Appendix — Ardito v. NBC Universal, Inc. (No. 07-1142)

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4 Supreme Count, U.S.

NO. 0

O71 147 JAN 2 ~ 2008

isthe OFFIGE OF THE CLEAK

UNITED STATES SUPREME COURT

CHIVALRY FILM PRODUCTIONS and

JOSEPH ARDITO Individually,

Petitioner,

~-V-

NBC UNIVERSAL, INC., IVERSAL PICTURES

COMPANY, INCORPORATED, UNIVERSAL

STUDIOS, INC., UNIVERSAL STUDIOS LLC,

UNIVERSAL CITY STUDIOS LLLP, UNIVERSAL

CITY STUDIOS, INC., UNIVERSAL CITY

STUDIOS PRODUCTIONS LLLP, DREAMWORKS,

L.L.C., DREAMWORKS L.L.C. D/B/A

DREAMWORKS SKG, DREAMWORKS

PRODUCTIONS LLC, DREAMWORKS, INC.,

TRIBECA PRODUCTIONS INC., AMY SAYRES,

NANCY TENENBAUM, NANCY TENENBAUM

FILMS, INC., TWENTIETH CENTURY FOX FILM

CORPORATION, EVERYMAN PICTURES, JAY

ROACH, AND JAY ROACH D/B/A EVERYMAN

PICTURES,

Respondents,

On Petition For WRIT OF CERTIORARI TO

THE UNITED STATES COURT OF APPEALS

For the SECOND CIRCUIT

Pro Se: Joseph Ardito

Petitioner

97-12 76> Street

Ozone Park, NY 11416

Tel. No. (917) 435-2820

App. 1

UNITED STATES COURT OF APPEALS

FOR THE SECOND CIRCUIT

SUMMARY ORDER

07-0665-cv

MANDATE

(Filed Oct. 04, 2007)

Catherine O'Hagan Wolfe, Clerk

At a stated term of the Untied States Court of

Appeals for the Second Circuit, held at the Daniel

Patrick Moynihan United States Courthouse, 500

Pearl Street, in the City of New York, on the 4* day

of October, two thousand seven.

PRESENT:

HON. PIERRE N. LEVAL,

HON. ROBERT D. SACK,

Circuit Judges,

HON. NICHOLAS G. GARAUFIS,"*

District Judge.

Chivalry Film Productions, Joseph Ardito,

Plaintiffs-Appellants,

* The Honorable Nicholas G. Garaufis of the United States District Court

fot he Eastern District of New York, sitting by designation.

App. 2

NBC Universal, Inc., et al.

Defendants-Appellees.

-—]| = se es seeaeseeee e#eeeeass_ss_28# = eo we weweeee

Appearing for Appellants: Joseph Ardito, pro se,

Ozone Park, N.Y.

Appearing for Appellees: Mark a. Tamoshunas,

Stephen F. Huff, Tom J.

Ferber, Pryor Cashman

LLP, New York, NY

Appeal from a judgment of the United States

District Court for the Southern District of New York

(Gerard E. Lynch, Judge).

UPON DUE CONSIDERATION, IT IS

HEREBY ORDERED, ADJUDGED AND DECREED

that the judgment of the district court be, and it

hereby is AFFIRMED.

Plaintiff-appellant Joseph Ardito, representing

himself pro se and purporting to represent Chivalry

Film Productions, an individual proprietorship,

appeals from a December 22, 2006, judgment of the

United States District Court for the Southern

District of New York (Gerard E. Lynch, Judge)

granting summary judgment to the defendants-

appellees as to all of the appellants’ claims pursuant

to Federal Rule of Civil Procedure 56. We assume

the parties’ and counsel’s familiarity with the facts

App. 3

and procedural history of this case and the scope of

the issues presented by this appeal.

We affirm the judgment of the district court

for substantially the reasons set forth in its opinion

and order, Chivalry Film Productions v. NBC

Universal, Inc., No. 05 CV 5627, 2006 U.S. Dist.

LEXIX 92956, 2006 WL 3780900 (S.D.N.Y. Dec. 22,

2006).

The judgment for the District Court is hereby

AFFIRMED.

FOR THE COURT:

Catherine O’Hagan Wolfe, Clerk

of the Court

/s/ Lucille Carr

A TRUE COPY

Catherine O’Hagan Wolfe, Clerk

By:_/s/ Lyneth Rodriguez

Deputy Clerk

App. 4

05Civ.5627(GEL)

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

hy ge ele: Rh a A aa OCA Xx

CHIVALRY FILM PRODUCTIONS

and JOSEPH ARDITO,

Plaintiffs,

NBC UNIVERSAL, INC., et al.,

Defendants.

CE eee ee ee eee x

USDC SDNY DOCUMENT

ELECTRONICALLY FILED

DOC #:_71

Date filed: 12/22/06

94077

Dec 27, 2006 -9:00 AM [stamp]

OPINION AND ORDER

Joseph Ardito, pro se

Stephen F. Huff, Tom J. Ferber,

Mark a Tamoshunas, Richard J. Purcell,

Prior Cashman Sherman & Flynn LLP

New York, NY, for defendants.

GERARD E. LYNCH, District Judge:

App. 5

In this copyright infringement action, pro se

plaintiff Joseph Ardito charges that defendants, a

number of motion picture production and

distribution companies, infringed his copyrightst

Defendants move for summary judgment dismissing

plaintiffs claim, arguing that the allegedly infringing

films are independently created works that no

reasonable juror could find substantially similar to

plaintiffs copyrighted material. Defendants’ motion

will be granted.

Plaintiff charges that two movies produced

and distributed by certain of the defendants, Meet

the Parents and its sequel Meet the Fockers, infringe

his copyrights in several versions of a novel and

screenplay entitled variously The Tenant or The

Dysfunctionals (hereafter collectively “The Tenant’).

To establish copyright infringement, plaintiff

must demonstrate “(1) ownership of a valid

the work that are original.” Feist Publ’ns, Inc. v.

Rural Tel. Serv. Co., 499 U.S. 340, 361 (1991); see

Matthew Bender & Co. v. West Publ’g Co., 158 F.3d

693, 699 (2d Cir. 1998). Copying may be established

either through direct evidence of copying or through

indirect evidence, including “similarities that are

probative of copying between the works.” Hogan v.

DC Comics, 48 F.Supp.2d 298, 308 (S.D.N.Y. 199),

quoting Castle Rock Entm’t, Inc. v. Carol Publ’g

' On January 11, 2006, this Court dismissed plaintiff's various other

causes of action at the pleading stage. Chivalry Film Prods. v. NBC

Universal, Inc., No. 0S Civ. 5627, 2006 WL 89944 (S.D.N.Y. Jan. 11,

2006). In this Opinion, as in that one, the Court refers to plaintiff in the

singular, since the co-plaintiff named in the pleading is a sole

proprietorship having no legal existence independent of Ardito himself.

See id. at *1 n.1.

App. 6

Group, Inc., 150 F.3d 132, 137 (2d Cir. 1998).

Defendants do not dispute that plaintiff holds valid

copyrights in the various versions of The Tenant.

They argue, however, that no reasonable finder of

fact could find copying, because the works are not

substantially similar, and because plaintiff has failed

to raise a genuine issue of fact with respect to

defendants’ claim of independent creation.

Defendants are right on both grounds.t

Summary judgment may be granted ona

trier of fact could find the works substantially

similar.” Williams v. Crichton, 84 F.3d 581, 587 (2d

Cir. 1996) (citation and internal quotation marks

omitted). That is precisely the case here.

The works at issue could not be more different

in “total concept and feel.” Green v. Lindsay, 885

F.Supp. 469, 481-82 (S.D.N.Y. 1992). Defendants’

movies are farcical situation comedies in which a

young man encounters various embarrassing

calamities while trying to win over the parents of his

fiancée, and in which the parents of the engaged

couple, who represent opposing cultural and political

stereotypes, seck to become comfortable with each

* Defendants also claim there is no evidence that any defendant had

access to The Tenant. Indeed, plaintiff offers no evidence whatsoever

that any defendant ever saw any of his works, asserting only that while

visiting Los Angeles in 1998, and staying with a friend of his attorney, his

bags were broken into and ransacked by unknown individuals, and

“(vjarious project outlines were missing.” (P_Rule 56.1 Stmt. 48.) Even

assuming that a thief took or read a version of Zhe Tenant (something not

expressly asserted in plaintiff's statement), there is absolutely no

evidence that any defendant ever came into possession of that material.

Nevertheless, because plaintiff may not have had an adequate opportunity

to take discovery of defendants on this issue, the Court declines to rely on

the absence of evidence of access as a ground for summary judgment.

App. 7

other. In the tradition of slapstick comedies,

exaggerated disasters ensue from the encounters

among the protagonists, but the tone is light, no one

suffers lasting damage, and the situations resolve

happily with the former antagonists achieving

grudging mutual respect and accommodation. The

works are designed as light entertainment for a

mainstream audience.

Plaintiffs work is more in the violent horror

genre. Any humor in the work is, in plaintiffs own

words, “sick humor.” (Ferber Decl. Ex. F.) The

prologue to the novel version warns that “fiJf you find

the material contrary to your taste, vile, abusive and

pornographic, the author has achieved his objective”

(id. Exs. F, G), and the work more or less lives up to

that claim. The work follows a common theme in the

horror genre, that of the unwitting “normal”

protagonist thrown together with a group of violent

sociopaths, who torment and torture him. The plot

involves three brothers, their sister and their father,

whose back story involves extraordinary intrafamily

violence and abuse, depicted at considerable length.

(See, e.g., id. Ex. J at 20-23.) The eponymous tenant

rents a room in the house from one of the brothers,

who repeatedly beat and abused him, in addition to

engaging in extreme violence against various other

characters. (See, e.g., id. at 55-56, 77-78, 101-105,

135-140.) Eventually, the three brothers are brought

to justice and committed to a psychiatric hospital,

and the police suspect the tenant of murdering the

father, who in fact commits suicide. (See id. at 137-

40.) The treatment is unrelentingly horrific and is

presumably aimed at the popular niche market for

graphic tales of violence.

App. 8

Plaintiff attempts to show similarity by

providing a long chart of alleged similarities between

specific scenes in his work and defendants’. These

parallels, however, involve the most trivial and

generic incidents. For example, in Meet the Parents

the fiancée’s father ridicules his prospective son-in-

law’s car, and in The Tenant the abusive landlord is

critical of his tenant’s vehicle. (See Artido Decl. at

6.) Even if the scenes were otherwise similar, there

is nothing original in either scene; the events are

simply minor, generic set pieces establishing the

relationships between the parties through common

experiences relating to cars. In any event, the scenes

are not even that similar. Apart from the differences

in tone, the father in defendants’ film sneers at the

make and color of the car, thus making his

daughter’s suitor feel embarrassingly outclassed in

wealth and taste, while in plaintiffs work the villain

objects to the protagonist’s choice of a standard shift,

because he might “need to borrow [the tenant’s] car,”

thus establishing his assumed power over his

tenant’s property. (Id.) The scenes are thus

strikingly different. Plaintiff offers scores of such

specious similarities, all of which can be similarly

deconstructed.

The characters, pace, settings, themes and

plots of the two sets of materials are in fact so

extraordinarily different that plaintiff is reduced to

arguing that copying can be proved by the absence of

similarity, alleging that defendants “blatantly went

through extremes in revisions and manipulation in

an attempt to conceal and subterfuge said crime by

revising said screenplay.” (Compl. 4] 1960.) But this

claim is self-defeating. As the Second Circuit has

held, “[e]ven if an alleged copy is based on a

App. 9

copyrighted work, ‘a defendant may legitimately

avoid infringement by intentionally making

sufficient changes in a work which would otherwise

be regarded as substantially similar to that of the

plaintiffs.” Eden Toys, Inc. v. Marshall Field & Co.,

675 F.2d 498, 501 (2d Cir. 1982), quoting Warner

Bros. v. Am. Broad. Cos., 654 F.2d 204, 210 (2d Cir.

1981) (additional citation omitted). In short, no

reasonable fact-finder could conceivably find the

works so substantially similar as to warrant an

inference that one was copied from the other.

Summary judgment is also appropriate

because defendants can establish an independent

source for their films pre-dating The Tenant.

Defendants’ works do not pretend to be wholly

original. They are based on an earlier film, also

called Meet the Parents, that was made and

copyrighted in 1991, and to which defendants

acquired the rights in 1994. (See Ferber Decl. Ex. E;

Tamoshunas Decl. Ex. C.) Plaintiffs earliest

Decl. { 10; id. Ex. A.) Unlike The Tenant, the earlier

version of Meet the Parents shares a similar theme

and tone with defendants’ film; the similarity

extends to the very names of the principal characters

in the two versions. While plaintiff attempts to

discredit defendants’ claim by pointing to various

differences between the two versions of Meet the

Parents, those differences are far less striking than

the differences between either version and plaintiff's

work, and the similarities between the two versions

of Meet the Parents are far more striking. No

reasonable fact-finder could conclude that the

challenged works derived from The Tenant, rather

than from the earlier Meet the Parents film and

App. 10

screenplay. Summary judgment is appropriate

where a plaintiff fails to offer evidence sufficient to

raise a factual question about a defendant’s proof of

independent creation, including “re-creation” from an

independent pre-exisiting source. See Novak v. Nat'l

Broad. Co., 760 F. Supp. 47, 48 (S.D.N.Y. 1991).

Accordingly, defendants’ motion for summary

judgment is granted.

SO ORDERED.

Dated: New York, New York

December 22, 2006

/s/ Gerard E. Lynch

GERARD E. LYNCH

United States District Judge

App. |1

05Civ.5627(GEL)

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

ep er A CPR igs Mh ee X

CHIVALRY FILM PRODUCTIONS

and JOSEPH ARDITO,

Plaintiffs,

NBC UNIVERSAL, INC., et al.,

Defendants.

USDC SDNY

DOCUMENT ELECTRONICALLY FILED

DOC #:

Date filed: 1/11/06

OPINION AND ORDER

Joseph Ardito, pro se

Stephen F. Huff, Tom J. Ferber,

Mark a Tamoshunas, Richard J. Purcell,

Prior Cashman Sherman & Flynn LLP

New York, NY, for defendants.

GERARD E. LYNCH, District Judge:

App. 12

Joseph Ardito$’ brought this case pro se,

charging a variety of defendant entities and

individuals in the movie business with copyright

infringement, violations of the federal racketeering

statutes, and a number of other tortuous acts.

Defendants move for dismissal on a number of

grounds. The motion will be granted in part and

denied in part.

The gravamen of plaintiffs action lies in

extremely lengthy, its factual allegations, which for

purposes of the present motion must be accepted as

true, are fairly straightforward. Ardito asserts that

he is the author of a copyrighted screenplay or

screenplays, entitled “The Tenant” and/or “The

Dysfunctionals,” described as “comic satires

ridiculing dysfunctional families.” (Compl. { 1940.)

The complaint charges that defendants infringed

Ardito’s copyrights by copying “the same identical

synopsis, theories, character analysis, ideas, etc.” of

his screen play(s) in producing their popular films,

“Meet the Parents” and its sequel “Meet the

Fockers.” (Id. at | 1942.) Unlike many copyright

plaintiffs, Ardito does not allege that he ever

submitted his screen play to any of the defendants

for consideration. Rather, he appears to allege that

* The complaint is brought in the names of Ardito and of Chivalry Film

Productions, which is identified as a “sole proprietorship duly

orgamzed...under...the laws of the State of New York” and wholly

owned by Ardito. (Compl. ff 4, 7.) Such a proprietorship, under New

York law, has no legal entity apart from that of its proprietor. See, e.g.,

Mattel, Inc.v. Adventure Apparel, 00 Civ. 4085 (RWS), 2001 WL

1035140, at *5 (S.D.N.Y. Sept. 7, 2001) (“[The] sole proprietorship [is]

owned by [defendant] and, therefore, [it] is not a separate legal entity

capable of being sued.”) Thus, Ardito is cffectively the sole plaintiff, and

will be so referred to in this Opinion.

App. 13

his work was not merely metaphorically stolen from

him in a 1998 burglary. (Id. at |; see also P. Mem.

3.)

Certain allegations in the complaint appear to

cast doubt on the viability of plaintiff's claim.

Ardito’s description of what was copied suggests that

the resemblance between the works is at the level of

uncopyrightable general concepts. Indeed, the

complaint suggests that the actual expression in the

allegedly infringing works may be quite different

from that of the copyrighted works, in that

defendants are said to have gone “through extremes

in revisions and manipulation” in order to conceal

the origin of their ideas “by revising [his]

screenplay.” (Compl. 41960.) Nevertheless,

construing the complaint liberally as befits a pro se

filing, see Burgos v. Hopkins, 14 F.3d 787, 790 (2d

Cir. 1994), plaintiff clearly states a claim for

otherwise.

Defendants do argue, however, that Count

One should be dismissed as barred by the statute of

limitations, to the extent that it asserts claims for

acts pre-dating June 16, 2002.

Defendants are correct about several

propositions. First, the statute of limitations for

507(b); Kresgos v. Associated Press, 3 F.3d 656, 661

(2d Cir. 1993). Second, as the complaint in this case

was filed on June 16, 2005. any claim that accrued

before June 16, 2002, is time-barred. Third,

although there is some disagreement among the

courts as to when a claim for copyright infringement

accrues, Judge Kaplan’s thorough analysis in

App. 14

Auscape Int'l v. Nat'l Geographic Soc’y, No. 02 Civ.

6441 (LAK), 2004 WL 1798130, at *4-*8 (S.D.N.Y

Aug. 12, 2004), is persuasive that the cause’of action

accrues on the date of the infringement, not on the

date that the infringement is discovered. At any

rate, even courts following the contrary “discovery

rule” hold that the date of accrual is the date

“plaintiff knew or should have known of the

infringement.” Sapon v. DC Comics, No. 00 Civ. 8892

(WHP), 2002 WL 485730, at *5(S.D.N-Y. mar. 29,

2002) (emphasis added).** Fourth, plaintiff claims

infringement by two films, “Meet the Parents” and

“Meet the Fockers.” The former film was released on

or about October 6, 2000. Any infringement by the

creation of that film occurred no later than that date,

and there can be little doubt that Ardito should have

known of any infringement by “Meet the Parents’ at

or shortly after the highly-publicized release of that

film.

Thus, it appears clear that plaintiff will be

unable to recover for infringements committed by

“Meet the Parents.” Count One, however, also

** Defendants’ brief blandly cites Auscape for the proposition that a claim

for copyright infringement accrues on the date of the infringement, and

derides plaintiff's argument in favor of accrual on discovery as “plainly

incorrect in light of the holding in Auscape.” (D. Reply 2.) But Auscape

is not binding authority, and its holding represents onc sidc, and the

minority side at that, of an issue hotly disputed by various courts. This

Court expects a higher standard of candor from members of its bar.

Counsel cannot fairly be accused of deception; Judge Kaplan’s careful

discussion in Auscape fairly lays out the conflicting authority and the

arguments on both sides, and it should certainly be expected that the

Court would review the cited authority. But particularly when dealing

with a lay adversary, who might not be alerted by the citation to read the

case and discover the contrary authority, lawyers should display greater

accuracy and candor in stating the law by expressly acknowledging the

existence of contrary authority.

App. 15

charges defendants with an infringement in

connection with “Meet the Fockers,” which was

released in 2004. Thus, Count One may not be

dismissed, and in the absence of a factual record, it is

premature for the Court to attempt to carve up the

claim by making definitive rulings about the precise

contours of potential hability on that count.

