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UNITED STATES DISTRICT COURT
THE SOUTHERN DISTRICT OF FLORIDA
CASE NO: CIV 05-22618 ALTONAGA/TURNOFF

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AISHA
AISHA KAMILAH MUSIC (ASCAP)
AISHA GOODISON
SONUSTAR,

Plaintiffs,

vs.

MADONNA A/K/A MADONNA RITCHIE,
GUY RITCHIE, DISNEY, BUENA VISTA PICTURES,
WALT DISNEY PICTURES, WALT DISNEY RECORDS,
MICHAEL EISNER, JERRY BRUCKHEIMER,
JERRY BRUCKHEIMER FILMS,
TIME WARNER AOL, WARNER BROS,
WARNER BROS RECORDS, WARNER BROS TV,
WARNER CHAPPELL MUSIC PUBLISHING,
WEBO GIRL MUSIC PUBLISHING,
WB MUSIC CORP, WARNER VISION,
MAD GUY ENTERTAINMENT INC,
BERTRAM FIELDS, STUART PRICE,
MAVERICK RECORDS, MAVERICK FILMS,
GUY OSEARY, MARK MORGAN,
MOTOROLA, LIZ ROSENBERG, STEVEN KLEIN,
BRITNEY SPEARS, MUSIC TODAY INC,
LUC BESSON, STEVE CHRISTIAN,
VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS,
EUROPACORP, CHRISTOPHER CICCONE,
GWENYTH STEFANI, HARAJUKU LOVER MUSIC,
PHARRELL WILLIAMS, CHAD HUGO, STAR TRAK,
INTERSCOPE RECORDS, NICK CANNON,
ZOMBA RECORDING LLC, SONY BMG,
DARREN SHERRILL, JAMES EDWARD JONES,
LILLY DARRON KEITH,
BOOGOLOGY MUSIC, LIL D MUSIC PUBLISHING,
DARREN SHERRILL MUSIC,
CALLAWAY ARTS AND ENTERTAINMENT,
ANDREWS MCMEEL PUBLISHING,
MISSY ELLIOT, MIRWAIS AHMADZAI,
DONATELLA VERSACE, VERSACE INC,
PRATO VERDE, MARIO TESTINO,
VICTORIA NEWTON, GRAHAM DUDMAN,
NICKI WATERMAN, THE SUN NEWSPAPER LTD UK,
NEWS GROUP NEWSPAPERS LTD,
GARY MARSHALL AKA GARRY MARSHALL,
GINA WENDKOS, MEG CABOT,
SHONDA RHIMES, PATRIOT PICTURES,
PATRIOT ADVISORS, ARCLIGHT FILMS,
JOHN QUAINTANCE, SUSAN JANSEN,
JESSICA O’TOOLE, AMY RARDIN,
MARTHA COOLIDGE, MICHAEL MENDELSON,
CHARLES HOWARD, SUNIL NAYAR,
STEVEN MAEDA, MICHAEL OSTROWSKI,
COREY MILLER, ILDY MODROVICH,
BRIAN DAVIDSON, MARC DUBE,
LIONS GATE FILMS INC, MARK AMIN,
KATHERINE FUGATE, JACK AMIEL,
MICHAEL BEGLER, JONAS AKERLUND,
DAVID BERCUSON,
UNIVERSAL PICTURES, PAUL WEITZ,
CHRIS WEITZ, DEPTH OF FIELD,
PAUL WEITZ, CHRIS WEITZ,
DEPTH OF FIELD, UNIVERSAL PICRTURES,
JOE HENRY, JOHAN RENCK, PROD4EVER,
CHIME INTERACTIVE,
CHRISTIAN KARLSSON AND PONTUS WINNBERG
A/K/A BLOODSHY AND AVANT

Defendants.

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AMENDED COMPLAINT - JURY TRIAL DEMANDED

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. 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.

2. 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.

3. 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.

4. Aisha is the owner of a very valuable, wholly owned, multi-million dollar valued copyrighted catalog containing over 6,500 songs, 2 dozen scripts, 4 dozen film synopsises, 11 book manuscripts, 4 dozen music video treatments and 3 dozen photo treatments. It is the largest privately owned and authored intellectual property catalog in the world. 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. 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."

5. 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.

6. Aisha is known to people all over the world, as attested by her 6.5 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. 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.

7. 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 BACKGROUND

8. 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 Distinct accommodation, 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.

9. 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.

10. 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.

11. 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.”

12. 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. 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 interloped 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.

13. 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.

SUBJECT MATTER JURISDICTION AND VENUE

14. Respectfully, the Plaintiff asserts, this Court has jurisdiction over this case and it should proceed at this venue for the following reasons:

15. The Plaintiff is a tax paying resident of Miami, in the Southern District of Florida.

16. The Plaintiff has been a law abiding resident of Miami for the past 20 years, in the Southern District of Florida.

17. The Plaintiff’s business that was criminally stolen from by the Defendants is located in Miami, in the Southern District of Florida.

18. The majority of the malfeasances committed against the Plaintiff occurred in Miami, in the Southern District of Florida.

19. Defendant Warner Bros Records has offices in Miami, Florida in the Southern District of Florida, located at 15800 NW 48th Avenue, Miami, FL 33014. It was written this year that Defendant Madonna has been a resident of Miami, Florida and that Defendant Missy Elliot is a resident of Miami, Florida.

20. Numerous Federal laws this Court has jurisdiction over have been willfully violated by the Defendants such as Copyright Infringement, Criminal Copyright Infringement, Unfair Trade Practices, Mail Fraud, Fraud, Wire Fraud, Wiretapping, Internet Fraud, Assault, Harassment, Grand Theft Larceny, Human Rights violations, Civil Rights violations, violations of The U.S. Constitution and violations of United Nations Laws (much of which occurred on U.S. soil). This Court has subject matter of this action under 28 U.S.C. 1338. All the Plaintiffs infringed works were registered with the copyright office prior to them being infringed by the nefarious, avaricious Defendants.

21. The case has been sent to the FBI and DOJ due to the number of Federal and international laws that have been broken by the Defendants. The Plaintiff, upon interview and delivering case documents to the North Miami Beach, Florida branch of the FBI, was told that the case will be investigated.

22. Defendant Warner Bros Records and Jive (SONY/BMG) recently admitted committing willful violations of Federal law, felonies, in utilizing the unlawful practice of payola (“pay for play” – paying DJs for radio airplay, which is illegal). Upon information and belief, Defendant Warner Bros Records and SONY BMG have settled with the New York State Attorney’s Office for millions in fines and admitted wrongdoing. This recent development is additional evidence that Jive/SONY BMG and their affiliates and Warner Bros Records and there affiliates are no strangers to breaking Federal law in the operation of their business, much like the Plaintiff asserts in her Complaint they have done to her, trampling on her rights and willfully stealing her Federally and internationally protected copyrighted works, both released and unreleased, in acts that also constitute numerous felonies.

