Oksana Baiul v. William Morris Agency

7/22/2019 Oksana Baiul v. William Morris Agency

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Silver, Steven11/7/2013

For Educational Use Only

Oksana BAIUL, Plaintiff, v. WILLIAM MORRIS AGENCY,..., 2013 WL 5565762...

2013 Thomson Reuters. No claim to original U.S. Government Works. 1

2013 WL 5565762 (N.Y.Sup.) (Trial Pleading)

Supreme Court of New York.

New York County

Oksana BAIUL, Plaintiff,

v.

WILLIAM MORRIS AGENCY, LLC f/k/a William Morris Agency, Inc.; William Morris Endeavor

Entertainment, LLC; Sheldon Schultz; Michael Carlisle; James Griffin; Alan Dworkin; Richard

Hersh; Wallin, Simon & Black; Patricia Black, Alan A. Wallin; Alan Suskind; The Screen Actors Guild

- American Federation of Television and Radio Artists; Olympic Champions Ltd (BVI); Olympic

Champions Ltd (DEL); Ukrainian Financial Group JSC; Galina Zmievskaya; Victor Petrenko; Nina

Petrenko; PJSC Gala Radio; Joseph Lemire AKA Joseph C. Lemire; Valery G. Babich AKA Vlasislav

V. Babych; Key Brand Entertainment Inc; Michael Rosenberg; and Nancy Rosenberg., Defendants.

No. 0653491-2013.October 8, 2013.

Summons and Complaint

Raymond J. Markovich, Esq., Attorney for Plaintiff, 351 Westbourne Drive, West Hollywood, CA 90048, (323) 401-8032.

Dated: October 8, 2013

Certified per 22NYCRR 130-1.1(a)

Attorney for Plaintiff

Raymond J. Markovich, Esq.

Summons

To the above named Defendants:

You are hereby summoned to answer the complaint in this action and to serve a copy of your answer, or if the complaint isnot served with this summons, to serve a notice of appearance, on the Plaintiff's attorney within 20 days after the service of

this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally

delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against

you by default for the relief demanded in the complaint.

The basis of venue is the principal office in New York County of Defendant William Morris Endeavor Entertainment, LLC

which is at 1325 Avenue of the Americas; New York, New York 10019.


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Dated: New York, New York

October 8, 2013

Raymond J. Markovich, Esq.

Attorney for Plaintiff - Oksana Baiul

351 Westbourne Drive

West Hollywood, CA 90048

(323) 401-8032

Defendants' Addresses

William Morris Agency, LLC

9601 Wilshire Blvd

3rd Floor

Beverly Hills, CA 90210

William Morris Endeavor Entertainment, LLC

1325 Avenue of the Americas

New York, New York 10019

Sheldon Schultz

c/o SRS Global Artists, Inc.

454 West 44th Street

New York, NY 10036

Michael Carlisle

c/o Inkwell Management

521 5th Avenue

26th Floor


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Joseph C. Lemire

c/o Olympic Champions Limited

Agent for Service - The Company Corporation

2711 Centreville Road; Suite 400

Wilmington, DE 19808

Valery G. Babich aka Vladislav V. Babich

Ukrainian Financial Group JSC

c/o Western Union Co.

12500 East Belford Avenue

Englewood, CO 80112

Key Brand Entertainment Inc

1619 Broadway

19th Floor

New York, NY 10019

Michael Rosenberg

77835 Cottonwood Cove

Indian Wells, CA 92210

Nancy Rosenberg

77835 Cottonwood Cove

Indian Wells, CA 92210

COMPLAINT

Plaintiff Oksana Baiul a/k/a Oksana S. Baiul a/k/a Oksana S. Baiul-Farina (Plaintiff) by her attorney, Raymond J. Markovich,

Esq., alleges as follows:


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The Parties

1. Plaintiff is an adult individual residing in Bucks County, Pennsylvania.

2. Upon information and belief, Defendant William Morris Agency, LLC f/k/a William Morris Agency, Inc. (WMA) is a

limited liability company organized under the laws of Delaware and registered to do business and doing business in New York

County, State of New York.

3. Upon information and belief, WMA owns, uses and/or possesses real property in the State of New York.

4. Upon information and belief, on or about June 2009, WMA merged with the Endeavor Talent Agency (Endeavor) to form

Defendant William Morris Endeavor Entertainment, LLC (WMEE).

5. Upon information and belief, WMEE expressly and/or impliedly assumed the tort liabilities of both Endeavor and WMA

and/or WMEE is a mere continuation of both Endeavor and WMA.

6. Upon information and belief, WMEE is a limited liability corporation organized under the laws of Delaware and registered

to do business and doing business in New York County, State of New York with a current principal place of business at 1325

Avenue of the Americas, New York, NY 10019 and formerly at 1350 Avenue of the Americas, New York, NY 10019.

7. Upon information and belief, WMEE owns, uses and/or possesses real property in the State of New York.

8. Upon information and belief, WMEE is the successor in interest to WMA.

9. WMEE and WMA shall collectively and individually henceforth be referred to as WME (WME).

10. Defendant Sheldon Schultz (Schultz) is an adult individual that was a talent agent for Plaintiff at WME in New YorkCounty, State of New York.

11. Upon information and belief, Schultz worked for WME in the State of New York and/or is doing business in the State of

New York and/or transacts business in the State of New York and/or has done regular and continuing work for WME and/or

SRS Global Artists, Inc. in the State of New York and/or business with WME and/or SRS Global Artists, Inc. in the State of

New York and/or business with others in the State of New York for several years and/or did business related to Plaintiff in the

State of New York when WME had represented Plaintiff as Plaintiff's talent agency.

12. Defendant Michael Carlisle (Carlisle) is an adult individual that was a talent agent for Plaintiff at WME in New York

County, State of New York.

13. Upon information and belief, Carlisle worked for WME in the State of New York and/or is doing business in the State of


Inkwell Management in the State of New York and/or business with WME and/or Inkwell Management and/or Carlisle and Co.

in the State of New York and/or business with others in the State of New York for several years and/or did business related to

Plaintiff in the State of New York when WME had represented Plaintiff as Plaintiff's talent agency.

14. Defendant James Griffin (Griffin) is an adult individual that was a talent agent for Plaintiff at WME in New York County,

State of New York.


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15. Upon information and belief, Griffin worked for WME in the State of New York and/or is doing business in the State of


The Paradigm Agency in the State of New York and/or business with WME and/or The Paradigm Agency in the State of New

York and/or business with others in the State of New York for several years and/or did business related to Plaintiff in the Stateof New York when WME had represented Plaintiff as Plaintiff's talent agency.

16. Defendant Alan Dworkin (Dworkin) is an adult individual that worked for WME in New York County, State of New

York when WME had represented Plaintiff as Plaintiff's talent agency.

17. Upon information and belief, Dworkin worked for WME in the State of New York and/or is doing business in the State of


Crystal, Shapiro & Dworkin, LLP in the State of New York and/or business with WME and/or Crystal, Shapiro & Dworkin,

LLP in the State of New York and/or business with others in the State of New York for several years and/or did business related

to Plaintiff in the State of New York when WME had represented Plaintiff as Plaintiff's talent agency.

18. Defendant Richard Hersch (Hersch) is an adult individual that was a talent agent for Plaintiff at WME.

19. Upon information and belief, Hersch is doing business in the State of New York and/or transacts business in the State of

New York and/or has done regular and continuing work for WME and/or Celebrity Consultants, LLC in the State of New York

and/or business with WME and/or Celebrity Consultants, LLC in the State of New York and/or business with others in the State

of New York for several years and/or did business related to Plaintiff in the State of New York when WME had represented

Plaintiff as Plaintiff's talent agency.

20. Schulz, Carlisle, Griffin, Dworkin and Hersch are collectively referred to as the WME Agents (WME Agents).

21. Defendant Wallin, Simon & Black (WSB) is a company that claims to be certified public accountants with its principalplace of business in New York County, State of New York with its offices currently at 370 Lexington Avenue; Suite 1207; New

York, New York 10017 and formerly at 1350 Avenue of the Americas; New York, New York 10019 which was just across the

hallway from the offices of WME, Schultz, Carlisle, Griffin and Dworkin.

22. WSB continually served and represented Plaintiff as Plaintiff's certified public accountants and business manager from

April 1997 through January 2012.

