Reply Brief Submitted by Appellants HTWF




UPDATE!

JOHN BRANCA RUSHED TO HAVE THIS DOC SEALED, THAT MEANS YOU DONT GET TO READ ABOUT THE BRIBERY OF HTWF ATTORNY BY THE ESTATE, YOU DONT GET TO READ HOW WEITZMAN WAS ACTIVELY INVOLVED IN SENDING 3 DOCS TO MELISSA ATTORNEYS. DOCS FOR SETTLEMENT TALKS, BUT THE LAST DOC WAS ALTERED ALLOWING THE ESTATE TO TAKE MELISSA ENTIRE COLLECTION OF INTELLECTUAL PROPERTY FOR FREE!!!


NO WORRIES WE CAN SUMMARIZE THE MAIN POINTS FOR YOU TO READ.


WE DO NOT HAVE TO REMOVE THIS DOC AS WE ACQUIRED IF FROM THE COURT WEBSITE WHEN IT WAS NOT SEALED, BUT IN THE PAST BRANCA HAS ATTEMPTED TO SANCTION MELISSA EVEN TRYING TO HAVE HER JAILED……….. JAILED BECAUSE WE WERE COLLECTING DONATIONS TO FUND HER CASE.  TRUST EVERYTHING THAT IS STATED IS BACKED UP BY HARD EVIDENCE, EMAILS DATE STAMPED, VOICE MAILS AND THE THREE MEMORANDUM OF SETTLEMENT NEGOTIATIONS.

post-on-feb-7th-2014
This is the latest happenings in the HTWF appeal.

Summary.

John Branca Vs Heal The World Foundation

 

The estate is coming after HTWF for trademark infringement in reference to Michael Jackson image and likeness they claim that HTWF exploited these marks without the permission of Triumph or The Estate which claim to be the rightful owners. HTWF states and proves that the said trademarks had been abandoned since 2001 when Michael was still alive and had been picked up by the organization during Michael’s life with no argument or challenge from him. The estate came in after Michael’s death on June 25th 2009 and after this date is when any such authorization for Michael’s image and likeness is needed. Trademarks and licenses pre-2009 are not under the governance of the estate as they would not be included in estate holdings assets or property if they were solely owned outright by another party. In this case, they were already licensed and owned by another entity which is Heal The World Foundation. The estate in its quest to own and confiscate everything Michael Jackson and under a false pretense of entitlement are wrongly pursuing Heal The World Foundation in an attempt raid the foundation of its trademarks assets.. Which are invaluable. Putting a monetary value on the licenses and trademarks bearing Michael image and likeness owned by HTWF are worth undoubtedly in the billions of dollars.

The estate wants HTWF’s motion for relief from judgment entered to be disposed…. as its not seen as new evidence in the eyes of the court and a decision denying the relief had already been granted. The relief clearly state that the judgment entered against HTWF and Melissa, giving the Estate…. HTWF and its trademarks were gained through fraudulent means. Edgar Pease was the former attorney for HTWF and during so called settlement talks between Melissa Johnson on behalf of HTWF and herself with Howard Weitzman John Branca and the estate… Edgar Pease began to over bill for attorney fees by increasing his hourly rate and the amount of hours worked, once he learned that part of the settlement with the estate would be that legal fees for HTWF  would be paid. The thought is that, this was a clever way for Pease to take his bribe from the estate and furnish documents to them that would otherwise be protected under the lawyer client confidentiality act. Furthermore this inflated bill is the guise to cover up bribery payments and was also monies to ensure that Melissa Johnson and HTWF would unknowingly sign over themselves and all their rights. This also took place in the 13th hour before both parties HTWF & The Estate trial in a district court courtroom where other eyes would have the opportunity to go over the matter.

 

Pease admitted to up billing and doing so under seal, he also admitted that Melissa nor the HTWF  was furnished with the enhanced bill, the bills were only furnished to the Estate and its attorneys. When Pease agreed to the MOU settlement agreement that was in favor of the estate.

 

On the first day of court, the district court held an in chambers meeting, where  Pease and the Estate advised the court that a settlement had been reached and there was no need to pursue litigation. Neither Melissa or Mr. Wilson was present. Pease told Melissa and Mr. Wilson they need not be there as this was a formality and that he would be asking the court to grant a 45 day suspension of the case so that all parties had time to have proper settlement negotiations. Instead he told the court that Melissa and her parties on behalf of themselves and HTWF had in fact agreed to the fraudulent settlement with the Estate.

 

 

With these new findings Pease was let go and new motions were issued to the courts in light of the new evidence. The motion was to get a stay on the settlement and judgment. The request was so that the district court could begin an evidentiary hearing due to the aforementioned findings of fraud coercion and legal neglect by strong arming Ms. Johnson and HTWF into signing a settlement that was non beneficial to them. The court instead upheld the settlement and judgment, ruling the judgment ruling was a request by the Estate to hold up the settlement agreement that was fraudulently entered. There was only a foot note of Melissa’s concerns and arguments added to the case. The court acknowledged that Pease the attorney of record for Ms. Johnson and HTWF at the time the settlement with the Estate was reached was in fact grossly negligent.

 

“Is typically chargeable to his or her client and do not ordinarily constitute extraordinary circumstances warranting relief from judgment under rule. One exception is an attorneys gross negligence.. Neglect so gross that its inexcusable.”

 

Melissa had provided evidence of such gross negligence. With emails that had date and time stamps, the emails were between Pease and Estate counsel. The Estates counsel sent over a revised MOU#2 settlements in favor of themselves at 10:20am on that day. Ten minutes later Pease forwarded that same version over to Melissa, yet it was not the revised version of the Estates, it was the version that Melissa earlier agreed to, with missing signature pages and omitting the fact that the newly revised MOU was binding whereas Melissa agreed to a NON BINDING MOU. Later that day Melissa on advice and request of Pease signed the agreement. She was told not to sign the version that she had in her possession, which was of an agreed upon benefit to all parties and NON BINDING which means that the terms can be revisited and changed at need by herself and the Estate.  The one forwarded to Pease from the Estate and then forwarded to Melissa by Pease.. Was the version that did not have any of the revisions benefiting the Estate and the BINDING agreement. MOU#1 was the original agreed upon document by Melissa that was NON BINDING, MOU#2 was the Estate forwarded Revised settlement document that Pease ONLY agreed to, which was in full benefit of the Estate and BINDING. The BINDING and the Estate benefits were removed from this document. MOU#3 was the complete version of the MOU settlement that included all the Estate revisions and benefits, the BINDING and signature pages, this was the one that was submitting to the courts by Pease and the Estate and that Melissa and HTWF had NO KNOWLEDGE OF.

