cooper harvey charged
10:36 GMT 28 Nov 2019. Cooper objects to the Court considering paragraphs eleven and sixteen of Harvey's affidavit. 1986). 162, Cooper Resp. Citizen Lobby, Inc. v. ExxonMobil Corp., No. 3). Code 16.051). The agreement Cooper asks this Court to enforce is one where he videotaped shows at Harvey's club, and, in return, Harvey conveyed rights in the footage to him, along with a sum of money. Id. . Oct. 1, 1999) (declining to rule on laches claim as a matter of law because of fact issues). For this reason, there exists a genuine issue of material fact as to whether Harvey signed the document, and thus whether there is actually a valid, enforceable contract. "[T]he justification defense can be based on the exercise of either (1) one's own legal rights or (2) a good-faith claim to a colorable legal right, even though that claim ultimately proves to be mistaken." Despite arriving at the club as a lateselection, Harvey looked right at home alongside the other big 2022 AFL Draft names like Will Ashcroft, Elijah Tsatas, and now teammate Harry Sheezel. At this juncture, Harvey has failed to show that he is entitled to attorneys' fees. 46-47. Harvey argues that Cooper's affidavit is a "sham affidavit," though, and is therefore not competent summary judgment evidence. 53-54, Seaman Dep. Compare Tex. Funeral info: 708-383-3191. 151, Cooper MSJ 1-2 (internal quotation marks omitted). . R. 7.2(e). 802 & 402). See Doc. but this does not affect the interest charged on the finance agreement, which is set by the lender. Therefore, there exists a genuine issue of material fact as to this element. 15, 2013), rep't and rec. Doc. 152-2, Cooper App. Cooper rebuts this characterization and suggests it was Anderson's interference, not any sort of independent trepidation regarding Cooper's ownership rights, that caused MVD to forgo the agreement. In short, he contends that none of the agreements Cooper alleges he had with him gave Cooper copyrights in Harvey's works, nor do they give Cooper any right to market, distribute, or sell the tapes, or to use Harvey's name, image, or likeness. Co., 492 F.3d 634, 638 (5th Cir. 136, Order 3). Thus, it will not consider this objection. Instead, and aside from case law, Cooper cites only (1) his own Original Complaint (Doc. 78:2-79:1 & 99:9-20). Puzzlingly, Cooper cites his appendix in his Response to Harvey's summary judgment motion, but not in support of his own summary judgment motion. Get to know North Melbourne's fourth and final selection of the 2022 AFL Draft, Cooper Harvey. Neely v. Wilson, 418 S.W.3d 52, 72 (Tex. 2, Harvey Aff. [his] right[s]." Id. See Nat'l Architectural Products Co. v. Atlas-Telecom Services-USA, Inc., CIV.A. . 's Objs. Neither objections have merit. 156, Harvey App. 162, Cooper Resp. To prove his point, Cooper cites (1) his own affidavit, Doc. 1994) (per curiam) (citing Celotex, 477 U.S. at 325). 136, Order 3, 6. DALLAS (CN) - A federal jury rejected a videographer's $50 million claim against comedian and talk show host Steve Harvey, who refused to release video of his old comedy routines containing embarrassing material. To support this position, Harvey points to his own affidavit, where (1) he indicated that MVD initiated all contact with him and his representatives, who, in response, only notified MVD that they had no relationship with Cooper, nothing more, id. Fed. 1989). Specifically, he points to the 1998 lawsuit, where Harvey admitted that Cooper did assert his purported right to sell, advertise, and mass produce videos from the contested footage. The fact that the "[o]riginal videotapes remain the exclusive property of [Cooper]" would not necessarily deprive Harvey of his right to screen them in his club. Because the motions presented many convoluted and overlapping issues and arguments, this Court struck them and ordered the parties to file one summary judgment motion each. Doc. 6:21-7:1. In short, Harvey suggests he had an exclusive copyright interest in the tapesand, thus, either a legal right or a good-faith claim to a legal rightthat permitted him to contact MVD. New Century Fin., 2005 WL 2453204, at *11 ("[A] finding of laches seems inappropriate on summary judgment where the parties contest several key facts. Coinmach Corp. v. Aspenwood Apartment Corp., 417 S.W.3d 909, 923 (Tex. The handwritten portion of the purported contract, appearing after the words "Services Included," reads: And, contrary to Harvey's argument, see Doc. 802, 402 & 403). Accordingly, Harvey's argument on this element is framed under the COC Services test, which seems to combine the "proximate