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Cross-Complainant Sydney Holland (“Sydney”), by and through their undersigned counsel, bring

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this action and allege against Cross-Defendants Shari Redstone (“Shari”), Jeremy Jagiello (“Jagiello”),

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Joseph Octaviano (“Octaviano”), and Giovanni Paz (“Paz”), (collectively, the “Staff Defendants”), as

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follows:

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THE PARTIES

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1. Cross-Complainant Sydney Holland is a natural person residing in the County of Los

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Angeles, California.
2. Cross-Defendant Shari Redstone is a natural person residing in Boston, Massachusetts, who
regularly conducts business in California, frequently visits California, committed the below listed

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tortious acts in California, and otherwise directed her tortious conduct toward Sydney, a resident of Los

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Angeles, California.

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3. Cross-Defendant Jeremy Jagiello is a natural person residing in the County of Los Angeles,
California, who works as Sumner Redstone’s (“Redstone”) lead nurse.
4. Cross-Defendant Joseph Octaviano is a natural person residing in the County of Los Angeles,
California, who works as a nurse for Redstone.
5. Cross-Defendant Giovanni Paz is a natural person residing in the County of Los Angeles,
California, who previously worked as a nurse for Redstone.
6. At all times, each Cross-Defendant acted as an agent for their co-defendants and were acting
in that capacity and are responsible for the acts of each other.
JURISDICTION AND VENUE

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7. Cross-Defendants are subject to personal jurisdiction in Los Angeles County because the acts

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and omissions by Cross-Defendants alleged herein occurred in or caused harm to Sydney in this county.

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8. Venue is proper in Los Angeles County because the events or omissions giving rise to the
claims alleged herein occurred in this county, and the harm alleged herein occurred in this county.

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FACTUAL ALLEGATIONS

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A.

Shari and Redstone have always had a tumultuous relationship.

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9. Redstone’s complaint filed on October 25, 2016 (the “Complaint”) is a byproduct of Shari’s

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concerted efforts to malign and destroy Redstone’s fiancée, Sydney, through various means, including as

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explained below, secretly paying Redstone’s staff to spy on Sydney and invade Redstone and Sydney’s

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privacy, to discover confidential information she could use to oust Sydney from Redstone’s life.

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10. Shari’s surreptitious conduct was hidden from both Redstone and Sydney, and she

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compromised the security of Redstone’s staff to obtain information she could use to attack Sydney. In

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the course of this conspiracy to violate their privacy, Shari also sought and obtained confidential

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information regarding Redstone’s health care treatments. Even worse, she did not seek this information

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out of some heart-felt attempt to improve the outstanding care Redstone was receiving, but rather to

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determine the best time to falsely accuse Sydney of acting improperly in order to remove her from

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Redstone’s life.

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11. It is no secret, that long before Sydney met Redstone, the Redstone family was wrought with

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conflict. At the center of the conflict was the question of who would succeed Redstone after his death.

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For long bouts, Redstone and Shari were estranged because of Redstone’s long-held position that Shari

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was unfit to be his successor. Indeed, in 2007, Redstone made clear to the boards of both Viacom and

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CBS that Shari should not succeed him after his death.

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CROSS-COMPLAINT

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12. Indeed, over the years, Redstone frequently expressed his fundamental disagreements with

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Shari publically. In 2014, while he was dating Sydney, he reaffirmed his wishes and provided Sydney

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with a copy of the following letter so she could ensure his wishes were carried out after his death:

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13. Nevertheless, Shari kept fighting for control of her father’s empire. She knew that the only
thing standing in her way was Redstone himself. That was, until, Redstone fell in love with Sydney.
B.

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Sydney becomes an extension of Redstone and an impediment to Shari’s eventual
empire.

14. For Redstone, beautiful women parading in and out of his life was commonplace. With

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Redstone’s level of success, finding women to offer momentary companionship was not a difficult task.

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Finding someone who he emotionally bonded with, however, was something he had been unable to

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attain. That search ended with Sydney.

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15. Their courtship began in the fall of 2010, when Redstone hired Patti Stanger, “The

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Millionaire Matchmaker®” to find him a girlfriend who was not only young and beautiful, but also

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intelligent, funny, and who shared Redstone’s Jewish faith. Patti knew Sydney was the “perfect match,”

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and contacted her right away.

