Académique Documents
Professionnel Documents
Culture Documents
4 ep@eplaw.us 07/12/2017
Clerk of the Court
5 [Additional Counsel Listed on Next Page] BY:JUDITH NUNEZ
Deputy Clerk
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Exhibits to Preston Declaration No. CGC-16-55133
Randall B. Aiman-Smith (124599)
Reed W.L. Marcy (191531)
Hallie Von Rock (233152)
2 Carey A. James (269270)
Brent A. Robinson (289373)
3 AlMAN-SMITH & MARCY, P.e.
7677 Oakport Street, Suite 1150
4 Oakland, California 94621
(510) 817-2711 (telephone)
5 (510) 562-6830 (facsimile)
ras@asmlawyers.com
6 rwlm@asmlayers.com
hvr@asmlawyers.com
7 caj@asmlawyers.com
bar@asmlawyers.com
8
Zack Broslavsky (241736)
9 Jonathan A. Weinman (256553)
BROSLAVSKY & WEINMAN, LLP
10 1500 Rosecrans Ave., Suite 500
Los Angeles, CA 90266
11 (310) 575-2550 (telephone)
(310) 464-3550 (facsimile)
12 zbroslavsky@bwcounsel.com
jweinman@bwcounsel.com
13
David e. Parisi (162248)
14 Suzanne Havens Beckman (188814)
PARISI & HAVENS LLP
15 212 Marine Street, Suite 100
Santa Monica, California 90405
16 (818) 990-1299 (telephone)
(818) 501-7852 (facsimile)
17 dcparisi@parisihavens.com
shavens@parisihavens.com
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Attorneys for PlaintiffAngelica Cosio, on
19 her own behalf, and behalf of all others
similarly situated
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Exhibits to Preston Declaration No. CGC-16-551337
INDEX OF EXHIBITS TO
2 DECLARATION OF ETHAN PRESTON
3 DESCRIPTION
4 A Assem. Com. on Arts, Entertainment, Sports, Tourism,
and Internet Media., Analysis of Assem. Bill No. 1319 as
5 amended April 15,2009 (2009-2010 Reg. Sess.) April 28,
6
2009
B Excerpts of Federal Trade Commission Response to
7 Cosio's October 25,2016 FOIA Request
C Cosio's RF As with Appendix
8
D Cosio's Motion to Compel MPA
9 E Defendants' RF A Responses
F Defendants' Form Interrogatory Responses
10 Defendants' Special Interrogatory Responses
G
11 H Defendants' Brochure as Produced (LIONOO450-
LION00461)
12 I Defendants' Contracts as Produced (LION00349-
13 LION00352, native Winter 2014 contract,
LION00939-LION00940, LION00996-LIONOI009,
14 "IPAS CA FEB 13.pdf', "IPAS CA June14 (2).pdf')
J, Part 1 Excerpts of Defendants' Talent Directories as
15 Produced (LION00511-LIONOO711)
16 J, Part 2 Excerpts of Defendants' Talent Directories as
Produced (LION00713-LION00796)
17 J, Part 3 Excerpts of Defendants' Talent Directories as
Produced (LION00802-LIONOO867)
18
J, Part 4 Excerpts of Defendants' Talent Directories as
19 Produced (LION00868-LION00921)
K Defendants' Industry Professional Agreements as
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Produced (LION00463-LION00478; LION00993-
21 LION00995; LIONOIOIO)
L Preston Law Offices Firm Resume
22 M Defendants' Demand for Production Responses
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EXHIBIT K
IPAS Winter 2013
Industry Professional Registration
CompanyName: ______________________________________________________________________
SHOWCASE REQUEST
Please mark an "X" in the space below next to eaeh showease you would like to scout/judge, as well as IP special functions such as IP
dinner. We will do our best to accommodate as each showcase is limited. Required participation is already marked.
IMPORTANT: Partieipation requirements are a minimum of one complete set of competitions, model & talent overview, talent showcase
and both callback & open call. Talent scouts are required to scout talent competitions and model scouts are required to scout model
eompetitions. **ONLY one pre-approved $250 reimhursement will he issued per company, unless otherwise agreed.
HOTEL ACCOMODATIONS
Please select the option that applies to your level of partieipation
___ YES, I would like a room reservation Friday, Febmary 8 Sunday, Febmary 10 (only if seouting both talent and model competitions)
OR
___ YES, r would like a room reservation the evening of Saturday, Febmary 9
OR
NO, I declIne hotel accommodations.
FAX: 415.704.3384
www.TalentShowcase.tv
INDUSTRY PROFESSIONAL AGREEMENT
The International Performing Arts Showcase - February 7 - 10, 2013
This Agreement is entered into between the International Performing Arts Showcase ("I PAS") and
("Industry Professional" or "IP") representing ("IP
Entity"), as an [insert position such as agent, casting director, A & R, etc]
Whereas, IPAS wishes IP to act, and IP agrees to act, as an industry professional at IPAS Event being held in
February 2013 and outlined in attached form (referred to herein as an "Event").
1. IP represents and warrants to IPAS that IP is authorized to sign this Agreement and represent the IP Entity
in the position set forth above, that IP has the power and authority to sign, cast, hire, scout or screen
new talent for the IP Entity and IP has the permission of IP Entity to attend the Event on behalf of IP
Entity.
2. IP will attend one complete set of competitions to be held at Event, in addition to all scheduled mandatory
attendance and full duration of the callback and open call sessions. IP agrees to be on time to all events
and follow rules specified at meetings. IP will not bring guests unless approved by IPAS prior to the Event.
3. As compensation for IP participating in all required activities, IPAS agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 participation reimbursement for attending all required functions; competition, talent &
model overview, final showcase and callbacks & opencall session. The reimbursement will cover
any and all miscellaneous travel costs, which will be issued in the form of an IPAS check. The
check for IP will be given on the last day of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selling any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of IPAS,
including without limitation fee-based conventions, contests and workshops without prior consent of
IPAS.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by IPAS and its agents and employees. IP's participation in the event constitutes IP's
express consent thereto. In consideration therefore, IP further acknowledges and agrees that IPAS may use
IP's name, portraits, photographs, statements and any and all other likeness obtained in connection with the
Events in any form, format and media, for any purpose in the promotion of IPAS and its products and
services. IP shall have no claim or action against IPAS, its agents or representatives in connection with
such use. IP agrees that IP will not take any action to limit any licenses or rights IPAS has with any
attendee of the Events to publish pictures or likeness, or details of their success through their affiliation with
IPAS.
6. IPAS reserves the right to cancel the Events at anytime at its sole discretion without liability to IP.
FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IPAS Winter 2014
Industry Professional Registration
CompanyName: ______________________________________________________________________
SHOWCASE REOUEST
Please mark an "X" in the space below next to eaeh showease you would like to scout/judge, as well as IP special functions such as IP
dinner. We will do our best to accommodate as each showcase is limited. Required partieipation is already marked.
IMPORTANT: Partieipation requirements are a minimum of one complete set of competitions, model & talent overview, talent showcase
and both callback & open call. Talent scouts are required to scout talent competitions and model scouts are required to scout model
competitions. **ONLY one pre-approved $250 reimhursement will he issued per company, unless otherwise agreed.
HOTEL ACCOMODATIONS
Please select the option that applies to your level of participation
YES, I would like a room reservation Friday, January 10 Sunday, January 12 (only if seouting both talent and model eompetitions)
OR
YES, I would like a room reservation the evening of Saturday, January II
OR
NO, I decline hotel accommodations.
