Professional Documents
Culture Documents
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ANTHONY
PLANT, JOHN PAUL JO
WARNETVCHAPPELL
MUSIC, INC., SUPER HYPE
ATLANTIC RECORD ING CORP
ENTERTAINMENT COMPANY
MUSIC GROUP CORP.
Helene Freeman. Esq.. admitted oro hac vice
E-Mail : hfreernnlbhittipsnizei.com
PHILIPS NIZER LI,P
666 Fifth Avenue
New York, NY 10103-0084
Tel: (212\ 977-9700
Fax: 12ll\ 262-5152
Attorhev for De fendants
JAMES PATRICK PAGE, ROBERT ANTHONY
PLANT and JOHN PAUL JONES
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WESTERN DIVISION
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Plaintit
vs.
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Defendants.
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DECLARATION OF JAMES
PATRICK PAGE IN SUPPORT OF
MOTION FOR SUMMARY
JUDGMENT OR, IN THE
ALTERNATIVE, PARTIAL
SUMMARY JUDGMENT
Date: March 28,2016
Time: 9:00 a.m.
Courtroom of the Honorable
R. Garv Klausner
United Stats District Judge
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I, along with Robert Plant, John Paul Jones and the late John Bonham,
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in
1968.
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cornplexity and speed culminating in a guitar solo that was preceded by a distinct
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fanfare, followed by the last verse concluding a climax to the song. Robert Plant
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created the lyrics tlor Stairway to Heaven after my initial composition of the music,
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when the song was worked on by the band members of Led Zeppelin
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January 1971 in London, England, and first performed by Led Zeppelin in March
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created in early
in
1970 in
1970 to
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irway to Heaven
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1971.
line.
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consider descending chromatic lines and arpeggiated ohords basic skills learned by
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chromatic lines and arpeggios long before 1968. For example, in 1960, I arranged for
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a friend, Chris Farlowe, and his band the Thunderbirds to record a demo of
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composition Spring is Near along with other material.. Chris Farlowe did get
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pressing of the demo and provided it to my counsel for production in this case. The
played an ascending
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in 1960, is a guitar
playing a descending
Before 1968, I also was familiar with other songs that included
descending line, such as songs by the Beatles and Cry Me a River by Davey Graharn.
Also, in 1964 a studio musician, Joe Moretti, introduced me to the song Chim Chm
Chiree and I liked the idea of music going at counterpoint and I used that and similar
ideas
descending chromatic line over which there is also an ascending line, so that the music
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Cartoone for their album of the same name. That album includes a song titled /ce
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of
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music and am absolutely certain that I never heard Taurus until 2014.
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line.
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Led Zeppelin and the band Spirit never performed together and were
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available to rne, the only occasions when Led Zeppelin performed at the same venue
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on the same date on which Spirit was scheduled to perform were: the Auditorium
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Arena in Denver, Colorado, on December 26, 1968, the Atlanta International Pop
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Festival at the Atlanta Speedway in Atlanta, Georgia, on July 5, 1969 and the Seattle
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events
were outdoor festivals over two or three days with approximately 20 to 40 bands or
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Colorado, the day after Christmas in 1968. I understand that Spirit also performed
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14. Generally, in my experience, when bands played on the same bill, each
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band or performer used their own guitars, amplifiers, keyboards, drums and other
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dismantle and remove their equipment, and that generally took anywhere from
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In rny experience, the set-up interval between bands meant that we did
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16. I understand Mark Andes testified that he was introduced to the members
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of Led Zeppelin at the concert in Denver in 1968 by Toby Roberts, who he stated had
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Roberts, did not lease a plane from hirn and to the best of my knowledge he was not
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involved in our tour. Led Zeppelin did not lease an airplane for use in touring until
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December 1968, Led Zeppelin performed live concerts in England and Scandinavia
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Garbage. I had heard Fresh Garbage on the radio in England before Led Zeppelin
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I Have You as a
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before LedZeppelin was formed, while I was a member of the Yardbirds. I purchased
the Sonic Wave after Jeff Beck told me that Brian Wilson used a Theremin in the 1966
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I have several
I purchased, albums people gave me and albums that were simply left at my
albums
home. Also, like a book collector who never gets around to reading books they
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album in my record collection. I had not previously seen it in my collection and do not
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know how or when it got there. It may well have been left by a guest. I doubt it was
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there for long, since I never noticed it before. But, again, I know I did not hear Taurus
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until 2014.
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In the over four decades since the l97I release of Led Zeppelin IV and
Stairway to Heaven, documents have been lost or stolen. For example, portions of the
made at Headley
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Grange in 1970 are gone. They were stolen from my home at some time in the 1980's,
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and in later years copies of the stolen recordings have turned up for sale on bootleg
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recordings. I have had to purchase bootleg recordings in order to try to recover what
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However, other recordings remain missing, and with the passage of time documents,
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such as concert contracts, set lists, and travel documentation, have been lost or
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discarded.
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Also, and unfortunately, rnany people have passed away since 197l,
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including John Bonham, who died in 1980, Peter Grant (Led Zeppelin's personal
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of its concerts) in
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f dcolre undor pcnalty of perjury undor tho laws of the Unitd Statcs of
Amcisa tbat thc fortgoing is ile aud corroct. Exoflted on Febnrary 24,20t6.
JAMES P
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