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rage 1 '9f 30) ZHL8 LTat? 1 | William A, White (Bar No. 121681) G. Cresswell Templeton Ill (Bar No, 138398) 2 | Jeffrey B. Beil Bar No. 269608) Seep ILE FARRER & SURRILL LLP FILED, 3} One California Plaza, 37th Floor eno 300 South Grand Avenue Goes ar a 4 | Los Angeles, California 90071-3147 Teleghew: 319) 200460 | wan 5 | Facsimile: (213) 624-4840 ‘0. eo Bante © Sv were Ra so rs 6 | Attomeys for Plaintiff, Qn, i. Gaon PATRIC JONES — chore 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES 10 ec gobi? 11 | PATRIC JONES, an individual, CASE NO. 12 Plaintiff, COMPLAINT FOR: 3 ws, (1) BREACH OF QUASI-CONTRACT Q) SET ASIDE OF COMMUNITY 14 | RANDALL DOUTHIT, an individual; DOUTHIT PRODUCTIONS LTD., a SPOUSAL CONSENT; 15 | California domestic stock company, RD, 3) CONVERSION; LLC; limited liability company; SUDITH | (4) ° BREACH OF FIDUCIARY DUTY; PROPERTY TRANSFER WITHOUT 16 | SHEINDLIN, an individual; HER (3) AIDING & ABETTING; HONOR, INC,, 2 Florida Corporation, (6) MONEY HAD AND RECEIVED; 17 | QUEEN BEE PRODUCTIONS, INC, a (7) UNJUST ENRICHMENT: California corporation; BIG TICKET (8) ACCOUNTING; and 18 | PICTURES, INC.; a Delaware (9) DECLARATORY RELIEF corporation; and DOES 1-100, inclusive, Defendants. JURY TRIAL DEMANDED jovor "08 "08 rans 13H FasArzay ne wie Id 31a Lat 33 oorsere teers 4 Na estc0 STrsescosHa9 # Sasa/es 235007119 42369808 ‘COMPLAINT ‘Deol 1 Pageh 2 — Boa ID = 1704203013 - bee Type = on rage 2 of 30) 1 Plaintiff, Patric Jones, alleges as follows: 2 THE PARTIES 3 1. Plaintiff, Patric Jones (“Plaintiff” or “Jones”), is and at all times mentioned herein 4 | was an individual residing in Los Angeles County, California. 5 2, Defendant Randall Douthit (“Douthit") is and at all times mentioned herein was an idual residing in Los Angeles County, California. 7] 3. Plaintiff is informed and believes that Defendant Douthit Productions Ltd. 8 | (’DPL") is a California domestic stock company that was a all relevant times doing business in 9 | Los Angeles, California. 10 4, Plaintiff's informed and believes that Defendant RD, LLC ("RD") was a 11] California limited liability company that at all relevant times was doing business in Los Angeles, 12 | California. 5. Defendant Judith Sheindlin (“Sheindlin”) ig an individual, Plaintiffs informed. 14 | and believes that Sheindlin owns a home in Beverly Hills, California and that at all relevant ! : f i 15 | times, she conducted business in Los Angeles, California, 16 6. Plaintiffs informed and believes that Defendant Her Honor, Ine. (“HHI”) is a 17 | Florida Corporation owned in whole or part by Sheinlin and that in connection with the facts 18 | alleged against it was doing business in Los Angeles, California, 19 7. Plaintiffs informed and believes that Defendant Queen Bee Productions, Inc. 20 | ("Queen Bee”) is 2 California corporation owned in whole or part by Sheindlin and that in 21 | connection with the facts alleged against it was doing business in Los Angeles, California, 2 8, Plaintiff is informed and believes that Defendant Big Ticket Pictures, Ine. (“Big 23 || Ticket”) is a Delaware corporation and that at all relevant times it was doing business in Los 24 | Angeles, California, 2s 9. Plaintiff’ is unaware ofthe true names and capacities of DOES | through 100 and 26 | therefore sues them using fictitious names. Plaintiff will amend this Complaint to reflect the 27 | DOE Defendants’ true names and capacities when Plaintiff discovers that information, Plaintiff 22+ ‘COMPLAINT ‘Doct 1 Paget 2 — Doo TO = 1704203013 ~ doo Type = OTHER rage 3 of 30) 1) isinformed and believes that each DOE Defendant is in some manner responsible forthe acts, 2. | omissions, and matters alleged in the Complaint 3 10. Plaintiff's informed and believes, and theteon alleges, that at all times material 4 | herein, Defendants, including each defendant sued under a fictitious name, were the agent, 5 | servant, employee, representative and/or alter ego of the remaining Defendants, and that in so 6 | doing the things alleged herein, was acting within the course and scope of its/is/her duthority as 7 | such agent, servant, employee, representative and/or alter ego, with permission and consent of the 8 | remaining defendants, and is responsible in some manner forthe acts alleged in this Complaint, 9 : GENERAL ALLEGATIONS 10 11, Plaintiff is informed and believes that Douthit and other Defendants engaged in MH | conduct designed to deprive Plaintiff of her community property interest in certain community 12 | assets as alleged below. Plaintiff is informed and believes that as part of such conduct, Douthit, it { 13 | and perhaps other Defendants attempted to conceal from Plaintiff the very existence of the i 14 } community property at issue in an attempt to deprive Plsintff of her lawful interest in that i 15 | property and the proceeds that have been derived from that property. The purpose of this lawsuit 16 | is to secure Plaintiff the retum Plaintiff's portion of such community property, to be appropriately 17 | compensated for the injuries, losses, and harm she has suffered, and to obtain the other relief 18 | requested below. 