ht in Ce Baw” 10 u 12 13 4 15 16 7 18 19 20 2 2 24 25 26 2 28 e e oo por od FIL IMATERN LAW GROUP Ke Supsiioe Cour Galiomia MATTHEW J. MATERN (SBN 159798) A wPW ef Loe angates /mmatern@matemlawgroup.com JAN 20 2016 1230 Rosecrans Avenue, Suite 200 > ‘Shen, i Manhattan Beach, CA 90266 oa Ts neon ‘Tel: (310) 531-1900 ‘Crate Oral nn Faesimile: (310) 531-1901 Attorneys for Plaintiff |Leah Rothman ial i Dot Crest thy 0 Shagad SUPERIOR COURT OF THE STATE OF CALIFORNI FOR THE COUNTY OF LOS ANGELES: 4 5 LEAH ROTHMAN, an individual BC 6 0 ? 5 8 fort Plaintiff, False Imprisonment ve. Intentional Infliction of Emotional Distress 1 2 3. Whistleblower Retaliation PETESK] PRODUCTIONS, INC.,a Texas | 4. Wrongful Constructive Termination corporation; CBS STUDIOS, INC., a Delaware corporation; ENTERTAINMENT | Demand For Jury Trial PARTNERS, INC,, a Delaware corporation; EPSG TALENT SERVICES, LLC, a California limited liability corporation: DR. PHIL MCGRAW, an individual; and DOES 1 through 50, inclusive, Defendants | NATURE OF THE ACTION 1, This civil sights action is brought to remedy Defendants’ employment whee a including (1) false imprisonment, (2) intentional infliction of emotional diggs @s s z 3 Whistleblower retaliation, and (4) wrongful constrictive temination in vida at pubig 3 Policy. Plaintiff seeks compensatory damages, punitive damages, attomey's fos and gb JURISDICTION AND VENUE ii 3 a ‘This Court has personal jurisdiction in this matter because Plaintiff is g resi Be. the State of Califomia and Defendants are residents of andlor regularly eae Shsingsiin 1 COMPLAINT 8430/0 #3580 LTS, sese0908ea aw 10 u 12 B 14 15 16 7 18 19 20 2 22 23 24 25 26 California. 3. Venue is proper in the County of Los Angeles, because Defendants’ unlawful actions and omissions, set forth herein, occurred in the County of Los Angeles. PLAINTIFF 4, Plaintiff Leah Rothman (“Plaintiff" or “Rothman”), worked on the Dr. Phil Show for Peteski Productions, Inc., CBS Studios, Ine., Entertainment Partners, Inc., EPSG Talent Services, LLC, and Dr. Phil McGraw (collectively “Defendants”) from approximately December 2003 until approximately April 24, 2015, at which time she was constructively terminated in violation of public policy. DEFENDANTS 5, Plaintiff is informed and believes and thereon alleges that Defendant Peteski Productions, Inc. (“Petesh is and at all times relevant herein was, a Texas corporation, however was operating and existing under the laws of the State of Califomia. Plaintiff is further informed and believes and thereon alleges that at all times relevant herein, Defendant was ‘authorized to and did conduct business in the State of California. Specifically, upon information and belief, Defendant maintains offices and facilities and conduets business in the County of Los Angeles, State of California, At all relevant times herein, Peteski has been the copyright owner of the Dr. Phil show. 6, Plaintiff is informed and believes and thereon alleges that Defendant CBS Studios, Tne. (“CBS”) is and at al times relevant herein was, a Delaware corporation, however was ‘operating and existing under the laws of the State of California. PlaintifFis further informed and believes and thercon alleges that at all times relevant herein, Defendant was avthorized to and did conduct business in the State of California. Specifically, upon information and belief, Defendant mnaintains offices and facilities and conducts business in the County of Los Angeles, State of California 7. Plaintiff is informed and believes and thereon alleges that Defendant Entertainment Partners, Inc. (“Entertainment Partnt is and at all times relevant herein was, a Delaware ‘corporation, however was operating and existing under the laws of the State of California. 2 COMPLAINTewe am 10 u 12 B 14 15 16 7 18 19 20 a 22 23 24 25 Plaintiff is further informed and believes and thereon alleges that et all times relevant herein, ‘Defendant was authorized to and did conduct business in the State of California. Specifically, upon information and belicf, Defendant maintains offices and facilities and conducts business in ‘the County of Los Angeles, State of California 8. Plaintiffs informed and believes and thereon alleges that Defendant EPSG Talent Services, LLC (“EPSG") is and at all times relevant herein was, a Califomia limited liability corporation operating and existing under the laws of the State of Califormia. Plaintiffs further informed and believes and thereon alleges that at all times relevant herein, Defendant was authorized to and did conduct business in the State of Catifornia. Specifically, upon information ‘and belief, Defendant maintains offices and facilities and conducts business in the County of ‘Los Angeles, State of California. Ea Plaintiff is informed and belicves and thereon, alleges that Defendant Dr. Phil MeGraw (“Dr. Phil”) is, and at all times relevant herein was, an individual residing in the State of Celifomia. At all times relevant herein, Defendant Dr. Phil was the host of the Dr. Phil show, produced by Peteski, the production company founded by Dr. Phil. At all times relevant herein, Dr. Phil was Plaintiff's supervisor, and in taking specific actions on behalf of Defendants Peteski, CBS, Entertainment Partners, and EPSG, caused the violations of law about which Plaintiff’ now complains, STATEMENT OF FACTS 10. Plaintiff was employed by Defendants from approximately December 2003 until approximately Apri] 24, 2015 when Plaintiff was forced to leave. 