Electronically FILED by Superior Court of California, County of Los Angeles on 05/20/2020 03:41 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by N. Alvarez,Deputy Clerk

20STCV19252
Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Dennis Landin

JAMES R. FELTON, ESQ. (State Bar No. 138767)

j felton@gblawllp.corn
GAB LAW, LLP
16000 Ventura Boulevard, Suite 1000
Encino, California 91436
Tel: (818) 382-6200 ~ Fax: (818) 986-6534

Attorneys for Plaintiffs,

5 Dawn Dangaard aka Alana Evans, Jennifer Allbaugh
aka Ruby, and Kelly Gilbert aka Kelly Pierce

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10

DAWN DANGAARD aka ALANA EVANS, an CASK NO.:

individual, JENNIFER ALLBAUGH aka RUBY,
12 an individual, KELLY GILBERT aka KELLY UNLIMITED JURISDICTION
PIERCE, an individual,
13 COMPLAINT FOR:
14 (1) BREACH OF CONTRACT
)~ INTERNATIONAL ENTERTAINMENT (2) SERVICES RENDERED
15 ADULT UNIOIN, a federally recognized union, (3) DEFAMATION
AMANDA GULLESSERIAN, an individual, and (4) DEFAMATION
16 DOES 1 through 10, inclusive,
17 Defendants.
18

19

20 COME NOW Plaintiffs DAWN DANGAARD aka ALANA EVANS, an individual,

JENNIFER ALBAUGH aka RUBY, an individual, and KELLY GILBERT aka KELLY PIERCE, an
individual (" Plaintiffs'") and file the following complaint against Defendants, International

Entertainment Adult Union and Amanda Gullesserian, and DOES 1 through 1 0 (hereinafter
23

24 collectively referred to as "Defendants" ), as follows:

25 1. Dangaard is an individual and a resident of San Diego County, State of California.

26 2. Allbaugh is an individual and resident of County, State of Ohio.

27 3. Gilbert is an individual and resident of Bloomington, Illinois.

COMPLAINT FOR BREACH OF CONTRACT AND DEFAMATION

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 4. Plaintiffs are informed and believe and, on that basis, allege that the International
2 Entertainment Adult Union ("IEAU") is a federally recognized union.

5. Plaintiffs are informed and believe and, on that basis, allege that Gullesserian is the
4 Secretary of the IEAU and as set forth below, is the alter ego of such organization. Gullesserian

was, up till approximately three months ago, a resident of Los Angeles CA.

6. Plaintiffs are ignorant of the true names and capacities of Defendants DOES I
7 through 10 inclusive, and therefore sues these Defendants by fictitious names. Plaintiffs will amend
8 this Complaint to allege their true names and capacities when the same are determined, Plaintiffs are
9 is informed and believes and, on that basis, alleges that each of fictitiously named Defendants is

10 responsible in some manner for the damages herein alleged.

7. Plaintiffs are is informed and believes and thereon alleges that at all times herein
12 mentioned, each of the Defendants was the agent, servant and employee of the remaining Defendants
13 and was at all times acting within the course and scope of their agency or employment.
l4 8. There exists, and at all times herein mentioned existed, a unity of ownership between
~ g
15 Defendant IEAU, on the one hand, and Defendant Gullesserian, on the other, such that any
6
16 individuality and separateness between Defendant IEAU and Defendant Gullesserian have ceased
17 and Defendant Gullesserian is the alter ego of Defendant IEAU.

