13 Bryan J. Freedman, Esq. (SBN 151990) David Marmorstein. Esq. (SBN l92993) FREEDMAN TAITELMAN. LLP 1901 Avenue of the Stars, Suite 500 Los Angeles. CA 90067 Telephone: (310) 201-0005 Facsimile: (3 l0) 201-0045 E-mail: BFreedman ?llp.com Attorneys for Plaintiff Jordan Belfort SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - CENTRAL DISTRICT JORDAN BELFORT, an individual. Plaintiff, VS. RED GRANITE PICTURES, INC. fonnerly RED GRANITE PRODUCTIONS. INC. 8 California co oration; RIZA SHAHRIZ BIN ABDUL a/lda RIZA AZIZ. an individual; and DOES 1-10, inclusive, Defendants. Case No.: Unlimited Civil Case Amount in excess of $25,000 COMPLAINT FOR: (1) FRAUD (INTENTIONAL MISREFRESENTATION) (2) NEGLIGENT (3) VIOLATION OF RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT (4) BREACH OF WRITTEN CONTRACT (5) BREACH OF COVENANT OF GOOD FAITH AND FAIR DEALING (6) DECLARATORY RELIEF Complaint omumuaww Plaintiff Jordan Belfort (Belfort? or ?Plaintifl"), hereby alleges as follows against Defendants Red Granite Pictures. lnc.. formerly Red Granite Productions. Inc. (?Red Granite?) and Riza Shahriz Bin Abdul Aziz. also known as Riza Aziz (?Aziz?) (collectively, ?Defendants"): This lawsuit arises from Defendants? fraudulent, intentional and strategic concealment of Aziz?s background, the stepson of disgraced former Malaysian Prime Minister Najib Razak. the proven embezzler of billions in Malaysian state funds, and concealment of the true source of Red Granite?s funding. in their successful effort to convince Belfort to sign away the rights to his highly lucrative life story for exploitation by Defendants. In March 20] l, Aziz represented himself, and his ?lm company Red Granite, to Belfort as a legitimate and legally funded ?lm production company. Speci?cally. it was represented to Belfort that Red Granite was ?nanced by high net worth individuals and entities, including but not limited to Goldman Sachs, as well as other legal and legitimate entities. ln reliance on the misrepresentations. Red Granite acquired certain book/story rights from Belfort, which included the right and obligation to exploit and maximize those rights to the fullest extent for the bene?t of Belfon and others. In 2013. Red Granite released the feature ?lm ?The Wolf of Wall Street". based on the book/story rights acquired from Belfort, to overwhelming critical and box of?ce success, earning over $300 million. The ?lm became the highest earning ?lm in the historic ?lmography of its iconic ?lm Director, Martin Scorsese. Yet, despite such success. Defendants have since refused to further exploit this goldmine of an asset to the bene?t of Belfort, despite its contractual obligations. Unbeknownst to Belfort. discovered after the ?lm's release, Defendants were not legitimately or legally funded when they acquired Belfort?s rights. In fact. in a now world-wide. well documented and highly publicized international criminal scandal surrounding the lMalaysia Development Berhad Red Granite and Aziz speci?cally, have been identi?ed by the United States Justice Department and the Malaysian authorities as central ?gures in this global. criminal scandal. The matter is now one of the most publicized and disturbing stories of international. criminal misconduct over the past several decades, at least. Aziz faces charges that he laundered $248 million into Red Granite and Red Granite Capital Ltd. (Singapore) bank accounts between 20l and 2012. Belfort was completely 2 Complaint u?o?nu-?u?oa?n?n Mwa?O blindsided to learn. a?er the fact. of the source of funding for Red Granite and the film based on his book/story, as Defendants concealed these criminal acts and funding sources from him. He had no indication that Red Granite was funded by illegal proceeds, and planned to use those illicit funds to exploit the rights acquired from him. Had he known, he certainly would have never sold the rights. Now that the truth has surfaced, and as Red Granite and Aziz are facing heavy scrutiny and formal charges from law enforcement. Belfort is significantly damaged by Red Granite?s tainting of his book/story rights, coupled with Red Granite?s inability and/or refusal to exploit and maximize the rights acquired from Belfort as required by contract, due to the highly publicized scandal and amid the allegations of their direct involvement. Now motivated only by self-preservation. Defendants must distance themselves from Belfort?s ?The Wolf of Wall Street" story, and other rights purchased, for fear that propagating the books/stories will only fan the ?ames of the criminal charges facing them. However. Defendants self-preservation operates as a clear breach of their obligations to Belfort. for which they are now liable. in excess of $300 million in damages. A ON 1. Belfort is an individual who at all relevant times resided in Los Angeles County. in the State of California. 2. Red Granite is a corporation organized and operating under the laws of the State of California, quali?ed to do business in the State of California, with its principal place of business located in the State of California. County of Los Angeles. 