l

2
3
6
20
21
22
2
')
25
6
27
Louis Willacy (SBN 186356)
LOUIS WILLACY, ESQ
360 Grand Avenue, Suite 250
Oakland, California 94610
TEL: (415)
Fax: (415) 952-9310
louis@willacy.com
Attorney for Plaintiff
SIDNEY EARL SWANSON
UNITED STATES DISTRICT COURT
IF
CENTRAL ::CVT lFa:sANLO . 7 5 /
SIDNEY EARL SWANSON, vY"
an individual,
Plaintiff, COMPLAINT FOR COPYRIGHT
VS. INFRINGEMENT
MJJ PRODUCTIONS, INC., a California
corporation; SONY MUSIC HOLDINGS DEMAND FOR JURY TRIAL
INC., a Delaware corporation; TIMOTHY
ZACHERY MOSLEY, an individual; CORY
ROONEY, an individual; and DOES 1
through 10, inclusive,
Defendants.
Plaintiff SIDNEY EARL SWANSON, for his Complaint against Defendants, and each of
them, alleges as follows:
PARTIES
1. Plaintiff SIDNEY EARL SWANSON ("SWANSON") is an individual resident a
the State of California.
CUMPLAINT FOR COPYRIGHT INFRINGEMENT with DEMAND FOR JURY TRIAL

Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 1 of 12 Page ID #:11
d
a
i
l
y
m
i
c
h
a
e
l
1
2
3
5
6
7
8
10
11
12
l3
14
16
, ,
..:..!
18
20
21.
23
25
26
Defendant MJJ PRODUCTIONS, INC. ("MJJ PRODUCTIONS") is a corporatio
organized and existing under the laws of the State of California, with its principal place of
business located in North Hollywood, California, within this district.
Defendant SONY MUSIC HOLDINGS INC. dba SONY MUSIC
ENTERTAINMENT and/or EPIC RECORDS ("SONYtI) is a corporation organized and
existing under the laws of the State of Delaware, with its principal place of business located in
New York, New York.
4. Upon infonnation and belief, Defendant TIMOTHY ZACHERY MOSLEY
professionally known as TIMABALAND (tlTIMBALAND"), is an individual resident of the
State of California.
5. Upon infonnation and belief Defendant CORY ROONEY (tlROONEY"), whose
full name is Mark Rooney, is an individual resident of the State of New York.
6. The names, residences and capacities oftbe Defendants named herein as DOES 1
through 10 are unknown to Plaintiff at this time. Plaintiff is infornled and believes, and thereon
alleges, that each of the fictitiously named Defendants is in some way liable, jointly and
severally, to Plaintiff for the damages alleged herein, either together 'with, or independently of,
each other Defendant. At such time as the fictitiously named Defendants are identified, Plaintiff
will amend this Complaint to state each of their true names, capacities and residences.
7. At all material times, each Defendant acted as the agent andior principal of each
other Defendant and each is equally liable for the \Tongful acts of the other.
JURlSDICTION AND VENUE
8. Subject matter jurisdiction is invoked pursuant to 28 US.c. 1331 and 1338
because this action is based on federal copyright law.
_ ~ _
COMPLAINT FOR COPYRIGHT INFRINGEMENT with DEMAJ'm FOR JURY TRIAL
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 2 of 12 Page ID #:12
d
a
i
l
y
m
i
c
h
a
e
l
1
3
:to
::'2
::'3
14
...i.... f
20
23
25
9. Venue is proper in this district pursuant to 28 U.s.c. 1391(b)(2) because the
infringement occurred in this district and pursuant to 28 e.s.c. 1391 (b )(3) because at least one
defendant resides in this district.
GENERl\L AVERMENTS
10. Swanson is the owner of the copyright in the composition and sound recording
copyright entitled "Come Home On the Move" (the Infringed Composition") written by
SWANSON, U.S. Copyright Registration No. PAu0027l2187, dated September 11,2002.
