James Cameron Lawsuit

8/3/2019 James Cameron Lawsuit

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O R I G I N A L

SUPERIOR COURT OF THE STATF: OF CALIFORNIAFORTHE COLNTY OF LOS ANGELES

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~-~---.--.-----.------- -------~-Complaint

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K. Andrew Kent, State Hur No. 130007Gregory N. Alhrighl. State B ar N o. 14:;547R IN CO N V EV llJR E L,,\W GROUP2 R 1 5 Townsgate Rd., Su ite 2 15Westlake Villaue. C alifo rnia 91 36 1Telephone: (lWJ.)557-0580Facsimile: (805) 5570480A tto rn ey s fo r P la in ti ffERIC RY DER

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ER IC RY DER, all individual ))PlainlilT ))vs. ))LlGHTSTORM ENTHnAINMENT, INC .. a )California Corporation: .lAM ES CAM EROK. )an individual; and DOES I through 25. )inclusive, ))Defendants. ))))

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FILEDUPERIOR COURT OF CALIFORNIAC OUN TY O F ,.O S A N GE LE S

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Case No.: B eCOMPLAINT FOR: " 74 8 7 61) BREACH OF IMPLIED CONTRACT;2) fRAlID AND DECEIT; .3) NEGLIGENT MISREPRESENTATION;-l) [\/TENTIONAL INTEIlFEIUSIJECTIVE ECONOMICADVANTAGE

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NATURE OF THE ACTION1. This action arises from the release and exploitation of the motion picture Avatar.

in breach of an implied agreement bctwccn tbat film's producer, Lightstorrn Entertainment. Inc.("LEI"), and Plaintiff Eric Ryder. At its own request. LEI had Mr. Ryder work with it for nearlytwo years on the development of his science fiction story into a production-ready motion pictureenvisioned as an environmentally therned J-D epic about a corporation's colonization and

7 plundering of a distant moon's lush and wondrous natural setting, the corporation's sp y sent tocrush an insurrection on the distant moon among: anthropomorphic. organically created beingspopulating that moon. and the spy's remote sensing experiences with the beings. emotionalattachment to one of them in particular. and eventual spiritual transformation into a leader of the0

1 I lunar beings' revolt against the corporation's mining practices. During the time he worked with: : . 2 LEI on the motion picture's development. Mr. Ryder provided LEI executives not only his

science fiction story, entitled K.R.7. 206R CKRT). hut also further treatments, photographs, 3-14 I D visual representations and imagery, character and scene development, story element and

Il!:; ! production ideas, find screenplay development assistance. in anticipation o r the motion piciures:'6 production. LEl and Mr. Ryder agreed. impliedly. that l.El would not use or exploit any of the:.7 material Mr. Ryder singly. or they jointly, developed in a motion picture, without Mr. Ryder18 sharing ill the commercial receipts and the writer and producer credits. After some two years of~9 enthusiastically working with Mr. Ryder on the films development. LEI pronounced that the20 KRL movie could no t be made because no one would be interested in an environmentally21 themed science fiction real ure film..22 2. In mid-December 2009. LI-:!began its worldwide release and distribution of an23 environmentally themed feature length science fiction movie. titled Avatar, Avatar liberally and

substuruially uses material that fell within the LEl-Ryder agreement. After Avatar's release.Ryder asked LEI to make good on its implied promises to him. LEI has refused. Its refusal,after the release. distribution and theatrical exploitation of Avatar without permission from. orcredit and compensation to. Mr. Ryder. breached LEl's agreement with him. as have subsequent,additional and derivative exploitations ofAvolar. including but not limited to DVD releases of

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1 th e mo vie ... ,.L In 20) l , M r. Ryder learned . through an LEI re pr es en ta ti ve , th at D e fe nd an ts

.:, contend Avatar is owned solely by producers that do not include him ; that Avatar was,

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s up po se dly . w ri tte n s ole ly by James Cameron: and that Mr. Cameron, supposedly, had prepareda full scriptmcnt for Avatar before the 1999 ti me p er io d in which r ,E I was, on information an dbelief, first prov id ed w ith the K R7. story. Mr. R yd er is inform ed and believ es that L Ei'scontentions arc false. in whole or in part. 011 the lim e period the A vatar scriptm ent w as w ritten,

