Opinion
1:21-cv-05411-JPC
06-27-2022
ROC-A-FELLA RECORDS, INC., PLAINTIFF AND COUNTERCLAIM-DEFENDANT, v. DAMON DASH AND GODIGITAL RECORDS, LLC, DEFENDANTS AND COUNTERCLAIM-PLAINTIFFS .
QUINN EMANUEL URQUHART & SULLIVAN, LLP Alex Spiro Natraj S. Bhushan Eric Howard
QUINN EMANUEL URQUHART & SULLIVAN, LLP
Alex Spiro
Natraj S. Bhushan
Eric Howard
JOINT STIPULATION
Plaintiff Roc-A-Fella Records, inc. (“RAF, inc.”) and Defendant Damon Dash (“Dash”) by and through their respective counsel, stipulate as follows:
WHEREAs, RAF, inc. filed a complaint on June 18, 2021, naming Dash as a defendant and seeking a judgment declaring that (a) RAF, inc. owns all the rights to Reasonable Doubt, including its copyright; (b) Dash, as a RAF, inc. shareholder, has no direct ownership interest in Reasonable Doubt; (c) Dash is not permitted to sell any interest in Reasonable Doubt; and (d) Dash must transfer to RAF, inc., any NFT or other asset in his possession, custody, or control reflecting rights to Reasonable Doubt (EcF No. 1 at 11);
WHEREAs, also on June 18, 2021, RAF, inc. moved for a preliminary injunction preventing Dash from “altering in any way, selling, assigning, pledging, encumbering, contracting with regard to, or in any way disposing of any property interest in Reasonable Doubt, including its copyright and including through any means, such as auctioning a non-fungible token (‘NFT') reflecting such interests, pending a final determination of the above- captioned lawsuit” (EcF No. 5 at 1);
WHEREAS, on July 2, 2021, upon stipulation of the parties, the Court ordered that, pending a final resolution of this action, “Dash, all those in active concert with him, and all persons having notice of this Order by personal service or otherwise, be and the same hereby are RESTRAINED AND ENJOINED from altering in any way, selling, assigning, pledging, encumbering, contracting with regard to, or in any way disposing of any property interest in Reasonable Doubt, including its copyright and including through any means, such as auctioning a non-fungible token (‘NFT') reflecting, referring, or directing to such interest” (ECF No. 27 at 2);
WHEREAS, on August 6, 2021, RAF, Inc. filed an Amended Complaint;
WHEREAS, on September 8, 2021, Dash answered the Amended Complaint and asserted Counterclaims against RAF, Inc.;
WHEREAS, as set forth in their Joint Stipulation dated June 13, 2022, the parties hereby seek to resolve any and all claims and causes of action asserted in this case, and therefore, respectfully request that the Court enter the attached [Proposed] Final Judgment;
IT IS THEREFORE STIPULATED AND AGREED that there is good cause for the Court to enter the attached [Proposed] Final Judgment.