8 9 10 11

Defendants.

1 Richard Ross #048576 Attorney at Law

2 424 South Beverly Drive Beverly Hills, CA 90212 3 Ph: 310-277-4360

Fx: 310-277-4693

4 rro§s777@earthHnk.net

5

Attorney for Plaintiffs George Lopez and 6 Tambien Productions, Inc.

7

~J1I~~ OffloerJClerK '~~~~~~Oeputy

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SUPERIOR COURT OF THE STATE OF CAllFOf1~J1A

FOR THE COUNTY OF LOS ANGELES I

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Case No. B C 4 r 4 0 4 ~

COMPLAINT FOR'

1. BREACH OF C NTRACT

2. BREACH OF T E IMPLIED COVENANT F GOOD FAITH AND FAIR DE LING

3. ACCOUNTING

GEORGE lOPEZ, an individual, and 12 TAMBIEN PRODUCTIONS, INC., a California Corporation,

Plaintiffs,

13

14 15

vs.

PARAMOUNT PICTURES

16 CORPORATION, and its Television Distribution Division, PARAMOUNT 17 HOME ENTERTAINMENT DISTRIBUTION, INC., a Delaware 18 Corporation, and Does 1 through 50, inclusive,

19 20 21 22 23

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COMPlAINT

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JURY TRIAL DE~ANDED

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UNLIMITED JURrSDICTii j e fa E DAMAGES EXC m (J~ ~ ; ~

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Plaintiffs George Lopez and Tambien Productions, Inc., allege rs follows:

NATURE OF THE ACTION I

1. This is an action commenced by George Lopez ("Lopez") 1nd Tambien

4 Productions, Inc.{"Tambien"), a California corporation, creators, devejopers, producers,

s writers of and performers in extremely successful television programring as well as 6 Lopez being a performer in theatrical motion pictures and being a perorrner in 1lve

7 stand-up comedy concerts. This action is Instituted to protect and tojrecelve the share B of receipts due them from the videogram exploitation of an original fmedY concert

9 entitled Why You Crying. i

10 2. Receipt by plaintiffs of their proper share of receipts has en frustrated by

11 the actions of Paramount Pictures and its television distribution dlvi ion, Paramount 12 Home Entertainment (hereinafter collectively referred to as uparam1unt").

PARTIES AND BACKGROUND I

I

3. Lopez is an individual residing in the County Of Los AngelrS, State of

15 California. f!

16 4. Tambien Productions, Inc., is a corporation duly existing nder and by virtue

17 of the laws of the State of California with its principal office for the nduct of business

I

18 located in the County of Los Angeles, State of California. I

19 5. Paramount Pictures is a corporation with its principal offi~e for the conduct of

20 business located in the County of Los Angeles, State of California. i

I

. I

6. Paramount Home Entertainment is a television distributi9n division of

22 Paramount Pictures Corporation known as Paramount Home Enteftainment

23 Distribution, Inc., with its principal office for the conduct of businesr located in the

County of Los Angeles, State of California. !

7. Defendants Does 1 through 50, inclusive, are sued hereIn under their fictitious names, the true names and capacities are unknown to Plrintiff. When their true names and capacities are ascertained, plaintiffs will amend this cimp,aint by asserting

28 2 I

~~----------4-----------------

COMPLAINT I

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1

2

3

13

14

21

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125

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1 their true names and capacities herein. Plaintiffs are informed and believe and based 2 thereon allege that each of the fictitiously named defendants is resp01sible in some

3 manner for the occurrences herein alleged, and that plaintiffs' damagts as herein

4 alleged were legally caused by said defendants. I

5 8. At all times herein mentioned each of the defendants Para~ount Pictures and

I

6 Paramount Home Entertainment and Does 1 through 50, inclusive, w~s and is, the

7 agent, servant, employee, conspirator, jOint venturer, partner, aider ahd abettor,

8 guarantor, indemnitor, and/or surety of each of their co-defendants ahd was acting 9 within the scope of their authority within such relationship, and with t~e permission,

10 consent and knowledge of said co-defendants. I

I

11 9. Tambien Productions, Inc., is a producer of television pro raming and is an

