Professional Documents
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Facsimile: 310.566.9850
Telephone: 310.566.9800
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FILED
Superior Court of California
County of Los Angeles
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FEB 04 2016
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COMPLAINT FOR:
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INTRODUCTION
1.
This case arises out of failure of one producing partner (Bradley Krevoy) to honor
his contractual obligations to another producing partner (Stephanie Germain) in connection with
the development and production oftelevision motion pictures based on the Hannah Swensen
Mystery book series. Three Hannah Swensen films, known as Murder, She Baked titles, have
already aired on the Hallmark Movie and Mystery channel. Krevoy has repeatedly breached his
contractual obligation to reach agreement with Germain on all creative and business decisions, and
Krevoy has frequently functioned as ifhe has no producing partner at all. Krevoy has kept
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Germain in the dark on many issues and has failed to provide complete accountings to Germain.
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Because Krevoy's breaches are on-going and the production ofadditional films is also on-going,
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Germain seeks to enforce her contractual rights regarding the films already made, to obtain a
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complete accounting ofmonies in connection with all films and to obtain declaratory relief as to
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THE PARTIES
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Productions") is a California corporation with its principal place of business located in Los
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Angeles County, California. Stephanie Germain is the owner ofGermain Productions. She has
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extensive experience in the television industry as a producer, executive producer and co-owner for
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20 years. Germain's productions include over 25 movies for television or mini-series, and an
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Emmy Award nomination. In addition, she co-produced the Showtime television series Jeremiah
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and was an executive producer on the Roland Emmerich motion picture The Day After Tomorrow.
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Plaintiff will refer to Germain Productions and Stephanie Germain collectively as "Germain"
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3.
Plaintiffs are informed and believe that Defendant BK Productions LLC ("BK
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Productions") isa suspended California limited liability company with its principal place of
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11073.00002/334700.6
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COMPLAINT
Distribution") is a California limited liability company with its principal place ofbusiness located
owns and operates BK Productions LLC and BK Distribution LLC and serves as an agent for the
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a suspended corporation and cannot legally defend itself. Moreover, Germain is informed and
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believes that BK Productions and BRK Distribution are the alter ego of Bradley Krevoy such that
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the Court should not recognize any legal distinction between them in that (i) BK Productions and
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BRK Distribution are not adequately capitalized, (ii) BK Productions and BRK Distribution are
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merely a conduit, shell and instrumentality through which Bradley Krevoy conducts business, (iii)
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there is a unity of interests and ownership among Bradley Krevoy, BK Productions and BRK
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Distribution, and Bradley Krevoy exercises complete dominance and control over BK Productions
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and BRK Distribution such that any separateness or individuality has ceased to exist, and (iv) BK
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Productions and BRK Distribution have not followed basic corporate formalities. Adherence to
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the fiction of the separate existence of BK Productions and BRK Distribution as entities separate
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and distinct from Bradley Krevoy would permit anabuse of the corporate privilege and would
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sanction fraud and promote an injustice. Accordingly, the obligations of BK Productions and
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Plaintiffs are informed and believe that Defendant Bradley Krevoy is a resident of
Los Angeles County and that he regularly conducts business within Los Angeles County. Krevoy
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Plaintiffs are informed and believe that DefendantBRK Distribution LLC ("BK
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7.
This Court has personal jurisdiction over BK Productions, BRK Distribution and
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Bradley Krevoy because (i) Bradley Krevoy isa resident ofCalifornia, and he and BK Productions
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and BRK Distribution conduct business within California; and (ii) the term sheet agreement dated
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May 14, 2014 provides for the exclusive jurisdiction and venue to be the Los Angeles Superior
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2
COMPLAfNT
8.
Venue is proper in Los Angeles County in accordance with Section 395(a) ofthe
California Code of Civil Procedure because Bradley Krevoy resides in this county, BRK
Distribution does business in this county, and the term sheet agreement provides for Los Angeles
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9.