8 the scriptm enr's content, and irs state of developm ent as of 19(1). At the same time. M r. Ryderplead s in the alternativ e that. based 011 the statements LE[ conveyed to him in 20 II, to the extentL EI's contentions are true, D efendants perpetrated a fraud on M r. R yder and engaged in otherwrongfu l conduct: they induced him to believe L EI was working w ith him in good faith forsom e tw o YC8rs on KRZ's developm ent into a motion picture. On information and belief, theyd id so as a sham project. one fashioned by them to su rreptitiou sly ad vance the interests of L EI

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1314 . and M r. Cameron in Avatar and fu rther refine their d ev elopm ent of that film project. all the15 w hile intend ing to prev ent or delay a substantially sim ilar mov ie, KRZ, from going into16 produ ction with any com petitor of L EI.17 PARTIES

4. Plaintiff L ric R yd er is an ind iv id ual resid ing in O jai, V entu ra C ou nty, C alifornia.5 . M r. Ryder is inform ed and believes and therefore alleges that D efendant L EI is a

20 California corporation conducting business ou t of offices located in Santa M Ollica, L os Angeles21 County , Ca li fo rn ia .

6 . On inform ation and belief: D efendant Jam es Cam eron is an ind iv idual whoZ} resid es in L os A ngeles C ou nty. C alifornia.:~ 4 I 7. M r. Ryder is ignorant of the True names and capacities of D efendants sued as?~. D OES I through 25. inclu sive. and he therefore su es these D efend ants by their fictitiou s nam es.Lt. O n inform ation and belief, each of the fictitiou sly nam ed Defendants is responsible in som e')7 m anner C ur the occu rrences alleged in this C om plaint. and by their cond uct proxi m ately cau sed2c ( M r. Ryder's damages. M r. Ryder w ill amend this Complaint to allege the true names and


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capacities of Defendants DOES through 25 when ascertained.II!

ALLEGA nONS COMi\'ION TO ALL CALISES OF ACTION8. In 1997 and 1995, Plairui ITEric Ryder developed a story and wrote a treatment

entitled K.RZ. 2068 CKRZ"}.9. In February 1944. Mr. Ryder submitted his KRZ treatment to Andrew Wald, a

8film producer with Wald Pictures in Los Angeles. Wald expressed interest in co-producing KRZas a feature film.

10. On information and belief: during J 999. Wald discussed the KRZ project on Mr.10 Ryder's behalf with L EI dev elopm ent executiv e Jay Sanders. who likewise expressed interest in

developing KR7. as a feature film. On information and belief, KRZ was circulated within LEI;1senior executives and decision-makers within LEI. including James Cameron, Jon Landau andRae S anch in i became intimately familiar with the KRZ project. including the story anddevelopment material. On information and belief. Cameron, Landau and Sanchini also wereintirnatclv involved in th e development and production 01';11'(//((1'.I

.15 II. Messrs. Ryder and Wald, and Walds associate Toni Baffo, worked together with17 Sanders, who was acting as LEI's representative. to further develop a motion picture based on1B the KRZ treatment. During this period, at Sanders request on behalf of LEI, Mr. Ryder worked19 on numerous story draft!,; lind created additiunul content that was provided to LEI. Mr. Ryder2C also submitted to Jay Sanders 3D imaging material, photographs and visual representationsz i which depicted what Ryder envisioned certain scenes and settings to look like fo r the proposed;,,:; motion picture. including without limitation scenes of Jupiter and her moons looming in the:'] background, self-contained robotic exterior suits which house a single human operator, and24 bioluminescent nature scenes that playa role in the KRZ plot development. On information and2 : : belief, Sanders circulated these photographs and visual representations to other senior executives26 and decision-makers within I,FL

12. In late summer :2000, Sanders asked Ryder In work with Stuart Hazeldine, a728 registered screenwriter, who was commissioned pursuant to the KRZ project to prepare a

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screenplay based on KRZ. In the summer of 200 I. Hazeldine submitted his first draft storytreatment to U = : 1 . based upon Ryder's most recent story revisions. creative material andsuggestions. The Hazeldine story treatment draft was circulated within LEI and creative noteswere generated in order for a screenplay 10 be prepared.