cause of injury" element with the "independently tortious or wrongful act" element to form a single element: "that the independently tortious or wrongful act prevented the relationship from occurring." When it did so, the Court also denied Cooper's requests for a preliminary injunction and declaratory judgment establishing his rights to market, distribute, and sell tapes of the performances in question; denied Cooper's Motion to Dismiss certain paragraphs of Harvey's First Amended Answer; and struck certain language in other paragraphs of that answer. Next, Harvey argues that, even if there was a reasonable probability that Cooper and MVD were going to enter into a business relationshipand even if Harvey interfered with that process, he did not do so with a conscious desire to prevent the relationship, or with knowledge that such conduct was certain or substantially certain to result in interferencemeaning Cooper cannot establish this element. 42 (citing Doc. See Doc. & Rem. 156, Harvey App. In short, it appears Cooper seeks summary judgment on his claims for (1) breach of contract and (2) tortious interference with prospective business relations, as well as (3) Harvey's affirmative defenses and (4) counterclaims. 151, Cooper MSJ 8. Life Ins. Both summary judgment motions are now ready for review. 163, Def. 1994)). Doc. Doc. 154, Harvey MSJ 25 (citations omitted). . He used cash to buy a one-way ticket on . Doc. 1990). Harvey responded by offering a number of affirmative defenses, Doc. Doc. Because a genuine issue of material fact would exist whether or not the Court considered Cooper's affidavit, it need not weigh in on Harvey's argument here. The jury deliberated for several hours before concluding on Thursday that plaintiff Joe Cooper . 163, Def. 204(a). NORTH Melbourne parted with pick one to wield two top five selections at this year's draft, with a father-son nominee and bargain slider among seven fresh faces to land at Arden Street. Id. I know that I didn't feel good about things. But simply waiting to exercise a right, so long as that right is not time-limited by contract or law, does not necessarily mean that one intends to waive a right. Harvey says Cooper has no contract with MVD, or any other entity for that matter, meaning no agreement exists with which he could have actually interfered. In support, he offers three pieces of evidence. This, he says, "constitutes the torts of defamation and business disparagement." Id. 126). . 3-9, Cooper Aff.). adopted, 2013 WL 1926375 (N.D. Tex. Victoria Police confirmed to Daily Mail Australia they are investigating after a video recorded on October 12 was posted online. N. Cypress Med. 154, Harvey MSJ 18 (citing Doc. Restraining Order); and (3) Harvey's Original Petition and Application for Injunctive Relief, id. Tex. R. Evid. Before her $60 million deal with Spotify and before skyrocketing her career . And my little fellow, Hudson, he's 7 and he's playing Under-9 this year. 22). Id. Cooper responds by pointing out that Harvey has cited (1) Tex. In addition to moving for summary judgment upon all of Cooper's claims, Harvey also moves for summary judgment upon his own affirmative defenses, starting with waiver and laches. 76); (5) the minute entry from Magistrate Judge Stickney's hearing on some of the discovery issues in this case (Doc. Dubbed the "First Lady of Radio," Harvey's sixty year career in radio transformed American radio and television news format. Compl. See Doc. 170, Def. 162, Cooper Resp. Harvey also moves for summary judgment on Cooper's claim that Harvey engaged in tortious interference with prospective business relations when Harvey contacted MVD to tell it that Cooper did not actually have rights to the tapes. 152-1, Cooper App. v. Fin. Closed: 113: 05/11/21: Montrell Harvey: 26: 500 North Curley Street: Shooting victim: None: 114: 05/13/21: Gary Wilson: 30: 3000 Normount Court: . See Doc. to Def. 48-51; and (3) tortious interference with prospective business relations. 44. Instead, section 16.501 applies. R. Evid. Civ. 1, Compl., and his Amended Complaint on June 29, 2015. Doc. ACS Investors, Inc. v. McLaughlin, 943 S.W.2d 426, 430 (Tex. See id. Partial Summ. 162, Cooper Resp. 162, Cooper Resp. It is easy to envision a scenario where Harvey has the right to "loop[] the tapes for continuous play before, during and after show performances" and Cooper has the right to "use the original tape and/or reproductions for display, publication, or other purposes." 20). ET Former Harvey Park District official Dionne Cooper faces new government theft charges, alleging she made personal purchases with Park District debit card. 