Attached hereto as Exhibit "A" is a true and correct copy of the composition and sound recording
registration for the Infringed Composition.
1 L On or about May 2014, Defendants SONY and MJJ PRODCCTIONS released fo
sale and distribution the sound recording "Chicago," CDefendants' Sound Recording") featured
as the second track on Xscape, the posthumous album of famed singer-performer Michael
Jackson, which has achieved tremendous financial success.
12. Defendants TIMBALAND and ROONEY are two of the artists credited Virith
creating the Defendants' Sound Recording.
13. Defendants' Sound Recording is. and continuously has been since it was first
released, offered for sale in various media. It continues to this day to be offered for sale on CDs
and available for downloading from iTunes, Amazonmp3.com, eMusic.com as well as other
internet music providers. On information and belief, Defendants' Sound Recording still
generates substantial income for all Defendants at this time.
14. On information and belief, Defendants copied and incorporated substantial,
original ponions of the Infringed Composition in Defendants' Sound Recording. The portions 0
the Infringed Composition which have been copied into Defendants' Sound Recording are
COMPLAJ2\'T FOR COP\'RIGHT INFRINGEMENT with DEMA,",ND FOR JURY TRIAL
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 3 of 12 Page ID #:13
d
a
i
l
y
m
i
c
h
a
e
l
2
3
5
14
c
20
numerous. There is a substantial similarity bernreen the Infringed Composition and Defendants'
Sound Recording due to Defendants' copying.
15. Defendants' copying, duplication, use, perfonnance and exploitation of the
Infringed Composition in Defendants' Sound Recording constitute infringement of
SWANSON's copyright in the Infringed Composition.
FIRST f:LAIMFORRELIEF
COPYRIGHT INFRINGEMENT
16. Plaintiff repeats and incorporates by reference the allegations contained in
Paragraphs 1 through 15 above, as though fully set forth.
17. Plaintiff is, and at all material times hereto has been, the owner of the copyright in
the Infringed Composition and is entitled and authorized to protect his composition against
copyright infringement, including the enforcement of copyright actions. Plaintiff secured the
exclusive rights under .S.c. 106, among others, to "reproduce the copyrighted work in copies
or phonorecords," "to prepare derivative works based upon the copyrighted work," "to distribute
copies or phonorecords of the copyTighted work to the public by sale or other transfer of
o"Wllership, or by rental, lease, or lending," and to "perfonn the copyrighted work publicly."
18. Plaintiff did not authorize Defendants to copy, reproduce, perfoID1, or use the
Infringed Composition in Defendants' Sound Recording. or at all. Defendants did not seek or
obtain any permission, consent or license from Plaintiff for the copying, reproduction,
performance or use of the Infringed Composition in Defendants' Sound Recording or in any uses
thereof that were made or authorized by Defendants, or at all.
19. Defendants, and each of them., have infringed, and are continuing to infringe
upon, Plaintiffs copYTight in the hlfringed Composition by copyring, preparing a deri'vative
-4-
COl\1PLAI1\i FOR COPYRIGHI I1\TfRINGEMENT with DEMA.ND FOR JURY TRiAL
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 4 of 12 Page ID #:14
d
a
i
l
y
m
i
c
h
a
e
l
3
f
::'3
- I
20
21
25
2
work reproducing and using, and causing, contributing to, and participating in the unauthorized
copying, preparing a derivative work, reproduction and using, of the Infringed Composition in
Defendants' Sound Recording and causing the same to be publicly distributed in retail stores, on
the internet, by digital download and otherwise.
20. Defendants never paid Plaintiff for the use of the Infringed Composition.
21. Defendants have infringed on Plaintiff s exclusive rights by:
(a) Reproducing Plaintiffs copYlighted work in copies or phonorecords in
violation of 17 U.S.c. 106(1);
(b) Preparing derivative works based on Plaintiff s copyrighted work in violation
of 17 U.S.c. 106(2);
(c) Distributing copies or phonorecords of Plaintiff s copyrighted work and
derivative work to the public by sale or other transfer of ownership, or by
rental, lease, or lending in violation of 17 U.S.c. 106(3);
(d) Performing Plaintiffs copyTighted work or a derivative thereof publicly in
violation ofl7 U.S.c. 106(4); and
(e) Performing Plaintiffs copyrighted work and derivative work publicly by
means ofa digital audio transmission in violation of 17 USc. 106(6).