13 , The process continued until the final screenplay draft was completed andsubmitted to LEI in the fall 01'2001. On information and belief. the final screenplay draft wascirculated to senior executives and decision-makers within LEI.

14. During the process described above. Mr. Ryder visited LEI's officesapproximately six times. The final meeting at the end of200 I was attended by Ryder, Wald,Buffo, Sanders and. on inform ation and belief. other L E T senior executives and representatives/that included Rae Sanchini and Jon Landau. Hazeldine participated in the meeting byspeakerphone.

15. From about 2000 to 2001, Mr. Ryder as well as Andrew Wald (on Ryder's behalf)presented KRZ to Defendants. their agents and employees. including Sanders. Hazeldine,Landau and Sanchini, Those agents and employees of Defendants were acting within the courseand scope of such agency and employment. and with the permission and consent of theDefendants, an d all of them .

16. Mr. Ryder presented and disclosed KRZ to the Defendants, and their agents andemployees. in confidence and with the expectation and understanding that he would becompensated and receive writer and producer credits. in the event any of the KRZ developmentproject's material was used in a motion picture released for commercial distribution.

17. 1 \ 1 1 ' . Ryder's presentation and disclosure of the KRZ story, production materialsand film development project to Defendants and their agents and employees was consistent withthe well-established customs and practices of the entertainment industry, and on the conditionthat the ideas and concepts presented by Ryder would not be disclosed or exploited withoutRyder's consent and Ryder's receipt of appropriate compensation and ~redit.

18. At no time was Mr. Ryder asked to sign, nor did he sign, any document thatwaived his rights or assigned any right, Litle o r interest in KRZ or the project to LEI. Nor did

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LEJ ever compensate Mr. Ryder for KRZ or his services. The parties' clear understanding W


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21. The KRZ project an d Avatar have many striking similarities, including elementsof the synopsis above. Among other things. in both KRZ and Avatar:

3-D effects infuse the story, and ill particular the faraway moon's environment: The protagonist is retained by a large corporation (0 do its bidding: The protagonist has suffered personal hardship, and the loss of a close loved-one, whichhave made the protagonist a lone wolf. who is receptive: to the corporation's proposal: The earth-based corporation asks the protagonist to travel to a faraway moon of a distantplanet for a mission;

The corporation has reached into and has colonized d eep space to m ine a su bs tan ce o r10 incredible value:

The protagonist is offered enormous compensation in exchange Ior helping the1

13 12 corporation to maximize productivity of its mining operation;

The corporation has created and utilized anthropomorphic creatures that are able to move14 about in and experience the alien environment, and the protagonist is able to connect with these15 creatures to share sensory data and share the creature's real-time sensory experiences;16 T hrou gh the protagonist's sharing of the creature' S sensory experiences, th e protagonist17 was able to directly p erc eiv e th e b eau ty and richness of the ind igenou s w orld ;

Sensory experience is shared through loeb o r hair at the back o r the head, through a(; 19 filament, or pony-Iuil connection, and this occurs between the protagonist ami the

21 formed:20 anthropomorphic native of the moon world. with v\'l1()111 an emotional and romantic bond has

22 The protagonist and other characters also experience powerful connections to the

2~ /..1 indigenous world and its bioluminescent life forms;

The lush and fantastical environment-c-on a distant moon-plays a central role in the25 story:26 The protagonist escapes from danger in th e moon's lush environment by pi unging

z s 27 through a torrent of water:

A character is envisioned to be played by or styled after Sigourney Weaver:

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The protagonist used a digital diary 10 record experiences: The corporation' s mining practices haw been incredibly destructive, but the corporation

3 feels no responsibility to limit its impact on the environment in its ever-increasing demand for

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maximum productivity and profits: The corporation creates great incentives Corincreased production:

The lead on-si to corporate actor refuses ttl accept low production, has quarterlyproduction goals, and resorts to extreme tactics to achieve those goals; The corporation's mining practices arc dangerous, but the corporation views the lunarbeings lind indigenous environment us expendable, and violence is used to set an example; The protagonist's growing appreciation l?r the natural environment leads the protagonistto turn against the death and destruction represented by the corporation;

There is a recurring theme of studying and learning to appreciate the indigenous nature.

