UNITED STATES DISTRICT COURT

FOR THE
MIDDLE DISTRICT OF TENNESSEE

BRYAN D. JONES and JEFFERY G. JONES, )

)
Plaintiffs, )
)
v. ) Case No. ____________
)
GLAD MUSIC PUBLISHING & RECORDING LP )
d/b/a GLAD MUSIC CO. AND/OR GLAD MUSIC )
PUBLISHING, PAPPY DAILY MUSIC LP, ROUND )
HILL MUSIC LP d/b/a FORT KNOX MUSIC, INC., )
BMG RIGHTS MANAGEMENT (US) LLC, NANCY )
JONES, DAVID L. SNODDY, WORLD-WIDE )
RECORDS, INC., DWAYNE D. MADDOX, III, AS )
ADMINISTRATOR AD LITEM OF THE ESTATE OF )
DONALD EVANS GILBRETH, )
)
Defendants. )

COMPLAINT FOR DECLARATORY RELIEF

Plaintiffs Bryan D. Jones and Jeffery G. Jones, by and through their attorney, for their

Complaint against Defendants Glad Music Publishing & Recording LP d/b/a Glad Music Co.

and/or Glad Music Publishing, Pappy Daily Music LP, Round Hill Music LP d/b/a Fort Knox

Music, Inc., BMG Rights Management (US) LLC, Nancy Jones, David L. Snoddy, World-Wide

Records, Inc., and Dwayne D. Maddox, III, as Administrator ad litem of the Estate of Donald

Evans Gilbreth allege as follows:

I. THE PARTIES

1. Plaintiff Bryan D. Jones (“Bryan”) is a citizen and resident of Huntsville, Texas.

2. Plaintiff Jeffery G. Jones (“Jeffery”) is a citizen and resident of Conroe, Texas.

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 3. Upon information and belief, Defendant Glad Music Publishing & Recording LP

d/b/a Glad Music Co. and/or Glad Music Publishing (“Glad”) is a Texas limited partnership with

its principal place of business in Houston, Texas.

4. Upon information and belief, Defendant Pappy Daily Music LP (“Pappy Daily”) is

a Texas limited partnership with its principal place of business in Houston, Texas.

5. Upon information and belief, Defendant Round Hill Music LP d/b/a Fort Knox

Music, Inc. (“Round Hill”) is a Delaware limited partnership authorized to do business in

Tennessee as a foreign limited partnership with its principal place of business in Nashville,

Tennessee.

6. Upon information and belief, BMG Rights Management (US) LLC (“BMG”) is

a Delaware limited liability company authorized to do business in the State of California as a

foreign limited liability company with its principal place of business in California at 6100

Wilshire Blvd. Ste. 1600, Los Angeles, California.

7. Upon information and belief, Defendant Nancy Ann Jones (“Nancy”) is the

surviving spouse of country music recording artist and songwriter, George Glenn Jones, and is a

citizen and resident of Brentwood, Williamson County, Tennessee

8. Upon information and belief, Defendant David L. Snoddy (“Snoddy”) is a citizen

and resident of the State of Alabama.

9. Upon information and belief, Defendant World-Wide Records, Inc. (“World-

Wide”) is an Alabama corporation with its principal place of business in Muscle Shoals,

Alabama.

10. Dwayne Depew Maddox, III is an attorney duly licensed in the State of Tennessee,

BPR #010805, and is the administrator ad litem of the Estate of Donald Evans Gilbreth

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(“Maddox”), having been appointed by the Probate Court of Benton County, Tennessee on April

12, 2018. In his role as administrator ad litem, Maddox is a citizen and resident of Tennessee

with his law office located at 19695 E. Main Street, Huntingdon, Carroll County, Tennessee.

II. JURISDICTION AND VENUE

11. Jurisdiction is based upon 28 U.S.C. § 1331 as this case is an action arising under

the laws of the United States. It also is based upon 28 U.S.C. § 1338(a) as it arises under the

Copyright Act of 1976, 17 U.S.C. § 101, et seq.

12. Personal jurisdiction over each of the Defendants is proper on the grounds, among

others, that (a) Defendants and/or Defendants’ agents transact and/or transacted business in the

State of Tennessee; (b) Defendants’ wrongful conduct and omissions alleged herein occurred in

the State of Tennessee and in this District; (c) at issue in this action is the disputed ownership or

possession of interests in property located within the State of Tennessee; and (e) Defendants have

offices and/or their principal places of business located in the State of Tennessee and in this

District.

13. Venue is proper in this district pursuant to 28 U.S.C. §§ 1391 and 1400.

III. GENERAL ALLEGATIONS

A. Musical Compositions

14. Plaintiffs Bryan Daily Jones and Jeffery Glenn Jones are the adult sons of the late

country music recording artist and songwriter George Glenn Jones (“George Jones”) and the late

Shirley Ann (Jones) Arnold née Shirley Ann Corley.

15. Upon information and belief, George Jones and Shirley Ann Corley were married

on September 15, 1954. In or about April 1968, a Petition for Divorce, Case No. B-14,469, was

filed in the 163rd Judicial District Court of Orange County, Texas by Shirley Ann Jones, Plaintiffs’

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mother, seeking a divorce from George G. Jones.

16. On or about April 15, 1968 and in contemplation of the divorce, a written

agreement was voluntarily made between Shirley Ann Jones (later known as Shirley (Jones)

Arnold (“Arnold”)) and then-defendant George Jones that reads, in pertinent part:

WHEREAS in contemplation of the pending divorce suit and in settlement

of the community property rights of the parties, SHIRLEY ANN JONES is to
receive as her separate property out of the community estate:

One-half of the song writer’s rights to all songs written by the said George
Glenn Jones, which are presently published or controlled by Broadcast Music
International…

The said George Glenn Jones shall receive as his separate property…

… one-half of the rights to songs that he has published with B.M.I.…

17. On or about June 11, 1968, a Supplemental Property Settlement Agreement was

voluntarily made and executed by Shirley Ann Jones and then-defendant George Jones that reads,

in pertinent part:

WHEREAS, the Property Settlement Agreement was previously entered

into by the hereinabove mentioned parties as of the 15th day of April, 1968,
the parties wishing to amend said agreement, it is hereby agreed that in
contemplation of the pending divorce suit and in settlement of the
community property rights of the parties, SHIRLEY ANN JONES is to
receive as her separate property out of the community estate, the hereinafter
described property:

…
6. One-half of the songwriter’s rights to all songs written by the said
George Glenn Jones, which are presently published or controlled by
Broadcast Musick (sic) International (As per the written assignment
executed of even date.) …

The said George Glenn Jones shall receive as his separate property
…
He shall receive all recording rights and record sale rights in the
songs that he has sung with Musicor, Starday, Mercury and any other
recording company that he might have performed for.

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 …
He shall receive one-half of the song rights that he has published
with BMI.

