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BRYAN J. FREEDMAN, Esq. (SBN 151990) BRIAN E. TURNAUER, Esq. (SBN 214768)
FREEDMAN & TAITELMAN, LLP

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1901 Avenue of the Stars, Suite 500

Los Angeles, CA 90067 (310)201-0005 (310)201-0045

E-mail: bfreedman@ftllp.com

SUPERIOR COURT OFCALJFORN1A

COUNTY OF LOS ANGFXES

FILED

bturnauer@ftllp.com

/PR 12 2012

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Attorneys for Plaintiff International Creative Management, Inc. John A, ciarKe. Executive ofli<xf/Cicrk

by AaM^T'.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES

, Deputy

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BC48874*
INTERNATIONAL CREATIVE
Case No.:

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MANAGEMENT, INC., a Delaware Corporation,

Plaintiff,
vs.

COMPLAINT FOR:

1. BREACH OF WRITTEN CONTRACT

2. IN THE ALTERNATIVE, BREACH
OF ORAL CONTRACT

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PAUL DELVECCHIO, JR. aka "DJ Pauly D,' an individual; BLOWOUT ENTERPRISES, LLC, a Rhode Island limited liability

3. QUANTUM MERUIT
4. ACCOUNTING

corporation; and DOES 1 through 50,

inclusive,
Defendants.

5. DECLARATORY RELIEF

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_)

Plaintiff International Creative Management, Inc., a Delaware Corporation ("Plaintiff or

"ICM"), complains against defendants Paul DelVecchio, Jr. aka "DJ Pauly D," an individual ("DelVecchio"), Blowout Enterprises, LLC, aRhode Island limited liability corporation
("Blowout") (collectively, Defendants"), and DOES 1-50, as follows:
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COMPLAINT

1
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INTRODUCTION

1.

DelVecchio goes by the name "DJ Pauly D" on a widely popular MTV reality

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television show entitled Jersey Shore (the "Jersey Shore"). DelVecchio asked ICM torepresent

him after the first season ofthe Jersey Shore when MTV refused to compensate him despite the

virtually overnight success ofthe show. ICM went to bat for DelVecchio, successfully

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negotiating lucrative amendments to DelVecchio's participation agreement with MTV. Because

ofICM's efforts, DelVecchio, through his loan out company Blowout, earns asubstantial sum for

each season ofJersey Shore and has endorsement deals and side-projects based on his DJ Pauly D
persona.

2.

No good deed goes unpunished, however, and DelVecchio ultimately terminated

the representation. Now, DelVecchio and Blowout refuse to pay ICM nearly $400,000 in
commissions on amounts Defendants have already received. Defendants have also unequivocally

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announced that they have no intention ofpaying ICM over $200,000 in commissions on future

money DelVecchio and Blowout are set to earn from Jersey Shore despite their contractual
obligation to do so.

3.

ICM attempted to resolve the matter informally, but DelVecchio refused to even

acknowledge the contractual obligations binding him and his loan out company. Accordingly,
ICM was left with no choice but to file this lawsuit. By this complaint, ICM seeks to hold

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Defendants liable for their purposeful and intentional breach oftheir talent agency agreement with

ICM. ICM seeks judicial intervention to help the agency collect commissions on the hundreds of
thousands of dollars that Defendants have already earned onJersey Shore. ICM further seeks a

judicial declaration that itis entitled to commissions on substantial sums in excess of$200,000 to
be paid to Defendants as a result ofICM's hard work and dedication to Defendants' career.
PRELIMINARY ALLEGATIONS

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4.

ICM is, and at all times material hereto has been, a corporation duly organized and

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operating under the laws of the State ofDelaware, with its principal place ofbusiness located in
the County ofLos Angeles, State ofCalifornia. ICM is, and at all times relevant hereto was,
licensed as a talent agency by the Labor Commissioner of the State ofCalifornia.
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COMPLAINT

5.

Upon information and belief, ICM alleges that at all times material hereto,

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DelVecchio has been an "artist" as that term is defined in Section 1700.4(b) of the California

Labor Code. DelVecchio is an actor regularly working in the entertainment industry and,

accordingly, has entered into numerous contracts in the County of Los Angeles, California, including a contract with MTV. DelVecchio is and has been represented by entertainment
counsel, business managers and agents whose offices are located in Los Angeles,

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California. These lawyers, agents and business managers regularly conduct business onhis
behalf in the County of Los Angeles, California. Moreover, upon information and belief,

ICM alleges that DelVecchio performs DJ services and other music related performances in
the County of Los Angeles, State of California

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6.

Upon information and belief, ICM alleges that Blowout is a Rhode Island limited

liability corporation which, at all relevant times, was authorized to do business in the State of
California. At all times material hereto, Blowout has been DelVecchio's personal services

corporation, loaning out DelVecchio's services as anactor in the entertainment industry.

7. The true names and capacities, whether individual, corporate, associate or
otherwise of the defendants named herein as Does 1 through 50, inclusive, are unknown to ICM

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which therefore sues said defendants by such fictitious names. ICM alleges on information and
belief that each of thedefendants, including those designated as a Doe, are responsible for the

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events alleged herein and the damages caused thereby asa principal, agent, co-conspirator or
aider and abettor. ICM will seek leave of Court to amend this Complaint to allege the true

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names and capacities of such defendants when the same have been ascertained.

8.

Upon information and belief, ICM alleges that Defendants and Does 1-50 atall

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times relative to this action, were the agents, servants, partners, jointventurers and employees
of each of the other Defendantsand Does 1-50 and, in doing the acts alleged herein, were acting

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with the knowledge and consent ofeach ofthe other Defendants and Does 1-50 in this action.
9. This Court hasjurisdiction over all Defendants becauseon information and

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belief, Defendants have entered into numerous contracts in thisforum, regularly conduct
business in this forum, have performed several concerts in this forum and have hired agents,
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COMPLAINT

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managers and other representatives with offices in this forum. Moreover, Defendants' payment

for services is processed in this forum. Thus, Defendants have sufficient minimum contacts in
California and otherwise intentionally avail themselves ofthe California market so as to render

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the exercise ofjurisdiction over them by the California courts consistent with traditional notions
of fair play and substantialjustice.

10.

This Court is the proper court for trial ofthis matter because the agreement which

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is the subject ofthis action was entered into in Los Angeles County, California. The parties'
obligations under the agreement were incurred and to be performed in Los Angeles County,
California.

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GENERAL ALLEGATIONS COMMON TO ALL COUNTS

The Agent/Performer Agreements

11.