22. Defendants failed to properly attribute the authorship of Defendants' Sound
Recording to Plaintiff.
23. Defendants' acts of infringement were done, and now continue to be done with
knowledge that such actions constitute an infringement of Plaintiffs exclusive rights and are,
therefore, willful. At a minimum, Defendants acted in reckless disregard of Plaintiffs copyright.
_r:_
COMPLAINT FOR COPYRIGHT INFRINGEMENT with DEMAND FOR JURY TRIAL
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 5 of 12 Page ID #:15
d
a
i
l
y
m
i
c
h
a
e
l
3
4
5
6
8
12
:3
l8
1c:
20
21
24
26
27
24. Asaresultof theiractions, Defendants,andeachof them, are liableto Plaintiff
forwillfulcopyrightinfringementunder 17USc.501. Plaintiffsuffered,willcontinueto
sufferandis entitledtorecoverfromDefendant,substantialdamagetohisprofessional
reputationandgoodwill,aswellaslosses in anamountyetascertained, butwhichwillbe
determinedaccordingtoproof,pursuantto 17 U.s.c. 504(b). Inadditionto Plaintiffsactual
damages,Plaintiffis entitledto receivetheprofitsmadebyDefendantsfromtheirwrongfulacts,
pursuantto 17U.S.c. 504(b).
25. AsadirectandproximateresultofDefendants' infringement,Plaintiff has
incurredattorneys' fees andcosts. inanamountaccordingtoproof,whicharerecoverableunder
theprovisionsof17U.S.c. 505.
WHEREFORE,Plaintiff praysforjudgmentagainstDefendants,andeachof them,
jointlyandseverallyas follows:
1. Fordamagesinsuchamountasmaybefound, oras otherwisepermittedbylaw;
2. ForanaccountingofDefendants'profitsattributabletotheirinfringements of
Plaintiffs'copyrightintheInfringedComposition;
3. ForapreliminaryandpermanentinjunctionprohibitingDefendants,andtheir
respectiveagents, servants,employees,officers, successors,licenseesandassigns,
andallpersonsactinginconcertorparticipationwitheachoranyofthem,from
continuingto infringePlaintiffs'copyrightintheInfringedComposition;
4. ForPlaintiffs'attorneys' fees, costs, anddisbursementsinthis action; and
~ :
COMPLAINTFORCOPYRIGHTINFRINGEMENTv,'ith DEMANDFORJ1JRY TRIAL
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 6 of 12 Page ID #:16
d
a
i
l
y
m
i
c
h
a
e
l
5, ForsuchotherremediesunderthecopyrightlawsoillieUnitedStatesandiorasthe
Courtdeemsreasonableandjust.
~
I
I
1 \ \ ~ \
II
>j
LouisWillacy
'I
LOUIS WILLACY. ESQ,
!
360GrandAvenue.Suite250
Oakland. 94610
q (41 670-9400
I
I
Fax:(415)952-9310
I
le
I
Attorney for Plaintiff, Sidney Earl Swanson
--,
..L .)
Respectfullysubmitted,
FOR COP)'RIGllT JURY
! :
i
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 7 of 12 Page ID #:17
d
a
i
l
y
m
i
c
h
a
e
l
Attom:::-y for Plaintiff Sidney Earl Swanson
J E M A ~ D FOR JURY TRIA.L
Plaintiff, Sidney Swanson. hereby demands a trial by jury in the above matter.