FAX: 415.704.3384
www.TalentShowcase.tv
INDUSTRY PROFESSIONAL AGREEMENT
The International Performing Arts Showcase - January 9 -12,2014
This Agreement is entered into between the International Performing Arts Showcase ("I PAS") and
("Industry Professional" or "IP") representing ("IP
Entity"), as an [insert position such as agent, casting director, A & R, etc]
Whereas, IPAS wishes IP to act, and IP agrees to act, as an industry professional at IPAS Event being held in
January 2014 and outlined in attached form (referred to herein as an "Event").
1. IP represents and warrants to IPAS that IP is authorized to sign this Agreement and represent the IP Entity
in the position set forth above, that IP has the power and authority to sign, cast, hire, scout or screen
new talent for the IP Entity and IP has the permission of IP Entity to attend the Event on behalf of IP
Entity.
2. IP will attend one complete set of competitions to be held at Event, in addition to all scheduled mandatory
attendance and full duration of the callback and open call sessions. IP agrees to be on time to all events
and follow rules specified at meetings. IP will not bring guests unless approved by IPAS prior to the Event.
3. As compensation for IP participating in all required activities, IPAS agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 participation reimbursement for attending all required functions; competition, talent &
model overview, final showcase and callbacks & opencall session. The reimbursement will cover
any and all miscellaneous travel costs, which will be issued in the form of an IPAS check. The
check for IP will be given on the last day of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selling any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of IPAS,
including without limitation fee-based conventions, contests and workshops without prior consent of
IPAS.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by IPAS and its agents and employees. IP's participation in the event constitutes IP's
express consent thereto. In consideration therefore, IP further acknowledges and agrees that IPAS may use
IP's name, portraits, photographs, statements and any and all other likeness obtained in connection with the
Events in any form, format and media, for any purpose in the promotion of IPAS and its products and
services. IP shall have no claim or action against IPAS, its agents or representatives in connection with
such use. IP agrees that IP will not take any action to limit any licenses or rights IPAS has with any
attendee of the Events to publish pictures or likeness, or details of their success through their affiliation with
IPAS.
6. IPAS reserves the right to cancel the Events at anytime at its sole discretion without liability to IP.
FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IPAS Winter 2015
Industry Professional Registration
CompanyName: ______________________________________________________________________
SHOWCASE REQUEST
Please mark an "X" in the space below next to eaeh showease you would like to scout/judge, as well as IP special functions such as IP
dinner. We will do our best to accommodate as each showcase is limited. Required partieipation is already marked.
IMPORTANT: Partieipation requirements are a minimum of one complete set of competitions, model & talent overview, talent showcase
and both callback & open call. Talent scouts are required to scout talent competitions and model scouts are required to scout model
competitions. **ONLY one pre-approved $250 reimhursement will he issued per company, unless otherwise agreed.
HOTEL ACCOMODATIONS
Please select the option that applies to your level of participation
__ YES, I would like a room reservation Friday, January 16th Sunday, January 18th (only if scouting both actor and model comps)
OR
YES, I would likc a room rescrvation the evening of Saturday, January 17th
OR
NO, I decline hotel accommodations.
FAX: 415.704.3384
www.TalentShowcase.tv
INDUSTRY PROFESSIONAL AGREEMENT
The International Performing Arts Showcase - January 15 -18,2015
This Agreement is entered into between the International Performing Arts Showcase ("I PAS") and
("Industry Professional" or "IP") representing ("IP
Entity"), as an [insert position such as agent, casting director, A & R, etc]
Whereas, IPAS wishes IP to act, and IP agrees to act, as an industry professional at IPAS Event being held in
January 2015 and outlined in attached form (referred to herein as an "Event").
1. IP represents and warrants to IPAS that IP is authorized to sign this Agreement and represent the IP Entity
in the position set forth above, that IP has the power and authority to sign, cast, hire, scout or screen
new talent for the IP Entity and IP has the permission of IP Entity to attend the Event on behalf of IP
Entity.
2. IP will attend one complete set of competitions to be held at Event, in addition to all scheduled mandatory
attendance and full duration of the callback and open call sessions. IP agrees to be on time to all events
and follow rules specified at meetings. IP will not bring guests unless approved by IPAS prior to the Event.
3. As compensation for IP participating in all required activities, IPAS agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 participation reimbursement for attending all required functions; competition, talent &
model overview, final showcase and callbacks & opencall session. The reimbursement will cover
any and all miscellaneous travel costs, which will be issued in the form of an IPAS check. The
check for IP will be given on the last day of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selling any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of IPAS,
including without limitation fee-based conventions, contests and workshops without prior consent of
IPAS.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by IPAS and its agents and employees. IP's participation in the event constitutes IP's
express consent thereto. In consideration therefore, IP further acknowledges and agrees that IPAS may use
IP's name, portraits, photographs, statements and any and all other likeness obtained in connection with the
Events in any form, format and media, for any purpose in the promotion of IPAS and its products and
services. IP shall have no claim or action against IPAS, its agents or representatives in connection with
such use. IP agrees that IP will not take any action to limit any licenses or rights IPAS has with any
attendee of the Events to publish pictures or likeness, or details of their success through their affiliation with
IPAS.
6. IPAS reserves the right to cancel the Events at anytime at its sole discretion without liability to IP.
FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IP AS Summer 2013
Industry Professional Registration
CompanyName: ______________________________________________________________________
What type of modelsItalent does your company represent/mange? (Include age) ___________
SHOWCASE REOUEST
Please mark an "X" in the space below next to eaeh showease you would like to scout/judge, as well as IP special functions such as IP
dinner. We will do our best to accommodate as each showcase is limited. Required partieipation is already marked.
IMPORTANT: Partieipation requirements are a minimum of one complete set of competitions, model & talent overview, talent showcase
and both callback & open call. Talent scouts are required to scout talent competitions and model scouts are required to scout model
competitions. **ONLY one pre-approved $250 reimhursement will he issued per company, unless otherwise agreed.
HOTEL ACCOMODATIONS
Please select the option that applies to your level of participation
YES, I would like a room reservation Friday, June 28 Sunday, June 30 (only ifseouting both talent and model competitions)
OR
YES, I would like a room reservation the evening of Saturday, June 29
OR
NO, I decline hotel accommodations.
FAX: 415.704.3384
www.TalentShowcase.tv
INDUSTRY PROFESSIONAL AGREEMENT
The International Performing Arts Showcase - June 27 - 30,2013
This Agreement is entered into between the International Performing Arts Showcase ("I PAS") and
("Industry Professional" or "IP") representing ("IP
Entity"), as an [insert position such as agent, casting director, A & R, etc]
Whereas, IPAS wishes IP to act, and IP agrees to act, as an industry professional at IPAS Event being held in
June 2013 and outlined in attached form (referred to herein as an "Event").
1. IP represents and warrants to IPAS that IP is authorized to sign this Agreement and represent the IP Entity
in the position set forth above, that IP has the power and authority to sign, cast, hire, scout or screen
new talent for the IP Entity and IP has the permission of IP Entity to attend the Event on behalf of IP
Entity.
2. IP will attend one complete set of competitions to be held at Event, in addition to all scheduled mandatory
attendance and full duration of the callback and open call sessions. IP agrees to be on time to all events
and follow rules specified at meetings. IP will not bring guests unless approved by IPAS prior to the Event.
