Escolar Documentos
Profissional Documentos
Cultura Documentos
JS 44C/SDNY
REV. 7/2012
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of
pleadings or other papers as required by law, except as provided by local rules ofcourt. This form, approved bythe
Judicial Conferenceof the United States in September 1974, is required for use of the Clerkof Courtforthe purpose of
initiating the civil docket sheet.
DEFENDANTS
PLAINTIFFS
i/vU ^
Eric Johnson
15 CV 1356
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OF CAUSE)
(DONOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
No
[*
Yes
Yes D
TORTS
[
[
[
[
] 110
]120
1130
1140
[]150
[ ]151
[1152
PERSONAL INJURY
INSURANCE
MARINE
[ ]310 AIRPLANE
[ ] 315 AIRPLANE PRODUCT
LIABILITY
MILLER ACT
NEGOTIABLE
INSTRUMENT
RECOVERY OF
[ ] 330 FEDERAL
SLANDER
OVERPAYMENT &
EMPLOYERS'
ENFORCEMENT
OF JUDGMENT
MEDICARE ACT
RECOVERY OF
DEFAULTED
LIABILITY
STUDENT LOANS
[ ] 340 MARINE
[ ) 345 MARINE PRODUCT
LIABILITY
(EXCL VETERANS)
[]153
[]160
RECOVERY OF
OVERPAYMENT
OF VETERAN'S
PERSONAL INJURY
[ ] 362
PRODUCT LIABILITY
[ ] 368
[1610
[ ] 620
AGRICULTURE
OTHER FOOD &
[ ]400 STATE
DRUG
[ ] 423 WITHDRAWAL
[]625
INJURY PRODUCT
LIABILITY
PERSONAL PROPERTY
[
[
[
[
] 630
] 640
]650
]660
[ ]690
DRUG RELATED
SEIZURE OF
PROPERTY
21 USC 881
LIQUOR LAWS
RR & TRUCK
AIRLINE REGS
OCCUPATIONAL
SAFETY/HEALTH
PRODUCT LIABILITY
INJURY
LABOR
STOCKHOLDERS
SUITS
[]720
STANDARDS ACT
LABOR/MGMT
OTHER
PRISONER PETITIONS
CONTRACT
CONTRACT
[ ]510
REAL PROPERTY
[ ] 441 VOTING
[ ] 442 EMPLOYMENT
[ ] 443 HOUSING/
MOTIONS TO
LAND
[ ] 444 WELFARE
[ ] 445 AMERICANS WITH
[ ]240
[]245
EJECTMENT
TORTS TO LAND
TORT PRODUCT
[ ]290
LIABILITY
ALL OTHER
DISABILITIES EMPLOYMENT
(RICO)
[]480
[ ]490
11810
[ ]850
[
[
[
[
[
]861
] 862
] 863
] 864
] 865
HIA(1395ff)
BLACK LUNG (923)
DIWC/DIWW (405(g))
SSID TITLE XVI
RSI (405(g))
LABOR/MGMT
REPORTING &
RAILWAY LABOR ACT
OTHER LABOR
LITIGATION
EMPL RET INC
SECURITY ACT
CONSUMER CREDIT
CABLE/SATELLITE TV
SELECTIVE SERVICE
SECURITIES/
COMMODITIES/
EXCHANGE
[]875 CUSTOMER
CHALLENGE
12 USC 3410
DISCLOSURE ACT
VACATE SENTENCE
20 USC 2255
[]740
[]790
[ ] 530 HABEAS CORPUS
[ ] 535 DEATH PENALTY
[ ] 540 MANDAMUS& OTHER [)791
[ ]893 ENVIRONMENTAL
MATTERS
[]894
ENERGY
ALLOCATION ACT
26 USC 7609
[ ]895
FREEDOM OF
[ ]900
APPEAL OF FEE
INFORMATION ACT
IMMIGRATION
ACCOMMODATIONS
CONDEMNATION
FORECLOSURE
[ ] 830 PATENT
[ ] 840 TRADEMARK
RELATIONS
[ ]730
CIVIL RIGHTS
PROPERTY RIGHTS
ftJ820 COPYRIGHTS