In or about January 2010, Defendants engaged ICM to serve as DelVecchio's

talent agency. Initially, Defendants operated under an oral agency agreement with ICM
from January 2010 through July 2010. In late July 2010, ICM and Defendants entered into
ICM's written standard "General Services Agreement" (the "Agency Agreement"). The

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Agency Agreement clearly set forth the terms, conditions and obligations ofthe parties.
12. Paragraphs 4 and 5 of the Agency Agreement states:

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4. I [Defendants] agree to pay you [ICM] ten percent (10%) of the gross compensation earned or received by me for, or in connection with, (i) any contracts for, or engagements of, my services (collectively and individually
hereinafter sometimes referred to as "employment") now in existence, except

to such extent that I may be obligated to pay commission on such contracts to

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another agent, or contracts entered into or negotiated for during the term, including, but not limited to, all gross compensation therefrom, and payments thereon, that are earned or received by me, or become due or payable to me after the expiration of the term, and (ii) for, or in connection with all
modifications, renewals, additions, substitutions, supplements, replacements, or extensions of or to such contracts and engagements, whether negotiated

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during or after the term hereof. You shall continue to perform your obligations hereunder after the term with respect to all employment with respect to which you are entitled to your commission as provided in the immediately preceding sentence. "Gross compensation" includes all forms of compensation, money, things ofvalue orother emoluments (including, but not
limited to, salaries, earnings, fees, residuals, royalties, bonuses, gifts,

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monetary and non-monetary consideration, securities and shares of profits or gross receipts) received by me orany person, firm orcorporation, partnership,
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COMPLAINT

joint venture or other entity now or hereafter owned or controlled by me

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(hereinafter "my firm") or in which I may have any right, title or interest, on my behalf, from such contracts or engagements and modifications, renewals, additions, substitutions, supplements, replacements, and extensions of or to
such contracts or engagements, whether or not procured by you or by anyone else as well as from any form of advertising, or commercial tie-ups or
infomercials using my name, likeness, or voice.

5. In the event that my firm, if any, has or hereafter during the term
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acquires, directly orindirectly, any right respecting my services in any of

the fields covered by this Agreement, then promptly following your

request to do so, I shall cause my firm to enter into a written exclusive agency agreement with you with respect to such services upon all of the
terms and conditions herein contained, specifically including an

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agreement by my firm to pay compensation to you as herein provided in

Paragraph 4, based upon the gross compensation paid and/or payable to

my firm, directly or indirectly, for furnishing my services. For the purposes ofthis Paragraph 5, the term "gross compensation" shall be deemed
to include gross compensation paid and/or payable tomy firm ifit would have been gross compensation pursuant to Paragraph 4 if paid or payable to me.
Notwithstanding the fact that my firm may enter into such agency agreement

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with you, I shall in all events remain primarily liable, jointly and severally with my firm, to pay compensation to you as provided in Paragraph 4 above,
based on the gross compensation paid and/or payable to my firm, directly or indirectly, for furnishing my services; and I shall indemnify you against a

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failure ofmy firm to execute said agency agreement, or, if ithas executed said agency agreement, any failure of my firm to pay commissions pursuant thereto or otherwise to comply with the provisions thereof, and hold you harmless from any loss, cost, or expense incurred by you as a result of said failure. No waiver, extension, change, or amendment with respect to said agency agreement, nor failure for any reason to execute same, shall be deemed
to release me of or from any liability hereunder.

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The above terms were expressly discussed and agreed to by the Parties. Thus, pursuant to

the terms of the Agency Agreement, Defendants became obligated to pay ICM a

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commission equal to ten percent (10%) ofthe gross compensation earned or received by
DelVecchio or on his behalf by any business, including, but not limited to, loan-out

companies such as Blowout inconnection with any contracts for, orengagements of,
DelVecchio's services, in existence at the time of the Agency Agreement (except to the
extentsuch commissions were already owedto anotheragency), or entered into or

negotiated during the relationship, and for, or in connection with, all modifications, renewals, additions, substitutions, supplements, replacements, or extensions of or to such
COMPLAINT

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contracts and engagements, whether negotiated during or after the relationship. A true and correct copy of the Agency Agreement is attached hereto as Exhibit "A" and incorporated
herein by this reference.
ICM Successfully Modifies Defendants' MTV Participant Agreements

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13.

On or about June 22,2009, prior to engaging ICM's services, Defendants

entered into a certain Participant Agreement (the "ParticipantAgreement") with MTV in

connection with the MTV television series JerseyShore ("Jersey Shore"), under which

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Defendants rendered talent services on Jersey Shore. The first season of Jersey Shore
achieved an unprecedented level of television ratings success on MTV. 14. On or about January 29, 2010, during ICM's representation of Defendants,

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ICM successfully procured an amendment to the Participant Agreement (the "First

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Amendment to Participant Agreement") in which Defendants' overall compensation was

increased and options for Defendants' services on cycles 2 and 3 of Jersey Shore were
granted to MTV.

15.

On or about April 14, 2010, attorneys for MTV sent a notice to Defendants

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and ICM that the second cycle option ("Cycle 2") for Jersey Shore was beingexercised by
MTV pursuant to the First Amendment to Participant Agreement. ICM is informed and

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believes, and thereupon alleges, thatCycle 2 for Jersey Shore was a twenty-four (24) episode order thatwas ultimately divided into twoseparate seasons of Jersey Shore by
MTV, which were categorized as Cycle 2A and Cycle 2B by MTV. Cycle 2A was filmed

in Miami, Florida and Cycle 2B was filmed in Seaside Heights, New Jersey.
16. Pursuant to the terms of the Agency Agreement with ICM, Defendants remitted

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10% commission on all compensation received pursuant to the First Amendment to

Participant Agreement to ICM, includingall compensation received in connection with

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Cycle 2A and Cycle 2B of Jersey Shore. Both Cycle 2A and Cycle 2B each produced
tremendous television ratings for MTV.

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17.

Jersey Shore's popularity enabled ICM to successfully negotiate another

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improved amendment for Defendants to provide services on additional seasons ofJersey

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COMPLAINT

Shore. On or about July 20,2010, during ICM's representation of Defendants, ICM

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successfully procured a second amendment to the Participant Agreement (the"Second

Amendment to Participant Agreement"), in which Defendants' overall compensation was increased, including a retroactive episodic increase for Cycle 2B, and options for

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Defendants' services on cycles 3 and 4 ofJersey Shore were granted to MTV. Pursuant to the
third paragraph of the Second Amendment to Participant Agreement, Cycle2A was re-

categorized as Cycle 2 and Cycle 2B was re-categorized as Cycle 3 of Jersey Shore (which had
already filmed and aired).

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18.

Pursuant to the terms of the Agency Agreement with ICM, Defendantsremitted

10%commission on all compensation received pursuant to the Second Amendment to

Participant Agreement to ICM.

19.

