PBT - Courthouse News Service€¦ · tm: beasley fntm, llc 1125 wainur sti!eft plllladf.iphla, pa 19107 215 592 1000 215 592. 8.360 (fax) 11. ~ in the united states district court

JS 44 (Rev 06/17) PBT The JS 44 civil cover sheet and the mfonnahon contamed herem provided by local rules of court Tills form, approved by the Ju purpose of lllltlatmg the c1vtl docket sheet (SEE lflSTRUCT!ON.

I. (a) PLAINTIF:FS

A. Charles Peruto, Jr.

(b)

( C) Attorneys (Firm Name. Address. and Te/epl1on

Louis F. Tumolo, Esq, The Beasley Firm, LLC, 1125 Walnut St. Phila, PA 19107 215.592.1000

DEFENDA.~TS

Hoo In Kim

NOTE. IN LAND CONDEMNATION CASES, USE THE THE TRACT OF LA."ID INVOLVED

Attorneys (ff Known)

ICTIO'.'J (Placean "X"'inOneBoxOn/y) III. CITIZENSHIP OF RINCIP AL PARTIES rPlace an "'X • tn One Box/or Pla1n1iff (For Diversity Cases 0 ) and One Box for Defendant)

CJ I U S Government

Plamllff ~ 3 F era! Questton PTF PTF DEF

:J 2 U S Government Defendant

(US. Government Not a Party)

Diversity (Indicate Citizenship of Parties in Item Ill)

C111zen of This State CJ4 CJ4

C111zen of Another State ::"JS OS

a 6 CJ 6

IV. NATURE OF Click here for Nature of Suit Code Descn t10ns ONTRlro "'~ORFEITUREIPENA ANKRC:PTG THER'8'£ATu:rES\llW

::"J 110 Insurance PERSONAL INJURY PERSONAL INJLRY CJ 625 Drug Related Seizure CJ 422 Appeal 28 USC 1 S8 ::"J 37S False Clallils Act CJ 120 Manne CJ 310 Airplane 0 365 Personal Injury · of Property 21L'SC881 ::"J 423 Withdrawal CJ 376 Qui Tam (31 USC :J 130 Miller Act :J 3 IS Airplane Product Product Liab1hty 0 690 Other 28 USC I S7 3 729(a)) ::"J 140 Negollable Instrument Lrnbihty :J 367 Health Care/ CJ 400 State Reapporuonment :J 1 SO Recovery of Overpayment CJ 320 Assault, Libel & Phannaceullcal m=======::l:".=::i:I CJ 410 Anlltrust

& Enforcement of Judgment Slander Personal Injury CJ 430 Banks and Banlang CJ 151 Medicare Act CJ 330 Federal Employers' Product L1abihty :J 450 Commerce CJ 152 Recovery of Defaulted L1ab1hty :J 368 Asbestos Personal ::"J 83 5 Patent · Abbrevrnted CJ 460 Deportallon

Student Loans CJ 340 Marme Injury Product New Drug Apphcallon CJ 4 70 Racketeer Influenced and (Excludes Veterans) .CJ 345 Marme Product Lrnb1hty CJ 840 Trademark Corrupt Organ1zal1ons

CJ 153 Recovery of Overpayment Liabihty PERSONAL PROPERTY fi!iiiOii'.!!DY!lo~iii!i'!iiiiil[li!filJo~E\~u~· ~!!i~J~ .. )if!RJ CJ 480 Consumer Credi.I ofVeteran'sBenefits 0 350MotorVeh1cle CJ 3700therFraud 0 710Fa1rLaborStandards CJ 861 HIA(I395tl) :'.'J Cable/Sat TV

CJ 160 Stockholders' Smts CJ 355 Motor Velucle 0 371 Truth m Lendi.ng Act CJ 862 Black Lung (923) 850 ecunttes/Commodilles/ CJ 190 Other Contract Product L1ab11Ity CJ 380 Other Personal 0 720 Labor/Management CJ 863 DIWC/DIWW (405(g)) Exchange :::J 195 Contract Product L1ab1hty CJ 360 Other Personal Property Damage Relattons 0 864 SSID Title XVI 90 Other Statutory Acttons CJ I 96 Francluse Injury ::J 385 Property Damage CJ 740 Railway Labor Act CJ 865 RSI (405(g)) 891 Agncultural Acts

CJ 362 Personal Injury · Product Liability 0 75 I Famliy and Medi.cal 0 893 Envrronmental Matters Medical Mal racllce Leave Act CJ 895 Freedom of Iuformatton

fij!fl!ijijA~ftR!ij~Oj!PEE~RBii!iillil!Jii[IVI~fllIU~·,!filG§fljjgii9i~RI~S~O~NEilijR'l'ifEl'm§:ffi~o~N~S[!ICJ 790 Other Labor L111ga11on li!iE~D!?i]~~ij~illj~· Act ::"J 210 Land C.ondemnallon CJ 440 Other Civ!l Rights Habeas Corpus: CJ 791 Employee Retirement CJ 870 Truces (US Plamllff CJ 896 Arb1tral10n 0 220 Foreclosure CJ 441 Vollng 0 463 Aben Detamee Income Secunty Act or Defendant) ::"J 899 Administrallve Procedure CJ 230 Rent Lease & Ejectment ::"J 442 Employment CJ 510 Motions to Vacate CJ 871 lRS Third Party Act/Review or Appeal of CJ 240 Torts to Land CJ 44 3 Housmg/ Sentence 26 USC 7609 Agency Dec1s10n CJ 245 Tort Product L1ab1hty Accommodallons CJ 5 30 General CJ 950 Consl1tul1onal1ty of 0 290 All Other Real Property CJ 445 Amer w/D1sab1h11es · CJ 535 Death Penalty _,,.IA;lMIGRATIO State Statutes

Employment Other: CJ 462 Natural1Z8l1on Apphcation CJ 446 Amer w 'D1sab1hl1es · CJ S40 Mandamus & Other CJ 465 Other l1DIDigrat10n

Other CJ 5 50 C1vd Rights Acllons CJ 448 Educallon :'.'J 5 SS Pnson Cond111on

CJ 560 C1vd Detamee .

