(rage 1 of a 1 COMPLAINT : ®@ — ORIGINAL FILED jo Catt Catton 1] Neville L. Johnson (SBN 66329) OCT 31 2016 Douglas L. Johnson (SBN 209216) 2 | James T. Ryan (SBN 210515) one meee 3 | Jennifer McGrath (SBN 211388)” JOHNSON & JOHNSON LLP 4 | 439 North Canon Drive, Suite 200 Beverly Hills, California 90210 5} Telephone: (310) 975-1080 6 Facsimile: (310) 975-1095 Email: njohnson@jjllplaw.com 7 4 jllplaw-com jyan@jjllplaw.com 8 jmograth@jjllplaw.com vy 9 | Attomeys for Plaintiff, \ -1o | JASONLUST =~ -—~ = ll L 12 13 SUPERIOR COURT FOR THE STATE OF CALIFORNIA’ 4 COUNTY OF LOS ANGELES 15 : . 1g | JASON LUST, a individual, CASE NO. BCE 39.228 Pa Plaintiff, : COMPLAINT FOR: 18 Vs. e 1. BREACH OF WRITTEN CONTRACT; pa 2. BREACH OF IMPLIED COVENANT 19 a LOGIC * OF GOOD FAITH AND FAIR DEALING; 20 Callie limited Ty i =)" 13, BREACH OF FIDUCIARY DUTY; 21 | corporation; ZAREH. 4. FRAUD; NALBANDIAN, an indivi il, and | 5. DECLARATORY RELIEF; AND 22 | DOES J through 20, inclusive, 6 ACCOUNTING 3B Defendants. i [DEMAND FOR JURY Re 2 # 3 8 i i 8 8 ke ! oot Ish G,” ble mw secnese61 ~ aoc mpe = Oren S3SHO/ITS saen908age 2 of 2) Plaintiff Jason Lust alleges as follows: 1. Plaintiff Jason Lust is, and at all relevant times was, an individual residing, and doing business, in Los Angeles, California. 2. Upon information and belief, Defendant Animal Logic Entertainment US, is and at all relevant times was, a company organized under the laws of the State of Califomia, with its principal place of business in Burbank, California, Defendant Zarch Nalbandian is, and at all relevant times was, ihe Chief Executive Officer of Defendant Animal Logic Entertainment US. On information and belief, Defendant ‘Nalbandian resides in Sydney, Australia and does business in Sydney, Australia a5 well a in Los Angeles County, State of California 3. Plaintiff does not know the true names ‘nd capacities of Defendants ‘sued in this Complaint as Doe 1 through Doe 20, inclusive, and therefore sue these. defendants by fictitious names pursuant to Section 474 of the California Code of www nannunaun 10 “12 13 4 | civil Procedure. Plaintif will amend this Complaint to allege the true names and 15 | capacities of Doe 1 through Doe 20, inclusive, when ascertained, Plaintiff is ! 16 | formed and believes, and on that basis alleges, that each of the Defendants named : 7 herein as Doe 1 through Doe 20, inclusive, is responsible in some manner for the i ae ossinrenoas injury sal abe damages alleged in this Complaint, | ti 4, . Plaintiff is informed and believes, 2nd on that basis alleges, that each : Defendant was in some manner responsible for the acts and damages alleged herein, | 71 | and/or are indebted to.Pleiniff as alleged: hereia, and that each Defendant % | rtcipated in the acts alleged herein and the, in participating in such acts, each 7 | Defendant:was the agent.and co-conspirat of each other Defendant, and was 2 24 1 cting in the Gourse and scope of such agency and conspiracy. = 5. Plaintiff is informed and believes, and based thereon alleges, that at all 3 6 | ines relevant to this complaint, each ofthe Defendants wa and isthe alter 280, a f agent, employee, servant, subsidiary, partner, member, associate or representative. eee 2 “COMPLAINT ‘boot 2 Paget 2 ~ Dec 2D = 2669205861 ~ Dec Type = OTIERerage 3 of a "| of each ofthe remaining Defendants, and in doing or omitting to pecform the acs | atteged herein, was acting within ie course and scope of the agency, employment, > | serve, partnership, membership, association andor representative relationship and “| swith knowledge and consent of their respective principals, employees and/or parent *| atts 6 URISDICTION AND VENUE zi 6. This Court has jurisdiction over all causes of action asserted herein 5) secause all causes of action asserted herein avise out of conduct undertaken by _..? | Defendants which took place, in Los Angeles County, State of California, The 10 partnership agreement which is the subject of this lawsuit was knowingly and u deliberately entered into and executed by the Parties, the terms of which were to be 1? | aried out in Los Angeles County, State of California 1 i 7. Bach Defendant has sufficient minimum contacts with the State of| a '4 | calfomia, is a citizen ofthe State of Calfomia, or otherwise intentionally avaited °° set or himself ofthe State of California soas to render the exercise of jurisdiction "6 | veri or it by the Stat of California courts consistent with traditional notions of "7 | sic play and substantial justice. Ee 8, Venue is proper in this Court under Code of Civil Procedure §§ 395 "9 | and 395.5 because at east one Defendant resides in Los Angeles County, State of 7 | california, andthe obligations and liailiies-o which Defendants are subject tise 71 | in Los Angeles County, State of California ce OVERVIEW a 9... . This case involves an.egregious breach of fiduciary duty and violation S | of ust by Defendants:ALE and Zareh Nalbancian, who actively. sought out a = 251 arnetship withthe Plaintiff an experienced Hollywood producer ~ apparently in 3 75) order to capitalize ‘on hisisklls'and connections: in the Hollywood community a . Defendants also sought'to appropriate Pleimtif?s intellectual property rights in i 4 COMPLAINT oct 1'bagee 2 - boo ED = 1665205861 ~ Doo Type = OnEceige 4 of "| tucrative family and atimated feature Sms thet Psitit developed and controlled 7 | Gnchuting by creating new story ideas and/or new takes on children’s classics and : public domain works). Unbeknownst to Plaintiff, from the outset of the partnership, Deferidants did not intend to continue in the partnership once Plaintiff was able to | et up tucative deals for Defendant ALE at major studios and production $y companies. a 10. In addition, Defendants have not paid Plaintiff’ monies due to him in 7 ‘connection with (i) projects which he labored to set up at studios and production e companies, using his skills as a producer and his studio connections, and (ii) 1) advisory services he provided. Nor have Defendants guaranteed that he would in u fact be attached to projects (as he is entitled to be under the partnership agreement 12 | sctween the Parties). On the contrary, on information and belief, Defendants have "5 | violated the temns of the partnership agreement between the Patss by taking 74 | ction to replace Plaintiff esa producer on various Brojects, » i 11, Through this complaint, Plaintiff seeks ‘remedies for, infer alia, the 16] reach of contract, breach of fiduciary cuity and fraud perpetrated by defendants. In 7) dition, Plaintiff sesks an accounting ofthe substantial sums that he is owed in i both front-end producer