Pete v. 1501 Certified Entertainment
Pete v. 1501 Certified Entertainment
Pete v. 1501 Certified Entertainment
NO. _______________
Plaintiff Megan Pete p/k/a Megan Thee Stallion (“Plaintiff” or “Pete”) files this Original
Petition against her recording label, Defendant 1501 Certified Entertainment (“Defendant” or
“1501”), seeking a declaration that her album, “Something for Thee Hotties” constituted an
I. INTRODUCTION
1. Over the past two (2) years, Pete and 1501 shared a long and tortured history of
disputes with each other concerning Pete’s recording agreement, including the unconscionability
of the agreement in its original form, as well as disputes concerning the release of Pete’s music.
The two have been able to resolve many disputes through the issuance of multiple temporary
restraining orders and other relief from the 152nd Judicial District Court. 1 But a new dispute has
2. More specifically, on October 29, 2021 Pete released her new album called,
“Something for Thee Hotties”. More than two (2) months after its release, 1501 informed Pete
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Rule 3.2.2 of the Rules of the Civil Trial Division, Harris County District Courts, requires that any matter filed after
a non-suit of a previous filings involving substantially-related parties and claims shall be assigned to the court where
the prior matter was pending.
that it did not consider the album “Something for Thee Hotties” to meet the definition of an
“Album” under her recording agreement and, therefore, allegedly does not satisfy her “Minimum
Recording Commitment” for the second option period under the terms of the parties’ agreement.
1501’s new position, taken months after the album’s release, is clearly a ruse in an effort to try to
take further advantage of Pete, at great expense and not in good faith.
3. Contrary to 1501’s position, “Something for Thee Hotties” clearly meets the
definition of “Album” under the recording agreement because it is not less than forty-five (45)
minutes in length. There are no other parameters or requirements under the contract for what can
be deemed an “Album” other than total run time of the album. As such, “Something for Thee
Hotties” satisfies her “Minimum Recording Commitment” for the second option period of the
agreement. To protect herself, her music, and her artistic choices, Pete has been forced to bring
4. Pete intends that discovery be conducted under Level 3 of the Texas Rule of Civil
Procedure 190.4.
III. DAMAGES
5. Pursuant to Texas Rule of Civil Procedure 47, Pete seeks only non-monetary relief
in the form of a declaratory judgment. Pete further seeks the recovery of attorneys’ fees and costs.
IV. PARTIES
7. 1501 Certified Entertainment, LLC, is a limited liability company with its principal
place of business in Harris County, and it is organized and exists under the laws of the State of
Texas. 1501 Certified Entertainment, LLC may be served through its registered agent, Carl
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Crawford, at 15618 Bristol Lake Drive, Houston, Texas 77070 or wherever he may be found.
8. This Court has subject matter jurisdiction over this dispute and jurisdiction to grant
all relief requested by Pete. TEX. GOV’T CODE § 24.008. The amount in controversy is within the
9. Venue is proper in Harris County because Defendant has its principal office in
Houston, Texas. See TEX. CIV. PRAC. & REM. CODE § 15.002(a)(3). Venue is also proper in Harris
County because a substantial part of the events or omissions giving rise to this claim occurred in
Harris County. See TEX. CIV. PRAC. & REM. CODE § 15.002(a)(1).
10. Pete began her successful rap career right here in Houston, where she was first
11. As a result of Crawford’s misrepresentations and omissions, which were the subject
of prior litigation, Pete signed that certain Exclusive Artist Recording and Performance Contract,
12. The terms of the Contract as originally written were entirely one-sided in favor of
1501, not consistent with industry standards, and wholly unconscionable to the detriment of Pete.
When Pete raised the unconscionable nature of the Contract to 1501 and Crawford, 1501 and
Crawford unlawfully instructed 300 Entertainment, the distributor of Pete's records, not to release
Pete initiated a lawsuit against 1501 and Crawford and obtained a temporary restraining order
(“TRO”) against 1501 and Crawford to ensure that they refrained from preventing 300
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13. In an effort to resolve the parties’ disputes, Pete and 1501 engaged in negotiations
to amend the Contract. On or about March 1, 2021, Pete and 1501 entered into an agreement that
14. The Contract and its Amendment are the subject of an order entered on October 1,
2021 permanently sealing the documents under Texas Rule of Civil Procedure 76a in Cause No.
