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1 Ethan Preston (263295)

PRESTON LAW OFFICES


2 4054 McKinney Avenue, Suite 310 ELECTRON ICALLY
Dallas, Texas 75204 FILED
3 (972) 564-8340 (telephone) Superior Court of California,
(866) 509-1197 (facsimile) County of San Francisco

4 ep@eplaw.us 07/12/2017
Clerk of the Court
5 [Additional Counsel Listed on Next Page] BY:JUDITH NUNEZ
Deputy Clerk

6 Attorneys for PlaintiffAngelica Cosio, on her own


behalf, and behalf of all others similarly situated
7

8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA


9 CITY & COUNTY OF SAN FRANCISCO
10

11

12

13 ANGELICA COSIO, an individual, on her No. CGC-16-551337


own behalf and on behalf of all others
14 similarly situated, EXHIBITS K THROUGH M TO
DECLARATION OF ETHAN PRESTON
15 Plaintiff, SUPPORTING PLAINTIFF ANGELICA
COSIO'S MOTION FOR CLASS
16 v. CERTIFICATION
17 INTERNATIONAL PERFORMING The Honorable Curtis E.A. Karnow
ARTS ACADEMY, LLC, a California Department 304
18 limited liability company, BARBIZON Civic Center Courthouse
SCHOOL OF SAN FRANCISCO, INC., a 400 McAllister Street
19 California corporation, LION San Francisco California 94102
MANAGEMENT GROUP INC., a
20 California corporation, ANTHONY Date: To be determined
LOUIS LIONETTI, LARRY D. Time: To be determined
21 LIONETTI, LENA QUESADA
LIONETTI, LENA M. LIONETTI, and Complaint Filed: April 6, 2016
22 DOES 1-100, inclusive,
Defendants.
23

24

25

26

27

28
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
18
Attorneys for PlaintiffAngelica Cosio, on
19 her own behalf, and behalf of all others
similarly situated
20

21

22

23

24

25

26

27

28
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
20
Produced (LION00463-LION00478; LION00993-
21 LION00995; LIONOIOIO)
L Preston Law Offices Firm Resume
22 M Defendants' Demand for Production Responses
23
24
25
26
27
28
EXHIBIT K
IPAS Winter 2013
Industry Professional Registration

CompanyName: ______________________________________________________________________

Attendee Name: ____________________________ Position/Title/Division: ______________________

Company Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ----,; State, Zip: _____________

Office Phone: _____________________ Cell: ____________________ Fax: ____________________

What type of modelsItalent does your company represent/mange? (Include age) _ _ _ _ _ _ _ _ __

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.

Talent: Dance .............................................. 5:00pm 6: l5pm


Talent: Vocalist ................................................. 6:15pm 7:30pm

~Model & Talent Overview .............................. 5:15pm 6:00pm **REQUIRED


IP Cocktail Party ....................................... 6:00pm 7: 15pm
~Talent Showcase ..................................... 7:30pm 8:30pm **REQUIRED
__ Special IP Dinner ................................... 8 :30pm - IO:OOpm

Sunday, February 10, 2013


~Callbacks ............................................ I 0:00am - I 2:00pm **REQUIRED
~Open Callbacks ..................................... 12:00pm 1:00pm **REQUIRED

*Timcs subject to change

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.

Please Sign _______________________________________________ Date:


--------------------

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").

IPAS and Industry Professional agree as follows:

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.

Date ___' ___---' ____


IP Signature

DOB ____~ _____! _ _ _ __


Print Legal Name

FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IPAS Winter 2014
Industry Professional Registration

CompanyName: ______________________________________________________________________

Attendee Name: ____________________________ Position/Title/Division: ______________________

Company Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ----,; State, Zip: _____________

Office Phone: _____________________ Cell: ____________________ Fax: ____________________

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.

Talent: Dance .............................................. 5:00pm 6: l5pm


Talent: Vocalist ................................................. 6:15pm 7:30pm

~Model & Talent Overview .............................. 5:15pm 5:45pm **REQUIRED


IP Cocktail Party ....................................... 6:00pm 7:30pm
~Talent Showcase ..................................... 7:30pm 8:30pm **REQUIRED
__ Special IP Dinner ................................... 8 :30pm - IO:OOpm

Sunday, January 12,2014


~Callbacks ............................................ I 0:00am - I 2:00pm **REQUIRED
~Open Callbacks ..................................... 12:00pm 1:00pm **REQUIRED
IP Brunch ............................................. 1:00pm - 2:00pm

*Timcs subject to change

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.

