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(wage 1 of 36) 1 || FREEDMAN + TAITELMAN, LLP Bryan J. Freedman (State Bar No, 151990) 2 || bffeedman@ftllp.com Steven E. Formaker (State Bar No. 93906) ie 5 3 || sformaker@tlip.com Supe A, 1901 Avenue of the Stars, Suite 500 iy a ea 4 || Los Angeles, California 90067 ‘Telephone: (310) 201-0003 DEC 91 2017 5 || Facsimile: (310) 201-0045 Ronee 6 || Attorneys for Plaintiffs EMJAG PRODUCTIONS, INC, “SES Devuty SCOTT LAMBERT, and ALEXANDRA MILCHAN 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 11 || BMJAG PRODUCTIONS, INC., a ) Case No. BC685514 California corporation; ) 12 | SCOTT LAMBERT, an individual; and ——-)-_Unlimited Civil Case ALEXANDRA MILCHAN, an individual, ) 3 ‘n ) COMPLAINT FOR DAMAGES FOR: Plaintiff, ) 4 ) 1, BREACH OF WRITTEN vs. ) CONTRACT; 15 ) THE WEINSTEIN COMPANY LLC,2 = 2. QUANTUM MERUIT; 16 [Delaware limited liability company; and) DOES 1 through 20, inclusive, } 3. NEGLIGENCE; AND 7 ) Defendants. 4, FRAUD BY CONCEALMENT 18 ) sy 19 20 Plaintiffs EMJAG Productions, Inc, “EMJAG"), Scott Lambert (“Lambert”), and Alexandra 21 || Mitchan (“Milchan”), as their causes of action against The Weinstein Company LLC (“TWC") and 22 ||Does 1 through 20, inclusive, allege as follows: 23 INTRODUCTION 24 1. Lambert and Milchan are a husband and wife team of accomplished Hollywood 25 || producers. ‘They spent years developing a television project to be directed by noted director David 6 © 27 || created for the Project and to hire Lambert and Milchan as producers for the Project. They were to "2. 28 |} be compensated for their work as producers on a pay-or-play basis. Because the Project was to be 0. Russell (the “Project”), TWC agreed to purchase the valuable intellectual property that they had 1 COMPLAINT boot 1 pagel 3 ~ Doe 3D = 2719403279 ~ Doc type = om ths oom = guztanerer = at 200 - 2 #a6ea T $000 i = erreceses Censor etesosit RECEIPT as COHASIZ DATE PAID: Iz/04s17 PAYMENT: $435.09, RECETVEr 05S 44:20 0m 0 #438.00 40.00 $9.00 30.00 Sy eo \) zea) or age 3 of 35) 1 || filmed in New York, they would need to relocate to New York City. They uprooted their lives to 2 || accommodate the needs of the Project. 3 |}; 2. TWC partnered with Amazon Studios, LLC (“Amazon”) on the Project. Upon information and belief, Amazon provided essential financing for the Project. 3." TWC had lured Plaintiffs into a trap. Unknown to Plaintiffs, TWC’s former co- 4 5 6 || chairman, Harvey Weinstein, had engaged in multiple acts of sexual misconduct. This misconduct — 7 which TWC knew very well, but concealed from Plaintiffs — was effectively a ticking time bomb. In October 2017, the time bomb exploded with the revelation of Weinstein’s sordid history of sex abuse, The Project was one of its casualties, as Amazon, seeking to distance itself from Weinstein, 10 || withdrew from the Project. TWC then withheld the compensation that it had promised to pay to 11 |] Plaincitts. 2 II THE PARTIES 13 4, EMJAG is, and was at all relevant times, a corporation in good standing organized 14 |Jand existing under the laws of the State of California that maintains its principal place of business in 15 |}the County of Los Angeles, State of California, EMJAG functions as a loan-out company for the 16 || services of Lambert and Milchan. 7|I 5. Lambert is, and was at all relevant times, an adult individual who resides in the 18 || County of Los Angeles, State of California, 19 6. Milchan is, and was at all relevant times, an adult individual who resides in the 20 || County of Los Angeles, State of California 2 7. Plaintiffs are informed and believe that TWC is, and was at all relevant times, a 22 |) limited liability company organized under the laws of the State of Delaware that does business in the 23 || State of California and maintains an office within the County of Los Angeles, State of California. 