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FILED: NEW YORK COUNTY CLERK 11/15/2018 12:11 PM INDEX NO.

655696/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/15/2018

SUPREME COURT OF THE STATE OF NEW YORK


COUNTY OF NEW YORK
Index No.:
SOFLA SPORTS, LLC,
SUMMONS
Plaintiff,
DATE FILED:
- against –
Plaintiff designates New York County
as the venue for the place of trial.
ENTERTAINERS & PLAYERS INNOVATIVE
CONSULTANTS, LLC, and RONALD BUTLER

Defendants.

YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve

a copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice

of Appearance on the Plaintiff’s attorneys within 20 days after the service of this Summons,

exclusive of the day of service (or within thirty (30) days if this Summons is not personally

delivered to you within the State of New York); and, in case of your failure to appear or answer,

judgment will be taken against you by default for the relief demanded in the Complaint.

Dated: New York, New York


November 15, 2018 ROBINSON BROG LEINWAND
GREENE GENOVESE & GLUCK, P.C.

By: /s/ Peter R. Ginsberg


Peter R. Ginsberg, Esq.
875 Third Ave, 9th Floor
New York, NY 10022-0123
(212) 603-6300
(prg@robinsonbrog.com)

Attorneys for Plaintiff

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TO: RONALD BUTLER


11538 SW 235th Street
Homestead, Florida 33032

ENTERTAINERS & PLAYERS


INNOVATIVE CONSULTANTS, LLC
1900 North Bayshore Drive, Suite 2118
Miami, Florida 33132

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SUPREME COURT OF THE STATE OF NEW YORK


COUNTY OF NEW YORK
Index No.:
SOFLA SPORTS, LLC,

Plaintiff, COMPLAINT

- against –

ENTERTAINERS & PLAYERS INNOVATIVE


CONSULTANTS, LLC and RONALD BUTLER,

Defendants.

Plaintiff SoFla Sports, LLC (“SoFla”), by its attorneys, Robinson Brog Leinwand Greene

Genovese & Gluck P.C., allege as and for its Complaint against Defendants Entertainers &

Players Innovative Consultants, LLC (“EPIC”) and Ronald Butler (“Butler”) as follows:

INTRODUCTION

1. In approximately May 2017, Allan Guertin, the sole owner of SoFla, began

discussions with Alex Gavilla, the owner and CEO of EPIC, about the possibility of Gavilla

investing in SoFla and EPIC merging into SoFla. SoFla and EPIC are sports representation

companies that provide representation to NFL Players. Despite having been established in 2011,

EPIC at the time was a struggling business with few if any clients.

2. The discussions between Guertin and Gavilla continued for several months.

Unknown to Guertin, EPIC representatives also were having discussions with Ronald Butler, a

Certified NFL Contract Advisor employed at the time by SoFla.

3. EPIC and Butler hatched a scheme to steal SoFla clients in violation of Butler’s

fiduciary obligations, including his duty of loyalty, to SoFla and his contractual obligations.

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4. As part of EPIC’s and Butler’s conspiracy, Butler has engaged in a pattern of

fraud, deceit and dereliction of his duties and obligations, including his fiduciary obligations,

owed to SoFla. Working hand and hand with EPIC, Butler has diverted and otherwise deprived

SoFla of fees and commissions and tortiously interfered with SoFla’s business and personal

relationships with clients.

5. While still employed by SoFla, Butler entered into business relations with other

Certified Contract Advisors, at least one of whom is employed by EPIC, for the sole purpose of

diverting and otherwise depriving SoFla of fees and commissions to which it was and is entitled.

6. In early 2018, Butler joined EPIC as a member. At least since that time, EPIC has

interfered with SoFla’s relationships with its clients, including by convincing Players who were

using SoFla’s services to leave and become EPIC clients, using both financial and other

incentives and by impugning the reputation of SoFla and people associated with SoFla.

7. To the benefit of EPIC and Butler, Butler and other EPIC partners and employees

have acted in a manner that threatens to compromise SoFla’s standing in the community and in

the industry of sports agency, and Butler has failed and refused to abide by and commit to the

terms of his binding agreements with SoFla.

8. As a product of their conspiracy, Butler and EPIC have diverted or stand to divert

in excess of $2 million due to SoFla and have successfully caused approximately fifteen NFL

Players formerly represented by SoFla and SoFla Contract Advisors to leave SoFla and enter

contractual agency relationships with EPIC and EPIC Contract Advisors.