23. Upon information and belief, WSB owns, uses and/or possesses real property in the State of New York.

24. Defendant Patricia Black (Black) is an adult individual that claims to be a certified public accountant and who did work

for Plaintiff at WSB in the State of New York.

25. Upon information and belief, Black works for WSB in the State of New York and/or is doing business in the State of New

York and/or transacts business in the State of New York and/or has done regular and continuing work for WSB in the State

of New York and/or business with WSB in the State of New York and/or business with others in the State of New York for

several years and/or did business related to Plaintiff in the State of New York when WSB had represented Plaintiff as Plaintiff's

certified public accountants and business manager.

26. Defendant Alan A. Wallin (Wallin) is an adult individual that claimed to be a certified public accountant and who did

work for Plaintiff at WSB in the State of New York.


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27. Upon information and belief, Wallin works for WSB in the State of New York and/or is doing business in the State of New



several years and/or did business related to Plaintiff in the State of New York when WSB had represented Plaintiff as Plaintiff'scertified public accountants and business manager.

28. Defendant Alan Suskind (Suskind) is an adult individual who did work for Plaintiff at WSB in the State of New York.

29. Upon information and belief, Suskind is a certified public accountant.

30. Upon information and belief, Suskind works for WSB in the State of New York and/or is doing business in the State of New



several years and/or did business related to Plaintiff in the State of New York when WSB had represented Plaintiff as Plaintiff's

certified public accountants and business manager.

31. Black, Wallin and Suskind are collectively referred to as CPA (CPA).

32. The Screen Actors Guild merged with the American Federation of Television and Radio Artists on or about March 30,

2012 and the result of the merger is Defendant The Screen Actors Guild - American Federation of Television and Radio Artists

(SAG) which is not-for-profit corporation registered to do business and doing business in New York County, State of New

York with offices at 360 Madison Avenue; 12th Floor; New York, NY 10017.

33. Upon information and belief, SAG expressly and/or impliedly assumed the tort liabilities of both the Screen Actors Guild

and the American Federation of Television and Radio Artists and/or SAG is a mere continuation of both the Screen Actors

Guild and the American Federation of Television and Radio Artists.

34. Upon information and belief, SAG owns, uses and/or possesses real property in the State of New York.

35. Upon information and belief, Defendant Olympic Champions Ltd (OCL) is a corporation formed under the laws of the

British Virgin Islands, by and through its agents Galina Zmievskaya, Nina Petrenko, Victor Petrenko and/or Joseph Lemire.

36. Upon information and belief, OCL is doing business in the State of New York and/or transacts business in the State of New

York and/or has done regular and continuing business with WME in the State of New York and/or business with others in the

State of New York for several years and/or was and/or is doing business related to Plaintiff in the State of New York and/or did

business related to Plaintiff in the State of New York when WME had represented Plaintiff as Plaintiff's talent agency.

37. Upon information and belief, Defendant Olympic Champions Limited (OCL2) is a corporation formed under the laws of

the State of Delaware, by and through its agents Galina Zmievskaya, Nina Petrenko, Victor Petrenko and/or Joseph Lemire.

38. Upon information and belief, OCL2 is doing business in the State of New York and/or transacts business in the State of

New York and/or has done regular and continuing business with WME in the State of New York and/or business with others in

the State of New York for several years and/or was and/or is doing business related to Plaintiff in the State of New York and/

or did business related to Plaintiff in the State of New York when WME had represented Plaintiff as Plaintiff's talent agency.


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39. Upon information and belief, Defendant Ukrainian Financial Group JSC (UFG) is a public limited company formed under

the laws of the Ukraine by and through its agent(s) Joseph Lemire and/or Valery G. Babich.

40. Upon information and belief, UFG is doing business in the State of New York and/or transacts business in the State of

New York and/or has done regular and continuing business with WME and/or OCL and/or OCL2 and/or Western Union in theState of New York and/or business with others in the State of New York for several years and/or was and/or is doing business

related to Plaintiff in the State of New York and/or did business related to Plaintiff in the State of New York when WME had

represented Plaintiff as Plaintiff's talent agency.

41. Defendant Galina Zmievskaya (Zmievskaya) is an adult individual that was Plaintiff's coach and is and/or was an agent

for OCL and/or OCL2.

42. Upon information and belief, Zmievskaya is doing business in the State of New York and/or transacts business in the State

of New York and/or has done regular and continuing work for OCL and/or OCL2 in the State of New York and/or business

with WME and/or OCL and/or OCL2 in the State of New York and/or business with others in the State of New York for several

years and/or was and/or is doing business related to Plaintiff in the State of New York and/or did business related to Plaintiffin the State of New York when WME had represented Plaintiff as Plaintiff's talent agency.

43. Defendant Victor Petrenko (Petrenko) is an adult individual and is and/or was an agent for OCL and/or OCL2.

44. Upon information and belief, Petrenko is doing business in the State of New York and/or transacts business in the State of

New York and/or has done regular and continuing work for OCL and/or OCL2 in the State of New York and/or business with

WME and/or OCL and/or OCL2 in the State of New York and/or business with others in the State of New York for several

years and/or was and/or is doing business related to Plaintiff in the State of New York and/or did business related to Plaintiff

in the State of New York when WME had represented Plaintiff as Plaintiff's talent agency.

45. Defendant Nina Petrenko (N Petrenko) is an adult individual that serves and/or served as a bookkeeper for Plaintiff and/or OCL and/or OCL2 and/or UFG.

46. Upon information and belief, N Petrenko is doing business in the State of New York and/or transacts business in the State

of New York and/or has done regular and continuing work for OCL and/or OCL2 in the State of New York and/or business

with WME and/or OCL and/or OCL2 in the State of New York and/or business with others in the State of New York for several

years and/or was and/or is doing business related to Plaintiff in the State of New York and/or did business related to Plaintiff

in the State of New York when WME had represented Plaintiff as Plaintiff's talent agency.

47. Upon information and belief, Defendant PJSC Gala Radio (Gala Radio) is a company formed under the laws of the

Ukraine by and through its agent(s) Joseph Lemire and/or Valery G. Babich.

48. Upon information and belief, Gala Radio is doing business in the State of New York and/or transacts business in the State of

New York and/or did business with WME and/or OCL and/or OCL2 and/or UFG in the State of New York and/or business with

others in the State of New York for several years and/or was and/or is doing business related to Plaintiff in the State of New York

and/or did business related to Plaintiff in the State of New York when WME had represented Plaintiff as Plaintiff's talent agency.

49. Defendant Joseph Lemire (Lemire) is an adult individual, an attorney admitted in Texas and an agent for OCL and/or

OCL2 and/or UFG and/or Gala Radio.


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50. Upon information and belief, Lemire is doing business in the State of New York and/or transacts business in the State of

New York and/or has done regular and continuing work for OCL and/or OCL2 and/or UFG and/or Gala Radio in the State of

New York and/or business with WME and/or OCL and/or OCL2 and/or UFG and/or Gala Radio in the State of New York and/

or business with others in the State of New York for several years and/or was and/or is doing business related to Plaintiff in

the State of New York and/or did business related to Plaintiff in the State of New York when WME had represented Plaintiffas Plaintiff's talent agency.

51. Defendant Valery G. Babich aka Vladislav V. Babych (Babich) is an adult individual and an agent of UFG.

52. Upon information and belief, Babich is doing business in the State of New York and/or transacts business in the State of

New York and/or has done regular and continuing work for UFG and/or Gala Radio in the State of New York and/or business

with WME and/or UFG and/or Gala Radio in the State of New York and/or business with others in the State of New York for

several years and/or was and/or is doing business related to Plaintiff in the State of New York and/or did business related to

Plaintiff in the State of New York when WME had represented Plaintiff as Plaintiff's talent agency.

53. Zmievskaya, Petrenko, N Petrenko and/or Joseph Lemire are collectively referred to as OCL Agents (OCL Agents).

54. Babich and Lemire are collectively referred to as UFG Agents (UFG Agents).

55. Upon information and belief, Marco Entertainment, Inc. (Marco) had been Petrenko's talent agency and/or manager.

56. Upon information and belief, Defendant Key Brand Entertainment Inc. (KBE) is the result of a consolidation or merger of

KBE, Marco Entertainment, Inc. (Marco) and/or Magicworks Entertainment Inc. and/or other entities and/or KBE expressly

and/or impliedly assumed the tort liabilities of Marco and/or KBE is a mere continuation of Marco.