24 || TWC was, until its reputation became tarnished due to the sexual predation of one of its founders, a 25 || major player in the production of motion pictures and television shows. ho 26 Plaintiffs are unaware of the true names and capacities of those defendants sued & 27 || herein as Does 1 through 20, inclusive, and therefore sue such defendants unde fictitious names. "2g || Plaintfs are informed and believe that each of the fcttiously-named defendants participated in the i 2 COMPLAINT Doo 1 page 3 ~ Doe ID = 1719401279 - Doo type = on age 4 of 36) @ e } 1 || wrongful conduct hereinafter alleged. Plaintiffs will amend this Complaint to set forth the true 2 || names of the fictitiously-named defendants after they have been ascertained. 3 9. Plaintiffs are informed and believe that each defendant, in performing the acts and 4 || omissions alleged herein, was an agent, partner, joint venturer, or employee of each of the other 5 || defendants, acting within the course and scope of such relationship. 6 FIRST CAUSE OF ACTION 7 (Breach of Written Contract) i 8 10. Plaintiffs incorporate by reference, as though fully set forth hereat, each and every : 9 | allegation of Paragraphs 1 through 9 of this Complaint. 10 | LL. For several years prior to 2016, Plaintiffs worked on developing the Project, The 11- || Project was to be a television crime drama series to be directed by David O. Russell. By the fall of 12 |} 2016, the esteemed actors Robert De Niro and Julianne Moore were attached to the Project. TWC. 13 |[and Amazon committed to produce two seasons of the series at a reported cost of $160 million, 14 || Upon information and belief, Amazon provided essential financing for the Project, 15 12. Inor about November 2016, Plaintiffs and Defendant TWC reached a verbal 16 || understanding that TW would acquire the rights to the Project. Plaintiffs would be retained to act, 17 |] as producers for the Project. As it was envisioned that the Project would be filmed in New York, 18 || this would require Plaintiffs to relocate from their home in Los Angeles, California to New York. 19 || They would have to remove their children from their schools in Los Angeles, and enroll them in new 20 |] schools in New York. 2 13. After reaching the verbal understanding, Plaintiffs and TWC entered into negotiations 22 || of the specific terms of the contract for TWC’s acquisition of the tights to the Project. 2B 14, Ina November 28, 2016 e-mail that Plaintiffs’ transactional attorney sent to TWC's 24 |) president, David Glasser, Plaintiffs made a written offer to TWC that included the following material 25 || terms relating to Plaintiffs’ compensation: i > 26 (a) A $250,000 development fee, 100% of which would be payable to Plaintiffs é oa immediately. 3 28 iii - 3 COMPLAINT —— —————————————————————— = Doct 2 Page# 4 = Doo 1D = 1719401279 - Doo type ~ ommt (eage § of 16) | (©) Anexecutive producer deal paying Lambert $50,000 per episode, on a play- 2 or-pay basis with the same minimum number of episodes as the principal cast, 3 / (©) Anexecutive producer deal paying Milchan $50,000 per episode, on a play- 4 |]; or-pay basis with the same minimum number of episodes as the principal cast. 5 | (4) Back-end compensation to Lambert and Milchan of not less than 1.5 points 6 / apiece (i. 3 points for the two of them combined) based upon modified adjusted gross 7 : receipts, sf (6) A travel allowance for reasonable travel when required, which was to cover | ol reasonable number of flights to and from Los Angeles per season, 10 : (Provision ofa ear and driver when Lambert and/or Milchan were working in u New York. | 12 |f (g) A logo credit for Lambert. | 2B (h) An office and an assistant for Milchan at TWC’s offices in New York, | “4 15, Glasser acknowledged receipt of the November 28, 2016 e-mail and promised to 15 || respond “shortly.” In the expectation that a contract would be formalized shortly thereafter, 16 |} Plaintiffs continued to work diligently on the Project. However, months passed before TWC 17 |] provided its response to Plaintifis’ offer. 