AWOIG e e ama 1] KING, HOLMES, PATERNO & SORIANO, LLP HOWARD E. KING, Esq, STATE BAR NO. 77012 2 || SETH MILLER, EsQ., STATE BAR No. 175130 FILED HKING@KHPSLAW.COM Superior Court of California 3 || 1900 AVENUE OF THE STaRs, 25" FLOOR County of Los Angeles 4 [HOSANGELES. Catironnta 90067-4506 DEC 172016 5 6 ‘TELEPHON! (310) 282-8989 FACSIMILE: (310) 282-8903 Snot: ee, » Deputy Attorneys for Plaintiff RITA ORA. Se ene : DY Mechelle Coseulo\ast- 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT = 4294 11 || RITA ORA, an individual, CASE NO. BC 6 0 12 Plaintiff, COMPLAINT FOR DECLARATORY 3 RELIEF AND BREACH OF CONTRACT. 1 vs. 14 |] ROC NATION, LLC, a limited liability company; and DOES'I through 10, inclusive, 15 Defendants. 17 18 Plaintiff Rita Ora (“Rita” or “Plaintiff") seeks freedom from her recording with Roc 19 || Nation, LLC (“Roc Nation”) in furtherance of California’s fundamental public policy that no 20 || person can be bound to a personal services contract for more than seven years. In order to pursue 21 |/ her goals to create, distribute and promote music, goals that have been obstructed by Roc Nation, 22 || Plaintiff alleges as follows: 8 g eR 68 goes Be 232 28 pki | 8 =e 8 26 || Pictures, Inc. 67 Cal. App. 2" 225 (1944): “Seven years of time is fixed as the maxinitugg time for aa 27 || which [an employee] may contract for their services without the right to changg emplgyers or 28|l1/ S834 88 we 00°04 00°Ds or aoso1ngn976 ‘COMPLAINT FOR DECLARATORY RELIEFwer aw awn ‘occupations. Thereafter they may make a change if they deem it necessary or advisable.” Rita now deems it both necessary and advisable to make precisely such a change. 2. Atthe age of 18, Rita entered into an oppressive recording agreement with Roc Nation (the “Agreement”) providing for Roc Nation to gamer not only the bulk of income from Rita’s record sales, but a sizable portion of her income from endeavors such as live shows, endorsements, sponsorships, acting, and merchandise sales. 3. Roc Nation’s initial support for Rita waned as it diverted its focus from a record label business into other ventures, launching various endeavors including a sports management firm and agency and the Tidal Music streaming service. When Rita signed, Roc Nation and its senior executives were very involved with her as an artist. As Roc Nation’s interests diversified, there were fewer resources available and the company suffered a revolving door of executives. Rita’s remaining supporters at the label left or moved on to other activities, to the point where she no longer had a relationship with anyone at the company. 4. Roc Nation now allocates its diminished record label resources to only a handful of admittedly worthy heritage superstar artists. Contrarily, Roc Nation has used the terms of the Agreement to hinder Rita’s recording efforts, to the point where she has only been permitted to release one album in seven years, despite the fact she has created multiple additional records she wanted to release, Rita has pushed forward with her own career, self-funding her promotional television appearances, recording costs and video projects with the proceeds of her other professional endeavors. 5. Since Roc Nation is not a full service, active record label, it must contract with a distributing major label in order to release records by its artists. The distributing label is responsible for promoting, marketing and, to some extent, assisting in the completion of Roc Nation’s artists? records.. In 2013, Roc Nation left its distributing label partner, Sony, to join up with a competing company, Universal, but Roc Nation was legally obligated to leave Rita at Sony. Roc Nation’s remaining focus in the record business, such as it is, is now directed at Universal. Sony, under normal circumstances an excellent distributor, is hamstrung by Roc Nation’s inattention. As a consequence, Sony has attempted to fill the void left by Roc Nation’s apathy, aeaso10979776 2 ‘COMPLAINT FOR DECLARATORY RELIEFMM cn Be a Ko, Howes, Premio sSomsno, LLP wee raan eon which at this point borders on antipathy. Between Sony’s limited economic return from its orphaned relationship with Roc Nation and Sony’s indirect relationship with Rita, Rita is caught in a political quagmire of dysfunction. 6. Refusing to be defeated by the egregious terms of the Agreement and Roc Nation’s roadblocks, Rita has sustained a successful and accomplished career as a singer, composer, actress, television personality and model. Rita’s success has been chiefly self-generated through talent, hard work and financial commitment of her own resources. She has been nominated for numerous prestigious awards in the music industry, including a Billboard Music Award, an Oscar, BET Awards, BRIT Awards, Glamour Awards, MTV Awards and has won an Urban Music Award for Artist of the Year, an MP3 Music Award for Best Newcomer, a Bambi Award for Music-International, and a Silver Clef for Best Female Artist. She is a household name intemationally. She has just concluded a season as a judge on the immensely popular X Factor television show in the United Kingdom. 7, Rita's relationship with Roc Nation is irrevocably damaged. Fortunately for Rita, the California legislature had the foresight to protect its artists from the sorts of vicissitudes she’s experienced with Roc Nation when it enacted California Labor Code §2855 (the “Seven Year Rule”). ‘The Seven Year Rule mandates that contracts to render personal service “may not be enforced beyond seven years form the commencement of service under it.” 8. Rita brings this action for declaratory relief to confirm her rights to freedom under the Seven Year Rule as of the seventh anniversary of the Agreement. PARTIES 9. Plaintiff Rita is an individual, a California resident and a California taxpayer residing in Los Angeles, California, 10, Rita maintains her residence and principal place of business in Los Angeles County, California. 11. Defendant Roc Nation is and was at all times mentioned herein qualified to do business in California; with a registered agent for service of process in California; an office at 9348 Civic Center Drive, Beverly Hills, California 90210; employees and telephone numbers in sa3so109719716 3 COMPLAINT FOR DECLARATORY RELIEFAw ew ne 10 uw 12 13 14 15 16 7 18 19 20 a 22 23 24 25 26 27 28 California; and conducts significant business operations in California. 12, The true names and capacities of Defendants named herein as DOES | through 10, whether individual, corporate, associate or otherwise, are presently unknown to Plaintiff, who therefore sues these Defendants by such fictitious names. Plaintiff will amend her complaint to substitute such true names and capacities when they have been ascertained. Plaintiff is informed and believes and thereupon alleges that each of the fictitiously named Defendants is responsible in some mannér for the occurrences alleged herein. Plaintiff is informed and believes and thereon alleges that each Defendant herein is now, and at all times relevant thereto was, the agent, employee, servant or alter ego of each of the other Defendants herein and, in doing the things hereafter alleged, was acting within the scope of such employment, agency, servitude or alter ego relationship. 13, Plaintiffs informed and believes and on that basis alleges that each of the DOES has participated in or benefitted from the conduct of the named defendants or are otherwise legally responsible in some manner for the matters alleged in this complaint. SUBJECT MATTER AND VENUE 14, Pursuant to Article VI, §§ 4 and 10 of the California Constitution, California Labor Code § 2855 and California Civil Code § 3513, subject matter jurisdiction is proper in the Superior Court of California for the County of Los Angeles, California. 