deage 1 of 28) VENABLE LLP ORIGINAL wp @ 10 ul 12 3 14 1s 16 7 18 19 20 ai 22 23 4 25 26 Pu 28 ‘Alex M. Weingarten (SBN 204410) FILE ‘AMWeingarten@Venable.com Sugoor eu ER, Jeffrey K. Logan (SBN 136962) oun of Los Aneag IKLogan@Venable.com VENABLE LLP SEP 15 2015 2049 Century Park East, Suite 2100 os Los Angeles, CA 90067 _ ee iW OficeaCienk Telephone: " (310) 229-9900 > Facsimile: (310) 229-9901 y mens Attorneys for Plaintiffs MATHEW CULLEN and MOTION THEORY, INC. SUPERIOR COURT OF CALIFORNIA. FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT MATHEW CULLEN, an individual; and | Case No. MOTION THEORY, INC., a California | BOS 94640 corporation, COMPLAINT Plaintiffs, | v. Failure of Consideration; 3) Declaratory Relief; CHRISTOPHER S. HANLEY, an individual; 4) Misappropriation of Name and MUSE PROUCTIONS, INC., a California Likeness; and corporation; JORDEN DEREK GERTNER, an 5) Unfair Competition in Violation of individual; HERO ENTERTAINMENT, an unknown business entity; NICOLA SIX LIMITED, an unknown business entity; and DEMAND FOR JURY TRIAL DOES 1-50, inclusive, Bus. & Prof. Code §§ 17200, e¢ seq. Defendants. Td BBS8 8S Raa bees RB agages! oh 7 gz oa a wage 2h 8 33 3 Gass 43 B888 5 CEMLAINT ‘boot 1 Pages 1 = boo TD = 1627S57961 ~ Doo Typerage 2 VENABLE LLP. of 2 wn he 6 a u 12 13 14 15 16 17 18 19 20 2 2 2B 24 25 26 a 28 Plaintiffs Mathew Cullen and Motion Theory, Inc, for their Complaint against Defendants Christopher S. Hanley, Muse Productions, Inc., Jordan Derek Gertner, Hero Entertainment, Nicola Six Limited, and Does 1 through 50, each of them, allege as follows: NATURE OF COMPLAINT 1, This isa case of life imitating art —namely, the Martin Amis novel, London Fields, upon which the film that isthe subject of this dispute is based. In the novel, a surprise ending introduces a “revisionary” author, Mark Asprey, so as to make it impossible for the reader to tell which passages of the narrative might have been genuinely those of the narrator, ‘Samson Young, and which may have been tampered with by Asprey. Similarly, inthis case, the defendant producers have tampered with Plaintifis’ work as director ofthe film, Unlike the novel, which reveals the revisionary author, Defendants have concealed their fraudulent efforts to pass off their work as that of Plaintifis 2. None of the revisionary elements that Defendants have interjected into the film appear anywhere in the script. Nor do they have any place in the film, atleast not the one that Plaintiffs were asked to direct. Among other things, these elements include incendiary imagery evoking 9/11 jumpers edited against pomography, as well as juxtaposing the holiest city in Islam against mind-control. No cast or crew member signed up for this, nor did Plaintiffs. But Defendants insist upon doing this, and more, in the names of Plaintiffs and others, notwithstanding their objections to the theft of their identities and the false, distorted and. perverted associations that Defendants are imposing upon them. 3. Toaccomplish this feat, Defendants have perpetrated one fraud after another, ‘rom the hiring of Plaintiffs based upon false promises, to the ongoing marketing and promotion of their rendition of the film as something which itis not —a film directed by Mathew Cullen. Accordingly, Plaintiffs seek damages against Defendants based on claims including fraud and the misuse of their rights of publicity. Plaintiffs also seek rescission of the agreement upon, which Defendants rely in perpetrating their fraud, as well as injunctive relief for unfair, ‘COMPLAINT ‘Dock i Pagek 2 ~ nos FO = WeaTSNNEAI ~ Doo Type(rage 2 of 20) e @ 1} untawful and fraudulent business acts and practices in violation of Business and Professions | 2. || Code Sections 17200, et seg 3 PARTIES 4 4. Plaintiff Mathew Cullen (“Cullen”) is an individual who is and at all relevant 5. || times has been a resident of Los Angeles County, California 5. Plaintiff Motion Theory, Inc. (“Motion Theory”) is a corporation, which is organized under the laws of the State of California and which has and at all relevant times had. 6. Defendant Christopher S. Hanley (“Hanley" 6 7 8 || had its principal place of business located in Los Angeles County, California. 9 an individual who is and at all 0 ul 7. Defendant Muse Productions, Ine. (“Muse Productions”) is a corporation, which | relevant times has been a resident of Los Angeles County, California, | 12. |}is organized under the laws of the State of California and which has and at all relevant times hed 13. || had its principal place of business located in Los Angeles County, California. At all relevant | 14. |} times, in doing the things alleged herein, Defendant Hanley has served as a managing agent of | 2 i g VENABLE LLP. i i 15. }] Defendant Muse Productions, 16 8. Defendant Jordon Derek Gertner (“Gertner”) is an individual who conducts and 17 |) atall relevant times has conducted business in Los Angeles County, California. 18 9, Defendant Hero Entertainment is a corporation or other entity or company, 19. |} which conducts and at all relevant times has conducted business in Los Angeles County, 20 || California, Ar all relevant times, in doing the things alleged herein, Defendant Gertner has 21 | served as a managing agent of Defendant Hero Entertainment. 2 10. Defendant Nicola Six Limited is « corporation or other entity or company, which 23, |} conducts and at all relevant times has conducted bt ss in Los Angeles County, California 24 |] Atall relevant times, in doing the things alleged herein, Defendants Hanley, Gertner and their 195. [respective companies, Muse Productions and Hero Entertainment, have served as managing + 26 |f agents of Defendant Nicola Six Limited. @ 7 n 28 ce) COMPLAINT i = 1 27887941 ~ Doo Type = OTHERi 1 JL. Plaintiffs are unaware of the true names and capacities of the Defendants sued 2. || herein as Does 1 through 50, inclusive, and for that reason, sue said Defendants by such 3, | fictitious names, Plaintiffs will amend their complaint to allege the true names and capacities of 4 |) said fictitiously named Defendants upon ascertaining the same. Plaintiffs are informed and 5 || betieve, and upon that basis allege, that cach fictitionsly named Defendant is responsible in some manner for and proximately caused the harm and damages alleged. [ON ALLE! TONS 12. Plaintiif Mathew Cullen is a 20 year veteran of production and has directed and produced hundreds of commercials, music videos and multi-platform projects, including two of 10 |} the most viewed videos of all time: Katy Perry's Dark Horse at #3 