 

Pease told Melissa that these signatures were urgently needed now to just sign as we need them when we go to court and Pease would ask the district court for the 45 day suspension of the settlement so that they could properly be looked over. As you can imagine a signature is not needed for such a thing, asking the court for a 45 day suspension so that you and your counsel can properly read the MOU settlement. Once viewed and agreed upon at that time you would then sign and advise the court of the settled upon agreement. Pease was a fast talking lawyer that had already changed sides and was looking out for his own best interests and the interest of the Estate.

 

The Estate says that HTWF has no stance as they are basing there need to have this settlement and judgment over turned on the wrong-doings of Pease and not themselves. Pease got in bed with the Estate, they two did their business and now the Estate is leaving Pease in bed alone, like a disheveled whore, with some chump change on the night stand. Isn’t this how its always done….

 

However, Melissa’s evidence showed that an email from the Estate to Mr. Pease on the 11th of May in 2011.. Apologizing for pages 5 and 6 of the signed settlement agreement of the MOU being inverted, the Estate says they inverted these pages because they had to be REMOVED from the original PDF to assure the signing of the switched MOU. These emails from the estate proved admitted collusion with Pease to deceive and defraud Melissa and HTWF. Pages 5 & 6 were signature pages on MOU#1 and MOU#2.

 

Phone records presented as evidence showed that Melissa only had 17 minutes to print sign scan and return the MOU#3 document with her signature. MOU#3 was the final revised version of the settlement which was BINDING and had all the benefits for the Estate. Pease told Melissa that this had to be done by 8pm he rushed and bullied her into the signing giving her no time to review the final settlement. It turns out that there was no deadline of 8pm or any other time.

 

The Estate DOES NOT! Dispute Melissa’s claims nor evidence against former HTWF attorney Edgar Pease for negligence and misconduct. The Estate DOES NOT! Oppose Melissa or HTWF’s evidence of Pease’s wrongdoing. What the Estate wants is for the judgment against Melissa and HTWF which makes them adhere to the settlement agreement on the grounds that Melissa’s evidence was submitted and the District Court entered judgment to enforce the settlement to still stand.

 

The Estate says that Melissa’s claims should be denied because she did not file a request for Evidentiary Hearing on the judgment that was entered against her. Melissa did in fact ask that there be a Evidentiary Hearing filed however before Pease was let go he opposed this and told Melissa and Mr. Wilson to file individual Status Reports and Evidentiary Hearing request “pro se” and that he would also file a request asking for an Evidentiary Hearing. As Melissa, Mr. Wilson & HTWF’s lead counsel… this made no sense and did in fact send up red flags, for Melissa and Mr. Wilson. However, when you are faced with a serious legal action placed against you by a very powerful entity such as the Estate.. a legal suit that involves billions of billions of dollars and Michael Jackson’s image and likeness. Believing in the judicial system, wanting to do the right thing, obtaining the charity and all its images and trademarks in a stand up and legal way.  Renewing them herself after many attempts at contacting Michael’s management when he was alive that they would expire. Melissa Johnson had nothing to hide or fear. She is well within her legal rights to run HTWF and own its trademarks and licenses. There is a certain innocence and naivety that befalls you when you have never had to deal with big business. You expect everything to go by how the law dictates and that you will have no problems provided that you follow them, which Melissa did.  Melissa thought that her lawyer Edgar Pease would be a stand up man and an efficient lawyer. Pease lied once more as he did not request and Evidentiary Hearing from the District court; he actually filed the MOU#3 settlement that he and the Estate agreed to and tricked Melissa Johnson on behalf of herself and HTWF into signing. Edgar Pease NEVER REBUTTED the claims laid against him.

 

—Katherine and Joe Jackson approves and knowingly acknowledges Melissa Johnson as one of the board members and facilitators of HTWF

 

—Prince Paris and Blanket Jackson appointed to the Youth board of the HTWF

 

—Randy Jackson is on the board of HTWF and along with his parents, niece and nephews in conjunction with Melissa Johnson made decisions regarding HTWF charity events, HTWF’s supported charities and initiatives.

 

 

—Raymone Bain, Michael’s general manager at the time that Melissa Johnson acquired the HTWF, has a declaration included into evidence which states that Michael told Bain that he knew Melissa Johnson & granted her request to take over the HTWF in 2005 and that she should handle all matters concerning the foundation completely. The HTWF that Melissa acquired was in fact the HTWF that Michael created in 1991

 

 

The Estate says that Melissa & HTWF “infringing” activities began to take place after Michael had died and interest in him was “revived”. The Estate in particular is upset with the HTWF and Melissa’s use of the trademark, MICHAEL JACKSON that they say belongs to them.

 

Comment: Michael Jackson had to be trademark as (dba) Do Business As… You need this trademark license in order to use the name MICHAEL JACKSON to make money. Do you get what’s happening here? The trademark for Michael’s name he had licensed under his foundation HTWF when Melissa inherited the foundation she also obtained all its assets and trademarks. HTWF is well within its legal rights to use these trademarks and licenses. These trademarks and licensed images were owned by HTWF and Melissa while Michael was still alive. Therefore…. They Are Not Included In The Estate’s Assets! Reason being why the Estate has Ms. Johnson & HTWF in court and along with Pease tricked her out of them with the MOU#3. Melissa & HTWF was allowed an injunction and this is why the process has not gone all the way through. With the injunction… Neither Melissa nor the Estate can use said trademarks until a decision is made as to the rightful owner. The Estate wants the judgment that came after their granted  settlement through the district to stand.

 

—After Michael’s death, the Estate executors, Michael’s business managers and lawyers all dropped the ball on picking up the expired trademarks and renewing them. They also failed to protect them from affiliated and non affiliated third parties. These third parties were filing trademark applications at a rapid pace all wanting to cash in on the death of Michael Jackson and use his name and variations of his name, along with key words that are linked to him. Melissa Johnson stepped in and while she was already authorized to pick and renew any of the trademarks owned and related to the HTWF she felt the need and urgency to protect the trademarks from the public/third parties and acquired them before they can be taken and abused.