RIGIN (Placean "X'"inOneBoxOn/y)

gmal ['J 2 Removed from roceeding State Court

0 3

Condi.llons of Confinement

Remanded from Appellate Court

'.1 4 Remstated or '.1 5 Transferred from Reopened Another DIStrict

(specifo)

'.1 6 Multtdtstnct L1t1gat1on -Transfer

Cite the U .S C1vtl Statute under winch you are filmg (Do 1101 cite j11risdictio1111/ st11t11tes 1111/ess diversity)

C1 8 Mult1d1stnct L1t1gation -

Drrect Ftle

. CAUSE OF ACTION 1-S:.e:::.:c:o::ti""'on,,..,s...,2:.:5..,1_..0-=-2=2------------------------------Bnef descnption of cause

VII. REQUESTED L1'l COMPLAINT:

VIII. RELATED CASE(S) IF ANY

DATE

11/07/2018 FOR OFFICE CSE ONLY

Defendants willfull and intentionall obtained ille al recordin n CHECK IF THIS IS A CLASS ACTION DEMAND $

UNDERRL'LE23,FRCvP Gx~e: s of150,000.00

(See instrnctions) JUOOE

~RECORD

RECEIPT# AMOUNT APPL YING IFP JUDGE

of Plaintiff CHECK YES only if

.n.:RY DEMAND:

DOCKET NUMBER

MAG JUDGE

m complamt

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Case 2:18-cv-04818-PBT Document 1 Filed 11/07/18 Page 1 of 38

UNITED STATES DISTRICT COL'RT

~:,. ~, STERN DISTRICT OF PENNSYLVANIA I! B 1 8 'l DESIGNATION FORM 18 ..:

(to be used by counsel or pro se ain in cate the category of the case for the purpose of assignment to the appropriate calendar)

Address of Plaintiff: _______ 2101 .. ~.i[le Str~e~hila~elphia, ~~!?~0~-- ____ _

Address of Defendant: 6007 Sepulveda Blvd., Van Nuys, CA 91411 --- --- ---------- - --- ------ ---

Place of Accident, Incident or Transaction: 2101 Pine Street, Philadelphia, PA 19103

RELATED CASE, IF ANY:

Case Number~ Judge: ·- _ _ _ Date Terminated.

Civil cases are deemed related when Yes 1s answered to any of the following questions·

1. Is this case related to property included in an earlier numbered suit pending or within one year previously terminated action in this court?

2. Does this case mvolve the same issue of fact or grow out of the same transaction as a prior suit pending or within one year previously terminated action in this court?

3. Does this case involve the validity or infringement of a patent already in suit or any earlier numbered case pendmg or within one year previously terminated action of this court?

4 Is this case a second or successive habeas corpus, so al s curity appeal, or prose civil rights case filed by the same individual?

YesD

YesD I certify that, to my knowledge, the within case this court except as noted above.

e now pending or within one year pre

DATE ~/07/201~ _ 314255 Attorney ID #(if applicable)

CIVIL: (Place a '-i in one category onl;y)

A.

D D D D

§ D

Federal Question Cases:

Indemnity Contract, Marine Contract, and All Other Contracts FELA Jones Act-Personal Injury Antitrust Patent Labor-Management Relations Civil Rights Habeas Corpus Securities Act(s) Cases Social Security Review Cases All other Federal Question Cases (Please specify) . ____ Federal Wjre~Act

B. Diversity Jurisdiction Cases:

D t. D 2. D 3. D 4. D 5. D 6. D 7 D s. D 9.

Insurance Contract and Other Contracts Airplane Personal lnJury Assault, Defamation Marine Personal Injury Motor Vehicle Personal Injury Other Personal Injury (Please specify) _ _ _ __ __ _

Products Liability Products Liability - Asbestos All other Diversity Cases (Pleasespectfy) _____________ _

ARBJTRA TION CERTIFICATION (The effect of this certification zs to remove the case from ebg1b1bty for arbitration)

Louis F. Tumolo _ _ _ _ _ _ _ _ _, counsel of record or pro se plamtdf, do hereby certify

uant to Local Civil Rule 53 2, § 3(c) (2), that to the best of my knowledge and belief, the damages recoverable in this civil action case exceed the sum of $150,000.00 exclusive of interest and costs·

Relief other than monetary damages ts sought.

DATE~!!07_/2018 ________ -~-.- ___ _

NOV 0 7 2018 314255

Attorney-at-Law I Pro Se Plaintiff Attorney ID #(if applicable)

NOTE A tnal de novo will be a tna! by Jury only tf there has been comphance with F RC P 38

Ci• 609 (512018)


IN THE UNITED ST A TES DISTRICT COURT

l b A. Charles Peruto, Jr.

v.

Hoo In Kim, et al.

EASTERN DISTRICT OF PENNSYLVANIA

AGEMENT TRACK DESIGNATION FOR.1\1

CIVIL ACTION

18 (818 NO.

In accordance with the Civil Justice Expense and Delay Reduction Plan of this court, counsel for plaintiff shall complete a Case Management Track Designation Form in all civil cases at the time of filing the complaint and serve a copy on all defendants. (See § I :03 of the plan set forth on the reverse side of this form.) In the event that a defendant does not agree with the plaintiff regarding said designation, that defendant shall, with its first appearance, submit to the clerk of court and serve on the plaintiff and all other parties, a Case Management Track Designation Form specifying the track to which that defendant believes the case should be assigned.

SELECT ONE OF THE FOLLOWING CASE MANAGEMENT TRACKS:

(a) Habeas Corpus - Cases brought under 28 U.S.C. § 2241 through§ 2255. ( )

(b) Social Security - Cases requesting review of a decision of the Secretary of Health and Human Services denying plaintiff Social Security Benefits. ( )

(c) Arbitration - Cases required to be designated for arbitration under Local Civil Rule 53.2. ( )

( d) Asbestos - Cases involving claims for personal injury or property damage from exposure to asbestos. ( )

(e) Special Management - Cases that do not fall into tracks (a) through (d) that are commonly ref erred to as complex and that need special or intense management by Q the court. (See reverse side of this form for a detailed explanation of special management cases.) (

(f) Standard Management - Cases that do not fall into any one of the other tracks. ( )

11/7/2018 Plaintiff, A. Charles Peruto, Jr. Date Attorney-at-law Attorney for

215.592.1000 215.592.1523 [email protected]

Telephone FAX Number E-Mail Address

(Civ. 660) 10/02

NOV 0 7 2018


Tm: BEASLEY FntM, LLC 1125 WAINUr STI!EFT

PlllLADF.IPHlA, PA 19107 215 592 1000

215 592. 8.360 (FAX) WWW.BEASl.EYFIR.UCOM

11.

~

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

A. Charles Peruto, Jr. 2101 Pine Street Philadelphia, PA 19103

v.

