11 12 13 14 15 16 a7 18 1g 20 21 22 23 24 25 26 27 28 e af ° Mark Goshgarian, Esq., State Bar No. 105703 Sy FILED Merak Eskigian, Esq., State Bar No. 115579 Son unt att tas sAnadiora GOSHGARIAN & MARSHALL, Professional Law Corporation 23901 Calabasas Road, Suite 2073 SEP 09 2016 Calabasas, CA. 91302-1542 rs Telephone: (818) 591-9000 nd Facsimile: (818) 591-0810 ee Wa Bolden —— OWPury Attorney for Plaintiff D’ Andrea Graphic Corporation, a California corporation SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES D’ANDREA GRAPHIC CORPORATION, CASENO. BC 6 32651 a California Corporation, Plaintiff, COMPLAINT FOR: (1) BREACH OF WRITTEN CONTRACT; (2) BREACH OF ORAL CONTRACT; (3) COMMON COUNT [INDEBITATUS ASSUMPSIT}; (4) QUANTUM MERUIT; (5) UNJUST ENRICHMENT; AND (6) DECLARATORY RELIEF v. ALPHA GRP, INC., a Delaware corporation doing business as RED BULL GLOBAL RALLYCROSS; and DOES 1 through 50, inclusive, Defendants, Plaintiff D’ Andrea Graphic Corporation alleges as follows: 1. Atalltimesrelevanthereto, Plaintiff D’ Andrea Graphic Corporation (“DGC”) is and has been a California corporation existing under and by virtue of the laws of the State of California with its principal office located in Los Angeles, California. B222 & 2. Plaintiff is informed and believes and thereon alleges that at all ores ero gees 2 defendant Alpha Grp, Inc., is and has been a Delaware corporation doing State California as Red Bull Global Rallycross (hereinafter “ALPHA”) with its pilaf oregon ag & 17383 Sunset Boulevard, A210, Pacific Palisades, California. ase & fees 3. Plaintiff is informed and believes and thereon alleges that the defendants nad herein as DOES 1-50 are in some manner legally responsible for the damages and other things cofjplained of L B88 zg 12 S883 Qomp.antPs € & 10 a 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 herein, Plaintiff is presently unaware of the true names and/or capacities of the defendants identified herein as DOES 1-50 and for that reason sues them in said fictitious manner. Plaintiff will amend this complaint to allege the true names and capacities of DOES 1-50 upon ascertaining that information, 4, Plaintiff is informed and believes and thereon alleges that defendant ALPHA is a mere shell, device and/or alter-ego, dominated and controlled by DOES 1-10, without adequate capitalization, designed to carry out the whims and desires of DOES 1-10, to perpetrate fraud and deception upon plaintiff. Plaintiffs informed and believes and thereon alleges that at all times herein mentioned there existed a unity of interest and ownership between defendant ALPHA and DOES 1-10, such that any individuality and separateness between defendant ALPHA, on the one hand, and DOES Ithrough 10, on the other hand, have ceased, and that ALPHA is the alter ego of DOES 1-10. Plaintiff is informed and believes and thereon alleges that adherence to the fiction of the separate existence of ALPHA as an entity distinct from DOES 1-10 would permit an abuse of the corporate privilege and would sanction fraud and promote injustice, in that ALPHA is a mere shell or device of DOES 1-10 used to injure and commit fraud upon DGC. Plaintiffs informed and believes and thereon alleges that ALPHA and DOES 1-10 are affiliated corporations which are so organized and controlled, and their affairs so conducted, as to make ALPHA merely an instrument, agency, conduit, or adjunct of DOES 1-10, with a common business purpose such that the corporate veil of ALPHA should be pierced and DOES 1-10 be deemed jointly liable for the debts of ALPHA. 5. Plaintiff's informed and believes and thereon alleges that at all times relevant hereto the defendants, and each of them, acted as the agents, employees, servants, joint tortfeasors, and/or co-conspirators of each of the other defendants and in doing the things alleged herein were acting within the course and scope of such agency and/or employment and/or in furtherance of a conspiracy and/or with the permission and consent of the other defendants. 6. DGCisinthe business of providing printing services and event and display solutions for businesses, including design, fabrication, and delivery of banners and graphics for events and trade shows. 