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1 Ethan Preston (263295)
PRESTON LAW OFFICES

2 4054 McKinney Avenue, Suite 310 ELECTRON ICALLY
Dallas, Texas 75204 FILED
3 (972) 564-8340 (telephone) Superior Court of California,
(866) 509-1197 (facsimile) County of San Francisco
4 [email protected] 07/12/2017
Clerk of the Court
5 [Additional Counsel Listed on Next Page] BY:JUDITH NUNEZ
Deputy Clerk
6 Attorneys for PlaintiffAngelica Cosio, on her own

behalf, and behalf of all others similarly situated
7
8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA

9 CITY & COUNTY OF SAN FRANCISCO
10
11
12
13 ANGELICA COSIO, an individual, on her No. CGC-16-551337

own behalf and on behalf of all others
14 similarly situated, EXHIBITS D THROUGH I TO
DECLARATION OF ETHAN PRESTON
15 Plaintiff, SUPPORTING PLAINTIFF ANGELICA
COSIO'S MOTION FOR CLASS
16 v. CERTIFICATION
17 INTERNATIONAL PERFORMING The Honorable Curtis E.A. Karnow
ARTS ACADEMY, LLC, a California Department 304
18 limited liability company, BARBIZON Civic Center Courthouse
SCHOOL OF SAN FRANCISCO, INC., a 400 McAllister Street
19 California corporation, LION San Francisco California 94102
MANAGEMENT GROUP INC., a
20 California corporation, ANTHONY Date: To be determined
LOUIS LIONETTI, LARRY D. Time: To be determined
21 LIONETTI, LENA QUESADA
LIONETTI, LENA M. LIONETTI, and Complaint Filed: April 6, 2016
22 DOES 1-100, inclusive,
Defendants.
23
24
25
26
27
28
Exhibits to Preston Declaration No. CGC-16-55133
Randall B. Aiman-Smith (124599)
Reed W.L. Marcy (191531)
Hallie Von Rock (233152)
2 Carey A. James (269270)
Brent A. Robinson (289373)
3 AlMAN-SMITH & MARCY, P.e.
7677 Oakport Street, Suite 1150
4 Oakland, California 94621
(510) 817-2711 (telephone)
5 (510) 562-6830 (facsimile)
[email protected]
6 [email protected]
[email protected]
7 [email protected]
[email protected]
8
Zack Broslavsky (241736)
9 Jonathan A. Weinman (256553)
BROSLAVSKY & WEINMAN, LLP
10 1500 Rosecrans Ave., Suite 500
Los Angeles, CA 90266
11 (310) 575-2550 (telephone)
(310) 464-3550 (facsimile)
12 [email protected]
[email protected]
13
David e. Parisi (162248)
14 Suzanne Havens Beckman (188814)
PARISI & HAVENS LLP
15 212 Marine Street, Suite 100
Santa Monica, California 90405
16 (818) 990-1299 (telephone)
(818) 501-7852 (facsimile)
[email protected]
18
Attorneys for PlaintiffAngelica Cosio, on
19 her own behalf, and behalf of all others
similarly situated
20
21
22
23
24
25
26
27
28
Exhibits to Preston Declaration No. CGC-16-551337
INDEX OF EXHIBITS TO
2 DECLARATION OF ETHAN PRESTON
3 DESCRIPTION
4 A Assem. Com. on Arts, Entertainment, Sports, Tourism,
and Internet Media., Analysis of Assem. Bill No. 1319 as
5 amended April 15,2009 (2009-2010 Reg. Sess.) April 28,
6
2009
B Excerpts of Federal Trade Commission Response to
7 Cosio's October 25,2016 FOIA Request
C Cosio's RF As with Appendix
8
D Cosio's Motion to Compel MPA
9 E Defendants' RF A Responses
F Defendants' Form Interrogatory Responses
10 Defendants' Special Interrogatory Responses
G
11 H Defendants' Brochure as Produced (LIONOO450-
LION00461)
12 I Defendants' Contracts as Produced (LION00349-
13 LION00352, native Winter 2014 contract,
LION00939-LION00940, LION00996-LIONOI009,
14 "IPAS CA FEB 13.pdf', "IPAS CA June14 (2).pdf')
J, Part 1 Excerpts of Defendants' Talent Directories as
15 Produced (LION00511-LIONOO711)
16 J, Part 2 Excerpts of Defendants' Talent Directories as
Produced (LION00713-LION00796)
17 J, Part 3 Excerpts of Defendants' Talent Directories as
Produced (LION00802-LIONOO867)
18
J, Part 4 Excerpts of Defendants' Talent Directories as
19 Produced (LION00868-LION00921)
K Defendants' Industry Professional Agreements as
20
Produced (LION00463-LION00478; LION00993-
21 LION00995; LIONOIOIO)
L Preston Law Offices Firm Resume
22 M Defendants' Demand for Production Responses
23
24
25
26
27
28
EXHIBIT D
Zack Broslavsky (241736)
Jonathan A. Weinman (256553)
2 BROSLAVSKY & WEINMAN, LLP
11620 Wilshire Boulevard, Suite 900
3 Los Angeles, California 90025
(310) 575-2550 (telephone)
4 (310) 464-3550 (facsimile)
[email protected]
5 [email protected]
6 David C. Parisi (162248)
Suzanne Havens Beckman (188814)
7 PARISI & HAVENS LLP
212 Marine Street, Suite 100
8 Santa Monica, California 90405
(818) 990-1299 (telephone)
9 (818) 501-7852 (facsimile)
[email protected]
11 [Additional Counsel Listed on Signature Page]
12 Attorneys for Plaint(/JAngelica Cosio, on her own
beha(f, and behalf of all others similarly situated
13
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
14
COUNTY OF SAN FRANCISCO
15
ANGELICA COSIO, an individual, on her No. CGC-16-551337
16 own behalf and on behalf of all others
similarly situated, PLAINTIFF ANGELICA COSIO'S
17 MEMORANDUM OF POINTS AND
Plaintiff, AUTHORITIES SUPPORTING HER
18 MOTION TO COMPEL FURTHER
v. RESPONSES TO COSIO'S REQUESTS
19 FOR ADMISSION NOS. 8 TO 13 AND 41,
INTERNATIONAL PERFORMING AND FORM INTERROGATORY NO.
20 ARTS ACADEMY, LLC, a California 17.1 TO DEFENDANT LION
limited liability company, BARBIZON MANAGEMENT GROUP, INC.
21 SCHOOL OF SAN FRANCISCO, INC., a
California corporation, LION The Honorable Curtis E.A. Karnow
22 MANAGEMENT GROUP INC., a Department 304
California corporation, ANTHONY Civic Center Courthouse
23 LOUIS LIONETTI, LARRY D. 400 McAllister Street
LIONETTI, LENA QUESADA San Francisco California 94102
24 LIONETTI, LENA M. LIONETTI, and
DOES 1-100, inclusive, Date: April 19,2017
25 Defendants. Time: 4:00 p.m.
26 Complaint Filed: April 6, 2016
27
28
Memorandum for Motion to Compel Further Responses No. CGC-16-551337
to RF As and Form Interrogatory No. 17.1 to Lion
T ABLE OF CONTENTS
2 1. THE PARTIES' MEET AND CONFER PROCESS PRIOR TO THE MOTION ............. 1
3 II. LION'S DECEMBER RESPONSES REGARDING ITS MARKETING
MATERIALS ARE EVASIVE ........................................................................................... 2
4
A. Lion's December Responses to RFAs Nos. 8 to 13 Are Evasive ........................... 2
5
B. Lion's December Response to RFAs No. 41 Is Evasive ........................................ 4
6
7 C. Lion's December Response to RFAs No. 41 Is Evasive ........................................ 5
8 1. Lion's December Response to Form Interrogatory No. 41 as to

RFAs Nos. 8 to 13 Is Still Incomplete and Evasive .................................... 5
9
2. Lion's November Response to Form Interrogatory No. 17.1 as to
10 RF A No. 41 Fails to Identify Relevant Facts and Witnesses ...................... 6
11 3. Lion's December Response to Form Interrogatory No. 17.1 as to

RFA No. 41 Is Evasive and Incomplete Because It Refers to
12 "Students" Rather than "Customers," and Relies on Speculation
Rather than Providing Specific Facts Supporting Its Denial ...................... 7
13
III. LION'S VERIFICATION OF ITS RESPONSES IS DEFECTIVE ................................. 11
14
IV. CONCLUSION ................................................................................................................. 12
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Memorandum for Motion to Compel Further Response 2 No. CGC-16-551337

to Special Interrogatory No.2 to Lion
TABLE OF AUTHORITIES
2
Page(s)
3
Federal Cases
4
Hunter v. Int 'I Sys. & Controls Corp.,
5 56 F.R.D. 617 (W.D.Mo.1972) .................................................................................................. 4
6
Independent Living Ctr. of S. Cal. v. City ofLos Angeles,
7 296 F.R.D. 632 (C.D. Cal. 2013) ............................................................................................... 4
8 Saltzman v. Fullerton Metals Co.,

661 F.2d 647 (7th Cir. 1981) ..................................................................................................... 4
9
10 Werbungs Und Commerz Union Austalt v. Collectors Guild, Ltd.,
728 F. Supp. 975 (S.D.N.Y.1989), rev'd in part on other grounds, 930 F.2d 1020
11 (2dCir.1991) .............................................................................................................................. 4
12 State Cases
13 Appleton v. Superior Court

14 (1988) 206 Cal.App.3d 632 ..................................................................................................... 11
15 Burke v. Superior Court

(1969) 71 Cal.2d 276 ............................................................................................................... 11
16
17 Deyo v. Kilbourne
(1978) 84 Ca1.App.3d 771 ............................................................................................... 4, 9, 10
18
Hillman v. Stults
19 (1968) 263 Cal.App.2d 848 ................................................................................................... 3, 9
20 Liberty Mut. Fire Ins. Co. v. LCL Adm 'rs, Inc.

(2008) 163 Cal.App.4th 1093 .................................................................................................. 11
21
22 Melendrez v. Superior Court
(2013) 215 Ca1.AppAth 1343 .................................................................................................. 11
23
People v. Dixon
24 (2007) 148 Cal.AppAth 41 ........................................................................................................ 7
25
Puerto v. Superior Court
26 (2008) 158 Cal. App. 4th 1242 .................................................................................................. 7
27 Reedy v. Bussell
(2007) 148 Ca1.App.4th 1272 .................................................................................................... 3
28

Zarro Inv. Co. v. Great Pac. Sec. Corp.
(1977) 69 Cal.App.3d 907 ....................................................................................................... 12
2
State Statutes
3
Civil Discovery Act ............................................................................................................... 5, 7, II
4
Code Civ. Proc., 2017.010 ............................................................................................................ 7
5
6 Code Civ. Proc. 2030.220(a) ................................................................................................... 7, 10
7 Code Civ. Proc. 2033.220(b) .................................................................................................. 5, 12
8 Code Civ. Proc. 2030.250(b) ...................................................................................................... 11
9 Code Civ. Proc. 2030.300 ......................................................................................................... 2, 1

10 Code Civ. Proc. 2033.290 ......................................................................................................... 2, 1
11
Rules
12
California Rules of Court, Rule 3.1345 ........................................................................................... 3
13
Other Authorities
14
15 Wei I & Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group
2016) ~ 8:1106 ......................................................................................................................... 11
16
Weil & Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group
17 2016)~ 8:1106.1 ...................................................................................................................... 12
18
19
20
21
22
23
24
25
26
27
28

COSIO'S MOTION TO COMPEL FURTHER RESPONSES
TO HER REQUESTS FOR ADMISSIONS AND FORM INTERROGATORIES
2 Plaintiff Angelica Cosio ("Cosio") hereby submits her memorandum of points and
3 authorities in support of her Motion for an order compelling further responses by Defendant Lion
4 Management Group, Inc. ("Lion") to Cosio's Requests for Admissions Nos. ("RFAs") Nos. 8 to
5 13 and 41, and the corresponding Fonn Interrogatory No. 17.1, under Code of Civil Procedure
6 sections 2030.300 and 2033.290.
7 I. The Parties' Meet and Confer Process Prior to the Motion

8 On July 19, 2016, Cosio served her first set of discovery on Lion, including RF As Nos. 8
9 to 13 and 41, and the corresponding Fonn Interrogatory No. 17.1. (Preston Decl. ~3.) On August
10 22, 2016, Lion served responses composed entirely of objections ("August Responses").
11 On November 11,2016, Lion served supplemental responses ("November Responses").
12 On November 21,2016, Cosio sent Lion a draft "one shot" brief explaining the various defects in
13 the supplemental responses, consistent with the Court's "User's Manual for Department 304"
14 and the parties' discovery plan (Id. ~8. See also Department 304 of the Superior Court for San
15 Francisco County, User's Manual for Department 304 (Sept. 2016), p. 3
16 <http://www.sfsuperiorcourt. org/sitesldefault/files/pdfs/Department%203 04 %20U ser%20
17 Manual.pdf>.)
18 On December 15, 2016, after some additional meeting and conferring, Defendants served
19 amended responses ("December Responses") which are at issue in this motion. (Preston Decl.
20 ~10.) The December Responses incorporated the objections from the August Responses, the
21 defective answers from the November Responses, and additional answers which eliminated some
22 disputes but made others worse. (Ibid.) On January 20,2017, Cosio sent Lion her second draft
23 "one shot" brief, which explained that the amended responses were still evasive and incomplete.
2 So far, Lion has refused to provide a counterdraft to Cosio's draft one shot brief. (Id. ~13.)
25 Cosio's other efforts to meet and confer with Lion have also been unsuccessful and
26 unproductive. (Id. ~~14-21.) It appears the parties may have an infonnal conference with the
27 Court after Cosio files this Motion. (Id. ~21.) Cosio's past experience is that Defendants are
28 much more productive in the meet and confer process while there is a motion to compel pending.
Memorandum for Motion to Compel Further Response No. CGC-16-551337
If Lion voluntarily serves discovery responses that are complete, responsive, and non-evasive
2 before the hearing date on this Motion, Cosio will take the Motion off calendar.
3 II. Lion's December Responses Regarding Its Marketing Materials Are Evasive
4 Cosio's discovery is really very simple, although Lion's various Responses and its
5 involvement in the meet and confer process has complicated the Motion. Cosio received
6 marketing materials (attached as pages 14 to 26 of the appendix attached to the Complaint and
7 the RF As) at her child's audition on July 13, 2013 (hereinafter, "Marketing Materials"). (See
8 (Ex. 1 to Preston Decl. at pp. 26-38 ("Ex. 1,,).)1 RFAs Nos. 8 to 13 ask Lion to admit that its
9 marketing included various representations found in these Marketing Materials throughout the
10 class period. RF A No. 41 asks Lion to admit that it provided its customers documents containing
11 the same terms and representations as the Marketing Materials. Form Interrogatory No. 17.1 asks
12 Lion to identify specific factual situations where Lion's marketing did not include the
13 representations found in Cosio's Marketing Materials, or it did not provide its customers
14 documents like the Marketing Materials. Lion has misconstrued this discovery, and provided
15 evasive and incomplete Responses.
16 A. Lion's December Responses to RFAs Nos. 8 to 13 Are Evasive

17 RF As Nos. 8 to 13 ask Lion to admit that its marketing during the class period
18 continuously included specific representations which Cosio found in the Marketing Material:
19 RFA No.8: "Since at least April 6,2012, IPAS has represented that IPAS's
showcase was the best opportunity to start a career in the modeling or talent
20 industry. "
21 RFA No.9: "Since at least April 6, 2012, IPAS has represented that IPAS
customers are placed in an elite group that auditioned successfully for fashion
22 modeling, commercial modeling, TV commercials, television/film acting, singing
and dancing."
23
RF A No.1 0: "Since at least April 6, 2012, IPAS has represented that IPAS
24 customers wi11 be showcased before the top modeling and talent agents,
managers, casting directors/producers, and film directors/producers."
25
26 1 Exhibit 1 to the Preston Declaration is a paginated copy of the entire set of RF As to Lion. The
appendix in the RFAs (and a portion of Exhibit 1) is marked as "Plaintiffs Appendix" and
27 are also paginated on the right-hand side. (Preston Decl. ~3.) Cosio has also paginated the
entire Exhibit 1 to facilitate the Court's review. The pagination on the left-hand side of
28 Exhibit I (marked "Exhibit I") refers to specific pages throughout the entire Exhibit. (Id. ~4.)
In short, "pages 14 to 26 of the appendix" translates to pages 26 to 38 of Exhibit 1.
RF A No. 11: "Since at least April 6, 2012, IPAS has represented that IPAS
customers will read for casting directors, producers and directors who are
2 currently working in the industry."
3 RFA No. 12: "Since at least April 6, 2012, IPAS has represented that IPAS
customers will meet, try-out for and interview with scores of modeling and talent
4 agents and managers."
5 RFA No. 13: "Since at least April 6, 2012, IPAS offered IPAS customers
enrollment in Official Showcases/Auditions."
6
(Ex. 1 at pp. 3-4. Cf. Ex. 1 at pp. 28, 29, 32, 36 [corresponding Marketing Material]. As Cosio
7
explained in the meet and confer process, the phrase "since at least April 6, 2012" makes it clear
8
that these RFAs cover all IPAS's marketing continuously throughout the class period.
9
Lion's December Responses misconstrue RF As Nos. 8 and 13, stating in relevant part:
10
"Based on meet and confer with Plaintiff in which she states that this request is intended to ask
11
whether Lion has ever" made the corresponding representation in RFAs Nos. 8 to 13. (Ex. 4 to
12
Preston DecL at pp. 11:15-16; 13:5-6; 14:22-23; 16:11-12; 17:16-17; 19:2-3 ("Ex. 4").) But
13
Cosio's January 20 draft one shot brief explicitly told Lion that it had misconstrued these RFAs:
14
The Responses gravely mischaracterize Cosio's position in the meet and
15 confer. In the meet and confer process, Cosio specifically clarified that she
drafted [these] RFA[s] to cover all of IPAS's marketing communications
16 since April 6, 2012. [These RFAs] asks whether Lion's marketing materials
continuously contained the representation at issue, not whether Lion ever used a
17 particular brochure on specific and/or isolated instances.
18 (Ex. 6 to Preston Decl. at p. 7:15-19 ("Ex. 6").) Lion's misconstruction ofRFAs Nos. 8 to 13
19 renders them pointless-it is not meaningful to class certification if Lion made these
20 representations just once.
21 It is hard to escape the impression Lion has willfully misconstrued RF As Nos. 8 to
22 particularly where Cosio specifically explained the problem with these Responses in her January
23 20 one shot brief~ and Lion has declined to amend the Responses. (Preston Decl. ~~13-20.)
24 Where Lion's responses do "not fairly meet the substance of the requested admissions or were
25 not phrased in good faith," sanctions are warranted to remedy "the resulting extended litigation
26 to prove these unfounded denials or partial denials." (Hillman v. Stults (1968) 263 CaLApp.2d
27 848,888.) This conduct reflects bad faith. (Cf. Reedy v. Bussell (2007) 148 CaLApp.4th 1272,
28 1281 [sanctions appropriate where litigant did not make "any effort to fairly interpret" discovery

requests] (Reedy); Deyo v. Kilbourne (1978) 84 Cal.App.3d 771,783 ["party may not provide
2 deftly worded conclusionary answers designed to evade a series of explicit questions .... party
3 may not deliberately misconstrue a question for the purpose of supplying an evasive answer"]
4 (Deyo)/
5 Lion's December Response to Form Interrogatory No. 17.1 lacks any information about
6 instances when Lion's marketing was different from the representations cited in RFA Nos. 8 to
7 13, presumably because the December Responses admitted Lion's improperly misconstrued
8 versions ofRFAs Nos. 8 to 13. Hence, Lion's misconstruing RFAs Nos. 8 to 13 deprives Cosio
9 of either (1) admissions to RFAs Nos. 8 to 13 that Lion's marketing was materially consistent
10 with the Marketing Materials throughout the class period; or (2) identification of specific
11 instances when Lion's marketing deviated from the Marketing Materials that Cosio received.
12 B. Lion's December Response to RFAs No. 41 Is Evasive

13 Cosio's RFA's No. 41 asks Lion to admit that it gave all its customers the Marketing
14 Materials:
15 Since at least April 6, 2012, IP AS gave all its customers documents containing the
same terms and representations as the documents labeled as pages 14 to 26 of the
16 attached appendix (excluding any hand-written notes and differences in IP AS
employee names and showcase dates).
17
(Ex. 1 at p. 9:2-5.) Lion's November Responses to RFA No. 41 were evasive and
18
nonresponsive-Lion only admitted that "some customers were signed up using Lion's form of
19
agreement and some using IP AA' s form of agreement, which have variations," and denied the
20
21
Discovery requests should not be "read hypertechnically; rather, a party should attempt to
22 comply with discovery demands in good faith." Werbungs Und Commerz Union Austalt v.
Collectors Guild, Ltd., 728 F. Supp. 975, 982 (S.D.N.Y.1989), rev'd in part on other
23 grounds, 930 F.2d 1020 (2d Cir.1991) ) (attempt to avoid discovery by hypertechnical
construction "smacks of the type of gamesmanship that the Federal Rules were designed to
24 avoid"). Evasive misconstruction of discovery requests was not consistent with "good faith
duty to comply with discovery requests[,] smack[ ed] of gamesmanship[,] and is contrary to
25 the purposes of modem discovery provisions to promote the fair and efficient resolution of
disputes." Saltzman v. Fullerton Metals Co., 661 F.2d 647,651 n.4 (7th Cir. 1981). See also
26 Independent Living Ctr. ors. Cal. v. City ofLos Angeles, 296 F.R.D. 632, 635 (C.D. Cal.
2013) (granting motion to compel where defendants "deliberately misconstrue[ ed] plaintiffs'
27 discovery requests"); Hunter v. Int'l Sys. & Controls Corp., 56 F.R.D. 617, 624
(W.D.Mo.1972) ("deliberate misconstruction of [discovery] constitute[ d] a failure to make
28 discovery without substantial justification and [would] be considered ... as a basis for
possible sanctions").
rest. (Ex. 4 at p. 44: 18-22.) Of course, RFA No. 41 concerns the Marketing Materials-not
2 Lion's contracts. So Lion's November Responses facially misconstrued RFA No. 41.
3 Lion's December Response bluntly denies RFA No. 41. The December Response to
4 Form Interrogatory No. 17.1 (discussed below) makes it clear that Lion gave copies of the
5 Marketing Materials to at least some of its customers. Hence, the December Response's blunt
6 denial violates the Civil Discovery Act, which requires Lion to make an affirmative admission to
7 the extent it provided its customers documents with the same terms and representations in the
8 Marketing Material: "Each answer shall ... Admit so much of the matter involved in the request
9 as is true, either as expressed in the request itself or as reasonably and clearly qualified by the
10 responding party." (Code Civ. Proc. 2033.220 subd. (b).)
11 c. Lion's December Response to RFAs No. 41 Is Evasive

12 Form Interrogatory No. 17.1 in effect asks Lion to explain and substantiate its denials to
13 RFAs Nos. 8 to 13 and 41. Cosio's Form Interrogatory No. 17.1 asked:
14 Is your response to each request for admission served these interrogatories an

unqualified admission? If not, for each response that is not an unqualified
15 admission:
(a) state the number of the request;
16 (b) state all facts upon which you base your response;
(c) state the names, ADDRESSES, and telephone numbers of all PERSONS
17 who have knowledge of those facts; and
(d) identify all DOCUMENTS and other tangible things that support your
18 response and state the name, ADDRESS, and telephone number of the
PERSON who has each DOCUMENT or thing.
19
(Ex. 2 to Preston Decl. at p. 7.) Lion's answers to Form Interrogatory No. 17.1 begin with a
20
lengthy preamble on, e.g., Lion's business history which is irrelevant to any of the specific RF As
21
at issue here. (Ex. 5 to Preston Decl. at pp. 3:26-6:20 ("Ex. 5").)
22
1. Lion's December Response to Form Interrogatory No. 41 as to RFAs
23 Nos. 8 to 13 Is Still Incomplete and Evasive
24 The December Response to Form Interrogatory No. 17.1 also incorporates Lion's
25 November Response which contains several paragraphs of irrelevant statements purportedly in
26 response to RFAs Nos. 8 to 13. (Ex. 5 at pp. 6:21-7:25.) Other than incorporating the November
27 Response, however, the December Responses does not address RF As Nos. 8 to presumably
28 because the Lion admitted its improperly misconstrued versions of Cosio's RFAs Nos. 8 to 13.

Hence, Lion's December Responses to RF As Nos. 8 to 13 deprive Cosio of a complete and
2 accurate answer to Form Interrogatory No. 17.1.
3 2. Lion's November Response to Form Interrogatory No. 17.1 as to RFA

No. 41 Fails to Identify Relevant Facts and Witnesses
4
Again, the December Response to Form Interrogatory No. 17.1 incorporates the
5
November Response. Hence, this motion discusses the portions of the November Response
6
which are still relevant and disputed. The November Response makes a generalized, boilerplate
7
denial ofRFA No. 41:
8
Defendant denies that it made uniform representations to the putative class, or that
9 all members of the putative class were told the same thing or were exposed to the
same statements .... Each student may be subject to additional and different
10 disclosures and disclaimers about Defendants' services depending on each
student's individual circumstances and his or her (and their children's) questions
11 asked, and answers given.
12 (Ex. 5 at p. 8:10-18.) But the November Response to Form Interrogatory No. 17.1 is woefully
13 incomplete. It plainly does not state "all facts" supporting Lion's denial of RF A No. 41. In
14 particular, while students "may be subject to additional and different disclosures and
15 disclaimers," Lion utterly fails to identify what different disclosures apply to what
16 "circumstances." (Ibid.)
17 Further, it is clear that "Larry Lionetti and Lena Q. Lionetti" cannot be the only persons
18 with "knowledge of those facts" relating to the commonality of Lion's marketing. (Cf. Ex. 5 at p.
19 8:20-21.) This answer patently contradicts other portions of Lion's answer to Form Interrogatory
20 No. 17.1:
21 Brandy Calderon, who "scouted" Cosio denies that she made any such promises
or offers to Cosio. Ms. Calderon did not tell Cosio ... that they could get a job in
22 the entertainment industry or an audition, agent or manager. When she told people
about the program, she would present it like any other activity such as
23 gymnastics.
24 (Id. at p. 7:9-12.) Lion cannot reconcile the statement above with the implicit assertion that only
25 the Lionettis have knowledge of the relevant facts. Likewise, the Lion employees who actually
26 conducted the tryouts (such as Karen Dewey) would clearly have knowledge of whether and
27 when marketing materials were or were not distributed to Lion's customers. Yet, Lion has not
28 identified any such employees.

