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,. ..

I' t;
.- !4--
199-Summona without Notice, Supreme Court. 10-73
Personal Service.
COPYRIGHT 197.:J DY JULIUS BLU MDERG, INC . • LA W BLAN K PUOLISftERS
BO EXCHANGE PL. AT BRO A DWA Y, N, Y. C. 10004

&uprrmr <irnurt nf tltt ~tatt nf N:ew Wnrk


--1.mi_ex No.
' <irnuitty nf -.. .._
CBS DIC.
SPECIAL RUSH
Plaintifl
against

_k.J • .. wau. . doiag buaineaa


as •DfLiii A I~· -
.... -
Plaintiff resides at

l W..t 52nd Street


Defendant
County of uew York
To the above named DefendanA.J • WBBBRMAH S.

I.nu ar.e 11.er.ehy sumu111u.eh to answer the complaint in this action and to serve
a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
appearance, on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive
of the day of service (or within JO days after the service is complete if this summons i.s not personally
delivered to you within the State of New York) ,· and in case of your failure to appear or answer, juflg-
ment will be taken against you by default for the relief demanded in the complaint.
Dated,
Donald E. Biedezman
Defendant's address :
Attorney(s) for Plaintiff
6 Bleek•r Str~
New York, ew York
Post ODice Address
5l. wast S.2nd str-t
t.ov York, New York 10019

L
... ~ .. Affidavit of Service
Index No.
State of New York, County of SS.:
Supreme Court of the State of New York
b-.
' .
bein?;I; duly sworn, deposes and says ; that deponent is not
County of
a party to the action, is over 18 years of age and resides
; at
That on 19 at No.

Plaintifi
deponent served the within summons a11d complaint on
against
defendant

ltlDIV IDUAL by delivering a true copy of each to said de·


fendant personally; deponent knew the person
i. 0 so served to be the person described as said
Defendant
defendant therein.
~ummnn!l
CORPORATION a corporation,
by delivering thereat a true copy of each to
ACTION NOT BASED UPON
2. D CONSUMER CREDIT TRANSAC'.f ION

personally, deponent knew said corporation so


served to he the corporation described in said
summons as said defendant and knew said
individual to be Attorney(s) for Plaintifl
t11ereof

Sll'ITABLE by delivering thereat a true copy of each to Oflice, Post Oflice Address and Tel. No.
AGE PERSON

3.0 a person of suitable


age and discretion. Said premises is defen-
dant's - actual place of husines - dwelling
house-usual place of abode-within the state.
DESCRIPTION
AFFIX ING TO by affixing a true copy of each to the door of USE WITH Deponent describes the individual served
DOOR, ETC. said premises, which is defendant's - actual 1 or 3 O as follows: sex: 0 male 0 female;
4. 0 place of business-dwelling house- usual place
of abode-within the state. Deponent was un- 0 White Skin 0 Under 5' 0 Under 100 Lbs.
able, with due diligence to find defendant or 0 Black Skin 0 5' O" - 5' 3" 0 100 - 130 Lbs.
a person of suitable age and discretion, thereat, 0 Yellow Skin 0 5' 4" - 5' 8" 0 131 - 160 Lbs.
having called there
0 Brown Skin 0 5' 9" - 6' O" 0 161 - 200 Lbs.
0 Red Skin 0 Over 6' 0 Over 200 Lbs.

0 Black Hair 0 14-20Yrs.


0 Brown Hair 0 21-35 Yrs.
O Blond Hair 0 36 - 50 Yrs.
O Gray Hair 0 51-65 Yrs.
O Red Hair 0 Over 65 Yrs.
O White Hair
MAILING Deponent also enclosed a copy of same in a
O Balding
USE WITH
3 or 4
postpaid sealed wrapper properly addressed to Other identifying features:
defendant at defendant's last known residence,
D at

and deposited said wrapper in- a post office-


oflicial depository under exclusive care and
custody of the United States Postal Service --··················-·······················
within New York State. Sworn to before me on
NOTICE OF ENTRY
Ymlex No. Year 19
I• w

SUPREME COURT
Sir:- P lea..,e take n otice that the within is a (ce rt ified) •
true copy of a
STATE OF NEW YORK
duly entered in the office of the clerk of the within
COUNTY OF NEW YORK
named court on 19
CBS INC.,
Dated ,
P l aintiff
Yours, etc.,
-against-
Attorney fo r
A. J . WEBERMAN,
Of/ice a11d P ost O ffice Address
doing bus i ness as
"DYLAN ARCHIVES" ,

