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HOLLAND & KNIGHT LLP James W. Michalski. Slate Bar No, 177015 Robert Barton. State Bar No. 269455 400 South Hope Street, 8th Floor Los Angeles, California 90071 Telephone; 213.896.2400
Facsimile: 213.896.2450


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Angules SUpetior Court

FILED

OCT 0·32011

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Email: Jawes.Michalsk:i@hldaw.oom Robert.Barton@hIdaw.com Attorneys for John Doe, Plaintiff

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

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FOR THE COUNTY OF LOS ANGEJjES

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JOHN DOE~an indivi~l,
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HAROLD MATZNER, an individual; MICHAEL LEVINE, an iridiv.idual; and DOES 1-50, inclusive, Defendants.

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) 1. Breach of Contract

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Plaintiff JOHN DOE, (the "Plaintifr' or I'JoM Doe"), for causes cf'acticn against Defendants, and each of them. complains and alleges as follows: 1. . John Doe is a natunU person and at all times relevant to this action. has resig,e~i'h
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Los Angeles County, California. 2.

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Haro~d Matzner ("Mr. Matzner!!) is a natural person and at all times relevant t~ this acti~~~ been. a resident of Riverside County, California..' II/
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COMPLAINT FOR DAMAGES

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John

Doe is informed and believes) and on such basis alleges, that Defendant

Michael Levine ("Mr. Levine") is a natural person and at all times relevant to this action, has been a resident of Los Angeles County, California. 4. John Doe is presently ignorant of the true names and capacities of Defendants

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sued herein as DOES I-50, inclusive. and therefore

Sues said Defendants

by such fictitious.

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names. John Doe will seek to amend this Complaint when the true names and capacities of said Defendants are ascertained. John Doe is informed and' believes, and on that basis alleges, that each fictitiously named.Defendant in some m~er caused, contributed to. participated in,

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committed or otherwise is responsible for the acts aDd omissions herein alleged, and thereby proximately caused injuries and damages to John Doe. 5.
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Doe is informed and believes,and on such basis alleges, that each of the

Defendants named herein was the principal, agent, conspirator, or WaB in some manner legally liable for the conduct and damages at issue in this action. John Doe is further informed and believes, and on that basis alleges, that each of the Defendants named herein was at all material times acting within the course and scope of one or more of such relationships and with the express 'or implied knowledge, direction, approval or ratifi().ation of each other. 6. Ronni Chasen ("Ms. Chasen") was a well-known Hollywood publicist. Ms.

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Chasen worked as a publicist on campaigns for more than 100 movies, including the 2008 Best
Picture Oscar winner, THE HURT LocKER (2008 VOLTAGE P]CTURES). as well as COCOON (1985
TWENTlETii Cl!NTlJR.Y FOX FILM

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CoRP.), BAav BOOM (1987UNlttO

ARtISTS). ON GOLDEN POND
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(1981 IPC FILMS), and the 1989 best picture winner DRIVING MISS DAISY (1989 MAJESTIC
INTERNATIONAL).

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7.

On November l(;, 20 I0, Ms. Chasen was working an after-psrty for the premiere

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of the film BURLESQUE (2010 SCREEN GEMS), promoting the work of a songwriter she represented. Following the after-party, Ms, Chasen drove throllgh Be-verly Hills, California, As she waited in her vehicle at the intersection of Sunset Boulevard and Whittier Drive, Ms. Chasen was shot five times by an unknown assailant. Police and paramedics responded and Ms, Chasen
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transported to a hospital where she was pronounced dead on arrival. 2. VERIFIED COMPLAINT FOR DAMAGES .

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To induce members of the public like John Doe to assist with the police

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investigation of the: shooting, Mr. MatzJiert a close friend of Ms. Chasen's, offered a reward of $100,000.00 to any individual who had information leading to the identification and arrest of Ms.
Ch~nls killer,

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Also to induce members of the public like John Doe to assist with the police

investigation, Mr. Levine, another close friend of Ms. Chasen, separately offered to start a
reward fund that was to contain
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of $25,000.00 within a week. The funds of this

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reward fund would be paid to any individual who had informetion leading to the identification . and arrest of Ms. Chasen's killer, 10.
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John Doe resided in the Harvey Apartment complex. Harold Martin Smith also .
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resided.in the Harvey Apartment complex,
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after the occurrence oftbe murder, Mr. Smith

made several statements to John Doe at the Harvey Apartment complex that led John Doe to believe that Mr. Smith bad committed a crime. Shortly thereafter) John Doe learned of Ms. Chasen's murder from news reports. After learning the details of the crime from the reports, John Doe believed that the statements Mr. Smith made to him the previous evening incriminated
Mr. Smith in Ms. Chasen's murder .. John Doe also learned from news reports tbat there were two separate reward offers totaling at least $125,000.00 that would be paid to any individual who had

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information leading to the identification and arrest of~s. ChaseJJ'skiller and who provided that
infonnation to authorities. .

