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Roberts “RICK ROSS”, but
none of the Defendants had a right to use the name,
and Defendants ignored letters from Plaintiff‟s lawyer in
October-November,2006 to Def Jam
, to stop using “RICK ROSS” name,
and the 2006 letters areattached hereto as Exhibits C, D, and E. An online VH1.com news article dated07/27/2006 confirms that Defendant Roberts got signed by Defendants Carter,
Def Jam and UMG who “invested millions”, and a c
opy of that article isattached
and incorporated by reference as Exhibit “H”
, as well as the full pageback cover RICK ROSS magazine photo print ad for Roberts at
Exhibit “I”.
 137. Plaintiff Rick Ross is suing to take his name and image back from
Defendants‟ control, and
to stop Defendants from fraudulently misusing hisname.138. Plaintiff could not discover, through the exercise of reasonable due
diligence, the full scope of Defendants‟ fraudulent acts because Defendantsnever responded to reasonable letters from Plaintiff‟s attorney sent directly to
Def Jam in 2006, which were a
cknowledged being received by “Nicole” by
telephone, plus Defendants fraudulently concealed their unlawful musicactivities from the public and Defendants failed to disclose or give any notice of name use to Plaintiff, or seek his consent, and Defendants materialmisrepresentations and omissions were intentional and done with intent todeceive Plaintiff and falsely induce reasonable reliance that the Defendants
Case 2:10-cv-04528-PA -RZ Document 1-2 Filed 06/18/10 Page 1 of 23
 
would do right, not the fraudulent, harmful acts done.WHEREFORE, Plaintiff demands judgment against each of theDefendants, individually, and/or jointly with each other, for civil damages
sustained as a result of Defendants‟ fraudulent actions, misrepresentations and
omissions, from 2006 to the present, concealed from Plaintiff, and Plaintiff request that this Court award monetary damages to Plaintiff in excess of $1Million for Defendants fraudulent actions, which caused this lawsuit, andPlaintiff demands legal remedies available under California law, common law,and the California Civil Code, in an amount to be determined at trial, but no lessthan $1 Million in compensatory damages, plus$1 Million in punitive damages,plus all injunctive remedies available in this Court as the direct result of 
Defendants‟ unlawful fraudulent activities, and an
order compelling Defendantsto pay all costs, disbursements and expenses paid by or incurred by Plaintiff, as a
result of Defendants‟ unlawful conduct, including attorneys‟ fees and court
costs, interest to the extent provided by law, and all such other damages andlegal and equitable relief this Court deems proper.
COUNT VIII
 – 
COLLUSION AND CONSPIRACY TO DEFRAUDPlaintiff v. all Defendants, individually and jointly
139.
Plaintiff Ricky D. Ross a/k/a “RICK ROSS” i
ncorporates byreference all the prior averments made in Paragraph 1 through 138, as if set forth
Case 2:10-cv-04528-PA -RZ Document 1-2 Filed 06/18/10 Page 2 of 23
 
at length.140. Defendants jointly engaged in fraudulent acts or omissions, todeceive the Plaintiff and deceive others, in collusion, agreements by two or morepersons to defraud a person of his rights or obtain an object forbidden by law,and in this case and controversy,
the object forbidden by law was Plaintiff‟s
name and rights that Defendants wanted, and acted fraudulently, and
maliciously, to control, use and convert to Defendant Roberts‟
benefit and
Defendants‟ ownership, unlawfully, and Defendants
 jointly employed fraudulentmeans to accomplish their unlawful purposes, and lawful means, to accomplishtheir unlawful purposes, by concerted business actions, secret combinations andagreements concealed from Plaintiff.141. Defendants jointly conspired and agreed to act in concert for thepurposes of committing, by their joint efforts unlawful acts, or lawful acts, byunlawful means, to achieve the
unlawful purpose of controlling Plaintiff‟s name,
likeness and identity which Defendants had no authority nor right to doindividually, nor jointly, but Defendants acted, in secret combination, as if theyobtained lawful authority or rights from Plaintiff or the USPTO to so act, andDefendants held themselves out to the world, falsely, as the holders and owners
of Plaintiff‟s name and rights, while they exploited the Plaintiff,
who was inprison with a life sentence, and maliciously used his name and identity for
Case 2:10-cv-04528-PA -RZ Document 1-2 Filed 06/18/10 Page 3 of 23
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