18 U.S.C. 2257 Record-Keeping Requirements Compliance Statement
OC Cash Sites @
Custodian of Records, Phil Rivera, 22425 Ventura Blvd. #197, Woodland Hills, CA 91367

THE LAW OFFICE OF Jeffrey J. Douglas - A Professional Corporation

June 10, 2005

Re: Secondary Producer Records Pursuant to 18 U.S.C. § 2257

To Whom It May Concern:

I represent OC Cash Media. We received your inquiry concerning copies of records for secondary producers. I am very familiar with 18 U.S.C. § 2257 in my capacities as a First Amendment and criminal defense practitioner, the Chairman Emeritus of the First Amendment Lawyers Association and the Chair of the Board of the industry’s trade association, the Free Speech Coalition. I write this letter exclusively in my capacity as OC Cash Media’s attorney.

Despite General Gonzalez’ efforts at reviving the concept of “secondary producers” in the most recent version of regulations in support of 18 U.S.C. § 2257, the concept is not supported by the statute itself. The only case addressing the issue, Sundance Assocs. Inc. v. Reno, 139 F.3d 804, 807 (10th Cir.1998), held that the “secondary producer” requirements of the regulations to be unconstitutional. We rely on that holding, and further decline to violate the privacy of the performing artists by disseminating private data when not required to do so by law.

If you have any questions regarding this policy, please do not hesitate to call, or have your attorney do so.

The Law Office of Jeffrey J. Douglas
By: Jeffrey J. Douglas