This complaint alleges breach of contract against Michael Jackson, MJJ Productions, Dileo Entertainment, Frank Dileo, Anshutz Entertainment Group, AEG Live, and AEG Live NY. It summarizes that the plaintiff, AllGood Entertainment, entered into agreements with the Dileo defendants to exclusively promote and produce a Jackson family reunion concert, but that the defendants breached the agreements by partnering with AEG to produce concerts in London instead. The complaint seeks damages for expenses incurred by AllGood in reliance on the agreements.
Fisker's lawsuit against insurance companykatiefehren
A lawsuit filed by Fisker against insurance company XL for denying its claim when 338 Karmas were lost in Sandy flooding, which had a value of $33 million.
Complaint for breach of contract, constructive fraud, constructive trust and unfair business practices against Joshua Macciello, self-pronounced bidder for the Dodgers and alleged film producer. Anyone with knowledge of Mr. Macciello's whereabouts, or who "invested" or "lent" money to Mr. Macciello, please contact CharismaticScam@gmail.com
Fisker's lawsuit against insurance companykatiefehren
A lawsuit filed by Fisker against insurance company XL for denying its claim when 338 Karmas were lost in Sandy flooding, which had a value of $33 million.
Complaint for breach of contract, constructive fraud, constructive trust and unfair business practices against Joshua Macciello, self-pronounced bidder for the Dodgers and alleged film producer. Anyone with knowledge of Mr. Macciello's whereabouts, or who "invested" or "lent" money to Mr. Macciello, please contact CharismaticScam@gmail.com
WATERSHED: Trillion-Dollar Lawsuit Could End Financial TyrannyZurich Files
WATERSHED: Trillion-Dollar Lawsuit Could End Financial Tyranny -- lawsuit against UN, OITC, WEF, Italian Republic and related parties. Keenan complaint, 2011-Nov-23. Also headlined as: "CONFIRMED: The Trillion-Dollar Lawsuit That Could End Financial Tyranny".
LENOX FINANCIAL vs. THE MORTGAGE INSIDER MEDIA, LLC and ROB K. BLAKE and TERR...Lenox Financial
Complaint filed by LENOX FINANCIAL vs. THE MORTGAGE INSIDER MEDIA, LLC and ROB K. BLAKE and TERRI EWING personally -- Filed August 4, 2010 in the Georgia Northern District Court -- Nature of Suit: Intellectual Property - Trademark -- Jury trial demanded.
AMENDED Lawsuit Against JustMugshots.com, MugshotsOnline.com and BustedMugsho...Mugshot Removal
Lawsuit involving Arthur D'Antonio (owner of JustMugshots.com and Mugshots.mobi) and Citizens Information Association, LLC, (owner of BustedMugshots.com and MugshotsOnline.com). Class action lawsuit against mugshot websites involving over 250,000 individuals. Official Action of violation of Ohio's Right of Publicity statute.
Roger Woods and Joy Clemente jocelyn woods AZonedivinemind
Roger Woods and Joy Clemente jocelyn woods jocelyn clemente jocelyn deal cruz urban crib design llc lio cåollection llc charnel dela cruz etc are con artists. they prey on people by creating false hope about creating large amounts of capital to fund and "fix credit" and by taking money from you and off of your credit cards.
Using an old fashioned bank Scam, They have successfully stolen numerous dollars from people, with no current capability to repay by claiming that they can fix other peoples credit and then raise more money into their names eventually investing the money in a variety of vague and risky investments.
An update on the effort in New York State to get shale drilling legalized--issued by the Joint Landowners Coalition of New York (JLCNY). This June 2013 newsletter provides a quick legislative update, a review of a recent seminar held in Albany, FrackNation screening update, and most importantly, an update on the lawsuit being undertaken by the JLCNY to force New York to compensate landowners if they will not allow drilling--a legal concept called "takings".
Wanna be startin somethin, mj in the scholarly literature, a selected bibliog...Brandon Penny
Two librarians at Texas Tech University have released a report detailing Michael Jackson's broad influence in the scholarly community. Associate Librarians Susan Hidalgo and Rob Weiner combed through scholarly papers and peer-reviewed articles in over 100 databases in creating "Wanna Be Startin' Somethin': MJ in the Scholarly Literature: A Selected Bibliographic Guide"
The guide shows Jackson popping up in psychology, medical, chemistry, mass communications and even engineering journals.
WATERSHED: Trillion-Dollar Lawsuit Could End Financial TyrannyZurich Files
WATERSHED: Trillion-Dollar Lawsuit Could End Financial Tyranny -- lawsuit against UN, OITC, WEF, Italian Republic and related parties. Keenan complaint, 2011-Nov-23. Also headlined as: "CONFIRMED: The Trillion-Dollar Lawsuit That Could End Financial Tyranny".
LENOX FINANCIAL vs. THE MORTGAGE INSIDER MEDIA, LLC and ROB K. BLAKE and TERR...Lenox Financial
Complaint filed by LENOX FINANCIAL vs. THE MORTGAGE INSIDER MEDIA, LLC and ROB K. BLAKE and TERRI EWING personally -- Filed August 4, 2010 in the Georgia Northern District Court -- Nature of Suit: Intellectual Property - Trademark -- Jury trial demanded.
AMENDED Lawsuit Against JustMugshots.com, MugshotsOnline.com and BustedMugsho...Mugshot Removal
Lawsuit involving Arthur D'Antonio (owner of JustMugshots.com and Mugshots.mobi) and Citizens Information Association, LLC, (owner of BustedMugshots.com and MugshotsOnline.com). Class action lawsuit against mugshot websites involving over 250,000 individuals. Official Action of violation of Ohio's Right of Publicity statute.
Roger Woods and Joy Clemente jocelyn woods AZonedivinemind
Roger Woods and Joy Clemente jocelyn woods jocelyn clemente jocelyn deal cruz urban crib design llc lio cåollection llc charnel dela cruz etc are con artists. they prey on people by creating false hope about creating large amounts of capital to fund and "fix credit" and by taking money from you and off of your credit cards.
