1 2 3 4 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 I 27 28 P1LLSBURY WINTHROP SHAW PITTMAN LLP REYNOLD L. SIEMENS #177956 reynold.siemens(a),pillsburylaw.com MARIAH BRANDT #224076 [email protected]725 South Figueroa Street, Suite 2800 Los Angeles, CA 90017-5406 Telephone: (213) 488-7100 Facsimile No.: (213) 629-1033 Attorneys for Plaintiffs RIDDELL, INC., ALL AMERICAN SPORTS CORPORATION, RIDDELL SPORTS GROUP, INC., EASTON-BELL SPORTS, INC., EASTON-BELL SPORTS, LLC, EB SPORTS CORP. and RBG HOLDINGS CORP. FILED APR 122012 fvke, bxe^iive Otlicer/Cltrk Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES RIDDELL, INC., ALL AMERICAN SPORTS CORPORATION, RIDDELL SPORTS GROUP, INC., EASTON-BELL SPORTS, INC., EASTON-BELL SPORTS, LLC, EB SPORTS CORP., and RBG HOLDINGS CORP., Plaintiffs, vs. Case No. BC482698 UNLIMITED JURISDICTION COMPLAINT FOR DECLARATORY RELIEF, BREACH OF CONTRACT, AND BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING JURY TRIAL DEMANDED 30 8 ACE AMERICAN INSURANCE COMPANY, AMERICAN HOME ASSURANCE CO., ARROWOOD INDEMNITY COMPANY, ASSOCIATED INTERNATIONAL INSURANCE COMPANY, CENTURY INDEMNITY COMPANY, COLUMBIA CASUALTY COMPANY, THE EMPLOYERS' FIRE INSURANCE COMPANY, ILLINOIS NATIONAL INSURANCE CO., INSURANCE COMPANY OF NORTH AMERICA, LUMBERMENS MUTUAL CASUALTY COMPANY, STEADFAST INSURANCE COMPANY, TRANSPORT INDEMNITY COMPANY, and DOES 1-50, Defendants. 50 "O •» m i- 3> £2 S —i m a rn •—« m £ as -o rn »m a> S 2 S3 21 •« 35 «• us wj m •> -e. <p R at o O -J CO o O 3: 403425655v2 COMPLAINT FOR DECLARATORY RELIEF, BREACH OF CONTRACT, AND BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
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P1LLSBURY WINTHROP SHAW PITTMAN LLP
REYNOLD L. SIEMENS #177956reynold.siemens(a),pillsburylaw.comMARIAH BRANDT #[email protected] South Figueroa Street, Suite 2800Los Angeles, CA 90017-5406Telephone: (213) 488-7100Facsimile No.: (213) 629-1033
RIDDELL, INC., ALL AMERICANSPORTS CORPORATION, RIDDELLSPORTS GROUP, INC., EASTON-BELLSPORTS, INC., EASTON-BELL SPORTS,LLC, EB SPORTS CORP., and RBGHOLDINGS CORP.,
Plaintiffs,
vs.
Case No.
BC482698
UNLIMITED JURISDICTION
COMPLAINT FORDECLARATORY RELIEF, BREACHOF CONTRACT, AND BREACH OFTHE IMPLIED COVENANT OF
GOOD FAITH AND FAIR DEALING
JURY TRIAL DEMANDED
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ACE AMERICAN INSURANCECOMPANY, AMERICAN HOMEASSURANCE CO., ARROWOODINDEMNITY COMPANY, ASSOCIATEDINTERNATIONAL INSURANCECOMPANY, CENTURY INDEMNITYCOMPANY, COLUMBIA CASUALTYCOMPANY, THE EMPLOYERS' FIREINSURANCE COMPANY, ILLINOISNATIONAL INSURANCE CO.,INSURANCE COMPANY OF NORTHAMERICA, LUMBERMENS MUTUALCASUALTY COMPANY, STEADFASTINSURANCE COMPANY, TRANSPORTINDEMNITY COMPANY, and DOES 1-50,
Defendants.