3. As compensation for IP participating in all required activities, IPAS agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 participation reimbursement for attending all required functions; competition, talent &
model overview, final showcase and callbacks & opencall session. The reimbursement will cover
any and all miscellaneous travel costs, which will be issued in the form of an IPAS check. The
check for IP will be given on the last day of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selling any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of IPAS,
including without limitation fee-based conventions, contests and workshops without prior consent of
IPAS.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by IPAS and its agents and employees. IP's participation in the event constitutes IP's
express consent thereto. In consideration therefore, IP further acknowledges and agrees that IPAS may use
IP's name, portraits, photographs, statements and any and all other likeness obtained in connection with the
Events in any form, format and media, for any purpose in the promotion of IPAS and its products and
services. IP shall have no claim or action against IPAS, its agents or representatives in connection with
such use. IP agrees that IP will not take any action to limit any licenses or rights IPAS has with any
attendee of the Events to publish pictures or likeness, or details of their success through their affiliation with
IPAS.
6. IPAS reserves the right to cancel the Events at anytime at its sole discretion without liability to IP.
FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IPAS Summer 2014
Industry Professional Registration
CompanyName: ______________________________________________________________________
What type of modelsItalent does your company represent/mange? (Include age) ___________
SHOWCASE REOUEST
Please mark an "X" in the space below next to eaeh showease you would like to scout/judge, as well as IP special functions such as IP
dinner. We will do our best to accommodate as each showcase is limited. Required partieipation is already marked.
IMPORTANT: Partieipation requirements are a minimum of one complete set of competitions, model & talent overview, talent showcase
and both callback & open call. Talent scouts are required to scout talent competitions and model scouts are required to scout model
competitions. **ONLY one pre-approved $250 reimhursement will he issued per company, unless otherwise agreed.
HOTEL ACCOMODATIONS
Please select the option that applies to your level of participation
YES, I would like a room reservation Friday, June 27th Sunday, June 29th (only if seouting both actor and model competitions)
OR
YES, I would like a roOlll reservation the evening of Saturday, June 28th
OR
NO, I decline hotel accolllmodations.
FAX: 415.704.3384
www.TalentShowcase.tv
INDUSTRY PROFESSIONAL AGREEMENT
The International Performing Arts Showcase - June 26 - 29, 2014
This Agreement is entered into between the International Performing Arts Showcase ("I PAS") and
("Industry Professional" or "IP") representing ("IP
Entity"), as an [insert position such as agent, casting director, A & R, etc]
Whereas, IPAS wishes IP to act, and IP agrees to act, as an industry professional at IPAS Event being held in
June 2014 and outlined in attached form (referred to herein as an "Event").
1. IP represents and warrants to IPAS that IP is authorized to sign this Agreement and represent the IP Entity
in the position set forth above, that IP has the power and authority to sign, cast, hire, scout or screen
new talent for the IP Entity and IP has the permission of IP Entity to attend the Event on behalf of IP
Entity.
2. IP will attend one complete set of competitions to be held at Event, in addition to all scheduled mandatory
attendance and full duration of the callback and open call sessions. IP agrees to be on time to all events
and follow rules specified at meetings. IP will not bring guests unless approved by IPAS prior to the Event.
3. As compensation for IP participating in all required activities, IPAS agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 participation reimbursement for attending all required functions; competition, talent &
model overview, final showcase and callbacks & opencall session. The reimbursement will cover
any and all miscellaneous travel costs, which will be issued in the form of an IPAS check. The
check for IP will be given on the last day of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selling any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of IPAS,
including without limitation fee-based conventions, contests and workshops without prior consent of
IPAS.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by IPAS and its agents and employees. IP's participation in the event constitutes IP's
express consent thereto. In consideration therefore, IP further acknowledges and agrees that IPAS may use
IP's name, portraits, photographs, statements and any and all other likeness obtained in connection with the
Events in any form, format and media, for any purpose in the promotion of IPAS and its products and
services. IP shall have no claim or action against IPAS, its agents or representatives in connection with
such use. IP agrees that IP will not take any action to limit any licenses or rights IPAS has with any
attendee of the Events to publish pictures or likeness, or details of their success through their affiliation with
IPAS.
6. IPAS reserves the right to cancel the Events at anytime at its sole discretion without liability to IP.
FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IPAS Fall 2015
Industry Professional Registration
CompanyName: ______________________________________________________________________
SHOWCASE REOUEST
Please mark an "X" in the space below next to eaeh showease you would like to scout/judge, as well as IP special functions such as IP
dinner. We will do our best to accommodate as each showcase is limited. Required partieipation is already marked.
IMPORTANT: Partieipation requirements are a minimum of one complete set of competitions, model & talent overview, talent showcase
and both callback & open call. Talent scouts are required to scout talent competitions and model scouts are required to scout model
competitions. **ONLY one pre-approved $250 reimhursement will he issued per company, unless otherwise agreed.
HOTEL ACCOMODATIONS
Please seleet the option that applies to your level of participation
YES, I would like a room reserved Friday, November 13th Sunday, November 15th (only if scouting both actor and model comps)
OR
YES, I would like a room reserved the evening of Saturday, November 14th
OR
NO, I decline hotel accommodations.
FAX: 415.704.3384
www.TalentShowcase.tv
INDUSTRY PROFESSIONAL AGREEMENT
The International Performing Arts Showcase - November 12 -15,2015
This Agreement is entered into between the International Performing Arts Showcase ("I PAS") and
("Industry Professional" or "IP") representing ("IP
Entity"), as an [insert position such as agent, casting director, A & R, etc]
Whereas, IPAS wishes IP to act, and IP agrees to act, as an industry professional at IPAS Event being held in
November 2015 and outlined in attached form (referred to herein as an "Event").
1. IP represents and warrants to IPAS that IP is authorized to sign this Agreement and represent the IP Entity
in the position set forth above, that IP has the power and authority to sign, cast, hire, scout or screen
new talent for the IP Entity and IP has the permission of IP Entity to attend the Event on behalf of IP
Entity.
2. IP will attend one complete set of competitions to be held at Event, in addition to all scheduled mandatory
attendance and full duration of the callback and open call sessions. IP agrees to be on time to all events
and follow rules specified at meetings. IP will not bring guests unless approved by IPAS prior to the Event.
3. As compensation for IP participating in all required activities, IPAS agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 participation reimbursement for attending all required functions; competition, talent &
model overview, final showcase and callbacks & opencall session. The reimbursement will cover
any and all miscellaneous travel costs, which will be issued in the form of an IPAS check. The
check for IP will be given on the last day of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selling any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of IPAS,
including without limitation fee-based conventions, contests and workshops without prior consent of
IPAS.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by IPAS and its agents and employees. IP's participation in the event constitutes IP's
express consent thereto. In consideration therefore, IP further acknowledges and agrees that IPAS may use
IP's name, portraits, photographs, statements and any and all other likeness obtained in connection with the
Events in any form, format and media, for any purpose in the promotion of IPAS and its products and
services. IP shall have no claim or action against IPAS, its agents or representatives in connection with
such use. IP agrees that IP will not take any action to limit any licenses or rights IPAS has with any
attendee of the Events to publish pictures or likeness, or details of their success through their affiliation with
IPAS.
6. IPAS reserves the right to cancel the Events at any time at its sole discretion without liability to IP.
FAX: 4 t 5.704.3384
www.TalentShowcase.tv
SHOWCASE Fall 2016
Industry Professional Registration
CompanyName: ______________________________________________________________________
SHOWCASE REOUEST
Please mark an "X" in the space below next to eaeh showease you would like to scout/judge, as well as IP special functions such as IP
dinner. We will do our best to accommodate as each showcase is limited. Required partieipation is already marked.
