John Fogerty v. Cook - 2nd Amended Complaint

SECOND AMENDED COMPLAINT -1- 2:15-cv-06069-FMO (FFMx) 055523\0002\14003155.2

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MICHAEL D. ROUNDS (CA State Bar No. 133972) [email protected] BROWNSTEIN HYATT FARBER SCHRECK, LLP 5371 Kietzke Lane Reno, Nevada 89511 Telephone: 775.324.4100 Facsimile: 775.333.8171 MITCHELL J. LANGBERG (CA State Bar No. 171912) [email protected] LAURA BIELINSKI (CA State Bar No. 264115) [email protected] BROWNSTEIN HYATT FARBER SCHRECK, LLP 2049 Century Park East, Suite 3550 Los Angeles, CA 90067-3007 Telephone: 310.500.4600 Facsimile: 310.500.4602 Attorneys for Plaintiffs POOR BOY PRODUCTIONS, INC., CREEDENCE CLEARWATER REVIVAL, STUART COOK, DOUGLAS CLIFFORD, AND PATRICIA FOGERTY

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

JOHN FOGERTY Plaintiff, vs. STUART COOK, an individual; DOUGLAS CLIFFORD, an individual; and POOR BOY PRODUCTIONS, INC., a corporation, Defendants.

Case No. 2:15-cv-06069-FMO (FFMx) consolidated with 2:15-cv-06501-FMO (FFMx)

SECOND AMENDED COMPLAINT JURY DEMAND

AND RELATED ACTIONS

Plaintiffs Poor Boy Productions, Inc. ("Poor Boy"), Creedence Clearwater

Revival ("CCR"), a partnership, Stuart Cook ("Cook"), Douglas Clifford

("Clifford"), and Patricia Fogerty ("Ms. Fogerty") (collectively "Plaintiffs"), by

and through their undersigned attorneys Brownstein, Hyatt, Farber and Schreck,

Case 2:15-cv-06069-FMO-FFM Document 34 Filed 12/23/15 Page 1 of 17 Page ID #:450


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for their Second Amended Complaint against Defendant John Fogerty

("Defendant" or "Fogerty"), allege the following:

JURISDICTION AND VENUE

1. This action arises under the Acts of Congress relating to the Lanham

Act, Title 15 U.S.C. 1051, et seq., and the common law. This is also an action

for declaratory relief, breach of contract, breach of the implied covenant of good

faith and fair dealing, and breach of fiduciary duty under California law.

2. Jurisdiction is based on federal question pursuant to 28 U.S.C.

1331 and 1338 because this action involves federal questions of law. This Court

has supplemental jurisdiction over the claims brought under the common law

pursuant to 28 U.S.C. 1338(b) and 1367(a).

3. Defendant is subject to this Court's personal jurisdiction because he is

a resident of the State of California and this District.

4. As determined by Judge Robert C. Jones, United States District Court

Judge for the District of Nevada, venue is proper in this judicial district pursuant

to 28 U.S.C. 1391(b)(1). PARTIES

5. Plaintiff Poor Boy is a Nevada corporation with its principal place of

business located in Incline Village, Nevada.

6. Plaintiff CCR is a California partnership comprised of Messrs. Cook,

Clifford, Ms. Fogerty and Fogerty.

7. Plaintiff Clifford is a resident of the State of Nevada.

8. Plaintiff Cook is a resident of the State of Florida.

9. Plaintiff Ms. Fogerty is a resident of the State of Arizona.

10. Defendant Fogerty is a resident of the State of California and this

District.



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FACTS

11. The musical group and partnership Creedence Clearwater Revival was

originally comprised of Douglas Clifford, Stuart Cook, Tom Fogerty and John

Fogerty. Tom Fogerty passed away in 1990, and his interest in CCR's property,

including intellectual property and royalties, passed to his wife, Ms. Fogerty.

