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Alan Harris (SBN 146079) Priya Mohan (SBN 228984) HARRIS & RUBLE 6424 Santa Monica Boulevard Los Angeles, California 90038 Telephone: 323.962.3777 Facsimile: 323.962.3004 aharris @harrisandruble.com pmohan@harrisandruble.com Attorneys for Plaintiff Michael Anthony Sullivan

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SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES Case No.

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COMPLAINT
MICHAEL ANTHONY SULLIVAN, Plaintiff, 1. Failure to Pay Overtime Compensation, California Labor Code §§ 510 and I 194 Failure to Provide Accurate Itemized Wage Statements, California Labor Code § 226 Failure to Maintain Accurate Payroll Records, California Labor Code § 1174 Failure to Pay Overtime Compensation, Fair Labor Standards Act, 29 U.S.c. § 201 et sC6'ntinuing Wages, California Labor Code § 2D3 Improper Deductions from Wages, California Labor Code § 221 Failure to Reimburse Business Expenses, California Labor Code § 1802 "1:1 '==' :0:0 r, Defamation ~ 55 ~ R ::: [ntentional Interfer~~£e witUj ~ ;,~5:1 ~ Prospective EcqnoWl£ ~dyahta8..e,.., ~ Negligent Interference t; , ., :,s ProspectIve EconomIC Advantagec'} :::; Res.tlq.ltion.and Injuncti ve 15 ~ 3i ~ Relief, California 13usmes,s and~~ ~2;: Professions Code §§ 172QOet seq~ ~
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TOMMY LEE, MAYHEM TOURING, INC., a California corporation, and DOES 1 to 20, Defendants.

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1 COMPLAINT

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Plaintiff Michael Anthony Sullivan, by and through his undersigned attorney, alleges as follows:

PARTIES AND JURISDICTION
I. Plaintiff MICHAEL ANTHONY SULLIVAN ("Plaintiff' or "Sullivan") is

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an individual who, during the time periods relevant to this Complaint, was employed by Defendant TOMMY LEE ("Lee") and Defendant MA YHEM TOURING, INC. ("Mayhem Touring"). 2. Sullivan resides in the County of Los Angeles, State of California. Lee arid Mayhem Touring, Inc. served as At all

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relevant times herein, Defendants employers of Sullivan.

Lee and Mayhem Touring may hereinafter be collectively

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referred to as "Defendants." 3. Lee was and is a drummer and founding member of the glam metal band,

Motley Crile. Since its inception in 1981, Motley Cnie has sold more than 80 million album copies worldwide. In addition to recording and performing with Motley Crue, Lee is a founding member of the rap-metal band Methods of Mayhem, and an electronic music OJ. Lee resides in the County of Los Angeles. 4. Sullivan was a non-exempt Assistant to Lee from approximately January,

2005 through March 31, 2011, at which time Sullivan's employment was terminated. 5. Mayhem Touring is a California Corporation with its principal place of

business in Encino, California. Tommy Lee is the President and owner of Mayhem Touring. Mayhem Touring issued Sullivan his paychecks, W-2s and was responsible for tendering payment to Sullivan for the Assistant services rendered by Sullivan to Lee. From time to time Lee and his professional advisors, including attorneys and accountants, caused Sullivan to be paid by cash, thereby defrauding the fisc and clouding whether payments were being made by Lee or Mayhem Touring. 6. The true names and/or capacities, whether individual, corporate, associate,

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or otherwise, of Defendants Does 1 to 20, inclusive, are unknown to Sullivan at this time,

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COMPLAINT

and Sullivan therefore sues said Defendants by such fictitious names. When the true 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 names and capacities of said Defendants have been ascertained, Sullivan will amend this Complaint accordingly. Sullivan is informed and believes and thereupon alleges that

each Defendant designated herein as a Doe is responsible, negligently, intentionally, contractually, or in some other actionable manner, for the events and happenings hereinafter referred to, and caused injuries and damages proximately thereby to Sullivan as is hereinafter alleged, either through said Defendants' own wrongful conduct or through the conduct of their agents, servants, employees, representatives, officers, or attorneys, or in some other manner. 7. Sullivan is informed and believes and thereon alleges that, at all times herein

mentioned, Defendants, and each of them, were the agents, servants, employees, and/or joint ventures of their co-Defendants and were, as such, acting within the scope, course, and authority of said agency, employment, corporate capacity, and/or joint venture, and that each and every Defendant as aforesaid, when acting as a principal, was negligent and reckless in the selection and hiring of each and every other Defendants as an agent, servant, employee, corporate officer, and/or joint venture, and that each and every Defendant ratified the acts of his co-Defendants.

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VENUE
Venue is the proper in this court because Defendants operate in its jurisdictional area. Furthermore, all or a portion of Defendants' liability arose in this County, and the acts upon which this action is based occurred, in large part, in Los Angeles County, including the Staples Center and the Standard Hotel located in downtown Los Angeles, the Guitar Center in Hollywood, and the Greek Theater.

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GENERAL ALLEGATIONS
9. During all times relevant to this Complaint, Sullivan provided various services to Lee and his family, acting as a procurer, Man Friday, chauffer, guide, bookkeeper, attendant, door-keeper, agent, butler, valet, attendant, cook, runner, shopper, nanny, bodyguard, maid, nurse and nursemaid (hereinafter, Sullivan is occasionally
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described as the "Assistant").

Sullivan's duties are governed by the provisions of IWC

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Wage Order 4.

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In his capacity as Lee's non-exempt Assistant, Sullivan engaged in a wide

variety of work-related tasks. Generally speaking, Sullivan's job responsibilities depended on what Lee was doing at any particular time. Plaintiffs time was spent assisting Lee in the following broad work-related categories: (1) work in the Lee home and office/studio, and (2) work while Lee was "on the road" touring throughout the world. Sullivan worked

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for Lee as his Assistant beginning in January, 2005 until his termination in March, 2011. 11. In general, whether Sullivan was assisting Lee at his home/office/studio, or

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on the road while touring, Sullivan was required to be on call twenty-four hours a day, seven days a week. To the extent Lee needed anything, whether it be personal or workrelated, Sullivan was required to carry a telephone and respond to Lee's needs and requests immediately upon Lee making a demand of Sullivan. Furthermore, there were long stretches of time during which Sullivan was required to work seven days a week, without a single day off. Under California Labor Code section 551, "Every person employed in any occupation of labor is entitled to one day's rest therefrom in seven." Cal. Lab. Code § 551. Similarly, California Labor Code section 552 provides: "No employer of labor shall cause his employees to work more than six days in seven." Cal. Lab. Code § 552. 12. Lee found Sullivan so useful that he required him to stay at his residence so

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that he was always available for service. However after requiring Sullivan to stay at the home and obtaining the benefits of Sullivan's presence in his home, in 2009, Lee began deducting $1,000 from his wages every month for "rent." Lee continued to deduct the $1,000 "rent" payments from Sullivan's wages during the six months prior to Sullivan's termination even though Sullivan no longer lived in Lee's home. 13. While working at Lee's home, Sullivan's job duties ranged from assisting Lee

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with his personal and business needs and requests to assisting Lee's family members with tasks around the home and/or running errands for the family and business associates . These tasks and errands included, but were not limited to: chauffeuring Lee, his extended
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family, and others; picking up various items at the store for Lee's personal and studio use and for use by other family members and guests; babysitting for Lee's two children and tending to the needs of Lee's elderly, infirm mother; preparing food for Lee, family members and guests; and stocking Lee's home and music studio with groceries and other supplies. In general, while acting as Lee's Assistant at home, Sullivan estimates that he regularly worked more than eight hours per day. Furthermore, although Sullivan was frequently required to make purchases for Lee and his family members with his own funds, on many occasions, Lee failed to reimburse Sullivan for these work related expenses. Instead, Lee regularly and improperly deducted wages from Sullivan's paychecks for work related expenses. For example, in addition to improperly deducting rent payments from Sullivan's paychecks after he no longer lived in Lee's residence, Lee regularly and improperly deducted wages for cell phone charges that were associated with work related phone calls Sullivan had made on Lee's behalf. Lee also improperly deducted wages from

Sullivan's paycheck to cover the insurance deductible for an accident that Sullivan had been involved in while taking Lee's car to a mechanic to repair its faulty brakes. 14. As set forth herein, Lee's fan base is spread across the globe, and as a result,

Lee spent significant portions of the time period relevant to this Complaint, touring and performing live across the world with Motley Crile, Methods of Mayhem and for Lee's DJ performances. Whenever Lee was "on the road" performing live shows and touring,

Sullivan was generally required to accompany Lee, travelling with him from city to city, and assisting him with his every need. While touring with Lee, Sullivan would regularly work sixteen or more hours in a given day. For example, a typical day would start at 9:00 or 10:00 a.m. and not end until well after midnight, without all required break periods. During this time Plaintiff was required to accompany and assist Lee with, among other things, packing his personal items and music equipment, transportation, retrieval and unpacking of Lee's personal items and equipment once they arrived at their destination. In addition, a major part of Sullivan's work while on Lee was on the road touring or during events was acting as his personal bodyguard. Indeed, after Sullivan began
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COMPLAINT

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performing bodyguard duties for Lee, Lee no longer employed a separate bodyguard.

