1s
16
"
18
19
20
au
Devin A. McRae, SBN 223239 CONFORMED COPY
dmerae@earlysullivan.com org QGRAL FINED
Peter D. Scott, SBN 247786 Pa EE
pscott@earlysullivan.com wnac
EARLY SULLIVAN WRIGHT AUG 192015
GIZER & MCRAE LLP
6420 Wilshire Boulevard, 17" Floor Sherri R. Carter, Executive Oficer/Clerk|
Los Angeles, California 90048 By: Shaunya Bolden, Deputy
Telephone: (323) 301-4660
Facsimile: (323) 301-4676
Attomeys for Plaintiff
SHANNEN DOHERTY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES — CENTRAL DISTRICT
caseNo,__BC5 91881
SHANNEN DOHERTY, an individual, |
Plaintiff, | COMPLAINT FOR DAMAGES FOR:
|
v, 1) BREACH OF CONTRACT;
TANNER MAINSTAIN GLYNN & 2) BREACH OF THE IMPLIED
JOHNSON, LLP, a California limited COVENANT OF GOOD FAITH
liability partnership; AND FAIR DEALING;
STEVEN D. BLATT, an individual; and
DOES | through 20, inclusive, 3) | BREACH OF FIDUCIARY DUTY;
Defendants. 4) CONVERSION;
5) NEGLIGENCE;
6) VIOLATION OF CALIFORNIA
BUSINESS & PROFESSIONS
CODE §§ 17200 ET SEQ;
2
e r CONTRACTUAL INDEMNITY;
8) EQUITABLE INDEMNITY;
Py
9) ACCOUNTING
25
6 —_ [DEMAND FOR JURY TRIAL]
n
EARLY =
= | sutuan
= | trier
COMPLAINT FOR DAMAGES
| Guere
WHEM | fAcRAE we
87570310
u
2
13
4
1s
16
0
18
19
20
au
2
23
4
28
26
27
28
EAR
| SULLIVAN
Plaintiff SHANNEN DOHERTY hereby alleges as follows:
INTRODUCTION
1. This is a case about crooked business managers who not only stole from their clients
but habitually blundered the most critical tasks of the profession. Defendant Tanner Mainstain
|Glynn & Johnson, LLP (“Tanner Mainstain”), before it terminated now disgraced original name
partner, Defendant Steven D. Blatt (“Blatt”), was formerly known as, Tanner Mainstain Blatt Glyna
|& Johnson, LLP. Tanner Mainstain’s promotional materials specifically target clients in the
entertainment industry, tellitig prospective clients they will “enjoy the confidence, convenience and
[continuity of having all of their financial matters handled in one place.” They offer “experience,”
commitment,” “professionalism,” “stability,” “confidentiality” and “peace of mind” — and a
specialization in the entertainment and professional sports industries that allows the firm to turn the
“unpredictable income” and “complex tax issues” in these industries into “a lifetime of financial
security” by virtue of skilled “careful planning, guided by knowledge and experience.” Blatt, now
]with the financial firm of Squar Milner, similarly promotes his specialization in serving “the needs
lof professional athletes, actors and high net worth individuals.” He too understands the “unique
challenges faced by entertainment and sports industries,” and develops “strategic plans” to help
clients “meet their short and long term financial goals.”
2. Intruth, the firm and former partner Blatt specialize in fleecing actors and
entertainment industry professionals. After gaining control of all of their clients’ cash and assets,
they find a way to lose it, sometimes by gross incompetence, sometimes by self-dealing and
outright theft. Along the way, they habitually deceive their clients, going so far as to set up bogus
transactions, to conceal their misdeeds, errors and omissions. ‘The firm has hallmarks of a Ponzi
scheme.
Rather than a “lifetime of financial security,” clients leave Tanner Mainstain and
Blatt (jointly, “Defendants”) with promises broken, tax liens and related penalties, debt they never
needed, depressed credit scores, and with the ultimate question: Where did my money go?
4, Plaintiff Shannen Doherty (“Plaintiff”), a successful, well-known actress, is one of
these victims who, by this Complaint, seeks redress for the actionable conduct and resultant harm
1 —
‘COMPLAINT FOR DAMAGES wanes4
15
16
W
18
19
20
2
23
“4
28
26
caused by what should have been, according to Tanner Mainstain’s website, her “most trusted
advisor.”