(Ex. A, Am. Prop. Settlement)

18. On or about June 11, 1968, a judgment was made and entered, granting the divorce,

incorporating by reference the Amended Property Settlement Agreement. Thereafter and in

accordance with the final decree, Arnold held as her separate property one-half of “the

songwriter’s rights” in all songs George Jones had written prior to their June 11, 1968 divorce.

(Ex. B, Judgment of Divorce)

19. Upon information and belief, George Jones authored or co-authored over ono

hundred seventy (170) musical compositions prior to the June 11, 1968 divorce that were

“published or controlled” by BMI, and that presently remain in term, renewal term and/or in term

as extended under U.S. copyright law.

20. On or about February 20, 1991, Arnold died testate, bequeathing her separate

property interest in all the compositions written by George Jones in equal shares to her sons, Bryan

and Jeffery.

21. On or about March 30, 2020 and for the first time, Bryan and Jeffery learned of a

December 20, 1991 document, found among the documents from the attorney handling the estate

of Arnold, in which Defendant Glad agreed to file applications and renew the copyright

registrations in the names of Bryan and Jeffery for their (Bryan and Jeffery’s) respective

copyright ownership shares in and to approximately 118 George Jones compositions. Glad

registered none of the musical compositions copyright renewals in the names of Bryan and

Jeffery.

22. Commencing on or about February 4, 1992, a dispute arose concerning Arnold’s

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interest in the aforementioned George Jones compositions awarded to her as her separate property

in the divorce, wherein BMI, at the direction of George Jones, ceased public performance royalty

payments to Arnold’s heirs, Bryan and Jeffery, alleging that the compositions reverted to George

Jones on Arnold’s death.

23. As a result of the dispute set forth in Paragraph 22, on September 7, 1995, a lawsuit

was filed on behalf of Bryan and Jeffery against George Jones and BMI, Inc. in the Eastern

District of Texas. Jones, et al. v. Jones, et al., Case No. 1:95-cv-00810-RAS. (Ex. C, Docket) A

stipulation of dismissal entered on September 24, 1996. (Id. at Doc. 110)

24. As part of the resolution of the action referenced in Paragraph 23, on or about May

23, 1996, Bryan and Jeffery agreed to release George Jones and his wife, Nancy, in exchange for

certain payments and undertakings, including but not limited to:

(a) “the waiver by George Jones of all claims to performance royalty

payments, past and future, by [BMI] for songs written by George Jones prior to his
divorce from Shirley (Jones) Arnold on June 11, 1968”, referred to therein as the
“pre-divorce catalogue”; and

(b) “the waiver by George Jones of all claims to any other royalties being
paid to Shirley (Jones) Arnold by virtue of the pre-divorce catalogue at the time of
[her] death on February 20, 1991, including but not limited to those being paid by
BMI, Glad Music Co., Fort Knox Music, Inc. Hudson Bay Music, Inc. and Trio
Music, Inc.”

(Ex. C-1 , Release)

25. Upon information and belief, Hudson Bay Music, Inc. referenced in Paragraph 24

above was a New York corporation that later changed its name to Carlin America, Inc. and then

again to Bienstock Empire, Inc. Upon information and belief, Round Hill acquired certain

catalogues of musical compositions from Carlin, including compositions that are part of the “pre-

divorce catalogue,” one-half of which was voluntarily transferred by George Jones to Shirley Jones

by written agreement, incorporated by reference in the June 11, 1968 divorce decree, and
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transferred by testamentary disposition to Bryan and Jeffery as referenced in Paragraphs 17 to 20

hereinabove.

26. Following the release and dismissal of the action referenced in Paragraphs 23 and

24, Bryan and Jeffery each began receiving royalty statements and certain royalty payments from

(a) Glad, (b) Pappy Daily, (c) Fort Knox Music, Inc. predecessor in interest to Round Hill,

(d) Round Hill as successor to Fort Knox Music, Inc., (e) T/Q Music, Inc. d/b/a Trio Music

Company as predecessor in interest to Bug Music, Inc., (f) Bug Music, Inc. as successor in interest

to T/Q Music, Inc. d/b/a Trio Music Company, (g) BMI, the performing rights organization with

whom George Jones was affiliated as a songwriter, and later (h) BMG as successor in interest to

Bug Music, Inc. that was successor in interest to T/Q Music, Inc.

27. George G. Jones died on April 26, 2013, domiciled in Franklin, Williamson County,

Tennessee. (Ex. D, Death Certificate)

28. On July 19, 2013, the Last Will and Testament of George Glenn Jones was admitted

to probate in the Chancery Court of Williamson County, Tennessee. Upon information and belief,

after bequeathing specific personal and household effects to certain legatees and bequeathing all

other personal and household effects to his wife, Nancy, George G. Jones gave, bequeathed, and

devised the entire residue of his estate, including “all rights I may have at the time of my death to

royalties or other payments as a result of my album sales, song writing and my entertainment

career, … to the George Glenn Jones Trust executed on June 5, 2012, and as it may be amended

from time to time hereafter, …” (Ex. E, Will)

29. Upon information and belief, a notice of termination of grant under 17 U.S.C.

§ 304(c) was recorded on George G. Jones’s behalf on June 1, 2012 with the U.S. Copyright Office

at Document Number V3607 D042 P1-2, V3610 D043 P1-2, purporting to terminate his prior

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transfer of three (3) musical compositions to Fort Knox Music, Inc., effective on varying dates

in 2012. The three musical compositions identified in said notice are part of the “pre-divorce

catalogue,” one-half of which was voluntarily transferred by George Jones to Shirley Jones by

written agreement, incorporated by reference in the June 11, 1968 divorce decree, and transferred

by testamentary disposition to Bryan and Jeffery as referenced in Paragraphs 17 to 20

hereinabove. (Ex. F, Notice of Termination) The notice was allegedly served on February 20,

2007 upon Fort Knox Music, Inc. predecessor in interest to Round Hill.

30. Upon information and belief, a notice of termination of grant under 17 U.S.C.

§ 304(c) was recorded on George G. Jones’s behalf on June 1, 2012 with the U.S. Copyright Office

at Document Number V3607 D040 P1-2, purporting to terminate his prior transfer of one (1)

musical composition to Glad effective June 2, 2012. The musical composition identified in said

notice is part of the “pre-divorce catalogue,” one-half of which was voluntarily transferred by

George Jones to Shirley Jones by written agreement, incorporated by reference in the June 11,

1968 divorce decree, and transferred by testamentary disposition to Bryan and Jeffery as

referenced in Paragraphs 17 to 20 hereinabove. (Ex. F-1, Notice of Termination) The notice was

allegedly served on February 20, 2007 upon Glad.

31. Upon information and belief, a notice of termination of grant under 17 U.S.C.

§ 304(c) was recorded on George G. Jones’s behalf on September 20, 2012 with the U.S. Copyright

Office at Document Number V3610 D450 P1-3, V3610 D610 P1-3, V3610 D613 P1-3, purporting

to terminate his transfer of eight (8) musical compositions to Fort Knox Music, Inc. effective on

varying dates in 2013. The eight (8) musical compositions identified in said notice are part of the

“pre-divorce catalogue,” one-half of which was voluntarily transferred by George Jones to Shirley

Jones by written agreement, incorporated by reference in the June 11, 1968 divorce decree, and

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transferred by testamentary disposition to Bryan and Jeffery as referenced in Paragraphs 17 to 20

hereinabove. (Ex. F-2, Notice of Termination) The notice was allegedly served on February 20,

2007 upon Fort Knox Music, Inc. predecessor in interest to Round Hill.

