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•Bryan J. Freedman (SBN 151990)bfreedmanaftllp.comSteven E. Formaker (SBN 93906)sformaker@ftlip.comSean M. Hardy (SBN 266446)smhardy@ftlIp.comFREEDMAN + TAITELMAN, 'LP1901 Avenue of the Stars, Suite 500Los Angeles, CA 90067Telephone: (310) 201-0005Facsimile: (310) 201-0045

0'1 I 1-%tiN3\

• "s,o•

Attorneys for Plaintiffs Steve Stabler and Brad KrevoyVo

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

STEVE STABLER, an individual, andBRAD KREVOY, an individual,

Plaintiffs,

VS.

NEW LINE CINEMA, a Delawarelimited liability company; NEW LINEPRODUCTIONS, INC., a Californiacorporation, and DOES 1 through 50,.inclusive,

Defendants.

CASE NO. 5 6 6 4 1 °

COMPLAINT FOR:

1. B R E A C H OF CONTRACT •2. B R E A C H OF THE IMPLIED

COVENANT OF GOOD FAITHAND FAIR PEALING

3. DECLARATORY RELIEF

Plaintiffs Steve Stabler ("Stabler") and Brad Krevoy ("Krevoy") allege: XI -V r..-) X i r " "-)rn ..t, x.., m M

Nature of the Action frl-n

2- 2 X, 2 - • • I''', I r1. Pla in t i f fs are motion picture producers. In 1994, Plaintiffs entere4 itqa"-'cOhtrad r•• 0 •• 7:=:. i h . •rri • • 4 1 0 0

with Defendant New Line Productions, Inc. ("New Line Productions"), whose peiformanceA4 2:.1 A 'guaranteed by Defendant New Line Cinema ("New Line Cinema"), with respect to the pro duct. ag•. 0

motion picture entitled Dumb and Dumber (the "Film"). The contract provided, inter alia, thafilaintiffs

had rights of first negotiation to produce sequels of the Film with a floor of the terdnsF,otthe 1140 0 0 f..r1

ORIGINAL, Cd7z. . -0 0. 0 0 0 .

COMPLAINT

•

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• S .contract. New Line blatantly breached the contract by assigning tights to produce a sequel entitled

Dumb and Dumber To (the "Sequel") to a third party, Red Granite Capital US LLC ("Red Granite"),

without honoring Plaintiffs' rights of first negotiation. As a result of Defendants' conduct, Plaintiffs

have lost monetary compensation as well as credits and other consideration, and Defendants have been

unjustly enriched.

2. B y this action, Plaintiffs seek damages and equitable relief to restrain Defendants

from such unlawful conduct in the future.

Parties and Jurisdiction

3. S t a b l e r is, and at all times mentioned herein was, an individual residing and

conducting business in Los Angeles County, California.

4. K r e v o y is, and at all times mentioned herein was, an individual residing and

conducting business in Los Angeles County, California.

5. P la in t i f f s are informed and believe, and on that basis allege, that New Line Cinema

is, and at all times mentioned herein was, a limited liability company organized and existing under the

laws of the State of Delaware, and residing and conducting business in Los Angeles County, California.

Plaintiffs are informed and believe, and on that basis allege, that New Line

Productions is, and at all times mentioned herein was, a corporation organized and existing under the

laws of the State of California, and residing and conducting business in Los Angeles County,

California.

6. P la in t i f f s are informed and believe, and on that basis allege, that New Line Productions

is, and at all times mentioned herein was, a corporation organized and existing under the laws of the

State of California, and residing and conducting business in Los Angeles County, California,

7. T h e true names and capacities of Defendants Does 1 through 50, inclusive, are

presently unknown to Plaintiffs, who therefore sue said defendants by such fictitious names pursuant to

California Code of Civil Procedure § 474. Plaintiffs are informed and believe, and on that basis allege,

that each of the fictitiously named defendants is responsible in some manner for the occurrences alleged

herein. Plaintiffs therefore sue these defendants by such fictitious names and will amend this Complaint

to state their true names and capacities when such names have been ascertained.

2COMPLAINT

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•8. P l a i n t i f f s are informed and believe, and on that basis allege, that at all times

mentioned herein, each defendant acted as the actual or ostensible agent, employee and/or coconspirator

of each other defendant and, in performing the actions alleged herein, acted in the course and scope of

such agency, employment and/or conspiracy. Plaintiffs are further informed and believe, and on that

basis allege, that each defendant succeeded to and/or ratified the actions of each other defendant with

respect to the matters alleged herein.

9. V e n u e is proper in Los Angeles County because Plaintiffs are residents of Los

Angeles County; New Line Cinema and New Line Productions are residents of Los Angeles County;

the contract in issue was entered into and was to be performed in Los Angeles County; and the county

in which Does 1 through 50 reside is unknown to Plaintiffs.

Background

10. Plainti ffs are well known Hollywood producers, who have worked in the motion picture •

and television production business for more than 25 years. Their projects have generated more than $1

billion in worldwide revenue and the motion picture and television projects they have produced and

distributed have garnered Academy Awards, Emmy, Golden Globe, WGA, DGA, SAG and numerous other

awards and nominations. Among other positions, Plaintiffs ran production, marketing and distribution for

Orion Pictures prior to the company's sale to MGMAJA, served on the board of IFTA and are members of

the Academy of Motion Picture Arts and Sciences.

11. A S of March 1, 1994, Plaintiffs entered into a contract with New Line Productions,

whose performance was expressly guaranteed by New Line Cinema, with respect to the production of

the Film (the "Producer Agreement"). A copy of the Producer Agreement is attached to this Complaint

as Exhibit 1. The Producer Agreement provides, inter alia, that:

a. New Line Productions will own all rights in the Film..

b. Stabler and Krevoy each will receive producer fees of $200,000.

c. Stabler and Krevoy each will receive one-third of 50% of New Line Productions' net

profits from the Picture.

d. New Line Productions will place producer credits for Plaintiffs for the Film on screen

and in paid advertising, including: (a) "In Association with Motion Picture Corporation

3COMPLAINT

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•of America," a company of which Krevoy is President; (b) "A Brad Krevoy/Steve

Stabler/Charles Wessler Production"; and (c) "Produced by Charles Wessler, Steve

Stabler and Brad Krevoy."

e. Other terms are subject to New Line Productions' "standard form agreements, including

"rights offirst negotiations for sequels and remakes with a floor of this deal.. . ."

(Emphasis added.)

f. N e w Line Cinema guarantees all of New Line Productions' obligations.

12. Plaintiffs are informed and believe, and on that basis allege, that as of June 13, 2013,

New Line Productions had assigned rights in the Film and/or the Sequel to related or affiliated

companies named Katja Motion Picture Corporation ("Katja") and Avery Pix, Inc. ("Avery").

13. Plaintiffs and informed and believe, and on that basis allege, that as of June 13, 2013,

New Line Productions, along with Katja and Avery, entered into a contract with Red Granite entitled

'Dumb and Dumber To' Quitclaim Agreement" (the "Sequel Agreement") with respect to the Sequel.