Germain first met Krevoy in the Fall of 2014. After discussing various projects,
Germain suggested they work together on a pilot for a television series based on the published
Hannah Swensen Mystery book series written by best-selling author Joanne Fluke. They
ultimately decided to produce a series of"Movies ofthe Week" ("MOW's") based on this book
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series for broadcast on the Hallmark Murder and Mystery channel. There are approximately 20
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published books in the series. Crown Media United States LLC ("Crown Media") owns the
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Hallmark Murder and Mystery channel which broadcasts original content series and motion
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Germain and Krevoy entered into a written Term Sheet dated May 14, 2014 (the
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"Agreement"). Pursuant to the Agreement, the parties would develop and produce up to three
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MOW's based on the Hannah Swensen Mystery book series to be broadcast by the Hallmark
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network (the "Project"). Agreement, Recital \ B. Germain and Krevoy were to form a new entity
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and each would own a 50% interest in that entity (the"Company"), and the Company would
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acquire the rights to three books and hold the copyright to the MOW's. Agreement, U2.
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Under the Agreement, "[the parties] agreed to consult with each other with respect
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to all proposed material creative and business decisions concerning the Project and the Company,
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provided final decision making authority on all such matters will be determined by
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unanimity..." Id.,\ 3.
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12.
Under the Agreement, the parties were to "share equally all fees, profits and any
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other revenues derived by and actually received by [the new entity]...." Id., 14. The budget for
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each MOW would include producer fees of $125,000 to Germain and Krevoy each.
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11073.00002/334700.6
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COMPLAfNT
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Krevoy was to be responsible for all costs associated with procuring the rights,
financing the development and production ofthe Project and forming and operating the Company.
Agreement, \ 5. As for overhead, the parties agreed "neither ofthem shall be entitled to charge
percentage overhead or other flat overhead to the cost ofproduction orotherwise as recoupable
expense, but mutually approved actual overhead costs shall be allowable." Agreement, \ 5.
Krevoy could recoup allowable overhead costs out ofthe approved budget and profits from the
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14.
The Agreement provided: "[Germain] shall have final approval over the terms of
any producing services Stephanie Germain provides in connection with the Project, including
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Under the Agreement, each party was to receive production company credits and
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logo credits and Germain and Krevoy would receive separate card executive producer credits.
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comply with Paragraph 7 as follows: "The terms ofthis Agreement apply solely to the first three
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MOW's comprising the Project, and if there are anyfurther productions proposed or
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contemplated based on the Books, the parties will negotiate in good faith as to applicable
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terms, and if they do not reach agreement, then neither party shall be entitled to proceed
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limited liability company called Swensen Productions LLC ("Swensen"). Krevoy sent a proposed
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written operating agreement. Germain's counsel provided comments to the agreement, but the
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parties never reached agreement onall material terms and no operating agreement was ever
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signed. Krevoy caused Swensen to be formed as a Louisiana limited liability corporation with
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as ofApril 2, 2014 whereby Swensen agreed to develop three teleplays based on the Hannah
11073.00002/334700.6
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COMPLAINT
Swensen Mystery book series ("Crown Media Development Agreement"). Under the Crown
Media Development Agreement, Crown Media had three separate options to license up to three
additional films per option exercisable by written notice to Swensen. Accordingly, Crown Media
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Germain and Krevoy, acquired the rights to make the Hannah Swensen MOWs and Swensen
licensed these rights to Crown Media. Accordingly, Germain and Krevoy, through Swensen, were
to co-own the rights to the films being broadcast by the Hallmark Murder and Mystery channel.
19.
20.
The first film was Murder She Baked: A Chocolate Chip Cookie Mystery
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("Chocolate Chip"), which was based on the first Hannah Swensen book. Crown Media entered
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into a Production and License Agreement with Swensen and Krevoy's distribution company BRK
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Distribution LLC dated as of February 2, 2014 for the Chocolate Chip film ("Production and
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License Agreement").
