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KINSELLA WEITZMAN ISER KUMP & ALDISERT LLP

GREGORY J. ALDISERT (SBN 115334)

galdisert@kwikalaw.com

808 Wilshire Boulevard, 3rd Floor

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Santa Monica, California 90401

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Facsimile: 310.566.9850

Attorneys for Plaintiff SGP ENTERTAINMENT

dba STEPHANIE GERMAIN PRODUCTIONS

Telephone: 310.566.9800

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FILED
Superior Court of California
County of Los Angeles

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FEB 04 2016
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Judi Lara

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES, CENTRAL DISTRICT

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SGP ENTERTAINMENT dba STEPHANIE

Case No.

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GERMAIN PRODUCTIONS, a California

corporation,

COMPLAINT FOR:

Plaintiff,

(1) BREACH OF WRITTEN CONTRACT;

(2) ACCOUNTING; AND
(3) DECLARATORY RELIEF

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BK PRODUCTIONS LLC, a California

limited liability company; BRK
DISTRIBUTION, LLC, a California limited

liability company; and BRADLEY KREVOY,

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an individual,

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Defendants.

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Plaintiff SGP Entertainment dba Stephanie Germain Productions alleges as follows:

INTRODUCTION

1.

This case arises out of failure of one producing partner (Bradley Krevoy) to honor

his contractual obligations to another producing partner (Stephanie Germain) in connection with

the development and production oftelevision motion pictures based on the Hannah Swensen

Mystery book series. Three Hannah Swensen films, known as Murder, She Baked titles, have

already aired on the Hallmark Movie and Mystery channel. Krevoy has repeatedly breached his

contractual obligation to reach agreement with Germain on all creative and business decisions, and

Krevoy has frequently functioned as ifhe has no producing partner at all. Krevoy has kept

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Germain in the dark on many issues and has failed to provide complete accountings to Germain.

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Because Krevoy's breaches are on-going and the production ofadditional films is also on-going,

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Germain seeks to enforce her contractual rights regarding the films already made, to obtain a

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complete accounting ofmonies in connection with all films and to obtain declaratory relief as to

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her rights and Krevoy's obligations on future productions.

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THE PARTIES

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2.

Plaintiff SGP Entertainment dba Stephanie Germain Productions ("Germain

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Productions") is a California corporation with its principal place of business located in Los

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Angeles County, California. Stephanie Germain is the owner ofGermain Productions. She has

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extensive experience in the television industry as a producer, executive producer and co-owner for

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20 years. Germain's productions include over 25 movies for television or mini-series, and an

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Emmy Award nomination. In addition, she co-produced the Showtime television series Jeremiah

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and was an executive producer on the Roland Emmerich motion picture The Day After Tomorrow.

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Plaintiff will refer to Germain Productions and Stephanie Germain collectively as "Germain"

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unless separately designated.

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3.

Plaintiffs are informed and believe that Defendant BK Productions LLC ("BK

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Productions") isa suspended California limited liability company with its principal place of

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business located in Los Angeles County, California.

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11073.00002/334700.6

1
COMPLAINT

Distribution") is a California limited liability company with its principal place ofbusiness located

in Los Angeles County, California.

owns and operates BK Productions LLC and BK Distribution LLC and serves as an agent for the

companies. Plaintiff will refer to BK Productions, BK Distribution and Bradley Krevoy

collectively as "Krevoy" unless separately designated.

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6.

Germain sues Bradley Krevoy in his individual capacity because BK Productions is

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a suspended corporation and cannot legally defend itself. Moreover, Germain is informed and

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believes that BK Productions and BRK Distribution are the alter ego of Bradley Krevoy such that

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the Court should not recognize any legal distinction between them in that (i) BK Productions and

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BRK Distribution are not adequately capitalized, (ii) BK Productions and BRK Distribution are

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merely a conduit, shell and instrumentality through which Bradley Krevoy conducts business, (iii)

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there is a unity of interests and ownership among Bradley Krevoy, BK Productions and BRK

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Distribution, and Bradley Krevoy exercises complete dominance and control over BK Productions

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and BRK Distribution such that any separateness or individuality has ceased to exist, and (iv) BK

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Productions and BRK Distribution have not followed basic corporate formalities. Adherence to

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the fiction of the separate existence of BK Productions and BRK Distribution as entities separate

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and distinct from Bradley Krevoy would permit anabuse of the corporate privilege and would

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sanction fraud and promote an injustice. Accordingly, the obligations of BK Productions and

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BRK Distribution should be treated as those of Bradley Krevoy as well.

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Plaintiffs are informed and believe that Defendant Bradley Krevoy is a resident of

Los Angeles County and that he regularly conducts business within Los Angeles County. Krevoy

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Plaintiffs are informed and believe that DefendantBRK Distribution LLC ("BK

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JURISDICTION AND VENUE

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7.

This Court has personal jurisdiction over BK Productions, BRK Distribution and

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Bradley Krevoy because (i) Bradley Krevoy isa resident ofCalifornia, and he and BK Productions

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and BRK Distribution conduct business within California; and (ii) the term sheet agreement dated

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May 14, 2014 provides for the exclusive jurisdiction and venue to be the Los Angeles Superior

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Court for any dispute arising thereunder.

11073.00002/334700.6

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COMPLAfNT

8.

Venue is proper in Los Angeles County in accordance with Section 395(a) ofthe

California Code of Civil Procedure because Bradley Krevoy resides in this county, BRK

Distribution does business in this county, and the term sheet agreement provides for Los Angeles

County as the exclusive venue for litigation.

BACKGROUND FACTS

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9.

Germain first met Krevoy in the Fall of 2014. After discussing various projects,

Germain suggested they work together on a pilot for a television series based on the published

Hannah Swensen Mystery book series written by best-selling author Joanne Fluke. They

ultimately decided to produce a series of"Movies ofthe Week" ("MOW's") based on this book

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series for broadcast on the Hallmark Murder and Mystery channel. There are approximately 20

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published books in the series. Crown Media United States LLC ("Crown Media") owns the

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Hallmark Murder and Mystery channel which broadcasts original content series and motion

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pictures, among other content.

