Court of Common Pleas of Philadelphia County For Prothonotary Use Only (Docket Number)

Trial Division
Civil Cover Sheet E-Filing Number: 1809039280
PLAINTIFF'S NAME DEFENDANT'S NAME
A. CHARLES PERUTO, JR. SIXX DEGREES MEDIA

PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS

2101 PINE STREET 1735 MARKET STREET SUITE 3750
PHILADELPHIA PA 19103 PHILADELPHIA PA 19103

PLAINTIFF'S NAME DEFENDANT'S NAME

ROC NATION, LLC

PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS

C/O CORPORATE CREATIONS NETWOR 1001 STATE
STREET NO. 1400
ERIE PA 16501

PLAINTIFF'S NAME DEFENDANT'S NAME

AMAZON DIGITAL SERVICES, LLC

PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS

C/O AMAZON.COM 410 TERRY AVENUE NORTH
SEATTLE WA 98109

TOTAL NUMBER OF PLAINTIFFS TOTAL NUMBER OF DEFENDANTS COMMENCEMENT OF ACTION

X Complaint Petition Action Notice of Appeal
1 5
Writ of Summons Transfer From Other Jurisdictions
AMOUNT IN CONTROVERSY COURT PROGRAMS

Arbitration Mass Tort X Commerce Settlement

$50,000.00 or less Jury Savings Action Minor Court Appeal Minors
X More than $50,000.00 Non-Jury Petition Statutory Appeals W/D/Survival
Other:
CASE TYPE AND CODE

1V - REPLEVIN

STATUTORY BASIS FOR CAUSE OF ACTION

RELATED PENDING CASES (LIST BY CASE CAPTION AND DOCKET NUMBER) IS CASE SUBJECT TO
COORDINATION ORDER?
YES NO

SEP 19 2018
A. SILIGRINI

TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Plaintiff/Petitioner/Appellant: A. CHARLES PERUTO, JR.
Papers may be served at the address set forth below.

NAME OF PLAINTIFF'S/PETITIONER'S/APPELLANT'S ATTORNEY ADDRESS

JAMES E. BEASLEY JR 1125 WALNUT ST

PHILADELPHIA PA 19107
PHONE NUMBER FAX NUMBER

(215)592-1000 none entered

SUPREME COURT IDENTIFICATION NO. E-MAIL ADDRESS

83282 jbj@beasleyfirm.com

SIGNATURE OF FILING ATTORNEY OR PARTY DATE SUBMITTED

JAMES BEASLEY JR Wednesday, September 19, 2018, 11:04 am

FINAL COPY (Approved by the Prothonotary Clerk)

COMPLETE LIST OF DEFENDANTS:
1. SIXX DEGREES MEDIA
1735 MARKET STREET SUITE 3750
PHILADELPHIA PA 19103
2. ROC NATION, LLC
C/O CORPORATE CREATIONS NETWOR 1001 STATE STREET NO. 1400
ERIE PA 16501
3. AMAZON DIGITAL SERVICES, LLC
C/O AMAZON.COM 410 TERRY AVENUE NORTH
SEATTLE WA 98109
4. AMAZON PRIME VIDEO
C/O AMAZON.COM 410 TERRY AVENUE NORTH
SEATTLE WA 98109
5. THE IPC GROUP
6007 SEPULVEDA BLVD.
VAN NUYS CA 91411
 THE BEASLEY FIRM, LLC Attorneys for Plaintiff
By: James E. Beasley, Jr., Esq. Filed and Attested by the
Louis F. Tumolo, Esq. Office of Judicial Records
I.D. Nos. 83282/314255 19 SEP 2018 11:04 am
A. SILIGRINI
1125 Walnut Street
Philadelphia, PA 19107-4997
215.592.1000
215.592.8360 (telefax)

