(Page 1 of 23) Y. 1 JOHN L. HOLCOMB, JR, BAR ID #258175 iholcomb@khslaw.com 2 SHAHROKH SHEIK, BAR ID #250650 FILED sshe1k@khslaw.com Superior Court of California 3 KRAMER HOLCOMB SHEIK LLP County of Los Angeles 1925 Century Park East, Ste. 1180 . 4 Los Angeles, California 90067 JUN 0 632018 Telephone: (310) 551-0600 . 5 Facsimile: (310) 551-0601 Shem R- Car er. Exec Of?cer/Clerk 6 371,421. ,Deputy Attorneys for Plaintiffs, M0595 50?? 7 Amy Nobile and Trisha Ashworth 3 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES . 10 AMY NOBILE, an individual; and CASE NOTRISHA A HW RTHCOMPLAINT FOR: 12 P1 muffs 1. BREACH OF ORAL JOINT VENTURE - 13 v, 2. PROMISSORY 14 . . 3. BREACH FIDUCIARY 15 SUZANNE TODD, an 1nd1v1dual, 4. Defendant 5. BREACH OF IMPLIED-IN-FACT 1 6 6. BREACH OF 17 7. UNJUST 18 8. UNFAIR BUSINESS PRACTICES IN VIOLATION OF CAL. BUS. PROF. 19 CODE ?17200; - . 9. AND 20 10. CONVERSION 21 DEMAND FOR JURY TRIAL 22 23 24 25 53COMPLAINT Doc# 1 Page# 1 Doc ID 1741750476 Doc Type OTHER (Page 2 of 23) cum-ASE: emu-9030 LEm'Der??s: RECEIPT CCH524880002 DQTE PAID: 0?:43 PRVMENT: $435.00 310 CHECK: $435.00 CASH: $0.00 $0.r-T?div; a 2: 13Doc# 1 Page# 2 Doc ID 1741750476 Doc Type OTHER (Page Plaintiffs Amy Nobile and Trisha Ashworth (collectively referred to as ?Plaintiffs?), 2 demanding trial by jury, complain and allege on information and belief as follows: 3 THE PARTIES 4 1. Plaintiff Amy Nobile (?Nobile?) is an individual and is a resident of New York, who at 5 times mentioned in this complaint resided in Marin County, State of California. 6 2. Plaintiff Trisha Ashworth (?Ashworth?) is an individual and is a resident of Illinois, who 7 at times mentioned in this complaint resided in Marin County, State of California. 8 3. Defendant Suzanne Todd (?Todd?) is an individual and is now, and at all times mentioned 9 in this complaint was, on information and belief, a resident of the County of Los Angeles, State of 10 California. i 11 JURISDICTION AND VENUE 12 4. This Court has jurisdiction over this action pursuant to the California Constitution, Article 5 13 VI, Section 10, which grants the Superior Court ?original jurisdiction in all causes except those l4 given by statute to other courts.? The statutes under which this action is brought do not specify 15 any other basis for jurisdiction. 16 S. This Court has jurisdiction over all defendants because, upon information and belief, each I 17 party is either a citizen of California, has sufficient minimum contacts in California, or otherwise i 18 intentionally avails itself of the California market so as to render this Court's jurisdiction over it 19 consistent with traditional notions of fair play and substantialjustice. 20 6. Venue as to each defendant is proper in this judicial district pursuant to California Code of 21 Civil Procedure Sections 395(a) and 395.5, because the acts herein complained of, and the 22 injuries to Plaintiffs, occurred in the County of Los Angeles. Defendants, and each of them, own 23 or maintain offices in the County of Los Angeles, transact business there, have an agent or agents 24 within the County of Los Angeles, or are otherwise found within the County of Los Angeles. 25 COMMON ALLEGATIONS 3? 26 7. Plaintiffs are the international best?selling authors of the books I Was A Really Good Mom 27 Before I Had Kids, Dirty Little Secrets from Otherwise Perfect Moms, and I?d Trade My Husband 28 for a Housekeeper (the ?Books?). Their work is a pioneer in the literary genre of comedic 2 COMPLAINT Doc# 1 Page# 3 - Doc ID 1741750476 Doc Type OTHER (Page 4 of 23) area 4' 1031openness and honesty about motherhood. They have been promoted on national media including Oprah, The Today Show, 20/20, Rachael Ray, NPR, People Magazine, Redbook and many other outlets. 8. In 2008, Defendant contacted Plaintiffs after seeing them on The Today Show, informing them that they believed there was signi?cant potential to develop their Books and genre insights into ?lms and television series. 9. On Defendant?s invitation, Plaintiffs met with Defendant to discuss potential collaboration on ?lm and television projects. Plaintiffs agreed to work with Defendant to disclose their prOprietary research derived from hundreds of interviews with women and insights from the Books and collaborate on ?lm and TV projects with the understanding Plaintiffs would be compensated in the form of producing and/or writing fees and credit as well as applicable licensing fees in connection with any projects arising from the collaboration or based on their Books (?Agreement?). 10. Over the course of the next three years from 2008 through 2011, (the ?Collaboration Period?), Plaintiffs disclosed character sketches, plot ideas, sequences, as well as extensive proprietary research, including dozens of thoughts/quotes from interviews with hundreds of women and insights with third party experts, pursuant to the Agreement in efforts to develop and produce film and television projects. 11. It was always understood between Defendant and Plaintiffs (collectively, the ?Parties?) that if Defendant used Plaintiffs? ideas, research and insights, Defendant would compensate and credit Plaintiffs pursuant to the Agreement. Over the years, up to and including the release of the Film in November 2016, Plaintiffs, operating under the understanding that the Agreement remained in full force and effect, passed up several ?lm/television opportunities to collaborate with Defendant on translating their content and ideas to a ?lm or television show. 12. In or around November 2016, Defendant produced the ?lm, Bad Moms (the ilm?). Upon seeing the Film, Plaintiffs were shocked to discover it included substantial themes, sequences, character sketches and plot lines from the Books as well as Plaintiff?s private and proprietary research, concepts, and ideas disclosed in private collaborative meetings, emails and 3 COMPLAINT Doctt 1 Page# 4 Doc ID 1741750476 Doc Type OTHER (Page 5 of 23) 1 calls during the Collaboration Period (collectively, the ?Results and Proceeds?). 2 l3. Defendant used the Results and Proceeds in developing the Bad Moms script. 3 l4. Defendant accepted the disclosure and the reasonable value of Plaintiffs? work when 4 Defendant accepted the Results and Proceeds and encouraged Plaintiffs to provide plot sequences, 5 character sketches, and furtherbrainstorm other ideas with Defendant?s team, arranged additional 6 meetings, and forwarded Plaintiffs copies of scripts to review and revise throughout the 7 Collaboration Period. 