and Roar at #4, both with 11, |] over a billion views. Rolling Stone has named Cullen to its annual Hor List, and Wired called 12. |[ him one of six directors who are making music videos cool again. Cullen has received Grammy ay 35 i 13. Avarésforthe mack Eyed Pes’ Boom Boom Pow and Weezer's Porkand Bears, the most ELE 14 |] blogged-about video 02008. He has been honored by MTV VMA, MTV EMA, Cannes, ADC, z H * 45 |]D&AD, Youtube and Emmy. 2 1 1 13. Callen is the founder of the production company Motion Theory and has "17 Jf overseen production of over 500 projects. Cullen joined forces with Guillermo del Toro in 2010 18 |} to launch Mirada, a studio designed for storytellers. Under his direction, Mirada launched a 19. |} number of multi-platform experiences, including IBM's THINK Installation, Google Cardboard | | 20 || ve and MirrorWorl, a living storybook app for Comelia Funke’s book series, the latter two 21 |} garnering Cannes Lions in Animation, Ilustration and Graphic Design, and Best Visual 22. || Design/aesthetc. o 3 14. Cullen has creatively collaborated with icons Beck, Billy Bob Thornton, Robert 24. || Downey Jr., Jennifer Garner, Phatrell, Taylor Swift, REM, Prince, Green Day, Kanye West, th 25 || Say-Zand introduced Adele to the world with his muse video Chasing Pavements, In 2013, 26 |} Cullen worked under the mentorship of Guillermo del Toro, and designed and directed the i © 27 [prologue to the film Pacific Rim, P28 4 COMPLAINT ‘Boch 4 Pagel 4 ~ Doo ED = 1627587941 ~ Doo type = OER(rage 5 of 25) 1 15, On or about April 10, 2013, Cullen met with Jordan Gertner about directing the 2. || feature film London Fields. At the time, Cullen had been exploring opportunities for his feature 3. || directorial debut, and Gertner explained that he and his “partner,” Chris Hanley, desired to have 4 |} Cullen direct London Fields. Cullen had never worked with Gertner or Hanley, and was aware 5. || that other directors had previously been attached to the film only to leave the project. Cullen 6 |] explained that he was reticent to pass up other opportunities end put his own productions on 7_ |) hold unless Defendants had the wherewithal to produce the picture and were willing to cede 8 || creative control to Cullen in making the film. 9 16. Among other things, Gertner assured Cullen that he and Hanley would give 10 || Cullen the freedom to make the film according to his own creative vision without interference, : 11, }) To substantiate this promise, Gertner explained that he could deliver on his assurances to Cullen ag 12 |] beemusehe and Hanley diet or ndrecty owned and had sole contol over the right the 2 = 2. 13 || film Gertner added that he knew what it meant fr a director to have control over the creative aii A 14. || process of a film project because he and Hanley were knowledgeable and experienced film i i : * 15 |] producers with their own production companies, Hero Entertainment and Muse Productions, - : 16’ | respectively. Gertner also volunteered that the script for the picture was too long, and in need of 17 |} substantia! work and focus, again reiterating to Cullen that he would have their support and 18} autonomy in revamping the script and shooting of the film in accordance with his vision forthe 19 || picture. Gertner further assured Cullen that he would have all ofthe support that he would 20 |) need, including financial suppor, in order to make a successful film. Gertner expressly 21. |} represented to Cullen that he and Hanley had financing or other funding in place for production 22. |[ ofa film with an estimated budget of approximately $8 milion. : 2 17. Gertner assured Cullen that Hanley was of the same view, and encouraged s. 24 |} Cullen o speak with Hanley to discuss his expectations regarding the film. The next day, on or 5 25 |} about April 11,2013, Cullen spoke by telephone with Hanley, who confirmed and also 26 | represented to Cullen that he would have freedom to make the film without interference from {27 [ftmem. Hanley added in substance and effect, “I am a diector's producer, [let you make your wl COMPLAINT Dock 2 Paget & - Doc ID = 4620657941 ~ boo type = omaR1 || film, The most involved that I will ever be is this phone call.” Hanley also adopted and 2. |) reaffirmed Gertner's representation that they had funding to produce a film costing in the range 3. |} of $8 million or so to produce. 16_ || and production designer to scout and lock down locations for principal photography. After 17 || returning to Los Angeles, Cullen continued providing pre-production services in June and July, 18, |] 2013, and retumed to London on or about July 29, 2013, to finalize pre-production and prepare 19. |] for principal photography. 4 18. Onorabout May 1, 2013, the parties orally agreed to certain deal points for 5. || Cullen to serve as director ofthe film. ‘These points included fixed compensation to Cullen in | 6} the amount of $300,000, pay ot play as of July 1, 2013, and payable 20% over pre-production, | 7, |] 60% during principal photography, and the balance during post-production. ‘The parties also 8} agreed thatthe production would be a “DGA" film, subject to the rules and regulations of the 9. || Directors Guild of America (the “DGA” or “Guild, and that Cullen shall have a least three 10 |} cuss and three public previews for the fim eu 19. Cullen reasonably and justifiably relied upon Defendants’ assurances and other aq 12 || representations as alleged herein, including thee approval of the foregoing deal points. Among 3: i 13 [other things, Cullen undertook in May, 2013, to provide development and pre-production 2 i g i 14. || services for the film, including re-working of the script, casting, meetings with actors, and i i 7 * 15 Il scouting of locations, Near the end of May, 2013, Cullen traveled to London with his assistant 20 20. On or about September 9, 2013, Cullen commenced principal photography for 21. |} the film, which continued until approximately October 31, 2013. The shoot took place on 22 |} locations in London and surrounding areas, All the while, no contract had been executed by the 23, | patti * 24 || photography commended. Accordingly, Cullen advised Defendants through their respective nor had a contract even been provided for Cullen to sign as ofthe time when principal j in 25. | representatives that he was proceeding in reliance upon the deal terms expressed back on May | + 96 ff,2013. 