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16. Almost immediately, the pair hit it off. And by 2011, Redstone proposed to Sydney with a

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beautiful 9 carat yellow canary engagement ring, and asked her to move in with him. She happily

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accepted.

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17. Two years later, Redstone helped Sydney conceive her daughter, and was by Sydney’s side

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when her daughter was born in their home. He repeatedly told Sydney that he wanted to spend the rest

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of his life with her and that he wanted to adopt her daughter. He added her daughter to his Will. He

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assured her that he would take care of them for the rest of their lives. They were, by all accounts, a

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close family unit.

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18. As Redstone’s primary companion, Sydney took on all the duties of a fiancée and eventual

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wife. She also coordinated Redstone’s visits and meetings with Redstone’s business associates, Phillipe

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Dauman, Leslie Moonves, Carl Folta, George Abrams, Ace Greenberg, Tom Dooley, Steven

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Sweetwood, Brad Gray, Leonard Goldberg, Arnold Kopelson, and Robert Evans. Sydney scheduled

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Redstone’s appearances at shareholder meetings, as well as on earnings calls, for Viacom and CBS. She

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even helped Redstone organize a meeting of the entire board at their home in March 2013.

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19. Throughout their entire relationship, Redstone remained very active in the business activities
of Viacom and CBS. He continued in his role as Executive Chairman of CBS and Executive Chairman
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CROSS-COMPLAINT

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and founder of Viacom. In fact, during the time he was with Sydney, Redstone’s contribution to his

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companies was recognized and rewarded by the boards. Redstone’s annual CBS salary increased over

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$100,000 between 2010 and 2012 based on “the Compensation Committee’s evaluation of Mr.

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Redstone’s performance, salary history and appropriate pay levels compared to our other senior

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executives.” His annual salary at Viacom increased a quarter of a million dollars beginning on January

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1, 2014. He also received bonuses above and beyond his projected bonus each year he was with

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Sydney. For example:

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20. Reflecting Redstone’s love and gratitude for Sydney, Redstone added Sydney to his estate

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plan bequeathing her a portion of his estate, amending his 2003 Trust to ensure that she could remain in

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their home after his death, and giving her custody of his dogs, Sugar and Butterfly. He also told his

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estate planning attorney, David Andelman (“Andelman”) that he wanted to marry Sydney and adopt her

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daughter. Redstone shared the following letter with Sydney to keep her up to date on the process:

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CROSS-COMPLAINT

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C.

Shari begins to turn on Sydney.

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21. In the first few years of Sydney and Redstone’s relationship, Sydney worked hard to try to

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bring the feuding family together. Indeed, at first, Sydney had good relationships with nearly all of

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Redstone’s family.

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22. Sydney communicated with the family frequently, and arranged visits and calls from Shari,

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her children, Brandon Korff, Tyler Korff, and Kimberlee Ostheimer, and Redstone’s great-

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grandchildren. The security guest log, for example, indicates at least 16 visits from Shari during 2012-

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2014, which Sydney helped facilitate:

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23. She also invited Shari and her children to gatherings at the house, including Redstone’s 90th
birthday party which Sydney planned and threw for Redstone.

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CROSS-COMPLAINT

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24. And since Shari knew that she had to accept Sydney to have a relationship with her father,

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Shari sought to maintain a respectful, cordial relationship and frequently expressed kind sentiments to

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one another:

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CROSS-COMPLAINT

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25. But Redstone did not trust Shari. Redstone knew that Sydney provided him with

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unconditional love, companionship, comfort, care, assistance, protection, affection, society, and moral

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support throughout their relationship. In turn, he wanted to protect her, as any good partner would. As

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his relationship with Sydney progressed, Redstone became fearful that Sydney’s share in his Will or the

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gifts that he had given her throughout their relationship, might be diluted or eliminated by litigation

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from his family, especially Shari, after his death. Both Redstone and Sydney sensed increasing hostility

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and jealousy from Shari shortly after Sydney’s daughter was born, whom she inevitably saw as an

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additional threat to her eventual multibillion-dollar empire. Shari watched with her very own eyes, her

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father’s growing bond with Sydney and her daughter. She saw what was becoming a tight family bond

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that she always wished for.