On or about January 26, 2011, attorneys for MTV sent a notice to Defendants

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and ICM that the fourth cycle option ("Cycle 4") for Jersey Shore was being exercised by
MTV pursuant to the Second Amendment to Participant Agreement.

20.

Again taking advantage of the huge ratings success of Jersey Shore, in or around

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April 2011, during ICM's representation of Defendants and before filming on Cycle 4 began,

ICM began and managed to successfully negotiate another improved amendment for Defendants to provide services onadditional seasons ofJersey Shore, which was entered into and effective
as of March 31, 2011 (the "ThirdAmendment to Participant Agreement"). The Third

Amendment to Participant Agreement provided for a significant compensation increase to

Defendants beginning with Cycle 4 of Jersey Shore andalso contained options for Defendants'
services on cycles 5 and 6 of Jersey Shore.
Defendants Breach the Agency Agreement by Failing to Pay Commissions for Cycle 4

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21.

Pursuant to the Third Amendment to Participant Agreement, Defendants were

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entitled to a $400,000 signing bonus and $100,000 per episode for the first twelve (12) episodes of Cycle 4 of Jersey Shore. ICM is informed and believes, and thereupon alleges, that 12

episodes, a launch special, multiple "after-shows" and a reunion show of Cycle 4 of Jersey
Shore were produced. Therefore, Defendants were entitled to $1,600,000 plus additional
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compensation, including but not limited to"after-shows," a launch special, a reunion show, participations, merchandising and bonuses pursuant to the Third Amendment to Participant
Agreement for Cycle 4. ICM is informed and believes, and thereupon alleges, that Defendants
also received a total of $107,037.33 in gross compensation representing contractual

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participations and $200,000 in gross compensation as a "thank you" bonus on Cycle 4 ofJersey
Shore, bringing Defendants' known total gross compensation onCycle 4 ofJersey Shore to

$1,907,037.33. Accordingly, at a 10% commission rate, ICM is entitled to a minimum of

$190,703.73 plus 10% commission on any other compensation received by Defendants from

Cycle 4 ofJersey Shore, including but not limited to "after-shows," a launch special, a reunion
show, other participations, merchandising and bonuses pursuant to the Third Amendment to

Participant Agreement. To date, Defendants have failed to remit any commission inconnection
with Cycle 4 of Jersey Shore to ICM. Defendants Are Required to Pay Post-Termination Commissions on ICM-Negotiated Deals

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22.

On or about May 5,2011, Defendants discharged ICM as their talent agency.

ICM acknowledged its discharge and confirmed that, pursuant to the written Agency Agreement

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and custom and practice in the entertainment industry, Defendants remained contractually

obligated to pay ICM a commission on all gross compensation Defendants would receive in the
future onany deals negotiated before Defendants' discharge of ICM, including but not limited to
Defendants' Third Amendment to Participant Agreement for Jersey Shore (with an effective
date of March 31,2011 clearly before Defendants' discharge of ICM on or about May 5,

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2011). Indeed, it is standard custom and practice in the entertainment industry that talent

agencies are entitled to post-termination commissions on all deals they negotiate for their client.
See The Stein Agency v. James Tripp-Haith (Cal. Labor Comm'n 2006) (enforcing oral agreement for post-termination commissions as to options exercised well after end of agency
relationship); The Endeavor Agency, LLC v. Milano, TAC 10-05 (Cal. Labor Comm'n 2005)

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(citing Cal. Civ. Code 1656; Rest. 2d Contracts 221) (awarding post-termination commissions
to talent agency based on oral agency agreement on grounds that "the evidence established that the overwhelming industry custom and practice requires an artist to pay post termination
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COMPLAINT

commissions for work negotiated by the agent").

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On or about June 8, 2011, attorneys for MTV sent a notice to Defendants and

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ICM that the fifth cycle option ("Cycle 5") for Jersey Shore was beingexercised by MTV
pursuant to the Third Amendmentto Participant Agreement.

24.

Pursuant to the Third Amendment to Participant Agreement, Defendants were

entitled to $150,000 per episode for the first twelve (12) episodes of Cycle 5 of Jersey Shore. ICM is informed and believes, and thereupon alleges, that 12 episodes, multiple "after-shows"

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and reunion shows of Cycle 5 were produced. Cycle 5 is currently airing on MTV. If 12

episodes, multiple "after-shows" and reunion shows of Cycle 5 were in fact produced, Defendants would be entitled to $1,800,000 plus additional compensation, including butnot limited to "after-shows," reunion shows, participations, merchandising and bonuses pursuant to
the ThirdAmendment to Participant Agreement. Accordingly, at a 10% commission rate, ICM would be entitled to a minimum of $180,000 plus 10% commission on any othercompensation
received by Defendants from Cycle 5 of Jersey Shore, including but not limited to "aftershows,"reunion shows, participations, merchandising and bonuses pursuantto the Third
Amendmentto Participant Agreement.

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25.

ICM is informed and believes, and thereupon alleges, that on or about March 19,

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2012, MTV decided to exercise the sixth cycle option ("Cycle 6") for Jersey Shore pursuant to the
Third Amendment to Participant Agreement. Perthe Third Amendment to Participant
Agreement, whenCycle 6 is produced by MTV, Defendants will be entitled to $175,000 per

episode for the first twelve (12) episodes of Cycle 6 of Jersey Shore. If 12episodes of Cycle 6 of Jersey Shore are in fact produced, Defendants will be entitled to $2,100,000 plus additional compensation, including but not limited to "after-shows," reunion shows, participations,

merchandising and bonuses pursuant to the Third Amendment to Participant Agreement.

Accordingly, at a 10% commission rate, ICM will be entitled to a minimum of $210,000 plus

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10% commission on any other compensation received by Defendants for Cycle 6 of Jersey Shore,

including but not limited to "after-shows," reunion shows, participations, merchandising and bonuses pursuant to the potential exercise of MTV's option to produce Cycle 6 ofJersey Shore.
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COMPLAINT

26.

On or about December 9,2011, ICM received a letter from Defendants' counsel

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Ms. Hillary Hughes, whereby Defendants denied (i) any obligation to pay ICM commission on

compensationreceived pursuant to Cycle 4 of Jersey Shore and (ii) any obligation to pay ICM
any additional commission from Defendants.

27.

On or about December 13,2011, ICM responded to Ms. Hughes and reaffirmed

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its entitlement to commission on any compensation received by Defendants pursuant to the

Third Amendment to Participant Agreement. 28. Defendantscontinue to deny their obligation to pay ICM commission pursuant to

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the Third Amendmentto ParticipantAgreement, including potential future commissionpursuant

to Cycle 6 of Jersey Shore.

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29.