15, Pursuant to Section 392 of the California Code of Civil Procedure, venue is proper in the Superior Court of California for the County of Los Angeles, California, including in that this action seeks to vindicate an important substantive right of a citizen of the State of California, and the agreement at issue in this action was negotiated and called for substantial performance in Los Angeles, California, and purports to be enforceable in Los Angeles, California beyond the time prescribed by California Labor Code § 2855. GENERAL ALLEGATIONS 16. Roc Nation distributes to the public phonorecords embodying Rita’s original performances and compositions. ait 4exn0109719776 4 COMPLAINT FOR DECLARATORY RELIEFua Kin, Hous, Pacem & sSonano, ike wer an awn 10 wu 12 13 14 15 16 7 18 19 20 2 2 23 24 25 26 27 28 17. Plaintiff's agreement with Roc Nation is a personal service contract that binds Rita to work continuously for Roc Nation (and precludes Rita from other work) beyond seven years afier December 18, 2008, the date of commencement of Rita’s services under the agreement, 18. Plaintiff seeks a judicial declaration that Rita’s agreement is voidable and may not be enforced against Plaintiff under California law to the extent it purports to require Rita’s services after December 17, 2015. Concurrently herewith, Plaintiff has delivered notice to Roc [Nation in accordance with California Code of Civil Procedure § 1020 that she will not render personal services after December 17, 2015. THE 2008 AGREEMENT 19. Rita has been contractually bound to Roc Nation under a Long-Form Entertainment Agreement, dated December 18, 2008 (the “Recording Agreement”), a redacted copy of which is attached hereto as Exhibit 1. 20. By its terms, the Recording Agreement has significantly limited Rita's employment rights. Since December 18, 2008, Roc Nation has exclusively owned her services as a recording artist, has exclusively owned the right to exploit her name and likeness for merchandise, and has exclusively had the right to approve (and share in the proceeds of) Rita’s endorsement or sponsorship opportunities. Rita has not been free to provide her recording services except as permitted or dictated by Roc Nation. 21. The Recording Agreement purports to bind Rita as an exclusive employee of Roc Nation for the “Initial Period” which ended May 26, 2013, nine months after release of her first album “Ora,” and up to four additional Option Periods of more than one year each. By its express terms, the Recording Agreement, a contract for unique personal services in the entertainment field, ‘would, according to Roc Nation’s interpretation, bind Rita as Roc Nation's exclusive employee for a duration running from December 18, 2008, to at least 2019, and potentially until much longer, as, ‘each Option Period is keyed to a commercial release by Roc Nation of a record album. 22. California Labor Code § 2855 prohibits the enforcement beyond seven years of a contract (such as the Recording Agreement) to render services of a special, unique, extraordinary or intellectual character. Rita’s seven years have run. Roc Nation’s attempts to thwart this, sa8.0109719776 5 ‘COMPLAINT FOR DECLARATORY RELIEFKno, Howes, Pavano & Somuno,LLP important and fundamental California public policy should not be condoned. FIRST CAUSE OF ACTION (Declaratory Relief) (Cal. Civ. Code. § 3513; Cal. Civ. Proc. Code § 1060; Cal. Lab. Code § 2855; Cal. Bus. & Profs. Code. § 17200 et seg.) 23, Plaintiff re-alleges and incorporates by reference each and every allegation contained in paragraphs 1-22. 24, An actual and immediate controversy has arisen and now exists between Plaintiff and Roc Nation regarding the legality and effect of the Recording Agreement between Plaintiff and Roc Nation related to Rita’s services rendered in connection with her musical recordings and related creative output, 25. Plaintiff seeks a declaration of her rights under California Code of Civil Procedure §1060, that the Recording Agreement violates the Seven Year Rule under Cal, Lab. Code § 2855, and therefore is unenforceable against Plaintiff after December 17, 2015. See Cal. Lab. Code § 2855 (personal service contracts are barred from having terms beyond seven years); de la Hoya v. Top Rank, Inc., No. CV 00-10450-WMB, 2001 WL 34624886, at *14 (C.D. Cal. Feb. 6, 2001) (“De La Hoya has been continuously obligated to provide such services to Top Rank for ‘more than seven years. To bind him to Top Rank any longer would violate section 2855(a). Therefore, the Top Rank Contract between De La Hoya and Top Rank is void and unenforceable.”), 26. Plaintiff also seeks a declaration of her rights that, as the Recording Agreement is unenforceable after December 17, 2015, the Recording Agreement constitutes unfair competition, under Cal. Business & Prof. Code §§ 17200 ef seg., and that Plaintiff is entitled to all of the protection and remedies thereunder. 27. A judicial declaration is necessary and appropriate at this time in order that the parties ascertain their rights and obligations to each other and to avoid the hardship caused on the parties by a protracted dispute and further delay. ut 4esgoi09ni97.6 6 COMPLAINT FOR DECLARATORY RELIEFAo te a Kine Houses, Paraane 8. somino, LLP ee 8s aw ew 10 u 12 13 14 15 16 a7 18 19 20 2 2 23 24 25 26 27 SECOND CAUSE OF ACTION (Breach of Contract) 28. Plaintiff re-alleges and incorporates by reference each and every allegation contained in paragraphs 1-27. 29. The Recording Agreement at all relevant times prior to the date of filing of this Complaint was a valid, binding, and enforceable agreement. 30. Plaintiff has performed all obligations, covenants, and conditions required of her under the Recording Agreement, except to the extent any such obligations, covenants, or conditions have been excused, prevented, or waived by Roc Nation’s acts and omissions. 31. Paragraph 1 1(a) of the Recording Agreement grants Roc Nation on behalf of Plaintiff “the non-exclusive right to procure opportunities in connection with” certain of Plaintiff's entertainment rights, and provides that Plaintiff will pay Roc Nation “twenty percent (20%) of Net Receipts (as defined in Paragraph 11(b) of the Recording Agreement] in connection with such entertainment activities” so procured by Roc Nation, as set forth in more detail in Paragraph 11 of the Recording Agreement, incorporated herein by reference as if set forth in full. 32. On information and belief, Roc Nation at all relevant times herein breached the Recording Agreement by taking a twenty percent (20%) commission on Plaintiff's income from entertainment activities that were not opportunities procured by Roc Nation, 33. Plaintiff has been damaged by Roc Nation’s breach of contract in an amount subject to proof, plus pre-judgment interest thereon, including without limitation, all amounts that Roe Nation improperly took as commissions from opportunities that it did not procure or that it otherwise was not authorized to commission under Paragraph 11 of the Recording Agreement. PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests the following relief: 1, A declaratory judgment that the Recording Agreement exceeds a term of seven years, and violates the Seven-Year Rule under California Labor Code § 2855(a); 2. A declaratory judgment that the Recording Agreement is unenforceable against Plaintiff after December 17, 2015; sa38.0108719756 1 COMPLAINT FOR DECLARATORY RELIEF1 || Plaintiff after December 17, 2015; 3. A declaratory judgment that the Recording Agreement constitutes unfair won competition under Cal. Bus. and Prof, Code §§ 17200 et seq.; 4 4. General, special, and consequential damages in an amount subject to proof, 5 5. Pre-judgment and post-judgment interest; and 6. Such other and further relief as this Court may determine to be just and proper. DATED: December 16, 2015 KING, HOLMES, PATERNO & SORIANO, LLP 10 By: re HOWARD E. KING SETH MILLER 12 Attorneys for Plaintiff RITA ORA 13 14 15, 16 17 18 19 20 a 2 24 26 2 28 ul Kg, Hous, PareRn 8. sonmo.ite || assgoiasrio77s 8g Be COMPLAINT FOR DECLARATORY RELIEF| Roc Nation, LLC Carroll, Guido & Groffman, LLP 1790 Broadway, 20" Floor New York, New York 10019 Rita Ora clo Spraggon Stennett Brabyn, Solicitors, Crown House 225 Kensington High Street London W8 6SQ England Attention: Paul Spraggon December 18, 2008 Re: -w- Roc Nation, Lt ni Entertainment Agree! Dear Rita: The following, when signed by you (‘Artist’) and Roc Nation, LLC ('Company" of “us") will constitute a binding agreement between Company and Artist with respect to a long-form entertainment agreement (the “Agreement’) for Artist's exclusive services as a recording and -entertainment artist as set forth below. 