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1s 16 " 18 19 20 au Devin A. McRae, SBN 223239 CONFORMED COPY dmerae@earlysullivan.com org QGRAL FINED Peter D. Scott, SBN 247786 Pa EE pscott@earlysullivan.com wnac EARLY SULLIVAN WRIGHT AUG 192015 GIZER & MCRAE LLP 6420 Wilshire Boulevard, 17" Floor Sherri R. Carter, Executive Oficer/Clerk| Los Angeles, California 90048 By: Shaunya Bolden, Deputy Telephone: (323) 301-4660 Facsimile: (323) 301-4676 Attomeys for Plaintiff SHANNEN DOHERTY SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES — CENTRAL DISTRICT caseNo,__BC5 91881 SHANNEN DOHERTY, an individual, | Plaintiff, | COMPLAINT FOR DAMAGES FOR: | v, 1) BREACH OF CONTRACT; TANNER MAINSTAIN GLYNN & 2) BREACH OF THE IMPLIED JOHNSON, LLP, a California limited COVENANT OF GOOD FAITH liability partnership; AND FAIR DEALING; STEVEN D. BLATT, an individual; and DOES | through 20, inclusive, 3) | BREACH OF FIDUCIARY DUTY; Defendants. 4) CONVERSION; 5) NEGLIGENCE; 6) VIOLATION OF CALIFORNIA BUSINESS & PROFESSIONS CODE §§ 17200 ET SEQ; 2 e r CONTRACTUAL INDEMNITY; 8) EQUITABLE INDEMNITY; Py 9) ACCOUNTING 25 6 —_ [DEMAND FOR JURY TRIAL] n EARLY = = | sutuan = | trier COMPLAINT FOR DAMAGES | Guere WHEM | fAcRAE we 875703 10 u 2 13 4 1s 16 0 18 19 20 au 2 23 4 28 26 27 28 EAR | SULLIVAN Plaintiff SHANNEN DOHERTY hereby alleges as follows: INTRODUCTION 1. This is a case about crooked business managers who not only stole from their clients but habitually blundered the most critical tasks of the profession. Defendant Tanner Mainstain |Glynn & Johnson, LLP (“Tanner Mainstain”), before it terminated now disgraced original name partner, Defendant Steven D. Blatt (“Blatt”), was formerly known as, Tanner Mainstain Blatt Glyna |& Johnson, LLP. Tanner Mainstain’s promotional materials specifically target clients in the entertainment industry, tellitig prospective clients they will “enjoy the confidence, convenience and [continuity of having all of their financial matters handled in one place.” They offer “experience,” commitment,” “professionalism,” “stability,” “confidentiality” and “peace of mind” — and a specialization in the entertainment and professional sports industries that allows the firm to turn the “unpredictable income” and “complex tax issues” in these industries into “a lifetime of financial security” by virtue of skilled “careful planning, guided by knowledge and experience.” Blatt, now ]with the financial firm of Squar Milner, similarly promotes his specialization in serving “the needs lof professional athletes, actors and high net worth individuals.” He too understands the “unique challenges faced by entertainment and sports industries,” and develops “strategic plans” to help clients “meet their short and long term financial goals.” 2. Intruth, the firm and former partner Blatt specialize in fleecing actors and entertainment industry professionals. After gaining control of all of their clients’ cash and assets, they find a way to lose it, sometimes by gross incompetence, sometimes by self-dealing and outright theft. Along the way, they habitually deceive their clients, going so far as to set up bogus transactions, to conceal their misdeeds, errors and omissions. ‘The firm has hallmarks of a Ponzi scheme. Rather than a “lifetime of financial security,” clients leave Tanner Mainstain and Blatt (jointly, “Defendants”) with promises broken, tax liens and related penalties, debt they never needed, depressed credit scores, and with the ultimate question: Where did my money go? 4, Plaintiff Shannen Doherty (“Plaintiff”), a successful, well-known actress, is one of these victims who, by this Complaint, seeks redress for the actionable conduct and resultant harm 1 — ‘COMPLAINT FOR DAMAGES wanes 4 15 16 W 18 19 20 2 23 “4 28 26 caused by what should have been, according to Tanner Mainstain’s website, her “most trusted advisor.” PART 5. Plaintiffs, and at all relevant times hereto was, a resident of the County of Los Angeles, State of California, 6 Tanner Mainstain is a California limited liability partnership with its principal place of business at 10866 Wilshire Boulevard 10th Floor, Los Angeles, California 90024-4300, 7. Blatt is, and at all relevant times hereto was, a resident of the County of Los ‘Angeles. 