18 16. Finally, on May 2, 2017, Glasser replied to the November 28, 2016 e-mail with an e- 19 || mail of his own, In that e-mail, Glasser confirmed in writing TWC’s agreement as to the terms 20 |} controlled by TWC, but noted that back-end points were controlled by David O. Russell. ai 17, Plaintiffs thereafter negotiated with representatives of David O. Russell on their 22, || back-end compensation, On June 20, 2017, by means of an exchange of e-mails, the parties agreed 23 |)in writing that PlaintiffS' back-end compensation would be 1.5% of 100% of modified adjusted gross 24 || receipts (defined on @ most favored nations basis), reduoible pro rata if necessary to accommodate 25 || additional star cast (that is, beyond Robert De Niro and Julianne Moore). | "5 26 || 18. The foregoing e-mail exchanges constituted a written contract between TWC and 27 || Plaintiffs (the “Contract”) 2 28 |i _ 4 COMPLAINT iL = oot £ Page § ~ Doo 1 = 1718401279 - boo Type = ons rage 6 of 16) eS & be 10 u 13 4 15 16 7 19 20 a 22 23 24 25 26 7 28 19. The principal cast members for the Project were guaranteed a minimum of twenty episodes of the series. Because Plaintifis’ guarantees were tied to those of the principal cast members, they were likewise guaranteed that their contractual executive producer compensation of $50,000 apiece per episode would be payable for a minimum of 20 episodes. 20. Plaintiffs performed all conditions to be performed by them pursuant to the Contract, except to the extent that such performance was excused by Defendants’ actions. Among other things, the performance included Plaintiffs’ execution of documentation assigning their intellectual property rights in the Project to an entity affiliated with TWC. 21. In October 2017, Harvey Weinstein, who was one of the co-founders of TWC, was revealed to have engaged in a pervasive pattern of sexual abuse. Upon the revelation of this sordid pattern, Amazon withdrew ftom the Project. Amazon’s withdrawal resulted in the cancellation of the Project. 22, After Amazon withdrew, TWC ceased performing its obligations under the Contract. ‘TWC has breached the Contract by, among other things, failing to pay Plaintiffs any of their ‘executive producer compensation, failing to pay Plaintiffs’ reasonable travel expenses between Los Angeles and New York, failing to provide Plaintiffs with a car and a driver while they were in New York, and failing to provide Milchan with an office and an assistant. 23. Asa result of Defendants’ breaches of the Contract, Plaintiffs have suffered damages well in excess of $2,000,000, the exact amount of which has not yet been ascertained, but which shall be proven upon the trial of this action. SECOND CAUSE OF ACTION (Quantum Meruit) 24. Plaintiffs incorporate by reference, as though fully set forth hereat, each and every allegation of Paragraphs | through 23 of this Complaint. 25, Between November 2016 and October 2017, Plaintiffs performed services for Defendants in connection with the development of the Project, at Defendants’ special request. | Defendants knew that these services were being provided and promised to pay for them. Defendant | accepted, used, and enjoyed the services provided by Plaintiffs. 