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A.

The Agreement Between Germain and Krevoy

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10.

Germain and Krevoy entered into a written Term Sheet dated May 14, 2014 (the

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"Agreement"). Pursuant to the Agreement, the parties would develop and produce up to three

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MOW's based on the Hannah Swensen Mystery book series to be broadcast by the Hallmark

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network (the "Project"). Agreement, Recital \ B. Germain and Krevoy were to form a new entity

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and each would own a 50% interest in that entity (the"Company"), and the Company would

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acquire the rights to three books and hold the copyright to the MOW's. Agreement, U2.

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Under the Agreement, "[the parties] agreed to consult with each other with respect

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to all proposed material creative and business decisions concerning the Project and the Company,

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provided final decision making authority on all such matters will be determined by

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unanimity..." Id.,\ 3.

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12.

Under the Agreement, the parties were to "share equally all fees, profits and any

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other revenues derived by and actually received by [the new entity]...." Id., 14. The budget for

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each MOW would include producer fees of $125,000 to Germain and Krevoy each.

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11073.00002/334700.6

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COMPLAfNT

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Krevoy was to be responsible for all costs associated with procuring the rights,

financing the development and production ofthe Project and forming and operating the Company.

Agreement, \ 5. As for overhead, the parties agreed "neither ofthem shall be entitled to charge

percentage overhead or other flat overhead to the cost ofproduction orotherwise as recoupable

expense, but mutually approved actual overhead costs shall be allowable." Agreement, \ 5.

Krevoy could recoup allowable overhead costs out ofthe approved budget and profits from the

Project so long as they were reasonable and approved by Germain. Id.

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14.

The Agreement provided: "[Germain] shall have final approval over the terms of

any producing services Stephanie Germain provides in connection with the Project, including

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without limitation, extent of services, location of services, and exclusivity." Agreement, \ 3.

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Under the Agreement, each party was to receive production company credits and

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logo credits and Germain and Krevoy would receive separate card executive producer credits.

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comply with Paragraph 7 as follows: "The terms ofthis Agreement apply solely to the first three

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MOW's comprising the Project, and if there are anyfurther productions proposed or

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contemplated based on the Books, the parties will negotiate in good faith as to applicable

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terms, and if they do not reach agreement, then neither party shall be entitled to proceed

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with any further production(s) based on the Books." Id.

Pursuant to the Agreement, Krevoy and Germain were specifically obligated to

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17.

Pursuant to the Agreement, Germain and Krevoy agreed to form a California

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limited liability company called Swensen Productions LLC ("Swensen"). Krevoy sent a proposed

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written operating agreement. Germain's counsel provided comments to the agreement, but the

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parties never reached agreement onall material terms and no operating agreement was ever

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signed. Krevoy caused Swensen to be formed as a Louisiana limited liability corporation with

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Krevoy and Germain as 50-50 owners.

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B.

The Agreements With Crown Media

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18.

On behalfof Swensen, Krevoy negotiated an agreement with Crown Media dated

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as ofApril 2, 2014 whereby Swensen agreed to develop three teleplays based on the Hannah
11073.00002/334700.6

4
COMPLAINT

Swensen Mystery book series ("Crown Media Development Agreement"). Under the Crown

Media Development Agreement, Crown Media had three separate options to license up to three

additional films per option exercisable by written notice to Swensen. Accordingly, Crown Media

had the ability to license up to twelve films in total.

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The agreements were to be structured so that Swensen, co-owned 50/50 by

Germain and Krevoy, acquired the rights to make the Hannah Swensen MOWs and Swensen

licensed these rights to Crown Media. Accordingly, Germain and Krevoy, through Swensen, were

to co-own the rights to the films being broadcast by the Hallmark Murder and Mystery channel.

19.

20.

The first film was Murder She Baked: A Chocolate Chip Cookie Mystery

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("Chocolate Chip"), which was based on the first Hannah Swensen book. Crown Media entered

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into a Production and License Agreement with Swensen and Krevoy's distribution company BRK

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Distribution LLC dated as of February 2, 2014 for the Chocolate Chip film ("Production and

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License Agreement").

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Under the Production and License Agreement, Crown Media was to pay a license

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fee to Swensen in installments over the course of production and final delivery. Swensen was to

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pay all costs and expenses in connection with the production and delivery of the film. Crown

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Media had the right to approve many aspects of production and post-production. The film had to

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be delivered to Crown Media at least 90 days prior to the anticipated first public exhibition.

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Plaintiffs are informed and believe that Crown Media entered into similar

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production license agreements for each subsequent Hannah Swensen MOW. Germain did not
receive copies ofthe production license agreements for the first two motion pictures until long
after they were signed, and as such, Krevoy prevented Germain from reviewing and commenting

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on the agreements before they were signed. Although Germain did see drafts ofthe licensing

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agreement for the third production, Krevoy rejected her comments, and never provided afinal

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version to her.

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23.

Notwithstanding the fact that Crown Media licensed the rights to make motion

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pictures based on specific Hannah Swensen titles, Krevoy attempted to interchange titles and

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scripts and took a cavalier approach to the author's books.

11073.00002/334700.6

5
COMPLAINT

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24.

Crown Media received the right to exploit the film domestically in all media. BRK

Distribution entered into separate distribution agreements with Sony Pictures Television Inc. to

distribute the Hanna Swensen films in international markets.

C.

Krevoy Breaches the Agreement Between Germain and Krevoy

25.

Krevoy largely excluded Germain from the budgetary process for making

Chocolate Chip, and submitted the budget to the Hallmark network before Germain even saw the

budget. As aresult, Germain could not pursue savings in the budget as she has customarily done

on many of her past productions not involving Krevoy.

26.

The Agreement addressed overhead as follows: "Neither of[Krevoy and Germain]

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shall be entitled to charge percentage overhead or other flat overhead to the cost ofproduction or

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otherwise as recoupable expense, but mutually approved actual overhead costs shall be allowable."