3 27 2 ‘COMPLAINT got 6 ~ Doo 1D = 1607857941 - Doo Type = ori(rage 7 ot 25) 1 21. As principal photography progressed, it became increasingly apparent that 2 |} Defendants were unable or unwilling to fund the production of the film as they had represented to Cullen, This caused significant disruption and interference with the filming. Among other things, actors and crew were not paid, leading some to quit or walk off'the set, Also, no 5 || compensation had been paid to Cullen even though payments were long overdue and he was out 6 || of pocket for significant expenses relating to his work on the film. 1 22, To make matters worse, Hanley and Gertner permitted the soreenvriter, Roberta | 8 || Hanley, to substantially interfere with production of the film, Although Geriner repeatedly 9. || promised to fix the problem, neither he nor Hanley did anything to stop the interference, 10 |] Eventually, Cullen attempted to ban Ms. Hanley from the set in an effort to stop her interference | 11. |} withthe production, but she managed to keep reappearing and disrupting the produetion. 2 23, After principal photography, Cullen retumed to Los Angeles to conduct post- | 13. || production for the film. As with ‘pal photography, however, Defendant failed properly to | 14. | fund post-production causing creative talent and support staff to quit the project. To this day, 15 |} Cutten has not been paid as was promised to him. Nor has he been provided the resources | 16 |} needed properly to edit the film, including the three euts and three public screenings promised Vewaeee LLP 17 ||to him. Instead, Defendants have flatly refused to conduct any public screenings of the films, 18. || stating in substance and effect, “we don't do that”or “we can’t afford it” And, of course, 19 || Defendants have refused to honor their promise to produce London Fields as a DGA. film, 20 | including the requirement in Section 7-202 of the Basic Agreement that “in no case will any 21 || creative decision be made regarding the preparation, production, and post-production of 22. |] motion picture without the consultation of the Director.” he 23 24. Defendants not only failed and refused to provide the resources necessary for %. 24 | Cullen to exercise his cutting authority for the picture, but Defendants also secretly prepared 25 || their own version of the film without consulting with Cullen or his consent. In creating their ~ 26 || own version of the film, Defendants have interjected scenes and footage that are highly @ 27 | offensive and neither appear inthe script nor are a part of the film that Cullen was asked to 28 va COMPLAINT ‘Bock 4 Pagel 7 ~ Doo ED = 1627557941 - Doc Type = ozcae 8 ot 28) 1 |[eitect, Cullen has objected to any use of Defendants" version of the film, as have several cast 2. || members and others, Despite these objections, Defendants are currently marketing and 3, |] promoting their version of the film over the Intemet and elsewhere, including at the 2015 4 || Toronto Film Festival, a a film directed by Mathew Cullen. None ofthe incendiary images or 5 || ostensive material that Defendants have interjected in the film are properly attributable tothe 6 | eirectorial services of Cullen, nor does he wish tobe identified or associated with any such | 7 |) material. | 8 FIRST CAUSE OF ACTION | 9 (Fraud — All Defendants) | 10 25. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 11 |] 2sasitset out in fll herein ai 8 26. Onorabout April 10 and 11, 2013, as futher alleged hereinabove, Defendants { 3 is 13 || enmer, Hero Entertainment, Hanley, Muse Production, and Nicola Six Limite, and each of | BEES 14 |{ them, represented to Cullen that Defendants had sufficient financing or other funding in place : i * 15 || for production of film with an estimated budget of approximately $8 million. In fact, i * 46 || Defendants did not have sufficient funding in place to produce such a film, and Defendants 17. |) knew that their representation to the contrary was false atthe time it was made, Yet Defendants 18 || nonetheless falsely represented that they had sufficient funding in place to produce the film in 19. || order to induce Cullen to enter into a transaction to render services and provide facilities that 20 || Defendants desired for production of the film. ty 27. ‘On or about May 1, 2013, as further alleged hereinabove, Defendants Hanley, 22. || Muse Production, Gertner, Hero Entertainment, and Nicola Six Limited, and each of them, © 93} promised and otherwise represented to Cullen that they intended for him to receive a fee for % 24 || directing the production of a film based on the novel London Fields, which included fixed 25. |] compensation in the sum of $300,000, pay or play as of July 1, 2013, and payable 20% over 26 || pre-production, 60% during principal photography, and the balance during post-produetion or 27 || delivery. In fact, Defendants had no intention of paying any such fee to Cullen, and Defendants ‘COMPLAINT Doct 1 Pages 8 ~ boo I= 1627657941 ~ boo Hype = OTHERcage 3 of 23) 1 || knew that their representation to the contrary was false at the time that it was made, Yet Defendants nonetheless falsely represented that they intended to pay or cause the payment of such fee to Cullen in order to induce him to enter into a transaction to render services and provide facilities that Defendants desired for production of the film. 28. Onorabout May 1, 2013, as further alleged hereinabove, Defendants Hanley, ‘Muse Production, Gertner, Hero Entertainment, and Nicola Six Limited, and each of them, ‘promised and otherwise represented to Cullen that they intended for him to receive three cuts and three public viewings in connection with the production of the London Fields film. In fact, Defendants had no intention of providing Cullen with three cuts and three public viewings of | 10 |) the film, and Defendants knew that their representation to the contrary was false at the time that 11 |[itwas made. Yet Defendants nonetheless falsely represented that they intended for Cullen to 2 Eq 12 [recive tee cts an thee public viewings of the film in order t induce him tener into a | 335 4 13-[] transaction to ender servies and provide faites that Defendants desired for production of the rte & 14 [fim i i "45 29. On orabout May 1, 2013, as further alleged hereinabove, Defendants Hanley, 16 |] Muse Production, Gertner, Hero Entertainment, and Nicola Six Limited, and each of them, 17. || promised and otherwise represented to Cullen that they intended for the London Fields film be a 18 || DGA film that is produced in accordance with the rules and requirements of the Guild. In fact, 19. |) Defendants had no intention of producing the film as a DGA film in accordance with