7. Beginning in approximately early 2016, Plaintiff was approached by authorized agents, employees, servants, and/or principals of ALPHA, who requested that DGC provide various services 2 COMPLAINT® e and products for which ALPHA. and DOES 1- 50 agreed to pay the amounts invoiced by DGC on a timely basis. ALPHA and does 1-50 repeatedly promised DGC that once the requested products and services were delivered by DGC, that ALPHA would pay DGC the full amount of the invoices. 8. __Inreliance on the representations of ALPHA and DOES 1-50, DGC delivered banners, signage, and related products and services to ALPHA at agreed upon locations throughout the United States 9. Despite demand therefore, at present, ALPHA owes DGC an overdue balance of $246,337.32. FIRST CAUSE OF ACTION (Breach of Written Contract - against ALPHA and DOES 1-10) 10; Plainti incorporates herein by this reference the allegations in paragraphs 1-9 above as though set forth in full 11, Inorabout early 2016, DGC entered into negotiations with ALPHA and DOES 1-10 regarding the delivery of banners, signage, and related products and services to ALPHA. 12. Inorabout early 2016, ALPHA and DOES 1-10, by and through their authorized agents, employees, and principals entered into a written contract with DGC whereby ALPHA requested, and DGC agreed to provide ALPHA with, products and services in exchange for ALPHA’s promise to pay DGC on a timely basis the full amounts invoiced by DGC for said products and services. The aforesaid written contractis established by the exchange of correspondence between the parties and their authorized agents, including but not limited to quotes, estimates, and emails pursuant to which ALPHA and DOES 1-10 agreed to pay DGC the full amounts invoiced for products and services requested by ALPHA. Said correspondence between the parties has the legal effect of establishing a written contract between ALPHA and DGC pursuant to which ALPHA was required to pay the full amount of DGC’s invoices on a timely basis 13, DGC has fully complied with its obligations under the aforesaid written contract by delivering to ALPHA the products and services identified in the invoices attached hereto as Exhibit “A”. 14, ALPHA and DOES 1-10 have breached the aforesaid written contract with DGC by failing to pay the full amount owed under the contract on a timely basis. COMPLAINT& & °: 10 11 12 13 14 15 16 17 18 1g 20 21 22 23 24 25 26 27 28 15, _. Asaresult of ALPHA’s breach of contract, DGC has suffered. damages in an amount not less than $246,337.32. SECOND CAUSE OF ACTION (Breach of Oral Contract - against ALPHA and DOES 1-10) 16. Plaintiéf incorporates herein by this reference the allegations in paragraphs 1-9 above as though set forth in full. 17, Inor about early 2016, ALPHA, by and through its authorized agents entered into an oral contract with DGC whereby ALPHA requested, and DGC agreed to provide, products and services in exchange for ALPHA’s promise to pay in a timely manner the full amounts invoiced by DGC for said products and services. 18. DGC has fully complied with its obligations under the aforesaid oral contract by delivering to ALPHA the products and services requested by ALPHA which are identified in the invoices attached hereto as Exhibit “, 19. ALPHA and DOES 1-10 have breached the aforesaid oral contract by failing to pay the full amount owed under the contract on a timely basis. 20. As aresult of ALPHA’s breach of contract, DGC has suffered damages in an amount not less than $246,337.32. ‘THIRD CAUSE OF ACTION (Common Count - Indebitatus Assumpsit - against ALPHA and DOES 1-10) 21. Plaintiff incorporates by reference herein the allegations in paragraphs 1-25 as though set forth in full. 22, Within the past two years, ALPHA and DOES 1-10 became indebted to DGC in the agreed sum of $246,337.32, for work, labor, and materials furnished by DGC to ALPHA at the special request of ALPHA. 