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cage © or ae ® © pp), wo effey M, Lenkov, Ea (Stato Bar No, 156478) wu iml@mannin; ‘Steven J. Renick, Esq, (State Bar No, 101255) si Sevan Gobel, Esq, (State Bar No. 221768) sxg@manninglip.com FILED MANNING & KASS supereh conto! Gatrnia ELLROD, RAMIREZ, TRESTER LLP - “Bounty ot bos Anases 801 S. Figueroa St, 15" Floor Los Angeles, California 90017-3012 | Telephone: (213) 624-6900 Facsimile: (213) 624-6999 ‘sneriR, Cat, ‘Attomeys for Plaintfis eee | TREEHOUSE FILMS, LLC and KEVIN COSTNER uy Prt g Viandiq ARIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES BC 638460 ‘TREEHOUSE FILMS, LLC, 2 Califomia | Case No, limited liability company, and KEVIN COSTNER, an individual, ; cE COMPLAINT FOR DAMAGES: Plaintiff, (1) Breach of Contract v @)_ Declaratory and Injunctive Relief KYLIN PICTURES, a California corporation @) Fraud and DOES { through 50, inclusive, (4 Common Count: Goods and Services Rendered Defendants. DEMAND FOR JURY TRIAL B bel egonaZs PARTIES g285° 2: 1. Plaintiff TREEHOUSE FILMS, LLC ("TREEHOUSE") is alimited Shai company organized and existing under the laws of California, and has its principal | [business located in Los Angeles, California, S 2. Plaintiff KEVIN COSTNER ("COSTNER) is a citizen. of Califo . 1 boa & ‘COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL” ena30/077 35007 119 apreseoa Doo ype = omER (rage 2 of 22) 1 3. Defendant KYLIN PICTURES (“KYLIN") is a California corporation with its 2|{ principal place of business located in Los Angeles, California, 3 4, Plaintiffs are ignorant of the true names and capacities of the defendants sued as 4|| DOBS 1-50 inclusive, and therefore sues these defendants by such fictitious names, Plaintifis will 5|| amend this complaint to allege their true names and capacities when ascertained, 5. Plaintiffs are informed and believe and thereon allege that at all times herein mentioned, each of the defendants was the employee or agent of each of the other defendants and 8||in doing the things hereinafter alleged was acting within the scope of such employment or agency 9] and with the permission and consent of the other defendants, 10 3) ou GENERAL ALLEGATIONS i. 5 12 6 Onor about April 4, 2016, TREEHOUSE and Beacon Films (“BEACON”) entered 13 | into a written contract (the ‘CONTRACT”) ~ identified in the CONTRACT as a “Binding Letter 14 fof Intent” — with KYLIN and DOES 1-50 inch Euirop, ace to produce a theatrical motion pictur titled Manwina: 15 || "shanghai Sojourners” (the "PICTURE”). A copy of the CONTRACT is attached to this 16 |] Complaint as Exhibit A. Among the provisions of the CONTRACT is a venue provision, stating 17] that the parties agree that eny lawsuit brought to enforce the contract shall be venued in a state or 18 } federal court located in Los Angeles, Californie, 9 7. Pursuant to the terms of the CONTRACT, TREEHOUSE and BEACON were to 20] provide the services of COSTNER and Army Bernstein ("BERNSTEIN") respectively to produce | 21 || the PICTURE. Under the specific terms of the CONTRACT, TREEHOUSE end BEACON were 22.||10 oversee the re-write of the existing screenplay of the PICTURE and were also to use 23 || “commercially reasonable efforts” to assist KYLIN and DOES 1-50 in finding suitable actors and 24 /}|a director, as well as a line producer. 25 8. Pursuantto the terms of the CONTRACT, KYLIN and DOES 1-30 were to pay i 2 26|)COSTNER and BERNSTEIN a combined fixed Producers’ Fee of Three Million Dollars 27] ($3,000,000), to be split as determined by COSTNER and BERNSTEIN. KYLIN and DOES 1-50 28|| were also to pay TREEHOUSE and BEACON a combined “Overhead Fee” of One Million i 2 ‘COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL ooh 4 Paget 2 - Dee ID = 1668722606 ~ Doo Type = on rage 3 0f 22) 1|[Dollars ($1,000,000), to be split as determined by TREEHOUSE and BEACON. Additionally, 2|| KYLIN and DOES 1-50 were to pay all writers’ fees. 3 9. Pursuant to the terms of the CONTRACT, COSTNER, TREEHOUSE, BEACON, « 4|]and BERNSTEIN were to receive certain specified credits during the credit sequence of the 5|/PICTURE. 6 10, Pursuant to the terms of the CONTRACT, TREEHOUSE and BEACON were to be 7]| paid Twenty-Five Percent (25%) of any and all net profits from all sources after recoupment by 8]| the equity investors of 100% of their actual equity investment in the PICTURE plus a twenty percent (20%) premium thereon. 11, Pursuant to the terms of the CONTRACT, KYLIN and DOES 1-50 were to grant to ‘TREEHOUSE and BEACON equity or options in KYLIN, or a subsidiary, affiliate or successor company of KYLIN engaged in the film, television or other content development, production, and/or distribution business that goes public in any equity market anywhere in the world, provided that COSTNER and BERNSTEIN fulfilled their material obligations provided for in the CONTRACT. Mannie Kass Eutnop, RaniRez, TRESTER ur a 12, After the parties signed the CONTRACT, KYLIN and DOES 1-50 issued various press releases and made other public announcements that COSTNER, TREEHOUSE, BEACON, and BERNSTEIN would be involved in the production of the PICTURE with KYLIN and DOES | + 1-50, KYLIN and DOES 1-50 issued these press releases and made these announcements in order | Bs to induce investors to invest in the PICTURE and in order to enhance the name, reputation, and standing of KYLIN and DOES 1-50 and the PICTURE in the international entertainment community and with the public, and the plaintiffs ere informed and believe and thereon allege that KYLIN and DOES 1-50 did obtain investments in the PICTURE as a result of issuing these press releases and making these announcements. 