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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Raymone K. Bain 4TTO Dexter Street, NW Washington, D.C. 20007 (Plaintiff) and Davis, Bain & Associates, Inc. 4770 Dexter Street, NW Washington, D.C. 20007 (Plaintiff) v. Civil Action No.: Michael J. Jackson 100 N. Carolwood Drive Los Angeles, CA 90077-3515 (Defendant) MJJ Productions, Inc. 562 Homewood Road. Los Angeles, CA 90049-1906 (Defendant) COMPLAINT Plaintiffs, Raymone K. Bain and Davis Bain & Associates (hereinafter collectively referred to as “Plaintiffs") complaint against Michael J. Jackson and MJJ Productions (hereinafter referred to collectively as “Defendants’) as follows: NATURE OF THE ACTION 4. This is an action for breach of contract, quantum meruit, and unjust enrichment under the laws and the common law of the District of Columbia. THE PARTIES Plaintiff, Raymone K. Bain, is a natural person and citizen of the District of Columbia. Ms. Bain is CEO and Co-Founder of the public relations firm of Davis, Bain & Associates, Inc., and President and COO of the Michael Jackson Company, LLC. In addition to International pop icon, Michael Jackson, Ms. Bain has represented many high profile public figures in the sports, entertainment and political fields including, 10-time Grammy-Award winning singer, songwriter, producer, and entertainment mogul, Kenneth “Babyface’ Edmonds; recording group Boyz Il Men; Janet Jackson; “The Kings of Comedy," a/k/a Steve Harvey, the late Bernie Mac, D.L. Hughley, and Cedric “The Entertainer’; the Estate of the late Sammy Davis, Jr.; Boxing legends “Marvelous” Marvin Hagler and Thomas “Hit Man’ Heams; top-ranked International tennis star Serena Williams; and former D.C. Mayor and current Washington D.C. City Council Member, Marion S. Barry, Jr. among many others. Plaintiff, Davis, Bain & Associates, Inc., is a corporation organized under the laws of the District of Columbia having a place of business at 4770 Dexter Street, NW, Washington, D.C. 20007. Defendant, Michael J. Jackson, (hereinafter Mr. Jackson) is a singer, songwriter, investor, collector, businessman, and international pop icon, who has sold over 1 billion records worldwide. Upon information and belief, Mr. Jackson, formerly residing in The Kingdom of Bahrain, Ireland, and Las Vegas, Nevada, is a resident, citizen and domiciliary of the State of California. Upon information and belief, Defendant MJJ Productions, Inc. is a California corporation at one time receiving mail, and having an address of 4770 Dexter Street, N.W. Washington, D.C. 20007. JURISDICTION This Court has jurisdiction over the parties and this action pursuant to 28 U.S.C. 1332, the Long-Arm Statute of the District of Columbia, and by contract, Venue is proper under 28 U.S.C. 1391. FACTS COMMON TO ALL COUNTS On or about December 2003, Mr. Jackson hired Davis, Bain & Associates, Inc., as his public relations firm and appointed Ms. Bain as his personal spokesperson and publicist. As his publicist, Ms. Bain performed public relations consultation services for Mr. Jackson including planning, coordination, and supervision of proactive media strategies; crisis management and damage control; preparation and distribution of press releases; and preparation of Promotional materials, supervision and coordination of media appearances, 3-