23. Neither the whole nor any part of the above sum has been paid, notwithstanding that, demand has been made for payment, and there is now due, owing, and unpaid from ALPHA and DOES 1-10 the sum of $246,337.32. COMPLAINTfs & & 10 11 12 13 14 15 16 17 18 1g 20 21 22 23 24 25 26 27 28 FOURTH CAUSE OF ACTION (Common Count - Quantum Meruit - against ALPHA and DOES 1-10) 24. . Plaintiff incorporates by reference herein the allegations in paragraphs 1-23 as though set forth in full 25. — Within the past two years, DGC rendered work, labor, and services to ALPHA and DOES 1-10 at the special request of defendants, for which defendants then and there promised to pay DGC the reasonable value of such services. 26. Atal times herein mentioned, the above-services were and are of a reasonable value exceeding $250,000, of which there is now due, owing, and unpaid from ALPHA and DOES 1-10 the sum of $246,337.32. 27. Notwithstanding that demand has been made for payment, there is now due, owing, and unpaid from ALPHA and DOES 1-10 the sum of $246,337.32. FIFTH CAUSE OF ACTION (Unjust Enrichment - against ALPHA and DOES 1-10) 28. Plaintiff incorporates by reference herein the allegations in paragraphs 1-27 as though set forth in full 29. Asalleged above, ALPHA and DOES 1-10 have received a benefit of $246,337.32 from DGC, which equity and faimess dictate be repaid to DGC. 30. Despite DGC’s requests, defendants have failed and refused to pay the balance due of $246,337.32. 31. The $246,337.32 constitutes a benefit that defendants have received to the detriment of DGC. 32. Plaintiff'is informed and believes and thereon alleges that ALPHA’s dba “Red Bull Global Rallycross” evidences that the relationship between ALPHA and DOES 1-10is such that DOES 1-10 received a direct and immediate benefit from the products and services that ALPHA wrongfully obtained from DGC without paying the agreed upon, just compensation, and that DOES 1-10 were in 4 position where they knew, or should have known that ALPHA was taking unjust advantage of DGC, 5 COMPLAINT2 e = wr 10 ql 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 to the detriment of DGC. As such, equity mandates that DOES 1-10 be held jointly liable for the $246,337.32 that ALPHA owes DGC. ‘SIXTH CAUSE OF ACTION (Declaratory Relief - against ALPHA and DOES 1-10) 33. Plaintiff incorporates by reference herein the allegations in paragraphs 1-32 as though set forth in full. 34. Plaintiffs informed and believes and thereon alleges that a dispute has arisen between DGC and the defendants which requires judicial resolution in that DGC contends that: A. ALPHA isa shell, device and/or alter-ego, dominated and controlled by DOES 1-10, without adequate capitalization, to perpetrate fraud and deception upon plaintiff, such that the corporate veil of ALPHA should be pierced and DOES 1-10 be deemed jointly liable for the debts. of ALPHA. B. ALPHA and DOES 1-10 are affiliated corporations which are so organized and controlled, and their affairs so conducted, as to make ALPHA merely an instrument, agency, conduit, or adjunct of DOES 1-10, with a common business purpose such that they should be treated a single business enterprise and DOES 1-10 be deemed jointly liable for the debts of ALPHA. 35. Plaintiff is informed and believes and thereon alleges that defendants dispute the aforesaid contentions by Plaintiff. WHEREFORE, plaintiff prays judgment against defendants as follows: 1, For the sum of $246,337.32; For judicial declarations in accordance with Plaintiff's contentions; For reasonable attomeys fees to the extent provided for by law or contract; For interest at the maximum legal rate; yee N For costs of suit incurred herein; and a a ut a COMPLAINT10 11 12 13 14 16 17 18 1g 20 21 22 23 24 25 26 27 28 6. For such other and further relief as the court may deem just and proper. DATED: September 1, 2016 GOSHGARIAN & MARSHALL, PLC COMPLAINT.