,-

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Bryan J. Freedman (SBN 151990) Jesse A. Kaplan (SBN 255059) FREEDMAN & TAITELMAN, LLP 190 1 Avenue of the Stars, Suite 500 Los Angeles, California 90067 Telephone: 310-201-0005
Facsimile: 310-201-0045

SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES

FILED

FEB 1 4 2012
John

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Attorneys for Plaintiff SDB Partners, Inc.

BY

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SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL SDB PARTNERS, INC., a California corporation, Plaintiff, vs. CHRIS PINE, an individual; SIR HC ENIP, INC., a California corporation; and DOES I10, inclusive, Defendants. ) Case No.:

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eC478818
COMPLAINT FOR:

1. BREACH OF IMPLIED CONTRACT; 2. DECLARATORY RELIEF; AND ) 3. ACCOUNTING.

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COMPLAINT

Plaintiff SOB Partners, Inc. ("SOB "), hereby alleges the following causes of action

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against defendants Chris Pine ("Pine"), SIR HC ENIP, Inc., a California Corporation ("SIR"), and Does I through 10, inclusive, as follows:

Introduction
I. In 2002, SOB, a boutique talent agency, agreed to represent a completely

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unknown actor named Chris Pine. Like any other client, SOB invested a great deal oftime, money, energy, dedication and good will to organically building Pine's career from scratch. Over the course of approximately internationally nine years, SOB took Pine from a novice actor to an In particular,

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renowned movie star who could command a seven figure payday.

SOB entrenched Pine in the iconic, not to mention lucrative, roles of Star Trek IS Captain James T. Kirk and Tom Clancy's Jack Ryan. In June of 2009, about a month after Star Trek's release, Pine praised his talent agents at SOB and professed his loyalty to them for building his career. Pine said the following about SOB: I'm a firm believer in loyalty. At the end of the day, this is a business, and you are a business, and I have felt in my career it has served me to stay with the people starteg with me because I believe they're as passionate and as dedicated as they've ever been.

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(emphasis added) 2. Nonetheless, on November 11,201], Pine discharged SOB byemail. Pine did no

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even have the courtesy of picking up the telephone to tell SOB that he was ending their relationship of nine years, 3. In Pine's email, pine again praised SOB, acknowledging SOB's investment of

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time and energy in building pine's career. In fact, Pine even went as far as to credit much of his success to ~O~. Specifically, Pine's email stated as follows:

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After much thought and consideration, I have decided that it is best for me to leave. I hope that you will understand that this decision was very difficult for me to make becauSe lowe much of the success in my career to all of you. At our last group meeting I explained that I was frustrated and needed more than what I was getting from the agency. I thought that with some time, perhaps, my feelings might change but unfortunately they have not. Please know that I recognize what great advocates you have been for me and that you have invested your time and energy into building my career. None of this do I take lightly or for granted. That 2

COMPLAINT

is why this has been so agonizing for me. I hope that you can respect my decision and accept it as final.
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I wish you, Steven, Ro and Susie nothing but the best. Have a wonderful holiday season and a happy new year. If you need to discuss anything further please contact, John. With [sic] much appreciation and gratitude, (emphasis added) 4. Moreover, Pine apparently does not intend to continue paying SDB its on projects that SDB had helped bring to Pine, including Star Trek and the Jack

7

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Ryan fllms. That is,
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Pine apparently
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does not believe that 10Yillty to pis ag~Pts includes paying
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SOB the commissions

that it is owed. After Pine discharged SOB by entail, SDB confirmed in

11 , writing that Pine was required to continue paying SDa commissions on certain. projects. Pine 12 13 14 15 16
17 responded with silence. Tnough SDB has not heard from Pine since SDB's discharge, Pine's silence

Js very
5.

telling. Whether Pine is being misguided by his handlers or has simply been blinded by

his success and fame, Pine apparently needs a refresher course on his obligation to compensate SDB for what SDa has done for him. Through this lawsuit, SP~ seeks to nat only recover its commissions
. '

an millions of dollars
i,

that Pine

hasalready earned, but also the millions of dollars
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that Pine will continue to earn. as a result ofSPB's career.

prior hard work and dedication to Pine's
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The Parties

6.

SDa is, ~4 at all times herein mentioned was, a California corporation, with its
" ;..,

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principal place of business in Los Angeles, California, and is qualified to conduct business in the SDB is a talent agency.

2~ State of California.

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7.
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Upon information and belief, pine is, and ~t all times herein mentioned was, an
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individual residing in Los Angeles, California. 8. Upon information and belief, SIR is, and at all times herein mentioned was, a Upon

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California corporation, with its principal place of business in Los Angeles, California. information and belief, Pine is SIR's sole stockholder and equity owner.

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3 COMPLAINT

9. 2

The true names and capacities, whether individual, corporate, associate or

otherwise of the defendants named herein as Does 1 through 10, inclusive, are unknown to SOB which therefore sues said defendants by such fictitious names. Upon information and belief, each of the defendants, including those designated as a Doe, are responsible for the events alleged herein and the damages caused thereby as a principal, agent, co-conspirator or aider and abettor. SDB will seek leave of this Court to amend this Complaint to allege the true names and capacities of such defendants when the same have been ascertained. 10. Upon information and belief, at all times relative to this action, cross-defendants

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were the agents, servants, partners, joint venturers and employees of each of the other defendants and, in doing the acts alleged herein, were acting with the knowledge and consent of each of the other defendants in this action. 11. SDB's causes of action arise out of events and transactions that occurred in Los

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Angeles County, California .' SOB and Pine

12.
experience.

