Before the COPYRIGHT ROYAL TY JUDGES Washington, D.C.

In the Matter of ) ) Distribution of ) Docket No. 14-CRB-0010-CD 2010-2013 2010-2013 ) Cable Royalty Funds )

In the Matter of ) ) Distribution of ) Docket No. 14-CRB-0011-SD 2010-2013 2010-2013 ) ~Sa~t~el~lit~e~R~o~y~al~ty~F~u~n~d~s------~-)

MULTIGROUP CLAIMANTS' OPPOSITION TO SETTLING DEVOTIONAL CLAIMANTS' MOTION TO DISQUALIFY MULTIGROUP CLAIMANTS AND TO DISALLOW CERTAIN CLAIMANTS AND PROGRAMS

Brian D. Boydston, Esq. California State Bar No. 155614 PICK & BOYDSTON, LLP 10786 Le Conte Ave. Los Angeles, California 90024 Telephone: (213) 624-1996 Facsimile: (213) 624-9073 Email: [email protected]

Attorneys for Multigroup Claimants TABLE OF CONTENTS

INTRODUCTION. . . . . • • . . • • . • . • • . . . • . • • ...... • • ...... • . . • . . . 4

Falsity #1: Multigroup Claimants did not "substantially refuse to respond to many of the SDC's discovery requests." ..•.••.•.•.••.••.6

Falsity #2: MC did not "[seek] to deceive the Judges and other participants concerning the true identity of [Multigroup Claimants] and Spanish Language Producers." ....••...••..•..•.•..•.•••..•.••..7

Falsity #3: Al Galaz has never been found to have engaged in any fraudulent activity...... •..•...... •.•...... ••••....•...•..• 11

ARGUMENT

A. AS A MATTER OF CONTRACT AND OF LAW, MULTIGROUP CLAIMANTS HAD NO OBLIGATION TO OBTAIN CONSENT TO MAKE PROGRAM CLAIMS DIRECTLY FROM THE UNDERLYING OWNER OF COPYRIGHT•••••.•...... •.•.•••. 14

B. DENISE VERNON HAD THE AUTHORITY TO MAKE 2010 "JULY CLAIMS" ON BEHALF OF IPG; NO DOCUMENTS SUGGEST THE CONTRARY; NO DOCUMENTS RESPONSIVE TO THE SDC DOCUMENT REQUESTS WERE WITHHELD.•.•.....•.•.•.... 17

C. SALEM BAPTIST CHURCH OF CHICAGO HAS AFFIRMED ITS OWNERSHIP OF PROGRAMMING CHALLENGED BY THE SDC, AND THE SDC PROVIDE NO INFORMATION CONTRADICTING SUCH CLAIM...... •.•.....••...••...... •... 19

D. THE SDC PERSIST IN DEMANDING A DISCOVERY SANCTION FOR THE PRODUCTION OF DOCUMENTS THAT SIMPLY DO NOT EXIST•.•.•...... •.•.•.•..•..•...•••..•.•••..••.•• 22

2 E. THE SDC BLATANTLY MISREPRESENT THE SUBSTANCE OF KENNETH COPELAND MINISTRIES EMPLOYMENT AGREEMENTS AS A PREDICATE TO ARGUING THAT THE "KENNETH COPELAND" TELEVISION PROGRAM IS NOT OWNED BY KENNETH COPELAND MINISTRIES.••...... 24

F. THE SDC MAKE NO SUBSTANTIVE ARGUMENT FOR THE DISMISSAL OF IWV MEDIA'S CLAIM, PREMISE THEIR ARGUMENT ON A MISREPRESENTATION OF THE CONTENTS OF MAUREEN MILLEN'S DECLARATION, AND MISCHARACTERIZE BROADCAST NETWORKS AS CABLE NETWORKS...... •...... •...... 28

G. NO EVIDENCE SUGGESTS THAT IPG ACTED IN BAD FAITH REGARDING CLAIMS ATTRIBUTABLE TO BOB ROSS, INC.•.. 30

CONCLUSION...... •.•...... •...... •..••.. 34

3 Multigroup Claimants hereby submits its Opposition to Settling Devotional

Claimants Motion to Disqualify Multigroup Claimants and to Disallow Certain

Claimants and Programs in the above-captioned proceeding.

INTRODUCTION

The first eighteen ( 18) pages of the SDC motion appear to be no more than a campaign to besmirch Multigroup Claimants. With literally zero information on which to understand the purpose for the existence and involvement of Multigroup

Claimants ("MC") and Spanish Language Producers ("SLP") in these proceedings, the SDC fabricate a remarkable number of false, incendiary accusations against such entities, their principal Al Galaz, Independent Producers Group ("IPG"), Raul

Galaz, Denise Vernon, and the undersigned counsel.

The only thing that is truly learned from the SDC motion is that the SDC has educated itself about the absolute privilege to defamation for statements made in litigation, i.e., even malicious, knowingly false statements, are privileged from prosecution. 1 It is only by hiding behind this mother's skirt of protection that the

SDC is so bold as to make the series of unfounded statements, including:

1 Notwithstanding, it has been noted that "[i]n strictly judicial proceedings the potential harm which may result from the absolute privilege is somewhat mitigated by the formal requirements such as notice and hearing, the comprehensive control exercised by the trial judge whose action is reviewable on appeal, and the availability ofretarding influences such as false swearing and perjury prosecutions ... " Zagami, LLC v. Mary Ann Cottrell, 403 N.J. Super. 98, 957

4 "Through counsel, Alfred Galaz has intentionally sought to deceive the Judges and other participants concerning the true identity of [Multigroup Claimants] and Spanish Language Producers."

"The authorization and transfer [from IPG to Multigroup Claimants] is a tainted conveyance apparently designed to obscure IPG's and Raul Galaz's criminal history, and is likely a fraudulent conveyance for the purpose of defrauding claimants."

"It is also likely to be a fraudulent conveyance for the purpose of defrauding unwitting claimants, in order to avoid IPG' s responsibility to pay them royalty distributions that are or may become due to them."

"IPG has a history of swindling legitimate claimants out of royalties. "2

"The instant strategy to transfer all authority from IPG to Alfred Galaz has all the hallmarks of another fraudulent transaction designed by Raul Galaz to insulate [Multigroup Claimants] from the adverse rulings issued by the Judges against IPG and Raul Galaz in prior distribution cases and to defraud IPG's creditors ...."

Literally nothing supports these malicious accusations of the SOC. If the

SOC is. so confident as to utter any of the foregoing accusations outside of the context of litigation, Multigroup Claimants welcomes such opportunity and the

A.2d 691, 695 (2008), citing Rainier's Dairies v. Raritan Valley Farms, Inc .. 19 N.J. 552, 562, 117 A.2d 889 (1955).

2 Since its inception in 1998, no party has ever brought suit against IPG for failure to properly account for collected royalties, nor has IPG ever found it necessary to negotiate a settlement with any party, confidential or otherwise, based on any allegation of a failure to account. See Exhibit A (Deel. of R. Galaz).

5 inevitable prosecution of the SDC and its legal counsel for its multiple accusations of criminal acts. 3

In fact, throughout its discourse, it is the SDC that makes multiple, significant false statements.

Falsity #1: Multigroup Claimants did not "substantially refuse to respond to many of the SDC's discovery requests." Review ofMC's discovery objections reveals the fact that several SDC "document" requests were, in fact, interrogatories, or sought information relating to parties for whom MC does not even make claim for in these proceedings, e.g., Bob Ross, Inc., Feed the Children.

See SDC Exh. 4 (MC responses to SDC initial and follow-up discovery).

Following MC's articulated objections, the only two areas of interest for which the

SDC then moved to compel production were the employment agreements of two individuals, and the legal structure of Multigroup Claimants.

Ironic to the SDC's argument is that MC's document requests were effectively identical to those propounded by the SDC, yet the SDC refused to produce documents reflecting the legal structure of its claimants. The Judges ultimately compelled MC to produce documents relating to the MC legal structure, but did not compel the SDC to similarly produce such documents, holding that:

3 A false accusation of a criminal act constitutes defamation per se, for which injury is presumed and need not be proven by the offended party. See California Civil Code Section 45(a), and Yow v. National Enquirer, Inc., 550 F.Supp.2d 1179, 1183 (E.D. Cal. 2008).

6 "When addressing the issues of these two particular participants with regard to business ownership, relationships, and asset transfers, sauce for the goose is not, ipso facto, sauce for the gander.

Cf. Order Granting In Part Settling Devotional Claimants ' Motion to Compel

Production by Multigroup Claimants at p. 3 (Sept. 14, 2016), with Order Granting

In Part and Denying In Part Multigroup Claimants Motion to Compel Production by Settling Devotional Claimants at p. 4 (Sept. 14, 2016).

Regardless of such disparate application of discovery, after being ordered to produce such documents, which the SOC did not similarly produce, MC nonetheless complied. The sole responsive document reflecting the "legal structure" of MC was a recorded filing in Bell County, Texas and was produced on

September 22, 2016. See SOC Exh. 9. To MC's awareness, no further issue surrounding such matter existed.

Falsity #2: MC did not "[seek] to deceive the Judges and other participants concerning the true identity of [Multigroup Claimants] and

Spanish Language Producers." As part of its initial production of documents on

April 6, 2016, Multigroup Claimants produced the aggregate chain-of-title for any programs claimed in this proceeding, i.e., all documents reflecting agreements amongst the underlying copyright owner claimants, IPG, SLP, and MC. Notably, the authorization and transfer documents amongst IPG, SLP, and MC clearly and conspicuously reflect the names of all signatories, including that of"Al Galaz" as a

7 signatory for SLP and MC. See SDC Exhs. 9 and 39. Notwithstanding, and without explanation, the SDC accuse that Al Galaz's identity has remained

"concealed" in an attempt to "deceive the Judges and other participants". Not a single fact supports the SDC accusation, which runs contrary to the fact that all

SLP and MC documentation was produced.

As part of its accusation of covert activity, the SDC further charge that MC failed to produce documents relating to the legal structure of Spanish Language

Producers, despite a demand therefrom by the MPAA, but that the MPAA nevertheless obtained a document reflecting SLP' s legal structure by "cleverly request[ing] [documents] from public records in California." The referenced document is attached as Exhibit 39 to the SDC motion. As an initial matter, SLP does not, nor ever has, asserted a claim in the devotional programming category.

Moreover, the SDC conveniently fail to address that the MPAA did not submit a request for documents relating to the SLP legal structure in the course of discovery, and for such reason obscure that the MPAA' s informal email "demand" first came on October 4, 2016, i.e., over six months after initial discovery requests were propounded, and five weeks after the close ofdiscovery. 4 See SDC Exh. 38.

4 Equally as ridiculous in the email string is that the SDC counsel chimed in to threaten that if it turns out that MC has concealed that SLP is another assumed name of Al Galaz, that the SDC will "certainly move for discovery sanctions." Such statement ignores the very subject of the email string, i.e., that the MP AA was complaining that MC made no representations at all regarding either the

8 As reflected by IPG' s response thereto, the MPAA attempted to distort both the

interpretation of its prior discovery requests and an order by the Judges in order to

untimely demand further documents. Id. MC's counsel informed the MPAA's

counsel of as much, and informed the MPAA that no post-discovery documents

would be produced. Id. For such obvious reasons, the MPAA did not file a motion

to compel documents related to this post-discovery request. Further, MC is wholly

unaware of what "clever" discovery was derived from public records in California,

as SLP does not have, nor ever has had, any association with the state of

California, a fact evidently verifiable by the face of the SDC's Exhibit 39.