32. Upon information and belief, Copyright Recapture, LLC by and through Brent

McBride, allegedly on behalf of George G. Jones caused a notice of termination of grant under 17

U.S.C. § 304(c) to be recorded on the date of George G. Jones’s death, April 26, 2013, with the

U.S. Copyright Office at Document Number V3616 D053, purporting to terminate a prior transfer

of thirteen (13) musical compositions to Fort Knox Music, Inc. and to Trio Music Co., Inc. c/o

Bug Music effective on varying dates in 2015. The thirteen (13) musical compositions identified

in said notice are part of the “pre-divorce catalogue,” one-half of which was voluntarily transferred

by George Jones to Shirley Jones by written agreement, incorporated by reference in the June 11,

1968 divorce decree, and transferred by testamentary disposition to Bryan and Jeffery as

referenced in Paragraphs 17 to 20 hereinabove. (Ex. F-3, Notice of Termination) The notice of

termination recorded with the U.S. Copyright Office was served the day before on April 25, 2013

upon Fort Knox Music, Inc. predecessor in interest to Round Hill and Trio Music Co., Inc. c/o

Bug Music, predecessor in interest to BMG. Id. The aforementioned notice served April 25, 2013

contains one title “Long Time to Forget” not listed on the records of the U.S. Copyright Office.

33. Upon information and belief, more than one year after George G. Jones’s death, an

unknown party caused a notice of termination of grant under 17 U.S.C. § 304(c) to be recorded on

May 19, 2014 with the U.S. Copyright Office at Document Number V3626 D683 purporting to

terminate George G. Jones’s transfer of two (2) musical compositions to Trio Music Company,

Inc. predecessor in interest to Bug Music, Inc. that was succeeded by BMG effective May 21,

2014. The two musical compositions identified in said notice are part of the “pre-divorce

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catalogue,” one-half of which was voluntarily transferred by George Jones to Shirley Jones by

written agreement, incorporated by reference in the June 11, 1968 divorce decree, and transferred

by testamentary disposition to Bryan and Jeffery as referenced in Paragraphs 17 to 20

hereinabove. (Ex. F-4, Notice of Termination) The notice was allegedly served on Trio Music

Company on February 20, 2007. Upon information and belief, a notice of termination may have

been served upon Trio Music Company, Inc. predecessor in interest to Bug Music, Inc. that was

succeeded by BMG on or about February 20, 2007 purporting to terminate a previous transfer by

Jones of four (4) musical compositions. (Ex. F-5, Notice) There is no corresponding recordation

of the notice with the U.S. Copyright Office. The four (4) musical compositions in such notice

also are part of the “pre-divorce catalogue,” one-half of which was voluntarily transferred by

George Jones to Shirley Jones by written agreement, incorporated by reference in the June 11,

1968 divorce decree, and transferred by testamentary disposition to Bryan and Jeffery as

referenced in Paragraphs 17 to 20 hereinabove. Id.

34. Upon information and belief, Defendants Glad, Pappy Daily, Ft. Knox Music,

Inc. predecessor in interest to Round Hill, T/Q Music, Inc. d/b/a Trio Music Company as

predecessor in interest to Bug Music, Inc. that was succeeded by BMG, Hudson Bay Music

Company predecessor in interest to Round Hill, and Jones have failed and refused to fully identify

to Bryan and Jeffery all musical compositions voluntarily transferred to Arnold by George G.

Jones upon the June 11, 1968 divorce.

35. Upon further information and belief, Glad, Pappy Daily, Ft. Knox Music, Inc.

predecessor in interest to Round Hill, T/Q Music, Inc. d/b/a Trio Music Company as predecessor

in interest to Bug Music, Inc. and succeeded by BMG, and Hudson Bay Music Company

predecessor in interest to Round Hill retitled certain of the compositions (some with multiple

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titles), reported varying songwriter shares, and registered copyrights or recorded transfers of

copyrights without written agreements by the copyright owner(s).

36. Upon information and belief, the notices of termination referenced in Paragraphs

29 through 33 and the actions of certain Defendants herein and certain predecessors to Defendants

herein as alleged in Paragraphs 29 to 34 (a) have caused a cloud upon the title in and to the

copyright interests held by Bryan and Jefferey in the musical compositions transferred to them

from Arnold by testamentary disposition, (b) have caused disputes regarding the fractional shares

of the musical compositions held by Bryan and Jefferey both in the territories of the U.S and the

world excluding the U.S., and (c) have caused inaccurate accountings and payments and/or no

accountings and payments to be rendered by Defendants Glad, Pappy Daily, Round Hill d/b/a

Ft. Knox Music, Inc., Jones, and BMG to Bryan and Jefferey for their respective interests in all

of the compositions Bryan and Jefferey inherited from Arnold.

B. Master Sound Recordings and Musical Compositions

37. On or about May 20, 2020, Bryan and Jeffery learned about the existence of

certain master recordings recorded by George G. Jones which, upon information and belief, were

recorded in or before 1966 in Sumner County, Tennessee and during the marriage of Jones and

Arnold. (“Masters”) Upon information and belief, said Masters are eight (8) reel-to-reel master

recordings that currently are held in a safe deposit box at First Bank in either Benton County or

Carroll County, Tennessee.

38. Upon information and belief, the Masters contain recordings identified as “Album

2, Album 3, Album 4, and a fourth unnamed project containing ten Masters. (Ex. G, Inventory)

The Masters embody certain musical compositions that are part of the “pre-divorce catalogue,”

one-half of which was voluntarily transferred by George Jones to Shirley Jones by written

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agreement, incorporated by reference in the June 11, 1968 divorce decree, and transferred by

testamentary disposition to Bryan and Jeffery as referenced in Paragraphs 17 to 20 hereinabove,

including but not limited to recordings of “Jonesy”, “I’m Ragged but Right”, “Open Pit Mind”, “I

Can’t Change Over Night”, “Wrong Number”, and “Ship of Love”.

39. Upon information and belief, the Masters (a) were recorded in or before 1966 and

during the marriage of Arnold and George Jones; (b) were not disclosed as assets of the marital

estate during the divorce proceeding; and (c) were not awarded to George G. Jones as his separate

property under the terms of the divorce decree.

