IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. é TEASE LOUNGE, INC, " a Florida Corporation, GO 2012CA 01258 4 XXXXNB A Plaintiff, 3 8 v. 35 5 : ae = NATALIE SULEMAN, a Ss m cz Defendant. ge Oo 322 I sey 2g PLAINTIFF’S VERIFIED MOTION FOR EMERGENCY HEARING FOR TEMPORARY INJUNCTION Tease Lounge, Inc. (“Plaintiff”), by and through its undersigned counsel, hereby files Plaintiff's Verified Motion for Emergency Hearing for Temporary Injunction, and in support thereof states as follows: 1. Plaintiff is a corporation organized and existing under the laws of the State of Florida, which operates an adult entertainment establishment known as T’s Lounge. As part of the operation of the establishment, Plaintiff hires various entertainers/celebrities to be featured entertainers. 2. Natalie Suleman (“Defendant”) has obtained notoriety and is also known as “Octomom”. On or about June 3, 2012, Plaintiff entered into a written Agreement (attached hereto as Exhibit “A”) with Defendant to perform at Plaintiff's establishment. 3. Pursuant to the terms of the Agreement, Defendant agreed to perform a number of shows at Plaintiff's establishment during a four day period commencing on July 11, 2012 and terminating on July 14, 2012.4, The Agreement specifically indicated the type of dance shows which Defendant agreed to perform. 5. Pursuant to the special terms and conditions of the Agreement, Defendants performance at Plaintiff's establishment would be Defendant’s “1* Featured Dance Appearance”. 6. The Agreement also provided that either party to the Agreement would be permitted to cancel the Agreement by providing the other party with thirty-five (35) days advance written notice of the event/appearance of Defendant. 7. Defendant unilaterally cancelled the Agreement with Plaintiff. A copy of the notice of cancellation and the confirmation sheet is attached hereto as composite Exhibit “B”. 8. Since Defendant's first performance was to take place on July 11, 2012, Defendant’s notice to Plaintiff is untimely. Said notice was given only thirty-four (34) days prior to the event/appearance of Defendant, and therefore, Defendant is in breach of the Agreement with Plaintiff. 9. Such notice of termination caused Plaintiff to incur costs in advertising Defendant’s performance at Plaintiff's establishment. 10. In addition, the exclusivity provision of the Agreement, specifically paragraph 18, states that Defendant “shall not be booked or advertised to appear at any Gentlemen’s Club within 50 miles of CLUB within Ninety (90) Days, (Prior or Post) of the engagement date(s)”. Plaintiff has discovered that Defendant is scheduled to appear at another gentlemen’s club located in Hallandale, Florida on July 13", 2012, which was one of the same dates that Defendant was to perform at Plaintiff's establishment. 11. Attached hereto as Exhibit “C” is a copy of an advertisement that appeared in a trade publication for the month of July, whereby Defendant’s appearance is advertised on one of the same days on which Defendant was to appear at Plaintiff's establishment.12. Plaintiff has notified Defendant of her breach of the Agreement (a copy of said letter is attached hereto as Exhibit “D*), Defendant has failed to respond to said letter. 13, Not only has Defendant breached the terms and conditions of the Agreement with Plaintiff, but by Defendant agreeing to perform in: another establishment so close in proximity to Plaintiff's, Plaintiff's damages are unascertainable and Defendant’s actions shall cause Plaintiff irreparable harm. 14, As there can be only one “1% Feature Dance Appearance”, it would be impractical, if not impossible, to establish the damages to Plaintiff resulting in the breach of the Agreement by Defendant and by Defendant agreeing to perform at another gentlemen’s club so close in proximity to Plaintiff's. 15. There is no possible way that Plaintiff can determine its damages for the loss of the “1 Feature Dance Appearance”, especially due to the fact that Defendant is adding insult to injury by electing to not only breach her Agreement with Plaintiff, but also by selecting another gentlemen’s club in such close proximity to Plaintiff establishment thereby causing additional damages to Plaintiff. 16. The only way to preserve the status quo is for this Court to enter a temporary injunction to prohibit Defendant from appearing at any gentlemen’s club until this dispute is resolved between Plaintiff and Defendant: 17. The issuance of a temporary injunction by this Court to prohibit Defendant from appearing at any gentlemen’s club is the only way to avoid this irreparable harm to Plaintiff, 18. The appearance by Defendant at a gentlemen’s club in such close proximity to Plaintiff's establishment, will cause Plaintiff. immediate, temporary and permanent irreparable injury, and Plaintiff has no other adequate remedy at law. 23. Plaintiff would request that this Court conduct, an emergency hearing to enter a temporary injunction since it is evident that Defendant has