Case 2:15-cv-03462-RGK-AGR Document 119-7 Filed 03/07/16 Page 1 of 4 Page ID

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Francis Malofiy, Esq.

Francis Alexander, LLC
280 N. Providence Rd. | Suite 105
Media, PA 19063
T: (215) 500-1000; F: (215) 500-1005
E: francis@francisalexander.com
Attorney for Plaintiff
Glen L. Kulik, Esq. (SBN 082170)
Kulik Gottesman & Siegel LLP
15303 Ventura Blvd., Suite 1400
Sherman Oaks, CA 91403
T: (310) 557-9200; F: (310) 557-0224
E: gkulik@kgslaw.com
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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MICHAEL SKIDMORE, as Trustee for

15 the RANDY CRAIG WOLFE TRUST,
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Case No. 15-cv-03462 RGK (AGRx)

Hon. R. Gary Klausner

Plaintiff,

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DECLARATION OF MARK ANDES

IN OPPOSITION TO
DEFENDANTS MOTION FOR
SUMMARY JUDGMENT OR IN
THE ALTERNATIVE, PARTIAL
SUMMARY JUDGMENT

v.

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LED ZEPPELIN; JAMES PATRICK

PAGE; ROBERT ANTHONY PLANT;
JOHN PAUL JONES; SUPER HYPE
PUBLISHING, INC.; WARNER MUSIC
GROUP CORP., Parent of
WARNER/CHAPPELL MUSIC, INC.;
ATLANTIC RECORDING
CORPORATION; RHINO
ENTERTAINMENT COMPANY,

Date: March 28, 2016

Time: 9:00 a.m.
Room:

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Defendants.

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DECLARATION OF MARK ANDES

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DECLARATION OF MARK ANDES IN OPPOSITION TO DEFENDANTS MOTION FOR
SUMMARY JUDGMENT OR IN THE ALTERNATIVE, PARTIAL SUMMARY JUDGMENT

Case 2:15-cv-03462-RGK-AGR Document 119-7 Filed 03/07/16 Page 2 of 4 Page ID

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I, Mark Andes, declare as follows:

1.

I was the original bassist for the band Spirit from 1967 through 1970.

2.

Randy Craig Wolfe, the guitarist for Spirit, was a musical genius.

3.

Randy wrote the song Taurus in 1966 and Spirit played the song in

early and mid-1967, including at the Ash Grove.

4.

The song Taurus was created by Randy well before myself and other

Spirit members signed the August 29, 1967 songwriting contract with Hollenbeck

Music and Lou Adler.

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5.

all of Spirits albums.

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Taurus received radio airplay in the late 1960s and early 1970s, as did

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Spirit was very popular in the United Kingdom and our albums,

including Spirit, were sold all over the world in the late 1960s and early 1970s.

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7.

Led Zeppelin and its members were familiar with myself and Spirit.

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8.

I was introduced to Led Zeppelin by Toby Roberts backstage at the

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show Led Zeppelin opened for Spirit in Denver on December 26, 1967.

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Robert Plant.

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10.

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Before the show, Spirits members were told that Robert Plant was

present and Spirits members had a quick meet-and-greet with Plant.

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Another instance was at a club in early 1970 called Mothers Club,

where Spirit played a show.

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During that conversation Plant told me that he really liked Spirits

sound, and I returned the compliment. The conversation lasted several minutes.

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At the Atlanta Pop Festival I had a discussion with Robert Plant as Led

Zeppelin coming on stage following Spirits set.

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In particular I had several interactions with Led Zeppelin front man,

14.

After the show Randy California, John Locke, and myself went out

with Robert Plant and spent the night drinking and playing snooker.

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15.
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As Plant was driving home later that night he was involved in a serious
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DECLARATION OF MARK ANDES IN OPPOSITION TO DEFENDANTS MOTION FOR

SUMMARY JUDGMENT OR IN THE ALTERNATIVE, PARTIAL SUMMARY JUDGMENT

Case 2:15-cv-03462-RGK-AGR Document 119-7 Filed 03/07/16 Page 3 of 4 Page ID

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car crash.

16.

I also met Robert Plant in 1982 when I was touring with Heart. Plant

came up to me because he remembered me from Spirit and we had a conversation

with the rest of Heart present.

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I declare under the penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.

Executed March 7, 2016 in Magnolia, TX.

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_______/s/ Mark Andes______________

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Mark Andes

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DECLARATION OF MARK ANDES IN OPPOSITION TO DEFENDANTS MOTION FOR
SUMMARY JUDGMENT OR IN THE ALTERNATIVE, PARTIAL SUMMARY JUDGMENT

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DECLARATION OF MARK ANDES IN OPPOSITION TO DEFENDANTS MOTION FOR
SUMMARY JUDGMENT OR IN THE ALTERNATIVE, PARTIAL SUMMARY JUDGMENT