A. Charles Peruto, Jr. : PHILADELPHIA COUNTY

2101 Pine Street : Court of Common Pleas
Philadelphia, PA 19103 : Commerce Program
Plaintiff, :
v. : SEPTEMBER TERM, 2018
:
Sixx Degrees Media : No.:
1735 Market Street :
Suite 3750 :
Philadelphia, PA 19103 :
:
And : NOTICE
:
Roc Nation, LLC :
c/o Corporate Creations Network, Inc. :
1001 State Street, No. 1400 :
Erie, PA 16501 :
:
And :
:
Amazon Digital Services, LLC :
c/o Amazon.com :
410 Terry Avenue North :
Seattle, WA 98109-5210 :
:
And :
:
Amazon Prime Video :
c/o Amazon.com :
410 Terry Avenue North :
Seattle, WA 98109-5210 :
:
And :
:
The IPC Group :
6007 Sepulveda Blvd. :
Van Nuys, CA 91411 :
:
Defendants.

THE BEASLEY FIRM, LLC

1125 WALNUT STREET
PHILADELPHIA, PA 19107 __________________________________________________________________
215.592.1000
215.592.8360 (FAX)
PERUTO V. SIXX DEGREES MEDIA, ET AL.
NOTICE
Case ID: 180902399
WWW.BEASLEYFIRM.COM
 “NOTICE”
You have been sued in court. If you wish to
defend against the claims set forth in the
following pages, you must take action within
twenty (20) calendar days after this complaint
and notice are served, by entering a written
appearance personally or by attorney and filing
in writing with the court your defenses or
objections to the claims set forth against you.
You are warned that if you fail to do so the case
may proceed without you and a judgment may be
entered against you by the court without further
notice for any money claimed in the complaint or
for any other claim or relief requested by the
plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER. IF YOU CANNOT AFFORD
TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
Philadelphia Bar Association
LAWYER REFERRAL & INFO.
One Reading Center
Phila., PA 19107
(215) 238-1701
THE BEASLEY FIRM, LLC
1125 WALNUT STREET
PHILADELPHIA, PA 19107
215.592.1000
215.592.8360 (FAX)
WWW.BEASLEYFIRM.COM PERUTO V. SIXX DEGREES MEDIA, ET AL.
NOTICE
"AVISO"
Le han demandado a usted en la corte. Si usted
quiere defenderse de estas demandas dispuestas
en las paginas siguientes, usted tiene veinte (20)
calendario dias de plazo al partir de la fecha de la
demanda y la notificacion. Hace falta asentar
una comparencia escrita en persona o con un
abogado y entregar a la corte en forma escrita
sus defensas o sus objecciones a las demandas en
contra de su persona. Sea avisado que si usted
no se defiende, la corte tomara medidas y puede
continuar la demanda en contra suya sin previo
aviso o notificacion. Ademas, la corte puede
decidir a favor del demandante y requiere que
usted cumpla con todas las provisiones de esta
demanda. Usted puede perder dinero o sus
propiedades o otros derechos iportantes para
usted.
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE. SI NO TIENE ABOGADO,
VAYA EN PERSONA O LLAME POR TELEFONO A
LA OFICINA QUE SE ENCUENTRA ESCRITA
ABAJO. ESTA OFICINA PUEDE PROVEER DE
USTED INFORMACION SOBRE EMPLEAR A UN
ABOGADO. SI USTED NO TIENE SUFICIENTE
DINERO PARA EMPLEAR UN ABOGADO, ESTA
OFICINA PUEDE PODER PROVEER DE USTED
LA INFORMACION SOBRE LAS AGENCIAS QUE
PUEDEN OFRECER SERVICIOS LEGAL A LAS
PERSONAS ELEGIBLES EN UN HONORARIO
REDUCIDO O NINGUN HONORARIO.
Asociacion de Licenciados de Filadelphia
Servicio de Referencia e Informacion
One Reading Center
Phila., PA 19107
(215) 238-1701
Case ID: 180902399
 THE BEASLEY FIRM, LLC Attorneys for Plaintiff
By: James E. Beasley, Jr., Esq.
Louis F. Tumolo, Esq.
I.D. Nos. 83282/314255
1125 Walnut Street
Philadelphia, PA 19107-4997
215.592.1000
215.592.8360 (telefax)