To date, Defendants have not remitted any commission to ICM for monies

received pursuant to the Third Amendment to Participant Agreement, including but not limited
to compensation received by Defendants pursuant to Cycle 4 and Cycle 5 of Jersey Shore, which

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includesThree Hundred SeventyThousand Seven Hundred Three Dollars and SeventyThree Cents ($370,703.73) in commission (the "Outstanding Commission") for monies earned by Defendantsfor Cycle 4 (i.e., $190,703.73 in commission) and Cycle 5 (i.e., $180,000 in
commission) of Jersey Shore. 30. As of the filing of this petition, Defendants have not paid ICM the Outstanding

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Commission due ICM in respect of the Third Amendment to Participant Agreement.

FIRST CAUSE OF ACTION

(For Breach of Written Contract Against Defendants and Does 1-50)

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31.

ICM re-alleges herein by this reference each and every allegation contained in

paragraphs numbers 1 through 30 of this Complaint as if set forth fully herein.

32. Under the terms of the Agency Agreement, Defendants and Does 1-50

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became obligated to pay ICM a commission equal to ten percent (10%) of the gross
compensation earned or received by DelVecchio or on his behalf by any business,

including, but not limited to, loan-out companies such as Blowout in connection with any
contracts for, or engagements of, DelVecchio's services, in existence at the time of the
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Agency Agreement (except to the extent such commissions were already owed to another
agency), or entered into or negotiated during the relationship, and for, or in connection with,
ail modifications, renewals, additions, substitutions, supplements, replacements, or

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extensions of or to such contracts and engagements, whether negotiated during or after the

relationship. This included Defendants' obligation to payICM a commission on all gross compensation Defendants would receive in thefuture on any deals negotiated by-ICM on
Defendants' behalf before Defendants' discharge of ICM.

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33.

ICM has fully performed each of the promises, covenants and conditions to be

performed by it under the Agency Agreement with Defendants and Does 1-50, except tothe extent such performance was prevented or excused by Defendants and Does 1-50.
34. Defendants and Does 1-50 breached the AgencyAgreement by failing and

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refusing to pay ICM commissions in an amount equal to ten percent (10%) of the gross

compensation received by Defendants pursuant to Cycle 4 and Cycle 5 ofJersey Shore arising
out of the Third Amendment to Participant Agreement.

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35.

As a direct and proximate result of Defendants' and Does 1-50's breach ofthe

Agency Agreement, ICM has been damaged, and will be damaged ina sum not yet fully
ascertained, but inany event not less than $370,703.73, together with interest thereon at the
legal rate from the date each payment became or becomes due.
SECOND CAUSE OF ACTION

(In the Alternative, For Breach of OralContract Against Defendants and Does 1-50)
36. ICM re-alleges herein by this reference each and every allegation contained in

paragraphs numbers 1through 30 of this Complaint as if set forth fully herein.

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37.

ICM alleges in the alternative that, only to the extent that the Defendants did

notsign the written Agency Agreement and as a result no written agreement was formed,
ICM and Defendants agreed and contracted orally to abide by the terms of the Agency

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Agreement, thereby forming an oral agreement the terms of which are expressly articulated
in the Agency Agreement attached hereto as Exhibit "A" and incorporated herein.
38. Under the terms of the oral agreement which are set forth in the Agency
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COMPLAINT

Agreement, Defendants and Does 1-50 became obligated to pay ICM a commission equal to ten percent (10%) of the gross compensation earned or received by DelVecchio or on his
behalf by any business, including, but not limited to, loan-out companies such as Blowout

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in connection with any contracts for, or engagements of, DelVecchio's services, in existence
at the time of the Agency Agreement (except to the extent such commissions were already

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owed to another agency), or entered into or negotiated during the relationship, and for, or in
connection with, all modifications, renewals, additions, substitutions, supplements,

replacements, or extensions of or to such contracts and engagements, whether negotiated

during or after the relationship. This included Defendants' obligation to pay ICM a

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commission on all gross compensation Defendants would receive in the future on any deals
negotiated by ICM on Defendants' behalf before Defendants' discharge of ICM.

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39.

ICM has fully performed each of the promises, covenants and conditions to be

performed by it under the terms of the oral agreement which are set forth in the Agency Agreement with Defendants and Does 1-50, except to the extent such performance was
prevented or excused by Defendants and Does 1-50.

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40.

Defendants and Does 1-50 breached the oral agreement, the terms of which are

set forth in the Agency Agreement by failing and refusing to pay ICM commissions in an amount equal to ten percent (10%) of the gross compensation received by Defendants pursuant
to Cycle 4 and Cycle 5 of Jersey Shore arising out of the Third Amendment to Participant
Agreement.

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41.

As a direct and proximate result of Defendants' and Does 1-50's breach of the

oral agreement, the terms of which are set forth in the Agency Agreement, ICM has been

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damaged, and will be damaged in a sum not yet fully ascertained, but in any event not less than

$370,703.73, together with interest thereon at the legal rate from the date each payment became
or becomes due. THIRD CAUSE OF ACTION

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(For Quantum Meruit Against All Defendants and Does 1-50)

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42.

ICM re-alleges herein by this reference each and every allegation contained in
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paragraphs numbers 1 through 41 of this Complaint as if set forth fully herein.

43. Defendants and Does 1-50 have become indebted to ICM for work, labor and

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services rendered by ICM as the agent with respect to the Third Amendment to Participant

Agreement as herein described, and for which Defendants, and each of them, promised to pay
Plaintiff the reasonable value thereof. Defendants, and each of them, knew that these services

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were being provided and accepted, used, and enjoyed the services provided by ICM. 44. Defendants knew that ICM was providing talent agency services to Defendants

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and on Defendants' behalfand, accordingly become indebted to ICM for the reasonable value of
said talent agency services.

45.

Defendants accepted, used and enjoyed and continue to enjoy, the benefits of the

talent agency servicesprovided by ICM. Though Defendants initially paid ICM commissions for compensation received pursuant to the Agency Agreement as a result of the talent agency services that they accepted, used and enjoyed, Defendants have failed and refused to fully

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compensate ICM for the full value of the talent agency services employed by ICM. Defendants
have not paid the commissions from the gross compensation received by Defendants pursuant to Cycle 4 and Cycle 5 of Jersey Shore and refuseto pay commissions from future gross

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compensation to be received by Defendants pursuant to Cycle 6 of JerseyShore arising out of

the Third Amendment to Participant Agreement, although demand therefore has been made.
46. The fair and reasonable value of commissions now past-due and owing by

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Defendants to ICM relating to its talent agency services is ten percent (10%) of the gross

compensation earned or received by DelVecchio or on his behalf by any business,

including, but not limited to, loan-out companies such as Blowout. 47. As a direct result of Defendants' failure and refusal to pay ICM for its work, labor

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and services rendered, ICM has been damaged in an amount according to proof at hearing, \but in any event not less than $370,703.73, together with interest thereon at the legal rate from the
date each payment became or becomes due.
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to

COMPLAINT

FOURTH CAUSE OF ACTION

2 3
4

(For Accounting against all Defendants and Does 1-50)

48.