40. On or about November 13, 2017, Snoddy initiated an action in the Circuit Court of

Tennessee for Benton County entitled Snoddy v. Maddox, Case No. 17-CV-33, in which he sought

declaratory judgment to determine ownership of the Masters, then held by the Clerk of the Court

for the Eastern District of Tennessee. (Ex. H, Compl.) Snoddy alleged therein that he and one

Donald Evans Gilbreth (“Gilbreth”) were joint owners of World-Wide Records, Inc. and that

World-Wide owned master recordings by George Jones entitled George Jones Sings Hank

Williams. (“GJ Sings Masters”) (Id., Compl. at ¶¶ 10-12) The GJ Sings Masters contains eight

of the Masters and two additional master tracks recorded during Jones’s marriage to Arnold.

(Compare, Ex. I, Doc. 411-1, Exhibits, Ex. D-1, CD label copy -w- Ex. G, Inventory)

41. In 1984, Gilbreth and Snoddy were arrested on federal drug trafficking charges

involving the attempted purchase, possession, and distribution of over 40,000 pounds of

marijuana, as a result of a reverse sting operation. See, United States v. Nixon, 777 F.2d 958, 962-

63 (5th Cir. 1985).

42. Upon information and belief, the Masters were pledged in 1984 by Gilbreth as

security for an appearance bonds of Gilbreth and his co-defendant Snoddy, following a hearing in

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which the value of the Masters was determined to be approximately $1.5 million, sufficient to

satisfy the increased bonds, each set at $500,000 pending said defendants’ appeal. (See, United

States of America v. David L. Snoddy, Donald E. Gilbreth, et al., Case No. 2:38-cr-00541-KDE

(the “ED LA case”), Ex. J, Doc. 397 Order at 2-3; see also, Ex. J-1, Doc. 244, valuation) On

July 11, 1984, Gilbreth and Snoddy were convicted and sentenced to a period of incarceration;

Gilbreth was released from prison on June 18, 1992, and Snoddy was released June 3, 2015. (Id.

at 3)

43. Upon information and belief, after their convictions were upheld on appeal Snoddy

and Gilbreth reported to prison to serve their terms. The appearance bonds were canceled, and

the Masters initially were ordered returned to Gilbreth, but a supplemental order was entered to

return the Masters to Gilbreth’s attorney. (Id.; Ex. K, Doc. 343, Order at 9-10) Notwithstanding

a receipt for the return of the Masters signed by Gilbreth’s attorney, the Masters remained in the

possession of the Clerk of the Court for the Eastern District of Louisiana until on or about May

30, 2018. (Ex. J, Doc. 397, Order at 3-4 )

44. Upon information and belief, Gilbreth died intestate on July 17, 2005 in Tennessee.

See, id., at 3.

45. Pursuant to an April 16, 2018 Order of the district court for the Eastern District of

Louisiana (ED LA case, Ex. L, Doc. 426, Order), the Masters were ordered to be transferred to

Maddox. On May 30, 2018, Maddox retrieved the tapes from the safety deposit box for the Clerk

of Court for the Eastern District of Louisiana (ED LA case, Ex. M, Doc. 428, Clerk’s Report) and

upon information and belief, transported the Masters to the State of Tennessee.

46. On or about July 16, 2018, Maddox filed an inventory with the Probate Court of

Benton County, Tennessee in the Estate of Donald Evans Gilbreth, Deceased, identifying the

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Masters as assets of the estate and stating that said Masters were in a safe deposit box at First Bank.

Upon information and belief, the Masters remain in the safe deposit box at First Bank in either

Benton or Carroll County, Tennessee.

47. On July 19, 2018, a judgment was entered in the Circuit Court for Benton County,

Tennessee holding that Snoddy and Gilbreth “are equal owners of the George Jones recordings

previously held by the U.S. District Court and currently in the possession of the Estate of Donald

Gilbreth.” (emphasis added) The court further held that Snoddy and Gilbreth “were equal partners

in a record company known as World Wide Records.” (emphasis added) The court also found that

the U.S. District Court for the Eastern District of Louisiana had not made a finding regarding

ownership of the tapes, and that the matter in Benton County was not barred by res judicata. (Ex.

N, Snoddy v. Maddox, 17-cv-33, Judgment, entered March 13, 2018; Ex. N-1, Order entered July

19, 2018.)

48. In Snoddy’ s Benton County complaint, he alleged that he and Gilbreth were “joint

owners of ‘World Wide (sic) Records, Inc.’ The tapes in question were owned by ‘World Wide

(sic) Records, Inc.’ The tapes posted as collateral include one tape titled ‘George Jones Sings Hank

Williams’” (referred to herein as GJ Sings Masters) (Ex. H, Snoddy, Complaint at ¶ 11) In

Snoddy’s Response to Defendant’s Motion to Dismiss, Snoddy submitted that “Mr. Jones

recorded the tapes at issue for both Mr. Gilbreth and Mr. Snoddy…” (Ex. O, Feb. 23, 2018 Resp.

to Mot. Dismiss at ¶ 5)

49. World-Wide is and has been a corporation existing under the laws of the State of

Alabama, having been incorporated in 1984.

50. Upon information and belief, Snoddy is and remains one of the initial incorporators

of and one of the shareholders in World-Wide.

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 51. In the course of the ED LA case, Snoddy caused his sworn affidavit to be filed on

April 18, 2017 in support of his “Motion and Claim for Return of Tapes Pledged as Collateral for

the Bonds of Donald E. Gilbreth and David L. Snoddy.” (Ex. P, Doc. 411, Mot.; Ex. I, Doc. 411-

1, Exhibits, Ex. C, Snoddy Aff.)

52. In his affidavit referenced in Paragraph 51, Snoddy swore that he, Gilbreth, and

three other men formed World-Wide, a corporation, in 1983, attaching as an exhibit thereto, a

certificate of incorporation identifying (1) six (rather than five) shareholders, (2) six directors, and

(3) three officers, a stock subscription list for World-Wide, and Minutes of a Special Meeting

with a Waiver of Notice as to said meeting signed by five of the six shareholders. (Id. at Ex. C-3 )

53. In his affidavit referenced in Paragraph 50, Snoddy swore that he, Gilbreth, and

David Johnson were the “primary shareholders.” (Id. at Ex. C, ¶ 16) Snoddy did not mention the

sixth shareholder, Sherman Wallace, who held 175 shares, while Snoddy held 225, Gilbreth held

225, Johnson held 250, Paul Lovelace held 75 and Charles Rosser held 50 shares. (Id. at Ex. C,

¶ 16, C-3)

54. In the course of the ED LA case, Snoddy swore under oath that in 1966, Gilbreth

“had been involved with recording performances that George Jones made for various radio shows,”

that Gilbreth and a business partner, Jimmy Klein, “gained ownership of the various masters

discussed in Exhibit 1 (i.e., Gilbreth’s Aff. dated August 3, 1984), and that “The tapes were owned

by a partnership referred to as Jimidon Enterprises.” (Id. at Doc. 411-1, Ex. C, Snoddy Aff. ¶¶ 6–

8) Snoddy also swore that he and Gilbreth “discussed the idea of producing and marketing the

George Jones masters that Don had recorded back in 1966.” (Id. at ¶ 10)

55. In the ED LA case, Snoddy filed the Affidavit of Jimmy Klein with an attached

“Agreement” dated November 10, 1982, purporting to sell his (Klein’s) interest in the dormant

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“limited partnership” known as Jimidon Enterprises to Gilbreth. (Id. at Doc. 411-1, Ex. C, Snoddy

Aff. ¶ 11, Ex. C-2, Klein Aff.) No copyrights, including for any George Jones master recordings,

are identified, or transferred from Klein and/or Jimidon to Gilbreth in said agreement. (Id.)

