1 A. Barry Cappello, Bar No. 037835
J. Paul Gignac, Bar No. 125676
2 Troy A. Thielemann, Bar No. 174276
CAPPELLO & McCANN LLP
3 831 State Street
Santa Barbara, California 93101
4 Telephone: (805) 564-2444
Facsimile: (805) 965-5950
5
Attorneys for Defendants and Cross-Complainants
6 Courtney Love and Doll Head, Inc.
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES
10
11 GEFFEN RECORDS, INC., and UMG ) Case No. BC 223364
RECORDINGS, INC., )
12 ) [Action filed 1/19/2000]
Plaintiffs, )
13 ) [Assigned for all purposes to the
v. ) Honorable Fumiko Wasserman]
14 )
COURTNEY LOVE, ERIC ) CROSS-COMPLAINT FOR:
15 ERLANDSON, DOLL HEAD, INC., a )
corporation, and DOES 1 through 10, ) (1) Injunctive Relief Re
16 inclusive, ) Labor Code 2855(b)(3)
) (2) Unfair Competition
17 Defendants. ) (3) Restraint of Trade
) (4) Antitrust Violations
18 ________________________________ ) (5) Declaratory Relief Re
) (6) Rescission of Agreements
19 ) (7) Breach of Contract
COURTNEY LOVE, DOLL HEAD, ) (8) Breach of the Implied
20 INC., a corporation, ) Good Faith and Fair
) (9) Intentional
21 Cross-Complainants, ) (10) Concealment
) (11) Fraudulent Nondisclosure
22 v. ) (12) Breach of Fiduciary Duty
) (13) Accounting
23 GEFFEN RECORDS, INC., a ) (14) Unjust Enrichment
corporation, UMG RECORDINGS, ) (15) Imposition of Constructive
24 INC., a corporation, )
SNIPPETS:
Attorneys for Defendants and Cross-Complainants
Cross-complainants Courtney Love and Doll Head,
support after a reasonable opportunity for further investigation
illusory and impossible-to-14
breaching the contract in order to unjustly enrich itself at the
California Business & Professions Code 17200.
UMG claims to be the successor-in-12
therefore sue said cross-defendants by such fictitious names.
marketing and distribution of rock
agreement with Geffen,
the Inducement Letter agreement, as of July 1, 1992.
and to deliver to Geffen certain master recordings for LPs
such a delivery schedule was
gap between releases for rock artists.
artists and monumental profits for the record company.
record companies withhold marketing support.
Universal eliminated entire record labels.
One example of such fraudulent reporting,
Record clubs are companies which sell records to
cross-complainants by, inter alia, systematically rendering false
concealment of the true facts,
loss of royalties and other compensation;
applies to recording artists, threatens the music community.
preserve their current unfair and inefficient business practices.
herein by reference each and every allegation contained in
paragraphs 1 through 62, inclusive, as though fully incorporated
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