3. 0n information and belief, Aziz is an individual who at all relevant times resided in Los Angeles County. in the State of California. 4. Plaintiff is ignorant of the true names and capacities of defendants sued herein as Does 1 through l0, inclusive, and thereon sues these defendants by such fictitious names. Plaintiff alleges on information and belief that such DOE defendants are liable to Plaintiff for the actions hereina?er set forth Plaintiff will amend this complaint to allege the true names and capacities of such DOE defendants when ascertained. 5. Plaintiff alleges on information and belief that, at all times relevant hereto. each defendant. including Doe defendants. was the agent. servant, employee and/or representative of each of 3 Complaint l4 the other defendants and, in doing the things herein alleged. was acting within the course and scope of. and pursuant to, said agency, services, employment and/or representation. 6. Plaintiff alleges on information and belief that there exists. and at all times herein mentioned existed. a unity of interest and ownership between Aziz, on the one hand, and Red Granite, on the other hand, such that any individuality and separateness between Aziz and Red Granite has ceased, and Aziz is the alter ego of Red Granite. 7. Jurisdiction and venue for this action in the County of Los Angeles are proper pursuant to, without limitation, California Code of Civil Procedure 395 and 395.5. 8. Prior to March 29, 201 l, Aziz individually and on behalf of Red Granite, held themselvesi out to Belfort as a legitimate and legally funded ?lm producer/production company, able to exploit Belfort?s book/story rights to the fullest extent possible, so that Belfort could maximize the earning potential of such assets. In particular, Aziz represented that Red Granite was ?nanced by high net worth individuals and entities. including but not limited to Goldman Sachs. as well as other legal and legitimate entities. 9. On March 29. 201 l. in reliance on the representations of Defendants. Belfort sold certain book/story rights to Red Granite, which included the right to exploit and maximize those rights to the fullest extent for the bene?t of Belfort, among others (hereinafter. the ?Agreement?). A true and correct copy of the Agreement is attached hereto as Exhibit 1. 10. in or about 2013, Red Granite released the feature ?lm, ?The Wolf of Wall Street" to critical and box of?ce success and acclaim. On information and belief, since that time. Defendants have failed and refused to exploit and maximize the rights acquired from Belfort pursuant to the Agreement. A?er the ?lm?s release. Belfort Ieamed. for the ?rst time, that Red Granite and Aziz were connected to and in fact central ?gures in one of the largest and highly publicized global, criminal scandals in history. 11. On information and belief. Aziz. Red Granite?s principal, is the stepson of the now disgraced former Malaysian Prime Minister Najib Razak. On information and belief, Aziz has been charged with ?ve counts of money laundering from Good Star Ltd.. a company linked to Aziz's stepfather, Prime Minister Rank, who was behind the theft of billions from the IMDB fund. 4 Complaint wqom# 12. On information and belief. Aziz is being investigated by the Malaysian Anti-Corruption Commission. and is currently out on bail, facing up to 25 years in prison if found guilty of the charges. 13. On information and belief. the actions of Aziz and Red Granite in connection with production of ?The Wolf of Wall Street" ?lm led the United States Department of Justice to ?le the largest forfeiture complaint in US. history, citing $1 billion of assets which included Aziz?s mansion in Beverly Hills and Park Laurel condominium in New York, as well as all future pro?ts from ?The Wolf of Wall Street" ?lm. On information and belief, among the charges against Aziz. he apparently laundered $248 million into Red Granite and Red Granite Capital Ltd. (Singapore) bank accounts between 2010 and 2012. 14. On information and belief. during the years 2010 and 2012. Red Granite?s former co- founder.me McFarland. accepted valuable gifts. artwork and a cache of luxury watches from funds tied to the IMDB fund. On information and belief. at the same time, Red Granite used these tainted, illegal and illicit funds to purchase the rights from Belfort under the Agreement. and to ?nance ?The Wolf of Wall Street" ?lm. pursuant to the rights it acquired under the Agreement. 15. On information and belief. Red Granite last year was forced to pay out $60 million when it was shown it ?nanced Belfort?s story. purchased under the Agreement, ?The Wolf of Wall Street" with cash siphoned from 1MDB. 0n information and belief, in addition to criminal exposure, Red Granite has also faced civil actions stemming from its receipt of illicit funds for its ?lm projects. including civil actions alleging RICO violations. 