Please Sign _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Date: _ _ _ _ _ _ _ _ __

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").

IPAS and Industry Professional agree as follows:

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.

Date ___' ._ _---' ____


IP Signature

DOB ____~ _____: ____


Print Legal Name

FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IPAS Winter 2015
Industry Professional Registration

CompanyName: ______________________________________________________________________

Attendee Name: ____________________________ Position/Title/Division: ______________________

Company Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ----,; State, Zip: _____________

Office Phone: _____________________ Cell: ____________________ Fax: ____________________

What type of modelsItalent does your company represent/mange? (Include age) _ _ _ _ _ _ _ _ __

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.

Talent: Dance .............................................. 5:45pm 6:30pm


Talent: Vocalist ................................................. 6:30pm 7:15pm

___ IP Cocktail Party ....................................... 4:45pm 5:30pm


~Model & Talent Overview and Final Show ...... 5:30pm 7:00pm **REQUIRED
Special IP Dinner ................................... 7:00pm 9:00pm

Sunday, January 18,2015


~Callbacks ............................................ 1O:00am 12:30pm **REQUIRED
~Open Callbaeks ..................................... 12:30pm- 2:00pm **REQUIRED
IP Lunch ............................................. 2:00pm 3:00pm

*Tirnes subject to change

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.

Please Sign _______________________________________________ Date:


--------------------

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").

IPAS and Industry Professional agree as follows:

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.

Date ___' ._ _---' ____


IP Signature

DOB ____~ _____: ____


Print Legal Name

FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IP AS Summer 2013
Industry Professional Registration

CompanyName: ______________________________________________________________________

Attendee Name: ____________________________ Position/Title/Division: ______________________

Company Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ----,; State, Zip: _____________

Office Phone: _____________________ Cell: ____________________ Fax: ____________________

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.

Talent: Dance .............................................. 5:00pm 6: l5pm


Talent: Vocalist ................................................. 6:15pm 7:30pm

~Model & Talent Overview .............................. 5:15pm 5:45pm **REQUIRED


IP Cocktail Party ....................................... 6:00pm 7:30pm
~Talent Showcase ..................................... 7:30pm 8:30pm **REQUIRED
___ Special IP Dinner ................................... 8 :30pm - 10:00pm

Sunday, June 30, 2013


~Callbacks ............................................ I 0:00am - I 2:00pm **REQUIRED
~Open Callbacks ..................................... 12:00pm 1:00pm **REQUIRED
IP Brunch ............................................. 1:OOpm - 2:00pm

*Timcs subject to change

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.

Please Sign ______________________________________________ Date: __________________

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").

IPAS and Industry Professional agree as follows:

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.

Date ___' ._ _---' ____


IP Signature

DOB ____~ _____! _ _ _ __


Print Legal Name

FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IPAS Summer 2014
Industry Professional Registration

CompanyName: ______________________________________________________________________

Attendee Name: ____________________________ Position/Title/Division: ______________________

Company Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ----,; State, Zip: _____________

Office Phone: _____________________ Cell: ____________________ Fax: ____________________

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.

Talent: Dance .............................................. 5:00pm 6: l5pm


Talent: Vocalist ................................................. 6:15pm 7:30pm

~Model & Talent Overview .............................. 5:45pm 6:00pm **REQUIRED


~Talent Showcase ..................................... 6: 15pm 7:30pm **REQUIRED
IP Cocktail Party ....................................... 7:30pm 8:15pm
___ Special IP Dinner ................................... 8: 15pm - 10:00pm

Sunday, June 29, 2014


~Callbacks ............................................ I 0:00am - I 2:30pm **REQUIRED
~Open Callbacks ..................................... 12:30pm 2:00pm **REQUIRED
IP Lunch ............................................. 2:00pm- 3:00pm

*Timcs subject to change

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.

Please Sign ______________________________________________ Date: ___________________

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").

IPAS and Industry Professional agree as follows:

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.