Plaintiff re-alleges herein by this reference each and every allegation contained

in paragraphs numbers 1 through 47 of this Complaint as if set forth fully herein. 49. Pursuant to the Agency Agreement, ICM is entitled to an accounting of all

5 6
7

monies or other consideration payable to Defendants in connection with the Third Amendment
to Participant Agreement. 50. Demand is hereby made for such accounting.

8
9

51.

Defendants have not provided an accounting to ICM for all monies or other

10
11

consideration earned or received by or on behalfof Defendants in connection with the Third Amendment to Participant Agreement. An accounting is required to determine the total amount
of the moniesor other consideration received by or on behalfof Defendants pursuant to the

12
13 14

Third Amendment to Participant Agreement and the exact amount of commissions that are due
and owing to ICM.
FIFTH CAUSE OF ACTION

15 16
17

(For Declaratory Relief against all Defendants and Does 1-50)

52.

ICM re-alleges herein by this reference each and every allegation contained in

18 19
20 21

paragraphs numbers 1 through 51 of this Complaint as if set forth fully herein.

53. ICM contends that Defendants are contractually obligated to pay ICM a 10%

commission on all gross compensationDefendants will receive as a result of any and all deals

that were negotiated by ICM on Defendants' behalf before Defendants' discharge of ICM. This

22
23

includes, but is not limited to, any future compensation Defendants receive under the Third
Amendment to Participant Agreement (with an effective date of March 31,2011 clearly
before Defendants' discharge of ICM on or about May 5,2011), such as Cycle 6.
54. Defendants contend that they do not and will not owe ICM such commissions.

24
25
26

55.

Accordingly, an actual controversy has arisen and now exists between ICM, and

27

Defendants regarding commissions owed by Defendants to ICM moving forward.

% X
I* 10 \
10

28

56.

ICM desires a judicial determination of its rights and duties, and a declaration
14

COMPLAINT

1 2

that Defendants, and eachof them, are obligated to pay ICM a commission on all gross

compensation Defendants received on any deals negotiated by ICM on Defendants' behalf

before Defendants' discharge of ICM, including but not limited to Defendants' Third
Amendment to Participant Agreement which includes Cycle 6.

3
4 5

57.

Ajudicial declaration therefore isnecessary and appropriate atthis time under the

6
7

circumstances in order to determine ICM's rights and Defendants' obligations under the Agency
Agreement.
PRAYER FOR RELIEF

8
9

WHEREFORE, ICM prays for judgment against Defendants, and each of them, as
follows:

10

11 12 13
14 15

On The First Cause Of Action For Breach of Written Contract:

1.

For general damages in a sum in excess of the minimum jurisdiction of the court,
according to proof at trial;

2.
3.

For pre-judgment interest at the maximum rate permitted by law;

For costs of suit incurred herein; and

16
17

4.

For such other and further relief as the Court may deem just and proper.

On The Second Cause Of Action For Breach of Oral Contract In the Alternative:

18
19

1.

For general damages in a sum in excess of the minimum jurisdiction of the court,
according to proof at trial;

20
21 22

2.
3.

For pre-judgment interest at the maximum rate permitted by law;

For costs of suit incurred herein; and

4.

For such other and further relief as the Court may deem just and proper.

23
24

On The Third Cause Of Action For Quantum Meruit:

1.

For general damages in a sum in excess of the minimum jurisdiction of the court,
according to proof at trial;

25 26 27
\
I"

2.
3.

For pre-judgment interest at the maximum rate permitted by law;

For costs of suit incurred herein; and

10
10

28

4.

For such other and further relief as the Court may deem just and proper.

15
COMPLAINT

1 2 3 4
5

On The Fourth Cause Of Action For Accounting:

1.

For ICM to be provided with a written accounting with respect to all monies or
other consideration received by or on behalf ofDefendants in connection with the
Third Amendment to Participant Agreement;

2.

For payment to ICM of the amount due from Defendants as a result of the
accounting;

6
7 3.

For pre-judgment interest at the maximum rate permitted by law;

For costs of suit incurred herein; and

8 9

4.
5.

For such other and further reliefas the Court may deem just and proper.

On The Fifth Cause Of Action For Declaratory Relief:

10

1.
11
12

For an order declaring that Defendants, and each ofthem, are obligated to pay ICM
a commission on all gross compensation Defendants receive on any deals

negotiated by ICM on Defendants' behalfbefore Defendants' discharge of ICM,

including but not limited to Defendants' Third Amendment to Participant
Agreement which includes Cycle 6;

13
14

15
2.

For costs of suit incurred herein; and

16
3.
17

For such otherand further reliefas the Courtmay deem just and proper.

18

Dated: April 12,2012

FREEDMA^TAITELj^AN, LLP

19
20
21

BrydfTJ.
Brian E. Turnauer

Attorneys for Plaintiff International Creative Management,

Inc.

22
23
24 25

26 27
I* 10

28
16

\
I* 10

COMPLAINT

CM-Q1Q
Bar "srarroi number, and address): ATTORNEYOR PARV.WIJHOUT ATTORNEY(Nama.
FOR COURT USe ONLY

"Bryan J. Freedman (SBN 151990) Brian E. Tumauer (SBN 214768)

FREEDMAN & TAITELMAN, LLP 1901 Avenue of the Stars, Suite 500

FILED

Los Angeles, California 90067

TELEPHONE NO.:
1( ATTORNEY FOR (Name):

310-201-0005

fax no.:

310-201 0045

APR 1.2 201*

International Creative Management. Inc

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

street address: 111 N. Hill Street
MAILING ADDRESS:

cityandzip code: Los Angeles, California 90012

BRANCH NAME: CENTRAL

case name:
[~x~1 Unlimited
(Amount

International Creative Management, Inc. v. Paul Delvecchi, Jr.