IMPORTANT: Partieipation requirements are a minimum of one complete set of competitions, model & talent overview, talent showcase
and both callback & open call. Talent scouts are required to scout talent competitions and model scouts are required to scout model
competitions. **ONLY one pre-approved $250 reimhursement will he issued per company, unless otherwise agreed.
HOTEL ACCOMODATIONS
Please seleet the option that applies to your level of participation
YES, I would like a room reserved Friday, November 11th Sunday, November 13th (only if scouting both actor and model comps)
OR
YES, I would like a room reserved the evening of Saturday, November 12th
OR
NO, I decline hotel accommodations.
FAX: 415.704.3384
www.TalentShowcase.tv
INDUSTRY PROFESSIONAL AGREEMENT
Showcase - November 10 - 13, 2016
1. IP represents and warrants to SHOWCASE that IP is authorized to sign this Agreement and represent the
IP Entity in the position set forth above, that IP has the power and authority to sign, cast, hire, scout or
screen new talent for the IP Entity and IP has the permission of IP Entity to attend the Event on
behalf of IP Entity_
2. IP will attend one complete set of competitions to be held at Event, in addition to all scheduled mandatory
attendance and full duration of the callback and open call sessions. IP agrees to be on time to all events
and follow rules specified at meetings. IP will not bring guests unless approved by SHOWCASE prior to the
Event.
3. As compensation for IP participating in all required activities, SHOWCASE agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 participation reimbursement for attending all required functions; competition, talent &
model overview, final showcase and callbacks & opencall session. The reimbursement will cover
any and all miscellaneous travel costs, which will be issued in the form of an SHOWCASE check.
The check for IP will be given on the last day of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selling any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of
SHOWCASE, including without limitation fee-based conventions, contests and workshops without prior
consent of SHOWCASE.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by SHOWCASE and its agents and employees. IP's participation in the event
constitutes IP's express consent thereto. In consideration therefore, IP further acknowledges and agrees
that SHOWCASE may use IP's name, portraits, photographs, statements and any and all other likeness
obtained in connection with the Events in any form, format and media, for any purpose in the promotion of
SHOWCASE and its products and services. IP shall have no claim or action against SHOWCASE, its
agents or representatives in connection with such use. IP agrees that IP will not take any action to limit any
licenses or rights SHOWCASE has with any attendee of the Events to publish pictures or likeness, or
details of their success through their affiliation with SHOWCASE.
6. SHOWCASE reserves the right to cancel the Events at any time at its sole discretion without liability to IP.
FAX: 4 t 5.704.3384
www.TalentShowcase.tv
See Native File
See Native File
INDUSTRY PROFESSIONAL AGREEMENT
The International Performing Arts Showcase - June 23 - 26, 2011
This Agreement is entered into between the International Performing Arts Showcase ("IPAS") and
_ _ _ _ _ _ _ _ _ ("Industry Professional" or "lp representing lI
) (HIP Entity"),
as an [insert position such as agent, casting director, A & R, etc] Whereas, IPAS
wishes IP to act, and IP agrees to act, as an industry professional at IPAS Event being held in June 2011 and outlined
in attached form (referred to herein as an "Event").
1. IP represents and warrants to IPAS that IP is authorized to sign this Agreement and represent the IP Entity in
the position set forth above, that IP has the power and authority to sign, cast, hire, scout or screen new
talent for the IP Entity and IP has the permission of IP Entity to attend the Event on behalf of IP Entity.
2. IP will attend two or more competitions to be held at Event, in addition to all scheduled mandatory attendance
and full duration of the Callback session. IP agrees to be on time to ali events and follow rules specified at
meetings. IP will not bring guests unless approved by IPAS prior to the Event.
3. As compensation for IP participating in all required activities, IPAS agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 honorarium for attending all required functions; minimum of two showcases, talent & model
overview and final showcase and callbacks & opencalJ session. The honorarium will cover any and all
miscellaneous travel costs, which will be issued in the form of an IPAS check. The check for IP will be
given on the last day of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selling any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of JPAS,
including without limitation fee-based conventions, contests and workshops without prior consent of IPAS.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by IPAS and its agents and employees. IP's participation in the event constitutes lP's
express consent thereto. In consideration therefore, lP further acknowledges and agrees that IPAS may use
IP's name, portraits, photographs, statements and any and all other likeness obtained in connection with the
Events in any form, format and media, for any purpose in the promotion of IPAS and its products and services.
IP shall have no claim or action against IPAS, its agents or representatives in connection with such use. IP
agrees that IP will not take any action to limit any licenses or rights IPAS has with any attendee of the Events to
publish pictures or likeness, or details of their success through their affiliation with IPAS.
6. IPAS reserves the right to cancel the Events at anytime at its sole discretion without liability to IP.
DOB _ _~ ____._ __
Print Legal Name
TEL: 888.686.7827 * FAX: 415.704.3384" 369 SUTTER ST, SAN FRANCISCO, CA 94108
www.TalentShowcllsc.tv
LlON000993
IPAS Summer 2012
Industry Professional Registration
What type of models/talent does your company representfmange? (Include age) ___________
SHOWCASE REOUEST
a
Please m<rk a1 "X" in the spa:::e belQIN next to eoch showcase you would liketo sooutljudge, aswell as I P spEd functioossuch as IP
dinner. We will do our bcst to accommodate as each showcase is limited. Required participation is already marked.
IMPORTANT: Participation requirements arc a minimum of one complete set of competitions, model & talent overview, talent showcase
and both callback & open call. ""'ONLY olle pl'e.appl'm'ed pel' diem posilioll will be issued pel' compall)" IIl1less othenvise discussed.
HOTEL ACCOl'.IODATIONS
_ _ YES, I would like a room reservation Friday, June 29 - Sunday, July I (only if judging both full days)
OR
_ _ YES, I would like a room reservation the evening of Saturday, June 30
OR
_ _ NO, I decline hotel accommodations.
FAX: 415.704.3384
www.TalcntShowcRsc.tv
LlON000994
INDUSTRY PROFESSIONAL AGREEMENT
The International Performing Arts Showcase - June 28 - Ju Iy 1, 2012
This Agreement is entered into between the International Performing Arts Showcase ("IPAS") and
=:-"':""'""::-:-_ _ _ _ _ _ ("Industry Professional" or "IP") representing ("IP
Entity"), as an [insert position such as agent, casting director, A & R, etc]
Whereas, IPAS wishes IP to act, and IP agrees to act, as an industry professional at IPAS Event being held in
June-July 2012 and outlined in attached form (referred to herein as an "Event").
1. IP represents and warrants to IPAS that IP is authorized to sign this Agreement and represent the IP Entity
in the position set forth above, that IP has the power and authority to sign, cast, hire, scout or screen
new talent for the IP Entity and IP has the permission of IP Entity to attend the Event on behalf of IP
Entity.
2. IP will attend one complete set of competitions to be held at Event, in addition to all scheduled mandatory
attendance and full duration of the callback and open call sessions. IP agrees to be on time to all events
and follow rules specified at meetings. IP w[!l not bring guests unless approved by IPAS prior to the Event.
3. As compensation for IP participating in all required activities, IPAS agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 per diem for attending all required functions; competition, talent & model overview, final
showcase and callbacks & opencall session. The per diem wiJl cover any and all miscellaneous
travel costs, which will be issued in the form of an IPAS check. The check for IP will be given on the
last day of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selfing any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of IPAS,
including without limitation fee-based conventions, contests and workshops without prior consent of
IPAS.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by IPAS and its agents and employees. IP's participation in the event constitutes IP's
express consent thereto. In consideration therefore, IP further acknowledges and agrees that IPAS may use
IP's name, portraits, photographs, statements and any and all other likeness obtained in connection with the
Events in any form, format and media, for any purpose in the promotion of IPAS and its products and
services. IP shall have no claim or action against IPAS, its agents or representatives in connection with
such use. IP agrees that IP will not take any action to limit any licenses or rights IPAS has with any
attendee of the Events to publish pictures or likeness, or details of their success through their affiliation with
IPAS.
