Case 2:14-cv AB-PJW Document 1 Filed 09/04/14 Page 1 of 14 Page ID #:6 UNITED STATES DISTRICT C<DURT

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1 Case 2:14-cv AB-PJW Document 1 Filed 09/04/14 Page 1 of 14 Page D #: oo Q.., P 'tr..j. o HALLAM & HOCHBERG, LLP WlLLAJvl. HOCHBERG (SBN DANEL MATUSOV (SBN whochberg@hallamhochberg.com '20 l Santa Monica Boulevard, Suite Santa.Monica, California Tel: ( Fax: ( :l = 0' 2...; lfj '- r;:c 2 13 e::: > 5 5:i 14 0 < _,... :::S:!U 3 15 "' < < c z 16..J'""""'..Jz_.-: <;; < :J: - c;3 C" l c.lj Attorneys for Plaintiff Bonnie Schiffman UNTED STATES DSTRCT C<DURT a> -<..., - l"':: nr- = :;z:::n rnr"l.r::- _,;oo: en,-::::je, 1""1 o';:'"" ""0.' >CJ'(. ztht'ft J:;"--i--1 rn '?:!..,. CE\'TRAL DSTRCT OF CALFORNA, WESTERN DVSON BONNE SCHFFMA't\, an individual. vs. Plaintiff, ROD STEWART, an individual; STEWART ANNOYANCES, LTD., a California corporation; THE STEFEL OFFCE, LMTED., a California corporation; ANSCHUTZ E:-JTERTANlviENT GROUP. NC., a Colorado corporation dba AEG LVE: CAESARS ENTERTANMENT CORPORATON, a Delaware corporation; and DOES 1 through2:5'; inclusive, to Defendants. c\f\n4169 o 1 FOR COPYRGHT NFRNGE!vfENT [DEMAND\ FOR JURY TRAL].r:- r-!""' ro-- ::.:; 0 M-,o c.nn.--t ;p.c"> N.. r+cm - <= N PlaintiffBoilllie Schiffman alleges: NATURE OF THE ACTOl\ L "Rod's Back" is a tagline referring to a comeback tour by famous singer Rod Stewan and also to Plaintiffs iconic image of the back of Stewmi's head with lhe unmistakable bouffant hair style. Plaintiff created the image and it was licensed non-exclusijly for a greatest hits album in Then in 2013, Stewart and his handlers offered the photogrlpher $1,500 to re-use the image on a billboard. Plaintiff turned down the offer. Rather than findink a new image, Defendants simply COMPLA.\T L'd S\18cN

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11 Case 2:14-cv AB-PJW Document 1 Filed 09/04/14 Page 11 of 14 Page D #:16 AD 440 (R<.'V- 06/1 2'1 Surnmcms:in n CNiiActivn UNTED STATES DSTRCT CdURT tor the Central District of Californiu Schiffman, an individun1 v. ROD STEWART, m1 individuw; STEWART ANNOY,'\NCES, LTD., a California corporation; THE STEFEL OffiCE, LMTED., a Catifomia corporation; ANSCHUTZ ENTERTAh'liVlE-T GROUP. NC.. a Colorado corporation db-a AEG LVE; CAESARS lo CORPORATON,a Dehtwarecorporation;.und OOES Def 11da11r(s1 } ' Cit rr2, -6 9 a 1 PJw,. SUMMONS N A CVL ACTON To: tdeferrdant 's name cmd address} A lawsuit has been filed against you. Within 21 days after serv[ce of this summons on you (not counting the day rou received it or 60 days if you are the United States or a United States agency, or an officer or employee of the Umted States descrihed in Fed. R. Civ. P. 12 (a(2 or (3... you must serve on the plaintiff an answer to the attached ce>rnplarnt or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: f yon fail to respm1d. judgment by default will be entered against you You also must tile your answer or motion with the couit. relief demanded in the complaint. Date: SEP , z: d S\f8C\fA

