DD NTC Errata Re MTN 4 Sum - Judgmt Ex.A PDF

Case 2:15-cv-02857-R-PLA Document 115 Filed 02/05/18 Page 1 of 45 Page ID #:4439
1 Carlos A. Leyva, Esq. (FBN 005107)

Linda S. McAleer, Esq. (SBN 249233)
2 Digital Business Law Group, P.A.
5000 Birch Street,
West Tower, Ste. 3000,
3 Newport Beach, California 92660
Tel: 619-516-1601
4 Fax: 866-635-1485
Attorneys for Plaintiff
5
7 UNITED STATES DISTRICT COURT

8 CENTRAL DISTRICT OF CALIFORNIA
9
DOC’S DREAM, LLC; CASE NO. 2:15-cv-02857-R (PLA)
Plaintiff and Hon. Manuel Real, Ctrm. 880
10 Counterclaim-Defendant
11 vs. NOTICE OF ERRATA RE:
PLAINTIFF DOC’S DREAM,
12 DOLORES PRESS, INC., MELISSA LLC.’S, MOTION FOR
SCOTT; SUMMARY JUDGMENT,
13 Defendants and EXHIBIT A.
Counterclaim-Plaintiffs
14 Discovery Cutoff: January 15, 2018
Pretrial Conf.: February 5, 2018
15 AND RELATED COUNTERCLAIMS Trial Date: March 6, 2018
AND THIRD PARTY CLAIMS.
16
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
17
PLEASE TAKE NOTICE that Plaintiff Doc’s Dream, LLC (“Plaintiff”), hereby
18
19 submits the following Notice of Errata regarding Plaintiff’s Doc’s Dream, LLC.’s,
20 Motion for Summary Judgment, Exhibit A. (Dkt. No. 82-2), which was originally
21 filed in the United States District Court, Central District of California, on January
22
14, 2018. Due to inadvertent error, the affiants failed to date their affidavits.
23
24
25 PLAINTIFF’S NOTICE OF ERRATA

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1 Plaintiff has now taken steps to contact each affiant and request that they update
2
their affidavits with the correct dates. The corrected Exhibit A is attached herewith.
3
Dated: 02/05/2018 DIGITAL BUSINESS LAW GROUP, P.A.
4
5 /s/Linda S. McAleer
Linda S. McAleer, CA SBN 239233
6
Digital Business Law Group, PC
7 3958 Talah Dr.
Palm Harbor, FL 34684
8 (800) 516-7903 Phone
(800) 257-9128 fax
9
Linda@lindamcaleer.com
10 ATTORNEY FOR PLAINTIFF
DOC’S DREAM, LLC
11
12 CERTIFICATE OF SERVICE
13
I hereby certify that on February 5, 2018, I electronically transmitted the
14
attached documents to the Clerk's office using the CM/ECF System for filing and
15
service on all registered participants of the CM/ECF System with regard to this
16
17 matter. All parties’ counsel are registered CM/ECF users and will be served by the
18 CM/ECF system.
19 /s/Linda S. McAleer
Linda S. McAleer, Esq.
20
Attorney for Plaintiff
21
22
23
24
25 PLAINTIFF’S NOTICE OF ERRATA

2
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EXHIBIT A
EXHIBIT A
UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA
Doc’s Dream, LLC

Plaintiff and Counterclaim-Defendant,
v.
Dolores Press, Inc.,
Melissa Scott,
Defendants and Counterclaim-

Plaintiffs
Case No.: 2:15−cv−02857−R−PLA
Dolores Press, Inc., Melissa Scott;
Third Party Plaintiffs,
v.
Patrick Robinson, Truth Seekers, Inc.,

