Stokes v. UMG

Case 2:20-cv-00370 Document 1 Filed 01/14/20 Page 1 of 15 Page ID #:1
1
Paul N. Philips, Esq., SBN 187928
e-mail: pnp@pnplegal.com
2 Samantha E. Mirabello, Esq., SBN 325827
3 e-mail: sm@pnplegal.com
LAW OFFICES OF PAUL N. PHILIPS, APLC
4
468 North Camden Drive, Suite 200
5 Beverly Hills, California 90210
6
Telephone: (323) 813-1126
Facsimile: (310) 854-6902
7
8 Attorneys for Plaintiff MICHAEL STOKES

9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
11
12
MICHAEL STOKES, MICHAEL ) CASE NO.:
13 STOKES A/K/A MIKE STOKES )
A/K/A MICHAEL STOKES D/B/A ) COMPLAINT FOR DAMAGES;
14
WILLOW GIRL MUSIC A/K/A ) DEMAND FOR TRIAL BY JURY
15 MICHAEL STOKES D/B/A )
16
SKYTOWER MUSIC, ) 1. COPYRIGHT INFRINGEMENT
) 2. CONVERSION
17
Plaintiff, ) 3. INTENTIONAL INTERFERENCE
18 ) WITH PROSPECTIVE ECONOMIC
v. ) ADVANTAGE
19
) 4. UNFAIR BUSINESS PRACTICES
20 UNIVERSAL MUSIC GROUP, ) [CAL. BUS. & PROF. CODE §17200]
21
INC.; UNIVERSAL MUSIC ) 5. UNJUST ENRICHMENT
DISTRIBUTION; UMG ) 6. FINANCIAL ELDER ABUSE
22 RECORDINGS, INC.; CONCORD ) [CAL. WELFARE & INSTITUTIONS
23 MUSIC GROUP, INC.; CONCORD ) CODE §15610.30]
MUSIC PUBLISHING; CRAFT ) 7. ACCOUNTING
24
RECORDINGS; THE BICYCLE ) 8. DECLARATORY RELIEF
25 MUSIC COMPANY, INC.; BIKE )
26
MUSIC; KOBALT MUSIC )
PUBLISHING AMERICA, INC.; )
27 KOBALT MUSIC GROUP; )
28 KOBALT MUSIC SERVICES )
COMPLAINT FOR DAMAGES;

DEMAND FOR TRIAL BY JURY
1
AMERICA, INC.; WARNER )
MUSIC GROUP; )
2 WARNER/CHAPPELL MUSIC, )
3 INC.; SONY MUSIC )
ENTERTAINMENT; SONY/ATV )
4
MUSIC PUBLISHING GROUP, )
5 )
6
Defendants. )
)
7
8 COMES NOW Plaintiff MICHAEL STOKES (“Mr. Stokes”), and asserts his
9 Claims and Causes of Action against the parties named herein as Defendants as
10 follows:
11 1. Mr. Stokes asserts the within claims against Universal Music Group, Inc.,
12 Universal Music Distribution, UMG Recordings, Inc. (collectively “ Defendants
13 Universal”), Concord Music Group, Inc., Concord Music Publishing, Craft Recordings
14 (collectively “Defendants Concord”), The Bicycle Music Company, Inc., Bike Music
15 (collectively “Defendants Bicycle”), Kobalt Music Publishing America, Inc., Kobalt
16 Music Group, Kobalt Music Services America, Inc. (collectively “Defendants
17 Kobalt”), Warner Music Group, Warner/Chappell Music, Inc. (collectively
18 “Defendants Warner”), Sony Music Entertainment, and Sony/ATV Music Publishing
19 Group (collectively “Defendants Sony”);
20 PARTIES
21 2. Mr. Stokes resides in the County of Los Angeles within the Central
22 District of the State of California;
23 3. Defendants Universal, Defendants Concord, Defendants Bicycle,
24 Defendants Kobalt, Defendants Warner, and Defendants Sony all maintain systematic
25 contacts with, and do substantial business in the County of Los Angeles, Central
26 District of the State of California;
27 ////
28 ////
2