the rules 20 || and requirements of the Guild, and Defendants knew that their representation to the contrary 21 |] wos false atthe time that it was made, Yet Defendants nonetheless falsely represented that they 22, || intended to produce the film as a DGA film in accordance with the rules and requirements of the 93. |{ Guild in order to induce Cullen to enter into a transaction to render services and provide 24 || facilities that Defendants desired for production of the film. 2s 30, Plaintiffs did not know that Defendants’ representations as alleged herein were » 26 | false, and reasonable and justifiable relied upon those representation in undertaking to direct the 27 || London Fields film. Had Plaintiffs known that Defendants’ representations were false as 28 COMPLAINT ‘Dost 2 Page 9 ~ bos HD = 4EZTS579N) ~ Doc Bype = OMEER(rage 20 3 25) 1 |[alleged herein, they would not have undertaken to direct the film under the terms provided or at all 31. Asa direct and proximate result of Defendants’ fraud and deceit as alleged 2 3 4, || herein, Plaintiffs were fraudulently induced to enter into a transaction to direct the London 5 || Fields film and to render certain services and incur certain costs in connection therewith, The 6 reasonable value of such services exceeds $300,000, and the costs so incurred include out of 7 || pocket expenses in excess of $800,000, according to proof at tral. In addition, asa further 8. || direct and proximate result of Defendants’ fraud and deceit as alleged herein, Plaintiffs were 9 || fraudulently induced to forego other opportunities, including the production of commercial 10. || advertising for Plaintiffs’ clients and the revenues and profits associated therewith. 3 W 32. As a further direct and proximate result of Defendants’ fraud and deceit as 7 : 12. JJ alleged herein, Plaintiffs have also incurred and continue to incur costs including substantia 2 i i 13 |] eet fess and expenses in conneton wth his tigation inorder to enforee or protest ESE 14 || Plaimins rights as against Defendant Nicole Six Limited, because ofthe fraud and deceit : 5 i * 15 [I perpetrated upon them by other Defendants, including Defendants Hanley, Muse Production, $16 || ermer, and Hero Entertainment, and each of them. “47 33. Asa further direct and proximate result of Defendants’ fraud and deceit as 18. || alleged herein, Plaintiffs have has suffered and continues to suffer damages in excess of $1 19. || mittion, according to proof at tral 20 34, Asa further direct and proximate result of Defendants’ fraud and deceit as 21, || alleged herein, Plaintiffs are entitled to rescission of any agreement with any of Defendants for 22 |) cutien’s work as director ofthe London Fields film. Plaintiffs intend that service of this, | © 93 || pleading constitute notice of rescission and offer to restore any consideration received under the o ». 24 || agreement in the event the Court finds any consideration net of the harm caused to Plaintiffs jw 25. |] was bestowed upon them, provided that Plaintiffs receive restoration of the consideration that 26 | they have furnished and otherwise the complete relief to which they are entitled, including Nv : @ 27 |Jeonsequential damages. re COMPLAINT Doct 1 Paged 10 ~ bas HD = SGB7ED7OGA ~ Doo Fype = OTSER(age 12 of 28) 1 35. In doing the acts alleged herein, Defendants, and each of them, have acted with 2. || oppression, fraud and malice in conscious disregard of Plaintiffs’ rights, and with intent to 3, | cetraud Plaintfts and profit at their expense, all so as to entitle Plaintiffs to exemplary and 4. |} punitive damages in an amount to be determined at tral. 5 SECOND CAUSE OF ACTION 6 (Material Failure of Consideration ~ Defendant Nicola Six Limited) 1 36. Plaintiffs repeat and reallege the allegations contained in Paragraphs | through 8 |] 35 as if set out in full herein. 9 37. Plaintiffs are informed and believe, and upon such basis allege, that Defendant 10. || Nicola Six Limited is the party through which Defendants contend that an agreement with 11 |} Cullen was made for him to direct the film London Fields film, This cause of action is therefore 12. | alleged against Nicola Six Limited. To the extent that Defendants assert than another Defendant 13. |] isa party who entered into such a contract in liew of or in addition to Defendant Nicola Six 14. || Limited, then each such Defendant is also named as a party to this cause of action in lieu of or 3 af S38 >E 15, }] in addition to Defendant Nicola Six Limited. 16 38. Except as otherwise excused, Plaintiffs have performed all of the terms, 17 |) conditions and covenants to be performed on their part as director of the film London Fields. 18 39, The material consideration for the agreement between Plaintiffs and Defendant 19. || Nicola Six Limited for Cullen to serve as director of the film includes the fixed compensation 20 |} payable to Cullen as director of the film, the three cuts and three public screenings to which he 21 |)is entitied in editing the film, and the production of the film as a DGA film in accordance with 22. || the rules and requirements of the Guild, Also implicit in the agreement is the requirement that 23. || Defendant Nicola Six Limited provide funding needed in order properly to produce a first-class 24, || theatrical motion picture of the type envisioned for the film. =o 40. Defendant Nicola Six Limited has material breached the agreement with | 26 || Plaintiffs to direct the film, and there has been a material failure of consideration of such Ww 27 _ |] agreement, by reason of the following: the failure and refusal to pay the fixed compensation to ae wa 10 COMPLAINT Poot 2 Fayed ii ~ boo HD ~ L6a7SS794A - boo Tyee = onaage 12 of 28) 1 || which Cutten is entitled; the failure and refusal to provide to Cullen the three cuts and three 2. || public screenings to which he is entitled; the failure and refusal to produce the film as a DGA 3. J film in accordance with the rules and requirements of the Guild; and the failure to provide 4, || funding needed properly to produce the film, 3 41, Asadireet and proximate result of Defendant Nicola Six Limited’s material breach of the agreement as alleged herein, and as a direct and proximate result of such material failure of consideration, Plaintiffs are entitled to rescission of the agreement. Plaintiffs intend 6 7 8 || that service of this pleading constitute notice of rescission and offer to restore any consideration, 9 || received under the agreement in the event the Court finds any consideration net of the harm 0 ‘caused to Plaintiffs was bestowed upon them, provided that Plaintiffs receive restoration of the 1 |} consideration that they have furnished and otherwise the complete relief to which they are 2 aty 12 |fentted, including consequential damages. tos ‘THIRD CAUSE OF ACTION z u i 16 (Declaratory Relief - All Defendants) i 5 1s 42, Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through $° 1g |] 41 asifst out in fll herein, 7 43, An actual controversy has arisen and now exists between the Plaintiffs and 18 |] Defendants regarding their respective rights and obligations relating to film London Fields. 