and Bobbi Jones,
Defendants
AFFIDAVIT OF ROCCO PERROTTI
I, Rocco J. Perrotti, under penalties as provided by law pursuant to 28 U.S.C. § 1746,
certify that the factual statements set forth in this Affidavit are true and correct.
1. I am over the age of eighteen and competent to testify, and if called as a witness
in this matter will testify, to the facts set forth in this Affidavit based on firsthand
knowledge.
2. I was a parishioner of Dr. Eugene Scott for over 15 YEARS.
3. Dr. Scott wanted us to share his teaching, his voice, his messages, and he gave
them away for free even before the digital age.
1
4. Doc’s voice and teaching were shared worldwide, through satellite, shortwave,
Web TV, and cable.
5. Doc started his website in the late 90’s. His website included an archive of
messages that he allowed anyone to access, download, use, share and have for
free.
6. His digital archives (“Works”) were available on the Internet1 for about nine (9)
years before his death, which occurred on February 21, 2005.
7. To the best of my knowledge Dr. Scott never sent a single cease and desist letter
pursuant to his Works.
8. To the best of my knowledge Dr. Scott never sent initiated a single copyright
infringement lawsuit pursuant to his Works.
9. Dr. Scott’s conduct led me to believe that his Works were in the public
domain.
10. Said conduct was manifested in the following ways: (a) by making his Works
available for free to download from the Internet for nine (9) years; (b) by
encouraging all those aware of the Works to reproduce and distribute the Works
to others, without restriction of any kind other than attribution; and (c) by failure
to enforce his copyrights as indicated herein.
11. Said encouragement was manifested by Dr. Scott’s conduct as follows: I'll never
forget the first time I heard Dr. Scotts teaching on the Resurrection of JESUS. I
was awe struck. I lived in Glendale Ca. 91205 for 12 and ½ years from sept 1st
1984 to Dec. 17th 1996. I became a voice of Faith answering phone calls and
1
See www.drgenescott.org.
2
taking down messages for Dr. Scott. The last four months of 1996 Dr. Scott
hired me on staff. Having watched Dr. Scott off camera as well as on camera, he
was the same man, either way. As a camera man on Festival of Faith, I heard
many behind the scenes conversations. He always said he wanted us to share his
teachings and always wanted us to bring guests to the Sunday services. Dr. Scott
was always acted Honorably and Nobly. What you saw was what you got with
this man. I thank God for Dr. Scott’s teachings.
FURTHER AFFIANT SAYETH NAUGHT,
ROCCO J. PERROTTI 11/16/2017
3
Doc’s Dream, LLC

v.
Melissa Scott,

Plaintiffs
v.

and Bobbi Jones,
Defendants
AFFIDAVIT OF TIMOTHY BRIGGS
I, Timothy Briggs, under penalties as provided by law pursuant to 28 U.S.C. § 1746, certify that the
factual statements set forth in this Affidavit are true and correct.
1. I am over the age of eighteen and competent to testify, and if called as a witness in this matter
will testify, to the facts set forth in this Affidavit based on firsthand knowledge.
2. I was a parishioner of Dr. Eugene Scott for over 30 years.
3. Dr. Scott wanted us to share his teaching, his voice, his messages, and he gave them away for
free even before the digital age.
4
4. Doc's voice and teaching were shared worldwide, through satellite, shortwave,
Web TV , and cable.
5. Doc started his website in the late 90's. His website included an archive of
free.
6. His digital archives (" Works") were available on the Internet 1 for about nine (9)
years before his death, which occurred on February 21 , 2005.
9. Dr. Scott's conduct led me to believe that his Works were in the public
domain.
avai lable for free to download from the Internet for nine (9) years ; (b) by
II . Said encouragement was manifested by Dr. Scott's conduct as follows : Dr. Scott
would read books to the class and encourage us to go out and get the book as to
get a full lesson on the subject he was teaching on. His teachings on his website
were organized into subjects that his students would either listen or download to
fortify their knowledge on these subjects so Doc didn't have to repeat his
1
5
11/17/2017
6

Doc's Dream, LLC

v.
Melissa Scott,

Plaintiffs
Case No.: 2:15-cv-02857-R-PLA
v.
Patrick Robinson, Truth Seekers

Inc., and Bobbi Jones,
Defendants
AFFIDAVIT OF DAVID JOHN MILLER
I, David John Miller, under penalties as provided by law pursuant to 28 U.S.C. § 1746,
knowledge.
2. I was a parishioner of Dr. Eugene Scott for over 20 y e a r s .
7
free.
6. His digital archives ("Works") were available on the Internet 1 for about nine (9)
domain.
11. Said encouragement was manifested by Dr. Scott's conduct as follows:
Dr. Scott was my pastor, teacher and mentor. He was always truthful in what he
taught and always stated to look it up to make sure he was telling the truth.
When the age of the internet became available I used his website not only to
1
8
news of the biblical truths that he taught on with others in the world.
David John Miller 11/17/2017
9