The Sequel Agreement provides, inter alia:

a. N e w Line Productions, Katja and Avery quitclaim to Red Granite the

right to use the Film and associated rights in connection with the production of a

motion picture based in whole or in part on the Film, i.e., the right to produce a

sequel.

b. R e d Granite will pay to New Line Productions, Katja and Avery, inter alia, (i)

purported costs of $1,759,417 plus interest; (ii) a license fee of $1,500,000; and

(iii) certain contingent compensation.

c. R e d Granite will give a "presentation credit" on the Sequel to New Line

Productions, Katja and Avery along with other credits, but there is no

provision for any credits for Stabler or Krevoy.

d. T h e parties expressly acknowledge the Producer Agreement between Plaintiffs

and New Line Productions and the potential for a claim by Plaintiffs for breach of

the contract; and Red Granite will indemnify New Line Productions, Katja and

Avery from all liability for any claim under the Producer Agreement.

4COMPLAINT

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14. A f t e r New Line Productions, Katja, Avery and Red Granite entered into the Sequel

Agreement, Plaintiffs attempted to negotiate an agreement with Red Granite with respect to the

production of the Sequel based on the terms of their rights of first negotiation under the Producer

Agreement. When Red Granite refused to enter into an agreement based on those terms, and the parties

could not agree to other terms, Stabler and Krevoy had to file a lawsuit to protect their rights, Stabler v.

Red Granite Pictures, Inc., Los Angeles Superior Court Case No. BC 15978. Then, in mitigation of

their damages, Stabler and Krevoy entered into a settlement with Red Granite, which partially

compensated them for the damages caused by Defendants herein.,

First Cause of Action

Breach of Contract

[Against AL! Defendants]

15. Plaintiffs reallege and incorporate herein by reference paragraphs 1 through 14, above,

as though set forth in full.•

16. T h e Producer Agreement constitutes a Written contract between Plaintiffs, on the one

hand, and Defendants, on the other hand.

17.. Pursuant to the Producer Agreement, Stabler and Krevoy were entitled to, inter

alia, rights of first negotiation to Produce the Sequel with a floor of the terms of the Producer

Agreement.

18. Defendants breached the Producer Agreement by, inter alia, failing to negotiate

with Plaintiffs with respect to the production of the Sequel; failing to pay Plaintiffs fixed and contingent

compensation in connection with the Sequel; failing to provide Plaintiffs with credits on the Sequel;

failing to accord Plaintiffs the opportunity to produce the Sequel; and quitclaiming rights to Red

Granite so that it could produce the Sequel.

19. Plaintiffs have performed all conditions and covenants to be performed by them

under the Producer Agreement except to the extent their performance has been excused.

20. A s an actual and proximate result of the breaches of contract by Defendants,

Plaintiffs have suffered and will suffer damages in an amount to be proved at trial in excess of $1

million.

5COMPLAINT

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21. I n addition, Defendants have received benefits from their breaches of contract. It

would be unjust to allow Defendants to retain the benefits of their willful breaches of contract at

Plaintiffs' expense. Therefore, Plaintiffs are entitled to recover the amount of such benefits in an

amount to be proved at trial.

22. Furthermore; unless Defendants are ordered to perform their obligations under .the

Producer Agreement, and are restrained from committing future breaches of the Producer Agreement,

Plaintiffs will suffer substantial, irreparable and incalculable injury and monetary damages will not

provide adequate compensation. Therefore, Plaintiffs are entitled to (a) specific performance of the

Producer Agreement according Plaintiffs their rights of first negotiation on all sequels and remakes of

the Film; and (b) preliminary and permanent injunctive relief enjoining Defendants, during the

pendency of this action and permanently thereafter from, directly or indirectly, producing a sequel to

the Film, or assigning, licensing, quitclaiming or transferring to any person any right to produce a

sequel to the Film, without according Plaintiffs their rights of first negotiation.

Second Cause of Action

Breach of Implied Covenant of Good Faith and Fair Dealing

[Against. All Defendants]

23. Plaintiffs reallege and incorporate herein by reference paragraphs 1 through 14 and

16 through 22, above, as though set forth in full.

24. T h e Producer Agreement contains an implied.covenant of good faith and fair

dealing which provides that the parties must deal with each other in good faith and not engage in

conduct to deprive the other party of the benefits of the contract.

25. Defendants breached the implied covenant of good faith and fair dealing by, inter

alia, negotiating and entering into the Sequel Agreement; failing to negotiate with Plaintiffs with

respect to the Sequel; failing to pay Plaintiffs fixed and contingent compensation in connection with the

Sequel; failing to provide Plaintiffs with credits on the Sequel; failing to accord Plaintiffs the

opportunity to produce the Sequel; quitclaiming rights to Red Granite so that it could produce the

Sequel; and failing to ensure that Red Granite negotiate with Plaintiffs, pay Plaintiffs fixed and

contingent compensation, provide Plaintiffs with credits on the Sequel or accord Plaintiffs the

6COMPLAINT

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•opportunity to produce the Sequel.

26. Plaintiffs have performed all conditions and covenants to be performed by them

under the Producer Agreement except to the extent their performance has been excused.

27. A s an actual and proximate result of the breaches of the implied covenant of good

faith and fair dealing by Defendants, Plaintiffs have suffered and will suffer damages in an amount to

be proved at trial in excess of $1 million.

28. I n addition, Defendants have received benefits from their breaches of contract, It

would be unjust to allow Defendants to retain the benefits of their willful breaches of contract at

Plaintiffs' expense. Therefore, Plaintiffs are entitled to recover the amount of such benefits in an

amount to be proved at trial.

29. Furthermore, unless Defendants are ordered to perform their obligations under the

Producer Agreement, and are restrained from committing future breaches of the Producer Agreement,

Plaintiffs will suffer substantial, irreparable and incalculable injury and monetary damages will not

provide adequate compensation. Therefore, Plaintiffs are entitled to (a) specific performance of the

Producer Agreement according Plaintiffs their rights of first negotiation on all sequels and remakes of

the Film; and (b) preliminary and permanent injunctive relief enjoining Defendants, during the

pendency of this action and permanently thereafter from, directly or indirectly, producing a sequel to

the Film, or assigning, licensing, quitclaiming or transferring to any person any right to produce a

sequel to the Film, without according Plaintiffs their rights of first negotiation.

Third Cause of Action

Declaratory Relief

[Against All Defendants]

30. Plaintiffs reallege and incorporate herein by reference paragraphs 1 through 14, 16

through 22, and 24 through 29, above, as though set forth in full.

31. A n actual controversy has arisen and now exists between Plaintiffs, on the one

hand, and Defendants, on the other hand, concerning their respective rights and obligations under the

Producer Agreement. Plaintiffs contend that Defendants may not, directly or indirectly, produce a

sequel to the Film, or assign, license, quitclaim or transfer to any person any right to produce a sequel

7COMPLAINT

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to the Film, without according Plaintiffs' their rights of first negotiation. Plaintiffs are informed and

believe, and on that basis allege, that Defendants deny Plaintiffs' contentions.