12 1 - Case 2:14-cv AB-PJW Document 1 Filed 09/04/14 Page 12 of 14 Page D #:17 UNTED STATES DSTRCT COURT, CENTRAL DSTRCT OF CALFORNA 1: (a PLANTFFS (Check box if you are representing yourself 0 BONNE SCHFFMAN, an individual CVL COVER SHEET DEFENDANTS (check box if you are representing yourself 0 ROD STEWART, an lndividtat STEWART ANNOYANCES, LTD. a Calnornla corporation; THE STEFEL 6FFCE ltd., a California corpol'ation; ET AL (b County of Residence of First Listed Plaintiff LOS ANGELES (EXCEPT N U.S. P.AN71FF CASES (c Attorneys (Firm Name, Address and Telephone Number f you are representing yourself, provide the same information. HAllAM & HOCHBERG, LLP 201 SANT\ MONCA BLVD.,SU SANTA MONC/\ CA ( Coumy of Residence of First Listed Defendant (N US. PlANTFF CASES ONLY ' LOS ANGELES Attorneys {Finn Name, Address and Telephone Number f you are 1 repres nting yourself, provide the same information.. BASS OF JURSDCTON (Place an X in one box only. ll. CTZENSHP OF PRNCPAL PARTES-For Diversity Cases Only (Place an X in one box for plaintiff and one for defendant PTF bef... PTF DEF s b of Business n this State 6 of Business ln Ahother State 01. U.S. Government 3. Federal Question {U.S. Otlzen ofthi State ncorporated or Pnnc1pal Place D 4 D 4 Plaintiff D 2. U.S. Government Defendant Government Not a Party 04. Diversity Ondkate Citizenship of Parties in tem ll V. ORGN (Place an X in one box only. rv1 1.0rlglnal D 2.R'emovedfrom D 3.Remandedfrom Proceeding State Court Appellate Court V. REQUESTED N COMPLANT: JURY DEMAND: /Z] Yes 0 CLASS ACTON under F.R.Cv.P. 23: DYes [gj No D Citizen of Another State ln<:orporated and Principal Place Subject ofa D 3 3 Foreign Nation D 6 D 6 ore gn ountry 6.Mulfi- 4. Reinstated or 0 5. Anottler 0 District D1stnct (Specify Utigatlon No (Check "Yes" only ifilemanded in complaint. ZJ MONEY DEMANDEJ;N COMPLANT: $ 2,500,000 V.. CAUSE OF ACTON {Cite the U.S. Civil Statute under which you are flung and write a brief statement of c:apse. Do not cite jurisdictional statutes 1.mless diversity. COPYRGHT NFRNGEMENT NVOlVNG UNAUTHORZED USE OF PLANTFF'S PHOTOGRAPH N MARKETNG AND UBLCTY FOR DEFENDANTS V. NATURE OF SUT (Place an X in one box only. OlHER STATUTES CONTRACT REAL PROPERTY CONT. MMGRATON PRSONER PETTONS PROPERTY RGHTS D 375 False Claims Act nsurance Tarts to Land. D 462 NatureUzat1on Habeas Corpu:$: lsj 820 Copy1ights Application 400 State 0 120Marine D 245 Tort Product Allen Detainee D B30Patent Reapportionment Liability D 4650ther D Motions: to Vacate Antitrust 0 130MillerAct Real mmigration Actions Sentence D 84Q Trademark Banks anclll4nking D 14<J Negotiable nstrument TORTS PERSONAL PROPERTY 0 5:is Death Penalty '0 861 HA (1395ff D 450 Commen:MCC 15( Recovery of PERSONAL NJURY Other Fraud Other: Rates/Etc. D 362 Black lung (923 0 Overpayment & Airplane Deportation Enforcement of 0 371Truth n Lending D 315 Airplane D 540 Mandamus/Other Judgment D 470 Racketeer lnflu- Product Liability D 380 Other Personal Civil Rights 0 864SSJDTitleXV enoed & Corrupt Or g. D 151 Medicare Act D 320 Assault, Ubei & Property Damage Consumer Credit D 490 Cable/Sat TV Prope TORTS 0 5:lo General SOCAL SECURTY D 863 DWC/DWW (405 (g Slander D 385 Property Damage D sls Prison Condition D 86S RS (405 (g 152 Rec:ove-tyof D 330 Fed. Employ<>rs' D 560 Civil Detainee 0 Defaulted Student Product liability Liability COnditions of Loan (Excl. Vet. BANKRUPTCY COriinement 0 340Marine FOfiFelTURE/PENAL TY federal TAX SUTS 0 870Taxes(U.S.Piaintlffor D 850 Securities/Com- 153 Recovery of D 422 Appeal 28 Defendant mod1t1as/e.xchange 0 D 345MarineProduc:t Overpayment of usc 158 Drug Related 0 871iRS-Third Party26 USC Liability D 890 Other Statutory Vet. Benefits D 423 Withdrawal 28 0 Sezureoi'Property ActiOns D Motor Vehicle 160 Stockholders' usc Agricultural Acts Suits D 355 Motor Vehicle CMLRGHTS 0 Product Uabi!ity D 893 Environmental Other Civil Rights LABOR ther l\.'latters O 360 Other Personal Contract njury D 441 Voting Fair labor Standards A<:f D l: Freedom of nfo. D 195 Contract D 362 Personal lnjijry Employment Product Liability Med Malpratice 0 72P Labor/Mgmt D 896 Arbitrotlon 0 l96 Franchise D 365 Personal njury Housing/ Relations 899 Admln.:Proceclures REAL PROPERTY Product Liability Accommodations 367 Health Care/ 445 American w1th 0 74 Railway labor Act 0 Act/Review of Appeal of Land 0 Pharmaceutical D Disabilities ] Family and Medical leavekt Agency Dedsion Condemnation Personal njury Employment D 79Q Other Labor Foreclosure Product Liability D 446 American with Constitutionalityof 368 Asbestos Disabilities-Other lttlr tlon State Statutes D 230Rentlease& Electment s"'urkv Act D Ed ucatlon D 79 Employee Ret. nc. FOR OFFCE USE ONLY: CaSt? Number. CV-71 {11/131 CVL COVER SHEET Pagel ou g d svsusvs<:s S\f8'CJ\fll