57. KBE is registered to do business and doing business in New York County, State of New York.

58. Upon information and belief, KBE is the successor in interest to Marco. Marco and KBE shall collectively and individually

henceforth be referred to as KBE (KBE).

59. KBE was doing business related to Plaintiff in the State of New York and/or did business related to Plaintiff in the State of

New York when WME had represented Plaintiff as Plaintiff's talent agency.

60. Upon information and belief, Defendant Michael Rosenberg (M Rosenberg) is an adult individual who was employed by

KBE and was a talent agent and/or manager for Petrenko.

61. Upon information and belief, M Rosenberg is doing business in the State of New York and/or transacts business in the

State of New York and/or has done regular and continuing work for Marco and/or Magicworks Entertainment Inc. and/or KBE

in the State of New York and/or business with others in the State of New York for several years and/or was doing business

related to Plaintiff in the State of New York and/or did business related to Plaintiff in the State of New York when WME had

represented Plaintiff as Plaintiff's talent agency.

62. Upon information and belief, Defendant Nancy Rosenberg (N Rosenberg) is an adult individual who was employed by

KBE and was a talent agent and/or manager for Petrenko.

63. Upon information and belief, N Rosenberg is doing business in the State of New York and/or transacts business in the State

of New York and/or has done regular and continuing work for Marco and/or Magicworks Entertainment Inc. and/or KBE in the


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State of New York and/or business with others in the State of New York for several years and/or was doing business related to

Plaintiff in the State of New York and/or did business related to Plaintiff in the State of New York when WME had represented

Plaintiff as Plaintiff's talent agency.

64. As shall be explained below, over the period from 1993 to present, the following individuals and/or entities: WME, Schultz,Carlisle, Griffin, Dworkin, Hersh, WSB, Black, Wallin, Suskind, OCL, OCL2, UFG, Zmievskaya, Petrenko, N Petrenko, Gala

Radio, Lemire, Babich, KBE, M Rosenberg and/or N Rosenberg; were and/or are persons associated with a criminal enterprise

(Promises Broken) in a pattern of mail fraud, wire fraud, bank fraud, money laundering, interstate transportation of stolen

property, theft and/or obstruction of justice against Plaintiff.

Factual Background

65. On February 23 and 25, 1994, in two of the most watched television performances in history, 1993 World Champion

Ukrainian figure skater Plaintiff Oksana Baiul competed for and ultimately won the Olympic Gold Medal in Ladies Figure

Skating at the Seventeenth Winter Olympics in 1994.

66. As a result of years of training culminating in Plaintiff's World and Olympic championships, Oksana Baiul became a

global household name.

67. As a further result of Plaintiff's professional success, advertisers, film, television, and stage producers, fashion companies,

jewelry companies, book, periodical, and newspaper publishers, as well as talent agents, sought to affiliate with Plaintiff.

68. In the nearly two decades since her historic performances on February 23 and 25, 1994, Plaintiff has appeared and

performed in innumerable television, film, and stage productions; been featured in a broad range of television, radio and print

advertisements; authored two (2) books, both of which made bestseller lists; and promoted fashion and jewelry lines.

69. Upon information and belief, the OCL Agents and/or the UFG Agents had an agreement sometime in 1994 with StephenFish (Fish) and/or Robert Young (Young) whereby OCL, the OCL Agents, UFG and/or the UFG Agents would own part of

the International Skating Center of Connecticut and/or receive other compensation if they brought Plaintiff to live in Simsbury,

Connecticut and to exclusively train at the International Skating Center of Connecticut.

70. Plaintiff was the most famous and most popular figure skating star in the world at the time and upon information and belief,

Fish and Young wanted the Plaintiff to train exclusively at the International Skating Center of Connecticut in order to promote

this new, state-of-the-art facility that Fish and/or Young were building.

71. The OCL Agents and/or the UFG Agents moved Plaintiff, a minor, from the Ukraine to Simsbury, Connecticut in 1994 to

train at the International Skating Center of Connecticut.

72. As a means to control Plaintiff, Zmievskaya kept Plaintiff's passport.

73. Plaintiff should have been the individual compensated by Fish and/or Young.

74. Plaintiff received no ownership or shares in the International Skating Center of Connecticut.


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75. Upon information and belief, the OCL Agents and/or the UFG Agents stole from Plaintiff whatever compensation and/

or ownership and/or shares provided by Fish and/or Young for Plaintiff to reside in Simsbury, Connecticut and to train at the

International Skating Center of Connecticut and Plaintiff has been damaged by this theft.

76. Plaintiff was a minor immigrant, from a country in economic turmoil after the collapse of the Soviet Union, who did not didnot speak, read or understand English and did not understand the criminal acts of Zmievskaya and/or other persons associated

with Promises Broken.

77. Upon information and belief, Plaintiff's stolen monies were held in federally insured banks and were knowingly and/or

fraudulently transferred interstate and/or internationally by the OCL Agents and/or the UFG Agents

78. Upon information and belief, Plaintiff's stolen shares were knowingly and/or fraudulently transferred interstate and/or

internationally by OCL Agents and/or the UFG Agents.

79. On or about May 9, 1994, less than three months after Plaintiff won her Olympic Championship in front of approximately

60% of the worldwide television-watching audience, WME and the WME Agents executed several agreements, with all or mostof them on WMA letterhead for the William Morris Agency, Inc; 1350 Avenue of the Americas; New York, NY 10019, with

the then sixteen (16) year-old (born on XX/XX/1977 in the Ukraine), non-English speaking, understanding or reading Plaintiff

who was not represented by counsel or a legal guardian.

80. Upon information and belief, all of the aforementioned agreements were executed by WME in New York County, State

of New York.

81. On or about May 9, 1994, Plaintiff and WME executed the following agreements:

a. General Materials and Packages granting WME the exclusive right to represent Plaintiff in all fields and media, throughout

the world, attached hereto as Exhibit 1 (hereinafter Package Agency Contract).

b. Authorization appointing WME as Plaintiff's attorney-in-fact, authorizing WME to collect monies on behalf of Plaintiff,

authorizing WME to deduct commissions from such monies collected and requiring WME transfer the balance of all monies

collected to Plaintiff personally, attached hereto as Exhibit 2 (hereinafter Authorization).

c. Standard AFTRA Exclusive Agency Contract employing WME as Plaintiff's sole and exclusive Agent in the transcription,

radio broadcasting and television industries within the scope of the Regulation (Rule 12-B) of the American Federation of

Television and Radio Artist, attached hereto as Exhibit 3 (hereinafter Television Contract).

d. SAG Motion Picture/Television Agency Contract engaging WME as Plaintiff's agent for the following fields as defined in

the Screen Actors Guild Codified Agency Regulations, Rule 16 (g) and WME accepted such engagement: Theatrical Motion

Pictures; Television Motion Pictures, attached hereto as Exhibit 4 (hereinafter Film Contract).

e. Exclusive Management Contract Under Equity Agency Regulations engaging WME as Plaintiff's sole and exclusive agent

in the legitimate theatre industry, attached hereto as Exhibit 5 (hereinafter Stage Contract).

f. General Services Agreement engaging WME as Plaintiff's sole and exclusive agent, adviser, and representative with

respect to Plaintiff's services, activity and participation in all branches of the entertainment, publication and related fields

throughout the world, attached hereto as Exhibit 6 (hereinafter General Services Agreement).


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82. Also on or about May 9, 1994, WME executed agreements with and among: (A) UFG, by and through its agent Lemire, and

(B) OCL, by and through its agents Zmievskaya, Petrenko and/or Lemire and (C) unknowingly by Plaintiff. Those agreements

were as follows:

a. A confidential agreement granting WME five percent (5%) of OCL's gross compensation for the services of Plaintiff for

existing offers for skating tours in 1994 and from which WME would have to pay UFG two percent (2%) of OCL's grosscompensation for the services of Plaintiff for existing offers for skating tours in 1994 attached hereto as Exhibit 7 (hereinafter

Skating Tour Agreement).

b. General Services Agreement appointing WME as Plaintiff's sole and exclusive agent, adviser, and representative with

respect to Plaintiff's services, activity and participation in all branches of the entertainment, publication, and related fields

throughout the world, including but not limited to merchandising, testimonials and commercial tie-ups, whether or not using

Plaintiff's name, voice or likeness, attached hereto as Exhibit 8 (hereinafter OCL General Services Agreement).

c. Deferment Agreement setting forth a schedule to compensate OCL for payments relating to dramatic special and series,

variety specials and series, animated specials and series, mini-series, and movies for television, attached hereto as Exhibit

9 (hereinafter Deferment Agreement).