8. Plaintiff is ignorant of the true names and capacities of defendants named herein as Does | through 20, inclusive. Plaintiff is informed and believes, and thereon alleges that Does 1 through 20 are liable, in whole or in part, for the claims asserted in this Complaint against the Defendants. When Plaintiff learns the true identities and capacities of Does 1 through 20, Plaintiff Will seek leave of the Court to amend this Complaint to allege the true names and capacities of Does | through 20, 9. Plaintiff is informed and believes, and thereon alleges, that at all relevant times, each| defendant was the principal, agent, or employee of each other defendant, and acted within the scope lof that relationship. JURISDICTION AND VENUE. 10. This Court has jurisdiction over this dispute and over all causes of action asserted herein pursuant to the California Constitution, Article VI, §10. The amount in controversy, exclusive of interests and costs, exceeds the jurisdictional minimum of this Court. This case involves California residents that conduct substantial operations in this jurisdiction, Each defendan resides in California and has sufficient contacts with Califomia to make proper the exercise of personal jurisdiction over them. 11, Venue is proper in this Court. A substantial part ofthe acts or omissions giving rise {0 the claims alleged occurred in Los Angeles, California, and each defendant resides within the |County of Los Angeles such that this Court is the appropriate venue for this action, COMPLAINT FOR DAMAGES 975703 10 u 12 13 4 15 16 7 18 19 20 aa 2 2B FACTUAL ALL ATIONS, 12. On July 30, 2009, Plaintiff and certain of her related entities, on the one hand, and ‘Tanner Mainstain, on the other hand, entered into a written agreement (the “Agreement”) for the [provision of accounting, business management, tax, payroll, insurance and investment services. A true and correct copy of the Agreement is attached hereto as Exhibit 1, Under the Agreement, Blatt }was to be principally responsible for coordinating and managing all of the services Tanner /Mainstain was required to perform. In consideration of 5% of the income received by Plaintiff for her professional services, Tanner Mainstain essentially assumed exclusive control and responsibility for the management of all of Plaintiff's financial affairs, including the payment of Plaintiff's medical insurance premiums. 13. Plaintiff had previously obtained medical insurance coverage through the Screen [Actors Guild (“SAG”) medical insurance program. Tanner Mainstain, as Plaintiff's business ‘managers, took responsibility for timely payment of Plaintiff's medical insurance premiums Indeed, the medical insurance invoices for Plaintiff were sent by SAG directly to Tanner /Mainstain’s offices for payment. In November 2013, SAG sent the premium invoice to Tanner /Mainstain for Plaintiff's medical insurance coverage for the year 2014, However, Defendants ignored it, failed to pay it (without informing Plaintiff) and then promptly terminated their relationship with Plaintiff effective February 7, 2014. Plaintiff assumed that the medical insurance premiums had been properly paid as Defendants were still responsible for paying them during the relevant time period. Unbeknownst to Plaintiff at the time, Defendants had not paid the required premiums and Plaintiff was left completely uninsured. 14, Plaintiff subsequently discovered that Defendants had failed to pay her insurance premiums and that she was uninsured until the next SAG insurance re-enrollment period for 2015. Pr 2s 26 a EARLY ae | suiuvan mc ene OGM | FecRae uu» Accordingly, during 2014, Plaintiff did not have medical insurance, and thus did not regularly visit a doctor as she normally would have had she been insured. 15. After re-enrolling in the SAG medical insurance program for 2015, Plaintiff began tol regularly see medical professionals. In this regard, in March 2015, Plaintiff discovered that she had| invasive breast cancer metastatic to at least one lymph node. Plaintiff was informed that her cancer 3 ‘COMPLAINT FOR DAMAGES 375703