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Mark G. Tratos (Bar No. 1086) [email protected] Laraine M. I. Burrell (Bar No. 8771) [email protected] GREENBERG TRAURIG, LLP 3773 Howard Hughes Parkway Suite 400 North Las Vegas, Nevada 89169 Telephone: (702) 792-3773 Facsimile: (702) 792-9002 Counsel for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
SPI ENTERTAINMENT, INC., a Nevada corporation,
Plaintiff,
v.
ERNESTO BELTRAN CHARGOY, an individual; ALEXIS SOMOZA ERICE, an individual
Defendants.
CASE NO.
COMPLAINT FOR DECLARATORY RELIEF
Plaintiff, SPI ENTERTAINMENT, INC. (“Plaintiff,” or “SPI”), a Nevada corporation, by
and through the undersigned counsel of record, alleges as follows:
NATURE OF THE ACTION
This is an action for Declaratory Judgment with ancillary claims for Fraud/Fraud in the
Inducement, Commercial Defamation and related claims. Plaintiff seeks declaratory and
injunctive relief, damages, attorneys’ fees, and costs.
PARTIES
1. SPI ENTERTAINMENT, INC. is a Nevada corporation, owned and operated by
Adam Steck (“Steck”), and which engages in the business of producing and promoting various
entertainers and live production shows in Las Vegas, throughout the United States and across the
globe.
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2. Upon information and belief, ERNESTO BELTRAN CHARGOY, (“Beltran”), is
a Mexican citizen doing business in the United States, including business related to the
entertainment industry in Las Vegas, Nevada.
3. Upon information and belief, ALEXIS SOMOZA ERICE (“Somoza”), is a
Mexican citizen doing business in the United States, including business related to the
entertainment industry in Las Vegas, Nevada.
JURISDICTION
4. This Court has original jurisdiction over the Parties and the subject matter of this
action under 28 U.S.C. §§1331, because it is an action arising under the laws of the United States
and specifically under the provisions of the Declaratory Relief Act, 28 U.S.C. §2201 (a).
5. This Court has supplemental jurisdiction under 28 U.S.C. §1367 over Plaintiff’s
state and common law claims.
6. This Court has personal jurisdiction over the Defendants, because both claim to
conduct business in Nevada, including alleging to have transferred large sums of money into a
Nevada account, and the alleged transactions or occurrences giving rise to this action and/or the
foreseeable harm caused by Defendants’ actions occurred within and/or to Plaintiff in this
jurisdiction such that the exercise of jurisdiction over Defendants in this jurisdiction is
foreseeable, fair, and reasonable.
7. Venue is proper in the United States District Court for the District of Nevada
under 28 U.S.C. §§1391(b). Venue lies in the unofficial Southern District of this Court.
ALLEGATIONS COMMON TO ALL COUNTS
A. STATEMENT OF FACTS:
1. In or about August, 2011, SPI began to discuss and negotiate the performance of
certain shows in Mexico and Latin America with Jorge Santos (“Santos”) with G S Booking
Agency (“GS”), located in Mexico. The shows included those produced and promoted by SPI,
and a show performed by Criss Angel (“Angel”), but produced and promoted by a third parties
representing Criss Angel.
2. Initially, SPI obtained authorization from representatives of Criss Angel to
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negotiate with GS for Criss Angel shows in Mexico.
3. On or about September 30, 2011, SPI sent a letter to GS representative Jorge
Santos confirming SPI would be Santos’ exclusive agent for procuring Criss Angel for
performances in Mexican Territory. The letter further stated that any financial transactions,
including deposits for Criss Angel were to be conducted with Mr. Santos and his company, GS.
Finally, if SPI receives word that a deal with Criss Angel cannot be reached, SPI will return any
deposit related to the Criss Angel negotiations within 48 hours. (See September 30, 2011 letter
from SPI, attached hereto as Exhibit 1).
4. On or about October 5, 2011, SPI Representative Adam Steck spoke with Criss
Angel’s representative who confirmed that Criss Angel was interested in performing in Mexico.
Mr. Steck relayed that confirmation to GS via email that same day. (See October 5, 2011, email
from Adam Steck, attached hereto as Exhibit 2).
5. Throughout October and into November 2011, SPI and GS continued to negotiate
a deal for Criss Angel shows. The negotiations included discussions of venue, seat capacity and
ticket price. During this time period, and to show his good faith intent in the negotiations,
Santos wired money into the SPI account on four separate occasions for an amount totaling
$142,935.00.1
6. On October 28, 2011, SPI confirmed with GS that Criss Angel had, and was
considering, the offer for performing in Mexico. (See October 28, 2011 email from Adam Steck
attached hereto as Exhibit 3).
