Case 2:18-cv-03466-DMG-SK Document 58 Filed 12/04/18 Page 1 of 3 Page ID #:1887 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Angela C. Agrusa (SBN 131337) angela.agrusa@dlapiper.com Lisa Tenorio-Kutzkey (SBN 205955) ltk@dlapiper.com Miles M. Cooley (SBN 206783) miles.cooley@dlapiper.com DLA PIPER LLP (US) 2000 Avenue of the Stars Suite 400, North Tower Los Angeles, CA 90067 Telephone: 310.595.3000 Facsimile: 310.595.3300 Christopher Lovrien (State Bar No. 230546) Email: cjlovrien@jonesday.com Brian D. Hershman (State Bar No. 168175) Email: bhershman@jonesday.com Erica L. Reilley (State Bar No. 211615) Email: elreilley@jonesday.com JONES DAY 555 South Flower Street, Fiftieth Floor Los Angeles, CA 90071.2300 Telephone: + 1.213.489.3939 Facsimile: + 1.213.243.2539 Attorneys for Non-Party H.E. AHMED AL-RUMAIHI (by special appearance) and Defendant AYMAN SABI 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 19 BIG 3 LLC, et al., 20 21 22 23 24 Plaintiffs, v. AHMED AL-RUMAIHI, et al., Defendants. CASE NO. 2:18-CV-3466 DMG (SKX) Assigned for all purposes to Hon. Dolly M. Gee SPECIALLY-APPEARING NONPARTY H.E. AHMED ALRUMAIHI’S NOTICE OF NEW DEVELOPMENTS 25 26 27 28 H.E. AL-RUMAIHI’S NOTICE RE NEW DEVELOPMENTS Case 2:18-cv-03466-DMG-SK Document 58 Filed 12/04/18 Page 2 of 3 Page ID #:1888 1 TO THE COURT, ALL PARTIES, AND ATTORNEYS OF RECORD: 2 PLEASE TAKE NOTICE that Specially-Appearing Non-Party H.E. Ahmed 3 Al-Rumaihi (“H.E. Al-Rumaihi”), by and through his counsel, respectfully submits 4 this Notice to apprise the Court of recent developments that have occurred since 5 briefing was completed on H.E. Al-Rumaihi’s and Defendant Ayman Sabi’s Motion 6 to Strike (“Dkt. No. 8”) and Plaintiffs Big3 LLC’s, O’Shea Jackson’s, and Jeff 7 Kwatinetz’s (“Plaintiffs”) Motion for Jurisdictional Discovery (Dkt. No. 10). These 8 new developments preceded the November 29, 2018 Order of this Court (the “Anti- 9 SLAPP Order”) which, inter alia, granted the Motion to Strike in part, dismissed all 10 claims against H.E. Al-Rumaihi, and foreclosed Plaintiffs from asserting new claims. 11 Dkt. No. 57 at 13. While H.E. Al-Rumaihi is no longer a party to this action as a 12 result of the Anti-SLAPP Order, H.E. Al-Rumaihi believes it is nonetheless prudent 13 to apprise the Court of these new developments, which preclude Plaintiffs from any 14 further efforts to involve H.E. Al-Rumaihi in this action. 15 On or about August 27th of this year, H.E. Al-Rumaihi received a diplomatic 16 appointment as the Commercial Attaché for Investment for the State of Qatar, which 17 carries the rank of ambassador and the title of His Excellency (“H.E.”). 18 September 7, 2018, the Qatari Embassy formally notified the United States 19 Department of State (“State Department”) of H.E. Al-Rumaihi’s diplomatic posting 20 via a Notification of Appointment through the Office of Foreign Mission e-Gov 21 system. The State Department thereafter formally recognized H.E. Al-Rumaihi’s 22 diplomatic status, as reflected by his Diplomatic Identification Card, issued on or 23 about September 13, 2018. The State Department further identified H.E. Al-Rumaihi 24 as an accredited diplomat entitled to immunity under the Vienna Convention on 25 Diplomatic Relations (“Vienna Convention”) on its most recently published 26 Diplomatic List.1 Under the well-settled doctrine of diplomatic immunity, H.E. Al- 27 28 1 https://www.state.gov/documents/organization/287365.pdf at 96. 1 H.E. AL-RUMAIHI’S NOTICE RE NEW DEVELOPMENTS On Case 2:18-cv-03466-DMG-SK Document 58 Filed 12/04/18 Page 3 of 3 Page ID #:1889 1 Rumaihi has full immunity from all aspects of civil litigation. 2 Convention, Articles 31.1 & 31.2. See Vienna 3 4 Dated: December 4, 2018 JONES DAY 5 6 7 8 By: /s/ Brian D. Hershman Brian D. Hershman Attorneys for Specially-Appearing NonParty H.E. AHMED AL-RUMAIHI 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 H.E. AL-RUMAIHI’S NOTICE RE NEW DEVELOPMENTS