Howard Films v. Miller - California complaint.pdf

8/16/2019 Howard Films v. Miller - California complaint.pdf

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. Michael Kernan, State BarNo. 181747

R. Paul Katrinak, State Bar No. f64057

2 Sean A. Pope, State Bar No. 299018

THE KERNAN LAW FIRM

3 9663 Santa Monica Blvd., Suite 450

Beverly Hills, California 90210

4 Telephone: (310) 490-9777

Facsimile: (310) 861-0503

5

Attorney for Plaintiff

6 HOWARD FILMS, INC.

7

•

s U p e r l o r ~ h r E p .

Ountv

of l

alifornia

8 Aoqeles

M Y 202016

Sherri

A c a ~ •

y_ OfficerlClert

§n unya

olden Deputy

8

9

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

10

11

HOWARD FILMS, INC., a California

12 corporation,

13

Plaintiff

14

v.

)

)

)

)

)

)

)

)

)

15

JIMMY MILLER, an individual; JULIE )

DARMODY, an individual; MOSAIC MEDIA )

16 GROUP, INC., a Delaware corporation; and )

DOES I through 100, )

17

)

18

19

20

21

22

23

24

25

26

27

28

Defendants.

)

)

)

)

)

)

Case No.

Be

6

21

21

7

COMPLAINT FOR

DAMAGES

FOR:

1) BREACH OF CONFIDENCE

COMPLAINT

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OMPLAINT

2 On

information and belief, Plaintiff Howard Films, Inc. (hereinafter sometimes referred

3 to as Howard Films ) alleges as follows:

4

L

NATURE

OF THE ACTION

5

I This action arises from the Defendants' misappropriation, unauthorized use and

6 exploitation of Plaintiffs work, ideas and concepts for an innovative film entitled Get Hard,

7 also koown as Tbe Prison Coach (collectively referred to herein as Concepts ) resulting

8 from the Defendants' unexcused breach

of

confidence that existed between Plaintiff and

9 Defendants.

10

2.

The treatment, ideas, and story materials referred to herein were submitted and

II presented to Defendants Jimmy Miller, Julie Darrnondy, Mosaic Media Group, Inc. and Does 1

12 through 100 in or about May of2012. Pla intif fs agent followed up multiple times regarding

13 the submission with Defendants and received no response. Plaintiff believed that there was no

14 interest on the part

of

Defendants in the Concepts.

15

3.

Plaintiff presented the Concepts to Defendants consistent with well-established

16 customs and practices of the entertainment industry and on the mutually understood condition

17

and bilateral expectation that Defendants would not disclose, use andlor exploit the Concepts

18 without Plainti ff s permission andlor without compensating Plaintiff in the form of payments,

19 credit and other consideration to the Plaintiff.

20

4. However, instead

of

compensating Plaintiff for its Concepts, Defendants

21

misappropriated, used, exploited Pla intiff s Concepts assisting in the production of the hit film

22

Get Hard without Plainti ffs permission andlor without compensating Plaintiff in the form of

23

payments, credit, and other consideration to the Plaintiff. Plaintiff did not discover the use of

24

Plaintiffs Concepts by Defendants until after the release

of

Get Hard on March 27, 2015.

25

5.

Get Hard has now enriched Defendants to the tune of millions of dollars.

26

II

JURISDICTION AND VENUE

27

6. On May 4, 2011, a Ninth Circuit n bane panel published its decision, Montz v.

28

Pilgrim Films Television Inc. 649 F.3d 975 (9th Cir. 2011) and determined that Plaintif fs

2

COMPLAINT

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• •

anagement services. Defendant Mosaic Media Group, Inc. conducts business in Los

2 Angeles, California.

3

4

5

13.

14.

15.

[Intentionally left blank].


Plainti ff is ignorant of the true names and capacities of Defendants sued

6 hereunder as DOES 1 through 100 inclusive, and therefore sue these Defendants by such

7 fictitious names. Plaintiff is informed and believes and thereon alleges that each of the

8 fictitiously named Defendants is responsible in some manner for the occurrences herein

9 alleged, and that Plaintiff 's damages which are herein alleged were proximately caused by their

10

conduct. Plaintiff will amend this Complaint to allege the true names and capacities

of

Defendants DOES 1 through 100 when ascertained. These fictitiously named Defendants, and

c

12 each of them are, and at all times mentioned were, acting in concert with Defendants, and the

.