23. It was made public last month that Defendants Madonna and Warner Bros Records were found guilty of Plagiarism and Copyright Infringement in Belgium (Acquaviva v. Madonna) in a crushing legal blow, the most definitive of its kind in music history against a major label and artist. It is the very misconduct the Plaintiff asserts in her Complaint they committed against her in willfully breaking U.S. Federal Law, over which this Court has jurisdiction. The Judge, Xavier Hiernaux, ordered a complete recall in the country of Belgium (population 10,000,000), of all copies of Madonna’s copyright infringing works “Ray Of Light” and “Frozen,” ordering that these works never be played again in Belgium and never aired again on Belgian TV.

24. The Plaintiffs’ web site, transmitted from the Southern District of Florida, is viewed nationally and internationally with over 6,500,000 hits and counting, had its copyrights willfully infringed by the Defendants.

25. LAWS VIOLATED IN WHICH THE PLAINTIFFS ARE ENTITLED TO RELIEF

1. Copyright Act 17 U.S.C. 101
2. The Lanham Act 15 U.S.C. 1051
3. The Business and Professions Code of Sections 17500 to 17535
4. Uniform Deceptive Trade Practices Act
5. Title 18 section 1341 of the U.S. Code (Mail Fraud)
6. The Securities Exchange Act of 1934
7. Violations of The U.S. Constitution: The Fourth Amendment
8. Multiple willful violations of RICO statues
9. The Computer Fraud and Abuse Act of 1986
10. Title 18 U.S.C. Sec.1001
11. Title 18 U.S.C. Sec.1030.
12. Title 18 U.S.C. Sec. 2510
13. The No Electronic Theft Act (NET)
14. 17 U.S.C. _ 506 (a)(2) and 18 U.S.C. _2319(c)(3)
15. Multiple violations of The Universal Copyright Act of 1952
16. Multiple violations of The Digital Millennium Copyright Act
17. Multiple violations of The Berne Treaties of 1967, which the U.S. joined in 1989 and swore to uphold.
18. The Universal Declaration Of Human Rights (UDHR 1948), which the U.S. joined and swore to uphold.
19. The United Nations Guidelines/Computerized Personal Data Files, which the U.S. joined and swore to uphold.
20. The European Convention on Human Rights
21. The Charter of Fundamental Rights of the European Union
22. The inter-American declaration of the Rights and Duties of Man (Art V), which the U.S. joined and swore to uphold.
23. The Inter-American Convention on Human Rights (Art 11), which the U.S. joined and swore to uphold.
24. The United Nations Convention on the rights of the Child, which the U.S. joined and swore to uphold.


CAUSE OF ACTION

26. This action arises out of the Defendants willful civil and criminal violations of U.S. Federal laws, among other things; in unlawfully using copious amounts of the Plaintiff’s Nationally and Internationally protected Copyrighted works without permission and without her knowledge, invading her privacy and that of her family in violation of the Fourth Amendment and U.N Laws and then harassing and assaulting her when she publicly spoke out against them for the above described misconduct.

27. Madonna and her co-Defendants have made a regular habit of visiting the Plaintiff’s copyrighted web sites www.aishamusic.com and www.aisha.tv and illegally helping themselves to copious amounts of copyrighted works, in willful violations of U.S. and U.N Laws. The Plaintiff’s web site statistical software recorded thousands of these visits by the Defendants, inextricably tying them to her web site. Madonna is further inextricably tied to the Plaintiff’s web site via continually and characterlessly quoting and attributing items from the Plaintiff’s original writings on her online Sound Off Column, to herself in public interviews.

28. 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. However, what began as willfully violating federal Copyright law via stealing off the internet in clear, open view scores of people in Aisha’s audience, many of whom began contacting her over the internet asking if she’d noticed the way Madonna has been stealing her work, a frequent form of misconduct utilized by Madonna, who has been sued for this very misconduct several times before by different unrelated Plaintiffs, evolved into invasion of privacy, hacking and corporate theft to steal an unreleased Copyrighted catalog of works only available on the Plaintiff’s business computers stored in her home studio. Her home studio was also mysteriously broken into as evidenced by the Police report contained in this lawsuit as an exhibit.

29. The Defendants criminally procured Aisha’s catalog of 6,500 songs, 2 dozen scripts, 4 dozen film synopsises, 11 book manuscripts, 4 dozen music video treatments and 3 dozen photo treatments and criminally began using numerous items from said catalog in acts worthy of imprisonment. Said catalog is worth hundreds of millions in its text state, and billions in its produced, released and marketed state.

30. Madonna and her co-Defendants criminally used already copyrighted works they obtained via hacking, invasion of privacy, grand theft larceny, fraud and dealing in stolen goods, without permission and in open violation of U.S. and U.N. civil and criminal laws. Works identical to the Plaintiff’s already copyrighted works, only stored in the Library of Congress and in her home on her business computers, were criminally used by the Defendants to make several new products by the Defendants, as listed in detail below. The Plaintiff has owned the copyrights to these works years before the Defendants criminally infringed them. The Defendants criminally entered into multi-million dollar deals with several corporations, unlawfully and fraudulently using the Plaintiff’s copyrighted works as the basis and security for said projects – works they criminally gained access to via hacking, in violation of U.S. and U.N. laws.

31. They are further using these works for sacrilegious purposes that go against everything the Plaintiff believes in and holds dear. These acts constitute numerous violations of U.S. and U.N. human rights, property rights, copyright and civil rights laws. The Defendants have made millions in ill-gotten wealth via these acts of racketeering, fraud and invasion of privacy. The Plaintiff’s home has been placed under illegal surveillance by the Defendants, violating her human rights in an abhorrent, despicable way. They have fraudulently enriched themselves via acts U.S. and U.N. laws condemns as criminal. These acts were completely premeditated, willful, intentional and wicked.

PRECEDENT FOR INVASION OF PRIVACY VIA HACKING SET BY DEFENDANTS

32. Defendants Jive Records A/K/A Zomba Recording LLC/SONY BMG has announced the unprecedented recall of 5 million CDs, roughly 50 million dollars worth of merchandise, due to its illegal XCP copy protection program contained on said music CDs being discovered. XCP in actuality is a deceptive invasion of privacy tool A/K/A a trojan horse, items as such are used for the crime of hacking. Microsoft classified it as “malware” and other computer agencies a “a hidden Trojan horse.” Both classifications amount to unlawful hacking tools. Sony BMG sold 2.47 million copies of those CDs, which invaded in the privacy of millions of Americans and the world, due to the exploitation and spread of viruses stemming from said Sony BMG program. The insidious XCP program was transmitting the contents of millions of consumers computers, as well as their on and offline internet habits, to Jive/Sony BMG without permission, which is hacking. Much like Aisha’s copyrighted catalog was illegally copied by a commissioned hacker, with works from the Plaintiff’s copyrighted catalog now surfacing in Madonna and her co-defendants projects, verbatim.