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At great personal risk to his own life, and the lives ofhis family members, and

induced by the offered rewards totaling $125.000.00, John Doe provided a tip to the popular television show ~America's Most Wanted, in which he provided. the name of Harold Martin Smith as the possible killer of Ms. Chasen -. ]2.
The

Beverly Hills Police Department. as 6. direct result of the infonnation

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provided by John Doe) responded to the Harvey Apartment complex in the 5600 block of Santa Monica Boulevard, in the CitYof Los Angeles. Mr. Smith, returned to the location, and. once . inside, was contacted by Beverly Hills Police Department personnel. After the Beverly Hills Police Department personnel made contact with Mr. Smith, Mr. Smith drew his weapon and took
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VERIFIED COMPLAINT FOR DAMAGES

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his own life. Mr. Smith sustained a single self-inflicted gunshot wound to the head and died at

the scene.
13. Following Mr. Smith's death, the Beverly Hills Police Department conducted an

exhaustive investigation oiMs. Chasen's murder. Detectives reviewed in excess of 150,000 e-mails and texts belonging to the victim and investigated thousands of tips received on the Beverly Hills Police Department's hotline. A comprehensive review of thousands of financial . documents belonging
to

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Ms. Chasen

and persons ofjnterest

was also conducted .. In addition,

detectives recovered video and closed circuit television footage that established Ms. Caasen's route of travel between Hollywood and Beverly Hills on the night of her murder. Numerous interviews were also conducted with family, fiiends~ professional contacts" and other individuals who provided irifomtation 14.
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Beverly Hills Police Department detective personnel.

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The BeverlyHills Police Department personnel assigned to this case worked in

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excess of 10,000 hours in order to investigate thoroughly each and every tip, theory, and legitimate lead in order to bring the investigation 15.
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conclusion.

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The Beverly Hills Police Department stated: "without a doubt, it is the conclusion

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. of Robbery Homicide Detectives that the sole perpetrator of this most heinous crime

was Harold

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Martin Smith. AU facts and evidence conclusively indicate that Mr. Smith acted alone and was in possession of the murder weapon when confronted in Hollywood for questioning on the night of December 10, 2010. The Los Angeles County Sheriffs Department confirmed that the weapon used in the Chasen homicide and the weapon Mr. Smith used to take his own life. were
one in the same,"
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On March 15, 2011,

Mr. Mat2nertold

media sources that he was "prepared to pay

the reward as soon as the Bev~)y Hills Police Department tells us this is the correct thing to do. '1
A true and correct copy ofMr",Matznerts statement as it appeared in the entertainment website, http://www.thewrap.comis 17. attached hereto as Exhibit A.

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On July IS, 20 1I, the Beverly Hills Police Department concluded that the tip
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provided by John Doe to America's Mosl Wanted reSulted in solving and closing the Ronnie

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Chasen murder investigation. A true and correct copy of this letter :from the Beverly Hills Police Department to JOM Doe's counsel is attached as Exhibit B. 18.
On July 27,2011.
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John Doe's counsel sent Mr. Matmer and Mr. Levine letters

enclosing the Beverly Hills Police Department findings and requesting immediate payment of the offered rewards. True and correct copies of these letters are attached as Exhibit C.

