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Tera King Production Requests .pdf



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TARA KING
1094 Chavez Court
North Las Vegas, Nevada 89031
Phone: (702) 395-5464
Facsimile: (702) 395-6265
Email: djtara@djtaraking.com
Defendant in proper person

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
SOUTHERN DIVISION

SLEP-TONE ENTERTAINMENT
CORPORATION,

)
)
)
Plaintiff,
)
)
vs.
)
)
ELLIS ISLAND CASINO & BREWERY; )
et al.,
)
)
Defendants.
)
____________________________________)

CASE NO. 2:11-cv-0239-KJD-RJJ

TARA KING’S REQUESTS FOR
PRODUCTION TO SLEP-TONE
ENTERTAINMENT CORPORATION

TO:

SLEP-TONE ENTERTAINMENT CORPORATION; and,

TO:

JAMES M. HARRINGTON, ESQ., of HARRINGTON LAW, P.C., and KERRY P.
FAUGHNAN, ESQ.: its attorneys”
COMES NOW, Defendant, Tara King dba DJ Tera King Productions, and herein

pursuant to Federal Rule of Civil Procedure 34 serves these requests for production of documents
to be responded to by the Plaintiff, Slep-Tone Entertainment Corporation:
....
1

Request Number 1:
Produce a copy of all investigative reports in the possession of Slep-Tone Entertainment
Corporation or its attorneys regarding Tara King.
Request Number 2:
Produce a copy of all investigative reports in the possession of Slep-Tone Entertainment
Corporation or its attorneys regarding DJ Tara King Productions.
Request Number 3:
Produce a copy of all documents you reserve the right to introduce into evidence in
support of the allegations made in the Complaint filed in the above-entitled action.
Request Number 4:
Produce a copy of all documents evidencing the allegation made in paragraph 3 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation is a North
Carolina corporation.
Request Number 5:
Produce a copy of all documents evidencing the allegation made in paragraph 24 of the
Complaint filed in the above-entitled action that DJ Tara King Productions and Tara King are
providing karaoke entertainment at multiple venues in Nevada using multiple karaoke systems.
Request Number 6:
Produce a copy of all documents evidencing the allegation made in paragraph 47 of the
Complaint filed in the above-entitled action that Slep-Tone is the manufacturer and distributor of
karaoke accompaniment tracks sold under the name “Sound Choice.”
....
2

Request Number 7:
Produce a copy of all documents evidencing the allegation made in paragraph 48 of the
Complaint filed in the above-entitled action that Sound Choice is recognized as one of the
leading producers of high quality karaoke accompaniment tracks.
Request Number 8:
Produce a copy of all documents evidencing the allegation made in paragraph 48 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation invested
over $18 million to re-record and replicate the authentic sound of popular music across different
eras and genres of music.
Request Number 9:
Produce a copy of all documents evidencing the allegation made in paragraph 49 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation’s music
became the staple of almost every karaoke show in the United States.
Request Number 10:
Produce a copy of all documents evidencing the allegation made in paragraph 49 of the
Complaint filed in the above-entitled action that Sound Choice became the brand that nearly
every karaoke fan wanted to sing.
Request Number 11:
Produce a copy of all documents evidencing the allegation made in paragraph 49 of the
Complaint filed in the above-entitled action that Sound Choice became the brand that nearly
every karaoke jockey wanted in his or her library.
....
3

Request Number 12:
Produce a copy of all documents, including expert psychological reports and articles in
peer reviewed psychological journals, evidencing the allegation made in paragraph 51 of the
Complaint filed in the above-entitled action that computer copying technology has proven
irresistible to karaoke jockeys to copy one purchased disc to several different computer based
systems.
Request Number 13:
Produce a copy of all documents evidencing the allegation made in paragraph 53 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Company as been
driven nearly out of business including, but not limited to, Slep-Tone Entertainment
Corporation’s fiscal year end income statements, fiscal year end balance sheets, and income tax
returns for the years 2006 through 2011, inclusive.
Request Number 14:
Produce a copy of all documents evidencing the allegation made in paragraph 53 of the
Complaint filed in the above-entitled action that the Sound Choice family of companies
employed 75 individuals.
Request Number 15:
Produce a copy of all documents evidencing the allegation made in paragraph 43 of the
Complaint filed in the above-entitled action that the Sound Choice family of companies produced
as many as 5 new karaoke discs per month.
....
....
4