7. On November 10, 2011, Criss Angel representatives communicated to SPI that
Criss Angel preferred to do a “one off” (one or two shows on one day only) and in Mexico City
to determine if his type of show will work in other venues. (See November 10, 2011 email from
Adam Steck attached hereto as Exhibit 4).
8. Negotiations between SPI and GS continued through the end of 2011, into 2012,
for various shows, including the Criss Angel show, all of which were to be performed during
2012. During this time, Santos expressly asked that negotiation letters from SPI be placed on
1 Supporting financial documentation will be marked “Confidential” and produced during discovery.
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SPI stationary. (See November 30, 2011 email from Santos attached hereto as Exhibit 5).
9. On or about November 22, 2011, SPI communicated to GS that Criss Angel had
some concerns about performing in Mexico including for his safety, and that the venue is too big
for the type of magic that he does. SPI further communicated to Santos that although Santos was
invited to see Criss Angel’s show if he was in Las Vegas, Criss Angel did not want to meet with
Santos. (See November 22, 2011 email from Adam Steck attached hereto as Exhibit 6).
10. In or about January 2012, SPI became aware that numerous rogue promoters in
Mexico, all unknown to SPI, who were publically and falsely claiming that they represented
Criss Angel for his upcoming performances in Mexico including for performances in venues
which were not part of the negotiations between SPI and GS. (See January 7, 2012 email from
Diego Camargo attached hereto as Exhibit 7).
11. Representatives of Criss Angel also became aware of these false representations
regarding Criss Angel’s agreement to perform in other venues in Mexico and, believing they
were fabricated in part by SPI and GS, on January 20, 2012, sent a cease and desist letter to SPI
and GS, among others, stating that the misrepresentations concerning Criss Angel must stop or
legal action would be taken to protect Criss Angel’s rights. (See January 20, 2012 Cease and
Desist Letter from MGM and David Barum, attached hereto as Exhibit 8).
12. Also, on or about January 20, 2012, GS requested a formal letter from SPI stating
that GS representative Jorge Santos has the exclusive representation of Criss Angel in Mexico.
SPI responded that it was not authorized to grant the requested exclusivity. Around this same
date, SPI expressly told GS to stop all talk and publicity regarding Criss Angel. (See January 20,
2012 email from Santos, attached hereto as Exhibit 9).
13. On or about February 2, 2012, SPI received a communication from Criss Angel’s
representative, David Barum, questioning a, “Press invitation released in Mexico by PR Agency”
concerning Criss Angel and which also references SPI. The PR entity identified in the press
release, Musikatum Entertainment, is unknown to SPI. That same date, SPI contacted Santos
and again informed him to cease and desist any talk or publicity regarding Criss Angel
performing in Mexico. (See February 2, 2012 email and press release, attached hereto as Exhibit
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10).
14. On or about February 9, 2012, SPI sent a formal letter to GS stating that because
of the numerous false representations by rogue promoters, all negotiations for Criss Angel shows
between SPI and GS will stop immediately. SPI continued to offer GS the ability to promote
other SPI shows in Mexico. (See February 9, 2012 letter from SPI, attached hereto as Exhibit
11).
15. By February 9, 2012, SPI had made four wire transfers to Santos returning
$138,383.60 of the monies Santos had sent to SPI. The balance of $4,551.40 was for non-
refundable first class airline tickets, and it was agreed between SPI and Santos that this portion
would not be refunded to Santos.2
B. DECEMBER 14, 2012, CEASE & DESIST LETTER FROM BELTRAN:
16. On December 14, 2012, SPI received a letter from attorneys claiming to represent
Ernesto Beltran Chargoy (“Beltran”). (See December 14, 2012 letter from “Procopio”, attached
hereto as Exhibit 12). SPI has never heard of Beltran, and has certainly never conducted any
negotiations, or entered into any agreements with Beltran. The letter contains many
misrepresentations including the following:
a. On September 21, 2011, SPI as agent for Angel appointed Alexis Somoza (and Jorge Santos) as its agent to bring Angel to perform seven shows in Mexico from February 8 – 16, 2012. (See Exhibit 12, page 1) SPI has never heard of, or had any connection to, an Alexis Somoza nor was there a contract with Santos to provide Criss Angel for the shows on the dates mentioned. The Exhibit 1 referenced in the letter (Plaintiff’s Exhibit 12 attached hereto) is a letter with forged letterhead and a forged signature as will be further explained below.
b. On October 13. 2011, Somoza on behalf of SPI, contracted with Beltran to invest $550,000.00 in the Angel shows to be held in Guadalajara, Mexico. Beltran transferred $550,000 into SPI’s account. (See Exhibit 12, page 1)
SPI has never heard of Somoza; has never authorized Somoza to act on its behalf; has never heard of Beltran; and has never authorized a third party to contract with Beltran on SPI’s behalf. Moreover, SPI did not enter into any final agreement on behalf of Criss Angel, for Angel to perform in Mexico. Finally, SPI did not receive $550,000 from Beltran, Somoza or any person or entity.