Date ___' ._ _---' ____


IP Signature

DOB ____~ _____,_____


Print Legal Name

FAX: 4 t 5.704.3384
www.TalentShowcase.tv
IPAS Fall 2015
Industry Professional Registration

CompanyName: ______________________________________________________________________

Attendee Name: ____________________________ Position/Title/Division: ______________________

Company Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ----,; State, Zip: _____________

Office Phone: _____________________ Cell: ____________________ Fax: ____________________

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.

Talent: Dance .............................................. 5:45pm 6:00pm


Talent: Vocalist ................................................. 6:00pm 6:45pm

___ IP Cocktail Party ....................................... 4:30pm 5:30pm


~Model & Talent Overview and Final Show ...... 5:30pm 7:00pm **REQUIRED
Special IP Dinner .................................... 7:00pm 9:00pm

Sunday, November 15, 2015


~Callbacks ............................................ 1O:00am 12:30pm **REQUIRED
~Open Callbaeks ..................................... 12:30pm- 2:00pm **REQUIRED
IP Lunch ............................................. 2:00pm 3:00pm

*Tirnes subject to change

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.

Please Sign _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Date: _ _ _ _ _ _ _ _ __

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").

IPAS and Industry Professional agree as follows:

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.

Date ___' ___---' ____


IP Signature

DOB ____~ _____: ____


Print Legal Name

FAX: 4 t 5.704.3384
www.TalentShowcase.tv
SHOWCASE Fall 2016
Industry Professional Registration

CompanyName: ______________________________________________________________________

Attendee Name: ____________________________ Position/Title/Division: ______________________

Company Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ----,; State, Zip: _____________

Office Phone: _____________________ Cell: ____________________ Fax: ____________________

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.

Talent: Dance .............................................. 5:45pm 6:00pm


Talent: Vocalist ................................................. 6:00pm 6:45pm

___ IP Cocktail Party ....................................... 4:30pm 5:30pm


~Model & Talent Overview and Final Show ...... 5:30pm 7:00pm **REQUIRED
Special IP Dinner .................................... 7:00pm 9:00pm

Sunday, November 13, 2016


~Callbacks ............................................ 1O:00am 12:30pm **REQUIRED
~Open Callbaeks ..................................... 12:30pm- 2:00pm **REQUIRED
IP Lunch ............................................. 2:00pm 3:00pm

*Tirnes subject to change

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.

Please Sign _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Date: _ _ _ _ _ _ _ _ __

FAX: 415.704.3384
www.TalentShowcase.tv
INDUSTRY PROFESSIONAL AGREEMENT
Showcase - November 10 - 13, 2016

This Agreement is entered into between SHOWCASE and ("Industry Professional" or


"IP") representing ("IP Entity"), as an [insert
position such as agent, casting director, A & R, etc] Whereas, SHOWCASE wishes IP to act, and IP agrees to
act, as an industry professional at SHOWCASE Event being held in November 2016 and outlined in attached form
(referred to herein as an "Event").

SHOWCASE and Industry Professional agree as follows:

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.

Date _ _---' ._ _---' ____


IP Signature

DOB ____~ _____! _ _ _ __


Print Legal Name

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").

IPAS and Industry Professional agree as follows:

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.

Date _ _---: ___--' ___


IP Signature

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

Company Name: ______________________________________

Attendee Name: _______________ Positiollrfitlc/Divisioll: ____________

Company Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _City, State, Zip: _ _ _ _ _ _ _ _ _ _ __

Office Phone: ___________ Cell: ___________ Fax: ___________

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.

*Times subject to change

Friday, June 29,2012


_ _ Talent: Soaps, TV Bea.J!Y, TV Commeraa ..... II :OOmn - 4:00pm
_ _ Tarot: TV Bea.Jty, TV Commeraa, Sitcom. .. 11 :OOam -4:00pm
_ _ Taen!: MOflologues. ................................ 11:00mn-4:00pm
Talent: Dance .............................................. 4:15pm - 5:00pm
Talent: Vocalist ................................................. 5:00pm - 6:00pm

Saturday. JUlie 3D. 2012


_ _ Commeraa & Fashion Print ............................ 1:00pm-2:00pm
_ _ Trendy Runway ...................................... 2:00pm - 3:15pm
__ High Fashion! SWimwea .......................... 3:15pm-5:00pm
~Model & Tarot OvavieN .............................. 5:30pm -6:00pm "''''REQUIRED
_ _ JP CockttiJ Paiy ....................................... 6:00pm -7:30pm
~Talel1t Showcase..................................... 7:30pm - 8:30pm ""'REQUIRED
_ _ Special IP Dinner ................................... 8:30pm - 1O:00pm

Sunday. July 1. 2012


~Calba::ks ............................................ 10:00an -12:00pm **REQUIRED
~Opfl CaJba::ks..................................... 12:00pm - 1:00pm **REQUIRED

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.