19 12. Plaintiff Patric Jones and Defendant Randall Douthit were married on January 28, 20 | 1996. al 13. Douthit is an experienced and successful television producer. On or about 2} January 16, 1998, Douthit’s production company, DPL, entered into an agreement with Big 23 | Ticket, a CBS Television Studios affiliate, for Douthit’s services in connection with the court- 24 | gente television series Judge Judy (the “Big Ticket Agreement”). The Big Ticket Agreement was 25 | amended in 1999, 2001, 2002, 2004, and again on March 7, 2006. (The January 16, 1998 agreement, including all amendments, is referred to as the “Big Ticket Agreement.”) A true and : Lees eee 27 | correct copy sf what Plaintiff is informed and believes is the Big Ticket Agreement is attached to 28 | this Coniplaint as Exhibit “A.” “3. ‘COMPLAINT Doct 2 waged 3 - Roc xD = 1704209012 - Dos Type = OnIER erage ¢ of 30) 10 ul ii a : i 4 1s 16 nau Phanan & euRREL LLP 7 18 19 ‘20 2 2 B 8 14, The Big Ticket Agreement outlined the services Douthit was to perform in connection with the Judge Judy program. It also gave Douthita first look development deal with Big Ticket, whereby Big Ticket gave itself aright of first refusal fr the rights to any project in which Douthit or DPL would hold a proprietary interest: Notwithstanding the exclusivity set forth in the Agreement, Big ‘Ticket and Lender hereby agree that Lender or Artist shall have the right to start up a production company, and Artist shall have the right to provide Artists services fo such production company, provided, however, such production company shall not be involved inthe development, production or distribution of court-genre programming, with the exception of court-genre programming for primetime subject to Judge Judith Sheindlin's prior approval. Big Ticket shall have first califirst priority over Aitist’s services, and ‘Artist may not render services for such production company in @ manner that will interfere with the rendition of Artist's services hereunder. With respect to any project in which Artist or Lender or such production company holds a proprietary interest, Artist shal! present exclusively to Big Ticket, or its designee, such projeet for consideration for a period of thirty (30) days end Big Ticket, or its designee, shall have the exclusive right, but not the obligation, 10 move forward to develop, produce and/or distribute any such, project. 15. On June 24, 2007, Plaintiff and Douthit separated. That seme dey, Douthit filed’a ‘marital dissolution action in Los Angeles Superior Court captioned fn re Marriage of Dowthit/Jones, LASC Case No. BD 469 787 (the “Dissolution Action’. 16. Plaintiffs informed and believes that while the Dissolution Action was pending, ddferidant Judith Sheindlin approached Douthit about entering into a development deal for a court-genre-television project. On or about April 1, 2010, Douthit’s production company, RD, entered into an agreement with Sheindlin’s production company, HHI, for Douthit’s services in connection with « court-genre television project for the 2013/2014 television season (the “HHL Agreement”). A true and correct copy of what Plaintiff is informed and believes is the HH Agreement is attached to this Complaint as Exhibit “B.” 17. The term of the HH Agreement was one year, and gave IH an option to renew the agreement in 2011 and 2012. In exchange for Douthit's exclusive development services, HH ‘paid RD $500,000 forthe frst year. HH subsequently exercised its two options to review the -4- ‘COMPLAINT oot 2 Faget 4 = nec 1D = 1704203813 - Doc Type = OTHER rage 8 of 30) | contract in April 2011 and April 2012, each time paying RD $500,000, for a total of $1.5 million 2 | in payment to RD, and thereby extending the HH Agreement until at least April 1, 2013. 3 18, On July 19, 2012, Douthit filed an updated Declaration of Disclosure in the 4 | Dissolution Action purporting to disclose under penalty of perjury all material facts and 5 | information regarding his community property assets at issue in the Dissolution Proceedings (the 6 | “Disclosure”), In his Disclosure, Douthit identified the HH Agreement, and declared under 7 | penalty of perjury that “My agreement with Her Honor, inc, hes ended.” He further declared 8 | under penalty of perjury that “I received the last and final payment under the agreement in April 9 | 2012, and the agreement has not been extended or replaced.” On the first page of the updated ‘| isclosure, Douthit declared under penalty of perjury thatthe Disclosure was “[a]n accurate and 11 | complete written disclosure of any investment opportunity, business opportunity, or other 12 | income-producing opportunity presented since the date of separation that results from any 13 | investment, si ficant business, or other income-produeing opportunity from the date of 14 | marriage to the date of separation.” 15 19. . Trial ofthe Dissolution Action commenced on September 27, 2012, On December 16 | 31,2013, the court entered a final Judgment of Dissolution. ” 20. Less than four weeks after the Judgment of Dissolution, it was announced in the 18 | media that Sheindlin and Douthit had syndicated a new television show called Hof Bench, a 30 19 | minute court-genre television program in which a panel of three “judges"—one former judicial 20 | officer and two practicing attomeys—would preside over small-claims cases, argue over the 21 | merits of the case in chambers, and then deliver a verdict in front of a live studio audience. Hot 22. | Bench first debuted on CBS stations throughout the United States in September of 2014. Plaintiff, 23 | isinformed and believes that Ho! Bench is produced by Big Ticket and Queen Bee. Plaintiffs 24 | Sarthe formed and believes aid thereon alleges that Hot Bench continues to air on television, 5 3 21. Inor about December 2014, Plaintiff discovered an envelope conta ga disc ina 26 | box that Douthit was having seat to storage. When Plaintiff opened the dise and printed out the 27 | contents, she discovered « written “treatment” for a court-genre television program with the 28 || working tile Legal Eagles. ‘The cover page of the treatment reflects a calendar year of 2005 and 25 COMPLAINT ‘Dock 1 Fage# 5 — Doo 1D = 1704203013 - Doo Type = OTHER rage 6 of 30) 1 | contains the following statement above the date: “Created by Randy Douthit” In November 2 | 2016, while going through a box of what looked like Douthit's business documents, Plaintiff 3 | discovered four additional typewritten treatments of Legal Eagles. The cover page of each of 4.