19 |] Among other things, the parties dispute the terms comprising the agreement for Cullen's 20 || services as director of the film. Plaintiffs are informed and believe, and upon such basis allege, 21. |) that Defendants contend that the terms of such agreement are as stated in a Certificate of 22 || Engagement, together with an attached Director Agreement, that Defendants’ counsel sent to . 23. || Plaintiffs’ counsel on October 8, 2013, together with a customary reservation of rights, “24. |] Plaintiffs dispute this contention. Among other things, Plaintiffs’ counsel requested changes to ~ wt 25. || those documents on behalf of Plaintiffs, which changes Defendants never made to the % 26 |} documents, and Plaintiffs never delivered an executed Certificate of Engagement and Director 27 || Agreement to Defendants for purposes of effecting any such agreement as between them. On or u ‘COMPLAINT Book 1 Paged 12 - Doe 1D ~ 1627867942 ~ Doo Type = om1 || about November 25, 2013, Plaintiffs did provide Defendants’ counsel with a signed copy of the Certificate, but that was done solely to accommodate a request of Defendants’ counsel for such ‘a document that Defendants could use internally for purposes other than as constituted an ‘agreement with Plaintiffs, and it was expressly agreed and made clear that the provision of such ° "ee document did not constitute execution and delivery of any agreement as between any of Plaintiffs and Defendants, but rather the following: conditioned upon, the conclusion of the negotiations of the material terms to Per our conversation today, this document is being signed and sent subject to, and Mat’s director agreement and the complete execution of that agreement. | 10 |} No such document was ever executed, nor did Defendants ever even provide a revised version 8 11 |} of the director agreement in accordance with the changes that had requested therefor on behalf a i . 12. || of Plaintiffs. 33 : 22 44, The parties also dispate the extent to which any of Defendants may use 2 EZ 14 |) Plaines’ name and likeness in connection with any promotion or advertising ofthe film. : i * 15 |] Among other things, Plaintiffs contend that Defendants have no right to use Plaintiffs’ rights of | 16 |} publicity for commercial advantage without Plaintiffs’ consent, including no right to use 17 |] Cullen’s name and likeness to promote or advertise any film containing creative elements added 18} by Defendants that are neither inthe script nor consistent with Cullen's expression of his vision 19 |] for the film or approved by him. Plaintiffs are informed and believe, and upon that basis allege, 20 |} that Defendants dispute this contention. 2 45. Plaintiff's desire a judicial determination of their rights and obligations relating to 22. || the film, including the terms comprising the agreement for Plaintiffs’ services as director of the (55 }] fim and the extent to which Defendants may use Plaintiffs’ name and likeness in connection 24 |} with any promotion or advertising of the film. 8 46. A judicial determination is necessary and appropriate in order to resolve the 26 |} parties’ respective rights and obligations relating to the film so as to avoid further litigation and W {27 |] potential interference withthe parties’ rights under the agreement for Plaintiffs” services as 6 2B 2 ‘COMPLAINT ‘beck 4 Faged 12 - Doo 1D = 2627957941 ~ Doe Type = THER(eage of 200 7. ee | 1 || eirecior ofthe film and in connection withthe use of Plaintiff’ name and likeness to promote | 2. |f and advertise the film. | 3 FOURTH CAUSE OF ACTION | 4 (Misappropriation of Name and Likeness ~ All Defendants) 5 47, Plaintiffs repeat and reallege the allegations contained in Paragraphs | through 6 |] 46 as ifset outin full herein | 7 48. Plaintiffs have not consented to the use of Cullen’s name, identify, likeness, and || personal information in connection with any promotion or advertising of any version ofa film 9, | sited, London Fields, which Defendants have prepared without consulting with Plaintiffs or 10 }| without their consent, and Defendants know that Plaintiffs have not consented to the use of 11 || Cutler's name identity, ikeness, and personel information in connection with any such | af 12 |) promotion or advertising of any such film. 2 i 28 49, Despite knowing that Plaintiffs have not consented to the use of Cullen's name, a ¢ £14 |) identity, likeness, and personal information in connection with eny promotion or advertising of z : : * 15 Il the version of the film that Defendants are exploiting, Defendant Nicola Six Limited is actively . : ~ 16 |] promoting and advertising such a version ofthe film by using Culien’s name, identify, likeness, 17. || and personal information as the purported director of such film. Further, despite knowing that 18. |) Plaintitts have not consented to the use of Cullen's name, identify, likeness, and personal 19. || information in connection with any promotion or advertising of the version of the film that 20 || Defendants are exploiting, Defendants Hanley, Muse Productions, Gertner, and Hero 21 | Entertainment, and each of them, have actively encouraged and substantially assisted Defendant 22. || Nicola Six Limited to use Cullen’s name, identify, likeness, and personal information in 23 |} connection with the promotion and advertising of such version of the film as the purported 24 |} director of such film. nS 50. In doing the acts alleged herein, Defendants are wrongfully using or aiding and ~ 26} abetting the use of Cullen’s name, identity, likeness, and personal information for commercial ) fy 27 fadvantage without his consent. oe va 13 ‘COMPLAINT Boot i Faget 14 ~ Doo 1D = 162788796 - boo Type = OTHERage 15 2 25) e e 1 51. Asa direct and proximate result of Defendants’ misappropriation of Cullen's 2 |] name and likeness as alleged herein, Plaintiffs have suffered and continues to suffer damages in 3. || excess of the jurisdictional limit, according to proof at trial. 