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Under the Production and License Agreement, Crown Media was to pay a license
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fee to Swensen in installments over the course of production and final delivery. Swensen was to
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pay all costs and expenses in connection with the production and delivery of the film. Crown
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Media had the right to approve many aspects of production and post-production. The film had to
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be delivered to Crown Media at least 90 days prior to the anticipated first public exhibition.
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Plaintiffs are informed and believe that Crown Media entered into similar
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production license agreements for each subsequent Hannah Swensen MOW. Germain did not
receive copies ofthe production license agreements for the first two motion pictures until long
after they were signed, and as such, Krevoy prevented Germain from reviewing and commenting
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on the agreements before they were signed. Although Germain did see drafts ofthe licensing
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agreement for the third production, Krevoy rejected her comments, and never provided afinal
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version to her.
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23.
Notwithstanding the fact that Crown Media licensed the rights to make motion
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pictures based on specific Hannah Swensen titles, Krevoy attempted to interchange titles and
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5
COMPLAINT
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24.
Crown Media received the right to exploit the film domestically in all media. BRK
Distribution entered into separate distribution agreements with Sony Pictures Television Inc. to
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25.
Krevoy largely excluded Germain from the budgetary process for making
Chocolate Chip, and submitted the budget to the Hallmark network before Germain even saw the
budget. As aresult, Germain could not pursue savings in the budget as she has customarily done
26.
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shall be entitled to charge percentage overhead or other flat overhead to the cost ofproduction or
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otherwise as recoupable expense, but mutually approved actual overhead costs shall be allowable."
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for BK Productions on the Chocolate Chip budget, which had a roughly $2.5 million budget. This
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overhead figure was inflated, and Germain refused to approve this overhead allowance. Krevoy
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subsequently offered to reduce the overhead figure on Chocolate Chip to $50,000, which Germain
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again did not approve. For the next film, Krevoy proposed an $80,000 overhead allowance for BK
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Productions and again offered to reduce the number to $50,000. Germain again did not approve
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the $50,000 allowance for the second film. Germain incurred overhead in connection with her
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The first MOW Chocolate Chip was shot in February and March 2015. Krevoy
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failed to render producer services on the set ofChocolate Chip. When Krevoy did appear on set,
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his presence was disruptive. Krevoy attempted unilaterally to cut scenes, ridiculed and advised
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against acceptance ofnetwork notes, and attempted to put his friends' kids in the film as walk-ons.
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Germain rendered additional services as a creative producer, even though she never agreed in
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advance to serve in this role and was not being paid to do so.
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Chocolate Chip first aired on May 2, 2015. At the time, it had the highest ratings
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11073.00002/334700.6
COMPLAINT
additional role ofcreative producer for much of the Plum Pudding production without additional
compensation.
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Krevoy once again failed to render his producer services on the set of Plum
Pudding and was only on the set for approximately 24 hours. Germain once again fulfilled the
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The second MOW was based on the book, APlum Pudding Murder Mystery
("Plum Pudding"). Krevoy continued to cause similar types of problems on the development and
production of Plum Pudding. Krevoy was generally dismissive of the author's material. Krevoy
again attempted to disregard the network notes on the script on set. He insulted cast and crew, and
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Plum Pudding was shot in May 2015. It first aired on November 21, 2015 and had
excellent ratings.
32.
For Plum Pudding, Krevoy was responsible for paying the book author Joanne
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Fluke no later than the commencement ofprincipal photography. In violation ofMs. Fluke's
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contract, she was not paid until after the filming was completed and thus without timely exercise
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of the option to exploit the Plum Pudding book and without proper acquisition of the rights.
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Krevoy was responsible for securing "Errors and Omissions" insurance coverage
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for each MOW production. Germain recently learned that Krevoy had failed to secure errors and
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omissions insurance coverage until halfway through the production for Chocolate Chip. For Plum
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Pudding, Krevoy did not secure insurance coverage until after the filming was already completed.