| these additional treatments reflects a calendar year of either 2005 or 2006 and similarly states 5 | “Created by Randy Douthit A 2006 treatment describes a 30-minute program in which @ pane] 6 | of three judges, one of which is an attorney, would hear evidence on multiple éases with 2 7 | comunon theme, deliberate in chambers, and render a verdict in front of alive studio audience. | 8 | (The 2005 and 2006 teatments collectively ate referred to herein asthe “Treatments” | 9 22, Plaintiffs informed and believes and thereon alleges that Douthit conceived of| 10 | and created the Legal Eagles project during his marrige to Plaintiff. Douthit’s conception and 4. < _ II] development of court-genre television program during his marriage to Plaintif, including the i L i 12. | Treatments he prepared, were community assets or opportunites in which Pleimiff ad a at q i 13 | community interest. Plaintiff ig further informed and believes and thereon alleges the court-genre ral 14 | television projector projects developed by Douthit during his marriage to Plaintiff constitate an # 1-15 | investment opportuity of asset, business opportunity or asset, or other incame-producing, 16 | opportunity or asset, Doutht, however, did not disclose any such opportunity or asset in the 17 | Dissolution Action. 18 23, Plaintiffs informed and believes and thereon alleges that the Hot Bench program 19 | was created in whole or in part by Douthit and/or RD and/or DPL from or pursuant to the Legal 20 | Eagles project, or some other projet in which Douthit and/or RD and/or DPL had a proprietary 21 | interest, as provided in or under the terms ofthe Big Ticket Agreement, and in whieh Plaintiff had 22 | community interest. Douthit has never disclosed to Plaintiff the existence of that community 23 | asset, or that he should receive, has received, or will receive valuable consideration for it. _ 0 24. On December 9, 2015, Plaintiff led a motion in the Dissolution Acton to deem =! 25 | the Legal Eagles treatment discovered in December 2014 as an omitted asset. Plaintiff is ® 26 } informed and believes that Douthit has falsely stated under penalty of perjury in the Dissolution | © 27 | Action thatthe Legal Eagles treatment discovered by Plaintiffin December 2014 was not created | : 28 | by Dowthit. l iret ‘COMPLAINT ‘bool 1 bageh § ~ Doo FO = 1704203013 ~ Doo Type = OTHER (age 7 9f 30) FIRST CAUSE OF ACTION (Breach of Quasi-Contract Against All Defendants) 25. Plaintiff realleges and incorporates in this cause of action the allegations set forth 5 | inparagraphs | through 24 of the Complaint as though fully set forth herein. 6 26, Plaintiffs informed and believes that Douthit submitted his Treatments, ideas, 7 |, and/or the propriety interests they contained, andlor other substantially similar property created 8 || and developed during his marriage to Plaintiff, to some or all of the other Defendants, or to such 9 | Defendants’ agents, assignees, or predecessors-in-interest, and that such Defendants, or their | 10 | Defendants” agents, assignees, or predecessors-in-interes,feccived them, | EN \ z W 27. Plaintiff is informed and believes that the Treatments, ideas, and/or the propriety. Bll 12 | interests they contained, and/or other substantially similar property created and developed during : He 13 | Douthit’s marriage to Plaintiff, submitted to some or all of the other Defendants, or to such Et i 14 | Defendants? agents, assignees, or predevessors-i-interest, were the community property of #2815 | Plainiffand Dou 16 28, Plaintiffs informed and believes tat before Douthit submited his Treatments 17 | andor the propriety interests they contained, or éther substantially similar propriety interests 18 | created and developed during his marriage to some oral of the other Defendants, such 19 | Defendants, or their agents assignees, or predecdssors-n-intrest, knew or should Fave known, 20 | through Douthit's statements, conduct or otherwise, that that such submission and disclosure had 21 | value and were or should have been conditiéned on such Defendants’ agreement, or that of their 22. | agents’ assignees’, or predecessors-in-interes’s agreement, to fully compensate and pay for any 23 | use of the Treatments, ideas, and other matters or property submitted and disclosed to them, 29. Plaintiff is informed and believes that atthe time of the submissions, Douthit did not disclose to the other Defendants the existence of PlaintifPs community property interest in such submissions. Plaintiff is informed and believes that the Defendants to whom the submissions were made obtained the submissions through mistake, fraud, or other tortious, illegal, or. actionable conduct. “T+ ‘COMPLAINT ‘Doo 1 Paget 7 ~ Doo 1D = 1704203813 - Doe Type * om rage & of 30) 30. Plaintiff is informed and believes that in developing and writing the television show Hot Bench, Defendants, or their agents, assignees, or predecessors-in-interest, actually used the Treatments, ideas, and/or the propriety interés they contained, and/or other substantially similar property created and developed during Douthit's marriage to Plaintiff, and that Hor Bench is based substantially on the Treatments, ideas, and/or the propriety interests they contained, andlor other substantially similar property created and developed during Douthit's marriage to Plaintiff, which Douthit submitted to the other Defendants. _ 31. Pla informed and believes thatthe Treatments, ideas, andlor the propriety interests they contained, and/or other similar property created and developed during Douthit’s 10 | marriage to Plaintiff, had value. ' i 32 Defendants did not fully compensate aid pay Plaintiff for her community interest i 12 | in the Treatments, ideas, and/or the propriety interests they contained, and/or other substantially | 13 | similar property created and developed during Douthit’s marriage to Plaintiff, that Douthit 14 | submitted to the other Defendants. Plaintiffs informed and believes that Douthit was not fully seu. ramen a oun. 15 | compensated and paid by the other Defendans forthe submitalsor that he received less tha a 16 | fair and reasonable value for them. 7 SECOND CAUSE OF ACTION . 