13, During the Shanghai International Film Festival, held between June 12, 2016 and June 19, 2016, KYLIN and DOES 1-50 promoted the PICTURE to the public and to potential investors by indicating that COSTNER, TREEHOUSE, BEACON, and BERNSTEIN would be involved in the production of the PICTURE with KYLIN and DOES 1-50. KYLIN and DOES 1- 3 COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL ‘oct 2 ragey 3 - Doc Zp = 1668722606 - Dos Type = OME erage 6 of 22) woe awe 10 u 2 3 4 is 16 7 18 19 20 a 2 2B 4 25 7 28 50 dic this in order to induce investors to invest in the PICTURE and in order to enhance the name, reputation, and standing of KYLIN and DOES 1-50 and the PICTURE in the international entertainment community and with the publi, and the plaintiffs are informed and believe and thereon allege that KYLIN and DOES 1-50 did obtain investments in the PICTURE as a result of promoting the Picture to the public and to potential investors by indicating that COSTNER, TREEHOUSE, BEACON, and BERNSTEIN would be involved in the production of the PICTURE. 14, Pursuant to their obligations under the CONTRACT to oversee the re-write of the existing sereenplay of the PICTURE, TREEHOUSE and BEACON identified an experienced sereenplay writer, Den Gordon ("GORDON"), to KYLIN and DOES 1-50 as a potential writer to re-write the screenplay for the PICTURE. After interviewing GORDON and reviewing screenplay notes provided by GORDON to KYLIN and DOS 1-50, KYLIN and DOES 1-50 ‘engaged GORDON to rewrite the screenplay pursuant to a writer’s agreement between GORDON and KYLIN and DOES 1-50. Thereafter, wth the explicit approval of KYLIN and DOES 1-50, KYLIN and DOES 1-50 engaged COSTNER to re-write of the draft of the screenplay of the PICTURE written by GORDON. COSTNER had completed re-writing 104 pages of the screenplay when he was instructed by KYLIN and DOES 1-50 to cease re-writing the screenplay. 15. Onorabout August 29, 2016, KYLIN and DOES 1-50 informed TREEHOUSE and BEACON that they no longer wanted COSTNER, TREEHOUSE, BEACON, or BERNSTEIN to be involved in the production of the PICTURE or to otherwise fulfill their obligations under the terms of the CONTRACT, and that KYLIN and DOES 1-50 would not be fulfilling their obligations under the terms of the CONTRACT. In response TREEHOUSE and COSTNER informed KYLIN and DOES 1-50 that they either had already fulfilled some or all of their obligations under the CONTRACT, or were ready, wi i, end able fo fulfill any and all of their remaining obligations under the CONTRACT. 16. Todate, KYLIN and DOES 1-50 have not fulfilled all of their obligations owed to [TREEHOUSE and COSTNER under the termns of the CONTRACT, including, but not limited to, payment of moneys to TREEHOUSE or COSTNER other than the sum of One Hundred Fifty 4 ‘COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL ‘Boot 1 Pago 4 - Dec TD = 2668722606 ~ Doo Type ~ OTHER (rage 5 of 2 Mayena Seas Euirod, Raminez, TRESTER us ' 10 ul 12 B 4 15 16 n 19 20 a 22 B 24 25 26 2 28 Thousand Dollars ($150,000.00) that was previously paid to TREEHOUSE by KYLIN and DOES 1-50 through BEACON. EIRSTCAUSEOFACTION ANTICIPATORY BREACH OF CONTRACT (by all plaintiffs against all defendants), 17, Plaintiffs refer to and incorporate herein by this reference the allegations contained |in the preceding paragraphs of this complaint, as though fully set forth herein. 18. In doing the things alleged herein, KYLIN and DOES 50 have totally repudiated the CONTRACT, and to date their repudi 19. At the time TREEHOUSE and COSTNER were notified by KYLIN and DOES 1- tion has not been retracted., 50 of their repudiation of the CONTRACT, TREEHOUSE and COSTNER had performed all of their obligations under the terms of the CONTRACT due and owed to that time, and were ready, willing, and able to perform all of their obligations remaining to be performed under the terms of the CONTRACT. ; 20, Asaresult of the repudiation of the CONTRACT by KYLIN and DOES 1-50 inclusive, TREEHOUSE has been damaged in the amount of One Million Dollars ($1,000,000) jand COSTNER has been damaged in the amount of Three Million Dollars ($3,000,000), less the |sum of One Hundred Fifty Thousand Dollars ($150,000) previously paid to TREEHOUSE by KYLIN and DOES 1-50 through BEACON. In addition, TREEHOUSE and COSTNER have. been damaged by the loss of the specified credits to be included during the credit sequence of the PICTURE. TREEHOUSE has also been damaged by the loss of the percentage of the net profits ‘that was to be paid to it, and by the loss of the equity or options in KYLIN, or a: Subsidiary, affiliate or successor company of KYLIN, TREEHOUSE and COSTNER have suffered additional special and consequential damages in an amount to be proven hereafter. 21, Pursuant to the terms of the CONTRACT, TREEHOUSE is entitled to recover its attomey's fees and costs incurred in litigating this action. 5 COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL rn ‘oat 1 Paget & Goo 1D = 1668722606 ~ Dos Type = ona cose 6 ot 22) ; 1 ‘SECOND CAUSE OF ACTION \ 2 DECLARATORY AND INJUNCTIVE RELIEF | 3 (by all plaintiffs against all defendants) 22. Plaintiffs refer to and incomporate herein by this reference the allegations contained in the preceding paragraphs of this complaint, as though fully set forth herein. 