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Mr. Levine contacted John Doe's counsel and stated that he had not started a

'reward fund and that he did not intend to pay the reward of$2S,OOO.OO. ' 20. Jolm Doe's counsel has not heard back from Mr. Matzner, despite mu1tiple

attempts to contact him by telephone and mail. 21. Mr. Matzner made an oral and/or written promise to offer the payment of a

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reward sum. of $100,000.00 in return for information leading to the identification and arrest of Ms. Chasen's killer. Mi. Matzner thereafter acknowledged the falsity of his promise and his fraud by an admission of having no true intent to perform on his promise of paying the $100,000.00 reward offered. Tbrough the promise of the reward sum, it was Mr. Ma~'s intent to induce John Doe toprovide infonnation on Ms. Cbasee's killer. In acceptance of Mr. ,Matzner's' offer and in reasonable, foreseeable, and justifiable reliance on Mr. Matzner's promise, John Doe provided information on Ms. Chasen's killer. Through Mr. Matznets refusal to pay the reward
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John Doe bas suffered damages in the minimwn amount ofSl00,OOO.OO and au

additional amount according to proof. 22. Mr. Levine made an oral andlor written promise to Oleate it reward fund and to

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pay a minimum reward sum of $25,000.00 from this fund in refurn for information regarding Ms. Chasen's killer. Mr. Levine had knowledge of the falsity of this promise and had no intent to perform on his promise. Mr. Levine thereafter acknowledged the falsity of his promise and his
fraud by

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an admission of having no true' intent to perform on his promise. Through the promise

to create a reward fund in order to make payment of a $25,000.00 reward sum, Mr. Levine

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intended to induce John Doe to provide information on Ms. Chasen's killer. In acceptance of Mr. Levine's offer and in reasonable, foreseeable, and justifiab1e reliance on Mr. Levine's promise) John Doe provided information on Ms. Chasen's killer, Through Mr. Levine's failure to start a
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reward fund and the refusal to ~y the reward sum, John Doe has suffered damages in the

minimum amount of $25,000.00 and an additional amount according to proof. FIRST CAUSE OF ACTION , Breaeh of Contra~t
(By Plaintiff Against Harold Matzner., Micbael Levine and Does 1 - SO)

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John Doe, incorporates the allegations in Paragraphs 1 through 22 above as though

fully set forth herein.

24.

Mr. Matzner made an oral andlorwritten contract offer through his promise in

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which he offered the payment of a reward sum of $100)000.00 in return for infonuation regarding Ms. Chasen's killer t which John Dee accepted by providing such information. 25. In acceptance and in consideration afMr. Matznets offer, John Doe performed on

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the contract by providing information as to the identity of Ms. Chasen's killer to America's Most Wanted and, subsequently, the Beverly Hills Police Department.
26. sum. 27. Mr. Levine made an oral and/or written contract offer through his promise to

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Mr. Matzner's has breached the contract though his non-payment

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create a reward fund and to pay a minimum reward swn of $25,000.00 from this fund in return for information regarding Ms. Chasen's killer, which John Doe accepted by providing such

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information. 28.
In acceptance of Mr. Levine's offer. John Doe provided information as to the the Beverly Hills

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identity of Ms. Chasen's killer to America's Mwt Wanted and, subsequently, Police Department. 29.
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Mr. Levine has breached the c:ontract though

hls failure to start a reward fund and

his refusal to pay the reward sum,

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30. :

As a result of Defendants' breach, John Doe has suffered damages in the

minimum amount of $125,000.00 and an additioI¥tl amount according to proof. SECOND CAUSE OF ACTION, Promissory Estoppel (Bf Plaintiff Ag8i~st'Harold MatzDer, Michael Levine and Does 1- SO)
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John DoeincorPomtes

the allegations in Paragraphs

1 through 30 above as though

6 VERIFIED COMPLAINT FOR DAMAGES

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fully set forth herein. 32.

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Mr. Matzner made a clear, Wlambiguous, o~ and/or written promise in which he

offered the payment of a reward sum of $100)000.00 in return for information regarding Ms. Chasen's killer. 33. 'In reasonable, foreseeable, andjustifiable reliance on Mr. Matzner's promise for
the payment

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of a reward

sum

of $1 00,000.00 in return for infonnation regarding M~. Chasen's

killer, John Doe provided information on Ms. Chasen's killer to America's Most Wanted and, subsequently, the Beverly Hills Police Department. 34.
Mr ..Levine made a clear, unambiguous, oral and/or written promise in which he

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offered to create a reward fund and to pay a minimum "reward sum of $25,000.00 from this fund in return for infonnation regarding Ms. Chasen's killer.
35. In reasonable, foreseeable, andjustifiable reliance on Mr. Levine's promise to

