Plaintiff, an individual, hereby alleges as follows:
1.This court has jurisdiction over this matter, and venue is proper inpart pursuant to 17 U.S.C. 77v, and Cal. Code Civ. Proc. Sections 395 and 395.5in that at all times relevant hereto defendant Suzanne L. Bowser and defendantSuzanne Lambert Bowser LLC (“the defendants”) conducted business in California,including Humboldt County. The defendants as well as DOES 1 through 50 engagedin substantial, systematic, and continuous activities in California in order toeffectuate the sale of movie investment securities in Humboldt County. Theamount in controversy among the parties exceeds the jurisdictional minimum ofthis Court.2.Plaintiff was induced to make the investment alleged herein in partpursuant to personal meetings between plaintiff and defendant Suzanne L Bowser,for her own account and in her capacity as an member of defendant Suza LambertBowser LLC, occurring in Humboldt County, California. The letter agreementdated August 10, 2009, establishing a partnership, is attached hereto as ExhibitA-1 (hereinafter “the Letter Agreement”) alleged herein was entered into byplaintiff in Humboldt County, California.
E-mails from defendant Suzanne L. Bowser, many of which areattached as print outs in Exhibit B, as well as the Letter Agreement, establishthat:a) defendant Suzanne L. Bowser held herself out as possessing professionalknowledge of the movie production industry;b) defendant Suzanne L. Bowser solicited plaintiff to invest in apartnership investment that would produce movies with defendant Suzanne LBowser running the partnership business; and,c) defendant Suzanne L. Bowser sold a security interest, withoutregistration or Federal or state securities exemption, to the plaintiff to