WNIDSTHO i BY. FA 28 KASOWITZ BENSON TORRES LLP JOHN Y. BERLINSKI (SBN #208537) jberlinski@kasowitz.com i CHRISTIAN K, WREDE (SBN #268307) cwrede@kasowitz.com 2029 Century Park East, Suite 2000 _ Los Angeles, CA 90067 ‘Telephone: (424) 288-7900 Facsimile: (424) 288-7901 Attorneys for Plainiiff Katie O'Connell Marsh SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT KATIE O'CONNELL MARSH, an individual, Plaimif, GAUMONT TELEVISION USA, LLC F/K/A GAUMONT INTERNATIONAL TELEVISION, LLC; and Does 1 through 20, inclusive. Defendant. i) FILED | Hoe Cayrt t Galion Countyol Los Arter JAN 26 2018 Ste Caer, Expo Otaecin olan oes Deputy CASE NO. BC69}790 Amendeh— COMPLAINT FOR: 1. Declaratory Relief; 2. Breach of Contract; and 3. Breach of the Implied Covenant of Good Faith and Fair Dealing. DEMAND FOR JURY TRIAL 0Sb ‘COMPLAINT ooh 1 Fagot 1 ~ Doo 3D = 1727368266 ~ Doe Type = on(age 2 of 39) 1 Plaintiff Katie O'Connell Marsh, demanding a trial by jury, alleges as follows 2 1. GENERAL INTRODUCTION 3 1. In 2010, afier successful runs in senior development roles with two high-profile 4 | television companies, Plaintiff Katie "Connell Marsh joined forces with Gaumont SA, a film 5 | studio based in Paris, France, to launch a new television studio in Los Angeles, California called 6 | Gaumont International Television, LLC (“GIT”), focusing on the production and distribution of 7 | high-quality television programming for a global audience. 8 2. Asa veteran television executive, Ms, O°Connell Marsh knew the risks (the 9 | overwhelming majority of start-up studios fail, as do the overwhelming majority of television 10 | shows), but took a chance as GIT’s first CEO—and first employee—because she saw an 11 | opportunity to build a new kind of television studio and to participate financially more fully than 12 | she could at established studios in the success of the television series she developed. B 3. Ms. O'Connell Marsh’s willingness to take a risk was reflected, by design, in her 14 | initia three-year employment agreement, under which she took less guaranteed compensation in 15 | exchange for greater incentive and contingent compensation, including a 2.5% share of the gross 16 | receipts derived from each television series produced by GIT and distributed in the U.S. while she 17 | was employed by GIT, minus a few agreed upon deductions. ‘The partes referred to this 18 | contracted-for share of gross receipts as “Modified Adjusted Gross Receipts,” of “MAGR.” 19 4, In 2013, GIT signed Ms. O’Connell Marsh to a second three-year term as CEO, 20 | and the following year, the Hollywood Reporter recognized het as one of the 100 most powerful 21 | women in entertainment, noting her role in developing a number of successful new series for GIT 22 | and stating that under her leadership, GIT bad “kept a tight focus on getting scripted fare on the 23 | air and bypassing the traditional development cycle.” = 24 5. ‘Ms. O'Connell Marsh did not receive a salary raise in connection with this second % 25 | term of employment, but instead secured various enhancements to her incentive and contingent S26 | compensation, including an increased share of MAGR—from 2.5% to 3%. on 6. 1n2015—about a year before her second term as CEO was to expire—GIT 28 } eliminated Ms. O'Connell Marsh’s position in connection with a corporate reorganization in “esoane tor ale me COMPLAINT oot 4 Pages 2 - Boa ID = 1727368266 - Doe Type = OnIERage of 39) 1 || which, on information and belief, GIT was renamed Gaumont Television USA, LLC 2 | (’Gaumont”) 3 7. Innegotiating her separation agreement ("Separation Agreement"), Ms. O°Conzell 4 | Marsh again placed an emphasis on her incentive and contingent compensation, securing, inter 5 | alia, an MAGR provision 10 8. The television series Ms. O”Connell Marsh developed for GIT have generated 11 | substantial gross receipts, due, in large part, to innovative development and licensing strategies 12 | Ms. O’Connell Marsh helped pioneer