23. An actual controversy has arisen and now exists between TREEHOUSE and COSTNER and by KYLIN and DOES 1-50 inclusive concerning their respective tights and duties ‘under the terms of the CONTRACT, and accordingly TREEHOUSE and COSTNER desire and 10 }] request a judicial determination of those rights and duties. u 24. TREEHOUSE and COSTNER request a declaration as follows: 12 2) That KYLIN and DOES 1-50 have totally repudiated the CONTRACT and 13 || that TREEHOUSE and COSTNER are no longer obligated to perform their obligations as set cut 14 fin the CONTRACT; 15 b) That KYLIN and DOES 1-50 owe COSTNER the sum of Three Million Manninc&Kass Eunod, RAMIREZ, TRESTER ws 16|| Dollars ($3,000,000), less the sum of One Hundred Fifty Thousand Dollars ($150,000) previously 17||paid to TREEHOUSE by KYLIN and DOES 1-50 through BEACON; 18 ©) That KYLIN and DOES 1-50 owe TREEHOUSE the sum of Oné Million 19 || Dottars ($1,000,000), 20 4d) Thatif the PICTURE is produced, TREEHOUSE and COSTNER are to 21 || receive during the credit sequence of the PICTURE the credits specified in the CONTRACT; 2 ©) That if the PICTURE is produced, TREEHOUSE is to be paid Twenty-Five 23 | Percent (25%) of any and all net profits from all sources after recoupment by the equity investors 24 | of 100% of their actual equity investment in the PICTURE plus a twenty percent (20%) premium 25 || thereon; and = 26 ) That KYLIN and DOES 1-50 are to grant to TREEHOUSE equity or j 27 [options in KYLIN, or a subsidiary, affiliate or successor company of KYLIN engaged in the film, 28 || television or other content development, production and/or distribution business that goes public 6 ‘COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL Doct 1 Pagct 6 = Zoo 3D ~ 1669722506 - Doo tye = om age 7 of 223 1 in any equity market anywhere in the work, and a further declaration es tothe specific equity or options to be granted by KYLIN and DOES 1-50 to TREEHOUSE. 25. A judicial declaration is nevessary and appropriate at this time under the circumstances in order that TREEHOUSE and COSTNER and KYLIN and DOES 1-50 may ascertain their rights and duties towards each other, which will have the practical effect of informing the parties’ future conduc and limiting the possibility of future lawsuits between the parties on the issues to be addressed by the requested declaration, ‘THIRD CAUSE OF ACTION FRAUD 1 nl (by all plaintiffs against all defendants) 12 13 26, Plaintiffs refer to and incorporate herein by this reference the allegations contained 14 in the preceding paragraphs of this complaint, as though fully set forth he is 27, TREEHOUSE and COSTNER are informed and believe and thereon allege that at Manninc Kass Eunop, Ramirez, TRESTER ur 16 some time prior to the opening of the 2016 Shanghai International Film Festival, KYLIN and 17] DOES 1-50 decided that they were going to repudiate the CONTRACT and refuse to fulfil their 18 || obligations under the terms of the CONTRACT. 19 28. KYLIN and DOES 1-50 failed to disclose this decision to TREEHOUSE and 20|] COSTNER and concealed it from TREEHOUSE and COSTNER until on or about August 29, +21 || 2016, when KYLIN and DOES 1-50 informed TREEHOUSE and BEACON that they no longer } 22 || wanted TREEHOUSE, BEACON, COSTNER, or BERNSTEIN to be involved in the production 23 || of the PICTURE or to otherwise fulfil their obligations under the terms of the CONTRACT, and © — 24]|that KYLIN and DOES 1-50 would not be fulfilling their obligations under the terms of the : 25 || CONTRACT. | 26 29. TREEHOUSE and COSTNER did not know of the concealed information until on “47h or about August 29, 2016, when KYLIN and DOES 1-50 disclosed the information to 28 || TREEHOUSE and BEACON. 1 ‘COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL oct 1 Pagel 7 ~ Doc ID = 2668722606 - Doc Type = OTHER rage 8 of 22) 1 30. KYLIN and DOES 1-50 intended to deceive TREEHOUSE and COSTNER by 2] concealing this information. 3 31. Had the concealed information been disclosed in a timely manner, TREEHOUSE 4|{and COSTNER reasonably would have behaved differently, including, but not limited to, 5 | instructing KYLIN and DOES 1-50 not to issue press releases or other public announcements that ; 6 || COSTNER, TREEHOUSE, BEACON, and BERNSTEIN would be involved in the production of the PICTURE with KYLIN and DOES 1-50, and instructing KYLIN and DOES 1-50 not to 8||| promote the PICTURE at the 2016 Shanghai International Film Festival by indicating that 9 || COSTNER, TREEHOUSE, BEACON , and BERNSTEIN would be involved in the production of 10]|the PICTURE with KYLIN and DOES 1-50. u 32, The concealment by KYLIN and DOES 1-50 of this information was a substantial factor in causing monetary harm to, and harm to the reputation of, TREEHOUSE and COSTNER, 33. In taking the actions described above, KYLIN and DOES 1-50 intended to cause 14] injury to TREEHOUSE and COSTNER or acted with a willful and conscious disregard of the ss TRESTER wr 5 Se 15 || rights or safety of others, including TREEHOUSE and COSTNER, and subjected TREEHOUSE . 16 || and COSTNER to crue! and unjust hardship in conscious disregard of their rights, and intended to Mane Europ, RAmineZ, 17|| deprive TREEHOUSE and COSTNER of property or legal rights or otherwise cause them injury. 19 FOURTH CAUSE OF ACTION i 20 (COMMON COUNT: GOODS AND SERVICES RENDERED. | a (by plaintiff COSTNER against all defendants) i B 34. Plaintiffs refer to and incorporate herein by this reference the allegations contained 2 2aVlin the preceding paragraphs ofthis complaint, es though lly set forth herein, ete 35. KYLIN and DOES 1-50 authorized and approved having COSTNER re-write the S296 || screenplay of the PICTURE, ‘The re-writing of the screenplay of the PICTURE was done at the 27 || request of, and for the benefit of, KYLIN and DOES 1-50. 28 |r ! 8 COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL ‘pect 2 Pagel 8 - Doc 1D = 1668722606 ~ Doe type = on wage 8 9f 22) Mannine&iKass Eitnop, RAMIREZ, TRESTER we 10 n 12 B 4 is 16 W7 18 19 20 a 2B 24 6 a 8 36, COSTNER performed the re-writing of the screenplay of the PICTURE as requested, until instructed to stop by KYLIN and DOES 1-50. 37. KYLIN and DOES 1-50 have not paid COSTNER for the re-writing of the screenplay of the PICTURE, despite COSTNER having requested such payment. 