Hoo In Kim cf o IPC Television, LLC 6007 Sepulveda Blvd. Van Nuys, CA 91411

Plaintiff,

: CML COMPLAINT

NO. ___ _

( [J 1 8

And JURY TRIAL DEMANDED

Eli Holzman cf o IPC Television, LLC 6007 Sepulveda Blvd. Van Nuys, CA 91411

And

Patrick Reardon 527 Grand Street Apt. 6F Brooklyn, NY 11211-4391

And

Josh Miller cf o Amazon Alternative, LLC 1620 26th Street Suite4000N Santa Monica, CA 90404-4060

And

IPC Television, LLC 6007 Sepulveda Blvd. Van Nuys, CA 91411

And

Amazon Alternative, LLC 1620 26th Street Suite4000N Santa Monica, CA 90404-4060

And

1

PERVTo v. Hoo IN KIM, ETAL. COMPLAINT


Tm: BEASLEY FlitM, LLC 1125 WAU<\JI STREFT

PlllLAOOIPllTA, PA 19107 215.592. IOOO

215 592. 8360 (FAX) WWW .BEASl.EYFlll'\t.COM

Roe Nation, LLC c/o Corporate Creations Network, Inc. 1001 State Street, No. 1400

Erie, PA 16501

Defendants.

INTRODUCTION

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

Honorable Genece Brinkley.

2. On 30 May, 2018, the defendants, and in particular defendant Hoo In

Kim, on behalf of all defendants and employed by IPC Television, LLC (IPC),

interviewed Peruto for an upcoming docu-series slated for 2019 release by the Amazon

and Roe 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 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 Peruto, the defendants' personnel lied, and continued to

use a device to intercept record the audio (and perhaps video) of the off the record

conversation.

6. Defendants also misled Peruto as to the true intent of, and entities

involved with, the interview.

7. 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.

2

PERUTO V, Hoo IN KIM, ETAL. COMPIAINT


THE BEASLE't FIItM. LLC 1125 WAINUr STIUiITT

PH1LADEIJ>HIA, PA 19107 215 5921000

215 592 8360(FAX) WWWJH!ASLEYFIR."LCO:M

8. Peruto had a justifiable expectation that its wire, oral, or electronic

communications were not subject to interception by the defendants' devices.

9. The defendants' fraudulent representations to Peruto induced him to

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

communications.

10. Defendant Hoo In Kim (Kim) was the IPC employee in Philadelphia, PA to

interview Peruto at his office; she intentionally and illegally obtained the recording.

11. Defendant Eli Holzman (Holzman) has provided a sworn statement that

"[he] [is] the Chief Executive Officer at IPC Television, LLC (IPC); in [his] role as CEO,

[he] oversee[s] all projects produced by IPC, including the #FreeMeek Documentary on

behalf of IPC." Holzman statement attached as Exhibit "A."

12. Defendant Holzman's sworn statement admits that he has possession of

the illegally obtained recording.

13. Defendant Patrick Reardon (Reardon) is an agent, servant and/ or

employee of defendant Roe Nation, and has provided a sworn statement that "in [his]

role as Executive Vice President, [he] oversee[s] the various creative and logistic aspects

relating to the production of the Documentary Series." Reardon statement is attached

as Exhibit "B."

14. Defendant Reardon's statement admits that "Roe Nation is producing the

Documentary Series with IPC for broadcast and distribution by Amazon."

15. Defendant Reardon's sworn statement admits that he has possession of

the illegally obtained recording.

3

PERUTo v. Hoo IN KIM· ET AL. COMPLAINT


Tm: BEASLEY FIRM, LLC 1125 WALNUI STREET

l'iDLADEIPHJA, PA 19107 215.592. IOOO

215 .592 .. 8360 (FAX) WWW .BEASl.EYFIR.'\f.ffiM

16. Defendant Josh Miller (Miller) is an agent, servant and/or employee of

defendant Amazon Alternative, LLC, has provided a sworn statement that IPC is in

charge of providing all production services for the Documentary, including the filming

and recording of interviews." Miller statement is attached as Exhibit "C."

17. Defendant Miller's sworn statement admits that he has possession of the

illegally obtained recording.

18. Defendant Miller's sworn statement admits that Amazon Alternative, LLC

is producing the documentary at issue with co-defendants IPC Television, LLC (IPC)

and Roe Nation, LLC.

19. In violation of, inter alia, 18 U.S.C. § 2511(1)(c)-(d), these defendants are

involved in the interception, retention, distribution, disclosure (attempted and actual),

use (attempted and actual), and/or manipulative editing of the illegally obtained

recording, as well as the public relations use of it, in addition to other involvement with

it and the Meek Mill docu-series.

20. All defendants' continuing wrongful possession, disclosure, and use of this

digital recording has resulted in it being knowingly altered and illegally distributed to

third parties.

21. These illegally intercepted and digitized oral communications were then

edited and leaked to the press so that Peruto's off the record words would be

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

defendants' own agenda in maximizing the buzz and profitability of the upcoming Meek

Mill Documentary Series.

4

PERUIOV. Hoo IN KIM,, ET AL. COMPI.AINT


THE BEASLEY FlltM, LLC 1125 W AI>IUT STREET

PinLADELPHJA, PA 19107 215 592 IOOO

Zl~.~92.8.360(FAX)

WWW .lll.ASLEYFIR.\1.COM

22. The Commonwealth of 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 Peruto instructed them to go off the record.

23. Plaintiff is a "person" whose wire, oral, or electronic communications were

intercepted within the meaning of 18 U.S.C. § 2520.

24. As a direct result of the defendants' actions, Peruto suffered irreparable

harm to his business and property and is entitled to an award of the greater of the

actual damages suffered or the statutory damages and injunctive relief pursuant to 18

u.s.c. §2520.

25. In light of the defendants' egregious acts, Peruto is entitled to punitive

damages and reasonable attorneys' fees and costs pursuant to 18 U.S.C.

§§252o(b )(2)&(3).

26. Therefore, pursuant to 18 U.S.C. §2510, et seq, Plaintiff, by his attorneys,

The Beasley Firm, brings this Wiretap Action against the defendants, and in support

thereof avers as follows:

PARTIES

27. A. Charles Peruto, Jr., is a citizen of the Commonwealth of Pennsylvania,

an Attorney, and resides at the identified address.

28. Defendant Hoo In Kim is an adult individual employed by IPC Television,

LLC (IPC); Ms. Kim attended and participated in the 30 May 2018 interview and has a

service address identified above.

5

PERUTo v. Hoo IN KIM. EI AL.

COMPIAINT


TllE BEASLEY FntM, LLC 1125 WAWL'T STREFT

PllILADEIPHIA, PA 19107 215 592.1000

215592 8360(FAX) WWW .B~"LEUilL'\'LCOM

29. Defendant Eli Holzman is an adult individual employed as the Chief

Executive Officer by IPC; Mr. Holzman oversees all projects produced by IPC, including

the # FreeMeek Documentary and has a service address identified above.

