UMG Files Section of Deposition Transcript Admitting that Witness Only Asked 3 People About p2p Use in Lindor Case

In "opposition" to Marie Lindor's motion to compel and for discovery sanctions in UMG v. Lindor, the RIAA submitted to the Magistrate a section of the deposition transcript in which UMG's witness, an in-house lawyer at UMG, admitted that the only people she had contacted at UMG in trying to find out about p2p file sharing between UMG and radio stations were 2 lawyers and an officer involved in procurement (Transcript, p. 42, ll. 4-15), and that she never contacted anyone in the radio promotion departments (Transcript, p. 32, ll. 20-23). She further testified that the only question she was purporting to ask was whether p2p file sharing had been used by "the company" or "Universal"(Transcript, p. 32 li. 24-p. 33 li. 7)(Transcript, p. 34 ll. 13-17), as opposed to the question Ms. Lindor's lawyers had asked -- and the Magistrate had ordered them to answer -- whether p2p had been used by the company's employees to send song files to radio stations.

RIAA Response to Ms. Lindor's application:

September 13, 2006, Letter of Richard Gabriel*
Transcript of September 7, 2006, Deposition of JoAn Cho, pages 1-3, 30-43*

Ms. Lindor's application:

September 8, 2006, Letter to Magistrate*
Document Request Number 4*
Response to Document Request Number 4*
Interrogatory Number 5*
Response to Interrogatory Number 5*

* Document published online at Internet Law & Regulation

Table of Cases

Keywords: digital copyright online download upload peer to peer p2p file sharing filesharing music movies indie label freeculture creative commons pop/rock artists riaa independent mp3 cd favorite songs