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Greene Broiilet & Wheeler, LLP

LAWYERS

(SPACE BELOW FOR FILING STAMP ONLY)

100 WILSHIRE BOULEVARD. SUITE 2t00

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P.O. BOX 21 31

SANTA MONICA. CALIFORNIA 90407-2(31 TEL (310) 576-1200 FAX. (310) 576-1220

Superior Court of California


County, ofLos Angeles

SCOTT H. CARR, State Bar No. 156664 CHRISTIAN T.F.NICKERSON, State Bar No. 281084

JAN 0 9 2014
Sherri R-Cai :ive Officer/Clerk
Deputy

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Attorneys for

Plaintiff

By.

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SUPERIOR COURT OF THE STATE OF CALIFORNIA


FOR THE COUNTY OF LOS ANGELES

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NATE BOLOTIN, an individual;


Plaintiff,
vs.

CASE NO.

BC53-2847

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COMPLAINT FOR DAMAGES


1. BREACH OF CONTRACT

THE JOHNSON-ROESSLER COMPANY, a California limited liability company; ACT 4


ENTERTAINMENT, LLC, a California limited

2. TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS


DEMAND FOR JURY TRIAL

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liability company, and DOES 1through 50,


inclusive,
Defendants.

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COMES NOW the Plaintiff, and for causes of against Defendants, and each of them,
alleges as follows:

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GENERAL ALLEGATIONS
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1. The true names and/or capacities, whether individual, plural, corporate,IJafjri&liip, 3 < 2? -TJ XI associate or otherwise, of Defendants, DOES 1through 50, inclusive, areluft?oia%"Piintiff : c? z x o .: .; ' '
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who therefore sues said Defendants by such fictitious names.


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2. The full extent of the facts linking such fictitiously sued Defendants with thecals!; of action alleged herein is unknown to Plaintiff. Plaintiff is informed and believes, and hereupon
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1C2C.01

Complaint for Damages

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alleges, that each ofthe Defendants designated herein as aDOE was and is negligently, or in some
other actionable manner, responsible for the events and happenings hereinafter referred to, and
thereby negligently, or in some other actionable manner, proximately caused the hereinafter
alleged injuries and damages to the Plaintiff. Plaintiff will hereafter seek leave of Court to amend

this Complaint to show the Defendants' true names and/or capacities after the same have been
ascertained.

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3. Plaintiff is informed and believes, and thereupon alleges, that at all times mentioned

herein, Defendants, and each ofthem, including DOES 1through 50, inclusive, and each ofthem, were the agents, servants, employees, and/or joint venturers oftheir co-Defendants, and were, as

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such, acting within the course, scope and authority of said agency, employment and/or joint
venture, and that each and every Defendant as aforesaid, when acting as a principal, was negligent in the selection and hiring ofeach and every other Defendant as an agent, employee, and/or joint
venturer, and that each Defendant, by and through its officers, directors and/or managing agents,
authorized, ratified and/or otherwise approved the acts of the remaining Defendants and/or said

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officers, directors, and/or managing agents participated in said acts by the Defendants, and each of
them.

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4. At all times mentioned herein, Plaintiff, NATE BOLOTIN, was and is an individual
residing in the Countyof Los Angeles, State of California.

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5. Plaintiff is informed and believes, and thereupon alleges, that at all times mentioned

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herein, Defendant THE JOHNSON-ROESSLER COMPANY ("JOHNSON-ROESSLER") was,


and now is, aCalifornia Limited Liability Company organized and existing under and by virtue of the laws ofthe State ofCalifornia, and that said defendant was, and now is, authorized to do, and

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is doing business in the State of California, and that said defendant has regularly conducted
business in the State of California, and that defendant's principal place of business is located
within the State of California.

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6. Plaintiff is informed and believes, and thereupon alleges, that at all times mentioned

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herein, Defendant ACT 4 ENTERTAINMENT, LLC ("ACT 4") was, and now is, a California
Limited Liability Company organized and existing under and by virtue of the laws of the State of -_2_Complaint for Damages"

1C2C.01

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California, and that said defendant was, and now is, authorized to do, and is doing business in the
State of California, and that said defendant has regularly conducted business in the State of California, and that defendant's principal place of business is located within the State of
California.

