Case 2:15-cv-03462-RGK-AGR Document 119 Filed 03/07/16 Page 1 of 4 Page ID #:2519

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Francis Malofiy, Esq.

Francis Alexander, LLC
280 N. Providence Rd. I Suite 105
Media, P A 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: (31 0) 557-9200; F: (31 0) 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

the RANDY CRAIG WOLFE TRUST,

Hon. R. Gary Klausner

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Plaintiff,
v.

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LED ZEPPELIN; JAMES PATRICK

PAGE; ROBERT ANTHONY PLANT;
2I JOHN PAUL JONES; SUPER HYPE
PUBLISHING, INC.; WARNER MUSIC
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GROUP CORP., Parent of
23 WARNER/CHAPPELL MUSIC, INC.;
24 ATLANTIC RECORDING
CORPORATION; RHINO
25 ENTERTAINMENT COMPANY,
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Case No. 15-cv-03462 RGK (AGRx)

DECLARATION OF PAUL
FRANKLIN IN OPPOSITION TO
DEFENDANTS' MOTION FOR
SUMMARY JUDGMENT OR IN
THE ALTERNATIVE, PARTIAL
SUMMARY JUDGMENT
Date:
Time:
Room:

March 28, 2016

9:00 a.m.
850

Defendants.

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Case No. 15-cv-03462 RGK (AGRx)

DECLARATION OF PAUL FRANKLIN IN OPPOSITION TO

DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

Case 2:15-cv-03462-RGK-AGR Document 119 Filed 03/07/16 Page 2 of 4 Page ID #:2520

DECLARATION OF PAUL FRANKLIN

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I, Paul Franklin, declare as follows:

I.

I was Randy Craig Wolfe's (aka Randy California) dearest friend from

childhood until he died in 1997. We met in junior high school in September of

1965. I have personal knowledge of the facts stated within this declaration. I could

and would testify competently to the facts contained in this declaration.

2.

Randy and I would talk about all things friends would talk about,

including his personal life, his music life, his financial difficulties, and things that

he was excited about, and things that concerned him or made him upset. He was

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very open with me given our long history of being close and best of friends from

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childhood

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3.

Randy wrote the song Taurus in 1966.

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4.

I went to many of Randy and Spirit's early concerts in the early years

lie.

wP.Sif

c.tJNFIPitttr

~Melf161({.

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(1966-71) and most of them that were in the Los Angeles, California area. Taurus

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was played at many of these concerts as it was a staple song of theirs in 1967 and

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1968 especially. I have an independent recollection that they played the song

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Taurus regularly at the Ashgrove in Los Angeles and other venues. The Ashgrove

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was a club where they had a regular gig.'.$-'

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5.

A ;M tjoNS T

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\A..I. rr
6l.t )' W t!)(!> 0

!ffN~J~tJ..~JJtcA-.

~ ....~,..

Sta11ing in the early 1970s, Randy expressed to me that he was deeply

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upset that Led Zeppelin had lifted his musical composition Taurus without giving

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him any credit.

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He expressed this to me on numerous occasions in the 1970s,

t.O /-1111 jJ V11Ef? tJv.S
1980s, 1990s, and up unti 1 the time of his death. -::z::. -r f>
~ e.,.~y t($A
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6.
When Randy first shared this thought with me he said he was very
"~didn't

even say thank you." Randy told me, "It was rude, Led
fit
Zeppelin were fans and friends of Spirit, and they were in the front row of some of
upset that

.::rtllhf PA

our shows in the UK. And we would even comp them tickets." Randy told me that
members of Led Zeppelin and Spirit were friends and would hang out together.

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Case No. 15-cv-03462 RGK (AGRx)

ft

DECLARATION OF PAUL FRANKLIN IN OPPOSITION TO

DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

Case 2:15-cv-03462-RGK-AGR Document 119 Filed 03/07/16 Page 3 of 4 Page ID #:2521

7.