9. SoFla seeks damages for tortious interference with contractual relations, tortious

interference with prospective business relations, aiding and abetting a breach of fiduciary duty,

conversion and civil conspiracy.

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THE PARTIES

10. SoFla is a limited liability company organized under the laws of the State of

Florida with its principal place of business located at 2799 NW Boca Raton Blvd, Suite 203,

Boca Raton, Florida 33431.

11. EPIC is a limited liability company organized under the laws of the State of

Florida with offices located at 38 Stonehurst Lane, Dix Hills, New York 11746 and 1900 North

Bayshore Drive, Suite 2118, Miami, Florida 33132.

12. Butler is a natural person who resides at 11538 SW 235th Street, Homestead,

Florida 33032.

JURISDICTION AND VENUE

13. EPIC is subject to jurisdiction in the State of New York pursuant to N.Y.C.P.L.R.

§ 302(1), by transacting business within the State, and N.Y.C.P.L.R. § 302(2), by committing a

tortious act within the State. The owner and principal of EPIC, Alexander Gavilla, identifies 38

Stonehurst Lane, Dix Hills, New York 11746, as his place of business on the National Football

League Players Association (“NFLPA”) website.

14. Butler is subject to jurisdiction in the State of New York pursuant to

N.Y.C.P.L.R. § 302(1), by transacting business within the State, and N.Y.C.P.L.R. § 302(2), by

committing a tortious act within the State.

15. Venue is proper in New York County pursuant to N.Y.C.P.L.R. § 503(a), as

neither Defendant resides in the State of New York and Plaintiff designates New York County

for venue.

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FACTS COMMON TO ALL CAUSES OF ACTION

16. SoFla is a sports representation company which, both directly and through its

Contract Advisor employees, represents NFL Players, including in connection with their contract

negotiations with NFL teams and marketing opportunities. Allan Guertin is the sole owner of

SoFla.

17. EPIC is a sports representation company which, both directly and through its

Contract Advisor employees, also represents NFL Players and holds itself out on the NFLPA

website as conducting its business in Dix Hills, New York.

18. Butler is a former employee of SoFla providing representation to SoFla’s clients

and is now a partner in EPIC.

19. Impact Sports Management (“ISM”) is a sports representation company which,

both directly and through its Contract Advisor employees, represents players. Mitchell Frankel

is an owner of ISM and currently the sole ISM Contract Advisor.

20. The NFLPA certifies Contract Advisors to represent NFL Players as agents and,

among other things, to negotiate NFL contracts on behalf of Players and receive fees for their

representation.

21. ISM hired Butler in or around July 2010 to serve as a salaried consultant.

22. For various reasons, including that he could not pass the examination to become a

Certified Contract Advisor until September 2014, Butler remained in the position of a low-level

consultant and aid to ISM Certified Contract Advisors.

23. In or about July 2014, Butler, without notice and in violation of his duties and

obligations, including his fiduciary duties, left ISM in an effort to become an employee of a rival

agency, Select Sports Group, LLC (“SSG”), and to steal ISM’s clients.

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24. Butler returned to ISM as a consultant in or about August 2014 after a short and

unsuccessful tenure with SSG.

25. Butler finally received his certification to become an NFLPA Contract Advisor on

or about September 2014.

26. On January 19, 2015, Butler entered into an employment agreement with SoFla

(“Butler Employment Agreement”) after being informed that he could no longer continue as an

ISM consultant. Butler’s employment agreement with SoFla was thereafter extended in writing

at least nine times, including as recently as December 1, 2017, until it terminated on December

31, 2017.

27. According to the Butler Employment Agreement, Butler was obligated to “serve

as an employee of SoFla under the direction of SoFla’s Manager.” (Butler Employment

Agreement ¶ 1.)

28. With regard to fees and commissions received at any time during or after Butler’s

SoFla employment from NFL players who at any time during Butler’s SoFla employment were

SoFla Clients, as that term is defined in the Butler Employment Agreement, such fees and

commissions “shall be solely for the account of SoFla and paid to SoFla.” (Butler Employment

Agreement ¶ 9.)

29. The Butler Employment Agreement explicitly states that the arrangement set forth

in Paragraph 9 remains in place even after Butler’s SoFla employment terminates.

30. SoFla, following receipt of fees and commissions, is obligated to distribute such

fees and commissions pursuant to the terms and conditions of the Butler Employment

Agreement. Paragraph 14 of the Butler Employment Agreement provides:

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POST-EMPLOYMENT FUND ADMINISTRATION:

a. All gross revenue from any source generated by all


Butler Clients must be paid to SOFLA, whether Butler is
employed by SOFLA or otherwise. SOFLA shall then
distribute any such revenue pursuant to the terms of the
instant Agreement.