Further, Lion's November Response states "Defendants' internal procedures prohibit any
2 employee from making any representation that the company will provide an audition for work in
3 the entertainment industry, or as a means to secure a talent agent or manager." (Id. at p. 7:18-21.)
4 If the Lionettis were the only people who knew about these alleged policies, it is fair to say they
5 were not policies at all.
6 Lion's tight-fisted approach to discovery here prejudices Cosio. Cosio should not have to
7 depend on the Lionettis' testimony alone to investigate Lion's denial "that it made uniform
8 representations to the putative class[.]" (Id. at p. 8:12-18.) Cosio is entitled to discovery of
9 witnesses with knowledge relevant to class certification and specifically the commonality of the
10 Marketing Materials. "Discovery may be obtained of the identity and location of persons having
11 knowledge of any discoverable matter ... " (Code Civ. Proc., 2017.010.)
12 Central to the discovery process is the identification of potential witnesses. "The

disclosure of the names and addresses of potential witnesses is a routine and
13 essential part of pretrial discovery." (People v. Dixon (2007) 148 Cal.App.4th
414,443,56 Cal.Rptr.3d 33 [applying Civil Discovery Act in context of sexually
14 violent predator proceeding].) Indeed, our discovery system is founded on the
understanding that parties use discovery to obtain names and contact information
15 for possible witnesses as the starting point for further investigations ... The
party's ability to subpoena witnesses presumes that he has the witnesses' contact
16 information." (Dixon, at p. 443, 56 Cal.Rptr.3d 33.) One glance at the form
interrogatories approved by the Judicial Council, particularly the interrogatories in
17 the 12.0 series, demonstrates how fundamentally routine the discovery of witness
contact infonnation is.
18
(Puerto v. Superior Court (2008) 158 Cal. App. 4th 1242, 1249-50.) Lion has taken a scorched-
19
earth approach to discovery, and has evidently misconstrued even basic RF As in a manner that
20
renders them entirely useless for their obvious purpose-class certification. Under these
21
circumstances, Cosio is entitled and indeed needs complete answers to Form Interrogatory No.
22
17.1. Again, the Civil Discovery Act requires answers to an interrogatory to "be as complete and
23
straightforward as the information reasonably available to the responding party permits." (Code
24
Civ. Proc. 2030.220, subd. (a).)
25
3. Lion's December Response to Form Interrogatory No. 17.1 as to RFA
26 No. 41 Is Evasive and Incomplete Because It Refers to "Students"
Rather than "Customers," and Relies on Speculation Rather than
27 Providing Specific Facts Supporting Its Denial
28 The December Response to Form Interrogatory No. 17.1 is still evasive and incomplete.

It does not identify all persons who have knowledge of the facts supporting Lion's denial ofRFA
2 No. 41. Moreover, the December Response still does not fully or specifically identify the facts
3 supporting Lion's denial ofRFA No. 41 (i.e., that Lion's marketing contained the same terms
4 and representations in the Marketing Material):
5 Lion denies that since at least April 6, 2012, Defendants gave all its customer
documents containing the same terms and representations as the documents
6 labeled as pages 14 to 26 of the attached appendix (excluding any hand-written
notes and differences in IPAS employee names and showcase dates).
7
Appendix 14, "welcome letter" is given out only to students who show up for
8 headshots. Many Barbizon attendees do not go to the Headshot appointment and
thus never get an opportunity to receive Appendix 14. Also, some students enroll
9 directly into Showcase and therefore never get the "welcome letter." Moreover,
the "welcome letter" is varied depending on the identity of the Talent Scout who
10 will be hosting the tryout. Appendix 15-26 is available only to students who
show up for headshots and also stay for a Showcase try out. Many students leave
11 after headshots and thus do not have an opportunity to receive Appendix 15-26.
For those students that both attend headshots and stay for the showcase tryout,
12 they may get a copy of Appendix 15-26 at the tryout for Showcase, though there
is no established procedure to ensure that they do. Moreover, following the try-
13 outs, there are often a number of copies of Appendix 15-26 that have been left
behind by students so it is unclear which students ultimately receive a copy of
14 Appendix 15-26.
15 (Ex. 4 to Preston Decl. at pp. 8, 10-11 ("Ex. 4.").) As explained below, this Response is non-
16 responsive and evasive. Lion's counsel has provided a little clarification-but only in an
17 unsworn email from counsel. (Ex. 8 to Preston Decl. at pp. 5-6 ("Ex. 8").)
18 First, RFA No. 41 concerns Lion's "customers." Cosio purposefully drafted RFA No. 41
19 to limit its scope to people who ultimately paid Lion to attend the showcase-that is, class
20 members. 3 (See Preston Decl. ~~13-20.) In contrast, Lion insists on framing its answer in terms
21 of Barbiz on's students, rather than Lion's customers. 4 (Preston Decl. ~11 ["[w]e don't use the
22 term "customers" and I do not see why we have to adopt your convention of calling them that"].)
23
24 3 The language used in RFA No. 41 intentionally traces the class definition from Cosio's
complaint. (See Cosio's Fifth Am. Compl. ~34 [defining the class as "All natural persons
25 who are California citizens at the time Cosio's original complaint was filed (April 5, 2016)
who (a) paid IPAS so that the Class member, the Class member's child (or other beneficiary)
26 could attend a showcase operated by IP AS ... "J)
4 As explained in Cosio's complaint, Defendants also operated Barbizon-which referred at least
27 some of its students to IP AS/Lion-and Lion recruited at least some of its customers from
these Barbizon students. But Defendants charged Barbizon's students fees for attending
28 Barbizon classes which were separate and distinct from the fees charged for participating in
IPAS/Lion's "showcase."
By framing its response in tenns of "students" (who would not necessarily be Lion's paying
2 customers), Lion inserts an enonnous amount of uncertainty and potentially non-responsive
3 infonnation into the December Response. (See Ex. 8 at pp. 5-6. Cf. Preston Decl. ~16, Ex. 8 at
4 pp. 3-4.) Lion's insistence on framing its answer in tenns of students, rather than paying
5 customers, supposedly renders it incapable of answering Cosio's very straightforward question:
6 Your request that we "either expressly and unambiguously state that all persons
referenced in Lion response paid money not just to Barbizon but also to
7 IP AS/Lion" is inconsistent with the facts. Only those who chose to later enroll in
Showcase pay money to Lion.
8
(ld. at p. 6 [emphasis in original].) But Cosio explained that RFA No. 41 was limited to that set
9
of individuals who ultimately paid money to Lion, "whether the customers made their payment
10
to Lion before or after the try outs/headshot appointment." (ld. at pp. 3-4.) Cosio even told Lion
11
it could frame its answer in tenns of "showcase enrollees who paid IP AS" (as Lion used the
12
phrase "showcase enrollee" in its email and presumably understands what it means). (ld. at p. 3.)
13
RFA No. 41 avoided these logical gaps and uncertainty by restricting itself to Lion's
14
"customers": Lion's answer here is at least evasive and may reflect bad faith, particularly where
15
Cosio repeatedly explained to Lion that RF A No. 41 was limited to Lion's paying customers, not
16
Barbizon's students. (See Preston Decl. ~11; Ex. 6 at p. 3:20-4:18. See also Deyo, supra, 84
17
Cal.App.3d at p. 783 ["party may not deliberately misconstrue a question for the purpose of
18
supplying an evasive answer"]; Hillman v. Stults, supra, 263 Cal.App.2d at p. 888 [responses
19
that do "not fairly meet the substance of the requested admissions or were not phrased in good
20
faith" are sanctionable].)
21
Lion's references to "students," instead of "customers," creates another problematic
22
ambiguity. It is unclear from Lion's December Response whether some of its customers attended
23
showcases without attending Lion's tryouts (and therefore without receiving the Marketing
24
Materials). Lion's counsel asserts that "admittance in Showcase is after a try out, acceptance, and
25
execution of our contract," but then goes on to discuss "students who do not do the 'tryout' but
26
go right to showcase ... " (Ex. 8 at p. 6.) If there were Lion customers who were never students
27
(because they do not attend a "tryout"), then the December Response to Form Interrogatory No.
28

17.1 must be incomplete because it only discusses individuals who try out:
2 Verification of the answers [to discovery requests] is in effect a declaration that

the party has disclosed all information which is available to him. If only partial
3 answers can be supplied, the answers should reveal all information then available
to the party. If a person cannot furnish details, he should set forth the efforts made
4 to secure the information. He cannot plead ignorance to information which can be
obtained from sources under his control. ... Where the question is specific and
5 explicit, an answer which supplies only a portion of the information sought is
wholly insufficient.
6
(Deyo, supra, 84 Cal.App.3d at pp. 782, 783.) Cosio is owed a complete response to Form
7
Interrogatory No. 17.1 which conforms to the language Cosio actually used in RFA No. 41:
8
Lion's response needs to refer to "Lion's customers."
9
Second, the statement that "students [who] both attend headshots and stay for the
10
showcase tryout, they may get a copy of Appendix 15-26 at the try out for Showcase, though
11
there is no established procedure to ensure that they do" is evasive and incomplete (even setting
12
aside the reference to "students"). (Ex. 4 at p. 11 [italics added].) Lion appears to simply
13
speculate that some of its customers might not have received the same Marketing Materials that
14
Cosio did. This answer fails to provide any facts which support its denial of RF A No. 41 (beyond
15
the assertion that copies of the marketing are sometimes left behind). Form Interrogatory 17.1 (b)
16
specifically required Defendants to "state all facts upon which" they base their denial ofRFA
17
No. 41. The Civil Discovery Act required Lion's answer to Form Interrogatory No. 17.1 to "be
18
as complete and straightforward as the information reasonably available to the responding party
19
permits." (Code Civ. Proc. 2030.220, subd. (a).)
20
Further, it is unclear what Lion means when it says "there is no established procedure" to
21
ensure it gives Marketing Materials to its customers. It is unclear whether Lion's answer means
22
(1) the Marketing Materials were always present at Lion's tryouts, but there was no "procedure"
23
to ensure the Marketing Materials are actually handed out and reviewed by the attendees, or (2)
24
whether there were actually some tryouts where these Marketing Materials were not available at
25
all. Defendants' counsel stated in an unsworn email that "while 15-26 is available for use at the
26
tryout, sometimes it is handed out, sometimes it is not," which suggests appendix 15 to 26 is
27
always available. (Ex. 8 at p. 6.) Likewise, the qualification that "there is no established
28

procedure" makes the answer vague and leaves open the potential for iriformal procedures. Lion
2 needs to unambiguously disclose if the Marketing Materials were not present at specific tryouts
3 or during specific time periods.
4 Certainly, Lion's answer provides no indication that the terms and representations of its
5 marketing ever deviated from the Marketing Material that Cosio received. Obviously, if Lion
6 withheld any facts supporting its denial ofRFA No. 41, the December Response is necessarily
7 incomplete and undennines the proper function of discovery. (See also Liberty Mut. Fire Ins. Co.
8 v. LCL Adm 'rs, Inc. (2008) 163 Cal.App.4th 1093, 1104 ["[a]n important aspect oflegitimate
9 discovery ... is the ascertainment, in advance of [class certification], of the specific components
10 of [opposing party's] case so that appropriate preparations can be made to meet them"; citations,
11 punctuation omitted]. See also Burke v. Superior Court (1969) 71 Cal.2d 276,281 ["[d]iscovery
12 necessarily serves the function of 'testing the pleadings,' i.e., enabling a party to detennine what
13 his opponent's contentions are and whatfacts he relies upon to support his contentions";
14 citations, punctuation omitted; emphasis added].)
15 III. Lion's Verification of Its Responses Is Defective

16 Lion's verification of its December Responses is deficient. In the December Responses,
17 Larry Lionetti certifies the responses with the statement "I have personal knowledge of the
18 matters stated therein and declare them to be true or I am informed and believe and on that
19 ground allege that they are true." (Ex. 4 at p. 50; Ex. 5 at p. 13 [italics added].) The Civil
20 Discovery Act requires responses to be "under oath." (Code Civ. Proc. 2030.250, subd. (b);
21 2033.240, subd. (b).) Generally, "when an individual verifies discovery responses, further
22 discovery can be directed to that individual to detennine the sources for the initial responses.
23 Indeed, ... this is one of the purposes of a verification of a discovery response ... " (Melendrez
24 v. Superior Court (2013) 215 Cal.App.4th 1343, 1352.) The purpose of verification would be
25 frustrated if Defendants could simply allege their answers "on infonnation and belief." Hence,
26 "nothing in the Discovery Act authorizes verification of interrogatories on 'infonnation and
27 belief[.]'" (Weil & Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group
28 2016) ~ 8:1106.) "Unsworn responses are tantamount to no responses at all." (Appleton v.
Memorandum for Motion to Compel Further Response 11 No. CGC-I6-551337

Superior Court (1988) 206 Cal.App.3d 632,636 [citing Zarro Inv. Co. v. Great Pac. Sec. Corp.
2 (1977) 69 Cal.App.3d 907, 914].) The best practice for a corporation verifying its discovery
3 response is the following form:
4 I certify and declare under penalty of perjury under the laws of the State of
Califomia that:
5 I am the Secretary ofXYZ, Inc.; and
I have made reasonable efforts to review relevant documents, records and
6 information possessed by or known to XYZ, Inc. and its officers and employees;
and
7 Based on such review, the facts stated herein are true and correct.
8 (Weil & Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group 2016) ~
9 8: 1106.1.) The discrepancy and deficiency in Defendants' Responses is especially problematic
10 where the basis for Mr. Lionetti's personal knowledge appears to be quite limited: Larry Lionetti
11 "is not employed by, and does not receive a paycheck from, Lion, Barbizon or IPAA [and] had
12 some serious health issues a few years ago which limit his ability to work." (Lena Lionetti Decl.
13 ~4, Dec. 13,2016.) By failing to conform to this best practice, Defendants have provided
14 ultimately unreliable discovery answers.
15 IV. Conclusion
16 Lion should answer RFAs Nos. 8 to 13 as Cosio asked them: did Lion's marketing
17 contain the relevant representations throughout the class period? If Lion denies RFAs Nos. 8 to
18 13 after they have been properly construed, it needs to amend its answer to Form Interrogatory
19 No. 17.1 to provide a complete set of facts that support its denial. Likewise, Lion should
20 "[a]dmit so much of [RFA No. 41] as is true," and amend its answer to Form Interrogatory No.
21 17.1 to (1) identify all witnesses with personal knowledge (2) frame its response in terms of
22 Lion's customers, not Barbizon's students, and (3) give a complete and correct statement of facts
23 under which these customers did not receive the Marketing Materials. (Code Civ. Proc.
24 2033.220 subd. (b).) In particular, Lion needs to clarify what it means when it says "there is no
25 established procedure" to ensure it gives Marketing Materials to its customers. Finally, Lion
26 should amend its verification to the RFAs and Form Interrogatory No. 17.1 under oath, based on
27 personal knowledge after a reasonable inquiry of Lion's officers and agents.
28

Dated: March 16,2017 By: IslDavid C. Parisi
David C. Parisi
2 Zack Broslavsky (241736)
Jonathan A. Weinman (256553)
3 BROSLAVSKY & WEINMAN, LLP
(310) 575-2550 (telephone)
5 (310) 464-3550 (facsimile)
[email protected]
6 [email protected]
7 David C. Parisi (162248)
Suzanne Havens Beckman (188814)
212 Marine Street, Suite 100
(818) 990-1299 (telephone)
10 (818) 501-7852 (facsimile)
[email protected]
12 Ethan Preston (263295)
PRESTON LAW OFFICES
13 4054 McKinney Avenue, Suite 310
Dallas, Texas 75204
14 (972) 564-8340 (telephone)
(866) 509-1197 (facsimile)
16 Attorneys/or Plaintiff Angelica Cosio, on
her own behalf, and behalf 0/ all others
17 similarZv situated
18
19
20
21
22
23
24
25
26
27
28

EXHIBIT E
CONSTANCE J. YU (SBNNO. 182704)
E-mail: [email protected]
2 MICHELLE L. LANDRY (SBN. 190080)
3 PUTTERMAN LANDRY + YU LLP
353 Sacramento Street, Suite 560
4 San Francisco, CA 94111
Telephone: (415) 839-8779
5 Facsimile: (415) 727-1363
6 Attorneys for Defendants

INTERNATIONAL PERFORMING ARTS ACADEMY, LLC,
7 BARBIZON SCHOOL OF SAN FRANCISCO, INC., LION
MANAGEMENT GROUP, INC., LARRY D. LIONETTI, and
8 LENA QUESADA LIONETTI
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 FOR THE COUNTY OF SAN FRANCISCO
11
Case No. CGC-16-551337
12 ANGELICA COSIO, an individual, on her own
behalf and on behalf of all others similarly DEFENDANT LION MANAGEMENT
13 situated, GROUP, INC.'S FURTHER AMENDED
AND SUPPLEMENTAL RESPONSES TO
14 Plaintiff, PLAINTIFF'S FIRST SET OF REQUESTS
FOR ADMISSIONS
15 v.
Assigned for all purposes:
16 INTERNATIONAL PERFORMING Hon. Curtis E.A. Karnow
ARTS ACADEMY, LLC, a California limited
17 liability company, BARBIZON SCHOOL OF Dept.: 304
SAN FRANCISCO, INC., a California Complaint Filed: April 6, 2016
18 corporation, ANTHONY LOUIS LIONETTI,
LION MANAGEMENT GROUP INC., a
19 California corporation, LARRY D. LIONETTI,
LENA QUESADA LIONETTI, LENA M.
20 LIONETTI, and DOES 1-100 inclusive
21 Defendants.
22
23
24 PROPOUNDING PARTY: Plaintiff ANGELICA COSIO

25 RESPONDING PARTY: Defendant LION MANAGEMENT GROUP, INC.
26 SET NO.: One (1)
27
28
CASE NO. CGC-16-551337
DEFENDANT LION MANAGEMENT GROUP INC. 's FURTHER AMENDED AND SUPPLEMENTAL RESPONSES
TO PLAINTIFF'S FIRST SET OF REQUESTS FOR ADMISSIONS
Pursuant to section 2033.010 et seq., of the California Code of Civil Procedure
2 ("CCP"), Defendant LION MANAGEMENT GROUP, INC. hereby responds to Plaintiff
3 ANGELICA COSIO'S Request for Admissions Set One.
4 GENERAL OBJECTIONS
5 1. In addition to the Specific Objections set forth below, Responding Party LION
6 MANAGEMENT GROUP, INC. ("LION MANAGEMENT") objects generally to the Requests on
7 several grounds. The objections set forth in this section apply to each request. The assertion of the
8 same, similar, or additional objections in LION MANAGEMENT's responses to individual requests,
9 or the failure to assert any additional objection to a request, does not waive any of the General
10 Objections.
11 2. LION MANAGEMENT objects to these Requests insofar and to the extent they
12 purport to impose on its obligations other than those imposed by Sections 2017.010 and 2033.210
13 et seq. of the Code of Civil Procedure.
14 3. LION MANAGEMENT objects to these Requests on the grounds to the extent they
15 purport to require disclosure of communications protected by the attorney-client privilege. LION
16 MANAGEMENT further objects to these Requests to the extent that they would require subjective
17 judgment on the part of LION MANAGEMENT and its attorneys, and would further require
18 disclosure of a conclusion or opinion of counsel in violation of the attorney work product doctrine.
19 4. LION MANAGEMENT objects to these Requests on the grounds that they seek
20 information wholly irrelevant to the matters alleged in this litigation, and is not reasonably calculated
21 to lead to the discovery of admissible evidence.
22 5. LION MANAGEMENT objects to these Requests on the grounds that they are
23 overbroad, burdensome and oppressive and seeks information wholly irrelevant to the matters alleged
24 in this litigation, and is not reasonably calculated to lead to the discovery of admissible evidence.
25 6. LION MANAGEMENT further objects to these Requests as prematurely served, and
26 failing to abide by the Court's procedures for discovery in complex litigation and guidance for class
27 action matters (see Complex Litigation Users' Manual, at pages 2-4). LION MANAGEMENT
28 objects to these Requests to the extent they seek information in violation of the Discovery Act and are
2 CASE NO. CGC-16-551337
therefore improper. EVID. CODE 210, 350, 950-955,1060,1061; CCP 2017.010 et seq.,
2 2018.030 (work product), 2019.210 (trade secrets).
3 RESPONSES TO REQUEST FOR ADMISSION
4 REQUEST FOR ADMISSION NO.1:
5 Defendant Lion Management Group Inc. is requested to admit that:
6 Since at least April 6, 2012, IP AS has represented that IP AS's services are a way to obtain a
7 talent agent.
8 (As used in these Requests for Admission, "IPAS" means the same person(s) or entity(ies)
9 identified as "International Performing Arts Showcase" in the documents included in the attached
10 appendix (expressly including Lion Management Group Inc., whether or not doing business under the
11 fictitious business name "Hollywood Showcase"), its predecessors, successors, agents, partners,
12 attorneys, servants, employees, assignees, lessees, affiliates, and/or anyone acting on behalf of it,
13 and/or any affiliate, subsidiary, parent or related corporation, partnership or entity, and/or anyone
14 acting for or on behalf of an such subsidiary, related corporation, parent, partnership, entity, or
15 natural person.)
16 RESPONSE TO REQUEST FOR ADMISSION NO.1:
17 Responding party LION MANAGEMENT GROUP, INC. ("LION MANAGEMENT
18 GROUP, INC.") objects to this Request to the extent that it seeks information protected from
19 disclosure by the attorney client privilege and/or work product doctrine. LION MANAGEMENT
20 objects to the form of this Request as argumentative and as purporting to require Responding Party
21 adopt Plaintiff s statutory construction of the California Labor Code or its interpretation of specific
22 terms with the California Labor Code. LION MANAGEMENT also objects to this Request as
23 containing or calling for a legal conclusion(s) and that it improperly seeks an admission regarding an
24 ultimate issue for the Court or factfinder, and thus, violates the Discovery Act. CCP 2017.010
25 et seq., 2033.230 et seq.
26 LION MANAGEMENT further objects to this Request as prematurely served, and failing to
27 abide by the Court's procedures for discovery in complex litigation and guidance for class action
28 matters (see Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each
3 CASE NO. CGC-16-551337
phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
2 3, 4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
3 This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
4 discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
5 plaintiffs file the certification motion.")
6 Accordingly, LION MANAGEMENT reserves all rights and objections until the parties,
7 through counsel, are able to meet and confer regarding the appropriate scope of the discovery at this
8 pre-class certification stage of this action. EVlD. CODE 21O, 350, 950-955, 1060, 1061;
9 CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
12 Since at least April 6,2012, IPAS has represented that IPAS's services are a way to obtain a
13 talent manager.
15 LION MANAGEMENT objects to this Request to the extent that it seeks information
16 protected from disclosure by the attorney client privilege and/or work product doctrine. LION
17 MANAGEMENT objects to the form of this Request as argumentative and purporting to require
18 Responding Party adopt Plaintiff s statutory construction of the California Labor Code or its
19 interpretation of specific terms with the California Labor Code. LION MANAGEMENT also objects
20 to this Request as containing or calling for a legal conclusion( s) and that it improperly seeks an
21 admission regarding an ultimate issue for the Court or factfinder, and thus, violates the Discovery
22 Act. CCP 2017.010 etseq., 2033.230 etseq.
25 matters (see Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each
26 phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
4 CASE NO. CGC-16-551337
discovery is taken at this stage regarding anticipated defenses to the certification motion. Then
5 pre-class certification stage of this action. EVID. CODE 21O, 350, 950-955, 1060, 1061;
9 Since at least April 6, 2012, IP AS has represented that IP AS's services are a way to obtain
10 employment as an ARTIST.
11 (As used in these Requests for Admission, "ARTIST" has the same definition as it does in
12 California Labor Code section 1701, subsection (a): "a person who is or seeks to become an actor,
13 actress, model, extra, radio artist, musical artist, musical organization, director, musical director,
14 writer, cinematographer, composer, lyricist, arranger, or other person rendering professional services
15 in motion picture, theatrical, radio, television, Internet, print media, or other entertainment enterprises
16 or technologies.")
20 MANAGEMENT objects to the form ofthis Request as argumentative and purporting to require
21 Responding Party adopt Plaintiffs statutory construction of the California Labor Code or its
23 to this Request as containing or calling for a legal conclusion(s) and that it improperly seeks an
25 Act. CCP 2017.010 et seq., 2033.230 et seq.
5 CASE NO. CGC-16-551337
phase designed to either lead directly to a motion or provide efficacies for the next phase"), and pages
12 Since at least April 6,2012, IPAS has represented that IPAS's services are a way to obtain an
13 employment opportunity as an ARTIST.
22 Act. CCP2017.010etseq.,2033.230etseq.
6 CASE NO. CGC-16-551337
9 Since at least April 6, 2012, IPAS has represented that IPAS's services are a way to obtain
10 employment in the ENTERTAINMENT INDUSTRY.
11 (As used in these Requests for Admission, "ENTERTAINMENT INDUSTRY" means motion
12 picture, theatrical, radio, television, Internet, print media, or other entertainment enterprises or
13 technologies.)
7 CASE NO. CGC-16-551337
9 Since at least April 6, 2012, IP AS has represented that IP AS's services are a way to obtain an
10 employment opportunity in the ENTERTAINMENT INDUSTRY.
16 interpretation of specific tenns with the California Labor Code. LION MANAGEMENT also objects
24 3,4 (Class actions: "1. Plaintiffs do only the discovery they need to meet their certification needs.
8 CASE NO. CGC-16-551337
through counsel, are able to meet and confer regarding the appropriate scope of the discovery at this
2 pre-class certification stage of this action. EVID. CODE 21O, 350, 950-955,1060,1061;
4 REQUEST FQR ADMISSION NO.7:
6 Since at least April 6, 2012, IP AS has represented that IP AS's services included an
7 opportunity to obtain an AUDITION.
8 (As used in these Requests for Admission, "AUDITION" has the same definition as it does in
9 California Labor Code section 1701, subsection (b): "any activity for the purpose of obtaining
10 employment, compensated or not, as an artist whereby an artist meets with, interviews or performs
11 before, or displays his or her talent before, any person, including a producer, a director, or a casting
12 director, or an associate, representative, or designee of a producer, director, or casting director, who
13 has, or is represented to have, input into the decision to select an artist for an employment
14 opportunity.")
9 CASE NO. CGC-16-551337
DEFENDANT LION MANAGEMENT GROUP INC.'S FURTHER AMENDED AND SUPPLEMENTAL RESPONSES
This is usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
10 Since at least April 6, 2012, IPAS has represented that IPAS's showcase was the best
11 opportunity to start a career in the modeling or talent industry.