13 parties DOES 1 through 100 inclusive are sued herein individually and joined as Defendants in

d '§

4 this action. Hereinafter Defendant Jimmy Miller, Defendant Julie Darmody, Defendant

u

: ;;

5 Mosaic Media Group, Inc., and Does I through 100 will be collectively referred to as

w '

x 6

Defendants.

'

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17

16.

Defendants

at

all times herein mentioned were agents, employees and/or alter

8 egos of one another as co-defendants. In doing things hereinafter alleged, Defendants were

19 acting within the course and scope of such agency, employment and/or alter ego capacity with

20 the permission and consent of the co-defendants. The allegations of this Complaint are stated

2 on information and belief and are likely to have further evidentiary support after a reasonable

22 opportunity for further investigation and/or discovery.

23

24

25

26

27

28

17. At all material times hereto, Defendants, and each of them, were the alter ego of

each other,

or

were in a principal and agency relationship, and as such were acting with the

implied or ostensible authority of each other. On that basis, Plaintif f alleges that each of the

Defendants is the alter ego of each other Defendant in that each Defendant is but an

instrumentality or conduit of one or more of the other Defendants in the pursuit of a single

business venture such that disregard of the separate nature of the Defendants' corporate

4

COMPLAINT

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organization, or other association, is necessary to prevent an injustice upon Plaintiff. In this

2 regard, Plaintiff is informed and believes, and based thereon alleges, that each

of

the

3 Defendants has common employees or agents, and at the time this matter arose, was operating

4

from the same business location, and using the financial resources of the other Defendants, and

5

each of the Defendants tends to benefit jointly from the transactions entered into by one or

6 more of the other Defendants.

7

IV.

ALLEGATIONS COMMMON

TO

ALL COUNTS

8

18

When Plaintiff conceived the Concepts for the film the written format and

9 treatment had several variations.

1

19. Plaintiff registered the treatment for the Concepts with the Writers' Guild at the

endof2011.

12

13

14

15

16

17

20. The Concepts included ideas and material relating to a new, innovative, and

exciting film that included but was not limited to the elements set forth in Exhibit

A and

incorporated herein as fully set forth.

21. From about May of2012, Plaintiff and/or its agents, managers, counsel and/or

representatives on their behalf, presented the Concepts to Defendants, their predecessors,

agents, employees and/or alter egos acting within the course and scope

of

such agency,

18 employment and/or alter ego capacity, and with the permission and consent

of

Defendants, and

19 all ofthem.

20

22.

From about May of2012, Plaintiff, its agents, managers, legal counsel, and/or

21 representatives, presented the Concepts to at least Defendants' following predecessors, agents,

22 employees and/or alter egos, all operating within the course and scope

of

their agency on

23

Defendants' behalf.

24

23. Plainti ff presented the Concepts to Defendants consistent with well-established

25 customs and practices of the entertainment industry and

on

the mutually understood condition

26 and bilateral expectation that Defendants would not disclose, use, and/or exploit the Concepts

_) 27 without Plaintiffs permission and/or without compensating Plaintiff in the form of payments,

::-.;.:.

28 credit and other consideration to the Plaintiff.

5

COMPLAINT

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4. [Intentionally left blank].

25.

26.

27.

28.




After the massive

s u ~ e s s of

Get Hard that is based on

Plaintiff

s Concepts

6 that Plaint iff pitched to Defendants, Defendants have made huge sums

of

money by producing

7

the film based on Plaintiff s Concepts without compensating or crediting Plaintiff for their

8

Concepts as they committed to do.

9

29.


10


31.


12

32.


13

33.


14

34 .


15

35.


16


17

37. [Intentionally left blank] .

18

38.


19

FIRST CAUSE OF ACTION

20

BREACH OF CONFIDENCE AGAINST ALL

DEFENDANTS

21

39. Plaint iff incorporates herein by this reference ea


7/13

7 o 32)

• •

without

Plaintiffs

permission andlor without compensating Plaintiff in the

fonn of

payments,

2 credit and other considerations to Plaintiff.

3

42.

In light of well-established customs and practices of the entertainment industry

4 and on the mutually understood condition and bilateral expectation that Defendants would not

5 disclose, use andlor exploit the Concepts without Plaintiff s pennission andlor without

6 compensating Plaintiff in the fonn of payments, credit

and

other consideration to

the

Plaintiff,

7

Defendants' actions and conduct implied and led Plaint iff to reasonably believe that

8 Defendants would not disclose, use andlor exploit the Concepts without Plaintiffs pennission

9 andlor without compensating Plaintiff.