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26. In fact, Shari’s hostility and jealousy boiled over in the summer of 2014, when she hired
legal counsel and threatened to sue Sydney and Herzer for “undue influence” over Redstone. Thus, to
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further protect Sydney, and the financial gifts that he had given her, Redstone hired four different legal

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teams to protect the women he cared about most. The additional teams worked alongside Redstone’s

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attorneys, Andelman and Leah Bishop (“Bishop”) to ensure that Redstone’s bequests to Sydney were

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iron-clad and could not be later challenged by Shari. Indeed, Redstone safeguarded his gifts and

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bequests by obtaining certificates of independent approval by independent legal counsel and Redstone’s

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physicians each time he amended his estate plan to confirm and document his capacity. Redstone also

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asked Shari to sign a letter to sign a letter releasing any potential legal claims she had against Sydney. It

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was so important to Redstone that he promised to exclude Shari from his funeral if she refused to agree

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to release any potential claims she had against Sydney:

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CROSS-COMPLAINT

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27. Although Shari knew that all her father wanted was to give him and Sydney peace of mind,

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she coldly refused. Shari was prepared to jeopardize going to her own father’s funeral so that she could

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seek to later pursue a vendetta against Sydney despite the fact that Redstone’s gifts to Sydney were

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made with stringent review and approval by Redstone’s counsel while he was the vibrant Chairman of

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Viacom and CBS. Thus, Shari began to effectuate her plan to intentionally destroy Sydney and

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Redstone’s relationship.

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D.

Shari uses the Staff Defendants to infiltrate Sydney’s home and violate Sydney’s
privacy.

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28. Sydney is informed and believes, and on such information and belief alleges that, in 2013,

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Shari hired a private investigator to surveil Sydney. She hoped to discover something damning about

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Sydney that would cause Redstone to exile Sydney from his life. After the search proved fruitless, Shari

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concocted a plan to use her financial resources and power to infiltrate Sydney and Redstone’s home

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instead; through the Staff Defendants.

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29. On information and belief, in the fall of 2014, Shari first solicited nurse Joseph Octaviano

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(“Octaviano”) to be her key insider. At Shari’s insistence, Octaviano began secretly sharing private on-

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goings in the Redstone residence and reporting to Shari through daily journal entries and e-mails. Shari

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and Octaviano also recruited two other nurses: Giovanni Paz (“Paz”) and Jeremy Jagiello (“Jagiello”) to

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assist them. Paz and Jagiello worked clandestinely like Octaviano.

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30. On information and belief, in direct contravention of the confidentiality and non-disclosure

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agreements the Staff Defendants signed, the Staff Defendants transmitted highly confidential and private

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information to Shari without Redstone or Sydney’s consent, including but not limited to:

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a) secretly taping conversations between Redstone, Sydney and their lawyers;

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b) listening in on Sydney and Redstone’s conversations about marriage and adoption;

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c) documenting Sydney and Redstone’s schedules including when they met with lawyers,

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friends, and colleagues, and who came in and out of the house;

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d) talking about Sydney and Redstone’s sex life;

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e) repeating Sydney and Redstone’s conversations about Redstone’s sensitive medical

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information; and
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f) disclosing details related to Sydney and Redstone’s finances.
31. In short, the Staff Defendants subverted their interest in caring for Redstone–their patient–

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and disregarded the sanctity that Sydney was entitled to in her own home. Instead, they became moles

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for Shari, sharing Redstone’s most sensitive medical information, tracking meetings Redstone and

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Sydney held with lawyers, and disclosing the most intimate details of Redstone and Sydney’s life

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together.

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32. Even after Redstone fired Paz for unrelated reasons, upon Paz’s departure, Shari paid him

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$10,000 for the wealth of inside information that he provided. On information and belief, Shari gave, or

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promised to give, each of the Staff Defendants money in exchange for spying on Redstone and Sydney.

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E.

Shari and the Staff Defendants intentionally interfere with Sydney and Redstone’s
relationship.

33. While Shari and the Staff Defendants have tried to justify their illegal acts as a genuine

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concern for Redstone, the evidence suggests otherwise. Shari made little effort to contact Redstone’s

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primary care physician, only speaking to him a handful of times, while communicating daily with the

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Staff Defendants. Redstone never gave, and Shari never received permission to access his medical

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records. Therefore, she subverted privacy and confidentiality laws by obtaining the information from

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the Staff Defendants.