1 JURISDICTION AND VENUE

2 4. Jurisdiction of the claims made herein arises under the copyright laws of
3 the United States as set forth in the Copyright Act, 17 U.S.C. § 101, et seq. This Court
4 has subject matter jurisdiction over the action pursuant to 28 U.S.C. § 1331 (federal
5 question);
6 5. Venue is proper in this Court pursuant to 28 U.S.C. § 1392(b)(2) in that a
7 substantial portion of the events giving rise to the claims occurred in this Judicial
8 District;
9 FACTS COMMON TO ALL COUNTS
10 6. Michael Stokes is a multi-Grammy-nominated music producer, composer,
writer, musician, and music publisher who has at times herein relevant done business
11
12 as Michael Stokes, Mike Stokes, Michael Stokes d/b/a Willow Girl Music, and
13 Michael Stokes d/b/a Skytower Music;
14 7. Mr. Stokes has composed, written, produced, and arranged for world-
15 renowned acts including but not limited to Tina Turner, Whitney Houston, Prince,
16 Quincy Jones, Earth Wind & Fire, Merle Haggard, Color Me Bad, Mavis Staples, Patti
17 Labelle, Janet Jackson, Herb Alpert, Smokey Robinson, Booker T., Magic Lady, Little
18 Richard, Big Daddy Kane, Sticky Fingaz, Marilyn McCoo, Billy Davis, Jr., Morris
19 Day, Jesse Powell, Enchantment, and Keith Barrow, among others. In addition to his
20 vast musical pursuits, Mr. Stokes has also taken on active political and social roles,
21 including having been intimately involved in Nancy Reagan’s “Just Say No” anti-drug
22 campaign (having co-written the song “Stop the Madness”);
23 8. Works representing the original creation of Mr. Stokes have been released
24 on labels including but not limited to MCA Records, Columbia, A&M Records, Giant
25 Records, Paisley Park, Warner Bros. Records, Sussex, United Artists Records, Arista,
26 Motown, Atlantic, Capitol Records, Reprise Records, and Universal Records, and have
27 been widely distributed by numerous physical and digital distributors since the early
28 1970s;
3

1 9. Mr. Stokes’ original musical works have enjoyed massive success and
2 notoriety, and have been extensively sampled and otherwise licensed for use by several
3 popular artists. By way of example, artists whose works sample or otherwise use Mr.
4 Stokes’ creations include but are not limited to Rick Ross, Jay-Z, Ne-Yo, LL Cool J,
5 Kendrick Lamar, Wiz Khalifa, French Montana, The Game, G-Unit, and Lil’ Wayne;
6 10. In or about 2010, Mr. Stokes suffered a stroke that incapacitated him and
7 rendered him unable to manage or supervise the musical empire he had created over
8 the course of several decades. Specifically, his medical condition left him unable to
9 engage in the business of creating or monetizing music, and likewise unable to monitor
10 the various uses to which his musical works were being put. During the period of Mr.
Stokes’ incapacity as such, on information and belief, Mr. Stokes’ name was forged on
11
12 several chain of title documents, his copyrights and related interests thereby being
13 effectively stolen from him, creating the false impression that Mr. Stokes’ copyrights
14 and attendant rights in his music catalogs had been transferred to the former Music
15 Publishing Company of America (hereafter “MPCA”);
16 11. On information and belief, MPCA thereafter sold, conveyed, or otherwise
17 transferred to Defendants Bicycle certain of their unlawfully-held rights in Mr. Stokes’
18 music catalogs, as identified at least in part by copyright registrations in the works set
19 forth in Exhibit A hereto. For some time thereafter, on information and belief,
20 Defendants Bicycle earned substantial income on copyright and attendant rights
21 Defendants Bicycle unlawfully held in those works. On further information and belief,
22 Defendants Bicycle were absorbed in some fashion by Defendants Kobalt and
23 Defendants Concord, which therefore also wrongfully earned substantial income on
24 copyright and attendants rights they unlawfully held in those works;
25 12. Defendants Universal, Defendants Warner, and Defendants Sony are
26 believed and alleged to have occupied, at all times herein relevant, distribution and/or
27 publishing relationships with certain of their co-Defendants, to wit, on information and
28 belief, Defendants Bicycle, Defendants Kobalt, and Defendants Concord. In the
4

1 course of those relationships, on information and belief, Defendants Universal,

2 Defendants Warner, and Defendants Sony wrongfully accepted income arising from
3 Mr. Stokes’ copyright and attendant interests, and made payments to Defendants
4 Bicycle, Defendants Kobalt, and Defendants Concord on income arising from Mr.
5 Stokes’ copyright and attendant interests. On further information and belief, all
6 Defendants have been placed on specific notice that Mr. Stokes’ copyright and
7 attendant interests were stolen and/or otherwise unlawfully exploited, and that Mr.
8 Stokes was and has always been the rightful owner of all income interests unlawfully
9 assumed by said Defendants. Despite that knowledge, and despite Mr. Stokes’
10 demands that Defendants cease accepting income arising from his copyright and
attendant interests, and that they cease making payments to their co-Defendants or to
11
12 anyone, Defendants have continued to accept income arising from Mr. Stokes’
13 interests, and have continued to make unlawful payments to their co-Defendants, and
14 not to Mr. Stokes;
15 13. As to Defendants Universal specifically, said Defendants not only
16 unlawfully made payments to their co-Defendants on Mr. Stokes’ copyright and
17 attendant interests, and not to Mr. Stokes, but Defendants Universal also actively
18 concealed from Mr. Stokes their actual knowledge that their co-Defendants were not
19 entitled to said payments, and that Mr. Stokes was the rightful owner of the subject
20 copyright interests and of all income interests arising therefrom. Only by reason of
21 accidental discovery, and to the chagrin of Defendants Universal, did Mr. Stokes learn
22 that Defendants Universal had been concealing from Mr. Stokes the known unlawful
23 nature of their payments to their co-Defendants;
24 14. On information and belief, all Defendants have in some manner
25 knowingly and willfully infringed upon Mr. Stokes’ copyright interests in his musical
26 works by misappropriating, unlawfully licensing, copying, selling, and otherwise
27 exploiting said works for their financial gain, all to Mr. Stokes’ damage;
28 15. As a result of the foregoing, Mr. Stokes has been severely damaged in his
5