as GIT’s CEO. 3 9. Hannibal, which is widely recognized as one of the best horror gense television 14 | series of ll time, ran for three seasons on NBC. 1s 10, Hemlock Grove also ran for three seasons and was the second original series ever 16 | commissioned by Netflix. "7 11. Fils for Family is now entering its third season streaming on Netflix, 18 12, And Nareos, which is going into its fourth season on Netflix, was nominated for a 19 | Golden Globe for Best Television Drama in 2016, took the award for Best Drama Series at 20 | Mexico's prestigious Fénix Film Awards in 2017, and has been described by Variety as a “world- 21 | wide mega hit.” On information and belief, analysts estimate that Narcos pulled in more than 27 22 | million viewers in the United States alone in 2017, making it the 7th most popular television 23 }) series domestically across all platforms last year. ry 13, Moreover, on information and belief, Geumont has not produced any new & 45 | television series inthe two years since Ms. O’Connell Marsh’ position was eliminated, 2 2% 14. Thus, Ms. O’Connell Marsh not only put GIT on the map in the television 47 | industry, but the series she developed as GIT’s first employee remain the comerstone of 28 | Gaumont’s television operations to this day quate 2. oan COMPLAINT oot 1 aged 2 - Doo ID = 1727368266 - Doc Tyee = onmRrage & of 39) 1 15, Unfortunately, while Ms, O'Connell Marsh did precisely what she promised to 2 | do—develop successful television programming while building GIT from the ground up— 3 | Gaumont failed to bold up its end of the deal and has, instead, resorted to shifty calculations that 4 | bear no resemblance to the terms of the MAGR provision in her Separation Agreement to deprive 5 | Ms. O'Connell Marsb of millions of dollars in bargained-for contingent compensation, 6 16. In fact, while on information and belief Gaumont has received substantial gross 7 | receipts from the projects Ms. O'Connell Marsh’s developed, Ms. O’Connell Marsh bas yet to 8 | receive a single MAGR payment in connection with any ofthe series she brought to the screen, 9 17, Ms. O'Connell Marsh therefore brings this action, out of necessity, to enforce the 10 | promises GIT made to her atthe time of her separation—and that Gaumont as GIT"s successor 11 | as failed to uphold—as to her MAGR interests and to recover many millions of dollars due to 12 | her under the plain language of her Separation Agreement. 13 Il. PARTIES AND NON-PARTIES 14 A. Plaintiff. 15 18, Katie O’Connell Marsh is a resident of the County of Los Angeles, State of 16 | California. In 2010, following a successful career in which she was a senior television 17 | development executive with Imagine Entertainment, where she oversaw development of the 18 | Emmy Award-winning comedy series, Arrested Development, and NBCUniversal, Inc., where 19 | she oversaw development of the Emmy Award-winning comedy series 30 Rock, Ms O'Connell 20 | Marsh was recruited by Gaumont SA, a film studio based in Paris, France, to launch GIT, an 21 | independent television studio based in Los Angeles. Ms. O’Connell Marsh served as CEO of GIT 22 | forapproximately five years, during which time she built GIT's operations from the ground up 23 | and developed several successful television series, including Narcos, Hemlock Grove, Hannibal San | and Fs for Family Ss B. Defendants. oa 26 19. Defendant Gaumont Television USA, LLC (*Gaumont”) is a limited liability = 27 | corporation organized and existing under the laws of the State of Delaware with its principal 28 | place of business in the County of Los Angeles, State of California, Gaumont isa television ger eo 3. sce se COMPLAINT oot 1 Paget 4 ~ Doo ID = 1727368266 - Doe type = ona1 | studio engaged primarily in the production and distribution of television series. Ms. O'Connell 2. | Marsh is informed and believes and thereon alleges that Gaumont was formerly known as GIT 3 | and /or is the successor-in-interest to GIT. 4 