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UNITED
STATES DISTRICT COURT
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SUMMARY OF ALLEGATIONS JURY TRIAL REQUESTED BACKGROUND 1. Aisha Goodison, hereinafter “Aisha,” “Aisha Goodison,” “Plaintiff” or “the Plaintiff”, and at all times material hereto, is a resident of Miami, Florida. Aisha is a singer/writer/producer/director and owner of the independent film, record and literary company Sonustar. 2. Aisha is an innovative, cutting edge, multi-talented artist with a God given voice that covers several octaves, performing styles of music from Gospel to R&B, Rap to Rock and Jazz to Opera on her eponymous self-titled debut album. This feat was a music industry first. Aisha is also a multi-instrumentalist. 3. Her debut single "Contemporary Girl" has an original and rap remix version, where she performs in several styles of music on both versions of the song - another industry first. She also produces, engineers and masters her own music as featured on her debut album “Aisha” and on "Aisha The Remixes" - another industry first. Aisha wrote and directed her debut music videos. She is also an excellent cinematographer, photographer and editor. 4. Aisha was a child prodigy with an extraordinary God given gift for writing and music comprehension. She began writing poems at age 4, music video treatments (scripts) at age 14, songs at age 15 and movie scripts at age 16. She has a high IQ with a great aptitude for problem solving and analysis. She is a brilliant orator with a great gift for gab. 5. Aisha is the owner of a very valuable, wholly owned, multi-million dollar valued copyrighted catalog containing over 6,000 songs, 2 dozen scripts, 4 dozen film synopsises, 11 book manuscripts, 4 dozen music video treatments and 3 dozen photo treatments. Aisha has been actively authoring this catalogue since childhood. It has become very valuable and grown tremendously in content, as she has eschewed partying in favor of writing literary, music and film works, which she has spent 2/3 of her 28 years authoring. 6. This very valuable literary catalog has been copyrighted for years with additional material continually being sent to the copyright office. United Nations Law, Jamaican Law and United States Federal Copyright Law protect said catalog. Aisha holds dual citizenship in both countries, as she was born in Jamaica and raised in Miami, Florida from the time she was a little girl. 7. Aisha is known to people all over the world, as attested by her 6.2 million and counting web site hits from countries like America, Jamaica, England, France, Spain, Ireland, Italy, Israel, Sweden, Germany, Australia, New Zealand, Hungary, Iraq, Belgium, Switzerland, The Netherlands, Brazil, Portugal, Canada, Japan, China, Russia and many other countries. 8. Her web site patrons include fans, MTV/Viacom, renown book publishing companies in New York, Eaton College in England, numerous universities in America and Europe, government agencies from around the world, numerous international stars, over three dozen international newspapers and magazines, music managers, record labels, several international law firms and geological institutes, who frequent her site to listen to her music, read her innovative writings and commentary in her Sound Off Column, which features a variety of topics. She is listed in many worldwide music and writer directories, which offer biographical information on her and links to her web site. 9. Aisha is a very upright character that leads a relatively quiet life in Miami. Many will attest to this under oath and that of her great character and charitable acts. She has no criminal record or history of questionable behavior. She eschews alcohol and drugs in accordance with her faith, Christianity. She has devoted her life to authoring Judeo-Christian inspired music and scripts in tribute to her Faith. FAMILY BACKGROUND10. Aisha hails from a renowned and very accomplished arts family. Her family is Jamaica’s celebrated, premier arts family. Her father, Vaughn, is a Justice of the Peace (a British Commonwealth Magistrate) and holds an Order of Distinction, the Commonwealth equivalent of a British OBE. He is also a multiple award winning radio disc jockey, internationally renowned musicologist, who has been featured in numerous documentaries on music. Journalists travel far and wide from places like America, Britain, France and Germany to interview him due to his vast knowledge of music - from mainstream artists to lesser-known artists that many people don’t know a lot about. 11. He is one of the most sought after musicologists in the world; having done numerous print and television interviews for many years with respected publications and news outlets in America, Europe and the Caribbean. His vast knowledge of music is widely known and referred to in and by numerous international periodicals, entertainment industry organizations and entertainers. His expertise has been used to settle copyright infringement music cases in Britain and the Caribbean. He is also a former international soccer player and one of the youngest to every play worldwide for a national team. 12. Aisha’s aunts are also writers. Her aunt, the Right Honourable Barbara Gloudon, is a well known, loved and respected professor, award winning radio personality, humorist, international playwright and head of the United Nation’s UNESCO branch in Jamaica. She frequently lectures in America, France and the Caribbean. She heads the Little Theatre and has written and produced plays that have been viewed worldwide. When out in Jamaica, America and Paris, she is often approached by fans of her work that congratulate her on her success. 13. Her aunt, Professor Lorna Goodison is one of the most famous, well written about and accomplished poets in the world. The award winning Poet Laureate is author of several critically acclaimed books available in bookstores all over the world. She has penned the successful, critically acclaimed books “Controlling The Silver (Illinois Poetry Series),” “Fool-Fool Rose is Leaving Labour-in-Vain Savannah,” “Selected Poems by Lorna Goodison,” “Turn Thanks,” “Guinea Woman,” “I Am Becoming My Mother,” “To Us, All Flowers Are Roses (Illinois Poetry),” “Kingston: A Cultural and Literary History,” “Baby Mother and the King of Swords,” “Cities of the Imagination” by Lorna Goodison (Foreword) David Howard, “Heartease” and “Tamarind Season.” 14. Her works and life are written about in the books “Contemporary Authors: Biography - Goodison, Lorna,” "Identity in the Poetry of Grace Nichols and Lorna Goodison (Salzburg Studies in English Literature)” by Gudrun Webhofer and “Lorna Goodison. Guinea Woman: New and Selected Poems” (World Literature Today) by Jim Hannan. 15. She is the recipient of dozens of international literary awards including a gold star from the highly esteemed Booklist magazine. Nobel Prize recipient Derek Walcott praised her books. Her works were also compiled with Maya Angelou’s in the book “Quartet of Stories” by Maya Angelou, et al. She maintains a professorship in the United States and Canada at two prestigious universities. 16. Several of Aisha’s cousins are also writers. One is an associate producer for a world famous American investigative journalism news program that airs weekly on one of the 4 major networks. The other is a journalist for a well-known newspaper. CAUSE OF ACTION17. As illustrated in the preceding paragraphs, writing is a tradition in the Goodison family and has been for over 120 years, as Aisha’s grandmother was also a lyricist. The Goodison family has excelled in the literature and entertainment worlds and are Jamaica’s definitive arts family - a tradition Aisha has prolifically continued via her released works and private unreleased copyrighted catalog mentioned above. 18. However, that 120 year tradition is being perversely and criminally disrupted and destroyed by the dishonorable, disgraceful, nefarious Madonna (Madonna aka Madonna Ciccone aka Madonna Ritchie). The infringements began with Madonna willfully stealing Aisha’s original, wholly authored, copyrighted music, lyrics, pictures, Sound Off Column articles and unique features from Aisha’s widely read web site that has been viewed millions of times by internet users all over the world, who began bombarding Aisha with emails and queries asking if she’d notice how Madonna was stealing her work for her own projects. 19. Defendant Madonna has publicly admitted to getting ideas from the internet, which is where a lot of Aisha's released work has been located since 2001 with Madonna stealing Aisha’s work from her site in 2003 for her ill received, critically panned “American Life” CD. This telling admission was made on the British television program Blue Peter SEE EXHIBIT 2. Madonna has been sued and slammed numerous times by several international artists for this very same misconduct in deliberately stealing their copyrighted works and morphing into them for her so called reinventions, a violation of the Right to Privacy and the Right to Publicity. 20. However, what started with Madonna flagrantly stealing Aisha’s copyrighted music, lyrics, pictures, Sound Off Column articles and unique features in clear view of Aisha’s site visitors, criminally progressed to something far worse and far more sinister - invasion of privacy, illegal surveillance, wiretapping, hacking, corporate theft, fraud, harassment, assault and stalking, commissioned by Madonna to steal Aisha’s multi-million dollar copyrighted literary catalog referred to above, that she Madonna, has been criminally using and selling off items from to partners, coworkers, collaborators and colleagues at Disney, Warner Bros and using at her own Maverick Records and Films, in boldface, arrogant, mocking, brazen violations of numerous Jamaican, United States and United Nations laws, punishable by several years in prison per count. Preliminary diagnostic counter-surveillance tests on Aisha’s home revealed criminal wiretapping and unusually high levels of RF, which are indicative of the unlawful filming and recording of an unwitting victim of illegal, invasive surveillance. Furthermore, Aisha has been the victim of textbook examples of harassment techniques used by privacy invaders trying to shake potential litigation and criminal charges for their illegal conduct, as listed in detail further in this Complaint. 21. When Aisha publicly wrote on her widely read site that she was going to sue Madonna for constantly stealing her released work, this criminal wave of harassment and invasion of privacy ensued that matches a similar pattern her attorney, Defendant Bertram Fields and his private investigator, Anthony Pellicano have been publicly accused of by both famous and non-famous entertainment industry professionals, as detailed further in this Complaint. 22. This criminal campaign of harassment commissioned by Madonna progressed to the assault of the young singer this summer in Miami on the same street as the District Court House in downtown, where Aisha was headed for an early morning meeting. This assault was commissioned by Madonna to discourage Aisha from going to the police when she realized the young singer figured out she had her under illegal surveillance and to dissuade her from taking legal action against her, the often sued Madonna, for criminally stealing her work and criminally invading her privacy. Madonna was hit with a slew of lawsuits over the last few months for her gross, unlawful, nefarious misconduct and fraud regarding several unrelated people and companies. 23. Over the summer, each time Aisha got near a court house in Miami, she was approached and harassed by people clearly affiliated with Madonna, who would come up to her angry and repeat verbatim to her, things she’d said over the phone and in the privacy of her own home. 24. It must be noted, Madonna’s lawyer, the notorious Bert Fields, has been at the center of an FBI probe for his private investigator criminally wiretapping the phones of and harassing his celebrity clients legal opponents. His celebrity clients who have been publicly accused of invasion of privacy are Kabbalahist Michael Jackson, Scientologist Tom Cruise, The Church Of Scientology, The Kaballah Center and now Kabbalah Center front woman Madonna. 25. The nefarious Madonna, like the people who she commissioned to harass then later assault Aisha near the District Court House in downtown Miami, has been repeating verbatim in her public interviews on TV and in print things Aisha had said over the phone to friends, family and business associates, attributing it to herself as a sick form of harassment. According to security experts, this is a harassment technique commonly used by wiretappers to upset, scare and discourage potential legal opponents and enemies. 26. Furthermore, the method of assault commissioned and utilized against Aisha is one favored by Madonna - choking, which she, Madonna, has done to two people and was sued for the last time she committed this vile act of assault against a pre-teen boy named Keith Sorrantino, as mentioned further in this Complaint (SEE EXHIBIT 9). It was reported Madonna quietly settled the lawsuit out of court for $600,000 to avoid the horrible publicity that would ensue for deliberately choking and “beating up” a child, who simply “wanted her autograph” on “her day off” when she couldn’t be bothered to sign it. This coupled with her other unlawful behavior regarding this case illustrates the fact that she is a danger to society. What kind of human being does such things to another person, let alone a child. 27. Other public figures who have publicly complained, went to the FBI and or were approached by the FBI for investigative interviews because of wiretapping, harassment and or death threats by either Madonna’s lawyer Bertram Fields or his celebrity clients listed above are Court TV’s Diane Diamond, actor Sylvester Stallone and comedian/actor/talk show host Gary Shandling, several notable journalists such as Anita Busch of the L.A. Times and several entertainment industry lawyers. This has been widely written about and well established in many publications (SEE EXHIBITS 11 AND 12). Defendant Bertram “Bert” Fields retained criminal attorney Donald Re on November 1, 2003, to defend him in the currently ongoing FBI criminal probe. 28. Illegal wiretapping and harassment is an old dirty secret among a small set in Hollywood, which has been exposed in recent years due to the above-mentioned FBI probe and formal complaints by entertainment industry professionals and celebrities who unknowingly became the victims of invasion of privacy, which is a crime under U.S. and United Nations laws, punishable by several years in prison. 29. After stealing Aisha’s music, literary and photographic works from her widely read web site in clear view of Aisha’s audience who wrote to the young singer about it, Madonna then upped the ante and deliberately engaged in a pattern of willful theft of Aisha’s multi-million dollar valued copyrighted literary catalog that is housed in the Library of Congress and on her personal computers, in acts that spit in the face of the Goodison family, the U.S. Federal Government, Congress, The Government of Jamaica and the United Nations, due to the sheer number of laws that have been broken in each country by Madonna and her co-defendants in their quest to criminally use Aisha’s vast copyrighted works, invade her privacy and then terrorize and assault her into not going to the police and suing them. 30. This has been a criminal campaign spearheaded by Madonna that has already grossed the Defendants close to $500,000,000 in ill gotten profits, which is absolutely disgraceful and one of the worst acts of criminal corporate theft in entertainment history. 31. There is a mountain of evidence that clearly illustrates beyond any shadow of a doubt that Madonna has criminally and perversely been targeting, stealing from, harassing, terrorizing and stalking Aisha, in ways that crossed from severe breaches of civil law in plain view of scores of people who read Aisha’s web site regularly and alerted her to the fact that Madonna was stealing her copyrighted music, pictures and articles and progressed to severe breaches of criminal law in a sick, greedy, nefarious campaign commissioned by Madonna to steal a multi-million dollar copyrighted Federally protected catalog and terrorize the young singer into not pressing charges. 32. The fact of the matter is people who visit Aisha’s site on a regular basis witnessed Madonna rip off Aisha’s work in 2003 that Aisha had already copyrighted and released two years before in 2001. Madonna has been accused of and sued for this very same pattern of theft numerous times by international copyright holding artists. 33. And due to the fact that for the last 20 years, the span of her career, a Madonna project is usually an overblown spectacle with little or no substance that requires much staff and industry artists to put it together, many people were commissioned in criminally stealing and using Aisha’s works and most of them knowingly so. 34. Further causing additional offense and problems is that Madonna criminally began using for herself and selling off to her partners Aisha’s copyrighted scripts, songs, photo treatments and book manuscripts - works that Madonna does not and never has owned, but gained via a criminally obtained copy of Aisha’s already copyrighted catalog via hacking. 35. Who is she to criminally procure Federally and Internationally protected copyrighted works of such great monetary value and use and sell several of them off for millions of dollars in ill-gotten profits. This was a vile, despicable, offensive, criminal, greedy act punishable by several years in prison. 36. Aisha is being robbed, defrauded, exploited and criminally harassed and assaulted at every turn in despicable behavior by the Defendants that break U.S., Jamaican, British and international United Nations laws. 37. This criminal conduct must cease immediately. It is disgraceful, abhorrent, nefarious and unbecoming. However, it provides a glaringly accurate portrait of what certain pockets of the entertainment industry has become - laden with criminals who have no qualms about breaking not only civil law, but criminal as well. They believe that because they are famous and on television it gives them the right to steal from and assault people at will. They conduct themselves as though they are above the law and as though it does not apply to them. 38. Defendants Madonna, Disney, Madonna’s employers Warner Bros/Time Warner AOL and their affiliates have engaged in an willful ongoing pattern of illegal acts against Aisha, including but not limited to copyright infringement, plagiarism, corporate theft, grand larceny, wiretapping, invasion of privacy, harassment, assault, fraud, terrorization, terroristic threats, career sabotage, blacklisting, tortuous interference and malice in illegal attempts to steal Aisha's multi-million dollar copyrighted catalog mentioned previously in this Complaint, which they have been criminally using. Aisha's very valuable, prolific copyrighted multi-million dollar catalog has made her a target for the vulture-esque Madonna, her employers Warner Bros/Time Warner, her affiliates Gary Marshall, Jerry Bruckheimer and Disney, all of whom she has very clear, well established business ties to. 39. Madonna is a frequently sued, known intellectual property thief who is terribly driven by greed. She is a kleptomaniac who has bragged about stealing money from employers and other music artists. Her entire career has been based on stolen works. Her biggest projects and works such as Like A Virgin, Vogue, Justify My Love, Frozen, Deeper, Bad Girls, Human Nature, Ray Of Light (Music video), Hollywood (music video) and Swept Away (movie) were on the receiving end of copyright infringement and plagiarism lawsuits or credible public allegations of the same from scores of artists and writers. 40. She is known in the industry by lawyers and critics alike for this appalling thievery. She has also been exposed as someone who signs her name to other artists works, collecting their royalties (money) that she did not write or her contribution to was “changing one line” of an already completed song, then taking huge credit in front of the mainstream public for these pathetic acts of plagiarism and posing. 41. Due to Madonna’s criminal conduct, which escalated to commissioned invasion of privacy, harassment and assault, Aisha is now concerned for the safety of her family, as the Defendants conduct towards her has grown worse, culminating in acts that violated her civil rights, copyrights and personal safety, as detailed further in this Complaint. Furthermore, her aunts have numerous copyrighted works, some of which are partly owned by renowned Universities and publishing houses that Aisha is concerned the depraved and greedy Madonna will seek to infringe in her unlawful, criminal copyright infringement spree, as outlined in detail further in this Complaint. 42. Madonna's conduct towards Aisha has grown increasingly obsessive depraved and out of control. Madonna's stalker-like behavior towards Aisha has gone too far, venturing into very disturbing territory. In investigating this case, Aisha has logged on to internet sites and was creeped out when she saw pictures of Madonna wearing the same clothes, earrings, shoes and hairstyles that she, Aisha, had worn around Miami previously on different occasions (more proof that Madonna has her under surveillance, some of which is criminal). Aisha was wearing her hair in a shade of red for a time this year with a trademark matching red lipstick, only to see Madonna dye her hair the same shade of red and wear the same shade of bold red lipstick in the last couple weeks - and also styling her hair the same way. Aisha has since changed her hair in the last two weeks back to a shade of blonde. 43. Madonna has been accused of this disturbing, mimicking conduct before by other artists like Nashville Pussy and Courtney Love, who publicly accused her of dressing like them and stealing their respective looks SEE EXHIBITS 17 AND 18. Madonna was also publicly accused by the well-respected industry music compilation and biographical information company Muze of stealing the looks and video imagery of transvestite German singer Peaches for her own photos and videos that she took to the mainstream and fraudulently claimed as her own, furthering this myth about her that she in the queen of reinvention when she is in fact the queen of stealing. 44. She constantly steals other people’s looks and music for her reinventions that she takes full credit for in the mainstream, all while violating other artists Copyrights, Rights to Publicity and Rights to Privacy. The mainstream press, mostly owned by her label Warner Bros (Warner owns Conde Naste, who owns most of the major magazines and newspapers the mainstream public reads), then labels her creative in self-aggrandizing, PR fueled, pre-arranged publicity spots masquerading as articles, when in actuality she is sickly and creepily dressing and styling her hair like other indie music artists and illegally using their copyrighted music, because she feels they are lesser known, therefore her large mainstream audience won’t know she’s stealing other people’s images and music for her reinventions. 45. However, some industry professionals have caught on to what she has been doing and have written about and condemned this habit Madonna has engaged in for many years at lesser-known artists’ expense. There are lawsuits and credible dated before and after material that completely support this claim about Madonna. 46. One of Aisha's friends is also a friend of Madonna's former secretary. Aisha's friend told her that the secretary complained that this type of mimicking conduct is something Madonna has done to others including herself. The secretary said that she came into work with a new hairstyle and Madonna complimented her on the new look - then eerily came into the office the very next day with the exact same hairstyle as well. 47. Madonna has taken a sick, obsessive likening to publicly quoting verbatim things Aisha writes in her widely read entertainment industry column “Sound Off” days after Aisha publishes them online and copyrights them - proving Aisha wrote it before Madonna mimicking quotes it like a demented parrot. 48. Madonna disgracefully made Aisha into a default speechwriter through this unethical, plagiaristic practice, which is also a violation Aisha’s copyrights’ Right of Attribution (a form of copyright infringement). Later, it progressed to something that is once again far more sinister and disturbing, when Madonna began a sick practice of repeating verbatim in her, Madonna’s public interviews, things Aisha had said over the phone in confidence to friends, family and business associates. Even more disturbingly, Madonna has been publicly repeating verbatim things Aisha said in the privacy of her own home, which raises many questions. 49. Things Aisha said over the telephone have also been printed in the Sun Newspaper verbatim by Madonna’s nefarious, vile, publicly announced email pal Victoria Newton, whom she gives many exclusives in said trash tabloid newspaper. 50. Security experts describe the printing of information a wiretapped victim said over the phone as a form of pre-litigation harassment and corporate theft. Newton and the Sun further printed copyrighted items from Aisha’s private, unreleased copyrighted multi-million dollar catalog in the Sun Newspaper under various sections attributed to Victoria Newton, Nikki Waterman and to Life, News and Sports section writers. These are acts of corporate theft, invasion of privacy, criminal copyright infringement and fraud. STALKING 51. Further evidence that Madonna has Aisha under surveillance in acts that are criminal violations of the respective Jamaican, British and U.S. constitutions and United Nations laws happened this month. On September 12th, 2005 Aisha flew to London to begin filming for two music videos and other works. She immediately began filming with a professional broadcast quality hand held movie camera. She went around London filming known landmarks, red double decker buses and tube stations. She filmed many Londoners cinema verite style and the smiled for the camera when they saw her. Some of them recognized her from her web site. She went around with her camera hidden in a bag, then filmed different locations spontaneously to capture people’s reactions. 52. The very next day Madonna made an official public announcement through her manager that her new video was to be of London landmarks, red double decker buses, tube stations and hidden cameras where they would capture the surprised reactions of Londoners at Madonna’s presence. In a matter of minutes Madonna ripped off the video Aisha had already filmed and labored over (the footage is time and date stamped), making plans of her own to shoot the same exact video Aisha had filmed two days before. Many people witnessed Aisha filming this footage - several of which were given her business cards. Aisha had also copyrighted that London video treatment years ago, but only got around to shooting it last week. Further proof Madonna has been committing corporate theft, stalking, harassment and invasion of privacy against Aisha. 53. It also highlights the fact that Madonna was still sickly watching Aisha even in London, via the surveillance campaign she commissioned against the young singer in Miami who has been going about her business and not bothering anyone. Yet the perverted, depraved, obsessed Madonna has been constantly stealing from and harassing her at every turn. The illegal surveillance campaign followed Aisha from Miami to Jamaica to London over a 10 day span in a gross invasion of privacy and foul acts of stalking. 54. Additionally, Aisha noticed a burly man whose arms were covered in tattoos sitting at the bus stop outside her aunt’s home on the outskirts of London when she went to take the bus to the train station to get to central London (her aunt’s car wasn’t working). She paid it no mind until two days later she saw the exact same man again standing roughly a foot behind her at an Oxford Street bus stop where she had been filming. This bus stop was very far from her aunt’s home and she was startled when she turned around and saw the same man again. He stared at her intently for several minutes, which prompted her to cross the street to get away from him. 55. Much like the incident where she was assaulted in Miami two months ago, she saw the same person on two separate occasions in close proximity of each other (over the course of a few days). The incident in London was at the hands of a tall, burly white male and the incident in Miami was at the hands of a tall, burly black male. Both men along with several other people who have approached Aisha at different times in Miami to harass her on Madonna’s behalf beginning this summer, all looked menacing and unstable. 56. These were not Madonna fans, as several of these individuals, with the exception of the male in London who did not speak to her, all repeated things to her verbatim that she’d said over the phone in confidence and in the privacy of her own home. How would a fan know what Aisha has been saying over the phone and in the privacy of her own home to do such a thing as to sickly approach her in public, strike up a conversation and repeat these things to her exactly as she had said them before. 57. Only someone who had information from an illegal surveillance campaign would know these things to memorize then repeat them in person to the victim of the wiretapping, as was done to another of Madonna’s lawyer’s nemesises, Court TV’s Diane Diamond, who publicly complained “My words were coming back to me through others” regarding the wiretapping and harassment she experienced during the time she reported on the first Michael Jackson child molestation case. 58. Though Aisha does not believe Mr. Pellicano was involved in the assault, as he is currently incarcerated, it is worth noting that the FBI confiscated 4 billion pages of wiretap transcripts of famous and non-famous people’s telephone calls that Madonna’s lawyer’s private investigator, Mr. Pellicano had tapped, which were all stored in paper/text format made from sound recorded wiretap tapes. According to experts, text copies of wiretapped phone calls are easier to send to the individual who commissioned the wiretapping and easier to understand, as opposed to sending them tapes of the illegally tapped calls. 59. On September 18, 2005 Aisha noticed that she and her family were being followed by a man and a woman in a dark blue BMW for over 25 minutes in Oxfordshire, England in a pre-planned trip she had made to film a specific place. It was the main footage she required and planned the trip around. 60. These incidents coupled with Madonna’s conduct listed above, show a clear pattern of commissioned harassment, stalking, assault and invasion of privacy. 61. Defendant Madonna is and at all times mentioned herein was, a copyright infringing, plagiarism prone singer who has built a career on pornographic music, filth, debauchery and shock value, much of it resulting in plagiarism and copyright infringement lawsuits by numerous international copyright holding songwriters, directors, artists and singers all over the world. Madonna has become very rich off of infringing artists copyrights, thereby unlawfully diverting their songwriting royalties and film points (royalties) to herself, as evidenced by the numerous lawsuits filed against her in this regard, listed further in this Complaint under the "Madonna’s Extensive History Of Plagiarism And Copyright Infringement" section. 62. Madonna and her label Warner Bros Records/Warner Bros/Time Warner AOL, have been sued for and publicly accused of stealing people's copyrighted works more times than any other artist and company in entertainment history. Michael Jackson, Elvis and the Beatles are considered the most famous and successful artists in music history and none of them have such a disgraceful history of copyright infringement and plagiarism, as does Madonna, though they wrote many of their own tunes, as the Defendant Madonna claims she does, which has been shown to be untrue on many occasions. 63. Madonna has confessed to having long bouts of writer's block, SEE EXHIBIT 46, and stated in People Magazine, "I no longer have time to be creative," SEE EXHIBIT 47 - very telling statements by a woman who has been sued numerous times for plagiarism and copyright infringement, with almost 3 dozen credible public allegations of the same by many artists, who were left defrauded and damaged as a result of her unconscionable, thieving actions. DESPERATE MADONNA64. The malfeasances committed against Aisha occurred due to Madonna’s desperate need for innovate, cutting edge music and ideas to maintain her career, which has been solely based on substanceless trends, debauchery, vulgarity, pornography and shock tactics. In a vain attempt to inject life into her fading career and to compete with the likes of younger stars like 24 year-old Britney Spears and 25 year-old Jessica Simpson, 47 year-old Madonna pilfered and pillaged the copyrighted works of rising 28 year-old indie singer Aisha, even going as far as making over her image into that of the younger singer for a Versace ad campaign in a grossly exploitative violation of Aisha’s Right To Publicity and Right To Privacy, listed in detail further in this Complaint. 65. Rather than aging gracefully and elegantly like talent based stars Tina Turner and Barbra Streisand, Madonna continues to vulturously rape and pillage younger, innovative artists' copyrighted works in a vain attempt to remain a 20 year-old, while making a fool of herself due to this in latter years, due to her career having been based on selling sex and youthfulness, rather than vocal ability, which according to scores of critics, entertainers, music industry experts and audiences, she greatly lacks. 66. Artists such as the Beach Boy’s Brian Wilson, Joni Mitchell, Elton John, Prince, Elvis Costello, Boy George and former Westlife member Bryan McFadden have publicly voiced their disapproval of Madonna’s lack of talent and penchant for debauchery and pornography to get the spotlight and sell records. Scores of critics and audiences have also publicly and very vocally complained of her lack of talent and lack of singing ability. 67. Aisha has filed this action against Madonna, Time Warner, Disney and their co-defendants for the systematic stealing of original works wholly authored and copyrighted by Aisha in accordance with US copyright law, as recognized by the United Nations’ Berne Convention and Jamaican Law - all prior to Madonna, Time Warner, Disney, their subsidiaries, affiliates and co-defendants thefts thereof. There are over 300 instances of copyright infringement and plagiarism by Madonna and her co-defendants, of works wholly authored, owned and copyrighted by Aisha, prior to the Defendants stealing them. 68. Madonna acted as the ringleader and head conspirator in the ongoing gross malfeasances being committed against Aisha with her employer Warner Bros/Time Warner, Madonna’s partner in JBT Films online Jerry Bruckheimer (Jerry Bruckheimer Films) and her colleagues at Disney that she has clear public ties to soon following suit when they realized the value of the treasure trove of copyrighted works Aisha owns, that took her over 20 years to author. Works they criminally stole and made use of. 69. These malfeasances constitute numerous violations of U.S., British, Jamaican and United Nations Laws, both civil and criminal, for financial gain, which is disgraceful and thoroughly reprehensible. Sadly, it is a blaringly accurate portrait of the state of the entertainment industry and just how far artists like Madonna and companies like Disney and Warner Bros will go for money via raping and pillaging the copyrighted intellectual property of independent writers, which is a way of life for the Defendants, as evidenced by close to 100 separate lawsuits against them for said crimes, mentioned further in this Complaint. Copyright infringement is a lucrative, albeit criminal, source of income for them, for which they have been sued numerous times, but continue to illegally engage in, anyway. Their actions clearly illustrate they have no respect for or fear of the law. 70. Coveting the innovative indie artist's music, film and literary projects that have set industry precedents and realizing what was to come from the young writer/singer, Madonna in conjunction with Time Warner, Disney and their affiliates, commissioned and executed a vile, corruption based, racketeering ridden plan to commit corporate theft, grand theft larceny and invasion of privacy, waging an illegal, surreptitious surveillance campaign, actively harassing, terrorizing, bullying and invading the privacy of Aisha via wiretapping, computer hacking, 24 hour surveillance and threatening associates who criminally approached Aisha on the streets of Miami, threatened her verbally and on one occasion physically grabbed her by the neck and attempted to choke her before a civil court meeting in Downtown Miami. 71. Choking is a method perversely preferred by Madonna, who choked two people as mentioned above, due to her perverse obsession with the young singer and stealing her treasure trove of published and unpublished copyrighted works. 72. Curiosity and greed got the best of Madonna and she hired a hacker to illegally copy Aisha's unpublished copyrighted multi-million dollar catalog of works that she spoke of on her web site, from her hard drive that she and her co-defendants have been criminally making use of in putting these already copyrighted works from Aisha’s catalog into production at their companies and re-copyrighting them as their own - severe civil and criminal breaches of United Nations, U.S. and Jamaican Laws. MADONNA: FROM INTERNET THEFT TO CRIMINAL CORPORATE THEFT VIA HACKING AND INVASION OF PRIVACY 73. The malfeasances began with Madonna blatantly and flagrantly stealing from Aisha's published 2001 copyrighted music (sent to 50 international DJs in 2002 by Aisha, for which she has mailing receipts), lyrics, articles, album pics and features unique to Aisha's copyrighted web site, in clear view of Aisha's fans on her web site www.aishamusic.com, for illegal use on Madonna's critically dismissed 2003 “American Life” CD and progressed to something far more sinister and illegal - invasion of privacy via commissioned phone tapping and computer hacking to commit corporate theft of more of Aisha's copyrighted works. 74. This was also done to harass Aisha and her family by spying on them and making the personal contents of their lives that could only be gained via illegal surveillance, public through the Sun Newspaper UK and the Time Warner/Jerry Bruckheimer show CSI: Miami, in a sick, despicable, criminal attempt to discourage litigation and enable them to further criminally use her very lucrative catalog, especially the film scripts, which would have been worth billions to them if they got her out of the way. Things Aisha said verbatim to friends, family and business associates appeared in its exact context in the Sun Newspaper UK and on Madonna’s partner’s show CSI:Miami, that Aisha had said she was a fan of (with was being the operative word). The owner of the show “CSI:Miami” is Madonna’s partner in JBT films online, Mr. Jerry Bruckheimer - SEE EXHIBIT 33. 75. Aisha realized a few months ago that things she was saying in the privacy of her home were being repeated publicly by Madonna and printed in the Sun Newspaper by her publicly confessed friend and email buddy, Victoria Newton and by Madonna’s partner in JBT Films online, Jerry Bruckheimer via his show CSI:Miami. Mr. Bruckheimer has been publicly written about before for using his shows to insult and harass competitors by including them and details of their lives in the storylines, as mentioned further in this Complaint. 76. It was recently discovered via an electronic gadget that tests for RF, that there’s been audio recording and filming in Aisha’s home and close to the perimeter at times no visible audio or video recorders were present. This did however explain how Madonna was able to quote word for word things Aisha had said in the privacy of her own home, not just over the telephone. 77. Aisha's other copyrighted works not released to the public yet, but registered in the Library Of Congress and housed on her computers, were illegally utilized by Madonna, her employer Time Warner, Disney and their affiliates, in acts that can only be described as abhorrent, despicable and nefarious. The numerous thefts by the Defendants of Aisha's unreleased, unpublished copyrighted works bear exact duplication, blatant copying and willful alteration, all punishable felonies, largely due to how Aisha’s private Library of Congress copyrighted catalog was criminally procured by Madonna. 78. Aisha and her family's privacy has been inhumanely and perversely invaded and thrown in their faces by Madonna and her co-defendants through hired hackers, wiretapping and unlawful surveillance - the contents of which were used by Madonna, Disney, Warner Bros and Jerry Bruckheimer Films, as a form of harassment and terrorization against Aisha to discourage litigation and free them to use more of her valuable copyrighted works, in making items said in the privacy of her home and over the phone in confidence to different people, public via the Sun Newspaper UK and Warner's CSI:Miami. 79. Aisha's greatest item of concern is the sophisticated surveillance campaign utilized against her and her family. Aisha and her mom live together in a quiet Miami suburb. Relatives have visited and stayed for vacation, some of who are minors whose citizenship originate in two countries. They had their meals, changed their clothes, and said their prayers at night before they went to sleep in a home Aisha has now discovered has been under illegal surveillance in violation of many U.S., Jamaican, British and United Nations laws. 80. Aisha recently found digital phone taps on her telephone line and over 22 computer virus trojans and numerous illegal spyware programs on her computer, placed there by a hacker unbeknownst to her. SEE EXHIBIT 1 for the computer programs reports regarding the unlawful ongoing intrusions to her computers and the number of times it occurred. The CD ROM exhibit shows the numerous computer trojans planted on Aisha's computer to gain unlawful entry and copy the hard drive containing Aisha's multi-million dollar catalog of copyrighted works that is also housed in the Library of Congress. 81. Aisha was prompted to search for computer hacking/intrusions, as she began noticing items from her already copyrighted catalog she privately houses on her computers with the other copies in the Library of Congress in Washington, D.C. began mysteriously surfacing in Madonna, her affiliates Disney and her employer Time Warner's new and announced projects such as the movie Material Girls (Madonna's Maverick Films) and "Princess Diaries 2" (Buena Vista Film/Disney) - without Aisha's permission and fraudulently attributed to the Defendants. 82. This raised some serious questions about how these leaks occurred, as the only place the works have been housed since their creation is in the Library of Congress/Copyright Office in Washington, D.C. and on Aisha's personal computers - the matter complicated by an issue listed further in this Complaint. 83. In an ironic and incriminating twist, Madonna's children's book the English Roses, sickly has a page about spying on a girl, a character, who is a lot like Aisha in the description Madonna used to describe her in the book. The book eerily says, "They couldn't turn down the chance to spy on Binah without her knowing they were there" and "but she'll think were burglars or something (Aisha's home studio was burglarized shortly after she began publicly complaining on her web site of Madonna stealing her copyrighted music from the site, SEE EXHIBIT 13, for Police Report) and "she will call the Police" are among the odd, demented lines in the children’s book. 84. Even more eerie is the fact the character they were spying on, Binah's life is a lot like Aisha's, especially in the exact list of chores Aisha does at home that the books lists on page 32 in great detail and illustrated pictures (peeling potatoes, chopping onions, scaling fish, washing the clothes, ironing the clothes, scrubbing the floors, taking out the trash and taking care of a parent they live with). 85. Even the description and picture of Binah's room in the book is like Aisha's actual bedroom at home. The character in the book was not based on Madonna's daughter, as she deceitfully claimed on several TV shows and in magazines - it was perversely based on Aisha, who Madonna has criminally had under surveillance, as she stole the young singer’s copyrighted multi-million dollar catalog and began using it. 86. Madonna's daughter does not do any of those chores (peeling potatoes, chopping onions, scaling fish, washing the clothes, ironing the clothes, scrubbing the floors, taking out the trash and taking care of the parent they live with) as she was 5 years old at the time the book was published. Nor is she blond, like the character in the book (her hair is black). Aisha does those exact chores several days a week, lives with her mom who she takes care of and has had her hair blonde for over 10 years. 87. Furthermore, references made by Madonna on the television show “The View” in June of 2005, referring to putting her daughter’s clothes in a trash bag because she leaves them all over and on the floor, is a practice Aisha does weekly in putting her mom's dirty clothes in a new trash bag, taking them to the laundry room and washing them, right after complaining to her mom about leaving her clothes in different rooms of the house (even Aisha's realtor asked her to not leave the trash bags with the clothes in the room next to the laundry room, when he was trying to sell her home last year. He told her that a good house selling tip is eliminating clutter, as potential home buyers might mistake it for trash, when its actually clothes to be washed). 88. This was the same thing Madonna later, who publicly claims she isn't domesticated and can't cook, claimed she is doing regarding her daughter, in putting her dirty clothes in trash bags. The idea of Madonna going around a house with a trash bag when she says she has maids and two nannies is very incredulous. She got that story from the illegal surveillance campaign she commissioned against Aisha. 89. Another of Madonna's children’s books, “Lots De Casha,” has furniture that is like furniture in Aisha's home and chronicles private events that happened in Aisha's home - yet Madonna included it in her book. The character in the book actually sleeps with a blanket every night that is very similar in color and pattern to the one Aisha sleeps with every night. Aisha sleeps with a pink and white blanket with stars and squares on it. The character in Madonna’s book sleeps with a pink and white blanket with squares on it. Not to mention, the Versace ads featuring Madonna that rip off Aisha's life, Right To Publicity and Right To Privacy, contained furniture in it that is like the furniture in Aisha's home office. 90. How could Madonna have possibly known so much about the daily goings on, incidents, layout and furniture in Aisha's home to write and print it in her books and Versace ads in such accurate detail, unless she had illegal access to Aisha's home. Aisha was stunned, appalled and creeped out when she read Madonna's Kaballah children’s books for the first time recently looking for further infringement of works from her catalog, as that is when she realized the extent of what the depraved 47-year-old singer had done in invading her privacy and that of her family, some of which are minors. 91. No one should be made to endure such illegal, invasive treatment. Aisha and her family members, some of whom are minors, are law-abiding citizens who've had their privacy violated by the Defendants. They didn't deserve to be spied on like dogs with no rights. The Defendants’ conduct violates numerous international human rights laws set forth by the United Nations - and most of all, is inhumane. What kind of sick individual does something like that to an innocent family. THE KABALLAH CULT: PRIVACY INVADERS, TRESPASSERS AND COPYRIGHT INFRINGERS 92. As mentioned above, the Defendants are no strangers to claims of invasion of privacy. Madonna’s lawyer Bert Fields is the attorney for the privacy invading Church of Scientology (members were arrested for bugging an FBI office) and the privacy invading Kabbalah Center. 93. The Kabbalah Center's founder, Phillip Berg, was sued for invasion of privacy in going into the home of a deceased Rabbi, stealing his manuscripts, re-copyrighting them in his name and publishing them as his own. He has been publicly accused of copyright infringement of other works as well and sued in another instance, mentioned further in this Complaint. Berg’s actions were an invasion of privacy in entering the Rabbi’s home and committing an act of grand theft larceny and later copyright infringement. There have been published reports of a memo where the Kabbalah Center encouraged copyright infringement to gain literary material, as written about in Radar magazine’s investigative piece on the cult, included as an exhibit in this Complaint. MAIL TAMPERING94. Beginning in June 2005, Aisha noticed that when she checked the mailbox at her home, her mail had been tampered with, crumpled and opened. Confidential legal documents from a lawyer, a report from stock company and a letter from a Christian charity were opened by persons unknown and placed back in the mailbox with the envelopes blatantly opened. 95. Looking at the mail, you can tell the sender had sealed the letters, as the envelopes' glue had been altered in textured and appearance by the presence of saliva/ water before sealing it. However, someone had clearly opened it, read the contents, folded the envelopes flaps back over and put them back in the mail box, as when Aisha went to open letters on four occasions, these items were already opened. Imagine receding your mail opened. It is not a common occurrence, but a deliberate act of invasion of privacy and mail tampering. 96. The first time it happened, Aisha wondered about it, but then discounted it. But then it happened three more times in a short period of time. That's when she realized someone was deliberately opening her mail. She then thought about it and remembered that the companies that sent her the mail that someone had unlawfully opened had never sent her opened or unsealed items in the mail in all the years she has known them. She filed a complaint with the Postmaster General. WIRETAPPING 97. Aisha has never had the mail in the box opened before, until the recent escalation of harassment and terrorization against her began in May of 2005 by people clearly affiliated with Madonna and her co-defendants, who clearly illegally had access to Aisha's phone conversations and her home. Also evident by the fact that Madonna in the same manner was repeating publicly, verbatim, things Aisha had said in the privacy of her own home and over the telephone to numerous people. 98. As mentioned above, people have come up to her in public places, made physical contact, harassed and threatened her about Madonna, told her in veiled threats of commissioned crimes against private citizens who challenged major named figures and of citizens losing in lawsuits against big companies in New York (which is ironically where Madonna’s Time Warner is located) - only these weren't Madonna fans, these were strangers who clearly had had access to Aisha’s home via invasion of privacy, as they repeated things to her verbatim that she had said in confidence over the phone and other items she'd said in the privacy of her own home to her mother. 99. This has been apart of an unlawful, despicable commissioned campaign to exploit and terrorize the young writer/singer due to her very valuable catalog of copyrighted works, as mentioned above, that Madonna and her co-defendants covetously and illegally obtained a hacker procured copy of and have been unlawfully putting songs and movies from said catalog into production at Maverick, Warner Bros and Disney, violating Aisha's rights of copyright ownership and authorship and right to privacy. 100. Security experts Probe Inc of Los Angeles, California state, "If you have a company that is involved in the fashion, entertainment, advertising or marketing industry, you may become a target of wiretapping and unlawful surveillance.” They warn of red flags to watch for that Aisha has experienced. And considering so much of Aisha's other copyrighted works housed in the Library of Congress and on her personal computers, that have not been released yet, has been stolen at such a disgraceful rate and keeps surfacing in projects by Madonna and her affiliates and partners, it is clearly and unquestionably a vile case of criminal corporate theft and invasion of privacy. MADONNA’S LABEL WARNER/AOL THE SOURCE OF A HACKER SPENDING SPREE ON AISHA’S VISA DEBIT CARD USED TO PAY FOR AOL INTERNET SERVICE AND AISHA BLOCKED FROM GETTING ONLINE TO UPDATE HER SITE FOR DAYS DUE TO ALLEGED AOL “TECHNICAL DIFFICULTIES” 101. Time Warner's AOL, a subsidiary of the company Madonna records for, further allowed a hacker to charge almost $600.00 to Aisha's debit/credit card they had on file to charge her account $24 monthly for internet access with AOL. When she called AOL to dispute the AOL charges - they said “a hacker probably got access to your card” and that she was to “change her passwords.” 102. This occurred days before a worse identity theft occurred, where someone tried to tie up all her funds using the very same debit/credit card connected to her bank account that AOL had, the weekend she announced the pending release of her album. The person tried to tie up her funds charging items that they provided no proper shipping address for and advertising services that they could not use. Regardless, this would have tied up Aisha's funds, and some banks like Washington Mutual, do not refund money from fraudulent charges stemming from identity theft, holding customers liable for them. 103. However, thankfully, at that point Aisha was not banking with such an institution. The debit/credit card company used by her new bank, called her very early in the morning, waking her out of her sleep to tell her they felt she'd been the victim of identity theft in that someone was using her card over and over again to buy things on the internet (at about 4AM in the morning EST). She informed them that it definitely was not her and they asked for authorization to cancel the compromised card. They further investigated the fraudulent charges and realized someone on the West Coast made them at a time Aisha was sleeping on the East Coast, when they called her home. 104. The debit/credit card company provided her with a list of merchants the hacker made the fraudulent charges with and the telephone numbers for the businesses. When Aisha called to investigate what happened, the merchants told her that they realize the charges aren't legitimate in looking at them now, as the person did not fill in a proper shipping address, rather typing gibberish in the shipping address fields. Someone was playing around with her card online to spend and tie up as much of her money as they could to thwart her pending album release. 105. Aisha was additionally having problems with her AOL service in not being able to get online to update her web sites www.Aisha.tv and www.aishamusic.com. There were times when she couldn't get online for a few days due to alleged "technical difficulties." Aisha now believes it was due to the fact that she was publicly complaining about Madonna and Warner Bros (who owns Aisha’s former internet service provider AOL) on her web site in speaking out against them for the illegal acts they were committing against her. Aisha’s web site was hacked shortly after as well, links removed and pages deleted referring to Madonna’s misdeeds, all without permission on a site they do not own or host and in violation of Aisha’s rights. 106. This was done by a hacker, clearly commissioned by Madonna, who hacked her site in the same manner he hacked her computer to give Madonna criminally obtained and made copies of Aisha’s copyrighted multi-million dollar catalog that Madonna later began criminally using for her projects. These projects made Madonna millions of dollars in ill-gotten money. 107. When Aisha closed her AOL internet account, uninstalled their software from her computers and switched to another ISP, they still continued to bill her anyway SEE EXHIBIT 49 - a complaint echoed by many former AOL subscribers. However, the AOL identity theft and hacking provided Madonna and Warner Bros with a clear, detailed layout of Aisha’s computer systems and the contents thereof - which they later criminally used via the copy of Aisha’s multi-million dollar valued copyrighted catalog. MADONNA’S COMMISSIONED ILLEGAL SURVEILLANCE OF AISHA 108. Red flags Aisha has experienced, as outlined by Probe Inc are "Confidential personal information mysteriously appears in the newspaper." This has happened to Aisha in that things said in confidence over the telephone to her family and friends have appeared in print in the Sun Newspaper UK, attributed to Madonna and her friend, Sun Newspaper journalist Victoria Newton, in actions that can only be described as perverse. 109. It is a violation of Aisha's civil and human rights via invading her privacy through having her under round the clock surveillance and going as far as having these personal items Aisha said in the privacy of her own home to her mother, and on other instances, items she said over the phone to friends and family members, reprinted verbatim in the Sun Newspaper UK, which is listed in detail further in this Complaint. 110. Victoria Newton further printed items from Aisha's copyrighted documents and scripts only available on Aisha's personal computer and in the Library Of Congress, in the Sun Newspaper UK, attributed to herself and Madonna, which was a gross invasion of privacy and copyright infringement, also listed further in this Complaint. Ms. Newton further unlawfully helped herself to items from Aisha's widely read copyrighted Sound Off Column and online Diary pages of her web site that has been read by millions, after Aisha published them online to her web site, for use in her distasteful Bizarre column in the Sun Newspaper. 111. Based on preliminary evidence, the tapes of Aisha's telephone calls were shared by Madonna with not only her friend and email buddy Victoria Newton of the Sun Newspaper UK, who singer Pete Doherty of Babyshambles deliberately mentioned to in an interview that he found hidden cameras and a bugging device in his home that is now being investigated, SEE EXHIBIT 26, they have also been shared with the writers for Time Warner/Warner Bros owned Jerry Bruckheimer Productions' television show CSI:Miami, who also infringed Aisha's copyrights by ripping off items from her copyrighted Sound Off Column and online Diary after she'd put copyrighted editions of the column online, detailed further in this Complaint. 112. Aisha's copyrighted works from her web site and things she said over the phone in confidence, were utilized for script dialogue and plotlines for CSI:Miami, which is outlined further in this Complaint. These acts of invasion of privacy were utilized for four episodes of the show this year. The program is filmed in Aisha's hometown and also featured Madonna's best friend of 25 years fellow Kabbalahist, Debi Mazar SEE EXHIBIT 34. 113. Jerry Bruckheimer, owner of Jerry Bruckheimer Films/Warner Bros attributed copyrighted items from Aisha's Sound Off Column and things she said in the privacy of her own home, to himself in public interviews he did, after she published the items on her web site and after she said these items in the privacy of her own home SEE EXHIBIT 48. 114. Madonna and Jerry Bruckheimer are friends and partners in an internet venture for films SEE EXHIBIT 33, both work for Warner Bros/Time Warner and both have the same lawyer, Bert Fields, who, as mentioned above, has been at the center of an FBI probe for his private investigator Anthony Pellicano wiretapping people who'd threatened to sue or sued Bert Fields' famous clients. Mr. Bruckheimer's former partner, the late, notorious Don Simpson was also a client of Bert Fields and was also mentioned in the wiretapping scandal. 115. Her telephone calls have been recorded, her faxes intercepted, both business and personal, and forwarded to Madonna and shared with fellow Warner Bros and Kaballah cohorts, who foolishly and incriminatingly utilized and repeated business and personal items said over the phone and in Aisha's home, verbatim in interviews in the press and on the show CSI:Miami (The owner of the show “CSI:Miami” is Madonna’s partner in JBT films online, Mr. Jerry Bruckheimer - SEE EXHIBIT 33). This is a harassment technique commonly used in certain circles in Hollywood when they want to scare a legal opponent, someone publicly threatening to sue them, someone writing unflattering articles about them or publicly speaking out against them, as did Diane Diamond and Anita Busch in going against clients of Madonna's lawyer. 116. Madonna commissioned the phone tapping then utilized verbatim items from Aisha’s personal and business telephone calls for her projects on Maverick, Warner Bros, articles in the Sun Newspaper in London about her and numerous other interviews to enhance her sullied image, in an effort to aid her latest reinvention to make her appear intelligent, demure and refined, when she is none of those things. 117. Madonna has been actively and perversely watching Aisha's every move through an unlawful 24 hour surveillance campaign, that recently escalated to threatening and harassing Aisha in public, that several of her co-defendants knew of, but looked the other way in exchange for profits reaped from the illegal surveillance of the Plaintiff, used to commit corporate theft of her copyrighted works valued in the millions and the subsequent terrorization in vain attempts to scare her out of suing and reporting them for their misdeeds towards her. 118. These malfeasances are detailed further in this Complaint. They hoped by scaring her via threats, she would cave in and not go through with the lawsuit against them, freeing them to illegally use more of her works from her vast, lucrative copyrighted multi-million dollar catalog. However, Aisha was and is undeterred in bringing them to justice for the horrible malfeasances they've committed against her. 119. On September 3, 1993, Kabbalah cult lawyer Bert Fields' private investigator Anthony Pellicano and attorney Howard Weitzman claimed that the unauthorized wiretap they used on behalf of Kabbalahist Michael Jackson was legal. There are at least 4 civil suits that have begun since Mr. Pellicano's imprisonment pertaining to his illegal use of electronic surveillance, harassment and intimidation. Pellicano still advertises on the internet. 120. Bert Fields private investigator Anthony Pellicano further threatened, bullied and harassed writers who went against his clients the National Enquirer. When writer Stuart Goldman changed his phone number, Anthony Pellicano would call him on the new numbers to let him know he had "made" the number. Goldman further stated Bert Fields' private investigator further wiretapped his phone calls and terrorized his family. 121. Writers Lurie and De Becker he referred to as a "couple of fags" that he was going to expose. Pellicano stated "Their lives are going to be disrupted in ways they can't even begin to image." Lurie, shortly after was knocked off his bicycle 50 feet in the air by an unmarked car and sustained two broken ribs and a busted back. Laurie stated after the accident, "it was no accident...they made good on their threat" (source: anthonypellicanoweblinks.com). 122. There is a pervasive problem in Hollywood where the rule of thumb in certain circles is a misbehaving celebrity and or executive trying to shake off litigation for their misdeeds and unlawful acts, trumps your rights as a private "nobody" citizen to privacy and safety. That you do not have the right to have a phone that is not wiretapped. That you do not have the right to go about your life without strange menacing people approaching you in public, threatening, harassing and assaulting you. That you do not have the right to a computer that is not hacked and laden with spyware and internet activity tracking programs monitoring and recording you online. That you do not have the right to a home that is under illegal surveillance. 123. Rather than a clean, constitutional legal fight fought in the courts, some in Hollywood, time and time again opt for a dirty, illegal, unconstitutional fight that breaks more laws than the average spoiled, overindulged female pop star has tantrums. This allows the same handful of misbehaving pop stars and entertainment industry executives to hypocritically and cowardly bully and victimize, all while hiding behind hired hands that terrorize innocent people who dare to protect their rights and property against the pseudo-almighty celebrity. 124. This conduct needs to stop and serious, consequential questions need to be asked as to why it is always the same set of people being publicly accused of this exact same invasive misconduct against innocent people in the entertainment industry. 125. Another red flag, as outlined by Probe Inc is, "Corporate raiders mysteriously launch a hostile takeover at the opportune time." Aisha's copyrighted works that are unpublished and housed on her personal computer and in the Library Of Congress are illegally being put into production by Madonna, who is behaving like a corporate raider, but criminally so, in a mad rush to put out and criminally sell as much of Aisha’s copyrighted works as she can for her own projects and that of partners and collaborators, to corner it in the marketplace on Aisha’s works and labor in despicable acts of corporate theft. CATALOGS126. Another item of great concern for Aisha is that Madonna is now secretly in unlawful, criminal possession of Aisha's copyrighted, unpublished, multi-million dollar catalog containing 6,000 plus songs, 2 dozen scripts, 4 dozen film synopsises, 11 book manuscripts, 4 dozen music video treatment, and 3 dozen photo treatments. Madonna has already been misappropriating items from this catalog and obtaining huge financial remuneration for selling and using Aisha's already copyrighted works she has illegally attributed to herself and re-copyrighted in her name and Maverick's, which constitutes criminal acts in violation of Jamaican, U.S., British and United Nations laws. 127. According to ABC News, “Song catalogs have become hugely lucrative in the last two decades due to the compact disc boom, rising sales of Internet downloads, and movie studios and advertisers willing to pay royalties to use hit songs in film scores and commercials...It's hardly chump change: the small amounts add up to millions of dollars in revenues each year." HACKING AND CORPORATE THEFT ON THE RISE128. Madonna first stole Aisha's 2001 copyrighted and released song titled "Contemporary Girl" which was sent to 50 international DJs and featured on Aisha's site, for her later ill fitting, critically panned, clumsy rip off "American Life" released in 2003. Madonna passed off Aisha's copyrighted works as her own in the mainstream to untold millions - but later progressed to more sinisterly stealing unpublished unreleased copyrighted works, valued in the millions, from Aisha's private computers via a hired computer tech specializing in hacking computer systems via the internet. 129. According to a September 19, 2005 article in London’s Metro newspaper, Microsoft Chief security adviser Ed Gibson speaking to the Westminster eForum warned, “Cyber criminals could render the Internet useless in 3 to 5 years” if “Microsoft and other major players in this arena do not make a concerted effort to make the products more secure, the thing we call the internet will not be as it is today.” 130. Other figures show that internet corporate theft has become a leading form of crime. Hacking and computer data theft is a crime that is on the rise in the entertainment industry. Recently, Fred Durst of the band Limp Bizkit filed an $80,000,000 suit on March 2, 2005, due to the contents of his personal computer being hacked and copied by a company seeking to do business with him in distributing a video he had made and believed was "safely stored on the hard drive of his personal computer." 131. A hacker had been hired by the company to use IP tracking to locate and monitor Durst while he surfed the internet, pinpointing his location, then hack his computer, illegally copying the video from his hard drive. Then in an extortion style business bid, they contacted his manager requesting to do business with him for the hacker procured copy of the video they unlawfully had in their possession. They even informed him that Durst's computer was deliberately hacked to steal the contents. When Durst declined their offer, they vindictively placed the video and pics from it online. Durst then called the Secret Service and filed suit. HIRED HACKER132. The Plaintiff has every reason to be believed Madonna was behind the hackings of her computer and web site: 133. Aisha was the victim of a hacker beginning with Madonna's employer Time Warner AOL - who allowed who they said they believed to be “a hacker” to charge $600 to Aisha's AOL internet account that was connected to her Visa Debit card. When Aisha pressed them on how something like that could happen, they wouldn't give her any proper answers only telling her “it is confidential,” "I can't tell you that” and "I'm not allowed to tell you that” and to "change her password." Days later, Aisha was the victim of an identity theft based in malice and not financial gain - and the person clearly knew a lot about Aisha, as they tried to buy items at places they felt she would shop, in an attempt to run out all the money in her account attached to her visa/debit card. They spent almost $2,000 in a few minutes in erratic buying patterns then were stopped by her Visa Debit Card company. This was done the very weekend Aisha announced her album was available through the site. They tried to spend all of her album promotion money so she and the project would be marooned. 