Please Sign _ _ _~_~~~~~~~_~_ _ _ _ _ _ _ _ __ Date: _ _ _ _ _ _ _ _ _~

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").

IPAS and Industry Professional agree as foHows:

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").

IPAS and Industry Professional agree as follows:

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.

Date ___.1_ _--'1_ __


IP Signature

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

(May 2017) FIRM RESUME

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).

Representative rulings obtained by Preston Law Offices include Kuns v. Ocwen


Loan Servicing LLC, No.1 2015 WL 2405422 (9th Cir. May 21,2015)
(reversing Rule 12(b)(6) dismissal); Holmes v. NCO Financial Services, Inc., No. 11-
56969, 2013 WL 4376585 (9th Cir. Aug. 16, 2013) (reversing summary
judgment); Meyer v. Portfolio Recovery Associates, LLC, 707 F.3d 1036 (9th Cir.
2012) (affirming preliminary injunction and class certification under Rule
23(b)(2)); In re Col/ecto, Inc., Telephone Consumer Protection Act Litigation, No. 14-
02513, 2016 WL 552459 (D. Mass. Feb. 10, 2016) (denying motion for summary
judgment on Telephone Consumer Protection Act); Lofton v. Verizon Wireless
(VAW) LLC, 308 F.R.D. 276 (N.D. Cal. 2015) (granting motions to compel and
sanction defendants); Wang v. Asset Acceptance LLC, No. 09-04797, 2010 WL
2985503 (N.D. Cal. july 27,2010) (denying motion to dismiss Fair Credit
Reporting Act claim against furnisher); DuFour v. Be., LLC, No. 09-3770, 2009 WL
4730897 (N.D. Cal. Dec. 7, 2009) (granting constructive trust as preliminary
injunction); Lofton v. Bank of Am. Corp., No. 07-05892, 2008 WL 2037606 (N.D.
Cal. May 12, 2008) (granting discovery motions); and In re Netflix Antitrust
Litigation, 506 F. Supp. 2d 308 (N.D. Cal. 2007) (ruling consumers have standing
to bring Walker Process antitrust claims, ordering limited discovery on other
elements of antitrust claims).
Mr. Preston received his Bachelor of Arts degree with honors from the Plan II
honors program at the University of Texas at Austin, and his juris doctor degree
with distinction from the Georgetown University Law Center in 2001. Mr.
Preston is admitted to practice in California and Texas, and is also admitted to
practice before the United States District Court in, e.g., the Northern and
Eastern Districts of Texas, all Districts in California, as well as the United States
Courts of Appeals for the Seventh and Ninth Circuits.

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

6 Attorneys for Defendants


INTERNATIONAL PERFORMING ARTS ACADEMY, LLC,
7 BARBIZON SCHOOL OF SAN FRANCISCO, INC.,
LION MANAGEMENT GROUP, INC.,
8 LARRY D. LIONETTI, and LENA M. LIONETTI

9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN FRANCISCO
11

12 Case No. CGC-16-551337


ANGELICA COSIO, an individual, on her own
13 behalf and on behalf of all others similarly SUPPLEMENTAL DEFENDANT LION
situated, MANAGEMENT GROUP, INC.'S
14 RESPONSES TO PLAINTIFF'S FIRST
Plaintiff, SET OF REQUESTS FOR PRODUCTION
15 OF DOCUMENTS
v.
16
INTERNATIONAL PERFORMING Assigned for all purposes:
17 ARTS ACADEMY, LLC, a California limited Hon. Curtis E.A. Karnow
liability company, BARBIZON SCHOOL OF Dept.: 304
18 SAN FRANCISCO, INC., a California Complaint Filed: April 6, 2016
corporation, ANTHONY LOUIS LIONETTI,
19 LION MANAGEMENT GROUP INC., a
California corporation, LARRY D. LIONETTI,
20 LENA QUESADA LIONETTI, LENA M.
LIONETTI, and DOES 1-100 inclusive
21
Defendants.
22