5 COMPLAINT ‘oot 1 Fagee 6 - Doo HD = 1739402279 ~ eage 7 of 16) 1 26. Defendants have failed and refused, and continue to fail and refuse, to pay Plaintiffs 2 || for the services that they provided. 3 27. Plaintiffs have demanded payment for their services, but Defendants have failed and 4 || refused, and continue to fail and refuse, to pay for the services rendered by Plaintiff 5 28. Plaintiffs have suffered damages in the amount of the reasonable value of the services 6 ||that they provided to Defendants, according to proof. 7 THIRD CAUSE OF ACTION 8 (For Negligence) i 9 29. Plaintiffs incorporate by reference, as though fully set forth hereat, each and every ; 10 || allegation of Paragraphs | through 28 of this Complaint. uf} 30. Harvey Weinstein (“Weinstein”) is one of the founders of TWC, and until October 12 || 2017 was TWC’s co-chairman and an employee of TWC. At all material times, Weinstein 13 |] functioned as the public face of TWC. Asa result, TWC was widely associated with Weinstein’s 14 || persona. 15 31. Upon information and belief, beginning long before TWC’s founding in 2005 and 16 |} continuing into 2017, Weinstein engaged in a pattern of sexual abuse of many of the actresses and 17 || other women whom he encountered while conducting business. Weinstein pattem of abuse was so 18 || reprehensible that, when it became public knowledge, TWC’s involvement in a motion picture or 19 || television production became toxic. The revelation of Weinstein’s pervasive misconduct resulted in 20 || the cancellation of a number of productions, including the Project. 21 32. Defendants had a duty to exercise reasonable care to assure that Weinstein was fit to 22 || occupy his position with TWC and to supervise Weinstein's conduct as an employee of TWC. 2B 33. Defendants knew when TWC entered into the Contract with Plaintiffs that the success 24 || of the Project was largely dependent on TWC maintaining its reputation in the entertainment 25 || community. Defendants knew or should have known that a scandal that destroyed TWC’s reputation 15, 26"|] would lead to the cancellation of Amazon’s involvement the Project and prevent the realization of © 27 || the objects of the Contract. ro 28 lives 6 COMPLAINT | Doct 1 Fage# 7 Boo 2D = 1789401279 ~ Doo type ~ OMER rage 8 of 26) 1 34, Defendants had numerous warning signs that such a scandal was brewing. In the 2 |] years before TWC entered into the Contract, TWC had received numerous complaints of sexual 3 |] abuse and harassment engaged in by Weinstein. Those complaints, if investigated with reasonable 4 || diligence, would have disclosed that Weinstein was unfit for his position with TWC. 5 || Notwithstanding the many complaints of Weinstein’s misconduct, Defendants continued his 6 ||employment as TWC’s co-chairman and allowed him to continué to be TWC’s public face. Worse, 7 || Defendants provided Weinstein with a steady flow of potential victims of further abuse by allowing 8 |] him to meet with actresses and other women on behalf of TWC without any supervision 9 35. Defendants negligently breached their aforementioned duties of reasonable care by 10 ||{continuing to employ Weinstein despite numerous indications of his unfitness to serve in his position 11 |/and by faiting to reasonably supervise his conduct as TWC’s employee. 12 36. Asa direct and foreseeable result of TWC’s negligence, Plaintifis have suffered 13 ||demages in an amount that has not yet been ascertained, but which shall be proven upon the trial of 14 |} this action, 15 FOURTH CAUSE OF ACTION 16 (For Fraud by Concealment) 7 37. Plaintiffs incorporate by reference, as though fully set forth hereat, each and every 18 || allegation of Paragraphs | through 36 of this Complaitt. 