16. Belfort?s reliance on Aziz and Red Granite holding themselves out to be legitimately funded, ?nanced by high net worth individuals and entities, including but not limited to Goldman Sachs, as well as other legal and legitimate entities. and Red Granite being a properly funded ?lm production company. caused him to enter into the Agreement. Had Belfort known the truth, he never would have done so, as he had other, legitimate and legally funded parties interested in purchasing his book/story rights at the time. 17. Belfort has been damaged to the extent that the rights to his books and stories, and the film based thereon. were acquired using illegal and illicit funds. and such rights are forever 5 Complaint contaminated by the illicit funding used by Aziz and Red Granite to acquire the rights. fund its own operations and to produce the film. 18. Aziz and Red Granite have now distanced themselves from Belfort?s ?The Wolf of Wall Street? story. and other rights purchased under the Agreement (including ?Catching The Wolf of Wall Street? book rights), given the true source of funding for the film which has come to light and the criminal charges facing Defendants. At this time. Defendants cannot exploit the rights as such rights are normally exploited, even if they wanted to, by virtue of its illegal acquisition of the rights and funding of the ?lm. and it has forever damaged the rights acquired from Belfort by its conduct. l9. Defendants are liable to Belfort for the damages caused by their election to sti?e the exploitation of rights acquired from Belfort. by fraudulently inducing Belfort to enter into the Agreement. and by using tainted funds to acquire the rights to. and produce. Belfort's story, ?The Wolf of Wall Street." 20. By their actions. Red Granite and Aziz have fundamentally and directly damaged Belfort and his rights under the Agreement. which include exploitation and monetization of his book/story righisi that are now and forever blemished by the scandal. and Red Granite and Aziz?s involvement therein. 1 - A (By Belfort. against Defendants and Does 1 through 10) 21. Plaintiff hereby incorporates by reference each and every allegation set forth in Paragraphs 1 through 20 as if set forth in full herein. 22. Prior to March 29. 20l l. in negotiations with Belfort, Aziz individually and on behalf of Red Granite. misrepresented themselves and held themselves out to Belfort as a legitimate and legally funded film producer/production company. financed by high net worth individuals and entities. including but not limited to Goldman Sachs, as well as other legal and legitimate entities, able to exploit Belfort?s book/story rights to the fullest extent possible. so that Belfort could maximize the earning potential of such assets. 6 Complaint March 29, 201 l. in reliance on the representations of Defendants. Belfort entered into the Agreement with Red Granite. and sold certain book/story rights to Red Granite, which included the right to exploit and maximize those rights to the fullest extent for the benefit of Belfort. among others. 24. In 2013. Red Granite released the film. ?The Wolf of Wall Street" based on the book/story of Belfort it acquired under the Agreement. Therea?er. Belfort learned. for the ?rst time, that Red Granite and Aziz were connected to and in fact central ?gures in one of the largest and highly publicized global. criminal scandals in history. Belfort also learned that funding for Red Granite, and consequently for the film, were allegedly derived from illegally secured sources. 25. Belfort learned that Aziz was alleged to have laundered $248 million into Red Granite bank accounts between 2010 and 2012; that during the years 20l0 and 20l 2. Red Granite's former co. founder. Joey McFarland, was alleged to have accepted valuable gifts. artwork and a cache of luxury watches from funds linked to the fund; and that Red Granite used these tainted funds to acquire Belfort?s rights and ?nance ?The Wolf of Wall Street? pursuant to the rights it acquired under the Agreement. Belfort also learned that Red Granite last year was forced to pay out $60 million when it was shown it financed Belfon's story, purchased under the Agreement. ?The Wolf of Wall Street? with cash siphoned from 26. Plaintiff is informed and believes and thereon alleges that Defendants made the foregoing misrepresentations to fraudulently induce Belfort to enter into the Agreement. 27. Belfort reasonany relied on Defendants misrepresentations in entering into the Agreement. believing that Defendants were legally funded, could and would fully exploit the entirety of rights he sold under the Agreement. and maximize Belfon?s compensation under the Agreement. 28. Defendants have failed and refused to maximize the rights acquired under the Agreement, due to their involvement in and/or association with the international criminal scandal and/or due to the harm they have caused the acquired rights by virtue of their involvement/association. 29. Plaintiff has demanded that Defendants pursue exploitation of the acquired rights pursuant to the obligations under the Agreement. Defendants have refused. 