12 entity furnishing the services of Lopez and is controlled by Lopez. L pez is a creator, 13 developer, writer of and performer in very successful television prog amingand is

14 responsible for successful television programming in the capacities pf performer, writer, 15 producer, creator, and developer of five seasons of the George LOprZ Show, Lopez

16 Tonight, and multiple comedy concerts. Lopez has been directly invplved in hundreds of 17 hours of television programming. In addition, he has appeared in th~atrical motion

18 pictures, such as Valentine's Day and Swing Vote. Why You Cl}1np has been

19 extremely successful in the home video market having, to date, getrated

20 approximately $5,000,000 of gross receipts to defendants. But be use of accounting

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21 irregularities and because defendants have overstated permissible/deductible costs and

22 have failed to supply documentation In support of such costs, a su~ in excess of

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23 $700,000 has been wrongfully withheld from plaintiffs through APril 26, 2008.

BACKGROUND AND FACTUAL ALLEGATIONS CqMMON

TO ALL CAUSES OF ACTION. !

10. On or about March 16,2005, plaintiffs entered into a written agreement with defendants granting defendants the right to exploit in the home vi1eo market a comedy

________________________ 3.~=_ ----+1~----------

ro~~lm I

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I 1 concert starring plaintiff which had premiered as a Showtime special1n

2 May 29 - 31, 2004. The rights granted are known as a videogram wh~ch means all 3 forms and formats of video recordings or devices intended for home ~se.

I I

4 11. In exchange for the grant of rights to defendants for a ten year term (as

5 defined in the written agreement), plaintiffs were to receive seventy-fi~e percent (75%) 6 of the gross receipts after deducting from gross receipts a distributiorl fee and

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7 permissible deductible costs. I

12. The agreement further provided that defendants maintainl at their offices in 9 Los Angeles, California, complete books and records with respect to/defendants'

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10 distribution and exploitation of the program. It was further provided tat plaintiffs, by

11 means of a certified public accountant, could examine the books an1 records pertaining 12 to the distribution and exploitation of the program in order to determIne the accuracy of 13 any statement rendered by defendants pursuant to the agreement. I

i

13. The agreement further provided that defendants WOUldfnder periodiC

15 distribution statements containing reasonable written detail of gross receipts and

16 permissible deductible costs accompanied by a remittance of the a I aunt due plaintiffs.

17 14. Because reasonable written detail was not provided in tre distribution

18 statements, plaintiffs were required to seek to audit the books and ~ecordS in

19 accordance with their contractual rights. I

20 15. On or about November 7, 2006, plaintiffs informed def~ndants in writing that

21 they intended to conduct an audit.

8

4

--------------------------~C~O~MP~LN~N~T~---------+---------------

14

22 16. Even though this audit is limited in breadth and scope, nd an audit of this

23 nature could have been conducted within a period of three to four onths, defendants

:;24 /' 1.25 '5~ ~t26

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1 027

would not consent to the audit commencing until December 17, 29°7.

17. Notwithstanding defendants' commitment to permittin~ the audit to commence on December 17,2007, it ignored its commitment. Derendants refused to

permit the audit to commence until August 18, 2008. .

28

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18. Although defendants, through their certified public accounrant auditors, 2 repeatedly verbally and in writing requested supporting documentatior for required 3 categories of expenses contained in the distribution statements, the ~upportlng

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4 documentation was not provided. There was either inadequate docurpentation or the

5 complete absence of documentation. I

19. Defendants continually represented there was either SU~cient

7 documentation or that they would supply the required documentatlori until finally they I

8 just ignored requests for documentation. I

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20. Documentation for over $1,000,000 in distribution costs ~as requested by

10 plaintiffs' auditors on March 3, 2009. Three months later defendant~ provided a

11 methodology for supporting these purported distribution costs. The lauditors were

12 willing to try defendants' proposed methodology. Notwithstanding, ~efendants refused 13 to supply any further documentation./

21. Defendants prevented the audit from occurring for a + of twenty-one IS months. When they finally permitted the audit to commence, their rjnultiple

16 mlsrepresentaticns, upon which plaintiffs' auditors reasonably reliet, caused the 17 preparation of the audit to be further delayed. Completion of the a. dit was in fact 18 delayed for a period of two years as a result of defendants' Obstru~tions and

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19 misrepresentations. :

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20 22. For the period of inception through April 26, 2008, the budit report revealed

21 unsupported deductions by defendants of $1 ,219,495. Even thou~h over six months

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22 have elapsed since the rendering of the audit report, defendants ~ave been able to

23 provide support for just a minor percentage of the unsupported de~UCtions leaving an

i

amount In excess of $800,000 in unsupported deductions. As a r~ult, through the i

period of April 26t 2008, over $600,000 has been wrongfully with~eld from plaintiffs.