4. Territory. The Universe. 2. Term/Minimum Recording Commitment, (@) Initial Period: ‘The initial Period will commence upon full execution hereof and ‘end on the date nine (9) months from initial commercial release in the United States of the First Album (as hereinafter defined). Artist will deliver one (1) studio album during the Initial Period (the ‘First Album"). (>) (@ Four (4) Option Periods (the ‘First Option Period’, “Second Option Period’ “Third Option Period” and “Fourth Option Period’, as applicable). Artist will deliver one (7) studio album per option period (the "Second Album” through “Fifth Album’, as applicable). ) Each Option Period will commence upon the expiration of the prior contract period and end on the date nine (9) months from initial commercial release in the United States of the applicable Commitment Album. Company will have ninety (90) days ftom the end of the Initial Period to exercise the First Option Period and Company will have ninety (90) days from the end of each ‘option period to exercise any subsequent options (the ‘Option Date"). Company shall notify Artist in writing at any time (the “Termination Notice’), prior to the EXECH HOPRia Om Em ex |3 ©) (a) 1} applicable Option Date of Company's election to extend the Term (as hereinafter defined) for an additional contract period. If Company has not exercised its option by the Option Date, the Term will end on the earlier of the Option Date or the date of the Termination Notice and Company will have no further obligation to Artist thereafter (excluding those obligations which survive termination of this Agreement), subject to the following two (2) sentences. if Company has not exercised its option prior to the Option Date, Artist may, if Company has not already sent Artist the Termination Notice, notify Company in writing at any time after the Option Date, that the Term will end thirty (30) days after Artist's notice. If Company does not exercise its option prior to the end of such thirty (30) day period, the Term will end. The First Album through the Fifth Album will collectively be referred to as the “Commitment Albums.” The Commitment Albums will embody new recordings of Artists studio performances of previously unreleased compositions unless otherwise agreed in writing between the parties. ‘Subject to paragraph 2(e) below, the "Term" shall be the period commencing upon full execution of the Agreement and continuing until the date that is nine (9) months following the date of initial commercial release of the last Commitment Album. Notwithstanding the foregoing, the Term for all ancillary rights will be co- terminous with the Term set forth above plus a post-Term retention period of eighteen (18) months to collect income generated from agreements entered into during the Term and not yet collected. Rights and Ownership. (a) (b) Company will own all recordings, videos, artwork, digital materials and other materials created, delivered and/or released prior to and during the Term in perpetuity as "works made for hire”. Each recording delivered hereunder shall be commercially and technically satisfactory in Company's sole discretion, shall be fully mixed, edited and ‘equalized, and shall be delivered along with all necessary consents, licenses, approvals and permissions and all other materials reasonably requested for release. Advances/Recording Funds. The recording funds set forth below are inclusive of any producer, mixer and musician fees and any other recording, mixing and/or mastering costs and/or advances in connection with the applicable Commitment Album. As used herein the term "Advance" shall mean a prepayment of record royalties which Company may recoup from record royalties to be paid or accrued to Artist under this Agreement. For the avoidance of doubt, mechanical royalties shall not be chargeable in recoupment of any Advances except those which are expressly recoupable from all monies payable under this Agreement. RECS 1807 Rin Or ne@) (b) @ @ First Album: A recoupable recording fund for the First Album in the amount of i } shall be payable to Artist upon full execution hereof. The balance, if any, will be paid to Artist promptly following delivery and acceptance of the First ‘Album (along with all required materials to be delivered by Arfist in connection therewith). The recoupable recording costs will be paid by Company by invoice. In addition, Artist hereby requests and irrevocably authorizes Company to make a one-time recoupable payment of upon full execution hereof directly to Spraggon Stennett Brabyn, Solicitors, Crown House, 225 Kensington High Street London W8 6SQ England, Attention: Paul Spraggon (’Payee") as a contribution towards Artis’s legal fees in connection with the negotiation of this Agreement. Company's compliance with this authorization will constitute an accommodation to Artist alone; Payee is not a beneficiary of it. All Payments under this authorization will constitute payment to Artist which is due to Artist pursuant to this Agreement and Company will have no liability by reason of any erroneous payment of failure to comply with this authorization. Artist will indemnify and hold Company harmless from and against any and all claims asserted against Company and any damages, losses of expenses incurred by Company by reason of any such payment or otherwise in connection. ‘Subsequent Commitment Albums: With respect to the Second Album, the amount of the recording fund shall be of the amount under paragraph 4(b)() below (including pipeline monies but subject to paragraph 4(b)(i) below). With respect to Commitment Albums other than the First Album and the Second Album, the amount of the recording funds shall be of whichever of the following amounts is less (including pipelines monies but subject to paragraph 4(b)(i) below): (the amount of the royalties (other than mechanical royalties) credited to Artist's account on net sales through normal retail channels in the United States and the United Kingdom of the First Album (including digital sides), as determined by Company from its most recent monthly trial balance accounting statement before the date on which the Second Album is delivered or required to be delivered (whichever date is earlier) after deduction of reserves for retums and credits not exceeding of the aggregate number of units of the First Album shipped to ‘Company's customers: or (i) the average of the amounts of such royalties on the two (2) such Commitment Albums released most recently before the delivery of the applicable Commitment Album concerned. No recording fund shall be less than the applicable minimum amount or ‘more than the applicable maximum amount set forth below: Minimum — Maximum LP2 : LP3 LP4 EXECS 107. Roe Oa BasLPs (©) Payment Schedule for the Second Album through the Fifth Album: The following Percentages of the applicable Commitment Album recording funds will be Payable to Artist upon commencement of recording for the applicable Commitment Album; the balance, if any, will be paid to Artist promptly following delivery and acceptance of the applicable Commitment Album (along with all required materials to be delivered by Artist in connection therewith). The recoupable recording costs will be paid-by Company by invoice. ‘Second Album = Third Album — - Fourth Album Fifth Album —" (@) _ In the event that the First Album is not released within twelve (12) months of full execution hereof, Artist shall be paid an additional advance in the amount of (©) Company shall also make available a fund in the amount of . 