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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION Flava Works, Inc.

and Phillip Bleicher, Plaintiffs, ) ) ) ) ) ) ) ) ) ) ) )

Case No. 2011-L-008115

v.

COMPLAINT JURY TRIAL DEMANDED

Jamie Alistair Gonzalez ,

Defendant.

Plaintiffs, Flava Works, Inc. and Phillip Bleicher, by and through their attorneys, Meanith Huon, and for their complaint against the Defendant, Jamie Alistair Gonzalez, states as follows:

COUNT I 1. Plaintiff, Flava Works, Inc., is a corporation incorporated under the laws of the

State of Illinois and the State of Florida with its principal place of business at 2610 N. Miami Ave., Miami, Florida 33127 and in Chicago, Illinois at 933 W. Irving Park Rd., Ste. C, Chicago, Illinois 60613. 2. 3. Plaintiff, Phillip Bleicher, is the CEO of Flava Works, Inc. On information and belief, Defendant, Jamie Alistair Gonzalez is a resident of the

State of Illinois. 4. At all relevant times, Plaintiffs had an exclusive modeling contract with Cody

McCart a/k/a Cody Kyler. 5. Plaintiffs had a reasonable expectation of entering into a valid business

relationship and/or prospective economic advantage with Cody McCart, namely, a 3-year modeling contract to produce gay adult films. 6. 7. Defendant, Jamie Alistair Gonzalez knew of this expectancy. On information and belief, Defendant, Jamie Alistair Gonzalez entered into a

relationship with Mr. McCart and provided him with financial support. 8. On information and belief, Defendant, Jamie Alistair Gonzalez intentionally

and unjustifiably interfered to prevent the expectancy of Mr. McCarts contract with Plaintiffs from being fulfilled. 9. On information and belief, Defendant, Jamie Alistair Gonzalez advised and

induced Mr. McCart that he should breach his contract with Plaintiffs to pursue a career in fashion modeling. On information and belief, Defendant advised Mr. McCart that he could make a lot more money by breaching the contract and pursuing a career in the fashion industry. 11. As a result of the interference and acts of the Defendant, Jamie Alistair

Gonzalez, Cody McCart breached his contract with Plaintiffs. 12. As a result of the interference and acts of the Defendant, Jamie Alistair

Gonzalez, Plaintiffs sustained damages. 13. Plaintiffs had invested considerable time and money and resources building the

brand of Cody Kyler. Mr. Kylers breach of the contract further caused Plaintiffs to sustain potential losses from films or videos that were never produced. WHEREFORE, Plaintiffs, Flava Works, Inc. and Phillip Bleicher, request that a judgment be entered in favor of Plaintiffs and against Defendant, Jamie Alistair Gonzalez for damages in an amount in excess of $50,000.00 plus punitive damages and costs.

Respectfully Submitted,

______________________________ Meanith Huon Attorney No. 44320 PO Box 441 Chicago, Illinois 60690 (312) 405-2789 Fax No.: (312) 268-7276 (Please us the above mailing address.)

Flava Works, Inc. 933 West Irving Park Road Suite C Chicago, IL 60613-3074

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION Flava Works, Inc. and Phillip Bleicher, Plaintiffs, ) ) ) ) ) ) ) ) ) ) ) Defendant. )

Case No2011-L-008115

v.

COMPLAINT JURY TRIAL DEMANDED

Jamie Alistair Gonzalez ,

VERIFICATION

Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certifies as aforesaid that he verily believes the same to be true. _____________________________________ PHILLIP BLEICHER