Genuine vs. A&E Lawsuit

1COMPLAINT

12345678910111213141516171819202122232425262728 Neville L. Johnson (SBN 66329)Douglas L. Johnson (SBN 209216)James T. Ryan (SBN 210515)JOHNSON & JOHNSON LLP439 North Canon Drive, Suite 200Beverly Hills, California 90210Telephone:(310) 975-1080Facsimile:(310) 975-1095Email:njohnson@jjllplaw.comdjohnson@jjllplaw.comjryan@jjllplaw.comAttorneys for Plaintiffs,GENUINE ENTERTAINMENT, INC. d/b/aTHE IDEA FACTORY and REBELENTERTAINMENT PARTNERS, INC.

SUPERIOR COURT FOR THE STATE OF CALIFORNIACOUNTY OF LOS ANGELES

GENUINE ENTERTAINMENT,INC. d/b/a THE IDEA FACTORYand REBEL ENTERTAINMENTPARTNERS, INC.,Plaintiffs,v.STEVEN SEAGAL;STEAMROLLER PRODUCTIONS;INTERNATIONAL CREATIVEMANAGEMENT, INC.; NICK REED; A&E TELEVISION NETWORK; and DOES 1 - 30,inclusive,Defendants.CASE NO.:COMPLAINT FOR:

1. BREACH OF ORAL JOINT VENTUREAGREEMENT;2. PROMISSORY ESTOPPEL;3. AIDING AND ABETTING ANDBREACH FIDUCIARY DUTIES;4. FRAUD;5. BREACH OF IMPLIED-IN-FACTCONTRACT;6. BREACH OF CONFIDENCE;7. CONSPIRACY TO COMMITINTENTIONAL INTERFERENCE WITHCONTRACTUAL RELATIONS;8. CONSPIRACY TO COMMITINTENTIONAL INTERFERENCE WITHPROSPECTIVE ECONOMICADVANTAGE [COUNT 1]; AND9. CONSPIRACY TO COMMITINTENTIONAL INTERFERENCE WITHPROSPECTIVE ECONOMICADVANTAGE [COUNT 2].

DEMAND FOR JURY TRIAL

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2COMPLAINT

Plaintiffs GENUINE ENTERTAINMENT, INC. d/b/a THE IDEA FACTORYand REBEL ENTERTAINMENT PARTNERS, INC. (collectively referred to as“Plaintiffs”), demanding trial by jury, complain and allege on information and belief as follows:

THE PARTIESPLAINTIFFS

1.

Plaintiff GENUINE ENTERTAINMENT, INC. is a California corporation thatdoes business in the County of Los Angeles, State of California and elsewhere asTHE IDEA FACTORY (“Idea Factory”).

2.

Plaintiff REBEL ENTERTAINMENT PARTNERS, INC. (“Rebel”) is aCalifornia corporation that does business in the County of Los Angeles, State of California.

DEFENDANTS

3.

Defendant STEVEN SEAGAL (“Seagal”) is an individual and is now, and atall times mentioned in this complaint was, on information and belief, a resident of the County of Los Angeles, State of California.

4.

Defendant STEAMROLLER PRODUCTIONS (“Steamroller”) is a Californiacorporation and is now, and at all times mentioned in this complaint was, doing business in the County of Los Angeles, State of California. At all times mentionedherein, Steamroller approved and/or ratified the acts of its agent, Seagal. At alltimes mentioned herein, Seagal was acting as the agent for and on behalf of Defendant Steamroller.

5.

Defendant INTERNATIONAL CREATIVE MANAGEMENT, INC. (“ICM”)is a California corporation and is now, and at all times mentioned in this complaintwas, doing business in the County of Los Angeles, State of California.6.Defendant NICK REED (“Reed”) is an individual and is now, and at all timesmentioned in this complaint was, on information and belief, a resident of the

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3COMPLAINT

County of Los Angeles, State of California. At all times mentioned in thiscomplaint, Reed was acting as the agent for and on behalf of Defendant ICM as itsemployee.

7.

Defendant A&E TELEVISION NETWORK (“A&E”) is, on information and belief, a privately-held partnership that does business in the County of Los Angeles,State of California.

8.

Plaintiffs are ignorant of the true names and capacities of the Defendants suedherein as Does 1 through 30, inclusive, and therefore sues such Defendants byfictitious names. Plaintiffs will seek leave of Court to amend this complaint toallege their true names and capacities when they have been ascertained. Plaintiffsare informed and believe, and thereon allege, that each of the fictitiously nameddefendants were responsible in some manner for the occurrences herein alleged,and that Plaintiffs’ damages, as herein alleged, were proximately caused by suchconduct.

9.

At all times herein mentioned, all defendants, including Does 1 through 30,were the agents, servants, and employees of their co-defendants, and in doing thethings hereinafter alleged, were acting within the course and scope of their authority as those agents, servants, and employees and with the permission andconsent of their co-defendants. Throughout this complaint, Defendants and Does 1through 50 are sometimes referred to collectively as “Defendants.”

COMMON ALLEGATIONS

10.

Plaintiff Idea Factory is an independent, end-to-end production companywith offices in Los Angeles that is wholly-owned and controlled by Darryl Silver (“Silver”). Idea Factory specializes in the development and production of non-scripted television programs.

11.

On July 23, 2007, Seagal and Darryl Silver’s brother, Scott, met at Seagal’shome. During the course of the discussion, Scott Silver mentioned to Seagal that