18] (Co Set Aside Transfer of Community Property Interest Without Spousal Consent Against All 19 Defendants) 20 33. Plaintiff realleges and incorporates in this cause of action the allegations set forth | 21 } in paragraphs 1 through 32 of the Complaint as though filly set forth herein. 2 34. Plaintiffs informe and believes that Douthit submitted his Treatments ideas, 23 | andor the propriety interests they contained, andlor other substantially simila property created 24 || and developed during his marriage to Plaintiff, to some or all of the other Defendants, or to such ~ 25 | Defendants’ agents, assignees, or predecessors-in-interest, and that such Defendants, or their %, 26 | Defendants’ agents, assignees, or predecessors-in-interest, received them, Soa 35. Plaintiffs informed and believes that the Treatments, ideas, and/or the propriety 28 | interests they contained, and/or other substantially similar property created and developed during 8 ‘COMPLAINT ‘Doct 1 Page# @ - oo ED = 1704203812 - boo Type = oneER tage 9 of 30) 1} Douthit’s marriage to Plaintiff, submitted to some or all ofthe other Defendants, or to such 2 | Defendants’ agents, assignees, or predecessors-in-interest, were the community property of 3 | Plaintiff and Douthit 4 36. Plaintiffs informed and believes that before Douthit submitted his Treatments 5 | andlor the propriety interests they contained, or other substantially similar propriety interests 6 | created and developed during his marriage to some or all of the other Defendants, such 7 | Defendants, or their agents, assignees, or predecessors-in-interest, knew or should have known, | 8 | through Douthit’s statements, conduct, or otherwise, that that such submission and disclosure had 10 | agents’, assignees’, or predevessors-in-inteest’s agreement, to fully compensate and pay for any 11 J use of the Treatments, ideas, and other matters or property submitted and disclosed to them, 12 37. Plaintiff is informed and believes that at the time of the submissions, Douthit did 13 | not disclose to the other Defendants the existence of Plaintiffs community property interest | 9} value and were or should have been conditioned on such Defendants’ agreement, or that of their | 14 | such submissions. Plaintiff is informed and believes that the Defendants to whom the submissions 15 | were made obtained the submissions through fake, fraud, or other tortious, illegal, or able conduct, : 7 38. Plaintiffs informed and believes that in developing and writing the television 18 | show Hot Bench, Defendants, or their agents, assignees, or predecessors-in-interest, actually used 19 | the Treatments, ideas, and/or the propriety interests they contained, and/or other substantially 20 | similar property created and developed curing Douthit’s marriage to Plaintiff, and that Hot Bench 21 | is based substantially on the Treatments, ideas, and/or the propriety interests they contained, 22 | and/or other substantially similar property created and developed during Douthit’s marriage to 23 | Plaintiff, which Douthit submitted to Defendants. 4 39. Plaintiffs informed and believes thatthe Treatments, ideas, and/or the propriety S25 | interests they contained, and/or other substantially similar property created and developed during S26 | Douthit's marriage to Plaintiff, had value. 40. Defendants did not pay Plaintiff for her community interest in the Treatments, ‘ideas, and/or the propriety interests they contained, and/or other substantially similar property -9- COMPLAINT Doct 1 Faget 9 - Doc ID = 1704203813 ~ Doo mype = crMER @age 10 of 30) 1] created and developed during Douthit’s marriage to Plaintiff, which Douthit submitted to 2 | Defendants. Plaintiff is informed and believes that Defendants either did not pay Douthit for the 3} submittals or paid him less than the fair and reasonable value for them. 4 41, Plaintiffs informed and believes that Sheindlin, HHI, Queen Bee, DPL, and DOE 5 | Defendants 1 through 25 conspired with Douthit to acquire and covert the community property of Plaintiff. 42,. Plaintiff asks the Couct to set aside the transfer of Plaintiff's one-half community interest made without Plaintiff's consent or authorization as alleged above, deem Defendants, 9 | constructive trustees of such community property, and direct Defendants to return to Plaintiff her 10 | one-half interest in such community property, together with all assets acquired with such 11 | community property, and all profits and rents, therefrom, # gub 12 THIRD CAUSE OF ACTION Hy sig 3 (For Conversion Ageinst All Defendants) BUS 4 43, Plaintiff realleges and incorporates in this cause of action the allegations set forth iPal Z* 34 15 | in paragraphs ! through 42 of the Complaint as though fully set forth herein. 