SOCIAL SECURITY
FAIR LABOR
28 USC 157
[]410 ANTITRUST
[]430 BANKS & BANKING
[ 1450 COMMERCE
[ ]460 DEPORTATION
[]470 RACKETEER INFLU
[]710
PRODUCT
LIABILITY
REAPPORTIONMENT
28 USC 158
OTHER
PROPERTY DAMAGE
[J 190
[ 1210
OTHER STATUTES
ASBESTOS PERSONAL
[ ]195
[ ]220
[ ]230
BANKRUPTCY
[ ] 422 APPEAL
PRODUCT LIABILITY
FORFEITURE/PENALTY
BENEFITS
[]196 FRANCHISE
JS 3 -) i mk
NATURE OF SUIT
CONTRACT
DETERMINATION
UNDER EQUAL
[]462
[]463
DISABILITIES -OTHER
NATURALIZATION
ACCESS TO JUSTICE
APPLICATION
HABEAS CORPUSALIEN DETAINEE
[ )950 CONSTITUTIONALITY
OF STATE STATUTES
OTHER IMMIGRATION
ACTIONS
REAL PROPERTY
DEMAND $_
OTHER
DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.?
IF SO, STATE:
JUDGE
DOCKET NUMBER
NOTE: Please submit at the time of filing an explanation of why cases are deemed related.
M 1 Original
ORIGIN
Q 3 Remanded D 4 Reinstated or
fj 2 Removed from
Proceeding
state Court
from
7 Appeal toDistrict
Judge from
Magistrate Judge
Judgment
Litigation
(Specify District)
Reopened
Appellate
Court
I | b. At leastone
party is pro se.
1US PLAINTIFF
IF DIVERSITY, INDICATE
BASIS OF JURISDICTION
CITIZENSHIP BELOW.
Q4 DIVERSITY
DEF
PTF
DEF
[ ]1
[ ]1
CITIZEN OR SUBJECT OF A
FOREIGN COUNTRY
[]3 [ ]3
[ ]2
[ ]2
[ ]4 [ ]4
PTF
DEF
[ ]5
[ ]5
[16
[]6
Checkone:
WHITE PLAINS
M MANHATTAN
(DO NOT check either box ifthis a PRISONER PETITION/PRISONER CIVIL RIGHTS COMPLAINT.)
[] NO
M YES (DATE ADMITTED Mo.
RECEIPT*
yi 5
Magistrate Judge
Ruby J. Krajick, Clerk of Court by
01
^"j*
is so Designated.
Yr.J013_,
(212) 520-4296
15 CV 1356
ERIC JOHNSON,
Plaintiff,
- against -
COMPLAINT
Defendant.
COMPLAINT
Mr. Eric Johnson (hereinafter "Plaintiff), by and through his undersigned counsel, for
his Complaint against Steed Media Group ("Defendant"), states and alleges as follows:
THE PARTIES
1.
Plaintiff Eric Johnson is a citizen of the State ofNew York, County ofNew York,
with his principal place ofbusiness at 472 9th Avenue, Apt. #3, New York, New York, 10018
2.
Georgia corporation with its principal place of business in Atlanta, Georgia and with offices in
New York, New York and around the United States.
3.
This is an action for copyright infringement arising under the Copyright Act of
1976, as amended, 17 U.S.C. 101 et seq. (the "Copyright Act"). This action arises from
Defendant's unauthorized and unlawful reproduction, distribution, and public display of certain
4.
This Court has subject matter jurisdiction pursuant to 17 U.S.C. 501 and 28
5.