2 for travel and accommodations for Artist and Artist's management in connection with the First Album. . Artist shall be paid an ‘allin’ royalty of, for the First & Second Albums, : for the Third ‘Album, for the Fourth Album and for the Fifth Album of the published price to dealer (‘PPD’) (or the third-party distributor equivalent) for USNRC net sales of full priced Commitment Albums. Artist shall receive of the net receipts paid or credited to ‘Company from any third party master use license or any exploitation where ‘Company is paid on a flat fee or net receipts basis. All other terms and conditions of such royalties will be pursuant to the terms of any third party distribution agreement provided same shall be within the parameters of industry custom and Company shall use its good faith best efforts to obtain the most favorable terms and conditions concerning royalties. Mechanical Royalties. Artist hereby grants to Company an irrevocable license under copyright to reproduce each Controlled Composition on records and to distribute them in the United States and Canada, “Controlled Composition” shall mean a composition wholly or partly written, owned or controlled by Artist, an individual producer or any person in which Artist or an individual producer has a direct or indirect interest. The license will be at percent of minimum fixed statutory rate as of the date of delivery (or required delivery) of the applicable master recording, regardless of time, subject to a maximum of eleven (11) songs for Commitment Albums. In the event that Company and Artist enter into a co-publishing agreement, the mechanical rate will be increased to Percent of the minimum fixed statutory rate as of the date of delivery (or required delivery) of the applicable master recording, regardless, of time, subject to a maximum of eleven (11) songs for Commitment Albums. PXEOIS 1007 Ri On Eas7. Marketing Restrictions. During the Term in the United States (unless otherwise specified): (a) Artist shall have reasonable approval rights over the musical compositions, producer and terms of their engagement, recording studios and recording dates for each Commitment Album, (b) Company shall not without Aris’s prior written consent, couple any master recording delivered hereunder or embody a master recording delivered hereunder together with other master recordings not subject hereto on records except that Company shall have the right to: () to couple master recordings delivered hereunder on promotional records; (i) couple master recordings delivered hereunder on records distributed for use primarily in means of transportation or jukeboxes; and (ii) authorize consumer compilations (ie., records embodying master recordings delivered hereunder together with other master recordings not subject hereto that are selected and/or ‘sequenced by the consumer). (©) __ Company shall not without Artists prior written consent commercially release any Commitment Album as a mid-price record prior to twelve (12) months or as a budget record prior to eighteen (18) months following Company's initial United States commercial release of such Commitment Album, (d)__ Company shall not without Artist's prior written consent commercially release any Commitment Album as a “cutout” within twenty four (24) months after the initial United States release of the such Commitment Album, (e) Company shall not without Artist's prior written consent remix, remaster, re- sequence, edit or alter the master recordings delivered hereunder unless such edit or alteration is required for the purpose of equalizing the running time of tracks on records, to conform to technological or commercial requirements in various formats now or hereafter known or developed, or to eliminate material which might subject Company to any legal action. () Artist shall have the right of reasonable approval over all master use licenses. (9) Company shall not release demos or outtakes without Artist's prior written consent. This restriction will apply worldwide and after the Term. (h) _ Artist shall have the right to approve photographs of Artist, Artist's likenesses and Artist's bio. Company wil instruct its licensees outside of the U.S. to comply with this approval; provided such licensees’ failure to comply will not be deemed a breach of this Agreement, ! () Artist will have the right to approve artwork on record packaging (including digital ‘ reproductions. thereof). Company will instruct its licensees outside of the U.S. to comply : with this approval; provided such licensees’ failure to comply will not be deemed a breach of this Agreement. EXECIS. 1807 Ria OnE 19@ @ @ Artist will have the right to approve the title of any Committed Album, This restriction will apply worldwide. {K) There shall be no use of any recordings, photographs, artwork or other materials in connection with premium records or other premium-type uses including commercial tie-ups, without Artist's prior written consent. This restriction will apply worldwide and after the Term, () No joint recordings shall be created without Artist's prior written consent. (m) No so-called "samples" shall be authorized without Artist's prior written consent. (0) _Attist and Company shall mutually approve all sponsorship and endorsement ‘opportunites. Accounting and Payment. Company will collect all monies on behalf of Artist and Shall account to Artist on a semi-annual basis. Company's semi-annual accounting periods are currently the periods ending December 31 and June 30. Company shall Tender to Artist a reasonably detailed statement of account and payment of any sums thereby shown to be due with each such accounting. Company shall have the right to hold reasonable reserves in respect of sales hereunder (provided that such reserves are consistent with the reserves taken in connection with other recording artists signed to Company and distributed by the same distributor as Artist). Artist shall have the right to appoint a certified public accountant to examine Company's books and records to the extent the same relate to Commitment Albums and Materials (as defined below) hereunder, at Company's offices during normal business hours, on reasonable written notice, not more frequently than once per statement or once in any calendar year and not later than the later of: () two and one-half (2 14) years from the date the applicable statement is rendered to Artist; or (ji) six (6) months less than the time period Company has to examine distributor's books and records. Fan Club & Company will have the exclusive worldwide fan club and ‘website rights to Artists website and fan club, and will pay Artist « of the Net Receipts (as hereinafter defined) from website and fan club revenues derived from subsription fees and ticket sales. Sales of records via the Artist website or fan club will be accounted for as per the royalty provisions contained in the third-party distribution agreement. Company will also pay Artist. of any Net Receipts from the placement of ads on the website. The website will be the “official” website of Artist. Artist shall have approval over the ‘look and fee!” of the website, the webmaster and the placement of ads on the website; provided that, in the event of a dispute, Company's decision shall control. Upon expiration of the Term, all rights in and to the domain name and URL of the Artist website shall revert to Artist. Additionally, subject to any applicable privacy policies, Company shall transfer to Artist the database of information compiled from all source relating to the Artist and/or “hits to the Artist website (including, without limitation, statistical and demographic data). EXEOK HOT Rin Om Enea?10. Merchandise. Arist will grant to Company the exclusive right to exploit Artist's merchandising rights which includes the use of the Artist's name and likenesses for the manufacture, distribution and sale of both physical merchandise (e.g., t-shirts, sweatshirts, posters, efc.) and digital merchandise (e.g., digital wallpaper and screen savers). All merchandise products will be subject to Artist's creative approval Company will pay Artist of Net Receipts from the sale of merchandise. 