\ . Exhibit A le@ D'Andrea Graphics Corporation Invoice 6341 Arizona Circle Los Angeles, CA 90045 Date Invoice # arora | Dave Bil To Aig GRP ine Laura Cooper /77383 Sunset Blvd, A210 Pacific Palisades, CA 90272 Fone | Fat [ Sit 16398 - RED BULL Red Bull Global Rallycross Paes S4 579 i CRON Banners - DVC #10886 (Customer Jab Deposit 428 aBS SSS aaa ‘GOING FORWARD - INVOICES WILL BE SPERATED BY: ‘TRACK SIGNAGE, ‘VENUE SIGNAGE ‘MISC, SIGNAGE [su Total $107,018.35 Payments/Credits a Balance Due $107,018.35 Ex.D'Andrea Graphics Corporation Invoice 6341 Arizona Circle Los Angeles, CA 90045 Date Invoice misnois | D39337 BilTo Apts GRP Tae Laura Cooper 17383 Sense Bhi, A210 Pacific Palisades, CA 90272 F.0. Number Terms Rep Project ‘ent Job No. Net30 1A | 6501 REDBULL FE RedBull Global RalyCrose- Das $28 65 Track Signage Racac2n6 SaaS 26S post $11,276.88 Payments/Credits oo Balance Due $11,276.89D'Andrea Graphics Corporation I . nvoice 6341 Arizona Circle Los Angeles, CA 90045 Date Invoice # maanas | passe Bil To phe GRP ine sare Cooper 17363 Sunset Bid, A210 Pact Paisnds, CA 90272 P.O. Number Terms Rep Project Client Job No, e130 1A [16501 -RED BULL i q z eer [Red Bull Global Rally Cros Dalles 5/28 6/5 Mise Signage JRBCRC 2016 Dalas Mise -DVC#11232 Crate eBcieairenRaais ucts + 25,992.06T| ree ie wt] TPIT RE Total $33,214.70 es PaymentsiCredits a Balance Due 833,204.70D'Andrea Graphics Corporation Invoice 6341 Arizona Circle Los Angeles, CA 90045 Date Invoice # misnois | D3es36 Bil To Alp GRP Ine Laura Cooper 1738 Suet Bh, A210 Paci Palisades, CA 90272 .0, Number Terms Rep Project Cilent Job No et 30 1A | 6508 REDBULL. Red Bull Global Rally Coss- Daytone 6/11 - 6720 Track Signage /RECRC 2016 Daytona Complas!- DVOS1I347 Sula CROMER cma 5 Total sear. Payments/Credits aa Balance Due $4037.72D'Andrea Graphics Corporation Invoice 634] Arizona Circle Los Angeles, CA 90045 Date Invoice # ananois | 039377 Bil To Alps GRP Ine Laura Cooper 17363 Sunset Bid, A210 Pai Palisades, CA 90272 .0. Number Tes Rep Project ent Job No Ne30 LA | 16569- RED BULL = ig Red Bull Global Ralyrose- MCAS 625-14 203.80T RBORC 2016 Veove Signage - DVC #11619 : ° J RGRE2ING Yehues FERS? x Ty $ lgaesar Sales Tex 183 hs Total 82,720.48 2 Payments/Credits a Balance Due 52,720.48D'Andrea Graphics Corporation Invoice 6341 Arizona Circle Los Angeles, CA 9004: Date Invoice # 132016 39378 Alpha GRP Ine Laure Cooper 17383 Sunset Blvd, A210 Pacific Palisades, CA 90272 P.O. Number Project ‘Client Job No. 16549 - RED BULL. 4071167 62ST JRBGRC 2016 Track Signage-DVCMI19. PRBGRC 200 ia SinnmmetiNc aisoe ft bia ERIS er 29.46 ‘Sales Tax Total 8641235, Payments/Credits $0.00 Balance Due 8641235D'Andrea Graphics Corporation Invoice 6341 Arizona Circle ‘Los Angeles, CA 90045 Cate Invoice # anenois | 39503 Bil To Alpe GRP ine 7 era Cooper 17383 Suoset Blvd, A2i0 Paci Palisades, CA 90272 .0. Number Terms Rep Project Cent Job No. Net 30 1a) 16s67-RED BULL Red Bull Global Rallyeross- DC 723-731 saeiaoae 5932607 78230 Sales Tax “0658 EE Total 11,6665 & PaymentsiCredits a Balance Due $11,666.29D'Andrea Graphics Corporation Invoice 6341 Arizona Circle ‘Los Angeles, CA 90045 ~ Dats Invoice # snans | D39504 Bit To * lpia GRP ne Laura Cooper 19383 Sunset Bvd, A210 Pacific Palisades, CA 90272 .0, Numbar Terms Rep Project Clent Job No. Net 30 ta | 16567-RED BULL Signage |RUGKGDOTODC-Vahit Sipngt=ONCH ERAT: Sales Tax be 5 Total 130380 = PaymentsiCredits 5000 Balance Due 5130.80& D'Andrea Graphies Corporation Invoice 6341 Arizona Circle Los Angeles, CA 90045 i) voice # ansaois | Dsss06 Bill To Alpe GRP Tne Laura Cooper 17383 Sunset Blvd, A210 Pacific Pelsndes, CA 90272 .0. Number Terms Rep Project (Client Job No. et 30 1A |16587-REDBULL Sees ae DC 123-735 B45 56 ae SS era.oor4 | Per TTA er Total 333,504. 4 QIpTaETar Payments/Credits $0.00 Balance Due $33,524.74CM-011 TROT OR PIR WOOT TORY fa SB mora FR CORTE | Merak Eskigian, Esq. SBN 115579 GOSHGARIAN & MARSEALL, PLC FILED 23901 Calabasas Road ‘Superior Court of Califomla Suite 2073 ny of Los Angeles. Calabasas, CA 91302 ; reuervone wo: (818) 591-9000 — Faxno; (818) 591-0810 SEP 09 2016 srowertonpun D'Andrea Graphic Corporation ‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES: ‘Sheri R, Ce OttioertClerk smerracoress 111 Ne Hill Street rs ery tmunoooress 111 N. Hi1T Street a econ civaoareove Los Bageles, CA 90012 suncuwve.Central CASENAWE:_D'ANDREA GRAPHIC CORPORATION, etc. v. ALPHA RP,INC., etc., etal. CIVIL CASE COVER SHEET Complex Case Designation “Ber 3 % 6 r Cpt “Tuma [} counter 1 doinder mount sol is Filed with first appearance by defendant | suoce: exceeds $25,000) $28000 or ess) (Cal, Rules of Cour, rule 3.402) oo items 1-6 below must be completed (see insiructions on page 2). 