 

—The Estate asserts that neither Melissa nor HTWF has the right to use Michael’s name likeness or image. (The estate also asserts that Michael’s own Mother Katherine or his kids Prince Paris & blanket has the right to use their Son and Father’s name likeness or image) Melissa Johnson & HTWF have conceded that the Estate never granted them the right to use Michael’s name likeness or image. However, the Estate cannot grant the right to use what is rightfully and legally owned by them. (No more than the Estate can tell a Mother not to use the name likeness or image of a child she gave birth to, Michael’s name image & likeness are hers.)

 

*And no I don’t want to hear about DBAs and trademarks in regards to Michael’s Mother, you all know better than that*

 

—The Jacksons’ attorney Brian Oxman when deposed in preparation for a trial in this matter testified that: He spoke with Michael at Neverland Ranch in 2004 about Melissa Johnson running the charity and foundation HTW that Michael Jackson authorized Melissa to use his likeness for commercial purposed to generate capitol for the foundation. At this meeting Michael also told Oxman that he loved Melissa’s presentation her plans for the foundation and that he really wanted her to do it. Brian Oxman also disclosed that Michael told him to tell Ms. Johnson that he had given her permission to run Heal The World Foundation and that the foundation now belonged to her. Michael in this meeting said that he was far too busy with his pending legal matters at the time and wanted Melissa Johnson to do everything that she could to preserve it, operate it, protect it and do all the thing necessary with respect to its trademarks and copyrights.

 

—Brian Oxman and Raymone Bain were Michael’s representatives during the years spanning 2004-2009, both declared that Jackson gave all rights and authority to Melissa and HTWF, need to run his foundation preserve its brands and (IP) Intellectual Property which would include the use of his name and image and the right of publicity was to be used by the foundation forever.

 

—Bain declared in her statement that Michael trusted Melissa Johnson but asked that she appoint a liaison from the Michael Jackson Company which was Alexander Verbolsky to communicate with Melissa to make sure that she continued to develop and operate the charity with the utmost integrity and in an efficient and effective manner. Bain went on to say that while Michael authorized Melissa to take control of Heal The World Foundation, he said that he done with an advisement and strong warning to Ms. Johnson that he did not want to repeat what happened in 2001 and that he was not going to be held responsible for any legal fees, financial obligations or stand for the organization….he originally founded…to be tarnished again in any regard.

 

Comment: The Estate now runs The Michael Jackson Company; it is in fact an asset of the Estate. However, Michael did not give any ownership or rights to The Michael Jackson Company he requested that one of it members be a liaison a consultant to, an advisor of sorts to Melissa and HTWF. Michael’s relinquishing all legal responsibility and fees, stating that he will not be responsible for any  financial obligations in regards to HTWF states and puts on record that Michael was no longer HTWF and that He gave it ALL over to Melissa Johnson. The Estate has NO Rights to HTWF or any of its assets likenesses and trademarks that it rightfully owns. What Michael did give authorization for is the use of his image and likeness to promote publicly so that monies are generated for the foundation in order to continually carry out its charitable pursuits. This was granted to Melissa and HTWF forever. This attestation by Michael Jackson supersedes any rights the Estate falsely say they have.

 

—In spite of its Denial, the Estate cannot deny that the record is clear that Melissa was given the right of Publicity by Michael in 2005 prior to his death. The Estate acknowledges that Michael’s 1991 HTWF had that right of Publicity inherently.

 

—Brain Oxman testified that in 2004 Melissa notified him of the expiration of many Michael Jackson & HTWF related domain names, websites, trademarks and copyrights that Michael’s attorneys were allowing to expire without Michael’s knowledge. Melissa told Oxman that these Charity related assets needed to be protected from 3rd parties and that various items needed to be sold on behalf of the 1991 HTWF in order to protect and register the brands future use, all while simultaneously raising money for the foundation’s relief initiatives. Michael later got the opportunity to review Melissa’s proposal to take over the charity completely. Michael approved the sale of various items to build capitol to preserve the charity’s brand, including the authority to acquire any domain name and trademark that was needed to carry out Michael’s approved charity initiatives.

 

—The Estate is attempting to slander Melissa Johnson through a number of means. On in particular is the false citing from Michael’s former IP attorney Evan N. Spiegel’s declaration and this all… predating the 2003 (DTA) Domain Transfer Agreement. The Estate’s premeditation to slander discredit and falsely accuse Ms. Johnson of copy right infringement and misrepresentation… purposely omitted during their citation of Evan Spiegel’s declaration that Mr. Spiegel Michael’s the IP attorney failed to renew the domains federal registration each of the four years he was hired and contracted to do so.

 

—The Estate misstates a letter to Mr. Spiegel by Ms. Johnson in 2002 which in fact was before the 2003 DTA. In this letter Melissa asks that Michael buys the domain registrations which were due to expire not from her as the Estate so blatantly lied about. Melissa did not own any of the registrations before 2003; she was bring awareness to Michael’s attorney and management that they were expiring and available to third parties legally and needed to be protecting for obvious reasons.

 

—The Estate also fails to mention the 2003 DTA says that Michael Jackson and the MJJ Productions entered into an agreement with Melissa Johnson to protect the efforts of Ms. Johnson in securing the domain names and that the agreement provided for payment to reimburse her for the renewal payments of the domain names. This was all necessary because Mr. Spiegel failed to due the job he was contracted and hired to do by allowing a collection of domain names to expire in 2003.

 

—More slander by the Estate, as they falsely claim that Melissa sold the 2003 domain collection to Michael, when she in fact donated the saved and recovered domains to Michael and HWTF. For such good deeds and the insight that these domains in the wrong hands and public to third parties could cause irrecoverable damage, the 2003 DTA included a clause to reimburse her for monies paid to save the domain collection.

 

 

—The Estate is trying to say that the 2003 DTA between Michael MJJ Productions and Melissa has no bearing on what they say is unauthorized use of trademarks and publicity rights more than six years later. However, the Estate does not dispute that one of the provisions in the DTA specifically state that Michael provided he would not allow the domain names to expire for three years, and that if they did expire… Melissa would have first right of refusal any party or third parties and that she would be granted the option to register the names for her.