23

24

25 PROPOUNDING PARTY: Plaintiff ANGELICA COSIO


26 RESPONDING PARTY: Defendant LION MANAGEMENT GROUP, INC.

27 SET NO.: One (1)

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"),

2 Defendant LION MANAGEMENT GROUP, INC. hereby responds to Plaintiff ANGELICA

3 COSIO'S First Set of Requests for Production.

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

14 seq. of the Code of Civil Procedure.

15 C. LION MANAGEMENT objects to these Requests on the grounds to the extent they

16 purport to require disclosure of communications protected by the attorney-client privilege. LION

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

21 RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS

22 REQUEST FOR PRODUCTION NO.1:

23 All DOCUMENTS identified or referenced in LION MANAGEMENT's responses to

24 COSIO's Form Interrogatories, Set One, served with this demand.

25 RESPONSE TO REQUEST FOR PRODUCTION NO.1:

26 Responding party LION MANAGEMENT SCHOOL OF SAN FRANCISCO, INC.

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

10 plaintiffs file the certification motion.")

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).

17 REQUEST FOR PRODUCTION NO.2:

18 All DOCUMENTS that COSIO's Form Interrogatories, Set One (served with this demand)

19 directed LION MANAGEMENT to identify or reference.

20 RESPONSE TO REQUEST FOR PRODUCTION NO.2:

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

4 plaintiffs file the certification motion.")

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).

11 REQUEST FOR PRODUCTION NO.3:

12 All DOCUMENTS that LION MANAGEMENT will use or may use to support any defenses

13 to COSIO's claims.

14 RESPONSE TO REQUEST FOR PRODUCTION NO.3:

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

26 plaintiffs file the certification motion.")

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).

5 REOUEST FOR PRODUCTION NO.4:

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.

13 RESPONSE TO REOUEST FOR PRODUCTION NO.4:

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

25 plaintiffs file the certification motion.")

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).

4 SUPPLEMENTAL RESPONSE TO REOUEST FOR PRODUCTION NO.4:

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,

9 custody or control concerning COSIO.

10 REQUEST FOR PRODUCTION NO.5:

11 All DOCUMENTS concerning any communication regarding this case between LION

12 MANAGEMENT and another person (aside from COSIO, her attorneys, or the Court).

13 RESPONSE TO REQUEST FOR PRODUCTION NO.5:

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

25 plaintiffs file the certification motion.")

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).

4 REOUEST FOR PRODUCTION NO.6:

5 All DOCUMENTS concerning any communication regarding this case between IP AS and

6 another person (aside from COSIO, her attorneys, or the Court).

7 RESPONSE TO REOUEST FOR PRODUCTION NO.6:

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

19 plaintiffs file the certification motion.")

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).

26 REOUEST FOR PRODUCTION NO.7:

27 All organization charts and personnel directories which identify LION MANAGEMENT's

28 employees, officers, directors, managers, and/or members.


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.7:

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

13 plaintiffs file the certification motion.")

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).

20 SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO.7:

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.

2 REQUEST FOR PRODUCTION NO.8:

3 All organization charts and personnel directories which identify IP AS's employees, officers,

4 directors, managers, and/or members.

5 RESPONSE TO REQUEST FOR PRODUCTION NO.8:

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

17 plaintiffs file the certification motion.")

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

24 constitutional protected privacy rights.

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).

3 SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO.8:

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

12 PERFORMING ARTS ACADAMY, LLC during the relevant time period.

13 REQUEST FOR PRODUCTION NO.9:

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

20 misstatements or misrepresentations about IP AS's services.

21 RESPONSE TO REQUEST FOR PRODUCTION NO.9:

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

5 plaintiffs file the certification motion.")

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).

12 SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO.9:

13 LION MANAGEMENT objects to this Request as overbroad, burdensome and harassing as

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

17 reasonably calculated to lead to the discovery of admissible evidence.