Defendant
To

Attorney(s) for
SUM.MONS AND
I
!• NOT ICE O F SETT LE M ENT VERIFIED COMPLAINT
Sir: -Please take notice that an or der

of which the within is a true cop y will be p resented Donald E . Biederman


for settlement to the Hon.
A ttorney for Plaintiff
one of the judges of the within named Court, at Of/ice a11d Post Office A d d ress, Tclep honz
51 West 52nd Street
New York, New York 10 019
on th e day of 19
at M. (212)765 - 5431 X4 2 64
Dated,
To
Yours, etc.,

Attorney(s) fo r I
Arrorncy f or

Office and Post O ffice Address Service of a copy of the within

Dated,
is here by admitted.
I
., ...
To

.' } Attorne!{(t1' for


Attor ney(s) fo r

1.
1 900-© tG73, .JUL I U• OLUMU C AG , INC . , 8 0 E X CHA NG C PLACE , N . y , 4
= 1117:S .JULIUS llLUMlllORCi, INC.

S.TATE 0.F NEW YORK, COUNTY OF SS. t


... ..
The undersigned, an attorney admitted to practice in the courts of New York State,
0 Cortlficatlon certifies that the within
.
0
ID
By Attorney has been compared by the undersigned with the original and found lo be a true and complete copy.
1i
.~
0 Attorney's
Affirmation
shows: deponent is
the attorney (s) of record for
g
..
...
;;
in the within action; deponent has read the fo regoing
and knows the contents thereof ; the same is
u true to deponent's own knowledge, except as to the matters ther ein stated to be alJcged on information and belief,
and that as to those matters deponent believes it to be true. This ver ification is made by deponent and not by

The grounds of cleponent's belief as to all matters not stated upon deponent's knowledge are as follows:

The name signed muil bt printed beneath


l.
STeTE OF NEW YORK, COUNTY OF NEW YORK S!.:

WALTER R . YETNIKOFF being dul y sworn, deposes and says: deponent is


Individual the in the within action ; deponent has read
Verification
the foregoing and knows the contents ther eof ; the same is true lo
dcponent's own knowledge, except as to the matters therein stated to be alleged on information and belief, and as

..
c3 D
to those matters deponent believes it to be true.

.;e~;~~~~::n the Vice President of CBS Inc .


a New York corporation, plaintiff in ,t he within action ; deponent has read the
foregoing Complaint and knows the contents thereof ; and the same
is true to deponent's own knowledge, except as to the mauers therein stated to be alleged upon information and
belief, and as to those matters deponent believes it to be true. This verification is made by deponent because
plaintiff CBS Inc. is a corporation and deponent is an officer thereof.
The groun ds of deponent's belief as to aU matters not stated upon deponent's knowledge are as follows: plaintiff's
records and conferences with plaintiff's employees

Sworn to before me on October 7 , 1975


DONALD E. BI EDERM AN
NOTARY PU J LIC, Sti:t .? o f 1\1(.\W York
M,1. ) f).Q:'''· ; ! ~
Qu;ilifi" d i ; N ··::..:;1'.1 Ccuniy
I';! d I.. N 'H Y~· I k Cvl!Hty
r;c. (.
STAT E OF ~Ew' '!c:l'kK~·to'l'.JN'TPoF SS.:

being duly sworn, deposes and says: deponent is not a party to the action,
is over 18 years of age and r esides at
Affidavit On 19 deponent served the withjn
D of Stn lct
By Mail upon
attorney ( s) for in this actfon, at
><
0
ID .. . t~e address designated by said attorney ( s) for that purpose
by depos1tmg a true copy of same enclosed m a post-paid properly ad dressed wrapper, in - a post office - official
depository un der the exclusive care and custody of the United States Postal Service within the S tate of New York.
Affidavit On 19 at
] D
u
of Personal
Service deponent served the within upon
the
her ein, by delivering a true copy thereof to h personally. Deponent knew the
person so served to be the person mentioned and described in said' papers as the therein.
Sworn to before me on 19
i
·.

SUPREME COURT, STATE OF NEW YORK


COUNTY OF NEW YORK
- -x
CBS INC.

Plaintiff,

- aga inst-
VERIFlED COMPLAINT
A.J. WEBERMAN, doing
business as "DYLAN ARCHIVES" Index No.:
Defendant.
- - - - - - - - - - - - - -x

The Plaintiff, CBS Inc., by its attorney, DONALD

E. BIEDERMAN, for its complaint against the defendant, A.J.


WEBERMAN, alleges as follows, upon information and belief:

FOR A FIRST CAUSE OF ACTION :

1. Plaintiff CBS Inc. ("CBS") is and at all

times pertinent has been a corporation organized and exist-

ing under the laws of the State of New York and having its
principal off ice and place of business at 51 West 52nd

Street, City, County and State of New York.