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l3 and scientific cataloguing of alien spec it's:I One-man vessels or suits (with a scaled interior environment for the human operator)

!5 w ith fu nctio ning I im bs that mimic the operator's m ov em ents, arc used for performing th e1 e , corporation's tasks in the alien environment: There is an increasing and ultimutely foreboding threat to continued existence of natural

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: B environment creates anxiety for the characters, am! suspense f(IT the audience;The protagonist ultimately becomes completely sympathetic to the lunar beings, and

2C becomes one of them; and71 There is a happy ending, with the protagonist taking a leading role in preventing then corporation from achieving its destructive objectives and protecting the natural indigenous23 environment.

n. Mr. Ryder is informed and believes and therefore alleges that the substantial2:' similarities between Avatar and KRZ arc no mere coincidence. On information and belief. LEI2~ is the production company uf James Cameron, the director lI r :tVOlW' who also claims to haven created an Avatur "scriptmeut" and screenplay, Mr. Ryder is informed and believes. and pleads: % i < in the alternative, that one of two things (l1I" some combination of two things) must he true;......,-,---,,-1

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either:2 (A) any scripuncnt of Avatar that was in existence in 1999 d id not yet include the

elem ents of K RZ that arc su bstantially sim ilar to the AWI/ar motion p ictu re th at w as u ltim atelyreleased, and LEI breached it s implied-in-fact contract with Ryd er. an d b reach ed its duty ofcon fid entiality , b y disclosing KRZ and R yd er's related prod uction m aterial, concepts. and id easto Cameron, for purposes u nrelated to the advancement of the KRZ project, who then claimed

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the material as his own;

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(B) L EI indu ced R yder to enter into an im plied -in-fact contract regarding d ev elopm ent ofKRZ as a m otion picture, and induced Ryder to disclose his KRZ treatm ent, co ncep ts ami ideasto LE I. th ro ugh frau d: specifically, R yd er is informed and believ es and therefore a lle ge s th at LEInever intended to develop KRZ as a m otion pictu re, and its representations to R yd er to thec on tra ry w er e false, m ade for the pu rpose of inducing Ryder 10 take hi s potentially competitivestory and [ilm project ou t of the m arket lor a period of time su fficient to allow D efendants to getAvatar i n p roduct ion before Ryder, Wald and another studio could pu t KRZ into development;

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or16 (C ) L EI ind uced R yd er to en ter in to an im plied -in -fact co ntract reg ard ing d ev elo pm en t

of KRZ as mo ti on p ic tu r e, with the secret objective of apprupriating and incorporating Ryder'sstory. 3-D production ideas and material as it saw fit lor lise in L EI's nascent Avatar project,nev er intending in good faith to facilitate the prod uction of a film that w ould be su bstantially

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22 FIRST CAUSE OF ACTION(B reach of Im plied C ontract. against L EI)

23. Ryder incorporates by reference paragraphs 1 throu gh 2 2 above.25 24. In abou t 2000 2001. P la in ti ff I':r ic Ryde r and D efendant L EI established an2G im plied -in -fact co ntract. as Sh (HVn by their conduct. whereby L EI agreed to a c ce p t Ryder's: < . , presentations ofKRl and to d ev elop K RI.. into a m otion pictu re only w ith Ryder's consent and2 ~ with com pensation and cred it to Ryder. At LEI's requ est, 'v Ir. R yder physically, orally and in

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",writing provided and disclosed KRZ and related 3-D imagery visualizations, ideas, concepts,story. character an d scenery elements, photographs, artistic renderings. graphic presentations.a nd o th er materials to L I 'J lind its authorized agents and r ep r esent at ive s .