A. Charles Peruto, Jr. : PHILADELPHIA COUNTY

2101 Pine Street : Court of Common Pleas
Philadelphia, PA 19103 : Commerce Program
Plaintiff, :
v. : SEPTEMBER TERM, 2018
:
Sixx Degrees Media : No.:
1735 Market Street :
Suite 3750 :
Philadelphia, PA 19103 :
:
And : COMPLAINT IN REPLEVIN
:
Roc Nation, LLC :
c/o Corporate Creations Network, Inc. :
1001 State Street, No. 1400 :
Erie, PA 16501 :
:
And :
:
Amazon Digital Services, LLC :
c/o Amazon.com :
410 Terry Avenue North :
Seattle, WA 98109-5210 :
:
And :
:
Amazon Prime Video :
c/o Amazon.com :
410 Terry Avenue North :
Seattle, WA 98109-5210 :
:
And :
:
The IPC Group :
6007 Sepulveda Blvd. :
Van Nuys, CA 91411 :
:
Defendants.

THE BEASLEY FIRM, LLC

1125 WALNUT STREET
PHILADELPHIA, PA 19107 __________________________________________________________________
215.592.1000
215.592.8360 (FAX)
PERUTO V. SIXX DEGREES MEDIA, ET AL.
COMPLAINT IN REPLEVIN
Case ID: 180902399
WWW.BEASLEYFIRM.COM
 INTRODUCTION

1. Plaintiff A. Charles Peruto, Jr. (Mr. Peruto) is an attorney and represents

the Honorable Genece Brinkley.

2. On 30 May, 2018, the defendants interviewed Mr. Peruto for an upcoming

docu-series slated for 2019 release by the Amazon and Roc Nation defendants.

3. This docu-series is reported to address, at least in part, Robert Rihmeek

Williams (Meek Mill) and the criminal justice system.

4. After the interview concluded and Mr. Peruto instructed the defendants’

personnel to go off the record, the defendants’ personnel stated that they were off the

record, and pointed the camera towards the wall.

5. Unbeknownst to Mr. Peruto, the defendants’ personnel lied, and

continued to record the audio of the off the record conversation.

6. These defendants intentionally digitized and stored this intercepted off the

record conversation; this has made permanent the sounds of the conversation, and its

contents, in violation of 18 Pa.C.S. §5703.

7. These illegally obtained and digitized recordings fall under the definition

of property.

8. Defendants have also intentionally disclosed to others excerpts of these

intercepted, digitized oral communications, in violation of 18 Pa.C.S. §5703.

9. Pennsylvania’s Wiretap and Electronic Surveillance Law (18 Pa. C.S.A.

§5701, et seq) (Wiretap Act) is plain that Pennsylvania is a “two consent” state, meaning

that absent consent and permission by both parties to a discussion, it is a crime to

intercept the oral communication after Mr. Peruto instructed them to go off the record.

THE BEASLEY FIRM, LLC 2

1125 WALNUT STREET
PHILADELPHIA, PA 19107 __________________________________________________________________
215.592.1000
215.592.8360 (FAX)
PERUTO V. SIXX DEGREES MEDIA, ET AL.
COMPLAINT IN REPLEVIN
Case ID: 180902399
WWW.BEASLEYFIRM.COM
 10. Mr. Peruto specifically revoked any consent or permission that was given

for the on the record interview once that interview was concluded and the parties went

off the record.

11. These defendants illegally intercepted the entire off the record oral

communication; Mr. Peruto is an Aggrieved Person under the Wiretap Act, as these

defendants intentionally intercepted and permanently digitized his oral communication

for which there was no consent or permission.