10 CASE NO. CGC-16-551337
Accordingly, LION MANAGEMENT reserves all rights and objections until the parties,
3 pre-class certification stage of this action. EVID. CODE 21O, 350, 950-955, 1060, 1061; CCP
4 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
5 SUPPLEMENTAL RESPONSE TO REOUEST FOR ADMISSION NO.8:
6 To the extent Plaintiff intends to refer to a specific statement allegedly made by some
7 Defendant in some specific context, Defendant objects that this request is not full and complete in
8 and of itself. Subject to the foregoing specific and general objections, Defendant admits that it holds
9 itself out as providing talent training services such as lessons, coaching, seminars, workshops, or
10 similar training, which develops aspiring artists. While many students attend Defendant's school to
11 train for the world of modeling, acting, singing or dancing, others choose to enter the business world,
12 or use their fashion and beauty experience as a stepping stone to careers as stylists, make-up artists
13 and designers. Except as expressly admitted herein, Defendant denies the remainder of this request.
14 AMENDED SUPPLEMENTAL RESPONSE TO REOUEST FOR ADMISSION NO.8:
15
16
17 Lion admits that Defendants have used a brochure, since at
18 least April 6, 2012, which contains a "Showcase Frequently Asked Questions:" page in which the
19 talent service answers the question: "What are the chances of starting a career in the modeling or
20 talent industry as a result of my participation in the Showcase?" with the answer: "It is the very best
21 opportunity in this industry. Imagine having maximum exposure to scores of the industries 'A' list
22 watching you perform. Success is at its highest. It is up to the model or talent afterwards to follow
23 through with the agencies and managers who are interested in them. Showcase staff, as well as your
24 talent scout will assist with this."
27
28
11 CASE NO. CGC-16-551337
Since at least April 6, 2012, IP AS has represented that IP AS customers are placed in an elite
2 group that auditioned successfully for fashion modeling, commercial modeling, TV commercials,
3 television/film acting, singing and dancing.
4 RESPONSE TO REOUEST FOR ADMISSION NO.9:
5 LION MANAGEMENT objects to this Request to the extent that it seeks infonnation
7 MANAGEMENT objects to the fonn of this Request as argumentative and purporting to require
9 interpretation of specific tern1S with the California Labor Code. LION MANAGEMENT also objects
23 pre-class certification stage of this action. Evid. Code 210, 350, 950-955,1060, 1061; CCP
24
2017.010 et seq., 2018.030 (work product), 2019.21 (trade secrets).
25 SUPPLEMENTAL RESPONSE TO REQUEST FOR ADMISSION NO.9:
28 and of itself. Subject to the foregoing specific and general objections, Defendant admits that it has
12 CASE NO. CGC-16-551337
that it has helped to train aspiring artists, who have gone on to have successful careers in modeling,
2 acting, singing and dancing, and has made true statements, from time to time, to that effect. Except
3 as expressly admitted herein, Defendant denies the remainder of this request.
4 AMENDED SUPPLEMENTAL RESPONSE TO REOUEST FOR ADMISSION NO.9:
8 Lion admits that Defendants have used a brochure, since at least April
9 6,2012, which contains a "Showcase Frequently Asked Questions:" page in which the talent service
10 answcrs the question: "Why is someone selected for the Showcase?" with the answer: "Those
11 accepted are placed in an elite group that auditioned successfully for fashion modeling, commercial
12 modeling, TV commercials, television/film acting, singing and dancing, and they receive evaluation
13 oftheir talent."
14 REQUEST FOR ADMISSION NO. 10:
16 Since at least April 6, 2012, IPAS has represented that IPAS customers will be showcased
17 before the top modeling and talent agents, managers, casting directors/producers, and film
18 directors/producers.
19 RESPONSE TO REQUEST FOR ADMISSION NO. 10:
23 Responding Party adopt Plaintiff's statutory construction of the California Labor Code or its
28
13 CASE NO. CGC-16-551337
LION MANAGEMENT further objects to this Request as prematurely served, and failing to
11 pre-class certification stage ofthis action. EVID. CODE 21O, 350, 950-955, 1060, 1061;
13 SUPPLEMENTAL RESPONSE TO REQUEST FOR ADMISSION NO. 10:
18 similar training, which develops aspiring artists, and from time to time, uses the terms "showcase"
19 and "showcased". Except as expressly admitted herein, Defendant denies the remainder of this
20 request.
21 AMENDED SUPPLEMENTAL RESPONSE TO REQUEST FOR ADMISSION NO. 10:
22
23
24
25 Lion admits that Defendants have used a brochure advertising Showcase, since at least April
26 6,2012, that contains the statement: "If selected, you will be traveling to Los Angeles to learn the
27 latest in modeling, acting and talent techniques, how to market yourself in the industry, and all the
28 in's and out's of the business from the leaders in this industry. You will also be showcased before
14 CASE NO. CGC-16-551337
the top modeling and talent agents, managers, casting directors, film directors/producers, record
2 labels and and industry professionals from the entertainment capital of the world, Hollywood."
5 Since at least April 6, 2012, IP AS has represented that IP AS customers will read for casting
6 directors, producers and directors who are currently working in the industry.
10 MANAGEMENT objects to the form of this Requcst as argumentativc and purporting to rcquire
28
15 CASE NO. CGC-16-551337
SUPPLEMENTAL RESPONSE TO REQUEST FOR ADMISSION NO. 11:
6 similar training, which develops aspiring artists, and from time to time, may discuss with students the
7 Los Angeles event, where agents, managers and casting directors with active careers in the industry
8 will review performances.
9 Except as expressly admitted herein, Defendant denies the remainder of this request.
11
12
13
14 Lion admits that Defendants have used a brochure advertising Showcase, since at least
15 April 6, 2012, that has a "Top 10 Reasons to Attend the Showcase!" section which states under
16 reason number 8: "You will read for casting directors, producers and directors who are currently
17 working in the industry."
20 Since at least April 6, 2012, IP AS has represented that IP AS customers will meet, try-out for
21 and interview with scores of modeling and talent agents and managers.
24 protected from disclosure by the attomey client privilege and/or work product doctrine. LION
25 MANAGEMENT objects to the fonn of this Request as argumentative and purporting to require
26 Responding Party adopt Plaintiff's statutory construction of the Califomia Labor Code or its
27 interpretation of specific terms with the Califomia Labor Code. LION MANAGEMENT also objects
16 CASE NO. CGC-16-551337
admission regarding an ultimate issue for the Court or factfinder, and thus, violates the Discovery
2 Act. CCP * 2017.010 et seq., 2033.230 et seq.
12 through counsel, are able to meet and confer regarding the appropriate scope ofthe discovery at this
13 pre-class certification stage of this action. EVID. CODE 21O, 350, 950-955,1060,1061;
15 AMENDED SUPPLEMENTAL RESPONSE TO REOUEST FOR ADMISSION NO. 12:
16
17
18
19 Lion admits that Defendants have used a brochure advertising Showcase, since at least
20 April 6, 2012, that contains the statement: "You will meet, try-out for and interview with scores of
21 modeling and talent agents and managers during this showcase that you would never have an
22 opportunity to see otherwise."
25 Since at least April 6, 2012, IPAS offered IPAS customers emollment in Official
26 Showcases!Auditions.
27
28
17 CASE NO. CGC-16-551337
RESPONSE TO REQUEST FOR ADMISSION NO. 13:
22 SUPPLEMENT AL RESPONSE TO REQUEST FOR ADMISSION NO. 13:
25 and of itself. Subject to the foregoing specific and general objections, Defendant admits that
26 potential students are offered a chance to perform their talent for Defendants, but denies that anyone
27 is charged for that opportunity. Defendant only charges its students for talent training services upon
28
18 CASE NO. CGC-16-551337
successful enrollment into its program and after written disclosure that Defendant is not permitted to
2 procure work or auditions for any student, that only a licensed talent agent may do so.
6 Lion admits that Barbizon graduates are offered an opportunity to attend the Showcase
7 networking event, and that Defendants have used a brochure advertising Showcase, since at least
8 April 6, 2012, that contains the statement: "Your Showcase package includes: ... Enrollment in five
9 (5) Official Showcases/Auditions (based on selection by your Showcase talent scout [sic.]"
12 Since at least April 6,2012, IPAS's services are a way for Cosio's child to obtain a talent
13 agent.
14 (As used in these Requests for Admission, "COSIO" means Plaintiff Angelica Cosio.)
19 CASE NO. CGC-16-551337
6 pre-class certification stage of this action. Evid. Code 21O, 350, 950-955,1060, 1061; CCP
7 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
10 Since at least April 6,2012, IPAS's services are a way for Cosio's child to obtain a talent
11 manager.

20 CASE NO. CGC-16-551337
7 IPAS has represented to COSIO that IPAS's services were a way for COSIO's child to obtain
8 employment as an ARTIST.
9 (As used in these Requests for Admission, "ARTIST" has the same definition as it does in
10 California Labor Code section 1701, subsection (a): "a person who is or seeks to become an actor,
11 actress, model, extra, radio artist, musical artist, musical organization, director, musical director,
12 writer, cinematographer, composer, lyricist, arranger, or other person rendering professional services
13 in motion picture, theatrical, radio, television, Internet, print media, or other entertainment enterprises
14 or technologies.")
21 CASE NO. CGC-16-551337
6 pre-class certification stage of this action. EVID. CODE 21O, 350, 950-955,1060, 1061;
10 IP AS has represented to COSIO that IP AS's services were a way for COSIO's child to obtain
11 an employment opportunity as an ARTIST.

22 CASE NO. CGC-16-551337
5 REQUEST FQR ADMISSION NO. 18:
8 employment in the ENTERTAINMENT INDUSTRY.
12 MANAGEMENT objects to the fonn ofthis Request as argumentative and purporting to require
21 phase desib:rned to either lead directly to a motion or provide efficacies for the next phase"), and pages
28
23 CASE NO. CGC-16-551337
pre-class certification stage of this action. EVID. CODE 210, 350, 950-955,1060,1061;
6 an employment opportunity in the ENTERTAINMENT INDUSTRY.
28
24 CASE NO. CGC-16-551337
REQUEST FOR ADMISSION NO. 20:
3 LION MANAGEMENT represented to COSIO that IPAS's services were a way for COSIO's
4 child to obtain a talent manager.
24 pre-class certification stage ofthis action. EVJD. CODE 210, 350, 950-955,1060,1061;
28
25 CASE NO. CGC-16-551337
IPAS has represented to COSIO that IPAS's services were the best opportunity for COSIO's
2 child to start a career in the modeling or talent industry.
22 pre-class certification stage ofthis action. EVID. CODE 210, 350, 950-955, 1060, 1061;
26 IP AS represented to COSIO that IP AS customers are placed in an elite group that auditioned
27 successfully for fashion modeling, commercial modeling, TV commercials, television/film acting,
28 singing and dancing.

26 CASE NO. CGC-16-551337
24 IPAS represented to COSIO that COSIO's child would be showcased before the top modeling
25 and talent agents, managers, casting directors/producers, and film directors/producers.
27 CASE NO. CGC-16-551337
MANAGEMENT objects to the form of this Request as argumentative and purporting to require
10 phase designed to either lcad directly to a motion or provide efficacies for the next phase"), and pages
21 IP AS represented to COSIO that COSIO's child would read for casting directors, producers
22 and directors who are currently working in the industry.
28 CASE NO. CGC-16-551337
to this Request as containing or calling for a legal conclusion(s) and that it improperly seeks an
18 IPAS represented to COSIO that COSIO's child would meet, try-out for and interview with
19 scores of modeling and talent agents and managers.

29 CASE NO. CGC-16-551337
11 pre-class certification stage of this action. EVID. CODE 210, 350, 950-955, 1060, 1061;
15 IPAS offered COSIO's child enrollment in Official Showcases/Auditions.
17 LION MANAGEMENT objects to this Request as containing or calling for a legal
18 conclusion(s) and that it improperly seeks an admission regarding an ultimate issue for the Court or
19 factfinder, and thus, violates the Discovery Act. CCP 2017.010 et seq., 2033.230 et seq.
28
30 CASE NO. CGC-16-551337
3 pre-class certification stage of this action. EVID. CODE 210, 350, 950-955,1060,1061;
7 Since at least April 6, 2012, IPAS charged its customers a FEE.
8 (As used in these Requests for Admission, a "FEE" has the same definition as it does in
9 California Labor Code section 1701, subsection (d).)
24 pre-class certification stage ofthis action. EVID. CODE 210, 350, 950-955,1060,1061;
27 To the extent that this Request seeks a legal opinion or conclusion, Defendant objects to the
28 request. Subject to the foregoing specific and general objections, Defendant admits that it charges its
31 CASE NO. CGC-16-551337
students for its talent training services. Except as expressly admitted herein, Defendant denies the
2 remainder of this request.
5 request. Subject to the foregoing specific and general objections, Defendant admits that, since April
6 6,2013, pursuant to Section 1701(f), for a fee from, or on behalf of, an artist, IPAA (until 2013) and
7 Lion (after 2013) provides or offers to provide, or advertises or represents itself as providing, that
8 artist, directly or by referral to another person, with career counseling, vocational guidance, aptitude
9 testing, or career evaluation as an artist.
12 IP AS charged COSIO a FEE.
21 Act. CCP20l7.010etseq.,2033.230etseq.
28
32 CASE NO. CGC-16-551337
9 request. Subject to the foregoing specific and general objections, Defendant admits that it charges its
10 students for its talent training services, and that Cosio signed up for talent services and was charged
11 for such training. Except as expressly admitted herein, Defendant denies the remainder of this
12 request.
15 request. Subject to the foregoing specific and general objections, Defendant admits that, since April
16 6, 2013, pursuant to Section 1701 (f), for a fee from, or on behalf of, an artist, IP AA (until 2013) and
17 Lion (after 2013) provides or offers to provide, or advertises or represents itself as providing, that
18 artist, directly or by referral to another person, with career counseling, vocational guidance, aptitude
19 testing, or career evaluation as an artist.
22 IP AS is not aware of any written agreements between IP AS and its customers which contain
23 terms that are different than IPAS's agreement with COSIO.
33 CASE NO. CGC-16-551337
interpretation of specific tenus with the California Labor Code. LION MANAGEMENT also objects
18 Defendant objects to this Request to as vague and ambiguous in its failure to specify what
19 "tenus" it refers to. Subject to the foregoing specific and general objections, Deny.
22 IP AS is not a public educational institution.
24 LION MANAGEMENT objects to this Request to the extent that it seeks infonuation
26 MANAGEMENT objects to the fonu of this Request as argumentative and purporting to require
28 interpretation of specific tenus with the California Labor Code. LION MANAGEMENT also objects
34 CASE NO. CGC-16-551337
to this Request as containing or calling for a legal conclusion(s) and that it improperly seeks an
18 IP AS is not a nonprofit corporation.
28
35 CASE NO. CGC-16-551337
15 IPAS is not a LABOR ORGANIZATION.
16 (As used in these Requests for Admission, "LABOR ORGANIZATION" has the same
17 definition as it does in California Labor Code section 1117.)
28
36 CASE NO. CGC-16-551337
9 IP AS is not a PUBLICATION.
10 (As used in these Requests for Admission, "PUBLICATION" means newspaper, bona fide
11 newsletter, magazine, trade or professional journal, or other publication of general circulation,
12 whether in print or on the Internet, that has as its main purpose the dissemination of news, reports,
13 trade or professional information, or information not intended to assist in locating, securing, or
14 procuring employment or assignments for others.)
37 CASE NO. CGC-16-551337
pre-class certification stage of this action. EVID. CODE 210, 350, 950-955,1060,1061;
5 IP AS is not a public institution.
10 LION MANAGEMENT further objccts to this Requcst as prematurcly served, and failing to
20 pre-class certification stage of this action. EVlD. CODE 210, 350, 950-955, 1060, 1061;
24 The document labeled as page 9 of the attached appendix is a true and correct copy of an
25 image file available on IPAS's website at http://talentshowcase.tv/.
38 CASE NO. CGC-16-551337
MANAGEMENT objects to the fonn of this Request as argumentative and purporting to require
3 interpretation of specific tenus with the California Labor Code. LION MANAGEMENT also objects
17 pre-class certification stage of this action. EVlD. CODE 21O, 350, 950-955,1060,1061;
20 Subject to the foregoing specific and general objections, Defendant admits the image file is an
21 image that has been used on the website at http://talentshowcase.tv/., but denies that this image, taken
22 alone, accurately reflects the website and what customers experience when they visit the site.
27
28
39 CASE NO. CGC-16-551337
3 conclusion( s) and that it improperly seeks an admission regarding an ultimate issue for the Court or
28 factfinder, and thus, violates the Discovery Act. CCP 2017.0] 0 et seq., 2033.230 et seq.
40 CASE NO. CGC-16-551337
19 The document labeled as page 12 of the attached appendix is a tme and correct copy of
20 webpage available on IPAS's website at http://talentshowcase.tv/.
22 LION MANAGEMENT objects to this Request as prematurely served, and failing to abide by
23 the Court's procedures for discovery in complex litigation and guidance for class action matters (see
24 Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each phase designed
25 to either lead directly to a motion or provide efficacies for the next phase"), and pages 3, 4 (Class
26 actions: "1. Plaintiffs do only the discovery they need to meet their certification needs. This is
27 usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
28
41 CASE NO. CGC-16-551337
6 CCP 2017.010 et seq. and 2033.230 et seq.
8 Subject to the foregoing specific and general objections, Defendant admits that page 12
9 reflects a webpage that has been used in connection with the website at http://talentshowcase.tv/.
12 The document labeled as pages 12 to 13 of the attached appendix is a true and correct copy of
13 webpage available on IPAS's website at http://talentshowcase.tvl.
17 Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each phase designed
19 actions:" 1. Plaintiffs do only the discovery they need to meet their certification needs. This is
25 pre-class certification stage of this action. EVID. CODE 210, 350, 950-955,1060,1061;
28 See Response to RF A No. 38, which is incorporated herein by reference.

42 CASE NO. CGC-16-551337
AMENDED SUPPLEMENTAL RESPONSE TO REQUEST FOR ADMISSION NO. 39:
2 Subject to the foregoing specific and general objections, Defendant admits that page 12 to 13
3 of the attached appendix is a true and correct copy of webpage available on IP AS's website at
7 The documents labeled as pages 14 to 26 of the attached appendix are true and correct copies
8 of documents which IPAS gave COSIO on or about July 13,2013.
22 SUPPLEMENT AL RESPONSE TO REQUEST FOR ADMISSION NO. 40:
23 Subject to the foregoing specific and general objections, Defendant admits, except that the
24 copy in the attached appendix is adulterated and contains additional writing.
27
28
43 CASE NO. CGC-16-551337
Since at least April 6, 2012, IP AS gave all its customer documents containing the same terms
2 and representations as the documents labeled as pages] 4 to 26 of the attached appendix (excluding
3 any hand-written notes and differences in IPAS employee names and showcase dates).
4 RESPONSE TO REOUEST FOR ADMISSION NO. 41:
18 Subject to the foregoing specific and general objections, Defendant admits that all of its
19 contracts for talent services are in writing and contain the language required by Labor Code section
20 1703, and further avers that some customers were signed up using Lion's form of agreement and
21 some using IPAA's form of agreement, which have variations. Except as expressly admitted herein,
22 Defendant denies the remainder of this request.
24 Based on meet and confer and Plaintiff's explanation that she seeks an admission that Lion
25 gave all of its customers a copy of pages 14 to 26 of the attached appendix, Defendant denies this
26 request.

44 CASE NO. CGC-16-551337
The document labeled as pages 27 to 28 of the attached appendix are a true and correct copy
2 of the agreement between IPAS and COSIO.
21 Since at least April 6, 2012, all ofIP AS's agreements with its customers contained the same
22 terms and representations as the documents labeled as pages 27 to 28 of the attached appendix
23 (excluding any hand-written notes and differences in showcase dates).
45 CASE NO. CGC-16-551337
actions: "1. Plaintiffs do only the discovery they need to meet their certification needs. This is
10 Defendant objects that "terms and conditions" are not specified or identified, rendering this
11 Request vague and ambiguous. Subject to the foregoing specific and general objections, Defendant
12 admits that all of its contracts for talent services are in writing and contain the language required by
13 Labor Code section 1703, and further avers that some customers were signed up using Lion's form of
14 agreement and some using IP AA' s form of agreement, which have variations. Except as expressly
15 admitted herein, Defendant denies the remainder of this request.
18 The document labeled as pages 30 to 97 of the attached appendix are a true and correct copy
19 of the showcase directory which IPAS gave COSIO on or about January 9,2014.
25 actions: "1. Plaintiffs do only the discovery they need to meet their certification needs. This is

46 CASE NO. CGC-16-551337
3 pre-class certification stage of this action. EVID. CODE 210, 350, 950-955,1060, 1061;
5 SUPPLEMENTAL RESPONSE TO REOUEST FOR ADMISSION NO. 44:
9 Dated: April 24, 2017 PUTTERMAN LANDRY + YU LLP

10
11 By:
MICHELLE L. LANDRY
12
Attorneys for Defendants
13 INTERNATIONAL PERFORMING
ARTS ACADEMY, LLC, BARBIZON SCHOOL OF
14 SAN FRANCISCO, INC., LION MANAGEMENT
GROUP, INC., LARRY D. LIONETTI, and
16
17
18
19
20
21
22
23
24
25
26
27
28
47 CASE NO. CGC-16-551337
VERIFICATION
2 I, LENA QUESADA LIONETTI, am Vice President of Lion Management Group, Inc., and
3 authorized to make this verification on its behalf. I have read the foregoing DEFENDANT LION
4 MANAGEMENT GROUP, INC. 'S FURTHER AMENDED AND SUPPLEMENTAL RESPONSE TO
5 PLAINTIFF ANGELICA COSIO'S FIRST SET OF REQUESTS FOR ADMISSION and know its
6 contents. I have personal knowledge of the matters stated therein and declare them to be true or I am
7 informed and believe and on that ground allege that they are true.
8 I declare under penalty of perjury under the laws of the State of California that the foregoing
9 is true and correct. Dated this _ day of April 2017.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
48 CASE NO. CGC-16-551337
VERIFICA TION
its
10
11
PROOF OF SERVICE
2 I am over the age of eighteen and not a party to this action; I am employed by PUTTERMAN
3 LANDRY + YU LLP. My business address is 353 Sacramento Street, Suite 560, San Francisco,
4 California 94111.
5 On April 24,2017, I served the foregoing document(s) described as:
6 LION MANAGEMENT GROUP, INC.'S FURTHER AMENDED AND

SUPPLEMENTAL RESPONSE TO PLAINTIFF ANGELICA COSIO'S FIRST SET OF
7 REQUESTS FOR ADMISSIONS
8 on the interested party(ies) below, using the following means:
9 ELECTRONIC TRANSMISSION based on a court order or an agreement of the

parties to accept service bye-mail or electronic transmission, I caused the
10
documents to be sent to the persons at the e-mail addresses on the attached service
11 list on the dates and at the times stated thereon. I did not receive, within a
reasonable time after the transmission, any electronic message or other indication
12 that the transmission was unsuccessfuL The electronic notification address of the
person making the service is ~;!ill~Iili~'Y.&Q!!!
13
UNITED STATES MAIL by placing a true copy of the document(s) listed above
14 for collection and mailing following the firm's ordinary business practice in a
15 sealed envelope with postage thereon fully prepaid for deposit in the United States
mail at San Francisco, California addressed as set forth below.
16
OVERNIGHT DELIVERY by depositing a true copy of the same enclosed in a
17
D sealed envelope, with delivery fees provided for, in an overnight delivery service
pick up box or office designated for overnight delivery, and addressed as set forth
18 below.
19 MESSENGER SERVICE by causing to be personally delivered a copy of the
document(s) listed above to the person(s) at the addressees) set forth below.
20
21
David C. Parisi AUorneys for Plaintiff
22 Suzanne Havens Beckman
ANGELICA COSIO
PARISI & HAVENS LLP
24 TEL: (818) 990-1299
FAX: (818) 501-7852
25 E-Mail: [email protected]
[email protected]
26
27
28
49 CASE NO. CGC-16-551337
PROOF OF SERVICE
Zack Broslavsky Attorneys for Plaintiff
lonanthan A. Weinman ANGELICA COSIO
2 BROSLA VSKY & WEINMAN, LLP
TEL: (310) 575-2550
4 FAX: (310) 464-3550
5 [email protected]
6 Ethan Preston Attorneysfor Plaintiff

PRESTON LA W OFFICES ANGELICA COSIO
Dallas, Texas 75204
8 TEL: (972) 564-8340
FAX: (866) 509-1197
Attorneysfor Plaintiff
10 Randall B. Aiman-Smith ANGELICA COSIO
Reed W.L. Marcy
11 Hallie Von Rock
Carey A. James
12 AlMAN-SMITH & MARCY P.e.
13 Oakland, CA 94621
TEL.: (510)817-2711
14 FAX: (510) 562-6839
[email protected]
17
18
I declare that I am employed in the office of a member of the bar of this court at whose direction
19
the service was made. Executed On April 24, 2017, at San Francisco, California.
20
21
22
~~
MELANIE K. KING
23
24
25
26
27
28
50 CASE NO. CGC-16-551337
PROOF OF SERVICE
EXHIBIT F
CONSTANCE J. YU (SBNNO. 182704)
3 PUTTERMAN LANDRY + YU LLP
Telephone: (415) 839-8779
5 Facsimile: (415) 727-1363

7 BARBIZON SCHOOL OF SAN FRANCISCO, INC., LION
MANAGEMENT GROUP, INC., LARRY D. LIONETTI, and
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN FRANCISCO
11
12 Case No. CGC-16-551337

