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8/9/2019 Carter Complaint Part 3
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Roberts RICK ROSS, but none of the Defendants had a right to use the name,
and Defendants ignored letters from Plaintiffs lawyer in October-November,
2006 to Def Jam, to stop using RICK ROSS name, and the 2006 letters are
attached hereto as Exhibits C, D, and E. An online VH1.com news article dated
07/27/2006 confirms that Defendant Roberts got signed by Defendants Carter,
Def Jam and UMG who invested millions, and a copy of that article is
attached and incorporated by reference as Exhibit H, as well as the full page
back cover RICK ROSS magazine photo print ad for Roberts at Exhibit I.
137. Plaintiff Rick Ross is suing to take his name and image back from
Defendants control, and to stop Defendants from fraudulently misusing his
name.
138. Plaintiff could not discover, through the exercise of reasonable due
diligence, the full scope of Defendants fraudulent acts because Defendants
never responded to reasonable letters from Plaintiffs attorney sent directly to
Def Jam in 2006, which were acknowledged being received by Nicole by
telephone, plus Defendants fraudulently concealed their unlawful music
activities from the public and Defendants failed to disclose or give any notice of
name use to Plaintiff, or seek his consent, and Defendants material
misrepresentations and omissions were intentional and done with intent to
deceive Plaintiff and falsely induce reasonable reliance that the Defendants
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would do right, not the fraudulent, harmful acts done.
WHEREFORE, Plaintiff demands judgment against each of the
Defendants, individually, and/or jointly with each other, for civil damages
sustained as a result of Defendants fraudulent actions, misrepresentations and
omissions, from 2006 to the present, concealed from Plaintiff, and Plaintiff
request that this Court award monetary damages to Plaintiff in excess of $1
Million for Defendants fraudulent actions, which caused this lawsuit, and
Plaintiff demands legal remedies available under California law, common law,
and the California Civil Code, in an amount to be determined at trial, but no less
than $1 Million in compensatory damages, plus$1 Million in punitive damages,
plus all injunctive remedies available in this Court as the direct result of
Defendants unlawful fraudulent activities, and an order compelling Defendants
to pay all costs, disbursements and expenses paid by or incurred by Plaintiff, as a
result of Defendants unlawful conduct, including attorneys fees and court
costs, interest to the extent provided by law, and all such other damages and
legal and equitable relief this Court deems proper.
COUNT VIII
COLLUSION AND CONSPIRACY TO DEFRAUD
Plaintiff v. all Defendants, individually and jointly
139. Plaintiff Ricky D. Ross a/k/a RICK ROSS incorporates by
reference all the prior averments made in Paragraph 1 through 138, as if set forth
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at length.
140. Defendants jointly engaged in fraudulent acts or omissions, to
deceive the Plaintiff and deceive others, in collusion, agreements by two or more
persons to defraud a person of his rights or obtain an object forbidden by law,
and in this case and controversy, the object forbidden by law was Plaintiffs
name and rights that Defendants wanted, and acted fraudulently, and
maliciously, to control, use and convert to Defendant Roberts benefit and
Defendants ownership, unlawfully, and Defendantsjointly employed fraudulent
means to accomplish their unlawful purposes, and lawful means, to accomplish
their unlawful purposes, by concerted business actions, secret combinations and
agreements concealed from Plaintiff.
141. Defendants jointly conspired and agreed to act in concert for the
purposes of committing, by their joint efforts unlawful acts, or lawful acts, by
unlawful means, to achieve the unlawful purpose of controlling Plaintiffs name,
likeness and identity which Defendants had no authority nor right to do
individually, nor jointly, but Defendants acted, in secret combination, as if they
obtained lawful authority or rights from Plaintiff or the USPTO to so act, and
Defendants held themselves out to the world, falsely, as the holders and owners
of Plaintiffs name and rights, while they exploited the Plaintiff, who was in
prison with a life sentence, and maliciously used his name and identity for
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unlawful monetary gains, in violation of the Plaintiffs rights.