Doc's Dream, LLC

v.
Melissa Scott,

Plaintiffs
v.
Patrick Robinson, Truth Seekers, Inc.

and Bobbi Jones,
Defendants
AFFIDAYIT OF BLAKE E. BROWN
I, Blake E. Brown, under penalties as provided by law pursuant to 28 U.S.C. § 1746, certify
that the factual statements set forth in this Affidavit are true and correct.
I. I am over the age of eighteen and competent to testify,and if called as a witness
knowledge.
2. I was a parishioner of Dr. Eugene Scott for over 20 Years.
10
Web TV, and cable.
5. Doc started his website in the late 90' s. His website included an archive of
messages that he allowed anyone to access, download, use, share, and have for
free .
6. His digital archives ("Works") were available on the Internet' for about nine (9)
years before his death, which occurred on February 21, 2005 .
9. Dr. Scott' s conduct led me to believe that his Works were in the public domain.
11. Said encouragement was manifested by Dr. Scott's conduct as follows:
My first experience with Dr. Gene Scott started in 1982 when my father,
Edmund J. Brown, took me to King's House 1. We were proud to be King's House
Number 51704. At the time, I did not truly understand, or appreciate, the in depth
knowledge Dr. Scott had with comparative religions, world history, world
1
11
geography, philosophy, mathematics, science, and general education. Dr. Gene
Scott was a master of gestalt instruction. Since 1982, I have listened to thousands
of hours of lectures I sermons from Dr. Gene Scott.
Before Dr. Gene Scott built his web site I purchased his lectures and book
reading tapes for additional review and study. Even before the web site creation,
Dr. Scott encouraged people to share his lecture tapes with others to get the
message of grace and salvation out to everyone. The only conditions Dr. Gene
Scott had was 1) not to financially charge fees, or to profit, from his work and, 2)
as with most college professors, give him credit for his work. Dr. Gene Scott
always had an issue with plagiarism which he equated as theft.
Dr. Gene Scott continued his policy of sharing by the creation of his web site
where one could access various lectures I sermons. Dr. Gene Scott stated that he
did not want money unless one received instruction and education. At that point,
one would give based on the value of the instruction and the moving of the Holy
Spirit, a tithe worthy to the teacher. Dr. Gene Scott built a worldwide church with
parishioners that would freely give money, who were moved by the Holy Spirit
after receiving instruction.
The free and open access to Dr. Gene's Scott's web site in the public domain
was a continuation of Dr. Gene's Scott's sharing the grace and salvation message
of Jesus Christ.
FURTHERAFFIANTSAYE~~
Blake E. Brown Blake E. Brown 11.29.2017
12

Doc's Dream, LLC

v.
Melissa Scott,

Plaintiffs
ase No.: 2:15-cv-02857-R-PLA
v.
Patrick Robinson, Truth Seekers

Inc., and Bobbi Jones,
Defendants
AFFIDA\TJT OF MARTIN SAPNDEBS
I, Martin Saunders, under penalties as provided by law pursuant to 28 U.S.C. §
1746, certify that the factual statements set forth in this Affidavit are true and correct.
¶1 • I am over the age of eighteen and competent to testify, and if called as a
witness in this matter will testify, to the facts set forth in this Affidavit
based on firsthand knowledge.
¶2 • I was a parishioner of Dr. Eugene Scott for over 15 Years.
¶3 • Dr. Scott wanted us to share his teaching, his voice, his messages, and he gave
13
¶4 • Doc's voice and teaching were shared worldwide, through satellite, shortwave,
Web TV, and cable.
¶5 • Doc started his website in the late 90's. His website included an archive of
messages that he allowed anyone to access, download, use, share and
have for free.
¶6• His digital archives ("Works") were available on the Internet for about nine
(9) years before his death, which occurred on February 21, 2005.
¶7 • To the best of my knowledge Dr. Scott never sent a single cease and desist
letter pursuant to his Works.
¶8 • To the best of my knowledge Dr. Scott never sent initiated a single copyright
¶9 • Dr. Scott's conduct led me to believe that his Works were in the public
domain.
¶ 10 • Said conduct was manifested in the following ways: (a) by making his Works
encouraging all those aware of the Works to reproduce and distribute the
Works to others, without restriction of any kind other than attribution;
and (c) by failure to enforce his copyrights as indicated herein.
¶ 11 • Said encouragement was manifested by Dr. Scott's conduct as follows:
• Doc always conducted himself in a manner consistent with wanting his
14
teaching played until Jesus comes, he said that many times. Every Doc
student knows this and all my friends agree that the world was his parish
and his teaching should be set free.
FURTHER AFFIANT SAYETH