ANGELICA COSIO, an individual, on her own
13 behalf and on behalf of all others similarly LION MANAGEMENT GROUP, INC.'S
situated, FURTHER AMENDED AND
14 SUPPLEMENTAL RESPONSE TO
Plaintiff, PLAINTIFF ANGELICA COSIO'S FIRST
15 SET OF FORM INTERROGATORIES
v.
16 Assigned for all purposes:
INTERNATIONAL PERFORMING Hon. Curtis E.A. Karnow
17 ARTS ACADEMY, LLC, a California limited
liability company, BARBIZON SCHOOL OF Dept.: 304
18 SAN FRANCISCO, INC., a California Complaint Filed: April 6, 2016
corporation, ANTHONY LOUIS LIONETTI,
19 LION MANAGEMENT GROUP INC., a
California corporation, LARRY D. LIONETTI,
20 LENA QUESADA LIONETTI, LENA M.
LIONETTI, and DOES 1-100 inclusive
21
Defendants.
22
23
24
25 PROPOUNDING PARTY: Plaintiff ANGELICA COSIO

26 RESPONDING PARTY: Defendant LION MANAGEMENT GROUP, INC.
27 SET NO.: One (1)
28
DEFENDANT LION MANAGEMENT GROUP, INC. 's FURTHER AMENDED AND SUPPLEMENTAL RESPONSE TO
PLAINTIFF ANGELICA COSIO'S FIRST SET OF FORM INTERROGATORIES
Pursuant to section 2030.010 et seq., of the California Code of Civil Procedure ("CCP"),
2 Defendant LION MANAGEMENT GROUP, INC. hereby responds to Plaintiff ANGELICA
3 COSIO'S Form Interrogatories Set One.
4 GENERAL OBJECTIONS
5 A. In addition to the Specific Objections set forth below, Defendant LION
6 MANAGEMENT GROUP, INC. ("LION MANAGEMENT") objects generally to the Interrogatories
7 on several grounds. The objections set forth in this section apply to each Interrogatory. The assertion
8 of the same, similar, or additional objections in the Company's responses to individual
9 interrogatories, or the failure to assert any additional objection to an interrogatory, does not waive
10 any of the General Objections.
11 B. LION MANAGEMENT objects to these Requests pursuant to Code of Civil Section
12 2030.020 on the grounds that these Requests are premature and served on LION MANAGEMENT
l3 before service of a summons.
14 C. LION MANAGEMENT objects to these Requests insofar and to the extent they
15 purport to impose on its obligations other than those imposed by Sections 2017.010 and 2030.210
16 et seq. of the Code of Civil Procedure.
17 D. LION MANAGEMENT objects to these Requests on the grounds to the extent they
18 purport to require disclosure of communications protected by the attorney-client privilege. LION
19 MANAGEMENT further objects to these Requests to the extent that they would require subjective
20 judgment on the part of LION MANAGEMENT and its attorneys, and would further require
21 disclosure of a conclusion or opinion of counsel in violation of the attorney work product doctrine.
22 RESPONSES TO FORM INTERROGATORIES
23 FORM INTERROGATORY NO. 17.1:
24 Is your response to each request for admission served with these Interrogatories an
25 unqualified admission? If not, for each response that is not an unqualified admission:
26 (a) state the number of the request;
27 (b) state all the facts upon which you base your response;
28
(c) state the name, ADDRESS, and telephone number of all PERSONS who have
2 knowledge ofthose facts; and
3 (d) identify all DOCUMENTS and other tangible things that support your response and
4 state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT and
5 thing.
6 RESPONSE TO FORM INTERROGATORY NO. 17.1:
7 LION MANAGEMENT objects to this Form Interrogatory Request to the extent that it seeks
8 information protected from disclosure by the attorney client privilege and/or work product doctrine.
9 LION MANAGEMENT objects to this Request to the extent it purports to require that Responding
10 Party violate or waive privacy rights of third parties protected by the United States Constitution
11 and/or the California Constitution and applicable law. U.S. Const. 4th Amendment; Cal. Const. Art.
12 1, 1; see also Information Practices Act of 1977, Civil Code, 1978 et seq. Responding Party also
13 objects to this Request to the extent that a response to this Request would expose Responding Party to
14 liability by third parties relating to any wrongful disclosure of any third party's constitutional
15 protected privacy rights.
16 LION MANAGEMENT objects to this Request as prematurely served, and fail to abide by
18 Complex Litigation Users' Manual, at pages 2, 3 ("sequencing discovery, with each phase designed to
19 either lead directly to a motion or provide efficacies for the next phase"), and pages 3,4 (Class
20 actions: "1. Plaintiffs do only the discovery they need to meet their certification needs. This is usually
21 brief, as plaintiffs' counsel typically have what they need before the suit is filed. No discovery is
22 taken at this stage regarding anticipated defenses to the certification motion. Then plaintiffs file the
23 certification motion.")
24 SUPPLEMENTAL RESPONSE TO FORM INTERROGATORY NO. 17.1:
25 (a)-(b)
26 AS TO RFAS NOS. 8-13, 27-29,35-39,40,41-44:
27 For over 70 years, Barbizon Modeling and Acting School has provided instructional courses
28 in modeling, acting and personal development. Founded in 1939 on Fifth Avenue in New York City,
New York, by Helen Fraser,l a fashion model and teacher, Barbizon Modeling and Acting Centers
2 are now located in more than 200 markets across the United States, Asia, Canada and South America.
3 Train to BE A MODEL or ... Just Look Like One! is the registered slogan of the iconic
4 company.
5 While many students go to Barbizon to train for the world of modeling and acting, others
6 choose to enter the business world, or use their fashion and beauty experience as a stepping stone to
7 careers as stylists, make-up artists and designers. Others benefit by simply becoming more confident
8 and poised in their personal and professional lives. Barbizon alumni include everyday people,
9 entertainment industry professionals, and world leaders; ranging from Sports Illustrated swimsuit
10 models, movie and TV actors, Miss Americas, and even former Secretary of State Condoleezza Rice,
11 who credits Barbizon in her autobiography, "An American Life", revealing that she enrolled as a
12 "lark", something her mother wholeheartedly endorsed: "She thought I was kind of a tomboy and
l3 maybe it would make me a little more elegant." In the end, Rice said, "actually, I learned a lot"
14 [from the Barbizon school]. (ELISABETH BUM ILLER, AN AMERICAN LIFE, p. 64 (Random
15 House 2007.) Showcase alumni also have gone on to have successful careers in acting, modeling,
16 and singing.
17 Defendant Larry Lionetti is Barbizon's longest-franchisee, first acquiring San Francisco's
18 Barbizon Modeling and Acting Center almost 43 years ago. Mr. Lionetti holds the franchise through
19 Defendant Barbizon School of San Francisco, Inc. He is the sole member and President of Barbizon
20 School of San Francisco, Inc. Barbizon has operated continually in California since approximately
21 1973.
22 Mr. Lionetti and his wife of 31 years, Defendant Lena Q., annually host a well-known
23 industry networking conference in Los Angeles, known as "Showcase," where students from
24 California and elsewhere have an opportunity to learn from, meet with, perform in front of, and be
25 critiqued by licensed agents, managers, and casting directors. The event provides students with an
26
27 I The Barbizon name was developed from Mrs. Fraser's vacations to France where she became
interested in the town of Barbizon, a village outside of Paris known for the 19th-century Barbizon
28 school of painters.
opportunity to get real-world feedback in a safe and nurturing environment, filled with fun.
2 Before ~ 2013, the event was operated by Defendant International Perfonning Arts
3 Academy, LLC, of which Lena Q. Lionetti, is the sole member.
4 In early ~ 2013, the Lionettis began using Lion Management, Inc., which is owned jointly
5 by Larry and Lena Q. Lionetti to operate the International Perfonning Arts Academy and Showcase
6 event in Los Angeles. Larry Lionetti is the President of Lion, Lena Q., is the Vice-President. At that
7 point in time, the Lionettis discontinued the active use of IP AA, LLC.
8 At all relevant times, Defendants Barbizon, IP AA, and Lion have posted the bond required to
9 operate as a talent service in California. (See, http://www.dir.ca.gov/dlse/DLSE-Databases.htm.)
10 Since April 2012, Defendants Barbizon and Lion have entered into written contracts with any
11 artist desiring to utilize their talent service. The written contracts are intended by Defendants to
12 confonn to Labor Code section 1703, and as far as Defendants know, do conform to those
13 requirements, including by posting a conspicuous warning that:
14
THIS IS NOT A TALENT AGENCY CONTRACT. ONLY A
15
TALENT AGENT LICENSED PURSUANT TO SECTION 1700.5 OF
16 THE LABOR CODE MAY ENGAGE IN THE OCCUPATION OF
PROCURING, OFFERING, PROMISING, OR ATTEMPTING TO
17 PROCURE EMPLOYMENT OR ENGAGEMENTS FOR AN
ARTIST. [DEFENDANT] IS PROHIBITED BY LAW FROM
18 OFFERING OR ATTEMPTING TO OBTAIN AUDITIONS OR
EMPLOYMENT FOR YOU. IT MAY ONLY PROVIDE YOU WITH
19
TRAINING, COUNSELING, OR LISTING INFORMA TION
20 (whichever is applicable). FOR MORE
INFORMATION, CONSULT CHAPTER 4.5
21 (COMMENCING WITH SECTION 1701) OF PART 6 OF DIVISION
2 OF THE LABOR CODE. A DISPUTE ARISING OUT OF THE
22 PERFORMANCE OF THE CONTRACT BY THE TALENT
SERVICE THAT IS NOT RESOLVED TO THE SATISFACTION OF
23
THE ARTIST SHOULD BE REFERRED TO A LOCAL CONSUMER
24 AFFAIRS DEPARTMENT OR LOCAL LAW ENFORCEMENT, AS
APPROPRIATE.
25
26 Since :A:Bfl:hB;}t~ 2013 to present, all artists using Lion's talent services have been "signed
27 up" using Lion's fonn of agreement; however, due to a mistake, Cosio, and a handful of others, were
28 signed up using IPAA's contract. The services were not provided by IPAA, and the Los Angeles

DEFENDANT LION MANAGEMENT GROUP, INC.'S FURTHER AMENDED AND SUPPLEMENTAL RESPONSE TO
event she attended Winter 2014 Showcase , was not operated by IPAA. As such, Cosio's contract
2 is different than the majority of other participants of the program from W+2 2013 to present.
3 As part of its services, since W+2 2013, Lion has provided lessons, coaching, seminars,
4 workshops, or similar training for artists, including several months of additional "advanced" training
5 in acting, modeling, singing and dancing. For those desiring to attend, since ~ 2013, Lion has
6 operated a conference in Los Angeles, known as "Showcase" or "Hollywood Showcase". At the
7 event, which takes place over four (4) days, artists and their parents and guests attend seminars and
8 workshops, meeting and learning from industry professionals. The event also hosts "showcases"
9 where talent competes in their chosen category before entertainment professionals who judge the
10 competition for an award at the conclusion of the program. The artists also attend parties and other
11 exciting events.
12 Before attending the Los Angeles event, as a customary business practice from April ~
13 2013 to April6, 2016, Lion personnel collected releases executed by Showcase participants for any
14 physical injury occurring at the event and disclaimers executed by participants representing as
15 follows: "NO PERSON HAS TOLD YOU OR LED YOU TO BELIEVE THAT HS OR ANY
16 MEMBER WOULD PROVIDE ANY SERVICES INCLUDING ANY POTENTIAL
17 EMPLOYMENT FOR YOU IN CONNECTION WITH THE SHOWCASE ... " and "I am fully
18 aware that my attendance and participation at the HS showcase is a learning experience and that no
19 promises of a job or agent signing have been made to me or my parents by my school/training
20 location/agency or its Directors or affiliated representatives or by HS."
21 AS TO RFAS NOS. 8-12:
22 Defendants do not misrepresent the nature of their services or otherwise promise to provide
23 any student with an audition or job opportunity in the entertainment industry. Defendants do not
24 promise to provide an agent or manager for any student. The ternlS of the services to be provided are
25 set forth in Defendants' contracts and other agreements with its students, which expressly disclaim
26 that such are being provided. To the extent that students have an opportunity to meet with or audition
27 before any producer, director, casting director, or any associate thereof, or any other person who
28 makes, or is represented to make, decisions for the process of hiring artists for employment as an
artist, or any talent agent or talent manager, or any associate, representative, or designee thereof,
2 Defendant maintains, in accordance with Labor Code section 1703.4 written evidence of the
3 supporting facts, including the name, business address, and job title of all persons conducting the
4 meeting or audition, and the title of the production and the name of the production company. Each
5 Showcase program booklet distributed to students identifies the entertainment industry professionals
6 attending Showcase.
7 As it relates to Cosio, Defendants deny that Cosio was promised an audition or job
8 opportunity or that she was told that anyone would secure her a talent agent or talent manager, as she
9 alleges. Cosio's family friend, Brandy Calderon, who "scouted" Cosio denies that she made any such
10 promises or offers to Cosio. Ms. Calderon did not tell Cosio, or anyone, that they could get a job in
11 the entertainment industry or an audition, agent or manager. When she told people about the
12 program, she would present it like any other activity such as gymnastics.
l3 To Defendant's knowledge, no person affiliated with Defendant made any representations to
14 Cosio that she would receive an audition or job opportunity or that they would secure her a talent
15 agent or talent manager and never has Cosio made any such complaint to Defendants. In fact, Cosio
16 indicated complete satisfaction with her experience.
17 Defendants lack personal knowledge as to what Cosio read on the Internet or what she was
18 told by third parties about Barbizon and Lion's services; however, Defendants' internal procedures
19 prohibit any employee from making any representation that the company will provide an audition for
20 work in the entertainment industry, or as a means to secure a talent agent or manager. Defendants
21 further provide students with disclosures that only a licensed talent agent may procure work for them.
22 RFAS NO. 13:
23 Defendant denies that it offers, in exchange for a fee, auditions. Defendant does not charge
24 any person to audition for its program and does not send students out on auditions for work in
25 exchange for a fee.
26 RFA NOS. 27-28:
27 Defendant charges its students for its talent training services, but does not charge any fees for
28 auditions, jobs, or employment opportunities.

RFANO.29:
2 As discussed above, Cosio executed an IPAA contract when in reality her showcase was
3 operated by Lion. Cosio and a handful of other students were the subject of this error. Most ofthe
4 putative class executed a different contract.
5 RFAS NOS. 35-39:
6 The images attached to the appendix as pages 9-13 of the attached appendix do not accurately
7 reflect the website at h!1J12JL:li!l.~.lli~~~r1. The images have been cropped or separated out from
8 other text such that they do not accurately reflect a user's experience.
9 RFA NOS. 40-44:
10 Although it makes all requisite statutory disclosures, Defendant denies that it made uniform
11 representations to the putative class, or that all members of the putative class were told the same thing
12 or were exposed to the same statements. Each class member is individually recruited and will have a
l3 different experience depending on how they come to the schooL Further some putative class
14 members may review the company website and some may not (and some may review parts of the
15 website, while others review other parts). The process of enrollment is highly interactive. Each
16 student may be subject to additional and different disclosures and disclaimers about Defendants'
17 services depending on each student's individual circumstances and his or her (and their children's)
18 questions asked, and answers given.
19 (c)-(d)
20 (c) The following persons have knowledge of those facts: Larry Lionetti and Lena Q.
21 Lionetti. They may be contacted through their counsel of record.
22 (d) The following DOCUMENTS support Lion's Response: marketing material; talent
23 service contracts, and other agreements executed by any customer; training material; payment
24 records; showcase directories and video of the event; corporate documents related to Lion; scripts and
25 presentations (including video); some customer satisfaction surveys; and various other misc. records
26 related to its rendition of services, including but not limited to class schedules, informational flyers,
27 contact information fonns, sponsor letter, photo shoot packet, etc. Lion's records are maintained in
28 drop box files and on go ogle drive. While Lion maintains templates, Lion does not routinely keep
copies of personalized incidental records, such as completed tryout forms, completed sponsor letters,
2 scout cards, or other school material completed by, or sent to, students. Before the filing of this
3 action, Lion maintained hard copy records in its Seattle office of documents signed by all Showcase
4 participants (including Cosio) attending the L.A. event, including copies of releases by Showcase
5 participants (for any physical injury occurring at the event) and disclaimers executed by Showcase
6 participants representing as follows: "NO PERSON HAS TOLD YOU OR LED YOU TO BELIEVE
7 THAT HS OR ANY MEMBER WOULD PROVIDE ANY SERVICES INCLUDING ANY
8 POTENTIAL EMPLOYMENT FOR YOU IN CONNECTION WITH THE SHOWCASE ... " and "I
9 am fully aware that my attendance and participation at the HS showcase is a learning experience and
10 that no promises of a job or agent signing have been made to me or my parents by my school/training
11 location/agency or its Directors or affiliated representatives or by HS." In January 2016, however,
12 Zynn Jones, National Education Director, who operates out of the Seattle office, without permission
l3 or warning, destroyed the hard copies of these records. Ms. Jones' computer has been retrieved and
14 forensically imaged and Defendant is investigating what records, if any, can be retrieved from this
15 computer. After learning of Ms. Jones' actions, Defendant has changed its procedure and now
16 maintains copies of these releases and disclaimers at its San Francisco office.
17 AMENDED SUPPLEMENTAL RESPONSE TO FORM INTERROGATORY NO. 17.1:
18 AS TO RFAS NOS. 35, 36, 37 AND 41:
19 RFAS NOS. 35-37:
20 The images attached to the appendix as pages 9-11 of the attached appendix do not accurately
21 reflect the website at !illJ[l;il1!!~.lli~~~r.L. The images have been cropped or separated out from
22 other text such that they do not accurately reflect a user's experience. In appendix page 9, plaintiff
23 has a screen grab of an image that does not reflect the interactivity of the website. On the actual
24 website, while the young girl is holding a phone, the background is continually changing, scrolling
25 through 9 different images that more readily capture the viewer's attention. The screen grab also
26 distorts the placement of the image. On the website, the girl holding phone photo is under a drop
27 down bar where a person can input their name, age, zip, state, phone and email, and upload a photo.
28
Plaintiffs Appendix 9 shows the young girl blocking the drop down menu such that portions of the
2 website are completely obscured. This is not the user's experience.
3 Plaintiff s Appendix 10 is just an isolated image file taken from the website. It is one of 9
4 changing images on the home screen. On the website, the image appears for just a few seconds before
5 it changes to another image. There are also other elements on the page which are not reflected in the
6 screen grab including other content and disclaimers about the services.
7 Plaintiffs Appendix 11 is just an isolated image file taken from the website. The image is
8 found on the last tab of the website, under "Contact". On the actual website, the image is partially
9 blocked by the drop down bar where a person can input their name, age, zip, state, phone and email,
10 and upload a photo. There are also other elements on the page which are not reflected in the screen
11 grab including other content and disclaimers about the services.
12 As to RFAs No. 41:
l3
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FURTHER AMENDED SUPPLEMENTAL RESPONSE TO FORM INTERROGATORY
NO. 17.1:
2
10
11
12
l3
14
15
16
17
18
19
20
21
22 Dated: April 24, 2017 PUTTERMAN LANDRY + YU LLP
23
24 By:
MICHELLE L. LANDRY
25
Attorneys for Defendant
26 INTERNATIONAL PERFORMING
27 SAN FRANCISCO, INC., LION MANAGEMENT
GROUP, INC., LARRY D. LIONETTI, and
its
10
11
PROOF OF SERVICE
4 California 94111.
5 On April 24, 2017, I served the foregoing document( s) described as:
6 LION MANAGEMENT GROUP, INC. 'S FURTHER AMENDED AND

SUPPLEMENTAL RESPONSE TO PLAINTIFF ANGELICA COSIO'S FIRST SET OF
7 FORM INTERROGATORIES

10
12 that the transmission was unsuccessful. The electronic notification address of the
person making the service is ~;;!lli~P.!J1ill'Y.&Qill
l3
14 for collection and mailing following the firm's ordinary business practice in a
16
17 sealed envelope, with delivery fees provided for, in an overnight delivery service
18 below.
D document(s) listed above to the person(s) at the addressees) set forth below.
20
21
David C. Parisi
22 Suzanne Havens Beckman Attorneys for Plaintiff
PARISI & HAVENS LLP ANGELICA COSIO
24 TEL: (818) 990-1299
FAX: (818) 501-7852
[email protected]
26
27
28
PROOF OF SERVICE
Zack Broslavsky Attorneys for Plaintiff
Jonanthan A. Weinman ANGELICA COSIO
2 BROSLA VSKY & WEINMAN, LLP
TEL: (310) 575-2550
4 FAX: (310) 464-3550
5 [email protected]
6 Ethan Preston Attorneysfor Plaintiff

PRESTON LA W OFFICES ANGELICA COSIO
Dallas, Texas 75204
8 TEL: (972) 564-8340
FAX: (866) 509-1197
Attorneysfor PlaintjIJ
Reed W.L. Marcy
11 Hallie Von Rock
Carey A. James
12 AlMAN-SMITH & MARCY P.C.
l3 Oakland, CA 94621
TEL.: (510)817-2711
14 FAX: (510) 562-6839
[email protected]
17
18 I declare that I am employed in the office of a member of the bar of this court at whose direction
19 the service was made. Executed on April 24,2017, at San Francisco, California.
20
21
22 MELANIE K. KING
23
24
25
26
27
28
PROOF OF SERVICE
EXHIBIT G
CONSTANCE J. YU (SBN NO. 182704)
3 PUTTERMAN LANDRY YU LLP
Telephone: (415) 839-8779
5 Facsimile: (415) 727-1363