. Dated: September 16.2014
COMPLAI:t\T HT wifh DEMAND FOR
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 8 of 12 Page ID #:18
d
a
i
l
y
m
i
c
h
a
e
l
9/1Q/2014 ' cocatalog.loc.gov/cgi-bin/Pwebracon.cgi
Type of Work: Music
Registration Number / Date:
PAu992712187 / 2992-99-11
Title: Songs by Sidney: vol. 1.
Description: compact disc.
Notes: Music only.
Copyright Claimant:
Sidney E. Swanson
Date of Creation: 1995
Rights and Permissions:
Rights &permissions info. on original appl. in C.O.
Variant title: Songs by Sidney: vol. 1
Names: Swanson, Sidney E.
================================================================================
htlp:l!cocatalog.loc,gov/cgi-bin/Pwebrecon.cgi 1/1
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 9 of 12 Page ID #:19
d
a
i
l
y
m
i
c
h
a
e
l
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
l. (a) PLAINTIFFS
( Check box if you are representing yourself
[
)
SIDNEY EARL SWANSON. an inciividual
(b)
County of Residence of First Listed Plaintiff
{EXCEPT IN U.S. PLAINTIFF CASES)
(c)
Attorneys
(Firm Name, Address and Telephone Number) lf you are
representing yourself, provide the same information.
Louis Wiilacy
(SBN
186356)
LOUIS WILLACY. ESO,
360 Grand Avenue, Suite 250, Oakland, CA 94610
Telephone: 4'l 5.67 0.94A0 Facsimile: 41 5.952.91'l 0
ll. BASIS OF JURISDICTION (Piace an X in one box only.)
ENDANTS ( Check box if you are representing yourself
E
)
SONY MUSIC HOLDINGS lNC., a Delaware corporation; MJJ PRODUC|IONS, lNC., a
falifornia corporation;TIMOTHY ZACHERY MOSLEY. an indiviciual: CORY ROONEY, an
individual:and DOES I throuqh 10, inclusive.
unty of Residence of First Listed Defendant
(IN
U.S. P#.INTIFF CASFS ONtY]
Attorneys (Firm
Name, Address and Telephone Number)
representing yourseif, provicie the same iltformation.
[l I. U.S. Government
U
Plaintiff
T-] 2. U.S. Government
L___t
Deiendant
pl 3. Federal Question
lU.S
Government Not a Party)
l-l
4. Diversity
(indicate
Citizenship
of Parties in ltpm lllt
l1l. CITIZENSHIP OF PRINCIPAL PARTIES-For Diversitv Cases onlv
(Place
an X in one box for plaintiff anci one for defendint)
PTF DEF PTF
-
"
lnaorooratpd or Prrn.rnal Pla.e
Lrirzenol thrs>ra1e
Ll
i
L-J
i
"tarli""".ii,.,ir;.;i:"
"--
LJ
4
CitizenofAnotherState
tr
2
[
2 incorooratedandprincipalpiace
n
5
DEF
!+
Ll5
Citizen or Sub.ject of a
Foreign Country
4. Reinstated oi'
Reopened
6. Multi-
--I Districi
!
Litrqation
of Business tn Another State
J-l: T
3
ForeiqnNation
f]
0
E
0
]V. ORIGIN
(Place
an X in one box only.)
1a1
1. Origrnal
T-1
2. Removed from
Tl
l3
Proceeciing
!
StateLoun
IJ
3- Remanded from
Appellate Coun
Ll
l----'l 5. Jransierred from Another
L--l Drsrrct (specifyl
V. REQUESTED IN COMPLAINT: JURY DEMAND
ffi
Yes
E
No
(Check "Yes" oniy if demanded in complaint.)
CLASS ACTION under F.R.Cv.P.23:
l-lYes No
I I
MONEY DEMANDED lN COMPLAINT: 5
proven attrial
VI.CAUSEOFACTION(CtetheU.S.Civil Siatuteunderwhichyouarefilingandwrateabrief statementof cause. Donotcirejurisdictional siatutesunlessdiversity.)
Copyright inf ringemen! under 17 U.5.C. 55 1 06 anci 501 baseci on Defenda nts' unauthorizeci use of Pla intifl's com position.
