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GREENBERG TRAURIG, LLP
VINCENT H. CHIEFFO (SBN 49069)
E-Mail: ChieffoV@gtlaw.com
NINA D. BOYAJIAN (SBN 246415)
E-Mail: BoyajianN@gtlaw.com
2450 Colorado Avenue, Suite 400E
Santa Monica, CA 90404-5524
Telephone: 310-586-7700
Facsimile: 310-586-7800

Attorneys for Plaintiffs John G. Branca and John
McClain, Special Administrators of the Estate of
Michael J. Jackson; Triumph International, Inc.

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION
JOHN G. BRANCA, Special
Administrator of the Estate of Michael J.
Jackson; JOHN MCCLAIN, Special
Administrator of the Estate of Michael J.
Jackson; TRIUMPH INTERNATIONAL,
INC., a California corporation,

Plaintiffs,
vs.
HEAL THE WORLD FOUNDATION, a
California corporation; UNITED FLEET,
a California corporation; and DOES 1-10,
inclusive,

Defendants.
CASE NO. CV-09-07084 DMG (PLAx)


PLAINTIFFS WITNESS STATEMENT
OF KAREN LANGFORD




Trial Date: April 19, 2011



Complaint Filed: September 29, 2009
Hon. Dolly M. Gee

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Pursuant to Local Rule 43-1 and this Courts order, Plaintiffs submit the
following witness statement of Karen Langford.


