7 BARBIZON SCHOOL OF SAN FRANCISCO, INC.,
LION MANAGEMENT GROUP INC. LARRY D. LIONETTI,
8 and LENA QUESADA LIONETTI
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 FOR THE COUNTY OF SAN FRANCISCO
11
Case No. CGC-16-551337
12 ANGELICA COSIO, an individual, on her own
behalf and on behalf of all others similarly DEFENDANT LION MANAGEMENT
13 situated, GROUP, INC.'S SUPPLEMENTAL
RESPONSE TO PLAINTIFF ANGELICA
14 Plaintiff, COSIO'S FIRST SET OF SPECIAL
INTERROGATORIES
15 v.
Assigned for all purposes:
16 INTERNATIONAL PERFORMING Hon. Curtis E.A. Karnow
ARTS ACADEMY, LLC, a California limited
17 liability company, BARBIZON SCHOOL OF Complaint Filed: April 6, 2016
SAN FRANCISCO, INC., a California
18 corporation, ANTHONY LOUIS LIONETTI,
LION MANAGEMENT GROUP INC., a
19 California corporation, LARRY D. LIONETTI,
LENA QUESADA LIONETTI, LENA M.
20 LIONETTI, and DOES 1-100 inclusive
21 Defendants.
22
23
24
25
26
27
28
DEFENDANT LION MANAGEMENT GROUP, INC. 's SUPPLEMENTAL RESPONSE TO
PLAINTIFF ANGELICA COSIO'S FIRST SET OF SPECIAL INTERROGATORIES
Pursuant to section 2030.010 et seq., ofthe California Code of Civil Procedure ("CCP"),
2
Defendant LION MANAGEMENT GROUP, INC. hereby further responds to Plaintiff ANGELICA
3
COSIO'S Special Interrogatories Set One.
4
GENERAL OBJECTIONS
5
A. In addition to the Specific Objections set forth below, Defendant LION
6
MANAGEMENT GROUP, INC. ("LION MANAGEMENT") objects generally to the Interrogatories
7
on several grounds. The objections set forth in this section apply to each Interrogatory. The assertion
8
of the same, similar, or additional objections in the Company's responses to individual
9
interrogatories, or the failure to assert any additional objection to an interrogatory, does not waive
10
any of the General Objections.
11
B. LION MANAGEMENT objects to these Requests pursuant to Code of Civil Section
12
2030.020 on the grounds that these Requests are premature and served on LION MANAGEMENT
13
before service of a summons.
14
C. LION MANAGEMENT objects to these Requests insofar and to the extent they
15
purport to impose on its obligations other than those imposed by Sections 2017.010 and
16
2030.210 et seq. of the Code of Civil Procedure.
17
D. LION MANAGEMENT objects to these Requests on the grounds to the extent they
18
purport to require disclosure of communications protected by the attorney-client privilege. LION
19
MANAGEMENT further objects to these Requests to the extent that they would require subjective
20
judgment on the part of LION MANAGEMENT and its attorneys, and would further require
21
disclosure of a conclusion or opinion of counsel in violation of the attorney work product doctrine.
22
23
SUPPLEMENTAL RESPONSES TO SPECIAL INTERROGATORIES
24
SPECIAL INTERROGATORY NO.1:
25
INDICATE the DOCUMENTS which LION MANAGEMENT has preserved in connection
26
with this case.
27
(As used in these Special Interrogatories, (1) "LION MANAGEMENT" means
28 Defendant Lion Management Group Inc., whether or not doing business under the
1 CASE NO. CGC-16-551337
fictitious business name "Hollywood Showcase", and its predecessors, successors,
agents, partners, attorneys, servants, employees, assignees, lessees, affiliates, and/or
2 anyone acting on behalf of it, and/or any affiliate, subsidiary, parent or related
corporation, partnership or entity, and/or anyone acting for or on behalf of any such
3 subsidiary, related corporation, parent, partnership, entity, or natural person: (2)
"DOCUMENT" means, consistent with Code of Civil Procedure section 20 16.020(c)
4 and Evidence Code section 250, handwriting, typewriting, printing, photostating,
photographing, photocopying, transmitting by electronic mail or facsimile, and every
5 other means of recording upon any tangible thing, any form of communication or
representation, including letters, words, pictures, sounds, or symbols, or combinations
6 thereof, and any record thereby created, regardless of the manner in which the record
has been stored; and (3) "INDICATE" means to state as much of the following as is
7 possible with respect to DOCUMENTS responsive to this Interrogatory: (a) the general
category by which BARBIZON references DOCUMENTS responsive to this
8 Interrogatory during the ordinary course of business (by way of example: account
notes, computer manuals, correspondence, etc.); (b) any specific name for
9 DOCUMENTS responsive to this Interrogatory which BARBIZON uses during the
ordinary course of its business; the form or format of the DOCUMENT (by way of
10 example: paper, photograph, tape recording, or if an electronic DOCUMENT-file
type); (c) the storage device containing the DOCUMENT (if the DOCUMENT is a
11 paper document, then the folder, file cabinet, or other container, or ifthe DOCUMENT
is electronic, then the computer hard drive, portable hard drive, DVD, CD flash drive,
12 etc.); (d) the file path for any electronic DOCUMENT; and (e) the street address where
the storage device may be found.)
13
14
RESPONSE TO SPECIAL INTERROGATORY NO.1
15
Responding party LION MANAGEMENT GROUP INC. ("LION MANAGEMENT")
16
objects to this Request to the extent that it seeks information protected from disclosure by the
17
attorney client privilege and/or work product doctrine. A litigation hold is in place, but the
18
requesting party is not entitled to the identification of the documents that have been preserved. LION
19
MANAGEMENT further objects to this Request as prematurely served, and fail to abide by the
20
Court's procedures for discovery in complex litigation and guidance for class action matters (see
21
Complex Litigation Users' Manual, at pages 2,3 ("sequencing discovery, with each phase designed
22
to either lead directly to a motion or provide efficacies for the next phase"), and pages 3, 4 (Class
23
24
usually brief, as plaintiffs' counsel typically have what they need before the suit is filed. No
25
26
plaintiffs file the certification motion.")
27
28
2 CASE NO. CGC-16-551337
LION MANAGEMENT further objects that that the scope of Plaintiffs requested discovery
2
is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
3
violates the Discovery Act. Accordingly, LION MANAGEMENT reserves all rights and objections
4
until the parties, through counsel, are able to meet and confer regarding the appropriate scope of the
5
discovery at this pre-class certification stage of this action. Evid. Code 21 0, 350, 950-955, 1060,
6
1061; CCP 2017.010 et seq., 2018.030 (work product), 2019.210 (trade secrets).
7
LION MANAGEMENT further objects that an answer to this interrogatory would necessitate
8
the preparation or the making of a compilation, abstract, audit, or summary of or from the documents
9
of defendant, and the burden or expense of preparing or making it would be substantially the same for
10
plaintiff as for the responding party.
11
(As used in these Special Interrogatories, (1) "DESCRIBE" means to state as much of
12 the following as is possible with respect to the actions responsive to this Interrogatory:
(a) the name, address, telephone number, and employer of every natural person who
13 performed or participated in a responsive action (or attempted to do so); (b) the storage
devices which were searched (or attempted to be searched) for responsive
14 DOCUMENTS (if the DOCUMENTS are a paper document, then the folder, file
cabinet, etc., or if the DOCUMENT is electronic, then the computer hard drive,
15 portable hard drive, DVD, CD flash drive, etc.), the file path for any electronic
DOCUMENT, and the street address where the storage device may be found; (c) the
16 method or means used to search each such storage device (by way of example:
manually reviewed each document in the storage device, searched an electronic file
17 database using the following command, etc.); and (d) the DOCUMENTS which each
such person located (or attempted to locate) in each such storage device using each
18 such search method; (2) "IPAS" means the same person(s) or entity(ies) identified as
"International Performing Arts Showcase" in the documents included in the attached
19 appendix (expressly including Lion Management Group Inc., whether or not doing
business under the fictitious business name "Hollywood Showcase"), its predecessors,
20 successors, agents, partners, attorneys, servants, employees, assignees, lessees,
affiliates, and/or anyone acting on behalf of it, and/or any affiliate, subsidiary, parent
21 or related corporation, partnership or entity, and/or anyone acting for or on behalf of
any such subsidiary, related corporation, parent, partnership, entity, or natural person.)
22
23
SUPPLEMENTAL RESPONSE TO SPECIAL INTERROGATORY NO.1
24
Subject to the foregoing objections, Lion responds: Lion maintains copies of its business
25
records, including marketing material; talent service contracts, and other agreements executed by any
26
customer; training material; payment records; showcase directories and video of the event; corporate
27
documents related to Lion; personnel files and payroll records of its employees and independent
28
3 CASE NO. CGC-16-551337
contractors; scripts and presentations (including video); some customer satisfaction surveys; and
2
various other misc. records related to its rendition of services, including but not limited to class
3
schedules, informational flyers, contact information forms, sponsor letter, photo shoot packet, etc.
4
Lion's records are maintained in dropbox and googledrive files. While Lion maintains templates,
5
Lion does not routinely keep copies of personalized incidental records, such as completed try out
6
forms, completed sponsor letters, scout cards, or other school material completed by, or sent to,
7
students. Before the filing of this action, Lion maintained hard copy records in its Seattle office of
8
documents signed by all Showcase participants (including Cosio) attending the L.A. event, including
9
copies of releases by Showcase participants (for any physical injury occurring at the event) and
10
disclaimers executed by Showcase participants representing as follows: "NO PERSON HAS TOLD
11
YOU OR LED YOU TO BELIEVE THAT HS OR ANY MEMBER WOULD PROVIDE ANY
12
SERVICES INCLUDING ANY POTENTIAL EMPLOYMENT FOR YOU IN CONNECTION
13
WITH THE SHOWCASE ... " and "I am fully aware that my attendance and participation at the HS
14
showcase is a learning experience and that no promises of a job or agent signing have been made to
15
me or my parents by my school/training location/agency or its Directors or affiliated representatives
16
or by HS." In January 2016, however, Zynn Jones, National Education Director, who operates out of
17
the Seattle office, without permission or warning, destroyed the hard copies of these records.
18
Ms. Jones' computer has been retrieved and forensically imaged and Defendant is investigating what
19
records, if any, can be retrieved from this computer. After learning of Ms. Jones' actions, Defendant
20
has changed its procedure and now maintains copies of these releases and disclaimers at its San
21
Francisco office.
22
23
DESCRIBE the actions that LION MANAGEMENT has taken to locate DOCUMENTS
24
responsive to Plaintiff Angelica Cosio's Demands for Production of Documents No. 17 to LION
25
MANAGEMENT (i.e., all DOCUMENTS concerning marketing ofIPAS's services, including (a)
26
DOCUMENTS constituting advertisements and/or marketing ofIPAS's services; and (b) any policy,
27
guideline, manual, instruction set, procedure, and/or practice which required, prompted, applied to,
28
4 CASE NO. CGC-16-551337
controlled, or governed any action IPAS and/or LION MANAGEMENT (including any of its owners,
2
directors, officers, agents, partners, attorneys, servants, employees, assignees, affiliates, and/or
3
anyone acting on behalfIPAS, LION MANAGEMENT, and/or any affiliate, subsidiary, parent or
4
related corporation, partnership or entity, and/or anyone acting for or on behalf of any such
5
subsidiary, related corporation, parent, partnership, entity, or natural person, including any talent
6
scout) took to market IPAS's services).
7
RESPONSE TO SPECIAL INTERROGATORY NO.2:
8
Responding party LION MANAGEMENT objects to this Request to the extent that it seeks
9
information protected from disclosure by the attorney client privilege and/or work product doctrine.
10
Requesting party is not entitled to the description of actions undertaken by LION MANAGEMENT
11
with the assistance of its counsel in connection with this Request or other discovery. LION
12
13
14
15
16
17
18
19
20
21
is overbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
22
23
24
discovery at this pre-class certification stage of this action. Evid. Code 210, 350, 950-955, 1060,
25
26
27
28
5 CASE NO. CGC-16-551337
Late Arrival Flyer JAN 2014 Participants.docx; HS - MOCK Participant Date Flyer.doc; HS -
2
PROFESSIONAL PHOTO SHOOT PACKET. (Updated July 2013) PDF.pdf; HS - Resume Example
3
with Details.doc; HS - Sponsor Letter 2014 KARINA.doc; HS - Transportation, Hotel & Showcase
4
Info Jan2014.doc; HS - Wardrobe Guidelines.doc.
5
Ms. Jones also revealed that before this action was filed, because of space issues in the Seattle
6
office, she destroyed hard copies of Lion's business records. Ms. Jones did not ask or receive
7
permission to destroy files. It is unknown exactly what records she once possessed that were
8
destroyed. However, before the filing of this action, Lion maintained hard copy records in its Seattle
9
office of documents signed by all Showcase participants (including Cosio) attending the L.A. event,
10
including copies of releases by Showcase participants (for any physical injury occurring at the event)
11
and disclaimers executed by Showcase participants representing as follows: "NO PERSON HAS
12
TOLD YOU OR LED YOU TO BELIEVE THAT HS OR ANY MEMBER WOULD PROVIDE
13
ANY SERVICES INCLUDING ANY POTENTIAL EMPLOYMENT FOR YOU IN
14
CONNECTION WITH THE SHOWCASE ... " and "I am fully aware that my attendance and
15
participation at the HS showcase is a learning experience and that no promises of a job or agent
16
signing have been made to me or my parents by my school/training location/agency or its Directors
17
or affiliated representatives or by HS."
18
Among the items destroyed were copies of releases and disclaimers signed by Showcase
19
participants.
20
Ms. Jones' computer has been retrieved and forensically imaged and Defendant's counsel is
21
investigating what records, if any, can be retrieved from this computer. After learning of Ms. Jones'
22
actions, Defendant changed its procedure and now maintains a hard copy file in San Francisco of
23
such releases and waivers.
24
As discussed above, Lion generally maintains copies of its business records, including
25
marketing material; talent service contracts, and other agreements executed by any customer; training
26
material; payment records; showcase directories and video of the event; corporate documents related
27
to Lion; personnel files and payroll records of its employees and independent contractors; scripts and
28
7 CASE NO. CGC-16-551337
presentations (including video); some customer satisfaction surveys; and various other miscellaneous
2
records related to its rendition of services, including but not limited to class schedules, informational
3
flyers, contact information forms, sponsor letter, photo shoot packet, etc.
4
Pay records are in FM as well as the merchant online terminal. Here is what a search for
5
Cosio's payment information looks like:
6
10 1i1114153!114254 User: L.ena_star
11
12
6251
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
incidental records, such as completed try out forms, completed sponsor letters, scout cards, or other
2
school material completed by, or sent to, students.
3
At this time, and before merits discovery, Lion has not attempted to collect and review its
4
employees, agents and contractors email which would be an expensive and time consuming
5
undertaking. There may be records related to this action in these persons email accounts. All such
6
persons have been instructed to preserve all documents that might be relevant to the claim.
7
SUPPLEMENTAL COURT ORDERED RESPONSE TO SPECIAL INTERROGATORY NO.
8
2:
9
The following searches were conducted by LION to locate DOCUMENTS responsive to
10
Cosio's Demands for Production of Documents No. 17 (DOCUMENTS constituting advertisements
11
and/or marketing ofIPAS's services! DOCUMENTS constituting employment policies, manuals, etc.
12
concerning LION's marketing oflPAS's services):
13
Lena Marie Lionetti and Lena Q. Lionetti searched two mac desktop computers (known as
14
"Stephanie's old computer" and "Kelly's old computer") at Lion's office in San Francisco, CA.
15
Search terms were not used. DOCUMENTS before April 2012 were excluded. Lena Marie and Lena
16
Q. mechanically viewed DOCUMENTS that reside on those computers and selected those that they
17
believed were responsive to Plaintiff's request for Production of Documents No. 17.
18
Lena Marie and Lena Q. also performed a manual search of Lion's dropbox accounts, which
19
are registered in Lena Q.'s name. Search terms were not used. DOCUMENTS before April 2012
20
were excluded. Lena Marie and Lena Q. mechanically viewed DOCUMENTS and selected those that
21
that they believed were responsive to Plaintiff's request for Production of Documents No. 17.
22
Lena Q. Lionetti also searched for DOCUMENTS by accessing Lion's Vinmeo (a video-
23
sharing website in which users can upload, share and view videos) account. She did not use any date
24
or search term limiters.
25
Lena Marie Lionetti also searched google documents, which are under Lena Q.'s account.
26
Search terms were not used. A manual review was undertaken to locate DOCUMENTS that she
27
believed were responsive to Plaintiff's request for Production of Documents No. 17.
28
1 CASE NO. CGC-16-551337
As part of the ordinary course of business, Lena Marie Lionetti usually asks scouts for their
2
scripts a few times a year to make sure the company is abiding by the AB 1319 law as well as having
3
them on file. To locate these historical scripts, Lena Marie searched her old company email and her
4
current company email using the search terms "script" and "scout script." Once she located them, she
5
continued to search her emails in and around the class dates. She also searched her google drives
6
attached to those company emails with the same terms.
7
After the Court's March 3 Order, and in an effort to locate any updated scripts, on March 6,
8
2017, Lena Marie Lionetti emailed Kanieta Russel, Sheree Dyer, Michele Haglin, Gina Hiraizumi,
9
Bianca Gutierrez, Jamie Sorenson, and Koda King. Any scripts received in response to Lena Marie's
10
March 6 email were forwarded to counsel for production.
11
12
DESCRIBE the actions that LION MANAGEMENT has taken to locate DOCUMENTS
13
responsive to Plaintiff Angelica Cosio's Demands for Production of Documents No. 22 to LION
14
MANAGEMENT (i.e., DOCUMENTS sufficient to show the legal name, principal residence
15
address, date of birth, and driver's license number and state of issuance thereof of every talent scout,
16
and the name each talent scout used while soliciting customers for LION MANAGEMENT and/or
17
IPAS, since April 6, 2012.)
18
RESPONSE TO SPECIAL INTERROGATORY NO.3:
19
Responding party LION MANAGEMENT objects to this Request to the extent that it seeks
20
information protected from disclosure by the attorney client privilege and/or work product doctrine.
21
Requesting party is not entitled to the description of actions undertaken by LION MANAGEMENT
22
with the assistance of its counsel in connection with this Request or other discovery. LION
23
24
25
26
27
28
11 CASE NO. CGC-16-551337
2
3
4
5
is ovcrbroad, harassing, and seeks confidential proprietary information, and is therefore improper and
6
7
8
discovery at this pre-class certification stage of this action. Evid. Code 21 0,350,950-955, 1060,
9
10
11
DATED: March 30, 2017 PUTTERMAN LANDRY + YU LLP
12
13
By:
14
Attorneys for Defendants
15
INTERNATIONAL PERFORMING
16
SAN FRANCISCO, INC.,
LION MANAGEMENT GROUP INC.
17
LARRY D. LIONETTI,
and LENA QUESADA LIONETTI
18
19
20
21
22
23
24
25
26
27
28
12 CASE NO. CGC-16-551337
VERIFICATION
2
I, LENA MARJE LIONETTI, am Marketing Director of Lion Management Group, Inc., and
3
authorized to make this verification on its behalf. I have read the foregoing DEFENDANT LION
4
MANAGEMENT GROUP, INC.'S SUPPLEMENTAL RESPONSES TO PLAINTIFF ANGELICA
5
COSIO'S FIRST SET OF SPECIAL INTERROGATORIES and know its contents. I have personal
6
knowledge of the matters stated therein and declare them to be true.
7
I declare under penalty of perjury under the laws of the State of California that the foregoing is true
8
and correct. Dated this ~1 day of March 2017.
9
10
11 LENA MARJE LIONETTI
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
VERIFICA nON
PROOF OF SERVICE
4 California 94111.
5 On March 31, 2017, I served the foregoing document(s) described as:
6 DEFENDANT LION MANAGEMENT GROUP, INC.'S SUPPLEMENTAL
7 RESPONSE TO PLAINTIFF ANGELICA COSIO'S FIRST SET OF SPECIAL
8 INTERROGATORIES

11
l3 that the transmission was unsuccessful. The electronic notification address of the
person making the service is M;rruwllli~Y&Q!!l
14
15 D for collection and mailing following the firm's ordinary business practice in a
17
18
D sealed envelope, with delivery fees provided for, in an overnight delivery service
19 below.
D document(s) listed above to the person(s) at the addressees) set forth below.
21
Zack Broslavsky Attorneys/or Plaintiff
22 Jonanthan A. Weinman ANGELICA COSIO
BROSLAVSKY & WEINMAN, LLP
23 11755 Wilshire Boulevard, Suite 1250 E-MAIL ONLY
Los Angeles, California 90025
24 TEL: (310) 575-2550
FAX: (310) 464-3550
25
[email protected]
26
27
28

PROOF OF SERVICE
David C. Parisi Attorneys/or Plaintiff
Suzanne Havens Beckman ANGELICA COSIO
212 Marine Street, Suite 100 E-MAIL ONLY
TEL: (818) 990-1299
4 FAX: (818) 501-7852
E-Mail: [email protected]
5 [email protected]
6 Ethan Preston Attorneys/or Plaintiff

PRESTON LAW OFFICES ANGELICA COSIO
Dallas, Texas 75204 E-MAIL AND UNITED STATES MAIL
8 TEL: (972) 564-8340
FAX: (866) 509-1197
Attorneys/or Plaintiff
Reed W.L. Marcy
11 Hallie Von Rock E-MAIL ONLY
Carey A. James
12 AlMAN-SMITH & MARCY, P.c.
7677 Oakport St. Suite 1150
l3 Oakland, CA 94621
TEL: 510.817.2711
14 FAX: 510.562.6830
E-Mail: [email protected]
[email protected]
17
I declare that I am employed in the office of a member of the bar of this court at whose direction
18
the service was made. Executed on March 31, 2017, at San Francisco, California.
19
20
21
22
23
24
25
26
27
28

PROOF OF SERVICE
EXHIBIT H

Sh()Wc:aSE~slJ!.\.udlltiorlS (blaSEld on seIE~ctl(m
names in
(1 )
(1)
in IVIOClel &
MOClel & LI.("Tnrc Ulrf!ctolrv
room
pal:;kclqe is in
<..::innlo occ;up.anc;y availlable
'-'''-,'-',''-...... &
A aPIPolntrnellt 1J~\lI"YIontc are
room
10
in
8
are Irronthl uU'Irlnr.f'1 in
6
in
5
a in
3
are eligible
2
some
1
I
ov"' ...... nk"" are:
are pelDPle
"
"
" errIPI()vE!d or own a
I"'lrlth;,nn F:tnrAF: nrrl\lIrlO one or more

an
in
is someone sellected
C't",rli"",.. a career in ""1"\1"'1""1,,,,,,.. or as a

participat:ion in
in selectmg
I
Orientation
An,:>nt,/I\/I:::ln:::.npr Panel: Q&A "The Entertainment Biz"

Parent Seminar I: "Children in Film"
- 1V.VVtJ"" LA Live: Room Launch
l~nll~lu 1
8:30am
9:00am 10:00am Seminar: "For the & Model in You"
10:00am -11:00am r"UlIVllclV Seminar: "Fierce & Flawless"
Monol1oglles, TV TV H:o,;:" It\!
Dance Showcase
9:00am 10:00am Music Seminar: "Don't the Music"

9:30am Hair & IIIICl.I\CUIJ
1 Commercial Print
Fashion Print
Swimwear
Model & Talent Overview
Showcase. & I\II<>n<:>,",ar Introduction
Red Awards & Dinner
4
9:00am 10:00am Own Your Career: 1\/Ir1i\1in,n Forward
10:00am 10:45am Own Your Career: Forward II
10:00am 1 Callbacks Invite
12:010pm - 1 Callbacks
Angeles. it
......"""'+'.... N an arena wl1,p-rF!'
careers. I aPIPlalua
hltllll"oI:lI success.
EXHIBIT I
International Petiormlng Arts ShClWCose Is a
oerlbrnnino arts This program
vQCaliclool guidance career evaluotlOn through cO<lChiing.
nthAr slmlltlf training.
JCIII'11UCllrv9
. Hotel
.
.
.. Enlmnc::e Indlustiry PlrO'Etssi'QncJIs 1[AClents and Seminars and WClrksOOI)S ttl'OI.tghout the event
. Heodshat In distributed to IndtlmY PrO'fes!;lonais, Partlcli:)ol1lts & ReGlldered Guests
. at at LA lIVEI
" &
Artist:
Record
inslallmenl payment due of each month thereafter until on

reverse of document, I OU1111011;Ze Inlerjl1alionol PEmOlrmirig Arts Showcase to Ouj'OlYlotically
Intemmional Ar1s Showcase

Los Studios
4'3-1923" www,TalentShowcase.tv" www, Fa(~.I::l,oollc:.c,om/Talenl$h;c)w,cQs,e
P.o, Ilcm71\l,
234567 8
5 678 10
Hollywood Slowcase isa talent tra
to
and service
I ing a
,vocational guidance and career evaluation
nArfnrminn
Artist Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ T _ _ __ ht: _ __
Add ress: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ 3ate:
Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Mobile Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Email: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Ernel'gency
Extra Room: v _ _ _ _ _ _ __
Balance of $ _ _ _ _ _ _ _ to be paid in _ _ _ monthly installment n::l limA n'l!'\ $-----,

Rrst installment payment due on and every _ _ _ of each month thereafter until paid in full.
on reverse ofthisdocument, I authorize Hollywood Slowcase to automatically processpaymentsby the method indicated
below, Total participation fees must be in full by Dec. 1,2013. Returned/declined paymentsare to a
dollar cha rge,

ACCT# _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ SlC: _ _ __
Card Holder 88#,' _ _ _ _ _ _ _ _ _ __ D,L#.' _ _ _ _ _ _ _ __ Slowcase Ke(;el[)t#, _ _ _ _ _ _ _ __

I Instructions: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
HolllVVlloc)d Slowcase
493-1923 www.TalentSlowcase.tv" www. Facebook.comlTalentSlowcase
Mailing Address: P.O, Box 719, San Francisco CA 94104
lhe 4-day event, located in los Angeles, iSLue largest networking and
resource opportunity for industry professionals- agents, managers,
casting directors, choreographers and record executiv~>s.
Parent or Legal Guardian Print (if artist is under 18) Parent or Legal Guardian Signature (if artist is under 18) DAle
Talent (Signature) Hollywood Showcase Rep. (Print) Hollywood Showcase Rep. (Signature)
Hollywood PO Box 719, San Francisco CA 94104 Tel: (888) 493-1923
My signature is to make application to the Hollywood Showcase, for participation at the Hollywood Showcase Winter 2015 Event. 1he event is scheduled
to take place January 9 - 12,2014 at the Millennium Biltmore Hotel in Los CA. This agreement becomes valid when accepted and executed
by a Hollywood Showcase Representative. Upon execution of this agreement, I authorize payments to be made to Hollywood Showcase through ACH/
EFT using the credit card information listed on the front side of this agreement. Returned/declined payments are subject to a thirty dollar service
charge. HOLLYWOOD SHOWCASE IS A TALENT COUNSELING AND TRAINING SERVICE. THIS IS NOT A TALENT AGENCY CONTRACT.
ONLY A TALENT AGENT LICENSED PURSUANT TO SECTION 1700.5 OF THE LABOR CODE MAY ENGAGE IN THE OCCUPATION
OF PROCURING, OFFERING, OR ATTEMPTING TO PROCURE EMPLOYMENT OR ENGAGEMENTS FOR AN ARTIST. HOLLYWOOD
SHOWCASE IS PROHIBITED BY LAW FROM OFFERING OR ATTEMPTING TO OBTAIN AUDITIONS OR EMPI~OYMENT FOR YOu. IT MAY
ONLY PROVIDE YOU WITH TRAINING. FOR MORE INFORMATION, CONSULT CHAPTER 4.5 (COMMENCING WITH SECTION 1701) OF
PART 6 OF DIVISION 2 OF THE I.ABOR CODE. A DISPUTE ARISING OUT OF THE PERFORMANCE OF THE CONTRACT BY THE TAI.ENT
SERVICE THAT IS NOT RESOI.VED TO THE SATISFACTION OF THE ARTIST SHOULD BE REFERRED TO A LOCAL CONSUMER AFFAIRS
DEPARTMENT OR I.OCAL I~AW ENFORCEMENT, AS APPROPRIATE. YOUR RIGHT TO CANCEl.: . You may cancel this contract
and obtain a full refund, without penalty or obligation, if notice of cancellation is given, in writing, within 10 business days from the above date or the
date on which you commence utilizing the services under contract, whichever is longer. For purposes of this section, business days are Monday through
Friday. To cancel this contract, mail via certified mail with the USPS a signed and dated copy of the following cancellation notice or any other written
notice of cancellation to Hollywood Showcase, PO Box 719, San Francisco CA 94104. NOT LATER THAN MIDNIGHT OF:
If you cancel, all fees you have paid must be refunded to you within 10 business days after ofthe cancellation notice to the talent service.
A refund may not be obtained after the lO-day cancellation period has expired. Effective withdrawal date is the postmark date. CANCELLATION
NOTICE I hereby cancel this contract.
Artist Signature Dated: Hollywood Showcase is in compliance with applicable bond
requirements. A bond in the amount of"#y thousand dollars ($50,000) is held and is posted with the Labor Commissioner (Bond # 57BSBGI7017).
Each Artist is provided with a copy of this contract and program dates before becoming obligated to pay any fee. This Participation Agreement represents
the entire between the parties respecting the services and and any and all oral or written No
employee of Hollywood Showcase or any other parties may modify or otherwise alter the terms of this agreement. You are entitled to an exact copy of this
agreement. Hollywood Showcase reserves the right to class dates and/or class times and/or venue in which the classes will take because of
difficulties beyond its controL We reserve the to amend this contract as circumstances dictate provided no such amendment shall diminish the services
provided. ]be first date of service commences with a photo shoot analysis with a Hollywood Showcase Scout at no charge, with no obligation to pay. The
second class commences with the date on reverse of this document. Any failure to take the classes shall not relieve the student/parent of the obligation of this
contract. The student/parent agrees to pay any and all costs associated with the collection of any monies owed, or any rights hereunder in the event
the buyer fails to sanle. It is the student/parent or legal under this agreement or transferred to
any other person or student. The student/parent or guardian agrees to abide by the rules and of this agreement. Hollywood Showcase will include
your image in the Program Book given to attending industry professionals. The registration fee does not include airfare, transportation to or from the airport,
parking fees, room service, alcoholic food (other than offered at scheduled times), or additional hotel incidentals and excursions you
wish to enjoy while in Los Angeles, CA. Hollywood Showcase does not guarantee any income or employment as a result this event. Talent may
not guests that have not and been paid tor, including hotel stay. ALL Talent under the age of 18 are to bring a and re~~istered
guest (parent or If the Artist is 18 years or older and not registering a guest; Showcase will pair you with a talent of the same
delTIogr<lph.ic for double occupancy. Paid and guests will receive the hotel accommodations (shared with one other Talent Palrticina,nt)
from January 9 12,2014; scheduled meals; entrance to and talent educational and seminars the event. Attend the Red
Carpet at LA LIVE!; Dinner & at Awards Gala and the Finale Show Event.
Artist Name: _ _ _ _ _ _ _ _ _ _ _ _ _ $ ._ _ _ _ DOB _ _ _ Age _ _ F / M Height: _ _
Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ City: _ _ _ _ _ _ _ _ _ _ State: _ _ Zip: _ _ __
Phone: (......_ _- ' _ _ _ _ _ _ _ _ _ _ _ _ _ Mobile Phone: ('--_ _-' _ _ _ _ _ _ _ _ _ _ _ __
Email: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.Emergency Contact: _ _ _ _ _ _ _ _ _ _ _ _ __
Registered Guest: _ _ _ _ _ _ _ _---'$ _ _ _ _ Registered GUest: _ _ _ _ _ _ _ _ _ _ _$ _ __
Cea"tna Schilling
$JpefrriOdaMaJ~ne .~
. Mchae Thrner .
ABC Fa:nlly's' (leaf
Next Workshop Date: ,...,....""":"'-';"""":"'-......--..-.;.,..;."..;.,..;.".;...,..0.
'[IDPre~ShoWcaseSer'llce$
lIDp,.epa~an9h fortalentShowcas'~
. ,[ill Jihbtoshooi ....
IPAS will provide the artist June 28,2012 through July 1,2012:
.[ill Hotel accommodations (double occupancy)
m:JPerformance in up to 5 showcases of the artist choice, providedyoumeet showcase requirem~nts
~m:J Sch eduled meals
,[illf:ntranCe to Industry Professionals (Agents and Managers) Seminars and Workshops throug hout the event
,[ill Heaclshot in IPAS Program Book dlstfibuteqto Industry Professionals, Participants & Registered Guests
'{IDAttendan ce at th e Red Carpet Opening Night.at LA LIVE!
.I:ID Dinner & Dancing a~ Awards Gala andTalerit Showcase
Artist: $,_ _ _ _ _ _ _ Guests: $_ _ _ _ _ _ _ Other: $_ _ _ _ _ _ _ Extra Room: $._ _ _ _ _ __