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Agreement, \ 5. Nonetheless, Krevoy unilaterally added an 8% overhead allowance to the budget

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for BK Productions on the Chocolate Chip budget, which had a roughly $2.5 million budget. This

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overhead figure was inflated, and Germain refused to approve this overhead allowance. Krevoy

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subsequently offered to reduce the overhead figure on Chocolate Chip to $50,000, which Germain

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again did not approve. For the next film, Krevoy proposed an $80,000 overhead allowance for BK

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Productions and again offered to reduce the number to $50,000. Germain again did not approve

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the $50,000 allowance for the second film. Germain incurred overhead in connection with her

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services, but she never asked for an overhead allowance.

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The first MOW Chocolate Chip was shot in February and March 2015. Krevoy

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failed to render producer services on the set ofChocolate Chip. When Krevoy did appear on set,

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his presence was disruptive. Krevoy attempted unilaterally to cut scenes, ridiculed and advised

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against acceptance ofnetwork notes, and attempted to put his friends' kids in the film as walk-ons.

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Germain rendered additional services as a creative producer, even though she never agreed in

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advance to serve in this role and was not being paid to do so.

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Chocolate Chip first aired on May 2, 2015. At the time, it had the highest ratings

everfor a Hallmark Murder and Mystery channel MOW.

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11073.00002/334700.6

COMPLAINT

disrespected and bullied Germain.

additional role ofcreative producer for much of the Plum Pudding production without additional

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Krevoy once again failed to render his producer services on the set of Plum

Pudding and was only on the set for approximately 24 hours. Germain once again fulfilled the

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The second MOW was based on the book, APlum Pudding Murder Mystery

("Plum Pudding"). Krevoy continued to cause similar types of problems on the development and
production of Plum Pudding. Krevoy was generally dismissive of the author's material. Krevoy
again attempted to disregard the network notes on the script on set. He insulted cast and crew, and

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Plum Pudding was shot in May 2015. It first aired on November 21, 2015 and had

excellent ratings.

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For Plum Pudding, Krevoy was responsible for paying the book author Joanne

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Fluke no later than the commencement ofprincipal photography. In violation ofMs. Fluke's

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contract, she was not paid until after the filming was completed and thus without timely exercise

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of the option to exploit the Plum Pudding book and without proper acquisition of the rights.

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Krevoy was responsible for securing "Errors and Omissions" insurance coverage

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for each MOW production. Germain recently learned that Krevoy had failed to secure errors and

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omissions insurance coverage until halfway through the production for Chocolate Chip. For Plum

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Pudding, Krevoy did not secure insurance coverage until after the filming was already completed.

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34.

The third motion picture was Murder, She Baked: APeach Cobbler Murder

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Mystery ("Peach Cobbler"). Krevoy hired anew writer, Teena Booth, to draft the Peach Cobbler
teleplay without obtaining Germain's approval. Krevoy also hired anew casting director for

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Peach Cobbler without obtaining Germain's approval. Krevoy submitted a treatment (asummary

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of the script to be written) to Hallmark for Peach Cobbler without obtaining Germain's approval.

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In each instance, Krevoy violated Paragraph 3ofthe Agreement that all business and creative

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decisions were to be madejointly and required unanimity.

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11073.00002/334700.6

COMPLAINT

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Acreative producer was hired for this production, and there were fewer problems on the set

involving Krevoy. Peach Cobbler aired on January 10, 2016.

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Hallmark and Germain had approved the credits for Peach Cobbler. After they did

so, Krevoy unilaterally changed the screen credits for Peach Cobbler without the knowledge or

approval ofHallmark and Germain, and provided a"co-executive producer" credit for an

employee of Krevoy (Amanda Phillips Atkins), a"business consultant" credit for another Krevoy

employee (Eric Jarboe), and aproducing credit for someone whom Germain never met and who

never fulfilled any producing functions (Sean O'Reilly). Germain asked that these credits be

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removed, and Krevoy has refused to do so. Peach Cobbler aired in the United States with these

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unauthorized credits.

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Peach Cobbler was shot in Vancouver, British Columbia during November 2015.

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During 2015, Germain and her counsel made repeated requests to Krevoy that he

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honor his contractual obligation to provide Germain with pertinent contracts and other documents

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to enable Germain to fulfill her role.as co-owner and producer of the Project. Nonetheless,

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Krevoy refused to do so. Krevoy did not provide certain documents to Germain until after

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Chocolate Chip had already aired and after Plum Pudding was filmed. To date, Krevoy has failed

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to provide complete accountings of revenues and expenses for each ofthe MOW's to his co-owner

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despite repeated requests by Germain and her counsel.

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damaged Germain's reputation.

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Krevov Refuses to Negotiate in Good Faith a New Agreement With Germain

and Unilaterally Proceeds with Future Productions

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Krevoy's failure to comply with third party contract obligations and other conduct

39.

The Agreement provided that "ifthere are any further productions [beyond the

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three MOW] proposed or contemplated based on the Books," Krevoy and Germain had to

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negotiate new terms in good faith for future productions, and "ifthey do not reach agreement, then

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neither party shall be entitled to proceed with further production(s) based on the Books."

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Agreement, ^| 7.

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COMPLAINT

Germain attempted to negotiate in good'faith with Krevoy the terms for a new

agreement covering the fourth Hannah Swensen MOW and beyond. Germain made multiple

proposals to Krevoy. Some ofher proposed terms were designed to improve the MOW's, such as

including the continuing obligation to hire athird party creative producer. Some were designed to

increase Krevoy's transparency. Some were to ensure that Germain would be involved in

decision-making on business issues. Krevoy ignored or rejected all orvirtually all ofthese terms

and Germain believes that Krevoy did so in order to eliminate his accountability and avoid his

obligations as a producer.

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41.

Krevoy violated Paragraph 7 ofthe Agreement by pursuing a fourth (and fifth)

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motion picture during the Summer and Fall of2015 without reaching an agreement with Germain

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for these MOW's. Notwithstanding Germain's insistence that Krevoy comply with Paragraph 7

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and reach a new agreement with her, Krevoy proceeded with development for a fourth MOW. For

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example, by email dated November 10, 2015, Krevoy wrote to the lead actor about scheduling

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issues "[a]s we plan for the next four movies next year ..."

