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Pauly D Lawsuit 2

Pauly D Lawsuit 2

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Published by: SharonWaxman on Apr 12, 2012
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11/17/2012

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BRYANJ.FREEDMAN,Esq.(SBN151990)BRIANE.TURNAUER,Esq.(SBN214768)
FREEDMAN
&
TAITELMAN,
LLP
1901Avenue
of
theStars,Suite500
LosAngeles,CA90067
(310)201-0005(310)201-0045
E-mail:bfreedman@ftllp.com
bturnauer@ftllp.com
/PR
12
2012
Attorneys
for
Plaintiff
International
CreativeManagement,
Inc.
John
A,
ciarKe.
Executive
ofli<xf/Cicrk
by
AaM^T'.
SUPERIOR
COURT
OF
THESTATE
OF
CALIFORNIA
FILED
SUPERIOR
COURTOFCALJFORN1A
COUNTY
OF
LOS
ANGFXES
,Deputy
FORTHECOUNTY
OF
LOSANGELES
INTERNATIONAL
CREATIVE
MANAGEMENT,INC.,aDelaware
Corporation,
Plaintiff,
vs.
PAULDELVECCHIO,JR.aka"DJPaulyD,'
anindividual;
BLOWOUT
ENTERPRISES,LLC,a
Rhode
Islandlimitedliability
corporation;
andDOES
1
through
50,
inclusive,
Defendants.
BC48874*
Case
No.:
COMPLAINT
FOR:
1.
BREACH
OFWRITTENCONTRACT
2.
IN
THE
ALTERNATIVE,
BREACH
OF
ORAL
CONTRACT
3.
QUANTUM
MERUIT
4.
ACCOUNTING
5.
DECLARATORY
RELIEF
_)
Plaintiff
InternationalCreative
Management,
Inc.,
a
DelawareCorporation
("Plaintiff
or
"ICM"),
complains
against
defendants
Paul
DelVecchio,
Jr.
aka"DJPaulyD,"
an
individual
("DelVecchio"),
BlowoutEnterprises,
LLC,
a
RhodeIsland
limitedliabilitycorporation
("Blowout")
(collectively,
Defendants"),
and
DOES
1-50,
as
follows:
III
III
III
IIIIII
1
COMPLAINT
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\
\
1*
ID
1
2
3
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6
789
10
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2728
INTRODUCTION
1.
DelVecchio
goes
by
thename
"DJ
PaulyD"
on
a
widelypopular
MTV
realitytelevision
show
entitled
Jersey
Shore
(the
"Jersey
Shore").DelVecchioasked
ICM
to
represent
him
after
the
firstseason
of
the
Jersey
Shorewhen
MTV
refused
to
compensate
him
despite
the
virtuallyovernightsuccess
of
theshow.
ICM
went
to
batfor
DelVecchio,successfully
negotiatinglucrativeamendments
to
DelVecchio's
participationagreement
with
MTV.
Because
of
ICM's
efforts,
DelVecchio,through
hisloan
outcompanyBlowout,earns
a
substantial
sum
for
each
season
of
JerseyShore
and
has
endorsement
deals
and
side-projects
based
onhis
DJ
Pauly
D
persona.
2.
No
good
deed
goes
unpunished,
however,
and
DelVecchioultimatelyterminatedthe
representation.
Now,
DelVecchio
and
Blowout
refuseto
pay
ICM
nearly$400,000
in
commissions
on
amounts
Defendants
have
alreadyreceived.
Defendants
have
alsounequivocally
announced
thatthey
have
no
intention
of
paying
ICM
over$200,000
in
commissions
on
future
money
DelVecchio
and
Blowout
are
set
to
earn
from
Jersey
Shore
despitetheir
contractual
obligationtodoso.
3.
ICM
attempted
to
resolve
the
matterinformally,butDelVecchiorefused
to
even
acknowledge
the
contractualobligationsbinding
himand
hisloan
out
company.Accordingly,
ICM
was
left
with
no
choice
but
to
file
thislawsuit.
By
thiscomplaint,
ICM
seeks
to
hold
Defendantsliable
for
theirpurposeful
and
intentional
breach
of
their
talent
agency
agreement
with
ICM.
ICM
seeks
judicial
intervention
to
help
the
agency
collectcommissions
on
the
hundreds
of
thousands
of
dollars
that
Defendants
havealreadyearned
on
Jersey
Shore.
ICM
furtherseeks
a
judicial
declarationthat
it
is
entitled
to
commissions
on
substantial
sums
in
excess
of
$200,000
to
be
paid
to
Defendants
as
a
result
of
ICM's
hardworkand
dedication
to
Defendants'
career.
PRELIMINARYALLEGATIONS
4.
ICM
is,
and
at
all
times
materialhereto
has
been,
a
corporation
duly
organized
and
operating
under
the
laws
of
the
State
of
Delaware,withits
principal
place
of
business
located
in
the
County
of
Los
Angeles,State
of
California.
ICMis,
and
at
all
timesrelevant
hereto
was,
licensed
as
a
talent
agency
by
theLabor
Commissioner
of
the
State
of
California.
2
COMPLAINT
 