56. In the ED LA case, Snoddy swore under oath that he “cannot provide specific

documents detailing my joint ownership in the tapes now in the Court’s possession, I represent to

this Court that Don and I had multiple verbal agreements that made me an equal co-owner in those

tapes.” (Id. at Doc. 411-1, Ex. C, Snoddy Aff. ¶ 21)

57. In the ED LA case, Snoddy filed certain documents in which he alleged that the GJ

Sings Masters is a compilation containing ten masters that had not been distributed or sold

commercially. (Ex. P, Doc. 411, Mot. at 2; Ex. I, Doc. 411-1, Ex. C, Snoddy Decl., Ex. C. Ex.

C-1)

58. Upon information and belief, World-Wide registered a copyright with the U.S.

Copyright Office, being registration number SR0000046240, effective May 2, 1983 for a sound

recording with ten tracks entitled George Jones sings Hank Williams and other great country hits.

The copyright claimant is World-Wide, as employer for hire of Snoddy and Don Gilbreath (sic).

The registration states that the work was created in 1983 and was published on April 25, 1983.

(emphasis added). (Ex. Q, Copyright Record)

59. Upon information and belief, the ten tracks listed on the copyright registration

identified in Paragraph 58 were recorded during George Jones’s marriage to Arnold as referenced

in Paragraphs 37 to 38 hereinabove and includes eight of the Masters.

60. Upon information and belief, there are no copyrights or documents registered or

recorded with the U.S. Copyright Office that identify Snoddy or Gilbreth as copyright claimants

to any musical compositions authored by George Jones or to any sound recordings performed by

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George Jones, whether in whole or in part.

61. Bryan and Jeffery are the true equal copyright owners of the one-half interest in

and to the musical compositions authored, in whole or in part, and owned by George Jones as the

copyright claimant, that were voluntarily transferred to Arnold by the June 11, 1968 written

agreement between George Jones and Arnold, incorporated by reference into the judgment of

divorce of the same date, and inherited by Bryan and Jeffery, upon the death of their mother.

62. Bryan and Jeffery are the true equal co-owners of one-half of the songwriter rights

in and to the musical compositions authored, in whole or in part, by George Jones, which such

interests were voluntarily transferred to Arnold by the June 11, 1968 written agreement between

George Jones and Arnold, incorporated by reference into the judgment of divorce of the same date

and inherited by Bryan and Jeffery, upon the death of their mother, Arnold, including but not

limited to (a) the right to receive their pro-rata share of royalties and fees derived from the

commercial exploitation of such compositions, (b) the right to accountings and payments for their

pro-rata interests from the copyright co-owner(s), the exclusive music publishing copyright

administrators, and/or the music publishers of such copyright interests, and (c) the statutory right

to terminate any transfers of copyrights made by songwriter/author George Jones.

63. Any notices of termination from songwriter George Jones to Glad, Pappy Daily,

Round Hill as the successor in interest to Ft. Knox Music, Inc. and Hudson Bay Music, Inc., and

to BMG as successor in interest to Bug Music, Inc. that succeeded T/Q, Inc. d/b/a Trio Music

Company as set forth in Paragraph 29 to 33 hereinabove, are invalid as against any interest held

by Bryan and Jeffery as a result of the transfer by written agreement of a one-half interest to

Arnold, mother of Bryan and Jeffery, executed by George Jones on June 11, 1968, separate and

apart from any grant George Jones may have made to Glad, Pappy Daily, Round Hill through its

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predecessors in interest, or to BMG through its predecessors in interest.

64. As equal co-owners of the songwriter rights in the “pre-divorce catalogue”, Bryan

and Jeffery are the true equal copyright co-owners of one-half of any interest that may have been

validly terminated by songwriter George Jones pursuant to and as a result of any notices of

termination from George Jones to Glad, Pappy Daily, Round Hill as the successor in interest to

Ft. Knox Music, Inc. and Hudson Bay Music, Inc., and to BMG as successor in interest to Bug

Music, Inc. that succeeded T/Q, Inc. d/b/a Trio Music Company, including but not limited to (a)

the right to receive their pro-rata share of royalties and fees derived from the commercial

exploitation of such compositions, (b) the right to accountings and payments for their pro-rata

interests from the copyright co-owner(s), the exclusive music publishing copyright administrators,

and/or the music publishers of such copyright interests, (c) the right to sell, license, or encumber

such interests, and (d) all other rights afforded to copyright owners.

65. The testamentary disposition of the copyright interests and the “songwriter rights”

to Bryan and Jeffery by Arnold is not subject to termination by George Jones or his statutory

representatives pursuant to 17 U.S.C. § 304(c).

66. As a result of George G. Jones’s authorship and ownership of the Masters and the

GJ Sings Masters from the date of creation in 1966, Bryan and Jeffery have (a) the right to receive

their pro-rata share of the royalties and fees derived from the commercial exploitation of the

Masters and the GJ Sings Masters and all derivative works created therefrom, to the extent such

master recordings and derivatives were commercially exploited; (b) the right to receive their pro-

rata share of the royalties and fees derived from the commercial exploitation of their interests in

the musical compositions from the “pre-divorce catalogue” that are embodied in the Masters and

the GJ Sings Masters and all derivative works create therefrom, to the extent they were

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commercially exploited from their date of creation to the present, and (c) the right to receive their

pro-rata share of any economic benefits from the copyrighted work created by George Jones during

the existence of the marital community and all derivatives of such works following the termination

of the Jones/Arnold marriage, which such rights Bryan and Jeffery inherited from their mother;

FIRST CAUSE OF ACTION

(Declaratory Relief)

67. Bryan and Jeffery reallege each allegation in Paragraphs 1 through 66 hereof as

if fully rewritten herein.

68. Pursuant to 28 U.S.C. § 2201, and to resolve these controversies, Bryan and Jeffery

request that the Court declare the respective rights and duties of the parties in this matter and that

the Court declare:

(a) that Bryan is a twenty-five percent (25%) copyright owner of the musical compositions

authored, in whole or in part, and owned by George Jones and “published or controlled” by BMI,

Inc. as conveyed to Bryan’s mother, Arnold, from George Jones by written agreement dated June

11, 1968 and incorporated by reference in the Jones judgment of divorce of the same date, each of

which such composition interests was transferred to Bryan by Arnold’s testamentary disposition.

(b) that Jeffery is a twenty-five percent (25%) copyright owner of the musical compositions

authored, in whole or in part, and owned by George Jones and “published or controlled” by BMI,

Inc. as conveyed to Jeffery’s mother, Arnold, from George Jones by written agreement dated June

11, 1968 and incorporated by reference in the Jones judgment of divorce of the same date, each of

which such composition interests was transferred to Jeffery by Arnold’s testamentary disposition.