32. Plaintiffs seek a judicial determination of their rights and interests under the

Producer Agreement, i.e., that Defendants may not, directly or indirectly, produce a sequel to the Film,

or assign, license, quitclaim or transfer to any person any right to produce a sequel to the Film, without.

according Plaintiffs' their rights of first negotiation.

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

Plaintiffs and Defendants may ascertain their rights, interests, obligations and duties with respect to

foregoing and to avoid a multiplicity of actions.

Prayer for Relief

WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of them, as follows:

1. F o r compensatory damages in an amount to be proved at trial;

2. F o r preliminary and permanent injunctive relief (a) ordering specific performance of the

Producer Agreement; and (b) enjoining Defendants, during the pendency of this action and permanently

thereafter from, directly or indirectly, producing a sequel to the Film, or assigning, licensing,

quitclaiming or transferring to any person any right to produce a sequel to the Film, without according

Plaintiffs' their rights of first negotiation;

3. F o r a judicial declaration that Defendants may not directly or indirectly, produce a

sequel to the Film, or assign, license, quitclaim or transfer to any person any right to produce a sequel

to the Film, without according Plaintiffs' their rights of first negotiation;

4. F o r costs of suit incurred herein; and

5. F o r such other and further relief as the Court may deem just and proper.

Dated: June 12,2017 FREEDMA L , LLP

By:an J. Freedman

Steven E. FormalcerSean M. HardyAttorneys for Plaintiffs. Steve Stabler and BradKrevoy

8• COMPLAINT

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EXHIBIT 1

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1

NEW LINE CINILMA

gy_Fax- 310-288-4800

As o f March- 1, 1 9 9 4

Brad Smi thC r e a t i v e A r t i s t s Agency9 0 0 W i l s h i r e Bou leva rdBever ly R i l l s , C a l i f o r n i a 9 0 2 1 2

Re: " D u m b a n d Dumber"

Dear Brad :

The f o l l o w i n g S h a l l c o n f i r m t h e m a t e r i a l t e r m s O f t h eagreements between New L i n e P roduc t i ons , I n c . o r i t sdes ignated p r o d u c t i o n company ("New L i n e " ) ( a l l o b l i g a t i o n sto b e guaran teed b y New L i n e Cinema a s s e t f o r t h o n page 4 )and y o u r c l i e n t s P e t e r F a r r e l l y , Bob F a r r e l l y and Benne t tYe l l i n ( r e f e r r e d t o sometimes i n d i v i d u a l l y and sometimesc o l l e c t i v e l y, j o i n t l y and s e v e r a l l y, a s " Wr i t e r s " ) , a n d w i thChar les Wess le r, S t e v e S t a b l e r and Brad Krevoy ( r e f e r r e d t osometimes i n d i v i d u a l l y and sometimes c o l l e c t i v e l y , j o i n t l yand s e v e r a l l y , a s " P r o d u c e r s " ) a n d w i t h P e t e r F a r r e l l y( " D i r e c t o r " ) w i t h r e s p e c t t o t h e p r o d u c t i o n o f a mo t i onpicture present ly e n t i t l e d "Dumb and Dumber" ( " t h ePicture") :

1 . - f l I é T r r W t a n o i i i i i , rare s u b j e c t t o r e v i e w and reasonable a p p r o v a l o f a l l c h a i no f t i t l e documents, a n d W r i t e r s and Producers and D i r e c t o rhereby w a r r a n t t h a t t h e o n l y c h a i n o f t i t l e documents a r ethe s i g n e d W r i t e r s ' agreements w i t h U n i v e r s a l P i c t u r e s ands i g n e d C e r t i f i c a t e s o f A u t h o r s h i p , r e c e i p t a n d a p p r o v a l o Cw h i c h . a re h e r e b y a c k n o w l e d g e d b y New L i n e . W r i t e r s .Producers and D i r e c t o r s h a l l be deemed "pay o r p lay"hereunder when t h e chain o f t i t l e i s approved, t h e Qui tc la imAgreements. and s i g n e d assignment r e f e r r e d t o be low a r e f u l l yexecuted, a d e a l memo w i t h J i m Carrey i s s i g n e d c o m m i t t i n g

C n r r e y t o t t n r i n t ! . . : P i C t u r e . H o t m i t h s t a n d i n g a n y t h i n g • ( 1 . 4

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Brad SmithAs o f March 1 , 1994page 2

herein to the contrary, but subject t o the 'pay or play'conditions of t h i s l e t t e r agreement, Peter Parrel ly, CharlesWeseler, Steve Stabler and Brad Krevoy shal l be 'pay andplay' through the f i t a r t w o weeks of principal photography.Subject to events o f disabi l i ty or force majeure, the startdate i s tentat ively set for May 2, 1994, and shall be nola ter than May 23, 1994. .

2. R i g h t s : W r i t e r s warrant and represent that they havethe r i g h t to enter into a Quitclaim Agreement withThunderbird, I n c . ("Thunderbird') who, t o the best ofWriters', Producers' and Director's knowledge owns andcontrols a l l underlying rights whatsoever i n Lhe'Picturesand that Writers warrant and represent that concurrentlywith the complete execution of the Thunderbird QuitclaimAgreement, Wri ters w i l l , execute an Assignment o f a l l Rightsin form attached hereto as exhibit A to New Line and Writersconvey a l l underlying rights Whatsoever t o New LineProductions, I n c . Wr i t e r s , Producers and Director furtherwarrant and represent that they have the r ight t o enter intothe Thunderbird Quitclaim, the New Line Productions, Inc .Assignment, t h i s agreement and grant a l l r ights grantedhereunder, t h a t there are no third parties whatsoeverclaiming an interest i n the Picture or the underlying rightstherein, t h a t the screenplay i s original with them and doesnot infr inge on the rights o f any third parties'whateoever,and they hereby indemnify New Line from any damages orclaims whatsoever arising out of any breach of the foregoingwarranties. N e w Line agrees to pay direct ly to Thunderbirdthe sum of $220,963 concurrently with the execution of a l ldocuments, including, without l imitation, Q u i t c l a i m •documents referred t o hereinahove and any chain of t i t l edocuments reasonably required hereunder. New Line alsoagrees t o pay d i rec t ly to Universal P iat i tea the sum of$6,792 when due pursuant to the terms of the ThunderbirdQuitclaim,

3. Producers Pees! Subject to the terms and conditions ofthis l e t t e r agreement, the Producer's fees shal l be $600,000in the aggregate (payable 20/60/10/10) t o be divided amongstthem i n equal shares. Likewise, the Producers and theDirector shal l receive, i n the aggregate, divided i n equalshares, 50% o f 200% o f New Line's nut prof i ts from thePicture from 4,1 sources, reducible by a l l otherp a r t i c i p a t i o n t o a hard f loor o f 15t o f 1004 o f the netprof i ts . V i d e o revenues shall be included i n New Line'sgross revenues a t a 25% royalty, wi th no distribution fees. a - 4 'Al l other terms and conditions of net prof i ts sha l l besubject t o New Line's standard definit ion o f net profi ts, a smodified f o r Jersey Films fo r the Picture ent i t led be

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Brad SmithAs o f March 1, 1994page 3

Seconds.' ProdUcere Shall perform a l l services customarilyrendered by producers of f i r s t class motion pictures i n theentertainment industrx in,Los Angeles, Cal i fornia, w i thCustomary creative consultation rights, b u t subject to NewLine's direction and control.