9 38. Upon information and belief, beginning long before TWC’s founding in 2005 and 20 || continuing into 2017, Weinstein engaged in a pattern of sexual abuse of actresses and other women 21 || whom he encountered while conducting business, 2 39. Defendants were well aware of Weinstein’s pervasive pattern of abuse, TWC had 23 || made multiple payments to victims of such abuse to settle claims of sexual assault and harassment. 24 || Weinstein’s employment contract with TWC reportedly provided that he could continue to engage in 25 |] such abuse without breaching the contract, so long as he paid TWC a fine and reimbursed TWC for 26 || the resulting payouts to claimants. ei > 28 ilies 1 COMPLAINT 2 Pageh @ = Doc ZB = 1739401279 - Doo type OMER age 9 of 36) 1 40. Weinstein’s pattern of abuse was a fact that would be material to anyone contracting. 2 || with TWC to develop and/or produce a project with TWC, including Plaintiffs, because of the risk 3 | that the project would be tainted in the public eye by its association with Weinstein. 41. Defendants had long presented TWC as a reputable production company with which }10 do busiriess, both prior to and during the time that the Contract was under negotiation, This image of reputability was maintained by Defendants by means of the suppression of the facts of Weinstein’s sexual abuse and of Defendants’ role in enabling the abuse to continue, 42. Plaintiffs negotiated with TWC under the belief that they were dealing with a reputable company. During the time of the negotiations and at the time that they entered into the 10 |{Contract, they had no knowledge of Weinstein’s history of sexual misconduct. Had they known of 11 || his sordid history, they would not have entered into the Contract, as it would have exposed TWC’s 12 |}appearance of reputability to be a sham, | B 43. During the negotiations of the Contract, Defendants concealed Weinstein’s pattem of | 14 || sexual abuse from Plaintiffs. Defendants did so with the intention that Plaintiffs would enter into the Contract in reliance thereon, 16 44, Plaintiffs, in reasonable reliance on their lack of knowledge of the concealed facts, 17 |Jentered into the Contract and assigned valuable intellectual property rights for the Project to an 18 || affiliate of TWC. 9 45, Asa direct, foreseeable and proximate result of Defendants” fraudulent conduct 20 || Plaintiffs have suffered damages in an amount that has not yet been ascertained, but which shall be 21 || proven upon the trial if this action, 2 46, Inacting as alleged above, Defendants acted fraudulently, oppressively, and 23 || maliciously, in that they intentionally concealed material facts known to them with the intention of 24 || thereby depriving Plaintiffs of property or legal rights or otherwise causing injury, and thereby 25 |lengaged in despicable conduct that subjected Plaintiffs to cruel and unjust hardship in conscious v= 26 || disregard of Plaintiff's rights. Defendants should accordingly be required to pay punitive or & 27 |\exemplary damages to Plaintiffs p28 rie 8 COMPLAINT 1 eee ‘Doct 1 Fage¥ 9 = Doe ED = 1719403279 - Doo tyge = om (tage 10 of 16 10 12 13 14 15 16 7 18 19 20 au 22 23 24 25 26 a 28. WHEREFORE, Plaintiffs pray for damages against Defendants, and each of them, jointly and severally, as follows: ON THE FIRST CAUSE OF ACTION For damages in an amount in excess of $2,000,000, according to proof, For interest on the damages, at the legal rate; For costs of suit incurred herein; yO DP For such other and further relief as the court may deem just aid proper; ON THE SECOND CAUSE OF ACTION " For damages, according to proof; For interest on the