MED COPY
cogs-1354M. 
Superior Coon of Calufomia

STRIS NIAHER LLP Countv of Los Angeles
PETER K. STRIS (SBN 216226)

2 peter.stris@strismaher.com . JUL 0 6 2018
ELIZABETH R. BRANNEN (SBN 226234) .

3 Slum B. Carter. omeerlClerk 0? 00"?
DANA BERKOWITZ (SBN 303094) By: K?suna Vargas. Dawn,

4 danaberkowitz@strismaher.com
KENNETH J. HALPERN (SBN 187663)
5 ken.halpem@strismaher.com
JOHN STOKES (SBN 310847)
6 john.stokes@strismaher.com
725 South Figueroa Street, Suite 1830
7 Los Angeles, CA 90017
T: (213) 995-6800 I F: (213) 261-0299

SHAUN P. (SBN 158480)
9 smartin@sandiego.edu

S998 Alcala Park, Warren Hall 109C
10 San Diego, CA 92110

T: (619) 260-2347 I F: (619) 260-7933

Counsel for Plainti?'Shera Bechard

53 12

g; 2 SUPERIOR COURT FOR THE STATE OF CALIFORNIA

41 13

55' FOR THE COUNTY OF LOS ANGELES

a i 14 -

5:2; 15 SHERABECHARD, CaseNo. BC71 2913

?3 Plaintiff, VERIFIED COMPLAINT FOR DAMAGES
16 AND OTHER RELIEF

 

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ELLIOTT BROIDY, an individual,
13 KEITH DAVIDSON, an individual; DEMAND FOR JURY TRIAL
MICHAEL AVENATTI, an individual;

19 DAVIDSON ASSOCIATES, PLC, a
professional limited liability company; and
20 DOES I through 20, inclusive,

21 Defendants.

 

 

 

 

 

 

 

 




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1. Plaintiff Shera Bechard (?Ms Bechard?) brings this Complaint against Defendants

Elliott Broidy (?Mn Broidy?), Keith Davidson and Davidson Associates, PLC (together, ?Mr.
Davidson?), and Michael Avenatti (?Mr Avenatti?), and alleges as follows:

2. Ms. Bechard is a model and former Playboy Playmate. She had a relationship
with Mr. Broidy, a married man. Broidy re eedly 


3. BERNIE Broid [Eh violent and engage in profound disturbing
Tear the end of their relationship, Mr. Broidy 
MEWMHW telling genital he yes? urt [?33 an" got Ms.

Bechard pregnant.

   

 

     

4. Thereafter, Ms. Bechard retained Mr. Davidson to help her understand and assert her
rights against Mr. Broidy.

5. DeSpite his ?duciary and ethical duties to his client, Mr. Davidson treated Ms.
Bechard?s claims as a commodity to be traded for his own ?nancial gain. He began by recruiting
Michael Cohen (?Mn Cohen?)?a notorious ?fixer? for wealthy individuals including President
Donald Trump?to approach Mr. Broidy with an offer to represent Mr. Broidy and ?solve? his issues
with Ms. Bechard. Unknown to Ms. Bechard, Mr. Davidson and Mr. Cohen were well acquainted
with one another, having worked together on projects including the hush money deal between porn
star Stormy Daniels (represented by Mr. Davidson) and Donald Trump (represented by Mr. Cohen).

6. Mr. Davidson wrote a crushingly one-sided agreement (the ?Settlement Agreement?)
that favored Mr. Broidy. To be sure: it required a substantial payment from Mr. Broidy (thus in?ating
Mr. Davidson?s fee). But in exchange, it required Ms. Bechard to sign away her rights and agree to
additional absurd terms, such as a $4,800,000 liquidated damages clause. No reasonable lawyer
would have recommended that Ms. Bechard sign the Settlement Agreement, and no properly
informed client in her position would have agreed. It was instead a deal that Mr. Davidson could
convince Ms. Bechard to sign only by misrepresenting and omitting its key terms. Indeed, to conceal

the Settlement Agreement?s many unconscionable aspects, Mr. Davidson included a term that

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(35prohibited Ms. Bechard from having a copy of the agreement, refused to show the agreement to

her, and af?rmatively lied to her about what the agreement said.

7. It gets worse. Although Mr. Broidy paid Ms. Bechard the ?rst two of eight installment
payments required by the Settlement Agreement, he failed to make the third installment payment, due
on July 1, 2018. The same day, the Wall Street Journal published an article on that failure. It reported
that Mr. Broidy?s current lawyer had told it (1) that Mr. Broidy would not pay any of the $1,200,000
still owed to Ms. Bechard under the Settlement Agreement, and (2) that the reason for his refusal was
that Mr. Davidson allegedly leaked the existence of the Settlement Agreement to Mr. Avenatti, who
in turn revealed it to the public on Twitter in April 2018.

8. In a statement to the Wall Street Journal, Mr. Davidson denied any wrongdoing,
adding that ?[a]ny accusation to the contrary is false and defamatory.? And in Mr. Avenatti?s statement
to the Wall Street Journal, he refused to comment on his guilt or innocence. But Mr. Broidy?s attorney
insists that he ?can prove there was an intentional breach that renders the contract null and void??
that Mr. Davidson and Mr. Avenatti breached the con?dentiality provisions of the Settlement
Agreement, thus justifying Mr. Broidy?s refusal to pay Ms. Bechard the compensation to which she
is entitled under that agreement.

9. What Ms. Bechard knows for certain is that she has done nothing wrong; in particular,
she neither knows about nor ever consented to Mr. Davidson or Mr. Avenatti revealing her
con?dential information or the terms (or even existence) of the Settlement Agreement. Thus, at least
one thing is clear: Defendants have violated Ms. Bechard?s rights. This action seeks to enforce them.

PARTIES

10. Plaintiff Shera Bechard is an individual who resides in Beverly Hills, California.

11. Defendant Elliott Broidy is an individual who resides in Beverly Hills, California.

12. Defendant Keith Davidson is an attorney who resides in Woodland Hills, California.

13. Defendant Davidson Associates, PLC is a law ?rm whose principal
place of business is located at 8383 Wilshire Boulevard, Suite 510, Beverly Hills, California 90211.
Mr. Davidson is a principal of DAPLC.

l4. Defendant Michael Avenatti is an attorney who resides in Newport Beach, California.

