IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

MICHAEL SKIDMORE, as Trustee for the
RANDY CRAIG WOLFE TRUST,

Plaintiff

v.

LED ZEPPELIN, J AMES PATRICK
PAGE, ROBERT ANTHONY PLANT,
J OHN PAUL J ONES, SUPER HYPE
PUBLISHING, INC., WARNER MUSIC
GROUP CORP.

Parent of:

WARNER/CHAPPELL MUSIC, INC.,
ATLANTIC RECORDING
CORPORATION, RHINO
ENTERTAINMENT COMPANY,

Defendants

:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:



No. 14-cv-3089

DEFENDANTS REQUEST FOR JUDICIAL NOTICE
IN SUPPORT OF MOTIONS TO DISMISS OR TRANSFER
DIRECTED TO PLAINTIFFS AMENDED COMPLAINT

Pursuant to Federal Rule of Evidence 201 and in connection with their pending motions to
dismiss or transfer, defendants J ames Patrick Page, Robert Anthony Plant, J ohn Paul J ones, Super
Hype Publishing, Inc., Warner Music Group Corp., Warner/Chappell Music, Inc., Atlantic
Recording Corporation and Rhino Entertainment Company, by and through their undersigned
counsel, respectfully request that the Court take judicial notice of the following in connection
with their Motions to Dismiss or Transfer directed to plaintiffs Amended Complaint:
1. The docket in Conservatorship of Randy Craig Wolfe, Superior Court of
the State of California, County of Ventura, Case No. P072493, a true and correct copy of
which proceedings docket is attached hereto as Exhibit 1 and accessible on that
Case 2:14-cv-03089-JS Document 37 Filed 10/27/14 Page 1 of 4
2
California Courts Internet website by searching for the foregoing case number at
http://www.ventura.courts.ca.gov/via.html, last accessed on September 9, 2014.
2. The U.S. District Court J udicial Caseload Profiles for the United States
District Court for the Eastern District of Pennsylvania and the United States District Court
for the Central District of California, attached hereto as Exhibit 2 and accessible at
http://www.uscourts.gov/viewer.aspx?doc=/uscourts/Statistics/FederalCourtManagement
Statistics/2014/district-fcms-profiles-march-2014.pdf&page=68, last accessed on Sep-
tember 9, 2014.
Good cause exists for the Court taking judicial notice of the foregoing.
As to the California proceeding Conservatorship of Randy Craig Wolfe, plaintiff sues on
behalf of the Randy Craig Wolfe Trust, which plaintiff alleges was established by Bernice C.
Pearl, the mother of Randy Craig Wolfe, as conservator of his estate by court order on February
19, 2002. Am. Complaint at 12, 60 & 62. Exhibit 1 is a copy of the docket in that California
Superior Court action and includes as docket entry 97 a February 19, 2002 order for the creation
of a trust. Courts properly take judicial notice of other courts dockets. See, e.g., Wilson v.
McVey, 579 F. Supp. 2d 685, 688 n. 5 (M.D. Pa. 2008).
As to the U.S. District Court J udicial Caseload Profiles attached as Exhibit 2, these
documents, provided by the Administrative Office of the U.S. Courts on behalf of the Federal
J udiciary, summarize the caseload of this District Court and the District Court for the Central District
of California. Courts properly take judicial notice of reports published by government agencies and
publicly available on their Internet websites. See, e.g., Anspach v. City of Philadelphia, Dept of
Pub. Health, 503 F.3d 256, 273 n. 11 (3d Cir. 2007) (taking judicial notice of an announcement
made by a Commission of the FDA published in the Federal Register); Pension Benefit Guar.
Case 2:14-cv-03089-JS Document 37 Filed 10/27/14 Page 2 of 4
3
Corp. v. White Consol. Indus., Inc., 998 F.2d 1192, 1197 (3d Cir. 1993) (public records include
published reports of administrative agencies).
Accordingly, defendants respectfully request that the Court take judicial notice of
Exhibits 1 and 2.
Respectfully submitted,

FOX ROTHSCHILD LLP

/s/ Michael Eidel
Michael Eidel, Esquire
2000 Market Street, 20th Floor
Philadelphia, 19103
(215) 918-3568
(215) 345-7507 (facsimile)

Local Counsel for Defendants


PHILIPS NIZER LLP

/s/ Helene Freeman
Helene Freeman, Esquire
666 Fifth Avenue
New York, NY 10103-0084
(212) 977-9700
(212) 262-5152 (facsimile)

Attorney for the Individual Defendants
Admitted Pro Hac Vice










Dated: October 27, 2014
LAW OFFICES OF PETER J. ANDERSON P.C.

/s/ Peter J . Anderson
Peter J . Anderson, Esquire
100 Wilshire Boulevard, Suite 2010
Santa Monica, CA 90401
(310) 260-6030
(310) 260-6040 (facsimile)

Attorney for the Warner Defendants
Admitted Pro Hac Vice

Case 2:14-cv-03089-JS Document 37 Filed 10/27/14 Page 3 of 4
4
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing Defendants Request for
J udicial Notice in Support of Motions to Dismiss or Transfer Directed to Plaintiffs Amended
Complaint, was served upon counsel for Plaintiff via the Courts ECF filing system.


/s/ Matthew S. Olesh
Matthew S. Olesh, Esquire
Dated: October 27, 2014


Case 2:14-cv-03089-JS Document 37 Filed 10/27/14 Page 4 of 4