38, The reasonable value of the services that were provided by COSTNER to KYLIN ‘and DOES 1-50 — to wit, the re-writing of the screenplay of the PICTURE —is in an amount to be proven hereafter. PRAYER FOR RELIEF WHEREFORE, TREEHOUSE and COSTNER pray for relief against KYLIN and DOES 1-50, jointly and severally, as follows: ‘As to the First Cause of Action: To TREEHOUSE, the sum of One Million Dollars ($1,000,000). 2. ToCOSTNER, the sum of Two Million Eight Hundred Fifty Thousand Dollars ($2,850,000). 3, To TREEHOUSE and COSTNER, the value of the loss of the specified credits to be included during the credit sequence of the PICTURE, according to proof. 4, To TREEHOUSE, the value of the loss of the percentage of the net profits that was to be paid to it, according to proof. ' 5, To TREEHOUSE, the value ofthe loss of the equity or options in KYLIN, or a subsidiary, affiliate or successor company of KYLIN, according to proof. 6. To TREEHOUSE and COSTNER, the value of the special and consequential damages they have suffered, according to proof, 7. To TREEHOUSE, the value of the attomey’s fees and costs incurred in litigating this action. iit 9 COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL, Dock 2 aged 9 Doo 30 = 2660722606 - Doo Type = OnER (rage 10 of 22) 1 4s to the Second Cause of Action: 2 8. A declaration concerning the respective rights and duties of TREEHOUSE and 3|| COSTNER and KYLIN and DOES 1-50 under the terms of the CONTRACT, declaring that: 8) That KYLIN and DOES 1-50 have totally repudiated the CONTRACT ond 5 | that TREEHOUSE and COSTNER ate no longer obligated to perform their obligations as setout | | in the CONTRACT; ; b) That KYLIN and DOES 1-50 owe COSTNER the sum of Two Million Eight Hundred Fifty Thousand Dollars ($2,850,000); ©) That KYLIN and DOES 1-50 owe TREEHOUSE the sum of One Million 10] Dotlars ($1,000,000); nt That ifthe PICTURE is produced, TREEHOUSE and COSTNER are to 12 ll receive during the credit sequence of the PICTURE the credits specified in the CONTRACT; 3 ©) That ifthe PICTURE is produced, TREEHOUSE is o be paid Twenty-Five 14} Percent (25%) of any and all net profits from all sources after recoupment by the equity investors 15 [of 100% of their actual equity investment in the PICTURE plus a twenty percent (20%) premium 16 || thereon; and - "7 {) That KYLIN and DOES 1-50 are to grant to TREEHOUSE equity or 18 options in KYLIN, or a subsidiary, affiliate or successor company of KYLIN engaged in the film, | 19} television or other content development, production and/or distribution business that goes public 20 fin any equity market anywhere inthe world, anda further decaraton as to the specific equity or 21 |J options to be granted by KYLIN and DOES 1-50 to TREEHOUSE, 2 B As to the Third Cause of Action 4 8, To TREEHOUSE and COSTNER, compensatory. damages, according to proof, 28 9. To TREEHOUSE and COSTNER, punitive damages, according to proof. 26 | 27| tOEr St 28 |r . 10 = ‘COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL, och 2 fagee 10 - Doe Ab ~ 2660722606 - Doc Type - OmIER (age ot 22) ss RESTER tx" Mannie Euinop, Raine,” 10 u 12 13 14 1s 16 7 18 19 20 a 2 23 4 25 26 7 28 As to the Fourth Cause of Action: 10, To COSTNER, the value of the writing services provided and performed by |COSTNER in connection with the rewriting of the screenplay for the PICTURE, according to proof. As to all of the causes of actic 11. Pre-judgment and post-judgment interest in the maximum amount allowed by law. 12, The costs of suit herein incurred. 12, Such other and further relief as this Court deems necessary, just, and proper, DATED: October 24, 2016 Steven J. Renick, E Sevan Gobel, Esa. Attorneys for Plaintifts, ‘TREEHOUSE FILMS, LLC and KEVIN COSTNER ui ‘COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL i ‘Boot 4 Paget Li ~ Doe 1D = 1668722606 ~ doe Type = OTE rage 12 ot 22) MansuvoQilass : é i 10 u 12 3 4 15 16 W 18 19 20 a 2 4 25, 26 27 28 matter by jury. DATED: October 24, 2016 DEMAND FOR JURY TRIAL MANNING & KASS, ‘COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL Plaintiffs TREEHOUSE FILMS, LLC and KEVIN COSTNER hereby demand trial of this | | Sevan Gobel, Esq. Attorneys for Plaintiffs, ‘TREEHOUSE FILMS, LLC and KEVIN COSTNER 12 ‘och 2 Pagey 42 ~ Dee ID = 1668722606 - Doc Type = OMER (eage 2 of 22) EXHIBIT A Doe type 668720605, 8 ‘boat 1 Paget 13 rage 24 ot 22 BINDING LETTER OF INTENT ‘This Binding Lener of Intent (this “LOP) is entered into and made effeetive as of April 4, 2016 (the “Effective Date") by and among Kylin Pictures ("Kylin”), Treehouse Films, LLC (*Tyeehouse") and Beacon Films ("Beaton") end sets forth the basic terms of agreement between Xylin, Treehouse and Beacon to produce a theatrical motion picture currently tiled “Shanghai Sojourners” (the “Picture™). PREAMBLES i Kylin owas the Picture, which is developed based on e novel tied “Sojoumers", written by ‘Geling Yan (see altached Literary Agreement) Leo Shi Young, a US eitizea, owns the copyright ‘of the screenplay of Shanghai Sojoumers”. Kylin has obtained from the Chinese government The Co-produetion Perms (Permit No, 2016- 001, see attached), has developed the Picture and intends to finance the production in 2016. A single purpose company, Shanghai Sojoumers Productions LLC, has boon established by Kylin in California, USAwhich as or wiil obtain the rights to the curent screenplay and produce ‘the Picture as provided in this LO! For good and valuebte consideration, the receipt and sufficiency of which are hereby acknowledged, the parties inthis Letter of Intent (*LOY") agree to jointly produce the Picture ‘according to the basic terms as follows: provide the services of Army Bernstein (“Bemstela") to produce the Picture, Kylin will cash flow and fully finance the development, prodection and distibution of the Picture, intead for ‘wide theatvical release It the US, China, and rest of the world. Kylin will'commence funding | | 1. Treehouse will provide the services of Kevin Costner (“Coster”) and Beacon will development and pre-production of the Picture prompdy following execution ofthis LOI. 2 ‘The partes agree that if required by actors, the director and producers of the Picture, XKylin will be required to put funds into an escrow account in order to obtain “pay or play” comenitments from such actors, ditetors and producers. 