33. Anyone who bought Defendant Jive/Sony BMG CDs or emailed a friend who had bought these CDs playing them on their computer, was subjected to invasion of privacy, as the XCP program left the backdoor of millions of computers open for Sony BMG to surreptitiously get in and out to transmit the contents of consumers computers. However, they weren’t the only ones gaining access to the infected computer systems, as due to Sony BMG’s negligence and willful misconduct, hackers wrote code to exploit said open backdoors – which led to identity theft, personal computer data theft and file corruption and destruction. This created an undue burden on the computer industry that received many complaints and frantic tech support calls and emails from consumers all over the world.

34. Government condemns Sony BMG's XCP Trojan: "On November 16, 2005 US-CERT, the United States Computer Emergency Readiness Team, part of the United States Department of Homeland Security, issued an advisory on XCP DRM. They said that XCP uses rootkit technology to hide certain files from the computer user." - Wikipedia

35. The Texas State Attorney General's Office has sued Jive/Sony BMG: “Sony has engaged in a technological version of cloak-and-dagger deceit against consumers by hiding secret files on their computers. Consumers who purchased a Sony CD thought they were buying music. Instead, they received spyware that can damage a computer, subject it to viruses and expose the consumer to possible identity crime." - Texas State Attorney General Greg Abbott.

36. "At what point do you think it is a good thing to surreptitiously put Trojans on people's machines? The only thing you're guaranteeing is that they won't be customers anymore,”- researcher David Maynor said in The N.Y. Times.

37. Software and ISP companies had their employees bogged down with tech support inquiries that were unnecessary and avoidable. Normally, they expect calls from people with systems damaged by hackers, not the second largest record company in the world. Their employees’ time was used solving a computer crisis caused by Jive/Sony BMG. It was no accident. To put a privacy-invading program on music CDs, press up the 5 million CDs, ship the 5 million CDs into the American market place, approve funding and set up of servers/storage to collect the illegal data reports the privacy invading program will be sending over the internet to the Sony BMG servers from the 5 million personal computers it was designated to be deceptively placed on, took pre-planning, planning, organization, budget approval and clearance. This entire episode, among several others, has completely embarrassed the entertainment industry, exposing several of its key members and decision makers as privacy invaders.

38. Jive/Sony BMG, is a partner with Warner Bros and Warner Bros Records in distributing Madonna’s copyright infringing records “Frozen” and “Ray Of Light” in Europe, which a Belgian Judge Xavier Hiernaux, ordered the recall of for willful copyright infringement by Madonna.

39. The Plaintiff Aisha was the victim of a harassment styled case of identity theft that began with Time Warner AOL, her former ISP – during the time they owned Madonna’s label Warner Bros Records. Time Warner AOL allowed a hacker to charge $2600 dollars ($600 on one occasion, $2000 on another two weeks later) to her Visa ATM card that was given to AOL to pay for her monthly internet service the weekend she announced her album would be available for sale. The hacker tried to spend as much of the money in her account as possible, in a couple hours, to tie up all her funds, to leave she and the album marooned. There is a clean, irrefutable, digitally and financially linkable trail pointing to the same nefarious person and her partners, Madonna/Warner Bros.

40. PLAINTIFF’S COPYRIGHTS WILLFULLY VIOLATED (COPYRIGHT OFFICE REGISTRATION NUMBERS:

Pau2-587-556 (4-16-2001)
Pau2-739-041 (7-01-2002)
Pau2-803-203 (7-21-2003)
Pau2-851-193 (8-25-2003)
Pau2-858-936 (4-12-2004)
Pau2-946-506 (7-12-2004)
Pau2-902-060 (9-14-2004)
Pau2-938-294 (12-23-2004)
Pau2-979-924 (3-14-2005)
Pau2-969-938 (6-09-2005)

41. RELEASED COPYRIGHT INFRINGING WORKS:
1. “American Life” by Madonna
2. Promotional photos for “Madonna Greatest Hits Volume 2”
3. Every song on “Confessions on a Dance Floor” by Madonna
4. “Hung Up” music video
5. Numerous promotional photos for “Confessions on a Dance Floor”
6. Numerous items from Madonna’s “English Roses” fashion line
7. "Madonna's Inspirations" stolen from Aisha’s “Beautiful Inspirations”
8. Madonna.com and Icon web sites
9. “The Princess Diaries 2” by Buena Vista Disney
10. “Can I Live” by Nick Cannon
11. “Hollaback Girl” by Gwen Stefani
12. “Stream of Consciousness” column by Britney Spears
13. “Goal!” the movie by Disney
14. “Players: The Mysterious Identity Of William Shakespeare” by Bertram Fields
15. A character on Disney’s “That’s So Raven” illegally based on Aisha, using willful alterations of her copyrighted song.
16. Guy Ritchie’s “Revolver” movie poster
17. “The Prince and Me” by Lions Gate Films
18. American Hi-Fi stolen from Aisha band name “American Radio”

42. FORTHCOMING INFRINGING WORKS

1. “American Dreamz” by Universal Pictures willfully and criminally infringes the Plaintiff’s copyright registration Pau2-739-041 in violation of the Copyright Act and the Lanham Act. Madonna criminally sold Aisha’s script “Presidential Dreams” to Defendants Paul Weitz and Chris Weitz. They have since used it to make the criminal copyright infringing movie “American Dreams.” Aisha’s script “Presidential Dreams” was written in 1998 and copyrighted in 2002. She further bought the internet name www.presidentialdreams.com in 2002. Defendants Paul Weitz and Chris Weitz copyrighted their blatant rip off of “Presidential Dreams” retitling it, only changing the first word to American, calling it “American Dreams” during this year, 2005. Aisha’s copyrights, internet film title registration, poor man’s copyrights and digital time stamped CDs showing the dates of authorship of her work, all predate by years, the Defendants’ copyright obtained this year.

Aisha’s 2002 copyrighted script “Presidential Dreams” is a patriotic comedy/drama about the American presidency, a singer and the middle east – all unique and distinct in one script, among other items the Defendants willfully stole. Defendants Paul Weitz and Chris Weitz’s 2005 illegally copyrighted rip off script “American Dreams” is an unpatriotic comedy/drama about the American presidency, a singer and the middle east – all once unique to Aisha’s previously copyrighted works until the Weitz brothers criminally ripped it off via a copy of Aisha’s script that was procured via criminal hacking and invasion of privacy. Both films also have two word titles ending in the word “dreams.” There are many other duplications of Aisha’s copyrighted script that will be introduced as evidence.

Furthermore, the Weitz’ rip off is an unpatriotic, nasty film, mocking, insulting and taking pot shots at the President and American culture, which the Plaintiff does not approve of. They had no right to turn her film script that they criminally stole into the unpatriotic, foolish, offensive, sloppy mess they have. Aisha’s film was an inspiring, patriotic film about the American Presidency. However, the Defendants have turned it into a mockery of the American Presidency with jokes about a solider in Iraq, which in these times is completely inappropriate. Much like the original culprit behind all this stealing and criminal theft, main Defendant Madonna, did in mocking the President in 2003’s “American Life” music video. Though the film is not released yet, with a planned release date of April 14, 2005, it was screened to a select few (critics), one of which gave a full scene-by-scene synopsis of the film, which is how Aisha realized what the film contained and that it criminally ripped off her copyrighted works to the tee.