Using an old fashioned bank Scam, They have successfully stolen numerous dollars from people, with no current capability to repay by claiming that they can fix other peoples credit and then raise more money into their names eventually investing the money in a variety of vague and risky investments.
An update on the effort in New York State to get shale drilling legalized--issued by the Joint Landowners Coalition of New York (JLCNY). This June 2013 newsletter provides a quick legislative update, a review of a recent seminar held in Albany, FrackNation screening update, and most importantly, an update on the lawsuit being undertaken by the JLCNY to force New York to compensate landowners if they will not allow drilling--a legal concept called "takings".
Wanna be startin somethin, mj in the scholarly literature, a selected bibliog...Brandon Penny
Two librarians at Texas Tech University have released a report detailing Michael Jackson's broad influence in the scholarly community. Associate Librarians Susan Hidalgo and Rob Weiner combed through scholarly papers and peer-reviewed articles in over 100 databases in creating "Wanna Be Startin' Somethin': MJ in the Scholarly Literature: A Selected Bibliographic Guide"
The guide shows Jackson popping up in psychology, medical, chemistry, mass communications and even engineering journals.
From Slave to Scourge: The Existential Choice of Django Unchained. The Philos...Rodney Thomas Jr
#SSAPhilosophy #DjangoUnchained #DjangoFreeman #ExistentialPhilosophy #Freedom #Identity #Justice #Courage #Rebellion #Transformation
Welcome to SSA Philosophy, your ultimate destination for diving deep into the profound philosophies of iconic characters from video games, movies, and TV shows. In this episode, we explore the powerful journey and existential philosophy of Django Freeman from Quentin Tarantino’s masterful film, "Django Unchained," in our video titled, "From Slave to Scourge: The Existential Choice of Django Unchained. The Philosophy of Django Freeman!"
From Slave to Scourge: The Existential Choice of Django Unchained – The Philosophy of Django Freeman!
Join me as we delve into the existential philosophy of Django Freeman, uncovering the profound lessons and timeless wisdom his character offers. Through his story, we find inspiration in the power of choice, the quest for justice, and the courage to defy oppression. Django Freeman’s philosophy is a testament to the human spirit’s unyielding drive for freedom and justice.
Don’t forget to like, comment, and subscribe to SSA Philosophy for more in-depth explorations of the philosophies behind your favorite characters. Hit the notification bell to stay updated on our latest videos. Let’s discover the principles that shape these icons and the profound lessons they offer.
Django Freeman’s story is one of the most compelling narratives of transformation and empowerment in cinema. A former slave turned relentless bounty hunter, Django’s journey is not just a physical liberation but an existential quest for identity, justice, and retribution. This video delves into the core philosophical elements that define Django’s character and the profound choices he makes throughout his journey.
Link to video: https://youtu.be/GszqrXk38qk
In the vast landscape of cinema, stories have been told, retold, and reimagined in countless ways. At the heart of this narrative evolution lies the concept of a "remake". A successful remake allows us to revisit cherished tales through a fresh lens, often reflecting a different era's perspective or harnessing the power of advanced technology. Yet, the question remains, what makes a remake successful? Today, we will delve deeper into this subject, identifying the key ingredients that contribute to the success of a remake.
From the Editor's Desk: 115th Father's day Celebration - When we see Father's day in Hindu context, Nanda Baba is the most vivid figure which comes to the mind. Nanda Baba who was the foster father of Lord Krishna is known to provide love, care and affection to Lord Krishna and Balarama along with his wife Yashoda; Letter’s to the Editor: Mother's Day - Mother is a precious life for their children. Mother is life breath for her children. Mother's lap is the world happiness whose debt can never be paid.
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Scandal! Teasers June 2024 on etv Forum.co.zaIsaac More
Monday, 3 June 2024
Episode 47
A friend is compelled to expose a manipulative scheme to prevent another from making a grave mistake. In a frantic bid to save Jojo, Phakamile agrees to a meeting that unbeknownst to her, will seal her fate.
Tuesday, 4 June 2024
Episode 48
A mother, with her son's best interests at heart, finds him unready to heed her advice. Motshabi finds herself in an unmanageable situation, sinking fast like in quicksand.
Wednesday, 5 June 2024
Episode 49
A woman fabricates a diabolical lie to cover up an indiscretion. Overwhelmed by guilt, she makes a spontaneous confession that could be devastating to another heart.
Thursday, 6 June 2024
Episode 50
Linda unwittingly discloses damning information. Nhlamulo and Vuvu try to guide their friend towards the right decision.
Friday, 7 June 2024
Episode 51
Jojo's life continues to spiral out of control. Dintle weaves a web of lies to conceal that she is not as successful as everyone believes.
Monday, 10 June 2024
Episode 52
A heated confrontation between lovers leads to a devastating admission of guilt. Dintle's desperation takes a new turn, leaving her with dwindling options.
Tuesday, 11 June 2024
Episode 53
Unable to resort to violence, Taps issues a verbal threat, leaving Mdala unsettled. A sister must explain her life choices to regain her brother's trust.
Wednesday, 12 June 2024
Episode 54
Winnie makes a very troubling discovery. Taps follows through on his threat, leaving a woman reeling. Layla, oblivious to the truth, offers an incentive.
Thursday, 13 June 2024
Episode 55
A nosy relative arrives just in time to thwart a man's fatal decision. Dintle manipulates Khanyi to tug at Mo's heartstrings and get what she wants.
Friday, 14 June 2024
Episode 56
Tlhogi is shocked by Mdala's reaction following the revelation of their indiscretion. Jojo is in disbelief when the punishment for his crime is revealed.
Monday, 17 June 2024
Episode 57
A woman reprimands another to stay in her lane, leading to a damning revelation. A man decides to leave his broken life behind.
Tuesday, 18 June 2024
Episode 58
Nhlamulo learns that due to his actions, his worst fears have come true. Caiphus' extravagant promises to suppliers get him into trouble with Ndu.
