FILED: NEW YORK COUNTY CLERK 01/20/2021 10:46 AM INDEX NO. 650402/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------------------------------------------------------------------X Index No. ______________ CLAUDIA C. LEVY as EXECUTRIX Under the Last Will and Testament of JACQUES M. LEVY, Date Index No. Purchased: also known as JACQUES LEVY, Deceased, and JACKELOPE PUBLISHING COMPANY, INC., ____________________ SUMMONS Plaintiffs, Plaintiffs designate New York -against- County as the place of trial. ROBERT ZIMMERMAN, also known as BOB DYLAN, The basis of venue is, inter alia, and doing business as RAM’S HORN MUSIC, the County where Plaintiffs SPECIAL RIDER MUSIC and/or BOB DYLAN MUSIC CO., reside and/or have their UNIVERSAL MUSIC GROUP, INC. and doing business as principal place of business. UNIVERSAL MUSIC GROUP, UNIVERSAL MUSIC PUBLISHING, INC. and doing business as UNIVERSAL MUSIC PUBLISHING GROUP, and JOHN DOES 1-10, Defendants. --------------------------------------------------------------------------X To the above-named Defendants: You are hereby summoned to answer the complaint in this action and to serve a copy of your answer or, if the complaint is not served with this summons, to serve a notice of appearance on Plaintiffs’ attorney within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: New York, New York January 20, 2021 Defendants’ Addresses: ROBERT ZIMMERMAN, also known as BOB DYLAN, and doing business as RAM’S HORN MUSIC, SPECIAL RIDER MUSIC and/or BOB DYLAN MUSIC CO. 67 Irving Place New York, New York 10003; 1 1 of 18 FILED: NEW YORK COUNTY CLERK 01/20/2021 10:46 AM INDEX NO. 650402/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 UNIVERSAL MUSIC GROUP, INC. and doing business as UNIVERSAL MUSIC GROUP, UNIVERSAL MUSIC PUBLISHING, INC. and doing business as UNIVERSAL MUSIC PUBLISHING GROUP 1755 Broadway Suite 6 New York, New York 10019 AARON RICHARD GOLUB, ESQUIRE, P.C. Attorney for Plaintiffs BY: __s/Aaron Richard Golub_______________ Aaron Richard Golub 35 East 64th Street, Suite 4A New York, New York 10065 Tel: (212) 838-4811 [email protected] 2 2 of 18 FILED: NEW YORK COUNTY CLERK 01/20/2021 10:46 AM INDEX NO. 650402/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------------X Index No. CLAUDIA C. LEVY as EXECUTRIX Under the Last Will and Testament of JACQUES M. LEVY, also known as JACQUES LEVY, Deceased, and JACKELOPE PUBLISHING COMPANY, INC., Plaintiffs, COMPLAINT (Jury Trial Demanded) -against- ROBERT ZIMMERMAN, also known as BOB DYLAN, and doing business as RAM'S HORN MUSIC, SPECIAL RIDER MUSIC and/or BOB DYLAN MUSIC CO., UNIVERSAL MUSIC GROUP, INC. and doing business as UNIVERSAL MUSIC GROUP, UNIVERSAL MUSIC PUBLISHING, INC. and doing business as UNIVERSAL MUSIC PUBLISHING GROUP, and JOHN DOES 1-10, Defendants. ---------------------------------------------------------------------------X Plaintiffs CLAUDIA C. LEVY ("CL") as EXECUTRIX Under the Last Will and Testament of JACQUES M. LEVY, also known as JACQUES LEVY, Deceased, and JACKELOPE PUBLISHING COMPANY, INC. ("Jackelope") (collectively, "Plaintiffs"), by Plaintiffs' their attorney, AARON RICHARD GOLUB, ESQUIRE, P.C., as and for complaint against Defendants ROBERT ZIMMERMAN, also known as BOB DYLAN, and doing business as RAM'S HORN MUSIC ("RHM"), SPECIAL RIDER MUSIC ("SRM") and/or BOB DYLAN MUSIC CO. ("BDMC"), UNIVERSAL MUSIC GROUP, INC. ("UMGI") and doing business as UNIVERSAL MUSIC GROUP ("UMG"), UNIVERSAL MUSIC PUBLISHING, INC. ("UMPI") and doing business as UNIVERSAL MUSIC PUBLISHING GROUP ("UMPG") and JOHN DOES 1-10 (collectively, "Defendants"), allege as follows: 3 of 18 FILED: NEW YORK COUNTY CLERK 01/20/2021 10:46 AM INDEX NO. 650402/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 PARTIES 1. On September 30, 2004, Jacques M. Levy, also known as Jacques Levy (“JL”), died, leaving a last will and testament (“Will”) wherein and whereby CL, JL’s wife and Plaintiff herein, was appointed the sole executrix. JL’s Will was duly admitted to probate by the Surrogate of the County of New York and, on February 8, 2005, Letters Testamentary upon the Will were duly issued and granted by the Surrogate to CL as duly qualified Executrix of the Estate of JL, Deceased. CL continues to act as Executrix. 