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create a reward fund and to pay a minimum reward sum of $25,000.00 from this fund in return for information regarding Ms. Chasen's killer, John Doe provided information on Ms. Chasen's killer to America's Most Wcmted and, subsequently) fhe Beverly Hills Police Department, 36; Defendants, and each of them, have not paid on the reward amounts promised and

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as a result of his reasonable reliance; John' Doe has been injured by Defendants in the minimum amount of $125,000.00 and

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an additional

amount according to proof

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THIRD CAUSE OF ACTION Fra.d (By PlaiDtift' Against Harold Mitzner, Millbael Levine aDd Does 1 - 50) John Doe incorporates the allegations in Paragraphs 1 through 36 above as though

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fully set forth herein.
38.

Mr. Matzner made a misrepresentation that he would pay a reward sum of

$100;000.00 iii remm for information regarding Ms. Chasen's killer. , , 39. 40.

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:Mr. Matzner

knew

this misrepresentation was false.

Mr. Matzner's misrepresentation was designed to induce John Doe to provide

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information as to the identitY of Ms. Chasen's killer. 41.
In reasonable, foreseeable, and justifiable reliance on Mr. Matzner's promise fur 7 VERIFIED COMPLAINT FOR DAMAGES

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the payment of a reward sum of$1 00.000.00 in return fOr information regarding Ms. Chasen Is killer, JOM Doe provided information on Ms. Chasen's killer to America's Most Wanted and, subsequently, the Beverly Hills Police Department. 42. Mr. Levine made a misrepresentation that he would create a reward fund and pay

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a minimum reward sum of$2S~OOO.OOfrom this fund in return for infonnation ~ganting Ms. Chasen's killer. 43. 44. Mr. Levine knew this misrepresentation was false.
Mr. Levine's misrepresentation was designed to induce John Doe to provide

infonnation as to the identity of Ms. Chasen's killer. 45. . In reasonable, foreseeable, and justifiable reliance on Mr. Levine's promise to

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create a reward fund and to pay a minimum reward sum of$2S,OOO.OO from this fund in return
for infonnation regarding Ms. Chasen's killer, John Doe provided information on Ms. Chasen's

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killer to America's Most Wanted and, subsequently, the Beverly Hills Police Department. 46.
As a direct, proximate, and foreseeable result of John Doe's reliance on each

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Defendants misrepresentation, and both of these misrepresentations,

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in the minimum amount of$125;000;00 and an additional amount according to proof. 47. , As a direct, proximate, and foreseeable result of John Doe's reliance
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each

Defendant's misrepresentation, and both of these misrepresentations, John Doe has suffered and
will continue to suffer physical injuries, pain and suffering, and extreme and severe mental anguish and emotional distress •. John Doe has incurred and/or

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will incur medical

expenses for

treatment by physicians. psychiatrists, and/or other health care professionals; and for other incidental medica] expenses. John Doe is therefore entitled to general and compensatory damages in an amount to be proven at trial. 48. The conduct and acts of Defendants, and 'each of them including DOES 1 through

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50, and/or their agents or employees, as described herein, were oppressive; :fraudulent, malicious,

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committed in bad faith

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disregard of John Doe's rights and given

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the deleterious consequences of Defendants' actions, John Doe is thereby entitled to an award of
punitive damages ..

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8 VERIFIED COMPLAINT FOR DAMAGES
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PBADft
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fOR RELIEF

WHEREFORE, the Plaintiff John Doe Prays for an order as follows: Against all Defendants, and each of them, for S125~OOO.OO; other general and and

compensatory damages according to proof; 2. Against all Defendants, and each of them, for reasonable attorneys' fees and costs

as allowed by law; 3. 4. appropriate. Against a11Defendants, and each of them, for punitive damages; and For such other and further orders and relief as the Court may deem just and

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..... Dated: October->, 2011

Respectfully submitted,

James W. Michalski
Robert Barton

HOLLAND & KNIGHT LLP

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FOR DAMAGES

EXHIBJT A

Ronni Chasen Tipster Will Get

1°,000

Reward

Page I of3

Published on The Wrap Movies (http://www.thewrap.com)
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RQrlnl Chasen Tipster Will Get ~1 OD.Ooo Rewaro

Ronni Chasen Tipster Will Get $100,000 Reward
By Anonymous Created 03115/2011 -1B.-52

.