Wednesday, 19 June 2024
Episode 59
A woman manages to kill two birds with one stone. Business doom looms over Chillax. A sobering incident makes a woman realize how far she's fallen.
Thursday, 20 June 2024
Episode 60
Taps' offer to help Nhlamulo comes with hidden motives. Caiphus' new ideas for Chillax have MaHilda excited. A blast from the past recognizes Dintle, not for her newfound fame.
Friday, 21 June 2024
Episode 61
Taps is hungry for revenge and finds a rope to hang Mdala with. Chillax's new job opportunity elicits mixed reactions from the public. Roommates' initial meeting starts off on the wrong foot.
Monday, 24 June 2024
Episode 62
Taps seizes new information and recruits someone on the inside. Mary's new job
As a film director, I have always been awestruck by the magic of animation. Animation, a medium once considered solely for the amusement of children, has undergone a significant transformation over the years. Its evolution from a rudimentary form of entertainment to a sophisticated form of storytelling has stirred my creativity and expanded my vision, offering limitless possibilities in the realm of cinematic storytelling.
Tom Selleck Net Worth: A Comprehensive Analysisgreendigital
Over several decades, Tom Selleck, a name synonymous with charisma. From his iconic role as Thomas Magnum in the television series "Magnum, P.I." to his enduring presence in "Blue Bloods," Selleck has captivated audiences with his versatility and charm. As a result, "Tom Selleck net worth" has become a topic of great interest among fans. and financial enthusiasts alike. This article delves deep into Tom Selleck's wealth, exploring his career, assets, endorsements. and business ventures that contribute to his impressive economic standing.
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Early Life and Career Beginnings
The Foundation of Tom Selleck's Wealth
Born on January 29, 1945, in Detroit, Michigan, Tom Selleck grew up in Sherman Oaks, California. His journey towards building a large net worth began with humble origins. , Selleck pursued a business administration degree at the University of Southern California (USC) on a basketball scholarship. But, his interest shifted towards acting. leading him to study at the Hills Playhouse under Milton Katselas.
Minor roles in television and films marked Selleck's early career. He appeared in commercials and took on small parts in T.V. series such as "The Dating Game" and "Lancer." These initial steps, although modest. laid the groundwork for his future success and the growth of Tom Selleck net worth. Breakthrough with "Magnum, P.I."
The Role that Defined Tom Selleck's Career
Tom Selleck's breakthrough came with the role of Thomas Magnum in the CBS television series "Magnum, P.I." (1980-1988). This role made him a household name and boosted his net worth. The series' popularity resulted in Selleck earning large salaries. leading to financial stability and increased recognition in Hollywood.
"Magnum P.I." garnered high ratings and critical acclaim during its run. Selleck's portrayal of the charming and resourceful private investigator resonated with audiences. making him one of the most beloved television actors of the 1980s. The success of "Magnum P.I." played a pivotal role in shaping Tom Selleck net worth, establishing him as a major star.
Film Career and Diversification
Expanding Tom Selleck's Financial Portfolio
While "Magnum, P.I." was a cornerstone of Selleck's career, he did not limit himself to television. He ventured into films, further enhancing Tom Selleck net worth. His filmography includes notable movies such as "Three Men and a Baby" (1987). which became the highest-grossing film of the year, and its sequel, "Three Men and a Little Lady" (1990). These box office successes contributed to his wealth.
Selleck's versatility allowed him to transition between genres. from comedies like "Mr. Baseball" (1992) to westerns such as "Quigley Down Under" (1990). This diversification showcased his acting range. and provided many income streams, reinforcing Tom Selleck net worth.
Television Resurgence with "Blue Bloods"
Sustaining Wealth through Consistent Success
In 2010, Tom Selleck began starring as Frank Reagan i
Panchayat Season 3 - Official Trailer.pdfSuleman Rana
The dearest series "Panchayat" is set to make a victorious return with its third season, and the fervor is discernible. The authority trailer, delivered on May 28, guarantees one more enamoring venture through the country heartland of India.
Jitendra Kumar keeps on sparkling as Abhishek Tripathi, the city-reared engineer who ends up functioning as the secretary of the Panchayat office in the curious town of Phulera. His nuanced depiction of a young fellow exploring the difficulties of country life while endeavoring to adjust to his new environmental factors has earned far and wide recognition.
Neena Gupta and Raghubir Yadav return as Manju Devi and Brij Bhushan Dubey, separately. Their dynamic science and immaculate acting rejuvenate the hardships of town administration. Gupta's depiction of the town Pradhan with an ever-evolving outlook, matched with Yadav's carefully prepared exhibition, adds profundity and credibility to the story.
New Difficulties and Experiences
The trailer indicates new difficulties anticipating the characters, as Abhishek keeps on wrestling with his part in the town and his yearnings for a superior future. The series has reliably offset humor with social editorial, and Season 3 looks ready to dig much more profound into the intricacies of rustic organization and self-awareness.
Watchers can hope to see a greater amount of the enchanting and particular residents who have become fan top picks. Their connections and the one of a kind cut of-life situations give a reviving and interesting portrayal of provincial India, featuring the two its appeal and its difficulties.
A Mix of Humor and Heart
One of the signs of "Panchayat" is its capacity to mix humor with sincere narrating. The trailer features minutes that guarantee to convey giggles, as well as scenes that pull at the heartstrings. This equilibrium has been a critical calculate the show's prosperity, resounding with crowds across different socioeconomics.
Creation Greatness
The creation quality remaining parts first rate, with the beautiful setting of Phulera town filling in as a scenery that upgrades the narrating. The meticulousness in portraying provincial life, joined with sharp composition and solid exhibitions, guarantees that "Panchayat" keeps on hanging out in the packed web series scene.
Expectation and Delivery
As the delivery date draws near, expectation for "Panchayat" Season 3 is at a record-breaking high. The authority trailer has previously created critical buzz, with fans enthusiastically anticipating the continuation of Abhishek Tripathi's excursion and the new undertakings that lie ahead in Phulera.