6. IPAS reserves the right to cancel the Events at anytime at its sole discretion without liability to IP.
Date I
IP Signature
008 _ _ _ _ _ _ _ __
Print Legal Name
FAX: 415.704.3384
WWw.TlllcntShowcRSC.tv
UON000995
INDUSTRY PROFESSIONAL AGREEMENT
The International Performing Arts Showcase - January 12 -15, 2012
This Agreement is entered into between the International Performing Arts Showcase ("IPAS") and
_ _ _ _ _ _ _ _ _ ("Industry Professional" or "IP") representing ("IP Entity"),
as an {insert position such as agent, casting director, A & R, etc] Whereas, IPAS
wishes IP to act, and IP agrees to act, as an industry professional at IPAS Event being held in January 2012 and
outlined in attached form (referred to herein as an "Event").
1. IP represents and warrants to IPAS that IP is authorized to sign this Agreement and represent the IP Entity in
the position set forth above, that IP has the power and authority to sign, cast, hire, scout or screen new
talent for the IP Entity and IP has the permission of IP Entity to attend the Event on behalf of IP Entity.
2. IP will attend one complete set of competitions to be held at Event, in addition to all scheduled mandatory
attendance and full duration of the callback and open call sessions. IP agrees to be on time to all events and
follow rules specified at meetings. IP will not bring guests unless approved by IPAS prior to the Event.
3. As compensation for IP participating in all required activities, IPAS agrees to provide IP with
a. Hotel accommodations for participation days at the Millennium Biltmore. Room service and extra
services of the hotel are the sole responsibility of IP.
b. Certain meals specified in the Event Summary.
c. Valet parking at the Millennium Biltmore Hotel Los Angeles.
d. $250.00 per diem for attending all required functions; competition, talent & model overview, final
showcase and callbacks & openca[[ session. The per diem will cover any and all miscellaneous travel
costs, which will be issued in the form of an [PAS check. The check for IP will be given on the last day
of the event post opencall session.
4. IP acknowledges that during the Event, IP is prohibited from selling any services or goods directly to any
participants or providing any participants with information regarding any third party competitors of IPAS,
including without limitation fee-based conventions, contests and workshops without prior consent of [PAS.
5. IP acknowledges that the Event and the activities of IP in connection with the Event will be recorded
and photographed by IPAS and its agents and employees. IP's participation in the event constitutes IP's
express consent thereto. In consideration therefore, IP further acknowledges and agrees that IPAS may use
IP's name, portraits, photographs, statements and any and all other likeness obtained in connection with the
Events in any form, format and media, for any purpose in the promotion of IPAS and its products and services.
IP shall have no claim or action against IPAS, its agents or representatives in connection with such use. IP
agrees that IP will not take any action to limit any licenses or rights IPAS has with any attendee of the Events to
publish pictures or likeness, or details of their success through their affiliation with IPAS.
6. [PAS reserves the right to cancel the Events at anytime at its sole discretion without liability to [P.
DOB 1______
Print Legal Name
TEL: 888.686.7827 ~ FAX: 415. 704.3384 * 369 SUTTER ST, SAN FRANCISCO, CA 94108
www.TalentShowcase.tv
LlON001010
EXHIBIT l
PRESTON LAW OFFICES
4054 Avenue, Suite 3101
(972) (866) 509-1197 ep@eplaw.us
Ethan Preston has represented consumers in class actions since 2006, focusing
on consumer privacy and unfair trade practices that relate to consumer
technology. Mr. Preston has taken substantial leadership roles in several class
actions: he was appointed lead counsel in Lofton v. Bank of Am. Corp., No. 07-
5892 (N.D. Cal. Nov. 5,2008), Wang v. Asset Acceptance, LLC, No. 09-4797 (N.D.
Cal. Nov. 17, 2011), Holmes v. NCO Financial Services, Inc., No.1 0-2543 (S.D. Cal.
june 23,2014), Lofton v. Verizon Wireless (VAW) LLC, No. 13-05665 (N.D. Cal. jan.
28,2016), Wang v. Bank of America, N.A., No. CGC-12-526452 (Sup. Ct. San
Francisco Aug. 8. 2014), Meyer v. PYOD, LLC, No. 37-2014-0000811 O-CU-BT-NC
(Sup. Ct. San Diego jan. 6,2017), and was appointed co-lead counsel in the
multi-district litigation case, In re Portfolio Recovery Associates, LLC Telephone
Consumer Protection Act Litigation, No. 11-2295 (S.D. Cal. june 23, 2016). Prior to
forming his own law firm, Mr. Preston was a partner at KamberEdelson,
(now Edelson PC).
Mr. Preston has also authored several law review articles: Cross-Border
Collaboration by Class Counsel in the u.s. and Ontario, 4 Canadian Class Action
Rev. 164 (2007), The Global Rise of a DUty to Disclose Information Security Breaches,
22 J. Marshall J. Computer & Info. L. 457 (2004) (with Paul Turner), Computer
Security Publications: Information Economics, Shifting Liability and the First
Amendment, 24 Whittier L. Rev. 71 (2002) (with John Lofton), and The USA PATRIOT
Act: New Adventures in American Extraterritoriality, 10 J. Fin. Crime 104 (2002).
EXHIBIT M
CONSTANCE J. YU (SBNNO. 182704)
E-mail: cyu@Plvlaw.com
2 MICHELLE L. LANDRY (SBN. 190080)
E-mail: mlandry@plylaw.com
3 PUTTERMAN LANDRY + YU LLP
353 Sacramento Street, Suite 560
4 San Francisco, CA 94111
Telephone: (415) 839-8779
5 Facsimile: (415) 727-1363
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN FRANCISCO
11
23
24
28
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
Pursuant to section 2031. 010 et seq., ofthe California Code of Civil Procedure ("CCP"),
5 GENERAL OBJECTIONS
6 A. In addition to the Specific Objections set forth below, Responding Party LION
7 MANAGEMENT GROUP, INC. ("LION MANAGEMENT") objects generally to the Requests for
8 Production on several grounds. The objections set forth in this section apply to each request. The
9 assertion of the same, similar, or additional objections in the Company's responses to individual
10 requests, or the failure to assert any additional objection to a request, does not waive any of the
11 General Objections.
12 B. LION MANAGEMENT objects to these Requests insofar and to the extent they
13 purport to impose on it obligations other than those imposed by Sections 2017.010 and 2031.210 et
15 C. LION MANAGEMENT objects to these Requests on the grounds to the extent they
17 MANAGEMENT further objects to these Requests to the extent that they would require subjective
18 judgment on the part of LION MANAGEMENT and its attorneys, and would further require
19 disclosure of a conclusion or opinion of counsel in violation of the attorney work product doctrine.