20. Ms. O'Connell Marsh does not know the true names and capacities of the 5 | defendants named herein as DOES 1 through 20 and therefore sues these defendants under such 6 | fictitious names. Ms. O*Connell Marsh will amend this complaint to show the true names, capacities, and conduct of DOES 1 through 20 when and as she ascertains the same. 21. Ms. O’Connell Marsh is informed and believes that Gaumont and DOES 1 through 20 (sometimes collectively referred to herein as the “Defendants”) are and at all material times 10 } have been the agents and servants of, and acted in concert with, one another with respect to the 11} acts and conduct herein alleged, and are responsible for and liable to Ms. O'Connell Marsh for 12 || the damages arising out of such conduct. 13 22. In that capacity, each of the Doe defendants is liable for the breaches of the 14 | Separation Agreement and other causes of action that are asserted against Gaumont, as alleged 15 | below. By virtue of their relationships with one another, the Doe defendants share the same 16 | interests as Gaumont and any Doe Defendant is therefore united in interest with Gaumont. In 17 | particular, a Doe defendant, on information and belief, will have liability that depends on, or 18 | results vicariously from, its relationship with Gaumont, As such, no Doe defendant will be 19 | prejudiced by lack of notice of this action at this juncture. 20 IIL JURISDICTION AND VENUE 2 23. Vemue is proper in this County pursuant to California Code of Civil Procedure §§ 22 | 395(a) and 395.5 because Defendant Gaumont has its principal place of business in the County of, 23 || Los Angeles and because the agreement at issue was negotiated, entered into, performed and 24 | breached in the County of Los Angeles. eas] 24," This Court has personal jurisdiction over Defendant pursuant to California Code of S26 | Civil Procedure § 410.10 because Defendant Gaumont has it principal pace of business in the ® 97 | county oLos Angeles and the amount in controversy exceeds the juriadtional minimum ofthis 28 | Court Somees tL = sea COMPLAINT oot 1 page 5 - Doo 3D = 1727268266 - Doe type = omanrage @ of 39) 1 25. Furthermore, the Separation Agreement contains 2 3 4 5 IV. GENERAL ALLEGATIONS 6 A. COMPENSATION IN THE TELEVISION INDUSTRY 7 26, Television studios often use a combination of fixed base pay and 8 | incentive/contingent compeasation to compensate their most senior executives 9 27. One of the most valuable—and coveted—forms of incentive/contingent 10 | compensation in the television industry is a “backend interest” in one or more television series. u 28. “backend interest” is typically a percentage share of certain contractually 12 | defined revenues associated with the distribution and/or exploitation of a series, minus certain, 13 | contractually defined deductions. The specific set of agreed-upon rules governing the calculation 14 | of this “backend interest” in a given instance is defined purely by contract, and commonly 15 | referred to, as it was here, as the “MAGR” definition, 16 29. _Aftera television series begins generating gross receipts fora studio/distributor, 17 | that studio/distributor reports to MAGR participants through periodic “participation statements,” 18 | applying the terms of each MAGR participant's agreed-upon MAGR definition to calculate the 19 | jamount of money due to the MAGR participant. Payments due are typically sent when 20 | participation statements are issued. 21 B. MS. O’CONNELL MARSH LAUNCHES GIT AND DEVELOPS FOUR 22 SUCCESSFUL TELEVISION SERIES IN LESS THAN FIVE YEARS 2B 30. Ms. O*Contnell Marsh is an accomplished television executive witha long and E24 | istnguished record of developing high-quality, commercially succesful television serie, os 31. After serving as Executive Vice President of Development and Current = 26 } Programming for the independent television studio Imagine Television, where she developed the 27 | Emmy Award-winning comedy Arrested Development, Ms. Marsh went on to become Senior 28 | Vice President of Development for NBC, where she developed the Emmy-Award winning “semate _ + ee COMPLAINT oot 1 Page 6 ~ Doo ID = 1727968266 ~ Doe type = OMENage 7 of 15) 1} comedy 30 Rock. Shortly thereafter, Ms. O'Connell Marsh was elevated to Executive Vice 2 | President of Drama Programming for NBC, where she oversaw all of NBC’s drama series, 3 | including new and existing series. 