Vll. NATURE OF SUIT (Piace an X in one box only).
OTHER STATUTES CONTRACT REAL FEOPERTY.CONT. IMMIGRAT]ON PRISONER PETITIONS PROPERTY'RIGHTS
375 False Cialms Act
400 State
Reapponionmeni
41 0 Antirrust
430 Banks and Banking
450 Commerce/lCC
RateslErc.
460 Deportation
470 Racketeer lnflu--
enced & Corrupt Org.
480 Consumer Credit
490 Cable/SatTV
850 Securities/Com-
mod ities/Excha nge
890 Other Statutory
Actions
891 Agricultural Acts
893 Environmental
Matters
895 Freeciom ofinfo.
Act
896 Arbitration
899 Acimin. Procedures
Act/Review of Appeai of
Agency Decision
950 Constitutionality of
State Statutes
n
tr
I
n
n
I
n
tr
n
n
T
tr
tr
n
I
tr
tr
U
n
I
T
1 1 0 insurance
120 Marine
130 Miller Ac
140 Negotiable
instrument
150 Recovery of
Overpayment &
Enforcement of
judgment
'151
Medicare Act
'i52
Recovery of
Defaulied Student
Loan (Excl. Vet.)
I 5l HeCOVeTV Ol
Overpayment oi
Vet. Benefits
1 60 Stockholders'
Suits
190 Other
Contract
1 95 Contract
Product Liability
196 Franchise
n
x
T
T
tr
tr
T
n
f
240TonstoLand
-]
245 Tort Product
! .,,
Iral}lrlv
T-l 290 All Other Real
Pfanctr\/
-
462 Naturalrzation
U
Application
-
1(q nth6.
L-l
r*-*ioruiion n.tion,
Habeas Corpus:
463 Alien Derainee
510 Motions to Va.ar.
5entence
530 General
5:5 Death Penalty
u
n
T
T
820 Copyrighrs
830 Patent
840 Trademark
tr
T
T
TORTS SOCIALSECURITY
TORTS
PERSONAL INJURY
PERSONAL PROPERTY
L_l
8bi HIA (1395ff1
E
862 Black Lung (923)
n
863 Drwc/Drww (aos (g))
f
so+ ssto titte xvt
I
B6s RSr (405
{9))
T
n
I
x
370 Other Fraud
37 1 Truth in Lending
380 Other Personal
Properry Damage
385 Propefty Damagr
Product Liability
Othen
L_.1
l
T
u
tr
tr
tr
T
tr
L
J I U Arrplane
315 Airplane
Produ{t Liabiiity
320 Assaulr, Libel &
Siander
330 Fed. Employers'
Liabiliry
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
in,ury
362 Personal lnjury-
Med Maipratice
365 Personal injury-
Product Liability
367 Health Carel
Pharma.eutical
Personal injury
Prociuct Liability
368 Asbesros
.Lu:'ffl?r,'31:l*., f
u
I
I
n
540 Mandamus/Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee
Conditions of
fnrtfinaman+
tr
u
T
tr
FEDEBALT'AX SUITS
BANKRUPTCY
-
870Taxes [U.S. Piarntiff or
LJ
Defendantr
-
871 lRS-Thrrd Part\,26 USC
) zaos
11
422 Appeal23
U
USC 158
n 4]3 Withdrawal 28
tt,,^----
!
u)L 15,
FORFEITURE/PENALTY
-
625 Drug Related
L-J Serzure of Propefty 21
USC 881
f
oeootirer
CIYIL BIGHTS
I
440OtherCivilRights
I
441 Voring
[
442 Empioyment
11
443 Housrngr
!
Accommodations
445 American with
I
Disabilirles-
Emoioyment
-
446 American with
L--]
Drsabilrtres otner
El44CF'grioE
LABOR
rr 7'10 Fair LaborStandards
!