Ronni Chasen Tipster Will Get $100,000 Reward
,

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Published: March 15, 2011 @ 7:53 pm
The man who turned in publicist Ronni Chasen's murderer to.the police will receive the $100,000 reward that the Palm Springs Film Festival offered to catch her killer, TheWrap has learned. '

"We are prepared to pay the reward as soon as the Beverly Hills Police Department tells chairman of the Palm Springs Film Festival. "The magic word is: the case is solved. My belief is we will give him the reward."
us this is the correct thing to do," said Harold Matzner! Read more: k,goks Like Ronnl Chasents Friends Were

Right: Killing Was Random

(1)

Chasen, who was shot dead on her
way home from a premiere on November 16 of last year, was

a longtime publicist to the festival.

Her killing deepy shook the entertainment industry. And the payment to the tipster has been held up by ongoing concern

was responsible for

her shooting death.

within the Hollywood publicity community that someone other than, or in addition to, Harold Martin Smith

Smith shot himself desdion Dec. 1.as police approached him for questioning at the' Harvey Apartment buildings on $antCi Monica Boulevard. . The tipster, who lived in~he same down-at-me-heels hotel as the ex-felon Smith, remains anonymous- He called i~his tip to "America's Most Wanted," and police followed up from there. .., .~

http://www. thewrap.conJmoviesl~rint!2553

7

9/2<)/2011

Ronni Chasen Tipster WHl Get

1°,000 Reward

Page 2 of3

BallIstics tests found that t.tJe"gurrSmith used to kill himself was the same used to kill Chasen, a beloved, veteran publicist. The pollee detectives support paying the tipster for his information. Nonetheless, there is vehement resistance to closing the case among chasen's friends. Matzner met with BHPD on Tuesday and told them about the widespread skepticism in the Hollywood community. " "We discussed the fact that even though with definitive proof and some video from security cameras, that all these peeple have strong beliefs that this guy was hired to do it," Matzner told TheWrap afterward. Through most of the invetigation, police have said they believed Smith killed Chasen in a random act of violence -- most likely a desperate "robbery gone bad." Ballistics testing indicated a match between the gun that he used to shoot himself and the murder weapon. They told Matzner on Tuesday that they had unearthed no evidence to suggest that anyone else was involved in the killing. "They have video that shows him in this general area at this approximate time," Matzner noted. "They've got him in the area with film, That's good enough for me." That video footage has not been released to the public. Smith had a long history of criminal behavior, including burglary and drug possession in California and New York State. But those who heard Smith talking about a hit at the time also heard him refer to $10,000 reward money. And that detail has never been explained. Meanwhile, Matzner will be paying the reward out of his own pocket, because the festival is constrained by lts non-profit status. And he said that Chasen would be happy to know that the man who took the risk to tell the police what he knei about Smith would be rewarded. . "We wanted some

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I know she's be at least happy with that part," Matzner said. dam
{Z]

Related Articles: " " Looks Like onni C asen's Friends Were Ri ht: illin Was R e ort: BHPD Chie Declares Ronni Chasen Murder Solved [3] Exclude Thumbnaill from River: Don't Exclude Published Date:
I

28 weeks 1 day ago' "

Share
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http://www.thewrap.comimovieslprinV2553

7

9129/2011

Ronni Chasen Tipster Will Get IO~OOOLReward .
._ T:lgs: B0V9r!y HHls' Police Depal1lnent (4), publicist (1 OJ, Rpn III Ch as!}!"! [11). tlpsttlr [12]

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Harold Martin Smith

Harold

Source URL: http;/lwww.thewrap.comimovieslcolumn-posVronni"chasen-tiQster-will:aet-1QQQQQ.reward~ Li"kS~ [1 J http://wvJw.thewrap.com/movies1articielronni-chasen~had.no.enetnies-iu5t-fata l-bad~luck-23124 [2) http://www.thewrap.com/movieslarticle/ronni-chasen-had-Ilo-enemies-%E2%8Q%93~just-fatal-bad-h.Jck~ 23124 [3] http://www.thewrap.comlmovles/column~postlreportYpolice-declare-case.solved-ronni-chasen-murder24038