Defendants Paul and brother Chris Weitz and their company Depth of Field have clear, indisputable ties to Madonna’s Warner Bros, which is where they gained criminal access to the Plaintiff’s copyrighted works:

a. For years the Defendants the Weitz brothers wrote and produced a show for the Warner Bros Television Network titled “Off Centre.” Defendant Warner Bros is the label for Defendant Madonna.

b. The Defendants the Weitz brothers are currently writing the sacrilegious, offensive “His Dark Materials: The Golden Compass (2007)“ for Warner Bros’ New Line Cinema set for release on December 7, 2007 – a film that has been condemned by the Catholic Church, prompting Warner Bros to ask the Weitz brothers to make changes to said film.

2. “Pirates of the Caribbean 2 & 3” by Jerry Bruckheimer and Disney, willfully and criminally infringes Plaintiff’s copyright registrations that predate theirs, in violation of the Copyright Act and the Lanham Act. 2005 previews and film synopsises of “Pirates of the Caribbean” 2 &3 reveal the blatant infringements of the Plaintiff’s 2002 copyrighted film script “World Mafia” AKA “International Mafia.” “Pirates of the Caribbean” 2 & 3 are currently being filmed in the Bahamas. Upon information and belief, the original “Pirates of the Caribbean” was the subject of a copyright infringement lawsuit by Florida filmmaker Royce Matthew, who had copyrighted it 10 years before Disney and Jerry Bruckheimer willfully stole it.

3. “Material Girl” by Madonna’s Maverick Films, willfully and criminally infringes Plaintiff’s copyright registrations in violation of the Copyright Act and the Lanham Act. Aisha copyrighted a synopsis of a film script with the story line being about twin sisters and one of them the CEO of a very successful company, fighting to save her company. Madonna’s later rip off “Material Girl” is about sisters, one of them the CEO of a very successful company, fighting to save her company. The Copyright infringing “Material Girl” is schedule for release sometime in 2006. The copyright infringing film stars the Duff sisters. 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. Madonna has tried her best to mislead the public into thinking the copyright infringing movie “Material Girl” is about, inspired by and based on her song “Material Girl” 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 Aisha’s song of the same name.

Madonna’s 80’s song "Material Girls" is what she claims the movie is about when it clearly is not. “Material Girl” 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 Girl” is about a modern CEO - which is what Aisha’s 2001 song and movie synopsis for her film “Contemporary Girl” is about. The similarities and duplications to Aisha's previously copyrighted works and Madonna's subsequent rip off is blaring.

Furthermore, Aisha’s “Contemporary Girl” film script synopsis is only housed on her private business computers and in the Library of Congress in Washington, D.C. where it is Federally protected by Copyright law. Coincidentally, this is very copyright that 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, not the U.N. assigned rights, and 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, suspiciously told Aisha over the phones she “can’t sue Warner” (Madonna’s label) and even though she owns copyrights “anyone is free to use her work.”

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 them to time stamped discs, sending herself a poor man’s copyright via U.S. Mail to prove the date of authorship, all of which, including her copyright registration, predates Madonna’s and her company Maverick’s fraudulent registration.

4. “Sam’s Lake” by Maverick Films – 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. 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." The reworked script Aisha authored original material for has a lead character named Sam and the film is about Sam and his friends. 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.

5. “Chasing Fate” - 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. Maverick FilmSis currently filming the rip off “Chasing Fate” which is listed as being about “a man who dumps his fiancée only to watch her ascend to fame and fortune.”

6. “Grave Dancers” - Aisha copyrighted items such as “Grave Diggers: Concrete Diggers” only to read headlines shortly after of Maverick Films shooting a movie called “Grave Dancers.”

    INJUNCTION

43. The Plaintiff requests an immediate injunction barring the Defendants from using and or releasing any of her copyrighted works in the above named projects and any other currently unknown planned projects by the Defendants. The Plaintiff is entitled to injunctive relief under the Copyright Act and the Lanham Act. SEE ATTACHED INJUNCTION REQUEST.

COUNTS

44. Plaintiffs, Aisha, Aisha Goodison, Aisha Kamilah Music and Sonustar hereby sues the Defendants for the triable and recoverable counts under U.S. Federal Law:

45. MADONNA A/K/A MADONNA RITCHIE, in the ongoing willfully misconduct relating to the theft of the Plaintiff’s Copyrighted works, for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right Of Publicity, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Defraud, Assault, Stalking, Harassment, Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Commit Harassment and Terrorization, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation, Endangerment, Willful Infliction of Emotional Distress and Mental Anguish. Madonna has stolen numerous copyrighted works of the Plaintiff’s valued at hundreds of millions of dollars, in willful civil and criminal violations of U.S. and U.N. laws, as listed under the RELEASED COPYRIGHT INFRINGING WORKS segment of this Complaint. Madonna is in criminal possession of a hacker procured copy of the Plaintiff’s multi-million dollar copyrighted catalog that she has been criminally using items from for herself, her company Maverick and selling off other items from to her business associates and partners in the entertainment industry.

46. MADONNA, WARNER BROS TV, JERRY BRUCKHEIMER, JERRY BRUCKHEIMER FILMS, CHARLES HOWARD, SUNIL NAYAR, STEVEN MAEDA, MICHAEL OSTROWSKI, COREY MILLER, ILDY MODROVICH, BRIAN DAVIDSON and MARC DUBE for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Defraud, Stalking, Harassment, Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Commit Harassment, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Exploitation, Willful Infliction of Emotional Distress and Mental Anguish.

47. 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).

48. Tapes of Aisha's telephone conversations have unlawfully been shared with staff of Jerry Bruckheimer’s show CSI:Miami in attempts to harass her out of suing its principal owner, Bruckheimer, who in conjunction with his partner Madonna, whose copyright infringing music was recently featured on the show, have been criminally using the Plaintiffs copyrighted works. Things the Plaintiff said over the phone to numerous friends, family and business associates appeared in the show verbatim. 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. They further plagiarized Aisha's web site column www.soundoffcolumn.com with items from her web site being used for show plots and dialogue, all after she published them to the web site and copyrighted its contents.

49. 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. 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 6,500 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.

50. Mr. Bruckheimer’s partner was the late, notorious Don Simpson, who was also represented by Madonna's lawyer Defendant 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. As mentioned above, preliminary evidence indicates that Jerry Bruckheimer is in illegal possession of a copy of Aisha’s above-mentioned catalog that he is currently using items from in violation of U.S. and U.N. laws, in acts worthy of imprisonment.