11. Additional Entertainment Rights. (@) Artist and Company acknowledge and agree that during the Term, Company will be bullding Artist as a brand, Accordingly, Artist grants to Company the non- exclusive right to procure opportunities in connection with the following entertainment rights on behaif of Artist: ()) endorsements, sponsorships, strategic partnerships or other third party entertainment business relationships; (ji) the exploitation in any and all media of Artist's name, likeness and/or biographical Artist’s live performance engagements in all media (e.g., musical and/or dramatic performances on tour, in concerts or on television), (iv) Artist's services rendered as an actor or performer (in any and all media, including, without limitation, film and television); and (v) books, magazines ‘and other _ Publishing materials writen by or about Artist. Arist wil pay Company ‘of Net Receipts in connection with such entertainment activites. For the avoidance of doubt, Artist shall administer the foregoing entertainment rights provided that Company shall have the right to approve any sponsorship or endorsement opportunities, such approval not to be unreasonably withheld or delayed. Notwithstanding the immediately preceding sentence, in the event an agreement relating to the entertainment rights listed above is secured directly by Attist or any third party on Artist's behalf, Artist will use best efforts to cause payment of of Net Receipts to be paid directly to Company by Artist's accountant or direcily to Company by the applicable third party pursuant to a letter of direction. In the event that the accountant and/or any third parties refuse to pay Company directly, Artist will pay Company __of Net Receipts in accordance with the accounting provisions of paragraph 8 above. Further, Company shall be entitled to examine Artist's books and records to the extent the same relate to any such third parly agreements in accordance with the terms of paragraph 8, (b) "Net Receipts” means gross receipts received by Company (or Artist (including ‘Artist's accountant) andlor any third party on Artists behalf, as applicable) in ‘connection with the fan club, website, merchandise and additional entertainment rights granted hereunder less related expenses (excluding all of Artist's third party commissions, including, without limitation management, business management, agent, and legal fees or commissions, which will be solely Artist's responsibilty). Notwithstanding the foregoing, third party agency fees and commissions with respect to mutually approved agents hired and directly related to the negotiation of agreements with respect to motion pictures, television works, books, sponsorships, endorsements (including in connection with touring), product lines ‘and any synchronization and master use licenses in connection therewith (provided such fees/commission shall be no more than of EXB0{9 407 Rim On Eat i912. 13. 14, e @ gross monies of the consideration) shall be taken “off the top” prior to the split of income between Artist and Company. Live Concert Film. During each contract period, Company will have the option to shoot and produce a live concert fim for use in any and all media (DVD, theatrical, TV, on- line, mobile). Artist will be paid the full LP royalty rate for all net sales of full-priced DVD's of the live concert film. Artist shall have a right of reasonable approval over the direction and form of use of such live concert film, US. & U.K, Release Commitment. (@) Company will cause a bonafide national release of each Commitment Album in the United States, in physical or digital format, within one (1) year following delivery to Company of all required materials in connection with the applicable Commitment Album (including artwork) (“Delivery”). Company will also cause a single to be released to radio within six (6) months following Delivery. If Company does not release each Commitment Album and/or single as aforesaid, Artist may provide written notice to Company of such failure and Company shall have a period of sixty (60) days from the date of such notice to release the applicable Commitment Album and/or single within the manner required herein, failing which the Term shall automatically terminate without further notice. The months of November and December shall not be included for purposes of calculating Company's deadlines hereunder. (b) Company will release each Commitment Album in the U.K. within six (6) months from U.S. release of the applicable Commitment Album. If Company does not release a Commitment Album as aforesaid, Artist may provide written notice to ‘Company of such failure and Company shall have a period of sixty (60) days from the date of such notice to release the applicable Commitment Album. The months of November and December shall not be included for purposes of calculating Company's deadlines hereunder. In the event that Company fails to release a Commitment Album in the U.K. within the time period prescribed above, Artist may require Company to license that Commitment Album to a third party for the U.K. only and Artist shall be paid ; of Net Profits (@s defined in the next sentence) pursuant to such third party license. “Net Profits" means gross receipts received by Company in connection with any third party license for the release of a Commitment Album in the U.K. less all related expenses in connection with the Commitment Album. Pay or Play. if Company fails or refuses to allow Artist to record a particular ‘Commitment Album or if Company notifies Artist that it does not intend to allow Artist to record a particular Commitment Album, Artist may provide written notice to Company of such failure or refusal and Company shall have a period of thirty (30) days fromthe date fof such notice to cure by allowing Artist to commence or continue recording. If Company fails to cure as aforesaid, upon the expiration of said thirly (30) days, the Term shall automatically terminate without further notice and Company shall pay Artist one-third (1/3) of the minimum applicable recording fund, subject to offset of any prepaid in-pocket Advances in connection with such Commitment Album made to Artist in accordance with the terms of this Agreement, EXEC 1807 Ria Om End@ 15. ranties, Ret t ti ind Indemni Artist warrants and represents that: (a) (b) © @) e) © ) Artist is not under any disability, restriction or prohibition, whether contractual or otherwise with respect to (A) Artist's right to enter into this ‘Agreement, and (B) Artist's right to grant the rights granted to Company hereunder, to perform each and every term and provision hereof, and to record each and every composition hereunder. Company shall not be required to make any payments of any nature for, or in connection with, the acquisition, exercise or exploitation of rights’ by Company pursuant to this Agreement, except