Total Fees: $ Paid Today: $._ _ _ _ _ __ Record # _ _ _ _ _ _ _ _ _ _ _ _ __
Balance of $ to be paid In monthly installment payments of $

First installment payment due on _ _ , _ _ , _ _ and every ___ of each month thereafter until paid in
full. By signing on reverse of this document, J authorize International Performing Arts Showcase to automatically
process payments by the method indicated below. Total participation fees must be paid in fun by May 31,2012.
OOSA OMc ITBlsc CWv1EX ACCT# Exp:_'_SIC: _ _
Special Instructions: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
IrtEr~ icra RrfanirgA"ts Srucase

l!:s,ll(@esQrtEf S ldc61201\1'1lith3.aiteT.J00.losArg3~, 0\90017
888.686.7827 'wmlJaa1~h:lIa3etv LlON000996
,": " :, :,', '"
Thelnte.rnationalperfcrming A rtsShC1Nca$e
The.4~avevent,locat~dlnLos Angeles, is the largest networ~il1gal1d
resource opportunityJor inclustry professionals- agents, ntflnagers,
casting directors, choreographers and record executive~.
I I
Parent or Legal GmiI'dhm (print) Parent orLegal Guardian Signature (ifartist is under 18) DATE
Atiist (Signature) !PAS Representative (Print) IPAS Represelltative(SigllatjJre)

International Performing Arts Showcase, PO Box 719, San Francisco CA 94104 Tel: 888.686.7827
My signature is to make application to the Intel"llational Performing Arts Academy, L.L.C. dba international Performing Arts$ho\\\~ase (IPAS), foj"
participation at the IPAS SU!llmer 2012 E\enL rn1 event is scheduled to take place June 28 through July I, 2012 at the Millennium Biltmore Hotel in
Los Angeles,CA [llls agreellle!lt becomes valid when accepted and executed by an IPASRepresentative. Upon execution of this agreel11e!lt, I authorize
payments to be Imide to International Performing Arts Acade!llY through ACHIEFT using the credit card information listed 011 the front side of this
a~;reement.Returned/declined pil.yUle!lts are ~tlbject to a h\'e!lty-ffi1 dollar service charge. INTERNATIONAL PERFORMING ARTS ACADEMY IS
A TALENT COUNSELING AND TRAINING SERVICE. THIS IS NOT A TALENT AGENCY CONTRACT. ONLY A TALENT AGENT LICENSED
PURSUANT TO SECTION 1700.s OF THE LABORCODEMAYENGAGE IN THEOCCUPATIONOFPROCURING,OFFERING,ORATTEMPTING
TO PROCURE EMPLOYlvlENT OR ENGAGEMENTS FOR AN ARTIST. INTERNATIONAL PERFOR1vHNG ARTS ACADEMY IS PROHIBlTED
BYLAW FROM OFFERING OR ATTE11PTING TO OBTAIN AUDITIONS OR E11PLO\'MENT FOR YOU. IT MAY ONLY PROVIDE YOU WITH
TRAINING. FOR MORE INFOru.1ATION, CONSULT CHAPTER 4.5 (COMMENCING WITH SECTION 1701) OF PART 6 OF DIVISION 2 OF
THE LABOR CODE. A DISPUTE ARISING OUT OF THE PERFORMANCE OF THE CONTRACT BY THE TALENT SERVICE THAT IS NOT
RESOLVED TO THE SATISFACTION OF THE ARTIST SHOULD BE REFERRED TO A LOCAL CONSUi\1ERAFFAIRS DEPARTMENT ORLOCAL
LAW ENFORCEMENT, AS APPROPRIATE. YOUR RIGHT TO CANCEL: . You may cancel this contract and obtain a full rdund,
without penalty or obligation, if notice of cancellation is giWll, iIi \Wiling, within 10 business days from the aboye date or the date Olt \\hich you
commence utilizing the services under contract, whichenr is longer. For purposes of this section, business days are Monday through Friday. To
c[lllcel this contract, mail via cel'til:ill:J mail ",ith the USPS 1\ signed and dated copy of the following cancellation notice or any other written notice of
cllncellation to International Perform ing Arts Academy, PO Box 719, San Francisco CA 9410<1. NOT LATER THAN MIDNIGHT OF: . If
you cancel, all fees you hm'epaid must be refunded to you within 10 business day!> a[]J: deliyeryofthe cancellation notice to the talent service. A refund
may not be obtained aOB the lO-day cancellation period has expired. EliatiYe withdrawel date is the postmark date. CANCELLATION NOTICE I
hereby cancel this contract. Artist Signature Dated: International Performing Arts
Academy is in compliance with applicable bond requirements. A bond in the [lmount ofCIJpthousand dollars ($50,000) is held and is posted with the
Labor Com missioner (Bond # SB006500169). Each Artist is pro\ided \\ith a copy ofthis contract and program dates before becoming obligated to pay any
fee. llih Participation Agree!ltent represe!lts the entire understanding bet\\\!e!l the parties respecting the senices pro\1ded, and replaces and supersedes allY
and all oralor \witten understandings. No employee ofIPAS or all),other parties may modify or othem;se alter the te!lllS ofthis agree!uent. You are e!ltitled
loan exact copy of this agreement. Intemational Perfollnjng Arls Acade!nyjese!Yes the right to change class dates (\l1el / or class times nnd/or yenue in which
the dassl!$ \\ill take place because of djmJulties beyond its control. We reserYe the right to amend this contract as circumstances dictate pro\ided no such
amendment shall diminish the sen;ces proyid.:d. ffi1 OOt date of service commences with a photo shoot analysis with an rpAS Scout at no charge, \\ith no
obligatioll to pay. m1 second class commences with the date 011 re\'erS<! of this document. All)' failure to take the classes shall not relieye the student/parellt
of the obligation ofthis contract. DI1 shHlentiparent agrees to pay any lind all costs associated with the collection ofall),lUonies o\\\!d, or enforcing allY right s
hereunder in the e\'ent the buyer fails to pay the same. It is fill'ther agreed that the student/parent or legal guardian's rights under this agreement may not be
assigned or transfe!'red to allY otlH'l: person or student. rn:b ~illdelll/parellt or guardian agre<!s to abide by the rules and regulations of this agreement. IPAS
"ill include your image in the Program Book gko!n to attending industry profes~ionals. I}[k registration fee does not include airfare, transportation to or
Iiom the airport, parking fe<!s, room sen1ce, Ellcoholic beyeragcs, food (olhe!' than o[lliJed at scheduled times), or additional hotel illcicientals and sight-seeing
excursions you \\;sh to e!tjoywhile in Los Angeles, CA. []1 International Perfomling Arts Showcase (IPAS) does not gU[lf[lutee any income or e!nployment as
a result of attrnding this ewnt. Talent may not bring guests that haw not registered and been paid fot, incruding hotel ~iay. ALL Talent under the age of 18 are
required to bring a paid and registered guest (parent or gUllrdian). Hthe Artist is 18 years or older and not regi,te!inga guestj IPASwill pau'YOu with a talent of
the ~megender and de!llOgraphic for double occupancy. Paid and registered guests will receh-c the following: hotel accommodations (shared "ith oneIPAS
Tale!lt Participant) from June 28 through July 1,2012; scheduled meals; e!lIrancc to modeling and talent educational workshops and seminars throughout the
eYe!lt. Altend the Red Carpet Opening Night at LA LIVE!; Dinner & Dancing at Awards Gala and Talent Sho\\1~ase.
UON000997
Artist Name: _ _ _ _ _ _ _ _ _ _ _ _ _ $ 0 0 8 _ ' _ ' _ Age _ _ F' M Height _ _
Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ City: state: _ _ Zip: _ _ __
Phone: ( _ _- ' _ _ _ _ _ _ _ _ _ _ _ _ _ Moblle Alone: ('-_ _--' _ _ _ _ _ _ _ _ _ _ _ __
Ernail: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~EmergencyContact: _ _ _ _ _ _ _ _ _ _ _ _ __
Registered Guest: _ _ _ _ _ _ _ _ _$ _ _ _ _ Registered Guest: _ _ _ _ _ _ _ _ _ _ _.$ _ _ __
O~ai1nas: hilling
&IpermooelMagazlne
IPASwlllprovide the artist February 7J 2013 through February 10,2013:

Hotel accommodations (quadruple occupancy)
PerfOm1anc e in up to 5 showc ases of the artist choic e, provided you meet showcase req uirements
S: heduJed meals
Entrance to Industry Profess[onaJs(Agerits~nd Managers)~minars and Workshops throughoultheevent
Heaqshot in JPAS Prog ram80okdi~tributedto Industry Professionals, Partic [pants & ~gisteredGuests
.' Attendance at the Red Carpet Opening Night at LA UV8
.' Dinner & Dancing at Awarqs Gala and TalentS10wc ase
Artist: $ Guests: $_ _ _ _ _ __ Other: $_ _ _ _ _ __ B:.lra Room: $._ _ _ _ _ __

Total Fees: $_ _ _ _ _ _ _ Pald Today: $_ _ _ _ _ __ Record # _ _ _ _ _ _ _ _ _ _ _ _ __
Balance of$ _ _ _ _ _ _ to be paid In ___ monthly installment paymentsof $ _ _ _ _ _-'
Rrst Installment payment due on _ _ I __ I _ _ and every _ _ _ of eac h month thereafter until paid In full. By signing on
reverse ofthlsdocument, I authorize International Perfonning ArtsS10wcase to automatically

processpaymentsby the method Indicated below. Total partie Ipatlon feesmust be paid In full by January 1, 2013.
ACCT# _______________________________ B:.p: ____ , _ _ SC: ______
Card Holder 88#: _ _ _ _ _ _ _ _ __ D.L.#:_______________ S10wcase Recelpt#:_ _ _ _ _ _ __

~eclallnstructlons: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
International performing Arts 91o\'/c sse

LosAngeles Centerstudlos '. " .......................
a88.~86.7827 www.TalentSlOwcase.tvoww..v.Facl:jb(lok.com!TalentShowc ase LlON000998
': .. '.:.
Thelnt erriafiohaJ>Pe rfcr riling A rlsShPNC~se

111l4~daYt3\fenkl()catedin Los Angeles, is the largest n~tvyor~in~.ahq
resource opportunityfcuindustryprofessiona Is-- a g t3~ts,l11aD~geJs,
casting directors, choreographers and record executives.
Paren! or Le gal Guardian Aint (if artist is under 18) Parent or Legal Guardian Sgnature (if artist is under 18)
--'_._._' DATE
Thlent(9gnature) IPAS R:l pre san ta tive (Print) IPASR:lpresantalive (Sgnature)

International Petfonning At1s, PO Box 719, 150 Sutter Street, San FranciscoCA 94104 Tel: 888.686.7827
l...1y signature is tonlake application to the International Pe.:fofllling Arts Academy, L.L.c. dba Itltet'uational Perfonlling Arts Show!;ase(IPAS), for
participation at the JPAS Winter 1013 Event. [TI1 e\"ent is scheduled to take place February 7, 1013 through February 10,1013 at the Millenniulll
BiItU10l;C Hotel ill Los Angeles, CA. [ill s agreement becomes valid when accepted and executed by an IPA,) Representatin. Upon execution of this
agreeilient,I authorizepaYJllellts to be made to IntefJlationai Performing Arts Academy through ACHfEFT using the credit card information ii5ted
on the frontside ofthis agreement. RetufIled/dedined payments are subject to a twenty.lli1dollar senice charge. INTERNATIONALPERFOlUvllNG
ARTS ACADEMY IS A TALENT COUNSELING AND TRAINING SERVICE. THIS IS NOT A TALENT AGENCY CONTRACT. ONLY A TALENT
AGENT LICENSED PURSUANT TO SECTION 1700.5 OF THE LABOR CODE l\1AY ENGAGE IN THB OCCUPATION OF PROCURING,
OFFERlNO, OR ATTEMPTING TO PROCURE EMPLOyrvIENT OR ENGAGEIvlENTS FOR AN ARTIST. INTERNATIONAL PERFORMING ARTS
ACADEMY IS PROHIBITED BY LAW FROM OFFERING OR ATTEMPTING TO OBTAIN AUDITIONS OR BMPLOYMENT FOR YOU. IT MAY
9NLY PROVIDE YOU WITH TRAlNING. FOR MORE INFOIUvIATION, CONSULT CHAPTER 4.5 (COMMENCING WITH SECTION 1701) OF
PARr 6 OF DIVI 510N2 OF THB LABOR CODE. A DISPUTE ARISING OUT OF THE PERFORIvlANCE OF THE CONTRACT BY THE TALENT
SERVICE THAT IS NOT RESOLVED TO THB SATISFACTION OF THE ARTIST SH OULD BE REFERRED TO A LOCAL CONSUMER AFFAIRS
DEPARTMENT ORLOCAL LAW ENFORCEMENT, AS APPROPRIATE. YOUR RIGHT TO CANCEL: . You lIlay cancel this contract
and obtain a full refund, without penalty or obligation, if notice of cancellation is gh"en, in writing, ,,"ithin 10 business days from the abo\"c date or
the date on which you commence utilizing the sel'\ices lInder contrnct, whiche\"er is longer. For purposes of this section, business days are Monday
through Friday. To cancel this contract, mail \la ~rtiilll! mail \\lth the USPS a signed and dnted copy of the following cancellation notice or any other
mittetillotice of cancellation to International PerfonningArts Academy, PO Box 719, 150 Sutter Street, San Francisco CA 94104. NOT LATER THAN
MIDNIGHT OF: . If you cancel, all fees you have paid lIlust be refunded to you within 10 business days aW:l deliyery of the cancellation
IlOtic.! to the talent senl~. A refund may not be obtailled aWl the lO-day cancellatioll period has expired, Etm:tiYe withdrawal date is the postmark
datc, CANCELLATION NOTICE I hereby cancel this contract. Artist Signature Datcd:
Intematioll111 Peffol"ming Arts Academyis ill compliance with applicable bond requirements. A bond ill the alllount of~thousand dollars ($50,000)
is held and is p05ted \\'ith the Labor Commissioner (Bond # SB006500169), Ellch Al'ti5t is pro\ided \\ith a copy oft his contract and program dates before
becoming obligated to pay any fee. Dlls Participation Agreement represents the etltire understanding between the parties respecting the senice:> proyjded,
and replaces and supersedes any and all oral or mitten under5tandings, No employee of IPAS or any othet' parties may modify 01' otherwise alter the terms
ofthis agreement, You are.entitied toan exact copy ofthisa,greement. International Pet-forJnillg Arts Academy resen'es the right to change class dates and!
or class timesaild/or ,'cnue in \,ilich the classes will take place because of diillJuhies berond its control. We reserYe the right to amend this contract as
circUlmtllilces dictate pl:ovided 110 stIch amendment shaU diminish the sen'ices pro\ided. [[b Cilt date of serYlce C01lll1\ellces with a photo shoot analysis
\\'ith ru\ 1PAS Scout at 110 charge, with no obligation to pa)~ llib 5econd class commences with the date on re\'erse of this document. Any failure to take the
classes shall not relie,'e the student/parent oflhe obligation of this contract. [ll1 student/parent agrees to pay any and 311 costs associated with thecolkctioll of
anYllIonies o\\"e<l,or enfol'cillg any rights hereunder in the eyent the buyer fails to pay the same. It is liH1hel' agreed that the 5tudentf pafent or legal guardian's
rights unde!. this agreetllenlmay not be assigned or transferred to rulY other person or studenLllik student/parent or guardian agrees to abide by the rules
and regulations of this agreement. IPAS \,iIl include your image in the Progrnm Book gi\"en to attending industry profes~ionals, 0Ib registration fee does
not include airfare, trampoItalion to or from the airpol"t, parking fees, room ser\'ice, alcoholic be\"erages, food (other than oUtled at scheduled times), or
additional hotel incidentals and sight.seeing excuroions you wi~h to enjoy while ill Los Angeles, CA. [l[b International Performing Al1s Sho\\"ca.~e (IPAS)
does not gllarantee any income or employment as a result of attending this e\"ent. Talent lIlay not bring gue5ts that ha\'e not registered and been paid for,
including hotel stny. AIL Talent under the age of 18 are required to bring a paid and regi~tered guest (parent or guatdian). Ifthe Arti~t is 18 years or older und
!lot registering a gue5tj IPAS will pair you \\ith a talent ofthe sallie gender and demographic for double occupancy. Paid and registered guests will receiYe the
follo\\;ng: hotel accollllllodations (!shared with one IPAS Talent Participant) Ji-om February 7, 2013 through February 10, 2013; scheduled 111 <:31s; entrance
to modeling and talent educational workshops and seminars tlu'oughout the e\enl. Altend thc Red C(l.rpet Opening Night at LA liVE!; Dinner & Dallcillg at
Awards Gala and Talent ~lo\\'case. "
LlON000999
afOW Artist TalentAgreement
Hollywood Slowcase Isa talent training and counseling servlc e providing a perfomllng artsprogram. Thlsprogram Islntended
to provide careercounseling, vocational guidance and career evaluation through coaching, seminars, workshopsand other
simila r training.
Artist Name: _ _ _ _ _ _ _ _ _ _ _ _ _ $_ _ __ D08 _ _ _ _ _ _ Age _ _ Ff M Height: _ __
Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ City: _ _ _ _ _ _ _ _ _ _ 3ate: _ _ 21p: _ _ __
Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Mobile Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Bnail: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.8nergency Contact:._ _ _ _ _ _ _ _ _ _ _ _ _ __
Reg istered Guest: _ _ _ _ _ _ _ _ _.$ _ _ _ _ Reg Istered G ue st: _ _ _ _ _ _ _ _ _ _ _.$ _ _ __
Next Wo rkshop Date: .....,...."---~-'-'----.-.....,....__.,......,....__.,.------

PreS'lowcaseSe"rvlces Preparation for Hollywood S'lowcase o Fhotoshoot
Hollywood Showcase will provide the artl$t January 9 -12,2014:

rnJHotelilccommodations(quadruple occupancy)
ffi)Performance in up to 5 $howc asesofthe artist chpice, provided you meet s/1owc are requirements
ffi)~ hed uled mea Is
ffiJEntranc e to Ind ustry Professionals(Agentsand Ma,..agers) Semlnarsand W0r}{sh0psthroughout the event
lID He ad shot in Hollywo od S'lowc a se Progra mBookdistrib uttad to Ind ustry Pro fe ssion a Is, Pa rtlc ipa nts& Reg istered
Guests
.lli1AUenctanceat the Red Carpet Opening Night atLAUVE!
illIDinner & Danc Ing at AwardsGafa and Finale ;t!owEvent
Artist: $........,..._ _ _ _...;......, Gue&~$ _____~_____ Othe r: $._ _ _ _ _ __ Extra R:)om: $_ _ _ _ _ __
Tota I Fe es: $-'-'--_ _ _ _ _ _ Pa Id Tod ay: $._ _ _ _ _ __ Record # _ _ _ _ _ _ _ _ _ _ _ _ _ __
Balance of$ _ _ _ _ _ _ to be paid in ___ monthly installment paymenlsof$ _ _ _ _ _ _.

Rrst installment payment due on _ _ I _ _ I _ _ and every ___ of each month thereafter until paid in full. By signing
on reverse of this document, I authorize Hollywood Slowca se to automatically process payments by the method indicated
below. Total participation fees must be paid in full by Dec. 1, 2013. Returned/declined payrnentsare rubject to a thirty
dolla r charge.
ACCT# _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Exp: _ _ _ _ _ _ SC: _ __
Card Holder 88#: _ _ _ _ _ _ _ __ D.L#:, _ _ _ _ _ _ _ __ Slowcase Receipt # :_ _ _ _ _ _ __

tpecial Instructions: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Hollywood Slowcase
(888) 493-1923 www.TalentSlowcase.tv www. Facebook.comlTalentSlowcase
Maifing Address: P.O. Box 719, &In Francl9:;o CA 94104
LlON0001000
::~~rll;~ :~~.- (~;~.;~; 8;;~~ 8 ~n~t:. ~~~]: ~~:;3 t~1::~ ~~1 ~~:~j ~1 }~;;Hl~r~ :~lt ~~~ ~f:. ~~~~~. ;~:~1 ~~ ~;.~ ~~~ =~rl~~1 r~~:~;~{~~~:~f~~~ ~~:~ rd~ ~ ~~~ ;=j~
r;
~~l~;:~~J: ~jl ril~:~ ~~:~~= ~J :~~: rt~J rl ~t~~ f~~~~ ~~1 ~j~ ~~;~:E~t~f.~ ~~; r~~;f.~ ~r~~i~~~; r~.~ ~~~~:: .~~ ~d ;~~ t1~1~r ~f~~; i~~ ~~:~~.:~~ f::~~:
casting directors, choreographers and record execut'i'v~s.
Parent or Legal Guardian Print (if artist is under 18) Parent or Legal Guardian Sgnature (if artist is under 18) DAlE
Ta lent (Sg nature) HoJlywood Slowcase Pap. (Prin!) Hollywood Slowcase ~p. (Sgnature)
Hollywood Showcase, PO Box 719, San Francisco CA 94104 Tel: (888) 493-1923
My signature is to makcapplication to the Hollywood Showcase, for participation Elt the Hollywood Showcase Winter 20 14 Evcnt. illbevent isscheduled
to takc place January 9 - 12,2014 Elt the Millennium Biltmore Hotel in Los Angeles, CA. illlis agreement becomes valid when accepted and executcd
by a Hollywood Showcasc Representative. Upon execution ofthis agreement, I authorize paymcnts to be madeto Hollywood Showcase through ACH/
EFT using the crcdit card information listed on thc front side of this agreement. Returned/declined payments are subjcct to a thirty dollar service
charge. HOLLYWOOD SHOWCASE IS A TALENT COUNSELING AND TRAINING SERVICE. THIS IS NOT A TALENT AGENCY CONTRACT
ONLY A TALENT AGENT LICENSED PURSUANT TO SECTION 1700.5 OF THE LABOR CODE MAY ENGAGE IN TilE OCCUPATION
SHOWCASE IS PROHIBITED BY LAW FROM OFFERING OR ATTEMPTING TO OBTAIN AUDITIONS OR EMPLOYMENT FOR YOU. IT MAY
ONLY PROVIDE YOU WITH TRAINING. FOR MORE INFORMATION, CONSULI' CHAPTER 4.5 (COMMENCING WITH SECTION 1701) OF
PART 6 OF DIVISION 2 OF THE LABOR CODE. A DISPUTE ARISING OUT OFTHE PERFORMANCEOFTl-IE CONTRACT BY THE TALENT
SERVICE THAT IS NOT RESOLVED TO THE SATISl-'ACTION OF THE ARTIST SHOULD DE REFERRED TO A LOCAL CONSUMER AFFAIRS
DEPARTMENT OR LOCAL LAW ENFORCEMENT, AS APPROPRIATE. YOUR RIGHT TO CANCEL: . You may cancel this contract
and obtain a full refund, without penalty or obligation, ifnotice of cancellation is given, in writing, within 10 business days from the above date or the
Friday. To cancel this contract, mail via certiUlli mail with the USPS a signed and dated copy of the following cancellation notice or any other written
notice ofcancclIation to Hollywood Showcase, PO Dox 719, San Francisco CA 94104. NOT LATER THAN MIDNIGHT OF:
If you cancel, all fees you have paid must be refunded to you within 10 business days aWl delivery of the cancellation notice to the talent service.
A refund may not be obtained aWl the 1Oday cancellation period has expired. Ernltive withdrawal date is the postmark date. CANCELLATION
NOTICE] hereby cancel this contract.
requirements. A bond in the amount ofrn:IP thousand dollars ($50,000) is held and is posted with the Labor Comm issioner (Bond # 57DSBGI70 17).
Each Artist is providcd with a copy of this contract and program dates before becoming obligated to pay any fee. ITUs Participation Agreement represents
the entire understanding between the parties respecting the services providcd, and replaces and supersedes any and all oral or written understandings. No
employee of Hollywood Showcase or any other parties may modify or otherwise aIter the terms of this agreement. You arc entitled to an exact copy ofthis
agreement. Hollywood Showcase rcscrves the right to change class dates and/or class times and/or venue in which the classes will take place because of
dillilulties beyond its control. We reserve the right to amend this contract as circumstances dictate provided no such amendment shall diminish the services
provided.lli1 [illt date of service commences with a photo shoot analysis with a Hollywood Showcase Scout at no charge, with no obligation to pay. ill1
second class commences with the date on reverse ofthis document. Any failure to take the classes shall not relieve the student/parent ofthe obligation ofthis
contract. illb student/parent agrees to pay any and all costs associated with the collection of an)' monies owed, or enforcing any rights hereunder in the event
the buyer tails to pay the same. It is further agreed that the student/parent or legal guardian~ rights under this agreement may not be assigned or transferred to
any other person or student. ill1 student/parcnt or guardian agrees to abide by the rnles and regulations ofthis agrcement. Hollywood Showcase will include
your image in the Program Book given to attending industry professionals. m:1 registration fcc does not include airfare, transportation to or from the airport,
parking fecs, room service, alcoholic beverages, food (other than oOiled at scheduled times), or additional hotel incidentals and sight-seeing excursions you
wish to enjoy while in Los Angeles, CA. Hollywood Showcase does not guarantee any income or employmcnt as a result of attending this event. Talent may
not bring guests that have not registered and been paid for, including hotel stEly. ALL Talent under the age of 18 are required to bring a paid and registercd
guest (parent or guardian}.lfthe Artist is 18 ycars or older and not registering a guest; Hollywood Showcase will pElir you with a talent ofthe same gender and
demographic fur double occupancy. Paid and registered guests will reecive the following: hotel accommodations (sharcd with one other Talent Participant)
from January 9 - 12, 2014; scheduled meals; entrance to modeling and talent educational workshops and seminars throughout the event. Attend the Red
Carpet Opcning Night at LA LIVE!; Dinner & Dancing at Awards Gala and the Finalc Show Event. LlON001 00 1
'I
,
1
"".,
1
Hollywood Ehowcase Isa talent training and counseling service provIding a perrormlng artsprogram. lhlsprogram Islntended
to provide career counseling, vocational guidance a nd career evaluation throug h coaching, sem inars, workshops and other
simila r training.
Artist Name: _ _ _ _ _ _ _ _ _ _ _ _ _ $._ _ __ DOB _ _ _ __ Age _ _ F/ M Height _ __
Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ City: _ _ _ _ _ _ _ _ _ _ Sate: _ _ Zip: _ _ __
Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Mobile Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Bna iI: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _-----'Bnergency Conta ct._ _ _ _ _ _ _ _ _ _ _ _ _ __
Reg iste red Guest: _ _ _ _ _ _ _ _ _$ _ _ _ _ Reg istered G ue st: _ _ _ _ _ _ _ _ _ _ _$ _ _ __
Next Workshop Date: _ _-'--_..--_ _ _....-_;.......;;,;.......;;,_ _ _ _ __