4 32, In 2010, as an industry veteran with more than a decade of experience and 5 | numerous critical and commercial successes to her credit, Ms. O’Connell Marsh was recruited by Gaumont SA to launch GIT, a television studio focused on producing and distributing television ‘programming for the United States and other parts of the global market 33. In GIT, Ms. O'Connell Marsh recognized the risks inherent ina start-up venture, ‘yt also saw an opportunity to build a studio from the ground up; retbink aspects ofthe television 10 | business; and participate financially more fully inthe success of the television series she 11 | developed. Thus, she entered into a three-year employment agreement with GIT dated October 1, 12 | 2010 (the “Employment Agreement”), under which she became GIT’s first CEO and first 13 | employee. “4 34. Consistent with Ms. O'Connell Marsh's professional objectives and reasons for 15 } taking chance on GIT, the Employment Agreement provided for significant incentive 16 | compensation, including a 2.5% MAGR interest in connection with any “television series greenlit 17 | and produced by [GIT] and ordered into production with a distributor in the United States” during 18 | the period of her employment 19 35. Under the Employment Agreement, “MAGR” was defined “as all gross receipts 20 | derived from {a qualifying] television show less the following items and in the following order of 21 | priority: (i) any third party distribution fees actually charged to [GIT], provided, however, if 22 | {GIT} self-istributes the Program, the distribution fees shall be twenty percent (20%) for cable 23 | and syndication, and twenty-five percent (25%) forall other media; (i) third party out of pocket 24} istrbution expenses; and (ii) daficits (including a fifteen pereent (15%) overhead on al = 25 | production costs pls all producer fees pad to Employee as a producer of such television show), S26 | plus interest at prime plus one percent (126).” eon 36. nother words, Ms. O°Connell Marsh was entitled under the Employment 28 | Agreement to 2.5% of “all gross receipts" on “each television series greealit and produced by Some ur aa src COMPLAINT ‘boot 1 Fagot 7 = Doo XD = 1727268266 ~ Doo type = ommR(Gage 8 of 29) 1 | (GIT] and ordered into production with a distributor in the United States” during her tenure with 2. | GIT minus just three specified deductions: (i) “distribution fees”; (i) “distribution expenses”; and 3 | Gi) “deficits” plus interest. 4 37. Thus, as intended, Ms, O’Connell Marsh's financial interests were tied directly to 5 | er performance as a studio executive and television producer. 6 38. As CEO, Ms. O'Connell Marsh built GIT’s operations from the ground up; 7 | pioneered a unique approach to the development and monetization of television programming — 8 | emphasizing larger initial investments, shorter development timelines, and the concurrent 9 | licensing of domestic, foreign and rerun rights to accelerate the receipt of revenues—that has 10 | since become known industrywide as the “Gaumont Model”; and brought four television series to 11 | the screen in less than three years: Narcos, Hemlock Grove, F Is for Family and Hannibal, 2 39. GIT signed Ms. O’Connell Marsh to a second three-year term as CEO in an 13 | amendment to the Employment Agreement dated September 17, 2013 (“Amendment No. 1") “4 40. And in 2014, The Hollywood Reporter included Ms. O° Connell Marsh in its 15 | Women in Entertainment Power 100, noting her role in developing Narcos, Hemlock Grove, and 16 | “NBC's critical darling Hannibat” and stating that “[s}ince she launched GIT in 2011, the 17 | company ha{d) kept a tight focus on getting scripted fare on the air and bypassing the traditional 18 }} development cycle.” 