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Quite literally, when Sullivan accompanied Lee on the road, the job was entirely consuming of Sullivan's time, and notwithstanding time spent sleeping, Sullivan was usually working. Sullivan conservatively estimates that he worked anywhere between 80 to 100 or more hours per week while Lee was on the road touring. 15. Lee and Mayhem Touring paid Sullivan a weekly salary without taking into

consideration the fact that Sullivan worked far in excess of eight hours per day, and far in excess of forty hours per week. As set forth herein, Sullivan regularly worked hours well in excess of 12 hours in a given day, yet Lee and Mayhem Touring failed to compensate Sullivan at the overtime rates of time and one-half and/or double-time for all hours worked in excess of eight in a day and/or forty in a week.

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16.

Indeed, rather than properly compensating Sullivan in accordance with the

applicable labor laws, Defendant Lee docked Sullivan's wages for various reasons. For instance, Defendant Lee often docked Sullivan's wages when he chose to work remotely from a location other than Lee's home, when Lee was out of town. If Sullivan happened to be late to work, Lee would dock Plaintiff s wages. Indeed, if Lee was upset with Sullivan for any reason, he would often find a reason to dock his pay. Lee's practice of docking Plaintiff s wages confirms that the parties understood that Plaintiff was a nonexempt employee. 17. In addition to failing to compensate Sullivan for all hours worked at

overtime wage rates, Lee also failed to provide Sullivan with a paid ten minute rest period for every four hours worked. Furthermore, there existed no policy allowing Sullivan to take a 30-minute unpaid meal period for every five hours worked. In fact, often when Lee's schedule was particularly busy, Sullivan was forced to eat on the run if he was able to eat at all. 18. Sullivan's employment with Defendants ended on or about March 31,201 L

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After the termination of his employment, Sullivan has learned that Defendant Lee has been and is currently engaged in a campaign of disparagement against him and that Lee
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COMPLAINT

has defamed Sullivan to various individuals in the music industry in which they both 2 3 4 work. Lee's disparagement of Sullivan began shortly after the termination of Sullivan's employment, when Lee was on tour in South America with Motley Criie and continues to date. These documented remarks include, but are not limited to stating that Plaintiff is untrustworthy and performed illegal and improper acts while employed by Tommy Lee. These disparaging and defamatory remarks are false and were made solely with the purpose to disparage and in order to interfere with Plaintiff's ability to earn a living in the music industry. Lee's statements have damaged Sullivan's reputation and have interfered with Sullivan's existing and potential employment opportunities and business associations. Indeed, due to Lee's irresponsible and defamatory comments, Plaintiff lost

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at least two jobs, both tour manager positions with prominent rock bands. The first position, with the band Godsmack, would have lasted a minimum of five weeks and Sullivan would have earned an income of $3,000 per week. The second position was to be the tour manager for the band Bush. Sullivan was hired on September 30, 2011 to be Bush's tour manager and was slated to start work on October 9, 2011. Immediately upon learning that he had the job with Bush, Plaintiff began preparing for the position by contacting travel agents and working with Bush's team to get up to speed before the tour began. However, on October 7,2011 Sullivan was told by Bush's manager that the

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position was no longer his. Plaintiff later discovered that he lost the job due to Lee's defamatory statements and interference. The tour manager position with Bush was

confirmed to last for a period of at least eleven weeks and three days and Sullivan would have earned an income of $3,000 per week for the duration of the position. 19. This Complaint asserts claims against Defendants Lee and Mayhem

Touring for various violations of California Labor Code. The Complaint alleges that Defendant Lee violated sections 201, 203, 204, 221, 226, 512, 551,552, 1174, 1194 and

2802 of the California Labor Code, that Defendants Lee and Mayhem Touring violated sections 226, 510, 1174, 1194 and 1198 of the California Labor Code, Wage Order 4 of the Industrial Welfare Commission ("IWC"), section 17200 et seq. of the California
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Business and Professions Code, and the federal FLSA. The Complaint also asserts 2 3 4 5 claims against Lee for Defamation, Negligent Interference with Prospective Economic Advantage and Intentional Interference with Prospective Economic Advantage. As of

April 14, 2011, Defendants, through their counsel, have agreed to toll the statute of limitations for Plaintiff s claims through the date of the filing of this Complaint. A copy of the tolling agreement is attached hereto as Exhibit 1. 20. At all times relevant hereto, sections 510, 1194, and 1198 of the California

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Labor Code and Wage Order 4 (3) (A) required (1) the payment of at least the minimum wage, (2) the payment of wages equal to one-and-one-half times an employee's regular

rate of pay for all hours worked in excess of eight per day or forty per week, and (3) the payment of wages equal to double the employee's regular rate of pay for all hours

worked in excess of twelve per day and for all hours worked in excess of eight on the seventh day of work in anyone workweek. 21.
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See Cal. Lab. Code § 51O(a).

Similarly, at all times relevant hereto, the FLSA requires the payment of at

least the minimum wage (see 29 U.S.c. § 206) and overtime as follows: [N]o employer shall employ any of his employees who in any workweek is engaged in commerce or in the production of goods for commerce, or is employed in an enterprise engaged in commerce or in the production of goods for commerce, for a workweek longer than forty hours unless such employee receives compensation for his employment in excess of the hours above specified at a rate not less than one and one-half times the regular rate at which he is employed. 29 U.S.C. § 207(a)(l). 22. At all time relevant hereto, sections 226, 1174, and 1174.5 of the California

Labor Code required employers to keep records of and provide employees with itemized wage statements showing the total hours worked.
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Exhibit 2 sets forth Industrial Welfare Commission Wage Order 4. Section 7(B) of Wage Order 4 provides: "7. (8) Every employer shall semimonthly or at the time of each payment of wages furnish each employee, either as a detachable part of
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COMPLAINT

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At all times relevant hereto, paragraph 7(A) of IWC Wage Order 4, requires

the following: Every employer shall keep accurate information with respect to each employee including the following: ... (3) Time records showing when the employee begins and ends each work period. Meal periods, split shift intervals and total daily hours worked shall also be recorded .... [and] (5) Total hours worked in the payroll period and applicable rates of pay. This information shall be made readily available to the employee upon reasonable request. Defendant Lee violated paragraph 7(A) of the applicable wage order by, among other things, failing to keep all of the records set forth therein, including the specific times when Sullivan began and ended each work period, as well as the time when meal periods were taken, if they were able to be taken at all. 24. At all relevant times mentioned herein, section 203 of the California Labor

Code provided: If an employer willfully fails to pay, without abatement or reduction, in accordance with Sections 201, 201.5, 202 and 202.5, any wages of an employee who is discharged or who quits, the wages of the employee shall continue as a penalty from the due date thereof at the same rate until paid or until action therefor is commenced; but the wages shall not continue for more than 30 days. Cal. Lab. Code § 203. 25. Sullivan contends that the failure of Defendant Lee to pay Plaintiff within

the time provided by section 20 I of the California Labor Code has been and is "willful" thecheck, draft, or voucher paying the employee's wages, or separately, an itemized statement in writing showing: (1) all deductions; (2) the inclusive dates of the period for which the employee is paid; (3) the name of the employee or the employee's social security number; and (4) the name of the employer, provided all deductions made on written orders of the employee may be aggregated and shown as one item. 8 Cal. Code Regs. § 11040, § 7. Defendant did not mamtain such records with respect to Sullivan's work.
9 COMPLAINT

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within the meaning of section 203 of the California Labor Code and that, accordingly, 2 3 4 5 6 7 8 9 lOCal. II 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Sullivan is entitled to the "continuing wages" provided for by section 203. 26. At all relevant times mentioned herein, section 1198 of the California Labor

Code provided: The maximum hours of work and the standard conditions of labor fixed by the [Industrial Welfare Commission] shall be the maximum hours of work and the standard conditions of labor for employees. The employment of any

employee for longer hours than those fixed by [an] order or under conditions of labor prohibited by [an] order is unlawful. Lab. Code § 1198. 27. Sullivan also contends that Defendants' failure to comply with section 226

of the California Labor Code subjects Defendants to civil penalties pursuant to section 226.3 of the California Labor Code. At all relevant times mentioned herein, section 226 of the California Labor Code provided: (a) Every employer shall, semimonthly or at the time of each payment of wages, furnish each of his or her employees, either as a detachable part of the check, draft, or voucher paying the employee's wages, or separately when wages are paid by personal check or cash, an itemized statement in writing showing (I) gross wages earned, (2) total hours worked by the employee, except for any employee whose compensation is solely based on a salary and who is exempt from payment of overtime under subdivision (a) of Section 515 or any applicable order of the Industrial Welfare Commission, (3) the number of piece-rate units earned and any applicable piece rate if the employee is paid on a piece-rate basis, (4) all deductions, provided, that all deductions made on written orders of the employee may be aggregated and shown as one item, (5) net wages earned, (6) the inclusive dates of the period for which the employee is paid, (7) the name of the employee and his or her social security number, except that by January 1,
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2008, only the last four digits of his or her social security number or an employee identification number other than a social security number may be shown on the itemized statement, (8) the name and address of the legal entity that is the employer, and (9) all applicable hourly rates in effect during the pay period and the corresponding number of hours worked at each hourly rate by the employee. The deductions made from payments of wages shall be recorded in ink or other indelible form, properly dated, showing the month, day, and year, and a copy of the statement or a record of the deductions shall be kept on file by the employer for at least three years at the place of employment or at a central location within the State of California.