142. Defendants acted in concert and in an unlawful conspiracy to
defraud Plaintiff out of his name, its value and to manipulate use of the Rick
Ross name, for Defendants unlawful commercial purposes, without Plaintiffs
consent, while Plaintiff was in prison, and from 2006 to present, the Defendants
spent and made millions by using Plaintiffs RICK ROSS name, image and
reputation in commerce, while Plaintiff suffered financial loss, disrespect and
humiliation from the fraud.
143. Defendants Roberts allegedly started his rap career when he was
with Suave House Records, and then went on to Slip-n-Slide Records, at some
point marketing himself as RICK ROSS, a non-fictitious real name which he
used while Plaintiff was in prison, and based on his hit Hustlin and the
attention RICK ROSS name brought to Roberts, Defendant Roberts caught the
attention of Defendants Def Jam, UMG, and Carter who agreed to sign and
distribute Roberts music under the RICK ROSS name, but Defendants never
registered or cleared use ofthe RICK ROSS name, before using it, to brand
Roberts RICK ROSS and to violate Plaintiffs rights, which Defendants knew
or should have known, because Defendants were experienced in music business,
but Defendants started spending and preparing for the release of Roberts new
music, under Plaintiffs name, doing media, photo shoots and recordings, and
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promoting Roberts using Plaintiffs name and entered in conduct and agreements
that constituted unlawful acts, designed to wrongfully help Defendants profit off
the name without consent, and Defendants contracted with each other and third
parties, to further commit unlawful acts, by using Plaintiffs name, without
authority, and evenplanned to take control over Plaintiffs name and use it for
Defendants commercial gain in the future, without Plaintiffs consent, and
refused to respond to Plaintiffs lawyers who contacted Defendants for Plaintiff
in 2006 and 2010, and put them on notice.
144. In fall, 2006, Defendants avoided and ignored the Plaintiffs
lawyers letters, thus Defendants knowingly engaged in unlawful actions in bad
faith, with prior notice that they were requested to cease and desist before
using the name..
145. Defendants conspiracy is continuing, and has not stopped, and the
purposes of the conspiracy have not changed since it began before 2006, when
Defendant Slip-n-Slide was involved with Roberts in the conspiracy from the
very beginning, then Carter and Def Jam joined in, and by refusing to respond to
letters from Plaintiffs lawyer, Def Jam showed it was part of this conspiracy,
and Defendants acted out their master plan in concert to profit off of Plaintiffs
name, and Def Jam and UMGs unexplained failure, intentional decision or
refusal, to act
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responsibly and as legally expected and respond to letters from Plaintiffs 2006
and 2010 lawyers at Exhibits C, D, E and J respectively, shows a bad
pattern of practices, and a negligent or intentionally bad faith course of conduct,
that Def Jam and UMG, principals who invested financially in the conspiracy,
intended to conceal their dealings and profit to the tune of millions of dollars
unjustly from all.
146. Since 2006, as a direct result of the scheme, Defendants represented
to the public, media and the music community, fraudulently and knowingly, that
they and Roberts had legal rights to exploit the name RICK ROSS, when they
did not have any rights to Plaintiffs name, and the USPTO never approved a
trademark , so Defendants Def Jam, Universal, Carter and others acted
unlawfully, in bad faith,
maliciously, fraudulently, and with the intent to deceive Plaintiff and the public.