9. Plaintiffs are informed and believe and upon that ground allege that Defendant IEAU,
19 and at all times herein mentioned was, the alter ego of Defendant Gullesserian and there exists, and
20 at all times herein mentioned has existed, a unity of interest and ownership between such Defendants
21 such that any separateness has ceased to exist and that Defendant Gullesserian may have used assets
22 of the corporation for their personal use, causing assets of the aforementioned Defendant corporation
23 to be transferred to them without adequate consideration, and withdrew funds from Defendant

24 IEAU's bank accounts for their personal use.

25 10. Plaintiffs are further informed and believe and upon that ground allege that Defendant
26 IEAU, on the one hand, and Defendants Gullesserian, on the other, is, and at all times herein
27 mentioned were, alter egos and there exists, and at all times herein mentioned has existed, a unity of
28 interest and ownership between such Defendants such that any separateness between them has

COMPLAINT FOR BREACH OF CONTRACT AND DEFAMATION

I 87618 I . I - 32073.0001
 ceased to exist in that Defendants Gullesserian completely controlled, dominated, managed, and

operated the corporate Defendant and commingled assets to suit the convenience of Defendants
Gullesserian.

11. Plaintiffs are informed and believe, and upon that ground allege that Defendant IEAU

is, and at all times herein mentioned was, a mere shell, instrumentality, and conduit through which

Defendants carried on their business in the corporate name exactly as they had conducted prior to

incorporation, exercising complete control and dominance of such business to such an extent that

any individuality or separateness of Defendant IEAU and Defendants do not exist and at all times

herein mentioned, did not exist.

10 12. Plaintiffs are informed and believe, and upon that ground allege that adherence of the

fiction of the separate existence of Defendant IEAU as an entity distinct from Defendants would
12 permit an abuse of the corporate privilege and sanction fraud and promote injustice, as well as
13 sanction fraud, as the alter ego Defendants have deliberately rendered themselves financially unable

~~
14 to respond to money judgments.
3
15 FACTUAL BACKGROUND
6
16 13. On or about June 6, 2016, each of the Plaintiffs, signed contracts with the IEAU to
17 perform services on behalf of the Adult Performers Actors Guild ("APAG"). IEAU is the mother
18 union to APAG. The contracts were all the same and provided that each officer would be paid an
19 amount to be determined but also provided that in the event the officer provided services in excess of
20 a 40-hour week, the officer would be compensated at rate in excess of $ 15.50 per hour. This

21 certainly suggests that the officer's regularly salary would be in excess of $ 15.50 per hour. The

contracts indicate that they would terminate in two years but could be re-issued. In fact, in or about
23 June 2018, all of the contracts were re-issued under the same terms. The contracts were executed in
24 Los Angeles, CA and the services to be provided by the Plaintiffs were to be provided in Los
25 Angeles, CA and online. A true and correct copy of the contract provided to Shore is attached hereto
26 as Exhibit "A".

27

28

COMPLAINT FOR BREACH OF CONTRACT AND DEFAMATION

1876181.1 - 32073.0001
 FIRST CAUSE OF ACTION
(For Breach of Contract Against All Defendants)
14. Plaintiffs refer to and incorporate as though fully set forth herein Paragraphs 1

through 13, inclusive, of this Complaint.

15. Plaintiffs and Defendant IEAU executed written agreements for Plaintiffs to perform

services for APAG and be paid for those services.

16. Defendants breached their agreement with Plaintiffs by failing to pay the sums due

under the written agreements.

17. Based upon normal working hours, as required by the written agreements, the
10 following amounts should have been paid to each of the Plaintiffs from June 6, 2016 through May 1,

2020:
12 Dangaard - $ 124,400.00
13 Allbaugh - $ 124,000.00
14 Gilbert - $ 124,000.00
I~
~ ~ 0
15 18. As a result of the Defendants'reach of its obligations under the Settlement,

16 Plaintiffs have been damaged individually as noted above and collectively in the amount of
17 $ 372,000.00.

18 SECOND CAUSE OF ACTION

19 (For Goods and Services Rendered Against All Defendants)
20 19. Plaintiffs repeat and reallege the allegations set forth in paragraphs 1 through 18 of

21 the Complaint and incorporates the same by reference as if set forth at length herein.
22 20. Defendants requested, by words or conduct, that Plaintiffs provide services for the
23 benefit of IEAU.
24 21. Plaintiffs provided the services as requested by IEAU.
25 22. Defendants have not paid Plaintiffs for the services rendered despite
26
Plaintiffs'emands.
27 23. The reasonable value of the services provided is $ 496,000.00.