4. D i r e c t o r Pees t S u b j e c t to the terms and conditions o fthis l e t t e r agreement, Director shall be paid the t o t a l sumof $200,000 (20/60/10/10) and as a courtesy to Director,shall be reimbursed the sum of up to $5,000 as and f o r DIGAini t ia t ion fees. D i r e c t o r shall perform a l l servicescustomarily performed by directors of f i r s t class motionpictures i n the entertainment industry i n Loa Angeles,California, wi th customary creative consultation rights, butsubject CD New Line's directionand control.

5. W r i t e r s ' Pees: S u b j e c t t o New Line's receipt andapproval o f the wr i ter 's agreement between Writers andUniveraal, the assignment o f that agreement to New Line.together with a signed cert i f icate o f authorship, New Lineshall assume the obligation to pay to Writers the productionbonne o f $150,000 plus St o f 100t of the net prof i ts i f theyare accorded sole writ ing credit pursuant t o f ina l WGAdetermination. I f , a t New Line's request, Writers performadditional writing services, then the Writers shal l receiveadditional fees o f $30,000 i n the aggregate t o be dividedequally amongst them/ arta rek afrUsArolf..-to N..4i5olboo.

6. C r e d i t s : S u b j e c t t o any pro-existing contractual creditrequirements ( e . g . , executive producer credits t oindividuals associated with the use OE 'Ngtional Lampoon' i nconnection with the Picture), New Line agreea, subject t ostandard contractual conditions (e .g . , defaul t o rdisabil i ty) and to a l l the credit provisions o f the WGA andDGA Basic Agreements, t o accord on screen and paid ad creditas follows;

(a) Mot ion Picture Corporation of America shal lreceive an ' i n asaociation with' credit /

(b) Producers shal l be accorded credit i n the form "ABrad Krevoy/ateve Stabler/Charles Wessler Production.°

(c) Producers shal l be accorded credit I n the form:'Produced by Charles Weedier, Steve Stabler and BradKrevoy.°

(d) D i r e c t o r shal l be accorded a poesessory credit anda °directed by' c red i t .

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Brad SmithAs o f March 1, 1994page 4

(d) Tr a c e y Graham, Robert Farrel ly and Bradley Jenkelshall share a 'co -producer' credit on one shared card onscreen i n the main' t i t l e s , but shall not be required to beaccorded credits i n paid ads. Brad ley Thompson shal lreceive an °Associate Producer' credi t i n the end t i t l e s ,which may be shared.

All credits shal l be subject to New Line's customary 'standards and exclusions and New Line reserves the r ight t oaccord -ae-pmeSeemette-grreeleeer-amd- executiveproducer credits t o any parties provided that no otherparties shall receive a 'produced by" c r e d i t exceptProducers.

7. Miscellaneous: A l l other terms and conditions ofWriters', Producers' and Director's deals shal l be subjectto the provisions o f the WGA and 'WA Basic Agreements and toNew Line's standard form agreements (which include, withoutlimitation, provisions regarding default, d i e a b i l i t y, forcemajeure,,rights o f f i r s t negotiation for sequels andremakecff Deter Parrel ly shall have the option with respectto theatrical sequels and remakes t o be one o f the producersand to share producer'e fees instead of negotiating as adirector) no injunction r e l i e f and California law andjurisdiction), which standard form agreements may be subjectto modification a f t e r good fa i th negotiation within NewLine's customary parameters.

?tVrilbUri eletWii I tau utt, arosto rtirnbase 'Oink FOY - rutuctionBrad, please have your cl ients sign where indicated below, 11.f4td2S 11DThank you f o r your courtesy and cooperation. ( h a Ostia&

r i e t Personal regards,

(LiI t

Mar a r B l * atnerS o i c e PresidentBun e a n d Legal W e i r s

New Line g u a r a n t e e s a l lOhligat one L i n e Productions, I n c .and/or i t s p r o d u c t i o n company

By

Ti t le

(Signatures continued on next page)

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•Brad SmithAS o f March 1 , 1994page 5

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cc: Michae l DeLucaBen ZinkinLawrence Kopeikin

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°DUNS AND DOWIED•

Thia Agreement dated ea of March 1, 1994 shal l ceeat,iiuiethe basic terms and conditions of the agreement betweenPeter Parrel ly, Bob Parrelly and Bennett Ye l l i n (40w5er°)and New Line Productions, Inc . ('Purchaser') r e la t ing tothat certain unpublished original screenplay ent i t led "Dumband Dumber° ( t h e 'Screenplay) written by Peter Parrel ly,Bob Parrel ly and Bennett Yel l in (0Author6).

1. Proper ty. T h e Property is , col lect ively, a l ltreatments, wri t ings, screenplays and other materialscomprising the Screenplay and any a l l elements includedtherein or embodied therein and a l l previous and/orsubsequent revisions and/or translations thereof and theplots, themee and characters contained i n a l l o f theforegoing.

2. Assignment. Owner hereby irrevocably sel ls , grants andassigns t o Purchaser, exclusively and absolutely andoutright, i n perpetuity and throughout the universe: a l lrights o f any kind new known or hereafter known includingwithout l imitat ion, a l l theatrical motion picture, non-theatrical motion picture, television, home video,audiovieual devise, sequel, remake, prequel, soundtrack,music merchandising, p r i n t publications rights (excekat fo rOwner's reserved r igh t ) , advertising and publ ic i ty r ightsand any and a l l other a l l ied and incidenV1 r ights i n theProperty (the.oRights°).

3. purchase Price. I n consideration f o r a l l the Rightsgranted to Purchaser by Owner hereunder and a l l o f Owner'srepresentations, warranties and agreements herein, Purchasershall pay to Thunderbird, Inc . , on Owner's behalf, t h e sumof $220,963 upon complete execution of t h i s Assignment andPurchaser aesumes the obligation to pay Universal Picturesthe cum of $6,192 upon principal photography of a motionp ic tu re based on t h e Property.

4. T h e Rigrink. T h e Rights shall include, but not helimited to , the following

4 . 1 . O w n e r hereby i r revocably and abso lu te ly t r a n s f e r s ,sets o v e r and g ran ts t o Purchaser the R ights t o and w i t hrespect t o t h e Proper ty, inc lud ing a l l copyr ights t h e r e i n .

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4,2. Purchaser shall have the unlimited r ight t o use,exploit; advertise, exhib i t and otherwise turn to accountany motion picture based on the Property i n any manner andin any and a l l media, whether new known or hereafter -devised, throughout the world, i n perpetuity, i n a l llanguages, as Pura:altar in i t s sole discretion shal ldetermine. Authoritterebrwaives any and a l l so-called°moral r ights ' o f authors.