2 Supporting financial documentation will be marked “Confidential” and produced during discovery.
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The Exhibit 3 reference in the letter (Plaintiff’s Exhibit 12) is a letter with forged letterhead and a forged signature as will be further explained below.
c. SPI made written assurances to Santos and thus to Beltran that Santos could represent himself as Angel’s “exclusive” representative in Mexico. (See Exhibit 12, page 2) At no time during its communications with Santos was the name Beltran ever mentioned, SPI had no awareness of the existence of Beltran. In fact, no communications were received from, sent to, or copied to Beltran or Somoza. At no time did SPI receive money from Beltran and/or Somoza through any means.
d. SPI engaged in fraud because it never had authorization to commit Criss Angel to performances in Mexico. (See Exhibit 12, page 2). SPI initially had authorization to negotiate on behalf of Criss Angel. As stated above, the authorization was rescinded upon the discovery of rogue promoters claiming to represent Criss Angel. (See November 14, 20011 email between SPI and Criss Angel representatives Lorena Villanueva, attached as Exhibit 13).
C. FORGED DOCUMENTS, INCLUDING FORGED SPI LETTERHEADS, AND SIGNATURES:
17. SPI uses a blue letterhead with a specific logo, in gradated shades of blue shown
as follows:
(See December 7, 2011 letter sent to Santos on valid SPI Letterhead, attached hereto as Exhibit
14).
18. And with a solid blue block footer with the contact information formatted to line
up with the bottom of the logo, shown as follows:
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(See December 7, 2011 letter sent to Santos on valid SPI Letterhead, attached hereto as Exhibit
14)
19. When the letterhead is copied in black and white it appears in gradated shades of
grey on a white background as follows:
(See December 7, 2011 sent to Santos on valid SPI Letterhead copied in black and white,
attached hereto as Exhibit 15).
20. When the footer is copied in black and white it appears as follows and of course
with the contact information formatted to line up with the bottom of the logo:
(See December 7, 2011 sent to Santos on valid SPI Letterhead copied in black and white,
attached hereto as Exhibit 15).
21. The letterhead on the forged documents appears only in black and white, absent
the gradated shades of grey and with a solid black background as follows:
(See Exhibit 1 attached to the Procopio Cease and Desist letter, attached hereto as Exhibit 12).
22. The footer in the forged documents shows the contact information is not
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formatted to line up with the bottom of the logo, there is a large gap between the address and
telephone number, the logo font is different and the address is in a bolder font, and appears as
follows:
(See Exhibit 1 attached to the Procopio Cease and Desist letter, attached hereto as Exhibit 12).
23. Upon information and belief, the Beltran cease and desist letter is fraudulent and
supported by forged documents, and sent to SPI with the intent to extort more than $550,000
from SPI.
24. Accordingly, SPI alleges the following claims against Defendants:
FIRST CLAIM FOR RELIEF (Declaratory Judgment)
25. Plaintiff realleges and incorporates each and every allegation of the preceding
paragraphs as if fully set forth herein.
26. On or about December 14, 2012, SPI received a cease and desist letter from
Beltran’s counsel making false allegations that SPI entered into an Agreement with Beltran
through Defendant Somoza for Criss Angel to perform in Mexico, and under that same
Agreement SPI accepted a payment of $550,000 from Beltran. The letter was supported by
documents on forged SPI letterhead with forged signatures allegedly signed by representatives of
SPI.
27. The letter concluded that SPI did not have the right to negotiate deals on behalf of
Criss Angel and demanded that SPI return $550,000 plus expenses and lost profits for a total of
$768,000.
28. SPI denies ever knowing Beltran, or Somoza, and denies having entered into the
forged agreement, or executing the forged letters, and denies ever receiving any money from
Beltran and/or Somoza.
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29. SPI denies owning Beltran and/or Somoza any money whatsoever.
30. Beltran’s false allegations arise from forged agreements and documents as set
forth above.
31. These false allegations which are vehemently denied by SPI constitute an actual
and justifiable controversy that is ripe for adjudication by this Court under the Declaratory Relief
Act, 28 U.S.C. §2201 (a).
32. These false claims and allegations of Beltran, and similar rogue promoters, have
harmed and are harming SPI. These allegations have caused SPI to lose production and
promotion deals including the Mexican deal with Criss Angel.