11. On March 11, 2015, Plaintiff was called into her place of work on her day off Plaintiff and approximately 300 other individuals who worked on the Dr. Phil Show were ‘summoned into a single room, where several security officers were also present. 12. Dr. Phil entered the room and demanded that the doors to the room be locked, forcing all of his employees present, including Plaintiff, to be enclosed in the room with no way out. 13. The employees were packed in the room together. Because the employces were 3 COMPLAINTween ee a 10 Ww 2 1B 14 15 16 7 18 19 20 2 22 2B 24 25 26 7 28 )packed in the room together, Plaintiff and those around her were forced to stand in the enclosed room. During this meeting, Dr. Phil also demanded that ‘every employee tum off their phones, ‘further isolating them. 14. Dr. Phil yelled at the employees present at the meeting, inchiding Plaintiff, alleging that one of them had leaked intemal information to the press. Dr, Phil informed those present that he had contacted the “Feds” because the information that was transmitted was done 50 over state lines. During the meeting, Dr, Phil was yelling at Ms, Rothman and her colleagues, slamming items down, and threatened whoever leaked the story. Specifically, he stated “if you fuck with me, Tl fuck with you,” continuously using profanity toward the employees throughout the meeting 15. Plaintiff was not allowed to leave this mecting, particularly as security guards were ‘standing by the doorways. Plaintiff began experiencing emotional distress from the verbal assault of Dr. Phil which was magnified by the confined Space, the locked doors, the ban on phones, and the presence of security guards. 16. Plaintiff is informed and believes that the March 11, 2015 meeting, which falsely ‘noprisoned all employees of the Dr. Phil show, including Plaintiff, in a single space while being yelled at, was a planned event by Dr. Phil and the Defendants, La Plaintiff is further informed and believes that the March 11, 2015 meeting had been planned for some time. Specifically, Plaintiff saw cue cards in Dr. Phil's hands, which be often referred to during bis outbursts at the March L1, 2019 meeting, making it appear like Dr. Phil had scripted the entire event. 18. Dr. Phil intentionally chose to threaten and scare his employees, including Plaintiff, despite the fact that it was already known who the ‘person that leaked the information was. In act, Plaintiff was later informed by an executive at CBS that Defendants were already aware of the identity of the individual who leaked the information Prior to the March 11, 2015 meeting. 19. ‘On March 13, 2015, shortly after the meeting and false imprisonment, Plaintiff requested a meeting with Cassic Thomas, the Senior Vice President of Human Resources, which ‘was set up between Plaintiff and Ms. Thomas for March 18, 2015. 4 COMPLAINTaw ek ew 10 W 12 B 4 15 “16 17 18 19 20 2 20. During this March 18, 2015 meeting, Plaintiff expressed how nervous she was for reporting the inappropriate behavior at the March 11, 2015 meeting, particularly as Plaintiff had ‘pot complained about other hostile behavior she had previously experienced working on the Dr. Phil Show. 21. After reassurances from Ms. Thomas who stated, “don’t worry, you won’t get fired 3st for coming to talk,” Plaintiff then told Ms. Thomas about the events of March 11, when Dr, Phil had locked her and the other employees in a room, and expressed her belief that “locking the doors was probably illegal.” Ms. Thomas sympathized with Plaintiff, telling Plaintiff that she too was shocked and that she also felt that Dr. Phil’s actions were most likely illegal, promising that she" ill have to look into it.” When Plaintiff further expressed to Ms. Thomas that she felt Dr. Phil’s behavior was egregious, Ms. Thomas responded by stating “egregious is a Teally good word for it.” Ms. Thomas then stated that the Dr. Phil show had been a problem for CBS since the boginning of it being on the ait. 22. Rather taking any action whatsoever against Dr. Phil or seeking to protect their employees, Defendants simply condoned Dr. Phil’s behavior. 23, Defendants continued to convey the message that Dr. Phil was their cash cow and that they needed him and his show on the CBS network. Specifically, Plaintiff was informed of this fact by an executive in charge of production, as well as who had leaked the information, that ‘Dr. Phil threatened the employees about during the March 11, 2015 meeting. This executive in ‘charge of production informed Plaintiff that Defendants allowed Dr. Phil to continue his, interrogation of the employees, including Plaintiff, hecause he got joy out of the process and in scaring his employecs. The executive confirmed with Plaintiff that the meeting initiated by Dr. Phil on Mareh 11, 2015 was not a “fact-finding mission,” but rather a planned event meant to scare and intimidate the employees — something Dr. Phil was proud of himself for doing. Dr. Phil, with the remaining Defendants’ supporting his actions, intentionally inflicted the scare and intimidation tactics on Ms. Rothman and her colleagues. 