As is also evident from SDC Exhibits 9 and 39, MC and SLP are two

different sole proprietorships. Nonetheless, the SDC attempt to distort this fact by

arguing that their common ownership by Al Galaz somehow makes them

indistinguishable. In fact, the SDC go so far as to argue that when these separate

entities, each of which separately filed petitions to participate in these proceedings,

elected to have all claims prosecuted by MC, it was somehow deceptive for such

ownership or organizational structure of SLP, nor produced documents relating thereto. Again, MC produced no documents relating thereto for the obvious reason that discovery was not even propounded regarding such topic. Moreover, despite the SDC's and MPAA's protestations to the contrary, SLP is no longer even a participant in the proceedings, having transferred all of its interests to MC and filed that attestation with the CRB.

9 parties to file with the CRB a notice that all of SLP' s claims would be transferred to and handled by MC.

The SOC even go so far as to accuse MC's legal counsel of engaging in a deception, querying "why would Alfred Galaz and his counsel ... go to such lengths to fabricate the illusion that [MC] and SLP are separate and distinct entities?". The obvious response: because they are separate entities, that were initially proceeding independently of each other with mutually exclusive program claims (Spanish language programming, non-Spanish language programming), and no "lengths" were ever taken to even address their ownership or organizational structure - the very fact repeatedly complained of by the SOC. But again, it is the

SOC that engages in deception, by fabricating conclusory accusations based on nothing, perhaps believing that if the same falsity is repeated frequently enough, the Judges will begin to believe it.

As should be evident from the moniker "Spanish Language Producers", such entity was initially formed for the purpose of establishing Spanish language programming as a separate Phase I category. Even documents produced by MC as early as April 2016 reflect such fact, wherein IPG' s authorization and transfer to

MC (SOC Exh. 9) states:

"Such authorization and transfer shall apply to all categories of programming, subject to the caveat that it shall include Spanish language programming only in the event that such programming is not

10 defined as a separate "Phase I" category, whether by order or stipulation of participants in such proceedings."

See SDC Exh. 9.

Correspondingly, the IPG' s authorization and transfer to SLP, which the

SDC conveniently failed to include as an exhibit, states:

"Such authorization and transfer shall apply only to Spanish language programming, and only in the event that such programming is defined as a separate "Phase I" category, whether by order or stipulation of participants in such proceedings." In the event that such Spanish language programming is not defined as a separate "Phase I" category, the authorization and transfer herein shall inure to the benefit of Multigroup Claimants, according to an authorization and transfer simultaneously effectuated."

See Exhibit F; see also, SLP Petitions to Participate for 2010-2013 cable and satellite ("SLP maintains claims in the yet-to-be-established Spanish language programming category".).

Considering the foregoing, the SDC's "straw man" argument of accusing

MC of misleading any party about the ownership or organizational structure of either MC or SLP is revealed to be nothing more than hot air. Disappointingly, however, SDC's counsel not only distorts such facts, but then relies on his own misstated facts to make accusations that he is fully aware are false, i.e., that any element of fraudulent activity is involved.

Falsity #3: Al Galaz has never been found to have engaged in any fraudulent activity. The.SDC uses its motion as an opportunity to direct the

11 Judges to all matters of litigation involving Raul Galaz, Al Galaz, and Denise

Vernon. Notably, and despite the SDC's mischaracterization, three of the four cited cases did not involve allegations of fraudulent activity by either Raul Galaz,

Al Galaz or Denise Vernon, 5 and the fourth case expressly found no fraudulent activity by Al Galaz, and is nevertheless under appeal to the Federal Court of

Appeals for the Fifth Circuit after already previously being vacated as a ruling

5 Suenos v. Satchell, et al.; SDC Exh. 15: Plaintiff Segundo Suenos' claims were dismissed because it failed to adequately establish its standing to bring a claim against the named defendants, and an inadequate record on appeal foreclosed the appellate court from addressing Segundo's arguments regarding the adequacy of its entitlement.

Galaz v. Jackson; SDC Exh. 16: Raul Galaz sued his acknowledged co­ conspirator in his crime in order to have such co-conspirator return the stolen funds to the victim, the MPAA. Contrary to assertion of the SDC, Raul Galaz did not sue to "enforce" an illegal contract, but rather to have the Court "rescind the illegal contract" and return the money to the MPAA. Raul Galaz's claims were dismissed subject to the defendant's "unclean hands" defense and statute of limitations, but noting the candor and truthfulness of Raul Galaz about his prior criminal act ("Having listened to the testimony of the two witnesses, Galaz and Jackson, the trial court found Galaz had testified truthfully, while Jackson had given false testimony".). Id. at p. 3.

Galaz v. Katona; SDC Exh. 11 : Al Galaz (assignee of rights held by Marian Oshita) sued Lisa Katona for her failure to account to co-owner Marian Oshita for sums owed to Oshita. The matter is currently on appeal before the Federal Court of Appeals for the Fifth Circuit on grounds that, for a third time, a bankruptcy court in San Antonio, Texas has asserted jurisdiction over matters involving Lisa Katona to which it has no subject matter jurisdiction.

12 beyond the jurisdiction of the bankruptcy court. 6 The SDC apparently find great significance in the fact that Al Galaz is the father of Raul Galaz and Denise

Vernon.

The obvious question is what these cited matters of litigation have to do with any matter before the Judges. Three of the four matters involve claims brought by

Al Galaz or Raul Galaz as plaintiffs. Not only do the cases have no relation to any matter before the Judges, they do not even establish the pattern of malfeasance that the SDC suggests. They are, quite simply, an effort by the SDC to parade a variety of matters before the Judges to suggest that where there is strife, there is malfeasance by any involved party - even a plaintiff.

Beyond the foregoing aspersions, the SDC make a prodigious number of specious arguments, which MC addresses as follows.

6 Galaz v. Galaz, et al.; SDC Exh. 12: At issue are the proposed findings of fact by a bankruptcy court located in San Antonio, Texas that declined to find any fraudulent activity on the part of Al Galaz, but nevertheless premised fraudulent activity by Raul Galaz on the forwarding of a capital call letter to Julian Jackson at an address required by the operative Operating Agreement, ostensibly knowing that such letter would not be received. Despite the Federal Court of Appeals vacating the bankruptcy court's initial ruling, such bankruptcy court issued a substantively identical ruling after refusing to allow post-trial briefing on the case. Only now are factual issues demonstrating the inaccuracy of the bankruptcy court's proposed factual findings being addressed.

13 ARGUMENT

A. AS A MATTER OF CONTRACT AND OF LAW, MULTIGROUP CLAIMANTS HAD NO OBLIGATION TO OBTAIN CONSENT TO MAKE PROGRAM CLAIMS DIRECTLY FROM THE UNDERLYING OWNER OF COPYRIGHT.

The SDC's initial argument is to point out what was acknowledged and documented from the outset, i.e., that Multigroup Claimants is a participant in these proceedings, and represents the interests of IPG. For reasons that are wholly unclear, the SDC criticize that the document memorializing such authority is

"poorly drafted" because:

"The document fails to provide any details whatsoever regarding [Multigroup Claimants], whether [Multigroup Claimants] is a business entity or individual, whether [Multigroup Claimants] has any agreement with any copyright claimant, and what capacity [Multigroup Claimants] has to act as a party in this proceedings, all of which are relevant to [Multigroup Claimants'] status as a participant in these cases.

SDC motion at 3.

Why the authorization and transfer document should even address these

subjects of apparent SDC interest is unstated and, as a rather obvious point, no

explanation is provided as to why such transfer document needs to identify

whether MC is a corporation, partnership, limited liability company, or sole

proprietorship.7 It simply would not matter.

7 The SDC further criticize that the petitions to participate filed by MC and SLP in these proceedings also failed to clarify the organizational structure of MC and

14 MC has already produced all the agreements between underlying copyright owner claimants and IPG (the same documents produced in numerous prior proceedings). Notably, none of those agreements restrict IPG's authority to engage third parties to perform some or all of IPG's duties, and no rule of law precludes such assignment of responsibilities. All agreements between IPG and the MC- represented copyright owners are subject to the jurisdiction of California law, and under California law a party has no obligation to obtain the permission of its

obligees to assign its rights and responsibilities to another. Specifically, California

Civil Code Section 955.1 sets forth the requirements under California law for an

assignment:

"Transfer of General Intangibles. (a) ... a transfer other than one intended to create a security interest ... of any payment intangible ... and any transfer of accounts, chattel paper, payment intangibles, or promissory notes ... shall be deemed perfected as against third persons upon there being executed and delivered to the transferee an assignment thereof in writing."

See also, Royal Bank Export Fin. v. Bestways Distributing ( 1991) 229 Cal.

App. 3d 764, 767 ("once the transferee receives possession of the instruments, duly

endorsed or assigned in writing by the transferor, the transfer of title is complete.")

Contrary to the SDC's argument, MC has the authority to make the program

claims it has made in this proceeding, derivatively through IPG. Predictably, the

SLP. As the Judges are presumably aware, such information was not solicited, nor has ever been solicited, as part of the filings of petitions to participate.

15 SDC cite to no authority requiring MC to obtain authority directly from the MC- represented claimants. 8

In fact, most IPG agreements engage IPG to collect royalties for copyright owners on a worldwide basis, IPG regularly engages third parties to collect royalties from the foreign equivalent of the U.S. Copyright Office, and on not a single occasion since IPG's formation in 1998 has an !PG-represented claimant challenged IPG' s authority to engage third parties in its collection efforts. See

Exhibit A (Deel. ofR. Galaz). Not surprisingly, the SDC do not present a single

MC-represented claimant to object to MC's prosecution of rights in these proceedings.

As a basis of comparison, not only have the Judges refrained from imposing the condition advocated by the SDC on the MPAA, whose vast majority of program claims are derivatively made through agents (see generally, Multigroup

8 The only authority cited for any purpose in the SDC argument is a reference to an excerpt from a prior ruling of the Judges that includes an obvious statement, i.e., that "IPG must have representation authority from each rights holder that IPG purports to represent". SDC motion at p. 5. Such excerpted language, however, did not relate to a situation such as that which the SDC currently challenges, i.e., where authority was granted by underlying claimants to IPG, and then such authority was transferred to SLP and MC. Moreover, even if a comparable scenario had existed, the full text of the excerpt reflects that a challenge is not viable "unless another party raises a reasonable objection that would preclude or rebut the presumption". Because the SDC present no evidence that any MC­ represented claimant objects to MC's prosecution of their program claims, no "reasonable objection" has been raised.

16 Claimants' Motion to Strike Claims ofMP AA), but have not even required that the

MPAA produce in discovery the contracts between the underlying copyright owners and their agents, or even produce correspondence from the underlying copyright owners confirming their entitlement to retransmission royalties attributable to MP AA-claimed programs. As such, affirming the position advocated by the SDC, i.e., that MC must demonstrate direct agreement between itself and its represented claimants, would stand in stark contradiction to the

Judges' prior rulings.

To summarize, the SDC's challenge that MC must have obtained express authorization directly from each MC-represented claimant to make claim for its programming in this proceeding, rather than authorization derivatively through

IPG, is incorrect as a matter of contract and a matter of law, thereby making the

SDC argument "much ado about nothing".

B. DENISE VERNON HAD THE AUTHORITY TO MAKE 2010 "JULY CLAIMS" ON BEHALF OF IPG; NO DOCUMENTS SUGGEST THE CONTRARY; NO DOCUMENTS RESPONSIVE TO THE SDC DOCUMENT REQUESTS WERE WITHHELD.

