Siegel and Shuster document archive - settlements, other material from Pacific Pictures case

7/29/2019 Siegel and Shuster document archive - settlements, other material from Pacific Pictures case

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DECLARATION OF KEITH G. ADAMS IN SUPPORT OF DEFENDANTS MOTION FOR SUMMAR

JUDGMENT ON DCS FOURTH, FIFTH, AND SIXTH CLAIMS

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Marc Toberoff (State Bar No. 188547)[email protected]

Keith G. Adams (State Bar No. 240497)[email protected]

Pablo D. Arredondo (State Bar No. 241142)[email protected] Harris (State Bar No. 255557)[email protected]

TOBEROFF & ASSOCIATES, P.C.22337 Pacific Coast Highway #348Malibu, California 90265Telephone: (310) 246-3333Fax: (310) 246-3101

Attorneys for Defendants Mark WarrenPeary, as personal representative of theEstate of Joseph Shuster, Jean Adele Peavy,and Laura Siegel Larson, individually and

as personal representative of the Estate ofJoanne Siegel

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION

DC COMICS,

Plaintiff,

vs.

PACIFIC PICTURES CORPORATION;

IP WORLDWIDE, LLC; IPW, LLC;

MARC TOBEROFF, an individual;

MARK WARREN PEARY, as personal

representative of the ESTATE OF

JOSEPH SHUSTER; JEAN ADELE

PEAVY, an individual; LAURA

SIEGEL LARSON, individually and as

personal representative of the ESTATE

OF JOANNE SIEGEL, and

DOES 1-10, inclusive,

Defendants.

Case No: CV 10-03633 ODW (RZx)

Hon. Otis D. Wright II, U.S.D.J.Hon. Ralph Zarefsky, U.S.M.J.

DECLARATION OF KEITH G.

ADAMS IN SUPPORT OFDEFENDANTS MOTION FORPARTIAL SUMMARYJUDGMENT ON DCSFOURTH, FIFTH, AND SIXTHCLAIMS

Notice of Motion and Motion;Statement of Undisputed Facts andConclusions of Law; [Proposed]Order and Statement of Decision

filed concurrently herewith

Complaint filed: May 14, 2010Discovery Cutoff: None SetTrial Date: None Set

Date: March 11, 2013Time: 1:30 p.m.Place: Courtroom 11

Case 2:10-cv-03633-ODW-RZ Document 578 Filed 02/05/13 Page 1 of 9 Page ID #:37330


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Ex. Title Page

AOctober 2, 1992 agreement between DC Comics, Frank Shuster and

Jean Peavy6

B October 19, 2001 letter from Kevin Marks to John Schulman 7

C October 26, 2001 letter from Schulman to Marks 13

DNovember 28, 2001 agreement between Pacific Pictures

Corporation, Jean Peavy and Mark Warren Peary21

E February 1, 2002 letter from Patrick Perkins to Marks 25

F May 9, 2002 letter from Joanne Siegel to Richard D. Parsons 82

G February 12, 2002 agreement between Pacific Pictures Corporation

and Ariel Emanuel

85

HSeptember 21, 2002 letter from Joanne Siegel and Laura Siegel

Larson to Marks and Bruce Ramer

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IOctober 23, 2002 agreement between IP Worldwide, Joanne Siegel

and Laura Siegel Larson93

J October 7, 2003 order admitting will to probate 97

K

October 30, 2003 agreement between Pacific Pictures Corporation,

and Mark Warren Peary, as executor of the estate of Joseph

Shuster, and Jean Peavy

102

L Letter sent from Ariel Emanuel to Bruce Rosenblum 106

M March 12, 2004 Certificate of Recordation 107

N

April 12, 2004 agreement between IP Worldwide, Joanne Siegel

and Laura Siegel Larson 123

OSeptember 10, 2004 letter from Marc Toberoff to Mark Warren

Peary and Jean Peavy124

PNovember 23, 2001 agreement between Marc Toberoff, Mark

Warren Peary and Jean Peavy125

Q October 3, 2004 agreement between Marc Toberoff, Joanne Siegel 129



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and Laura Siegel Larson

RAnonymous document entitled SUPERMAN MARC

TOBEROFF TIMELINE135

SExcerpts from the October 7, 2006 deposition of Kevin Marks in

Siegel142

TExcerpts from the November 2, 2006 deposition of Ariel Emanuel

in in Siegel154

UExcerpts from the November 11, 2006 deposition of Mark Warren

Peary in Siegel168

V November 15, 2006 letter from Alexander Merino to Adam Hagen 200

WExcerpts from the November 17, 2006 deposition of Marc Toberoff

in Siegel201

X March 26, 2007 Declaration Of Wayne M. Smith in Siegel 277

YMay 29, 2007 Opposition To Plaintiffs Motion For Partial

Summary Judgment in Siegel285

Z September 25, 2007 Declaration Of Michael Bergman in Siegel 381

AASecond Amended Counterclaims, filed in Siegel, dated February

17, 2011400

BB

Defendants Request For Judicial Notice In Support Of

Consolidated Motion And Motion To Dismiss Pursuant To Fed. R.