damages, at the legal rate; am For costs of suit incurred herein; = For such other and further relief as the court may deem just and proper; ON THE THIRD CAUSE OF ACTION 1. For damages, according to proof; J. Forcosts of suit incurred herein; K. _ Forsuch other and further relief as the court may deem just and proper; ON THE FOURTH CAUSE OF ACTION L. __ Forcompensatory damages, according to proof; M, For punitive damages, according to proof. N. For costs of suit incurred herein; and ©. Forsuch other and further relief as the court may deem just and proper. DATED: December 1, 2017 FREEDMAN + TAITELMAN, LLP By: BGA Usnn re | Steven E. Formaker 1 Attorneys for Plaintiffs EMJAG || PRODUCTIONS, INC., SCOTT LAMBERT, and ALEXANDRA MILCHAN 9 ‘COMPLAINT ‘oot 2 Paget 20 - Deo 2 1719401279 ~ Doe type = OTR age 12 of 16) {Lirimev oteanivwiOUT TGV ps, Se Sar aan Fon counT aa on Bryan J. Freedavan, Beq/Steven E,Formaker, Esq, SBN: 1$1990/93906 PREEDMAN + TAITELMAN LLP e ® coi 1901 Avenue of the Stars, Suite $00, Los Angeles, CA 90067 F LER via exon: (310) 201-0005 raeso-(310) 20-0085 Sea fants a _sromev ron ysis EMJAG Prout, nc Scot Lambe an Alani ican {ueenor cour oF ex roma, courrv oF LOS ANGELES DEC 01 2017 ‘NET 00286 111 North Hill Sireet ‘uwuna hoones-111 North Hil Street ‘ rc x, Exggufve Ofeet et] cya pecooe Los Angeles, California 90012 Shen est suse ne: Conal Distt Pte ANRTEE ‘CASE NAME: EMIAG Productions, In, et al v. The Weinsiein Company, LLC ‘OVIL'GAGE GOVER SHEET — a be ewe I sont | $< peepee sionedss200m) Séno0aresy| "(Caesar na 940) | er tems 1-6 belbW Tus be completed (see insrucions on page 2). [FCheek one bax below ore case iype that best descibes iis case: ‘uta Tort Contract Provsionsly Complex Gv Ltgation (EI isto aay [J ‘ereach ot contacvwarrany (06) {Cal Rules of Cour, rules .600-3.403) ‘Uninsured motorist (46) 2) ute 3.740 conecsions (03) F) Antirusi Trace reguiation (03) ‘Other PUPDIWO (Personal injury'Property — [_] ther catections (09) TZ) Construction detec (10) Samagertrongt Deas) Tort () snararce cover (18) 1 isto 40) Tasbenas 8) TF onrerconvact 97 Sects tigation (20) Products 20) fsa Property [ EonmantaTontan (0) Mecial mlsctce (48) [Enno donainrverse TF rweance conrage cine si tom ne | [J one Puen cn) tendemvaton a) ‘ove ies ool conse Non PVPOMWD (Other) Tort rong eviction (99) ‘ypes cat) Busines tons busless paces (or) L_] Other rea xopeny (28) Exforcoment of Judgment Git ights (08) Lnlawtvt Detainer OD entorcerent of judgment (20), Splamatn (9) CJ commmerciat 31> Miscellaneous Civil Complaint me (esos 2) (oy sco ‘elected propery (19) TF dags cm, 2) omer compain (not specie above) (42) Professional negigence (25 Jada Review cancercaca Other nen PUPOMND a 25) foo fuser Parwerstip and arporate governance 21) Employment Peston: abiaton aver (1) eee aor! I wrrengtut termination (38) wet ot mandate (2) ae ae [J other emotoyment (18) (7) ontes jul review (39) 2 Thsease L_Jis LJ ienot complex under rule 3.400 ofthe Calvoria Rules of Cau the case is complex, mark the factors requitng exceptional dial management a. Large number of separately represented partes 4, [_] Large number of witnesses [1] Extensive motion practice raising diticutt or novel e. [—) Coordination with related actions pending In one or more courts issues that willbe time-consuming to resolve in other counties, states, or counties, ori a federal cout c. (7) Substantial amount of documentary evidence +. [1 Substantal postiudgment judicial supervision 38. Remedies sought (check al that pp) 4, Number of causes of action (specty) Four (4) 5, Thiscase [lis (isnot a class action sult. 6. Ifthere are any known related cases, file and serve a natice of related case. (You may use form CM-015) FREE! rATELMAN, LLP Steven E, Foomaket. E5455 raarmme———————— bLece TURE SF FoR OF ATTORNEY FOR PARTY) NOTICE « lot ust cover sae wth he pape fed int sion or rceedig (xcept ema cr cates orcas ed vo“ tidorne Pate God, Fariy Godot Woda and abutens Coe) ea. Bue ute 9 20 Pane fhe may ok 7 seretor + BETTE Str soon aston any cover ses equ el out “Hitless comply one Ja 340 clean he Calon Fides Cos, you mos see a copy oh cover shot onal eter artes oe stone proce. 