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34.
The third motion picture was Murder, She Baked: APeach Cobbler Murder
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Mystery ("Peach Cobbler"). Krevoy hired anew writer, Teena Booth, to draft the Peach Cobbler
teleplay without obtaining Germain's approval. Krevoy also hired anew casting director for
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Peach Cobbler without obtaining Germain's approval. Krevoy submitted a treatment (asummary
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of the script to be written) to Hallmark for Peach Cobbler without obtaining Germain's approval.
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In each instance, Krevoy violated Paragraph 3ofthe Agreement that all business and creative
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11073.00002/334700.6
COMPLAINT
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Acreative producer was hired for this production, and there were fewer problems on the set
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Hallmark and Germain had approved the credits for Peach Cobbler. After they did
so, Krevoy unilaterally changed the screen credits for Peach Cobbler without the knowledge or
approval ofHallmark and Germain, and provided a"co-executive producer" credit for an
employee of Krevoy (Amanda Phillips Atkins), a"business consultant" credit for another Krevoy
employee (Eric Jarboe), and aproducing credit for someone whom Germain never met and who
never fulfilled any producing functions (Sean O'Reilly). Germain asked that these credits be
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removed, and Krevoy has refused to do so. Peach Cobbler aired in the United States with these
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unauthorized credits.
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Peach Cobbler was shot in Vancouver, British Columbia during November 2015.
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During 2015, Germain and her counsel made repeated requests to Krevoy that he
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honor his contractual obligation to provide Germain with pertinent contracts and other documents
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to enable Germain to fulfill her role.as co-owner and producer of the Project. Nonetheless,
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Krevoy refused to do so. Krevoy did not provide certain documents to Germain until after
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Chocolate Chip had already aired and after Plum Pudding was filmed. To date, Krevoy has failed
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to provide complete accountings of revenues and expenses for each ofthe MOW's to his co-owner
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Krevoy's failure to comply with third party contract obligations and other conduct
39.
The Agreement provided that "ifthere are any further productions [beyond the
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three MOW] proposed or contemplated based on the Books," Krevoy and Germain had to
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negotiate new terms in good faith for future productions, and "ifthey do not reach agreement, then
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neither party shall be entitled to proceed with further production(s) based on the Books."
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Agreement, ^| 7.
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COMPLAINT
Germain attempted to negotiate in good'faith with Krevoy the terms for a new
agreement covering the fourth Hannah Swensen MOW and beyond. Germain made multiple
proposals to Krevoy. Some ofher proposed terms were designed to improve the MOW's, such as
including the continuing obligation to hire athird party creative producer. Some were designed to
increase Krevoy's transparency. Some were to ensure that Germain would be involved in
decision-making on business issues. Krevoy ignored or rejected all orvirtually all ofthese terms
and Germain believes that Krevoy did so in order to eliminate his accountability and avoid his
obligations as a producer.
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motion picture during the Summer and Fall of2015 without reaching an agreement with Germain
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for these MOW's. Notwithstanding Germain's insistence that Krevoy comply with Paragraph 7
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and reach a new agreement with her, Krevoy proceeded with development for a fourth MOW. For
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example, by email dated November 10, 2015, Krevoy wrote to the lead actor about scheduling
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issues "[a]s we plan for the next four movies next year ..."
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Germain's latest proposal to Krevoy regarding new terms - - made after several
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others were ignored - - was made by email dated January 6, 2016 from her counsel. Germain's
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counsel even offered to meet with Krevoy or his representative to discuss the proposal at their
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convenience, and requested a response by January 15, 2016. Krevoy never responded to the
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43.
Germain intends to produce future MOW's in the series, and has cooperated in the
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development ofthe fourth MOW even without an agreement between her and Krevoy on the
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fourth MOW and beyond. In doing so, however, Germain has not waived her rights to seek
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by reference.