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34. On information and belief, Shari requested and received detailed summaries of Redstone’s

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most confidential and sensitive medical condition, care, and treatment; information about privileged

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conversations with Redstone’s attorneys regarding matters involving Sydney; and extremely intimate

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details of Redstone and Sydney’s relationship. With this information, Shari sought to gain an advantage

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in her plan to oust Sydney (and her daughter) from Redstone’s life and Will, in order to become

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Redstone’s closest confidant and entrench herself in a position to succeed him in his businesses. The

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Staff Defendants had a huge financial incentive to help.

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35. Evidencing Shari’s ultimate goal, after Sydney left Redstone’s residence in September 2015,

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and Shari took over, Sydney’s attempts to communicate with Sumner were frustrated. Sydney sent

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letters, cards, flowers, and gifts to his home because she wanted to come back. She called the house,

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only to find the line was disconnected and the number changed.
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36. Sydney only later learned that Shari had instructed the Staff Defendants to block Sydney

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from Redstone’s life to ensure that there was no reconciliation. On information and belief, Shari

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instructed security to refuse to let Sydney or her deliveries through. She told the Staff Defendants to

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screen Sydney’s calls and refused to let Redstone speak to her. She filtered Redstone’s mail to make

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sure that Sydney’s heartfelt apologies did not reach him. Of-course, this was devastating for Sydney and

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caused her great distress, anxiety, helplessness, embarrassment, and depression.

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37. But Shari could not risk Sydney getting back into Redstone’s good graces. Redstone had

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promised to take care of Sydney for the rest of her life by making lifetime gifts and including her as a

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beneficiary of his estate plan. She wanted to make sure he would not keep his promises.

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38. On one occasion, however, Redstone successfully bypassed Shari’s controls and he

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immediately arranged a visit with Sydney. During that meeting in late fall 2015, Redstone wanted to

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know why she had an affair. He needed to know what made their relationship fall apart. He missed

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Sydney’s daughter. Sydney jumped at the opportunity to speak with Redstone. However, her attempts

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were once again thwarted by Shari’s meddling. Sydney was escorted to Redstone’s formal living room

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where she found Redstone watching TV. She quickly noticed Shari just an arms-length from Redstone.

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Shari greeted Sydney with a cold stare, ignored Sydney’s effort to exchange pleasantries and refused to

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speak to Sydney’s daughter. When Sydney asked to speak with Redstone privately about their most

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personal matters, Shari refused to go. She sat perched over her father while Sydney profusely

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apologized for the biggest mistake of her life. Shari saw Redstone getting emotional and, fearful he may

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forgive Sydney, pressured Redstone to tell Sydney to leave. Eventually, he did. Tellingly, Redstone

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never mentioned any regret about the gifts he gave to Sydney nor did he ask for his money back.

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39. On information and belief, Shari and the Staff Defendants began to spread lies about Sydney

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to Redstone after her departure from the home to discourage him from making additional attempts to

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meet with Sydney. On information and belief, Shari and the Staff Defendants told Redstone that Sydney

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never loved him, that she purposely took advantage of him, and that she treated him poorly.

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40. Even so, as late as June 28, 2016, a few months before Redstone allegedly filed his

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Complaint against Sydney, Redstone requested a visit with Sydney’s daughter, whom Sydney believes

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still remains in Redstone’s Will, and Redstone loves dearly. Not coincidentally, when Redstone
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requested to see Sydney’s daughter a second time, his requests were ignored, and the Complaint was

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filed.

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41. On information and belief, Shari continues to manipulate Redstone to prevent him from

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providing any financial support to Sydney (or her daughter), including but not limited to telling him to

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take Sydney and her daughter out of his estate plan and filing the Complaint.