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15. The true names and capacities of Defendants Does 1 through 20, inclusive, are
unknown to Ms. Bechard at this time, and are therefore sued under such ?ctitious names pursuant to
California Code of Civil Procedure section 474. Each of them is in some manner legally responsible
for the events and happenings alleged herein. When these defendants are identi?ed, Ms. Bechard will
seek to amend this Complaint accordingly.

JURISDICTION AND VENUE

16. Jurisdiction is proper under section 410.10 of the California Code of Civil Procedure
and Article 4 of the California Constitution.

17. Venue is proper under section 395 of the California Code of Civil Procedure because
the Defendants, or some of them, reside in the County of Los Angeles.

FACTUAL ALLEGATIONS

 

A. Ms. Bechard, Expecting Mr. Broidy?s Child?nd Disturbed By His Mistreatment}

Meets With Mr. Davidson.
18. On October 31, 2017, Ms. Bechard met with Mr. Davidson and asked for his help
dealing with a problem. She was seven weeks pregnant with the child of Mr. Broidy (the then-Finance
Chairman of the Republican National Committee), conceived in an extramarital addrm

(behavior had become destructive, an?d she was confused and scared.

19. Mr. Davidson interviewed Ms. Bechard about the facts of her relationship with Mr.

 

 

Broidy. He also reviewed?loluminous tgegt messages, including photographs), between Ms. Bechard
and Mr. Broidy. Mr. Davidson took handwritten notes at the meeting and kept them.
20. Here is some of what Mr. Davidson learned:
a) (Ms. Bechard ?rst at a restaurant in 2013. Mr. Broidy was)

bbsessed with Playboy Playmates, and became very interested in Ms. Bechard, who was a two-time)

 

 

 

@Ybov Playmate of the Month. Before long, the two were in an intimate sexual relationship.)

 

[That relationship was both sexual and deeply personal. Mr. Broidy told Ms.)

 

(Bechard about masturbating to the thought of her. He also repeatedly told Ms. Bechard that he loved)

 

?ier, and said that he would ?nancially support her. He shared personal information about his children.)

 

@Broidv and Ms. Bechard referred to one another gas??Eddy? and??rnommy?

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(c3) (During their sexual activities, Ms. Bechard discovered that Mr]

 

(Broidy might have prostate cancer. At Ms. Bechard?s encouragement, Mr. Broidy was tested anm

 

(gums con?rmed that he was indeed suffering from prostate cancer. Concerned, Ms. Bechard)

 

(encouraged Mr. Broidy to have his prostate removed. But Mr. Broidy told her he was unwilling to do)

 

(so because it would stop him ?'om having sex, which he told her was more important to him than life)

 

d) (B_eginning in 2016, Mr. Broidy?s conduct became increasingly violent a_n_d)

 

(Elisturbing. Mr. Broidy became possessive of Ms. Bechard and iealous toward any other men in her)

 

(life. MLIBroidy would not allow Ms. Bechard to date anyone else, and commanded that no other man)

 

?vas to touch her. And while Ms. Bechard wanted to work, Mr. Broidy insisted that she be ?nancially)

 

@pendent on him. Mr. Broidy also told Ms, Bechard that giro was ?fat and needed to ?x it,? and)

 

i(encou_raged her to have liposuction)

 

(During this same time, Ms. Broidy also became increasingly derogatory)

 

(toward women. Ms. Bechard believed this character shift had to do with Mr. Broidy working for)

 

(Donald Trump, and Trump?s rise to political prominence. Although Mr. Broidy said that Mr. Trump)

 

(was 5an idiot,? who ?could not even pronounce the names of countries correctly,? Mr. Broidy admired)

 

(Mr. Trump?s uncanny ability to sexually abuse woman and get away with it. Mr. Broidy began to hurt)

 

(Ms. Bechard physically during their sexual activities??touching her in ways to which she did not)
(-

 

t) (In addition, Mr. Broidy would tell Ms. Bechard that he wanted to fs?n fuck?)

 

(her. MLIBroidy would describe his wife as a ?bitch.? And Mr. Broidy refused to use condoms even)

 

@ugh he had communicable genital herpes?a fact Ms. Bechard learned only when Mr. Broidy told)

 

((her years after their sexualrelationship began.)

g) (Ms. Bechard and Mr. Broidy typically used the and withdrawal)

 

 

(methods to avoid pregnancy. But on the? night of September 24, 2017, Mr. Broidy pushed Ms. Bechard)

 

(to drink excessively so that she would be more compliant toward his physical abuse. This had thE)

 

Effect of making Ms. Bechard less vigilant about protecting herself from the risk that Mr. Broidy)

 

(would impregnate her, which, as con?rmed, occurred that ni?)

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(After learning she was pregnant, Ms. Bechard told Mr. Broidy. Initially, he)

 

(supported her keeping the baby. But he quickly changed his tune and began demanding that she get]

 

[an abortion, insisting that ?nobody can 

 

 

(Ms. Bechard was scared of Mr. Broidy. She knew that he carried a gnu in his car, and]

 

{Mn Broidy told her that he had?connections who could make people disappear. Ms. Bechard had)

 

[grave fears that something might happen to her. But she was also upset. The pregnancy prompted her)

 

{to_think about what her life would be like with a violent misogynist as the father of her child. And]

 

(she needed to protect herself.)

B. Mr. Davidson Gets Ms. Bechard To Sign The Settlement Agreement.

23. Mr. Davidson told Ms. Bechard that he could help with her situation. He had Ms.
Bechard Sign an engagement letter (the ?Engagement Letter?) that-retained Mr. Davidson as her
attorney.

24. On or around November 8, 2017, Mr. Davidson told Ms. Bechard he had begun talking
with Mr. Broidy?s lawyer. Ms. Bechard was surprised to?hear that Mr. Davidson had so quickly
?gured out who Mr. Broidy?s lawyer was, so she asked how that had happened. Mr. Davidson
responded that he had a ?relationship? with the lawyer, a guy named Michael Cohen. Ms. Bechard
asked, ?wait, he?s your friend?? But Mr. Davidson said no. Ms. Bechard had no reason to suspect
anything was amiss. So she let the issue go and told Mr. Davidson that she looked forward to hearing
more.