30. Defendant Patrick Reardon is an adult individual employed as Executive

Vice President, Television for Roe Nation LLC; Mr. Reardon resides in New York at the

identified address, and oversees the various creative and logistic aspects relating to the

production of the Documentary Series.

31. Defendant Joshua Miller is an adult individual employed as an

unscripted creative executive at Amazon Alternative, LLC; Mr. Miller oversees the

creative development of the # FreeMeek Documentary on behalf of Amazon Alternative

and has a service address identified above.

32. Defendant IPC Television, LLC (IPC) is in charge of providing all

production services for the Documentary, including the filming and recording of

interviews, and is the entity that conducted the 30 May 2018 interview at Peruto's

Philadelphia office; IPC has a service address identified above.

33. Defendant Amazon Alternative, LLC (Amazon) is a branch of Amazon, is

producing the documentary at issue with co-defendants IPC Television, LLC (IPC) and

Roe Nation, LLC, and has a service address identified above.

34. Defendant Roe Nation, LLC is an entertainment company with its nerve

center in New York, does substantial business in Philadelphia County, litigates in the

Eastern District of Pennsylvania, and has an address for service of process identified

above.

6

PERUTQ v. Hoo IN KIM. ET AL. COMPIAINT


Tm: BEASLEY FIRM, LLC 1125 W A1NUI SrnE!IT

l'HILADEU'HIA. PA 191 07 215 592, 1000

215 ,592.8360 (FAX) WWW .Bf.ASLEYF1R.'1COM

35. Roe Nation is producing the Documentary Series with IPC for broadcast

and distribution by Amazon.

JURISDICTION AND VENUE

36. This Honorable Court has Federal Question Jurisdiction pursuant to 28

U.S.C. §§ 2510-22 (commonly referred to as the Federal Wiretap Act).

37. This Honorable Court has subject matter jurisdiction of this case pursuant

to 28 U.S.C. §§ 1332. The amount in controversy substantially exceeds the requirement

for Federal Diversity Jurisdiction and to guarantee a jury trial, exclusive of interest and

costs. The defendants are citizens of states other than the state in which the Plaintiff

resides.

38. Jurisdiction and venue are both proper in the United States District Court

For The Eastern District of Pennsylvania as the defendants all participated in the 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 as it relates to the "Meek Mill" docu-series.

39. Jurisdiction and venue are further proper in the Eastern District of

Pennsylvania as the tortious actions occurred in Philadelphia, Pennsylvania, the Roe

Nation nerve center is in New York, Reardon operates out of New York, and the IPC and

Amazon Alternative defendants' nerve center is in California.

40. Therefore, that defendant Kim and IPC personnel, on behalf of all

defendants, traveled to Philadelphia to illegally, tortuously and maliciously obtain the

recording at issue makes it plain that the most convenient and proper location for this

lawsuit is in the Eastern District of Pennsylvania.

7

PERuro v. Hoo IN KIM. ET AL. COMPI.AINT


THE BEASLEY FiltM, LL(' 112.5 WAlNUTSTREET

PmlADElJ'HJA. PA 19107 215 592.1000

215 592 .. 8360 (FAX) WWW .BEASI.EVFIR.'\f..COM

FACTS

41. As described in the Introduction, this Federal Wiretap Action is brought as

a direct result of the defendants' willfully and intentionally intercepting and recording a

discussion after Peruto specifically revoked any consent or permission.

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

defendants, conducted an interview of Peruto in Peruto's Philadelphia office for

purposes of the defendants' upcoming Meek Mill Documentary Series.

43. 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. Philadelphiabased 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 Zand Roe Nation are producing the untitled project with IPC and documentary filmmaker Isaac Solotaroff.

44. As part of the defendants' preparation for this Documentary Series, they

sought, and were granted, an interview with Peruto in Philadelphia, and traveled to this

district to conduct two separate interviews of Peruto.

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

46. After the interview was completed, Peruto instructed the interviewer, Ms.

Kim, and others participating on behalf of all defendants, to go off the record and to stop

recording; they agreed, stated they stopped the audio recording, and had the camera

turned facing the wall.

8

PERUI'OV. Hoo IN KIM. ETAL. COMPLAINT


THE BEASLEY FntM, LLC 1125 w AlRlJT STREFI

PllnADEIPHIA, PA 19107 215.5921000

215 592.8360(FAX) WWW .BEASl.FYFIR..\LCOM

47. Unbeknownst to Peruto, the audio was left on, intercepting the off the

record oral conversation and permanently digitizing the illegally intercepted oral

communication.

48. The only reason that 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.

49. Had these defendants informed Peruto that they were continuing the

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

discussion and instructed them to leave.

50. The defendants' fraudulent representations to Peruto induced him to

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

communications.

51. These intentional misrepresentations resulted m valuable personal

property of Peruto's being illegally acquired by the defendants.

52. These illegally intercepted and digitized oral communications were then

edited and leaked to the press so that 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.

9

PERlITOV. Hoo IN KIM, ET AL· COMPIAINf


Tiii: BEASLEY FIIIM, LLC 1125 w AlNU1 STREET

l'HILADEIPHIA, PA I 9:07 215.5921000

215.592 8360 (FAX) WWW .BEASLEil1R..'\LCOM

COUNT I FEDERAL WIRETAP ACT VIOIATIONS

PIAINTIFFv. HOO IN KIM

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

54. Defendant Kim traveled to Philadelphia to participate in and conduct the

30 May 2018 illegal interception of the off the record oral communications, and

permanently digitized the illegally intercepted oral communication.




56. In violation of 18 U.S.C. § 2511(1)(a), Kim willfully and intentionally

intercepted or endeavored to intercept Plaintiff's wire, oral, and/or electronic

communications by surreptitiously recording the conversation.

57. In violation of 18 U.S.C. § 2511(1)(c), Kim willfully and intentionally

disclosed the contents of Plaintiff's wire, oral, and/or electronic communications,

knowing or having reason to know that the information obtained through the

interception of wire, oral, or electronic communication in violation of 18 U.S.C. § 2511.

58. In violation of 18 U.S.C. § 2511(1)(d), Kim willfully and intentionally used

the contents of wire, oral, electronic communications, knowing or having reason to

know that the information was obtained through the interception of a wire, oral, or

electronic communication in violation of 18 U.S.C. § 2511.

59. Peruto specifically told Kim he 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.

10

PERUTO v. Hoo IN KIM. ET AL. COMPLAINT


THE BEASLEY FIRM, LLC 1125 W AU<UT STREF!

l'HlLADELPHJA. PA J 9107 215 .592 1000

215 592 8360 (FAX) WWW.BEASLEVFIRUCOM


communications were not subject to interception.



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

defendants, including Kim.