2. Upon information and belief, defendant A.J.


Weberman ("Weberman ") is and at all times pertinent herein
has been a resident of the City , County and State of New
York, having his residence and place of business at 6
Bleeker Street therein.
,..
~:

3. Bob Dylan is a world-famous composer and


performer in the popular music field.

4. With the exception of the period from· June

30, 1972 to August 1, 1974, Bob Dylan has been and cur-

rently remains an exclusive Columbia Records recording

artist since March 1, 1962 pursuant to a series of term

recording artist agreements between Bob Dylan and CBS

Records, a division of CBS. (The period from March 1, 1962

to the present, excluding the period June 30, 1972 to August

1, 1974, is referred to below as the "Period of Exclusivity".)

5. During the Period of Exclusivity, Bob Dylan

has recorded solely for CBS Records and CBS Records alone

has the right to manufacture, distribute and sell through-

out the world phonograph records and tapes embodying the

performances of Bob Dylan recorded during such period and

to use the name and likeness of' Bob Dylan in connection

therewith.

and, upon information and belief, at various other times

prior thereto, defendant Weberman has advertised for

sale, and sold, in the State of New York .duplicate copies

of recorded performances of Bob Dylan and Johnny Cas.h of

the compositions "ONE TOO MANY MORNINGS"•, "RING OF FIRE",


"I WALK THE LINE", "CARELESS LOVE", "JUST A CLOSER WALK WITH

THEE", "THAT'S ALRIGHT NANA", and others, recorded in the

CBS Recording Studios, Nashville, Tennessee at a time when

both Bob Dylan and Johnny Cash were under exclusive re-

cording agreements with CBS Records.

7. Said recordings were obtained by defendant

i·leberman by means unkr101i..1n to CBS and wil:l1out per1nission from

CBS, and have·been duplicated, advertised and sold without

permission from CBS for the duplication of said recordings

or the use of the names or likenesses of Bob Dylan or Johnny

Cash in connection therewith .

. 8. The unauthorized duplication, advertisement

and sale by defendant Weberman constitutes a violation of

Sections 560 and 561 of the General Business Law and

Sections 50 and 51 of the Civil Rights Law.

. ·":~, 9. Such unauthorized duplication, advertisement

and sale by defendant Weberman of said recordings constitutes

a violation of the exclusive contr.act right~s of CBS therein.

10. Plaintiff has no adequate remedy at law.

FOR A SECOND CAUSE OF ACTION:

11. Repeats, reiterates and r~alleges the

allegations of paragraphs 1 through 6 'hereof with the same


~------

·e{fect as though set forth at length herein.

12. In addition, by separate agreement between

CBS Records and Bob Dylan dated June 14, 1973, CBS ac-
'
quired the exclusive right to the soundtrack of the motion

pict.ure "·PAT GARRETT and BILLY THE KID" for the manufacture,

distribution and sale of phonograph records and tapes

therefrom and the use of the name and likeness of Bob

Dylan in connection therewith.

13. In or about March and April, 1975, and,

upon information and belief, at various times prior thereto,

defendant Weberman duplicated, advertised and sold in the

State of ijew York, duplicate copies of performances of Bob

Dylan from the soundtrack of the.motion picture "PAT

GARRETT and BILLY THE KID".

14. Said recordings were obtained by defendant

Weberman by means unknown to CBS and without permission

from CBS, and have been duplicated, advertised and sold


L•-_'>' __ •• : - ' ;:--~·J'~ .+:;_;..-.,,,.~: .~-,.,,_.. -----··-
without permission from CBS for the duplication of said

recordings or the use of the name or likeness of Bob Dylan

in connection therewith.

15. The unauthorized duplication, advertisement

and sale by defendant Weberman constitu1;es a violation of

Sections 560 and 561 of the General Business Law and

Sections 50 and.51 of the Civil Rights Law.


16. Such unauthorized duplication, advertise-

ment and sale by defendant Weberman of said recordings

constitutes a violation of the exclusive contract rights


of CBS therein.

l7. Plaintiff has no adequate remedy at law.

FOR A THIRD CAUSE OF ACTION:

18. Repeates, reiterates and realleges the alle-

gations of paragraphs l through 6 hereof with the same

effect as though set forth at length herein.

19. In or about the months of March and April,

1975, and, .upon information and belief, at various times

prior thereto, defendant Weberman·duplicated, advertised

and sold in the State of New York, duplicate copies of live

performances of Bob Dylan which were recorded without

permission of CBS during the Period of Exclusivity.