fees (including producing and production fees), as well as 19) a batkend ‘compensation from various projects produced by Defendants since the ba inception of the partnership between Plaintiff and Defendants. Plaintiff also seeks a | ao judicial determination of his intellectual property rights in certain films (which 7 | Defendants are producing) which were brought tothe partnership by Plaintiff and 23 | tie rights to which have never been transferred to Defendant ALE. e a ALLEGATIONS TO COMMON TO ALL CAUSES OF ACTION 2 ie 12. . Plaintiff Lust is a successful executive.and content creator who has B 75 | over fifteen (15),years of experience in developing and producing feature films in - EF the family and animation film genre: Mr. Lust founded Circle of Confusion (where 4 7 COMPLAINT’ +a . ‘Beat 1 Paged & ~ Doc XD = 2669205861 - Doo type = OMEN@oge 8 of a) "| he was producing paris) and was associafed with The Jim Henson Company, 7 | shore he oversaw the feature film division for si (6) yeas. Mr, Lust as been 7 credited for his producing services on numerous successful projects, including 4 several feature films, over the course ofhis career, including Whip It nd Alexander > | and the No Good Horrible Very Bad Day : 13. In or about 2007, Plaintiff met Defendant Zareh Nalbandian while the | two were both working on a project atthe Jim Henson Company. At that time, 5 | praintt was employed as a Senior Vice President at Jim Henson Productions, | 9 | Since meeting, Plaintiff and Defendant Nalbandian continued to have a professional 491 lationship. i 14. Later, in or about fall 2012, Plaintiff told Defendant Nalbandian that 7? | ye no longer wished merely to work for production companies as an employee, but 5 | so retumto partnering, with a production enty (as Plitiff had done earlier in his 4) careet in onde'to able to préduce family and aninated feature films, Pint 15 J pressed interest in entering nt a partnership with Defendants. ie 15. + Over the course of several meetings in late 2012 and early 2013, the i 17 | reintéf and Defendant Nalbandian discussed the prospect of Plaintiff entering into "8 4 producing. partnership with “Defendant Nelbandian's production company, 7 Defendant ALE. ' Plaintiff even travelled, at his own expense, to Australia in order 9 to meet with Defendant Nalbandian in person and hammer out the details of such a 21] artmership deal a 16. On information and belief, at this time in late 2012 and early 2013, e Defendants Nalbandian and ALE had primarily done work in visual effects and e 24 | nimation (@s a work-for-hire visual effects and animation production facility), but 2 > | ad limited experience in producing feature films. Moreover, on information and 3 a belief, previous feature’ film projects that Defendants had in fact developed had if : been largely, unsuccessful, despite. significant financial investment, resulting in Ss COMPLAINT “ See TL “1 Boot 4 rages's = noo'mm = 1669208961 - Dos ype = cmmERrage 6 of 41) Defendant ALE deciding to shed its creative team. 2 17. On information and belief, in or about late 2012 and early 2013, | atthough Defendant ALE had hd an office in Los Angeles for some period of time “ | prior, Defendants wanted to gein more of a foothold in creative film production in > Los Angeles. Defendant sought to enter into a partnership with Plaintiff in order to $1 ‘be able to capitalize on Plaintfs-extensive network of personal and business 7 connections at major studios and film production companies. : 18. ‘On information and belief, Defendants also sought out a partnership al with Plaintiff because Plaintiff had lucrative intellectual property rights-in various| feature film concepts and treatments in the family film and animation genre, | a including certainl “franchise” properties with potential for prequels/sequels, as well i 12 | as lucrative merchandising rights. On information and belief insted of seeking out "> | and developing such rights on their own, Defendants sought to capitalize on, and "4 ) enetit Snancaly fom, the rights developed and controled by Plant and from 7 Plaintiff's industry connections. 7 4 Partnership and Fiduciary Relationship Is Created a. 19. Plaintiff and Defendant Nalbandian ‘exchanged a series of e-mails 9} ecween December 2012 and iFebruary:2013, expressing their desire, to form a 20 | sarnership and discussing specfiétrms of the prospective partnership agreement, 71 | cluding vith tegard to Plait? entitlemeitito percentages of up-front producer 7 | tees and back-end patcipation.- peeeaaie * ee ca 20: The talks between Plaintiff and Defendant Nalbandian ultimately =. culminated in a shoit form agreement (“the SFA”), entered into between the Parties = 5) as of February 28, 2013. The SFA provides that Plantif's role in the partnership 3 | sit be Producer.” A copy ofthe SFA is attached hereto as “Exhibit 1.” . = 21. The SFA was not a fully integrated agreement. It was at all times 6 COMPLAINT ‘Boch 2 mage 6 ~ Doc xD = 1669205061 - Doe Sype = om(rage 7 of 41) grees tess Cera Hee ne 401 12 1B 14 15, 16 7 18 19 20 2 2 24 25 26 27. 28 contemplated by the parties, and expressly referred to in the SFA, thit a Jong form agreement setting forth the full and complete terms of the partnership agreement | between the parties would be drafted and executed. 22. Despite repeated assurances (verbally and in writing) that the parties would enter into a long form agreement and despite the fact that a long form agreement was, on information and belief, drafted by Defendants (through their counsel Loeb & Loeb LLP), no such long form agreement was ever given to Plaintiff for his review nor was any long form agreement ever executed between the Parties. ‘enter into both'the SFA and a long form agreement, Plaintiff began working (including on projects Plaintiff was already developing, including Peter Rabbit, Monkeys, Betty Boop 2nd Gil’s Ali Fright Diner) on behalf of the partnership in January 2013, even before the SFA was executed by the Parties, 24, From the outset of the partnership, Plaintiff worked-on setting up meetings with agencies, production companies, and studios as well as other’ strategic relationships. Plaintiff devoted many hours to formulating and executing a five-year business plan and other strategic planning for Defendants, including actively planning ways.in which Defendants‘could secure development financing, for their feature film projects, form strategic joint ventures, and form multiple producing. partnerships- with talent, including high-level Hollywood producing partners. 