This Court has personal jurisdiction over Defendant because Defendant engages
in continuous and systematic business activities in the State of New York and/or has purposely
directed substantial activities at the residents of New York by means of the web site described
herein and derives substantial revenue from interstate commerce. This Court also has personal
jurisdiction over Defendants pursuant to the long-arm statute of New York because the causes of
action alleged herein arise from transactions of business carried out by Defendants in this State
and/or from transactions of business to supply goods or services in this State carried out by
Defendants and/or from tortious acts causing injury to person and/or property within this State.
C.P.L.R. 302; see Penguin Group (USA) Inc. v. Am. Buddha, 16 N.Y.3d 295 (2011).
6.
this Judicial District and/or because a substantial part of the events giving rise to the causes of
action alleged herein occurred in this Judicial District, and the injury suffered by Plaintiff took
place in this Judicial District.
FACTUAL ALLEGATIONS
A.
PLAINTIFF AND HIS ORIGINAL CREATION AND USE OF HIS
COPYRIGHTED PHOTOGRAPHS OF AALIYAH AND THE NOTORIOUS B.I.G. &
FAITH EVANS
7.
and artist. He is a citizen of the State of New York and resides in the Borough of Manhattan.
8.
producing iconic photographic portraits of a wide, diverse group of musicians, artists, and
celebrities for over twenty-five years. His photographs have been published in countless books,
magazines, newspapers and periodicals, used as cover artwork for music albums, and shown in
gallery shows. Many of his more well-known portraits have become truly etched into the public
consciousness.
9.
Plaintiff is the legal and beneficial owner of a vast number of his original
photographs, certain of which he licenses and/or sells, and many of which he has not licensed or
sold and instead maintains in his private personal archive. Plaintiff has invested significant time,
money, resources and manpower over his distinguished and longstanding career in building and
maintaining his personal photograph archive.
10.
In July 1995, Plaintiff shot a series of photographs of the rapper and recording
artist The Notorious B.I.G. and his wife, recording artist Faith Evans (the "BIG/Evans
Photographs").2
The certificate of copyright registration covering the BIG/Evans Photographs (U.S. Reg. No. VA 1-929-530),
which identifies Plaintiff as author and copyright claimant, is attached hereto at Exhibit 1.
11.
come to define the enduring images of the late recording artists The Notorious B.I.G. and
Aaliyah among the public and their devoted fans.
B.
13.
Upon information and belief, Defendant, Steed Media Group, Inc., is a print and
new media publishing company which claims to distribute the nation's largest chain of AfricanAmerican newspapers. Upon information and belief, Defendant publishes a print edition of its
publication, titled "Rolling Out," and distributes 1.2 million copies thereof each week in 19 of
the top 25 African-American markets. Upon information and belief, over 90,000 copies of
Defendant's "Rolling Out" print publication are distributed in New York City each week.
14.
Upon information and belief, at all times relevant to this dispute, Defendant has
publishing outlet, which entertains over 150,000 unique visitors each month with, inter alia,
celebrity, music, lifestyle, and gossip articles.
16.
Upon information and belief, Defendant is the registered owner and operator of
the Website and is responsible for all of the content that appears thereon.
17.
Upon information and belief, Defendant takes an active role in selecting content
to appear on the Website by, inter alia, selecting, copying, posting, and publicly displaying
photographic images thereon, and employing moderators and administrators ("Employees") who,
The certificate of copyright registration covering the Aaliyah Photographs (U.S. Reg. No. VA 1-910-554), which
identifies Plaintiff as author and copyright claimant, is attached hereto at Exhibit 1.
within the scope of their employment, select and control the content (including photographic
images) displayed on the Website.
18.
advertisements and markets the goods and services of Defendant to the public, including to
persons located in the State of New York. Upon information and belief, Defendant profits from
its operation of the Website.
19.
Website by which third parties who access the Website can reproduce and/or distribute content
thereon, including photographic images.
C.