134. AOL violated the Electronic communications Privacy Act, 18 USC 2703, in their misconduct regarding Aisha. AOL - spied on Aisha on behalf of Warner and Madonna who were actively stealing her copyrighted works for huge profits in the millions. 135. AOL criminally assisted their co-workers at Warner (Madonna) in their illegal quest to rob, exploit and defraud Aisha out of millions of dollars in copyrights. 136. The VP of EarthLink, Claudia Caplan said, " AOL sells your information." Aisha has found that to be quite true, as they assisted their co-workers at Warner in violating Aisha's privacy and stealing millions of dollars in copyrighted work the US government via the Library Of Congress granted copyright protection to. 137. AOL additionally violated the copyrights of Aisha’s Sound Off Column numerous times, stealing items from it for the AOL home pages as knock off articles and news features. 138. This is not the only case of AOL misconduct, invasiveness and negligence. AOL was sued for “distributing child porn.” It was reported that they knew of the problem with their chat rooms distributing child porn, but did not stop the child pornographers once the complaints had been made. The report accused them of looking the other way. 139. The mother of the boy featured on the child porn tapes distributed online sued teacher Richard Lee Russell for child pornography and AOL for distributing it online. The boy’s mother referred to AOL as the "home shopping network for pedophiles and child pornographers" due to the severe problems with child porn and said ISP. 140. One chat room was also reported to have been blatantly called “boy4man2rape,” which translates into boy for man to rape. Attorney Bill Crimmins said, "Why are these people (pedophiles) still around AOL. Certainly not because the corporation has zero tolerance to child pornography and child sexual abuse." 141. AOL was sued on charges of copyright infringement by author Harlan Ellison for the unauthorized distribution of his writings. 142. AOL hired chat monitor that seduced teen in kids’ only AOL chat room. The adult monitor persuaded a 16-year-old girl to send him nude pics of herself and engage in phone sex with him. He sent the minor sexually explicit videos of himself and planned to drive to meet her for the weekend on her 17th birthday. According to analysts this case proved that “AOL’s parental controls are useless.” 143. AOL released Clifton S. Freedman's info without the signature of a judge on warrant for which he sued. They released his name, address, phone numbers, account status, membership information, software information, billing and account information. A local newspaper obtained a copy of the police report and made his information public. Freedman had to withdraw from a school board race and resign (LLRX.COM). AOL had violated the Electronic communications Privacy Act, 18 USC 2703. 144. The University of California and Amalgamated Bank's LongView Collecitive Investment fund sued AOL/Time Warner for insider trading that reaped them 1 billion dollars. AOL was fined $300,000,000 by the FCC for accounting scams. AOL fired three employees, Luke Hansen, Paul Carlson and Hanson Melling for exercising their right to bear arms. 145. Numerous consumers have also complained of AOL continuing to bill after they cancel. AOL utilized this same unethical practice against Aisha as well. 146. Playmedia sued AOL for copyright infringement. AOL cleared showed in this case that they have no respect for copyrights when they willfully stole the copyrighted program and trademarked technology Playmedia created, and unlawfully used it in AOL 6.0's media player. 147. Aisha’s contract with AOL became null and void when they violated their half of the agreement in protecting Aisha’s privacy and information. Aisha’s contract with AOL also became null and void when they violated on behalf of their parent company Warner Bros, label to Madonna, who criminally used Aisha’s multi-million dollar valued copyrighted catalog that was criminally procured for their co-worker Madonna in violation of international civil and criminal law. 148. AOL also enabled Madonna and her coconspirator at the Sun Newspaper UK to see in advance what Aisha had researched online for her Sound Off Columns and Madonna and The Sun’s Victoria Newton used this information to put out press releases and articles in The Sun that would illegally use items Aisha had searched for, written about and saved in WordPad documents on her laptop and personal computers. Madonna and Newton perversely did this for months Aisha kept wondering how her Sound Off Columns were being leaked verbatim in advance as Madonna and Newton idiotically and incriminatingly would quote verbatim what Aisha had written into search engines, in WordPad documents and the just about to be released Sound Off Columns on her laptop and PCs. 149. Victoria Newton's column "Bizarre" is sister column to the New York Post's "Page Six", written by Paula Froelich and Chris Wilson, who both frequently exchange stories, tips and gossip with each other that often times violate people's privacy. News Corp owns both newspapers. 150. A hired hacker deliberately tampered with the commerce page of her web site on different occasions so web site patrons could not purchase items. No sooner than she would fix it under the direction of a Microsoft technician, than the hired hacker would tamper with the commerce page once again, which prevented customers from buying items. 151. Aisha's multi-million dollar catalog was illegally copied from her computer's hard drive at times she was online working - with works from this copyrighted catalog already appearing in numerous of Madonna's announced, planned, in production and released projects - prima facie evidence that Madonna is the culprit behind the hired hackings, as she is using works from Aisha's already copyrighted multi-million dollar catalog only available on the computers that were hacked and in the Library of Congress, which constitutes several felonies. 152. It is the equivalent of someone breaking into your office, stealing your original one of a kind designer clothes you designed and made, then you see them parading around on TV wearing them, which essentially Madonna has done in having costumes included in Aisha’s unpublished copyrighted music video treatments and fashionline made and she has worn them on her Drowned World Tour, Reinvention Tour, Defendant Motorola’s “Rokr” commercial and at Live 8). She is unquestionably in possession of Aisha's multi-million dollar music, film, literary, video and song catalog that she has been illegally making use of for her own works and selling to her entertainment industry partners and cronies, which is completely reprehensible and illegal. She has illegally obtained copies of Aisha's copyrighted works and has been putting them into production in violation of Aisha's copyright and rights (invasion of privacy, defraud, grand larceny, property theft, dealing in stolen goods). 153. Aisha has seen pics online of Madonna wearing the same items of clothes, jewelry, shoes and hats she did around Miami, only Madonna wore them after Aisha did, which says they have her under surveillance. 154. Aisha's web site logged close to 1,000 hits (site visits) from Madonna’s label Warner's web service in New York, where their headquarters are located, before this lawsuit was ever written up, printed on paper. 155. Aisha's web site logged 150 hits from Buena Vista/Disney's headquarters in Burbank before this lawsuit was ever printed on paper or told to anyone with Buena Vista/Disney listed as a Defendant. SEE EXHIBIT 56. 156. Madonna has attributed items from Aisha's copyrighted web site column Sound Off and online Diary to herself in her very public interviews word for word. Madonna foolishly and incriminatingly did this numerous times, as mentioned under the Copyright Infringement Right Of Attribution segment of this Complaint. 157. These facts are prima facie evidence that the Defendants know exactly who Aisha is and have been watching this prolific writer for a long time - within that time stealing her copyrighted works from her internet site in clear view of scores of internet visitors who wrote in and alerted Aisha to what Madonna had been doing to stealing her copyrighted catalog only housed on her personal computers and in the Library Of Congress in Washington, DC - which is a foul crime. 158. Said hacker caused extensive damage to Aisha's computers, destroying the operating system on two of them, and rerouting key components in the operating system of the master computer housing the bulk of the catalog to allow said hacker and Madonna to illegally obtain, copy and spy on Aisha's already copyrighted multi-million dollar valued catalog and any and all new projects Aisha was working on/authoring to add to the catalog on said computer system. Microsoft recently replaced and upgraded items on Aisha's computers, as they couldn't fix it through normal technical support means, as the damage was that extensive to her computer systems. 159. Aisha's computers are being actively hacked on a daily basis by the Defendants to steal the latest projects she is working on. An EarthLink tech support agent informed her over the phone that the reason she is unable to get online at times and her computers are slowing down is due to the fact that a hacker is attacking her firewall to get into the computer system to see what she’s got on her computers. 160. He was in fact correct, as the EarthLink service was working properly, but a closer inspection of her computer system revealed the hacking, keystroke recording and illegal invasion of privacy tools that have been placed on her computers. At times the hacker was able to completely disable her firewalls and anti-virus software via deleting key components causing them to malfunction while she was online, involuntarily shutdown, which allowed them criminal access. 161. Her email accounts have also been hacked, unauthorized parties have read emails, while other emails incriminating to the Defendants have been deleted by a hacker. 162. The Defendants conduct has caused Aisha a lot of inconvenience and lost work time, in addition to the wasted man-hours spent by techs at companies such as Microsoft, EarthLink, AVG, Zone Alarm and Go Daddy in combating these illegal hackings and destruction of Aisha's computer systems and web site. 163. It is grossly unfair and highly unethical that so many people have been put to so much inconvenience including Aisha, their products severely tested beyond reasonable means, their employees time spent on correcting and trying to combat an issue that is rooted in a vile, racketeering based, criminal case of invasion of privacy, grand theft larceny and corporate theft - prima facie evidence pointing to the Defendants guilt, particularly Madonna's, in that Aisha's already copyrighted works housed on her private computers and in the Library of Congress have been illegally surfacing in Madonna's work, which was a violation of many civil and criminal laws. 164. What Madonna did was the equivalent of going into someone's house and stealing their paintings that were registered with the copyright office, then showing them off to the world in her own home as her own paintings. Items stolen were used in their original context as Aisha authored and copyrighted them while others were willfully altered, but not so much that they were unrecognizable as Aisha's earlier copyrighted works. The altered items would be the art equivalent of painting a green dress on the Mona Lisa, to hide the theft. It would still be recognizable as the Mona Lisa. Changing small elements of it to customize it to your bad taste does not change the fact that it is stolen, legally belongs to someone else and visible apparent to the naked eye when the works are compared. 165. Madonna and her co-defendants unfairly caused disparagement to be cast on several products, however, the relentlessness with which the Defendants sought to steal Aisha's works knew no bounds and violated and corrupted computer programs and systems in their unmitigated, greed fueled drive to steal Aisha's multi-million dollar copyrighted catalog. 166. They caused several businesses such as Microsoft, Hewlett Packard Computers, Toshiba Computers, EarthLink Internet Services, People PC internet services, Grisoft AVG, Zone Alarm, Symantec, McAfee and Go Daddy and several other software manufacturers great inconvenience, man hours, replacement products, hundreds of hours in 800 and long distance number services, embarrassment and confusion. This on going conduct by the Defendants touched too many people's lives at these companies and Aisha's, in their campaign to steal Aisha's multi-million dollar catalog that they criminally gained access to, then destroyed 2 of the 3 computers that housed these works. However, Aisha had and has numerous time stamped backup copies and these items were already registered and stored in the Library Of Congress. 167. There were times that Aisha was online working with her anti-virus and firewall programs on and right before her eyes, they were hacked and shutdown by Madonna’s hired hacker who made a regular habit of hacking into her computers to illegally copy the new material she had been writing and recording. 168. The Defendants also illegal utilized programs like "KeySnatch" which Aisha recently found on her computer, to record all keystrokes (a keystroke is everything you type on your computer and the internet - including passwords) and all actions on Aisha's computers such as music recording, script writing, personal letters and legal documents. This illegal, underhanded tactic enabled them to make illegal copies of Aisha's copyrighted works, other works she was authoring, all internet research she was doing, every word she typed into a search engine, every site she visited, every article she wrote. 169. This also enabled them to tamper with Aisha's web site, as the KeySnatch program logs everything the computer owner types, including their passwords for web site accounts, email accounts and online bank accounts. Microsoft Windows technicians further detected trojans and illegal items in the registry of Aisha's computers used to criminally gain access to the contents of her computers. 170. This also enabled them to deface and destroy pages of Aisha's web site on several occasions, even going as far as tampering with the commerce store page of her web site. They had all her passwords for the web site due to the illegal means in which they planted programs like KeySnatch, which recorded all passwords and typed information. The general public is not aware of how easy it is for someone to illegally plant such programs on unsuspecting victims computers to spy on and steal personal and corporate documents. It is as easy as sending an email to the unwitting victim who opens it. 171. Aisha's site has received thousands of emails since it has been online. She does her best to keep up with her mail and the Defendants abused that to plant programs on her computers to invade her privacy and allow them access to her computer whenever she went online to work. This conduct was completely reprehensible and illegal violating several international laws. 172. The program can be configured to send daily or hourly updates of everything the unwitting computer owner types on their computer or into search engine or records (as Aisha does with music) to the felonious intruder. 173. Madonna and Victoria Newton, out of sheer arrogance, made a regular habit of illegally using the information they were unlawfully receiving from the programs like KeySnatch criminally placed on Aisha's computers to spy on her work and its progress, by publicly repeating and printing items from Aisha's upcoming Sound Off articles stored on her computer, days before they were published. 174. Madonna would repeat them in press interviews and Newton would print them in the Sun after having a sneak peek at them days before they were published via the illegal spyware and trojans that were deliberately planted on Aisha’s computers containing her copyrighted works. “KeySnatch” can be configured to send the hacker copies of the contents of an unwitting victims computer every 5 minutes, every hour, every day or every week. 175. Items Aisha searched for on the internet for her Sound Off Column was criminally used verbatim by the Defendants just as she had typed them into search engines. Using the illegal key logger information provided by KeySnatch, Victoria Newton rushed out her columns featuring the same things Aisha searched for, researched on the internet and written into her unpublished Sound Off Column, for use in her own daily column that she rushed out the illegally copied items ahead of Aisha's biweekly and now monthly Sound Off Column. Newton unethically, pathetically and perversely did this for months. 176. Additionally, Madonna used this means via a hired hacker, to steal Aisha's copyrighted multi-million dollar catalog, which she has illegally been using works from, violating Aisha's copyrights and several criminal invasion of privacy laws. 177. Madonna displays a sick, perverted, depraved fascination with violating people's privacy. She even inappropriately, sickly and perversely wrote about this in her children’s book “The English Roses” where she wrote about invading a girl’s privacy. Her new planned video for her forthcoming single “Hung Up” also incorporates “hidden cameras” something she sickly and perversely seems to be fond of in conduct that can only be described as depraved. HOME STUDIO BREAK IN178. Several of Madonna’s lawyer and his private investigator’s legal and journalistic enemies complained of burglaries and threats. Aisha’s home studio was broken into. SEE POLICE REPORT CONTAINED IN EXHIBIT 13. 179. On other occasions Aisha and her mother would notice items moved from where they had left them before they left the house for the day. They would ask each other about it, but at first didn't pay attention to what was happening, as they couldn't believe someone would be so foul as to enter their home without their permission. This coupled with the fact the items from their home, lives and Aisha’s business and personal telephone calls are featured in Madonna’s children’s book series and interviews is very disturbing. 180. Who has the right to be illegally going in and out of someone's home in order to spy on them, plant illegal surveillance equipment and rifle through their things. This is completely inexcusable by any standards. CAREER INTERFERENCE, SABOTAGE, TORTUOUS INTERFERENCE AND BLACKLISTING BY MADONNA AND THE MEDIA MONOPOLY WARNER/CONDE NASTE 181. Madonna began to unduly interfere with Aisha's career by not only stealing her copyrighted works, rushing out rip off versions and fraudulently passing them off as her own in the mainstream, she has also actively tried to kill the younger singer's career. Recently out of compassion for Aisha, she was informed by a very reliable, well connected source that Madonna and her reps had gone around telling entertainment industry outlets not to interview her, having her blacklisted in the industry, in an attempt to suppress the information regarding the disgraceful malfeasances she committed against Aisha from coming out in the mainstream media and in turn to the mainstream public. 182. This credible person tipped off Aisha to other scurrilous events that were happening behind the scenes at her expense. He told Aisha that Madonna had gone around the industry telling people not to interview under any circumstances in response to an article Aisha wrote and published to her web site on December 27, 2004 detailing the enormous amount of stealing Madonna had been doing from Aisha's copyrighted works. 183. This article generated much press interest, as evidenced by Aisha's site statistics detailing the members of the press who read the site, however Madonna did her best to have it stubbed out behind the scenes. This press blackout Madonna demanded also interfered with Aisha's career and newly released album. She has been publicly accused by other publications of using the “Warner PR Machine” to block out unflattering articles and damaging news about her terrible misconduct in other situations. LOST ENDORSEMENT DEAL AND LOSS OF WORK184. Aisha also mysteriously lost an endorsement deal that was on the table with guitar company Gibson. They promised to feature her on their web site, which they said gets 20 million hits per month and furnish her with their guitars for use in her music videos and promotional appearances as apart of the endorsement that would have garnered a lot of exposure for her as a musician SEE EXHIBIT 4 - however, with no explanation, they mysteriously backed out of the deal at the last minute, which Aisha was told by an industry source was Madonna's doing. 185. She also spoke to the Gibson reps about the endorsement deal they promised over the telephones that unbeknownst to her at the time was criminally tapped and communicated with them via email, which unbeknownst to her at the time had been and continues to be criminally hacked. 186. Madonna has actively tampered with Aisha's career in attempts to crush it and deprive her of the right to earn a living, in order to clear the way for her to further use more of Aisha's very lucrative copyrighted works that she is in unlawful possession of with no rights to under the law. No one has the right to deprive another of the right to earn a living, especially off of their own copyrighted music and literary works via going around the marketplace exercising undue influence and pressure over publications and businesses to destroy another person's career. It is unbecoming and a gross abuse of position and influence. According to United Nations laws, it is also illegal. MADONNA THREATENED BY THE PROSPECT OF AISHA BECOMING FAMOUS AND TAKING HER COPYRIGHTED WORK TO THE MAINSTREAM ALONG WITH THE STORY OF HER (MADONNA’S) UNPROVOKED, NEFARIOUS CONDUCT TOWARDS HER. 187. Madonna was so threatened by prospect of the younger singer becoming famous, as it would expose Madonna's misdeeds towards Aisha to the mainstream public and put an end to her criminally using the hacker obtained copy of the younger singer’s copyrighted catalog, that she did her very best to kill Aisha’s career. 188. As in the case of 50 Cent and Murder Inc, Madonna did everything in her power to thwart and impede Aisha’s career in an attempt to avoid that scenario with the aforementioned 50 Cent and Murder Inc happening to her at the public’s hands, and further free her to continue criminally selling and using items from Aisha’s copyrighted catalog without permission. 189. This behavior is characteristic of Madonna, as upon information and belief, it was reported on June 9, 2005 that she threatened ABC's "20/20" via her lawyers, stating, "She would never appear on the network again" if they continued with an uncomplimentary Kaballah feature for the widely watched show. The show went ahead, but she and fellow Kabbalahists Demi Moore, Ashton Kutcher, Paris Hilton and Britney Spears refused to appear on it, as it had individuals who viewed the Kaballah Center as a cult, a farce and a scam, speaking openly of their opposition to said cult and their legitimate reasons why. 190. Similar threats by Madonna happened previously regarding Aisha. As mentioned in preceding paragraphs, Aisha published a telling article on December 27, 2004 detailing Madonna's misconduct towards her in an attempt to publicly shame Madonna into stop stealing her copyrighted works. On December 27, 2004 and December 30, 2004, Aisha faxed and or emailed numerous newspapers and magazines such as The New York Post, New York Times and Rolling Stone, referring them to the article detailing Madonna's misconduct towards her (SEE EXHIBIT 45). 191. However, recently Aisha was told that under threat from Madonna's reps, the publications suppressed the story that would have brought Madonna's misconduct to light and spared Aisha and her family further privacy intrusions, thefts, terroristic threats, the assaults of Aisha this summer that would ensue, and the invasion of privacy that Madonna had been cruelly and perversely been inflicting upon them. Aisha found the papers actions unethical and cowardly - aiding and enabling Madonna and Time Warner in further misconduct without fear of public accountability and scrutiny for their disgusting, nefarious conduct in violation of U.S., Jamaican, British and United Nations Laws. So much for freedom of the press and truth and integrity in journalism. 192. There exists a pattern that illustrates when her inappropriate conduct is threatened with exposure, she issues threats through representatives to get the damning items squashed from coming out to the mainstream public, where her reps have carefully crafted an image that is in direct contradiction to the real Madonna, a dishonorable, thieving, greedy, ruthless, nefarious, violent individual. 193. As mentioned above, Madonna is a celebrity that has committed numerous offenses through out her career, but due to her wealth, much of it derived from copyright infringement and plagiarism, and her label, the media monopoly that is Warner Bros; much of it has been kept from the mainstream public to preserve her image. 195. Through careful research for this case, Aisha uncovered numerous lawsuits and criminal behavior by Madonna that was quieted down, covered up, paid off and kept from the mainstream. Madonna is a celebrity given to violent behavior, evidence by the fact that she choked two people on two separate occasions, one of them a 10 year old boy. 196. Madonna and co went around the industry cowardly getting Aisha blacklisted, rather than face the music regarding her shameful, disgraceful, abhorrent conduct. She has done her level best to destroy Aisha's career to hide her misconduct towards her and to clear the way to further use Aisha's copyrighted multi-million dollar catalog. 197. They didn't even want Aisha earning an income, as they tampered with her web site's store page and got her dropped from a Gibson endorsement deal that was on the table. Aisha earning a sizable income would further mean her being able to afford the hundreds of thousands it would take to hire a law firm to sue them for the criminal way they have been stealing from and using copyrighted works from her multi-million dollar valued catalog. 198. Madonna has proven via her actions, over and over again that she is a lawless, reckless human being with no respect for the law or other people's rights and well being. From choking a 10 year old to choking an adult, to invading Aisha's privacy to criminally stealing her copyrighted catalog and actually having the criminal gall to put these works into production, painfully illustrates her abhorrent nature and absolute disregard for Federal and United Nations laws, which is absolutely criminal. 199. The Defendants illegally and criminally hacked and used Aisha's personal computers containing her already copyrighted works, as a type of criminal, unauthorized P2P system, the very type of misconduct they complain of regarding kids on the internet illegally downloading their music and films, and stole substantial amounts of Aisha's copyrighted multi-million dollar catalog, having the sheer nerve to criminally put Aisha's copyrighted works into production under different names at their own companies, which constitutes several felonies of the highest order. 200. It was done with clear intent, sheer arrogance, organization and planning to commit these crimes. It was despicable and underhanded, warranting the greatest legal condemnation, as there was no excuse or necessity for it. These were civil and criminal crimes motivated by sheer greed and envy at the prolific, valuable catalog this young woman had amassed through over 20 years of her blood, sweat, tears and labor. The only just punishment for such conduct is for the defendants to forfeit years of their own freedom in jail and pay back every penny they wrongfully made off of criminally stealing Aisha's copyrighted works (that took her years of her own life to author) then criminally putting them into production, re-copyrighting them in their own names and companies with different titles. 201. Madonna has referred to herself as someone who doesn’t take no for an answer. When she doesn’t get what she wants she clearly takes it, even if it breaks civil and criminal Federal and United Nations laws. 202. Aisha’s site clearly marked that she (Aisha) wished for her works to remain on her label and did not wish to work with outside artists not on the label. Madonna reading this, decided to steal Aisha’s released copyrighted works from her web site in plain view of the public who complained to Aisha - and later criminally stole her unreleased copyrighted works as well from her catalog, which was a vile violation of domestic and international law. This was in addition to violating Aisha and her family's privacy in 3 countries, when they criminally put Aisha’s under 24 hour surveillance, deliberate misconduct by Madonna worthy of imprisonment. MADONNA HACKER TRIES TO BLOCK AISHAMUSIC.COM’S COMMERCE PAGE TO PREVENT SALES 203. In further attempts to thwart Aisha's career, a hacker made a habit of tampering with the commerce "store page" of Aisha's web site www.aishamusic.com in attempts to block anyone from purchasing items from it, which is a serious crime. This has been a serious problem for Aisha. Buttons, links and pages directing Aisha's site visitors to the commerce page where they can purchase items such as her CDs and digital downloads of her music, has been tampered with and removed by a hacker on different occasions, which prevented customers from purchasing items. 204. From the first day the commerce page went online, a nefarious person who didn't want Aisha to earn any money off of her copyrighted music works made a regular habit of tampering with the page to block sales. This same individual deleted emails from her email accounts connected with her site that were incriminating to the Defendants. MADONNA REFUSES TO STOP CRIMINALLY STEALING FROM AND CRIMINALLY USING AISHA’S COPYRIGHTED MULTI-MILLION DOLLAR CATALOG. 205. There are already strong indicators that Madonna has once again illegally used more material from Aisha's pilfered copyrighted catalog and released 21 track debut CD "Aisha" for her forth coming fall album "Confessions on a Dance Floor." Aisha copyrighted a hook for a song she titled song called “The Dance Floor” way before Madonna chose this title as her new album’s name. 206. She is even sickly releasing the album “Confessions On A Dance Floor” on Aisha’s birthday of November 8, 2005 - see amazon.com release date EXHIBIT 89. Last year she also released her Kabbalah children’s book “The Adventures Of Abdi” on Aisha’s birthday last as well. It was written in several articles that Madonna believes in astrology and that certain signs and people’s birthdays will bring her good luck. Two years in a row she has exhibited this same sick, obsessive pattern regarding Aisha and her birthday. 207. Madonna had already changed course with the direction of her forthcoming album in another illegal attempt to rip off Aisha's album that was released on December 27, 2004. On November 29, 2004, Madonna announced through her mouthpiece Victoria Newton in the Sun Newspaper that her new album would be "trip-hop" SEE EXHIBIT 5. One month later Aisha released her album on December 27, 2004. Then, weeks later, Madonna announced through Newton that her album has changed and is now rock oriented with rock guitar - which is the exact type of record Aisha had released on December 27, 2004 SEE EXHIBIT 6. 208. That was a major change for Madonna in a matter of weeks; in a style of music she has never done, rock - the very same type of record Aisha had just released. This coupled with the fact that Madonna is in unlawful possession of Aisha's multi-million dollar catalog and is releasing items from it as her own, infringing Aisha's copyright, says there is great cause for concern that Madonna is planning to completely rip off Aisha's record that was released on December 27, 2004, as she did with Aisha’s song “Contemporary Girl” two years ago, further infringing more of Aisha's copyrights. This unlawful conduct must desist. It is illegal, criminal and unethical. 209. Already her new single “Hung Up” from her forthcoming album has infringed lyrics and music from Aisha’s December 2004 released CD and items from her unpublished copyrighted catalog in the Library Of Congress and on her personal computers. This song is illegally featured in Defendant Motorola’s “Rockr” commercials and on their official web site, constituting several counts of copyright infringement, criminal copyright infringement, fraud, corporate theft, invasion of privacy, grand larceny and plagiarism. 210. Files on Aisha's computers containing copyrighted works were mysteriously deleted from her hard drive while she was online, as though the hacker thought deleting them from the computer meant erasing any evidence of it existing and belonging to Aisha, allowing them to freely and fraudulent take credit for it. However, Aisha retained copies of her work in various formats, had previously copyrighted them before the internet intruder deleted them, therefore was able to put them back and her rights and international copyrights still stand. HARASSMENT AND TERRORISTIC THREATS BY MADONNA’S WARNER BROS AFFILIATED MIAMI ATTORNEY DAVID BERCUSON 210. Aisha has been vilely harassed, bullied and threatened via terroristic styled threats, by local Warner Bros affiliated attorney David Bercuson, the label for which Madonna records, in a disgraceful attempt to terrify Aisha out of filing this lawsuit, thereby suing Madonna for all the crimes she's committed against her. Aisha filed a complaint against Defendant Bercuson with the Florida Bar, which is detailed, further in this Complaint. MADONNA’S BROTHER GETS IN ON THE ACT OF STEALING FROM AISHA’S PRIVATE COPYRIGHTED MULTI-MILLION DOLLAR CATALOG 211. Madonna has not only imitated and ripped off Aisha's every business move in the entertainment industry, she even went as far as to imitate Aisha's every business move in non-industry ventures. Madonna has roped in her brother Defendant Christopher Ciccone in her unlawful conduct, who upon information and belief has been privy to and seen pilfered copyrighted documents and business plans that were illegally copied from Aisha's computers by a hired hacker. Christopher Ciccone in conjunction with his sister, Madonna, has already used two of Aisha's copyrighted business plans they pilfered from her personal computers. 212. Two weeks after Aisha made the web site for a business she plans to start, a real estate company and web site for it she copyrighted, named "Son Real Estate Investment Corp" and "Son Realty" on the computer which Madonna has been paying a hacker to steal her copyrighted works from, and after Aisha spoke with her mom about the venture in the privacy of their home, Madonna placed an article in the press stating her brother has just gotten work renovating the Fortune Realty offices at 1300 Brickell Avenue in Miami, the same city and exact same line of work Aisha was venturing into - renovating buildings and homes in Miami. SEE EXHIBIT 7. 213. This is not the first time Christopher Ciccone and Madonna have surreptitiously ripped off one of Aisha's copyrighted business plans. In November of 2002 Aisha wrote in her copyrighted online Diary that she was starting a restaurant with her mom and that she'd just registered the name. The name she registered on November 1, 2002 is “The Continents” SEE EXHIBIT 8. The name Madonna and her brother later chose for their restaurant is “The Central,” a restaurant that was later located at 8590 Sunset Blvd, West Hollywood, CA 90064 - the first four letters being the same as the name Aisha's chose and registered for her restaurant business plan. The Ciccone's "The Central" restaurant failed miserably in less than a year and is now out of business. 214. The Ciccone's conduct reflects they are a greedy, lascivious, characterless, thieving family who will steal anything to make a quick buck, irrespective of others rights and well being. To steal two of Aisha's copyrighted business plans in a row and utilize them is greedy and despicable - conduct indicative of common thieves. Christopher Ciccone is also a member of the Kaballah cult that his sister is a principal of. A cult that is known for devious, thieving, unethical behavior that has been well publicized and written about. MADONNA’S BEHAVIOR CONTINUES TO GROW OUT OF CONTROL215. Madonna's behavior towards Aisha is a serious item of concern. It has grown more and more bizarre and the Plaintiff and her family are concerned as to what her disgraceful, obsessive conduct will evolve into next. The terrible malfeasances, from the invasion of privacy and harassment to the theft of copyrighted works via stealing from her widely viewed web site and further hacking her personal computers, tapping her phones and repeating verbatim the things that happened in the privacy of their own home, was willful, sick, premeditated, perverse and malicious, showing signs of someone whose behavior is escalating from one criminal deed to the next. She has perversely gotten into so many areas of Aisha's life and business that it is alarming and cause for serious concern. There is absolutely no justification for Madonna's abhorrent, depraved conduct. MADONNA RIPS OFF AISHA’S DEBUT 216. Madonna has had a commercially successful 20 year career, albeit one which was based on filth, theft and fraud, yet had absolutely no qualms in stealing the debut of a very hard working independent artist, that used the little she had at the time to author an astonishing body of work. 217. Aisha was minding her own business doing the music and film works she loves. She never once asked any label for a record or production deal. She kept to herself with the intent of building her company from the ground up as an independent label. However, Madonna and Time Warner, criminally targeted, exploited, robbed and invaded Aisha’s privacy out of sheer greed and jealousy in an attempt to destroy a very bright, promising singer/writer/director who has authored and performed stunning, ground breaking works unlike anything the industry had ever seen before. 218. Realizing the potential of what was to come from Aisha and he precedent setting works, Madonna’s notorious, widely written about ego took over and would have none of it. She proceeded to covetously steal substantial amounts of copyrighted works from Aisha, taking it to the masses, before Aisha had a chance introduce herself and her works to the mainstream public, thereby firmly establishing her innovative works and inventive style as her own. MADONNA USES HER FAME TO CRIMINALLY EXPLOIT AISHA’S COPYRIGHTS 219. It is a known fact in the music industry that to establish a new artist in the mainstream public requires time to record an album of multiple recordings, not just a debut song, and promotional items such as interviews, touring and substantial airplay. Madonna used this to her advantage and stole numerous amounts of Aisha’s copyrighted works which include, music, lyrics, photos, photo treatments, articles, ideas, scripts, a music video treatment and fashion line, film scripts and a book manuscript then quickly introduced them to her already established mainstream audience of 20 years, as her own creations, when they never were. An unlawful habit she has engaged in at other artists expense as well. 220. Madonna has made millions off of debauched pornographic music and movies, and can afford to hire writers to pen material for her, but she, Time Warner and the co-defendants deviously and abhorrently opt to steal from Aisha, an independent writer she felt at the time was an unknown, therefore she could get away with the blatant thefts, claiming all the writer’s credit and millions in profits for herself. It is an unethical practice that the Defendants engaged in at Aisha's expense, which essentially amounted to stealing the Plaintiff's life’s work, due to the voluminous amount of work that was stolen and continues to criminally be stolen by the Defendants. MADONNA DELIBERATELY STEALS FROM AISHA’S COPYRIGHTS HUNDREDS OF TIMES 221. Aisha has suffered irreparable harm, loss of privacy, damage and financial loss as a direct result of Madonna and her co-defendants’ willfully abhorrent conduct. You don’t steal everything from copyrighted music to lyrics to movies to photos to articles to movie scripts in over 200 incidences, from the same writer, Aisha, and unlawfully duplicate them for your own projects, by accident or coincidence. The malfeasance committed by the Defendants is as willful as it gets. They relied on her wealth and fame to prey on a humble indie author. 222. The evidence is not circumstantial, as this Complaint and its accompanying exhibits will clearly show. So much was taken and duplicated that the infringements are painfully clear and disgraceful. It is a clear case of copying copyrighted intellectual property, which is completely unlawful, not to mention the manner in which some of it was pilfered, is criminal. 223. The Defendants refuse to play by the rules and obey the law, which has resulted in great loss to the Plaintiff, who only sought to build up an indie company that the Goliath-like Defendants sought to exploit and destroy. MADONNA ARRANGES WITH WRITERS TO BLOCK AISHA’S FORMAL PUBLISHING LICENSE REQUEST SO SHE COULD FURTHER COMMIT CORPORATE THEFT OF AISHA’S IDEAS AND MUSIC 224. Aisha applied through Wixen Music Publishing in Los Angeles for permission (license) to remake a Richard Marx song, who she had been a fan of growing up. Wixen rejected the mechanical license request, which left Aisha puzzled as Mr. Marx had granted clearance to a variety of artists to remake his work. She tried to eliminate all possible scenarios as to what transpired. 225. While the main receptionist was nice to Aisha, Wixen’s representative handling the license request, the nasty, arrogant, insolent Elissa Klein, was thoroughly rude to Aisha for absolutely no reason. She looked for every reason she could find under the sun for rejecting Aisha’s formal, written request. She even called Aisha and was very insolent with her over the phone regarding her application for absolutely no reason. 226. Ms. Klein acted as though she was doing Aisha a favor and somehow had her over the barrel with the mechanical license request, when it was nothing of the sort, as Aisha owns a 6,000 song catalog (that Madonna has been criminally using) and only asked to remake Mr. Marx’s song out of sentiment not necessity. 227. Aisha could not make sense of this highly inappropriate level of nastiness for no apparent reason, when she had been polite, complimentary and respectful in her formal written request - and then the rejection of the license when Marx had granted licenses to indie artists and mainstream artists with less vocal ability than Aisha. 228. She knew it wasn’t because she is black or a Christian as one of his late dear friends, the vocally gifted Luther Vandross, was black and it is well known that his mother is an Evangelist. And for someone Aisha had spoken well of, even prayed for him and his family, she did not understand the unprovoked nasty treatment from Mr. Marx’s representative at Wixen or the declination of the mechanical license request by him. 229. However, an industry insider told Aisha what happened behind the scenes. He told her that Madonna is 5 minutes away from pulling a license for the same song remake from Richard Marx, that Aisha had applied for and tinkered around with a new version of the song, recording it on her computer - the computer that was hacked by the hacker Madonna hired to make an illegal copy of Aisha’s catalog that she, Madonna, had begun criminally using and selling off items from to her cronies, colleagues and partners. 230. That same industry insider who felt sympathy for Aisha, as he heard about what was going on, also pointed her in the direction of a Madonna sponsored article featuring Richard Marx’s long time band member, co-writer and friend Bruce Gaitsch. In an interview arranged by Madonna’s management, Mr. Gaitsch slammed Madonna detractors in what eerily resembled a response to a Sound Off Column article Aisha had just written and published, which slammed Madonna about the same topic Mr. Gaitsch later spoke about in his Madonna interview. 231. Mr. Gaitsch should have known there was something behind it, as he had not worked with Madonna in many years and had not been asked to do anything for her for a long time. He was being used due to his tie with Mr. Marx, who Aisha had spoken of liking his work and what she thought he stood for as a former indie artist, whose struggle to get his music to the mainstream was well documented. 232. Bruce Gaitsch slammed Madonna detractors and tellingly said something that was a clear response to what Aisha had written about Madonna in an article in her Sound Off Column. Like clockwork, Madonna would mysteriously arrange for musicians and writers to refute things Aisha had written in her popular Column. The refutations were done in such detail that it was clear it was in response to things Aisha had written, copyrighted and published to her widely read web site. 233. Examples of this can be readily citied and proven via Aisha’s site and the subsequent Madonna related articles, like the one featuring Bruce Gaitsch on a Madonna site that she and her management frequently give exclusives. Madonna knew Aisha was tinkering around with that Richard Marx song on her computer, albeit a hacked computer unbeknownst to her at the time, and used her influence to get Aisha’s mechanical license request rejected, so she could use it. Just like she’s been stealing Aisha’s other copyrighted works. 234. It must be noted, while Mr. Marx has the right to decline any license request, as Aisha has the right to decline any request for usage of any and all of the 6,000 songs and other literary and music material in her own copyrighted catalog, Aisha did add one of her own musical compositions (beat), new harmonies and new lyrics to the remake of Mr. Marx’s song she tinkered around with on her computer. 235. In the event Madonna continues with her criminal spree of corporate theft and criminal copyright infringement at Aisha’s expense and uses the music, harmonies and or lyrics Aisha added to the remake that was only on her computer as a test recording to see what it would sound like with the changes (copyrighted changes that do not involve nor were inspired by Mr. Marx’s work), additional criminal charges and an additional lawsuit will be filed against her and anyone who uses the original material belonging to Aisha. 236. Aisha had applied for another unrelated mechanical license from another publishing company, but at the time of this filing the results from it had not come in yet to determine if Madonna used her undue influence to tamper with that as well. If there are any infringements of Aisha’s original material in regards to these mechanical requests, that Madonna was made privy to via invasion of privacy, additional criminal charges and an additional lawsuit will be filed against her and anyone who uses the original material belonging to Aisha. It will also be reported to the FBI. MADONNA MADE OVER TO LOOK LIKE AISHA’S MOTHER237. In a sick twist to Madonna's repugnant conduct, Madonna participated in a Cafedirect Flight 5065 campaign to boost fair trade. This generated publicity for the 47-year-old singer, via an artist rendering of Madonna as a black person. However rather than looking like Alivera Kilza, the person whose image was purportedly mixed with Madonna's to create the pic, or even using a digitally altered pic of Madonna with black skin, the pics look like an old pic of Aisha's mother SEE EXHIBIT 15, a former model and Miss Jamaica Nation Beauty Pageant runner up. Considering Aisha’s mother looks like neither Kilza nor Madonna, how did this sick incident happen. The minute Aisha saw the picture she remembered an old pic of her mom the Cafedirect alleged rendering looked like. 238. One of Madonna's most disgusting and repugnant incidents of misconduct is in regards to Aisha's deceased brother Norman. On his way home from playing soccer, he noticed a child had fallen in the sea and was being pulled under by the tide. Of the people who had gathered, no one was going in the water, but Aisha's brother, being the selfless person he was, dived in, in an attempt to save the child. They were both pulled under by the tide. When rescue workers arrived and were able to pull them out, they were taken to the hospital and shortly after pronounced dead. They had both drowned. 239. This has been a very difficult tragedy for Aisha's family and to this day, Aisha and her father frequently talk about it over the phone. Madonna, Liz Rosenberg, Victoria Newton and other employees at the Sun perversely listened into these very private conversations as well. Madonna went as far as to sickly name her 2001 world tour "Drowned." A tour for which she even wore a costume design she stole from Aisha's copyrighted video treatment "Contemporary Girl," SEE EXHIBIT 37, with the video treatment having been registered with the Library Of Congress in 2001 (registration no PAu2-587-556), 6 months before Madonna's "Drowned" world tour began. 240. No one should have to endure their privacy being invaded in such a horrible manner and having the contents of their calls spat in their face in such a vile manner. They've invaded her privacy and terrorized her in a reprehensible manner that is completely inexcusable and abhorrent. MADONNA MORPHS INTO CHARACTER FROM AISHA’S COMPUTER241. Aisha has been a fan of the show “To The Manor Born” for many years. She recorded it from the TV years ago on a time stamped VCR. Then later when it became available for sale online, ordered an official set of all the episodes. She watches these tapes regularly. Aisha jokingly and affectionately calls her mother “her ladyship” when she (her mother) gives her a verbal list of things to do (the lead character in the show is notorious for doing that - giving instructions/lists of things to do). Her mother jokingly in return says she (Aisha) looks like "a valet." Aisha wrote detailed filming instructions on her computer in a copyrighted Microsoft WordPad text file for filming at the manor home used for the show To The Manor Born. 242. This idea and treatment was stored in Aisha’s pilfered copyrighted catalog on her computer (which was hacked and illegally copied) along with HTML and photo files of the manor house used for the show. Aisha scripted an original video and pictures for it with original material. Madonna later stole the idea from Aisha's copyrighted catalog, opting to have a filmed photo shoot at her British manor home instead and eerily and creepily morphing into the lead character from the show To The Manor Born, Mrs. Audrey fforbes Hamilton, for the shoot. 243. This drew much laughter and snickering in the British press, who immediately recognized Madonna's new clothes, hairstyle, attitude and demeanor to be that of the beloved British character "Audrey fforbes Hamilton" from the show. 244. In light of the fact that Aisha copyrighted a video to be shot there and the fact that Madonna has said repeatedly in numerous TV and print interviews to journalists like Matt Lauer that she “does not watch TV,” it is more prima facie evidence that she got the idea from the hacker procured copy of Aisha’s copyrighted catalog that she has been criminally using - with said catalog having referred to the show and filming at the home, used for said sitcom 20 years ago. 245. How else did she get the idea to morph into the character and more incriminatingly film at a manor home dressed and coiffed just like the character Audrey fforbes Hamilton- when Aisha's copyrighted catalog contained a video treatment of the exact same idea, with the exact same character for a show that's been off the air for almost 20 years on TV that Madonna vehemently stated numerous times, even this summer, that she does not watch (TV). Once again, those are too many illegal duplications and similarities to Aisha’s already copyrighted multi-million dollar valued catalog that Madonna is in criminal possession of. 246. Madonna, even more tellingly used items from one of the storylines from “To The Manor Born” about a special bird visiting the estate (Episode 17). Aisha has watched this episode in her home numerous times and knows it quite well. For Madonna’s July 2005 Vogue cover story featuring her posing on a horse she clearly could not ride and dressed and coiffed exactly like the character from the show, Audrey fforbes Hamilton, Madonna spoke of a special bird visiting her at the estate. 247. Sadly, Madonna's re-invention into Audrey fforbes Hamilton ended in tragedy as she unadvisedly and in this case, accidentally, acted out Episode 11 where the "pretend" lord of the manor on the show was thrown from his horse due to the fact that he pretended he knew how to ride when he did not and was subsequently thrown from said steed. 248. Madonna unadvisedly rode a thoroughbred after only a few lessons of horse riding, which is a big no no (The Mirror UK did an article published in July of 2005 before the accident, which reported she had just begun taking lessons that month). She was thrown from a thoroughbred on her birthday and broke several bones with the horse reportedly, additionally stepping on her hand. 249. When Aisha saw the July 2005 issue of vogue and realized Madonna had sickly morphed into one of her (Aisha’s) favorite TV characters and used the idea from her copyrighted catalog to film at the TV’s shows manor home as a tribute to the show, she was appalled and creeped out - much like the British press were derisively commenting on the clear, distinct similarities to the character Audrey fforbes Hamilton that Madonna pretended to be unaware of - a project idea Madonna stole from Aisha's copyrighted catalog. 250. Madonna has been in a mad race to use Aisha’s copyrighted works before she, Aisha, gets the opportunity and time to put all of her vast catalog into production, actions by Madonna which are completely criminal, as she never should have had access to Aisha’s Federally and internationally protected copyrighted catalog in the first place. A catalog that she procured a digital copy of via a hired hacker and went on to criminally sell off and use items from in criminal violation of numerous domestic and international laws. 251. When you write a movie or video script and copyright it, it can lay in the Library of Congress with copyright protection and under the United Nation's protection for years before you actually shoot it as a film or music video. Madonna has sickly been taking Aisha’s lyrics, music, video, book and movie scripts already in the Library of Congress in an unpublished, private catalog and has been criminally putting them into production by recording, filming and publishing them. She has criminally gained millions from this dirty, underhanded illegal practice she has been engaging in at Aisha’s expense in flagrant violation of U.S. and U.N. laws that protected Aisha’s works before Madonna ever criminally used them. 252. She additionally ripped off previously copyrighted text and jokes from Aisha’s web site for the Vogue 2005 article. THE DEFENDANTS VISITS TO AISHA’S WEB SITE253. Aisha's web site has registered hundreds of hits from Defendants Buena Vista/Disney's offices in Burbank, from Time Warner's internet service in Manhattan (New York) and numerous Madonna fan sites. Two of these fan sites are in constant contact with Madonna's manager, publicist and label Warner Bros, as illustrated by comments they made to that effect and exclusives on their web sites. Both Madonna's manager and publicist have provided them with inside information on many occasions, and they in turn kept them abreast of fan issues. These sites send Aisha hundred of hits in site referrals and inappropriate, threatening emails, two of those emails containing viruses and self destructing emails that auto-delete and wipe out email boxes once you close them. This was a criminal act of data tampering and is included in a report to the FBI. MADONNA’S PENCHANT FOR VIOLENCE, CHOKING AND PROPERTY THEFT254. Due to this vile, collusive campaign to terrorize and exploit Aisha, and sabotage her career, she is concerned that Madonna and her co-defendants conduct will escalate into commissioned violence against herself and her family. These concerns are due to Madonna's increasingly obsessive, unlawful, intrusive conduct towards Aisha - and Madonna's disgraceful view that violence is a means to get rid of problems you don't want. 255. Upon information and belief, it was reported that Madonna inexcusably threw 10-year-old Keith Sorrentino of Staten Island, New York, against a wall and choked him, because he sought an autograph when she wasn't in the mood to sign it, as it was her day off SEE EXHIBIT 9. It was reported his family initiated litigation against Madonna for choking and “beating up” their 10 year old boy, who suffered physical damage and long term emotional damage like nightmares and bedwetting as a result of the assault. Madonna quietly settled the suit for a reported $600,000. 256. On another occasion Madonna choked Dick Clarke’s son Rac, who was the stage manager at the Oscar's, for not letting her rehearse due to the fact that there was a seriously injured crewmember that had fallen several feet from above and landed on the stage SEE EXHIBIT 10. As they waited anxiously for paramedics, it was reported a nasty, callous Madonna said regarding her rehearsal “Can’t we just do this. She’s just lying there.” When he refused she launched into an astonishingly profane tirade in the presence of a children’s choir. The incident, unprovoked, escalated into Madonna choking Rac Clark. 257. Madonna has already commissioned an illegal surveillance campaign of Aisha that has also violated her family’s privacy via wiretaps, stalking, hacking and illegal filming and recording that has terribly invaded Aisha's privacy and defrauded her via corporate theft, therefore a horrible pattern of illegal commissioned conduct exists in this case. History has shown that people who have resorted to such illegal tactics to get what they want or to get rid of problems they don’t want, irrespective of the law, showed no restraint in commissioning further illegal activity when their shameful deeds were found out, reported to the authorities and made public. MADONNA AND BERT FIELDS 258. The most serious item of concern is the fact that Madonna and the Kaballah Center's lawyer Defendant Bert Fields is, and at all times mentioned herein was, a partner in Greenberg Glusker, a Los Angeles, California based law firm, has been at the center of an FBI probe regarding wiretapping done by his private investigator Anthony Pellicano as mentioned above. 259. It was reported that the FBI informed Sylvester Stallone that his phone had been tapped by Bert Field’s private investigator in a "case (that) pitted Stallone against his former business manager Kenneth Starr, who was represented by Bert Fields." Drudge Report - SEE EXHIBIT 11. Comedian Gary Shandling, Court TV's Diane Diamond and L.A. Times writer Anita Busch were among rivals of Bert Fields' famous clients who publicly stated their phones had been tapped by Fields' investigator, Anthony Pellicano, as private calls were being made public in a deceitful manner, as Bert Fields' client Madonna (also lawyer of Jerry Bruckheimer's late partner Don Simpson) are now doing to Aisha and her family via the Sun Newspaper and CSI:Miami. 260. On June 10, 2005 the 9th U.S. Circuit Court of Appeals, ruled that prosecutors could comb through transcripts of wiretaps found in Anthony Pellicano's office. Upon information and belief the Federal probe began due to LA Times writer Anita Busch reportedly being harassed and threatened by Pellicano to stop her from writing a story in the newspaper about one of his famous clients. Busch said she received threatening telephone messages - local Warner Bros affiliated attorney David Bercuson similarly threatened Aisha over the phone. 261. L.A. Times journalist Anita Busch said she was almost run down by two men in a car - Aisha has also experienced similar incidents on the streets of downtown Miami and at the main intersection near her home. Anita Busch's computer hard drive was destroyed - Aisha's computer's hard drive was illegally copied, tampered with then damaged on several occasions, by a hacker who was actively copying her multi-million dollar unpublished copyrighted catalog and works stored on her computer, unbeknownst to her - with works from the illegally copied catalog now illegally surfacing in Madonna's and her partners and colleagues new and announced releases. Incriminating evidence Aisha had been collecting for this case regarding Madonna and the hired hacker were deleted from the hard drive by the hacker, however, Aisha had back up copies of the evidence on burned discs. 262. Another of Aisha's computers, her laptop, sustained major damage at the hands of an internet intruder who illegally access the laptop's hard drive and deleted files vital to windows causing the computer to shut down for months. Aisha's laptop is the system on which she had been writing scathing articles about Madonna and several scripts that were quickly copyrighted. A third computer owned by Aisha, which she used for internet research, was also attacked by an internet hacker who planted viruses on it to destroy all of her Windows WordPad documents. 263. This year when she discovered that the Defendants were using a hacker to commit corporate theft to steal her works, all Aisha had to do was log on to the internet, pages like www.google.com or www.msn.com and someone would send a virus to her computer/ip address, which the anti-virus program would alert her to. They did this via ip tracking and the illegal recording and tracking programs they placed on her computer that immediately renews themselves and sends a copy of all the new information the computer user typed and worked on. Madonna via a hired hacker has been hell bent on getting into her computers to see and steal the latest projects she had been working on - with Aisha's copyrighted works later illegally surfacing in Madonna's projects. 264. Aisha has also been harassed and terrorized in the same manner Anita Busch and others have been, several of whom legally and or literarily opposed Bert Field’s famous clients. 265. It was reported the FBI found the equivalent of 4 billion pages of wiretap transcripts in Pellicano's office. Several public figures have publicly gone on record, complaining that they believe Madonna's lawyer Bert Fields used Pellicano to tap their telephones. Victims who threatened to sue Bert Fields' famous clients reported they were victimized, their lives threatened, homes and cars burglarized and their telephones tapped. 266. Another victim, Court TV's Diane Diamond, reported, "My words were coming back to me through others." She was referring to items she said in confidence over the telephone SEE EXHIBIT 12. This has also happened to Aisha. Madonna, like a deranged parrot, has publicly repeated things Aisha said over the phone and in the privacy of her own, verbatim, in very publicly interviews the 47 year old pop singer has done, which were viewed by millions, even as recently as this June. Madonna has done this numerous times, as mentioned further in this Complaint. Strangers also approached Aisha in public repeating things to her she had said over the phone and in the privacy of her own home. 267. Aisha experienced the same things as the other victims after declaring on her widely read web site that she is going to sue Madonna for stealing her copyrighted works. Madonna, Liz Rosenberg and Victoria Newton foolishly and incriminatingly began repeating verbatim items Aisha had said over the telephone during personal and business calls, much like Diane Diamond complained of, regarding other of Bert Fields' famous clients. A pattern exists here of misconduct. 268. Several public figures are complaining of being wiretapped by Bert Fields. He has denied any misconduct, however, his main private investigator is incarcerated and was found with billions of pages of illegal wiretap transcripts. 269. Defendant Bert Fields was quoted recently in a New York Times article, as saying he, didn't use any of the information from the illegal wiretaps. It was a well-worded statement. However, did he commission the wiretaps and did he read or listen to the contents thereof. Was he privy to them. 270. Regardless, people like Diane Diamond have complained that he tapped her phone and her words said over the phone were being repeated to her verbatim by others - which is exactly what has been happening to Aisha by Bert Fields' client Madonna in a parrot like manner. 271. Like others victims of Bert Fields' famous clients, shortly after she publicly announced she would sue Madonna for stealing her copyrighted works, Aisha was the victim of: 272. A home recording studio burglary attempt. SEE EXHIBIT 13. The first burglary for Aisha in her 28 years. 273. A vile case of identity theft where malice was the goal, not financial gain, which she reported to the bank and the Federal Trade Commission. SEE EXHIBIT 14. 274. She was terroristically threatened by local Warner affiliated attorney David Bercuson, which is detailed further in this Complaint. 275. Most tellingly her telephone was tapped with items said in confidence during private business calls, personal calls and business faxes publicly utilized by Madonna, Liz Rosenberg and their disgraceful mouthpiece, tabloid journalist Victoria Newton of the Sun Newspaper UK, all attributed to them in the press, rather than the true source, Aisha. Other times they were utilized by Madonna's partner Jerry Bruckheimer for his show CSI:Miami, all detailed further in this Complaint. 276. Her computers were hacked with previously copyrighted unpublished works utilized by Madonna, Maverick Records, Maverick Films, Warner Bros Records, Warner Bros, Buena Vista (Time Warner owned), Victoria Newton and the Sun Newspaper for pieces mostly focused on Madonna to enhance her image in the mainstream press. Madonna and her hired cohorts, mentioned further in this Complaint, were terrorizing Aisha. 277. Aisha has been harassed on the streets and in stores by people who kept coming up to her repeating things to her verbatim - things she'd said over the phone in confidence and in her home. 278. Almost hit by cars on different occasions while crossing streets in Miami near her home and in the business district she visits every week to tend to items concerning her work. 279. Aisha was assaulted on her way to a Miami Court house via a method of assault Madonna has a penchant for - choking. 280. Her mail was being intercepted and tampered with, arriving blatantly opened. Reported to Postmaster. 281. None of these things had ever happened to Aisha before, and in such rapid succession, until shortly after she publicly declared on her web site that she is going to sue Bert Fields' famous client Madonna - then the harassment and terrorization began in spades. 282. The Defendants have shown a complete disregard for civil and criminal law, both domestic and international, in exploiting and terrorizing a law abiding citizen with no criminal record or history of questionable behavior, acting as though they are above the law due to their celebrity. They have behaved as though the law does not apply to them, which makes them a danger to society. 283. Anyone who can so easily toss U.S., British, Jamaican and United Nations laws aside and cruelly harass, terrorize, exploit, rob and perversely invade the privacy of a young woman, Aisha, in such a vile manner, trampling on her rights as a citizen and a human being as recognized by the United Nations, is absolutely corrupt. If fact, such conduct reeks of organized corruption. There are criminal organizations that utilize the same illegal tactics against innocent citizens. 284. Madonna and her co-defendants are out of control and a danger to Aisha, a victim of their civil and criminal crimes, and anyone who seeks to legally defend their rights against the Defendants' unlawful conduct. They have a history of misconduct that shows they have no respect for the law or citizen's rights; clearly illustrating they are a danger to society. 285. At no time did Aisha contact Madonna or wish to do business with her, as she deplores her work due to the fact that she lacks talent and demeans women. However, that did not stop Madonna, who began to flat-out steal copious amounts of Aisha's copyrighted works and invade her privacy. 286. Madonna's undue, stalker-like presence is a disturbing, harassing, unwelcome presence in Aisha's life and that of her family that she legally wishes to be rid of and has filed this action as a step in doing so. Madonna's invasive, intrusive presence in Aisha's life is unwarranted, claustrophobic and encumbering. No sooner than Aisha puts out work do Madonna and her co-defendants unlawfully infringe the copyrights thereof. 287. Aisha's wishes to be free to live and do her work as she sees fit without having to worry about the vain, narsisstic, overly ambitious, neurotically competitive Madonna, intrusively and unlawfully watching and illegally copying her every move and every copyrighted work. It is unreasonable and unconstitutional. No one should have to live and work under such terrible, unlawful circumstances. 288. Aisha wishes to be free to pick up her telephone and use it without having to be concerned about lawless people listening in on the other end and pilfering her phone calls and faxes for corporate theft. Aisha wishes to be free to use the internet without lawless people tracking her every move and stealing her ideas and works from her computers. Aisha wishes to check her bank statements and financial data over the phone and online without lawless people listening in and recording her transactions, invading her privacy. 289. Aisha wishes to discuss family members health, medical records and well being with them over the phone without lawless people listening in and invading her privacy and that of her family members. People's medical records are private and no thieving pop singer should be privy to them via wiretapping and fraud. 