In 2002, Pine was

an unknown

actor with literally no professional acting

Though Pine could not even find an agent to represent him, let alone a paying acting

17 job, in 2002, SOB agreed to meet with Pine as a favor. While Pine was certainly a long shot,
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spa recognized
one else
W'lS

Pine's talent, ambition and potential to become a viable client. Even though no

wjllipg to touch pine, in 2002, SDB agreed to take Pine on as a new client.
Subsequently, in or around February 2003, SPB formalized the terms of its

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a~reement !o represent fine. SPB explained

to Pine

the principal terms of the agreement that

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would govern SOB's representation of Pine as his talent agent. That is, SOB told Pine that in return for SOWs services, Pine would pay SDB

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an industry

standard 10% commission on any engagements

sums or other consideration that Pine received with respect to all commissionable

(including renewals and options that are exercised or contracts that have been renegotiated) that
SDa participated in obtaining for Pine andlor offered to Pine andlor initiated while represented

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by SOB (the "Commissionable
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Projects") as is accepted as industry standard. in or around February 2003, SDB and Pine entered into

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Contemporaneously,

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COMPLAINT

several guild approved standard written talent agency agreements. 2 3 4 5 6 7

Again, Pine and SDB

expressly agreed that SDB would be entitled to the industry standard 10% commission for representing Pine as his talent agent. In particular, on or about February 26. 2003, SDB and Pine entered into a written SAG Motion Picture/Television Agency Contract (the "SAG Agency

Contract") for a one year term. Pursuant to the SAG Agency Contract, Pine agreed in writing to pay SDB a 10% percent commission. Specifically, the SAG Agency Contract stated as follows:

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The Actor [Pine] agrees to pay to the Agent [SDB] as commissions a sum equal to 10 percent of all moneys or other consideration received by the Actor, directly or indirectly, under contracts of employment (or in connection with his employment under said employment contracts) entered into during the term specified in Paragraph (2) or in existence when this agency contract is entered into except to such extent as the Actor may be obligated to pay commissions on such existing employment contract to another agent. Commissions shall be payable when and as such moneys or other consideration are received by the Actor, or by anyone else for or on the Actor's behalf. (emphasis added) 15. In addition to entering into the SAG Agency Agreement, on or about February 26,

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2003, SDB and Pine also executed a written American Federation of Television and Radio Artists Standard AFTRA Exclusive Agency Contract and an Actors' Equity Association Exclusive Management Contract Under Equity Agency Regulations, Like the SAG Agency

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Contract, these agreements also required Pine to pay SDB a 10% commission. 16. Around the same time, in early 2003, SDB was able to secure Pine's first

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professional acting job, a guest role on the television show $800 for his one day of work. 17.

ER. Pine was paid approximately

Gradually, SDB was able to secure more substantial television roles for Pine. By the end 0[2003, SDB was able to land Pine the leading male role in a Disney
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feature film, The Princess Diaries II. This was a breakout role for Pine. That is, over the span approximately 8 months, SDB had taken Pine from an unknown actor who earned $800 on his

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first job, to a young actor who played the leading male role in a studio feature film. 19. During the one year term of the SAG Agency Agreement, Pine paid SOB a 10%

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COMPLAINT

commission on all sums and consideration he received on Commissionable 2 20.

Projects.

When the SAG Agency Agreement concluded on its own terms in February 2004, While The Princess Diaries 11

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both Pine and SDB were excited to continue their relationship.

was a substantial notch in Pine's belt, both SDB and Pine knew that there was a long road ahead and room for substantial growth in Pine's young acting career. As such, after the SAG Agency Agreement concluded in February 2004, SDB continued to represent Pine through November 2011. During this period, SDB continued to render talent agent services to Pine, including without limitation, reading m~terial for Pine and advising him, assisting Pine in procuring

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employment, assisting

in the negotiation of Pine's various deals, and building Pine's acting

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C'!f~e~,:Jhp"mpJiRltUJla~rsum~ill~W~Jluit
any sums or consideration 21.

Sp~ wpu14 pp.Jltin~c;Jq ~fU1lfrQo/ft~9mmissr()n'pn
Projects.

earned by Pine from Commissionable

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From the beginning of the relationship between SDB and Pine and 2011, when

Pine abruptly stopped paying SDB, Pine or his loan out company SIR always paid SDB the industry standard 10% commission on all sums or other consideration respect to all Commissionable guaranteed compensation, that Pine received with

Projects, including without limitation, fixed compensation, bonuses, advances,

earnings, fees, royalties, contingent compensation,

17 . allcwances, merchandising
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cqmpensation.
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profit participation Of
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4lwnership interests opmined by
"

Agreement"). Iorined SIR

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'S~t)'seque~tly,Pi~~<

as his "loan out tcimpany"

f~rthe 'purpose of

loaning Pine's acting services to studios, productions companies, networks, etc. Pursuant to the Pine/SDB Implied Agreement, SIR as Pine's loan out company, continuously appropriate 10% commission for all sums and consideration on Commissionable 23. Projects. paid SDB the

that SIR realized for Pine's services

While SDB represented Pine, Pine and SIR typically required the studios to pay

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SOB directly so thafSDB could receive i~s 10% commisslon.
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The requirement
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that

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pay SDB for Pine's and/or SIR's services was typically memorialized agreements with the studios.

in Pine's and SIR's writte

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Realizing Pine's potential as well as Pine's desire to work on projects that were

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COMPLAINT

1

different and not expected of him, SDB sought to expand Pine's acting range. While SDB could

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have capitalized on placing Pine in more romantic comedies, SDB did not want to pigeonhole th young actor. 25. In 2006, SOB assisted Pine in securing a role in Smokin' Aces star studded
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ensemble cast. Pine played Darwin Tremor, a redneck, speed-freak hitman with a penchant for scorched earth tactics. Indeed, a unique and different role for Pine. In 2007, SOB secured a starring role for Pine in the critically acclaimed independent feature, Bottle Shock, which premiered at the Sundance Film Festival and Napa Valley Film Festival.