20. The advertising circular, a copy of which


·~ -- . -.. -· .. •.,.::.:,.:... ---'-~·~__.'T>:_;''"''. '''· - -- -·~-·-~-·--"--
is'' annexed hereto as EJ.:h-ibit A 1 Contains at least two

entries (Items 2 and 12) which appear to consist of such

unauthorized recordings of live performances during the

Period of Exclusivity.

21. Said recordings were obtained by defendant


..--
.-

Weberman by means unknown to CBS and without permission from

CBS, and have been duplicated, advertised and sold without

permission from CBS for the duplication of said re.cordings

or the use of the name or likeness of ~ob Dylan in con-


nection therewith.

22. The unauthorized duplication, advertisement


and sale by defendant Weberman _cgnsti tutes a violation of

Sections 560 and 561 of the General Business Law and Sec-

tions 50 and 51 of the Civil Rights Law.

23. Such unauthorized duplication, advertisement

and sale by defendant Weberman of said recordings constitutes

a violation of the exclusive contract rights of CBS therein.

24. Plaintiff has no adequate remedy at law.

FOR A FOURTH CAUSE OF ACTION:

25. Repeats, reiterates and realleges the allega-

tions of paragraphs 1 through 7, 12 through 14 and 19


through. 21, with .the same •. ef.fec-t;--as~·though set" ·for'Eh_ at-------
length herein.

26. Such unauthorized duplication, advertisement


and sale by defendant Weberman of said recordings con-

stitutes willful and malicious unfair ,competition and is

designed to trade unlawfully upon the reputation, popu-

larity and good will created by CBS.


)
..

/ 27. By reason of the foregoing, plaintiff has

s·uffer·ed and will suffer monetary damages in the amount of

$250·,ciQO. or such other sum as shall be dete:Cmined at trial·

cir .by an accounting.

....
WHERETOFORE, plaintiff demands judgm.ent on each of

t)c1e. foregoing causes of acti.on as follows:

(a) enjoining defendant preliminarily during

the pendency of this action and permanently

thereafter from manufacturing, advertising,

distributing, offering or selling phonograph


-,.-,-. .. ~..-..-~·,-1.-. ,.......,.. -1--.,,....,,,.....r ,.....,-,,1-...-..-l"T-1 ~-..-.- "l"'C.-r<.~-.-r!; -rc:: 1; c+..or:l ,..,...
................................... ~ ............. ~-r;~~ ~--._..~-.i ---:J --~~~-----:J-
1-••
--- -~-

described in Items 2, 11, 12 and/or 14 of Exhibit

A hereto;

(b) enjoining defendant preliminarily during the

·pendency ·of this action and permanently thereafter

from manufacturing, advertising, distributing,

embodying any other recording ow.ned by the plain-

tiff and/or embodying .any performance of Bob Dylan

reco:Cded during the pe:i:.·iod of any exclusive re-

cordi.ng artist agreement between Bob Dylan and

the plaintiff, without the prior written consent

.l
(
.-
·of the plaintiff in each inRtari.ce;

( c) awarding the plairitiff·. · c6inpensa tory damages

of all profits realiz~d by defendant through

his unauthorized duplication of plaintiff's

recordings or such other sum as. plaintiff may

prove ·to be entitled to upon the trial of-this

action or u·pon an· accounting, and ptl)"\,~i:iV,-«'' d?Lmages

to'be determined by this Court; and

.(d) for the costs and disbursements of this

action, together with interest, and for such other

and further relief as this Court shall .deem

proper.

DONALD E. BIEDERMAN
Attorney for Plaintiff

CBS INC.
51 West 52nd Street
New York, New York 10019
Tel: 212- 765-4321

____ _:_
__ ---~-· 'C.e.,·-:
(

DYLAN ARCHIVES · · ..•. 'EXF!IBIT ·A
STRF..r~·r
6 O!-EEKE11
N!:W YORK CITY.!0012
,.
C:BS Inc~ v. A .. J .. WEBERM.llN

Dea1• l<'ellow Dylan Freek:.


~

Thanks for w1•itting to the Ardh.ives.' All of the tapes listed in the

back. of Tony Scadutto 's book on Dylan are~vailable from the Archives for.
$5 per 900 ft of tape recorded at· 3 3/4 ips. This price includes cost of.
tape and postage.but .all orders must be pre-paid.
If you.are not sure how lomg the tape or tapes you want are just
. ' .
send along a list ?f EVERYTHING. you want in orderof 'preference and I'll

be sur.e and fill up yer tape end to end •.


If you don't have Tony's . book I .can send you a discography for:._$2 .
. Al.l of the stuff in it, except for the tc,pes listed in .the enclosed update
I
'· sheet, sell for the price stated above.
We also sell cassettes for $5 per 90 minutes and 8-tra·cks for $6 per
80 minutes.
If you.have ;;i.ny questions don't hesitate to write or calJ. 212-477-
. . .. - ..
-

6243 - the Dylan


.
Hotlj_~e .
;-~:,-.---
; .. ,. .