290. These things Aisha wishes for are her constitutional rights as a U.S. citizen and international right as a human being as recognized by the United Nations, but Madonna and her co-defendants have perversely and unlawfully robbed her of these sacred rights in a most disgraceful, disgusting, menacing way that there is absolutely no justification for. 291. A person's home is their sanctuary and no one has the right to invade that as Madonna and her co-defendants have done to Aisha for financial gain and critical acclaim. Such conduct is illegal and depraved. No one should have to endure that, but Aisha was made to endure that due to Madonna and her co-defendants repugnant conduct. 292. The disgraceful defendants, namely Madonna, listened to private family talks with her parents, who were recovering from illness. Private moments Aisha spent reminiscing with her dad about her childhood and hopes for the future, talking to her little sister encouraging the bright young teenager in her plans for the future, providing her godbrother with support and encouragement for his exams and sporting event qualifiers, speaking to medical professionals about her parents health and medical records, were all perversely and inappropriately listened to by Madonna and her co-defendants. 293. There was no necessity for any of this to have happened. The Defendants who are already wealthy in their own right did it with the worst of intent. Aisha understands that people sometimes have financial difficulties, as she herself went through that when repairing and restoring an old home that she affectionately dubbed “The Money Pit” after the 80’s film of the same name, due to the amount of unrevealed things that was wrong with it. 294. However, Madonna has the ability to hire writers and producers, rather than steal other people’s works which she constantly does and has been sued for many times. Madonna has the ability to pay her creditors, but has been worming out of paying debts to creditors because she feels she can get away with it. She wormed out of paying $350,000 in fees for a documentary Hamilton Hamish shot on her behalf and paid for her expenses in advance with the agreement that he would be reimbursed later. She never did and he had to file suit after she repeatedly ignored his requests for payment of said debt. 295. A duo loaned Madonna’s Maverick Films $100,000 that she defaulted on - yet gives her daughter a $10,000 credit card, takes expensive vacations and buys high priced items written about in the press on a constant basis with pictures to match of said purchases. Said duo filed suit against Madonna and Maverick Films in New Jersey. 296. Madonna has clearly exhibited she has no respect for other people's labor or income. She so cruelly stole copious amounts of Aisha's copyrighted works, criminally reaping millions off it and continues to steal and illegally use Aisha's copyrighted catalog valued at millions that she, Madonna, criminally gained a copy of through commissioned hacking and invasion of privacy. 297. Madonna is a woman who simply does not care about others, their well being or finances - as long as she gets what she wants, everyone else can be defrauded out of income and or property (copyrights), mistreated, assaulted and put to great inconvenience. This conduct is positively criminal. 298. The information contained in Aisha’s unreleased private multi-million dollar valued catalog and other computers were private. It was unpublished copyrighted works that they had no business viewing, let alone stealing and putting into production. It was a despicable, premeditated, underhanded crime. MADONNA THE KLEPTOMANIAC299. Madonna has defrauded many writers by deliberately stealing their copyrighted works to fund her overly lavish and overly indulgent lifestyle. Madonna admitted and bragged in July 2005 in Vogue that she stole money from a cash register to fund her first trip to London right before she became famous. Madonna arrogantly and unremorsefully stated, "I used to rob the register blind." She's been robbing people for a very long time in acts of civil and criminal theft, worthy of imprisonment. Madonna is in fact, a kleptomaniac, who has shown time and time again that she will steal anything for financial gain irrespective of the law. COPYRIGHT OFFICE AGENT300. Adding to Aisha's concerns, this year when she called the Copyright Office to ask them about their privacy rules regarding copyrighted materials, a Copyright Office agent at the Library Of Congress told her that they only release copies of copyrighted works when there is a potential lawsuit or litigation. Still ill at ease with the leak of her copyrighted work that was now surfacing in Madonna's projects, Aisha called the Copyright office again in April of 2005 about a July 6, 2004 copyright registration for which the certificate had not been sent to her yet, though the Post Office tracking system displayed a message stating the Library Of Congress had received it almost a year prior. 301. On April 18, 2005 Aisha spoke to Copyright Office agent Robert "Bob" Blankenburg, who'd flagged one of Aisha's numerous copyrights "AISHA WORK 5," one of the main ones Madonna had infringed for the forthcoming Maverick Film "Material Girls," and did not send her a notice stating he had flagged the copyright submission, regardless of the fact that after 120 days the Copyright would have expired leaving Madonna to claim it as her own though she had stolen it from Aisha whose original registration was the earliest. 302. Mr. Blakenburg oddly began lecturing Aisha over the telephone regarding lawsuits and copyrights. He told her she "can't sue Warner Bros," (when she never told him Warner was the company she was going to sue - he brought it up on his own). He then stated an example of a lawsuit involving Warner Bros and the film the Maltese Falcon - and how Warner supposedly won said lawsuit where they "remade the Maltese Falcon without permission." He told her people were free to use her copyrighted works as you "can only copyright a portrayal" not the "idea" "characters" or "script." Aisha looked up the case the next day and Mr. Blakenburg either intentionally or unintentionally quoted the facts surrounding the case incorrectly. 303. As stated above, Warner Bros is the label Madonna records for, which made Aisha suspicious of Mr. Blakenburg's motives for, firstly, flagging her copyrighted work submission that was sent certified mail with an additional poor man's copyright sent to herself, not sending her any notice of what he had done, which could have caused her rights to expire and Madonna to get away with illegal conduct, when it goes against Library Of Congress rules and procedures, and secondly, bringing up the very company, Warner Bros, that Aisha was about to sue in regards to Madonna, who has been greedily stealing her copyrighted works in manner worthy of prosecution. 304. Mr. Blakenburg further tried to deny a portion of Aisha's Copyright registration under suspicious circumstances and verbally attacked her over the phone. He accused her of "embellishing the copyright." Aisha told him "I did not and how do you embellish a copyright anyway?" When she asked him how and what he meant by that he did not answer. 305. Aisha tried not to think the worst, however, in light of the corporate theft of her works by Madonna and her co-defendants, then Mr. Blakenburg's questionable conduct, it was a very difficult thing to do. Aisha reported this incident to his supervisor Lara Lee Fischer via letter and telephone, detailing her concerns and questions, as what Mr. Blakenburg had told her was in diametric opposition to everything she'd read about Copyrights and it was the first time in 14 years of Copyrighting that she did not receive a correspondence from their office, as Mr. Blakenburg failed to do SEE EXHIBIT 16. 305. Mr. Blakenburg acted very inappropriately towards Aisha. His negligence almost cost Aisha a multi-million dollar copyright that is rightfully hers, that Madonna illegally made use of for the forthcoming Maverick Film “Material Girls” months after it was sent in for registration with the Library of Congress. 306. Madonna later criminally re-copyrighted Aisha’s already copyrighted work in hers and Maverick's name months after Aisha's original copyright submission was sent in to the Library of Congress. Aisha has a poor mans copyright of that Copyright registration that she mailed to herself, along with mailing and money order receipts and letters from the Copyright office confirming the dates the registration was received. Aisha also burns her work to time stamp discs immediately after she creates them to prove the date of authorship. 307. The agents at the Copyright Office are usually organized, prompt, courteous, efficient and knowledgeable. In the 14 years Aisha has been copyrighting, she has never had a problem with any of the agents at the Copyright Office. However, Mr. Blakenburg, right off the bat was nasty and had a conspiratorial tone and stance in withholding Aisha's copyright. His supervisor, Ms. Fischer, apologized for it and said she would issue the long over due Copyright certificate to Aisha’s works that had wrongfully expired thanks to Mr. Blakenburg’s conduct. Works that Madonna greedily re-copyrighted when she thought Aisha had lost all rights to it. 308. Aisha registered a book called "Beautiful Inspirations" On June 3, 2005 sent certified mail to the Library Of Congress SEE EXHIBIT 31 - the manuscript contains advice, quotes, inspirational anecdotes and advice on health and beauty along with layout instructions for pictures. One week later on June 9, 2005 Madonna announced a new book she is working on and wants to release titled "Madonna's Inspirations" SEE EXHIBIT 32 which is a complete rip off of Aisha's previously written Copyright submission "Beautiful Inspirations." Madonna's rip off is set for release on September 1, 2005, SEE EXHIBIT 30, through Defendant Andrews McMeel Publishing, who does her yearly calendar. 309. Aisha's new registration submitted to the Copyright Office was infringed approximately one week after Aisha sent it in to the Library Of Congress for copyrighting. Madonna clearly obtained access to the registration and compromised and violated another of Aisha's copyrights once again. Madonna is now rushing to put out the fraudulent rip off version of Aisha's book manuscript that she stole from the indie singer to beat Aisha's to the punch in releasing her own work, which is utterly despicable. 310. Defendant Time Warner is, and at all times mentioned herein was, a Delaware corporation that is the parent company of Madonna's Maverick, Warner Bros Records (who Madonna records for and ripped off Aisha's 2001 song "Contemporary Girl" for her 2003 "American Life" song and numerous other items listed further in this complaint), Jerry Bruckheimer Films (who Madonna's Maverick is partnered with in Z Films - and passed illegal surveillances tapes of Aisha's home life to, was utilized for the show CSI:Miami, with the show's writers further infringing Aisha's copyright from her Sound Off Column for said show). 311. Warner Chappell Music, through whom Madonna and Maverick further exploited Aisha's already copyrighted music to gain huge royalty payments in sheet music and ASCAP fees. Madonna herself further stole additional items from Aisha and put them into production at Maverick Films, namely the movie "Material Girls." However, Maverick Films is not owned by Time Warner - but by Madonna and Guy Oseary. 312. Defendants Warner Bros and Warner Bros Records is, and at all times herein mentioned was, a Delaware Corporation with offices in Santa Monica, New York and Miami. 313. Time Warner is a media monopolizing, multi-national conglomerate who have been frequently sued for copyright infringement (see detailed list of lawsuits listed further in this action). Time Warner AOL was also recently sued and fined $300,000,000 by the S.E.C. for accounting scams and dishonest trade practices that defrauded consumers SEE EXHIBIT 20. They are the recording label for Defendant Madonna, who have greatly profited from her stealing Aisha's copyrighted works. Madonna has an extensive, sordid history of copyright infringement, that Warner is aware of, having been named as a co-defendant several times in plagiarism and copyright infringement lawsuits against her, but continually looks the other way in favor of huge profits they've reaped from the illegal conduct. 314. They knew of and participated in the cruel, unlawful conduct Madonna spearheaded, orchestrated and has been committing against Aisha, but deliberately went along with it for financial gain, enabling her to terrorize and rob a law abiding citizen, as they too shared in the profits of her pillaging and plundering Aisha's vast copyrighted works. Madonna and her employer Time Warner and their subsidiaries illegally shared Aisha's copyrighted works amongst themselves putting them into production for projects that have grossed a few hundred million dollars in sales. The Defendants Madonna, Buena Vista, Jerry Bruckheimer and their parent company Warner Bros/Time Warner have a long, sordid history of copyright infringement and plagiarism, evidenced by numerous lawsuits and settlements thereof against them, detailed further in this action. 315. Warner Bros recently sold Warner Bros Records to an outside group of investors lead by Edgar Bronfman Jr., of New York, however the infringements occurred under both their watches and continues to occur under the new Warner Bros Records label that retains its old management and most of it's employees, for which Defendant Madonna records and continues to steal Aisha's copyrighted works for. Warner Bros records are still tied to Time Warner AOL and appear on their web site. 316. Defendant Warner Chappell Music is, and at all times herein mentioned was, a music publishing subsidiary of Warner Bros Records, who administers the rights to Defendant Webo Girl Music Publishing SEE EXHIBIT 21, who is, and at all times herein mentioned a artist owned music publishing company owned by Defendant Madonna. Both Warner Chappell Music and Webo Girl Music Publishing unlawfully misappropriated the rights to Aisha's "Contemporary Girl" in collecting huge royalties for the rip off "American Life," which infringes Aisha's copyrights. Defendant Madonna has further ripped off more of Aisha’s released and unreleased copyrighted works for her new single “Hung Up” also registered with ASCAP. 317. Defendant Buena Vista Pictures is, and at all times herein mentioned was, the Los Angeles based film company owned by Disney, who infringed Aisha's copyright for the film "The Princess Diaries 2." In dire need of a follow up to their first hit "The Princess Diaries," Buena Vista stole Aisha's copyrighted scripts and synopsis about a British Royal family and used it heavily in the creation of the script for the "Princess Diaries 2." The source of access was Madonna who has criminal possession of Aisha’s copyrighted multi-million dollar valued catalog that she sold Aisha’s script to her longtime friend, collaborator and employer Gary Marshall, who is the director of the “Princess Diaries 2.” The shocking, blatant infringement regarding this film is listed in full detail further in this Complaint. 318. Buena Vista's head office in Burbank has registered numerous hits to Aisha's web site, therefore they know exactly who she is, as does Time Warner who registered hits to her site as well according to site statistics. 319. Under Michael Eisner, Disney has violated the copyrights of many independent writers to the tune of millions. One of their worst violation - all while pushing the image of a family company at Disney - came by way of the copyrighted indie film they stole from Royce Mathew and made into the billion dollar rip off "The Pirates Of the Caribbean." 320. Eisner was shamefully and unceremoniously forced to retire this year due to his questionable conduct. However, Aisha is very concerned that the same arrogant, lawless attitude with which they illegally obtained her private unpublished copyrighted works via invasion of privacy (Madonna - who has done work with Disney) they will continue to arrogantly, insidiously and illegally put more of her copyrighted works they stole into production under the Buena Vista/Disney moniker irrespective of her copyright certificates stating her ownership of the work. Disney has illustrated time and time again that they have no respect for the law, copyrights, privacy laws, UN laws and people's well being. Profits come before ethics at Disney, where the latter just does not exist. 321. Aisha is angry, furious, outraged and grossly offended beyond words that one of her literary works that she treasured so, that is essentially about her ancestry, essentially apart of her, was illegally stolen via invasion of privacy and put into production at Buena Vista/Disney, by human scum. This script meant so much to Aisha as it is apart of who she is as a person coming from British lineage. This story is now gone and no amount of money will ever compensate for what Buena/Vista Disney has done. Aisha has described their behavior as "slimy, underhanded, damnable and lascivious." She has now become their most vocally outspoken opponent calling for a boycott of their products, as with the rest of the Defendants who so underhandedly and disgracefully stole her work like a group of common thieves. 322. There exists a barbaric, ignorant, deprave attitude in Hollywood that one is allowed to rob and steal another man's life's work at any cost and irrespective of what they have to do to get it. It is an attitude very unbecoming and classified with the worst of human kind that fails to acknowledge, observe and respect the rights of others. However, it is the law in Hollywood that many boast of. 333. Gary Marshall is, and at all times herein mentioned was, the Los Angeles based director and co-creator of the script for the "Princess Diaries 2." Gary Marshall, brother of Penny Marshall, is a friend and co-star of Madonna (League Of Their Own - 1992). Marshall even makes reference to his pal in his other works - such as the line "I wonder who thought up sex in the first place and the other character in “The Other Sister” responding "I think it was Madonna.” 334. Marshall also included Madonna's work in her then husband's film he directed, titled “At Close Range” (Live To Tell). It was written that Marshall commissioned the song from Madonna and Pat Leonard in 1986. Madonna was to be included in his forthcoming flick "Chicken Little" but was removed from the production at the last minute. Madonna and Marshall are long time friends and co-workers for the past 20 years, with him having employed her before. 335. Madonna and Marshall flat out stole Aisha's copyrighted work "The Royal Monarchy" and made it into the "Princess Diaries 2," which grossed over $100,000,000 at the box office. 336. Madonna illegally sold Aisha's already copyrighted script to Marshall, without Aisha's permission, that she (Madonna) stole from Aisha's copyrighted multi-million dollar catalog. Marshall was aware of how the script was pilfered as he and his co-writers erased Aisha's name from the script and etched in their own for what criminally became "The Princess Diaries 2." Aisha's original works were written before the Princess Diaries. 337. Aisha's copyrighted works were actively shared among and sold to other people by Madonna who obtained huge fees for works that were already copyrighted and never belonged to her. Works that were obtained by the Defendants via breaking federal law. 338. Meg Cabot, Gina Wendkos and Shonda Rhimes are, and at all times mentioned were, the writers of the copyright infringing script "The Princess Diaries 2." Shonda Rhimes has co-written copyright infringing scripts two times in a row. First “Crossroads” starring Britney Spears and now “The Princess Diaries 2.” “Crossroads” is the subject of another Federal lawsuit for copyright infringement where the writer wrote and submitted the script long before “Crossroads” was made or released. Shonda Rhimes is clearly Hollywood’s go to girl to tweak and rewrite copyrighted scripts that do not belong to the studios, which is an act worthy of imprisonment. Shonda's last two scripts are at the center of serious copyright infringement lawsuits. 339. Defendant Mark Morgan is, and at all times herein mentioned was, the Los Angeles based C.E.O. of Maverick Films, co-owned by Defendants Madonna and Defendant Guy Oseary. Mark Morgan overseas the day-to-day operations of Maverick Films and actively works on its projects, receiving points (royalties) on said films and producer's credit. Morgan is listed as a principal for the copyright infringing film "Material Girls," which ripped off Aisha's copyrighted unpublished work. 340. Defendant Mr. Morgan is also currently named as a Defendant in a sexual harassment and wrongful dismissal lawsuit brought by Yale Osteric, former Maverick Films v.p., where he has been accused of publicly reprimanding the Plaintiff Yale Osteric for being "uptight" in not wanting to engage in talks about sex, tweaking female employees nipples, inquiring about her past sexual relationships and accusing her of having slept with three men at a well known Hollywood talent agency. Defendants Madonna and Guy Oseary have also been sued in that lawsuit for knowing about, but refusing to do anything about Mr. Morgan's conduct even when it was reported to the companies management who told her she was "being insecure." 341. Defendant Madonna acquired million dollar advances and signing fees in Hollywood for Aisha's copyrighted works that she pilfered from her computers via commissioned invasion of privacy, then fraudulently passed off as her own. The proceeds from Madonna's theft of Aisha's works were shared with Maverick principals Oseary and Morgan, who get points (royalties) in the company projects. 342. Aisha announced on her site in 2001 that she was starting a film company, as she had written so many scripts and script synopsises since the age of 15. That very year, Madonna and Guy Oseary started and registered Maverick Films with the Spy Kids knock off "Agent Cody Banks" (SEE EXHIBIT 19). Madonna and her staff have been preying on and watching Aisha's every business move for quite some time. 343. Their cohort, friend and co-defendant Victoria Newton would read Aisha's posts on the message board of English singer Craig David, who she has interviewed and included in her column many times during her leadership of the Bizarre section of the Sun Newspaper and her former boss and tabloid collaborator, Dominic Mohan did as well. Aisha, posting under a pseudonym with her friends, was the most known internet poster on that message board due to her vast knowledge of music. Ms. Newton was a frequent visitor to Mr. David's site in search of the latest news. Aisha's link was posted on the site by fellow posters, which is how Ms. Newton first landed on Aisha's web site when it launched. Ms. Newton has known about Aisha since 1999. Mr. David is mentioned further in this Complaint. 344. Madonna is no stranger to lawsuits for stealing other people's film projects. A serious lawsuit was brought against Madonna by filmmaker Vincent D' Onofrio for stealing his movie remake proposal he pitched to her several times in the presence of said singer and her agent SEE EXHIBIT 25. Madonna greedily cut him out of the deal stealing his remake project he pitched to her instead remaking the film with her husband Guy Ritchie using Vincent D’Onofrio’s ideas. 345. However, the film went on to become the biggest box office and critical bomb in film history. It's categorical, unequivocal failure, sent shudders down the spine of Hollywood, who have since refused Madonna and Guy Ritchie's film projects. 346. Other directors such as John Schlesinger have complained about Madonna trying to take over their film sets and rewrite their scripts. All of the films she was publicly accused in print of doing this to have failed miserably, even though the directors had past successes in other films without her - even winning an Oscar for previous works. 347. Defendant Guy Oseary is, and at all times herein mentioned was, the CEO of the Los Angeles based entertainment company Defendant Maverick Records and Maverick Films. Maverick Records is co-owned by Defendant Warner Bros. Defendant Madonna was a partner in Maverick Records until 2004 and during the time the malfeasances were being committed against Aisha. However, Madonna retains part ownership of Maverick Films, which has begun ripping off Aisha's copyrighted unpublished works for films like "Material Girls" and others named further in this action. 348. In the 90's Madonna booted established industry executive Fred Demann, Michael Jackson's manager, who many credit with making her an international star, in favor of the younger, less experienced Oseary. The company suffered massive losses to the tune of $72,000,000 shortly thereafter and continues to struggle to stay afloat, prompting illegal behavior by Madonna, such as stealing numerous copyright holding artists' works and putting them into production at Maverick (see Madonna's long sordid History of Plagiarism and Copyright Infringement outlined further in this Complaint). This conduct is grossly unlawful. 349. Madonna chooses and obtains material for the company, while Oseary oversees the day-to-day operations, produces numerous films for said company and is a partner in Maverick. Oseary is listed as a principal for the copyright infringing film "Material Girls," which was ripped off from Aisha's copyrighted unpublished works. 350. Defendants Patriot Films and Patriot Advisors is, and at all times herein mentioned was, a small film company headed by Defendant Michael Mendelsohn, both listed as producers and financiers of the forthcoming film "Material Girls" which infringes Aisha's copyrights. The film "Material Girls" stars Hillary and Haylie Duff. 351. Defendant Arclight Films is, and at all times herein mentioned was, a Australia based film distributor, that has signed contracts to distribute the copyright infringing film "Material Girls" on a worldwide basis. 352. Defendant Martha Coolidge is, and at all times herein mentioned was, a Los Angeles, California based director, who utilized two of Aisha's copyrighted unpublished scripts and synopsises for the last two feature films she directed, "The Price and Me" commissioned and distributed by Defendant Lion's Gate Films, a Los Angeles corporation, and the forthcoming Madonna produced "Material Girls." Martha Coolidge's copyright and authorship dates all bare dates later than Aisha's, which reveals a clear case of intellectual property theft by invasion of privacy. Coolidge is a friend and employee of Madonna. 353. Defendant John Quaintance, Susan Jensen, Jessica O'Toole and Amy Rardin are, and at all times herein mentioned was, screenplay writers who are listed as authors of the copyright infringing script that rips off Aisha's copyrighted synopsises, for the forthcoming Maverick film "Material Girls." 354. Charles Howard, Sunil Nayar, Steven Maeda, Michael Ostrowski, Corey Miller, ildy Modrovich, Brian Davidson and Marc Dube are, and at all times herein mentioned was, writers for the television show CSI: Miami, which is produced by Defendant Warner Bros and Defendant Jerry Bruckheimer Films. 355. As mentioned previously in this Complaint, invasive, illegal items not limited to, tapes of Aisha's telephone conversations have unlawfully been shared with staff of the show CSI:Miami, who are employed by Jerry Bruckheimer and Warner Bros, Madonna's label, who wrote items from her calls and things she'd said and done in her house into scripts for the show. They further plagiarized Aisha's web site, with items from her site being used for show plots and dialogue after she published them to the site and copyrighted the contents. Things Aisha said over the phone appeared verbatim as dialogue on later episodes of the show, which is also filmed in Miami, Aisha's hometown of the last 20 years. 356. Mr. Bruckheimer is a friend of Madonna's, who has partnered with her in a business venture SEE EXHIBIT 39, and knows several principals at Warner Bros, who distributes his show CSI:Miami. Aisha made reference to the show on her site's Sound Off Column and over the phone, as she has watched the program for two years - and shortly after Madonna put them up to terrorizing Aisha via the show by including items from the contents of the illegal surveillance campaign she had commissioned, as she had already done using Victoria Newton and the Sun Newspaper, who also infringed Aisha's copyright. Madonna is a sick, perverted individual who is a danger to society. 357. Jerry Bruckheimer made an announcement 6 weeks after Aisha copyrighted a second edition of a script in May of 2005, which she had already copyrighted earlier versions of in 2003 and 2004, that contained items and script instructions from some of Aisha’s already registered copyrights for a particular film trilogy. The instructions were to film back to back and at the same time, which is commonly not done. In trying to save time Aisha decided this way this best, albeit much more difficult, method to complete her wholly authored and original copyrighted film trilogy. 358. Six weeks later, In June 2005 Mr. Bruckheimer announced verbatim just as Aisha had written it in the copyright that he too would be filming back to back and at the same time for two film sequels that he was sued for stealing the first episode of, "The Pirates of The Caribbean." Mr. Bruckheimer is clearly in possession of Aisha's works and private files and is illegally utilize them for his own ends. Bruckheimer has never done this before. It really isn't done at all to "film back to back and at the same time." Movies are filmed and treated separately. Not at the same time. However Aisha had a vision for a special film trilogy and copyrighted three versions of it, each containing new updates to the script, beginning in 2002. 359. Aisha is concerned in that indicators are pointing to the fact that Mr. Bruckheimer, Madonna’s partner, has unauthorized access to her work and in light of what he did in stealing the already copyrighted works of Royce Matthew (Mathew vs. Jerry Bruckheimer Films/Disney) and making it into the copyright infringing film "The Pirate Of The Caribbean" she is concerned, he will do the same to her by stealing from her treasure trove of copyrighted film scripts and synopsises that have not been released yet, but from which his partner in JBT internet films, Madonna has already criminally stolen from and illegally put into production as “Material Girls” and various other infringing projects. 360. Mr. Bruckheimer’s partner was the late notorious Don Simpson, who was also represented by Madonna's lawyer Bert Fields, as is Mr. Bruckheimer and the Kabbalah Cult. Mr. Simpson had lawsuits and allegations leveled against him for harassment and tapping an employee's phone through Bert Fields' private investigator Anthony Pellicano. Mr. Bruckheimer's partner Don Simpson was publicly accused of beating prostitutes and forcing them to drink out of a toilet while he urinated in it. Mr. Simpson reportedly had a $60,000 a month drug habit. A doctor was found dead at his home - the cause reportedly being a drug overdose. 361. Jerry Bruckheimer is a man who can’t make a film without an explosive. A pillar of filth, Bruckheimer said in an interview regarding his film Kangaroo Jack: Interviewer: did you have to learn how to make a PG movie? Bruckheimer: ...mothers got very upset when they said "ass," so three "as*es came out. It didn't hurt the movie, but the mothers didn't want their kids to hear that." 362. Bruckheimer is a vindictive, unethical man with a Napoleon complex, who uses his shows to terrorize, harass and defame enemies in the industry and people he dislikes. He has done this to Aisha as a form of harassment and done this to others as well like Harvey Weinstein, the top indie producer in the industry. Jerry Bruckheimer's show CSI:NY sent out a nasty casting call notice that read as such: 363. MELVIN GREEN - Guest star/MALE/40 to 49's NY's biggest indie film producer. Think Harvey Weinstein. He has a weight problem, can't stop eating. He's found dead and assumed murdered, as everyone he knows hates him. 364. This was to demoralize and humiliate Weinstein via Bruckheimer's show, as they did to Aisha using CSI:Miami, by including items from Bruckheimer’s partner Madonna's illegally commissioned and conducted 24 hour a day surveillance campaign of Aisha. They were using her released and unreleased private copyrighted works and hated the fact she had the nerve to publicly speak out against them for it. 365. They perversely and illegally did this to punish her, while taking their invasion of privacy campaign that much further in disseminating items from her calls, home and daily life in Miami, on the show. It was a sick, perverse thing to do that warrants the strongest legal reprimand available. The U.S., Jamaican and British governments along with the United Nations did not enact privacy laws for perverts like Madonna and Bruckheimer to so vilely break them. 366. Defendant Victoria Newton is, and at all times herein mentioned was, a lawsuit prone tabloid journalist for the London based tabloid the Sun Newspaper, with its parent company being the London based News Group Newspapers LTD. The Sun Newspaper is widely distributed in England, with daily circulation reportedly in the millions and on a slightly smaller scale in America through nationwide outlets like Barnes and Noble, Borders and Walden Books. Victoria Newton is a resident of London, England, who also commutes to America for tabloid pieces, as illustrated by her distasteful articles and features such as "Monday Moron" and "Sack The Stylist,” that slate celebrates when she herself ironically sports an Elvira look year round. Defendant Newton is a friend, confidant and email buddy of Madonna (SEE EXHIBIT 40). 367. Defendant The Sun Newspaper is, and at all times herein mentioned was, a lawsuit prone tabloid newspaper of the worst order, based in London, England, whose editor is Defendant Graham Dudman. The Sun Newspaper is no stranger to allegations of gross misconduct that often arrogantly and smugly ventures into illegal territory. They have been sued countless times for violating people's rights and printing defamatory stories with no basis in reality, which were concocted to sell the trashy rag. They have invaded Aisha's privacy in conjunction with Madonna and violated several of her copyrights for financial gain. They unlawfully helped themselves to a number of Aisha’s published and unpublished copyrighted works. 368. Ms. Newton was aware and privy to every facet of the illegal surveillance campaign of Aisha's home commissioned by Madonna, taking it upon herself to print items from the contents of the illegal surveillance in the newspaper of all places - as was Mr. Bruckheimer, who in turn placed items from the illegal surveillance on his show CSI that the Defendants knew from Aisha's web writings and phone conversations that she regularly watched. This was absolutely depraved and perverted but goes to show the type of people they are. 369. The Sun UK printed several items from Aisha’s copyrighted diet book as diet tips in Defendant Nicki Waterman's column. 370. They stole a shirt from Aisha’s unreleased private fashionline that is apart of her copyrighted catalog and made it into a pornographic sports feature. Aisha’s shirt was titled “Soccer Chick” and the Sun used the British slang translation for the shirt and made it into “Footie Chick” asking members of the public to send in lewd pictures of themselves to become The Sun’s “Footie Chick.” 371. These were acts of corporate theft, computer fraud, unlawful entry into a computer, hacking and invasion of privacy. 372. The Sun is a tabloid with real newspaper aspirations that continually misleads the public by printing the most unfit, libelous drivel, only suitable for lining animal cages and as toilet paper in primitive societies. 373. They were even sued by The Queen for copyright infringement. That says it all. They showed absolutely no qualms about infringing the copyrights of the nation's Monarch, which testifies to their utter lack of respect for copyright law and the law in general. 374. Actress Nicole Kidman also initiated litigation against them for libel, lying and misrepresentation when Defendant Victoria Newton defamed her in said newspaper with a slur regarding her co-star Jude Law. Kidman received an acknowledged financial settlement to compensate for Newton mudding her reputation. 375. Britney Spears also sued Defendant Newton and newspaper for libel and lying when they deliberately misrepresented facts that defamed her to millions of people. 376. Defendant Victoria Newton was also recently forced to issue a public apology for libeling and defaming well-known British singer Robbie Williams in her column Bizarre. 377. Said newspaper was forced to issue and apology and pay damages to international soccer player, Kieron Dyer, for libel and defamation in implicating him in print in the rape of a minor. 378. Said newspaper was sued in conjunction with their sister newspaper the New York Post by Cameron Diaz, who said they libeled and defamed her in an article, labeling her an adulterer. Cameron won a substantial settlement and the paper issued an apology for lying about Ms. Diaz. 379. The Sun, owned by co-defendant News Group Newspapers LTD, has a long history of questionable, libel-laden journalism. Recently, as a publicity stunt, they drove a van through one of the Queen's official residences that was to hold the wedding of Prince Charles and Camilla, and placed a box with the word "bomb" written on it, filming the whole spectacle for TV and their sensationalized article that appeared in their newspaper shortly thereafter. 380. It was an irresponsible, imbecilic, dangerous stunt that could have resulted in serious harm to members of the public - not to mention giving unbalanced people ideas. It was done for publicity and not out of concern for the public’s safety. The Sun's intention was to embarrass the monarchy, the government and the police, while getting a sensationalized story for their disgraceful trash peddling rag, which is the scourge of British journalism. The UK is known for great newspapers with superlative reporting - a standard that The Sun has muddied and lowered on countless occasions since its regrettable inception. 381. Recently, the Sun obtained pictures of imprisoned dictator Saddam Hussein in his underwear doing his laundry, which many wondered how they got unprecedented, invasive, illegal access to said dictator to take of the pics of the former Iraqi Prime Minister who is being held in a high security prison SEE EXHIBIT 22. In the pics, Hussein seems to be unaware that he is being photographed, which indicates that it was done surreptitiously by an unauthorized party SEE EXHIBIT 23. They invaded the privacy of Hussein in obtaining and publishing the authentic pictures of him in a state of undress, which raised many questions in the world press and military. 382. Their bragging about the pictures amounted to trumpeting breaking the law. Rather than shut their mouths and be contrite about breaking the law, their incredibly imbecilic staff bragged about the pics in the world press, showing no remorse for violating numerous United Nations and British laws. Editor Graham Dudman inadvertently admitted through his braggadocio that they had broken invasion of privacy laws and the Geneva Convention SEE EXHIBIT 24. No newspaper or entity has the right to do that. The Sun is not above the law or the United Nations. 383. A master of stating the obvious, Dudman's poor excuse for their unlawful, invasive conduct was that Hussein is a bad man. While Hussein has committed horrible atrocities, no one has the right to break the law as the Sun Newspaper UK did in flagrantly and willfully breaking British and United Nations laws, making themselves criminals as well. The law just does not matter to them. 384. Following Mr. Dudman's unlawful line of reasoning that bad people deserve to have their human rights violated, what was the Sun's excuse along with Madonna’s for violating Aisha's human rights and civil liberties and that of her family by plundering her unpublished multi-million valued copyrighted works protected by Jamaica, U.S. and United Nations laws, by hacking then printing excerpts of her telephone calls and the unpublished copyrighted contents of her private catalog and computer in the Sun Newspaper for millions of people to read without permission. 385. What was the Sun’s excuse for constantly and deliberately stealing copyrighted items from Aisha’s widely read, publicly viewed web site, for illegal, plagiaristic use in the Sun UK for millions to read, but attributed to Madonna, Victoria Newton and several of their other copyright infringing writers who did not author the content. 386. Aisha is a law-abiding citizen with no criminal record or history of misconduct. She comes from a family who has been devoted to numerous charities for years of which they give their time for free and their money. Following that tradition, Aisha has given to numerous charities, even out of her allowance as a teen. She generously donates great items to charity, even at times when it didn't grant a tax break. She runs a web site with free services to help the public that 99% of web companies would charge for due to its high quality content. People have told her she should charge for some of those web services, but she hasn't, as her goal is to help people. This is the same web site (www.aishamusic.com) The Sun UK decided to rip off copyrighted works, features and ideas from and on a constant basis for their repugnant, pornographic newspaper. 387. Not content with invading the privacy of innocent British citizens and imprisoned foreign dictators, in conjunction with a depraved pop star, The Sun's unlawful reach crossed the Atlantic to invade the privacy of a Jamaican-American citizen who did them no harm. The Sun has not only printed verbatim things Aisha has said over the phone, they have printed things she has said in the privacy of her own home, mentioned in detail further in this Complaint. The journalists at the Sun walk around with their smug attitudes and noses in the air, when they are a group of degenerate, eavesdropping perverts that invade people's privacy in violation of United Nations Laws. 388. Serious questions need to be asked about this disgraceful, abhorrent newspaper, as they specialize in invasion of privacy in boldface violations of United Nations Human And Civil Rights Laws and are notorious for publishing private moments that take place in private places like people's homes and offices that can only be obtained via planting a camera and or wiretapping device, also known as invasion of privacy. 389. The Sun and their disgraceful employees continually spit in the face of the United Nations and law enforcement around the globe in their perverted attempts at getting scoops for their filth ridden rag. Aisha is a witness to just how far the quasi-journalistic parasites at The Sun will go to get a story and a scoop, as she has been a victim of their wiretapping and computer hacking in conjunction with Madonna's theft of her work. It has become a free for all, irrespective of international laws. 390. You don't say something in confidence over the phone on Monday then read it published in the newspaper verbatim on Wednesday, attributed to a singer, Madonna and a journalist, Victoria Newton, who are publicly admitted friends, that have spent months publicly ripping off your copyrighted works. You don't author, copyright and place private unpublished works in the Library of Congress and on your computer only for them to be later utilized in the newspaper and public domain without your permission or knowledge, attributed to same singer and journalist...unless there is sinister, unlawful conduct transpiring behind the scenes at your expense, namely invasion of privacy to commit corporate theft. 391. While Aisha strongly disagrees with Mr. Hussein’s actions as dictator and is thankful he has been removed as Prime Minister of Iraq, she is concerned that The Sun has set a dangerous precedent. Today it's Hussein on the front page of their paper in his underwear, tomorrow it could be anyone in the general public, criminal or law aiding citizen, whose privacy they deem fit to invade for their purposes and for increased sales. The law affords no one such rights and it is open to abuse at the expense of innocent people, such as Aisha, if The Sun decides it (invasion of privacy) advantageous to sales. Today it's Hussein; tomorrow it could be a British Prime Minister, a doctor, a lawyer, a singer or an actor. They've shown they invade the privacy of the criminal and the law abiding, therefore that precedent for unlawful conduct is blatantly there and a danger to the general public. CRAIG DAVID - MADONNA’S WARNER LABEL MATE AND FRIEND OF VICTORIA NEWTON. 392. Aisha had been a regular message board poster on singer Craig David’s message board, where she spoke to friends about everything from music to films and world news. 393. However, unbeknownst to them, Mr. David had been reading the board (which he publicly admitted on several occasions later), where Aisha's analytical posts on music and the industry stood out like a sore thumb, due to how inventive, thought provoking and historically accurate they were, which was due to having been raised by a musicologist of over 40 years. She knew the history of music with an extensive knowledge of it. Mr. David recognizing the uniqueness and cleverness of what she wrote to her friends on there then began to attribute items she wrote on said message board to himself in his interviews (Aisha extracted old message board posts and later written articles/interviews that clearly illustrate where Mr. David did this numerous times, burning them to a disc if needed for this case). 394. Mr. David often attributed to himself numerous original music observations, jokes and commentary Aisha had written on the message board to friends, who would all engage in discussions. The board became quite popular. However, Mr. David’s attributions carried over to Aisha’s web site, with him getting the link off his message board, then would go over to her site and later quote items from it attributing them to himself in his public interviews. Aisha did not like this, as she saw it as a lack of character to repeat someone else's copyrighted writings who was not famous, attributing them to yourself in your interviews, because you are famous and clearly felt some inappropriate right of entitlement to take advantage of someone in that manner. 395. In the beginning Aisha went to his site to read about and hear his music, as she does with numerous British artists who are written about on the BBC’s web site that’s she’s been reading for years. She joined the message board, the first one she'd ever joined, as the people on there were talking about music and she thought it would be fun. 396. While she did meet some very nice people on there, it turned into a situation where people like Craig David and his friend Victoria Newton, who has included him in her column many times, began to steal from Aisha’s writings. 397. Victoria Newton was also a frequent visitor to his web site. The Bizarre column has featured Craig David numerous times for several years, who Victoria Newton knows personally. This is where Newton first learned of Aisha and her site. 398. When it came time for Mr. David's birthday his fans posted ideas of what they could do to commemorate his birthday. One suggested a birthday site. They attempted to make it but faltered and asked Aisha to make the site, as they knew she had made her own sites. She reluctantly agreed for their sakes (she did not like Mr. David’s behavior at this point in attributing her writings to himself and only wrote on the message board at that point to chat to her friends). 399. When she completed it, she posted a link to it and gave them an email address to send the birthday wishes they requested to include. She added the wishes and the entire message board was pleased with it. Aisha sent a letter to his manager’s office in London telling them of what his fans had done. She wrote the birthday site’s address in the letter as well, so he could thank them personally through the audio messages he would leave on the his site occasionally. 400. He never thanked his fans. He ignored the birthday site they thought up for him and asked Aisha to make. The secretary at his management company told Aisha she was collecting in a box the gifts his fans had sent in from all over the world to their office for his birthday and would give it to him when he returned to London that weekend. 401. In short, Mr. David never thanked his fans for the birthday gifts and cards they sent in when some of them had to save up their allowance for the gifts, nor did he thank them for the birthday wishes on the site they had asked Aisha to make for them. 402. Aisha later found out, as did another message board poster with ties to them that the gifts his fans had sent had been dumped in the trash, not even donated to charity as some management companies do with gifts they cannot give the entertainer for safety reasons. Mr. David was reading the board. He even admitted at different times that he did. He knew of it. 403. Aisha was perplexed at his apparent ingratitude towards his audience who made him rich, but just chalked it up to celebrity arrogance that she had seen so much of from a distance, as her father had raised her in the music industry, where she had heard and seen so much of it directed towards others over the years. 404. Mr. David was reading the board, admitted it in interviews, knew the gifts had been sent, fans even went up to him in public and told him when they saw him, but he never thanked them, some of whom were kids who saved up their allowance to send this thankless star gifts and birthday cards that he was too busy and too arrogant to simply say "thank you" for in a written or audio message. He completely ignored it, where other stars publicly acknowledge such acts of kindness from their audience. 405. While Aisha has never met or spoken with Mr. David, she found his conduct towards his audience, the people she helped to put together the site they thought up as a kind gesture to him, pretty lousy and unexplainably ungrateful. 406. Mr. David, much like Madonna, is an artist with a history of plagiarizing other artists works. 407. He famously ripped off the guitar riff from U2's “One” and used it on his song "Walking Away." Many critics wrote about this blatant rip off. 408. He ripped off a line from Damage's 2001 "Ghetto Romance" for his 2003 song "Fast Cars" stealing the line "body like a race car." 409. He has blatantly ripped off Jodeci's 1990’s "Love You 4 Life" for his 2005 song "Do You Believe in Love" stealing the Jodeci lines "Could you believe in love. And the promise that it brings," as the beginning of the chorus to his song - when it was already the beginning of the chorus to Jodeci’s song, written, copyrighted and released years ago. 410. He ripped off Jon B's "Don't Talk" for his song released a few years later titled "Hidden agenda." Many critics commented on this in publications as well. The songs are sung the same, with shared melodies, harmonies, phrasing and lyrics (the similarities are highlighted):
411. He ripped off numerous melodies, lyrics and song ideas from Usher, who at times he sings exactly like confusing consumers who hear them on the radio. 412. He ripped off Sammy Davis jr's "The Candyman" for his song "The Bootyman" Sammy's lyric goes "the candyman can..." and David’s lyric goes "the bootyman can..." sung in the same melodic phrasing. 413. There are also similarities to Aisha’s December 2004 released CD to Craig David’s August 2005 CD. Aisha copyrighted a hook in July 2004 titled “And The Story Goes On” while David’s August 2005 CD is title “The Story Goes.” Other lines and themes from Aisha’s album appear on Mr. David’s record released months later. Mr. David’s 2005 song “Girls Around The World” is eerily similar to Aisha’s previously released 2004 song “Wouldn’t Date A Black Girl.” Aisha has not fully reviewed his entire album yet to check for other similarities that would constitute legal action, but will do so shortly. 414. Defendant Liz Rosenberg is, and at all times herein mentioned was, a New York based in-house publicist for Warner Bros, who exclusively represents Defendant Madonna in PR matters. Ms. Rosenberg issued numerous press statements on behalf of Madonna that utilized items from Aisha's copyrighted unpublished works solely housed on her computers and in the Library of Congress and items from Aisha's personal and business telephone calls and intercepted faxes that were wiretapped by her co-defendant, republishing them verbatim to enhance Madonna's image. 415. Ms. Rosenberg has disgracefully put a spin on Madonna's shameful conduct numerous times to the disgust of the press and public - from publicly excusing Madonna and husband Guy Ritchie dressing up as the Pope and a nun at the time 1.5 billion Catholics were concerned about The Pontiff's fading health - he died days after, to publicly berated a Rabbi who appropriately called Madonna a "vulgarian" who “sets women back decades” with her "pornographic music" and vulgar publicity stunts. Rosenberg berated the rabbi for publicly stating that Madonna is a bad role model, therefore should not front a religious organization - the Kabbalah group, whose teachings are derived from Judaism. 416. Defendant Missy Elliot is, and at all times herein mentioned was, a Warner Bros singer and songwriter and co-writer of the copyright infringing Madonna track 2003’s "American Life" which ripped off Aisha's previously written, recorded, copyrighted and released 2001 track "Contemporary Girl." 417. Defendant Mirwais Ahmadzai is, and at all times herein mentioned was, a songwriter and producer and co-writer of the copyright infringing Madonna track 2003’s "American Life" which ripped off Aisha's previously written, recorded, copyrighted and released 2001 track "Contemporary Girl." 418. Defendant Calloway Arts And Entertainment is, and at all times herein mentioned was, a New York based book publisher, who published Defendant Madonna's copyright infringing children’s book series that also violated Aisha’s Right To Publicity and right To Privacy. Upon information and belief, Nicholas Calloway is the CEO, owner and namesake of Calloway Arts and Entertainment and a resident on New York City. 419. Defendant Music Today Inc is, and at all times herein mentioned was, a web hosting and design and fan club management company based in Virginia. They are responsible for the creation and management of Madonna's web site and fan club, which sells numerous infringing items stolen from Aisha's copyrights. Music Today Inc also stole items from Aisha's web site and applied it to client and fellow Kabbalahist, Britney Spear's web site. 420. Defendant Britney Spears, who is and at all times herein mentioned was, a copyright infringement and plagiarism prone singer residing in Los Angeles, California. Britney Spears made a regular habit of violating Aisha's Copyrights "Right of Attribution" in quoting items from Aisha's articles, attributing them to herself in her own interviews, after Aisha published said articles online SEE EXHIBIT 27. Spears and Music Today have ripped off several unique features from Aisha's web site in the creation of britneyspears.com SEE EXHIBIT 28. Britney Spears is a frequent copyright infringer, having been sued numerous times for stealing people's work SEE EXHIBIT 29, much like her idol who she constantly imitates and recklessly follows, fellow Kabbalahist Madonna. 421. Defendant Donatella Versace is, and at all times herein mentioned was, a fashion designer and part owner of Defendant Versace and Defendant Prato Verde, fashion clothing companies with the latter Defendant Prato Verde, being the parent company located in New York City. Defendant Mario Testino is and at all times herein mentioned was, a photographer. Madonna, Dontatella Versace and Mario Testino authored, authorized and paid for an ad that severely ripped off Aisha's image, life and persona, paying Madonna 10 million dollars for said ad and getting Versace out of the red due to it's stunning concept which was based on Aisha, detailed further in this Complaint and in EXHIBIT 41. 422. In doing so, they infringed Aisha's Right to Publicity and Right to Privacy in stealing her life, image, recognizable aspects of her persona and copyrighted online diary and bio writings. The ad even eerily resembles Aisha's home studio - with the beige carpet, beige chair, TV, glass top desk with computer and white phone. Further proof people have been in her home without her permission. 423. They had no right stealing Aisha's copyrighted online diary and bio, her image and life for these unlawful ads, especially for a product she holds in low esteem due to its outrageous prices and gaudy, distasteful use of color. They have exploited Aisha in a most disgraceful way, by going as far as to crassly steal her image for some quick, undeserved cash. It is completely reprehensible. Dontatella Versace has said on record that this ad campaign got Versace's books out of the red, however at Aisha's expense. Aisha should be the one to use and profit off of her own image - not Madonna or the ailing fashion house. What they did was completely sick. Their actions are terribly exploitative and greedy in stealing and using something so fundamental and intrinsic to a person - their image, life, personality, and persona - essentially who they are as a human being. 424. Joan Akerlund is, and at all times herein mentioned was, a music video director who directed Madonna's documentary "The Re-Invented Process" aka "I'm Going To Tell You A Secret." This documentary contains footage from Madonna's "Reinvention Tour" that contains the 2003 copyright infringing song "American Life" which rips off Aisha's 2001 "Contemporary Girl." 425. Andrews Publishing is, and at all times herein mentioned was, a book publishing company who are publishing the copyright infringing forthcoming release "Madonna's Inspirations" which has a scheduled released date of September 1, 2005 SEE EXHIBIT 30. This book is a blatant rip off of Aisha's previously copyrighted book "Beautiful Inspirations." Aisha copyrighted "Beautiful Inspirations" on June 2, 2005 SEE EXHIBIT 31 and by June 9, 2005 Madonna made an announcement that she was releasing a rip off version of it titled "Madonna's Inspirations" SEE EXHIBIT 32. Aisha's book is about beauty and health advice, inspirations, along with beauty pictures. Madonna's announced book contains the same based on the descriptive summary released to the public. THE KABBALAH CENTER: A DANGEROUS, MURDEROUS, NEFARIOUS CULT426. The Kabbalah Center is, and at all times herein mentioned was, a cultic organization, of which Madonna is the front woman, with head offices on the outskirts of Beverly Hills, California. The Kaballah Center is owned and operated by the Berg family - Phillip S. Berg, also known as Feivel Gruberger, Karen Berg, Michael Berg, Yehuda Berg and Michal Berg - with Madonna being their international spokesperson and chairperson. 427. The Kabbalah Center and the Bergs have greatly profited from Madonna stealing Aisha's copyrighted works - funds from which have gone to the disgraced cult, purportedly as a charity donation from the 47-year-old singer. Madonna infringed Aisha's copyrights to put together her documentary film about the Kaballah. 429. She also infringed Aisha’s Right To privacy via her Kabbalah children's book series, for which they received a huge portion of the proceeds - which is now under investigation as the not for profit charity, Spirituality For Kids, used these funds to flip real estate in low income black neighborhoods in Los Angeles - further ripping off one of Aisha's copyrighted business plans that was located on her hacked computer with her catalog Madonna criminally procured a copy of and used (though Aisha's business plan did not call for low income neighborhoods as it's area, rather middle income neighborhoods with unique architectural homes in need of refurbishment. Her plans were to renovate unique, historic homes, not rape underprivileged communities as Barak Enterprises has been doing via loans from Madonna's Spirituality For Kids). 430. Madonna is using Aisha's copyrighted works she stole to help fund this disgraceful cult that goes against everything Aisha believes. As a copyright owner, no one has the right to use your works for derivative works you did not authorize, then take said ill-gotten profits for use in ventures you deem a scam and sacrilegious. 431. Other Kabbalahist stars like Demi Moore, Ashton Kutcher, Michael Jackson, Elizabeth Taylor, Defendant Britney Spears, Lindsay Lohan and Paris Hilton also front this dangerous cult. 432. The Kaballah Centere much like Madonna, are thieves, stealing people's intellectual property and exploiting it for financial gain. Philip Berg himself is no stranger to copyright infringement and plagiarism, having been sued by the estate of Levi Krakovsky for copyright infringement and plagiarism. Krakovsky's estate formally sued and accused "(Phillip) Berg and or persons acting under his direction" of among other things, "entering the impoverished scholar's home after his death and taking his original manuscripts." Berg later published the deceased rabbi's work as his own - a thoroughly reprehensible act (SEE EXHIBIT 35). 433. In a similar pattern of intellectual property theft and invasion of privacy, Madonna hired a hacker to steal the contents of Aisha's copyrighted multi-million dollar catalog housed on her computer and in the Library Of Congress and someone also broke into the young singer/writer's home studio SEE EXHIBIT 13 FOR POLICE REPORT. Madonna has illegally been putting Aisha's already copyrighted works into production at Maverick Records, Maverick Films, Warner Bros, Warner Chappell, Calloway Arts And Entertainment, Andrews McMeel and Disney, with their full cooperation and backing, as mentioned further in this lawsuit. It is illegal to steal unpublished copyrighted works and put them into production under your own name and business, as it is grand theft larceny, invasion of privacy, corporate theft, conversion, fraud, plagiarism, copyright infringement, and more seriously, racketeering - violating several RICO statutes. 434. Philip Berg was also accused of plagiarism by Rabbi Immanuel Schochet of Toronto, for stealing Rabbi Yehuda Ashlag's copyrighted intellectual property from his book and reprinting it in his own book, errors and all (SEE EXHIBIT 35). 435. The Kaballah Center is so desperate for intellectual property that they advertise on the site Craiglist, searching for "ghostwriters" whose works will be attributed to the Kaballah Center's principals (SEE EXHIBIT 35 and 36). 436. According to an internal Kabbalah marketing memo obtained by LA's Radar Magazine, the Kaballah Center encourages their ghostwriters to "study spiritual best sellers and mimic them using Kaballah Center lingo" which is also known as copyright infringement and plagiarism SEE EXHIBIT 35). 437. Plagiarism and Copyright Infringement is a way of life for Madonna, has been for her entire career of 20 years, and for the Kaballah Center, who have utilized this disgraceful practice to gain intellectual property for over 10 years - judging by each of the Defendants lawsuits for said crime and allegations of the same. Madonna's and the Kaballah Center's union, which has been described as a "financial agreement" by a Jewish rabbinical organization, was a equal match of thievery, greed and copyright infringement. 438. Furthermore, since Madonna's involvement with the Berg's and the Kaballah Center, her already abhorrent conduct has grown worse, culminating commissioned in invasion of privacy, hacking, wiretapping, fraud, terrorization, assault and harassment - conduct that has caused harm to the Plaintiff Aisha. 439. Numerous credible press and investigative outlets have warned of the dangers of this cult. Madonna has been a reprobate for her entire 20 year career performing sick, perverted acts on stage such as reportedly masturbating with a cross and simulating sex acts before audiences of various ages, however, joining the Kabbalah cult in recent years, and actively promoting it in the last 2 years, has only served to worsen her already disgraceful conduct, which contributed to the malfeasances she committed against Aisha. Her obsessiveness and intrusiveness towards Aisha has been a source of great concern for the younger singer's family. Her behavior has been positively inexcusable and depraved. 440. The Spirituality for Kids center where the profits from Madonna's Children's books go, for which Madonna is the international chairperson, loaned millions to Barak Enterprises Inc, a for profit company with a P.O. Box address, are utilizing one of Aisha's copyrighted business plans for buying property, renovating it and selling it back. However, rather than choose stable income neighborhoods like Aisha's business plans entailed, Madonna and her co-defendants are lending millions in interest loans from the charity's money to a close friend of the Kabbalah Group, Barak Enterprises, who are targeting impoverished black neighborhoods like Watts, Compton and Inglewood, then selling the properties back at high prices under the guise of helping the poor, which they are not. Barak Enterprises, using millions loaned to them by Madonna's so called charity Spirituality for Kids, are selling these properties back at a 80% profit - while only $1,985 actually went to the Spirituality for Kids charity, which is clearly a for profit venture via these loans they are doling out for real estate transactions that are a disadvantage to the black community (SEE EXHIBIT 35). It was reported that the IRS and Inland Revenue are investigating. 441. Madonna has reportedly funded the center with 18 million dollars to date, but it came from ripping off and exploiting Aisha's already copyrighted intellectual property, which also contained business plans that she gained criminal access to, which is completely reprehensible. 442. In January 2005, Jetblue donated $10,000 worth of teddy bears to the Kabbalah Center’s Tsunami Relief Fund and Madonna’s Spirituality For Kids, but as of mid June - not a single teddy bear had reached Indonesia (SEE EXHIBIT 35 for the Radar magazine investigative piece). Where did these bears go? 443. The Kabbalah Center collected $960,244.76 to send water to tsunami victims in Indonesia, but only $77,256.10 worth of water was actually sent. Where did the surplus of almost $900,000 go? (SEE EXHIBIT 35). 444. Madonna's Spirituality For Kids purported that 10,000 kids participated in the outreach programs, but 2003 tax filings revealed only 150 kids participated. (SEE EXHIBIT 35). 445. In 2003 (the last year for which figures from the charity are available) Spirituality For Kids spent $813, 092 on program services, $440,332 on salaries and wages and a "scandalously low" $1,986 on its scholarship fund (SEE EXHIBIT 35). 446. Madonna sold Kabbalah merchandise at each stop of her Reinvention Tour, though they claim to be a not for profit entity - whose principals all live in Beverly Hills mansions that take up a whole block of prime real estate in said district. Madonna and Rocawear's Alex Bize were to be equity partners in the Kaballah Water line. 447. Berg reportedly said, "If the damn FDA would just let me put that the water cures cancer on the label, I wouldn't need marketing" and told a student that Kabbalah Water cures AIDS. A scientist from the Miami Center told a Kaballah congregation that Kabbalah water cured her of SARS she contracted in Asia. (Source: Radar magazine) SEE EXHIBIT 35. However, the bottling plant in Canada that bottles the water bought by numerous companies that stick their organization’s name on the same bottled water, was cited by the CJC because "it had not tested its water's properly" - water they claim cures AIDS, SARS and Cancer. 448. During Passover 1992, Union, The Rabbinic administrator of the Orthodox Rabbinical Council of California, faxed numerous Rabbis denouncing the Kabbalah. By the next morning there was a severed sheep's head at his doorstep. Several young men appeared at his home that evening and asked, in Hebrew, "Did you get our message?" 449. Upon information and belief, a BBC2 expose revealed that Kabbalah cult members are taught that the Holocaust happened because the Jewish people didn't use the Kabbalah. "The Light was blocked. They didn't use Kabbalah,” said Kabbalah Center's Eliyahu Yardeni. They also said that a child who dies in a car accident brought it upon himself. 450. The BBC2 expose featuring a man sick with cancer that was told to buy $700 worth of Kabbalah water, fill his swimming pool with it and it would allegedly cure him from cancer. 451. The "healing spring water" is actually bought by the Kabbalah Center from a Canadian bottling plant CJC, and sold at a great mark-up to followers. In 2002 authorities issued an order against CJC because it had not tested its waters properly. However, the Kabbalah Center has remarketed this water as having undergone "exclusive Kabbalistic process called Quantum - Resonance Technology" making it a "spiritual tool." 452. Cash raised by the Kabbalah for the tsunami victims is being spent on distributing Kabbalah products in Malaysia, which raised the ire of a lot of observers. 453. The Kaballah Center says it is not for profit, but its principals the Berg's live in Beverly Hills mansions, gamble in Atlantic City and have spent money on costly plastic surgery. 454. The Kaballah Center is under investigation by the Westminster Council in London due to members of the cult sleeping in windowless cells in a basement of their building. 455. Rabbi Barry Marcus of London's Central Synagogue referred to the Kaballah as "hell bent on making money." He further stated they are a "nefarious bunch of charlatans."
456. Chief Rabbi, Dr Jonathan Sacks said the Kaballah Center "is not recognized by religious authorities."
457. Phillip Berg encourages Kabbalah members to purchase and wear $27.50 red string bracelets, a practice that goes back to paganism. This is a practice traditional Judaism forbids. Mr. Berg purports with no proof that the practice will "ward off the evil eye" and bad things happening, when he himself was reportedly incapacitated by a stroke last year. The celebrities that are apart of this unethical group who wear the red string bracelets have been met with abject failure, accidents, injury, personal crisis, embarrassment, humiliation and one financial loss after and during the time they have worn said red string bracelets. There is no proof to back up Mr. Berg's claim and much to state the contrary.