1

43. Plaintiff

perfonned

all conditions, covenants and promises required

on

their part

to be

perfonned in

accordance with

the

tenns

and

conditions of their confidential relationship

12 with Defendants.

13

14

15

16

17

18

44. Defendants breached the confidential relationship by, among other actions,

disclosing, misappropriating, and exploiting Plaintiffs Concepts by disclosing Plaintiff s

Concepts and producing the hit film Get Hard repackaged as Defendants' own projects

without

Plaintiffs

pennission andlor without compensating Plainti ff in the fonn of payments,

credit, and other consideration to Plaintiff.

45

Defendants' breaches of the confidential relationship are ongoing, and unless

19 Defendants are enjoined by this Court, Defendants will continue to disclose, use andlor exploit

2 the Concepts without

Plaintiffs

pennission andlor without compensating Plaintiff.

21

46

As a direct and proximate result of Defendants' breaches described herein,

22

Plainti ff has suffered irreparable damages, including lost profits, and Pla intif f will continue to

23

suffer irreparable damages in amounts to be proven at trial.

24

47. Plaintiff is entitled to a pennanent injunction restraining Defendants

and

their

25 officers, agents, employees and all persons acting

in

concert

with them

from engaging in

any

26

further acts in violation of the

Plaintiff

s rights.

27

48.

Defendants' conduct was malicious, fraudulent, oppressive and intended to

28

injure Plaintiff. Additionally, Defendants' conduct and the conduct of the Defendants'

7

COMPLAINT

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

FOR COURT

USE

ONL Y

The Kernan

9663 Santa Monica Blvd., Suite 450

FILED. .

Beverly Hills, CA 90210

TELEPHONE NO.

U - , 4 \ 1 I J - ~ r n 7

FAX NO. 310-861-0503 aupelrior Court 01 Cahlomla

~ A T ~ T O ; R ~ N ; E Y ~ ; ; ; , ; ; ; ' f . * ~ p . ~ ~ ~ ~ c ; F ~ I L ~ M ~ S ~ I ~ N f C ~ .

---------1 I Los Angeles

Is

COURT OF CALIFORNIA, COUNTY OF

Los

STREET ADDRESS III

North Hill Street

MAILING

ADDRESS

III

North Hill Street

Officer/Cia \(

~ : ; : ; ~ : J L ~ 0 ~ S ~ ~ ~ 9 ~ O ~ 0 ~ 1 2 ~ ~ ~ ~ ~ ~ ~

CASE

Inc.

v.

Miller et

al.

CIVIL CASE COVER SHEET

o

Unlimited

0 Limited

(Amount (Amount

demanded demanded is

exceeds I

Complex Case

Designation

o Counter

0 Joinder

one

Auto Tort

for the case type that best describes this case:

o Auto 22)

D

Uninsured motorist (46)

Other PI/PDIWD

IPersonallnjury/Property

DamagelWrongful

Death)

Tort

o Asbestos 04)

D

Product liability (24)

D Medical malpractice

(45)

D Dlher PIIPDNVD (23)

Non-PI/PDIWD

(Other)

Tort

D Business tort/unfair business practice (07)

D

Civil rights (08)

D Defamation (13)

o Fraud(16)

D Intellectual property (19)

D Professional negligence (25)

D Other non-PI/PDfIND tort (35)

~ o y m e n t

U wrongful termination (36)

I

Contract

D

Breach of contracUwarranty (06)

D

Rule

3.740

collections (09)

D

Other collections (09)

D Insurance coverage (18)

o Other contract (37)

Real Property

D Eminent domain/Inverse

condemnation (14)

D Wrongful eviction

(33)

o Other real property

(26)

Unlawful

Detainer

o Commercial (31)

D Residential (32)

o Oru9S 38)

Judicial Review

D

Asset forfeiture

OS)

o

: ; : ~ _

Deputy

JUDGE:

DEPT:

Provisionally Complex Civil

l i t igation

(Cal. Rules of Court, rules

3.400-3.403)

D

AntitrusVTrade regulation (03)

D

Construction defect

(10)

D

Mass tort (40)

D Securities litigation (28)

D

EnvironmentallToxic tort (30)

D

Insurance coverage claims arising from the

above listed provisionally complex case

types (41)

Enforcement of Judgment

D

Enforcement of

udgment

(20)

Miscellaneous Civil Complaint

o

RICO(27)

o Diller complainl

not speCified above) 42)

Miscellaneous Civil Petition

D Partnership and corporate governance (21)

o

Diller petition not specified above) (43)

2. complex under rule 3.400

of

the Cal"lfornia Rules

of

Court. If the case is complex, mark the

factors requiring

i

i management:

8. D Large number

of

separately represented parties d. D Large number

of

witnesses

b D Extensive motion practice raising difficult or novel

e.

