CIVIL COVER SHEET filed by Movants AMERICAN VIDEO DUPLICATING INC, KENNETH M.… — Agent Fee Litigation (Dkt. 2)

Summary

The civil cover sheet filed April 27, 2020 as Doc. 2 in American Video Duplicating, Inc., et al. v. Citigroup Inc., Citibank, N.A., et al., No. 2:20-cv-03815-ODW-AGR, in the U.S. District Court for the Central District of California. It lists Los Angeles as the first plaintiff's county of residence and Delaware for the first defendant, with counsel from Geragos & Geragos, Graylaw Group, Inc. and Dhillon Law Group, Inc. The form marks the case as a class action under F.R.Cv.P. 23 and states a money demand of $3,848,597,082.00. The causes of action listed are the Class Action Fairness Act, 28 U.S.C. Section 1332(d), declaratory relief, unfair business practices under California Business & Professions Code Section 17200, and unjust enrichment. The 3-page form designates the Western Division.

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Case 2:20-cv-03815-ODW-AGR Document 2

Filed 04/27/20

UNITED STATES DISTRICT COURT,#ENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET

Page 1of3 Page ID

I. (a) PLAINTIFFS ( Check box if you are representing yourself ["] )

AMERICAN VIDEO DUPLICATING, INC., a California corporation, et al.

DEFENDANTS

( Check box if you are representing yourself [_ ] )

CITIGROUP INC,, CITIBANK, N.A,, et al.

(b) County of Residence of First Listed Plaintiff Los Angeles
(EXCEPT IN U.S. PLAINTIFF CASES)

(IN U.S. PLAINTIFF CASES ONLY)

County of Residence of First Listed Defendant Delaware

(c) Attorneys (Firm Name, Address and Telephone Number) If you are
representing yourself, provide the same information.

Mark J. Geragos, Geragos & Geragos, 644 South Figueroa Street, Los Angeles, CA
90017, (213) 625-3900. Michael E. Adler, Graylaw Group, Inc., 21515 Hawthorne Blvd.,

Suite 450, Torrance, CA 90503. (310) 540-2000. Harmeet K. Dhillon, Dhillon Law

Group, Inc., 177 Post Street, Suite 700, San Francisco, CA 914108, (415) 433-1700.

Attorneys (Firm Name, Address and Telephone Number) If you are
representing yourself, provide the same information.

Il. BASIS OF JURISDICTION (Place an X in one box only.)

1. U.S. Government
Plaintiff

2. U.S. Government
Defendant

3. Federal Question (U.S.
Government Not a Party)

4. Diversity (Indicate Citizenship
of Parties in Item III)

IV. ORIGIN (Place an X in one box only.)

1. Original
Proceeding

2. Removed from
State Court

O

Appellate Court

II. CITIZENSHIP OF PRINCIPAL PARTIES-For Diversity Cases Only
(Place an X in one box for plaintiff and one for defendant)
- f This Stat By aie Incorporated or Principal Place Br 4 aie
MzenVor Nis tate of Business in this State

Citizen of Another State [] 2 2 Incorporated and Principal Place [_] 5 5
of Business in Another State

Citizen or Subject of a ; ‘
F Nat

Foreign Country C13 CL) 3 foreignivenen Uses

3, Remanded from O 4. Reinstated or O 5. Transferred from Another OC &. ieee O a deters
Reopened District (Specify) Transfer Direct File

V. REQUESTED IN COMPLAINT: JURY DEMAND: Yes [] No
CLASS ACTION under F.R.Cv.P. 23:

>x]Yes [_]No

(Check "Yes" only if demanded in complaint.)

[_] MONEY DEMANDED IN COMPLAINT: $ 3,848,597,082.00

VI. CAUSE OF ACTION (cite the U.S. Civil Statute under which you are filing and write a brief statement of cause. Do not cite jurisdictional statutes unless diversity.)
Class Action Fairness Act, 28 U.S.C. Section 1332(d); Declaratory Relief; Unfair Business Practices in Violation of California Business & Professions Code Section 17200, et seq,;

Unjust Enrichment

Vil. NATURE OF SUIT (Place an X in one box only).

| OTHER STATUTES CONTRACT REAL PROPERTY CONT. IMMIGRATION PRISONER PETITIONS PROPERTY RIGHTS
[1] 375 False Claims Act [_] 110 Insurance ([] 240 Torts to Land oO Aiton Habeas Corpus: [] 820 Copyrights

376 Qui Tam 1] 120 Marine []_ 245 Tort Product L] 463 Alien Detainee [-] 830 Patent
oO (31 USC 3729(a)) Liability 465 Other [5] 310 Motions to Vacate

a [J 130 Miller Act 290 All Other Real |L] immigration Actions Sentence 835 Patent - Abbreviated
O New Di licati

