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DANIEL M. PETROCELLI (S.B. #97802) Dpetrocelli@Omm.Com O Case 2:12-cv-09912-ABC-SH Document 188 Filed 06/09/14 Page 1 of 33 Page ID #:4591 1 DANIEL M. PETROCELLI (S.B. #97802) [email protected] 2 O’MELVENY & MYERS LLP 1999 Avenue of the Stars, 7th Floor 3 Los Angeles, California 90067-6035 Telephone: (310) 553-6700 4 Facsimile: (310) 246-6779 5 Attorneys for the Warner Parties 6 MARTIN R. GLICK (No. 40187) [email protected] 7 ARNOLD & PORTER LLP Three Embarcadero Center, 10th Floor 8 San Francisco, California 94111-4024 Telephone: 415.471.3100 9 Facsimile: 415.471.3400 10 Attorneys for The Saul Zaentz Company 11 UNITED STATES DISTRICT COURT 12 CENTRAL DISTRICT OF CALIFORNIA 13 FOURTH AGE LTD., et al, Case No. 12-9912-ABC (SHx) 14 Plaintiffs, NOTICE OF MOTION AND MOTION BY WARNER AND 15 v. ZAENTZ TO DISQUALIFY GREENBERG GLUSKER; 16 WARNER BROS. DIGITAL MEMORANDUM OF POINTS DISTRIBUTION, et al, AND AUTHORITIES IN 17 SUPPORT THEREOF Defendants. 18 LENS DECLARATION FILED 19 WARNER BROS. DIGITAL CONCURRENTLY HEREWITH DISTRIBUTION INC., et al, 20 Counterclaim Judge: Hon. Audrey B. Collins 21 Plaintiffs, Magistrate: Hon. Stephen J. Hillman 22 v. Hearing Date: July 7, 2014 Hearing Time: 10:00 a.m. 23 FOURTH AGE LTD., et al, Discovery Cut-Off: July 29, 2014 24 Counterclaim Defendants. 25 26 27 28 MOTION TO DISQUALIFY GREENBERG GLUSKER CASE NO. 12-9912-ABC (SHX) Case 2:12-cv-09912-ABC-SH Document 188 Filed 06/09/14 Page 2 of 33 Page ID #:4592 1 NOTICE OF MOTION AND MOTION 2 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 3 PLEASE TAKE NOTICE that on July 7, 2014 at 10:00 a.m., or as soon 4 thereafter as the matter may be heard by the above-entitled court, located at 255 5 East Temple Street, Los Angeles, California, in Courtroom 680, defendants and 6 counterclaim plaintiffs Warner Bros. Home Entertainment Inc., Warner Bros. 7 Entertainment Inc., Warner Bros. Consumer Products Inc., and New Line 8 Productions, Inc. (collectively, “Warner”) and The Saul Zaentz Company 9 (“Zaentz”) will and hereby do move the Court for an order (i) disqualifying 10 forthwith Greenberg Glusker Fields Claman & Machtinger LLP (“Greenberg”) as 11 counsel in this action for plaintiffs and counterclaim defendants Fourth Age 12 Limited, Priscilla Mary Anne Reuel Tolkien, as Trustee of the Tolkien Trust, The 13 J.R.R. Tolkien Estate Ltd., Harper Collins Publishers, Ltd., Unwin Hyman Ltd. and 14 George Allen & Unwin (Publishers), Ltd. (collectively, the “Tolkien/HC Parties”); 15 (ii) barring the Tolkien/HC Parties from calling Alan Benjamin or William 16 Bernstein as witnesses at deposition or at trial; and (iii) requiring new or separate 17 counsel to examine Benjamin or Bernstein free from any information from 18 Greenberg, if Warner or Zaentz choose to call them as witnesses. Alternatively, to 19 the extent Greenberg is not disqualified now, Warner and Zaentz seek an order 20 (iv) requiring Greenberg to fully disclose its communications with Benjamin and 21 Bernstein, its records, and its notes thereof to the Court for in camera review, as 22 well as to MGM (as defined below); (v) ordering the deposition of Bonnie Eskenazi 23 on these matters; and (vi) granting all such other and further relief this Court deems 24 just and proper. 25 This motion is made pursuant to Rule 83-3 of the Local Rules of this Court, 26 Rules 3-310(c), 3-310(e), and 1-120 of the California Rules of Professional 27 Conduct, Canon 9 of the Model Code, and the inherent authority of this Court, on 28 MOTION TO DISQUALIFY GREENBERG GLUSKER CASE NO. 12-9912-ABC (SHX) Case 2:12-cv-09912-ABC-SH Document 188 Filed 06/09/14 Page 3 of 33 Page ID #:4593 1 the grounds that Greenberg has violated its ethical and professional obligations and 2 compromised the integrity of this litigation to the prejudice of Warner and Zaentz. 3 Pursuant to Local Rule 7-3, the parties attempted to resolve this dispute 4 without the Court’s intervention. As explained in the accompanying Declaration of 5 Molly M. Lens, the parties have met and conferred for months in an attempt to 6 resolve the issues in this motion, including two conferences on April 24, 2014 and 7 April 30, 2014, but the parties were unable to reach a resolution. 8 This motion is based on this Notice of Motion and Motion; the 9 accompanying Memorandum of Points and Authorities; the concurrently-filed 10 Declaration of Molly M. Lens; the Joinder to be filed by non-parties Metro- 11 Goldwyn-Mayer Inc., Metro-Goldwyn-Mayer Studios Inc., Metro-Goldwyn-Mayer 12 Pictures Inc. and United Artists Corporation; any additional briefing that may be 13 filed; all exhibits, files, and records on file in this action; matters of which judicial 14 notice may be taken; and such additional submissions and argument as may be 15 presented at or before the hearing on this motion. 