1 pecuniary and other interests, and seeks, inter alia, an accounting of all sums accepted
2 and paid with any regard to his rightful copyright interests in his music catalog;
3 16. On information and belief, certain of the Defendants have conceded and
4 admitted their wrongdoing, but have still failed to compensate Mr. Stokes;
5 FIRST CAUSE OF ACTION
6 COPYRIGHT INFRINGEMENT
7 (As Against All Defendants)
8 17. Mr. Stokes incorporates paragraphs 1 through 16 above as though fully set
9 forth herein in form and substance;
10 18. The songs at issue herein have been duly registered with the U.S.
Copyright Office. Each such song is a work of original creative expression and
11
12 constitutes all or in part the property of Mr. Stokes, and not rightfully the property of
13 the Defendants. All legal copies, or derivatives thereof, are produced either directly by
14 Mr. Stokes or, in the alternative, are under his authority or license. All such works
15 have been published in conformity with the provisions of the Copyright Act, 17 U.S.C.
16 § 101, et seq.;
17 19. Defendants had at all times herein relevant ready and easy access to Mr.
18 Stokes’ works as alleged herein;
19 20. Defendants have infringed upon Mr. Stokes’ copyright interests in works
20 of original expression as alleged herein by, inter alia, knowingly and willfully
21 misappropriating, unlawfully licensing, copying, selling, and otherwise exploiting said
22 works for their financial gain;
23 21. Defendants’ conduct infringes Mr. Stokes’ rights in direct violation of the
24 Copyright Act, 17 U.S.C. § 101, et seq.;
25 22. As a direct and proximate result of Defendants’ wrongful acts alleged
26 above, Mr. Stokes has been damaged, and Defendants have been unjustly enriched, in
27 amounts to be determined at trial. Alternatively, Mr. Stokes may elect to seek
28 statutory damages of $150,000 per willful infringement pursuant to 17 U.S.C. §
6

1 504(c);
2 23. As a direct and proximate result of Defendants’ wrongful acts alleged
3 above, Mr. Stokes has suffered, and continues to suffer, irreparable harm and injury for
4 which there is no adequate remedy at law. Mr. Stokes is informed and believes, and
5 thereon alleges, that Defendants’ copyright infringement will continue unless enjoined
6 by this Court;
7 SECOND CAUSE OF ACTION
8 CONVERSION
10 24. Mr. Stokes incorporates paragraphs 1 through 23 as though fully set forth
herein in form and substance;
11
12 25. Mr. Stokes had, at all times herein relevant, a right to possess those funds
13 and property in sums known to Defendants, who as of the filing hereof wrongfully
14 have and maintain such possession, and who wrongfully refuse to account to Mr.
15 Stokes as to the amounts unlawfully held and maintained;
16 26. Defendants, by reason of their wrongful conduct as alleged herein, have
17 intentionally and substantially interfered with Mr. Stokes’ right to possession by: (a)
18 taking funds and property from Mr. Stokes; (b) preventing Mr. Stokes from gaining
19 access to the funds and property, and (c) refusing to return said funds and property to
20 Mr. Stokes despite Mr. Stokes’ demand for the same;
21 27. At no time did Mr. Stokes consent to Defendants’ taking or their refusal to
22 return or grant Plaintiff access to the funds and property herein described, nor would
23 Plaintiff have ever so consented;
24 28. As a direct and proximate result of the conduct of Defendants as herein
25 alleged, all of which was a substantial factor in damaging Mr. Stokes, Mr. Stokes was
26 in fact damaged severely in sums according to proof at the time of trial;
27 29. The conduct of Defendants was knowing, willful, and purposefully
28 designed to damage and injure Mr. Stokes in his personal and business interests, and in
7

1 undertaking said conduct Defendants acted in depraved and malicious manners in

2 complete disregard for the rights of Mr. Stokes, and in purposeful derogation of Mr.
3 Stokes’ financial and other interests. By reason of said conduct, Mr. Stokes is entitled
4 to an award of exemplary damages in amounts sufficient to punish and make an
5 example of Defendants and each of them;
6 THIRD CAUSE OF ACTION
7 INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC
8 ADVANTAGE
herein in form and substance;
11
12 31. At times herein relevant, Mr. Stokes possessed certain copyright,

13 publishing, and other business interests flowing from his rightful ownership of, inter
14 alia, his music catalog. Mr. Stokes also possessed certain business contacts, business
15 relations, and goodwill that respectively and collectively formed and developed
16 economic relationships between himself and others that were likely to result in
17 substantial economic benefit to Mr. Stokes in relation to the management, publishing,
18 licensing, and other exploitation of his catalog of original musical works;
19 32. Defendants and each of them knew of Mr. Stokes’ economic
20 relationships, knew of his copyright and attendant income rights flowing therefrom,
21 and knew that said relationship and rights were likely to result in substantial future
22 economic benefit to Mr. Stokes;
23 33. By reason of engaging in the intentional conduct herein alleged, and
24 additionally in, inter alia, (a) infringing upon Mr. Stokes’ copyright and attendant
25 interests, (b) undermining Mr. Stokes’ efforts to preserve the economic business
26 relationships and goodwill he spent decades forming and developing, and (c)
27 concealing from Plaintiff facts directly relevant to his copyright interests and to the
28 unlawful use and exploitation of those interests, Defendants and each of them intended
8