12. CCR is the owner of U.S. Trademark Registration No. 1222931 ("'931

Reg."), issued by the United States Patent and Trademark Office ("USPTO") on

January 4, 1983, for the Mark CREEDENCE CLEARWATER REVIVAL for

"entertainment servicesnamely, a vocal and instrumental group" in International

Class 41. A copy of the '931 Reg. is attached hereto as Exhibit A. CCR also owns

all common law rights related to the Creedence Clearwater Revival Mark and its

derivatives (collectively the CCR Mark)

13. In or about February and March 1992, Cook, Clifford, Fogerty and

Ms. Fogerty executed an Assignment of Trademark, which was subsequently

recorded with the USPTO ("Assignment"). A copy of the Assignment is attached

hereto as Exhibit B. The Assignment states, in relevant part, as follows:

a. "CREEDENCE CLEARWATER REVIVAL, a firm consisting

of John Fogerty, Doug Clifford, Stu Cook and Tom Fogerty is the owner of" the

CCR Mark;

b. Tom Fogerty passed away and Ms. Fogerty is his sole heir;

c. "it is the intention of the parties and the purpose of this

Assignment to substitute Tricia Fogerty in the place and stead of the deceased Tom

Fogerty in said partnership for the sole purpose of establishing her ownership

interest in and to said service mark and the registration thereon, and for no other

purpose"; and

d. "the interest of said Tom Fogerty, solely in connection with

his interest in the Service Mark: CREEDENCE CLEARWATER REVIVAL and

the registration thereon, together with the goodwill of the business with which said



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mark was used, is hereby sold, transferred and assigned to CREEDENCE

CLEARWATER REVIVAL, a firm consisting of John Fogerty, Doug Clifford, Stu

Cook and Tricia Fogerty, as heir to the deceased Tom Fogerty."

14. On or about March 1, 1995, Clifford, Cook and Ms. Fogerty, a

majority of the CCR partners, executed a Licensing Agreement ("License") on

behalf of CCR, for a term of ten years with an option to extend the term for an

additional ten years, with Poor Boy. Among other things, the License granted Poor

Boy the right to use the name CREEDENCE CLEARWATER REVISITED

("REVISITED Mark"), in connection with musical performances.

15. Shortly after the License was executed, Clifford and Cook, through

Poor Boy, began touring using the REVISITED Mark.

16. On July 2, 1996, Fogerty filed a Complaint in the United States

District Court Central District of California Western Division against Poor Boy,

Cook, Clifford and Ms. Fogerty styled Fogerty v. Poor Boy Productions, Inc., et

al., Case No. CV 96-4634 RMT (RNBx) alleging, among other things, that Fogerty

was synonymous with the CCR Mark and that there was therefore infringement

and a likelihood of confusion regarding Fogertys association with CREEDENCE

CLEARWATER REVISITED.

17. Fogerty also sought and obtained a preliminary injunction against the

Defendants in that action from performing under the REVISITED Mark. The

Ninth Circuit Court of Appeals reversed that order in an unpublished opinion in

Fogerty v. Poor Boy Productions, Inc., et al., 124 F.3d 211 (9th Cir. 1997), finding

that there was no evidence that the American public believed that Fogerty was

associated with CREEDENCE CLEARWATER REVISITED. The Ninth Circuit

further found that the record does not support Fogertys efforts to deny that a

partnership owned the mark or that it makes decisions regarding the mark by

majority vote.

18. After the Ninth Circuit reversed the district court's preliminary



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injunction order, through counsel, the parties entered into a settlement agreement

("Settlement Agreement") on or about January 9, 2001 that resulted in a dismissal

with prejudice of the action. A copy of this Settlement Agreement is attached

hereto as Exhibit C. Pursuant to the Settlement Agreement, the parties agreed that

Fogerty would withdraw his objection to Clifford's and Cook's performing under

the REVISITED Mark. Id. The parties also agreed that Clifford, Cook and Ms.

Fogerty would not authorize any other persons or entities to perform under the

names CREEDENCE, CREEDENCE CLEARWATER or any derivative of those

names without the prior written permission of Fogerty. Id. The parties also agreed

that Poor Boy would pay additional monies to Fogerty. Id.

19. At the time Plaintiffs entered into the License and at the time they

entered into the Settlement Agreement, and through the present date, Fogerty was

and is a copartner in CCR for at least purposes of ownership of the CCR Mark and

the 931 Reg., and Plaintiffs reasonably believed that he was and is a copartner in

the CCR partnership. Fogerty stated in the Assignment that a partnership existed

and that he was a copartner in the partnership, and has acted as a copartner in

matters concerning ownership of the CCR Mark and 931 Reg. since at least 1992.