's Mot. AFL games record holder Brent Harvey discusses son Cooper at the Kangaroos' 2016 Father-Son Day. According to Cooper, Harvey sent twelve "take down" notices to Google to try to force the company to remove some of the contested footage from YouTube, id. Able Energy's Michael Harvey faces up to 20 years in prison for accusations of stealing more than $1 million from his customers. at 11. Son of a gun. There is a genuine issue of material fact here. for Injunctive Relief 5. . 2d 680, 692 (N.D. Tex. in negotiating any type of entertainment contracts." 163, Def. But the Court's analysis as to Harvey's misappropriation claim turns upon Cooper's defense under section 29 of the Restatement (Third) of Unfair Competition. Cooper says the Court cannot consider this evidence. If the movant on summary judgment bears the burden of proof on a claim or defense, he must produce evidence that establishes "beyond peradventure" the elements of that claim or defense. 16.501. 6 (citing Fed. Harvey objects to the Court considering his Original Petition and Application for Injunctive Relief from the state court lawsuit. Id. Cooper offers a number of arguments for why the Court cannot consider this evidence. In support, Harvey cites Seaman's deposition, where Seaman, when asked if he would have entered into the agreement if his company's counsel had not talked to Anderson, said, "It's hard to say. Perhaps a father-son candidate flying under the radar, Cooper Harvey is certainly well known to North Melbourne fans. For the following reasons, the Court DENIES Plaintiff's Motion and GRANTS in part and DENIES in part Defendant's Motion. Specifically, Harvey argues that Cooper has not pointed to an actual contract with which Harvey could have interfered. 130:8-19. Id. Doc. 18:1-19, 20:18-21:8, 30:23-31:10). 4, Harvey Aff. See Impala African Safaris, LLC v. Dall. But he says that he is now asking for a permanent injunction, whereas he only asked for a preliminary one earlier. 152-1, Cooper App. JOSEPH COOPER, Plaintiff, v. BRODERICK STEVEN "STEVE" HARVEY, Defendant. But Cooper overlooks the fact that "judicial admissions are not conclusive and binding in a separate case from the one in which the admissions were made," so this argument fails. Here, Harvey says these include: (1) "the specific terminology used in the agreements"; (2) "the lack of discussion of selling or distributing the recordings in the Video Invoice"; and (3) "the roles of the parties - performer and videographer - at the time the services under the Video Invoice were performed." 's Req. Harvey Cooper | 240 followers on LinkedIn. See Fed. He also points to (4) the original contract, id. 3:15-CV-1225, 2015 WL 4750786, at *2 (N.D. Tex. Insofar as Cooper's Response can be construed as a motion for the Court to reconsider its ruling, the Court notes that Cooper has provided no reason for why it ought to do so. The 2019 Writing Prize will be given to a student who has written an exemplary essay or research paper on an American subject . So, according to Harvey, Cooper's claim is barred because he brought it more than four years later, in November 2014. Get to know North's newest father-son selection. . Presented with his substandard briefing, this Court is under no obligation to sift through Cooper's 276-page appendix to find evidence that supports his various assertions. 7. . 59:7-9), as well as (2) the actual contract, which, according to Harvey, merely indicates Cooper would "record 'promotional material' that would be used 'for continuous play before, during, and after show performances,'" and contains "no provisions . 2, Aff. Ctr. at 3-4. The son of AFL games record holder Brent, he boasts similar instincts around goal but is slightly taller as a midfielder/forward. Marceline Harvey, 83, is charged in the murder of Susan Leyden, 68. ], he chose not to cite any portions of it in his brief. "Under Texas law, a valid contract requires an offer, acceptance, mutual assent, execution and delivery of the contract with the intent that it be mutual and binding, and consideration." Further, the Court notes that Harvey does not seem to contest the second element of a breach of contract claimwhether Cooper performed or tendered performance thus it does not analyze it. 23:8-22. Cooper's breach claim is not barred. 151, Cooper MSJ 14. 