IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Raymone K. Bain
4TTO Dexter Street, NW
Washington, D.C. 20007
(Plaintiff)
and
Davis, Bain & Associates, Inc.
4770 Dexter Street, NW
Washington, D.C. 20007
(Plaintiff)
v. Civil Action No.:
Michael J. Jackson
100 N. Carolwood Drive
Los Angeles, CA 90077-3515
(Defendant)
MJJ Productions, Inc.
562 Homewood Road.
Los Angeles, CA 90049-1906
(Defendant)
COMPLAINT
Plaintiffs, Raymone K. Bain and Davis Bain & Associates (hereinafter collectively
referred to as “Plaintiffs") complaint against Michael J. Jackson and MJJ Productions
(hereinafter referred to collectively as “Defendants’) as follows:
NATURE OF THE ACTION
4. This is an action for breach of contract, quantum meruit, and unjust
enrichment under the laws and the common law of the District of Columbia.THE PARTIES
Plaintiff, Raymone K. Bain, is a natural person and citizen of the District of
Columbia. Ms. Bain is CEO and Co-Founder of the public relations firm of
Davis, Bain & Associates, Inc., and President and COO of the Michael
Jackson Company, LLC. In addition to International pop icon, Michael
Jackson, Ms. Bain has represented many high profile public figures in the
sports, entertainment and political fields including, 10-time Grammy-Award
winning singer, songwriter, producer, and entertainment mogul, Kenneth
“Babyface’ Edmonds; recording group Boyz Il Men; Janet Jackson; “The
Kings of Comedy," a/k/a Steve Harvey, the late Bernie Mac, D.L. Hughley,
and Cedric “The Entertainer’; the Estate of the late Sammy Davis, Jr.;
Boxing legends “Marvelous” Marvin Hagler and Thomas “Hit Man’ Heams;
top-ranked International tennis star Serena Williams; and former D.C. Mayor
and current Washington D.C. City Council Member, Marion S. Barry, Jr.
among many others.
Plaintiff, Davis, Bain & Associates, Inc., is a corporation organized under the
laws of the District of Columbia having a place of business at 4770 Dexter
Street, NW, Washington, D.C. 20007.Defendant, Michael J. Jackson, (hereinafter Mr. Jackson) is a singer,
songwriter, investor, collector, businessman, and international pop icon,
who has sold over 1 billion records worldwide. Upon information and belief,
Mr. Jackson, formerly residing in The Kingdom of Bahrain, Ireland, and Las
Vegas, Nevada, is a resident, citizen and domiciliary of the State of
California.
Upon information and belief, Defendant MJJ Productions, Inc. is a California
corporation at one time receiving mail, and having an address of 4770
Dexter Street, N.W. Washington, D.C. 20007.
JURISDICTION
This Court has jurisdiction over the parties and this action pursuant to 28
U.S.C. 1332, the Long-Arm Statute of the District of Columbia, and by
contract, Venue is proper under 28 U.S.C. 1391.
FACTS COMMON TO ALL COUNTS
On or about December 2003, Mr. Jackson hired Davis, Bain & Associates,
Inc., as his public relations firm and appointed Ms. Bain as his personal
spokesperson and publicist.
As his publicist, Ms. Bain performed public relations consultation services
for Mr. Jackson including planning, coordination, and supervision of
proactive media strategies; crisis management and damage control;
preparation and distribution of press releases; and preparation of
Promotional materials, supervision and coordination of media appearances,
3-