SUPERIOR COURT OF CALI NOTICE OF CASE ASS iN cLASs ACTION Case Number ae BC 6 040 ” ‘THIS FORM IS TO BE SERVED WI ul AND COMPLAINT @ ‘Your cae isiged frail purposes ote judge indeed blow. Theres moe formation onthe reverse sie of thi form. ‘ASSIGNED IUDGE DEPT [ROOM | ~ [ASSIGNED JUDGE DEPT _[ ROOW Hon, Kevin C Brazile 1 [se Mon, Elizabeth Aten Waite | 48 | 506 Hon. Barbara A. Meiers n 636 ‘Hon. Deirdre Hill a 9 509 Hon, Terry A, Green | 300 Hon. Teresa A Beaudet so | se Von Reba [er] Pini nani (Can Hon. Rta Mier 16 | 306 Hon, Susan Bryan Deaton = | si on, Ricard. Rico v | a” on, Seven. Klild s [ss Hon, Stephanie Bowick w | Hon, Ernest M. Hroshige «| sa Mon, Dalla Corraltyons | 20 | 310 Hon, Maen H Mackey s | ss Hon, Robert L Hess ™ [aw on, Misha! Johnson | su [ae on, Rolf. Trew =| s6 Hon, Barbara Scheper xo | a0 Hon. Gregory Ketan a [| 7m oe. Saantha eomee a | ow Hon Michal Stra a | « Hon, Mary Hy Strobel a | a6 Hon Mark Mooney | ar Hon, Michael P Lint ua on. Wiliam Fahey » | a Hon, Gregory Alarcon ae | a0 Hen, Suzanne G. Bruguera a | Ho. Mare Marmaro [ap on Ruth Ann Kran mn [ml Won. Maureen Duffy-Lawis | 38 | 412 Hon. Rafe Ongheko a | a Mon, Hiabet eter » | as Hon, TereaSancherGerdon | 14 | 38 on MicaeR Rosenblatt | 40 | ata Hon, Gall Ruderman Fever m | 20 Hon. oly E: Keng “a | as Hon, Mel ed Recama ws | 9 on Bile lias | cow Hon Frederik C.Stater | 46 | 500 ‘Feegosaly Comper Mon DebreK. Weintraub | 47 | 807 Sore aa_| cow *Complex All non-cass action cases designated as provisionally complex are forwarded to the Supervising Judge of the Complex Li located in the Central Civil West Courthouse (600 S. Commonwealth Ave., Los Angeles 90008), for complex/non-complex determin: pursuant to Local Rule 3.3(k). This procedure is for the purpose of assessing whether or not the ease is complex within the meaning of California Rules of Court, rule 3.400. Depending on the outcome ofthat assessment, the ease may be reassigned to one of the judges of the ‘Complex Litigation Program or reassigned randomly to a court in the Central District, tive Offcer/Clerk. Given othe Pairs Complinaauatonny of Regtn | § 205 sueResR cARTE By LA LACIV CCH 190 (Rev. 09/15) = NOTICE OF CASE ASSIGNMENT — LASC Approved 05-06 UNLIMITED CIVIL CASE Deputy Clerk Page 1 of2INSTRUCTIONS FOR HANDLING UNLIMITED CIVIL CASES ‘The following critical provisions of the Chapter Three Rules, as applicable in the Central District, are summarized for your assistance. APPLICATION ‘The Chapter Three Rules were effective January 1, 1994. They apply to all general civil cases. PRIORITY OVER OTHER RULES ‘The Chapter Three Rules shall have priority overall other Local Rules to the extent the others are inconsistent. CHALLENGE TO ASSIGNED JUDGE, A challenge under Code of Civil Procedure section 170.6 must be made within 15 days after notice of assignment for all purposes to @ judge, or if party has not yet appeared, within 15 days of the first appearance. ‘TIME STANDARDS Cases assigned tothe Individual Calendaring Court will be subject to processing under the following time standards: COMPLAINTS: All compl ts shall be served within 60 days of filing and proof of service shall be filed within 90 days of filing. CROSS-COMPLAINTS: Without leave of court first being obtained, no cross-complaint may be filed by any party aftr their answer is filed. Cross-complaints shal be served within 30 days of the filing date and a proof of service filed within 60 days of the filing date, AA Status Conference will be scheduled by the assigned Independent Calendar Judge no later than 270 days after the filing ofthe complaint. Counsel must be fully prepared to discuss the following issues: alternative dispute resolution, bifurcation, settlement, trial date, and expert witnesses. FINAL STATUS CONFERENCE, ‘The Court will require the partes at a status conference not more than 10 days before the trial to have timely filed and served all motions in limine, bifurcation motions, statements of major evidentiary issues, dispositive motions, requested jury instructions, and special jury instructions and special jury verdicts. These matters may be heard and resolved at this conference. At least 5 days before this conference, ‘counsel must also have exchanged lists of exhibits and witnesses and have submitted to the court a brief statement ofthe case to be read to the jury panel as required by Chapter Eight of the Los Angeles Superior Court Rules. SANCTIONS ‘The court will impose appropriate sanctions for the failure or refusal to comply with Chapter Three Rules, orders made by the Court, and time standards or deadlines established by the Court or by the Chapter Three Rules. Such sanctions may be on a party or if appropriate on ‘counsel forthe party. This is not a complete delineation of the Chapter Three Rules, and adherence only to the above provisions is therefore not a guarantee against the imposition of sanctions under Trial Court Delay Reduction. Careful reading and compliance with the actual Chapter Rules is absolutely imperative. LACIV CCH 190 (Rev. 08118) - NOTICE OF CASE ASSIGNMENT — Page 20f2 LASC Approved 05.08 UNLIMITED CIVIL CASEVOLUNTARY EFFICIENT LITIGATION STIPULATIONS The Early Organizational Meeting Stipulation, Discovery Resolution Stipulation, and Motions in Limine Stipulation are voluntary stipulations entered into by the parties. The parties May enter into one, two, or all three of the stipulations; however, they may not alter the stipulations as written, because the Court wants to eneure uniformity of application, = ‘These stipulations are meant to encourage cooperation Lesfowtescomay between the parties and to assist in resolving issues in a ‘Employment Law Section manner that promotes economic case resolution and judicial efficiency. The following organizations endorse the goal of ‘Association of Lon Angeies Promoting efficiency in litigation and ask that counsel Consider using these stipulations as a voluntary way to Promote communications. and procedures among counsel and with the court to fairly resolve issues in their cases. ‘@Los Angoles County Bar Association Litigation Section® (Oelonee Counsel Los Angeles County Bar Association — Labor and Employment Law Section® (See Nl nape Consumer Attomays Association of Los Angeles@ ‘Souther Califomia Defense Counsel® ‘Association of Business Trial Lawyers@ (Catto Eaghoymect ee ‘@Callfornia Employment Lawyers Assoclation®SERS STIPULATION - DISCOVERY RESOLUTION This Stipulation Is intended to provide a fast and informal resolution of discovery issues (hrough imited paperwork and an informal conference with the Court to aid in the resolution of the issues. ‘The parties agree that: 1 For to the dlacovery cutof inthis action, no discovery motion shall be filed d heard unless the moving party firet makes a written request for an informal Conference pursuant to the tenis ofthis stipulation. fi 2. Atthe Informal Discovery Conference ’. Following a reasonable and good faith attempt at an informal resolution of each issue to be Preeerya.,2 Party may request an Informal Diecovery Conference pursuant tothe following Procedures: The party requesting the Informal Discovery Conference wilt 1. File @ Request for informal Coitference with the cleri’s office on the Reem iy ce a ae a tin ‘assigned department; Include a briet surtmary of the dispute and specify the relief requested; and la. Serve the opposing party pursuant to any authorized or agreed method of service that enous tle oppo party seer Oe eeee ence mice Conference no later than the next court day folowing the fling. 