Remember: "THERE'S NO DYLAN LIKE THE OLD DYLAN"

. · wai tin on you

/(if. /~/:~,u~·
.~-J, ,/e,.,_rman
Difector Of Dubbing Service
Dylan Archives
·,. ..
Prices :lnclude cost of tnpe _& postage - all orders prepaid. fl'1oney-back et<arant.::e
'· . \
...
'. DYLAN ARCHIVES , I
6 Bleecker Street I ''
Nc;i York City 100_12
U.S.A.~··

"1
'4 I
_
.. ""
E;
~
NEW 'rAP)':S AVAILABLE FROM ARCHIVES:

1. 11
SUPEHTJ\PE 11 - evcr.y DIFFERJ.7:NT song from Toil.r 74 includine;-YOU GO YC~iR ·,:.'.Y-
. ~~ I:J\XU\VXLAY. - I DONT BELIEVE YOU - 'l10M TJITJMD - nl\ :rl!Y DJ\ y ';fr,;11;·::; - '-;'",- --:::
""· MAMA ·- WENT OUT ONE MOI1NIKG - I11' J\INT Mto: J}f1):1·: - 'l'Ji] n:·ifdf - 'l'/\ir.1:<1~! i/; .. ~.· :i -

.~
""
(-j
H
WATCHTOWER - WATCHTOWER - HOLLIS BROWN - HE/\VAN3 DOOil - JU!;T DI?.:; ::c.'.•·.. i-
BLEEDING - HATTIE CARROLL - EXCEP1' FOR YOU - HEDDING SONG - DIVORC;': ;2;;.:1c-
: '4
RAViON'A· - f'1A!1A YOU 1\TE BEEH ON MlHD - Tii'1ES· ARE CHANG I~ - DON 1 T 'l':-!:I1·7:{ 2:·:
GATI!:S - YOUNG - SOi•lliTHING .l\BOU'l1 -you - IfIG!fWAY 61 - ROl:.LING S'rOKZ - ·,E!.C:·:IK

>A
"'
. [;l IN WIND - li'OURTH Tir·IE AROUND - SONG TO WOODY - SHE DELONGS 'rO iv:=: - .:.c~,r~
i'<l:C~{US ZERO - GIRL FROM NORTH. COUN 1rRY - BABY BLUE - P:l:i..bEOX HAT" - ;.;AGG:E
10 LOT TO LD.UGH - ONE T00}.1Al'ri M0\1HINGS - HERO .~~UE.S _- Hi~RD RAIN - D!::3. Ro·.-;
, •tO
SeJ.ection choosen on basis of' perfori.mance &·.-ti~·mr:r:rt!y· · - '$10~00 i_:ivs'vpp..id
"'
.:o . - --.-.
·?< 2. DYLAN IN
Mi>LIJOURC:!:: 1966 - DESOLATION ROW - !10Tl!ER REVISITE,D (Visiono o::
J onc.nna) - 1·1H 111A;•lriOrlNt: PIAN - JUST LIKE WOI1AN - etc. Excellent fide.i.i ty .1
,H
"'
U)
$5. 00 postpaid ·