8 15. Defendant used the Results and Proceeds in the production of Bad Moms as evidenced by 9 Defendant?s access to Plaintiffs? ideas and the similarities between the works (the Film, Results 10 and Proceeds and the Books). First, Defendant had unfettered access to Plaintiffs? ideas during 1 the three years the Parties worked together when Plaintiffs revealed tremendous amounts of I 12 proprietary research, insights, and disclosed many ideas to translate the Books into 13 ?lm/television. Second, Defendant?s use is indisputable as the Film uses themes and ideas 14 expounded by Plaintiffs in their books and employs plots, scenes and various ideas Plaintiffs 15 provided to Defendant during the Collaboration Period, including without limitation: i 16 i. competitiveness and high standards between mothers, 17 ii. constant labeling and judging of one another between moms, pressures to have perfect marriages and be ?good moms,? but in truth all moms 18 have ?dirty little secrets,? iv. pressures to prepare perfect home-cooked meals, such as packaging store-bought i 19 donuts in Tu erware containers to make them appear home?made, PP 20 v. mom fantasies, such as, fantasizing about having breakfast or coffee alone, or I getting into a car accident and being cared for in the hospital, 21 vi. hiring tutors for any and all activities to help their children succeed, vii. mom cliques, 22 friendships or lack thereof between moms, and ix. the overall message that mothers need to be less overworked and learn to make i 23 mistakes. 24 16. After the release of the Film, Plaintiffs were contacted by numerous colleagues and 25 friends inquiring whether the Film was based off of their Books. In fact, the Film was so similar 26 to Plaintiffs? Books Dirty Little Secrets from Otherwise Perfect Moms and I was a Really Good G9 ?If 27 Mom Before I had Kids, that many of Plaintiffs? readers contacted them to congratulate them on a ts.) 28 ?lm being made based on their Books. a: 4 Doc# 1 Page# 5 - Doc ID 1741750476 - Doc Type OTHER (Page 6 of 23) 1 17. The Film has caused signi?cant confusion among Plaintiffs? reader base, platforms and 2 has banned Plaintiffs? reputation and prospective business opportunities. 3 l8. Defendant used the Results and Proceeds in connection with the Film and the derivative 4 works thereto in breach of the Agreement. The Film went on to generate over $1 $0,000,000.00 in 5 the worldwide box of?ce, the derivative ?lm Bad Moms 2 has been released, and Bad Dads is 6 slated for release. 7 FIRST CAUSE OF ACTION 8 BREACH OF ORAL JOINT VENTURE AGREEMENT 9 (Plaintiffs against Defendant) 10 19. Plaintiffs re?allege and incorporate herein by reference each and every allegation and 1 1 statement contained in the prior paragraphs. 12 20. In 2008, Plaintiffs, on the one hand, and Defendant, on the other, entered into an oral 13 joint venture agreement for the purpose of collaborating together to develop ?lm and television 14 projects based off of Plaintiffs? Books and insights (the ?Agreement?). The material terms of the 15 Agreement, which were discussed an agreed upon at this meeting, included that Plaintiffs would 16 be compensated for the disclosure of the Results and Proceeds and attached by way of producing 17 and/or writing fees and credit, depending on the scope of the project and use of the Results and 18 Proceeds and Plaintiffs? future services, to any projects derived therefrom. 19 21. Plaintiffs performed all of their obligations under the Agreement or were excused from 20 performance as a result of Defendant?s material breaches. 21 22. Although Defendant had the ability to carry out the terms of the Agreement, Defendant 22 breached the Agreement by repudiating its existence and failing to compensate Plaintiffs for their 23 services and use of the Results and Proceeds. Said conduct constitutes a material breach of the 24 Agreement. 25 23. Defendant further breached the implied covenant of good faith and fair dealing by 26 unfairly preventing Plaintiffs from receiving all of the bene?ts they would be entitled to receive 27 under the Joint Venture Agreement had Defendant not breached. 28 24. As a direct and proximate result of Defendant?s breach, Plaintiffs have been damaged in 0.: 5 COMPLAINT Doc# 1 Page# 6 - Doc ID 1741750476 Doc Type OTHER (Page 7 of 23) 1 an amount according to proof at the time of trial. 2 SECOND CAUSE OF ACTION 3 PROMISSORY ESTOPPEL 4 (Plaintiffs against Defendant) ?5 25. Plaintiffs re-allege and incorporate herein by reference each and every allegation and 6 statement contained in the prior paragraphs. 7 26. Plaintiff alleges this claim in the alternative to its cause of action for Breach of Oral Joint 8 Venture Agreement. 9 27. Defendant made a promise clear and unambiguous in its terms that they would work 10 together with Plaintiffs to develop film and television projects based off of Plaintiffs? Books and 1 1 insights. The Parties agreed that Plaintiffs would be compensated for the disclosure of the Results 12 and Proceeds and attached by way of producing and/or writing fees and credit, depending on the 13 sc0pe of the project and use of the Results and Proceeds and Plaintiffs? future services, to any 14 projects derived therefrom. 15 28. Plaintiffs relied on the promise by Defendant as demonstrated by the fact that Plaintiffs 16 spent three years working with Defendant to devel0p ?lm and television projects based off of 17 Plaintiffs? Books and insights. During those three years, Plaintiffs revealed tremendous amounts 18 of proprietary research, insights, and disclosed many ideas to develop their Books and insights 19 into film/television. Plaintiffs forwent several film/television opportunities to collaborate with 20 Defendant on translating their content and ideas to a ?lm or television show. 21 29. Plaintiffs? reliance was both reasonable and foreseeable in light of the multiple assurances 22 by Defendant that they were committed to collaborating together to develop film and television 23 projects based off of Plaintiffs? Books and insights. Defendant accepted the Results and Proceeds 24 and encouraged Plaintiffs to provide plot sequences, character sketches, and further brainstorm 25 other ideas with Defendant?s team, arranged additional meetings, and forwarded Plaintiffs copies 26 of scripts to review and revise throughout the Collaboration Period. 