(e) An employee suffering injury as a result of a knowing and intentional failure by an employer to comply with subdivision (a) is entitled to recover the greater of all actual damages or fifty dollars ($50) for the initial pay period in which a violation occurs and one hundred dollars ($100) per employee for each violation in a subsequent pay period, not exceeding an aggregate penalty of four thousand dollars ($4,000), and is entitled to an award of costs and reasonable attorney's fees.

(g) An employee may also bring an action for injunctive relief to ensure compliance with this section, and is entitled to an award of costs and reasonable attorney's fees. Cal. Lab. Code § 226. Defendants employed Sullivan but failed to provide him with the data required by section 226(a) of the California Labor Code. For example, Defendants failed to provide information concerning (1) the total hours worked by Sullivan, (2) the inclusive dates of the period for which Sullivan was being paid, and (3) all applicable hourly rates in effect during the pay period and the corresponding number of hours worked at each hourly rate by Sullivan. All of the foregoing was intentional misconduct
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COMPLAINT

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of Defendant Lee that injured Sullivan insofar as Sullivan was subjected to confusion as 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 to whether he had been compensated correctly and deprived of information to which he was legally entitled. Exhibit 2 hereto reflects certain of Sullivan's redacted wage statements. 28. At all relevant times mentioned herein, section 226.3 of the California Labor

Code provided: Any employer who violates subdivision (a) of Section 226 shall be subject to a civil penalty in the amount of two hundred fifty dollars ($250) per employee per violation in an initial citation and one thousand dollars ($1,000) per employee for each violation in a subsequent citation, for which the employer fails to provide the employee a wage deduction statement or fails to keep the records required in subdivision (a) of Section 226. The civil penalties provided for in this section are in addition to any other penalty provided by law. Cal. Lab. Code § 226.3. 29. At all relevant times mentioned herein, section 204(a) of the California

Labor Code provided: All wages, other than those mentioned in Section 201, 202, 204.1, or 204.2, earned by any person in any employment are due and payable twice during each calendar month, on days designated in advance by the employer as the regular paydays. Labor performed between the 1st and 15th days, inclusive, of any calendar month shall be paid for between the 16th and the 26th day of the month during which the labor was performed, and labor performed between the 16th and the last day, inclusive, of any calendar month, shall be paid for between the 1st and 10th day of the following month. Cal. Lab. Code § 204. 30.

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At all relevant times mentioned herein, section S 1 (a) of the California

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COJ\.1PLAINT

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Eight hours of labor constitutes a day's work. Any work in excess of eight hours in one workday and any work in excess of 40 hours in anyone workweek and the first eight hours worked on the seventh day of work in anyone workweek shall be compensated at the rate of at least one and onehalf times the regular rate of pay for an employee. Any work in excess of 12 hours in one day shall be compensated at the rate of no less than twice the regular rate of pay for an employee. In addition, any work in excess of eight hours on any seventh day of a workweek shall be compensated at the rate of no less than twice the regular rate of pay of an employee. Nothing in this

section requires an employer to combine more than one rate of overtime compensation in order to calculate the amount to be paid to an employee for any hour of overtime work. The requirements of this section do not apply to the payment of overtime compensation to an employee working pursuant to any of the following: (1) An alternative workweek schedule adopted pursuant to Section 511. (2) An alternative workweek schedule adopted pursuant to a collective bargaining agreement pursuant to Section 514. Cal. Lab. Code § 510. 31. In regard to the employment of Sullivan, the provisions of subparagraphs (1)

and (2) of section 510 of the California Labor Code were inapplicable in that no alternative workweek schedule had been adopted pursuant to section Sll and Sullivan's employment to which reference is hereinafter made was not governed by any collective bargaining agreement to which Sullivan consented or to which they signed onto on their own behalf. 32. At all relevant times mentioned herein, section 1194 of the California Labor

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COMPLAINT

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receiving less than the legal minimum wage or the legal overtime compensation applicable to the employee is entitled to recover in a civil action the unpaid balance of the full amount of this ... overtime compensation, including interest thereon, reasonable attorney's fees, and costs of suit. Cal. Lab. Code § 1194. At all relevant times mentioned herein, section 1194.2 of the California Labor Code provided: (a) In any action under ... Section 1194 to recover wages because of the payment of a wage less than the minimum wage fixed by an order of the commission, an employee shall be entitled to recover liquidated damages in an amount equal to the wages unlawfully unpaid and interest thereon. Cal. Lab. Code § 1194.2 33. Notwithstanding the foregoing requirements of law, Sullivan was routinely

denied payment of overtime wages. 34. At all relevant times mentioned herein, section 221 of the California Labor

Code provided that: "[i]t shall be unlawful for any employer to collect or receive from an employee any part of wages theretofore paid by said employer to said employee." Lab. Code § 221. 35. California Labor Code section 2S02 requires employers to fully reimburse Cal.

employees for all work-related expenses the employees incur while performing work related duties. See Cal. Lab. Code § 2S02(a). 36. Defendants Lee and Mayhem Touring's conduct of requiring additional

work from Sullivan in the absence of overtime wage pay violates provisions of California law and the FLSA and also constitutes unfair competition and unlawful,

unfair, and fraudulent acts and practices within the meaning of section 17200 et seq. of the California Business and Professions Code. III

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COMPLAINT

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FIRST CAUSE OF ACTION (Failure To Pay Overtime Compensation, California Labor Code §§ 510, 1194, 1198) (Against All Defendants)
37. Plaintiff repleads, realleges, and incorporates by reference each and every allegation set forth in the Complaint. 38. Pursuant to Labor Code section 1194(a), Sullivan may bring a civil action

for unpaid overtime wages directly against the employer without first filing a claim with the Department of Labor. 39. At all times herein relevant, the sections of the California Labor Code and of of

the California Code of Regulations referenced herein applied to the employment Sullivan. 40.

Pursuant to Labor Code section 1198, it is unlawful to employ persons for

longer than the hours set by the IWC or under conditions prohibited by the California Code of Regulations. 41. At all times herein relevant, sections 510, 1194, and 1198 of the California

Labor Code and 8 California Code of Regulations section 11040 provided for the payment of overtime wages equal to one-and-one-half times an employee's regular rate

of pay for all hours worked over eight per day or forty per week, as well as for the payment of overtime wage equal to double the employee's regular rate of pay for

all hours worked in excess of twelve in any day and for all hours worked in excess of eight on the seventh day of work. 42. Under the provisions of sections 510, 1194, and 1198 of the California section 11040, Sullivan should

Labor Code and 8 California Code of Regulations

have received overtime wages in a sum according to proof. 43. Defendants owe Sullivan overtime wages pursuant to sections 510, 1194,

and 1198 of the California Labor Code and 8 California Code of Regulations section 11040 according to proof at trial of the hours worked for the period of time from four years prior to the filing of the Complaint to date.
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Sullivan requests payment of overtime compensation

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interest, liquidated damages, attorneys' fees, and costs pursuant to California Labor Code sections 1194(a) and 1194.2. SECOND CAUSE OF ACTION (Failure To Provide Accurate Itemized Wage Statements, California Labor Code § 226) (Against All Defendants) 45. Plaintiff repleads, realleges, and incorporates by reference each and every

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allegation set forth in the Complaint. 46. At all times herein relevant, section 226 of the California Labor Code and 8

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California Code of Regulations section 11040 required that employers provide employees with itemized wage statements showing, among other things, (1) the name of the legal entity that is the employer, (2) wages earned on account of meal and rest penalties, (3) the total hours worked by the employee, (4) the inclusive dates of the period for which the employee is paid, and (5) all applicable hourly rates in effect during the pay period and the corresponding number of hours worked at each hourly rate by the employee. Moreover, Labor Code section 226(e) provided that, if an employer knowingly and intentionally fails to provide a statement with all of the above-referenced information, then the employee is entitled to recover the greater of all actual damages or $50 for the initial violation and $100 for each subsequent violation, up to a maximum of $4,000.

47.