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***

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FIRST CAUSE OF ACTION

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(Common Law Violation of Privacy: Intrusion into Private Affairs - All Defendants)

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42. Sydney incorporates by reference the allegations set forth in paragraphs 1 through 41 above

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as if fully stated herein.
43. Sydney maintained an objectively reasonable expectation of privacy with respect to activities
and conversations in her residence, which she shared with Redstone from 2011 through 2015.
44. Shari and the Staff Defendants intentionally intruded into places in which Sydney had an

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objectively reasonable expectation of privacy, by among other things, secretly taping conversations

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between Redstone, Sydney and their lawyers; listening in on Sydney and Redstone’s conversations

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about marriage and adoption; documenting Sydney and Redstone’s schedules including when they met

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with lawyers, friends, and colleagues, and who came in and out of the house; talking about Sydney and

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Redstone’s sex life; repeating Sydney and Redstone’s conversations about Redstone’s sensitive medical

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information; and disclosing details related to Sydney and Redstone’s finances.

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45. Shari and the Staff Defendants’ invasion of Sydney’s privacy is highly offensive to a

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reasonable person, especially to the extent that information regarding Sydney’s most private affairs was

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shared with third-parties. As a result, Sydney experienced great distress, anxiety, helplessness,

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embarrassment, and depression.

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46. Shari and the Staff Defendants’ invasion of Sydney’s privacy, and subsequent disclosure of

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Sydney’s private information, was a substantial factor in the harm and emotional distress suffered by

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Sydney including, but not limited to, the loss of Sydney’s partnership with Redstone the loss of

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Redstone’s bequests to Sydney in his estate plan.

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47. By virtue of the wrongful conduct alleged above, Shari acted with malice, fraud, and
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oppression and is liable for punitive damages in an amount to be determined at trial.

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SECOND CAUSE OF ACTION

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(Common Law Violation of Privacy: Aiding and Abetting — Shari Redstone)

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48. Sydney incorporates by reference all of the allegations set forth in paragraphs 1 through 47
above as if fully stated herein.
49. Shari knew that Sydney’s privacy was being invaded by the Staff Defendants, indeed, it was

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Shari’s idea. Shari directly encouraged and supported the Staff Defendants in their efforts to invade

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Sydney’s privacy.

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50. Without Shari’s encouragement, direction, and money, the Staff Defendants would not have
invaded Sydney’s privacy and reported the information obtained through privacy breaches to Shari.
51. By virtue of her wrongful conduct alleged above, Shari acted with malice, fraud, and
oppression and is liable for punitive damages in an amount to be determined at trial.

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THIRD CAUSE OF ACTION

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(Common Law Violation of Privacy: Conspiracy - All Defendants)

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52. Sydney incorporates by reference all of the allegations set forth in paragraphs 1 through 51
above as if fully stated herein.
53. Shari and the Staff Defendants agreed to work together to invade Sydney’s right to privacy in
her own home.
54. The Staff Defendants, at Shari’s direction, worked together to implement a scheme to

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eavesdrop on and surveil Sydney in her own home, and report their discoveries to third-parties without

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Sydney’s consent.

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55. Shari and the Staff Defendants invasion of Sydney’s privacy, and subsequent disclosure of

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Sydney’s private information to third-parties, was a substantial factor in the harm and emotional distress

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suffered by Sydney including, but not limited to, the loss of Sydney’s partnership with Redstone the loss

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of Redstone’s bequests to Sydney in his estate plan.

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56. By virtue of the wrongful conduct alleged above, Shari acted with malice, fraud, and
oppression and is liable for punitive damages in an amount to be determined at trial.

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FOURTH CAUSE OF ACTION

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(Breach of Contract — Staff Defendants)

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57. Sydney incorporates by reference all of the allegations set forth in paragraphs 1 through 56
above as if fully stated herein.
58. The Staff Defendants entered into written confidentiality and non-disclosure agreements with

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Redstone by which the Staff Defendants agreed not to disclose information learned through the course

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of their employment to third-parties.

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59. As a resident of Redstone’s home, Sydney was intended to be, and was, a third-party
beneficiary of the confidentiality and non-disclosure agreements.
60. Redstone fulfilled all obligations under the confidentiality and non-disclosure agreements,
and the Staff Defendants are not excused from performance.
61. The Staff Defendants breached their contractual obligations to Sydney by disclosing private

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information about Sydney to Shari and others that the Staff Defendants learned during the course of their

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employment.

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62. The breach of the non-disclosure agreement was a substantial factor in causing Sydney

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emotional distress as well as other damages, including but not limited to, the loss of Sydney’s

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partnership with Redstone the loss of Redstone’s bequests to Sydney in his estate plan.