'b. Any Answer to a Request for informal Discovery Conference must i. Also be filed on the approved form (copy attached); il, Include a brief summary of why the requested relief should be ‘denied; THEN 035 ram, etesetoent ‘STIPULATION — DISCOVERY RESOLUTION Page tot3li, Be filed within two (2) court days of receipt of the Request; and 'W. Be served on the opposing party pursuant to any authorized or agreed upon method of service that ensures that the opposing party receives the Anewer no tater than the next court day folowing the filng. a Be ther pleadings, incusing but not limited to exhibits, declarations, or attachments, will ‘be accepted, a tthe Court hes not granted or denied the Request for informal Discovery Conference within tan (10) days following the fling of the Request, then e 1! he conferonce fe not held win twenty (20) days ofthe fing of {Gfarmal Discovery Conference, uniesa extended by agreement of the parte ad tre Gourt then the Request forthe Informal Discovery Conference shall be dosteed tena ‘been denied at that ime. expired 4 1" (a) the Court has denied a conference or (b) one ofthe tine deadines above hes wihout the Court having acted or (c) the informal Discovery Conference is concluded wit a resclving the dispute, then a party may fie a discovery motion to address urvesched are, ‘an order shortening time for a motion to be heard 7. terminate this (21) days notice of intent to eae Stipulation by giving twenty-one 6 Rething herein wil preclude any party from applying ex parte for appropriate rele, incuding ‘conceming discovery. ‘8. References to “days” calendar unless otherwise noted. Wf the date for performing Sat purser otis spdaton aso a Satay Sana ea ee for performing that act shall be extended tothe next Court day. 148% awd ut ‘STIPULATION - DISCOVERY RESOLUTION Page2'3The following parties stipulate: Date: : a FS ———— : aa LL > Dele, ROTI ARTO RT ra . Date: a el Date: Lidell : ‘CAFFRA FOR BEFERORT) a : ar —— Date: eee > oe TTC. : = oR RS ———$—— aE —— ————— Terenas zi Use peed oun STIPULATION - DISCOVERY RESOLUTION _ Page Sof—annee ‘STIPULATION — EARLY ORGANIZATIONAL. MEETING ‘This stipulation is Intended to encourage cooperation among the parties at tn {the litigation and to esaist the parties in efficient case resctution. bande! ‘The parties agree that: 1 The batiss commit to conduct an inital conference (n-person or via teloconference or via within 15 {rom the date thie stipulation is signed, to dlscuse and consider whothor Poe can be agromest on ne tase © eae ae ostatende the pleadings necessary? if the issue can be rescived by a Exchange of names and contact information of witnesses; 4. Any insurance agreement that may be avaliable to satify part or all of a judgment, or to Intute pyre at st pte Exchange of any other information that might be helpful to faitate understending, handing, : crrenon ce ene na manor el pares eco a, hn t Controting issues of law thet, if resolved early, wil promote efficiency and economy in other phases of the case. ‘Also, when and how such issues can be presented to the Court; o Whether or when the case should be scheduled wih a settlement officer, what discovery or court ruling on legal issues ls reasonably required to make settlement discussions meaningful, and whether the parties wish to use a siting judge or a private mediator or other options as TAN 229 foe {ac foe unt ‘STIPULATION ~ EARLY ORGANIZATIONAL MEETING Page tota eeutsoe In the “Atemative Dispute Resolution (ADR) Information Package” served wth the ‘complal h of not from Computation tat ung document, rivieged or protected from disclosure, on | Whether the case is sultable for the Expedited Jury Trial procedures (see information at of Chil 1054{a), good cause ‘been found by the Cit Judge due to the case management by this Sdputation. ‘A copy of the General Order can be found at under “Chir, click then click on *Voluntery Efficient Litigation Stipulations’ efficient ‘Or resolution of the case. The parties shail ‘the Joint Status Report to the .Case Management ‘and fie the when the CMC itera documents . References to “day” mean calendar days; uniess otherwise noted. Hf the date for performing act to this falls: I, then the Titaesctn STIPULATION — EARLY ORGANIZATIONAL MEETING ‘The following parties stipulate: ate: > (HYPE OR PRINT NAME) ‘(ATTORNEY FOR PLAINTIFF) Date: > Fam OVPEORPRIT RANE) ——— “ATTORNEY FOR DEFENDANT) > ~__ YPEOR PRINT RAMEY "TAFTORNEY FOR DEFENDANT) ——— om > ~~ (FYFE OR PRINT NAME) ATTORNEY FOR OEFEROART) Dota: > ___ (1YPEOR PRINT NAME) TORREY FOR__—— Cate: > TIYPE OR PRINT NAME) — (ATTORNEY FOR FRE OR PRERIT NE) ” prone — faRequest for Informal Discovery Conference Answer to Request for informal Discavery Conference 2 (Deering for Court to decide on Request: Creer date 10 cotondar days teloning fing of Deadiine for Court to hold informal Discovery ‘Conference: 2 dap tiloaleg Wing fe Regine). 4. For « Request for informal Discovery Conference, briefly describe the nature of the lacovery puts, Inctotg th acta oe ME. anc For an Answer to teatuest for informal Dlacovery Conference, briefly describe why the Court should deny {he requested discovery, Including the facts and legal arguments at lesue, Gone date 20 calentar TGV ON pee) INFORMAL DISCOVERY CONFERENCE Protea (Pureuant to the Discovery Reeohition Stipuition of the parties)‘STIPULATION AND ORDER — MOTIONS IN LIMINE This stipulation le intended to provide fast and informal resolution of evidentiary lesues through diligent efforts to define and discuss such issues and limit paperwork. The parties agroo that: * Gatos srs a cota sn pee cme, cach pay wil prove a oer parties with a ‘a one of each imine. Each one paragraph explanation must identty the substance of a single proposed ‘motion in fimine and the grounds for the proposed motion, 2. The parties thereafter will meet and confer, elther in person or via teleconference or videoconference, = . concerning ail proposed motions in imine. In that meet and confer, the ‘8. Whether the parties can stipulate to any of the proposed motions. ifthe parties so Stipulate, they may fle‘a stiputation and proposed order with the Court. ree on a date and manner for exchanging the parties’ respective portions of the shot et stoner of sues eid he pea a ae one of the tasues. 3 ‘All proposed mations in imine that are not either the subject of a stipulation or briefed via 8 short Joint statement of issues will be briefed and filed in accordance with the Catifornia Rules of Court and the Los Angeles Superior Court Rules. TAN OTS pee) aeagematoen STIPULATION AND ORDER - MOTIONS IN LIMINE reetctzThe following parties stipulate: Date: TIVPE OR PRONT NAME TORREY FOR PNT) Foul (TYPE OR PRINT NAME) ‘(ATTORNEY FOR OEFENDANT) _ ‘OR PRINT ~~ > (RTORREY FOR DEFERANT) “(AYRE OR PRINT NAME) ~PRTTORREY FOR DEFENDANT) Date: “ —___—GPEGR PRINT Ray _———— TFTORREY FoR Date: ———— Dane, CRORE Ey (ATTORNEY FOR yr CPE OR PRINT RARE ~prronnEr FoR_—_—————— een ‘THE COURT 80 ORDERS. —————— CAMS OFC Uacneecibunn STIPULATION AND ORDER — MOTIONS IN LIMINE acesoO SUMMONS SUM-100 (CITACION JUDICIAL) Fee oY (solS Btn iso BELA Cone) NOTICE TO DEFENDANT: ZOO8Y DESCHANEL, an individual; (AVISO AL DEMANDADO): and DOES 1-10, inclusive Fine Superior it uty of SaMBRNED copy ore emi, Carter, Executive Ofcertlark YOU ARE BEING SUED BY PLAINTIFF: SEVEN SUMMITS PICTURES By Grstina Grijalva, Doputy (LO ESTA DEMANDANDO EL DEMANDANTE): & MANAGEMENT, LLC, @ California limited liability company NOTICE! Yeu have been sued. The court may decide against you without your being hoard unless you respand within 30 days. Read the nformalion | "You have 20 CALENDAR DAYS ater tissurmmons and egal papers ae served on yu to fea writen reeponce a this curt and have # copy Served onthe paintif. Alter or phone cal il no rote! you. You wt response must be in propes egal lar ifyou ent necoen i Rae our ‘ate, There maybe a cour farm thal you can uso fo yout reaponse, ou can these cout ork snd mara foerston ie Senta ake Sacer rec oe you cu uy rn oats rated yu I yven pya oe out clr fora fe wane form. you do nt fle your esponse on tim, you may tae the eas0 By dalal one your mages recen ame cna ‘ray bela wihou futher warming fom te cau aa fs parr There er cher egal requrements. You may want to cal an atomey ight away. I you do nt know an afore, you may wart o call an store ilar erica i youcanet ated an atmey, you may be epee aang ovens fom aronpotegel ties papa ou com ose” those nenaofteroupe atthe Calorie Legal Scvicos We ato jvwaawnopcalfonia erg, he Galeria Coats One Sek alpen {erwn.courtinfocacewsethel) or ty contacting your local our o county bar assecation NOTE: The cous