PSI T t

2 Randall B. Aiman-Smith #124599

Reed W.L. Marcy #191531 ELECTRON ICALLY
3 Hallie Von Rock #233152 FILED
Carey A. James #269270 Superior Court of California,
4 Brent A. Robinson #289373 County of San Francisco
7677 Oakport St. Suite 1150 08/24/2017
5 Oakland, CA 94621 Clerk of the Court
T 510.817.2711 BY:JUDITH NUNEZ
Deputy Clerk
6 F 510.562.6830

9 Cosio, on her own

behalf, and on behalf of other similarly situated
10 *Additional Counsel Listed on Next Page
11
SUPERIOR COURT OF CALIFORNIA
12
FOR THE CITY AND COUNTY OF SAN FRANCISCO
13
ANGELICA COSIO, an individual, on Case No. CGC-16-551337
14 her own behalf and on behalf of all
others similarly situated, DECLARATION OF TIA HEU
15
Plaintiff, The Honorable Curtis E.A. Karnow
16
Department 304
v.
17 Civic Center Courthouse
INTERNATIONAL PERFORMING 400 McAllister Street
18 ARTS ACADEMY, LLC, a California San Francisco, California 94102
limited liability company, BARBIZON
19 SCHOOL OF SAN FRANCISCO, Complaint Filed: April 6, 2016
INC., a California Corporation, a
20 California limited liability company,
BARBIZON SCHOOL OF SAN
21 FRANCISCO, INC., a California
corporation, LION MANAGEMENT
22 GROUP INC., a California corporation,
ANTHONY LOUIS LIONETTI,
23 LARRY D. LIONETTI, LENA
QUESADA LIONETTI, LENA M.
24 LIONETTI, and DOES 1-100,
inclusive,
25
Defendants.
26

27

28
Declaration of Angelica Cosio
Angelica Cosio, et at. v. International Pel/arming Arts Academy, LLC, et at. Case Number CGC-l6-551337
 Ethan Preston (263295)
PRESTON LAW OFFICES
2 4054 McKinney Avenue, Suite 310
Dallas, Texas 75204
3 (972) 564-8340 (telephone)
(866) 509-1197 (facsimile)
4
ep@eplaw.us
5
Zack Broslavsky (241736)
6 Jonathan A. Weinman (256553)
BROSLAVSKY & WEINMAN, LLP
7 1500 Rosecrans Ave., Suite 500
Los Angeles, CA 90266
8 (310) 575-2550 (telephone)
(310) 464-3550 (facsimile)
9 zbroslavsky@bwcounsel.com
jweinman@bwcounsel.com
10
David C. Parisi (162248)
11
Suzanne Havens Beckman (188814)
12 PARISI & HAVENS LLP
212 Marine Street, Suite 100
13 Santa Monica, California 90405
(818) 990-1299 (telephone)
14 (818) 50 1-7852 (facsimile)
dcparisi@parisihavens.com
15 shavens@parisihavens.com