From May 18, 2011 through November 25, 2011, as a result of a dispute between IPG co-owners Lisa Katona and Denise Vernon, a bankruptcy court appointed an interim receiver to manage the business ofIPG. SOC Exhs. 21, 22.

As is evident on its face, such order states that the appointed receiver will manage the business of IPG, not that the interim receiver will perform all of the functions

17 of IPG. In rather explicit fashion, the order references several different business- related functions typically handled by several persons, including Lisa Katona,

Denise Vernon, Brian Boydston, Raul Galaz, and Jeff Sedacca. Nothing in such order suggests that the appointed receiver decided for IPG to not submit a 2010

"July claim". Nothing in such order suggests that the appointed receiver instructed

Denise Vernon to not submit the 2010 "July claim".9 Nothing in the order suggests that Denise Vernon was acting beyond her authority, or contrary to the authority of the appointed receiver, when she filed the 2010 "July claim" on behalf ofIPG. In fact, Ms. Vernon's filing of the 2010 "July claim" was expressly authorized by and known by the interim receiver, as were all actions taken by Ms. Vernon on behalf ofIPG at such time. See Exhibit B (Deel. ofD. Vernon).

Nevertheless, the SDC argue that the bankruptcy court order should have been produced as responsive to several SDC documents requests. The SDC is simply wrong:

-- the bankruptcy court order does not underlie the basis for IPG to file claims in these proceedings (SDC request no. 7);

9 The SDC note that the order stated "Denise Vernon, Lisa Galaz, and WSG acting through Raul Galaz are enjoined from signing any contract or lease or incurring any debt in the name of or on behalf ofWSG." SDC motion at p. 19. Why such provision is cited is unclear, as the filing of a "July claim" is not the signing of a contract or lease, or the incurrence of debt.

18 -- the bankruptcy court order does not undermine the basis for IPG to file claims in these proceedings (SDC request no. 8);

-- the bankruptcy court order does not relate to any termination, threatened termination, or expiration of IPG's authority to file claims in these proceedings (SDC request no. 9).

Consequently, the bankruptcy court order is not responsive to any of the

SDC document requests, no matter how tortured and expansive of an interpretation the SDC attempt to apply.

C. SALEM BAPTIST CHURCH OF CHICAGO HAS AFFIRMED ITS OWNERSHIP OF PROGRAMMING CHALLENGED BY THE SDC, AND THE SDC PROVIDE NO INFORMATION CONTRADICTING SUCH CLAIM.

As an initial matter, the SDC rely on an SDC-created exhibit (SDC Exh. 19) which misrepresents information appearing in electronic files produced by MC.

Therein, such document purports that MC has made claim for programs such as

"Chicago, Inc." and attributed it to devotional claimant Salem Baptist Church of

Chicago, Inc., when no such program claim has been made. 10 See SDC Exh. 19, at p. 2.

The SDC take issue with MC's claim for programming under a variety of titles, asserting:

10 MC can only suppose that SDC Exh. 19 was derived from an MC-produced spreadsheet, but that the SDC then reformatted such spreadsheet in a manner that misstates the information appearing under the heading "PROGRAM". While such an error might normally be inconsequential, the fact that the SOC argument relates to the accuracy of the program title makes such error significant.

19 "Presumably, MGC believes it is entitled to claim royalties for any program associated with a church that contains the phrase "Salem Baptist" or "Salem Church," regardless whether there is any evidence associating the program with Salem Baptist Church of Chicago."

SDC motion at p. 20-21.

On the contrary, MC's predecessor (IPG) was expressly informed by Salem

Baptist Church of Chicago, Inc., that broadcasts of programs with the SDC challenged titles were, in fact, produced and owned by such claimant.

As a matter of background, in prior proceedings, IPG acquired broadcast data from Tribune Media (previously known as TV Data). When acquiring such data, Tribune Media explicitly explains it process for pre- and post-broadcast title verification, which necessarily depends upon submissions to Tribune Media by the television stations that are broadcasting a program. Because there is not always uniformity by such television stations in the title ascribed to a particular program, a common effect is for the identical program to be identified in multiple ways, e.g.,

"Oprah", "Oprah Winfrey", "Oprah Winfrey Show", "The Oprah Winfrey Show".

See Exhibit A (Deel. ofR. Galaz).

In prior proceedings, IPG submitted to devotional claimant Salem Baptist

Church a list of broadcasts with program title derivations of its name. Particularly when there are multiple similar names, it is necessary to verify that the broadcasts are of the program for which the claimant has asserted a program claim. Notably, no other participant in these proceedings (other than IPG) has ever submitted lists

20 of program broadcasts to verify the accuracy of the program claim. In the case of

Salem Baptist Church of Chicago, Inc., for the 2000-2003 cable proceedings

(Phase II), such entity confirmed that the broadcasts of "New Salem Baptist

Church", "New Salem Church", and "Salem Church", were broadcasts of the programming produced and owned by Salem Baptist Church of Chicago, Inc. See

Exhibit C (response of Salem Baptist Church affirming and disaffirming claim to particular broadcasts). By contrast, broadcasts of a program identified as "Greater

Salem Church" was expressly rejected by Salem Baptist Church of Chicago as broadcasts of a program not claimed by such entity. Id. As revealed from its face, the document attached hereto as Exhibit C was previously produced by IPG to the soc.

The aggregate of the SDC argument is that there is evidenced from a Google search the existence of other churches with "Salem" in their name. However, such

Google searches do not even suggest that any of these other entities produce or air a television program. Literally nothing within SOC Exhibit 23 contradicts the claim by Salem Baptist Church of Chicago, Inc. to the programs for which it has made claim.

21 D. THE SDC PERSIST IN DEMANDING A DISCOVERY SANCTION FOR THE PRODUCTION OF DOCUMENTS THAT SIMPLY DO NOT EXIST.

The SDC urge a discovery sanction against MC for its failure to produce documents which simply do not exist, a fact that has been reiterated on several occasions in prior proceedings. 11 Although the SDC argue that its follow-up request sought the "two agreements with Copeland" referenced in an email dated

November 23, 2005, such follow-up request actually sought five separate

categories of documents. See SDC Exh. 26 (Request no. 41 ). MC did not object to the request, and responded by producing all documents in its possession that

were responsive.

MC can only speculate as to what the author of the 2005 email was referring,

which could have been affirmations by Kenneth Copeland Ministries to a Canadian

organization as to the validity ofIPG's representation, or any variety of other

possibilities. It simply is not clear. Regardless, MC has comprehensively

produced all responsive documents in its possession. According to prior rulings of

the Judges:

"It is a basic principle of discovery that a party cannot be required to produce documents that do not exist. Accordingly, a party cannot be

11 See, e.g., Docket nos. 2012-6 CRB CD 2004-2009 and 2012-7 CRB SD 1999- 2009, !PG Second Motion/or Modification ofthe March 13, 2015 Order (filed March 20, 2015).

22 sanctioned for failing to produce non-existing documents in discovery. See, e.g., Hagemeyer N Am., Inc. v. Gateway Data Scis. Corp., 222 F.R.D. 594, 598 (E.D. Wis. 2004) ("A party need not produce documents or tangible things that are not in existence .... "); Sonnino v. Univ. ofKansas Hospital Auth., 220 F.R.D. 633, 640 (D Kan. 2004) ("The Court cannot compel a party to produce documents that do not exist .... ")."

Docket No. 2008-1 CRB CD 98-99 (Phase II), Order Denying IPG Motion to

Strike at pp. 8-9 (May 2, 2014). 12

Regardless, and but again, the SOC urge sanction again three parties, even though the author of the email, David Joe, has never been legal counsel to one of those claimants, Creflo Dollar Ministries, and was not legal counsel to another at the time of the email, Benny Hinn Media Ministries. Moreover, the SOC urge sanction against three entities even though they allege, without substantiation, that

IPG has refused to produce "two agreements" with only one of those entities,

Kenneth Copeland Ministries.

Quite simply, there is nothing on which to base a discovery sanction.

12 In fact, in its ruling the Judges went so far as to reject IPG's contention that the SOC could have obtained the requested information from the MP AA, but had refused to do so. According to the Judges, it was "of no consequence" that the missing information may have been with the MP AA (the identified source of the information) and that the SOC had made no attempt to secure it from the MPAA, irrespective of IPG' s demand that the SDC make such request. Id. The Judges further held that IPG had not attempted to prove that the SDC had the ability to obtain the requested information from the MPAA, even though such fact was acknowledged, and that it was IPG's burden to prove such fact. Id.

23 E. THE SDC BLATANTLY MISREPRESENT THE SUBSTANCE OF KENNETH COPELAND MINISTRIES EMPLOYMENT AGREEMENTS AS A PREDICATE TO ARGUING THAT THE "KENNETH COPELAND" TELEVISION PROGRAM IS NOT OWNED BY KENNETH COPELAND MINISTRIES.

In their zeal to exclude any program claim for the "Kenneth Copeland" television program, the SDC present an embarrassing argument that blatantly misrepresents the substance of two employment agreements. The SDC recite the text of a provision appearing in two employment agreements, but glaringly fail to address two phrases therein that outright clash with the conclusion sought by the

SOC, then rearrange documents produced by MC in discovery, then fail to address another provision within both employment agreements that twice affirmatively refers to the fact that the "Kenneth Copeland" television program is owned by MC- represented claimant Eagle Mountain International Church, Inc. dba Kenneth

Copeland Ministries. 13

First, the SOC cite to section 1.4 of both employment agreements for the proposition that ownership to all works of authorship (by Kenneth Copeland and

Gloria Copeland) are retained by such individuals. However, that is not what the provision states. First, and as reflected in the body of section 1.4, the works of authorship for which the Copelands retain ownership (that is subject to an ongoing

13 The "Kenneth Copeland" television program is often referred to as such because of its primary host, Kenneth Copeland. However, the program's actual name is "Believer's Voice of Victory".

24 license for Eagle Mountain to exploit) are identified in Exhibit A to such agreement. SDC Exhs. 27, 28 at section 1.4. Exhibit A to both employment agreements does not identify the "Kenneth Copeland" television program, by that name or any other. 14 See SDC Exh. 27. Ergo, the predicate of the SDC argument that Kenneth and Gloria Copeland have retained ownership to the "Kenneth

Copeland" television program is directly contradicted by the fact that such television program does not appear on the "Exhibit A" list of programs for which copyright ownership is retained by such individuals. 15

14 The SDC misrepresent the documents that were produced by MC by rearranging them. On September 22, 2016, MC electronically produced three separate documents to the SDC relating to this subject: (i) the employment agreement of Gloria Copeland; (ii) the employment agreement of Kenneth Copeland; and (iii) "Exhibit A" to both employment agreements. The documents were scanned and titled, respectively, (i) "2016-09-19 REDACTED Gloria Copeland Employment Contract 01-01-07.pdf', (ii) "2016-09-19 REDACTED Kenneth Copeland Employment Contract 01-01-07 .pdf', and (iii) "Exhibit A to Copeland Employment Contracts - Royalty Bearing Products.pdf'. MC further separately served the Declaration of Brian Boydston in support of designation of restricted documents, which separately identified these three documents. See SDC Exh. 27.

Nevertheless, in their presentation to the Judges, the SDC rearrange the four aforementioned documents. As SDC Exhibit 27, the SDC include the Boydston declaration, then attach the third document (Exhibit A) to the first document (the Gloria Copeland employment agreement), attempting to portray Exhibit A as not also being Exhibit A to the Kenneth Copeland employment agreement. SDC Exhibit 28 is the employment agreement of Kenneth Copeland, presented without its Exhibit A attachment.