27 30. As a direct and proximate result of Plaintiffs? reliance on the promise made by 28 Defendant, Plaintiffs have been damaged in an amount according to proof at the time of trial. 6 COMPLAINT Doc# 1 Page# 7 Doc ID 1741750476 Doc Type OTHER (PageS of 23) 1 2 THIRD CAUSE OF ACTION 3 BREACH FIDUCIARY DUTY 4 (Plaintiffs against Defendant) 5 31. Plaintiffs re-allege and incorporate herein by reference each and every allegation and 6 statement contained in the prior paragraphs. 7 32. Plaintiffs and Defendant were business partners by virtue of their joint venture 8 relationship. 4. 9 33. Consequently, Defendant owed ?duciary duties to Plaintiffs as their business partner, 10 including (1) to act as a reasonably careful partner would have acted under the same or similar ll circumstances, (2) refrain from misappropriating partnership opportunities, (3) to avoid secret 12 dealings to the exclusion of their other co-venturer, (4) to not engage in self?dealing, and (5) to 13 not intentionally withhold information from their co?venturer. 14 34. Defendant breached these ?duciary duties owed to Plaintiffs by, among other things, (1) 15 secretly usurping the joint venture opportunity for their own bene?t, thereby gaining a ?nancial 16 bene?t for themselves to the prejudice of Plaintiffs, (2) breaching the Agreement with Plaintiffs 17 by failing to compensate them for their services and the use of the Results and Proceeds, and (3) 18 using the Results and Proceeds in the production of Bad Moms without permission or prior 19 consultation with Plaintiffs, in breach of their duty of con?dence. 20 35. This conduct was done without Plaintiffs? knowledge or consent and was a substantial 21 factor in causing Plaintiffs? harm. 22 36. As a direct and proximate result of Defendant?s breach, Plaintiffs have suffered damages 23 in an amount to be proven at trial. 24 37. Defendant?s conduct as described herein was done with a conscious disregard of the 25 rights of Plaintiffs, with the intent to vex, annoy, and/or harass Plaintiffs and to unjustly pro?t is; 26 from the use of Plaintiffs? ideas. Such conduct was unauthorized and constitutes oppression, El 27 fraud, and/or malice under California Civil Code ?3294, entitling Plaintiffs to an award of 28 punitive damages in an amount appropriate to punish or set an example of the Defendant in an 0? 7 COMPLAINT Doc# 1 Page# 8 Doc ID 1741750476 Doc Type OTHER (Page 9 of 23) 0 1 amount to be determined at trial. 2 FOURTH CAUSE OF ACTION 3 FRAUD 4 (Plaintiffs against Defendant) 5 38. Plaintiffs re?alleg'e and incorporate herein by reference each and every allegation and 6 statement contained in the prior paragraphs. 7 39. Defendant has committed four variations of fraud. i 8 Intentional Misrepresentation 9 40. Defendant misrepresented to Plaintiffs the material fact that Defendant would i 10 compensate Plaintiffs for their services and the use of the Results and Proceeds. This I representation was false when made. 12 41. Defendant knew that the promise to Plaintiffs was false when it was made. 13 42. Defendant intended to defraud and induce Plaintiffs into the joint venture relationship 14 described above because Plaintiffs are reputable authors that would provide valuable services 15 and proprietary insights to develop ?lm and television projects based on their Books. Plaintiffs? 16 work is a pioneer in the literary genre of comedic openness and honesty about motherhood. 17 43. Plaintiffs relied on Defendant promise and provided valuable services and proprietary 18 insights to Defendant, namely the Results and Proceeds, over the course of three years. During 19 those three years, Plaintiffs revealed tremendous amounts of proprietary research, insights, and 20 disclosed many ideas to develop their Books and insights into ?lm/television. Plaintiffs forwent 21 several ?lm/television Opportunities to collaborate with Defendant on translating their content . 22 and ideas to a ?lm or television show. 23 44. Plaintiffs justifiably relied on Defendant?s promise in light of the multiple assurances by 24 Defendant that they were committed to collaborating together to develop ?lm and television 25 projects based off of Plaintiffs? Books and insights. Defendant accepted the Results and 26 Proceeds and encouraged Plaintiffs to provide plot sequences, character sketches, and further 27 brainstorm other ideas with Defendant?s team, arranged additional meetings, and forwarded ED: 28 Plaintiffs copies of scripts to review and revise throughout the Collaboration Period. er: 8 COMPLAIN Doc# 1 Page# 9 Doc ID 1741750476 Doc Type OTHER (Page 10 of 23) . 1 45. Plaintiffs did not know Defendants representation was false and believed it was true 2 especially in light of Defendant multiple assurances to Plaintiffs that they were committed to 3 collaborating together to develop ?lm and television projects based off of Plaintiffs? Books and 4 insights. Plaintiffs had no reason to believe that Defendant would not honor their promise based 5 on the multiple assurances Defendant made to Plaintiffs. Plaintiffs also justi?ably relied on 6 Defendant?s promise because the joint venture relationship that was entered into was a common 7 relationship in the ?lm and television industry, and, on information and belief, Defendant were 8 aware of this industry practice. 9 Deceit per Cal. Civil Code {$1710 10 46. Defendant made a promise to Plaintiffs (that they would collaborate together to develop 3: 1 1 ?lm and television projects based off of Plaintiffs? Books and insights, and Plaintiffs would be 12 compensated for their services and use of the Results and Proceeds) without any intention of 1 3 performing it. 14 47. Defendant knew that the promise to Plaintiffs was false when it was made. 15 48. Defendant?s promise was made with the intent to defraud and induce Plaintiffs to rely 16 upon it. Defendant intended to induce Plaintiffs into the joint venture because Plaintiffs are 17 reputable authors that would provide valuable services and proprietary insights to deveIOp ?lm 18 4 and television projects based on their Books. Plaintiffs? work is a pioneer in the literary genre of 19 comedic openness and honesty about motherhood. 20 49. Plaintiffs were unaware of Defendant?s intention not to perform the promise. 