NAUGHT,
MARTIN SAUNDERS
December 15, 2017
15

Doc's Dream, LLC

v.
Melissa Scott,

Plaintiffs
v.

and Bobbi Jones,
Defendants
AFFIDAVIT OF CHRISTINA PEBEIDA
I, Christina Pereida Wlder penalties as provided by law pursuant to 28 U.S.C. § 1746,
1. I am over the age of eighteen and competent to testifY, and if called as a witness
in this matter will testifY, to the facts set forth in this Affidavit based on firsthand
knowledge.
2. I was a parishioner of Dr. Eugene Scott for over 22 YEARS.
16
4. Doc' s voice and teaching were shared worldwide, through satellite, shortwave,
Web TV, and cable.
free.
6. His digital archives ("Works") were available on the Internet1 for about nine (9)
domain.
11. Said encouragement was manifested by Dr. Scott' s conduct as follows: I was
presented to Doc's ministry as an infant in 1982. I grew up with the familiarity
of seeing/ hearing Doc on the radio and television instead of the normal paid
programming. Every weekend we made the voyage to Kings House 1 on Sunday.
1
17
In between teachings on television/radio and on Sundays, my parents also had
tapes they had been given or had purchased. As technology accelerated, Doc had
placed all his teachings on a website accessible to the public in which they were
able to study, download and share at will for God's glorious Truth. I was able to
access this website for a time until Doc's widow removed them indefinitely. For
reasons unknown this same widow is vindictively persecuting parishioners
whom are sharing tape/file messages they were encouraged to share just less than
a decade prior.
CHRISTINA PEREIDA
18

Doc's Dream, LLC

v.
Melissa Scott,

Plaintiffs
v.

and Bobbi Jones,
Defendants
AFFIDAVIT OF MICHAEL EVANS
I, Michael Evans, under penalties as provided by law pursuant to 28 U.S.C. § 1746,
knowledge.
19
Web TV, and cable.
free.
domain.
11. Said encouragement was manifested by Dr. Scott's conduct as
follows: I was blessed to have born and brought up under Dr. Gene Scott's
teaching. Growing up, "the Doc" was always playing throughout our home 24/7.
I always saw him on television and short-wave radio, but as I got older I use to
1
20
sit y,ilh my por<niS and liSien 10 Doe on his public v.ebsitc. I remember how
ea.y il was 10 just log into his website and pull up any subject and liSieD 10 il.
especially loved his ·MySieries Series' sinee I wu doing some research wort< al
school. Dr. Seon's teachings helped me wilh the research because aL any g.i\'en
time of the dny I could log into his public online website to listen to his teachings
on any subj«:l any time of the day or night to lu:lp me. 111ey were an available
source fm: to all for the listening and downloodina. I learned early on how to
operate c:omput<tS. I learned it in school. so I knew lhe public website had the
capability of downloading his messages. Dr. Sc:ou w:r11c:d us to bave lhcse
messai!eS for our personal libraries. Dr. !-;ont t '~ mM(."CM ht<ive guidM the coUJ'fc
of life tmd I don't know what my life would be Jikc without his teachings!
Jlllt'l.tii!:H :U'FL\1\T SAYETH l'" t :GIIT,
'·
12/02/2017
21

Doc’s Dream, LLC

v.
Melissa Scott,

Plaintiffs
v.