Plaintiffs remaining claims, however, have

less validity. Cont Two asserts a claim for unjust

enrichment. This appears merely to restate the

claim that defendants made money by legal or

equitable rights that are equivalent to any of the

exclusive rights within the general medium of

expression and come within the subject matter of

U.S.C. § 301 (a). The Second Circuit has derived

from this statute a two-part test for Copyright Act

preemption of state law claims. “The Copyright Act

exclusively governs a claim when: (1) the particular

work to which the claim is being applied falls within

the type of works protected by the Copyright Act

under 17.U.S.C. §§ 102 and 108 [‘the subject matter

requirement,” and (2) “the claim seeks to vindicate

legal or equitable rights that are equivalent to one of

the bundle of exclusive rights already protected by

scope requirement’].” Briarpatch Ltd., L.P. vl

Phoenix Piectures, Inc., 373 F3d 296, 305 (2d Cir.

2004), citing 17 U.S.C. §301(a) and Nat’l Basketball

Ass’n v. Motorola, Inc., 105 F.3d 841, 848 (2d Cir.

1997). “In other words, state law claims that are

substantively redundant of Copyright Act claims are

preempted.” Sharp v. Patterson, No. 03 Civ. 8772

(GEL),2004 WL 2480426, at *7 (S.D.N.Y. Nov. 3,

2004). Since Count Two seeks recovery under state

App. 16

law for the same acts that constitute the alleged

infringement of copyright, it is pre-empted by the

(stating that in determining whether a state law

claim is preempted, the court examines what the

plaintiff “seeks to protect, the theories in which the

matter is protected, and the rights sought to be

enforced,” and “taking a restrictive view’ of extra

elements that might make a state law claim different

from a federal one); Weber v. Geffen Records, Inc., 63

F.Supp. 2d 458, 462 (S.D.N.Y. 1999)(“Whether a

state law claim is preempted depends on whether it

is derivative of a copyright claim or is based on an

“extra element” beyond those of a copyright claim.”);

Netzer v. Continuity Graphic Assocs., Inc., 963 F.

Supp. 1308, 1322 (S.D.N.Y. 1977)(‘[Plaintiffs’] claim

of unjust enrichment is preempted by the federal

Count Three alleges violations of the RICO

statute, 18 U.S.C. §§ 1961-1964. Courts are skeptical

of plaintiffs’ efforts to turn ordinary civil litigation

into racketeering claims. Goldfine v. Sichenzia, 118

F. Supp. 2d 392, 397-98 (S.D.N.Y. 2000). At the

same time, RICO complaints must be sustained if

they state a claim, however farfetched, on which

relief may be granted if the allegations of the

complaint can be proved. Here, defendants argue

that the complaint fails to state a claim because the

predicate acts alleged to constitute a pattern of

racketeering activity are mail and wire fraud claims,

and thus subject to the particular pleading

requirements of Rule 9(b), Fed. R. Civ. P. See

Anatian v. Coutts Bank (Switzerland) Ltd., 193 F.3d

85, 88 (2d Cir. 1999) (affirming dismissal of claim of

RICO predicate acts of mail and wire fraud for

App. 17

failure to plead with sufficient particularity).

Defendants are clearly right that plaintiff utterly

fails to identify any details of the alleged fraud.

Moreover, to the extent the alleged “fraud” can be

discerned, it appears that Ardito alleges that

defendants committed fraud by presenting their

films as their copyrighted works, without

acknowledging that the films infringed his copyright.

(Comp. 1960.) This is merely an effort to turn a

simple copyright claim into mail or wire fraud, and

will not suffice.

However, defendants ignore the allegation in

the complaint that allege that their “pattern of

racketeering consisted of Defendants aiding and

abetting the commission of countless acts of federal

Interstate Transportation of stolen property obtained

by acrime,” citing 18 U.S.C. §2314. (Compl. { 1961.)

In light of plaintiffs claim that his manuscript was

literally stolen from him (id. at 41940), plaintiff

appears to have alleged a number of crimes other

than fraud, specifically a number of acts of interstate

transportation of stolen property.tt Nevertheless, the

RICO count must be dismissed for a different reason,

because the complaint fails to allege a RICO

“pattern.” A pattern requires a showing of

“continuity,” or the threat thereof._H.J. Inc. v.

Northwestern Bell Tel. Co., 49 U.S. 229, 240 (1989).

Here, plaintiff alleges nothing more than a single,

limited scheme to exploit his copyrighted work by

committing infringing his copyrights. The only

viable alleged predicate acts, the interstate

transportation of his stolen manuscript, must have

" Although plaintiff does not explicitly allege that the property had a

value greater than $5000, as required by § 2314, his claims for damages

indicates a belief that the works had a substantial value.

App. 18

taken place, if at all, within a limited period between

the theft in August 1998 and the release of the first

completed film in 2000. A scheme of such limited

purpose, accomplished in such a limited period,

cannot constitute a RICO pattern, and thus, count

Three is dismissed.

Count Four alleges common-law fraud,

claiming that defendants committed a fraud on the

by presenting the challenged films as their original

works without disclosing that they were copied from

plaintiff. This claim fails, because plaintiff has no

standing to object to any such fraud. To recover

damages for fraud, a plaintiff must prove the he

reasonably relied on misrepresentations made to

him. Plaintiff does not allege that defendants

misrepresented anything to him, and as the author of

the allegedly infringed works, he could not

conceivably have relied upon any claim that the

infringing works were original. See Barnhart v.

Fderated Dep’t Stores, Inc., No. 04 Civ. 3668, 2005

WL 549712 (S.D.N.Y. Mar 8, 2005)(finding that

plaintiff had not alleged any reliance and dismissing

claim that defendants falsely filed a claim with the

internet information about defendants’ films (P.

Mem.5) does not change this conclusion. Defendants’

motion to dismiss is granted as to Count Four.

Count Five charges unfair competition in

violation of the Lanham Act. This count also fails to

state a claim distinct from the copyright

infringement charge. The Supreme Court has held

** Plaintiff tries to distinguish this case as relating to a song rather than a

screenplay. (See P.Mem.5.) The legal principles involved do not depend

on the nature of the copyrighted material.

App. 19

that the Lanham Act protects only “the producer of

...tangible goods that are offered for sale, and

not...the author of any idea, concept, or

communication embodied in those goods.” Dastar

Corp. v. Twentieth Century Fox Film Corp., 539 U.S.

23, 37 (2003). The right to copy creative works, with

or without attribution, is the domain of copyright,

not of trademark or unfair competition. Id. at 33.

“The failure to credit the true author of a copyrighted

work is not a false designation of origin, but a

violation of copyright.” Freeplay Music, Inc. v. Cox

Radio, Inc.,__ F.Supp.2d__,__, No. 04 Civ. 5238

(GEL), 2005 WL 1500898m at *3-*4(S.D.N_Y. June

23, 2005). Plaintiff has failed to state a claim of

unfair competition under the Lanham Act.

Finally, although plaintiff has thus far

undertaken to represent himself without the services

of an attorney, in Count Six he demands attorney’s

fees. This demand does not state a separate cause of

action, but merely requests a form of relief in

connection with plaintiffs copyright claim. To the

extent that plaintiff attempts to assert a separate

cause of action, Count Six is dismissed; however, the

request for attorneys’ fees remains an aspect of the

requested damages, should plaintiff incur any such

fees, and should he prevail in the case. _

In addition to the various arguments

addressed to specific counts of the complaint,

defendants also move to dismiss the entire complaint

on grounds that its length and prolixity violates Rule

8, Fed. R. Civ. P., which requires that a complaint

contain “a short and plain statement of the claim,”

and that “each averment of a pleading shall be

simple, concise, and direct.” Fed. R. Civ. P. 8(a)(2),

8(e)(1). On the surface, the argument has

App. 20

considerable merit. The complaint, exclusive of

exhibits, runs to 149 pages and 1983 paragraphs.

However, the vast bulk of the complaint (pages 3

through 136, and 99-1939), consists of a series of

repetitious and alternative allegations of every

conceivable description of each defendant, its

addresses and offices, and its potential relationships

with every other defendant. Even to require each

defendant to affirm or deny these mostly irrelevant

descriptions would impose a substantial burden. In

contrast, the core allegations of the copyright

infringement are relatively compact and clear,

especially by the standards of pro se pleading.

Accordingly, rather than dismiss the complaint, and

require the plaintiff to replead the legitimate

interests of the defendants can be accomplished by

striking the redundant and unnecessary portions of

the complaint. Defendants will not need to answer

allegations that are stricken; nor, of course, will they

be required to answer claims that have been

dismissed. To the extent that the addresses or

corporate relationships of the defendants are

relevant to the case, such information can be sought

in discovery.

Finally, defendant Twentieth Century Fox

Film Corporation originally moved to dismiss the

complaint as to it for failure of service; it is now

conceded that plaintiff has cured this failure, and

that motion has accordingly been withdrawn.

(D.Reply 1 n.2.)

CONCLUSION

Accordingly, for the reasons set forth above,

defendants’ motion to dismiss is granted with respect

App. 21

to Count Two through Six, and those claims are

dismissed with prejudice. The motion to dismiss is

denied with respect to Count One. Paragraphs 9

through 1939 are stricken, except for such

paragraphs as allege that any defendant was a

producer and/or distributor of the movies “Meet the

Parents” and “Meet the Fockers.”

SO ORDERED.

Dated: New York, New York

January 11, 2006

/s/ Gerard E. Lynch

GERARD E. LYNCH

United States District Judge

App. 22

Aug 03 06 1:40a Chivalry Film Productions

Dear Judge Lynch,

This fax is a request for a 2"4 extension of time in

opposition to defendant’s summary judgment motion

due on August 7th, 2006. This plaintiff needs an

additional 2 wecks of time in formulating and

completing his opposition.

In the process of reviewing the defendants

“Irrefutable Documentary Evidence” and in the

process of reviewing plaintiffs finding which are not

even complete.

The plaintiff in this action will now state that the

projects entitled “Meet the Parents and Meet the

Fockers” are in fact a product of Plaintiffs Stolen

Federal Copyrighted Materials” which let to other

movies and spin offs.

The overwhelming comparisons are far too many to

be coincidental. “Meet the Parents and Meet the

Fockers are in fact a product of Plaintiffs “Stolen

Federal Copyrighted Materials” which started a new

trend in comedy.

For all of the above reasons this plaintiff respectfully

request that the summary judgment motion be held

in abeyance and a conference be scheduled

concerning discovery or limited discovery and a

timely extension be granted in opposition to

defendants summary judgment motion.

Thank you,

Respectfully Submitted

App. 23

/s/ Joseph Ardito

Chivalry Film Productions and

Joseph Ardito,

Plaintiffs

150 William Street 10‘ Floor

New York, New York 10038

Tel. No. (917) 425-2820

[MEMO ENDORSED]

The application for an extension is granted only to

the extent that plaintiffs response will be due on

August 11, 2006. There will be no further

extensions. Plaintiffs response was originally due on

July 17, and was extended in deference to his pro se

status. The request for a conference and for a lifting

of the stay on discovery is denied.

SO ORDERED

/S/ Gerard FE. Lynch

GERARD E. LYNCH, U.S.D.J.

App. 24

Library of Congress

Of the United States

Washington, D.C.

THIS IS TO CERTIFY that the attached photocopy is a

true representation of the work entitled “THE

TENANT” deposited in the Copyright Office with

claim of copyright registered under number PAU 2-

283-460.

THIS IS TO CERTIFY FURTHER, that pages 191

through 222 were missing from the registered

deposit for this registration.

IN WITNESS WHEREOF, the seal of this Office is

affixed hereto on December 14, 2005.

Marybeth Peters

/s/ Tracie M. Coleman

By: Tracie M. Coleman

Head

Certifications and

Documents Section

Information and Reference

Division

Use of this material is governed by the U.S.

App. 25

Library of Congress

Of the United States

Washington, D.C.

THIS IS TO CERTIFY that the attached visual

recording in video-cassette for is a true

representation of the video-cassette tape entitled

MEET THE PARENTS deposited in the Copyright

Office with claim of copyright registered under

number PAU 1-571-116.

THIS IS TO CERTIFY FURTHER, that the attached

photocopies are a true representation of the front of

the video-cassette tape, front and side of the video-

cassette tape cover.

IN WITNESS WHEREOF, the seal of this Office is

affixed hereto on March 7, 2006.

Marybeth Peters

/s/ Tracie M. Coleman

By: Tracie M. Coleman

Head

Certifications and

Documents Section

Information and Reference

Division

Use of this material is governed by the U.S.

App. 26

United States Copyright Office

The Library of Congress

[seal]

March 28, 2006

Pryor, Cashman

410 park Avenue

New York, NY 10022-4441

Dear Rick Purcell,

This letter is a correction to the certified letter for

PAU 1-571-116 (Meet the Parents) sent to you on

March 7, 2006). To clarify, there are no “attached

photocopies” of “the front of the video-cassette tape”

or of the “front and side of video-cassette tape cover”.

The video-cassette came in an unmarked black

container.

Sincerely,

/s/_ Richard Sharp

Richard D. Sharp

Certifications and Documents

Section

Information and Reference

Division

App. 27

United States Copyright Office

Library of Congress, 101 Independenc eAvenue SE,

Washington, DC 20559-6000, www.copyright.gov

[Seal]

January 26, 2007

Joseph Ardito

8 Badeau Place

New Rochelle, NY 10801

Dear Mr. Ardito:

This letter is in response to your request for a

search of the Copyright Office Inspection File and

Authorization File. The search failed to disclose

evidence that anyone has requested to examine of

the following work.

MEET THE PARENTS Pau 1-571-116

A search of the Copyright Office Authorization

Files disclosed that a copy of this work was requested

for litigation purposes in a Copyright Infringement

Dispute by the following.

Richard J. Purcell

PRYOR CASHMAN SHERMAN & FLYN

410 Park avenue, 10t» Floor

The proceedings have been instituted in

the Southern District of NY,

We conducted a careful search of the files at

the Copyright Office Deposit Copy Storage Area

App. 28

which revealed the work was missing from the

storage box assigned for this deposit. Because of this

the above listed registration is

You may resubmit your request at a later date

and we will conduct

SHOULD YOU DECIDE TO DO SO, YOU

MUST RETURN THE ENCLOSED COPY OF

THIS LETTER AFTER 120 DAYS AND BEFORE

160 DAYS TO ENSURE NO ADDITIONAL FEES

FOR LOATING AND RETRIEVING THIS FILE

IS APPLIED, PLEASE NOTE HOWEVER THAT

OTHER FEES COULD BE DUE FOR

PHOTOCOPYING.

App. 29

Tampering of Federal Evidence:

[Printed label on videocassette]

07-0665-cv Chivalry Film Productions, et al. v. NBC

Universal, et al.

Exhibit E to Ferber Declaration, dated June 16,

2006

VHS Copy of 1991 Version of “Meet the Parents”

App. 30

The Independent Inspection of the true label at the

Library of Congress:

CEM Productions

“Meet the Parents”

Handwritten:/72 mins./ typewritten [crossed out

information] 1991

App. 31

05Civ.5627(GEL)

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

Pee re errs Pee oe per rere xX

CHIVALRY FILM PRODUCTIONS

and JOSEPH ARDITO,

Plaintiffs,

NBC UNIVERSAL, INC., et al.,

Defendants.

ee ee a etre =

DECLARATION IN OPPOSITION TO DEFENDANTS’

MOTION FOR SUMMARY JUDGMENT

Preliminary Statement

The plaintiffs independently created copyrighted

work entitled “The Tenant” PAu-2-283-460 dated

April 27‘, 1998 was stolen in Los Angeles,

California, on or about August 21st, 1998 and a copy

was returned the first 60 pages were right side up as

the next 178 were backwards, also various project

outlines were also missing. I notified the LAPD and

filed a complaint . After viewing Meet the Fockers I

notified the LAPD in reference to the complaint filed

back on or about August 21st, 1998 concerning the

stolen federal copyrights materials. Detective

Packman Packer from the LAPD was on the case

App. 32

however the statute of limitations on the case was

running. I cooperated with the investigation and

furnished the detective with whatever materials

were needed to prosecute the case. However, I firmly

believe that due to the numerous studios involved

the LAPD declined on pursuing the case.

The Defendants in this case try to subterfuge the

fact that plainitffs “Stolen Federal Copyrighted

Materials entitled The Tenant and/or The

Dysfunctionals were not used in the making of Meet

the Parents and Meet the Fockers this denial is

absurd. The numerous similarities of scenes and

characters prove beyond a shadow of a doubt that.

plaintiffs Stolen Federal Copyrighted materials

entitled The Tenant and/or The Dysfunctionals were

in fact used in the making of Defendants projects

entitled Meet the Parents and Meet the Fockers.

The following characters and scenes from plaintiffs

“Stolen Federal Copyrighted Materials” entitled The

Tenant and/or The Dysfunctionals were

independently created by plaintiff on May 15t», 1996

preceding Meet the Parents 2000 in Characters and

Scenes by 4 years 6 months and preceding Meet the

Fockers by 8 years.

Defendants 1991 distorted VHS Version of Meet the

Parents was intentionally devised and used to back

date plaintiff's copyright, very few scenes from this

1991 VHS are present in Meet the Parents 2000 and

no scenes from this 1991 VHS are present in Meet

the Fockers 2004. However, the scenes and

characters from plaintiffs “Stolen Federal

Copyrighted Materials” entitled The Tenant and/or

The Dysfunctionals are numerous and overwhelming

App. 33

in both Meet the Parents and Meet the Fockers. It’s

fair to say that Meet the Parents and Meet the

Fockers are a product of plaintiffs “Stolen Federal

Copyrighted Materials” entitled The Tenant and/or

The Dysfunctionals.

The 1991 distorted VHS which defendants rely on as

“The Irrefutable Documentary Evidence” has no real

sequel, because everyone including the dog is dead.

The purpose of this back dated copyright is quite

obvious to conceal , mask and subterfuge the blatant

use of plaintiffs “Stolen Federal Copyrighted

Materials” entitled The Tenant and/or The

Dysfunctionals. Any jury in the United States or

throughout the world will come to the same

conclusion.

The following Characters and Scenes are from

plaintiffs “Stolen Federal Copyrighted Materials

entitled - The Tenant and/or The Dysfunctionalsand

an independent creation.

The Characters:

The Tenant and/or The Dysfunctionals - CIA Agent,

Attorney Character, Psychiatrist Character, Nurse

Character, Flight Attendant Character, Psychiatrist

Character (Pam), Flight Attendant Character,

Michael Angelo of Carpentry Character, Police

Officers Character, Animal Shelter Character, Judge

Character, Senior Citizen Character, Concerned

neighbor Character, Doctor Character, Baby

Characters. These Characters were developed on or

about May 15, 1996 - 4 years prior to Meet the

Parents and 8 years prior to Meet the Fockers.

App. 34

Characters in The Tenant and/or The Dysfunctionals

llsimilar/ Meet the Parents and Meet the Fockers

are very similar.

Meet the Parents and Meet the Fockers are as

follows : — CIA Agent Character, Attorney Character,

Nurse Character, Pam, Attorney Character,

Psychiatrist Character, Flight Attendant Character,

Carpenter Character , Doctors Character, Mother

Character, Concerned Neighbor Character, Little

Jack Character, Relative Characters, Rusty

Characters, Isabelle Character, Jaho Character,

Police Officer Character, Animal Shelter Character,

Judge Character, Senior Citizen Characters, Relative

Characters, Baby Character. Etc.

The Scenes:

Jo Jo nervously practicing in the mirror in a

stuttering manner on how, he is going to ask Pam

out. // similar// Gregg is at the hospital practicing to

a patient on how he is going to ask Pam to marry

him. Both scenes when asking take place at a school

location. (Def Exh. H -PAu-2-423-720 — Def Exh. C

-(MTP))

Stimmy’s full luggage scene as he moves into a new

house. // similar // Gregg’s full luggage scene going

on a trip. (Def Exh. J PAu—2-423-720 Def Exh. C

(MTP).

Greyy pulls up to the house and Jack Byrnes moves

the curtain viewing Gregg in a cynical manner. //

App. 35

similar/ Stimmy pulls up to the house and the

landlord is peeking through the blinds viewing

Stimmy “watching his every move” in a cynical

manner. (Def Exh. H PAu-2-423-720 (Page 88-15

Paragraph) Def Exh. C (MTP) and Def Exh.