has egies Wes fo ah eos and ‘2us on ay stleen’ or ariaton award of $10,000 oF more na cl ease, The cous len mst be pal belts te souk wil Somme ee onee {AVEO Lan demands. Siro responde ent co 30 les fa cone pune Gacren es conta shrcsucer su vost Law's hpacia& Tere 30 DIAS DE CALENDARIO despus de qu fo enroquon eta coca ypapees gles pra present une respuesta por scr on sta ate y hacer quo se enteguo une copia el demandant. Una eat o una lamsada fete nb protege Su respuesta por ese Woke cue alr nora leglcorecto si desea que proceson su caso nla corte. Ea peso que haya un formule ace usted poses teat pre ou teeponate use encontrar esos foruarios oof corey mas nformacn an el Cnt do Ayuda ce as Crt ds Colfonia enw auesteces you ea ‘ofece de eyes desu condaco 0 en fa cata quo lo quedo mas core. Sino puede poger a coos de rosonieclbn ise asec Pore coie aus le un frmutao de exonién de pago de evtas Siro presenta Su respuesta a tempo, puede peer el caso porlncumpimieto yi ca lo ‘Podré quia su sues, nero y bans sin mas advertonele, Hay otros requisites egeles. Es recomandable que lame 9 un ebogedo Inmeditaments. Sino canoce a un abogado, puede Hamar a un servicio do ‘omisién a sbagados. Sino puede pagar a un abogade, es sib que cumple can os regustos pore ot programa de sencios legates sin fines do uco. Puede encontrar estos grupos sn fines de uc en el silo web ce Galforia Loge! Services, {i lawhelpalteria.rg, en al Centro de Ayuda 2 las Cortes do Coloma, (win susote.ca. gos) 0 porténdose on omtacto son I sort of ‘colegio de apogados ocales. AVISO: Por le, la cote lane drecho a reclamar las cuolas yi cosios exentos por impener un grevamen sobre aur recuneracion de $10,000 ¢ més do valor racibida medarte un acuorda O une cencesiin de arbaje en Un Caso de devecno Gui. lone gue ‘gravamon do la corte antes de quo la carte puede dasechar caso re and address of he court is (Elnombrey drection col cotee) co Los Angeles Superior court Bososp re 21 Noven ill Street Los Angeles, CA 90012 ‘The name, address, and telephone number of plaintiffs attorney, or plant without an attorney, is (Elnombre, ia drecsién y ef numero de telefono del abogado del demandents, o del demandante que no tiene abogado, es): Bryan J. Freedman, Esq. (SBN 151990) 310-201-0005 Fax: 320-201-0045, Steven B. Stiglitz, Esq. (SBN 222667) FREEDMAN + TAITELMAN, LLP 1901 Avenue of the Stars, Suite 500, Los Angeles, CA 90067 DATE: Clerk, by Deputy (Fecha) (Secretario) Sewn {Agjunto) (For proof of Service of this sumr 1001 of Service of Summons (form POS-OIOhI~<—< INP (Para prueba de entrega de esta ciatién use e formularia Proof of Service of Sumr 28°10). NOTICE TO THE PERSON SERVED: You are senvé ENT 1. [_) as an individual defendant. | as the person sued under the fictious name of (speci): 3. [] on behalf of (specify): get 16 01 under: (—] CCP 416.10 (corporation) ICP 416.80 (minor) (© cep 416.20 (defunct corporation) — ccP 416.70 (conservates) =) CCP 416.40 (association or partnership) :CP 416.90 (authorized person) other (specify): 4. [1] by parsonal delivery on (date): age tot3 Fakir ‘SUMMONS: odie Gein ci Pca 1275 Sno Sy)00/00/2015 09:15:52 FAK 2132499990 Bryan J. Freedman, Esq, (SBN 151990) Steven B. Stiglitz, Esq. (SBN 222667) FREEDMAN + TAITELMAN, LLP 1901 Avenue of the Stars, Suite 500 Los Angeles, CA 90067 ‘Telephone: (310) 201-0005 Facsimile: (310) 201-0045 E-mail: BFreedman@fillp.com SStiglitz@ftlip.com Attomeys for Plaintiff Seven Summits Pictures & Management, LLC NATIONWIDE LEGAL CONFORMED Gop ORIGINAL Fi i RES aane DEC 16 2015, Sheri R. Carter, Executive OfficentClerk By Cristina. Grijalva, Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES SEVEN SUMMITS PICTURES & MANAGEMENT, LLC, a California limited liability company, Plaintiff, vs. ‘ZOOEY DESCHANEL, an individual; and DOES 1-10, inclusive, Defendants. Bb 04072 Case No.: Unlimited Civil Case Amount in excess of $25,000 COMPLAINT FOR: (1) BREACH OF WRITTEN CONTRACT; Q DECLARATORY RELIEF; @) QUANTUM MERUIT; AND (@ ACCOUNTING Complaint00/00/2015 Soerxraunaeun MW 12 13 4 15 16 7 18 19 20 2 22 23 24 25 26 27 28 09:15:52 FAK 2132499990 NATIONWIDE LEGAL Plaintiff Seven Summits Pictures & Management, LLC, a California limited liability company (Plaintiff or Seven Summits”) hereby alleges as follows: NATURE OF THE. LAWSUIT 1. Seven Summits managed the Defendant Zooey Deschanel’s (“Deschanel” or “Defendant”) career from 1996, when she was an unknown actress, until 2013, by which time she was one of the most famous actresses in the world, a Grammy Award-nominated singer, and the co-founder of a successful entertainment website vow. hellosiggles.com (“Hello Giggles”). Throughout that time, Seven Summits worked diligently for Deschanel and helped shape Deschanel's career into one of the best success stories in Hollywood. Seven Summits also handled the day-to-day responsibilities of being Deschanel’s personal manager, as well as handling major career decisions, suchas helping Deschanel ‘choose her other representation, including her agents at CAA and UTA and her attomeys at Hansen Jacobson. In 1999, Seven Summits and Deschanel entered into a writen agreement, pursuant to which Seven Summits agreed to continue managing Deschanel’s career in return for “a ten percent (10%) ‘commission on all monies or other consideration received by (Deschanel] or [Deschanel’s] company for all entertainment activities or deals initiated during the term of [the] agreement.” Pursuant to the terms of the agreement, and consistent with the custom in the industry, although Deschanel terminated the management relationship with Seven Summits in 2013, Deschanel has paid some post-termination commissions on income she has received since the time she ended the relationship with Seven Summits, For example, Deschanel has continued to pay Seven Summits its 10% commission in connection with television series “New Girl.” Once Seven Summits requested commissions on Deschane!'s income fron Hello Giggles, however, Deschanel retaliated by ceasing to pay commissions on all her projects, including “New Girl.” As an excuse, Deschanel is claiming that the signature on the agreement is not hers, an allegation that is false, as indicated by the fact that Deschanel actually paid commissions Pursuant to that agreement for many years. Further, Deschanel is making the false claim that Seven Summits procured employment for Deschanel when it was not legally permitted to do so. Aside from ‘being untrue, Deschanel’s claim is not a reasonable excuse for deciding to withhold payment for services from a dutiful adviser who worked diligently for 17 years. Whereas most actors would be tivilled to have a manager put them on a successful career trajectory, Deschanel is now making a claim 2 ‘Complaint00/00/2015, Ce ee 10 u 12 13 4 15 16 7 18 19 20 2 2 23 24 25 26 2 28 09:15:52 FAX 2132499990 NATIONWIDE LEGAL eainst Seven Summits for supposedly doing foo much to make her successful and for supposedly doing ‘00 much to help her earn a giant fortune. In sum, this lawsuit arises from an entertainer’s position that the very people who helped her achieve a level of success higher than her wildest dreams are not entitled] to their rightful, contractually provided share of the entertainer’s proceeds, GENERAL ALLEGATIONS 2. Plaintiffs a limited liability company organized under the laws of the State of California With its principal place of business located in the State of California, County of Los Angeles. 3. Plaintiff alleges on information and belief that Deschanel is an individual who, for all times relevant hereto, resided in the State of Califomia, County of Los Angeles. 4. Plaintiffs ignorant ofthe true names and capacities of defendants sued herein as DOES | through 10, inclusive, and thereon sues these defendants by such fictitious names. Plaintiff alleges on information and belief that such DOE defendants are liable to Plaintiff for the actions hereinafter set forth. Plaintiff will amend this complaint to allege the true names and capacities of such DOE defendants when ascertained. 