Act
T.l
720 Labor/Mgmt.
-
Relatrons
I
z+o Railway Labor Aci
;1
751 Family and Medicai
LJ
LeaveAci
-
790 Other Labor
L-J
1111631q3p
;-
Z9t- Emoloyee Ret. r*..
l)
/[41y17e aa-1r- I
REAL FROPERTY
n
r
Conciemnation
220 Foreciosure
230 Rent Lease &
Eiectment z,-J\
T
Y
FOR OFFICE USE ONLY: Case Numbe:r
cv-71 106114\ ctvtL covER si-{EEi Page 1 of 3
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 10 of 12 Page ID #:20
d
a
i
l
y
m
i
c
h
a
e
l
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVlL COVER SHEET
Vlll. VENUE: Youranswerstothequestionsbelowwill determinethedivisionoftheCourttowhichthiscasewillbeinitialiyassigned.
Thisinitial assignmentissubject
to change, in accordance with the Court's General Orders, upon review by the Court of your Compiaint or Notice of Removal.
QUESTION A: Was this case removed
from state court?
I
ves
I
tito
lf ''no, '' skip to Question B. lf "yes,'' check the
box to the right that appiies, enter the
corresponding division in response to
Question E, beiow, and continue from there.
SIATE CASE WAs PENDING IN THE COUNTY OF: ,NITIAL]DIVISION IN CACD IS:
!
Los Angeles, Ventura, Santa Barbara, or San Luis Obispo Western
I
Orange
Southern
I
Riverside or San Bernardino
Eastern
QUESTION B: ls the United States, or
one of its agencies or employees, a
PLAINTIFF in this action?
lf "no, '' skip to Question C. lf
''yes,"
answer
Question 8.1, at right-
x
No Yes
tr
8,1 , Do Soozir or more of the defendants who reside in
the district reside in Orange Co.?
checkoneoithe boxestothetight +
YES. Your case will initially be assigned to the Southern Division.
I
Enter "southern" in response to Question E, below, and continue
from there.
-
^,^
.^--.-.
L__..1
r\v, LUnLil tu= LU vuc5LluIl D-z
8.2, Do 500/b or more of the defendants who reside in
the district reside in Riverside and/or San Bernardino
Counties?
(Considerthe
two counties tooether.)
check one of the boxes to the riaht
r+
YES- Your case will initially be assigned to the Eastern Divisron.
f
Enter''Eastern" in response toQuestion E, below,and continue
from there.
NO. Your case wili initially t e assigned to the Western Dlvislon.
I
Enter "Western" in response to Question E, below, and continue
from there.
QUESTIOI'i C: ls the United States,
one of its agencies or employees, a
DEFENDANT in this action?
If "no, '' skip to Question D. lf "yes," answer
Question C.1, at right.
No
tr
Yes
n
C.I. Do 50oza or more of the piaintiffs who reside in the
district reside in Oran.-qe Co.?
checkoneoftheboxestotheright +
YES, Your case will initiaiiy be assigned to the Southern Division.
!
Enter"southern" in responsetoQuestion E, below.and continue
from there.
T
NO. Continue to Ouestion C-2.
C.2. Do 50oi or more of the plaintiffs who reside in the
district resicie in Riverside and/or San Bernardino
Counties?
(Consider
the two counties together.)
checkone ofthe boxes tothe right +
YES. Your case will intially be assigned to the Eastern Divisron.
!
Enter "Eastern" in response to Question E, beiow, and continue
from there.
NO. Your case will initially be assigned to tne Western Drvrsron.
f
Enter "Western" in response to Question E, below, and continue
irom there.
QUESTION
D: rlocation of plaintiffs and defendants?
A.
Orange County
8,,
Riverside or,San
6ernarorno Lountv
c.
Los Angeles; Ventura,
5anta tsarbara. or 5an
Luis Obispo Countl,
lndicate the location(s) in which 50cc oI rnorc o{ plainti{{s who residz rn this dtswct
reside.