24. Plaintiff was never provided a formal apology by any Defendant, despite her ‘complaints and concems, and is unaware of any apology being made to any of the employees 3 COMPLAINTau eo 10 nu 2 B 14 15 16 a7 subjected to the Merch 11, 2015 mecting. 25. Plaintiff attempted to schedule a subsequent meeting with Cassie Thomas in Human Resources in early April of 2015, to follow up to their March 18, 2015 meeting, however Ms. Thomas made it very difficult for Plaintiff to mect with her, never firmly scheduling any meeting after the first March 2015 meeting, 26, Despite Ms. Thomas’ promises to follow up with Ms. Rothman, neither Ms. Thomas ‘nor any other Human Resources representative ever followed through with Plaintiff to make sure her concems about the egregious behavior in the workplace was remedied, a8 Plaintiff was kept on guard and nervous when entering the workplace after tho March 11, 2015 esting. 27. Plaintiff is not aware of Dr. Phil ever being counseled or disciplined for hs illegal conduct, displaying the Company's ratification of his conduct. 28, Plaintiff was forced to quit her job with Defendants, due to the intolerable workplace ‘she had been subjected to working in, despite that she worked competently and performed strongly for over 10 seasons, Plaintiff even made a commitment to her supervisors to finish the season, despite the fact that each day following the March 11, 2015 incident felt too difficult to bear in the workplace. Plaintiff eventually had no choice but to leave 29. Since ending her employment Plaintiff has been able to secure additional work, but for less pay and, for some time, with loss consistency. More so, she docs not have the benefits ‘and pension she earned on the Dr. Phil show. 30. The Defendants knew of Dr. Phil’s inappropriate illegal conduct, knew that employees like Plaintiff had complained about it and needed protection, yet did nothing to make hr or other employees feel safe in the workplace or to prevent or correct the illegal activity. Due to this, Plaintiff has suffered emotionally, endured numerous sleepless nights, has had her work affected due to her focus shifting, and has fost the feeling of safety one would expect in any workplace. INJURIES TO PLAINTIFF 31. Asa direct and proximate result of the foregoing unlawful and malicious acts by Defendants, Plaintiff has suffered great mental and emotional distress. Moreover, Plaintiff has 6 COMPLAINTa auUesun 10 u R 3 4 15 16 v7 18 19 20 2 22 2 bccn humiliated and embarrassed as a result of the foregoing acts of Defendants. 32. Asa further direct and proximate result of the foregoing unlawful and malicious acts of Defendants, Plaintiff has suffered monetary damages. FIRST CAUSE OF ACTION False Imprisonment [Cal. Penal Code § 236] (Against All Defendants) 33, Plaintiff incorporates herein by specific reference as though fully set forth the allegations in paragraphs 1 through 32. 34. Atall relevant times, Penal Code section 236 was in full force and effect and binding upon all defendants, Penal Code section 256 defines “false imprisonment as the unlawful violation of the personal liberty of another.” An employer can be held lisble for civil damages for violating Penal Code section 236. Fermino v. Fedco, Inc,,(1994) 7 Cal, 4th 701. An employer's right to require are employee to follow the employer's directions does not authorize the employer to deprive coercively the employee of his or her liberty for purposes of compelling confession and an employer who does so is guilty of false imprisonment. 35. Toestablish a claim for false imprisonment, a plaintiff must show that: (1) defendant intentionally deprived plaintiff of her freedom of movement by use of physical barriers, force, threats of force, menace or unreasonable duress; (2) that the restraint and confinement compelled plaintiff 0 stay or go somewhere for some appreciable time, however short; (3) that plaintiff did not knowingly or voluntarily consent; (4) that plaintiff was harmed; and (5) that defendant's conduct was a substantial factor in causing plaintiffs harm, 36. Asset forth above, Defendants’ acts and omissions constitute violations of the California Penal Code § 236. 37. Asalleged herein, Defendants’ managers confined Plaintiff and refused to let her leave under threat of force and perceived force. 38. By committing the outrageous and malicious acts and omissions complained of /herein, Defendants Peteski, CBS, Entertainment Partners, EPSG, and Dr. Phil knew or should have known that their conduct would result in Plaintiff's severe emotional distress. Moreover, Defendants Peteski, CBS, Entertainment Partners, EPSG, and Dr. Phil’s acts and omissions were 2 COMPLAINTea aw 10 12 1B 4 15 16 17 18 19 20 21 2 23 24 25 26 27 28 perpetrated with the intent of inflicting humiliation, mental anguish, and severe emotional stress upon Plaintiff. Defendants Peteski, CBS, Entertainment Partners, EPSG, and Dr. Phil knew of thé false imprisonment and egregious activity by Dr. Phil and failed to investigate and take any action against Defendant Dr. Phil, thereby ratifying his actions. 