Defendants knowingly and intentionally failed to furnish Sullivan with

timely, itemized statements showing, among other things, (1) the total hours worked by Sullivan, (2) the inclusive dates of the period for which Sullivan was being paid, and (3) all applicable hourly rates in effect during the pay period and the corresponding number of hours worked at each hourly rate by Sullivan. All of the foregoing was intentional misconduct of Defendants that injured Sullivan as he was subjected to confusion as to whether Sullivan had been paid properly and deprived of information to which he was

23
24 25

26 27

16 COMPLAINT

1 2 3

legally entitled. As a result, Defendants provided by Labor Code section 226(e).

are liable to Sullivan for the amounts

4
5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

THIRD CAUSE OF ACTION (Failure To Maintain Accurate Payroll Time Records, Labor Code section 1174, Wage Order No.4) (Against All Defendants)
48. Plaintiff repleads, realleges, and incorporates by reference each and every

allegation set forth in the Complaint. 49. Defendants have violated Labor Code section 1174 and IWC Wage Order 4,

section 7(A) by willfully failing to keep required payroll records showing the actual hours worked each day by Sullivan. Indeed, the Wage Order requires that the employer maintain "[t]ime records showing when the employee begins and ends each work period. Meal periods, split shift intervals and total daily hours worked shall also be recorded." 8 Cal. Code Regs. § 11040(7)(A). Defendants have failed to properly maintain such records. 50. As a direct and proximate result of Defendants' failure to maintain payroll

records, Sullivan suffered actual economic harm as he has been precluded from accurately monitoring the number of hours worked and thus seeking all accrued pay.

FOURTH CAUSE OF ACTION (Failure to Pay Overtime Compensation, Fair Labor Standards Act, 29 U.S.C. § 216(b» (Against All Defendants)
51. Plaintiff rep leads , realleges, and incorporates by reference each and every

allegation set forth in the Complaint. 52. At all times relevant herein, 29 U.S.C. § 203(d) of the Fair Labor Standards

Act defined employer as "any person acting directly or indirectly in the interest of an employer in relation to an employee." 29 U.S.C. § 203(d). At all times herein,

Defendants acted directly or indirectly in the interest of an employer in relation to Plaintiff.
17 COMPLAINT

53.

At all times herein relevant, the FLSA provided:

2
3 4

[N]o employer shall employ any of his employees who in any workweek is engaged in commerce or in the production of goods for commerce, or is employed in an enterprise engaged in commerce or in the production of goods for commerce, for a workweek longer than forty hours unless such employee receives compensation for his employment in excess of the hours above specified at a rate not less than one and one-half times the regular rate at which he is employed. 29 U.S.c. § 207(a). 54. Defendants have intentionally and improperly failed to pay Sullivan

5 6
7

8 9 10 II 12 13 14 15 16 17

overtime compensation to which he is entitled. 55. During Sullivan's employment with Defendants, Sullivan was not paid for

all of his time worked. 56. Accordingly, Sullivan requests payment of overtime compensation

according to proof, liquidated damages, attorney's fees, and costs pursuant to 29 U.S.C. § 216(b).

18
19 20 21 22 57.

FIFTH CAUSE OF ACTION (Continuing Wages, California Labor Code § 203) (Against Tommy Lee)
Plaintiff repleads, realleges, and incorporates by reference each and every

allegation set forth in the Complaint. 58. At all times herein relevant, California Labor Code sections 201 and 202

23
24 25 26
)

provided that employees must receive wages earned and unpaid promptly upon termination or resignation. Defendant has failed and refused, and continues to fail and

refuse, to pay the amounts that are owed. 59. Defendant's failure to compensate Plaintiff within the time provided for in

..

27

the California Labor Code, despite his knowledge of his obligation to do so, was "willful" as the word is used in section 203.
18 COMPLAINT

"I~·28 1

P ):
)'

60. 2

Because Defendant has willfully failed to pay wages earned and unpaid

promptly upon termination or resignation, Defendants are liable to Sullivan for continuing wages under California Labor Code section 203 in an amount according proof. to

3 4
5 6 7 8

SIXTH CAUSE OF ACTION (Improper Deductions From Wages, California Labor Code § 221) (Against Defendant Tommy Lee)
61. Plaintiff rep leads, realleges, and incorporates by reference each and every

9
10 II 12 13 14

allegation set forth in the Complaint. 62. Pursuant to California Labor Code section 221, Defendant is prohibited

from deducting amounts from employee wages. In violation of the Labor Code and other provisions of law, Defendant improperly forfeited employee wages and deducted a portion of wages from Plaintiff on account of alleged expenses. Plaintiff seeks payment of such sums deducted in violation of California law.

IS
16 17 18 19 20 21 22 23 24 25

SEVENTH CAUSE OF ACTION (Failure To Reimburse Business Expenses, California Labor Code § 2802) (Against Defendant Tommy Lee)
63. Plaintiff repleads, realleges, and incorporates by reference each and every

allegation set forth in the Complaint. 64. California Labor Code section 2802 requires employers to fully reimburse

an employee for all work related expenses the employee incurs while performing work related duties. California Labor Code section 2804 prohibits employees from waiving their rights to full reimbursement for work-related expenses. 65. During the course of Sullivan's employment with Defendant, Plaintiff was

frequently required to make purchases for Lee and his family members with his own funds. Defendant failed to reimburse Sullivan for all expenses incurred in discharging his duties. Sullivan is entitled to be reimbursed for all expenses incurred in discharging the duties of his employment.
19 COMPLAINT

26

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1 2 3

66.

Sullivan is entitled to full reimbursement according to proof, and attorneys

fees and litigation costs as set forth in Cal. Lab. Code section 2802.

4 5
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
I'

EIGHTH CAUSE OF ACTION (Defamation) (Against Defendant Tommy Lee)
67. Plaintiff repleads, realleges, and incorporates by reference each and every

allegation set forth in the Complaint. 68. Lee published false statements disparaging Sullivan, and falsely stating that

he is untrustworthy and performed illegal and improper acts while employed by Lee. These disparaging and defamatory remarks were made to Lee and Sullivan's mutual acquaintances and to Sullivan's business contacts in the music industry. The statements made by Lee were false and made with actual malice. Lee intended to vex, annoy and humiliate Sullivan and interfere with his business relations. 69. Lee's defamatory statements, as alleged herein, were defamatory per se

because they tend, among other things, to injure Sullivan in his ability to pursue his profession and by imputing his general disqualification for his profession. 70. Lee's defamatory statements, as alleged herein, were not privileged. A

communication to interested persons for legitimate business reasons is only privileged if made without malice. The privilege is forfeited when, as in Sullivan's case, Lee was motivated by malice in providing knowingly false information about Sullivan's competence and trustworthiness, and effectively blacklisting Sullivan in his chosen industry. 71. Lee's false and unprivileged statements have damaged Sullivan's reputation

and business interests. 72. As a proximate result of Lee's defamatory statements, Sullivan has suffered

special economic losses including, but not limited to, loss of income, benefits and bonuses, loss of business-related opportunities and other devastating financial

27 ~. 1·28
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20 COMPLAINT

t 2 3 4 5 6 7

consequences.

As a result of Lee's wrongful actions, Sullivan has suffered special

damages in an amount no less than $50,000.00 or according to proof. 73. As a further and direct result of Lee's defamatory conduct, Sullivan has

suffered general damages, including, but not limited to, mental anguish, physical distress and humiliation. As a result of Lee's wrongful actions, Sullivan has suffered general

damages in an amount according to proof. 74. Sullivan is informed and believes, and thereon alleges, that in taking the

8
9

actions alleged above, Lee acted with malice, fraud or oppression and in reckless disregard of Sullivan's rights, and with the intent to cause injury and emotional distress to Sullivan. Lee's conduct was outrageous and despicable and warrants the award of punitive damages against him in an amount sufficient to punish Lee and make an example of him.

10
11 12 13 14 15 16 17 18 19 20 21 22 23 24

NINTH CAUSE OF ACTION (Intentional Interference With Prospective Economic Advantage) (Against Defendant Tommy Lee)
75. Plaintiff repleads, realleges, and incorporates by reference each and every

allegation set forth in the Complaint. 76. Economic business relationships existed between Sullivan and respective

third parties. All of these economic relationships would have contained a highly probably future economic benefit or advantage for Sullivan. 77. Lee knew of the existence of Sullivan's other economic relationships and, as

described herein, Lee intentionally committed acts designed to interfere with or disrupt these business relationships. These acts include, but are not limited to, Lee's publication

of false statements disparaging Sullivan, and false statements that Sullivan is untrustworthy and performed illegal and improper acts while employed by Lee. 78. As a proximate result of Lee's actions, Sullivan's economic relationships

2S
26
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27

with these third party business entities and individuals were in fact disrupted and in fact, Lee's actions were specifically designed to interfere with or disrupt these relationships,
21 COMPLAINT

;)28
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..

all of which caused damage to Sullivan. 2 3 4 79. Sullivan has suffered substantial injury, including mental anguish, As a result of Lee's wrongful

humiliation and the loss of said economic opportunities.

actions, Sullivan has suffered damage in an amount of at least $50,000.00 or in an amount according to proof. 80. Sullivan is further informed and believes, and thereon alleges, that in taking

5
6 7

the actions alleged above, Lee acted with malice, fraud or oppression and in reckless disregard of Sullivan's rights, and with the intent to cause injury and emotional distress to Sullivan. Lee's conduct was outrageous and despicable and warrants the award of punitive damages against him in an amount sufficient to punish Lee and make an example of him.