COMPLAINT FOR BREACH OF CONTRACT AND DEFAMATION

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 THIRD CAUSE OF ACTION
(For Defamation Against All Defendants)
24. Plaintiffs refer to and incorporate as though fully set forth herein Paragraphs 1

through 23, inclusive, of this Complaint.

25. On or about March 19, 2020, Defendants, and each of them, sent out false press

releases to all major media outlets and posted on the IEAU website. The press release was sent to all
involved with the union, including State Assembly members that Plaintiffs have relationships with,

as well as all union members, The press release provided in part that:

At this moment, the International Entertainment Adult Union would like to announce the
10 termination of our Adult Performers Actors Guild, APAG. The IEAU has official filed and
terminated APAG with the DOL, as well as filed lawsuit under the Supreme Court against
12 Alana Evans, Ruby and Kelly Pierce, APAG's former President, VP & Secretary to recover
13 all of APAG's assets totaling over $ 210,000,

~ I 14 The board of the IEAU can no longer tolerate under any circumstances, the constant online

15 hatefulness and the [bullying]; that is not what we are about or who we are, that is not the
0
16 professionalism we want to portray; therefore, the board has decided to pull back and
17 regroup.
18 The Adult Performers Actors Guild is a trademark entity of the International Entertainment

19 Adult Union therefore, the name will stay with the IEAU, all APAG members at this time
20 will be under the main IEAU membership. Once all that has been done officially, we have
21 retrieved back all assets from APAG officers, we will then regroup and figure out together,
22 how to move forward.
23 26. Gullesserian, the founder, noted that: "I put this union together for the [sole] purpose
24 to help people, and create a [safe] place for workers to be able to come to for guidance and help.
25 There has been so much slanderous talk and bullying; that helps no one, and it takes the focus away
26 of what is important. Right now, we need to pull together as an industry and a union is an entity that
27 can help everyone in this time of need. I was hoping they would all see the good in what they were
28

COMPLAINT FOR BREACH OF CONTRACT AND DEFAMATION

1876181.1 - 32073.0001
 able to do, but that doesn't seem to be possible, even though it saddens me, it's time to say
2 goodbye."
27. Elisabeth Thomas, International President also stated in the press release that: "We
4 thank all the current officers very much for all the work they have put into this union; however, we
5 wished you would of lead us with a more professional stance [sic] than is currently being projected
6 as the union, and we look forward to establishing the APAG chapter at a later date, once we have

7 had time to step back and regroup.

28, The press release continued by adding that "At this current time, APAG is no longer
9 registered with the Department of Labor under the IEAU. As of March 19, 2020 APAG, is now
10 officially terminated, until further notice. "The IEAU has official filed and terminated APAG with

the DOL, as well as filed lawsuit under the Supreme Court against Alana Evans, Ruby and Kelly
I2 Pierce, APAG's former President, VP & Secretary to recover all of APAG's assets totaling over
13 $ 210,000."

~ ~ =" 29. In addition to the press releases, Defendant Gullesserian make defamatory comments
j5 about Plaintiff Dangaard during a radio show that aired on March 20, 2020, Specifically,
0
16 Gullesserian stated that Dangaard was known to have doctored images placed on the internet.
17 30. These press releases referred to Plaintiffs by name throughout, was made of and
18 concerning Plaintiffs, and was so understood by those who read the press releases. The radio show
I9 referred to Dangaard by name.
20 31. Statements contained in the press releases and regarding Dangaard from the radio
2I show are false as they relate to Plaintiffs.
22 32. The statements are libelous on their face. They clearly expose Plaintiffs to hatred,
23 contempt, ridicule and obloquy because no lawsuit has been filed by IEAU against Plaintiffs,
24 33. The statements releases were seen and read on or about March 19, 2020 by all of the
25 individuals noted above and by those listening to the Dollhouse radio show on Blog Talk Radio.