 

—The Estate strangely claims that Ms. Johnson’s repeated offer to give the trademarks at issue to the Estate provided that they are co-administered and owned by the Jackson Family is irrelevant. (Head Scratcher) As the Estate wants them all to for themselves while excluding the Jackson Family. The Estate false depiction of Melissa Johnson and her intentions are quite contradictory due to the fact that she repeatedly tried to give the trademarks and domain names to the Estate. No such deal could be reached because the Estate would not allow nor include the Jackson Family involvement which was required by Melissa Johnson. The Estate has once again shown their true intentions.

 

—The Estate has been ignoring the primary issue which is on appeal, which are the undisputed allegations of misrepresentation by Edgar Pease as Ms Johnson Mr. Wilson and HTWF’s counsel, the terms of certain provisions and the intentionally concealed final nature of the Settlement Agreement MOU#3

 

—There is no dispute that Melissa and the appellants have previously transferred domain names at no cost and were willing to do so, but not under the terms and time frame represented to them by their counsel.

—Melissa was ready and willing to have this matter resolved with the Estate so long as they adhered to her provisions. Again Melissa is well within her rights as HTWF its trademarks domain registrations and assets legally belong to her. She also has the approval and consent of Michael which was the previous owner of the aforementioned and transferred it all over to Melissa Johnson while still alive, which makes HTWF its licenses trademarks images and likeness not apart of the Estates assets. Simply because Michael did not own them nor bear any legal or financial responsibility to them before his death. So the Estates misrepresentation of power in this matter was not needed nor the offer of giving Melissa a seat on the board which they have no autonomy over and a board for which she already has a seat on… as a lure to sign their settlement agreement. The Estates double talk was to give a false sense of power.

 

—The district court agrees that the Estate cannot offer Ms. Johnson a seat on her owns a board a board which the Estate did not have control over.

 

—After HTWF and her assets were fraudulently gained through settlement agreement MOU#3. All board members were forced out accepts for Melissa and Mrs. Katherine Jackson and the charity ordered dissolved by the Estate after raiding and confiscating its assets…

 

—Dissolving the Charity, without any board or shareholders meeting to authorize such an action is illegal under California Law. The law requires directors of charitable corporations to give notice or obtain consent from the attorney general before taking certain actions, including sale or disposal of all or substantially all corporate assets. Neither Melissa nor Mrs. Jackson agreed to dissolving the HTWF or the transference or selling of its assets. The dissolving of the charity should be null and void.

 

—The district court agreed that none of this was sufficient or appropriate to get Melissa to sign the Settlement Agreement and this…even if all the terms and conditions were then known.

 

—Even with these facts being acknowledged by the district court, the court however did not begin an Evidentiary Hearing. The district court did not make any changes in its October 2011 order where a judgment was entered to ensure that the Estates fraudulently obtained MOU#3 stands but instead added a footnote of Melissa’s evidence and agreed upon claims.

 

—The Estate does not dispute that Melissa did not sign the MOU in full awareness or that with such knowledge and evidence provided by Melissa Johnson Mr. Wilson and HTWF…the district court made orders directing her personally to perform certain tasks over her and the foundation’s objections. The only change in the July 27 order was the addition of a footnote, over their objection, which such orders were only in her capacity as an officer.

 

—The Estate claims intellectual property rights to anything connected with Michael long before it applied for those rights after his death. The Estate came up with these so called rights even after it admitted that Michael manager’s lawyers camp etc… Had allowed hundreds of trademarks to remain unprotected for years before Michael’s death. Not protecting a single trademark for Michael’s beneficiaries. The Estate applied for rights for Michael’s intellectual property on August 8th 2009.

 

—Third party non-Jackson related applicants began flooding USPTO & WIPO for Michael Jackson related brands the very day he died.

 

—Melissa Johnson and the HTWF are entitled to the exclusive rights to the Heal The World marks as given to them by Michael Jackson in 2003 initially by way of DTA and then permanently and forever in 2005 when he let go all responsibility and gave HTWF and its assets to Melissa Johnson.

 

—The Estate admits that HTWF registered and owns the marks Heal The World Foundation

 

— The Estate does not dispute that Melissa personally owns the marks Heal The World and Make That Change in the United States. She also owns the marks HTWF and MJ internationally. The Estate however feels that the use of Heal the World cannot and should not belong to Melissa or be available for trademark as its the title of a very successful song Michael written and released and the mark should be theirs being that they took all of Michael’s music. The song Heal The World was in fact written and released in correlation to Michael’s charity and the Estate again are wrong.

 

—The Estate is not the registrant of most of the trademarks in this matter. The only trademark they are in legal possession of is Michael Jackson in regards to sound recordings. They have in fact taken Michael’s music.

 

—The Estates alleges infringement by Melissa Johnson and HTWF for the following marks to name a few: King of Pop, Neverland Ranch, Neverland Valley Ranch, Thriller 25 The World’s Biggest Selling Album Of All Time, and M.J. Theses allegations are not based on anything factual or legally binding but solely because they applied for them after Michael’s death and even that application by the Estate was already late. As Melissa and HTWF had already done so which had long since been a fiduciary right of theirs…given to them by Michael himself years before his death in order to serve the charity and efforts and preserve it marks and protect against any non-Jackson Melissa Johnson and HTWF related third parties. Again this was set in place while Michael was alive and through Melissa’s first right refusal clause in the 2003 DTA with Michael and then later in 2005 when he relinquished his responsibility to HYWF giving it totally to Melissa.

 

—Heal The World, Make That Change, HTWF, MJ are all registered under Melissa Johnson’s name on behalf and for the use of HTWF and it charitable efforts. Many of which have now been acquired by the Estate through the fraudulent MOU#3

—Based on the Lanham Act applying for a trademark does not equate ownership nor does it give the applicant rights against infringement alleged or otherwise.

 

—The Estate has no claim here for the trademarks in question, since approval of their use has already been granted and the Estate has no exclusive rights to such marks.

 

—The Estate also has not produced any evidence that Melissa Johnson nor HTWF has misused the marks name likeness of Michael Jackson, which they have been approved to use forever by Michael Jackson himself, for the sake pf preserving approve charitable initiatives.