TXU-742-462)

Jack Byrnes — What do you drive a Ford, interesting

color did you pick it? Only geniuses pick green and

you didn’t pick it. //similar //The Landlord’s scene is

asking Stimmy why did you buy a standard shift?

How about if I need to borrow your car? What kind of

car do you drive? (Def Exh. H-PAu-2-423-720 , PAu

2-283-460 - Def Exh C (MTP).

Vinny badgered Stimmy on his driving ability, Vinny

tells Stimmy once he is already in the intersection to

make a turn if he misses the turn he’s ridiculed. //

similar // When Gregg is driving and he missed the

turn he was also ridiculed by his future in-laws.

(Def Exh. H PAu-2-283-460 —- Def Exh. C (MTP).

Jimmy climbed up on the roof to pursue a nosy

neighbor who vanished into thin air. // similar //

Gregg climbing up on the roof to pursue Jinx who

vanished into thin air. (Def Ex H-PAu-2-283-460 -

Def Exhibit C (MTP).

The Tenant eavesdropped on the landlord’s

conversation. / similar // Gregg eavesdropping on

Jack Byrnes Conversation (Def Exh. H-PAu-2-283-

460 —- Def Exh. C (MTP)),

App. 36

Stimmy is strapped down into a chair with a home

made lie detector test to get the truth out. //similar

// Gregg being strapped to an Antique Lie Detector in

getting the truth out. (Def Exh H. PAu-2-283-460 —

Def Exh. C-(MTP)).

The Tenant and/or the Dysfunctionals have a Hidden

Surveillance Camera //similar // Meet the Parents

and Meet the Fockers who also have a hidden

Surveillance Camera (Def Exh H. PAu-2-283-460 —

Def Ex C-(MTP)).

The landlord and his brother are viewed on the

hidden surveillance camera, claiming to be innocent

and were found guilty by the recorded evidence.

// similar // to Gregg was viewed on the hidden

surveillance camera, claiming to be innocent and was

found guilty by the recorded evidence. (Def Exh H.

PAu-2-283-460 —Def Exh. C-(MTP)).

The landlord had claimed to have taken a shower

however, his hair was noticeably dry. // similar //

Gregg also claiming to have taken a shower and his

hair was noticeably dry. (Def Exh H. PAu-2-283-

460 — Def Exh. C (MTP)).

The landlord is a Control Freak // similar //as Jack

Byrnes is also a Control Freak. (Def Exh H PAu-2-

283-460 — Def Exh. C-(MTP)).

The tenant is given a tour of the house and it is

brought to his attention that the bathroom is under

renovation // similar // Gregg getting a tour of the

house it was also brought to his attention that

App. 37

problem existed in the bathroom. (Def Exh. PAu-2-

283-460 — Def Exh. C-(MTP)).

The name Focker in Meet the Parents and Meet the

Fockers is prevalent throughout defendants’ entire

screenplay which in a comical aspect is meant to

mean fucker as directed to a person. // similar // The

term fucker is prevalent throughout plaintiffs entire

screenplay, meaning one in the same in a comical

aspect. (Def kxh H PAu-2-283-460 —- Def Exh C-

(MTP)).

The term Little Fuckers in the plaintiffs screenplay

is intended in a comical aspect to mean children //

similar // The term little fockers is in a comical

aspect is meant to mean little fuckers. (Children).

(Def Exh. H PAu-283-460 — Def Exh. C-(MTP)).

The landlord use character uses Asian Dialect //

similar // Jack Byrnes character uses Asian Dialect.

(Def Exh. PAu-2-283-460 —Def Exh. C-(MTP)).

The landlord disguises his voice using a variety of

accents to keep his identity anonymous. The doctor

in the tenant ridicules a southern accent //similar //

Jack Byrnes tells his travel agent to disguise his

voice using a southern accent to keep his identity

anonymous. (Def Exh H - PAu-2-283-460 Def Exh

C (MTP)).

Vinny dresses up as a male nurse which triggers one

of many Gay ridicule scenes, also Tommy being a

transvestite attributes to the gay ridicule scenes //

similar // Gregg being a male nurse triggering one of

App. 38

many gay ridicule scenes throughout defendants

screenplay. (Def Exh H-PAu-2-283-460 Def Exh C-

(MTP)).

Jack Byrnes ask Gregg a question, is your loved one

safe with a stranger? Gregg answers yes as opposed

to Jacks answer that is no. // similar // The Tenant

and/or Dysfunctionals — The content of this book will

help you develop a sense of cynicism before becoming

a statistic yourself — not to trust strangers. (Def Exh

G —- TXU-775-750 — Def Exh C (MTP)).

Gregg’s future Brother-In-Law claims that he saw

Gregg going through his wallet and was about to

steal his money while in the Tuxedo Shop. //similar//

Vinny stealing money out Stimmy’s wallet. (Def

Exh. H- PAu-2-283-460 —- Def Exh C (MTP)).

The dilated pupil peeking through the blinds would

insinuate that the landlord is a pot head. Stimmy’s

ex claiming to be crack head —overdose drug-related.

/similar// Jack Byrnes claiming that Gregg Focker

is a pot head also claims that he works in a hospital

looking for access to drugs. (Def Exh G TXU-775-

759 —- Def Exh C-(MTP)).

Jimmy dragging behind him dismembered tree limbs

//similar/ A worker in Meet the Parents dragging

behind him some dismembered tree limbs. (Def Exh

I Paul 2-380-629 — Def Exh C-(MTP)).

Cheap Bottle of Champagne in The Tenant and/or

Dysfunctionals’. //similar// The Cheap Bottle of

Champagne Scene in Meet the Parents. (Def Exh H-

PAu-2-283-460 — Def Exh C-(MTP)).

App. 39

Bestiality Joke in The Tenant and/or The

Dysfunctionals’ //similar// Bestiality Joke Meet the

Parents. The jokes punch line is one and the same.

(Def Exh. H- PAu-2-283-460 — Def Exh. C-(MTP)).

Landlord is time conscience //similar// Jack Byrnes

is also time conscience. (Def Exh H- PAu-2-283-460

— Def Exh C-(MTP)).

Jimmy’s wife is stereo-typically permissive

/Isimilar/ Dina Byrnes is very permissive. (Def

Exh H-PAu-2-283-460 — Def Exh- C-(MTP)).

Carlo’s father comes out wearing a woman’s robe

//similar// Gregg is also wearing a woman’s (Pam's)

bathrobe. (Def Exh H PAu-2-283-460 — Def Exh C-

(MTP)).

The landlord has rules and regulations of the house //

similar // Jack Byrnes also has rules and

regulations of the house.

(Def Exh H-PAu-2-283-460 — Def Exh C-(MTP)).

The Tenant and/or The Dysfunctionals’ use the term

mother fucker in a comical aspect. //similar/ Jack

Byrnes when claiming that Pam’s middle name is

Martha — Pamela Martha Focker used in a comical

aspect to also mean Mother Fucker. (Def Exh H-

PAu- 2-3283-460 — Def Exh C-(MTP)).

In the Tenant and/or The Dysfunctionals the

landlord claims to be CIA claiming to know Bill

Clinton really well and headed for the White House

to the oval office to talk about the invasion or coupe.

//similar// Meet the Parents when Gregg falls into

the secret room a picture appears of Jack Byrnes

App. 40

walking next to President Clinton at the White

House, another picture depicting Jack Byrnes with a

turban on his head with an Arab and another picture

with an Army General the intended message was

that Jack Byrnes was CIA involved in some sort of

military action involving a coupe or invasion of some

sort. (Def Exh J- PAu 2-423-720 /H PAu-2-283-460

/- Def Exh C-(MTP)).

Jack Byrnes ask Gregg if he ever watched

pornographic movies while taking the he detector

test the needles were jumping //similar// The

landlord watching pornographic movies. (Def Exh H

— PAu-2-283-460- Def Exh C-(MTP)).

Stimmy is traumatized by the lie detector test

venting out to the landlord / similar // Gregg is

traumatized by the hie detector test venting out to

Pam. (Def Exh PAu-2-283-460 — Def Exh C-

(MTP)).

Jack Brynes jimmies Gregg’s luggage to gain access

and finds sex paraphernalia which leads Jack to

believe that Gregg is a sexual deviant //similar/ The

Landlord jimmies Stimmy’s door open to gain access

and is seen on one occasion going through Stimmy’s

luggage. The same sex paraphernalia is found to

ridiculing sexual deviants in The Tenant and/or The

Dysfunctionals while the crew is on vacation. (Def

Exh PAu-2-283-460 -sex paraphernalia- Def

Exhibit F-TXU-742-462 - Def Exh C-(MTP)).

The landlord wakes up startled in a semi-conscience

state and sees a chair planted next to his bed, it’s the

landlord starring at him sippiny coffee

isimilar//Gregg wakes up startled and sees Jack

App. 41

Byrnes right next to him. (Def Exh G- TXU-775-750

— Def Exh C9MTP)).

Jo Jo threatens a person as to keep his identity as a

CIA confidential or else//similar// Jack Byrnes tells

Gregg to keep his identity as a CIA confidential or

else. Def Exh PAu-2-283-460 — Def Exh C-(MTP)).

Stimmy’s Father-In-Law threatens Stimmy

concerning his daughter //similar// Jack Byrnes

threatens Gregg concerning his daughter.

(Def Exh PAu-2-283-460 —- Def Exh C-(MTP)).

The Chaps in The Tenant and/or The Dysfunctionals’

feel alienated when no one laughs at their jokes

‘/similar// Gregg’s feels alienated when no one from

the family laughs at his jokes. (Def Exh H- 2-283-

460 Def Exh C-(MTP)).

The tenant on numerous occasions states to the

landlord “leave me alone” //similar// Go away mat in

Denny’s room symbolizes — leave me alone. (Def Exh

G- TXU-775-750 —- Def Exh C-(MTP))

Vinny- Michael Angelo of Carpentry — Cabinets from

Vienna // similar // Kevin carpenter Bolivian wooden

floors.

(Def Exhi -G-TXU-775-750 — Def Exh C (MTP)).

The landlord refers to Oliver Twist to stay out of his

drawers that he will be subject to search and seizure.

The mute had ransacked the drawers and was found

with the wife’s panties over his head. //similar//

Gregg when going through Denny’s drawers is

approached by Denny hey! Hey! What are you going

through my drawers? Where you sniffing my boxers’

App. 42

dude? (Def Exh H- PAu-2-283-460 — Def Exh - G-

TXU-775-750 — Def Exh C (MTP)).

The tenant had claimed to Carlo that he was

petrified of the landlord. //similar// Gregg had

claimed to Pam that he was petrified of her dad. (Def

Exh PAu-2-283-460 — Def Exh C-(MTP)).

The tenant is calling his stay at the landlord’s house

a nightmare. /similar/ Gregg calling his stay at the

parents house a nightmare. (Def Exh F-TXU-742-

462 Def Exh C-(MTP)).

The tenant and/or Dysfunctionals’ elaborate on how

History plays an important role in the formulation of

their bond with one another, just as a war brings a

country together these characters portrayed in this

novel show a sick sense of allegiance toward one

another. The fidelity creates a bond which in turn

forms a crew // similar// Circle of Trust. (Def Exh

G-TXU-775-750 — Def Exh C-(MTP)).

The Tenant and/or The Dysfunctionals’ “ Watching

his Every Move” , “ Watching Him” , “Watching with

Binoculars” , Brother quite his job to “Watch the

Tenant”, Stalker, Stalking // similar // Meet the

Parents and Meet the Fockers - I'm watching you!

(Def Exh H- PAu-2-283-460,

Def Exh G-TXU-775-750, Def Exh G - TXU-775-

750, Def Exh F-TXU-742-462 — Def Exh C-(MTP)).

The Tenant and/or The Dysfunctionals’ Skimpy

bathing suit Scene // similar // The Meet the

Parents’ Skimpy bathing suit scene. (Def Exh G-

TXU-775-750 Def Exh C (MTP)).

App. 43

The Tenant and/or Dysfunctionals’ Volleyball Game

scene in where a woman breaks her nose // similar //

The Meet the Parents Volleyball Scene with a nose

injury. (Def Exh F-TXU-742-462 — Def Exh — C-

(MTP)).

The senior citizens who are cynical pessimist

investigate Jo Jo character after witnessing some

bizarre behavior in order to find out, whether he is

who he says he 1s. // similar// Jack Byrnes a cynical

pessimist after witnessing some bizarre behavior,

investigates Gregg in order to find out if he is who he

says he is. (Def Exh H — PAu-2-283-460 — Def Exh

C-(MTP)).

Vinny is spelling out Stimmy’s name to an official for

investigative purposes. // similar // Jack Byrnes is

spelling out Gregg’s name to an official for

investigative purposes. (Def Exh H- PAu-2-283-460

—- Def Exh C-(MTP)..

The Tenant and/or The Dysfunctionals’ — The

investigation concluded that Jo Jo is fabricating. //

similar // The investigation concludes that Gregg is

fabricating. (Def Exh H -PAu-2-283-460 - Def

Exhibit C-(MTP)).

The landlord claims that Stimmy has been nothing

but trouble since he came into the house. Jimmy

saying this guys referring to his son-in-law has been

nothing but trouble since he came into the family. //

similar // Jack Byrnes — Honey this kid has been

lying to us since we met him. (Def Exh H-PAu-2-

283-460 —- Def Exh C-(MTP)).

App. 44

The Tenant and/or The Dysfunctional “Michael

Angelo of Carpentry” orders cabinets from another

country Vienna. // similar // Kevin a carpenter

orders wood from another country Bolivia. (Def Exh

G TXU-775-750 Def Exh C-(MTP)).

Vinny speaks Asian Dialect // similar // Jack

Byrnes speaking Asian dialect (Def Exh H-PAu2-

283-460 Def Exh C-(MTP)).

Vinny says Fucker. // similar // Gregg looking for

Jinx says fucker in a comical aspect. (Def Exh G-

TXU-775-750 , Def Exh H - PAu-2-283-460 — Def

Exh C-(MTP)).

The plaintiff in The Tenant and/or Dysfunctionals’

receives a call from a concerned neighbor about his

dog and the ASPCA // similar // Jack Byrnes while

retrieving his messages receives a call from a

concerned neighbor that he found Jinx — Jack comes

concluding that Gregg took a cat from the Animal

Shelter. (Def Exh G-TXU-775-750 — Def Exh C-

9MTP)).

Race home Scene —Vinny’s wife pulls up parallel to

his car exactly 3 (Three) times, Vinny is trying to get

home first to fix the dent, get rid of the evidence and

substantiate an alibi // similar // Jack Byrnes pulls

up parallel to Greggs car exactly 3 (Three) times.

Gregg is trying to get home first to get rid of the

evidence both deal with evidence. (Def Exh G TXU-

775-750 - Def Exh C-(MTP)).

Stimmy as he pulls up to the house, he finds his

clothes shredded and burnt all over the front lawn in

a bizarre manner. The carpentry case the plaintiff

App. 45

enters his apartment which is in total disarray, it

looked as if an earthquake struck. His dog was in the

closet. He received a phone call from a concerned

neighbor informing him about his dog and the fact

that ASPCA was present. // similar // The Byrnes

family comes home and finds the house in a total

disaster with the wedding clothes, tuxedos and gown

shredded up all over the place in a bizarre manner.

Jack realized that the cat was from the Animal

Shelter. (Def Exh G TXU-775-750 Ex H-PAu-2-

283-460, J-PAu-2-423-720, —- Def Exh C (MTP)).

Gregg informed Pam that her father was breaking

them apart, that he didn’t like him. // similar //

Where as in Jo Jo and Pam’s relationship the parents

were against it. (Def Exhibit H-PAu- 2-283-460 -

Def Exh — C (MTP)).

“The shredded clothes in a bizarre

manner leads to the eviction of both the Tenant

and Gregg Focker”. (Def Exh G-TXU-775-750,

Def Exh H -— PAu-2-283-460 — Def Exh — C-

(MTP)..

The shredded clothes in a bizarre manner leads

to the eviction of both the Tenant in “The

Tenant and/or The dysfunctionals”; and Gregg

Focker in “Meet the Parents”. The numerous

comparisons alone should substantiate and

prove that the defendants beyond any

reasonable doubt knew at all times that they

were in possession of plaintiffs stolen federal

copyrighted materials and used plaintiffs’

Stolen Federal Copyright in the making of

defendants’ projects Meet the Parents and Meet

App. 46

the Fockers. // similar //(Def Exh G TXU-775-750,

Exh H - PAu-2-283-460, Exh J-PAu-423-720 — Def

Exh C-(MTP)).

Dina Byrnes then tells Jack that no one was ever

good enough for Pam. // similar // Pam’s family in

the Tenant felt the same way. (Def Exh H - PAu-2-

283-460 —- Def Exh C-(MTP)).

Eddie is at the airport by himself and Stimmy’s

girlfriend took off to the airport with Stimmys

engagement ring // similar // Gregg goes to the

airport it appears he 1s the only one in the airport as

he looks at the engagement ring). (Def Exh G TXU-

775-750 — Def Exh C-(MTP))

Jo Jo is taken into custody from the plane. A crew

member is arrested and carried off by two police

officers restraining both his arms and legs as he is

acting like a raving lunatic. // similar // Gregg has a

problem on the flight and is arrested and carried off

the plane by two police officers restraining both his

arms and legs as he is acting like a raven lunatic.

(Def Exh H-PAu -2-283-460 — Def Exh C-(MTP)).

Jack Byrnes driving erratically sped to the airport

and jackknifed his car in front of the entrance to the

airline. A police officer walked up and said to him

you can’t park there. Jack replied tow it. // similar //

Jimmy driving erratically sped to the hospital and

jackknifed in front of the emergency entrance. A

police officer walked up and said to him you can’t

park there. Jimmy’s reply was yeah right! (Def Exh

H -PAu-2-283-460 —Def Exh —- C (MTP)).

App. 47

Jo Jo is interrogated and in light of the

investigation is set free. Stimmy is also cuffed to a

chair and in light of the investigation is set free. //

similar // Gregg is interrogated and cuffed to a chair

declaring his innocence and in light of the

investigation is set free. (Def Exh H- PAu-2-283-

470 — Def Exh C- (MTP)).

Stimmy goes on to Meet another Dysfunctional

family, upon entering the premises he notices a

picture on the wall which resembled the owner.

Stimmy could have sworn while looking around the

apartment he saw the eyes in the picture moving. It

was confirmed that the landlord was watching him

from behind the picture as the landlord starting

conversing with Stimmy from behind picture.

“Watching Him” (Def Exh H-PAu-2-283-470)

Gregg states to Jack do I think you’re a psycho?

Yes // similar // Vinny’s stalking his boss and the

boss calls him a psycho, Stimmy calling him a

psychotic. (Def Exh H- PAu-2-283-460 Def Exh C

(MTP)).

Jo Jo at the end of “The Tenant and/or The

Dsyfunctionals is in the process of developing a

relationship with Pam the Psychiatrist as Stimmy is

off to meet another dysfunctional family // similar //

Gregg returns to the house and continues his

relationship with Pam and Jack Byrnes is in the

process of meeting another dysfunctional family

‘The Fockers” //. (Def Exh H —PAu-2-283-460 Def

Exh. C-(MTP)).

App. 48

Jack Byrnes during the credits plays the video

from the hidden surveillance camera and verifies

that Gregg was guilty of flushing the toilet. //similar//

Stimmy playing the video from the hidden

surveillance camera which verifies that Vinny was

guilty of stealing his money. (Def Exh. H-PAu-2-

283-460 — Def Exh C (MTP)).

Gregg doing karate moves and screams // similar

// Vinny doing karate moves and screams (Def Exh.

H-PAu-2-283-460 — Def Exh-C(MTP)).

There are many more scenes, however time

is of the essence.

The Tenant and/or The Dysfunctionals’

Characters: CIA Character, Psychiatrist

_Character, Attorney Character,

Theologian/Monk Character, Michael Angelo Of

Carpentry Character, Police Officer Character,

Correction Officer Character, The In-laws

Character, Captain Character, Judge

Character, Senior Citizen Characters.