20
27 ("BARBIZON") objects to this Request to the extent that it seeks information protected from
28 disclosure by the attorney client privilege and/or work product doctrine. LION MANAGEMENT
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
objects to these Requests insofar and to the extent they purport to impose on it obligations other than
2 those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil Procedure. LION
3 MANAGEMENT further objects to this Request as prematurely served, and failing to abide by the
4 Court's procedures for discovery in complex litigation and guidance for class action matters (see
5 Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each phase designed
6 to either lead directly to a motion or provide efficacies for the next phase"), and pages 3, 4 (Class
7 actions: "1. Plaintiffs do only the discovery they need to meet their certification needs. This is
8 usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
9 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
11 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
12 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
13 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
14 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
15 discovery at this pre-class certification stage ofthis action. Evid. Code 2lO, 350, 950-955, 1060,
16 1061; CCP 2017.0lO et seq., 2018.030 (work product), 2019.210 (trade secrets).
18 All DOCUMENTS that COSIO's Form Interrogatories, Set One (served with this demand)
21 LION MANAGEMENT objects to this Request to the extent that it seeks inforn1ation
22 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
23 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
24 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
25 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
26 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
27 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
28 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
2 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
3 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
5 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
6 is overbroad, harassing, and seeks confidential proprietary infonnation, and is therefore improper and
7 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
8 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
9 discovery at this pre-class certification stage of this action. Evid. Code 21O, 350, 950-955, 1060,
10 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
12 All DOCUMENTS that LION MANAGEMENT will use or may use to support any defenses
13 to COSIO's claims.
15 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
16 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
17 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
18 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
19 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
20 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
21 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
22 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
23 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
24 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
25 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
27 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
28 is overbroad, harassing, and seeks confidential proprietary infonnation, and is therefore improper and
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
2 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
3 discovery at this pre-class certification stage of this action. Evid. Code 2lO, 350, 950-955, 1060,
4 1061; CCP 2017.0lO et seq., 2018.030 (work product), 2019.210 (trade secrets).
6 All DOCUMENTS concerning COSIO, and/or which contain, are indexed, filed, or
7 retrievable under COSIO's name or any number, symbol, designation, or code (such as an account
8 number or Social Security number) assigned to COSIO, or which LION MANAGEMENT uses to
9 refer to COSIO.
10 This request includes, by way of example (but without limitation), communications with
11 COSIO, communications about COSIO, documents showing payments by COSIO, and all
12 DOCUMENTS concerning COSIO received from LION MANAGEMENT or any talent scout.
14 LION MANAGEMENT objects to this Request to the extent that it seeks information
15 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
16 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
17 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
18 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
19 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
20 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
21 phase desib:rned to either lead directly to a motion or provide efficacies for the next phase"), and pages
22 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
23 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
24 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
26 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
27 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
28 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
2 discovery at this pre-class certification stage ofthis action. Evid. Code 21 0,350,950-955, 1060,
3 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
5 LION MANAGEMENT objects to this request to the extent that it seeks information
6 protected from disclosure by the attorney client privilege and/or work product doctrine including
7 communications about COSIO. Subject to the foregoing, after a diligent search and good faith
8 inquiry, LION MANAGEMENT will produce any non-privileged documents in its possession,
11 All DOCUMENTS concerning any communication regarding this case between LION
12 MANAGEMENT and another person (aside from COSIO, her attorneys, or the Court).
14 LION MANAGEMENT objects to this Request to the extent that it seeks information
15 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
16 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
17 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
18 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
19 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
20 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
21 phase desib:rned to either lead directly to a motion or provide efficacies for the next phase"), and pages
22 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
23 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
24 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
26 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
27 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
28 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
2 discovery at this pre-class certification stage of this action. Evid. Code 21 0,350,950-955, 1060,
3 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
5 All DOCUMENTS concerning any communication regarding this case between IP AS and
8 LION MANAGEMENT objects to this Request to the extent that it seeks information
9 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
10 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
11 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
12 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
13 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
14 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
15 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
16 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
17 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
18 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
20 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
21 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
22 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
23 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
24 discovery at this pre-class certification stage of this action. Evid. Code 21O, 350, 950-955, 1060,
25 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
27 All organization charts and personnel directories which identify LION MANAGEMENT's
2 LION MANAGEMENT objects to this Request to the extent that it seeks information
3 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
4 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
5 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
6 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
7 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
8 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
9 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
10 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
11 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
12 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
14 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
15 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
16 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
17 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
18 discovery at this pre-class certification stage of this action. Evid. Code 210, 350, 950-955, 1060,
19 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
21 LION MANAGEMENT objects to this Request as overbroad as to time and subject matter,
22 and not reasonably calculated to lead to the discovery of admissible evidence as it pertains to the
23 identification of "all employees". Moreover, it is overbroad and irrelevant in that it implicates every
24 employee for all times, including persons in accounting, janitorial services, IT, etc. LION
25 MANAGEMENT further objects that this request violates the phasing stipulation as to "all
26 employees" as such information is not relevant to class certification. Subject to the foregoing, after a
27 diligent search and good faith inquiry, LION MANAGEMENT will produce any non-privileged
28 documents in its possession, custody or control sufficient to show the owners of LION
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
MANAGEMENT during the relevant time period.
3 All organization charts and personnel directories which identify IP AS's employees, officers,
6 LION MANAGEMENT objects to this Request to the extent that it seeks information
7 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
8 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
9 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
10 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
11 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
12 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
13 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
14 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
15 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
16 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
18 LION MANAGEMENT objects to this Request to the extent it purports to require that
19 Responding Party violate or waive privacy rights of third parties protected by the United States
20 Constitution and/or the California Constitution and applicable law. U.S. Const. 4th Amendment; Cal.
21 Const. Art. 1, 1; see also Infonnation Practices Act of 1977, Civil Code, 1978 et seq. Responding
22 Party also objects to this Request to the extent that a response to this Request would expose
23 Responding Party to liability by third parties relating to any wrongful disclosure of any third party's
25 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
26 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
27 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
28 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
discovery at this pre-class certification stage of this action. Evid. Code 210, 350, 950-955, 1060,
2 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
4 LION MANAGEMENT objects to this Request as overbroad as to time and subject matter,
5 and not reasonably calculated to lead to the discovery of admissible evidence as it pertains to the
6 identification of all "employees". Moreover, it is overbroad and irrelevant in that it implicates every
7 employee for all times, including persons in accounting, janitorial services, IT, etc. LION
8 MANAGEMENT further objects that this request violates the phasing stipulation as to "all
9 employees" as such information is not relevant to class certification. Subject to the foregoing, after a
10 diligent search and good faith inquiry, LION MANAGEMENT wi1l produce any non-privileged
11 documents in its possession, custody or control sufficient to show the owners oflNTERNATlONAL
14 All DOCUMENTS concerning any allegations that IPAS (or any of its owners, directors,
15 officers, agents, partners, attorneys, servants, employees, assignees, affiliates, and/or anyone acting
16 on behalf IPAS, and/or any affiliate, subsidiary, parent or related corporation, partnership or entity,
17 and/or anyone acting for or on behalf of any such subsidiary, related corporation, parent, partnership,
18 entity, or natural person): (1) violated any provision of chapter 1701 of the Labor Code or
19 Employment Agency, Employment Counseling, and Job Listing Services Act, or: (2) made
22 LION MANAGEMENT objects to this Request to the extent that it seeks information
23 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
24 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
25 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
26 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
27 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
28 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
2 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
3 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
4 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
6 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
7 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
8 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
9 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
10 discovery at this pre-class certification stage of this action. Evid. Codc 2l 0, 350, 950-955, 1060,
11 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
14 there is no date limitation. LION MANAGEMENT further objects to this Request in that it concerns
15 claims that have been withdrawn (Employment Agency), or which are not made (misstatements or
16 misrepresentations as to the service). LION MANAGEMENT further objects to this Request as not
19 All contracts or agreements between LION MANAGEMENT and its customers on whose
20 behalf LION MANAGEMENT and/or IPAS received payment since April 6, 2012.