31. Consistent with Paragraph 8 of the Butler Employment Agreement, even with

regard to SoFla Clients on whose Standard Representation Agreement (“SRA”) – the official

document the NFLPA requires in order for an agent to represent an NFL Player -- Butler is

identified as a Certified Contract Advisor, all fees and commissions received from those Clients

are the property of SoFla. Paragraph 8 of the Butler Employment Agreement provides:

NFLPA SRA Not Determinative: It is understood and


agreed by Butler and SOFLA that Butler’s name on an
NFLPA Standard Representative Agreement or on any
other contract, marketing right or other agreement
involving the representation of a SOFLA Client does not
determine Butler’s control over or interest in any current or
future revenue from such Client.

32. A second agreement executed simultaneously with the Butler Employment

Agreement, identified as the Player Fee Assignment Agreement (“Fee Assignment Agreement,”

and collectively with the Butler Employment Agreement, the “Agreements”), reiterates in

Paragraph 2 that Butler’s affiliation with SoFla was at all relevant times as an employee and,

further, with regard to Client fees and commissions, confirms that such monies are and at all

times remain the property of SoFla. Paragraph 2 of the Fee Assignment Agreement provides:

RB [Ron Butler] represents and warrants that irrespective


of his being listed as the contract advisor/agent of record or
as a co-agent of record on any SRAs, marketing
agreements, marketing advance agreements or any other
agreement with such [SoFla] clients …, any and all fees
earned, due and owing or any other monies due from any
such client is and remains the sole and exclusive property
of SoFla and RB hereby assigns to SoFla all such fees as to

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any and all contracts or agreements between any player and


any team or sponsor, now or in the future.

(Fee Assignment Agreement ¶ 2.)

33. The scope of the Fee Assignment Agreement is equally clear: “This Agreement

applies to all SRAs, player loan agreements, marketing agreements and marketing advance

agreements for any player/client for or through which RB shall have any contact while an

employee of SoFla.” (Fee Assignment Agreement at ¶ 3.)

34. The post-employment allocation of fees and commissions address, and apply to,

fees and commission as a result of NFL contracts and Marketing Agreements “in existence at the

time of Butler’s departure” and to “any NFL contracts and Marketing Agreements throughout

each [Player’s] professional football career….” (Fee Assignment Agreement at ¶ 13.)

35. The Butler Employment Agreement and Fee Assignment Agreement explicitly

apply to present as well as future fees and commissions. (Butler Employment Agreement at ¶

14; Fee Assignment Agreement at ¶ 2.)

36. The provisions identified above apply whether Butler is actually on a Player’s

SRA or other agreement or, instead, has explicitly or clandestinely transferred representation of

the Player to a third-party. The Butler Employment Agreement contains the following

provisions:

… each Party agrees that any affiliated entities of such


Party, including but not limited to future employers, or
other sports management agencies, are to be considered to
be agents of that Party, and the obligations of this
Agreement are to be imputed to such agents.

(Butler Employment Agreement ¶ 14 (b).)

37. Both the Butler Employment Agreement and the Fee Assignment Agreement

apply to Players who were SoFla Clients at any time during Butler’s SoFla employment,

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including Clients who became clients during Butler's employmcñt with SoFl

Clients."
Players who are identified as "Prospective A Prospective Client is defi

[A]ny Player whom any SOFLA certified adviso

.contacted within the 12 months before non-renewal

termination for purposes of representing


such prospective
player'
client during such s professional career.

38. In approximately May 2017, Guertin and EPIC began discussi

possibility
of Gavilla investing
between $500,000 and $700,000 in SoFla and E

SoFla. Unknown to Guertin, EPIC also began having secret meetings with B

EPIC and Butler hatched a scheme to steal the NFL Player clients of SoFla

SoFla the fees and commissions owed or to be owed by those NFL Players,

Butler's duty of loyalty to SoFla and his contractual obligations.

39. During this time Butler failed to disclose his c0ñversations

representatives.

40. Butler became a partner of EPIC in


early 2018.

41. Butler, in contravention of his fiducis-y duties to SoFla,

convincing at least fifteen NFL player clients of SoFla to become clients of EPIC

42. In addition, and in violation of the Agreemcñts, Butler, individüãlly

of EPIC, has directly and indirectly received certain fees and commissions

owing to SoFla. Even after


diverting and accepting those fees and en==issions,
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the total amount of $60,000. On each occasion, Butler delayed transmitting all of those fees to

SoFla for significant periods of time.