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In order to further diversify Pine's career, SDB looked beyond the silver screen

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and secured several prominent theatrical roles for Pine. In particular, Pine appeared in a Los Angeles production of Neil LaBute's Fat Pig. SOB's decision to feature Pine on both the stage and the big screen would prove to pay large dividends. Pine's performance caught the attention of a Paramount Pictures executive who attended the production of Fat Pig. Moreover, it just so happened that Paramount would soon be in the market for the next Captain James TvKirk, . .. ,~
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Tbe Star Trek Contract
27. In or around 2007, it was rumored that Paramount Pictures ("Paramount") was going to revitalize ita epic Star Trek franchise by releasing a new and updated Star Trek feature. Due to secrecy surrounded Star Trek
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production, the film was given the fake working title of

Corporate Heqdq~arter~. One of the biggest questions was who was goina to replace William
Shatner and 28.

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~an4the coveted
the next an4 was
.

leading role of Captain James T. K~*

. SDa did llot Wigs a beat. Knowing that the marquee rote of Captain Kirk would level and make Pine a movie star. SDB lobbied Paramount's able to secure an audition for pine. Though. Paramount was initially
,

take Pine's career to casting department,

unsure abOut casting Pine as !<ir~, Paramou~t was convinced to do so a~er a subsequent audition. l\~cordingly, SOB began negotiating the terms of Pine's deal with Paramount. ~ .. ,.
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29.

On. or abou] October 17,2007, SIR, as Pine's loan out company, and Paramount
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services in up to three Star Trek films (the "Star Trek Contract"). Through the Star Trek

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COMPLAINT

Contract, Pine had reached the seven figure plateau and could earn over $5 million in fixed 2 compensation 30. alone. The Star Trek Contract was not only highly lucrative, but entrenched Pine as the In addition to the initial

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leading role of Captain Kirk in the popular Star Trek movie franchise.

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Star Trek film, the Star Trek Contract provided Paramount with options to engage Pine in two
more Star Trek films (the "Star Trek Films"). Pursuant to the Star Trek Contract, Pine and SIR stood to be compensated handsomely if Paramount exercised its options under the Star Trek Contract to make the two additional Star Trek Films. That is, Pine and SIR stood to earn both guaranteed fixed compensation as well as contingent compensation merchandising receipts. based on the Star Trek Paramount agreed to pay

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Films' box office returns and Paramount's

Pine and SIR a guaranteed $1.5 million in fixed compensation

for the second

Star Trek Film (the

first sequel option) and a guaranteed $3 million in fixed compensation Film (the second sequel option).

for the third Star Trek

Moreover, Paramount agreed to pay Pine and SIR up to for the second Star Trek Film and up to $500,000 in

$500,000 in contingent compensation contingent compensation

for the third Star Trek Film based on gross box office receipts. net merchandizin

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Additionally, Paramount agreed to pay Pine and SIR up to 5% of Paramount's

receipts derived from the use of Pine's name, likeness and voice in connection with merchandising 31. deals. In May 2009, Paramount released the heavily promoted Star Trek domestically.

Star Trek was both a commercial and critical success. The film grossed over $75 million
domestically on its opening weekend. box office worldwide. Significantly, the film grossed over $385 million at the

In addition to being praised by the critics, Star Trek was nominated for Pine even was even named as the ShoWest

several awards, including four Academy Awards.

Male Star of Tomorrow based on his role in Star Trek. 32. As required by the Pine/SDB Implied Agreement, Pine paid SDB a 10% that Pine or SIR received from the first Star Trek film.

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commission on all compensation

Furthermore, at no time, at least up until Pine discharged SDB, has Pine expressly or implicitly indicated that SDB was not entitled to its commission on the Star Trek Contract. In fact, the Star

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COMPLAINT

Trek Contract required Paramount to direct all payment to SOB on Pine's andlor SIR's behalf.

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33.

Jack Ryan
In the wake of Star Trek's success in 2009, SDB was offered a series of

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prominent roles. First, Pine was cast opposite Denzel Washington in Unstoppable, an action thriller film directed by Tony Scott. Not only was Pine paid $3 million in fixed compensation for his role in Unstoppable, Pine was afforded "above the title" billing with Denzel Washington. 34. In 2009, SOB also began discussions with Paramount about casting Pine for the Pine was given the

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heroic role of Jack Ryan in the reboot of the Tom Clancy franchise.

opportunity to fill the shoes of Alec Baldwin and Harrison Ford, and play yet another iconic role. Again, SOB assisted in developing the Jack Ryan project for Pine. SDB discussed the various drafts of the film's script with Pine and director Jack Bender, and at Pine's request, gave notes on each draft. 35. On or about December 1,2009, SIR, as Pine's loan out company, and Paramount of Agreement whereby SIR agreed to provide Pine's

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entered into a certain Memorandum

services in up to three films based on Clancy's Jack Ryan character (the "Jack Ryan Contract"). Pine's potential eight figure compensation under the Jack Ryan Contract reflected the stardom Like the Star Trek Contract,

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Pine had achieved and the high price tag that he commanded.

Paramount had the option of making up to three Jack Ryan films (the "Jack Ryan Films"). Paramount agreed to pay Pine fixed compensation in the amount of $4 million for the first Jack Ryan Film, $8 million for the second Jack Ryan Film, and $12 million for the third Jack Ryan Film. Accordingly, excluding contingent compensation, SDB had positioned Pine to earn up to Moreover, Pine stood to earn

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$24 million in fixed compensation

under the Jack Ryan Contract.

between 5% and 10% of the Jack Ryan Films' adjusted gross receipts after breakeven as well as 10% of merchandising receipts.

This Means War
36. Based on the success of Sta~ Trek and Unstoppable, in or around 2010, Pine was leading role opposite Reese Witherspoon in the film This Means War.

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cast in a seven-figure 37.

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On or about August 6, 2010, SIR, as Pine's loan out company, and Fox U.S.