These actions include, but are not limited to, licensing the CCR Mark as a

copartner and ceasing infringing use of the CCR Mark and 931 Reg. on several

occasions since the execution of the Settlement Agreement because the CCR

partnership did not consent to his infringing use.

20. Plaintiffs relied on Fogerty's express representations and course of

conduct that he was a copartner in the CCR partnership from at least the time of

the Assignment and through the present date.

21. Fogerty is estopped from denying the existence of the CCR

partnership for at least purposes of CCR's ownership of the CCR Mark and the 931

Reg. and a partnership further exists through the parties long-time and undisputed

course of conduct.



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22. By executing the Assignment and receiving the benefit of the

goodwill associated with the CCR Mark and 931 Reg. through the present date,

Fogerty is estopped from challenging the validity of the CCR Mark and 931 Reg.

23. Poor Boy has continuously used the REVISITED Mark in commerce

in connection with live musical performances since at least 1995, except for the

brief period it was enjoined.

24. After entering into the Settlement Agreement, Poor Boy fully

performed under the terms of that Agreement, and paid the agreed-upon monies to

Fogerty. However, in a July 9, 2011 article for Ultimateclassicrock.com, Fogerty

publically condemned and objected to Poor Boy's, Clifford's and Cook's use of the

REVISITED Mark in direct contravention of the Settlement Agreement, falsely

stating, among other things, that it breaks a longstanding band agreement." See

http://ultimateclassicrock.com/john-fogerty-condemns-former-bandmates/, a copy

of which is attached hereto as Exhibit D.

25. After publication of this article, Poor Boy, through counsel, sent a

letter to counsel for Fogerty enclosing checks for performances and merchandise

for use of the REVISITED Mark for the second and third quarters of 2011, and

demanding cessation of Fogerty's malfeasance and breach of the Settlement

Agreement. Fogerty did not respond, and, as a result, Poor Boy ceased paying

Fogerty monies under the Settlement Agreement. To this day, the article and its

false statements can still be accessed at http://ultimateclassicrock.com/john-

fogerty-condemns-former-bandmates/.

26. In addition to violating the terms of the Settlement Agreement,

Fogerty has in the recent past used the CCR Mark without the permission of CCR.

Examples of such infringing uses are attached collectively hereto as Exhibit E.

27. Most recently, Plaintiffs learned that Fogerty has used the CCR Mark,

and derivations thereof, without permission from CCR, as follows:

a. on Fogerty's Facebook page located at



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www.facebook.com/johnfogerty, Fogerty attributes the page to

"John Fogerty/Creedence Clearwater Revival" under the

category "Musician/Band." In the "About" section of the page,

Fogerty lists the following as "Members" of "John

Fogerty/Creedence Clearwater Revival": "John Fogerty, Kenny

Aronoff, Bob Malone, Shane Fogerty, James Lomenzo, and

Devon Pangle" ("Facebook Infringement"). Of these

individuals, only Fogerty is or ever was a member of the

musical group Creedence Clearwater Revival;

b. through his website located at www.johnfogerty.com, Fogerty

sells: (i) baseball caps bearing solely the word CREEDENCE,

for $30; (ii) hockey pucks bearing the world famous Creedence

Clearwater Revival "Green River" album cover, for $10

unsigned, and $150 autographed by Fogerty; (iii) sweatshirts

bearing CREEDENCE CLEARWATER REVIVAL for $50;

(iv) t-shirts bearing CREEDENCE CLEARWATER REVIVAL

for $30; and (v) autographed Creedence Clearwater Revival

albums for $150 (collectively, "Merchandise Infringement");

and

c. Fogerty titled his forthcoming January 2016 series of his shows

at The Venetian hotel in Las Vegas, Nevada ("Venetian"),

JOHN FOGERTY PEACE, LOVE & CREEDENCE

("Venetian Infringement" and, together with Facebook

Infringement and Merchandise Infringement, "Recent

Infringement"). True and correct copies of documents

evidencing the Recent Infringement are attached as Exhibit F.

28. After Plaintiffs sent Fogerty and Venetian a cease and desist letter on

or about October 26, 2015, regarding the Venetian Infringement, Fogerty and/or



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Venetian changed the name of January 2016 Venetian show from JOHN

FOGERTY PEACE LOVE AND CREEDENCE to JOHN FOGERTY

FORTUNATE SON IN CONCERT.