25. On or around November 18, 2017, Mr. Davidson told Ms. Bechard that a deal was on
the table under which she would receive $1,600,000. Mr. Davidson told Ms. Bechard the amount
represented the net present value of child-support payments Mr. Broidy would be expected to make
over the 18-year support term of their child. In exchange for the money, Mr. Davidson told Ms.
Bechard she would give up all rights to sue Mr. Broidy for past conduct and would be required to
never again speakof the a?air. Based on what she was told by Mr. Davidson, Ms. Bechard said she
would agree to the prOposed deal.

26. On December 1, 2017, Mr. Davidson met with Ms. Bechard at a restaurant near his

o?ice so she could sign a written agreement while he ate lunch. Mr. Davidson held the 26-page

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contract in a manner such that Ms. Bechard could not actually read the document, while he purported

to go through the agreement paragraph by paragraph to explain it in lay terms. Mr. Davidson told Ms.
Bechard the following about the Settlement Agreement:
a) Ms. Bechard would receive $1,600,000 over eight quarterly installment

payments, minus Mr. Davidson?s 35 percent fee. When she questioned why installment payments

 

were necessary,t1VIr. Davidson told her Mr. Broidy had said he was broke and would have to borrow)
the funds.

b) In exchange for the money, Ms. Bechard and Mr. Broidy would never again
speak of the affair and would give up the right to sue one another for everything that had previously
happened between them.

c) If either party breached con?dentiality, the penalties would purportedly be as
follows: If Mr. Broidy breached, he would have to immediately pay the full amount due under the
Settlement Agreement. Mr. Davidson did not explain what would happen if Mr. Broidy breached
con?dentiality after all of the payments had been made. If Ms. Bechard breached, her ?rst offense
would be punished by a judge ordering her not to talk about the affair again. If she breached again,
she would be charged a fee. Mr. Davidson did not say how much it would be, but he said not to worry
about it.

d) The Settlement Agreement would be secret?only Ms. Bechard and her
accountant (no one else) could ever see it.

e) Mr. Davidson told her that she was not getting paid to have an abortion, but
rather to give up her rights to sue Mr. Broidy and to not to talk about the relationship.

27. (?at being paid to have an abortion was important to Ms. Bechard. She told}-

tDavidson that while she had considered having an abortion. she wanted to keep her baby. Indeed, she)

(had to purchase baby supplies and had seen a neonatal specialist to ensure medication)

 

 

 

 

 

[she was taking would not adversely affect the child.)

28. But when Ms. Bechard revealed her plans to. keep her baby, Mr. Davidson went)

(ballistic. He insisted that Ms. Bechard had to get an abortion because ?that is how these deals work?)
(He questioned why Ms. Bechard would want to'have'lMT'Broidy?s child when ?the man looks like a)

 

 

 

 

 

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(warned Ms. Bechard that he had spoken to Mr. Broidy directly and if she didn?t have an abortion 

 

 

Ehe would never be able to move out of California (and de?nitely not back to her home country of)
(Canada) due to Mr. Broidy?s visitation rights, and would suc"her for child-support}

(payments. ,Mr.,Davidson also told Ms. Bechard that W?Broidy had said ?Shera should be very, very)

(careful.? a thinly veiled threat to Ms. Bechard that she had better sign the Settlement Agreement and)

ave an abortion.

29. Mr. Davidson did not tell Ms. Bechard about many other material aspects of the

 

 

 

 

 

Settlement Agreement. They did not come to light until many months later. (See infra 50-53.)

30. During the lunch, Mr. Davidson pointed to places in the Settlement Agreement and
instructed Ms. Bechard to sign, which she did.

C. After Signing The Settlement Agreement, Ms. Bechard Begins To Receive

Installment Payments.

 

 

31. Eearing that the threats conveyed were genuine and extremely)
(serious; 'five days later (on December 6, 2017), Ms. Bechard terminated her 
(Davidson?s request, Ms. Bechard signed documentation releasing medical records con?rming the)

abortion to Mr. I avison

32. Mr. Davidson received the ?rst installment payment of $200,000 from Mr. Broidy on

 

or around December 5, 2017. Mr. Davidson did not disburse Ms. Bechard?s funds to her until January
2018, and only did so after Ms. Bechard repeatedly asked him to do so. Mr. Davidson took a $70,000
fee on the ?rst installment payment, and wired the remainder of $130,000 to Ms. Bechard.
33. Mr. Davidson received the second installment payment of $200,000 from Mr. Broidy
on or around April 1, 2018. Mr. Davidson took a $70,000 fee on the second installment
payment, plus $3,292.42 in costs. Mr. Davidson wired the remainder of $126,707.58 to Ms. Bechard.
When Ms. Bechard inquired about the basis for the costs, Mr. Davidson told her they were incurred
on a trip he took to New York for a face-to-face meeting before the Settlement Agreement happened.

34. The next installment payment of $200,000 from Mr. Broidy was due on July 1, 2018.

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(315Ms. Bechard Learns About The Troubling Relationship Between Mr. Davidson

And Mr. Cohen.

35. In early April 2018, Ms. Bechard began to realize that something had gone seriously
awry. The national news reported on Mr. Davidson and Mr. Cohen for their apparent collusion on two
other deals: (1) an agreement between Donald Trump and Stephanie Clifford (aka ?Stormy Daniels?),
and (2) an agreement between American Media, Inc. and Karen McDougal, which also
related to Donald Trump. The press reported strange behavior between Mr. Davidson and Mr. Cohen
that seriously concerned Ms. Bechard. -

36. On the AMI deal, for example, Mr. Davidson?s only client was Karen McDougal. Yet
according to a New York Times report, Mr. Davidson improperly and unethically back-channeled
information about that deal to Mr. Cohen. (See Jim Rutenberg et al., Tools of rump is Fixer: Payouts,
Intimidation and Tabloids, NY. Times (Feb. 18, 2018), 
[?Soon after Ms. McDougal signed the con?dential agreement
on Aug. 5, 2016, Mr. Davidson emailed Mr. Cohen, ?Michael, please give me a call at your
convenience.? Mr. Davidson followed up by explaining to Mr. Cohen over the phone that the
McDougal transaction had been completed, according to a person familiar with the 
This conduct also contributed to a Federal Election Commission complaint alleging that AMI had
made an undisclosed in?kind campaign contribution to the Trump campaign. (See 


37. As a result of these disclosures, and needing to protect herself, in April 2018 Ms.
Bechard ?red Mr. Davidson and retained new counsel.