13 Case 2:14-cv AB-PJW UNTED STATES DSTRCT Document COURT, 1 CENTRAL Filed 09/04/14 DSTRCT OF Page CALFORNA 13 of 14 Page D #:18 CVL COVER SHEET V. VENUE: Your answers to the questions below will determine the division of the Court to which this case will most likely be initially assigned. This initial assignment is subject to change, in accordance with the Court's General Orders, upon review by the Court of your Complaint or Notice of Removal. Question A: Was this case removed from state court? Yes No f "no, " go to Question B. f "yes," check the box to the right that applies, enter the corresponding division in response to Question D, below, and skip to Section X. STATE CASE WAS PENDNG N THE COUNTY OF: Los Angeles Ventura, Santa Barbara, or San Luis Obispo Orange Riverside or San Bernardino NTAL DVSON N CACD S: Western Western Southern Eastern Question B: s the United States, or one of its agencies or employees, a party to this action? Yes No f "no, " go to Question C. f "yes," check the box to the right that applies, enter the corresponding division in response to Question D, below, and skip to Section X. Los Angeles Ventura, Santa Barbara, or San Luis Obispo Orange f the United States, or one of its agencies or employees, is a party, is it: A PLANTFF? Then check the box below for the county in which the majority of DEFENDANTS reside. A DEFENDANT? Then check the box below for the county in which the majority of PLANTFFS reside. Los Angeles Ventura, Santa Barbara, or San Luis Obispo Orange NTAL DVSON N CACD S: Western Western Southern Riverside or San Bernardino Other Riverside or San Bernardino Other Eastern Western Question C: Location of plaintiffs, defendants, and claims? (Make only one selection per row A. Los Angeles County B. Ventura, Santa Barbara, or San Luis Obispo Counties C. Orange County D. Riverside or San Bernardino Counties E. Outside the Central District of California F. Other ndicate the location in which a majority of plaintiffs reside: ndicate the location in which a majority of defendants reside: ndicate the location in which a majority of claims arose: C.1. s either of the following true? f so, check the one that applies: 2 or more answers in Column C only 1 answer in Column C and no answers in Column D Your case will initially be assigned to the SOUTHERN DVSON. Enter "Southern" in response to Question D, below. f none applies, answer question C2 to the right. C.2. s either of the following true? f so, check the one that applies: 2 or more answers in Column D only 1 answer in Column D and no answers in Column C Your case will initially be assigned to the EASTERN DVSON. Enter "Eastern" in response to Question D, below. f none applies, go to the box below. Your case will initially be assigned to the WESTERN DVSON. Enter "Western" in response to Question D below. Question D: nitial Division? Enter the initial division determined by Question A, B, or C above: NTAL DVSON N CACD WESTERN DVSON CV-71 (11/13 CVL COVER SHEET Page 2 of 3

14 Case 2:14-cv AB-PJW UNTED STATES DSTRCT Document COURT, 1 CENTRAL Filed 09/04/14 DSTRCT OF Page CALFORNA 14 of 14 Page D #:19 CVL COVER SHEET X(a. DENTCAL CASES: Has this action been previously filed in this court and dismissed, remanded or closed? NO YES f yes, list case number(s: X(b. RELATED CASES: Have any cases been previously filed in this court that are related to the present case? NO YES f yes, list case number(s: Civil cases are deemed related if a previously filed case and the present case: (Check all boxes that apply A. Arise from the same or closely related transactions, happenings, or events; or B. Call for determination of the same or substantially related or similar questions of law and fact; or C. For other reasons would entail substantial duplication of labor if heard by different judges; or D. nvolve the same patent, trademark or copyright, and one of the factors identified above in a, b or c also is present. X. SGNATURE OF ATTORNEY (OR SELF-REPRESENTED LTGANT: DATE: Notice to Counsel/Parties: The CV-71 (JS-44 Civil Cover Sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law. This form, approved by the Judicial Conference of the United States in September 1974, is required pursuant to Local Rule 3-1 is not filed but is used by the Clerk of the Court for the purpose of statistics, venue and initiating the civil docket sheet. (For more detailed instructions, see separate instructions sheet. Key to Statistical codes relating to Social Security Cases: Nature of Suit Code Abbreviation Substantive Statement of Cause of Action 861 HA All claims for health insurance benefits (Medicare under Title 18, Part A, of the Social Security Act, as amended. Also, include claims by hospitals, skilled nursing facilities, etc., for certification as providers of services under the program. (42 U.S.C. 1935FF(b 862 BL 863 DWC 863 DWW 864 SSD 865 RS All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of (30 U.S.C. 923 All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, as amended; plus all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405 (g All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security Act, as amended. (42 U.S.C. 405 (g All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security Act, as amended. All claims for retirement (old age and survivors benefits under Title 2 of the Social Security Act, as amended. (42 U.S.C. 405 (g CV-71 (11/13 CVL COVER SHEET Page 3 of 3