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11073.00002/334700.6
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COMPLAINT
46.
Krevoy failed to consult with and obtain Germain's approval on many business
and creative decisions in violation of Paragraph 3 of the Agreement.
Krevoy failed to provide to Germain, who was a 50/50 co-owner of the Project,
Krevoy included an improper overhead allowance for Chocolate Chip and Plum
Agreement.
Krevoy unilaterally imposed screen credits that Germain disapproved (and that
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Krevoy failed to have the book rights timely paid, for in violation of Paragraph
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the Agreement.
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Germain believes that Krevoy has not paid and will not pay amounts owed to
47.
Germain is informed and believes that Krevoy has committed other breaches of the
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Agreement that Germain is currently unaware of and that Krevoy will continue to breach the
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48.
Germain has performed all or substantially all of her obligations required under the
Agreement except for those obligations that Germain was excused from performing.
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COMPLAINT
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Under the Agreement, Krevoy and Germain are 50-50 owners ofSwensen and are
to amounts owed to her under the Agreement. Moreover, an accounting is appropriate based on
the nature.of the relationship between Krevoy and Germain as co-owners ofthe Project.
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52.
The balance due from Krevoy to Germain cannot be readily ascertained without an
accounting.
53.
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Productions, Bradley Krevoy, BRK Distribution, Swensen and all other entities owned or
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controlled by Bradley Krevoy (collectively, "Krevoy Entities") and all expenses paid or owed by
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the Krevoy Entities for each Hannah Swensen MOW. Germain also seeks an order requiring BK
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Productions, BRK Distribution and Bradley Krevoy to pay all monies due to Germain, either
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to split profits equally (among other terms). Accordingly, Germain is entitled to an accounting as
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by reference.
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Crown Media, an actual and judiciable controversy has arisen and now exists between Germain
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and Krevoy over 1) whether Krevoy must comply with the contract term requiring them to reach
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agreement on all material creative and business decisions pertaining to each existing and future
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MOW, and 2) whether Germain is entitled to a complete accounting from the Krevoy Entities for
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56.
Germain seeks ajudicial declaration that (i) Krevoy must reach agreement with
Germain regarding all material creative and business decisions pertaining to all existing and future
11073.00002/334700.6
II
COMPLAINT
Hannah Swensen MOW's; (ii) Germain must receive advance notice from Krevoy of all potential
contracts involving the Project and the Company and have a reasonable opportunity to provide her
input into the decision-making and negotiation process for all such contracts; (iii) Krevoy must
notify all third parties in advance that Germain must approve all creative and business decisions
for all contracts involving the Project and the Company; and (iv) Krevoy must provide Germain
with a complete and timely accounting from the Krevoy Entities for all existing and future
MOW's and pay all monies owed to Germain, either directly through the Agreement or as a
member of Swensen. Germain's position is that Krevoy has breached the contract terms requiring
Germain's agreement on all business and creative decisions and requiring Krevoy to provide
10
complete accountings and that Krevoy will continue to breach these contract terms in the future.
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Germain believes that Krevoy's position is that he either does not need to comply with these
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contract terms given that three MOW's have been made or that he has complied with these terms
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the parties may ascertain their rights and duties and so as to avoid the need for multiple lawsuits
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regarding whether these contract terms apply and whether Krevoy has breached them.
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1.
proof at trial;
2.
For the Second Cause of Action, a complete accounting of all revenue received or
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owed and expenses paid or owed in connection with each of the Hannah Swensen MOW's and an
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order requiring payment of all monies due to Germain, either directly through the Agreement or as
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a member of Swensen;
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3.