30. As a direct, proximate and foreseeable consequence of the misrepresentations described above. Plaintiff has suffered damages. and will continue to suffer damages in excess of the minimum 7 Complaint u?pnon-o?ou?a?o 16 jurisdictional amount of this Court. according to proof at trial. but in excess of $300 million, plus interest, legal fees and costs. 31. Plainti?' is informed and believes, and thereon alleges, that. in performing the actions described above. Aziz. Red Granite. and Does I through l0 acted with maliCe. oppression, and fraud as those terms are de?ned by California Civil Code Section 3294, and Aziz and Red Granite carried out those actions with the intent to deprive Plaintiff of his interests. Plaintiff is therefore entitled to punitive damages in a suf?cient amount to make an example of. punish Aziz and Red Granite, and deter future fraudulent. oppressive and malicious misconduct. SEC (By Belfort agath Defendants and Does I through l0) - I 32. Plaintiff hereby incorporates by reference each and every allegation set forth in Paragraphs 1 through 31 as ifset forth in full herein. 33. Prior to March 29. 20l I. In negotiations with Belfort. Aziz individually and on behalf of Red Granite, represented themselves and held themselves out to Belfort as a legitimate and legally funded ?lm producer/production company. ?nanced by high net worth individuals and entities, including but not limited to Goldman Sachs, as well as other legal and legitimate entities, and able to exploit Belfort?s book/story rights to the fullest extent possible, so that Belfort could maximize the earning potential of such assets. 34. On March 29. 20] l, in reliance on the representations of Defendants, Belfort entered into the Agreement with Red Granite. and sold certain book/story rights to Red Granite, which included the right to exploit and maximize those rights to the fullest extent for the bene?t of Belfort, among others. 35. in 2013, Red Granite released the ?lm, ?The Wolf of Wall Street? based on the book/story of Belfort it acquired under the Agreement. Thereafter. Belfort learned. for the ?rst time. that Red Granite and Aziz were connected to and in fact central ?gures in one of the largest and highly publicized global. criminal scandals in history. Belfort also learned that funding for Red Granite. and consequently for the ?lm, were seemingly derived from illegally secured sources. Complaint 36. Belfort reasonably relied on Defendants representations in entering into the Agreement. believing that Defendants could and would fully exploit the entirety of rights he sold under the Agreement. and maximize Belfort?s compensation under the Agreement. 37. Plaintiff is informed and believes and thereon alleges that Aziz. as the principal of Red Granite, knew that the representations about Red Granite as a legitimately funded ?lm production company were materially and grossly inaccurate. Aziz, as the principal of Red Granite. also knew that the failure to disclose to Belfort his and Red Granite?s association and involvement with the IMDB scandal were materially and grossly misleading. 38. Defendants grossly misrepresented its ?nancing sources. and failed to disclose its association and involvement with the IMDB scandal to Belfort when they entered into the Agreement. 39. Plaintiff is informed and believes and thereon alleges that Defendants should have known the effect their illicit funding sources would have on the ?lm. as well as the negative effect of discovery of Defendants connection with the IMDB scandal would have on the rights acquired under the Agreement, and their ability to exploit those rights upon discovery. 40. Belfon reasonably relied on Defendants representations in entering into the Agreement. believing that Defendants would fully exploit the entirety of rights he sold under the Agreement. and maximize Belfort?s compensation under the Agreement. 41. Defendants have failed and refused to maximize the rights acquired under the Agreement. due to their involvement in and/or association with the international criminal scandal and/or due to the harm they have caused the acquired rights by virtue of their involvement/association. 42. Plaintiff has demanded that Defendants pursue exploitation of the acquired rights pursuant to the obligations under the Agreement. Defendants have refused. 43. As a direct, proximate and foreseeable consequence of the misrepresentations described above, Plaintiff has suffered damages, and will continue to suffer damages in excess of the minimum jurisdictional amount of this Court, according to proof at trial, but in excess of $300 million plus interest, legal fees and costs. ll 9 Complaint u?o?u?n?o THIRD SE OF ACTIO - AT 1 (By Belfort against Defendants and Does 1 through 10) 44. Plaintiffs hereby incorporate by reference each and every allegation set forth in Paragraphs 1 through 43 as if set forth in full herein. 45. Red Granite is an enterprise that is engaged in interstate commerce within the United States through the production of motion pictures. Red Granite is funded with monies that include proceeds from unlawful activities. Plaintiff is informed and believes bad on published reports that individuals in Malaysia, Indonesia. Russia, and other countries in Asia and the Middle East have engaged in unlawful activities as de?ned by 18 U.S.C. l956(c)(7), and that they have invested the ill- gotten gains from such activity in Red Granite. 