16 44, Plaintiff is informed and believes that Defendants, and each of them, converted the 17 } community property of Plaintiff, including without limitation: (a) the Treatments; and/or (b) the 18 | ideas, and/or the propriety interests they contained; and/or (c) other substantially similar property 19 | created and developed during Douthit’s marriage to Plaintiff 20 45. Plaintiffs informed and believes that by engaging in the conduct alleged above, 21 | Douthit breached his fiduciary duty to Plaintiff with respect to the management and control of 22 | community property including, but not limited to, Legal-Eagles and other proprietary interests. B 46. Plaintiffs informed and believes that Sheindlin, HHT, Queen Bee, DPL, and DOE 24 | Defendants 1 through 50 conspired with Douthit to deprive Plaintiff of her community property. 25 47. Plaintiffs informed and believes that she has suffered, and will continue to suffer, 26 | damages within the jurisdiction of this Court. 27 48. At the time of the conversion, Plaintiff had the immediate right to possess her one- 28 || half community interest in the community property converted. =10- | COMPLAINT oct 1 Paget 10 - Doo 1D = 1704203625 ~ Doe type = OTHER (@age 11 of 30) mmgcganmen emus sr e 49, Asadirect and proximate result of Defendants? wrongful acs, Plaintiff is informed and believes that she has suffered and will continue to suffer damages within the jurisdiction of this Court in an amount to be proven at trial, 50, Plaintiffs informed and believes that by engaging in the conduct alleged above, Defendants acted willfully, wantonly, and/or with reckless disregard within the scope and ‘meaning of Civil Code section 3294 and/or Family Code section 1101(h).. FOURTH CAUSE OF ACTION (Breach of Fiduciary Duty Against Douthit) 51. Plaintiff realleges and incorporates in this cause of aetion the allegations set forth in paragraphs { through 50 of the Complaint as though fully set forth herein, 52. Plaintiffs informed and believes that by engaging in the conduct alleged above, Douthit breached his fiduciary duty to Plaintiff with respect to the management and control of community property including, but not limited 16, Legal Eagles and other proprietary interests 53. Asa direct and foreseeable result of Douthit’s breach of fiduciary duty, Phaintff has suffered damages in an aniount according to proof within the jurisdiction of this Court 54, Plaintiffs informed and believes that by engaging in the conduct alleged above, Douthit acted wilfully, wantonly, and/or with reckless disregard within the ambit and meaning of Civil Code section 3294 and Family Code section 1101(h). FIFTH CAUSE OF ACTION (Aiding and Abetting Against All Defendants Except Douthit and Big Ticket) 55. Plaintiff realleges and incomporates in this cause of action the allegations set forth in paragraphs | through 54 of the Complaint as though fully set forth herein, 56. Upon information and belief, Defendants aided and abetted Douthit in the conversions and breaches of fiduciary duty alleged above, 57. Upon information and belief, Defendants provided substantial assistance and ‘encouragement to Douthit in the conversions, breaches of fiduciary duty, and other unlawful conduct alleged above. oie COMPLAINT oot 3 Paget 31 - Boe XD = 1704203013 ~ Cee fype = oR wage 12 of 30) 1 58. Plaintiffs informed and believes and thereon alleges that when Defendants 2 | provided such assistance and encouragement to Douthit, they knew that Douthit’s conduct was 3 | unlawful 4 59. Based upon the conduct of Defendants, Plaintiff is entitled to an award of damages 5 | in.an amount according to proof within the jurisdiction of this Court. 6 60. Plaintiffis informed and believes that, by engaging in the conduct herein alleged, 7 | Defendants acted willfully, wantonly, and/or with reckless disregard within the ambit and 8 | meaning of Civil Code section 3294. 9 SIXTH CAUSE OF ACTION 10 (Money Had and Received Against All Defendants) i 61 Plaintiff realleges and incorporates in this cause of action the allegations set forth 12 | in paragraphs 1 through 60 ofthe Complaint as though fully set forth herein, 62. Asaresult ofthe facts alleged above, Defendants became indebted to Plaintiff for 14 | community funds and community property of Plaintiff in amounts unknown to Plaintiff but 15 | believed to be within the jurisdiction ofthis Cour. 16 63. Plaintiff has not received the money Plaintiffs informed and believes is owed to 17 | her by Defendants 18 64, Plaintiff is informed and believes there is now due and owing the sum of an 19 | amount unknown to Plaintiff but believed to be within the jurisdiction of this Court. 20 SEVENTH CAUSE OF ACTION : 2 (Unjust Enrichment Against All Defendants) 1 n 65. Plaintiff realleges and incorporates inthis cause of action the allegations set forth | 23 | in paragraphs 1 through 64 of the Complaint as though fully set forth herein. 66,” Plaintiff is informed and believes that as a result of the facts alleged sbove, Defendants have received community property, assets, and funds that were provided by Douthit without Plaintiff's authorization or consent and bave wrongfully converted such community property, assets, and funds to their own use. -12- ‘COMPLAINT oot 1 Pago# 12 ~ Deo 1D = 1704203813 ~ Doe aype (tage 13. of 30) 1 67, Plaintiffs informed and believes that Defendants have unjustly retained the 2 | benefits of community propery, assets, and funds of Plaintiff that were transferred without 3 | Plaintiff's authorization or consent. 4 68. Asadirect and proximate result of Defendants’ conduct, Plaintiff has suffered 5 | damages in an amount unknown to Plaintiff but believed to be within the jurisdiction ofthis 6 | Cour, Further, PlaintifF is informed and believes that Defendants have been unjustly enriched as 7 a direct and proximate result of the conduct alleged above. 