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42.

Germain's latest proposal to Krevoy regarding new terms - - made after several

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others were ignored - - was made by email dated January 6, 2016 from her counsel. Germain's

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counsel even offered to meet with Krevoy or his representative to discuss the proposal at their

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convenience, and requested a response by January 15, 2016. Krevoy never responded to the

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invitation from Germain's counsel.

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43.

Germain intends to produce future MOW's in the series, and has cooperated in the

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development ofthe fourth MOW even without an agreement between her and Krevoy on the

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fourth MOW and beyond. In doing so, however, Germain has not waived her rights to seek

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damages for Krevoy's breach of Paragraph 7 of the Agreement.

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FIRST CAUSE OF ACTION

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(Breach of Written Contract Against BK Productions and Bradley Krevoy)

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44.

The allegations ofParagraphs 1through 43 are realleged and incorporated herein

by reference.

45.

The Agreement is a legally enforceable contract.

11073.00002/334700.6

Q
COMPLAINT

46.

Krevoy breached the Agreement, among other ways, as follows:

Krevoy failed to render producer services on the Hannah Swensen MOW's.

Krevoy failed to consult with and obtain Germain's approval on many business
and creative decisions in violation of Paragraph 3 of the Agreement.

Krevoy failed to provide to Germain, who was a 50/50 co-owner of the Project,

complete accountings and provide all pertinent documents.

Krevoy included an improper overhead allowance for Chocolate Chip and Plum

Pudding that Germain has not approved in violation of Paragraph 5 ofthe

Agreement.

Krevoy unilaterally imposed screen credits that Germain disapproved (and that

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Crown Media did not approve) in violationof Paragraph 8 the Agreement as

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amended.

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Krevoy failed to have the book rights timely paid, for in violation of Paragraph

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2 of the Agreement.

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Krevoy failed to secure errors and omissions insurance coverage in timely

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Krevoy is proceeding with a fourth MOW and additional productions without

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first reaching agreement with co-owner Germain in violation of Paragraph 7 of

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the Agreement.

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Germain in violation of Paragraph 4 of the Agreement.

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Germain believes that Krevoy has not paid and will not pay amounts owed to

47.

Germain is informed and believes that Krevoy has committed other breaches of the

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Agreement that Germain is currently unaware of and that Krevoy will continue to breach the

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Agreement regarding existing and future MOW's.

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48.

Germain has performed all or substantially all of her obligations required under the

Agreement except for those obligations that Germain was excused from performing.
49.

As a result of Krevoy's breaches, Germain has suffered compensatory damages in

an amount to be proven at trial.

11073.00002/334700.6

}Q
COMPLAINT

SECOND CAUSE OF ACTION

(Accounting Against all Defendants)

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Under the Agreement, Krevoy and Germain are 50-50 owners ofSwensen and are

to amounts owed to her under the Agreement. Moreover, an accounting is appropriate based on

the nature.of the relationship between Krevoy and Germain as co-owners ofthe Project.

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52.

The balance due from Krevoy to Germain cannot be readily ascertained without an

accounting.

53.

Germain seeks a complete accounting as to all revenues paid or owed to BK

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Productions, Bradley Krevoy, BRK Distribution, Swensen and all other entities owned or

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controlled by Bradley Krevoy (collectively, "Krevoy Entities") and all expenses paid or owed by

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the Krevoy Entities for each Hannah Swensen MOW. Germain also seeks an order requiring BK

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Productions, BRK Distribution and Bradley Krevoy to pay all monies due to Germain, either

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directly through the Agreement or as a member of Swensen.

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to split profits equally (among other terms). Accordingly, Germain is entitled to an accounting as

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The allegations ofParagraphs 1through 43 are realleged and incorporated herein

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THIRD CAUSE OF ACTION

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(Declaratory Relief Against all Defendants)

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54.

The allegations ofParagraphs 1through 43 are realleged and incorporated herein

by reference.

55.

Because the Hannah Swensen MOW's continue to be ordered to production by

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Crown Media, an actual and judiciable controversy has arisen and now exists between Germain

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and Krevoy over 1) whether Krevoy must comply with the contract term requiring them to reach

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agreement on all material creative and business decisions pertaining to each existing and future

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MOW, and 2) whether Germain is entitled to a complete accounting from the Krevoy Entities for

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all existing and future Hannah Swensen Mystery series MOW's.

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28

56.

Germain seeks ajudicial declaration that (i) Krevoy must reach agreement with

Germain regarding all material creative and business decisions pertaining to all existing and future
11073.00002/334700.6

II
COMPLAINT

Hannah Swensen MOW's; (ii) Germain must receive advance notice from Krevoy of all potential

contracts involving the Project and the Company and have a reasonable opportunity to provide her

input into the decision-making and negotiation process for all such contracts; (iii) Krevoy must

notify all third parties in advance that Germain must approve all creative and business decisions

for all contracts involving the Project and the Company; and (iv) Krevoy must provide Germain

with a complete and timely accounting from the Krevoy Entities for all existing and future

MOW's and pay all monies owed to Germain, either directly through the Agreement or as a

member of Swensen. Germain's position is that Krevoy has breached the contract terms requiring

Germain's agreement on all business and creative decisions and requiring Krevoy to provide

10

complete accountings and that Krevoy will continue to breach these contract terms in the future.

11

Germain believes that Krevoy's position is that he either does not need to comply with these

12

contract terms given that three MOW's have been made or that he has complied with these terms

13

in the past so no judicial declaration is necessary for future productions.

CO
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in

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<a U. O CD
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CO < o

M$ 2 S
a

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14

57.

A judicial declaration is necessary and appropriate under the circumstances so that

15

the parties may ascertain their rights and duties and so as to avoid the need for multiple lawsuits

< in

16

regarding whether these contract terms apply and whether Krevoy has breached them.

a 29 <

17

ju 5 CO

JO)

N! ^

< T O '

CO

PRAYER FOR RELIEF

-J

18

Wherefore, Germain prays as follows:

CO

19
20
21

1.

For the First Cause of Action, compensatory damages in an amount according to

proof at trial;

2.