WHEREFORE, Plaintiff demands judgment against the Defendants, as
co-conspirators against Plaintiff and Plaintiffs name, and the Defendants are
jointly liable to Plaintiff, for their collusive actions and unlawful conspiracy, in
an amount to be determined at trial, but no less than $10 Million compensatory,
and punitive, damages for Defendants malicious, manipulative, outrageous, and
egregious acts, retroactive to October, 2006 and an award of attorneys fees and
court costs, to Plaintiff for Defendants calculated plan and scheme to defraud
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Plaintiff out of his rights, and then defraud the public into believing that
Defendants owned, or had right to use, Plaintiffs name and rights Defendants
didnt own, or control, and Defendants willful misconduct, entitles Plaintiff to
immediate, injunctive relief, the seizure of Defendants business records to
determine the full extent of the conspiracy and the right to a formal accounting
of Def Jam and UMG books, because Defendants conspiracy succeeded and
Defendants made millions of dollars and are still making millions up to the
present unlawfully off Plaintiffs name, whereby Plaintiff demands an order be
entered immediately forcing Defendants to cease and desist from any and all
use of Plaintiffs name pending Court orders regarding injunctive relief
requested by the Plaintiff..
COUNT IXTORTIOUS INTERFERENCE WITH BUSINESS
RELATIONS
Plaintiff v. all Defendants, individually and jointly
147. Plaintiff Ricky D. Ross a/k/a RICK ROSS incorporates by
reference the averments in Paragraph 1 through 146 herein as if fully set forth at
length.
148. Plaintiff was recently released from federal prison in November,
2009 and since that time Plaintiff has been attempting to find lawful gainful
employment and pursuing entertainment business opportunities in Los Angeles,
California, as to avoid involvement with any illegal activities, for which he was
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incarcerated, and to attempt to clear his name from its negative influences as
Plaintiff desires to change his life for good, and to do positive things in his
community, in pursuit of his new life, and Plaintiff has been shopping his life
story for adaptation as a new movie, and recently he signed a production deal for
his movie using Plaintiffs name.
149. Due to the sheer magnitude of Defendants investment in Plaintiffs
name, for branding of Defendant Roberts, amounting to spending of millions of
dollars, and Defendants major positions of authority in the entertainment
industry, the Plaintiff has been prevented from securing contractual
commitments and by design Defendants have directly and indirectly interfered
with Plaintiffs business and commercial opportunities in his name, especially
on the Internet and his Web 2.0 activities, which are unduly limited and
restricted, by Defendants control over his name, so Plaintiff used his nickname,
and became the first federal inmate to create a social networking website called
FREEWAY ENTERPRISE.com,but as to Plaintiffs RICK ROSS name,
Defendants dominate its use in commerce.
150. Plaintiff has been, and is being, damaged by his inability to use his
own name, RICK ROSS, to pursue lawful business opportunities and internet
options, Defendants wrongful acts are preventing exercise of his constitutional
rights, and his domain name rights at 15 U.S.C. Section 1114, and 1125(d)
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cyber-piracy violations under the official RICK ROSS website.
WHEREFORE, Plaintiff demands judgment against the Defendants and in
his favor, for reasonable damages for Defendants unlawful tortious interference
with his business and employment opportunities in California, and on award of
$50,000.00 for compensatory damages and $50,000.00 punitive damages, plus a
declaratory judgment order awarding Plaintiff sole rights to use, control, and do
business in Plaintiffs RICK ROSS name, and simultaneously an order to stop
Defendants immediately from using Plaintiffs name in any Defendants
business, especially in the music or entertainment industry, in Los Angeles,
Miami or NYC,plus attorneys fees and court costs, and sanctions against
Defendants for any failure to adhere to and abide by the Courts order, by an
action for contempt.
COUNT XUNJUST ENRICHMENT
Plaintiff v. all Defendants, individually and jointly
151. Plaintiff Ricky D. Ross a/k/a RICK ROSS incorporates by
reference all of the prior averments in Paragraph 1 through 150, as if fully set
forth at length.
152. Defendants, by way of accomplishment of their individual or joint
unlawful schemes or conspiracies since 2006, when Plaintiff was in prison, and
continuing up to and including the present, which Defendants benefited from
financially to the tune of millions of dollars, have been unjustly enriched by their
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unlawful actions, which requires a balancing of the equities in favor of Plaintiff.