19 41. Ms, O’Cofinell Marsh did not receive a salary increase in any of the three years of 20 | her second term as GIT’s CEO, but instead secured enhancements to her incentive/contingent 21 | compensation, including a 5% ierease (from 2.5% to 3%) in her MAGR share, and significant 22 | improvements in her MAGR definition, including reductions in deductions for distribution fees 23 | and overhead. S24 42, In September 2015, GIT terminated Ms. O’Connell Marsh in connection with & 3S & 95 } restructuring in which, on information and belief, GIT was renamed Gaumont Television USA, 2 26 | LLC. 7 27 43. On September 30, 2015, Ms. O’Connell Marsh entered into a separation agreement 23 | wiki (te"Spantn Agen) somes COMPLAINT oot 1 Rage# 8 ~ Doo 1D = 1727368266 - Doo Type = omarage 9 of 19) 12 44, The following month, the entertainment industry trade publication Variety ranked 13 | Ms, O°Connell Marsh #26 om its 2015 Women’s Impact Report despite her separation from GIT, 14 stating that GIT “ha{d] been on a roll since launching in 2010-with series like Hannibal,” 15 | ‘Hemlock Grove," and ... ‘Naroos.”” 16 | C. GIT RENEGES ONITS PROMISE TO PAY MAGR EVEN AS IT CONTINUES "7 ‘TO BENEFIT FROM MS. O'CONNELL MARSH'S WORK 18 43. On information and belief, the television series Ms. O’Connell Marsh developed 19 | during her 5-year tenure as GIT’s CEO have generated substantial revenue for GIT and its 20 | successo:-in-interest Gaumont Television USA, LLC. 2 46, Hannibal, which is widely tecognized as one of the best horror genre television 2 | series of alltime, ran for three seasons on NBC. 2B 47. Hemlock Grove also ran for three seasons and was the second original series ever © a4 | commissioned by Neti eas 48. F ls for Family now entering its third season streaming on Netix 2 2% 49. And Narcos, which is going into its fourth season on Netflix, was nominated for a a7} Golden Globe for Best Television Drama in 2016, won Best Drama Series at Mexico’s 28 | prestigious Fénix Film Awards in 2017, and has been described by Variety asa “world-wide “Soames UL Ee seen COMPLAINT oot 1 Paged 9 - Doc 1D = 1727368266 - Doo type = OME1} mega hit” Indeed, analysts estimate that Narcos pulled in more than 27 million viewers in the 2 | United States alone in 2017, making it the 7th most popular television series domestically across, 3 | all platforms last year 4 50. Moreover, on information and belief, Gaumont has not produced any new 5 | television series in the two years since Ms, O’Connell Marsh’s position was eliminated. 6 51. Thus, Ms. O°Connell Marsh not only put GIT on the map in the television 7 | industry, bur the series she developed as GIT’s first employee have kept Gaumont financially 8 | viable to this day. 9 52, - Unfortunately, despite her successes, GIT and then Gaumont have chosen not to 10 | honor their most basic contractual obligations to Ms, O’Connell Marsh and have failed to 11 | calculate or pay her MAGR consistent with her Separation Agreement. 2 53. Most egregiously, in a clear effort to avoid their contractual obligations and keep 13 } from their founder what is rightfully hers, GIT and then Gaumont have wildly overstated the 14 | amount of| ‘when calculating Ms. 15 | O'Connell Marsh’s MAGR by unilaterally redefining the term to mean something 16 || entirely different from its common meaning, its meaning in the entertainment industry, and the 17 || meaning that GIT itself ascribed to that term in documents that it provided to Ms. O'Connell 18 || Marsh. On information and belief, GIT and now Gaumont possess numerous internal documents | 19 | reveaing that they understand tbe term ft mea exactly what Ms. O"Conel ase that 20 | it means—not the tortured definition that they ginned up for te sole purpose of avoiding