18 REQUEST FOR PRODUCTION NO. 10:

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.

21 RESPONSE TO REQUEST FOR PRODUCTION NO. 10:

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

5 plaintiffs file the certification motion.")

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).

12 REQUEST FOR PRODUCTION NO. 11:

13 All contracts or agreements between IP AS and its customers on whose behalf LION

14 MANAGEMENT andJor IPAS received payment since April 6, 2012.

15 RESPONSE TO REQUEST FOR PRODUCTION NO. 11:

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

27 plaintiffs file the certification motion.")

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).

6 REQUEST FOR PRODUCTION NO. 12:

7 All contracts or agreements between LION MANAGEMENT and LION MANAGEMENT

8 since April 6, 2012.

9 RESPONSE TO REQUEST FOR PRODUCTION NO. 12:

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

21 plaintiffs file the certification motion.")

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.

3 RESPONSE TO REQUEST FOR PRODUCTION NO. 13:

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

15 plaintiffs file the certification motion.")

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).

22 REQUEST FOR PRODUCTION NO. 14:

23 All DOCUMENTS concerning communications between LION MANAGEMENT and

24 BARBIZON since Apri16, 2012.

25 RESPONSE TO REQUEST FOR PRODUCTION NO. 14:

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

9 plaintiffs file the certification motion.")

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).

16 REQUEST FOR PRODUCTION NO. 15:

17 All DOCUMENTS concerning communications between LION MANAGEMENT and IP AS

18 since April 6, 2012.

19 RESPONSE TO REQUEST FOR PRODUCTION NO. 15:

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

3 plaintiffs file the certification motion.")

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

9 Connecticut (1965) 381 U.S. 479, 484).

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).

16 REQUEST FOR PRODUCTION NO. 16:

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

21 of such customers for services rendered or goods provided to such customers.

22 RESPONSE TO REQUEST FOR PRODUCTION NO. 16:

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

6 plaintiffs file the certification motion.")

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

10 also Information Practices Act of 1977, Civil Code, 1978 et seq.

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).

17 REQUEST FOR PRODUCTION NO. 17:

18 All DOCUMENTS concerning marketing ofIPAS's services, including (a) DOCUMENTS

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

26 market IP AS's services.

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

13 plaintiffs file the certification motion.")

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).

20 SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 17:

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

8 time period) ; and (b) policies concerning the practices at issue.

9 REQUEST FOR PRODUCTION NO. 18:

10 All DOCUMENTS supporting any of LION MANAGEMENT's and/or IPAS' advertisements

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

15 manager, or any associate, representative, or designee thereof

16 RESPONSE TO REQUEST FOR PRODUCTION NO. 18:

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

28 plaintiffs file the certification motion.")


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).

7 REQUEST FOR PRODUCTION NO. 19:

8 All DOCUMENTS supporting any of LION MANAGEMENT's and/or IPAS' advertisements

9 and representations since April 6, 2012 that one or more ofIPAS's customers obtained an audition,

10 employment opportunity, or professional employment in the entertainment industry in whole or in

11 part by use of IP AS's services.

12 RESPONSE TO REQUEST FOR PRODUCTION NO. 19:

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

24 plaintiffs file the certification motion.")

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).

3 REQUEST FOR PRODUCTION NO. 20:

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

6 MANAGEMENT's owner(s) and member(s), since April 6, 2012.

7 RESPONSE TO REQUEST FOR PRODUCTION NO. 20:

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

19 plaintiffs file the certification motion.")

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).

26 SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 20:

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.

5 REOUEST FOR PRODUCTION NO. 21:

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

8 IPAS's owner(s) and member(s), since April 6, 2012.

9 RESPONSE TO REOUEST FOR PRODUCTION NO. 21:

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

21 plaintiffs file the certification motion.")

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

6 sufficient to identify the owners of IP AA during the relevant time period.

7 REQUEST FOR PRODUCTION NO. 22:

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.

12 RESPONSE TO REQUEST FOR PRODUCTION NO. 22:

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

24 plaintiffs file the certification motion.")

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).

3 SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 22:

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

6 of admissible evidence. LION MANAGEMENT further objects to this Request as seeking

7 employment records without a notice to consumer.