4 52, In doing the acts alleged herein, Defendants, and each of them, have acted with oppression, fraud and malice in conscious disregard of Cullen's rights, and with intent to defraud Cullen and profit at his expense, all so as to entitle Cullen to exemplary and punitive 3 6 7. || damages in an amount to be determined at tral 8 FIFTH CAUSE OF ACTION 9 (Violation of Bus. & Prof. Code §§ 17200, et seq. All Defendants) 0 53, Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 11 |] 52s: set out in full herein. 12 54, Defendants’ conduct as alleged herein constitutes unfair competition in violation 13. |] of California Business and Professions Code §§ 17200, et seg. including unfair, unlawful | 14 |] and/or fraudulent business acts or practices Business and Professions Code § 17200. 15 55, Plaintiffs are each a person who has suffered injury in fact and has lost money or 16 |] property as a result of the unfair competition as alleged herein, VENABLE LLP 7 56. Asadirect and proximate result of Defendants’ unfair, unlawful and/or 18. |] fraudulent business practices as alleged herein, Plaintiffs are is entitled to injunctive relief 19. |] pursuant to Business and Professions Code § 17203, as well as restitution or other relief to the 20 |} extent permissible in accordance with the statute, ai PRAYER FOR RELIEF 2 WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of them, as 23 | follows: 4 1) For compensatory damages in an amount according to proof at trial; q 25 2) For punitive damages in an amount aczording to proof at trial; . 2% 3) Fora declaration stating the terms of any agreement between any of Plaintiffs = 27. || and Defendants for Plaintiffs’ services as director of the film, London Fields; rs 14 ‘COMPLAINT ‘Dooh 1 Pageh 15 - Goo 40 = 162755798) ~ Doo type = OMARage 16 of 23) c 4) Fora further declaration that Defendants have no right to use Plaintiffs’ rights of publicity for commercial advantage without Plaintiffs’ consent; 5) For costs of suit, including reasonable attomeys’ fees to the fullest extent sen allowed by law; and | 6) For auch other relief oz the Caurt decms just and proper. | Dated: September 15,2015 VENABLE LLP 10 u 12 13 4 Venapee LLP 15 16 i 7 18 19 20 21 2 D3 ae 25 26 m7 28 15 ‘COMPLAINT ‘book 1 Pagee 46 ~ boo ID = LeQ7SS794 ~ boo Fype = OMERGage 17 of 23) r - - —— | 1 DEMAND FOR JURY TRIAL 2 Plaintiffs Mathew Cullen and Motion Theory, Ine. hereby demand trial by jury. 4 |} Dated: September 15, 2015 10 u 12 3 4 1s Venamir LLP 16 | 1” 18 20 ai 2 2B 4 25 26 27 28 COMPLAINT ‘Dock 1 Pages U7 — hea HD = S427S5704i ~ Doo Type ~ CDR(age 18 2 25) 2 —_ ORIGINAL 5 cman FFirir wengocen Genco chon Capon con seu) Ceanale 2049 Century Park East, Suite 2100 Los Angeles, CA 90067 ‘wuovonevo: (310) 229-9900 razvo: (810) 228-9901 FILED scromevror meat Mathew Cullen and Motion Theory, Inc. Seganoy Cate Jeon court Be cauronacouor LOS ANGELES mht tno eam sraceranoess. 111 N, Hil Street sre une wooness: Same 15 2015 ‘orvmoarcene Los Angeles, CA 90012 ler snc nine. Central - Stanley Mosk “ 4 Mics erk, ‘CASE Name. MATHEW CULLEN, et al v. CHRISTOPHER 8, HANLEY, el al. wn IVIL CASE COVER SHEET Complex Case Designation | BSS 94 64 BD Uniimited CO Limited aaa em Cl counter) dointer | —" amended 's_| Fed wh fe appearance by defendant i exceeds $25,000) ___ $25,000 or iess)| (Cal. Rules of Coun, rule 3.402) err iHems 1-8 below musi be completed (see Instruchors on Page 2 1” Gheck one box below fore case type that best describes tis case: ‘AstoTor ‘contract, visionaly Complex Cl Ligation D> Asoc (FP arene ot convactnarany 06) (Sal Rule of Cou ues 400-3403) rise motor (8) (1 utes 740cotecions 09) Arts resaton (5) ‘Gee PUPDID (Persona! nryProperty ter clacton (0) 1D constactin sec (10) Benen ba Ton insurance coverage (18) asic Aabeson (8) reresnne SeeutesMgaten (28) Fy meray 29 rane _Enrorewnarecon 0) 1 tcc marecies 5) CE crinont daraininvere (Otnaurancecovrage ceasing tom he Tote pipoio @2) ‘Snoaraios 04) ‘dove ated provelonaly comple cava Nan puPOIW (Oenen Tor Wrngtt nection (9) cnvoseai Suaness lotdnia business pace (07) on) reament of Judgment Oooo, ra oO ean FT exon tenen 20 1 etemation 3 CD conmereat on Wiecaeeracu Cea angie O ravscs 1) Resenta 32 D1 con TD intatoctua! property (19) C1 rugs 38) (1 omer compisnt not speciog above) (42) Proteins neghence (28) “aii Rev Wigcaianeous Civ Pstton Other non-PUPDNVD tort (38) Asset freure (08) Partnership and corprate governance (21) Employment C) Pettion re arbivation award (11) LJ Other petition (not species above) (43) "wrongs mination 3 1 wnetmarcae cz) G)_onerempiymane (15) ter ji sion (95) | 2 Triscase [lis Bis coi complex under rule 8.400 of the Calfonia Rules of Cour, Wihe eave complex, mark the {acorsrequling exceptional judicial management 2. [Large rumber of sopaatey represenied partes. [] Large number of winesses ©, C1 Extensive motion practice raising diet or novel e. [] Gootsnaton wth related actons pending in ane or ore cours isaues that wi be ime-consuing to exOhVe Inoter eauntes, states, or counties, oF federal cout ce. C Svbctaniatamaunt of acumentary evidence [Substantial poefudgment ud superiion 3. Remedies sought (check al that apy)”. Elmonetary 0. BX] nonmonetary; cecartory orijuncive reiet —c. 2) puntive 44 Number of causes of action (spect) 5 5, Thisease C] is BQ isnot a classaction suit thee are any known related cases, fe and serve anole o related Dale. September 15, 2015 seffrey K Logan SE c EE TSAR FR TET NOTICE 'sPiairt must te his cover sheet with the frst paper fled inthe action or proceeding (except smal calms cases or cases fled “under the Probate Code, Family Code. or Welfare and Instuions Cade). (Ca. Rules of Cou. ule 3.220.) Fale to fe may result in sanctens. \sFile this cover sheet in addon to any cover sheet required by local court rule. Lunder ‘ule 3.400 et seg. ofthe Cafomia Rules of Cour. you must serve a copy ofthis cover sheet on all ‘he action or proceeding ‘Unies this is colactons case under rule 3.740 ora complex cate, this cover sheet wil be used for slate! purposes ony "Uieteectaoawee CIVIL CASE COVER SHEET Ge Riya AT, ‘Boch 2 Pageh 18 - Goo 1D = 1627557944 - boo type = omrage 19 of 28) @... ‘cmo10 INSTRUCTIONS ON HOW TO COMPLETE THE DOVER SHEET ‘To Plaintifs and Others Filing Firat Papers, f you are fing a fs paper (for example, @ complain) in a civil case, you must Complete and fle, lang wth your frst paper, te Ci! Case Cover Sheet contained on page i. Ths information wl be used to compile Sallstics about te types ana numbers of eases fled. You must complete Rems 1 through 6 on the sheet. In item *, you must check ‘he ox or the ease type that best deserbes the case Il the case its both a general and a mare specie type of case listed in tem 1. Sheek the more speci one. Ifthe oase has muliple causes of action, check the box that best indicates the primary cause of ation. Jo sssist you m completing the sheet, examples ofthe cases that belong under each case type in item 1 are provided below. A cover Sheet mus! be fied ony wth your ital paper. Felre to Sle a cover sheet with the fist paper fled in a civil case may subject & nary, {ts counsel, or both fo sanctions under ules 2.30 and 3.220 o the Calfomia Rules of Cour. ‘To Parties in Rule 3.740 Collections Cases, A “collecions case" under rule 3.740 is defined as an action for recovery of money ‘owed inva sum slaled tobe certain that enol more than $25,000, exclusive of infarest and attomey's fees, arising from a transaction wihich propery, senices, or money wes acquired on ered. A coliecons ease doss nct include an action seeking the folowing: (1 tor ‘damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal propery, or (6) @ prejudgment wit of ‘Skachment The Wentiieaton of a case as 8 rule 3.740 colectons case on tis form moans that i wil b= exempt from the general timedforservce requirements and case management rule, unless a defendant fles a responsive pleading, A rule 3.740 collections cease wil be subject to Mo requirements fr service and obtaining a judgment in rule 8.740. ‘To Parties in Complex Cases. In complex cases only, paries must also use the Civl Case Cover Sheot to designate whether the ave is complex. I plain believes the case i complex under rule 3400 of the Calfora Rules of Count, this must be indicated by empleting ne appropriate boxes in ems | and 2.2 plsintif designates a case as complex, the cover sheet must be served with the ‘Somplain-on all partes tothe action. A defendant may fla and serve no later than the time of is frst eppearance a jonder in the plantife designation. a counter-designaion thatthe case isnot complex, or. the pint has made no designation. a designation that the cage is complex. ‘CASE TYPES ANO EXAMPLES ‘Auto Tor contract Provislonaly Compiex Civ Ligation (Cal, ‘Ato (22}-Pesonel un#Propery Breach of ConeacuWarany (08) Rolve of oun Rules 3400-403) ‘Bamagelronta Beat ‘reach of RemaLaes0, “anaros ade Rogulaton (02) Unineures Wolo 1) (Fre ‘Canta! (ot ant dtaner Conatrtion Detect (10), ‘ate aes an uninsured ‘or wrongal even) Gian roving Mass Ton (40) ‘motel claim sutjea fo ConvaatWarrenty Brese™ Sele ‘Secures Ligaen (28) ‘otra, check sem er (rat Pau or rasgonce) “Enuronmereav Txt To (90) Instesd of Ato) Negigent reac: et convacd Insurance Coverage Clans ‘other PUBDIW (Pereonal Injury! “arty {arang fom prowsonaly complox Broperty Oumagernrongtul bean) Cotter Bresc™of Conracwvareny {aoe tye lated above 3) Tor ‘ooleciar (3. eney owed open Enforcement of Judgment ‘Asbesos (04) Book acount (8) ‘Enorcement of susgrert (20) olecion Crse-Seler Paint ‘Abaactof Judgment (Out of ‘Snr Promissory NtwCalecions ‘Cuny ‘case Confession of Judgment frm Insurance Sovsage (no proviinaty ‘domes reatons) ‘ample (18) Sitar State cutgment Medial Malpractse 05), ‘ato Subrogation emintrave agency Award ‘Medica! Mpacten ‘ier Coveraae (hot unpaid tees) ‘Physioans & Surgeons other Conant 3) etfon/Garteation of Entry of ott Protessinat Heath Ci Contract! Praud “wagment on Unpaid Tasos Mapractce Omer Conrac Dispute ‘omar Enoreement of Jusgment ‘one PUPDAND (23) Real Property Cese Premees Labity (9. iP Eminent Domanvinverse iscatlaneous Civil Complaint tnd) ‘Condemnation (1) Ricozn i Intentional Bos inuryPOWO Wiongtl Even (33) ther Comssaet (no apeciod (es. aseaul vandalism) ‘ner Real Prope (e.g. que ie) (26) “sbove) (2), Intent aienon of ‘Wit of Possession of Real Property ‘Gectertor Reset Oniy Emotions Oisvass Mongene Foreconure Inonetve ett Ont oon- Negigont inet of oct Te harassment) Eralena.Otass ‘ier Real Propet (nat eminent eshanies Lon ner PuPDMD Soman, anderctenant or (Ofer Commarea Corian. Noo:PUPOMND (Other) Tort fowcosure) “Case (na iavnon-comaler) ‘Business TriUniar Business nial Botainer ‘otnar Givi Complaint Pracice (07> ‘Comrerein 6) Iondorinen Cc Rigs (69 crimination, Renae (2) Imiscelianeats Givi Petition fale ares fat ci rugs 38) (the case involves eg! ‘Pannership and Coporle herasement (08). ‘rugs, checks om; erie ‘Governance (21, “Detamaton (eg, slander, sb) ‘apo 8s Commereal or Restor) (nes Petiton (70! ssciied 03 tude! Review ‘above) 3) ‘rau (36) “Acel Foote (05) Git Harastment “eioleciual Property (18) Pelton Re: Ab¥aten Aware (11) Werke Vence 1 Botessional Negigerce (25) ‘Wits Mandate (02) tcorDepencert Adit ‘Legal Malpractice Vineaemesratve Mancemus “Abuse 7 Otter Protesstonel Malpacte ‘ircAtandams on Ute Court tecton Contest "rot mectea ela ‘Gase Maer elon for same Change: “Other New PUPOMD Te (5) ther Led Cout Case Petton for Rett From Ute empipyment Revew ‘aim tongs Terinabon (36) ther ‘tne Just Review (3) ‘omer Cr Peiion Enbiyment (15) Review at real Ofer Order Netce of ApceaLabor bs Commenine:Azpeale ‘orga 2007 CIVIL CASE COVER SHEET rte ‘Doct 1 Paget 17 - oo £0 = 4627857841 - Doe Type = OERage 20. of 23) : ®@ | ‘ORT DseRNOCR 1 TINTVIElv CULLEN, etal. CHRISTOPHER S, HANLEY, et 649 | CIVIL CASE COVER SHEET ADDENDUM AND ‘STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) “This form is required pursuant to Local Rule 2.3 In all new civil case filings in the Los Angeles Superior Court, Item 1. Check the types of hearing and fil in the estimated length of hearing expected for this case. auny TRU? (BYES classaction? CI yes uMireD case? Cl ves TIME ESTIMATED FOR TRIAL _10_[]Hounsy/ Bd oAvs tem tl Indicate the correct district and courthouse location (4 steps ~If you checked "Limited Case”, skip to Item Il, Pa. 4) ORIGINAL Step 4: After first completing the Cull Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected. Step 2: Check one Superior Court type of action in Column B below which best deseribes the nature of this case. ‘Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have ‘checked. For any exception to the court location, see Local Rule 2:3 ‘Applicable Reasons for Choo: 1g Courthouse Location (see Column C below) 1.iass actors must be fedja the Stanley Nosk Couthouse, cantalaerct, 6, Location of propery 9 pemnanentygoraped vehicle 4} Gassadens enti tie coments nay murrosey sarape) Loca we pains aes, 3 Leaton where cause o eton arose & UBcaton neretdetandnutesgorcen funions why. 2 Lats wnere Seah iu, death or dapape occur, 5 {Seaton whee one sr mare of ha gas vesice | 5 LSSeton were