"'''4 3. 'GASLIGHT THREE - NOTHERLESS CHILDREN -·HANDSOME ViOLLY - JOHN BRO\·/N -


'""
'E; JRlLLl'.~ WICHITA BL\BS ".SEE GRAVE IS CLEAN - :iANN>.H - COC>.ns-

·1~
COCKOO IS PRETTY BIRD - Excellent Fidelity $5 post paid

4. CARNEGIE }L',LL HOOT - SALLY GAL - .HIGH'llAY 61 - JOHN BIRCH - HOLLIS BP.O'iiN
'"'
I I 1i'.AflJ:J'rlAIN - ~~. pp

I"'
'""
IJ I
ASSORTED -
l"!''ui\liil~l
BACr~·//\Tlm BJ,UES
Onllr.f:l:' l.;
1-1 Nl~V.'P0\1 1 11
- 1961 Carnet;J.e Ha.ll 'rm::; 'Nl/\J;1 -
\};.) "' J\lAOGTg~ F'fd1M ..., Mii 1
•_1 •• fll:;i.n o r,n,
w.i.i..;l :;..~~-J;:~
JbC<
1[:J
le; 6. INTERVIEWS (aka "Pittsburgh") - SKIP WESHNE;R & s;/EDISl! FR(\E with 1-2-3-4
,. z
. ,. 'H T. . PLAY:BOY INTERVIEW - Nat Hentoff raps with the Big 'D - $5 pp
'P'.I
" \§ 8. NEW ELECTRIC .. SIGN ON CROSS -· DONT YA TELL HENRY - TELL ME ;IP,i'lA
l"' 1-2.1.- 3-4 or $5 with #5 & 119 also on t:;i.pe.
··1~
.""
I)
,,8 9. CHILE BENEFIT - HORTH COUNTRY BLUES - SPANISH. IS LOVING TONGUE <::id
mmTTITJ:lTWrriD - free with 1-2~3-4
""
.!~ 10. LEEDS DE;~os - STANDING ON l!IG(HWAY' - l!E WAS FRIEND OF)MINE - HAnD Tii•33
jo=: IN NY .T'O'lll'I- POOR BOY BLUES this is very early tape - GA1·IBLCiiN WILLE
0
- BALLAD JJOR FRIEl'fJ) - i'rne with 1-2-3-4
-..J;· . <;; __,_
---J..1-.-· -?AT-GARRBT7-S-0Ul\11J'J.?RJ"'i\;r1. - complete
.. . .
dit"ferent cuts then: record -:1?5 pp
[~t~;:ri} recordiri.g -· EVERY SONG~ I~c;~-d1ble 11 i-i;-iJ~;~~~1i. 11
'J! !;:l · 12. ~PniLfrAfil~QIJJ:_C. 6.4.. -
. A:.. concert inc. MT'I'Il!; vARROLL, MR 'I'MAN, SPA?'I HA.RLEM Il:iCIDF.l{T: v.r',•/IX~ nr.u;.::.;
L_; ·and 14 rao:r-e all time favor:tton featur_ing JO/l.Nig on ON i-'i'f ViT(1U'1 und l'I' AXh'*T
, ·" "· HE BOB. $5 postpaid. (no freo ooloctJ.011 ••••• uorry •••• ) 1J[:IN ,I.I
13. TOUR 74 - CHICAGO - Parr, - TOHON'ro - S'l1 LOUIS - MON1.L'Hf>;Af., - ]JC - Cli't,;; [,1;'.!."l1.I
·(· MlAMl - ATLANTA ·- I1EI,TBHIS - HUSTON ~. NYC - ANN ARDOP. - BLOOrtiIXG~orr -
' SEATTLE -· OAKLAND - LA - specii'y date and evening/afternoon :):.5 cachM
14. DYLAN-CASH }fASlillILLE ·sEsS!oNs - n·;;lan and. Cas~ ··w·a.11 - o~JZ-TOO ~:A1~· 1·~0~~r;~GS,
11).l«G 0.1/ l.'Iltt: - I W!u7ir-7lrrz-'L.07.tE - CARELESS LO'IE - JUS 1r A CLOSECT HhL!( 1dI'J.':-:
I ; TEl\E - 'l~HhT /i.LF\IGH~r MAHA - o.r:.d several more! Studio tape - pcr1'c_;c·v i'1Cc:i ty.
[. j1 $'.) tt) i•cr.uJur A1·ohivnn clicn'tn - $10 to everyone else .•.•. rJE::.VV~tl
. . l.5. .. 'l'lll~ t<:r:3:.->J.~(} D'JLAN ti.r.nu;.~ - J.1oh Dylnn In.concert: - Dyl;in readinr.; 0;1e ot.' h10
1.,i. yr\,tJiiio-ro~J:;.-1u-r11ULO'lt!-On1y plu.ou ht! ever rcudo hir; poetry. HA'l.'TIE CARP.OI..1-
~ SEill!.~~ CUR.SES - PEHCY 1 S SONG - and rnoro ...•. $5. (no !'roe scloction-sorry)
· r..dcl ~·l pet•· :j; 1) f'or canncttc ... :ji;;_~ pnP. 'f5
Cot> Q... tru.ci.c -complP.to r1.lGco n,,mp'lJed by
1· ·n.::i.r111y ... :i.~: ·1't1 .tuns ... )u1111Jtt\.Pi1.1 t:'idt1 ... •p;-~ l'.Jeit1t:.pa1u, 11i:Ulr. u11<,l11.:1 L11 AJ' wi·:u:~::.~1:,N
' . ~ /Jo~ 7"l' "-0( i::1 o iJ \l.
- - - - - ·-··--·---- ·-----·-··--.. :...t.

'.
.
SUPREME COURT OF THE S'i'ATE OF NEW YORK
COUNTY OF NEW YORK
-x
CBS INC.