All in all, the authority trailer for "Panchayat" Season 3 recommends that watchers are in for another drawing in and engaging ride. Yet again with its charming characters, convincing story, and ideal mix of humor and show, the new season is set to enamor crowds. Write in your schedules and prepare to get back to the endearing universe of "Panchayat."
Meet Crazyjamjam - A TikTok Sensation | Blog EternalBlog Eternal
Crazyjamjam, the TikTok star everyone's talking about! Uncover her secrets to success, viral trends, and more in this exclusive feature on Blog Eternal.
Source: https://blogeternal.com/celebrity/crazyjamjam-leaks/
Maximizing Your Streaming Experience with XCIPTV- Tips for 2024.pdfXtreame HDTV
In today’s digital age, streaming services have become an integral part of our entertainment lives. Among the myriad of options available, XCIPTV stands out as a premier choice for those seeking seamless, high-quality streaming. This comprehensive guide will delve into the features, benefits, and user experience of XCIPTV, illustrating why it is a top contender in the IPTV industry.
Skeem Saam in June 2024 available on ForumIsaac More
Monday, June 3, 2024 - Episode 241: Sergeant Rathebe nabs a top scammer in Turfloop. Meikie is furious at her uncle's reaction to the truth about Ntswaki.
Tuesday, June 4, 2024 - Episode 242: Babeile uncovers the truth behind Rathebe’s latest actions. Leeto's announcement shocks his employees, and Ntswaki’s ordeal haunts her family.
Wednesday, June 5, 2024 - Episode 243: Rathebe blocks Babeile from investigating further. Melita warns Eunice to stay clear of Mr. Kgomo.
Thursday, June 6, 2024 - Episode 244: Tbose surrenders to the police while an intruder meddles in his affairs. Rathebe's secret mission faces a setback.
Friday, June 7, 2024 - Episode 245: Rathebe’s antics reach Kganyago. Tbose dodges a bullet, but a nightmare looms. Mr. Kgomo accuses Melita of witchcraft.
Monday, June 10, 2024 - Episode 246: Ntswaki struggles on her first day back at school. Babeile is stunned by Rathebe’s romance with Bullet Mabuza.
Tuesday, June 11, 2024 - Episode 247: An unexpected turn halts Rathebe’s investigation. The press discovers Mr. Kgomo’s affair with a young employee.
Wednesday, June 12, 2024 - Episode 248: Rathebe chases a criminal, resorting to gunfire. Turf High is rife with tension and transfer threats.
Thursday, June 13, 2024 - Episode 249: Rathebe traps Kganyago. John warns Toby to stop harassing Ntswaki.
Friday, June 14, 2024 - Episode 250: Babeile is cleared to investigate Rathebe. Melita gains Mr. Kgomo’s trust, and Jacobeth devises a financial solution.
Monday, June 17, 2024 - Episode 251: Rathebe feels the pressure as Babeile closes in. Mr. Kgomo and Eunice clash. Jacobeth risks her safety in pursuit of Kganyago.
Tuesday, June 18, 2024 - Episode 252: Bullet Mabuza retaliates against Jacobeth. Pitsi inadvertently reveals his parents’ plans. Nkosi is shocked by Khwezi’s decision on LJ’s future.
Wednesday, June 19, 2024 - Episode 253: Jacobeth is ensnared in deceit. Evelyn is stressed over Toby’s case, and Letetswe reveals shocking academic results.
Thursday, June 20, 2024 - Episode 254: Elizabeth learns Jacobeth is in Mpumalanga. Kganyago's past is exposed, and Lehasa discovers his son is in KZN.
Friday, June 21, 2024 - Episode 255: Elizabeth confirms Jacobeth’s dubious activities in Mpumalanga. Rathebe lies about her relationship with Bullet, and Jacobeth faces theft accusations.
Monday, June 24, 2024 - Episode 256: Rathebe spies on Kganyago. Lehasa plans to retrieve his son from KZN, fearing what awaits.
Tuesday, June 25, 2024 - Episode 257: MaNtuli fears for Kwaito’s safety in Mpumalanga. Mr. Kgomo and Melita reconcile.
Wednesday, June 26, 2024 - Episode 258: Kganyago makes a bold escape. Elizabeth receives a shocking message from Kwaito. Mrs. Khoza defends her husband against scam accusations.
Thursday, June 27, 2024 - Episode 259: Babeile's skillful arrest changes the game. Tbose and Kwaito face a hostage crisis.
Friday, June 28, 2024 - Episode 260: Two women face the reality of being scammed. Turf is rocked by breaking
Are the X-Men Marvel or DC An In-Depth Exploration.pdfXtreame HDTV
The world of comic books is vast and filled with iconic characters, gripping storylines, and legendary rivalries. Among the most famous groups of superheroes are the X-Men. Created in the early 1960s, the X-Men have become a cultural phenomenon, featuring in comics, animated series, and blockbuster movies. A common question among newcomers to the comic book world is: Are the X-Men Marvel or DC? This article delves into the history, creators, and significant moments of the X-Men to provide a comprehensive answer.
Are the X-Men Marvel or DC An In-Depth Exploration.pdf
AGE Official Jackson Lawsuit
1. Ira Scot Meyerowitz (IM 2449)
Jon D. Jekielek (JJ 0536)
Meyerowitz Jekielek PLLC
347 Fifth Avenue
Suite 1300
New York, New York 10016
Tel: (212) 686-7008
Fax: (212) 686-7113
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------------------------x
ALLGOOD ENTERTAINMENT, INC.,
COMPLAINT
Plaintiff,
Case No.:
vs.