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COMPLAINT

Productions ("Fox") entered into a certain Agreement whereby SIR agreed to provide Pine's 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 28 40. acting services in the film This Means War (the "TMW Contract"). Pursuant to the TMW Contract, Paramount agreed to pay Pine, through SIR, $S million in fixed compensation, up to $1 million in deferred compensation based on This Means War's box office receipts, and contingent compensation equaling 5% of certain defined gross proceeds from This Means War. Additionally, Pine, through SIR, was entitled to a 10% merchandising royalty on certain net merchandising receipts from This Means War. 38. Production on This Means War was completed and the film is targeted to be

released in February 2012. 39. Though Fox has paid Pine and SIR $5 million in fixed compensation under the

TMW Contract, to date, Pine has only paid SDB commissions totaling $392,439.88, leaving a deficiency of $107,560.12 based on the 10% commission Pine and SIR agreed to pay SDB. This does not include the commissions that Pine and SIR must pay to SDB for future compensation earned under the TMW Contract, including deferred compensation, contingent compensation and merchandising royalties. Welcome To People In or around 2010, Pine was given the opportunity to play the leading role in

Welcome To People, a lower budget independent film. Welcome To People was a serious and dramatic role that would allow Pine to showcase his range as an actor. Creatively, Welcome To People was precisely what Pine was looking for. 41. On or about November 10, 2010, SIR, as Pine's loan out company, and Dream

Works II Productions Co., LLC ("Dream Works") entered into a certain Actor Agreement whereby SIR agreed to provide Pine's acting services in the film Welcome To People (the "WTP Contract"). Pursuant to the WTP Contract, Dream Works agreed to pay Pine, through SIR, $750,000 in fixed compensation, and up to $4.25 million in bonuses based on Welcome To People's gross box office receipts. Because of Welcome To People's lower budget, however, Pine would need to sacrifice guaranteed upfront compensation in exchange for a larger backend deal. Accordingly, Pine was to be rewarded financially if Welcome To People was successful.

10 COMPLAINT

42. 2

Production on

Welcome to People was completed and the film is targeted to be

released in February 2012. 43. Though Dream Works has paid Pine and SIR $750,000 in fixed compensation on that fixed

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under the WTP Contract, to date, Pine has failed to pay SOB any commissions compensation,

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leaving a deficiency of $75,000 based on the understood industry standard 10%

commission Pine and SIR agreed to pay SDB. This does not include the commissions that Pine and SIR must pay to SOB for future compensation earned under the WTP Contract, including bonuses.

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Pine Discharges SDB
44. On November 11, 2011, after over nine years of representing Pine as his talent

agency, Pine discharged SOB by email. SDB has not heard from Pine since. 45. On or about November 22,2011, SOB sent Pine a letter (the "Protection Letter") on money or other

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confirming Pine's continued obligation to pay SOB commissions consideration earned on Commissionable Projects.

Specifically, the Protection Letter confirmed

Pine's continued obligation to pay SOB a 10% commission on any sums or other consideration received by Pine (or for Pine's account), including future payments, with respect to all commissionable engagements (including renewals and options that are exercised or contracts tha

have been renegotiated)

that SOB participated in obtaining for Pine and/or offered to Pine and/or

initiated while represented by SDB. The Protection Letter further informed Pine that he currently owed SDB commissions with respect to

This Means War and Welcome To People.

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Finally, the Protection Letter requested that that Pine confirm in writing his intent to pay SOB commissions related to any of the Commissionable Projects identified in the Protection Letter.

The Protection Letter requested that Pine respond by December 1, 20 II. 46. Despite the Protection Letter's request that Pine respond by December 1, 2011, have ever had the courtesy of responding.

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neither Pine nor Pine's representatives

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Paramount's
47.

Exercise of the First Seguel Option under the Star Trek Contract

,

.:,

On or about April 29, 2011, Paramount exercised its first sequel option under the

Stark Trek Contract to engage Pine's acting services in a second

Star Trek Film.

11 COMPLAINT

48. 2

On or about December 12, 20 II, Paramount notified Pine in writing that the

second Star Trek Film's start date was scheduled for January 12,2012. 49. Upon information and belief, the second Star Trek Film began production, and

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that pursuant to the Star Trek Contract, Paramount has paid Pine and/or SIR at least some fixed compensation 50. for Pine's acting services on the second Star Trek Film. To date, Pine and SIR have failed to pay SOB any portion of the commission they have earned from the second Star Trek Film.

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based on compensation

FIRST CAUSE OF ACTION (For Breach of the Pine/SDB Implied Agreement 51.

by SDB Against all Defendants)

SDB realleges herein by this reference each and every allegation contained in

paragraphs 1 through 50, inclusive, of this Complaint as if set forth fully herein. 52. SOB and Pine entered into the Pine/SDB Implied Agreement whereby SOB's,

Pine's and SIR's conduct demonstrated and confirmed that SOB would continue representing Pine and that Pine would continue to pay SDB an industry standard 10% commission on any sums (including renewals and options that are exercised or contracts that have been renegotiated) or other consideration 53. that Pine received with respect to all Commissionable Projects.

IS
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SOB has performed certain services for Pine, including without limitation, on various Commissionable

assisting Pine in procuring or attempting to procure employment Projects.

In tum, SOB has duly performed all of the conditions, promises and covenants which

the Pine/SOB Implied Agreement required it to perform, except those obligations SOB was prevented or excused from performing. 54. Pine and SIR breached the Pine/SDB Implied Agreement by failing to pay SDB Projects.

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the agreed upon 10% on certain Commissionable 55.

In particular, Pine and SIR were required to pay SOB a 10% commission on the that Pine and SIR eamed from the TMW Contract to date. Pin leaving a deficiency

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$5 million in fixed compensation

and SIR, however, have only paid SOB commissions totaling $392,439.88, of$107,560.12

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based on the 10% commission Pine and SIR agreed to pay SDB. This does not

12 COMPLAINT

include the commissions 2

that Pine and SIR must pay to SOB for future compensation contingent compensation

earned and

under the TMW Contract, including deferred compensation, merchandising 56. royalties.