50 "O •»m i- 3>£2 S —im a rn•—« m£ as -orn »m a>
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403425655v2
COMPLAINT FOR DECLARATORY RELIEF, BREACH OF CONTRACT, AND BREACH OF THEIMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
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Plaintiffs RIDDELL, INC., ALL AMERICAN SPORTS CORPORATION,
34. The Excess Policies include the following policies issued by certain
Insurers and/or their predecessors:
Insurer Policy No. Policy Period
Arrowood f/k/a RoyalIndemnity, successor ininterest to Globe
GLA-100207 3/31/1965 3/31/1968
American Home 35-15-48 3/31/1968-12/22/1969American Home 35-15-48 12/23/1969-3/31/1971American Home CE 35-15-48 3/31/1971-10/31/1971
American Home BE 267-71-55 10/31/1971 -10/31/1974Columbia RDX 4169594 42 4/22/1979 4/22/1980Transport TUL 675407 4/22/1982 8/19/1982Transport TUL 675426 8/19/1982 4/22/1983Transport TUL 675434 4/22/1983 4/22/1984Transport TUL 675458 4/22/1984 4/22/1985Illinois National BE 357-02-65 1/31/1998 1/31/2009Steadfast SCO 9672420-00 8/1/2008 1/31/2010Steadfast SCO 9672420-01 1/31/2010 7/31/2011
35. The losses incurred by Plaintiffs in connection with the Underlying
Actions fall or potentially fall within the scope of coverage of these Policies.403425655v2 - 6 -
COMPLAINT FOR DECLARA"
IMPLIED CON
ORY RELIEF, BREACH OF CONT/ENANT OF GOOD FAITH AND F/
RACT, AND BREACH OF THEUR DEALING
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Accordingly, pursuant to the terms of the Policies and under the law, Insurers have
the duty to defend and/or indemnify Plaintiffs for losses incurred in connection with
the Underlying Actions, subject to each policy's terms, indemnity limit, deductible,
or attachment point.
36. To date, Arrowood, Employers' Fire, and ACE/Century/INA have
agreed to defend Riddell against the Underlying Actions, and Steadfast has agreed to
defend upon exhaustion of its self-insured retention, subject to a reservationof
rights. Other Insurers that have a duty to defend have refused to honor their defense
obligations. The Insurers have not agreed to indemnify plaintiffs against the
Underlying Actions.
37. As to the Policies, Plaintiffs have paid the required premiums in full
and have satisfied all other conditions to coverage, or are otherwise excused from
doing so. All actions taken by Plaintiffs with respect to the above loss have been
reasonable, and no action has prejudiced the ability of the Insurers to fulfill their
contractual obligations.
FIRST CAUSE OF ACTION
(For Declaratory Relief as to Duty to Defend)
(Against Lumbermens, American Home, and Columbia)
38. Plaintiffs repeat and incorporate by reference the allegations of
paragraphs 1 through 37above.
39. Pursuant to the terms of certain of the Lumbermens, American Home
and Columbia Policies, these Insurers are obligated to defend Plaintiffs against the
Underlying Actions.
40. These Insurers have failed to defend Plaintiffs against the Underlying
Actions.
41. An actual controversy of a justiciable nature presently exists between
Plaintiffs and these Insurers concerning the proper constructionof the Policies and
403425655v2
COMPLAINT FOR DECLARATORY RELIEF, BREACH OF CONTRACT, AND BREACH OF THEIMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
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the rights and obligations of the parties. The controversy is of sufficient immediacy
to justify the issuance of a declaratory judgment.
WHEREFORE, Plaintiffs pray for relief as set forth below.
SECOND CAUSE OF ACTION
(For Declaratory Relief as to Duty to Indemnify)
(Against All Defendants)
42. Plaintiffs repeatand incorporate by reference the allegations of
paragraphs 1 through 41 above.
43. Pursuant to the terms of the Policies, the Insurers are obligated to
indemnify the Plaintiffs covered by their Policies for the entire amount of losses
incurred in connection with the Underlying Actions, subject to the Policies' limits,
deductibles, or attachment points.
44. None of the Insurers have agreed to indemnify or provide a defense for
any of the Underlying Actions.
45. An actual controversy of a justiciable nature presently exists between
Plaintiffs and Insurers concerning the proper construction of the Policies and the
rights and obligations of the parties with respect to losses incurred by Plaintiffs in
connection with the Underlying Actions. The controversy is of sufficient immediacy
to justify the issuance of a declaratory judgment.
46. WHEREFORE, Plaintiffs pray for relief as set forth below.
THIRD CAUSE OF ACTION
(For Breach of Contract)
(Against Lumbermens, American Home, and Columbia)
47. Plaintiffs repeat and incorporate by reference the allegations of
paragraphs 1 through 46 above.