FIRST CAUSE OF ACTION FOR BREACH OF CO~TRACT

23. Plaintiffs reallege and incorporate paragraphs 1 through 22, inclusive, as I

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9

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though fully set forth in full herein. I

24. Plaintiffs have performed aU conditions, covenants and prO~ises required 3 by them on their part to be performed in accordance with the terms of ~he written

4 agreement, dated as of March 16, 2005. I

25. On or about November 7,2006 and again on or about on ~ecember 17,

6 2007, defendants breached the contract by refusing to permit an audl~ of its books and I

7 records and not permitting an audit to commence until on or about August 18, 2008.

26. In further breach of contract, defendants rendered distribJtion statements I

9 on or about March 10, 2006, on or about June 30, 2006, on or about peptember 27,

10 2006, on or about January 3,2007, on or about April 2, 2007, on or about July 5, 2007, I

lIon or about February 8, 2008, on or about July 21, 2008, on or abou~ February 24,

12 2009, on or about June 28,2009 and on or about January 27,2010, lin which

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13 defendants materially breached the contract by improperly deductinQ from gross

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14 receipts, as reported to plaintiffs, excessive amounts for discounts apd rebates, price

15 protections, ad and publicity costs, co-op advertising, prints and tranisportation.

27. As a result of defendants' breach of the contract, PlaintiJs have been

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17 damaged In a sum not yet ascertained, but through April 26, 2008, *elieved to be in

18 excess of $700,000 together with prejudgment and post-judgment i~terest. When such 19 damages are ascertained, plaintiffs shall seek leave of court to amdnd this complaint to

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20 set forth the same. I

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2

THE SECOND CAYSE OF ACTION FOR BREACH OF fveNANT OF GOOD EA1TH AND FAIR DEALING. I

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28. Plaintiffs reallege and incorporate paragraphs 1 throU9r 27, inclusive, as

though fully set forth in full herein .

29. The agreement contains a covenant implied by law th~t defendants will act

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towards plaintiffs in good faith and with fair dealing. i

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30. The implied covenant of good faith and fair dealing imroses upon

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1 defendants the duty to not take any actions with the motive to intentiorl3Uy frustrate the

2 plaintiffs' enjoyment of their rights and benefits under the agreement. In doing the acts 3 alleged herein, defendants have breached the covenant of good faith ~nd fair dealing 4 implied in the agreement in that defendants in bad faith and with a mJive intentionally 5 to frustrate plaintiffs' enjoyment of their rights and benefits under the Jgreement, have 6 perpetrated the above described acts and omissions by and through ~bstructing and

7 frustrating an audit and by overstating permissible deductions on the ~istrlbution

8 statements. This has served to deprive plaintiffs of their rightful shar~ of gross receipts 9 to be derived from the distribution and exploitation of their comedy ~ncert because

10 defendants have received revenues generated from the exploitation In video format of 11 the comedy concert and have withheld from plaintiffs the amounts ri~htfUIlY due them. 31. As a direct and legal result of the above described acts if defendants,

13 plaintiffs have been damaged in an amount according to proof. Plairtiffs will seek leave 14 of court to amend this complaint to reflect said sum when it has bee I ascertained.

12

32. Plaintiffs reallege and incorporate paragraphs 1 throug 27, inclusive, as I

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15 16

17 though fully set forth in full herein.