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7. Plaintiffis uncertain of the exact form of business entity under which DOES 1 through
50, inclusive conduct business, whether coiporate, partnership, proprietorship, association, or otherwise, and Plaintiff will seek leave of Court to amend the Complaint to state the exact form of
legal entity under which said Defendants do business when the same have been ascertained.
8. At all relevant times herein, Plaintiff NATE BOLOTIN was and is a creative artist and

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producer.

9. Plaintiff NATE BOLOTIN initially conceived the concept for the "American Psycho" musical (hereinafter referred to as the "PROJECT"). On or about June 1, 2007, Plaintiff pitched
the PROJECT to, and ultimately entered into an agreement to work on the PROJECT with, The

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Collective Management Group (hereinafter referred to as "The Collective"). After entering into this agreement, Plaintiff worked diligently to see the PROJECT come to fruition.
10. On or about June 3, 2008, Plaintiff entered into a separation agreement with The
Collective, whereby Plaintiff would receive seventy-five percent (75%) of all revenue derived from the Collective's interest in the PROJECT (hereinafter referred to as the "Separation

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Agreement"). Specifically, the Separation Agreement provided that: "Employee shall be entitled
to continue pursue (sic) the project currently entitled 'American Psycho' with no obligation to Company; provided that Employee shall pay to Company (or Company's designated entity) twenty-five percent. (25%) of one hundred percent (100%) of all amounts received by Employee

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(or his assignees, designees, or affiliated entity(ies)) arising in any way from the 'American
Psycho' project. Employee will pay all such amounts within five (5) business days after

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Employee's (or his assignee's, designee's, or affiliated entity's) receipt of each applicable

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payment of such amounts." Plaintiff continued to work diligently to see the PROJECT come to
fruition after the Separation Agreement was executed.

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1C2C.01

Complaint for Damages

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11. In or around June of2008, the relevant terms ofthe Separation Agreement were shared
with Defendants JOHNSON-ROESSLER, ACT 4, and Does I through 50, inclusive, and each of
them. Said Defendants acknowledged the terms ofthe Separation Agreement.

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12. In or around September 2008, The Collective entered into a partnership agreement with

Defendants JOHNSON-ROESSLER and ACT 4 with respect to the PROJECT (hereinafter


referred to as the "Partnership Agreement". See September 2008 Partnership Agreement attached
hereto as Exhibit 1). Plaintiff is informed and believes, and thereupon alleges, that at the time the
Partnership Agreement was entered into, Defendants JOHNSON-ROESSLER and ACT 4 were

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fully aware of the Separation Agreement that Plaintiff had with The Collective, and that Plaintiff

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was, and is, an intended and foreseeable third party beneficiary to the Partnership Agreement, and
entitled to 37.5% of the total income derived from the PROJECT.

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13. In reliance upon both the Partnership Agreement and Separation Agreement, Plaintiff

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continued to expend substantial time, effort and resources toward the development of the
PROJECT.

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14. Plaintiff is informed and believes, and thereupon alleges, that Defendants JOHNSONROESSLER and ACT 4, and DOES 1-50 inclusive, and each of them, have breached the
Partnership Agreement, and have deprived Plaintiff of his rights, as well as his interest in the
PROJECT.

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FIRST CAUSE OF ACTION

(Breach of Contract As AgainstDefendants, and Each of Them,

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Including DOES 1through 50, Inclusive, And Each ofThem)

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15. Plaintiff incorporates herein as though fully set forth at length all ofthe allegations and
statements contained in Paragraphs 1through 14, inclusive, ofthe General Allegations, above.
16. At all times mentioned herein, Defendants JOHNSON-ROESSLER and ACT 4 had a

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valid and enforceable contract with The Collective with respect to the PROJECT (the Partnership
Agreement), and Plaintiff NATE BOLOTIN, was an intended and foreseeable third party
beneficiary of the Partnership Agreement.

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1C2C.01

Complaint for Damages

17. At all times mentioned herein, Plaintiff had a valid and enforceable contract with The

Collective with respect to the PROJECT (the Separation Agreement), and Defendants JOHNSONROESSLER, ACT 4, and DOES I through 50, inclusive, and each of them, were aware of the
relevant terms of such agreement.
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18. Pursuant to the terms of the Separation Agreement, and with knowledge by
Defendants, and each of them, Plaintiff was a person who was directly affected by the contractual
relationship between The Collective and Defendants JOHNSON-ROESSLER, ACT4, and DOES

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1 through 50, inclusive, and each of them. Plaintiff was therefore a foreseeable third party
beneficiary of the Partnership Agreement between The Collective and Defendants JOHNSONROESSLER and ACT 4.

