Professional Documents
Culture Documents
I 1
A " ) Y
P1aintitt,
VS.
PACIFIC PICTURES CORPORATION,
[P WORLDWIDE, LLC, IPW, LLC,
MARC TOBEROFF, an individual,
MARK WARREN PEARY, as
personal representative of
the ESTATE OF JOSEPH SHUSTER,
JEAN ADELE PEAVY, an
individual, JOANNE SIEGEL,
an individual, LAURA SIEGEL
LARSON, an individual, and
DOES 1-10, inclusive,
Defendants.
DEPOSITION OF:
LAURA SIEGEL LARSON
FRIDAY, JULY 22, 2011
9:45 A.M.
Reported by:
Kathleen E. McCarthy
CSR No. 4483
Case No.
CV-I0-3633 ODW (127,x)
Merrill Corporation
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LAURA SIEGM, DAWION /22/".J
['due 22
documents?
2 A. Yes.
Q-
How do you know that?
A. My mother told me.
5
Q.
Do you know how much he charged?
10 A. Correct.
11 Q. Joanne Siegel.
12 A. Us as the Siegels.
15 with that.
18 when "you" does not refer to her and her mother and
3 BY MR. PETROCELLI:
Q. So afterhe litigation document that you and
9 A. I don't recall.
10
Q. You signed a document sometime in or about
12 correct?
13 A. Yes.
14
Q. And Mr. Toberoff also signed that; correct?
15 A. Yes.
17 that document?
18 A. Yes.
20 you,signed it?
21 A. Yes.
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LAURA :;11,(;EL LARON - 1/22/2011
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1L?
2 A. Yes.
Q. Was he here in town with you or
4 A. No,
6 A. Yes,
7 Q.
Has he Lived in Florida the whole time you've
9 A. Yes.
10
Q. Okay. Did any other attorney besides
11
Mr. Zadrozny review that document, to your knowledge,
14 Q.
This 2008 -- we've been calling it a consent
15 agreement.
17
Q. How many documents have you or your mother
19 Shuster people?
20 A. Only one.
21
Q.
Was the 2008 consent agreement the last
22
document you asked or your mother asked, to your
23
knowledge, Mr. Zadrozny to review related to Superman?
24 A. I believe so.
25 Q.
Have you signed any other documents related
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Merrill Corporation
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LAURA S1EGEL LARSON - 1/22/2011
Mge 25
to Superman after the 2008 consent agreement that you
signed together with the Shusters and Mr. Toberoff and
3 your mother?
4 A. L don't remember any other document.
5 Q. How did you obtain a copy -- withdrawn.
6 Did you or your mother send the draft uf the
7 2008 consent agreement to Mr. Zadrozny, or did someone
8 else send it on your behalf?
9 A. I believe my mother sent it.
10 Q. And do you know how Long before your signing
11 it your mother sent it to him?
12 A. I don't know. I would be guessing, but, you
13 know --
14 MR. TOBEROFF: Don't guess.
15 THE WITNESS: You know.
16 BY MR. PETROCELLI:
17
Q.
On the subject of guessing, your lawyer said
18 don't guess, and I concur with that except that you
19 need to understand that there's a wild guess, which we
20 don't want to know about. Wild speculation we don't
21 want to know about. But if you have some basis to
22 estimate something or approximate something based on
23 your overall knowledge, we are entitled to that, just
24 so you keep that in mind. Okay?
25 A. Um-hum. Yes. You pointed --
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Merrill Corporation - Los Angeles
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LAURA SLEGEL LARSON - //22/2011
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MR. PETROCELLI: And to he cLear, with
9 certain questions
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LAURA SLEGSL LARSON - 1/22/2011
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that her answer is not a waiver of any privilege.
MR. TOBEROFF: She already answered that
3 question. She said no.
/1 MR. PETROCELLI: Not with respect to
5 Superman. She did with respect to Superboy.
6 MR. TOBEROFF: I thought you said --
7 MR. PETROCELLI: Did I misspeak?
8 THE WITNESS: I kind of lost track for a
9 minute.
10 MR. PETROCELLI: Let me put it again for the
11 record, then.
12 MR. TOBEROFF: As to that question, we are
13 asserting privilege, and I'm instructing her not to
14 answer.
15 MR. PETROCELLI: Okay. So even though I
16 would agree that the answer would not affect the
17 waiver.
18 MR, TOBEROFF: Yes,
19 MR. PETROCELLI: Okay,
20 Q. And does the -- did you discuss with your
21 mother at any time whether or not to enter into an
22 agreement with the Shusters regarding the sharing of
23 recoveries or proceeds from Superman?
24 A. I believe we talked about it.
25 Q. Can you relate that discussion to me?
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Merrill Corporation
Los Angeles
800-826-0277
www.merillcorp.com/law
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LAURA S1EGEL [ARSON - //22/2011
Page 45
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MR, TOBEROFF: T instruct you not to answer
2 based on the attorney-client privilege, joint client
3 privilege.
4 BY MR. PETROCELLI:
5 Q. And these were conversations just between
6 your mother and you; is that correct?
7 A. Yes.
8 Excuse me. May I take a bathroom break for a
9 moment?
10 MR. PETROCELLI: Sure. Let's stop right now.
11 THE VIDEOGRAPHER: Off the record. The time
12 is 10:32.
(A recess was taken.)