15 To avoid any predictable accusation of malfeasance by the SDC, Exhibit A to the employment agreements is a periodically updated list of works for which

25 Second, section 1.4 of both employment agreements states that Kenneth and

Gloria Copeland will retain copyright ownership "with the exception of such works whose ownership is specifically designated as belonging to [Eagle Mountain

International Church]." SDC E:xhs. 27, 28. As discussed infra, at the conclusion of each episode of the television program "Believer's Voice of Victory" aka

"Kenneth Copeland" there expressly appears a copyright notice in the name of

Eagle Mountain International Church. Moreover, and as stands as the example of the SDC affirmatively ignoring a relevant provision of the employment agreements, the opening recitals of both employment agreements refer to

the "[Eagle Mountain] television program 'Believer's Voice of Victory'"; and

the "[Eagle Mountain] broadcast entitled 'Believer's Voice of Victory"'.

SDC Exhs. 27, 28 at opening recitals.

Notably, both references are to "Eagle Mountain's" program and broadcast,

making abundantly clear that such television program is the property of Eagle

Mountain, not employees Kenneth and Gloria Copeland.

Kenneth and Gloria Copeland retain copyright ownership, and such fact is addressed in section 1.4 of both employment a&reements which expressly contemplates the amendment of Exhibit A to provide an updated list of works. It is exclusively for such reason that the employment agreements are dated in January 2007, and Exhibit A is dated September 2012. That is, Exhibit A is an updated version of works for which Kenneth and Gloria Copeland retain copyright ownership.

26 Regardless, and as was already noted in MC's Opposition to SDC Motion to

Compel Production ofDocuments, filed July 28, 2016, the ownership of the

"Kenneth Copeland" program has been litigated before, and Jan Harbour, Eagle

Mountain's Chief Financial Officer, has gone on the record, by both sworn testimony and written declaration, confirming the fact that Eagle Mountain owns the programs at issue. See Exhibit D. In a subsequent declaration executed by

Ms. Harbour, Rev. Kenneth Copeland, and Rev. Gloria Copeland, each of those individuals has attested under penalty of perjury that:

Eagle Mountain owns the television programming at issue;

the Copelands have no personal ownership interest in any of the television programming;

Eagle Mountain produces the programs at issue;

the programs are produced exclusively by Eagle Mountain employees;

all programs are produced at Eagle Mountain's facilities at Eagle Mountain's cost;

all programs are aired at Eagle Mountain's cost; and

the Eagle Mountain copyright notice appears on each episode of the television program.

See SDC Exh. 31.

No different than in its motion to compel the production of the employment agreements, rather than take this document for its obvious sworn statements, the

SDC chooses to characterize Eagle Mountain's attestation as a surreptitious

27 conspiracy to hide some alternative truth. As MC reminds the Judges, the premise of the SDC argument that the employment agreements for the Copeland should be produced was a line appearing in a Senate Report that the Judges previously found to be "hearsay and of questionable reliability" (see Ruling and Order Regarding

Claims and Separate Opinion, Docket No. 2008-1 CRB CD 1999-1999 (Phase II)

(June 18, 2014) at 18), and which in any event was misquoted by the SDC to

remove language making clear that the seminal phrase upon which the SDC relied

was unrelated to the "Kenneth Copeland" television program.

But again, not a single piece of evidence corroborates the SDC allegation

that the "Kenneth Copeland" television program is not owned by Eagle Mountain

International Church, Inc. dba Kenneth Copeland Ministries.

F. THE SDC MAKE NO SUBSTANTIVE ARGUMENT FOR THE DISMISSAL OF IWV MEDIA'S CLAIM, PREMISE THEm ARGUMENT ON A MISREPRESENTATION OF THE CONTENTS OF MAUREEN MILLEN'S DECLARATION, AND MISCHARACTERIZE BROADCAST NETWORKS AS CABLE NETWORKS.

In order to challenge the devotional claim of IWV Media, the SDC attach

the Declaration of Maureen Millen, submitted by IPG in connection with the

consolidated 1999-2009 satellite and 2004-2009 cable proceedings. See SDC Exh.

32.

In a word, the SDC challenge is frivolous. First, the SDC points out that

Ms. Millen ceased production of programming in 2005. Obviously, such fact is

28 irrelevant ifIWV Media's programming was nonetheless broadcast at any time

from 2010-2013.

Second, Ms. Millen indicates in her declaration that she "could not locate her records or agreements". However, Ms. Millen describes in great detail the

formation and agreement with IPG, and her dealings with IPG, in order to

demonstrate the timeliness and existence of an agreement with IPG. As the record

reflects, Ms. Millen's declaration as to such matters was in response to challenges

that IWV Media had not timely engaged IPG, an allegation that Ms. Millen

soundly refuted. See SDC Exh. 32.

Third, the SDC refer to Ms. Millen' s statement that her program Primary

Focus was aired on Trinity Broadcasting Network ("TBN"), Christian

Broadcasting Network ("CBN"), and DayStar TV. In what is now commonplace

for the SDC, the SDC conveniently omit a single word from Ms. Millen's

declaration, where she states that Primary Focus was "predominantly" aired on

TBN, CBN, and DayStar TV. More to the point, Ms. Millen's attestation

regarding Primary Focus airing on such networks was to address the SDC's

challenge that Primary Focus was not devotional in nature, and her observation

29 that TBN, CBN, and OayStar TV are television networks exclusively distributing religious content programming. 16

Notwithstanding the SDC's misrepresentation regarding Ms. Millen's declaration, the SOC further argue- incorrectly- that TBN, CBN, and DayStar

TV are all "cable networks" not subject to the generation or distribution of retransmission royalties. In fact, each of those "networks" each constitute a group

of over-the-air broadcast stations associated with each other in order to create a

"network". 17 That is, they are not "cable networks", as the SOC assert.

Consequently, such broadcast stations do generate retransmission royalties (if

distantly retransmitted by a cable or satellite system), and programming thereon

would qualify for royalties in a distribution proceeding.

G. NO EVIDENCE SUGGESTS THAT IPG ACTED IN BAD FAITH REGARDING CLAIMS ATTRIBUTABLE TO BOB ROSS, INC.

Continuing with its shameless mischaracterization of events, the SDC assert

that IPG "embezzled" monies from Bob Ross, Inc., asserting that IPG acted in a

16 As Ms. Millen points out in her declaration, Primary Focus was hosted by Rev. Cal Brenner as a television magazine format that examines current issues through a biblical perspective, concluding each episode "with a question to the viewer whether they would now accept Jesus as their savior". SOC Exh. 32.

17 Such fact is easily determinable by multiple online sources. Attached as Exhibit E are printouts of relevant pages regarding such broadcast networks appearing at the online source Wikipedia. Each source identifies TBN, CBN, and OayStar TV as broadcast networks, often identifying the broadcast stations affiliated with such networks.

30 matter that permeates these proceedings and must result - to the SDC' s benefit - in the abrogation of all presumptions otherwise afforded to all participants, and the dismissal of all ofMC's claims. According to the SDC, the Judges need look no further than the SDC-drafted declaration of Walter Kowalski, a representative of

Bob Ross, Inc.

As the Judges may recall, this issue was thoroughly vetted in the

consolidated 1999-2009 satellite, 2004-2009 cable proceedings. Therein, the SDC

made the identical argument set forth herein, and after considering all the evidence,

the Judges did not even see fit to make any legal finding adverse to IPG. See

Memorandum Opinion and Ruling on Validity and Categorization ofClaims

(March 13, 2015). The SDC make no further argument in connection thereof, and

present no further evidence, other than deposition testimony demonstrating that the

status quo remains the same. 18 In fact, the SOC rely on the identical exhibits and

testimony that were presented to the Judges in the consolidated proceedings, minus

the SDC's conspicuous failure to present the controverting evidence and testimony

provided by IPG. On this basis alone, collateral estoppel precludes further

consideration of such issue.

Notwithstanding, MC is obligated to respond to the SDC's misstatements.

Notably, Bob Ross, Inc., is not even a devotional claimant. Notably, MC does not

18 Specifically, in an unrelated proceeding Raul Galaz testified that Bob Ross, Inc. has still refused to cash the check that IPG previously forwarded. SDC Exh. 34.

31 even make claim for Bob Ross, Inc. in these proceedings. Notably, IPG collected royalties attributable to Bob Ross, Inc. vis-a-vis its agreement with PBS for PBS to act as IPG's agent for the collection of retransmission royalties attributable to the non-commercial broadcasting category, and no issue exists or has been raised by

PBS challenging IPG's actions as having been in bad faith. Each of the foregoing

facts independently warrants the Judges' disregard of the SDC proverbial "beating

of a dead horse" and, moreover, precludes intrusion into what can at worst be

considered a contractual dispute between IPG and Bob Ross, Inc. 19

As Mr. Kowalski's testimony and declaration reflect, IPG did not

"embezzle" funds, i.e., fraudulently appropriate monies due to Bob Ross, Inc. On

the contrary, IPG and Bob Ross, Inc. had entered into multiple one-year

agreements, and IPG was under a good faith impression that the last agreement

entered into by Bob Ross, Inc. was a continuing Letter of Extension for IPG' s

representation. Based thereon, IPG continued to submit claims on behalf of Bob

Ross, Inc., received non-commercial royalties, and accounted to Bob Ross, Inc. on

19 As the Judges noted in a recent ruling relating to this identical matter, "the Act does not authorize the Judges to adjudicate or mediate contract disputes". Docket Nos. 2012-6 CRB CD 2004-09 (Phase II) and 2012-7 CRB SD 1999-2009 (Phase II), Order Granting in Part and Denying in Part !PG 's Motion for Partial Distribution ofProgram Suppliers ' Royalties at p. 9 (Sept. 29, 2016).

32 several separate occasions for 2004-2007 retransmission royalties. After receiving non-commercial royalties attributable to calendar year 2008, IPG was informed in an unnecessarily adverse manner that IPG should not have made claim for the 2008 royalties and to forward those newly-collected royalties to Bob Ross, Inc.

IPG inquired whether Bob Ross, Inc. wanted to receive the collected

royalties less the IPG commission, or for the entire amount to be returned to PBS.

Bob Ross, Inc., through its newfound legal counsel Ted Hammerman, insisted that

the entirety of the royalties, without deduction for IPG' s commission, be paid over

to Bob Ross, Inc. IPG stated that it could not rationally do the same, and timely

and promptly accounted to Bob Ross, Inc. for the 2008 royalties, a fact

demonstrated by the check and accounting that IPG forwarded.

The foregoing facts are undisputed and reflected in the attachments to Mr.

Kowalski's declaration. SDC Exh. 33. They are not a basis for accusing IPG of

malfeasance, much less "embezzlement". Consequently, even ifthe Judges had

not already ruled on this matter after considering the identical evidence; even

disregarding that IPG does not make claim for Bob Ross, Inc. royalties in these

proceedings; even disregarding the SDC' s lack of standing to address a claim for

royalties between IPG and Bob Ross, Inc.; even if this were not a contractual

dispute (at worst) between IPG and Bob Ross, Inc. - nothing suggests any actions

on the part of IPG that are worthy of concern.

33 Indeed, what should be of concern is the SDC' s persistent mischaracterization of events in order to glibly accuse IPG of fraudulent activity when no hint of fraud exists. The SDC's actions are unbecoming, are chronically impugning the professionality of these proceedings, and absent some sanction or discouragement by the Judges for the SDC's repeated exaggerated accusation, the

SDC will continue to make such accusation without any concern for the accuracy of its pleadings.

CONCLUSION

For the reasons set forth herein, the SDC motion should be denied in its entirety.