[4J http://www.thewrap.com/movl&slarticlesibeverly%20hllls%20poHce%20department (5J http://www.thewrap.comlmovies/articleslharnld%20martin%20smith [6] http://www.thewrap.comlmovlesfarticles/harold%20matzner (7) hltpJlwww.thewrap.com/moviesiarticles/movies [8) htlp:II\VWW.thewrap.com/movieslarticleslmurder [9) http://www.thewrap.comlmoviesJartlcles/pollee {101 http://www.thewrap.com/moviesiarticles/pubJicist
[11] http://www·.thewrap.comimovieslartjcles/ronni%20chasen [12] http://www.thewrap.comJmovieslarticles/tipster.

http;!/www"thewrap.com/movies!printJ25537

9129/2011

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EXHIBIT B

e.
POUCE DEPARTMENT

464 N. Rexford Drive
Beverly ).lil~. CA 90210-4817

MIJID L. SNOWDEN

Chief of PtJli(:e 310.2S6.2100
FAX~ 310.246.9864

July 22. ~Ol1

Robert Barton / Holland & Knight Attorney, Private Wealth Services
400 South Hope Street, 8th Floor
Los Angeles, Ca. 90071 Re: Chasen Homiddelnvesti90tion

(10~6804)

Mr. Barton, I om writing you on behalf of the Beverly Hills Police Department and the Cohen
fo.mily in regards to the untimely death of Ms. Ronni Cnasen. On Novembe.r 16, 2010, Ms. Chasen VJOS the. victim of homicide which occurred in the city of Beverly Hills. Whilf driving home from a movie premier in Hollywood,

Ms. Chasen ·was shot to death at the. intersection of Sunset Slvd and Whittier
Drive.
. I ! ,

REDACTED :::l suspect was identified. Mr. Harold Martin Smith was identified 10 be the suspect
Once Mr .: Smith was confronted by Beverly Hills Detectives, he chose to take his own life. Through interviews, scientific evidence and ballisticS it was determined that Mr. Smith WaS the. outstanding suspect in the Chasen homicide. and that he qcted alone. .
in the Chasen homicide.
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A lengthy investigation ensued and with the sole assistance of'

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Chasen Homicide
July 22, 2011

{lO-6B04)

Page 2 of 2

On July 15, 2011 the C~asen homlcide investigation was officially closed. It is not

this

the policy of the. Beverly Hi"~ Polic~ Department to rele.as~ copies of homicide investigations, Allow this letter to serve as official, notifkation of the closure of
COSt;.

4:30 pm.

Should ygU have any questions or concerns, please'feel free to contact me. directly at (310) 285~2167, Tuesday through friday, between the hours of 6:30 am until
, '

Thank you for yQur time and consideration. Respectfully.

•I

,_g~.(~
Sergeant Michael Publii:ker . Beverly, Hills Police Deportment Detective Buretlu Supervisor

7122111 3:36: PM

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EXHIBIT C

Holland-& Knight
400 SOlJlh HOpe Str'9i!t, ath ROOf' I los Angeles, CA90071 Holland eo Knight LlP 1 www,hWaw,CQIn

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213,696.2400

I F 21:3-800,2450

Robert Berton (213) 696-2503 robe/t,balton@hkleW.c:om

July 27, 2011 Vta Certified Moil, Return Receipt Requested Mr. Harold Matzner
Palm Springs International Film Festival 1700 East Tahquitz Canyon Way # 3 Palm Springs, CA 92262 Re: Reward Money Due Our Client for Solving the Ronnie Chasen Murder

Dear Mr. Matzner,
Our law finn represents the interests of the individual who provided the tip, through "America's Most Wanted,. that led the Beverly Hills Police Department to the person who murdered Ronnie
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Chasen. As you may have heard, on July 15; 2011, the Police Department officially dosed its lengthy investigation of this tragic murder. Enolosed is the Police Department's letter advising that the investigation has been completed .: Our client wishes to remain out of the public light, although we ere happy to disclose his nameto you m a telephone conversation,

According to the Beverly Hills Police Department, defectives reviewed more than 1SO,ooO emails and texts, reviewed thousands of financial documents, interviewed family members,
professional contacts, friends and others and worked more than 10,000 hours on this case. The final conclusion of Department that Harold Smith "was the outstanding suspect in the Chasen bomicide and that he acted alone." The Police Department was alerted to Harold Smith with the "sole assistance" from our client.

is

his whereabouts, his call to "America's Most Wanted," as police have confirmed, led to the