 

— The Estate falsely claims Melissa had no authority from Michael to operate the HTWF Corporation and that the Estate themselves somehow did have that authority over the board of the 1991 Charity and therefore, could deny permission to merge the Corporations five years after the merger had been concluded in accordance with state laws. Again the Estate has no governance over the HTWF and its assets as they had been turned over to Melissa Johnson by Michael himself while he was alive and therefore no longer in his possession and not apart of his estate in death. Michael no longer had any financial nor legal responsibility to HTWF as of 2005

 

—The Estate does not dispute that in 2008, Melissa registered HTWF with the California Secretary of State at the suggestion of The Michael Jackson Company liaison Alexander Vroblesky, Michael had requested that an officer of The Michael Jackson Company act as an advisor only and in no way was his company The Michael Jackson Company in partnership. Nor does the Estate deny that in July 2008, Vroblesky directed Melissa to contact Venable LLP, who represented Michael in business matters; in connection with his IP. Melissa worked with Michael’s counsel, Mark Harrison at Venable to defend and protect these trademarks.

 

—The Estate also conveniently leaves out that, that Melissa’s request to merge HTWF from 1991 with HTWF of 2008 (again while Michael was aware and alive) was made following her receiving a letter from the IRS, warning the 1991 HTWF Corporation would lose its 501(c)(3) status if it did not get current. The IRS recognized the 1991 corporation and Melissa as its place and person of contact.

 

—The Estates case is so weak that they have now claimed that the 1991 HTWF bylaws which are said to be written in 1993 state that in the event of Jackson’s death, his personal representatives, here presumably Mr. Branca and Mr. McClain, would control the corporation.

 

 

Comment: If in fact this was true and we seriously doubt it, Branca was fired around 1990 the first time and snaked his way back in the fold and not as Michael’s anything as Bert Fields was his attorney of record, Sandy Gallin his manager, this was all going down when Michael was being extorted. And once Branca cut everyone else out.. Fields’ gone Weitzman in, he in 1996 merged Michael’s ATV with Sony. Michael had fired Branca again his management and lawyers had changed several times. By 2006 when Michael was done with Branca once and for all. HTWF was already in the hands of Melissa Johnson in 2005, in 2003 when Branca and McClain we both fired….there was the DTA between Melissa Michael and MJJ productions. You must see the theme here, Branca has long since planning for the day MJ would die and had been secretly signing everything over to himself.

 

— The Estate executors as personal representatives would not and could not just control the corporation because Michael died, without being voted onto the board and even if that had happened, which it did not, they would merely hold a vote, having no control of the public charity. As cited by the Estate, the sole provision it cites allows that in the event of Michael’s death, his representatives, could take his place on the board. The bylaw also states that in the event of the resignation of a permanent member of the committee, that member may designate a person to fill the vacancy. Michael was the only director left on the board just before it was to be dissolved in 2004, as the record shows he had resigned in 2005, designating Melissa to take his place at his sole direction, leaving her as the only director of the charity at his death. The Estates sole again has no merit and had to add provisions to its MOU to give themselves seats on the board to which they had no entitlement. Its drafted MOU only granted its “representatives” control of the Board, by booting all existing directors from the Board, including Michael’s father Joe Jackson.

 

—Melissa provided indisputable evidence that the HTWF had a full board of directors and that the Estate had none of the seats.

 

—Branca nor McClain had any seats on the board of HTWF when Michael was alive nor did they have any seats on the board after he died.

 

—The Estate through fraudulently obtaining Melissa’s signature on MOU#3 a settlement agreement she was not aware of its contents nor agreed to allowed the Estate to undo the charities merger HTWF 1991 and HTWF 2008 the merger had already been legal and good standing when Michael was aware and alive. This was done on the advice of a Michael Jackson Company officer and with the guidance of Michael’s people at Venable LLP. However, the MOU was drafted in a way that the Estate would separate the charity and dissolve it without so much as the already in placed board being aware.

 

Comment: John Branca transferred and registered the marks in his name not as the Estate of Michael Jackson and not as Triumph International another dba of the Estate but as John Branca himself for himself. Technically any monies generated by them goes directly to John Branca not the Estate and least of all for the benefit of the beneficiaries Mrs. Jackson and Michael’s children.

 

—The district court all of the sudden ruled that no merger had taken place when The IRS and California State board recognizes that the 1991 HTWF and 2008 HTWF are one in the same.

 

Melissa Johnson, Mr. Wilson, HTWF and their new morally and ethically sound counsel request that the District Court vacate the October 27th amended judgment, reverse the district court’s dismissal of their counterclaims and the imposition and permanent injunctions.

 

 

Reply Brief Submitted by Appellants Heal the World Foundation.





Below is a summary of docs filed.

03/07/2012 15

5 pg, 50.23 KB Filed order MEDIATION (VLS): The Mediation Program of the Ninth Circuit Court of Appeals facilitates settlement while appeals are pending. See Fed. R. App. P. 33 and Ninth Cir. R. 33-1. The court has scheduled a telephone settlement assessment conference, with counsel only, on April 5, 2012, at 1:00 p.m. PACIFIC (San Francisco) Time to discuss whether this case is appropriate for participation in the Mediation Program. The Circuit Mediator will initiate the conference call by contacting each person on the attached list of participants at the telephone number listed. Please be available for the call at least five minutes before the scheduled time. Counsel should review the attached list and inform the Mediation Assistant by email (virna_sanchez@ca9.uscourts.gov) or telefax letter (415/355-8566) at least 72 hours in advance of the scheduled call of any of the following: (1) any attorneys on the list of counsel who will not be participating in the conference; (2) the direct dial phone number of any participant if it is not listed; and (3) any other corrections to the list. Please notify the Circuit Mediator immediately by email or telefax letter if the dispute is settled, the appeal is dismissed or if counsel has an unavoidable scheduling conflict. Please copy all counsel on any such communications. All discussions that take place in the context of the assessment conference are strictly confidential. For more detailed information about the assessment conference, confidentiality, the Mediation Program and its procedures generally, please see the attachment to this order and the Mediation Program web site: www.ca9.uscourts.gov/mediation. The briefing schedule previously set by the court is vacated. [8093947] [11-56926, 11-57048] (BJB)

04/05/2012 16

2 pg, 29.21 KB Filed order MEDIATION (CLR): The court has determined that these appeals will not be selected at this time for inclusion in the Mediation Program. The following briefing schedule shall control these appeals: appellants shall file the opening brief on or before June 1, 2012; appellees shall file the answering brief on or before July 30, 2012; appellants may file their optional reply brief within fourteen (14) days from the service date of the answering brief. Counsel are advised that the Clerk’s office may consider the granting of this briefing schedule to be appellants’ and appellees’ first extension of time, which may preclude the granting of oral requests for extensions of time on the opening and answering briefs. Cf., Ninth Circuit Rule 31-2.2. All further inquiries regarding these appeals, including requests for extensions of time, should be directed to the Clerk’s office. Counsel are requested to contact the Circuit Mediator should circumstances develop that might warrant further settlement discussions while the appeal is pending. [8129230] [11-56926, 11-57048] (BJB)

