Before the COPYRIGHT ROYALTY JUDGES Washington, D.C.
) In the Matter of ) ) Docket No. 14-CRB-0010-CD (2010-13) Distribution of the 2010-2013 ) Cable Royalty Funds ) )
) In the Matter of ) ) Docket No. 14-CRB-0011-SD (2010-13) Distribution of the 2010-2013 ) Satellite Royalty Funds ) )
DECLARATION OF LUCY HOLMES PLO VNICK
I, Lucy Holmes Plovnick, declare:
1. I am over 18 years of age and an attorney at law duly licensed to practice law in the District of Columbia, Massachusetts, and Rhode Island. I am a partner in the law firm of
Mitchell Silberberg & Knupp LLC, attorneys of record for the Motion Picture Association of
America, Inc. ("MPAA") and other program suppliers who have agreed to representation by
MPAA in the captioned proceedings.
2. Attached hereto as Exhibit A are worksheets that I prepared and/or were prepared at my direction for each of the 2010-2013 cable royalty years that match up the entity names
identified in Multigroup Claimants ("MC") Exhibit 16 with the same entity names and claim
information that appears on MPAA's Petitions to Participate in these proceedings, and the name appearing on the applicable MPAA representation agreement for each entity.
3. Attached hereto as Exhibit B are spreadsheets prepared at my direction for each of the 2010-2013 satellite royalty years that match up the entity names identified in MC Exhibit 17 with the same entity names and claim information that appears on MPAA's Petitions to Participate in these proceedings, and the name appearing on the applicable MPAA representation agreement for each entity.
4. The differences in entity names MC identified in its Exhibits 16 and 17 are, in most cases, simply matters of punctuation, spacing, or the use of abbreviations—all of which should be easily understood by anyone reviewing the documents produced by MPAA.
5. Moreover, the spreadsheets and other documents that MPAA produced in discovery in these proceedings would necessarily vary in some ways from MPAA's Petitions to
Participate because the former are internal MPAA documents, while MPAA's Petitions to
Participate were prepared by MPAA's counsel specifically for these proceedings pursuant to the directions set forth by the Judges in their Federal Register Notices.
6. Attached hereto as Exhibit C are spreadsheets prepared at my direction for each of the 2010-2013 cable and satellite royalty years that list those entities identified in MC Exhibits
16 and 17 that were not included on MPAA's Petitions to Participate in these proceedings. All but two of the entities listed on Exhibit C did not file a cable and/or satellite royalty claim for the year at issue, and thus, were properly excluded from MPAA's Petitions to Participate. The two
MPAA-rep esented entities identified on Exhibit C that filed royalty claims for the cable or satellite royalty year identified are Challenger Films for 2011 satellite (individual Claim No.
210) and Osiris Entertainment for 2012 satellite (included in joint Claim No. 99). These two entities were inadvertently omitted from MPAA's Petition to Participate.
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
Executed this 31st day of October, 2016, at Washington, D.C. -14i4uL) Lucy Holmes Plovnick
2 EXHIBIT A EXHIBIT A
