing,promoting, advertising, and distributing the
Infringed Works, or performing anymaterials that are substantially
similar to the Infringed Works, and to deliver tothe Court for
destruction or other reasonable disposition, all such material
andmeans for producing same, in their possession or control.For
actual damages and their profits in an amount to be determined at
trial, notless than $300,000.
For declaratory judgment that Plaintiffowns the copyright in the
Infringed Works,and are entitled to publishing royalties and
royalties from the sale ofphysical anddigital albums, including
digital download royalties and ringtone/ringbackroyalties, based on
such ownership or, in the alternative, that the Court
declarePlaintiffs' ownership interest in the Infringing Works and
sound recordings ofsuch works, and order appropriate payment based
upon such ownership interest.
1) On his Thirteenth Claim, Judgment against all Defendants for
damages inan amount to be determined at trial not less than
$1,000,000.00, with punitivedamages ofnot less than $3,000,000.
m) On his Fourteenth Claim, Judgment against all Defendants**
damages inan amount to be determined at trial not less than
$1,000,000.00 million, with punitive
30
-
damages ofnot less than $3,000,000.00.n) On all
ofPlaintiffsClaims his reasonable attorney's fees, interest,
costs,
and disbursements and such other and further relief as the Court
deems just andproper.
Dated: New York, New YorkDecember 5,2014
31
WidfrANTHONY'MOTJAAttorney forPlaintiffs50 Broadway, Suite
800New York, N.Y. 10004-1874Tel: (212)791-7360Fax: (212)
791-7468
-
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104
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Art
ist/
Bo
xN
ote
sR
epea
tYou
rBro
ther
Col
lie
Wee
dB
arry
Bro
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KT
88/6
550
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Reg
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ligio
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Hom
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/Tra
vleA
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Pag
e4
of2
3
Art
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AiC
ampb
ell
Bar
ringt
onLe
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arry
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wn
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TM.
Lor
dC
reat
or
lett
erhe
ad Max
Ro
meo
Max
Ro
meo
Mr.
D.
Lee
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ly
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is
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181
182
183
184
185
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2337
Art
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ox
No
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ourB
roth
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Arti
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xN
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sR
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Col
lie
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dB
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NoGo
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Me
tape
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test
tape
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Chi
cken
The
Vib
rato
rs(15
/09/71
)T
ooL
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19tr
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VP
R10
07-A
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"~
Page
7of2
3
Art
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AlC
ampb
ell
Bar
ringt
onLe
vyB
arry
Bro
wn
Jim
my
Lond
onJim
my
Lond
onJim
myL
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ma
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The
Vib
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-
*=
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