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5.
Upon
information
and
belief,
ICM
allegesthat
at
all
timesmaterialhereto,
DelVecchiohasbeenan"artist"asthattermisdefinedinSection1700.4(b)oftheCalifornia
Labor
Code.
DelVecchio
isan
actorregularlyworking
intheentertainment
industry
and,
accordingly,
has
entered
into
numerous
contracts
in
theCounty
of
LosAngeles,
California,including
a
contract
with
MTV.
DelVecchio
is
and
has
been
represented
by
entertainment
counsel,business
managers
and
agents
whose
officesarelocatedinLosAngeles,
California.These
lawyers,agents
and
business
managers
regularlyconduct
business
on
his
behalf
in
the
County
of
Los
Angeles,
California.Moreover,
upon
information
and
belief,
ICM
alleges
that
DelVecchioperforms
DJ
services
and
other
music
related
performances
in
theCounty
of
LosAngeles,State
of
California
6.Upon
information
and
belief,
ICM
allegesthatBlowout
is
a
RhodeIslandlimited
liability
corporation
which,
at
all
relevant
times,
was
authorized
todo
business
in
the
State
of
California.
Atalltimesmaterialhereto,BlowouthasbeenDelVecchio'spersonalservices
corporation,loaning
out
DelVecchio's
services
as
an
actor
in
the
entertainment
industry.
7.
The
true
names
and
capacities,
whetherindividual,corporate,associate
or
otherwise
ofthe
defendants
named
herein
as
Does
1
through
50,
inclusive,
are
unknown
to
ICM
which
therefore
suessaiddefendants
by
such
fictitious
names.
ICM
alleges
on
information
and
belief
that
each
ofthe
defendants,includingthosedesignated
asa
Doe,are
responsible
for
the
events
alleged
herein
andthe
damagescaused
thereby
asa
principal,
agent,
co-conspirator
or
aiderandabettor.ICMwillseekleave
of
CourttoamendthisComplainttoallegethetrue
names
and
capacities
of
such
defendants
when
the
samehavebeen
ascertained.
8.
Uponinformation
and
belief,
ICM
allegesthatDefendants
andDoes
1
-50
at
all
times
relative
to
thisaction,
were
the
agents,
servants,partners,
joint
venturers
and
employees
ofeach
of
theotherDefendantsandDoes1-50and,indoingtheactsallegedherein,wereacting
with
the
knowledge
and
consent
of
each
of
the
otherDefendants
and
Does
1-50
in
thisaction.
9.ThisCourthasjurisdictionoverallDefendantsbecauseoninformationand
belief,Defendants
have
entered
intonumerous
contracts
inthis
forum,
regularly
conductbusiness
inthis
forum,
have
performedseveral
concerts
inthis
forum
andhave
hiredagents,
3
COMPLAINT

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