1 to disrupt Mr. Stokes’ economic relationships and his right and entitlement to earn an
2 income flowing from his rightful copyright interests in the songs at issue in this
3 litigation, including without limitation his right to form contracts for the use and
4 exploitation of the songs. In fact, Defendants knew that their conduct was virtually
5 certain to disrupt said relationships, and that said disruption was certain to cause
6 Plaintiff severe and permanent damage in his personal and other interests;
7 34. As a direct and proximate result of the conduct of Defendants as herein
8 alleged, all of which was a substantial factor in damaging Mr. Stokes, Mr. Stokes was
9 in fact damaged severely in sums according to proof at the time of trial;
10 35. The conduct of Defendants was knowing, willful, and purposefully
designed to damage and injure Mr. Stokes in his personal and business interests, and in
11
12 undertaking said conduct Defendants acted in depraved and malicious manners in

13 complete disregard for the rights of Mr. Stokes, and in purposeful derogation of Mr.
14 Stokes’ financial and other interests. By reason of said conduct, Mr. Stokes is entitled
15 to an award of exemplary damages in amounts sufficient to punish and make an
16 example of Defendants and each of them;
17 FOURTH CAUSE OF ACTION
18 UNFAIR BUSINESS PRACTICES (Cal. Bus. & Prof. Code § 17200, et seq.)
21 herein in form and substance;
22 37. Defendants’ acts as alleged herein together and separately constitute
23 unlawful, unfair, and/or fraudulent business practices within the meaning of section
24 17200 of the California Business & Professions Code, in that said acts violate
25 applicable law and public policy;
26 38. On information and belief, Defendants maintain an ongoing business
27 practice of implementing the conduct herein alleged, for commercial gain and without
28 the consent of those they are intending to damage and are in fact damaging, including
9

1 without limitation wrongfully misappropriating copyright and other interests from

2 valid copyright holders, believing the copyright holders will not have the financial
3 means and wherewithal to undertake a legal battle to recover the same;
4 39. As a direct and proximate result of Defendants’ conduct, Mr. Stokes was
5 damaged in his personal and business financial and other interests, and is entitled to,
6 among other things, a declaration that Defendants’ conduct is unlawful and egregious,
7 and is entitled to preliminary and permanent injunctive relief. Mr. Stokes is likewise
8 entitled to disgorgement of Defendants’ profits received as ill-gotten gains;
9 FIFTH CAUSE OF ACTION
10 UNJUST ENRICHMENT
(As Against All Defendants)
11
12 40. Mr. Stokes incorporates paragraph 1 through 39 as though fully set forth
14 41. Defendants were unjustly enriched by misappropriating Mr. Stokes’ work,
15 licensing the same for their own commercial gain, and, on information and belief,
16 unlawfully exploiting Mr. Stokes’ copyright and attendant interests;
17 42. Because it would be unjust for Defendants to retain any money derived
18 from the misappropriation of Mr. Stokes’ original works, Mr. Stokes is entitled to
19 disgorgement of all profits earned by Defendants and each of them by virtue of their
20 wrongful use and exploitation of said works;
21 SIXTH CAUSE OF ACTION
22 FINANCIAL ELDER ABUSE (Cal. Welfare & Institutions Code §15610.30)
26 44. Mr. Stokes was at times herein relevant a person over 65 years of age
27 living in California, and therefore qualifies as an “elder” pursuant to California
28 Welfare & Institutions Code section 15610.27;
10

1 45. At times relevant, by reason of the conduct alleged herein, Defendants

2 and each of them wrongfully obtained, maintained, exploited, and profited from the
3 copyrights and attendant rights and funds belonging to Mr. Stokes, all in violation of
4 California’s Elder Abuse and Dependent Adult Civil Protection Act;
5 45. Specifically, Defendants and each of them were aware at all times herein
6 relevant that Mr. Stokes was an elder within the meaning of the law. Defendants were
7 also aware and were on notice that the copyrights and attendant rights Defendants
8 exploited, and the funds Defendants were receiving as a result of said exploitation,
9 belonged to Mr. Stokes and not to Defendants. Despite said awareness and notice,
10 Defendants and each of them have continued to exploit Mr. Stokes’s legal interests,
and have continued to collect and retain sums due to Mr. Stokes, and have continued to
11
12 wrongfully direct to parties other than Mr. Stokes funds Defendants are aware belong
13 not to said parties but to Mr. Stokes;
14 46. By reason of the facts alleged herein, Defendants and each of them
15 secreted, appropriated, obtained, and/or retained property for a wrongful use aimed at
16 depriving Mr. Stokes of said property, all in violation of the law;
17 48. Defendants and each of them knew their conduct alleged herein was
18 wrongful and stood to substantially damage Mr. Stokes in his pecuniary and other
19 rights, while simultaneously earning Defendants substantial profits;
20 49. As a direct and proximate result of the conduct of Defendants and each of
21 them in violation of California Welfare & Institutions Code sections15610.30, et seq.,
22 Mr. Stokes has sustained severe financial and other damages in amounts according to
23 proof, including at least compensatory damages and attorney fees;
24 50. Defendants’ conduct as herein alleged was so depraved and malicious,
25 and so driven by Defendants’ desire to profit and to benefit themselves to the exclusion
26 of Plaintiff, and was so directed at damaging Plaintiff in his legal and other rights, as to
27 justify an award of an award of treble damages and/or an award of punitive damages
28 against Defendants and each of them in amounts sufficient to punish and make an
11