25. Also from:ithe outset: of: the partnership, Plaintiff began to work tirelessly to inyolve Defendants in projects that he was already developing and for which he already hadiintellectual, property rights in the particular concepts. Plaintiff pushed forward on the ‘projects which she wes developing, setting up meetings-and attempting to set up deals at studios with regard to these projects. 7 COMPLAINT ‘Hoc 2 Page 7 - Doo XD = 1669205863 - 23. Based on the representations of Defendants that the Parties would os Bype = OnIER(eage 8 of a1) e e 1) prsinift thus devoted a tremendous ainount of effort to the Parties’ endeavors] | i before he had even signed SFA. 26. After executing the SPA, Plaintiff worked tirelessly throughout 2013 “| and 2014, developing projects on behalf of the partnership, including Peter Rabbit, 5) Monkeys, Betty Boop, Fim, The Life and Adventures of Santa Claus, Spy v. Spy, S| astro Boy, Gil's All Fright Diner, The "Animated Princesses Move” and 71 Rortmately the Milk i 27. Plaintiff used his expertise and connections to set these projects up at . studios and seoure producer credit for ALE, generating significant revenue for ALE 1] (as well asthe prospect of millions of dollars inthe future), Plaintiff, through his "YF ettorts and connections, was abe to help Defendants become creative producers in 7? | de family and animated feature fm genre, including by entering into deals with "> | sudios and production companies that hed not previously worked with ALB. News . of ALE deals fot Peter Rabbit, Betty Boop, Monkeys, Finn, the ALE-Simon Cowell °° Foie ventured Forté che Milk, al of which were orchestrated and set up at 16 | cadios or major production companies by Plaintiff;'preatly increased the profile of 7 | Defendant ALB in the Hollywood community. ea 28. In addition, Plaintiff brought his advice, expertise and producing, 1° | experience to those few projets which Defendants were producing through their 70 | pipeline production facility, inching, most notably the new Lego Movies. In 21 onnection with the Lego Batman Movie, the Lego Ninjago Movie and the Lego 2 1 Movie Sequel, Plaintiff is entitled (pursuant to the Attachment provisions of the - i SFA), inter alia, to producer fees; profit participation and producer attachment. ae Defendants Exploit Plaintiff's Expertise and = ‘Connections for their Exclusive Benefit @ 26 H : 4 moo 29." Duting the’ entife time ‘period betwiéen when the SFA was signed in 2g | February'30i3 and early '20i4" Plaintiff askéld for the long form’ version of the veh te gh a 1 COMPLAINT: "|. T= Bock 3 Page# @ - noe 1D = Aees205R61 - nos type = OER(rage 9 of a agreement that he had been promised, Despite repeated assurances, no draft long | orm was ever given to him for his review and none was ever executed between 3) Defendant ALE and Plintif. - 30. Tn fact, unbeknownst to Plaintiff, Defendant Nalbandian, acting on > | enat ofan in concert with Defendant ALE, had sought to unrave the partueship $ between the Parties almost ffom the beginning. On information and beliet| | 7) though Defendants soxety intended to unravel the partnership txtween the| | 5 | parties ftom the outset, Defendants didnot want to do so until such time as they | ° | had capitalized on Plaitf’s connections and appropriated his intellectual property | 10 in order to secure deals with major studios to ‘produce various projects belonging to i n Plaintiff. | ad 31. Of course, during 2013 and early 2014, when Plaintiff was working 'S | rotessly to utilize is wiolly-owmed intellectual propety rights and connections '4 | and obtain studio deals for ALB to produce numerous film projects, he was 1S nawace of Defendant? secret intent to unravel the Parties partnership 2s soon as 16 | vefendants had capitaliéed on Plaintif’s talents, connections and lucrative _ intellectual property rights): 1 ye is Defendants Breach the SRA and Their Fiduciary Obligations to Plaintiff in connection with Peter Rabbit 20 a 32. In or about late 2013, through PiaintifP’s efforts’ and corinections at 22 | Sony, Plaintiff secured a deal for Defendants io produce a motion picture based on 23 | the Peter Rabbit children’s books at Columbia Pictures. 2 33. Especially in light of the fact thet Plaintiff was bringing his intellectual 25 | property to the table, as well as utilizing his relationships in the industry to secure {326 | 2m agreement between ALE and Columbia to produce Plaintiff's concept for Peter 3 27 | Rabbit, Plaintiff fully expected, and the Parties discussed, that (in accordance with 2g | the Parties’ agreement under the SFA) Plaintiff would be 4 “priority” producer, ie., ce ; 7 COMPLAINT | PAO 2 Pages 9 - Doc 2D = 1669205861 ~ Doc Bype = OTRoge 10 of 4) actively working on Peter Rabbit, as well as on The Adventures of Santa Claus, Astro Boy, Fortunately the Milk, Betty Boop, The Monkeys, Finn, The Animated] Princesses Movie and Gil’s All Fright Diner. 34. At the same time, in or about early 2014, Columbia and ALE began negotiating an agreement to provide the producing services of Plaintiff in connection with Peter Rabbit (the “Producer’s Agreement”). A draft of that Producer’s Agreement, dated on or about February 12, 2014 (“the February 12 Producer's Agreement”) provided that Plaintiff would be a “priority” producer on Peter Rabbit, Plaintiff was provided with a copy of the February 12 Producer’s Agreement for his review on or about April 7, 2014. Plaintiff was likewise assured by the CFO of Defendant ALE that he would be receiving the same “priority” producer status as was to be afforded to Defendant Nalbandian on the project. 35. At the same time, in or about April 2014, Defendant ALE presented Plaintiff with 4 “Certificate of Ownership of Results and Proceeds” (“the Certificate”) relating to Peter Rabbit. The document provides that all of Plaintiff's intellectual property rights in the Peter Rabbit project are purportedly transferred to non-party Animal Logic Entertainment Pty Limited and Plaintiff's work becomes a “work for hire.” 36.: At the time that Defendants gave Plaintiff a copy of the Certificate and immediately thereafter, they:(and their attomeys) urged and cajoled him to sign the document as soon as possible, so — as they claiiied ~- not to delay work on the Peter! Rabbit. project. ‘Defendants: (and their: attorneys who were. also supposed’ to be representing Plaintiff's interests as well as'those of Defendants) insisted to him that neither Célumbia Pictures inor Defendant ALE could wait any longer for work to begin on Peter Rabbit — work that Defendants claimed could not begin in earnest until Plaintiff transferred his intellectual property rights by executing the gieesTesat Certificate. “10 1 COMPLAINT 7 ‘ect 1 Pages 20 ~ Doe ID = 16659205061 ~ Doo Type = OTHER(rage 12 38 a1) e e ; 37. Atthe time that Plaintiff was being urged to sign the Certificate he still 7 | nad not seen along form agreement that comported with his understanding of the 3} att scope of his partnership with Defendant ALB, In light ofthis ator around this “1 same time, in February 2013, and throughout the entire relationship between the * | Parties, Paints kept asking Defendants when he would receive a more detailed $ | partnership agreement that more filly reflected the agreement between the partes 7 | and fleshed oxt additional specific tems agreed upon but nt reflected inthe SFA. : 38. Nonetheless, Plaintiff had reviewed the February 12, 2014 Producer's _ _.. 