51. MADONNA, AOL (TIME WARNER AOL) for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Wire Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation, Willful Infliction of Emotional Distress and Mental Anguish.

52. 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 actively stole her copyrighted catalog for huge profits in tallying in the millions. The Defendants further allowed a hacker to charge over $2600 dollars to Aisha’s Visa ATM card they were given to pay for her monthly AOL service. When Aisha and her bank called to inquire about the unauthorized charges to Aisha’s card that Star ATM card company verified was done by a hacker, AOL told Aisha “It was probably a hacker. Change your password.” AOL assisted their co-workers at Warner Bros (Warner Bros Records and Madonna) in their illegal quest to rob, exploit and defraud Aisha out of millions of dollars in Copyrights, via providing the layout and keys of the Plaintiff’s computers and ports used to connect to the internet via AOL, which made it extremely easy for the commission hacker to gain access to Aisha’s business computers on a regular basis and copy the copyrighted contents. VP of EarthLink, Claudia Caplan recently stated, " AOL sells your information." AOL further violated the Copyrights of Aisha’s Sound Off Column on several occasions for its news home page. The Plaintiff’s contract with AOL and its terms are null and void, as they willfully violated it in assisting their co-workers (Warner Bros Records and Madonna) in illegally accessing Aisha’s business computers for corporate theft.

53. MADONNA, WARNER BROS, WARNER BROS RECORDS, WARNER CHAPPELL MUSIC PUBLISHING, WEBO GIRL MUSIC PUBLISHING, WB MUSIC CORP, WARNER VISION, MIRWAIS AHMADZAI, STUART PRICE, JOHAN RENCK, JONAS AKERLUND, STEVEN KLEIN, PROD4EVER, CHIME INTERACTIVE and LIZ ROSENBERG for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Defraud, Trade Libel, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish. This segment relates to the ongoing willful infringements of Aisha’s copyrighted works namely for the Madonna single “American Life,” the entire Madonna album “Confessions on a Dance Floor” CD and promo pics, “Re-invention Tour” DVD, “Hung Up” music video and the Madonna.com web site. The willful infringements of Aisha’s copyrighted works, namely Madonna 2003 single “American Life” occurred during Warner Bros ownership of Warner Bros Records and its subsidiaries.

54. MADONNA, STUART PRICE, MIRWAIS AHMADZAI, JOE HENRY, CHRISTIAN KARLSSON AND PONTUS WINNBERG A/K/A BLOODSHY AND AVANT for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish. The above named Defendants are sued for their part in writings and or producing the copyright infringing “Confessions on a Dance Floor” CD by Madonna.

55. MADONNA, BERTRAM FIELDS for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Cyber Based Theft, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish..

56. 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 works attributed to him. 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. Scholars and audiences alike have met his claims about William Shakespeare with derision and contempt. It quite amazing that 4 months after Aisha wrote, copyrighted and published a 40 page scathing article titled "Material Girl or Material Thief" on December 27, 2004, in which she 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, style and theories 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. Aisha’s article has been read by scores of people and can be found at www.aishamusic.com/plagiarism.htm.

57. Mr. Field’s client Madonna further tapped Aisha’s phone, an accusation that has been leveled at Fields and several of his clients before by others, some of whom have been imprisoned for this very misconduct. Bert Fields is the common link that binds these people. "A security expert testified at a deposition, 'It is pro forma for you to advise clients to conduct sweeps of their telephones in any matter in which Bert Fields [leading Hollywood lawyer and employer of Pellicano] is involved as the opposing counsel. Bert Fields writes novels under the name D. Kincaid about legendary attorney Harry Cain who has a close relationship with private eye Skip Corrigan, who frequently breaks the law." - (Source: www.LukeFord.net)

58. MAVERICK RECORDS, MAVERICK FILMS, GUY OSEARY, MARK MORGAN, PATRIOT PICTURES, PATRIOT ADVISORS, ARCLIGHT FILMS,
JOHN QUAINTANCE, SUSAN JANSEN, JESSICA O’TOOLE, AMY RARDIN,
MARTHA COOLIDGE and MICHAEL MENDELSON for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Securities Fraud, Defraud, Libel, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish.

59. Madonna and her Maverick Records and films associates have stolen numerous copyrighted works of the Plaintiff’s valued at hundreds of millions of dollars, in willful civil and criminal violations of U.S. and U.N. laws, as listed under the RELEASED COPYRIGHT INFRINGING WORKS and FORTHCOMING INFRINGING WORKS segment of this Complaint. 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 A/K/A Patriot Advisors (co-producers) willfully infringed and stole a copyrighted film script synopsis from Aisha’s copyrighted private multi-million dollar valued catalog, mentioned previously in this Complaint, for their subsequent in production film “Material Girls” starring Hillary and Haylie Duff. Defendant Martha Coolidge also directed a film titled "The Prince And Me" starring Freddy Prinze jr and Julia Stiles, released in 2004 through Defendant Lions Gate Films, distributed by Paramount Pictures, that bears blatant duplications and similarities to a 2002 copyrighted synopsis and script belonging to Aisha.

60. MADONNA, MOTOROLA for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation, Willful Infliction of Emotional Distress and Mental Anguish. Madonna and Motorola illegally used release and unreleased copyrighted works by the Plaintiff for their ROKR cell phone commercials and internet advertising featured on their web site.

61. MADONNA, BRITNEY SPEARS, MUSIC TODAY INC for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Corporate Theft, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Securities Fraud, Defraud, Willful Violation of International Law, Willful Violation of United Nations Treaties, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Trade Practice Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish.

62. Defendants, Music Today Inc (Madonna’s fan club managers) and Madonna’s fellow Kabbalah Center member and protégé Defendant Britney Spears infringed Aisha’s copyrights. Defendant Jive Recording artist Britney Spears has been sued many times for infringing several writers and singers copyrights. 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. 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. 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. 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.

63. 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 Inc sold copyright infringing items such as Madonna’s “American Life” CD single, “American Life” CD, “American Life” sheet music, “Madonna Remixed and Revisited” and the Madonna children’s book series featuring Adventures Of Abdi, Mr Peabody's Apples, Lots De Casha, Yakov and The Seven Thieves.

64. MADONNA, GUY RITCHIE, LUC BESSON, STEVE CHRISTIAN, VIRGINIE SILLA, PIERRE SPENGLER, SKA FILMS, MAD GUY ENTERTAINMENT INC and EUROPACORP for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish. The Defendants in this segment criminally stole an unreleased movie poster from one of Aisha’s scripts contained in her multi-million dollar copyrighted catalog mentioned above, and illegally used it for Madonna’s husband’s widely panned film “Revolver.” Aisha has yet to see the film “Revolver” to determine if there are any further infringements.

65. MADONNA, CHRISTOPHER CICCONE for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish.

66. Aisha wrote and copyrighted business plans, housing them on her computers. Unbeknownst to her, her computers were later hacked in the above mentioned misconduct via Madonna’s Warner Bros. 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. 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 the Defendants have been paying a commissioned 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. 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.