Request Number 16:
Produce a copy of all documents evidencing the allegation made in paragraph 53 of the
Complaint filed in the above-entitled action that today the Sound Choice family of companies
employs fewer than 10 individuals.
Request Number 17:
Produce a copy of all documents evidencing the allegation made in paragraph 54 of the
Complaint filed in the above-entitled action that Sound Choice Studios, Inc. was Slep-Tone
Entertainment Corporation’s sister company.
Request Number 18:
Produce a copy of all documents evidencing the allegation made in paragraph 54 of the
Complaint filed in the above-entitled action that Sound Choice Studios, Inc. was responsible for
recording new music for karaoke.
Request Number 19:
Produce a copy of all documents evidencing the allegation made in paragraph 55 of the
Complaint filed in the above-entitled action that Sound Choice Studios, Inc. lost money on every
recent new karaoke disc.
Request Number 20:
Produce a copy of all documents evidencing the allegation made in paragraph 54 of the
Complaint filed in the above-entitled action that Sound Choice Studios, Inc. was driven out of
business because it could no longer profitably produce new music as illegally copying of its
products has skyrocketed.
....
5

Request Number 21:
Produce a copy of all documents evidencing the allegation made in paragraph 54 of the
Complaint filed in the above-entitled action that Sound Choice Studios, Inc’s most recent new
disc did not produce enough revenue even to cover the production and licensing costs associated
with it.
Request Number 22:
Produce a copy of all documents evidencing the allegation made in paragraph 54 of the
Complaint filed in the above-entitled action that songs from Sound Choice Studios, Inc’s most
recent new disc can be found on as many as 30,000 karaoke systems around the United States.
Request Number 23:
Produce a copy of all documents evidencing the allegation made in paragraph 54 of the
Complaint filed in the above-entitled action that ex-employees of Sound Choice Studios, Inc.
purchased its assets.
Request Number 24:
Produce a copy of all documents evidencing the allegation made in paragraph 57 of the
Complaint filed in the above-entitled action that karaoke jockeys who legitimately acquired all of
their music at great cost are being forced by illicit competition to produce shows for lower and
lower fees.
Request Number 25:
Produce a copy of all documents evidencing the allegation made in paragraph 57 of the
Complaint filed in the above-entitled action that illegitimate competitors produce shows for onethird the rates a legitimate karaoke jockey can offer.
6

Request Number 26:
Produce a copy of all documents evidencing the allegation made in paragraph 70 of the
Complaint filed in the above-entitled action that Tara King dba DJ Tara King Productions has
used unauthorized media-shifted and format-shifted copies of karaoke accompaniment tracks
which have been marked falsely with Slep-Tone Entertainment Corporation’s federal registered
trademarks.
Request Number 27:
Produce all documents evidencing the amount of revenue Slep-Tone Entertainment
Corporation has lost as a result of Tara King dba DJ Tara King Productions use of unauthorized
media-shifted and format-shifted copies of karaoke accompaniment tracks which have been
marked falsely with Slep-Tone Entertainment Corporation’s federal registered trademarks.
Request Number 28:
Produce all documents evidencing the amount of revenue Slep-Tone Entertainment
Corporation receives from selling each of the karaoke discs it has marketed from January 1, 2000
to September 1, 2012.
Request Number 29:
Produce all documents evidencing notice given to Tara King dba DJ Tara King
Productions regarding Slep-Tone Entertainment Corporation’s conditions of tolerance as
described in paragraph 72 of the Complaint filed in the above-entitled action prior to the filing of
the Complaint in the above-entitled action.
Request Number 30:
Produce all documents evidencing notice given to Tara King dba DJ Tara King
Productions regarding the allegations made in paragraph 73 of the Complaint filed in the above7