2 Agroement and believed — based on the express terms ofthat agreement and verbal | 1) assurances ftom Defendants ~ that he would be the “priority” producer on Peter 11) rabbit, with a uaranteed attachment, ie, that he ‘ould be actively involved in 12 | producing the project ss 39, Because Plaintiff had reviewed the February 12, 2014 draft and ue understood its tertns!(and had engaged in diseussions with Defendants to the same i 15 | tract) and in reliance on the terms of the Febuary 12, 2014 Producer's Agreement, ; 161 as well as assurances from Defendants, Plaintiff signed the Certificate, which 17 | purportedly transferred his!intllectul property rights in Peter Rabbit to Defendant 18 | ALE on 6r about April 10,2014. - 40. . Plaintiff did not know when he signed the Certificate, and Defendants 70 | actively concealed ffom him that, they intended to replace.him as a priority 21 | roducer (ie. producer actually providing services on the Peter Rabbit projec) in 7 | iotation of SFA and Defendants’ fiduciary duties to Plaintiff. Defendants intended 2 | only to-uslize Plains: intellectual property rights in, Peter Rabbit and other S a properties and his connections at)studios.in order to get projects: set.up before they = 25) sought ond the; partnership and oust Plaintiff from the projects. oo 41. Unbeknownst:to Plaintiff, almost as soon as the ik was dry on the i ‘ Certificate signed by Plaintiff, Defendants reached out to Columbia Pictures: Hee : COMPLAINT! * ‘Doct 2 Page Ai ~ Doc XD = 1663205861 - Doo Type ~ OERGage 12 of 41) ou Ane one WL 12 13 “4 15 16 Ww 18 19 20 a1 22 23 24 25 26 27 28 through their counsel (who was supposed to be representing Plaintiff's interests as well) and asked that language be inserted into the Producer’s Agreement that would provide that Defendant ALE could replace Pla Rabbit. 42. On information and belief, the requested language making Plaintiff replaceable as a producer on Peter Rabbit was incorporated by Columbia Pictures into a later draft of the Producer Agreement, a draft which Plaintiff did not see for ‘some time after he had already signed the Certificate. _.._.43. In direct contravention of the terms of SFA, Plaintiff has now been informed and believes that, despite his role in setting up the deal for Defendants to produce Peter Rabbit for Columbia Pictures, including through his connections and iff as a priority producer on Peter the purported assignment of his intellectual property rights, he is no longer a “priority” producer on the Peter Rabbit project. 44, In further breach’ of the SFA, Plaintiff has been prevented from actively participating in'the ‘production of Peter'+Rabbit. » Plaintiff is further informediand believes thit-Defendant Nalbandian’ has told Plaintiff's contacts at Columbia that Plaintiff was being removed from the project, thereby damaging Plaintiff's professional relationships and standing in the entertainment community. 45, Over the: course of mid-2014, Plaintiff continued to express to| Defendants his dismay that no long form agreement had been executed between the Parties. ‘In response,, in, early : August 2014,. Defendant Nalbandian informed Plaintiff that Defendants, had decided .that; they wanted to end the producing partnership between the ;Parties.: Following that, however, during the course of| discussions in or about early August 2014, Defendant Nalbandian reversed course 2 T 1. COMPLAINT : TT hot a Paget 12! Boo 1D 1669205961 - Dov type = onERage 13 or aay e e and suggested that he and Plaintiff meet to discuss the ongoing relationship between the parties and the terms of the partnership agreement. 46. At that time, in or about early August 2014, Plaintiff was deceived into believing that Defendant Nalbandian (acting on behalf of Defendant ALE) wanted to continue the relationship between the Parties and finally provide the promised ong form agreement. Purportedly to that end, Plaintiff and Defendant Nalbandian engaged in discussions, in or about early August 2014, about the terms of the partnership agreement between the Parties. a 47. Plaintiff and Defendant Nalbandian also engaged in discussions, i regarding a Retainer Advance Agreement, dated December 19, 2013, by which : ‘Animal Logic, LLC had provided Plaintiff with an advance of $120,000 against 2) ture monthly advances payable pursuant to the SFA. i ie 48. In the course of those discussions in or about early August 2014, 14 ! Defendant Nalbandian again misled Plaintiff into believing that Defendant ALE 15 | | 16 | 7 Car anuroene would provide Plaintiff with’a Jong'form agreement setting forth the entirety of the contractual relationshiip betweeti the Plaintiff: and ALE. | In addition, Defendant 7 ‘Nalbandiani orally. agreed thiat the long form agreément would reflect, inter alia, the 19 20 following terms: (a) Plaintiff's required. repayments of the loan made to him by Animal Logic .LLC pursuant. to. the: Retainer; Advance . Agreement would immediately cease; (b) that Plaintiff would bevattached to any projects which he had worked to set up while partnered with ALE in perpetuity, i.e., even if those projects i 2 ag | ete erent beyond the five-year sunset clause provide inthe SFA; (that with regord to any projects greenlit after the commencement of the partnership between . the Pasties, Plaintiff would be entitied to 25% of upfront producing fees, regardless 2 2s = 7 | of whether or not the partnership between the Parties.ended and (e) that with regard 2 ° | to any projects greenlit after the commencement of the partnership between the 27 ; i | Parties, which Plaintiff had worked to set-up while partnered with ALE, Plaintiff] 28 non 1 ' | 13 ~ COMPLAINT, epee ‘= 1669205864 ~ Doo Type = OnIERceage 18 of "would be entitled to an inerease in his backend producing fees ftom 125% to 25% 2 | and would also be entitle to thet 25% backend fe in perpetuity, ie., even if those 3 | srojects were greenlit beyond the five-year sunset cause provided in the SFA. : 49. Apparently these promises by Defendant Nalbandian were only a 5) continuation of the fiaud perpetrated throughout the relationship between the * | artis, designed only to placate Paint long enough to capitalize on the efforts 7) Plaintify was making to set up ALE projects at major studios and production 5) companies, - °| 50, Thus, despite the discussions and promises discussed above and io despite having insisted to Plaintiff that he was happy with the partnership 11 J relationship betvéen the Parties and withthe work that Plaintiff had already done "2 Fon behalf of ALE, Defendants never presented Plaintiff with’a Jong form agreement 1D | hich reflected the apreedto terms. . S1.