8 REQUEST FOR PRODUCTION NO. 23:

9 All Showcase Directories for every showcase LION MANAGEMENT and/or IPAS has

10 conducted since April 6, 2012.

11 RESPONSE TO REQUEST FOR PRODUCTION NO. 23:

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

23 plaintiffs file the certification motion.")

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).

2 SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 23:

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.

5 REQUEST FOR PRODUCTION NO. 24:

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.

9 RESPONSE TO REQUEST FOR PRODUCTION NO. 24:

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

21 plaintiffs file the certification motion.")

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

5 any non-privileged documents responsive to this Request.

6 REQUEST FOR PRODUCTION NO. 25:

7 All documents which LION MANAGEMENT may use to support any objection which LION

8 MANAGEMENT makes to any discovery request served by COSIO in this case

9 RESPONSE TO REQUEST FOR PRODUCTION NO. 25:

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

21 plaintiffs file the certification motion.")

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

3 lacking particularity pursuant to CCP Section 2031.030(a)(2)(c)(1).

4 REQUEST FOR PRODUCTION NO. 26:

5 All DOCUMENTS which LION MANAGEMENT may use to support the following passage

6 from the parties' June 20, 2016 joint case management statement:

7 Defendants is in the business of providing an event, their "Showcase," allowing young


talent the opportunity to compete in an "American Idol" type contest. The "Showcase"
8 event takes place over several days during which there are workshops, critiques and
presentations for contestants. Also invited are members of the entertainment
9 community to judge these events.
10 RESPONSE TO REQUEST FOR PRODUCTION NO. 26:

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

22 plaintiffs file the certification motion.")

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

3 IP AS's showcase is a competition, contest, or convention.

4 RESPONSE TO REQUEST FOR PRODUCTION NO. 27:

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

16 plaintiffs file the certification motion.")

17

18

19

20 II
21 II
22 II
23 //

24 II

25 II
26
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
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).

8 Dated: March 17, 2017


9

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

4 DEFENDANT LION MANAGMENT GROUP, INC.'S RESPONSES TO PLAINTIFF'S

5 REQUESTS FOR PRODUCTION OF DOCUMENTS and know its contents. I have personal

6 knowledge of the matters stated therein and declare them to be true.

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.

5 On March 17 2017, I served the foregoing document( s) described as:

6 SUPPLEMENTAL DEFENDANT LION MANAGEMENT GROUP, INC.'S RESPONSES TO


PLAINTIFF'S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
7
on the interested party(ies) below, using the following means:
8
ELECTRONIC TRANSMISSION based on a court order or an agreement of the
9 parties to accept service bye-mail or electronic transmission, I caused the
documents to be sent to the persons at the e-mail addresses on the attached service
10
list on the dates and at the times stated thereon. I did not receive, within a
11 reasonable time after the transmission, any electronic message or other indication
that the transmission was unsuccessfuL The electronic notification address of the
12 person making the service is .mJj;!lli~rill~Y&Q.ill

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.

OVERNIGHT DELIVERY by depositing a true copy ofthe same enclosed in a


16 D sealed envelope, with delivery fees provided for, in an overnight delivery service
17 pick up box or office designated for overnight delivery, and addressed as set forth
below.
18
MESSENGER SERVICE by causing to be personally delivered a copy of the
19 D document(s) listed above to the person(s) at the addressees) set forth below.
20 Zack Broslavsky Attorneysfor Plaintiff
Jonathan A. Weinman ANGELICA COSIO
21 BROSLAVSKY & WEINMAN, LLP
11755 Wilshire Boulevard, Suite 1250 VIA E-MAIL ONLY
22 Los Angeles, California 90025
TEL: (310) 575-2550
23 FAX: (310) 464-3550
E-mail: zbroslavsky@bwcounseLcom
24 jweinman@bwcounseLcom
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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

6 Ethan Preston Attorneysfor Plaint(n'


PRESTON LAW OFFICES ANGELICA COSIO
7 4054 McKinney Avenue, Suite 310
Dallas, Texas 75204 VIA MAIL AND E-MAIL
8 TEL: (972) 564-8340
FAX: (866) 509-1197
9 E-Mail: ep@eplaw.us

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.

13

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15 MELANIE K. KING

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CASE NO. CGC-16-551337


PROOF OF SERVICE

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