Meet the Fockers Characters as follows:

CIA Character, Nurse Character, Pam

Character, Mother Character, Attorney Character,

Psychiatrist Character, Little Jack, Isabella

Character, Rusty Character, Jaho Character,

Ordained Minister Character & Carpenter

Character, Relative Characters, Police Officer

Character , Correction Officer Character, Judge

App. 49

Character, Senior Citizen Characters. Captain

Character.

Characters in the Tenant and/or The Dysfunctionals

// similar // Characters in Meet the Fockers

The Scenes from The Tenant and/or The

Dysfunctionals //similar// Meet the Fockers

The Scenes:

A mother in agonizing pain is frantically

seeking a doctor to deliver her baby. A doctor cannot

be found and Gregg is informed that he has to deliver

the baby. The parents are concerned of his lack of

medical qualifications and competence. However, the

delivery goes well. // similar // Jimmy’s wife in

agonizing pain is frantically seeking her doctor to

deliver her baby. The doctor comes in late Jimmy

aware of the doctor’s medical mal practice is

concerned about his competence. However the

delivery goes well. (Def Exh. H-PAu-2-283-460 —

Def D (MTFP)).

Little Jack was brought into Meet the

Fockers for the purpose of incorporating the

Sign language, Mammary Gland, Gay ridicule,

Ferber Focker Method, “Scar Face say hello to

my little friends” . and to get some of the

sexually explicited materials out for instance

seeing Isabellas Breast and making the using

his tongue and mimicking his hands in an what

appears to be sexual.

Roz the Psychiatrist was brought in to

bring in sexual situations on an educated level

App. 50

low tone // Exhibition // Sex // First time details

etc// emulating Pam the psychiatrist.// Ferber-

Focker method in growing up children.

Jack Byrnes is teaching Little Jack sign

language by showing him cards. When Gregg

appears Jack shows little Jack a card with a picture

of a Nurse on it. Little Jack laughs because as Jack

explains to Gregg that the nurse card only comes in

one gender. Gay Ridicule // similar // The landlord

tells Stimmy he’s got a hot date for him a Nurse —

Stimmy thinking a nurse could only be a female and

when he views Vinny dressed up in a nurses

uniform with a wig on. — Gay Ridicule- (Def ExhG

— TXU-775-750 —- Def Exh D (MTF)).

Dina this is the highlight of our twilight //

similar// Members would always be ready for

something out of the ordinary like the twilight zone

or outer limits. (Def Exh H- PAu-2-283-460 — Def

Exh D (MTP)).

Jack develops a Mammary Gland to breast

feed little Jack however, while in the RV (deleted

scene) Jack ask Gregg to feel how real the breast

feel. While Gregg was feeling the breast Dina and

Pam walked in startled to witness such bizarre

behavior. // similar // Vinny going over the bridge

making out with a blow up doll acting as if she were

real. Vinny acted as if it were his date as he began to

make out with a doll, when the wig fell off the toll

clerk was startled by the bizarre behavior. Anyhow

the intent of the joke is one and the same. (Def Exh.

PAu-2-283-460 — Def D (MTP)).

App. 51

Bernie Focker doing karate outside his house //

similar // Vinny doing kararte (Def Exh H-PAu-2-

283-460 —Def D (MTF)).

Fockers make sleeping arrangements , Jack

Byrnes wants to sleep in the RV. // similar // Vinny

tells Stimmy he could sleep anywhere sometimes he

sleeps inthe car. (Def Exh G — TXU-775-750 — Def

Exh D (MTP)).

Byrnes family pulls up to the house and they

get a tour — It was explained that the upstairs was

being renovated // similar // When the landlord gave

Vinny a tour of the house and explained that the

bathroom was in the process of renovations. (Def

Exh H-PAu-2-283-460-Def D (MTF)).

Bernie Focker is bragging about his Stamina /

similar / Mary is bragging about Jo Jo’s stamina.

(Def Exh H-PAu-2-283-460 — Def Exh D (MTF)).

When Isabelle was introduced at the dinner

table little Jack began making tongue movements

and mimicking his arms and hands to feel

// similar // Vinny starring and mimicking his

tongue movements and mimicking his arms and

hands the intent of the joke sexual deviant.

(Def Exh H-PAu-2-283-460 — Def Exh D-(MTF)).

Isabelle looks at little Jack and actually says

handsome little fucker // similar/ Fucker being

prevalent throughout the script as a comical aspect

(Def Exh G —- TXU-775-759 — Def Exh D(MTFP)).

Bernie said Gay will be the official quarterback

he’ll go both ways. Jack said I’m sure he does. 7

App. 52

similar // Stimmy thought maybe this chap went

both ways. (Def Exh H-PAu-2-283-460 — Def Exh

D -(MTPF)).

Bernie Focker say to Jack Byrnes look at

those pecks. // similar // Father in The Tenant

and/or The Dysfunctionais is a well built man.

(Def Exh H — PAu-2-283-460 — Def Exh D

(MTF)).

Macho Football

Bernie Focker paints his face // similar //

Father paints his face. (Def Exh H- PAu-2-283-460

— Def Exh D (MTP)).

Jack and Gregg in football huddles whispering

there plan // similar// Brothers in a football huddle

whispering their plan. (Def H- PAu-2-283-460 — Def

D (MTF)).

Bernie Focker does an Indian War Dance to

rowel himself up while playing football // similar //

It sounded like an Indian War dance before the

attack. (Def Exh H —PAu-2-283-470 — Def Exh D

(MTF)).

Jack Byrnes gets intercepted and tackled by

Bernie // similar // Tommy getting intercepted and

tackled. (Def Exh F TXU-742-462 — Def Exh D

(MTF)).

Jack Byrnes — Can I get some privacy? //

similar // I have to talk te my brother in private stop

App. 53

eavesdropping. (Def Exh H-PAu-2-283-460 — Def

Exh D (MTFPF)).

Jack Brynes is eaves dropping as he bends over

trying to listen by the door // similar// Stimmy

listening by the door. (Def Exh -PAu-2-283-460 —

Def D (MTF)).

Ferber Method don’t pick the baby up when he

cries // similar / A baby is crying awaiting a

response. The parents in fetal position are also

crying with no intention of picking the baby up.

Dysfunctional v. Rational. (Def Exh H- PAu-2-283-

460 — Def Exk. D-(MTP)).

Ferber —Focker Method //similar//

Dysfunctional v. Rational Method — we will have an

opportunity to study some of the bizarre behaviorism

and abnormal reactions of the dysfunctional as well

as the normal people of society, I would like at this

point to return to the crying chap and focus in on the

newborn, who will have to endure being raised in a

dysfunctional home. (Def Exh H - PAu-2-283-460 -

Def Exh C -(MTF)).

Roz Focker states Jack is in denial // similar //

The parents that finally realize through failures and

tragedies of their offspring that something is indeed

wrong and continues to go through life turning a

blind eye are usually to blame. The lack of

understanding and stubbornness to deal earnestly

with this problem creates the barriers and inability

for these chaps to function rationally in a normal

society. (Def Exh G- TXU-775-750- Def Exh D-

(MTF)).

App. 54

Jack Brynes talks about his family legacy //

similar // The parents who go through life

subterfuging their guilt without any attempt or

reconciling differences, have not learned anything.

They only condone the behavioral] pattern that will

eventually destroy their families and destroy the

lives of the next generation. (Def Exh G -TXU-775-

750 - Def Exh D (MTP)).

Roz the psychiatrist tries to get to the

foundation of the problem // similar // Pam the

psychiatrist tries to get to the foundation of the

problem.

(Def Exh H PAu-2-283-460 Def Exh D (MTF)).

Roz what was his childhood like? Roz goes into

Jack’s childhood thinking all he needed was a hug. //

similar // Pam what was your childhood like? (Def

Exh H — PAu-2-283-460 — Def Exh D (MTPF)).

Denny was away at Military School // similar

// JoJo was raised quasi-military. (Def PAu — 2-

283-460 — Def Exh D-(MTP)).

Jack Byrnes and his wife Dina are in the

downstairs bedroom listening to sounds of a couple in

ecstasy making passionate love // similar / real

estate agent and potential buyers hear the sounds of

a woman in ecstasy makiny passionate love. (Def

Exh H-PAu-2-283-460 - Def Exh D (MTF)).

Jack Brynes gives Gregg a truth serum drug

and his true feelings begin to emerge. // similar //

The liquor began working like a “Truth Serum” as

the chaps true feeling began to emerge. (Def Exh H-

PAu 2-283-460 — Def Exh D (MTF)).

App. 55

Gregg passes out on the floor // similar // Jo Jo

passes out on the floor (Def Exh PAu-2-283-460 —

Def Exh D -—(MTP)).

Roz explained to Gregg your father it would

make good conversation (sex) on who was the first. //

similar // Jo Jo at the dinner table cued in on the

topic of conversation at the dinner table who was the

first time. (Def Exh H-PAu-2-283-460 — Def Exh D

(MTPF)).

Richard liked details // similar // Roz claimed

she liked details. (Def Exh H-PAu-2-283-460 — Def

Exh D (MTPF)).

Bernie Focker a rebel , activist hippy // similar

// Jo Jo one of the sons had a rebel type of attitude,

finding most of the ordinances concerning rules and

regulations totally abnormal and out of touch with

reality, mocking such demented behavior — a sort of

rebellion against the absurdity of such dysfunctional

behavior. (Def Exh H-PAu-2-283-460 — Def Exh D

(MTPF)).

Bernie Focker an Activist //similar// Baffled

about the Captains arrest , Jo Jo began questioning

whether or not the police acted properly gathering

the liberals on the beach. After learning the ground

Jo Jo aborted the matter of righteousness. Jo Jo

faded into the crowd to avoid any negative exposure.

(Def Exh H- PAu- 2-283-460 —- Def Exh D (MTPF)).

(Deleted Scene) Defendants’ Highway Cop — stay

in the car. Bernie jumps out of the car and start

running up to the cop.// similar // Keep your hands

App. 56

on the steering wheel: Vinny jumps out of the car

and runs up to the cop. The cops draw their guns.

(Def Exh H-PAu-2-283-460 - Def Exh D -

(MTF)).

Defendants’ Police Officer — Didn't | tell you to stay

in the car ? What seems to be the problemo?

Speeding going 55 in 45 mph zone .//similar// Didn't I

tell you to stay in the car? What seems to be the

problem? Speeding going 60 mph running steady red

lights and driving recklessly, I say that constitutes a

major problem. (Def Exh H- PAu-2-283-460 -— Def

Exh D- (MTP)).

Gregg while in custody sees Jack and starts

running trying to get Jacks attention. The officer

chases after Stimmy who was taken down with a

Tazar gun // similar // Officer chases after Vinny

trying to escape custody as he’s taken down witha

tranquilizer gun. (Def Exh H-PAu-2-283-460-Def

Exh D-(MTP)).

Jack Byrnes approaches the officer and shows his

identification A “Man of Influence”. The officer looks

at the identification that states retiree. CI what?

What are you going to show me next your AARP card

? // similar // Vinny flicking his wallet to his date to

give the date some inclination that he was a “Man of

influence”. Are you talking to me? (Robert De Niro

Impersonation). ’m CIA baby! Dates reply — Listen,

Elliot Nest just drop me off

Def Exh H - PAu-2-283-460 -— Def Exh D (MTPF)).

Jack claims that if the officer doesn’t stand down

he'll be working in an old age home // similar /

Vinny telling his date that those cops do not know

App. 57

who they are messing with that they’ll be working

the beat in the fucking circus. Mentality is similar.

(Def Exh H- PAu 2-283-460 — Def Exh D (MTF)).

(MTF) Cop hits Jack Byrnes with a stun gun taken

him down with a few volts. // similar // Stimmy is hit

with a stun gun taken him down with a few volts.

(Def Exh H — PAu-20283-460 — Def Exh D (MTF)).

(MTF) Cop goes into the RV and comes out with the

Rubber Booby and finds what he believes to be

pornography tapes in the trunk of the car and

explains this is what you find behind the blue velvet

ropes — the cop is led to the conclusion that he is

dealing with sexual deviants // similar // Cops

finding 3 rubber dolls and semen on the seats of the

car is led to the same conclusion he is dealing witha

sexual deviant. The encompassing of porn tapes,

rubber booby, semen and rubber dolls all encompass

the same effect the ridiculing of a sexual deviant in

a comical aspect. (Def Exh H- PAu 2-283-460 — Def

Exh D-(MTPF)).

Deleted Scenes:

MTP — Cop - Mr. fucker remain in the vehicle //

similar// Fucker referring to individuals in a comical

aspect. (Def Exhibit H-PAu-2-283-460 — Def Exh

D (MTP)).

MTP — Cop - You want to Dance do si do (square

dance)

// similar // Jimmy in the hospital what’s this look

like a fucking square dance. (Def Exh I- PAu-2-380-

720- Def Exh D (MTPF)).

App. 58

MTP Cop- Poppa Freak and Baby freak out for a

Sunday drive and Mrs. Freak //similar// The Tenant

and/or The Dysfunctional Cops - Freaks of Nature

were exposed and labeled sexual deviants. (Def H-

PAu-2-283-460 — Def D (MTF)).

Deleted Scene cop claims they are doing interstate

porn trafficking these are the kinds of videos you find

behind the velvet rope // similar // Stimmy is taken

down to the peep parlor.

( Def Exh H- PAu 2-283-460 —- Def Exh D (MTF)).

MTF Child services // similar// Child Services if this

type of warped behavior is being used as a form of

conditioning or discipline in your household, stop

right here and notify the child abusc hotlinc. If

you're an adult get out! (Def H- PAu-2-283-460 -

Def D- (MTP)).

Baby Jack puts on Scar Face with Al Pacino “ Say

hello to my little friends” // similar // Say hello to

my little friends is dialogue — Al Pacino — Jimmy the

father watched Scar Face with Al Pacino on T.V.

Vinny talked like Al Pacino in the restaurant. (Def

Exh G - TXU-775-750 — Def Exh D (MTP)).

Deleted Scene — Bernie Focker states to Jack we all

have our issues // similar // The pattern of behavior

in this novel is called “Sick Humor” the actions of

these characters creates the type of ambivalence and

animosity that severs numerous relationships as you

will see, instilling apprehension, fear and anxiety

that creates the onsets of the chaotic environment,

The characters portrayed in this story all suffer from

App. 59

a variety of disorders which makes this novel

entertaining. (Def Exh G —TXU-775-750 — Def Exh

D (MTPF)).

Relative — Barry Focker (In-Law) Looked like a

typical sex degenerate, with his stalker stares //

similar // starring in a lecherous manner, the

woman noticed the perverted stares from the stalker

— The tenant and/or Dysfunctionals’ ridicules this

type of behavior throughout the projects. (Def Exh

H-PAu-283-460 — Def Exh D (MTF)).

Kevin became an ordained minister when

he was talking to Isabelle he claimed Gregg had good

taste and threw his collar away // similar //

Theologian - monk who studied theology and then

went after women. - (Def Exh H- PAu 2-283-460 -

Def Exh D(MTP)). (The theologian character

was developed through biblical references

because the tenant was created to ridicule all

the freaks and outcast of society and

dysfunctional families in society.

Kevin in meet the parents who got you

into carpentry? Iguess I would have to say Jesus “if

your gonna follow in someone’s footsteps who better

than Christ” Kevin explains in biblical reference -

why he was a carpenter his analogy takes all the

biblical references from The Tenant and The

Dysfunctionals ( However biblical reference

would be /Jesus Aast supper/ grace at the table,

mother must have carried the cross, the cock

crowed until it was singing a song)

Deleted Scene Rusty Bridge — spitting on the floor

— taking his son to hooters to look at girls for some

App. 60

family bonding “Dysfunctional” // similar // Vinny

spitting on the floor when he’s talking to his boss in

the dinner and taking Stimmy to the peep parlors to

look at girls. ( Def Exh H —PAu-2-283-460 - Def

Exh D (MTP)).

Meet the Parent and Meet the Fockers are

a product of plaintiffs Stolen Federal Copyrighted

Material independently created entitled The Tenant

and/or The Dysfunctionals the characters portraying

the awkward and humorous situations were

developed 4 years prior to Meet the Parents and

Meet the Fockers. The resemblance is overwhelming.

The Defendants rely on as “Indisputable

Documentary Evidence” Meet the Parents a

copyrights. However, the defendants use the name

and a few scenes with no sequel in relation to Meet

the Fockers because everyone in this Meet the

Parents 1991 version is dead including the dog.

Meet the Parents distorted VHS (1991)

Clarke

A distorted VHS that looks like it was shot

in the 60’s with no written copyright the credits seem

to be the only undistorted scene. The very few scenes

characterized only in Meet the Parents with no

scenes in Meet the Fockers. However, plaintiff's

“Stolen Federal Copyrighted Scenes and Characters

are numerous and excessive in both Meet the

Parents and Meet the Fockers. The plaintiffs sequel

is used in meeting another dysfunctional family.

However, defendants had more than enough of

App. 61

material in plaintiffs stolen Federal copyrighted

materials entitled The Tenant and/or The

Dsyfunctionals whatever the defendants didn’t

extract out of the plaintiff's stolen Federal

Copyrighted Materials in Meet the Parents they used

in Meet the Fockers that’s why it is fair to say that

defendants projects Meet the Parents and Meet the

Fockers are a product of plaintiffs “Stolen Federal

Copyrighted Materials” The Tenant and/or The

Dysfunctionals this back dated 1991 VHS only

proves that the defendants objective was to

subterfuge and conceal the use of plaintiffs Stolen

Federal Copyrighted Materials entitled The Tenant

and/or The Dysfunctionals.

Meet the Parents VHS (1991)

The movie narrated at first by a gas

station owner, A normal family until the end, a stick

is thrown into the lake for the dog to fetch the dog

drowns. The sister commits suicide and is found

swinging from a rope in her bedroom. (Sister’s dead).

The father a retired gas station owner comes down

the stairwell with a shotgun and accidentally kills

his wife and other daughter (Both mother and

daughter are dead) and supposedly the father dies of

a heart attack in the process.

This blockbuster has no sequel because

everyone in this project is dead including the dog.

However, a sequel was in the making for this 1991

blockbuster. — The sequel once again narrated by a

gas station owner: A totally different man witha

totally different chain of events taking his children to

the circus. “A Trip to the Circus” another tragedy

App. 62

that will most likely resemble the same outcome of

the 1991 MTP everyone will wind up dead.

The “Stolen Federal Copyrighted

Materials” were independently created by the

plaintiff and entitled The Tenant and /or The

dysfunctionals.

The Characters:

CIA Agent, Nurse Character, Mother (submissive

character) Attorney Character, Doctor Character,

Carpenter Character, The Theologian / Monk

Character Baby Character, Police Character, Judge

Character, Correction Officer Character, Flight

Attendant Character, Detective Character, Relative

Characters, In-Law Characters. Importantly to

note, that none of these Characters are portrayed in

the distorted 1991 VHS copyright of Meet the

Parents by Gregg Glienna and Mary Ruth Clarke’s

version.