16 Attorneys for Plaint(ffAngelica Cosio, on

her own beha(f; and beha(f of all others
17
similarly situated
18

19

20

21

22
23

24

25

26

27

28
Declaration of Angelica Cosio
Angelica Cosio, et at. v. International Pel/orming Arts Academy, LLC, et at. Case Number CGC-l6-551337
 DECLARA TION OF TIA REV
2
I, Tia Heu, declare:
3
1. I submit this declaration in the matter of Cosio v. International Performing
4
Arts Academy, LLC, et aI., currently pending before the California Superior Court for the
5
City and County of San Francisco, Case No. CGC-16-551337.
6
2. I am over 18 years of age and reside in the State of California. I base the
7
statements that follow on my personal knowledge. If called as a witness, I could and would
8
competently testify as follows.
9
3. I am employed as a molecular biologist, and I am mother of three children.
10
4. In 2014, my husband and I paid for my then seven-year-old daughter (who I
11
will refer to here as "Jane" to protect her privacy) to attend Barbizon classes in Stockton,
12
California. My husband and I paid for Jane to attend and audition at the January 2015
13
Showcase event in Los Angeles, California. In general, our experience with Barbizon was
14
negative and unsatisfactory.
15
5. Towards the end of July of2017, I received a telephone call from a woman
16
who said she worked for Barbizon. The caller identified herself though I have forgotten her
17
name. However, in a subsequent letter, attorney Bojana Rnjak identified herself as the
18
person who spoke to me in "our conversation" and, since I spoke with only one person, I
19
assume I spoke with Bojana Rnjak and I will refer to her by that name in this declaration.
20
6. Attached hereto as Exhibit A is a true and correct copy of the letter, with the
21
attached declaration, that I received from Ms Rnjak; my daughter's name has been redacted
22
to protect her privacy.
23
7. Ms Rnjak told me that she was conducting a survey on behalf of Barbizon's
24
owners who, she said, were aware that some customers were not happy with their experience
25
at Barbizon. Ms Rnjak said she wanted to get feedback from me regarding my family'S
26
experience so she that could write it all up and send it to the owners.
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et al. Case Number CGC-16-551337
Page 1
 8. Ms. Rnjak initially asked to speak with my daughter Jane directly about her
2 experiences with Barbizon and Showcase. Not least because my daughter is only IO-years
3 old, 1 refused and told her she should direct her questions to me instead.
4 9. Ms Rnjak did not identify herself as a lawyer or suggest that she might be a
5 lawyer; she did not say or indicate that she worked for a law firm; she did not say or indicate
6 that she was conducting an investigation related to a lawsuit; she did not say or indicate that
7 litigation was pending against Barbizon and that she wanted a declaration from me for that
8 lawsuit; she did not say or indicate that that the information she was gathering could be or
9 might be used in a lawsuit, or presented to a court; and she did not say or indicate anything
10 to suggest that there were attorneys for the plaintiffs that 1 could talk to. Rather, Ms Rnjak
11 posed as someone conducting a consumer satisfaction survey.
12 IO.My family's experiences with Barbizon and its Showcase were unpleasant and
13 not good and therefore 1 was very cautious about talking to anyone from Barbizon or a
14 related company. However, because 1 thought my input was being sought to improve the
15 program, 1 agreed to answer Ms Rnjak's questions.
16 11. Ms Rnjak proceeded to ask me a long series of questions which focused on the
17 dates that Jane attended Barbizon and the Showcase, how much my family paid, whether
18 anyone associated with Barbizon made any job offers to my family, other statements made
19 to our family, and whether anyone told my family that if we went to Barbizon's Showcase
20 that my daughter would get contracts with agents or managers.
21 12.1 answered each of her questions at length and to the best of my ability.
22 13. Ms Rnjak made it clear to me that she had talked to many other people about
23 these same issues because she talked about how my answers compared to other people's
24 answers. Specifical1y, Ms Rnjak expressed surprise at my lengthy answers and indicated
25 that most people responded simply with "yes" or "no" to the questions asked. 1 thought that
26 was strange, given that she told me she was seeking feedback and further because Ms Rnjak
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et al. Case Number CGC-16-551337
Page2
 was very insistent in asking for certain details, like asking me to give her the name of the
2 person who conducted the audition to attend the Showcase.
3 14. When Ms Rnjak finished her questions, she told me she needed to send me my
4 responses and have me sign them so she could submit them to the owners. Again, believing
5 that this was part of a customer satisfaction survey, I agreed and even offered to dig through
6 my records to try to find the names she was asking for. Ms Rnjak did not offer, or suggest,
7 that I could review a draft of my survey responses. However, I specifically asked her to
8 email me a draft of my survey response so I could fill in any missing details. I did not
9 provide her with my mailing address.
10 15. I was surprised when, a few days later I instead received a F edEx delivery at
