Case 2:15-cv-03462-RGK-AGR Document 1 Filed 05/31/14 Page 1 of 40 Page ID #:1 United States District Court Eastern District of Pennsylvania Michael Skidmore, as Trustee for the: No.: tbd Randy Craig Wolfe Trust Plaintiff Case Filed: May 31, 2014 v. Led Zeppelin Causes of Action: James Patrick Page Copyright Infringement Robert Anthony Plant John Paul Jones Right of Attribution – Falsification of Super Hype Publishing, Inc. Rock n’ Roll History Warner Music Group Corp. Parent of: Warner/Chappell Music, Inc. Atlantic Recording Corporation Rhino Entertainment Company Jury Trial Demanded Defendants Plaintiff’s Complaint Copyright Infringement and Related Claims Regarding Stairway to Heaven Francis Alexander, llc Francis Alexander Malofiy, Esquire Attorney ID No.: 208494 280 N. Providence Road | Suite 105 Media, PA 19063 T: (215) 500-1000 F: (215) 500-1005 E:
[email protected] Law Firm / Lawyer for Plaintiff Case 2:15-cv-03462-RGK-AGR Document 1 Filed 05/31/14 Page 2 of 40 Page ID #:2 Preamble 1. In the summer of 1967, Randy Craig Wolfe (aka Randy California), discovered by Jimi Hendrix, was a founding member of the eclectic rock band Spirit who pioneered the psychedelic rock sound. The band fused rock and jazz and enhanced the audio palette by incorporating mind-bending and mood-altering effects such as the Etherwave-Theremin, delay, and distortion into their recorded songs and live performances. 2. In January 1968 Spirit released a self-titled album named Spirit—a top 40 Billboard charting album. On that album was a unique 2 minute and 37 second instrumental titled “Taurus” which has a distinct-plucked guitar line and melody.