Complex Case Designation
I I Counter I I Joinder
CASE NUMBER:

CIVIL CASE COVER SHEET

Limited
(Amount

BC48 2 741

JUDGE: Filed with first appearance by defendant demanded demanded is (Cal. Rules of Court, rule 3.402) DEPT: exceeds $25,000) $25.000 or less) Items 1-6 below must be completed (see instructionson page 2). 1. Check one box below for the case type that best describes this case:

Auto Tort

Contract

HAuto (22) Uninsured motorist (46) Other PI/PD/WD (Personal Injury/Property Damage/Wrongful Death) Tort

Breach of contract/warranty (06)

Rule 3.740 collections (09)

r~l Asbestos (04) I IProduct liability (24)

I IMedical malpractice (45)

IOther PI/PD/WD (23)

Other collections (09) Insurance coverage (18) Other contract (37) Real Property I I Eminent domain/Inverse condemnation (14)

Provisionally Complex Civil Litigation (Cal. Rules of Court, rules 3.400-3.403) I I Antitrust/Trade regulation(03) 1 I Construction defect (10)

I
I
I I

I Mass tort (40)

I Securities litigation (28)
I Environmental/Toxic tort (30) I Insurance coverage claims arising from the above listed provisionally complex case types (41)

Non-PI/PD/WD (Other) Tort

CD Wrongful eviction (33)

Unlawful Detainer

rn Business tort/unfair business practice (07) O 0,her real V0**** <26>

I
1

Enforcement of Judgment

ICivil rights (08)

I Defamation (13)

I Enforcement of judgment (20)

I
I I I
I I
2.

IFraud (16)
IIntellectual property (19) I Professional negligence (25) IOther non-PI/PD/WD tort (35)
IWrongful termination (36) IOtheremployment (15)

I I

ICommercial (31) I Residential (32)

Miscellaneous Civil Complaint

I
I
I

I RICO (27)
I Othercomplaint (not specified above) (42)
I Partnership and corporate governance (21)

I
I
I

IDrugs (38)
IAsset forfeiture (05)
I Petition re: arbitration award (11)

Judicial Review

Miscellaneous Civil Petition

Employment

I Other petition (notspecified above) (43)

IWritof mandate (02)

Thiscase

I is

I IOther judicial review (39) I x I is not complex underrule3.400ofthe California Rules of Court. Ifthe case is complex, mark the

factors requiring exceptional judicial management:

a. I

I Large number ofseparately represented parties

issues that will be lime-consuming to resolve I Substantial amountof documentary evidence

d. I
f. I

I Large number ofwitnesses

b. I
c. I

I Extensive motion practice raising difficult ornovel e. I

I Coordination with related actions pending in one ormore courts

inother counties, states, or countries, or in a federal court I Substantial post-judgment judicial supervision

3. Remedies sought (check all that apply): a. SH monetary b. CED nonmonetary; declaratory or injunctive relief c. 1ZZ1 punitive
4. Number of causes of action (specify): 1)Breach ofWritten Contract, 2) IntheAltemativ^f-B^each ofOral Contract, 3)Quantum Meruit,

5. This case 1 I is

I x 1 is not

a classaction suit.

4) Accounting, ancj;

lentT")

6. Ifthere are any known related cases, file and serve a notice of related case/

i CM-015.)

Date: April 12,2012 Bryan J. Freedman (SBN 151990

(TYPE OR PRINT NAME)

OF PARTY OR ATTORNEY FOR PARTY)

NOTICE

Plaintiff mustfile this cover sheet with the first paper filed inthe action or proceeding (exceptsmall claims cases or cases filed underthe Probate Code, Family Code, or Welfare and Institutions Code). (Cal. RulesofCourt, rule3.220.) Failure to file mayresult
in sanctions.

s File this cover sheet in addition to any cover sheet required by local court rule.
> Unless this is a collections \
FortsAdopted tor Mandatory Use
Judicial Council of California

iS If this case iscomplex under rule 3.400 et seq.oftheCalifornia Rules ofCourt, you must serve a copy ofthis cover sheet on all
,!} otherpartiesto the action or proceeding. case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only.
_ Pagt1of2
Cal. Rutaa of Court, rulas 2.30. 3.220.3.400-3 403,3.740.

CIVIL CASE COVER SHEET

CM410(Rav. July 1.2007)

ScfjZj

insUS

Cal. Standards ofJudicial Administration. Hd. 310

To Plaintiffs and Cohere Filing First Papers. If you are filing afirst paper (for example, acomplaint) in ai civil case " !"

INSTRUCjJInS ON HOW TO COMPLETE THE COV^SHEET

CM-10

complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This informal on will be used to compile statistics about the types and numbers of cases filed. You must complete items 1through 6on the sheet. In item 1, you must check one box for the case type that best describes the case. If the case fits both ageneral and amore specific type of case listed in item 1, check the more specific 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 1are prov.ded below. Acover sheet must be filed only with your initial paper. Failure to file acover sheet with the first paper filed in acivil case may subject aparty, its
counsel orboth to sanctions under rules 2.30 and 3.220 ofthe California Rules of Court.

To Parties in Rule 3.740 Collections Cases. A"collections case" under rule 3.740 is defined as an action for recovery of money owed in asum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from atransaction in which

damages. (2) punitive damages. (3) recovery of real property, (4) recovery of personal property, or (5) aprejudgment writ of attachment. The identification of acase as arule 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 adefendant files aresponsive pleading. Arule 3.740 collections case will be subject tothe 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 odesignate whether the case is complex. If aplaintiff 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 1and 2. If aplaintiff designates acase as complex, the cover sheet must be served wi h he complaint on all parties to the action. Adefendant may file and serve no later than the time of its first appearance ajonderiin the plaintiffs designation, acounter-designation that the case is not complex, or, if the plaintiff has made no designation, adesignation that
the case is complex.
Auto Tort

property, services, or money was acquired on credit. Acollections case does not include an action seeking the following: (1) tort

CASE TYPES and examples

Contract

Provisionally ComplexCivilLitigation (Cal.

Rules of Court Rules 3.400-3.403)

Auto (22)Personal Injury/Property Damage/Wrongful Death

Uninsured Motorist (46) {Ifthe
case involves an uninsured

Breach of Contract/Warranty (06)

Breach of Rental/Lease

Antitrust/Trade Regulation (03)

Construction Defect (10)

Contract (not unlawful detainer

or wrongful eviction)

motorist claim subject to arbitration, check this item instead of Auto)

Contract/Warranty BreachSeller Plaintiff (not fraud or negligence)

Claims Involving Mass Tort (40) Securities Litigation (28)

Environmental/Toxic Tort (30)

Negligent Breach of Contract/

Warranty Other Breach of Contract/Warranty

Insurance Coverage Claims

Other PI/PD/WD (Personal Injury/

(arising from provisionally complex

case type listed above) (41)
Enforcement of Judgment

Property Damage/Wrongful Death)

Tort

Collections (e.g., money owed, open

book accounts) (09) Collection CaseSeller Plaintiff

Asbestos (04)

Asbestos Property Damage Asbestos Personal Injury/ Wrongful Death Product Liability (not asbestos or
toxic/environmental) (24) Medical Malpractice (45) Medical Malpractice-