4 25. M r. R yd er submitted KRZ and disclosed hi s material, ideas and creat ive concepts5 for KR7. to LEI pursuant to the standard custom and practice in the motion picture industry with6 respect to the exchange of creative material an d ideas. and on the condit ion and with the

understanding that: (AJ Ryder's disclosure o r KRZ and related material, ideas and concepts was

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for the purpose of inducing LEl to become interested in KRZ and to produce KRZ as a motionpicture; (3 ) Ryder expected to be : compensated an d receive credit for an y US~ or exploitation ofKRZ by LEI; (C) LU would not exploit or cause or assist any other person or entity to exploitKRZ w ith ou t o bta in in g Ryders consent. giving him credit, and compensating him; and (0 )

12 Ryder presented KRZ and disclosed his material, ideas and concepts related 10 KRZ to LEI andI " I its agents and representatives in confidence, with the expectation and understanding that LEI14 would use the disclosures and its working relationship with Ryder only for the good faith15 objective of furthering the development of KI{L into a feature length motion picture. not for16 other purposes,17 26. LEI demonstrated and implemented the implied-in-fact contract through itsI ~ intentional conduct, including the following:19 In early 2000. Sanders. Oil behalf of LEI. accepted Ryder's submission and disclosure of20 the KRZ treatment, and said LEI was interested in developing KR7, as a feature film:2~ Sanders, on behalf of Lr.l, worked with Ryder. Wald and Baffo to lurther develop a22 motion picture based on Ryder's KKI. treatment;23 Sanders. on behalf of LEI, acti vel)' encouraged Ryder to work on numerous story drafts24 to creak additional content and production material. and to submit photographs and visual25 representations that depicted what Ryder envisioned certain scenes ami settings 10 look like;20 Sanders, on behalf of I,IT asked Ryder to \vork with Hazeldine tu prepare a screenplay27 based on KRZ, and LEI commissioned Hazeldine to prepare that screenplay;28 LEI caused KRZ, story drafts. screenplays based on KRZ. and related materials to be

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31. Ryder incorporales by reference paragraphs I through 30 above.In or abou t Febru ary ~O OO .in II m eeting at L EI's Santa M onica offices, LEI,

I iIII Icircu lated w ithin I.F I for rev iew hy I.F .I senior execu tiv es and d ecision-m akers: and LEI representatives. including Sunders and. Oil information and belief. Rae Sanchini and

3 \1 Jon Landau . mel personally with Ryd er at LEI's offices for the purpose o r developing KRZ into

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27. The conduct of M r. Ryder and LEI alleged above \-\'US intentional. and Ryder anda feature film,

LEI each knew , or had reason to know . that the other party would interpret their conduct as anagreement 10 enter into a contract. An implied-in-fact contract betw een M r. Ryder an d LE I was

8 created. as herein alleged.2X . M r. Ryd er has perform ed all cond itions. cov enants. and prom ises requ ired on hi s

1 n pan to be performed in accordance with the terms and cond itions o r h is im p lie d-in -f ac t c on tra ct1] with LEI.12 I 29. Mr. Ryder is informed and believes and therefore alleges that LEI breached it s131 contract w ith him by, am ong other things. (A ) u sing and exploiting, and cau sing or assistinglq I others to u sc and exploit. KRZ and Ryder's related ideas and concepts in a motion picture15 I released as Avatar: ('8) failing to lise Ryder's submission of KRZ and related material. ideas andI,Is ) concepts, lor the purpose of g oo d faith development of KRZ into a motion pictu re; and (C)17 failing 10 com pensate M r. Ryder. share with him the receipts and profits from the exploitation ofH KRZ. or give him writer and p ro d uc er c re dits .

;;0 and w ill continue to su ffer damages and lost profits in an amount 10 be prov en at trial.30. As a direct and proximate result of LEI's breach of contract, Ryd er has suffered

2: SECO.'iD CAUSE OF ACTION22 (Fraud and D eceit. against L EI)

32.2: , through Jay Sanders. m ad e the m aterial representation to Plaintiff Eric Ryder that LEI was


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KRZ as a m otion picture in which Ryder would participate, receive credit, and receive a share o rits receipts and profits from exploitation, and to use Ryder's story. treatment, creative materialsand future submissions only for the purpose or furthering their joint development project. Inmaking this representation. LEI did not disclose the following facts, among others, which LEI

'J has represented in 2011 us true: that l.El us ofthe time ofthe representation already possessed aIS fully developed scriptment supposedly prepared by James Cameron for a film project called

Avatar that was substantia lly similar 10 KRZ. and thai LEI fully intended to prepare Avatar for3 film production. Nor did LEI disclose that it would no t produce or facilitate a film such as KRl.