3. Trechouse and Beacon will have final cut outside of tho Greater China tenrtories (consisting of Mainland China, Hong Kong and Taiwan); provided, however, If Costner elects to direct the Picture, then Costier shall is all cases have final cut of the Picture. 4. Trechouse and Beacon will oversee the re-viite of the current screenplay that Is owned .. by Leo Shi Young, and will use commercially reasonable effort to find suitable actors and = B —— direotor, as wel as line producer, at are murually axceptuble to Treehouse, Beaoon and Kyfin, 'Kylin wall be responsibe forall reasonable devetopment costs, including but not Hinited to any S ‘writers’ fees, guild fringes and residuals and for the Overhead Fee to be pald to Treehouse andl 53 Beacon as provided in Section 5 below, Trechouss, Beacon and Kylin will discuss and mutually m ‘agree in good faith to adjusting the current production budget for the Picture of US$42,000,000 depending on which actors and diredtor are selected. Compensation, As Producers of the Picture, be oc 1 Faget 24 = Doo ID = 1668722606 - doe Type = OTR Geage 18 of 22) Costner and Bernstein ate entitled to a combined Producers’ Fee of US$3,000,000, which will be split as determined by Costner and Bemstein, This Producers’ Fee shall be a line item in the Picture’s budget. Also as a line Hem in the Budget, ‘frechouse and Beacon will be paid a combined Overhead Fee of USSI,000,000, of which will be split between them as determined by ‘Treehouse and Beacon. 5. Compensation. As Producers of the Pioture, Coster and Bemstein are entitled to a combined Producers’ Fee of US$3,000,000, which will be split es determined by Costner and ‘Bernstein, This Producers’ Feo shalt be a lino item in the Plcrare’s budget. Also as ¢ line item in ‘the Budget, Treckouse and Benoon wil be paid a combined Overhead Fee of US$1,000,000, of which will be split between them as determined by Treehouse and Beacon. 6 Credits. 46.1 Kylin will receive a company credit as “A Kylin Pictures Release” on single card with animated logos and 62 Teeshowse end Beacon will esch receive or be entitled to designete & production company credit on separate cards with animated logos in the first and second position (es determined and agreed by them) and 6.3 Costner and Bernstein will exch receive Producer credits on separate cerds in the first and second position (6s determined and agreed by them), and each will be entitled to designate up to two (2) Executive Producer eredits (Rod Lake is designated for one executive producer credi] in positions to be mutually agreed upon by the parties 64 Kyfin will he entitled to receive or designate a production company credit on a single cand in a third position behind thoso of Trechouse-and Beacon, and to designate no more than two (2) individual producer credits in a third and fourth positfon behind those received or designated by Costner and Bernstein, and such executive producers, end lesser ctedits to as are mutually agreed upon by all parties in good faith. 6.5 Subject io any applicable WGA or other applicable guild eutes, and also subject to any credits to be received by the weiter(s) who rewrite the current screenplay, Leo Sbi Young will receive a single or shared “Scteenplay by" credit on separate card and Goling Yon will eosive “Based on a novel by” ereéit on separate catd, 7. Peolit Participation. Any and oll nstprofits from all sources Guetuding, but not Limited to, ‘worldwide distribution fn all media, tax rcbates and incsntives, Besnsing and merchendising, ele), after recoupment by cquity investors (Kylin and/or its investors) of 100% of thir asteal equity investment in the Pichue plus a twenty percent (20%) premium thereon, will be shared, and paid pro rata 4s follows: (1) 25% to Kylin, (2) 25% to Treehouse and Beacon (to be shared in the manner apreed upon by them), and (3) 50% to all equity investors (whether Kylin, its investors or say other equity investors). Worldwide gross receipts will be paid to acottection ‘och 2 page 15 ~ Deo 1D = 1668722005 ~ Doc Type = CmER (rage 26 of 22) account manegement company such 35 Fintage House or Freeway (pre-proved) or snether collection account management company mutually agreed upon by all of the parties, 8. If Costnet is interested in dirceting the Picture, his compensalion package will be a separate negotiation; provided, however, thal Kevin's directing the Picture is not a condition to this LOL. If Costner directs the Picture, Costner will receive the sole “Directed by" exedit for the Pronure. 9, Subject to their reasonable professional and personel availability, terms for the possible attendance by Coster and/or Bernstein to attend the 2016 Shanghal Iateraational File: Festival (/SIFF") to be held from June 12" - 19°) will be discussed and negotiated by the patties. 