7. Check one box below forthe case type that best describes this case Auto Tor Contract Provsinaly Complex Cli Litigation [Jat 2) [EE] Beach of contacieranty(06) (Ga Rules of Cour rules 400-3409) [J uninsures motorist (46) {Rute 3.740 collections (09) {_) AntituswTrade regulation (03) Other PIPDIWD (Persona InuniProperty (ower cntactons 09) [constuction detect (10) BamageMrongful Death) Tort {= insurance coverage (18) Mass ton (40) TDasvesio 04) (Totter convact 7) seats ingaon 28) (lerecuctibiy (4) Real Property (S Enmircnmeriaioic ot (30) (J etcl malpracice 5) (eninent somainnnerse tnsurance coverage ois asin from the eas) Ones PIEaTD ES condematon (8) ‘bove listed proving complex cae Non PLPOIWD (Oter Tet Eavecienaiy coat [business trvunfair business practice (07) (—] Other real property (26) Enforcement of Judgment ew its (8) Unlawful Detainee 1 enoccoment of judgment (20) CEdovematon 3) CT eommerciat (21) Ieceiciccr ce coecan Froud 16) (resent 2) CJ rco@n [ intetiectual property (19) CJ rugs (38) (2) other complaint (not specified above) (42) ([Protessinalnegigenc 25) adil Review Miscellaneous Civil Petition Jone or PUPDAND tot (26) TJ statue (05) ] Parersip an corporate governance (21) Employment [J rettion reat anara(11) [=] Othe peton (not secited above) (4) J Wrongtteminaton (8) (Jovi ot mandate (02 Jone empoyment (15) (omer jada revew 0 2. Thiscase (| is [LX] isnot complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the {actors requiring exceptional judicial management 2. | Large numberof separately represented partes ¢. [] Large number of witnesses ®. [=] Extensive mation pracice raising difcut or novel e. [—) Coordination wth elated actions pending none ormore courts issues that wil be time-consuming resolve in other counts, states, or counties, or ia federal cout . [1] Substanta! amount of documentary evidence 1. [] Substantial postudgment judicial supervision Remedies sought (check all thet apoly): a. [i] monetary b. Li] nonmonetary: delartor o injunctive rlet_c. (—] punitive 3, 4. Number of causes of action (specify): Six (6) a 5. 6 Triscase [J is [x] isnot aciass action su there are any known related cass, fle and serve a notice of elated pf dafé lati. = Merak Bskigian, fsa aes ‘*:Piaintiff must fe this cover sheet with the first paper filed inthe action or prbGeeding (except small claims cases or cases filed ‘Ender he Probate Code, Family Code, or Welfare and Instutions Code) (Cal. Rules of Cour, rule 3.220.) Failure te may result sanctions, this cover sheet in addition to any cover sheet required by local court rule « If this case is complex under rule 3.400 et sea. of the California Rules of Court, you must serve @ copy of this cover sheet on all other parties to the action or proceeding, ‘+ Unless this isa collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only ane ot Fan aoaed my Ose CIVIL CASE COVER oT ‘at Reso Gat rasa P9295 300408 974, te “sin Can! of cama ‘Sono osin tavnon i918 ‘Sisato eda 0INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET cuRot0 To Plaintiffs and Others Filing First Papers. If you are fling a first paper (for example, a complain!) in a civil case, you must ‘complete and file, long with your frst paper, the Civl Case Cover Sheet contained on page 1. This information will be used to compile statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. in item 1, you must check ‘one box for the case type that best describes the case. If the case fts both a general and a more specific type of case listed in item 1, check the more specific one. Ifthe case has multiple causes of action, check the box that best indicates the primary cause of action To assist you in completing the sheet, examples ofthe cases that belong under each case type in item 1 are provided below. A cover sheet must be fled only with your initial paper. Failure