8 EIGHTH CAUSE OF ACTION 9 (Accounting Against All Defendants) 10 69, Plaintiff realleges and incorporates in this cause of action the allegations set forth 11 | in paragraphs 1 through 68 of the Complaint as though fully set forth herein, dus 12 70. Plaintiff is informed and believes that as a result of the facts alleged above, ay a 15 | Defendants have received community property, assets, and funds that were submitted and u a 14) provided by Douthit without Plaintiff's authorization or consent and have wrongfully converted #24 15) such community property, assets, and funds to their own use. 16 7 Plaintiff is informed and believes that Defendants have unjustly retained the 17 } benefits of the community property, assets, and funds of Plaintiff that were transferred without 18 | Plaintii's authorization or consent. 19 72. The exact amounts of Plaintfs community property transferred to Defendants or 20 } for their use or benefit or use, and the amounts of funds and other bereft derived from them, are 21 | unknown to Plaintiff at this time and can determined only through an accounting. Plaintiff seeks : 22 | an accounting of all her community property transferred to Defendants or for their use or benefit, 23 | and the amounts of funds and other benefits derived from them, m4 NINTH CAUSE OF ACTION 1 3 (Declaratory Relief Against All Defendants) 6 73. Plaintiff realleges ang incorporates inthis cause of action the allegations set forth 27 | in paragraphs | through 72 of the Complaint as though fully set forth herein, 28 -13- COMPLAINT ‘Doot + Page# 33 Boo 1D = 2704203013 - Doe Type = orn rage 4 of 30) ' 1 74, An actual controversy and/or dispute has arisen and now exists by and between 2.| Plaintiff and defendants, and each of them. 3 75. Plaintiff contends: (1) she has a community interest in the assets or opportunities, as described above, including, without limit, the income, revenue, profits, benefits, or other 5 | valuable consideration obtained therefrom; (2) she has a community interest in the investment opportunities or asses, business opportunites or asels, or other income-producing opport 6 ies 7 | orassets as described above, including, without limit, the income, revenue, profits, benefits; or 8 | other valuable consideration obtained therefrom; (3) Douthit failed to disclose in compliance with 9 | applicable law the community assets as described above; (4) Douthit failed to disélose in (0 | compliance with applicable law the investment opportunities or assets, business opportunities or 11 } assets, or ther income-producing opportunities or assets as deseribed above, (5) Plaintiff is 12 | entitled to her interest according to law in the assets or opportunities as described above, 13 } including, without limit, the income, revenue, profits, benefits, or other valuable consideration 14 | obtained therefrom, and (6) Plaintiff is entitled to her interest according to Jaw in the investment ue pana a ouRRIL LUP 15 | opportunities or assets, business opportunities or assets, or other income-producing opportunities 16 | or assets as described above, including, without limit, the income, revenue, profits, benefits, or 17 || other valuable consideration obtained therefrom, 76, Plaintiff further contends thatthe transfers of her community property alleged 19 | above are void in whole or in part because they were done without Plaintiff's authorization o 20 || consent and done as gifts, for no value, or for less than fair and reasénable value, 2 71. Plaintiffs informed and believes that defendants contend to the contrary. 2 78. Plaintiffrequests a judicial determination of her disputes and of Her rights and title 23 } to, and interests in, all community property transferred to Defendants or to Defendants? agent, 24 | assignees, or predecessors-in-interest. 2 Tos 79. A judicial declaration is necessary and appropriate at this time under the © 26 | circumstances in order that Plaintiff may ascertain her rights and interests according to law. S70 PRAYER FOR RELIEF 28 WHEREFORE, Plaintiff prays for judgment as follows: -14- COMPLAINT ‘Boot 4 Bags 14 ~ Doc 1D = 1704209619 ~ Doc Type = om age 18 9f 30) 149 (1) Fordamages according to proof, Q) — Forpunitive damages; G) _ Fordeclaratory relief as requested above; (4) For reformation andlor specific enforcement; (5) Fora constructive trust over Plaintiff's portion of the community property, including all rents, revenues, and other benefits generated therefrom; (6) Foranaccounting; (1) Fordisgorgement, (8) For interest on damages in accordance with applicable law, (9) For costs of suit; (10) For attoreys’ fees in accordance with applicable law including, without limit, Family Law section 1 101, subseetions (g) and (a); and (12) For such other and further legal and equitable relief as may be permitted under applicable law. DATED: July 244°, 2017 HILL, FARRER & BURRILL LLP (SH A iam A. Whi Attorneys for Plaintiff, PATRIC JONES Ha aoaeson2002 218- ‘COMPLAINT Dock 2 Faget 15 ~ Doc 1D = 170#203813, + Doe type = oman age 16 of 30) ‘book 1 Pagoh 26 ~ Doo 1D ~ 1704203813 ~ Dee Typo = ommER (eage 27 of 30) DONESTICTELEVISION” 4 * ‘Telesision Distcbation Division : |. Theodosopoulos | 5355 Malone Avenue : _ Bret Pretine Hollsciad, CA SUOS3097 Tae ase Afar Legal : MST : Doniestic elrision Fx amnertins | ditanspovboontijoronvantens April 21,2006 , Steve Sooke 1° GreativeAntists Agensy >. re ‘ x 9830 Wilshire Bld ° + : Beverly Hils,CA 9021 ‘ 7 : Re: JUDGE JUDY: Agreeiment with Douthit Productions, Led: “dated January 16,"1998 {isio Randy Douthit.