19. Inherent in all contracts, and implied therein is a covenant of good faith and fair

dealing which required that Defendants JOHNSON-ROESSLER, ACT 4, and DOES 1 through 50
inclusive, and each of them, refrain from doing anything that would injure the rights of the Plaintiff to receive the benefits from the PROJECT, render the performance of the Separation
Agreement by Plaintiff impossible, or otherwise invade the Plaintiffs rights. The covenant further

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required the Defendants to refrain from needless injury or damage toward Plaintiff, and to act at
all times in good faith.

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20. On or about August 16, 2012, Defendants JOHNSON-ROESSLER, ACT 4, and DOES

1 through 50, inclusive, and each of them, breached the Partnership Agreement, and violated the

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implied covenant of good faith and fair dealing contained therein by depriving Plaintiff of his
rights, as well as his interest in the PROJECT;

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21. Plaintiffhas duly performed all of the terms, conditions and covenants required to be
performed by him in accordance widi the contract identified herein.
22. As a direct legal and proximate result of this breach of contract and breach of the

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implied covenant of good faith and fair dealing by Defendants, and each of them, Plaintiff has

sustained general and special damages, including consequential damages, according to proofto be
determined at the time of trial.

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51C2C.01

Complaint for Damages

SECOND CAUSE OF ACTION

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(Tortious Interference with Contractual Relations As Against All Defendants, and


Each of Them, Including DOES 1 through 50, Inclusive, and Each of Them.) 23. Plaintiff incorporates herein as though fully set forth at length all of the allegations and

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statements contained in Paragraphs I through 14, inclusive, of the General Allegations and Paragraphs 15 through 22 of the First Cause of Action, above.
24, As of June 3, 2008, and at all times mentioned herein, Plaintiff had a valid and

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enforceable contract with The Collective with respect to the PROJECT (the Separation
Agreement).

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Defendants JOHNSON-ROESSLER, ACT 4, and DOES 1 through 50, inclusive, and

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each of them, at all relevant times herein, had knowledge of the existence of the valid and
enforceable contract between the Plaintiff and The Collective, and the relevant terms therein.

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Defendants JOHNSON-ROESSLER, ACT 4, and DOES 1 through 50, inclusive, and

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each of them intentionally and wrongfully shut Plaintiff and the Collective out of the PROJECT

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by improperly declaring breach of the Partnership Agreement without any justifiable basis for
doing so.

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27. As a direct and proximate result of the conduct of Defendants, and each of them, Plaintiff has been deprived of his rights, as well as his interest in the PROJECT.
28. Defendants, and each of them, had no justification for their intentional interference

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with Plaintiffs contractual relationship between Plaintiff and The Collective.


29. Plaintiff is informed and believes, and thereupon alleges, that as a direct and proximate result of the aforementioned acts of Defendants, and each of them, Plaintiff has suffered general

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and special damages in an amount according to proof, in an amount in excess of the jurisdictional
limits of this Court.

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1C2C.01

Complaint for Damages

PRAYER FOR RELIEF


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WHEREFORE, Plaintiff prays judgment against the Defendants, and each of them, as
follows:

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1. For special damages, according to proof;

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2. For general damages, according to proof and within the jurisdictional limits of this
Court;

3. For loss ofearnings and earning capacity, according to proof;

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4. For damages for breach of contract, including consequential damages, according to


proof;

5. For damages for Plaintiffs other economic losses, according to proof;


6. For costs of suit incurred herein:

7. Forprejudgment interest, according to proof; 8. For post-judgment interest, according to proof;


9. For attorneys fees; and

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10. For such other and further relief as this Court may deem just and proper.
DATED: January 6,2014

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GREENE BROILLET & WHEELER, LLP

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Scbtt If.jCarr,' sq-7 fOC^ ChKstikn T.F. NicUgbon, Esq.


Attorneys for Plaintiff

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71C2C.01

Complaint for Damages

DEMAND FOR JURY TRIAL

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Plaintiff NATE BOLOTIN hereby demands a jurytrial on all causes ofaction.

DATED: January 6,2014

GREENE BROILLET & WHEELER, LLP

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f<#-ChristiM T.F'. Nick4son, Esq.