20.
reproducing, distributing, publicly displaying, and making available for further reproduction,
distribution and public display, such photographs on the Website. Attached hereto at Exhibit 2
are true and correct copies of printouts of web pages on the Website showing Defendant's
infringing uses of one of the BIG/Evans Photographs and five of the Aaliyah Photographs, and,
at Exhibit 3, reproductions of Plaintiff s infringed photographs. Each of the printouts of the
Website attached at Exhibit 2 shows an exact copy of one of Plaintiff s original BIG/Evans
Photographs or Aaliyah Photographs attached at Exhibit 3.
21.
attached hereto at Exhibit 2), Defendant commenced seven separate and distinct infringing uses
of one of the BIG/Evans Photographs on or about September 5, 2012, October 8, 2012, October
29, 2012, October 31,2012, January 18,2013, November 27,2013, and October 18, 2014, and
Defendant commenced five separate and distinct infringing uses of five of the Aaliyah
Photographs on or about April 27, 2012, January 16, 2013, May 23, 2014, May 26, 2014, and
June 23, 2014.
22.
displayed on the Website were posted thereon by Defendant and/or Defendant's Employees
acting within the scope of their employment with Defendant. None of the infringing copies of
the BIG/Evans Photographs or the Aaliyah Photographs were posted on the Website at the
direction of a "user" as defined under 17 U.S.C. 512.
23.
BIG/Evans Photographs and Aaliyah Photographs on the Website with knowledge of their
renown among the public and the devoted fans of The Notorious B.I.G. and Aaliyah, with the
intention of attracting web visitor traffic to the Website by their visibility thereon, thereby
increasing advertising revenues and sales of its goods and services.
24.
Upon information and belief, Defendant has driven significant traffic to the
Website by the presence of Plaintiff s photographs thereon. The increased traffic to the Website
has led to the generation of substantial revenues for Defendant directly attributable to its
infringements of Plaintiff s copyrights.
25.
been sued for copyright infringement on the basis of unauthorized use of photographs on the
Website at least four times since 2012.
26.
of record in its two current litigation defenses) over many months, beginning in June 2014.
However, neither Defendant nor its counsel has responded to any of our communications in any
manner, and the infringing copies of Plaintiff s photographs remain publicly displayed and
available for further reproduction and distribution on the Website to this day. Furthermore,
Defendant commenced no fewer than two of its infringing uses of Plaintiff s photographs
Plaintiff has complied in all respects with Title 17 of the United States Code,
secured the exclusive rights and privileges to the BIG/Evans Photographs and the Aaliyah
Photographs, and obtained the appropriate certificates of copyright registration, U.S. Copyright
Reg. Nos. VA 1-910-544 and VA 1-929-530 (attached hereto at Exhibit 1).
28.
Upon information and belief, Defendant has engaged in the infringing acts
forming the basis of this Complaint knowingly of, and with reckless disregard for, Plaintiffs
rights in the Photographs, and were aware and/or should have been aware that its infringing
activities constitute infringements under the Copyright Laws of the United States.
29.
Upon information and belief, Defendant has engaged in its illicit reproduction,
distribution and public display of Plaintiffs photographs infringing activities for the purpose of
profiting therefrom.
30.
Upon information and belief, at all times material hereto, Defendant has had the
means and ability to stop the reproduction, distribution, and public display of Plaintiff s
copyrighted photographs, on the Website and, despite being repeatedly put on notice of the
infringing nature ofthe copies ofPlaintiffs photographs displayed on the Website, has failed to
do so.
31.
substantially harmed.
32.
above have caused and, if not enjoined, will continue to cause irreparable harm to Plaintiff.
FIRST COUNT
33.
At all times herein, Plaintiff has been and is still the owner, and proprietor of all
right, title and interest in and to the BIG/Evans Photographs and the Aaliyah Photographs. The
BIG/Evans Photographs and the Aaliyah Photographs are original, creative works of Plaintiff s
authorship and constitute copyrightable subject matter under the CopyrightAct.
35.