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PLAINTIFFS WITNESS STATEMENT OF KAREN LANGFORD
I, Karen Langford, submit the following as my direct testimony at the trial of
this matter.
1. I am a paralegal at the law firm of Ziffren Brittenham, LLP (Ziffren). I
have been working at Ziffren for 29 years as a paralegal. During my time at Ziffren, I
worked extensively on Michael J. Jacksons legal matters and am very familiar with his
work, including his charitable efforts and in particular his Heal the World Foundation
(Jacksons Foundation). Since Mr. Jacksons passing, I have been working closely
with the Co-Executors of the Estate.
2. Michael Jackson was one of the most commercially successful entertainers
of all time prior to his untimely death on June 25, 2009.
3. After making his debut as a member of The Jackson 5, Mr. Jackson
embarked on a highly successful solo career and both his life and tragic death have been
the subject of constant media attention for over four and a half decades.
4. Mr. Jacksons 1982 album Thriller remains the best-selling album of all
time, and his other albums are also among some of the most successful albums. The
single Thriller was adapted into a highly successful music video, known
independently as Michael Jacksons Thriller. The video was immediately popular
and received high critical acclaim, being nominated for six MTV Video Music Awards
in 1984 and winning three. In 2009 it was added to the National Film Registry by the
Library of Congress, the only music video that has received this distinction to date.
5. Mr. Jacksons song Man in the Mirror, peaked at number one in the
United States when released as a single in early 1988 off his seventh solo album, Bad.
It is one of Mr. Jacksons most critically acclaimed songs and it was nominated for
Record of the Year at the Grammy Awards. The song topped the Billboard Hot 100 for
two weeks. The song peaked at number 21 in the UK Singles Charts in 1988, but in
2009, following Mr. Jacksons death, the song peaked at number two, and also became
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the No. 1 single in iTunes downloads in the U.S. and the U.K. The song includes the
well-known refrain, Make that Change.
6. Neverland Valley Ranch, or Neverland as it is popularly referred to, was
the home of Mr. Jackson from 1988 to 2005.
7. As a result of his talent and remarkable success, Mr. Jackson came to be
known as the King of Pop. Mr. Jackson acquired this nickname when actress and
friend Elizabeth Taylor presented Mr. Jackson with an Artist of the Decade award at
the 1989 Soul Train Awards, proclaiming him the true king of pop, rock and soul.
Since that time, major media outlets and Mr. Jackson himself have marketed Mr.
Jackson as the King of Pop. In 2008, in celebration of Mr. Jacksons 50th birthday, a
compilation album, entitled King of Pop was released. Currently the album has sold
in excess of 3 million worldwide and reached the top ten in the majority of countries in
which it was released.
8. In March 2009, Mr. Jackson announced the This Is It tour, a planned
series of fifty concerts by Michael Jackson to be held at The O2 Arena in London. The
concerts, promoted by AEG Live were scheduled to begin in July 2009 and continue
through to March 2010. The shows were to be Mr. Jacksons first major series of
concerts since the HIStory World Tour finished in 1997, and had been cited as one of
the years most important musical events. Originally only 10 concerts were announced,
but the tickets were sold out in less than an hour and the public demand for tickets
resulted in 40 more concerts being added, resulting in 50 concerts in total. Ticket sales
broke several records.
9. Early in June 2009, Mr. Jackson approved a line of official merchandise
for the This Is It tour. The merchandise was to be manufactured and distributed
exclusively through Bravado International Group Merchandising Services, Inc.
(Bravado).
10. Mr. Jackson died on June 25, 2009.
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11. The film Michael Jacksons This Is It, released on October 28, 2009,
documents Michael Jacksons rehearsals and preparation for the This Is It concert
series which was canceled due to his death eighteen days prior to the first scheduled
performance date. The film consists of Mr. Jackson rehearsing musical numbers and
directing his team, and additional behind the scenes footage including dancer auditions
and costume design. The film is now the highest worldwide grossing concert/music
documentary in the history of cinema.
12. In August 2009, Bravado entered into an agreement with the Estate to be
the exclusive manufacturer and distributor of merchandise for Michael Jackson. The
extensive collection of merchandise, which is the only official line of Michael Jackson
merchandise available to the public, includes items created in collaboration with the late
entertainer. It is available worldwide through MichaelJacksonMerch.com and
michaeljackson.shop.bravadousa.com, as well as through authorized retailers.
13. Bravado has sued dozens of merchants and retailers for selling
unauthorized, bootlegged merchandise using Michael Jackson related trademarks and
copyrights, as well as for unauthorized exploitation of Mr. Jacksons name, image, and
likeness.
14. After his death, Mr. Jackson became the best-selling artist of 2009 in the
United States selling over 8.2 million albums, and sold 35 million albums worldwide in
the 12 months that followed his death.
15. On February 24, 2010, Sony Music Entertainment signed a new deal with
the Estate to extend their distribution rights to Mr. Jacksons back catalogue until at
least 2017, as well as to obtain permission to release ten new albums including both
previously unreleased material and new collections of released work. On November 4,
2010 Sony announced the release of Michael, the first posthumous album which was
released on December 14, 2010 with the promotional teaser single streamed
exclusively on MichaelJackson.com on November 8, entitled Breaking News, and the
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first single released to radio on November 15, 2010, Hold My Hand (a duet with
Akon).
16. On November 3, 2010, Cirque du Soleil announced that it would launch
Michael Jackson: The Immortal World Tour in October 2011 in Montreal. The 90-
minute $57 million production will combine Mr. Jacksons iconic musical style and
choreography with the Cirques signature artistry, dance and aerial displays. A second
collaboration by the Estate and Cirque du Soleil is a permanent show which will reside
in Las Vegas and will open in 2013.
17. Prior to Mr. Jacksons death, he entered into worldwide merchandising
agreements with Signatures Network (formerly Sony Signatures), MJ Net
Entertainment AG, and MJ Licensing LLC, and with AEG Live, LLC with respect to
his 2009 planned This Is It Tour that was cancelled as a result of his untimely death
in late June 2009.
18. In addition to his success as a musician and performer, Mr. Jackson was
also a notable philanthropist and humanitarian who donated and raised millions of
dollars to support of dozens of charities and his own Heal the World Foundation.
19. Mr. Jackson founded the Heal the World Foundation (Jacksons
Foundation) in 1991. Jacksons Foundation was registered as a non-profit corporation
in 1991. Trial Exhibits 34, 35, 58.
20. Jacksons Foundation was named after his hit song, Heal the World,
which he wrote and composed. The song reached #2 in the UK Singles Chart in
December 1992, and reached #27 on the Billboard Hot 100. In a 2001 Internet chat
with fans, Jackson said Heal the World is the song he is most proud to have created.
21. The song Heal the World was so identified with Mr. Jackson that it was
performed as the closing to Mr. Jacksons memorial service at the Staples Center in Los
Angeles on July 7, 2009. An ensemble of performers, including members of Mr.
Jacksons family, paid tribute to Mr. Jackson by singing this song. Mr. Jacksons
memorial service was viewed live by millions around the world, and millions more
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have since watched the memorial service, including the performance of Heal the
World.
22. The purpose of Jacksons Foundation was to provide medicine to children
and fight world hunger, homelessness, child exploitation and abuse. Mr. Jackson raised
millions of dollars for his Heal the World Foundation by aggressively publicizing
Jacksons Foundation and its goals. For example, profits from The Dangerous World
Tour, during which Mr. Jackson performed concerts for millions of people around the
world, were donated to Jacksons Foundation.
23. Mr. Jackson also performed his song Heal the World during the halftime
show at the Super Bowl XXVII, one of the most viewed events on television. Mr.
Jackson donated his entire fee to his charity, with the NFL also donating $100,000 and
a 30-second advertisement requesting contributions. Other efforts by Mr. Jackson to
raise awareness and funds for Jacksons Foundation are numerous and well-publicized.
24. While Jacksons Foundation is no longer active, as a result of its
worldwide success in raising awareness and money for childrens causes, Heal the
World is a phrase that continues to invoke Mr. Jackson, Mr. Jacksons Heal the World
charity, song, and commitment to improving the lives of children around the world.
25. One consequence of the confusion caused by Defendant HTWF and Ms.
Johnsons activities is that bootleggers offering for sale and selling unauthorized
Michael Jackson branded merchandise advertise their infringing products by claiming
that proceeds from the sale of the merchandise benefit Michael Jacksons Heal the
World Foundation. Trial Exhibit 352.
26. Further evidence of confusion caused by Defendants is demonstrated by a
Facebook page for International Micheal [sic] Jackson Day! that encourages users to
donate money to Defendant HTWF. Trial Exhibit 324.
27. Howard Mann, who is also being sued by the Estate and is a business
partner of Defendants, also promoted an event he hosted with an advertisement bearing
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Mr. Jackson's
image and stating that proceeds from the event would benqfit Heal the
'World
Foundation. Ttial Exhibit 373,
I declare under penalty ofperjury that the foregoing is true and colrect'
Executed at
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GREENBERGTRAURIG, LLP
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VINCENTH. CHIEFFO
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Attomevs for Plaintiffs John G. Branca and John
Mclai, Special Administrators of the Estt of
Michael J. Jackson; Triumph International, Inc.
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