(c) that Bryan and Jeffery each hold a twenty-five percent (25%) ownership interest in

and to the songwriter rights in and to the musical compositions authored, in whole or in part, by

George Jones, which such interests were voluntarily transferred by the June 11, 1968 written
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agreement between George Jones and Arnold, incorporated by reference into the judgment of

divorce of the same date and inherited by Bryan and Jeffery, upon the death of their mother,

including but not limited to the right to receive the correct pro-rata shares of royalties and fees

derived from the commercial exploitation of the such compositions and all derivative works, the

right to accountings and payments for the correct pro-rata shares of royalties and fees derived from

the exploitation of the such compositions and all derivative works from Glad, Pappy Daily,

Round Hill d/b/a Ft. Knox Music, Inc, BMG, and Nancy, and the statutory right to terminate

any transfers of copyrights made by the songwriter/author George Jones.

(d) that the testamentary disposition by Arnold of her separate property copyright

interests and the songwriter rights to her sons, Bryan and Jeffery, are not subject to termination

by George Jones or his statutory representatives pursuant to 17 U.S.C. § 304(c).

(e) that the Notices of Termination recorded with the U.S. Copyright Office identified

in Paragraphs 29 to 33 are invalid as against any copyright ownership interests in the musical

compositions held by Bryan and Jeffery resulting from June 11, 1968 voluntary transfer from

George Jones to Arnold and the subsequent testamentary disposition by Arnold of her separate

property to them.

(f) that Bryan and Jeffery each are twenty-five percent (25%) copyright owners in

any copyrights to musical compositions whose previous transfers were validly terminated by

songwriter George Jones pursuant to and as a result of the Notices of Termination from George

Jones to Glad, Pappy Daily, Round Hill as the successor in interest to Ft. Knox Music, Inc.

and Hudson Bay Music, Inc., and to BMG as successor in interest to Bug Music, Inc. as successor

in interest to T/Q, Inc. d/b/a Trio Music Company as set forth in Paragraphs 29 to 33 hereinabove,

and that Nancy has a duty to account for all revenues she received directly or indirectly from the

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commercial exploitation that are attributable to the one-half copyright interests equally co-owned

by Bryan and Jeffery, whether by sale, leasing, or licensing the subject compositions.

(g) that Glad and Pappy Daily be required to fully and completely identify all

musical compositions, including by alternate titles, that were authored or co-authored by George

Jones on and before June 11, 1968 and subject to George Jones’s BMI agreement in effect on that

date.

(h) that Bryan and Jeffery are entitled to full and complete accountings and royalty

payments and fees from Defendants Glad, Pappy Daily, Round Hill, BMG, and Nancy for

Bryan and Jeffery’s pro-rata copyright ownership shares and their pro-rata interests comprising

one-half the songwriter rights in and to the musical compositions authored or co-authored by

George Jones on and before June 11, 1968 that were subject to the BMI agreement in effect on

that date.

(i) that the judgment of the Benton County, Tennessee Circuit Court granting equal

ownership of the Masters to Snoddy and the Estate of Donald Evans Gilbreth is of no force and

effect in that said Tennessee Circuit Court has no jurisdiction to determine copyright ownership

which falls within the exclusive jurisdiction of federal courts pursuant to 17 U.S.C. §§ 1331,

1338(a);

(j) that Bryan and Jeffery are entitled to (a) equally share in fifty percent (50%) of the

proceeds from an arm’s length sale, lease, and/or license of the Masters and the GJ Sings Masters,

(b) to equally share in fifty percent (50%) of all revenue streams arising from the commercial

exploitation of the Masters and the GJ Sings Masters and each of the tracks embodied therein,

including all derivative works, (c) the right to receive full accountings and payments for their pro-

rata share of royalties and fees derived from the commercial exploitation of their copyright interests

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and “songwriter rights” in the musical compositions from the “pre-divorce catalogue” embodied in

the Masters and the GJ Sings Masters; and (d) all other rights and economic benefits available to

them as a result of Arnold’s one-half community property interest in the Masters and the GJ Sings

Masters, and all derivatives created therefrom including after termination of the marriage which

such interests Bryan and Jeffery inherited from their mother, Arnold; and

69. There is a valid justiciable controversy with respect to the musical compositions

comprising the “pre-divorce catalogue” between Bryan and Jeffery on the one hand, and

Defendants Glad, Pappy Daily, Round Hill, BMG, and Nancy on the other hand, sufficient for

this Court to declare the rights and obligations of the parties in that:

(A) Defendants Glad, Pappy Daily, and Nancy claim (1) that Bryan and Jeffery have

no copyright ownership interests in and to the musical compositions in the “pre-divorce catalogue”

that they inherited from their mother; (2) that Bryan and Jeffery have “songwriter rights” in and

to fewer of the musical compositions than those included in the “pre-divorce catalogue” they

inherited from their mother; (3) that Bryan and Jeffery have less than equal shares in the one-half

of the “songwriter rights” in and to the musical compositions included in the “pre-divorce

catalogue” they inherited from their mother; (4) Bryan and Jeffery are not entitled to complete,

accurate accountings and payments, or audit rights as to their respective copyright ownership

interests and/or their interests arising from the “songwriter rights” in and to the musical

compositions included in the “pre-divorce catalogue” they inherited from their mother; and

(5) that the Notices of Termination extinguished Bryan and Jeffery’s copyright interests and

“songwriter rights” in and to certain musical compositions included in the “pre-divorce catalogue”

they inherited from their mother.

(B) Defendants Round Hill and BMG claim ownership and/or are administering

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copyrights contained in the “pre-divorce catalogue” and accounting and making payments based,

in part, upon inaccurate and incomplete copyright ownership shares and “songwriter rights”

interests held by Bryan and Jeffery as a result, in part, of the actions and inaction of their

predecessors in interest Ft. Knox Music, Inc., Hudson Bay Music Company, T/Q Music, Inc. d/b/a

Trio Music Company (succeeded by Bug Music, Inc.), George Jones, and Defendants Glad,

Pappy Daily, and Jones.

(C) Defendant Glad failed to make application and file copyright renewals in the names

of Bryan and Jeffery and instead have treated such copyrights as being owned by Glad and/or

Pappy Daily without properly accounting to or paying Bryan and Jeffery according to their proper,

respective ownership shares and “songwriter rights” in and to 118 musical compositions contained

in the “pre-divorce catalogue” they inherited from their mother.

Conversely, Bryan and Jeffery assert that they are entitled to a declaration of their rights

with respect to the musical compositions as set forth in Paragraphs 61 through 65 and 68 (a) – (h)

as if fully rewritten herein.