83. Upon information and belief, on or about June 22, 1993, Plaintiff was allegedly paid $75000 by wire transfer for Plaintiff's

work on the Tom Collins Shows but Plaintiff never received such funds and believes that this $75,000 was stolen from Plaintiff

by Zmievskaya, Petrenko, N Petrenko and/or Lemire.

84. Upon information and belief, on or about April 26, 1994, KBE received by interstate mail check #5667 in an amount of

$104,000 drawn on a federally insured bank and this $104,000 check was money stolen from Plaintiff by KBE, M Rosenberg

and/or N Rosenberg since it was Plaintiff's earnings from the Tom Collins Shows but Plaintiff had never authorized that KBE,

M Rosenberg and/or N Rosenberg be paid for Plaintiff's work.

85. Upon information and belief, on or about May 11, 1994, KBE received by interstate mail check #5716 in an amount of

$96,000 drawn on a federally insured bank and this $96,000 check was money stolen from Plaintiff by KBE, M Rosenberg and/

or N Rosenberg since it was Plaintiff's earnings from the Tom Collins Shows but Plaintiff had never authorized that KBE, M

Rosenberg and/or N Rosenberg be paid for Plaintiff's work.


$72,000 drawn on a federally insured bank and this $72,000 check was money stolen from Plaintiff by KBE, M Rosenberg and/

or N Rosenberg since it was Plaintiff's earnings from the Tom Collins Shows but Plaintiff had never authorized that KBE, M

Rosenberg and/or N Rosenberg be paid for Plaintiff's work.


$288,000 drawn on a federally insured bank and this $288,000 check was money stolen from Plaintiff by KBE, M Rosenberg

and/or N Rosenberg since it was Plaintiff's earnings from the Tom Collins Shows but Plaintiff had never authorized that KBE,

M Rosenberg and/or N Rosenberg be paid for Plaintiff's work.

88. Upon information and belief, on or about July 21, 1994, WME received a wire transfer in an amount of $205,000 through a

federally insured bank and this $205,000 wire transfer was money stolen from Plaintiff by WME since it was Plaintiff's earnings

from the Tom Collins Shows but Plaintiff never received this $205,000 less commissions from WME.


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89. On or about August 2, 1994, WME and/or one or more other persons associated with Promises Broken co-signed Mutual

Settlement and Release Agreements transferring no less than $200,000 that belonged to Plaintiff to settle a dispute between

UFG Agents, OCL Agents, Lemire, Babich, UFG, KBE, M Rosenberg and/or N Rosenberg.

90. Upon information and belief, on or about September 1994, Lemire stole $40,000 of Plaintiff's monies even though he knewthat Plaintiff was not personally involved in such dispute between legal strangers and/or that Plaintiff had no knowledge that

Plaintiff's funds were being used to settle a dispute between legal strangers and/or that Plaintiff had not even signed the Mutual

Settlement and Release Agreements.

91. Upon information and belief, on or about September 1994, Lemire and/or one or more other persons associated with Promises

Broken knowingly and/or fraudulently transferred interstate and/or internationally, from a federally insured bank, the $40,000

stolen from Plaintiff and used such stolen funds to purchase the license(s) for Gala Radio in the Ukraine.

92. Upon information and belief, on or about November 1994, UFG stole $40,000 of Plaintiff's monies even though UFG knew

that Plaintiff was not personally involved in such dispute between legal strangers and/or that Plaintiff had no knowledge that

Plaintiff's funds were being used to settle a dispute between legal strangers and/or that Plaintiff had not even signed the MutualSettlement and Release Agreements.

93. Upon information and belief, on or about November 1994, UFG, Lemire and/or Babich and/or one or more other persons

associated with Promises Broken knowingly and/or fraudulently transferred interstate and/or internationally, from a federally

insured bank, the $40,000 stolen from Plaintiff and used such stolen funds to purchase the license(s) for Gala Radio.

94. Upon information and belief, Gala Radio is owned and/or controlled by Lemire and/or Babich and/or UFG.

95. Upon information and belief, Gala Radio is an extremely successful business.

96. Upon information and belief, Gala Radio is a premiere sponsor of the National Olympic Committee of the Ukraine for itsbid for the 2022 Winter Olympic Games.

97. Upon information and belief, Gala Radio only exists today because of monies stolen by UFG and/or Lemire and/or Babich

from Plaintiff, the Ukraine's first and only Winter Olympic Gold Medalist.

98. Upon information and belief, Lemire and/or Gala Radio has brought suit and won more than $12,000,000 in damages against

the Ukrainian government related to Gala Radio, Oksana Baiul Beauty Salons and/or Oksana Baiul real estate holdings.

99. Upon information and belief, Lemire has for many years (1993-present) misrepresented himself as Plaintiff's equal partner

in the above businesses and while substantial money and/or property stolen from Plaintiff by Lemire had been used to obtain

such businesses, Plaintiff currently has no ownership of such businesses.

100. Upon information and belief, Lemire, Gala Radio, Babich and/or UFG intentionally and substantially interfered with

Plaintiff's property by taking possession of and/or stealing monies and/or property worth no less than $15,000,000 from Plaintiff

in the Ukraine.

101. Upon information and belief, in September 1994, KBE, M Rosenberg and/or N Rosenberg stole $60,000 of Plaintiff's

monies even though one or more knew that Plaintiff was not personally involved in such dispute between legal strangers and/

or that Plaintiff had no knowledge that Plaintiff's funds were being used to settle a dispute between legal strangers and/or that

Plaintiff had not even signed the Mutual Settlement and Release Agreements.


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102. Upon information and belief, in September 1994, WME knowingly and/or fraudulently transferred to KBE by interstate

mail a check for $60,000 drawn on a federally insured bank and this $60,000 check was money stolen from Plaintiff by KBE,

M Rosenberg and/or N Rosenberg.

103. Upon information and belief, in November 1994, KBE, M Rosenberg and/or N Rosenberg stole $60,000 of Plaintiff's

monies even though one or more knew that Plaintiff was not personally involved in such dispute between legal strangers and/

or that Plaintiff had no knowledge that Plaintiff's funds were being used to settle a dispute between legal strangers and/or that

Plaintiff had not even signed the Mutual Settlement and Release Agreements.

104. Upon information and belief, in November 1994, WME knowingly and/or fraudulently transferred to KBE by interstate

mail a check for $60,000 drawn on a federally insured bank and this $60,000 check was money stolen from Plaintiff by KBE,

M Rosenberg and/or N Rosenberg.

105. On or about January 1997, while Plaintiff still did not competently read, speak or understand English, due to an unrelated

dispute, Plaintiff severed all ties with Zmievskaya, Petrenko, N Petrenko and Lemire.

106. Schultz, clearly operating in the interests of one or more persons associated with Promises Broken and/or WME, arranged

for WSB and/or Black to manage Plaintiff's business affairs going forward and thus conceal the prior criminal acts of one or

more persons associated with Promises Broken and/or WME.

107. On or about April 1997, Black demanded from Plaintiff a power of attorney and such power of attorney was used by Black

to conceal from Plaintiff criminal acts committed by one or more persons associated with Promises Broken including, but not

limited to, the transfer of Plaintiff's Connecticut house.

108. Additionally, in order to further conceal from Plaintiff the criminal acts committed by one or more persons associated

with Promises Broken, Black and Wallin appointed themselves in 1997 as treasurer and secretary of Plaintiff's new loan-outcompany, Oksana, LTD.

109. On May 9, 1997, Plaintiff who still did not competently read, speak, understand or otherwise communicate in English and

due to concealment by WME, Schultz, WSB and/or the CPA, Plaintiff had no knowledge of the criminal acts of one or more

persons associated with Promises Broken; Plaintiff and WME renewed all of the agreements.

110. In the Stage Contract, Defendants explicitly promised to maintain the relationship of a fiduciary to [Plaintiff]. (See

Exhibit 5).

111. Plaintiff was not given a fully executed copy of any of the agreements or the renewal agreements and Plaintiff only

discovered such agreements on or about November 2011 (Baiul Agreements).

112. At all relevant times hereto, Plaintiff exclusively relied upon one or more persons associated with Promises Broken for

business decisions including the interpretation of the Baiul Agreements.