Dated: October 28, 2016 ---Isl------Brian D. Boydston, Esq. California State Bar No. 155614

PICK & BOYDSTON, LLP 10786 Le Conte Ave. Los Angeles, California 90024 Telephone: (213) 624-1996 Facsimile: (213) 624-9073 Email: [email protected]

Attorneys for Multigroup Claimants

34 CERTIFICATE OF SERVICE

I hereby certify that on this 31st day of October 2016, a copy of the foregoing was sent by electronic mail to the parties listed on the attached Service

List.

------Isl Brian D. Boydston, Esq.

SETTLING DEVOTIONAL CLAIMANTS

Matthew MacLean, Esq. PILSBURY WINTHROP SHAW PITTMAN LLP 1200 Seventeenth Street NW Washington, DC 20036

[email protected]

NATIONAL ASSOCIATION of BROADCASTERS

John I. Stewart Crowell & Moring LLP 1001 Pennsylvania Avenue NW Washington, DC 20004 Email: [email protected]

CANADIAN CLAIMANTS GROUP

L. Kendall Satterfield, Esq. FINKELSTEIN THOMPSON LLP 1 1077. 30 h Street, NW Washington, DC 20007

35 [email protected]

LARSON & GATSON LLP 200 S. Robles Ave., Suite 530 Pasadena, CA 91101 [email protected]

JOINT SPORTS CLAIMANTS

Robert Alan Garrett ARNOLD AND PORTER LLP 601 Massachusetts Ave., NW Washington, DC 20001 Email: [email protected]; [email protected]; [email protected]

Thomas J. Ostertag OFFICE OF THE COMMISSIONER OF BASEBALL 245 Park A venue New York, NY 10167 Email: [email protected]

Phillip R. Hochberg, Esq. LAW OFFICES OF PHILLIP R. HOCHBERG 1 12505 Park Potomac A venue, 6 h Floor Potomac, MD 20854 [email protected]

Ritchie T. Thomas, Esq. SQUISRE, SANDERS & DEMPSEY LLP 1201 Pennsylvania Ave., NW Washington, DC 20004 Email: [email protected]; [email protected]

MPAA-REPRESENTED PROGRAM SUPPLIERS

Gregory 0. Olaniran, Esq.

36 MITCHELL SILBERBERG & KNUPP LLP 1818 n Street N.W., gth Floor Washington, DC 20036 Email: [email protected]; [email protected]

MUSIC CLAIMANTS

AMERICAN SOCIETY OF COMPOSERS, AUTHORS, AND PUBLISHERS

Samuel Mosenkis AS CAP One American Plaza New York, NY 10023 Email: [email protected]; [email protected]

BROADCAST MUSIC, INC.

Joseph DiMona BROADCAST MUSIC, INC. 7 World Trade Center 250 Greenwich Street New York, NY 10007-0030 Email: [email protected]

Michael J. Remington, Esq. DRINKER BIDDLE & REATH LLP 1500 K Street, NW - Suite 1100 Washington, DC 20005 Email: [email protected]; [email protected]; [email protected]

NATIONAL PUBLIC RADIO

Gregory A. Lewis NATIONAL PUBLIC RADIO 1111 North Capitol Street, NE Washington, DC 20002 Email: [email protected]

37 SESAC, INC.

John C. Beiter, Esq. SHACKELFORD, BOWEN, ZUMWALT & HAYES 4 7 Music Square East Nashville, TN 3 7203 Email: [email protected]

Christos P. Badavas SESAC 152 West 57th Street, 5th Floor New York, NY 10019 Email: [email protected]

BROADCASTER CLAIMANTS GROUP

John I. Stewart, Esq. Ann Mace CROWELL & MORING LLP 1001 Pennsylvania Ave., NW Washington, DC 20004-2595 Email: [email protected]

Richie T. Thomas, Esq. SQUIRE PATTON BOGGS 2550 M Street Northwest Washington, D.C., 20037 Email: [email protected]

38 EXHIBIT A Before the COPYRIGHT ROYAL TY JUDGES Washington, D.C.

In the Matter of ) ) Distribution of ) Docket No. 14-CRB-0010-CD 2010-2013 2010-2013 ) ~C~ab~le~R~oy~a~lt~y~F~un_d~s~~~-)

In the Matter of ) ) Distribution of ) Docket No. 14-CRB-0011-SD 2010-2013 2010-2013 ) ~S~m~el~li~re~R~o~y~a~lt_y_F~u~n~ds""--~~)

DECLARATION OF RAUL GALAZ IN SUPPORT OF MULTIGROUP CLAIMANTS' OPPOSITION TO SDC MOTION TO DISQUALIFY MULTIGROUP CLAIMANTS AND TO DISALLOW CERTAIN CLAIMANTS AND PROGRAMS

I, Raul Galaz, swear under penalty of perjury, that the following is true and correct:

1. I am over twenty-one years of age, am of sound mind and suffer from no legal disabilities. I am fully competent to testify to the matters set forth in this declaration. I have personal knowledge of all the facts stated herein and am in all respects qualified to assert the same. The contents of this declaration are true and correct.

Multigroup Claimants exhibits. 2. Attached hereto as Exhibit C is a true and correct copy of an email dated May 17, 2012, from Veronica Abney of Salem Baptist Church of Chicago, Inc. to IPG, verifying the claimed programs and broadcasts of such entity.

3. Attached hereto as Exhibit D is a true and correct copy of excerpts from the deposition transcript of Jan Harbour, an employee of

Eagle Mountain International Church, Inc. dba Kenneth Copeland

Ministries, and dated April 29, 2014.

4. Attached hereto as Exhibit E is a true and correct copy of relevant excerpts from online printouts from the web site Wikipedia, describing Daystar TV, Trinity Broadcasting Network, and Christian

Broadcasting Network.

5. Attached hereto as Exhibit F is a true and correct copy of the

Authorization and Transfer from IPG to Spanish Language Producers, dated

January 21, 2015.

Declarant attestations.

6. Since its inception in 1998, no party has ever brought suit against IPG for failure to properly account for collected royalties, nor has

IPG ever found it necessary to negotiate a settlement with any party, confidential or otherwise, based on any allegation of a failure to account.

2 7. Most IPG agreements engage IPG to collect royalties for copyright owners on a worldwide basis, IPG regularly engages third parties to collect royalties from the foreign equivalent of the U.S. Copyright Office, and on not a single occasion since IPG's formation in 1998 has an IPG- represented claimant challenged IPG's authority to engage third parties in its collection efforts.

8. In prior proceedings, IPG acquired broadcast data from Tribune

Media (previously known as TV Data). When acquiring such data, Tribune

Media explicitly explains it process for pre- and post-broadcast title verification, which necessarily depends upon submissions to Tribune Media by the television stations that are broadcasting a program. Because there is not always uniformity by such television stations in the title ascribed to a particular program, a common ·effect is for the identical program to be identified in multiple ways, e.g., "Oprah", "Oprah Winfrey", "Oprah

Winfrey.

DATED: October 31, 2016

By: Isl ______Raul Galaz

3 EXHIBITB \

Before the COPYRIGHT ROY AL TY JUDGES Washington, D.C.

In the Matter of ) ) Distribution of ) Docket No. 14-CRB-0010-CD 2010-2013 2010-2013 ) ~C=ab~le~R~o_y=alzy~F~un~ds~·~~~)

In the Matter of ) ) Distribution of ) Docket No. 14-CRB-0011-SD 2010-2013 2010-2013 ) ___sa;;.;.;;t~el ..... lit __ e __ R __o ...... v ...... al ...... tv ...... F...... un _____ ds ____ )

DECLARATION OF DENISE VERNON IN SUPPORT OF MULTIGROUP CLAIMANTS' OPPOSITION TO SDC MOTION TO DISQUALIFY MULTIGROUP CLAIMANTS AND TO DISALLOW CERTAIN CLAIMANTS AND PROGRAMS

I, Denise Vernon, swear under penalty of perjury, that the following is true and correct:

1. I am over twenty-one years of age, am of sound mind and suffer from no legal disabilities. I am fully competent to testify to the matters set forth in this declaration. I have personal knowledge of all the facts stated herein and am in all respects qualified to assert the same. The contents of this declaration are true and correct. 2. From May I 8, 2011 through November 25, 2011, as a result of a dispute between myself and IPG co-owner Lisa Katona, a bankruptcy court appointed an interim receiver to manage the business of Independent

Producers Group ("IPG"). See SDC Exhs. 21, 22. As is evident on its face, such order states that the appointed receiver will manage the business of

IPG, not that the interim receiver will perform all of the functions of IPG.

3. In rather explicit fashion, the order references several different business-related functions typically handled by several persons, including myself, Lisa Katona, Brian Boydston, Raul Galaz, and Jeff Sedacca.

Nothing in such order suggests that the appointed receiver decided for IPG to not submit a 2010 "July claim". Nothing in such order suggests that the appointed receiver instructed me to not submit the 20 I 0 "July claim".

Nothing in the order suggests that I was acting beyond my authority, or contrary to the authority of the appointed receiver, when I filed the 2010

"July claim" on behalf of IPG. In fact, my filing of the 2010 "July claim" was expressly authorized by and known by the interim receiver, as were all actions that I took on behalf of IPG at such time.

DATED: October 28, 2016

2 Denise Vernon

3

---r.-.---··-·--·---··--·-·---··· EXHIBITC RE: Salem Baptist Church; final broadcast verification Page 1 of I 5,J~""~~~--\­ From: Veronica Abney To: worldwidesg -b~c~ Subfect: RE: Salem Baptist Church; final broadcast verification Date: Thu, May 17, 2012 4:10 pm \)~~+~c.c\ \~(\ Attachments: Salem_Baptist_Church_of_Chicago_lnc_ Unclaimecl_S-17-12.xlsx (36K)

Attached is the revised list of the unclaimed Spreadsheet.

From: \'!.'ll"ll!~iucswchml.fi'.!ll {mailtn~·1rld\\ il!cswci aol.cnm] Sent: Friday, May 11, 2012 1:21 PM To: Veronica Abney; Denise A. Rogers Subject: Salem Baptist Church; final broadcast verification

Dear Sir/Madam,

As the final step in our process of representing your company's claim to 2000-2003 U.S. cable ~transmission royalties, we have identified each broadcast of the programs that you previously infonned us were owned or controlled by your company. These broadcasts appear in the attached Excel spreadsheet.

In some instances, multiple programs appear with the same title. Nevertheless, the broadcast information oftentimes provides additional infonnation regarding the identity of the program. Consequently, and in order to preserve the integrity of your claim and the claims of all represented producers, it is imperative that your company confirm that the broadcasts appearing on the attached Excel spreadsheet were owned or controlled by your company.

At this point we need you to do two things:

1) Immediately forward a reply email confirming your receipt of this email and its attachment A simple response with the word "Received. will suffice. If we do not receive this reply we will need to continue emailing and calling you until the delivery of the email is confirmed.

2) Immediately review the attached list of titles and identify any broadcast of a program that was not owned or controlled by your company. This must be handled in the following manner: in the column immediately next to the program title, headed "Unclaimed Broadcast", place an "x" onlv ff tbe particular broadcast is of a program for which the free tv rights were not owned or controlled by your companv at the time of the broadcast.

We are only a few weeks away from the filing of our direct case with the U.S. Copyright Office. Consequently, it is imperative that your company complete this task immediately. Failure to immediately respond could jeopardize your receipt of royalties, and we need your response no later than Tuesday, May 15, earlier if possible. We realize that this is a short time frame, however your cooperation is necessary as we are analyzing over eleven million broadcasts as part of our presentation.

finally, allow me to remind you that this email contains highly proprietary information. Do not share this information with any third party~ as doing so could potentially harm both your claim and the claims of several hundred other represented claimants.