4.3. Owner hereby grants exclusively to Purchaserforever and throughout the world and i n any and a l l media(whether now known or hereafter devised) t h e exclusiveright t o use'Author's name, likeness, and biographical datain connection with the Picture and the advertising,publicity, promotion, marketing, merchandising andexploitation of the Picture (including without l imitat ion inconnection with promotional films and featurettes such as"behind the scenes a n d "making o f ' f i lms) .

5. Renreeentatione & Warranties: Owner represents andwarrants as follows:

5.1. owner has the f u l l r ight, power and authority toenter in to th is Agreenent and to grant t o Purchaser theRights and a l l other rights granted herein to Purchaser.

5.2. N e i t h e r the Property nor any part thereof i s i nthe public domain.

5.3. T h e Property i s val idly copyrighted and registeredfor copyright i n the United State; o f America and maysimilarly be protected elsewhere to the maximum extent that.the laws o f other countries provide for sych protection.

5.4. T h e Property i s Wholly original with Author and noincident contained therein and no part thereof has beentaken from, has been based upon, o r w i l l infringe upon anyother l i t e r a r y, dramatic or musical material o r any motionpicture.

5.5. T h e Property does not and w i l l not i n any wayinfringe upon o r violate the copyright or common law rightsor l i t e r a r y or dramatic or motion picture rights o f , o r.constitute a l i b e l o r defamation against, or' invssion of therights o f privacy, publ ic i ty or any other rights, o f anyparty whatsoever; .

5.6. Owner owns a l l r ight , t i t l e and interest i n theProperty, and Author 4rote the Screenplay as an employee forhire o f Owner and/or Universal Pictures and/or Thunderbird.Inc. owner has not entered into any agreement derogatingfrom or otherwiea affecting the Property or any of the

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• •;,,•,.ea'

Rights granted herein to Purchaser, and no part of theProperty or any of the Rights granted herein to Purchaserbee i n any way been encumbered, void, conveyed, ansigned,granted or otherwise disposed of t h e Property and a l l ofthe Righte granted herein to Purchaser are free of any l iensor claims whatsoever, and there are no claims or . l i t igat ionptnding, outstanding or threatened which might i n any.layprejudice, interrupt-or interfere with the use by Purchaserof the 'Property, the Rights or any other rights grantedherein to Purchaser.

5.7. T h e Property has not previously been exploited asa motion picture, televisien production, p lay or otherwise,and no o t h e r l i te rary work or other materials based on theProperty has been wri t ten. '

5.0. Owner shall indemnify and hold harmless Purchaser,i ts representatives, licensees and assigns from and againstany And a l l l i ab i l ip ies , judgments, claims costa , damages,losses and expenses (including without l imitat ion costs andreasonable attorneys' fees) arming out of or i n connectionwith the Property or any use thereof o r a breach-e•—elieged-baseeab,by Owner of any warranties, representations o ragreements contained in this Agreement. Purchaser shal lhave the sole r ight to control the legal defense of any suchclaims, demands or l i t igat ion, including the r ight t o selectcounsel o f Purchaser's choice and to compromise or oet t leany such claims, demands or l i t igat ion.

5.9. Purchaser shall indemnify and hold harmless Owner,his representatives, licensees and assigns from and againstany and a l l l i a b i l i t i e s , judgments, claims, costs, damages,losses and expenses arising out of o r in connection with anyadditions to the Property made by Purchaser, o r the breachby Purchaser of any warranties, representations or •agreements contained in th is Agreement.

6. p r e a c h of Aereessem N o act or omission of e i ther partyhereunder shal l constitute an event o f default or breach o fthis Agreement unless the other party shal l f i r s t g ivenotice i n writ ing setting forth such alleged breach ordefault and such alleged breach or default shall not havebeen cured within ten' (10) days af ter the giving of suchnotice.

7. H o In iungt imRel ieA I n the event of a breach o f th isAgreement by Purchaser, Owner shall not he ent i t led t oequitable r e l i e f or to.terminate or rescind this Agreementor any of the Rights granted to Purchaser herein o r torestrain, enjoin or otherwise impair the production,distribution, advertising or other exploitation o f anyproduction based i n whole or in part on the Property,

• 9 ,

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Owner's so le remedy being an ac t ion a t law f o r damages, i fany.

B. Af is ignment . O w n e r agrees t h a t Purchaser may ass ign t h i sAgreement, i n whole o r i n p a r t , a t any t ime t o any p a r t y, a ti t s s o l e d i s c r e t i o n .

9. N o t i c e % A l l not ices hereunder s h a l l be i n w r i t i n g andshal l be g iven by personal d e l i v e r y, un less peroonalde l ivery i s impract icab le , i n which case no t ice may b e givenby telegram o r f a c s i m i l e transmisaion, o r by reg is te red o rc e r t i f i e d m a i l (postage prepa id ) , and s h a l l be deemed givenhereunder on t h e da te d e l i v e r e d , telegraphed o r faxed o r adate f o r t y - e i g h t ( 4 8 ) hours a f t e r t h e da te mai led. U n t i lfu r ther no t i ce , t h e address o f t h e p a r t i e s s h a l l b e a sf o l l o w :

OKNER/ADTBOR

Peter F a r r e l l yBob. F a r r e l l yBennett Y e l l i nc/o Bradford SmithCreat ive A r t i s t s Agency9830 W i l s h i r e B lvd .Beverly R i l l s , CA 9 0 2 1 2

PURCRASER

New L ine Productions, I n c .c/o New L ine Cinema Corp.114 N . Robertson Blvd.Ste. 200Los Angeles, CA 9 0 0 4 8Attn: M a r g a r e t B l a t n e rSenior Vice PresidentBusiness A f f a i r s

with a copy t o :Benjamin Z i n k i nExecutive Vice PresidentBusiness A f f a i r sNew L i n / Cinema Corp.888 Seventh AvenueNew York, NY l o l o &

10. Q&. ,Lsceement . T h i s Agreement s h a l l b e subject t o themandatory provis ions o f t h e Wr i t e r ' s Gu i ld o f America BasicAgreement (uBasic Agreement ) , and any discrepancy betweenthin Agreement and t h e Basic Agreement s h a l l be resolved i nfavor o f t h e Basic Agreement.

11. M i s c e l l a n e o u e . T h i s Agreement e h a l l b e governed by t h elaws o f t h e S t a t e o f C a l i f o r n i a appl icab le t o agreementsexecuted and t o be whol ly t o be performed t h e r e i n and s h a l lnot b e modif ied except .by a w r i t t e n document executed b yboth p a r t i e s h e r e t o . T h i s Agreement expresses t h e e n t i r eunderstanding o f t S e p a r t i e s hereto and replaces any and a l lformer agreements o r understandings, w r i t t e n o r o r a l ,r e l a t i n g t o t h e sub jec t m a t t e r hereof . P a r a g r a p h headings

\GROVistsign.drab .

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are f o r the convenience o f the parties only and shal l haveno legal ef fect whatsoever.

I f the foregoing correctly sets for th your understanding,please sign i n the space provided below.

AGRERD AND ACCRPTCD:'4'(Owner,

By

I ts

Ped. I .D . f t

Pete F a . e l l y

ennett Ye 1 4 4 4 "

\DMIALlusign.dab

Very t ru ly yours,

PL'44f4c61,4Itri: kvo

Bob Par e l l y

S.S.4.