16 Dated: June 9, 2014 17 O’MELVENY & MYERS LLP 18 19 By: Daniel M. Petrocelli 20 Attorneys for the Warner Parties 21 22 ARNOLD & PORTER LLP 23 By: 24 Martin R. Glick Attorneys for The Saul Zaentz Company 25 26 27 28 MOTION TO DISQUALIFY - 2 - GREENBERG GLUSKER CASE NO. 12-9912-ABC (SHX) Case 2:12-cv-09912-ABC-SH Document 188 Filed 06/09/14 Page 4 of 33 Page ID #:4594 1 TABLE OF CONTENTS 2 Page 3 I. INTRODUCTION ........................................................................................... 1 4 II. STATEMENT OF FACTS .............................................................................. 4 5 A. Benjamin and Bernstein Negotiated, Drafted, and Implemented 6 The Agreements at Issue in This Case. ................................................. 4 7 B. Greenberg Invades MGM’s Privilege and MGM Objects. ................... 5 8 C. Greenberg Refuses to Stop its Misconduct or to Disclose the Full Extent of its Communications. ...................................................... 6 9 III. GREENBERG HAS VIOLATED ITS ETHICAL OBLIGATIONS, 10 COMPROMISING THE INTEGRITY OF THE PROCEEDINGS ............. 10 11 A. Greenberg Violated Rule 3-310(c)...................................................... 11 12 B. Greenberg Violated Rule 1-120 and 3-310. ........................................ 12 13 C. Greenberg Violated Canon 9. ............................................................. 14 14 IV. PROTECTIVE ACTION BY THIS COURT IS NECESSARY TO PRESERVE THE INTEGRITY OF THESE PROCEEDINGS ................... 18 15 A. Greenberg Has Gained an Unfair Advantage. .................................... 19 16 B. Greenberg Has Not Been Candid about Its Communications 17 with Benjamin and Bernstein. ............................................................. 22 18 C. Greenberg’s Continued Involvement Will Irreparably Taint the Integrity of the Proceedings. ............................................................... 23 19 V. CONCLUSION ............................................................................................. 25 20 21 22 23 24 25 26 27 28 MOTION TO DISQUALIFY GREENBERG GLUSKER CASE NO. 12-9912-ABC (SHX) Case 2:12-cv-09912-ABC-SH Document 188 Filed 06/09/14 Page 5 of 33 Page ID #:4595 1 TABLE OF AUTHORITIES 2 Page(s) 3 CASES 4 All Am. Semiconductor, Inc. v. Hynix Semiconductor, Inc., 5 2008 WL 5484552 (N.D. Cal. Dec. 18, 2008) ................................................... 24 6 Am. Prot. Ins. Co. v. MGM Grand Hotel-Las Vegas, Inc., 1986 WL 57464 (D. Nev. Mar. 11, 1986) .......................................................... 15 7 8 Anticancer, Inc. v. Xenogen Corp., No. 05-00448 (S.D. Cal. Aug. 10, 2006) ............................................................ 14 9 Biocore Med. Techs., Inc. v. Khosrowshahi, 10 181 F.R.D. 660 (D. Ka. 1998) ............................................................................ 16 11 Cargill, Inc. v. Budine, 12 2007 WL 1813762 (E.D. Cal. June 22, 2007) ............................................. passim 13 City Nat. Bank v. Adams, 14 96 Cal. App. 4th 315 (2002) ............................................................................... 22 15 Columbia Pictures, Inc. v. Bunnell, 16 2007 WL 4877701 (C.D. Cal. Dec. 13, 2007) ................................................... 18 17 Colyer v. Smith, 50 F. Supp. 2d 966 (C.D. Cal. 1999) .................................................................. 19 18 19 Conn v. Superior Court, 196 Cal. App. 3d 774 (1987) .............................................................................. 25 20 Davis v. Los Angeles W. Travelodge, 21 2010 WL 623657 (C.D. Cal. Feb. 3, 2010) ........................................................ 11 22 Decaview Distribution Co., Inc. v. Decaview Asia Corp., 23 2000 WL 1175583 (N.D. Cal. Aug. 14, 2000) ................................................... 18 24 Employers Ins. of Wausau v. Albert D. Seeno Const. Co., 25 692 F. Supp. 1150 (N.D. Cal. 1988) ................................................................... 23 26 Erickson v. Newmar Corp., 27 87 F.3d 298 (9th Cir. 1996) ......................................................................... passim 28 MOTION TO DISQUALIFY - ii - GREENBERG GLUSKER CASE NO. 12-9912-ABC (SHX) Case 2:12-cv-09912-ABC-SH Document 188 Filed 06/09/14 Page 6 of 33 Page ID #:4596 1 Flatt v. Superior Court, 2 9 Cal. 4th 275 (1994) ............................................................................................ 2 3 FMC Techs., Inc. v. Edwards, 420 F. Supp. 2d 1153 (W.D. Wash. 2006) ......................................................... 18 4 5 Holm v. City of Barstow, 2008 WL 4290857 (C.D. Cal. Sept. 16, 2008) ................................................... 14 6 Huston v. Imperial Credit Commercial Mortg. Inv. Corp., 7 179 F. Supp. 2d 1157 (C.D. Cal. 2001)
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