10, Provided that Costner and Bernstein {ull their material obligations provided for in this, LOI, Kylin will grant equity or options in Kylin, or a subsidiary, affiate or suocessor company of Kylin engaged in. the film, television or other content development, production and/or distribution business that goes public in any equity market anywhere in the worl, to Trechouse and Beacon or their respective designees or assignees. AL, This LO} shall be governed by and eonstrocd in accordance with the Inws of the State of California, Unites States of Ametica, Any suit or proceeding brought to enforce or iniezpcet this LOL of say of the terms or provisions hereof shall be brought and maintained exclusively in the. appropriate state or federal court located in Los Angeles, California, and the parties each hereby intevocably consent tothe exclusive jurisdiction and venue thereof for all such purposes. Should any party commence any legel action, suit or proceeding to enfocee or interpret this LOT ot any of the terms or provisions hereof, then in addition to any olher rights or remedies that may be ‘awarded to the provailing party or partes therein, the prevailing panty or pasties shall be entitled to have and recover from the losing party or parties such prevailing party's or parties" actual -xtommeys’ foes and costs incurred in connection therewith, ‘Althoogh tho parties intend 4 enter invo more formal agreements containing the terms provided for a this binding LO}, unless and until such tee. asthe parties eiter lito such mere fornal agreement, | this binding LOI is the binding agreement of the parties regarding the subject ator of this LOI, An wimess whereof, the parties huve executed this binging LOI and have made it effective as of the Effective Date firs above written. Kylin Pictures LLC Beacon Films L&C By, Tne. eee SE he ee Name; Sbivouns "Gi: Zurn tke, Names peampal Beeperess) “Titlec_Miee President Title; 4404 OR ‘tits:_ Chan conan ‘Paget 16 ~ noc 10 = 1668722605 - Doc ype = OTHER (rage 27 of 2) os e cu-019 TORT RTO TOS a TT A CRT ETT [Jeffrey M. Lenkov, Esq. (SBN 156478) ‘Sevan Gobel, Esq. (SBN 221768) MANNING & 3S ELLROD RAMIREZ TRESTER, LLP 801 S. Figueroa Street, 15th Floor 4 ‘Los Angeles, California 90017 i rmuserosto: (213) 624-6500 axnas_ (213) 624-6999 superoh (LED ancuterrosmunat_ Plait, TREEHOUSE FIUMS, LLC and KEVIN COST Baro Couto Catena ‘supemon cOURT oF curs counry oF LOS ANGELES tau ! snares ILM. HSE OCT 26 2018 errmosncone Los Angeles, aan aus Central Distt ‘Shou R, Cane, Exapuve OticerClerk CASE NAME: TREEHOUSE FILMS, LLC and KEVIN COSTNER ey Deputy v. KYLIN PICT! cy Alvaro CIVIL CASE COVER SHEET ‘Complex Case Designation AE NRER: Cel ypintes “Cita (Counter 1 voinder (Amount, our Fed with fst appearance by defendant. | w00e Tee cco, Et Saal _Nicutucacerewarenty seams [Spe 38 460 | ims 1-6 lew must be completed (08 isratons on page 2 |. Check one box below for the case type that best describes this case: ‘ute Tot ona, Provsonaly Complex Givi Ligation Auto (22) LJ eresch of contractwarranty (08) (Gat, Rules of Court, rales 3.400-3.403), rtrd melo 66) Clee are cotecins 03) Antstaderegstion 08) ‘ier PuPDID (arena renyPropty : (cones ete 1) Darageirongtl Death) Tor eee TD mass ion) CL Jastestos (04) TDother conract (37) 2 Secunties ttigation (28) T)Produet tabiity (24) Real Property. E EnwitenmentaiToxic tor (20) Sets moprcie 5 Tenn donaninere (insurance coverage cis aang tom ne ore riromo ey denen) shoved pve comple Non-PUPDIWD (Other) Tort i wrongful eviction (29) ‘types (41) (Teusiness torvuta business practee (07) C—] omer ret property (26) Enforcement of Judgment (leivn rights (08) Unlawful Detainer 2) Enforcement of judgment (20) Soetomatien (13) ‘CTecemmeril (21) Miscellaneous Civil Complaint hrs Elrecitertee) Jreoen intettectual propery (19) CT ponags (38) (J other complaint (not spectied stove) (42) Crtesonl reaigee 25) Sed Roview iieetancus Cel Pelion ; {Joie er PDD a (25) dase oer (5) CT Tretetipmncapems greece | | Employment [PPetivon re: arbitration award (11) C—] Otner patton (not specified above) (43) {Ever einen 26 ite meat (02) other employment (15) | Other judicial review (39) ZThiscase (_) is [ac] isnot complex under ule 3.400 ofthe Califonia Rules of Cour the case is complex, mark the ‘2etors requiring excoptonal judicial management: ; 2 EY Toige number of separate represenes partes. (—] Lerge numberof winesses | >. Cl Ewensive moton practnralsngafeut or navel. Cearinaon wthelatedacfons pending inoneor more couts ; issues that wl be time-consuming to resoWve inter counties, stale or counties orin federal cout , (1) Substantial amount of documentary evidence _f [] Substantial postudgmentjuciiat supervision 3. Remedies sought (check al hat apply): a.) monetary b. (—] nonmonetary; decaratory or injunctive relief c. [) punitive 44, Number of causes of action (specify: Four Brach of Ceamet Delanln/ajcve Rell Fa; Crimea Count: Od and Serves Rend Tniscase (_] is Lx] isnot class action suit It there are any known coated cases, fle and serve a notice of elated case. (Ye ole: October 24, 2016 Jeffs vB ay use form CM-015) Tre Orr Wah 7 NOTICE Y [2+ Prainott must se his cover shoot with the fest paper fled inthe actin or proceeding (except small claims cases or cases fled AT" Gncer ne Probate Code, Family Cace, or Wellare and Institutions Code). (Cal. Rules of Court, rule 3.220) Failure to file may resut Insonctions. + Fle this cover sheet in action to any cover shost required by tocal court rue. I 1 iit case is complex under cule 3.400 el seq. of tho California Rules of Cour, you must serve a copy of his cover sheet on all t ‘ther partes tothe action or procaeding. { « Unless this is 2 coteations case under Pile 3.740 or a complex case, this cover sheet wil be used for statistical purposes ony i Fagan Civil CASE COVER SHEET, ae hotopre ka ‘Boot 4 Pages $7 = Doc 1D = 168722606 - Doe Type = OTIER ou oe = . unstel@ons on vow 70 coumcere rae MMe sueer cxtor0 70 Pants and Others Fling Firs Papers. you ae fing a rt paper (or example, a compan) in eh eae, ou must omplte ae ley lng wn your rt paper, te Chi Case Cover Sheet Cana on age . Tis ormaton wil be ued compe Sates abou he pes ard rambers of eats fed You must compl fons 1 #vough 6 on be Shak. nam 7, you sl chock nebo rine case iyp