their 21 | contractual obligations to the woman responsible for GIT and now Gaumont’s primary successes n 54. ‘Through various accounting improprieties and its failure to apply the MAGR 23 | definition as written, Gaumont has already deprived Ms. O°Connell Marsh of millions in MAGR 2 "2 24 | payments, and Ms, O’Connell Marsh will suffer further financial harm if Gaumont's misconduct S B 25 | continues. ke 2 6 27 28 “sere te ee reset ‘COMPLAINT oot 1 pagel 20 - Doo 29 = 1727268266 - Doo type = OnGage 21 of 19) 1 V. CAUSES OF ACTION 2 FIRST CAUSE OF ACTION 3 (Declaratory Relief, Cal. Code Civ. Proc. § 1060) 4 (Against Gaumont and DOES 1 through 20) 5 55. Ms. O'Connell Marsh repeats, realleges and incorporates paragraphs 1 through 52 6 | above, as though here fully set forth. 7 56. An actual controversy has arisen and now exists relating to the parties’ rights and 8 | duties with respect to the calculation of MAGR payments due Ms. O*Connell Marsh in 9 | connection with 10 57. Specifically, Ms. O°Connell Marsh seeks a judicial declaration that, per the plain 11 | terms ofthe MAGR definition set forth in her Separation Agreement, payments due Ms. 12 | O’Connell Marsh 3 as that term is commonly understood and as GIT’s 14 | own internal documents define that term- 15 16 58, Such a judicial determination is necessary at this time in order for Ms. O'Connell 17 | Marsh and Defendants to resolve their dispute in its entirety. 18 SECOND CAUSE OF ACTION 19 (Breach of Contract) 20 (Against Gaumont and DOES 1 through 20) j 2 59, Ms. O’Connell Marsh repeats, realleges and incorporates paragraphs 1 through 56 22 | above, as though here fully set fort -» 2 60. The Separation Agreement constitutes a written contract between Ms. O°Connell = 24 | Marsh, on the one band, and GIT, on the other band. 2 25 61. Ms. O'Connell Marsh fully performed all of her material obligations under the 26 | Separation Agreement or has been excused from performance, 27 62. GIT and then Gaumont have materially breached the provisi of the Separation 28 | Agreement 8 described sbove—inctuding yn atee -l0 _| sees COMPLAINT oot 1 paged 11 ~ Doc ID = 1727368266 ~ Doc Type = oTRERrage 12 of 19) and perhaps in other ways not 3 | yet discovered 4 63. As an actual and proximate result of GIT and then Gaumont’s breaches of 5 | contract, Ms. O'Connell Marsh has suffered and incurred, and will continue to suffer and incur, 6 | substantial damages in an amount to be proven at trial, but estimated to be many millions of 7} dollars and well in excess of the jurisdictional minimum of this Court 8 THIRD CAUSE OF ACTION 9 (Breach of Implied Covenant of Good Faith and Fair Dealing) 10 (Against Gaumont and DOES 1 through 20) u 64. Ms, O’Connell Marsh repeats, realleges and incorporates paragraphs | through 61 12 | above, as though here fully set forth 2B 65. The Separation Agreement constitutes a written contract between Ms. O°Connell 14 | Marsh, on the one hand, and GIT, on the other hand, under which GIT promised Ms. O'Connell 15 | Marsh that she would receive} 16 y 66.__ GIT and then Gaumont have prevented Ms. O*Connell Marsh from collecting 18 | payments] 19 \d perhaps in other ways not yet discovered, 20 67. Ms. O'Connell Marsh fully performed all of her material obligations under the 21 | Separation Agreement or has been excused from performance, n 68. inplying es rr o08 cen Gauron 23 | have acted arbitrarily and in bad faith to prevent Ms. O'Connell Marsh from receiving the fruits 2 24 | of her Separation Agreement, 25 69. Asan actual and proximate result of Defendants’ breach of the Separation 26 | Agreement and its implied covenant of good faith and fair dealing, Ms. O'Connell Marsh has 27 || suffered and incurred, and will continue to suffer and incur, substantial damages in an amount to 28 oot 1 agel 22 ~ Doo xD = 1727368266 ~ Doo ype = OTHERage 23 of 39) 1 | be proven at trial, but estimated to be many millions of dollars and well in excess of the 2 | jurisdictional minimum of this Court. 