67. MADONNA, GWENYTH STEFANI, HARAJUKU LOVER MUSIC, PHARRELL WILLIAMS, CHAD HUGO, STAR TRAK and INTERSCOPE RECORDS for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish.

68. Friend and publicly admitted cousin of Defendant 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. Defendant 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. They illegally used 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.” Stefani’s infringing song was pushed out ahead of Aisha’s song, though it was not written, recorded and copyrighted before Aisha’s.

69. Defendant Harajuku Lover Music (ASCAP) publishes “Hollaback Girl” by Gwen Stefani and is owned by said singer. It is also co-published by Star Trak Music owned by Defendants Pharrell Williams and Chad Hugo (ASCAP). Defendant Interscope 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. 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. 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.

70. 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. Furthermore, Ms. Stefani and her producers did not have permission to rip off Queen’s “We Will Rock You.” Defendant Gwen Stefani’s “Hollaback Girl” uses the same beat pattern and structure as Aisha’s 2004 recorded version of “Contemporary Girl.” 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.”

71. 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. Another song on Stefani’s album “Long Way To Go,” featuring Dre from the group Outkast, is eerily similar to previously copyrighted songs by Aisha titled “You Wouldn’t Date A Black Girl,” “You Talk Like A White Girl” and “The N Word.”

72. 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. 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. 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.” 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.

73. In 2004 there was a big scandal in the press regarding their shameful mistreatment and blatant exploitation of a teenager for his beats/music. 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. 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. 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.

74. Zuckoni posted excerpts of his beats on Defendants Pharrell Williams and Chad Hugo’s message boerd 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. 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.

75. 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. 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. 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. 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."

76. 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. 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. 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. 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.

77. NICK CANNON, JIVE RECORDS, ZOMBA RECORDING LLC, SONY BMG, DARREN SHERRILL, JAMES EDWARD JONES, LILLY DARRON KEITH, BOOGOLOGY MUSIC, LIL D MUSIC PUBLISHING and DARREN SHERRILL MUSIC for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Securities Fraud, Defraud, Willful Violation of International Law, Willful Violation of United Nations Treaties, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Trade Practice Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish.

78. Another of Defendant Jive Records artists 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). 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. 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.). Aisha copyrighted these songs a year before Nick Cannon ever wrote and released his song “Can I Live” on Jive Records.

79. 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. 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.” “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. 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 his co-defendants mentioned in this segment. Aisha is concerned about what else Defendant Nick Cannon has ripped off from her copyrighted works for his forthcoming album "Stages" due shortly. If further infringements are found, additional lawsuits will be filed.

80. MADONNA and CALLAWAY ARTS AND ENTERTAINMENT for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Corporate Theft, Invasion of the Right Of Publicity, Invasion of the Right of Privacy, Deceptive Trade Practices, Harassment, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Commit Harassment, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish.

81. 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. 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. 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 therein surfacing in works by the Defendants, with Madonna as the ringleader in the unlawful acts.

82. 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. 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).

83. 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. 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.

84. 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. 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. 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.

85. 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.” 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.

86. 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. 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. 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.

87. 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.” 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." 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.”

88. 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.

88. MADONNA, ANDREWS MCMEEL PUBLISHING for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right Of Publicity, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish.

89. 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.

90. MADONNA, MISSY ELLIOT AND MIRWAIS AHMADZAI for Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Trade Practice Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish. Elliot and Ahmadzai are sued for their part in the willful copyright infringement of the Plaintiff’s song “Contemporary Girl” unlawfully used for the song “American Life” by Madonna and its accompanying remix featuring lyrics and raps by Missy Elliot.

91. MADONNA, DONATELLA VERSACE, VERSACE INC, PRATO VERDE and MARIO TESTINO for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right Of Publicity, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Defraud, Assault, Stalking, Harassment, Terroristic Styled Threats and Behavior, Defamation of Character, Libel, Trade Libel, Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Commit Harassment and Terrorization, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation, Endangerment, Willful Infliction of Emotional Distress and Mental Anguish.

92. 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. Defendant Donatella Versace even referred to the campaign as that of the “Contemporary Woman” when the title of Aisha’s previously released debut song is “Contemporary Girl.”

93. MADONNA, VICTORIA NEWTON, GRAHAM DUDMAN, NICKI WATERMAN, THE SUN NEWSPAPER LTD UK, NEWS GROUP NEWSPAPERS LTD for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Defraud, Harassment, Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Commit Harassment, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish.

94. The above named Defendants are sued for invasion of privacy, willfully infringing the Plaintiff’s copyrighted Sound Off Column, online Diary page, private unreleased scripts and book manuscripts that are apart of her multi-million dollar valued catalog for use in the Sun Newspaper UK, sold in the UK and US. Items from Aisha’s business and personal telephone calls were printed in the Sun under Victoria Newton’s column verbatim, attributed to Madonna and Newton.

95. MADONNA, BUENA VISTA PICTURES, DISNEY, WALT DISNEY PICTURES, WALT DISNEY RECORDS, MICHAEL EISNER, GARY MARSHALL AKA GARRY MARSHALL, GINA WENDKOS, MEG CABOT and SHONDA RHIMES for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right Of Publicity, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Defraud, Assault, Stalking, Harassment, Terroristic Styled Threats and Behavior, Defamation of Character, Libel, Trade Libel, Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Commit Harassment and Terrorization, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation, Endangerment, Willful Infliction of Emotional Distress and Mental Anguish.

96. The above named Defendants are sued for criminally infringing the copyrights of Aisha’s script “Royal Monarchy” for illegal use in Buena Vista/Disney film the “Princess Diaries 2. “ 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." Gina Wendkos, Meg Cabot and Shonda Rhimes are the co-writers of the infringing film. Gary Marshall, brother of Penny Marshall, is a friend, employer and co-star of Madonna (League Of Their Own - 1992). Madonna and Marshall and Madonna and Disney frequently do business together. 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. 26 scenes composing the running time of the film were criminally stolen from Aisha’s already copyrighted script and used without permission to make said Disney film.

97. LIONS GATE FILMS INC, MARK AMIN, KATHERINE FUGATE, JACK AMIEL and MICHAEL BEGLER for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right Of Publicity, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Defraud, Assault, Stalking, Harassment, Terroristic Styled Threats and Behavior, Defamation of Character, Libel, Trade Libel, Willful Violation of Civil Liberties, Unlawful Surveillance, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Commit Harassment and Terrorization, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation, Endangerment, Willful Infliction of Emotional Distress and Mental Anguish.

98. Defendant Coolidge directed a film titled "The Prince And Me" released in 2004 through Defendant Lions 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. 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 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". 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.