44. Butler, with regard to Robinson, breached his fiduciary and contractual duties to

SoFla by placing a Certified Contract Advisor employed by EPIC, Ira Turner, on a new SRA for

Robinson. Butler also arranged for Turner’s name to appear on Robinson’s March 2018 New

Orleans Saints contract.

45. Turner could provide no additional expertise or professional support to Robinson

and, indeed, provided no expertise or professional support to Robinson. At the time, Turner had

no experience acting on behalf of NFL Players, had not successfully taken the lead in negotiating

any significant NFL Player contracts, and had no experience acting as a primary Contract

Advisor. Turner also had little or no role in Robinson’s contract negotiations with the New

Orleans Saints.

46. Butler acted in this manner with Turner and EPIC for the exclusive purpose of

diverting fees that are and will be due and owing from Robinson away from SoFla and to EPIC

and himself and, upon information and belief, acted in this manner as a material part of Butler’s

effort to obtain employment with EPIC.

47. EPIC now advertises Robinson as a client on its website.

48. Kareem Jackson was a SoFla Client, as defined in Butler’s Employment

Agreement. Both Frankel, on behalf of ISM, and Butler, on behalf of SoFla, appeared at all

times relevant as the Certified Contract Advisors on Jackson’s SRA. Pursuant to an agreement

between SoFla and Impact, one half of the fees and commissions from Jackson is owed to SoFla

and one half of the fees and commissions is owed to ISM through Frankel. SoFla and Frankel in

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turn are obligated to pay 20% of the money they collect as follows: 10% to Butler and 10% to

another former ISM Certified Contract Advisor.

49. By invoice dated December 26, 2017, SoFla billed Jackson for fees and

commissions owed for the 2017 NFL Season in the amount of $202,500.

50. In violation of the Agreements, Butler directed Jackson’s financial advisor to pay

him the $202,500 total owed in fees and commissions. Butler thereafter retained possession of

those monies in contravention of the Butler Employment Agreement, Fee Assignment

Agreement and subsequent representations made to Guertin confirming Butler’s obligations and

duties.

51. EPIC now advertises Jackson as a client on its website.

52. Butler admitted to a third-party that he intended to arrange with Jackson to enter

into an SRA with a different agent but still receive the fees and commissions in an attempt to

deprive SoFla of fees and commissions which are and will be owed to it under the Agreements.

53. Butler similarly arranged to divert fees from SoFla Clients Phillip Dorsett and

Denzel Perryman in a total amount of $61,314. SoFla was obligated to transfer a portion of

those fees to ISM.

54. EPIC now advertises both Dorsett and Perryman as clients of EPIC on its website.

55. Corey Liuget became an ISM client in 2011, prior to being drafted into the NFL.

On June 8, 2015, Liuget executed a new SRA that identified Frankel, Butler and Ashton Wilson,

also an agent, as his Certified Contract Advisors. Frankel negotiated Liuget’s June 2015 NFL

contract with the San Diego Chargers without any involvement by, or assistance from, Butler.

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56. Liuget was never a Butler Client pursuant to the Butler Employment Agreement

and during his SoFla employment Butler never received any compensation as a result of fees and

commissions received from Liuget.

57. In February 2018, Butler convinced Liuget to terminate Frankel, acting at the time

as a consultant for SoFla, as his Certified Contract Advisor and to execute a new SRA that

identified Butler and Wilson as his Certified Contract Advisors. Butler acted in this manner for

the exclusive purpose of diverting fees owed to SoFla under the Agreements.

58. Pursuant to the Butler Employment Agreement and Fee Assignment Agreement,

Butler has no right to any of the Liuget fees and commissions paid, due or to be owed in the

future. In violation of the Butler Employment Agreement and Fee Assignment Agreement,

Butler has diverted and received monies due to SoFla and to which he has no right.

59. EPIC now advertises Liuget as a client on its website.

60. David Sharpe in 2017 signed a four-year rookie NFL contract in the total amount

of $2.986 million. Pursuant to his SRA, SoFla is owed 50% of the fees and commissions from

Sharpe. Without authority or legal right, Butler agreed to co-represent Sharpe with another

Certified Contract Advisor, Richard Beda.

61. As a result of Butler’s actions, SoFla has not received any of the fees and

commissions due and owing to SoFla in 2017. Upon information and belief, Beda’s company

received the fees and commissions and, upon information and belief, transferred a portion of

those fees and commissions to Butler.