39. Asa direct and proximate result of Defendants’ unlawful acts, practices and ‘omissions, Plaintiff has suffered monetary damages, humiliation, mental anguish, and physical and emotional distress, in an amount subject to proof at tial. Plaintiff claims such amount as damages 40, The vnlawful acts and practices of Defendants alleged herein were intentional and ‘willful, and caused great physical and emotional harm to Plaintiff. The Defendants ratified the ‘wrongful acts. Therefore, an award of punitive damages, sufficient to punish Defendants to serve as an example to deter them from similar conduct in the future, should be made. Plaintiff claims such amount as damages, SECOND CAUSE OF ACTION Intentional Infliction of Emotional Distress (Against all Defendants) 41. Plaintiff incorporates herein by specific reference as though fully set forth the allegations in paragraphs | through 40, 42. By committing the outrageous and malicious acts and omissions complained of herein, Defendants Peteski, CBS, Entertainment Partners, EPSG, and Dr. Phil knew or should have known thet their conduct would result in Plaintiff's severe emotional distress. Moreover, Defendants Peteski, CBS, Entertainment Partners, EPSG, and Dr. Phil’s acts and omissions were perpetrated with the intent of inflicting humiliation, mental anguish, and severe emotional distress upon Plaintiff. Defendants Peteski, CBS, Entertainment Partners, EPSG, and Dr. Phil knew of the false imprisonment and egregious activity by Dr. Phil and failed to investigate and take any action against Defendant Dr. Phil, thereby ratifying his a s. 43, Asa direct and proximate result of Defendants’ unlawful acts, practices and ‘omissions, Plaintiff has suffered monetary damages, humiliation, mental anguish, and physical and emotional distress, in an amount subject to proof at trial. Plaintiff claims such amount as 8 COMPLAINTwon awe 10 ul 12 B 14 1s 16 7 18 19 20 2 2 23 24 25 26 2 28 damages. 44, ‘The unlavful acts and practices of Defendants alleged herein were intentional and willful, and caused great physical and emotional harm to Plaintiff. The Defendants ratified the wrongful acts. Therefore, an award of punitive damages, sufficient to punish Defendants to serve as an example to deter them fiom similar conduct in the future, should be made, Plaintit [claims such amount as damages. ‘THIRD CAUSE OF ACTION ‘Whistleblower Retaliation ICal, Labor Code § 1102.5 et seq} (Against Peteski, CBS, Entertainment Partners, EPSG, and Does 1-50) 45, Plaintiff incorporates herein by specific reference as though fully set forth the allegations in paragraphs 1 through 44, 46, Atall relevant times herein, the Califomia Labor Code § 1102.5 et seq., was in full force and effect and was binding on Defendants 47, Pursuant to Labor Code section 1102.5(a), “An employer, of any person acting on behalf of the employer, shall not make, adopt, or enforce any rule, regulation, or policy preventing an employee from disclosing information to a government or law enforcement agency, to a person with authority over the employee, or to another employee who has authority to investigate, discover, or correct the violation or noncompliance, or from providing information to, or testifying before, any public body conducting an investigetion, hearing, or inquiry, if the employee has reasonable cause to believe that the information discloses a violation of state or federal statute, or a violation of or noncompliance with a local, state, or federal rule or regulation, regardless of whether disclosing the information is part of the Jemployce’s job duties.” 48. Pursuant to Labor Code section 1102.5(b), “An employer, or any person acting on behalf of the employer, shall not retaliate against an employee for disclosing information, or because the employer believes that the employee disclosed or may disclose information, toa ‘government or law enforcement agency, to a person with authority over the employee or another ‘employee who has the authority to investigate, discover, or correct the violation or noncompliance, or for providing information to, or testifying before, any public body. 8 ‘COMPLAINTa auew 10 n 12 2B 14 15 16 a7 18 19 20 a 22, 23 24 26 conducting an investigation, hearing, or inquiry, if the employee has reasonable cause to believe that the information discloses a violation of state or federal statute, or a violation of or /noncomplience with a local, state, or federal rule or regulation, regardless of whether disclosing the information is part of the employee's job duties.” 49. Labor Code section 1102.5(f) provides that, “In addition to other penalties, an ‘employer that is a corporation or limited liability company is liable for a civil penalty not exceeding ten thousand dollars ($10,000) for each violation of this section.” 