153. Defendant Roberts and the other Defendants should not be
permitted, and should not have ever been permitted, to exploit, manipulate and
use Plaintiffs name for their unlawful benefit without Plaintiffs consent and
Plaintiff acted to prevent Defendants from infringing, using, and intruding upon
his name, but there was little that he could do while he was in prison, and but for
his early release from a life sentence in prison, Plaintiff would not have been
able to challenge Defendants unauthorized use of his name and identity, and in
2006, Plaintiff and his family hired a lawyer to contact the Defendants, and
request that Defendants cease and desist their unlawful use of his RICK ROSS
name, but Defendants intentionally refused to respond to Plaintiff lawyers 4 or
5 letters to Def Jams New York corporate offices but receipt of Plaintiffs 2006
lawyers letters were acknowledged as received by a Def Jam employee Nicole
by telephone.
154. Defendants enriched themselves to the tune of million of dollars in
profit from Defendant Roberts use of Plaintiffs name, and sales, which resulted
from Defendants Def Jam and UMG direct branding, marketing, promoting and
financing of Defendant Roberts as RICK ROSS, using Plaintiffs name, image
and identity, which unjust enrichment occurred at Plaintiffs expense, and
Defendants should be required to make restitution in the millions of dollars to
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the Plaintiff for the harm done to Plaintiff from Defendants unlawful use of his
name, identity and persona maliciously, retroactively from 2006 to the present or
trial.
155. Given Defendants tortious, blatantly unlawful actions, restitution
to Plaintiff in the millions of dollars is deemed appropriate under the
circumstances, as Defendants concealed their unlawful conspiracy from Plaintiff
and acted jointly against Plaintiffs financial interests to Plaintiffs detriment,
and Defendants never contacted Plaintiff to seek authorization, and never offered
Plaintiff anything nor responded to Plaintiffs reasonable inquiries about use of
his name by U.S. mail, plus Defendants manipulated and exploited Plaintiffs
name, image, identity and persona by fraudulent means, and damaged Plaintiffs
names value by their unlawful actions, and the money Defendants owe
Plaintiff made Roberts a star.
156. Defendants Roberts, Def Jam & UMG were unjustly enriched by
their wrongful use of Plaintiffs name and theyve illegally retained all the
benefits of their unlawful actions as a direct result of using Plaintiffs name, but
the financial benefits, under equity and justice, belong to Plaintiff in half, or in
part.
157. Defendants wrongful actions have caused substantial commercial,
mental, emotional and psychological damage to Plaintiff due to his loss of name.
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s.
158. Defendants unlawful actions made Defendant Roberts a rap star
based upon using Plaintiffs name and identity to brand Defendant Roberts as
RICK ROSS, and Defendants have made millions of dollars by Roberts using
Plaintiffs name as his rap name, they exploited Plaintiffs name to the
maximum extent, so much so that Defendant Roberts shouldnt be allowed to
use Plaintiffs name any more, and Defendant Roberts is recognizable now as a
successful rap star by his face, features, tattoos and his voice, independent of
RICK ROSS name, so justice and Plaintiff demands, and equity compels, that
Defendants and Defendant Roberts be prohibited from any future use of
Plaintiffs name and identity, for any reason, and that Defendants profits be
determined, and disgorged, by lawful means of an accounting, and be placed in a
constructive trust, for the benefit of Plaintiff.
WHEREFORE, Plaintiff Ricky D. Ross a/k/a RICK ROSS demands
that Defendants be compelled to make financial restitution to Plaintiff in an
amount determined at trial, but not less than $10 Million, retroactive to 2006, a
formal accounting, by Plaintiffs forensic accountant, for unjust enrichment
funds due Plaintiff to be placed in a constructive trust for Plaintiffs sole benefit,
that Defendants be forever prohibited from using RICK ROSS name in the
future, that Defendants, Roberts and Def Jam, UMG, Slip-n-Slide Records and
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Does, be required to notice third parties that they can no longer use Plaintiffs
name, that all Internet orphysical references to Defendant Roberts as RICK
ROSS be disabled, terminated, taken out of commerce or be authorized to be
seized, with fines being levied for violations of this Court Order, and an award
of attorneys fees and court costs to Plaintiff for Defendants outrageous,
malicious misconduct.