34. As a proximate result of the above-described publication, Plaintiffs have suffered loss
27 of their individual reputation, shame, mortification, and injury to their feelings in an amount in
28 excess of $ 100,000.00 each.

COMPLAINT FOR BREACH OF CONTRACT AND DEFAMATION

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 35. The above-described publication was not privileged because it was published by

Defendants with malice, hatred and ill will toward Plaintiffs and the desire to injure Plaintiffs

36. Because of Defendants'alice in publishing, Plaintiffs seek punitive damages in an

amount to be determined at trial.

FOURTH CAUSE OF ACTION
(For Defamation Against All Defendants)
37. Plaintiffs repeat and reallege the allegations set forth in paragraphs 1 through 36 of

the Complaint and incorporates the same by reference as if set forth at length herein.

38. Plaintiffs participated with Defendants in a union board meeting on February 20,
10 2020. Defendants falsified the meeting minutes to slander Plaintiffs. Specifically, the following
statements were included in the minutes about statements that were not made on the call:
12 Let the record show as of the Ieau acknowledgement that there is no APAG 225.00 a month
13 membership. Membership is a one-time yearly fee of 225.00.

~~ =
Accepting membership dues without the knowledgement of the Ieau
'5
Article XX Sec. 2. The date and place of a special meeting shall be specified on the calls
6
16 thereof.
17 Dawn Dangaard stated "At this time, as president of APAG, speaking on behalf of every
18 representative from her board, they have I.a) NO INTEREST in moving forward with the

19 current agenda until we address the emergency issue that we are dealing with today."
20 8. President APAG continued to 1. c) TAUNT the IEAU Vice President for reaching out for
21 help.
22 Article XIII Section 1. Paragraph e. Committing any act of a malicious nature with the intent
23 to disrupt the progress of the International Union."

She states that 4. a) none of the Ieau board has actually read the language of what was

created after Amanda sent the bill that she listed proposal and yet again she is putting our

names, out hard work on the line by behaving in a rogue way and she was for one 4 b)
27 stayed that THEY ARE DONE WITH THIS TYPE OF BEHAVIOR."
28 Article XIII Section 1 Paragraph o. Leering or making explicit or implied on—the-job threats

COMPLAINT FOR BREACH OF CONTRACT AND DEFAMATION

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 Gullesserian states "yes when I put in the people to make the course the first name, I put was
2 Alana Evans. So, we had no intentions whatsoever not to include you."
Dawn Dangaard speaks up and stated you put my name on something without my

permission. Gullesserian states no I did not put your name on anything I placed your name

as someone who would be helping create the course proof we had no intentions not to include

you whatsoever
Bob takes the floor and states the Ieau board did not approve this we understand APAG did

not approve this the Ieau was never going to approve this without APAG Being."

Prop 60 was the condom initive in which Amanda still stands behind because you don't wear
10 a condom or you don't work, that is where that got us."

However, we do make additional notation that a statement was made "This is industry is
12 done with this Union, and they want it stopped now."
13 Acting as additional proof that APAG is no longer acting on behalf of its members it's acting

~ ~
14 on behalf of the thumb of Free Speech Coalition.
15 39. These alleged statements referred to Plaintiffs by name throughout, was made of and
0
]6 concerning Plaintiffs, and was so understood by those who read the alleged statements.
17 40. Statements contained in the false transcript are false as they relate to Plaintiffs.
18 41. The statements are libelous on their face. They clearly expose Plaintiffs to hatred,
19 contempt, ridicule and obloquy.
20 42. The statements releases were seen and read on or about March 19, 2020 by all of the

21 individuals noted above and by those listening to the Dollhouse radio show on Blog Talk Radio,
22 43. As a proximate result of the above-described publication, Plaintiffs have suffered loss
23 of their individual reputation, shame, mortification, and injury to their feelings in an amount in
24 excess of $ 100,000.00 each.
25 44. The above-described publication was not privileged because it was published by
26 Defendants with malice, hatred and ill will toward Plaintiffs and the desire to injure Plaintiffs.
27 45. Because of Defendants'alice in publishing, Plaintiffs seek punitive damages in an
28 amount to be determined at trial.