Other Promissory Note/Collections

Case

Enforcement of Judgment (20)

Abstract of Judgment (Outof

County) Confession of Judgment (nondomestic relations) Sister State Judgment

Insurance Coverage (not provisionally

complex) (18) Auto Subrogation
Other Coverage Other Contract (37) Contractual Fraud Other Contract Dispute

Physicians & Surgeons

Other Professional Health Care

Administrative Agency Award (not unpaid taxes) Petition/Certification of Entry of

Malpractice Other PI/PD/WD (23) Premises Liability (e.g., slip

and fall)

Real Property
Eminent Domain/Inverse

Judgment on Unpaid Taxes

Other Enforcement of Judgment
Case

Condemnation (14) Wrongful Eviction (33)

Intentional Bodily Injury/PD/WD (e.g., assault, vandalism)

Intentional Infliction of
Emotional Distress

Other Real Property (e.g., quiet title) (26)

Writ of Possession of Real Property

Miscellaneous Civil Complaint RICO (27)

Other Complaint (not specified

above) (42) Declaratory Relief Only

Mortgage Foreclosure
Quiet Title

Other Real Property (not eminent

domain, landlord/tenant, or foreclosure)
Unlawful Detainer

Negligent Infliction of
Emotional Distress

Injunctive Relief Only (nonharassment)

Mechanics Lien

Other PI/PD/WD

Other Commercial Complaint

Non-PI/PD/WD (Other) Tort

Business Tort/Unfair Business

Commercial (31) Residential (32)

Case (non-tort/non-complex)
Other Civil Complaint

Practice (07)

Civil Rights (e.g., discrimination,

false arrest) (not civil harassment) (06) Defamation (e.g.. slander, libel) (13) Fraud (16)

Drugs (38)(ifthecase involves illegal drugs, check this item:otherwise, report as Commercial or Residential)
Judicial Review

. (non-tort/non-complex)
Miscellaneous Civil Petition

Partnership and Corporate

Governance (21)

Asset Forfeiture (05)

Petition Re: Arbitration Award (11)

Writ of Mandate (02)
Writ-Administrative Mandamus

Other Petition (not specified

above) (43)
Civil Harassment

Intellectual Property (19) Professional Negligence (25) Legal Malpractice

Writ-Mandamus on Limited Court

Case Matter

Workplace Violence Elder/Dependent Adult

Abuse

<p OtherProfessional Malpractice if (not medicalor legal)

Other Non-PI/PD/WD Tort (35)

Writ-Other Limited Court Case

Review

Election Contest

Employment
Wrongful Termination (36)

Ofther Employment (15)

CM-010lRov. July 1,20071

Other Judicial Review (39) Review of Health Officer Order Notice of Appeal-Labor Commissioner Appeals

Petition for Name Change Petition for Relief from Late

Claim

Other Civil Petition

Pag*2of]

CIVIL CASE COVER SHEET

short title: International Creative Management, Inc. v. Paul Delvecchi, Jr.

CASE NUMBER

UC48274*

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

{CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This form is required pursuant to Local Rule 2.0 In all newcivil case filings in the LosAngeles Superior Court.
Item I. Check the types of hearing andfill in the estimated length ofhearing expected for this case:

JURY TRIAL? CD YES CLASS ACTION?

YES LIMITED CASE?

YES TIME ESTIMATED FOR TRIALX

I IHOURS/IT1 PAY?

Item II. Indicate thecorrect district and courthouse location (4steps - If you checked "Limited Case", skip to Item III, Pg. 4):

Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your
case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet casetype you selected.

Step 2: Check one Superior Court type of action in Column Bbelow which best describes the nature of this case.
Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have
checked. Forany exception to the court location, see Local Rule 2.0.

Applicable Reasons for Choosing Courthouse Location (see Column C below)

2. May be filed in central (other county, or nobodily injury/property damage).
4. Location where bodily injury, death ordamage occurred. 5. Location where performance required ordefendant resides.
3. Location where cause of action arose.

1. Class actions must be filed in the Stanley Mosk Courthouse, central district.

9. Location where one or more of the parties reside. 10. Location of Labor Commissioner Office

6. Location of property orpermanently garaged vehicle. 7. Location where petitioner resides. 8. Location wherein defendant/respondent functions wholly.

Step 4: Fill in the information requested on page 4 in Item III; complete Item IV. Sign the declaration.

juitojoyoiy ' 7(BD.

Auto (22)
Uninsured Motorist (46)

| A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death

1.. 2,4.

<

I
I

| A7110 Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist

I A6070 Asbestos Property Damage

1., 2., 4.

Asbestos (04)
ft

I
I
I

11 A7221 Asbestos - Personal Injury/Wrongful Death

| A7260 Product Liability (not asbestos or toxic/environmental)
I A7210 Medical Malpractice - Physicians & Surgeons
I A7240 Other Professional Health Care Malpractice
1..2., 3.,4.,8.
14.
1..4.

Product Liability (24)

To

fi
si

Medical Malpractice (45)

I
Other

I A7250 Premises Liability (e.g., slip and fall)

1..4.
1..4.

2 i

Personal Injury Property Damage Wrongful Death

(23)

I
I

I A7230 Intentional Bodily Injury/Property Damage/Wrongful Death(e.g.,

assault, vandalism, etc.) I A7270 Intentional Infliction of Emotional Distress
1..3. 1., 4.

I 'I A7220 Other Personal Injury/Property Damage/Wrongful Death

LACIV109 (Rev. 03/11)

LASC approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0

Page 1 of 4
LA-CV109

shorttitle: international Creative Management, Inc. v. Paul

Delvecchl Jr.

CASE NUMBER

"

Business Tort (07)

I A6029 OtherCommercial/Business Tort (not fraud/breach of contract)

1., 3. 1,2., 3.

Civil Rights (08)

Defamation (13)
~ c

| A6005 Civil Rights/Discrimination

I
I I |

I A6010 Defamation (slander/libel)

I A6013 Fraud (nocontract) I A6017 Legal Malpractice | A6050 Other Professional Malpractice (not medical orlegal)

1.,2., 3. 1,2., 3. 1., 2., 3. 1 2,3.

2.,3.

n 2

Fraud (16)

iE

Professional Negligence (25)

Other (35) Wrongful Termination (36) Other Employment (15)

28

I
I I I I

I A6025 Other Non-Personal Injury/Property Damage tort

I A6037 Wrongful Termination I A6024 Other Employment Complaint Case I A6109 Labor Commissioner Appeals I A6004 Breach of Rental/Lease Contract (not unlawful detainer orwrongful
eviction)

1., 2., 3. 1 2., 3.

10.

0
a.

E
LU

2., 5.