Although our client provided the tip at great personal risk about Harold Smith's involvement and

solving of Ms. Chasen's murder. We understand that you have been awaiting the official closure of the case by the Beverly Hills Police Department in order to pay the $100,000 reward you generously offered for information leading to the conclusion of this case, At our client's request, we have established a Trust that will assist him in paying basic living expenditures. He has asked us to contact you in order to arrange payment into that irust. You may send the payment at your earliest convenience to my attention at: . Holland & Knight LLP Client Trust Account 400 South Hope Street, 8th Floor Los Angeles, CA 90071.
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Mr. "Harold MatznE.1.~ July 27, 2011 Page 2

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I am of course happy to speak with you further about this. If you have any questions, please call me at (213) 896~2503. Otherwise, we will look forward to your prompt payment.
Please accept my sincere condolences and that of OUT law finn on the loss of Ms. Chasen. I understand you were a close friend of hers. and that she did a tremendous amount of work for the Palm Springs International Film Festival.

Best regards,
HOLLAND & KNIGHT LLP

Robert Barton

cc:

M. Katharine Davidson
Charles Tobin

#]0479013_V2

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DAVID

POLICE DEPAR'tMENT
464 N. Rexford Dri\le

L. SNOWDEN
ChIef of Pali(:e

Beverly Hilts, CA 90210-4817

310.285,2100 FAX; 310,246,9854

July 2·2, 2011

Robert Barton I Holland & Knight

Attorney, Private Wealth S£rvi,es
400 South Hope street, 8th Floor

Los Angeles, CCil. 90071 Re: Chasen Homicide Investigation (10-6804)

Mr. Barton,

r am wI',iting you on be'half

of the Beveriy Hills Police Department

and the Cohen

fO!T'ily in regar~s to the untimely de<rth of Ms. ROl'lfli Chosen.
On November 16, 2010, Ms_ Chasen r'as the victim of homicide which occurred in the city of Beverly Hills, While driving. home from Q movie premi,er in. Hollywood. Ms_ Chasen .waS shot ~o death at the intersection of Sunset Blvd and Whittier Drive.
I

I

A lengthy in\lesti9atio~;. ensued and with the sole assistance of REDACTED a suspect was identified. I Mr. Harold Martin Smith was identified to be the suspect in the Chasen homicide.. Once Mr.' Smith Was confronted by Beverly Hills Detectives, he 'chose to take his own life. ThrQugh interviews, scientific evidence and ballistics, it was dete.rmine.d that Mr. Smith was the outstanding suspect in the Chasenhomicide and that he acted alone.

I' .1, .1.

Chasen Homicide
July 22, 2011

(10-6804)

Page 2 of 2

this eese,

On July 15, 2011 the Chasen homicide investigation was officially dosed. It is not the policy of the Beverly Hills Police Department to release copies of homicide investigations. Allow rhts letter to serve as official, notification of the closure of

Should you hove any questions or concerns, please' feel free to contact me directly at (310) 285-2167, Tuesday through Friday, between the hours of 6:30 om until 4:30 pl'n_
Thank you for your time and cpnSideration.

Respectfully,

_g;1.~
Sergeant Michael Publicker Detective Bureau Supervisor ,

Beverly Hills Police DeparTment

7i22f11 3:36 PM

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Holland & Knight
400 South MOPe Streat, 8th Floor
Hollend & Knight UP

I 'fflffl.hl<laW.oom

I Lo:s MgeleS,

CA 00071 J T 213.896.2400

I F l13.S96.2450

Robert Bartoo

(213) a9M503
mbllrt.bart<lI1@hklllW.com

July 27.2011 Via Certified "1ai/. Return Receip; Requested

Levine Communications Office
1180 S. Beverly Dr. #301 Los Angeles, CA 90035 Re: Reward Money Due Our Client for Solving the Ronnie Chasen Murder

Mr. Michael Levine

Dear Mr. Levine.