70. There is a valid justiciable controversy with respect to the Masters and the GJ Sings

Masters between Bryan and Jeffery on the one hand, and Defendants Snoddy, Maddox as

Administrator ad litem, and World-Wide on the other hand, sufficient for this Court to declare

the rights and obligations of the parties in that:

(A) Defendants Snoddy and Maddox as administrator ad litem for the Estate of Donald

Evans Gilbreth purport to be the equal co-owners of the Masters and GJ Sings Masters and each of

the tracks embodied therein following entry of a judgment in Tennessee Benton County Circuit

Court. Conversely, Bryan and Jeffery claim (1) that the Benton County Circuit Court lacked

jurisdiction to enter such a judgment, (2) that World-Wide registered a copyright in 1984 as the

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copyright claimant of the GJ Sings Masters as employer for hire of Snoddy and Gilbreth, and (3)

that in 2017 and 2018 Snoddy knowingly presented evidence to the Benton County Circuit Court

that was wholly contradictory to the papers and filings Snoddy presented to the District Court in

the Eastern District of Louisiana in 2017 in order to secure an order for the removal of the Masters

and the GJ Sings Masters from the Clerk of Courts in said district to Maddox who is storing them

in the safe deposit box at First Bank in Tennessee as alleged hereinabove, including but not limited

to Snoddy’s sworn statement that he acquired ownership of the Masters by verbal agreement with

Gilbreth and that a corporation of which he was a shareholder, Defendant World-Wide, owned the

GJ Sings Masters while Snoddy presented evidence a few months later to the Benton County

Circuit Court that the Masters were created for he and Gilbreth who were equal partners in World-

Wide, among other major inconsistencies.

Conversely, Bryan and Jeffery claim that the Masters and GJ Sings Masters were

recordings authored and owned by George Jones, and made during the marriage between Jones and

Arnold that constitute community property of the marital estate, and pursuant to the June 11, 1968

judgment for divorce and testamentary disposition to Bryan and Jeffery by their mother, they are

entitled to a one-half interest in all revenues streams related to the commercial exploitation, sale,

lease, licensing, or other disposition, and all other economic benefits derived from the Masters and

the GJ Sings Masters and all derivatives prepared therefrom including after the termination of the

marriage.

(B) Defendant World-Wide purports to own the sound recording copyright in and to

the GJ Sings Masters as employers for hire of Snoddy and Gilbreth whereas Snoddy claims

ownership for himself as an “equal partner” in World-Wide with Gilbreth, while admitting he has

no documents detailing his ownership, whether as a purported partner or as a shareholder of World-

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Wide.

Conversely, Bryan and Jeffery claim that the GJ Sings Masters contain ten master

recordings (including eight of the Masters) that constituted community property of the marital estate

and pursuant to the June 11, 1968 judgment for divorce and testamentary disposition to Bryan and

Jeffery by their mother, they are entitled to one-half of all revenues streams related to the

commercial exploitation, sale, lease, or licensing, or other disposition of the Masters and the GJ

Sings Masters.

70. A judicial declaration of the parties’ respective rights and obligations with respect

to the Masters and the GJ Sings Masters is necessary and appropriate as set forth in Paragraphs 1

through 77 of this Complaint.

SECOND CAUSE OF ACTION

(Conversion Against Glad, Pappy Daily, and Jones)

71. Bryan and Jeffery reallege each allegation in Paragraphs 1 through 36 hereof as

if fully rewritten herein.

72. Without Bryan and Jeffery’s knowledge or consent, Glad, Pappy Daily, George

Jones and Nancy, T/Q, Inc. d/b/a Trio Music Company and Ft. Knox Music, Inc. knowingly and

willfully gained control over certain interests in the musical composition copyrights authored or

co-authored by George Jones that were voluntarily transferred to Arnold by George Jones on June

11, 1968 and later inherited by Bryan and Jeffery upon the death of their mother, Arnold in 1991.

73. Without Bryan and Jeffery’s knowledge or consent, Glad failed to register renewal

copyrights in and to 118 musical compositions authored or co-authored by George Jones that had

been voluntarily transferred to Arnold by George Jones on June 11, 1968 and later inherited by

Bryan and Jeffery upon the death of their mother, Arnold.

74. Glad, Pappy Daily, George Jones and Nancy, T/Q, Inc. d/b/a Trio Music Company
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and Ft. Knox Music, Inc. intended to, and in fact, did intentionally exercise dominion and control

over and in defiance of Bryan and Jeffery’s one-half interest in the songwriter rights voluntarily

transferred to their mother, Arnold, by written agreement on June 11, 1968 and inherited by Bryan

and Jeffery upon their mother’s death in 1991, including Bryan and Jeffery’s one-half interest in

and to musical composition copyrights owned by George Jones on and before June 11, 1968

including the renewal terms and extensions, and Bryan and Jeffery’s one-half interest in George

Jones’s songwriter rights in and to all musical compositions authored or co-authored by George

Jones on or before June 11, 1968 that were subject to the BMI agreement.

75. Glad, Pappy Daily, George Jones, T/Q, Inc. d/b/a Trio Music Company and Ft.

Knox Music, Inc. registered copyrights in their names, retitled compositions, and following George

Jones’s death, together with Nancy collected and/or received revenue streams resulting from the

commercial exploitation of the compositions and all derivative works created therefrom, and

exercised control over such compositions and derivative works as if the one-half interest had not

been lawfully transferred first to Arnold and then to Bryan and Jeffery.

76. With actual notice of Bryan and Jeffery’s copyright ownership interests and the

interests in the “songwriter’s rights”, Glad, Pappy Daily, George Jones and Nancy, T/Q, Inc.

d/b/a Trio Music Company, Ft. Knox Music, Inc., and Nancy intended to and then did convert said

interests in the musical compositions and the economic benefits derived therefrom for their own

use and benefit with an intent to permanently deprive Bryan and Jeffery of the benefits of

copyright ownership, and the revenue and rights associated with the songwriter rights.

77. Glad, Pappy Daily, George Jones, T/Q, Inc. d/b/a Trio Music Company and Ft.

Knox Music, Inc. and later Nancy as the surviving spouse of George Jones used and benefited from

the commercial exploitation of the musical compositions and the songwriter rights in which Bryan

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and Jeffery hold and have held the interests as alleged hereinabove, including (a) collecting and/or

receiving royalties, fees and payments from the commercial exploitation of the works, (b) securing

copyright registrations and/or reversions of copyright for the terms, renewal terms, and/or

extensions of such terms, and (c) recording documents with the U.S. Copyright Office that affected

title in and to such musical compositions, all to the detriment of Bryan and Jeffery.

78. George Jones and later Nancy knowingly engaged in the conduct alleged in

Paragraphs 72 and 74 through 77 in defiance of and contrary to the written Release (Ex. C-1) and

dismissal of the action brought by Bryan and Jeffery as alleged in Paragraphs 22 through 24

hereinabove.

79. By converting, modifying, licensing, reproducing and distributing, and otherwise

commercially exploiting the musical compositions in which Bryan and Jeffery hold and have held

the interests since 1991 as alleged hereinabove, Defendants diminished the value and economic

benefits of the musical compositions to Bryan and Jeffery.