that best deseo tho case the eave fe bos a general and amo spent ype of eased in fem heck he mae spect one te ease has mp calses of aden, chock to box rt bax ness te primary cause of acto. ‘Toast you comping te shee, evanploso fe aces hal belong under each case type nem fare prowded blow. A cover Sheet mt be fled ony wh oul paper Faureto flea cover shot wih ret paper fled na cae may sujet pay, 1s counselor bth sactons under es 290 and 3.220 ofthe Clfoo Rules of Cou. ToParie in ele 3740 Collections Coss, A"coledlon cate" under e740 is defned as an aon or recover of moray owed Ine sufted be ceamn asl ote ian $25,000, excuse of eres and somays tees, ang om rarsacton hich propery, sees, or money was aequred on ceGk. A ctasions caso dos nt Indude an acon seeking te oloxng (1) ot Ezrnoges (2) pntvecamaes (9) ecovery eal propery, eee of escnal propery, r() a mudgent nt of atastrent The dentcaton os esc 36 8 nde 9740 Clacton cose on bs fom reas that wt be exam fom he poner Une ore vce ‘eautemenss ond ease management es, unless a Gefendent ls araspons leading, A tla 3140 cnecter cae wl be sb tothe roqlerers fr sone and ouahing@ negmert tarde 2.70, To Parties in Complex Cases, ln complex cases en, pres must ao wie the Ct Cate Cover Shot to designate wheter be {ass complex i's plank beeves te case complex uncer rue 3400 of be Calfonia Rules of Cour, ts mle ides by Serletng he eppcpia boxes nes tand 2a pl designates e ease ab complex the cover heat must be eed wth he Cormplat onal partes he acton. A defendant may fe an serve no ler than the be of frst appearance 8 jande ne Slane cesgraon, coser-desgration Wate cave fs ot compl othe paths made ro cesgration,«Sesgnaon hat the cose compen CASE TYPES aN EXAMPLES to Tort contact Prov\sionsly Complex Chil Litigation (Cs. ‘Alo 2)~Persaal jn Prepery gh of Cnenaarany (8) Rtas of Court Rules 3400-2.409) ‘Damogeliiengfl Death razr of Reraitesce ‘Anta rade Regulation (3) une (0 “ann td ear Scearctn Geo) care inaves an areied con atest Cains invohieg Mes Tot (40) trata clan sujet to ne ee Seovies igaton (28) ‘rbtran, chek ttm trot gauze oaalgerea) EnvvonmentaVToi Txt 20) ‘aad aay, Negi re ourtce Covooge Oui ter PUPDIND Personal i ‘nar Brent ofConracvieranty (arsrg tom posioaly comer Bropery Damagetngtl cet ea, ey ve rn £020 jp ited obo) 44) Am ca EEE Caren EMH, See 7 Inwance Covers ot proviso nt Product Lab (rt abodes er ‘ere (8) ‘Conese of Judgment fron. toriclensironmenta) (24) ‘Auto Subrogation ee eee esea ityseis 3) omer Sele Sate dgment Neceaipractee Otero iran ry hd Physi 8 Sugeone na : he acon ie ele StherGetoe Dispate PetteniGetcaton of Eby of ‘tairosiee Real Propeny “gent on Unpaid Taxes ae onan ee ‘ripen Oomeiwerse (vie Enereements Juagment Premiges Lady (09, ‘ne a) ip ‘Condernason (34) rang Evesn (33) ‘cote Miceetianeous Givi Complaint ett Streres Proper (oa aust tbe (25) wc ens dot ronfeone "ne Posceson ace rope StrCompare seco’ veg nc) Nongap Foecoowe stove) (2) ae Ses nee vee” shear Seatages hn atte! treaty) wetnnte oner Pron UnawatDtaer aaa onsPuPOM® (ter Tort anmesal Oca anf Compl SonneneTWetr Base reser (2) comer Ou tt race 7) Drag (0 ie ato noha! ronda) Ch Rais (€,leeriminatin, crag, check tiem; cerns, need fateh epee Janeovs Civ Petion erassmead 08). Judi Roview o Perpeip ord Capea “oetamaton (eg and hse Fore (05) ome ae a3) Pettion Re: Atbitration Award (11) ‘above) (a3), ae Feu (36) Vist ot wansate (C2) apo) 63) ‘Binal Pepey (1 ‘orenarare Mandan alncromet | 2 tesions Nee (25) Wie anenmvs on Und St ioanlce voerce Legal Malpractice: ‘Case Matter pthogs ‘Ofer Prolersona Mapracicn weber ited Cou Care ent eat Laategertatlas mh — Pefition for Name Change (tor Non PUPDIWD Tort (35) (ther Judi Review (99) Pelion for Ralf rom Late Employmant ‘eile of Heath Offcer Order ten ‘cnet Termination (98) ce of Appes-Lsbor ce iver Employment (15) ‘Commise rer Appeals Other Gv Petion ore aay HT CIVIL CASE COVER SHEET Panett Doob 1 age 28 ee xb ~ 1662722606 - neo Type = OTR age 19 or 22) ‘Sear mE TREEHOUSE FILMS, LLC and KEVIN COSTNER exsE une i v. KYLIN PICTURES me get CIVIL CASE COVER SHEET ADDENDUM AND ‘STATEMENT OF LOCATION I! (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) ‘This form Is required pursuant to Local Rule 2.3 in all now civil ease flings Inthe Los Angoles Superior Court. Step 1: After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in ‘Column A that corresponds to the case type indicated in the Civil Case Cover Sheet, ‘Step 2: In Column B, check the box for he type of action that best deserves the nature of the case. ‘Step 3: In Column C, ciel the number which explains the reason forthe cout fing location you have chosen, ‘Applicable Reasons for Choosing Court Filling Location (Coluran G) \ cess aonsmaetnbeSay Ne Cot Cleeve pir | 2, Permissive fling in cena sit. {Location wherein dlendantkespondent unaons whely. 53. Locaon whee eavte of soton arose, 8 Location wnere ona or mote of tepals reste 4 Mandotorypereona yur fing North Ostet 10.Locaton of Labor Commissioner Ofc, 5. Loceten nhere prfonmancerequted or defendant cosies 11.Mandotory ing locaton (Hub Cases ~ nla deter inited rnon-colecton, tite catecton, or pecsoal nur) 6. Locaton of reper or permanent garaged veil, A B i c case Cover set ype ct Acton Apteati Resors- Category No, (check ony one) Ben Sup SAbowe i ‘uo (22) I aric0 wor venen -Persenal cyroveny DanageMrerst beam [1.411 $F eanresitcne) | Jart0 Pera mney Onogeergt Dea —Unnsued ars 141 1 aeoro asbens Pronery Darase +i EB ‘Aatestos(0) | yarant asbestos - Paranal nung Dest aH 2's | rrewetuasey 20) |[)arzeo Prose Unnty ret asenes roctenvtonment) an : 3 ra aso anes eee Se wen EB | Mesetvcirasce 49) | arzto omer Peesena Hea Cae Mspaice want Be 3 5 over Pexonal [1 A7260 Premises Listy (o9. stp an fat) Att ag Injury Proery 7230 intentions! Bosly