1) « Ghetto cdo under le 740 ra compl case, cover het ibe uid or satan ony ey Givi CASE COVER SHEET ere and monetary 6. nonmonetary declaratory or injunctive ree ¢ Xpunitive oot 1 Paged 11 ~ Dee 3D = 1739401279 - Doe type = oma (rage 22 of 10) INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET To Plaintfs and Others Filing First Papers. you are fling a frst paper (or example, a complaint) In a eNi ease, you must ceamplete and le, along with your tet paper, the Ci! Gase Cover Shee! containes on page. This information wil be used to compte Stalsics about the types and numbers of cases fied. You must complete ems 1 through 6 on the sheet..In tem 1, you must check ‘one box fr the cave type that best describes the case. I the cago fes bath a general and a more speci ype of case listed In Kom 1, heck the mare specife one, I the case has muliple causes of action, check ihe box that best indicates the primary cause of action ‘To asset you in completing the sheet, examples of the cases that belong under each case type Initem 1 are provided below. A cover ‘sheet must be fled only wit your inal paper. Fallure to le a cover shest with tho frst papa led ina ell case may subject a party, its counselor both fo sanctions under ules 2.30 and 3220 ofthe Callomia ues of Court To Parties in Rule 2.740 Collections Cases. A “collections cate" under ule 3.740 és defined as an action for recovery of money cowed ina sum stated io be certain that Is nat more than $25,000. exclusive of interest and attorney's feos, arising fom a waneaction in lihich property, services, or money was aoqufed on cred, A collections case does not include an action seeking te follwing: (1 fat damages, (2) punitive damages, (2) recovery of real property, (4) recovery of personal propery, of (5) a prejudgment wit of attachment, The Kentiicaion ofa case as a rue 3.740 colecons caso on this form means that it wil be exems fm the general {ime-forse‘vee requirements and case management rules, unless a delendart les a responsive pleading. A rue 3.740 colecfons ‘case wil be subject to the requirements for carvice and abtainng 3 judgment in rule 3740, ‘To Parties in Complex Cases. In complex cases only, partes must also use the Givl Case Cover See to designate whether the case is comple, I a pail beeves ine case ls compex under rUie 2400 ofthe California Rules of Coun, ts must be Indicated by ‘competing the appropiate boxes in tems 1 an 2. I'2 plain designates a case as complex, the cover sheet must served wit the ‘complaint on all partes to the action. A delendant may file ard serve no later than the time of lis fst appearance a jinder in the plan's designation, a counter-designation thatthe case isnot complex, o,f the paint nas mace ro dasignaton, a designation that cuo10 {he case is complex Auto Tort “auto (21-Pereonal nun eepenty ‘Osmage/rongil Death seeurad Mors (46) (fhe “ase vais an amined Inotortelam suet ‘mbtraton heck Fem Instead of Auto) ‘ther PUPOIWD (Persona injury Property Samageriongtu Beat Asbestos (04) Asbesios Property Damage Dedesiog Personal ay? Preducl Labi (01 abesios or Tovvenveorment) (28) Medea Marsico (<) Medea! talracica Presser & Surgeons ‘iharProtesions Hoan Gare aration Other PUPDID (23) Promises Latiy (0. ip ‘od al) Irvestiona Boy