For the Third Cause of Action, a judicial declaration that (i) Krevoy must reach
26
agreement with Germain regarding all material creative and business decisions pertaining to all
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existing and future Hannah Swensen MOW's; (ii) Germain must receive advance notice from
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Krevoy of all potential contracts involving the Project and the Company and have a reasonable
11073.00002/334700.6
]2
COMPLAINT
opportunity to provide her input into the decision-making and negotiation process for all such
contracts; (iii) Krevoy must notify all third parties in advance that Germain must approve all
creative and business decisions for all contracts involving the Project and the Company; and (iv)
Krevoy must provide Germain with a complete and timely accounting from the Krevoy Entities
for all existing and future MOW's and pay all monies owed to Germain, either directly through the
4.
5.
For such other and further relief as this Court deemsjust and proper.
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Gregory J. Aldisert
Attorneys for Plaintiff SGP ENTERTAINMENT
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11073.00002/334700.6
_13_
COMPLAINT
CM-PIP,
3rd Fl.
FILED
566-9850
She
CA 90012
FEB 04 2016
rriK.C^^.MixecuUve Officer/Clerk
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case name:
.Deputy
Judi Lavs*
1 x i Unlimited
(Amount
ILimited
(Amount
I Counter
CASE NUMBER:
I Joinder
BC * 0 9 ft 2 6
JUDGE:
Filed with first appearance by defendant
(Cal. Rules of Court, rule 3.402)
DEPT
Items 1-6 below must be completed (see instrvctions on page 2).
1. Check one box below for the case type that best describes this case:
demanded
demanded is
Auto Tort
Contract
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IAuto (22)
IUninsured motorist (46)
IAsbestos (04)
IX
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Real Property
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1
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condemnation (14)
types (41)
I IBusiness tort/unfair business practice (07) lZ3 other real property (26)
Enforcement of Judgment
Unlawful Detainer
IDefamation (13)
ICommercial (31)
IFraud (16)
IResidential (32)
I RICO (27)
I
I
IDrugs (38)
Judicial Review
I
I
I
I
I
Employment
2. This case
IZZD is
EjTjisnot complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
a. I
b. I
3. Remedies sought (check all that apply): a. I x I monetary b. I x Inonmonetary; declaratory or injunctive relief c. I
I punitive
61 .ff there are any known related cases, file and serve a notice of related case. (
Date: February 4,
2016
.4:-
NOTICE
Plaintiff mustfile this cover sheet with the first paper filed in the action or proceeding (exceptsmallclaimscases or cases filed
under the Probate Code, Family Code, orWelfare and Institutions Code). (Cal. Rules ofCourt, rule 3.220.) Failure tofile may result
i. in sanctions.
File this cover sheet in addition to any cover sheet required by local court rule.
i.:lf this case iscomplex under rule 3.400 et seq. oftheCalifornia Rules of Court, you must serve a copy ofthis cover sheet on all
i_,:pther parties to the action or proceeding.
Unless this isa collections case under rule 3.740 or a complex case, this cover sheetwill be used for statistical purposes only.
-'"
Form Adopted lor Mandatory Use
Judicial Council of California
Page 1 of 2
ilUUQ]tj-,cSoiuC
US
CM-010
^mnHJS f,nd thersiilin3 fFirs* Papers. If you are filing a first paper (for example, a complaint) in a civil case vou must
complete and file along with your first paper, the Civil Case Cover Sheet contained on page 1 This information w5 be used to comS
oSK iKSSiJK;TiTlT
IT filed- YU mUSt Cmple,e i,emS 1,hrOU9h 6on ,he sheet- " 1you muS CS
/Pe <ha ,b6St deSCnbeS the case- lf ,he case fi,s b0,h aSeneral and amore specific type of case listed in tern 1
rZllZi
To cf
6spec,"c,one' 'f the case has 'P'e causes of action, check the box that best indicates the primary cause of actTon'
ILT
\k
nTP
nguthC
of ,hetocases
that belon9
below oaSH
Acover
sheet must be filed
onlyet'with
yourSheet'
initialeXamples
paper. Failure
file acover
sheet und^
with theeach
firstcase
papertype
filedininitem
acivil1are
casep2d
maysubkSa
counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court
V J
P V'
,Tna?ume,SJllH i!!6h!'74S Co'!ec(tions ,Cases" UA "collections case" under rule 3.740 is defined as an action for recovery of money owed
h? if
ertam th3t 'S n0t mre than $25'000' exclusive of interest and attorney's fees, arising from atransaction in wrvlch
damS; ^nrrHmney wasac(*uired on credit' Acollections case does not include an action seekmg the ic Sing(1?5
The
dentifc S
^^
f PerSna'
r (5> a^
writtime-for-serviee
of attachment
me laeniincation
of a tZTa
case as a rll^/cZlT
rule 3.740 collections
case on^T^
this form means
that itprperty'
will be exempt
from the qeneral
requirements
and
case
management
rules,
unless
adefendant
files
aresponsive
pleading.
