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1 Brad Greenspan, Pro Se 2 14938 Camden Ave Suite 47 3 San Jose, CA 95124 4 5 UNITED STATES DISTRICT COURT 6 CENTRAL DISTRICT OF CALIFORNIA 7 8 9 EUNICE HUTHART, ) Case No. CV 13-4253 MWF ) 10 Plaintiff, ) Honorable Michael W. Fitzgerald 11 v. ) ) 12 ) 13 ) ) 14 ) NOTICE OF ERRATA 15 REGARDING MOTION TO INTERVENE 16 NEWS CORPORATION, NI GROUP 17 LIMITED f/k/a NEWS ) INTERNATIONAL LIMITED, ) 18 19 NEWS GROUP NEWSPAPERS ) LIMITED, and JOHN and JANE ) 20 DOES 1-10 ) 21 ) Defendants. ) 22 ) 23 ) 24 25 26 27 28 1 NOTICE OF ERRATA 1 2 TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: 3 PLEASE TAKE NOTICE 4 Petitioner respectfully submit the following corrections to certain limited portions of 5 6 the pleadings Entered into the Court filing system on May 6, 2014. 7 Specifically, petitioner wishes to correct certain pleadings as set forth below. 8 Plaintiff Motion to Intervene Conclusion section And Exhibits. 9 10 Because of the last minute clerical changes to the numbering of certain exhibits and 11 conversion of pleadings from a Word document - prior to filing the document – the 12 spacing and formatting and certain sections were omitted and inserted erroneously 13 14 from incorrect versions. Plaintiff did not realize the error in these citations until after 15 the Pleadings were filed and Defendant’s May 19, 2014 claims were reviewed. In 16 particular, Plaintiff wishes to make the following corrections to certain Documents in 17 18 the pleadings 19 20 A. Correction #1 – on page 22 of filed May 2, 2014 Motion To Intervene: 21 22 “39. The Intervenor further respectfully requests the Court grant in such motion, the right to serve the Complaint in Intervention (Exhibit #2) , Motion for 23 Partial Summary Judgment (Exhibit #3) , and Motion for Preliminary 17200 24 Injunction and/or Motion of Contempt for Violation 2006 California State Attorney 17200 25 Permanent Injunction entered into consent decree on behalf of Defendant News 26 Corporation with State Attorney (Exhibit #4) related and precedential rulings and briefings attached as herein. 27 28 be replaced with the phrase “ 2 NOTICE OF ERRATA 1 “39. The Intervenor further respectfully requests the Court grant in such motion, the right to serve the Complaint in Intervention (Exhibit #2) , Motion for 2 Consolidation and/or Motion of Contempt for Violation 2006 California State 3 Attorney 17200 Permanent Injunction entered into consent decree on behalf of Defendant News Corporation with State Attorney (Exhibit #3) related and 4 precedential rulings and briefings attached as herein.” 5 6 7 8 B. Correction #2 9 Corrected Complaint in Intervention as Exhibit A is attached 10 11 C. Correction #3 12 Corrected Motion for Consolidation as Exhibit B. 13 14 15 16 DATED: May 23, 2014 respectfully submitted, 17 18 19 20 21 22 Brad Greenspan, in Pro Per 23 24 25 26 27 28 3 NOTICE OF ERRATA 1 EXHIBIT A- 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 NOTICE OF ERRATA 1 EXHIBIT B 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 NOTICE OF ERRATA Brad Greenspan, Pro Se 1 264 South La Cienega 2 Suite 1216 Beverly Hills, CA 90211 3 4 UNITED STATES DISTRICT COURT 5 CENTRAL DISTRICT OF CALIFORNIA 6 7 EUNICE HUTHART, ) Case No. CV 13-4253 MWF 8 ) Plaintiff, ) Honorable Michael W. Fitzgerald 9 v. ) 10 ) ) 11 ) ) 12 NEWS CORPORATION, NI GROUP ) COMPLAINT IN INTERVENTION LIMITED f/k/a NEWS ) 13 INTERNATIONAL LIMITED, ) 14 NEWS GROUP NEWSPAPERS ) LIMITED, and JOHN and JANE ) 15 DOES 1-10 ) ) 16 Defendants. ) ) 17 ) 18 ) 19 20 21 22 23 24 25 26 27 28 1 COMPLAINT IN INTERVENTION 1 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN: 2 PRELIMINARY STATEMENT 3 4 1. This is a civil action brought against Defendants for damages for violations of Plaintiff’s right to privacy; for the unlawful access to stored communicationl and for the intrusion into, 5 interception of, email and other wire communications while Plaintiff was living in Los Anglees in violation of 18 U.S.C. 2701, 2707; 18 U.S.C. 2510, 2511, 2520; Article I, Section 1of the California State Constituion; 630- 6 637.0 of the California Penal Code; 1708.8 of the California Civil Code; and California common law. 7 JURISDICTION AND VENUE 8 This action is brought pursuant to 18 U.S.C. 2701 and 2707, 18 U.S.C. 2510, 2511 and 2520. This Court has 9 jurisdiction of the action pursuant to 28 U.S.C. 1331, as this is a civl action arising under the laws of the United States. This Court has jurisdiction over the supplemental claims arising under the Constituion of the State of 10 California, California State law and California common law pursuant to 28 U.S.C. 1367(a). 