that was substantially similar to the A \ '(I1aI" SCript111ClItLEI noll' contend s was already developedprior to 2000; nor that LEI intended to secretly share KRZ and Ryder's submissions with James0Cameron for the purpose of surreptitiously assisting Cameron' s conti nuing development of this

}2 film project called A vatar. as LEI and Cameron saw fit. without the knowledge or participationo r Ryder. Tilt: facts known.io LEI. but not disclosed to Mr. Ryder at the time of Sanders'3

15representations to him, were material. and their withholding made Sanders' representationsmisleading. LEI knew these affirmative representations and omissions of fact were false andmisleading; or, it made them recklessly, without regard for their truth and their likely impact onERyder.

.8 33 . Mr. Ryder relied on the representations Sanders made on behalf of LEI. He was19 induced to believe that he had entered into ajoint project for the development of an20 environmentally therned feature length science fiction movie based on KRZ. Over the course of2l roughly two years, based on Ja y S an de rs ' re pre se nta ti on s on behalf of LEI, Eric Rydern committed his time and labor. and his story. to what he believed was a good faith joint23 development project with LEI.24 34. On inforruation and belief. LEI intended for Ryder to rely on Sanders'/:5 representations and withholding of material information.

35. On information and belief as a pretext to cover up its use of the KRZ film projecin bad faith for the purpose of surreptitiously aiding the development of Avatar, LEI conveyed toMr. Ryder in 2002 the supposed assessment that an environmentally themed feature length

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2science fiction movie, such as KRZ. would 110t be accepted by the movie-going public, and torthis reason LEI would not he able to continue with production ofKRZ. LEI conveyed this

3 assessment while knowing this. too, was false and misleading.36. As 1 1 proximate result o r LEI's false representations and omissions as to material

.~ facts, compounded by its effort in 2002 tu continue to mislead Mr. Ryder about its true intent tocovetously assist and se cu re th e exclusive development of the supposed Avatar project. withoutcompetition, Plaintiff futilely devoted two years of his lire to what was, unbeknownst to him. a1

8 sham project He lost the opportunity to sell his project to another film production company, andlost his working relationship with film producer Andrew Wald. Plaintiff has suffered tort

10 damages in an amount to be proven at trial.37 . LEI's conduct as described above was malicious. oppressive and fraudulent1

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THIRD CAUSE OF ACTlON14 (Negligent Misrepresentation, against LL::Iand Does 1 through 25)

Ryder incorporates by reference paragraphs 1 through :n and 35-36 above,LEI 's representations to Mr. Ryder were made despite LEI's possession or facts

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: 0 ' showing them to he false and misleading. Llil negligently misrepresented to Ryder that it \\'3S in18 good faith entering into a joint project for the development of an environmentally therned feature: ~ length science fiction movie based 011 KRZ, without conflict with a supposedly fully or partially

Id .?C cvcloped Avatar scnptment.21 fOURTH CAUSE OF ACTION22 (Intentional Interference with Prospective Economic Advantage,23 Against LEI. Cameron and Does 1 through 25)

Ryder incorporates by reference paragraphs I through 39 above.l\s o r 11.)99, Film producer Andrew Wald agreed to work with Plaintiff Eric Ryder5

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to co-produce KRZ as a motion picture, in association with a studio or other film productioncompany. Plaintiff had a reasonable expectation of future economic benefits through Mr. Waldsagreement to particip.ate in the production of KRZ a feature length film.':8


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42. L Et and . On inform ation and belief, Defendant James Cameron, were aware that2 Mr. Ryder and Mr. Wald had an actual and prospective economic relationship and advantage:3 1 concerning the development of KRl into a fC3ture length film.4 I 43. LEI and Defendant .larnes Cameron engaged in wrongful acts intended to disrupt6

th e p ro sp ec tiv e ec on om ic relationship between Ryder and Wald ; or, at the least, they pursuedthese wrongful acts with reckless disregard for the interference they would cause to Plaintiff'sprospective economic relationship w ith film prod ucer A nd rew Wald.