22 LION MANAGEMENT objects to this Request to the extent that it seeks information
23 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
24 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
25 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
26 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
27 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
28 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
2 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
3 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
4 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
6 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
7 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
8 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
9 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
10 discovery at this pre-class certification stage of this action. Evid. Codc 21 0, 350, 950-955, 1060,
11 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
13 All contracts or agreements between IP AS and its customers on whose behalf LION
16 LION MANAGEMENT objects to this Request to the extent that it seeks information
17 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
18 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
19 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
20 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
21 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
22 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
23 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
24 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
25 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
26 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
28 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
2 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
3 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
4 discovery at this pre-class certification stage ofthis action. Evid. Code 210, 350, 950-955, 1060,
5 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
10 LION MANAGEMENT objccts to this Request to the extent that it seeks information
11 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
12 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
13 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
14 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
15 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
16 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
17 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
18 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
19 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
20 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
22 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
23 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
24 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
25 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
26 discovery at this pre-class certification stage of this action. Evid. Code 2W, 350, 950-955, 1060,
27 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
28
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST FOR PRODUCTION NO. 13:
2 All contracts or agreements between LION MANAGEMENT and IPAS since April 6, 2012.
4 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
5 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
6 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
7 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
8 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
9 to abide by the Court's procedures for discovery in complex litigation and guidance for class aetion
10 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
11 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
12 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
13 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
14 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
16 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
17 is overbroad, harassing, and seeks confidential proprietary infonnation, and is therefore improper and
18 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
19 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
20 discovery at this pre-class certification stage of this action. Evid. Code 21O, 350, 950-955, 1060,
21 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
26 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
27 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
28 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
2 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
3 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
4 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
5 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
6 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
7 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
8 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
10 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
11 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
12 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
13 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
14 discovery at this pre-class certification stage of this action. Evid. Code 210, 350, 950-955, 1060,
15 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
20 LION MANAGEMENT objects to this Request to the extent that it seeks information
21 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
22 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
23 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
24 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
25 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
26 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
27 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
28 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
2 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
4 LION MANAGEMENT objects to this Request to the extent it seeks infonnation that is
5 protected from disclosure deriving from its and third parties' constitutional right to privacy under
6 both the California Constitution (Article 1, Section 1) (see, Britt v. Sup.Ct. (San Diego Un~fied Port
7 Dist.) (1978) 20 Ca1.3d 844, 855-856 and Pioneer Electronics (USA), Inc. v. Sup. Ct. (Olmstead)
8 (2007) 40 Cal.App.4th 360, 370)) and the United States Constitution (Griswold v State of
10 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
11 is overbroad, harassing, and seeks confidential proprietary infonnation, and is therefore improper and
12 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
13 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
14 discovery at this pre-class certification stage of this action. Evid. Code 210, 350, 950-955, 1060,
15 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
17 DOCUMENTS sufficient to show: (a) the name and address of each LION MANAGEMENT
18 and/or IP AS customer with a contract with LION MANAGEMENT and/or IPAS since April 6, 2012;
19 (b) the amount of the fees paid by or for such customer during the term of such contract; (c) records
20 of any out-of-pocket costs which LION MANAGEMENT and/or IP AS contends it incurred on behalf
23 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
24 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
25 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
26 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
27 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
28 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
2 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
3 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
4 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
5 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
7 LION MANAGEMENT objects to this Request to the extent it purports to require that it
8 violate or waive privacy rights of third parties protected by the United States Constitution and/or the
9 California Constitution and applicable law. U.S. Const. 4th Amendment; Cal. Const. Art. 1, 1; see
11 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
12 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
13 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
14 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
15 discovery at this pre-class certification stage ofthis action. Evid. Code 210, 350, 950-955, 1060,
16 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
19 constituting advertisements and/or marketing of IP AS's services; and (b) any policy, guideline,
20 manual, instruction set, procedure, and/or practice which required, prompted, applied to, controlled,
21 or governed any action IPAS and/or LION MANAGEMENT (including any of its owners, directors,
22 officers, agents, partners, attorneys, servants, employees, assignees, affiliates, and/or anyone acting
23 on behalf IPAS, LION MANAGEMENT, and/or any affiliate, subsidiary, parent or related
24 corporation, partnership or entity, and/or anyone acting for or on behalf of any such subsidiary,
25 related corporation, parent, partnership, entity, or natural person, including any talent scout) took to
27
28
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
2 LION MANAGEMENT objects to this Request to the extent that it seeks information
3 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
4 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
5 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
6 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
7 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
8 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
9 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
10 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
11 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
12 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
14 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
15 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
16 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
17 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
18 discovery at this pre-class certification stage of this action. Evid. Code 210, 350, 950-955, 1060,
19 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
21 LION MANAGEMENT objects to this Request on the grounds that it is not limited as to time
22 and thus is overbroad. LION MANAGEMENT further objects to the term "marketing" as vague,
23 ambiguous and not reasonably particularized. LION MANAGEMENT further objects to this Request
24 as compound. LION MANAGEMENT further objects to the Request in that it seeks "all"
25 employment policies and thus is overbroad and not reasonably calculated to lead to the discovery of
26 admissible evidence. LION MANAGEMENT further objects that this Request violates the phasing
27 stipulation as COSIO does not need material to which she was never exposed to file her opening class
28 certification brief.
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
Subject to the foregoing, and construing this Request to be for the time period April 6, 2012 to
2 the date of response, and seeking (1) advertising type material (which Plaintiff has explained it
3 believes includes scripts [and without arguing whether that is properly within the definition of
4 advertising or marketing or whether COSIO needs scripts she was never exposed to], and (2)
5 employment policies which concern the practices at issue, LION MANAGEMENT will produce any
6 non-privileged documents in its possession, custody or control that constitute advertisements of its
7 talent services (including scripts which may have been used to attract CA citizens to showcase for the
11 and representations since April 6, 2012 that IPAS's services expressly or impliedly included the
12 opportunity for IPAS's customers to meet with or audition before any producer, director, casting
13 director, or any associate thereof, or any other person who makes, or is represented to make,
14 decisions for the process of hiring artists for employment as an artist, or any talent agent or talent
17 LION MANAGEMENT objects to this Request to the extent that it seeks information
18 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
19 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
20 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
21 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
22 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
23 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
24 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
25 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
26 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
27 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
2 is overbroad, harassing, and seeks confidential proprietary infonnation, and is therefore improper and
3 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
4 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
5 discovery at this pre-class certification stage ofthis action. Evid. Code 210, 350, 950-955, 1060,
6 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
9 and representations since April 6, 2012 that one or more ofIPAS's customers obtained an audition,
13 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
14 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
15 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
16 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
17 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
18 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
19 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
20 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
21 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
22 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
23 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
25 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
26 is overbroad, harassing, and seeks confidential proprietary infonnation, and is therefore improper and
27 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
28 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
discovery at this pre-class certification stage ofthis action. Evid. Code 210, 350, 950-955, 1060,
2 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
4 DOCUMENTS sufficient to show the name, address, date of birth, social security number,
5 federal tax identification number, and driver's license number and state of issuance thereof, of LION
8 LION MANAGEMENT objects to this Request to the extent that it seeks information
9 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
10 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
11 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
12 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
13 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
14 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
15 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
16 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
17 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
18 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
20 LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
21 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
22 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
23 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
24 discovery at this pre-class certification stage of this action. Evid. Code 210, 350, 950-955, 1060,
25 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
27 LION MANAGEMENT objects to this Request on the grounds that it violates the privacy of
28 the individual owners of LION MANAGEMENT and is not reasonably caleulated to lead to the
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
discovery of admissible evidence. Subject to the foregoing, after a diligent search and good faith
2 inquiry, LION MANAGEMENT will produce any non-privileged documents in its possession,
3 custody or control sufficient to identify the owners of LION MANAGEMENT during the relevant
4 time period.