Civ. P. 12(b)(6), filed in this case at docket entry 333-1 on October

14, 2011

438

CC

DC Comics Response To Defendants Request For Judicial Notice

In Support Of Consolidated Motion To Dismiss Pursuant To Fed.

R. Civ. P. 12(b)(6), filed in this case at docket entry 335 on October

24, 2011

448

DD Mediation Questionnaire filed in connection with Ninth Circuit 452



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Case Number 11-56934, dated November 9, 2011

EEDefendant Marc Toberoffs Response To Plaintiff DC Comics

Second Set Of Interrogatories, dated February 23, 2012457

FFExcerpts from the September 18, 2012 deposition of Marc Toberoff

in this case467



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DECLARATION OF KEITH G. ADAMS IN SUPPORT OF DEFENDANTS MOTION FOR SUMMARJUDGMENT ON DCS FOURTH, FIFTH, AND SIXTH CLAIMS

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DECLARATION OF KEITH G. ADAMS

I, Keith G. Adams, declare as follows:

1. I am an attorney at the law firm of Toberoff & Associates, P.C., counseof record for defendants Mark Warren Peary, as personal representative of the Estate

of Joseph Shuster, Jean Adele Peavy, and Laura Siegel Larson, individually and as

personal representative of the Estate of Joanne Siegel, in the above-captioned action

and submit this declaration in support of Defendants Motion For Partial Summary

Judgment On DCs Fourth, Fifth, And Sixth Claims.

2. Attached hereto as Exhibit A is a true and correct copy of anagreement between DC Comics, on the one hand, and Frank Shuster and Jean Peavyon the other, signed as of October 2, 1992.

3. Attached hereto as Exhibit B is a true and correct copy of a letter senby Kevin Marks to John Schulman, dated October 19, 2001.

4. Attached hereto as Exhibit C is a true and correct copy of a letter senby John Schulman to Kevin Marks, dated October 26, 2001.

5. Attached hereto as Exhibit D is a true and correct copy of anagreement between Pacific Pictures Corporation, on the one hand, and Jean Peavy

and Mark Warren Peary, on the other, signed as of November 28, 2001.

6. Attached hereto as Exhibit E is a true and correct copy of a letter senby Patrick Perkins to Kevin Marks, dated February 1, 2002.

7. Attached hereto as Exhibit F is a true and correct copy of a letter sentby Joanne Siegel to Richard D. Parsons, dated May 9, 2002.

8. Attached hereto as Exhibit G is a true and correct copy of anagreement between Pacific Pictures Corporation, on the one hand, and Ariel

Emanuel, on the other, signed as of February 12, 2002.

9. Attached hereto as Exhibit H is a true and correct copy of a letter senby Joanne Siegel and Laura Siegel Larson to Kevin Marks and Bruce Ramer, dated

September 21, 2002.



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10. Attached hereto as Exhibit I is a true and correct copy of an agreemebetween IP Worldwide, on the one hand, and Joanne Siegel and Laura Siegel Larson

on the other, signed as of October 23, 2002.

11. Attached hereto as Exhibit J is a true and correct copy of an OrderAdmitting Will To Probate, Appointing Executor And Authorizing Independent

Administration of Estate With Limited Authority, issued on October 7, 2003.

12. Attached hereto as Exhibit K is a true and correct copy of anagreement between Pacific Pictures Corporation, on the one hand, and Mark Warren

Peary, as executor of the estate of Joseph Shuster, on the other, signed as of October

30, 2003.13. Attached hereto as Exhibit L is a true and correct copy of a letter sen

by Ariel Emanuel to Bruce Rosenblum.

14. Attached hereto as Exhibit M is a true and correct copy of aCertificate of Recordation, dated March 12, 2004.

15. Attached hereto as Exhibit N is a true and correct copy of anagreement between IP Worldwide, LLC, on the one hand, and Joanne Siegel and

Laura Sigel Larson, on the other, signed as of April 12, 2004.