62. EPIC now advertises Sharpe as a client on its website.

63. Butler, upon information and belief, has enticed and otherwise convinced

additional SoFla clients to alter their SRAs, and the persons identified as Certified Contract

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Advisors, in a manner designed to deprive SoFla of fees to which SoFla is entitled and divert

those fees to EPIC, including those Players identified above as well as Travis Benjamin and

Lavonte David.

64. EPIC now advertises Benjamin and David as clients on its website.

65. In or about early 2017, Butler entered into an unauthorized agreement with Pat

Lawlor, Butler’s current attorney and, at the time, an inexperienced and unsuccessful Certified

Contract Advisor, to represent Corn Elder. There was no bona fide professional reason to allow

Lawlor to become a party to Elder’s SRA and the only purpose was to attempt to divert fees and

commissions from SoFla. Lawlor no longer is certified to act as an NFL sports agent.

66. During Butler’s employment with SoFla, Butler entered into Player Marketing

Advances on behalf of SoFla with various SoFla Clients. Pursuant to the terms and conditions of

the Player Marketing Advances, each Player who entered into such an agreement was obligated

to repay the advances from the fees the Player received from any marketing or sponsorship

agreements.

67. The marketing advances arranged for and provided by Butler, using SoFla funds,

include the following: Mike Gillislee ($20,000); Corn Elder ($50,000); Damontae Kazee

($40,000); and, Elijah McGuire ($35,000).

68. Butler has failed to recover essentially all of the Marketing Advances and has

interfered with SoFla’s ability to recover the marketing advances Butler provided, using SoFla

funds, to SoFla clients.

69. EPIC now advertises on its website that Gillislee, Elder, Kazee and McGuire are

clients.

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AS AND FOR A FIRST CAUSE OF ACTION


(Tortious Interference With
Contractual Relations Against EPIC)

70. Plaintiff repeats and realleges each of the allegations set forth in Paragraphs 1 –

69 above, as if fully set forth herein.

71. The Agreements represent valid contracts between SoFla and Butler.

72. At all relevant times, EPIC had knowledge of the Agreements and their

provisions.

73. EPIC, a non-party to the Agreements, intentionally procured and actively

participated in Butler’s breach of the Agreements without justification.

74. Butler has breached the Agreements by, inter alia, diverting funds to himself

and/or EPIC that are required to be paid to SoFla under the Agreements and causing NFL Players

to terminate their business relations with SoFla and enter into contracts with EPIC agents to

provide representation to those NFL players.

75. EPIC tortiously interfered with SoFla’s contractual relations.

76. By reason of the foregoing, SoFla has suffered monetary damages to be

determined at trial but not less than $10,000,000.

AS AND FOR A SECOND CAUSE OF ACTION


(Tortious Interference With
Prospective Business Relations Against EPIC and Butler)

77. Plaintiff repeats and realleges each of the allegations set forth in Paragraphs 1 –

69 above, as if fully set forth herein.

78. SoFla has business relations with NFL Players, including as a result of its

employees representing Clients in negotiations with NFL teams and in marketing arrangements.

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79. EPIC and Butler interfered with those business relations – and at the same time

violated NFLPA Regulations governing activities of Certified Contract Advisors -- by causing at

least fifteen NFL Players whom SoFla represented to leave SoFla and enter into contracts with

EPIC and its Contract Advisors to provide representation to those NFL Players.

80. EPIC and Butler acted for the sole purpose of harming SoFla and benefiting EPIC

and Butler or used wrongful means in causing such harm.

81. EPIC and Butler tortiously interfered with SoFla’s business relationships with its

Clients.

82. As the result of EPIC’s and Butler’s wrongful conduct, the NFL Players have

terminated their business relations with SoFla, which has caused injury to SoFla.

83. By reason of the foregoing, SoFla has suffered monetary damages to be

determined at trial but not less than $10,000,000.

AS AND FOR A THIRD CAUSE OF ACTION


(Aiding and Abetting A Breach Of Fiduciary Duty Against EPIC)

84. Plaintiff repeats and realleges each of the allegations set forth in Paragraphs 1 –

69 above, as if fully set forth herein.

85. Butler, by reason of his employment with SoFla, owed fiduciary duties, including

a duty of loyalty, to SoFla.

86. Butler breached his fiduciary duties to SoFla by, inter alia, diverting funds owed

to SoFla to himself and EPIC and causing NFL Players to terminate their business relations with

SoFla.