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ATTORNEY PARTY /ITHOUT ATTORNEY (Name,. Bar number, and address):—Bryan J . F r e e d m a n ( S B N 1 5 1 9 9 0 ) •

S t e v e n F o r m a k e r ( S B N 9 3 9 0 6 ) S e a n H a r d y (SBN 2 6 6 4 4 )FREEDMAN + TAITELMAN, L L P1901 A v e n u e o f t h e S t a r s , S u i t e 5 0 0Los A n g e l e s , C A 9 0 0 6 7

TELEPHONE NO.: 3 1 0 - 2 0 1 - 0 0 0 5 F A X NO,:ATTORNEY FOR (Name): P l a i n t i f f sSUPERIOR COURT OF CALIFORNIA, COUNTY OF L o s A n g e l e s

STREET ADDRESS: 1 1 1 N o r t h H i l l S t r e e tMAILING ADDRESS:CITY AND ZIP CODE: LOS A n g e l e s 9 0 0 1 2

ermialwaECentral D i s t r i c t

•

CASE NAME: S TA B L E R V. NEW L I N E CINEMA

CIM:21QFOR COURT USE ONLY

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ju 1 2 M7'1140141;AW4JvC

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41. O e n ( tta

CIVIL CASE COVER SHEETM Unlimited E l Limited

(Amount ( A m o u n tdemanded ' d e m a n d e d isexceeds $25,000) $25,000 or less)

Complex Case DesignationI - 1 Counter n i JoinderFiled with first appearance by defendant

(Cal. Rules of Court, rule 3.402)

CASE NUMBER: •Be 6 64796JUDGE:DEPT:

Items 1-6 below must be completed (see instructions on page 2).1. Check one box below for the case type that best describes this case:

Auto Tortn Auto (22)E l Uninsured motorist (46)Other PIIPDNVD (Personal Injury/PropertyDamageNVrongful Death) Tort

n Asbestos (04)Product liability (24)

n Medical malpractice (45)= Other PI/PD/WD (23)Non-PI/PD/W13 (Other) Tortr 7 Business tort/unfair business practice (07)r i Civil rights (08)n Defamation (13)I - 7 Fraud (16)n l In te l l ec tua l property (19)

r i P r o f e s s i o n a l negligence (25)

I - 7 Other non-PI/PDNVO tort (35)EmploymentE 7 Wrongful termination (36)

Other employment (15)

Contractn Breach of contract/warranty (08)

R u l e 3.740 collections (09)

E 7 Other collections (09)E l Insurance coverage (18)r i Other contract (37)Real PropertyE J Eminent domain/Inverse

condemnation (14)= Wrongful eviction (33)n Other real property (26)

Provisionally ComplerCivil Litigation(Cal. Rules of Court, rules 3.400-3.403)L J Antitrust/Trade regulation (03)E 7 Construction defect (10)E 7 Mass tort (40)r - i Securities litigation (28)n i Environmental/Toxic tort (30)n Insurance coverage claims arising from the

above listed provisionally complex casetypes (41)

Enforcement of JudgmentUnlawful Detainer E l Enforcement of judgment (20)E 7 Commercial (31) M i s c e l l a n e o u s Civil Complaint

n Residential (32) E l RICO (27)= Drugs (38) E 7 Other complaint (no? specified above) (42)

Judicial Review M i s c e l l a n e o u s Civil Petitionr i Asset forfeiture (05) r 7 Partnership and corporate governance (21)

1-1 Petition re: arbitration award (11) F 7 Other petition (not specified above) (43)n Writ of mandate (02)E 7 Other judicial review (39)

2. This case 1 - 1 is E 7 is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark thefactors requiring exceptional judicial management:a. L a r g e number of separately represented parties d . L J Large number of witnessesb. n Extensive motion practice raising difficult or novel e. 1 7 Coordination with related actions pending in one or more courts

issues that will be time-consuming to resolve i n other counties, states, or countries, or in a federal courtc. 1 1 Substantial amount of documentary evidence Substantial postjudgment judicial supervision

3. Remedies sought (check all that apply): a. r 7 monetary b. 1 7 nonmonetary; declaratory or injunctive relief c. F. -1 punitive

4. Number of causes of action (specify): ( 3 ) BREACH OF CONTRACT5. ,his case n is i s not a class action suit.6.4:;If there are any known related cases, file and serve a notice of related case. (You o n n CM-015.)

jONE 1 2 , 2 0 1 7

(TYPE OR PRINT NAME) ( S I G N A T U R E OF PARTY OR ATTORNEY FOR PARTY)i..)

NOTICE',Plaintiff must file this cover sheet with the first paper filed in the action or p ceeding (except small claims cases or cases filed

under the Probate Code, Family Code, or Welfare and Institutions Code). ( at. Rules of Court, rule 3.220.) Failure to file may resultin sanctions.

• File this cover sheet in addition to any cover sheet required by local court rule.• If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all

other parties to the action or proceeding.• Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only.

Pago102Form Adopted for Mandatory U

Judicial Council of CatiromiaCM-010 'ROY. July 1, 20)71

ALR I G I N C I V I L C A S E C O V E R S H E E T s i t r i a i n s . Cat' Rul sa.t!iSCtataicrseosf2.7u311211trtiU4n(.13siciTiO

Zk NUS

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INSTRUIPONS ON HOW TO COMPLETE THE C O S I SHEET C M -010To Plaintiffs and Others Filing First Papers. I f you are filing a first paper (for example, a complaint) in a civil case, you mustcomplete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compilestatistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must checkone box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1,check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A coversheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party, itscounsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court.To Parties in Rule 3.740 Collections Cases. A "collections case' under rule 3.740 is defined as an action for recovery of money owedin a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in whichproperty, services, or money was acquired on credit A collections case does not include an action seeking the following: (1) tortdamages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of attachmentThe identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general lime-for-servicerequirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections case will be subjectto the requirements for service and obtaining a judgment in rule 3.740.To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether thecase is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated bycompleting the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with thecomplaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in theplaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation thatthe case is complex..Auto Tort

Auto (22)—Personal Injury/PropertyDamagefiNrongful Death

Uninsured Motorist (46) (if thecase involves an uninsuredmotorist claim subject to •arbitration, check this iteminstead of Auto)

Other PUPDNVD (Personal injury/Property DamageNVrong(ul Death)Tort

Asbestos (04)Asbestos Property DamageAsbestos Personal Injury/

Wrongful DeathProduct Liability (not asbestos or

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

Medical Malpractice—Physicians & Surgeons

Other Professional Health CareMalpractice

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

and fall)Intentional Bodily Injury/PD/WD

(e.g., assault, vandalism)Intentional Infliction of

Emotional DistressNegligent Infliction of

Emotional DistressOther PUPD/WD

Non-PUPD/WD (Other) TortBusiness Tort/Unfair Business

Practice (07)Civil Rights (e.g., discrimination,

false arrest) (no! civil;,:; harassment) (06)

Defamation (e.g., slander, libel)(13)