A
rule
3740^J^JSl!SiS
suSect
to the requirements for service and obtaining a judgment in rule 3.740.
^
a
v w leuiwis case win De suoject
Iase isrtcoSmiDn|e<x0^n.Xa,n,affVLJ?
TPl8X
aSeS n'y' P3rtieS mUSt alS0 USe the C/V// Case Cover Sheet to designate whether the
P. u
,he ^ ,S C0mplex under rule 3400 of the California Rules of Court, this must be indicated bv
L3
comS9on
h^"
t^ ,fmaV
aP'afi|intiff
desi9nates
as comP|
e*'theof cov*r
muTtbe ajoindeT
serleTw thnthe
the
nfaTnSTw anS?
f St0' th.6
l01'0"'"TJ
Adefendant
e and
serve noacase
later than
the time
its first^heet
appearance
the
molex0, "COUn,er-desi9nation that ,he case is "* mp.. or, if the plaintiff has made no designation adeSaton hat
the casi.
case is c'
complex.
CASE TYPES AND EXAMPLES
Auto Tort
Contract
motorist claimsubjectto
arbitration, check this item
instead of Auto)
Asbestos (04)
Physicians &Surgeons
Other Professional Health Care
Malpractice
IntentionalBodily Injury/PD/WD
(e.g., assault, vandalism)
Intentional Infliction of
Emotional Distress
Negligent Infliction of
Emotional Distress
Other PI/PDA/VD
i Legal Malpractice
<v Other Professional Malpractice
,-;,
ContractArVarranty BreachSeller
Plaintiff (not fraud ornegligence)
Negligent Breach of Contract/
Warranty
OtherBreach of ContractWVarranty
Collections (e.g., money owed, open
book accounts) (09)
Collection CaseSeller Plaintiff
Auto Subrogation
Other Coverage
Other Contract (37)
Contractual Fraud
Condemnation (14)
Wrongful Eviction (33)
Commercial (31)
Residential (32)
Commissioner Appeals
Enforcement of Judgment
Enforcement of Judgment (20)
Abstract of Judgment (Out of
County)
Petition/Certification of Entry of
Judgment on Unpaid Taxes
Declaratory ReliefOnly
Injunctive Relief Only (nonharassment)
Mechanics Lien
Other CommercialComplaint
Case (non-tort/non-complex)
Other Civil Complaint
(non-tort/non-complex)
Miscellaneous Civil Petition
Workplace Violence
Elder/Dependent Adult
Abuse
Election Contest
CASE NUMBER
BC * 0 9 * 2 6
CIVIL CASE COVER SHEET ADDENDUM AND
STATEMENT OF LOCATION
I 1HOURS/flH DAYS
Item II. Indicate the correct district and courthouse location (4 steps - If you checked "Limited Case", skip to Item III, Pg. 4):
Step 1: After first completing the Civil 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 Bbelow which best describes 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. Forany exception to the court location, see Local Rule 2.3.
Step 4: Fill in the information requested on page 4in Item III; complete Item IV. Sign the declaration.
Civil Case Cover Sheet
Category No.
r
o
Auto (22)
C Applicable
Type of Action
Above
1.,2., 4.