MICHAEL JACKSON, MJJ PRODUCTIONS, INC.,
DILEO ENTERTAINMENT AND
TOURING, INC., FRANK DILEO, Plaintiffs Demand a
ANSHUTZ ENTERTAINMENT GROUP, Trial by Jury
AEG LIVE, LLC, AEG LIVE NY, LLC.,
Defendants
--------------------------------------------------------------------x
Plaintiff AllGood Entertainment, Inc. (“AllGood” or “Plaintiff”), by its attorneys,
Meyerowitz Jekielek PLLC, as and for its Complaint against defendants Michael Jackson
(“Jackson”), Dileo Entertainment and Touring, Inc. (“Dileo Entertainment”), Frank Dileo
(“Dileo”), Anshutz Entertainment Group (“Anshutz”), AEG Live, LLC (“AEG 1”), AEG
Live NY, LLC (“AEG 2”), and MJJ Productions, Inc., (collectively, “Defendants”) allege
as follows:
1
2. THE PARTIES
1. AllGood was and is a corporation duly organized and existing under the laws
of New Jersey with its principal place of business located in the State of New Jersey,
Morris County.
2. Upon information and belief, Anshutz was and is a corporation duly organized
and existing under the laws of the State of Delaware, with its principle place of business
located at 145 West 45th Street, Suite 9, New York, NY 10036.
3. Upon information and belief, AEG 1 and AEG 2 were and are corporations
both of which are duly organized and existing under the laws of the State of Delaware
with their principal places of business located at 5750 Wilshire Blvd., Suite 501, Los
Angeles CA 90036, and doing business in New York at offices located at 111 Eighth
Avenue, New York, NY 10011. Anshutz, AEG 1 and AEG 2 are collectively referred to
herein as “AEG.”
4. Upon information and belief, Jackson is an individual who is a resident of the
State of California, Los Angeles County.
5. Upon information and belief, MJJ Productions was and is a corporation duly
organized and existing under the laws of the State of ____________, with its principle
place of business located at ___________________.
6. Upon information and belief, Dileo Entertainment was and is a corporation
duly organized and existing under the laws of the State of Tennessee, with an office
located at 2 Music Circle South, Suite 208, Nashville, TN 37203.
2
3. 7. Upon information and belief, Dileo is an individual who is a resident of the
State of Tennessee and is CEO of Dileo Entertainment. Dileo and Dileo Entertainment
are collectively referred to herein as the “Dileo Defendants.”
8. Except as hereinafter specifically described, Defendants, and each of them,
were and are acting in concert or participation with each other, or were joint participants
and collaborators in the acts complained of, and were the agents, alter egos, and/or
employees of the others in doing the acts complained of herein, each and all of them
acting within the course and scope of said agency and/or employment by the others, each
and all of them acting in concert one with the other and altogether.
JURISDICTION AND VENUE
9. This Court has subject matter, i.e., diversity jurisdiction, over this action
pursuant to 28 USC § 1332(a)(1) as the amount in controversy exceeds the sum or value
of $75,000, exclusive of interest and costs, and this controversy is between citizens of
different states.
10. Venue is proper pursuant to 28 USC §1391(a) and this Court has personal
jurisdiction over the parties on the grounds that: (i) a substantial part of the events and/or
wrongful conduct that give rise to the claims alleged herein occurred in this District; (ii)
AEG’s principal place of business is in this District; (iii) the Dileo Defendants agreed to
jurisdiction herein pursuant to an agreement, as discussed in greater detail below; and (iv)
all of Defendants are doing business in New York.
3
4. FACTUAL ALLEGATIONS
The Main Players
11. Patrick Allocco (“Allocco”) is the president and CEO of AllGood, a company
that promotes live events, including but not limited to concerts, festivals and personal
appearances, featuring internationally known performing artists.
12. Upon information and belief, Jackson is a critically acclaimed, multi platinum,
award winning performing artist known throughout the world. Jackson, along with his
siblings, Janet Jackson, Tito Jackson, Jermain Jackson, Marlon Jackson, Randy Jackson,
and Jackie Jackson collectively comprise a family of world renowned performing artists
(collectively the “Jackson Family”).
13. Upon information and belief, Dileo is the president and CEO of Dileo
Entertainment (collectively the “Dileo Defendants”) and was the personal manager of
Jackson for many years, including at all relevant times herein
14. Upon information and belief, AEG is one of the leading providers of live
entertainment and sports in the world and, in fact, the second largest concert promotion,
special event and touring company in the world.
Dileo’s Representations, Dileo’s Authority and the Agreements
15. On or about October 21, 2008 Allocco flew to Las Vegas, Nevada for a
meeting with Joe Jackson, the father of Jackson and the Jackson Family.
16. At the meeting, in which various persons attended, Allocco spoke with Joe
Jackson about his desire to promote a major concert featuring the return of Jackson
and/or a Jackson Family reunion through his company AllGood (the “Event”).
4
5. 17. Joe Jackson informed Allocco that he really hoped to produce the Event, it
would be best to reach out to Dileo, because Dileo was Jackson’s then-current manager.
18. In fact, upon information and belief, Dileo was then and still is generally
known in the music industry to be a long-time former and current manager of Jackson
and/or the Jackson Family. Up to the date of this Complaint, and as recently as last week,
Dileo and other reliable sources were quoted in several media sources as stating that
Dileo was and still is Jackson’s manager.
19. Allocco’s reliance on this industry-wide knowledge, as well as Dileo’s
representations in the media, was reasonable in support of his belief that Dileo was
Jackson’s manager and that Dileo had the express and/or implied authority to bind
Jackson to any such agreement as Allocco was proposing.
20. Shortly after Allocco’s business trip to Las Vegas, an associate of Allocco set
up an appointment for Allocco to meet with Dileo.
21. On or about November 20, 2008, Allocco met with Dileo and another
representative of Dileo Entertainment at a restaurant in Nashville, Tennessee.
22. At the meeting, Allocco reiterated to Dileo his desire and ability to promote a
one time concert in the United States featuring Jackson and/or the Jackson Family, and
even suggested the idea of a making it a Pay Per View event, i.e., the Event.
23. Allocco informed Dileo that he had investors who would be willing to invest
in such a concert.
24. At the meeting, Dileo confirmed and represented that he was in fact Jackson’s
manager, and that he believed he could make the Event a reality
5
6. 25. Further, Dileo stated that he had already spoken to Jackson about Allocco’s
idea of doing a concert featuring Jackson and/or the Jackson Family and that Jackson was
very interested in the Event.