E. Michael Avenatti Publicizes The Settlement Agreement.

38. On April 12, 2018, Mr. Avenatti began to expose the facts of the affair on Twitter. His
Twitter post identi?ed an LA-based ?prominent GOP donor? and identi?ed the existence of a ?hush
between him and an woman,? noting that he ?impregnated her and then made sure she
had an abortion? and that ?[t]he deal provided for multiple payments across many months.?

39. On April 13, 2018, after the Wall Street Journal revealed additional details about the

Settlement Agreement, identifying Ms. Bechard and Mr. Broidy by name, (see Joe Palazzolo 

9

 

 

 

COMPLAINT 13

 

 

 

1 Michael Rothfeld, Trump Lawyer Michael Cohen Negotiated $1.6 Million Settlement for Top
2 Republican Fundraiser, Wall Street J. (last updated April 13, 2018 9:36 pm. ET),
3 

4 [the ?April WSJ Mr. Avenatti publicly expressed
5 his disappointment for the lack of credit he had received for the April WSJ Article, tweeting tweeted
6 the facts on this last night. Always good to be proven correct. But attribution would have been nicethe Wall Street Journal article, Mr. Broidy had vaguely acknowledged his alfair

10 with Ms. Bechard but avoided expressly acknowledging the existence of the Settlement Agreement.

 

11 41. On July 1, 2018, the Wall Street Journal published another story about the Settlement
12 Agreement. (See Michael Rothfeld Joe Palazzolo, Top GOP Fundraiser to Stop Hush Payments
13 OverA?air, Wall Street J. (last updated July 1,2018 5:30 pm. ET), 
14 [the ?July WSJ This time,
2 15 Mr. Broidy admitted the existence of the Settlement Agreement, stating through his lawyer that I
5, Q: 16 ?Elliott speci?cally was paying for con?dentiality that would shield his family from the embarrassing 
l; 17 mistake he made.? Mr. Broidy also told the Wall Street Journal he would not make his July 1, 
18 2018 installment payment. 1
19 42. Mr. Broidy told the Wall Street Journal that he believed the Settlement Agreement had
20 been breached. To be clear: Mr. Broidy did not allege that Ms. Bechard had personally breached the
21 contract, nor even that she had intended for a breach to happen. Nor could he. Ms. Bechard had no
22 incentive or desire to reveal any con?dential information. And she has never done so. Indeed, even 
23 in the face of intense public scrutiny resulting from the April WSJ Article, Ms. Bechard refrained
24 from revealing any con?dential information.
25 43. Nonetheless, Mr. Broidy maintains that the contract was somehow breached by Ms.
26 Bechard because Mr. Davidson?the lawyer who represented Ms. Bechard in negotiating the
E: 27 Settlement Agreement?leaked con?dential information to Mr. Avenatti, who then exposed and
Elf 28 publicized it. As the Wall Street Journal explained:
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Mr. Broidy, who worked on the RNC with Mr. Cohen, will withhold the third
installment of $200,000 that was due Sunday, in response to an alleged breach of the
nondisclosure agreement, according to Chris Clark, a lawyer for Mr. Broidy.

Mr. Clark said Ms. Bechard?s lawyer at the time of the agreement, Keith Davidson,
improperly discussed the hush-money agreement with another lawyer, Michael
Avenatti, who has replaced Mr. Davidson in representing Stephanie Clifford, a former
adult-f1 lm star. Ms. Cli?brd, known professionally as Stormy Daniels, got a $130,000
payment arranged by Mr. Cohen to keep quiet about what she said was a 2006 sexual
encounter with Mr. Trump.

?Elliott speci?cally was paying for con?dentiality that would shield his family from

the embarrassing mistake he made,? Mr. Clark said. ?We can prove there was an
intentional breach that renders the contract null and void.?

Mr. Clark, Mr. Broidy?s lawyer, said Mr. Broidy and his representatives . . . Spoke to
people who said they had knowledge that Mr. Avenatti learned of the hush-money deal
from Mr. Davidson, prompting the tweet.

(July WSJ Article.)

44. The July WSJ Article also reported statements that Mr. Davidson and Mr. Avenatti
made in response to the allegations of Mr. Broidy.

45. According to the Wall Street Journal, Mr. Davidson had denied any wrongdoing: 
spokesman for Mr. Davidson said the lawyer hasn?t breached any agreement. ?Any accusation to the
contrary is false and defamatory,? said the spokesman, Dave Wedge, adding that Mr. Davidson ?looks
forward to addressing these matters in the preper venue, which is the court room, not the press.? (Id)

46. According to the Wall Street Journal, Mr. Avenatti declined to comment on his
complicity: ?Mr. Avenatti said: ?I?m neither going to con?rm nor deny what information I have about
this, whether it?s all been disclosed yet, or where I learned it. But Iwould encourage Ms. Bechard to
disclose everything she knows about this situation to the public.? (Id)

E. Additional Serious Misconduct Is Revealed.

47. Additional troubling facts about the Settlement Agreement and the circumstances
surrounding it came to light after Ms. Bechard ?red Mr. Davidson and retained the undersigned as
counsel.

48. First, the April WSJ Article revealed that Mr. Davidson had actually recruited Mr.

Cohen. According to Mr. Broidy?s statement in the April WSJ Article: ?Mr. Cohen reached out to me

11

 

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after being contacted by this woman?s attorney, Keith Davidson. Although I had not previously hired
Mr. Cohen, I retained Mr. Cohen after he informed me about his prior relationship with Mr.
Davidson.? The July WSJ Article further described the circumstances of these events, reporting that
when Mr. Cohen ?rst approached Mr. Broidy, he had told him ?It?s your lucky day, because you have
a big problem, and I can help you solve it.?