50. Defendants and each of them, have breached their statutory and self-imposed duties owed to Plaintiff, and under California law, including Labor Code §2856, Ponal Code §236, and Labor Code § 1102.5 et seg which makes it unlawful for an employer to utilize any unlawfl exercise of force, or express or implied threat of force by which in fact any person is deprived of his liberty and compelled to remain where he or she does not wish to remain amounts to false imprisonment, Labor Code §2856 and Penal Code §236 embody fundamental Public Policy of the State and any retaliation for opposing violations of these statutory obligations gives rise to civil liability and damages under Labor Code § 1102.5 er seg. Si. Defendants retaliated against Plaintiff for complaining to Human Resources personnel about her false imprisonment. Defendants, and each of them, and/or their agents/employees, retaliated against Plaintiff by adversely affecting Plaintiff's employment after she engaged in protected activity, as set forth herein above 52. By committing the outrageous and malicious acts and omissions complained of herein, Defendants Peteski, CBS, Entertainment Partners, EPSG, and Dr. Phil knew or should have known that their conduct would result in Plaintiff's severe emotional distress. Moreover, Defendants Peteski, CBS, Entertainment Partners, EPSG, and Dr. Phil’s acts and omissions were perpetrated with the intent of inflicting humiliation, mental anguish, and severe emotional distress upon Plaintiff. Defendants Peteski, CBS, Entertainment Partners, EPSG, and Dr. Phil knew of the faise imprisonment and egregious activity by Dr. Phil and failed to investigate and take any action against Defendant Dr. Phil, thereby ratifying his actions. 53. Asa direct and proximate result of Defendants’ unlawful acts, practices and 10 COMPLAINTomissions, Plaintiff has suffered monetary damages, humiliation, mental anguish, and physical and emotional distress, in an amount subject to proof at trial. Plaintiff claims such amount as damages. 54, The unlawful acts and practices of Defendants alleged herein were intentional and willful, and caused great physical and emotional harm to Plaintiff. The Defendants ratified the wrongful acts. Therefore, an award of punitive damages, sufficient to punish Defendants to serve as an example to deter them from similar conduct in the future, should be made. Plaintiff claims such amount as damages. FOURTH CAUSE OF ACTION Wrongful Constructive Termination {Against Peteski, CBS, Entertainment Partners, EPSG, and Does 1-50) 55. Plaintiffincorporates herein by specific reference as though fully sot forth the allegations in paragraphs 1 through $4. 56. Atall relevant times herein, the California Constitution and the Fair Employment and Housing Act were in fall force and effect, and were binding on Defendants Peteski, CBS, Entertainment Partners and EPSG. Article I, Section 8 of the California Constitution, the Fair Employment and Housing Act, and the public policy of the State of California based thereupon, require Defendants to refrain from committing acts of false imprisonment, retaliation, intentional infliction of emotional distress, including making complaints about an employer's unlawful behavior. 57. As set forth above, Defendants’ acts and omissions constitute violations of Article I, Section 8 of the California Constitution, the Fair Employment and Housing Act, Labor Code § 1102.5, and the publie policy of the State of California based thereupon, Such unfair and discriminatory conduct was a substantial factor in causing damage and injury to Plaintiff 58. By reason of Defendants® unlawfal acts, practices, and omissions, Plaintiff has suffered monetary damages, humiliation, mental anguish, and physical and emotional distress, jn an amount subject to proof at trial 59. The unlawful acts and practices of Defendants alleged herein were reckless and ‘willful, and caused great physical and emotional harm to Plaintiff. Therefore, an award of u COMPLAINTew ao 10 u 12 2B 4 1s 16 7 18 19 20 a 22 2 Pz 25 26 a 28 punitive damages, sufficient to puni Defendants and to serve as an example to deter Defendants from similar conduct in the future, should be made, Plaintiff claims such amount as damages. PRAYER FOR RELIEF \WHERErore, Plaintiff respectfully prays for relief against Defendants as follows: 1. For compensatory damages in an amount fo be ascertained at trial, including ‘compensation for Plaintiff's economic losses, deprivation of civil rights, humiliation, physical anguish, and mental and emotional distress; 2. Foran award of punitive and exemplary damages on each cause of action as permitted by law; 3. For prejudgment interest pursuant to Labor Code § 218.6, Civil Code §§ 3287, 3288, and/or any other applicable provision providing for prejudgment interest; 4. For the costs and expenses of this action, including reasonable attomey's fees Pursuant to applicable laws and statutes; 5. Foran award of reasonable attomeys’ fees, costs, and expenses, pursuant to Cal. Givil Code § 1021.5, and any other applicable provisions providing for attomeys’ fees and costs; 6. For declaratory relief, including entry of judgment declaring that the acts and practices of Defendants and their agents and employees as set forth herein violate the foregoing provisions of law. 7. For such further relief as the Court may deem just and proper. DATED: January 15,2016 MATERN LAW GRQUP BY: MATTHEW