Case 2:15-cv-03462-RGK-AGR Document 118-4 Filed 03/07/16 Page 1 of 4 Page ID

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Francis Malofiy, Esq.

Francis Alexander, LLC
280 N. Providence Rd. | Suite 105
Media, PA 19063
T: (215) 500-1000; F: (215) 500-1005
E: francis@francisalexander.com
Attorney for Plaintiff
Glen L. Kulik, Esq. (SBN 082170)
Kulik Gottesman & Siegel LLP
15303 Ventura Blvd., Suite 1400
Sherman Oaks, CA 91403
T: (310) 557-9200; F: (310) 557-0224
E: gkulik@kgslaw.com
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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MICHAEL SKIDMORE, as Trustee for

15 the RANDY CRAIG WOLFE TRUST,
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Hon. R. Gary Klausner

Plaintiff,
v.

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Case No. 15-cv-03462 RGK (AGRx)

LED ZEPPELIN; JAMES PATRICK

PAGE; ROBERT ANTHONY PLANT;
JOHN PAUL JONES; SUPER HYPE
PUBLISHING, INC.; WARNER MUSIC
GROUP CORP., Parent of
WARNER/CHAPPELL MUSIC, INC.;
ATLANTIC RECORDING
CORPORATION; RHINO
ENTERTAINMENT COMPANY,

DECLARATION OF JANET
WOLFE IN OPPOSITION TO
DEFENDANTS MOTION FOR
SUMMARY JUDGMENT OR
PARTIAL SUMMARY JUDGMENT
Date: March 28, 2016
Time: 9:00 a.m.
Room: 850

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Defendants.

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Case No. 15-cv-03462 RGK (AGRx)__
Declaration of Janet Wolfe in Opposition to Defendants
Motion for Summary Judgment

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DECLARATION OF JANET WOLFE

I, Janet Wolfe, declare as follows:

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I am Randy Wolfes sister. I have no financial stake in the outcome of

this litigation but do have an interest in justice and in seeing that my brother gets the

recognition he deserves. I have personal knowledge of the facts recited below and if

called as a witness could testify competently to these facts.

2.

In early 1966, my family moved from California to New York. Randy

was 15 at the time and I was 12. In approximately June of that year, he met Jimi

Hendrix in a record store and they became fast friends until the day Jimi died. They

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played music and performed together that entire summer, and my family would

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always go and see their shows. It was Jimi who gave Randy his nickname Randy

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California.

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3.

At the end of the summer Jimi and Randy met Chas Chandler, who

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became Jimis manager. He convinced Jimi to go to London to form the Jimi

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Hendrix Experience. They wanted my brother to go too but my mother Bernice

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Pearl felt Randy was too young and she refused. Thus, when Jimi headed to

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London, my family moved back to California.

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4.

When we returned to California we lived for the first two months at my

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uncles home and then we moved to Ojai where Randy attended Nordhoff High

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School. He soon met Robin, who would later become his wife. Her astrological

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sign was Taurus, so in late 1966, Randy wrote a song for her called Taurus.

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5.

When we returned from New York to California my brother formed a

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band with two friends, Mark Andes and Jay Ferguson. My uncle, Ed Pearl, owned a

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famous club in Hollywood called the Ash Grove. Randy and his band played there at

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least once a week under the name Spirits Rebellious. My entire family, myself

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included, would go and see the band perform. They played Taurus at all their

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shows. Taurus was Randys favorite song until the day he died, because it was

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written for Robin, the love of his life.

Case No. 15-cv-03462 RGK (AGRx)
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Declaration of Janet Wolfe in Opposition to Defendants
Motion for Summary Judgment

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6.

Eventually the family moved from Ojai to Santa Monica. The band

rehearsed at our home several times per week. One day there was a knock at the

door while they were rehearsing and it was a guy by the name of Brian Berry. I was

present. Brian told us he really liked the music, and he struck up a friendship with

Randy and the other group members. Brian was the brother of Jan Berry of the

musical group Jan and Dean, and he later offered to introduce them to Lou Adler

who became their manager and owner of their record label.

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The group Spirit released its first album in 1968. One of the tracks on

the album was Taurus. They then went on a lengthy tour in support of the album. I

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attended many of the performances they gave in the United States, but I did not

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accompany them when they went to Europe. The band played Taurus at every show

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I attended during the years 1968 and 1969. As I said, it was Randys favorite song

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and it was a crowd pleaser in concert.

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Spirits second album was called The Family That Plays Together was

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a testament to how close the band members were. In addition, we were a very

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musical family. My uncle owned the famous Ash Grove, and my stepfather was the

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drummer for the group Spirit. I sang with Randy from the time I was five, singing

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harmony. I sang back up on his solo albums.

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9.

In 1970, while Randy was doing the final mix for the album Twelve

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Dreams of Dr. Sardonicus, he was badly injured when he was thrown from a horse.

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He was in the hospital for at least two months, and while he was in intensive care,

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Jay and Mark came to visit him and Jay told Mark (when he didnt think Randy

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could hear them) that he did not think Randy was ever going to be the same so they

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should leave the band. Randy was heartbroken. Then came the news in September

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1970 that Jimi Hendrix died. These three events the accident, Jay and Mark

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leaving the group, and Jimis death, sent Randy into a serious tailspin of depression

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that took years for him to shake.

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Case No. 15-cv-03462 RGK (AGRx)
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Declaration of Janet Wolfe in Opposition to Defendants
Motion for Summary Judgment

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10.

I spoke with Randy several times over the years about Stainvay to

Heaven and the obvious similarity between that song and Taurus. The brother I

knew was a kind, gentle soul for whom the music - not the money - was everything.

Randy told me he knew that Jimmy Page had lifted his song from Taurus, and he felt

beleaguered by interviewers always asking him about it and people always telling

him he was crazy for not suing. I know he thought about it, our mother was pressing

him to sue, and before his tragic death

finally bringing a legal action though he feared it was too late.

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on~ ~91, he was planning on

Executed on March 4, 2016 at Ventura, California.

I declare under the penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.

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Declaration of Janet Wolfe in Opposition to Defendants'
Motion for Summary Judgment

Case No. 15-cv-03462 RGK (AGRx)