6 DOCUMENTS sufficient to show the name, address, date of birth, social security number,
7 federal tax identification number, and driver's license number and state of issuance thereof, of
10 LION MANAGEMENT objects to this Request to the extent that it seeks information
11 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
12 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
13 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
14 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
15 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
16 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
17 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
18 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
19 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
20 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
22 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
23 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
24 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
25 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
26 discovery at this pre-class certification stage of this action. Evid. Code 21O, 350, 950-955, 1060,
27 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
28
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 21:
2 LION MANAGEMENT objects to this Request on the grounds that it violates the privacy of
3 the individual owners of IP AA and is not reasonably calculated to lead to the discovery of admissible
4 evidence. Subject to the foregoing, after a diligent search and good faith inquiry, LION
5 MANAGEMENT will produce any non-privileged documents in its possession, custody or control
8 DOCUMENTS sufficient to show the legal name, principal residence address, date of birth,
9 and driver's license number and state of issuance thereof of every talent scout, and the name each
10 talent scout used while soliciting customers for LION MANAGEMENT and/or IPAS, since April 6,
11 2012.
13 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
14 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
15 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
16 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
17 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
18 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
19 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
20 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
21 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
22 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
23 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
25 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
26 is overbroad, harassing, and seeks confidential proprietary infonnation, and is therefore improper and
27 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
28 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
discovery at this pre-class certification stage of this action. Evid. Code 210, 350, 950-955, 1060,
2 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
4 LION MANAGEMENT objects to this Request on the grounds that it violates the privacy of
5 LION MANAGEMENT/IPAA's employees and is not reasonably calculated to lead to the discovery
9 All Showcase Directories for every showcase LION MANAGEMENT and/or IPAS has
12 LION MANAGEMENT objects to this Request to the extent that it seeks information
13 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
14 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
15 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
16 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
17 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
18 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
19 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
20 3,4 (Class actions: "l. Plaintiffs do only the discovery they need to meet their certification needs.
21 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
22 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
24 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
25 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
26 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
27 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
28 discovery at this pre-class certification stage ofthis action. Evid. Code 210, 350, 950-955, 1060,
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
3 After a diligent search and good faith inquiry, LION MANAGEMENT will produce any non-
4 privileged documents in its possession, custody or control that are responsive to this Request.
6 All documents relating to any policy, guideline, manual, instruction set, procedure, and/or
7 practice which required, prompted, applied to, controlled, or governed LION MANAGEMENT's
8 destruction or retention of any document responsive to any discovery served by COSIO in this case.
10 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
11 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
12 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
13 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
14 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
15 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
16 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
17 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
18 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
19 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
20 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
22 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
23 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
24 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
25 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
26 discovery at this pre-class certification stage of this action. Evid. Code 21O, 350, 950-955, 1060,
27 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
28
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 24:
2 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
3 protected from disclosure by the attorney client privilege and/or work product doctrine. Subject to
4 the foregoing, after a reasonable search and diligent inquiry, LION MANAGEMENT will produce
7 All documents which LION MANAGEMENT may use to support any objection which LION
10 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
11 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
12 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
13 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
14 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
15 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
16 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
17 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
18 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
19 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
20 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
22 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
23 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
24 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
25 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
26 discovery at this pre-class certification stage of this action. Evid. Code 21O, 350, 950-955, 1060,
27 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
28
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 25:
2 LION MANAGEMENT objects to this Request as vague, ambiguous and unintelligible, and
5 All DOCUMENTS which LION MANAGEMENT may use to support the following passage
6 from the parties' June 20, 2016 joint case management statement:
11 LION MANAGEMENT objects to this Request to the extent that it seeks information
12 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
13 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
14 obligations other than those imposed by Sections 2017.010 and 2031.210 et seq. of the Code of Civil
15 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
16 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
17 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
18 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
19 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
20 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
21 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
23 LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
24 is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
25 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
26 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
27 discovery at this pre-class certification stage ofthis action. Evid. Code 210, 350, 950-955, 1060,
28 1061; CCP 2017.0lO et seq., 2018.030 (work product), 2019.210 (trade secrets).
CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST FOR PRODUCTION NO. 27:
2 All DOCUMENTS which LION MANAGEMENT may use to support any contention that
5 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
6 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
7 MANAGEMENT objects to these Requests insofar and to the extent they purport to impose on it
8 obligations other than those imposed by Sections 20 17.010 and 2031.210 et seq. of the Code of Civil
9 Procedure. LION MANAGEMENT further objects to this Request as prematurely served, and failing
10 to abide by the Court's procedures for discovery in complex litigation and guidance for class action
11 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
12 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
13 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
14 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
15 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
17
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23 //
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CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
LION MANAGEMENT further objects that that the scope of Plaintiff's requested discovery
2 is overbroad, harassing, and seeks confidential proprietary infonnation, and is therefore improper and
3 violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
4 until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
5 discovery at this pre-class certification stage ofthis action. Evid. Code 210, 350, 950-955, 1060,
6 1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
10
11
Attorneys for Defendants
12 INTERNATIONAL PERFORMING
ARTS ACADEMY, LLC, BARBIZON SCHOOL OF
13 SAN FRANCISCO, INC.,
LION MANAGEMENT GROUP, INC.,
14 LARRY D. LIONETTI, and LENA M. LIONETTI
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CASE NO. CGC-16-551337
SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP INC. 's RESPONSES TO PLAINTIFF'S
FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
VERIFICATION
2 I, LENA QUESADA LIONETTI, am Vice President of Lion Management Group, Inc., and
3 authorized to make this verification on its behalf. I have read the foregoing SUPPLEMENTAL
5 REQUESTS FOR PRODUCTION OF DOCUMENTS and know its contents. I have personal
7 I declare under penalty of perjury under the laws of the State of California that the foregoing
6t
8 is true and correct. Dated thil 8ay of March 2017.
10
LE A QUESADA LIONETTI
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CASE NO. CGC-16-551337
VERIFICATION
PROOF OF SERVICE
2 I am over the age of eighteen and not a party to this action; I am employed by PUTTERMAN
3 LANDRY + YU LLP. My business address is 353 Sacramento Street, Suite 560, San Francisco,
4 California 94111.
13 UNITED STATES MAIL by placing a true copy of the document(s) listed above
for collection and mailing following the finn's ordinary business practice in a
14 sealed envelope with postage thereon fully prepaid for deposit in the United States
15 mail at San Francisco, California addressed as set forth below.
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CASE NO. CGC-16-551337
PROOF OF SERVICE
David C. Parisi A ttorneys for Plaintiff
Suzanne Havens Beckman ANGELICA COSIO
2 PARISI & HAVENS LLP
212 Marine Street, Suite 100 VIA E-MAIL ONLY
3 Santa Monica, California 90405
TEL: (818) 990-1299
4 FAX: (818) 501-7852
E-Mail: dcparisi@parisihavens.com
5 shavens@parisihavens.com
10
11 I declare that I am employed in the office of a member of the bar of this court at whose direction
12 the service was made. Executed on March 17, 2017, at San Francisco, California.
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15 MELANIE K. KING
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