enyPOMMD (ea. arcacl, vancatsm) Ironton nian of ‘Erallonal Distess Neatiget neion of Erotonal Oisross other PuPOMD Non-PUPOAYD (Other) Tor ‘Business Tenn Business Prat (07, ‘Gi nns (eq, cscminaton, "ae are (nt ct horas (8) Detamation fe, sande, be) ta) Fraud (8) Insecta Property (19) Protersoral Negigence (25) Legal Welpacice (iter Profesional Majractoe re OM patmeacal 2 ega FD onerNon PUPOIWD ToA (8) Epelovment "Wrong Termination (98) ier Employment (18) ‘cocpa aaa (CASE TYPES AND EXAMPLES contact Breach of Conreraranty (06) Grescho! Retaitoare ‘Contras (ot lal dtainer 9: wrangiloton) ContactWaratty Bese Seller Parl nt frau or rapigence) Negigan Breach ol Contac ‘Wareniy ‘other Breach of ConracrWaranty Ccaecton os, money owed, open ook cet) (0) Coteston Case Sater Pint Other Promisson NteColectons Insurance Coverage ra provsonaly ‘ome (i) Sra Subrogaon Cine Coverage ‘ner Contra (37) ‘Conrecva Haus Siner Contact Dispue feat Property. met Darlioverse Condenmanon i) ‘wrong Eon 3) ter Rel Property (ait 28) ‘Weve Posrecson aed Proper Nongspe Foreaarore ult te ‘Sire eal Provery (nt eminent aman, andoraronst, oF fereaersre) Unizwtat Deange “Gommorci (21) Rendon 2 ‘rags (3 (he ase ites egal rugs, Shek te te: oben, ‘ooo ar Comment or osorto) sudiia Ree ise Foro (05) Petton Reh ialon Award (11) itemise Mansomus Wicancers on ies Cot wicSer Linas Cou Case owe ‘one si Revi vow ot eal Sie: Grr Nese of Appear Conmgsone epee CIVIL CASE COVER SHEET Provisionally Complex Civil Livgetion (Cal utes of Court ules 3 800-2.403) ewes ae Regain (03) Cenavucton Oeee (0) lame ncn Mas To (40) Seer aigaton 2). Envvosmertal Txt Tot (0) Ineuranos Coverage Garms (aig tom provioraly complex Ease ype lated above) 9) Enlorcement of Judgment Enlreement of Juspment (20) ‘stato uggment (Out ol ‘County. CConteson ol ugment (nan domeste relaion) Sister Sale susoment ‘emisvabve Agony Avra (not urea ares) Petton entation of ety of “udpmenton Unpals Taxes rec Enireamert ot uogment tase Miscetaneous Civil Complaint ico 27 ther Comelait (o! specios pov) (12) Declan Rael Ony Iron Rete! Ont tron harassment Mechanics en ‘Giher Commas Complaint 88 (nomortnon campex) ‘omer Compa inontorinomeoretes) Penna and Corporate ‘Govomanse 2") ‘omer Baton (nt spi sbove) 9) Eieivarasament Warepace Violence ElienDependent Adu Jecion Cones! Beton Name Change Pein le Ret From ate ‘Cam (ther Cit Petion 12 = boc XD = 1719404279 = Doo type = OTR rage 13. of 16) e e TIE EMING Pods w The Webicn Company ro Re aTS 1 CIVIL CASE COVER SHEET ADDENDUM AND ‘STATEMENT OF LOCATION | (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) ‘hs om ened pruaio Lova fue 2 pwc igt nb Loe Angel por oa | Step 1: After completing the Civil Case Cover Sheet (Judicial Counel form CN-010}, find the exact case type in Column & that corresponds tothe case type indicated inthe Civil Case Cover Sheet ‘Step 2: in Column 8, check the box for the type of action that best describes the nature of the.case. Step 3: In Column, circle the number which explains the reason for the court filing location you have chosen, ‘Applicable Reasons for Choosing Court Filing Location (Column C) 1: lags atone must be fein he Startey Mosk Courtheuse, Cana Dist, 7. Location where petoner resides. 2. Permissive fing in cert set, 8. Location wherein detendenurespondetrctions whol 3. Location where cause of acon arose 9. Location where one or more fhe pars resi. 4 Mandotory personal ini ng in Norn Dist. 10, Location of Labor Commissioner Ofc, 21, Mandatory flag location (Hub Cases —unlwfldetainer limites 5. Location ware perlomance requis rdefendnt esos Fea eee eat Hh 6. Lecaton ot property or permaneniy garaged vehicle a B c ‘ct. 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