Summary of the initial complaint and few letter exchanges added as exhibits:

Parties :

Noval Williams Films / Craig Williams – Plaintiff.

MJ Estate - Defendant.

Third party who shot the footage – never identified but MJ Estate believes it to be Green Flame Media.

Lightning Entertainment - who has a sales agency agreement with Noval Williams Films


- In 2007 MJ took part in two photo shoots.  Noval Williams Films claims MJ authorized a third party to videotape both photo shoots and the third party is the copyright owner.  Part of the footage has been released publicly or commercially in November 2007.

- In July 2011, a lawyer representing the third party who shot the footage contacted Karen Langford from MJ Estate to sell the footage to MJ Estate.  They showed portions of it to MJ Estate. They asked $250,000 to buy it, additional $250,000 for limited commercial usage (less than 10 minutes) and additional $750,000 to have full rights (so a total of $1.25 Million).  Estate did not purchase it.

- Noval Williams claims MJ Estate passing on the footage gives them right to commercially to use the footage.

- Weitzman in a later letter (dated June 10 2014) disagrees with this position and mentions more details of the exchange between the lawyer representing the third party and Karen Langford. He states from those conversations Estate understood MJ only allowed the footage to be taken with the understanding that it was strictly for his private use and cannot be commercially released without his consent. Weitzman also points out the lawyer for the third party told Karen Langford in 2011 that they were shopping the footage to “private collectors” – hence they were aware that it could not be commercially released.

- In May 2013 Craig Williams has bought the rights to the footage. September 2013 photos were licensed. October 2013, Bonaventura Films got the rights to the footage. November 2013 Noval Williams Films got license to use/release the film from Bonaventura Films.

- In February 2014, Noval Williams Films entered into sales agency agreement with Lightning Entertainment.  At that time there were two offers – Brazilian and North American- to acquire license rights for television. Brazilian deal was finalized later. Negotiations about North American deal were ongoing.

- On May 19 2014, MJ Estate hears that Lightning Entertainment has acquired rights to distribute the “Last Photo Shoots” documentary. Howard Weitzman sends a letter to Craig Williams and Lightning Entertainment stating they understand the documentary has photos/footage of MJ and Estate may have rights to some of them. Weitzman states it’s their understanding that the footage was for MJ’s own use and was done “work for hire” and Estate is unaware of any MJ signed release agreement that would allow the footage commercially released without MJ Estate’s consent.  MJ Estate asks to review the film to determine whether and to what extent MJ footage was used.

- On May 27 2014, Lightning Entertainment notifies Noval Williams if they file a claim against MJ Estate they will be in breach of their agreement.

- On May 28 2014, Noval Williams films reply to MJ Estate saying they acquired the footage from the third party owner, Estate passed on it, there’s no photographs that Estate has rights in the film and no MJ music was used.

- On June 10 2014, Weitzman wrote back mentioning possibility of breach of agreement between MJ and the third party who shot the footage. In his email Weitzman writes “We are still willing to resolve this matter amicably” and once again asks to review the film so that MJ Estate can determine what and how the footage/photographs were used in the documentary.

- On June 12 2014, Lightning Entertainment provided MJ Estate a copy of the film without authorization of Noval Williams Films.

- On June 18 2014, Weitzman sent another letter now claiming co-ownership of copyrights in some photos (at least 7 photographs) and repeating breach of agreement based on the correspondence they reviewed. Weitzman repeats it’s their position that the MJ only allowed footage to be taken for his private use and would not be commercially used without his consent. MJ Estate asked Noval Williams to cease and desist.

- On June 19 2014, Brazilian TV deal was cancelled.

- On June 23 2014, Noval Williams films acquired extended licenses for the photos.

- Lightning Entertainment has not been returning Noval Williams calls or emails.

- Noval Williams Films is asking the court for a declaration that they haven’t infringed any copyrights and MJ Estate has no valid claims.