Pre9'lOwease Services Preparati()n for Hollywo()dSlowease ftlotoshoot
Hollywood Slowcase will provide the arti~t January 15 - 18, 2015:

[illHotelaeeommodations (q ua d ruple oee upancy)
[illPerformanee in up to 5 showeasesof the artisteh()iee, provld ed you meetshowease requirements
[ill&; hed uled mea Is
[illEntranee to Industry Professionals (Agents and Managers) teminarsand Workshopsthroughout the event
illlHead shot in Hollywo od Slowe a se Progra ml300 kdistlib uted to Ind ustry Pro fessiona Is, Partie ipa nts& Registe red
Guests
ffiJAttendanee at the Red Carpet Opening Night atLP. UV8
dlliOinner&Daneing at AwardsGalaalld Rnale 910"" Event
Artist: $ Gue~S:$. _ _- c -_ __ other: $,_ _ _ _ _ __ Extra R::lo m: $._ _ _ _ _ __
Total Fees: $._ _ _ _ _ _ _ Pa Id Todaoy; $._ _ _ _ __ Record # _ _ _ _ _ _ _ _ _ _ _ _ __
Balance of $ _ _ _ _ _ _ to be paid in ___ monthly installment paymentsof $ _ _ _ _ __

First installment payment due on _ _ I _ _ / _ _ and every ___ of each month thereafter until paid in full. By signing
on reverse of thisdocument, I authorize Hollywood Slowcase to automatically processpaymentsby the method indicated
below. Total participation fees must be paid in full by Dec. 15,2014. Returned/declined payments are rubject to a thirty
dollar charge.
ACCT# _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Exp: _ _ _ _ _ _ SC: _ __
Card Holder 88#:, _ _ _ _ _ _ _ __ D.L#:. _ _ _ _ _ _ __ Slowcase Receipt #: _ _ _ _ _ _ __

~eciallnstructions: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Hollywood Showcase
(888) 4931923' www.TalentShowcase.tv www. Facebook.comlTalentShowcase
MaOing Add res;; P.O. Box 719, S3 n Francisco CA 94104
LlON001002
:::~~;.~ ;~1:::;~ ~1 :~~. ;~:~~;:E 5~~t;: ~ t.];~ ;~~ ~:~:f~ .~;5il ~t;~~. ~~1~~ fl~:H! ~:~~;~:B:: ~ r~ .~~~:~:~ ~~ ~rf~ :~~t ~n~t~~::~ f~r.~~~~~~;~ ;~~r~:~
!n~ ffi.~'] l~~ ~~~l; ~ :~~~] ~~::t) ~:t;U~f5~~~~~~(. ~[a::r ~~~n~~~ ~~~~~~~;~~~~: ~~t; ~~O ~~~~:i.~ t.] $fa ~~~. ~~ffi::: ~~~:~ ~~~~n1~~~; :~~i:~~ W~;~~:H! ~+~r~~=
.~.t ~11~:!n;5~;~ ;~I ~ 5~:f~ ~:~t: a~~.1 t~ ~r5;~ W~ ~E~:;~ ~~~~ ~ ~rag~ r~~ ;~l r~5:~~ :5~:Ei~ r3 ~ftJ! :o.~:~ tj ;Lij nir~~:~~1JJ~~
I I
Parent or Legal Guardian Print (if artist is under 18) Parent or Legal Guardian Sgnature (if artist is under 18) DA1E
Talent (9g nature) Hollywood Slowca se Rep. (Print) Hollywood S10wcase Rep. (Sg nature)
My signature isto make application to the Hollywood Showcase, for pArticipation At the Hollywood Showcase Winter 2015 Event.llibevent is scheduled
to take place January 15 - 18,2015 at the Millennium Biltmore Hotel in Los Angeles, CA. Wls agreement becomes valid when accepted and executed
by a Hollywood Showcase Representative. Upon execution of this agreement, I authorize payments to be made to Hollywood Showcase through ACl-I/
EVr using the credit card information listed on the front side of this agreement. Returned/declined payments are subject to a thirty dollar service
charge. HOLLYWOOD SHOWCASE IS A TALENT COUNSELING AND TRAINING SERVICE. THIS IS NOT A TALENT AGENCY CONTRACT.
ONLY A TALENT AGENT LICENSED PURSUANT TO SECTION 1700.5 OF THE LABOR CODE MAY ENGAGE IN THE OCCUPATION
OF PROCUIUNG, OFFERING, OR ATTEMPTING TO PROCURE EMPLOYMENT OR ENGAGEMENTS FOR AN ARTIST. HOllYWOOD
SHOWCASE IS PROHIBITED BY LAW FROM OFFERING OR ATTEMPTING TO OBTAIN AUDITIONS OR EMPLOYMENT FOR you. IT MAY
PART 6 OF DIVISION 2 Of THE LABOR CODE. A DISPUTE ARISING OUT OF THE PERFORMANCE OF THE CONTRACT BY THE TALENT
SERVICE THAT IS NOT RESOLVED TO THE SATISFACTION OF THE ARTIST SHOULD BE REFERRED TO A LOCAL CONSUMER AFFAIRS
DEPARTMENT OR LOCAL LAW ENfORCEMENT, AS APPROPRIATE. YOUR RIGHT TO CANCEL: . You may cancel this contract
Friduy. To cancel this contract, mail via certilli1J mail with the USPS a signed and dated copy of the following cancellation notice or any other written
notice of cancellation to Hollywood Showcase, PO Box 719, San Francisco CA 94104. NOT LATER THAN MIDNIGHT OF: .
If you cancel, all fees you have paid must be refunded to you within 10 business days aWl dclivery of the cancellation notice to the talent service.
A refund may not be obtained aWl the lOday cancellation period has expired. EU&tive withdrawal date is the postmark date. CANCELLATION
NOTICE I hereby cancel this contract
requirements. A bond in the amount ofDml thousand dollars ($50,000) is held and is posted with the Labor Commissioner (Bond # 57BSBGI7017).
Each Artist is provided with a copy of this contract and program dates before becoming obligated to pay any fee. [ills Participation Agreement represents
the entire undcrstanding betwccn the partics respccting the services provided, and replaces and supersedes any and all oral or m'iUen understandings. No
agreement. Hollywood Showcase reserves the right to change class dates and/or class times and/or yenue in whieh the classes will take plAce because of
dirnJulties beyond its control. We reserve the right to amend this contract as circumstances dictate provided no such amendment shall diminish the services
provided. ffi1 OOt date of service commences with a photo shoot analysis with a Hollywood Showcase &out at no charge, with no obligation to pay.llib
sccond class COlIlmences with the date on reverse of this document. Any failure to take the classes shall not relieve the student/parent ofthe obligation ofthis
contract. ffib student/parcnt agrces to pay any and all costs associatcd with the collection of any monies owed, or enforcing any rights hereunder in the even!
the buyer thils to pay the same. It is further agreed that the student/parent or legal guardian's rights under this agreement lIlay not be assigned or transferred to
an yother person or studcnt.1ll1 student/parcnt or guard ian agrces to abide by the rules and regulations of this Agreement. Hollywood Showcase will include
your image ill the Program Book given to attending industry professionals. ffib registrAtion fee does not include airfare, transportation to or from the airport,
parking fees, room service, alcoholic bevcragcs, food (othcr than o[JDed at scheduled times), or additional hotel incidentals and sight-seeing excursions you
wish to enjoy while in Los Angeles, CA. Hollywood Showcase does not guarantee any income or employmcnt as a result ofattcnding this cvent. Tulent may
not bring guests thut have not registered and bcen paid for, including hotel sta)~ ALL Talent under the age of 18 are required to bring a paid and registered
guest (parent or guardian). Ifthe Artist is 18 years or older and not registering a guest; Hollywood Showcase will pair you with a tAlent ofthe same gender and
demographic for double occupancy. Paid and registered guests will receive the following: hotel accommodations (shared with one other Talent Participant)
from January 15 - 18,2015; scheduled mcals; entrance to modeling and talent educatiOllnl workshops and seminars throughout the event. Attend the Red
Carpet Opening Night at LA LIVE!; Dinner & Dancing at Awards Gala and thc Finale Show Eyent. Rollover Applications may be granted to performers and
guest(s) with extenuating circumstances. Approval is to be determined upon submission to our registmr department. Applicable fees lIlay apply. For more
information, contact our registrar department at [email protected] LlON001003
.f~'.I1~\~,~\)~i;~&;'~iy~;" ~~(i5~~~;~:js:!!!,~~~ ;,~,~ ,ij .
. . '. 'i:Affir~ir'tmmAG.R$V1~$Q~M~~;~'1:~:.j:.:;: _.... . ,. . ;:'1
0t~iO~ti9~~i.J?ertQ?m.i~9Art~~9~~.a~ ~.~t~.~Qt.)r~iilj~'~;,~na;~Q,ijhiii6~'~fl;ik~?pt?v~~~K('i . . . j
. p~rf~~m1.n{!Jl ~.~ pJ-e~.~m :1'l~pJ()~wm.~Jnt?Jld,e.~ . ~pPf?,~.jCI:~f~re:.er S?HV~ lin~;xQ'~tj9~~1'<i "i
'~;~id,~ n~!:)~!l~~a rear~~ 'lIal~nt~rpil~~c o~pti iil g,~J1l!n~r~~q~~9P~i~d;p:t~~r:.~mi~~.!f~!Q!ng , "j
Artist Nama: _ _ _ _ _ _ _ _ _ _ _ _ _ $ DOB_'_f _ Age _ _ Ff M Helght: _ _
Ad dress: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ CUy: Sa te: _ _ Zip: _ _ __
Phone; ( _ _- - - J _____________ Moblle Alone: (......_ _- ' _ _ _ _ _ _ _ _ _ _ _ __
Erne iI: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.Ernergenc y Contact: _ _ _ _ _ _ _ _ _ _ _ _ _ __
Reglste red Guest: _ _ _ _ _ _ _ _~$ _ _ _ _ Registered Guest: _ _ _ _ _ _ _ _ _ _ _.$ _ _ __
Deanna 9:tllUlng
SUpermOdi;!IMagalille
~extWOrkS~()P9ah~: '. '.. ............. . '. '. ..... . . . . . . . . . . . ,

Pre~~()'h'caset:eryices 'Preparation f()rT(llentS1()wcase 'R!otosh06f
IPAS will provide the artist June 27,2013 through June 30,2013:
Performance in up to 5 showc ases of the artist choice, provided you meet showcase requirements
s:: heduled meals
Entrance to Industry Professionals (AgentsCind Managers) S9mlnars and Workshops throu{Jhout the event
Headshot inlPASProgramBook distributedto Industry professionals, Participants& ~gistered Guests
Attendance at the Red Carpet OpeningNig ht at LA UV8
Dinner& Dancing atAwardsGala and Talent Slowcase
Artlst:$_____________ Guest~$ _____________ Other: $_ _ _ _ _ __ Extra ~om: $._ _ _ _ _ __
Tota I Fe es: $_________ Pa Id Toda y: $_ _ _ _ __ Record # _ _ _ _ _ _ _ _ _ _ _ _ _ __
Balance of $ _ _ _ _ _ _ to be paid In ___ monthly Installment paymentsof $ _ _ _ _ _ _,

Rrst Installment payment due on _ _ , _ _ , _ _ and every ___ of each month thereafter until paid In full. By signing on
reverse of this document, I authorize International Perform Ing Arts Slowca se to a utoma tic al~
process payments by the method Indicated below, Total partlclpatfon feesmu& be paid In full by May 31,2013,
ACCT# Exp: _ _ ' _ _ SC: _ __
Card Holder 55#:_ _ _ _ _ _ _ _ __ D.L#:_ _ _ _ _ _ _ __ Slowcase Receipt #:_________
~eclallnstructlon~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
International Performing Arts Showcase

los Ang(:lles Center~udlos
(888) 493-1923 www.ThlentSlowcase.tv.W\.M.Facebook.com/TatentShowcastIONO()1004
.J ... Ul........ " .......... r ..... .r.r- n n p.-.v7tn .of'::::" CIIUh.-O,.4 ...... 0.-.. .... u--..n .... L-..- ..... 'lit nJ1:n!
T heJntetnafionalPerfcr ming A r tsShQNcase
1hf;l4-day evellt)loc atedlnLc>$ Angeles) is the larg estnetWorking.~nd
re$Ourc eopportUn.ityforindustry profe ssio na Is- ag e~ts'l11arlagers)
c a sUn 9 dire c to rs, chore og ra p he rs and re cord eXe cutives.
Pdrent or lagal Guardian Print (if artist is under18) Parent or lagal Guardia n Sg nature (if a rtist is under 18) -- --' DAlE
Talent(Sgnature) IPASA;lpresentative (Print) IPASR3presenlative (Sgnature)

lIiternational Peiforming Arts Showcase, PO Box 719, 150 Sutter Street, San Francisco CA 94104 Tel: 888.493.1923
MysignEltureis to make application to theInlernlltional Performing Arts Showcase (IPAS), for participation at the IPAS Summer 2013 Event.[ILle eyent
is sehedul.;:d to tnke place June 27 through JUlle 30,2013 at tne Millennium Biltmore Hotel in Los Angeles, CA.lli1is agreement becomesyalid \\hen
acoepted and ~xecllted byan IPj\S Representath'e. Upon es.eclltioll ofthis agreement, I autbot"ize payments to be made to International Performing Arts
Sho\\\!ase thl'oughACH/EFT using the credit card information listed on the frollt side of this agreement. Returnedldeclined payments :Ire subject to a
twenty~lli1 dollal~ service chatge. INTERNATIONAL PERFORIvHNG ARTS SHOWCASE IS A TALENT COUNSELING AND TRAINING SERVICE.
THIS IS NOT A TALENT AGENCY CONTRACT. ONLY A TALENT AGENT LICENSED PURSUANT TO SECTION 1700.5 OF THE LABOR CODE
MAY ENGAGE IN THE OCCUPATION OF PROCURlNG, OFFERING, OR ATTE?I'IPTING TO PROCURE EMPLOYMENT OR ENGAGEMENTS
FOR AN ARTIST. INTERNATIONAL PERFORMING ARTS SHOWCASE IS PROHIBITED BY LAW FROM OFFERING OR ATTEMPTING TO
OBTAIN AUDITIONS OR ElviPLOYlvlENT FOR YOU. IT MAY ONLY PROVIDE YOU WITH TRAINING. FOR MORElNFOIUv1ATION, CONSULT
CHAPTER4.5 (COMMENCING WITH SECTION 1701) OF PART 6 OF DIVISION 2 OF THE LABOR CODE. A DISPUTE ARISING OUT OF
THE PERFOfuvIANCE OF THE CONTRACT BY THE TALENT SERVICE THAT IS NOT RESOLVED TO THE SATISFACTION OF THE ARTIST
SHOULD BE REFERRED TO A LOCAL CONSUMER AFFAIRS DEPARH.'IENT OR LOCAL LAW ENFORCEMENT, AS APPROPIUATE. \DUR
RIGHT TO CANCEL: , YOlllllayc:lnoelthis contract and obtain Il fullrefuud, without penalty or obligation, ifuotice of Call cella lion
is giwll, ill \witing, within 10 business days froll! the above date or the date on which you commence utilizing the senioes under contract, \\ilicheyer
is longer, For purposes of this section, business days are Monday through Friday. To cancel this contract, mail \la certi[JTh mail "ith the USPS a
signed and elated copy of the following cancellation notice or any other \witten notice of cancellation to International Perform ing Arts Shom:ase, PO
Box 719, 150 Sutter Street, San Francisco CA 94104. NOT LATER THAN MIDNIGHT OF: . If you cancel, all fees you ha\"C paid Illllst
ben:funded to you \\ithin 10 business days aillJ delh'ery ofthecanoel!alion notice to the talent senice. A refund maynol be obtained aUa the 10-
day canoellation period has expired. ECkbtive \yithdrm\tll date is the postmark date. CANCELLATION NOTICE I hereby cancel this contract. Artist
Signature Dated: International Performing Arts Showcase is in compliance with
applicable bond requirements. A bond in the amount of0I:8tho\1s3lld dollars ($50,000) is held and is posted with the Labor Commissioner (Bond
# SB006500169). E.'lch Al'tht is pro\ided with a copy of this contract and program dates before becom~lg obligated to pay any fee. ODs Participation
Agreement represents the entire 'Hlderstanding between the parties respecting the sen;ces pro,ided, and replaces and ~1.lpersede$ au)' and all oral or ,witten
undentandings. No employee ofIPAS or allY other parties may modify or otherwise alter the terms of this agreement. You m'e entitled to an es.act copy of
this agreement. International Performing Arts Showcase rese1'\'e$ the right to chrulge class dates aud/or class times andlor yenue ~l \\hich the classes will
take place because ofdiillJulties beyond its control. We resen'e the tight to runelld this contract as circumstances dictate provided no 5UClt amendment ~holl
diminish thescnices provided. IIU OOtdate ofsel'\'ice COllllllcnces with a photo shoot analysis with on IPASScont at no charge, \\'ith no obligation to pay.llib
second class commences with the dale Oil reverse ofthis document. Any .1ilure to take the clas~es shall not relieve the student/parent of the obligation oflhi$
contract. [lIb student/parent agrees to pay any and 011 costs associated \\'ith the collection of ony monies owed, or enforcing an)' rights hereunder in th.: e\'ent
the buyer fails to pay the same. It is furthcr agreed that the 5iudentlpru'ent or legal ~lRrdians rights under this agreement may not be assigned or transferred
to any other person or student.lli.k ~ttldelltfparellt or guardiml ogr~s to abide by the rules and regulations oft his agro:ement. IPAS will include your image in
the Program Book gi\'ell to attending industryprofessionals.1TI1 reghtration fee dOe$llot illcludeair.'lre, trampol1ation to 01' f!'Om the airpol1, pm'kingfees,
I'com senlce, alcoholic be\'erages, food (other than oUaed ot scheduled times), or additional hotel ~lcidentals and sight-seeing excursions you wish to ellioy
\\hile in Los Angeles, CA. [Rb Internatiol131 Performing Arts ~lO\\~aSe (IPAS) does !lot guarantee rul)' income or employment as a result of attending this
eyent. Talent may not bring gue~ts that h(lYe not registered and been paid for, including hotel ~ta)'. ALL Talent under the age of I 8 are required to bring a paid
and registered guest (parent 01' guardian), If the Artist is 18 )'ears 01' older and IlOt registering a guest; IPAS \\iIl pail' you with a talent of the srunc gender and
demographic for double oc<:upancy. Paid and registered guests \\ill recer."e the follo\\;ng: hotel ac<:omlUodaliolls (shared \\1th one I PAS Talent Participant)
fi'om June 27 through .1\1l1e 30,2013: scheduled meals; entmnce to modeling and talent educational worhhops and seminars tlu'oughoul the event. Attend the
Red Carpet Opell~lg Night at LA LIVE!; Dinner & Dallclllg at Awards Gala and Talent Showcase.
LlON001005
81CW Artist Talent Ag ree me
Hollywood Slowcase isa talent training and counseling seNice providing a performing arts program. Thlsprogram Isintended
to provide ca reer counseling, vocational guidance and career evaluation through coaching, seminars, workmopsa nd other
sim ila r tra ining.
Artist Name: _ _ _ _ _ _ _ _ _ _ _ _ _ $_ _ __ 008 _ _ _ __ Age _ _ FI M Height: _ _
Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Cily: _ _ _ _ _ _ _ _ _ _ Sate: _ _ lip: _ _ __
Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Mobife Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Bnail: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _,8nergency Contact _ _ _ _ _ _ _ _ _ _ _ _ _ __
Registered Guest: _ _ _ _ _ _ _ _-----:$ _ _ _ _ Reg istered Guest: _ _ _ _ _ _ _ _ _ _ _,$ _ _ __
Next Workshop Date: _ _ _.........._ _--._--....,....-.........._ _ _ _~__

Pre~91owcase Servlc es t Preparation for HoHywood91owc asetA1otoshoot
Hollywood Slowcase will provide the artist June 26;. 29,2014:

ffiJHotelaccommodations(quadruple occupancy)
lliJPerfonnance in up to 5 showcasesof the artist choice, provided you meetshowcase requirements
lliJfc hed ulE:l,dmea Is
ffiJEntrance to Ind ustry Professionals (Agents and~a ~agers)feminarsand Workshopsthroughout the event
ffiJHead shot in Hollywood Slowca se Progra m 800kdistrib lIted to Industry Professiona Is, Partic ipa nts& Reg Istered
Guests
llilAttendallce at the Red Carpetopening Night at LA UV8
ffiJOinner & Dancing at Awards Gala and Finale 9101,'{ Event
Artist: $ Guests: $,_ _...;.;...._ __ Other: $~ _ _ _ _ __ Exira Rlom: $_ _ _ _ _ __
Total Fees: $_ _ _ _ _ _ _ Paid Today: $ _ _ _ _ _ _ _ Record # _ _ _ _ _ _ _ _ _ _ _ _ __
Balance of $ to be paid in ___ monthly installment paymentsof $ _ _ _ _ _ _.