21 Actual Fraud per Cal. Civil Code 61572 22 50. Defendant intended to induce Plaintiffs to enter into the Agreement and to use their 23 signi?cant efforts and talents to develop ?lm and television projects based off of Plaintiffs? 24 Books and insights by making a promise to Plaintiffs (that Plaintiffs would be compensated for 25 their services and use of the Results and Proceeds) without any intention of performing it. 3 26 51. Defendant knew that the promise to Plaintiffs was false. ":33 27 ?52. Defendant?s promise was made with the intent to defraud and induce Plaintiffs to rely i; 28 upon it. Defendant intended to induce Plaintiffs into the joint venture relationship because 9 COMPLAINT Doc# 1 Page# 10 Doc ID 1741750476 Doc Type OTHER (Page 11 of 23) 0 9 1 Plaintiffs are reputable authors that would provide valuable services and proprietary insights to 2 develop ?lm and television projects based on their Books. Plaintiffs? work is a pioneer in the 3 literary genre of comedic Openness and honesty about motherhood. 4 53. Plaintiffs were unaware of Defendant?s intention not to perform the promise. 5 Constructive Fraud per Cal. Civil Code 61573 6 54. By virtue of thejoint venture relationship between Defendant and Plaintiffs as alleged 7 above, Defendant owed Plaintiff a duty of truth, honesty and full disclosure. 8 55. Defendant breached this duty by secretly usurping the joint venture opportunity for their i 9 own bene?t, thereby gaining a ?nancial bene?t for themselves to the prejudice of Plaintiffs. I 10 Defendant failed to disclose at any time that they did not intend to compensate Plaintiffs for their 1 1 services and use of the Results and Proceeds 12 56. Plaintiffs was misled by Defendant to their prejudice. Had Plaintiffs known Defendant?s 13 true intentions they would have never entered into the Agreement or spent a signi?cant amount 14 of time and effort into developing ?lm and television projects based off of Plaintiffs? Books and 5 insights. 16 57. As a direct and proximate result of Defendant?s fraud, Plaintiffs have been damaged in 17 an amount according to proof at the time of trial. 18 58. Defendant?s conduct as described herein was done with a conscious disregard of the rights 19 of Plaintiffs, with the intent to vex, annoy, and/or harass Plaintiffs and to unjustly pro?t from the 20 use of Plaintiffs? ideas. Such conduct was unauthorized and constitutes oppression, fraud, andlor 21 malice under California Civil Code ?3294, entitling Plaintiffs to an award of punitive damages in 22 an amount appropriate to punish or set an example of the Defendants in an amount to be 23 determined at trial. 24 FIFTH CAUSE OF ACTION 25 BREACH OF IMPLIED-IN-FACT CONTRACT ea: 26 (Plaintiffs against Defendant) 3 27 S9. Plaintiffs re-allege and incorporate herein by reference each and every allegation and 28 statement contained in the prior paragraphs. km 10 COMPLAINT Doc# Page# 11 Doc ID 1741750476 Doc Type OTHER (Page 12 of 23) 60. Plaintiffs and Defendant had an implied?in?fact contract pursuant to the Agreement 2 whereby Plaintiffs would be compensated for the disclosure of the Results and Proceeds and 3 attached by way of producing and/or writing fees and credit, depending on the scope of the 4 project and use of the Results and Proceeds and Plaintiffs1 future services, to any projects derived 5 therefrom. Defendant accepted the disclosure and the reasonable value of Plaintiffs? work when 6 Defendant accepted the Results and Proceeds and encouraged Plaintiffs to provide plot sequences, 7 character sketches, and further brainstorm other ideas with your team, arranged additional 8 meetings, and forwarded Plaintiffs copies of scripts to review and revise throughout the 9 Collaboration Period. 10 61. Defendant used the Results and Proceeds in the production of Bad Moms as evidenced by 11 Defendant?s access to Plaintiffs? ideas and the similarities between the works (the Film, Results 12 and Proceeds and the Books). First, Defendant had unfettered access to Plaintiffs? ideas during 13 the three years they worked together when Plaintiffs revealed tremendous amounts of proprietary 14 research, insights, and disclosed many ideas to translate the Books into ?lm/television. Second, 15 Defendant?s use is indisputable as the Film uses themes and ideas expounded by Plaintiffs in their 16 books and employs plots, scenes and various ideas Plaintiffs provided to Defendant during the 17 Collaboration Period. 18 62. Defendant understood that Plaintiffs were conditioning their disclosure of the Results and 19 Proceeds on Defendant?s agreement to compensate Plaintiffs for the use of the Results and 20 Proceeds. Defendant, knowing the condition before the proprietary research and insights were 21 disclosed, voluntarily accepted its disclosure. 22 63. As a result of Plaintiffs? disclosure of their Results and Proceeds to Defendant, on the 23 terms and conditions alleged above, Defendant entered into an implied-in?fact contract that 24 required Defendant to compensate Plaintiffs for the use of its Results and Proceeds. 25 64. Plaintiffs have performed each and every obligation required of them pursuant to the 26 terms and conditions of the implied~in-fact contract. :31 27 65. All conditions required by the implied-in-fact contract for Defendant?s performance 28 occurred. COMPLAINT Doc# 1 Page# 12 Doc ID 1741750476 - Doc Type OTHER (Page 13 of 23) BIQU *4 is66. Defendant found Plaintiffs? Results and Proceeds valuable and used it without compensating Plaintiffs. Defendant breached the implied?in-fact contract by failing to compensate Plaintiffs for the use of their Results and Proceeds. 67. Although Defendant had the ability to carry out the terms of the Agreement, Defendant breached the Agreement by repudiating its existence and failing to compensate Plaintiffs for their services and use of the Results and Proceeds. Said conduct constitutes a material breach of the Agreement. 68. As a direct and proximate result of Defendant?s breach, Plaintiffs have been damaged in an amount according to proof at the time of trial. SIXTH CAUSE OF ACTION BREACH OF CONFIDENCE (Plaintiffs against Defendant) 69. Plaintiffs re-allege and incorporate herein by reference each and every allegation and statement contained in the prior paragraphs. 70. Plaintiffs con?dentially disclosed proprietary research and insights, original themes, character sketches, and plot ideas, the Results and Proceeds, after Defendant requested to work with them to develop ?lm and televisions series based off their Books and insights. 