—$<<$<$<$$$<<_—_ wr ARRON VERTED COMPANY eT TG 0 oO SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS LARRY JOHNSON, Plaintiff, -against- SPENDAN SPORTS, LLC., DANIEL DECHON, individually, and SPENCER LADER, individually, Defendants 70 THE ABOVE NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the plaintiff’s Attorney within 20 days after the service of this summons, exclusive of the day of service service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgement will be taken against you by default for the relief demanded in the complaint. Date New York, N.Y. October 26, 2007 . -! \ index No.: UALS] Date Purchased: . Plaintiff designates County of NEW YORK As the place of trial The basis of venue designated is Defendant’s Place of Business. ‘SUMMONS Plaintiff’s address is 144-15 Hillside Avenue Jamaica, N.Y. 11435 . (or 30 days after the New York, New York 10038 (212) 566 2424SL 20727198 SLNMIONS AVERUED COMPLAMT (Pape 21) 7 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS aoe ne neX, LARRY JOHNSON Plaintiff, VERIFIED COMPLAINT ~against- rnpex ou: DAO} SPENDAN SPORTS, LLC., DANIEL DECHON, individually, and SPENCER LADER, individually, Defendants. aX The plaintiff, LARRY JOHNSON, by his attorney, MARVIN K. PETTUS, for its Verified Complaint against the defendants, SPENDAN SPORTS, LLC., DANIEL DECHON and SPENCER LADER alleges: 1. LARRY JOHNSON, is an individual residing in the State of Kansas, who is entitled to do business within the State of New York. 2. LARRY JOHNSON is a National Football League player and is in the business of merchandising and endorsements services. 3. Defendant, SPENDAN SPORTS, LLC., is a New York State Domestic Limited Liability Corporation having a place of business at 144-15 Hillside Avenue, Jamaica, New York 11435. 4, Defendant, SPENDAN SPORTS, LLC., is sports memorabilia purchasing, selling and marketing company. 5. DANIEL DECHON(*DECHON”) is an individual having a place of business at 144-15 Hillside Avenue, Jamaica, New York 11435. 6. Upon information and belief, defendant DECHON is a shareholder, member, director and/or officer of defendant SPENDAN SPORTS, LLC. 7. Upon information and belief, defendant DECHON has a financial interest in defendant SPENDAN SPORTS, LLC. 8. SPENCER LADER(“LADER”) is an individual having a place of10727198 SUMMONS A VEREIED COMPLANT (Page 310) 10. 11. 12. 13. 14, 15. 16. business at 144-15 Hillside Avenue, Jamaica, New York 11435. Upon information and belief, defendant LADER is a shareholder, member, director and/or officer of defendant SPENDAN SPORTS, LLC. Upon information and belief, defendant LADER has a financial interest in defendant SPENDAN SPORTS, LLC. FIRST CAUSE OF ACTION AGAINST SPENDAN SPORTS, LLC. FOR BREACH OF CONTRACT On May 14, 2007, the defendant, SPENDON SPORTS, LLC and Plaintiff entered into a sports memorabilia contract whereby plaintiff provided valuable consideration. To wit: license to use his name and likeness, exclusivity of memorabilia rights, autographed goods, signing opportunities for events and other promises detailed within the contract. Plaintiff provided license to use his name and likeness, exclusivity of memorabilia rights, autographed goods, signing opportunities for events and other promises detailed within the contract totaling $250,000.00 for which plaintiff has not been paid. Plaintiff demanded payment of $250,000.00 due to him under contract and defendant refused to pay. Wherefore plaintiff demands judgment against defendant, SPENDAN SPORTS, LLC., in the amount of $250,000.00. SECOND CAUSE OF ACTION AGAINST DEFENDANT SPENDAN SPORTS, LLC. ROR AN ACCOUNT STATED Plaintiff repeats the allegations contained in paragraphs 1 through 14 as if fully set forth here. On May 14, 2007, plaintiff furnished certain services to defendant SPENDAN SPORTS, LLC.; specifically, license to use