Plaintiff has complied in all respects with the Copyright Act's prerequisites for a
copyright infringement action, including obtaining certificates of copyright registration from the
Copyright Office covering each of the infringed photographs (attached hereto at Exhibit 1).
36.
Defendant has not obtained valid license, authorization or permission to use any
of the BIG/Evans Photographs or the Aaliyah Photographs in any manner, and Plaintiff has not
assigned any of his exclusive rights in his copyrights in the BIG/Evans Photographs or the
Aaliyah Photographs to Defendant.
37.
rights under 17 U.S.C 106, Defendantimproperly and illegally copied, reproduced, distributed,
the Website as set forth in this Complaint violates Plaintiffs exclusive rights under the
Upon information and belief, thousands of people throughout the United States
have viewed the infringing copies of the BIG/Evans Photographs and the Aaliyah Photographs
on the Website.
40.
infringements alleged herein, and has knowingly and willfully carried out its infringing activities,
continue to do so to this day despite being repeatedly put on notice of its infringements, and will
continue to do so unless enjoined by this Court.
41.
42.
Individuals using the Website that Defendant owns, operates, distributes, and
promotes, have been provided with technological means to directly infringe and are directly
infringing Plaintiffs copyrights in the BIG/Evans Photographs and the Aaliyah Photographs by
creating and distributing unauthorized reproductions thereof on social media providers including
Facebook, Twitter, and Tumblr.
44.
1.
That the Court enter ajudgment finding that Defendant has directly infringed and
induced others to infringe Plaintiffs U.S. Copyright Reg. Nos. VA 1-910-544 and VA 1-929530 in violation of17 U.S.C. 501 et seq. and award damages and monetary and injunctive
relief as follows:
a.
b.
c.
2.
Such other and further reliefthatthe Court determines is just and proper.
JURY DEMAND
10
Respectfully submitted,
11
EXHIBIT 1
Certificate of Registration
Th!> Certificate is-nuvJ umici she sea! of (he Copvnviht
Orticc in accorJana: with Mil '~ ! 'rrtctiM-ilc< Cede.
Registration Number
VA 1-910-544
Effective date of
registration:
December 9,2013
Title
Completion/Publication
Year of Completion:
Date of 1st Publication:
2001
June 7,2001
Author
Author:
Author Created:
Citizen of:
Eric Johnson
photograph(s)
United States
Copyright claimant
Copyright Claimant: Eric Johnson
472 Ninth Avenue, Apt. #3,New York, NY, 10018, United States
Alex Malbin
Email:
alexigeric-johnson.com
Name:
Alexander Malbin
Date:
December 9, 2013
Certification
Correspondence: Yes
Page 1 of 1
^ertiicate.;rf:feistf^ioii^
Ml. Eertifate issued wilte^SealoftheC^Jvrlgfet
,e toaccordance with; title t% United SMes Code,
^lS<^.
Registration Number
mi-929-530
Elfecttvedateof
gistratioa;
Title
October!, 2014
:
:
!
Completion/Publication
YearofCoBJptetton: 1995
Dttt* of IstPuWMtton: July25,199$
Airtrior
'.:' Author! ;; Eric Johnson'"
Author Created: photog
Work made for hire!
No
Copyright claimant
Copyright Claimant: EricJohnson
472Ninth Avenue, NewYork, NY, 10018, Uflited States
Certification
'Namel'i: Alex.Malbin \;
:':-JJfRv: October2,2014;
Page 1 of 1
EXHIBIT 2
1/21/15, 9:04 PM
Faith reveals whatshe didn't know about Biggie and Lil Kim - Rolling Out
THE E^afs
m^mmmx*
MUSIC(HTTP://ROLUNGOUT.COM/CATEGORY/MUSIC/)
f
SHARE
FEATURED NOW
*
TWEET
PIN
(http://rollingout.com/music/tlc-launcheskickstarter-campaign-final-album-raisesurprising-amount/)
(http://rollingout.com/politics/highlights(http://rollingout.com/wp-content/uploads/2014/10/notorious-bigand-faith-evans.png)
president-barack-obama-state-unionaddress/)
(http://rollingout.com/entertainment/delta-
sigma-theta-kicks-deltas-sorority-sisters/)
http://rollingout.com/music/faith-reveals-didnt-know-biggie-lil-kim/
Page 1 of 7
1/23/2015
ENTERTAINMENT (HTTP://ROLLINGOUT.COM/CATEGORY/ENTERTAINMENT/)
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http://rollingout.com/entertainment/aaliyah-biopic-reveal-alleged-affair-r-kelly/
1/18
1/23/2015
(http://rollingout.com/wp-content/iip1oads/2014/01/aalivahl.ipg)
An upcoming biopic with Aaliyah will delve into her alleged affair with R. Kelly. According to
a report by the New York Post, the film will reveal details of their relationship.