THIRD CAUSE OF ACTION

(Conversion Against Snoddy, World-Wide, and Maddox)

80. Bryan and Jeffery reallege each allegation in Paragraphs 1 through 13 and 37

through 60 hereof as if fully rewritten herein.

81. Without Bryan and Jeffery’s knowledge or consent, Snoddy, World-Wide, and

Maddox knowingly and willfully gained control over and purportedly obtained copyright

ownership in and to the Masters and the GJ Sings Masters authored or co-authored by George

Jones, one-half of the economic value and benefits were inherited by Bryan and Jeffery upon the

death of their mother, Arnold in 1991.

82. Without Bryan and Jeffery’s knowledge or consent, Snoddy, World-Wide, and

Maddox intended to, and in fact, did intentionally exercise dominion and control over Bryan and
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Jeffery’s one-half interest in economic value and benefits in and to the Masters and the GJ Sings

Masters authored by George Jones, which such one-half interest was inherited by Bryan and

Jeffery upon their mother’s death in 1991.

83. Without Bryan and Jeffery’s knowledge or consent and without disclosing George

Jones or his heirs’ interest in the Masters or the GJ Sings Masters, Snoddy and World-Wide by

and through Snoddy filed documents in District Court for the Eastern District of Louisiana as set

forth in Paragraphs 37 through 57 hereof to secure possession of the Masters and the GJ Sings

Masters. As a result of Snoddy’s filings, Maddox knowingly secured possession of the Masters

and the GJ Sings Masters on behalf of the Estate of Donald Evans Gilbreth, transported them to the

State of Tennessee, and presently retains possession of them, storing them in a safe deposit box in

Benton County or Carrol County, Tennessee.

84. World-Wide registered a sound recording copyright with the U.S. Copyright Office

in World-Wide’s name for the GJ Sings Masters as employer for hire of Snoddy and Gilbreth as

alleged in Paragraph 58, and upon information and belief, did so without a writing between World-

Wide and the author George Jones. Said copyright was registered while Snoddy was a shareholder

of World-Wide and when Snoddy and World-Wide by and through Snoddy had knowledge that

the Masters and the GJ Sings Masters were recorded in or before 1966 by George Jones, but not

for Snoddy, Gilbreth, or World-Wide, and that the Masters and GJ Sings Masters were not

lawfully conveyed to Snoddy, Gilbreth, or World-Wide.

85. Maddox was aware of the action in the Eastern District of Louisiana and had access

to the publicly available court records regarding Snoddy’s pursuit of possession and ownership of

the Masters and the GJ Sings Masters that concerned (a) the probate case in which he was the

administrator ad litem for Donald Evans Gilbreth, and (b) the declaratory relief action for

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ownership of the Masters and the GJ Sings Masters brought by Snoddy against Maddox as

Gilbreth’s administrator. Maddox also had access to the publicly available records of the U.S.

Copyright Office for the GJ Sings Masters in which a corporation, World-Wide, and not Snoddy

or Gilbreth claimed ownership of the copyright in said masters.

86. With actual and/or constructive notice of the interests of George Jones and his

heirs, and Bryan and Jeffery in the Masters and the GJ Masters, Snoddy and Maddox as

administrator intended to and then did convert said interests in said Masters for their respective

uses and benefit (i.e., for Snoddy’s use and benefit and for the estate’s use and benefit) with an

intent to permanently deprive George Jones’s heirs and Bryan and Jeffery of the economic

benefits associated with the Masters and the GJ Sings Masters to which they are lawfully entitled.

87. By converting the Masters and GJ Sings Masters in which Bryan and Jeffery hold

and have held the interests since 1991 as alleged hereinabove, Defendants Snoddy and Maddox

as administrator diminished the value and economic benefits of the Masters and GJ Sings Masters

to Bryan and Jeffery.

IV. PRAYER FOR RELIEF

WHEREFORE, Plaintiffs demand declaratory relief against Defendants on those matters

to be determined by a judge, and further prays for judgment against Defendants, and each of them,

as follows:

1. A declaration that Plaintiffs are the copyright claimants, at least in part, of the

copyrights in and to the musical compositions as set forth in Paragraphs 68(a) and (b) hereof and

that will clear the copyright title of each such musical composition at issue;

2. A declaration that Plaintiffs each hold a twenty-five percent (25%) ownership

interest in and to the songwriter rights in and to the musical compositions authored, in whole or in

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part, by George Jones as set forth in Paragraph 68(c) hereof;

3. A declaration that that the testamentary disposition by Arnold of her separate

property copyright interests and the songwriter rights to her sons, Plaintiffs herein, are not subject

to termination by George Jones or his statutory representatives pursuant to 17 U.S.C. § 304(c) as

set forth in Paragraph 68(d) hereof;

4. A declaration that the Notices of Termination recorded with the U.S. Copyright

Office identified in Paragraphs 29 to 33 are invalid as against any copyright ownership interests in

the musical compositions held by Plaintiffs resulting from June 11, 1968 voluntary transfer from

George Jones to Arnold and the subsequent testamentary disposition by Arnold of her separate

property to them.

5. A declaration that Plaintiffs are entitled to a full and complete list of all musical

compositions, including by alternate title, that were authored or co-authored by George Jones on

and before June 11, 1968 and subject to George Jones’s BMI agreement in effect on that date.

6. A declaration that Plaintiffs are entitled to full and complete accountings and

royalty payments and fees from Defendants Glad, Pappy Daily, Round Hill, BMG, and Nancy as

alleged in Paragraph 68(h) hereof;

7. A declaration that the judgment of the Benton County, Tennessee Circuit Court

granting equal ownership of the Masters to Snoddy and the Estate of Donald Evans Gilbreth is of

no force and effect as alleged in Paragraph 68(i) hereof;

8. A declaration that Plaintiffs are the fifty percent (50%) owners of all revenue

streams and all economic benefits generated or to be generated by or arising from the commercial

exploitation of the Masters and the GJ Sings Masters, each of the Tracks, and all derivative works

prepared therefrom as alleged in Paragraph 68(j) hereof.

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 9. For compensatory damages Plaintiffs sustained in consequence of Defendants’

actions and inactions as alleged hereinabove, including but not limited to damages for the

diminution or destruction of the intrinsic value of the musical compositions and master recordings

identified hereinabove

10. For punitive damages, to the extent available, in an amount to be determined at the

time of trial arising out of Defendants’ intentional, malicious, and/or reckless action and/or

inaction;

11. For Plaintiffs’ reasonable and actual attorney fees and costs in this action;

12. For pre-judgment and post-judgment interest; and

13. For such other and further relief as may be just and proper.

DATED: October 26, 2020 Respectfully submitted,

DESALVO LAW FIRM PLLC

/s/ Ramona P. DeSalvo

Ramona P. DeSalvo (#018491)
1720 West End Ave., Suite 403
Nashville, TN 37203
Telephone: (615) 600-4741
Facsimile: (615) 600-4761
rdesalvo@desalvonashville.com
Attorney for Plaintiffs Bryan D. Jones and
Jeffery G. Jones

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