44. Th e wrongful acts of LEI. Defendant James Cameron, and Doe Defendants 1'l through 25, directly or in concert, did in fact interfere ill and disrupt the prospective economic10 relationship between Ryder and Waldo11 45. As a proximate result uf the acts of interference by Defendants. Plaintiff Eric12 Ryder has suffered tort damages in an amount 10 be proven at trial.13 46. The acts of interference. intentionally undertaken by LEI and Mr. Cameron, were14 fraudulent, malicious and oppressive.15 FIFTH CAUSE OF ACTION16 (Negligent Interference with Prospective Economic Advantage,1" Again st L EI. C am ero n and Docs I through 25)18 47.

48.Ryder incorporates by reference paragraphs I through 42 and 44-45 above,LEI, James Cameron and Does 1 through 25 were negligent in engaging in the9

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4 . That RYD I::R be awarded punitive damages in an amount su fficient to punish,2 deter. and make an example of Defendants for their conduct alleged herein;3 5. That the Court award R Y D ER such further relief as the Court deems just and

proper.5 Respectfully submitted,

RINCON VENTURE LA W GROUPDated: December 8, 2011'7

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K. Andrew KentAttorneys for PlaintiffERIC RY DER

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-,_: TTORNEYOR PARJY lMTHOUT A110flNEY IN."",. Si...\> e a r pU"'O


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St,OR r TITLE: Ryder v . Ughtstorm Entertainment

CIVIL CASE COVER SHEET ADDENDUM ANDSTATEMENT OF LOCATION(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This form Is required pursuant to Local Rule 2,0 in all new Civil case fil ings in the Los Angeles Superior Court. JItem I. Check the types of hearing and fill in the estimated length of hearing expected for this case:JURY TRIAL? ill YES CLASS ACTION? n YES LIMITED CASE? 0YES TIME ESTIMATED FOR TRIAL 5-6 0 HOURSI '! :J DAYS

Item II. Indicate the correct district and courthouse location (4 steps - Ifyou checked "Limited Case", sk.ipto Item III, Pg. 4):

Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for yourcase in the left margin below. and, to the right in Column A, the Civil Case Cover Sheet case type you selected.Step 2: ChecK~ 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 court location choice that applies to the type of action you havechecked. For any exception to the court location, see Local Rule 2.0.! Applicable Re.~~ons for Choosing Courthouse Location (see Column C below)1, Class actmns must be filed in the Stanley Mask Courthouse. centrat.oismct.2 . May be l iled in cenuai (other coun ty . or no !ladil)' injury/property camaqo).3. location where cause of action arose.4. location where bodily Inj ll ry, o ea tn o r damage occurred.5. t . c cancn where performance required or defencant resides.

6. location of property' or permanently garaged vehicle.7. Location where petit ioner resides.8. location wherein defendantrrasponoent lunctions wholly.9. ~ocat ion where one or more of (he part ies reside.10. Location of labor Commissioner Office

Step 4: Fill in the information requested on page 4 in Item III;complete Item IV. Sign the declaration.

A B CCivil case Cover Sheet 1ype ot /I.clion Applicable R eason s Category No. (Check cnt~ one) See Step :lAbove

Auto (22i 0 A7100 Motor Vehicle - Personal lnjuryrProperty DamageiWrongFul Death 1 .. 2 . . 4."""

Uninsured Motorist ("-6) 0 A7110 Personal Injury/Properly DarnagalVVronglul Death - Uninsured Motons! t .. 2 . . 4 .

0 A60JO Asbestos Pr:.>pe.ly Damage 2.Asbestos (04) 0 A7221 Asbestos - PersonallnjurylWronglul Dealh 2.Product Liability (24) 0 AnSO Product Liability Inot asbe sics or to~icJen\lironmental} 1" 2.. J..4.. B.

C 1 A7210 Medical Malpractice - Physicians & Surgeons 1..4.Medical Malpractice (45) 0 A7240 Other Prcfessicnat Health Care Malpractice 1.. 4 .