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33. Pursuant to the agreement, defendants are obligated tq provide plaintiffs

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19 with distribution statements accurately reflecting the amount of grOfs receipts and

20 expenses derived from and ariSing from the exploitation in the ho~e video market for 21 the comedy concert. Because of the overstatement of costs and ekpenses associated

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22 with exploitation of the comedy concert, defendants have failed to remit to plaintiffs their

23 appropriate share of such receipts. I

34. Despite demand therefor, defendants have failed and refused, and continue to fail and refuse, to provide plaintiffs with proper and accurate acCounting reflecting the I

amount due them from exploitation of the comedy concert. I

35. An accounting is required to determine the amount of receipts and

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permissible deductions from the distribution and exploitation of Why Y9U Crying.

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WHEREFORE, plaintiffs George Lopez and Tamblen Productions, Inc., pray for

3 judgment against defendants and each of them as follows: /

FIRST AND SECOND CAUSES OF ACTION I

2

4 5 6

7 8 9

10 11 12

13 Dated: March 18,2010

1. For actual and compensatory damages In an amount accor~in9 to proof.

/1

2. For an accounting,

3. For actual and compensatory damages required thereby, I

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4, For costs of suit incurred herein, and i

5. For such other and further relief as the court may deem pr4per.

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THIRD CAUSE OF ACTION

FOR ALL CAUSES OF ACTION

RICHAR9 ROSS

I

14 15 16 17 18 19 20 21 22 23

324

1. 25 8 /26

1

28

(Nome,

chard Ross #048576 424 S. Beverly Drive Beverly Hills, CA 90212 Ph: 310-277-4360

Fx: 310-277-4693

SUPERIOR COURT Of CAUfORNIA, COUNTY OF Lo s Ange 1 e s sTREETADOREss,111 North Hill Street W,ILINGADDRESS: 111 North Hi 11 Street

CITY AND ZIP CODE.: Los e Le s , CA 90012

CASE NAME:

CIVIL CASE COVER SHEET 00 Unlimited 0 Limited

Auto Tort

BAutO(22)

Uml1$urec mo\omt (46)

Other PIIPDIWD (Pen;onallnjury/Property Damage/Wrongful Death) Tort

o Asbestos (04)

o Product liability (24)

o Medical malpractice (45)

o Other PIIPOIVVD (23) Non.pIlPDIWD (other) Tort

o Business torVunfalr business Ptactice (07)

o Civil rights (08)

o Defamation (13)

o Fraud (16)

o Intellectual property (19)

o Professional negllgrmC8 (25)

o Other non-PIIPDIWD tort (35)

Employment

o Wrongful termination (36)

Complex Case Designation o Counter 0 Joinder

Flied with first appearance by defendant (Cal. Rules of Court, rule 3.402)

Conb'act

CXJ Breach of contract/warranty (OO) o Rule 3.740 collections (09) D Other collections (09)

o Insurance coverage (18)

o Other contract (37) Real Property

o Eminent domain/Inverse

condemnatlon (14)

o WrongfUl evlctlon (33)

o Other real property (26)

Unlawful Detainer

o Commercial (31) D RGlIlceml.d (32) DDNgs(38)

JudiCial Review

o Asset forfeiture (OS)

Petition re: arbitration award (11) Writ 01 mandate (02)

Other judicial review

Co~nDlllx Civil Litigation rules 3.400.3.403}

regulation (03)

(10)

""",,"',,;nt (not specified above) (42) Petition

PanlnAnoh!1'I1 and corporate governance (21) (not Bp9cffled above) (43)

2. This case \s is not complex under I\lle 3.400 of the CalifOl'nia Rules of Court. If

factors reqUiring exceptional judicial management:

a. 0 Large number of separately represented parties d. 0 Large number of witnesses

b. 0 Extensive motion practice raising difficult or novel e. 0 Coordination with related

issues that will be time-consumlng to resolve in other counties, states, or

c. 0 Substantial amount of docu mentary evidence f. 0 Substantial postjudgment

3. Remedies sought (check 011/ that apply); a. 00 monetary b. 0 nonmonetary; declaratory or 'IUL,nr:l'VR

4. Number of causes of action (specify): 3

5. This case 0 is [][J is not a class acuon suit.

6. If are any known related cases, file and serve a notice of related case,

March 18, 2010

case is ccm?lex, mark the

NOTICE

must file this cover sheet with the first paper flied in the action or proceE"~illlg unoersne Probate Code, Family Code, or Welfare and Institutions Code).