1 example of Defendants;
2 SEVENTH CAUSE OF ACTION
3 ACCOUNTING
7 52. At times herein relevant, Defendants and each of them have owed and still
8 owe Mr. Stokes certain income, including without limitation royalties and other funds,
9 based on Mr. Stokes’ ownership and other rights in the songs at issue herein.
10 Defendants and each of them maintain exclusive control of the sums collected, paid,
and owed to Plaintiff, and have denied Mr. Stokes access to an accounting of such
11
12 funds. As such, the balance due Mr. Stokes can only be ascertained by an accounting;
13 EIGHTH CAUSE OF ACTION
14 DECLARATORY RELIEF
18 54. An actual and immediate controversy has arisen and now exists as
19 between Mr. Stokes and the Defendants regarding the ownership of and entitlement to
20 certain benefits derived from the copyright and other interests at issue as alleged
21 herein;
22 55. Mr. Stokes seeks judicial declarations of his rights in and to the songs at
23 issues herein, including without limitation ownership and income rights flowing from
24 the copyrights in the subject musical works;
25 56. The judicial declarations sought hereby are necessary and appropriate in
26 order that the parties may ascertain their legal rights and obligations to one another,
27 and also in order that they may avoid the hardships to be inflicted upon them by a
28 protracted legal dispute;
12

1 PRAYER FOR RELIEF

2 WHEREFORE, Mr. Stokes prays for Judgment against all Defendants as
3 follows:
4
5 1. For a judicial determination and Declaration to the effect that the

6 Defendants have willfully infringed the copyrighted works alleged herein, in violation
7 of the Copyright Act;
8 2. For a judicial determination and Declaration to the effect that the
9 Defendants are directly, vicariously, and or contributorily liable for copyright
10 infringement as alleged herein, as may be applicable;
3. For permanent injunctions prohibiting the Defendants and their agents,
11
12 employees, servants, officers, attorneys, successors in interest, licensees, partners,

13 assigns, and all persons acting in concert with the foregoing, or at their direction or
14 behest, and each and all of them, from directly and/or indirectly causing, enabling,
15 facilitating, permitting, encouraging, promoting, inducing, and/or participating in the
16 infringement of any right enjoyed and/or owned by Mr. Stokes and protected by the
17 Copyright Act;
18 4. For permanent injunctions prohibiting the Defendants and their agents,
21 behest, and each and all of them, from directly and/or indirectly collecting any funds
22 deriving from or arising in any manner related to any right enjoyed and/or owned by
23 Mr. Stokes and protected by the Copyright Act;
24 5. For permanent injunctions prohibiting the Defendants and their agents,
27 behest, and each and all of them, from diverting to any party other than Mr. Stokes any
28 funds deriving from or arising in any manner related to any right enjoyed and/or
13

1 owned by Mr. Stokes and protected by the Copyright Act;

2 6. An award of damages against Defendants pursuant to 17 United States
3 Code section 504(b), including actual damages and disgorgement of profits reaped by
4 the aforementioned Defendants, or alternatively for an award of $150,000 per
5 infringement pursuant to 17 United States Code section 504(c);
6 7. On each Cause of Action, compensatory and special damages according
7 to proof offered and made at the time of trial;
8 8. On each Cause of Action upon which punitive damages are legally
9 allowable, an award of punitive damages sufficient to punish and make an example of
10 the Defendants;
9. On each Cause of Action upon which treble damages are legally
11
12 allowable, an award of treble damages;

13 10. An award of attorney fees and costs pursuant to 17 United States Code
14 section 505 and all other applicable law;
15 11. An award of attorney fees and costs pursuant to California Welfare &
16 Institutions Code section 15657.5;
17 12. For pre-judgment and post-judgment interest on all damages awarded;
18 13. For costs of suit as may be legally allowable;
19 14. For such other and further relief as this Court may deem to be just and
20 proper.
21
22 LAW OFFICES OF PAUL N. PHILIPS, APLC

23
24
Dated: January 14, 2020 By: /s/ Paul N. Philips
PAUL N. PHILIPS, ESQ.
25 Attorneys for Plaintiff
26 MICHAEL STOKES
27 ////
28 ////
14