5. Plaintiff alleges on information and belief thet, at all times relevant hereto, each defendant, including DOE defendants, was the agent, servant, employee and/or representative of each of| the other defendants and, in doing the things herein alleged, was acting within the course and scope of, and pursuant to, said agency, services, employment and/or representation. 6. Jurisdiction and venue for this action in the County of Los Angeles are proper pursuant ‘o, without limitation, California Code of Civil Procedure § 393, § 395 and § 395.5 in that, among other things, (a) the contract at issue was made and to be performed in the State of California, County of Los ‘Angeles; (b) the conduct occurred and the claims and causes of action alleged herein arose in the State of California, County of Los Angeles; and (c) the defendant is a resident of the State of California, County of Los Angeles. ALLEGATIONS COMMON TO ALL CAUSES OF ACTION A. The Management Agreement and Term of the Management Relationship 7. In 1996, Sarah Jackson (“Jackson”) of Seven Summits met Deschanel when she was a 16 year-old student at Crossroads School in Los Angeles. After Jackson saw Deschanel perform in a 3 ‘Complaint00/00/2015 Cer anneun 10 u 2 13 14 15 16 17 18 19 20 a 23 24 25 26 2 28 09:15:52 FAX 2132499990 NATIONWIDE LEGAL emake of “Into the Woods,” Jackson recognized Deschanel’s talent and agreed to have her company, ‘Seven Summits, serve as her personal management firm. Seven Summits quickly assembled a team to help Deschanel pursue her career in the entertainment industry. That team included a talent agency, law] firm, and public relations firm. 8. On April 30, 1999, Seven Summits and Deschanel entered into a written agreement ‘whereby Seven Summits agreed to perform services as Deschanel’s personal manager in return for “a ten percent (10%) commission on all monies or other consideration received by [Deschanel] or (Deschanel’s} company for all entertainment activities or deals initiated during the term of [the] agreement as it may be extended.” A copy of that management agreement (the “Management Agreement") is attached hereto as Exhibit A. 9. The Management Agreement states that the term of the Management Agreement (the “Term”) is as follows: “The term of this agreement shall be two years from the date of this letter. After two years, the agreement shall be automatically renewed for additional one-year periods unless either Party terminates the agreement by delivering written notice to the other party at least ten days before the agreement expires.” 10. Ona day-to-day basis for at least 17 years, Seven Summits’ work included all managerial responsibilities within regards to acting, music, endorsements, literary endeavors, security, press and publicity, as well as oversight of all contracts relating to the above. 11, Deschanel was always interested in creatively participating in a multitude of different aspects of the entertainment industry. With Seven Summits’ help, Deschanel developed a thriving TV and Film career, an online presence, a music career, an endorsement career, a show in development for Broadway, and a production company. As such, Deschanel’s required a manager with experience in all of those fields, Seven Summits not only had that breadth of experience, but also had the skill set and vision to become an architect of her brand. 12, Nevertheless, in August 2013, after Deschanel sent notice to Seven Summits that she was terminating the agreement. As such, pursuant to the terms of the agreement, the term ended on April 30, 2014, which was the end of the then-current one-year extension of the Term. B. —_Deschanel’s Commissionable Income from Hello Giggles 4 Complaint00/00/2015 Cer anvaun 10 u 12 3 4 15 16 7 18 19 20 2 22 23 24 25 26 27 28 09:15:52 FAX 2132499990 NATIONWIDE LEGAL 13. Inor about 2010, Deschanel and two of her friends, Molly McAleer and Sophia Rossi, came up with the idea to develop a website that would provide content geared for the entertainment of women. Seven Summits worked extensively on helping Deschanel to bring the idea for that website to reality. On or about November 10, 2010, Deschanel and her friends, through an entity called Hello (Giggles, LLC (which later converted to a corporation named Hello Giggles, Inc), registered the domain name www hellogigeles.com for the purpose of creating that website. After the registration of the ‘website, Seven Summits continued to work extensively on Hello Giggles. Seven Summits worked on Deschanel’s behalf, and in particular, worked tirelessly on her Internet business, Hello Giggles, while Deschanel was focusing more on her singing and acting career. Seven Summits’ work on Hello Giggles include all of the following: 2. Helping form the corporate entity, set up a bank account, and set up a separate movie production company; b. Advising Deschanel on the benefits of formalizing the relationship between her and her partners in Hello Giggles, which facilitated the expansion of the business, as well as Deschanel’s ability to reap financial rewards from it; ©. Helping Deschanel with the Hello Giggles book, including participating in many conference calls with representatives of Random House, such as editors, executives and marketing professionals; 4. Helping with publicity, including working with Deschanel when she was asked to be on the cover of AD Weed, €. Helping to bring in endorsement money; £ Communicating on a daily basis with Sofia Rossi and acting as the go between when she could not connect with Deschanel; 8 Advising on restructuring the company to alter the roles of the three partners; hh, Helping to bring in potential investors; i. Interfacing with Steven Pines; J. Meeting with Sophia and potential creators of content; k. Developmental work on the film “Sister in Law”; 5 Complaint00/00/2015 09:15:52 FAX 2132499990 NATIONWIDE LEGAL 1 1. Working with Fox to realize the benefits of synergy between Hello Giggles and Deschanel’s role on “New Girl,” including meetings with Digital Media Content and ‘many conference calls to strategize how best to raise awareness about “New Girl” to Hello Giggles’ core audience to make the premier of “New Girl” a must see event among the Hello Giggles community, m. Working with Rimmel and Pantene, a make-up company and hair care product company, respectively, for each of which Deschanel was the spokesperson, to realize the benefits of synergy between Hello Giggles and Deschanel’s endorsement career , including having, Deschanel’s make-up artist Jorjee Douglass, write blogs/ tutorials to be featured on Hell Giggles to highlight Deschanel’s style and looks as created by Rimmel. Soe wrHauneuen u 14, Over time, Hello Giggles became an extremely popular website that many people, 12 [especially women, frequented for entertainment. Even today, Hello Giggles confirms that itis an 13 |]entertainment publication by stating, “We were founded by Zooey Deschanel, Molly McAleer, and 14 || Sophia Rossi in 2011 as a place on the Internet to inspire a smile.” In fact, entertainment content 15 || dominates Hello Giggles. For example, Hello Giggles recently published the following articles: (a) an 16 |} article called “Things to Put Your Eyes On,” which contains a photo of a police dog rappelling from a 17 |} building and humorous commentary regarding the photo; (b) an article called “Pop Goes the Culture,” 18 || which discusses the nominees for the People's Choice Awards; (c) an article called “Chris Hemsworth 19 | [officially has an Instagram and his first Insta is uh, horrifying,” which contains commentary on Mr. 20 || Hemsworth, a popular actor; and (4) an article called “The Intemet can't get over Heidi Klum's epic 21 || Jessica Rabbit costume,” which describes the Halloween costume of the famous host of the television 22 |) series “Project Runway.” B 15. Seven Summits is informed and believes and thereon alleges that, from the time 24 | Deschanel co-founded Hello Giggles through the time that Deschanel terminated the management 25 ||relationship, Deschanel did not receive any income from Hello Giggles. Instead, Deschanel and her co- 26 || owners agreed that: (a) Ms. Rossi would be the partner responsible for the day-to-day activities 27 | associated with the development of the website and she would be the only partner to receive any salary 28 |] or other compensation for services rendered; and (b) the partners would re-invest any profits into the 6 Complaint00/00/2015 09:15:52 FAX 2132499990 NATIONWIDE LEGAL ee ee) 10 u 12 13 4 1s 16 - 18 7 20 21 22 B 24 25 26 2 28 ‘business rather than take distributions of such profits, unless and until they agreed otherwise. 