8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 ~.

TENTH CAUSE OF ACTION (Negligent Interference With Prospective Economic Advantage) (Against Defendant Tommy Lee)
81. Plaintiff repleads, realleges, and incorporates by reference each and every

allegation set forth in the Complaint. 82. An economic relationship existed between Sullivan and respective third

parties, which assured future economic benefit to Sullivan. 83. Lee knew of the existence of many of Sullivan's other economic

relationships, and was aware, or should have been aware, that his improper actions would interfere with these relationships and cause Sullivan to lose, in whole or in part, the probable economic benefits or advantages of the relationships. 84. Lee's negligent acts include, but are not limited to, publishing false

statements disparaging Sullivan and false statements that Sullivan is untrustworthy and performed illegal and improper acts while employed by Lee to third parties. 85. As a result of Lee's actions, Sullivan has suffered substantial injury,

including, but not limited to, mental anguish, humiliation, and the loss of economic and employment opportunities. As a result of Lee's wrongful actions, Plaintiff has suffered
22 COMPLAINT

~: ,.
"

;;28

damages in the amount of at least $50,000.00 or in an amount according to proof. 2 3 4

ELEVENTH CAUSE OF ACTION (Violations of Section 17200 et seq. of the California Business and Professions Code) (As Against All Defendants)
86. Plaintiff repleads, realleges, and incorporates by reference each and every

5
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

allegation set forth in the Complaint. 87. Defendants have engaged in acts that constitute a continuing and ongoing

unlawful activity prohibited by section 17200 et seq. of the California Business and Professions Code. These illegal acts justify restitution pursuant to section 17203 of the Business and Professions Code. 88. Beginning at an exact date unknown to Plaintiff, Defendant Tommy Lee has

committed acts of unfair business practice as defined in California Business and Professions Code section 17200 et seq. by engaging in the following acts and practices: I) failing to provide overtime compensation in accordance with sections 510 and 1194 of the California Labor Code; 2) failing to pay Plaintiff in accordance with sections 201, 202 and 203 of the California Labor Code; 3) failing to maintain accurate time recording and payroll records; 4) failing to reimburse Plaintiff for business-related expenses; 5) improperly deducting wages; 6) providing pay stubs that do not include the data required by section 226 of the California Labor Code; and 7) violating the Fair Labor Standards Act. Beginning at an exact date unknown to Plaintiff, Defendant Mayhem Touring, Inc. has committed acts of unfair business practice as defined in California Business and Professions Code section 17200 et seq. by violating sections 226, 510, 1174 and 1194 of the California Labor Code and the applicable Wage Order, and violating the Fair Labor Standards Act. 89. The acts and practices as described in the paragraph above violate Business

and Professions Code section 17200 et seq. in the following respects: Defendants' policy and practice of failing to pay Plaintiff overtime compensation violates sections 510 and 1194 of the California Labor Code and the Fair Labor
23
COMPLAINT

,.27 ,.
""

;~28 p,

1 2 3 4 5 6 7

Standards Act, and, consequently, constitutes an unlawful business act or practice within the meaning of Business and Professions Code section 17200 et seq.; Defendant Lee's policy and practice of failing to pay Plaintiff at the times mandated by sections 201 and.202 of the California Labor Code constitutes an unlawful business act or practice within the meaning of Business and Professions Code section 17200 et seq.; Defendants' policy and practice of failing to maintain accurate time recording and payroll records in violation of section 1174 of the California Labor Code and IWC Wage Order 4 constitutes an unlawful business act or practice within the meaning of Business and Professions Code section 17200 et seq.; Defendant Lee's policy and practice of failing to reimburse Plaintiff for businessrelated expenses in violation of section 2802 of the California Labor Code constitutes an unlawful business act or practice within the meaning of Business and Professions Code section 17200 et seq.; Defendant Lee's policy and practice of improperly deducting wages in violation of section 221 of the California Labor Code constitutes an unlawful business act or practice within the meaning of Business and Professions Code section 17200 et seq.; Defendants' policy and practice of failing to provide certain pay-stub data violates section 226 of the California Labor Code and, consequently, constitutes an unlawful business act or practice within the meaning of Business and Professions Code section 17200 et seq.; and Defendants' violation of the Fair Labor Standards Act is in contravention of federal law and, consequently, constitutes an unlawful business act or practice within the meaning of Business and Professions Code section 17200 et seq. 90. Through the wrongful and illegal conduct alleged herein, Defendants have violations of

8
9 10 11 12 13 14

IS
16 17 18 19 20 21 22 23 24 25 26 27

acted contrary to public policy and law. As a result of Defendants'

24 COMPLAINT

section 17200 et seq., Defendants have unjustly enriched themselves at the expense of 2 3 4 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Sullivan and the general public. 91. Under section 17200, et seq. of the Business and Professions Code, this

Court is authorized to enter such judgment or order as may be necessary to restore to any person in interest the money or property acquired by Defendants through their unlawful and unfair business practices. 92. To prevent this unjust enrichment, Defendants should be required to make

restitution to Sullivan, as identified in this Complaint (and as will be identified through discovery into Defendants' books and records), for the period of time from the four years preceding the filing of the Complaint to date. 93. Plaintiff is therefore entitled to a judgment of this Court requiring

Defendants to pay to Plaintiff the unpaid compensation and continuing wages, to which he is entitled, but which have been denied him by reason of Defendants' conduct alleged herein. 94. Sullivan also requests that the Court enter such orders or judgment as may

be necessary to restore to any person in interest any money that may have been acquired by means of such unfair practices, as provided in section 17203 of the California Business and Professions 95. Code.

Sullivan is a "person" within the meaning of section 17204 of the California

Business and Professions Code, and has standing to bring this claim for relief. 96. Injunctive relief is necessary to prevent Defendants from continuing to

engage in unfair business practices, as alleged herein. Defendants have done, or are now doing and will continue to do or cause to be done, the herein-described illegal acts unless restrained or enjoined by the Court. 97. The conduct of Defendants, as alleged herein, has been and continues

to be deleterious to Sullivan and the general public. By this action, Sullivan seeks to enforce important rights affecting the public interest within the meaning of section lO21.5 of the California Code of Civil Procedure.
25
COMPLAINT

";:28
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I.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
.,1,

98.

Pursuant to section 17203 of the California Code of Civil Procedure,

Sullivan requests injunctive relief and restitution of all sums obtained by Defendants in violation of section 17200 et seq. of the California Business and Professions Code for the period of time from the four years preceding the filing of the Complaint to date. PRA YER FOR RELIEF WHEREFORE, 1. Sullivan prays for judgment against Defendants as follows:

That, with respect to the First Claim for Relief, this Court enter judgment in

favor of Plaintiff for payment of his unpaid overtime compensation, interest thereon, liquidated damages, reasonable attorneys' fees and cost of suit, according to proof in accordance with sections 510 and 1194 of the California Labor Code. 2. That, with respect to the Second Claim for Relief, this Court enter judgment

in favor of Plaintiff for damages, reasonable attorney's fees, and costs of suit, each according to proof, in accordance with section 226(e) of the California Labor Code. 3. That, with respect to the Third Claim for Relief, this Court enter judgment in

favor of Plaintiff for damages, reasonable attorney's fees and costs of suit. 4. That, with respect to the Fourth Claim for Relief, this Court enter judgment

in favor of Plaintiff against all Defendants for payment of compensatory damages in an amount according to proof at time of trial representing the amount of unpaid overtime compensation owed to Sullivan, for liquidated damages pursuant to 29 U.S.C. § 216(b), and for reasonable attorney's fees and costs of suit pursuant to 29 U.S.C. § 216(b). 5. That, with respect to the Fifth Claim for Relief, it be adjudged that the

failure of Defendant Lee to make payment of wages within the time prescribed by sections 201 of the California Labor Code was "willful" within the meaning of section 203 of the California Labor Code and that this Court award Plaintiff continuing wages according to proof. 6. That, with respect to the Sixth Claim for Relief, this Court enter judgment in

favor of Plaintiff for unpaid wages, damages, civil penalties, interest, reasonable attorney's fees, and costs of suit.
26
COMPLAINT

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,,1;

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7. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

That, with respect to the Seventh Claim for Relief, this Court enter judgment

in favor of Plaintiff for all unreimbursed business expenses, damages, civil penalties, interest, reasonable attorney's fees, and costs of suit 8. That, with respect to the Eighth Claim for Relief this Court enter judgment

in favor of Plaintiff against Defendant Lee for economic damages for lost profits and business opportunities in an amount of at least $50,000.00 or according to proof at trial and interest thereon, for general non-economic damages for emotional distress, and mental anguish relief in an amount according to proof, for punitive damages in an amount that will punish Defendant Lee for his wrongful conduct and make an example of him. 9. That, with respect to the Ninth Claim for Relief this Court enter

judgment in favor of Plaintiff against Defendant Lee for economic damages for lost profits and business opportunities in an amount of at least $50,000.00 or according to proof at trial and interest thereon, for general non-economic damages for emotional distress, and mental anguish relief in an amount according to proof, for punitive damages in an amount that will punish Defendant Lee for his wrongful conduct and make an example of him. 10. That, with respect to the Tenth Claim for Relief this Court enter

judgment in favor of Plaintiff against Defendant Lee for economic damages for lost profits and business opportunities in an amount of at least $50,000.00 or according to proof at trial and interest thereon, for general non-economic damages for emotional distress, and mental anguish relief in an amount according to proof. II. That, under the Eleventh Claim for Relief, it be adjudged that Defendants'

violations of sections 201, 203, 204, 221, 226, 510, 1174, 1194 and 2802 of the California Labor Code, the applicable Wage Order, and the Fair Labor Standards Act violated section 17200 et seq. of the California Business and Professions Code. Accordingly, Plaintiff requests that the Court order Defendants to pay restitution to Plaintiff in the form of overtime compensation, wages, and continuing wages retained by Defendants, with interest. Furthermore, Plaintiff requests that the Court issue an

".