3

4 5
6
7

Moreover, Pine and SIR were required to pay SOB a 10% commission on the that Pine and SIR earned from the WTP Contract to date. Pine, leaving a

$750,000 in fixed compensation

however, has failed to pay SOB any commissions on that fixed compensation,

deficiency of $75,000 based on the 10% commission Pine and SIR agreed to pay SOB. This does not include the commissions that Pine and SIR must pay to SOB for future compensation

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earned under the WTP Contract, including bonuses.

57:'
in

FinaJl~, upon information and belief, the second Star Trek Film began production 2012, and that pursuant to the Star Trek Contract, paramount has paid

January

Pine and/or SI

some fixed

compensation for Pine's acting services on that film. To date, Pine and SIR have

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16
17 ,

failed to pay SOB earned from

any

portion of the 10% commission based on fixed compensation

they have

the second Star Trek Film.
. As a 4irect andproximate result of Pine's and S{R's breach of the Pine/SOB
SDB has suffered damages in an amount in excess of the minimum

'S.

Implied Agreement, jurisdictional

limits of this Court, according to proof at trial.

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SECOND CAUSE OF ACTION (For Declaratory Relief by SDB Against all Defendants)

S9.
paragraphs 60.

~D13 realleges 1 through
Anactual

herein by this reference each and every allegation contained in

58, inclusive, of this Complaint as

if set forth fully herein.

cOntr~versy has arisen and now exists between SOB, on the one hand,

and Pine and SIR; on the other hand, concerning their respective rights and duties under the Pine/SO}3 Implied Agreement in that SDB contends that it is still entitled to be paid the full 10% commission on any sums or other consideration received by Pine or SIR (or for their account), including future payments, with respect to all Commissionable limitation, the following Commissionable Projects: Projects, including without

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13 COMPLAINT

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15 16 17 18 19 61.

• • • • • • • • • • • • • • • • • • • • • • • • •

Any STAR TREK sequels Any JACK RYAN film, including sequels THIS MEANS WAR WELCOME TO PEOPLE. RISE OF THE GUARDIANS A FEW GOOD MEN HAMLET A TIME TO KILL SWEET BIRD OF YOUTH TRIPLE NINE THE ART OF MAKING MONEY UNTITLED RON POPEIL PROJECT HARD LUCK UNTITLED STEVE MCQUEEN BIOGRAPHY THE INFILTRATOR THE BLADE ITSELF UNTITLED STEPHEN GAGHAN PROJECTS THE BEST MAN, INC. WINTER HILL THE LAST DAYS OF AMERICAN CRIME SEXUAL PERVERSITY IN CHICAGO NESS/CAPONE WINTER'S TALE WEIRDO XOXO

That is, pursuant to the Pine/SOB Implied Agreement, SOB is entitled to a 10%

commission on any future monies, properties, compensation or other valuable consideration of any kind or character, including without limitation, fixed compensation, guaranteed compensation, earnings, fees, royalties, contingent compensation, bonuses, advances, allowances, merchandising compensation, profit participation or ownership interests that Pine or SIR obtain at any time in the future with respect to any of the Commissionable Projects. This

20 21 22 23 24 25
t:
!'

includes without limitation, the following: (I) all future fixed compensation, contingent compensation, and merchandising royalties earned by Pine and/or SIR related to any Star Trek Films or the amounts of compensation identified in the Star Trek Contract; (2) all future fixed compensation, contingent compensation, and merchandising royalties earned by Pine andlor SIR related to any Jack Ryan Films or the amounts of compensation identified in the Jack Ryan Contract; (3) all future fixed compensation, deferred compensation, contingent compensation,

i:
L

26 27

28

14 COMPLAINT

--l

r
and merchandising 2 3 4 royalties earned by Pine and/or SIR related to any This Means War or the identified in the TMW Contract; and (4) all future fixed compensation

amounts of compensation

or bonuses earned by Pine and/or SIR related to Welcome To People or the amounts of compensation 62. identified in the WTP Contract Upon information and belief, Pine and SIR dispute that they owe SDB any Projects.

5
6

commissions on future amounts earned by Pine with respect to Commissionable

7
8 9 10 11 12 13 14 15 16 17 18

63.
circumstances

A judicial declaration is necessary and appropriate at this time under the so that SDB may ascertain its rights and duties under the Pine/SOB Implied

Agreement, in particular whether Pine and SIR are required to continue paying SOS a 10% commission on any sums or other consideration received by Pine or SIR (or for their account), including future payments, with respect to all Commissionable 64. Projects

Accordingly, PHPW seeks a declaration that pursuant to the Pine/SDB Implied

Agreement, Pine and SIR are required to continue paying SO B a 10% commission on any sums or other consideration received by Pine or SIR (or for their account), including future payments, Projects.

with respect to all Commissionable

THIRD CAUSE OF ACTION (For an Accounting by SDB Against Pine)
65. paragraphs 66. Commissionable 67. SOB realleges herein by this reference each and every allegation contained in 1 through 65, inclusive, of this Complaint as if set forth fully herein. Pine and SIR have derived substantial sums or other consideration Projects. Pursuant to the terms of the Pine/SOB Implied Agreement, SOB is entitled to a resulting from

19
20 21

22
23

24
25
!I

10% commission on any sums or other consideration that Pine or SIR receives with respect to all Commissionable Projects. Pine and SIR, however, failed and continue to fail to pay SDB Projects.

!' i. !'
I: I:

26 27 28

commissions on Commissionable 68.

Upon information and belief, a full and complete accounting of all sums and Projects will demonstrate what

consideration that Pine and SIR realized from Commissionable

15 COMPLAINT

----------1

additional monies are due and owing SDB from Pine and SIR. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
t
,

69.