49. Second, on April 12, 2018, and again, through counsel, on April 13, 2018, Ms.
Bechard requested from Mr. Davidson her complete client ?le and a copy of the Settlement
Agreement. Mr. Davidson refused to even respond to this request until April 24, 2018, at which time
he asserted a $420,000 lien for unpaid attomey?s fees. Mr. Davidson unethically and imperrnissibly
refused to turn over Ms. Bechard?s client ?le and the Settlement Agreement to her upon her
request.

50. Third, a review of the Settlement Agreement reveals (I) unconscionable terms to
which no reasonable lawyer or informed client would agree, as well as (2) terms that Mr. Davidson
either deliberately refused to disclose to Ms. Bechard or about which he af?rmatively lied. For
example, in addition to the terms discussed supra at 11'? 26-27, the Settlement Agreement provides no
effective remedy to Ms. Bechard if Mr. Broidy violates its con?dentiality or payment provisions (not
even acceleration, as Mr. Davidson had claimed to Ms. Bechard). In fact, Mr. Broidy has already
made multiple statements to the press that concern Ms. Bechard and the Settlement Agreement,
including about Mr. Davidson?s and Mr. Avenatti?s alleged actions that breached it. In stark contrast,
Ms. Bechard faces the threat of a preposterously high liquidated damages penalty and resulting
?nancial ruin if she has the audacity to mention the Settlement Agreement or reSpond to Mr. Broidy?s
factual misstatements.

51. Indeed, among the more overtly unconscionable terms of the Settlement Agreement is
the $4,800,000 penalty it purports to impose on Ms. Bechard for a breach. (Agreement at 5.1.2.)
Shockingly, this provision arose when Mr. Davidson sent a redlined draft to Mr. Cohen that increased
the liquidated damages provision by many multiples, from $500,000 to $4,800,000. Mr. Davidson

never discussed this change with Ms. Bechard nor explained the signi?cance of that provision?on

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concerned.

52. The Agreement was also peppered with deliberate falsehoods that were useful only to
Mr. Broidy, such as Bechard] has been asked by counsel for [Mr. Broidy] but has refused to
show proof of pregnancy.? (Agreement at 2.3.) That was ?atly untrue. Days after retaining Mr.
Davidson, Ms. Bechard had given Mr. Davidson a copy of sonogram images of her baby. And she
had told Mr. Davidson she would gladly conduct paternity tests. Mr. Davidson had told her, however,
that Mr. Broidy would not submit to one. When the Wall Street Journal covered the story, they
reported those false details in ways that embarrassed Ms. Bechard, Writing for example that ?Ms.
Bechard declined to provide proof that she was pregnant with Mr. Broidy?s child, the contract says.?

(See April WSJ Article.)

 

53. [The Settlement Agreement also contains additional deliberately false statements)

 

[designed exclusively to bene?t Mr. Broidy. One of the statements signed by Ms. Bechard, fc?j
(example, claims that she never had an affair with or was impregnated Broidy.) (Agreement at

 

 

24.) Mr. Davidson never told Ms. Bechard that these provisions existed, or that this was in what she
was signing; rather, when she ?nally discovered that Mr. Davidson had tricked her into signing these
false statements, Ms. Bechard was shocked and appalled at these deliberate and knowing falsities.

54. Fourth, to add insult to injury, Ms. Bechard learned from the client ?le that Mr.
Davidson had even lied to her about the $3,292.42 in costs for his trip to New York. These costs were
not incurred on her case because they were ?om a trip that occurred in January of 20 1 7?nine months
before Ms. Bechard even met Mr. Davidson.

55. Finally, on May 8, 2018, Mr. Avenatti released a report that revealed three wire
payments of $62,500 had been made from Mr. Broidy to Mr. Cohen. (Avenatti Associates, APC,
Project Sunlight: Executive Summary (May 8, 2018), 
The payments were made on January 2,
2018, January 31, 2018, and March 1, 2018, and appear to be fees paid to Mr. Cohen for his

role in the Settlement Agreement. (Id)

13

 

 

 

COMPLAINT 17

 

 

725 S. FIGUEROA ST. STE 1830

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FIRST CAUSE OF ACTION

(For Breach of Contract)
(Against Broidy)

56. Ms. Bechard re-alleges each paragraph of this Complaint as if fully set forth herein.

57. Under the Settlement Agreement, Mr. Broidy is required to pay Ms. Bechard
$1,600,000 in eight $200,000 quarterly payments. (Agreement at 3.1, 3.1.2.)

58. The third quarterly payment of $200,000 was due on July 1, 2018.

59. Mr. Broidy breached the Settlement Agreement by failing to make the required
contractual payment on July 1, 2018.

60. Ms. Bechard did not breach the Settlement Agreement and knows of no valid excuse
for Mr. Broidy?s breach.

61. Further, Mr. Broidy?s assertion of a breach by Ms. Bechard was made in ?bad faith?
within the meaning of the Settlement Agreement, entitling Ms. Bechard to acceleration of at least two
installment payments. (See Agreement at Evidence of bad faith here includes, but is not
limited to, the following evidence: 

a. Ms. Bechard did not personally reveal any con?dential information (de?ned
by the Settlement Agreement to include, among other things, the agreement itself and the affair).

b. Any alleged disclosure of con?dential information was purportedly done by
Mr. Davidson, who was not acting with Ms. Bechard?s consent or knowledge.

0. Mr. Broidy?s allegation of breach was made to the Wall Street Journal, which
is the wrong forum to allege breach by Ms. Bechard under the Settlement Agreement; indeed, that
allegation itself is a breach of Mr. Broidy?s duties of con?dentiality and non-disclosure under the
Settlement Agreement. 

62. Ms. Bechard has suffered damages as a result of Mr. Broidy?s breach of the Settlement
Agreement and requests monetary payment of $200,000, the immediate acceleration of at least two
required installment payments due to Ms. Bechard, and, in the alternative, payment of all remaining
amounts due under the Settlement Agreement. Ms. Bechard also requests pre- and post-judgment

interest at the statutory rate as well as her attorneys? fees and costs in this action.