12. The intercepted oral communication is Mr. Peruto’s property; this

Complaint in Replevin demands that these defendants immediately return this property

to him, with sole, temporary possession of digitized audio of the illegally intercepted

oral communication while this lawsuit is pending, and then permanent, sole possession

of the digitized audio of the illegally intercepted oral communication upon a final

judgment.

13. Mr. Peruto also demands that the defendants permanently destroy all

electronic or other files in which the intercepted oral communication exists, and not use

these intercepted oral communications for any purposes, including the upcoming Meek

Mill documentary series.

14. Therefore, pursuant to Pa.R.C.P 1701, Mr. Peruto brings this Action in

Replevin against the defendants, and in support thereof avers as follows:

PARTIES

15. A. Charles Peruto, Jr. is a citizen of this Commonwealth, an Attorney, and

resides at the identified address.

THE BEASLEY FIRM, LLC 3

1125 WALNUT STREET
PHILADELPHIA, PA 19107 __________________________________________________________________
215.592.1000
215.592.8360 (FAX)
PERUTO V. SIXX DEGREES MEDIA, ET AL.
COMPLAINT IN REPLEVIN
Case ID: 180902399
WWW.BEASLEYFIRM.COM
 16. Defendant Sixx Degrees Media is a media and marketing company

engaged by Meek Mill and, upon information and belief, is working with the co-

defendants in the upcoming Meek Mill Documentary Series; Sixx Degrees Media

operates out of the identified Philadelphia address.

17. Defendant Roc Nation, LLC is an entertainment company which does

substantial business in Philadelphia County, and has an address for service of process

identified above.

18. Defendant Amazon Digital Services, LLC is a branch of Amazon, and has a

service address listed above.

19. Defendant Amazon Prime Video is a branch of Amazon, and has a service

address listed above.

20. Defendant The IPC Corporation (IPC) is the entity that conducted the 30

May 2018 interview at Mr. Peruto’s Philadelphia office; a Ms. Kim (believed to be Hoo

In Kim of IPC) attended and participated in the interview. IPC has an address

identified above.

JURISDICTION AND VENUE

21. Pursuant to Pa. R.C.P. 1072 and 1073, Jurisdiction and venue is proper in

Philadelphia County as the Defendants all participated in the Mr. Peruto interview in

Philadelphia, and intercepted and digitized the off the record discussion in Philadelphia.

Further, all of these defendants conduct substantial and continuing business in

Philadelphia County.

THE BEASLEY FIRM, LLC 4

1125 WALNUT STREET
PHILADELPHIA, PA 19107 __________________________________________________________________
215.592.1000
215.592.8360 (FAX)
PERUTO V. SIXX DEGREES MEDIA, ET AL.
COMPLAINT IN REPLEVIN
Case ID: 180902399
WWW.BEASLEYFIRM.COM
 FACTS

22. As described in the Introduction, this Action in Replevin is brought to

recover property rightfully, and solely, owned by Mr. Peruto.

23. On 30 May, 2018, Hoo In Kim, on behalf of IPC and the other defendants,

conducted an interview of Mr. Peruto in his Philadelphia office for purposes of the

defendants’ upcoming Meek Mill Documentary Series.

24. Defendant IPC describes on its website the purpose of the Meek Mill

Documentary Series:

Meek Mill Documentary Series

Coming 2019 on Amazon

The six-part docu-series is targeted to premiere in 2019.

Philadelphia-based rapper Robert Rihmeek Williams was
released from jail in 2018 after serving nearly five months for
a probation violation — for popping a wheelie in an
Instagram video without wearing a helmet.

The docu-series will chronicle Meek Mill’s rise to fame and

his 10-year battle with Philadelphia justice officials, as well
as the larger issue of high incarceration rates for people of
color. Jay Z and Roc Nation are producing the untitled
project with IPC and documentary filmmaker Isaac
Solotaroff.

25. As part of the defendants’ preparation for this Documentary Series, they

sought, and were granted, an interview with Mr. Peruto.