Thank you for your immediate attention to this matter.

Denise Vernon Worldwide Subsidy Group

hno:llmaiLaol.comf3608 l- l l l /aol-6/en-us/mail/PrintMessage.aspx 5/17/2012 RESTRICTED - Subject to Protective Order in Docket No. 2008-2 CRB CD IPG 1075 2000-2003 (Phase II) Salem Baptist Church of Chicago - Unclaimed Broadcasts list

id date time day_of_ we call_slgn origination syndication length program-~ phase 1_c; Unclaimed Broadcast title synopsis 8508694 102002 5 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8508901 102702 5 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8509105 110302 5 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8509306 111002 5 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8509510 111702 5 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8509710 112402 5 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8509897 120102 5 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8510130 120902 39 Monday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8510311 121502 5 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8510518 122202 5 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 8510723 122902 17 Sunday WBTV L 30 27 Devotional x Greater Salem Church With Anthe 11366043 61501 130 Friday WGNA L 60 27 James T. Meeks 11366269 62201 130 Friday WGNA L 60 27 James T. Meeks 11366716 70601 130 Friday WGNA L 60 27 James T. Meeks 11374912 31302 200 Wednesda~ WGNA L 30 27 James T. Meeks 4789950 10201 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4790011 10401 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4790044 10501 335 Friday WMC L 30 27 Devotional New Salem Baptist Churd 5786918 10701 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4790166 10901 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4790229 11101 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4790262 11201 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5787167 11401 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4790379 11601 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4790440 11801 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4790474 11901 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5787417 12101 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4790578 12301 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4790639 12501 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4790672 12601 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5787660 12801 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4790782 13001 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4790843 20101 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4790876 20201 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5787906 20401 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Chord 4790990 20601 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church

1 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

4791051 20801 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4791084 20901 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5788145 21101 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4791199 21301 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4791260 21501 305 Thursday WMC L 30 27 Devotional New Salem Baptist Churct 4791293 21601 335 Friday WMC L 30 27 Devotional New Salem Baptist Churct 5788387 21801 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4791412 22001 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Churd 4791473 22201 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4791506 22301 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5788628 22501 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4791618 22701 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4791678 30101 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4791711 30201 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5788871 30401 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4791823 30601 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4791884 30801 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4791917 30901 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5789100 31101 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4792030 31301 335 Tuesday WMC l 30 27 Devotional New Salem Baptist Church 4792091 31501 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4792124 31601 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5789345 31801 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4792235 32001 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4792296 32201 305 Thursday WMC l 30 27 Devotional New Salem Baptist Church 4792329 32301 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5789590 32501 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4792440 32701 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4792501 32901 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4792535 33001 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5789834 40101 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4792646 40301 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4792733 40601 335 Friday WMC l 30 27 Devotional New Salem Baptist Church 5790078 40801 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4792846 41001 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4792910 41201 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4792944 41301 335 Friday WMC L 30 27 Devotional New Salem Baptist Church

2 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

5790323 41501 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churd 4793056 41701 335 Tuesday WMC l 30 27 Devotional New Salem Baptist Church 4793117 41901 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4793150 42001 335 Friday WMC l 30 27 Devotional New Salem Baptist Church 5790566 42201 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4793256 42401 335 Tuesday WMC l 30 27 Devotional New Salem Baptist Church 4793316 42601 305 Thursday WMC L 30 27 Devotional New Salem Baptist Churc~ 4793349 42701 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 5790804 42901 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4793455 50101 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4793516 50301 305 Thursday WMC l 30 27 Devotional New Salem Baptist Church 4793549 50401 335 Friday WMC l 30 27 Devotional New Salem Baptist Church 6140707 50601 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4793661 50801 335 Tuesday WMC l 30 27 Devotional New Salem Baptist Church 4793722 51001 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4793755 51101 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6140952 51301 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4793868 51501 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4793928 51701 305 Thursday WMC l 30 27 Devotional New Salem Baptist Church 4793959 51801 335 Friday WMC l 30 27 Devotional New Salem Baptist Church 6141198 52001 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4794073 52201 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4794135 52401 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4794168 52501 335 Friday WMC l 30 27 Devotional New Salem Baptist Church 6141443 52701 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4794273 52901 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4794333 53101 335 Thursday WMC L 25 27 Devotional New Salem Baptist Church 4794367 60101 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6141688 60301 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4794476 60501 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Churcl1 4794537 60701 405 Thursday WMC L 25 27 Devotional New Salem Baptist Church 4794569 60801 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 4794570 60801 405 Friday WMC l 25 27 Devotional New Salem Baptist Church 6141935 61001 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4794671 61201 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4794730 61401 335 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4794761 61501 335 Friday WMC L 30 27 Devotional New Salem Baptist Church

3 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

4794762 61501 405 Friday WMC L 25 27 Devotional New Salem Baptist Church 6142181 61701 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4794863 61901 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4794924 62101 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4794957 62201 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6142427 62401 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4795078 62601 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4795141 62801 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4795176 62901 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6142676 70101 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4795287 70301 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4795345 70501 320 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4795376 70601 350 Friday WMC L 15 27 Devotional New Salem Baptist Church 6142923 70801 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4795469 71001 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4795530 71201 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4795563 71301 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6143169 71501 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4795677 71701 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4795738 71901 305 Thursday WMC L 30 27 Devotlonal New Salem Baptist Church 4795771 72001 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6143415 72201 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4795889 72401 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4795950 72601 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4795985 72701 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6143662 72901 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4796103 73101 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Churcli 4796164 80201 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4796197 80301 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6143908 80501 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4796319 80701 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4796380 80901 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4796414 81001 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6144154 81201 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churc~ 4796528 81401 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4796589 81601 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4796622 81701 335 Friday WMC L 30 27 Devotional New Salem Baptist Church

4 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

6144397 81901 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churc~ 4796736 82101 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4796797 82301 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4796830 82401 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6144637 82601 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4796945 82801 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4797006 83001 305 Thursday WMC L 30 27 Devotional New Salem Baptist Churcl1 4797036 83101 405 Friday WMC L 25 27 Devotional New Salem Baptist Church 6493769 90201 700 Sunday WlMT L 30 27 Devotional New Salem Baptist Church 4797156 90401 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4797215 90601 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4797248 90701 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6494005 90901 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churct 4797367 91101 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Churct 6494239 91601 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4797524 91801 330 Tuesday WMC L 35 27 Devotional New Salem Baptist Church 4797555 91901 235 Wednesda1 WMC l 30 27 Devotional New Salem Baptist Church 4797589 92001 305 Thursday WMC l 30 27 Devotional New Salem Baptist Church 4797622 92101 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 4797653 92201 400 Saturday WMC L 30 27 Devotional New Salem Baptist Church 6494469 92301 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4797742 92501 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4797773 92601 235 Wednesda, WMC L 30 27 Devotional New Salem Baptist Church 4797806 92701 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4797841 92801 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 6494698 93001 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4797961 100201 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4797993 100301 235 Wednesda1 WMC L 30 27 Devotional New Salem Baptist Church 4798026 100401 305 Thursday WMC l 30 27 Devotional New Salem Baptist Church 4798061 100501 335 Friday WMC L 30 27 Devotional New Salem Baptist Churd 4798093 100601 400 Saturday WMC L 30 27 Devotional New Salem Baptist Churct 6494928 100701 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churd 4798187 100901 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Churd 4798220 101001 235 Wednesda' WMC l 30 27 Devotional New Salem Baptist Church 4798252 101101 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4798287 101201 335 Friday WMC L 30 27 Devotional New Salem Baptist Churcli 4798322 101301 400 Saturday WMC L 30 27 Devotional New Salem Baptist Church

5 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

6495160 101401 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4798411 101601 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4798443 101701 235 Wednesda' WMC l 30 27 Devotional New Salem Baptist Church 4798476 101801 305 Thursday WMC l 30 27 Devotional New Salem Baptist Church 4798511 101901 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 4798543 102001 400 Saturday WMC l 30 27 Devotional New Salem Baptist Church 6495393 102101 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4798632 102301 335 Tuesday WMC l 30 27 Devotional New Salem Baptist Church 4798664 102401 235 Wednesda1 WMC L 30 27 Devotional New Salem Baptist Church 4798700 102501 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4798735 102601 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 4798767 102701 400 Saturday WMC L 30 27 Devotional New Salem Baptist Church 6495626 102801 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4798855 103001 335 Tuesday WMC l 30 27 Devotional New Salem Baptist Church 4798887 103101 235 Wednesda, WMC L 30 27 Devotional New Salem Baptist Churcl1 4798920 110101 305 Thursday WMC L 30 27 Devotional New Salem Baptist Churcl1 4798952 110201 335 Friday WMC L 30 27 Devotional New Salem Baptist Churcl1 4798984 110301 400 Saturday WMC L 30 27 Devotional New Salem Baptist Churcl1 6495859 110401 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churcl1 4799067 110601 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Churcl1 4799098 110701 235 Wednesda1 WMC L 30 27 Devotional New Salem Baptist Church 4799131 110801 305 Thursday WMC L 30 27 Devotional New Salem Baptist Churd 4799166 110901 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 4799198 111001 400 Saturday WMC L 30 27 Devotional New Salem Baptist Churct 6496089 111101 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4799281 111301 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Church 4799313 111401 235 Wednesda1 WMC L 30 27 Devotional New Salem Baptist Church 4799346 111501 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4799381 111601 335 Friday WMC L 30 27 Devotional New Salem Baptist Churcl1 4799413 111701 400 Saturday WMC L 30 27 Devotional New Salem Baptist Church 6496324 111801 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churc~ 4799499 112001 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Churd 4799530 112101 235 Wednesda1 WMC L 30 27 Devotional New Salem Baptist Church 4799563 112201 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4799595 112301 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 4799623 112401 400 Saturday WMC L 30 27 Devotional New Salem Baptist Church 6496556 112501 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church

6 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

4799711 112701 335 Tuesday WMC L 30 27 Devotional New Salem Baptist Churc 4799742 112801 235 Wednesda'i WMC l 30 27 Devotional New Salem Baptist Church 4799775 112901 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4799811 113001 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 4799842 120101 400 Saturday WMC L 30 27 Devotional New Salem Baptist Churct 6496789 120201 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churct 4799929 120401 335 Tuesday WMC l 30 27 Devotional New Salem Baptist Church 4799960 120501 235 Wednesda1 WMC L 30 27 Devotional New Salem Baptist Church 4799993 120601 305 Thursday WMC L 30 27 Devotional New Salem Baptist Church 4800028 120701 335 Friday WMC L 30 27 Devotional New Salem Baptist Church 4800060 120801 400 Saturday WMC l 30 27 Devotional New Salem Baptist Church 6497024 120901 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4800152 121101 335 Tuesday WMC l 30 27 Devotional New Salem Baptist Church 4800181 121201 235 Wednesda, WMC l 30 27 Devotional New Salem Baptist Churct 4800214 121301 305 Thursday WMC l 30 27 Devotional New Salem Baptist Churct 4800281 121501 405 Saturday WMC L 30 27 Devotional New Salem Baptist Church 6497257 121601 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 4800404 121901 235 Wednesda' WMC L 30 27 Devotional New Salem Baptist Church 4800437 122001 305 Thursday WMC l 30 27 Devotional New Salem Baptist Church 4800503 122201 405 Saturday WMC L 30 27 Devotional New Salem Baptist Church 6497491 122301 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churct 4800615 122601 235 Wednesda'i WMC L 30 27 Devotional New Salem Baptist Churd 4800648 122701 305 Thursday WMC l 30 27 Devotional New Salem Baptist Churct 4800715 122901 405 Saturday WMC l 30 27 Devotional New Salem Baptist Churct 6497728 123001 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churct 7114205 10602 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7114441 11302 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7114678 12002 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7114915 12702 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 7115154 20302 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Churct 7115392 21002 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7115631 21702 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7115869 22402 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7116105 30302 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churd 7116329 31002 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7116573 31702 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7116816 32402 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church