113. Mr. Carlo J. Farina (Farina) began working as Plaintiff's business manager in the latter half of 2011.

114. Because it appeared to Farina that Plaintiff had had several extremely successful films and/or audio-visual works that were

(and still are) being licensed worldwide, Farina began to investigate Plaintiff's royalties and residuals.


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115. Farina contacted SAG, WSB, the CPA and/or WME for all documentation and explanations.

116. Farina proceeded to request documents from SAG, WSB, the CPA, WME and/or other parties including, but not limited

to, Plaintiff's earnings history report.

117. On November 19, 2011, Plaintiff received from WME, by e-mail, Plaintiff's Earnings History Report (EHP) dated

November 18, 2011 for the period from December 29, 1991 through December 26, 2009.

118. Almost all of the earnings on the EHP were attributed to WME's offices in the State of New York.

119. The EHP was part of a scheme or artifice to defraud Plaintiff and was intended by WME to defraud Plaintiff into believing

that Plaintiff had no other historical income from the period during which WME had represented Plaintiff as Plaintiff's talent

agents and/or related to transactions executed while WME had represented Plaintiff as Plaintiff's talent agents.

120. The EHP was false and thus fraudulent.

121. Plaintiff relied on the fraudulent EHP.

122. Plaintiff would have taken actions sooner to recover monies owed to Plaintiff had it not been for the fraudulent EHP and

Plaintiff has suffered damages because of the fraudulent EHP.

123. Over the next few weeks, Farina reviewed the EHP and began to realize that something was very wrong.

124. Farina contacted WME over the next several months in hopes of receiving some logical explanation concerning the material

discrepancies in the EHP.

125. In mid-November 2011, Farina contacted WSB and requested, with a letter signed by Plaintiff, Plaintiff's documents and/or accounting records and especially for the year 1997.

126. On or about December 6, 2011, Farina contacted WSB again but was informed by Alan Suskind at WSB that Plaintiff's

1997 documents and/or accounting records had been shredded. Luckily, one or more critical documents from 1997 and before,

such as the $11,045.70 Sony Agreement Royalty Payment that does not exist on the EHP (see Exhibit 13), had been misfiled

by WSB in a folder or folders for subsequent years that were provided to Plaintiff between December 6, 2011 through May

2012 with Plaintiff's documents and/or accounting records for the years 1998 and later.

127. From on or about December 6, 2011 through May 2012, WSB sent by mail to Plaintiff some documents and/or accounting

records but such documents and/or accounting records could not explain the discrepancies in the EHP (WSB Documents).

128. The WSB documents were part of a scheme or artifice to defraud Plaintiff and were intended by WSB to defraud the Plaintiff

into believing that Plaintiff had no other income, historical or otherwise, except that represented by the WSB Documents and/

or the EHP.

129. Upon information and belief, some or all of the WSB Documents were false and/or misleading and/or incomplete and

thus fraudulent.

130. Upon information and belief, WSB corruptly destroyed Plaintiff's documents and/or accounting records for the year 1997

in order to protect WME and/or one or more of the other persons associated with Promises Broken.


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131. Plaintiff relied on the WSB Documents.

132. Plaintiff would have taken actions sooner to recover monies owed to Plaintiff had it not been for the fraudulent WSB

Documents and/or the destruction of documents by WSB and Plaintiff has suffered damages because of the fraudulent WSBdocuments and/or the corrupt destruction of documents by WSB.

133. Farina later realized that the EHP did not include earnings from A Promise Kept: The Oksana Baiul Story (A Promise

Kept), the Sony Signatures Merchandising License Agreement (Sony Agreement), the Wizard of Oz on Ice (Wizard

of Oz), the HealthRider Infomercial and other sources of earnings and Farina did not learn about missing earnings from the

Nutcracker On Ice starring Oksana Baiul and Victor Petrenko (Nutcracker 1) and/or the Nutcracker On Ice starring

Oksana Baiul and Brian Boitano (Nutcracker 2) until on or about October 2012. Farina informed Plaintiff after each discovery.

134. Farina later realized that there was $5,016,255 on Plaintiff's EHP that Plaintiff had never received from WME.

135. Farina contacted WME again but WME would not take or return his calls after Farina had raised the above issues.

136. Upon information and belief, since WME began representing Plaintiff on May 9, 1994, WME would have sent Plaintiff

by mail and/or wire at least 20 fraudulent earnings history reports over the period from May 9, 1994 through June 2000 (20+

Reports).

137. WME and/or one or more other persons associated with Promises Broken, intended not to report to Plaintiff the Plaintiff's

earnings from A Promise Kept, the Nutcracker 1, the Nutcracker 2, the Sony Agreement, the Wizard of Oz, the HealthRider

Infomercial and other sources of earnings.

138. Upon information and belief, since the 20+ Reports did not include earnings from A Promise Kept, the Nutcracker 1, the

Nutcracker 2, the Sony Agreement, the Wizard of Oz, the Healthrider Infomercial and other sources of earnings; each and everyone of the 20+ Reports that was sent by WME would have been a part of a scheme or artifice to defraud Plaintiff.

139. Upon information and belief, WSB and/or the CPA were clearly aware of the scheme or artifice to defraud Plaintiff by

WME and/or one or more other persons associated with Promises Broken and WSB and/or the CPA were actively involved

in such scheme or artifice to defraud Plaintiff.

140. Plaintiff never personally received any of the fraudulent 20+ Reports but instead was forced to rely upon the

misrepresentations and/or concealment carried out by WSB and/or the CPA acting on behalf of WME and/or one or more other

persons associated with Promises Broken.

141. Upon information and belief, WME, the WME Agents, OCL, OCL2, the OCL Agents, UFG and/or the UFG Agents did

from May 1994 to the date of this Complaint misrepresent and/or conceal from Plaintiff the prior wrongdoings and/or criminal

acts of one or more persons associated with Promises Broken, WME, the WME Agents, OCL, OCL2, the OCL Agents, UFG,

Gala Radio, the UFG Agents, KBE, M Rosenberg and/or N Rosenberg.

142. Plaintiff would have taken actions sooner to recover monies owed to Plaintiff had it not been for the misrepresentations

and/or concealment carried out by WME, the WME Agents, OCL, OCL2, the OCL Agents, UFG, and/or the UFG Agents acting

on behalf of WME and/or one or more persons associated with Promises Broken.


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143. Upon information and belief, WME, the WME Agents, OCL, OCL2, the OCL Agents, UFG, the UFG Agents, WSB, and/

or the CPA did from April 1997 to today misrepresent and/or conceal from Plaintiff the prior wrongdoings and/or criminal acts

of one or more persons associated with Promises Broken, WME, the WME Agents, OCL, OCL2, the OCL Agents, UFG, Gala

Radio, the UFG Agents, KBE, M Rosenberg and/or N Rosenberg.

144. Plaintiff would have taken actions sooner to recover monies owed to Plaintiff had it not been for the misrepresentations

and/or concealment carried out by WME, the WME Agents, OCL, OCL2, the OCL Agents, UFG, the UFG Agents, WSB and/

or the CPA acting on behalf of WME and/or one or more persons associated with Promises Broken.

145. Upon information and belief, there have been numerous interstate and/or international wire transfers, checks and/or money

transfers, over the last 18 or more years, executed by one or more persons associated with Promises Broken of money stolen

from Plaintiff in the United States involving the Bank of New York Mellon, the Bank of Boston Connecticut, Barclay's Bank,

Fleet Bank, Chase Bank, Bank of America, Bank of Boston Connecticut Private Wealth Management and/or Western Union.

146. Upon information and belief, some or all of the aforementioned banks are federally insured.

147. Upon information and belief, from May 9, 1997 to present, one or more persons associated with Promises Broken are

occasionally transferring, interstate and/or internationally, through US Trust, Barclay's Bank, Western Union and/or other banks

monies derived from the illegal acts carried out by one or more persons associated with Promises Broken against Plaintiff.

148. Upon information and belief, some or all of the aforementioned banks are federally insured.

149. What follows now are five major films and/or audio-visual works and/or agreements involving millions of dollars that

one or more of the persons associated with Promises Broken stole from Plaintiff and/or earnings that were not disclosed on the

fraudulent EHP and, upon information and belief, had not been disclosed on any of the 20+ Reports.

150. Plaintiff's interest in the film A Promise Kept that was produced in 1994 is documented by the agreement (PK Agreement)that was only discovered by Plaintiff on or about November 2011 attached hereto as Exhibit 10.