99. DAVID BERCUSON for Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Wire Fraud, Securities Fraud, Harassment, Terroristic Styled Threats and Behavior, Defamation of Character, Libel, Conspiracy to Commit Fraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Harassment and Terrorization, Conspiracy to Violate Trade Practice Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Intent to Cause Harm and Loss, Misconduct, Sabotage and Willful Infliction of Emotional Distress and Mental Anguish. Defendant Bercuson is sued for harassing and threatening the Plaintiff when she sought him for legal representation and deliberately did not disclose the serious conflict of interest in this case in that he is an employer of Defendant Warner Bros via clients placed on the label.

100. UNIVERSAL PICTURES, PAUL WEITZ, CHRIS WEITZ, DEPTH OF FIELD, PAUL WEITZ, CHRIS WEITZ, DEPTH OF FIELD for Copyright Infringement, Willful and Malicious Copyright Infringement, Criminal Copyright Infringement, Vicarious Copyright Infringement, Contributory Copyright Infringement, Infringement of the Right of Reproduction, Infringement of the Right to Prepare Derivative Works, Infringement of the Right of Attribution, Infringement of the Right of Display, Infringement of the Right of Distribution, Vicarious Distribution, Willful Alterations, Plagiarism, False Description, False Designation of Origin, Unfair Competition, Misappropriation, Invasion of Privacy, Hacking: Unauthorized Entry Into A Computer, Cyber Based Theft, Computer Fraud, Computer Data Damage, Corporate Theft, Computer Data Tampering, Cyber Stalking, Invasion of the Right of Privacy, Deceptive Trade Practices, Fraud, Common Law Fraud, Constructive Fraud, Extrinsic Fraud, Intrinsic Fraud, Internet Fraud, Mail Fraud, Securities Fraud, Defraud, Willful Violation of Civil Liberties, Willful Violation of International Law, Willful Violation of United Nations Treaties, Willful Violation of Human Rights, Tortuous Interference, Unjust Enrichment, Racketeering, Conspiracy to Commit Fraud, Conspiracy to Defraud, Conspiracy to Commit Mail Fraud, Conspiracy to Violate Copyright Laws, Conspiracy to Violate Privacy Laws, Conspiracy to Violate Fourth Amendment and Civil Rights, Conspiracy to Violate RICO Laws, Conspiracy to Violate United Nations Treaties, Conspiracy to Violate Human Rights, Conspiracy to Violate Trade Practice Laws, Conspiracy to Violate Computer Laws, Collusion, Conversion, Negligence, Negligent Misrepresentation, Reckless Misrepresentation, Misrepresentation by Omission, Falsehood, Trade Secret Theft, Misappropriation of Trade Secrets, Intent to Cause Harm and Loss, Loss of Work Time, Misconduct, Sabotage, Exploitation and Willful Infliction of Emotional Distress and Mental Anguish. The above named Defendants are sued for the criminal, unauthorized use of a hacker procured copy of the Plaintiff’s script “Presidential Dreams” that they have unlawfully filmed and made into “American Dreams” in violation of numerous US and UN Laws.

101. UNIVERSAL PICTURES EXTENSIVE HISTORY OF MISCONDUCT - 20th Century-Fox v. Universal – sued for willful copyright infringement for copying Star Wars., 2. Mike Myers v. Universal Pictures – sued for alleging bullying the well known actor into making a film titled ``Dieter'' with what he deemed a bad script., 3. Flash/ETD v. Universal Music – sued for willful misappropriation and pressuring retailers not to buy from rival, 4. Sara Karloff v. Universal Studios - sued for $10 million for willfully and illegally licensing image of a late actor, 5. Crispin Glover v. Universal – for illegally using his image, footage of him and derivative works in Back To The Future sequels, 6. Daniel Kolton v. Universal Studios – sued for willful copyright infringement for the Music for Hercules: The Legendary Journeys, Xena: Warrior Princess and Young Hercules, 7. Alvin and the Chipmunks v. Universal Studios – sued for breach of contract, 8. James Garner v. Universal – breach of contract and deliberate non-payment, 9. Rodgers & Hammerstein Organization/ Songwriters Guild of America v. Universal – sued for deliberate non-payment of royalties, 10. William Patrick v. Universal/Eddie Murphy – willful copyright infringement for unlawfully using Patrick’s screenplay "Brand New Me" to make the film "The Nutty Professor, " 11. Bela Lugosi Jr. v. Universal Studios – sued for the rights to sell his late father’s image. This action later brought about rights for deceased celebrities and their estates, 12. Hoehling v. Universal – for willful copyright infringement in using his story line to make film without permission, 13. Kubrick v. Universal – for making a deliberate rip off of his film and attempting to release it at the same time, 14. Mae West Estate v. Universal – for deliberate non-payment of royalies.net profit for the film My Little Chicadee, 15. Saban Entertainment v. Universal – sued for exploitation regarding marketing plans for the X-Men, 16. City Studios, Inc. v. Universal – sued for breach of contract, 17. Lebbeus Woods v. Universal for copying the artist’s drawings and using them without permission for profit in the film Twelve Monkeys, 18. Harold Lloyd v. Universal Pictures – sued for willful copyright infringement, 19. Steve Gerber v. Universal – sued for “Howard The Duck,” 20. Lucy Lawless v. Universal – sued by Xena actress for breach of contract and non-payment, 21. Nintendo v. Universal Pictures – sued for deliberately unauthorized use of licensing agreement regarding the well-known video game Donkey Kong, 22. Nichols v. Universal – sued for misconduct, 23. Sony v. Universal – sued for misconduct, 24. Universal was sued by writer for copyright infringement in stealing his work for the TV show Northern Exposure and using it as their basis for the program, 25. Sued by a Hungarian musician for copyright infringement, regarding the willful infringement of his tune "Ma Este Meg Boldog Vagyok.”

PROTECTIVE ORDER

102. 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

103. 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.” 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.

104. 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. 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

105. 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. 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.

106. 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. 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:

107. The Plaintiff requests the Defendants and their associates be made to permanently desist from stealing from the Plaintiff's works.

108. The Plaintiff requests a permanent injunction, recalling and delivery of all infringing works for destruction.

109. The Plaintiff requests a permanent injunction against all planned, in production and or completed future releases containing the Plaintiff's work.