For the Second Cause of Action, a complete accounting of all revenue received or

22

owed and expenses paid or owed in connection with each of the Hannah Swensen MOW's and an

23

order requiring payment of all monies due to Germain, either directly through the Agreement or as

24

a member of Swensen;

25

3.

For the Third Cause of Action, a judicial declaration that (i) Krevoy must reach

26

agreement with Germain regarding all material creative and business decisions pertaining to all

27

existing and future Hannah Swensen MOW's; (ii) Germain must receive advance notice from

28

Krevoy of all potential contracts involving the Project and the Company and have a reasonable
11073.00002/334700.6

]2
COMPLAINT

opportunity to provide her input into the decision-making and negotiation process for all such

contracts; (iii) Krevoy must notify all third parties in advance that Germain must approve all

creative and business decisions for all contracts involving the Project and the Company; and (iv)

Krevoy must provide Germain with a complete and timely accounting from the Krevoy Entities

for all existing and future MOW's and pay all monies owed to Germain, either directly through the

Agreement or as a member of Swensen;

4.

For costs of suit herein incurred; and

5.

For such other and further relief as this Court deemsjust and proper.

9
c_:

10

in

co

11

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CD
^ q 0) in

12

DATED: February 4, 2016

KINSELLA WEITZMAN ISER

KUMP & ALDISERT LLP

; CO < b'
Ogccn

13

5<25
a

3U

By:
14

Gregory J. Aldisert
Attorneys for Plaintiff SGP ENTERTAINMENT

15
N 5 < in

dba STEPHANIE GERMAIN PRODUCTIONS

16

;- z"o
a g < n

<

00

17

-J

18
CO

19

20
21

22

23
24
25
26

27
28
Ji
11073.00002/334700.6

_13_
COMPLAINT

CM-PIP,

ATTORNEY ORPARTY WITHOUT ATTORNEY (Name. St^Kar

St&WBar number, andaddress):

FOR COURT USE ONLY

"Gregory J. Aldisert (SBN 115334)

Kinsella Weitzman Iser Kump & Aldisert LLP
808 Wilshire Blvd.,

3rd Fl.

FILED

Santa Monica, California 90401

telephone no.: (310) 566-9800
faxno.:

Superior Court of California

(310)

County of Los Aneeles

566-9850

attorney for (Name): Plaintiff SPG Entertainment

SUPERIORCOURT OF CALIFORNIA, COUNTY OF LOS ANGELES
streetaodress: 111 North Hill Street
MAILING AODRESS:

city and zip code: Lo s Angeles,

She

CA 90012

FEB 04 2016
rriK.C^^.MixecuUve Officer/Clerk
'/^

BRANCH NAME: CENTRAL

case name:

.Deputy

Judi Lavs*

SPG Entertainment v. BK Productions LLC,

BRK Distribution LLC and Bradley Krevov

Complex Case Designation

CIVIL CASE COVER SHEET

1 x i Unlimited
(Amount

ILimited
(Amount

I Counter

CASE NUMBER:

I Joinder

BC * 0 9 ft 2 6

JUDGE:
Filed with first appearance by defendant
(Cal. Rules of Court, rule 3.402)
DEPT
Items 1-6 below must be completed (see instrvctions on page 2).
1. Check one box below for the case type that best describes this case:

demanded

demanded is

exceeds $25,000) $25,000 or less)

Auto Tort

Contract

I
I

IAuto (22)
IUninsured motorist (46)

IAsbestos (04)

IX
I
I
I
I

IProduct liability (24)

Real Property

IMedical malpractice (45)

IOther PI/PD/WD (23)

Other PI/PD/WD (Personal Injury/Property

Damage/Wrongful Death) Tort

Non-PI/PD/WD (Other) Tort

Provisionally Complex Civil Litigation

(Cal. Rules of Court, rules 3.400-3.403)

IBreach ofcontract/warranty (06)

IRule 3.740 collections (09)
IOther collections (09)
IInsurance coverage (18)
IOther contract (37)
I Eminent domain/Inverse

I
I
I

I Antitrust/Trade regulation (03)

I Construction defect (10)
I Mass tort (40)

1
I
I

I Securities litigation (28)

1 Environmental/Toxic tort (30)

I Insurance coverage claims arising from the

condemnation (14)

above listed provisionally complex case

IWrongful eviction (33)

types (41)

I IBusiness tort/unfair business practice (07) lZ3 other real property (26)

Enforcement of Judgment

ICivil rights (08)

Unlawful Detainer

IDefamation (13)

ICommercial (31)

Miscellaneous Civil Complaint

IFraud (16)

IResidential (32)

I RICO (27)

I
I

IIntellectual property (19)

IProfessional negligence (25)

IDrugs (38)

I Other complaint (not specified above) (42)

Judicial Review

Miscellaneous Civil Petition

IOther non-PI/PD/WD tort (35)

IAsset forfeiture (05)

I
I
I

IPetition re: arbitration award (11)

i Writ of mandate (02)
IOther judicial review (39)

I
I

Employment

IWrongful termination (36)

IOther employment (15)

2. This case

IZZD is

I Enforcement ofjudgment (20)

i Partnership and corporate governance (21)

I Other petition (not specified above) (43)

EjTjisnot complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the

factors requiring exceptional judicial management:

a. I
b. I

I Large number ofseparately represented parties d. I

1Extensive motion practice raising difficult ornovel e. I

I Large number ofwitnesses

I Coordination with related actions pending in one ormore courts

issues that will be time-consuming to resolve

c. CZ) Substantial amount of documentary evidence

in other counties, states, or countries, or in a federal court

f. CZ\ Substantial postjudgment judicial supervision

3. Remedies sought (check all that apply): a. I x I monetary b. I x Inonmonetary; declaratory or injunctive relief c. I

I punitive

4. Number of causes of action (specify): 3

51-This case I I is I x I is not
a class action suit.

61 .ff there are any known related cases, file and serve a notice of related case. (
Date: February 4,

2016

ay use form CM-015.)