° In or about mid-November 2014, Defendant Nalbandian informed °° | plant that he, in fact, wanted to end the partes’ paimership in late January 2015 °6 | tie End Date"). Both prior io and subsequent tothe End Date, Plait has not "7 | received monies they have come’ de ftom film projects, has not been provided "8 ) ith adequate information about the sereen eredit that he has begn afforded on i various projects, and has been prevented from active involvement in the partnership o projects. 9: fy ere reeeIC Na 22 | Defendants Violate Their Fiduciary and Contractual Obligations to Plaintiff a ; Regarding Peer Rabbit and Other Projects 24 52: On irformiation and belief, Peter Rabbit is going forward at Columbia © 25 | Pictures and’is slated to be a’ major release. Pursuant to the SFA, ‘Plaintiff is 26 | entitled to a portion of the prodicer fees, including producing and production fees, 97 | in connection with Peter Rabbit. At present, no such monies have been paid to 2g | Plaintiff. Further, in direct contravention of the express terms of the SFA, as well 14 i COMPLAINT 7 Dock 1 Bageh 14 ~ Doc ID = 2669205861 ~ Doo Type = OERceage 35 of 4) e e } as Defendants’ fiduciary obligations to Plaintiff, Plintif is no longer attached to 2) peter Rabbit. i 53. On information and belief, among other partnership projects, Monkeys, | ety Boop, Finn, The Life and Adventures of Santa Claws, Spy v. Spy, Astro Boy >| the Animated Princesses Movie and Fortunately the Milk, are, or may be, also * | going forward at major studios andor with major production companies. Pursuant | to the SEA, Plaintiff is entitled to a portion of the producer fees, inchuding 8+) roducing and production fes, in connection with these projects, At present, no | such monies have been paid to Plaintiff. __ ae 4 a Et 54. As discussed above, in direct contravention of the express terms of the i SPA, as well as Defendants’ fiduciary obligations to Plaintiff, Plaintiff is no longer 12 | tached to, among other projects, Peter Rabbit, the Lego Batman Movie, the Lego i Ninjago Movie, the Lego Movie Sequel, Monkeys, Betty Boop, Finn, The Life and 4) saventures of Santa Claus, Spy v. Spy, Astro Bay, The “Animated Princesses | 'S | Movie” and Fortunately the Milk; Moreover, Plaintiffs informed and believes that ae Defendant Nalbandian has told Plaintiff's contacts at major studios and production a companies associated with these projects that Plaintiff is being removed from the 7 projects, thereby damaging Plaintiff's professional relationships and standing in the i | entertainment community. 1. : fe ‘| 20) 55. Plaintiff never signed any writing of any kind transferring his ; 71 J stellectual property rights in Monkeys, Betty Boop, The Life and Adventures of| : ‘ Santa Claus, Spy v. Spy,.Astro Boy, The “Animated Princesses Movie” and : a Fortunately the Milk and herein seeks declaratory relief as to his intellectual rights 1 2 24 these projects, which; Plaintiff is informed and believes are now being exploited i 5 25 | | y Defendants without his involvement or authorization. : 2 2 56. : Plaintiff is unaware of what other projects ALE is in fact producing a from which he is.entitled to proceeds, .to which he should be: actively attached. ft 1S. : 5 : COMPLAINT 1 Doct 1 Paget 15 - Doc 20 = 1659205861 - Doo type = onERage 16 of 61) i aa e e "| taint wll sek leave to emend this Complaint as new information is providéd to 2 | tim orbe is able to obtain infomation about such projects, : FIRST CAUSE OF ACTION ‘ BREACH OF WRITTEN CONTRACT : (Against Defendant ALE and Does 1 through 20) 57. All previous allegations are re-alleged and incorporated herein by 7 reference i 58. By executing the Short Form Agreement (“SFA”) as of February 28, _? | 2016, Plainttf and Defendant ALE entered into,e valid binding, and enforceable 10) contact. Plaintiff has performed all conditions, covenants, and promises required 11 | to-be performed tinder the terms and conditions of the SFA or was excused from | i performance due to Defendants’ material breaches described below. I ts 59. ‘The SFA contains the following relevant terms: : i ‘a, Revemiés: "" (a) | Producér Fees ride : i‘ a <1 ct 1@) © 125% of contracted Producer Fees (net of ie COMPLAINT, Thoot 4 raget! 19 - Doc 3p = 2660205863 ~ ' i | , i ' i | oo type = oesage 20 of 41) OTT TET er AKHe ENE ay 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 an amount to be determined at trial. FOURTH CAUSE OF ACTION FRAUD (Against All Defendants) 74, All previous allegations are re-alleged and incorporated herein by reference, 75. Defendants have committed five variations of fraud, iter 76. Defendant Nalbandian, on behalf of himself and Defendant ALE, misrepresented to Plaintiff the material fact that Defendant ALE would enter into a partnership to cé-develop and co-produce projects with Plaintiff, which would result in compensation to Plaintiff and active producing roles for Plaintiff, This istepresentation representation was false when made. 77. Defendant Nalbandian knew that his promise to Plaintiff was false when he made it to Plaintiff; (2! — ! ts ‘ 78. Defendants intended to ‘defraud and induce Plaintiff into the Partnership because Plaintiff is.a successful‘and well-connected producer and had lucrative intellectual property rights in various feature film concepts and treatments in the family film and animation genre. 