Illud (16)Itf ellectual Property (19)Professional Negligence (25)

Legal MalpracticeOther Professional Malpractice

(not medical or legal)Other Non-PI/PD/WD Tort (35)

EmploymentWrongful Termination (36)Other Employment (15)

CASE TYPES AND EXAMPLESContract

Breach of Contract/Warranty (06)Breach of Rental/Lease

Contract (not unlawful detaineror wrongful eviction)

Contract/Warranty Breach—SellerPlaintiff (not fraud or negligence)

Negligent Breach of Contract/Warranty

Other Breach of ContractNVarrantyCollections (e.g., money owed, open

book accounts) (09)Collection Case—Seller PlaintiffOther Promissory Note/Collections

CaseInsurance Coverage (not provisionally

complex) (18)Auto SubrogationOther Coverage

Other Contract (37)Contractual Fraud

' Other Contract DisputeReal Property

Eminent Domain/inverseCondemnation (14)

Wrongful Eviction (33)Other Real Property (e.g., quiet title) (26)

Writ of Possession of Real PropertyMortgage ForeclosureQuiet TitleOther Real Properly (not eminentdomain, landlord/tenent, orforeclosure)

Unlawful DetainerCommercial (31)Residential (32)Drugs (38) (if the case involves Illegal

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

Judicial ReviewAsset Forfeiture (05)Petition Re: Arbitration Award (11)Writ of Mandate (02)

Writ—Administrative MandamusWrit—Mandamus on Limited Court

Case MatterWrit—Other Limited Court Case

ReviewOther Judicial Review (39)

Review of Health Officer OrderNotice of Appeal—Labor

Commissioner Appeals

Provisionally Complex Civil Litigation (Cal.Rules of Court Rules 3.400-3.403)

Antitrust/Trade Regulation (03)Construction Defect (10)Claims Involving Mass Tort (40)Securities Litigation (28)Environmental/Toxic Tort (30)Insurance Coverage Claims

(arising from provisionally complexcase type listed above) (41)

Enforcement of JudgmentEnforcement of Judgment (20)

Abstract of Judgment (Out ofCounty)

Confession of Judgment (non-domestic relations)

Sister State JudgmentAdministrative Agency Award

(not unpaid taxes)Petition/Certification of Entry of

Judgment on Unpaid TaxesOther Enforcement of Judgment

CaseMiscellaneous Civil Complaint

RICO (27)Other Complaint (not specified

above) (42)Declaratory Relief OnlyInjunctive Relief Only (non-

harassment)Mechanics LienOther Commercial Complaint

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

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

Partnership and CorporateGovernance (21)

Other Petition (not specifiedabove) (43)Civil HarassmentWorkplace ViolenceEider/Dependent Adult

AbuseElection ContestPetition for Name ChangePetition for Relief from Late

ClaimOther Civil Petition ,

CM-010(1,10v. July 1.20071 CIVIL CASE COVER SHEET Page 2012

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ACivil Case Cover Sheet

.Category No.

B •Type of Action • - • r

(Check only one)

• CApplicable•Reasons :

See Seji:3Atiove

Auto (22) 1, 4, 11F l A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death

Uninsured Motorist (46) 1, 4, 11= A7110 Personal Injury/Property Damage/Wrongful Death — Uninsured Motorist

1, 11I N A6070 Asbestos Property DamageAsbestos (04) •

O n A7221 Asbestos - Personal injury/Wrongful Death 1, 11

Product Liability (24) . 1, 4, 11I 1 A7260 Product Liability (not asbestos or toxic/environmental)

Medical Malpractice (45)1, 4,

1, 4,

11

11

1T1A7210 Medical Malpractice - Physicians & Surgeons, - - - ,1t A7240 Other Professional Health Care Malpractice

1, 4, 11I . A7260 Premises Liability (e.g., slip and fall)Other PersonalInjury Property

Damage Wrongful1, 4, 11= A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g.,

assault, vandalism, etc.)Death (23) = A7270 Intentional Inffiction of Emotional Distress 1, 4, 11

1, 4, 11= A7220 Other Personal Injury/Property Damage/Wrongful Death

• •SHORT link STABLER V. NEW LINE CINEMA CASE NUMBER

• C I V I L CASE COVER SHEET ADDENDUM ANDSTATEMENT OF LOCATION

(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This form is required pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court.

Step 1: After completing the Civil Case Cover Sheet (Judicial Council form CM-OW), find the exact case type inColumn A that corresponds to the case type indicated in the Civil Case Cover Sheet.

Step 2: In Column B, check the box for the type of action that best describes the nature of the case.

Step 3: In Column C, circle the number which explains the reason for the court filing location you havechosen.

Applicable Reasons for Choosing Court Filing Location (Column C)

1. Class actions must be filed in the Stanley Mosk Courthouse, Central District,2. Permissive filing in central district.3. Location where cause of action arose.4. Mandatory personal injury filing in North District.

5. Location where performance required or defendant resides.

6. Location of property or permanently garaged vehicle.

7. Location where petitioner resides.8. Location wherein defendant/respondent functions wholly.

9. Location where one or more of the parties reside,10. Location of Labor Commissioner Office.11. Mandatory filing location (Hub Cases — unlawful detainer, limitednon-collection, limited collection, or personal injury).

LACIV 109 (Rev 2/16)LASC Approved 0 -04

CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATION

EMIL' Local Rule 2.3• P a g e 1 of 4

LA-MOS

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SHORT TITLE: STABLER V . N E W L I N E C I N E M A1

CASE NUMDER '

i r,....' 7, ': -7.'4'Z'; Non-Personal Injury/ PropertyUnlawful 15erainer Real Property Contract Employment Damage/ Wrongful Death Tort

. . . . . .

A 8 I C ApialiCableCivil Case Cover Sheet Type of Action Reasons- See Step 3

Category No. ' ( C h e c k only one) Above

Business Tort (07) (not fraud/breach of contract) 1, 2, 3A6029 Other Commercial/Business Tort

Civil Rights (08) 1,2, 3I I A6005 Civil Rights/Discrimination

Defamation (13) 1, 2, 3I I A6010 Defamation (slander/libel)

Fraud (16) 1,2, 3 •1 A6013 Fraud (no contract)

Professional Negligence (25) 1, 2, 3I 1 A6017 Legal Malpractice

I ] A6050 Other Professional. Malpractice (not medical or legal) 1,2, 3

Other (35) Damage tort 1, 2, 3E - 1 A6025 Other Non-Personal injury/Property

Wrongful Termination (36) L 11 A6037 Wrongful Termination 1, 2, 3

Other Employment (15)1, 2, 3

10

n A6024 Other Employment Complaint Caser ,l I A6109 Labor Commissioner Appeals

(not unlawful detainer or wrongful 2, 5A6004 Breach of Rental/Lease Contract

Breach of Contract/ Warrantyeviction)

2, 5A6008 Contract/Warranty Breach -Seller(06) Plaintiff (no fraud/negligence)(not insurance) ¶ I A6019 Negligent Breach of Contract/Warranty (no fraud) 1, 2, 5