24:24-25:23). So, from Cooper's point of view, "[because he] owns the original video tapes[,] . Doc. 2006)). In other words, if it would take more than a year for Cooper to videotape the shows required under the contract, then the agreement is subject to the statute of frauds. Father-son selection Cooper Harvey and North Melbourne great Brent face the media after the 2022 AFL Draft, North Media chats with Cooper Harvey and dad Brent after the Kangaroo great's son was drafted to the club, North Media takes you inside the Harvey household as Cooper, the son of League games record holder Brent, became an AFL player, AFL games record holder Brent Harvey discusses son Cooper at the Kangaroos' 2016 Father-Son Day, Meet pick No.56 Cooper Harvey from the Northern Knights, Check out the highlights of 2022 NAB AFL Draft prospect Cooper Harvey, Cooper Harvey, the son of AFL games record-holder Brent, wants to create his own legacy at the top level, Get to know North's newest father-son selection, The newest Harvey has officially arrived at Arden Street after North Melbourne used pick No.56 in the 2022 AFL Draft on Cooper, the son of Kangaroos great, Brent, North Melbourne will nominate Cooper Harvey as a father-son prospect in the upcoming AFL Draft, You are currently logged in to Club Exclusive access. . 152-1, Cooper App. She was unaware anything had happened to her until she went to school the following week and a friend showed her a video circulating on social media of her while she was unconscious. 2015)). Brent left a permanent legacy at North Melbourne, and now Cooper will have the opportunity to etch his own name into the club's storied history. See Note 40. 48-51; and (3) tortious interference with prospective business relations. 's Objs. for Injunctive Relief 3). Jack Ruby, the Dallas nightclub owner who killed Lee Harvey Oswald the accused assassin of President John F. Kennedy is found guilty of the "murder with malice" of Oswald and sentenced . (citing Doc. So, the promise would need to be in writing. 2007, no. See generally Doc. Lori Harvey, the daughter of Steve Harvey, has been charged with hit and run and resisting arrest by Los Angeles County prosecutors. 154, Harvey MSJ 7-8. CHICAGO (CBS) -- Two pregnant women accused a South Suburban Harvey police officer of serious misconduct, even beating one of them and causing her to . In support of his position, Harvey cites only a portion of his affidavit, where he swore he never signed the agreement. "A contract may be the subject of an interference action even though it is unenforceable between the contracting parties. 32-34, Examples of Ads). Southern District of Mississippi (601) 965-4480. Cooper, also known as Dan Cooper, criminal who in 1971 hijacked a commercial plane traveling from Portland, Oregon, to Seattle, Washington, and later parachuted out of the aircraft with the ransom money. 45 (citing Doc. 170, Def. Therefore, it will not. Earlier that day, an injured Cooper's Hawk found himself a safe space to wait out the storminside a Lone Star taxicab. By Atahabih Germain Jan. 14 2020, Updated 3:02 p.m. 117); (3) Cooper's Motion to Dismiss Harvey's Amended Complaint (counterclaims) (Doc. Cooper's father Brent played 432 games in the blue and white, setting the AFL games record in the process. Id. 2009) (citations omitted). Our ever-changing showroom features brands such as Audi, BMW, Mercedes-Benz, Jaguar Land Rover and many more. Doc. 801(d)(2). Doc. For the reasons set forth in Part III(B)(1)(ii)(a), the Court finds that the scope of the purported Video Contract, and whether Harvey signed it, are ambiguous. at 11-12. [on the] tapes," thereby "attempt[ing] to have [the owners and principals] influence Harvey to pay extortion money to [Cooper] for the tapes." Cooper objects to the Court considering this part of Harvey's affidavit, but because the Court's analysis depends only upon Golland and Seaman's testimony, Harvey's affidavit has no effect, and the Court need not rule on its admissibility. Second, he offers Harvey's deposition, where Harvey evidently admitted that he never contested Cooper's ownership of the videos until this lawsuit: Cooper only cites page ninety-six, but the excerpt is found on part of page ninety-five, as well. Though Cooper objects to a portion of paragraph twenty-two of Harvey's affidavit, he does not object to the relevant language"Any arrangement that [MVD] had with . Nowhere does he cite his appendix. Id. See Matter of Pirani, No. 60. 4, Harvey Aff. Doc. . 152-1, Cooper App. Elvis Presley Enters., Inc. v. Capece, 141 F.3d 188, 205 (5th Cir. Servs., Inc., 4:11-CV-0685, 2012 WL 2870639, at *7 (S.D. 151, Cooper MSJ. Vincent Harvin charged of one count of murder of Walter Glen and two counts of attempted murder in 1990. They are relevant as they pertain to the contract at issue in this suit. And when Harvey evidently violated the 1998 restraining order, Cooper did not sue. Doc. 2000) (citation omitted). 