http://rollingout.com/entertainment/aaliyah-biopic-reveal-alleged-affair-r-kelly/
2/18
2/5/2015
M0VIES(HTTP://R0LLING0UT.C0M/CATEG0RY/M0VIES/)
&/^!&&>iri!w/mt&^'&&w4iii*^^
http://rollingout.com/movies/will-play-aaIiyah-vhl-biopic-top-5-picks/
1/18
2/5/2015
(http://rollingout.com/wp-content/uploads/2014/01/aaliyahl2.jpg)
With VHl in the works on an epic Aaliyah (http://rollingout.com/movies/aaliyah-biopic-
coming-vhl/) biopic, fans are weighing in on whom they feel should take on the role of the
legendary singer.
While there has been no official report as to who VHl has locked in, several celebrity names
have been thrown into the mix as possible picks poised to play the late and great "Rock the
Boat" singer.
Hit the flip for celebrities rumored to play Aaliyah intheir upcoming biopic. Who would you
http://rollingout.com/movies/will-play-aaliyah-vhl-biopic-top-5-picks/
2/18
1/21/15, 9:13 PM
R*aWeMuWto*Piife
Aaliyah movies
threatens to
TV
(HTTP://ROLLINGOUT
OJUN18.2014
e? SHARE
>
production-lifetime-biopic/)
Zendaya Coleman maynot get to playher dream
role after all. Just days after Lifetime announced
that they had
(http://rollingout.com/tv/aaliyahs-family-attempts-
stop-production-lifetime-biopic/)
hawkins/)
mored to play
-nnml biopic
MOVIES
(HnP://RO LLINGOUT.CO
MAY26,2014
& SHARE
(http://rollingout.com/movies/will
play-aaliyah-vhl-biopic-top5-picks/)
With VHl in the works on an epic Aaliyah biopic,
(http://rollingout.com/movies/will-play-aaliyah-
hawkins/)
vhl-biopic-top-5-picks/)
http://rollingout.com/tag/aaliyah-movies/
Page 1 of 2
1/21/15,9:13 PM
MOVIES
(HTTP://R0LLING0UT.C0lM
MAY 23,2014
OSHARE
(http://rollingout.com/movies/aaliy
biopic-coming-vhl/)
(http://rollingout.com/movies/aaliyah-biopicVH1 to release Aaliyah biopic this summer Last fall,
coming-vhl/)
,. .
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http://rollingout.com/tag/aahyah-movies/
Page 2 of 2
1/21/15, 8:59 PM
Manila Luzon talks life after boyfriend Sahara Davenport's death - Rolling Out
ReaiMcMuffin'Wcby:<amadalakld
'"
ENTERTAINMENT(HnP://ROLLINGOUT.COM/CATEGORY/ENTERTAINMENT/)
SHARE
(http://rollingout.com/music/tlc-launches-
TWEET
kickstarter-campaign-final-album-raise@ PIN
surprising-amount/)
(http://rollingout.com/politics/highlights-
president-barack-obama-state-unionFaith Evans
address/)
R&B star Faith Evans lost her husband, hip-hop legend The
Notorious B.I.G., in 1997,during a drive-by shooting.