29. On November 12, 2015, Fogerty sent a letter to Plaintiffs, accusing

Plaintiffs and their counsel of attempting to wrongfully interfere with Fogerty's

contractual relationship with Venetian by the October 26, 2015 cease and desist

letter, "through meritless trademark contentions using an abandoned mark against

protected First Amendment activity."

30. The CCR Mark has not been abandoned in any sense. The CCR Mark

remains world famous today, and is used to identify the band as a source of CCR

recordings that are sold in stores and over the internet and performed on radio daily

around the world. In addition, the CCR Mark has been used by Plaintiffs Clifford

and Cook to promote their previously recorded work with Creedence Clearwater

Revival, and Poor Boys substantial, continued and licensed use of the

REVISITED Mark has inured to the benefit of the CCR Mark and the CCR

partnership. Defendant Fogerty has recognized the ownership, strength and

continued use of the CCR Mark repeatedly since at least 1992, by licensing third

parties through the partnership and ceasing his own infringing use of the CCR

Mark and 931 Reg. on several occasions.

31. Fogerty has, and has intended to, explicitly mislead the consuming

public as to an affiliation, connection, association, origin, sponsorship or approval

of his goods and services by CCR, including in connection with the Recent

Infringement.

32. Fogerty's unauthorized use of the CCR Mark and derivations thereof

creates a likelihood of confusion, mistake and deception as to the affiliation,

connection, association, origin, sponsorship or approval of its goods and services,

by or with CCR, all to CCR's irreparable loss and damage. His infringing conduct

is not protected by the First Amendment because he is using the CCR Mark as a



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trademark to identify source and not in a descriptive sense to state his former

affiliation with the musical group CREEDENCE CLEARWATER REVIVAL or

the playing of its music.

33. Consumer confusion will likely occur as a result of Fogerty's acts

complained of herein unless Fogerty is enjoined from continuing said acts.

Furthermore, CCR will suffer irreparable injury to its reputation and goodwill

unless Fogerty is so enjoined.

34. Fogerty has recently alleged that Poor Boy, Clifford and Cook have

violated the terms of the Settlement Agreement by failing to pay royalties and, at

least impliedly, by asserting that Messrs. Clifford and Cook are required to at all

times but have not performed together. As such, Fogerty has recently demanded

payment of all monies allegedly owing from December 2011 to the present,

including an accounting of performances where Clifford and Cook have not

performed together. Plaintiffs Cook, Clifford and Poor Boy deny these allegations. CLAIM I

(Trademark Infringement - 15 U.S.C. 1114(a))

35. Plaintiffs repeat, reallege, and reiterate each and every paragraph set

forth above as if fully set forth herein.

36. By the acts complained of herein, Fogerty has used in connection with

his services and/or goods a reproduction, counterfeit, copy or colorable imitation of

the CCR Mark protected by the 931 Reg., in connection with the sale, offering for

sale, distribution and advertising of his entertainment services and/or goods, and

such use is likely to cause confusion, mistake and deception amongst the

consuming public in violation of 15 U.S.C. 1114(a).

37. Fogerty's aforesaid acts have caused and will continue to cause great

and irreparable injury to Plaintiffs and, unless such acts are restrained by this

Court, such acts will continue and Plaintiffs will therefore continue to suffer great

and irreparable injury.



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38. Plaintiffs have been damaged by Defendants' willful infringement in

an amount according to proof. CLAIM II

(Lanham Act Violation - 15 U.S.C. 1125(a))



40. By the acts complained of herein, Fogerty has used in connection with

his entertainment services and/or goods a false designation of origin, description or

representation, including use of the CCR Marks and derivations thereof, which is

likely to cause confusion, mistake or to deceive as to origin, affiliation, connection,

sponsorship or association of Fogerty with Plaintiffs, or as to the origin,

sponsorship or approval of Fogerty's services and/or goods by Plaintiffs, in

violation of 15 U.S.C. 1125(a).





42. Plaintiffs have been damaged by Defendant's willful unfair

competition in an amount according to proof. CLAIM III

(Unfair Competition at Common Law)



44. The aforesaid acts of Fogerty constitutes the sale and passing-off of

his services and/or goods as Plaintiffs' services and/or goods, infringement,

imitation and misappropriation of the CCR Mark, unjust enrichment, and unfair

competition with Plaintiffs, in violation of Plaintiffs' rights at common law.