--

INSTRUcttNS ON HOW TO COMPLETe THE CO~SHEeT CM-010

To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) n a civil case, you must complete and file, along with your first paper, the eMf Case Cover Sheet contained on page 1, This informa on will be used to compile statistics about the types and numbers of cases filed. YOu must complete Items 1 through 6 on the sheet. n item 1, you must check one box for the case type that best describes the case. If the case fits both a general and a more specific e of case listed in item 1, check the 11'101'$ specific one. H the case has multiple causes of action, check the box that best Indicates th primary cause of action. To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 a provided below. A cover

sheet must be filed only with your Initial paper, Failure to file a cover sheet with the first paper flied In a civil se may subject a party, its

counsel, or both to sanctions under rules 2,30 and 3.220 of the California Rules of Court. I

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 ~m a transaction in Which property, services, or money was acquired on credit A collections case does not include an action se,klng the following: (1) tort damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejpdgment 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 fe general time-for-service requirements and case management rules, unless a defendant flies a responsive pleading. A rule 3.740 col actions case will be subject to the requirements for servlce ana obtaining a judgment In nne 3,740.

To Parties In Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sh6ft to designate whether the case Is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Co~~, this must be indicated by completing the appropriate boxes In items 1 and 2. If a plaintiff designates a case as complex, the cover s~t must be served with the complaInt on all partles to the action. A defendant may file and serve no later than the time of its first ppearance a joinder in the pl~intiff's designation, a counter-<!esignation that the case Is not complex, or, if the plaintiff has made no d ignation, a deSignation that

the case Is complex. CASE lYPES AND EXAMPLES I

Auto Tort Contract ProV[SionanY~ C plex clVn Utigatlon (Cal.

Auto (22)-PersonaJ Injury/Property Breach of Contract/Warranty (06) Rl.Ilils of Court 1" 3.400-3.403)

DamageIVVrongtul Death Breach of RentaUlease AntllrUst/T ade Regulation {03}

Uninsured Motort&t (46) (If the Contract (not unlawful delalner Construct! n Defect (10)

case J~voIv~s an unlnsurad orwrongfulrJvictlon) Claims In olving Mass Tort (40)

mol list cI rn b"""' to ContractlWarranty Breach-Seller

o 81 au ~""~. Pl.llntlff (not fraud or nAn/igencfJ\ Securilies'L)\lgatlon (28)

aroitralion, check Ihi& Item ~.. ~ EnvI~ntallToxlc Tort (30)

Instead of AUto) Ne~~=n:each of Contract! Insu~~T Coverage Claims

Other PIIPDIWD (Personlllinjuryf Other Breach of ConlractM'arran!y (arislnp from provisionally camp/ex

Property Damago!Wrongful Death) Collections (e.g., money owed, open case o/pe l!stect above) (41\

Tort boollliocounts) (09) Eft ..... J d t

klbeslO$ (04) Collection Case-Seller Plaintiff n or~mlln "". u gman

Asbestos Property Damage Other Promls$Qry Note/Collections Enforceml~nt of Judgment (20)

Asbestos Personal InJuryl Casa Abstr,ct of Judgment {Out of

WrongfulOea'" Insurar.ce Coverage (not provfsionally ~unty)

Product Uabllity (not asbestos or complex) (18) Conf~ssion of JUdgment (non-

tOxic/environmental) (24) Auto Subrogation domestic relatkms)

Medical Malpractice (45) Other Coverage Siata~tate Judgment

Medical Malpractice- Other Contract (37) Adml Istratlve Agency Award

PhYSicians & Surgeons Cootractua\ Fraud ( t unpak1laxas)

Other Professional Health Care Other Contract DIspute Petit Certification of Entry of

Malpractice Real Property J gmenton Unpaid Taxes

Other PI/PD/WD (23) Eminent Domain/Inverse Othel nforcement of Judgment

Premises UabiUty (e.g., slip Condemn{ltlon (14) e

and faU) Wrongful Eviction (33) MtlicilUanao Civil Complaint

Intentional Bodily InJuryfPDlWD Other ReElI Property (e.g., quiet title) (26) RICO (2 )

(e.g., assault, vandallsrn) Writ of Possenion of Real Property Other mplalnt (not speclfi9rJ

Intentionallnfllclion of Mortgage Foreclosure abo e) (42)

Emotlonal Dlstress Quiet Title ratory Relle~ Only

Ne"Jj"""'t Infliction of Other Real Property (not eminent Inju va Relief Only 'non.