05/23/2012 17

7 pg, 403.82 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet in 11-56926 Motion to extend time to file Opening brief until 09/04/2012 at 11:59 pm. Date of service: 05/23/2012. [8188534] [11-56926, 11-57048] (JDE)

06/04/2012 18

10 pg, 246.4 KB Filed (ECF) Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926 response non-opposing motion (,motion to extend time to file brief). Date of service: 06/04/2012. [8201318] [11-56926, 11-57048] (NDB)

06/11/2012 19

2 pg, 25.23 KB Filed clerk order (Deputy Clerk: LKK): Appellants’ unopposed motion for a 90-day extension of time to file the opening brief is granted. The opening brief is due August 30, 2012. The answering brief is due October 31, 2012. The optional reply brief is due within 14 days after service of the answering brief. [8210120] [11-56926, 11-57048] (WL)

08/28/2012 20

7 pg, 260.29 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet in 11-56926 Motion to withdraw as counsel. Date of service: 08/28/2012. [8302653] [11-56926, 11-57048] (JDE)

08/29/2012 21

10 pg, 316.08 KB Filed (ECF) Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926 response opposing motion (,motion to withdraw as counsel). Date of service: 08/29/2012. [8303856] [11-56926, 11-57048] (NDB)

09/11/2012 22

2 pg, 31.38 KB Filed clerk order (Deputy Clerk: LKK): Appellants’ counsel motion to withdraw as counsel of record is granted. Court records shall be amended to reflect that Jeremy D. Eveland of Eveland & Associates is no longer counsel of record for appellants. Appellants’ are inform that a corporation cannot represent itself. See In Re Highley, 459, F.2d, 554 (9th Cir. 2004). Within 21 days after the date of this order, appellants shall enter an appearance of new counsel. Failure to enter an appearance of new counsel may result in the automatic dismissal of this appeal. 9th Cir. R. 42-1. The briefing schedule is reset. The opening brief is due November 9, 2012. The answering brief is due December 10, 2012. The optional reply brief is due within 14 days after service of the answering brief. [8318255] [11-56926, 11-57048] (BJB)

09/11/2012 23 Terminated Jeremy D. Eveland for United Fleet and Heal The World Foundation in 11-56926 [8318268] [11-56926, 11-57048] (BJB)

11/08/2012 24

2 pg, 587.71 KB Filed (ECF) notice of appearance of Gary S. Brown for Appellants Heal The World Foundation and United Fleet in 11-56926. Date of service: 11/08/2012. [8394717] [11-56926, 11-57048]–[COURT UPDATE: Edited notice of appearance form to reflect correct case number. Resent NDA. 11/08/2012 by RY]–[Edited: Added consolidated case 11-57048 to form. Resent NDA. 11/09/2012 by RY] (GSB)

11/09/2012 25 Added attorney Gary Stephen Brown for United Fleet Heal The World Foundation, in case 11-56926. [8396111] [11-56926, 11-57048] (JFF)

11/09/2012 67 Added attorney Gary Stephen Brown for United Fleet Heal The World Foundation, in case 11-57048. [8973292] (LA)

11/11/2012 26

3 pg, 44.54 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet in 11-56926 Motion to extend time to file Answering brief. Date of service: 11/11/2012. [8397451] [11-56926, 11-57048]–[COURT UPDATE: Edited docket text to reflect correct relief. Resent NDA. 11/13/2012 by RY] (GSB)

11/14/2012 27

31 pg, 680.15 KB Filed (ECF) Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926 response opposing motion (,motion to extend time to file brief). Date of service: 11/14/2012. [8401916] [11-56926, 11-57048] (NDB)

11/27/2012 28

2 pg, 25.73 KB Filed clerk order (Deputy Clerk: LKK): Appellant’s opposed motion for an extension of time to file the opening brief is granted in part. The opening brief is due January 7, 2013. The answering brief is due February 6, 2013. The optional reply brief is due within 14 days after service of the answering brief. Any further request for an extension of time to file the opening brief is disfavored. [8415119] [11-56926, 11-57048] (BJB)

01/06/2013 29

3 pg, 2.97 MB Filed (ECF) Appellants Heal The World Foundation and United Fleet in 11-56926 Motion to extend time to file Opening brief until 03/07/2013 at 05:00 pm. Date of service: 01/06/2013. [8462606] [11-56926, 11-57048]–[COURT UPDATE: Removed “supplemental”, resent notice. 01/07/2013 by ASW] (GSB)

01/10/2013 30

7 pg, 122.72 KB Filed (ECF) Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926 response opposing motion (,motion to extend time to file brief). Date of service: 01/10/2013. [8468966] [11-56926, 11-57048] (NDB)

01/25/2013 31

2 pg, 25.97 KB Filed order (Appellate Commissioner): Appellants’ opposed motion for an additional extension of time to file the opening brief is granted in part. The opening brief is due February 25, 2013. The answering brief is due March 27, 2013. The optional reply brief is due within 14 days after service of the answering brief. No further extensions of time to file the opening brief will be granted absent exceptional circumstances. Appellee’s motion to dismiss for lack of prosecution is denied. Appellees are informed that when a response to a motion requests affirmative relief, the title of the response must identity the request for affirmative relief. Fed. R. App. 27(a)(3)(B). (Pro Mo) [8489194] [11-56926, 11-57048] (MS)

02/22/2013 32 Submitted (ECF) Opening brief for review and filed Motion to file oversized brief. Submitted by Appellants Heal The World Foundation and United Fleet. Date of service: 02/22/2013. [8523604]–[Edited 02/26/2013 by ASW: Sealed per order, [35]; attached cert of service.]–[Edited: Spread docket text to 11-57048. 02/27/2013 by RY] (GSB)

02/22/2013 33 Submitted (ECF) excerpts of record. Submitted by Appellants Heal The World Foundation and United Fleet. Date of service: 02/22/2013. [8523719]–[Edited 02/26/2013 by ASW: Sealed per order, [35].]–[Edited: Spread docket text to 11-57048. 02/27/2013 by RY] (GSB)