JAAATERN ‘Attomeys for Plaintiff ‘Leah Rothman COMPLAINT1 DEMAND FOR JURY TRIAL Plaintiff hereby demands a jury trial with respect to all issues triable of right by jury. DATED: January 15, 2016 MATERN LAW GROUP BY: 1 THEW J. Attorneys for Plaintiff 8 Leah Rothman 3 COMPLAINT(rage 24 of 19) ee e— cu-o10 TE = eer oe } Mathew Mater (SBN 159798) 1230 Rocecrans Avene Sate 200 Merron: (310) 331-1900, (G10) 531-1901 Dp j sumtrfonneey LEAH ROTHMAN “eae Meee Feremencounoreauronen coum er Los Angeles ‘smageraconess: 11] North Hill Street Srincorcnt Los Angels, California 0012-3014 nee : ‘orvawo ze cont: Los Angeles, California 90012-2 Carter, ceuesne, Conial Distt 3 eae { ASE NAME aise Leah Rothman v, Peteski Productions, Inc. etal CIVIL CASE COVER SHEET Complex Case Designation pee te mae ee 1 counter] soinder P7588 (Brount (amount — demanded demanded is. Filed with first appearance by defendant sxcneds$25000) _$25000rless)| "(Cal Ruleset Coury le 3402)" | oor Tes 1-6 boon mist bo Gonpletd c00 Ptctons 0 ag 2). [ir Gheckone bax Bala Trthe case ype that Best desctbes ths case auto Ton contact Provsionly compos ct Ligation ‘to (22) [Breach of conractnerranly (98) (Cal. Rules of Court, rules 3.400-3.403) Uninsured motorist (46) TE) Rue a740cotertons (oa) — J aninssvTrace rgutation 03) ‘Omer PHPOIMD (Porson InjuryiProperty ‘Other collections (09) 5) constretion detect (10) DamagerWeongful Death) Tort Insurance coverage (18) Co tiass on eo) CF Astestes 04) ‘Other contact (37) Secures ttigation (26) Prt tay fel property [enone txt (0) Hee! marae 5) [Ey Ener donsstmene tetrce otape cma ag tan be ‘ner uPDr> 2) Ccndenoaion G3). ‘Sores craae srs to ‘Non-PUPOMD (Other) Tort 1 Wren eviction (23) ‘ypes (41) ‘Business touts business practice (7) L] omer ral popety (2) Enforcement of Judgment 2) cman (08) Unlawful Beta Enforcement ofudgmert (20) Detsmaten 13) Commer 1 ‘Mlscatloneous CWilComphant Fraud (16) TE) Resisentat 32) [I reoen ‘nietetval property (19) CO owes 08) TH omnes comptant not specie above) (42) ‘Professional negligence (25) a Miscellaneous Civil Petition (1 otter non-PuP OND tot (35) LEY sco ortene 05) Parrership nd corporat governance (21) Joyment Peon re ativan ard (11) etna ‘Wogan (8) ) warotmancate 02) Seheedaedacneraicaanains (Zone enstoymen ts) onerjueatrvew 20) 2 Trisease [Tis LZTisnot complex under rule 2400 of he Calioria Rules of Cour. ithe case is complex, mark he factors requting exceptional judicial management: aL] Large number of separately represented panies d. (_] Large number of winesses >.) extensive motion practice raising aticutor novel 0, =] Coordination wih elated actions pending in one or more couts 'ssues that willbe time-consuming oresoNe inter cauntes, totes or counties, of na federal cout 1 Substantial amount of documentary evidence _f. [_] Substantial posiiudgment judicial supervision 3. Remedies sought eck lina apply: a[Z] monetary. 4, Number of eautes of acon (speci: Four (4) strisease CJis CJisnot acass action suit rnonmanetary; declaratory or injunctive reef © [7 Jpunitive ‘G-ifthere are any known related cases, fle and serve notice of related cawe-yWou , Date: January 19, 2016 Matthew J. Matern NOTICE ‘Pita oe oversee tn eft par od n eee tout etcen melee cases orcas fed cer he robote Ga, Foy Code cr Wel aninslons Co) (2, Muss Ca tla 220) Poe oe may eet Maton, IEAISTNE eter anetin dation to any cove sheet eed by ca cout ie 1 ‘Fit this case is complex under rule 3.400 et seq, of the Cakfornia Rules of Court, you must serve a copy ofthis cover sheet on all oe partes ite actor or cee {rstess this isa colections case under rule 3.740 or a complex case, this cover sheet wil be used fr statistical purposes onl | a WIL GASE COVER SHEET 7 Saaceeeas eee Dock 1 waged 16 - Doe 1D « 3640386121 ~ Doo Typerage 38 of 29) were Mors nnn 70 comers ri Maser cian To Plaintiffs and Others Filing First Papers. If you are fling a frst paper (or example, 8 complain) in a civil case, you must ‘compete and fl, along with your first pape, the Civil Case Cover Sheet contained on page 1. This information wil be used to compile ‘lastics about the iypes and numbers of cases fled. You must complete items 1 through 6 on the sheet. In item 1, you must check ‘one box for he case type that best describes the case. Ifthe case fis both a goneral and e more spectic ype of case sted in ter 1, check the more speciic one. If te case has mutple causes of action, check the box that best inlcates the primary cause of acto. ‘To assist you in competing the sheet, exemples ofthe cases that belong under each case type in im 1 are provided below. A cover ‘sheet must be fled ony wih your inal paper. Failure fo fle a cover sheet with the ft paper fod in a chil case may subject a party, its counsel, or both io sanctions under rufes 2.30 and 3.220 ofthe Catfornia Rules of Cour. ‘To Parties In Rute 8.740 Collections Cases. A “collections case" under rule 3.740 is defined as an action for recovery of money ‘owed in a sum stated to be certain that isnot moce than $25,000, exclusive of interest and alloray’s fees, arsing from a transaction in \whien propony, eonices, or meray was acquied on credit. A callselione ease does nat include an action seeking