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46. Plaintiffs have been damaged by Defendants' willful unfair

competition in an amount according to proof. CLAIM IV

(Declaratory Relief - 28 U.S.C. 2201-2202)



48. By reason of the foregoing allegations, an actual case or controversy

has arisen and exists between Plaintiffs and Fogerty as to:

a. whether Fogerty has, or Plaintiffs Clifford, Cook and Poor Boy

have, violated the Settlement Agreement;

b. whether Plaintiffs Clifford, Cook, Poor Boy and CCR have

wrongfully interfered with Fogerty's contract with Venetian;

c. whether CCR has abandoned the CCR Mark; and

d. whether Fogerty's infringing conduct as described herein is

protected First Amendment activity.

49. Given the nature of Fogerty's charges, Plaintiffs will continue to suffer

harm and damage unless this Court declares that Plaintiffs have not violated the

Settlement Agreement and have not wrongfully interfered with Fogerty's contract

with Venetian, that CCR has not abandoned the CCR Mark, and that Fogerty's

conduct is not protected First Amendment Activity. CLAIM V

(Breach of Contract)



51. Poor Boy, Clifford, Cook, Ms. Fogerty and Fogerty entered into the



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Settlement Agreement on or about January 9, 2001, whereby Fogerty agreed to

withdraw his objection to Clifford's and Cook's performing under the REVISITED

Mark. See Exhibit D. The parties also agreed that Clifford, Cook, and Ms.

Fogerty would not authorize any other persons or entities to perform under the

names CREEDENCE, CREEDENCE CLEARWATER or any derivative of those

names without the prior written permission of Fogerty. Id. The parties also agreed

that Poor Boy would pay monies to Fogerty for uses the REVISITED Mark. Id.

52. Poor Boy, Clifford, Cook, and Ms. Fogerty performed under the terms

of the Settlement Agreement with Fogerty until Fogerty breached the Settlement

Agreement by publically condemning and objecting to Poor Boy's use of the

REVISITED Mark, which he agreed to pursuant to the Settlement agreement. See

Exhibit D.

53. As a direct and proximate result of Fogerty's actions and breach of

contract, Poor Boy, Clifford, Cook, and Ms. Fogerty have suffered damages in an

amount in excess of $75,000, and in an amount according to proof. CLAIM VI

(Breach of Implied Covenant of Good Faith and Fair Dealing)



55. The Settlement Agreement between Poor Boy, Clifford, Cook, and

Ms. Fogerty and Fogerty contains an implied covenant of good faith and fair

dealing.

56. The implied covenant of good faith and fair dealing requires that

Fogerty do nothing to injure the right of Poor Boy, Clifford, Cook, and Ms.

Fogerty to receive the benefits of that Settlement Agreement, that Fogerty give full

cooperation to Poor Boy, Clifford, Cook, and Ms. Fogerty, and Fogerty refrains

from doing any act to prevent or impede Poor Boy, Clifford, Cook, and Ms.

Fogerty's enjoyment of the benefit of that Agreement.



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57. The acts and omissions described herein have resulted in Fogerty's

breach of not only the Settlement Agreement with Poor Boy, Clifford, Cook, and

Ms. Fogerty, but have also resulted in the breach of Fogerty's covenant of good

faith and fair dealing as applied to that Agreement.

58. As a direct and proximate result of Fogerty's actions and breaches of

implied covenant of good faith and fair dealing, Poor Boy, Clifford, Cook, and Ms.

Fogerty have suffered damages in an amount in excess of $75,000, and in an

amount according to proof. CLAIM VII

(Breach of Fiduciary Duty Cal. Corp. Code. 16401, 16404, 16501)



60. Cal. Corp. Code 16401(g) states that a "partner may use or possess

partnership property only on behalf of the partnership." Cal. Corp. Code 16501

provides that a "partner is not a coowner of partnership property and has no interest

in partnership property that can be transferred, either voluntarily or involuntarily."

Cal. Corp. Code 16404 provides that "(a) the fiduciary duties a partner owes to

the partnership and the other partners are the duty of loyalty and the duty of care

set forth in subdivisions (b) and (c)." Subsection (b)(3) of Cal. Corp. Code

16404 provides that a partner must refrain from competing with the partnership in

the conduct of the partnership business before the dissolution of the partnership.