D 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.

D

Substantial amount

of

documentary evidence f.

D

Substantial posqudgment judicial supervision

3.

Remedies sought

check aI/ that apply):

a 0 monetary

b. [2]

nonmonetary; declaratory or injunctive relief

c· puni t ive

4.

Number

Of causes of action (specify). I Cause of Action: Breach ofContidence

5.

This case

D

is

0 is

not a class action suit.

6. If

there are any known related cases, file and serve a notice

of

related case. You may use form CM-01S.)

Date

May

16,2016

/

S. Michael Kernan .

J--L7,;

1}J\£ tV - ==o=-

_

TYPE OR PRINT NAME) iSIGNATUREOFARTY OR AnORNEY

FOR

PARTY)

, NOTICE

Plaintiff must file this cover sheet with the first paper filed

in

the action or proceeding (except small claims cases or cases filed

. ~ . under the Probate Code, Family Code, or Welfi;lre and Institutions Code). (Cal. Rules

of

Court, rule

3.220.)

Failure to file may result

-•

)

in

sanctions.

: "r File this cover sheet

in

addition to any cover slleet 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

. i.

Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes onlv

,._

1' 01 e

1

of

2

Form AdoptB(j

ot

Mandatory

Use

Judicial

Council 01

California

CM..o,O

[ R e ~

July 1. 2007]

CIVIL CASE COVER SHEET

Cal. Rules 01 Cour1. rules 2.30. 3.220, 3.400-3.403. 3.740:

Cal. Standards

of Judicial AdminiSlratiOl1,

sid. 3.10

www.cour1info.c:a.gov

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SHORT TITLE

Howard Films, Inc. v. Miller,

Be 6

2

1 21 7

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 2.3 In all

new civil

case filings In the Los ngeles Superior Court

Step

1: After

completing the Civil Case Cover Sheet (Judicial Council form CM-OlO), find the exact

case

type in

Column A that corresponds to the case type indicated in the Civil

Case

Cover Sheet.

Step 2:

In

Column B, check the box

forthe

type of action that best describes the nature of the

case.

Step 3: In Column

C,

circle the number which explains the reason for the court filing location you have

chosen.

Applicable Reasons

for

Choosing Cour t Filing Location (Column

C

1.

Class actions must be filed in the Stanley Mask Courthouse. Central District.

7 Location where petitioner resides.

2.

Permissive filing

in

central district.

8

Location wherein defendanUrespondent functions wholly

3.

Location where cause of action arose.

9.

Location where one

or more of

the parties reside.

4. Mandatory personal injury filing in North District.

10. Location

of

Labor

Commissioner

Office.

S. Location where performance required or defendant resides.

11. Mandatory

filing location

Hub

Cases

- unlawful

detainer, limited

non-collection, limited collection,

or

personal injury).

6.

Location of property or permanently garaged vehicle.

O t

- 0

A

Civil Case

Cover Sheel

Categor y No.

Auto (22)

Uninsured Motorist

(46)

Asbestos (04)

Product Liability (24)

Medical Malpractice (45)

Other Personal

Injury Property

Damage Wrongful

Death (23)

LAC V 109 (Rev 2/16)

LASe Approved 03-04

,

.

B

Type

of

Action

(Check only one)

0

A7100

Motor Vehicle - Personal Injury/Property DamageNVrongful Death

0

A7110

Personallnjury/Property DamageNVrongful Death - Uninsured Motorist

0

A6070

Asbestos Property Damage

0

A7221

Asbestos - PersonallnjuryNVrongful Death

0

A7260

Product Liability (not asbestos or toxic/environmental)

0 A7210

Medical Malpractice - Physicians & Surgeons

0 A7240

Other

Professional Health Care Malpractice

0 A72S0 Prem'lses Liabil lty (e.g., slip and fall)

0 A7230

Intentional Bodily Injury/Property DamageNVrongful Death (e,g

assault, vandalism, etc,)

0

A7270

Intentional Infliction of Emotional Distress

0

A7220

Other

Personal Injury/Property Damage.NVrongful Death

CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION

C

Applicable Reasons-

See Step

3

Above

1,

4,

11

1,

4,

11

1. 11

1, 11

1,4,11

1,4,11

1,

4.

11

1

4,

11

1,

4, 11

1,4, 11

1,

4,

11

Local Rule 2.3

Page 1

of4

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"

,

I HORT TITLE:

Howard Films, Inc, v, Miller,

I ASE

.

A

Civil Case Cover Sheet

Category No.

Business Tort (07)

~ 1 :

Civil Rights (08)

0

.

...

0

a:m

Defamation (13)

" "

--

::

Cl

Fraud 16)

- ::

ni e

is;:;

I ?Qj

Cl

Professional Negligence (25)

"-

E

o ..

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Other

35)

'E

Wrongful Termination (36)

"

,.,

0

C.

Other Employment (15)

E

w

Breach of ContracV Warranty

(06)

(not insurance)

U

E

Collections (09)

E

0

u

Insurance Coverage (18)

Other Contract (37)

Eminent Domain/Inverse

Condemnation (14)

"

Wrongful Eviction (33)

c.

2

"-

"

'

Other Real Property (26)

Unlawful Detainer-Commercial

31)

"

5:>

Unlawful Detainer-Residential

32)

3

Unlawful Detainer-

l

Post-Foreclosure (34)

'"

J

Unlawful Detainer-Drugs (38)

?:>

- - ~

LACIV 109 (Rev

2/16

,LASC Approved 03-04

B

"

.

.

.

Type of Action .

(Check only one)

0 A6029 Other Commercial/Business Tort (not fraud/breach of contract)

0 A6005

Civil RightslDiscrimination

0 A6010 Defamation (slander/libel)

0

A6013

Fraud (no contract)

0

A6017

Legal Malpractice

0 A6050 Other Professional Malpractice (not medical or legal)

0

A6025

Other Non-Personallnjury/Property Damage tort

0 A6037

Wrongful Termination

0 A6024 Other Employment Complaint Case

0 A6109

Labor Commissioner Appeals

0 A6004

Breach of Rental/Lease Contract (not unlawful detainer

or

wrongful

eviction)

0 A6008 ContractlWarranty Breach -Seller Plaintiff (no fraud/negligence)

0

A6019

Negligent Breach

of

ContractlWarranty (no fraud)

0

A6028

Other Breach of ContractlWarranty (not fraud or negligence)

0 A6002

Collections Case-Seller Plaintiff

0 A6012 Other Promissory Note/Collections Case

0

A6034

Collections Case-Purchased Debt (Charged Off Consumer Debt

Purchased

on

or after Januarv 1 20141·

0

A6015

Insurance Coverage (not complex)

0

A6009

Contractual Fraud

0 A6031

Tortious Interference

[

A6027 Other Contract Dispute(not breach/insuranceJfraud/negligence)

0 A7300

Eminent Domain/Condemnation

Number

of

parcels___

0

A6023

Wrongful Eviction Case

0 A6018 Mortgage Foreclosure

0 A6032 Quiet Title

0 A6060

Other Real proper ty (not eminent domain, landlord/tenant, foreclosure)

0 A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction)

0

A6020

Unlawful Detainer-Residential (not drugs or wrongfUl eViction)

0

A6020F Unlawful Detainer-Post-Foreclosure

0 A6022 Unlawful Detainer-Drugs



C

Applicable

Reasons - See Step 3

Above

1,2,3

1,2,3

1,2,3

1,2,3

1,2,3

1,2,3

1,2,3

1,2,3

1,2,3

10

2, 5

2, 5

1,2,5

1,2,5

5,6,11

5, 11

5,6,11

1,2,5,8

1,2,3,5

1,2,3,5

1,2,3,8,9

2,6

2,6

2,6

2,6

2,6

6,11

6, 11

2,6,11

2,6,11

Local Rule 2,3

Page 2 of4

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.

I

ORT TITLE

Howard

Films,

Inc. v. Miller,

I

I

ASE

A

. Civil Case Cover Sheet

Category No,

Asset Forfeiture (05)

Petition re Arbitration (11)

.s:

.,

a::

n;

Writ of Mandate (02)

'u

.,

Other Judicial Rev'lew (39)

AntllrusVTrade Regulation (03)

0

Construction Defect (1

0)

'

:5

Claims Involving Mass Tort

.,

(4D)

a.