"" ,,_. domain, landlordllenant, or l'

Emotional Distress forBoIOBure) arassment)

Other PlfPDIWD UnlawfUl ~talner Me nics Uen

Non-PIIPDIWD (Othar) Tort Commeroial {31} Oth r Commercial Complaint

Business TortlUnfair Business Residential (32) tase (non-torllnon-complex)

Practice (07) Drugs (38) (If the case Involves Illegal Olh r Civil COmplaint

Civil Rights (e.g .• diSCrimination, drugs, check this itBm; otherwise, . on-torVnon-complex)

falsEl<6rrest) (not cIVil report as Commercial or Resfdential} Misceu~neo •. Clvll PetItion

htJ~ment) (08) Judicial Review . P hIp and CQrj)orata

DefamallOn (e.g., slander, libel) Asset Forfellure (OS) G emanoa (21)

(13)j Petition Re; Arbilratlon Awerd (11) Othe;titiDn (not specified

FraUd (~) Writ of Mandate (02) II vel (43)

IntellectS;,I Pro~ (19) Wril-Ac!mlnimrative Mandamus Clv I Harsssment

Prof~nal Negligente (25) Wrlt-Mandamus on limited Court W lace Violence

~ Malpractloe Case M{ltter Eld r/Dependent Adult

....... t:.a W· oth Abusa

.... u 'I," Profe~lOnal Malpractice nt- er Limited Court Casa El lion Contest

(not medical or legal) Review P !ion for Name Change

Othllf Non--PIJPDlWD Tort (35) Other Judlcla' Ravlllw (39) PEt ition for Rellaf from Late

·Empl~nt Revlew of Health Officer Order

Wrongful TennlnaUon (36) Notice of Appeal--Ulbor Claim

Other Employment (15) Commissioner Appeals Otl er Civil Petition

I

CM-OiCjRw,Jut)'1,2OOTl eM\. CASE COVER SHEET I

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•

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE

Item I. Check the types of hearing and fill in the estimated length of hearing expected for this

JURY TRIAL? 0 YES CLASS A.cTION? 0 YES LIMITED cASE? 0 YES TIME ESTIMATED FOR TRIAL -+_ ....... -'-'==~~=~ Item II. Select the correct district and courthouse location (4 steps - If you checked "Limited Step 1: After first completing the Civil Case Cover Sheet Form, find the main civil case cover the left margin below, and, to the right in Column A. the CMI Case Cover Sheet case type you SelE~C\eo. Step 2: Check one Superior Court type of action in Column 8 below which best describes the Step 3: In Column C, circle the reason for the court location choice that applies to the type of For any exception to the court location, see Los Angeles Superior Court Local Rule 2.0.

Applicable Reasons for Choosing Courthouse Location (See Column C

1. Class Actions must be in the County Courthouse, Central District. 6.

2. May be filed in Central (Other county, or no Bodily Injury/Property Damage).

3. Lo~on where cause of action arose.

4. LocatIon where bodily InJUry, daath or damage occurred.

5. Location where periormanC!;! required or defendant resides. 10. tccanon of Labor r .... " ... H.,.,I, .... or

Step 4: Fill in the information requested on page 4in Item III; complete Item IV. Sign the declaration

CIvil

A

Cover Sheet No.

B

C

Applicable Reasons· See Step 3 Allova

Asbestos (04)

~~r-----------+-------------------~--~------------~~----------~ 1l.I ....

%..s::

~ ~ r-------------~--------------------------~-------------------4--~------------~

~l5

::1-

'E'::I

==

~ c r--------------;--~-------------------------------------------4---+------------~

ce

~.~

l.&

... 0)

~i

00

Product Liability (24)

Medical Malpractice (45)

Other Personal Injury Property Damage Wrongful Death (23)

(16)

LACIV 109 (Rev. 01107) LASe Approved 03-04

cwu, CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

lAse, rule 2.0 Page 1 of4 ~B1

. .