33. SPI, therefore, seeks a declaratory judgment that it did not engage in any business
whatsoever with the Defendants, did not receive any monies whatsoever from the Defendants,
and does not owe any monies to the Defendants.
34. SPI has been required to retain the services of counsel to prosecute this action and
it seeks the recovery of its attorneys fees and costs incurred herein.
SECOND CLAIM FOR RELIEF (Fraud/Fraud in the Inducement)
35. Plaintiff realleges and incorporates each and every allegation of the preceding
paragraphs as if fully set forth herein.
36. On or about December 14, 2012, SPI received a cease and desist letter from
Beltran’s counsel making fraudulent allegations that SPI entered into an Agreement with Beltran
through Defendant Somoza for Criss Angel to perform in Mexico, and under that same
Agreement SPI accepted a payment of $550,000 from Beltran.
37. Specifically the agreement states that SPI entered into an agreement with Somoza
as shown by a letter dated September 21, 2011. The letter dated September 21, 2011,
purportedly from SPI to Somoza is comprised of a forged letterhead with forged signatures, and
contains fraudulent representations.
38. Similarly the September 21, 2011, agreement allegedly entered into between SPI
and Santos is likewise forged and the contents of the agreement are fraudulent.
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39. Also, the purported agreement for Criss Angel to perform in Guadalajara in
February 2012 was on forged SPI letterhead and the contents are fraudulent.
40. The cease and desist letter claims that Beltran was required to pay $550,000 under
the agreement and several wire transfers totaling that amount were sent to SPI bank accounts in
the United States. Absent from the documents attached to the cease and desist letter is evidence
of these purported monetary transfers.
41. The allegation that Beltran transferred $550,000 to SPI bank accounts is
fraudulent.
42. The cease and desist letter with its false demands, and its attached forged
documentation, is intended to fraudulently induce SPI into paying defendants $768,000 or more.
43. These fraudulent claims and forged documents have harmed and are harming SPI.
These allegations have caused SPI to lose production and promotion deals including the Mexican
deal with Criss Angel.
44. As a direct, proximate, legal result of these misrepresentations, SPI has been
damaged.
45. SPI seeks the recovery of its attorney’s fees and expenses, actual and
consequential damages, which are in excess of $75,000.00, and as the unlawful actions of
Defendants were willful and malicious, SPI seeks the recovery of the maximum amount of
punitive damages permitted by Nevada law.
THIRD CLAIM FOR RELIEF (Commercial Defamation)
46. Plaintiff realleges and incorporates each and every allegation of the preceding
paragraphs as if fully set forth herein.
47. As set forth above, Defendants and their agents have engaged in rogue
promotional deals wrongfully claiming an affiliation with SPI. Further, Defendants have made
misrepresentations to third parties including publicity statements that Beltran is working with
SPI to bring Criss Angel to Mexico to perform. Beltran’s public advertising and promotion of
Criss Angel performances in Guadalajara in Mexico is admitted in the cease and desist letter
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and encompasses part of the expenses Beltran seeks from SPI.
48. These public statements are false and because there was no agreement for Criss
Angel to perform in Guadalajara Mexico, SPI is being blamed for the failure of Criss Angel to
perform impacting the reputation of SPI and its principals.
49. The Mexican public and other third parties to whom Defendants made and/or
published these false statements understood that SPI was to blame for Criss Angel not
performing in Guadalajara in February 2012.
50. Representatives of Criss Angel became aware of these false statements, attributed
them to SPI and on January 20, 2012, sent SPI a cease and desist letter. Consequently, all
negotiations between SPI and Criss Angel were terminated.
51. By blaming SPI for Criss Angel’s failure to perform in Mexico, Defendants
knowing and intentionally made defamatory statements which have caused SPI to lose business,
and to suffer irreparable harm to its good will and reputation and to that of its principals for
which there is no adequate remedy at law.
52. SPI seeks injunctive relief, the recovery of its attorney’s fees and expenses, actual
and consequential damages, which are in excess of $75,000.00 and the maximum amount of
punitive damages permitted by Nevada law.
FOURTH CLAIM FOR RELIEF (Intentional Interference with Prospective Economic Relations)
53. Plaintiff realleges and incorporates each and every allegation of the preceding
paragraphs as if fully set forth herein.
54. As set forth above, SPI had existing prospective contractual relationships with
third parties including Criss Angel.
55. Defendants knew of these prospective relationships.
56. Defendants intended to harm SPI by publicly alleging Beltran was involved in the
SPI/Criss Angel agreement thus creating a public perception of rogue promoters claiming to
represent Criss Angel.
57. The public knowledge of rogue promoters caused Criss Angel representatives to
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