COUNT XINEGLIGENCE AND IMPUTED NEGLIGENCE
Plaintiff v. Defendants Def Jam, Carter, UMG and Universal specifically
159. Plaintiff Ricky D. Ross a/k/a RICK ROSS incorporates by
reference all of the averments made in Paragraph 1 through 158, as if fully set
forth at length.
160. Defendants Def Jam, a major national record label, and Defendant
Universal Music Group referred to herein as UMG, a major worldwide
distributor of content, signed Defendant Roberts directly or signed Slip-n-Slide
Records which furnished Defendant Roberts musical services, under major
recording and distribution Agreements which are the underlying contracts on
which Plaintiffs actions herein complained against are based, and consequently,
Def Jam, Carter, and Universal, industry veterans and corporate officials in the
music business, had a fiduciary duty of care they owed to the holders of
intellectual property rights, to make sure that they didnt infringe upon the rights
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of intellectual property owners by checking records and engaging in legal
searches to determine if rights users they contract with, or for, have obtained the
appropriate approvals from owners, before engaging in known unauthorized uses
of intellectual property and content.
161. As representatives of the music industry Def Jam and Universal
have a duty to the public and the industry to examine names, titles and rights
issues before they contract with parties who allege that they own names, and
rights to names, and certainly after they contract with the users of content, and
non-proprietary intellectual property, Defendants have a contractual duty to
review, verify, and authorize all desired uses before they begin to contract
further on the basis of any parties names, symbols, etc., especially in the rap
music industry, where artists often indiscriminately use names of prior
intellectual property owners.
162. Defendants Def Jam and UMG had a contractual relationship and
legal duty, to conduct due diligence regarding the use of Plaintiff RICK
ROSS trade name, and they used Carter as an agent and established a duty of
care owed Plaintiff, and to intellectual property right holders, to the public and
the industry, and they intentionally chose to violate Plaintiffs common law
trademark, and trade name, in their blind pursuit of commercial gain, on their
commercial RICK ROSS musical projects, from 2006 to the present,
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consequently any planned commercial release of any alleged William Leonard
Roberts II projects, in RICK ROSS name, which includes an imminent 2010
album, must be enjoined due to this negligence.
163. But for Defendants Def Jams, Carter, and Universal Music
Groups breach of duty and known misconduct by apparent failure to clear the
rights to use Plaintiffs name RICK ROSS, which Defendant Roberts now
falsely claims that he made up, and did not take from the ex-drug dealer Plaintiff
Rick Ross, Defendant Roberts would not have been able to violate Plaintiffs
legal rights, since the U.S. Patent & Trademark Office failed to approve Roberts
RICK ROSS registration, and actions, conspiracy, harm, fraud,
misrepresentation, rights violations, and torts complained about herein by
Plaintiff, would not have occurred or existed, but they did occur and do exist,
and Defendants Def Jam and Universals negligence is, and was, the proximate
cause of the commercial and other injuries to Plaintiff , which Plaintiff demands
damages and equitable relief for the reckless omissions of duty.
164. Defendants Def Jam, Universal Music Group and Carter, neglected
their duty of care owed to Plaintiff, the public and their artist Defendant Roberts,
by not conducting the proper due diligence, and not informing parties that the
Plaintiffs name was not cleared and was in dispute, and with agent Carter doing
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the bidding in 2006 for the rights to Defendant Roberts services, Def Jam and
Defendants got caught up in the Roberts deals self-dealing and ignored their
due diligence duties, proximately causing harm as the direct result of their
breaches of fiduciary duties and their unmistaken negligence under the
circumstances.