458. There have been written reports that people were threatened that if they did not donate, they would get cancer. 459. The Philadelphia Board of Rabbis complained that Berg's followers have been abusive. 460. Rabbi Yitchak Sladowsky of Queens reported, "Parents had complained that children were taken in by Berg and were being estranged from their families." 461. Tony Donnelly, treated at London's Royal Marsden Hospital for cancer was prescribed three bottles of Kaballah water per day and offered a package of water worth $700, which he bought cash. He was told it would cure his cancer. 462. Rabbi Barry Marcus referred to the Kabbalah’s fleecing of people as, "absolutely disgusting and yet another cheap shot by a sect hell-bent on making money. We in the Jewish community dissociate ourselves from this appeal in the strongest way." 463. Debbi Chaski-Leventhal, a former Kabbalah cult member of 13 years said "It's a cult, absolutely it's a cult, especially for the few hundred people who are very close to the Bergs. Most of these people will do almost absolutely anything he will tell them to do, and if he will tell them tomorrow to all commit suicide together they will." 464. It was reported in British newspapers that Kabbalah members have been fleeced out of millions of dollars and tossed out penniless from this greedy group fronted by the Berg's and Madonna. 465. Many journalists, religious scholars and cult experts have stated in publications that Madonna's Kabbalah book series for kids, The English Roses, Lots De Casha, Mr. Peabody's Apples, Yakov and the Seven Thieves and the Adventures of Abdi aims to brainwash children with the Kabbalah cults teachings. 466. It was reported that Kabbalah Center members known as "chevras" were forced to hand over their life savings and worked for the Kabbalah Center on what was referred to as "slave wages" - $35 per month. Staff members who cook and clean for the Center only make that menial amount - which is far below minimum wage (SEE EXHIBIT 35). 467. Kabbalah Center members erroneously reportedly believe, "negative energy can be absorbed by swinging a chicken over the head." 468. A Rabbinical organization referred to Madonna's involvement in the Kabbalah Center as a "financial agreement" in a press release. 469. A former Kabbalah Center member whose family intervened and got her out of the dangerous cult reported that as a result they left numerous, obsessive messages on their daughter’s answering machine. 470. A former Kabbalah member going by the name of "Mike Gold" and his wife were fleeced into believing donating large sums would protect them from bad things happening to them. Upon information and belief "Mike Gold" returned to the townhouse and asked the hevrei he was living with "If Rabbi Berg asked you to jump off a building, would you? They said, "If Rabbi Berg promised I'd be safe, then I would." Upon hearing that Gold promptly left the Kaballah Center. He later said, "When I joined the center my life fell apart." 471. Upon information and belief Rabbi Bentzioni Kravitz stated, "I was spat on by them" and "they surrounded me and yelled at me." 472. Last year, Phiona Davis of London, a Kabbalahist that attended frequent sessions by the cult in the same small group as Madonna, snapped under pressure she described as the Kabbalah Center “being in her apartment” and “watching her every move.” The article implied that she did not know they were there, but felt she was being watched. It turns out she may not have been completely wrong (as Madonna has criminally invaded Aisha’s privacy). 473. Phiona Davis snapped under pressure she told her doctor was from the Kabbalah Center, and then committed the brutal homicide of two innocent people. The Kabbalah Center 's conduct reportedly drove her to these misdeeds; from what she felt was them watching her all the time. And considering the gross invasion of privacy Aisha has experienced at Madonna’s hands, it is not implausible that there was something to Davis’ complaints. As mentioned above, the Kabbalah Center’s founder already proved himself to be a trespasser, thief and privacy invader in entering the home of a deceased rabbi and stealing his manuscripts, later illegally printing them as his own, for which he was sued. 474. They clearly seeking to dupe people into thinking they have mystical powers via special unearthly gifts, when their information is obtained via trespassing and invasion of privacy. If someone is illegal in your home invading your, of course they are going to unconstitutionally know the personal details of your life, your prayers, your phone conversations, family talks, project ideas and daily activities. They can then use this to get an illegal advantage. 475. Phiona Davis stabbed her boyfriend, Keith Fernandez, 58 times in the face. His neighbors heard him screaming and went to his home to see what was happening, only to find her on top of him stabbing him with a knife. He got away from her and she chased him down the street with "an evil grin on her face" saying "this is done through God." It was reported, "Her eyes were glazed and evil looking and she had an evil look on her face." Upon information and belief, in addition to the stab wounds, he had bite marks on his cheek, arm and chest. She then calmly departed the murder scene by taking a public bus. 476. However, the next day after alluding police, she attacked her great-grandmother, Mary Skerritt, stabbing her 130 times, killing her in a similarly brutal fashion. Nigel Eastman told the court that Kabbalahist Phiona Davis was "one of the sickest people he had examined." A few months prior to the murders, Davis told her doctor that she was being "controlled" by the Kabbalah Center and that they were in her apartment. She reported "feeling that people from the Kabbalah Centre were walking around her flat (apartment)." 477. During the 2004 murders, Phiona Davis said delusional things such as "I am God, I am the benevolent one, burn the demons and burn her" and upon arrest stated, "I am the messiah and the king of kings." 478. At Madonna's 2004 Reinvention Tour concerts, she similarly took to calling herself "God" and "The Alpha and The Omega" (a Biblical name for God) in front of thousands of people. Upon information and belief she has also been crowned a "High Priestess" of the cult. 479. As mentioned previously in this action, Madonna herself has shown a penchant for violence. The book titled "The Big Show: High Times And Dirty Dealings Backstage At The Academy Awards" by Steve Pond, detailed how a camerawoman fell into the orchestra pit and was seriously injured, and as she laid there on the floor waiting for paramedics, a furious Madonna was upset that she wouldn't be able to rehearse for the show. Madonna, obviously not concerned for the woman's welfare exclaimed, "But she's just lying there. Can't we just do this." Still upset at not being able to rehearse Madonna later choked Dick Clark’s son Rac who accidentally fell asleep during her show and ruined a planned microphone stunt for her performance. According to the book she then, "Launched into an astonishingly profane tirade, despite the fact that the area below was occupied by a group of children" SEE EXHIBIT 10. 480. In 2002, unprovoked, she choked a 10-year-old boy who wanted her autograph when she was not in the mood to sign it. She choked him, roughed him up then threw him to the floor. Because of her celebrity and wealth, she has been able to get away with unlawful conduct and pay for further illegal conduct, such as the complete invasion of privacy of the Plaintiff Aisha, which encompassed tapping Aisha's telephone, hacking her computers and stealing her private copyrighted catalog worth millions. She further commissioned people to come up to Aisha in public and harassing her. OVERVIEW481. There is a plethora of triable facts in this case. Defendant Madonna is the ringleader in the horrible civil and criminal malfeasances committed against Aisha, and her co-defendants threw in their lot with her, despite the fact that she has been publicly sued and accused of copyright infringement, plagiarism and misconduct numerous times, as listed in this Complaint. The Defendants have purposefully lied to cover their civil and criminal misdeeds. 482. This type of behavior should not be tolerated. It is criminal, base thievery, racketeering and corruption. Just because you are a celebrity, does not make that type of unmitigated corruption, property theft and lawlessness acceptable. It is plain wrong and an utter disgrace. 483. They willfully did not exercise due diligence, were terribly negligent and tossed in their lot with a woman known in the entertainment industry for misconduct, stealing, violent behavior, threatening conduct and perverseness. 484. Knowing that she was committing numerous civil and criminal crimes against the Plaintiff, Madonna's co-defendants deliberately looked the other way and allowed an innocent woman, Aisha, to suffer and be terribly exploited, in exchange for acclaim, profit and a share of the plundering of a hard working artist's innovative, life's work in the form of a copyrighted catalog valued in the millions. It has become a free for all stealing spree in violation of U.S., Jamaican and United Nations Laws and it must cease. 485. They further looked the other way and perversely participated in unlawfully invading her privacy, and that of her family, which includes a minor, like a bunch of moral reprobates. This is inexcusable and unjustifiable under any circumstances and worthy of the strongest legal censure available. 486. Aisha is of the belief that Madonna should not have power of attorney, as she is using it to commission civil and criminal crimes against innocent people, which break both domestic and international laws, in illegal bids to further her career, bank account and extraordinarily extravagant lifestyle, she clearly can't afford without committing these deliberate acts of fraud, theft, corporate theft, grand larceny and criminal copyright infringement. An indulgent lifestyle that includes a reported 5 mansions, several luxury cars, a private jet, huge personal staff in two countries and expensive, well-documented and photographed shopping sprees. 487. When one does that on one's own money it is lawful, but when said lifestyle is being maintained via willful, criminal acts of criminal copyright infringement, invasion of privacy, conversion, corporate theft and grand larceny, to the tune of millions of dollars, it is completely criminal and disgraceful. 488. Aisha thought her catalog was safe on her personal computers and in the Library Of Congress, where they had been prior to Madonna committing invasion of privacy and criminal copyright infringement, grand larceny, corporate theft and racketeering in selling off and using items from the catalog in open, criminal violation of U.S., British, Jamaican and United Nations laws. 489. As shown by a clear, connectable pattern of theft on her part, which defrauded numerous unrelated international copyright holders, Madonna is clearly in need of court appointed supervision, lest she causes anyone else irreparable harm - and further damages the people she has willfully and deviously committed criminal acts against, several of whom have sued her in three United Nations member countries. 490. The lawsuits Aisha vs. Madonna, Acquaviva vs. Madonna (Belgium "Frozen"), Bourdin vs. Madonna (NY/French origin "Hollywood" video), Easy Street Records vs. Madonna (NY "Deeper and Deeper" and "Bad Girl" songs), Salvatore vs. Madonna (Los Angeles/Italian origin for "Ray Of Light"), Hamilton vs. Madonna (filed in Los Angeles, British origin, deliberate non payment of $350,000 in production fees), in New Jersey - deliberate non-payment of $100,000 loan for film company fees, in addition to numerous other formal public allegations of theft against Madonna by singer/Prince protégée Ingrid Chavez (the real writer of “Justify My Love”), Hide the Babies (reportedly wrote what illegally became “Like A Virgin” and received no credit or compensation), in addition to acts of willful assault and aggravated battery against a minor, 10 year-old Keith Sorrantino (Sorrantino vs. Madonna filed in NY) and the choking of Dick Clark's son Rac, says there is clearly a problem and pattern of criminal and civil misconduct that needs to be addressed before anyone else is further defrauded or physically harmed. 491. She is wantonly and wrongfully going around creating international incidents in willfully defrauding and robbing international copyright holders in different countries who have had to find substantial amounts of money to sue her to reclaim their works. Aisha's case is by far the worst and clearly the worst in entertainment history, due to depraved Madonna's sick obsession with stealing from and mimicking the younger singer, whose privacy she has invaded and whose well being she has violated via commissioned harassment and terroristic threats. Aisha has family in three countries have been affected by Madonna's misconduct, among them children - which is a gross violation of UN laws on invasion of privacy and the Rights of a Child (to privacy). 492. These were premeditated, willful, racketeered acts, done with full volition, orchestration and planning that broke several domestic and international criminal and civil laws. COPYRIGHT INFRINGEMENTDEFENDANT MADONNA493. The Defendants willfully committed numerous violations of The Copyright Act 17 U.S.C. 101 and The Lanham Act 15 U.S.C. 1051, in unlawfully and deliberately pilfering and plundering Aisha's copyrighted works, which were authored registered with the Library of Congress prior to the thefts. In numerous instances the infringements were sheer duplications and copying of Aisha's copyrighted works, while in others instances the Defendants disguised the thefts by willful alterations of said copyrighted works, but to no avail, as they still contained clearly visible chunks of Aisha's works. 494. Madonna stole Aisha’s 2001 copyrighted debut “Contemporary Girl” for use in her subsequent 2003 flop “American Life.” Madonna stole lyrics, music, the beat, harmonies, melodies, song theme and song structure from Aisha’s song and unlawfully used it for her later released song. SEE SEGEMENT TITLED “DEFENDANTS MADONNA, MAVERICK RECORDS, TIME WARNER, WARNER BROS RECORDS, WARNER BROS, WARNER CHAPELL, MIRWAIS AHMADZAI, AND MISSY ELLIOT” FOR FURTHER DETAILS. 495. Aisha’s song contained a rap segment and when Aisha wrote on her web site’s Sound Off Column why is Madonna rapping all of a sudden after 20 years in the industry when she never cared about rap before. Madonna then did an MTV article lying about why she tried to rap (which the critics completely slammed). Madonna attributed it to being crazy about Defendant and collaborator Missy Elliot and Eminem’s rapping, but Madonna had put out two albums since Eminem’s debut and 4 albums since Missy's and never expressed any interest in rap until she saw and unlawfully stole Aisha’s 2001 copyrighted song from her web site and released her 2003 rip off “American Life” that Madonna expressed any interest in rap music. 496. Aisha showed that rock, rap, dance and r&b could be successfully merged in one song via 2001’s “Contemporary Girl.” Using her limited amount of vocal ability, Madonna ripped off Aisha’s lyrics, melodies, music, beat, unique song structure and unique song theme that had never been touched upon before. Madonna’s lack of talent did the song in and critics horribly panned it. 497. Aisha's has been rapping since 1986 and she has a voice that covers several octaves, so she wholly composed and authored a song to fit that, as it is what she knew. That was her style and vision of music. Madonna sensing it to be the next big thing in music, which she is always searching for and doing at other artists’ expense, ripped it off completely from lyrics to beat to melodies to music, in her vulturous quest to maintain a 20 year career that was based on nothing but meaningless trends. 498. However, she faltered severely in stealing Aisha's virtuoso piece and critics and fans bashed her. Aisha's complicated song that covered several styles of music called for a virtuoso voice that could adapt to all the changes and Madonna cannot sing, as has been noted by countless critics, musicians and audiences. 499. The lyrics and music from Madonna’s latest song titled “Hung Up” being hosted on Defendant Motorola’s web site and used in their global commercial contains lyrics and music from Aisha’s already released copyrighted debut CD “Aisha” and other lyrics from her aforementioned multi-million dollar copyrighted catalog that Madonna has been criminally using in violation of U.S. and United Nations laws. The original version of Aisha’s copyrighted 2003 song “Metronome” had the exact same ticking noise at the beginning of the song, as does Madonna’s now later released copyright infringing song “Hung Up.” 500. Madonna stole an old album pic of Aisha that did not make her album, from Aisha’s computers via the hire hacker she commissioned to steal Aisha’s catalog. This pic is now criminally being used in the artwork for the “Confessions On A Dance Floor” CD. 501. A picture treatment from Aisha’s multi-million dollar copyrighted catalog was stolen to make the “Confessions On A Dance Floor” CD cover. 502. Madonna announced a rip off version of Aisha’s copyrighted video she filmed in London during the second week of September. Aisha’s video treatment for said video was copyrighted a few years ago. 503. Madonna has stolen another song from Aisha's catalog titled "New York City" and renamed it "I Love New York" for her forthcoming album (SEE EXHIBIT 39). 504. Aisha copyrighted a song hook in July of 2004 titled “The Dance Floor” with Madonna a year and a half later titling her album and a possible single “Confessions on a Dance Floor.” 505. Madonna outright ripped off a copyrighted book manuscript from Aisha's private copyrighted multi-million dollar catalog titled "Beautiful Inspirations" and renamed it "Madonna's Inspirations." The books are about the same thing and from the listing on the Andrews McMeel web site who are the publishers; contain similar text as well, which is a criminal infringement. Upon release of said book, this Complaint will be amended to reflect the infringements. A proposal for endorsement contained on Aisha’s computers (that were later hacked) drafted to submit to clothing company Guess was ripped off by Madonna who went to their competitor the Gap. Madonna had never endorsed an American brand in her career, opting for European high couture brands. However, due to falling sales of her CDs in America, she used Aisha’s idea contained on her private computers. It culminated in print and TV ads in 2003 featuring Madonna and Missy Elliot. Much like she ripped off Aisha's image, life and persona and took it to Versace in 2004 for ads that were clearly based on Aisha's image, persona, life, look and copyrighted works, which violated Aisha's copyrights, Right to Publicity and Right To Privacy. These ongoing malfeasances committed by Madonna are sheer acts of invasion of privacy via hacking and corporate theft. 506. Items apart of Aisha's private copyrighted fashion line, among them a clothing, shoe and jewelry line, have now also mysteriously surfaced as knock off items in Madonna's “English Roses” fashion line that also contains jewelry and shoes. This is the same book that violated Aisha’s privacy in printing details, incidents and furniture from her home as apart of the story lines. 507. Madonna has stolen costume designs and outlines included in Aisha's copyrights and worn them on her “Drowned World Tour,” “Reinvention Tour,” during “Live 8” and in the Defendant Motorola’s “Rokr” commercials featuring the song (“Hung Up”) she criminally stole from Aisha’s unreleased music and released debut CD. 508. Aisha copyrighted a song called "Rockstar" in July of 2004. In the summer of 2005, a perfume for Madonna was released called “Rockstar.” 509. In July 2004 Aisha copyrighted a dance song titled "I Feel Like Dancing." On a June 2005 episode of the TV show “The View” Madonna said her new album “is a dance album” and uttered the words “I Feel Like Dancing." Aisha has yet to hear all of the music on Madonna’s forthcoming album to determine the full extent of the copyright infringements. 510. Aisha’s July 4, 2001 web site pics were ripped off 6 months later by Madonna for use in the CD artwork of her Greatest Hits Volume 2 CD released 11-12-01. PHOTO POSTER COMPARISON EXHIBIT WILL BE PRESENTED AT TRIAL. Madonna is notorious for stealing other copyright holders pics. She was sued in 2004 in the case Bourdin v. Madonna for stealing copyrighted images from artist Guy Bourdin’s works. She also infringed the copyrights of Marilyn Monroe pics for her “Like A Virgin” promo SEE EXHIBIT 67. 511. Madonna criminally stole one of Aisha’s copyrighted film script synopsises for a film titled “Contemporary Girl” and criminally used it renaming it “Material Girls” as listed in detail further in this “Copyright Infringement” segment of this Complaint. 512. Madonna criminally sold another script from Aisha’s private copyrighted multi-million dollar valued catalog to her employer, costar, colleague and friend of 20 years, Director Defendant Gary Marshall, who criminally used it for the film “Princess Diaries 2.” These infringements are listed in detail further in this “Copyright Infringement” segment of this Complaint titled “Gary Marshall.” 513. Violated the copyrights of Aisha’s web sites www.aisha.tv and www.aishamusic.com many times in falsely attributing items from Aisha’s web writings to herself in her interviews verbatim, as listed in detail in the Violation OF The Right Of Attribution segment of this Complaint. DEFENDANTS MADONNA, MOTOROLA, STUART PRICE 514. The lyrics and music from Madonna’s latest song titled “Hung Up” being hosted on Defendant Motorola’s web site and used in their global commercial contains lyrics and music from Aisha’s already released copyrighted debut CD “Aisha” and other lyrics from her aforementioned multi-million dollar copyrighted catalog that Madonna has been criminally using in violation of U.S. and United Nations laws. 515. A week after Aisha got clearance from iTunes (to submit her music for inclusion in their service), using the hacked information, Madonna signed up all her music with iTunes, after refusing to for 2 years. Further proof Madonna had unlawfully been stealing information and copyrighted materials from Aisha's computers (via the hired hacker). 516. Furthermore, Motorola filmed and released an ad of Fat Joe talking to animals, when Aisha previously (the month before) wrote a humorous piece of commentary in her Sound Off Column featuring her talking to animals, namely the horse that threw Madonna causing her to break several bones. Motorola got the idea for that commercial from Aisha’s Sound Off Column, for which she has digital proof was written and published before the commercial was ever made or aired. Further more the Column is copyrighted. 517. Defendant Motorola knew of all of the bad publicity Madonna had gotten for stealing artists copyrighted works and still used the material any, not checking whether or not the work belonged to her, causing further damage to Aisha. They took it one step further and began stealing from Aisha’s copyrighted web site themselves. The fact of the matter is Motorola threw in their lot with Madonna in hosting music that was criminally obtained by Madonna in violation of Jamaica, U.S. and United Nations laws. 518. It must be noted, with the high rate of illegal downloading and theft of music, it is inadvisable to have a campaign such as Rokr fronted by a known perpetual copyright infringer - Madonna. Defendants Madonna and Stuart Price wrote “Hung Up.” DEFENDANTS MADONNA, MAVERICK RECORDS, TIME WARNER AOL, WARNER BROS RECORDS, WARNER BROS, WB MUSIC CORP, WARNER CHAPELL MUSIC PUBLISHING, WEBO GIRL PUBLISHING, MIRWAIS AHMADZAI, AND MISSY ELLIOT: 519. The Defendants Madonna, Time Warner AOL, Warner Bros, Warner Bros Records, Maverick Records, Missy Elliot, Mirwais Ahmadzai, Webo Girl Publishing, Warner Chappell Music Publishing and WB Music Corp stole copious amounts of Aisha’s copyrighted work from the Plaintiffs sound recordings and web site for use in several Madonna projects that range from four music CDs (American Life CD single, American Life Maxi Single, American Life and Madonna Remixed and Revisited), music digital downloads widely available on Napster, Itunes, Real.com, Buy.com, Walmart.com and Madonna.com (American Life song download, American Life album download), a DVD and documentary titled "The Re-invention Tour" also known as "Let Me Tell You A Secret." 520. Numerous works stolen by the Defendants bear exact duplication, copying, striking similarities, remarkably similar themes, concepts and structure to Aisha's copyrighted works "Contemporary Girl," "Contemporary Girl" (remixes), script synopsises, photos, video, numerous original articles and writings set forth on the Plaintiff's frequently updated and copyrighted web page www.aishamusic.com and www.aisha.tv. Madonna used Aisha's work as the template for several projects, going as far as stealing many original items such as lyrics, beats, melodies, song structures, script synopsises, script dialogue, original articles and diary entries. 521. Defendant Madonna embarked on a tour that reportedly went on to gross $125,000,000 worldwide according to official reports from the Defendants to Billboard Magazine, based on the release of the song and album American Life, which was stolen from the Plaintiff’s song “Contemporary Girl.” Defendant Madonna has also obtained several award nominations and for works stolen from and derived from the Plaintiff’s work. Madonna won the “Billboard Tour Of The Year Award” which was launched on the strength of the copyright infringing song in question “American Life.” 522. The album “American Life” went to #1 on the Billboard Charts, based on the strength of the same name song “American Life” which is a direct rip off of the Plaintiff’s song “Contemporary Girl.” It is the accepted industry standard that the first song from an album determines and spurs on its sales and debut chart position. Madonna gained a #1 record based on the song that was a rip off of the Plaintiff’s song “Contemporary Girl.” The album was certified platinum for sales on 1 million copies in the United States. The album sold 5 million copies in total worldwide." American Life" went to #37 on the US charts and #2 on the UK charts and made the top 5 in several other countries. 523. Aisha’s 2001 “Contemporary Girl” and “Contemporary Girl (rap remix)” beat stolen for Madonna’s 2003 “American Life.” The Defendants sold 5 million copies worldwide of the CD American Life (grossing a minimum of $45 million dollars) and 1 million copies worldwide of the CD single American Life (grossing a minimum of $9 million dollars). This is in addition to additional fees from online digital download stores such as Itunes, Napster, Real.com, Buy.com and Wal-Mart who all sold the copyright infringing song. SIMILARITIES BETWEEN THE SONGS 2001’s "CONTEMPORARY GIRL" BY AISHA AND 2003’s "AMERICAN LIFE" BY MADONNA 524. From reading Madonna's lyrics to the song "American Life," it is obvious she did what other copyright infringers have done. She went over the song (Aisha's "Contemporary Girl" 2001) and tried to rewrite it, taking away portions, but changing what she assumed would be enough to not get caught, while retaining the concept and some of the lyrics of the song, thereby keeping the basic theme and music intact for her rip off "American Life" in 2003. Many copyright infringement cases bear this pattern. 525. Both songs contain duplicated and similar lyrics. In each chorus, Aisha's song "Contemporary Girl" contains the lines "Modern Society" at the beginning of the refrain. 526. In Madonna's rip off version "American Life" the lyrics contain the words "Modern Life" in the beginning of the refrain. The phrase “Modern Society” can be used interchangeably with the term she put in "American Life," “Modern Life” as both phrases can be used to mean the same thing. 527. In Aisha's "Contemporary Girl" the lyric in each chorus goes: “In a modern society, that gave you the right to be in control.” In American Life the lyric in each chorus goes “This type of modern life - Is it for me?” 528. During the rap on "Contemporary Girl," Aisha raps about the things contemporary women have. During the rap on "American Life," Madonna rapped about the things she has. Both songs list the same and similar things. In the same manner and both raps contain a “jet” as one of the items owned. In "Contemporary Girl" the lyric goes: “a private jet for you to fly out.” In "American Life" the lyric goes: “Three nannies, an assistant and a driver and a jet” 529. In Aisha's "Contemporary Girl" the lyric goes “You can’t be the man, when you’re a girl.” 530. In "American Life" the lyric goes: “I tried to be a boy. I tried to be a girl” It's the same pun about feminists, but once again, Madonna stole and rewrote Aisha's lyric in such a way as to camouflage the theft, also known in copyright law as the violation "Willful Alterations." 531. In Aisha's "Contemporary Girl" the lyric goes: “No matter what your friends say” In Madonna's "American Life" the lyric goes: “I tried to find a friend” 532. In Aisha's "Contemporary Girl," I write about eating in the rap, the lyric goes “business brunch, the power lunch.” In Madonna's "American Life" she writes about eating in the rap, the lyric is “I'm drinking a Soy latte. I get a double shot” 533. As written above, in "Contemporary Girl," Aisha lists all the things contemporary women have during the rap section:
Designer clothed 534. In "American Life" Madonna does the same, listing and rapping about all the things she has during the rap section as well: I
got a lawyer and a manager 535. It is abundantly clear Madonna went over Aisha's song "Contemporary Girl" and tried to rewrite it as "American Life," Stealing lyrics, melodies, themes and beats. Both songs’ lyrics follow the same order and share mutual lyrics. There are too many duplications and similarities and they follow the same song structure as well. 536. In "Contemporary Girl" Aisha makes references to God, as she is a Christian. She has written about Christianity on her web site many times. In the song "American Life" Madonna makes references to Christianity and Judaism, and is now busy writing and speaking about the Kabbalah religious cult she belongs to. She hadn’t written about or spoken of it before, as she has since she noticed Aisha promoting Christianity. All of a sudden she is pushing religion via a cult, which is absolutely appalling. Even worse, she’s been accused of trying to teach her religious cult’s beliefs to kids via her poorly written children’s books. 537. Both songs have very similar melodies and grooves/beats. Upon listening to the electronic groove/beat in 2003's "American Life" you realize they got it from my Aisha's 2001 song "Contemporary Girl," as it has the same melodic pattern, rhythm and sequence as Aisha's beat for with the accent on the last note of the musical phrase. Madonna, Mirwais and Missy Elliot claimed writer's credit for the song, which took Aisha's lyrics and music, her drumbeat and made it into a synth pattern that runs throughout the copyright infringing song "American Life." SEE EXHIBIT 42 for comparisons. 538. EXHIBIT 42 is a disc of the beats for Aisha's 2001 "Contemporary Girl" and Madonna's 2003 "American Life" separated and placed together - where the songs beat match up exactly. The combined songs show, both have the same rhythm, breaks, time and melodic pattern, only my drumbeat was made into a synth sample - which is why when played together both the "Contemporary Girl" drum beat and "American Life" synth are in complete sync. It's the musical equivalent of a tenor and soprano singing the same line at the same time - different ranges, but they are singing the same thing. 539. Another test, for home studio producers, if you run Aisha's "Contemporary Girl" through Efx processors, synth simulators or certain vocoders, you will come up with the "American Life" techno synth that's heard in Madonna's rip off. 540. When you put the beat for "Contemporary Girl" and "American Life" in a music recording program side by side, as Aisha did to render the comparative mix listed above, the wave files even look the same to the point that you think it's the same song or a copy and paste rendering. 541. In more universal terms, that's like a sample fingerprint found at a crime scene and a fingerprint on file in a police database matching when you run it through the computer. 542. Both songs have a "rap remix," a term coined by Aisha in 2001, and used by Victoria Newton in 2003 to describe Madonna's new song, the then "American Life." 543. Both songs have the exact same structure, which is a very uncommon one. Aisha decided to experiment with the structure when she wrote the song "Contemporary Girl." It was her debut and she wanted to do something different. It is not a common song structure in pop or R&B, especially when performed by the same artist. Another giveaway that Madonna stole the song. The song structure is verse, chorus, verse, chorus, rap and chorus. Madonna duplicated the song structure as Aisha wrote it. 544. Both songs used the same type of studio vocal processing to give it a futuristic sound (a mild vocoding type effect) - only Madonna later used it throughout the song, combined with Autotune, which Aisha has never used, that her producer and fellow plagiarizer Mirwais, applied very generously to her vocals against his wishes. Autotune is used to camouflage vocal deficiencies in people who cannot sing well.
545. Both songs are about the exact same thing - modern life in America for women, all the conveniences we have and realizing without love it doesn’t mean as much. Read the lyrics to both songs and you will see that SEE EXHIBIT 43 and 44.
546. Therefore, in the face of all these overwhelming similarities also known as rip offs and copyright infringement, can the 3 M's - Defendants Madonna, Mirwais and Missy explain how all of this happened. It's absolutely extraordinary - 12 blatant similarities that rip off and duplicate everything from lyrics to beats to songs structure to song topic/theme to melodies, of a song that was written, recorded, copyrighted and released years before their infringing song "American Life."
547. A comparative text and digital breakdown of the Plaintiff’s song “Contemporary Girl” and the Defendant’s song “American Life” show the blaring duplications and similarities, clearing proving the Plaintiff’s copyrights was infringed by the Defendant.
548. Aisha wrote a song titled "New York City" in 2002 and copyrighted it in 2004. This song is on the desktop of her computer and in the Library of Congress. Madonna later announced she had written a song called "I Love New York" in 2004.
549. Aisha wrote an album and designed a web site for a band she planned to sign and name "American Radio." The web site and documents pertaining to the band have been housed on Aisha's computer for years. Madonna and Maverick later signed and named a band "American hi-fi" - hi-fi is a synonym for the word "radio," therefore it is the same name Aisha chose, "American Radio," prior to the Defendants.
550. Sound Off Column - Madonna characterlessly infringed numerous copyrights of Aisha’s web site www.aishamusic.com and www.aisha.tv, in an on going malfeasance of quoting verbatim items from Aisha’s web site writings in her widely read Sound Off Column and in her online Diary, attributing them to herself (Madonna) in stunning details in her own very public TV and print interviews, as listed in detail under the INFRINGEMENT OF THE RIGHT OF ATTRIBUTION section of this Complaint.
551. Madonna’s copyright infringing “American Life” and “Hung Up” are hosted on the AOL, MSN, Warner, Yahoo, Amazon, CDNOW, Wal-Mart, Real.com, Buy.com and Madonna's site, among thousands of other sites, without obtaining: 1. Permission to use Aisha's copyrighted works they stole for the song. 2. Mechanical rights 3. No compulsory licenses 4. No digital rights acquired
552. Madonna has collected millions in international fees and rights associated with the copyrighted woks she willfully stole from Aisha in what can only be described as criminal. As it stands in the industry you must obtain licensee to use copyright holder's works, to use others works and do otherwise is unlawful. The Defendants did not obtain permission and the necessary licenses to use Aisha’s works, furthermore, Aisha never would have granted permission as she dislikes the Defendant’s works as it is vulgar, materialistic and self-serving.
553. The Defendants never obtained n a license in any format, just stole huge amounts of already copyrighted works belonging to Aisha for unauthorized uses. They stole Aisha’s works, enormously profited from them and she, Aisha, the true author and owner of these works, received nothing. Madonna diverted Aisha's ASCAP royalties to her own account at ASCAP by blatantly ripping off her song "Contemporary Girl" and other works from her private unreleased multi-million dollar copyrighted catalog and illegally reassigned the rights to herself, collecting all royalties in a foul act of thievery. Aisha did not authorize anyone to use, take or duplicate any part of her copyrighted works and copyrighted catalog, as it is intended to be exclusive to her works and her label Sonustar.
554. Plots and characters from Aisha's already copyrighted film scripts and synopsises later surfaced as plotlines and rip off characters in Madonna's Kaballah children's book series. Madonna further unlawfully used copyrighted items from Aisha's works and items from her home life in her Kabbalah Children’s books, which constitutes copyright infringement, invasion of privacy, invasion of the Right of Publicity and invasion of the Right of Privacy, which is mentioned in detail Further in this Complaint.
555. Defendant Maverick Film’s forthcoming film “Material Girls” starring Hillary and Haylie Duff is a direct rip off of a copyrighted film treatment for a synopsis Aisha wrote 4 years ago and copyrighted one year ago, before Madonna’s Maverick Film announced their rip off version of Aisha’s already copyrighted works.
556. Aisha's copyrighted, unreleased film synopsis includes a film called "Contemporary Girl" the movie named and patterned after her 2001 song “Contemporary Girl” that Madonna criminally stole and named her rip off of Aisha’s movie "Material Girls" the movie, after her own song - once again, using another of Aisha’s works without authorization, and criminally so. The fact of the matter is Madonna should not have possession of Aisha’s copyrighted catalog that she is criminally using in bold face violations of United Nations, Jamaican, U.S. and British laws.
557. Aisha's copyrighted synopsis is of a film script of twin sisters, one of them a CEO of a very successful company.” Madonna’s rip off is about sisters, one of them a CEO of a very successful company.
558. Furthermore, The Duff sisters look so much alike, like twins, that Haylie Duff dyed her blonde hair brown, so as not to be confused with her sister Hillary, who is also blonde.
558. Madonna's has tried her best to mislead the public into thinking the copyright infringing movie “Material Girls” is about, inspired by and based on her song “Material Girls” but the facts show that it is not. She stole Aisha’s copyrighted synopsis for the film “Contemporary Girl” named after, inspired by and written about her song of the same name.
559. Madonna’s 80’s song "Material Girls" which she claims the movie is about when it clearly is not. “Material Girls” the song is about a woman using sex to get money and gifts from men. All the published synopsises of Madonna’s Maverick Films forthcoming copyright infringing film “Material Girls” is about a modern CEO - which is what Aisha’s 2001 song and movie synopsis for her film “Contemporary Girl” is about.
560. The similarities and duplications to Aisha's previously copyrighted works and Madonna's subsequent knock offs are blaring. Furthermore, Aisha’s “Contemporary Girl” film script synopsis is only housed on her private computers with the only other copy in the Library of Congress in Washington, D.C. where it is federally protected by copyright law. Coincidentally, this is very copyright the Copyright Office agent Robert Blakenburg tried to throw out when he flagged it and did not send the necessary notice informing Aisha of what he had done, knowing that if she did not respond with the additional information the Copyright Office agent required within 120 days, she would lose all rights to her work. For a time she had lost the U.S. federal rights to her works and the criminal Madonna and Maverick Films charged forth putting Aisha’s script synopsis into production thinking it was all clear due to Mr. Blakenburg’s questionable conduct - a man who unprompted and suspiciously told Aisha over the phone, “She can’t sue Warner” (Madonna’s label) and even though she owns copyrights “anyone is free to use her work.”
561. However, Aisha complained to Mr. Blakenburg’s supervisor Laura Lee Fischer and the rights and copyrights to the film that is rightfully hers was restored. Still, Aisha’s script was already protected by the United Nations the moment she wrote it. Additionally Aisha had burned it to a disc, sending herself a poor man’s copyright via U.S. Mail to prove the date of authorship, all of which, including her copyright registrations, precedes Madonna’s and her company Maverick’s.
562. Defendants Madonna and Maverick Films using these works were acts of criminal theft, criminal copyright infringement, hacking, invasion of privacy, grand larceny, corporate theft and fraud, all punishable by several years in prison.
563. The Defendant Madonna and Maverick also stole another of Aisha's unreleased works, which is a film remake (much like she stole the remake for Swept Away in the D'Onofrio vs. Madonna case).
564. Aisha wrote a synopsis and portions of a script for a remake of an old film about a group of friends. She also reworked and recorded a song she experimented with naming the new version "Sam" for the film's accompanying soundtrack with the intent of renaming the main character "Sam" after the song.
565. Madonna and Maverick later bought the rights to a film named "Sam's Lake" which is about a group of friends, one of them, the lead character named "Sam."
566. The reworked script Aisha authored original material for has a lead character named Sam and the film is about Sam and his friends.
567. The lead character in Maverick and Madonna’s film is about a lead character named Sam and the film is about Sam and her friends. Madonna and Maverick Film’s “Sam’s Lake” has not been released yet for Aisha’s to further determine the sum total of the copyright infringements.
568. Once again the clear, undeniable duplications and similarities are there and point to a rip off project of Aisha's private unreleased copyrighted works that are only available in the Library Of Congress and on her private computer.
569. Also apart of Aisha’s multi-million dollar copyrighted catalog is a script about a guy who rejects the girl he is attracted to then she later becomes a famous actress and things go wrong for him.
570. Maverick Film is currently filming the rip off “Chasing Fate” which is listed as a about a man who dumps his fiancée only to watch her ascend to fame and fortune.
571. Once again the clear, undeniable duplications and similarities are there and point to a rip off project of Aisha's private unreleased copyrighted works that are only available in the Library Of Congress and on her private computer.
572. In July of 2004, Aisha wrote in a copyright registration containing scripts and film synopsises, for which she has a certificate of registration, the title "Sonustar Animated Film Series." 6 months later on December 4, 2004 Madonna announced via her friend Victoria Newton, her own animated film she was to undertake for her book The English Roses.
573. Aisha has a copyrighted synopsis of a film about a thief who steals jewels, painting and other valuables, but gets into trouble for stealing from the wrong person.
574. Madonna's book the Adventures of Abdi bears the same theme. A necklace is stolen from a young man who turns out to be the wrong person to steal from, as his father has special powers.
575. Aisha wrote a introduction about a forthcoming song's release that she described as," A song about redemption." This was apart of a copyrighted file associated with www.aishamusic.com that was not published! Madonna later released her children’s books referring to one of them, Yakov and The Seven Thieves as, “A story about redemption,” a clear rip off of Aisha's line that is copyrighted and unreleased.
576. Aisha has a copyrighted script synopsis that is set in Oxford University. Defendant Victoria Newton later fabricated an article about Madonna planning to enroll at Oxford University," which due to said singer's lack of qualifications and intelligence was denounced by the school in a formal statement issued to the press. The story was a complete lie Defendant Victoria Newton made up and printed from Aisha’s private copyrighted script to help Madonna’s horrible image, as it was unfeasible under Oxford University rules for Madonna to register. Defendant Victoria Newton clearly got the idea for that fake story from Aisha's unreleased copyrighted synopsis.
577.This is one of many incidents/times where in conjunction with Defendant Madonna, Defendant Victoria Newton criminally used copyrighted items from Aisha’s private copyrighted multi-million dollar valued catalog of songs, scripts, music videos, book manuscripts and picture treatments, for her disgraceful, poorly written articles and fraudulent stories in the Sun Newspaper UK, for which many stars have sued her and said newspaper and won settlements.
578. The Defendants had no right being in Aisha’s computers at anytime via the hired hacker they commissioned to criminally copy Aisha’s private copyrighted works, which they later criminally used against U.S. and U.N. laws. These acts constituted several felonies, punishable by imprisonment.
DEFENDANTS MADONNA, DISNEY, GARY MARSHALL, MICHAEL EISNER, BUENA VISTA PICTURES, WALT DISNEY RECORDS, WALT DISNEY PICTURES, MEG CABOT, GINA WENDKOS, SHONDA RHIMES, BERTRAM FIELDS:
579. Defendants Madonna, Disney, Gary Marshall, Michael Eisner, Buena Vista Pictures, Walt Disney Records, Walt Disney Pictures, Meg Cabot, Gina Wendkos and Shonda Rhimes criminally used a script from Aisha’s private unreleased multi-million dollar valued copyrighted catalog and made it into the “Princess Diaries 2” in boldface, criminal violation of Jamaica, U.S. and United Nations laws.
580. Madonna criminally sold Aisha’s script to her long time employer, colleague, costar and friend of 20 years, director Gary Marshall, who knowing it did not belong to her, criminally used it anyway to make his film “Princess Diaries 2.” Defendant Disney and Michael Eisner knew of the criminal origins of this script, but used, filmed and distributed it anyway, causing further damage to Aisha. Further more, Michael Eisner has been passing around Aisha’s private unreleased multi-million dollar valued copyrighted catalog around Disney’s various divisions and criminally using it, as mentioned further in this segment of the Complaint.
581. During August of 2004, “The Princess Diaries 2” was released in theaters. Aisha only went to the theaters once last year and it was to see “The Passion Of The Christ,” therefore she had not seen the film “The Princess Diaries 2” to realize what the nefarious, despicable Defendants had done in criminally stealing one of her copyrighted scripts from her catalog found only on her computers and in the Library of Congress in Washington, D.C.
582. It wasn’t until this July of 2005 that Aisha saw the film ”The Princess Diaries 2” on television that she realized the Defendants with strong, prominent ties to Madonna, were criminally using her private copyrighted intellectual property catalog.
583. Further damning evidence comes courtesy of Aisha’s web site statistics that registered over 140 visits to her web site from Disney’s headquarters’ in Burbank, California, before the filing of this lawsuit or Aisha’s even realizing they’d stolen her work. They’ve know exactly who she is for a very longtime after criminally procuring her private unreleased multi-million dollar valued copyrighted catalog from their frequent collaborator Madonna. Acts worthy of imprisonment.
584. Additional damning evidence comes courtesy of the Disney channel show “Raven,” which tellingly violated Aisha’s copyrights and “Rights to Privacy and “Rights To Publicity.”
585. Defendant Disney misappropriated Aisha’s image, copyrighted music and web site content for use in the Disney show “Raven,” which contained a character who was a black blonde haired singer named “Myisha.” Aisha is a black blonde haired singer. Myisha’s tune on the show contained similar lyrics to Aisha’s 2001 “Contemporary Girl” and the character’s name is very similar to Aisha’s, both ending in the letters “isha.”
586. They violated Aisha’s copyrights for “Contemporary Girl” in scripting lyrics for the show’s character that used similar lyrics to Aisha’s song. Both Aisha’s Contemporary Girl and the Disney rip off song are about an old fashioned girl with a private jet.
587. Damning proof that executives at Disney know exactly who Aisha is and has known for a long time as they have criminally been using her works, in acts worthy of imprisonment.
588. Further proof of infringements from Aisha’s private unreleased multi-million dollar valued copyrighted catalog are Aisha copyrighted a script titled “Ice Princess” and months later Disney released a movie titled “Ice Princess” with a song by Madonna, "Ray Of Light," removed from the soundtrack at the last minute. However the song remained in the film. The same two criminal culprits again - Madonna and Disney.
589. Aisha copyrighted a soccer film that Disney may have used for the forthcoming 2005 film “Goal!” The film’s synopsis is similar to one of Aisha’s 2002 soccer based copyrighted works. Upon release of the film, the full extent of the infringement can be determined and this Complaint amended.
590. A joke from another of Aisha’s scripts copyrighted years ago was used in Disney’s 2005 film “Herbie: Fully Loaded.”
591. Preliminary comparisons reveal a samba record copyrighted by Aisha is similar to a later released Disney samba CD advertised on the Internet. The full extent of the infringements will be determined shortly and this Complaint amended.
592. Aisha copyrighted the hook for a song titled “Superchick.” A Disney soundtrack later featured a group called “Superchick” who are on a Disney soundtrack that also features Madonna.
593. They have been illegally making use of Aisha's works in violation of Jamaican, U.S. and U.N. Laws. Here are a few examples of the infringements to be listed in greater detail in court:
BLATANT THEFTS OF AISHA’S COPYRIGHTED SCRIPT FROM HER CATALOG TO MAKE THE DISNEY COPYRIGHT INFRINGING FILM “THE PRINCESS DIARIES 2”
594. Aisha wrote and copyrighted a script for a film she intended to make titled "Royal Monarchy." It was written in 2000 and the first copyright registration for the film script was made in 2002 with the second, updated version copyrighted in March 2004 - all before Disney’s copyright infringing “Princess Diaries 2” was filmed and released.
595. 7 months later, in September 2004 Madonna's employer, colleague, collaborator, friend of 20 years and former co-star (in the film “A League Of Their Own”) released the copyright infringing film "The Princes Diaries 2" through Buena Vista/Disney. It wasn't until July 2005 that Aisha saw the movie for the first time and she realized what they'd done in stealing her private copyrighted work only found on her computers and in the Library of Congress in Washington, D.C.
596. The original “Princess Diaries” was about a made up country named Genovia and the film was set in San Francisco, California in America. For the sequel, Madonna’s long time friend, costar, co-collaborator and employer Gary Marshall criminally used Aisha’s already copyrighted script from her private catalog that Madonna procured a hacker obtained copy of and had been busily and criminally using for her own projects at Warner Bros and Maverick Records, to name a few. The sequel was set in a clearly British setting to rip off Aisha’s British script about British royalty.
597. One of "The Princes Diaries 2" copyright infringing writers, Defendant Shonda Rhimes, was recently sued for infringing the copyrights of another writer to make the Britney Spears flop “Crossroads.”
598. Copyright infringement is a way of life for Madonna and her pal Shonda Rhimes, who also included a Madonna song in the copyright infringing film “Crossroads” netting Madonna money in soundtrack and film synchronization rights fees.
599. It is clearly a system of one hand washes the other - even if the hands are committing crimes that flagrantly break U.S. and U.N. laws.
600. The film “Crossroads” also served to get Madonna’s name into the mainstream again among younger audiences, the film’s demographic, as Shonda Rhimes scripted a shout out to Madonna in the film via teen idol Britney Spears idolatrously dancing and singing to a Madonna song in the film in her underwear.
601. It has been written numerous times in the press that 47-year-old Madonna tries to attach her name to younger popular stars and youthful vehicles in attempts to stay relevant with youth audiences, as a newspaper article wrote a about a survey which revealed many younger audiences didn’t know who Madonna was. They “thought she was a scientist.”
602. The “Princess Diaries 2” ripped off Aisha's already copyrighted script from her catalog in perfect detail and replication. Aisha’s copyrighted script was about a British royal family she made up, drawing on her British heritage in writing the script.
603. Half the maternal side of Aisha’s family has lived in England for the past 40 years. 3 generations of them now reside there. And her paternal great-great grandfather was a white, blue-eyed British sailor who moved to Jamaica from England.
604. The original “Princess Diaries” was in no way British. Defendant Gary Marshall and his co-defendants on the film twisted it to criminally use Aisha’s brilliant British script that he criminally got from his costar, co-collaborator and employee, Madonna.
605. Defendant Gary Marshall knows Madonna is a perpetual thief whose head is devoid of an original thought, but he criminally used the script he bought from her that he knows was not hers to begin with - further crediting himself and his staff with writers credit for something they know they bought and did not write.
606. Madonna was to be apart of director Gary Marshall’s Disney film “Chicken Little” as part of a deal for criminally supplying them with Aisha’s copyrighted works, but her name disappeared from the project at the last minute, to avoid any recent public association/link with Gary Marshall in light of the criminal misdeeds being committed behind closed doors in criminally using works that do not and never have belonged to them.
607. However, Aisha caught on and connected the dots finding all the business links between Madonna and her co-defendants. Sadly for Madonna, Marshall and Disney, Aisha saw the film a couple months ago and researched them all on the internet, cross referencing their names, which brought up a litany of business, legal and personal ties between Madonna, Marshall, Shonda Rhimes and Disney. Aisha further researched and found their history of copyright infringement in committing these very same misdeeds against others. It is a way of life for them that break numerous civil and criminal laws, both domestic and international.
608. The convoluted script sequel for the “Princess Diaries 2” looked ridiculous, as it ripped off Aisha’s British script and used it for a made-up non-British country named Genovia, which was plain stupid. Genovia was supposedly somewhere in Europe other than Britain, yet was blatantly British in the sequel “The Princess Diaries 2” when in the original “Princess Diaries” it was not at all British.
609. The film was nonsensical due to these changes and critics severely panned it and the copyright infringing writing team behind it in cutting reviews.
610. To fully steal Aisha’s copyrighted script as the Defendants did, they turned the made up non-British country Genovia from the first “Princess Diaries” film into a full fledged British country adding a British prince, a British styled parliament, A British styled monarchy and two dozen exact scenes they stole from Aisha's already copyrighted script, ripping them off to in exact detail and content.
611. In trying to make their sequel British in order to criminally use Aisha’s brilliant British script, Defendants Gary Marshall, Shonda Rhimes, Gina Wendkos and Meg Cabot did the following acts of criminal thievery:
612. Aisha's script was copyrighted and written years before the “Princess Diaries 2” was ever made, centers on an abdication/change of throne crisis. The Princess Diaries 2 centers on an abdication/change of throne crisis.
613. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a scene where a special jewelry display electronically opens up to reveal the royal jewels. The Princess Diaries 2 has a scene where a special jewelry display electronically opens up to reveal the royal jewels. Note: Aisha made this up for her script, as in Britain the Royal Jewels are not housed in this manner. Prima Facie evidence the team behind the “Princess Diaries 2” criminally stole this from Aisha’s already copyrighted script.
614. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a British Parliament scene. The Princess Diaries 2 also has a British Parliament scene, but pretended it belonged to the made up non-British country Genovia.
615. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a handsome British prince vying for a princess. The Princess Diaries 2 also has a handsome British prince vying for a princess. Since their film is set in a made up country called Genovia, should the handsome prince not have been Genovian. This whole British element was introduced to rip off Aisha’s brilliantly written British script that they profoundly and crassly butchered.
616. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a horse-jumping scene. The Princess Diaries 2 also has a horse-jumping scene.
617. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has an American friend come visit. The Princess Diaries 2 also has an American friend come visit.
618. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a scene with a “talk with the prince by a lake.” The Princess Diaries 2 also has a scene with a “talk with the prince by a lake.”
619. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a scene with unethical paparazzi and tabloids chasing the royal family. The Princess Diaries 2 also has a scene with unethical paparazzi and tabloids chasing the royal family.
620. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a ball scene. The Princess Diaries 2 also has a ball scene.
621. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a throne succession scene. The Princess Diaries 2 also has a throne succession.
622. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a scene with bickering (twin) brothers. The Princess Diaries 2 also has a scene with almost identically looking bickering twin brothers.
623. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a lawn sport scene. The Princess Diaries 2 also has a lawn sport scene.
624. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a character named Anna. The Princess Diaries 2 also has a character named Anna.
625. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a butler, footman and 2 maids (which are British servants). The Princess Diaries 2 also has a butler, footman and 2 maids (which are British servants).
626. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a scene where a princess and prince interact with the crowds. The Princess Diaries 2 also has a scene where a princess and prince interact with the crowds.
627. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a tennis scene. The Princess Diaries 2 also has a tennis scene.
628. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a royal wedding. The Princess Diaries 2 also has a royal wedding.
629. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has an arranged marriage. The Princess Diaries 2 also has an arranged marriage.
630. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a scene by a fountain. The Princess Diaries 2 also has a scene by a fountain.
631. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a polo scene. The Princess Diaries 2 also has a polo scene.
632. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a scene where they try to choose a suitor for the royal from eligible people. The Princess Diaries 2 also has a scene where they try to choose a suitor for the royal from eligible people.
633. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a press secretary meeting with the royals. The Princess Diaries 2 also has a press secretary meeting with the royals.
634. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a scene with the royals helping less fortunate people. The Princess Diaries 2 also has a scene with the royals helping less fortunate people.
635. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a dying king The Princess Diaries 2 also has a scene referring to dying king.
636. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a designer come in to dress the royal. The Princess Diaries 2 also has a designer come in to dress the royal.
637. Aisha's script copyrighted and written years before the Princess Diaries 2 was ever made has a royal frowning and upset on a staircase scene. The Princess Diaries 2 also has a royal frowning and upset on a staircase scene.
638. Those are exact duplications of a private copyrighted script that comes from Aisha’s private copyrighted multi-million dollar catalog with registrations of said script made by Aisha years before the Princess Diaries 2 was ever written, filmed or released.
639. The only places Aisha’s script has been that the Defendants procured via criminal means is housed on Aisha's private computers (which she subsequently found out was hacked) and in the Library Of Congress in Washington, D.C.
640. Madonna has clear, well-established ties to the makers of the “Princess Diaries 2” and its distributor Defendant Disney, which was run by the often slammed, unethical Defendant Michael Eisner.
641. Madonna criminally sold Aisha’s script from her copyrighted catalog worth millions, in exchange for money, product placement and career advancement at Disney’s film divisions and with Defendant Gary Marshall who has had several hit films.
642. Madonna’s film career has been a total bust and the subject of constant press and audience ridicule and mockery. She so desperately wants to achieve a successful, well-acclaimed film career, but never has due to her gross inability to act.
643. Her actions in this case were criminal, underhanded, despicable, unconscionable and worthy of criminal prosecution.
644. There is further evidence that suggests Disney, Michael Eisner and Jerry Bruckheimer are using other of Aisha’s copyrighted scripts for the making of the “Pirates Of The Caribbean 2” and the “Pirates Of The Caribbean 3,” which is currently being filmed.
645. In December of 2004, Aisha recommended the Christian film “The Chronicles of Narina” on her site. A site www.aishamusic.com, as mentioned earlier in this Complaint, has registered almost 140 site visits from Buena Vista/Disney Film’s headquarters in Burbank, California.
646. Four months after Aisha recommended the film “The Chronicles of Narina” on her web site, Disney announced they were going to remake the film “The Chronicles of Narina.”
647. In related events, Defendant Michael Eisner even went as far as showing his son, an aspiring filmmaker named Breck, Aisha’s private copyrights that the Defendants criminally gained a copy of via Madonna in exchange for cash and opportunities to advance her failed film career.
648. Two years ago Aisha copyrighted a special video treatment to be shot in the "Sahara.” She titled the video “Sahara.” This year, Michael Eisner’s son, the aforementioned Breck optioned Clive Cussler's novel "Sahara" and made it into a box office dud, for his directorial debut.
650. Thanks to Madonna, Mr. Eisner has been criminally passing around Aisha's unreleased copyrighted catalog around Disney's divisions and making criminal use of them in said company, as illustrated by the blatant criminal uses of Aisha’s already copyright catalog, with works from which illegally appearing in such Disney films and shows as “The Princess Diaries 2,” “Herbie: Fully Loaded,” “Raven” (TV Show) and “Goal!” - all without her permission. These are felonious acts punishable by imprisonment, as Aisha’s copyrighted works are protected by Federal copyright law, Jamaican law and United Nations laws, which he willfully violated in conjunction with his co-defendants.
651. Defendant Michael Eisner is possibly the most hated man in the entertainment industry today due to the vile, unconscionable things he has done to so many entertainment industry professionals, who publicly spoke out against him for it.
652. He was unceremoniously forced out of Disney, sued by the Disney board and shareholders, who are comprised of members of the general public and the company’s living namesakes.
653. Michael Eisner has forever tarnished and muddied the Disney name and legacy with a litany of unethical, cruel, disgraceful business and personal misdeeds. During the case involving Michael Ovitz, which was televised, Michael Eisner was shown to be an untrustworthy, overly competitive, reckless, covetous, deviously, scheming liar.
654. Breck Eisner’s directorial debut film flop “Sahara” was also the subject of a 90 million dollar Bert Fields litigated suit. As mentioned above, Defendant Bert Fields is Madonna’s lawyer. Fields sued on behalf of Clive Cussler. Breck Eisner had promised Cussler script control, but according to Cussler’s lawsuit, had failed to do so and destroyed the film.
655. This deviation from the novel at novice director Breck Eisner’s hand was directly responsible for its flop. After all, the novel was a best seller. Thanks to Breck Eisner, the movie was not. One critic wrote, "If Sahara weren't so dumb, it might have been a lot of fun" (Rob Blackwelder).
656. Madonna’s lawyer Defendant Bert Fields said in an Internet Movie Database article titled, "Huge Lawsuit Takes Shape Over 'Sahara" that, “They promised Mr. Cussler approval of the script. He wanted to protect his book. They departed fundamentally from the screenplays he approved." Fields flirted with the idea of blocking the film, but opted to litigate it instead, according to the article. Fields told Celebrity Justice, “We intend to take the matter to trial and fully litigate it. I wanna get these people in front of a jury."
657. Considering the (Defendant) Madonnaesque proportioned film failure of Breck Eisner’s directorial debut “Sahara,” maybe Defendant Fields should have gone through with his threat of blocking the film, after all.
658. Defendant Bertram Fields is the arrogant author of the self-aggrandizing, superfluous book "Players: The Mysterious Identity Of William Shakespeare” where he set forth the theory William Shakespeare didn't write the body of literary work attributed to him.
659. After years being the lawyer for Madonna, an artist sued many times for plagiarism and copyright infringement in cases that credibly revealed she did not write many of the works attributed to her, Mr. Fields clearly feels he is an expert on plagiarists and copyright infringers.
660. His claims about William Shakespeare have been met with derision by scholars and audiences alike.
661. It is actually quite amazing that 4 months after Aisha wrote, copyrighted and published a scathing article titled "Material Girl or Material Thief," which set forth the theory that Madonna is the entertainment industry’s worst plagiarist and copyright infringer, Defendant Bertram Fields published the above mentioned book, using the same premise, theory, theme, structure and style to state that Shakespeare was one of the world’s greatest plagiarists. Maybe the irony and hypocrisy of Mr. Field’s actions is lost on him.
662. Aisha’s article has been read by scores of people and can be found at www.aishamusic.com/plagiarism.htm
DEFENDANTS MADONNA, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, MAD GUY ENTERTAINMENT
663. Defendants Guy Ritchie, Luc Besson, Steve Christian, Virginie Silla, Pierre Spengler, Ska Films, Europacorp and Mad Guy Entertainment criminally stole a a movie poster from one of Aisha’s scripts contained in her multi-million dollar copyrighted catalog and criminally used it for Madonna’s husband’s film “Revolver.”
664. Madonna’s husband and fellow Kabbalahist, Defendant Guy Ritchie stole one of Aisha’s already copyrighted film posters from one of Aisha’s gangster film scripts and criminally used it for his widely panned film “Revolver.”
665. To further prove the criminal infringements and corporate theft of Aisha’s already copyrighted works from her catalog stored on her private computers with the only other copy in the Library Of Congress in Washington, D.C., “Revolver” had another movie poster, which was quite dull and unflattering. Madonna, Guy Ritchie and their co-defendants were having trouble selling their film. To revamp it they tossed the original movie poster that was already given to the press months before, and criminally took a poster treatment from Aisha’s copyright, making it into the new “Revolver” film poster to help aid in distribution and to spark public interest. The film flopped this month anyway, reportedly due to its poor content and Kabbalah cult references that test audiences, critics and fans disliked.
666. The film was just released a few days ago and only in Europe, therefore, additional time is needed to view the film “Revolver” to determine the full extent of the infringements and corporate theft to make amendments to this Complaint as required.
DEFENDANTS MADONNA, MAVERICK FILMS, MAVERICK RECORDS, WARNER BROS, ARCHLIGHT FILMS, GUY OSEARY, MARK MORGAN, MARTHA COOLIDGE JOHN QUAINTANCE, AMY RARDIN, SUSAN O'TOOLE, MICHAEL MENDELSOHN, PATRIOT PICTURES AND PATRIOT ADVISORS:
667. Beginning in March of 2005, articles were placed in publications by Madonna and Defendant Maverick Films falsely and fraudulent attempting to establish ownership of Aisha's copyrighted films to the public, while other April 2005 headlines blared "Madonna all set to become a film producer." However, she was producing films that do not belong to her and were pilfered from Aisha's unreleased copyrighted works in a very devious, criminal manner.
668. Madonna consistently misappropriated, plagiarized and fraudulently attributed copyrighted items such as songs, scripts, book manuscripts, photo treatments, articles, plots, themes, concepts, characters and ideas from Aisha’s original copyrighted catalog and in some instances from her website, to herself in her very public and widely disseminated magazine, newspaper, television show interviews, her children's book series and several of Maverick Film’s planned and in production movies in acts that can only be described as criminal.
669. Madonna handsomely profited stealing Aisha's copyrighted works for these projects and untold others, as the infringements continue to crop up in press announcements by Madonna, of projects that duplicate Aisha's copyrighted works that she criminally going around Hollywood making million dollar deals with.
670. As mentioned in paragraphs 555-572 Madonna, Maverick Films, Maverick Records/Warner Bros records have criminally stole items from Aisha’s multi-million dollar valued copyrighted catalog for use at Maverick Films and the distributor of the film’s soundtracks Maverick Records/Warner Bros in boldface violations of U.S. and U.N. civil and criminal laws. These stolen items were used to make the forthcoming Maverick Films projects “Material Girls,” “Sam’s Lake” and “Chasing Fate.”
671. Additionally, Aisha copyrighted items such as “Grave Diggers: Concrete Diggers” only to read headlines shortly after of Maverick Films shooting a movie called “Grave Dancers.”
672. There are other Maverick Films projects currently in production, the full extent of the thefts of Aisha’s works used for these films, to be revealed during discovery and at trial. Upon release of these copyright-infringing films, additionally criminally charges will be pressed and additional lawsuits will be filed against the Defendants.
673. Defendants Madonna (Maverick Films owner), Maverick Films, Martha Coolidge (director), Susan Jensen (writer), John Quaintance (writer), Amy Rardin (writer), Jessica O'Toole (writer), Michael Mendelsohn (co producer), Mark Morgan (co-producer), Guy Oseary (co-producer) and Patriot Pictures aka Patriot Advisors (co-producers) willfully infringed and stole a script from Aisha’s copyrighted private multi-million dollar valued catalog for their subsequent in production film “Material Girls” starring Hillary and Haylie Duff. They used copyrighted materials that were obtained through criminal means - hacking, invasion of privacy, grand theft larceny, corporate theft, conversion and fraud, which are violations of several international criminal laws and U.S. constitutional laws. “Material Girls” is being directed by Defendant Martha Coolidge.
