Music Download Lawsuit - John Deep v. RIAA, Boies, et al.

D. My Lawyers, Trans World and the Labels and Studios Caused Me Harm

29. Boies, Trans World and the Labels and Studios have damaged me in a variety of ways, including the following:

a. Misappropriating for defendants or defendants’ families millions of dollars in assets that they was not authorized to receive;

b. Wrongfully diverting to others millions of dollars in cash and stock, used to induce their cooperation or buy their silence;

c. Failing to provide faithful and competent services that were the consideration for Boies’s authorized compensation;

d. Inducing other lawyers and agents to fail to provide the faithful and competent services they were obligated to provide to me; and

e. Damaging my reputation and relationships with investors, employees, lenders, customers and suppliers, public authorities and the public generally.

30. The total amount of damages proximately caused by defendants’ misconduct is not yet known, but as set forth herein defendants’ conduct caused Boies, his agents, Trans World or the Labels and Studios to be enriched, or me to be harmed, in at least the following amounts:

a.In re CD MAP Antitrust Litigation – In excess of $1,000,000,000: the valuation of the market share I lost to iTunes, MusicNet and Movie Link when a settlement or release of my claims was concealed from me, as a result of Boies’s fraud upon the court and the inducement of or conspiracy in Boies’s fraud by Trans World and the Labels and Studios.

b. AOL v. John Deep – $10,000,000: the value of the trademark Aimster and the domain name aimster.com, which were both acquired by Boies’s Co-Conspirators on Dec. 14,2001, as a result of Boies’s fraud upon the court and the inducement of or conspiracy in Boies’s fraud by Trans World and the Labels and Studios.

c. In re Aimster Copyright Litigation – $10,000,000: value of LSAG cash flows fraudulently paid by Boies in November 2000 to induce Duker to misappropriate my Aimster assets;

$10,000,000: net present value of $700,000 per year in existing cash flow I lost when an injunction was entered on October 30, 2002 that shut down my business as a result of Boies’s fraud upon the court and the inducement of or conspiracy in Boies’s fraud by Trans World and the Labels and Studios.

In excess of $1,000,000,000: the valuation of the market share I lost to iTunes, MusicNet and Movie Link when an injunction was entered October 30, 2002 that shut down my business as a result of Boies’s fraud upon the court and the inducement of or conspiracy in Boies’s fraud by Trans World and the Labels and Studios.

d. USA v. PRSI – Unknown – unauthorized use of my assets to set up sham transactions involving shell or fabricated corporations, including “Pi2 Inc.,” “Pi3 Inc.,” “Pi2 Products LLC,” “IDVC” “PRSI” and “BackSpin.”

e. Tyco and Adelphia litigations – Unknown – unauthorized use of my assets to set up sham transactions involving shell or fabricated corporations, including “Pi2 Inc.,” “Pi3 Inc.,” “Pi2 Products LLC,” “IDVC” and “Amici LLC.”

$10,000,000 – litigation support fees paid to Amici LLC by Boies clients Tyco and Adelphia for unauthorized use of my assets, beginning in October 2002;

‹ C. My Lawyers Fraudulently Concealed the MisconductupParties, Jurisdiction and Venue ›