as specifically provided in this Agreement, Astist is or will become and will remain to the extent necessary to enable the performance of this Agreement, a member in good standing of all labor unions or guild, membership in which may be lawfully required for the performance of Artist's services hereunder; Neither the Materials nor any use of the Materials by Company will violate fr infringe upon the rights of any person. "Materials" as used herein means any musical, artistic, and literary materials, ideas and other intellectual properties, furnished by Artist and contained in or used in connection with any recordings made hereunder or the packaging, sale, distribution, advertising, publicizing or other exploitation thereof, Artist will not at any time record, manufacture, distribute or sell, or authorize or knowingly permit Artist's performances to be recorded for any purpose without an express written agreement prohibiting the use of such recordings. Artist will not perform any composition that has been recorded hereunder for anyone other than Company prior to the date which is five (5) years subsequent to the date of delivery to Company of the applicable master recording containing such composition or the date two (2) years subsequent to the expiration date of the Term of this Agreement or any subsequent agreement between Company and Artist with respect to Artist's recording services, whichever is later. Artist agrees to indemnify and hold us and our successors, assigns, agents, distributors and licensees harmless against any claim, lability, cost and expense (including attorneys’ fees and legal costs) in connection with any third party claim which is inconsistent with any agreement, covenant, representation, or warranty made by Artist herein provided such claim is reduced to final, adverse judgment in a court of competent jurisdiction or settled with Artist's prior written consent not to be unreasonably withheld, EXECS 07 Ria Om EmadPending the resolution of any such claim, we may withhold monies that ‘would otherwise be payable to Artist under this Agreement (such monies to be held in an interest-bearing account) unless Artist obtains a surety bond from a surety acceptable to Us in our sole discretion, with Company as a beneficiary, in an amount reasonably consistent with the amount of such claim. If no action is filed within one (1) year following the date on which such claim was first received by us, we shall release all sums withheld in eonnection with such claim, unless we, in our reasonable business judgment, believes an action will be filed. Artist shall have the right to post ‘a bond to assure Company of reimbursement for any costs and expenses based on Artist's lability, the terms of which shall be subject to Company's approval and upon such approval it shall no longer withhold any sums based on the claim 16. Notices. All notices pursuant to this Agreement shall be in writing and shall be given by registered or certified mail, return receipt requested or overnight courier (e.g., FedEx) at the respective addresses hereinabove set forth or such other address or addresses as designated by either party. A copy of all notices to you Artist shall be sent to Spraggon Stennett Brabyn, Solicitors, Crown House, 225 Kensington High Street, London WB. 6SQ England, Attention: Paul Spraggon. 17, Breach.& Cure. itis expressly understood and agreed that, in the event of a breach or purported breach by Company hereunder, Artist's rights shail be limited to an action at law for money damages, if any, actually suffered by Artist as a result thereof, and in no event shall Artist be entitied to rescission, injunction or other equitable relief of any kind. Neither party shall be entitled to recover damages by reason of any breach by the other party of a material obligations hereunder, unless the breaching party has failed to remedy such breach within thirty (30) days following receipt of the non-breaching party's written notice thereof, or, if the breach cannot be reasonably cured within said thirty (30) day period, ifthe breaching party does not commence to cure such breach within said thirty (30) day period and diligently continue to so cure thereafter. This document is intended to evidence both parties’ acceptance of the basic commercial terms of this exclusive recording agreement. Accordingly itis binding on both parties unless and until replaced by a long form agreement which both parties hereby agree to negotiate in good faith as soon as possible following the full execution of this heads of agreement and Which shall be based on customary industry parameters for agreements of this nature. This Agreement may be executed in counterparts, each of which shall be deemed an original, but all of which shall constitute one and the same instrument. This Agreement shall be exclusively governed by the laws of the United States and New York and exclusively subject to the jurisdiction of the courts of the United States and New York. You hereby represent and warrant that you have obtained independent legal advice in respect of this Agreement wa 7 wt uw EXECISS. IT Rin On Eadswit from a lawyer experienced in negotiating and concluding exclusive recording agreements and that the lawyer has confirmed that this Agreement is fair and reasonable and for Artist's and your benefit. AGREED AND ACCEPTED: Very truly yours, ROC NATION, LLC ‘An authorized signatory u EXECI. 187 Rin OnE 19ae @. @. a from a lawyer experienced In negotiating and concluding exclusive recording agreements and that the lawyer has confirmed that this Agreement is falr and reasonable and for Artist's and your benefit AGREED AND ACCEPTED: Very truly yours, Rita Ora ul EXECHS 107 Rin On Etacr oe Mees O—earacan | Howard E. King, Esq. (SBN 077012) Seth Miller, Esq. (SBN 175130) King, Holmes, Paterno & Soriano, LLP FILED 1900 Avenue of the Stars, 25th Floor Superior Court of Calitoen Los Angeles, CA 90067 County of Los Angeles Teepnoneno: (310) 282-8989 Faxno- (310) 282-8903 arronterronsum: Plaintif€ RITA ORA SUPEROR COURT OF ALFORNA COUNTY Of LOS, Angeles DEC 17 2016 finswowse ii? W. Hill Street eee ecutive OtieeCterk cmvmparcoe Los Angeles, CA 90012 i cusoruue Central District shay eats CASENAME: “Rita Ora v. Roc Nation, LEC CIVIL CASE COVER SHEET Complex Case Designation ae (eI unites “times, (1) Counter) soinder 06 04294 our oe Filed with first appearance by defendant | woce Bee oon ERY teal _tcatcee earn Sauter: | “ome items 1-5 below must be competed (se instructions on page 2). [Check one box below forthe case type that best describes this case ‘Auto Tort, ‘contract, Provisionally Complex Civil Litigation [Jato 22) [Ge] Breach of contractwarany (08) (Gal Rules of Cour, rules 3400-3403) uninsured motorist (6) ruse 2.740 cotecton (08) [Antius Trade reguatin 03) Other PIPDIWD (Persona InuryProperty =) omer cotestons (9) (construction detect 10) Damage/Wrongful Death) Tort [F | insurance coverage (18) (J mass tort 40) TJasbestos (04) [J other contract (37) (J) Secunties itigation (28) (Product ability (24) Real Property [Environmental Toxic tort (30) (FJ medical mapractce (45) [eminent domaiviverse insurance coverage claims ating rom the (hotter pupowo (23) condemnation (4) above ted provstonaly complex cate Non PUPOMD (Other Tort [Wrongtt eviction (3 types 1) (business torvuntair business practice (07) [—] Other real property (26) Enforcement of Judgment lea ons (08) Unlawful Detaner (J Entorcement of judgment (20) (—Detamation (13) Commercial (31) Miscellaneous Civil Complaint (Jere (16) (Resiaentat 32) Cacoe (inetectual property (18) Dongs 8) (—otner complain (not specie above (42) (—rotessional negigence (25) Jaeial Review Miscellaneous Civil Petition otner non PvP DD tort (38) J Asst fret (05) Partnership and corporate governance (21) Employment [= Petsion