674. Even more damningly, Defendant Martha Coolidge directed a film titled, "The Prince And Me" starring Freddy Prinze jr and Julia Stiles, released in 2004 through Defendant Lion's Gate Films, distributed by Paramount Pictures, that bears blatant duplications and similarities to a 2002 copyrighted synopsis and script belonging to Aisha. The same one that Defendants MADONNA, DISNEY, GARY MARSHALL, MICHAEL EISNER, BUENA VISTA PICTURES, WALT DISNEY RECORDS, WALT DISNEY PICTURES, MEG CABOT, GINA WENDKOS, SHONDA RHIMES used to criminally make the “Princess Diaries 2.”Aisha’s copyrighted script was registered with the Library Of Congress two years before the subsequent infringing film, "The Prince And Me".
675. The infringing film “The Prince And Me” was written and produced by Defendants MARK AMIN, KATHERINE FUGATE, JACK AMIEL and MICHAEL BEGLER. Defendant Mark Amin, who has been an executive producer for 17 years, all of a sudden was credited as co-writer of a copyright infringing script - a very odd and untimely jump. You don't all of a sudden become a screenplay writer after 17 years in the film industry as an executive producer.
676. Aisha's copyrights were obtained before the creation and announcement of these infringing projects by Madonna and her employers and partners. In the case of the "Material Girls" film that Madonna has clearly stolen from Aisha's "Contemporary Girl" film synopsis, it is much like what happened to celebrated Washington Post writer and humorist Art Buchwald, who sued Paramount Studios, for using his copyrighted synopsis without his permission and with no compensation, to make the film "Coming To America." Buchwald sued and won (Buchwald v. Paramount).
677. Madonna's forthcoming Maverick Films musical, a project that Martin Scorsese was apart of, but bowed out of, titled "Hello Suckers" contains a song pilfered from one of Aisha's telephone conversation that has now mysteriously materialized as the song "The Devil Wouldn't Recognize You."
678. All film soundtracks for these infringing films and songs are released through Defendant Maverick Records, a subsidiary of Defendant Warner Bros Records.
DEFENDANTS MUSIC TODAY INC AND BRITNEY SPEARS
679. The Defendants, Madonna’s fan club managers Music Today Inc and Madonna’s fellow Kabbalah Center member and protégé Defendant Britney Spears infringed Aisha’s copyrights. Jive Recording artist Britney Spears has been sued many times for infringing several writers and singers copyrights.
680. Defendants Music Today Inc willfully plagiarized and infringed Aisha's copyrights when they came up with a column in January of 2005 that ripped off Aisha's "Sound Off Column," naming theirs "Streams Of Consciousness" for client Britney Spears.
681. Both artists, Aisha and Britney Spears, are now the only two singers with a column, both bearing the same initials and about the same things, namely religion. Britney Spears’ column is a rip off of Aisha’s already established and copyrighted column. Not only did they rip off Aisha’s “Sound Off Column,” they began stealing the copyrighted contents as well.
682. Spears frequently plagiarized Aisha’s web site writings for her own plagiaristic web site musings, which constitutes copyright infringement. Aisha obtained her copyrights before Spears infringed several of them.
683. The Defendants willfully ripped off Aisha's 3 year old column, picking a similar name, theme and textual content for their client Britney Spears, who is duly aware of what is going on and contributed to the malfeasances by deliberately plagiarizing Aisha’s writings on several occasions attributing it to herself. When Aisha complained about this on her site on March 11, 2005, naming all the similarities listed above such as same initials and theme, Britney's web column was promptly renamed Love B: Streams Of Consciousness two weeks later.
DEFENDANTS MADONNA AND CHRISTOPHER CICCONE
684. Aisha wrote and copyrighted business plans, housing them on her computers. Unbeknownst to her, her computers were later hacked. Defendant Christopher Ciccone, who upon information and belief has been privy to and seen pilfered copyrighted documents and business plans that were illegally copied from Aisha's computers by a hired hacker. Christopher Ciccone in conjunction with his sister, Madonna, has already used two of Aisha's copyrighted business plans they pilfered from her personal computers.
685. Two weeks after Aisha made the web site for a business she plans to start, a real estate company and web site for it she copyrighted, named "Son Real Estate Investment Corp" and "Son Realty" on the computer which Madonna has been paying a hacker to steal her copyrighted works from, and after Aisha spoke with her mom about the venture in the privacy of their home, Madonna placed an article in the press stating her brother has just gotten work renovating the Fortune Realty offices at 1300 Brickell Avenue in Miami, the same city and exact same line of work Aisha was venturing into - renovating buildings and homes in Miami. SEE EXHIBIT 7.
686. This is not the first time Christopher Ciccone and Madonna have surreptitiously ripped off one of Aisha's copyrighted business plans. In November of 2002 Aisha wrote in her copyrighted online Diary that she was starting a restaurant with her mom and that she'd just registered the name. The name she registered on November 1, 2002 is “The Continents” SEE EXHIBIT 8. The name Madonna and her brother later chose for their restaurant is “The Central,” a restaurant that was later located at 8590 Sunset Blvd, West Hollywood, CA 90064 - the first four letters being the same as the name Aisha's chose and registered for her restaurant business plan. The Ciccone's "The Central" restaurant failed miserably in less than a year and is now out of business.
DEFENDANTS MADONNA AND CALLOWAY ARTS AND ENTERTAINMENT:
687. Defendants willfully used characters, plotlines, scenes, inventions and conveyances stolen from Aisha's copyrighted works housed on her computers and in the Library Of Congress for Madonna’s Calloway Arts and Entertainment distributed Kabbalah children’s book series.
688. As mentioned in paragraph 554, plots and characters from Aisha's already copyrighted film scripts and synopsises later surfaced as plotlines and rip off characters in Madonna's Kaballah children's book series. Madonna further unlawfully used copyrighted items from Aisha's works and items from her home life in her Kabbalah Children’s books, which constitutes copyright infringement, invasion of privacy, invasion of the Right of Publicity and invasion of the Right of Privacy, which is mentioned in detail Further in this Complaint.
689. Defendants Madonna and Calloway Arts and Entertainment - produced and released a copyright infringing book series containing the books "The English Roses," "Mr. Peabody’s Apples," "Yakov and the Seven Thieves," "The Adventures of Abdi" and "Lots De Casha" and an accompanying children’s fashion line called “The English Roses” that criminally stole items from Aisha’s private unreleased fashion line housed on her computers (a duplicate in the Library of Congress) that she later found out was criminally hacked, with works contained thereon surfacing in works by the Defendants, with Madonna as the ringleader in the criminal acts.
690. Aisha copyrighted a film script synopsis about a thief who steals jewels, painting and other valuables, but gets into trouble for stealing from the wrong person. Madonna's book “The Adventures of Abdi” bears the same theme. A necklace is stolen from a young man who turns out to be the wrong person to steal from.
691. Aisha wrote an introduction about a forthcoming song's release that she described as, “A song about redemption."
692. Madonna's later released book titled "Yakov And The Seven Thieves" that bore the press introduction "It is a story about redemption,” a clear rip off of Aisha's line that is copyrighted and unreleased and only found in her copyrighted files on her computers and in the Library Of Congress.
693. A film script apart of Aisha’s copyrighted multi-million dollar catalog is about a fictitious royal family - a member of which is a queen. The film contains a scene regarding royal jewels. Madonna’s children’s book “The Adventures of Abdi” is about a fictitious queen, her family with storylines about royal jewels.
DEFENDANTS MARTHA COOLIDGE AND LIONS GATE FILMS:
694. Defendant Coolidge directed a film titled "The Prince And Me" released in 2004 through Defendant Lion's Gate Films, distributed by Paramount Pictures, that bears blatant duplications and similarities to a 2002 copyrighted synopsis and script of Aisha’s that was registered with the Library Of Congress two years before the subsequent film, "The Prince And Me," starring Freddy Prinze jr and Julia Stiles. Defendant Martha Coolidge is also director of the forthcoming Madonna/Maverick Films movie “Material Girls.” Once again, another clear legal and business tie to Madonna and the criminal theft of Aisha’s multi-million dollar valued copyrighted catalog that is housed on her computers that were criminally hacked, with the only other copies in the Library of Congress in Washington, D.C.
695. The film was written by Defendant Mark Amin, who has been an executive producer for 17 years, then all of a sudden was credited as co-writer of a copyright infringing script/film "The Prince And Me,"- a very odd and untimely jump. You don't all of a sudden become a screenplay writer after 17 years in the film industry as an executive producer. The film was also co-written and produced by Defendants, Katherine Fugate, Jack Amiel and Michael Begler.
DEFENDANTS MADONNA, WARNER BROS, WARNER BROS RECORD, TIME WARNER, WARNER VISION AND JONAS AKERLUND:
696. The Defendants Madonna and Jonas Akerlund, video director, are habitual copyright infringer (Salvati v. Madonna and Akerlund), having been sued before for the copyright infringing Madonna music video “Ray Of Light.” Madonna was also sued for her copyright infringing video “Hollywood” (Bourdin v. Madonna).
697. Jonas Akerlund is the director of Madonna's forthcoming Re-invention Tour DVD titled "The Reinvented Process" also known as "Madonna: Let Me Tell You A Secret," which upon information and belief was to be screened at the prestigious Cannes Film Festival this year, but the board rejected it as being below their standards. The Re-invention Tour DVD in question contains the copyright infringing song "American Life" as its centerpiece, which was unlawfully stolen from Plaintiff Aisha’s copyrighted song "Contemporary Girl."
698. Madonna was recently sued by accomplished British director Hamish Hamilton for deliberately not paying him and his crew $350,000 in fees accrued upon her request, to film segments of her Reinvention Tour for a concert special that is also to be a DVD (Hamilton v. Madonna). This footage also contains the copyright infringing song “American Life” stolen from Aisha’s copyrighted song “Contemporary Girl.”
699. Hamish Hamilton incurred great expense filming her tour, on a “play or pay” basis. When subsequent deals fell through with CBS and HBO, the Defendant Madonna decided she was not going to pay Mr. Hamilton the $350,000 that was owed, in spite of the fact that magazine reports state she personally made $54,000,000 from said tour. Further evidence that Madonna does not respect other people’s labor, time and money.
700. Madonna’s “Re-invention Tour” was conducted around the copyright infringing song “American Life,” which is its centerpiece and the lead off single from the album of the same name that she stole from the Plaintiff’s copyrighted song “Contemporary Girl.”
701. Both Madonna DVDs are to be distributed internationally later this year by Defendant Warner Bros’ and their company Defendant Warner Vision.
702. Based on press reports of content, there are other infringing items pilfered from Aisha's unreleased copyrighted works contained in said forthcoming DVDs, the full extent of which to be revealed during discovery.
DEFENDANTS MADONNA, DONATELLA VERSACE, MARIO TESTINO, VERSACE INC, PRATO VERDE:
703. Madonna, Donatella Versace, Versace, Prato Verde and Mario Testino unlawfully used Aisha's copyrighted bio, online diary, web site Flash film and references to her copyrighted song “Contemporary Girl” to create a multi-million dollar ad campaign that ripped off Aisha's image, likeness and recognizable aspects of her persona, for profit, infringing and violating her copyrights, Right To Privacy and Right To Publicity - SEE EXHIBITS 41.
DEFENDANTS MADONNA, MUSIC TODAY INC AND BRITNEY SPEARS:
704. Upon information and belief, Defendant Music Today Inc runs a web hosting and fan club management company in Virginia and are responsible for Madonna and fellow Kabbalahist and co-defendant Britney Spears' official web sites. Spears, like Madonna, also frequently violates Aisha's Copyrights "Right of Attribution" in her own interviews, after Aisha publishes articles online to her frequently copyrighted web site.
705. The Defendants Music Today Inc sell copyright infringing items such as the “American Life” CD single, “American Life” CD, “American Life” sheet music book, “Madonna Remixed and Revisited” (which contains the copyright infringing song “American Life”), Madonna’s copyright infringing children’s book series featuring the books “The English Roses,” “Adventures of Abdi,” “Mr. Peabody's Apples,” “Lotsa De Casha” and “Yakov and The Seven Thieves.” These books also criminally violate Plaintiff Aisha’s Right to Privacy and Right to Publicity.
706. Defendants Music Today Inc further plagiarized and infringed Aisha's copyrights when they came up with a column in January of 2005 that ripped off Aisha's frequently copyrighted "Sound Off Column," naming theirs "Streams Of Consciousness" for client Britney Spears.
707. Both artists, Aisha and Defendant Britney Spears, are now the only two singers with a column, both bearing the same initials and about the same things on a regular basis, with Aisha copyrighting and publishing hers first, with Spears on several occasions following suit in ripping off Aisha’s copyrighted Sound Off Columns and Diary entries shortly after. EXTENSIVE EXHIBITS ILLUSTRATING THE WILLFUL THEFTS TO BE PRESENTED IN COURT.
708. The Defendants willfully ripped off Aisha's 3-year-old column, picking a similar name, themes and content for their client Britney Spears, who willfully participates in the infringements, evidenced by the fact that she says she writes her own column and journal entries - column and journal entries that have violated Aisha’s copyrights on several occasions.
709. When Aisha publicly complained about this on her own web site on March 11, 2005, naming all the copyright infringing similarities listed above and how Spears and Music Today Inc were deliberately violating her copyrights, Britney Spear's web column was promptly renamed “Love b: Streams Of Consciousness” two weeks later with the content streamlined.
710. Defendant Britney Spears routinely takes copyrighted items from Aisha’s Sound Off Column and online Diary (journal) entries and recycles it for her own knock off “Streams Of Consciousness” column and journal.
711. A few examples are (With the full list to be presented in Court) Aisha did a film review for her site’s “Sound Off Column” slamming the sacrilegious teen film “Saved.” Britney shortly after writes about the same film in her knock off “Streams of Consciousness” Column.
712. Aisha wrote an article about Christianity in her site’s “Sound Off Column.” Defendant Britney Spears shortly after wrote an article about “Kabbalah” her so-called religion, in her knock off “Streams of Consciousness” column - an article that plagiarized and infringed the copyrights of Aisha’s previously written, copyrighted and published article.
713. Aisha wrote about her godbrother's dog on her web site and within days Britney Spears added a "dog's crib" page to her site and similarly wrote about her own dogs, as Aisha had written about her godbrother’s dogs. She further posted pics of her dogs, as Aisha had previously done in posting pics of a dog to her web site.
714. There are numerous other similarities. Even the colors, layout and scheme of Britney Spears’ previous site was a rip off Aisha's previous site. Defendant Britney Spears’ previous and current sites are designed and maintained by Defendant Music Today Inc. COMPARATIVE EXHIBITS SHOWING THE THEFTS AND PROGRESSION THEREOF WILL BE PRESENTED IN COURT.
715. Other mimicking behavior includes: when Aisha wrote on her web site that she is a music video director, shortly after, Defendant Britney Spears announced that she too is a music video director. Spears claims she directed her music video “Do Something” but based on reports and her own interviews, it is blatantly obvious that the co-director was the one who did the work, with Britney’s foray into directing by her own admission being relegated to telling the extras to “just get up and do something.”
716. Defendant Britney Spears is also a frequent copyright infringer, having been sued numerous times for unapologetically stealing copyright holders works in the following cases:
717. Lite Breeze Inc v. Britney Spears - Spears sued for $10,000,000 for infringing their trademark "In The Zone" for her album.
718. Cotrill v. Spears - Michael Cottrill and Lawrence Wnukowski - Defendant Spears sued for copyright infringement.
719. Christopher Merrill v. Britney Spears - Defendant Spears in conjunction with MTV sued for $30,000,000 for stealing a script that was submitted to them and making it into the flop “Crossroads.”
720. Steve Wallace vs. Britney Spears - Defendant Spears was sued for stealing the song “Sometimes” from a young aspiring writer.”
721. Defendant Spears was additionally sued for songs on her album “Oops I Did It Again” and its predecessor “Hit Me Baby One More Time.”
722. Britney Spear's talent scout William Kahn invited a group of writer/producers to submit their work to Spears. The song "What You See Is What You Get" was submitted to Britney before the release of her album “Oops I Did It Again.” It was purportedly rejected, but a song later appeared on her album anyway titled as “What You See Is What U Get” changing the “You” in the title of the original song to a “U.” The song on Britney Spear’s album also ripped off the submitted song’s melody.
723. Defendant Spears further went on stage and deliberately plagiarized and infringed the copyrights of an already released song by singer Enrique Iglesias. She claimed to the audience of thousands that it was written about her break up with NSYNC singer Justin Timberlake, but fans immediately and embarrassingly recognized it as a blatant rip off of an Enrique Iglesias tune.
724. This year, Britney Spears rushed to a radio station to premier her new, tacky song titled “Mona Lisa” that blatantly ripped off the synthesizer/piano music from former boyfriend Justin Timberlake's band’s hit song, "It’s Gonna Be Me." The theft was so blatant that even MTV mentioned the blaring similarities in an article on their web site. Fans noted and publicly commented on the rip off as well.
DEFENDANTS MADONNA, VICTORIA NEWTON, NICKI WATERMAN, GRAHAM DUDMAN NEWS GROUPS NEWSPAPERS LTD:
725. As mentioned in paragraphs 576-577. Defendants Victoria Newton, Nicki Waterman, Graham Dudman, News Group Newspapers LTD and The Sun Newspaper UK - One of the most disgraceful, inaccurate, unreliable newspapers on the planet, engaged in a willful pattern of copyright infringement and plagiarism of Aisha's copyrighted web site, unlawfully using numerous articles from Aisha’s frequently copyrighted “Sound Off Column” and online Diary entries. The Sun Newspaper and Nicki Waterman further printed items from Aisha’s copyrighted health and diet book as diet tips in Nikki Waterman’s column in the Sun Newspaper.
726. Aisha’s health and diet book manuscript is copyrighted, unpublished and apart of her multi-million dollar valued copyrighted catalog. This copyrighted book manuscript is only on her private computers with the other copy in the Library Of Congress in Washington, D.C. - yet The Sun Newspaper UK in conduct reminiscent of Madonna’s (who is in criminal possession of Aisha’s copyrighted multi-million dollar valued catalog that she has been criminally using in the same method), was able to criminally utilize and print items from said book manuscript, attributed to themselves and Nikki Waterman in the newspaper and on their web site, whose daily respective circulation and readership is in the millions.
727. The Sun Newspaper UK has been caught in cases of invasion of privacy and criminal trespassing on several occasions that were written about in the press due to their privacy invading, unlawful tactics they frequent utilize to get invasive stories.
DEFENDANTS JERRY BRUCKHEIMER, WARNER BROS, WARNER BROS TV, TIME WARNER
728. Charles Howard, Sunil Nayar, Steven Maeda, Michael Ostrowski, Corey Miller, ildy Modrovich, Brian Davidson and Marc Dube are, and at all times herein mentioned was, writers for the television show CSI: Miami, which is produced by Defendant Warner Bros (recording label for Madonna) and Defendant Jerry Bruckheimer Films (Jerry Bruckheimer is Madonna’s partner - SEE EXHIBIT 33).
729. As mentioned previously in this Complaint, tapes of Aisha's telephone conversations have unlawfully been shared with staff of the show CSI:Miami in attempts to harass her. They are employed by Jerry Bruckheimer and Warner Bros. They deliberately wrote into scripts for the show CSI:Miami, verbatim items that were taken from Aisha’s wiretapped phone calls and other items from the 24 hour surveillance of the Plaintiff. Things Aisha said over the phone and did in her daily life, appeared as dialogue on later episodes of the show, which is also filmed in Miami, Aisha's hometown of the last 20 years.
730. They further plagiarized Aisha's web site, with items from her copyrighted web site being used for show plots and dialogue, all after she published them to the web site and copyrighted the contents.
731. Madonna is a friend and partner of the show's owner and producer Jerry Bruckheimer. Madonna's best friend of 25 years, Kabbalahist Debi Mazar, even made an appearance on one of the shows during said time period.
732. Episodes 58, 65, 66, 67, 68, 69 and 70 contained items from the criminal surveillance campaign Madonna commissioned of Aisha and was included in the show verbatim in attempts to harass and terrorize Aisha out of suing her and her co-defendants and pressing criminal charges against them for their criminal use of her private multi-million dollar copyrighted catalog containing 6,000 songs, 2 dozen scripts, 4 dozen film synopsises, 11 book manuscripts, 4 dozen music video treatments and 3 dozen photo treatments - a catalog that they greedily want to continue using without civil or criminal penalties.
733. And with the way the Defendants over-market and financially exploit projects such as films and music in the global marketplace, Aisha’s catalog is potentially worth billions to them - therefore they wanted her out of the way and went to great lengths in failed attempts to try to do so.
734. It is clear from these events that the writers of the show CSI: Miami, have been illegally made privy to Aisha’s wiretapped telephone calls and made privy to her day to day schedule, by Jerry Bruckheimer’s partner Madonna, who has criminally had Aisha under 24 hour surveillance, constantly throwing it in her face in failed attempts to harass, intimidate and scare her.
735. Jerry Bruckheimer Films is no stranger to lawsuits for copyright infringement. Recently, they were sued by Royce Mathews for willfully "stealing plot points and characters names" from his short film made and shopped around Hollywood studios 10 years prior, for unauthorized use in the very successful “Pirates Of The Caribbean."
736. Mr. Bruckheimer’s partner was the late, notorious Don Simpson, who was also represented by Madonna's lawyer Bertram Fields, as is Mr. Bruckheimer. Don Simpson had lawsuits and allegations leveled against him for harassment and tapping an employee’s phone through Bertram Fields' private investigator Anthony Pellicano. Mr. Bruckheimer's partner Don Simpson was also publicly accused of beating prostitutes and forcing them to drink out of a toilet while he urinated in it. Mr. Simpson also reportedly had a $60,000 a month drug habit.
DEFENDANTS GWEN STEFFANI, HARAJUKU LOVER MUSIC, PHARRELL WILLIAMS, CHAD HUGO, STAR TRAK
737. Friend and publicly admitted cousin of Madonna, Defendant Gwen Stefani, said in a recent interview that she goes over to Madonna’s house for dinner. Both married English men. Both have homes in London and Los Angeles. Madonna criminally sold one of Aisha’s unreleased beats to co-defendants Gwen Stefani, Pharrell Williams and Chad Hugo, also known as the production duo The Neptunes.
738. This beat stolen from Aisha in the same manner Aisha’s multi-million dollar copyrighted catalog was criminally stolen by Madonna via a commissioned hacker, illegally used several of Aisha’s song’s music drum pattern/beat, melodies, harmonies and arrangements, to become the #1 song “Hollaback Girl,” which ironically also rips off its title from rapper Fabulous’ song “Hollaback.”
739. Stefani’s infringing song was pushed out ahead of Aisha’s reworked song, though it was not written, recorded and copyrighted before Aisha’s.
740. Defendant Harajuku Lover Music publishes “Hollaback Girl” by Gwen Stefani. Defendant Gwen Stefani owns Defendant Harajuku Lover Music (ASCAP). It is also co-published by Star Trak Music owned by Defendants Pharrell Williams and Chad Hugo (ASCAP). Defendant Jive Records released, marketed and distributed the copyright infringing song in many formats that range from digital downloads to retail store CDs. The song went to #1 on Billboard’s charts and was the top seller on Wal-Mart’s digital downloads charts for weeks due to its distinct beat. “Hollaback Girl” was Defendant Gwen Stefani’s first solo #1 record. Her debut/previous solo single “What You Waiting For”, from her debut album, having flopped.
741. Many music critics have publicly slammed Gwen Stefani’s album, in print, for being highly derivative and plagiaristic. Many of these critics cited songs in their articles that Gwen Stefani clearly ripped off to create her copyright infringing debut album.
742. Furthermore, Defendant Gwen Stefani’s song Hollaback Girl’s lyrics are similar to Aisha’s already released “Contemporary Girl” in theme, concept, subject matter and style. The song also finds Stefani rapping and singing, as does Aisha - however, Stefani was never a rapper.
743. To try to distance herself from the blatant similarities, Stefani claimed the beat was taken from Queen’s “We Will Rock You” however the beats for “We Will Rock You” and “Hollaback Girl” don’t match. The beats for Aisha’s “Contemporary Girl” and “Hollaback Girl” match when digitally placed over each other.
744. Furthermore, Ms. Stefani and her producers did not have permission to rip off Queen’s “We Will Rock You.”
745. Other items from the song and music video “Hollaback Girl” are a blatant rip offs and infringements of the 80’s song “Oh Mickey” by Toni Basil.”
746. It is quite ironic and shameful that Madonna stole Aisha’s 2001 version of “Contemporary Girl” and unlawfully used it for her 2003 “American Life.” Then this forced Aisha to change the beat for “Contemporary Girl” to use it and keep it fresh after Madonna unlawfully stole it, but no sooner that she reworked the song, did Madonna’s cousin and friend, Defendant Gwen Stefani, rip it off for her single “Hollaback Girl.” Madonna, once again, was clearly the point of access for Aisha’s work that was criminally used without permission.
747. It follows the Hollywood tradition of copyright infringement where works are passed around among the same circle of people and sold to others, as was revealed in the case Stewart v. Warner Bros, where FBI evidence revealed the same script was passed around among many of Hollywood’s major studios and top directors, three of which unlawfully used the same script to create “The Terminator” and it’s sequels by director James Cameron (also sued several times for copyright infringement) then years later, more items were stolen from the same script to create “The Matrix” and its sequels. Great material is always sought after in the entertainment industry - sadly sometimes it is done unlawfully to many innocent, unsuspecting writers’ detriment. It’s an old, dirty, unlawful practice in Hollywood that needs to stop, as it violates many U.S. and United Nations laws.
748. Defendant Gwen Stefani’s “Hollaback Girl” uses the same beat pattern and structure as Aisha’s 2004 recorded version of “Contemporary Girl.”
749. Defendant Gwen Stefani’s “Hollaback Girl” uses the same TR 808 bass boom pattern repeated in frequent succession on Aisha’s 2004 recorded version of “Contemporary Girl.” This had not been used and used so frequently in a pop or rock song before, until Aisha did it on “Contemporary Girl.” Florida and Georgia artists are the ones known in music for using the TR 808 bass boom in their music, while others discounted it as being southern hip hop, which did not get any respect until the last few years - with New York and California dominating the industry. Aisha grew up in Florida while Gwen Stefani grew up in California, and The Neptunes in Virginia, therefore the usage of said sound and so frequently on the song was uncommon and out of place on the infringing track “Hollaback Girl.”
750. Gwen Stefani raps and sings on her track “Hollaback Girl” in the same style, pattern and phrasing Aisha does on her previously released song “Contemporary Girl.” Stefani is not and has never been a rapper. She is the front woman and lyricist for the rock band No Doubt. The song “Hollaback Girl” was a big leap for Stefani and a drastic, pretentious departure in style, genre and content.
751. Another song on Stefani’s album featuring Dre from the group Outkast, is eerily similar to previously copyrighted songs by Aisha titled “You Wouldn’t Date A Black Girl” and “You Talk Like A White Girl” and “The N Word.”
752. The song "Cool" by Gwen Stefani is eerily similar to the copyrighted song “Love Lost” by Aisha. She makes reference to other themes such as the Aisha song "Love Of My Life" including it as a lyric.
753. Aisha obtained all the copyrights to these works first and they are apart of her multi-million dollar valued copyright catalog that Madonna criminally stole via a commissioned hacker (diagnostic tests revealed Aisha’s computers have been hacked) and has been actively and illegally selling off and using items from in open, criminal violation of domestic and international laws.
754. Defendant Missy Elliot, co-writer and co-producer of the 2003 copyright infringing Madonna song “American Life” also appears as a credited and paid producer on this very same Gwen Stefani copyright infringing album containing the songs “Hollaback Girl” and “Cool.”
755. Producers of the song “Hollaback Girl” which infringes Aisha’s 2001 and 2004 version “Contemporary Girl,” Defendants Pharrell Williams and Chad Hugo are also known habitual copyright infringers.
756. In 2004 there was a big scandal in the press regarding their shameful mistreatment and blatant exploitation of a teenager for his beats/music.
757. Defendants Pharrell Williams and Chad Hugo deliberately stole a slew of beats from 18 year old Canadian producer Joseph Zuckoni and unlawfully used them to make several hit songs, some of which they were paid $250,000 a piece for - without paying the young man a single dime.
758. Much like Aisha and other indie music producers, Joseph Zuckoni posted on a music message board on the internet. Aisha posted on Craig David’s message board as mentioned above, while Zuckoni, posted on Defendants Pharrell Williams and Chad Hugo’s message board for their group The Neptunes.
759. Aisha and Zuckoni do not know each other, however it is very common among indie music producers in this underground music genre to post on message boards. Many of them do.
760. Zuckoni posted excerpts of his beats on Defendants Pharrell Williams and Chad Hugo’s message board for other message board visitors to listen to. Based on reports, they liked his music. It was so good that it got the attention of the owners of the message board, Defendants Pharrell Williams and Chad Hugo’s message board, who unbeknownst to Zuckoni, had begun using his beats and without permission.
761. Pharrell Williams and Chad Hugo’s then contacted the teen with the cruel ulterior motive to get more beats/music from him that they had no intention of paying or crediting him for. Based on reports, they further lead him on, flew him to their studios in New York, promised to make him a partner in their production company and team The Neptunes, on the basis that he brought them more of his beats to listen to at their recording studios.
762. Upon information and belief, when 18 year old Zuckoni arrived at their recording studios in New York from his home in Canada, his was greeted by his beat playing through the loud speakers, that had been used to make songs for artists like rapper Jay-Z - but, albeit, without the young Zuckoni’s permission.
763. Continuing to promise to make him a partner, young Zuckoni handed over his latest beats he’d made to the unscrupulous Pharrell Williams and Chad Hugo. Shortly after they used these beats in addition to other of Zuckoni’s beats, collected millions in production fees, not crediting or paying Zuckoni for his work.
764. Zuckoni went public with his story to one of the largest rap web sites on the internet. The story was then picked up by the mainstream press, to Pharrell Williams and Chad Hugo’s embarrassment.
765. Zuckoni then reported to the press that Pharrell Williams and Chad Hugo’s representatives angrily called him at his home. He said they, “Phoned me up with a courtesy call, more like a threat, basically telling me to shut the f*** up."
766. Upon information and belief, another producer, a 29-year-old Texan using the pseudonym "Jaime Sucio" met Defendant Pharrell Williams at the SXSW music festival in Austin, Texas. They “spoke for an half an hour,” and "Jaime Sucio" gave him a CD with 12 beats on it and another with some remixes.
767. Defendants Pharrell Williams and Chad Hugo then sent him a rejection letter in the mail notifying him they were opting not to work with him based on his CD of beats. However, upon information and belief, went ahead and used/stole Jaime Sucio’s music/beats anyway, selling them to famous recording artists they produced for.
768. Upon information and belief Defendants Pharrell Williams and Chad Hugo even stole one of Jamie Sucio’s melodies and paired it with a beat they stole from Joseph Zuckoni.
769. Another item of concern and caution this case and that of Joseph Zuckoni, who did find lawyers to take his case and initiate litigation against the Neptunes for copyright infringement, points out it is the rampant theft of materials from links and items on message boards of famous entertainers by the entertainers themselves who frequent their own message boards.
DEFENDANTS NICK CANNON, JIVE RECORDS, DARREN SHERRILL, JONES JAMES EDWARD, LILLY DARRON KEITH, BOOGOLOGY MUSIC, D LIL MUSIC PUBLISHING, DARREN SHERRILL MUSIC
770. Another Jive Records artist Nick Cannon willfully and deliberately infringed Aisha’s copyrights for her web site and her song “Why Did This Happen TO Me” to make the infringing song “Can I Live” (Britney Spears is also on Jive).
771. Not Only did Nick Cannon steal in its exact form, Aisha’s copyrighted piano riff from her released God themed song “Why Did This Happen To Me” for unauthorized use in his God themed song “Can I Live,” the lyrics in Defendant Cannon’s May 2005 song also plagiarize a copyrighted December 2004 article on Aisha’s web site about anti-abortion. This article by Aisha has been read by many people according site statistics and search engine statistics that spooled the article.
772. Further complicating matters is Aisha has three copyrighted, unpublished songs about abortion, that is apart of her multi-million dollar copyrighted catalog only available on her computers (the same catalog that Madonna has been criminally using that is housed on Aisha’s computers that she subsequently found out was hacked with the only other copy in the Library Of Congress in Washington, D.C.).
773. Aisha copyrighted these songs a year before Nick Cannon ever wrote and released his song “Can I Live” on Jive Records. Aisha had intended to put one of the songs about abortion on the album, but due to space constraints on the disc, she opted to leave it off, saving it for another record.
774. One of the songs is a lot like Nick Cannon’s “Can I Live” with Aisha’s having been written and copyrighted with the Library of Congress in Washington, D.C. a whole year before Nick Cannon’s “Can I Live.” One of Aisha’s copyrighted unpublished songs from her private catalog is called “Let Me Live,” another “When A Child Is Born” with the third being titled “Unborn.”
775. “Can I Live” was so out of place on the party loving Nick Cannon that even MTV commented on it in an article. MTV wrote that the song Can I Live, "doesn’t sound too much like Nickelodeon's fun-loving ‘All That Actor.’" There's a reason for that. He ripped it off from Aisha's music and writings. Nick Cannon’s music has always been about partying, drinking and sleeping with women. This was quite a departure for him.
776. Aisha’s song was also about an unborn baby talking to the future mother. However Aisha copyrighted all these items long before cannon made and released his infringing version. The infringing song “Can I Live” by Nick Cannon was written by Cannon and co-written by Defendants Darren Sherrill, James Edward Jones, Lilly Darron Keith, Boogology Music, D Lil Music Publishing and Darren Sherrill Music.
777. Aisha is concerned about what else Defendant Nick Cannon has ripped off from her copyrighted works for his forthcoming album "Stages" due in September 2005. If further infringements are found, additional lawsuits will be filed.
WILFUL AND MALICIOUS COPYRIGHT INFRINGEMENT ALL THE DEFENDANTS
778. All the infringements listed in the previous charge were willfully stolen. These were deliberate acts of theft. The plagiarized and infringed Aisha’s copyrights, as listed above in the prior charge, which constitutes several direct and flagrant violation of U.S. and United Nations copyright laws and treaties. Moreover, the Defendants deliberately exploited Aisha and her life’s work, unjustly enriching themselves and scoring prestigious awards and accolades that derived from Aisha’s labor.
779. Aisha has religious beliefs that prohibit her from engaging in or authoring work that is sacrilegious or inappropriate. Aisha has consistently honored her Christian beliefs through her work, as evidenced by her songs and web site bearing her name, which has been online for over 4 years and in good standing.
780. However, the Defendants deliberately stole copious amounts of Aisha’s already copyrighted works and interpolated them with expletives and sacrilegious items, which is a great offense to her. The desecration of her work has been particularly offensive to her as her writings pay homage to her faith, Christianity, whose beliefs and tenets the Defendant’s subsequent derivative and infringing works have profaned. The Defendants knew Aisha would not allow her work to be utilized for the types of projects Madonna and her co-defendants are known for, therefore they deliberately and criminally infringed several of her copyrights to use these works without her permission, reaping millions in profits for themselves.
781. Aisha is a very hard working indie writer, who on minimal resources authored ground breaking, innovative, trend and precedent setting work in the entertainment industry, that the Defendant robbed her of authorial credit and the financial rewards for.
CRIMINAL COPYRIGHT INFRINGEMENT MADONNA AND CO-DEFENDANTS
782. Copious amounts of Aisha’s copyrighted works were unlawfully used by the Defendants, first from her widely read web site that had indisputable evidence linking them to numerous visits to it and secondly by the criminal theft of Aisha’s very valuable, wholly owned, multi-million dollar valued copyrighted catalog containing over 6,000 songs, 2 dozen scripts, 4 dozen film synopsises, 11 book manuscripts, 4 dozen music video treatments and 3 dozen photo treatments
783. Due to the value of Aisha’s catalog, The Defendants criminally using and selling off items from said catalog constitutes criminal grand theft larceny, dealing in stolen goods, hacking, invasion of privacy and wire fraud.
VICARIOUS COPYRIGHT INFRINGEMENT ALL THE DEFENDANTS
784. Madonna’s co-defendants were all aware of her well publicized legal cases for unethical conduct and copyright infringement in the well written about international cases Acquaviva vs. Madonna (Belgium "Frozen"), Bourdin vs. Madonna, Easy Street Records vs. Madonna ("Deeper and Deeper" and "Bad Girl"), Salvatore vs. Madonna ("Ray Of Light"), Hamilton vs. Madonna (deliberate non payment of $350,000 in production fees), in New Jersey deliberate non-payment of $100,000 loan for film company fees, Yael Osteric v. Madonna and Maverick, for sexual harassment and wrongful dismissal and the case of 10 year old Keith Sorrantino in Sorrantino vs. Madonna for acts of willful assault and aggravated battery on a minor. This is in addition to well publicized initiated litigation against Madonna on formal public allegations of theft by singer/Prince protégée Ingrid Chavez for stealing the song “Justify My Love” and writing her name in the writer’s space where Chavez’s should have gone.
785. The Defendants knew they were dealing with a thief but just didn’t care. All they cared about was the untold millions they could make from criminally stealing Aisha’s copyrighted works.
786. The Defendants had the ability to prevent malfeasances and crimes, but looked the other way, paying Madonna huge sums of money for work that was not hers and that she didn’t have any legal rights to under the law.
787. In doing so, the Defendants subsidized and supported Madonna’s criminal behavior for their own financial gain. They have made a fortune in sharing the profits of Madonna’s willful and unlawful plundering of numerous works owned and copyrighted by Aisha, prior to the Defendants usage of said works.
CONTRIBUTORY COPYRIGHT INFRINGEMENT ALL THE DEFENDANTS
788. The Defendants in conjunction with Madonna contributed to the malfeasances committed against the Plaintiff by willfully infringing numerous Aisha’s copyrights belonging to Aisha.
INFRINGEMENT OF RIGHT OF REPRODUCTION ALL THE DEFENDANTS
789. The Defendants willfully stole copious amounts of copyrighted works, violating Aisha's copyrights, then reproduced, mass-produced and sold said infringing works around the world in paper, electronic and physical hard copy format, grossing millions in revenues. At no time did Aisha authorize anyone to use her copyrighted work. Only Aisha has the right to use and reproduce these copyrighted works, as accorded by The Copyright Act. In committing these acts, the Defendants willfully and criminally violated numerous of Aisha’s copyright’s Right Of Reproduction.
INFRINGEMENT OF RIGHT TO PREPARE DERIVATIVE WORKS ALL THE DEFENDANTS
790. The Defendants have unlawfully prepared and distributed derivative works from Aisha’s copyrighted material. The criminal, flagrant, willful and consistent copyright infringements by the Defendants have robbed Aisha of the opportunity to properly market and distribute her own copyrighted works.
INFRINGEMENT OF RIGHT OF ATTRIBUTION ALL THE DEFENDANTS
791. The Defendants willfully violated Aisha’s right of attribution in several ways. They violated Aisha’s basic Right Of Attribution for her works, that they criminally procured and took credit and monetary royalties for.
792. Secondly, Defendants Madonna, The Sun Newspaper UK, Victoria Newton, Nikki Waterman and Britney Spears willfully violated Aisha's Right Of Attribution § 106A.
793. Madonna and Britney Spears made a characterless habit of quoting items from Aisha's copyrighted web site articles and diary entries verbatim, attributing them to themselves in worldwide interviews and internet articles seen by millions of people.
794. Britney Spears violated Aisha's Right of Attribution afforded by her copyrights, as listed in detail in paragraphs 706-716.
795. Madonna violated Aisha's Right of Attribution afforded by her copyrights many times. The likelihood of two people saying the exact same things over and over again is very remote…especially when one had the copyrights prior to the other one falsely attributing the items to herself each time, which was another giveaway that Madonna had been regularly visiting and stealing from Aisha’s web site.
796. It started happening like clockwork. Aisha would write and publish items to her widely read web site, then shortly after like clockwork, Madonna would attribute these copyrighted items to herself verbatim in her own widely read interviews, which I found very pathetic. She practically turned Aisha into a speechwriter, without her consent.
797. AISHA: Aisha wrote on the interview page of her web site that “I don’t listen to my music at home.” MADONNA: Months later on April 12th, 2003, Madonna does an interview on a UK show saying she doesn’t "listen to her music at home.”
798. AISHA: Aisha wrote an article on celebrity for the Sound Off page of her web site on January 7, 2002, in which she penned the original term, “Why do people like to see people fall?” as a type of catch phrase. MADONNA: On March of 2003, in promoting her then new single “American Life” Madonna said the exact same thing on Access Hollywood with Nancy O’Dell, “Why do people like to see people fall?” Aisha had already copyrighted the article, as she does with all of the contents of her web site and updates, prior to Madonna repeating it verbatim and attributing it to herself.
799. AISHA: Was born on November 8, 1976. Aisha has written birthday commentary of the site poking fun of herself. MADONNA: It has been reported numerous times that Madonna believes in astrological signs and chooses specific dates to get pregnant, give birth and to release projects based on astrological dates. A June 2004 UK newspaper article discussed how she only hires people with compatible astrological signs and birthdays, as she (wrongfully) believes it will bring her good luck. Her back up dancer (Reshma Gajjar) was quoted to support this information. Madonna's third children’s book “Yakov and The Seven Thieves” was released in Russia on Madonna's birthday, according to press headlines/articles. The release date for her follow up, “The Adventures of Abdi” was on Aisha's birthday of November 8, 2004th. Once again, another Madonna project this year is being released on Aisha’s birthday this year - Madonna’s career depending album “Confessions on a Dancefloor is being released on November 8, 2005, SEE EXHIBIT 89.
800. AISHA: Aisha wrote on the Diary page of her web site on June 5th, 2004 that she's writing two books with her dad. “June 5, 2004 - for several months now, I’ve also been working on two other books with my dad, but he’s going to do the majority of the work on those. He’s always very busy, but last year I convinced him it was something he should do and he started working on them and so did I. He has such a brilliant mind. God gave him a lot of talent. I mean the stuff he knows is incredible. I learn from him all the time. I’m always asking him questions.” MADONNA: Two weeks later it was announced in the British tabloid The Sun Newspaper by Madonna's friend and cantankerous, characterless, malicious mouthpiece, Defendant Victoria Newton, that she is "writing a book with her husband." Madonna always gives Victoria exclusives, uses her to put a spin on her questionable behavior, like calling British People “lazy” and insulting British hospitals, and to answer insults other entertainers have hurled at her, via her articles. Defendant Victoria Newton is short on journalistic integrity. Newton has bragged that she has Madonna’s email address, in her column titled Bizarre, which is a fitting name, based on its odd content.
801. AISHA On January 11th, 2003, Aisha wrote about her management company she'd started. On the Diary page of her site she wrote: "January 11, 2003 - I remember a show I saw once where the character said, "the word free is not in a good manager's vocabulary." It's a funny line. Management is something I've studied for years as well. I have a management company that I started at the same time as the record company (there's an email link for it on this page). I decided in May of 1992 that I wanted to have my own music company with a record, management and production branch (I was 15 at the time). I still have the first sketches of it and the registration from a few years later. In a sense, I used it to house my work, which is basically what it is today. I have a lot of material by God's grace. It's wonderful working on it and getting it off the ground now. I'm really more comfortable with behind the scenes work like production, management and marketing. By God's grace, I've learned this industry and its markets very well." MADONNA: After Aisha's announcement, in an April 11th, 2004 press release from her then management and an accompanying New York Newspaper article, Madonna said she is "starting a management company." Madonna even parted ways recently with her manager of 13 years, Caresse Henry, which was written about in the press last month. Henry, who is now working with Miami native Ricky Martin, responded by saying Madonna, “wasn’t doing anything anyway."
802. Madonna’s former manager also cited not liking the turn Madonna’s personal and career interests were taking. Madonna cited she did not like Caresse Henry having sex with her bodyguard, as reason for firing her, as that type of conduct was unfaithful and not keeping with the Kaballah cult.
803. However, Aisha believes Madonna just wanted to get rid of Henry and manage herself to take home more of the profit, in spite of the fact that she knew nothing about management and was making terrible business and PR decisions on her own. Madonna has a habit of using people then discarding them when she feels she doesn't need them any longer. The books "Madonna" and "Madonna: An Intimate Portrait" write of people she has gotten rid of when they were no longer of use to her. The December 2004 issue of People Magazine also revealed that it wasn't about Henry's conduct at all.
804. AISHA: "July 29th, 2003 - Hi guys, I started working today at about 3 AM this morning. I spent most of the day doing paperwork. I found the right law firm I was looking for. I've outlined the basics I want covered for each contract; he will hammer out the rest. There are a few other matters I want addressed as well pertaining to this web site. January 18, 2003: I'm having a great week. Monday and Tuesday I spent a large part of the day on the phone making business calls and doing paper work. Mostly legal/contractual work, advertising, promotional arrangements for the CD and scheduling arrangements for the promo tour. MADONNA: "I'm the person who writes music for my next album, reads contracts and make sure everyone is making the right deals and crossing the t's and dotting the i's." - People Magazine December 2004.
805. Aisha took some law at a local college in Miami and has been reading law journals and articles since age 15. She has a basic understanding of contractual law. For anyone without any legal background such as Madonna, to go over industry contracts, is highly unlikely, as to the untrained eye it will look like a foreign language, and even then there are still items you can miss. Moreover, how could Madonna be the one who "writes the music" for her album as she claims, yet in the same article she said, "I no longer have time to be creative." That's a serious contradiction. Therefore, who's doing the work. Who's the one actually being creative.
806. AISHA: On November 1, 2002, Aisha wrote on her web site’s Diary page that she's working on opening a restaurant with her mom, for which she would include some of her mom’s recipes. She also wrote that she had just registered the name for it, “THE CONTINENTS” (this info is readily available online through any whois company). "November 1, 2002 - I've been working on plans to start a restaurant. It's been a fun project for me. By God's grace I've written the menu, planned the architectural design, made a business plan and I've started registering it. It's something I've wanted to do for a while. My mom is an excellent chef, she can make any dish and I've learned about cuisine from her, from books and television shows." MADONNA: Months later in 2003 Madonna puts out a press release stating she is opening a restaurant, with her brother, Defendant Chris Ciccone, and the name of it is "THE CENTRAL." The name THE CENTRAL is similar to the name Aisha registered for her future restaurant, THE CONTINENTS. The first four letters are the same. Aisha wrote that she would open her restaurant with her mom. Madonna later wrote she is opening hers with her brother in Los Angeles.
807. AISHA: On April 15, 2003 Aisha made a joke about polishing her nails in the Sound Off Column of her web site. "While I waited for a web site to load, I polished my nails (yes, the web site took some time to load because it had a lot of content...and like this page is any quicker)." MADONNA: Shortly after Madonna makes a joke in a British interview about "running her record label" and "having her nails polished."
808. AISHA: Aisha wrote an article on the Sound Off Page about young singers smoking and how bad it is for their voices. MADONNA: Shortly after on September 4th, 2003, "Rate the Music" posted an article quoting Madonna and her rep Liz Rosenberg from the MTV Awards, saying that she (Madonna) told Britney Spears to stop smoking or it will ruin her voice.
809. AISHA: On August 12th, 2004 Aisha wrote about "editing" her music videos she'd been shooting: " August 12, 2004 - Hi everyone, I’m here doing paperwork. I also have more footage to go over. I went over some more of it this morning. I have a lot of editing and processing to do on the latest stuff I got." MADONNA: A month later, on September 21st, 2004 Madonna wrote about "editing" her tour documentary in her monthly fan club newsletter, for which Aisha found a scan of the letter on a fan site SEE EXHIBIT. Madonna isn't editing anything. The amount of work that goes into that and the technical skill it requires is proof that she is not doing that nor does she know how to do, mostly due to the editing software and equipment many train for years to use.
810. AISHA: For three years Aisha's had a regular column titled "The Sound Off Column." She's also had a regular interactive Q&A feature on her web site where people email her questions or asking for advice or info about her not covered on the site, that if chosen is answered on the web site. This is another feature Madonna decided to steal for a new addition to her site. MADONNA: People Magazine December 6, 2004 "I want there to be an English Roses column where girls can write in and ask questions." This would enable her to indoctrinate young girls with her Kabbalah cult, as journalist have written she does with her Kabbalah children’s books.
811. AISHA: For over two years now Aisha has been writing and posting “Sound Off Column” articles and Diary entries on her site about "home studio recording," as it is how all her music has been recorded - in her home studio. From a 2001 article on Aisha's web site: "What is your ideal place to live? Somewhere near the ocean or a river with hills or mountains. Somewhere with lots of trees. I love looking out at the water and I love hills. I grew up in Florida, which is very lovely, but totally flat. I love English country homes. That's my ideal house. An English garden is as good as a garden gets. I love the look of Cotswold Stone, English Limestone and thatched roofs. I don't want a mansion or manor house. Just somewhere with adequate space for a studio, a large library and a lot of land for privacy. - Aisha 2001 (www.aishamusic.com interview 4 Ó2003). MADONNA: Madonna later made an announcement in a December 2004 article stating she is having a home studio put into her English country home. Madonna has been in the industry for over twenty years and did not have a home studio during that time. According to an article printed in December of 2004, Madonna is having one built in her home all of a sudden, and oddly at a time when her career is on its last legs.
812. AISHA: Aisha's bio, which was copyrighted and put online in 2001, states that she directs all her music videos and that she writes screenplays that she will also direct. It’s not something Aisha just started. She's been making mini movies and writing music videos since she was a teenager. She's authored and copyrighted many screenplays and synopsises of the same over the years, as she began writing them in her mid-teens. She started studying filmmaking at age fourteen. MADONNA: In a November 2004 Article in the Sun with her friend and co-defendant Victoria Newton; Madonna made the announcement through the column that she is now a director. Aisha is of the belief that Madonna couldn’t direct traffic. Wearing a beret in a music video does not a director make (American Life). Considering her history of butchering films and her recently being voted "The Worst Rock Star Actor of All Time," by Blender magazine, her new declaration that she is a director is quite dubious. Audiences cringed at her before the cameras, as she is now the proud owner of the most panned filmed in history, "Swept Away" - which coincidentally she is being sued for $10,000,000 for stealing the idea from filmmaker Vincent D’Onofrino, who says he pitched the idea to Madonna and her agents in several meetings, therefore only an executive who is a glutton for punishment would greenlight a project with Madonna as the director.
813. AISHA: in Aisha’s Sound Off Column she wrote some people get into the entertainment industry “for the wrong reasons” and how some get into it to become famous not because they love the work. MADONNA: Months later on the American Idolesque "Road To Stardom" by Missy Elliot, Madonna once again turned Aisha into a glorified speech writer by plagiarizing the article she wrote for her Sound Off Column regarding becoming an entertainer “for the right reasons” (SEE EXHIBIT 90). This statement was highly hypocritical from a woman who publicly declared on many occasions that she wanted to become famous and rule the world. Her involvement in the entertainment industry these past 20 years has never been for the art of it, is has been about money and her ego.
814. AISHA: Aisha began writing about Tennis on her web site in 2002. A whole section of her site is devoted to tennis commentary. MADONNA: Shortly after in 2004 there was an article stating that Madonna is moving house due to the fact that her current home has no tennis court. Madonna who does not play and never expressed any interest in tennis was moving house based on her home not having a tennis court.
815. AISHA: Aisha created a store page for her web site in 2002 with a coming soon page for ringtones. Typically artists did not sell their own ringtones on their own sites at that time. Aisha was the first artist to make the announcement via her site. They licensed them to major carriers who sell them through their own cell phone company web sites. MADONNA: In 2004 Madonna puts out a press release stating she is the first artist to sell ringtones on her site in the web site's newly opened ringtone shop. She hailed herself as the first when she ripped this idea and feature from Aisha's web site that made the announcement first.
816. AISHA: wrote on her site in 2003 that she is also an artist who paints and will hold an exhibition in the future displaying her work. MADONNA: In 2004 Madonna announces an exhibition of pictures of herself.
817. AISHA: Wrote that she doesn’t really wear real jewelry, as it doesn’t mean much to her (Copyrighted www.aishamusic.com web site interview in 2003). MADONNA: “I don't value diamonds. I rarely wear jewelry.” Madonna has been filmed and photographed numerous times bogged down in hundreds of thousands of dollars in jewelry (Magazine interview 2005).
818. AISHA: in Aisha’s May 2005 copyrighted Sound Off Column she joked about her mom going to the school bus with her one morning and jokingly wrote that thankfully she “wasn’t wearing rollers” or she (Aisha) would have been embarrassed. MADONNA: One month later, in a magazine article Madonna made the same joke, speaking of her daughter being embarrassed by her appearance at school “Sometimes my daughter gets angry because I got to school with her, wearing my tracksuit and she says, "Please can't you just wear normal clothes?" Grazia Magazine June 2005.
819. AISHA: Wrote in her web site Diary and in her bio (published July 2001) “I play the guitar, have since I was 15 years old (“I got my first guitar right before my 16th birthday as a gift from my dad, for which I still have the receipt).” MADONNA: In 2003 Madonna puts out a press release saying she’s learning to play the guitar. Also said on 2003 David Letterman appearance that she is not very good at the guitar, as she is just learning to play it.
820. AISHA: wrote on her web site’s Diary page on March 5, 2002 and December 5th, 2002 that she's been writing a book: March 5, 2002 - “I've also been writing a book that's turning out really well.” December 5, 2003 - This week I spent a few hours working on my book again. I started writing it last June. MADONNA: March 6, 2003, Madonna does an interview and puts out a press release saying that she’s writing a book titled “The English Roses.” The book was subsequently panned by critics worldwide.
821. AISHA: In her bio (copyright 2001) that she writes screenplays and has since she was 15. She also wrote about working on different screenplays at various times on the Diary page (diary entries starting in 2002 were about different ones she was working on at the time). MADONNA: Several months after Aisha wrote that on her web site, on September 21, 2003, Madonna announced in an interview with SFGate.com (San Francisco Chronicle) that she is working on writing a screenplay.
822. AISHA: Aisha wrote on the Diary page of her web site on several occasions beginning on June 8, 2002 that she “does not work on the Sabbath,” as she is a Christian." It's been a great week. I spent most of today in the studio recording, starting in the afternoon until before the Sabbath starts at midnight. July 31, 2002 - I write songs everyday except for on the Sabbath when I don't work. October 5, 2002 - I'm going to work a bit more then stop before the Sabbath begins. November 8, 2002 - I write songs everyday except the on the Sabbath." MADONNA: On September 25th, 2004 Madonna announced she is “no longer working on the Sabbath” therefore she “won't play shows on the Sabbath” during her Reinvention Tour.
823. AISHA: In her online bio, which was written in 2001, she wrote that she loves Jewish culture and incorporates it into her work often. MADONNA: In 2003 for her next album, "American Life," which contained the copyright infringing song, she started talking about Jewish culture and how she incorporates it into her work, leading to this Kaballah trend that she is currently promoting, and much to the detriment of Judaism. She hadn’t included it and so boldly in her music before, even though she later claimed she has studied it for years (her debauched behavior certainly does not show it, which makes her a very poor representative according to several rabbis who publicly spoke out about it).
824. Madonna attributed all these items to herself that she repeated and stole from Aisha's copyrighted writings on her web site. Aisha published and copyrighted these writings each time before Madonna falsely attributed them to herself in the press, often verbatim, which infringed Aisha's copyrights Right of Attribution. Furthermore, to continually quote someone else's writings without credit in interviews viewed by millions, unethically attributing said copyright items to yourself, shows a gross lack of character.
INFRINGEMENT OF RIGHT OF DISPLAY ALL THE DEFENDANTS
825. The Defendants infringed Aisha’s copyrights Right of Display by unlawfully violating then duplicating numerous of her copyrighted works that have been displayed via these unlawful infringements on many web sites, in print, on television, on radio and in retail stores around the world.
INFRINGEMENT OF RIGHT OF DISTRIBUTION ALL THE DEFENDANTS
826. The Defendants have stolen substantial amounts of copyrighted work, which infringed Aisha’s copyrights, and then mass-produced and sold said infringing works around the world, grossing millions in revenues. At no time did Aisha authorize anyone to use any of her copyrighted works.
VICARIOUS DISTRRIBUTION ALL THE DEFENDANTS
827. The Defendants unlawfully mass-produced and vicariously distributed many copyright infringing works containing Aisha’s already copyrighted works, selling them worldwide and reaping millions in profit and acclaim, all without her permission.
WILLFUL ALTERATIONS ALL THE DEFENDANTS
828. The Defendants willfully infringed several of Aisha's copyrights, in some cases items were illegally reproduced unaltered and in others, numerous items were altered in failed attempts to camouflage the blatant thefts of Aisha's copyrighted works.
PLAGIARISM ALL THE DEFENDANTS
829. The Defendants plagiarized Aisha's copyrighted web site Sound Off Column, copyrighted web site Diary, copyrighted songs and lyrics, and items from her private multi-million dollar valued copyrighted catalog only housed on her computers and in the Library Of Congress in Washington, D.C. This charge goes with the Copyright infringement charges mentioned previously in this Complaint in paragraphs 493-828.
FALSE DESCRIPTION ALL THE DEFENDANTS
830. The Defendants willfully set forth “false descriptions” of numerous of Aisha's copyrighted works, to millions of people, in print, radio and television. Numerous items from Aisha's copyrights were stolen, renamed and re-described to camouflage the thefts of numerous copyrighted works belonging to Aisha.
831. These false descriptions misappropriated to Aisha's copyrights the Defendants infringed, re-copyrighted under their own names, affixed their own logos and trademarks thereto, duplicated in mass quantities and sold in the marketplace, reaped millions in sales for them, thus defrauding and devaluing Aisha's copyrighted works. Aisha has sustained great financial and emotional damage as a result of the Defendants repeatedly utilizing this criminal, unethical practice at her expense for financial gain that has greatly enriched them. These unlawful acts are a violation of 43(a) of the Lanham Act, 15 U.S.C. 1125(a).
FALSE DESIGNATION OF ORIGIN ALL THE DEFENDANTS
832. Madonna and her co-defendants publicly set forth False Designation of Origin numerous times for numerous items they willfully stole from Aisha's copyrights. They credited themselves as the source of origin and authors of the works to millions in the public. They also publicly set forth False Designation of Origin many times on numerous writers contracts with royalties associations like ASCAP, The Writers Guild and Harry Fox and with other organizations such as Muze and AMG, when they never were the owners or authors of these works, as they stole them from Aisha, infringing many of her copyrights.
833. Madonna and her co-defendants stole copious amounts of Aisha's copyrighted works, criminally re-copyrighted them in their names, then manipulated the rights thereof, collecting various licensing and production fees for works they have no rights to under the law, as it never belonged to them.