71. Plaintiffs? Results and Proceeds were not generally known to the public and were only made known to persons or entities that were aware of the con?dential nature of the idea and agreed to keep the idea con?dential. 72. Defendant accepted the disclosures with the clear understanding such disclosure would be kept in con?dence pursuant to the Agreement. 73. Defendant violated this con?dence when Defendant used the Results and Proceeds in the production of Bad Moms without permission or prior consultation with Plaintiffs. 74. As a direct and proximate result of Defendant?s breach, Plaintiffs have suffered damages in an amount according to proof at the time of trial. 75. Defendant?s conduct as described herein was done with a conscious disregard of the rights of Plaintiffs, with the intent to vex, annoy, and/0r harass Plaintiffs and to unjustly pro?t 12 COMPLAINT Doc# 1 Page# 13 - Doc ID 1741750476 Doc Type OTHER (Page 14 of 23) 1 from the use of Plaintiffs? ideas. Such conduct was unauthorized and constitutes oppression, 4 2 fraud, and/or malice under California Civil Code ?3294, entitling Plaintiffs to an award of 3 punitive damages in an amount apprOpriate to punish or set an example of the Defendant in an i 4 amount to be determined at trial. i 5 SEVENTH CAUSE or ACTION 6 UNJUST ENRICHMENT i 7 (Plaintiffs against Defendant) 8 76. Plaintiffs re-allege and incorporate herein by reference each and every allegation and 9 statement contained in the prior paragraphs. 10 77. Defendant has been unjustly enriched by failing to compensate Plaintiffs for their I 1 services and the use of the Results and Proceeds in the Film, which has netted substantial profits. 12 78. Plaintiffs are entitled to damages for the bene?ts Defendant received from their services 13 and the use of the Results and Proceeds. 14 EIGHTH CAUSE OF ACTION 15 UNFAIR BUSINESS PRACTICES IN VIOLATION OF CAL. BUS. PROF. CODE 16 ?17200 17 (Plaintiffs against Defendant) 18 79. Plaintiffs re?allege and incorporate herein by reference each and every allegation and 19 statement contained in the prior paragraphs. 20 80. Defendant?s acts and conduct, as alleged above, constitute unfair competition in violation 21 of Cal. Bus. Prof. Code 17200. Cross-Defendants have engaged in unlawful, unfair, or I, 22 fraudulent business practices within the meaning of Cal. Bus. Prof. Code 17200. 23 81. Defendant engaged in unlawful conduct when Defendant breached the Agreement with 24 Plaintiffs by failing to compensate Plaintiffs for their services and the use of the Results and 25 Proceeds. Defendant made false and misleading statements that Plaintiffs would be :32 26 compensated for their services and the use of the Results and Proceeds in order to induce 27 Plaintiffs to enter into the Agreement. E: 28 82. Defendant?s unlawful business practice of soliciting ideas and failing to pay for the use 13 COWLAINT Doc# 1 Page# 14 Doc ID 1741750476 - Doc Type OTHER (Page such ideas and services resulted in ill-gotten gains when Defendant used the Results and 2 Proceeds for the Film, Bad Moms and netted substantial pro?ts. 3 83. Plaintiffs have suffered injury in fact and have lost money and/or property as a result of 4 Defendant?s unfair business practices, and Defendant have reaped unfair bene?ts and illegal 5 pro?ts at Plaintiffs? expense, and Plaintiffs are entitled to immediate possession of all amounts 6 owed to them by Defendant. 7 NINTH CAUSE OF ACTION 8 ACCOUNTING 9 (Plaintiffs against Defendant) 10 84. Plaintiffs re-allege and incorporate herein by reference each and every allegation and 1 1 statement contained in the prior paragraphs. 12 85. By virtue of the relationship between the respective parties as alleged herein, Plaintiffs 13 are entitled to the most recent accounting statement for the Film from Defendant. 14 86. Despite Plaintiffs? requests, Plaintiffs have have never received an accounting for the 15 Film from Defendant. The sole means of ascertaining such information and documentation are 16 within the control of Defendant. 17 87. Plaintiffs cannot determine their amount of damages without the most recent accounting 18 statement for the Film from Defendant. 19 88. Plaintiffs therefore demand an accounting for the Film from Defendant. 20 89. Plaintiffs re?allege and incorporate herein by reference each and every allegation and I 21 statement contained in the prior paragraphs. 22 TENTH CAUSE OF ACTION 23 CONVERSION 24 (Plaintiffs against Defendant) 25 90. Plaintiffs re-allege and incorporate herein by reference each and every allegation and 26 statement contained in the prior paragraphs. i SE1 27 91. Defendant has converted for their own use and bene?t funds belonging to Plaintiffs, and El; 28 have failed and refused and continue to fail and refuse to pay and account for these funds to 2.23 14 i COMPLAINT 1 Doc# Page# 15 Doc ID 1741750476 Doc: Type OTHER (Page 16 of 23) i A Plaintiffs. 2 92. Plaintiffs did not consent to this. 3 93. As a direct and proximate result of Defendant?s wrongful conduct, Plaintiffs have 4 suffered damages in an amount to be proven at trial. Plaintiffs also request an accounting to 5 allow them to ascertain the full amount of their damages. 6 94. Said conduct of Defendant was and is fraudulent, oppressive and malicious, and in 7 conscious disregard for the rights of Plaintiffs herein. By reason thereof, Plaintiffs are entitled to 8 recover, and hereby request an award of, punitive and exemplary damages from Defendant in an 9 amount to be determined at trial. 10 PRAYER FOR RELIEF 11 WHEREFORE, Plaintiffs pray forjudgment against Defendant, and each of them, as follows: 12 1. For general damages and special damages in an amount according to proof at trial; 13 2. For costs of suit incurred herein; 14 3. For exemplary and punitive damages on Plaintiffs? Third, Fourth, Sixth, and Tenth 15 Causes of Action against Defendant named therein, in addition to actual damages; l6 4. For restitution in an amount to be proven at trial. 17 5. For such other and further legal and equitable relief as the Court deems just and 1 8 proper. 