THE VIDEOGRAPHER: We're back on the record
15 at 10:46.
16 BY MR. PETROCELLI:
17 Q. I just want to follow up a bit on that last
18 area that we covered about the consent agreements and
19 the arrangements with the Shusters. Does -- do the
20 consent agreements -- I may have asked you this
21 already, but let me ask you again. Do the consent
22 agreement documents -- does the consent agreement
23 document make any reference at all to Superboy?
24 A. You did ask me that.
25 MR. TOBEROFF: Asked and answered. And I
13
14
Merrill Corporation - Los Angeles
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LAI A I;LEGEL LAR;;ON 1/22/20it
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instruct you not to answer.
2 MR. PETROCELLI: It I agree that it's not a
3 waiver, do you continue to instruct on that?
4 MR. TOBEROFF: Yes.
5 MR. PETROCELLI: Okay.
6 Q. Are you currently able to enter into an
7
agreement with DC Comics without the consent of the
8 Shuster side, the Shuster family?
9
10 that.
MR. TOBEROFF: I instruct you not to answer
11
MR, PETROCELLI: Same objection? Privilege?
12
MR. TOBEROFF: Same objection. Privilege.
13 BY MR. PETROCELLI:
14 Q. Have you had any discussions with any member
15
of the Shuster family since 2008 when the both of you
16 signed the consent agreement about the marketing of
17 the Superman rights?
18 A. I can't recall any discussion.
19 Q. Are -- have any efforts been made on your
20
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[.&O R& SIEGEL LARSON - //22/20II
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2 MR. TOBEROFF: So --
3
MR. PETROCELLI: To be clear, Marc, and we're
4
not going to settle this on the record, but I do want
5
to make clear that I disagree that all conversations
7
rendition of legal advice at the very minimum.
8
MR, TOBEROFF: Well, the marketing of her --
9
the subject of a litigation tor the past six now going
12
MR. PETROCELLI: It you meet with Paramount
14
and you then report on the meeting, that's hardly the
16
MR. TOBEROFF: It's totally intertwined with
17
legal advice. Any studio would want to know the state
19
odds on appeal. There's so much going on in this case
21
and which would -- it's just very closely intertwined.
24
Otherwise I would instruct you not to answer.
25
MR. PETROCELLI: It seems like it's
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Merrill Corporation
Los Angeles
800-826-0277
www.merillcorp.com/law
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LAURA SLEGEL LARSON - 1/22/2011
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1 of them, have already been disclosed to us with
2 respect to the Litigation retainer agreement.
A. Oh, okay. Sometimes it gets contusing
4 because we're talking about so many agreements, you
5 know.
6 Q. Okay. So let me see if I can break it down
7 for you.
8 A. All right.
12 is that correct?
13 A. I believe so.
18 Larson?
25 were a trial?
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Merrill Corporation Los Angeles
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LAURA SEEGEL LARS(N - //22/2011
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I A. It it were a trial., yes.
2 Q. Okay. :3o besides that 10 percent to
3 Mr. Toberoff, is there any other percent that would
4 have to be paid to Mr. Toberoff?
5 A. No.
6 Q. Is there any other fee that would have to be
7 paid to Mr. Toberoff?
8 A. No. I can't think of any.
9 O. Any other type of remuneration of any kind
10 thatwould be paid to Mr. Toberoff?
11 A. You know, I think that there were some
12 some costs that were advanced.
13 Q. Besides that.
14 A. Other than costs, no.
15 Q. Okay. Is there anything in the 2008 consent
16 agreement that would trigger additional remuneration
17 to Mr. Toberoff based on a transaction of the Siegel
18 rights?
19 MR, TOBEROFF: I -- I will allow you to
20 answer as to -- because what is not in the agreement
21 would not be privileged. Did I say that right?
22 MR. PETROCELLI: You did.
23 MR. TOBEROFF: Some things not in the
24 agreement we are not asserting privilege. We are
25 asserting privilege to what is in the agreement. So
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to that extent, you can answer the question.
2 THE WITNESS: Well, there's no -- [ can never
3 say the word. What is it? Remuneration? There's
4 no -- you know what I'm talking about. There's no
5 additional percentage.
6 BY MR. PETROCELLI:
7 Q. To Mr. Toberoff.
8 A. To Mr. Toberoff.
9 Q. As a result of anything in the consent
10 agreement.
11 A. Correct,
12 Q. Correct?
13 A. Correct.
14 Q. Okay. And to your knowledge, would there be
15 any percentage -- in addition to the 40 to
16 Mr. Toberoff, would there be any percentage or any fee
17 payable to Ari Emanuel or any of his companies?
18 A. No.
19 Q. So to your knowledge, he would not
20 participate at all in any current transaction.
21 MR. TOBEROFF: Asked and answered.
22 BY MR. PETROCELLI:
23 Q. Is that correct?
24 A. Correct.
25 Q. Out of the 60 percent or other proceeds that
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privileged.
10
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MR. PETROCELLI: -- a host of other
20 credibility issues.
23 clear.
6 testify.
16 position.
25 extent --
LAURA :;1- 1.X;EL LAW.;0N - /M/2011_
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STATE OF CALIFORNIA
2
) ss.
10 2011, at , California.
11
12
13
14
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1 STATE OF CALIFORNIA
2 ss.
17 hereto.
20