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FIFTH CAUSE OF ACTION

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(Intentional Interference with Contractual Relations — Shari Redstone)

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63. Sydney incorporates by reference all of the allegations set forth in paragraphs 1 through 62
above as if fully stated herein.
64. In or around October of 2010, Sydney and Redstone met and soon thereafter entered into a

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valid oral contract, amended from time to time, pursuant to which Redstone agreed, among other things,

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to provide for all of Sydney’s financial support and needs for the rest of her life in the same style and

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manner that was established during the parties’ relationship; include Sydney as a beneficiary in his

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personal trust as to one-half (1/2) of the Beverly Park home and as to one-half of all of his cash, bonds,

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PSUs, stocks, and other non-real property investments existing at his death; and provide for all of

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Holland’s daughter’s financial support and needs for the rest of her life including, but not limited to, her
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education.
65. In exchange, Sydney agreed to render certain services to Redstone during the period of their

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relationship, including, but not limited to being a confidante, companion, executive assistant, personal

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assistant, personal valet, stylist, household manager, organizer, social secretary and health care manager.

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During the period of their relationship, including from June 2011 through September 2015 during which

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Sydney and Redstone cohabitated, Holland performed each and every covenant and condition required

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to be performed by her and rendered services and contributed her skills, efforts, and labor as required by

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the oral contract, except as may have been excused by Redstone’s breach thereof.

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66. Commencing in early 2011 Sydney and Redstone also entered into a valid implied contract,

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amended from time to time, pursuant to which Redstone, through his communications and conduct,

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repeatedly promised Sydney that he would, among other things, provide for all of Sydney’s financial

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support and needs for the rest of her life in the same style and manner that was established during the

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parties’ relationship; include Sydney as a beneficiary in his personal trust as to one-half (1/2) of the

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Beverly Park home and as to one-half of all of his cash, bonds, PSUs, stocks, and other non-real

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property investments existing at his death; and provide for all of Sydney’s daughter’s financial support

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and needs for the rest of her life including, but not limited to, her education.

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67. In exchange, Sydney, through her communications and conduct, promised to render certain

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services to Redstone during the period of their relationship, including, but not limited to being a

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confidante, companion, executive assistant, personal assistant, personal valet, stylist, household

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manager, organizer, social secretary and health care manager. During the period of their relationship,

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including from June 2011 through September 2015 during which Sydney and Redstone cohabitated,

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Sydney performed each and every covenant and condition required to be performed by her and rendered

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services and contributed her skills, efforts, and labor as required by the implied contract, except as may

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have been excused by Redstone’s breach thereof.

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68. Shari knew that Redstone entered into the agreement with Sydney.

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69. Intending for Redstone to renege on his contractual obligations, Shari intentionally made

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statements to Redstone, or induced statements to be made causing Redstone to breach his support

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contract with Sydney.
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70. As a result of Redstone’s breach, Sydney suffered emotional distress and other damages in an
amount to be determined at trial.
71. Shari’s conduct was a substantial factor in causing Redstone to breach his support contract
with Sydney, which caused Sydney’s harm.
72. By virtue of the wrongful conduct alleged above, Shari acted with malice, fraud, and
oppression and is liable for punitive damages in an amount to be determined at trial.

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SIXTH CAUSE OF ACTION

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(Inducing Breach of Contract — Shari Redstone)

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73. Sydney incorporates by reference all of the allegations set forth in paragraphs 1 through 72
above as if fully stated herein.
74. In or around October of 2010, Sydney and Redstone met and soon thereafter entered into a

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valid oral contract, amended from time to time, pursuant to which Redstone agreed, among other things,

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to provide for all of Sydney’s financial support and needs for the rest of her life in the same style and

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manner that was established during the parties’ relationship; include Sydney as a beneficiary in his

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personal trust as to one-half (1/2) of the Beverly Park home and as to one-half of all of his cash, bonds,

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PSUs, stocks, and other non-real property investments existing at his death; and provide for all of

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Holland’s daughter’s financial support and needs for the rest of her life including, but not limited to, her

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education.

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75. In exchange, Sydney agreed to render certain services to Redstone during the period of their

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relationship, including, but not limited to being a confidante, companion, executive assistant, personal

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assistant, personal valet, stylist, household manager, organizer, social secretary and health care manager.