63. Kim's continuing wrongful possession of this digital recording has resulted

in it being maliciously edited and illegally distributed to third parties, all to the further

detriment of the Plaintiff.

64. As a direct result of Kim's actions, Plaintiff suffered irreparable harm to

his business and property and is entitled to an award of the greater of the actual

damages suffered or the statutory damages and injunctive relief pursuant to 18 U.S.C.

§2520.

65. In light of Kim's egregious acts, Plaintiff is entitled to punitive damages

against her, personally, and reasonable attorneys' fees and costs, pursuant to 18 U.S.C.

§§252o(b )(2)&(3).

WHEREFORE, Plaintiff demands judgment against all defendants and seeks,

pursuant to 18 USC §2520, et seq., damages substantially in excess of the jurisdictional

limit to guarantee a jury trial, punitive damages, and such other relief as this Honorable

Court permits.

11

PERUTO v. Hoo IN KIM, ET AL. COMPLAINT


THE BEASLEY FIRM, LLC 1125 WAINUfSTIIBET

l'lllIADEIPllIA, PA 19107 215 5921000

215 592 8360 {FAX) WWW JIEASLEYFill.'1.COM

COUNT II FEDERAL WIRETAP ACT VIOLATIONS

PLAINTIFF v. ELI HOLZMAN


67. Defendant Holzman oversaw the 30 May 2018 interview, the illegal

interception of the off the record oral communications, and caused the permanent

digitization of the illegally intercepted oral communication.




69. In violation of 18 U.S.C. § 2511(1)(a), Holzman willfully and intentionally

instructed the codefendants and their agents, servants and/or employees to illegally

capture and record Plaintiffs wire, oral, and/or electronic communications by

surreptitiously recording the conversation.

70. In violation of 18 U.S.C. § 2511(1)(c), Holzman willfully and intentionally

disclosed the contents of Plaintiffs wire, oral, and/or electronic communications,



71. In violation of 18 U.S.C. § 2511(1)(d), Holzman willfully and intentionally

used the contents of wire, oral, electronic communications, knowing or having reason to



72. Although Peruto specifically told Kim he revoked any consent or

permission that was given for the on the record interview once that interview was

12

PERUTQ v. Hoo IN KIM, ET AL. COMPLAINT


THE BEASLE'I< FnlM, LLC 1125 W AI1<Vf STilEET

l'lllIADEll'IDA, PA 19107 215 592 1000

215 592 8360 (FAX) WWW BEASLEYFIR."\f.COM

concluded and the parties went off the record, I Iolzman, in his capacity as CEO and

overseer of this project, instructed Kim to continue recording, and Holzman further

instructed Kim and the agents, servants and/or employees of the defendants to edit,

save, manipulate and distribute the illegal recording, and intends to use the illegally

obtained recordings in the upcoming docu-series.






defendants, including Holzman.

76. Holzman's continuing wrongful possession of this digital recording has

resulted in it being maliciously edited and illegally distributed to third parties, all to the

further detriment of the Plaintiff.

77. As a direct result of Holzman's actions, Plaintiff suffered irreparable harm

to his business and property and is entitled to an award of the greater of the actual


§2520.

78. In light of Holzman's egregious acts, Plaintiff is entitled to punitive

damages against him, personally, and reasonable attorneys' fees and costs, pursuant to

18 U.S.C. §§252o(b)(2)&(3).



13

PERuro v. Hoo IN KIM. ET AL. COMPIAINT


TllE BEASLn' FlltM, LLC 1125 W ALNIJ'I STREFr

PHILADELPHJA, PA 19107 215 592.1000

215 592 8360(FAX) WWW .BE.ASl.EYF'IR.UCOM


Court permits.

COUNT III FEDERAL WIRETAP ACT VIOLATIONS

PLAINTIFF v. PATRICK REARDON


80. Defendant Reardon oversaw the 30 May 2018 illegal interception of the off

the record oral communications, and caused the permanent digitization of the illegally

intercepted oral communication.




82. In violation of 18 U.S.C. § 2511(1)(a), Reardon willfully and intentionally




83. In violation of 18 U.S.C. § 2511(1)(c), Reardon willfully and intentionally




84. In violation of 18 U.S.C. § 2511(1)(d), Reardon willfully and intentionally




---·------------------------PERurov. Hoo IN KIM. ETAL.

COMPLAINT


l'llJl BEASLEY FI11M, LLC 1!25 W AUIUT STREE'I

l'HILADEIPHIA, PA 19107 2155921000

215 592.8360(FAX) WWW JIE.ASLEYl'lR"LCOM

85. Although Peruto specifically told Kim and the others involved in the

interview that he 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,

Reardon instructed Kim and/ or the other individuals involved in collecting, digitizing

and/ or storing and distributing to continue recording, and/ or Reardon further

instructed Kim and the agents, servants and/or employees of the defendants to edit,

save, manipulate and distribute the illegal recording, and intends to use the illegally

obtained recordings in the upcoming docu-series.






defendants, including Reardon.

89. Reardon's continuing wrongful possession of this digital recording has



90. As a direct result of Reardon's actions, Plaintiff suffered irreparable harm



§2520.

PERurov. Hoo IN KIM. ETAL. COMPLAINT


THE llEASLEY F'IllM, LLC 1125 WAINFI STREET

PHILADELPHJA, PA 19107 215 5921000

215.592.8360 (!<AX) WWW JIEASLEYlilll.'\tLC'.OM

91. In light of Reardon's egregious acts, Plaintiff is entitled to punitive

damages against him, personally, and reasonable attorneys' fees and costs, pursuant to

18 U.S.C. §§252o(b)(2)&(3).




Court permits.

COUNT IV FEDERAL WIRETAP ACT VIOLATIONS

PLAINTIFF v. JOSH MILLER


93. Defendant Miller, participated in the oversight of the 30 May 2018 illegal

interception of the off the record oral communications, and caused the permanent

digitization of the illegally intercepted oral communication.




95. In violation of 18 U.S.C. § 2511(1)(a), Miller willfully and intentionally




96. In violation of 18 U.S.C. § 2511(1)(c), Miller willfully and intentionally


16

PERUTO v. Hoo IN KIM. ETAL. COMPIAINT


THE BEASLEY FmM, LLC 1125 WAIM!I STREET

PlmADEll'HIA. PA 19107 215 .592 1000

215 592 8360(FAX) WWW .BEASLEYFIR."-COM



97. In violation of 18 U.S.C. § 2511(1)(d), Miller willfully and intentionally




98. Although Peruto specifically told Kim and the others involved in the

interview that he 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, Miller

instructed Kim and/or the other individuals involved in collecting, digitizing and/or

storing and distributing to continue recording, and/ or Miller further instructed Kim and

the agents, servants and/or employees of the defendants to edit, save, manipulate and

distribute the illegal recording, and intends to use the illegally obtained recordings in

the upcoming docu-series.






defendants, including Reardon.