02/26/2013 34

49 pg, 8.66 MB Filed (ECF) Appellees John G. Branca, John McClain and Triumph International, Inc. EMERGENCY Motion to strike whole of Appellants’ Excerpts of Record and Opening Brief Because They Include and Reference Sealed Documents Filed in the Public Record in Violation of Ninth Circuit Rules 27-13 and 25-5 (and Certificates of Service). Date of service: 02/26/2013. [8526785] (NDB)

02/26/2013 35

1 pg, 24.41 KB Filed order (Appellate Commissioner): Appellees’ emergency motion to strike is construed as a motion to seal the opening brief and excerpts of record. So construed, the motion is granted. Appellants’ motion to file an oversized brief is granted. The Clerk shall file, under seal, in appeal Nos. 11-56926 and 11-57048, the opening brief submitted on February 22, 2013. The parties are directed to include both appeal numbers on any future filings. The previously established briefing schedule remains in effect. (MOATT) [8528122] [11-56926, 11-57048] (DEV)

02/27/2013 36

2 pg, 86.6 KB Filed clerk order: The opening brief [32] submitted by Heal The World Foundation and United Fleet is filed UNDER SEAL. Within 7 days of the filing of this order, filer is ordered to file 7 copies of the brief in paper format, accompanied by certification, attached to the end of each copy of the brief, that the brief is identical to the version submitted electronically. Cover color: blue. The paper copies shall be printed from the PDF version of the brief created from the word processing application, not from PACER or Appellate ECF. The Court has reviewed the excerpts of record [33]. Within 7 days of this order, appellants are ordered to file 4 copies of the excerpts in paper format UNDER SEAL, with a white cover. The paper copies must be in the format described in 9th Circuit Rule 30-1.6. [8529946] [11-56926, 11-57048] (JB)

03/05/2013 37 Filed UNDER SEAL Appellants Heal The World Foundation and United Fleet paper copies of excerpts of record [33] in 4 volume(s). [8537499] [11-56926, 11-57048] (JB)

03/05/2013 38 Received 7 paper copies of Opening brief [32] filed by Heal The World Foundation and United Fleet. [8537691] [11-56926, 11-57048] (SD)

03/12/2013 39

21 pg, 4.01 MB Filed (ECF) Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926 Motion to extend time to file Answering brief until 04/26/2013. Date of service: 03/12/2013. [8547078] [11-56926, 11-57048] (NDB)

03/13/2013 40

2 pg, 88.39 KB Filed clerk order (Deputy Clerk: LKK): Granting Motion (ECF Filing) Appellees’ motion for an extension of time to file the answering brief is granted. The answering brief is due 04/26/2013. The optional reply brief is due 14 days after service of the answering brief. [8548961] [11-56926, 11-57048] (LKK)

04/26/2013 41 COURT DELETED INCORRECT/DUPLICATE ENTRY. Notice about deletion sent to case participants registered for electronic filing. Merged into Entry: [44]. Original Text: Submitted (ECF) supplemental excerpts of record. Submitted by Appellees John G. Branca, John McClain and Triumph International, Inc.. Date of service: 04/26/2013. [8607337] (VHC)

04/26/2013 42 COURT DELETED INCORRECT/DUPLICATE ENTRY. Notice about deletion sent to case participants registered for electronic filing. Merged into Entry: [44]. Original Text: Submitted (ECF) supplemental excerpts of record. Submitted by Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926. Date of service: 04/26/2013. [8607340] [11-56926, 11-57048] (VHC)

04/26/2013 43 COURT DELETED INCORRECT/DUPLICATE ENTRY. Notice about deletion sent to case participants registered for electronic filing. Merged into Entry: [44]. Original Text: Submitted (ECF) supplemental excerpts of record. Submitted by Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926. Date of service: 04/26/2013. [8607345] [11-56926, 11-57048] (VHC)

04/26/2013 44

3679 pg, 206.24 MB Submitted (ECF) supplemental excerpts of record. Submitted by Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926. Date of service: 04/26/2013. [8607355] [11-56926, 11-57048]–[COURT UPDATES: removed “Notice of filing Under Seal along with the district court order and certificate of service”, resent notice. 04/29/2013 by ASW; combined separately submitted ERs into one entry, resent notice. 04/30/2013 by ASW] (VHC)

04/29/2013 45

10 pg, 303.35 KB Filed (ECF) Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926 correspondence: Notice of filing Under Seal along with the district court order and certificate of service. Date of service: 04/26/2013 [8607783] [11-56926, 11-57048]–[COURT UPDATE: Corrected filing type and text, resent notice. 04/29/2013 by ASW] (VHC)

04/29/2013 47 Open Restricted Document

0 pg, 0 KB Filed UNDER SEAL original and 7 copies of Appellees answering brief of 71 pages. Supplemental Excerpts of record in 22 volumes (Volumes 16-22 UNDER SEAL). Served on 04/26/2013. [8611454] [11-56926, 11-57048] (JB)

04/30/2013 46

2 pg, 85.85 KB Filed clerk order: The Court has reviewed the supplemental excerpts of record [44] submitted by John G. Branca, John McClain and Triumph International, Inc. Within 7 days of this order, appellees are ordered to file 4 copies of the excerpts in paper format, with a white cover. The paper copies must be in the format described in 9th Circuit Rule 30-1.6. [8609572] [11-56926, 11-57048] (GV)

05/07/2013 48

2 pg, 45.56 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet Motion to extend time to file reply brief until 08/06/2013. Date of service: 05/07/2013. [8620099]–[COURT UPDATE: Changed reply to reply brief, spread entry to 11-57048. Resent notice. 05/07/2013 by ASW] (GSB)

05/23/2013 49

1 pg, 26.94 KB Filed clerk order (Deputy Clerk: AMT): Appellants’ motion for an extension of time to file the reply brief is granted. The reply brief is due August 6, 2013. Appellant’s counsel is reminded all filings must be served on all parties and be accompanied by proof of service. See Fed. R. app. P. 25(b); 9th Cir. R. 25-5(f). [8640155] [11-56926, 11-57048] (BJB)

07/30/2013 50 Filed (ECF) Streamlined request for extension of time to file Reply Brief by Appellants Heal The World Foundation and United Fleet. New requested due date is 09/30/2013 at 04:00 pm. [8723283] (GSB)