Plaintiff, AFFIDAVI'.I'
-against-

A.J. WEBER!1AN, doing business


as "DYLAN ARCHIVES"

Defendant.
- - - - - - - - - -x
STATE OF NEW YORK
SS. :
COUNTY OF NEW YORK

A.J. WEEER!1AN, being duly sworn; deposes and says:

I am the Defendant in the above action.

In order to induc'e CBS - I-nc. to agree to a stipulation __ ..

of Discontinuance of the above action with prejudice, I agree

that I shall not hereafter duplicate any recorded performances

by Bob Dylan which is or has been recorded by Bob Dylan pursuant

to a recording artist agreement with CBS Records without the

express written permission of CBS Records and Bob Dyla;,_ in each

instance.
01'- (!.E<:oF--~
Further, I will not duplicateAany p'e-d-e-rfuance by Bob

Dylan in concert, or 011 radio or television, or oth.er\.vise with-

out the express written permission of Bob Dylan and CBS Records

in each~·
rsi:a?i:':fan&e-,.. whether or not I have previously duplicated
' o;z. f'-~DEJ; (} {j /\; '
Asuch per ' ce.

Further, I shall not advertise, distribute or sell

-any such duplicate or any such performance except pursuant to


...

such express permission . _


:;::: (,vl/.L }JOT ];J() /IN"/ <l)C- nrc= f-C~t--:C,--o/A..16- bri<-t--cny Cf(l_ !N!:J / t<.t.--C7LY ,'IV(Z. OµJSC::
• * 771€"" ~.;i:;-01"-'6-
ArvV -,u 1'!>F l)ONF/ J>1t?.~TLY <¥- tAJDrre€-<7L.Y.
Further I warrant and represent that the recorded
~ •

• performances which are the subject matter of this action were

not obtained by me from any present or former employee of

CBS Records or from any CBS Records facility.

Sworn to before me this

31st day of October , 1975

Af\'"H' 1

.NOTARY ·:..:,, "''.'- -:· .. ::.~• 1 l·:r~


1 • •

. PU~1:1'.J , .1 l •. , , i'IOl'I Yori(


... N1.J. 31- l . ~..:;..! .l5
c_ Qualified i11 N.•w ·.'ork Count ,
..ommlss1on Expire::; Mc:rch 3 0, 1)977,

In consideration of the foregoing , it is hereby agreed by and


._ between A. J. Weberman and CBS Inc. that the above action be and
'hereby is discontinued with prejudice and without cost to
either party . It shall be a condition of this discontinuance
that neither party shall further publicize the above action or
this settlement .

Dated: New York, New York


October 31 , 1975

CBS n~c.

By ~~-~'- -
DONALD E . BIEDERMAN

- c1
~~ J. WEBERMAN
OYLANOLOGIST

;:;;·L,;~N ARCHIVES
6 BLE:Ef;::::R- -STREET
NEW YORK CITY ·-:en•~-._
. --~-

Dear Fellow Dylan Freek:

Thanks for writting to the Ardhives; All of the tapes listed i1il the

back o:t; Tony Scadutto 's book .on Dylan are available from the Archive50 :for-

$5 per 900 ft of tape recorded at 3 3/4 ips. This price includes cos~o:f
tape and postage but all orders must be pre-paid.
"
If you are not sure how long the tape or tapes you want are just,

send along a list of EVERYTHING you want in orderof preference and I']l
be sure and fill up yer tape end to end.

If you don't have Tony's~book I can send you a discography :for ?,2.

All of the stuff in it, except for the tapes listed in the enclosed update
sheet, sell :for the price stated above.

We also sell cassettes :for $5 per 90 minutes and 8-tra·cks :for $5 per
80 minutes.

If you have any questions don't hesitate to write or call 212-~77-


6243 - the Dylan Hotline .•••.

Remember: "THERE'S NO DYLAN LIKE THE OLD DYLAN"

waitin on_ you

Director Of Dubbing Services


Dylan Archives
----------------------------,

DYLAN ARCHIVES NEWSLETTER - FALI..:-WINTER 75 •

The Dylan Archives wishes to announce a new tape processing pol:i.cy. At


one time new aquisit1ons sold for more than ·the old stuff. No more. We are
back to a flat rate of $5 per ONE AND A HALF HOURS of ANY rare Dylan. We
are now offering a special Combination tape of all the new aquisitions
for $5. This tape include~-