inunsPropary DamagerWronglt Death (es. att ZS | comaternersys eee rencom ii ‘Death (23) | arer0 nenons nleton of Emotional Distress | areze one Pern bryPropety Osmageongl Death Taeiv so Reva) CIVIL CASE COVER SHEET ADDENDUM Tocal Rue 23 USC Aproved 504 ‘AND STATEMENT OF LOCATION Page tof ‘Doct 1 ages 19 - Doe ED = 1668722506 - Doc Type = OZER ceage 20 ot 2a sow RE“TREENOUSE FILMS, LUC and KEVIN COSTNER ose Mee v. KYLIN PICTURES. ivi Gass Cavers eee ry CaeGOnY NO gp | nen I actan ones ConmertausnssTot(ittautbresheteonree)—|1,2.3 B= | onemenw(on —_ [[)attos cvrghstiserninaon : nae By oe ES | ovematoncia) __|[—2asoto etenaton ended 42.3 53 a8 Fd(0) neo Fd ro oc : BB | mtesont wepiomee 2s) |) A007 Le Mapstce 123 58 J ncasa ctr Pratessiona practice (ot medal regal 128 ‘onertss)__ | aaeas oternin Pecos ninjPrceny Oarage on 12.3 [tera Temraton G5) [LT A037 Weng Temoibn z : FT ce empamensa [EA Oe Enporen Canptnt Cae i 123 i Empormert (5) | qgioa Later Commissioner Appeals i ‘a [1] 6004 Breach of Renta ease Contract (not unlawhut detaifer or wrongh | 2, § Beret oaay Breach of Conuec Watanty 177 prone contracatranty Breach eter Pant ro taustfegtgence) |S | (pot insurance) |) 46019 Negligent Sreach of Contractaeranty (x0 fraud) 128 i 438 I as028 oer Breach of Contacananty (ro aut er 22) 1 | comcwstey [EIA cae ; : i atot2 oer Prensa NoaCotecios Cate é (1 as024 conections Case-Puchaged Debt A (Charaed OF Conumer| Debt Esasertanrtonienanie ch Insurance Coverage (18) |] A6016 Insurance Coverage (not complex) e [a A8009 Contactn Face : coniecenvactean —|[Dasost Torousinetence |] aso27 otter Contract Disputelnat ecohnsurneataualegignee) [REESE Siew necromeacoarwam hemi Jea | orpeteneionn) [Jaan wont Bicton Case 28 3 inset wotgge Fete : 26 © | omerreat Property (28) |(—] asosz cuiet Tile 26 = [cote ut Popa tent ane, ten tron) | 28 1B [PsmetOemgerConmercet[[—Jaese1 Unaw Deane-Conmecil tangs er wang even) [6.31 1 [Breer Renzens | papn uneven Renan ctanaeerwerafeveten) [6.1 ET Bierman [scour unos osaner Pet toseave i 2a | unt Dewineons (8) [[] A602 Uniawia Oetaner-Oags 2611 ‘LAGIV 109 (Rev 2176) CIVIL CASE COVER SHEET ADDENDUM * ‘Local Rule 2:3. LASCAeroved 0204 Page et : AND STATEMENT OF LOCATION = ‘Doct 2 Page! 20 ~ Doc 10 ~ 1668722606 ~ boo type = oxER (rage 2 of 22) ‘sionrm TREEHOUSE FILMS, LLC end KEVIN COSTNER ASE NGER v. KYLIN PICTURES ‘Asset Farteliure (05) | [—] A106 Asset Forteiture Case ci 2.38 3 | Peston ntivaton i) [lasts Peten Conpecntmnvcie tiaton 26 i advert wn azine income ; 28 |. woruanato way | aoier we nasanuson inet Cut Cove Maer 2 3 | (.A6183 Writ- Other Limited Court Case Review = 2 (ter uct Revi 5) [TABI Other Wet via! Revew B 28 g_| raves Rogoten (nL TAGtma AnaiutradeRepaton 7 78 3 ‘Construction Detect (10) |] A6007 Construction Defect t 423 z i a seated ie Mass Tort | () 6008 Claims Involving Mass Tort 12.8 2 8 | sewitestiaion cn) [Tate sents upatn cae i 1ae 5 ene TeS any |Daense Tore TevEmvroamentst i 42.38 8 Insurance Coverage Claims T S| ESSERE” | ago14 insurance CaveragerSubregatin complex case ony) 1258 _JAst45 Sister Siete Judgment 2.511 ee passe nate wegen ; 26 ge ceiocenent | _DAHO7 Canes of udgnee (von mest ten) 29 BY | eksimeran | aato aansvtve oer Aum tiptoe)! ae Bs Jastte eetoncertse tr yf gmat et Tax 28 asta oni Enrcament of utgnen Core 208 a Tae PE Cane onc Rit ony Tae BE | omercempins —_ |[JAS#0 telnet Reet Ony (nt omesteharsesment) 28 i S| (het Spectied Avove) (42) |) asors cnr Commercial Complaint Case (rontartinoncometes) 142.8, S 8000 Omer Civ Complaint (non-tartinan-comples - 1.2.8 Papen Coston [atta Parnes on Cone Covearee Case 28 atte iv Harassment” 239 (7) 46123 Workplace Harassment 2.3.9 onecreston wey | #24 eterDepencen Ate en Cose 208 Spostesitow} ta) |[Jat00 evectonconet ‘ i —}As110 Petiion or Chonge ot NameiCnange of Gender ar Sacto Peton tr Rete to ate Ci tow a ()a6100 Other Civil Petition 29 LACIV 108 (Rev 2116) ‘CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LASC Approved 03:04 ‘AND STATEMENT OF LOCATION Page 3 of 4 ‘oct 4 aged 21 ~ Hoc TD = 2668722606 - Doc Type = oTIER age 22 of 22) [sonrime TREEHOUSE FILMS, LLC and KEVIN COSTNER esenaan v. KYLIN PICTURE! Step 4: Statement of Reason and Address Check the appropriate boxes forthe numbers shown under Column G forthe ‘ype of action that you have selected. Enter the address whichis the bass forthe fling locaton, including zip code (No adress required fr classaction cases). REASON: [1 ete, 9,4 5.6.7. 89.10.14} 1880 Century Park East on wae Jereooe: Los Angeles ca __|s0067 Step 5: Certification of Assignment: | cerily that this case is properly fled in the __ Central District of, the Superior Court of California, County of Los Angeles [Code GWv. Pros., §392 et seq, and Local Rule 2.3(a}(1)(E)]- Dated: October 24, 2016 Jn OF ATORIEWFLNGPART) Jeffrey M. Lenkov, E59 PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY ‘COMMENCE YOUR NEW COURT CASE: ‘1. Original Complaint or Petition. 2. Itfiing a Complaint, a completed Summons form for issuance by the Clerk. 3 4 Civil Case Cover Sheet, Judicial Counc form CM-010. . . Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev. o2n6). 7 Paymentin fullof the fling fee, urdess theres court order for waiver, partial scheduled payments, 6. Asigned order appointing the Guardian ad Litem, Judicial Council form CIV-010, i the plant or petitioner is a ‘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 Cierk. Copies of the cover sheet and this addendum ‘must be served along with the summons and complaint, or other initiating pleading in the case. 3 | Aci 109 (Rev 216) CIVIL CASE COVER SHEET ADDENDUM oval Ruie23 LAC Approved 03.04 AND STATEMENT OF LOCATION Page 4of4 : ‘post 2 Pagel 22 - Doc 1D = 1659722606 - noe Type = ONER

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