0 ees 140 Negotiable a TORTS [_] 530General vlan aaairamiaadl

Reapportionment OC instrument __ TORTS PERSONAL PROPERTY |[_] 535 Death Penalty [] 840 Trademark
[] 410 Antitrust Ui Recovery of aBOI INJURY [-] 370 Other Fraud Other: SOCIAL SECURITY |

: verpaymen 3 irplane
O iso ae on Mee O Enforcement of 315 Airplane (] 371 Truth in Lending [_] 540 Mandamus/Other U oe i vee
ommerce esis nen 2
CO Rates/etc. " ‘sgment C1 Product Liability | 380 Other Personal |L] 550 Civil Rights Ol BeLagtaZe)
[J 460 Deportation [-] 151 Medicare Act Oo a2 Assan Libel & Property Damage 555 Prison Condition _|[_] 863 DIWC/DIWW (405 (g))
ander - .
. 152 Reco f , 385 Property Damage 560 Civil Detainee 864 SSID Title XVI
O need & Corrt 4 Or O Defaulted Student Cl] #8 Fed. Employers’ |[] Product Liability Conditions of 5
[1 480 r ih Loan (Excl. Vet.) Liability “7 BANKRUPTCY. Confinement [_] 865 RSI (405 (g))
onsumer Credi 40 Mari {
[J 490 Cable/Sat TV 153 Recovery of | |J 3 is Marine Product |] 422Appeal 28 POREEITURE/RENAETY FEDERAL TAXSUITS |
” LJ Overpayment of [CJ [Liability USC 158 625 Drug Related 870 Taxes (U.S. Plaintiff or

oO 850 Securities/Com- Vet. Benefits 423 Withdrawal 28 CI Seizure of Property 21 |] Defendant)

modities/Exchange , | 350Motor Vehicle |L) ysc 157 USC 881 :

Oo 160 Stockholders : 690 Oth Oo 871 IRS-Third Party 26 USC

890 Other Statutory Suits Oo 355 Motor Vehicle CIVILRIGHTS — | er 7609

O Actions Product Liability [J] 440 Other Civil Right LABOR
; 190 Other er Civil Rights :

[-] 891 Agricultural se O Contract o a Personal Fy] ast voting = 710 Fair LaberStandards

893 Environmenta - Act
CL 195 Contract 362 Personal Injury-

nln CI) Product Liability LI Med Malpratice L] 442 Employment [q 720 Labor/Mgmt.
Oo oe Freedom of Info. (1 196 Franchise 365 Personal Injury- |] 443 Housing/_ Relations

ct oO sataili Accommodations ;
Product Liability LJ 740 Railway Labor Act
[] 896 Arbitration REAL PROPERTY Ithc 445 American with . .
367 Healthy Carer isabiliti 751 Family and Medical
; [J Disabilities- amlly'ang Med
‘ [J 210 Land Pharmaceutical CT

899 Admin. Procedures Condemnation O Personal Injury Employment Leave Act

L] Act/Review of Appeal of Product Liabilit 446 American with 790 Other Labor
[-] 220 Foreclosure y Oo oO

Agency Decision sani elo 368 Asbestos Disabilities-Other Litigation

950 Constitutionality of 0 Rent Lease P lInj ; 791 Employee Ret. Inc.
O State Statutes OL] 5 reece Liabilt L] 448 Education C] i

Ejectment Product Liability Security Act
FOR OFFICE USE ONLY: Case Number:
CIVIL COVER SHEET Page 1 of 3

CV-71 (05/17)
Case 2:20-cV-O2 fi FEDS? HtES GISTRIC? CGURE CENTRAL DRSTAICTOF CRLIFORMIR 2 Of 3 Page ID

CIVIL COVER SHEET

VIII. VENUE: Your answers to the questions below will determine the division of the Court to which this case will 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?

STATE CASE WAS PENDING IN THE COUNTY OF;

INITIAL DIVISION IN CACD Is:

[] Yes No

If "no," skip to Question B. If "yes," check the
box to the right that applies, enter the

corresponding division in response to
Question E, below, and continue from there.

CL] Los Angeles, Ventura, Santa Barbara, or San Luis Obispo Western
[] Orange Southern
Eastern

[-] Riverside or San Bernardino

QUESTION B: Is the United States, or
one of its agencies or employees, a
PLAINTIFF in this action?

[] Yes No

B.1. Do 50% or more of the defendants who reside in
the district reside in Orange Co.?

==>

check one of the boxes to the right

YES. Your case will initially be assigned to the Southern Division.
Enter "Southern" in response to Question E, below, and continue
from there.

NO. Continue to Question B.2.

If "no," skip to Question C. If "yes," answer
Question B.1, at right.