27

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27 COMPLAINT

order or decree pursuant 2 3 4 5 6 7 8 9 10 11 12 13 14 IS 16 17 Professions practice

to section

17203 of the California enjoins Defendants

Business

and their

Code that permanently

from pursuing

of violating

sections 201,203,204,221,226,510,

1174, 1194, and 2802 of

the California Standards reasonable Act.

Labor Code, the applicable Finally, Plaintiff requests

Wage Order, and the Fair Labor that the Court award Plaintiff in the prosecution his

attorney's

fees and costs incurred to section

of the Eleventh

Cause of Action pursuant Procedure. 12.

1021.5 of the California

Code of Civil

For such other and further relief as the Court may order.

Plaintiff demands a trial by jury as to all counts.

DATED: November 30, 2011

HARRIS & RUBLE

Alan Harris " . Attorneys for Plaintiff

18
19 20 21 22 23 24 25 26 27

28
COMPLAINT

Exhibit 1

-_._-

._._---_._._-

_

_

_

_

.

Priya Mohan
From: Sent: To: Cc: Subject: Steve Rothschild [Rothschild@khpblaw.com] Thursday, May 12, 2011 4:27 PM Priya Mohan Alan Harris Re: Tommy Lee/Tony Sullivan - Tolling Agreement

Continned.

Thanks.

On May 12, 2011, at 15:18, "Priya Mohan" <PMohan@harrisandruble.com>wrote: Dear Steve,

'10:"1:

This email will confirm that the parties have agreed to extend their tolling agreement, and that Mr. Lee and Mr. Sullivan agree that the statutes oflimitations applicable to claims that Mr. Lee or his entities may have against Mr. Sullivan, and that Mr. Sullivan may have against Mr. Lee or his entities are tolled effective April 14, 201 L pending the revocation of this agreement, which revocation can only be made with ten days written notice by email to counsel for either party.

Please confirm that this is your understanding.

Thanks,

Priya

Priya Mohan HARRIS & RUBLE 6424 Santa Monica Boulevard Los Angeles, California 90038 323.962.3777 Tel. 323.962.3004 Fax www.harrisandruble.com
1

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EXHIBIT

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Exhibit 2


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• ' i C/O DAVID' WEISE

_1 MAYHEMTOuRING INC'"'' " & .ASSOCIATES ~ " ~ 16000 VENTURA BLVD STE 600 \ ",'iENCINO.CA 91436'

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. ORDER

MICHAEL A SULLIVAN OF **VOID**
AMOUNT

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**VOID****THIS IS NOT A CHECK****VOID****THIS IS NOT A CHECK*· DEPOSIT AMOUNT MIIOUNT **.... 1694.77 *

.** Non

Negotiable

**

AUiHQIl,IZED SIGNAlURE(S)

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Af<D ALSO CONtAINS

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TOTAL EARNINGS
MAYHEM TOURING INC

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C/O DAVID WEISE & ASSOCIATES 16000 VENTURA BLVD STr 600 ENCINO.CA 91436 PAY PERIOD 08/27/07 TO 09/02/07 CHECK DATE 08/31/07 CHEtK' 11336
S 09 S 09 MEDICARE

soc

SEC

=

2500.00 155.00

73785.71

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411.48
36.25 169.72

FEDERAL CA DBL

15.00

10418.04 4603.49
442.71

4574.71 1069.B9

TOTAL WITHHOLDINGS

787.45

21108.84

TOTAL ADJUSTMENTS

17.78-

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NET PAY

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DEPOSIT AMOUNT ******441.51

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TOTAL EARNINGS

2000.00

4300.00

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CHECK DATE 01/11/08

PAY PERIOD 01/07/08 TO 01/13/08

CHECK

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11380

TOTAL WITHHOLDINGS ADVANCE

558.49 1000.00 -

1142.33 1000.00 -

TOTAL ADJUSTMENTS

1000.00-

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09110/2010
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MAYHEM TOURING INC
% DAVID WEISE & ASSOCIATES 16000 VENTURA BLVD STE 600 ENCINO CA 91436

0083-E655 200 Crew

11523
CHECK. NO.

PAY TO THE
ORDER OF

VOID THIS IS NOT A CHECK .•...........••............•.•..•.•••.•..•...

DOLLARS

.....
FOLU

AND REMOVE

FOLD AND REMOVE EARNINGS DESCRIPTION HOURS RA TE THIS PERIOD ($) YTD HOURS

s.,

PERSONAL AND CHECK INFORMATION

YTO($) 37982.86

Regular
10: 47 WITHHOLDINOS Bereavement Vacation EARNINGS DESCRIPTION Social Security Medicare Fed Income Tax CA Income Tax CA Disability TOTAL DESCRIPTION Advance TOTAL

1500.00

3000.00
....1.§QQJ!Q

Soc Sec # Home Department:

Employee

200 Crew

"i"'5Oo:OO
FILING STATUS THIS PERIOD ($)

42492.86
YTD($i 2634.56 616.15

Pay Period: 09/06110 to 09/10110 Check Date: 09/10/10 Chack #: 11523 NET PAY ALLOCATIONS DESCRIPTION Check Amount Chkg1252 NET PAY THIS PERIOD ($) YTD($)

93.00
21.75 S9 S09

126.08
83.55

3404.54
2284.27 467.43

0.00 1.:!..§2..!1. 1159.12

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DEDUCTIONS

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23299.06

340Fa
THIS PERIOD ($)

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NET PAY

THIS PERIOD ($) 1159.12

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Ma~hem Touring Inc' % David Weise & Assceiates- 16000 Venlura Blvd SID600· Encino CA 91436

::0083 oo83-E655

.3

~TTORNEY

323.962.3777 FAX NO.: 323.962.3004 Michael Anthony Sullivan SUPERIOR COURT OF CALIFORNIA. COUNTY OF Los Angeles STREET ADDRESS: III North Hill Street MAILING ADDRESS III North Hill Street CITY AND ZIP CODE: Los An~esk CA 90012 BRANCH NAME: Stanley os Courthouse
TELEPHONE NO.: ATTORNEY FOR

Alan Harris (SBN 146079) HARRIS & RUBLE 6424 Santa Monica Blvd. Los Angeles, CA 90038
(Name):

OR PARTY WITHOUT ATTORNEY

(Nome, SIBle Bar number. and address):

FOR COVRT

vse ONL Y

CM 010

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01P/,RILEDfCal (fom ia ug~rr9r.c;ouhie
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John A ' Crark c, r .:xecut;ve

NOV ~ 0 [011
On..

CASE NAME:

reer! ell rk """" ! !;'J~P!.l

Sullivan v. Lee

rz

CIVIL CASE COVER SHEET
Unlimited (Amount demanded exceeds $25,000)

0

Complex

Case Designation

CASE NUMBER:

Limited (Amount demanded is $25,000 or less)

D

Counter

D

Joinder
JUDGE: DEPT:

8C474341

Filed with first appearance by defendant (Cal. Rules of Court, rule 3.402)

Items 1-6 below must be completed (see Instr(lctlons on page 2). 1. Check one box below for the case type that best describes this case: Auto Tort Contract

o o

Auto (22) Uninsured motorist (46)

Other PIIPDIWD (Personal Injury/Property DamagelWrongful Death) Tort

o

o

Asbestos (04) Product liability (24) Medical malpractice (45) Other PIIPD,wD (23)

o o o o o o o o
a.

o o

D D

0

Bleach of contractlwarranty (06) Rule 3.740 collections (09) Other collections (09) Insurance coverage (18) Other contract(37)

Provisionally Complex CiVil Litigation (Cal. Rules of Court, rules 3.400-3.403)

o Construction defect (10) o Mass tort (40)

D

AntitrusVTrade regulation (03)

o
0

Non-PIIPDIWD (Other) Tort

Other real property (26) Business tort/unfair business practice (07) Civil rights (08) Unlawful Detainer Defamation (13) Fraud (16) Intellectual property (19) Professional negligence (25) Other non-PIIPDIWD tort (35) Wrongful termination (36) Other employmenl (15)

o
0

D

Real Property Eminent domain/Inverse condemnation (14) Wrongful eviction (33)

o o o
D

Securities litigation (28) EnvironmentalfToxic tort (30) Insurance coverage claims arising from the above listed provisionally complex case types (41) Enforcement of judgment (20) RICO(27) Other complaint (not specified above) (42) Partnership and corporate governance (21) Other petilion (nol specified above) (43)

Enforcement of Judgment

D

Commercial (31) Residential (32)
Drugs (38)

Miscellaneous Civil Complaint

o o

o o

Judicial Review

o

Employment

[ZJ
2.

