Russ, AuGusT & KABAT RUSS, AUGUST & KABAT Stanton L, Stein (SBN 45997) |sieing@raklaw.com Diana A. Sanders (SBN 296689) 4 av. 12424 Wilshire Boulevard, 12" Floor Los Angeles, California 90025 Telephone: (310) 826-7474 Facsimile: (310) 826-6991 Attorneys for Plaintiffs Jeff Franklin sand Moose Productions, Inc. SUPERIOR COURT OP THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES JEFE FRANKLIN, an individual; and MOOSE| Case No, PRODUCTIONS, INC, a California corporation, COMPLAINT FOR: Plaintts, (INTENTIONAL INTERFERENCE vs ‘WITH PROSPECTIVE ECONOMIC ADVANTAGE BRYAN BEHAR, an individual; ond DOBS 1- 50, inclusive, Defendant COMPCARTRuss, AuousT& Karat 26 Plaintiffs Jeff Franklin and Moose Productions, Ine. (collectively, “Frankl” hereby allege and complain as follows: NATURE OF HE CASI |, Franklin isan Executive Producer, writer and director esponsible for creating and running Full House, one of the most sucesfil television shows in Americ history and ts award winning and Tmmy-nominted hit spinofT Fuller use, cureatl ia production of ts Sift and final season to be ated on Netix. As the het and sou! ofthe Pll House franchise, these tremendously sucess shows ae the gret joy of Franklins profesional ite and the exst ‘nas become a second family to him for over 30 years. Despite iting and supporting Defendant yan Bebe, a writer and Co-Executive Producer on Fidler House Behae was resent of Franklin's sneess, Motivated by a see hatred of Franklin and hoping o take his place someday as showrunner, Her concocted «pli o compile uniatering and distasteful information about Franklin that was ier fabricated o twisted versions of events and presented {tft to the media and then to Warner rshers in an effort to get Franklin thrown off Fuller Howse, Behar even encoucaged others involved with Fuller onset do the same. Behur’s actions tok place a eeueil time when Warnee Brothers was r-negotiting Franklin's ‘agreement to extend Frunklin's services on Fuller House ad amit the then-new #metoo movement i esate srutny over stains al thee employees, rendering Warmer Brothers particularly vulneble and overly cautious sbout any questions of possible of impropity Unfortunately, Betas pla worked as Warner Brothers abrupy stopped all negotiations with Franklin and einsted its relationship with Franklin. In noed ofa showrunne to eary on the schedule for Fuller House's fouts season, Warner Brothers appointed Behar to replace Frain. Franklin now brings this action for Beas’s wrongful inference with Franklin's business relations with Wore Brothers in connection with the show he crested, launched and guided to success Fr three year ‘THEPARTIES, 2. Plaintiff Jeff Franklin is, and atl times material hereto was, aresideo of ‘ovesy Hills California. Jef Franklin san Executive Producer, seeenvriter and diretor 2 COMPLARNTRuss, AUGUST & KABAT responsible for erating and Executive Producing Full Hone, one of the most Sissi television shows in Americas history, nd its avard-vnning spiofT Fuller House, cust in ‘roeton ofits ifs and nal season to be aired on Netix. 3. Plaine? Moose Productions nei, anda all mes material hereto was, a comportion registered under the laws of the Stat of California and headquartered in Beverly ills, Califomia, Moose Production, Inc. ste “loan-ot” corporation wih provides the services of lef ranklin inthe eneriinment dusty. Unless othwise spesifiod herein, Je Franklin and Moose Productions, Inc shall be collectively refed to herein “Frnlin” oF “Plaats” 4, Franklin is informed and belioves, and based tesco alleges, that defendant Betas is resident of Los Angeles, Clin. Behari curently employed asthe Executive Producer and showrunner ofthe television com Fuller House, hic is med in Los Angeles, California, along, with his writing stl producing partner Steve Daldiosk 5. "Thetrue names and capacities ofthe defendants named herein as DOES 1 through 50, acusive, whether in joa, corporate, associate or otherwise, are presently unknown to Fraatin, and therefore Franklin ses these dafenionts by such fictitious names. Franklin will mend this complain o subsite the ue names al capacities when the same have been ascertained, Hankin i inforned and believe, ad based thereon alleges, that each ofthe fettousy named defendant is responsible in some manner for the occurences and damages alleged hereit 6. Franklin formed and believes, and based thereon alleges that each defendant herein snow, and atl nes relevant hereto was, the agent, servant, epresentatve or aller ego ofeach of the ter defendants herein ain, i dong the things hereinafter allged, was sting ‘within the seope of such employment, agency, sepreentation, or aller ego relationship. COMMON ALLEGATIONS 7. Inorabout 1987, Franklin erate, executve-producad, and eo-vrote te thease song for television stom Full House about Danny Taner; « widowed father whose bnoter- ‘nla Jesse an best frend Joey help im rise his three daughters in his Sen Francisco home,