46. Aziz is associated with Red Granite. and participates directly in the conduct of Red Granite?s affairs. 47. Defendants have engaged in a pattern of racketeering activity. in that they have engaged in multiple financial transactions within the United States - including ?nancing, producing and releasing the film, ?The Wolf of Wall Street" with knowledge that the property involved represented the proceeds of unlawful activity and with knowledge that the transactions were designed to conceal the nature, location, source. ownership. or control of the proceeds of the illegal activity. all in violation of IJ U.S.C. 1956. Each of these transactions occurred after the formation of Red Granite in or about September 2010. 48. Defendants have used and invested the proceeds of their pattern of racketeering activity in the operation of Red Granite. in violation of 18 U.S.C. l962(a). 49. Defendants? funding of Red Granite with proceeds of illegal activity has enabled Red Granite to acquire the rights to ?The Wolf of Wall Street.? Following the acquisition of those rights, Defendants have failed and refused to maximize the rights acquired under the Agreement. due to their involvement in and/or association with the international criminal scandal and/or due to the harm they have caused the acquired rights by virtue of their involvement/association. 10 Complaint m&uN-O 50. Plaintiff has been injured in his business or property through Defendants? use of racketeering activity to acquire rights to ?The Wolf of Wall Street,? which acquisition enabled Defendants to control the rights of Plaintiff and to refuse to exploit those rights as called for under the Agreement. The amount of the resulting damages shall be proven upon the trial of this action. but are in excess of $300 million. plus interest. legal fees and costs. FOURTH CAUSE OF ACTION - BREACH OF WRITTEN CONTRACT (By Belfort against Red Granite and Does I through 10) 51. Plainti?' hereby incorporates by reference each and every allegation set forth in Paragraphs 1 through 50 as if set forth in full herein. 52. Belfort and Red Granite entered into the Agreement. 53. Pursuant to the Agreement. including in Sections 3 and 4. Belfort and Red Granite agreed that Red Granite would acquire the right to exploit Belfort's book and story to the fullest extent possible. and the Agreement provided for various forms of compensation to Belfort when those rights are exploited. 54. Red Granite breached the Agreement by failing and refusing to exploit the book and story rights. and/or taking actions that would cause exploitation of the rights to run counter to their interests, thereby denying Belfort of compensation thereunder. SS. Belfort has duly demanded that Red Granite exploit the rights for the bene?t of Belfort. yet Red Granite refuses to do so. 56. Belfort performed all conditions. covenants and promises required on his part to be performed in accordance with the terms and conditions of the Agreement. with the exception of those conditions, covenants and promises which have been prevented. delayed or excused as a consequence of the conduct and/or breaches by Red Granite set forth herein. 57. As a direct. proximate and foreseeable consequence of the foregoing breaches. Plaintiff has suffered damages, and will continue to suffer damages in excess of the minimum jurisdictional amount of this Court. according to proof at trial. but in excess of $300 million. plus interest legal fees and costs. Complaint omqaubwh?uFIFTH CAUSE OF CT VEN AED Pg}; DEALING (By Belfort against Defendants and Does I through 10) 58. Plaintiff hereby incorporates by reference each and every allegation set forth in Paragraphs 1 through 57 as if set forth in full herein. 59. The Agreement. including without limitation in Sections 3 and 4. carried with it an attendant obligation of good faith and fair dealing by Red Granite. That obligation of good faith and fair dealing included. among other things. an obligation to exploit the acquired rights in a manner that would maximize the rights, and to maximize the rights to the fullest extent possible. to the bene?t of Belfort among others. 60. Aziz has caused Red Granite to breach the covenant of good faith and fair dealing incorporated in the Agreement by using illegal and illicit funds to acquire the rights from Belfort and to produce and release ?The Wolf of Wall Street.? which is now tainted by its association with this now highly publicized global criminal scandal, and by failing and refusing to now exploit the acquired rights. 61. Belfort performed all conditions. covenants and promises required on his part to be performed in accordance with the terms and conditions of the Agreement, with the exception of those conditions. covenants and promises which have been prevented, delayed or excused as a consequence of the conduct and/or breaches by Defendants set forth herein. 