and Bobbi Jones,
Defendants
AFFIDAVIT OF VAL MORTENSEN
I, Val Mortensen, under penalties as provided by law pursuant to 28 U.S.C. § 1746,
knowledge.
22
Web TV, and cable.
free.
domain.
11. Said encouragement was manifested by Dr. Scott’s conduct as follows:
12. Dr. Scott repeated multiple times he could be dead 20 years and no one would
ever know he was dead. He frequently mentioned that the archives (works)
would always be available to his students and the world. We could refer those
1
23
interested in his teaching to the archives (works) and programming to answer
their questions. The archives (works) would always be available for us to
reference as desired. Dr. Scott requested parishioners to will or donate real estate
to the ministry for the perpetuation of his teaching as well as tithes and gifts for
the same purpose. During the last year of his life Doc continued to work very
hard to make sure there would be enough assets, donations and pledges to keep
the teaching going at the Cathedral every Sunday on the big screen and on the
network after his passing and he states the archives (works) would always be
available to us for the rest of our lives. We and our daughter tithes on every
nickel we earned as well as the sale of our home because Doc promised his
teaching and archives (works) would always be there for us and to reach others.
Dr. Scott used not only the Bible, science, math, history, geology, geography and
archaeology as well as ancient manuscripts and languages to teach the reality of
Christ and the truth of the Bible. We believed Dr. Scott’s teaching would and
should be available as he repeatedly stated, and we committed our income and
lives to make sure that happened.
12/12/2017
24

Doc's Dream, LLC

v.
Melissa Scott,

Plaintiffs
v.

and Bobbi Jones,
Defendants
AFFIDAVII OF BOBBI JONES
I, Bobbi Jones, under penalties as provided by law pursuant to 28 U.S.C. § 1746, certify
that the factual statements set forth in this Affidavit are true and correct
1. I am over the age of eighteen and competent to testify,and if called as a witness
knowledge.
25
Web TV, and cable.
free.
domain.
11. Said encouragement was manifested by Dr. Scott's conduct as follows: When I
became a student and parishioner of Dr. Scott in 1982 he would give out his
tapes free just for the asking, or you could buy them at Dolores Press book store.
On every tape I have gotten is the statement, which I still have in my possession
1
S ee www.drgenescott.org.
26
say: "Pastors and laymen alike will want these tapes for their personal libraries
as messages to be reviewed often and SHARED WITH OTHERS. Dr Scott
takes us into God's Word in a unique way that makes it come alive in practical
application to everyday life." Dr. Scott loved God's Word and encouraged his
teaching in all manners of communication. Tape cassettes that were sold at
Dolores Press could be freely bought for ourselves, friends, family, neighbors
etc. There were no limits whatsoever. They were freely available. As the
church proceeded into the 90s and the digital age was upon us, Dr. Scott
formulated his online website which made his messages easy access for those
with computers. I personally had a computer at home at the time and was able to
log in and select any subject I wanted to listen to freely. It was a blessing. Dr.
Scott felt strongly about providing us his teaching through every aspect of
communication. He was firm about that! And I have tape after tape of him
mentioning how his tapes are always playing round the clock. When Dr. Scott
became ill he made the promise to us that his works of 30 years would continue
round the clock until Jesus comes. Here is one of the quotes: Quote "This kind
of teaching is 24 hours round the clock. This kind of teaching is ageless. Any of
you that are under the illusion that I'm not going to be around a while and that
I'm not going to finish Romans, you are not just under an illusion, you are
delusional. I'll be around a long, long time. The unknown can get me. I've set my
life to the unknown and what is the known, and I've set my emotions for the
worst but when I know who the enemy is or what the enerpy is, I go into an
attack mode. Me and God, and you if you want to go along. You listen to
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teaching on these subjects, Pyramids, leaf cutting ants in Brazil, Walruses at the
arctic which remind me of deacon boards, their organization and their
denominations. It's amazing what you can see as you look at life. Pyramids, Lost
Tribes, various books of the Bible we've taught verse by verse. Round the clock
we are going, round the world by satellite and by short wave radio. You
shouldn't have to just listen to this Sunday night 4 hours and from 10-11 on 56.
Open your eyes to the other access media available. But for those who really
want the teaching, get a shortwave radio, you can pick it up anywhere in the
world, get a small dish ......then he goes into the reading on Velikovsky ofhis
teaching in 1987. This tape is dated 10/24/04, just four months later he went
home. Another quote: In reference to J. Vernon McGee, it doesn't matter
that he's dead....his voice is eternal. He's still alive! (Although he's dead) You
could come to the Cathedral or to King's House 1 every Sunday and watch me on
a big screen, repeating the last 30 years and you would get more! I expect "my"
voice to be on television, radio, and the INTERNET because I haven't changed
that much. I get fat sometimes and skinny sometimes. You know, God has
gifted me with white hair when I was 31 so that people couldn't tell how old I
was. But the voice is the same! The Word is the same! And I expect this
ministry to be occupying the arenas of communication til Jesus comes! I have
60-70 thousand hours of teaching, and I ain't even started yet! That's what this
ministry is and this church is about. We are taking the truth of God's Word to
the world. That's why this ministry exists, for my voice." Dr. Scott's
website was download accessible since cassette tapes were out dated and moved
28
to digital. Dr. Scott wanted his students to have 'his' teaching available 24/7 and
when he was alive he made sure we had access to every available means of
communication to hear his teaching anytime of the day or night for our needs!
As Dr. Scott became more ill in his fmal days he wanted his wife to continue to
broadcast his messages. She promised she would. We witnessed him on stage
with his wife promising us his teachings, all ofthem, 60-70 thousand hours, and
30 years of his works to continue until Jesus comes. His wife stood right there
beside him and promised him and us she would. She failed in her promise.
Three weeks after he passed that website carne down. She kept making excuses
and said she would put it back up but never did. We have many more tapes and
videos with comments like the two examples above stating his wishes for his
teaching. What once was in the public's view was taken down and a death wish
promise was not kept.
Bobbi Jones 12/12/2017
29