COMPLAINT FOR BREACH OF CONTRACT AND DEFAMATION

1876181.1 - 32073. 0001
 WHEREFORE, Plaintiffs prays for judgment against Defendants, and each of them, as
follows:

ON THE FIRST CAUSE OF ACTION:

1. For damages in excess of $ 372,000.00;

2. For costs of suit herein;

3, For attorney's fees pursuant to the terms of the Agreement;

4. For such other relief as the Court deems proper.

ON THE SECOND CAUSE OF ACTION:

1. For damages in excess of $ 496,000.00;
10 2. For costs of suit herein;

3. For such other relief as this Court deems proper.

12 ON THE THIRD CAUSE OF ACTION:
13 l. For damages in excess of $ 100,000.00;

I~ 14 2. For punitive damages in an amount to be determined;

15 3. For costs of suit herein;
0
16 4.. For such other relief as this Co1nt deems proper.
17 ON THE FOURTH CAUSE OF ACTION:
18 1. For damages in excess of $ 100,000.00;
19 2. For punitive damages in an amount to be determined;
20 3. For costs of suit herein;
21 4. For such other relief as this Court deems proper.
22 DATED: May 20, 2020 G&B LAW, LLP

23

24 By:
JAME . FELTON
25 Attorn for Plaintiffs,
Dawn ngaard aka Alana Evans, Jennifer
26 Allbaugh aka Ruby, and Kelly Gilbert aka Kelly
Pierce
27

28

COMPLAINT FOR BREACH OF CONTRACT AND DEFAMATION

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EXHIBIT A
 CONTRACT FOR
BOARD MEMBER OF
ADULT PERPERMORS ACTORS GUILD A.P.A.G.

OFFK,"AL BOARD MEMBER

THIS CONTRACT is entered into on June 6th, 2016 by and between The
International Entertainment Adult Union, a Federal approved by Union by
the US Government, hereinafter called "COUNCIL", Kelly Shore AKA Kelly
Pierce, hereinafter called "CONTRACTOR."

NOW, THEREFORE, in consideration of the mutual promises herein, the parties

here to COVENANT, PROMISE and AGREE as follows:

1. The CONTRACTOR agrees to perform for the COUNCIL, Board Member services
and duties outlined in attachment Exhibit A and constructed in The A.P.A.G.
Constitution and Bylaws.

All work products provided by CONTRACTOR under this contract shall be

complete and accurate. Any necessary corrections or revisions will be completed by
CONTRACTOR at CONTRACTOR'S expense. The agreement is for work on the
projects specified in the attaclunent. Performance of services which fall outside the
scope of this contract, and agreement for such services will be negotiated separately
in additional contracts between the COUNCIL and the CONTRACTOR.

2. The CONTRACTOR agrees to keep records of services rendered and not hold any
other position or office.

3. The CONTRACTOR agrees to complete each duty specified in the attachment

with uttermost honesty.

4. The CONTRACTOR shall not assign any interest in this Contract and shall not
transfer any interest.
 All non-proprietary reports, drawings, renderings, or other documents or materials
prepared by CONTRACTOR hereunder shall become the property of the
COUNCIL.

The CONTRACTOR shall obtain and maintain a insurance bond or whatever is

necessary to protect the COUNCIL with limits of liability of no less than $ 500,000.

The CONTRACTOR agrees to abide by the Objects and Purpose of this International
Union as described in The Constitution and By Laws Article VL

The CONTRACTOR agrees to respect all fellow officers and members to the
fullest degree, and show pride in everything that is done in regards to this Union.