102. Miller's continuing wrongful possession of this digital recording has



17

PERUIO v. Hoo IN KIM. ET AL. COMPLAINT


THE BEASLEY FIRM, LLC 1125 W A1MJ1 STI<liliT

PinLADEIPHIA, PA 19107

215 5921000 215.592 8360(FAX)

W\VW•EASL~YFIR.._'1.COM

103. As a direct result of Miller's actions, Plaintiff suffered irreparable harm to

his business and property and is entitled to an award of the greater of the actual


§2520.

104. In light of Miller's egregious acts, Plaintiff is entitled to punitive damages

against him, personally, and reasonable attorneys' fees and costs, pursuant to 18 U.S.C.

§§252o(b )(2)&(3).




Court permits.

COUNTV FEDERAL WIRETAP ACT VIOLATIONS

PIAINTIFF v. IPC


106. Defendant IPC, through its agents, servants and/or employees,

participated in the 30 May 2018 illegal interception of the off the record oral

communications, and permanently digitized the illegally intercepted oral

communication.

107. The Commonwealth of Pennsylvania is a "two consent" state, a "two

consent" statute, meaning that absent consent and permission by both parties to a

discussion, it is a crime to intercept the oral communication after Peruto instructed

them to go off the record.

18 ---- - ---------



DIE BEASLEY FlKM, LLC 1125 W AlNUf STREET

l'llILADELPHIA, PA 19107 215 592 1000

215 592 8360 (FAX) WWW .BEASLEYFl&'\LCO.M

108. In violation of 18 U.S.C. § 2511(1)(a), IPC willfully and intentionally

intercepted or endeavored to intercept Plaintiffs wire, oral, and/or electronic


109. In violation of 18 U.S.C. § 2511(1)(c), IPC willfully and intentionally



interception of \'\ire, oral, or electronic communication in violation of 18 U.S:C. § 2511.

110. In violation of 18 U.S.C. § 2511(1)(d), IPC willfully and intentionally used

the contents of wire, oral, electronic communications, knowing or having reason to



111. Peruto specifically told IPC personnel, including co-defendant Kim, that

he 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.






defendants, including IPC.

115. I PC's continuing wrongful possession of this digital recording has resulted

in it being maliciously edited and illegally distributed to third parties, all to the further

detriment of the Plaintiff.

19 ----

PERUTQ v. Hoo IN KIM. Er AL.

COMPIAINT


TllE BEAS~ FnlM, LLC 1125 W AINUI STRE!IT

PHIIADF.IJ>HIA, PA 19107 21S.5921000

215 592. 8360 (FAX) WWW .BEASl.EYFllt.\LCOM

116. As a direct result of IPC's actions, Plaintiff suffered irreparable harm to his

business and property and is entitled to an award of the greater of the actual damages

suffered or the statutory damages and injunctive relief pursuant to 18 U .S.C. §2520.

117. In light of IPC's egregious acts, Plaintiff is entitled to punitive damages

against it, and reasonable attorneys' fees and costs, pursuant to 18 U.S.C.

§§252o(b )(2)&(3).




Court permits.

COUNT VI FEDERAL WIRETAP ACT VIOLATIONS

PLAINTIPF v. AMAZON ALTERNATIVE, LLC


119. Defendant Amazon, through its agents, servants and/or employees,



communication.




121. In violation of 18 U.S.C. § 2511(1)(a), Amazon willfully and intentionally

intercepted or endeavored to intercept Plaintiffs wire, oral, and/or electronic


20

PERUio v. Hoo IN KIM. ET AL.

COMPI.AINT


THE BEASLEV FIRM, LLC 1125 WAIRL'T STREBT

PiDLADEll'HIA, PA 19; 07 215 592, IOOO

m 592. 8360 (FAX) WWW .BE~LEYFIRM .. COM

122. In violation of 18 U.S.C. § 2511(1)(c), Amazon willfully and intentionally




123. In violation of 18 U.S.C. § 2511(1)(d), Amazon willfully and intentionally




124. Peruto specifically told Amazon's agents, servant, and/or employees,

including co-defendant Kim, that he 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.






defendants, including Amazon.

128. Amazon's continuing wrongful possession of this digital recording has



129. As a direct result of Amazon's actions, Plaintiff suffered irreparable harm


21

PERUTO V. Hoo IN KIM. ETAL. COMPLAINT


TllE BEASLEY FIRM, LLC 1125 w AU<UT STREE7

PlllLADELPBIA, PA 19107 215 .5921000

215 .592 8360 (FAX) WWW .BF.ASl.EYFIR.'\LCOM


§2520.

130. In light of Amazon's egreg10us acts, Plaintiff is entitled to punitive

damages against it, and reasonable attorneys' fees and costs, pursuant to 18 U.S.C.

§§252o(b )(2)&(3).




Court permits.

COUNT VII FEDERAL WIRETAP ACT VIOLATIONS

PLAINTIFF v. ROC NATION, LLC


132. Defendant Roe Nation, through its agents, servants and/or employees,



communication.



the oral communication after Peru to instructed them to go off the record.

134. In violation of 18 U.S.C. § 2511(1)(a), Roe Nation willfully and intentionally

intercepted or endeavored to intercept Plaintiff's wire, oral, and/or electronic


22



THE BEASLEY FlKM, LLC 1125 WAIN!!!" STREET

i'Hn.wEU'HJA, PA 19107 215 592 1000

215 5928360(FAX) WWW .BEASI.EYFIR.'\:L(;OM

135. In violation of 18 U.S.C. § 2511(1)(c), Roe Nation willfully and intentionally




136. In violation of 18 U.S.C. § 2511(1)(d), Roe Nation willfully and

intentionally used the contents of wire, oral, electronic communications, knowing or

having reason to know that the information was obtained through the interception of a

wire, oral, or electronic communication in violation of 18 U.S.C. § 2511.

137. Peruto specifically told Roe Nation's agents, servant, and/or employees,

including co-defendant Kim, that he 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.






defendants, including Roe Nation.

141. Roe Nation's continuing wrongful possession of this digital recording has



23

PERUTQ V. Hoo INK.JM, ET AL. COMPLAINT


In BEASLEY FntM, LLC 1125 WAIRUT STI!EFI

PillLADEJJ>HIA, PA 19107 215 592 1000

215 sn 8360 C•AXJ WWW .BEASLEYFIR'\t.COM

142. As a direct result of Roe Nation's actions, Plaintiff has suffered irreparable

harm and is entitled to an award of the greater of the actual damages suffered or the

statutory damages and injunctive relief pursuant to 18 U.S.C. §2520.