The defendants also fail to mention that the

scenes below are from the “Stolen Federal

Copyrighted Materials” entitled The Tenant and/or

The Dysfunctionals that were independently created

by the plaintiff and entitled “The Tenant” and/or The

Dysfunctionals’. Importantly to note, that none of

these scenes below are portrayed in the distorted

1991 VHS copyright of Meet the Parents by Gregg

Glienna and Mary Ruth Clarke

The Scenes:

The initial meeting where Jack Byrnes/landlord

mans a window moving the curtain/blinds with a

App. 63

cynical and apprehensive attitude in meeting (MTP/

Tenant) Scene, Full luggage (MTP/Tenant) Scene,

Car Scene — What kind of car do you drive/ what do

you drive a standard or automatic (MTP/Tenant)

Scene, Hidden Surveillance Camera (MTP/Tenant)

Scene, Frayed Wire Spark (MTP/Tenant) Scene, Lie

Detector Test (MTP/Tenant) Scene, Focker /Fucker

both relating to persons in a comical aspect

(MTP/MTF/Tenant) Scene, Little Fockers/Little

Fuckers both relating to children in a comical aspect

(MTP/MTF/Tenant) Scene, Bestiality Joke (MTP/

Tenant) Scene, Roof (MTP/Tenant) Scene, Volleyball

(MTP/Tenant) Scene, Skimpy Bathing Suit (MTP/

Tenant) Scene, Ransacking the luggage bag

(MTP/Tenant) Scene, Jimmying the Locks open

(MTP/ Tenant) Scene, Renovations (MTP/ MTF/

Tenant) Scenes, Asian dialect (MTP/Tenant) Scene,

Disguise Voice (MTP/Tenant) Scene, Southern

Dialect (MTP/Tenant) Scene, I’m Watching you

(MTP/MTF/Tenant) Scenes, Investigative

(MTP/MTF/Tenant) Scenes, Interrogation

(MTP/MTF/ Tenant) Scenes, Gay Ridicule

(MTP/MTF/Tenant) Scenes, Pot head dilated pupils

pill popper crack head drug related (MTP/Tenant)

Scenes, Spew (MTP/Tenant) Scene, Animal

Shelter/ASPCA-(MTP/Tenant) Scene, Shredded

Clothes in a bizarre manner which leads to both the

tenants eviction and Gregg’s eviction

(MTP/Tenant)Scene, Race Home Scene (driving

erratically) in where they pull up parallel exactly 3

times to try to get home to get rid of the evidence

(MTP/Tenant) Scene, Time Conscious (MTP/Tenant)

Scene, Karate (MTP/MTF/Tenant) Scene, Being

carried away by police by arms and legs while acting

like a raving lunatic (MTP/Tenant) Scene. Airport

Scene which results in arrest (MTP/Tenant) Scene,

App. 64

Ferber/Focker/ Dysfunctional/Rational method in

bringing Children up, Sign Language making facial

expression while mimicking arms and hands with

the intent of a sexual gesture for comical purposes

(MTF/Tenant) Scene, Military School — Quasi

Military (MTP/Tenant) Scene, Truth Serum where

true feeling emerge (MTP/ Tenant) Scene, Square

Dance (MTF/Tenant) Scene, Hospital baby being

born both families worried about the competence of

the person delivering. (MTP/ Tenant) Sex

Exhibitions (MTF/Tenant) Scene, Sex talk when

was your first time and details (MTF/Tenant) Scene,

Barry Focker in-law typical sexual deviant stalker

that is ridiculed in the Tenant and/or The !

Dysfunctionals (MTF/Tenant) Scene. Jackknifing the

car (MTP/ Tenant) Scene, Ordained Minister — The

Theologian / Monk (MTF/Tenant) Scene, Psychiatrist

Scene getting down to the foundation of the problem .

(MTF/ Tenant) Scene. Psychiatrist Scene going into

childhood (MTF/Tenant) Scene, Stun Gun

(MTF/Tenant) Lazar Gun (MTF/Tenant) Scene,

Police Chase (MTF/Tenant) Scene, Mammary Gland

and Rubber Dolls (MTF/Tenant) sexual deviant

Scene, Judge (MTF/Tenant) Scene.

The defendants rely on the distorted VHS

MTP 1991 version claiming that the plaintiffs

defendants’ feel they are ripe for summary judgment

— The defendants contentions are absurd and any

juror in the world after viewing the characters and

scenes will only come to one conclusion. That the

defendants acted in concert knowingly and willing in

the use of plaintiffs stolen federal copyrighted

materials entitled The Tenant and/or The

Dysfunctional in the making of their projects entitled

App. 65

Meet the Parents and Meet the Fockers and that the

defendants should not prevail, profit or benefit from

acrime .

See Character and Scene Similarity.

The very few scenes are portrayed in Meet

the Parents and no scenes are portrayed in Meet the

Fockers from the back dated VHS copyright of Gregg

Glienna and Mary Ruth Clarke that was solely used

in a premeditated scheme carefully devised in an

attempt to subterfuge and mask the blatant use of

plaintiffs “Stolen Federal Copyrighted Materials”

entitled The Tenant and/or The Dysfunctionals in the

making of defendants projects “Meet the Parents”

and “Meet the Fockers”.

| The reason why “The Tenant and/or The

Dysfunctionals fit so squarely into Meet the Parents

and Meet the Fockers is because both project :

combined are a product of plaintiffs “Stolen Federal

Copyrighted Materials” entitled The Tenant and/or

The Dysfunctionals.

See Character and Scene Similarity

The plaintiffs independent creation of The

Tenant and/or The Dysfunctionals’ needs no sequel to

further prove the case because Meet the Parents and

Meet the Fockers are a product of plaintiffs Stolen

Federal Copyrighted Materials entitled The Tenant

and/or The Dysfunctionals. However, in further

proving consistency the tenant after being evicted

from the premises seeks to mect another

aysfunctional family which gives rise to the

defendants Meet the Fockers.

Facts

App. 66

The defendants working in concert used

very few scenes in Meet the Parents and no scenes in

Meet the Fockers from the pre-dated 1991 VHS

unlawful use of plaintiffs “Stolen Federal

Copyrighted Materials” which were independently

created and entitled The Tenant and/or The

Dysfunctionals. It is quite clear and evident in these

proceedings that Meet the Parents and Meet the

Fockers are a product of plaintiffs “Stolen Federal

Copyrighted Materials” entitled The Tenant and/or

The Dysfunctionals. The “similarities of scenes

and characters are overwhelming” and it is quite

clear and evident that the defendants acting in

concert used the pre-dated VHS copyright of 1991 to

mask their unlawful conduct.in using the plaintiffs

“Stolen Federal Copyrighted Materials” The Tenant

and/or The Dysfunctionals in the making of there

projects entitled Meet the Parents and Meet the

Fockers.

These Character and Scenes bear extreme

resemblance which include and are not limited to

The CIA Character, The Pam Character, The

Psychiatrist Character, The Nurse Character, The

Police Character, The In — Law Characters , The

Michael Angelo Of Carpentry Character, The

Theologian Monk Character - The initial meeting

scene (cynical and apprehensive as he waits the

arrival looking out the window, lie detector test

scene, the hidden video camera scene, the volleyball

scene, the skimpy bathing suit scene, the cheap

bottle of champagne scene, the bestiality joke scene,

karate scenes. Eavesdropping scenes, investigation

App. 67

scenes, incarceration scenes, police scenes, race home

scenes, pulling up parallel scenes, shredded clothes

in a bizarre manner scene, concerned neighbor scene,

dilated pupil scenes — pot head, Carpentry scene

wood from another country, driving crratically

scenes, disguise voice scence, football scenes, stalking

scenes, Pamela Dysfunctional method in bringing up

children, lazar stun gun scene, Asian dialect scene,

airport scene, truth serum scene, square dance scene,

jackknife the car scene, The friction between the

landlord and tenant — the animosity and

ambivalence that leads to a chain of event in where

the tenant is terrified and thinks the landlord is a

stalker, the drawer scene, ransacking belonging

scene, renovation scene, I’m watching you scenes,

fucker referred to an individual in a comical aspect ,

little fucker referred to children in a comical aspect

the same as Mother fucker in a comical aspect. The

tenant leaving to meet another dysfunctional family

squarely fits into Meet the Fockers.

“Extremes in Revisions”

The defendants is the ultimate product of a

vaguely described theft, Plaintiffs have curiously

alleged the defendants “went through extremes in

revisions and manipulations in an attempt to conceal

and subterfuge said crime by revising said

screenplay’.

When plaintiff alleges that the defendants

“went through extremes in the revisions and

manipulations in an attempt to conceal and

subterfuge said crime by revising said screenplay the

plaintiff means that the defendants knew at all times

that they were in possession of plaintiffs “Stolen

App. 68

Federal Copyrighted Materials” entitled The Tenant

and/or The Dysfunctionals. The plaintiff used the

backdated copyright with the intent of masking and

subterfuging the theft and changed some scenes

around.

Revisions and manipulations are obvious:

For instance : The frayed wire and spark scene used

for plaintiffs lie detector test was used to start the

fire in the yard. However, the use of the lie detector

test whether it is home made or Antique still serves

a similar purpose to seek the truth.

The use of the mammary gland as opposed to the use

of the rubber dolls which again is revised however

the rubber dolls and the mammary gland serve a

similar purpose through police investigation which

labeled the characters sexual deviants one and the

same.

The Ferber —Focker method as opposed to the

Dysfunctional - Rational method which is self evident

in the novel as they still serve a similar purpose.

The defendants use a sex therapist to bring plaintiff's

“Stolen Federal Copyrighted Materials in for a PG

rating.

The defendants bring in little Jack to bring in sign

language, Ferber-Focker Method, Scar Face, the

tongue and mouth movement and mimicking of his

arms and hands are used by little Jack to bring out

the sexual deviants that the Tenants ridicule

however the overall message is similar.

The plaintiff has proven numerous and

overwhelming similarities in scenes and

characters in which a jury would have no

problem rendering a verdict on behalf of the

plaintiff.

App. 69

The plaintiff through discovery would most

likely be able to reveal the theft ring involved in the

plaintiffs “Stolen Federal Copyright Materials

entitled The Tenant and/or The Dysfunctionals. The

plaintiff believes that this copyright theft ring is

highly sophisticated and if given the opportunity

through discovery the plaintiff believes that these

perpetrators will be brought to justice.

The plaintiff also believes that the

defendants’ in this action know exactly where the

plaintiffs “Stolen Federal Copyrighted Materials”

entitled The Tenant and/or The Dsyfunctionals came

from and used the back dated 1991 distorted VHS

in a blatant attempt to mask, conceal and

subterfuge the blatant usc of plaintiffs “Stolen

Federal Copyrighted Materials” entitled The Tenant

and/or The Dysfunctionals into the making of Meet

the Parents and Meet the Fockers.

The theft occurred on or about August 215%

1998 the police report number 980626165 the project

stolen was entitled The Tenant- (PAu-2-283-460

dated April 27‘, 1998). After viewing Meet the

Fockers and then viewing Meet the Parents. I

constantly badgered Robert Epstein into helping me

formulate a complaint against the defendants he

constantly procrastinated so I decided to begin

formulating on my own.

When Robert Epstein found out that I was

formulating a complaint he told me that he would

notify Rico his friend from L.A. in where the actual

theft occurred, However, prior to any phone call

App. 70

Robert Epstein explained to this plaintiff, that he

would have to sign a retainer. Robert Epstein also

informed me that during the conversation I would

have to remain silent. The gist of the conversation

seemed somewhat tailored as Rico would go quiet

before answering each question and took his time

answering. However, during the course of the

telephone conversation Rico made it clear that the

script had been changed as he informed Robert

Epstein to read it. Rico Semonini during this

conversation made it quite clear and evident that

Robert Epstein was also in possession of plaintiffs

“Stolen Federal Copyrighted Materials entitled The

Tenant and /or The Dysfunctionals.

Prior to any theft occurring on or about

January of 1997 Robert Epstein constantly badgered

me on reading my script entitled The Tenant and/or

The Dysfunctionals (TXu -775-750 dated

December 24“) 1996). Robert Epstein promised

this plaintiff that he would never divulge any of the

content in said project, claiming that he was an

attorney vowing that he would keep all materials

confidential. Robert knew that I was in the process of

starting my own film production company and

wanted to break into the film industry with this

project. Robert Epstein also knew he would be of

counsel to my production company, I believed in

Robert Epstein because I thought he was my friend.

Robert Epstein was the only person in

possession of plaintiffs copyrighted novel The

Tenant and/or The Dysfunctionals TXU-775-750

dated December 24'» 1996 ) prior to the theft in

L.A on August 215+ 1998 of plaintiffs Stolen Federal

App. 71

Copyrighted Material entitled The Tenant (PAu-2-

283-460 dated April 27» 1998).

However, Robert Epstein helped me

formulate a complaint against the defendants in

doing the jurisdiction portion, attorney fees cause of

action and reverse passing off in the Lanham Act.

Robert Epstein had also informed me that John

Hamburg a writer on both Meet the Parents

and Meet the Fockers went to school with Adam

Schlesinger an attorney from the office.

During the course of the summary judgment [

asked Robert Epstein for an affidavit concerning the

said conversation with Rico Semonini. Robert

Epstein refused to give an accurate account of said

conversation concerning Rico Semonini. This

plaintiff firmly believes that a sophisticated theft

ring is involved with the “Stolen Federal Copyrighted

Materials” and the defendants in this case have

acted jointly in concealing, masking and subterfuging

the blatant use of plaintiffs “Stolen Federal

Copyrighted Materials” entitled The Tenant and/ or

The Dysfunctionals in the making of Meet the

Parents and Meet the Fockers.

The overwhelming similarities are quite clear

and evident that the defendants in this case used

plaintiffs “Stolen Federal Copyrighted Materials”

entitled The Tenant and/or The Dysfunctionals in the

making of defendants projects entitled Meet the

Parents and Meet the Fockers.

The back dated 1991 VHS copyright of Gregg

Glenna and Mary Ruth Clarke’s purpose for the

defendants in this case was to pre-date plaintiffs

App. 72

independent creation “Stolen Federal Copyrighted

Materials” entitled The Tenant and/or The

Dysfunctionals. The backdated 1991 copyright has

very few scenes in Meet the Parents and no scenes in

Meet the Focker. However, plaintiffs “Stolen Federal

Copyrighted Materials entitled The Tenant and/or.

The Dysfunctionals has numerous and overwhelming

comparisons scenes and characters to the

defendants Meet the Parents and Meet the Fockers.

It is fair to say that Meet the Parents and Meet the

Fockers are a product of plaintiff;s Stolen Federal

Copyrighted Materials entitled The Tenant and/or

The Dysfunctionals. The sequel intended for The

Tenant and/or The Dysfunctionals is to Meet Another

Dysfunctional Family which squarely fits into Meet

the Fockers. There is no sequel for the back dated

dead.

Whatever the defendants didn’t extract from

plaintiffs “Stolen Federal Copyrighted Materials”

entitled ‘he Tenant and/or The Dysfunctionals In

the making of Meet the Parents they used in the

making of Meet the Fockers. That’s why it is fair to

say that defendants projects entitled Meet the

Parents and Meet the Fockers are a product of

plaintiffs Stolen Federal Copyrighted Materials

entitled The Tenant and/or The Dysfunctionals.

Conclusion: Meet the Parents and Meet the

Fockers are a product of plaintiffs independently

created copyrights (Stolen Federal Copyrighted

Materials) entitled The Tenant and/or The

Dysfunctionals.

App. 73

The reason why Meet the Parents and Meet

the Fockers enjoyed worldwide success is because

they used all the materials from plaintiff “Stolen

Federal Copyrighted Materials entitled The Tenant

and/or The Dysfunctionals. The overwhelming

comparisons in scenes and characters are proof.

Defendants’ rely on the Independent

creation in this case however it is abundantly clear

that Meet the Parents and Meet the Fockers are a

product of plaintiffs Stolen Federal Copyrighted

Materials entitled The Tenant and/or The

Dysfunctionals. The defendants in the film industry

have access to all different copyrights and contracts,

the defendants use of the 1991 VHS use very few

scenes in Meet the parents and no scenes in Meet the

Fockers concerning this backdated distorted VHS

1991 which has no sequel for Meet the Fockers

because everyone in the family including the dog is

dead.

The only real purpose of this distorted 1991

backdated VHS was to mask, conceal and subterfuge

the unlawful use of plaintiffs “Stolen Federal

Copyrighted Materials” entitled The Tenant and/or

The Dysfunctionals.

CONCLUSION

For the foregoing reasons, plaintiff respectfully

request that this court deny defendants motion for

summary judgment in it’s entirety and grant the

plaintiffs such other and further relief as the court

deems just and proper.

App. 74

Dated: New York, New York

September 2, 2006

/s/ Joseph Ardito

Joseph Ardito

Chivalry Film Productions and Joseph Ardito

97-12 76. Street

Ozone Park, New York - 11416

Tel No. (917) 435-2820

App. 75

Table of Similarities between “Meet the

Parents” and “The Tenant” and/or “The

Dysfunctionals”

Meet the Parents

The Tenant and/or

The

Dysfunctionals

The story starts in

Chicago but takes place

The story takes place in

New York

in New York

Def Exhibit G - Txu-

775-750

Page 1 — 1st sentence

Train Train Scene

Def Exhibit H — Pau-2-

283-460

Page 3 - 1st paragraph

—1st sentence.

Hospital Scene — Man

with [V

Hospital Scene -Woman

with [V

Def Exhibit J - PAU- 2-

423-720

Page 52 - 6th

paragraph

Gregg practicing at the

hospital to a patient on

how he is going to

propose to his fiancée.

Jo Jo, now fourteen,

nervously looks forward.

His eyes are wide, as he

combs his hair.

Jo Jo — Pam, w-w-will

you go out with me’?

Suddenly, there is a

App. 76

[Meet the Parents The Tenant and/or

The

a ST Dysfunctionals

pounding at the door. Jo

Jo has been standing

before the bathroom

mirror.

Def Exhibit J Pau-2-

423=720

- | Page 13 -— Top

School Scene School Scene

Gregg on his knees Jo Jo—Jo Jo ask Pam

practicing to ask Pam to | out.

marry him, however he

finds out he needs her Def Exhibit J — Pau-2-

Father's approval. 423-720

7 _| Page 14

Gregg’s Full Luggage Stimmy’s Full luggage

Bag is lost. bag

A moving truck drives

by. Once it has passed,

we can see Stymie

struggling from his car

toward Vinny’s house

with an over-packed

suitcase.

Def Exhibit J —- Pau-2-

423-720

Page 78 - 2"4.

Narration from the

bottom.

Dina Byrnes — The Jo Jo (During Jo Jo’ high

App.

Meet the Parents

The Tenant and/or

The

Dysfunctionals

attitude is confirmed by

Pam’s mother when she

states to Jack Byrnes

“No one was ever good

enough for your

daughter.

school years he was

attracted to a girl named

Pam in his history class.

Pam would notice Jo Jo

smiling at her from time

to time but any chance

for a true romance was

zilch being that being

that Pam came from the

affluent side of town.

Exhibit H — PAU - 2-

283-460

Page 12 - 1

paragraph - through

to 14)

Jo Jo (At this point had

mixed feelings. Jo Jo

kissed Pam back

thinking to himself this

would be his only kiss).

Pam knew her parents

were against any kind of

relationship with this

lad.

Jo Jo (Cared about Pam

but didn’t want to delve

into a complicated

relationship or head

App.

Meet the Parents

The Tenant and/or

The

Dysfunctionals

game. At the end of the

movie Jo Jo kissed Pam

goodnight.) [ll guess will

meet sometime in the

future. This was the last

time they saw one

another for a while.

Pam — Maybe we will.

(Both teenagers were too

young to comprehend the

reality of the situation

and with the threat of

rejection, stalemated a

relationship).

Exhibit H - PAU- 2-

283-460

Page 14 — 1st five

Characters including

narration.

Gregg pulls up to the

house the father is

manning the window

and moves the curtain

with a cynical and

apprehensive attitude —

The mood: and music is

very Cynical —

Stimmy (Pulls up to the

house thinking he’s

punctual. The landlord

(Vinny) is viewing the

potential tenant through

a broken blind. Stimmy

walked up to the front

door and rang the bell

about 4 times. Stimmy

App.

Meet the Parents

Dysfunctionals q

The Tenant and/or

The

notices from a distance a

dilated pupil peaking

through the blind

watching his every

move. This type of

behavior seemed quite

peculiar even to Stimmy,

the potential tenant.

Stimmy happen to have

his cellular phone handy

and called Vinny, to see

why he wouldn't answer

the door.)

Vinny are you there?

Please pick up its

Stimmy, the new tenant.

