PRIVILEGED AND CONFIDENTIAL PREPARED BY CRAVATH, SWAINE & MOORE
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
ESPN, INC., Plaintiff, vs. VERIZON SERVICES CORP., Defendant. Index No. ________
SUMMONS WITH NOTICE TO THE ABOVE NAMED DEFENDANT:
PLEASE TAKE NOTICE THAT YOU ARE HEREBY SUMMONED and required to serve upon Plaintiff’s attorney a notice of appearance or demand for a complaint within twenty (20) days after service of this Summons with Notice, exclusive of the day of service, or within thirty (30) days after service is complete if this Summons with Notice is not personally delivered to you within the State of New York. In case of your failure to appear or serve a demand for a complaint, judgment will be taken against you on default for the relief demanded herein. Plaintiff designates New York County as the place of trial. Venue is proper because Defendant is registered to do business in New York and maintains offices in this County, and many of the wrongful acts alleged herein occurred in this County.
NOTICE
This is an action for breach of contract and declaratory judgment arising from Defendant’s breach of its obligations to Plaintiff under certain license agreements,
2 supplements, and amendments entered into between Plaintiff and Defendant. Plaintiff seeks specifically to enforce Defendant’s contractual obligations to Plaintiff, to enjoin Defendant from unfairly depriving Plaintiff of the benefit of its bargain, and to require Defendant to pay damages to Plaintiff in an amount consistent with (but not limited to) relevant provisions in the parties’ agreements. The relief Plaintiff seeks, in terms of specific performance, injunctive relief, and damages, is equitable and legal. Upon your failure to appear, judgment will be taken against you by default for money damages in excess of $500,000, and interest thereon, together with reasonable attorneys’ fees. April 27, 2015 CRAVATH, SWAINE & MOORE LLP by Evan R. Chesler Roger G. Brooks J. Wesley Earnhardt Members of the Firm Worldwide Plaza 825 Eighth Avenue New York, NY 10019 (212) 474-1000
Attorneys for Plaintiff ESPN, Inc.