19 20 DATED: June 5, 2018 KRAMER LCO SHEIK, LLP 21 22 BY . JOHN L. HOLCOMB, JR. 23 SHAHROKH SHEIK Attorneys for Plaintiffs, 24 AMY NOBILE and TRISHA ASHWORTH COMPLAINT Doc# 1 Page# 16 - Doc ID 1741750476 - Doc Type OTHER (Page 17 of 23) DEMAND FOR JURY TRIAL Plaintiffs hereby demand a trial by jury. DATED: June 5, 2018 KRAMER HOLCOMB HEIK, LLP By: JOHN L. SHAHROKH Attorneys for Plaintiffs, AMY NOBILE and TRISHA ASHWORTH MD 00 Ln $3 DJ 53 i?ni?ap?nhCOMPLAINT Doc# 1 Page# 17 Doc ID 1741750476 Doc Type OTHER (Page 18 of 23) Gilli-010 ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name, State Bar number. and address): FOR cover use ONLY Shahrokh Sheik (Bar #250650) Kramer Holcomb Sheik, LLP [925 Century Park East, Suite 1180 Los Angelcs, Califomta 90067 FILED TELEPHONE No.2 310?551-0600 FAX No.2 310'551'0601 - monuev FOR (Name): Amy Nobile and Trisha Ashworth SUP?l?wi? will; 0 A a I0mm, SUPERIOR COURT OF CALIFORNIA. COUNTY OF Los Augeies ounty 05 "3e cs STREETADDRESE 111 North Hill Street JUN 0 6. 2018 MAILING ADDRESS: 11 1 North Hill Street 1? 03 :23: CA 90012 licrri R. Carter, EXECU Of?certClerk CASENAME: By A ,Dcputy Amy Nobile and Trisha Ashworth vs Suzanne Todd MOSES 50m CIVIL CASE COVER SHEET Complex Case Desi nation CASE NUMBE Unlimited Limited l(Amount (Amount Counter JOInder demanded demanded is Filed with ?rst appearance by defendant JUDGE exceeds $25,000) $25000 or less) (Cal. Rules of Court, rule 3.402) DEPT: items 1?6 below must be completed (see instructions on page 2). 1. Check one box below for the case type that best describes this case: Auto Tort Contract Provisionally Complex Civil Litigation Auto (22) Breach of contraCuWarranw (05) (Cal. Rules of Court. rules 3.4ao?3.403) Uninsured motorist (46) Rule 3.740 collections (09) El AntitrustITrade regulation (03) Other (Personal lnjuryIProperty 1: Other collections (09) Construction defect (10) Mass tort (40) Securities litigation (28) Damagel'Wrongful Death) Tort Insurance COVerage (18) ?Shams (04) Other contract (37) Product liability (24) Real Property Environmentalfioxic tort (30) Medical malpractice (45) Emilie"! domainl Inverse Insurance coverage claims arising from the Other PIIPDIWD (23) condemnaiion (14) above listed provisionally complex case (Other) Tort l:l Wrongful eviction (33) ??95 1: Business (Omunfair business practice (07) Other real property (26) Enforcement of Judgment Civil rights (08) Unlawful Detainer Enforcement of judgment (20) Defamation (13) Commercial (31) Miscellaneous CivilComplaint Fraud (15) El Residential (32) RICO (27) Intellectual property (19) I: Drugs (38) Other complaint {not specified above) (42) Professional negligencel25) JudiCia' Miscellaneous Civil Petition Other tort (35) [3 Asset forfeiture (05) Partnership and corporate governance (21) Employment ?3 Petition re: arbitration award (11) [3 Other petition (not speci?e above) (43) Wrongful termination (36) Writ of mandate (02) Other employment (15) Other judicial review (39) 2. This case is [a is not complex under rule 3.400 of the California Rules of Court. If the case is complex. mark the factors requiring exceptional judicial management: a. Large number of separately represented parties d. Large number of witnesses b. :1 Extensive motion practice raising dif?cult or novel e. Coordination with related actions pending in one or more courts issues that will be time-consuming to resolve in other counties, states. or countries. or in a federal court 0. Substantial amount of documentary evidence f. Substantial postiudgment judicial supervision 3. Remedies sought (check all that apply): monetary l1- nonmonetary; declaratory or injunctive relief c. .punitive 4. Number of causes of action (specify): 10 5. This case is is not a class action suit. 6. If there are any known related cases, ?le and serve a notice of related case. You ay us form 5.) Date: 06/5/l 8 Shahrokh Sheik (TYPE 0R PRINT NAME) ltSI URE 0W ATTORNEY FOR NOTICE Plaintiff must ?le this oover sheet with the ?rst paper ?led in the action or proceeding (except small claims cases or cases ?led a under the Probate Code, Family Code, or Welfare and institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to ?le may result in sanctions. :1 File this cover sheet in addition to any cover sheet required by local court rule. if this case is complex under rule 3.400 et seq. of the California Rules of Court. you must serve a copy of this cover sheet on all if other parties to the action or proceeding. if Unless this is a collections case under rule 3.740 or a complex case. this cover sheet will be used for statistical purposes onl . age 1 of 2 Form Ado ted for Mandala Use Cal. Rules of Court. mlas 2.30. 3.220. 3400-3403. 3.740: JudicialpCouncil ol Califorg'Iia CIVIL CASE COVER SHEET Cal. Standards ol Judicial Administration. std. 3.10 (Rev. July 1. 2007] Docil 1 Pageit 18 Doc ID 1741750476 Doc Type OTHER (Page 19 of 23) . 0 INSTRUCTIONS ON COMPLETE THE COVER SHEET Chit-010 To Plaintiffs and Others Filing First Papers. If you are ?ling a ?rst paper (for example. a complaint) in a civil case, you must complete and ?le. along with your ?rst paper. the Civil Case Cover Sheet contained on page 1. This information will be used to compile statistics about the types and numbers of cases ?led. You must complete items 1 through 6 on the sheet. in item 1, you must check one box for the case type that best describes the case. if the case ?ts both a general and a more speci?c type of case listed in item 1, check the more speci?c one. if the case has multiple causes of action. check the box that best indicates the primary cause of action. To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover sheet must be ?led only with your initial paper. Failure to ?le a cover sheet with the ?rst paper ?led in a civil case may subject a party, its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court. To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is de?ned as an action for recovery of money owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees. arising from a transaction in which property. services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort damages. (2) punitive damages. (3) recovery of real property. (4) recovery of personal property. or (5) a prejudgment writ of attachment. The identi?cation of a case as a rule 3.740 collections case on this form means that it will be exempt from the general time-for-service requirements and case management rules, unless a defendant ?les a responsive pleading. A rule 3.740 collections case will be subject to the requirements for service and obtaining a judgment in rule 3.740. To Parties in Complex Cases. in complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the case is complex. if a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the complaint on all parties to the action. A defendant may ?le and serve no later than the time of its ?rst appearance a joinder in the plaintiff?s designation, 3 counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that the case is complex. Auto Tort Auto (22)?Personal Damage/Wrongful Death Uninsured Motorist (46) (if the case involves an uninsured motorist claim subject to arbitration, check this item instead of Auto) Other (Personal injury! Property DamagelWrongfui Death) Tort Asbestos (04) Asbestos Property Damage Asbestos Personal Injuryl Wrongful Death Product Liability (not asbestos or CASE TYPES AND EXAMPLES Contract Breach of Contract/Warranty (05) Breach of RentallLease Contract (not unlawful deiainer or wrongful eviction) ContractiWarranty Breach~5eiler Plaintiff (not fraud or negligence) Negligent Breach of Contract! Warranty Other Breach of Contractharranty Collections money owed. open book accounts) (09) Collection Case?Seller Plaintiff Other Promissory NotelCoiiections se Insurance Coverage (not provisionally Provisionally Complex Civil Litigation (Cal. Rules of Court Rules 3.400?3.403) Regulation (03) Construction Defect (10) Claims Involving Mass Tort (40) Securities Litigation (28) Environmental/Toxic Tort (30) insurance Coverage Claims (arising from pro visionaliy complex case type listed above) (41) Enforcement of Judgment Enforcement of Judgment (20) Abstract of Judgment (Out of County) Confession of Judgment (non- domestic relations) toxic/environmental) (24) complex) (18) Sister State Judgment Medical Malpractice (45) AW) Subrogatron Administrative Agency Award Medical Malpractice? Other Coverage (not unpaid taxes) Physicians 8: Surgeons Other Contract (37) Petition/Certification 01f ENVY Of Other Professional Health Care Contractual Fraud JUdeem on Unpaid Taxes Malpractice Other Contract Dispute Other Enforcement of Judgment Other PIIPDIWD (23) Real Property Premises Liability slip and fall) Intentional Bodily assault. vandalism) Intentional infliction of Emotional Distress Negligent in?iction of Emotional Distress Other (Other) Tort Business TortlUnfair Business Practice (07) Civil Rights discrimination. false arrest) (not civil harassment) (08) Defamation slander. libel) (13) Fraud (16) intellectual Property (19) Professional Negligence (25) Legal Malpractice gm Other Professional Malpractice (not medical or legal) ,3 Other Tort (35) Employment - Wrongful Termination (36) NJ Other Employment (15) G3 Eminent Domainlinverse Condemnation (14) Wrongful Eviction (33) Other Real Property quiet title) (26) Writ of Possession of Real Property Mortgage Foreclosure Quiet Title Other Real Property (not eminent domain, landlord/tenant, or foreclosure) Unlawful Detainer Commercial (31) Residential (32) Drugs (38) (if the case involves illegal drugs, check this item: othenvise, report as Commercial or Residential) Judicial Review Asset Forfeiture (05) Petition Re: Arbitration Award (11) Writ of Mandate (02) Writ?Administrative Mandamus Writ?Mandamus on Limited C0urt Case Matter Writ?Other Limited Court Case Review Other Judicial Review (39) Review of Health Of?cer Order Miscellaneous Civil Complaint RICO (27) Other Complaint (not speci?ed above) (42) Declaratory Relief Only lnjunctive Relief Only (non- harassment) Mechanics Lien Other Commercial Complaint Case (non-tort/non-complex) Other Civil Complaint (non-tort/non-complex) Miscellaneous Civil Petition Partnership and Corporate Governance (21) Other Petition (not specified above) (43) Civil Harassment Workplace \?olence ElderlDependent Adult Abuse Election Contest Petition for Name Change Petition for Relief From Late Claim Other Civil Petition Notice of Appeal-Labor I: Commissioner Appeals 2 r2 CIVIL CASE COVER SHEET 39? Doc# 1 Pagett 19 Doc ID 1741750476 Doc Type OTHER (Page 20 of 23) 0 SHORT TITLE: CASE NUMBER Amy Nobiie and Trisha Ashworth vs Suzanne Todd CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION . (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) 5 This form is required pursuant to Local Rule 2.3 in all new civil case ?lings in the Los Angeles Superior Court. Step 1: After completing the Civil Case Cover Sheet (Judicial Council form Chit-010), find the exact case type in Column A that corresponds to the case type indicated in the Civil Case Cover Sheet. Step 2: In Column 6, check the box for the type of action that best describes the nature of the case. Step 3: In Column C, circle the number which explains the reason for the court ?ling location you have chosen. Applicable Reasons for Choosing Court Filing Location (Column C) i 1. Class actions must be ?led in the Stanley Mosk Courthouse. Central District. 7. Location where petitioner resides. 2. Permissive ?ling in central district. 8. Location wherein defendantlrespondent functions wholly. i 3. Location where cause of action arose. 9. Location where one or more of the parties reside. 3 4. Mandatory personal injury ?ling in North District. 10. Location of Labor Commissioner Of?ce. 11. Mandatory ?ling location (Hub Cases unlawful detainer, limited 5. Location where performance requrred or defendant resrdes. non?collection, limited collection, or personal injury). 6. Location of property or permanently garaged vehicle. A Civil Case Cover Sheet Type of Action Applicable Reasons Category No. (Check only one) See Step 3 Above Auto (22) CI A7100 Motor Vehicle - Personal Injury/Property DamagefWrongful Death Uninsured Motorist (46) El A7110 Personal Injury/Property DamagelWrongful Death Uninsured Motorist 1. 4. 11 A6070 Asbestos Property Damage 1. 11 I Asbestos (04) A7221 Asbestos - Personal Injury/Wrongful Death 1. 11 i 0 Product Liability (24) CI A7260 Product Liability (not asbestos or toxiclenvironmentalA7210 Medical Malpractice - Physicians Surgeons Medical Malpractice (45) 1 4 11 A7240 Other Professronal Health Care Malpractice . . (A7250 Premises Liability slip and fall) Other Personal 1? 4? 11 injury Property [1 A7230 intentional Bodily InjuryIProperty DamagefWrongful Death 1 4 11 3 Damage Wrongful assault. vandalism, etc.) r111 Death (23) El A7270 lntentionalln?iction of Emotional Distress 1'4'11 El A7220 Other Personal InjuryIProperty Damage/Wrongful Death 1' 4' 11 is) 5 -.J IN.) (Rev arts) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LASC Approved 03414 AND STATEMENT OF LOCATION Page 1 of4 Doctt 1 Page# 20 - Doc ID 1741750476 - Doc Type OTHER (Page 21 of 23) SHORT TITLE: CASE NUMBER Amy Mobile and Trisha Ashworth vs Suzanne Todd A Applicable Civil Case Cover Sheet Type of Action Reasons - See Step 3 Category No. (Check only one) Above Business Tort (07) A6029 Other CommerciallBusiness Tort (not fraudlbreach of contract) 1. 