Vinny (Picked up as

Stimmy was leaving his

message.) Hello, Stimmy

its Vinny what took you

so long? You're late.

Stimmy (Looked quickly

at the broken blind and

noticed that the dilated

pupil disappeared)

Vinny - I thought [ was |

on time, it’s only

1'O'clock/

App. 80

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Vinny - Maybe on your

fucking watch, mine says

4:30

Stimmy (Didn’t want to

argue over the 30

minutes because he was

in dire need of an

apartment. However,

Stimmy now knew that

Vinny’s clock was set a

half an hour ahead of

eastern standard time.

Sorry, Vinny it won't

happen again, _ traffic

was unbelievable. Are

you going to let me in?

(Stimmy hears a dial

tone).

Vinny — What took you

so long? Come on in

Stimmy.

Vinny - After 4 o'clock I

decided to take a shower.

I didn’t hear the bell ring

if that’s okay with you.

Stimmy noticed Vinny’s

hair was dry that Vinny

didn’t really take a

shower.

| Def Exh. H —PAu-283-_

App. 81

Meet the Parents

The Tenant and/or |

The

Dysfunctionals

460

Page 88 Paragraphs I1-

Roof Scene

Analogy

Focker climbed up on the

roof in an attempt to

pursue the cat (Jinx)

while up there he

decided to have a smoke.

Jinx vanished into thin

alr.

Of course Focker has to

eavesdrop on a Jack

Byrnes's conversation _

Roof Scene

Analogy

Roof Scene - Jimmy

climbed up from the 24

story window to the

rooftop like a monkey,

in an attempt to pursue

a nosey neighbor.

Defendant’s Exhibit H

- PAU-2-283-460

Page 24 - Qund

paragraph last

sentence.

The neighbor took off

like a scared cat and

vanished into’ thin

air). You Mother fucker'

Exhibit H PAU- 2 -

283-460

Page 24 — Next to last

paragraph last

sentence.

The tenant picks up the

App. 82

Meet the Parents

The Tenant and/or

The

NESS SEE = === ——

Focker drops his

cigarette and slips

causing the leave to

ignite in the gutter. He

tries to put the fire out

and kicks the gutter that

somehow frays two

wires off the house

sparking.

The sparks ignite on the

leaves and we now have

the spreading like

wildfire.

Dysfunctionals

extension and

eavesdrops on_ the

landlord’s conversation.

Def Exhibit H PAU- 2-

283-460 —

Page 125 7th

Character narration.

Lie Detector ‘Test —

Stimmy found himself

bound and gagged to a

chair, now witnessing

Vinny plugging in the

extension cord into the

electrical outlet. (frayed

wires) Vinny _ started

touching two (frayed)

wires showing Stimmy

the sparks

Defense Exhibit H -

PAU- 2-283-460

Page 97 - 3rd

Character 1st and 24

sentence.

Stimmy (Looks at Jo Jo

who seemed _ sincere

about keeping his secret,

was now spreading like

Meet the Parents _

The Tenant and/or

The

Dysfunctionals

Focker after starting the

fire from the roof had

claimed to be in the

shower however his

hair was dry.

Focker got a quick tour

of the house

Jack - The toilet is not

flushing right in this

bathroom.

| Stimmy

wildfire. covering the

receiver). You told him

right?

Def Exhibit H PAU-

2-283-460

Page 8:7 - 10th

Character narration.

Stimmy (Noticed that

Vinny’s hair was dry,

and if he was in the

shower, who was

looking out the window?

thought to

himself that Vinny was a

cartoon character,

Def Exhibit H — PAU-

2-283-460

Page 88

Vinny (Gave Stimmy a

quick tour of the

house.)

Def Exhibit H - PAU-

2-283-460

Page 88 - 2™4 to last

Character

App.

Meet the Parents

| The Tenant and/or |

The

Dysfunctionals

Jack Byrnes was a

Control Freak

Pam told Focker try not

to be sarcastic

——EE

Vinny - The bathroom

is in the process of

renovations, once they

are completed, the rent

will obviously go up a

few dollars. You

understand.

Def Exhibit H — Pau-2-

283-460

Page 89 - 1st

Paragraph ard

sentence.

Vinny — Stimmy I made

dinner reservations at

an exclusive restaurant.

We will discuss the lease

at the restaurant. It will

protect both our interest.

(As Vinny referred to an

item he had in a paper

bag.) Please, I heard

about. your habits, try

and be on your best

behavior at this

restaurant, because I’m

_a regular there.

otimmy began to

App. 85

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Jack Burns to Focker

What do you drive their

a ford? Interesting color

did you pick it? They say

only Geniuses pick green

but you didn’t pick the

color?

(The ambivalence and

animosity between the

two becomes quite

apparent which creates

the rivalry.)

Pam’s future Father-In-

Law ridicules Stimmy

when he misses the turn

in the Race home scene.

acknowledge that Vinny

seem to be some sort of

Control Freak, the way

he carried himself, and

ordered him around in

such a demanding

manner.)

Vinny told Stimmy in an

arrogant manner. Now

get your fucking car.

Stimmy (Looked at

Vinny in shock for a

second, not believing

what he had just heard.

Stimmy with a bit of

sarcasm retorted.)

What did you say?

Vinny ‘Then

fucking car.

get you

Stimmy (Figured, Vinny

was paying for the meal,

so he had to drive.)

Okay.

| Vinny - (Upon entering

App.

Meet the Parents

The Tenant and/or

The

Def Exhibit C-Meet

the Parents (DVD).

Dysfunctionals

Stimmy’s car,

complained about

everything for instance)

Why did you buy a

standard shift? How

about if I need to borrow

your car?

(The entire ride to the

restaurant, Vinny was

badgering Stimmy the

potential tenant on

his driving — skills.)

Where the fuck did

you learn how to

drive like that?

Stimmy would you

please leave me alone.

Vinny (Giving Stimmy

turning directions, once

he was already in the

intersection screaming

out to him, at the top of

his lungs.) Make a right,

a left now! (Uf Stimmy

missed the turn he

wouldn’t hear the end

of it.)

Def Exhibit H — PAU

App.

Meet the Parents

The Tenant and/or

The

Dysfunctionals

2-283-460

Page 89 - 11th

Character.

Vinny- Yeah, ~ what?

What kind of car do

you drive?

Victims Husband -

station wagon.

Def Exhibit H - PAU-

2 —283-460

Page 99 - 5th & 6th

Character from

bottom.

Elmer Fudd Elmer Fudd

impersonation Scene impersonation

Dina Byrnes — “Where is | Scenes.

my “Widdle girl” Elmer

Fudd

Def Exhibit C-Meet

the Parents (DVD).

Def Exhibit H — Pau-2-

283-460

Mid paragraph page

137

Lost Luggage Scene at

Airport — Focker gets

spewed up on.

Mother Brynes

Jo Jo spewed up.

Passengers on the plane

| became repulsed from

App.

Meet the Parents

The Tenant and/or

The

Dysfunctionals

complains of smell

Def Exhibit C-Meet

the Parents (DVD)

the smell of spew

Exhibit H — Pau-2-283-

460

Bottom of page 168

Anything you need just

ask me casa es su casa

Make yourself at home.

Unique last name Focker

(The name Focker is

prevalent throughout

both Meet the Parents

and Meet the Fockers,

the intent of the usage

can only be construed

as referring to Fucker

again referring to an

individual).

Def Exhibit C-Meet

the Parents (DVD)

, attention _

“Fucker” is prevalent

throughout all the

plaintiffs copyrights it

refers to an individual in

a comical aspect.

Def Exhibit H — PAU-

2 —283-460

| Pages 50,

118,160,168,169,232

etc, etc, etc.,

The content of

material used in

expressing this _ story

may be a bit distasteful

and offensive the author

expresses his deepest

apologies to you the

reader. The reason for

the decadent vocabulary

usc 1S incumbent to

receive the kind = of

and

the

App.

Meet the Parents

The Tenant and/or

The

Dysfunctionals

recognition the author

climaxes on. The

inclination of such a

reaction is to pursue the

comical aspect of this

novel to its fullest

extent.

Def Exhibit G — Txu-

775-750

Page 5 — 1st Paragraph

Jack Brynes gets a call

and tells the travel agent

to disguise his voice with

a southern accent,

Def Exhibit C—Meet

the Parents (DVD)

Vinny is leaving a

message on Stimmy’s

answering machine, in a

disguised voice.

Def Exhibit H — PAU-

2-283-460

Page 100 - 3rd

character 1st sentence

I wish you didn’t tell you

parents I hate cats, but

you do hate cats

Stimmy began reading

the grounds for divorce,

as his buddies were

sneaking a peak, finding

out that Stimmy had

some really bad habits.

These chaps weren't

aware of Stimmy’s

habits that were now

exposed and led to an

embarrassing situation.

When Stimmy noticed —_|

App. 90

Meet the Parents The Tenant and/or

The

Dysfunctionals_

that his buddies were

Def Exhibit D-Meet sneaking a peak he

the Parents (DVD). asked them to keep

certain stipulations

confidential, both

buddies were sworn to

secrecy.

Exhibit G - TXU- 775-

Focker claimed it wasa_ | 750

nightmare. Page 57 Last

Paragraph.

Def Exhibit C-Meet Jo Jo explained to

the Parents-(DVD). Stimmy that his brother

Vinny was looking for a

roommate and that he

would give him a call, he

promised Stimmy he

could hook him up.

Stimmy had no idea that

his real nightmare was

about to begin.

Exhibit G — TXU — 775- |

750 |

Page 58 1st Three |

sentences.

Jo Jo told Stimmy that

he and his brother

_| needed some privacy.

App. 91

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Stimmy could see from

the table Jo Jo laughing

hysterically, like a nut

whispering to Vinny.

Stimmy went over to the

phone to say hello to

Vinny the brother

handed the phone over

to Stimmy. The landlord

was telling Stimmy that

his last tenant had some

“Bad Habits” and left the

premises in an

ambulance, pretty much

fucked up. Vinny |

explained how he had

rules and regulations

that had to be abided by

and would not tolerate

“bad habits” do you know

what I mean? Stimmy

looked at the brother

who seemed sincere

about his secret that was

beginning to spread

like wildfire.

Def ExhibitG TXU-

775-750

1st Paragraph

Jack Byrnes — Not many

men in your field

The brother Vinny told

the tenant that he'd fix

App.

Meet the Parents

The Tenant and/or

The

Dysfunctionals

(This is how the whole

Nurse character

developed for Meet

the Parents and Meet

the Fockers including

the constant

insinuations and

ridiculing that Focker

may be gay.

Def Exhibit C-Meet

the Parents (DVD)

him up on a hot date and

the she was on her way.

The landlord explained

to the tenant that she

was a nurse that he met

at his brother’s

psychiatric ward. Vinny

told Stimmy to take a

quick shower and _ get

ready. After the shower

Stimmy went into the

downstairs bathroom to

shave. Stimmy heard a

loud thump outside of

the house. The bell rang

Stimmy peaked out the

window and saw a

woman in a_ nurses

uniform, with a big head

looking a bit strange as

she was downing a bottle

of beer. Stimmy opened

the door and to his

surprise the peculiar

looking woman

resembled the landlord.

When in fact the tenant

finally realized it was

the landlord with a wig

on dressed up like a

bitch he let out a sigh of

| disgust.

App.

Meet the Parents

| The Tenant and/or

ee ee

The

Dysfunctionals

Def Exhibit G - TXU--

775-750

Page 123 - 1°

Paragraph.

Jack Brynes — Is your

loved one, safe witha

stranger? Can you

really trust another

human being? Yes or

no?

Focker answers yes!

Jack Brynes ~ Wrong the

answer is no!

Def Exhibit C-Meet

the Parents (DVD).

The content of this book

will help you develop a

sense of cynicism prior

to becoming a statistic

yourself by a

dysfunctional, if given

the chance could possibly

turn your life into

shambles.

Def Exhibit G —- TXU-

775-750 |

Page 4 — 4** sentence. .

Jack Byrnes - Trust me

Gregg when you have

"Little Fockers”

running around your

gonna’ need protection.

(Focker is used in these

the ordinances are

“Little Fuckers” a

Defendants’ Exhibit H |

— Pau-2-283-460

Page 110 - 1st

Paragraph next to last

sentence.

Jimmy (To make sure

App. 94

Meet the Parents

The Tenant and/or

The

Dysfunctionals

two projects entitled

Meet the Parents and

Meet the Focker ina

comical aspect refers to

individuals Fuckers).

Def Exhibit C-Mect

the Parents (DVD),

enforced, Jimmy

walks through the

railroad rooms with a

flashlight, shining the

light in the little

fuckers (children)

eyes, to see who’s in

defiance of the

sleeping code. )

Def H — Pau — 2-283-

460

Page 10 Last

paragraph narration.

Jack - You like Peter

Paul and Mary [Puff the

magic dragon.

Great song

Focker -Who really

would have thought it

wasn't about a dragon,

Jack - What do you mean

Fecker -You know the

| whole drug scene.

To puff the magic dragon

Dilated Pupil — peaking

through the blinds

(Dilated pupil would

refer to high status a pot

head).

App. 95

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Jack —Puff is just the

name of the boys magic

dragon

Focker are you a pot

head ?

Focker — I tried it but

Jack — Yes or No Focker

Def Exhibit C- Meet

the Parents (DVD).

Def Exhibit H — Pau-2-

283-460

Page 88 274 Sentence.

Jack Brynes - Hospital

worker looking for access

to ludes. We already

know he puffs the magic

dragon.

Def Exhibit C-Meet

the Parents (DVD).

Crack and Overdose

Def ExhibitG TXU-

775-750

2°4, sentence — Page 91

Worker dragging behind

him some dismembered

limbs

Def Exhibit C-Meet

the Parents (DVD).

“Cheap Bottle of

| Champagne Scene”

Dragging behind him

some dismembered limbs

Def Exhibit — I - PAU-

2-380-629

Page 14 - 4th

Paragraph — 24

sentence

“Cheap bottle of |

App. 96

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Focker wanted to

purchase an expensive

bottle of champagne —

However they only have

Mums instead of an

expensive champagne.

La Heim !

Focker makes grotesque

faces at the urn and

camera at the end.

Def Exhibit C- Meet

the Parents (DVD).

champagne Scene” A

very hyper man breaks

out the bottle of

champagne,

camouflaging the label

with a pink cloth. After

the pouring they raise

their champagne glasses

preparing for che holiday

toast with puzzled faces,

as the stock ysst is

delivered by Jimmy.

Let’s hope this holiday

doesn’t wind up like last

year!

Salute !

Defendants Exhibit H

— Pau-2-283-460

Page 15 = 5th

Character.

Jimmy , looks through

the window, is making

yrotesque faces

stretching his face with

his hands. The nurse

holds up his child, and

the facial activities stop.

App. 97

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Def Exhibit G. TXU

775-750

Page 14 - Last

paragraph, last

sentence.

Focker spying on Jack

picks up a magazine and

opens it and Jack sees a

picture of a woman and

breast pumps. Focker

claimed to have been

brought up on a farm.

Jack brings up a cat

named Cheppetto

(Puppet).

Bestiality Joke

Gregg explains why he

was looking at the

magazine with breast

pumps and elaborates on

how he was brought up

in Detroit Michigan but

it wasn't a farm per se //

Gregg explains that he

had a litter of cats and

one cat couldn’t make it

to the mothers teethe

and he went in and just

milked into a little

saucer. nipple so he

Husband (Sees her about

to enter the closet) Oh!

Stay out of the fucking

closet or you'll be joining

my puppets!

Def Exhibit H - PAU 2

~—283-460

Page 51 - 9th

Character.

Bestiality

Joke

I would now like to

give you an example of

the love Jimmy had for

his neighbors. Jimmy

was busy doing some

carpentry work on his

second floor apartment.

A sticky beak neighbor

wanting to engage ina

friendly chat initiates

the following

App. 98

Meet the Parents

The Tenant and/or

The

Dysfunctionals

milked the nipples

Mrs Brynes - I had no

idea you could milk a cat

Gregg you can milk

anything with nipples

Jack states: “Focker I

have nipples could you

milk me too.

Deleted Scenes/

Jack - Maybe Gregg does

it to the cats like people

do it to the sheep.

Def Exhibit C- Meet

the Parents (DVD).

conversation.

Neighbor (Notices

Jimmy working

diligently.) Hello, Jimmy

what are you doing up

there ?

Jimmy (The neighbor

could see Jimmy’s head

bobbing up and down in

the window. No reply

was given to the

neighbor . However,

Jimmy began swinging

the hammer more

fiercely, trying to give

the neighbor a hint as to

“fuck off’)

Neighbor tried a second

time to initiate some sort

of conversation as to

what Jimmy was doing

up there?

Jimmy (Wiped the sweat

from his brow and

replied to the noisy

_ neighbor in a boisterous

| tone.) Hey, scum bag!

| I’m fucking a chicken up —

App. 99

Meet the Parents

The Tenant and/or

The

Dysfunctionals

time conscious.

Def Exhibit C- Meet

the Parents (DVD)

Dina — Gregg never had

a home cooked meal.

| They were always

| Jack Burns was always |

here, would you like to

come up and hold his

head down!!

Def Exhibit Pau 2-283-

460

Page 23 — 2nd

paragraph down

Time Conscience.

(The landlord would

have to be at work a 7

a.m. in the morning, but

due to his tardy phobia

he ritually awoke every

morning at 3:45 a.m.

Def Exhibit H ~ Pau-

283-460

Page 98 - 274

paragraph 1>t

Sentence.

Vinny told Stimmy he

did not like being tardy.

Def Exhibit —-G - TXU-

775-750

Page 62 Last Par. 24

& 3™4, sentence.

The kids rush over to the |

pizza, and begin fighting

for their slices.

App. 100

Meet the Parents

The Tenant and/or

The

Dysfunctionals

fighting in the kitchen

over containers of

Chinese food.

Def Exhibit C- Meet

the Parents (DVD)

Def Exhibit J —- Pau-2-

423-720

Page 24 - 1st

Paragraph.

Jack Brynes wife Dina’s

Character very

permissive and easy

going the rational one.

Def Exhibit C-Meet

the Parents (DVD).

(Jimmy’s wife’s

Character very

permissive and easy

going the rational one).

Till get your dinner ready

honey, it’s going to take

a couple of minutes to

heat up.

Exhibit H — Pau 2-283-

460

Page 3 8th Character

last sentence.

Focker is wearing Pams

bathrobe.

Jack what’s with the

rob?

Don’t worry about what

happen today. Lets put

all that behind us and

enjoy our weekend

together.

Def Exhibit C-Meet _

Carlo pulls up to the

house and honks his

horn. He gets out of the

car. The front door to the

house opens and Carlo’

Father wanders out ina

woman’s bathrobe.

Def Exhibit I PAU 2-

380-629

| Page 53 34,

App. 101

Meet the Parents

The Tenant and/or

The

Dysfunctionals

the Parents (DVD).

paragraph from the

top.

One more thing under

our roof it my way or the

long Island expressway

keep your snake in its

cage ///

Def Exhibit C-Meet

the Parents (DVD).

Vinny - Rules and

regulations of the house

Pll tell you what ’'m

talking about homo,

there are rules and

regulations that have to

be abided by and I will

not tolerate “bad habits”

you understand me!

Def Exhibit H - Pau 2

— 283-460

Page 87 - 9th.

Character.

Jack Burns - Just

something about him

that’s a little off! Greggs

Eaves dropping on Pam’s

parents.

Gregg’s Eavesdropping

Def Exhibit C-Meet

the Parents (DVD)

Stimmy’s Eavesdropping

Listening to the

conversation between

the brothers and began

to choke.

Def Exhibit H - Pau 2-

283-460

Page 126 4th

Character — narration

I just realized something

“Pamela Martha Focker”

Simei

Mother Fucker — You

mother fucker you've

been giving me trouble

App. 102

Meet the Parents

The Tenant and/or

The

Dysfunctionals

(Martha Fucker in

these 2 entitled

projects Meet the

Parents and Meet the

Fockers is intended to

mean in a comical

aspect Mother

Fucker)

| Def Exhibit C-Meet

_the Parents (DVD)

house.