E

0

Securities Litigation (28)

>

.2-

n;

Toxic Tort

2

Environmental (30)

U

.s:

Insurance Coverage Claims

from Complex Case (41)

"E

"E

.,

.,

E

E Enforcement

.,

'

of

Judgment (20)

E

.,

'0

RICO (27)

'

i

...

,

a.

E

Other Complaints

a;

0

U

(Not Specified Above) (42)

'

E

:?

u

Partnership Corporation

Governance (21)

' '

,

;;

Other Petitions (Not

a;

-

Specified Above) (43)

=

~ : : f 3

..n

-

-'

C,

-

.0

LACIV 109 (Rev

2116)

LASe Approved 03-04

·

Type of Action

(Check only one)

0

A6108 Asset Forfeiture Case

0

A6115 Petition to Compel/ConfirmNacate Arbitration

0

A6151 Writ - Administrative Mandamus

0

A6152 Writ - Mandamus

on

Limited Court Case Matter

0

A6153

Writ - Other Limited Court Case Review

0 A615D OtherWr'lt IJudicial Review

0

A6DD3 AnlitrusVTrade Regulation

0 A6007 Construction Defect

0

A6006 Claims Involving Mass Tort

0

A6035 Securities Litigation Case

0

A6D36

Toxic Tort/Environmental

0 A6D14 Insurance Coverage/Subrogation (complex case only)

0

A6141 Sister Stale Judgment

0 A616D Abstract of Judgment

0

A61D7 Confession

of

Judgment (non-domestic relations)

0 A6140 Administrative Agency Award (not unpaid taxes)

0

A6114 Petition/Certificate for Entry

of

Judgment on Unpaid Tax

0 A6112 Other Enforcement of Judgment Case

0

A6033 Racketeering (RICO) Case

0 A6030 Declaratory Relief Only

0

A6040

Injunctive Relief Only (not domestic/harassment)

0

A6011

Other Commercial Complaint Case (non-tortlnon-complex)

121

A6000 Other Civil Complaint (non-tortlnon-complex)

0

A6113 Partnership and Corporate Governance Case

0 A6121

Civil Harassment

0

A6123

Workplace Harassment

0 A6124 Elder/DependentAdult Abuse Case

0

A6190

Election Contest

0 A6110 Petition for Change of Name/Change of Gender

0

A6170

Petition for Relief from Late Claim Law

0

A6100

Other Civil Petition


AND

STATEMENT

OF LOCATION

C Applicable

Reasons - See Step 3

Above

2 3 6

2,

5

2 8

2

2

2 8

1 2.8

1 2 3

1 2 8

1 2.8

1 2 3 8

1 2 5 8

2 5 11

2 6

2.9

2.8

2 8

2 8 9

1 2 8

1 2 8

2 8

1 2 8

1 2 8

2,

8

2 3 9

2 3 9

2,

3,

9

2

2 7

2 3 8

2 9

Local Rule 2.3

Page 3 of 4

Doc# 1

Page#

31 - Doc ID - 1653079228 - Doc Type

O


13/13

32 or 32)

SHORT TITLE:

Howard Films, Inc. v.

Step 4: Statement of

Reason and

Address:

Check the appropriate boxes

for

the numbers shown under Column C

for

the

type of action that you have selected. Enter the address which is the basis for the filing location, including zip code.

No address required for class action cases .

ADDRESS

REASON:

9663 Santa Monica Blvd.

01 02 03 04 05 06 07 08 09 010 011

CITY:

STATE·. ZIP CODE·

Beverly Hills CA

90210

Step 5:

Certification

of

Assignment: I certify that this

case is

properly filed in the Central District of

the Superior Court of California, County

of Los

Angeles [Code

Civ.

Proc., §392 et seq., and Local

Rule

2.3 a) 1) E)].

Dated: May 16, 2016

SIGNATURE OF ATTORNEY/FILING PARTY)

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.

02/16 .

5.

Payment in full of the filing fee, unless there

is

court order for

waiver,

partial or scheduled payments.

6.

A signed order appointing the Guardian

ad

Litem, Judicial Council form CIV-01

0,

if the plaintiff or petitioner is a

minor under 18 years of age will be required

by

Court

in

order to issue a summons.

7.

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

L CIV

109

Rev

2116)

LASe Approved 03-04



Local

Rule 2.3

Page

4 of 4

Documents

Howard Films v. Miller - California complaint.pdf