!. NEWPORT 65 complete -ALL I REALLY .WANT TO DO, MAGGIES FARM:. LIKE A ROLLING
STONE, LOT WO LAUGH, BABY BLUE & T;MAN. Dylan gets
bqoed off the stage in this profes·s1onally made
-recording. Different than record.
2. CHAPll'ER HALL - Despite the :fact that Izzy Young, who sponsored the Chapter I
Hall event took off' to Sweden the Archives was able to obtairi
(at la at)' a completei>Chapter Hall tape. Includes-PRETTY · i
PEGGIO, IN THE PINES, GOSPEL PLOW, 1913 MASSACRE, BACKWATER I
BLUES, FIX1N TO DIE LONQ TIME A GROWIN, Many interesting
early Dylan ·raps. Top Fidelity.
3. DYLAN AT THE BOTTOM LINE with JACK ELLIOT - Dylan .-~corded many of' these
§Ongs for his upcoming album. PRET'J;Y BOY FLOYD, HOW LONG
HAS THAT EVENING SUN GONE DOWN and the best song Dylan
has written .in years- I CAN HEAR THE' .
ll'URNING OF '.!:HE KEY.
4. BILLY FAIR TAPE "." 1963 WBAI radio' broadcast .:. FOLLOW YOU DOWN;_, EMIT'l'
TILL, JONH BIRCH,
.
and. MAKE
-.
A PALLET
..
ON YOUR FLOOR,
. .

WE ARE ~LSO DROPPING THE PRICES ON CASSETTES AND EIGHT TRACK TAPES- from now
on cassettes are $5 per 90 minutes and 8-tracks are ~6 per 80 minutes.
This drop in pr.ice is due to the publication of Coup D'Etat - by Third
Press. The book details the rela·t:i.onship between Ruby, Hunt, Lansky, Sturgis,
o_swald etc. and has nothing to d.o ·w+th Dylan. (he had nothing to do with the
jF~ killing) TAKE ADVANTAGE OF THESE PRICES NOWJ
1
aj weberman .;
6 Bleeker St i
I
:NYC 10012

i
I.
Dylan Archives
6 Bleecker St.
NYC l00l2
·.

Dear Dylan Tape Customer::

Severa.l months ago I was served 'with a summons by an agent of Columbia Records.

It said I was being sued for a quarter of a million dollars for making unauthorized

tapes of Dylan concerts, outtakes etc. I have included a xerox of part of that suit

in some of these letters.

The Archives will not close dD',m. I am in the process of weed:king out the

inf01'mers for Columbia Records and when I do I will mail out all the tapes that are

on order and will start taking new ordees" In the meantime just tell your friends

that the. Archives is "closed for repaj.rs". Unfortunatly I can't take on any new

customers unlesS they are reccomeended by an old customer ;the Dylan Archives lliDm · has

been forced underground.

I am taking a risk of a ·big legal hastle by mailing out these tapes - I am

trying to contact Dylan at tlhn time and get speciab:::i:~ permissioo -· so :;_~u>.Y3,ll!

please be patient - 1'elp is on the way.

for the Archives

snowplow floater

.--------;---·-~ --;--~-· ·.
. "

,,

'----
CBS
CBS Inc .. 51West52 Street
New York, NewYprk 10019
\, .....

(212) 765-4321
Donald E. Biederman, General Attorney

.Re : BOB DYLAN

Dear Mr . Weberman : Marc h 1 , 1 976

We have received a copy of the attached letter , wh i ch,


though s i gned 11 snowplow floater '', appears to ema nate
from you and, if so, to v iolate your agreeme nt and
promise to us .

Be assured that we i ntend that you liv e up to your word,


and we will not hesitate to take further action if you
break it.

Yours,

'

Mr . A. J . Weberman
6 Bl eeker Street
Ne w York, New York 10012

cc Perlstein, Saltzman

I !
' I , I fj
I • "'~
. :. :~ :;_ :_, ~~- Dyl.en Archives
. . ..,. .
. . "' ~ .. .
..
~

6 Bleecker St.
NYC 10012

. :. .
. ,.
i '. .
., :
~r
t'
· .
. . (/
/ Deer Dylan Tape Customer ·:
.•
/

Several months ago I was served -with a summons by ~n - agent of Columbia Records. -

It said I was being sued for a quarter of a million dollars for making unauthorized

tapes of Dylan concerts, outtakes etc. I have included a xerox 9f i:art of that suit

in some of these letters.

The Archives vill not close n o-.m. J: am in the process of -weedking out the "-.._

informers for Columbia Records and when I do I v.ill mail out all the tapes ~hat are

on order and vill start taking new ordees. In the meantime just tell your friends

that the Archives is "closed for repairs". Unfortunatly I can• t take on any new

customers unless they are reccomaended by an old customer - the Dylan Archives ~ has

been forced underground.

I am ta~ing a risk of a big legal hastle by mailing .out these tapes - I am

trying to contact Dylan at thia time end get specie~· permission - so ~

please be patient - help is on the way.

for the Archives

snowplow floater

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