Defendant’s Exhibit H

PAU-2-283-460

Pages 17 2.4 character

24d sentence from the

end.

Additional.Pages:/23/2

4/29/30/37/47/48/54

/99/102/1/

111/117/129/132/135/15

7/165/179/189

224/231/235

Martha ~ The name isa

character in the tenant.

Def Exhibit H — PAU-

2-283-460

Page 143 Top of page

1st character.

The content of the

material used in

expressing this story

may be a bit distasteful

and offensive the author

expresses his deepest

apologies to you the

reader. The reason for

the decadent vocabulary

use 1S incumbent to_

App. 103

Meet the Parents The Tenant and/or

The

Dysfunctionals

receive the kind of

attention and

recognition the author

climaxes on. The

inclination of sucha

reaction is to pursue the

comical aspect of this

novel to its fullest

extent.

Def Exhibit G — Txu-

775-750

Page 5 — 1st

Paragar ph.

CIA Character Scene.

Mistress — What

happen?.

Jo Jo — What do you

think happen?

(Jo Jo first looks

cautiously peels out,

| going through a steady

App. 104

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Picture of Jack Brynes

with President Clinton.

Picture of Jack Brynes

with a turban on in Arab

red.

Mistress — You mean to

tell me, they just let you

go, without arresting or

ticketing you?

Jo Jo — flicks his wallet

at her, than puts it

away.

Give me a break don’t

you know who I am?

Mistress — I have no

idea, who you are!

Jo Jo — I’m fuckin CIA

baby! That’s who the

fuck I am. [ll have both

those fucking cops

sucking dick on the beat

for the next ten years!

(Jo Jo grabs a cellular

phone from his glove

compartment, dials a

number. The mistress

realizes that a few wires

are protruding from the

phone, and the back

panel is missing).

JoJo—Hello, Bill? |

App. 105

Meet the Parents

The Tenant and/or |

The

Dysfunctionals

disguise, referring to

some sort of covert

operation.

Picture of Jack Brynes

with a General.

Def Exh C-(MTF).

What’s going on? You

don’t say, cock sucker!

I'll jump on the first

plane to Washington,

and we'll discuss the

invasion over dinner in

the oval office!

The mistress notices Jo

Jo watching her from the

corner of his eye.

Mistress — Who are you

speaking to?

Jo Jo — Excuse me!

Excuse me! (Clears his

throat and covers the

phone) You have no idea

who the fucking

president of the United

States 1s?

Mistress (Scared

Shitless) You talking to

the President of the

United States? Wow how

impressive!

Jo Jo— That’s right! The

president of the United

Fucking States

(screaming)

App. 106

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Slick Willie, that’s right!

Slick Fucking Willy,

leave the invasion up to

me!

I'll push the fucking

button don’t worry.

Ill push the button. I

know you need a skate

goat!

The CIA Scenes are

inclusive in all the

scripts. //

Exhibit J — Pau 2-423-

720

Mid paragraph on

Page 39 and page 40.

Also in Exhibit H

Focker wakes up in the

morning and Jack is

right next to him ina

chair — You have to keep

this a secret if you know

CIA Scene

Regular — So what do

you do for a living ?

Jo Jo — (Jo Jo doesn't

make eye contact with

the regular). I don’t want

to talk about it.

Regular — Come on your

could tell me.

Jo Jo - Hey what the

App. 107

Meet the Parents

The Tenant and/or

The

Dysfunctionals

—_ -- a

what's good for you

Def Exhibit C- Meet

the Parents (DVD).

fuck are you writing a

book ! Fucking CIA pal,

now keep your mouth

shut, if you know

what’s good for you.

Exhibit H — Pau 2- 284-

360

Page 134 - 6t — 9th,

Characters.

Gregg Fell into a secret

door

Looking for something

Gregg

I heard a noise and came

down to see if everything

was okay.

A door opened and Vinny

comes flying down the

stairwell.

Def Exhibit H — Pau-2-

284-360

Stimmy (Stimmy

believed he had _ the

landlords undivided

attention. As if he were

really interested in what

Stimmy had to. say.

However in the midst of

said conversation the

landlord passed _ out

snoring. While Vinny

was ina state of REM on

the couch. Stimmy in

trying to give’ the

landlord the benefit of

the doubt, began looking

for clues of a_second

App. 108

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Def Exhibit C-Meet

the Parents (DVD)

individual in the house

to vindicate the landlord.

He anxiously walked up

the stairwell to

investigate his alleged

suspicion, upon

conclusion the reality of

said situation had been

confirmed. That Vinny

was one sick puppy.

Def Exhibit H- Pau 2-

284-360

Page 95 -

characters.

Last - 2

Jack Byrnes - Antique

polygraph machine try

that on — straps Gregg to

the machine and begins

to ask a series of

questions / See if he is

telling the truth.

Old Fashion Lie

Detector Test is in all

scripts and novels.-

(Vinny thought Stimmy

was a trespasser).

Stimmy - When Stimmy

regained consciousness,

he found himself bound

to a chair, now

witnessing Vinny

plugging in an extension

cord, into an electrical

outlet. Vinny began

touching the two wires,

showing Stimmy the

sparks. Stimmy was

dazed not able to

App. 109

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Def Exhibit C-Meet

the Parents (DVD).

comprehend the full

extent of Vinny’s show

and tell. Until Vinny

began flicking the wires

on him). Ahhhhhh

Ahhhh! Stop, stop, ’'m

your tenant the lease is

on the table!

Exhibit H- Pau-2-283-

460

Page 97 34

Paragraph.

Jack Brynes -Have you

ever watched

pornographic videos ? No

the needles are jumping /

Def Exhibit C-Meet

the Parents (DVD)

Real Estate Agent and

Potential Buyers. (The

tric looked down the

stairwell through the

mirrors reflection and

saw the landlord stretch

out on the catch bare ass

watching a Chinese

Porno Flick

Def Exhibit H - Pau -

2-284-360

Page 53 1st Paragraph.

Gregg is traumatized

sitting up in the corner

of his bed //after taking

the lie detector test and

telling Pam what he’s

been through.

Stimmy is traumatized -

What reasoning

convinced you to

electrocute me with the

wire? .

App. 110

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Def Exhibit C-Meet

the Parents (DVD).

Def Exhibit J —- Pau-2-

423-720

Page 97 - 5t.

Character last

sentence.

Jack Brynes jimmied the

locks open on Focker’s

luggage.

Def Exhibit C-Meet

the Parents (DVD)

Luggage comes Jack

Brynes goes through

Jack Brynes went

through Gregg luggage

and found a dildo

Pair of black panties and

a whip. This led Jack to

believe that Gregg was

some sort of a sexual

deviant.

Def Exhibit C-Meet

the Parents (DVD)

Stimmy- heard his door

being jimmied as Vinny

gained access to his

room.

Def Exhibit H — Pau —

2 — 283-460

Page 137 — 2"4 par. 1st

and 2"4 sentence.

On one occasion he

thought he saw the

landlord (Vinny)

ransacking his

belongings). Hey, what

are you doing in my

personal belongings.

Def Exhibit H - Pau-2-

283-460

Page 97 Stimmy 7*h

paragraph 2 last

sentences.

Sex Paraphernalia —

dildo masochistic black

mask

App. 111

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Def Exhibit F

742-462

Page 92 — 3rd

paragraph 34

sentence.

- TXU-

Gregg is wakes and is

startled as he sees Jack

Brynes right next to

him.

Def Exhibit C-Meet

the Parents (DVD).

One night the tenant

was having nightmares

and awoke in a semi-

conscious state, he

looked over to where the

chair was planted and

saw the landlord sitting

in the chair starring at

him.

Def ExhibitG TXU-

| 775-750

Page 72 - Last

paragraph — 3".

Gregg came down for

breakfast and met the

in-laws — Some got a

Def Exhibit C-Meet

the Parents (DVD).

visit frora the hair fairy.

alr.

Exhibit H PAU-2-

283460

Page 96 — 7th

Character 4th

sentence

| No one laughs at his

jokes he felt alienated.

When the chaps realized

that the women were not

laughing at their jokes,

App. 112

Meet the Parents The Tenant and/or

The

ores 7m Dysfunctionals a

Pay a little visit to the they began to feel

shower fairy. alienated and figured

that maybe the women

were not accustomed to

the kind of sick humor

they had been

Def Exhibit C-Meet accustomed to their

Exhibit H - PAU2-283-

460

Page 75 - 8th character

(narration) 1st

sentence.

Go Away Mat-Denny’s Leave me alonc.

room.

Exhibit G - TXU-775-

750

Def Exhibit C-Meet Page 72 - 4th sentence.

| the Parents (DVD) - it Re

Denny — Hey! Hey! By the way Oliver Twist

What are you doing in stay out of my drawers,

my drawers? remember before you

people leave you are

subject to search and

Def Exhibit C-Meet seizure.

the Parents (DVD).

Def Exhibit H

PAU-2-283-460

Page 52 - 8th,

App. 113

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Where you just sniffing

my boxers dude?

Def Exhibit C-Meet

the Parents (DVD).

Character.

The mute was found in

the couple’s bedroom, the

draws had been

ransacked and he was

found sound asleep in

the couples bed with the

wife’s panties over his

head.

Def Exhibit G - Txu

775-750

Page 163 - Last

Sentence

Gregg I was petrified of

your dad when you told

me he was a retired

florist.

Def Exhibit C-Meet

the Parents (DVD).

The tenant is confiding |

in a friend about his

living conditions on how

he’s afraid of the

landlord.

Def Exhibit H PAU-2-

283-460

Page 132 3'4,

Character last

sentence. _

Focker called it a

nightmare!

Nightmare — Stimmy

had no idea that his

nightmare was about to

begin.

App. 114

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Def Exhibit C-Meet

the Parents (DVD).

Def Exhibit F-— TXU-

742-462

Page 32 — 6th -

Paragraph

Circle of Trust

Def Exhibit C-Meet

the Parents (DVD)

Jack Brynes lets Focker

back into the circle.

We will now take into

consideration that Old

cliché “Birds of a feather

flock together” History

plays an important role

here, just as a war

brings a country

together in a time of

crisis. The characters

portrayed in this novel

show a sick sense of

allegiance towards one

another, due to the

experiences growing up

in such a demented

environment. This

fidelity creates a bond

forming these chaps into

a crew.

Exhibit G TXU -775-

750

Page 8 Last

Paragraph

The tenant aftertwo

App. 115

Meet the Parents The Tenant and/or

The

Dysfunctionals

Def Exhibit C-Meet weeks had past was

the Parents (DVD). without incident the

brother and landlord

finally apologized for

there outrageous

behavior, which relieved

the tenant greatly. The

landlord explained to the

tenant that the behavior

perpetrated on him was

sought of an initiation to

the family. However, the

brothers were still

looking for the burglars

who robbed the tenant

that night.

Def Exhibit F - TXU-

742-462

Page 71 - 2"

Paragraph

Jack Brynes - Activate The landlord had also

the alarm t-minus 15 had a tardy phobia that

seconds I don’t want to he was going to he late

be late ///////// going to be | for work his job didn’t

late --- start until 7a.m. in the

morning but he had to be

the first on the sight.

App. 116

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Def Exhibit C-Meet

the Parents (DVD).

Defendant’s Exhibit G

— Txu — 775-750

Page 92 - 2nd.

paragraph last

sentence

Jack Byrnes I will be

watching your every

move studying your

every move and if I find

that you are trying to

corrupt my first born

child

I will bring you down to

China Town!

Stimmy notices from a

distance a dilated pupil

peaking through the

blind “watching his

every move”. (This

type of behavior seemed

quite peculiar even to

Stimmy, the potential

tenant.

Def Exhibit H Pau 2-

283-460

Page 88 1st Paragraph

4th and 5t* sentence.

Vinny - Hey, Stimmy I

just got rid of my wife,

I really don’t need

anybody watching my

every move.

Def Exhibit H — Pau 2-

283-460

Page 125 — 7th

Character 1stSentence

| When he entered the

App. 117

Meet the Parents The Tenant and/or

The

Dysfunctionals

visiting room the

orderly’s were instructed

watch Vinny’s every

move.

Def Exhibit G TXU-

775-750

Page 101 34 full par

down 34 sentence.

The landlord watched

the trio’s reaction

through the same

reflection in which

they were watching

him.

Def Exhibit - G- TXU

Def Exhibit C-Meet — 775-750

the Parents (DVD). Page 35 — 3r4-

Paragraph last

sentence.

Watched with

binoculars

Def Exhibit — G-

Page 21 - 4th sentence

Brother looking to

quite his job,to

App. 118

‘Meet the Parents

The Tenant and/or

The

Dysfunctionals

“Watch the Tenant”

Def Exhibit F - TXU-

742-462

Page 33 - Paragraph 2

~ 2.4 and 3'4 sentence.

Skimpy Bathing Suit

Scene

(Focker)

Def Exhibit C-Meet

the Parents (DVD).

The chaps beach attire

and dinner attire where

one in the same a

skimpy bathing suit and

from a right angle you

could see his testicles

hanging out.

Exhibit G TXU-775-

750

Page 136 — 24

Paragraph -— 3"

sentence.

Volleyball Game Scene —

hit in the nose.

(Pam’s Sister)

Def Exhibit C-Meet

the Parents (DVD).

Volleyball zame Jo Jo

just picked up a girl who

just broke her nose

playing volleyball.

Def Exhibit F TXU

742-462

Page 95 — 3rd.

Paragraph middle to

end.

App. 119

Meet the Parents — |

The Tenant and/or

The

Dysfunctionals

Deleted Scene Crawl

Space —

Jack Brynes -

Investigating Focker —

Time is of the essence

running Greggs name to

Whether he’s really is

who he says he is.

Def Exhibit C-Meet

the Parents (DVD).

I want him locked up,

Stimmy as he entered

the premise heard the

landlord spelling out his

name to some kind of

telephone official on the

phone.)

Def Exhibit H - PAUD-

2-283-460

Page 129 - 1st Par. 3rd

and 4th sentence.

Regulars (Being a bunch

of cynical pessimist, set

out to investigate Jo Jo

in finding the truth. The

finding would be

concluded in a week, at

the next coffee

conference.

Def Exhibit H - PAU

2-283-460

Page 134 - 34

| paragraphfromthe |

App. 120

Meet the Parents

The Tenant and/or

The

Dysfunctionals

bottom 15t, two

sentences.

Jack Brynes - Honey this

kid has been lying to us

since we met him.

Def Exhibit C-Meet

the Parents (DVD).

After an intensive

investigation it had been

concluded, that the

brother had nothing to

do with any type of Law

enforcement agency

Exhibit H —PAU - 2-

283-460

Page 134 - 3r4,

paragraph from the

bottom last two

sentences.

Jack Brynes - Honey this

kid has been lying since

we met him ///

Def Exhibit C-Meet

the Parents (DVD)

Jimmy Don’t listen to

that piece of shit, he’s

been giving me trouble

since he came into the

family.

Def Exhibit —H - Pau

2- 283-460

Page 19 — 11.

Character

Vinny That guy

(Stimmy) is nothing but

trouble, I caught him

eavesdropping on my

conversation.

App. 121

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Pau 2-283-460

Page 128 - 6th

Character

Kevin - A carpenter as a

hobby put Bolivian

warm wood floors in and

had wood from different

countries.

Def Exhibit C-Meet

the Parents (DVD).

Jack Brynes speaks

Asian dialect

Vinny — The defendant

told the plaintiff that he

would specially order

cabinets from Vienna

The defendant kept

looking away as he was

estimating the prices as

if he wasn’t quite sure on

what to charge.

However, the defendant

assured the plaintiff that

he was highly qualified

and the Michael Angelo

of Carpentry.

Def Exhibit G_ - TXU-

775-750

Page 153 — 3r¢

paragraph 4¢.

sentence.

Vinny (As they began

walking up the stairwell,

Vinny noticed that the

potential buyers were of

Asian descent. Vinny

standing in a karate

stance throwing kicks

and punches began _

App. 122

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Def Exhibit C-Meet

the Parents (DVD).

Gregg looking for Jinx in

the car says “Fucker”.

Def Exhibit C-Meet

the Parents (DVD).

talking Chinese fluently

to the potential buyers.

Def Exhibit H — PAU -

2-283-460

Page 52 — 4th

Character

Fucker

Def Exhibit G TXU -

775-750

Pages

11/14/24/27/32/80/102/1

27/

140/ etc.

Def Exhibit — PAU-2-

283-460

Pages

50/118/128/129/160

Driving Eratically Pulls

up Parallel at the light

focker you’re a wild man

at the wheel .

Jack pulls up Parallel

Focker what's the matter

with youupi were sil[[pse

tp ,ale tjat ;eft at the

light focker //

I wonder if he has a

license you're a lunatic

ipiciiceecsnnes

Race Home — Pulls up

parallel

App. 123

Meet the Parents

The Tenant and/or |

The

Dysfunctionals

Jack talk Thai — dad is

not retired

Terrified of you // I think

you have some serious

issues///

Jack Brynes — While

calling from a payphone

from the restaurant

received a message from

a concerned neighbor in

relations to his cat Jinx.

Def Exhibit C-Meet

the Parents (DVD).

The plaintiff within

minutes of finding his

house in total disarray

received a phone call

from a concerned

neighbor. The neighbor

asked why the police and

the ASPCA were over his

house. The plaintiff was

in shock to hear such an

accusation.

Def Exhibit G - TXU-

775-750

Page 156 Paragraph 3

— 2»¢ sentence to the

end.

Jack Byrnes threatens

Gregg at the Tuxedo

Shop thinking that

Gregg is a bad influence

and is going to corrupt

his daughter.

___| If you fuck with my

Stimmy’s Father-In-Law

- Threatens Stimmy.

App. 124

Meetthe Parents

The Tenant and/or

The

Dysfunctionals

I will bring you down to

China Town — [ll be

watching you!

Def Exh C (MTP))

Jack Brynes retrieved

his messages from a pay

phone and a concerned

neighbor called

claiming to have found

his cat Jinx without his

collar.

Animal Shelter

Gets the cat from the

animal shelter Focker

Spray paints the cats tail

so the cat would look like

Jinx. When they

returned home from the

restaurant the house

| was in total disarray. _

daughter I will give you

a smile like a clown.

Def Exh H-PAu-2-283-

460

Page 85 — 9th

Character.

When the plaintiff

entered his apartment it

seemed as though an

earthquake had hit the

premises. ‘/

The plaintiff within

minutes of finding his

house in total disarray

received a phone call

from a concerned

neighbor who lived

beneath him.

Def Exhibit G TXU-

775-750

App. 125

Meet the Parents i

; The Tenant and/or

The

Dysfunctionals

Their belongings were

shredded across the

room in a bizarre

manner.

Bizarre manner.

Def Exhibit C-Meet

the Parents (DVD).

Jack Brynes jimmics

open Gregg’s luggage

that has arrived. The |

- 5th, sentence and

Paragraph 2"4 34 and

4th sentence. .

Stymie pulls up by

Vinny’s house . His

belongings are burnt and

shredded across the

front law.

Def Exhibit J - PAU 2-

423-720

Page 133 — Last Par.

Ist & 2"4 sentence.

Stimmy drove home. As

he pulled up to the front

of the house, he saw all

his personal belongings

thrown all over the

street in a bizarre

manner.)

Exhibit H - PAU- 2-

283-460

Page 232 — last

paragraph 5th & 6th

sentence.

Stimmy that morning

heard his door being

jimmued- when the door

App. 126

Meet the Parents

The Tenant and/or

The

Dysfunctionals

content sexual (Dildo,

Whip, Black Panties.)

Referring to Gregg as an

S&M Masochistic —

Sexual Deviant.

Def Exhibit C-Meet

the Parents. (DVD).