The amount of money due from Pine and SIR to SDB cannot be ascertained

without a full and complete accounting of sums and consideration realized by Pine and SIR. Pine and SIR have access to such information, but this information has not been and will not be provided to SDB. Moreover, SOB does not and will not have access to such information. 70. Upon information and belief, the amount determined to be due to SDB from Pine

and SIR will exceed the minimum jurisdictional requirements of this Court. 71. An order from the Court is required for Pine and SIR to provide a full accounting Project on a

of all sums and consideration they received in connection with any Commissionable moving forward basis. WHEREFORE, of them, as follows: ON THE FIRST CAUSE OF ACTION 1.

SDB prays for judgment in their favor against the defendants, and each

For damages in an amount in excess of the Court's general jurisdiction, to be proven at the time of trial;

2. 3. 4.

For pre-judgment interest at the maximum rate permitted by law; For the costs of suit incurred herein; and For such other and further relief as this Court may deem just and proper.

ON THE SECOND CAUSE OF ACTION 1. For a declaration that pursuant to the Pine/SOB Implied Agreement, Pine and SIR are required to continue paying SOB a 10% commission on any sums or other consideration received by Pine or SIR (or for their account), including future payments, with respect to all Commissionable 2. 3. For the costs of suit incurred herein; and For such other and further relief as this Court may deem just and proper. Projects;

,
t;

I I

26 27 28

~,
I;

ON THE THIRD CAUSE OF ACTION 1. For an accounting between SDB and Pine and SIR;

r

I

16 COMPLAINT

.. •

l

2. 2
3
4

For payment to SDB of the amounts due from Pine and SIR as a result of the accounting;

3.
4.

For pre-judgment interest at the maximum rate permitted by law; For costs of suit incurred herein; and For such other and further relief as the Court may deem just and proper.

5
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

5.

Dated: February 13,2012

Bryan J. Freedman Jesse A. Kaplan Attorneys for Plaintiff SOB Partners, Inc.

21
22 23 24 25
t
i

,

I
I

26

!:
!.

I;

27
28

17 COMPLAINT

~

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FOR

r::;::.:::~:;vrO;;;RD:PA"R;;:TY;;W:MliTiTH:;rO;;;UTT AAiTTrToniR~N;;;:eY;:(;;;N=am~8. number. and IIddress): Bar

J. Freedman, Esq. (SBN: 151990) Jesse A. Kaplan, Esq. (SBN: 255059) Freedman & Taitelman, LLP 1901 A venue of the Stars, Suite 500

SUPERIOR COURT OF CALIFORNIA COUNTY OF I_OS ANGELES

FILED

Los Angeles,
TELEPHONE

CA
NO.:

90067
(31

201-0005
COUNTY OF

FEB 1 4 ZOlZ
John

SUPERIOR COURT Of CALifORNIA,
STREET ADDRESS: MAILING ADDRESS: CITY AND ZIP CODE: BRANCH:

Los Angeles ?0012-3014
Distri

same

111 N. Hill St.

BY~~'T~~~

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CIVIL CASE COVER SHEET
Unlimited

0

Limited

o

Complex Case Designation Counter Joinder Filed with first appearance by defendant . Rutes of Court, rule 3.402)

0

CASE NUMBER:

JUOGE:

1. Check one box below for the case type that best describes this case:
Auto Tort Auto (22) Uninsuredmotorist (46) Other PUPDIWD(Personal Injury/Property DamagelWrongful Death) Tort

o o

o Asbestos o Producillability D Medicalmalpractice o Other PIIPDIVVD
(04) (24)

Contract Breach of contractlwarranty(06) Rule 3.740 collections (09) Other collections(09) Insurancecoverage(1S)

W D D

(45) (23)

Non-PI/PDIWD(Other) Tort BusinesslorVunfairbusiness practice (07)

o Civil rights o o

Defamation(13) Fraud(16) Intellectualproperty(19) Professionalnegligence(25) Other non-PIIPDIVVD (35) lort Employment Wrongfultermination(36) Other employment(15)

o o o

Other contract (37) Real Property Eminentdomainllnverse condemnation(14) Wrongful eviction (33) Other real property (26)

E3
0

o o o

D D D

0

0

Provisionally Complex Civil LItigation (Cal. Rules of Court, rules 3.400-3.403) AntitrusVTraderegulation (03) Constructiondefect (10) Mass tort (40) Securilies litigation (28) Envlronmentatrroxictort (30) Insurancecoverageclaims ariSingfrom the above listed provisionallycomplexcase
types (41)

(OS)

o o o

Unlawful Detainer Commercial(31) Residential(32) Drugs (38) Judicial Review Asset forfeiture(05) Petillon re: arbitrationaward (11) Writ of mandate (02) Other judicial review(39)

0 0 0

Enforcement of Judgment Enforcementof judgment (20) Miscellaneous Civil Complaint

o
o o

0

o RICO (27) o Other complaint

(not speCified above) (42)

0 0

Miscellaneous Civil Petition Partnershipand corporategovemance(21) Other petition (not specified above) (43)

2. This case Is [X] is not complex under rule 3.400 of the Catifornia Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management: a. Large number of separately represented.parties d. Large number of witnesses b. Extensive motion practice raising difficult or novel e. Coordination with related actions pending in one or more courts issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court c. Substantial amount of documentary evidence f. Substantial postjudgment judicial supervision 3. Remedies sought (check a/l that apply): a. monetary b. nonmonetary; declaratory or injunctive relief c. punitive

0

0

0 0

0 0

0

00

00

0

0

4. Number of causes of action (specify): 1) Breach of Implied Contract; 5. This case is [][] is not a class action suit.

0

2) Dcelaratory

Relief;

and

3)

Accounting

6. If there are any known related cases, file and serve a notice of related ca Date: February 13,2012 Bryan J. Freedman. ESQ.

r: NOTIC r :Plaintiff must file this cover sheet with the first paper filed in the action or proceeding

(TYPE OR PRINT NAME)

(except small 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 California 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.
Pa .1012

Form Adopted 10< Mand810ry Use Judlcisl Council of telitornis 10 IRev. July 1. 20071

CIVIL CASE COVER SHEET

eM-a

~ cal. Rules of Court. rules 2.30.3.220.3.400-3.403.3.740; So ut gns' tel. Siandards of Judicial Adn'inislreUon. std. 3.10 ~ )lus

..