Rrst installment payment due on _ _ ' _ _ I _ _ and every _ _ _ of each month thereafter until paid in full, By signing
on reverse ofthisdocument, I authorize Hollywood Ehowcase to automatically processpaymentsby the method indicated
below, Total participation fees must be paid in full by May 30,2014. Retumed/declined paymentsare subject to a thirty
dollar c ha rge.
ACCT# _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~p: _ _ _ _ _ _ SC: _ __
Card Holder SS#:_ _ _ _ _ _ _ __ O.L#:_ _ _ _ _ _ __ Ehowcase Receipt #: _ _ _ _ _ _ __
Epeciallnstructions: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Hollywood Ehowcase
(888) 493-1923' www.TalentEhowcase.tv www. Facebook,comlTalentSlowcase
Mamng AddreEa' P,O. Box 719, Sln Francl<co CA 94104
L10N001006
::~ll;~ :~~.- (~;cr: ;f; ~H::~~ ~.:Hr~~t: ~~:rr=~: ~ g~8 r:i ~:r~ lU~~ ~5 :.~.lr~;~g:8 ~~8 tt~: ~~8 ~f:r8 :~~ r:~~ 8:~f.~ F~Ef~:~~~~il}ri~~ ~~1 ~i~ r.1E ~1 rj
5~lEE:i:~J: ~jl ri~::r1! ~iJ:~~=~) =~]: ~1~ ~~~~ ~t~~: ~~~: r ~ r~ ;j~ ;Um::~1i~f.~ ~p: fH.1:"f8 ~~~~:~]= n~~5Z: ~~~5- ~~ ~~ =& nrt~~:: r~1;~ r~ ~ ~J:8 ~n~:
castIng drrectors, choreographers and record execu"hvE!.s.
Parent or Legal Guardian Print (if artist is under 18) Parent or Legal Guardian Sgnature (if artist is under 18) DA1E
Talent (Sgnature) Hollywood S10wcase ~p. (Print) Hollywood S10wcase Rep. (Sgnature)
Hollywood Showcase, PO Dox 719, San Francisco CA 94104 Tel: (888) 493-1923
Ivly signature is to make application to the Hollywood Showcase, for participation at the Hollywood Showcase Summcr 2014 Evcnt. [[b event is
scheduled to take place June 26 - 29,2014 at the Millennium Biltmore Hotel in Los Angeles, CA. ffils agrcement becomes valid when accepted and
executed by a Hollywood Showcase Representative. Upon execution of this agreement, I authorize payments to be made to Hollywood Showcase
through ACHfEFT using the credit card information listed on the front side of this agrccmcnt. Returned/dcclincd paymcnts are subject to a thirty
dollar service charge. HOLLYWOOD SHOWCASE IS A TALENT COUNSELING AND TRAINING SERVICE. TIIIS IS NOT A TALENT AGENCY
CONTRACT. ONLYA TALENT AGENT LICENSED PURSUANT TO SECTION 1700,50FTHELABORCODEMAYENGAGEINTHEOCCUPATION
SHOWCASE IS PROHIBITED BYLAW FROM OFFERING OR ATTEMPTING TO ODTAIN AUDITIONS OR EMPLOYMENT FOR YOu. IT MAY
PART 6 OF DIVISION 20F THE LABOR CODE. A DISPUTE ARISING OUT OFTHE PERFORMANCE OF THE CONTRACT BY THE TALENT
DEPARTMENT OR LOCAL LAW ENFORCEMENT, AS APPROPRIATE. YOUR RIGHT TO CANCEL: . You may cancel this contract
date on which you commence utilizing the services under contract, whichever islongcr. For purposes ofthis scction, business days are Monday through
Friday. To cancel this contract, mail via certiilH.! mail with the USPS a signed and dated copy ofthe following cancellation notice or any other written
. If you cancel, all fees you have paid must be refunded to you within 10 business days aUB delivery of the cancellation notice to the talent service.
A refund may not be obtained a(ill the lO-day cancellation period has expired. E[ID;!ive withdrawal date is the postmark date. CANCELLATION
NOTICE I hercby cancel this contract.
requirements. A bond in the amOllnt of rn:IP
thousand dollars ($50,000) is held and is posted with the Labor Commissioner (Bond # 57BSBGI70 17).
Each Artist is provided with a copy of this contract and program dates before becoming obligated to pay any fee. []lls Participation Agreement represents
the cntire understanding betwecn the parties rcspceting thc scrvices providcd, and replaces and supersedes any and all oral or written understandings. No
employee of Hollywood Showcase or any other parties lIlay modify or otherwise alter the tcrms ofthis agrcemcnt. You arc entitled to an exact copy of this
agreemcnt. Hollywood Showeasc reserves the right to change class dates and/or class times andfor venue in which the classes will take place because of
dilliJulties beyond its control. We reserve the right to amend this contract as circumstances dictate provided no sllch amendment shall ditllinish the services
providcd. [[b {illt date ofscrvice commences with a photo shoot analysis with a Hollywood Showcase Scout at no charge, with no obligation to pay. [lib
second class commences with the date on reverse of this document. Any failure to take the classcs shall not relieve thc student/parent of the obligation ofthis
contract. [Rb student/parent agrees to pay filly and all costs associated with thc collection of any monies owed, or enforcing any rights hereunder in the evcnt
the buyer fhils to pay the same. It is further agreed that the student/parent or legal guardian!> rights under this agreement lllay not be assigned or transferred to
any other person or student. ill1 student/parent or guardian agrccs to abide by the rules and regulations ofthis agrcement.lIollywood Showcase will include
your image in the Program Book given to attending industry professionals. ffi1 registration fee does not include airfare, transportation to or from the airport,
parking fees, room service, alcoholic beverages, food (other than oOilcd at scheduled times), or additional hotcl incidentals and sight-seeing excursions you
wish to enjoy while in Los Angeles, CA. Hollywood Showcase does not guarantee any income or employment as a result of attending this event. Talent may
not bring guests that have not registered and been paid for, including hotel stay. ALL Talent under the age of 18 are rcquircd to bring a paid and registered
guest (parent or guardian). If the Artist is 18 years or older and not registering a guest; Hollywood Showcase will pair yOll with a talent ofthe same gender and
demographic for double occupancy. Paid and registercd gucsts will receive the following: hotel accommodations (shared with one other Talent Participant)
from June 26-29, 2014; scheduled meals; entrance to modeling IDld talent educational workshops and seminars throughout the even!. Attend the Red Carpet
Opening Night at LA LIVE!; Dinner & Dancing at Awards Gala and the Finale Show Event. LlON001007
Holtywood Showcase Is a lalenl training and counseling service providing a performing arts program. Th1s program Is Intended
to provide career counseling. vocational guldance and career evaluation through coaching. seminars, workshops and alher
similor Irainlng,
Next Workshop Delle:

PreShowcase Services
Hollywood Showcase will provide the artist November 10 ~ 13,2016:

Hotel pccommodalfons (quadruple occupancy)
Performance in up to 5 showcases of the artist choice. provided you meet shoyvcase n:~quiremenls
Scheduled meals
Entrance to Indus I/)' Profess1onals (Agents and Managers) Seminars and Works!1opslhroughouf the event
Headsholln Hollywood ShoWcase Program Book disfribu led tolndust/), Professionals, Participants 8, Regislered
Guests
A tlendance at the Red Carpet. Opening Night elLA LIVE!
DInner 8, Dancing at Awards Gala and finale Show Event
Artist: r;$_........ _ __
Record II "'~_' ___ .~.~ _____.______ ~ _ _ .__
monlhly Installment payments of $

and e v e . of each monfh paid In full. By ~Ignlng
on reverse of this document. I au Hollywood Showcase to automatically process payments by the melhod Indicated
below, Tolal participation tees must be paId In full by October 10,2016. Relufnod/deciIned payments are subJecllo 0 Ihlrly
d 0110 r c, "-'fl1 ..
ACCT ___ .. ___ . . Exp:
Card Holder S.S.#;_... ___ .. __~_ .. _. D.l.tI:
Speclallnstrucllons: _ .. __ ... ____._. _______ .
Hollywood Showcase
(ElBB) 4931923 www.TatentShowcase,fy www, facebook,com/lral(mtS:ho INC(
MO'fClg Address: P,O, aox 719. Son froncisco CA 94104
LlON001008
The 4-day event. located fn los Angeies, 15 the lOfgc-st nelworV<1fig ulld
resource opportunity for Industry professlonals- agents, managers,
Hollywood Showcaso, PO BOl( 719, San Francisco CA Tel: (688) 4931923

My signature Is to mako application to the Hollywood ShOwcase, for part!clpallon at the HolIY'Nood Showcase Winter 2018 Event The event Is schedu~et(~'ake
place November 10 13, 2016 at tho Millennium Biltmore Hotel In los Angeles, CA. This agreement becomes valid wtwn accepled and executed by a Hollywood
Showcase Representallve. Upon exocuHon of this agreement, I authorize payments 10 be made to HoltY'Nood Showcase through AC HIEFT using the cfedit card
informatiOn listed on U10 front side of this agreement. Heturnedldeclined paymonts are sublect to a thirty dollar service Charge. HOLLYWOOD SHOWCASE
IS A TALENT COUNSELING AND TRAINING SERVICE. THIS IS NOT A TALENT AGENCY CONTRACT. ONLY A TALENT AGENT LICENSED PURSUANT
TO SECTION 1700.5 OF THE LABOR CODE MAY ENGAGE IN THE OCCUPATION OF PROCURING, OFFERING, OR ATTEMPTING TO PROCURE
EMPLOYMENT OR ENGAGEMENTS FOR AN ARTIST. HOlLYWOOD SHOWCASE IS PROHIBITED BY LAW FROM OFFERING OR ATTEMPTING TO
OBTAIN AUDITIONS OR EMPLOYMENT FOR YOU. IT MAY ONLY PROVIDE YOU WITH TRAINING. FOR MORE INFORMATION, CONSULT CHAPTER
4.5 (COMMENCING WITH SECTION 1701) OF PART 6 OF DIViSION 2 OF THE LABOR CODE. A DISPUTE ARISING OUT OF THE PERFORMANCE OF
THE CONTRACT BY THE TALENT SERVICE THAT IS NOT RESOLVED TO THE SATISFACTION OF THE ARTIST SHOULD BE REFERRED TO A LOCAL
CONSUMER AFFAIRS DEPARTMENT OR LOCAL LAW ENFORCEMENT, AS APPROPRIATE. YOUR RIGHT TO CANCEL~ . You may
cancelth!s contract and obtain a fullrelund, without penalty or obtigatlon,lfnolice 01 cancellation Is givan, Inwrillng, within 10 bU$lnllss days from tho abovo dalo
or Ule dat(l on which you commence utitillng tho seIVlcos under contract, whichever Is longer. For purposes of this sectloo, business days are Monday through
Friday. To cancel Ihls contract. mall via cartified mall with the USPS a sIgned and dated copy of tho (olioWing cllnceUlllion notice or any olller 'MiUen nolico of
cancellation to HollywoOd Showcase, PO oox 719, San Frllncisco CA 94104. NOT LATER THAN MIDNIGHT OF; Ii
II you cancel, nil fees you have paid must be refunded 10 you within 10 business days after delivery orthe cance1!alion notice to the lalent sel\'lce. Arerund may [j
not be obttllned lifter the 10-day cancellation period has expired. Effective withdrawal date is the postmark date, CANCELLATION NOTICE I hereby cancell
this contract.
Artist Signature Dated: Hollywood Showcase Is In compliance with applicable
bond requirements. A bond In tho amount o/fifty thousand dollars (S5O,000) is held and Is posted with the labor Commlss!oner (Bond # 570SBG1701 Eaell n
Artist Is provided with a copy of thls contract and program dates betore becoming obligatod to pay any tee. ThiS Partlclpatlon Agreement represents tho entire
undorstandlng bet."..een the partlos respecting Ihe services pro\lldoo, and replaces ond supersedos any and all oral or written understandings. No ernployee
01 HollywOod Showe<)se or eny othor pa.rtles may modify or otMrwlse alter the terms of this agreomenl. You are enliUed 10 an exact copy of this agreement.
HolIY'Nood Showcase resorvos th!lflgh! to change class doles and/or class limes <lnd/or venue In wIlleh the classes will take place because of difficullIes beyond
Its control. We reServe the right to amend this contract as clrcumstances dlctato provided no sUch amendment shall diminish the seIVlces provided. The first date
of seIVloo commences with a photo shool analysis Wilh a HollywOod Showcase Scout at no charge, with no obligation to pay. The second class commences
\Yith Ihe date on reverse of thIs document. Any failure to lake the classes shall not relieve the studonllparenl of the obllgallon of IhlS conlfact. nle studenVparent
agrees to pay eny and a\l costs assoclated with Iho coliecUon of any monJes OYIed. or enforcing any rlghts hereundor In the evon! Ihe buyor foils to pay tho same.
II Is further agreed thatlhe studeniJparenl or legal guardian's rights uMer Ihls ngreemont may not bo assigned or transferred 10 any olher person or student. ThO
sludeniJparent or 9UMclian agroes to abide by tho rules and regulallons of this agreement. Hollywood ShowcasQ willindude your Imago In the Program Book
glvOn loat\endlng Industry professionals. The registration fee doos not Include airfare, Iransportl'ltton to Of from the airport, parking feos, room Service, alcohollc
bevnrages. food (othe! than offored at schoduled limos), or additional hotellnc!dentals end Sight-seeIng excursioos you wish 10 enloy while In los Angeles, CA
HolIY'NOOd Showcase does not guarantee any Incomo or employment as a result of attending thIs even!. Talent may nol bring guests that have not registered
and been paid for, Includlng hOtel stay. ALL Talent under the age oJ 18 are required \0 bring a paid and reglstared guest (parent or guardian). If tho Mist Is 18
years or older end flot registering a guest; Hollywood Showcase ylitl paIr you wilh a talent of th(l same gender and demographic for doublo occupancy. Paid and
roglslared guests Will receive the following; hotel accommodallons (shmed wHh one other Talent Participant) from November 10 - 13,20113; sCheduled meals;
entrence to m()tjel1ng and talan! educal!onal workshops and semlners throughout tho elJenl.AlIond tho Red Carpet Opening Night at LA lIVEl; Dinner & Dancing
alAwards Gala and the Flnate ShoW Event Rollover applk:otions (!1ay be gmnled to performers and guesl(s) with extenuating circumstances. Approval Is to be
determined upon sUbmlss!ooto our reglstrur dopartmont. AppllCllblo fees may epply. For moro Inronnallon, contec! our registrar department at
[email protected]
INTERNATIONAL PERFORMING ARTS I. ' __ ,: I h .... _~ . A .I _ c
'TkQ.., ~"A"o"~ r ~ 1 oV"MI"~ 'f""'\V"'T'5. ..::>koWUi\5.Q..,
ARll ST TALENT AG REEJ\II8\lT'WINlER 2013
International Performing ArtsSlOwcase isa talent training and counseling service providing a
performing artsprogram. This program isintend ed to provide career counseling, vocational
guidance and career evaluation through coaching, seminars, workshopsand othersimilartraining.
Artist Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ T _ _ __
FI M ht: _ __
Addre~: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ 9:ate: _ _ -,-
Phone: ,_ _ _---' _ _ _ _ _ _ _ _ _ _ _ _ _ _ Mobile Phone: , _ _ _--' _ _ _ _ _ _ _ _ _ _ _ _ __
Bnail: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _t:rrler~lency Conl,aclt: _ _ _ _ _ _ _ _ _ _ _ __
istered Guest: _ _ _ _ _ _ _ _ _ _ _ _v _ _ __
Deanna
Supermodel Ma~lazirle
Ulisses Suguero
Toys 'R Us Commercial
Next Workshop Date: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Pre-Showcase Services Preparation for Talent Showcase Photoshoot
IPAS will provide the artist February 7, 2013 through February 10, 2013:
Performance in up to 5 showcases of the artist choice, provided you meet showcase requirements
Scheduled meals
Entrance to Industry Professionals (Agents and Managers) Seminars and Workshops throughout the event
Headshot in IPAS Program Book distributed to Industry Professionals, Participants & Registered Guests
Attendance at the Red Carpet Opening Night at LA LIVE!
Dinner & Dancing at Awards Gala and Talent Showcase
Artist: "'_ _ _ _ _ _ __ Guests: "'_ _ _ _ _ _ __ Other: "'_ _ _ _ _ _ __ Extra Room: "'_ _ _ _ _ _ __
Total Fees: $_ _ _ _ _ _ _ Paid Today: $_ _ _ _ _ __ Record # _ _ _ _ _ _ _ _ _ _ _ _ _ __
Balance of $ _ _ _ _ _ _ _ to be paid in _ _ _ monthly installment paymentsof $ _ _ _ _ _ _'
Rrst installment payment due on _ _ and every _ _ _ of each month thereafter until paid in full. By signing on
reverse of thisdocument, I authorize Intemational Performing ArtsSlOwcase to automatically
proce~paymentsby the method indicated below. Total participation fees must be paid in full by January 1,2013.
ACCT# _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Exp: _ _ I _ _ SIC: _ __
Card Holder 88#.' _ _ _ _ _ _ _ _ _ _ __ D.L.#. _ _ _ _ _ _ _ _ _ __ SIIowcase Receipt # . _ _ _ _ _ _ _ __

!:peciallnstructions: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
International Pelrfolrmiing Arts Showcase

Los Center Studios
888.686.7827 www.TalentShowcase.tv www. Facebook.com/TalentShowcase
Mailing Address: P.O. Box 719,150 &lIter Sreet, San Francisco CA 94104
/ /
Parent or legal Guardian Print (if artist is under 18) Parent or Legal Guardian Signature (if artist is under 18) DATE
Talent (Signature) IPAS Representative (Print) IPAS Representative (Signature)

PO 7
event
Biltmore Hotel in Los CA. This agreement bel:Ol1lleS
agreement, I authorize payments to be made to International PelrfOlrmiing
the front ofthis Returned/declined payments
ARTS ACADEMY IS A TALENT COUNSELING TRAINING SERVICE. THIS IS
AGENT TO SECTION OF LABOR CODE ENGAGE IN OCCUPATION OF PROCURING,
OFFERING, OR ATTEMPTING PROCURE EMPLOYMENT OR ENGAGEMENTS FOR ARTIST. INTERNATIONAL PERFORMING ARTS
ACADEMY IS PROHIBITED BY LAW OFFERING OR TO AUDITIONS OR EMPLOYMENT FOR YOU. IT
PROVIDE YOU WITH TRAINING. FOR MORE INFORMATION, CONSULT CHAPTER 4.5 WITH SECTION OF
PART 6 OF DIVISION 2 OF THE LABOR CODE. A DISPUTE ARISING OF THE PERFORMANCE OF THE CONTRACT BY THE TALENT
SERVICE THAT RESOLVED TO SATISFACTION OF THE ARTIST SHOULD REFERRED TO LOCAL CONSUMER AFFAIRS
DEPARTMENT OR LOCAL LAW ENFORCEMEN1~ AS APPROPRIATE. YOUR RIGHT TO CANCEL:
and obtain full refund, withoul or obligatiolll,
utiliziing the services under contract, whicb,evl~r
tms C(lntract, mail via certified mail with the
Hollywood Slowcase isa talent training and counseling service providing a performing artsprogram.lhisprogram isintended
to provide ca reercounseling, vocational 9 uid ance a nd career eva luation throug h coaching, seminars, workshopsand other
sim ila r tra ining.
Artist Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ T _ _ __ F/ M ht: _ __
Addre$ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ 3ate:
Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Mobile Phone: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Email: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Ernel"gency
Extra Room: "'_ _ _ _ _ _ __

Record # _ _ _ _ _ _ _ _ _ _ _ _ _ __
Balance of$ _ _ _ _ _ _ _ to be paid in _ _ _ monthly installment paymentsof$ _ _ _ _ _---'
Rrst installment payment due on a nd every _ _ _ of each month thereafter until pa id in full. By sig ning
on reverse of this document, I authorize Hollywood Slowcase to a utomatically process payments by the method ind icated
below. Total participation fees must be paid in full by May 30, 2014. Returned/declined paymentsare to a
dolla r cha rge

ACCT# _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Exp: _ _ _ _ _ _ SC: _ _ __
Card Holder SS#. _ _ _ _ _ _ _ _ __ D.L.#. _ _ _ _ _ _ _ __ Slowcase Receipt #: _ _ _ _ _ _ __

~eciallnstructions: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Holiv1Nood Showcase
493-1923 www.TalentShowcase.tv www. facebook.com/TalentShowcase
Mailing Address: P.O. Box 719, San Fra rIc is:o CA 94104
The 4-day event, located in Los Angeles, is the largest networking and
resource opportunity for industry professionals- agents, managers,
/ /
Parent or legal Guardian Print (if artist is under 18) Parent or Legal Guardian Signature (if artist is under 18) DATE
Talent (Signature) Hollywood Showcase Rep. (Print) Hollywood Showcase Rep. (Signature)
My signature is to make application to the Hollywood Showcase, for participation at the Hollywood Showcase Summer 2014 Event. The event is
scheduled to take place June 26 29,2014 at the Millennium Biltmore Hotel in Los Angeles, CA. This agreement becomes valid when accepted and
executed by a Hollywood Showcase Representative. Upon execution of this agreement, I authorize payments to be made to Hollywood Showcase
through ACH/EFT using the credit card information listed on the front side of this agreement. Returned/declined payments are subject to a thirty
dollar service charge. HOLLYWOOD SHOWCASE IS A TALENT COUNSELING AND TRAINING SERVICE. THIS IS NOT A TALENT AGENCY
CONTRACT. ONLY A TALENT AGENT LICENSED PURSUANT TO SECTION 1700.50F THE LABOR CODE MAY ENGAGE IN THE OCCUPATION
SHOWCASE IS PROHIBITED BY LAW FROM OFFERING OR ATTEMPTING TO OBTAIN AUDITIONS OR EMPLOYMENT FOR YOu. IT MAY
PART 6 OF DIVISION 2 OF THE LABOR CODE. A DISPUTE ARISING OUT OF THE PERFORMANCE OF THE CONTRACT BY THE TALENT
DEPARTMENT OR LOCAL LAW ENFORCEMENT, AS APPROPRIATE. YOUR RIGHT TO CANCEL: You may cancel this contract
and obtain a full refund, without penalty or obligation, if notice of cancellation is given, in writing, within 10 business days from the above date or the
Friday. To cancel this contract, mail via certified mail with the USPS a signed and dated copy of the following cancellation notice or any other written
. If you cancel, all fees you have paid must be refunded to you within 10 business days after delivery of the cancellation notice to the talent service.
A refund may not be obtained after the 10-day cancellation period has expired. Effective withdrawal date is the postmark date. CANCELLATION
NOTICE I hereby cancel this contract.
requirements. A bond in the amount of fifty thousand dollars ($50,000) is held and is posted with the Labor Commissioner (Bond # 57BSBGI7017).
Each Artist is provided with a copy of this contract and program dates before becoming obligated to pay any fee. This Participation Agreement represents
the entire understanding between the parties respecting the services provided, and and supersedes any and all oral or written understandings. No
agreement. Hollywood Showcase reserves the to change class dates and/or class times and/or venue in which the classes will take because of
difficulties beyond its control. We reserve the to amend this contract as circumstances dictate provided no such amendment shall diminish the services
provided. The first date of service commences with a photo shoot analysis with a Hollywood Showcase Scout at no charge, with no obligation to pay. 1he
second class commences with the date on reverse of this document. Any failure to take the classes shall not relieve the student/parent of the obligation of this
contract. The student/parent agrees to pay any and all costs associated with the collection of any monies owed, or enforcing any rights hereunder in the event
the buyer fails to pay the same. It is further agreed that the student/parent or legal guardian's rights under this agreement may not be assigned or transferred to
any other person or student. 1he student/parent or guardian agrees to abide by the rules and regulations of this agreement. Hollywood Showcase will include
your image in the Program Book given to attending industry professionals. The registration fee does not include airfare, transportation to or from the airport,
parking fees, room service, alcoholic beverages, food (other than offered at scheduled times), or additional hotel incidentals and sight-seeing excursions you
wish to enjoy while in Los Angeles, CA. Hollywood Showcase does not guarantee any income or employment as a result of attending this event. Talent may
not bring guests that have not registered and been paid for, including hotel stay. ALL Talent under the age of 18 are required to bring a paid and registered
guest (parent or guardian). If the Artist is 18 years or older and not registering a guest; Hollywood Showcase will pair you with a talent of the same gender and
demographic for double occupancy. Paid and registered guests will receive the following: hotel accommodations (shared with one other Talent Participant)
from June 26-29, 20]4; scheduled meals; entrance to modeling and talent educational workshops and seminars throughout the event. Attend the Red Carpet
Opening Night at LA LIVE!; Dinner & Dancing at Awards Gala and the Finale Show Event.

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1 Ethan Preston (263295)

PRESTON LAW OFFICES

6 Attorneys for PlaintiffAngelica Cosio, on her own

8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA

13 ANGELICA COSIO, an individual, on her No. CGC-16-551337

7 C. Lion's December Response to RFAs No. 41 Is Evasive ........................................ 5

8 1. Lion's December Response to Form Interrogatory No. 41 as to

11 3. Lion's December Response to Form Interrogatory No. 17.1 as to

Memorandum for Motion to Compel Further Response 2 No. CGC-16-551337

8 Saltzman v. Fullerton Metals Co.,

13 Appleton v. Superior Court

15 Burke v. Superior Court

20 Liberty Mut. Fire Ins. Co. v. LCL Adm 'rs, Inc.

Memorandum for Motion to Compel Further Response 3 No. CGC-16-551337

7 Code Civ. Proc. 2033.220(b) .................................................................................................. 5, 12

8 Code Civ. Proc. 2030.250(b) ...................................................................................................... 11

9 Code Civ. Proc. 2030.300 ......................................................................................................... 2, 1

Memorandum for Motion to Compel Further Response 4 No. CGC-16-551337

7 I. The Parties' Meet and Confer Process Prior to the Motion

15 evasive and incomplete Responses.

16 A. Lion's December Responses to RFAs Nos. 8 to 13 Are Evasive

20 representations just once.

21 It is hard to escape the impression Lion has willfully misconstrued RF As Nos. 8 to

Memorandum for Motion to Compel Further Response 3 No. CGC-16-551337

12 B. Lion's December Response to RFAs No. 41 Is Evasive

11 c. Lion's December Response to RFAs No. 41 Is Evasive

14 Is your response to each request for admission served these interrogatories an

25 November Response which contains several paragraphs of irrelevant statements purportedly in

Memorandum for Motion to Compel Further Response 5 No. CGC-16-551337

2 accurate answer to Form Interrogatory No. 17.1.

3 2. Lion's November Response to Form Interrogatory No. 17.1 as to RFA

28 identified any such employees.

Memorandum for Motion to Compel Further Response 6 No. CGC-16-551337

5 were not policies at all.

8 representations to the putative class[.]" (Id. at p. 8:12-18.) Cosio is entitled to discovery of

12 Central to the discovery process is the identification of potential witnesses. "The

Memorandum for Motion to Compel Further Response 7 No. CGC-16-551337

4 and representations in the Marketing Material):

2 customers), Lion inserts an enonnous amount of uncertainty and potentially non-responsive

5 customers, supposedly renders it incapable of answering Cosio's very straightforward question:

Memorandum for Motion to Compel Further Response 9 No. CGC-16-551337

2 Verification of the answers [to discovery requests] is in effect a declaration that

Memorandum for Motion to Compel Further Response 10 No. CGC-16-551337

15 III. Lion's Verification of Its Responses Is Defective

Memorandum for Motion to Compel Further Response 11 No. CGC-I6-551337

3 response is the following form:

9 8: 1106.1.) The discrepancy and deficiency in Defendants' Responses is especially problematic

14 ultimately unreliable discovery answers.

27 personal knowledge after a reasonable inquiry of Lion's officers and agents.

Memorandum for Motion to Compel Further Response 12 No. CGC-16-551337

Memorandum for Motion to Compel Further Response 13 No. CGC-16-551337

6 Attorneys for Defendants

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

24 PROPOUNDING PARTY: Plaintiff ANGELICA COSIO

26 SET NO.: One (1)

2 ("CCP"), Defendant LION MANAGEMENT GROUP, INC. hereby responds to Plaintiff

3 ANGELICA COSIO'S Request for Admissions Set One.

6 MANAGEMENT GROUP, INC. ("LION MANAGEMENT") objects generally to the Requests on

8 same, similar, or additional objections in LION MANAGEMENT's responses to individual requests,

13 et seq. of the Code of Civil Procedure.

15 purport to require disclosure of communications protected by the attorney-client privilege. LION

21 to lead to the discovery of admissible evidence.

25 6. LION MANAGEMENT further objects to these Requests as prematurely served, and