Doc’s Dream, LLC

v.
Melissa Scott,

Plaintiffs
v.

and Bobbi Jones,
Defendants
AFFIDAVIT OF PATRICK ROBINSON
I, Patrick Robinson, under penalties as provided by law pursuant to 28 U.S.C. § 1746,
knowledge.
2. I was a parishioner of Dr. Eugene Scott for over 21 years before his death in
2005.
30
Web TV, and cable.
messages that he allowed anyone to access, download, use, share, and have for
free.
domain.
11. Said encouragement was manifested by Dr. Scott’s conduct as follows:
After being a student of Doc for only a short time, my entire life, and direction I
was heading, was changed, and I was truly set free by God’s Grace. He often
beamed with pride, regarding all of the teaching he had amassed, and often
1
31
indicated that we, his students, would always have access to the teaching. He
even made statements that he would find a way to make something automated,
so that if the rapture took place that something would automatically take over
and play his teaching on a loop. He desired for us to not only listen to his live
broadcast, but to go to his archives, and find any message we would need. I
know that he was proud of his digitizing efforts, and had amassed some 5000
messages that he wanted the world to have access to, “till the Lord returns”, he
often said. He was in the processing of digitizing all of his works when he died,
and within 3 weeks, all the teaching was gone.
He always wanted us to share the truths we’ve learned, and send people to his
website to get anything they needed. He allowed us to download for free any
message we wanted. I regret, terribly, that I had not the foreknowledge to see the
writing on the wall, and download his whole website. My collection was only a
couple of downloads, plus a couple of tape albums, some magazines and Doc
Notes. When his teaching became unavailable, within a few weeks after his
death, I was devastated. I knew he wanted his voice, his teaching, all of it,
available to the world, free access, no limitations… and it was all gone. My
ministry depended on his teaching; and I always pointed people to him as the
source of what I was trying to teach them, and I had often sent them to the
website to get their own teaching, straight from the source, which I could no
longer do. I was truly devastated. It was only later, that I was able to find a large
32
collection of Doc’s teaching that someone had downloaded, and put up on the
torrents. Thank God for the people who did that.
This world needs the amazing instructive mind of Dr. Gene Scott, and he wanted
us to have access to all his teaching “for the rest of our lives”. He knew, and
stated many times that the evil forces in this world would kill him, and silence
his voice if it were possible, unless his followers would raise up and resist the
those forces. He knew that his teaching would be snuffed out whenever it came
up, but that there would be other places that it would pop up. He allowed us to
download his teaching, his archives, because he knew that once it was out there
in cyberspace, that there was no stopping it. He never registered any copyrights
on his teaching, any of it, but he did for all of his paintings. He was a very smart
man, and had he been concerned with protecting the copyrights on his teaching,
as rich as he was, he would have registered everything, as well as preventing
downloading of the digital files off his website. He knew his parishioners were
downloading, and I have a video, where he talks about another minister that was
complaining about people stealing from him, recording his messages off the TV,
and Doc states that everyone downloads his teaching off of the internet, and that
wasn’t a crime. He just didn’t want anyone to be selling the teaching… to profit
off of his teaching. All he wanted was attribution.
His overt actions by letting us download for free, knowing that we were sharing
the teaching, just like he said we would want to do on his cassette tapes, clearly
33
places his teaching in the public domain, and the world should have free access
to at least what he had in his archives, plus maybe what everyone had already
purchased on cassette tapes, since the inserts state, that not only would we want
the messages to be in our personal libraries, to be reviewed often, but that we
also would want to share them with others. Dr. Scott wanted his voice and
teaching, all of it, flowing over the world, through all media, until Jesus returns.