11 my horne address from Ms Rnjak. When I opened the F edEx package, I was also surprised
12 to see that it contained a letter from someone in a law firm. When I read the letter and saw
13 the reference to "our conversation" I realized that the person who wrote the letter was the
14 same person that I had talked to on the telephone. Following the letter, I also saw a
15 document that looked like a legal document of some sort. This was completely inconsistent
16 with what Ms Rnjak had told me about a customer satisfaction survey.
17 16. Also, when I reviewed the document sent with the letter, that was supposed to
18 contain my thoughts and ideas about the Barbizon experience, it was completely inaccurate
19 and many of my statements had been reversed from negative statements to positive
20 statements that made it appear that I was endorsing Barbizon when I clearly told Ms Rnjak
21 that I was not happy with my experiences with Barbizon.
22 17. Nowhere in the FedEx package, or in the letter, or in the legal document was
23 this lawsuit, or this Court, or the plaintiffs' counsel identified or was any contact information
24 for the Court or plaintiffs' counsel provided. There was a "Case No." listed on the bottom of
25 the legal document, but I did not know what that referred to.
26 18. I Googled the law firm listed on Ms Rnjak's letter, Puttennan Landry + Yu
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et al. Case Number CGC-16-551337
Page3
 LLP ("Putterman"), and after additional research 1 discovered that there might be a pending
2 lawsuit against Barbizon. Until 1 did this internet research, 1 knew nothing about any such
3 lawsuit. As soon as 1 realized this, 1 was very upset because it looked like some of my
4 statements were falsified to support Barbizon when 1 had not done anything of the sort.
5 From this research 1 was able to find the name and contact information for plaintiffs' counsel
6 and 1 contacted them and asked for assistance.
7 19. The declaration attached to Ms Rnjak's letter contains many, many
8 inaccuracies. 1 will go through these one at a time below.
9 20. The Declaration throughout lists my last name as "Hell," yet my last name
10 actually is "Heu."
11 21. The Declaration states that "I live in Sacramento, California." (p. 1:3) This is
12 not true. 1 live in Stockton, California at the address where the Putterman firm sent the
13 Declaration.
14 22. The Declaration states that:
15 "[Jane] was approached by a Barbizon scout at a shopping center. The scout
16 gave us a flyer about the program and a list of upcoming auditions. 1 don't
17 recall what else was on the flyer. 1 don't believe it had pictures of past
18 participants or information on agents and managers. It was pretty
19 straightforward." (p. 1:4-7)
20 This is not true. 1 do remember what was on the "flyer" and 1 explained to Ms Rnjak
21 that the "flyer" was nothing more than a card containing an event invitation listing the date,
22 time, and location for an audition for the Barbizon program. There was no room on the card
23 for any pictures or other information.
24 23. IfMs Rnjak had inquired, 1 would have further explained that the "flyer"/card
25 was given to my husband by a talent scout, who approached Jane while we were shopping at
26 a Walmart. The scout told Jane that she had "the look," and the scout told Jane that she felt
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et at. Case Number CGC-16-551337
Page 4
 very strongly that Jane had the potential to be a model or in movies or on TV. The scout
2 told us that going to the Barbizon audition listed on the flyer/card was a way to get Jane into
3 the business. The scout mostly interacted with Jane and I distinctly remember that it
4 bothered me to have a stranger approach my daughter directly in a Walmart like that. Jane
5 who was seven years old - was very excited by all this, and my husband and I figured it
6 could not hurt, so we decided to attend the audition.
7 24. The Declaration states:
8 "The audition was mostly infonnational. We watched a very general video
9 about Barbizon." (p. 1:8-9.)
10 This is a true statement, as far as it goes, but it omits most of the infonnation that I provided
11 to Ms Rnjak and that gives a very different impression from what I actually said to her.
12 What I told Ms Rnjak was that at the audition, we watched a very glitzy video that, if you
13 watched it, you would think, "Wow, Barbizon is so cool! What a great company!" The video
14 shows that Barbizon has a lot of studios in Los Angeles that they own, and all these movies
15 that Barbizon has produced, and all these actors that have gone through Barbizon' s programs
16 and studios. The impression that I got from all of this was that the judges at the audition
17 were actual professionals in the entertainment industry. The message we received from the
18 presentation that day was that the easiest and quickest and perhaps the only way to get your
19 child into the television, movie, and modeling industry is through Barbizon.
20 25. If Ms Rnjak had inquired, I would have further explained that the scout that
21 had approached us at Walmart was at the audition, and she had all the kids who were scouted
22 line up, and then had them audition. She had the kids do a catwalk and had them deliver
23 lines from commercials. There were also "judges" at the audition. When my husband and I
24 met one of the judges, she gave us a business card and when we read the car it said that she