UNFAIR COMPETITION ALL THE DEFENDANTS
834. The Defendants made a habit of stealing Aisha's copyrighted works right when they were released to her sizeable, but internet based audience, releasing rip offs in the mainstream to the masses, fraudulently passing her copyrighted works off as their own. Other unreleased copyrighted works belonging to Aisha were criminally stolen, used and sold off in violation of several Jamaica, U.S. and United Nations laws.
835. This deliberate, criminal misconduct constitutes several counts of “unfair competition” where the thieving corporate giant steals from the small businessperson, using their vast resources to sabotage the smaller business via unethical, criminal unfair trade practices.
836. REVERSE PASSING OFF - Madonna and her co-defendants actions also constitutes "reverse passing off" a violation of Section 43(a) of the Lanham Act. Madonna and her co-defendants made willful alterations to Aisha's already copyrighted works and did not attribute any of it to her, Aisha, the rightful owner. Madonna and her co-defendants stole copious amounts of Aisha's copyrighted works and arrogantly passed them off as her own to untold millions of people around the world. All usage of Aisha's copyrighted works by Madonna and her co-defendants was and is unauthorized.
SACRILIGE ALL THE DEFENDANTS
837. The Defendants, with Madonna as the ringleader, violated many of Aisha’s copyrights by stealing her work, then intermingling it with sacrilegious elements of the Kaballah cult and other profane secular themes, which is a great offense to Christians, as many of the cults practices are universally known to Christians and Orthodox Jews as a form of paganism. Madonna and her co-defendants desecrated copyrighted religious works, adding profanity, vulgarity and crude language.
838. This malfeasance is a great offense to Aisha. She is very offended that her copyrighted works have been stolen and intermingled with such sacrilegious trash. Aisha’s works were never intended for such uses, especially works of such a disgraceful, common nature.
839. The Defendants destroyed the integrity of Aisha’s works by making unauthorized duplications and knock offs that go against everything she believes as a Christian. They had absolutely no right to these copyrighted works they infringed nor did they have her permission (that she never would have grant to them) which makes it all the more abhorrent that they did this.
840. Madonna's behavior is so many things have been utterly sacrilegious. She is after all the woman who reportedly masturbated with a cross on the Like A Virgin Tour, based on a published report - and more recently dressed up as a nun and her husband the Pope, in a sick publicity stunt the Catholic Church publicly denounced. Madonna did this publicity stunt when the revered Pope was unwell and dying. He passed a week later.
841. The Defendant Madonna has a perverse propensity for desecrating religious works, even the ones that do not belong to her and are protected by Copyright Law, all in the name of publicity and career advancement.
MALICE ALL THE DEFENDANTS
842. The malfeasances committed against Aisha were international, cruel, unconscionable and done with the worst of intent. Madonna and her co defendants deliberately broke numerous domestic and international laws for monetary gain, and all at Aisha's expense.
843. And when Aisha figured out the civil and criminal crimes they’d been committing against her, they turned to violent, criminal tactics that incorporated assault, stalking and harassment in failed attempts to scare her out of suing them and pressing charges for criminally stealing her multi-million dollar valued catalog.
844. They used their financial resources and media influence to exploit Aisha's copyrighted works on many occasions for their own enrichment, which interfered with Aisha's work and career. They took their malicious conduct even further in deliberately invading Aisha's privacy to commit corporate theft, then passed around among themselves her multi-million dollar catalog of copyrighted works. Additionally, they perversely passed around taped conversations of her private and business phone calls and faxes they acquired via commissioned illegal wiretapping.
MISAPPROPRIATION ALL THE DEFENDANTS
845. The Defendants misappropriated Aisha's copyrighted work over several projects without her authorization. Aisha would have never agreed to authorize the Defendants to use her work, as their projects are distasteful and go against her religious faith, Christianity. The Defendants realizing this due to Aisha's declaration on her web site of only doing wholesome work that compliments her religious faith, mounted an unlawful campaign of wholesale criminal intellectual property theft, stealing substantial amounts of Aisha's copyrighted work using it for their copyright infringing projects.
INVASION OF PRIVACY MADONNA AND CO-DEFENDANTS
846. Invasion of privacy is a violation of the Fourth Amendment. It is a serious crime, which is vile and abhorrent. A man's home is his sanctuary and it should not be violated, especially for acts of corporate theft. Both international and domestic law affords each citizen the right to privacy. This includes the right to discuss personal and business items, family members’ health and well being, share personal moments and prayers, without anyone illegally listening into their telephone conversations over the telephone and in their home. The Defendants criminally, disgracefully, willfully and inexcusably invaded Aisha’s privacy and that of her family for their own gain, which is a violation of several laws, civil and criminal, domestic and international.
847. The Defendants conducted an illegal surveillance of Aisha that included and was not limited to wiretapping and computer hacking. IP tracking was also utilized. Items the Plaintiff typed into search engines were utilized by Madonna and The Sun Newspaper UK.
848. The Defendant Madonna’s attorney, Bertram Fields, is at the center of an FBI probe regarding his clients’ enemies being threatened, burgled, property maliciously vandalized and their telephones tapped by his private investigator, mentioned previously in this Complaint.
849. Among the people’s phones that were formally announced as having been criminally tapped were actors Sylvester Stallone and Gary Shandling and Court TV’s Diane Diamond. These people all have something in common. They either threatened to sue, sued and or wrote about/publicly spoke out in an unflattering manner about one of Defendant Bert Fields’ celebrity clients.
850. Shortly after Aisha publicly threatened to sue one Defendant Bert Fields’ clients, Defendant Madonna, on her web site www.aishamusic.com, for stealing her copyrighted works, a string of orchestrated, criminal, bizarre things started happening one after another to Aisha, in rapid succession, bearing all the trademarks of what happened to others who were targeted and or terrorized for daring to seek justice against one of Mr. Fields' celebrity clients. It doesn’t take Einstein to find a pattern in all this.
851. And based on credible reports, other legal opponents of Mr. Fields’ clients experienced and publicly complained of the very same pattern of misconduct as Aisha has. Her words, ideas and statements over the phone being repeated in the press attributed to others.
852. Court TV’s Diane Diamond said something that completely rang a bell with Aisha, ‘I was positive my phones were tapped - I heard lots of clicking and cracking noises on the line and then my words started coming back to me through others.’
853. People kept complaining to the Aisha that her phone was making clicking and popping noises while she was talking to them. She could hear the noises as well. Sometimes there would be a sudden burst of unfamiliar music or static then it stopped. Not to mention the worst giveaway was reading what she was saying over the phone to different people, printed verbatim in The Sun Newspaper UK shortly after, attributed to Defendants Madonna and Victoria Newton.
854. An article by Luke Ford wrote of Bert Fields mysteriously gaining the most amazing evidence against opponents in court, which included information that could only be found in their private medical records and prescriptions and his propensity for disclosing these private details in court, that legal opponents believed were obtained through illegal wiretaps SEE EXHIBIT 90.
855. The mere fact that the contents of Aisha’s personal and business telephone calls have been repeated by Madonna and Victoria Newton, in her Bizarre Column and reprinted in other publications attributed to Madonna, and considering Fields is Madonna’s attorney, who is being investigated by the FBI for wiretapping legal opponents, it is blatantly clear what has been happening.
856. Preliminary inspections revealed Aisha’s telephone lines are not wiretapped at the junction box on her property, but were wiretapped digitally. According to experts, these digital wiretaps also enable quick, illegal access into the victim’s computer for further invasion of privacy via hacking, as Aisha like millions of other internet users, surfs the Internet via a phone connection.
857. The mere fact that Aisha has said business and personal items over the phone to several people, only to see those statements and ideas repeated and utilized by Madonna in the press, seeing them appear in print in the Sun Newspaper UK’s Bizarre column, written by fellow plagiarizer and publicly announced email buddy, Victoria Newton, once again attributed to Madonna and Newton, and in stunning detail, says something is very wrong.
858. Not to mention, Ms. Newton has been very liberal in stealing from Aisha’s web site’s Sound Off Column articles and Diary musings for her tabloid trash pieces, as outlined above in this action, which Aisha finds extremely offensive and will also sue her and The Sun Newspaper UK in British High Court. Ms. Newton was paid for articles that she poached from Aisha's copyrighted web site, violating U.S., British and United Nations laws in the process.
859. There is no question about what has been happening. You can’t say something on the phone one day, then read it in the papers the next, printed verbatim as you said it, but attributed to someone else - the very same person who criminally stole your multi-million dollar copyrighted catalog, used and sold off items from it and previously stole copious amounts of music, lyrics and text writings from your widely read web site in plain view of your audience, who wrote to you asking if you’d notice how badly that same celebrity has been stealing you work.
Via Computer Hacking:
860. After stealing her copyrighted works from her web site in clear view of Aisha’s site visitors who emailed her asking her if she didn’t notice how Madonna was stealing her work, Madonna driven by greed commissioned a hacker to criminally copy Aisha’s vast wholly authored music and film catalog she spoke of on her web site. Madonna then criminally and nefariously began selling off items from Aisha’s Federally protected Library of Congress copyrighted catalog to employers, partners, coworkers and longtime friends, and using other items from the catalog for her own projects at Warner Bros and Maverick.
Invasion Of Privacy In Her Home:
861. Aisha has said things in the privacy of her own home only to hear Madonna repeat them verbatim in her interviews, see them in print in her friend’s column in Defendant The Sun Newspaper UK and on her partner Jerry Bruckheimer’s show CSI:Miami.
862. Aisha was perturbed at what she noticed was happening; therefore she decided to research it on the internet, typing in the strange things she was experiencing into research sites. She found several articles that indicated those were the symptoms of hidden cameras and or illegal surveillance conducted from a neighboring house, where a privacy invader can record from outside a property via a parabolic microphone and other high definition devices, the things someone says in their home.
HACKING - UNAUTHORIZED ENTRY INTO A COMPUTER/COMPUTER INTRSUION MADONNA AND CO-DEFENDANTS
863. The Fourth Amendment states it is the, "right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized."
864. The Defendants willfully and unlawfully gained access to Aisha's personal computers via IP tracking and hacking and illegally copied and criminally utilized the contents thereof which includes a multi-million dollar copyrighted 6,000 song catalog containing other items such as scripts, synopsises, music video treatments, book manuscripts, unpublished literary text, a fashionline, a business plan for a restaurant and a real estate company. These items pilfered from Aisha's computers later surfaced in numerous Madonna and Madonna related copyright infringing works.
865. RSS recovery documents and other hacker applications (programs) appeared out of nowhere on Aisha's computer in areas like the desktop attempting to retrieve files Aisha had been working in and or deleted, and the music from any CDs she had placed into the disc drive and listened to on her computer. These criminal acts were violations of: 1. The Computer Fraud and Abuse Act of 1986 2. Title 18 U.S.C. Sec.1001 3. Title 18 U.S.C. Sec.1030. 4. Title 18 U.S.C. Sec. 2510 5. The No Electronic Theft Act (NET) 6. Criminal Copyright Infringement by willfully infringing several of Aisha's copyrights via criminally stealing copyrighted items from her hard drive via hacking in violation of the 17 U.S.C. _ 506 (a)(2) and 18 U.S.C. _2319(c)(3). 7. Economic Espionage Act - pilfered items from the Plaintiff Aisha's computers appeared in The Sun Newspaper UK in England, while other items are benefiting Arclight Films, an Australian film distribution company, responsible for the distribution of the forthcoming copyright infringing Maverick Films movie "Material Girls."
CYBER BASED COMPUTER THEFT MADONNA AND CO-DEFENDANTS
866. The Fourth Amendment states it is the, "right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized."
867. The Defendants intentionally invaded Aisha's privacy for financial gain, illegally utilizing works only found on her computer and in the Library Of Congress in Washington, D.C. This invasion of privacy tort has caused the Plaintiff great harm in that the Defendants flat out stole copyrighted works from her computer and have been going around Hollywood making multi-million dollar deals for themselves with these copyrighted works that they are now claiming as their own, when it never was. This malfeasance continues as the Defendants continue to utilize more and more of the Plaintiff's works, and criminally so, which is a violation of many U.S. civil and criminal laws.
868. Aisha's private, unreleased copyrighted files were accessed, some bearing trade secrets that were not to be viewed by the general public. Antivirus software confirms that Aisha's computer was hacked and files were accessed.
869. It is a despicable, underhanded crime. No one has the right to illegally access someone’s personal computers’ and rape and pillage the copyrighted works and ideas contained therein in a subversive, surreptitiously attempt to illegally gain intellectually property with less liability as to the origins/access.
870. These acts were a violation of the Computer Fraud and Abuse Act of 1986 and Title 18 U.S.C. Sec.1001 and 1030.
COMPUTER FRAUD
871. The Defendants criminally used Aisha’s private copyrighted works, while others were used and deleted by the Defendants hired hacker, as though that would somehow erase Aisha’s claim to her own copyrighted works.
872. These works had already been registered with the Library Of Congress in Washington before Madonna and her cohorts began putting the infringing versions into production. Later, incriminatingly, computer files related to this lawsuit that contained saved records of the unlawful intrusions on Aisha's computer were mysteriously deleted from her computer by a hacker while she was surfing the internet.
873. The Defendants also fraudulent passed off Aisha’s works as their own on the intenet to millions of people.
874. No one had the right to illegally access anyone's computer, then copy, steal and delete items that do not belong to them in acts of corporate theft. It is a criminal, sneaky, intrusive, despicable computer crime that goes against numerous U.S. and United Nations Laws.
875. The above name action constitutes computer fraud, as items were pilfered from the Plaintiff's computer and fraudulently utilized by and attributed to the Defendants, reaping them millions in ill-gotten profits.
COMPUTER AND DATA DAMAGE MADONNA AND CO-DEFENDANTS
876. Madonna is clearly in possession of Aisha copyrighted multi-million dollar valued catalog that she criminally procured and has been using in boldface violations of Jamaica, U.S., British and United Nations laws to the tune of millions in illegal, ill gotten profit.
877. The hacker hired by Madonna caused extensive damage to three of the Plaintiff's computers on several occasions. Previously, L.A. Times journalist Anita Busch reported, her hard drive was destroyed by Madonna's lawyer Bert Fields' private investigator, Anthony Pellicano, when she was working on unflattering stories to print in the L.A. Times.
878. Similarly, viruses and trojans were deployed on a regular basis to Aisha's computers, with certain parameters and instructions, to attack specific WordPad files containing Aisha’s Sound Off Column that regularly slammed Madonna for stealing Aisha’s work, scripts, songs, business contacts and legal documents. Items were surreptitiously being deleted from Aisha's computer as though the internet hacker felt that it would remove these items and lawsuit files from existence. However Aisha had back-up copies saved and was able to put them back, but the hacker's constant intrusions and deletion of key files created instability within the Windows Operating System on Aisha’s computers, creating lasting damage.
879. Once Aisha realized her computers were being hacked on a regular basis, she installed a stronger firewall. However, numerous times Aisha was not able to get on the internet because according to her ISP, "someone is trying to hack your computer's firewall" and the “firewall was resisting” by limiting and “blocking access to and from the internet.” Continued efforts to disable the Plaintiff's computers' firewall and anti-virus software were a great inconvenience and cost Aisha loss work time. Technical support representatives from Microsoft and EarthLink advised the Plaintiff that someone was actively “trying to shut off her computer's firewall” via hacking to “gain access to her computers.” This created numerous problems and inconvenience for the Plaintiff.
880. This happened several times and caused a loss of work time, computer damage, extra time and costs in computer security measures. At certain times the hacker was able to penetrate the firewall and further copy more items, that unbeknownst to the hacker was copyrighted - these items once again began surfacing in more of Madonna and Mavericks new projects, violating Aisha's copyrights.
881. IP tracking was also utilized, evidenced by the fact that Madonna and the Sun Newspaper days after utilized items Aisha had previously typed into search engines. When Aisha would type certain terms into the Search engine Google that pertained to “Lawsuits” “Warner Bros” and or “Madonna” the computer's memory and resources would be overworked by an outside source that was tracking and recording what she would type.
882. While Aisha searched Google while investigating this case, using the search string "Warner" "lawsuit" and "musician" Aisha’s disc drive lit up twice about 10 minutes apart between 7:40 and 7:50 AM on Tuesday May 10, 2005
883. Aisha typed "Warner Bros" "Lawsuit" and Musician" into Google to do research for the case, and unprompted her computer's disc drive with nothing in it, lit up for prolonged periods of time 10 minutes apart, which was someone trying to hack and unlawfully extract any information contained on her computers. When a drive lights up by itself, for prolonged periods of time without prompting and without anything in the disc drive, it is a universal sign of hacking.
884. No one has any business being in someone's computer without their permission. It is bumptious, criminal, pathetic and unethical. Their unwelcome, intrusive presence in the Plaintiff's life is completely reprehensible and perverse by any standards. It was a form of harassment as well. To let her know they were watching her, as has been done to others who opposed them legally or journalistically.
885. Their conduct became an inconveniencing nuisance, as so many precautions had to be taken and later certain projects had to be written on paper, as opposed to computer. The entire episode was a commissioned and orchestrated with the worst of intent - to steal the Plaintiff's unreleased copyrighted works and limiting their liability with regards to access.
886. When the Plaintiff realized what they were doing and began deleting WordPad files after she had printed them out, they resorted to hacking and planting "RSS recovery documents" to retrieve word pad documents containing scripts, songs and other writings that she had written, saved, printed then deleted, before going online to protect their integrity.
887. The Defendants crossed international lines when Madonna transferred pilfered intellectual property from Aisha’s computer to Defendants Victoria Newton and the Sun Newspaper in England. The Defendants repeatedly accessed private copyrighted files containing scripts, songs, fashion line, and other writings, housed on Aisha's computers, without authorization. Madonna and Victoria Newton then went a step further and utilized those files for articles in the Sun Newspaper to enhance Madonna's image.
888. Said misconduct was done for financial gain, to the Plaintiff's detriment with aggregated losses in the high millions, as they made a regular habit of lifting copyrighted items from Aisha's scripts and forthcoming Sound Off Columns for article ideas in the Sun Newspaper, many of these articles about Madonna to enhance her sullied image to the public.
889. These acts were a violation of the Computer Fraud and Abuse Act of 1986 and Title 18 U.S.C. Sec.1001 and 1030. It also constitutes violation of British data interception and tampering laws.
CORPORATE THEFT MADONNA AND CO-DEFENDANTS
890. The Fourth Amendment states it is the, "right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized." The Defendants intentionally invaded Aisha's privacy for financial gain to the tune of almost $500,000,000.
891. The malfeasance began with the Defendant Madonna stealing from Aisha’s publicly released copyrighted online music, lyrics, photos, articles and diary entries and progressed to something far more sinister - corporate theft via wiretapping, computer hacking and stalking - even going as far as to watch the footage Aisha would shoot in public for music videos and projects - with Madonna later announcing that she too was filming the same thing. Never mind Aisha had already filmed and copyrighted it.
893. Madonna is now in criminal possession of Aisha’s copyrighted catalog containing 6,000 unpublished songs, a few dozen film scripts and synopsises that she, Madonna has been criminally using in violation of United States and United Nations laws.
894. These acts of organized crime were spearheaded and commissioned by Madonna, who has developed an obsession with illegally spying on stealing from Aisha, who at no time wished to do business with her or any of her co-Defendants, as she deplores her work and what she stands for. This however did not deter Defendant Madonna, who turned to illegal means to obtain then utilize copyrighted works that never belonged to her.
895. Aisha has established ownership of the materials in question first as proven by her copyright registration dates. The only way the Defendants could have obtained these works is via hacking and wiretapping, as instructional files that were not copyrighted, were also tellingly and damningly utilized by Madonna and Victoria Newton of The Sun, proving it was pilfered from Aisha’s computers.
896. The file that first gave the point of unlawful access away is apart of the fashion line Aisha copyrighted and registered the name for online. In that folder contained a file on “how to make shirts for kids." However, Aisha did not copyright that file as it came from an instructional site. Weeks later, Madonna announced her own fashion line with an article placed in the Sun Newspaper, written by friend and email pal, Defendant Victoria Newton, titled “Madge’s Hot Tops For Tots.” The un-copyrighted accompanying file on Aisha’s computer desktop came from the Internet and was about making “tops for tots.” The "Windows properties" tab for the article Aisha's saved to her desktop, reveals that it was saved weeks prior to the article appearing in the Sun Newspaper under Victoria Newton's column announcing Madonna's new venture that ripped off Aisha's clothing line "Smarty Shirts" and several items from it and its accompanying Jewelry and Jeans line.
897. In this day and age where
child pornography and child sexual abuse have surged around the world, no one
should endeavor to make "hot tops for tots" which could only serve to encourage
pedophilia. 898. This is more prima facie evidence that the unlawful access to Aisha's copyrighted works was via hacking her computers and illegally copying then utilizing the contents of the copyrighted works also contained in the Library Of Congress.
899. It is a most despicable, underhanded, dirty crime that warrants the strongest reprimanding. It is completely unlawful, inappropriate and unconscionable that a law abiding citizen can author numerous works, ideas and innovations over the years, copyright them, then a lawless person invasively, perversely and sneakily steals them via blatant corporate theft in utilizing illegal wiretaps and hacking, to limit liability for their criminal conduct. The Defendants did just that and went on to reap millions in profit off work that was never their own. This is a great injustice.
900. Further acts of corporate theft include ripping off Aisha’s ideas and unique site features then clumsily and unethically running to the mainstream with it claiming it as her own.
901. RINGTONE SHOP - Aisha published her first web site with an area to purchase ringtones that she was to launch shortly. Madonna ripped off this site feature, ran with it to the mainstream announcing herself the first artists to offer ringtones on her web site when she stole the idea from Aisha’s web site
902. BUSINESS PLANS - Numerous ideas and business plans Aisha discussed over the phone, Madonna criminally used, rushing them out to beat Aisha to the punch at using her own ideas and business plans in what can only be described as characterless and depraved.
903. Madonna and her brother Defendant Christopher Ciccone further used two copyrighted business plans belonging to Aisha to start a restaurant and a real estate business.
904. Madonna’s Kabbalah Center further used another of Aisha’s copyrighted real estate plans, but greedily corrupted it to rape and pillage real estate in the black community.
TELEPHONE THEFT MADONNA AND CO-DEFENDANTS
905. The Fourth Amendment states it is the, "right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized."
906. The Defendants intentionally invaded Aisha's privacy for financial gain, utilizing numerous business and personal telephone calls for financial gain and publicity. After a while, Aisha’s family couldn’t even use the phone to discuss personal events in family members and friends’ lives and well-being. The Defendant Madonna would apply the Plaintiff's personal and business conversations to herself in the Sun Newspaper and other articles, attributing them to herself - a most perverse act. Other items later appeared on Madonna’s partner’s show CSI:Miami.
COMPUTER DATA TAMPERING MADONNA AND CO-DEFENDANTS
907. The Defendants hired a hacker to illegally access and copy files stored on Aisha's computers containing a 6,000 song catalogue, scripts, music video treatments, a fashionline, promotional plans and trade secrets among other copyrighted items. The hacker deleted several files containing copyrighted works and later documents pertaining to this lawsuit and accompanying evidence files. Thankfully, Aisha has a regular habit of burning all her works to discs and keeping physical copies as well.
CYBER STALKING MADONNA AND CO-DEFENDANTS
908. Aisha's online activities were being tracked and recorded by the Defendants, later utilizing portions of it for corporate theft and to illegally access her accounts via keystroke capturing. Every site Aisha went to was being recorded and forwarded to Madonna and several of her co-defendants. Every item Aisha typed into a search engine was being recorded and forwarded to Madonna, who on several occasions publicly repeated and wrote verbatim, items Aisha had typed into the search engine Google and cited articles she'd searched for and read on the internet, publicly attributing it to herself and her cronies at Defendants The Sun Newspaper UK and other press articles.
909. Aisha should be able to do research and make purchases online in peace without having anyone tracking, recording and utilizing her every move. It is completely unconstitutional and depraved.
INTELLECTUAL PROPERTY THEFTALL THE DEFENDANTS
910. Madonna and her co-defendants stole numerous copyrighted works from Aisha in a vile act of intellectually property theft. Madonna has always been idea challenged, as evidenced by the numerous copyright infringement lawsuits against her throughout her career. She terribly exploited and criminally robbed Aisha of her copyrighted intellectual property to help sustain and revitalize her fading career, but to no avail.
PROPERTY THEFT ALL THE DEFENDANTS
911. Illegally accessing Aisha's computers and stealing her copyrighted works is just like going into her home without her permission and stealing items from it for personal use. You cannot unlawfully go into someone's home and take what you want, neither can you go into someone's computer housed in their home, and steal copyrighted works from their hard drive. It is absolutely criminal.
912. The Defendants through a hired computer hacker, invaded Aisha's privacy and her home via the internet and stole Aisha’s multi-million dollar valued copyrighted catalog Federally protected by The Library of Congress and The United Nations and criminally used these works. This was in addition to the works they'd previously stolen from her public web site, in plain sight of many, several of whom contacted Aisha via the internet to inform her of Madonna stealing her music and literary works from her site. Madonna has unlawfully stolen Aisha's multi-million dollar valued copyrighted catalog and is in unlawful possession thereof.
DEALING IN STOLEN GOODS ALL THE DEFENDANTS
913. Madonna and her co-defendants have criminally used Aisha’s multi-million dollar valued copyrighted catalog, they commissioned the pilfering of from Aisha's computers via unauthorized entry into her computer, data tampering, hacking and invasion of privacy. This is dealing in stolen goods, as they've used it to obtain deals and make millions in ill-gotten profit off of copyrighted intellectual property that never belonged to them, infringing the rights of the Plaintiff.
BREAKING AN ENTERY; TRESPASSING MADONNA AND CO-DEFENDANTS
914. Computer - Aisha's computer housed in her home was hacked with her copyrighted multi-million dollar catalog criminally copied and used by the Defendants.
915. Home - Aisha's home was broken into in an incident she believes was commissioned by Madonna in the unlawful surveillance and corporate theft campaign she has utilized against her. Madonna and Jerry Bruckheimer's lawyer Bert Fields was accused of using such tactics via his private investigator Anthony Pellicano to burglarize Court TV's Diane Diamond of valuable case documents and related papers.
916. In addition to the break in attempt, there have been times when Aisha and her mother returned home after going out only to find items weren't where they left them. They have not experienced anything like this until Madonna started targeting Aisha and stealing her work in an obsessive, flagrant, criminal manner.
917. Things they have said in the privacy of their home has been repeated in public interviews by Madonna, repeated back to Aisha by strangers that were sent to harass her in public, printed in the Sun Newspaper UK and utilized on the Warner Bros show CSI:Miami.
INVASION OF THE RIGHT OF PUBLICITY MADONNA, CALLOWAY ARTS AND ENTERTAINMENT, VERSACE, DONATELLA VERSACE, PRATO VERDE, MARIO TESTINO, DISNEY
918. Spearheaded by Madonna, Defendant Calloway Arts and Entertainment published and marketed books on a worldwide basis that willfully and criminally violated Aisha’s Right of Publicity via using items from her private copyrighted multi-million dollar valued catalog and items from an illegal surveillance campaign of Aisha, in Madonna’s Kabbalah children’s books series in what can only be described as abhorrent, depraved and despicable. This misconduct also constitutes criminal acts of invasion of privacy. As mentioned previously in paragraphs 83-86:
Madonna’s “The English Roses” Children’s book:
919. Madonna's children's book “The English Roses,” sickly has a page about spying on a girl, a character, who is a lot like Aisha in the description Madonna used to describe her in the book. The book eerily says, "They couldn't turn down the chance to spy on Binah without her knowing they were there" and "but she'll think were burglars or something (Aisha's home studio was burglarized shortly after she began publicly complaining on her web site of Madonna stealing her copyrighted music from the site, SEE EXHIBIT 13, for Police Report) and "she will call the Police" are among the odd, demented lines in the children’s book.
920. Even more eerie is the fact the character they were spying on, Binah's life is a lot like Aisha's, especially in the exact list of chores Aisha does at home that the books lists on Page 32 in great detail and illustrated pictures (peeling potatoes, chopping onions, scaling fish, washing the clothes, ironing the clothes, scrubbing the floors, taking out the trash and taking care of a parent they live with).
921. Even the description and picture of Binah's room in the book is like Aisha's actual bedroom at home. The character in the book was not based on Madonna's daughter, as she deceitfully claimed on several TV shows and in magazines - it was perversely based on Aisha, who Madonna has criminally had under surveillance, as she stole the young singer’s copyrighted multi-million dollar catalog and began using it.
922. Madonna's daughter does not do any of those chores (peeling potatoes, chopping onions, scaling fish, washing the clothes, ironing the clothes, scrubbing the floors, taking out the trash and taking care of the parent they live with) as she was 5 years old at the time the book was published. Nor is she blond, like the character in the book (her hair is black). Aisha does those exact chores several days a week, lives with her mom who she takes care of and has had her hair blonde for over 10 years.
Madonna’s “Lotsa De Casha” Children’s book:
923. In the book “Lotsa De Casha” the character sleeps with a blanket every night that is similar in color and pattern to the one Aisha sleeps with every night. She’s had this blanket for over a year and a half, which predates Madonna’s book.
924. Aisha sleeps with a pink and white blanket with stars and squares on it that was given to her by her mom’s friend. The character in Madonna’s book “Lotsa De Casha” sleeps with a pink and white blanket with squares on it that was given to the character by a friend. This blanket appears on page 30,33,35 of Madonna’s book.
925. The book further contained incidents that happened in Aisha’s home. On Page 30 the main character moves a desk and as a result has an “aching back” from it. Last year, Aisha’s mom gave her her desk when she bought a new one. Aisha moved the desk from her mom’s office area in the house and strained her back (Aisha has had a slipped disc 3 times over the last 10 years). The desk was bought at an auction years ago and the one used in Madonna’s book “Lotsa De Casha” published this year is very similar to it.
926. Aisha said over the phone “just because something is expensive doesn't mean its worth it” This same line appears in Madonna’s book verbatim on Page 10 of “Lotsa De Casha.”
927. Aisha bought a distinct chair from a thrift shop 10 minutes from her house that sells items given to them by members of the public (in exchange for a tax donation receipt that can be used when filing one’s yearly taxes). The chair looked like an antique and caught Aisha’s attention. When she brought it home, she and her mom had a debate over whether or not the chair was really an antique, with one of them wondering out loud why someone would give away such a chair, as it was in great condition. Aisha has a receipt for this purchase. This chair appears in Madonna’s children’s book on page 32, and as Aisha and her mom had debated about its authenticity, in Madonna’s later released book, the lead character said who would give away such nice furniture.
Madonna’s “Adventures Of Abdi” Children’s book:
928. In the children’s book “Adventures of Abdi” the two main characters sleep in “two simple rooms to the back of the shop” - with the shop beign their business. In Aisha’s home, she and her mom sleep in two rooms to the side of the house, with the two front rooms and one to the back used for office space - Aisha’s office and studio and her mom’s office being the third.
929. In the book, their rooms are roped off from the shop by two Spanish monastery typed solid arched wood doors. In Aisha’s home, their rooms are roped off from the offices by two Spanish monastery typed solid arched wood doors.
930. In the book, the lead character Eli taught his son Abdi “how to navigate by the stars how to make lentil soup and how to be happy.” About two years ago, Aisha’s mom who is a gourmet cook taught her how to make her famous soup in the same home they have now found out was criminally under surveillance by the Defendants.
931. Aisha’s mom has to turn in long, detailed paper reports to her employer every month. The work at times has been overwhelming for her. Aisha’s offered to help her mom and said to her “I’ve watched you do this a million times. I can do this.” Her mother still wanting to do the work declined. In Madonna’s children’s book, Abdi told Eli regarding his work that had become too much for his father, “I’ve watched you do it, I can do it.”
932. When Aisha’s mom finished all her paperwork in the morning when Aisha woke up she told her, “I can’t believe you finished it all.” In the book the “Adventures of Abdi,” the lead character said to the other noticing that he finished the work by morning “I cannot believe you finished in time."
933. Aisha’s mom has said at different times in their home that “you can always tell the letters from her sister Rose in England because the mail has a crown on the envelope,” - the crown is the symbol used by the Royal Mail service in England. In the book the “Adventures of Abdi” the character said “he could tell it was an important letter because it had a big crown on the top.”
934. These are several blatant, detailed similarities of incidences, furniture, house layout and things said in the privacy of Aisha’s home and over her phone that are eerily and sickly detailed in Madonna’s children’s books. And in light of the fact that Aisha has discovered that her home has been criminally under surveillance by the Defendants and has digital proof to back up this claim, it is very clear and very disturbing what has transpired here.
935. Defendants Madonna, Donatella Versace, Versace, Prato Verde and Mario Testino have exploited Aisha in a most disgraceful way, even going as far as utilizing her life, persona and likeness, for a Versace ad campaign titled, "The Contemporary Woman," and “The Working CEO” as described by Donatella Versace. These ads recreated Aisha's life from her copyrighted online Diary writings, where she wrote of spending her days on the telephone and computer and watching TV. The Versace ads in question featured Madonna on the telephone and computers, and watching TV.
936. The Defendants went as far as buying furniture from Miami for the shoot, Aisha's hometown of 20 years, and having a wig made for Madonna that resembles Aisha's hair in color, cut, style and texture. These ads netted the Defendant Madonna $10,000,000 and gave a great boost to Versace’s spring women’s wear line, getting their books out of the red. This illegal use of Aisha’s life, likeness and recognizable aspects of her persona by the Defendants was a gross violation of her Right to Publicity and Right To Privacy, as prescribed by U.S. law.
937. The Defendants Madonna, Donatella Versace, Versace, Prato Verde and photographer Mario Testino have exploited Aisha in a most disgraceful way, to go as far as utilizing her copyrighted online Diary, life, image, likeness and recognizable aspects of her persona for the multi-million dollar Versace ad campaign. It is a fundamental right that they stole from Aisha - the use of her own image and life.
938. The ads were clearly created on Aisha’s Diary writings and bio which described her day in detail (as an “indie label CEO”), which is spent “on the phone and computer” and “watching TV” in her home office. The idea of a CEO doing these things is a novel concept, however, Aisha has an indie label that she started herself - hence doing all the groundwork herself.
939. The well-publicized Versace campaign is of a blonde CEO, on the phone, typing at the computer and watching television. Aisha fits that description to a tee, while Madonna does not and never has.
940. The most damning evidence comes courtesy of Donatella Versace in a Staronline.com email interview where she referred to the ads as, “The Contemporary woman is not afraid to be a woman. She can still be powerful by keeping her femininity.”
941. Aisha’s debut single that Madonna willfully plagiarized and infringed its copyrights is titled “Contemporary Girl” - while Donatella Versace referred to the ads as the “Contemporary Woman.”
942. Moreover, the contents of Aisha’s song is about women embracing their femininity even in the work place, much like the later released ads by Madonna and Versace, who herself paraphrased Aisha’s lyrics to describe the theme of the ads in said interview.
943. The Defendants even went as far as to import Miami furniture for the ad campaigns, which has been Aisha’s hometown of the last 20 years. They also hired a wig maker via stylist Julien D’Y to create a wig for the ads that resembles Aisha’s actual hair in style, cut, color and texture.
942. The furniture was obtained by Michael Howells, who testified to its Miami origins in the London Times newspaper and several references have been made to “the wig” Madonna is wearing in many publications.
943. The ads were a clear recreation of Aisha’s life from theme, persona, job title, song title and lyrics, which was a completely unlawful utilization of her work, life and image by the Defendants.
944. It is forbidden under U.S. law to use someone’s persona and or recognizable aspects thereof, image, likeness and or life without their permission, especially for financial gain. It is exploitative, deceitful and utterly pathetic.
945. The press mistakenly thought the ad campaign was of Madonna as a secretary and questioned its authenticity. Due to the fact that most secretaries cannot afford Versace's overpriced, overly colorful clothes, the ads seemed even stranger to the press and fans alike.
946. Donatella Versace publicly tried to correct this by stating in Italian Vogue that the ads as told to her by Madonna were of a “Working CEO,” which is pretty telling, as Aisha is a “Working CEO,” even by definition, one who uniquely does all her company’s secretarial work herself, hence leading to the confusion in the ads that rip off her persona, mistaking it for a secretary. SEE EXHIBIT 41 FOR THE VERSACE ADS.
947. CEO’s commonly don’t answer their own phones, do their own secretarial work and watch TV in their office, however, Aisha does that out of necessity due to her company being an indie start up label.
948. The Defendant Madonna has also gone on record many times in interviews with journalists like NBC’s Matt Lauer, saying she “doesn’t watch TV.” This has been a well-publicized declaration for years from Madonna’s own mouth. More proof that the ads were never molded on her life, but rather on Aisha's life and persona as described in detail on her copyrighted web site.
949. These ads were never based on Madonna or anyone other than Aisha, which is a violation of the Plaintiff's Rights Of Publicity. She owns and controls her image, persona, life and the usage thereof and never gave anyone permission to use it, especially in the gross exploitative manner the Defendants did for those tacky ads. This malfeasance was willful, flagrant and a gross violation of Aisha's Right Of Publicity.
950. As in the Bourdin lawsuit against Madonna (Samuel Bourdin v. Madonna 2004), which she had to settle out of court due to how obvious the rip offs and duplications were and the fact that she could not justify her conduct in court, she stole copious amounts of copyrighted intellectual property from one medium (copyrighted photographic art owned by Bourdin) and transferred it to another (music video - her video “Hollywood”).
951. Guy Bourdin is a deceased artist, which she obviously felt would make it easier to steal from him, as he is not here to defend himself or his rights against a grave robber, Madonna.
952. However, his son Samuel saw what happened and legally fought to restore and preserve his father’s copyrighted works that were unlawfully duplicated by Madonna in a most crude, substandard fashion (SEE EXHIBIT 57).
953. She ruined Bourdin’s works that utilized vigor, color and symmetry, replacing them with her haggardly, clumsy knock off. Side by side stills of Bourdin’s works and Madonna’s rip off, show the precipitous deterioration in the quality of the latter. It unintentionally looks like a comedic spoof of his copyrighted works due to its poor quality.
954. Defendants Madonna, her friend Donatella Versace, Versace, Prato Verde and photographer Mario Testino stealing from Aisha’s copyrighted web site bio, diary writings and Flash film movie is no different from a director who steals from a copyrighted script and recreates in on film (Buchwald vs. Paramount and Murphy).
955. Madonna, Donatella Versace, Versace, Prato Verde and Mario Testino wrongfully used the Plaintiff’s likeness and recognizable aspects of her persona, for a $20,000,000 Versace ad campaign in willful violation of the Lanham Act § 1125, The Right of Privacy Act and Right Of Publicity Act.
956. Aisha is known to millions of web site visitors, as verified by web site hits, among them university students from schools all over the world, journalists, MTV, publishers, ad agencies, investment companies and various international government agencies.
957. Furthermore, the Defendants Madonna, Donatella Versace, Versace, Prato Verde and Mario Testino credited themselves with these ads and its unique concept, that wasn't their idea, as it was illegally based on Aisha's life, image, persona, copyrighted text online Diaries, Bio and Flash film movie they foully exploited for financial gain and publicity.
958. No one has the right to do that to another and it is completely disgraceful and extremely exploitative. Not content with criminally stealing Aisha's publicly released and private unreleased copyrighted works, the Defendants sought to exploit her even further by unlawfully using her image, likeness and persona, which is thoroughly reprehensible.
959. The Plaintiff has exclusive rights to her image, persona and likeness and the licensing thereof, which the Defendants Madonna and Versace willfully infringed and exploited for an ad campaign that netted her, Madonna millions and scored Versace a lot of publicity and sales, due to the uniqueness of its concept, “A Working CEO.” These ads have been featured worldwide in just about every fashion magazine on the planet:
960. US: Elle, Harper's Bazaar, In Style, Interview, New York magazine, Rolling Stone, The New York Times, The New York Times Magazine, The New Yorker, Time - Style & Design Issue, V Magazine, Vanity Fair, Vogue, W, UK, Arena, Elle, Harper’s Queen, Tatler, The Times, Vogue, Wallpaper France: Citizen K, Elle, Glamour, International Herald Tribune, Jalouse, M. Figaro, Marie Claire, Numero, Officiel, Vogue Italy: Amica, CHI, Corriere Della Sera, D Repubblica, Elle, Espresso, Flair, Glamour, Grazia, Io Donna, M. Claire, Max, Vanity Fair, Vogue Germany: Elle, Glamour, In Style, Madame, Petra, Vogue Spain: Elle, Glamour, La Vanguardia mag, Telva, Vogue Belgium: Elle, Knack Weekend, Marie Claire Japan: 20 ans, Elle, Harper's Bazaar, Spur, Vogue China: Cosmopolitan, ELLE, Harper's Bazaar, I Look Russia: Elle, Harper's Bazaar, Jalouse, Officiel, Vogue, Wall Paper
961. The ads were also written about in noted newspapers like the Telegraph in London. Madonna did her best to give the public the perceptions that the ads were about her, which was quite sick considering as previously stated in this section, is completed untrue, as she never was any of the things she pretended to be for the ads. She was pretending to be Aisha’s for the ads, continuing her sick stalking and harassment of the younger singer.
962. This malfeasance has been injurious to the Plaintiff as they are exploiting and utilizing her copyrighted works from her copyrighted online Diary page, flash film intro, official web site and text bio and recognizable aspects of her persona to promote a product she doesn’t care for due to its exorbitant prices, garish appearance and message of overly lavish living, which is contrary to her faith, Christianity. Aisha's taste are more conservative, therefore she cannot stand Versace's trademark extreme use of every color of the rainbow on one garment.
963. The Defendants false and deceptive advertising to so many members of the public worldwide has been injurious to Aisha, who was terribly exploited by the Defendants in a most basic right, access and control of her image and persona. Madonna tried to become her for the ads, which is quite perverse and disturbing.
964. It is completely unlawful and another example, one of many, to the Defendants willful disregard of the law and basic civil rights. No one has the right to go around exploiting a person and their image for millions of dollars in profit, publicity and sales. Madonna herself recently and hypocritically sued someone for doing this to her. The same thing she did to Aisha was done back to her recently and she did not like it one bit.
965. Defendant Disney further misappropriated Aisha’s image, copyrighted music and web site content for use in the Disney show “Raven,” which contained a character who was a black blonde haired singer named “Myisha.” Aisha is a black blonde haired singer. Myisha’s tune on the show contained similar lyrics to Aisha’s 2001 “Contemporary Girl” and the character’s name is very similar to Aisha’s, both ending in the letters “isha.”
966. The violated Aisha’s copyrights for “Contemporary Girl” in scripting lyrics for the show’s character that used similar lyrics to Aisha’s song. Both Aisha’s Contemporary Girl and the Disney rip off are about an old fashioned girl with a private jet.
INVASION OF THE RIGHT OF PRIVACY MADONNA, VERSACE, DONATELLA VERSACE, PRATO VERDE, MARIO TESTINO, DISNEY
967. This portion of the charge is apart of the previously stated Invasion Of The Right Of Publicity, in which the Defendant’s ripped off Aisha’s life, image and persona for financial gain in a series of Versace ads to the tune of $10,000,000 paid to Madonna and a surge in sales that got Versace’s books out of the red due to the uniqueness of the campaign that despicably ripped off Aisha’s life, image and persona. This unauthorized use of and misappropriation of Aisha’s image, likeness and recognizable aspects of her persona constitute violations of the Right Of Publicity.
968. They gained an unreasonable amount of publicity from this malfeasance that was an act of sheer exploitation, greed, fraud and misappropriation. It also violates article 17 of the International Covenant On Civil and Political Rights and Article 8 of the European Convention for the Protection of Human Rights and Fundamental Freedoms.
969. Defendant Disney further misappropriated Aisha’s image, copyrighted music and web site content for use in the Disney show “Raven,” which contained a character who was a black blonde haired singer named “Myisha.” Aisha is a black blonde haired singer. Myisha’s tune on the show contained similar lyrics to Aisha’s 2001 “Contemporary Girl” and the character’s name is very similar to Aisha’s, both ending in the letters “isha.”
970. The violated Aisha’s copyrights for “Contemporary Girl” in scripting lyrics for the show’s character that used similar lyrics to Aisha’s song. Both Aisha’s Contemporary Girl and the Disney rip off are about an old fashioned girl with a private jet.
DECEPTIVE TRADE PRACTICES ALL THE DEFENDANTS
971. The Defendants are in willful violation of the Uniform Deceptive Trade Practices Act. They have unreasonably and intentionally interfered with Aisha’s work and businesses, Sonustar, Aisha Music Interactive Inc, for their own financial gain and advancement. These fraudulent, criminal, unfair trade practices which are in violation of the Business and Professions Code of Sections 17500 to 17535, resulted in substantial damage and loss to Aisha, who did them no harm, nor did she wish to do business with any of them at any time. They willfully mislead the public that Aisha’s copyrighted works were their own in deliberate acts of misrepresentation and fraud, with Madonna fraudulently claiming the bulk of the credit numerous times.
972. They have unreasonably and intentionally interfered with Aisha’s businesses many times to disrupt it and capitalize on her copyrighted works. This misconduct escalated into invasion of privacy, harassment and assault.
FRAUD ALL THE DEFENDANTS
973. The Defendants have engaged in a willful pattern of malicious and flagrant copyright infringement and plagiarism, criminally, unlawfully and fraudulently claiming Aisha's copyrighted works as their own on many occasions, in print and on television, around the world. The Defendants have publicly stolen writer’s credit and royalties for Aisha's work with many entertainment writers and organizations like ASCAP and the WGA.
974. These copyright infringing works have been nominated for numerous industry awards and accolades, all crediting the Defendants as the authors when they never were. These infringing works were clearly created from Aisha's copyrighted materials, which the Defendants criminally stole for financial gain and career advancement.
COMMON LAW FRAUD ALL THE DEFENDANTS
975. The Defendants willfully stole copious amounts of Aisha’s copyrighted works with the intent to deceive the public that it was their original creations, when they were not. These malfeasances robbed Aisha of credit as author, authorial fees and subsequent royalties. It was their intent to capitalize on Aisha’s works by creating knock off’s that they presented to the public as their own. Several of the knock off’s containing duplications of Aisha’s copyrighted work.
976. The criminal misrepresentation of authorship and royalties has created significant damage to the Plaintiff. Their willful conduct is the sole reason for these damages. The public believed the gross misrepresentation set forth by the Defendants, thus robbing Aisha of credit for work that she authored. This has affected Aisha’s résumé, as her innovative works have been wrongfully and criminally attributed to the Defendants to millions of people all over the world.
977. The Defendants all asserted these misappropriations of authorship as fact, fraudulently crediting themselves as the authors of numerous of Aisha’s copyrighted works from her valuable catalog they criminally obtained. It was done with the clear criminal intent to fraudulently deceive the public as to its origins, for critical acclaim. Awards committees, critics and fans alike were induced by these deceptions, which reaped great profits in the millions for the Defendants.
978. Aisha as a result suffered damages in lost credit and royalties for her copyrighted works, in addition to the emotionally distressing experience of seeing your work criminally stolen and credited to someone else who had nothing to do with it.
CONSTRUCTIVE FRAUD ALL THE DEFENDANTS
979. The Defendants have committed constructive fraud in the participation and release of copyright infringing works that were criminally procured.
EXTRINSIC FRAUD ALL THE DEFENDANTS
980. The Defendants deliberately destroyed evidence relating to this case in damaging Aisha's computers and deleting incriminating files and emails pointing to their guilt. Legal files pertaining to this lawsuit were erased from Aisha’s computers at different times by the Defendants via hacking and had to be rewritten. Evidence that points to their unlawful hacking was deleted from Aisha's computer, but thankfully she kept back up copies of said hacking evidence. They have caused extensive damage to her computers.
981. Defendant David Bercuson, a Warner Bros affiliate, also lied to and terroristically threatened Aisha in an attempt to get her not to sue Madonna and his affiliate Warner Bros. He pretended he was interested in her case and obtained sensitive case documents from Aisha under false pretenses to see how strong her case was knowing there was a gross conflict of interest he did not inform her of, though he knew.
982. When he got the sensitive case documents and realized how serious and valid the case is, he deliberately mislead her as to the rules of evidence and her rights, screaming at her in a demonic jarring voice that her evidence was worthless and inadmissible in court. His behavior, suddenly and unexplainably changed. When Aisha researched him later on the internet, she found his clear, undisputable ties to Madonna’s label Warner Bros.
INTRINSIC FRAUD ALL THE DEFENDANTS
983. The Defendants intentionally misrepresented the origins of their new projects that had been stolen from the publicly released and unreleased copyrighted works of Aisha. They went around Hollywood with works that had been procured via the criminally commissioned hacking, copying and theft thereof from Aisha's private computer based multi-million dollar valued copyrighted catalog and made million dollar deals with stolen goods that are the rightful property of Aisha.
INTERNET FRAUD ALL THE DEFENDANTS
984. Aisha’s works have been falsely credited to the Defendants on numerous entertainment industry sites and their own respective sites. Several of these infringing products can be purchased by mail over the internet - items such as compact discs, CD singles, sheet music books and clothes. Defendant Music Today runs a web hosting, site design and fan club management company in Virginia and is responsible for the Madonna and Britney Spears web sites.
985. The Defendants sold copyright infringing items such as American Life CD single, American Life CD, American Life sheet Music, Madonna Remixed and Revisited, The children’s book series featuring Adventures Of Abdi, Mr Peabody's Apples, Lots De Casha, Yakov and The Seven Thieves.
986. The Defendants Music Today Inc further plagiarized and infringed Aisha's copyrights when they came up with a column in January of 2005 that ripped off Aisha's "Sound Off Column," naming theirs" Streams Of Consciousness" for client Britney Spears. Both artists, Aisha and Spears, are now the only two singers with a column, both bearing the same initials and about the same things, namely religion. Defendant Spears frequently plagiarizes Aisha’s web site writings for her own web site.
987. The Defendants willfully ripped off Aisha's 3 year old column, picking a similar name, theme and textual content for their client Britney Spears, who is dully aware of what is going on and contributed to the malfeasances by deliberately plagiarizing Aisha’s writings on several occasions attributing it to herself. When Aisha complained about this on her site on March 11, 2005, naming all the similarities listed above such as same initials and theme, Britney's web column was promptly renamed Love b: Streams Of Consciousness two weeks later.
MAIL FRAUD MADONNA, CALLOWAY ARTS AND ENTERTAINMENT, MUSIC TODAY INC, WARNER BROS, WARNER BROS RECORDS, WARNER CHAPPELL MUSIC PUBLISHING, WB MUSIC CORP, WARNER VISION, WEBO GIRL MUSIC PUBLISHING
988. The Defendants have sold copyright infringing Madonna items via mail order, which constitutes mail fraud, as described in Title 18 section 1341 of the U.S. Code.
989. Several of these copyright-infringing products can still be purchased by U.S. mail over the internet via Madonna.com, Warner Bros Records web site and via Music Today Inc’s Madonna fan club site. These items are, but are not limited to compact discs, CD singles, sheet music books, Madonna’s Kaballah children’s book series and clothes.
990. Calloway Arts and Entertainment distributes the Kabbalah children book series by Madonna via U.S. mail to many Internet retailers and stores, who for a fee will ship the copyright infringing books to customers by U.S. mail.
991. Warner Bros Internet and mail order store sells the copyright infringing CDs, CD singles and digital downloads.
992. Music Today Inc runs a web hosting, site design and fan club management company in Virginia and is responsible for the Defendants Madonna and Britney Spears' official web sites.
993. The Defendants Music Today Inc sells copyright infringing items such as the American Life CD single, American Life CD, American Life sheet Music, Madonna Remixed and Revisited, The children’s book series and clothing line featuring Adventures Of Abdi, Lots De Casha, Mr. Peabody's Apples and Yakov and The Seven Thieves via the internet with U.S. mail shipping and through mail order catalogs for fan club members.
944. The Defendants Music Today Inc further plagiarized and infringed Aisha's copyrights when they came up with a column in January of 2005 that ripped off Aisha's "Sound Off Column," naming theirs" Streams Of Consciousness" for client Britney Spears. Both artists, Aisha and Spears, are now the only two singers with a column, both bearing the same initials and about the same things, namely religion. Defendant Spears frequently plagiarizes Aisha’s web site writings for her own web site.
945. The Defendants willfully ripped off Aisha's 3 year old column, picking a similar name, theme and textual content for their client Britney Spears, who is dully aware of what is going on and contributed to the malfeasances by deliberately plagiarizing Aisha’s writings on several occasions attributing it to herself. When Aisha complained about this on her site on March 11, 2005, naming all the similarities listed above such as same initials and theme, Britney's web column was promptly renamed Love b: Streams Of Consciousness two weeks later.
946. The Defendants willfully and knowingly conspired to and sold items over the Internet, distributing them to customers by U.S. mail, knowing that many of these items willfully infringed many of Aisha's copyrights. They fraudulently passed these items off as their own and sold them at a great profit, shipping them by U.S. mail to many customers around the world.
WIRE FRAUD MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE,
947. The Defendants have committed wire fraud in employing illegal listening devices on Aisha’s telephone lines and then utilizing the contents thereof for financial gain via corporate theft, with items Aisha discussed over the phone appearing in songs by Madonna "The Devil Wouldn't Recognize You" and several articles by the Sun Newspaper journalist Victoria Newton and on the Warner Bros’ show CSI:Miami as a form of harassment. This is a flagrant violation of the Wire Fraud Act with the Defendants conduct also resulting in corporate theft.
948. This intrusion into Aisha's life and that of her family has been extremely upsetting and is inexcusable. The Plaintiff is furious that her privacy has been invaded in such a manner. Not only did the defendants perversely listen into business conversations, they also listened into private conversations between Aisha and a family member who was unwell at the time. The illness in question baffled doctors and said relative and Aisha called each other frequently to provide encouragement and support. Aisha did extensive research on medications available with limited side effects to help her beloved relative. During these calls, they discussed private medical records that the despicable Defendants should not have been listening into. Those were private moments.
949. Aisha also called prayer lines to pray for friends and family who are unwell or going through a rough time. The Defendants perversely and offensively listened into those prayers and conversations for and from Aisha's beloved family and friends, which she finds extremely offensive and despicable. Prayer is a private matter, between the people praying and God that no eavesdropping, thieving pop star or perverted tabloid should be listening into. The whole episode is inexcusable and greatly offensive. It also violates religious freedoms, as people have the right to pray with and for family and friends without it being unlawfully listened to and spied on via wiretaps.
SECURITIES FRAUD DEFENDANTS MADONNA, DISNEY, BUENA VISTA, TIME WARNER AOL, WARNER BROS, WARNER CHAPPELL MUSIC PUBLISHING, WEBO GIRL MUSIC, MAVERICK RECORDS, MAVERICK FILMS, JERRY BRUCKHEIMER FILMS, MUSIC TODAY INC, CALLOWAY ARTS AND ENTERTAINMENT
950. Time Warner AOL, Warner Bros, Warner Chappell Music Publishing, Webo Girl Music, Maverick Records, Maverick Films, Calloway Arts and Entertainment, Music Today Inc, Andrews McMeel, Disney, Buena Vista Pictures and Jerry Bruckheimer Films committed securities fraud in engaging in a deliberate and ongoing pattern of criminally stealing and violating Aisha's copyrighted works for financial gain. This misconduct escalated to stalking, harassment and assault.
951. Numerous released copyrighted items by Aisha were stolen and utilized by Madonna, Warner and their co-defendants. Other items were later stolen via corporate theft, fraud, invasion of privacy and grand larceny. These acts broke numerous civil and criminal laws in flagrant violation of SEC rules.
952. Time Warner AOL and Disney are manipulating the stock market through these acts of fraud, theft, conversion and copyright infringement which is showing unearned, ill gotten profits - in addition to the "accounting scams" the government has already fined AOL $300,000,000 for.
953. Independent copyright holding writers need the governments help in protect them from the vulturous, ravenous, multi-national, media monopolizing, copyright infringing, corporate bullies Warner Bros (Time Warner AOL) and Disney and it’s film and music subsidiaries. They have hurt and defrauded countless writers who have sued them for violating and exploiting their copyrights to the tune of billions of dollars.
954. The Securities Exchange Act of 1934 states: "Companies offering investment opportunities must be open and forthcoming about the status of their business and the stocks they are offering. This way the investor has the opportunity to judge the information and assess the potential invest risks versus gains. Persons who sell or exchange securities must perform their business honestly and with fairness. Because a broker-investor relationship involves trust on the part of the investor, the broker (or dealer, or company, as the case may be) must provide reliable information to his customer.
955. The above named Defendants are SEC recognized corporations with damning, extensive histories of continual copyright infringement, plagiarism, property theft, and in this case those same charges coupled with corporate theft, invasion of privacy, harassment, assault, terrorization, fraud, libel, racketeering is not "performing their business honestly and with fairness" nor is it " being opening and forthcoming about the status of their business" nor is it " providing reliable information to their customer" as SEC rules demand.
956. They are in violation of SEC rules in the areas of accounting fraud in “keeping inaccurate books or presenting false information purposefully,” and in acts of misrepresentation in “presenting misleading or untrue information about a company, or its securities, to an investor or the public.”
957. They have criminally stolen and misrepresented numerous of Aisha's already copyrighted works as their own numerous times to global audiences, re-copyrighted her works and diverted millions in sales and royalties from it tallying almost $500,000,000 to their companies and affiliates, in what could only be described as conversion, corporate theft, grand theft larceny and an accounting scam.
Corporate Fraud: 958. The above named Defendants concealed their acts of conversion, criminal copyright infringement and intellectual property theft from the public.
959. As it stands, they have violated Aisha’s civil rights and copyrights in a shameful manner that no one should have to endure. They deliberately hid this misconduct from the public that they willfully committed against this young woman for millions in profits in criminally exploiting her copyrights in violation on U.S. and U.N. laws.
960. The above named companies are incorporated and answerable to the Securities and Exchange Commission - yet criminally violated so many of the Exchange's rules they are bound by, in an intentional campaign of fraud, racketeering, corporate theft, criminal copyright infringement, invasion of privacy, misrepresentation, computer theft and fraud, worthy of imprisonment.
DEFRAUD ALL THE DEFENDANTS
961. All the Defendants deliberately and willfully defrauded Aisha out of millions of dollars in copyrighted works that are protected by U.S. Law and United Nations Law. The Defendants willfully used deceit, falsehood, trickery and invasion of privacy to gain Aisha's copyrighted works, which are valued in the millions, and unlawfully assigned rights of said works to themselves, re-copyrighting them as their own and publicly misrepresenting their true origin and authorship as their own, which has caused the Plaintiff great loss and sadness.