2010 CABLE NIPA ii.. CLAIM kNT MPAA 2010 CABLE PTP LISTED ON MC EXHIBIT 16 NAME ON APPLICABLE MPAA REP AGREEMENT 2929 ENTERTAINMENT LLC 2929 ENTERTAINMENT 2010 454 W FINTAGE PUBLISHING AND COLLECTION B.V. 2929 ENTERTAINMENT LLC 2010 536 W FINTAGE PUBLISHING AND COLLECTION B.V. 3DD ENTERTAINMENT LIMITED 3DD ENTERTAINMENT LTD. 2010 604 W COMPACT COLLECTIONS LIMITED 4 LICENSING CORP. FKA 4KIDS PRODUCTION 4KIDS PRODUCTION 2010 418 1 4 LICENSING CORPORATION FKA 4KIDS PRODUCTIONS AIM GROUP LLC. AIM GROUP LLC 2010 454 W FINTAGE PUBLISHING AND COLLECTION B.V. MM GROUP LLC. 2010 536 W FINTAGE PUBLISHING AND COLLECTION B.V. ALCHEMY TELEVISION GROUP ALCHEMY TELEVISION GROUP DRG 2010 604 W COMPACT COLLECTIONS LIMITED ALLEGRO PICTURES ALLEGRO PICTURES LTD. 2010 604 W COMPACT COLLECTIONS LIMITED ALLSTAR MARKETING GROUP ALLSTAR MARKETING LLC LLC 2010 614 W BRUCE D. GOODMAN FOR THE GOODMAN GROUP, LLC ANN II, INC. A/K/A IPME IPME, LLLP FKA ANN II, INC. 2010 614 W BRUCE D. GOODMAN FOR THE GOODMAN GROUP, LLC APARTMENT 11 PRODUCTIONS APARTMENT 11 PRODUCTIONS INC. 2010 211 J APARTMENT 11 PRODUCTIONS APARTMENT 11 PRODUCTIONS INC. 2010 437 W CANADIAN BROADCASTING CORPORATION
AUDIO-VISUAL COPYRIGHT SOCIETY AUDIO-VISUAL COPYRIGHT AUDIO-VISUAL COPYRIGHT SOCIETY TRADING AS TRADING AS SCREEN SOCIETY LTD (TRADING AS AVCS) 2010 417 J SCREENRIGHTS BOSLEY BOSLEY INC. 2010 614 W BRUCE D. GOODMAN FOR THE GOODMAN GROUP, LLC BRAD LACHMAN PRODUCTIONS BRAD LACHMAN PRODUCTIONS INC. 2010 454 W FINTAGE PUBLISHING AND COLLECTION B.V. BRAD LACHMAN PRODUCTIONS 2010 536 W FINTAGE PUBLISHING AND COLLECTION B.V. BREAKTHROUGH ENTERTAINMENT BREAKTHROUGH INC. ENTERTAINMENT INC 2010 604 W COMPACT COLLECTIONS LIMITED BURBANK ANIMATION STUDIOS BURBANK ANIMATION STUDIOS, PTY. PTY LTD 2010 604 W COMPACT COLLECTIONS LIMITED CAKE ENTERTAINMENT LTD CAKE ENTERTAINMENT LTD. 2010 604 W COMPACT COLLECTIONS LIMI1Ell CAPITAL BRANDS, LLC CAPITAL BRANDS, LLC FKA LOHAN 2010 614 W BRUCE D. GOODMAN FOR THE GOODMAN GROUP, LLC CARSEY-WERNER CARSEY-WERNER DISTRIBUTION 2010 613 I CARSEY WERNER CBS BROADCASTING INC. CBS BROADCASTING, INC. 2010 227 J CBS BROADCASTING INC. CBS STUDIOS, A CBS COMPANY CBS STUDIOS, INC. 2010 36 J CBS STUDIOS INC. CCI RELEASING INC CCI RELEASING 2010 604 W COMPACT COLLECTIONS LIMITED CELLULAR RESEARCH A/K/A CELLULAR RESEARCH IRWIN NATURALS 2010 614 W BRUCE D. GOODMAN FOR THE GOODMAN GROUP, LLC CESAR' RESPONSE TELEVISION, CESARI RESPONSE TELEVISION INC. INC. 2010 614 W BRUCE D. GOODMAN FOR THE GOODMAN GROUP, LLC CHANNEL FOUR TELEVISION LTD CHANNEL FOUR TELEVISION LTD.. 2010 604 W COMPACT COLLECTIONS LIMII Ell CHANNEL FOUR TELEVISION LTD: FILM FOUR 2010 604 W COMPACT COLLECTIONS LIMITED CLASSIC MEDIA DISTRIBUTION CLASSIC MEDIA DISTRIBUTION LTD.. LIMI I Ell 2010 604 W COMPACT COLLECTIONS LIMITED CONNECTION III ENTERTAINMENT CONNECTION III ENTERTAINMENT CORP 2010 491 I CONNECTION DI ENTERTAINMENT CORP. CONTENT FILM INTERNATIONAL CONTENT FILM INTERNATIONAL LTD 2010 604 W COMPACT COLLECTIONS LIMITED OLE MEDIA MANAGEMENT LP OBO COOKIE JAR COOKIE JAR ENTERTAINMENT COOKIE JAR ENT INC FKA DIC ENT 2010 412 W ENTERTAINMENT, INC. COOKIE JAR ENTERTAINMENT/DIC ENTERTAINMENT 2010 437 W CANADIAN BROADCASTING CORPORATION CURB ENTERTAINMENT CURB ENTERTAINMENT INTERNATIONAL INTERNATIONAL CORP. 2010 276 W IFTA COLLECTIONS, A DIVISION OF IFTA DIC ENTERTAINMENT LLC DIC ENTERTAINMENT, L.P. 2010 412 W OLE MEDIA MANAGEMENT LP DISCOVERY COMMUNICATIONS, EDWARD S. HAMMERMAN, ESQ., HAMMERMAN PLLC DISCOVERY COMMUNICATIONS LLC 2010 5 W D/B/A INTERMEDIARY COPYRIGHT ROYALTY SERVICES