25 was an executive director for Barbizon. This judge told us that she directed the Pampers
26 commercials on TV. The scout, whose name was Charlie Petit, told us that Barbizon could
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et at. Case Number CGC-16-551337
Page 5
 introduce us to the agents that have worked with famous stars such as Leonardo DiCaprio.
2 26. The Declaration states that:
3 "I did not research Barbizon on the Internet and I did not look at their website
4 at that time." (p. 1: 11-12.)
5 This statement is literally true, but actually false. I told Ms Rnjak that I did not research
6 Barbizon prior to the audition but that I did research them when I got home from the audition
7 and I did view the website at that time. Jane, my seven-year-old daughter, was very excited
8 about the prospect of fame and glory, and now very much wanted to work in the movies, or
9 television, or as a model. My husband was also very impressed by the presentation and was
10 persuaded that Barbizon was a legitimate program for getting our daughter into the
11 entertainment industry. However, I was more cautious and so I looked up Barbizon's
12 website when I got home. The website had lots of information on Barbizon, including their
13 mission, how long they had been in the business, and the many people whose careers they
14 had helped. I told all of this to Ms Rnjak.
15 27. The Declaration states that:
16 "We were not interested in job opportunities when we signed [our daughter]
17 up. We saw this as a training experience, and not an opportunity to get into the
18 entertainment industry" (p. 1:13-14.)
19 This is absolutely not true and directly contradictory to what I told Ms Rnjak. I was very
20 clear with Ms Rnjak that as parents my husband and I did not need Jane to work, and that
21 our interest in enrolling her was in supporting her dreams but, that after being exposed to
22 Barbizon's promotional materials, Jane's dream, and therefore by extension our interest, was
23 for her to be in the movies or on television or a model. After seeing all of Barbizon's
24 promotional materials, my husband and I thought that if we put Jane into this program it
25 would help us to help her to get jobs in television, the movies, or a modeling.
26 28. The Declaration states:
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et at. Case Number CGC-16-551337
Page 6
 "The [BarbizonJ program was educational in nature." (p. 1:15-16.)
2 This is not an accurate quote of what 1 said and it creates a misleading impression. Ms
3 Rnjak asked me if 1 would agree that the Barbizon program was educational. 1 said that 1
4 guessed you could say that since there were teachers and classes.
5 29. The Declaration states that:
6 "No one at Barbizon made us any job offers or offers to sign a contract with an
7 agent." (p. 1:14-15.) ... "I am positive that no one at Showcase offered us any
8 work or to sign a contract with an agent. There were no offers like that at all." (p.
9 2:9-10.)
10 These statements are not true. As 1 explained to Ms Rnjak, right before the last classes at
11 Barbizon, a woman came up from Barbizon in Los Angeles and talked to all the parents,
12 including us, about this "wonderful program" called Showcase. This Barbizon person told
13 us that if you want your kids to "go to the next step" in getting into the entertainment
14 industry, Showcase is that "next step". Barbizon classes are just preparation for going to
15 Showcase, she said. Once you had the Barbizon training, the next level is to audition for
16 "directors, agents, and managers" at Showcase. She then invited us to go to another audition
17 for the Showcase.
18 30. 1 told Ms Rnjak that the woman from Barbizon who conducted the Showcase
19 audition told us that she was "99% certain" that our daughter would get signed by agent at
20 Showcase, and that "most kids get signed by agents at Showcase." The woman from
21 Barbizon also asked Jane if she wanted to work in the entertainment. When Jane said "yes,"
22 the woman from Barbizon told Jane that if she goes to Showcase, she was "pretty sure" that
23 Jane would start working right after going to Showcase. The Barbizon woman told my
24 daughter that she was "so good," she would get work "right after showcase." The person
25 who conducted the Showcase audition gave us her card at the audition, and her card listed
26 Barbizon on it. 1 specifically remember the language in quotation marks in this paragraph.
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et al. Case Number CGC-16-551337
Page 7
 31. The Declaration states:
2 "Showcase instructors told us many time that not every perfonner at showcase
3 would get a chance to speak with an agent."
4 This is not true and I never said it to Ms Rnjak. I don't remember any Showcase instructor
5 ever saying this, much less saying it many times.
6 32. The Declaration states:
7 "1 understood that the payment covered the months of continuing training,
8 accommodations in Los Angeles and all the events they planned for the
9 participants." (p. 1:20-22.)
10 This is not true. What 1 told Ms Rnjak was that 1 could not understand how the services
11 provided by Showcase could possibly have added up to justify the $10,000.00 my family
12 paid for them. The training my daughter received was just eight to nine classes of two or
13 three hours at the most, and these were not one-on-one trainings, but classes with 30 to 50