48. Pursuant to the terms ofcertain of the Lumbermens, American Home
and Columbia Policies, these Insurers are obligated to defend Plaintiffs against the
403425655v2 -8
COMPLAINT FOR DECLARATORY RELIEF, BREACH OF CONTRACT, AND BREACH OF THEIMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
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Underlying Actions.
49. These Insurers have failed to defend Plaintiffs against the Underlying
Actions.
50. Lumbermens, American Home and Columbia have breached the terms
of theirPolicies by refusing to perform theirduty to defend Plaintiffs against the
Underlying Actions.
51. As a direct result of these Insurers' breach of their Policies, Plaintiffs
have been deprived of the benefits of insurance coverage, for which it paid
substantial premiums, with respect to losses incurred by Plaintiffs in connection with
the Underlying Actions.
52. WHEREFORE, Plaintiffs pray for relief as set forth below.
FOURTH CAUSE OF ACTION
(For Breach of the Implied Covenant of Good Faith and Fair Dealing)
(Against American Home and Lumbermens)
53. Plaintiffs repeat and incorporateby reference the allegations of
paragraphs 1 through 52 above.
54. Implied in each of the Insurers' Policies is a covenant that they will act
in good faith and deal fairly with their insureds; that they will do nothing to interfere
with their insured's rights to receive the benefits of the Policies; that they will not
place their own interests before those of their insureds; that they will exercise
diligence, good faith, and fidelity in safeguarding the interests of their insureds; that
they will deal ethically with their insureds and will fairly and adequately inform
them of the nature and scope of their insurancecoverage (hereinafter referred to as
"the impliedcovenant of good faith and fair dealing").
55. American Home and Lumbermens have each breached the implied
covenant of good faith and fair dealing by, inter alia:
a. Refusing fully to defend and/or indemnify Riddell for covered
403425C>55v2 -9
COMPLAINT FORDECLARATORY RELIEF, BREACH OF CONTRACT, ANDBREACH OF THEIMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
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403425655v2
liabilities, as defined in their Policies, without regard to relevant
insurance policy language, relevant law, and the specific facts
of the claim;
Interpreting the terms and conditions of their Policies in an
unreasonable manner, which is wholly inconsistent with
applicable law, solely in an effort to avoid providing Riddell
with coverage to which it is entitled under the Policies;
Refusing to acknowledge coverage, or withdraw or alter their
denials of coverage, notwithstanding their inability to identify
supporting legal or factual authority for their coverage defenses,
and decisions of other Courts rejecting their legal and/or factual
contentions;
Inventing spurious grounds for avoidance of coverage without
regard to the pertinent policy language, facts, or law;
Failing to provide promptly a reasonable explanation of the
basis relied on, in relation to the facts or applicable law, for the
denial of coverage;
Not attempting in good faith to negotiate a prompt, fair, and
reasonable settlement within policy limits of Riddell's claims;
Failingto provide Riddell with copies of documents evidencing
the terms of coverage when requested;
h. Forcing Riddell to file this litigation in order to obtain the rights
and benefits to which it is entitled under their Policies.
56. Plaintiffs are informed and believe and thereon alleges, that American
Homeand Lumbermens are in breach of the implied covenant of good faith and fair
dealing, did the things and committed the wrongful acts allegedabove, among other
things, for thepurpose of willfully and consciously withholding from Plaintiffs the
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COMPLAINT FOR DECLARATORY RELIEF, BREACH OF CONTRACT, AND BREACH OF THEIMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
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rights and benefits to which they are entitled under their Policies and in complete
disregard of said rights; in so doing, American Home and Lumbermens have placed
their own interests above those of Plaintiffs for the purpose of retaining and using
money that should have been spent on the defense of Riddell.
57. Pursuant to Brandt v. Superior Court, 37 Cal. 3d 813 (1983), Plaintiffs
are entitled to recover all attorneys' fees and expenses that they reasonably have
incurred and will incur, in their efforts to obtain the benefits of insurance that have
been, and continue to be, wrongfully and in bad faith withheld by American Home
and Lumbermens.
58. The wrongful conduct alleged herein was done with conscious
disregard of Plaintiffs' rights and with the intent to vex, injure or annoy Plaintiffs,
such as to constitute oppression, fraud or malice under California Civil Code Section
3294, thereby entitling Plaintiffs to punitive damages in an amount appropriate to
punish or set an example of Lumbermens and American Home.