~ Amendment dated March 7, 2006 -- REVISED Dar Steve: ie er ‘Enclosed plessefind two (2) originals of the above-referenced emendnient Af you have had “sn opportunity wo feview the document, please have bot onginals signed and enh them to me for sountersignature on behalf of Big Ticket; thereafter, Iwill ed you uly signe orginal Tor your files. you have day questions please do not hesitate to call me. Very tly Yours, et David J. Theodosopavios : 7 pits 7 ° : i ‘A DIVISION OF CBS STUDIOSINC. Kh ‘Doct 1 Fagoh 37 - boo To = 1704208818 ~ Doo Type = one (rage 18 of 30) 8 ¥ Z19te + elo Steve Smacks! ae * Productions, Ld. ("Lender") forthe services of Randy Doutht [Mareh 7, 2006 ie hea Doin Prodoctions, Lid. . i ; Creative Arsts Agency . Pas ‘9830 Wilshice Blvd a ae ; Beverly Hils:CA' 90212: : = Rei, _JUDGE JUDY.-- Toltom Miy Cone: Reference is made fo th ageemat dated as of Jantar 16, 198, ss ainnded sof April 22,1999; Apa 13,2001, Apsil 24, 2002 and March 12,2004 (the “Agrecinen”) between Big Ticket Pistre, tne, Big Ticket") and Godt ist" connection withthe sts JUDGE JUDY. (ihe “Series. terms defined in the AGrecient shall have the’ same meanings whén used ia this amendment. Bi Ticket and Lender hefeby greet amend the Agreements follows eae “ 2 1: Big Ticket hereby ares to engage Lier and Lender hiveby agrees ace such eaggemt'o provide ‘Art's services as an Execive Poduet ard Dive for lew prograns ofthe Seres produced othe“) > ‘20062007 and 200772008 browdcast seasons. Art's Executive Producer and Director sevice onthe Serie,» shal commanee on tf be designed by Big Ticket nd continent competion ofall eee routed by Big Tike for eich such Broads sas, Big Tike shal ave two (2) consecutive, depeedent,ensal tions (the "Option()") to conte to engage Lender 15 provide Ants servis san Eeue Prodaer, = and Dictor for all ew programs pioduced fr each ofthe 20082009 ard 20092010 broad setsor. Each Sch Option shall be exercised by Big Ticket, if a all, on or before March 3-of the immediatly preoeding ‘broadeast season, eet . 2, _In fll Consideration forall services rendered by Amst as provided by Lender ‘ail righis oraied 16 Big’ Ticket by Lender pursuant to this amendment; Big Ticket agrees to pay Lender, and Lender agrees to accept, the following compensation Poh agae ok For each week of five new ¥ hou programs produced by Big Ticket for which Aftist enders ind complete at ‘equied services and provided Lende® stid/or Artisti nt in breach of any meteil tem hereunder, Big Ticket: shall pay Lender compensation in accordance withthe schedale set fih below (ero rated for:any partial weeks), Such compensation chal inelude payment for al incidental services and hold periods as ell as services performed by Artist on holidays, Soturdays and Sundays (any): : $360 pe week of fe new papas iced 7 Shea ge werk of Ivenew popanspodieed 0% $36,551 per week of five et programs produced’ 20092010 36551 per nek of ve ex prog routed - ‘o06n200 36078 pecweek of five ew progiars prodded 5 20072008: 6078 per week ove ew poses probed <>» $6381 pee week of five new programs produced”: 5 20037200 6381 per werk ve new progr proved 3.” Nonwitstadng the exclusivity se font in thé Agreement, Big Ticket snd Lerder hereby ape tht Léndet or ‘Artist shall have the right o stat up a production company, and Artist shall have the right to provide Artists serines fo seth prodution company; provided, however, such rodiction company sal not be woe a= - ‘Doo 1 Fagen 19 - Boo 1D = 1704202812 ~ Doo Type = OnE age 19 of 30) ede . Randy Douthit Mae, 2006 Page? the developmen, prouction cr distibution of cour-gece pogsning, with the exceiion of cour gi a rogranming for primetime subject to Judge Judith Shinn’ pir approval. Big Ticket shall hae Tr” calls pioity over Anis’ services, and Aris iy not render services fr such proton eomgany int ‘manner thit wil interere withthe rendition of Att’ services heveudes,, In Ve event Ua Judge Jad) Sheinglin aid Big Ticket determine tha Ariss services In connection orth sch podtion conway are” eee withthe rendition of Ars ervces hereunder, Big Ticket shal have the gh -Fight to provide services to such production company, # 7 a é With respeet'to aay project in whic Artist or Lender or such production company holds proprietary intredt: ‘Arist shall present exclsively to Big Ticket, or is designee, such project fer consideration fot a period of tiny (30) days and Big Tickel, or its designee, shall have the exclusive ight, but not the obligation, to move forvard to develop, produce endo dstbote any such project. In the-event that Big Ticket, or is designee, t ‘ernionently pases On oF abandons a project submited hereunder (.e.: Big Tickel elects not to proceed with 9” ° = : roject or permanently terminates a project inthe course of development), Artist shall have the fight to expleit” = 1 andlor tke the projec.o a tid party no less than tiny (30) days afer Arist presents such Projet to Big... 5 ‘Ticket or is designee; provided, however, Big Ticket, o As designee, shal ean alien for al direct, out-of {~ Ocket costs expended by it, or its designee, such projet: which len shall be payable by Lender and/or Artist over the course ofthe first production year fiom frst. monies expended by dhe third-party on such project * Provided that Big Ticket or its designee elects to produce any project developed by: Lendér or Artist or stich’ 5 Btoduction company under this Agreement, he pats shall ene ino pood faith negotistions. with respect 1 Lender's oF Artist's services in connection wit such poet i cep af mode erin, oes ed candtns thé Agremen a hereby ried nd fran il es sndete : ; If this tener acesely reflects your andra of our agreement please so indicate by signing inthe space povided ‘below and retring both originals for coantr-exceution by Big Ticket. : Ver tly yours; BIG TICKET PICTURES, INC. David Theodosopoulos : . Senior Viee President” 7 ; ‘Business Affsirs& Legal ACCEPTED AND AGREED 16: FOUL berE8. FATVRFEaeD sage Jj Doubt wind 20060400 4 : ovis oct 1 Faged 39 ~ Bee 1D = 3704202813 ~ boo "ype = OTHER fwage 20 of 30 Marth 7, 2006 Douiit Productions, Lad. . 