(http://rollingout.com/entertainment/delta-
Pages: 1(http://rollingout.com/entertainment/manila-luzon-talks-
sigma-theta-kicks-deltas-sorority-sisters/)
life-boyfriend-sahara-davenports-death/) 2 3
(http://rollingout.com/entertainment/manila-luzon-talks-life-
http://rollingout.eom/entertainment/manila-luzon-talks-life-boyfriend-sahara-davenports-death/2/
Page 1 of 7
Chilli's finally over Usher? 10 ofurban music's most famous failed couples
2/5/2015
MUSIC (HTTW/ROLUNGOUT.COM/CATEGORY/MUSIC/)
WS**^S8*<!*W*<^
http://rollingout.com/music/chillis-finally-over-usher-who-are-urban-musics-most-famous-failed-couples/10/
1/18
1/23/2015
MUSIC(HTTP://ROLLINGOUT.COM/CATEGORY/MUSIC/)
(http://rollingout.com/music/happy-birthday-aaliyah-10-reasons-to-celebrate-hermusical-legacy/attachment/aaliyah-10/)
http://rollingout.com/music/happy-birthday-aaliyah-10-reasons-to-celebrate-her-musical-legacy/
1/19
1/21/15, 9:00 PM
MUSIC(HnP://ROLLINGOUT.COM/CATEGORY/MUSIC/)
E5 YOUR SOU1
Pfaces
FEATURENOW
f
SHARE
(http://rollingout.com/music/tlc-launches-
TWEET
kickstarter-campaign-final-album-raise
PIN
surprising-amount/)
president-barack-obama-state-union-
Inthe '90s, Biggie Smalls created a song, "Dreams," about his love for
R&B divas, including Patti LaBelle, Mariah Carey, Mary J. Blige and
address/)
(http://rollingout.com/entertainment/delta-
Pages: 1(http://rollingout.com/musicAendrick-lamar-reveals-crush-
sigma-theta-kicks-deltas-sorority-sisters/)
on-brandy-debuts-high-on-billboard-charts/)2
(http://rollingout.com/music/kendrick-lamar-reveals-crush-onbrandy-debuts-high-on-billboard-charts/2/)3
http://rollingout.eom/music/kendrick-lamar-reveals-crush-on-brandy-debuts-high-on-billboard-charts/6/
Page 1 of 7
2/5/2015
MUSIC (HTTP://ROLUNGOUT.COM/CATEGORY|MUSIC/)
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http://rollingout.eom/music/natina-reeds-ex-boyfriend-kurupt-opens-up-about-her-death/5/
1/18
2/5/2015
ENTERTAINMENT(HTTP://ROLLINGOUT.COM/CATEGORY/ENTERTAINMENT/)
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http://rollingout.eom/entertainment/sahara-davenports-boyfriend-manila-luzon-opens-up-about-his-death/3/
1/18
1/21/15, 9:01 PM
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Highlights ofPresident Barack Obama's State
Faith Evans
R&B star Faith Evans lost her husband, hip-hop legend The
Notorious B.I.G., in 1997, during a drive-by shooting.
of the Unionaddress
(http://rollingout.com/politics/highlightspresident-barack-obama-state-unionaddress/)
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about-his-suicide/) 2 3 (http://rollingout.com/music/chris-lightyswife-opens-up-about-his-suicide/3/)4
(http://rollingout.com/entertainment/delta-
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his-suicide/4/) 5 (http://rollingout.com/music/chris-lightys-wife-
http://rollingout.eom/music/chris-lightys-wife-opens-up-about-his-suicide/2/
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ENTERTAINMENT (HTTP://ROLLINGOUT.COM/CATEGORY/ENTERTAINMENT/)
See as Holograms
APR 27,2012 7:24 AM
http://rollingout.eom/entertainment/dead-musicians-fans-most-want-to-see-as-holograms/2/
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EXHIBIT 3