_--_.- --_

...

---_ ..

r--------.-.

-.--

.- ..... -....

_.

__ ._------------CM-010

'-:.,_~.

_"

INSTR_IONS

ON HOW TO COMPLETE THE

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 tile, 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 time-for-service 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 service 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 Califomia 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 deslqnatlon, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that the case is complex. CASE TYPES AND EXAMPLES Auto Tort Auto (22}-PersonallnjurylProperty Damage/Wrongful Death Uninsured Motorist (46) (if the case involves an uninsured motorist claim subject to arbitration, check this item instead of Auto) Other PIIPDJWD (Personallnjuryl Property DamageIWrongful 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 PJlPDIWD (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 PIIPDIWD Non·PIIPDIWO (Other) Tort Business TOl1IUnfairBusiness Practice (07) Civil Rights (e.g.• discrimination, false arrest) (not civil harassment) (08) Defamation (e.g., slander. libel)
(13)

CaR

SHEET

Fraud (16) Iniellectual Property (19) Professional Negligence (25) ~: Legal Malpractice Other Professional Malpractice (not medical or legal) Other Non-PIIPDIWD Tort (35) Employment Wrongfui Termination (36) Other Employment (15)

!:

Contract Breach of ContractlWarranty (06) Breach of RentaVlease Contract (not unlawful detainer or wrongful eviction) ContractlWarranty Breach--Seller Plaintiff (not fraud or negligence) Negligent Breach of ContractJ Warranty Other Breach of Contract/Warranty Collections (e.g., money owed, open book accounts) (09) Collection Case-Seller Plaintiff Other Promissory Note/Collections 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 tiUe) (26) Writ of Possession of Real Property Mortgage Foreclosure QuletTltie Other Real Property (not eminent domain, landlordAenant, or foreclosure) Unlawful Detainer Commercial (31) Residential (32) Drugs (38) (if the CBseinvolves illegal drugs, check this item; otherwise, report as Commercial or Residential) Judicial Review Asset Forfeiture (05) Petition Re: Arbitration Award (11) Writ of Mandate (02) Writ-Administrative Mandamus Writ-Mandamus on limited Court case Malter 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) AntitrusVTrade Regulation (03) Construction Defect (10) Claims Involving Mass Tort (40) Securities Litigation (28) Environmentalrroxlc 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·tortlnon-complex) Other Civil Complaint (non-tor1lnon-complex) Miscellaneous Civil Petition Partnership and Corporate Governance (21) Other Petition (not specified above) (43) Civil Harassment Wor1<placeViolence ElderlDependent Adult Abuse Election Contest Petition for Name Change Petition for Relief from Late Claim Other Civil Petillon
Pave 2 012

CM-Ol0

IRev. July 1. 20071

CIVIL CASE COVER SHEET

• SDB v, Pine

'1

SHORTTITlE:

I

CASE NUMBER

I

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?

CXJ

YES CLASS

ACTION?

0

YES

LIMITED

CASE?

0

YES TIME ESTIMATED

FOR TRIAL3~__.D_

.... ....,O"",U"""R::;::Su./CXJ..<;X H ......D","A:u.Y""S

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

Step 1: Step 2: Step 3:

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 Civil Case Cover Sheet case type you selected. Check.2!!.! Superior Court type of action in Column

B below which

best describes the nature of this case.

In Column C, circle the reason for the court location choice that applies to the type of action you have checked. For any exception to the court location, see Local Rule 2.0.

I Applicable
1. 2. 3. 4. 5.

Reasons for Choosing Courthouse Location (see Column C below)
Location Location Location Location 10. Location 6. 7. 8. 9. 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

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.

Auto (22) Uninsured Motorist (46)

o o
o o

A7100 A7110 A6070 A7221 A7260 A7210 A7240 A7250 A7230 A7270

Motor Vehicle - Personallnjury/Property DamagelWrongful Death PersonallnjurylPropertyDamageM'rongful Asbestos Property Damage Asbestos - PersonallnjuryM'rongful Death Death-Uninsured Motorist

1.,2 .. 4.
1.,2.,4.

Asbestos (04) Product Liability (24) Medical Malpractice (45)

2. 2. 1.• 2.,3 .• 4.,8. 1.. 4.
1.. 4. 1.. 4. 1.• 4.

o o o

Product Liability (not asbestos or toxic/environmental) Medical Malpractice - Physicians & Surgeons Other Professional Health Care Malpractice Premises Liability (e.g.• slip and fall) Intentional Bodily Injury/Property DamageM'rongfuI Death (e.g., assault, vandalism, etc.) IntentionallnflictJon of Emotional Distress Other Personal Injury/Property DamageM'rongful Death

Other Personal Injury Property Damage Wrongful Death

o

t: ,
LACIV 109 (Rev. 03(11)

,

(23)

D A7220

o o

1.. 3. 1.. 4.

LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0 Page 1 of 4
LAoCV109

I

SHORT TITLE:

SOB v. Pine

~1:
II)

Business Tort (07) Civil Rights (OB) Defamation (13) Fraud (16)

0 0.10.1:

o

AB029 Other Commercial/Business A6005 Civil Rights/Discrimination A6010 Defamation (slanderllibel) A6013 Fraud (no contract) A6017 Legal Malpractice

Tort (not fraud/breach of contract)

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

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

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Professional Negligence (25) Other (35)

1.,2.,3.

~21

A6050 Other Professional M"lnr ••

cli,,..

1.,2.,3.
2.,3. 1.,2.,3. 1.,2.,3. 10. 2.,5. 2.,5.