110. Madonna A/K/A Madonna Ritchie - $500,000,000 in compensatory and punitive damages.
111. Bertram Fields - $100,000,000 in compensatory and punitive damages.
112. Guy Oseary - $75,000,000 in compensatory and punitive damages.
113. Guy Ritchie - $50,000,000 in compensatory and punitive damages.
114. Mad Guy Entertainment - $50,000,000 in compensatory and punitive damages.
115. Ska Films - $10,000,000 in compensatory and punitive damages.
116. Luc Besson - $50,000,000 in compensatory and punitive damages.
117. Europacorp - $50,000,000 in compensatory and punitive damages.
118. Steve Christian - $30,000,000 in compensatory and punitive damages.
119. Virinie Silla - $30,000,000 in compensatory and punitive damages.
120. Pierre Spengler - $30,000,000 in compensatory and punitive damages.
121. Christopher Ciccone - $100,000,000 in compensatory and punitive damages.
122. Mark Morgan - $75,000,000 in compensatory and punitive damages.
123. Maverick Records - $300,000,000 in compensatory and punitive damages.
124. Maverick Films - $300,000,000 in compensatory and punitive damages.
125. Webo Girl Music Publishing - $100,000,000 in compensatory and punitive damages.
126. Warner Bros Records - $100,000,000 in compensatory damages and $100,000,000 in punitive damages.
127. Warner Vision - $30,000,000 in compensatory and punitive damages.
128. Warner Chappell Music Publishing - $30,000,000 in compensatory and punitive damages.
129. WB Music Corp - $30,000,000 in compensatory and punitive damages.
130. Time Warner AOL - $300,000,000 in compensatory and punitive damages.
131. Motorola - $100,000,000 in compensatory and punitive damages.
132. Disney - $500,000,000 in compensatory and punitive damages.
133. Buena Vista Pictures - $300,000,000 in compensatory and punitive damages.
134. Walt Disney Pictures - $200,000,000 in compensatory and punitive damages.
135. Walt Disney Records - $50,000,000 in compensatory and punitive damages.
136. Michael Eisner - $500,000,000 in compensatory and punitive damages.
137. Jerry Bruckheimer - $200,000,000 in compensatory and punitive damages.
138. Jerry Bruckheimer films - $30,000,000 in compensatory and punitive damages.
139. Charles Howard - $30,000,000 in compensatory and punitive damages.
140. Sunil Nayar - $30,000,000 in compensatory and punitive damages.
141.Steven Maeda - $30,000,000 in compensatory and punitive damages.
142. Michael Ostrowski - $30,000,000 in compensatory and punitive damages.
143. Corey Miller - $30,000,000 in compensatory and punitive damages.
144. Ildy Modrovich - $30,000,000 in compensatory and punitive damages.
145. Brian Davidson - $30,000,000 in compensatory and punitive damages.
146. Marc Dube - $30,000,000 in compensatory and punitive damages.
147. Gary Marshall A/K/A Garry Marshall - $350,000,000 in compensatory and punitive damages.
148. Gina Wendkos - $150,000,000 in compensatory and punitive damages.
149. Meg Cabot - $50,000,000 in compensatory and punitive damages.
150. Shonda Rhimes - $150,000,000 in compensatory and punitive damages.
151. The Sun Newspaper (UK) - $150,000,000 in compensatory and punitive damages.
152. News Group Newspapers LTD - $150,000,000 in compensatory and punitive damages.
153. Victoria Newton - $35,000,000 in compensatory and punitive damages.
154. Charles Dudman - $15,000,000 in compensatory and punitive damages.
155. Nicki Waterman - $15,000,000 in compensatory and punitive damages.
156. Stuart Prince - $30,000,000 in compensatory and punitive damages.
157. Steven Klein - $30,000,000 in compensatory and punitive damages.
158. Liz Rosenberg - $70,000,000 in compensatory and punitive damages.
159. Callaway Arts and Entertainment - $100,000,000 in compensatory and punitive damages.
160. Versace - $30,000,000 in compensatory and punitive damages.
161. Mario Testino - $15,000,000 in compensatory and punitive damages.
162. Britney Spears - $30,000,000 in compensatory and punitive damages.
163. Missy Elliot - $10,000,000 in compensatory and punitive damages.
164. Mirwais Ahmadzai- $30,000,000 in compensatory and punitive damages.
165. Jive Records - $50,000,000 in compensatory and punitive damages.
166. Sony BMG - $50,000,000 in compensatory and punitive damages.
167. Interscope Records - $100,000,000 in compensatory and punitive damages.
168. Patriot Pictures - $50,000,000 in compensatory and punitive damages.
169. Arclight Films - $50,000,000 in compensatory and punitive damages.
170. Michael Mendelsohn - $50,000,000 in compensatory and punitive damages.
171. Martha Coolidge - $100,000,000 in compensatory and punitive damages.
172. John Quaintance - $50,000,000 in compensatory and punitive damages.
173. Susan Jensen - $50,000,000 in compensatory and punitive damages.
174. Jessica O’Toole - $50,000,000 in compensatory and punitive damages.
175. Amy Rardin - $50,000,000 in compensatory and punitive damages.
176. Jonas Akerlund - $50,000,000 in compensatory and punitive damages.
177. Music Today Inc - $50,000,000 in compensatory and punitive damages.
178. Andrews McMeel Publishing - $50,000,000 in compensatory and punitive damages.
179. David Bercuson - $50,000,000 in compensatory and punitive damages.
180. Gwenyth Stefani - $50,000,000 in compensatory and punitive damages.
181. Harajuku Lover Music - $50,000,000 in compensatory and punitive damages.
182. Pharrell Williams - $50,000,000 in compensatory and punitive damages.
183. Chad Hugo - $50,000,000 in compensatory and punitive damages.
184. Star Trak - 50,000,000 in compensatory and punitive damages.
185. Nick Cannon - $50,000,000 in compensatory and punitive damages.
186. Darren Sherrill - $50,000,000 in compensatory and punitive damages.
187. Jones James Edward - $50,000,000 in compensatory and punitive damages.
188. Lilly Darron Keith - $50,000,000 in compensatory and punitive damages.
189. Boogology Music - $50,000,000 in compensatory and punitive damages.
190. Lil D Music Publishing - $50,000,000 in compensatory and punitive damages.
191. Darren Sherrill Music - $50,000,000 in compensatory and punitive damages.
192. Lions Gates Films - $50,000,000 in compensatory and punitive damages.
193. Mark Amin - $50,000,000 in compensatory and punitive damages.
194. Katherine Fugate - $50,000,000 in compensatory and punitive damages.
195. Jack Amiel - $50,000,000 in compensatory and punitive damages.
196. Michael Begler - $50,000,000 in compensatory and punitive damages.
197. Jonas Akerlund - $50,000,000 in compensatory and punitive damages.
198. Universal Pictures - $2,000,000,000 in compensatory and punitive damages.
199. Paul Weitz - $500,000,000 in compensatory and punitive damages.
200. Chris Weitz - $500,000,000 in compensatory and punitive damages.
201. Depth Of Field – $500,000,000 in compensatory and punitive damages.
202. Joe Henry - $5,000,000 in compensatory and punitive damages.
203. Johan Renck - $5,000,000 in compensatory and punitive damages.
204. Prod4ever - $5,000,000 in compensatory and punitive damages.
205. Chime Interactive - $5,000,000 in compensatory and punitive damages.
206. Christian Karlsson and Pontus Winnberg A/K/A Bloodshy and Avant- $15,000,000 in compensatory and punitive damages.
207. Legal fees - costs of this action, including interest.
208. Any other relief the Court deems fit.

Dated: December 13, 2005

By: ________________________
Aisha Goodison
P.O. Box 190073
Miami Beach, Florida 33119-0073
law@sonustar.com