61. By using the CCR Mark without CCR's permission, contesting the

validity of the CCR Mark and denying the existence of a partnership, Fogerty has

violated his fiduciary duties to that partnership.

62. As a direct and proximate result of Fogerty's actions and breaches of

fiduciary duty, CCR, Cook, Clifford and Ms. Fogerty have suffered damages in an

amount in excess of $75,000, and in an amount according to proof.



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PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request this Court for the following

relief:

1. That the Court find that Fogerty has been and is infringing the CCR

Mark and corresponding '931 Reg., and is competing unfairly with Plaintiffs, and

otherwise has been unjustly enriched.

2. That Plaintiffs be awarded their damages and Fogerty's profits

attributable to his infringement of the CCR Mark and corresponding '931 Reg.

under 15 U.S.C. 1117(a).

3. That Plaintiffs be awarded three times the profits attributable to

Fogerty's infringement of the CCR Mark and corresponding '931 Reg. under 15

U.S.C. 1117(a).

4. That Plaintiffs be awarded their reasonable attorneys' fees and costs of

suit, under 15 U.S.C. 1117(a).

5. That an injunction be issued against Fogerty and his servants, agents,

employees, successors and assigns, and all persons acting in concert or privity with

him, enjoining each of them, singly and collectively, from:

a. further using, promoting, advertising, and marketing the

"Creedence Clearwater Revival" service mark and trademark,

or any name, mark or designation confusingly similar thereto;

b. further holding himself out to the public as being affiliated with

or sponsored by CCR in any manner, or committing any acts

likely to imply any such relationship or affiliation;

c. requiring Fogerty to deliver to Plaintiffs for destruction all

infringing material in his possession, custody or control bearing

the "Creedence Clearwater Revival" service mark or trademark,

or any other names, marks or designations confusingly similar

thereto; and



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d. requiring Fogerty to cease objecting to the use of, or stating that

Poor Boy, Clifford, Cook and Fogerty do not have an

agreement for the use of, the REVISITED Mark in commerce.

6. That an order be issued preventing Fogerty's infringement and unfair

competition and awarding all applicable damages for Fogerty's conduct.

7. That the Court declare:

a. Fogerty has, and Plaintiffs have not, violated the Settlement

Agreement;

b. Plaintiffs have not wrongfully interfered with Fogerty's contract

with Venetian;

c. CCR has not abandoned the CCR Mark; and

d. Fogerty's conduct as described herein is not protected by the

First Amendment. 8. For general damages.

9. For incidental damages.

10. For consequential damages.

11. For costs of suit incurred herein.

12. For reasonable attorneys' fees.

13. For pre-judgment and post-judgment interest.

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14. That the Court grant Plaintiffs such other relief as is just and proper.

DATED this ___ day of December, 2015.

By: /s/ Michael D. Rounds MICHAEL D. ROUNDS (CA State Bar No. 133972) [email protected] BROWNSTEIN HYATT FARBER SCHRECK, LLP 5371 Kietzke Lane Reno, Nevada 89511 MITCHELL J. LANGBERG (CA State Bar No. 171912) [email protected] LAURA BIELINSKI (CA State Bar No. 264115) [email protected] BROWNSTEIN HYATT FARBER SCHRECK, LLP 2049 Century Park East, Suite 3550 Los Angeles, CA 90067-3007

Attorneys for Plaintiffs


dcrudupTypewritten Text23rd


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JURY DEMAND

Pursuant to Fed. R. Civ. P. 38(b), Plaintiffs Poor Boy Productions, Inc.,

Creedence Clearwater Revival, Stuart Cook, Douglas Clifford, and Patricia

Fogerty hereby demand a jury trial on all issues triable by jury.

DATED this ___ day of December, 2015.

By: /s/ Michael D. Rounds MICHAEL D. ROUNDS (CA State Bar No. 133972) [email protected] BROWNSTEIN HYATT FARBER SCHRECK, LLP 5371 Kietzke Lane Reno, Nevada 89511 MITCHELL J. LANGBERG (CA State Bar No. 171912) [email protected] LAURA BIELINSKI (CA State Bar No. 264115) [email protected] BROWNSTEIN HYATT FARBER SCHRECK, LLP 2049 Century Park East, Suite 3550 Los Angeles, CA 90067-3007

Attorneys for Plaintiffs


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Documents

John Fogerty v. Cook - 2nd Amended Complaint