14 kids in them. As for the hotel accommodations, my husband had to book a separate room to
15 attend the Showcase, and ended up paying only $100 or so per night. Plus I was only able to
16 attend two events at the actual Showcase itself. I told Ms Rnjak that all ofthis did not come
17 close to the $10,000.00 my family paid.
18 33. The Declaration states:
19 "There was some talk about the fact that agents and managers would attend the
20 final show in Los Angeles." (p. 1:23-24.) ... "We knew we might never get a
21 chance for [Jane] to have a one-on-one conversation with an agent." (p. 2:12-13.)
22 These statements are not true, 1 did not say them to Ms Rnjak, and 1 do not remember her
23 asking me about them, either. I do not know what "final show" refers to, as the Showcase
24 involved multiple auditions. In any event, the woman who conducted the Showcase audition
25 told me specifically that at the Showcase event 1 would need to make myself available in the
26 evenings, because agents or managers might want to talk to me in the evenings. I understood
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et al. Case Number CGC-16-551337
Page8
 her to be describing networking, which is something I am familiar with from having
2 attended professional conferences related to my work. In addition, the Barbizon woman
3 who conducted the Showcase audition told the parents in attendance that our kids would be
4 auditioning in front of some of the world's best agents, managers, and casting directors. She
5 made it seem like they would be so thick on the ground that we might even run into them in
6 the hallways while walking to our rooms. She even suggested that it was important to have
7 our child's headshots handy at all times in case such a run-in was to happen. (I later learned
8 there was an extra fee to get copies of your child's official Showcase headshots.) If
9 anything, the Barbizon woman who ran the Showcase audition suggested that agents and
10 managers would be unavoidable during the process.
11 34. The Declaration states:
12 "we were not looking for work for our daughter. We wanted to first find out more
13 about the entertainment industry, what it would be like for her to pursue that line
14 of work, whether it would interfere with her school work, whether she was old
15 enough for it, etc. We were not looking to sign a contract right away, but we were
16 there for the experience." (p. 1:24-28.)
17 This is not accurate. I told Ms Rnjak that my husband and I did not need our daughter to
18 work. As parents, if she did not get work right away, we did not want her to be
19 disappointed, and we made it clear to her if that happened we would not be disappointed.
20 However, as I explained on the telephone to Ms Rnjak, the whole point of the Showcase
21 program as we understood it was getting our daughter into the movies, television, and
22 modeling industry. We wanted our daughter to get into that industry because that is what
23 she wanted. The suggestion in the Declaration that we did not care and had an extra
24 $10,000.00 just lying around is completely wrong.
25 35. The Declaration states:
26 "My understanding has always been that it is not possible to sign a contract with
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et at. Case Number CGC-16-551337
Page 9
 an agent at the final show anyway. As far as I know, no kid ever got signed at the
2 final show. It just doesn't work like that. Those steps happen later and are between
3 agents and families." (p. 1:28-2:3.)
4 This is not true. After the Showcase, when she got no work, my daughter was depressed for
5 a period of months. During that time, I sought to buoy my daughter's sprits by researching
6 online how to help her get into the entertainment industry. Through those efforts, I
7 eventually did learn how the entertainment industry actually works. One of the things I
8 learned through that research is that Barbizon and Showcase taught us precisely the wrong
9 ways to try to get into the entertainment industry. While I know now that it was not possible
10 simply to sign a contract with an agent at the Showcase event, I did not know that at the
11 time. On the contrary, as explained above, and as I told Ms Rnjak, I was repeatedly told by
12 the Barbizon woman who conducted the Showcase audition that it was not only possible, but
13 probable that my daughter would sign a contract for work at the Showcase event. In addition,
14 the Barbizon scout and the presentation she gave repeatedly told us that Barbizon is the
15 easiest, fastest, and perhaps only way to get your child into the entertainment industry. When
16 Barbizon presented Showcase to us, it was as just the next step in the path to getting into the
17 entertainment industry after completing the Barbizon program.
18 36. The Declaration states:
19 "I feel that the training they provided at Showcase was good, but I expected more
20 for the money we spent. My daughter tends to learn fast and she excels at things
21 she is interested in, so I was hoping for a more tailored and/or more advanced
22 training." (p. 2:4-8.)
23 I did not tell Ms Rnjak that I thought the Showcase training was good. For my daughter, the
24 training was way too easy. Basically, the kids in the Showcase classes were all given a single
25 script and lines for a single commercial to memorize, and they effectively spent the classes
26 memorizing those things. My daughter had her lines more or less memorized that first night,
27