Attorneys for Plaintiff

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81C2C.01

Complaint for Damages

EXHIBIT 1

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AMERICAN PSYCHO: THE MUSICAL - PARTNERSHIP AGREEMENT

The following agreement ("Agreement") is entered into as of September

, 2008

between The Collective Management Group, LLC ("TC") and The Johnson Roessler Company,

LLC ("JRC") (TC and JRC will collectively be referred to herein as the "Parties") in connection

with a partnership agreement between the Parties hereto with respect to the development and production of an on-stage musical based upon the novel entitled American Psycho written by
Bret Easton Ellis (the "Novel").
1. DEFINITIONS.

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Musical. As used herein, the term "Musical" shall mean the first dramatic stage

production based in whole or in part upon the Novel.


1.2. Property. As used herein, the term "Property" shall mean and include all of the

following: (!) the Novel; (ii) the book of the Musical ("Book"); (iii) any literary, dramatic and
other material based on the Book or derived from the Book; (iv) any literary, dramatic and other material on which the Book is based or derived, whether oral, written or otherwise; (v) the plot, scenes, titles, characters, characterizations and translations and any and all other parts, elements

or versions of any and allof the foregoing; (vi) all musical elements prepared inconnection with the Musical, including without limitation all original music, songs, lyrics, scores, manuscripts, instrumental and vocal parts and other music and any and all otherparts, elements or versions of

any and all of the foregoing; and (vi) any and all present and future copyrights in and to the foregoing, including, but not limited to, any renewals, extensions or reversions thereof now or
hereafter provided.
2. DEVELOPMENT OF MUSICAL.

2.1. JRC will invest up to $150,000 ("Initial Development Investment") in connection with thecosts of development of the Musical, including but not limited to the costs of acquiring

an option ("Option") to the rights necessary to exploit the Novel as a dramatic stage production ("Stage Rights"), legal fees incurred in connection with the development of the Property and/or
Musical, and the costs of hiring a writer to write the Book and a lyricist and composer to create
the musical elements for the Musical.

2.2.

TC shall use its reasonable best efforts to provide and perform all services and

acts necessary to assist in the development and production of the Musical as set forth herein

including, but not limited to: (a) targeting appropriate directors, lyricists, composers and writers to adapt the material into the Book, (b) requesting potential lyricists and composers to write songs on spec to gauge their understanding of the concept, (c) obtaining world-wide options for songs across various/unlimited territories, (d) identifying a suitable general manager to produce a budget based on the mutually approved Musical concept, (e) producing a table read or workshop, (f) securing additional financing required to develop and the Musical.
2.3. TC shall have the exclusive right (in addition to the right of JRC itself) to shop the

Property and/or Musical to third parties ("Third Party Financiers") in an effort to finance the development and production of the Musical upon a plan pre-approved by and acceptable to JRC
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(such approval/acceptance not tobe unreasonably withheld). Such exclusive shopping right shall
extend from the date hereof and continue for a period of one year after the completion of the Book (the"Shopping Period").

2.4. All decisions with respect to the Property and Musical, including without limitation all decisions concerning the Book and/or the Option, in whole or in part, will be made

jointly by TC and JRC, with JRC having the tie-breaking vote in the event of a disagreement.
2.5. JRC shall own all rights to the Property, the Musical and the Option, each of which shall be held in JRC's name and any rights in connection with the development of the

Musical not owned by the writer of the Book, the lyricist or the composer, shall be owned by JRC. Once a Financing Agreement is secured that provides for 100% of financing for the

production of the Musical, TC shall become vested in a right to share equally with JRC in all
revenue and receipts derived from the exploitation of the Musical (subject to JRC's right of
recoupment as set forth in 4.1 below).
3. EXPIRATION OF SHOPPING PERIOD. Upon expiration of the Shopping Period, in

the event a Financing Agreement has not been secured, all rights granted to TC herein in connection with the Property and/or Musical shall terminate, and TC shall have no further rights
or interest in and to the Property or the Musical.
4. ALLOCATION OF INCOME.

4.1. Recoupment of Development Expenses. JRC, and any other parties who invest in the development of the Property and/or the Musical shall recoup their investments, with interest
thereon at the rate of one hundred twenty percent (120%).