's First Am. As a side note, Harvey argues that any potential agreement between MVD and Cooper would have constituted an unenforceable, void agreement to commit copyright infringement. But this exchange came immediately after Cooper was asked whether he "had any other type of experience[,] besides [the] experience [he] sa[id] [he] ha[d] in negotiating recording contracts[,] . Thus, the Court need not determine whether Harvey's affidavit is admissible. 162, Cooper Resp. . 1- 2 [hereinafter Cooper MSJ]; Doc. There are 50+ professionals named "Harvey Cooper", who use LinkedIn to exchange information, ideas, and opportunities. 154, Harvey MSJ 7 (citing Doc. 10; Doc. 26, Am. [hereinafter Def. 127). . Richard Harvey, who shot an 84-year-old anti-abortion canvasser outside his Ionia County home after she was involved in a heated exchange with his wife, turned himself in to law enforcement Friday . Id. Id. Richard Harvey, left, speaks to a WOOD-TV reporter about a 20 September 2022 shooting of an anti-abortion rights group volunteer with which he has been charged. Upon hearing Courtney's rousing tune "Fire", Cooper and Weinstein decided it had the perfect recipe to fit into the comedy-drama about a top chef trying for his third elusive Michelin star . (quoting Doc. While this document is, indeed, an unsworn pleading, inadmissible for summary judgment purposes, the Court's analysis turns on the Video Contract and Harvey's statements. Ctr. Compl. Driven by happy customers! Review Servs., Inc., 29 S.W.3d 74, 80 (Tex. of Joseph Cooper 17, 20-21 [hereinafter Orig. At his Manhattan Criminal Court arraignment Wednesday . Cooper Aff. At a minimum, Seaman's and Golland's deposition testimony contradict each other. 152- 1, Cooper App. Harvey joins Jackson Archer, Bailey Scott and Luke McDonald as father-son selections on North Melbournes list. for Injunctive Relief). 156-1, Harvey App. in Supp. Sterner v. Marathon Oil Co., 767 S.W.2d 686, 689 (Tex. & App. 53-54 [hereinafter Harvey App. Cooper Harvey - son of North Melbourne legend and AFL games record holder Brent - has enormous shoes to fill if he is to follow in the footsteps of his father. 22), as well as Seaman's deposition, where (2) Seaman also indicated that it was MVD that reached out to Harvey and/or his representatives, not vice versa, id. Harvey says Cooper even went so far as to offer to "sell" him back the tapes for five million dollars. Summ. To show he was justified in interfering with Cooper's negotiations, Harvey points to his own affidavit, arguing that any contact with MVD was "merely to protect his exclusive copyright interests" in the tapes, and that Cooper cannot show that Harvey did not have a legal right to assert these purported rights. Harvey uses the same evidence to support both his waiver and laches claims. 12-14. 164, Original Pet. Lynne Cooper Harvey Writing Prize. To show it is likely that Cooper would not, in fact, have entered into such an agreement, Harvey offers two portions from MVD CEO Edward Seaman's deposition, where Seaman testified that: (1) when he sent Cooper a working draft potential agreement, he had not yet seen proof that Cooper owned the tapes, id. Police are dealing with a suspicious package, possibly a pipe bomb, near the Wendy's fast food store at 2070 Harvey Ave. Full title:JOSEPH COOPER, Plaintiff, v. BRODERICK STEVEN "STEVE" HARVEY, Defendant. 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CA 3:98-CV-1348, 1999 WL 304561, at *8 (N.D. Tex. Harvey moved to exclude paragraphs twenty-four to thirty-three of Cooper's affidavit, see Doc. Although it's likely that the Roos would lean towards using him as a forward, having the ability to find his own football through the midfield and use it with composure will certainly serve him well in the AFL system. Doc. So, it need not consider the petition, nor rule on its admissibility at this time. Video Contract." Oxford, England, United Kingdom. Summ. Indeed, examining Harvey's interrogatory response, the Court sees nothing to suggest he suffered undue hardship. 161, Pl. 62-2, Orig. 15. 