1 JURY DEMAND
2 Mr. Stokes hereby demands trial of the within action by jury.
3
5 LAW OFFICES OF PAUL N. PHILIPS, APLC

6
7
Dated: January 14, 2020 By: /s/ Paul N. Philips
PAUL N. PHILIPS, ESQ.
8 Attorneys for Plaintiff
9 MICHAEL STOKES
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Case 2:20-cv-00370 Document 1-1 Filed 01/14/20 Page 1 of 12 Page ID #:16
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EXHIBIT A
28
16

AO 121 (Rev. 06/16)
TO:
Register of Copyrights REPORT ON THE

U.S. Copyright Office FILING OR DETERMINATION OF AN
101 Independence Ave. S.E. ACTION OR APPEAL
Washington, D.C. 20559-6000 REGARDING A COPYRIGHT
In compliance with the provisions of 17 U.S.C. 508, you are hereby advised that a court action or appeal has been filed
on the following copyright(s):
COURT NAME AND LOCATION
G
✔ ACTION G APPEAL
United States District Cout - Central District of California
DOCKET NO. DATE FILED
312 North Spring Street
1/14/2020 Los Angeles, California 90012
PLAINTIFF DEFENDANT
UNIVERSAL MUSIC GROUP, INC.;
MICHAEL STOKES
(ADDITIONAL DEFENDANTS IDENTIFIED ON
ATTACHMENT "1" )
COPYRIGHT
TITLE OF WORK AUTHOR OR WORK
REGISTRATION NO.
1 PA0000008596 Angel In My Life Michael Stokes / Verdell Lanier
2 PA0000025528 Any Way You Want It Micahel Stokes / Emanuel Johnson
3 PA0000087416 Are You Ready For Love Michael Stokes / Emanuel Johnson
4 PA0000061697 Backstreet Michael Stokes / Ronn Matlock
5 ------------------------------- Continued On "Attachment 2" --------------------------------------------------
In the above-entitled case, the following copyright(s) have been included:

DATE INCLUDED INCLUDED BY
G Amendment G Answer G Cross Bill G Other Pleading
COPYRIGHT
TITLE OF WORK AUTHOR OF WORK
REGISTRATION NO.
3 .
In the above-entitled case, a final decision was rendered on the date entered below. A copy of the order or judgment
together with the written opinion, if any, of the court is attached.
COPY ATTACHED WRITTEN OPINION ATTACHED DATE RENDERED
G Order G Judgment G Yes G No
CLERK (BY) DEPUTY CLERK DATE
1) Upon initiation of action, 2) Upon filing of document adding copyright(s), 3) Upon termination of action,
mail copy to Register of Copyrights mail copy to Register of Copyrights mail copy to Register of Copyrights
DISTRIBUTION:
4) In the event of an appeal, forward copy to Appellate Court 5) Case File Copy

CENTRAL DISTRICT OF CALIFORNIA
MICHAEL STOKES v. UNIVERSAL MUSIC GROUP, et al.
ATTACHMENT #1 TO REPORT RE: COPYRIGHTS

Additional Defendants
UNIVERSAL MUSIC DISTRIBUTION; UMG RECORDINGS, INC.;

CONCORD MUSIC GROUP, INC.; CONCORD MUSIC PUBLISHING; CRAFT
RECORDINGS; THE BICYCLE MUSIC COMPANY, INC.; BIKE MUSIC;
KOBALT MUSIC PUBLISHING AMERICA, INC.; KOBALT MUSIC GROUP;
KOBALT MUSIC SERVICES AMERICA, INC.; WARNER MUSIC GROUP;
WARNER/CHAPPELL MUSIC, INC.; SONY MUSIC ENTERTAINMENT;
SONY/ATV MUSIC PUBLISHING GROUP

CENTRAL DISTRICT OF CALIFORNIA
MICHAEL STOKES v. UNIVERSAL MUSIC GROUP, et al.
ATTACHMENT #2 TO REPORT RE: COPYRIGHTS

Additional Works
Copyright Registration Title of Work Author of Work

Number
5. Copyright number for Come Be My Lover Michael Stokes
individual title not
located.
(Located only
SR0000064149.)
6. Copyright number for Come On And Ride Michael Stokes
located.
(Located by only
V3477D503,
V3477D502,
V3538D500,
V3538D502,
V3511D402.)
7. Copyright number for Dance To The Music Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D500,
V3538D502,
V3511D402.)
8. Copyright number for Dance With The Devil Michael Stokes
located.
(Located only
V3538D502,
V3538D500,
V3511D402.)
9. Copyright number for Don’t Fight The Feeling Michael Stokes
located.
(Located only
SR0000064149.)
10. Copyright number for Don’t Save Me Now Michael Stokes
located.
(Located only
V3511D402,
V3477D502,
V3538D500.)
11. Copyright number for Everything But Fail Michael Stokes
located.
(Located only
V3538D50,
V3538D502,
V3511D402.)
12. Copyright number for Expose Yourself Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D500,
V3538D502,
V3511D402.)
13. PA0000061696 Feeling Something Michael Stokes, Ronn
Matlock, et al.
14. Copyright number for Feel So Good Do It Michael Stokes
individual title not Again
located.
(Located only
V3477D502,
V3538D500,
V3511D402.)
15. PA0000025534 Forever More Sky Tower Music, Ltd.,