4.1.1. From the production budget of the Musical, to the extent such development expenses are recoupable from such budget;
4.1.2. To the extent such costs are not recoupable from the production budget,

such development costs shall be recouped from revenues received from exploitation of the Musical, subject to negotiation with theThird Party Financiers.
4-2. Payment of Profits to JRC/TC. In the event the Musical is produced, any and all

compensation, credits, profits or other remuneration or income derived from the exploitation
and/or sale of the Musical that becomes payable to JRC and/or TC shall be shared equally by

them, subject to recoupment by both parties of any amounts that have not been recouped above
pursuant to Section 4. i.

5CREDITS. Any and all credits to be accorded to IRC and its principals and employees and TC and its principals, employees and affiliates (and Nate Bolotin), shall be negotiated in
good faith.

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DERIVATIVE WORKS. If the Musical is produced, TC shall have the right to share

equally with JRC in all revenue and receipts resulting from all subsequent productions (spin-offs,
sequels, traveling productions, etc.) related to or derived from the Musical.

7. KEY MAN CLAUSE. If Aaron Ray ceases to be a partner of TC or ceases to be actively involved in the development of the Property and/or the Musical, JRC may, in its sole discretion, terminate this Agreement by providing written notice to TC.
8. TERMINATION. If TC fails to utilize its reasonable best efforts to fulfill its obligations

hereunder or fails to comply with any of the material terms or material conditions of this Agreement or any other agreement between JRC and TC, JRC shall have the right to terminate this Agreement upon written notice to TC.
9NOTICES. Until further notice, the addresses of the Parties shall be as follows:
9.1. ForTC:

9.2.

For JRC:

The Johnson Roessler Company

3000 W. Olympic Blvd., Suite 2311


Santa Monica, CA 90404
Attn: David Johnson

Jesse Singer
9.3. With a copy to: Reder & Feig, LLP 421 South Beverly Drive, Eighth Floor Beverly Hills, California 90212 Telecopier: (310)789-4771 Attn: Benjamin R. Reder, Esq. Michael J. Castrillo, Esq,

10. APPLICABLE LAW. This Agreement will be construed and enforced in accordance with the internal law of the State of California applicable to contracts negotiated, signed, and

fully performed within that State, regardless of where negotiation, signature, or performance of this Agreement may actually occur and subject to the exclusive jurisdiction of the courts of the
State of California.

11. ARBITRATION. Any controversy or claim arising out of this Agreement, or the breach hereof, shall be settled by arbitration in accordance with the rules of the American Arbitration Association ("AAA"). Said arbitration shall be held before a single arbitrator, who is mutually

agreed upon by the parties within (10) business days following receipt by one party hereto of
notice from the other requesting arbitration. If the parties are unable to select a mutually

acceptable arbitrator, then such arbitrator shall be appointed by application to AAA. The
determination of the arbitrator shall be final, binding and conclusive upon the parties hereto. The

prevailing party in any such arbitration shall be entitled to recover its reasonable attorney's fees and costs. The parties hereto agree that any and all disputes hereunder shall be exclusivity resolved through the arbitration procedure set forth herein and judgment thereon may be entered in the highestcourt of the forum, state or federal, havingjurisdiction thereof.
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12.

MISCELLANEOUS.

12.1. No Right To Injunctive Relief: In the event of any breach of this Agreement by

JRC, TC will not be entitled to restrain, enjoin orotherwise impair the development, production,
distribution, marketing or other exploitation of the Property or Musical or any rights in the

Property or Musical. It is expressly agreed that TC's sole remedy in the event ofJRC's breach
of this Agreement shall be an action at law for damages. 12.2. Assignment: Neither party may assign its obligations and rights under this

Agreement without the prior written approval of the other party.


12.3. Indemnification. Each party represents and warrants that it has the right, power

and authority to enter into this Agreement. The parties agree to indemnify and hold each other harmless from and against any claim, loss, damage, cost and expense (including attorneys' fees)
suffered as a result of theother party's breach of any provision of this Agreement. 13, ENTIRE AGREEMENT. The terms and conditions described herein may be set forth in

longer form agreements, which incorporate customary representations, warranties, covenants and
conditions common in the entertainment industry applicable to the services of producers and the

financing of entertainment endeavors, and subject to any changes which are mutually agreed upon after good faith negotiations. Unless and until more formal agreements are executed such
terms and conditions shall be deemed incorporated herein, this Agreement shall constitute a

binding agreement between the parties, superseding and replacing all prior oral or written understandings with regard to the subject matter hereof. No provision hereof may be waived or
amended except by a written instrument executed by the party to be charged.

IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed as of
the date first written above.

THE JOHNSON ROESSLER COMPANY, LLC

By:

(Print Name)
Its:

THE COLLECTIVE MANAGEMENT GROUP, LLC By:


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(Print Name)
Its:

This amendment dated as of July

, 2011 (the "Amendment") shatl constitute the

first amendment to the partnership agreement dated as of September , 2008 (the "Partnership Agreement") by and between The Collective Management Group, LLC ("TC")
and Act 4 Entertainment, LLC (formerly known as The Johnson-Roessler Company, LLC)
("JRC").

WHEREAS, TC and JRC entered into the Partnership Agreement with respect to the

development and production of a new stage musical (the "Musical") based on the novel
"American Psycho" by Bret Easton Ellis; and

WHEREAS, TC and JRC now wish to modify the terms and conditions of the
Partnership Agreement;

NOW, THEREFORE, the parties hereby agree to the following modifications to the
Partnership Agreement:
1. Financing Adjustments.

1.1

Pursuant to Paragraph 2.1 of the Partnership Agreement, JRC is

contractually responsible for contributing the first One Hundred Fifty Thousand Dollars ($150,000) offunding (the "Initial Development Investment") in connection with the costs of development of the Musical. The parties mutually acknowledge JRC's satisfaction of such
obligation.

1.2

The parties mutually agree that, notwithstanding any language to the

contrary set forth in the Partnership Agreement, JRC will be responsible for contributing additional development funds up to a maximum of Two Hundred Fifty Thousand Dollars ($250,000 which amount, for the avoidance of doubt, is inclusive of the Initial Development
Investment). Such additional development funds in excess of the Initial Development Investment
are referred to herein as the "Additional Development Investment."

1.3 JRC shall be entitled to recoup the Additional Development Investment in the same manner as the Initial Development Investment pursuant to Paragraph 4.1 of the

Partnership Agreement. That is, JRC shall be entitled to recoup one hundred twenty percent (120%) of the aggregate Initial Development and Additional Development Investment as follows: (i) at the election ofJRC, from the production budget ofthe Musical, to the extent such

expenses are recoupable from such budget; and (ii) to the extent such costs are not recoupable
from the production budget, such expenses shall be recouped from all revenues (including
without limitation, royalties, cash office charges, executive producer fees, net profits, etc.)

derived from exploitation of the Musical, subject to good faith negotiations with third party
financiers. To the extent that IRC elects option (ii) above, it shall be entitled to negotiate in good

faith with third party financiers the terms ofits investment in the production without obligation
to TC.

2.

Recalculation of Producer Net Profits. In consideration of JRC's committing to

additional funding in excess of the Initial Development Investment, the parties agree that the allocation of net profits as set forth in Paragraph 4.2 of the Partnership Agreement shall be

adjusted as follows: (i) JRC shall be entitled to eighty percent (80%) of any and all

compensation, credits, profits or other remuneration or income derived as producers from the exploitation and/or sale of the Musical that becomes payable to JRC and/or TC, subject to recoupment of any amounts unrecouped in accordance with Paragraph 1above; and (ii) TC shall

JRC of any amounts unrecouped in accordance with Paragraph 1above. Paragraph 6 shall be
amended so that JRC and TC share at a ratio of eighty percent (80%) to twenty percent (20%),
respectively.

be entitled to the remaining twenty percent (20%) ofany such amounts, subject to recoupment by

Partnership Agreement, notices to JRC shall be sent to Act 4 Entertaimnent, 1323 Ocean
Avenue, Santa Monica, CA 90401, Attn.: David Johnson and Jesse Singer.

3.

Notices. Anything to the contrary notwithstanding in Paragraph 9.1 of the

In all other respects, the terms and conditions set forth in the Partnership Agreement shall
continue to govern therelationship of the parties.

IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be


executed as of the date first written above.