16. On or about October 18, 2015, the media began reporting that Deschanel and her partners| Sold Hello Giggles to the global media and entertainment company Time, Inc. The Wall Street Jounal reported that Hello Giggles sold for an amount in the range of $20 million and that Hello Giggles was ‘Generating traffic from approximately 11 million unique visitors per month. The Los Angeles Times Teported even more favorable data, stating that Hello Giggles sold for an amount in the range of $30 ‘million and is visited by approximately 17 million unique users per month. In connection with reports of the sale, the Wall Street Journal also reported that “HelloGiggles.com is being folded into Time Inc's People and Entertainment Weekly group,” which further reinforces that Hello Giggles is widely ‘acknowledged to be an entertainment publication. 17. To the best of Seven Summits’ knowledge, Deschanel never received any income from Hello Giggles until the sale of the company occurred last month, 18. On November 16, 2015, after Seven Summits leamed that Deschanel received money in connection with the sale of Hello Giggles, Seven Summits requested that Deschanel pay Seven ‘Summits’ 10% commission on her income from Hello Giggles (which includes the amounts she received in connection with the sale of the website), but Deschanel refused to pay any such commissions, B. _ Deschanel’s Commissionable Income from “New Gir!” 19. During the Term, Deschanel began working as an actor on the television series “New Girl” 20. Ino about 2011, in connection with her role on “New Girl,” Deschanel entered into a ‘written agreement with the production company that is producing the series. Pursuant to that agreement, Deschanel received substantial compensation for her work as an actor on “New Girl.” 21. Pursuant to the Management Agreement, Deschanel paid Seven Summits commissions in /connection with Deschanel’s income from her work on “New Girl.” Those payments continued after the ‘conclusion of the term and through November 16, 2015, the date that Seven Summits first formally Tequested payment of commissions in connection with Deschanel’s income on Hello Giggles, Complaint90/00/2015 wey annun 10 u 12 13 4 15 16 7 18 19 20 a 2 24 25 26 27 28 09:15:52 FAX 2132499990 NATIONWIDE LEGAL 22. Seven Summits is informed and believes and thereon alleges that Deschanel is continuing] to receive compensation in connection with “New Girl,” but that Deschanel has failed to pay ‘commissions on that income to Seven Summits, 23. In fact, in response to Seven Summit's November 16, 2015 request for commissions on Hello Giggles, Deschanel explicitly stated that she was ceasing payment of commissions in connection with her income from “New Git C. Deschanel’s Commissionable Income from the Tommy Hilfiger Endorsement Campaign 24. During the Term, Deschanel began working on an advertising campaign for Tommy Hilfiger. In connection with that work, Deschanel received substantial income from Tommy Hilfiger, land Deschanel paid commissions to Seven Summits, 25. In connection with the Tommy Hilfiger advertising campaign, Deschanel then entered into an addendum to the initial agreement incorporating advertising in South Ametica into the original agreement, 26. Seven Summits continued to receive payments of commission in connection with Deschanel’s income from her work on the advertising campaign for Tommy Hilfiger atleast until July 10, 2014. 27. Seven Summits is informed and believes and thereon alleges that Deschanel continued to receive income in connection with her work on the advertising campaign for Tommy Hilfiger after July 10, 2014, especially in connection with advertising in South America. 28. Seven Summits requested that Deschanel pay Seven Summits’ 10% commission on her income from her work on the advertising campaign for Tommy Hilfiger in South America to the extent such commis ions have not been paid already, but Deschanel refused to pay any such commissions. FIRST CAUSE OF ACTION — BREACH OF WRITTEN CONTRACT (By Seven Summits against Deschanel and Does | through 10) 29. Plaintiff hereby incorporates by reference each and every allegation set forth in Paragraphs | through 28 as if set forth in full herein. 30. In 1999, Seven Summits and Deschanel entered into the Management Agreement. Complaint00/00/2015 ew ra wa 10 n 2 13 4 15 16 7 18 19 20 2 23 24 25 26 2 28 :52 FAX 2132499990 NATIONWIDE LEGAL 31. In August, 2013, Deschanel sent notice of termination of the Management Agreement. Thus, pursuant to the provisions of the Management Agreement, the Term ended on April 30, 2014, 32. Pursuant to the Management Agreement, Deschanel agreed to pay Seven Summits “a ten [percent (10%) commission on all monies or other consideration received by [Deschanel] or [Deschanel’s] company for all entertainment activities or deals initiated during the term of [the] agreement as it may be extended.” 33. During the Term, Deschanel initiated work on, and became a partner in, the business entity that owned Hello Giggles. 34. _Deschanel’s work on, and ownership and stewardship of, Hello Giggles constituted an “entertainment activity” as that term is used in the Management Agreement. Further, during a conversation between Deschanel and Sarah Jackson of Seven Summits, Deschanel confirmed her ‘understanding that income from Hello Giggles would be commissionable. 35. Seven Summits is informed and believes and thereon alleges that Deschanel received income in connection with Hello Giggles for the first time in or about October 2015. Prior to that time, ‘Seven Summits was unaware of Deschanel earning any income in connection with Hello Giggles and hhad no reason to believe that Deschanel had altered her agreement with her partners in Hello Giggles that they would re-invest profits into the business rather than take distributions of profits. 36. Seven Summits is informed and believes and thereon alleges that Deschanel received substantial income from the sale of her interest in Hello Giggles in or about October 2015. 37. Deschanel has not paid any commissions to Seven Summits in connection with the sale of her interest in Hello Giggles despite a request from Seven Summits for such commissions. 38. During the Term, Deschanel initiated work on “New Girl.” 39. Deschanel's work on “New Gir!” constituted an “entertainment activity” as that term is used in the Management Agreement, 40. Deschanel paid commissions to Seven Summits on certain of her income from “New Girl” from the time that her work on the project began, which was during the Term, through approximately November 16, 2015, which was well after the end of the Term. 9 Complaint00/00/2015 Cor aneun 10 N 12 13 14 15 16 7 18 19 20 2 23 24 25 26 27 28 +52 FAX 2132499990 NATIONWIDE LEGAL 41. Seven Summits is informed and believes and thereon alleges that Deschanel received income in connection with her work on “New Girl” on which she has not paid commissions to Seven ‘Summits. 42, — Deschanel explicitly stated that she would no longer pay such commissions. 43. During the Term, Deschanel initiated work on a Tommy Hilfiger advertising campaign. 44, Deschanel’s work on the Tommy Hilfiger advertising campaign constituted an “entertainment activity” as that term is used in the Management Agreement. 45. Deschanel paid commissions to Seven Summits on certain of her income from the ‘Tommy Hilfiger advertising campaign from the time that her work on the project began, which was Guring the Term, through approximately July 10, 2014, which was well after the end of the Term. 46. Seven Summits is informed and believes and thereon alleges that Deschanel entered into an addendum to her original contract with Tommy Hilfiger, and thatthe addendum related to advertising! in South America. 