26. The following day, Dileo and Allocco met again, this time at the offices of
Dileo Entertainment.
27. During this second meeting, Allocco once again asked Dileo directly and
explicitly if he had the authority and the power to bind Jackson and/or the Jackson
Family to an agreement requiring them to perform.
28. Dileo responded with a resounding and explicit “yes.” Dileo went further,
bragging that he spoke with Jackson nearly everyday and that he recently finished closing
a movie deal on behalf of Jackson.
29. In reliance of the representations made by Dileo, AllGood and the Dileo
Defendants entered into two agreements which, as described in detail below, essentially
provide that the Dileo Defendants were the acting managers for Jackson, duly authorized
to engage Jackson for a concert performance, that AllGood would be the exclusive
producer and promoter of a Jackson and/or the Jackson Family concert on a date to be
determined, but to be scheduled sometime in the summer of 2009, and, most importantly,
that neither the Dileo Defendants nor Jackson and/or the Jackson Family would agree to
do a concert with any other person or entity at any time prior to the 2009 summer concert
and for a period of three months after said concert.
AllGood’s Efforts, the Breach of the Agreements and AEG’s Intereference
30. Subsequently, Allocco and AllGood went to work to produce and promote the
concert and gather investors and financing.
6
7. 31. During many long months following the agreements, Allocco and
representatives of his company, AllGood, crisscrossed the country meeting with persons
and entities interested in investing in the concert, promoters, agents and other industry
insiders in a good faith attempt to live up to AllGood’s obligations under the agreements
and to produce a once in a lifetime concert event.
32. As a result of all this feverish activity, AllGood incurred significant expenses
and passed by numerous opportunities.
33. In addition, during these months, Allocco spoke with Dileo on a regular basis
and almost daily with Dileo’s business associate, Mark Lamicka, and met with Dileo on
several occasions; once where Dileo purported to call upon Jackson in Allocco’s
presence.
34. During this time, Dileo continued to represent to AllGood and Allocco that he
was still an influential member of Jackson’s small inner circle of advisors, that Jackson
wanted to do the concert, that he would produce Jackson and that the concert would go
on as the parties agreed.
35. In reliance on these continuing assurances, Allocco worked diligently and
successfully lined up investors who were ready, willing and able to invest in the concert
and provide funding to the Dileo Defendants.
36. At some point it became apparent that the Dileo Defendants were not acting in
good faith, and, despite extensions of time to act, could or would not follow through on
their obligations under the parties’ agreements.
37. Subsequently, AllGood learned that, despite their contractual obligations not
to circumvent AllGood, Jackson and Dileo had secretly teamed up with AEG to produce
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8. a concert or series of concerts in London, and perhaps a Pay Per View of Jackson Family
reunion event.
38. Upon information and belief, AEG knew of the agreement between AllGood,
the Dileo Defendants and Jackson, but due to their dominance and power in the live
performance industry, coerced and/or induced Dileo and Jackson to disregard the
agreements with AllGood and to work with it instead.
39. Up to the date of this Complaint, numerous press releases have been
published, which confirm that Jackson intends to move forward with AEG, Dileo as
Jackson’s acting manager, and AEG as the promoter and producer of the London shows,
and perhaps other domestic shows.
40. Defendants have not offered, nor have they made any attempts to include
AllGood in the London and/or other concerts and plans concerning Jackson and/or the
Jackson Family.
COUNT I
BREACH OF CONTRACT
41. Plaintiff hereby incorporates by reference each and every allegation set forth
in paragraphs 1 through 40 of this Complaint as though fully set forth herein.
42. As set forth in detail above, Dileo was a duly authorized manager and/or agent
of Jackson, with actual and/or apparent authority to enter into agreements on Jackson’s
behalf with respect to booking Jackson for a concert performance.
43. Despite being fully aware of the agreements herein and AllGood’s actions in
reliance on Dileo’s representations, neither Jackson nor any of his representatives ever
notified AllGood that Dileo was not Jackson’s manager and/or authorized to act on his
behalf.
8
9. 44. To the contrary, AllGood learned through the press, third-parties, industry
insiders and persons close to Jackson that Jackson approved of the Event and Dileo was
Jackson’s acting manager.
45. On or about November 25, 2008, AllGood and the Dileo Defendants, acting as
duly authorized agents and representatives for Jackson and/or the Jackson Family, duly
entered into and executed a written agreement whereby AllGood would promote a
concert featuring performances by Jackson and the Jackson Family tentatively titled quot;The
Jackson Family Reunion: A Concert for the Worldquot; in the summer of 2009 (the “Event”)
in consideration for the fee of Twenty Four Million ($24,000,000.00) Dollars (the
“Binder Agreement”).
46. The Binder Agreement signed by the Dileo Defendants, on behalf of Jackson
and the Jackson Family, states as follows: “ARTIST/S [i.e. Jackson and/or the Jackson
Family] represents and warrants that ARTIST/S is under no disability, restriction, or
prohibition, whether contractual or otherwise, with respect to ARTIST/S right to execute
this contract and perform its terms and conditions with respect to ARTIST/S right to
appear.”
47. Upon information and belief, the Dileo Defendants and/or Jackson breached
this provision because Jackson was under a disability, restriction or prohibition that
prevented him from performing the terms of the Binder Agreement.
48. Further, the Binder Agreement granted AllGood exclusive rights to produce
the Event with Jackson and/or the Jackson Family.
9
10. 49. In this regard, the Binder Agreement contained a non-compete provision
wherein Jackson and/or the Jackson Family “agree not to consider or agree to perform on
stage prior to the Event.”
50. Moreover, Jackson agreed not to perform, individually, for at least three (3)
months after the Event and the Jackson Family agreed not to perform together for at least
one (1) year following after the Event.