Focker Drives ---stops at

light // race home stops

at the light // Jack pulls

up parallel eye contact//

Jack pulls up paralied//

Jack pulls up parallel

eye contact // I'm

watching you -- // Jack

just turned you were

suppose to make the left

at the turn Focker ////

opened-cleaned out

Stimmy’s wallet.

Def Exhibit H — PAU-

2-283-460

Page 137 ~— 24d & 3rd

sentence.

Ridiculing a sexual

deviant

Witnesses giving

statements:

Def Exhibit F - txu-

742-462

Page 92 - 1st 2.4 and

3°4 sentences.

Race Home — The

incident that led to the

straw that broke the

camels back, was when

Vinny was caught by his

wife, Thelma pulled up

parallel up to a traffic

light she look over and

saw a man that

resembled her husband

with a woman in the car.

The couple were sexually

molesting one another in

curs

App. 127

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Pulls up parallel

exactly 3 (three)

times.

Def Exhibit C-Meet

the Parents (DVD).

Jack Brynes - Screaming

— you spray painted his

broad daylight. So

Thelma decided to pull

up parallel again at the

next traffic light to get a

better view. To Thelma’s

surprise the man driving

the car was her husband

who shguld have been at

work. Thelma couldn't

believe her eyes so she

pulled up parallel this

time she began beeping

her horn continuously to

get her husbands

attention When he made

eye contact he realized

that the bitch beeping

the horn was his wife.

Pulls up parallel

exactly 3 (three)times.

Def Exhibit G - TXU-

775-750

Page 26 - 2"4,

Paragraph — 24

| sentence to the end.

After the drop off the

husband immediately

App. 128

Meet the Parents ;

The Tenant and/or

The

Dysfunctionals

tail to make him look

like jinx — tried to beat

us hack so he could get

rid of the evidence.

Def Exhibit C-Meet

the Parents (DVD).

proceeded home in an

effort to substantiate an

alibi.

Exhibit F TXU-742-

462

Page 15 - Last

paragraph last

sentence.

How could you do

something like that you

set the alter on fire // I

had a smoke he put so

much lacquer, “Frayed

Wire with sparks set

the fire”.

Def Exhibit C-Meet

the Parents — (DVD).

The Frayed Wire

Sparks from the LIE

detector test caused the

fire. Began touching the

two wires showing

Stimmy the sparks.

Exhibit G - is part of

this writers

Page 97 —- Paragraph 2

— 2d sentence.

Gregg’s cat destroyed the

inside of the house and

the bridal dress and

tuxedo’s are shredded

all over the room ina

bizarre manner/

Receptionist — (Stimmy)

You have been evicted

and your shit 1s in the

street.

Stimmy pulls up to

Vinnys house his

belongings were burnt

and shredded all over

the front lawn.

App. 129

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Get out of my house

Focker and take the cat

with you.

Def Exhibit C-Meet

the Parents (DVD).

Def Exhibit J PAu 2-

423 -720

Page 133 - Last Par. —

1st and 2™4 sentence.

The Eviction

(Stimmy drove home as

he pulled up to the front

of the house, saw all of

his belongings thrown all

over the street ina

bizarre manner).

Def Exhibit - PAU-

2283-460

Page 232 Last 2

Characters

Dina Brynes - Jack can’t

talk Thai!

Husband (Screams out )

You didn’t know I could

speak Chinese ha!! Well

I happen to speak seven

different languages .By

the way Oliver Twist

stay out of my drawers,

remember before you

people leave you are

App. 130

Meet the Parents

The Tenant and/or

The

Dysfunctionals

Def Exhibit C-Meet

the Parents (DVD).

subject to search and

seizure.

Exhibit H

283-460

Page 52 3™4 Character

from the bottom.

- PAU-2-

Gregg - Your parents are

breaking us apart.

Def Exhibit C-Meet

the Parents (DVD).

Dina He still not good

enough for Pam you

never warmed up to

Kevin until she warmed

up to him /// maybe it’s

time you think about

what she wants //

Def Exhibit C-Meet

the Parents (DVD).

| understand. _

Pam- Well, | would love

to, but you know my

parents would be against

it.

Def Exhibit H — Pau-2-

283-460

Page 14 — 3rd

Character

Jo Jo (Could not deal

with a condescending

attitude. So as an

excursion Jo Jo evaded

any future dates. Jo Jo

knew to make the best of

that night. Jo Jo

intentionally distant

himself from Pam,

because of his inability

to psychologically deal

with rejection. Jo Jo

grabbed Pam’s hand and

held it exclaiming !). I

App. 131

Meet the Parents

The Tenant and/or

The

Dysfunctionals _

Def Exhibit H - PAU -

2-283-460

Page 13 - Last 3

paragraphs.

App. 132

Table of Similarities between “Meet the

Fockers” and “The Tenant” and/or “The

Dysfunctionals”

Meet the Fockers

The Tenant and/or The

Dysfunctionals

Train Scene

Def Exhibit D-Meet the

Fockers (DVD)

Train Scene

Def Exhibit H- PAU-2-

283-460

Page 3 —- 1st Paragraph

-1st sentence.

Ferry Scene

Def Exhibit C-Meet the

Parents (DVD)

Ferry to Fire Island

Def Exhibit H - PAU-2-

283-460

Page 78 -10** narration

Ist sentence

Hospital Scene Room :

Focker delivering a baby.

Def Exhibit D-Meet the

Fockers (DVD).

Hospital Emergency

Room

Det Exhibit H- PAU-2-

283-460

Page 5 - 1st Paragraph -

lst sentence

The family is frantically

seeking a doctor to

deliver their baby.

Focker who’s not a doctor

is in the process of

delivering the baby./

Family feels

apprehensive due to

Focker’s medical

qualifications and the

fact that he’s a nurse and

Jimmy (Pacing back anc

forth) Where is this

fucking doctor ?

Doctor Rosenberg —

(Comes in and sees

Jimmy pacing the floors

by the operating room.

Hello Jimmy, how are

you doing?

App. 133

Meet the Fockers The Tenant and/or The

Dysfunctionals

not a doctor. However, Husband — Fine, I guess

the delivery goes well. today is the big day ha

Doc? (In a whispered

voice) Hey Doc, don’t fuck

this one up!

Doctor Rosenberg —

(Doctor heard what the

husband had said but

played as he didn’t )

What ? Are you talking to

me ?

Husband (In a boisterous

tone as he was walking

away). Listen, I heard

about you mother fucker!

Def Exhibit H - PAU-

2-283-460

Page 5 2,3,4,5 and 6.

Listen my wife’s having a

baby! Don’t gimme no

problem — just get me a

doctor now!

Emergency Room — Night

| Jimmy comes running

| inte the lobby with Rose

| Def Exhibit D-Mect in his arms, who is

| the Fockers (DVD). _| panting in agony.

App. 134

Meet the Fockers The Tenant and/or The

Dysfunctionals

Jimmy — Get me a doctor

now!

Nurse — What seems to

be the problem?

Jimmy what’s it look like,

a fucking square dance?

My wife is about to give

birth.!

My wife is about to give

birth !

Dr. Rosenberg winces

upon seeing Jimmy. He

quickly shakes his hand,

and enters the delivery

room.

Dr. Rosenberg — Good

evening , Mr. Mussino!

He’s gone before Jimmy

can respond.

Rose is screaming with

pain as the Nurses set

her up for delivery. Dr.

Rosenberg enters.

Good evening , Mres

Mussino. How are you?

135

Meet the Fockers

The Tenant and/or The

Dysfunctionals

Rose responds with an

agonizing scream.

Def Exhibit —J - Pau 2-

380-629

Page 7 Next to last

Character

This particular page was

not found in the

defendant's Exhibit I // I

will have to check all

copies now.

Family frantically

looking for a doctor

because his wife is about

to give birth. When

Jimmy finds the doctor he

feels apprehensive due to

doctor’s medical mal-

practices. However, the

delivery goes well.

Jack Brynes sees

Isabella’s son and thinks

its Gregg son.

| Def Exhibit D —- Meet

That's not my baby

doesn’t even look like me.

Whose is it?

Def Exhibit J PUA-2-

423-720

App.

136

Meet the Fockers

The Tenant and/or The

Dysfunctionals

the Fockers (DVD)

Page 9 4t» character

Attorney Character

Bernie Focker — Greggs

Father. Meet the Fockers

Def Exhibit D- Meet

the Fockers (DVD).

Attorney Character —

The Tenant and/or The

Dysfunctionals.

Def Exhibit J — PAU - 2

—423-720

Page 116 — 8th

Character

31 pages are missing in

Pau-2-283-460

a few other pages are

missing in defendants

exhibits.

Gregg wakes up and finds

a note attached to his

chest drawn in magic

marker. Gregg was

sleeping between his

parents and has come to

the conclusion that Jack

has paid him a visit while

he was sleeping.

Def Exhibit D- Meet

the Fockers (DVD).

Stimmy wakes up and

looks in the bathroom

mirror and finds: Cat

Whiskers drawn on his

face- Stimmy has come to

the conclusion that paid

him a visit while he was

sleeping.

Def Exhibit - TXU 775-

750

Page 73 1*t paragraph

Focker fleeing to the

airport with the rock.

Stimmy wind up going to

the vault, taking out the

engagement ring that’s

been all over the

neighborhood. Woman

App. 137

Meet the Fockers

The Tenant and/or The

Dysfunctionals

Def Exhibit D - Meet

the Fockers (DVD).

was last scene fleeing to

the airport with a rock on

her finger.

Def Exhibit G- TXU-

775-750

Page 91 — Par. 1 - 3r4

and 4th sentence

Moses (Focker’s Dog )

humps everything in

sight.

Def Exhibit D-Meet the

Fockers (DVD).

Starts walking down the

peninsula, it’s only a

matter of time before

they start going at it like

two dogs in heat.

Def Exhibit H

Page 132 — 2"4

Character 1st Sentence.

Bernie Focker claimed to

have had one testicle.

Def Exhibit D - Meet

the Fockers (DVD).

Onc Ball

Def Exhibit F -TXU -

742-462

Page 112 - 1st

paragraph

Cop Scene — Gregg and

Bernie get pulled over for

speeding and driving

erratically

Officer — Stay inthe |

vehicle.

Vinny gets pulled over for

speeding, blowing red

lights and driving

erratically.

SS ares | Se eile

Police Officer - Pull over

to the side of the road and

keep your hands on the

App.

138

‘Meet the F ockers

The Tenant and/or The

Dysfunctionals

steering wheel.

Vinny pulled over quickly

and jumped out of his

vehicle running up

towards the patrol car.

Don’t shoot!

Police Officers (Already

had their weapons

drawn.) I told you to stay

in the car and keep your

hands on the steering

wheel!

Bernie Focker — What’s

the problemo Officer?

Vinny — What’s the

problem?

Police - We were going to

ask you that? Let’s see,

speeding at 60 mphina

30 mph zone, running

steady red lights and

driving recklessly. I'd sat

that constitutes a major

problem. Now get in the

back seat of the patrol car

and keep your fucking

mouth shut.

App. 139

Meet the Fockers

The Tenant and/or The

Dysfunctionals

Def Exhibit H PAU 2-

283-460

Page 35 - 6-11

Character.

Page 36- 1st paragraph.

Gregg Focker fleeing

custody trying to get Jack

Brynes attention. A chase

ensued and Gregg was

taken down by a tazer

gun.

Vinny fleeing custody. A

chase ensued and Vinny

was taken down by a

tranquilizer gun, aftera

short scuffle. He is back

in custody and sedated

10:4.

Def Exhibit H — Pau 2-

483-260

Page 227 - 5th Char. 4th

and last sentence.

Jack Brynes approaches

the officer he flicks his

_ identification and gives it

you were driving, you

could of killed someone or

caused a serious accident.

(Vinny regaled to the

officers, anda

confirmation came over

the PA) However, the

next time we see you

driving recklessly, your

coming “downtown”.

App.

140

Meet the Fockers

The Tenant and/or The

Dysfunctionals

to the police officer— Jack

Brynes CIA

Officer responds - CI

what ?

Officer looks at Jack’s

identification says here

you re a retired, what are

you going to show me

next your AARP card.

Jack Brynes — Tells the

officer to stand down or

he’ll be working security

at a retirement home in

Boyton Beach.

Vinny — took his wallet

out of his pocket and

flicked it open and close

quickly, in an attempt to

give his date the

inclination that he was a

man of influence. (CIA)

Date- (And I’m the first

Lady!) Listen, “Elliot

Nest” you think you could

drop me off. I don’t want

to be late for work.

Vinny give me a break ,

you don’t know who I am

do you?

Vinny ’m fucking CIA

baby! That’s who I am do

you understand? [ll have

both those cops walking

the beat in the circus for

the next ten years.

Def Exhibit H — PAU 2-

283-460

Page 36 Paragraphs 6

-10

Page 37 Paragraphs

1-9

App. 141

Meet the Fockers

The Tenant and/or The

Dysfunctionals

Jack Brynes was then

taken down by a “Stun

Gun” and hit with a few

volts.

———-

Stimmy was taken

down by a stun gun

and hit with a few

volts.

Def Exhibit H — PAU —

2-283-460

Page 153 — 1st and next

to last sentence.

Check it out he’s gota

rubber booby.

Def Exhibit D Meet

the Fockers (DVD)

Deleted

Scenes

| Officer - We in a hurry

today?

}

What’s the problemo

The police through a

thorough investigation

found semen on the seats

and 3 rubber blow-up

dolls in the back seat.

The investigation

proposed they were

dealing with some sort of

sexual deviant.

Def Exhibit H -PAU-2-

283-460

Page 120 - 1st

Paragraph 34 and 4th

sentence.

Vinny - What’s the

| problem officer ?

| Officer We were going

App.

142

Meet the Fockers

The Tenant and/or The

Dysfunctionals

officer? -

Officer — The problemo

is you were doing 55

mph in 45 mph zone

to ask you that let’s see

speeding at 60 mph ina

30 mph zone — I'd say

that constitutes a major

problem. Now get in the

back seat and keep your

fucking mouth shut.

Def Exhibit H - PAU-

2-283-460

Page 35 — 10,

Commentary — Jay

Roach stated that the

word Focker wasn’t

used enough.

Character.

Officer -Mr. Fucker - | Fucker

(Fucker — Focker for the

Jay Roach purpose of Meet the

Parents and Meet the

Fockers — Fucker and

Focker are one in the

same this cannot be

disputed.)

Def Exhibit H - PAU-2-

283-460

Pages — 50,

118,120,128,129,160,168,

169,232

O fficer - Jumps out of the

| Vinny pulled over quickly

App.

143

Meet the Fockers

The Tenant and/or The

Dysfunctionals

car remain in the vehicle

you gotta a hearing

problem!

and jumped out of his

vehicle running up

towards the patrol car in

an attempt to avoid

embarrassment and

being ridiculed in front of

his date.

Officers don’t shoot!

Def Exhibit H — PAU-2-

283-460

Page 35 — 9th

Character.

Officer- You want to

dance with me, a little Do

Se Do meaning “Square

Dance”.

Def Exhibit D-Meet the

Fockers (D).

Whai’s this look hike a

fucking square dance?

Def Exhibit I PAU-2-

380-629

Page 7 1st Paragraph

“Page Missing”.

Def Exhibit J — PAU-2-

423-720

Page 7 — 5‘ Character

— 1st sentence.

Poppa freak and baby

freak out for a Sunday

drive

| Gregg is trying to

explain to the officer

Freaks — These freaks of

nature were exposed,

stereo-typed and labeled

sexual deviants.

Det Exhibit H—- PAU-2- |

App.

144

Meet the Fockers

The Tenant and/or The

Dysfunctionals

his mother is a doctor.

Officer - Oh! Mrs.

Freak

Officer- Doctor of what

Looks like you boys

have been doing

interstate porno

trafficking granny

style.

Def Exhibit D-Meet the

Fockers (DVD).

——E

283-460

Page 176 — last

Paragraph- last

sentence.

(Freaks — used in

ridiculing sex maniacs).

Judge —Bring the sex

maniacs before the bench.

(Freaks).

Judge- I have no qualms

on dismissing the charges

against your clients, if

those freaks go back to

the United States.

Def Exhibit H

283-460

Page 184 - 8th. & 14th,

Character

- Pau2-

Oh my ginger bread

Jesus!

Biblical reference

Jesus

Def Exhibit H — Pau-2-

283-460

Page 127 6*6 Character |

Looks to me like the kind

(Velvet Rope meaning

App.

145

Meet the Fockers

The Tenant and/or The

Dysfunctionals

of videos you find behind

the velvet rope.

Def Exhibit D-Meet the

Fockers (DVD).

Red light district

includes pornography

etc).

Landlord 2 — By the way,

you look familiar; do you

hang around the peep

parlors?

Def Exhibit H — Pau-2-

283-460

Page 238 — 9th,

Character 24,

sentence.

Jo Jo - you're a closet

queer, right? |

Drive down to 20' street

and 11'h avenue the

hooker hang out. (Gay

Ridicule).

Stimmy - Were going to

go with hookers?

Jo Jo - Unless you prefer

men? (Gay Ridicule).

Stimmy — Noticed he was

in the “Red Light

District” As Stimmy was

about to pass a peep show

App.

146

Meet the Fockers

The Tenant and/or The

Dysfunctionals

parlor, Jo Jo pushed him

in).

Exhibit H — PAU-2283-

460 .

Page 158 -1st sentence

Officer - Pan in which

your gonna fry.

The police officer had

come to the conclusion

that he was dealing with

sexual deviants — low life

scum.

Def Exh D -MTFP)).

Officer - He probably got

what he deserved

Had come to the

conclusion that he was

dealing with a sexual

deviant low life scum.

Def Exh H - PAu-2-283

460

Page 130 — 1st

Paragraph - last

sentence.

Jack Brynes — To Child

service

Where are you taking my

grandson?

Child services called in

because of evidence

surrounding the case

scenario.

| Def Exhibit D-Meet the

—i._

Author informs readers:

If any type of warped

behavior is being used as

a form of conditioning or

discipline in your

household, stop right here

and notify the child abuse

hotline. (Child services —

warped behavior).

Def Exhibit H — Pau-2-

283-460

App.

147

Meet the Fockers

The Tenant and/or The

Dysfunctionals

Fockers (DVD)

Page 10 — 8th. Character

narration. — 4th

sentence.

Deleted Scenes

Cop said do you want to

Do Si Do (Square dance).

Def Exhibit D-Meet the

Fockers (DVD).

What’s this look like a

square dance.

Def Exhibit I PAU -2-

380-629

Page 7 - 4*» Character

1st sentence.

{Page 7 is missing]

What’s this look like a

square dance.

Def Exhibit J Pau 2

423-720

Page 7 — 5 Character

Sign Language

Little Jack -—- When little

Jack saw lIsabelle’s breast

— he began moving his

tongue and mimicking

hand motions that were

sexually explicit and

undesirable.

Sign Language

They made vulgar facial

expressions, using their

tongue and mimicking

hand motions, which

were sexually explicit and

undesirable.

App.

148

| Meet the Fockers

The Tenant and/or The

Dysfunctionals

This sort of behavior is

ridiculed in the Tenant

and /or Dysfunctionals.

However, the defendants’

used a child to tone down

the sexual content.

Def Exhibit H-Mect the

Fockers (DVD).

Def Exhibit H PAU-2-

283-460

Page 134 — Next to last

character —last

sentence.

(Didn’t catch on, to the

message being conveyed).

Began flicking his tongue

in and out of his mouth,

like a lizard. The tenant

still didn’t get the hint

until the landlord began

mimicking his hands.

Page 154 - 6th,

Character 1st sentence

and 7th Character

whole paragraph.

Gregg is watching Little

Jack and when Jack gets

back / Little Jacks hands

are glued to a liquor

bottle and he’s watching

Scar face.

Scar Face

Def Exhibit J

2-423-720

Page 51 — 1°

Paragraph

(More)

The landlord at this point

began talking like Al

Pacino in Scar Face,

saying t

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