B.2. Do 50% or more of the defendants who reside in
the district reside in Riverside and/or San Bernardino
Counties? (Consider the two counties together.)

check one of the boxes to the right

=>

YES, Your case will initially be assigned to the Eastern Division.
Enter "Eastern" in response to Question E, below, and continue
from there.

NO. Your case will initially be assigned to the Western Division.
Enter "Western" in response to Question E, below, and continue
from there.

QUESTION C: Is the United States, or
one of its agencies or employees, a
DEFENDANT in this action?

[] Yes No

C.1. Do 50% or more of the plaintiffs who reside in the
district reside in Orange Co.?

a>

check one of the boxes to the right

YES. Your case will initially be assigned to the Southern Division.
Enter "Southern" in response to Question E, below, and continue
from there.

NO. Continue to Question C.2,

If "no," skip to Question D. If "yes," answer
Question C.1, at right.

C.2. Do 50% or more of the plaintiffs who reside in the
district reside in Riverside and/or San Bernardino
Counties? (Consider the two counties together.)

=>

check one of the boxes to the right

YES. Your case will initially be assigned to the Eastern Division.
Enter "Eastern" in response to Question E, below, and continue
from there.

NO. Your case will initially be assigned to the Western Division.

[J Enter "Western" in response to Question E, below, and continue
from there.
A, B. Cc
oe Riverside or San Los Angeles, Ventura,
QUESTION D: Location of plaintiffs and defendants? Orange County Bernardino County | Santa Barbara, or San

Luis Obispo County

Indicate the location(s) in which 50% or more of plaintiffs who reside in this district
reside. (Check up to two boxes, or leave blank if none of these choices apply.)

O

O

Indicate the location(s) in which 50% or more of defendants who reside in this
district reside. (Check up to two boxes, or leave blank if none of these choices

apply.)

O

UO O

D.2. Is there at least one answer in Column B?

D.1. Is there at least one answer in Column A?
[_] Yes No

If "yes," your case will initially be assigned to the
SOUTHERN DIVISION.

Enter "Southern" in response to Question E, below, and continue from there,

=>

If "no," go to question D2 to the right.

[] Yes No

If "yes," your case will initially be assigned to the
EASTERN DIVISION.

Enter "Eastern" in response to Question E, below.

If "no," your case will be assigned to the WESTERN DIVISION,

Enter "Western" in response to Question E, below.

QUESTION E: Initial Division?

INITIAL DIVISION IN CACD

Enter the initial division determined by Question A, B,C, or D above: ms»

WESTERN

QUESTION F: Northern Counties?

Do 50% or more of plaintiffs or defendants in this district reside in Ventura, Santa Barbara, or San Luis Obispo counties?

[_] Yes No

CV-71 (05/17)

CIVIL COVER SHEET

Page 2 of 3

Case 2:20-cv-O2 fit FeO? Kites GISTRIG? COURIE CENTRAL BESTRICHOF CRLIFGRMIE 3 Of 3 Page ID

CIVIL COVER SHEET

IX(a). IDENTICAL CASES: Has this action been previously filed in this court? NO [_] YES

If yes, list case number(s):

IX(b). RELATED CASES: |s this case related (as defined below) to any civil or criminal case(s) previously filed in this court?

NO [] Yes

If yes, list case number(s):

Civil cases are related when they (check all that apply):
[] A. Arise from the same or a closely related transaction, happening, or event;
| B. Call for determination of the same or substantially related or similar questions of law and fact; or

L] C. For other reasons would entail substantial duplication of labor if heard by different judges.

Note: That cases may involve the same patent, trademark, or copyright is not, in itself, sufficient to deem cases related.

A civil forfeiture case and a criminal case are related when they (check all that apply):
[_] A. Arise from the same or a closely related transaction, happening, or event;

[_] B. Call for determination of the same or substantially related or similar questions of law and fact; or

C. Involve one or more defendants from the criminal case in common and would entail substantial duplication of
labor if heard by different judges.

2
X. SIGNATURE OF ATTORNEY | -
(OR SELF-REPRESENTED LITIGANT): DATE: UV [22 [229% Z

Notice to Counsel/Parties: The submission of this Civil Cover Sheet is required by Local Rule 3-1. This Form CV-71 and the information contained herein
neither replaces nor supplements the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. For
more detailed instructions, see separate instruction sheet (CV-071A).

Key to Statistical codes relating to Social Security Cases:

Nature of SuitCode Abbreviation Substantive Statement of Cause of Action

All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended. Also,

861 HIA 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 All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969, (30 U.S.C.
923)

863 DIWC 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))

863 DIWw 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))

864 SSID All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security Act, as
amended.

865 RSI 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 (05/17) CIVIL COVER SHEET Page 3 of 3

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