Gr.eaory J. Aldisert (SBN 115334)

(TYPE OR PRINT NAME)

.4:-

(SIGNATURE OF PARTYOR ATTORNEY FOR PARTY)

NOTICE

Plaintiff mustfile this cover sheet with the first paper filed in the action or proceeding (exceptsmallclaimscases or cases filed

under the Probate Code, Family Code, orWelfare and Institutions Code). (Cal. Rules ofCourt, rule 3.220.) Failure tofile may result

i. in sanctions.

File this cover sheet in addition to any cover sheet required by local court rule.

i.:lf this case iscomplex under rule 3.400 et seq. oftheCalifornia Rules of Court, you must serve a copy ofthis cover sheet on all
i_,:pther parties to the action or proceeding.

Unless this isa collections case under rule 3.740 or a complex case, this cover sheetwill be used for statistical purposes only.
-'"
Form Adopted lor Mandatory Use
Judicial Council of California

CM-O10(Rev. July 1.2007]

Page 1 of 2

CIVIL CASE COVER SHEET.

ilUUQ]tj-,cSoiuC
US

Cal. Rules of Court, rules 2.30. 3.220. 3.400-3.403, 3.740;

Cal. Standards ofJudicial Administration, sld. 3.10

INSTRU<)NS ON HOW TO COMPLETE THE COA SHEET

CM-010

^mnHJS f,nd thersiilin3 fFirs* Papers. If you are filing a first paper (for example, a complaint) in a civil case vou must

complete and file along with your first paper, the Civil Case Cover Sheet contained on page 1 This information w5 be used to comS

oSK iKSSiJK;TiTlT
IT filed- YU mUSt Cmple,e i,emS 1,hrOU9h 6on ,he sheet- " 1you muS CS
/Pe <ha ,b6St deSCnbeS the case- lf ,he case fi,s b0,h aSeneral and amore specific type of case listed in tern 1

rZllZi
To cf

6spec,"c,one' 'f the case has 'P'e causes of action, check the box that best indicates the primary cause of actTon'
ILT
\k
nTP
nguthC
of ,hetocases
that belon9
below oaSH
Acover
sheet must be filed
onlyet'with
yourSheet'
initialeXamples
paper. Failure
file acover
sheet und^
with theeach
firstcase
papertype
filedininitem
acivil1are
casep2d
maysubkSa

counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court

V J

P V'

,Tna?ume,SJllH i!!6h!'74S Co'!ec(tions ,Cases" UA "collections case" under rule 3.740 is defined as an action for recovery of money owed

h? if

ertam th3t 'S n0t mre than $25'000' exclusive of interest and attorney's fees, arising from atransaction in wrvlch

damS; ^nrrHmney wasac(*uired on credit' Acollections case does not include an action seekmg the ic Sing(1?5

The
dentifc S
^^
f PerSna'
r (5> a^
writtime-for-serviee
of attachment
me laeniincation
of a tZTa
case as a rll^/cZlT
rule 3.740 collections
case on^T^
this form means
that itprperty'
will be exempt
from the qeneral
requirements
and
case
management
rules,
unless
adefendant
files
aresponsive
pleading.
A
rule
3740^J^JSl!SiS
suSect
to the requirements for service and obtaining a judgment in rule 3.740.
^
a
v w leuiwis case win De suoject
Iase isrtcoSmiDn|e<x0^n.Xa,n,affVLJ?
TPl8X
aSeS n'y' P3rtieS mUSt alS0 USe the C/V// Case Cover Sheet to designate whether the
P. u
,he ^ ,S C0mplex under rule 3400 of the California Rules of Court, this must be indicated bv

L3

comS9on
h^"
t^ ,fmaV
aP'afi|intiff
desi9nates
as comP|
e*'theof cov*r
muTtbe ajoindeT
serleTw thnthe
the
nfaTnSTw anS?
f St0' th.6
l01'0"'"TJ
Adefendant
e and
serve noacase
later than
the time
its first^heet
appearance

the
molex0, "COUn,er-desi9nation that ,he case is "* mp.. or, if the plaintiff has made no designation adeSaton hat
the casi.
case is c'
complex.
CASE TYPES AND EXAMPLES

Auto Tort

Contract

Auto (22)Personal Injury/Property

DamageArVrongful Death

Uninsured Motorist (46) (ifthe

case involves an uninsured

motorist claimsubjectto
arbitration, check this item

instead of Auto)

Other PI/PD/WD (Personal Injury/

Property Damage/Wrongful Death)
Tort

Asbestos (04)

Asbestos Property Damage

Asbestos Personal Injury/
Wrongful Death

Product Liability (nor asbestos or

toxic/environmental) (24)
Medical Malpractice(45)
Medical Malpractice-

Physicians &Surgeons
Other Professional Health Care
Malpractice

Other PI/PDA/VD (23)

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

IntentionalBodily Injury/PD/WD
(e.g., assault, vandalism)
Intentional Infliction of
Emotional Distress

Negligent Infliction of
Emotional Distress
Other PI/PDA/VD

Non-PI/PD/WD (Other) Tort

Business Tort/Unfair Business
,.-, Practice (07)

Civil Rights(e.g., discrimination,

i'V false arrest) (notcivil
harassment) (08)

Defamation (e.g., slander, libel)

<;? d3)
Fraud (16)

Intellectual Property (19)

Professional Negligence (25)

i Legal Malpractice
<v Other Professional Malpractice
,-;,

(not medical or legal)

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

Employment

Wrongful Termination (36)

Oilier Employment (15)

CM-O10 [Rsv. July 1. 2007]

Breach ofContract/Warranty (06)

Breach of Rental/Lease

Contract (not unlawfuldetainer

or wrongfuleviction)

ContractArVarranty BreachSeller
Plaintiff (not fraud ornegligence)
Negligent Breach of Contract/
Warranty

OtherBreach of ContractWVarranty
Collections (e.g., money owed, open
book accounts) (09)
Collection CaseSeller Plaintiff

Other Promissory Note/Collections

Case

Insurance Coverage (not provisionally

complex) (18)