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et al. Case Number CGC-16-551337
Page 10
 so the remaining classes were wasted on her.
2 37. The Declaration states:
3 "I do credit Showcase for helping develop [Jane]'s interest in acting and for
4 encouraging me to look for more information on the entertainment industry on the
5 Internet." (p. 2:6-8.)
6 I did not say this to Ms Rnjak. Rather, I told her that what we learned from Showcase was
7 what not to do to get our child into the entertainment industry. Yes, my daughter's interest
8 in acting was sparked, and she has since succeeded in finding some work in the
9 entertainment industry, but I only learned how to make that happen in an attempt to bring her
10 out of the despair she felt when her dreams were crushed at the Showcase. In addition, I do
11 not understand why the declaration suggests that I credit Showcase specifically since, to the
12 best of my understanding, Barbizon and Showcase are part of the same company or
13 organization.
III
14
III
15 III
III
16 III
17 III
III
18 III
III
19
III
20 III
III
21 III
22 III
III
23 III
III
24
III
25 III
III
26 III
27 III

28 Declaration of Angelica Cosio

Angelica Cosio, et at. v. International Performing Arts Academy, LLC, et al. Case Number CGC-16-551337
Page 11
 .ue~clat'att()n states:

2 final show. I research on the Internet about the entertainment

3 industry and pursued opportwrIities for [our daughter]. has done commercials
4 a cOlllple of lrDOVles."