to file a cover sheet with the first paper fled ina civil case may subject a party its ‘counsel, or both to sanctions under rules 2.30 and 3.220 of the Caiifomia Rules of Court. To Parties in Rule 3.740 Collections Cases. A “collections case" under rule 3.740 is defined as an action for recovery of money owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in which property, services, or money was acquired on credit. collections case does not include an action seeking the following: (1) tort damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of attachment. ‘The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections case will be subject to the requirements for service and obtaining a judgment in rule 3.740. To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the case is complex. Ifa plaintif believes the case is complex under rule 3.400 of the California Rules of Cour, this must be indicated by completing the appropriate boxes in items 1 and 2. Ifa plant designates a case as complex, the cover sheet must be served with the Complaint on all parties to the action. A defendant may file and serve no later than the time of is fist appearance a joinder in the Plaintiffs designation, a counter-designation that the case is not complex, or, ifthe plaintiff has made no designation, a designation that the case is complex. cise Ween ao ues ‘Auto Tort contract Provisionally Complex Civil Litigation (Cal ‘Auto (22)—Personal nury/Propety Breach of ConracuWarranty (08) Rules of Court Rules 3.400-2.403) DamagelWrergl Death Breach of RetalLease “Antrus/ Trace Regulation (03) Uninsured Motos (48) (the Contact (not uni detainer Constructon Detect (10) case involves an uninsured cones ee te Claims involving Mass Tort (40) pasa ear eee Plait (nt Fraud or regigence) Felisener alee ‘arbitration, check this item iigent Brooch of Coben EnvironmentalToxic Tort (30) instoad of Auto) Ne Neen Insurance Coverage Claims (ther PUPDIWD (Personal Injury! ‘ner Breaeh of ContracuWvarany (arising trom provisional complex Property Damagenrongful Death Calectons (eg, money owed, open ase tye sted above) (41) Fo ook secouns) (09), forcement of Ju Aes (08) Collection Case Sete Paint aCe ceieee cco estos Property Damage Promissory NotelColectons ash Asoesos Personal uy? oe age Nowicoles Abarat of udgment (Out of Wrongful Death Insurance Coverage (no provsonaly County) Product itil (not asbestos or compton (18) Confession of usgment non ‘oxkfenvenmenta) (24) ‘Ato Subrogation ‘domestic elations) Medical Malpracton (8) Other Coverage Sister State Judgment Nedieal Maiprecses- Otter Convact (37) ‘Ainsative Agency Award Physicians & Surgeons ‘Contactal Fraud (pot unpa taxes) fae eae iner Contract Dispute Petton/Certicaton of Entry of alpractoe Ras Propety uterine ote PUPDIND (28) :minent Domalevinverse er Enforcement of Judgment Premises Liable. lip ondemnaton (14) Case ‘ond fal) onl ton (3) Miscellaneous Civt Complaint ea ay er Real Property (2, quiet ie) (28) ICO (27) not osm enialen) Wot of Possession of Real Property (Other Complain (nat specified ition onconet orange Freconwe cae Emon Oars her Res Pay tia Decor at NegigentInficton of comein, lndlratensn, or arassren) Emotional Distress forecosure) Mechanics Len other PUPDIWD Uniawful Detaner (Ofer Commercial Complaint Non PUPOID (Othe Tort Gomera (31) Canna Compt Business TowUntar Business Residential (52) Con ceeen Practice (97) Drugs (36) (he case Involves legal ee Ci gh (eg, elserminaton, arugs, check is tem: otherwise, ee fase are ot repries Commerc or Rector) ncllanaous Cail Petiion ee ag ear famaton (eg. larder, ‘ascet Fortetuce (05) 5 Petion © (13) Peiion Re: Arbtraton Avars (11) eee Fiaua 16) Wii of Mandate (02) 1s Ga pearariont intecual Property (19) ‘Wt-Adminisvaive Mandamus Workplace Vance" Professional Negigence (25) ‘WricMandamus on Limited Cour oripiace Vk teat Napractee Case ater EeDependet Act Otter Proessional Mapractice Wri ter imted Coun case cS (nol mecca orga) Review Peton orWame Crh Olver Non PUPDIWD Tort (25) ‘ther duce Row (39) Peon tr Ratt om ae Employment Review of Heath Offcer Order a“ "Mong Terinaton (3) Note