WHEREFORE, Plaintiffs pray for relief as set forth below:
PRAYER FOR RELIEF
Plaintiffs request that the Court enter judgment as follows:
59. On the First Cause of Action, for a declaration that the Lumbemens,
American Home and Columbia policies impose on those Insurers a duty to defend
Riddell against the Underlying Actions, as more fully described above;
60. On the Second Cause of Action, for a declaration that the Insurers have
a duty to indemnify the Plaintiffs insured under their Policies against the Underlying
Actions.
61. On the Third and Fourth Causes of Action:
a. Compensatory and general damages according to proof;
b. Special and incidental damages according to proof;
c. Prejudgment interest at the maximum legal rate;
403425655v2 -11
COMPLAINT FOR DECLARATORY RELIEF, BREACH OF CONTRACT, AND BREACH OF THEIMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
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62. For costs of suit; and
63. Forsuch otherand further reliefas theCourtdeems appropriate.
Dated: April 12,2012.
PILLSBURY WINTHROP SHAW PITTMAN LLPREYNOLD L. SIEMENS725 South Figueroa Street, Suite 2800Los Angeles, CA 90017-5406
REYNOLD L. SIEMENS #I77956/MARIAH BRANDT #224076725 S. Rfiucroa Street, Suite 2800, I^os AiiReles, CA 90017-5406
TELEPHONE-NO, (213) 488-7100 FAX NO, (213) 629-1033attorney for (N^m): Kiddeil, Inc., All American Sports Corporation, et al.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANG ELESSTREET ADDRESS: ] | | ft. Hill StreetMAILING ADDRESS:
city and zip code: Los Angeles, CA 90012branch name: StanleyMosk Courthouse
CASE NAME:
RIDDELL, INC., ct al. v. ACE AMERICAN INSURANCE, et al.
CM-010ouitr use ONLY
••*»•&•!»*fohn
•Qeputv
CIVIL CASE COVER SHEET
CZ3 Unlimited • Limited(Amount (Amountdemanded demanded is
exceeds $25,000) $25,000 or less)
Complex Case Designation
I I Counter I I Joinder
Filed with first appearance by defendant(Cal. Rules of Court, rule 3.402)
CASE NUMBER:
BC482 69 8JUDGE?
DEPT:
Items 1-6 below must be completed (see instructions on page 2).1. Check one box below for the case type that
Auto Tort
Auto (22)
Uninsured motorist (46)
Other PI/PD7WD (Porsonal Injury/PropertyDamagorWrongful Death) Tort
LZH Asbestos (04)CD Product liability (24)I I Medical malpractice (45)• Other PI/PD/WD (23)Non-PI/PD/WO (Other) Tort
Business tort/unfair business practice (07)
I I Civil rights (08)I I Defamation (13)
Fraud (16)
Intellectual property (19)
Professional negligence (25)
Other non-Pt/PD/WD tort (35)
Employment
|_ | Wronglul termination (36)I I Other employment (15)
•
••••
^--"2. This case I / I is I I is not complex under rule 3.400 of the California Rules ofCourt. If the caseiscomplex, mark thefactors requiring exceptional judicial management:
best describes this case:
Contract
•••
•
Breach of contract/warranty (06)
Rule 3.740 collections (09)
Other collections (09)
Insurance coverage (18)
Other contract (37)
Real Property
| | Eminent domain/Inversecondemnation (14)
I I Wrongful eviction (33)I I Other real property (26)Unlawful Detainer
[......".] Commercial (31)I I Residential (32)• Drugs (38)Judicial Review
L_J Asset forfeiture (05)I I Petition re: arbitration award (11)I I Writ of mandate (02)(_] Other judicial review (39)
Provisionally Complex Civil Litigation(Cal. Rules of Court, rules 3.400-3.403)
I I Antitrust/Trade regulation (03)L_J Construction defeet (10)CZ3 Mass tort (40)I I Securities litigation (28)I I Environmental/Toxic tort (30)I </ I Insurance coverage claims arising from the
above listed provisionally complex casetypes (41)
Enforcement of Judgment
I I Enforcement ofjudgment (20)Miscellaneous Civil Complaint
CZ3 RICO (27)I I Other complaint (not specified above) (42)Miscellaneous Civil Petition
I I Partnership and corporate governance (21)I I Other petition (not specified above) (43)
a. I / I Large number ofseparately represented partiesb. [_/J Extensive motion practice raising difficult or novel
issues thatwill be time-consuming to resolvec. I I Substantial amount of documentary evidence
3. Remedies sought (check all that apply): a.l / I monetary4. Number ofcauses ofaction (specify): Four (4)5. This case I I is I / I is not a class action suit.6. Ifthere are any known related cases, file and serve a notice of related case. (Youmay use form CM-C15.)