re: arstraion award (11) =] other pation ot spcted above) (48) TT vvrongf termination (36) (wit ot mandate (02) ote employment (1) other uct review (9) 2. Thiscase [_] is [ix] isnot complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management a. |__] Large number of separately represented parties d. (_] Large number of witnesses b. [=] Extensive motion practice raising difcut or novel e. (| Coordination with related actions pending none or more courts issues that wil be time-consuming o resolve in olher counties, states, or counties, orin a federal cour c. (J Substantial amount of documentary evidence f. [) Substantial postjudgment judicial supervision . Remedies sought (check all that app): a. Lx} monetary b. La] nenmonetay; declaratory or injunctive rliet Number of causes of action (specify): Two Thiscase (] is Lac] isnot a class action suit 20 forp/CM.015,) 6. Ifthere are any known related cases, fle and serve a notice of related case. (You] Date? December 16, 2015 » Howard E. King, Esq Tire ON FANT WIE a NOTICE + Plaintiff must file this cover sheet with the fit paper filed in the action or proceeding (except small claims cases or cases fled under the Probate Code, Family Cade, or Welfare and Institutions Code). (Cal. Rules of Cour, rule 3.220.) Failure to file may result " sanctions + Eile this cover sheet in addition to any cover sheet required by local court rule. «= [Ethis case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all ther parties to the action or proceeding «© Unless this isa collections case under rule 3.740 or a complex case, this cover sheet willbe used for statistical purposes only. Farm apa to naan Oe CIVIL CASE COVER SHEET ods Tat Rs of Ga rane 255 37, D203 374 CP punitive IGPATURC OF ERTY OR ATTGROEY FOR PART “see Cnet Cara Gat Sons ot Aaron 310 Sisto day 2007wsTRu@ons ON HOW TO COMPLETE THE C< ‘SHEET CM-010 To Plaintiffs and Others Filing First Papers._If you are fling a fist paper (for example, a complaint) in a civil case, you must complete and fle, along with your fist paper, the Civil Case Cover Sheet contained on page 1. This information will be used fo compile slatistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check ‘one box for the case type that best describes the case. Ifthe case fits both a general and a more specific type of case listed intern 1, check the more specific one. if the case has multiple causes of action, check the box that best indicates the primary cause of action. To assist you in competing the sheet, examples ofthe cases that belong under each case type in tem 1 are provided below. A cover sheet must be filed only wth your initial paper. Failure to file a cover sheet withthe fist paper fied in a civil case may subject a party, ts counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Cour. To Parties in Rule 3.740 Collections Cases. A ‘collections case" under rule 3.740 is defined as an action for recovery of money owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of attachment. ‘The identication of a case as a rule 3.740 collections case on ths form means that it wil be exempt from the general ime-fr-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections case will be subject to the requirements for service and obtaining ajudgment in rule 3.740. To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the case is complex. Ifa plaintiff believes the case is complex under rule 3.400 ofthe Calforia Rules of Court, this must be indicated by ‘completing the appropriate boxes in items 1 and 2. if plaintiff designates a case as complex, the cover sheet must be served with the Complaint on all parties to the action. A defendant may file and serve no later than the time of its frst appearance a joinder in the plainti’s designation, a counter-designation that the case isnot complex, or, if the plaintiff has made no designation, a designation that the case is complex. ‘Auto Tort ‘Auto (22)—PersonalinjuryiProperty Damage/Wrongful Death Uninsured Motorist (46) ( tho ‘case volves an uninsured ‘motorist claim subject arbitration, check his item instoad of Auto) Other PUPDAWD (Personal Injury! Property DamageMrongful Death) ort ‘Asbestos (04) ‘Asbestos Property Damage ‘Asbestos Personal Injury! ‘Wrongful Death Product Liabilty (not asbestos or toxie/environmental) (28) Medical Malpractice (45) Medical Malpractice Physicians & Surgeons: ther Professional Health Care Malpractice (ther PUPDIWD (23) Premises Liailty (e.g, slp ‘and fal) Intentional Body ijury/PONWD (e9, assault, vandalism) Intentional infletion of Emotional Distress Negligent Infcton of Emetional Distress ‘Other PUPDWD Non-PUPOAWD (Other) Tort ‘Business TorVUnfair Business F* practice (07) Gil Rights (e.g, ciscrmination, {alse atest (ot civil » harassment) (08) efamation (e.g, stander, libel) (3) Fraud (16) Intellectual Property (19) Professional Negligence (25) Legal Malpracton ‘Other Professional Malpractice (not medical or legal) ‘ther Non-PUPDAND Tart (35) Employment ‘Wrongful Termination (36) Other Employment (15) (CASE TYPES AND EXAMPLES Contract ‘Breach of ContracuWarrany (06) ‘Breach of RentalLease ‘Contract (not unlful detainer ‘or wrongful eviction) CContractMarranty Breach—Seller Plaintiff (not fraud or negigence) \Negigent Breach of Contract Wi ranty ‘other Breach of ContractWarranty CColections (e... money owed, open ‘book accounis) (09), Collection Case—SellerPlantif ‘Other Promissory NoteColections Case Insurance Coverage (not provisionally ‘complet (18) ‘Auto Subrogation ‘Other Coverage (Other Contract (37) ‘Contractual Fraud ‘Other Contract Dispute Real Property Eminent Domaivinverse ‘Condemnation (14) Wrongful Eviction (33) (Other Real Property (e.9.. quiet ile) (26) ‘Wei of Possession of Real Property ‘Mortgage Foreclosure ‘Quiet Tile ‘Other Real Property (not eminent domain, andierdteriant, or Terecosure) Untawtul Detainer ‘Commercial (31) Residential (32) Drugs (38) (i ho case involves ilogal ‘drugs, check tis tem; otherwise, ‘report as Commercial or Residential) Judicial Review ‘Asset Forfeiture (05) Pelton Re: Arbitration Award (11) Wal of Mandate (02) Wiit-Administrative Mandamus \Wrt-Mandamus on Limited Cour Case Matter Writ-Other Limited Court Case Review ther Jucicial Notice of Appeal-Labor ‘Commissioner Appeals Provisionally Complex Civil Litigation (Cal Rules of Court Rules 3.400-3.403) ‘AnttrusvTrade Regulation (03) Construction Defect (10) Claims Involving Mass Tor (40) ‘Secures Ltigaton (28) EnvionmentalToxic Tor (30) Insurance Coverage Claims (rising from provisionally complex ase type listed above) (41) Enforcement of Judgment Enforcement of Judgment (20) Abstract of Judgment (Out of ‘County) Confession of Judgment (aon- ‘domestic refatons) ‘Sister State Judgment ‘Aaministrative Agency Award (not unpaid taxes) Peiition/Certitation of Enty of Judgment on Unpaid Taxes (Other Enforcement of Judgment Case Miscellaneous Civil Complaint RICO (27) (Other Complaint (nat specitiad above) (82) Declaratory Relief Only Injunctive Relief Only (non- ‘herassment) Mechanics Lien ‘Other Commercial Complaint Case (non-or/non-complex) ‘Other Civil Complaint (on-trtinon-compiex) Miscellaneous Civil Petition Parinership and Corporate Governance (21) (Other Petition (not speciiod ‘above) (83) Civil Harassment Workplace Violence ElerDependent Adult ‘Abuse. Election Contest Petition for Name Change Petion for Rei from Late Claim Otner Civ Petition aro day. 20077 CIVIL CASE COVER SHEET Paget" Se Ra Te ome B gg OAD OE CIVIL CASE COVER SHEET ADDENDUM AND (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) STATEMENT OF LOCATION This form is reqi 1d pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court. Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case: JURY TRIAL?[3]YES CLASS ACTION?