Santa Monica Pictures, LLC, Perry Lerner, Tax Matters Partner - Page 302

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               Troy & Gould pointed out:  “There is no evidence * * * that            
          the Epic entities actually transferred their rights in the                  
          subject pictures to EBD, despite the fact that EBD subsequently             
          purported to transfer rights in the pictures”; and “The                     
          documentation of the chain of title thus appears unsatisfactory             
          as to the Epic pictures.”                                                   
               Troy & Gould characterized the various assignments of film             
          assets from Alpha, Epsilon, and EBD to CLIS as “quitclaim                   
          assignments; that is, the transferors disclaimed all warranties             
          and representations as to the assets.”  Moreover, although the              
          assignments referred to all right, title, and interest in the               
          film assets, the attached schedules referred only to “‘U.S. Video           
          Film Rights’”.  Troy & Gould also indicated that it had no                  
          documentation confirming CLIS’s assignment of the EBD film                  
          library to SMHC; it characterized this lack of documentation as             
          “another significant gap in the chain of title.”  Troy & Gould              
          expressed further concerns that the term “U.S. Video Film Rights”           
          in Schedule 1.6(b) of the exchange and contribution agreement was           
          not defined and that the exchange and contribution agreement                
          contained no explicit statement that SMHC owned those rights.               
               2.  Access Letters                                                     
               While Troy & Gould was conducting its due diligence on the             
          EBD film library, it was also attempting to obtain laboratory and           
          facility access letters to the physical materials of certain film           






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