7 LEEBRS clo Steve Smooke" | : tee 5 SGreaive Anists Ages ‘©9830 Wilsbite Blvd i: " Beveily “Te Wom I May Concern: . 7 : Reference is made to the agicemént dated as of January 16; 1998, a anended of Apil 22,1989, April 13, 200%, Pe 2 2002 and March 12,2008 (ie “Agreenen”) between Big Ticks Pictures, se, ("Big Ticket) and Dau» “=> of (ota, Lt (ede) for htservices of Randy Doth (“Amit n connection withthe Series JUDGE JUDY 2 {ite "Seres, Al terms defined inthe Agfeement sal ave te same means when used i this afenden..Big 5 Tickerandl Lender herby agree to amend the Agreement as fallow! ee Re: JUDGE JUDY -~ Agréeinen win Doitié Productions; Ld so Randy Déuthit ns i | i +: Big Ticket heccby agers t'engage Lender and Lender hereby agrees to accept such engagemeiy, to pie Atst's services as an Executive Producer and Ditector fot all new roams ofthe Sees prodsed for te 209672007 asd 200772008 broadcast eaions. Ants Executive Producer an Director series oa the Sens 2 <5, “fallenimence ons dt tbe designed by Big Tit and concent conpletin of al serves qed “by Big Ticket fot cach such bosdcast season. Big Ticket stall lave to (2) consecutive, dependens seca ‘pts (he. “Oion()") to connie to engage Lender to provide Aniats services san Enevulve Producer 4nd Diccior fo al new. prograns produced foreach ofthe 20082009 and 2005/2010 broedest stone Each, + uh Option shall be ekeiised by, Big Ticket, if at allo or before Marc: 31 of he iediaiely preding broadeast season, 7 oo : 2, fl ect esis nee yA pide by Lei wi ah pnd i igs Tike ty Lender sua’ ahs arent, Big Ticket ages fo pay Lente an Leet ogee 1 sooo ‘the following compensation: i ‘ pe Foreach week of ive nw shou pogras produced by Big Ticks ot which Artis venders ad eotpleie all © > #2 sequied services and provided Lender and/c Ariss nt in bese ny mali eam hereunder, Big The ‘stall pay Lender compensation in accordance withthe schedule et fort below (pp rated for any pata wees), Such eompersaton shall iclde payment forall ideal eeviges ‘and fold prio’ well as services performed by Arist on tlidays, Saudaysand Sundays (ifany)s 7 Bee Execuive Poder: : ee i 7006/2007 534810 perweckof Gv new programs prdused 2. oorroas: 534.10 pecwoek five rew programs produced. é Options: 5 : 2 Sante ‘ 200872008: 536,51 per wot five neve ogra jroced > 20097200.. 336,51 per wesko ve ne rogram produced : eter a peat oa 2006/2002 $6078 per week of ve new rograis produced 00772008: 5607S per neck of five new rogram produced S “Option: 7 & 2008/2000 $6381 pe wee five new programs produed = 200872010: ‘6381 pr week of ie nev propos prods SS, 3, Novwithstandig the exetsiviy set forth in the Agreement, Big Ticket and Leider bey age tht Lender of “1 Asal have te rgh to tat up a reduction company, ad Aris sll ave te ight provide Ai Serviees lo such production company provided, however, such production compaty shall not be involved ,! ‘Dooh 1 Paget 20 ~ Doc 1D = 1704202813 ~ Doe Type = om ago 21 of 30) the develope, producti ot dbo of cour-geepropramnin, with I expo of ean en! ~ co» -Roguning fot pnting sab o fdge Idi Shen's proc ppoal Big Tit shal re Te aoe callie pity over Arist’ Services nd Anis nny ot render series fr stehprodueton company tr ‘wane that wil interfere with the rendition of Art's services hereundei 15 the even tat Judge to: Stina and Big Ticket detamaine ht Art's seives in ennecton wilh 3h prosution cansaiy oe : + -itrrng withthe rendition of Artists services iceberg Ticket shall ve the igh to temizoy, aoe Tight provide services to such production company. s nt Wit cespeetto any projet in which Arist or Lender or such production conan bos» peoptitry ders Artist shall present exclusively to. Big Ticketor is designee such projet for csideration for fried ef thirty QO) days and Big Tike, or is designs, sal have the exchisive ight, but nt the obligation ae {onward develop rodose ands db sny sich projec. In the evet tha Big Tihs otis dence, Bermaneily passes oc of abandon a project subnited Perende (Big Ticket leis otto proceed ithe ojest ox permanent teminatesapojectin the couse of developmen, Anti sal have the right toeiplet : nlf tke the projet to hid pay no lest han thirty (30) as aie Ail present such Poet tig | : Ticket or its designes; provided, however Big Tcke: or its designe shall ean efor ll dinetsoue oe | Borkct costs expended By i, os designee, on such proj, which en sal be payable By Leni aly 2; Ae ve th sou ote fst diction yu fom es nis eee 8) hth py en mh “5 Provided shi Big Ticket ort esgne eles to robes any post devekped by Lene cé. Arlo ich roductoncompény under this Agreement, the pies shal ett ito good fh nepoitons wilh rapt Lender's or At's services in connection wih sch projet. * : Beet as mdi tinal tens anion eae by ated enn oad sand effet, * * wr Z . “his leer accuriely reflects your urdesanding of our ‘ageemin, ples 5 indie by siing in he space. paved 2.3 elwand cing ot orga oecouner ection y ig Teel aaa Soy + Neal yous, : ©. “BIGTICKET PICTURES, wc. By a Bes “ ’ David) Thessapoies : ei ait Senioe Vice Pesident eau siete Bisiness Alar 8 Lea : fond ‘ACCEPTED AND AGREED To: pete EFATVAFFAROevotae Jic/ Dou mine 20068 do oct 2 Faget 21 - Boo 1D = 1704208813 ~ Loo Type = onwcn age 22 of 30) LTR Pz720 ‘Doct 1 Paget 22 - Doo 1D = 17042088:3 - Doe Type = OTR

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