of Appel-Lsber ee Ober employment 13) ‘Commissioner Appeais a a Sot a2 e CIVIL CASE COVER SHEET e PataSORTMPD*ANDREA GRAPHIC CORPORATION, etc. v. ALPHA [Osewaccr Gap, INC., ete., et al CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION BC632651 (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court. Step 1: After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in Column A that corresponds to the case type indicated in the Civil Case Cover Sheet. Step 2: In Column B, check the box for the type of action that best describes the nature of the case. Step 3: In Column C, circle the number which explains the reason for the court fling location you have chosen, Applicable Reasons for Choosing Court Filing Location (Column C) (Class actions must be fied in the Stanley Mosk Courthouse, Central Distict. 7. Location where petioner resides. 2. Permissive fling in central district 3, Location where cause of action arose. 4 Mandatory personal injury fling In North Distt Location where performance required or defendant resides. £8. Location wherein defendanvrespondent functions wholly. 8. Location where one or more ofthe parties reside 10. Location of Labor Commissioner Office Location of property or permanently garaged venice, 11, Mandatory fling location (Hub Cases — unlawful detaner ited ‘non-collecton, limited collection, or personal injury) 5 Auto 22) (47100 Wotor veice- Personal njuryiProperty DamageMirongfl Death g 2 Uninsured Motoist (46) |[] A7110 Personal njuyPropery DamagelWrongtul Death - Uninsured Motors] 1,4, 11 7 [7] 6070 Asbestos Property Damage a ze ne ()ar221 Asbestos - Personal ljunWrongtl Death aM 5 Ee | rrsauasmy 2 |[—ava0 Pau uonty meee or centers van gs Nabractcs 4s) |_IA7210 Weal arctee Physician & Sugeors att ej ? Medical Matractece (48) |") 7240 otner Professional Health Care Malpractice nant BS 2 'A7250 Premises Labity (esp and fal 22 other Personal = abit (€.. sip and fal) ant se Iriry Propery 1 47230 intertonal Bost inuryProperty DamagenWrongtuDeath(eg. — | s, 4 11 Be Damage Wrengi assault vandals, et) ‘< Death (23) |) 47270 intentional infiction of Emotional Osstress want S [47220 other Personal njury/Peoperty Damage/rongtl Death att & LAcIv 109 Rev 2/6) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3, LASC Approved 03:04 AND STATEMENT OF LOCATION Page 1 of 4‘SORTTME D'ANDREA GRAPHIC CORPORA’ IN, etc. v. ALPHA | cHsenwecr GRP, INC., etc., et al. A B C Applicable Civil Case Cover Sheet ‘Type of Action Reasons - See Step 3] Category No. (Check only one) nae = Business Tor (07) |] A6029 Other CommeriavBusiness Tort (not rauabreach of contact) | 1,2.3, Bs Cit Rights (08) (600s civ RightsiDiscriminaton 1.2.3 = Detamaton (13) |=) A80%0 Defamation (anderibe) 123 2B 3e Fraus (16) [8019 Fraud (no contact) 1.2.8 es 3 } BB | pwnage [DAO ome wz aa [A060 other Proessional Malpractice (rot medical or lea!) 1.2.3 & otner (35) (8028 oiner Non-Personal juny Property Damage tort 1.2.9 4 [_rengta Termination 36) [1 6087 Wrong Termination 12.3 BL ones to) |ClAse2# ter Empoyment Compan cose 128 2 Employment 2 wiewment('5) 1) asi09 Labor Commissioner Appeals 0 [J 8006 Sreach of Rena.ease Contact (not unlawl detainer or wrongful | 2, § eveton) Breach of Contac Ware 08 "Y | 50) a6008 ContracWarranty Beach -Sellr Paint no raudinegigence) | 2° (oot insurance) 1 as019 Negligent Breach of ContracuWarranty (no fraus) 2 (as028 omer Breach of ConractWaranty (not aud ornegigence) — | 125 zg eae oe [)nt002 Cottections Case-Selier Piaintit 5,611 z (1aso12 otner Promissory NotelColectons Case 5 8 [at036 Cotectons Case-Purchased Debt (Charged OM Consumer Det | 5,6, 11 Purenased ono ater January 1, 2014) Insurance Coverage (18) |{] A6015 insurance Coverage (not complex) 1.2.5.8 T re008 contact Frau 1.2.35 Over Contact (37) |{) A601 Torsousintertrence 1.2.35 |) as027 omer contact Dispute! breacninsurancetravdinegtigence) | 1.2,3.8,9 | Sreamaeommaevar® [[—]avs00 eminent omainvCondenaton Number of parcels 26 ? B | wrongtuievicion 3) |[) 8028 Wrongtu Eviction case 26 i 7 ac018 morgage Foredosue 26 Otver Real Property 26) |[—) a6022 Que Tse 26 Asoc cine Rea ropa re