COMPLAINT Page 3 of 8BACKGROUND AND GENERAL ALLEGATIONS10.
Plaintiff is the lawful owner of 114 paintings by defendant, collectively referred to as TheIndependence Collection, purchased at auction from Polk County Storage, Independence,Oregon after defendant failed to maintain payments for storage.11.
Defendant is the artist Tala Madani, an internationally renowned artist born in Iran in1981, who, prior to obtaining her MFA from Yale University in 2006, and being collected bysuch as the Tate Modern, London, UK, and earning numerous other awards, was a student atOregon State University, winning the President’s Award for Excellence in Art in 2003 andobtaining a BFA in Visual Arts in 2004.
Tala Madani’s work has recently sold at auction for over $30,000.00 for a single canvas.13.
The Independence Collection comprises 114 paintings left by Tala Madani in a storagelocker in Independence, Oregon, and on being abandoned, were lawfully purchased at auction byBrad Daily and Mike Claxton, the principals of plaintiff (“principals” herein).14.
After the purchase of the contents of the storage locker, the principals discovered the paintings, and through contents of the storage locker were able to identify the owner and author of the paintings. Also found were a number of obvious personal items, including photo ID cardsof defendant, personal photographs and negatives, a handwritten journal, and other items.15.
The principals contacted defendant in an attempt to return the personal items.16.
The principals also discussed the return of several of the paintings believed to be of notable value, but negotiations quickly degenerated.17.
Independent documentation and the defendant’s mother have confirmed the items and paintings in the storage locker belong to defendant Tala Madani.
See generally: http://en.wikipedia.org/wiki/Tala_Madani, andhttp://www.pilarcorrias.com/artists/tala-madani/ (official representation)
Case 6:13-cv-01397-MC Document 1 Filed 08/11/13 Page 3 of 8 Page ID#: 3