Emanuel Johnson, et al.
16. PA0000036553 Free To Be Me Michael Stokes, Ronn
Matlock, et al.
17. PA0000025532 Fun Michael Stokes, Joe
Nathan Thomas, et al.
18. PA0000025526 Future Gonna Get You Michael Stokes, Joe
19. PA0000036552 Garden of Love Michael Stokes, Ronn
Matlock, et al.
20. Copyright number for Get It While It’s Hot Michael Stokes
located.
(Located only
SR0000064149.)
21. PA0000158671 Give It Up Michael Stokes,
Kimberly Ball, et al.
22. Copyright number for Gloria Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D500,
V3538D502,
V3511D402.)
23. Copyright number for Gotta Find A Love Michael Stokes
located.
(Located only
SR0000064149.)
24. PA0000017746 Heavenly Father Michael Stokes, Ronn
Matlock, et al.
25. Copyright number for Here’s Your Chance Michael Stokes, Emanuel
individual title not Johnson, et al.
located.
(Located only
SR0000051165.)
26. PA0000017743 He’s Got A Love That Michael Stokes, Ronn

Will Last Forever Matlock, et al.
27. Copyright number for Hold On Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D500,
V3538D502,
V3511D403.)
28. PA0000524230 I Believe In You Michael Stokes, Louis
Price, et al.
29. PA0000061695 I Can’t Forget About Michael Stokes, Ronn
You Matlock, et al.
30. PA0000064795 I Just Can’t Control Michael Stokes, Lynn
Myself Marie Smith, et al.
31. Unable to locate I Meta-For Michael Stokes
32.PA0000064796 I Never Felt This Way Michael Stokes, Lynn
Before Marie Smith, et al.
33. PA0000025531 I Wanna Boogie Michael Stokes, Joe
34. PA0000036548 If It’s Love That You’re Michael Stokes, Ronn
Looking For Matlock, et al.
35. PA0000008590 If You’re Ready (Here It Michael Stokes, Verdell
Comes) Lanier, et al.
36. PA0000823515 I’m Dreaming Emanual Johnson and
Enchantment
37. PA0000008591 It’s You That I Need Michael Stokes, Verdell
Lanier, et al.
38. Copyright number for Jesus Is Coming Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D500,
V3538D502,
V3511D403.)
39. PA0000025536 Journey Michael Stokes,

Enchantment, et al.
40. PA0000036551 Joyful Music Michael Stokes, Ronn
Matlock, et al.
41. Copyright number for Just A Talk Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D500,
V3538D502,
V3511D403.)
42. PA0000061693 Let Me Dance Michael Stokes, Ronn
Matlock, et al.
43. PA0000025533 Let Me Entertain You Michael Stokes, Joe
44. PA0000061694 Love City Michael Stokes, Ronn
Matlock, et al.
45. PA0000025529 Love Melodies Michael Stokes, Joe
46. Copyright number for Love Is You Michael Stokes
located.
(Located only
SR0000014169.)
47. Copyright number for Loving You Makes Me Michael Stokes
individual title not Happy
located.
(Located only
V3477D502,
V3538D501,
V3511D403.)
48. PA0000025527 Magnetic Feel Michael Stokes, Joe
49. PA0000017745 Message To The People Michael Stokes, Ronn
Matlock, et al.
50. Copyright number for Movin’ On Down The Michael Stokes

individual title not Line
located.
(Located only
V3477D503,
V3477D502,
V3538D501,
V3538D502,
V3511D403.)
51. PA0000008588 Music Michael Stokes, Emanuel
Johnson
52. Copyright number for My Rose Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D501,
V3538D502,
V3511D403.)
53. PA0000064794 Natures Divine Michael Stokes, Mark
Mitchell, et al.
54. Copyright number for Nobody But Jesus Michael Stokes
located.
(Located only
V3477D502,
V3538D501,
V3538D502,
V3511D403.)
55. PA0000025530 Oasis Of Love Michael Stokes, Joe
Thomas
56. PA0000036550 Physical Attraction Michael Stokes, Ronald
Matlock
57. PA0000017742 Salvation Michael Stokes, Ronald
Matlock
58. Copyright number for Sexy Lady Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D501,
V3538D502,
V3511D404.)
59. PA0000008595 Silly Love Song Michael Stokes, Emanuel
Johnson
60. Copyright number for Slow Down Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D501,
V3538D502,
V3511D404.)
61. Copyright number for Somebody’s Loving You Michael Stokes
located.
(Located only
SR0000064149.)
62. PA0000064799 Success Marvin Jones, Lynn
Smith
63. PA0000064797 Summer Nights Michael Stokes, Keith
Fondren
64. PA0000008589 Sunnyshine Feeling Michael Stokes, Verdell
Lanier
65. Copyright number for Sunshine Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D502,
V3538D501,
V3511D404.)
66. PA0001724974 Super High Michael Stokes, Emanuel
Johnson, et al.
67. PA0000011072 Super Lover Michael Stokes, Ronald