eminent domain ndordtenant orecosure) | 2,6 nian Detain Commerc [_] 46021 Uniowl Detaner-Commercal ot rugs o wrongful eviton) [6,1 | Uniawtu Detaner-Resisenia |] agaz0 UniawtlDetainer- Residential (ot crus or wrongful evcton) | 6,11 S punt Detainer |] A8020F Uniawl Detainer Post Forectosire 26,0 Uriowu Detainerrugs 38) |) AB022 Unlawtut Detainer- gs 2611 AGW 109 Rev 2116) CIVIL CASE COVER SHEET ADDENDUM Local Rule 23 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 2 of 4‘SioRT ME: D” AND! GRAPHIC CORPORATION, etc. v. ALPAA [osenamaer GRP, INC., etc., et al. A B C Applicable Chil Case Cover Shost Type of Acton Reasons - See Step 3 Category No. (Check ony ene) Above ‘Asset Forfeiture (05) | [_] AG108 Asset Forfeiture Case 2.3.6 | Petionre arivaion 11) |[—] A6t15 Petiion to CompelContm/vacatearivaton 2.5 & [A615 wit Administrative Mandamus 28 3 Wirt of Mandate (02) | |] a6152 Wit Mandamus on Limited Court Case Matt 2 3 (46183 wit- other Limited Court Case Review 2 ee ee 2.8 gg _[ ArtiwvTrade Regulaton(03)][_—] AG003 AntnusiTrade Regulaton 12.8 B | constuction Detect 10) |] as007 Construction Detect 1.23 | Claims ivoring Mass Tor | [7] 46006 Claims Involving Mass Tort 1.2.8 & S | securtes Ligation 28) |] 6035 Secures Ligation Case 1.28 3 | 5 entation 5) [[1 ae086 Tove Tovenvtoarentt 12.38 | insurance Coverage Claims E | Injurares Coverage Clair | agora insurance Coverage’Subrogation (complex case only) 1.2.5.8 [J stt Sister State Judgment 25.11 Enforcement of Juagment (20) Enforcement (of Judgment [J rete0 Abstract of Judgment [ast07 Confession of Judgment (non-domestic relations) [7 asr40 Administrative Agency Award (not unpaid taxes) (1) 46114 Petiion!Certiicate for Entry of Judgment on Unpaid Tax [PD aet2 other Enforcement of Judgment Case [J 6000 other civil Complaint (non-tortinon-complex) RICO (27) TJ As035 Racketeering (RICO) Case 1.28 3s (J n6030 Dectaratory Rel Only ae Other Complaints (6040 Injunctive Retief Only (not domestictnarassment) BS | (Not Speciied Above) (42) |) ag011 omer Commercial Complaint Case (non-tc/non-complex) 23 : Partnership Corporation rzerstip Comeraion 1 [—) agra Parersip and Corporate Govemance Case 28 (ast ci Harassment 2.3.9 [46123 Workplace Harassment 23.9 ome Petsons wot | = S124 elderDependent Ait Abuse Case 2.3.0 Species Above) (43) | [—] AB190 Election Contest A [6:10 Petition for Change of Name/Cnange of Gender Ag (= hsit0 Peetiion or Ret rm Late Cis Law ae J r100 omer cit Pettion te LACIV 109 (Rev 2/16) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 3 of 4 See ee ee ree ee ee tee ee ete hee ee ee ee eee ee ee ee ee tee eee eee‘swonrtm= D'ANDREA GRAPHIC CORPORATION, etc. v. ALPHA CASE NNER GRP, INC., etc., et al. Step 4: Statement of Reason and Address Check the appropriate boxes for the numbers shown under Column C for the type of action that you have selected. Enter the address which is the basis forthe filing location, including zip code. (No address required for class action cases). ADRESS: REASON: 6341 Arizona Circle Oo 3.46.06. 7. eo9.o10.01 Los Angeles cA 90045 Step 5: Certification of Assignment: | certify that this case is properly filed in the Central District of the Superior Court of California, County of Los Angeles [Code Civ. Proc., §392 et seq., and Local Rule 2.5(@)(1)(E) voes_ $73! le PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE'FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 41. Original Complaint or Petition, 2. Iffing a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010. 4 Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev. 02/16) Paymentin fullof the fling fee, unless there is court order for waiver, partial or scheduled payments. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, ifthe plaintf or petitioner is a minor under 18 years of age will be required by Court in order to issue a summons. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along with the summons and complaint, or other initiating pleading in the case. Stet? TAPER LAGIV 109 (Rev 2176) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3, LASC Approved 03-04 AND STATEMENT OF LOCATION Page 40f 4