the following’ (1) fort damages, (2) punitive damages, (3) recovery of real propery, (4) recovery of personal property, of (6) @ prejudgment wt of attachment. The identification of 8 case a3 a rule 3.740 collections case on this form means thal it will be exempt from the general time-or-service requirements and case management rues, unless a defendant fies a responsive pleading. A ro 3,740 collections: case ill be subject tothe requirements for service and obtaining ajudgment in rule 3.740, To Parties in Complex Cases. In complex cases only, partes must also use the Civ Case Cover Sheet to designate whether the case is complex. ia plainfif believes the case is complex under rule 3400 of the California Rules of Cour, this must be indcated by ‘completing the appropriate boxes in tems 1 and 2. Ifa planiff designates @ case as complex, the cover sheet must be served with the complaint on al! parties to the action. A defendant may fle and serve no later than the time of is frst appearance a jeinder in the plaints designation, a counter-designation that the case is not complex, o, ithe plain has made no designation, a desigalien that {he case's complex, ‘CASE TYPES AND EXANPLES Auto Tot contact, Provslonay Comps ct tigation Ca “ABs 2)-PananltuyPrepety in of Contact) Fue out Rue 400-345) asgarivontl Set Srencttenttoae ‘reas Regdton 2) nwo ant fie "Sal ar ter Consvcton ates 0) scstaohes unonaured wryly lame eg at Yo 0 Sorts sunt conser ect eter Sees gain Seti heck Re tom iat ft aude gers) Seino foo isseodal ue) neigettane i See shai Conan Ca cer rom (err oy a arog fo peony conor eee ae cota Boo Convair Leaner tn ee Laueboenit Collections (e.g., money owed, enti Enforcement of Judgmont ‘Asbesos 09 eos) Sittcmeat fame a) ae 8 apeycanage tsa Cok Ste Pat "ekg tdci (tet ‘eae Peer ‘Sie amasery Notes “tort Seat ene cones ef gat nn Pre ast et edoser saute Cae pray coneste aston) ta Gan la ‘anne sate Soir medial Matpactes (3), ‘lo Scbrogation ‘Administrative agency Award ‘Medical Malpractice Other Coverage (act unpaid taxes) Physicians & Surgeons: Other Contract (37) Peliion/Certfication of Eatry of \omerpetoas Sontact Pat ier on Ua ates especie Sones Sipue ose iecenet aust Other PUPDAWD (23) Real Property aa i Pam ae ue 1 antares sealaenes Cv Compan a9 ‘Sogmatee aco Inston! Boy InjacyPOMND ‘Wionghl Evin 3) (ther Complaint (not specified “egy sunt easton) Oe Reat Property 9a 25) Sool merken = Ra roe, et te Decay Rae ny Ecco Chess weeeronmesn Firs Kale ny on Nev Bala ees eae oe vedas i omer BPSD hee ney ct Bis Sermersat conga on euPom (tbe Tor ‘reontue) ‘eae ann Business TortUntair Business Unlawful Detainer Other Git ompleint eae Sires smaseatt ieee Gea od, dation, mammal eaten Cu eto Ew ane atc rig (Ge cose ines! eri nd Cag te ve) hig eck ta oe, ‘Saomaton tg. Sense, oe) epee Carmela Pace St uate Sve sito eset fate 05) Teta Popaey 0) Paton ete Awad (1) ‘Brmcena Neg a5 Wien icon wobec Si ee tants ce en 1, Olt Profesonat Mapracteo \Wricktanéams on Limied Cout ees comet ‘ronesete hae) ‘ese ater on etn Ca cndtree IPOM Tea WS inte cou case eee ‘is Toman cm ter Jose revew 39 aerate fer Empey (2) Tao arte Siar er atcct appear spe Commissioner Appeals iiaieenaall CIVIL CASE COVER SHEET fee ‘Doch 2 Fagen 35 - boo 1D = 2640386121 ~ Doo Type = OTHER | | :» (age 16 of 39) ‘Leah Rothman v. Peteski Productions, Inc., et al BCR 07 5 85 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 n all now civil case filings in the Los Angeles Superior Court. Hem 1. Check the types of hearing and filin the estimated length of hearing expected for this case: survTaiat? W] yes ciassacrionr C1] ves unmeocaser Clves tae esrimaren For TRA: 1820 C] Hours’ ZI oays ‘tem i. Indicate the correct aistrict and courthouse location (4 steps ~ If you checked “Limited Case’, skip to Item Il, Pg. 4) ‘Step 1: Atter frst complating the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your ‘case in the let margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected, ‘Step 2: Check one Superior Cour type of action in Column B below which best descrbes the nature of this case, ‘Step 3: In Column G, circle the reason forthe court location choice that applies tothe type of action you have checked. For any exception to the court location, see Local Rule 2.0. Te ee ices os on mage eneereenrna on ee | eRe mera SC TEERG NSIS pettmtoes toques orecRndaat ction 18 Location of kabor Gommisclonar Ofte ‘Step 4: Fillin the information requested on page 4 in Item Ill; complete Item IV. Sign the declaration. A B c cases ae es coat exaties, anaes 8% * pao (22) D_ATIO0 Motor Vehicle - Personal injuryiProperty Damegeronatu! Death: AaB ae ‘Uninsured Motorist (46) D_ATT10 Personal injuryiProperty Damage/Wrongful Death — Uninsured Motorist ——o == ee : wy |_ tet [6 mma : ES [__Peesvrumenny 20 [vata erat nity (tastes or oxetenvtonner 142.848 BS ca! Nabractc - Physicions 8 Surgeons ta gs 1 A720 Preiss Ubi (9, spa a z pesoa 7230 intentional Bodily Injury!Property Damagehongful Death (0.9, BE | remaie, Sot antl ay wa ei ‘Wronlaesm | cy arara tleionalinicton of Emotions ives 18 : 17220 oer aarti Prpary Damogtergh aah ta ‘LACIV 109 (Rey. 03/11) CIVIL CASE COVER SHEET ADDENDUM ‘Local Rule 2.0 