This case is [ZJ is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management:

0

D 0 0 0

Asset forfeiture (05) Petition re: arbitration award (11) Writ of mandate (02) Other judicial review (39)

Miscellaneous Civil Petition

o

0 b.O 0

Large number of separately

represented

parties

d. e. f.

Extensive motion practice raising difficult or novel issues that will be time-consuming to resolve Substantial amount of documentary evidence

0 Large number of witnesses 0 Coordination with related actions D Substantial
declaratory

pending in one or more courts in other counties, states, or countries, or in a federal court post judgment judicial supervision or injunctive relief c.

c.
3.

Remedies sought (check aI/ that apply): a.CZJ monetary

b. [Z] nonmonetary;

[ZJ punitive

4. Number of causes of action (specify): Eleven 5. This case is is not a class action suit. 6. If there are any known related cases, file and serve a notice of related c~as . (You maYlk:e form CM-015)

0

0

Date: November 29, 20 II Alan Harris
(TYPE OR PRlNT NAME)

~ ~
NOTICE

/' /\

L--J-.......l~--;(;O;SI;r;G"'NA"hR;f,E;-,O<OF¥.:4.R"TY""'O"R T-ATTr;o;;ORruN""EvyEFO"'R"P"'A"'RTruy") ----

• Plaintiff must fite this cover sheet with the first paper filed in the action or proceeding (except smalt claims cases or cases filed under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court. rule 3.220.) Failure to file may result in sanctions. • File this cover sheet in addition to any cover sheet required by local court rule. • If this case is complex under rule 3.400 et seq. of the Califomia Rules of Court, you must serve a copy of this cover sheet on all other parties to the action or proceeding. • Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only._
fI""ge10'2 FO!TIl Adopled for Mandalory Use Judicial ccuncu of callfomia CM-lJ10 IRav. July 1. 2007)

CIVIL CASE COVER SHEET

cal. Rulas 01 Coo~. rules 230. 3.220. 3.400-3403. 3740; Cal. Standards of Judicial Admj(listr.atiofl, std. 3.10 WNW.oourlinfo.ca.gov

INSTRUCTIONS

ON HOW TO COMPLETE THE COVER SHEET

CM-010

To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compile statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1, check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action. To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party, its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court. To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general tlrne-for-servlce requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections case will be subject to the requirements for seNice and obtaining a judgment in rule 3.740. To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the plaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that the case is complex.
Auto Tort Auto (22)--Personal Injury/Property CASE TYPES AND EXAMPLES Contract Breach of ContractlvVarranty (06) Breach of Rental/Lease Contract (not unlawful detainer or wrongful eviction) ContractlvVarranty Breach-Seller Plaintiff (not fraud or negligence) Negligent Breach of Contract/ Warranty Other Breach of ContracllWa rranty Collections (e.g .• money owed. open book accounts) (09) Collection Case-Seller Plaintiff Other Promissory NotelCollections Case Insurance Coverage (not provisionally complex) (18) Auto Subrogation Other Coverage Other Contract (37) Contractual Fraud Other Contract Dispute Real Property Eminent Domain/Inverse Condemnation (14) Wrongful Eviction (33) Other Real Property (e.g., quiet title) (26) Writ of Possession of Real Property Mortgage Foreclosure Quiet Title Other Real Property (not eminent domain, landlord/tenant, or foreclosure) Unlawful Detainer Commercial (31) Residential (32) Drugs (38) (if the case involves illegal drugs, check this item; othe/Wise. report as Commercial or Residentia/) Judicial Review Asset Forfeiture (05) Petition Re: Arbitration Award (11) Writ of Mandate (02) Writ-Administrative Mandamus Writ-Mandamus on Limited Court Case Matter Writ-Other Limited Court Case Review . Other Judicial Review (39) Review of Health Officer Order Notice of Appeal-Labor Commissioner Appeals Provisionally Complex Civil Litigation (Cal. Rules of Court Rules 3.400-3.403) AntitrustlTrade Regulation (03) Construction Defect (10) Claims Involving Mass Tort (40) Securities Litigation (28) EnvironmentallToxic Tort (30) Insurance Coverage Claims (arising from provisionally complex case type listed above) (41) Enforcement of Judgment Enforcement of Judgment (20) Abstract of Judgment (Out of County) Confession of Judgment (nondomestic relations) Sister State Judgment Administrative Agency Award (not unpaid taxes) Petition/Certification of Entry of Judgment on Unpaid Taxes Other Enforcement of Judgment Case Miscellaneous Civil Complaint RICO (27) Other Complaint (not specified above) (42) Declaratory Relief Only Injunctive Relief Only (nonharassment) Mechanics Lien Other Commercial Complaint Case (non-torllnon-complex) Other Civil Complaint (non-tol1lnon-complex) Miscellaneous Civil Petition Partnership and Corporate Governance (21) Other Petition (not speCified above) (43) Civil Harassment Workplace Violence Elder/Dependent Adult Abuse Election Contest Petition for Name Change Petition for Relief From Late Claim Other Civil Petition

DamagelWrongful Death Uninsured Motorist (46) (if the case involves an uninsured motorist claim subject to arbitration. check this item instead of Auto) Other PI/PDIWD (PersonallnJuryl Property DamagelWrongful Death) Tort Asbestos (04) Asbestos Property Damage Asbestos Personal Injury/ Wrongful Death Product Liability (not asbestos or toxic/environmental) (24) Medical Malpractice (45) Medical MalpracticePhysicians & Surgeons Other Professional Health Care Malpractice Other PI/PDIWD (23) Premises Liability (e.g .. slip and fall) Intentional Bodily Injury/PDIWD (e.g .• assault. vandalism) Intentional Infliction of Emotional Distress Negligent Infliction of Emotional Distress Other PI/PDIWD Non-PI/PDIWD (Other) Tort Business Tort/Untair Business Practice (07) Civil Rights (e.g., discrimination, false arrest) (not civil harassment) (08) Defamation (e.g., slander, libel) (13) Fraud (16) Intellectual Property (19) Professional Negligence (25) Legal Malpractice Other Professional Malpractice (not medical or legal) Other Non-PI/PDM'D Tort (35) Employment Wrongful Termination (36) Other Employment (15)

~,I,
~'h

v., I:;

p ,::
",

CM·Ol0 (Rev. July 1, 20071

CIVIL CASE COVER SHEET

Pago 2 of2

.1

SHORT TITLE:

Sullivan v . Lee

CASE NUMBER

BC474341

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court. Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL?

iili

YES

CLASS ACTION?

D

YES

LIMITED

CASE?

DYES

TIME ESTIMATED

FOR TRIAL 5

D ~--~~~~~~
HOURS/0

DAYS

Item II. Indicate the correct district and courthouse location (4 steps - If you checked "Limited Case", skip to Item III, Pg. 4):

Step 1:

After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your

case in the left margin below, and, to the right in Column

A, the B

Civil Case Cover Sheet case type you selected. below which best describes the nature of this case.

Step 2: Step 3:
checked.

Check ~

Superior Court type of action in Column

In Column C, circle the reason for the court location choice that applies to the type of action you have For any exception to the court location, see Local Rule 2.0, Applicable Reasons for Choosing Courthouse Location
6. 7, 8. 9. 10, location Location Location Location Location

(see Column C below)
of property or permanently garaged vehicle. where petitioner resides. wherein defendant/respondent functions wholly. where one or more of the parties reside. of Labor Commissioner Office

1. 2. 3. 4. 5.

Class actions must be filed in the Stanley Mosk Courthouse, central district. May be filed in central (other county, or no bodily injury/property damage). location where cause of action arose. Location where bodily injury, death or damage occurred. Location where performance required or defendant resides.

Step 4:

Fill in the information requested on page 4 in Item III; complete Item IV, Sign the declaration.

A
Cillil Case Cover Sheet Category No. Auto (22) Uninsured Motorist (46)

B
Type of Action (Check only one}

C
Applicable Reasons See Step 3 Above DamagelWrongful Death Motorist 1.,2.,4. 1.,2.,4.

<I-

.81:: ::s 0

0 0 0 0 0 0
D

A7100 A7110

Motor Vehicle - Personal Personal Injury/Property

k1jurylProperty DamagelWrongful

Death - Uninsured

Asbestos

(04)

A6070 A7221 A7260 A7210 A7240 A7250 A7230 A7270 A7220

Asbestos Asbestos

Property Damage - Personal InjurylWrongful Deah

2. 2,

Product liability

(24)

Product Liability (not asbestos Medical Malpractice Other Professional Premises

or toxidenvironmental)

1 .• 2.,3.,4 1.,4. 1.,4.