14

 

 

 

COMPLAINT 13

 

725 S. FIGUEROA ST. STE 1830

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ALISECOND CAUSE OF ACTION

(For Tortious Interference With Contract And
Interference With Prospective Economic Advantage)
(Against Davidson, DAPLC, and Avenatti)

63. Ms. Bechard re?alleges each paragraph of this Complaint as if fully set forth herein.

64. The Settlement Agreement was a valid contract between Ms. Bechard and Mr. Broidy.
The Engagement Letter between Mr. Davidson and Ms. Bechard was also a valid contract. The
Settlement Agreement required con?dentiality. The Engagement Letter and Mr. Davidson?s
associated ethical duties similarly required Mr. Davidson not to reveal con?dential information about
Ms. Bechard and her case, including but not limited to the existence and terms of the Settlement
Agreement. The relationships between Mr. Broidy and Ms. Bechard, as well as between Mr. Davidson
and Ms. Bechard, also promised Ms. Bechard economic advantage.

65. Mr. Broidy has alleged that ?Mr. Avenatti learned of the hush-money deal from Mr.
Davidson.? (See July WSJ Article.) Mr. Broidy thereby alleges that Mr. Davidson breached the
Settlement Agreement by revealing its existence and terms to Mr. Avenatti, which would in turn be a
breach of the Engagement Letter as well as Mr. Davidson?s ethical duties thereunder.

66. Mr. Davidson knew of the Settlement Agreement by virtue of his role as Ms. Bechard?s
attorney. At no time did Ms. Bechard give consent to, or have any knowledge of, the alleged
disclosure of the Settlement Agreement, its existence, its terms, or anything else to Mr. Avenatti. The
reported disclosure by Mr. Davidson to Mr. Avenatti constitutes an intentional act designed to induce
breach or disruption of the Settlement Agreement and the economic relationship between Ms.
Bechard and Mr. Broidy, and was accomplished by unlawful and unethical means?in particular, the
violation of Mr. Davidson?s ethical duties to his client.

67. Mr. Avenatti knew of the Settlement Agreement by virtue of Mr. Davidson purportedly
telling him about it. Additionally, as an attorney and given the nature of what he himself called the
?hush agreement, Mr. Avenatti knew that Mr. Davidson was contractually and ethically bound
not to disclose to Mr. Avenatti information known by Mr. Davidson about Ms. Bechard?s case,

including but not limited to the existence and contents of the Settlement Agreement. If Mr. Avenatti

15

 

 

 

COMPLAINT 1 9

 

 




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[mail
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725 S. FIGUEROA ST. STE l830

LOS ANGELES. CA 90017

STRIS
MAHER

 

 

indeed agreed to receive and received information about the Settlement Agreement ?om Mr.

Davidson, as alleged by Mr. Broidy, MI. Avenatti engaged in an intentional act designed to induce
breach or disruption of the Settlement Agreement and the Engagement Letter, as well as the economic
relationship between Ms. Bechard, Mr. Broidy, and Mr. Davidson. Mr. Avenatti?s decision to receive
con?dential information about Ms. Bechard from her attorney, including the existence and terms of
the Settlement Agreement was, if Mr. Broidy?s allegations are correct, accomplished through
unlawful and unethical means including complicity in Mr. Davidson?s violation of ethical duties owed
to Ms. Bechard.

68. As a result of the foregoing, Ms. Bechard has suffered damages in the form of Mr.
Broidy?s refusal to pay the amounts due under the Settlement Agreement, as well as in the form of
expenses incurred in the Settlement Agreement?s enforcement. Accordingly, Mr. Davidson and Mr.
Avenatti are liable in an amount to be proved at trial, and for pre- and post-judgment interest.

THIRD CAUSE OF ACTION
(For Conspiracy To Commit Breach Of Fiduciary Duty)
(Against Davidson, DAPLC, and Avenatti)

69. Ms. Bechard re-alleges each paragraph of this Complaint as if fully set forth herein.

70. The attorney?client relationship is a ?duciary relationship of the highest character.
(Cox v. Delmas (1893) 99 Cal. 104.) Every lawyer must refrain ?om using undue in?uence and must
undertake the relationship with the utmost good faith. (Trafton v. Youngblood (1968) 69 Cal. 2d 1;
Clark v. State Bar (1952) 39 Cal. 2d 161.) Every lawyer must render legal advice with the skill,
prudence, and diligence of a lawyer of ordinary skill and capacity. (Kirsch v. Duryea (1978) 21 Cal.
3d 303, 308; California Rules of Prof. Conduct 3-110.) And every lawyer owes an undivided duty of
loyalty and ?delity to his client. (Alkow v. State Bar (1971) 3 Cal. 3d 924.)

71. The elements of civil conspiracy are the formation and operation of the
conspiracy, (2) wrongful conduct in furtherance of the conspiracy, and (3) damages arising from the

wrongful conduct.? (AREI II Cases (2013) 216 Cal. App. 4th 1004, 1022.)

16

 

 

 

COMPLAINT 2?

 

 

 

 


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.FIOUEROA ST. STE 1830

LOS ANGELES. CA 90017

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MAHER

 

 

45143572. Mr. Davidson purportedly breached multiple ?duciary and ethical duties by revealing
the Settlement Agreement and client con?dences to Mr. Avenatti and did so for the purpose of 
breaching those duties.

73. Mr. Avenatti purportedly knew what Mr. Davidson knew, and knew that the Settlement
Agreement was secret. Indeed, his tweet about it described the agreement as a ?hush Mr.
Avenatti, moreover, desired to assist the exposure and public promotion of the Settlement Agreement
because he claimed entitlement to and hoped to receive attribution as the ?rst source of public
information about it.

74. As a result of the foregoing, Ms. Bechard has suffered damages in the form of Mr.
Broidy?s refusal to pay the amounts due under the Settlement Agreement, as well as in the form of
expenses incurred in the Settlement Agreement?s enforcement. Accordingly, Mr. Davidson and Mr.
Avenatti are liable in an amount to be proved at trial, and for pre- and post-judgment interest.