Date: April 12,2012 4Reynold L. Siemens h
d.1 ILarge number ofwitnessese. I / ICoordination with related actions pending in oneormore courts
inothercounties, states, or countries, or ina federal courtf. 1 1Substantial postjudgment judicial supervision
(TYPE OR PRINT NAME) (Sll "RE OFPARTY OR ATTORNEY FORPARTY)
NOTICE• Plaintiff must file this cover sheet with the first paper filed in the actionor proceeding (except small claimscases or cases filed
underthe Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule3.220.)Failure to file mayresultin sanctions.
• File this cover sheet in addition to any cover sheet required by local court rule.$• If this case iscomplex under rule 3.400 et seq. of the California Rules ofCourt, you must servea copy of this cover sheet on all"i other parties to the actionor proceeding.»• Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only'*i | . Pi
*535E55i5" CIVIL case cover sheetCM-OtO [Rev. July t, 2Q07|
Pago 1 of 2
Cfll. Rules of Court, rules 2.30.3.220, 3.400-3 403, 3.740.Cal. Standards of Judicial Administration, std. 3.10
www.courtinla.ca.gav
American LegaiNut, Inc.www. FormsWorkflow.oom
SHORT TITLE:
RIDOELL, INC. vs. ACE AMERICAN INSURANCE COMPANY, et al.CASE NUMBER
«£<**6*8-CIVIL CASE COVER SHEET ADDENDUM AND
STATEMENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.
Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL? EyES CLASS ACTION? D YES LIMITED CASE? DyES TIME ESTIMATED FOR TRIAL 15 D HOURS/ B DAYS
Item II. Indicate the correct district and courthouse location (4 steps - Ifyou checked "Limited Case", skip to Item III, Pg. 4):
Step 1: After first completing the Civil CaseCover Sheet form, find the main Civil CaseCover Sheet heading for yourcase in the left margin below, and, to the right in Column A, the Civil Case CoverSheet case type youselected.
Step 2: Checkone Superior Courttype ofaction in Column B below which best describes the nature of thiscase.
Step 3: In Column C, circle the reason for thecourt location choice that applies tothe type ofaction you havechecked. For any exception to the court location, see Local Rule 2.0.
Applicable Reasons for Choosing Courthouse Location (see Column C below)
1. Class actions must be filed in the Stanley Mosk Courthouse, central district.2. May be filed in central (other county, or no bodily injury/property damage).3. Location where cause of action arose.4. Location where bodily injury, death or damage occurred.5. Locationwhere performance required or defendant resides.
6. Locationof propertyor permanently garaged vehicle.7. Location where petitioner resides.8. Location wherein defendant/respondent functions wholly.9. Locationwhere one or more of the parties reside.
10. Location of Labor Commissioner Office
Step 4: Fill in the information requested on page4 in Item III; complete Item IV. Sign thedeclaration.
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ACivil Case Cover Sheet
Category No.
BType of Action
(Check only one)
cApplicable Reasons -
See Step 3 Above
Auto (22) D A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death 1..2..4.
Uninsured Motorist (46) • A7110 Personal Injury/PropertyDamage/Wrongful Death - Uninsured Motorist 1,2., 4.
Asbestos (04)O A6070 Asbestos Property Damage
• A7221 Asbestos - Personal Injury/Wrongful Death
2.
2.
Product Liability(24) D A7260 Product Liability (not asbestos or toxic/environmental) 1..2..3..4..8,
Medical Malpractice (45)a A7210 Medical Malpractice - Physicians &Surgeons
D A7240 Other Professional Health Care Malpractice
1..4.
1..4.
Other
Personal InjuryProperty DamageWrongful Death
(23)
D A7250 Premises Liability (e.g., slip and fall)
• A7230 Intentional Bodily Injury/PropertyDamageArVrongful Death (e.g.,assault, vandalism, etc.)
Q A7270 Intentional Infliction of Emotional Distress
D A7220 Other Personal Injury/PropertyOamageAVrongful Death
1„4.
1..4.
1„ 3.
1..4.
IfACIV 109 (Rev. 03/11)LASC Approved 03-04
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION
Local Rule 2.0
Page 1 of 4American l.cgiil.Vct, Inc.•mn .FumnWofkr-tow.cimi
SHORT TITLE:
RIDDELL, INC., et al. vs. ACE AMERICAN INSURANCE, et al.CASE NUMBER
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ACivil Case Cover Sheet
Category No.