143. In light of Roe Nation's egregious acts, Plaintiff is entitled to punitive

damages against it, and reasonable attorneys' fees and costs, pursuant to 18 U.S.C.

§§252o(b )(2)&(3).

WHERE:FORE, Plaintiff demands judgment against all defendants and seeks,


limit to guarantee a jury trial, punitive damages, and such other relief as this I lonorable

Court permits.

Remainder of this page is intentionally blank

24

PERuro v. Hoo IN KIM. ETAL. COMPLAINT


Tin: BEASLEY FnlM, LLC 1125 WAll<UT SIREFI

l'mLADE!PHIA, PA 19107 215 5921000

215 592 8360 (FAX) WWW .BEASLEYFl&.'d.COM

NOTICE OF PRESERVATION OF EVIDENCE

Pl.AINTIFF 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.

JURY DEMAND

Plaintiff demands a jury trial.

Dated: 7 November 2018

BY:

THE BEASLEY FIRM, LLC

J SE.B L rs F. T OLO THE BEASLEY FIRM, LLC The Beasley Building 1125 Walnut Street Philadelphia, PA 19107 215.592.1000 215.592.8360 (telefax) [email protected] [email protected] Attorneys for Plaintiff

25

PERuro v. Hoo IN KIM· ET AL. COMPIAINT


EXHIBIT

A


Case 2:18-cv-04468-PBT Document 12-3 Filed 11/01/18 Page 2 of 3

IN TU~ UNJt};J) STATES JllSTmcr .COURT FOR THE EASTERN DISTRICT'OF PENNSYLVANIA

A. CHARLES PERl1TO, JR.,

Plain:tit'f,

v. • •

:Sl:XX DEGREES MEDIA· ROCN!Tlo:N, : LLC; AMAZOWDJGITAt SERVICES, LLC; ·~ ~AZON PlUl\IE VIDEQ; ~;nd UlE IPC :; tGROUP,~ ~:

Defendants.

CIVIL ACTION .N"O. 18-~-4468-PBT

DECLARATION OF ELI HOLZMAN.

Ii Eli Holzinan, '.hereby Cleclare3 under penalty of petjtiry~ .as follows·:

!. I ilhl the PhiefEX,ecutive: Officer al !PC Television? LLO r'IPC")~

2. IPO'is prodqcing 'a documentary setjes on, Meek Mill with Roe Natiou) LLG1for

broadcast and diSttlbution by Amazon A1ternmi-qe, LLC {'~on'') {sued ificottectly as

';'Amazon Prlme Vid~o ~d .!\nll\ZOnDigital S~nticefl~ LLQ?') (hereinafter"1he "6Fr~Me((1<.

Do.Cumenfary").

3. ln thiS ~~' plW!tiff A.= Charl~s "P~ra..to, Jr. bas :uam~d ~ith.-e lP'C Gi:oµp1' .as a

defendant. TheJPC Group is not a corporate entity. The correct etiu1y is 1PC Telev'isiQn,. LLC~

4. !PC's principal place of business is mtos Angeles} ·CalifC1mia. 1ts S'cile mem.'ber is

NEG Otx'tations, Inc., dlbla Core Media, Gr9J1Ps \Vhicb fa ·i11~orp9~te~t in Delaware and has its

principal place of business in Los Angelesi Callforttla.

S. Amazon is fm~cing and will be'disttl'bJlting the #FreeMeek Do:cumentary.



6. In my role as 'CEO, I o"Versee all projec1s produced by IPC, including the

#FreeMeek Documentary on behalf of IPC.

7. !PC is responsible for providirtg production services for the #FreekMeek

Documentazy, \ncluding the.filming and recording of interviews.

8. IPC has never engaged nur worked with SixxDe-grees Media. SiXX. Degte~

Media has no role in the #FreeMeek Documentary and has not been involved in any.aspect of file

#FreeMeek Docuntentru.y. :Before learning of this lawsuit, fhad never heard of Six:x:: Degrees

Media.

9. Upon infonnation and belief, the only people present dilring the filmlng and

recording of Mt. Petuto;s interview on May 30, 2018 ·were Mr. Peruto and people employed by

or working for IPC. No one nom Sixx D~ees Media was present at that int~ew, and no one

from Sixx Degrees Media had any involvement in the;recotding of that interv1ew ot any oftne

other attivities that underlie Mr. Peru.to's claims in this case.

l 0. IPC has not shated flny .recording from'Mr. Pentto' s interview witl:t Sixx Degrees

Media.

PUI'$uant to 2.8 U.S.C. § 1746, I declare unde e pemtlty of perjuey th.a~ the foregoing

statements are tnte and c6n:e¢t to the best of my , leclge, Wotmation, mid belief.

Dated: October 31, 2018

2


EXHIBIT

B



IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

A. CHARLES PERUTO, JR.,

Plaintiff,

vs.

SIXX DEGREES MEDIA; ROC NATION, LLC; AMAZON DIGITAL SERVICES, LLC; AMAZON PRIME VIDEO; AND THE IPC GROUP,

Defendants.

Civil Action No. 2: 18-04468

DECLARATION OF PATRICK REARDON

Patrick Reardon, of full age, hereby certifies and declares as follows based upon my own

personal information and knowledge:

1. I am the Executive Vice President, Television for Roe Nation, LLC ("Roe Nation").

2. I am authorized to execute this affidavit on behalf of Roe Nation and am fully

familiar with the facts stated herein.

3. In Paragraph 16 of the Complaint filed by Plaintiff A. Charles Peruto ("Plaintiff')

in this case, Plaintiff states, upon information and belief, that Sixx Degrees Media ("Sixx

Degrees") is working with Roe Nation, Amazon Alternative, LLC ("Amazon") (sued incorrectly

as "Amazon Prime Video and Amazon Digital Services, LLC") and IPC Television, LLC (sued

incorrectly as "The IPC Corporation") in the filming and production of a documentary series about

Robert Rihmeek Williams (professionally known as Meek Mill) (the "Documentary Series").

4. Roe Nation is producing the Documentary Series with IPC for broadcast and

distribution by Amazon.



5. In my role as Executive Vice President, I oversee the various creative and logistic

aspects relating to the production of the Documentary Series.

6. To the best of my knowledge, Sixx Degrees has no involvement, and has never had

any involvement, in the creation, filming, production or distribution of the Documentary Series.

7. To the best of my knowledge, Sixx Degrees has no involvement with and did not

participate in Plaintiffs interview during the filming of the Documentary Series.

8. Neither I nor, to the best of my knowledge, anyone at Roe Nation have provided

Sixx Degrees with a copy of the recording from Plaintiffs interview.