UASC Approved 03-04 AND STATEMENT OF LOCATION Page 1 of 4 ‘Doct 2 Fago# 16 - Doc 1D = 1640386121 ~ Doo aype «fom(aage 17 of 19) » SenrT™ gah Rothman v. Peleski Productions, Inc, eta. A B c cas ovr See Ipect Acton Apc reasns- Coecon Ne eco emy Saaep ante Busmass Tone _ [A809 Oe: Conmerteycnes Tot wet taudbreaehefeontaa) [a3 g: Cua Rigtts (08) | AB008 Cia RightsCiscinaen 1.2.8 3 3 Twfanaon(i3) | ABUIO Detention (ange 12 7] aan | av rasan arr i © AOA Lega tapas 128 B | prsesiontneotsece 2) i 1 AtED Ofer Pessinal aac (et ede) 123 g ee 23 | wwengitTeminaton 8) | 0 6007 Wonotl Termination 128 5 1 A01B Ober Emel Campi Cae @ = | cberemeoyment & 9) a A600 Later ConmistanerAppesis 0. AE Bue ot Reales Ortolfl inl dae Won vin) Bracnetcemeey Waray | sone contestant scholar Pai ro authepatee) A sastueasasas.! _AGD1g Negligent Breach of Contracywartanty (no fraud) © A008 cher fioth ot entameany ct ar regience) E | commen | Mit? Saeins cra nae 3 ” | sot cterPrmisoy erotectons Caso 28 TrsuarcoCoveage (1) | ASD wsurerce Cova pot comple) 1288 © nate coastal Fd 2.88 coperconacran — |e asast Taos herresce 2.9.8 ©. As02T ott Cone Dapuent esehnssncetaudesignc) 2.300 EmnoniDorabvingse 1 47200 Eminent DamabiCondenmatin —Nomber of parcel 2. EB [_eotecione | ats wt ze 4 AB018 Mortgage Foreclosure: 2,68. | onerreatronety ian) | soa ule Tie 28 5 {A050 Oar Rel rope (rt nine domi dtr redex) | 2.8. Wont Dager ona Tg jet Ula OeanerConmecil at dps rworghievo | 2, 3 | emertoweperresontat |S p5rc0 unanl Dtinr Reson anpserwonatiovaen) (2. AD [oars _[e seoxroamtonnarzenroncnae 28 © [ unswroeanercas ae) [O Aste2 Univ Oniverons va LACIv 109 Rev. a3rtt) CIVIL CASE COVER SHEET ADDENDUM 1 Local Rule 2.0 TASC Approved 03-04 AND STATEMENT OF LOCATION Page 2 of 4 ‘ech 1 Fagee 17 - Goo 1D = 1640386121 ~ Doo type = OTRoge 20 of 39) SORTTINE: ah Rothman v. Peteski Productions, inc., et al. I; A B Cc cia case Ov: sent Typectfcion apes Reasons Sievert ose eemraee| | Fei Foes) | AIOE Ase Foret Case as } 3 | _retenreanivaten i) [a AB15 Potion eConpeontmnacat Araon ze 2 © ASIST Wet-Adnioave Nnioms Ze } 3 | wwnctvaneto (ez) | ase Wit- Mandan ens Cout as Mtor 2 s (O A6153 Woit- Other Limted Court Case Review 2 . ‘er sucareaew 2) [0 AED OnerVe dodea Review ar g_[patesrtecereguaton ay | at008 AmtusiogRepaaion ry cence tl) abe eae ie [eases Ton Lasoo tne tokng oe Tor nae, y : ; S| seewteeutpton ay | ASO Sects Utpoten Cove 12 2 ee 128 E | epemecoemnecn [caso nasaen coensetcrenen consaxens ou { Date Sat Sule apne te ©6180 Asta pment é tniocereny | ASI? Cares of ger en eres ons) B | etme | aste0 azine ageney Ans st pi ee as D_ A8114 Petition/Certificate for Enty of Judgment on Unpaid Tax I“ © A8t12 OtwrEnocoven cf dugmen Case 4 i Teco GN [a A000 Rockey (ROO) Goce ga 1. A8000 Cecio Reet Only Ne eee a aebaluacsoma Gl laeasaas ES | morseecteafoore} 2 | oy sors otercommeret Conant Cas rertovon comet) , fe G_ 46000. Other Civil Compiaint (non-torvnon-complex) Panzer Canesten Tq qsit9 Parreipand Cnerale Govrnatcs Case 2.8 ro Sperry za 8 1D A8123 Worklace Heassment 2.3.9. SS] curanay | Ait ccwtnmra on a S| ouSseatantom [co 45:00 elcin cones iS Lid 0 AS110 Petition for Change of Name X _A6170 Petition for Reis from Late Claim Law we 1D. A8100 Other Civil Petition ff & be Laci 109 (Rev. 099) ASC Approved 03-08 CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION ‘boot 1 Paget 18 - Doo 1D Local Rule 20 Page dof4 4 ona = boo He = bmnrage 19 of 19) eT ean Rothman v. Peteski Productions, In. etal |tem Il, Statement of Location: Enter the address of he accident, party's residence or place of business, performance, or other circumstance indicated in Item Il, Step 3 on Page 1, as the proper reason for fling in the court location you selected. REASON: Check the appropriate boxes fo the numbers shown 555 Melore Avorue tnd Column G for ha ypo of action that you havo seloctod or this ease. (Qtst be fled in Centra Dstt) 01. 2.03.04. 05. 06.07.08. Os. O10. om rod Los Angeles lca ona Item IV. Dectaraion of Assignment t declare under penally of perjury under the laws ofthe State of California thatthe foregoing is true ‘and correct and that the ebove-entitled matter Is properly filed for assignment to the Stanley Mosk ‘courthouse in the Sentral District ofthe Superior Court of California, County of Los Angeles [Code Civ, Proc, § 392 et seq,, and Local Rule 2.0, subds. (0), (e) and (A). esti Dated: 171972016 PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY ‘COMMENCE YOUR NEW COURT CASE: Original Complaint or Petition, IF fing a Complaint, a completed Summons form for issuance by the Clerk. Civil Case Cover Sheet, Judicial Council form CM.010, Gi Case Cover Set Addendum and Staterent of Location for, LAGIV 108, LASG Approved 05-04 (Rev. A i ‘Payment in ful ofthe filing fee, unless fees have been waived, ; 6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, ifthe plaintif or petitioner isa ‘minor under 18 years of age wil 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 intiating pleading in the case. Rene ‘RGIV 109 Rew. 037) CIVIL CASE COVER SHEET ADDENDUM Local Rule 20 5 ASC Approved 03-04 AND STATEMENT OF LOCATION Page of4 5 ‘Doct 1 Pagew 19 - bao 1D = 1640986121 - Doo Type = PEER