.• 8.

Medical Malpractice

(45)

- Physicians

& Surgeons

Healtn Care Malpractice

0
Other Personal Injury Property Damage Wrongful Death (23)

Liability (e.q., slip and fall) DamagelWrongful Distress DamagelWrongful Death Death (e.g.,

1.,4. 1.,4. 1.,3. 1.,4.

0 0 0

Intentional Bodily InjurylProperty assault, vandalism, etc.) Intentionallnftiction Other Personal of Emotional

I~. 1:1;:LACIV 109 (Rev. 03/11) "LASCApproved03-04

", '"
I,

Injury/Property

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

~~~~~~~~~~~~~;_~~~~~~------------~--~~~~---

Local

Rule 2,0

Page 1 of4

I SHORT TITLE

~UlhVan

v.

Lee

I
B
Type of Action (Check only one)

CASE NUMBER

A
Civil Case COver Sheet Category No. Business Tort (07) Civil Rights (08) Defamation (13)

C
Applicable Reasons See Step 3 Above of contract) 1.,3. 1.,2.,3. 1.. 2 .. 3. 1.,2.,3. 1.,2.,3. -

D D D

A6029 AG005 A60tO

Other Cornmerclat'Buslness Civil Rights/Discrimination Defamation (slander/libel)

Tort (not fraudlbreach

Fraud (16)

0 A6013 0 A6017

Fraud (no contract) Legal Malpractice Other Professional Malpractice (not medical or legal) Damage tort

Professional

Negligence

(25)

0 A6050 0 A6025

1.,2.,3. 2.,3. t., 2., 3.

Other (35)

Other Non-Personallnjury/Property Wrongful Termination Complaint Appeals Contract Case

c
'"
"'E. E w
E >. o

Wrongful

Termination

(36)

0

A6037

Other Employment

(15)

IZl A6024 0 0
A6109 A6004

Other Employment Labor Commissioner

1

~

10. (not unlawful detainer or wrcnqful

Breach of Rental/Lease eviction) ContracUWarranty Negligent

2.,5. 2.,5. t.,2.,5. 1.,2.,5.

Breach of ContracU Warranty (06) (not insurance)

0 A6008 0 A6019 0 A6028

Breach -Seller Plaintiff (no fraud/negligence) (no fraud)

Breach of ContracUWarranty

Other Breach of ContractlWarranty Collections Case-Seller Plaintiff

(not fraud or negligence)

~ c
U

o

Collections

(09)

0 A6002 0 A6012
(18)

2.,5.,6. Case 2.,5. 1.,2.,5.,8. 1.,2.,3.,5. 1.. 2 .. 3 .. 5.

Other Promissory Insurance Contractual Tortious

Note/Collections (not complex)

Insurance

Coverage

D D

A6015 A6009 A6031

Coverage Fra ud

Other Contract

(37)

D

Interference Dispute(not breach/insurancelfra udlnegligence)

0 A6027
Eminent Domain/Inverse Condemnation (14) Wrongful Eviction (33)

Other Contract

1.,2.,3.,8.

D D D

A7300

Eminent Domain/Condemnation

Number of parcels ___

2.

A6023 A6018 A6032 A6060

Wrongful Mortgage Quiet Title

Eviction Case Foreclosure

2.,6. 2.,6. 2.,6.

Other Real Property

(26)

D D

Other Real Property

(not eminent

domain, landlord/tenant,

foreclosure)

2.,6.

Unlawful

Detainer-Commercial (31) Detainer-Residential (32)

D D 0

A6021

Unlawful Detainer-Commercial

(not drugs or wrongful

eviction)

2.,6.

Unlawful

A6020

Unlawful Detainer-Residential

(not drugs or wrongful

eviction)

2.,6.

Unlawful DetainerPost-Foreclosure (34) Unlawful Detainer-Drugs (38)

A6020F Unlawful Detainer-Post-Foreclosure

2.,6.

) ~,

0 A6022

Unlawful Detainer-Drugs

2.,6.

~."' ,.",
I)

I)
:': ~. LACIV 109 (Rev. 03/11) LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0 Page 2 of 4

I SHORT

TITLE:

Sullivan

v,

Lee

I CASE NUMBER
B
Type of Action (Check only one)

A
,Civil Case Cover Sheet Category No. Asset Forfeiture (05) (11)

C
Applicable Reasons See Step 3 Above 2.,6. Arbitration 2 .. 5, 2., B. 2. 2. 2., B. 1.,2., 1.,2.,3. B.

0 AB10S Asset Forfeiture Case 0 A6115 0 A6151
Petition to CompellConfirmNacate Writ - Administrative Writ - Mandamus Mandamus

Petition re Arbitration

Writ of Mandate

(02)

0

A6152

on Limited Court Case Matter

0 A6153
Other Judicial Review (39)

Writ - Other Limited Court Case Review Other Writ IJudicial Antitrustrrrade Construction Review

0 A6150 0 0 0 0 0 0 0
A6003 A6007

~ CI

c:: o

AntitrustiTrade Construction

Regulation

(03)

Regulation Defect

:3
.!!
(.)
)(

Defect (10) Mass Tort

CL

E o

Claims Involving (40) Securities

A6006

Claims Involving

Mass Tort

1.,2.,

B.

~

Litigation

(2B)

A6035

Securities

Litigation

Case

1.,2.,

B.

n;
c:: .!:!
Q..

en .:;

Toxic Tort Environmental (30) Insurance Coverage Claims from Complex Case (41)

A6036

Toxic TortiEnvironmental

1.,2.,3.,

B.

2

A6014

Insurance

CoveragelSubrogation

(complex

case only)

1.,2.,5.,

B.

A6141 AB160 A6107

Sister State Judgment Abstract of Judgment of Judgment (non-domestic relations)

2,9. 2.,6. 2.,9. 2., B. 2., B. 2., B.. 9. 1.,2., 1.,2., 2., B. B. B.

CC <II <II EE <II CI

0
Enforcement of Judgment (20)

J2-=:
tfio

e-c

0

Confession

0 A6140 0
A6114

Administrative

Agency Award (not unpaid tasas) for Entry of Judgment of Judgment Case on Unpaid Tax

PetitionlCertificate Other Enforcement Racketeering Declaratory Injunctive

0 A6112
RICO (27)

0

A6033 A6030 A6040 A6011

(RICO) Case Relief Only

,
Other Complaints (Not Specified Above) (42)

0
0 0

Relief Only (not domestic/harassment) Complaint Case (non-tort/non-comptex)

Other Commercial

1.. 2 .. 8.
1.,2.,B.

0 A6000
Partnership Corporation Governance (21)

Other Civil Complaint

(non-tortlnon-complex)

0 A6113 0 A6121

Partnership

and Corporate

Governance

Case

2., S.

Civil Harassment Workplace Harassment Adult Abuse Case

2.,3.,9. 2.,3.,9. 2.,3.,9. 2. 2.,7. 2.,3.,4., 2.,9. S.

0
Other Petitions (Not Specified Above) (43)

A6123 A6124 A6190

0
0

Elder/Dependent Election Contest

0 ABll0 0 0
A6170 A6100

Petition for Chanqe of Name Petition for Relief from Late Claim Law Other Civil Petition

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~~,

v,

1:~

I)

."
.,

LACIV 109 (Rev, 03/11) LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0 Page 3 of 4

I
.

SHORT TITLE:

Sullivan v. Lee

I
ADDRESS:

CASE NUMBER

Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in Item 11.,Step 3 on Page 1, as the proper reason for filing in the court location you selected.

REASON: Check the appropriate boxes for the numbers shown under Column C for the type of action that you have selected for this case.

550 South Flower Street

01. [2]2.03.04.
CITY:

OS. 06. 07. 08. 09.010.
STATE: ZIP CODE:

Los Angeles

CA

90071

Item IV. Declaration of Assignment _C_e_n_tr_a_1

I declare under penalty of perjury under the laws of the State of California that the foregoing is true

.. and. correct and that the above-entitled matter is properly filed for assignment to the Stanley Mosk Rule 2.0, subds. (b), (c) and (d)).

courthouse in the

District of the Superior Court of California, County of Los Angeles (Code Civ, Proc., § 392 et seq., and Local

~.i ." ..

~ r

Dated: November 30, 2011

".

II

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED COMMENCE YOUR NEW COURT CASE:

AND READY TO BE FILED IN ORDER TO PROPERLY

\ 1. Original Complaint or Petition. 2. 3. 4. S.
Iffiling a Complaint, a completed Summons form for issuance by the Clerk. Civil Case Cover Sheet, Judicial Council form CM-Ol0. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASe Approved 03-04 (Rev. 03/11 ). Payment in full of the filing fee, unless fees have been waived. minor under 18 years of age will be required by Court in order to issue a summons .

6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-Ol0, ifthe plaintiff or petitioner is a
.- '7. 'Addiiional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along with the summons and complaint, or other initiating pleading in the case.

LACIV 109 (ReI'. 03/11) LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0 Page 4 of 4