79. Plaintiff relied on Deferidant Nalbandian’s promise and spent numerous hours, money and al great! dealof effort developing the partnership projects. Plaintiff justifiably relied on Deferidant Nalbandian’s promise because Plaintiff had known Defendant Nalbaidian for years, believed him to be an honorable man and believed. Defendant Nalbandian to be honest and sincere about partnering with Defendant ALE, Based on their previous discussions, Defendant Nalbandian was: aware thet Plaintiff was only seeking a producing partner relationship. Plaintiff did stot know Defendant NaJbandian's, representation was bi 20 TS SOMPLAIN 7 7 ho 4 nmerage 21 of a "| tase and believed it ‘was true especially in light of Defendant Nalbandian’s multiple 7} iscusions and assurances to Plaintiff about partnering with Plaintiff, Plaintiff had > | no’reason to believe that Defendant would not honor the promise. Plaintiff also: * | justifiably relied on Defendant Nalbandian's promise because the producing partner’ > | settonship that was entered into was a common relationship in the film industry, 5} and, on information an belief, Defendants were avare ofthis industry practice. - Deceit per Cal. Civil Code §1710 fl 80. Defendant Nalbandian, on behalf of himself and Defendant ALE, ° made a promise to Plaintiff (that Defendant ALE would enter into a partnership to OF condevelop and co-produce projets with Plaintiff) without any intention of 11 esforming it = 81. Defendants knew that thie promise to Plaintiff was false when it was | ae 4 i 82. Defendant Nalbandian's promise was'inade with the intent to defraud "> | and induce Plaintiff to rely upo it. Defendant intended to'indce Plaintiff into the '6 | artaership-because Plaintiff sa suécessful and welkcoanected producer and had "7 | ucative intllectualproperty right in various feature film ‘concepts and treatments °8 | a the family film and animation genre. © + i 6 83.1 Plaintiff was-unavéaré of Defendants’ intention not to perform the 70 1 romise, t ees ae : Actual Fraud per Cal, Civil Code §1572 . 84. Defendant Nalbandian, through: connivarice,:.intended to induce .. 22 | Plaintiff to enter into the SEA and to use Plains significant efforts and talents to S a develop and produce projects by making a promise to Plaintiff (that Defendant ALE 3 a would enter into.a partnership to co-develop-and co-produce projects with Plaintiff) 2 757 vithout any intention of performing it. Defendant Nalbandian knew that bis : 7 27 mise to Plaintiff was false : ' : 28 see a4 1 «HE SCOMPLAINT: ae 4 vw Teta ed - ‘Decl 4 Bagot 21 ~ Doo XD = 2669205861 - Doo Type ~ OmERage 2 of 42) e ® } 85. Defendant Nalbandian’s promise was made with the intent to defraud | ad induce Plaintiff to rely upon it. Defendant Nalbandian intended to induce | pisintgt into the partnership relationship because Plaintiff had comnections end “| tucctive intellectual property rights in various festue film concepts and treatments 51 inthe family film and animation genre. { 86, Plaintiff was unaware of Defendants’ intention not to perform the 7) promise, 5)" br. Defendants committed other acts fitted to deceive by constantly ° | promising delivery of a long form agreement that would more filly reflect the 1 | partes’ agreement, but never delivering such long form agreement over the course 11) oftwo years : A Code §1573 es 88. relationship between Plaintiff and 4 | Defendants as alieged above; Defendants owed Plaiitiffa duty of tat, honesty and 'S | sat disclosure. . sos ! ‘6 89,. Defendants breached this duty by’ secretly usurping partnership ! 17 | projects, producing. activities and credit for their own benefit, thereby gaining} | "8 | nancial and ctherbenefit-for themselves tothe prejudice ofPaitiff. Defendants : °° | ailed to disclose:at any time:that they did not intend to honor the partnership oe ' is 90, Plaintiff was:misled by Defendants to his. prejudice. Had Plaintiff » | sown Defendants! true intentions, he nover would have entered into the Certificate t 22 | or spent a-significant amount. of time, moviey-and effort into developing the ‘ S ca partnership projects. i 5 = Concealment per Cal, Civil Code §§1572 & 1710 1 2 91. Defendants concealed and/or suppressed material facts from Plaintiff ! : including: (a) Defendants intended to unravel. the’partnership, (b) Defendants did 22 » COMPLAINT © i ‘poct 1 eageh 22 - poo 19 = 1669205861 - boo Type = OmERage 23 of 43) i not intend to honor the SFA, and (c) Defendants did not intend to provide a long 2) som agreement to Plaintiff. ‘| i 92. Defendants were under 2 duty to disclose those facts to Plaintiff “| because (2) Defendants had exclusive knowledge of the foregoing material facts,| | : which Defendants knew were not known ot readily available to Plaintiff, and (6)} | the Parties were ina fiduciary relationship. \ ic 93. Defendants intentionally concealed or suppressed the material facts| | 5 | vith the intent to defraud Plant because, by concealing or suppressing the facts, | -. . . 2 | Defendants were able to continue to utilize Plaintiff's efforts in developing the 10 projets and acquire intellectual property from Plaintiff . 94. Plaintiff was completely unaware of thé’ material facts and would not af ‘bave acted as he did if he had known of the material facts. ue 95. As a direct and proximate result of Defendants? fraud, Plaintiff has te suffered damages in an amount that is in excess of the minimum jurisdiction of the 15) superior Court. +! i 96. Defendants’ conduct as: described herein was done with a conscious t i disregard of Plaintiff's rights, with the intent to vex, annoy, anid/or harass Plaintiff| 38 | and to unjustly profit from Plaintfs efforts; connections and intellectual property. 7 Such conduct was unauthorized and constitutes oppression, fraud, and/or malice 7 | nder Califomia Civil Code §3294, entitling Plaintiff to an award of punitive 21 | camages in anvamount appropriate to:punish or set an example of the Defendants in % | ax amount to be defermined atrial: ¢ Baal og a 7 rt FIFTH CAUSE OF ACTION S 7 « DECLARATORY:RELIEF aie _. Against Defendant ALE and Does 1 through 20) eB % 97. All previous allegatioris are re-alleged and incorporated herein by 27 reference. 50) anu Die ere tat 28 23 COMPLAINT: ~ aw , "Doct + Pagod 23 ~ Doe ID = 1669209861 ~ Doo Type = OnERrage 28 of a) gic 1e78t we ranean e 10 12 13 14 15 16 7 18 19 20 au 2 2B 24 28 26 27 28 98. During the time in which the Parties were partners, Defendants exploited Plaintiff's wholly owned intellectual property rights in certain film concepts in an attempt to make deals for Defendant ALE at studios and to benefit Defendants. Plaintiff, through his efforts, expertise and connections, pitched to studios various projects on behalf of Defendants, including Monkeys, Betty Boop, The Life and Adventures of Santa Claus, Spy v. Spy, Astro Boy and Fortunately the Milk, 99. Plaintiff's wholly owned intellectual property rights in Monkeys, Betty Boop, The Life and Adventures of Santa Claus, Spy v. Spy, Astro Boy, The “Animated Princesses Movie” and Fortunately the Milk were never transferred to Defendants or any third party. Plaintiff owns and controls intellectual property tights in these projects and Defendants have no ownership interest of any kind in Plaintiff's intellectual property rights in these projects. 