7 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

7117057 33102 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7117293 40702 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7117530 41402 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7117769 42102 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7118009 42802. 700 Sunday WLMT L 30 27 Devotional New 5alem Baptist Churct 7897550 50502 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7897790 51202 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 7898032 51902 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7898272 52602 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7898514 60202 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7898757 60902 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7899002 61602 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7899243 62302 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7899490 63002 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7899737 70702 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Churd 7899984 71402 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7900229 72102 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7900477 72802 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churcl1 7900724 80402 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7900971 81102 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7901218 81802 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 7901466 82502 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churd 8682943 90802 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 8683189 91502 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churd 8683670 92902 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 8683908 100602 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 8684147 101302 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churcl1 8684386 102002 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 8684626 102702 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 8684867 110302 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churct 8685112 111002 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Churc~ 8685350 111702 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 8685590 112402 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 8685832 120102 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Churcti 8686073 120802 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 8686315 121502 700 Sunday WLMT L 30 27 Devotional New Salem Baptist Church 8686553 122202 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church

8 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

8686795 122902 700 Sunday WLMT l 30 27 Devotional New Salem Baptist Church 4800249 121401 335 Friday WMC l 30 27 Devotional New Salem Church 4800372 121801 335 Tuesday WMe L 30 27 Devotional New Salem Church 4800472 122101 335 Friday WMC l 30 27 Devotional New Salem Church 4800591 122501 330 Tuesday WMC L 30 27 Devotional New Salem Church 4800683 122801 335 Friday WMC L 30 27 Devotional New Salem Church 11366491 62901 130 Friday WGNA L 60 27 Reverend Meeks 5693265 10601 630 Saturday WCCB l 30 27 Devotional Salem Church 5693300 10701 630 Sunday wees l 30 27 Devotional Salem Church 5693562 11401 630 Sunday wees l 30 27 Devotional Salem Church 5693819 12101 630 Sunday wees l 30 27 Devotional Salem Church 5694084 12801 630 Sunday WCCB l 30 27 Devotional Salem Church 5694343 20401 630 Sunday WCCB L 30 27 Devotional Salem Church 5694604 21101 630 Sunday WCCB L 30 27 Devotional Salem Church 5694860 21801 630 Sunday WCCB l 30 27 Devotional Salem Church 5695115 22501 630 Sunday wees l 30 27 Devotional Salem Church 5695369 30401 630 Sunday wees l 30 27 Devotional Salem Church 5695625 31101 630 Sunday wees L 30 27 Devotional Salem Church 5695885 31801 630 Sunday We CB L 30 27 Devotional Salem Church 5696145 32501 630 Sunday WCCB L 30 27 Devotional Salem Church 5696397 40101 630 Sunday wees L 30 27 Devotional Salem Church 5696658 40801 630 Sunday wees L 30 27 Devotional Salem Church 5696916 41501 630 Sunday wees l 30 27 Devotional Salem Church 5697178 42201 630 Sunday wees L 30 27 Devotional Salem Church 5697439 42901 630 Sunday WCCB L 30 27 Devotional Salem Church 6043850 50601 630 Sunday WCCB L 30 27 Devotional Salem Church 6044117 51301 630 Sunday wees l 30 27 Devotional Salem Church 6044377 52001 630 Sunday WCCB L 30 27 Devotional Salem Church 6044636 52701 630 Sunday WCCB L 30 27 Devotional Salem Church

~A 6044886 60301 630 Sunday WCCB l --- ·-·------~-·" -- --27 Devotional Salem Church 6045145 61001 630 Sunday WCeB l 30 27 Devotional Salem Church 6045404 61701 630 Sunday wees L 30 27 Devotional Salem Church 6045659 62401 630 Sunday wees l 30 27 Devotional Salem Church 6045913 70101 630 Sunday wees L 30 27 Devotional Salem Church 6046167 70801 630 Sunday We CB L 30 27 Devotional Salem Church 6046424 71501 630 Sunday wees L 30 27 Devotional Salem Church 6046457 71601 600 Monday wees L 30 27 Devotional Salem Church

9 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

6046686 72201 630 Sunday wees L 30 27 Devotional Salem Church 6046947 72901 630 Sunday wees L 30 27 Devotional Salem Church 6047207 80501 630 Sunday wees L 30 27 Devotional Salem Church 6047470 81201 630 Sunday wees L 30 27 Devotional Salem Church 6047729 81901 630 Sunday WCCB L 30 27 Devotional Salem Church 6047986 82601 630 Sunday wees L 30 27 Devotional Salem Church 6398702 90201 630 Sunday wees L 30 27 Devotional Salem Church 6398962 90901 630 Sunday WCCB l 30 27 Devotional Salem Church 6399192 91601 630 Sunday wees L 30 27 Devotional Salem Church 6399457 92301 630 Sunday wees L 30 27 Devotional Salem Church 6399720 93001 630 Sunday WCCB L 30 27 Devotional Salem Church 6399981 100701 630 Sunday wees L 30 27 Devotional Salem Church 6400219 101401 630 Sunday WCCB l 30 27 Devotional Salem Church 6400441 102101 630 Sunday wees L 30 27 Devotional Salem Church 6400692 102801 630 Sunday wees l 30 27 Devotional Salem Church 6400933 110401 630 Sunday wees l 30 27 Devotional Salem Church 6401194 111101 630 Sunday wees l 30 27 Devotional Salem Church 6401458 111801 630 Sunday wees L 30 27 Devotional Salem Church 6401712 112501 630 Sunday wees L 30 27 Devotional Salem Church 6401970 120201 630 Sunday We CB L 30 27 Devotional Salem Church 6402229 120901 630 Sunday wees l 30 27 Devotional Salem Church 6402491 121601 630 Sunday WCCB l 30 27 Devotional Salem Church 6402755 122301 630 Sunday wees l 30 27 Devotional Salem Church 6403015 123001 630 Sunday WCCB l 30 27 Devotional Salem Church

10 Salem Baptist Church of Chicago - Unclaimed Broadcasts list

year Idirector actor_l actor_2 1c ny Jinwright 1c ny Jinwright 1c ny Jinwright 1c ny Jinwright 1c ny Jinwright 1c ny Jinwright 1c ny Jinwright 1c ny Jinwright 1c ny Jinwright 1c ny Jinwright 1c ny Jinwright

11 EXHIBITD i (:~.~~ c ·"""...... ~:~~ ~ :1.~-· )'. Zr..-_-·_.

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Transcript of JAN HARBOUR

Date: April 29, 2014

Case: IN THE MATTER OF: PHASE II DISTRIBUTION OF THE 1998 AND 1999 CABLE ROYALTY FUNDS

Planet Depos Phone: 888-433-3767 Fax: 888-503-3767 Email: [email protected] Internet: www.planetdepos.com

Court Reporting I Videography I Videoconferencing I Interpretation I Transcription DEPOSITION OF JAN HARBOUR CONDUCTED ON TUESDAY, APRIL 29, 2014

40 1 television programs.

2 MR. BOYDSTON: Do you have more questions,

3 Matt, or not?

4 MR. MACLEAN: Yes, I have more questions,

5 but I'm not going to ask them if the witness isn't

6 going to answer them. So I'm not going to proceed.

7 MR. BOYDSTON: Okay. My question was are

8 you done. I don't want to interrupt you. That's what

9 I'm getting at.

10 MR. MACLEAN: Yes, I'm done.

11 BY MR. BOYDSTON:

12 Q Ms. Harbour, this is Brian Boydston. I am

13 counsel for Independent Producers Group. Is Kenneth

14 Copeland Ministries the owner of the Kenneth Copeland

15 television program?

16 MR. MACLEAN: Objection. Outside the scope

17 of direct and I wasn't permitted to conduct my direct

18 examination.

19 BY MR. BOYDSTON:

20 Q You can go ahead and answer, Ms. Harbour,

21 unless your attorneys instruct you otherwise.

22 A Yes, they are the owners. Kenneth Copeland

PLANET DEPOS 888.433.3767 I WWW.PLANETDEPOS.COM DEPOSITION OF JAN HARBOUR CONDUCTED ON TUESDAY, APRJL 29, 2014

41 1 Ministries is the owner of our television program.

2 Q Does Kenneth Copeland Ministries copyright

3 notice appear at the end of the Kenneth Copeland

4 television program episodes?

5 MR. MACLEAN: Same objection.

6 A Yes, it does.

7 BY MR. BOYDSTON:

8 Q Give me just a second. Does Kenneth

9 Copeland Ministries pay for its television program

10 production?

11 MR. MACLEAN: Same objection.

12 A Yes, it does.

13 BY MR. BOYDSTON:

14 Q Does Kenneth Copeland Ministries pay for the

15 air time for its television program?

16 MR. MACLEAN: Same objection.

17 A Yes, it does.

18 BY MR. BOYDSTON:

19 Q I think this was probably covered, but is

20 Kenneth Copeland the owner of the Kenneth Copeland

21 Ministries copyrighted contents -- copyrighted

22 television programs? I think that's probably been

PLANET DEPOS 888.433.3767 I WWW.PLANETDEPOS.COM

------·~-·-·· DEPOSITION OF JAN HARBOUR CONDUCTED ON TUESDAY, APRIL 29, 2014

42 1 covered by the questions before, but I'll ask it

2 anyway.

3 MR. MACLEAN: Same objection. Also

4 objection based on best evidence.

5 MR. BOYDSTON: Objection is noted.

6 BY MR. BOYDSTON:

7 Q You can try again, Ms. Harbour.

8 A Kenneth Copeland is not the owner of the

9 television programs.

10 Q Is Kenneth Copeland Ministries the owner of

11 the programs?

12 A Yes, Kenneth Copeland Ministries is the

13 owner of the programs.

14 MR. MACLEAN: Same objection.

15 BY MR. BOYDSTON:

16 Q And is Gloria Copeland the owner of the

17 Kenneth Copeland Ministries television programs?

18 MR. MACLEAN: Sarne objection.

19 A No, Gloria is not the owner of the Kenneth

20 Copeland Ministries-Eagle Mountain International Church

21 programs.

22

PLANET DEPOS 888.433.3767 I WWW.PLANETDEPOS.COM DEPOSffiON OF JAN HARBOUR CONDUCTED ON TUESDAY, APRIL 29, 2014

43 l BY MR. BOYDSTON:

2 Q To your knowledge, has any person or entity

3 ever challenged that Kenneth Copeland Ministries --

4 whether or not Kenneth Copeland Ministries is the owner

5 of the Kenneth Copeland Ministries television programs?

6 MR. MACLEAN: Same objection. Also hearsay.

7 A No, not to my knowledge.

8 MR. BOYDSTON: Okay. Give me just a moment.

9 I don't think I have anything further at

10 this time.

11 MR. JOE: Just give me a moment.

12 MR. MACLEAN: Somebody said something, but

13 we didn't hear who it was.

14 MR. BOYDSTON: Mr. Joe just asked to wait a

15 moment.