(not fraud or negligence) 6 5I X I A6028 Other Breach of Contract/Warranty

5,6, 11l 1 A6002 Collections Case-Seller PlaintiffCollections (09)

= A6012 Other Promissory Note/Collections Case 5, 11A6034 Collections Case-Purchased Debt (Charged Off Consumer Debt 5, 6, 11

Purchased on or after January 1, 2014)

Insurance Coverage (18) 1,2, 5,8A6015 Insurance Coverage (not complex)

1 1 A6009 Contractual Fraud 1,2, 3,5

Other Contract (37) 1, 2, 3, 5A6031 Tortious Interference

1, 2, 3, 8, 9E l A6027 Other Contract Dispute(not breach/insurance/fraud/negligence)

Eminent Domain/Inverse--•,-

1 iI i A7300 Eminent Domain/CondemnationCondemnation (14) Number of parcels 2, 6

Wrongful Eviction (33) 2, 6E l A6023 Wrongful Eviction Case

2, 6Ellili A6018 Mortgage ForeclosureOther Real Property (26) 2, 6I I I I A6032 Quiet Title

landlord/tenant, foreclosure) 2, 6A6060 Other Real Property (not eminent domain,

Unlawful Detainer-Commercial(31) drugs or wrongful eviction) 6, 11E l A6021 Unlawful Detainer-Commercial (not

Unlawful Detainer-Residential(32) drugs or wrongful eviction) 6, 11A6020 Unlawful Detainer-Residential (not

Unlawful Detainer- E l A6020F Unlawful Detainer-Post-Foreclosure 2, 6, 11Post-Foreclosure (34)

Unlawful Detainer-Drugs (38) F - I A6022 Unlawful Detainer-Drugs 2, 6, 11

• •

LACIV 109 (Rev 2116)

LASC Approved 03-04CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATIONLocal Rule 2.3

Page 2 of 4

Doca 1 Pagel!) 2 4 - D o c I D = 1700517112 - D o c Ty p e = OTHER

(Page 25 o f 2 6 )

SHORT TITLE: STABLER V. NEW L I N E CINEMA CASE NUMBER

z 711itiscllaneous z.< Miscellaneous Enforcement .%iIi.Paiiioili7. Civil Complaints of Judgment Provislonally Complex Litigation Judicial Review

. .

A B C ApplicableCivil Case Cover Sheet Type of Action . Reasons - See Step 3

Category No. (Check only one) , A b o v e

Asset Forfeiture (05) 2, 3, 61 1 A6108 Asset Forfeiture Case

Petition re Arbitration (11) Arbitration 2, 51 1 A 6 11 5 Petition to Compel/Confirm/Vacate

2, 8A6151 Writ - Administrative MandamusWrit of Mandate (02) Case Matter 2E T A6152 Writ - Mandamus on Limited Court

A6153 Writ - Other Limited Court Case Review 2

Other Judicial Review (39)._

2,81 1 A 6 1 5 0 Other Writ /Judicial Review

AntitrustiTrade Regulation (03) [ 1 A 6 0 0 3 Antitrust/Trade Regulation 1, 2, 8

Construction Defect (10) 1 1 A6007 Construction Defect 1, 2, 3

Claims Involving Mass Tart(40) 1, 2, 8A6006 Claims Involving Mass Tort

Securities Litigation (28) 1, 2, 8A6035 Securities Litigation Case

Toxic TortEnvironmental (30) 1,2, 3, 8I I A6036 Toxic Tort/Environmental

Insurance Coverage Claimsfrom Complex Case (41) (complex case only) 1, 2, 5, 8E i A6014 Insurance Coverage/Subrogation

1 1 A 6 1 4 1 Sister State Judgment 2, 5, 11

2,5I 1 A6160 Abstract of Judgment

Enforcementof Judgment (20)

relations)

unpaid taxes)

2,9

2, 8

r I A6107 Confession of Judgment (non-domestic

1 j A6140 Administrative Agency Award (not

on Unpaid Tax 2, 8A5114 Petition/Certificate for Entry of Judgment

Case 2, 8, 9L I I I A6112 Other Enforcement of Judgment

RICO (27) I 1 A6033 Racketeering (RICO) Case 1, 2, 8

1, 2, 81 I A6030 Declaratory Relief Only .

Other Complaints 2, 81 I A6040 Injunctive Relief Only (not domestic/harassment)(Not Specified Above) (42) i i A 6 0 1 1 Other Commercial Complaint Case (non-tort/non-complex) 1, 2, 8

1, 2, 8 •E - 1 A6000 Other Civil Complaint (non-tort/non-complex)

Partnership CorporationGovernance (21) Case 2, 8r ii 1 A 6 11 3 Partnership and Corporate Governance

2, 3, 9I I A6121 Civil Harassment2, 3, 9= A6123 Workplace Harassment

Other Petitions (Not n A6124 Elder/Dependent Adult Abuse Case 2,3, 9Specified Above) (43) I . I A 6 1 9 0 Election Contest

II A6110 Petition for Change of Name/Change of Gender22, 7

L I I I A6170 Petition for Relief from Late Claim Law 2, 3, 8I i A6100 Other Civil Petition 2, 9

• •

LACIV 109 (Rev 2/16)LASC Approved 23-04

CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATION

Local Rule 2.3Page 3 of 4

Docft 1 P a g e # 2 5 - 0 0 0 I D = 1 7 0 0 5 1 7 11 2 - D o c Ty p e = OTHER

(Page 2 6 o f 2 6 )

•sHoarrm.E: STABLER V. NEW LINE CINEMA CASE NUMSER

Step 4: Statement of Reason and Address: Check the appropriate boxes for the numbers shown under Column C for thetype of action that you have selected. Enter the address which is the basis for the filing location, including zip code.(No address required for class action cases).

ADDRESS: 4000 WARNER BLVDREASON:

0 1 . [ 2 J 2 . 0 3 . 0 4.E15.E16.07.1= 8.09.010.011.

CITY;

BURBANK •

STATE:

CA

ZIP CODE:

91522

Step 5: Certification of Assignment: I certify that this case is properly filed in the CENTRAL District ofthe Superior Court of California, County of Los Angeles (Code Civ. Proc., §39 , and Local Rule 2.3(a)(1)(E)].

Dated: JUNE 12 , 2017GNATURE OF ATTORNEY/FILING PARTY)

BRYAN J . FREEDMAN, ESQ.

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

1. Original Complaint or Petition.

2. I f filing a Complaint, a completed Summons form for issuance by the Clerk.

3. Civil Case Cover Sheet, Judicial Council form CM-010.

4. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.02/16).

S. Payment in full of the filing fee, unless there is court order for waiver, partial or scheduled payments.6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a

minor under 18 years of age will be required by Court in order to issue a summons.

7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendummust be served along with the summons and complaint, or other initiating pleading in the case.

t o "( 0 3

1:0

tr-e•

LACIV 109 (Rev 2116)

•LASC Approved 03-04CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATIONLocal Rule 2.3

Page 4 of 4

Doc# 1 Page# 2 6 - D o c I D = 1700517112 - D o c Ty p e = OTHER