2. Plaintiff Jackelope is and was a music publishing company created by JL and affiliated with Broadcast Music, Inc. that was and is duly organized and existing under the laws of the State of New York, with its principal place of business in the City, County and State of New York. 3. Upon information and belief, at all relevant times, Defendant Robert Zimmerman, also known as Bob Dylan (“Dylan”), presently does and has done business at and/or through entities and individuals at Davasee Enterprises Inc., located at 67 Irving Place, 11th Floor, New York, New York 10003, and resides and resided in the City, County and State of Los Angeles, California and the City, County and State of New York. Dylan is an American singer- songwriter, author and visual artist, widely regarded as one of the greatest songwriters of all time and a major figure in popular culture for more than 50 years. 4. At all relevant times, Defendant RHM is and was a registered assumed business name (a DBA)1 for Dylan pursuant to a business certificate signed by Dylan and notarized on or about October 18, 1971 and subsequently filed in the State of New York. Defendant RHM is the publisher of the Compositions set forth below and has rendered, inter alia, royalty payments and 1 Doing business under an assumed name. 2 4 of 18 FILED: NEW YORK COUNTY CLERK 01/20/2021 10:46 AM INDEX NO. 650402/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 other income and payments to Plaintiffs since 1975. Defendant RHM presently does and has done business at and/or through entities and individuals at Davasee Enterprises Inc., located at 67 Irving Place, 11th Floor, New York, New York 10003. Defendant RHM acts, in whole or in part, as an alter ego for Defendants Dylan, SRM and/or BDMC. 5. Upon information and belief, at all relevant times, Defendant SRM is and was a registered assumed business name (a DBA)2 for Dylan. Defendant SRM is the publisher of the Compositions set forth below and has rendered, inter alia, royalty payments and other income and payments to Plaintiffs since 1975. Defendant SRM presently does and has done business at and/or through entities and individuals at Davasee Enterprises Inc., located at 67 Irving Place, 11th Floor, New York, New York 10003. Defendant SRM acts, in whole or in part, as an alter ego for Defendants Dylan, RHM and/or BDMC. 6. Upon information and belief, at all relevant times, Defendant BDMC is and was a registered assumed business name (a DBA)3 for Dylan. Defendant BDMC is and was a corporation with its principal place of business and corporate headquarters in New York and is and was engaged in the business of administering Dylan’s, RHM’s and/or SRM’s publishing rights in the United States. Defendant BDMC presently does and has done business at and/or through entities and individuals at Davasee Enterprises Inc., located at 67 Irving Place, 11th Floor, New York, New York 10003. Defendant BDMC acts, in whole or in part, as an alter ego for Defendants Dylan, RHM and/or SRM. 7. Defendants Dylan, RHM, SRM and BDMC are collectively referred to herein as the “Dylan Defendants.” 2 Doing business under an assumed name. 3 Doing business under an assumed name. 3 5 of 18 FILED: NEW YORK COUNTY CLERK 01/20/2021 10:46 AM INDEX NO. 650402/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/20/2021 8. Upon information and belief, at all relevant times, Defendant UMGI, doing business as UMG, is and was a corporation duly organized and existing under the laws of the State of Delaware, with its principal place of business and corporate headquarters in Santa Monica, California. Upon information and belief, UMGI is duly authorized to conduct business in the State of New York and maintains an office at 1755 Broadway, New York City, New York, 10019. UMGI and UMG are one of the world’s leading music companies engaged in the business of recorded music with various recording labels. 9. Upon information and belief, at all relevant times, Defendant UMPI, doing business as UMPG, is and was a corporation duly organized and existing under the laws of the State of California, with its principal place of business and corporate headquarters in Santa Monica, California. Upon information and belief, UMPI is duly authorized to conduct business in the State of New York and maintains an office at 1755 Broadway, New York City, New York, 10019. Upon information and belief, UMPI and UMPG are engaged in the business of, inter alia, music publishing whereby they, inter alia, license the recording, reproduction and distribution of musical works for which they own or control the copyrights and the exclusive rights related to such works, in whole or in part. 10. Defendants UMGI, UMG, UMPI and UMPG are collectively referred to herein as the “Universal Defendants.” 11. Upon information and belief, John Does 1-10 are presently unnamed individuals and/or entities that are related to the facts, allegations and causes of action herein and that may be named additional defendants as a result of discovery.