[_] YES LIMITED CASE? [_] YES TIME ESTIMATED FOR TRIAL_4_[ | Hours/[ x |DAYS Item Il. Indicate the correct district and courthouse location (4 steps ~ If you checked “Limited Case’, skip to Item Il, Pg. 4: ‘Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected, Step 2: Check one Superior Court type of action in Column B below which best describes the nature of this case. ‘Step 3: In Column C, circle the reason for the cour location choice that applies tothe type of action you have checked. For any exception to the court location, see Local Rule 2.3. Applicable Reasons for Choosing Courthouse Location (see Column C below) 4, Class actions must be fed 4 LBeation where body injury, do 4 Garaacons mustne edna Stney Monk Coutnouna coral date, Location of propa 5 Uodaton where cause of action argie, "07 SY PrOPETY camage) ea Reetendanti ‘of damage occured 8 Location where one or mere of fhe partes reside, ‘or permanently garaged vehicle, permanent garag 3 Location wnerein detendant respondent functions whol. 5 Location where performance requred or defendant resides, 10, Location f Labor Commissioner 111. Mandatory Filing Location (Hub Case) ‘Step 4: Fill n the information requested on page 4 in item Il; complete item IV. Sign the deciaration, A B C Applicable Civ Case Cover Sheet Type of Acton Reasons See Step’ Category No (heck nly one) ‘Above s & ‘Auto (22) [47100 motor venice Persona juy/Property Damagemrongtul Death | 1.2.4 2 Uninsured Motorist (46) |[—] 47110 Personal injury/Property DamageWrengful Death — Uninsured Motors 1. 2. 4 = [1 Aso70 Asbestos Property Damage 2 ze a |) 7221 asbestos - Personal njunyWrongtu Desth 2 Re &3 Product Liabitty (24) —_|{] 7260 Product Liabilty (not asbestos or toxicenviconmental) 1,23, 448 se satapracce as) [cea A7210 Medica apace -Pyskcians & Surgeons 14 BE | Mesetmabacin 48) |) arz4o other Professional Heath Care Malpractice 14 B= a4 mer pesone: [ol A750 Premises ibity (sip anda) 1.4 Pay TnluryPropery |] 7290 Intentional Baty inuyiPropery Damagenwrongul Death eg. | 44 is Damage Weng ansaut vandatem ete) i Death 23) | 7270 Intentional nicion of Emotional Distess 1.3 |=] 47220 otter Personal nur Property Damage/Wrongful Death 1.4 fc Lacwy 108 (Rev 3715) CIVIL CASE COVER SHEET ADDENDUM Local Rule 23 Lac Approved 03-04 AND STATEMENT OF LOCATION Page 1 ofA B CApplicabie Civil Case Cover Sheet Type of Action Reasons.- See Step 3) ‘Category No. (Check only one) ‘Above ee Business Tort (07) [J 6029 Other Commercial/Business Tort (not fraud/breach of contract) 443, Be Civ Rights (08) [1 As005 ivi Rights/Diserimination 1.243 Bs Defamation 13) | [=] AB010 Detamaton slandebeh 12.8 ED [remeron | See ce necvutenemaom [oS Other (35) {) 6025 Other Non-Personal injury/Property Damage tort 2.3. ‘Wrongful Termination (36) | [__] 6037 Wrongful Termination 1.2,3. ([) A6024 Other Employment Complaint Cat oo ther Employment (18) | Breach of Contracl Warranty (06) (ot insurance) ([ A6108 Labor Commissioner Appeals eter) [As008 contrecuWorranty reach Selle Paint ro raudinegigence) (F As0t9 Negligent Breach of Contracuwarenty (oo raud) [5] 6028 oer Breach of ContractWarranty (not fraud or negigence) 10. [J 8004 Breach of Rental/Lease Contact (not unlawful detainer or wrongiul] 2 5 z lectins Case-Seler Plant 16.11 2 Cotectons (08) ([) A6002 Collections Case-Seller Plant 2.5.6, ¢ ( As012 other Promissory NoteCollection Case 2.511 8 (nso cotectons Case-Purchased Debt (Charged Off Consumer Debt| 5,6, 11 Purchased ono ter Janvary 1, 2014) (sors insurance Coverage (not complex) 1.2.8.8 (soos contactua Fraue 4.2,3,5 [A601 Tortousintererence 4.2.3,5. (A802? omer Contact Diaputenet breactinsuranceftaudinegigence) | 1.2.3, 8 Emery Domaevine*® |] a7300 Eminent DomaivCondermation Number of parcels 2 Wrongful Eviction (33) | [—] 6025 Wrongful Evietion Ca 2.6. (1 asots mortgage Forectosure 2.6. (Ones Real Property (28) | [—] a602 Quiet Tle 2 . 1 Asoeo other Rea! Property rat eminent domain landordtenan foecosue) | 2 * B [MnawttDetager-Conmerea!| (—] asoat Une! Detanerconmerca oat ngs or wong eveton) | 2 6 a ( A8020 Uniawiu Detainee Resident (not drugs orwrongfuteveton) | 2..6 ; iat outnine: | [1 ast20F une Osan Post Ferecnue 2.6 © | Untowiu Detainernugs (38) | [_) 8022 Unlawul Detainer-Orugs 2,6 ul AGW 109 (Rev 385) CIVIL CASE COVER SHEET ADDENDUM Local Rule 23 LASC Approved 03-06 AND STATEMENT OF LOCATION Page 2 of 4wonrmme RITA ORA V. ROC NATION, LLC SEMA B C-Appiicabie. ‘ivi Case Cover Sheet “Type of Action Reasons See Step Category No (heck ony one) ‘above Asset Forfeiture (05) | [_] A6108 Asset Forfeiture Case 2.6. | Pettion we arivaton 11) | [—] 6115 Petition o CompelContin/Vacate Arbitration 2.5. é (J) A661 Wet - Adminitrative Mandamus 2.8 q Wie of Mandate (02) |] 6152 wt - Mandamus on Linted Cour Case Matter 2 3 () a6tss wit ther Limited Court Case Review 2 Other Juacat Review (39) |[_—] 6150 Other Wet Jucca Review 2.8 sg [Anttrsrade Reguaton(03)]T_—] S003 Anti Trade Regulation 72,8 B | construction Detect (10) |[—] 6007 constuction Detect 1.243, B | Claims involgg Mass Tort |) 6006 Claims Involving Mass Tor 1.2.8 e S| securties tigation (26) |] 6095 Securities Liigaton Case 1,248, 5 envi RE TO yy) |] A036 Tore Tonvronmenta 1.2.8.8 2 | insurance Coverage Claims E | Mam Cemmer Coeetaiy |] A80%6 Insurance CoveragerSubrogaton (complex case ony) 12,848 TJ A141 Ser State Juegment 2.8 EE [Z asi60 Abstract of Judgment 2.6. gE Enforcement (48107 Confession of Judgment (non-domestic relations) 2.8 8s ‘f ddgrent (20) (1) As140 Administrative Agency Award (not unpaid taxes) 2.8, $3 as () Astt4 Petion'centcate for Entry of Judgment on Unpaid Tax 2.8 [J 6112 other Enforcement of Judgment Case 2.8.9 RICO (27) [__] 6033 Racketeering (RICO) Case ey gZ as A030 Dectratory Rett Ony 4.2.8 ag ‘omnes Compaints |] A040 tnunctive Relief Only (oot domesticiharassment) 2.8 BE | (etSreetea nove) (42) |) aso11 otter Commercial Compaint Case (non-orvnon complex) 1.2.8 2 [J A6000 other civil Complaint (non-tortinon-complex) 1,2,8 Paresh Coraraten [1] Astt3 Partnership and Corporate Governance Cate - J] A621 vi Harassment 2.3.8 a2 [ as125 worptace Harassment 2.3,9 Be | crerraon oun [TI Az euerence ae tc 2.3.8 3 Specified Above) (43) | [_} A6190 Election Contest 2 as & asi10 Pettion fr change of Name 247. y 48170 Peition for Rete rom Late Claim Law 2,94448 M TH asi00 one: cit Petton 2.9. LACIV 109 Rew 375) CIVIL CASE COVER SHEET ADDENDUM Local Rule 23 ASC Approved 03-04 AND STATEMENT OF LOCATION Page 3 of 4: oe e e ‘SWORTTMERITA ORA V. ROC NATION, LLC v CASE NOGER tem Ill. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other ‘circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected, 9348 Civic Center Drive tunder Column € for the type of action that you have s this ease, (C1. O3.46.06.7.O809.O10.0011 Beverly Hills cA___|g0220 Item IV. Declaration of Assignment. | deciare under penalty of perjury under the laws ofthe State of Cafonia tha he foregoing is true ‘and correct and that the above-enttled matter is properly fled for assignment to the Los Angeles courthouse in the Central Distt of the Supetor Court of Calor, County of Los Angeles [Code Civ. Proc. § 382 et seq, and Local Rule 2.3, subd. (2). | Dated: December 16, 2015 PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 4. Original Complaint or Petition 2. If fling a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010. 4 Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev. 03/18). Payment in full ofthe fling fee, unless fees have been waived 6. A signed order appointing the Guardian ad Liter, Judicial Council form CIV-010, ifthe plaintiff or petitioner is a minor under 18 years of age willbe required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along with the summons and complaint, or other initiating pleading in the case. Trew 108 Rev aria) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 4 of 4 Sees teresa ree