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4 OPTIMUM PRODUCTIONS, gop Miles J, Feldman, Esq. (SBN: vai “ sree iles J, Feldman, Esq. (SBN: 173383) JOHN le adnan hen ) oe ‘com Camilla Y. Chan, Esq, (SBN: 241674) 4 Cchan@linerlaw,com N 212009 LINER YANKELEVITZ SUNSHINE & REGENSTREIF LLP 1100 Glendon Avenue, 14th Floor ‘Los Angeles, Ralstonia 200243305 ‘Telephone: (310) 500 Fern ne: ty) S00. 380 Attorneys for Plaintiff Levitsky Productions, Ine. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, WEST DISTRICT LEVITSKY PRODUCTIONS, INC., a caseNo, SCL01420 California corporation, COMPLAINT FOR: Plaintiff, g BREACH OF WRITTEN v. INTRACT; 2) ACCOUNTING; RSI NI CONVE! 3 (ON: AND. California corporation; 4 BREACH OF FIDUCIARY JACKSON, an individual; and DOES 1 through 10, inclusive, Defendants. DEMAND FOR JURY TRIAL INITIAL CASE MANAGEMENT REVIEW AND CONFERENCE May 11 2009 LINDA K. LEFKOWITZ Weert MO Bsoan, Case No, COMPLAINT a 013014017 414707008 Plaintiff Levitsky Productions, Inc. (“Plaintiff” or “Levitsky”) alleges as x follows: INTRODUCTION 4 1. Inor about 1983, the parties created the 14-minute motion picture music video for Michael Jackson's hit song, “Thriller” (the “Thriller Video”). After a spectacular theatrical premier, the Thriller Video became a worldwide mega-hit and an iconic pop culture phenomenon that has continued to generate profits for ie 6 7 8| Defendants Optimum Productions and Michael Jackson, who have wrongfully 9 | refused to pay or account for such profits to Plaintiff. oO THE PARTIES n 2. Levitsky is a corporation organized and existing under the laws of the 12| State of California and is, and was at all times mentioned herein, qualified to do 13 | business in California. Levitsky furnishes the services of John Landis (“Landis”), 2 14 | well-known director, producer, and writer. 1 3. Upon information and belief, Defendant Michael Jackson (“Jackson”), 16 | at all times mentioned herein, has done, and currently does, business in the County of 17| Los Angeles. 18 4, Upon information and belief, Defendant Optimum Productions 19 |(“Optimum”) is a defunct corporation that has been suspended by the California 2 2 2 2: 8 Secretary of State, Upon information and belief, Jackson used Optimum to procure labor, services and/or goods on his behalf and that Optimum was the alter ego of Jackson and was established for the purpose of collecting funds due to Jackson for his various musical works and distributing such funds as required (collectively 24|“Jackson/Optimum”). Upon information and belief, Jackson was the alter ego of 2 20 Optimum and that, among other things: Optimum failed to observe proper corporate formalities and served as a mere conduit for transferring wealth from Optimum to x | Jackson; Jackson is the sole shareholder of Optimum and exercises complete 2 dominion over the corporation; Jackson commingled his funds with those of 2 Case No. COMPLAINT (0013014001/414707v08