0 A7250 Premises l iabi li ty (eg . . s lip and fal l) 1..4.OtherPersonal Injury 0 A7230 Intentional Bodlly InjurylPropeny DamageN~rongfLJI Death (e.g. , 1.. 4 .Propeny Damage assault. v an da lis m. e tc .)\/'Jrongful Daath 0A7270 Intentional lnll ietion of Emotional Distress 1..3.( 231 1.,4.0 A722 0 Other PersonallnjurylProperty OamageiWrongful Dcalh

CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATIONLi\CIV 109 (Rev. 03111)LASC AoprOV1'ld 0304 Local Rule 2.0Page 1 o f 4


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C~NU\l9ERI .f O RT I IT : .. E Ryder v. Lightstorm Entertainment

A B CCivil Case Cover Sheet Type of Action Applicable Reasons -Category No, ICheck only one) See Step 3 AcoveBusiness Tot1 ( U 7 ) 0 A6D29 Olher Commercial/Business Tort (not fraudlbreach 01 contract] 1,,3.Cilill Rights (08) 0 A600S Civil Rignts'Discliminalion 1., 2 .. 3,

Delamatior, (13) 0 AG010 Defamation (slander,1ibel) 1..2, a .Fraud (16) 0 ABO' 3 Fraud (no contract) I .. 2 .. 3,

0 AG017 Legal Malpractice '"2,, 3ProfeSSional Neglige,'l


19/20

CASE " 'UMBERf1O~f fIT ..E. Ryder v. Lightstorm Entertainment

A B CC'vil C ase C ove r Sheet Type 01Action Applicable Re~sons -Category No. (Check only one) See Step 3 AboveAsset Fotfeiture (05) 0AS10e Asset For.eHu,,, Ca." 2 . . U .

Petitio n re Arbitration p 1) 0A6115 Petition to CompcliConr,nnNacote Arbitration 2" 5.0A6151 Writ - Administrative Mandamus 2 . . S.

Wril of Mandale (02) 0A6152 Writ - Milndamu5 on Limlted Court Case MaUer 2.0 A6153 W,il - Other Limited Court Case Rev iew 2.

Other Judicial Review ( 3 9 ) 0A6150 Other Wr it (Judicia I ReYlew 2..8.AnlitrusVTrade Regulation (03) 0 A6003 AntitrustlTracie RegulatIOn 1,2 .. 8.

Construction Defect (10) 0A6007 Cor - s t ruc t l cn Defect 1. 2.,3.Claims Involving MilSS Tort 0 ".6006 Ciaimll Involving Mass Tort I" 2.. e.(40)Securities Litigation ( 281 0 A6035 Securities Litigation Case 1. 2 . . 1 1

ToxiC To,1 0 A6036 Toxic TortlEl'lvironmental 1.2 .. 3 .. B .Environmental (30)Insurance Coveraqe CI


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SHORttlTLt: CASE NUMBERRyder v. lighlslorm Entertainment

Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or othercircumstance indicated in Item I I., Step 3 on Page 1, as the proper reason for filing in the court location you selected.

AOORESSREASON: Check tho appropriate boxes for tho numbers shownunder Column C for tho typo of action that you have seloctod fo' 1i1 North Hil l Streetthis caae.

01.t:2i2. 03. 04. 05. 06. 07. DB. 09.010.OT"Y' SlATE Z IP C O D E Ios Angeles CA 90012 II tem IV. D e cl ar at io n o f A ss ig nme n t: I declare under penally of perjury under the laws of lhe State of Cali fomia thai the foregoing is t rueand correct and that the above-entitlec matter is properly filed for assignment to the Stanley Mosk courthouse in the

Central District of me Superior Court of California. County of Los Angeles {Code Civ, Proe.,392 et seq. , and LocalRule 2.0. subds. (b), (e) and (d)].

Dated: 1 2 1 _ 8 / _ '_ ' _

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLYCOMMENCE YOUR NEW COURT CASE:

1. Original Complaint or Peti tion.2. If filing a Complaint, a completed Summons form for issuance by the Clerk.3 . Civil Case Cover Sheet. Judicial Councll form CM-OW,4. Civi! Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.03111,.5. Payment in full of the filing fee, unless tees have been waived.6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-Ol 0, if the plaintif f or petitioner is aminor under 18 years o f age wil l be required by Court in order to issue a summons.7. Addit ional copies o f documents to be conformed by th e Clerk, Copies o f the cover sheet and this addendummust be served along with the summons and complaint, or other initiating pleading in the case.

LACtV 109 (Rev. 03/1' )LASe Approved Ol-04

CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATION

Local Rule 2.0Page 4 of 4

James Cameron Lawsuit

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