3 VI. PRAYER FOR RELIEF 4 70. WHEREFORE, Plaintiff prays for judgment against Gaumont as follows: 5 a On the First Cause of Action, for a judicial declaration of the parties’ contractual 6 | sights and duties in connection with the MAGR definition in the Separation Agreement, including 7 | ajudicial dectaraion that payments due Ms. O”Counell Marsh in connection with her MAGR 8 | interests in 9 10 Hy b. On the Second and Third Causes of Action, for actual and compensatory damages 12 | in an amount according to proof, but estimated at many millions of dollars, together with 13 | appropriate prejudgment interest asthe legal rate; 4 © Allotber relief the Court deems just and proper. 15 16 17 | tes Anesles, Califia KASOWITZ BENSON TORRES LLP yg | Dated: January 26,2018 4 yp 19 By = John V- Berhinski, Esq Zo) Christian K. Wrede, Esq. 2029 Century Park East, Suite 2000 2 Los Angeles, California 90067 Telephone: (424) 288-7900 2 Facsimile: (424) 288-7901 2B ‘Attorneys for Plaintiff Katie O'Connell Marsh 2 SR as 2S 16 = 28 egpemampoon Pt arcane COMPLAINT oot 1 Pagel 13 ~ Doo XD = 1727368266 - Doo type = om(wage 14 of 1) eames ere enete dk sa [zen vor, Es. 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Late Connie Apel: ‘CWIL CASE COVER SHEET Fevisonty Conpex Chl gon Co Rijs of Court oes 3400-340) ‘toss Regan (3) See erga Tot) ‘Seaio naion 0) Eran or) ‘Drs fopontaany compe pe or moc) lorcet uagmane Scene one oat 3 user (so ‘Sea Cone en fom vou ‘est PelonCeaeton of Ey of ‘hpmanton Ura es conegEeoment arent Eee En cae ‘Oh Comerl Compt Serer neat Parrerstip and Comore aes oneal Sevres BievOepuner At “ane acon ees, Betton Rare Crops Pen Ree Pom ‘ber Ext Peston Doct 1 raged 25 - Dec 29 = 1727268266 - Doo type ~ OTHERrage 26 of 19) ORIGINAL Amendeh ‘Katie Connell Marsh v. Gaumont Tolevicion USA, LLC Aen BC591790 CIVIL CASE COVER SHEET ADDENDUM AND. STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) Step 1 Step 2: Step 3: chosen [____Ablable Reason or hooting Cour Fling Location (lum ¢) 1..Clts atone must be odin he Strey Mosk Couthause, Cental Diet, 2. Peis ag inet dat 5. Lotaton tare cpus of atone. 4 Mandatory peserl eur ng in Not etic, 6 Locton wre pearance requted defendant ios ‘This form is required pursuantto Local Role 2. in ll new cv ace filings in the Los Angeles Sup tn Column 8, check the box for the type of action that best describes the nature ofthe case, tn Column ¢, circie the number which explain the reason forthe court filing location you have After completing the Civil Case Cover Sheet (Judicial Council form C¥-010), find the exact ase type in ' Column that corresponds to the case type indicated in the Civil Case Cover Sheet. : BY FAX 1. Lectin where patiene elds | 8. Lect hari deandenvrespondent uncon aly 11. Mandatory lag esto Hb Coses ule detain ites t ‘omeolecion ited colton, or personal uy 6 Location propery or paanentysaropee vehicle cas Se “ Phepribe ressae” Eee che oe 2) {© ATI00 Mol etic - Persona unyopeyOanagetorg Death pa ep racsecrnancesan fla fariin) ea nvetmtse neem tease ameeenaee | ira (AGC Asbesos Propet Damage an foweses.08) | nrza Ase -PeroalnnargitOssh an gs ea ‘Produc Littl (24) | A7260 Produc Libilty (at asbestos or oxclenvranmental) ait Es 0 AT2O Medal Malpaciea- Prins 8 Sayeans va 2B | rasicnrespracce ts) want Fi" © A7240 Ofer Persil stn Care Macice “ gs © Wis) Pana Uaaip(cp aman van a? SReyeesey, [oar wrt aoa neyo Onan ou en oon 58 out) A727 tert cin ol Emoon Dore nant 47220 Oher Perera uniresey Dmagerrorfl eat van {GV 1 an 26) CIVIL CASE COVER SHEET ADDENDUM Toon Rue 23 USC Acie 804 ‘AND STATEMENT OF LOCATION Page tot4 Doct 1 paged 16 ~ noc 30 = 1727368266 - Doo type = ontage 17 of 15) ‘ET ie Cone Marah v. GaumontTetevlon USA. 