FOURTH CAUSE OF ACTION
(For Declaratory Relief Regarding Further Attorney?s Fees)
(Against Davidson and 

75. Ms. Bechard re-alleges each paragraph of this Complaint as if fully set forth herein.

76. The Engagement Letter provides that in the event of discharge, Mr. Davidson will be
entitled to ?a reasonable fee? for the legal services he provided, determined using a multi-factor test.
As the Engagement Letter explains: 

In the event of Attomey?s discharge or withdrawal as provided in Paragraph 11, Client

agrees that, upon payment of the settlement, arbitration award or judgment in Client?s

favor in this matter, Attorney shall be entitled to be paid by Client a reasonable fee for

the legal services provided. Such fee shall be determined by considering the following

factors:

The actual number of hours expended by Attorney in performing legal
services for Client;

Attomey?s hourly rates;

17

 

 

 

COMPLAINT 21

 

 

(2th

725 S. FIGUEROA ST. STE 1830

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The extent to which Attorney?s services have contributed to the result
obtained;

The amount of the fee in proportion to the value of the services
performed;

The amount of recovery obtained;

(1) Time limitations imposed on Attorney by Client or by the
circumstances; and 

The experience, reputation and ability of personnel performing the
services.

77. Mr. Davidson has been discharged by Ms. Bechard.

78. To date, Mr. Davidson has charged Ms. Bechard fees of $140,000.

79. Applying the factors listed in the Engagement Letter to the facts of this case, the
reasonable value of Mr. Davidson?s services?particularly in light of his serious ethical violations,
see in?a zero, or, in the alternative, less than the $140,000 in fees already paid by
Ms. Bechard to Mr. Davidson.

80. There is an actual and continuing controversy about this issue between Ms. Bechard
and Mr. Davidson. Mr. Davidson asserts that he has done nothing wrong, and remains entitled to a 35
percent contingency fee on all ?iture payments received by Ms. Bechard from Mr. Broidy.

81. Accordingly, Ms. Bechard seeks a declaratory judgment that Mr. Davidson is entitled
to no further attorney?s fees, or, in the alternative, to an amount less than the amount he has claimed.
FIFTH CAUSE OF ACTION
(For The Return Of Excessive Attorney?s Fees and Costs Paid)

(Against Davidson and DAPLC)

82. Ms. Bechard re-alleges each paragraph of this Complaint as if fully set forth herein.

83. Pursuant to Rule 4-200 of the Rules of Professional Conduct, member shall not
enter into an agreement for, charge, or collect an illegal or unconscionable fee,? and the

unconscionability of a fee shall be determined on the basis of all the facts and

circumstances existing at the time the agreement is entered into except where the

18

 

 

 

COMPLAINT 22

 

 

 

{3:1

725 S. FIGUEROA ST. STE 1830

LOS ANGELES. CA 90017

STRIS
MAHER

 

LII parties contemplate that the fee will be affected by later events. Among the factors to

be considered, where appropriate, in determining the conscionability of a fee are the

following:

(1) The amount of the fee in proportion to the value of the services
performed.

(2) The relative sophistication of the member and the client.

(3) The novelty and difficulty of the questions involved and the skill
requisite to perform the legal service properly.

(4) The likelihood, if apparent'to the client, that the acceptance of the
particular employment will preclude other employment by the member.

(5) The amount involved and the results obtained.

(6) The time limitations imposed by the client or by the circumstances.

(7) The nature and length of the professional relationship with the client.

(8) The experience, reputation, and ability of the member or members
performing the services.

(9) Whether the fee is ?xed or contingent.

(10) The time and labor required.

(11) The informed consent of the client to the fee.

84. Applying these factors to the facts of this dispute, the fee that Mr. Davidson has
received to date is unconscionable. Particularly in? light of Mr. Davidson?s serious ethical violations,
see infra he should be entitled to no fee whatsoever, and the Court should order
disgorgement of the $140,000 currently in his possession, as well as of the money paid by Ms.
Bechard to Mr. Davidson for his alleged costs, or, in the alternative, the Court should order the return
of such lesser amount as this Court deems just and proper.

SIXTH CAUSE OF ACTION
(For Breaches Of Fiduciary Duty)
(Against Davidson and DAPLC)

85. Ms. Bechard re-alleges each paragraph of this Complaint as if fully set forth herein.

l9

 

 

 

COMPLAINT 23

 

 

 

 

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725 S. FIGUEROA ST. STE. 1830

LOS ANGELES. CA 90017

STRIS
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86. Mr. Davidson breached his ?duciary duties to Ms. Bechard in at least the following
ways:

a. Mr. Davidson contacted and hired Mr. Cohen without disclosing to Ms.
Bechard the nature of his relationship with Mr. Cohen and the con?icts arising thereunder.

b. Mr. Davidson drafted and coerced Ms. Bechard into signing a contract that
included provisions rendering it unconscionably 10psided in favor of Mr. Broidy for the purpose of
increasing his fee at Ms. Bechard?s expense.

0. Mr. Davidson made false statements and omissions to Ms. Bechard about the
terms of the Settlement Agreement, and induced her to sign a contract containing provisions to which
she would not reasonably agree had she known of and understood them.

d. Mr. Davidson failed to deliver to Ms. Bechard her client file and the
Settlement Agreement when she asked for them, during a period when she needed to fully understand
the Settlement Agreement?s provisions. 

e. Mr. Davidson purportedly disclosed con?dential information, as it is de?ned
in the Settlement Agreement, and information about his representation of Ms. Bechard, to Mr.
Avenatti without Ms. Bechard?s knowledge or consent.

f. Mr. Davidson unreasonably delayed in delivering client ?inds to Ms. Bechard;
in particular, the money that Mr. Broidy paid under the Settlement Agreement.

g. Mr. Davidson charged costs toMs. Bechard claiming they were associated
with her case when in fact no such costs were incurred.

87. As a result of the foregoing, Ms. Bechard was materially harmed, and Mr. Davidson
should be denied his fee and should be required to make Ms. Bechard whole for his misconduct.

88. Additionally, because Mr. Davidson?s conduct was willful, malicious, oppressive, and
done with a conscious disregard for Ms. Bechard?s rights and interests, punitive damages should be

awarded to punish and deter future misconduct.