PART
5. Plaintiffs, and at all relevant times hereto was, a resident of the County of Los
Angeles, State of California,
6 Tanner Mainstain is a California limited liability partnership with its principal place
of business at 10866 Wilshire Boulevard 10th Floor, Los Angeles, California 90024-4300,
7. Blatt is, and at all relevant times hereto was, a resident of the County of Los
‘Angeles.
8. Plaintiff is ignorant of the true names and capacities of defendants named herein as
Does | through 20, inclusive. Plaintiff is informed and believes, and thereon alleges that Does 1
through 20 are liable, in whole or in part, for the claims asserted in this Complaint against the
Defendants. When Plaintiff learns the true identities and capacities of Does 1 through 20, Plaintiff
Will seek leave of the Court to amend this Complaint to allege the true names and capacities of
Does | through 20,
9. Plaintiff is informed and believes, and thereon alleges, that at all relevant times, each|
defendant was the principal, agent, or employee of each other defendant, and acted within the scope
lof that relationship.
JURISDICTION AND VENUE.
10. This Court has jurisdiction over this dispute and over all causes of action asserted
herein pursuant to the California Constitution, Article VI, §10. The amount in controversy,
exclusive of interests and costs, exceeds the jurisdictional minimum of this Court. This case
involves California residents that conduct substantial operations in this jurisdiction, Each defendan
resides in California and has sufficient contacts with Califomia to make proper the exercise of
personal jurisdiction over them.
11, Venue is proper in this Court. A substantial part ofthe acts or omissions giving rise
{0 the claims alleged occurred in Los Angeles, California, and each defendant resides within the
|County of Los Angeles such that this Court is the appropriate venue for this action,
COMPLAINT FOR DAMAGES
97570310
u
12
13
4
15
16
7
18
19
20
aa
2
2B
FACTUAL ALL
ATIONS,
12. On July 30, 2009, Plaintiff and certain of her related entities, on the one hand, and
‘Tanner Mainstain, on the other hand, entered into a written agreement (the “Agreement”) for the
[provision of accounting, business management, tax, payroll, insurance and investment services. A
true and correct copy of the Agreement is attached hereto as Exhibit 1, Under the Agreement, Blatt
}was to be principally responsible for coordinating and managing all of the services Tanner
/Mainstain was required to perform. In consideration of 5% of the income received by Plaintiff for
her professional services, Tanner Mainstain essentially assumed exclusive control and
responsibility for the management of all of Plaintiff's financial affairs, including the payment of
Plaintiff's medical insurance premiums.
13. Plaintiff had previously obtained medical insurance coverage through the Screen
[Actors Guild (“SAG”) medical insurance program. Tanner Mainstain, as Plaintiff's business
‘managers, took responsibility for timely payment of Plaintiff's medical insurance premiums
Indeed, the medical insurance invoices for Plaintiff were sent by SAG directly to Tanner
/Mainstain’s offices for payment. In November 2013, SAG sent the premium invoice to Tanner
/Mainstain for Plaintiff's medical insurance coverage for the year 2014, However, Defendants
ignored it, failed to pay it (without informing Plaintiff) and then promptly terminated their
relationship with Plaintiff effective February 7, 2014. Plaintiff assumed that the medical insurance
premiums had been properly paid as Defendants were still responsible for paying them during the
relevant time period. Unbeknownst to Plaintiff at the time, Defendants had not paid the required
premiums and Plaintiff was left completely uninsured.
14, Plaintiff subsequently discovered that Defendants had failed to pay her insurance
premiums and that she was uninsured until the next SAG insurance re-enrollment period for 2015.
Pr
2s
26
a
EARLY ae
| suiuvan
mc
ene
OGM | FecRae uu»
Accordingly, during 2014, Plaintiff did not have medical insurance, and thus did not regularly visit
a doctor as she normally would have had she been insured.
15. After re-enrolling in the SAG medical insurance program for 2015, Plaintiff began tol
regularly see medical professionals. In this regard, in March 2015, Plaintiff discovered that she had|
invasive breast cancer metastatic to at least one lymph node. Plaintiff was informed that her cancer
3
‘COMPLAINT FOR DAMAGES
375703