100. Defendants, on information and belief, are proceeding with these projects, which utilize Plaintiffs whlly:owned intellectual property rights. 101. An actual controversy now exists:betweén Plaintiff, on the one hand, and Defendants; on ‘the’ other hand, with regard to ownership of certain intellectual property rights in Monkeys, Betty Boop, The Life and Adventures of Santa Claus, ‘Spy v. Spy, Astro Boy, The," Animated Princesses Movie” and Fortunately the Milk. | 102. A judicial declaration is therefore necessary and appropriate at this time in order to determine the Parties’ respective intellectual property rights in Monkeys, Betty Boop, The Life and Adventures of Santa Claus, Spy v. Spy, Astro Boy, The “Animated Princesses Movie" and Fortunately the Milk. + SIXTH CAUSEOF ACTION 1.2» ACCOUNTING : . .». (Against Defendant-ALE and Does: through 20) 103, All previous allegations are re-alleged and incorporated herein by 24 ‘COMPLAINT ‘oe ED = 1669205861 ~ Doo fype = omuen(rage 25 0f a) reference, 104. A relationship exists between Plaintiff onthe one hand and Defendant ALE on the other hand for which an accounting of Defendant ALE’s books and records is appropriate. 105. ‘The sums due to Plaintiff can be ascertained by an accounting. Plaintiff does not know the precise amount of monies received by Defendant ALE, ‘hich are owing to Plaintiff, but sucki monies can be determined by en accounting 0 Defendant ALE's books and records. 106._ Plaintiff also prays for the Court to impose a constructive trust on all ‘monies wrongfully withheld by Defendant ALE. In accordance with the common Jaw and California Civil Code §§2223-2224, for the benefit of Plaintiff and Plaintiff's interests, PRAYER FOR RELIEF Wherefore, Plaintiff prays for judgment against the Defendants, and each of them, as follows: : i | : : 1. . Fordamages; 1 4 Hoy 2... For pre:judgment interest pursuant to Civil Code §§3287, 3288; 3. Forcosts of suit; ve ' 4, . Foran accounting; : 5. _. For disgorgement of money. wrongfully. withheld; 1. 6. For the Court to impose a constructive trust on the monies wrongfully withheld; 7 ' i nent 7. Fora declaratory judgment that intellectual property rights in certain projects, including Monkeys, Betty Boop, The Life and Adventires of Santa Claus, Spy v. Spy, Astro.Boy, The “Animated Princesses Movie” and Fortunately the Milk, belong solely to Plaintiff and have never been transferred, in whole or in patt, to Defendants or any third party and that Defendants have no rights. whatsoever in any 25 Tr F COMPLAINT ceoan aid " 7 7 Deck 2 Pages 25 ~ Doc 1D = 1669205861 ~ ee ype = OER(eage 26 of a1) intellectual property in these projects. 8. For punitive damages on the Third and Fourth Causes of Action; and 9. Forsuch other, further, and different relief as the Court deems proper ‘under the circumstances, DATED: October 31, 2016 JOHNSON & JOHNSON LLP er Ane ena res 8t & 18 ree R 26 COMPLAINT ‘ook 2 PageH 26 - Doo XD = 1669205961 - Dos Type = OTEage 27 of a) Ter8T ate 3 DATED: October 31, 2016 DEMAND FOR JURY TRIAL Plaintiff hereby demands a tril by jury. JOHNSON & JOHNSON LLP By a ae mson mmeys folPlaintiff Jason Lust 2 COMPLAINT 2 ‘oct I Pages 27 ~ Dee 1D = 2668205861 ~ Doe Type = orER(age 28 of a1) ect 1 Paget 28 = Doo ZD = 1669205862 - Doo Type = CIRrage 29 of 45) EXHIBIT A ater tev at ‘Boot 1 Page 29 ~ Doo 1 = 1665205861 - Doo Typs = CTHERage 20 of 2 ANIMALLOGIC Fat Sag oes erue 28 Februnry 2013 Jason Lust ‘asonlusigG8@xmaiicam -- - Commercial in Confidence Deat Jason, Following our discussions in the ast two weeks 1am pleased to propose the following terms and structure for your role as Producer at Animal Logic Entertalnment US. The following will form the basis of any longform contrectval relationship executed between ws. Having considered all our notes and requicemens and having balanced them against what works for Animal Logi and what wre ean suppor, hope the folowing adresses all of theiasves we disussed and provides an acceptable structure for your engagament. Note that have defined youroe and title 3s Producer. tn thinking through the options believe that President of Production conveys. role asanemployee andlessasa ‘Producing partner. t would ik werk against us invalidating the contractor relationship Commencement Fesruay$,2013 Date: Term: Init term of 2 years fem Commencement Date on “st will” basis. Four (4) month notice clause for elther party daring initial Term. “Attached terms shall continue to apply during any extension beyond the Initial Term unless otherwise negotiated, RoleandTitl: Producer. Services: Services to be provided consistent with achieving the attached ‘agreed Business Plan ‘Your services related to fm, television, interactive games, dnd! ‘other entertainment related media IP projects wl be exclusive for the Term : oo 7 ‘Koedteter(exenen) 263299 "Bech 4 Page 35 ~ Doo XD = 166970586: ~ non ype = OFEER(rage 5 oe 2) 3 Engagement basis Revenues (Copyright and all related Pin the services to be assigned to Animal Logle. ‘Your contractor employment agreement wil acknowledge a carvecout of previously contracted project attachments to be attached as Exhibit 8 ‘Subject to confirmation from US tax and HR advisors, you will be ‘contracted to Arimat Logic Interactive LLC vis your wn company ‘ona loan out agreement. Laan out entity to be responsible forall ‘employment related taxes for your services, workers compensation insurance and general lability insurance Your contractor employment agreement wil acknowledge a carve out of previously contracted project attachments to be attached as Exhibit B. Advances of $220,000 pa payable monthij ih arrears on receipt of invoice detalng services rendered during month ‘Advances fly applicable against net Revenues. Timing and basis of recoupment of advances as per schedule in attached business plan and budget. Note that theres no recoupment required in year 1.25% ony in year 2, 50% onlyin year 3, and we goto 100% In year 4 (2) Producer Fees i{) 12.5%of contracted Producer Fees (net of applicable agents commissions) fora projets green after " Cantmencement Date to whieh you ate ented tobe attached plus (0) during tie Ter, andddional sot contracted * <1 prodhice? fads (net of Spplicabl commissions) "for aifprojects greet after Cortmenéement Date to <1" 7 which you are'entiled to beattached: (0). :ProfitPartcgation 11 fe (D! nfespect of projects listed as Exhibit A-m2.9% of AALE's entitlement to profit participation (as defined + ihedch project afd act of any agent's cominissions S11 and egal/audi,Sccounting ork professional