1,2,4.
Uninsured Motorist(46)
<
Asbestos (04)
r
.2
75
<u
1., 2.,3.,4.,8.
"5.
c
.-8
-o
Other Personal
E
,o
Injury Properly
Damage Wrongful
Death (23)
1,4.
1,4.
1.,4.
1..3.
1,4.
1., 4.
Page 1 of 4
LA-CV109
SHORT TITLE:
I*
I*
casenumber
C Applicable
Type of Action
Category No.
Above
1.,3.
1.,2.,3.
Defamation (13)
1..2..3.
co
Fraud (16)
1,2,3.
1., 2., 3.
1..2..3.
Other (35)
2,3.
1.,2.,3.
I
I
10.
~
*- a>
O-
c
41
E
>>
o
a.
E
LU
12.,3.
I
I
Collections (09)
C
2., 5.
1.,2.,5.
1,2,5.
2., 5., 6, 11
I
i
1.,25., I
1..2..3., 5.
2., 5, 11
5, 6, 11
1., 2.,3 5.
2,5.
1..2, 3, 8.
Condemnation (14)
Number of parcels
2,6.
2., 6.
I A6032 QuietTitle
2., 6.
2., 6.
2., 6.
2., 6.
Post-Foreclosure (34)
2., 6.
2., 6.
t
a
4)
or
Unlawful Detainer-Commercial
(31)
Unlawful Detainer-Residential
(32)
Unlawful Detainerc
Page 2 of 4
Miscelanous CPeitvonls
>
cc
2,6.
2,5.
2.
2,8.
1,2., 8.
1.,2 3.
Writ of Mandate(02)
3
->
Above
75
(Check onlyone)
.5
C Applicable
Type of Action
Category No.
CASE NUMBER
2., 8.
2.
co
O)
!3
X
V>
1.,2.,8.
1.,2.,8.
a.
,>.
75
Toxic Tort
!i2
Environmental (30)
'>
Q.
1.,2.,3.,8.
i
1., 2.,5.,8.
0)
o>
g-g'
S3
ut
Enforcement
of Judgment (20)
RICO (27)
CO
CO
I te
iS
Other Complaints
Partnership Corporation
Governance (21)
2., 9.
2., 6.
2,8.
2., 8., 9.
1.,2., 8.
1..2..8.
2., 8.
1..2.. 8.
1.,2., 8.
2,8.
Cl>
28.
I
e
2., 9.
[S,?
2.,3.,9.
2., 3., 9.
23.,9.
2.
2., 7.
CASE NUMBER
Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance orother
circumstance indicated in Item II., Step 3on Page 1, as the proper reason for filing in the court location you selected.
REASON: Check the appropriate boxes for the numbers shown
under Column C for the type of action that you have selected for
this case.
address:
180
l.E2.n3O4O5O6O7O8O9Ol0.C]11
CITY:
STATE:
Los Angeles
CA
ZIP CODE:
90025
Item IV. Declaration ofAssignment. Ideclare under penalty of perjury under the laws of the State of California that the foregoing is true
and correct and that the above-entitled matter is properly filed for assignment to the Central
courthouse in the
Los Anqeles
District of the Superior Court of California, County of Los Angeles [Code Civ. Proa, 392 et seq., and Local
Rule 2.3, subd. (a).
Dated: 02/04/16
Gregory J. Aldisert
2.
3.
4,
03/15)aSe CVer Sh6et Addendum and statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.
5.
Payment in full of the filing fee, unless fees have been waived.
6.
Asigned order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a
minor under 18 years ofage will be required by Court in order to issue a summons.
mncJhSfP!fS,f doc"eunts t0 be conformed by the Clerk. Copies of the cover sheet and this addendum
must be served along with the summons and complaint, or other initiating pleading in the case.
LAOIV'hOg (Rev3/15)
LASC Approved 03-04
Page 4 of 4