62. As a direct. proximate and foreseeable consequence of the foregoing breaches, Plaintiff has suffered damages. and will continue to suffer damages in excess of the minimum jurisdictional amount of this Court, according to proof at trial, but in excess of $300 million. plus interest. legal fees and costs. SIXTH A SE OF - (By Belfort against Defendants and Does 1 through 10) 63. Plaintiff hereby incorporates by reference each and every allegation set forth in Paragraphs 1 through 62 as if set forth in full herein. 64. Belfort alleges that the Agreement was/ts. in whole or in pan. illegal and/or tainted with illegality. and therefore void and cannot be enforced against Belfon. l2 Complaint anxious-wro? l2 65. Belfort alleges that the entire Agreement was illegal and/or tainted as Defendants used the Agreement, and speci?cally the acquired rights from Belfort, as a tool to launder illegal and illicit ?rnds, by acquiring ?lm rights and producing the ?lm. ?The Wolf of Wall Street". As set forth above. including in paragraph l3. such illegal/illicit funds were accessed by, and then through, Red Granite. and used to pay for the rights acquired from Belfort and production of the ?lm. 66. Belfort further alleges that not only is the Agreement entirely illegal for the reasons stated in paragraph 65, it is at least partially illegal as the exploitation of Belfort?s rights acquired under the Agreement. which rights are now known to be associated with illegality due to the connection between the ongoing criminal investigations into the scandal and its connection to the funding for the ?lm. With such criminal investigations now pending. it is unclear whether monies used to pay for the rights, or income from these exploited rights, will be clawed back or seized by the government. as set forth in paragraph 13 above. as a result of the criminal charges facing Aziz. and his company, Red Granite. who operated to ?nance the ?lm and who is charged with exploiting the remaining rights under the Agreement. 67. As a result, Belfort alleges that the Agreement is. in whole or in pan. void and cannot be enforced against Belfort. 68. On information and belief. Defendants contend that the Agreement is not void. is valid and is binding and enforceable on Belfort. 69. Based upon the foregoing, there exists an actual dispute or controversy between the pmies with respect to the Agreement. whether the Agreement is illegal and void, in whole or in part. and therefore unenforceable against Belfort, in whole or in part. 70. Belfort accordingly requests a declaration from this Court that the Agreement is void and unenforceable against Belfort, either in whole, or in part related to the exploitation rights thereunder. Belfort has fully and in all things performed his obligations under the Agreement. with the exception of those conditions, covenants and promises which were excused as a consequence of the breach or actions of Defendants. l3 Complaint l6 FQR WHEREFORE. Plaintiff prays for judgment against Defendants and Docs 1 through 10. and each of them, as follows: WW 1. For compensatory damages according to proof at trial. but in excess ofS300 million. 2. For attorneys' fees pursuant to contract. 3. For costs of suit to the extent permitted by law. 4. For interest at the maximum rate permitted by law. 5. For punitive damages. 6. For such other and further relief as the court may deem proper. Second Causeof Action rN l' at ire i. For compensatory damages according to proof at trial. but in excess of $300 million. 2. For attorneys? fees pursuant to contract. 3. For costs of suit to the extent permitted by law. 4. For interest at the maximum rate permitted by law. 5. For such Other and further relief as the court may deem proper. in! 'o 0 Rs et ueneedandCor to an ti :1 I. For treble damages in an amount according to proof at trial, but in excess of $300 million. 2. For reasonable attorneys' fees. Fourth use of Action for Breac i. For damages in a sum in excess of the jurisdictional minimum of this Court. according to proof at trial. but in excess of $300 million. 2. For special damages in a sum in an amount according to proof at trial. 3. For prejudgment interest on the damages at the maximum rate permitted by law. 4. l" or attomeys' fees to the extent permitted under California law. Fifth a cti a ood Fait Fair Dealin I. For damages in an amount in excess of the jurisdictional minimum of this Court, according to proof at trial. but in excess of $300 million. 14 Complaint owqambwn? IJ I?o u?o y?o 2. For special damages in a sum in an amount according to proof at trial. 3. For prejudgment interest on the damages at the maximum rate permitted by law. 4. For attorneys' fees to the extent permitted under California lawdeclaration that the Agreement is void and unenforceable against Belfon, either in whole. or in part related to the exploitation rights thereunder; Qn All Cam of Aegou 1. For costs of suit incurred in this action. 2. For such other and further relief as the court may deem proper. Dated: January Q3, 2020 FREEDMAN TAITELMAN. LLP 0\ Bryan J. Freedman David Marmorstein Attorneys for Plaintiff Jordan Belfort 15 Complaint