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•
e e
SHORTm~E: Lopez v. Paramount Home Ent. 1 CASE NUMBER I \
A B C
Civil Cap Cover Type of Action Appllcabl(l Reasons
Sheet Category No. (Check only one) • See Step 3 Above
Professional 0 A6017 l(lgal Malpractice I 1.,2.,3.
Negligence
(25) 0 A6050 other professional Malpractice (not medical or legal) 1.,2.,3.
Other (35) D 1\6025 Other Non-Personal Injury/Property Damege tort I 2.,3.
Wrongful Tennlnatlon 0 A6037 Wrongful Terminallon 1.,2.,3.
(36)
Other Employment 0 A6024 Other Employment Complaint Case I 1 .• 2-, 3.
(15) 0 A6109 Lawr Commisslooer Appeals 10.
Breach of Contract! 0 A6004 Breach of Rental/Lease Contract (not Unlawful Detainer or wrongful
eviction) 2.,5.
Warranty 0 M008 ContractlWerranty Breach -Seller Plaintiff (no fraud/negligence) I 2 .. 5.
(06) 0
(not Insurance) 1\6019 Negligent Breach of ContractiWarranty (no fraud) I 1.,2.,5.
00 ! 1 .. @5.
A6028 Other Breach of ContractiWarranty (not fraud or negligence) i
0 A6002 Collections Case-Seller Plaintiff I 2,5.,6.
Collections I
(09) 0 A6012 other Promissory Note/Collectlons Case I 2" 5,
Insurance Coverage 0 A6015 Insurance Coverage (not complex) r 1.,2 .. 5.,8.
(18) i
Other Contract 0 Moo9 Contractual Fraud I 1.,2.,3.,5.
(37) 0 A6031 Tortious Interference 1.,2 .• 3.,5.
I
0 A6027 Other Contract Dispute{not breach!lnsurancelfraudlnegligence) I 1.,2.,3.,8.
Eminent i
Domain/Inverse 0 A7300 Eminent Domain/Condemnation Number of parcels __ I 2.
I
Condemnation (14) !
Wrongful Eviction 0 A6023 Wrongful Eviction Case i 2.,6.
(33)
Other Real Property 0 A6018 Mortgage Foreclosure I 2.,6.
(26) 0 A6032 Quiet T1tla I 2. ,6.
I I
0 A6060 Other Real Property (not eminent domain, landlord/tenant, rore~osure 2.,6.
Unlawful Detainer - 0 A6021 Unlawful Detainer-Gommercial (not drugs or wrongful eviction)
Commercial (31) 2.,6.
Unlawful Detainer - 0 I
ResIdential (32) A6020 Unlawful Oetalner-Residential (not drugs or wrongful eviction) I 2.,6.
;~ i
Unla'Wfu1 Detainer - 0 A6022 Unlawful Detainer-Drugs
9rugS (38) 2.,6.
I
r;l 1
Asseil:orfelture (05) 0 A610B Asset Forfeiture Case 2.,6.
"' ,
j_ 0 !
Petl\l~ \'$ Arbitration {1 ~) A6115 Petition \1) CompellConlhmNacate Albitrat\on 2.,5.
I
1 LACIV 109 (Rev. 01107) lASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

LAse, rule 2.0 Page 20f4

~ .