entitled action that media-shifting or format-shifting that occurs outside the conditions of
tolerance as described in paragraph 72 of the Complaint filed in the above-entitled action is
entirely without authorization or tolerance prior to the filing of the Complaint in the aboveentitled action.
Request Number 31:
Produce a copy of all documents evidencing the allegation made in paragraph 74 of the
Complaint filed in the above-entitled action that Tara King dba DJ Tara King Productions used
media-shifted karaoke accompaniment tracks marked with Slep-Tone Entertainment
Corporation’s registered trademarks for commercial purposes.
Request Number 32:
Produce a copy of all documents evidencing that Tara King dba DJ Tara King
Productions received notice that the Sound Choice logo was a registered trademark.
Request Number 33:
Produce a copy of all documents evidencing the allegation made in paragraph 78 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation and its
affiliated companies pay statutory and negotiated royalties to the owners of the copyrights in the
underlying musical works including, but not limited to, copies of cancelled checks, receipts and
all contracts entered between Slep-Tone Entertainment Corporation and its affiliated companies
and the holders of the copyrights.
Request Number 34:
Produce a copy of all documents evidencing the allegation made in paragraph 80 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation and its
affiliated companies have spent millions of dollars building and maintaining studios, including,
8

but not limited to, land purchase contracts, construction contracts, lease agreements, cancelled
checks and receipts for the purchases of electronic recording equipment.
Request Number 35:
Produce a copy of all documents evidencing the allegation made in paragraph 80 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation and its
affiliated companies have spent millions of dollars hiring artists including, but not limited to,
employment contracts, cancelled checks, and W-2 forms (on which the name of the artist and
their social security number and address may be redacted).
Request Number 36:
Produce a copy of all documents evidencing the allegation made in paragraph 80 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation and its
affiliated companies have spent millions of dollars paying royalties to copyright owners
including, but not limited to, contracts and cancelled checks.
Request Number 37:
Produce a copy of all documents evidencing the allegation made in paragraph 83 of the
Complaint filed in the above-entitled action that on average for each legitimate copy of a karaoke
music disc created by Slep-Tone Entertainment Corporation and its affiliated companies, dozens
of illegitimate copies of the contents of the disc have been created.
Request Number 38:
Produce a copy of all documents evidencing the allegation made in paragraph 85 of the
Complaint filed in the above-entitled action that widespread pirating of karaoke song tracks has
contributed to the loss of more than sixty jobs at Slep-Tone Entertainment Corporation’s location
in Charlotte, North Carolina.
9

Request Number 39:
Produce a copy of all documents evidencing the allegation made in paragraph 85 of the
Complaint filed in the above-entitled action that widespread pirating of karaoke song tracks has
contributed Slep-Tone Entertainment Corporation suffering several consecutive years of
operating losses.
Request Number 40:
Produce a copy of the fee agreement between Slep-Tone Entertainment Corporation and
its attorneys in the above-entitled action.
Request Number 41:
Produce a copy of all documents evidencing the allegation made in paragraph 89 of the
Complaint filed in the above-entitled action that because of piracy it is nearly impossible for
legitimate karaoke jockeys to compete against illegal karaoke jockeys.
Request Number 42:
Produce a copy of all documents evidencing the allegation made in paragraph 90 of the
Complaint filed in the above-entitled action that even when illegitimate karaoke jockeys have
been forced through legal action or agreement to destroy their counterfeit copies of Slep-Tone
Entertainment Corporation’s tracks, illegitimate karaoke jockey’s continue to engage in unfair
competition using pirated materials belonging to other manufacturers.
Request Number 43:
Produce a copy of all documents evidencing the relationship between Slep-Tone
Entertainment Corporation and Sound Choice Studios, Inc.
Request Number 44:
Produce a copy of all documents evidencing the allegation made in paragraph 95 of the
10

Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation is the
owner of U.S. Trademark Registration No. 1,923,448 for the trademark SOUND CHOICE.
Request Number 45:
Produce a copy of all documents evidencing the allegation made in paragraph 86 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation is the
owner of U.S. Trademark Registration No. 2,000,725 for a trademark of the Sound Choice logo
shown in paragraph 86 of the Complaint filed in the above-entitled action.
Request Number 46:
Produce a copy of all documents evidencing when U.S. Trademark Registration No.
1,923,448 became effective.
Request Number 47:
Produce a copy of all documents evidencing when U.S. Trademark Registration No.
2,000,725 became effective.
Request Number 48:
Produce a copy of all documents evidencing the allegation made in paragraph 98 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation’s
investigators observed Tara King dba DJ Tara King Productions possessing unauthorized
counterfeit copies of at least one work bearing the Sound Choice Marks.
Request Number 49:
Produce a copy of all documents evidencing the allegation made in paragraph 98 of the
Complaint filed in the above-entitled action that Slep-Tone Entertainment Corporation’s
investigators observed Tara King dba DJ Tara King Productions using unauthorized counterfeit
copies of at least one work bearing the Sound Choice Marks.
11

Request Number 50:
Produce a copy of all documents evidencing the allegation made in paragraph 158 of the
Complaint filed in the above-entitled action that DJ Tara King Productions and Tara King were
observed operating a karaoke system to produce multiple karaoke shows at multiple venues in
Nevada in which counterfeit copies of Slep-Tone Entertainment Corporation accompaniment
tracks were being used.
Request Number 51:
Produce a copy of all documents evidencing the allegation made in paragraph 159 of the
Complaint filed in the above-entitled action that DJ Tara King Productions and Tara King
repeated displayed the Sound Choice Marks.
Request Number 52:
Produce a copy of all documents evidencing the allegation made in paragraph 160 of the
Complaint filed in the above-entitled action that DJ Tara King Productions and Tara King
perform regular karaoke shows at multiple venues in Nevada using multiple karaoke systems.
Request Number 53:
Produce a copy of all documents evidencing the allegation made in paragraph 161 of the
Complaint filed in the above-entitled action that DJ Tara King Productions and Tara King
regularly perform karaoke shows at multiple separate eating and drinking establishments
simultaneously.
Request Number 54:
Produce a copy of all documents evidencing the allegation made in paragraph 162 of the
Complaint filed in the above-entitled action that DJ Tara King Productions and Tara King have
....
12

advertised or otherwise indicated that they are in possession of a library containing more than
200,000 tracks stored on their karaoke systems.
Dated this 27th day of August, 2012.
DJ TARA KING PRODUCTIONS

_________________________________
TARA KING
1094 Chavez Court
North Las Vegas, Nevada 89031
Phone: (702) 395-5464
Facsimile: (702) 395-6265
Email: djtara@djtaraking.com
Defendant in proper person
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13

CERTIFICATE OF MAILING
I hereby certify that on the 27th day of August, 2012, I mailed a true and correct copy of
the foregoing TERA KING’S REQUEST FOR PRODUCTION OF DOCUMENTS TO SLEPTONE ENTERTAINMENT CORPORATION via first class mail, postage prepaid, in a sealed
envelope, by depositing same in a receptacle marked for mailing with the United States Postal
Service and addressed to the following:
Kerry P. Faughnan, Esq.
Law Offices of Kerry P. Faughnan
P.O. Box. 335361
North Las Vegas, Nevada 89033
Terry A. Coffing, Esq.
John M. Sacco, Esq.
Brian R. Hardy, Esq.
MARQUIS AURBACH COFFIN
10001 Park Run Drive
Las Vegas, Nevada 89145
Mark G. Tratos, Esq.
Lauri S. Thompson, Esq.
Peter H. Ajemian, Esq.
GREENBERG TRAURIG, LLP
3733 Howard Hughes Pkwy., Suite 400 North
Las Vegas, Nevada 89169
Thomas D. Boley, Esq.
BOLEY AND ALDABBAGH LAW FIRM
3143 Industrial Road
Las Vegas, Nevada 89109
....
....
....
....
....
14

Frank A. Ellis, III, Esq.
ELLIS & GORDON
510 S. Ninth Street
Las Vegas, Nevada 80101
Nicholas Tsunis
Office 7 Lounge & Restaurant, Inc.
6600 W. Charleston Blvd.
Las Vegas, Nevada 89146
DJ TARA KING PRODUCTIONS

_________________________________
TARA KING
1094 Chavez Court
North Las Vegas, Nevada 89031
Phone: (702) 395-5464
Facsimile: (702) 395-6265
Email: djtara@djtaraking.com
Defendant in proper person

15


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