Neil Boorstyn Filed
680 Beach Street Aug 12 1974
San Francisco, California, 94109 Robert J Hare, clerk
Attorney for Plantiff and Cross-Defendant MARTYN BUCHWALD
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE CITY AND COUNTY OF SAN FRANCISCO
MARTYN BUCHWALD, et al.,
Plaintiffs and
Cross-Defendants,
v. No 572-030
MATTHEW KATZ, etc.,
Defendant and
Cross-Complainant,
MARTYN BUCHWALD, et al.,
No 614-027
Complainants-Appellees,
v. Plaintiff,
Martyn Buchwald's
MATTHEW KATZ, etc., answers to
interrogatories
Respondent-Appellant.
Plaintiff, MARTYN BUCHWALD, pursuant to California Code
of Civil Procedure §2030, and order of Court, submits the
following further answers to defendant's interrogatories as
follows:
All documents identifiedherein, except those specifically
denoted, were previously provided to counsel for defendant;
however, said documents are available for inspection at the
Law Offices of Neil Boorstyn, 680 Beach Street, Suite 354, San
Francisco, California.
-1-
Matthew Katz' questions do not appear here, only Marty balin's answers
192. Yes. I don't remember the dates or the amounts, or
the means. My best recollection is that the payments were
in cash.
193. No
(a) -(f) Not applicable
194. No
(a) -(f) Not applicable
195. No. I never rendered services for or on behalf of
Matthew Katz
196. Not applicable
200. (a) Between September 1965 and 1966
(b) Procured employment for the Airplane without
obtaining an Artists. Manager's License as provided
for in the Labor Code, State of California~ Failed
to follow the provisions of the Labor Code, State
of California, §1700 et seq., sp~cifically §1700.5,
1700.23-.28, 1700.32, 1700.40, 1700.44~ Ordered the Airplane
to go to the placed specified by him without obtaining
an Artists' Manager's License~ He prevented the
Airplane from obtaining its own employments~ He
informed the musical community that "I, Matthew Katz,
am the Jefferson Airplane and all negotiations must
be through me", without obtaining an Artists'
Manager's license~ He attempted to fire me, then the
leader of the Jefferson Airplane~ He failed to
inform the Airplane of income received or the profit
and loss status of the Airplane~ He failed to inform
the members of the Airplane of their rights and
duties in connection with publishing contracts and
publishers~ He failed to act as an agent and ordered
the members of the Airplane to do as he directed~
He required me to sign blank engagement contracts~
13.
He endorsed at least $9,000 of earning ehecks payable
to the members of the Airplane and placed same in his
own bank accounts; He failed to pay bills of the
Airplane; He co-mingled Airplane funds with other
accounts; He antagonized people in the entertainment
industry, including Wess Wilson, Tom Rounds, Barry
Olivier and Ralph Gleason; He failed to place
insurance on musical instruemts; He took an extensive
vacation to the Bahamas in early 1966; He received
and kept money due the Airplane after their notice
of rescission; He required the Airplane to sign a
publishing contract with him; He refused to allow
membe~s of the Airplane to look at the books and
records showing their income and expenses; He im-
properly charged the Airplane with expenses for his
personal businesses and other matters unconnected
with the Airplane; He promised to pay $50 per week
every week to the members of the Airplane, but failed
to provide this; He failed to prepare financial state-
ments; He signed my name to employment contEacts;
He failed to obtain performance money for the Losers
North at the Cabana Hotel, May 22, 1966, in the
amount of $1,200; He failed to obtain performance
money for the Losers North at the Pavillion, San Jose,
August 2 and 5, 1966, in the amount of $2,500; He
failed to pay Bob Harvey; He failed to obtain
performances which a good manager would have obtained;
On several occasions he double-booked the Airplane,
i.e., he approved contracts for performances at the
same time in different locations; He failed to
recognize our interest of 20% in After You Publishing
Co.; He failed to carry auto insurance; He failed
14.
end of document found in Superior Court, San Francisco
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