perfomance veques or delendai res, {0 Loeaton a tabor Conmisioner Ofte | ‘1. Aanatay Fig Locabon (ul Case) | ‘Step 4: Fil inthe information requested on page 4 in tem Ill complete Item IV. Sign the declaration A B ‘hn case Cover Sheet, Type ot eton ateo0 Ro. (Chess cyan} "A (2) rico wow Vence Penna! imunirereny OmegewirengttDeat —| 1.2.4 5 33 | aewweenaearea) | LIArH# Penchpeymopty aragengSeh-uneaar| 12.4 | agen ny | CLASTD Attest Prepon Damsge 2 | ze | Clarzzs Asbestos - Personal injure vat Death 2 ge | § |_Pecoman TTDA7260 Petit Labiy rl abeno or txrenvonena rer | ES | eamapaces un | NR? Wosealtsencin- Praca Somes ha | # ee i | Be | as (Claras0 Praises ity (esp ane) tod ay rerzent [are telat mune Omeewintioebies, |, | 8 Dlarare nestor tino Emsonl Darest 13 © C4720 onerPaeeal uy/openy Damagefongt Oath tA iggy ne CIVIL CASE COVER SHEET ADDENDUM | IC Apres 8 AND STATEMENT OF LOCATION ! ‘och 3 Bagel 20 - boo ID = 1627857942 ~ Doo Type = OTHERage 22 MATHEW CULLEN, etal v. CHRISTOPHER S, HANLEY, et at 1 eo: A B Ch Case Cove Sheet Type ot hatin Category No. (choexay one) sunbess Ton 07) | C]Aso29 ner Conneriavowines Ten (ot raudtreachfcontac | 1.3, fs coarigns08) | C).ascos ivi Rehtsiscininaion 128 z &§ Detanaton(i3) | EJASO1O Defamation tonne) a es = Fraud (16) aso: Fraud (no contract) 1.2.8 ze 32 17 Lege abracice 1.28. E& | erctssona neaigence a5) | LAS tea id Clcose cme Profesional Macc (not mesa eos 1a 4 nner 53 (Cha8025 other Nen-Personal nueyPropeny Damage tart 23. § | wrengtui Termination 96) | [].a60a7 wrongut Termination 1.2.3 é ee waa & per ast02 Labor Commissioner Appeats 10. Tlasoor areas ot Remaiieese Conrad mt unewisceener omens | > oncen) reach Conuacy Wary 1m seo0g, ConvactWarany Breath Sater Pato taushegsgsocs) | 2-5 (raresvrnce) | Tagore Neaigem Bese ot Conracararty(o taut) i asoze_ na rach ContaciWarany (nt tas eafoece) 1.208 I Dacoca cotectons Cas-Saler Plant 2.5.61 g Cotecion (05) | LJA6012 omer Promisor NotrCoecns Cte 2st CT aonse cotecons case urerases Dot (Charges Of Cansun sat Pustesed ono ater Jensey L201) Insurance Coverage (18) | [J A8015 insurance Coverage (not complex) 14 2 $8, Basooe conacua Fon Ons tre conrae 7 — | Chagos Tonos nerternee 12.3.8 Clasnar one: conse Oseuetret vercvineuancatevanesionce) | 1.23 Eminent Dorarvinvene vnen.Demaivives® | C]aysoa eminent DamaivCondennaton Number of pels 2 g Wrongful Eveton (39) | [].A6023. Wirongh Eviction Case 2.8 § lasers Mortgage Foredosue 2.6. O% | omenrmeanvian | ieeme aren ze © D)A8050_ other Real Property (nat eminent domain. lndiordtenant. foreclosure) | 2.8. amu Deane Care| TT go2t Un Detae-Conmercil (el duper wengttevetin) | 2.8 Une Onanerenceta | 7 ganz0 ona Deane Reset gs rwongeicin) | 2.8 Tate Ba : Poseteedeeine a) __ | CDA8020F Unit Cetin PoseForeccsue 2.8 ee ees ze LAGI 108 (Rev. 09715) CIVIL CASE COVER SHEET ADDENDUM. Local Rule 2.3 scence AND STATEMENT OF LOCATION Page 2 of & fc sas @) ‘Doo 1 Paged 24 ~ Doo 1D = 2627557843 - Doo Type = omMERage 2 of 23) eo MATHEW CULLEN, et al v. CHRISTOPHER S. HANLEY, et al | A 8 c (Oui Case Gover Snest ‘ype of Acton Applicable (Sategory No, (hack ty oe) Reasons Seo Siep3 ADI ‘Asset Fereiture (05) | CJA6108 Asset Foceure Case 2.6 Paitionrearivaton (11) | C]A6118 Pettion to CompelCantmVacateAsitation 2.5 Dlreiss wit Adminstrative Mandamus 2 ‘wit etmandsio 02; | C)asts2 wit-Mandamus on imtod Court Case Nats 2 Clasiss wether Linted Cour Case Review 2 iner Jusciat Rewew (38) | []AS1S0 Other WriJudicial Review 2.8. | Artirusi Trade Regutation (03) | [].A6003_AntirusvTrade Reguiation 28 | & ‘Construction Detnct (10) | (].A8007 Construction Detect U.23, | Peremaige visor | Caine caine aig tne Tot tae e S| seotestnemion cn | Chases seca tion cae 128 : Env eT any | C1a8038 Tose Torenvinmentat 44.2,8.8 ere ane } (Clasiat Sister State Juagment 2.9. | ogg saan | : (aster Contsoe utrentenconstelion) za £6 crpcamet 53 ‘of Judgment (20) Cl Asr40 Aaministratve Agency Award (not unpaid taxes) 2.8, ns Dror Pettoncentea er En of gon Uae Tax 2a Chasrs2 omer enforcement of sudgmert Case 20,8 Reon 128 32 aa (Chrs030 cecteratory Retiet Ony 128 BE | cserconpane | LIAS ince Rela ny toatonarssne 26 BS | oe SeieeMow ca) | Spear over cere Contat as feat cr asp 6 rotenone: ci Conant ronteinencameln nae Peipemmecoraaten | C)aeria Paine and CopeleCovenarce ise 2 Q Dasa) cx harssnen 2.3.8 38 Dhast2s woroiace Harassment 2.38 a3 ther Pattions Dlaize cisewbeperitent Aout Abuse Case 2.3.8 Zs | sotsmeaecstnn | asin coven ones 2 =o = (Gasi10 Peition tor change ot Name 27. h (C1A6170_ Petition for Rel rom Late Clam Law 2.3.4.8. (Das100 omer ci Peition na a 05 fen OST CIVIL CASE COVER SHEET ADDENDUM Cocal Rule 2:3 Aer O24 AND STATEMENT OF LOCATION fee ‘Doct & waged 22 ~ Doo ID = Lezvae7=4s ~ oa sype = ona(age 22 of 2) MATHEW CULLEN, et al v. CHRISTOPHER S. HANLEY, et al tem lil, Statement of Location: Enter the address of the accident, partys residence or place of business, performance, or other cirgumstance indicated in tem I, Step 3 on Page 1, 2s the proper reason for fling in the court location you selected. REASON: Check the appropriate axes forthe numbers shown | 4235 Reawood Avenue {Under Column ¢ forthe type faction that you have selected for ——— | Oe. Os. Os. Os. Or. Oe. Os. Oo. : los Angeles ca” | S088 ters tv. Deciaration of Assignment: | declare under penalty of perury under tne laws ofthe State of Califomia thatthe foregoing is true ‘anc correct and thal the above-entiled materi property fied for assignment tothe Stanley Mosk courthouse inthe Cental District of the Superior Court of California, County of Los Angeles [Code Civ. Proc. § 992 et seq. and Local Rule 23, subd). Dated September 15,2015 _ PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY ‘COMMENCE YOUR NEW COURT CASE: 1. Original Compiaint or Petition It fling a Complaint, a completed Summons form for i Civil Case Cover Sheet, Judicial Counct form CM-010. ‘Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev. 03/18), Payment in full ofthe fling fee, unless fees have been walved. 3. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, ifthe plaintiff or petitioner is a minor under 18 years of age wil be required by Court in order to issue a summons. ance by the Clerk. heh 7. Additional copies of documents to be conformed by the Clerk. Copies ofthe cover sheet and this addendum ‘must be served along with the summons and complaint. or other inating pleading n the case . tusthooneneae CIVIL CASE COVER SHEET ADDENDUM Tegal Rule 23 ieioethaas) AND STATEMENT OF LOCATION ee ota j Toot 2 waged £2 - Doo a= AARTASTEA - os Type = On