In

the

early

1970s,

when

Randy

was

first

expressmg

his

disappointment over what Led Zeppelin had done, I asked him what he was going

to do about it. Randy told me in response that he was hurt and was going to

confront Jimmy Page the next time he saw him_;

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rl N fi L/, y,

Out of curiosity, some time later, I asked Randy if he had ever

followed up with Jimmy Page. He responded that he didn't want to talk about it.

He said he was too hurt and upset to talk about what had happened. I would

estimate that this conversation took place in the mid-1970s. I know this because it

occurred before I was married (in )he late 1970s ), and after he initially shared his

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J .,t)EPR ~~s1cr

disappointment wttn me in the early 1970s.

'TO

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OtJ~IDe.P

A short time later Randy finally 6peHe6 trP' to me about his interaction

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with Jimmy Page. Randy told me he confronted Jimmy Page at an after-event

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following a Spirit concert in the United Kingdom. Randy said that the interaction

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had really disturbed him because when he tried to speak with Page about it, Page

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admitted that he lifted Taurus for Stairway but threatened him and said that he

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would get 20 lawyers for every lawyer Randy might be able to hire. Randy said that

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Page also told him Led Zeppelin would not give him a dime or any credit. From

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Randy's expression it was clearly a very unsettling conversation, ~~ ~~:;~

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Executed this 61h day of March, 2016 at Los /IN,~t6tmty, California.

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7/IA-r

~.- e~

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

~1

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Case No. 15-cv-03462 RGK (AGRx)

DECLARATION OF PAUL FRANKLIN IN OPPOSITION TO

DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

P
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Case 2:15-cv-03462-RGK-AGR
Document 119 Filed 03/07/16 Page 4 of 4 Page ID #:2522
GARY T. KUBOTA

ltonolulu
Star-::6ulletin
I I H PUI

~-)I

f Jl

PAHAI Jl:.il

Mau1 Corr8spondcnl

132 North Chtm:h St

Watluku, Hawan 9Ei/G:3
Phone: 808 2443207
fC ax 808 244 3207

http://starbulleftn.corn

Pager 808 576 6480

Randy California of 'Spirit'

believed drowned off Molokai
BY GARY

T. KUBOTA

Maui correspondent

WAILUKU- Friends and music fans are mourning the apparent drowning off Molokai of rock
guitarist and lyricist Randy California, known for composing the
songs "Nature's Way" and "I Got
A Line On You."
California, 45, whose birth
name was Randy Wolfe, the lead
guitarist for Spirit, was swept
away by a strong current after
rescuing his 12-year-old son
Quinn at Papohoku Beach Thursday afternoon.
Maui rescue workers searched
by land and a1r Thursday night
and resumed their search yesterday until 12:24 p.m., when the
weather turned bad and made
visibility difficult.
"The clouds were pretty low,"
said Fire Capt. Frank Tam.
Tam said father and son were
swimming when the waves rose.
"He (California) was able to
push his son into shore to catch a
wave,'' Tam said.
He said there were conflicting
reports whether California was
last seen swimming or was face
down in the ocean.
California. who was visiting his
mother, Bernice Pearl, on MIJI<>

kai, had been scheduled to join

Spirit to begin a five-nation European concert tour today to promote its new recording "California Blues."
His boyhood friend Paul
Franklin said California, who
lived on Molokai in the 1970s, was
a "fabulous swimmer.~
"This guy was in perfect shape,
never drank, never did drugs,"
said l''ranklin, who initially
planned to go to Molokai with
California.
Hollywood Reporter music editor Jeffrey Jolson-Colburn said
California was an influential
song writer and described Spirit
as progressive in the early 1970s
when they mixed the use of
guitars with synthesizers.
"He influenced groups from
Genesis to Depeche Mode to No
Doubt," he said.
Colson said Spirit was playing
to sell-out crowds in mediumsized halls and had re-released a
collection of songs.
Franklin said California got his
stage name at age 15 while playing with rock star Jimi Hendrix.
Hendrix was working with a couple of Randys in the band.
"Jimi called him Randy California and the name stuck ever
since," l<'ranklin said.

PAUL FRANKLIN
2235 COMPOTE CIRCLE
PALMDALE,CA 93551

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