962. Many songs bring in $250,000 to $10,000,000 in royalties, and the Defendants willfully stole Aisha's catalogue containing 6,000 songs and numerous movie scripts, synopsises and music video and pic treatments. This was a vile act of criminal theft with the intent to defraud, worthy of imprisonment.
HARRASSMENT MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE,
963. Beginning in May of 2005, people began approaching Aisha on the streets of Miami and in stores harassing and attempting to intimidate her regarding Madonna. Only these weren't fans. These were people who had clearly been hired to harass Aisha, as they came up to her on 4 separate occasions talking about Madonna, legal matters and things Aisha had just discussed in the privacy of their home.
964. These individuals approached Aisha and out of the blue began talking to her about Madonna and detailed legal matters that pertained to her and this case that you could only know if you'd tapped Aisha's phone and read her faxes that were not sent to the Defendants at any time by Aisha. These people approaching Aisha weren't fans. They didn't come up to her and say "Hi, Aisha." They would approach her, lean really close, touch her and start talking to her about Madonna and things she (Aisha) had said over the phone right off the bat, repeating items from her own telephone conversations to her verbatim.
965. Aisha had never experienced anything like this before. It was clear that it was an attempt to harass and terrorize her out of suing and reporting Madonna to the authorities for criminally stealing her copyrighted multi- million dollar valued catalog via commissioned hacking to make a copy thereof.
966. This misconduct was commissioned, orchestrated and absolutely sick. The Defendants have been watching and terrorizing Aisha in a manner that is unconstitutional and illegal. There is a history of this type of misconduct as well, as opponents of Madonna's lawyer Bert Fields reported people came up to them in public and harassed and threatened them.
967. May 6, 2005 Aisha went into downtown Miami to pay her water bill. Earlier in the day, she had been discussing with her mom in their home whether or not she should file a tax return, as she hadn't earned anything in 2004. She had nothing to declare. Her record wasn't released until December 27, 2004 and she’d spent the whole year working on it. On her way crossing the street, a tall, burly white male with black hair (slight graying), came up beside her, bounce her with his body and said "Did you pay your taxes!" then walked off. The very thing she had discussed with her mom earlier and considering tax season was over, it made what he said even more odd.
968. Days later Aisha went to a photocopy store specializing in photocopying legal documents. A woman came in the store and struck up a conversation with her. Being polite, Aisha spoke back to her kindly. However, during the course of the conversation, the woman, who was very aggressive and wearing a wig, began tapping and poking Aisha on the shoulder with her index finger, in a very threatening manner for no reason. The woman began to ask her odd questions, brought up things to Aisha that she had discussed in the privacy of her home that morning and over the phone in the last few days.
969. Aisha spoke with her dad over the phone about Johnny Cochran’s passing and remembering the time she'd met him in Atlanta a few years prior. Shortly after, she'd spoke with her mom inside their home about filing suit in New York against Madonna, rather than Miami. The lady in the store brought these things up to her out of nowhere in clear detail. The woman tried to intimidate Aisha telling her that if you file a case in New York, it will not be fairly handled if you are your own lawyer suing a big company because people can be bribed.
970. Aisha thought it quite odd that this woman started saying these things to her, especially since she didn't tell her she was suing anyone and it was what she'd just spoken with her mom about before she left the house. Feeling strange about how the woman was in her face and being so aggressive telling her that an individual couldn't win a case in New York and using her index finger to poke Aisha in the shoulder as she spoke to her, Aisha turned away and moved to the other side of the counter away from the woman - who then erratically and abruptly exclaimed "Johnny Cochran was a bad man!" Her words were the exact opposite of what Aisha's dad had said to her over the phone that morning of "Johnny Cochran was a good man." Aisha turned around to the woman and said, "No he wasn't!"
971. That's when she remembered what she and her dad had talked about and realized something was wrong in that this lady was telling her things she'd said over the phone and in the privacy of her own home just hours prior. The photocopy store employee came back over, handed Aisha her copies, she paid for them by check and left. This woman was a mixed black woman, about 5'5 in height, wearing a brown ill-fitting wig and was slender in build.
972. During the third week of May 2005, Aisha caught a bus from outside her home to go into downtown Miami to take care of some legal errands relating to the case. After about 20 minutes, a guy got on the bus, and then came by where Aisha was sitting, awkwardly flashed Madonna's 1992 Greatest Hits CD in front of her, and then got right off the bus. Aisha thought it very odd. He really didn't seem like Madonna's demographic, as he was a black male between the ages of 18-21, dressed in hip-hop gear, with a hardcore grimace on his face. He is not exactly Madonna's demographic, that is mostly white gay and lesbians in their 30-50's. He had no backpack, no bags, only Madonna 1992 Greatest Hits CD in his hands, which was very odd and a liability considering where he got off the bus in a crime ridden neighborhood near downtown.
973. During the third week of May 2005 Aisha went to a computer/interent store that she regularly patronized due to the fact that she discovered her computers were being regularly hacked. A brainwashed looking girl with a crazy, zombie like expression, sat next to her and downloaded a Madonna video on the internet. She immediately menacingly started talking to her about Madonna, leaning close to her in an intimidating, menacing manner. She repeatedly kept asking her in a crazy manner, "Do you like Madonna?" When Aisha responded that she is not a fan, the unbalanced woman kept asking over and over again anyway. Perturbed by the stranger’s odd behavior, Aisha moved to another computer. The stranger attempted to move computers to go near Aisha, but the owner intervened and told her no, you can't switch computers. This woman was medium height with jet-black hair and brown eyes. She appeared to be in her twenties. Even the store's owner and other computer users in the store noticed her odd behavior and looked over to see what was going on, with the store owner later coming over to ask what the shuffle was about.
974. On June 25, 2005, Aisha left a book store in Aventura, a suburb of Miami, after looking at Madonna's children’s books in researching this case, which she hadn't read up until that day. She wanted to peruse them briefly for any signs of further copyright infringement of her work by the Defendants. She was creeped out to find the children’s books contained items and incidents from her home.
975. After she left the store a man came up to her and started talking to her. He said he'd just come off from work. He told her briefly about his family, then abruptly switched the subject - out of nowhere he turned the conversation to organizations and “companies who order hits on people” stating “the order comes from the top and goes right down to the workers” who carry out the vicious attacks. Aisha sensing something was wrong and refusing to be intimidated said, "People who do such things end up dead or in prison. Look at the mafia. Look how many members have ended up dead or in jail." The man's countenance changed to one of shock, he immediately stopped talking to Aisha, who then left.
976. On June 21, 2005 Aisha went to a store she visits weekly. She usually buys computer paper and other items from said store. She is a regular there.
977. Aisha arrived in downtown Miami at 9:25AM. She wanted to make some photocopies before she went to court regarding another civil case. She took her usual route and stopped at a store she goes to regularly to buy paper. On her way into the store, a tall man, approximately 6"2, about 250 pound, wearing a white shirt and black cap said hi to her and motion for her to stop, as though he was going to ask her a question. Aisha had recognized his face, as she had seen him in that area before. He was standing by a van this time taking to a lady drinking a cup of coffee.
978. Then out of nowhere, the perpetrator put his hand on the back of Aisha's neck in a firm grip. Aisha was alarmed and tried to move, but he started speaking and strengthening his grip trying to choke her. He crazily said, "This is my wife. But I am divorcing her. She doesn't treat me well. Doesn’t make me coffee. She’s going to go to court today and she is going to lose. When she goes home she is going to find the papers her mailbox."
979. All the while he was saying this to Aisha, who didn't know him from Adam, he began squeezing her neck even tighter. His hand was so big that is covered the back of her neck and wrapped around her neck about 3/4th’s of the way, which was allowing him to choke her. While he did this, the blonde hair lady drinking the cup of coffee smiled. Aisha kept trying to pry his fingers from around the back of her neck, but he was so strong that it wasn't working, so she spun under his arm, which forced him to loosen his grip or his arm would have ended up twisted and injured.
980. She had seen this same man several weeks prior where he had called to her and tried to strike up a conversation with her. She politely smiled said hi and went into the store.
981. The strange and eerie thing about this incident is 1 hour later at Aisha's 10:30AM meeting with judge Jon Gordon regarding a case management session he ordered, she found out that important, time sensitive documents that were supposedly sent to her and her attorney by mail from a legal opponent were not in a deceitful, unlawful legal maneuver. Aisha called her attorney to ask her if she'd received the document in question and she said no.
982. When she found out about the important official court document that she never received and the fact that when she called her lawyer right after the court meeting she said she’d not received these documents either, Aisha's mind flashed back to the incident that happened earlier in the morning where the man who’d tried to choke her had made reference to her mailbox saying, "When she (Aisha) goes home, she is going to find the documents in her mailbox."
983. On that same day of June 21, 2005 a little after 9:30PM, Aisha's mom who walks with a cane due to Guillain-Barre Syndrome was walking back to their home, when a man on a bicycle came out of nowhere and almost ran her over. She said he did not apologize, but kept going. Nothing like that had ever happened to her before and it happened feet from the front door of their home. Aisha then remembered what she’d read about the journalist who was knocked off his bicycle as a form of harassment and assault, as mentioned previously in this Complaint. Both Aisha and her mother were attacked in the same day.
984. Further evidence that Madonna has Aisha under surveillance in acts that are criminal violations of the respective Jamaican, British and U.S. constitutions and United Nations laws happened this month. On September 12th, 2005 Aisha flew to London to begin filming for two music videos and other works. She immediately began filming with a professional broadcast quality hand held movie camera. She went around London filming known landmarks, red double decker buses and tube stations. She filmed many Londoners cinema verite style and the smiled for the camera when they saw her. Some of them recognized her from her web site. She went around with her camera hidden in a bag, then filmed different locations spontaneously to capture people’s reactions.
985. The very next day Madonna made an official public announcement through her manager that her new video was to be of London landmarks, red double decker buses, tube stations and hidden cameras where they would capture the surprised reactions of Londoners at Madonna’s presence. In a matter of minutes Madonna ripped off the video Aisha had already filmed (the footage is time and date stamped), making plans of her own to shoot the same exact video Aisha had filmed two days before. Furthermore, Aisha had copyrighted that London video treatment years ago, but only got around to shooting it last week. Further proof Madonna has been committing corporate theft, stalking, harassment and invasion of privacy against Aisha.
986. It also highlights the fact that Madonna was still sickly watching Aisha even in London, via the surveillance campaign she commissioned against the young singer in Miami who has been going about her business and not bothering anyone. Yet the perverted, depraved, obsessed Madonna has been constantly stealing from and harassing her at every turn. The illegal surveillance campaign followed Aisha from Miami to Jamaica to London over a 10 day span in a gross invasion of privacy and foul acts of stalking.
987. Additionally, Aisha noticed a burly man whose arms were covered in tattoos sitting at the bus stop outside her aunt’s home on the outskirts of London when she went to take the bus to the train station to get to central London (her aunt’s car wasn’t working). She paid it no mind until two days later she saw the exact same man again standing roughly a foot behind her at an Oxford Street bus stop where she had been filming. This bus stop was very far from her aunt’s home and she was startled when she turned around and saw the same man again. He stared at her intently for several minutes, which prompted her to cross the street to get away from him.
988. Legal and security experts have described this conduct of approaching and harassing potential litigants as a tool used by unethical people to intimidate and terrorize victims and opponents. It is done to harass and scare victims out of pursing legal action against perpetrators and pressing charges. Private things said in the privacy of Aisha's home and over her phone were repeated to her by strangers who approached her in public, each speaking of Madonna or lawsuits. Further evidence they have been in her home:
989. The Defendants also engaged in a pattern of harassment and intimidation via local attorneys Leslie Zigel and David Bercuson, whom Aisha sought for legal representation in this case on separate occasions, unaware of their affiliation with Warner Bros Records, Madonna’s employer/record label.
990. Miami attorney Leslie Zigel of the law firm Greenberg and Traurig, who did disclose that he was affiliated with Warner Brothers Records, which would pose a conflict of interest, but would check and call Aisha back to let her know if he could take the case.
991. Mr. Zigel then called back shortly after saying he could not take the case due to a conflict of interest and that the Defendants would, “put an injunction on the Plaintiff’s album once it is released.” Mr. Zigel acted as the Defendant’s mouthpiece in a veiled legal threat, due to the then forthcoming lawsuit from Aisha, irrespective of the fact that the Plaintiff authored and copyrighted her work first, years prior to Madonna and her co-defendants stealing and re-copyrighting their infringing versions. He also told Aisha not to "be so cocky” that she’d win in court as, “Warner Bros is a big company with connections.”
992. Miami attorney David Bercuson’s conduct was completely repugnant. When contacted by the Plaintiff seeking legal representation, Defendant David Bercuson deliberately did not disclose his clear affiliation with co-defendant Warner Bros (Madonna’s label), via his clients recording artists IRON MAIDEN and KC and THE SUNSHINE band, who all have products placed on and sold by WARNER BROS companies. In spite of the conflict of interest, David Bercuson strung Aisha along by requesting sensitive legal information about the case, leading her to believe he was going to legally represent her in the action against the Defendants.
993. David Bercuson requested that Aisha send him her official copyright certificate bearing her personal information and official signature, and that it be faxed to his office (for which Aisha has scanned fax receipts). Aisha complied with his requests thinking it was the last step before David Bercuson represented her, as none of the attorneys she’d contacted prior to Mr. Bercuson, who either had a legal conflict of interest or unwillingness to represent her in the case for personal reasons (loss of potential future work from conglomerate Warner Bros and blacklisting), requested such a sensitive document and detailed information if they did not plan on representing her in the legal action.
994. Upon receiving Aisha’s certificate, Defendant Bercuson called her home shortly after and immediately launched into a vile, verbally abusive tirade in an attempt to dissuade her from filing suit. David Bercuson wrongfully told Aisha that her evidence of access via credible newspaper articles, magazine articles and television interviews featuring the Defendant Madonna was “hearsay,” “inadmissible in court” and “do you know how much money Madonna has. She could burry your lawyer…in paperwork.” Due to his hostile, threatening, screaming tone, Aisha wondered about his declaration where he questionably stated, “do you know how much money Madonna has. She could burry your lawyer…in paperwork,” as the last part of the statement was said in a way that it sounded like an abbreviated threat of violence due to the pause after the word “lawyer.”
995. Aisha suspected the information dispensed by Mr. Bercuson regarding the admissibility of her evidence was dubious, therefore, she did some research and found several other cases that allowed the same type of evidence, such as the widely written about Laci Peterson case.
996. However, Aisha was nonetheless offended by the extreme verbal abuse, yelling, threats, misinformation and intimidation from Defendant David Bercuson, whom she viewed as an officer of the court. Aisha filed a complaint with the Florida Bar Association in February of 2005, against Mr. Bercuson for his questionable, unethical conduct.
997. In Mr. Bercuson's first response to the Florida Bar dated March 3, 2005, in regards to Aisha's complaint against him, he lied, libeled and defamed her, conveniently leaving out his terrible conduct. Offended, Aisha sent in additional digitally collected evidence from her web site included in this case as an EHXIBIT (52-53) that exposed several of Mr. Bercuson's lies and defaming statements he made in the untruthful response he submitted to the committee. Being out of step with modern technology, he was unaware that his Internet misconduct regarding Aisha could be legally traced using site records that lead right back to his IP address.
998. The Bar chair, Ms. Vivian Reyes, amazingly found nothing wrong with Mr. Bercuson's inappropriate conduct. She dismissed the fact that there was a clear conflict of interest in that Mr. Bercuson has clients placed on Warner Bros. and should not have been entertaining legal talks of representation and collecting official case documents from Aisha for so long.
999. Ms. Reyes absurdly and astonishingly stated in a letter that it was "an imprint" of Warner Bros, therefore it didn't count. In the business world, being on an imprint of a major label means you are apart of that family. You go to the same meetings, the same events, the same major label sponsored industry parties. You know the same people. All imprints must report to their major label. There is no way around that, as it is a very close business relationship. It is a parent child relationship, that Ms. Reyes astonishingly and questionably dismissed in favor of excusing Mr. Bercuson's unlawful conduct in threatening, harassing, verbally abusing and lying to a young woman who went to him for help with a serious legal problem that was escalating to dangerous levels due to the Defendants misconduct that contained criminal activity.
1000. Mr. Bercuson spammed Aisha’s web site meeting the internet's universal definition of spamming, for which many have lost their ISP, yet Ms. Reyes deemed his conduct appropriate. A lawyer lied to, deceived, threatened, harassed, obtain documents under false pretenses and she amazingly declared it acceptable, even in the face of the credible digital evidence she was given.
1001. The Plaintiff respectfully asks the court to take into consideration the inappropriate, menacing, threatening conduct of the Warner Bros affiliated Mr. Bercuson who abused his position as an officer of the court in the deliberate misapplication of Federal Law, intimidation and the dispensing of unethical, erroneous legal counsel in an attempt to dissuade the Plaintiff from pursuing her rightful legal claim against his employers.
TERRORISTIC BEHAVIOR MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE,
1002. The Defendants threatened Aisha via attorney David Bercuson. They also mounted an illegal surveillance campaign, that was a form of harassment, as Aisha's every move on the internet, telephone and on the streets were being monitored and recorded, then used to commit corporate theft and harassment. As mentioned in the previous charge, people clearly employed by the Defendants approached Aisha several times in public and harassed her. One incident culminating in the assault of the Plaintiff.
DEFAMATION OF CHARACTER DAVID BERCUSON
1003. Warner affiliated Attorney David Bercuson, mentioned in the 44th cause of action defamed Aisha in documents to the Florida Bar when responding to the complaint she lodged. SEE EXHIBITS 52 AND 53.
LIBEL DAVID BERCUSON
1004. Warner Bros affiliated attorney Defendant David Bercuson, mentioned in the previous cause of action, libeled Aisha in documents to the Florida Bar when responding to the complaint she lodged against him for misconduct. SEE EXHIBITS 52 AND 53.
TRADE LIBEL ALL THE DEFENDANTS
1005. The Defendants knowingly committed trade libel, in selling copyright infringing items they willfully and criminally stole from Aisha's copyrights and intentionally misrepresented to millions worldwide as their own works, thus devaluing Aisha's works and projects. They deliberately made false statements to writer's associations like ASCAP and the WGA, that these works were their own when Aisha is the true author and owner, who had already copyrighted these items with the Library OF Congress in Washington, DC.
1006. They used their already established global audience of millions worldwide to establish Aisha's already copyrighted works as their own, with the hopes of deceiving the masses that Madonna and her co-defendants had authored these innovative works, and not the true author Aisha, who had written and copyrighted these works with the Library Of Congress before Madonna and her co-defendants deliberately stole them.
1007. They used their already established global audience to lie to the world that they wrote these works, when it was an indie artist, Aisha, with a smaller audience, who had truly authored and copyrighted these innovative works. They used their larger audience in a deliberate, calculated effort to trump and drown out Aisha's copyrighted projects they ripped off, claiming them as their own to untold millions in the mainstream via massive advertising campaigns, numerous global interviews and marketing drives, that indie artist Aisha, just could not afford.
1008. Each time Aisha released a new project or copyrighted one, Madonna and her co-defendants rushed out copyright infringing versions to global audiences, to kill Aisha's projects before they got anywhere. They further went around the entertainment industry using their influence and connection to have Aisha blacklisted - as mentioned previously in this Complaint. These acts were premeditated, deliberate and willfully with the clear intent to rob, defraud Aisha of her copyrighted works, then destroy her career, to prevent her from using her own copyrighted works, which they had their eyes and designs on, due to how innovative and well written her copyrighted catalog is. A catalog they criminally stole via invasion of privacy in making a hacker procured copy of it then criminally using it.
1009. The Lanham Act states "Any person who...in connection with any goods or serves...uses in commerce any...false or misleading description of fact, which ...in commercial advertising or promotion, misrepresents the nature, characteristics, or qualities...of his or her or another person's goods, services or commercial activities...shall be liable in a civil action by any person who believes that he or she is likely to be damaged by such conduct."
1010. These were Aisha's copyrighted "goods and services" that Madonna and her co-defendants repeatedly infringed the copyrights for, and criminally so, stole trade secrets and intentionally presented these copyrighted items to global audiences as their own works when they never were, robbing Aisha of royalties, authorial credit and devaluing her own works that were released - works that they were taking credit for through their own works released to larger audiences.
1011. The mainstream public was willfully mislead by Madonna and her co-defendants as to the origins and authorship of said works at Aisha's expense - works Aisha previously copyrighted before Madonna and her co-defendants willfully and criminally stole and deliberately "misrepresented" to global audiences as their own. Aisha has been "damaged by such conduct" defrauded out of millions of dollars and writer's credit for her hard work she copyrighted and owns.
WILFUL VIOLATION OF CIVIL LIBERTIES MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE 1012. The Defendants willfully violated Aisha's civil rights. They illegally monitored and recorded her phone calls and internet activities, used prominent local attorneys to deceive, harass and threaten her, thus interfering with her work and life. These actions are criminal and willful violations of her civil liberties.
UNLAWFUL SURVEILLANCE MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE
1013. The Defendants mounted an unlawful surveillance campaign with the goal of corporate theft. Everything Aisha did in her life was being illegally and intrusively tracked by but not limited to wiretapping, computer hacking, IP tracking and stalking commissioned by Madonna and shared with several of her co-defendants. They are a most unwelcome, stalker like presence in Aisha’s life. This misconduct stems from Madonna's obsession she has developed for stealing Aisha's work and perversely and unlawfully spying on her in her professional work and personal life, which is a gross violation of the Constitution (the Fourth Amendment).
1014. You cannot violate the sanctity of someone's home via invasion of privacy. It is unlawful and completely perverted. Under U.S. law no one has the right to tap your phones and hack into your computers, then disgracefully use the stolen copyrighted contents to commit corporate theft and harassment. It is a completely reprehensible crime.
1015. Items she typed into search engines and said over the phone, later appeared in print, verbatim, attributed to the perverse Defendants, namely Madonna, Victoria Newton and The Sun Newspaper UK. Other items appeared on the show CSI:Miami.
1016. There are programs available on the internet such as Spectator Pro, eBlaster, Spy Recon, Keystroke Logger 1.0 that capture keystrokes, record emails, internet messenger chats, passwords, online purchases, then sends the hacker an email containing a detailed activity report, enabling them to commit corporate theft. Many of these programs can be configured to send reports each hour, detailing all the sites the victim visited, what they typed into search engines. Aisha recently found the keystroke logger program in that family called Keysnatcher on her computer, which was recording and transmitting everything she did on her computer and sending it to the Defendants who utilized it for corporate theft.
1017. Aisha would routinely search items on the internet for her Sound Off Column, that the Defendants Madonna, Victoria Newton and the Sun Newspaper shamefully and perversely made a habit of utilizing before the Plaintiff did. They did this on several occasions.
1018. Aisha's web site was hacked with emails read. Emails that she had not read, were opened and read, attested by the bold highlighting being removed. Other important emails Aisha had read previously were mysteriously deleted days after.
1019. The commerce page of her web site was severely tampered with upon launch, to prevent customers from being able to purchase her music. Navigation buttons were changed and removed. Links rerouted and others erased. Pages had been erased as well. It was a coordinated attempt to harass and destroy the Plaintiff's business, to enable them to further steal, exploit and utilize her works, without her gaining the finances and media resources to fight back. No one has the right to invade a private citizen's privacy, intrusively and perversely muscling their way into their life via unlawful wiretaps and hacking.
1020. The Defendants Victoria Newton and The Sun Newspaper further crossed international lines, violating numerous international laws and United Nations treaties in invading the Aisha's privacy in conjunction with head conspirator Madonna. Their unlawful reach extended from Britain into the United States, to spy on and steal from an industrious, innovative writer whose works they coveted and perversely stole.
1021. As their publicly admitted cohort Madonna did, the Sun criminally utilized numerous items from Aisha’s private unpublished multi-million dollar valued copyrighted catalog that was sent to and registered with the Library Of Congress way before the Defendants criminally used them. This was a gross breach of international law and deserves the strongest reprimand.
WILFUL VIOLATION OF INTERNATIONAL LAW ALL THE DEFENDANTS
1022. All the Defendants violated numerous international copyright and trade laws when they willfully stole Aisha’s copyrighted works for financial gain and acclaim.
1023. Madonna and Liz Rosenberg in conjunction with Victoria Newton, Graham Dudman, her employers The Sun Newspaper and their parent company News Group Newspapers further willfully violated international law in three countries in invading the privacy of the Plaintiff, a Jamaican-American citizen living in Florida, by using the contents of her computers they hacked, faxes they illegally intercepted and phone calls they illegally monitored via wiretaps to commit corporate theft of copyrighted materials.
1024. Madonna further sold off copyrighted items from Aisha’s copyrighted catalog that has grossed herself and her co-defendants a few hundred million dollars, in criminal conduct worthy of imprisonment.
1025. In conjunction with Madonna, Victoria Newton and the Sun Newspaper's unlawful reach crossed the Atlantic clear into America, while simultaneously violating UN treaties, international privacy laws, international copyright laws, Jamaican privacy laws, UK copyright laws, UK privacy laws, US copyright laws, US privacy laws and the US Constitution - in criminally exploiting and unlawfully spying on a Jamaican-American citizen, whose father is a Jamaican national and a magistrate.
1026. The Defendants have willfully broken numerous laws in three countries in the malfeasances committed against Aisha. The Sun has continued its disgraceful tradition as the hemorrhoid on the butt of English journalism. Said publication had no qualms about violating the copyrights of the Queen of England, a case the Monarch sued and won, therefore what was to stop them from violating Aisha's copyrights.
1027. Furthermore, in criminally spying on Aisha, the Defendants also criminally spied on her family as well, some of who are minors, violating the United Nations Rights Of A Child Charter.
1028. Aisha was raised most of her life in America and is a lawful citizen of the United States. However, Aisha is of Jamaican birth and British descent. Jamaica is on the British system of government, with Queen Elizabeth II as the head of state. Numerous Jamaican laws were flagrantly and willfully violated in the Defendants criminal quest against the Plaintiff. Many telephone calls between Aisha and her little sister and her father in Jamaica, were unlawfully intercepted, recorded and forwarded to Madonna, who utilized many calls in conjunction with Victoria Newton and The Sun Newspaper, to commit harassment in the public domain and corporate theft.
1029. Violations of The U.S. Constitution: The Fourth Amendment - "right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized."
1030. The Defendants committed several willful violations of RICO statues, as outlined in the RICO Order attached to this Complaint.
1031. Violations of the Jamaican Constitution: Chapter III Fundamental Rights and Freedoms Section 13 a. Life, liberty, security of the person, the enjoyment of property and the protection of the law; c. Respect for his private and family life, the subsequent provisions of this Chapter shall have effect for the purpose of affording protection to the aforesaid rights and freedoms, subject to such limitations of that protection as are contained in those provisions being limitations designed to ensure that the enjoyment of the said rights and freedoms by any individual does not prejudice the rights and freedoms of others or the public interest.
Section 18 1032. No property of any description shall be compulsorily taken possession of and no interest in or right over property of any description shall be compulsorily acquired except by or under the provisions of a law.
1033. Domestic and International Copyright Laws Violated Are: Multiple violations of The Berne Treaties of 1967, which the U.S. joined in 1989. Multiple violations of The Universal Copyright Act of 1952. Multiple violations of The Lanham Act Multiple violations of The Copyright Act Multiple violations of The Digital Millennium Copyright Act
WILFUL VIOLATION OF UNITED NATIONS TREATIES ALL THE DEFENDANTS
1034. The Defendants willfully violated United Nations treaties in invading the privacy of Aisha, a Jamaican-American citizen living in Florida, by using the contents of her computers they hacked, faxes they illegally intercepted phone calls they illegally monitored via wiretaps, to commit corporate theft of copyrighted materials.
1035. They further stalked her in her in Miami, where she resides, and followed her across 3 countries this month during a business trip, for which they committed corporate theft of the copyrighted works she filmed in London, England. She was assaulted in Miami this summer by people clearly affiliated with Madonna and the illegal surveillance campaign she commissioned and utilized items from, against Aisha.
1036. This illegal surveillance campaign commissioned by Madonna also violated the rights and privacy of two of Aisha’s younger relatives who are minors. The following violations of United Nations Treaties by the Defendants are:
a.) The Universal Declaration Of Human Rights (UDHR 1948) www.un.org/overview/rights.html:
Article 3 - Everyone has the right to life, liberty and security of person.
Article 5 - No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment.
Article 7 - All are equal before the law and are entitled without any discrimination to equal protection of the law. All are entitled to equal protection against any discrimination in violation of this Declaration and against any incitement to such discrimination.
Article 12 - No One shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honor and reputation. Everyone has the right to the protection of the law against such interference of attacks.
b.) The United Nations Guidelines/Computerized Personal Data Files c.) The United Nations Convention on the rights of the Child www.unhchr.ch/html/menu3/b/k2crc.htm
Article 16 - 1: No child shall be subjected to arbitrary or unlawful interference with his or her privacy, family home or correspondence, nor to unlawful attacks on his or her honour and reputation.
1037. Both sister and godbrother are minors and telephone conversations to Aisha were illegally monitored and recorded. They told her of their future plans, hopes and dreams and the Defendants perversely listened into all calls of the Plaintiff both business and personal that included said calls. Both stayed at Aisha’s home on vacation, which unbeknownst to Aisha and her family, was under a criminally commissioned 24-hour surveillance campaign.
1038. Article 18 - Everyone has the right to freedom of thought, conscience and religion; this right included freedom to change his religion or belief, and freedom, either alone or in community with others and in public or private, to manifest his religion or belief in teaching, practice worship and observance.
(The religious, Christian part of Aisha’s web site was hacked and erased by Kabbalahist Madonna’s commissioned hacker. SEE EXHIBIT 3. Said hacker used the same method of hacking to erase the religious Christian parts of her site that he used to criminally copy Aisha’s multi-million dollar valued copyrighted catalog from her computer’s hard drives).
Article 19 - Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ides through any media and regardless of frontiers.
Article 23 -
1.) Everyone has the right to work, to free choice of employment, to just and favorable conditions of work and to protection against unemployment 2.) everyone, without any discrimination, has the right to equal pay for equal work. 3.) Everyone who works has the right to just and favorable remuneration ensuring for himself and his family and existence worthy of human dignity, and supplemented, if necessary, by other means of social protection...
The Defendants made a regularly habit of stealing the Plaintiff's copyrighted works depriving her of the monetary rewards of her labor. They behaved as though the Plaintiff was a slave whose labor and property was theirs to take and exploit, providing absolutely no remuneration. The Defendants stole her work, as though her labor was free. They went around telling industry reps not to interview her.
Article 27 1. - 2. Everyone has the right to the protection of the moral and material interests resulting from any scientific, literary or artistic production of which he is the author.
WILLFUL VIOLATION OF HUMAN RIGHTS MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE
1039. The Defendants have violated numerous U.S. and U.N. human rights laws in their criminally commissioned surveillance campaign against Aisha that has also affected her family, two of whom are minors who were spied on as well during times they spoke to Aisha and visited her family home. They have violated the following international treaties against a Jamaican-American citizen with no history of misconduct:
1040. The European Convention on Human Rights: Article 8 - Right to respect for private and family life: a.) Everyone has the right to respect for his private and family life, his home and his correspondence. There shall be no interference by a public authority with the exercise of this right except as is in accordance with the law and is necessary in a democratic society in the interest of national security, public safety or the economic well being of the country, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedoms of others.
1041. The Charter of Fundamental Rights of the European Union: Article 7 - Respect for private and family life - Everyone has the right to respect for his or her private and family life, home and communications: c.) Article 8 - Protection of personal data 1.) Everyone has the right to the protection of personal data concerning him or her 2.) Such data must be processed fairly for specified purposes and on the basis of the content of the person concerned or some other legitimate basis laid down by law. Everyone has the right of access to data, which has been collected concerning him or her, and the right to have it rectified. d.) The inter-American declaration of the Rights and Duties of Man (Art V) e.) The Inter-American Convention on Human Rights (Art 11)
TORTIOUS INTERFERANCE ALL THE DEFENDANTS
1042. Aisha authored very innovative, cutting edge work that set several music industry precedents. The project was sure to launch Aisha’s career once the full marketing and promotional plans were executed. However, the project was derailed for a period of time and had to be drastically altered due to Madonna and her co-defendants persistent, willful acts of criminal copyright infringement, plagiarism and unlawful threats of an injunction on Aisha’s work upon release, via Miami attorney Leslie Zigel. Further threats were issued through Warner Bros affiliated attorney David Bercuson in what could only be described as vile.
1043. Madonna further went around the entertainment industry getting Aisha blacklisted and dropped from an endorsement deal, in attempts to kill the younger singers career.
1044. Defendants Madonna, Victoria Newton, Graham Dudman, The Sun Newspaper, News Groups Newspapers deliberately interfered with and criminally used items from Aisha’s multi-million dollar copyrighted catalog that they have been making criminal use of, which they procured via corporate theft.
1045. The goal and objective of the Defendants disgraceful campaign has been to use as much of Aisha’s copyrighted catalog as possible, which has reaped them millions in a criminal enterprise worthy of imprisonment.
1046. The entire episode has changed the way she does business at a great inconvenience to her, due to the Defendants constant stealing of her copyrighted works. She has had to take extra precautions, which are a great financial, physical and emotional inconvenience to her. Thus affecting her work
1047. They have unreasonably and intentionally interfered with Aisha’s business many times to disrupt it and capitalize on her copyrighted works they criminally procured. Aisha would author and copyright inventive, innovative works and no sooner would the Defendants release unauthorized, rip off versions in the mainstream via massive ad campaigns to overtake and overwhelm Aisha’s original indie versions before she had the chance to promote them and establish them as the works of her domain. This is making it very difficult to conduct business under these circumstances.
UNJUST ENRICHMENT ALL THE DEFENDANTS
1048. The Defendants have engaged in a willful pattern of criminal copyright infringement and plagiarism, in the wholesale theft of Aisha's work that has grossed many millions of dollars for them to the tune of almost $500,000,000 in ill-gotten wealth. Aisha at no time authorized any party to use any of her copyrighted works, as it was solely meant for her independent label Sonustar.
1049. In 2001, via a web site interview, Aisha did state that she wanted to keep her work on her label, refusing to write for other companies. The Defendants realizing this circumvented her wishes by criminally stealing her copyrighted intellectual property for their own financial gain.
1050. The Defendants have made many millions via this criminal activity that are, but not limited to, record sales, online digital sales, music publishing (ASCAP and Warner Music Publishing), sheet music sales (“American Life”), book publishing deals (Calloway Arts and Entertainment), extensive touring using the copyright infringing song “American Life,” as a lead off single, touring using a set that stole Aisha's work that was apart of an unreleased video treatment, Madonna was paid $10,000,000 for a Versace advertising campaign that got Versace’s books out of the red, The Sun Newspaper UK saved money on stories by criminally stealing Aisha’s, Disney gained Box Office receipts of close to $130,000,000, millions in DVD sales, merchandising rights and millions in advanced fees, financing and remuneration for copyright infringing works.
RACKETEEERING ALL THE DEFENDNTS
1051. The Defendants’ conduct is in willful violation of United States RICO laws, as mentioned in the RICO Order attached to this Complaint and in the Conspiracy to Violate RICO Laws portion of this lawsuit listed further in this Complaint. Madonna in conjunction with her co-defendants conspired to and executed plans to criminally steal copyrighted intellectual property and private files belonging to Aisha for their own use over several projects that have grossed millions of dollars for them. The malfeasances were orchestrated among the Defendants and completely dismissive of U.S. RICO statutes.
1052. These willful, ongoing, criminal, premeditated acts of wholesale intellectual property theft, fraud, conversion, collusion, plagiarism, willful criminal copyright infringement and the stealing of private copyrighted files by Madonna in collusion with her co-defendants constitutes flagrant, willful violations of the RICO Act. They conspired to defraud Aisha and violate her numerous works by stealing millions of dollars in copyrighted work, which in turn made millions for them, while simultaneously devaluing Aisha’s work.
1053. Defendant Warner Bros are currently being sued for copyright infringement and racketeering in the lawsuit Sophia Stewart vs. Warner Bros. An official FBI investigation has already revealed that Warner Bros and their employees were in unlawful possession of Sophia Stewart’s already copyrighted work, which was present on the set of the copyright infringing films The Matrix.
1054. The subsequent FBI investigation also revealed that Warner Bros willfully used Sophia Stewart’s already copyrighted work without authorization and attempted to hide the theft, to no avail, by editing out 30 minutes of footage from the Matrix film to avoid copyright infringement charges. This goes to show a pattern of misconduct - a common business practice at Defendants Warner Bros, Disney, Jerry Bruckheimer Films and The Sun Newspaper UK.
CONSPIRACY TO COMMIT FRAUD ALL THE DEFENDNTS
1055. The Defendants conspired to and did commit fraud in the wholesale criminal theft of Aisha's copyrighted works that they willfully and fraudulently passed of as their own numerous times to untold millions, collecting huge sums of money for work they had absolutely no right to. At no time did Aisha grant anyone permission to use her copyrighted works.
CONSPIRACY TO DEFRAUD ALL THE DEFENDNTS
1056. The Defendants conspired to defraud Aisha out of revenue for her work, by stealing it and releasing it to mainstream markets first, which rendered several of Aisha’s projects useless in the marketplace, as they had already criminally been utilized and exploited by the Defendants.
1057. A substantial part of sellability in the entertainment industry is being the first to unveil a new concept, a new premise, a new style, a new film and a new sound. The Defendants craftily and surreptitiously violated then exploited Aisha's copyrighted works she authored and registered with the Library Of Congress years prior to their criminal re-copyrighted registrations, then used their vast financial and media resources to mass produced and heavily market the infringing works around the world, in an illegal attempt at establishing authorship of work that was not their intellectually property.
1058. In doing so they willfully defrauded Aisha out of millions of dollars worth of copyrighted works that was then rendered useless to her.
CONSPIRACY TO COMMIT WIRE FRAUD MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE,
1059. The Defendants willfully employed illegal listening devices to monitor Aisha's personal and business telephone conversations and used the contents of the calls they eavesdropped on to commit corporate theft, as mentioned previously in this Complaint under the segment titled WIRE FRAUD.
CONSPIRACY TO COMMIT MAIL FRAUD MADONNA, WARNER BROS, DISNEY, BUENA VISTA PICTURES, MAVERICK RECORDS, MAVERICK FILMS, MUSIC TODAY
1060. The Defendants willfully and knowingly conspired to and sold items over the Internet, distributing them to customers by U.S. mail, knowing that many of these items willfully infringed many of Aisha's copyrights. They fraudulently passed these items off as their own and sold them at a great profit, shipping them by U.S. mail to many customers around the world, as mentioned previously in this Complaint under the segment titled MAIL FRAUD.
CONSPIRACY TO VIOLATE COPYRIGHT LAWS ALL THE DEFENDNTS
1061. The Defendants conspired to flagrantly break U.S. and United Nations copyright laws and treaties in their unlawful, intentionally stealing of Aisha’s copyrighted intellectual property, as mentioned previously in this Complaint in paragraphs 493-836.
CONSPIRACY TO VIOLATE PRIVACY LAWS MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE
1062. The Defendants conspired to blatantly break Jamaica, U.S., British and United Nations privacy laws by intentionally hacking Aisha’s computers and tapping her telephone to obtain additional information and material they could use for their own financial gain via corporate theft. In doing so they invaded her privacy and that of her family in a most disgraceful way.
1063. Privacy and dignity are among the most basic and treasured rights the Constitution provides - that an individual has the right to conduct their lives in a dignified manner without anyone listening in to their telephone conversations, prying into their computers, web sites and home. The Defendants calculatedly and callously violated Aisha’s right to privacy in what can only be defined as emotionally raping a person’s life.
1064. Not content with her publicly released work they stole, they greedily conspired to obtain her unreleased copyrighted works, which they criminally did and criminally used. They sought to criminally capitalize on Aisha’s multi-million dollar valued copyrighted catalog with limited liability as to where they got it from. Obtaining copyrighted material via corporate theft by hacking Aisha’s computers and invading her privacy would put a great burden of proof on her to prove access as these works, unlike her previous work that they stole from her public web site in view of many, are only stored in the Library of Congress and on her personal computers.
1065. This would give them greater room to deny they stole anything, as it was obtained through criminal surreptitious acts of invasion of privacy, unbeknownst to the public - and unbeknownst to Aisha for a time until she realized what Madonna and her co-defendants had been doing and the computer diagnostic tests that digitally prove the criminal hackings and acts of grand larceny at the Defendants’ hands.
1066. This was a vile, abhorrent abuse and violation of privacy laws and Aisha’s rights. It was morally unconscionable with absolutely no justification under the law. This charge applies as mentioned previously in this Complaint under the segment titled INVASION OF PRIVACY.
CONSPIRACY TO VIOLATE FOURTH AMENDMENT AND CIVIL RIGHTS MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE
1067. The Defendants conspired to violate the Fourth Amendment and Aisha's civil rights via unlawful wiretaps and hacking, subjecting her and her family's every telephone conversation to prying ears and reprints in the Sun Newspaper attributed to Madonna and Victoria Newton and on CSI:Miami.
1068. This intrusion was unconscionable and inexcusable. A person's home is their sanctuary and the Defendants deliberately violated that sanctuary for financial gain in committing corporate theft and harassment. The Defendants behaved as though Aisha had no rights.
1069. The Defendants, further perversely listened into private family telephone conversations about sick relatives, calls that even discussed medical records, which they should not have been privy to. A person's medical records are confidential in most countries with doctors being bound by confidentiality rules, therefore how much more inappropriate was it for the Defendants to be listening in to such calls, while waiting for telephone communications regarding Aisha's business and copyrighted works.
1070. They also violated the rights of children in listening to Aisha’s telephone calls with younger relatives who she would encourage and support in their school work. The Defendants’ conduct is absolutely criminal, contemptible and deserving of reprimanding of the highest order.
1071. This charge applies as mentioned previously in this Complaint under the segment titled INVASION OF PRIVACY.
CONSPIRACY TO VIOLATE RICO LAWS ALL THE DEFENDANTS
1072. The mere fact that so many of Aisha’s copyrights were flagrantly infringed by the Defendants, with Madonna spearheading these numerous infringing projects that grossed millions of dollars for her and her co-defendants, shows clear intent, malice, fraud, conspiracy and a disgraceful disregard of RICO Laws.
1073. The conspiratorial manner in which the theft of Aisha’s released copyrighted works and unreleased multi-million dollar valued copyrighted catalog was criminally copied and used via hacking, shows a clear plan that took pre-planning, organization, presence of mind and deliberate intent to commit criminal acts for financial gain constitutes clear and flagrant violations of RICO laws. The violations are as follows:
a. The Defendants conspired to flagrantly violate section A, the robbery segment of U.S. RICO laws, US Code Title 18, in their unlawful, intentional stealing of Aisha’s copyrighted intellectual property, “which is chargeable under state law and punishable by imprisonment for more than a year” in addition to civil penalties.
b. The Defendants conspired to flagrantly violate portion B, section 1029 of U.S. RICO laws, US Code Title 18, in their unlawful, intentional stealing of Aisha’s copyrighted intellectual property via her computers, tampering with and destroying data on her computers and tampering with and destroying pages of her web site that deal with commerce and financial transactions, which is in regards to the “fraud and related activities in connection with access to connection devices.” The Defendants unlawfully accessed Aisha’s computers and copied copyrighted intellectual property files, which they later utilized and interfered with commerce on a web site page that contained financial data c0onnected to credit card transaction access and authorization devices. These felonious crimes are, “chargeable under state law and punishable by imprisonment for more than a year” in addition to civil penalties.
c. The Defendants conspired to flagrantly violate portion A, section 1341 of U.S. RICO laws, US Code Title 18, in their unlawful, intentional stealing of Aisha’s copyrighted intellectual property, which they then mass produced and sold via mail to countries all over the world. Section 1341 of the RICO laws relates to mail fraud, “which is chargeable under state law and punishable by imprisonment for more than a year” in addition to civil penalties.
d. The Defendants conspired to flagrantly violate portion A, section 1343 of U.S. RICO laws, US Code Title 18, in their unlawful, intentional wiretapping of Aisha’s phone to illegally obtain trade secrets and ideas, which Madonna later utilized for her own enrichment in conjunction with several of her co-defendants. In doing so the Defendants committed wire fraud and copyright infringement when they published these ideas and trade secrets, obtained via illegal wiretaps, in the Sun Newspaper in London and on CSI:Miami. The Sun Newspaper is also distributed in the United States through several bookstore chains. Section 1343 of the RICO laws pertains to wire fraud, “which is chargeable under state law and punishable by imprisonment for more than a year” in addition to civil penalties.
e. The Defendants conspired to flagrantly violate portion A, section 1951 of U.S. RICO laws, US Code Title 18, in their unlawful, intentional stealing of Aisha’s copyrighted intellectual property, “which is chargeable under state law and punishable by imprisonment for more than a year” in addition to civil penalties. The use of section 1952 is utilized in this lawsuit as it relates to “interference with commerce.” The Defendants stole numerous amounts of copyrighted works from Aisha and criminally interfered with the store page of her web site that conducts credit card transactions. These crimes greatly interfered with her ability to market and sell copyrighted works that rightfully belong to her and not the Defendants. Aisha’s telephone, internet and computer activities and works were being monitored and illegally utilized by the Defendants. This misconduct is "chargeable under state law and punishable by imprisonment for more than a year” in addition to civil penalties.
f. The Defendants conspired to flagrantly violate portion A, section 1952 of U.S. RICO laws, US Code Title 18, in their unlawful, intentional stealing of Aisha’s copyrighted intellectual property, “which is chargeable under state law and punishable by imprisonment for more than a year” in addition to civil penalties. Section 1952 relates to “racketeering.”
1074. These 6 violations of US Rico laws show a clear, statute defined criminal “pattern of racketeering activity” by several of the Defendants, namely Madonna, who commissioned and spearheaded the criminal activity in collusion with her several of her co-defendants.
1075. The Defendants showed great malicious intent and conspiratorial behavior in criminally violation RICO laws, where they committed acts included but not limited to hacking, wiretapping, invasion of privacy, stalking, harassment, conversion, collusion, corporate theft and fraud, which has greatly defrauded and caused Aisha irreparable harm.
1076. This charge applies as mentioned previously in this Complaint under the segment titled RACKETEERING.
CONSPIRACY TO COMMIT THEFT ALL THE DEFENDANTS
1077. Not being content with the work they stole in clear view of the public from Aisha's copyrighted web site, the Defendants took the thefts much further to the disgraceful level of hacking, criminal copyright infringement, invasion of privacy, corporate theft, conversion, harassment, stalking and fraud.
1078. The Defendants conspired to and executed plans to steal Aisha's copyrighted catalog from her computers and utilized them shortly after for numerous criminally infringing projects with copyright dates all later in date than Aisha’s.
CONSPIRACY TO VIOLATE UNITED NATIONS TREATIES ALL THE DEFENDANTS
1079. As outlined in the Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties and Willful Violation of Human Rights listed above, the Defendants conspired to violate United Nations treaties to spy on a Jamaican-American citizen living in Miami and surreptitiously and criminally steal her copyrighted catalogue worth millions, in what were gross acts of criminal copyright infringement, invasion of privacy, corporate theft, conversion, harassment, stalking and fraud. The Defendants invasion of privacy campaign criminally violated Aisha’s copyrights and human rights as set forth by the United Nations.
CONSPIRACY TO VIOLATE HUMAN RIGHTS MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE
1080. As outlined in the Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties and Willful Violation of Human Rights listed above, the Defendants conspired to violate United Nations laws in a commissioned criminal surveillance campaign that grossly invaded Aisha had her family’s privacy.
CONSPIRACY TO COMMIT HARRASSMENT AND TERRORIZATION MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE
1081. The Defendants conspired to and executed a vile plan to harass and terrorize Aisha for daring to publicly speak up about her works being stolen by them. They sought to punish and silence her for telling the world that Madonna and her co-defendants were stealing her copyrighted works and exploiting her. They turned to harassment and assault in attempts to silence her and stop her from reporting them to the authorities, which would bring criminal charges they feared.
CONSPIRACY TO VIOLATE TRADE PRACTICE LAWS ALL THE DEFENDANTS
1082. The Defendants conspired to willfully violate Trade Practice Laws by deliberately and criminally stealing then fraudulently passing off Aisha's copyrighted works as their own for financial gain, to Aisha’s detriment. Their misconduct was planned, organized, commissioned and executed swiftly to gain ill-gotten wealth.
CONSPIRACY TO VIOLATE COMPUER LAWS MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE
1083. The Defendants conspired to violate computer laws in a greedy campaign of intellectual property and corporate theft. When Aisha announced on her widely read web site that she'd authored thousands of songs, hundreds of beats and numerous scripts and music videos, consumed with greed, Madonna hatched a vile plan to steal Aisha's unreleased copyrighted catalog that was obviously housed on her computers due to their nature.
1084. Madonna hired a computer specialist who hacked Aisha's computers on numerous occasions. Said hacker criminally hacked then copied hundreds of files from her computers that are her life’s work/copyrighted catalog. They made a regular habit of quietly hacking Aisha's computers whilst she was online surfing the net, doing research for her projects and Sound Off Column.
COLLUSION ALL THE DEFENDANTS
1085. The Defendants secretly and surreptitiously agreed to violate several Jamaican, U.S., British and United Nations Laws in criminally stealing, utilizing then mass producing substantial amounts of Aisha’s copyrighted works for their own financial enrichment. This racketeering based, agreement and collusion, evidenced by their willful conduct in breaking the law and the results of Aisha’s copyrighted works appearing in various infringing projects against her will, is criminal.
1086. The Defendants also secretly and surreptitiously agreed to violate several Jamaican, U.S., British and United Nations Laws in invading Aisha’s privacy via wiretapping and hacking to obtain more of her works that were copyrighted with the Library Of Congress, but unreleased. They then utilized, remanufactured it, mass-producing substantial amounts of Aisha’s copyrighted works for their own financial enrichment.
1087. Madonna’s co-defendants being fully aware of this problem, continued to let her steal, allowing her free reign in infringing copyrights, looking the other way and collecting the profits from the misconduct. Madonna’s co-defendants had the power to stop her criminal, fraudulent, thieving, corrupt conduct, but willfully and negligently let a 20 year habit of plagiarism and copyright infringement continue, as evidenced by the allegations and lawsuits against her and subsequent settlements in this regard, for which some of the Defendants have also been named as co-conspirator and co-defendant on numerous occasions.
1088. An artist doesn't get accused of and sued for plagiarism and copyright infringement several times and you not realize there is a serious problem and a total disregard for the law. The simple fact is they profited greatly from her thieving conduct and the settlements made on the thefts are menial in comparison to the profits they gained.
CONVERSION ALL THE DEFENDANTS
1089. The Defendants unlawfully used numerous copyrighted works authored and owned by Aisha, thereby illegally transferring and criminally assigning rights of the same to themselves as though they were the authors, when and owners of these valuable works, when they are not and never were.
1090. The facts show Aisha authored and copyrighted all of these works first and the Defendants re-registered her works, via rip offs that bear exact duplications, copying and willful alterations.
1091. The Defendants have caused Aisha irreparable damage and loss in that they illegally utilized and misappropriated her released and unreleased copyrighted works, for which she established clear ownership of years prior to the Defendants rip offs being issued in the marketplace.
1092. What is even more troubling is that it is an ongoing problem, as they continue to arrogantly and unlawfully make multi-million dollar deals with Aisha's copyrighted works - with projects popping up all over Hollywood that infringe her copyrights. This is a criminal act worthy of imprisonment, as the works were illegally procured.
1093. The Defendants deprived her of ownership rights by illegally assigning themselves as the author and publisher of works that do not and never did belong to them. This unlawful conversion of valuable intellectual property against the owner's will and without their knowledge and consent is a horrible abuse of the law.
1094. The mere fact that these infringing works by the Defendants, which clearly rip off Aisha's copyrighted works, bearing exact duplication, copying and willful alterations, keep popping up in the entertainment industry, says the Defendants conduct is ongoing, completely willful and shows presence of mind in the these abhorrent, criminal violations of the law, spurred by financial gain.
PROPERTY THEFT ALL THE DEFENDANTS
1095. The Defendants committed grand larceny when they unlawfully hacked and criminally copied Aisha’s copyrighted catalog, then put into production. These were unreleased copyrighted works wholly authored and owned by Aisha that are housed on her computers and in the Library of Congress in Washington, DC. These unlawfully copied and utilized files contain copyrights valued in the high millions. This constitutes acts of grand larceny via property theft, invasion of privacy and conversion.
1096. These copyrighted unreleased works have been present on Aisha’s computers and in the Library Of Congress far before the Defendants created rip off versions of these projects that bear exact duplication, copying and willful alterations.
NEGLIGENCE ALL THE DEFENDANTS
1097. Madonna has been a copyright infringer for years. Her co-defendants knew this and were negligent in throwing in their lot with her, in signing up, marketing, promoting and taking credit for projects they knew neither she nor they authored. They simply did not care. They only cared about the millions they would net as a result of her criminal conduct. This makes them accomplices to criminal conduct.
1098. In conjunction with her co-defendants, she willfully stole Aisha's copyrighted works and criminally so, distributing them over several projects, which generated millions. When Aisha publicly complained on her web site, incredulous articles began surfacing immediately, trying to cover up the thefts in attributing them to people and scenarios that took place after the criminal fact of grand larceny, invasion of privacy, fraud, embezzlement and criminal copyright infringement for financial gain and acclaim.
1099. They knew of Madonna’s questionable, shameful past regarding plagiarism and copyright infringement, which is supported by several lawsuits against her and Warner for said infractions of the law, yet negligently allowed Madonna free reign in continuing a 20 year habit of intellectual property theft at Aisha and other artists' expense. They simply did not care as long as they made money off the projects, which they did in the millions.
1100. They facilitate her unlawful conduct time and time again and negligently allow her to continue stealing copyrighted intellectual property even as this Complaint is being written, as they too reap the financial rewards of her numerous criminal acts of copyright infringement and plagiarism. They knew of her history of plagiarism and copyright infringement, yet did nothing to stop it, all the while financially and supportively assisting her in violating United Nations, Jamaican, U.S. and British civil and criminal laws.
1101. They knew of Madonna's publicized, sullied past regarding intellectual property theft, assault, fraud and misconduct, as numerous lawsuits and publicized press stories wrote of her many misdeeds in this regard, but still allowed it to continue, giving her the needed financial seed money and media resources to commit these crimes.
NEGLIGENT MISREPRESENTATION ALL THE DEFENDANTS
1102. The Defendants negligently misrepresented Aisha’s copyrighted work as their own, on numerous occasions, for financial gain and career advancement. They criminally conducted business in a questionable manner, behaving as though they were Aisha’s publisher (when they never were), unlawfully misappropriating her copyrights and the associated rights thereof over several projects that generated millions of dollars in profit for them, when they had no entitlement to it at any point.
1103. Multi-million dollar deals were transacted by the Defendants, fraudulently using Aisha’s intellectual property that they had absolutely no right to under the law or in any other forum. They did not exercise reasonable diligence in ensuring the work was properly credited, falsely attributing it all to themselves.
1104. They willfully and criminally mislead many organizations, publications, critics and fans alike that the copyrighted works were authored by the Defendants, when it was plagiaristic and infringing works that criminally came from Aisha’s released copyrighted works and her unreleased multi-million valued catalog. Negligent misrepresentation is largely based on the “intent to deceive.” The Defendants acted with clear, unquestionable, undeniable intent to deceive.
RECKLESS MISREPRESENTATION ALL THE DEFENDANTS
1105. The Defendants recklessly misrepresented facts, crediting themselves as the sole authors of Aisha’s copyrighted works that reaped millions of dollars in ill-gotten profit for them. They dispensed and propagated these false authorial accreditations to the public and to the entertainment industry, irrespective of its true origin, Aisha’s copyrighted works. They negligently misrepresenting it to millions of people as the Defendants works, which infringed Aisha’s copyrights.
MISREPRESENTATION BY OMISSION ALL THE DEFENDANTS
1106. The Defendants concealed material facts as to the true authorship of Aisha’s copyrighted works, fraudulently accrediting it to themselves to millions of people, thus defrauding Aisha out of her intellectual property rights.
1107. They relied on the public and entertainment industry organizations relying on these false attributions of authorship in making million dollar deals and receiving awards and accolades for work they did not author, but criminally stole. They were legally and ethically responsible to disclose the true authorship and origins of the work to several industry organizations that have wrongfully and libelously given them credit and millions in royalties for these copyright infringing works.
FALSEHOOD ALL THE DEFENDANTS
1108. The Defendants publicly set forth many lies to explain the source of the unique, unusual material used to prepare the infringing works, offering many contradictory sources and scenarios that were in complete diametric opposition to established facts and public record. These lies were offered when critics and fans questioned the sudden, extreme changes in music, film and other works deriving from Aisha’s copyrights, Right to Publicity and Right to Privacy, that was out of place on the Defendants, namely Madonna (Scores of critics and audiences went on record with these queries) and Nick Cannon (September MTV interview mentioned above).
1109. Aisha’s copyrighted works and innovations were falsely and fraudulently attributed to Madonna and her co-defendants in print, film and video to millions of people worldwide. These falsities further propagated the lie that they authored the works, at a great detriment and loss to Aisha.
TRADE SECRET THEFT MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE
1110. Aisha's private, unreleased copyrighted works and files on her computers were accessed, copied and utilized by the Defendants numerous times. Some of these files bore trade secrets unique to Aisha’s original copyrighted works. The Defendants also utilized private trade secrets of the Plaintiff that were discussed over the telephone that was criminally wiretapped.
MISAPPROPRIATION OF TRADE SECRETS MADONNA, WARNER BROS, TIME WARNER, AOL, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, MICHAEL EISNER, DISNEY, MAD GUY ENTERTAINMENT INC, STUART PRINCE, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, EUROPACORP, CHRISTOPHER CICCONE, VICTORIA NEWTWON, THE SUN NEWSPAPER, GRAHAM DUDMAN, NIKI WATERMAN, MAVERICK RECORDS, MAVERICK FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON, MARC DUBE, STUART PRINCE
1111. Aisha's private, unreleased multi-million dollar valued copyrighted catalog and its accompanying instructional files were criminally copied by a hacker hired by Madonna, then criminally put into production, marketed and promoted as the Defendants in criminal acts of grand theft larceny, criminal copyright infringement, fraud and invasion of privacy. Some of Aisha’s illegally accessed accompanying bore trade secrets that were not to be viewed by the general public. However, the Defendants criminally accessed and used said trade secrets for various projects.