Breach of Contract/ Warranty (05)

(not insurance)

I x I A6008 Contract/Warranty Breach -SellerPlaintiff (no fraud/negligence) I l A6019 Negligent Breach of ContractA/Varranty (no fraud) I I A6028 Other Breach of Contract/Warranty (not fraud or negligence)
I I A6002 Collections Case-Seller Plaintiff

|g),
1..2..5. 1..2..5.
2., 5., 6. 2., 5.

"5
n

E
o

Collections (09)

I
I
I

i A6012 Other Promissory Note/Collections Case

I A6015 Insurance Coverage (not complex)
I A6009 Contractual Fraud I A6031 Tortious Interference

Insurance Coverage (18)

1., 2., 5., 8. 1,2., 3, 5.

Other Contract (37)

1..2..3., 5.
1., 2 3., 8.

I
Eminent Domain/Inverse

I A6027 Other Contract Dispute(not breach/insurance/fraud/negligence)

I A7300 Eminent Domain/Condemnation Number of parcels.

Condemnation (14)

&
p

Wrongful Eviction (33)

I i

I A6023 Wrongful Eviction Case I A6018 Mortgage Foreclosure

1 A6032 QuietTitle

2., 6. 2., 6.
2., 6.

Other Real Property (26)

I
Unlawful Detainer-Commercial

1A6060 0therRealProperry(noteminentdomain, landlord/tenant, foreclosure) I A6021 Unlawful Detainer-Commercial (notdrugs orwrongful eviction) I A6020 Unlawful Detainer-Residential (not drugs orwrongful eviction)
I A6020F Unlawful Detainer-Post-Foreclosure

2., 6.
2,6. 26.
2., 6.

(31)
Unlawful Detainer-Residential

I I
I

(32)
Unlawful Detainer-

Post-Foreclosure (34) Unlawful Detainer-Drugs (38)

1A6022 Unlawful Detainer-Drugs

2., 6.

s
LAQIV 109 (Rev. 03/11)

LAS^ Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0

Page 2 of 4

short title: International Creative Management, Inc. v. Paul

Delvecchi. Jr. __

EnfMoriscemlanRJtoeusdvivciofJwsauCldoognmisPpveantlosi

MiscelaL^1 nCotugmpyilenx r

CASE NUMBER
,

^^^^^^^^^^K^^^KChecKlonivioneli^i^i^i^i^i^i^i^i^i^i^i^i^i^i^i^i^H 1

Asset Forfeiture (05) Petition re Arbitration (11)

| A6108 Asset Forfeiture Case

2., 6.
2., 5.

|
I

| A6115 Petition to Compel/ConfirmA/acate Arbitration

I A6151 Writ - Administrative Mandamus

2., 8.
2.

Writ of Mandate (02)

I |

| A6152 Writ- Mandamus on Limited Court Case Matter J A6153 Writ- OtherLimited Court Case Review
I A6150 Other Writ /Judicial Review

2.

Other Judicial Review (39)

2,8.

Antitrust/Trade Regulation (03)

Construction Defect (10) Claims Involving Mass Tort (40)

I I I
I |

I A6003 Antitrust/Trade Regulation J A6007 Construction Defect I A6006 Claims Involving Mass Tort
I A6035 Securities Litigation Case | A6036 Toxic Tort/Environmental

1.,2.,8.
1.. 2., 3.

1., 2., 8.
1., 2., 8. 1., 2., 3., 8.

Securities Litigation (28)

Toxic Tort

Environmental (30)
o
cW

0.

Insurance Coverage Claims from Complex Case (41)

|
I
I

| A6014 Insurance Coverage/Subrogation (complex caseonly)

1
I A6141 Sister State Judgment
| A6160 Abstract of Judgment

1,2.5., 8.
2,9.
26.

Enforcement

|
I

| A6107 Confession of Judgment (non-domestic relations)

| A6140 Administrative Agency Award (not unpaid taxes)

2., 9.
2., 8.

of Judgment (20)

| A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax

2,8.

I"
RICO (27)

I A6112 Other Enforcement of Judgment Case

2., 8., 9.
1.,2.,8.

l A6033 Racketeering (RICO) Case

Other Complaints

(Not Specified Above) (42)

I | |
I

I A6030 Declaratory Relief Only | A6040 Injunctive Relief Only (not domestic/harassment) | A6011 Other Commercial Complaint Case(non-tort/non-complex)
I A6000 Other Civil Complaint (non-tort/non-complex)
| A6113 Partnership andCorporate Governance Case
| A6121 Civil Harassment | A6123 Workplace Harassment

1..2..8.
2., 8.

1.,2.,8. 1., 2., 8.

2.. 8.

Partnership Corporation
Governance (21)

|
I I

2., 3., 9.
2., 3., 9. 2., 3., 9.
2.

|
Other Petitions

| A6124 Elder/Dependent Adult AbuseCase

| A6190 Election Contest | A6110 Petition for Change of Name
I A6170 Petition for Relief from Late Claim Law
| A6100 Other Civil Petition

(Not Specified Above)

(43)

I |
|
I

2., 7.

2., 3,4., 8.
2., 9.

**

[U

LAclv"109 (Rev. 03/11)

LASC Appnived 03-04

( MVIL CASE COVER SHEET ADDENDUM

I.ocal Rule 2.0

Page 3 of 4

AND STATEMENT OF LOCATION

shorttitle: International Creative Management, Inc. v. Paul Delvecchi, Jr.

I case number

circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the courtlocation you selected.
REASON: Check the appropriate boxes for the numbers shown under Column C for the type of action that you have selected for
this case.

Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other
address: j Q250 Constellation Boulevard

CITY:

l.E2.a3O4O5O6O7.D8.a9.ni0.
STATE:
ZIP CODE:

Los Angeles

CA

90012

Item IV. Declaration ofAssignment Ideclare under penalty of perjury underthe laws ofthe State of California thai the foregoing is true

andcorrect andthatthe above-entitled matter is properly filed for assignment tothe Stanley Mosk courthouse in the CENTRAL District of the Superior Court of California, County of Los Angeles [CodeCiv. Proa, 392 et seq., and Local
Rule 2.0. subds. (b), (c) and (d)].

Dated: April 12.2012

(SlgflfTlJa^^TroRNEWlWG PARTyT"
Bryan J. Freedman

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE YOUR NEW COURT CASE:

1. Original Complaint or Petition.

2. If filing 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.
03/11).

5. Payment in full of the filing fee, unless fees have been waived.

6. Asigned orderappointing the Guardian ad Litem, Judicial Council form CIV-010, ifthe plaintiff or petitioner is a
minor under 18 years of age will 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.

i*

LACiy, 109 (Rev. 03/11)

LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0

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