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Ober corte ptapottescrmauancatotiestgnes) | 1.2889 ea Domain/Condermation [Number of paroals_ 26 ‘Condemnation (14) paneer = — g © | ontevaoncn) | A602 Werta Even cae 28 é ; ate wage Foner 2 © | onerresicpnty es) | atna2 Ouse 26 {Atos her Res roe (sterbent coma nde toca) | 2.6 ees eee (D AG021 UniawlutDelainer-Comnarcal (not urugs or wongtul eviekon) oat ee ae enue (2 AB020 Unlawful Delsiner-Residentis (net drugs or wrongful eviction) au 3 sities octanar | asezor awl Deane Poxtrexecosve 28.1 5 nrattonsnerdnar an |S As22 Ueownt Osan Oe Ban LACIV 108 (Rew 206) CIVIL CASE COVER SHEET ADDENDUM ‘Local Rule 2.3 ASC Aopromt 9304 AND STATEMENT OF LOCATION Page 2014 ooh 1 pagee 17 = Dos 1D = 1727268266 - Doo "ype = onmR(@age 18 cc 3) SHESTTME aYie O'Connell Matsh v, Gaumont Television USA, LLC aan dude palace pes sik setFortre (8) [D. AGHB Aas Feire Cove : z Pelion ra Arbitration (11) | AB115 Pettion to CompeCariirmVacsie Miran as ‘ 2 © ASS1 Wil Ata adam ae ; a et thane (02) |. A152 Wt-Mandamus on ried Cour Cos Mater 2 ' 3 ABS Wet-Cher Lid Cou Case Review 2 : ‘Ohardudca Review (29) | AGHEO Ober Wt usestReew 28 F ____[iuariateRoniton on [Asda Tae Apa Tat | commerenoeee (i [0 Aeto7 conmucton Dect rr i | core tmetianass To Toy secs cis olny ass Tot 128 ! : § [7 seanwescimosas ee) [1 A0ss seats Lipton Cove ve 2 : i Soe yg) | nem Tove Tenement peer) i 2 _|[Wenwronce Coverage Clams on : E [hemes cae [oan mses conaowsunogstin compe ten vase } f Oat Se Sa eget zai : mon 12 Abo abel ert 26 ti énorcamen, | 6107 Confession ger frondomesteretons) 29 } BB | ethane) Yea paisa acnisratve Agere Ava ntunpsdines) 28 53 © ABIH4 PebionGentécte or Entry denen on Unpaid Tax as 0. Ast12 er ntrconant ot gat Case 208 Ico er) D ASO33 Racketeering (RICO) Case ~ faze 4 3 1 net20 Daca Re ry 1a 5 conarComguine | ASH Inrti Ret Ot conestchasnon) ae BS | worSorater ore 2) |x aot other Conner Camps Cie (remoahancome) hae 12. Asto0 ihe ivi Camps nom otnon coma) 128 ‘Parmnersiio Corporation 113. Partnership and Corporate Governance Cise 28 ‘Governance (21) media a amma i D Asi Conese 2a ge] Abi Wate ae snen 239 Be) cmeremoepmn [2 M2 BéerDemain Aaa as cre aos $= | Stecieaatomts) | asieo cessoncanes 7 a6 {ASI Paton tr Charge tNanelCange of ener io 1D ASt70 Potion ered Yona Low ae © Mee0 Ober Ov Peon a Trew 0a Re 20) CiviL CASE COVER SHEET ADDENDUM ‘peat Rune 23 asc Aoroved O04 AND STATEMENT OF LOCATION Page Sor Doct 1 Pagel 16 ec xD = 1727268266 ~ Doe type = onmER(age 18 of 19) Katie O'Connell Marsh v. Gaumont Television USA, LLC CANNER BC691790 Step 4: Statement of Reason and Address: Check the appropriate boxes for the numbers shown under Cohumn Cfor the ’ ( tye of action that you have selected. Enter the address which is the bass forthe filing location ineluding zo code, (No address required for classaction cases). REASOW: |Gaumont Television USA, LLC oa 1750 San Vicente Blvd, Suite 1550-East Tower 2.013,04.116.06.07. 08.0 9.010.011 West Hoftywood Ica |s006a ‘Step 5: Certification of Assignment: | certify that this case is propery fied inthe_Central Distt of the Superior Court of California, County of Los Angeles [Code Civ. Proc., §392 et sea. Dates: January 25, 2018 fo Rule 2.3(aK1)E) 1) ‘wetted arom vrancranTy PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY ‘COMMENCE YOUR NEW COURT CASE: Diginal Complain or Petition. 2. fing a Complain, & completed Summons form for issuance by he Clk 2, Shil Case Cover Shoot, Judicial Council form CM-010, 4 Gain CovrSnt edu nd Stent arate fm, LAI” 108, LAS Anpov.8 Ra art) 5, Payment infu ofthe filing fe, unless theres cout oer for waiver, pati or scheduled payments, 6. Asigned oxder appointing the Guardian ad Litem, Judicial Council form CIV-010, the plant or petitioners @ i mine under 18 Yoars of 2g@ wil'oerequred by Court in order to eve a summons, 7. Additonal copies of documents to be conformed by the Clerk. Copies ofthe cover sheet and this addendum ‘mustioe seed slong withthe summons and complaint, o ther tian pleading inthe case. ‘Tac 199 Rev 2716) CIVIL CASE COVER SHEET ADDENDUM ‘acai Rule 2.3 ASC Approves -04 AND STATEMENT OF LOCATION Page 44 oot + Paget 19 ~ Doe 2 1721368266 ~ Dec type = oR