He often expressed those desires to his students. And… he often stated that, “the
world is my parish”, not just that one church in Glendale that his doing anything
but spreading his teaching. He was listening to J. Vernon McGhee one day, and
was bragging that he was dead, yet still alive through his teaching, and he was
talking to his wife as he stated that that is what he wanted for his voice, for all of
his teaching. That people wouldn’t know if he was dead or alive because the
tapes would keep playing.
Dr. Gene Scott, PHD’s actions, and desires expressed over the years, in regards
to his teaching, placed a call on my heart, and in my spirit, to do whatever I
could do, to help him spread that teaching, freely, all over this world.
12. I have downloaded Dr. Scott’s teachings from the Archive.
13. I don’t recall the year I followed the instructions from Dr. Scott’s website for
downloading Real Audio to listen to his teachings but their date ranges covers
from 1996 through 1999. See Exhibit 1, Dr. Scott’s instructions for downloading
“Real Networks” Real Audio program to listen to his messages through the
years.
34
14. I followed Dr. Scott’s instructions from the website page and I successfully
downloaded the Real Audio Player2 to my computer.
15. I do recall depending on the size of the files some took longer to download than
others but as modem speeds increased the download time was much shorter.
16. I downloaded a few files from the Archive and possibly the pages listed and was
able to play them on my personal computer for my own viewing whenever I
wish.
_____________________________________
Patrick A. Robinson
2
RealAudio is a proprietary RealAudio is a proprietary audio format developed by RealNetworks and first released
in April 1995. It uses a variety of audio codecs, ranging from low-bitrate formats that can be used over dialup
modems, to high-fidelity formats for music. It can also be used as a streaming audio format that is played at the
same time as it is downloaded. In the past, many internet radio stations used RealAudio to stream their programming
over the internet in real time. In recent years, however, the format has become less common and has given way to
more popular audio formats.
RealAudio was developed as a streaming media format, meaning that it can be played while it is downloaded. It is
possible to stream RealAudio using HTTP. In this case, the RealAudio file is retrieved similarly to a normal web
page, but playback begins as soon as the first part is received and continues while the rest of the file is downloaded.
Source: Wikipedia.
35
14. I followed Dr. Scott’s instructions from the website page and I successfully
downloaded the Real Audio Player2 to my computer.
15. I do recall depending on the size of the files some took longer to download than
others but as modem speeds increased the download time was much shorter.
16. I downloaded a few files from the Archive and possibly the pages listed and was
able to play them on my personal computer for my own viewing whenever I
wish.
_____________________________________
Patrick A. Robinson 11/17/2017
2
RealAudio is a proprietary RealAudio is a proprietary audio format developed by RealNetworks and first released
in April 1995. It uses a variety of audio codecs, ranging from low-bitrate formats that can be used over dialup
modems, to high-fidelity formats for music. It can also be used as a streaming audio format that is played at the
same time as it is downloaded. In the past, many internet radio stations used RealAudio to stream their programming
over the internet in real time. In recent years, however, the format has become less common and has given way to
more popular audio formats.
RealAudio was developed as a streaming media format, meaning that it can be played while it is downloaded. It is
possible to stream RealAudio using HTTP. In this case, the RealAudio file is retrieved similarly to a normal web
page, but playback begins as soon as the first part is received and continues while the rest of the file is downloaded.
Source: Wikipedia.
35
EXHIBIT 1
36
https://web.archive.org/web/19961220193540/http://www.drgenescott.org:80/
37
https://web.archive.org/web/19970622131932/http://drgenescott.org:80/
38
https://web.archive.org/web/19981203020217/http://207.155.78.66:80/
39
http://207.155.78.66:80/DocNote59.htm
40