51. As discussed in detail above, the Dileo Defendants and Jackson breached
exclusivity, non-compete terms of the Binder Agreement by, inter alia, agreeing to do the
London shows this summer of 2009 and/or any other performance obligations of which
AllGood is currently unaware during this approximately eighteen (18) month “blackout
period.”
52. The Binder Agreement provides that the “persons signing for … the
ARTIST/S [i.e., the Dileo Defendants] agree to be personally, jointly and severally liable
for the terms of this contract.”
53. On or about November 26, 2008, AllGood, Dileo and Dileo Entertainment,
acting as duly authorized agents and representatives for Jackson and/or the Jackson
Family, duly entered into and executed a written Confidentiality and Non-Disclosure
Agreement which was to run for a term of eighteen (18) months from the date of the
NDA Agreement (“NDA Agreement”).
54. The NDA Agreement incorporated and referenced the subject matter of the
Binder Agreement (collectively the Binder Agreement and the NDA Agreement are
collectively referred to herein as the “Agreements”).
10
11. 55. Further, the Dileo Defendants agreed in the NDA Agreement to apply New
York law and to submit to the jurisdiction of New York State for purposes of any breach
of said agreements.
56. The NDA Agreement had a non disclosure clause whereby the Dileo
Defendants agreed not to use any information prepared and/or provided by AllGood in
connection with the Event.
57. Upon information and belief, the Dileo Defendants breached the foregoing
provision by, inter alia, disclosing information prepared and/or provided by AllGood to
third-parties including AEG.
58. The NDA Agreement contained a non-circumvention clause which provides
that the Dileo Defendants agree not to circumvent AllGood with respect to potential
lenders, investment banking institutions, financial parties, financing sources, potential
investors, strategic alliances, strategic partners, investor group or other
financial/transactional/business relationship or business opportunity introduced to [the
parties] for consideration to provide such financing to the [parties]” with respect to the
Event. Moreover, the parties agreed that they “shall not use any information prepared by
the [parties] to secure financing or transactions independently of” AllGood and in
connection with the Event.
59. Furthermore, the NDA Agreement contained a non-compete clause which
provides that “[f]or a period of 18 months from the date first written above [November
26, 2008], the Parties [i.e., Jackson and Dileo] shall not, directly or indirectly, solicit or
contract in an effort to do business with any person or entity who was in any manner
associated with the Event during the term of this agreement.”
11
12. 60. As discussed in detail above, the Dileo Defendants and Jackson breached non-
circumvention and non-compete terms of the NDA Agreement by, inter alia, agreeing to
do the London shows this summer of 2009 and/or any other performance obligations of
which AllGood is currently unaware during this approximately eighteen (18) month
“blackout period.”
61. As set forth in detail above, with full knowledge and intent, the parties duly
negotiated and entered into the Dileo Agreements and Dileo had the actual and apparent
authority to bind Jackson to the Dileo Agreements.
62. As a result of the foregoing breaches of the Agreement, the Dileo Defendants
and Jackson caused Plaintiff to suffer financial damages and loss of earnings.
63. Plaintiff fully performed in accordance with the terms of the Agreements.
64. The Dileo Defendants and Jackson have no defense for their breaches of the
foregoing agreements and yet they refuse to make Plaintiff whole.
65. Accordingly, Plaintiff is entitled to an award of compensatory damages in an
amount to be determined at the trial, but in no event less than Twenty Million
($20,000,000) Dollars, which amount includes, but is not limited to: (i) the commissions
and fees AllGood would have received under the Agreements, (ii) loss of profits AllGood
would have received under the Agreements; (iii) reimbursement of the expenses AllGood
incurred pursuant to and in reliance on the Agreements; (iv) loss of business
opportunities AllGood forwent in its commitments under the Agreements; and (v) all pre-
and post-judgment interest, costs and attorneys fees.
12
13. 66. Furthermore, the NDA Agreement provides that in case of a breach of this
agreement then the non-breaching party shall be entitled to attorneys’ fees. Accordingly,
Plaintiff is entitled to an award of all attorneys fees incurred herein.
COUNT II
PROMISSORY ESTOPPEL
67. Plaintiff hereby incorporates by reference each and every allegation set forth
in paragraphs 1 through 66 of this Complaint as though fully set forth herein.
68. As described in detail above, the Dileo Defendants, individually, and on
behalf of Jackson, made unambiguous and false promises to AllGood that AllGood
would be the exclusive producer and promoter of a Jackson and/or Jackson Family
concert during the period of 2009 to 2010.
69. At all times, the Dileo Defendants and Jackson knew that AllGood was
reasonably relying upon their promises and foregoing other clients and opportunities due
to their commitments to the Event.
70. As a result, AllGood relied to its detriment upon the promises, assurances and
representations of the Dileo Defendants and Jackson by, among other things, incurring
expenses and by foregoing other business opportunities.
71. Based upon AllGood’s reasonable reliance on the foregoing representations,
the Dileo Defendants and Jackson are estopped from repudiating and/or denying the
terms of the agreements described above.
72. Accordingly, Plaintiff is entitled to an award of compensatory damages in an
amount to be determined at the trial, but in no event less than Twenty Million
($20,000,000) Dollars, which amount includes, but is not limited to: (i) the commissions
and fees AllGood would have received under the Agreements, (ii) loss of profits AllGood
13
14. would have received under the Agreements; (iii) reimbursement of the expenses AllGood
incurred pursuant to and in reliance on the Agreements; (iv) loss of business
opportunities AllGood forwent in its commitments under the Agreements; and (v) all pre-
and post-judgment interest, costs and attorneys fees.
COUNT III
FRAUD
73. Plaintiff hereby incorporates by reference each and every allegation set forth
in paragraphs 1 through 72 of this Complaint as though fully set forth herein.
74. As described in great detail above, the Dileo Defendants knowingly and
fraudulently induced AllGood into entering into the Agreements by making
misrepresentations of material fact to Plaintiff and/or failing to disclose material facts to
AllGood, despite having a duty to do so, such that the Dileo Defendants’ representations
were false representations.