16 BY MR. BOYDSTON:

17 Q I have another question. Ms. Harbour, I

18 would just caution you, since Mr. MacLean is generally

19 wanting to object, after I finish my question, just

20 give a little pause to see if he's going to jump in

21 with an objection. And if he does, then let him do

22 that and then after a little pause, then give your

PLANET DEPOS 888.433.3767 I WWW.PLANETDEPOS.COM

------~-·-·------~·- DEPOSITION OF JAN HARBOUR CONDUCTED ON TUESDAY, APRIL 29, 2014

44 1 response.

2 My question is where physically are the

3 programs produced?

4 MR. MACLEAN: Same objection.

5 A Our programs are produced on the property at

6 Kenneth Copeland Ministries.

7 BY MR. BOYDSTON:

8 Q And where is that?

9 MR. MACLEAN: Same objection.

10 A Newark, Texas.

11 BY MR. BOYDSTON:

12 Q And the individuals that actually do the

13 production work itself, who are they employed by?

14 MR. MACLEAN: Same objection.

15 A Kenneth Copeland Ministries.

16 MR. BOYDSTON: I think that's all. I have

17 nothing further.

18 MR. JOE: You pass the witness back?

19 MR. MACLEAN: I'm not proceeding with my

20 examination. Thank you everybody.

21 Brian, do you want to stay on the call or

22 should we have a separate call? Do you want me to call

PLANET DEPOS 888.433.3767 I WWW.PLANETDEPOS.COM DEPOSmON OF JAN HARBOUR CONDUCTED ON TUESDAY, APRIL 29, 2014

47 1 CERTIFICATE OF SHORTHAND REPORTER - NOTARY PUBLIC

2 I, Sharon B. Gregory, Court Reporter and Notary

3 Public, the officer before whom the foregoing

4 proceedings were taken, do hereby certify that the

5 witness was duly sworn by me; that said proceedings

6 were taken by me stenographically; and that I am

7 neither counsel for, related to, nor employed by any of

8 the parties to this case and have no interest,

9 financial or otherwise, in its outcome.

10

11 IN WITNESS WHEREOF, I have hereunto set my hand and

12 affixed my notarial seal this 30th day of April, 2014.

13

14 My commission expires January 31, 2016.

15

16

17

18

19 . /' .• -"'\ !'~'•' I,~ \ 20 ' :"->t Vl tc~~ 1 t . t,;,)~

22 THE DISTRICT OF COLUMBIA

PLANET DEPOS 888.433.3767 I WWW.PLANETDEPOS.COM EXHIBITE Daystar (TV network) - Wikipedla 10/18/16, 3:35 PM Daystar (TV network) From Wikipedia, the free encyclopedia

Daystar (formerly known as the Daystar Television ~ Network) is an American evangelical Christian-based ~ \\ Daystar religious broadcast television network that is owned by Word~ of God Fellowship. Its founders are Marcus Lamb and his wife, Joni Lamb. The network is headquartered near the DAYST R

Dallas/Fort Worth Metroplex in Bedford, Texas. i Type

i Country ··Contents : Availability • l History ! Owner Word of God Fellowship 2 Programming Key people Marcus Lamb (founder, president, • • 2.1 Special programming CEO) 3 Controversies Joni Lamb (vice-president, executive • • producer) 3.1 FCC investigation Launch December 31, 1997 • . date 3.2 Israel i Official www.daystar.com (http://www.days • i website 3.3 Lawsuits tar.com) • 4 Availability • 5 References • 6 See also • 7 External links

History

Daystar's roots can be traced back to 1993, when Marcus Lamb and his Word of God Fellowship ministry purchased KMPX (channel 29), a formerly defunct UHF station in Dallas, Texas, broadcasting Christian programming. Lamb is a Georgia native who first began preaching at age 15 and finished Magna Cum Laude from Lee College (now Lee University) at age 19. In 1982, he married Joni Trammel, and together they began to travel the United States, preaching in churches, conventions, and crusades.

https://en.wikipedia.org/wiki/DaystarjTV_network) Page 1 of 6 Trinity Broadcasting Network - Wikipedia IU/ Its/ 10, ~·~-' "IVI

Trinity Broadcasting Network From Wikipedia, the free encyclopedia

The Trinity Broadcasting Network (TBN) is an v international C hristian-based broadcast television ~7'- Trinity Broadcasting Network network.f11C2) Operating as an independent entity, TBN is also the world's largest religious television network .131 TBN is headquartered in Costa Mesa, California, with auxi liary studio facilities in Irving, Texas; Hendersonvill e, Tennessee; Gadsden, Alabama; Decatur, Georgia; M iami , Flori da; Tulsa, Oklahoma; Orlando, Florida; and New York City. TBN broadcasts programs hosted by a diverse group of ministries from Evangeli cal , traditional Protestant and Catholi c denominations, non-profit charities, Messianic Jewish and Type well-known Christian media personalities.HI TBN also offers a wide range of original programming, and faith-based fi lms Country from various distributors.151 Availability National (broadcast, cable and TBN owns a nd operates six broadcast networks, each satell ite); reaching separate demographics; in addition to the main TBN Worldwide (satellite) network, TBN owns Hillsong Channel, Smile of a C hild TV, Founded 1973 TBN Enlace, TBN Salsa and JUCE TV. It also owns several by Tammy Faye Messner, Jim other religio us networks outside of the United States, Bakker, Paul and Jan Crouch including international versions of its five U .S. networks. Matt Crouch CUJTe ntly serves as TB N's president and head of Slogan Worlds Largest Faith Channel 6 operations .1 1 TV stations JUCE TV Hillsong Channel Smile of a Child TV Contents TBN Enlace USA TBN Salsa • KTBN Paradi se Radio History Radio Paradise • Trinity Broadcasting Network 2 Broadcast outlets Headquarters Costa Mesa, California 3 Programming • • Owner Trinity Broadcasting Network 3. J Overview Key people Paul Crouch (co-founder) • 3 .1 .1 Children's programming Jan Crouch (co-founder) • Matt Crouch (president) 3.1.2 Regularly scheduled shows Launch date 1973

https://en.wikipedia.org/wiki/Trinity_Broadcasting_N etwork Page 1 of 16 Christian Broadcasting Network - Wikipedia IV/10/IQ1 ..:>·..:> .. ,...,.,, Christian Broadcasting Network From Wikipedia, the free encyclopedia

The Christian Broadcasting Network (CBN) is an American Christian-oriented religious television network and Christian Broadcasting Network production company. Foundeo by lei evangelist Pat Robertson, its headquarters and main studios are based in Virginia Beach, Virginia.

: Type Religious television ·Contents network/production company Country • , Availability 1 Background 2 Broadcast stations • • 2.1 Former television stations • 2.2 Former radio stations ; Headquarters 3 Programs • • : Owner 3.1 Current 4 Notable personalities : Key people Pat Robertson (founder) • • Gordon P. Robertson (CEO) 4.1 Current • Rob Allman

Background

CBN was founded by televangelist Pat Robertson in 1961, using a religious variety program format that has been successfully used in religious broadcasting ever since. One of the company's mainstays is The 700 Club, the longest-running program in the variety format. The network's journalistic branch, CBN News, provides news updates to The 700 Club and produces religious news programs such as CBN NewsWatch and Christian World News; it also produces a special hour-long block of prime time election coverage hosted by Robertson during American presidential and mid-term elections, airing on Freefonn, which also carries The 700 Club and the half-hour talk show 700 Club Interactive. CBN also operates online channels on its website, such as the CBN News Channe1.c2 1

https://en.wikioedia.oratwikilChristian_Broadcasting_Network Page 1 of 5 Christian Broadcasting Network - Wikipedia "IU/llj/ 101 ";"~ t'IVI

CBN Asia manages Operation Blessing International Relief and Development Corporation (OBI), an international relief and missionary effort, and has international programming, producing local programs including Solusi in Indonesia and From Heart to Heart in Thailand; CBN India produces three shows, a daily Hindi program Ek Nayee Zindagi, a bi-weekly Telugu program Nireekshana and an award-winning weekly Bengali program Samadhan.f3J The company also produces versions of The 700 Club aimed at Latin American (Club 700 Hoy) and British audiences (The 700 Club With Paul and Fiona).141 CBN has broadcast programs in over 70 languages.

On April 29, 1977, CBN launched a religious cable network, the CBN Satellite Service. The channel was later revamped as the CBN Cable Network in 1981, and began incorporating secular programming alongside religious content. In August 1988, it rebranded as The CBN Family Channel (later dropping the "CBN" name outright in September 1990), before selling it to International Family Entertainment (owned by Robertson's son, Timothy) two years later as the network became too profitable for CBN to maintain its nonprofit status. IFE later sold it to News Corporation in 1997 (rebranding it as the Fox Family Channel in August 1998), which later sold it to The Walt Disney Company in 2001 (and rebranding it as ABC Family, now known as Freeform). The terms of the sale to International Family Entertainment stipulated that the channel continue carrying two CBN programs, including The 700 Club. It is often thought the deal stipulated that the channel maintain the word "Family" in its name in perpetuity, however this was later dismissed by network executives as an urban legend.l51

CBN now serves mainly as a production company for The 700 Club, and four other syndicated shows: CBN NewsWatch, Christian World News, 700 Club Interactive and The Brody File., a news-analysis program hosted by political journalist David Brody. CBN and Re ent University jointly produced the film First Landing .l6l

Some of CBN's programs also air on ky ~rtg-el, the Trinit roadcasting Network, Cornerstone Television, FamilyNet, LeSEA Broadcasting and M. die East Televisio (which was founded and owned by CBN, until it was sold to LeSEA in the early 2000s), II of which are Eva gelical Christian networks. The secular commercial stations that continue to ai The 700 Club in s dication (along with Freeform) air CBN's annual telethon during the last week of January.

Broadcast stations

CBN entered into the broadcasting industry in 1960, when Robertson founded WYAH-TV (channel 27) in Portsmouth, Virginia - the group's flagship station - which signed on in October 1961. The organization's broadcasting unit, the Continental Broadcasting Corporation, ran it as a family-oriented independent station - featuring a mix of religious programming (which took up most of its stations' Sunday schedules) and secular acquired programs, including westerns, sitcoms, drama series and children's programming-a fonnat that would be later adopted by the LeSEA Broadcasting Corporation when it began launching its own television stations in the 1970s.

CBN later signed on WHAE-TV (channel 46) in Atlanta, Georgia in June 1971. ln January 1973, CBN purchased KBA-TV (channel 33) in Dallas, Texas and changed its callsign to KXTX-TV; that April, CBN and Doubleday Broadcasting became involved in a license swap in which Doubleday swapped KDTV (channel 39)

https://en.wikipedia.org/wlki/Christian_Broadcasting_Network Page 2 of 5 EXHIBITF .,

AUTHORIZATION and TRANSFER

For good and valuable consideration, hereby acknowledged as received, Worldwide Subsidy Group LLC dba Independent Producers Group hereby engages and authorizes Spanish Language Producers to act as its representative in connection with all proceedings relating to U.S. cable and satellite retransmission royalties, to the extent that such proceedings relate to 2010 broadcasts and thereafter, until such parties agree otherwise. S~ch authorization and transfer shall apply only to Spanish language programming, and only in the event that such programming is defined as a separate "Phase I" category, whether by order or stipulatio~ of participants in such proceedings. In the event that such Spanish language programming is not d~fined as a separate "Phase I" category, the authorization and transfer herein shall inure to th~ benefit of Multigroup Claimants, according to an authorization and transfer simultaneously effectuated.

Effective Date: January 20, 2015 WORLDWIDE SUBSIDY GROUP LLC dba INDEPENDENT PRODUCERS GROUP

By:

SPANISH LANGUAGE PRODUCERS -4JJ~3~...... By:------