165. Defendants Def Jam and UMG have been unjustly enriched by their
breach of fiduciary duty, and equity requires that they do not profit from their
negligence.
WHEREFORE, Plaintiff demands that Defendants Def Jam, Universal and
Carter, be required to submit to an accounting by Plaintiff of all earnings they
made from Defendant Roberts projects under the name RICK ROSS, and be
required to remit all earnings to a constructive trust for Plaintiff, and that said
Defendants be ordered to disgorge all their profits and pay them over to plaintiff
in amounts to be determined at trial, but not less than $10 Million, exclusive of
interest and costs, plus be ordered to pay attorneys fees, court costs, and
appropriate equitable relief, and submit to implementing name changes, and
website changes.
COUNT XIIEQUITABLE RELIEF AND FORMAL ACCOUNTING
Plaintiff vs. all Defendants, individually and jointly
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166. Plaintiff Ricky D. Ross a/k/a RICK ROSS incorporates by
reference all the averments in Paragraph 1 through 165 herein as if fully set forth
at length.
167. Plaintiff, as the damaged party who has an interest in gross receipts
from the use of his RICK ROSS name that Defendants have, and had, no right
to use, has a right to demand, for any purposes, including determining the extent
to which Defendants have profited from his RICK ROSS name, due to their
unlawful conduct, all books and records of the Defendants regarding the RICK
ROSS projects from 2005 to the present including royalty and publishing
statements, Business Affairs and Legal Department records, contracts,
correspondence and reports, legal opinions, an accounting of each Defendants
RICK ROSS profits, distribution statements, executive compensation
agreements, packages and bonuses to employees, and proof of all profits
received subject to the rights of Plaintiff, and furthermore, the Plaintiffs RICK
ROSS name search and trademark records, records detailing the sale of music
products under the name of RICK ROSS worldwide, from recordings,
ringtones, ring-back tones, online downloads, music synchronization uses,
concerts and special performances, merchandising, music publishing, and
Maybach Music Groups books, business records, contracts, and merchandising,
for all the recordings in RICK ROSS name.
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168. Equity compels an accounting and injunctive relief against Defendants.
169. Plaintiff demands a Temporary Restraining Order and a joint
Preliminary Injunction against Defendants under Rule 65 of the Federal Rules of
Civil Procedure and U.S Central District of California Local Rules, L.R. 65-1,
and L.R. 7-4 thru 7-8, at time of filing and presentation of this Verified
Complaint under federal law, to bar or prevent the continued use of Plaintiffs
name publicly, on music or other business and/or commercial products that can
result in further harm to Plaintiff and additional likelihood of confusion between
Plaintiff, and Defendant Roberts, who unlawfully claimed the name RICK
ROSS and Defendants shall be ordered to submit to a computer forensics expert
review, and financial audit, to determine extent ofPlaintiffs trademark and
name rights use.
170. Plaintiff demands a Jury Trial under Rule 38 of the Federal Rules of
Civil Procedure, according to the Seventh Amendment of the United States
Constitution.
WHEREFORE, Plaintiff requests a formal accounting of all of RICK
ROSS profits accounted, collected, reported and paid quarterly, or in royalties
or otherwise, Defendants legal and business records, for net profits accounting
purposes, and General corporate ledgers, and Plaintiff demands comprehensive
earnings, royalty and accounting statements, and equitable relief ordered by this
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Court by Order, and due to Defendants proven willful misconduct, Defendants
be ordered to pay Plaintiffs legal and forensic accounting fees, court courts, and
transcription costs, ordinary, necessary legal expenses, and a waiver of any costs
for a bond.
DATED: June 15, 2010 LAW OFFICES OF MELVIN T. SHARPE
By: ________________________________Melvin T. SharpeAttorney for Plaintiff
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