1 O'DONNELL & SHAEFFER, LLP
2 PIERCE O'DONNELL (State Bar No. 081298)
JOHN SHAEFFER (State Bar No. 139331)
3 LEE R. SELTMAN (State Bar No. 168857)
ERIC S. VANDERPOOL (State Bar No. 187307)
4 633 West Fifth Street, Suite 1700
5 Los Angeles, California 90071
(213) 532-2000
6
7 Attorneys for Plaintiff
BARBARA CHASE-RIBOUD
8
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11 WESTERN DIVISION
12 BARBARA CHASE-RIBOUD, an Individual, ) CASE NO. 97-7619 ABC (JGx)
13 )
Plaintiff, )
14 v. )) FIRST
15 DREAMWORKS, Inc. (dba DREAMWORKS )) (1) COPYRIGHT INFRINGEMENT (17
16 SKG) a Delaware Corporation; U.S.C.
DREAMWORKS FILMS LLC, a California ) (2)
17 limited liability company; DREAMWORKS )
DISTRIBUTION LLC, a California limited ) (3)
18 liability company; DREAMWORKS LLC, a )
California limited liability company; PUNCH ) (4) UNFAIR
19 PRODUCTIONS INC., a Connecticut ) §§
Corporation; PENGUIN PUTNAM, INC., a ) (5)
20 Delaware Corporation; PENGUIN BOOKS ) U.S.C.
USA INC., a New York Corporation; and ) (6)
21 DOES 4 through 50, inclusive, )) JURY
22 Defendants. ))
23 )
24
25 Plaintiff Barbara Chase-Riboud, by her undersigned attorneys, complains against
26 DreamWorks, Inc., DreamWorks Films LLC, DreamWorks Distribution LLC, and DreamWorks
27 LLC (collectively "DreamWorks"), Punch Productions Inc. ("Punch"), and Penguin Putnam, Inc.
28 and Penguin Books USA Inc. (collectively "Penguin") as follows:
O'DONNELL & SHAEFFER, LLP
1
2 JURISDICTION AND VENUE
3 1. This First Amended Complaint alleges copyright infringement and
4 copyright infringement arising under the Copyright Act of 1976, 17 U.S.C. §§ 101 et seq.
5 claim for unfair competition arising under the Lanham Act of 1946 (as amended), 15 U.S.C.
SNIPPETS:
O'DONNELL & SHAEFFER, LLP
PIERCE O'DONNELL (State Bar No. 081298)
12 BARBARA CHASE-RIBOUD, an Individual,) CASE NO. 97-7619 ABC
15 DREAMWORKS, Inc. ) COPYRIGHT INFRINGEMENT (17
26 DreamWorks, Inc., DreamWorks Films LLC, DreamWorks Distribution LLC, and DreamWorks
27 LLC, Punch Productions Inc., and Penguin Putnam, Inc. 28 and Penguin Books USA Inc. as
O'DONNELL & SHAEFFER, LLP
copyright infringement arising under the Copyright Act of 1976, 17 U.S.C. §§ 101 et seq.
California law and includes a claim for declaratory relief.
13 copyright infringement, contributory copyright infringement, unfair competition and other
17 district and its infringing theatrical motion picture will be exhibited within this
20 genocidal crime our Black Holocaust continue to haunt the United States of America.
25 Tubman, Abraham Lincoln, and John Quincy Adams are well-known;
15 President and then Congressman John Quincy Adams, Cinque and his fellow Africans ultimately
28 Cinque and the Amistad saga, weaving fictional characters and scenes into an absorbing
makes Echo of Lions a compelling epic, a work of such breathtaking originality that any
submitted it to Steven Spielberg in 1988.
17 for a feature film and better suited for a mini-series.
In February 1993, Punch optioned the motion picture, television and ancillary rights to Echo
believes, and on that basis alleges, that less than two months after the option lapsed,
10 of the screenplay, published by Defendant Penguin, has very recently arrived at bookstores.
16 of the recognition and just compensation she deserves for her crucial contribution to
Inc. is engaged in the production and worldwide distribution of theatrical motion
18 pertinent to this First Amended Complaint, DreamWorks, Inc. has controlled, succeeded to,
21 that basis alleges, that Penguin Putnam, Inc. conducts substantial, continuous and
27 the Lanham Act, 15 U.S.C. Sections 1117 and 1125.
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