fees urredinrelation to the calculation and receipt) . | stor al projects green after Commencement Date to which’yod are entitled tobe attached, prorated toreflect the actual provision of services tothe production during the Term, ‘oes eter fvertn) 265209 i i | Pa aged 41 ! noo ap = 2669208062 - Doe mype = OTEERrage 32 of ay (i) nrespectof projects not listed as Exhibit A-12.5% Of ALE’ entitlement to profit participation (as defined in each project and net of any agent's commissions andlegal audit, accountng or ike professional eas incurred inrelation to the ‘alulation and receipt fora projects greenit after Commencement Date to which you are entitled to besttached. Expenses Reasonable traveland accommodation expanses and outof A pocket expenses to be agreed inadvance i ‘Attachments: Inthe event your contract with ALEs terminated for any reason or Ierotrnewad ster th il tem, you wi sib ented tobe = ow attached tothe following: + Any fi projects sted as Exhibit A (pre-existing ALE. . projects) green it for production within atwo() year period from the date of termination; ‘© _Allother projects agreed as commencing development after the Commencement, greenkt for production withina fve (5) year period trom the date of termination credits: “Producer or "Executive Producer subject to considerations. suchas qualification for Australian Producer Offset rebates, your level ofinvolvement in developing existing ALE projects vs new cories, and approval of financiers and cstibutors(Frequired). In respect of projects sted as Exhibit greenlt after Commencement Date to which you are entitled to be attached, Company wil use best efforts to provide that you shal receive 3 credit ng ess than “Executive Producer”. In respect of projects not Istad as SNbit 4 greentt after ‘Commencement Date to which you are entitied tobe attached, you shall be accorded. credit no less than “Executive Producer.” seas Shee 3 Zeatahimer—— ew ba j 2 ZAREH NALBANDIAN JASON LUST i a Chief Executive Officer. ' on ; 8 oon toate pipers. ‘ eter (een) 923208 ‘book £ Bagel 32 - Des 1D ~ 2669205061 - oc Type = OTHERrage 33 of 4et EXHIBIT A PRE-EXISTING ALE PROJECTS cane THE MTEL BONE FOGMOUND NEMESIS MONSTER BLOOD TATTOO THELAST FAMILY stoesiewer acon 263205 ‘ech 1 Paged 53 ~ Doo 1D = 2669208861 ~ Doc Type = OTHER(rage 36 of a1) 2 3 a 5 é 4 5 8, 1 20. 2 3. gterieet EXHIBIT 8 PREVIOUSLY CONTRACTED PROJECT ATTACHMENTS ‘CIRCLE OF CONFUSION PROJECTS (contracted to the end of CY 2095) ‘ALEXANDER'S NO GOOD, HORRIBLE, VERY BAD DAY THE DOUBTFUL GUEST FRAGGLE ROCK AGIANT PINOCCHIO cuniosimes ‘CLEMENCY POGUE MONSTER BLOOD TATTOO -.-2 = —enenne a = DARK CRYSTAL2 ‘STORYTELLER LABYRINTH SEQUEL/PREQUEL/SPINOFF PORTABLE 000R, ONLY HUMAN WHICHWHTCH FROGAND TOAD FARSCAPE: THE MOVIE HENSON/ELTON JOHN LIVE STAGE PROJECT ‘THE HAPPYTIME MURDERS. THE OUTLAWS ‘THE MAPMAKER THETOMBS ‘THE EDWARD GOREY HAUNTED HOUSE PROJECT 1 ea tere Dock 4 Paged 34 - Doo ID = 1669205861 ~ Dee Type = OnEage $8 of a1) N exter AGREED BUSINESS PLAN 9 Doct 2 Faged 85 - Doo ZD = 1669205861 ~ Doo Typeceage 36 of a) ” a @ ORIGINAL @ CARA ene Rema Ace” arpa Jeanie MeGath SBN 211988) vot Count Galfomia FREES mpavmcumaaae | “Smaart moe AOR Ee om oct 31 208 [uecmoa court or eauroma coumror Los Angeles : cavCie | a8cs2 aver te 28 {#8069 otnerRea rope ht ence demain wiarera,torezsiwe) [2.6 ° 5 Cie DEaRe-CoRRERATT Cy peczt UnntlDeDarConmeclfraansorwegtieietn [Att i er ed an Bs amv Dee a 5 SE | ctmedloeees, | smaruipwsonane raisons 2a PS | unataceinerougs 2% [0 Ascee Unawsl Oetirer ors ev on ere CIVIL CASE COVER SHEET ADDENDUM Toca Rue 23 ssc anporesos0e AND STATEMENT OF LOCATION Page 2014 Dock 4 Pageh 29 ~ Doo ID = 1665205861 ~ Doc Type = OMIERerage 40 of a1) Lust v. Animal Logic Entertainment US otal, e x ne ath ee 23s [_Posmmrentrai) |e Ati6 Petrie ConprCasimveaaaton Bs é 1D AGE Wet Adinerave Mandems 2 EB | wagisintseon | sete wt-mancameson ited cout cae tater 2 3 0. A019 woes Co cat Rae 2 Se ee 28 [Reema [At woos Tae B [_conetectonostcici9 [a Asoo? Consinetondetea 12.8 Tar | ees et] jai casing ne Ten pune é 3 | secates upton [io att samme geoncane enim [MOSH Toe TE nternat 1238 Ingaine Corerae Cains |” Asay tsrapceCoveapisSubosaton (omelets ox 1258 a, seve Se Se one Ban . 1 |e: sere sit stone TB | cseenes "for aor comsninetavonn neem nen EE | RSE [a seie sanimetes enectnssinny ES 1 6114. PesienCeses Ey corertn Unt Tax ++ [a nos oer nocenettavarnert Cae RED [MO Foor GD) Ea i 4 12 6020 oscuro Reet ry 428 § cnerconpunss [0 A800, eine tet Oy ceaschaesanen) 28 i (et Spectes Aeove) (2) 1 agot4 CiherCormeril ampli Case emotnon compen) 128 . 000 iar Cit Cte paonor came) et AND STATEMENT OF LOCATION Pampemnpcenee=t [cq agit Patemypand Capone Goemaia Cave ae [ea ater chase 230 aE 1 A619 wae Hrseet ans FE | comoacenss © [2 Mit Bseberaeinesnee coe ane SS | sectesmaelian | nero Seconcovest : 28 it Pam cage cient at 7 > seo Peon ie Keni Cima ean 3 Aso Oferou Pettn * * = Tevmeeaio,, CIVIL CASE COVER SHEET ADDENDUM (wal Fue ASC Approvadas.on | Page 3of4 ‘boob A Faget 0 ~ Doo 1D = 1659205861 - Doc Type = OTHERrage a1 of 4 POT Lusty, Animal Logic Entertainment US et a ‘Stop 4: Statement of Reason and Adtiress: Check the appropriate boxes forthe nuntibers shown under Column for the type of action that youhave selected, Enter the address which isthe bass for the fling location, including ip code. (No address required for class action cases). REASON: 8337 Uta Drive : 91.02.03.04.95.06.07, 08.0 9.010.011, Los Angeles ica | sons ‘Step 8: Certification of Assignment: | certly that this casei properly Fed inthe Cental District of __ the Superior Court of California, County of Loz A Gi Pro 5992 etseq, and Local Rule 23@)NED, Dated: October 31,2016 PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TOB JORDER TO PROPERLY CCONIMENCE YOUR NEW COURT CASE: 41. Ofiginal Complaint or Petton, 2. Mfg a Completa completed Summons form for issuance by he Clerk, i 3. Gil Case Cover Shet, sual Counc form C¥V-010. 4 Syigese Cover Sheet dnd and Statement of Loaton form, LAGI 102, LASC Approved 03-06 (Rv. ‘2ne), Payment in ful of the filing fee, unless ther is court order for waver, partial or schedules payments. ' A signed orderappcintngthe Guerian ad tem, judicial Coun form CN-010, jhe painter pttioneris@ minor under 18 years of age willbe required by Cour in order to issue a Summons. 7. Adiitional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along wih the summons and cota, cr ther intang plooding nthe case. : gTezs Tes at aaiv a ferme CIVIL CASE COVER SHEET ADDENDUM oeat Rule 23 ASC hoped 03.08 AND STATEMENT OF LOCATION Page aera ‘Dood 2 Pages 41 ~ Dee XD = 1665205961 ~ Doc type = OTEER