.
•
SI10RT l1TL.E: Lopez v. Paramount Home Ent. I CASE NUMBER
I

A B ! C
Civil Case Cover Sheet Type of Action i Applicable Reasons·
Category No. (Check only one) See Step 3 Above
0 A6151 Writ - Administrative Mandamus 2.,6.
Writ of Mandate 0 A.615Z Wrlt· Mandamus on Limited Court Case Matter 2.
(02) 0 A6153 Writ· Other Limited Court Case Review 2.
Other Judicial Revlew 0 A6150 Other Writ ( Judicial Review I 2.,8.
(39)
Ar1titrf.J&VTrade 0 Mooa AntltrusVTrade Regulation 1.,2,8.
Regulation (03)
Construction Defect (10) 0 A6007 ConstructLon defect. 1.,2.,3.
Claims Involving Mass 0 MOo6 Claims Involving Mass Tort I 1,,2.,8.
Tort (40) I
Securities Utlgatloo (28) 0 A6oo5 Seountle& Utlgatlon Case 1.,2 .. 8,
Toxic Tort 0 M036 Terne Tort/environmental 1.,2" 3., B.
EnvlTonrnental L~ I
I
Insurance Coverage 0 A6014 Insurance Coverage/Subrogation (complex case only) 1.,2.,5 .. 8.
Claims from Complex
Case (41)
0 A6141 Sister State Judgment 2.,9.
Enforcement 0 A6160 Abstraclof Judgment 2,6.
of Judgment 0 AB107 Confession of Judgment (non-dorne&tic relations) 2.,9.
(20) 0 A6140 Admlnistrallve Agency Award (not unpaid taxes) 2.,8.
0 A6114 Petition/Cerlillcate for Entry of Judgment on Unpaid Tax 2.,8.
0 A6112 Other Enforcement of Juo;lgment Case 2.,6.,9.
RICO (27) 0 Moo3 Racketeering (RICO) Case I 1.,2.,6.
0 ASo30 Declaratory Relief Only 1.,2,,8.
Other Complaints 0
(Not Specified Above) AS040 Injunctive Relief Only (not domast!clharassment) 2.,6.
0 M011 Other Commercial Complaint Case (non-Iortlnon-complex) 1.,2.,8.
(42) 0 A6000 Other Civil Complaint (non-tortlnon-complex) 1.,2.,6.
Partnership """~.":"'"
,.. "(21) 0 A6113 Partnership and Corporate Governance Case 2.,8.
0 A6121 Civil Harassmen\ 2.,3.,9.
:)i 0 A6l23 WOI'kplace Harassment 2.,3.,9.
Ot~ Petitlons 0 AS124 EldWlOependent Adult Abuse Case 2.,3.,9.
(Not Spedfied Above)
~~ (43) 0 A6190 Election Contest 2.
} 0 MHO Petition for Change of Name 2.,7.
i
}: 0 A6170 Petllion for Relief from Late Claim Law 2.,3.,4., S.
~} 0 11.6100 Other CMl Pet\tlon 2.,9.

LACIV 109 (Rev, 01/07) CIVIL CASE COVER SHEET ADDENDUM I LAse, rule 2.0
I
lASe AppTO'Jsd 03-Q4 AND STATEMENT OF LOCATtON I Page 30f4
I
I ,.... . .

performance, or location you selected.

SHORTnn.~ Lopez v , Paramount Home Ent.

Item III. Statement of Location: Enter the address of the accident, party's residence or place of other circumstance indicated in Item iI., Step 3 on Page 1, as the proper reason for filing in the

01. 002.03. 04. 05. 06. 07. 08.09. 010.

REASON: CHECK THE NUMeER UNDER COLUMN C WHICH APPLIES IN THIS CASE ADDRESS:

paramount pictures 5555 Melrose Avenue

Cl1Y;

Hollywood

STATE:

CA

ZIP CODE;

90038

Item IV. Declaration of Assignment: I declare under penalty of perjury under the laws of tI:le State!

foregoing is true and correct and that the above.entitled matter is properly filed for .

Superior Court courthouse In the Central District (Code CIv. Proc., § 392 et seq., and LASC Local Rule 2.0, subds, (b), (c) and (d».

Dated: _-,M .... a,."r....,c"'-l,h.......,.1:,.>::8"L( --==.2 O,,-l:::..;O~_

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE

PROPERLY COMM YOUR N

1. Original Complaint or Petition.

2. If filing a Complaint, a completed Summons form for issuance by the Clerk.

3. Civil Case Cover Sheet form CM-010.

4. Complete Addendum to Civil Case Cover Sheet form LACIV 109 (Rev 01/07), LASe

5. Payment in full of the filing fee, unless fees have been waived.

6. Signed order appointing the Guardian ad Litem, JC form FL-935, If the plaintiff or n .. titini,n.,r under 18 years of age, or if required by Court.

7. Additional copies of documents to be conformed by the Clerk. Copies of the cover must be served along with the summons and complaint, or other initiating pleading in

LACIV 109 (Rev. 01/07) LAse Approved 03-04

CIVJl CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

LAse, rule 2.0 Page 4 of4