2020-14018; Megan Pete p/k/a Megan Thee Stallion v. 1501 Certified Entertainment LLC, et al.;
15. The Amendment did not change the definition of “Minimum Recording
Commitment” nor the definition of “Album” from the definitions provided in the original Contract.
16. On October 20, 2021, 1501 exercised its option to extend the term of the Contract
17. On October 29, 2021, Pete released her new album called, “Something for Thee
Hotties”. The total run time on the “Something for Thee Hotties” album is 45:02 minutes. The
album consists of new tracks recorded in 2021, previously unreleased tracks, and skits.
“Something for Thee Hotties” debuted at No. 3 on Billboard’s Top R&B/Hip-Hop Albums chart
18. In every respect, “Something for Thee Hotties” constituted an “Album” and met
her “Minimum Recording Commitment” for 1501’s second option period under the Contract.
C. 1501’s Unlawful Attempt to Chain Pete Down to 1501 for Additional Albums
19. On or about January 5, 2022, 1501 sent a letter out-of-the-blue asserting that the
album “Something for Thee Hotties” did not constitute an “Album” under the parties’ agreement.
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https://www.billboard.com/music/chart-beat/megan-stallion-something-hotties-top-10-rb-hip-hop-albums-chart-
9658786/
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20. Given that 1501 waited more than two (2) months after Pete’s release of the album
“Something for Thee Hotties” to take this position, it is clear that its position is frivolous and has
21. Prior to the release of “Something for Thee Hotties”, Pete and her team took steps
for the clearance of the album that were the same or similar to past practices to which 1501 never
complained about or objected to. Specifically, Pete’s team worked directly with 1501’s distributor,
Theory Entertainment, LLC d/b/a 300 Entertainment (“300 Entertainment”), leading up to the
release of the album “Something for Thee Hotties.” 300 Entertainment knew the list of songs and
assisted with getting several of the songs cleared and sample agreements signed. Moreover, 300
approved of the album and pushed for its release on the night of October 29, 2021. Any objection
after the release of the album is untimely and inconsistent with 1501 and 300 Entertainment’s past
conduct.
22. Pete can only speculate as to the reasons why 1501 has taken this new position. But
the intended result of its actions is clear: 1501 wants to tie Pete down to release more albums
under the Contract to the financial benefit of 1501. This is inconsistent with the Contract terms,
which are clear and unambiguous. Accordingly, Pete seeks a declaratory judgment that, among
other things, declares that her album, “Something for Thee Hotties”, constitutes an “Album” under
A. Declaratory Judgment
23. Pete incorporates by reference all of the foregoing paragraphs for all purposes.
24. This cause of action is brought under section 37.001 of the Texas Civil Practice and
Remedies Code as there is an actual and justiciable controversy between the parties.
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(1) Pete’s album “Something for Thee Hotties” released on October 29, 2021
constitutes an “Album” as defined in the Contract;
(2) Pete’s album “Something for Thee Hotties” released on October 29, 2021
meets her “Minimum Recording Commitment” for the second option period
under the Contract;
(3) The only determining factor as to what constitutes an “Album” under the
Contract is the total run time of the album released, which must be a
minimum of 45 minutes;
(5) 1501 waived its alleged rights to “equal authority” to determine “the
Musical Compositions to be recorded” by Pete.
26. Pursuant to Chapter 37 of the Texas Civil Practice and Remedies Code, Pete is
entitled to recover her reasonable, necessary, equitable, and just attorneys’ fees incurred in the
27. Additionally, pursuant to Section 26(e) of the Contract, Pete is entitled to recover
28. All conditions precedent for bringing this action have been satisfied.
X. JURY DEMAND
XI. PRAYER
For the reasons set forth above, Plaintiff respectfully prays for the following relief:
(1) The Court issues a declaratory judgment making the following declarations:
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2021 meets her “Minimum Recording Commitment” for the second
option period under the Contract;
(2) For reasonable and necessary attorneys’ fees, including contingent attorney’s fees
in the event of appeal;
(4) Such other and further relief, general or special, legal or equitable, to which
Plaintiff may show herself justly entitled.
Respectfully submitted,
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