INTENT TO CAUSE HARM AND LOSS ALL THE DEFENDANTS
1112. The malfeasances, torts and felonious crimes committed by the Defendants against Aisha were done so with clear intent on the Defendants part to cause irreparable harm and loss, thereby falsely establishing Aisha’s copyrighted works as their own.
1113. The aim was to set up and establish themselves as the author of Aisha’s copyrighted works to untold millions of people in the mainstream, which robbed Aisha of her intellectual property and rights thereof that was established with the Library Of Congress years prior. They utilized their vast media and advertising resources to accomplish this goal, in an attempt to maliciously destroy Aisha’s rights to her own vast copyrighted works and any income she could derive from it. They in turn falsely passed it off as their own to millions of people, which generated millions in revenue for them.
1114. They had the clear presence of mind to unlawfully steal Aisha’s released works and criminally steal Aisha’s copyrighted unreleased life’s work in the form of a very valuable catalog, through illegal means, then etch their names in the writer’s space on numerous industry authoring and financial royalty sheets, as the owners of the illegally duplicated, already copyrighted works owned by Aisha.
1115. This was done with the worst of intent and clear malice, as they knew they would be greatly defrauding an independent, law-abiding writer out of millions of dollars for works she spent 2/3 of her life authoring.
1116. The fact remains Madonna and her co-defendants had absolutely no right to Aisha’s copyrighted works, but deliberately stole and utilized them anyway, criminally reaping millions in profits. Their actions are unconscionable and abhorrent by any standards.
LOSS OF WORK TIME ALL THE DEFENDANTS
1117. The Defendants stole numerous amounts of copyrighted works from Aisha's public web site in view of many and from her computers, in the form of her copyrighted catalog valued at millions that they have been criminally using. This entire episode has greatly interfered with her ability to complete and market copyrighted works that rightfully belong to her and not the Defendants.
1118. Aisha also lost work time in attending to, researching, investigating and putting together this lawsuit and accompanying evidence to file this action, which has been very time consuming, as she did the work of a law firm, investigator and research company.
1119. However, Madonna's conduct in conjunction with her co-defendants has become so unlawful, criminal, vile and obsessive that Aisha had no other choice but to litigate this case herself when she could not find adequate legal representation to take on the conglomerate Warner Bros and their criminally indulged star.
DECEIT ALL THE DEFENDANTS
1120. The Defendants conduct was solely based on deceit and greed, which clearly motivated their unlawful actions. They willfully deceived the public numerous times that Aisha’s works were their own, when they never belonged to them. They willfully deceived entertainment industry organizations and audiences alike that they were the authors of numerous works, all stolen from many of Aisha’s copyrights contained in the Library of Congress, then criminally collected millions in signing fees, advances and royalties that they were never entitled to under the law or in any circumstances.
CRIMINAL DECEIT ALL THE DEFENDANTS
1121. On numerous occasions the Defendants set out to deceive the public into thinking Aisha's copyrighted works were their own and criminally so, as many of these works were criminally procured.
1122. They were and are in fact dealing in stolen goods that they publicly took full authorial credit for - even on forms and contracts that bear criminal penalties for lying, fraud and misrepresentation. These acts were nothing short of embezzlement.
1123. Many contradictory lies were set forth to explain the thefts, none of which were plausible or historically sequential. The work was so unfitting, that critics and fans wondered out loud where this new music, imagery and style was coming from.
CRIMINAL INTERFERENCE ALL THE DEFENDANTS
1124. The act of the Defendants continually stealing Aisha’s copyrighted works from her widely viewed web site then progressing to criminally stealing her copyrighted catalog, constitute criminal acts of interference that greatly effected, disrupted and harmed her business.
1125. These acts grossed the Defendants millions of dollars via quickly released rip off versions of Aisha’s already copyrighted intellectual property, which was surreptitiously marketed and distributed to mainstream audiences of millions.
1126. Aisha’s audience is internet based and sizable, but not mainstream, which is a great number of people worldwide in various formats such as print, TV, radio, internet and concerts. The Defendants continually stole works with copyright dates way prior to their later obtained registrations, and quickly established the rip offs as their own in the mainstream to a greater number of people than Aisha's Internet based audience who all recognized that she authored and released these works before the Defendants stole them. It was Aisha's audience that first alerted her to the infringements that were taking place at Madonna's hands, surfacing in her later works that all bear copyright dates after Aisha's.
1127. The Defendants have done their level best to kill Aisha’s career, having her blacklisted, creating advantageous disturbances and disruptions in her career, in order to clear the way for them to further criminally put more of her copyrighted works from her catalog into production.
INEPTITUDE ALL THE DEFENDANTS
1128. The Defendants stole Aisha's copyrighted works and made them into projects riddled with ineptitude and sacrilege. They desecrated Aisha’s original works and made them into laughable models of confusion.
1129. Madonna's 2003 copyright infringing "American Life" rip off of Aisha’s 2001 “Contemporary Girl” received horrible reviews from critics and audiences alike, who laughed at her poor singing masked, and inadvertently accented by Autotune and vocoders, rendering an inorganic, robot like voice. This overuse of vocal processors to hide her blaring vocal shortcomings, to match the melodies and pitches Aisha naturally utilized, only served to announce them on the Defendant's second-rate rip off.
1130. Aisha is a Soprano blessed with a voice that naturally covers several octaves and contains great range. Her voice is so naturally developed by the grace of God that she is able to sing opera - Soprano and Mezzo-soprano parts. Her vocally challenging song "Contemporary Girl" which Madonna and her co-defendants ripped off for their subsequent infringing song "American Life" was a difficult song to write and perform, requiring a profound amount of vocal and lyrical ability and balance, of which Defendant Madonna has neither. In ripping off and tackling Aisha's complicated song, all of Madonna's vocal shortcomings were laid bare.
1131. The Defendant Madonna has made a career out of recording simplistic, sing songy, vapid music, never tackling anything of vocal or lyrical substance and complexity. In ripping off Aisha's socially conscious, vocally challenging, lyrically complex song, that bears several musical changes and styles (which include soprano vocals, coloratura flourishes, vibrato, Melismatics notes, Gospel styled vocals, rock riffs and rap) the Defendant Madonna greatly floundered in plain sight of everyone, especially critics, who publicly called it her worst work yet and slammed the song. Her gross ineptitude desecrated Aisha’s well-composed copyrighted song that Madonna ripped off.
MISCONDUCT ALL THE DEFENDANTS
1132. The torts committed against Aisha by the Defendants are laden with willful misconduct. They set out to rob and exploit, then harass and threaten a young woman whose copyrighted works they coveted due to its potential value - already criminally grossing them almost $500,000,000. Their unlawful actions were willful, premeditated, wicked and reckless.
SABOTAGE MADONNA, WARNER BROS, TIME WARNER, LIZ ROSENBERG
1133. Madonna has unduly interfered with Aisha's career by not only stealing her copyrighted works and fraudulently passing them off in the mainstream as her own; she has also actively tried to kill the younger singer's career.
1134. Recently, out of compassion for Aisha, she was informed by a very reliable, well connected source that Madonna and her reps have gone around telling entertainment industry publications and outlets not to interview her, having her blacklisted in the industry, in an attempt to suppress the information regarding the malfeasances she committed against Aisha from coming out in the mainstream media, kill her career and clear the way to further use her copyrighted catalog Madonna criminally gained possession of via a hired hacker.
1135. Madonna has surreptitiously been sabotaging Aisha's career in an attempt to destroy it from reaching its full potential, which would clear the way for her to put all of Aisha's copyrighted songs, scripts and music videos into production under her Maverick moniker without the mainstream public finding out who the copyrighted works really belong to, as she has a habit of stealing from lesser known artists, illustrated by numerous suits filed against her in this regard.
1136. The Defendants conspired to destroy Aisha's career and have her blacklisted all over the entertainment industry for daring to speak out about the gross misconduct the Defendants had commissioned and carried out against her to criminally gain possession of said catalog.
1137. The Defendants stole numerous copyrighted works from Aisha, rushed their rip off versions out first, in another attempt to sabotage her career and claim her works as their own to the public. The Defendants utilized this tactic many times at Aisha's expense.
1138. They had surreptitiously stolen Aisha's valuable catalogue housing a wealth of copyrighted works that they sought to and began using. In trying to crush her career before it properly took off, they felt she would be in a weakened position to defend herself and all her copyrighted works that they wanted to put in full production under their own monikers.
1139. During the last week of December of 2004, when Aisha faxed several press outlets informing them of the Defendants misconduct, in order to bring attention to it and get them off her back, Aisha was informed by a reliable source that Madonna and her publicist Liz Rosenberg went around telling people not to interview her to keep the story out of the mass media.
1140. Madonna also got Aisha dropped from a Gibson endorsement deal that was promised to her. Madonna did her level best to kill Aisha's career to further criminally use her works in violations of United Nations laws governing the right to employment:
a. The Universal Declaration Of Human Rights (1948) www.un.org/overview/rights.html
Article 3 - Everyone has the right to life, liberty and security of person.
Article 7 - All are equal before the law and are entitled without any discrimination to equal protection of the law. All are entitled to equal protection against any discrimination in violation of this Declaration and against any incitement to such discrimination.
b. The United Nations Guildelines/Computerized Personal Data Files
Article 19 - Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ides through any media and regardless of frontiers.
Article 23
1.) Everyone has the right to work, to free choice of employment, to just and favorable conditions of work and to protection against unemployment
2.) Everyone, without any discrimination, has the right to equal pay for equal work.
3.) Everyone who works has the right to just and favorable remuneration ensuring for himself and his family and existence worthy of human dignity, and supplemented, if necessary, by other means of social protection...
EXPLOITATION ALL THE DEFENDANTS
1141. The Defendants have exploited Aisha in a most disgraceful way. They've stolen her publicly released copyrighted works and criminally stolen her unpublished copyrighted catalog, mounted an illegal surveillance campaign to commit corporate theft, and even exploited her image and likeness for a $10,000,000 Versace ad campaign.
1142. When she tried to legally fight back, they coordinated a harassment campaign that criminally culminated in the assault of the Plaintiff. This perverse conduct is a vile case of exploitation.
1143. The Defendants behave as though Aisha has no rights and is to be exploited at their discretion for financial gain. Slavery has ended, therefore no one has the right to exploit and steal anyone's labor, work and property. The Defendants grossly exploited a law-abiding immigrant whose only dream was to make music and films.
UNWELCOMED SERVITUDE ALL THE DEFENDANTS
1144. Slavery was abolished many years ago; therefore no one has the right to steal anyone's labor for financial gain. Madonna has stolen Aisha's copyrighted works numerous times, and criminally so, used said works and collected millions for her criminal acts. This constitutes acts of unwelcome servitude in criminally stealing works, which Aisha labored for years to author and produce and taking remuneration and credit for works and labor that were not her own.
1145. Continually stealing someone's labor, via pillaging their property and copyrighted life's work, is in essence, turning them into an unpaid slave, which is completely unlawful and abhorrent.
1146. Aisha had no desire to work with her; therefore theft was the only way to get her hands on Aisha’s lucrative catalogue. Aisha holds Madonna in very low esteem, as she was raised by a musicologist with very strict musical standards, namely artists music be able to sing and sing well. Madonna has never met that criterion.
CRUELTY ALL THE DEFENDANTS
1147. Stealing Aisha's scripts, music video treatments, pics and song catalogue, valued in the high millions, illegally spying on her, tapping her phones and hacking her computers to commit corporate theft was an act of cruelty. The Defendants behaved as though they could do as they pleased to the Plaintiff as though she had no rights as a law-abiding citizen.
1148. Jamaican, U.S. British and The United Nations recognizes each person as a human being with rights. Everyone has the right to be gainfully employed and paid for his or her work, which the Defendants undeniably, criminally stole so many times, depriving Aisha of remuneration thereof.
1149. Everyone as human being under the United Nations Human Rights charter has the right to privacy and privacy in family life and their home. Madonna willfully violated this, perversely spying on Aisha in her home life of all places. They are a most unwelcome, perverse presence in Aisha's life.
1150. Madonna behaved as though Aisha was a slave that wasn't entitled to any rights and was to be exploited for financial gain. What the Defendants did was absolutely unconscionable and sick, deserving the most severe legal reprimand available by law.
OPPRESSION ALL THE DEFENDANTS
1151. Madonna's conduct towards Aisha is very oppressive. She criminally stole and continues to steal Aisha’s copyrighted works from her catalog she illegally obtained a copy of via a hired hacker.
1152. Madonna has actively tried to sabotage and kill Aisha’s career. Madonna's commissioned illegal surveillance which escalated to assault, corporate theft and copyright infringement campaign has severely oppressed and infuriated Aisha, who had done her no harm.
1153. No one should have to live and work under those circumstances, with their privacy, constitutional and human rights being severely violated by a corrupt, depraved pop star with no respect for the law, people’s rights and well being.
ENDANGERMENT MADONNA AND CO-DEFENDANTS
1154. As listed above, Aisha was criminally threatened and assaulted on the streets of Miami. Madonna has commissioned an illegal surveillance of the singer that is nothing more than harassment and stalking. She has endangered Aisha with this menacing, criminal conduct to dissuade her from suing and pressing charges for the criminal corporate theft via invasion of privacy in stealing her multi-million dollar valued copyrighted catalog.
1155. Aisha's financial data was being unlawfully listened to over the phone and viewed online by the Defendants. Madonna’s employer Time Warner AOL was careless and negligent with Aisha’s financial data allowing a hacker to hack her accounts and charge huge sums to her Visa Debit Card. Aisha was the victim of identity theft based in malice and not financial gain, which tied up a lot of the funds in her checking account.
1156. Aisha was terroristically harassed and threatened by Warner Bros affiliated attorney Defendant David Bercuson.
1157. She was further harassed by people clearly affiliated with and commissioned by Madonna and her co-defendants, when she went out in public to places she’d been going she since she was a little girl with no problems prior to this criminal surveillance and harassment campaign commissioned by the Defendants.
1158. A Madonna supporter directed to her site by a Madonna supported, endorsed and aided fan site emailed Aisha’s web site harassing her and threatening to stalk her. As stated he was directed to her site by a Madonna endorsed and management aided fan web site that showed up in the www.AishaMusic.com site statistics as having directed people to Aisha's site with the goal of harassment because she was publicly speaking out against Madonna, as evidenced by the subsequent emails to her site.
1159. Aisha and her family are concerned about Madonna’s increasingly obsessive, intrusive conduct and how many more laws they intend to break in stealing from, exploiting, harassing, assaulting and terrorizing Aisha. Madonna’s conduct is very disturbing and creepy.
WILFUL INFLICTION OF EMOTIONAL DISTRESS AND MENTAL ANGUISH ALL THE DEFENDANTS
1160. The Defendants conduct has caused Aisha and her family a great deal of sadness, stress, distress, anxiety and offense. Aisha has suffered great financial and authorial loss due to the Defendants criminally pillaging her copyrighted works. What she finds most upsetting is that her privacy was invaded and copyrighted works stolen and done in such a willful, deceitful, slimy, underhanded, abhorrent manner.
1161. Aisha has been copyrighting works since age 14 and treasures all her works. She numbers them among her most prized possessions and is extremely upset, offended, distressed and infuriated at how the Defendants underhandedly stole the contents of said copyrights from her, utilizing their them without her permission, which she never would have granted, as she detests their materialistic, immoral works.
1162. As a result of the Defendants abhorrent conduct, Aisha's work has been sacrilegiously profaned, which is a great offense to Aisha, as the work it was stolen for and incorporated in goes against everything she believes. The Defendants have also ruined and marred Aisha's debut that she planned since she was a teenager, something of great sentimental value to her that only happens once, with their inexcusable, vile, unlawful conduct.
1163. No singer wants something like this during the process of their first album, but the Defendants selfishly continue to criminally steal from, harass and exploit her, leaving her no choice, but to sue.
1164. Aisha's parents were disheartened and distressed when informed of the full extent of the misconduct against their daughter by the Defendants, which she kept from them in not disturbing their well being as they recovered from illness. Upon finding out, Aisha's family was very saddened and grew genuinely concerned for her safety, wondering how someone, the Defendants, could be so unethical and perverse to go that far as to commit invasion of privacy, harassment and corporate theft after all the wrongs they, the Defendants, had already done to their daughter by stealing her copyrighted works from her web site in clear view of so many people.
1165. In light of the Defendants questionable, criminal conduct in a long history of copyright infringement and fraud, it is imperative that a case be entered into record with a positive judgment rendered in favor of the victim, the Plaintiff, to stand as an example, template and testament to deter future misconduct.
1166. It is in the public's best interest, the literary community and copyright holders in general, that this issue be brought to light and legally dealt with to put a stop to it. Too many artists are suffering at the hands of these same Defendants.
1167. Aisha has suffered irreparable harm and financial loss as a direct result of the Defendants unethical, inexcusable conduct. Her life’s work has been stolen and sacrileged, her privacy has been invaded in several ways and she has been threatened by the Defendants in a disgraceful attempt to stop this action from being filed.
1168. By the grace of God, she has persevered and survived this ordeal to the point that she has put together this extensive lawsuit chronicling the Defendants’ disgraceful, criminal, reckless and intentional breach of many U.S., Jamaican, British and United Nations laws for financial gain and acclaim, all at her expense.
1169. The Plaintiff beseeches the court to review these charges and give her the opportunity to prove her valid case in court.
ACCESS
1170. Aisha’s computers were hacked with her copyrighted multi-million dollar catalog criminally copied by a hacker, with these works criminally later surfacing in Madonna’s projects.
1171. Aisha’s official web site statistics reveal that Madonna’s employer Warner Bros has clocked numerous hits to Aisha’s web site. Defendant Disney has also registered over 140 hits to Aisha’s web site.
1172. Aisha’s telephones have been wiretapped with the Defendants uising the contents for corporate theft and harassment via Madonna’s interviews, articles in the Sun Newspaper UK and the show CSI:Miami.
1173. Madonna had direct access to the Plaintiff’s work via her widely read web sites Aishamusic.com and Aisha.tv (with over 6.2 million web hits). Madonna made a habit of quoting items verbatim from Aisha’s web site Sound Off Column and online Diary writings. These items were copyrighted before Madonna alter repeated them publicly in her interviews in major newspapers, on TV and the internet - whose copyright dates are all later than Aisha’s. This inextrivavly ties Madonna to Aisha’s web site.
1174. Over 50 international radio and satellite DJs in America, England, Germany, France, Cyprus and the Caribbean having been sent an official promo copy of the song “Contemporary Girl” by mail for airplay, one year prior to it being infringed by the Defendant.
1175. Aisha has been under illegal surveillance commissioned by Madonna, who one day after Aisha shot a video in London during this month, ran to the press the day after Aisha’s shoot, announcing that she was preparing to shoot what (Aisha) had filmed the day before. More evidence of corporate theft and Madonna knowing exactly who Aisha is - as Aisha had already copyrighted that video treatment as mentioned previously in this Complaint, but only got around to shooting it this month.
1176. Further proving access are a series of newspaper, magazine and television interviews where Madonna plagiarized and falsely attributed original items, article excerpts and catchphrases Aisha wrote, copyrighted and published on her website, to herself in very public interview.
1177. Most tellingly, these original items can now only be found on Aisha’s web site and in Madonna’s numerous interviews. In several widely published interviews, Madonna arrogantly, fraudulently and unscrupulously went as far as to quote word for word original copyrighted writings from Aisha’s web site writings, inextricably linking her to Aisha’s web site. Madonna turned Aisha into a speechwriter against her will by willfully attributing the Plaintiff’s original writings to herself in front of millions of people worldwide via these interviews, taking full credit for copyrighted items as her words, phrases, ideas and musings.
1178. Links to www.aishamusic.com http://www.aishamusic.com and www.aisha.tv http://www.aisha.tv have also been listed in several online music directories, web sites and message boards since 2001, which lead to over 5 million web hits in 4 years. It is not an obscure web site on the Internet.
1179. Aisha is listed in many directories as mentioned previously in this action. If you are listed, you would do well to be very careful and make sure your copyrights are in order. Aisha receives business solicitations from retailers, music companies and involuntary, but appreciated, music directory listings in web sites all the time. There are industry executives and companies who've told Aisha that they know about her, when she'd never done business with or met them prior. It is very important to remember that once you put something (music) out there, just because it is not in the mainstream, doesn't mean it's not being heard.
1180. A positive example of that is Eminem sampling a song by musician Edgar Winter, who was surprised Eminem even knew about him or the track, which he says never received any airplay. However, Eminem went about using the track legally by applying for a license (song clearance) through the music publisher, rather than stealing elements of it for his own work like Madonna does. Winter said, "I'm as interested as everyone else to see how he came up with the concept. I would never have thought he'd ever heard of me, or the song. It never got radio play, so I don't know how he came across it."
1181. One would assume no airplay, therefore no one knows about the artist, but that isn't true, especially with the introduction of the internet. Aisha is a prime example of that. Before she finished recording her debut album, her web site had received over 5 million hits.
1182. There are music industry record collectors who buy records by unknown artists that are in limited release. However, they are collectors who really just like buying music. There are also DJs and employees at radio stations who keep copies of CDs submitted for airplay consideration that they don't play because the station already has their preset playlist.
1183. These CDs often make their way around the industry. Some are sold to record stores where anyone can buy them, while others land in the hands of A&R guys, which could spell trouble for aspiring and indie artists’ copyrights if it is an unscrupulous label representative. The cause of many a lawsuit over the past 20 years. However, if it's a decent executive and an artist is looking for a deal, they could get signed.
1184. The Defendant Madonna admitted on renowned UK television program Blue Peter that she does get ideas from the internet, where the bulk of Aisha's released work has been located since 2001.
1185. In November of 2004, the Defendant Madonna was featured on the popular UK show "Blue Peter." When asked by the interviewer where she got the unusual names for the characters in her books, the defendant Madonna tellingly responded, "The Internet." It goes to show access and intent, in that Madonna is an internet surfer who gets ideas from the internet - the venue where Aisha has a well known web site.
1186. Moreover, IP tracking and keystroke recording programs were utilized by Madonna’s hired hacker to monitor and steal Aisha's copyrighted catalog and watch her online activities for further corporate theft, which included research for her music and film works and her Column. Aisha frequently visited name web sites to look up the meaning of Biblical names and her own name, prior to Madonna making that announcement on Blue Peter of doing the same. She even referred to the name meanings on her web site.
1187. On several occasions, Madonna and Victoria Newton sickly stole items from Aisha's written WordPad Sound Off Columns housed on her private computer, days before they went online, attributing various items from the unpublished column to themselves in fraudulent attempts to establish Aisha's work as their own before it was released and to harass, terrorize and frustrate her.
Madonna's Career Long History of Plagiarism and Copyright Infringement
1188. The Plaintiff respectfully asks the Court to enter into record the Defendant, Madonna’s extensive history of copyright infringement and plagiarism. She and several of her co-defendants are habitual copyright infringers with long, sordid histories of plagiarism and copyright infringement.
1189. Throughout her 20-year career, Madonna Ciccone has displayed a wanton disregard for copyright law, having been sued for and credibly been accused of copyright infringement more than 20 times - more than any other artist in the history of music. The Defendant has arrogantly and unlawfully made plagiarism and copyright infringement a staple in her career. For years, she has willfully defrauded writers, singers and filmmakers out of their earnings and credit for the work they authored, via plagiarizing their work and infringing their copyrights, several of which have sued her and won substantial settlements.
1190. In spite of these very telling lawsuits, Madonna continues to steal people's copyrighted works, undeterred. The infringements by Madonna continue at a disgraceful rate, more than any other singer on record, because her major record label, the multi-national Warner Bros, also a frequent copyright infringer, negligently facilitate this illegal behavior and mount a very strong legal offense that would financially crush the average copyright holder of normal means, each time an allegation or suit is brought against said singer and or company.
1191. This enables and emboldens her to further violate US and international laws in infringing copyrights of artists around the world then misappropriating and misrepresenting their works as her own, as she has done so many times over the years.
1192. The Defendant Madonna Ciccone tellingly said in a recent People Magazine interview “I no longer have time to be creative,” yet contradictorily claimed in the very same article that she is the one writing the music for her next album.
CASES REGARDING MADONNA MISCONDUCT
1193. Bourdin v. Madonna, Maverick, Warner Bros and Jonas Akerlund - The Defendants were sued for copyright infringement and settled out of court due to the overwhelming amount of evidence against them, namely the comparative evidence being so shockingly similar.
1194. Madonna brazenly stole 11 pictures from his copyrighted work and duplicated them for her video without permission or credit, only altering them slightly to hide the theft. Of course, she denied this, as she always does regarding these allegations, but a British newspaper reported that she was seen leaving the Victoria and Albert Museum in London, which housed Bourdin’s work, a week before she filmed the infringing video.
1195. The curator for the Bourdin exhibition, Charlotte Cotton, confirmed this information. The similarities are terribly striking. They look like they came from the exact same shoot SEE EXHIBIT 57.
1196. Earlier in the year she was quoted as saying his work is “so sick and interesting,” however she denied any wrong doing in this case. Bourdin’s family won a settlement thought to be $638,000. The late artist’s son said of her, “It's one thing to draw inspiration; it's quite another to simply plagiarize the heart and soul of my father's work.” True, indeed, as that seems to be her trademark.
1197. Salvati v. Madonna, Maverick, Warner Bros and Jonas Akerlund. Madonna was sued for copyright infringement in ripping off an already filmed and released video shot in 1994 for local famous pop star Biagio Antonacci for the song/video "Non e Mai Stato Subito,” that Italian director Stefano Salvati submitted to Madonna.
1198. The album "Ray Of Light" won a lot of awards, even Grammys, because of the breakthrough video she stole from Salvati, which also won awards. Based on records it was authored and filmed by Salvati, before he submitted it to Madonna who ripped it off four years after its release.
1199. Her version was released in 1998. Defendant Joanis Akerlund is also the director Madonna hired for the "Hollywood" video for which they were also sued and had to pay the plaintiff a $638,000 settlement on last year (see number one plagiarism example in this article).
1200. Ingrid Chavez v. Madonna and Lenny Kravitz (settled before filed) - Prince protégé threatened to sue Madonna for stealing credit for her song “Justify My Love,” by changing one line of her song and then replacing Chavez's name in the writer's space with her own. It was reported that Chavez was later credited and awarded a settlement after she threatened to sue.
1201. Chavez said, "Madonna only changed one line of the entire song” and stole writers credit for the song, even though Chavez was the one who wrote it. “This has been said of her by other credible writers as well involving other songs, mentioned in this Complaint.
1202. But this is what she does. She takes credit for other people’s writing and ideas then goes around declaring herself a writer. That is not songwriting. That is a sham. The song did match Chavez's trademark style, which at the time was once again unlike anything Madonna had done. Much like Aisha’s style of music is unlike anything Madonna has done.
1203. It was reported "Meanwhile, Chavez sued Lenny Kravitz for not giving her credit for co-writing Madonna's Justify My Love. Chavez's style consists of breathy spoken passages over heavy dance beats and this can be clearly heard in the Madonna track. Chavez is quoted as having said that Kravitz didn't write any of the lyrics and only came up with the phrase justify my love. She is also reported to have said that Madonna only changed one line of the entire song. She was finally given credit for the lyrics plus a rumored couple of million dollars in an out-of-court settlement."
1204. Vincent D’Onofrino v. Madonna and Maverick. The Defendant Madonna was sued for plagiarism and breach of contract in stealing a proposal of a film remake that was pitched to her and her agents by D’Onofrino, for a remake of the film Swept Away.
1205. Madonna underhandedly stole the project from D’Onofrino cutting him out of the $20,000,000 deal, for which she and her husband, Guy Ritchie, collected substantial fees and control of said budget. D’Onofrino was robbed of financial compensation, points and credit, for which he filed suit. However, the film fittingly bombed upon release, becoming the most panned film in history. The case is currently in court.
1206. Salvatore Acquaviva v. Madonna - Acquaviva sued Madonna for deliberately stealing his song "My Life's Getting Nowhere" for her 1998 hit "Frozen." Madonna had met his producer prior to recording her infringing version of the song.
1207. Madonna's lawyer incredulously and incriminatingly responded, "Just because there are similarities between two songs it doesn't mean it has been plagiarized. There are certain artists who hear songs on the radio, see that there are very successful and say to themselves, Why shouldn't I try it on?" You should not try it on because it is a violation of U.S. and U.N. laws.
1208. Easy Street Records vs. Madonna - Madonna was sued for $2.5 million dollars in U.S. District Court in New York for stealing the song "You Don't Know" by one of Easy Street Records' artists and making the song into her hits "Deeper and Deeper" and "Bad Girls."
1209. Millennium Films, Inc. v. Madguy Entertainment, Inc., Siren Films, Inc., Madonna Ciccone, Guy Oseary, Caresse Norman. Millennium films spent large sums of money and signed finance deals for Madonna to appear in the film "Going Down" and she reneged on her agreement to star in the film.
1210. Madonna.com v. Madonna. Operator of madonna.com website sues singer for declaration that name "Madonna" by itself is not entitled to Lanham Act protection.
1211. Madonna, Maverick v. Warner Bros. Madonna sued Warner Bros willfully attempting to disregard the terms of the contract she and her partners had signed with them to start Maverick Records. Warner settled lawsuit for menial sum, removing Madonna from the label and keeping Oseary.
1212. Bennie Brown v. Madonna. Man seeks $1 million after wooden statue badly reattached after Madonna video shoot in restaurant falls on him. NY Supreme Court filing.
1213. Branch vs. Maverick - Sued Madonna and Maverick Records due to being paid insufficient royalties.
DISNEY LAWSUITS
1214. Disney sued by French children’s author for stealing the character he created and trademarked, with Disney later stealing and renaming it Nemo.
1215. Disney sued by Royce Matthew for blatantly ripping off his movie for the film The Pirates Of The Caribbean.
1216. Litigation initiated by Simon & Schuster Inc., against M. Night Shyamalan and Disney for the film “The Village,” which infringes the copyrights of author Margaret Peterson Haddix's book "Running Out of Time," published in 1995. Simon & Schuster spokeswoman Tracy Van Straaten stated, "This is a children's book that sold more than half a million copies and won prizes, so it's not an obscure book for us." Peterson, like Aisha, was bombarded with queries from her readers asking if she noticed Shyamalan film used portions of her copyrighted book.
1217. Shyamalan has previously battled a copyright infringement lawsuit brought by a Pennsylvania screenwriter who claimed the plot from his 2002 film "Signs" mirrored his unpublished script "Lord of the Barrens." Source: San Francisco Chronicle
CASES INVOLVING WARNER BROS MISCONDUCT
1218. Sophia Stewart v. Warner Bros and the Wachowski Brothers - sued for stealing her script and using it to create the Matrix and its sequels. The FBI found evidence to support her claim.
1219. Cher vs. Warner Bros Records - Singer sues for non-payment of $350,000 in royalties owed for over 3 years.
1220. Warner Chappell sued for under paying songwriters on the Eagles Greatest Hits album, giving them under what they were entitled to based on their legal agreement with said publisher.
1221. Tom Petty and Warner sued for copyright infringement for the song "The last Dj."
1222. Crowe V. Warner - Cameron Crowe sues on copyright infringement charges for the show Singles.
1223. Warner and Oliver Stone sued by Greek Lawyers Association over Alexander The Great’s deliberately inaccurate por
1224. Le Roth v. Van Halen and Warner Bros - royalty and control dispute.
1225. Warner Bros were sued on copyright infringement charges for the movie “Eraser.”
1226. Warner Bros was just sued for copyright infringement for the summer 2005 film flop “The Island” starring Scarlett Johanssen.
1227. Warner Bros sued for defamation of character for an inaccurate, defamatory portrayal in the movie the “Perfect Storm.”
Courtesy of Entertainment Law Digest:
1228. Ilene Goldberg v. Warner/Chappell. Former legal affairs exec alleges discrimination and misconduct by her supervisors.
1229. Salah Hassanein v. Time Warner. Time Warner film executive says company used transfer pricing and other tricks to stop his bonus from being what it should have been.
1230. Warner Bros. v. Continental Casualty. Insurer has failed to reimburse expenses of copyright lawsuit over the film “Space Jam,” studio alleges.
1231. Warner Bros. v. Joseph Y. Compañía Representaciones Elephant S. En C. Warners sues Colombian distributor in dispute over termination of contract, saying inter alia that the case must be heard in Californian, not Colombian, court.
1232. Alan Ladd, Jr., Jay Kanter v. Warner Bros. Producers say their audit showed studio underpaid them $2.5 million for their share of revenue from a dozen films, including the “Police Academy” films and “Blade Runner.”
1233. Mellado v. Warner Bros. Fired financial analyst sues company under California’s unfair competition statute for allegedly failing to pay artists, actors, directors, writers and others correctly.
1234. Tracy Naegele v. Time-Warner, Gerald Levin, et al. TV watcher files class action, seeking millions in compensation for the "pain and suffering" inflicted when cable system cut off ABC and Disney for two days.
1235. Fox v. Time Warner. Fox says Time and Turner want to "squish" Fox by keeping Fox news channel off Time's cable systems.
1236. Syca v. Warner Bros. TV partnership investor says Warner failed to pay $1.8 million in profits from shows like “North and South.”
1237. Warner Bros. v. ESI Montana, MTTV, Equity Broadcasting, Montana Broadcasting. Defendants signed licenses but then refused to make license payments or broadcast bartered advertising.
1238. Cable Parker v. Time Warner. Disgruntled cable customer can seek class certification for allegation that cabler shared subscriber info without permission; problem of possible $12 billion award can be handled later.
1239. Baker v. Universal Interactive, Edgar Bronfman. Judge dismisses $1billion pro se lawsuit charging that defendants used manuscript of plaintiff's novel and used it in ads for theme park.
1240. Jean Patrick Capdevielle v. Miles Copeland, Warner Bros. French composer/record producer says makers of "Red Planet" hired singer for soundtrack and CD in violation of exclusive recording contract.
1241. LaCour v. Time Warner. Songwriter's unfair competition claims for "reverse passing off" of allegedly infringing hit song "I Believe I Can Fly" in movie "Space Jam" are pre-empted by Copyright Act. Ruling ND Illinois.
1242. Youngblood v. Score - (S.D.N.Y. Sept 1999) Plaintiff's claims of copyright infringement against Defendant Warner Bros. relating to the unauthorized use of plaintiff's music as background music in a television soap opera dismissed after full trail.
FURTHER THEFT ALLEGATIONS
1243. Madonna has a long history of plagiarism - an unusually high amount of incidences. She is a habitual copyright infringer, which is reflected by several the above named lawsuits. Madonna has built a career based on ruthlessness, theft and perversion. She and her team scour the industry for the latest trends and music, often stealing them as illustrated below.
1244. If you do this enough times, you'll build up an arsenal of hits - that don't belong to you. And that's just what she's done. The fact of the matter is the songs "Like A Virgin," "Vogue," “Frozen,” "Justify My Love," "Deeper And Deeper," "Human Nature," "Bad Girl," and "American Life," the videos for "Ray Of Light," What It Feels Like For A Girl" and "Hollywood," the "Sex" book, the movies "Swept Away" and now "Material Girls" are all at the center of credible plagiarism and copyright infringement claims and lawsuits against Madonna - none of which she has won.
1245. An insightful book that is currently available in stores titled, “Madonna: An Intimate Biography,” alleges that Madonna ripped off the idea for her “Sex” book from a publishing executive named Judith Regan (page 221) who is now considered the biggest independent publisher in the world.
1246. Madonna ripped off the 1989 song "Deep In Vogue" by Malcolm McLaren for her 1990 song "Vogue." As with Aisha’s song “Contemporary Girl” she stole it shortly after it was made available to the public. His song was released on July 19, 1989 on Epic Records and her rip off was released almost a year later on April 5th, 1990.
1247. His song came out first and was about "Voguing." Madonna's rip off brought his music, lyrics, melodies and dance trend to the mainstream by stealing it from him, along with portions of his beat. Madonna even tries to sing like the female vocalist on McLaren's track. AUDIO EXHIBIT COMPARISONS TO BE PRESENTED AT TRIAL.
1248. A journalist and several critics wrote of the remarkable, uncanny similarities between McLaren’s “Deep in Vogue” and Madonna’s later written “Vogue.”
1249. Respected music industry organization Muze criticized Madonna for ripping off visual concepts, video imagery and ideas from underground transvestite singer “Peaches” for her work. Several outlets mention this and the similarities are very, very striking. It was also reported that she would play Peaches' album over and over again before going on stage in Barcelona. A reviewer from the well-known industry company Muze wrote: "If imitation is the greatest compliment, then Peaches received top honors when Madonna stole imagery from Peaches’ videos and applied them to her own. If the queen of controversy steals your ideas, you must have something going on." Muze Inc
1250. Peaches' debut CD was released on a German label and sold only 50,000 - yet Madonna managed to get a copy of one of them. Those numbers are good for an indie, but translate into obscurity in the mainstream.
1251. The mere fact that they knew who Peaches was, even with him being an underground artist below the radar, speaks volumes. Ask the average musicologist or music critic about Peaches, and they wouldn't know who he is, as he is an underground artist, but she actually knew him and had his CD. That is very telling.
1252. Her reinventions are unethically that of marginally known, unknown and underground artists that she tries to become in search of that next new trend in music. That is profoundly disturbing. However, Madonna and her team do what some unscrupulous executives in the music industry do - scour the clubs, internet and other venues for new music, dance and clothing trends and take full credit for them as their own in the mainstream (as she did with “Vogue,” among other things).
1253. Her reinventions are the creations of unknown or marginally known artists, she wrongfully feels taking these ideas, concepts and music to the mainstream automatically makes her the author. She is often referred to as trendsetting, but judging by these lawsuits and allegations from so many people, she is not a leader, but a follower who takes all the credit.
1254. There is something Andrew Morton wrote of her in the biography he did titled "Madonna," which is very telling. He wrote that during the early days of her career, she would go around Manhattan in limos searching for guys to sleep with. He said she believes that she felt she could deny any questionable behavior if someone were to talk about it publicly, because she feels she is such a celebrity that no one would believe them. He's right. Some celebrities do think that way. However, at this point, she is a celebrity with no credibility due to years of unethical conduct, which resulted in lawsuits.
1255. Indie band Hide The Babies published a web site that contained the allegation that they gave Madonna’s manager their demo (cassette) in the 80's, she liked it and asked if she could keep it. She returned the tape to them 6 months later. They alleged that shortly after one of their lyrics appeared in Madonna’s song as the basis for "Like A Virgin," but not credited to them. A group member stated they felt she did this because she figured if she got her version out first it would render their version useless. SEE EXHIBIT 61.
1256. That’s the same lyric, just changed up slightly to camouflage the theft. It’s also the same concept/pun about not being a virgin, but someone seemingly making you feel like that. It is the same thing Madonna did with Aisha's song "Contemporary Girl." She took lyrics, among other things, and tried to change them up in the same manner using the same pattern of misconduct, but just enough to retain the idea and concept of the song and chunks of the lyrics and music, hopefully without getting caught.
1257. "Like A Virgin" was Madonna's first real hit and credited to another writer that her label and management hired. However, this allegation of theft bears a pattern that would later be said of many other songs Madonna allegedly composed.
1258. In a 2004 interview on Bravo with producer Nile Rodgers, he said Madonna told him at the time that the concept of the song "Like A Virgin" was such a good idea and kept emphasizing this point to him.
1259. Hide The Babies web site states, "Then when her tune came out we couldn't do ours anymore because everybody thought we got it from her." That statement it is profoundly sad and terrible considering "Like A Virgin" was such a big hit that allegedly came from this band who are saying they did not get credit for it.
1260. This strikes a chord with Aisha based on what she experienced with her song that was infringed by Madonna. It bears the same pattern.
1261. Hide The Babies front woman Kitty Brazelton: "We think Madonna stole a song of ours or at least the lyric/concept which was: "I'm not a virgin/but you're the first one..." What do you think? Her management was particularly interested in that song and asked to keep the cassette. We got it back after 6 months. Then when her tune came out we couldn't do ours anymore because everybody thought we got it from her." http://www.kitbraz.com/bndl/htb/ SEE EXHIBIT 61.
1262. In 2003 Victoria Newton ran a small feature in her column stating Eminem was angry at Madonna and accused her of ripping off his work, "Bonnie and Clyde” for one of her videos from her Greatest Hits Volume 2 album.
1263. In 2003 The Sun Newspaper UK ran an article accusing Madonna of Copyright Infringement in stealing a previously released Kylie Minogue poster for use as her CD cover for the album American Life. SEE EXHIBIT 63.
1264. An indie art web site alleges Madonna ripped off their slogan "Express Yourself, Don't Repress Yourself" for one of her lyrics from her song "Human Nature." She seems to have a thing for stealing from art, as evidenced by the Bourdin case.
1265. Madonna has a history of trying to horn in on credit for work she did not do or deserve credit for. This has been written about in several publications. It is discussed in the Andrew Morton biography titled "Madonna."
1266. An award winning songwriting partner of Andrew Lloyd Webber complained of her trying to horn in on credit for his song by trying to change a few lyrics, which is apart of a pattern of constant misconduct by Madonna. She somehow managed to get the lead role in Evita, regardless of the fact that most critics slam her acting.
1267. When it came time for the soundtrack, the studio hired two award-winning composers to pen the songs. After receiving his properly written song, sheet music and all, Madonna sent it back with revisions adding a few words (similar to what she did with the song “Justify My Love” by Ingrid Chavez, as mentioned above).
1268. Due to her lack of intelligence and crass speech, Madonna doing revisions to a song is like Homer Simpson doing revisions to Shakespeare. The composer who penned the song is a trained writer, unlike Madonna, but she wrote a few words, revising his already completed song in what was widely viewed in the industry as her unethically trying to horn in on credit for his composition. Credibility is something she’s always sought, but never achieved.
1269. Never mind the writer had already written the lyrics, piano and strings for the song already. When songs are credited, the names will appear as though each person did the same amount of work, when with some that’s not the case. Horning in on credit for something someone else wrote by trying to add a few words and collecting underserved publishing royalties/credit is not songwriting and is just plain unethical.
1270. However, offended and branding her revisions "abysmal and banal lyrics” the writer stood firm, rejected her so called lyrics and later won an Oscar for the song she tried to add a few words to and horn in on the credit for.
1271. He won it without her so-called revisions. If he hadn't stood firm, she would have won an Oscar for an already completed song that she tried to add a few words to, having nothing to do with its creation or music. What a travesty that would have been.
1272. Madonna's "Cherish" takes lyrics from Sam Cooke's "Cupid" and the Association's "Cherish." SEE EXHIBIT 66. Additional exhibits of audio comparison to be presented at trial.
1273. Keep It Together sounds like “It's A Family Affair." SEE EXHIBIT 66. Additional exhibits of audio comparison to be presented at trial.
1274. Spanish Eyes sounds like a cross between "Spanish Harlem" by Benny E King and music by Billy Joel. SEE EXHIBIT 66. Additional exhibits of audio comparison to be presented at trial.
1275. “Dear Jessie” sounds like The Beatles "Yellow Submarine." SEE EXHIBIT 66. Additional exhibits of audio comparison to be presented at trial.
1276. "Act of Contrition" sounds like The Beatles "Revolution No. 9" SEE EXHIBIT 66. Additional exhibits of audio comparison to be presented at trial.
1277. However, that’s what she does. According to a May 27th, 2003 Fox News article titled "Madonna Tour: Does She Need The Cash?" all her songs that were big hits were all written by someone else, while the latter, more unsuccessful songs that she performed and “co-wrote” were all written with someone else, which is a tell tale sign in the industry.
1278. Music critic Chuck Dimaria commented, "I always felt that if you leave Madonna in a room with a guitar and a pad of paper, all she’ll write is her grocery list. I have a hard time swallowing that she’s as much of a songwriter as the credits would lead you to believe."
1279. In a third similar case, singer/songwriter Jem, who's been featured on the television show The O.C., implied in an interview that Madonna did not write much of the song “Nothing Fails,” which she penned and submitted to Madonna. She horned in on credit for this already completed song for the same album she ripped off Aisha's "Contemporary Girl" for, "American Life."
1280. Just Like Band Camp - Las Vegas Review-Journal, By DOUG ELFMAN She has a law degree. She's a DJ. She used to run a small record label. Madonna picked up Jem's song "Nothing Fails" and recorded it for her own "American Life" album. Madonna shares songwriting credit on "Nothing Fails." Did Madonna change enough of it to merit that credit? "You can't ask questions like that! Somebody should, but there are some things that are best left unsaid,"
1281. Several directors have publicly complained about her trying to take over their film sets and altering scripts. When that happens, it forces a screenwriters credit that is undeserved, so many resist her efforts. Many articles and books support this claim. An Oscar award winning director, Schlesinger, died of a heart attack as a result of her trying to alter his film and antagonizing him with her ridiculous demands on the set of what would be his last film. In notes he bequeathed to the BFI he blamed Madonna for his heart attack that subsequently caused his death.
1282. Madonna does not like to give people credit for their work, typical of a copyright infringer. She was bashed by USA Today for leaving the illustrator's name off the cover of her children's book, “Yakov and the Seven Thieves.” It was written in the article that it is customary in the publishing industry to put the illustrator’s name on the front, which they were aware of, but left off anyway. SEE EXHIBIT 64.
1283. The music video for her latest single “Love Profusion” is a rip off of British singer Billie Piper’s “Honey to the Bee” video, which was released 5 years before Madonna’s knock off. Side by side stills show the striking similarities. Madonna’s video features her in front of a red 3D computer generated flower, while floating on the ocean, which is the same as Piper's video - only Piper's video was filmed and released years before. I remember seeing the behind the scenes segment for Billie’s video a few years ago and you can tell it's a rip off of it. They even used the same technique.
1284. Madonna ripped off copyrighted 1956 Marilyn Monroe pics for her 1985 “Like A Virgin” promo. SEE EXHIBIT 67.
1285. Madonna and her husband were accused of copyright infringement by the British band BBMak, who had the international hit "Back Here." BBMak publicly stated that Madonna and her director husband Guy Ritchie plagiarized their music video "Still On Your Side" for her video "What It Feels Like For A Girl." SEE EXHIBIT 59.
1286. Band Nashville Pussy accused Madonna of invasion of the Right Of Publicity in ripping off their image and likeness. SEE EXHIBIT 18.
1287. Sued by Belgian musician and writer John Acquaviva for stealing his song for use in her song released 5 years later titled “Frozen.”
1288. Yael Oestreich v Madonna, Maverick and Mark Morgan - Former Maverick Films vice president sued Madonna and Maverick for sexual harassment and wrongful termination. The case is currently in court. Morgan went around the office tweaking female employees nipples and called Ms. Oestreich "uptight" for not participating in talks about sex.
1289. According to the Columbia Plagiarism Project (Columbia University) several of Madonna’s songs infringe the copyrights of other songs.
1290. According to an independent music plagiarism web site, Madonna’s songs infringe and plagiarize the following songs:
MADONNA'S QUESTIONABLE CONDUCT
1291. As mentioned previously in this Complaint, Madonna choked and “beat up” 10 year old Keith Sorrantino.
1292. As mentioned previously in this Complaint, Madonna choked Dick Clarke’s son.
1293. As mentioned previously in this Complaint, Madonna condemned former manager Caresse Henry for alleged inappropriate behavior, having sex with her bodyguard, deeming it unfaithful, yet put on a debauched display with Christina Aguilera and Britney Spears at the MTV Awards. Madonna French kissed them on stage at the MTV Awards - two singers young enough to be her daughters.
1294. That was not faithfulness. That was perverse and people who claim to be decent individuals of a religious faith don’t engage in kissing orgies on stage at an international award show, televised to viewers of all ages at the respectable hour of 9PM.
1295. Her performance was ushered in by her 6-year-old daughter, who she dressed up as a bridesmaid for mommy's disgraceful display. Then had the gall to author children’s books, not to mention, with items she gained via invasion of privacy.
1296. That’s far worse than what she claims her former manager did, in that she exposed millions of unwitting viewers, many of them children, to that perversion. Moreover, condemning people, especially for things she has done, is not a principle espoused by Judaism. It is also grossly hypocritical. She is in no position to throw stones at anyone, as her conduct is among the vilest. Self-awareness is not one of her strong suits.
1297. Exaggerates her record sales by tens of millions of copies in official press releases that reflect great disparities in accounting and industry sales averages. Madonna claims she's sold 250,000,000 records, yet Soundscan and other international plaques that have been awarded for sales say otherwise. In 2002, Madonna and her reps put out a press release, which stated she sold over 150,000,000 records. That alone was a stretch, but in 2004, they put out another press release for her new album stating she'd allegedly sold over 250,000,000 records.
1298. Madonna incredulously purported that she managed to sell more records during the decline of her career, in two years (between 2002-2004), than the Beatles managed to sell in 20 years. 100,000,000 million more records in two years during the time her career started bombing. It is an attempt to steal the title of the best selling female artist of all time through padded, exaggerated sales figures.
1299. Who in music has sold 100,000,000 million records in two years, especially when their career hit a major decline. Guinness World Book records do not reflect what Madonna purports regarding her sales. Neither does Soundscan, whose records reflect that her records sold far less, with critics in recent years referring to her last and current project as terrible and calling her washed up
1300. In Madonna's interviews she comes across as an airhead, yet amazingly writes lyrics way above her speech level. She even claimed she is editing her tour documentary, as Aisha had previously written in her online copyrighted diary, which is a very complicated process, mostly due to the equipment. However, Aisha is an electronics whiz, Madonna is not. Much like Madonna's records sales, her editing the film herself doesn't add up. Does Madonna have proper receipts to back up those claims.
1301. It was reported in print and on film that Madonna slept with well-known New York DJ Mark Kamins in order for him to get her a record deal, which he did, with Sire Records.
WARNINGS TO CEASE AND DESIST
1302. The Plaintiff respectfully requests that the court take into consideration the repeated warnings that were issued via her web site instructing the Defendants to stop infringing her copyrights, which they stubbornly refused to heed. All work clearly bore copyright warnings, which the Defendants arrogantly and recklessly ignored.
PROTECTIVE ORDER
1304. The Plaintiff is requesting a protective order sealing the contents of her copyrights to be displayed as evidence in this case, some of which contains unreleased material, to protect her works from further infringement.
PRO SE
1305. Due to Warner Bros being such a large corporation, the Plaintiff is in possession of letters from several attorneys she sought legal representation from, who acknowledged they saw “the infringements,” but did not want to take the case for “financial reasons,” while others stated “personal reasons.”
1306. Much like the well known, accomplished Washington Times author and humorist Art Buchwald, who dared to sue a major studio to reclaim his work they'd pilfered for the film "Coming To America" starring Eddie Murphy, Aisha was given the run around by numerous entertainment industry attorneys who did not want to sue a major studio or label, much like Buchwald was. Buchwald could not find a lawyer for a long period of time.
1307. An attorney and family friend who does not practice copyright law, thereby he could not take the case, told Aisha that because of who Warner Bros is in the entertainment industry, one of the major film studios, record labels and music publishing companies, many lawyers do not want to sue and alienate them, which would make them and their clients ineligible for any future business.
1308. Aisha however, has had some legal training and has read legal journals since the age of 15, as she had contemplated becoming a professional lawyer for a time. In light of this, the Plaintiff has filed this complaint Pro se, with the judgment sought as follows:
PRAYER FOR RELIEF 1309. The Plaintiff respectfully asks the court to provide the most severe penalties possible, with punitive and actual damages, requiring the Defendants to give back all the profits they received and continue to receive in royalties from stealing Aisha’s intellectual property and cruelly invading her privacy, in addition to severe punitive damages for said abhorrent misconduct. It is the only remedy that will help to correct the Defendants’ gross misconduct that has caused Aisha unspeakable harm, loss and sadness. 1310. The unjustly enriched party should pay restitution to the rightful owner, Aisha, and punitive damages for their unlawful conduct that broke numerous international laws. Anything less would send the message that breaking the law, violating people's civil rights, invading their privacy and stealing their property is a profitable civil and criminal venture worth undertaking. 1311. The Defendants have conducted business for years under the premise of steal now and worry about the law later and if need be payoff the wronged party less than you made, thus turning a profit from criminal activity. This is evidence by their long history of stealing intellectual property and paying off litigants far less than they made from infringing their copyrights, which cost less financially in comparison to the profits made from the illegal activity. 1312. The Plaintiff requests penalties be levied against the Defendants for the tactics that resulted in additional the emotional distress, anxiety, mental anguish and sorrow this entire episode has created in her life. 1313. The Plaintiff requests the Defendants and their associates be made to permanently desist from stealing from the Plaintiff's works. 1314. The Plaintiff requests a permanent injunction, recalling and delivery of all infringing works for destruction. 1315. The Plaintiff requests a permanent injunction against all planned, in production and or completed future releases containing the Plaintiff's work. 1316. The Plaintiff requests damages in the amount of: 1317. Madonna aka Madonna Ciccone aka Madonna Ritchie - $200,000,000 in compensatory damages and $500,000,000 in punitive damages. 1318. Bertram Fields - $100,000,000 in compensatory damages and $50,000,000 in punitive damages. 1319. Guy Oseary - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1320. Guy Ritchie - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1321. Mad Guy Entertainment - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1322. Ska Films - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1323. Luc Besson - $70,000,000 in compensatory damages and $50,000,000 in punitive damages. 1324. Europacorp - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1325. Steve Christian - $30,000,000 in compensatory damages and $10,000,000 in punitive damages. 1326. Virinie Silla - $30,000,000 in compensatory damages and $10,000,000 in punitive damages. 1327. Pierre Spengler - $30,000,000 in compensatory damages and $10,000,000 in punitive damages. 1328. Christopher Ciccone - $100,000,000 in compensatory damages and $150,000,000 in punitive damages. 1329. Guy Oseary - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1330. Mark Morgan - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1331. Maverick Records - $100,000,000 in compensatory damages and $200,000,000 in punitive damages. 1332. Maverick Films - $100,000,000 in compensatory damages and $200,000,000 in punitive damages. 1333. Webo Girl Music Publishing - $100,000,000 in compensatory damages and $200,000,000 in punitive damages. 1334. Warner Bros Records - $100,000,000 in compensatory damages and $100,000,000 in punitive damages. 1335. Warner Vision - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1336. Warner Chappell Music Publishing - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1337. WB Music Corp - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1338. Time Warner AOL - $100,000,000 in compensatory damages and $200,000,000 in punitive damages. 1339. Motorola - $100,000,000 in compensatory damages and $150,000,000 in punitive damages. 1340. Disney - $200,000,000 in compensatory damages and $300,000,000 in punitive damages. 1341. Buena Vista Pictures - $150,000,000 in compensatory damages and $300,000,000 in punitive damages. 1342. Walt Disney Pictures - $200,000,000 in compensatory damages and $300,000,000 in punitive damages. 1343. Walt Disney Records - $50,000,000 in compensatory damages and $30,000,000 in punitive damages. 1344. Michael Eisner - $200,000,000 in compensatory damages and $300,000,000 in punitive damages. 1345. Jerry Bruckheimer - $200,000,000 in compensatory damages and $300,000,000 in punitive damages. 1346. Jerry Bruckheimer films - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1347. Charles Howard - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1348. Sunil Nayar - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1340. Steven Maeda - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1350. Michael Ostrowski - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1351. Corey Miller - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1352. Ildy Modrovich - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1353. Brian Davidson - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1354. Marc Dube - $20,000,000 in compensatory damages and $10,000,000 in punitive damages. 1355. Gary Marshall - $150,000,000 in compensatory damages and $300,000,000 in punitive damages. 1356. Gina Wendkos - $150,000,000 in compensatory damages and $300,000,000 in punitive damages. 1357. Meg Cabot - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1358. Shonda Rhimes - $150,000,000 in compensatory damages and $300,000,000 in punitive damages. 1359. The Sun Newspaper (UK) - $150,000,000 in compensatory damages and $300,000,000 in punitive damages. 1360. News Group Newspapers LTD - $150,000,000 in compensatory damages and $300,000,000 in punitive damages. 1361. Victoria Newton - $15,000,000 in compensatory damages and $30,000,000 in punitive damages. 1362. Charles Dudman - $15,000,000 in compensatory damages and $30,000,000 in punitive damages. 1363. Nikki Waterman - $15,000,000 in compensatory damages and $30,000,000 in punitive damages. 1364. Stuart Prince - $30,000,000 in compensatory damages and $20,000,000 in punitive damages. 1365. Steven Klein - $30,000,000 in compensatory damages and $20,000,000 in punitive damages. 1366. Liz Rosenberg - $70,000,000 in compensatory damages and $50,000,000 in punitive damages. 1367. Callaway Arts and Entertainment - $100,000,000 in compensatory damages and $300,000,000 in punitive damages. 1368. Versace - $30,000,000 in compensatory damages and $100,000,000 in punitive damages. 1369. Mario Testino - $15,000,000 in compensatory damages and $50,000,000 in punitive damages. 1370. Britney Spears - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1371. Missy Elliot - $10,000,000 in compensatory damages and $40,000,000 in punitive damages. 1372. Mirwais Ahmadzai- $30,000,000 in compensatory damages and $40,000,000 in punitive damage. 1373. Jive Records - $50,000,000 in compensatory damages and $60,000,000 in punitive damages. 1374. Interscope Records - $100,000,000 in compensatory damages and $150,000,000 in punitive damages. 1375. Patriot Pictures - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1376. Arclight Films - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1377. Michael Mendelsohn - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1378. Martha Coolidge - $100,000,000 in compensatory damages and $200,000,000 in punitive damages. 1379. John Quaintance - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1380. Susan Jensen - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1381. Jessica O’Toole - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1382. Amy Rardin - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1383. Jonas Akerlund - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1384. Music Today Inc - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1385. Andrews McMeel Publishing - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1386. David Bercuson - $50,000,000 in compensatory damages and $100,000,000 in punitive damages. 1387. Gwen Stefani - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1388. Harajuku Lover Music - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1389. Pharrell Williams - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1390. Chad Hugo - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1391. Star Trak - $50,000,000 in compensatory damages and $25,000,000 in punitive damage. 1392. Nick Cannon - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1393. Darren Sherrill - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1395. James Edward Jones - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1396. Lilly Darron Keith - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1397. Boogology Music - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1398. D Lil Music Publishing - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1399. Darren Sherrill Music - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1400. Lion’s Gates Films - $50,000,000 in compensatory damages and $50,000,000 in punitive damages. 1401. Mark Amin - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1402. Katherine Fugate - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1403. Jack Amiel - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1404. Michael Begler - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1405. Jonas Akerlund - $50,000,000 in compensatory damages and $25,000,000 in punitive damages. 1406. Legal fees - costs of this action, including interest. 1407. Any other relief the Court deems fit.
Dated: This 30th day of September, 2005
By: ________________________ Aisha Goodison P.O. Box 190073 Miami Beach, Florida 33119-0073 law@sonustar.com
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