A6025 Other Non-Personal Injury/Property Damage tort AB037 Wrongful Termination A6024 Other Employment Complaint Case A6109 Labor Commissioner Appeals A6004 Breach of Renlaillease eviction) A600B ContractlWarranty Contract (not unlawful detainer or wrongful

C GI E
0

Wrongful Termination (36)

>. Other Employment (15)

is. E w

Breach of Contracll Warranty (06) (not Insurance)

D A6019

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

Negligent Breach of ContracllWarranty

AB028 Other Breach of ContractlWarranty Collections Case-Seller Plaintiff

(not fraud or negligence)

1.G@
2.,5.,6. 2.,5. 1.,2.,5.,8. 1.,2.,3.,5. 1.,2.,3.,5. 1.,2.,3., B.

1.,2.,5.

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0

III

C
(J

..

Collections (09)

D AB012

D A6002

Other Promissory Note/Collections Case

Insurance Coverage (18)

o

AB015 Insurance Coverage (not complex) Contractual Fraud Tortlous Interference

Other Contract (37)

D AB009 D AB031

o
o
o o

AB027 Other Contract Dlspute(not breachlinsurance/fraud/negllgence)

Eminent Domain/Inverse Condemnallon (14) Wrongful Eviction (33)

A7300 Eminent DomalnJCondemnation Wrongful Eviction Case

Number of parcels

_

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

D A6023

o

AB018 Mortgage Foreclosure A6032 Quiet Title AB060 Other Real Property(notemlnentdomain,landlordltenant, AB021 Unlawful Detainer-Commercial A6020 Unlawful Detainer-Residential

Other Real Property (26)

'U'~"'''''i>U'''1I 2., 6.
2.,6.
2.,6.

Unlawful Detainer-Commercial (31) Unlawful Detainer-Residential

o

(not drugs or wrongful eviction) (not drugs or wrongful eviction)

(32)

o
o

Unlawful Detain Post-Foreclosure Unlawful Detainer-Drugs (38)

A6020F Unlawful Detainer-Posl-Foreclosure Unlawful Detainer-Drugs

2.,6. 2.,6.

D A6022

LACIV 109 (Rev. 03/11) LASe Approved 03-04

CIVIL CASfi:COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

local

Rule

2.0

Page 2 of4

-------------

II

.,

"

I

SHORT TITLE:

SOB v. Pine

I
D A6108
Asset Forfeiture Case

CASE NUMBER

Asset Forfeiture (05)

2., S. Arbitration 2.,5. 2., B. 2. 2. 2., B. 1.,2 .• B. 1.,2.,3. 1.,2., B. 1.,2., B. 1.,2.,3., (complex case only) 1.,2,,5., 2.• 9. 2.,6, 2.,9. 2., B. B. B.

a::
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CII

~

Petition re Arbitration (11)

o o o o o o

A6115 Petition to CompeliConfirmNacate Writ - Administrative Mandamus

D A6151
Writ of Mandate (02) Other Judicial Review (39)

"ti

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:3

A6152 Writ - Mandamus on Limited Court Case Matter A6153 Writ - Other Limited Court Case Review A5150 Other Writ /Judlclal Review A6003 AntitrusVTrade Regulation AS007 Construction Defect AS006 Claims Involving Mass Tort A6035 Securities Litigation Case Toxic TortlEnvironmental

.2

e Regulation (03) Construction Defect (10) Claims Mass Tort

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C. E
Ci e

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0

0

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Securities Litigation (28) Toxic Tort Environmental (30) Insurance Coverage Claims from Complex Case (41 )

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D A6036

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0

Enforcement of Judgment (20)

o o o o

AS014 Insurance Coverage/Subrogation AS141 Sister State Judgment A6160 Abstract of Judgment

A6107 Confession of Judgment (non-domestic relations) Administrative Agency Award (not unpaid taxes) for Entry of Judgment on Unpaid Tax

D A6140

RICO (27)
UI.!i

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Other Complaints (Not Specified Above) (42)

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A6114 PelitionlCertlflcate

2.,8. 2., B., 9.
1.,2.,8. 1.,2.,8. 2.,8. 1.,2.,8 . 1.,2., B. 2., B. 2.,3.,9. 2.,3.,9. 2.,3.,9. 2. 2.,7. 2.,3.,4.,8. 2.,9.

AS112 Other Enforcement of Judgment Case A6033 Racketeering (RICO) Case AS030 Declaratory Relief Only A6040 Injunctive Relief Only (not domestlclharassment) A6011 Other Commercial Complaint Case (non-tortlnon-complex) A600D Other Civil Complaint (non-tortlnon-complex) Partnership and Corporate Governance Case

Partnership Corporation Governance (21)

D A6113

UI III

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2

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Other Petitions (Not Specified Above) (43)

I:

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A6121 Civil Harassment A6123 Workplace Harassment A6124 Elder/Dependent Adult Abuse Case A6190 Election Contest AS11 D Petition for Change of Name A6170 Petition for Relief from Late Claim Law A6100 Other Civil Petition

LACIV 109 (Rev. 03/11) LASe Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0
Page 3 of4

'"

."

I

.
SDB v. Pme

SHORTTITlE:

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 Col umn C for the type of action that you have selected for this case.

1801 A venue of the Stars

01.002.03.04.005.06.07.08.09.010.
CITY: STATE: ZIP CODE:

Los Angeles

CA

90067 Los Angeles Superior
courthouse in the

Item IV. Declaration of Assignment: 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

Central

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

Rule 2.0, subds. (b), (c) and (d)).

Dated: February 12, 2012

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 1. Original Complaint or Petition. 2. If filing

a Complaint, a completed Summons form for issuance by the Clerk.

3. Civil Case Cover Sheet, Judicial Council form CM-010.

4. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.
03/11 ).
5.

Payment in full of the filing fee, unless fees have been waived. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a minor under 18 years of age will be required by Court in order to issue a summons. Additional 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.

6. 7.

,
I,

<,

\:

I'

LACtV 109 (Rev. 03/11) LASe Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0 Page 4 of4