47. Seven Summits is informed and believes and thereon alleges that Deschanel received ‘income in connection with the Tommy Hilfiger advertising campaign in South America on which she ‘has not paid commissions to Seven Summits. 48. Seven Summits requested that Deschanel pay such commissions, but Deschanel refused. 49. Seven Summits performed all conditions, covenants and promises required on its part to }be performed in accordance with the terms and conditions of the Management Agreement with the Jexception of those conditions, covenants and promises which have been prevented, delayed or excused 8 a consequence of the conduct and/or breach of the Management Agreement by Deschanel, as alleged herein. 50. Deschanel breached the terms of the Management Agreement by failing and refusing to ay commissions due and owing Seven Summits from Deschanel’s income described above. 51. _Asadirect, proximate and foreseeable consequence of the breach of the Management ‘Agreement by Deschanel and DOES 1 through 10, and each of them, Seven Summits has suffered damages, and will continue to suffer damages in excess of the minimum jurisdictional amount, according to proof at trial. 10 Complaint 1000/00/2015 Cam rxraue 09:15:52 FAX 2132499990 NATIONWIDE LEGAL OND CAUSE 0) [ON - DECLARATORY RELIEF (By Seven Summits against Deschanel and Does 1 through 10) 52. Plaintiff hereby incorporates by reference each and every allegation set forth in Paragraphs 1 through 51 as if set forth in full herein, 53. Pursuant to the Management Agreement, additional commissions will become due in the future from Deschanel to Seven Summits in connection with Hello Giggles, “New Girl,” and the ‘Tommy Hilfiger advertising campaign in South America, 54. There is a present controversy between Seven Summits and Deschanel as to whether and to what extent Deschanel actually owes such commissions to Seven Summits, 38. Assuch, Seven Summits requests the following judicial declaration from the Court: 56. Pursuant to the Management Agreement dated April 30, 1999, Deschanel is obligated to pay to Seven Summits Pictures & Management, LLC 10% of any income that Deschanel, or her jcompany, receive at any time in the future in connection with: (1) Hello Giggles, including the sale of the website and/or the entity that owns the website, as well as income in any other form from Hello Giggles; (2) “New Girl”; and (3) the Tommy Hilfiger advertising campaign. ‘THIRD CAUSE OF ACTION — QU: MERUIT (By Seven Summits against Deschanel and Does 1 through 10) 57. Plaintiff hereby incorporates by reference each and every allegation set forth in Paragraphs I through 56 as if set forth in full herein, 58. _Asalleged hereinabove, Seven Summits provided management services to Deschanel. 59. Deschanel, accepted, used and enjoyed, and is and continuing to use and enjoy, the benefits of Seven Summit’s management services. 60. The fair and reasonable value of the management services provided by Plaintiff to [Defendants includes a 10% commission on Deschanel’s income from Hello Giggles, “New Girl,” and on the Tommy Hilfiger advertising campaign on which Deschanel performed services. 61. Plaintiff has made written request on Defendants for payment of the reasonable value of their management services provided. Defendants, however, have failed and refused to make payment to Plaintiff as requested. u Complaint nn00/00/2015 Seer auenun u 12 13 14 15 16 7 18 19 au 22 23 24 25 26 27 28 09:15:52 FAX 2132499990 NATIONWIDE LEGAL THIRD CAUSE OF ACTION. .CCOI (By Seven Summits against Deschanel and Does 1 through 10) 62. Plaintiff hereby incorporates by reference each and every allegation set forth in Paragraphs 1 through 61 as if set forth in full herein. 63. _Asalleged hereinabove, Seven Summits provided management services to Deschane! [pursuant to the Management Agreement, 64. Pursuant to the Management Agreement, Seven Summits is entitled to a 10% commission] onalll income that Deschanel receives from certain sources specified in the Management Agreement, ‘which include Hello Giggles, “New Gitl,” and the Tommy Hilfiger advertising campaign on which Deschanel performed services. 65. Seven Summits is informed and believes and thereon alleges that Deschanel has received ‘monies that are commissionable under the terms of the Management Agreement, but for which Deschanel has not accounted to Seven Summits. 66. Seven Summits hereby demands an accounting of all amounts of income that Deschane! received from the foregoing sources so that Seven Summits can determine the amounts of commissions {that Deschanel owes to Seven Summits. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendants and Does | through 10, and Jeach of them, as follows: ‘On Plaintiff's First Cause of Action for Breach of Written Contract: 1. For compensatory damages according to proof at trial. 2. For consequential damages according to proof at trial. On Plaintiff's Second Cause of Action for Declaratory relief: 3. For a judicial declaration that: Pursuant to the Management Agreement dated April 30, 1999, Zooey Deschanel is obligated to pay to Seven Summits Pictures & Management, LLC 10% of any income that Deschanel, or her company, receive at any time in the future in connection with: (1) Hello Giggles, including the sale of the website and/or the entity that owns the website, 12 ‘Complaint 1200/00/2015 09:15:52 FAX 2132499990 NATIONWIDE LEGAL ee ee) 10 rt 2 13 4 15 16 7 18 19 20 ai 23 m4 2s 26 28 ‘as well as income in any other form from Hello. Giggles; (2) “New Girl”; and (3) the ‘Tommy Hilfiger advertising | ‘campaign on which Deschanel performed services. Qn Plaintiff's Third Cause of Action for Quantum Meruit: 4, For compensatory damages according to proof at trial. Plaintit ‘Action for yuntit = For an accounting of all sums due from Deschanel to Seven Summits pursuant to the ‘Management Agreement. On All Causes of Action: 6. For costs of suit to the extent Permitted by law. 1. For interest at the maximum rate permitted by law. 8. For such other and further relief as the court may deem proper. Dated: Decemberl 2015 teven B. Stiglitz Attorneys for Plaintiff ‘Seven Summits Pictures & Management, LLC 13 Complaint 1300/00/2015 09:15:52 FAX 2132499990 NATIONWIDE LEGAL wr 2 RE RATT TR SR arr — UM Hityan 3. Presduany vege aa asioo0y 3 Steven B. Stiglitz, Esq. (SBN 222667) ‘ONFORMED copy FREEDuaw 4 TADTSUtAn Gp sgetGNaeR G8 1901 Avenue of the Stare, suite soo ein aos Calton Los Angeles, CA 90067 wmeroneKo; 310-201-0005 __raxno: 310-201-0045 DEC 16 205 re Shanon Coot ores smervwonse 111 North Weil Stresses ee Secutve = cminaioiee Los Angeles, CA $0022 the Grave, Deputy ee Gee SEVEN SOMTTS PICTURES © WANG, TEV. CIVIL CASE COVER SHEET Complex Case Desi ion CASE NUMBER: United Cmte [ cmner setae i. Filed with frst appearance by defendant | su0ce| Seiten Bact Menem =BC6 040 79 To 1 Bao mua bs conpbed lve hates OUR [F Greek oe bar elow ore ase peat bes coches cen ee ‘mrston cee Prova Carp igen Auto (22) Gc] Breseh ot contractwarranty (06) (Cal. Rules of Court, rules 3.400-3.403) Tosmere nit Jute 2.740 catectons (00) T Anttretrade regulation (08) Seeeathersoaen = [foment comma asbestos (04) (J other contract (37) S) securities tigation (28) | Product lability (24) Real Property ( EnwronmentayToxic tort (30) /Medical malpractice (45) Eminent domainfinverse (5) insurance coverage claims arising from the (other pupa (23) ‘condemnation (14) above listed provisionally complex case ‘Non-PUPDAWD (Other) Tort J wrongful evietion 33) types (41) business torvnfak business practice (or) (1 Oter el property (2) Enforcement of Judgment (civ rights (08) ‘Unlawful Detainer [) Enforcemant of judgment (20) (2) defamation (13) [1 Commercial (1) ‘Miscellaneous Civil Complaint Frawa (16) Residentiat (32) CG ricoen ) intetectust property (19) Tongs «38 () otter complaint (not specified above) (42) Peterson me 2) roped cme ercaee (other non-PUPOAD tort (35) Asset forteiture (05) | Partnership