26. This 30 May 2018 interview was conducted on behalf of all defendants.

27. After the interview was completed, Mr. Peruto instructed the interviewer,

believed to be Ms. Kim, to go off the record and to stop recording; she agreed and had

the camera turned towards the wall.

THE BEASLEY FIRM, LLC 5

1125 WALNUT STREET
PHILADELPHIA, PA 19107 __________________________________________________________________
215.592.1000
215.592.8360 (FAX)
PERUTO V. SIXX DEGREES MEDIA, ET AL.
COMPLAINT IN REPLEVIN
Case ID: 180902399
WWW.BEASLEYFIRM.COM
 28. Unbeknownst to Mr. Peruto, the audio was left on, intercepting the off the

record oral conversation and permanently digitizing the illegally intercepted oral

communication.

29. The only reason that Mr. Peruto agreed to participate in the off the record

discussion was because he withdrew permission and consent to intercept any aspect of

the oral communication.

30. Had these defendants informed Mr. Peruto that they were continuing the

audio recording, and intercepting the oral communication, he would have ceased the

discussion and instructed them to leave.

31. The defendants’ fraudulent representations to Mr. Peruto induced him to

speak so that they could intercept and permanently digitize the protected oral

communications.

32. These intentional misrepresentations resulted in valuable personal

property of Mr. Peruto’s illegally being acquired by the defendants.

33. These illegally intercepted and digitized oral communications were then

edited and leaked to the press so that Mr. Peruto’s off the record words would be

manipulated against him and his client, Judge Brinkley, and to maliciously further their

own agenda in maximizing the buzz and profitability of the upcoming Meek Mill

Documentary Series.

COUNT I
REPLEVIN

34. Mr. Peruto incorporates the prior paragraphs as if fully set forth herein.

THE BEASLEY FIRM, LLC 6

1125 WALNUT STREET
PHILADELPHIA, PA 19107 __________________________________________________________________
215.592.1000
215.592.8360 (FAX)
PERUTO V. SIXX DEGREES MEDIA, ET AL.
COMPLAINT IN REPLEVIN
Case ID: 180902399
WWW.BEASLEYFIRM.COM
 35. All defendants participated in the 30 May 2018 illegal interception of the

off the record oral communications, and permanently digitized the illegally intercepted

oral communication.

36. The digitized oral communication is in the wrongful possession of the

defendants.

37. The digitized oral communication is Mr. Peruto’s property.

38. Mr. Peruto has an immediate right to the sole possession of the digitized

oral communication.

39. All Defendants’ continuing wrongful possession of this digital recording

has resulted in it being altered and illegally distributed to third parties.

40. Defendants must return all digitized recordings of Mr. Peruto’s off the

record discussion, destroy any copies they have after returning Mr. Peruto’s property to

him, and further be prohibited from using any part of it in any way.

41. Mr. Peruto demands sole, temporary possession of digitized audio of the

illegally intercepted oral communication while this lawsuit is pending, and then

permanent, sole possession of the digitized audio of the illegally intercepted oral

communication upon a final judgment.

WHEREFORE, Mr. Peruto demands the following:

• judgment in his favor;

• an immediate return and sole possession of the illegally intercepted and

digitized oral communication while this lawsuit is pending;

• permanent, sole possession of the digitized audio of the illegally

intercepted oral communication upon a final judgment;

• confirmed destruction of all copies of the illegally intercepted, digitized

oral communication in any of the defendants’ possession;
THE BEASLEY FIRM, LLC 7
1125 WALNUT STREET
PHILADELPHIA, PA 19107 __________________________________________________________________
215.592.1000
215.592.8360 (FAX)
PERUTO V. SIXX DEGREES MEDIA, ET AL.
COMPLAINT IN REPLEVIN
Case ID: 180902399
WWW.BEASLEYFIRM.COM
 • a detailed listing of every third party who the defendants have in any way
made available or otherwise provided the illegally intercepted, digitized
oral communication;

• a prohibition against any and all of the defendants from using of any
illegally intercepted and digitized recordings in any fashion;

• such other relief as this Honorable Court deems appropriate.