(Check
up to two boxes, or leave blank if none of these choices apply.) l tr T
lndicate the location(s) in which 500/b or more of defendants who resicje in this
dlsrricr reside. (Check
up to two boxes, or ieave blank if none of these choices
appiv.)
n T tr
D.1. ls there at least one answer in Column A?
fves Eruo
lf ''yes," your case will initialiy be assigned to the
SOUTHERN DIVISION.
Enter "Southern" in response to Question E, below, and continue from there.
lf "no," oo to question D2 to the right.
r+
D.2. ls there at least one answer in Column B?
ffives Iruo
lf "yes,'' your case will initialiy be assigned to the
EASTERN DIVISION.
Enter "Eastern" in response to Question E, below.
lf "no," your case wiil be assigned to the WESTERN DIVISION.
Enter "Western" in response to Question E, belou,-
+
QUESTION;E: lnitial Division? INITIAL DIVISION IN CACD
Enter the initial division determined by Question A, B, C, or D above:
*
EASTERN
QUESTION F: Northern Counties?
Do 50ozb or more of piaintifis or defendanis in this district resicie in Venture, Santa Barbara, or San Luis Obispo counties?
[
Ves
E
ruo
cv-71 to6/141 CIVIL COVER SHEET
Page 2 of 3
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 11 of 12 Page ID #:21
d
a
i
l
y
m
i
c
h
a
e
l
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
lX{a). IDENTICAL CASES: Has this action been prevlously filed in this court?
lf yes, iist case numbe(s):
ENO T
YES
IX(b). RELATED CASES: ls this case related (as defined below) to any cases previousiy filed in this court?
ENO T
YES
lf yes, list case number(s)
Civil cases are reiated when they:
!
A. Arise from the same or ciosely related transactions, happening, or event;
I
B. Call for determination of the same or substantially related or simiiar questions of iaw and fact; or
I
C. Eor other reasons would entail substantial duplication of iabor if heard by different
judges.
Check all boxes that appiy. That cases may involve the same patent, trademark, or copyright is not, in itself, sufficient to deem cases
related.
X, SIGNATURE OF ATTORNEY
{OR
SELF-REPRESENTED LITIGANT}:
IJ
U LL+c DATE: September 16,2014
Noticeto Counseii'Parties: The submission of this CivilCover Sheet is required by Local Ruie 3-i. This
neither repiaces nor supplements the fiiing and seruice. of pleadings or other papers as required by law,
more detailed instructions, see separate instruction sheet
(CV-071A).
Form CV-71 and the information contained herein
except as provided by local rules of cou11. For
Key to Statistical codes reiating to Sociai Security Cases
Nature of Suit Code Abbreviation
861 HIA
a62
863
853
865
BL
DIWC
Substantive Statemnt of Cause of Action
All claimsforhealthinsurancebenefits(Medicare) underTitlelS,PartA,oftheSocial Securin/Act,asamended. Alsc,
include ciaims by hospitais, skilled nursing facilities, etc., for certif lcation as providers of services under the program.
(42 U.S.C. 1e35FF(b))
All claims for "Biack Lung" benefits under Title 4, Part B, of the Fecierai Coal Mine Health and Safety Act oi I969. {30 U.S.C.
All claims fiied by insured workers for disability insurance benefits under Titie 2 of the Social Security Act, as amended; plus
ali claims filed ior chiid's insuran.e benefits based on ciisabiihy. (42 U.S.C, 405 (g))
All claims filed for widows or widowers inJurance benefits baseC on disabilitv under Title 2 of the Social Security Act, as
amencied. (a2 U.S.C. a05 ig))
All claims for supplemenialsecurity income payments based upon disability filed underTitle 16 of th Social Security Act, as
amended.
All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended.
(42 U.S.C.405 (g)l
RSI
SSID 864
cv-71 l06/14)
CIvIL COVER SHEET Page 3 of 3
Case 5:14-cv-01975-MMM-DTB Document 1 Filed 09/23/14 Page 12 of 12 Page ID #:22
d
a
i
l
y
m
i
c
h
a
e
l