Auto Subrogation
Other Coverage
Other Contract (37)
Contractual Fraud

Other Contract Dispute

Real Property
Eminent Domain/Inverse

Condemnation (14)
Wrongful Eviction (33)

Other Real Property (e.g., quiettitle) (26)

Writ of Possession of Real Property
Mortgage Foreclosure
Quiet Title

Other Real Property (not eminent

domain, landlord/tenant, or
foreclosure)
Unlawful Detainer

Commercial (31)
Residential (32)

Drugs (38) (ifthe case involves illegal

drugs, check this item; otherwise,
report as Commercial or Residential)
Judicial Review

Asset Forfeiture (05)

Petition Re: Arbitration Award (11)

Writ of Mandate (02)
Writ-Administrative Mandamus
Writ-Mandamus on Limited Court
Case Matter

Writ-Other Limited Court Case

Review

Other Judicial Review (39)

Review of Health Officer Order
Notice of Appeal-Labor

Commissioner Appeals

CIVIL CASE COVER SHEET

Provisionally Complex Civil Litigation (Cal.

Rules of Court Rules 3.400-3.403)
Antitrust/Trade Regulation (03)
Construction Defect (10)
Claims Involving Mass Tort (40)
Securities Litigation (28)
Environmental/Toxic Tort (30)
Insurance Coverage Claims

(arising from provisionally complex

case type listed above) (41)

Enforcement of Judgment
Enforcement of Judgment (20)
Abstract of Judgment (Out of
County)

Confession of Judgment (nondomestic relations)

Sister State Judgment

Administrative Agency Award

(not unpaid taxes)

Petition/Certification of Entry of
Judgment on Unpaid Taxes

Other Enforcement of Judgment

Case

Miscellaneous Civil Complaint

RICO (27)

Other Complaint (not specified

above) (42)

Declaratory ReliefOnly
Injunctive Relief Only (nonharassment)
Mechanics Lien

Other CommercialComplaint
Case (non-tort/non-complex)
Other Civil Complaint
(non-tort/non-complex)
Miscellaneous Civil Petition

Partnership and Corporate

Governance (21)
Other Petition (notspecified
above) (43)
Civil Harassment

Workplace Violence

Elder/Dependent Adult
Abuse

Election Contest

Petition for Name Change

Petition for Relief from Late
Claim

Other Civil Petition

Page J of J

short title: spg Entertainment v. BK Productions, et al.

CASE NUMBER

BC * 0 9 * 2 6
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 2.3 in all new civil case filings in the Los Angeles Superior Court.
Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:

JURY TRIAL? QDYES CLASS ACTION?

YES LIMITED CASE?

YES TIME ESTIMATED FOR TRIAL5

I 1HOURS/flH DAYS

Item II. Indicate the correct district and courthouse location (4 steps - 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 case type 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 2.3.

Applicable Reasons for Choosing Courthouse Location (see Column Cbelow)

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

Z. May be filed incentral(othercounty, or no bodily injury/property damage)

6. Location of property or permanently garaged vehicle

3. Location where cause of action arose.

4. Location wherebodily injury, death or damage occurred.

5. Location where performance required or defendant resides.

8. Location wherein defendant/respondent functions wholly.

7. Location where petitioner resides.

9. Location where one or more of the parties reside.

10. Location of Labor Commissioner Office

11. Mandatory Filing Location (Hub Case)

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

Category No.
r
o

Auto (22)

C Applicable

Type of Action

Reasons See Step 3

(Check only one)

Above

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

1.,2., 4.

1A7110 Personal Injury/Property Damage/Wrongful Death - Uninsured Motoris

1,2,4.

I A6070 Asbestos Property Damage

Uninsured Motorist(46)

<

Asbestos (04)
r

LJ A7221 Asbestos - Personal Injury/Wrongful Death

.2
75

Product Liability (24)

<u

I 1A7260 Product Liability (not asbestos or toxic/environmental)

1., 2.,3.,4.,8.

"5.
c

.-8
-o

Other Personal
E

,o

Medical Malpractice (45)

Injury Properly
Damage Wrongful
Death (23)

L_J A7210 Medical Malpractice - Physicians &Surgeons

1,4.

I A7240 Other Professional Health Care Malpractice

1,4.

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

1.,4.

1..3.

assault, vandalism, etc.)

1A7270 Intentional Infliction of Emotional Distress

I 1A7220 Other Personal Injury/Property DamageA/Vrongful Death

LACIV 109 (Rev 3/15)
LASC Approved 03-04

1,4.

I 1A7230 Intentional Bodily Injury/Property DamageAA/rongful Death (e.g

CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION

1., 4.

Local Rule 2.3

Page 1 of 4
LA-CV109

SHORT TITLE:

I*

I*

SPG Entertainment v. BK Productions, et al.

casenumber

C Applicable

Civil Case Cover Sheet

Type of Action

Reasons - See Step 3

Category No.

(Check only one)

Above

Business Tort (07)

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

1.,3.

Civil Rights (08)

I A6005 Civil Rights/Discrimination

1.,2.,3.

Defamation (13)

I A6010 Defamation (slander/libel)

1..2..3.

co

Fraud (16)

I A6013 Fraud (no contract)

1,2,3.

I A6017 Legal Malpractice

1., 2., 3.

I A6050 Other Professional Malpractice (not medical or legal)

1..2..3.

Other (35)

I A6025 Other Non-Personal Injury/Property Damage tort

2,3.

Wrongful Termination (36)

I A6037 Wrongful Termination

1.,2.,3.

Other Employment (15)

I
I

I A6024 Other Employment Complaint Case

I A6109 Labor Commissioner Appeals

10.

~
*- a>

O-

Professional Negligence (25)

c
41

E
>>

o
a.

E
LU

12.,3.

A6004 Breach ofRental/Lease Contract (not unlawful detaineror wrongful

eviction)

I
I

Breach of Contract/ Warranty

(06)
(not insurance)

Collections (09)
C

Insurance Coverage (18)

Other Contract (37)

2., 5.

I A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence)

I A6019 Negligent Breach ofContractA/Varranty (no fraud)

1.,2.,5.

I x I A6028 Other Breach ofContractA/Varranty (not fraud or negligence)

1,2,5.