NOTICE OF PRESERVATION OF EVIDENCE

PLAINTIFF HEREBY DEMANDS AND REQUESTS THAT DEFENDANTS TAKE

NECESSARY ACTION TO ENSURE THE PRESERVATION OF ALL DOCUMENTS,

COMMUNICATIONS, WHETHER ELECTRONIC OR OTHERWISE, ITEMS AND

THINGS IN THE POSSESSION OR CONTROL OF ANY PARTY TO THIS ACTION, OR

ANY ENTITY OVER WHICH ANY PARTY TO THIS ACTION HAS CONTROL, OR

FROM WHOM ANY PARTY TO THIS ACTION HAS ACCESS TO, ANY DOCUMENTS,

ITEMS, OR THINGS WHICH MAY IN ANY MANNER BE RELEVANT TO OR RELATE

TO THE SUBJECT MATTER OF THE CAUSES OF ACTION AND/OR THE

ALLEGATIONS OF THIS COMPLAINT.

THE BEASLEY FIRM, LLC

BY: /s/James E. Beasley, Jr.

JAMES E. BEASLEY, JR.
LOUIS F. TUMOLO
Attorneys for Plaintiff
Dated: 19 September 2018

THE BEASLEY FIRM, LLC 8

1125 WALNUT STREET
PHILADELPHIA, PA 19107 __________________________________________________________________
215.592.1000
215.592.8360 (FAX)
PERUTO V. SIXX DEGREES MEDIA, ET AL.
COMPLAINT IN REPLEVIN
Case ID: 180902399
WWW.BEASLEYFIRM.COM
19 September 2018

Case ID: 180902399

 COMMERCE PROGRAM ADDENDUM
TO CIVIL COVER SHEET

This case is subject to the Commerce Program because it is not an arbitration matter and it falls within one or
more of the following types (check all applicable):

1. Actions relating to the internal affairs or governance, dissolution or liquidation, rights or obligations
between or among owners (shareholders, partners, members), or liability or indemnity of managers
(officers, directors, managers, trustees, or members or partners functioning as managers) of business
corporations, partnerships, limited partnerships, limited liability companies or partnerships,
professional associations, business trusts, joint ventures or other business enterprises, including but
not limited to any actions involving interpretation of the rights or obligations under the organic law
(e.g., Pa. Business Corporation Law), articles of incorporation, by-laws or agreements governing such
enterprises;

2. Disputes between or among two or more business enterprises relating to transactions, business
relationships or contracts between or among the business enterprises. Examples of such transactions,
relationships and contracts include:

a. Uniform Commercial Code transactions;

b. Purchases or sales of business or the assets of businesses;
c. Sales of goods or services by or to business enterprises;
d. Non-consumer bank or brokerage accounts, including loan, deposit cash
management and investment accounts;

e. Surety bonds;
f. Purchases or sales or leases of, or security interests in, commercial, real
or personal property; and

g. Franchisor/franchisee relationships.

3. Actions relating to trade secret or non-compete agreements;

X 4. "Business torts," such as claims of unfair competition, or interference with contractual relations or
prospective contractual relations;

5. Actions relating to intellectual property disputes;

6. Actions relating to securities, or relating to or arising under the Pennsylvania Securities Act;

7. Derivative actions and class actions based on claims otherwise falling within these ten types, such as
shareholder class actions, but not including consumer class actions, personal injury class actions, and
products liability class actions;

8. Actions relating to corporate trust affairs;

9. Declaratory judgment actions brought by insurers, and coverage dispute and bad faith claims brought
by insureds, where the dispute arises from a business or commercial insurance policy, such as a
Comprehensive General Liability policy;

10. Third-party indemnification claims against insurance companies where the subject insurance policy
is a business or commercial policy and where the underlying dispute would otherwise be subject to
the Commerce Program, not including claims where the underlying dispute is principally a personal
injury claim.

EFS #1809039280 \\zdraddm 5/07