and corporate governance (21) Employment Petition re: arbitration award (11) [_] Other petition (not specified above) (43) (wrongful termination (36) () writ ot mandate (02) other employment (15) J othar jusicia review (39) 2 Thiscase (_] is [x] isnot complex under rule 3.400 of the California Rules of Court ifthe case is complex, mark the {acorn equtagexcaplonal ical mantseoars 2 ELF Groe numoeret eoparateyrepevered partes, (] Large number of winesses b. [71] Extensive motion practice raising diffcult or novel e. [—] Coordination with related actions, ‘pending in one or more courts: issues that wil be time-consuming to roslve inother counts, sate, or counties, ora fer court c. (—) Substantial amount of documentary evidence, ‘Substantial postjudgment judicial supervision ‘3. Remedies sought (check all that apply): a. (x_) monetary b. ‘nonmonetary; declaratory or injunctive relief c. [—] punitive 4. Number of causes of action (specify): 4 5. Thiscate (is not aclas econ sul 6. thre are any known related cases, le and seve a nace fread cate, Giv15) Date: 12/36/2018 PRINT aT NOTICE * Plaintitf must file this cover sheet withthe fist paper fled in the action or proceeding (except small claims cases or cases fied under the Probate Code, Family Code, or Welfare and Insitutions Code). (Cal. Rules of Court, ule 3.220.) Failure to fle may resul| sanctior + File this caver sheet in addition to any cover sheet required by local court rue. « If this case is complex under rule 3.400 et seq. of the Califomia Rules of Cour, you must serve a copy of this cover sheet on all ‘other partes tothe action or proceeding. + Unless ins a calectons case under re 8.740 ora complex case, hs cover shee wi be used for stata purposes ony "face Cavcitonieae CIVIL CASE COVER SHEET, odie Ghee eae citar dy crs00/00/2015 09:15:52 FAX 2132499990 > 3 To Plaintifs and Others the case is complex. Auto Tort ‘Auto (22)—Personalnjuy/Property DamagenWrongful Death Uninsured Motorist (46) (tho ‘ase involves an uninsured ‘motorist claim subject f0 arbitration, check thi am Instead of Aute) (Other PUPDIWVD (Personal Injury! Property Damagenirongful Death) Tor ‘Asbestos (08) ‘Asbestes Property Damage ‘Asbestos Personal injury? ‘Wrongful Death Product Lilly (not asbestos or toxicenvirormental (24) Medical Malpractice (35) ‘Medical Malpractice Physicians & Surgeons Other Professional Heath Care Malpractice ther PUBDIWD (23) Premises Lisilly(¢.9, sip ‘and fl) Intentional Body ijuyrPOv ssaut vandalism) IntetionlInfction of Emotional Distress ‘Negligent inticion of Emotional Distrass Ober PUPOMWD Non-PUPDIWD (Other) Tort Business Tor/Urtar Business Practice (07) (hut Rights (0.9. discrimination, false arrest) (ot cil herassmend (03) Defamation (eg, slander, Hal) « Fraud (16) Intellectual Propery (19) Professional Negligence (25) Legal Malpractice Other Professional Malpractice {ot medial or fge) ther Non-PUPDAWD Tar (35) Employment Wrongful Termination (36) ther Employment (15) arate tay 207 iling First Papers. ‘complete and fle, along with your frst paper, the ‘statistics about the types and numbers of cases ‘one box for the case lype that best describes the heck the more specific one. ifthe ease has mult To assist you in completing the sheet, exam) sheet must be fled only with your ial pape ‘counsel, or both to sanctions under rules 2. To Parties in Rule 3.740 Collactions Caso: ia sum states to be certain that is not more than $25,000, exclusive of Droperty, services, or money was acquired on crodit. A collections damages, (2) punitive damages, (2) recovery of real property, (4) reco The identification of a case as a rule 3.740 collections case on this, requirements and case management rules, unl to the requirements for service and obtaining a judgment in rule 3.740, To Parties in Complex Cases. In complex cases only, case is complex. I a plaintiff believes the case Is comple ‘completing the appropriate boxes in items 4 Ccompiaint on all parties to the action. A pleintf's designation, a counter-designat jon that the case is not complex, NATIONWIDE LEG! CASE TYPES AND EXAMPLES Contract Breach of ContractWaranty (06) Broach of Rentals ‘or wrongful eviction) CContracvWarranty Breach—Seler alti (ot fraud ‘Neglgent Breach of Contac Taran ‘omer Breach of ContractWerranty Collections (ag, money owed, open ‘ok aecouris) (09) Colecton Case—Soler Paint Otter Promissory NoteCallacions Cane Insurance Coverage (not provsionaly compies) (18) ‘Auto Subrogation ‘ter Coverage otter Contract (37) ‘Contractual Fraus (Other Conta! Dispute Real Property Eminent Demaln/inverse ‘Condemnation (14) ‘wrongtl Evletion 23) Other Real Property (e.9., quel ta) (26) ‘Wht of Possession of Real Property Mortgage Forectoaure uit Tite (thar Rest Property (ot ominant ‘oman, andoratenant or foreclosure) Uniawful Detainer ‘Commercia (31) Resident (32) Drugs (88) i tho caso involves ileal rugs, check this tem; ethonw report as Commercial r Resident) sical Review ‘Asset Forfeture (05) Petition Re: Ariraton Award (13) Writ andate (02) Wiit-Adminisatve Mendamus ri-Mandamus on Linked Court Case Matter ‘Wrt-Other Lnted Cour Case Review (ther Judea Review (38) Review of Heath Ofer Order [Notice of Appesl-Labor Commissioner Appeals CiViL CASE COVER SHEET Failure to file a cover shoct with the fst 1nd 3.220 ofthe California Rules of Cour ‘A “collections cose" under rule 3.740 is defined as an action for recovery of money owed 3 interest and attomey’s fees, arising from a transaction in which {case does nol include an action saeking the following: (1) tort very of personal property, or (6) a prejudgment wit of attachment form means that it will be exempt from the general time-for-servce 2 defendant files a responsive pleading. A rule 3.740 collections case wil be subject INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET cM.o10 4 you are fling a first paper (for example, a complaint) in a civil case, you must Civil Case Cover Sheet contained on page 1. This information will be used to compile filed. You must complete items 1 through 6 on the sheet. In item 1, you must check Case. Ifthe case fits both a general and a more specific type of case listed in item 1, tiple causes of action, check the box that best indicates the primary cause of action iples ofthe cases that belong under each case type in ilem 1 are provided below. A cover Peper filed ina civil case may subjeet a party, ts Parties must also use the Civil Case Cover Sheet to designate wether the x under rule 3.400 ofthe California Rules of Cour and 2. if plaintiff designates a case as complex, the cover sheet must be served with the defendant may file and serve no later than the time of lis fist appearance a joinder in the 0, ifthe plaintif has made no designation, a designation thet this must be indicated by Provisionaly Complox Civil Litigation (Cal, Rules of Court Rules 3.400-3.403), ‘Antitus/Trace Regulation (23), Construction Detect (10) Claims involving Mass Tort (40) Secuitios iigaton 8) Environmental/Toxc To (30) Insurance Coverage Claims (arising rom provsionaly complex case type lsd above) (43) Enforcement of Judgment Enforcement of Judgment (20) ‘Abstract of Judgmant (Out of ‘County) Confession of Judgment on ‘domestic relations) Sista State Judgment ‘Administrative Agency Award (rot unpaid taxes) Pettion'Canttetion of Enty of Judgment on Unpaid Taxes (Other Enforcement of Judgment Case Miscellaneous Chit Complaint ICO (27) Other Complaint (nt speciid ‘above) (2), Decaratoy Rett Only injunctive Retet Only (non- ‘haressment) Mecanic Lien (Other Commercial Complaint Case (nerterthon-camplox) (ther Civt Complaint (nonaeinan-complex) Niscellaneous Cll Petition Parinrship and Corporate Governance @1) ‘other Petton (rot spectiog ibove) (43) Civ Harassment Workplace Violence lderDependent Adut ‘Abuse ‘lection Contest Pelion for Name Change Potton fr Ralf trom Late ‘Cai ther Ci Petition00/00/2015 09:15:52 | AX 2132499990 NATIONWIDE LEG | [S8™= SEVEN SUMMITS PICTORES & MANAGEMENT, LEC v. | SenmaE | Lgoogy DESCHANEL ae CIVIL CASE COVER SHEET ADDENDUM AND. STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to