This contract shall commence June 6th, 2016 and shall terminate on.iune 6",
2016. or may be terminated as set forth below:

10. This contract may be terminated as follows:

1. By mutual consent of the parties;

2. At any time on a material breach of any of the provisions hereof; or
3. By the COUNCIL on delivery of written notice thereof to CONTRACTOR
for good reason decided by the COUNCIL. Such notice shall be delivered to
the CONTRACTOR as well as to the LOCAL COUNCIL at least 30 days prior
to the termination date of the contract.

11. If this contract is terminated by the COUNCIL under the provisions of

paragraph ten or for any reason, CONTRACTOR shall not be compensated for
the work performed by CONTRACTOR prior to the termination hereof.

12. At the point in which this International Union and the CONTRACTOR agrees
to accept as compensation the amount of (% to be determined) of the
COUNCILS Union organizations and (% to be determined) of the COUNCILS
affiliated organizations, such as but limited to all charity and fund raiser events
for the term of the contract and will receive an annual salary, which is to be
decided by the International Executive Board members and payable in twelve
(12) equal monthly installments, after receiving an invoice, which has attached
a record of services rendered. With the prior approval of the COUNCIL or their
designated representative, CONTRACTOR may invoice, and the COUNCIL
agrees to pay, for any hours expended over the regular hours of eight hours a
day or forty hours a week total hours during the course of this agreement, at the
billing rate of $ 15.50 per hour. The COUNCIL also agrees to reimburse
 CONTRACTOR for standard office supplies, computer software (subject to
prior approval by the COUNCIL or their designated representative). At which
time the COUNCIL is able to compensate, the CONTRACTOR will be
compensated for the duties preformed from this day forward.

13. Approved payments of salaries, expenses, and disbursements for its officers
and employees, shall be paid by this International Union from the dues, fees
and funds accounted for. The Salaries, expenses and disbursements must all be
agreed upon by the which is to be decided on by vote of the International
Executive Board members and payable in twelve (12) equal monthly
installments. All disbursements of funds shall follow the local and international
constitution under Article XXVIII Section 4, Article XX1 Sections 1 — 7.

14. Insurance, retirement and all and any other benefits plans shall be determined
with in two (2) years of the creation of this International Union and its Local
Chapters and G»ilrls hy conducting a vote through calling of a special
convention specified in Article XVIII Section 1-4 of the Unions Constitution and
Bylaws.

15. Claims for money due or to become due to the CONTRACTOR fiom the
COUNCIL under this contract may be assigned by the COUNCIL to a bank,
trust company, or other financial institution without such approval. Written
notice of any such transfer shall be furnished promptly to the CONTRACTER.
Any attempt at assignment of rights under this contract, except for those
specifically consented to by both parties or as stated above, shall be void.

16. CONTRACTOR shall be construed to be an independent contractor and nothing

in this agreement is intended nor shall be construed to create an employer-
employee relationship, or a joint venture relationship. The services to be
provided by CONTRACTOR shall be provided in a manner consistent with the
professional standards applicable to such services. The sole interest of the
COUNCIL is to ensure that the services shall be rendered and performed in a
competent, efficient, and satisfactory manner. CONTRACTOR shall be fully
responsible or payment of all taxes due to the State of California or Federal
Government which would be withheld from compensation if CONTRACTOR
were a COUNCIL employee. COUNCIL shall not be liable for deductions for
any amount for any purpose from CONTRACTOR'S compensation.
CONTRACTOR shall not be eligible for coverage under COUNCIL'S
Workers'ompensation
Insurance Plan nor shall CONTRACTOR be eligible for coverage
for any other COUNCIL benefit, until those benefits become available, at which
time this contract will be adjusted.
17. The funds of this International Union weather to invest or reinvest, in all
property such as real or personal, tangible or intangible, shall be held for the
effectuation of the purposes and objects of this International Union and the
interest of the members. Otherwise all such funds shall remain in an
authorized banl& account unvested.

18. All monies matters, covered by this Constitution and Bylaws, including without
limitations in the name of this International COUNCIL, or affiliated bodies shall
at all times by subject to audit by this International COUNCIL, and all books,
records and documents pertaining to money matters in the International
Constitution shall be available for inspection, copying and auditing by all and
any members of this International Union.