151. Despite the fact that A Promise Kept was Plaintiff's life story; WME, WME Agents, the OCL Agents and/or the UFG

Agents caused the producer of A Promise Kept to execute the PK Agreement with OCL for all rights and compensation due

to Plaintiff with the exception of amounts required to be paid directly for pension and welfare in accordance with the SAG

collective bargaining agreement.

152. As part of a scheme or artifice to defraud Plaintiff, WME, WME Agents, the OCL Agents, the UFG Agents and/or one or

more persons associated with Promises Broken caused Petrenko, Zmievskaya's son-in-law who is/was married to Zmievskaya's

daughter N Petrenko, to be included, to the detriment of Plaintiff, in the PK Agreement even though A Promise Kept was

Plaintiff's life story and in which Petrenko had had a negligible role, if any, in Plaintiff's real life to that date since Plaintiff had

only met Petrenko about one year before the Olympics and Petrenko was not nearly as big a star as Plaintiff.

153. There exists no valid basis as to why WME, the WME Agents, the OCL Agents, the UFG Agents and/or one or more

other persons associated with Promises Broken could have expected or should expect Plaintiff to share any compensation and/

or royalties from A Promise Kept with Petrenko and any and all amounts paid and/or payable to Petrenko are a theft of monies

from Plaintiff and Plaintiff has been damaged by such theft.

154. Upon information and belief, Plaintiff's stolen monies, held in federally insured banks, were knowingly and/or fraudulently

transferred interstate and/or internationally by WME and/or one or more other persons associated with Promises Broken.


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155. As part of a scheme or artifice to defraud Plaintiff, WME, WME Agents, the OCL Agents, the UFG Agents and/or one

or more persons associated with Promises Broken caused Zmievskaya to be included in the PK Agreement even though A

Promise Kept was Plaintiff's life story and in which Zmievskaya had had only a small role in Plaintiff's real life having only

met Plaintiff about one year before the Olympics.


persons associated with Promises Broken could have expected Plaintiff to share any compensation and/or royalties from A

Promise Kept with Zmievskaya and any and all amounts paid and/or payable to Zmievskaya are a theft of monies from Plaintiff

and Plaintiff has been damaged by such theft.



158. Under Section 2 of the PK Agreement (see Exhibit 10), OCL, and thus Plaintiff, is entitled to receive as a continuing

royalty of 30% of 100% of first dollar adjusted gross income at the source for A Promise Kept.

159. Under Section 4 of the PK Agreement (see Exhibit 10), Zmievskaya took a pay-or-play fee of $50,000 for ice staging

the skating sequences.

160. Many skating choreographers could have competently done the ice staging for the skating sequences for as little as $5,000.

161. The $50,000 fee for Zmievskaya was and is a theft of at least $45,000 from Plaintiff since it reduced the amount that

Plaintiff would be paid for A Promise Kept by $45,000 and Plaintiff has been damaged by such theft.



163. Only two days after the initial Baiul Agreements were signed, under Section 5 of the PK Agreement (see Exhibit 10),

WME took fees as the TV packaging agent for A Promise Kept equal to 6% of the network license fee plus 10% of adjusted

gross receipts.

164. OCL was paid $500,000 by WME as Plaintiff's compensation for A Promise Kept but Plaintiff never received any of these

funds and they were never reported to Plaintiff by WME, OCL, OCL2 or WSB.

165. OCL, the OCL Agents, UFG and/or the UFG Agents stole this $500,000 from Plaintiff.

166. WME aided and abetted in this theft of $500,000 from Plaintiff.

167. Upon information and belief, Plaintiff's stolen $500,000, held in a federally insured bank(s), was knowingly and/or

fraudulently transferred interstate and/or internationally by WME and/or persons associated with Promises Broken.

168. So while WME had managed to negotiate itself a favorable agreement as the TV packaging agent after only two days of

work, WME failed to collect and transfer to Plaintiff any monies (including compensation, royalties and/or residuals) that were

due to Plaintiff under the PK Agreement as WME was required to do as Plaintiff's agent.


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169. Upon information and belief, WME, OCL, OCL2, Zmievskaya and/or Petrenko were all paid for A Promise Kept from

monies that WME had collected on Plaintiff's behalf however Plaintiff was never paid for A Promise Kept despite the fact that

Plaintiff's Authorization (see Exhibit 2) required WME to collect monies on behalf of Plaintiff, deduct WME's commissions,

if any, from such monies collected and then transfer to Plaintiff personally the balance of all monies collected.

170. The transfer to legal strangers by WME of $500,000 of monies due and payable to Plaintiff was a theft of monies from

Plaintiff by one or more persons associated with Promises Broken and/or WME and Plaintiff has been damaged by such theft.

171. Upon information and belief, one or more persons associated with Promises Broken and/or WME sent the PK Agreement

by mail and/or fax to various parties.

172. The PK Agreement was fraudulent because it falsely allowed for the theft of monies from Plaintiff by WME, OCL, OCL2,

Zmievskaya, Petrenko, N Petrenko, Lemire, Babich, UFG and/or one or more other persons associated with Promises Broken.

173. As part of a scheme or artifice to defraud Plaintiff, WME transferred to legal strangers monies owed to Plaintiff under the

PK Agreement and any and all such transfers would constitute a theft of monies from Plaintiff and Plaintiff has been damagedby such theft.

174. Any and all money transfers and/or payments of Plaintiff's monies under the PK Agreement made by WME to legal

strangers would have been done by wire transfer and/or by check sent by mail.

175. Any and all amounts of Plaintiff's monies under the PK Agreement sent to legal strangers by WME without Plaintiff's

written authorization, by wire transfer and/or by check sent by mail would have been fraudulent and also would have been a

theft(s)of monies from Plaintiff.



177. Upon information and belief, A Promise Kept is still being licensed through the date of this Complaint.

178. Upon information and belief, through the date of this Complaint, WME should still be collecting royalties on behalf of

Plaintiff for A Promise Kept and transferring such monies to Plaintiff personally in accordance with the terms of Plaintiff's

Authorization (see Exhibit 2).

179. Plaintiff has never received any accounting for A Promise Kept from WME, OCL, OCL2, WSB or SAG.

180. Plaintiff only discovered on or about December 2011 that A Promise Kept was subject to the SAG collective bargaining

agreement.

181. Plaintiff was an actor and stunt performer in A Promise Kept.

182. Plaintiff is a member of SAG.

183. Plaintiff was a minor at the time that A Promise Kept was produced.

184. Plaintiff is a Ukrainian immigrant.


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185. Plaintiff is a figure skater.

186. As an actor and/or stunt performer in A Promise Kept, Plaintiff should have received no less than the minimum

compensation and pension, health and welfare contributions as specified in the applicable SAG collective bargaining agreement.

187. As an actor and/or stunt performer in A Promise Kept, Plaintiff should have received and/or still be receiving residuals

under the applicable SAG collective bargaining agreement.

188. Upon information and belief, for A Promise Kept, one or more other actors (who were not Ukrainian immigrants, figure

skaters and/or minors) were paid compensation, one or more other actors (who were not Ukrainian immigrants, figure skaters

and/or minors) received their pension, health and welfare contributions, one or more other actors (who were not Ukrainian

immigrants, figure skaters and/or minors) have received residuals and one or more other persons (who were not Ukrainian

immigrants, figure skaters and/or minors) have received royalties.

189. Plaintiff never received any compensation, pension, health and welfare contributions, royalties or residuals from the

producers of A Promise Kept for A Promise Kept.

190. The failure by the producers of A Promise Kept to have paid minimum compensation, pension, health and welfare

contributions and residuals are serious and material breaches by the producers of the applicable SAG collective bargaining

agreement.

191. Plaintiff filed a claim with SAG for residuals for A Promise Kept on June 28, 2013.

192. Although A Promise Kept is Plaintiff's life story, to date, SAG has refused to provide any information on the claim other

than to inform Plaintiff that some residuals have been paid to other actor(s) on the film but SAG has indicated that Plaintiff,

a member of SAG, would have to serve SAG with a subpoena in order for SAG to produce any documents concerning A

Promise Kept.

193. Upon information and belief, SAG is not required to protect the interests of the producers but rather SAG is required to

enforce the terms of the applicable collective bargaining agreement on behalf of its members.

194. SAG's actions and/or inaction concerning Plaintiff's claim(s) for A Promise Kept are arbitrary. It is completely irrational

for SAG to not pursue Plaintiff's claim for a film in which Plaintiff was clearly an actor and stunt performer as a minor and

a film that was Plaintiff's life story.