75. Upon information and belief, the Dileo Defendants knew at the time they
made those representations that they were factually false and that they had no intention of
abiding by them as evidenced by the fact that they entered into agreements with AEG to
produce the Event and/or concerts with Jackson, despite having no right to do so under
the Agreements.
76. AllGood relied to its detriment upon the Dileo Defendants’ failure to disclose
material facts, omissions of material facts, promises, assurances, and representations by,
among other things, incurring significant costs and expenses to produce and promote the
Event and by foregoing other business opportunities.
14
15. 77. At all times, the Dileo Defendants knew that AllGood was reasonably relying
upon their representations and/or omissions of material facts and foregoing other options
and opportunities due to their commitments to Dileo Defendants under the Agreement.
78. Accordingly, Plaintiff is entitled to an award of compensatory damages in an
amount to be determined at the trial, but in no event less than Twenty Million
($20,000,000) Dollars, which amount includes, but is not limited to: (i) the commissions
and fees AllGood would have received under the Agreements, (ii) loss of profits AllGood
would have received under the Agreements; (iii) reimbursement of the expenses AllGood
incurred pursuant to and in reliance on the Agreements; (iv) loss of business
opportunities AllGood forwent in its commitments under the Agreements; and (v) all pre-
and post-judgment interest, costs and attorneys fees.
79. In light of the malicious, intentional and/or willful nature of Defendants’
actions, Plaintiff is entitled punitive damages in an amount to be determined at trial, but
believed to be in excess of Twenty Million ($20,000,000) Dollars.
COUNT IV
TORTIOUS INTERFERENCE WITH A CONTRACT
80. Plaintiff hereby incorporates by reference each and every allegation set forth
in paragraphs 1 through 79 of this Complaint as though fully set forth herein.
81. AllGood and the Dileo Defendants, individually and on behalf of Jackson,
entered into the Agreements and/or prospective business relationships wherein AllGood
had a reasonable expectation that it would receive an economic benefit from the
Agreements and prospective business relationships.
82. As described in detail above, upon information and belief, AEG deliberately,
intentionally, and knowingly induced Jackson and the Dileo Defendants to breach and
15
16. repudiate the Agreements and/or terminate their prospective business relationships with
AllGood.
83. Upon information and belief, AEG induced the Dileo Defendants and Jackson
to engage AEG to promote and produce a concerts series in London scheduled to begin in
the summer of 2009, instead of doing a Jackson family reunion or Jackson return concert
series and/or Pay Per View special with AllGood.
84. Upon information and belief, AEG had actual and/or constructive knowledge
of the Agreements and/or prospective business relationships and AllGood’s expectancy to
incur a financial benefit from the Agreements and/or prospective business relationships.
85. In fact, AllGood served AEG with a cease and desist letter, putting AEG on
notice of the Agreements and demanding that AEG cease and desist from interfering with
the Agreements.
86. Had AEG not induced the Dileo Defendants and Jackson to breach the
Agreements, AllGood would have received the anticipated economic advantage of the
Agreements and/or prospective business relationships with the Dileo Defendants and
Jackson, thereby causing AllGood to suffer significant financial loss.
87. Accordingly, Plaintiff is entitled to an award of compensatory damages in an
amount to be determined at the trial, but in no event less than Twenty Million
($20,000,000) Dollars, which amount includes, but is not limited to: (i) the commissions
and fees AllGood would have received under the Agreements, (ii) loss of profits AllGood
would have received under the Agreements; (iii) reimbursement of the expenses AllGood
incurred pursuant to and in reliance on the Agreements; (iv) loss of business
16
17. opportunities AllGood forwent in its commitments under the Agreements; and (v) all pre-
and post-judgment interest, costs and attorneys fees.
88. In light of the malicious, intentional and/or willful nature of AEG’s actions,
Plaintiff is entitled punitive damages in an amount to be determined at trial, but believed
to be in excess of Twenty Million ($20,000,000) Dollars.
COUNT V
PERMANENT INJUNCTION
89. Plaintiff hereby incorporates by reference each and every allegation set forth
in paragraphs 1 through 88 of this Complaint as though fully set forth herein.
90. As set forth above, despite the Agreements, Defendants are proceeding with
Jackson concerts, despite having no lawfully right or authority to do so.
91. As a result, Plaintiff has suffered and continues to suffer permanent, imminent
and irreparable harm.
92. Plaintiff has no adequate remedy at law.
93. Accordingly, for the foregoing reasons, Plaintiffs are entitled to an order
enjoining Defendants from producing, performing and promoting the Jackson concerts
schedule for the summer of 2009, or at any time during the “blackout period.”
DEMAND FOR JURY TRIAL
Plaintiff hereby demands a jury trial as provided by Rule 38(a) of the Federal
Rules of Civil Procedure.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for relief on the counts stated above as against
Defendants as follows:
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18. a. On the First through Fourth Counts, that Plaintiff be awarded
compensatory damages in an amount to be determined at trial and which is otherwise
incalculable at this time, but is not less than Twenty Million ($20,000,000) Dollars;
b. On the Third and Fourth Counts, that Plaintiff be awarded punitive
damages in an amount to be determined at trial, but in no event less than Twenty Million
($20,000,000) Dollars;
c. On the Fifth Count, that Plaintiff be awarded an order enjoining
Defendants from producing, performing and promoting the Jackson concerts schedule for
the summer of 2009, or at any time during the “blackout period;”
d. That Plaintiff be awarded its attorneys’ fees as provided for under the
NDA Agreement and under the common law;
e. That Plaintiff be awarded pre- and post-judgment interest cost and
disbursements; and
f. That Plaintiff be awarded all other and further relief as the Court may
deem just and proper.
Date: New York, New York
June 9, 2009
MEYEROWITZ JEKIELEK PLLC
By:___________________________
Ira Scot Meyerowitz (IM 2449)
Jon D. Jekielek (JJ 0536)
347 Fifth Avenue
Suite 1300
New York, New York 10016
Tel: (212) 686-7006
Fax: (212) 686-7113
Attorneys for Plaintiff
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