2., 5., 6, 11

I A6002 Collections Case-SellerPlaintiff

I
i

I A6012 Other Promissory Note/Collections Case

I A6034 Collections Case-Purchased Debt (Charged Off Consumer Debt
Purchased on orafter January 1, 2014)

I A6015 Insurance Coverage (not complex)

1.,25., I

I A6009 Contractual Fraud

1..2..3., 5.

I A6031 Tortious Interference

2., 5, 11
5, 6, 11

1., 2.,3 5.

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

Eminent Domain/Inverse

2,5.

1..2, 3, 8.

Condemnation (14)

I A7300 Eminent Domain/Condemnation

Number of parcels

Wrongful Eviction (33)

I A6023 Wrongful Eviction Case

2,6.

I A6018 Mortgage Foreclosure

2., 6.

I A6032 QuietTitle

2., 6.

i A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure)

2., 6.

IA6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction)

2., 6.

I A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction)

2., 6.

Post-Foreclosure (34)

i A6020F Unlawful Detainer-Post-Foreclosun

2., 6.

Unlawful Detainer-Drugs (38)

[ A6022 Unlawful Detainer-Drugs

2., 6.

t
a

4)

or

Other Real Property (26)

Unlawful Detainer-Commercial

(31)
Unlawful Detainer-Residential

(32)
Unlawful Detainerc

LACIV 109 (Rev 3/15)

LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION

Local Rule 2.3

Page 2 of 4

Miscelanous CPeitvonls

short title: SPG Entertainment v. BK Productions, et al.

A
Civil Case Cover Sheet

Petition re Arbitration (11)

\_3 A6115 Petition to Compel/ConfirmA/acate Arbitration

>

cc

2,6.
2,5.

I 1A6151 Writ -Administrative Mandamus

I ...J A6152 Writ - Mandamus on Limited Court Case Matter
I 1A6153 Writ -Other Limited Court Case Review

2.

iZZI A6150 Other Writ/Judicial Review

2,8.

Antitrust/Trade Regulation (03)

I A6003 Antitrust/Trade Regulation

1,2., 8.

Construction Defect (10)

I A6007 Construction Defect

1.,2 3.

Writ of Mandate(02)

3
->

OtherJudicial Review (39)

c
o

Above

I. . J A6108 Asset Forfeiture Case

75

Reasons - See Step 3

(Check onlyone)

Asset Forfeiture (05)

.5

C Applicable

Type of Action

Category No.

CASE NUMBER

2., 8.
2.

co

O)

!3
X

V>

Claims Involving Mass Tort

(40)

I A6006 Claims Involving Mass Tort

1.,2.,8.

Securities Litigation (28)

I A6035 Securities Litigation Case

1.,2.,8.

a.

,>.

75

Toxic Tort

!i2

I ,,.l A6036 Toxic Tort/Environmental

Environmental (30)

'>

Q.

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

Insurance Coverage Claims

from Complex Case (41)

I 1A6014 Insurance Coverage/Subrogation (complex case only)

1., 2.,5.,8.

0)

o>

g-g'
S3
ut

Enforcement

of Judgment (20)

RICO (27)
CO

CO

I te

iS

Other Complaints

(Not SpecifiedAbove) (42)

Partnership Corporation
Governance (21)

I A6141 Sister State Judgment

2., 9.

I A6160 Abstract ofJudgment

2., 6.

I 1A6107 Confession of Judgment (non-domestic relations)

I 1A6140 Administrative Agency Award (not unpaid taxes)
| 1A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax

2,8.

1A6112 Other Enforcement of Judgment Case

2., 8., 9.

I A6033 Racketeering (RICO) Case

1.,2., 8.

I A6030 Declaratory Relief Only

1..2..8.

1A6040 Injunctive Relief Only (not domestic/harassment)

2., 8.

Other Petitions (Not

SpecifiedAbove)(43)

1..2.. 8.

1.,2., 8.

\Z3 A6113 Partnership and Corporate Governance Case

2,8.

I A6190 Election Contest

I A6100 Other Civil Petition

,'"'>

LACIV 109 (Rev 3/15)

LASC Approved 03-04

Cl>

28.

I 1A6000 Other Civil Complaint (non-tort/non-complex)

~7~J A6110 Petition for Change of Name

1 A6170 Petition for Relief from Late Claim Law

/IL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION

I
e

2., 9.

L_J A6011 Other Commercial Complaint Case (non-tort/non-complex)

CZH A6121 Civil Harassment

i I A6123 Workplace Harassment
1 A6124 Elder/Dependent Adult Abuse Case '

[S,?

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

23.,9.
2.

2., 7.

2., 3., 4., 8.

2., 9.

Local Rule 2.3

F'age 3 of 4

short title: spg Entertainment v. BK Productions, et al,

CASE NUMBER

Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance orother

circumstance indicated in Item II., Step 3on Page 1, as the proper reason for filing in the court location 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.

address:

10635 Santa Monica Blvd., Suite

180

l.E2.n3O4O5O6O7O8O9Ol0.C]11
CITY:

STATE:

Los Angeles

CA

ZIP CODE:

90025

Item IV. Declaration ofAssignment. Ideclare under penalty of perjury under the laws of the State of California that the foregoing is true
and correct and that the above-entitled matter is properly filed for assignment to the Central
courthouse in the
Los Anqeles
District of the Superior Court of California, County of Los Angeles [Code Civ. Proa, 392 et seq., and Local
Rule 2.3, subd. (a).

Dated: 02/04/16

(SIGNATURE OF ATTORNEY/FILING PARTY)

Gregory J. Aldisert

COMMENHCEVYOTul SeWCOURT CASE: C0MPLETED AND READY T0 BE FILED '* ER PROPERLY

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,

03/15)aSe CVer Sh6et Addendum and statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.

5.

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

6.

Asigned order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a
minor under 18 years ofage will be required by Court in order to issue a summons.

mncJhSfP!fS,f doc"eunts t0 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.

LAOIV'hOg (Rev3/15)
LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION

Local Rule 2.3

Page 4 of 4