195. Plaintiff has been subjected to discrimination by SAG because she is a Ukrainian immigrant, is a figure skater and/or was

a minor at the time that A Promise Kept was produced.

196. SAG has failed to provide Plaintiff with fair representation for A Promise Kept.

197. WME has intentionally and/or negligently failed in its fiduciary duties to Plaintiff as concerns A Promise Kept.

198. WSB has intentionally and/or negligently failed in its in its fiduciary duties to Plaintiff as concerns A Promise Kept.

199. Plaintiff's interest in Nutcracker 1 which was produced in 1994 and in which Plaintiff starred in the lead role as Clara, is

referenced in a production agreement between On Ice, Inc. (now known as Mendelson Entertainment Group) and NBC Sports

Ventures, Inc. (NOI Agreement) that Plaintiff only discovered on or about October 22, 2012, attached hereto as Exhibit 11.


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200. Plaintiff does not have and was never given by WME, or any other person associated with Promises Broken, her performer's

agreement for Nutcracker 1.

201. Upon information and belief, as part of a scheme or artifice to defraud Plaintiff, WME, the WME Agents, the OCL Agents,the UFG Agents and/or one or more other persons associated with Promises Broken caused Petrenko, Zmievskaya's son-in-law

who is/was married to Zmievskaya's daughter N Petrenko, to be included, to the detriment of Plaintiff, in the Nutcracker 1.



or royalties from Nutcracker 1 with Petrenko and any and all amounts paid and/or payable to Petrenko are a theft of monies


203. Upon information and belief, Plaintiff is owed significant monies for the Nutcracker 1.

204. Upon information and belief, Nutcracker 1 is still being licensed through the date of this Complaint.

205. Upon information and belief, through the date of this Complaint, WME should still be collecting royalties on behalf

of Plaintiff for Nutcracker 1 and transferring such monies to Plaintiff personally in accordance with the terms of Plaintiff's


206. Upon information and belief, as part of a scheme or artifice to defraud Plaintiff, WME transferred to legal strangers monies

owed to Plaintiff for Nutcracker 1 and any and all such transfers would constitute a theft of monies from Plaintiff and Plaintiff

has been damaged by such theft.

207. Any and all money transfers and/or payments of Plaintiff's monies for Nutcracker 1 made by WME to legal strangers

would have been done by wire transfer and/or by check sent by mail.

208. Any and all amounts of Plaintiff's monies for the Nutcracker 1 sent to legal strangers by WME without Plaintiff's written

authorization, by wire transfer and/or by check sent by mail would have been fraudulent and also would have been a theft(s)

of monies from Plaintiff.

209. Upon information and belief, Plaintiff's stolen monies, held in a federally insured bank(s), were knowingly and/or

fraudulently transferred interstate and/or internationally by WME and/or one or more persons associated with Promises Broken.

210. Upon information and belief, NBC Sports Ventures, Inc., NBC Sports and/or their parent company was a SAG signatory

at the time of production of Nutcracker 1.

211. Nutcracker 1 is and was advertised as a joint production of NBC Sports and On Ice, Inc. (now known as Mendelson

Entertainment Group).

212. Upon information and belief, since NBC Sports produced Nutcracker 1, Nutcracker 1 is and was subject to the applicable

SAG collective bargaining agreement.

213. Plaintiff was an actor and stunt performer in the Nutcracker 1.

214. Plaintiff was a minor at the time that the Nutcracker 1 was produced.


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215. As an actor and/or stunt performer in the Nutcracker 1, Plaintiff should have received no less than the minimum


216. As an actor and/or stunt performer in the Nutcracker 1, Plaintiff should have received and/or still be receiving residualsunder the applicable SAG collective bargaining agreement.

217. Plaintiff has never received any accounting for the Nutcracker 1 from WME, OCL, OCL2, WSB or SAG.

218. Plaintiff never received any compensation, royalties or residuals for Nutcracker 1 from WME or anybody else.

219. Upon information and belief, the producers for Nutcracker 1 breached the terms of the SAG collective bargaining

agreement.

220. Upon information and belief, SAG's actions and/or inaction concerning the producer's breaches are arbitrary.


a minor at the time that Nutcracker 1 was produced.

222. SAG has failed to provide Plaintiff with fair representation for Nutcracker 1.

223. WME has intentionally and/or negligently failed in its fiduciary duties to Plaintiff as concerns Nutcracker 1.

224. WSB has intentionally and/or negligently failed in its in its fiduciary duties to Plaintiff as concerns Nutcracker 1.

225. Plaintiff's interest in Nutcracker 2 which was produced in 1994 and in which Plaintiff starred in the lead role as Clara, is

referenced in a production agreement between On Ice, Inc. (now known as Mendelson Entertainment Group) and NBC SportsVentures, Inc. (NOI Agreement) that Plaintiff only discovered on or about October 22, 2012, attached hereto as Exhibit 11.

226. Plaintiff does not have and was never given by WME, or any other person associated with Promises Broken, her performer's

agreement for Nutcracker 2.

227. Upon information and belief, Plaintiff is owed significant monies for the Nutcracker 2.

228. Upon information and belief, Nutcracker 2 is still being licensed through the date of this Complaint.


of Plaintiff for Nutcracker 2 and transferring such monies to Plaintiff personally in accordance with the terms of Plaintiff's



owed to Plaintiff for Nutcracker 2 and any and all such transfers would constitute a theft of monies from Plaintiff and Plaintiff


231. Any and all money transfers and/or payments of Plaintiff's monies for Nutcracker 2 made by WME to legal strangers



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232. Any and all amounts of Plaintiff's monies for the Nutcracker 2 sent to legal strangers by WME without Plaintiff's written

authorization, by wire transfer and/or by check sent by mail would have been fraudulent and also would have been a theft(s)

of monies from Plaintiff.

233. Upon information and belief, Plaintiff's stolen monies, held in a federally insured bank(s), were knowingly and/orfraudulently transferred interstate and/or internationally by WME and/or on or more other persons associated with Promises

Broken.

234. Upon information and belief, NBC Sports Ventures, Inc., NBC Sports and/or their parent company was a SAG signatory

at the time of production of Nutcracker 2.

235. Nutcracker 2 is and was advertised as a joint production of NBC Sports and On Ice, Inc. (now known as Mendelson

Entertainment Group).

236. Upon information and belief, since NBC Sports produced Nutcracker 2, Nutcracker 2 is and was subject to the SAG

collective bargaining agreement.

237. Plaintiff was an actor and stunt performer in the Nutcracker 2.

238. Plaintiff was a minor at the time that the Nutcracker 2 was produced.

239. As an actor and/or stunt performer in the Nutcracker 2, Plaintiff should have received no less than the minimum


240. As an actor and/or stunt performer in the Nutcracker 2, Plaintiff should have received and/or still be receiving residuals


241. Plaintiff has never received any accounting for the Nutcracker 2 from WME, OCL, OCL2, WSB or SAG.

242. Plaintiff never received any compensation, royalties or residuals for Nutcracker 2 from WME or anybody else.

243. Upon information and belief, the producers for Nutcracker 2 breached the terms of the applicable SAG collective bargaining

agreement.

244. Upon information and belief, SAG's actions and/or inaction concerning the producer's breaches are arbitrary.


a minor at the time that Nutcracker 2 was produced.

246. SAG has failed to provide Plaintiff with fair representation for Nutcracker 2.

247. WME has intentionally and/or negligently failed in its fiduciary duties to Plaintiff as concerns Nutcracker 2.

248. WSB has intentionally and/or negligently failed in its in its fiduciary duties to Plaintiff as concerns Nutcracker 2.

249. In 1994, Sony Signatures, Inc. desired to obtain certain merchandising rights of Plaintiff.


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250. Plaintiff discovered on or about November 2011 a Merchandising License Agreement (Sony Agreement), attached hereto

as Exhibit 12.

251. WME, the WME Agents, the OCL Agents and/or the UFG Agents caused the Sony Agreement to be executed on or about

November 1, 1994 by and between Sony Signatures, Inc. (Sony) and OCL for all rights and compensation due to Plaintiff.

252. Upon information and belief, as part of a scheme or artifice to defraud Plaintiff by WME, WME Agents, the OCL Agents,

the UFG Agents and/or one or more other persons associated with Promises Broken, caused Petrenko, Zmievskaya's son-in-law

who is/was married to Zmievskaya's daughter N Petrenko, to be included, to the detriment of Plaintiff, in the Sony Agreement.