59:7-9). Conversely, Cooper says the evidence shows that he has always asserted his ownership and publication rights to the videos. He says no reasonable jury could find Cooper demonstrated: (1) there was a reasonable probability that he would have entered into a business relationship with MVD absent Harvey's interference; or that (2) Harvey contacted MVD with a conscious desire to prevent a business relationship between MVD and Cooper (or with knowledge that his conduct was certain or substantially certain to result in interference); (3) Harvey engaged in independently tortious conduct (business disparagement and/or defamation); (4) Harvey's contact with MVD proximately caused Cooper's damages; or (5) Cooper suffered damages at all. Cooper cannot do that. Born and raised in St. Louis, Angel as she was universally known earned both a bachelor's and a master's degree in English from Washington University and worked at local radio station . Prac. I can't really answer that fairly. to Pl. (citations omitted)). 152-3, Cooper App. Tex. 's Objs. . 151, Cooper MSJ. that [Cooper would release] the material . Doc. 's Am. Brassel, a longtime coach with the Harvey Colts youth football team, and Cooper, his assistant, were shot to death on April 20, 2011, in the home they shared in the 15100 block of South Myrtle . Last up is Harvey's statute of frauds affirmative defensethat Texas law requires he and Cooper's purported agreement be memorialized by a writingwhich he moves for summary judgment upon, based on the fact that Cooper cannot produce such a writing. Harvey impressed throughout the affair and particularly stood up in the third term to help Metro gain the lead. 's Objs.]. 156, Harvey App. See Part III(B)(3)(i). Element 1: Reasonable probability of a business relationship. Accordingly, the Court cannot conclude that Harvey suffered undue hardship, so his laches defense fails, as well. (citing Seagull Energy E & P, Inc. v. Eland Energy, Inc., 207 S.W.3d 342, 345 (Tex. A. Cooper's Motion for Partial Summary Judgment. Prudential Ins. But because both sections impose a four year limitations period, this distinction has no effect. The highway remains closed between Spall and Cooper roads. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). On July 6, 2015, Cooper filed his Second Amended Complaint, now the operative pleading in this case, suing Harvey for: (1) breach of contract, Doc. If the non-movant is unable to make such a showing, the court must grant summary judgment. MVD CEO Ed Seaman's deposition is clear on this point: 3. Doc. 701. Id. Specifically, Cooper seeks a declaratory judgment establishing he and Harvey's rights to the contested video footage under the purported Video Contract. 151, Cooper MSJ 2-3, with Doc. As to Cooper's substantive arguments, he contends that he and Harvey did, indeed, have a valid contract. Search. 68. The Court sees no relevant distinction between a permanent and preliminary injunction, and Cooper does nothing to identify one. Id. Despite struggling with an injury earlier in his 2022 campaign, Harvey strung together an impressive stretch of games that resulted in him cracking into the Victoria Metro side for the Under-18 National Championships decider against Victoria Country. Cooper Aff. This Court already denied both and explicitly instructed the parties to not raise these issues again. 162, Cooper Resp. It is not entirely clear whether Harvey argues that Cooper cannot show Harvey's actions proximately caused his damages. Marks omitted ) though it is unenforceable between the contracting parties eleven sixteen... 634, 638 ( 5th Cir and is therefore not competent summary judgment motions are now ready for review id! Year limitations period, this distinction has no effect an American subject twenty-four to of... View, `` constitutes the torts of defamation and business disparagement. of in... Not conclude that Harvey suffered undue hardship, so his laches defense fails, as.. 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Capece, 141 F.3d 188, 205 ( 5th Cir, '' though and. Son Cooper at the Kangaroos ' 2016 father-son Day Defendant 's Motion and in. A student who has written an exemplary essay or research paper on an American subject S.W.2d 426, 430 Tex... That he and Harvey 's affidavit is a `` sham affidavit, Doc research paper on an subject! From case law, Cooper cites only a portion of his affidavit Doc. 430 ( Tex of AFL games record holder Brent Harvey discusses son Cooper at the Kangaroos ' 2016 father-son.! Holder Brent, he says that he and Harvey 's Original Petition and Application for Injunctive from! ( 1 ) his own Original Complaint ( Doc and two counts of attempted murder in 1990,! With hit and run and resisting arrest by Los Angeles County prosecutors showing, the would! Genuine issue of material fact as to this element only ( 1 ) Tex Injunctive Relief id. To offer to `` sell '' him back the tapes for five million dollars his Amended Complaint cooper harvey charged. 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