5 I carefully eXf:,laIlrred to Ms Rnjak, our daughter has done one commercial, and one
6 mO'VIe. Neith(~r 0lPpoiftwrIity came through or Showcase. I told her this as a
7 exp,latl1lmg that Sh()wc:ase and our and
8 she basically had to go back and relearn everything the right
9 enb~lIl1T~ent industry

10 BRirb~mn taUWlt my daUlghtJer nothing that was way

11 entertainment industry.
12 I declare pettal1y n1r """'-1'11111"\1 that Rmegoing is true and correct.

14 EXlecuted on r'lUl!:!U::SL at Stockton, California.

15
16

17 Heu
18

19

24
25

Declaration Cosio
Ang''!lica COSio. et al. v. lnternaltiom'li PIE!iformillg Arts AIr.:aciJ~my. LLC, et al. Case Number CGC-16-5S1337
12
 INDEX OF EXHIBITS TO
2 DECLARATION OF TIA HEV
3 EXHIBIT DESCRIPTION
4 A Bojana Rnjak, Putterman Landry + Yu LLP, letter to
Tia Hell, July 31,2017, with encl.
5

10

11

12

13

14

15

16

17

18

19

20
21

22
23

24

25

26
27

28
EXHIBIT A
 Putterman I Landry I Yu llP
353 SACRAMENTO STREET ISUITE
BOJANA RNJAK
SAN FRANCISCO, CA 941:1.1
Tel. 415.839.8n91 Fax.
DO. 4J.~,.O.LO.o,.Lo.'l

July 31,

on

statement and mail it to me in the urc,vi<ied emlei<)pe at

convenience.

you your of luck you and

 1 I,

2 1. cllllOren, one _ atterHle<1 Hl'Irh.17on was

3 (8) years old. I work as a scientist and and I live in ;,a4crame:nt(), California.

4 2. _ was apf1roa,che:d a Barbizon scout at a shemping center. The scout us

5 a the program a I wason

6 I h",11"";p it paJiicipants or on a~'i:;nl'" manlage1rs. It
7 was pretty stnngJ1U()rnrard

8 3. _ wanted to go to audition and that was with me. The audition was

9 wa1tcht!d a general video about Hru:bl:l:on. _ was mtt~re~.ted

10 waTlted to act we tnougJlt it

11 about 4'""-"vuu pro:grarn. I not res<~an~h H,artllzem on

I not welbsi1te at
4. were not interested in job opportunities we slglrle<1_ up. saw
as a trrulmrlg e:Kpt~ne:ncl~, not an oPl)OrtuIllity to into the entert~lilllneIlt industry. one at

us or to a contract an
nature.
17 5. out Hnllv'Ulonrt Shc)wcase through_ cla~;ses at HarllJizon.

18 There was a hype about it. I don't renlemllJer -'---'-J what told us about it. I was

19 curious it and _ was too. wante:<1 to continue with

6. I hel1eve we for_to Shc.wc:ase. I un<1erstoo<1

all events
7. was some talk about that manag:ers would final

show attention to it lJec:am;;e we were not loo,klnlg

waTlted to out more about the enltet1:a1flm<~nt m<1ustry it

to pursue whiethl~r it
was old en()U}.!:h etc. were not loo,kmlg to a contract we

were it is not possible to a

Case No. CGC-16-551337

DEC LARA TION OF T1A HELL

 contract an at asI no ever at

2 show. work like are between

3 families.

4 8. I that the provided at was but! more

5 money we to is

-
6 so I was a more more

7 helping me to more

8 on the entertainment industry on the Internet.

9 lam that no one at offered us or to sign a contract

10 with an at all. It was contract as

II

us at would a to an

13 knew we might never a for_to a oneon-one with an

14 10. the final show, I did on entertainment industry

and for_ been in a

16 came we met at

17

18 I under the that the

is true and and that Declaration was on 2017.

2 Case No. CGC-16-55J337

DECLARATION OF TIA HELL