253. Upon information and belief, Plaintiff was the only figure skater at the time that had a merchandising and licensing

agreement with Sony Signatures and/or any major company similar to Sony Signatures, of course, with the exception of Petrenko

who had been fraudulently added to the Sony Agreement.

254. Upon information and belief, one or more persons associated with Promises Broken and/or WME sent the Sony Agreement

by mail and/or fax to various parties.

255. The Sony Agreement was fraudulent because it falsely provided for the theft of monies from Plaintiff by Petrenko, OCL

and/or one or more other persons associated with Promises Broken.



or royalties with Petrenko and any and all amounts paid and/or payable to Petrenko are a theft of monies from Plaintiff and

Plaintiff has been damaged by such theft.

257. Under Section 5.1 of the Sony Agreement (see Exhibit 12), OCL, and thus Plaintiff, was to receive an advance from Sony

of $100,000 within seven business days of execution of the Sony Agreement.

258. Under Section 5.2 of the Sony Agreement (see Exhibit 12), OCL, and thus Plaintiff, was to receive 90% of Gross Sales

from Tour Royalties.

259. Under Section 5.2.2 of the Sony Agreement (see Exhibit 12), OCL, and thus Plaintiff, was to receive 80% of Net Receipts

from sublicensees solicited by Sony and 90% of Net Receipts from sublicensees solicited by WME.

260. Under Section 5.2.3 of the Sony Agreement (see Exhibit 12), OCL, and thus Plaintiff, was to receive 60% of Net Profit

from the sale of Signatures Collectibles.

261. OCL, and thus Plaintiff, was to receive additional compensation for sales through other channels of distribution as specified

in Section 5.2.4 of the Sony Agreement (see Exhibit 12).

262. OCL, and thus Plaintiff, was to receive additional compensation under other Sections of the Sony Agreement.

263. Plaintiff alone is specified in Section 6.3 of the Sony Agreement (see Exhibit 12) as concerns when Sony has a right to

sell. This clearly indicates that Sony only cared about having the rights from Baiul whereas Petrenko was wrongly included,

to the detriment of Plaintiff, in the Sony Agreement by WME, WME Agents, the OCL Agents, the UFG Agents and/or one or

more other persons associated with Promises Broken in order to steal monies from Plaintiff.


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264. On March 14, 1995, Dworkin acting on behalf of WME wire transferred $11,045.70 to OCL with the reference Sony

Signature Series (Proof of Royalty Payment), attached hereto as Exhibit 13. This was clearly a royalty payment from

Sony and means that the $100,000 advance must have been paid by Sony prior to this date because Sony would not be paying

royalties if they had not already recouped the advance of $100,000 as specified in the Sony Agreement.

265. Upon information and belief, Plaintiff is owed significant monies under the Sony Agreement.

266. Any monies that WME received on behalf of Plaintiff under the Sony Agreement should have been transferred to Plaintiff

personally in accordance with the terms of Plaintiff's Authorization (see Exhibit 2).


owed to Plaintiff under the Sony Agreement and any and all such transfers would constitute a theft of monies from Plaintiff

and Plaintiff has been damaged by such theft.

268. Any and all money transfers and/or payments of Plaintiff's monies under the Sony Agreement made by WME to legal

strangers would have been done by wire transfer and/or by check sent by mail.

269. Any and all amounts of Plaintiff's monies under the Sony Agreement sent to legal strangers by WME without Plaintiff's

written authorization, by wire transfer and/or by check sent by mail would have been fraudulent and also would have been a

theft(s)of monies from Plaintiff.

270. Upon information and belief, Plaintiff's stolen monies, held in a federally insured bank(s), were knowingly and/or

fraudulently transferred interstate and/or internationally by WME and/or one or more other persons associated with Promises

Broken.

271. Plaintiff never received any monies under the Sony Agreement and no monies were ever reported to Plaintiff by WME,

OCL, OCL2 and/or WSB.

272. Plaintiff starred as Dorothy in the Wizard of Oz that was produced in 1995.

273. Plaintiff does not have and was never given by WME, or any other member of Promises Broken, her performer's agreement

for the Wizard of Oz.

274. Upon information and belief, as part of a scheme or artifice to defraud Plaintiff, WME, WME Agents, the OCL Agents,

the UFG Agents and/or one or more other persons associated with Promises Broken caused Petrenko, Zmievskaya's son-in-law

who is/was married to Zmievskaya's daughter N Petrenko, to be included, to the detriment of Plaintiff, in the Wizard of Oz.



or royalties from the Wizard of Oz with Petrenko and any and all amounts paid and/or payable to Petrenko are a theft of monies


276. Upon information and belief, Plaintiff is owed significant monies for the Wizard of Oz.

277. Upon information and belief, Wizard of Oz is still being licensed through the date of this Complaint.


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of Plaintiff for Wizard of Oz and transferring such monies to Plaintiff personally in accordance with the terms of Plaintiff's


279. Upon information and belief, as part of a scheme or artifice to defraud Plaintiff, WME transferred to legal strangers moniesowed to Plaintiff for Wizard of Oz and any and all such transfers would constitute a theft of monies from Plaintiff and Plaintiff


280. Any and all money transfers and/or payments of Plaintiff's monies for the Wizard of Oz made by WME to legal strangers


281. Any and all amounts of Plaintiff's monies for the Wizard of Oz sent to legal strangers by WME without Plaintiff's written

authorization, by wire transfer and/or by check sent by mail would have been fraudulent and also would have been a theft(s)of

monies from Plaintiff.

282. Upon information and belief, Plaintiff's stolen monies, held in a federally insured bank(s), were knowingly and/orfraudulently transferred interstate and/or internationally by WME and/or one or more other persons associated with Promises

Broken.

283. Upon information and belief, because the Wizard of Oz was a CBS television special, the production company was required

to be a SAG signatory and the production company was thus subject to the applicable SAG collective bargaining agreement.

284. Plaintiff was an actor and stunt performer in the Wizard of Oz.

285. Plaintiff was a minor at the time that the Wizard of Oz was produced.

286. As an actor and/or stunt performer in the Wizard of Oz, Plaintiff should have received no less than the minimumcompensation and pension, health and welfare contributions as specified in the applicable SAG collective bargaining agreement.

287. As an actor and/or stunt performer in the Wizard of Oz, Plaintiff should have received and/or still be receiving residuals


288. Plaintiff has never received any accounting for the Wizard of Oz from WME, OCL, OCL2, WSB or SAG.

289. Plaintiff never received any compensation, royalties or residuals for the Wizard of Oz and no compensation, royalties or

residuals were ever reported to Plaintiff by WME, OCL, OCL2, WSB and/or SAG for the Wizard of Oz.

290. Upon information and belief, the production company for the Wizard of Oz breached the terms of the SAG collective

bargaining agreement.

291. Upon information and belief, SAG's actions and/or inaction concerning the production company's breaches are arbitrary.


a minor at the time that the Wizard of Oz was produced.

293. SAG has failed to provide Plaintiff with fair representation for the Wizard of Oz.


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294. WME has intentionally and/or negligently failed in its fiduciary duties to Plaintiff as concerns the Wizard of Oz.

295. WSB has intentionally and/or negligently failed in its in its fiduciary duties to Plaintiff as concerns the Wizard of Oz.

296. One or more persons associated with Promises Broken and/or WME stole from Plaintiff, failed to account for and/or remitthe following payments to Plaintiff:

a. At least $5,016,255 reported by WME on Plaintiff's EHR but paid to persons associated with Promises Broken, their agents,

assigns, predecessors, or successors in interest.

b. At least $150,000 paid to one or more persons associated with Promises Broken, their agents, assigns, predecessors, or

successors in interest by QVC, Inc., Giovanni Jewelry Co., and Imperial Delta, Inc. for the Oksana Baiul Jewelry Collection.

c. All compensation paid to KBE, M Rosenberg, N Rosenberg and/or one or more other persons associated with Promises

Broken, their agents, assigns, predecessors or successors in interest earned from a multi-year, multi-million dollar endorsement

deal with Mars, Inc. and its predecessors in interest for Plaintiff's endorsement of Snickers brand candy bars.

d. At least $100,000 to be advanced to Plaintiff and all subsequent merchandising and/or licensing royalties under the Sony

Agreement.

e. Earnings of $500,000 from A Promise Kept.

f. Earnings, royalties, and/or residuals from film and television licenses for films and/or audio-visual works includ