11 Venue is proper in the United States District Court for the Central District of California pursuant to 28 U.S.C 12 1391(a) and (b)(2) because the claims arose in this district. 13 PARTIES 14 2. Plaintiff BRAD GREENSPAN “Plaintiff” is a citizen of the United States. 15 Petitioner owned approximately 3.9 million of a 35 million share class certified in Federal Court June 2009 in the Brown v. Brewer Federal Security Fraud Class Action, 2:0603731.over 4000+ individual victim shareholders 16 of the public company that stopped traded when Defendant News Corporation forced cash out of all shareholders that hadn’t thrown in the towel at $12.00 per share. 17 3. Plaintiff SubClass A – Federal Brown v. Brewer shareholders 18 i. Subclass B- UK and US victims of at list one of Defendants or Rico Associated in Fact Enterprise- 19 HAND’s privacy invasion or predicate act. 20 ii. Subclass C – U.S. employees part of HiTech Class in San jose Federal certified class action who were 21 victims of privacy violation by Google, Defendants, or Rico Associated in Fact Enterprise: HAND 22 23 B. Defendants are also RICO Defendants and members Of ‘HAND’ criminal Associated in Fact Enterprise ‘HAND” 24 25 3. Defendant NEWS CORPORATION, a Delaware incorporated company. 26 Defendant NI GROUP LIMITED f/k/a NEWS INTERNATIONAL LIMITED (“NEWS INTERNATIONAL”) IS A BRITISH newspaper publisher, and a wholly-owned subsidiary of NEWS CORPORATION. It is the 27 holding company of NEWS GROUP NEWSPAPERS LIMITED (“NEWS ROUP NEWSPAPERS), the publisher of The Sun newspaper, 28 2 COMPLAINT IN INTERVENTION 4. Defendant NEWS GROUP NEWSPAPERS, a subsidiary of NEWS INTERNATIONAL, is a United 1 Kingdom company 2 5. (Hereinafter, NEWS CORP, NEWS CORPORATION, NEWS INTERNATIONAL and NEWS GROUP NEWSPAPERS, are referred to, collectively as the “NEWS CORP Defendants” 3 6. Defendants JOHN and JANE DOES 1-3, whose identities are presently unknown to the Plaintiff., are 4 private investigators who work or worked for on 5 9. Defendants JOHN and JANE DOES 4-7, whose identities are presently known tio the Plaintiff, are 6 journalists, who were employed y agents ofm, and/or independent contractors some or all of the NEWS CORPORATION 7 10. Defendants JOHN and JANE DOES 8-10, whose identities presently unknwont ot the Plaintiff, are 8 current or former officers and executives of some or all of the NEWS CORPORAITON Defendants (collectively, the “UNIDENTIFIED EXECUTIVES”), and in such capacity, ivilated laws nad Plaintiff’s right ot 9 privacy, and with some or all of the Defendants, knew, or should have known of and did nothing to stop the 10 unlawful access to stored communications, the intrusioninto, the interceptio fo, the interference with, Plaintiff’s email communications with other Class Members during July 18, 2005 thru December 31, 2012. 11 11. Google, Inc. 12 i. Defendant Marissa Meyer, on Google EMG during Rico and antitrust predicate acts between 2005 thru at least 2011. 13 14 ii. Defendant Sheryl Sandberg, on Google EMG during Rico and antitrust predicate acts between 2005 thru at least 208. 15 iii. Larry Page iv. Defendant Sergey Brin 16 v. Defendant Alan Eustace 17 vi. Defendant David Drummond 18 vii. Defendant Pinchette, Google CFO. 19 viii. Defendant Amazon.com 20 12. Defendants eUniverse Inc. aka Intermix, Inc. ( “MySpace Parent Company”) 21 22 22. MySpace, Inc. 23 23. Defendant Brett Brewer. Brewer was former President but not a founder or cofounder of 24 eUniverse Inc. Brewer is a citizen of California. Brewer was a director throughout the Relevant Period 25 and was responsible for the preparation, review and/or dissemination of the 2003 Proxy and the 2005 Proxy, both of which were false and misleading when filed with the SEC, disseminated to Intermix 26 shareholders and voted upon by shareholders at the January 2004 and September 2005 shareholder 27 meetings. By preparing, reviewing and/or disseminating the false and misleading 2003 Proxy, Brewer 28 was able to maintain his seat on the Intermix Board, procure millions of dollars worth of personal 3 COMPLAINT IN INTERVENTION benefits in the form of continued employment and stock option grants and ensure that the VantagePoint 1 Transactions were approved by Intermix shareholders. Brewer also received material personal benefits in 2 connection with the Acquisition and his preparation, review and/or dissemination of the 2005 Proxy, 3 including the expectation that the consummation of the Acquisition would extinguish his liability in the 4 existing derivative suits, indemnify him for prior and contemporaneous misconduct, and immediately 5 monetize his illiquid stock holdings in the CompanyDefendant Brewer signed or authorized the signing 6 of the false andmisleading Registration and Proxy Statements 24.Defendant Edell.