Matlock
68. PA0000061698 Take Me To The Top (Of Michael Stokes, Ronn
Your Mountain) Matlock
69. Copyright number for Thank You Girl For Michael Stokes
individual title not Loving Me
located.
(Located only
V3477D503,
V3477D502,
V3538D502,
V3538D501,
V3511D404.)
70. Copyright number for Thought Of Love Michael Stokes
located.
(Located only
V3477D503,
V3477D502,
V3538D501,
V3538D502,
V3511D404.)
71. PA0000008597 Trying To Get Over With Michael Stokes, Emanuel
You Johnson
72. PA0000036549 Turn Me Up Michael Stokes, Ronald
Matlock
73. PA0000008594 Up Higher Michael Stokes, Verdell
Lanier
74. Copyright number for We Be Rollin’ Michael Stokes
located.
(Located only
V3538D501,
V3538D502,
V3511D404.)
75. PA0000025535 Where Do We Go From Johnson
Here
76. PA0000061700 Working Man Michael Stokes, Ronald
Matlock
77. Copyright number for You And Me Michael Stokes

located.
(Located only
V3538D502.)
78. PA0000017744 You Changed Me Over Michael Stokes, Ronald
Matlock
79. Copyright number for You Know That I Love Michael Stokes
individual title not You Girl (With All My
located. Heart)
(Located only
V3538D501,
V3538D502,
V3511D404.)
80. PA0000011073 You Know You Wanna Michael Stokes, Ronald
Be Loved Matlock
81. PA0000008593 You Must Be An Angel Michael Stokes, Verdell
Lanier
82. PA0000008592 You’re The One Michael Stokes, Verdell
Lanier
83. PA0000061699 You Got The Best Of Me Michael Stokes, Ronn
Matlock et. al.

Stokes v. UMG

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Stokes v. UMG

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Case 2:20-cv-00370 Document 1 Filed 01/14/20 Page 1 of 15 Page ID #:1

8 Attorneys for Plaintiff MICHAEL STOKES

COMPLAINT FOR DAMAGES;

COMPLAINT FOR DAMAGES;

1 JURISDICTION AND VENUE

COMPLAINT FOR DAMAGES;

COMPLAINT FOR DAMAGES;

1 course of those relationships, on information and belief, Defendants Universal,

COMPLAINT FOR DAMAGES;

COMPLAINT FOR DAMAGES;

COMPLAINT FOR DAMAGES;

1 undertaking said conduct Defendants acted in depraved and malicious manners in

12 31. At times herein relevant, Mr. Stokes possessed certain copyright,

COMPLAINT FOR DAMAGES;

12 undertaking said conduct Defendants acted in depraved and malicious manners in

COMPLAINT FOR DAMAGES;

1 without limitation wrongfully misappropriating copyright and other interests from

COMPLAINT FOR DAMAGES;

1 45. At times relevant, by reason of the conduct alleged herein, Defendants

COMPLAINT FOR DAMAGES;

COMPLAINT FOR DAMAGES;

1 PRAYER FOR RELIEF

5 1. For a judicial determination and Declaration to the effect that the

12 employees, servants, officers, attorneys, successors in interest, licensees, partners,

COMPLAINT FOR DAMAGES;

1 owned by Mr. Stokes and protected by the Copyright Act;

12 allowable, an award of treble damages;

22 LAW OFFICES OF PAUL N. PHILIPS, APLC

COMPLAINT FOR DAMAGES;

5 LAW OFFICES OF PAUL N. PHILIPS, APLC

COMPLAINT FOR DAMAGES;

COMPLAINT FOR DAMAGES;

Register of Copyrights REPORT ON THE

1 PA0000008596 Angel In My Life Michael Stokes / Verdell Lanier

2 PA0000025528 Any Way You Want It Micahel Stokes / Emanuel Johnson

4 PA0000061697 Backstreet Michael Stokes / Ronn Matlock

5 ------------------------------- Continued On "Attachment 2" --------------------------------------------------

In the above-entitled case, the following copyright(s) have been included:

G Order G Judgment G Yes G No

CLERK (BY) DEPUTY CLERK DATE

UNITED STATES DISTRICT COURT

MICHAEL STOKES v. UNIVERSAL MUSIC GROUP, et al.

ATTACHMENT #1 TO REPORT RE: COPYRIGHTS

UNIVERSAL MUSIC DISTRIBUTION; UMG RECORDINGS, INC.;

UNITED STATES DISTRICT COURT

MICHAEL STOKES v. UNIVERSAL MUSIC GROUP, et al.

ATTACHMENT #2 TO REPORT RE: COPYRIGHTS

Copyright Registration Title of Work Author of Work

15. PA0000025534 Forever More Sky Tower Music, Ltd.,

26. PA0000017743 He’s Got A Love That Michael Stokes, Ronn

39. PA0000025536 Journey Michael Stokes,

50. Copyright number for Movin’ On Down The Michael Stokes

67. PA0000011072 Super Lover Michael Stokes, Ronald

77. Copyright number for You And Me Michael Stokes

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