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During the period of their relationship, including from June 2011 through September 2015 during which

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Sydney and Redstone cohabitated, Holland performed each and every covenant and condition required

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to be performed by her and rendered services and contributed her skills, efforts, and labor as required by

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the oral contract, except as may have been excused by Redstone’s breach thereof.

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76. Commencing in early 2011 Sydney and Redstone also entered into a valid implied contract,

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amended from time to time, pursuant to which Redstone, through his communications and conduct,

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repeatedly promised Sydney that he would, among other things, provide for all of Sydney’s financial
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CROSS-COMPLAINT

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support and needs for the rest of her life in the same style and manner that was established during the

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parties’ relationship; include Sydney as a beneficiary in his personal trust as to one-half (1/2) of the

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Beverly Park home and as to one-half of all of his cash, bonds, PSUs, stocks, and other non-real

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property investments existing at his death; and provide for all of Sydney’s daughter’s financial support

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and needs for the rest of her life including, but not limited to, her education.

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77. In exchange, Sydney, through her communications and conduct, promised to render certain

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services to Redstone during the period of their relationship, including, but not limited to being a

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confidante, companion, executive assistant, personal assistant, personal valet, stylist, household

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manager, organizer, social secretary and health care manager. During the period of their relationship,

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including from June 2011 through September 2015 during which Sydney and Redstone cohabitated,

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Sydney performed each and every covenant and condition required to be performed by her and rendered

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services and contributed her skills, efforts, and labor as required by the implied contract, except as may

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have been excused by Redstone’s breach thereof.

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78. Shari knew that Redstone entered into the agreement with Sydney.

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79. Intending for Redstone to renege on his contractual obligations, Shari intentionally made

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statements to Redstone, or induced statements to be made causing Redstone to breach his support

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contract with Sydney.

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80. As a result of Redstone’s breach, Sydney suffered emotional distress as well as other
damages in an amount to be determined at trial.
81. Shari’s conduct was a substantial factor in causing Redstone to breach his support contract
with Sydney, which caused Sydney’s harm.
82. By virtue of the wrongful conduct alleged above, Shari acted with malice, fraud, and
oppression and is liable for punitive damages in an amount to be determined at trial.

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***

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CROSS-COMPLAINT

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PRAYER FOR RELIEF
WHEREFORE, Sydney Holland prays this Court to enter judgment:
Against the Staff Defendants:

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1. For nominal damages; and

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2. For costs of suit.

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Against Shari Redstone:

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1. For damages according to proof;

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2. For costs of suit;

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3. For punitive and exemplary damages; and

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4. For such other and further relief as the Court may deem appropriate.

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DEMAND FOR JURY TRIAL

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Sydney Holland hereby demands a jury trial.

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DATED: December 15, 2016

KIRKFAND & EFFIS FFP

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MARK HOFSCHER
SIERRA EFIZABETH

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Counsel for Cross-Complainant
Sydney Holland

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CROSS-COMPLAINT

PROOF OF SERVICE

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I, Laura Bay, am employed in the County of Los Angeles, State of California. I am over the
age of 18 and not a party to the within action. My business address is 333 South Hope Street, Los
Angeles, California 90071.
On December 15, 2016, the foregoing document was served on the interested parties in this
action as follows:
[ X ] By placing the document listed above in a sealed envelope with postage thereon fully
prepaid, in the United States mail at Los Angeles, California addressed as set forth below. I am
familiar with the firm's practice of collection and processing correspondence for mailing. Under that
practice it would be deposited with the United States Postal Service on that same day with postage
thereon fully prepaid in the ordinary course of business.

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Robert Klieger
Marshall Camp
Andrew Walsh
HUESTON HENNIGAN LLP
523 West 6th Street, Suite 400
Los Angeles, CA 90014
Telephone: (213) 788-4370

Ronald Richards
Nicholas Bravo
THE LAW OFFICES OF RONALD RICHARDS
& ASSOCIATES, A.P.C.
P.O.Box 11480
Beverly Hills, CA 90213
Telephone: (310) 556-1001

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Attorneys for PlaintiffSumner M. Redstone

Attorneys for Defendant, Manuela Herzer

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[ X ] (STATE) I declare under penalty of perjury under the laws of the State of
California that the above is true and correct.

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PROOF OF SERVICE