16. Attached hereto as Exhibit O is a true and correct copy of anagreement between Pacific Pictures Corporation, on the one hand, and Mark Warren

Peary, individually and as the executor of Joseph Shusters estate, and Jean Peavy, o

the other, dated September 10, 2004.

17. Attached hereto as Exhibit P is a true and correct copy of anagreement between Marc Toberoff, on the one hand, and Mark Warren Peary,

individually and as executor of Joseph Shusters estate, and Jean Peavy, on the other

dated as of November 23, 2001.

18. Attached hereto as Exhibit Q is a true and correct copy of anagreement between Marc Toberoff, on the one hand, and Joanne Siegel and Laura

Siegel Larson, on the other, signed as of October 3, 2004.



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19. Attached hereto as Exhibit R is a true and correct copy of a documenentitled SUPERMAN MARC TOBEROFF TIMELINE, anonymously sent to

executives at Warner Bros. sometime between 2005 and 2006.

20. Attached hereto as Exhibit S is a true and correct copy of excerptsfrom the transcript of the October 7, 2006 deposition of Kevin Marks in Siegel v.

Warner Bros. Entertainment, Inc., 04-CV-8400 ODW (RZx) (Siegel).

21. Attached hereto as Exhibit T is a true and correct copy of excerptsfrom the transcript of the November 2, 2006 deposition of Ariel Emanuel in Siegel.

22. Attached hereto as Exhibit U is a true and correct copy of excerptsfrom the transcript of the November 11, 2006 deposition of Mark Warren Peary inSiegel.

23. Attached hereto as Exhibit V is a true and correct copy of a letter senby Alexander Merino to Adam Hagen, dated November 15, 2006.

24. Attached hereto as Exhibit W is a true and correct copy of excerptsfrom the transcript of the November 17, 2006 deposition of Marc Toberoff in Siegel

25. Attached hereto as Exhibit X is a true and correct copy of theDeclaration Of Wayne M. Smith In Support Defendants Motion To Compel

Production Of Whistle-Blower Documents, filed in Siegel,dated March 26, 2007.

26. Attached hereto as Exhibit Y is a true and correct copy of DefendantOpposition To Plaintiffs Motion For Partial Summary Judgment And Memorandum

Of Points And Authorities In Support Thereof, filed in Siegel.

27. Attached hereto as Exhibit Z is a true and correct copy of theDeclaration Of Michael Bergman In Response To The Declaration Of Marc Toberof

Filed Pursuant To The Courts September 17, 2007 Order, filed in Siegel dated

September 25, 2007.

28. Attached hereto as Exhibit AA is a true and correct copy of theSecond Amended Counterclaims, filed in Siegel, dated February 17, 2011.

29. Attached hereto as Exhibit BB is a true and correct copy of



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Defendants Request For Judicial Notice In Support Of Consolidated Motion And

Motion To Dismiss Pursuant To Fed. R. Civ. P. 12(b)(6), filed in this case as docket

entry 333-1 on October 14, 2011.

30. Attached hereto as Exhibit CC is a true and correct copy of DCComics Response To Defendants Request For Judicial Notice In Support Of

Consolidated Motion To Dismiss Pursuant To Fed. R. Civ. P. 12(b)(6), filed in this

case as docket entry 335 on October 24, 2011.

31. Attached hereto as Exhibit DD is a true and correct copy of theMediation Questionnaire filed in connection with Ninth Circuit Case Number 11-

56934, dated November 9, 2011.32. Attached hereto as Exhibit EE is a true and correct copy of Defendan

Marc Toberoffs Responses To Plaintiff DC Comics Second Set Of Interrogatories

dated February 23, 2012.

33. Attached hereto as Exhibit FF is a true and correct copy of excerptsfrom the transcripts of the September 18, 2012 deposition of Marc Toberoff in this

case.

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I declare under penalty of perjury of the laws of the United States of America

that the foregoing is true and correct.

Executed on February 4, 2013, at Malibu, California.

Keith G. Adams



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EXHIBIT W

273



278/486

EXHIBIT W

274



279/486

EXHIBIT W

275



280/486

EXHIBIT W

276



281/486EXHIBIT X

277



282/486EXHIBIT X

278



283/486EXHIBIT X

279



284/486EXHIBIT X

280



285/486EXHIBIT X

281



286/486EXHIBIT X

282



287/486

EXHIBIT Y

283



288/486

EXHIBIT Y

284



289/486

EXHIBIT Y

285



290/486

EXHIBIT Y

286



291/486

EXHIBIT Y

287



292/486

EXHIBIT Y

288



293/486

EXHIBIT Y

289



294/486

EXHIBIT Y

290



295/486

EXHIBIT Y

291

Case 2:1