19. The CONTRACTOR shall hold harmless and indemnify the COUNCIL, against
all claims, suits, actions, costs, counsel fees, expenses, damages, judgments or
decrees by reason of any person's bodily injury, including death or property
damage by CONTRACTOR or any person employed by CONTRACTOR or in
any capacity during the progress of the work, whether by negligence or
otherwise. CONTRACTOR shall also indemnify COUNCIL of any adverse
determination made by the Internal Revenue Service or State Franchise Tax
Board against COUNCIL with respect to CONTRACTOR'S "independent
contractor" status that would establish a liability for failure to make social
security or income tax withholding.

20. If any action at law or in equity is necessary to enforce or interpret the terms of
this contract, the prevailing party shall be entitled to reasonable attorneys'ees,
cost, and necessary disbursements in addition to any other relief to which such
party may be entitled.

21. In the performance of the work authorized under this contract, CONTRACTOR
shall not discriminate against any fellow officer because of race, creed, color,
ancestry, religion, marital status, medical condition, age, physical or mental
handicaps, veteran or non-veteran status, sex, national origin, or industry
reputation. There shall be no bad mouthing, judging, speaking ill of or
disrespect against any fellow officer of any union associated with this union as a
whole. This will be held grounds for immediate termination and will not in any
way be tolerated within this COUNCIL.
22. There shall be no bad mouthing, judging, speaking ill of or disrespect
against any fellow officer of any union associated with this union as
a whole. This w'ill be held grounds for immediate termination and
will not in any way be tolerated within this COUNCII.,

23. The CONTRACTOR shall, during the entire term of this agreement, which is to
be said of two years unless terminated as such stated in Paragraph ten and twenty
one of this contract, at which time of the COUNCIL will be administrated as
such stated in The Constitution and By Laws Article XXII Election of Officers
remain in office.

24. The CONTRACTOR hereby covenants that, at the time of the execution of this
contract, CONTRACTOR has no interest and shall not acquire any interest in the
future, direct or indirect, which would conflict in any manner or degree with the
performance of services required to be performed under this contract.
CONTRACTOR also covenants that in the performance of this work, no person
having any such interest shall be employed. CONTRACTOR will comply with
any conflict of interest code approved by COUNCIL,

25. The CONTRACTOR by signing this contract solemnly swears that she has not any
type of prior felony or misdemeanor on record weather Nationally or
international within the past 13 years. If CONTRACTOR acquires any such
felony or misdemeanor during the term of this contract, this contract will be
automatically dismissed with no compensation owed to CONTRACTOR by
COUNCIL, nor with any such further discussion or notice, as stated by the
Federal Department of Labor Law.

26. By signing this contract, the CONTRACTOR pledges the following:

 "I, pledge to accept my responsibilities as a
Board Member of The Adult Performers Actors Guild. pledge upon my honor that
I

Iwill faithfully observe the Constitution and Bylaws of this Union.

I pledge to do everything in my power to properly represent the members within

this industry and community.

Iwill not knowingly wrong a member or see a member wronged if it is in

my power to prevent it. I also pledge that will work to the best of my ability
I to
provide effective and responsible leadership to the members amIprivileged to
represent."

27. This agreement supersedes all previous agreements and constitutes the entire
understanding of the parties hereto. CONTRACTOR shall be entitled to no other
benefits other than those specified herein. No changes, amendments, or
alterations shall be effective unless in writing and signed by both parties.
CONTRACTOR specifically acknowledges that in entering into and executing this
agreement, CONTRACTOR relies solely upon the provisions contained in this
agreement and no others. EXECUTED at LOS ANGELES, CA on JUNE 6", 2016.

By:
INTERNATIONAL PRESIDENT
ELIZABETH THOMAS

Date:

By:
CONTRACTOR, Kelly Shore

Date: