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Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 1 of 12 Page ID #:108

1 ATKINSON, ANDELSON, LOYA, RUUD & ROMO


A Professional Corporation
2 Marlon C. Wadlington, State Bar No. 192138
MWadlington@aalrr.com
3 Aaron S. Craig, State Bar No. 204741
ACraig@aalrr.com
4 Scott D. Danforth, State Bar No. 258382
SDanforth@aalrr.com
5 12800 Center Court Drive South, Suite 300
Cerritos, California 90703-9364
6 Telephone: (562) 653-3200
Fax: (562) 653-3333
7
Attorneys for Defendant and
8 Third-Party Plaintiff BRETT CARROLL
ROMO

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10

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

11

UNITED STATES DISTRICT COURT


CENTRAL DISTRICT OF CALIFORNIA

TRESONA MULTIMEDIA, LLC, an


12 Arizona limited liability company,
13

Plaintiff,

14 v.
15 BURBANK HIGH SCHOOL VOCAL
MUSIC ASSOCIATION; BRETT
16 CARROLL and JOHN DOE
CARROLL, a married couple; ELLIE
17 STOCKWELL and JOHN DOE
STOCKWELL, a married couple;
18 MARIANNE WINTERS and JOHN
DOE WINTERS, a married couple;
19 GENEVA TARANDEK and JOHN
DOE TARANDEK, a married couple;
20 LORNA CONSOLI and JOHN DOE
CONSOLI, a married couple;
21 CHARLES RODRIGUEZ and JANE
DOE RODRIGUEZ, a married couple;
22 HAAKON SUNDRY dba ARGENT
VISUALS and JANE DOE SUNDRY,
23 a married couple,
24

Defendants.

Case No.

2:16-cv-04781-SVW-FFM

DEFENDANT BRETT CARROLLS


THIRD PARTY COMPLAINT FOR:
1) TOTAL EQUITABLE
INDEMNITY AND
CONTRIBUTION
2) PARTIAL EQUITABLE
INDEMNITY
3) BREACH OF IMPLIED
CONTRACT
4) BREACH OF ORAL
CONTRACT
5) BREACH OF IMPLIED
WARRANTIES
6) DECLARATORY RELIEF
DEMAND FOR JURY TRIAL
Judge:

Stephen V. Wilson

Complaint Filed: June 29, 2016


Trial Date:
None

25
26 BRETT CARROLL, an individual and
employee of the BURBANK UNIFIED
27 SCHOOL DISTRICT,
28
006237.00009
14329817.1

Third-Party Plaintiff,
DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 2 of 12 Page ID #:109

1 v.
2 JOSH GREENE, an individual;
SQUAREPLAY, INC. d/b/a
3 SQUAREPLAY ENTERTAINMENT,
a California corporation; and DOES 14 10,
5

Third-Party
Defendants

6
7
8
ROMO

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10

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

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006237.00009
14329817.1

COMES NOW Defendant/Third-Party Plaintiff, BRETT CARROLL, alleges


as follows:
JURISDICTION
1.

This is an action arising under the copyright laws of the United States,

17 U.S.C. 101 et seq.


2.

This Court has jurisdiction over the subject matter of this Third-Party

Complaint pursuant to 28 U.S.C. 1367.


PARTIES
3.

Third-Party Plaintiff BRETT CARROLL (hereinafter Carroll), is an

individual and employee of the Burbank Unified School District, a California


government entity located in the County of Los Angeles. Carroll resides in
California.
4.

Third-Party Defendant, JOSH GREENE, (Greene) is an individual

who, at all pertinent times hereto, was a resident of the State of California, and
during such time, provided music arrangement services for the Burbank Unified
School District vocal music program and the Burbank High School Vocal Music
Association (BHSVMA).
5.

Carroll is informed and believed and based thereon alleges that Third-

Party Defendant, SQUAREPLAY, INC. d/b/a SQUAREPLAY ENTERTAINMENT


(SE), is a California corporation owned and/or operated by Greene with its
principal place of business in California.
-2DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 3 of 12 Page ID #:110

6.

The true names or capacities, whether individual, corporate, associate

2 or otherwise, of Third-Party Defendants DOES 1-10 (DOES), inclusive, are


3 unknown to Carroll, who therefore sues said DOES by such fictitious names.
4 Carroll will amend this Third-Party Complaint to allege their true names and
5 capacities when ascertained. Carroll is informed and believes and thereon alleges
6 that each of the fictitiously named Third-Party Defendants is liable to Carroll as
7 hereinafter alleged, and that Carrolls rights against such fictitiously named Third-

ROMO

8 Party Defendants arise from such liability and indebtedness.


9

FIRST CLAIM FOR

10

TOTAL EQUITABLE INDEMNITY AND CONTRIBUTION

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
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TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

11
12

(AGAINST GREENE, SE, and DOES 1-10)


7.

Carroll re-alleges each and every allegation contained in the preceding

13 paragraphs of this Third-Party Complaint and incorporates them as though fully set
14 forth herein.
15

8.

Plaintiff Tresona Multimedia, LLC (Tresona), an Arizona limited

16 liability company, has filed a Complaint against Carroll pursuant to 17 U.S.C.


17 101 et. seq., alleging that from 2010 through 2014, the Burbank Vocal Music
18 Association and Burbank High School show choirs, at the direction of Carroll and
19 other named Defendants, infringed copyrights owned by it during that time period.
20 A true and correct copy of Tresonas Complaint is attached hereto as Exhibit A
21 (Complaint).
22

9.

For each school year from 2010 through present, Carroll, was

23 employed as the Vocal Music Director for the Burbank High School vocal music
24 program. He was an employee of the Burbank Unified School District during this
25 entire time period. He has not now, nor has he ever been, Director of the Burbank
26 High School Vocal Music Association, a nonprofit corporation comprised of parent
27 volunteers.
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006237.00009
14329817.1

10.

During the time period between 2010 and 2014, BHSVMA contracted

-3DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 4 of 12 Page ID #:111

1 with Greene, SE, and DOES to prepare and provide music arrangements to the
2 Burbank High School vocal music program, which included the musical
3 compositions (Ive Had) The Time of My Life and Magic (collectively referred
4 to as the Arrangements).
5

11.

Carroll had no part in choosing the songs (Ive Had) The Time of My

6 Life and Magic or making the Arrangements; Greene and SE selected these
7 songs for use by the Burbank High School vocal music program and its show choirs.
8 Greene, SE, and DOES were asked to provide musical arrangements that could be
ROMO

9 used by the show choirs for educational purposes and during performances.
10 Accordingly, Greene, SE, and DOES chose the songs, devised the arrangements,

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

11 and provided the arrangements to be used by the Burbank High School show choirs.
12 Greene, SE, and DOES billed the Burbank High School Vocal Music Association
13 for their services and they received monetary compensation for the Arrangements.
14

12.

Carroll is informed and believes and based thereon alleges that

15 BHSVMA has paid Greene and SE in excess of $100,000 to create arrangements for
16 the Burbank High School vocal music program, including the Arrangements at issue
17 in this litigation.
18

13.

During negotiations for the Arrangements, Greene, SE, and DOES

19 represented and/or implied that in exchange for the fees paid, if any licenses and
20 permissions were necessary for Carroll and the Burbank High School show choirs to
21 use the Arrangements, that such licenses and/or permissions had been or would be
22 obtained by Greene, SE, and/or DOES from the copyright owners and that Burbank
23 High School vocal music program would be permitted to lawfully utilize the musical
24 arrangements for performances. Because of these representations and or implied
25 assurances, Carroll believed that the Burbank High School vocal music program was
26 permitted to perform the Arrangements, and that any and all necessary permissions
27 and licenses had been obtained.
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006237.00009
14329817.1

14.

BHSVMA was merely a downstream purchaser of the Arrangements

-4DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 5 of 12 Page ID #:112

1 created by Greene, SE, and DOES, and Carroll and the Burbank High School vocal
2 music program were merely downstream users of the Arrangements.
3

15.

If it should be found that Carroll is liable under the allegations

4 contained in the Complaint (which allegations Carroll has denied and continues to
5 deny), then Carroll alleges that any injuries and/or damages suffered by Tresona
6 were proximately caused by the unlawful conduct of Greene, SE, and DOES. Third7 Party Defendants conduct and/or omissions were active, primary and affirmative, as
8 regards Tresonas alleged damages and the conduct of Carroll and other Defendants,
ROMO

9 if any, was passive, secondary and derivative only.


10

16.

If Tresona recovers judgment against Carroll, or if Carroll incurs any

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

11 expense in the defense of said lawsuit, or makes any settlement with any party to
12 this lawsuit, then Carroll is entitled to judgment and indemnity over and against
13 Greene, SE, and DOES, and each of them, for all sums incurred by Carroll by
14 reason of said judgment or settlement, including but not limited to expense of
15 investigation, and expense and costs of litigation, in defending the instant lawsuit.
16

SECOND CLAIM FOR

17

PARTIAL EQUITABLE INDEMNITY

18

(AGAINST GREENE, SE, AND DOES 1-10)

19

17.

Carroll re-alleges each and every allegation contained in the preceding

20 paragraphs of this Third-Party Complaint and incorporates them as though fully set
21 forth herein.
22

18.

Greene, SE, and DOES prepared the Arrangements in exchange for

23 monetary compensation.
24

19.

Greene, SE, and DOES represented and/or implied that in exchange for

25 the fees paid, all necessary licenses and permissions, if any, would be obtained by
26 Greene, SE, and/or DOES from the copyright owners and that Burbank High School
27 vocal music program would be permitted to lawfully utilize the musical
28 arrangements for performances. Furthermore, Greene, SE, and DOES represented
006237.00009
14329817.1

-5DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 6 of 12 Page ID #:113

1 or implied that they had the right to create and sell the Arrangements to BHSVMA
2 for use by Carroll and the Burbank High School vocal music program, and that if
3 any permissions and licenses were necessary that Greene and SE had obtained them.
4

20.

If Carroll is liable as alleged in the Complaint, any such injuries or

5 damages were proximately caused and contributed to by the fault, acts, and/or
6 omissions of Greene, SE, and DOES inclusive. Third-Party Defendants fault, acts,
7 and omissions must be compared with the fault, acts, or omissions, if any, of
8 Carroll, as well as that of any other person and parties, and any award of damages to
ROMO

9 Tresona must be apportioned to, and required to be paid by, Greene, SE, and/or
10 DOES inclusive, and each of them, according to the amount and degree of their

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

11 fault, acts and omissions.


12

21.

BHSVMA was merely a downstream purchaser of the Arrangements

13 created by Greene, SE, and DOES, and Carroll and the Burbank High School vocal
14 music program were merely downstream users of the Arrangements.
15

22.

Carroll is therefore entitled to be held harmless and indemnified by

16 Greene, SE, and DOES inclusive, and each of them, in the same amount as may be
17 paid or rendered against Carroll on the Complaint herein, by virtue of settlement or
18 judgment, according to the relative fault or percentage of fault of Third-Party
19 Defendants, and each of them, which proximately caused or contributed to the injury
20 or damages, if any suffered by Tresona. Carroll is further entitled to be held
21 harmless and indemnified by Greene, SE, and DOES inclusive, and each of them,
22 for the reasonable costs incurred in defending the main action and prosecuting the
23 Third-Party Complaint, and for reasonable attorney's fees.
24

THIRD CLAIM FOR

25

BREACH OF IMPLIED CONTRACT

26

(AGAINST GREENE, SE, AND DOES 1-10)

27

23.

Carroll re-alleges each and every allegation contained in the preceding

28 paragraphs of this Third-Party Complaint and incorporates them as though fully set
006237.00009
14329817.1

-6DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 7 of 12 Page ID #:114

1 forth herein.
2

24.

Greene, SE, and DOES agreed to prepare and provide the

3 Arrangements to the Burbank High School vocal music program in exchange for
4 monetary compensation.
5

25.

Carroll is informed and believes, and thereupon alleges, that by

6 entering into an agreement to prepare the Arrangements and by selling those


7 Arrangements to the BHSVMA for use by Carroll and the Burbank High School
8 vocal music program for good and valuable consideration, Greene, SE, and DOES
ROMO

9 implied that they had the right and authority to engage in such actions pursuant to 17
10 U.S.C. 101 et seq.

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

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26.

If it is found that Carroll is liable as alleged in the Complaint, any such

12 injuries or damages were proximately caused by Third-Party Defendants breach of


13 their implied agreement to comply with 17 U.S.C. 101 et seq.
14

27.

Carroll is entitled to be indemnified by Third Party Defendants, and

15 each of them, for any recovery that Tresona, may realize against Carroll including,
16 but not limited to, any settlement, judgments, attorneys fees, costs of suit, cost of
17 repair, and such other and further relief as the court may deem appropriate.
18

FOURTH CLAIM FOR

19

BREACH OF ORAL CONTRACT

20

(AGAINST GREENE, SE, AND DOES 1-10)

21

28.

Carroll re-alleges each and every allegation contained in the preceding

22 paragraphs of this Third-Party Complaint and incorporates them as though fully set
23 forth herein.
24

29.

Carroll is informed and believes, and based thereon alleges, that

25 Greene, SE, and DOES entered into an oral contract with the BHSVMA for the
26 preparation of the Arrangements for their use by Carroll and the Burbank High
27 School vocal music program. This oral contract required that Greene, SE, and
28 DOES comply with all requirements of 17 U.S.C. 101 et seq. and, if any licenses
006237.00009
14329817.1

-7DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 8 of 12 Page ID #:115

1 and permissions were required to obtain such licenses and permissions, when
2 Greene and SE prepared the Arrangements and provided them to Carroll and the
3 vocal music program (Oral Contract).
4

30.

If it is found that Carroll is liable as alleged in the Complaint, Carroll

5 claims that Greene, SE, and DOES breached the Oral Contract by failing to comply
6 with 17 U.S.C. 101.
7

31.

Carroll also claims that this breach of Oral Contract by Greene, SE, and

8 DOES caused harm to Carroll for which Greene, SE, and DOES should pay.
ROMO

32.

Carroll is entitled to damages from Greene, SE, and DOES in the form

10 of any amount recovered by Tresona against Carroll, as well as any settlement,

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

11 judgments, attorneys fees, costs of suit, cost of repair, and such other and further
12 relief as the court may deem appropriate.
13

FIFTH CLAIM FOR

14

BREACH OF IMPLIED WARRANTIES

15

(AGAINST GREENE, SE, AND DOES 1-10)

16

33.

Carroll re-alleges each and every allegation contained in the preceding

17 paragraphs of this Third-Party Complaint and incorporates them as though fully set
18 forth herein.
19

34.

17 U.S.C. 101 et seq. govern and dictate the rights of copyright

20 holders, as well as lay out the limitations on third party uses of copyrighted material.
21

35.

By entering into a contract with Greene, SE, and DOES to prepare and

22 sell the Arrangements for use by the Burbank High School vocal music program,
23 Greene, SE, and DOES impliedly warranted to Carroll that all work and services
24 provided would be in good faith, to the best practices of the trade as judged by
25 industry standards, and in compliance with the provisions of the 17 U.S.C. 101 et
26 seq.
27

36.

Carroll is informed and believes and thereupon alleges, that if the

28 allegations of Tresonas Complaint are accepted by the trier of fact, Greene, SE, and
006237.00009
14329817.1

-8DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 9 of 12 Page ID #:116

1 DOES, and each of them, breached said implied warranties, by failing to perform
2 their duties and/or work in a good and fair manner and according to the best
3 practices of the trade as judged by industry standards, and in compliance with the
4 provisions of the 17 U.S.C. 101 et seq.
5

37.

As a result of the foregoing breach, among others, Carroll has suffered

6 damages in the way of costs including, but not limited to, additional fees, penalties,
7 interest on outstanding fees, the retention of attorneys and experts to respond to the
8 claims asserted by Tresona and to investigate and evaluate said claims, potential
10 the trier of fact at the time of trial.

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

ROMO

9 liability to Tresona on its Complaint, as well as other expenses to be determined by


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SIXTH CLAIM FOR DECLARATORY RELIEF

12

(AGAINST GREENE, SE, AND DOES 1-10)

13

38.

Carroll realleges and incorporates each and every allegation contained

14 in the preceding paragraphs of this ThirdParty Complaint and incorporates them as


15 though fully set forth herein.
16

39.

An actual controversy exists between the parties concerning their

17 respective rights and duties because Carroll, Greene, and DOES, inclusive, dispute
18 the allegations in this ThirdParty Complaint.
19

40.

Carroll requests a judicial declaration of the rights, responsibilities, and

20 obligations of Greene, SE, and DOES, inclusive, and each of them, as to the rights
21 and obligations herein alleged.
22

PRAYER FOR RELIEF

23

WHEREFORE Third-Party Plaintiff, BRETT CARROLL, prays for

24 judgment as follows:
25

1.

For judgment against Third-Party Defendants, and each of them, in the

26 amount of any judgment entered against this Third-Party Plaintiff;


27

2.

For judgment against Third-Party Defendants, and each of them, in an

28 amount appropriate according to the degree and percentage of fault attributable to


006237.00009
14329817.1

-9DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 10 of 12 Page ID #:117

1 each such Third-Party Defendant;


2

3.

For contribution against Third-Party Defendants, and each of them, in

3 an amount appropriate according to the degree and percentage of fault attributable to


4 each such Third-Party Defendant;
5

4.

For indemnity, whether total or partial, equitable or express, for all

6 damages arising out of or relating to Plaintiff TRESONA MULTIMEDIA, LLCs

ROMO

7 claims;
8

5.

For compensatory damages as alleged herein and according to proof;

6.

For costs of suit and attorneys fees incurred herein; and

10

7.

For such other and further relief as the Court may deem just and proper.

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

11
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13 Dated: August 19, 2016
14

ATKINSON, ANDELSON, LOYA, RUUD &


ROMO

15

By: /s/ Marlon C. Wadlington


Marlon C. Wadlington
Aaron S. Craig
Scott D. Danforth
Attorneys for Defendant and
Third-Party Plaintiff BRETT CARROLL

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006237.00009
14329817.1

- 10 DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 11 of 12 Page ID #:118

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CERTIFICATE OF SERVICE
Case Name: Tresona Multimedia LLC v. Burbank High School Vocal Music
Association, et al.
No.: 2:16-CV-04781-SVW (FFMx)

On August 19, 2016, I filed the following document(s) described as


6 DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT
electronically through the CM/ECF system. All parties on the Notice of Electronic
7 Filing to receive electronic notice have been served through the CM/ECF system.
8

A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

ROMO

The party(ies) listed below are currently on the list to receive e-mail notices
for this case.

Brad A. Denton
10 brad@dentonpeterson.com
Larry A. Dunn
11 larry@dentonpeterson.com
Elena J. Cottam
12 elena@dentonpeterson.com
Denton Peterson, PC
13 1930 N. Arboleda Road, Suite 200
Mesa, Arizona 85213
14 (480) 325-9900
Fax (480) 325-9901
15
William D. Chapman, Esq.
16 CADDEN & FULLER LLP
114 Pacifica, Suite 450
17 Irvine, CA 92618
wchapman@caddenfuller.com
18 (949) 788-0827
Fax (949) 450-0650
19 A. Eric Bjorgum
Marc Karish
20 KARISH & BJORGUM, PC
16 North Marengo St., Suite 307
21 Pasadena, California 91101
Telephone: (213) 785-8070
22 4Facsimile: (213) 995-5010
Eric.bjorgum@kb-ip.com
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Attorneys for Plaintiff

Attorneys for Plaintiff

Attorneys for Defendants Burbank High


School Vocal Music Association
Boosters, Ellie Stockwell, Marianne
Winters, Geneva Tarandek,
Lorna Consoli, Charles Rodriguez, and
their respective spouses

BY EMAIL: I have caused the above-mentioned document(s) to be


electronically served on the above-mentioned person(s), who are currently
on the list to receive e-mail notices for this case.

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006237.00009
14329817.1

DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

Case 2:16-cv-04781-SVW-FFM Document 24 Filed 08/19/16 Page 12 of 12 Page ID #:119

Executed on August 19, 2016, at Cerritos, California.

2
3

I declare under penalty of perjury under the laws of the United States that the
foregoing is true and correct, and that I am employed in the office of a member of
4 the bar of this court at whose direction the service was made.
5
/s/ Marlon C Wadlington
6
Marlon C Wadlington
7
8
ROMO

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A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
CENTER COURT DRIVE SOUTH SUITE
CERRITOS CAL IFORNIA
!
TELEPHONE" #$
% $
FAX" #$
% $

ATKINSON ANDELSON LOYA RUUD

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006237.00009
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-2DEFENDANT BRETT CARROLLS THIRD PARTY COMPLAINT

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