ACT 4 ENTERTAINMENT. LLC

THE COLLECTIVE MANAGEMENT


GROUP, LLC

By:

Print Name: Its:

By;

Print Name: Its:-

CM-010
ATTORNEY ORPARTY WITHOUT ATTORNEY (Hume. Stale8arnumber, and address):
FOR COURT USE ONLY

Scott H. Carr, Esq. (SBN 156664)


GREENE BROILLET &WHEELER, LLP 100 Wilshire Boulevard, 21st Floor Santa Monica, California 90401

telephone*), (310) 576-1200


street address: 111 North Hill Street
mailing address. Same as Above

fAXNo.; (310) 576-1220

Superior Court of California


County, of Los Angeles

attorney for yam): Plaintiff, NATE BOLOTIN SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

JAN 0 9 2014
Sherri R. Ca :iveOfficer/Clerk
Deputy

cityand zip code. Los Angeles 90012


branch name: Central District

case name: BOLOTIN v. THE JOHNSON-ROESSLER COMPANY, et al.


CIVIL CASE COVER SHEET

BC532847
CASE NUMBER:

Complex Case Designation

_3

Unlimited
(Amount
demanded

D Limited
(Amount
demanded is

Counter

Joinder

^ e^u
_

Filed with first appearance by defendant


(Cat. Rules of Court, rule 3.4021

exceeds $25,000)

$25,000 or less)

Items 1-6 below must be completed (see inslmctions on page 2). 1. Checkone boxbelow for the case type that best describesmiscase:
Auto Tort Contract

f_] Q
__

Auto (22) Uninsured motorisl (46) Asbestos (04) Product liability (24)
Medicalmalpractice (45)

_J

Breach ofcontract/warranty (06)

Provisionally Complex CMI Litigation (Cal. Rules of Court, rules 3.400-3.403)

Q
_]

Rule 3.740 collections (09)


Other collections (09) Insurance coverage (18)

Other PI/PD/WO(Personal Injury/Property

Damage/Wrongful Death) Tort

_j

Antitrust/Trade regulation (03)


Construction defect (10)

Q
[_
(_

Other contract (37)


Eminent domain/Inverse
condemnation (14)

Real Property

Mass tort (40) Securities litigation (28) Environmental/Toxic tort (30)

Q D

Other PI/PD/WD (23)


Civil rights (08)
Defamation (13)

Non-PI/PD/WO (Other) Tort

Wrongful eviction (33)

Insurance coverage claims arising from the above listed provisionallycomplex case types (41)
Enforcement of Judgment

Business tort/unfair business practice (07)


Q
_| Q

Other real property (26)


Commercial (31)

Unlawful Oetainer

_l
[_ [_

Enforcement ofjudgment (20)


RICO (27) Other complaint (not specified abova) (42)

Miscellaneous Civil Complaint

D Fraud (16) Intellectual property (19) a Professional negligence (25) D Other non-PI/PO/WD tort (35) Employment
Q P
WS3S_

Residential (32)
Orugs (38) Asset forfeiture (05) Petition re: arbitration award (11) Writ ofmandate (02) Other judicial review (39)

Judicial Review

Miscellaneous Civil Petition

Partnership and corporate, governance (21) Other petition (not specified above) (43)

2.

This case O is
b

Wrongful termination (36) Other employment (15)_

_| is not" complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
d. U Large number of witnesses

factors requiring exceptional judicial management:

a D Large number of separately represented parties

3. Remedies sought (check all that apply): a. |_ monetary b. nonmonetary: declaratory or injunctive relief
4. Number ofcauses of action (specify): Two (2) 5. Thiscase Q is __ is not a class action suit.

c.

Extensive motion practice raising difficult or novel e. D Coordination with related actions pending in one or more courts issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court Substantial amount of documentary evidence f. Substantia! postjudgment judicial supervision

c. Q punitive

Q, If there are any known related cases, file and serve a notice of related case. (You may
-tale: Januarys, 2014 , Scott H. Carr, Esq. (SBN 156664)
(TYPEOR PRINTNAME)

NOTICE

. Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
File this cover sheetinaddition to anycover sheetrequired bylocal court rule.
in sanctions.

underThe Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure (o file may result

. If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve acopy of this cover sheet on all other parties to the action or proceeding. . . . Unless this is acollections case under rule 3.740 or acomplex case, this cover sheet will be used for statistical purposes only. ^i^
Judicial Council oi Csetomi

"torm Adopted (or MandataryUse CM-010[Rav, July 1.2007)

CIVIL CASE COVER SHEET

Cal. Rutesof Court,rules 2.30. 3.220. 3.400-3.403.3.740;


Cal. Standards of Judicial Administration,6td. 3.10
iMMv.courfirtro.ca.0ov