I hereby swear that the statements made by me herein are true and correct and I

acknowledge that I am subject to the penalties of perjury if any such statements made by me are

knowingly false.

Dated: October 31, 2018

- 2 -


EXHIBIT

c



A .. ~~ES P.ERUTO~ JR;, nj11.·; ·"1-:l'l' ,. _qJlJuu.~

BIX.X'DEGREES MlIDi.A; ROCNA'J'IONJ ~ LLC; .A~Z~N J?IGIT~ ~EJ:lv.t:~ES,,LLC; : AMAZ-ON l>IUME VIDEO; nnd THE IP.C : ~QUP, :

Defendants, . . .. ,

DECLARATION OF JOSH MlLLER

Ii Josh Miller; l)et~by decl~e~ \ltider pen~Uy ,Qf per}µry; a~ f6llq\Ys~

1.. .t E!tn. etnpfoylrd ns U:nsc_ripted Creative E~4Uti\1.e at Amazon .Ait~mative; LLC.

'2. Ania'Zon Alternative iS producht~ a doctinientar~T'S'erfes OU Meek:Mill wif)i IP<;

Tefevisiol\ LLC t"lPd1} ancT'.Roc blati¢n; LL~ (hereln~~~r, !p;: i"#FreeM®k DowptenJ~ry'?,

3. fa 1bls. ea~e; J>Jai.htiff A. '.Charle$ Peruro,.Jr, fo:rs llllltl.ed as ,d~fen.d.ants runllZotl

Prime Video llrtd Amazon D~gital Sef\r.ices> LLC; :Amazon Prime Video is hot a C:otp6tate.entftyi

and Amazon Digttal Serii<;:es i~ not jpyoW'e.c.i'in ijie production. of the #F.r~Meek~.oq,umtmtElty.

Only Atn.aZQtt.Alte,mative is involved itl the production.

4. Ainaio11 Altetnative,s.princwa~place,ofbusin.es~ is in Sarita Moni'Ga,

.Callfonti~. Its ~ole tnember is A.tl}azon Conteu~ Setvices.LLC, which has"'~Js pi:!n¢.pal pl~e o.f

·bus-foes'$ in S.eattle, Wa:sh'ing.ton. The ~61~ metftber of::Attutzon 'Cout~nt Setvlc:es .is Amazon.com

SerVices~ Inc.~ which is. a Delaware corporation with its: principal place .of business in the stat~ of



,§_, ~in~on Alferna!ivc,; is ·filliiticlilg i\n,d Wilt l?~ dieftrl\itJfi!\gtth~WFr~~ek

· llpc;Ame':lt~cy. Ain~i<m !Pt~~~n~li c~ti~~Jnpif.t~11d f§ ii1Vq]¥etj fo t® ~r.~ttfiv~

,deye(ppment bf the b~e11mentacy.

·6. In Jlly.io!e as.:Qp.scri~d .Greative .~eeU.tlv~~ tI;>~rsee tiier~~~'tfy~ t{eveJgpmenl ·

Pf.the ~Fie~e* Po9~~n1a~y'.Q~ lJ~h~lf qf ~zon (\.lft:waljvQ. t.~· litu!{~JJ . .¢\Jtefo~fiv~t

pflnci pat pn1nt ·ot'toi'.\~ct fqrajl '<lfe~iV:e aspects ottn.e ".E).o&Ufilepta,i'fJ;~tf¢1,t. as h'C)W'tQ tell:fff e; ~ .. . ..,

·~qty.i-Whaf ~cene$-~lo ·$h'doti. whc,\ t<,\.Wte:ryiew.s and.Wne~ int~t¥i~mlll ta}n~pface;

v. rral~ fa.~hm~~ <1;(p19~tdi11g:~lJ. P&<>QIW!i.® ~~iVfc~. f qrJli~·Pb.~ume!it~fy)

jrlcluain~ ~6 nlmfn!jindrl';~f~~g :afbll~cyiews~

~1 Atti?w11 k\lferµ~tiv,v lm~·hQ\rQr-en~~geq S)~i!f>~gt~~ Mcii.ia. B.ikt?vgre~s'

M~41& hlis'.tro r~~ :fn :ihe QlJtee1Yteek.'Do@:m1;tlwo/~iJbtl JJa.~nPt h~1t~11-volved ifl ~~ ;is~ct gr~~

ifF.teeMeekJJo~~lfilY .. l3~for~1e-arnin~ot~~ lawsuit~ 1 ha~ it6~'1r ~-e;p-d ut~~·~e,gr~~

'MeSffo.

ii. ~lj .~ ·6·~~ tl!llt1 ~<Jwl~Cft~ ih'~ Dti!y ~e.Q:Pl'.~i>,re~t qµrin~.tlw lllnlin~ran~

.re~rain~nf.Mi.PetuU>~sinfirv@w¢i:fYciy ~01 ~{Yf8_$~ p~p!e,etiga.g~gh,Y'iP.~ .. 'To(h.e-~~r •Qf:¢..Y·I¢<!\tled@;llJIt>~.fm.m S~P;e~ys'Me~Jr~Y~:Pt~ept attft~t ititetyrew;,.ati4ii¢'Q.rtb-

• • 4 *

•ftbtn s .. Vv 1:ecrrA&>$.il\ke({"0 li<l';r M'\t k.tx faf1'\l:t1~11f~ n fll~ i'~~"di11 1'tlif'f1:.itt> ·~i&iv'\13ttf'fl...,at1~1'.{ff,i'.t.e "" . . 104 Y,.,.ei.....,v. alA5. 1~ . H4. • 1 \U-¥ ~ . ,., • J • .... ~v,f · .~E>· . ~~...!- LU!> . )vr• NJ. ,,.., " tU c ' * ~ "' • "' .. I'

<?t.hef ?*iivttl~~ that:un~*rt1~ Mrt ~futQ'.~~.~~ tn.,fhis kl~~.

:igt th.avetr.m·~~tad5!PY te~ord.iQ~.frPtn Ml~ f:Cn!tif~ illff.~ittw with$i~»~e~~



Ptt~"ant to ~8 t);S.C. § 1746, 1 d~la_~un9er the penalty Qfp~tJtll'Y tbatthe fore-going

s.tatements ar.¢ ttUe A'ild c'5tte:cJ to the best bf my krmwlet1g~ in'fol!UatfonJ ~hd ~e1ittf..

o:a~d; bcto_ber 3 I ~ 20 i.8

3


Documents

PBT - Courthouse News Service€¦ · tm: beasley fntm, llc 1125 wainur sti!eft plllladf.iphla, pa 19107 215 592 1000 215 592. 8.360 (fax) 11. ~ in the united states district court