BType of Action
.;*"'. '• " (Check only one)
CApplicable Reasons -
See Step 3 Above
Business Tort (07) D A6029 OtherCommercial/Business Tort (not fraud/breachof contract) 1..3.
Civil Rights (08) D A6005 Civil Rights/Discrimination 1..2, 3.
Defamation (13) D A6010 Defamation (slander/libel) 1..2..3.
Fraud (16) a A6013 Fraud (no contract) 1„ 2. 3.
Professional Negligence (25)a A6017 Legal Malpractice
Q A6050 Other ProfessionalMalpractice (notmedicalor legal)
1.. 2., 3.
1,2., 3.
Other (35) D A6025 Other Non-Personal Injury/Property Damage tort 2,3.
Wrongful Termination (36) D A6037 Wrongful Termination 1..2., 3.
Other Employment (15)• A6024 Other Employment Complaint Case
D A6109 Labor Commissioner Appeals
1„ 2., 3.
10.
Breach of Contract/ Warranty(06)
(not insurance)
D A6004 Breach of Rental/Lease Contract (not unlawfuldetainer or wrongfuleviction)
D A6107 Confession of Judgment (non-domestic relations)
D A6140 Administrative AgencyAward(not unpaid taxes)
D A6114 Petition/Certificate for Entryof Judgment on UnpaidTax
D A6112 Other Enforcementof Judgment Case
2., 9.
2,6.
2., 9.
2., 8.
2„8.
2., 8., 9.
RICO (27) O A6033 Racketeering (RICO) Case 1„2..8.
Other Complaints(Not Specified Above) (42)
0 A6030 Declaratory Relief Only
D A6Q40 Injunctive Relief Only (not domestic/harassment)
• A6011 Other Commercial Complaint Case (non-tort/non-cornplex)
• A6000 Other Civil Complaint (non-tort/non-complex)
1..2..8.
2,8.
1., 2., 8.
1., 2.,8.
Partnership CorporationGovernance (21) D A6113 Partnership and Corporate Governance Case 2., 8.
Other Petitions
(Not Specified Above)(43)
a A6121 Civil Harassment
Q A6123 Workplace Harassment
a A6124 Eider/Dependent Adult Abuse Case
a A6190 Election Contest
D A6110 Petition for Change of Name
O A6170 Petition for Relief from Late Claim Law
D A6100 Other Civil Petition
2., 3., 9.
2., 3.. 9.
2., 3., 9.
2.
2., 7.
2., 3„4.,8.
2., 9.
LACIV 109 (Rev. 03/11)
LASC Approved 03-04
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATIONAmerica* l,ci;i)Nrt, Inc.
Local Rule 2.0
-j Page 3of 4
SHORT TITLE:
RIDDELL, INC., et al. vs. ACE AMERICAN INSURANCE, et al.CASE NUMBER
Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or othercircumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected.
REASON: Check the appropriate boxes for the numbers shownunder Column C for the type of action that you have selected forthis case.
DT. D2. D3. D4. 05. D6. 07. D8. L7J9. D10.
ADDRESS:
818 W. Seventh Street
Los Angeles, CA 90017
CITY:
Los Angeles
STATE:
CA
ZIP COOE:
90017
Hem IV. Declaration of Assignment: Ideclare under penalty of perjuryunder the laws of the State of California that the foregoingis true
and correct and that the above-entitled matter is properly filed for assignment to the Stanley Mosk courthouse in theDistrict of the Superior Court of California, County of Los Angeles [Code Civ. Proc, § 392 et seq., and LocalCentral
Rule 2.0, subds. (b), (c) and (d)].
Dated: April 12, 2012
AtURE OF ATTORNEY/FIUNG PARTY)(SIGNAt
Reynold L. Siemens
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLYCOMMENCE YOUR NEW COURT CASE:
1. Original Complaint or Petition.
2. If filing a Complaint, a completed Summons form for issuance by the Clerk.
3. Civil Case Cover Sheet, Judicial Council form CM-010.
4. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.03/11).
5. Payment in full of the filing fee, unless fees have been waived.
6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiffor petitioner is aminor under 18 years of age will be required by Court in order to issue a summons.
7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendummust be served along with the summons and complaint, or other initiating pleading in the case.
LACIV109 (Rev. 03/11)
LASC Approved 03-04
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION AmfrlciB lxg»lN'cl, Inc.