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Case 2:15-cv-02857-R-PLA Document 115 Filed 02/05/18 Page 1 of 45 Page ID #:4439

1 Carlos A. Leyva, Esq. (FBN 005107)

7 UNITED STATES DISTRICT COURT

25 PLAINTIFF’S NOTICE OF ERRATA

25 PLAINTIFF’S NOTICE OF ERRATA

UNITED STATES DISTRICT COURT

Doc’s Dream, LLC

Defendants and Counterclaim-

Patrick Robinson, Truth Seekers, Inc.,

AFFIDAVIT OF ROCCO PERROTTI

I, Rocco J. Perrotti, under penalties as provided by law pursuant to 28 U.S.C. § 1746,

2. I was a parishioner of Dr. Eugene Scott for over 15 YEARS.

them away for free even before the digital age.

Web TV, and cable.

years before his death, which occurred on February 21, 2005.

pursuant to his Works.

infringement lawsuit pursuant to his Works.

to enforce his copyrights as indicated herein.

this man. I thank God for Dr. Scott’s teachings.

FURTHER AFFIANT SAYETH NAUGHT,

ROCCO J. PERROTTI 11/16/2017

Doc’s Dream, LLC

Defendants and Counterclaim-

Patrick Robinson, Truth Seekers, Inc.,

AFFIDAVIT OF TIMOTHY BRIGGS

2. I was a parishioner of Dr. Eugene Scott for over 30 years.

free even before the digital age.

Web TV , and cable.

years before his death, which occurred on February 21 , 2005.

pursuant to his Works.

infringement lawsuit pursuant to his Works.

to enforce his copyrights as indicated herein.

UNITED STATES DISTRICT COURT

Doc's Dream, LLC

Defendants and Counterclaim-

Patrick Robinson, Truth Seekers

AFFIDAVIT OF DAVID JOHN MILLER

2. I was a parishioner of Dr. Eugene Scott for over 20 y e a r s .

them away for free even before the digital age.

years before his death, which occurred on February 21, 2005.

pursuant to his Works.

infringement lawsuit pursuant to his Works.

to enforce his copyrights as indicated herein.

11. Said encouragement was manifested by Dr. Scott's conduct as follows:

FURTHER AFFIANT SAYETH NAUGHT,

David John Miller 11/17/2017

UNITED STATES DISTRICT COURT

Doc's Dream, LLC

Defendants and Counterclaim-

Patrick Robinson, Truth Seekers, Inc.

AFFIDAYIT OF BLAKE E. BROWN

I. I am over the age of eighteen and competent to testify,and if called as a witness

2. I was a parishioner of Dr. Eugene Scott for over 20 Years.

them away for free even before the digital age.

Web TV, and cable.

years before his death, which occurred on February 21, 2005 .

pursuant to his Works.

infringement lawsuit pursuant to his Works.

to enforce his copyrights as indicated herein.

11. Said encouragement was manifested by Dr. Scott's conduct as follows:

Edmund J. Brown, took me to King's House 1. We were proud to be King's House

geography, philosophy, mathematics, science, and general education. Dr. Gene

of hours of lectures I sermons from Dr. Gene Scott.