20

 

 

 

COMPLAINT 24

 

 

725 S. FIGUEROA ST. STE 1830

LOS ANGELES. CA 9011!?

STRIS
MAHER

 

SEVENTH CAUSE OF ACTION
(For Legal Malpractice)
(Against Davidson and DAPLC)

89. Ms. Bechard re-alleges each paragraph of this Complaint as if fully set forth herein.

90. ?In a legal malpractice action arising from a civil proceeding, the elements are the
duty of the attorney to use such skill, prudence, and diligence as members of his or her profession
commonly possess and exercise; (2) a breach of that duty; (3) a proximate causal connection between
the breach and the resulting injury; and (4) actual loss or damage resulting from the attorney?s
negligence.? (Cassia v. McKenna Cuneo (2001) 25 Cal. 4th 1194, 1199.)

91. Mr. Davidson breached the duty of care owed to Ms. Bechard by failing to accurately
inform her of the terms of the Settlement Agreement, by drafting and coercing her to sign a Settlement
Agreement with unconscionable terms, by failing to perform legal services with the care and
competence of a reasonable attorney, by failing to require adequate security to Ms. Bechard under the
Settlement Agreement, by failing to deliver money and client ?les to which Ms. Bechard
was entitled, by failing to accurately and fully disclose the relationship between Mr. Davidson and
Mr. Cohen and the con?icts therefrom, by recommending and inserting terms to which no properly
informed client in Ms. Bechard?s position would agree and which no reasonable counsel for her would
recommend, and by the repeated improper and unethical conduct referred to in this action.

92. Ms. Bechard was damaged by this malpractice by Mr. Davidson in an amount to be
established by proof at trial.

A EIGHTH CAUSE OF ACTION
(For Equitable Indemnity)
(Against Davidson and DAPLC)

93. Ms. Bechard re-alleges each paragraph of this Complaint as if fully set forth herein.

94. contract under which the indemnitor undertook to do work or perform services
necessarily implie[s] an obligation to do the work involved in a proper manner and to discharge
foreseeable damages resulting from improper performance . . . (Prince v. Pac. Gas Elec. Co.

(2009) 45 Cal. 4th 1151, 1159.)

21

 

 

 

COMPLAINT 25

 

 

 

 

1 95. Ms. Bechard retained Mr. Davidson to represent her in connection with her claims

2 against Mr. Broidy. Mr. Davidson failed to competently and ethically act in accordance with terms of

DJ

his engagement as Ms. Bechard?s attorney and breached his ?duciary duties therein, including by

4 allegedly revealing con?dential information about the representation to Mr. Avenatti that Mr. Broidy



claims violated the Settlement Agreement.
96. To the extent Mr. Broidy contends that he has been damaged or is entitled to any other

relief as a result of a breach of the Settlement Agreement, said allegation and purported breached

OOQON

having ?owed from Mr. Davidson?s alleged conduct, Ms. Bechard is entitled to indemnity from Mr.

\0

Davidson to cover the foreseeable resulting damages.

10 97. To be clear: Ms. Bechard does not have personal knowledge that Mr. Davidson
11 disclosed her con?dential information (including the existence and contents of the Settlement
12 Agreement) to Mr. Avenatti, but does know that (1) someone with intimate knowledge of these
13 facts?and not her?disclosed these details, (2) Mr. Broidy insists that that Mr. Davidson was the
14 one who disclosed these facts to Mr. Avenatti, and (3) Mr. Avenatti did indeed receive these facts

15 (since he tweeted about them). Given these predicate facts, Ms. Bechard alleges, in the alternative

725 S. FIGUBROA ST. STE 1330

LOS ANGELES. CA 90017

 

16 and on information and belief, the facts herein; in particular, that Mr. Davidson disclosed and Mr.

17 Avenatti knowingly received from Mr. Davidson con?dential information about her representation in

STRIS
MAHER

18 violation of Mr. Davidson?s ?duciary and ethical duties to Ms. Bechard. Those breaches of duty were
19 complete upon the disclosure of Ms. Bechard?s private legal information by Mr. Davidson to Mr.
20 Avenatti; no further disclosure to the public) was necessary.

21 98. Whatever tranSpired was not the fault of Ms. Bechard. She did nothing wrong. She
22 should not be deprived of her rights because the three men described above (Mr. Broidy, Mr.
23 Davidson, and Mr. Avenatti) decided that they could use her to their advantage.

24 PRAYER FOR RELIEF

25 WPIEREFORE, Plaintiff prays for an award against Defendants as follows:

26 1. For compensatory damages from all Defendants;

27 2. For pre-judgment interest against all Defendants;

28 3. For disgorgement from Mr. Davidson and 

<33: 22

 

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33. COMPLAINT 25

 

 

 

 

 

 

 

 

if?!

3 

?13

725 S. FIGUEROA ST. STE 1830

LOS ANGELES. CA 90017

STRIS
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EDOOQQ

For declaratory relief with respect to Mr. Broidy, Mr. Davidson, and 

5. For punitive damages from Mr. Davidson and and

6. For such other and further relief as the Court deems just and proper.
DEMAND FOR JURY TRIAL

Plainti? demands a jury trial for all claims so triable.

STRIS MAHER LLP

Petet K. Stris

725 South Figueroa Street, Suite 1830
Los Angeles, CA 90017"

T: (213) 995-6800 IF: (213)261-0299

Dated: July 5,2018

Co unsel for Plainti?Shera Bechard

23

 

 

 

COMPLAINT

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Woo-FIGUEROA ST. STE 1830

LOS ANGELES. CA 90017

 

16
17

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?45" 27
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VERIFICATION

STATE OF CALIFORNIA, COUNTY OF LOS AN GELES
I, Shera Bechard, declare:
I am the plaintiff in this action. I have read the foregoing complaint and know its contents.
The matters stated in the foregoing complaint are true of my own knowledge, or are stated on
my information and belief and I believe them to be true.
Executed on July 2018, in Los Angeles County, California.

I declare under penalty of perjury under the laws of the State of California that the foregoing



Shera Bechard

is true and correct.

28