2. 3 1: ,2 Civil Rights (08) A6005 Civil Rights/Discrimination 1,2,3 6? Defamation (13) A6010 Defamation (slander/libel) 1, 2, 3 a 3? Fraud (16) A6013 Fraud (no contract) 1. 2, 3 a A6017 Legal Malpractice 1. 2, 3 to .3, Professional Negligence (25) 0.- A6050 Other Professional Malpractice (not medical or legal) 1, 2. 3 a 2512 Other (35) A6025 Other Non-Personal Damage tort 1, 2. 3 Wrongful Termination (36) A6037 Wrongful Termination 1. 2. 3 c: 3' A6024 Other Employment Complaint Case 1, 2, 3 B. Other Employment (15) LE A6109 Labor Commissioner Appeals 10 A6004 Breach of RentalfLease Contract (not unlawful detainer or wrongful 2 5 eviction) Breach of Contract! Warren (05) ty A6008 ContracWVan?anty Breach -Se ler Plaintiff (no fraud/negligence) 2' 5 (not insurance) A6019 Negligent Breach of Contract/Wananty (no fraud) 1' 2?5 A6028 Other Breach of Contract/Warranty (not fraud or negligence) 1' 2' 5 A6002 Collections CaseSeller Plaintiff 5, 6, 11 t, Collections (09) A6012 Other Promissory NoteICollectlons Case 5. 11 0 A6034 Collections Case?Purchased Debt (Charged Off Consumer Debt 5. 6. 11 Purchased on or after January 1, 2014) Insurance Coverage (18) A6015 Insurance Coverage (not complex) 1, 2. 5. 8 A6009 Contractual Fraud ((233, 5 I Other Contract (37) A6031 Tortiouslnterference 1, 2. 3, 5 I A6027 Other Contract Dispute(not 1. 2, 3. 8, 9 Eminent Domain/Inverse A7300 Eminent Domain/Condemnation Number ofparoels 2, 6 I Condemnation (14) A 1? Wrongful Eviction (33) A6023 Wrongful Eviction Case 2. 6 . A6018 Mortgage Foreclosure 2.6 05 Other Real Property (26) A6032 Quiet Title 2, 6 A6060 Other Real Property (not eminentdomain, landlordltenant, foreclosure) 2, 6 i . Unlawful Detagt?r-Commermal A6021 Unlawful Defamer?Commercial (not drugs or wrongful eviction?mam" Res'dent?a' A6020 Unlawful Detainer?Residential(not drugs or wrongful eviction) 6. 11 52?: . Unlawful Detainer- A6020F Unlawful Detainer?Post-Foreclosure 2. 6. 11 m, Post-Foreclosure (34) 5] Unlawful Detainer-Drugs (38) A6022 Unlawful Detainer?Dmgs 2, 6, 11 CE LAEW 109 (Rev 2116) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LASC Approved 03434 AND STATEMENT OF LOCATION Page 2 of 4 Doc# 1 Page# 21 Doc ID 1741750476 DOC Type OTHER (Page 22 of 23) SHORT TITLE: CASE NUMBER Amy Nobile and Trisha Ashworth vs Suzanne Todd A Applicable Civil Case Cover Sheet Type of Action Reasons - See Step 3 Category No. (Check only one) Above Asset Forfeiture (05) A6108 Asset Forfeiture Case 2. 3. 6 a Petition re Arbitration (11) A6115 Petition to CompellCon?rmNacate Arbitration 2. 5 (D ?5 CI A6151 Writ ?Administrative Mandamus 2.8 :3 Writ of Mandate (02) El A6152 Wn't - Mandamus on Limited Court Case Matter 2 El A6153 Writ - Other Limited Court Case Review 2 Other Judicial Review (39) El A6150 Other Writ [Judicial Review 2. 8 Antitrust/Trade Regulation (03) A6003 Antitrusth rade Regulation 1. 2. 8 Construction Defect (10) Ct A6007 Construction Defect 1. 2. 3 C?a?ms ?wag? ??855 TM :1 A6006 Claims Involving Mass Tort . 1. 2. a D. . 0 Securities Litigation (28) A6035 Securities Litigation Case 1. 2. 8 '5 To?cTon - - ?3 Environmental (30) A6036 Toxrc TortlEnvrronmental 1. 2. 3. 8 '3 0 Insurance Coverage Claims - from Complex Case (41) El A6014 Insurance CoverageiSubrogation (complex case only) 1. 2. 5. 8 CI A6141 Sister State Judgment 2. 5. 11 A6160 Abstract of Judgment 2.6 I: a Enforcement A6107 Confession of Judgment (non-domestic relations) 2. 9 'g ofJudgment (20) El A6140 Administrative Agency Award (not unpaid taxesA6114 PetitionfCerti?cate for Entry of Judgment on Unpaid Tax 2. 8 CI A6112 Other Enforcement of Judgment Case 2. B. 9 RICO (27) El A6033 Racketeering (RICO) Case A6030 Declaratory ReliefOnIy 1. 2. n. 5 Other Complaints E1 A6040 Injunctive Relief Only (not domestidharassment) 2. 8 8 Specr?ed Above) (42) A6011 Other Commercial Complaint Case (non-tonlnon-complex) 1. 2, 8 .2 A6000 Other Civil Complaint 1. 2. 8 Partnership Corporation El A6113 Partnership and Corporate Governance Case 2. 6 Governance (21) El A6121 Civil Harassment 2. 3, 9 2 El A6123 Workplace Harassment 2. 3. 9 . 2 5.: r:i A6124 EIderi?Dependent Adult Abuse Case 2. 3. 9 Other Petitions (Not 8 Speci?ed Above) (43) El A6190 Election Contest 2 92 .2 '2 A6110 Petition for Change of Name/Change of Gender 2' 7 A6170 Petition for Relief from Late Claim Law 2_ 3. '33 El A6100 Other Civil Petition 2_ 9 "xi is; E) 14'" LACIV 109 (Rev 2i16) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LASC Approved 03o: AND STATEMENT OF LOCATION Page 3 of4 Doc# 1 Pagelt 22 Doc ID 1741750476 - Doc Type OTHER (Page 23 6f 23) SHORT TITLE: CASE NUMBER Amy Nobile and Trisha Ashworth vs Suzanne Todd Step 4: Statement of Reason and Address: Check the appropriate boxes for the numbers shown under Column for the type of action that you have selected. Enter the address which is the basis for the filing location, including zip code. (No address required for class action cases). REASON: [38.8 ADDRESS: 1158 26th Street, #878 CITY: STATE: ZIP CODE: Santa Monica CA 90403 Step 5: Certification of Assignment: I certify that this case is properly ?led in the Central District of Dated: 6/5/18 PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: the Superior Court of California, County of Los Angeles [Code Civ. Proc., 9392 et seq., and Local Rule OF 1. Original Complaint or Petition. 2 If ?ling a Complaint. a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010. 4 Civil Case Cover Sheet Addendum and Statement of Location form. LACIV 109. LASC Approved 03?04 (Rev. 02/16). 5. Payment in full of the filing fee, unless there is court order for waiver, partial or scheduled payments. 6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a minor under 18 years of age wiil be required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along with the summons and complaint, or other initiating pleading in the case. *4 CT.) 109 (Rev 2116) CASE COVER SHEET ADDENDUM Local Rule 2.3 LASC Approved 03?04 AND STATEMENT OF LOCATION Page 4 of 4 Doc# 1 Page# 23 Doc ID 1741750476 Doc Type OTHER