87. EPIC had actual knowledge of Butler’s fiduciary duties to SoFla,

including, inter alia, Butler’s obligations to SoFla under the Agreements, and his breach of

those fiduciary duties.

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88. EPIC aided and abetted, knowingly induced and/or substantially participated in

causing Butler to breach his fiduciary duties, including his duty of loyalty, to SoFla.

89. By reason of the foregoing, SoFla has suffered monetary damages to be

determined at trial but not less than $10,000,000.

AS AND FOR A FOURTH CAUSE OF ACTION


(Conversion Against EPIC and Butler)

90. Plaintiff repeats and realleges each of the allegations set forth in Paragraphs 1 –

69 above, as if fully set forth herein.

91. SoFla had the right to possession of funds earned under the Agreements as a result

of the representation of NFL Players.

92. EPIC and Butler have with wrongful intent interfered with SoFla’s property rights

under the Agreements without authority by causing and/or participating in the diversion to Butler

and/or EPIC of funds owed to SoFla under the Agreements.

93. By wrongfully interfering with SoFla’s property rights in the funds owed to it

under the Agreements, EPIC and Butler exercised unlawful dominion and control over SoFla’s

property and have converted those funds.

94. By reason of the foregoing, SoFla has suffered monetary damages to be

determined at trial but not less than $10,000,000.

AS AND FOR A FIFTH CAUSE OF ACTION


(Civil Conspiracy Against EPIC and Butler)

95. Plaintiff repeats and realleges each of the allegations set forth in Paragraphs 1 –

69 above, as if fully set forth herein.

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96. In furtherance of their plan, EPIC and Butler entered into an unlawful agreement,

inter alia, to divert funds owed under the Agreements to SoFla and wrongfully to cause NFL

Players to terminate their business relations with SoFla.

97. EPIC and Butler intentionally participated in a plan whose purpose was to commit

the tortious acts set forth above, including diverting to Butler and/or EPIC funds owed to SoFla

under the Agreements and wrongfully causing NFL Players to terminate their business relations

with SoFla.

98. EPIC and Butler committed overt acts in furtherance of their unlawful conspiracy

including, inter alia, the following: diverting, receiving and withholding of funds properly

payable to SoFla under the Agreements from Corey Liuget, Kareem Jackson, Philip Dorsett,

Denzel Perryman and Patrick Robinson; and, substituting Certified Contract Advisors employed

by or affiliated with SoFla with Certified Contract Advisors employed by or affiliated with

EPIC, including Butler on NFL Players’ SRAs including, but not limited to, Corey Liuget,

Kareem Jackson and David Sharpe.

99. By reason of the foregoing, SoFla has suffered monetary damages to be

determined at trial but not less than $10,000,000.

WHEREFORE, Plaintiff SoFla Sports, LLC demands judgment against Entertainers &

Players Innovative Consultants, LLC on its First through Fifth Causes of Action in its Complaint

and against Butler on its Second, Fourth and Fifth Causes of Action in its Complaint, as follows:

(A) On Plaintiff’s First Cause of Action for Tortious Interference With Contractual

Relations, monetary damages in an amount to be determined at trial but not less

than $10,000,000;

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(B) On Plaintiff’s Second Cause of Action for Tortious Interference with Prospective

Business Relations, monetary damages in an amount to be determined at trial but

not less than $10,000,000;

(C) On Plaintiff’s Third Cause of Action for Assisting a Breach of Fiduciary Duty,

monetary damages in an amount to be determined at trial but not less than

$10,000,000;

(D) On Plaintiff’s Fourth Cause of Action for Conversion monetary damages in an

amount to be determined at trial but not less than $10,000,000;

(E) On Plaintiff’s Fifth Cause of Action for Civil Conspiracy, monetary damages in

an amount to be determined at trial but not less than $10,000,000;

(F) The costs and disbursements of the action, including reasonable attorney’s fees;

(G) Applicable pre-judgment interest; and

(H) Such other and further relief the Court deems just and proper.

Dated: New York, New York


November 15, 2018

ROBINSON BROG LEINWAND GREENE


GENOVESE & GLUCK P.C.

By: /s/ Peter R. Ginsberg


Peter R. Ginsberg, Esq.
875 Third Ave, 9th Floor
New York, NY 10022-0123
(212) 603-6300
(prg@robinsonbrog.com)

Attorneys for Plaintiff

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FILED: NEW YORK COUNTY CLERK 11/15/2018 12:11 PM INDEX NO. 655696/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/15/2018

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