07/30/2013 51 Streamlined request by Appellants Heal The World Foundation and United Fleet to extend time to file the brief is not approved because filer requested a previous extension of time. The filer must file a motion per 9th Cir. R. 31-2.2(b). [8723913] (LW)

07/30/2013 52

6 pg, 174.23 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet in 11-56926 Motion to extend time to file Reply brief until 11/04/2013 at 04:00 pm. Date of service: 07/30/2013. [8723960] [11-56926, 11-57048]–[COURT UPDATE: Edited docket text to reflect correct relief (motion to extend time to file brief, NOT reply). Resent NDA. 07/31/2013 by RY] (GSB)

08/16/2013 53

2 pg, 34.29 KB Filed clerk order (Deputy Clerk: AMT): Appellants’ motion for a second extension of time to file the reply brief is granted. The reply brief is due November 4, 2013. [8746744] [11-56926, 11-57048] (BJB)

10/30/2013 54

3 pg, 294.24 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet in 11-56926 Motion to extend time to file Reply brief until 01/06/2014. Date of service: 10/30/2013. [8844311] [11-56926, 11-57048] (GSB)

10/31/2013 55

8 pg, 140.31 KB Filed (ECF) Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926, 11-57048 response opposing motion (,motion to extend time to file brief). Date of service: 10/31/2013. [8845334] [11-56926, 11-57048] (NDB)

11/04/2013 56

2 pg, 34.49 KB Filed clerk order (Deputy Clerk: AMT): Appellants’ opposed motion for a third extension of time to file the reply brief is granted in part. The consolidated reply brief is due December 18, 2013. Any further request for an extension of time to file the consolidated reply brief is disfavored. [8848755] [11-56926, 11-57048] (BJB)

11/30/2013 57

4 pg, 236.48 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet in 11-56926 Motion to unseal document Reply Brief. Date of service: 11/30/2013. [8882979] [11-56926, 11-57048] (GSB)

12/15/2013 58

4 pg, 170.88 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet Motion to file oversized brief. Date of service: 12/15/2013. [8901786]–[COURT UPDATE: Spread entry to case 11-57048, resent notice. 12/16/2013 by ASW] (GSB)

12/15/2013 59

3 pg, 168.7 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet Supplemental Motion to file oversized brief. Date of service: 12/15/2013. [8901787]–[COURT UPDATE: Spread entry to 11-57048, resent notice. 12/16/2013 by ASW] (GSB)

01/02/2014 60

10 pg, 691.55 KB Notice of Oral Argument on MARCH Calendar. Please return ACKNOWLEDGMENT OF HEARING NOTICE form to: PASADENA Office. Please open attached documents to view details about your case. [8922715] [11-56926, 11-57048] (LN)

01/06/2014 61

64 pg, 325.7 KB Submitted (ECF) Reply Brief for review. Submitted by Appellants Heal The World Foundation and United Fleet in 11-56926. Date of service: 01/06/2014. [8926993] [11-56926, 11-57048]–[COURT UPDATE: Attached corrected brief. Resent NDA. 01/07/2014 by RY] (GSB)

01/07/2014 62 COURT DELETED INCORRECT ENTRY. Notice about deletion sent to case participants registered for electronic filing. Correct Entry: [63]. Original Text: Filed (ECF) Errata to Reply brief ([61] Brief Submitted for Review (ECF Filing) ). Filed by Appellants Heal The World Foundation and United Fleet. Date of service: 01/07/2014. [8928716] (GSB)

01/08/2014 63

1244 pg, 86 MB Submitted (ECF) supplemental excerpts of record. Submitted by Appellants Heal The World Foundation and United Fleet. Date of service: 01/08/2014. [8929697]–[COURT UPDATE: Edited docket text to reflect correct excerpts type. Spread docket text to 11-57048. 01/08/2014 by RY] (GSB)

01/10/2014 64

2 pg, 183.7 KB Filed (ECF) Acknowledgment of hearing notice. Location: Pasadena. Filed by Attorney Vincent H. Chieffo for Appellees John McClain, John G. Branca and Triumph International, Inc. in 11-56926, 11-57048. [8933324] [11-56926, 11-57048] (VHC)

01/10/2014 65

11 pg, 141.64 KB Filed (ECF) Appellees John G. Branca, John McClain and Triumph International, Inc. in 11-56926 Motion for miscellaneous relief [Appellees’ 1-Motion to Strike Appellants’ Untimely & Oversized Reply Brief; 2-Motion to Strike Portions of Appellants’ Supplemental Excerpts of Record Filed with Appellants’ Reply Brief; 3-Request for Sanctions; 4-Motion to Dismiss Appeal]. Date of service: 01/10/2014. [8934109] [11-56926, 11-57048] (NDB)

02/10/2014 66

2 pg, 196.88 KB ENTRY UPDATED. Received Appellants Heal The World Foundation and United Fleet paper copies of supplemental excerpt of record [63] in 7 volumes (Volumes 2 and 3 UNDER SEAL). Served on 01/09/2014. Deficiencies: motion to file oversized reply brief pending, notification of filing under seal is required. Notified counsel (see attached notice). (Sent to Panel) [8973255] [11-56926, 11-57048]–[Edited 02/10/2014 by LA] (LA)

02/10/2014 68

1 pg, 190.16 KB Received Appellants Heal The World Foundation and United Fleet 4 copies of 4 disks: CD Volume 2, DE-210-4 [voice mail tracks #1-12] (UNDER SEAL); DVD Volume 5, Trial Exhibit -120 [ABC interview w/ Johnson and Oxman]; DVD Volume 5, Trial Exhibit -272 [HTWF Youth Board Meeting w/ Jackson’s kids, Mother and Johnson]; DVD Volume 5, Trial Exhibit -284 [Good Morning America – HTWF Segment – w/ Jackson’s kids, Mother and Johnson]. Served on 01/09/2014. Deficiencies: motion to transmit physical exhibits is required. Notified counsel (see attached notice). (Sent to Panel) [8973346] [11-56926, 11-57048] (LA)

02/13/2014 69

2 pg, 59.69 KB Filed (ECF) Appellants Heal The World Foundation and United Fleet in 11-56926 Unopposed Motion to reschedule oral argument. Date of service: 02/13/2014. [8978074] [11-56926, 11-57048] (GSB)

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