Local Rule 2.0 in all new clvil case flings In the Los Angeles Superior Court. Item I. Check the types of hearing and fillin the estimated length of hearing expected for this case: Jury TRiav? [3¢] Yes class AcTION? [_—] Yes umiTED case? [—] YES TIME ESTIMATED FOR TRIAL_3 [—lNouRsE]oays j tem ll Indicate the correct district and courthouse location (4 steps ~ If you checked "Limited Case’, skip to Item Il, Pg. 4): Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your case in the left margin below, and, tothe rightin Column A , the Civil Case Cover Sheet case type you selected. ‘Step 2: Check one Superior Court type of action in Column B below which best describes the nature of this case. Step 3: In Column C, circle the reason forthe court location choice that applies tothe type of action you have checked, For any exception to the court location, see Local Rule 2.0. Applicable Reasons for Choosing Courthouse Location (see Column ¢ below) ions must be fed inthe Stanley Mosk Courthouse, central ste. §. Location of property or permanonty garaged vec ay bed in cena eter coury. oto body njaypropeey Som { teeaton wore plone res. tetatn here cume sf acign ayer "oY MTPOETY Camp” a eA StS ot cts wal, {cation where Bodily uty, cea of damage occured. 3, {Sater wer rg arma ha gars von, Location where performangs reqed of Gtendant ratios, 10, (oeaton af taporCommasioner ice ‘Step 4: Filln the information requested on page 4 in Item Ill; complete Item IV. Sign the dectaration. Chi Case CoverSheot | Type ofadion ss g Gategory Now Reese (Check only one) 2 3 Auto (2) [A700 motor Vehicle -Porsona lyun/Propety Demage”Wrengtul Death Uninsured Motorist 46) | [_) a7110 Personal nunyroperty DamageMirongtu Death Uninsured Motos | 1, 2.4 —] As070 Asbestos Propeny Damage 2 2 ne [J azzat_asbestos - Personal injuryiWrongful Desth 2 Q Be Product Libilly (28) | [) 47260 Product Liblity (not asbestos or toxiosenvironmental) 142,348 } é y 38 ( Arat0 Modi! mapractin-Physians & Surgeons ta BE | NedestMebractce 4S) | arz4o other Professional Heath Care Mabrectice tad, 5 [) araso Premises Usb (esp ad tal) 1a 3 pen tg 7230 in! a hy Prery Doge Deano ie pearl iny | ASO Sr eat ga Wrongful Death 'A7270 Intentional lnfcon of Emotional Distress a [= ar220 other Personal ijur/Property Damege/Wrongtl Death LAGI 108 Rew. 037 8) CIVIL CASE COVER SHEET ADDENDUM Local Rule 20 USC Approved 09.04 AND STATEMENT OF LOCATION Page tof 400/00/2015 09:1 FAX 2132499990 NATIONWIDE LEGAL SOMME SEVEN SUMMITS PICTURES & MANAGEMENT, [sewer Lune vy. ZO0RY DESCHANEL, Business Tor (07) [1 A8029 other CommercavBusinass Tort (not raud/bresch of contract) — 4.3. Be es 1.2.8 $8 ES Defamation (13) ([ Ato10 Defamation (sianderibel 44243. z Fraus (16) ) A6013 Fraud (ne contract) 4, 33 [A050 Other Professions! Malpractice (nol medical or egal) 4,23. Other (25) Ase26 other Non Personal InjuyiProperty Damage tot 2.3. i Wrongful Termination (96) | [—] 8037 Wrongful Termination 142.3 3 2 ‘8024 Olter Employment Complaint Case 1.2.8 ines Employment (x5) |! E mpommen'(18) |] aston Later CommisinerAspeals ‘a, (soos Breach efRntatease Contact (not uniwldeainerorwrongtal) 2. Bresch of Contact Warranty ont () 8008 Contracuwrranty Breach -Soller Pini (no fraudinegigence) (not insurance) (—) Asors negigent Broach of ContactWarrenty (no aud) CK) A828 other Breach of Contractnvarranty (not raud or negligence) g & a J Asoo2 Cetlectons Case-SeterPiainttt : lectins (05) (1 Asot other Promissory NoteCotections Case [A601 insurance Coverage (not compiex) Insurance Coverage (18) 1.2.5.8. 5 A6009 Contractual Fraud 142,345 ‘Other Contract (37) (J As031 Tortious intererence 1.2.3,8, (1 6027 Other Contact Dspute(not broachinsursncefaucnegigence) | 1.2.3.8 Eminent Demainiinverse ; ‘Condemnation (1), | C1 A7300 Eminent Demain/Candermation Number of parcels a, Wrongful Eviction (33) ") A6023 Wrongful Eviction Case 2.8 Real Property (ther Real Propery (26) [ As018 Mongage Forectosure (5 agos2 auiet Tite [| A800 otherReatPropeny (ncteminontdomain,lordlordenant foreclosure) g_ [Um Detaper Commarea! [| goat Unlawtl Detain Commer (not rugs or wrongful eviction) | 2.8 | UnewtbetaigerResdental [[) qgozo unawid Dear Reacerta (ct ang orwengl even) | 26 2 ‘Unawful Detaner——[— Fis EL eS “| A6CZ0F Uni Detainar Pest Fred 2.8. 5 | unavut Detsinerorge (28) | [1 ABt22 Unlawhd Detaner rugs 2.8, LAGI 108 Rev. 03717) CIVIL CASE COVER SHEET ADDENDUM Local Rule 20 LASC Approved 03.08 AND STATEMENT OF LOCATION Page 201400/00/2015 09:15:52 FAX 2132499990 NATIONWIDE LEGAL rowwme SEVEN SUMMITS PICTURES @ MANAGEMENT, ‘Case NEE LLC v. ZOEY DESCHANEL LASC Approved 03-04 AND STATEMENT OF LOCATION Asset Forwture(0s) | [—} aston Asset Foretue Case 2.6. E | rewon eartatoncy | lass Petion to Compe/Confim/VecateAstitration 26. é zs (J A651 wit administrative Mandamus. 2.8, 3 ‘Wrtot Mandate (02) | (7) 46152 Wit-Mandamus on Linied Court Case Matter 2 3 As169 wit- Otter tinted Cour Cate Review 2 Other suai Review (33) | [—] A810 Other Wit ica Review 2.8 & _[ArtivsvtraceRepuaton(09)] [—] as00a Anti Tade Reguton 1.2.8 2 ‘Construction Defect (10) [J 6007 Construction Defect 14243. B | Setetnege ess Tor | n6t06 caine motng ass To ae Z| Secures tration ze) | C1 as0as Secuiis gation Go 1.2.8 5 2 [etettes | | lpm mateeeass 12.3.8 © [Thaurance Coverage caine ‘yam Cong Si ‘A80%4Insranea CovergeSuboaton (onyx cave on 128 (7 astat Sister State Judgment 2.8 aE (7 aste0 Abstract ot Judgment 2.8 bE fc [1 ast07 Confession of Judgmant non-domestic relations) 28 83 of Judgment (20) (1) A6140 Administrative Agency Auard (not unpas taxes) 2,8. ae 1 ast14 Pebtwenteate for En of ucgment on Unpaid Tax 2.8 1 A612 other Enforcement of Judgment Case 2.8.9. RICO @7) (7 sos Recketosing (RICO) Case 1 gz aE no acy etry cae 38 Other Compaints |] AB040 injunctive Reb! Ont (ot domestnarassmert 2a ES | erszectes Abo) ce | aaort omer comma Conpnt ise ronieunoncanpen | trace a5 6 (Aso othe iv Compie ronsortnon complex) 1.2.8. Partnership Corporetion (4 13 Partnership and Corporate Governance Case 2,8, Governance (21) ents = e —) A612 Civil Harassment 2.3.48 (= 46123 workplace Harassment 2.3.8 le nities TF ast2t eiderDependnt Adu Abuse Case 24.9 (wot Specines Above) | [—) agt90 Becton Cores 2 Ge “| A6110 Petition for Change of Name. 2,7. = as170 Peon for Rett from Late Ciaim Law 2.85448. ps0 other cv Pettion 2.8 LAGI 708 (Rew 03717) CIVIL CASE COVER SHEET ADDENDUM Local Rule 20 Page 3 of 400/00/2015 09:15:52 FAX 2132499990 NATIONWIDE LEGAL ‘sorting SEVEN SONMITS PICTURES & MANAGEMENT, LLC v.|oasunear ZOOEY DESCHANEL. SRE. Statement of Location: Enter the address ofthe accident, partys residence or place of business, performance, or ther reumstance indicated in Item I, Step 3 on Page 1, as the proper reason for fling inthe court loeaton you selecisa “ORES ie eo 8906 W. Olympic Blvd., Garden ris Cortho ype of ecton takyouhavescecedtor | Level O1.02.03.004.05.06.07.08, echo, Beverly Hills ca _|goaaa item IV. Declaration of Assignment | declare under penalty of perjury under the laws ofthe State of Califo thatthe foregoing is tue ‘and correct and that the above-entited matter Is property fled for assignment tothe Los Angeles ‘courthouse in the Central District of the Superior Court of California, County of Los Angeles [Code Civ. Proc., § 382 et seq., and Local Rute 2.0, subds. (0), (c) and (4). Dated: 12/26/2015 (BRATURE OF ATTORNEVRUNG PRR —————— Bryan J. Freedman, Esq. CLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: |. Original Complaint or Petition. 1 2. If fling a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010. 4 Saf Fase Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev. N Payment in full ofthe filing fee, unless fees have been waived. ‘A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plait or petitioner is @ ‘minor under 18 years of age wil be required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum ‘must be served along with the summons and complaint, or other intiating pleading in the case. {ACIV 109 (Rev. 03748) CIVIL CASE COVER SHEET ADDENDUM Local Rule 20 LASC Approved 09-04 AND STATEMENT OF LOCATION Page 4 of 4