America's Most Wanted," that led the Beverly Hills Police Department to the person who murdered Ronnie Chasen. As you may have heard, on July 15~2011 ~the Police Department officially closed its
Out law fmn. represents the interests of the individual who provided the tip, through
tI

lengthy investigation this tragic murder. Enclosed is the Police Department's letter advising that the investigatibn has been completed. 01,]1" client wishes to remain out of the public light, although we are hapP:r tt) disclose his name to you in II telephone conversation. According to the Beverly Hills Police Department, detectives reviewed more than 150,000 emails and texts. reviewed thousands of fina:ncial documents, interviewed family members,

of

professional contacts, friends and others and worked more than 10,000 hours on this case. The [mal conclusion Department is that Harold Smith "was the outstanding suspect in the Chasen homicide and thAt he acted alone. II The Police Department was alerted to Harold Smith with the "sole assistance" from our client.' .

of
, I

"

Although our olient prpvided the tip at great personal risk about Harold Smith's involvement and his whereabouts, his call to "America IS Most Wanted," as police have confirmed, led to the
solving of Ms. ~hasenjsmurder. We understand that you have been awaiting the official closure of the case by the Beverly Hills Police Department in order to pay the $25.000 reward you generously offered for 'irifonnation leading to the conclusion of this case. At our client's request. we have establi:sheda ]"mst that will assist him in paying basic living expenditures. He has asked us to contact you.in order to arrange payment into that trust. You may send. the payment at

your earliest convenience to my attention at:
.
I

.

.

,

:
.

Honan~ & Knight LLP Cli~t.Trusl ~ccount 400 South Hope S~eet) 8th r100r : Los An$eles. CA 90071. . •. :.
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Mr. Michael Levine
July 27,2011
Page 2

I am of course happy to speak with youfunher il},out this. If you-have tilly questions, please call me at (2\3) 896-2503. Otherwise, we will look forward to your prompt payment. Please accept my sincere condolences and that of our Jaw finn on the Joss of Ms. Chasen.

Best regards;
HOLLAND & KNIGHT LLP

Robert Barton

cc:

M. Katharine

Charles Tobin

Davidson

.e
.
POLICE DEPARIMENT 464 N. Rexford D~jve
\

Beve:r!y

Hills. CA 90210-4817

DA vrc L_ :SNOWDEN Chid 0( PoHe~ 310.265.2100 . FAX: 310.246.9854

July 22, 2011

Robert Barton I HoUand & Knight Attorney, Private Weafth Services ' 400 south Hope Street, 8th Ftoor Los Angeles, Co. 90071 . RB,:Chosen Homicide Investigation (10..-6804)
I

Mr. Barton, writing you on behalf cf the Beverly Hills Police Department end the Cohen family in regards to the untimely death of Ms. Ronni Chas~.
011 November 16, 2010, Ms. ChQsen
'!t'QS

r am

the. victim of homicide which occurred in

"the city of Beverly Hills. While. dr.iving horne from Q movie. premier In Hollywood, . Ms. Chasen was shot to death c+ the inter-section of Sunset Blvd and Whittier
Drive.

A lengthy investigcltion ensued and with the sole cssistcnce of . REDACTED a suspect was identified. Mr. Harold Martin Smith was identified TO be the suspect
in :the Chasen homicide.. Once Mr. Smith was confronted by Beverly Hills Detectives. he chose to teke his own life. Through interviews, scientific evidence and ballistics, it was determined that Mr. Smi.th was the outstanding suspect in the Chasen homicide and that he acted feme.

l

1

Chasen Homicice July 22, 2011

(10-5804)

Page 2 of 2

On Juty 15, 2011 the Cbasen homicide investigation was officially closed. It is not the policy of the Beverly Hills Police Department to release copies of homicide investigQtions. Allowthis tetter to serve as official notification of the closure of this ccse. Should you have any questions or concerns, please feel free to contact me directly at (310) 285-2167. TueSday through Friday, ~etween the hours of 6:30 atn ul'ltil
4i30 pm.

Thank you for your time. and conside.ration.

__g~. (~
Sergeant Michael Publicker Bevtrfy Hills Police Department
Detective Bureau SupervisQr

Respectfully,

7/221t 1 3:36 I'M

MICRDPCUSA

PAGE

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It John Doe, declare as follows: 1 am. the Plaintiff in the above-fmtitled action,

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r have read

tho foregoing COMPLAINT

and know the contents thereof. The same is true of my own knowlc:dg=, eXl;;ept as to those matters which are therein alleged on information and belief; and as to those matters, I believe them to be

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true.

I declare under penalty of perjury under the Jaws ofth.e State or California that the foregoing is true and correct. Execmted at Los Angeles, California on this __ September 2011. day of

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COMPLAINT·

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